DOE/EA-1626 

FINAL ENVIRONMENTAL ASSESSMENT 

Midwest Geological Sequestration Consortium (MGSC) 

Phase III Large-Scale Field Test 

Decatur, Illinois 

October 2008 

U.S. DEPARTMENT OF ENERGY 

NATIONAL ENERGY TECHNOLOGY LABORATORY 
U.S. Department of Energy MGSC Phase III 

National Energy Technology Laboratory Final Environmental Assessment

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Table of Contents i October 2008 

TABLE OF CONTENTS 

LIST OF TABLES.......................................................................................................................... v

LIST OF FIGURES ........................................................................................................................ v

ACRONYMS AND ABBREVIATIONS...................................................................................... vi

USE OF SCIENTIFIC NOTATION............................................................................................... x

1.0 INTRODUCTION .............................................................................................................. 1

1.1 Summary .......................................................................................................................... 1

1.2 Purpose and Need............................................................................................................. 6

1.3 Legal Framework ........................................................................................................... 10

2.0 PROPOSED ACTION AND ALTERNATIVES ............................................................. 17

2.1 Proposed Action ............................................................................................................. 17

2.1.1 Project Location...................................................................................................... 18

2.1.2 Construction............................................................................................................ 21

2.1.2.1 CO2 Supply...................................................................................................... 21

2.1.2.2 Compression-dehydration Facility .................................................................. 21

2.1.2.3 Pressurized Pipeline......................................................................................... 22

2.1.2.4 Injection Well .................................................................................................. 22

2.1.2.5 Verification Wells............................................................................................ 23

2.1.2.6 Groundwater Monitoring Wells....................................................................... 24

2.1.2.7 Vadose Zone Soil Vapor Monitoring Stations ................................................ 25

2.1.2.8 Atmospheric Modeling Data Collection Stations............................................ 25

2.1.2.9 Injection Well Surface Facilities ..................................................................... 26

2.1.3 Operations and Maintenance................................................................................... 26

2.1.3.1 General............................................................................................................. 26

2.1.3.2 Target Zone and Operational Integrity ............................................................ 27

2.1.3.3 Monitoring, Mitigation, and Validation (MMV) Programs ............................ 30

2.1.4 Decommissioning ................................................................................................... 31

2.2 No-Action....................................................................................................................... 31

2.3 Alternatives Considered but Eliminated from Detailed Analysis .................................. 31

2.4 Issues Considered and Dismissed .................................................................................. 32

3.0 THE ENVIRONMENTAL ANALYSIS APPROACH.................................................... 34

3.1 Approach to the Analysis ............................................................................................... 34

3.2 Analysis of Significance................................................................................................. 40

4.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT AND ENVIRONMENTAL 

EFFECTS...................................................................................................................................... 42

4.1 Air Quality...................................................................................................................... 42

4.1.1 Description.............................................................................................................. 42

4.1.1.1 Climate and Weather ....................................................................................... 42

4.1.1.2 National Ambient Air Quality Standards and Attainment Status.................... 42

4.1.1.3 Local Ambient Air Quality.............................................................................. 43

4.1.1.4 Existing Facility Emissions ............................................................................. 44

4.1.1.5 Greenhouse Gasses and Global Warming ....................................................... 44

4.1.2 Effects of Proposed Action ..................................................................................... 45

4.1.2.1 Estimated Emissions and General Conformity................................................ 45

4.1.2.2 Regulatory Review .......................................................................................... 46
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4.1.2.3 Greenhouse Gasses and Global Warming ....................................................... 47

4.1.3 Effects of No-Action............................................................................................... 48

4.1.4 Cumulative Effects.................................................................................................. 48

4.2 Geology and Soils .......................................................................................................... 48

4.2.1 Description.............................................................................................................. 48

4.2.2 Effects of Proposed Action ..................................................................................... 54

4.2.3 Effects of No-Action............................................................................................... 55

4.2.4 Cumulative Effects.................................................................................................. 55

4.3 Water Resources............................................................................................................. 55

4.3.1 Description.............................................................................................................. 55

4.3.2 Effects of Proposed Action ..................................................................................... 56

4.3.3 Effects of No-Action............................................................................................... 59

4.3.4 Cumulative Effects.................................................................................................. 59

4.4 Wetlands and Floodplains .............................................................................................. 59

4.4.1 Description.............................................................................................................. 59

4.4.2 Effects of Proposed Action ..................................................................................... 62

4.4.3 Effects of No-Action............................................................................................... 62

4.4.4 Cumulative Effects.................................................................................................. 62

4.5 Terrestrial Vegetation..................................................................................................... 62

4.5.1 Description.............................................................................................................. 62

4.5.2 Effects of Proposed Action ..................................................................................... 63

4.5.3 Effects of No-Action............................................................................................... 64

4.5.4 Cumulative Effects.................................................................................................. 64

4.6 Wildlife........................................................................................................................... 65

4.6.1 Description.............................................................................................................. 65

4.6.2 Effects of Proposed Action ..................................................................................... 65

4.6.3 Effects of No-Action............................................................................................... 66

4.6.4 Cumulative Effects.................................................................................................. 66

4.7 Land Use ........................................................................................................................ 66

4.7.1 Description.............................................................................................................. 66

4.7.2 Effects of Proposed Action ..................................................................................... 67

4.7.3 Effects of No-Action............................................................................................... 68

4.7.4 Cumulative Effects.................................................................................................. 68

4.8 Socioeconomic Resources.............................................................................................. 68

4.8.1 Population ............................................................................................................... 69

4.8.1.1 Description....................................................................................................... 69

4.8.1.2 Effects of Proposed Action.............................................................................. 70

4.8.1.3 Effects of No-Action ....................................................................................... 70

4.8.1.4 Cumulative Impacts......................................................................................... 70

4.8.2 Employment and Income ........................................................................................ 70

4.8.2.1 Description....................................................................................................... 70

4.8.2.2 Effects of Proposed Action.............................................................................. 71

4.8.2.3 Effects of No-Action ....................................................................................... 72

4.8.2.4 Cumulative Impacts......................................................................................... 72

4.8.3 Infrastructure........................................................................................................... 73

4.8.3.1 Description....................................................................................................... 73
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4.8.3.2 Effects of Proposed Action.............................................................................. 73

4.8.3.3 Effects of No-Action ....................................................................................... 74

4.8.3.4 Cumulative Impacts......................................................................................... 74

4.8.4 Parks and Recreation............................................................................................... 75

4.8.4.1 Description....................................................................................................... 75

4.8.4.2 Effects of Proposed Action.............................................................................. 75

4.8.4.3 Effects of No-Action ....................................................................................... 75

4.8.4.4 Cumulative Impacts......................................................................................... 75

4.8.5 Visual Resources..................................................................................................... 76

4.8.5.1 Description....................................................................................................... 76

4.8.5.2 Effects of Proposed Action.............................................................................. 76

4.8.5.3 Effects of No-Action ....................................................................................... 76

4.8.5.4 Cumulative Impacts......................................................................................... 76

4.8.6 Noise ....................................................................................................................... 76

4.8.6.1 Description....................................................................................................... 78

4.8.6.2 Effects of Proposed Action.............................................................................. 79

4.8.6.3 Effects of No-Action ....................................................................................... 80

4.8.6.4 Cumulative Impacts......................................................................................... 81

4.8.7 Environmental Justice............................................................................................. 81

4.8.7.1 Description....................................................................................................... 81

4.8.7.2 Effects of Proposed Action.............................................................................. 82

4.8.7.3 Effects of No-Action ....................................................................................... 82

4.8.7.4 Cumulative Impacts......................................................................................... 82

4.9 Human Health and Safety .............................................................................................. 82

4.9.1 Description.............................................................................................................. 82

4.9.2 Effects of Proposed Action ..................................................................................... 84

4.9.3 Effects of No-Action............................................................................................... 87

4.9.4 Cumulative Effects.................................................................................................. 88

4.10 Cultural Resources...................................................................................................... 88

4.10.1 Description.............................................................................................................. 88

4.10.2 Effects of Proposed Action ..................................................................................... 91

4.10.3 Effects of No-Action............................................................................................... 92

4.10.4 Cumulative Effects.................................................................................................. 92

4.11 Waste Management .................................................................................................... 92

4.11.1 Description.............................................................................................................. 92

4.11.2 Effects of Proposed Action ..................................................................................... 94

4.11.3 Effects of No-Action............................................................................................... 94

4.11.4 Cumulative Impacts ................................................................................................ 94

5.0 CONSULTATION AND COORDINATION .................................................................. 96

5.1 Agency Coordination ..................................................................................................... 96

5.1.1 U.S. Fish and Wildlife Service (USFWS) .............................................................. 96

5.1.2 State Historic Preservation Office (SHPO)............................................................. 96

5.1.3 Bureau of Indian Affairs ......................................................................................... 96

5.2 Public Involvement ........................................................................................................ 97

6.0 LIST OF PREPARERS..................................................................................................... 98

6.1 Mangi Environmental Group ......................................................................................... 98
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6.2 Wiebe Environmental Services ...................................................................................... 98

7.0 REFERENCES ................................................................................................................. 99

8.0 GLOSSARY ................................................................................................................... 107

APPENDICES ............................................................................................................................ 112

Appendix A Air Emission Calculations............................................................................. 112

Appendix B USFWS Consultation .................................................................................... 117

Appendix C Noise Calculations......................................................................................... 126

Appendix D SHPO Consultation ....................................................................................... 129

Appendix E Contact with the Bureau of Indian Affairs and Tribal Councils.................... 135
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Table of Contents v October 2008 

LIST OF TABLES 

Table 1.1. Comparison of Impacts................................................................................................. 4

Table 2.1. MGSC Project Timeline ............................................................................................. 17

Table 3.2. Impact Significance Thresholds.................................................................................. 40

Table 4.1.1.3. NAAQS and Monitored Air Quality Concentrations ........................................... 43

Table 4.1.1.4. Existing (2007) Air Emissions for Decatur ADM Complex ................................ 44

Table 4.1.2.1. Proposed Action Emissions Compared to Applicability Thresholds.................... 46

Table 4.1.2.3. Net CO2 Emissions for the Proposed Action........................................................ 47

Table 4.2.1. Map Legend to NRCS-derived Soils Map for ADM Phase III Test Site ................ 54

Table 4.8.2.1. Household Income for 2006 ................................................................................. 71

Table 4.8.3.2. Well Construction Transport Estimate ................................................................. 74

Table 4.8.6-1. Common Sounds and Their Levels ...................................................................... 77

Table 4.8.6-2. State of Illinois Environmental Noise Standards.................................................. 78

Table 4.8.6.1. Estimated Existing Noise Levels at Nearby Noise Sensitive Areas ..................... 78

Table 4.8.6.2-1. Noise Levels Associated with Outdoor Construction ....................................... 79

Table 4.8.6.2-2. Compressor Noise Levels at Nearest NSA Compared to Noise Standards....... 80

Table 4.9.1. Comparison of Natural Gas Pipelines to CO2 Pipelines from 1995 to 2005 ........... 83

LIST OF FIGURES 

Figure 1.2. Map of Regional Carbon Sequestration Partnerships.................................................. 8

Figure 2.1.1-1. Regional Vicinity Map........................................................................................ 19

Figure 2.1.1-2. Project Area Map ................................................................................................ 20

Figure 3.1-1. Cause-Effect-Questions Page 1.............................................................................. 35

Figure 3.1-2. Cause-Effect-Questions Page 2.............................................................................. 36

Figure 3.1-3. Cause-Effect-Questions Page 3.............................................................................. 37

Figure 3.1-4. Cause-Effect-Questions Page 4.............................................................................. 38

Figure 3.1-5. Cause-Effect-Questions Page 5.............................................................................. 39

Figure 4.2.1-1. Illinois Basin’s Stratigraphic Column of Key Formations for CO2 Injection..... 50

Figure 4.2.1-2. Map of Soil Types over the ADM Phase III Test Site ........................................ 53

Figure 4.4.1-1. Water Bodies and Wetlands near the Test Site ................................................... 60

Figure 4.4.1-2. Floodplains near the ADM Phase III Test Site ................................................... 61

Figure 4.10.1. Cemeteries and NRHP-listed Sites near Project Area.......................................... 90
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Acronyms and Abbreviations vi October 2008 

ACRONYMS AND ABBREVIATIONS 

°C Degrees Celsius 

°F Degrees Fahrenheit 

μg/m3 Micrograms per Meter Cubed 

μS/cm Microsiemens per Centimeter 

2D Two Dimensional 

3D Three Dimensional 

ADM Archer Daniels Midland Company 

ANSI American National Standard Institute 

AOR Area of Review 

AQCR 075 West Central Illinois Intrastate AQCR 

AQCR Air Quality Control Region 

ATSDR Agency for Toxic Substances and Disease Registry 

BEA Bureau of Economic Analysis 

BLS Bureau of Labor Statistics 

BMPs Best Management Practices 

CAA Clean Air Act 

CARB California Air Resources Board 

CCAR California Climate Action Registry 

CCS Carbon Capture and Storage 

CEQ Council on Environmental Quality 

CERCLA Comprehensive Environmental Response, Compensation, and Liability 

Act (Superfund) 

CF Center Frequency 

CFR Code of Federal Regulations 

CH4 Methane 

cm Centimeter 

CO Carbon Monoxide 

CO2 Carbon Dioxide 

CWA Clean Water Act 

dB Decibel 

dBA A-weighted Decibel 

DNL Day-night Average Sound Level 

DOE U.S. Department of Energy 

DST Drill Stem Test 

e.g. Exempli gratia, for example 

EA Environmental Assessment 

EDR Environmental Data Resources 

EIA Energy Information Administration 

EIS Environmental Impact Statement 

EOR Enhanced Oil Recovery 

EPCRA Emergency Planning and Community Right-to-Know Act 

ESA Endangered Species Act 

et al. et alia, and others 
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Acronyms and Abbreviations vii October 2008 

et seq. et sequens, and the following one or ones 

etc. et cetera, and so on 

FAA Federal Aviation Administration 

FONSI Finding of No Significant Impact 

ft3

 Cubic Feet 

GHG Greenhouse Gas 

HAARGIS Historic Architectural/Archeological Resources 

HAPs Hazardous Air Pollutants 

HFCs Hydrofluorocarbons 

hp Horsepower 

HYSPLIT Hybrid Single-Particle Lagrangian Integrated Trajectory Model 

Hz Hertz 

i.e. id est, that is 

IAC Illinois Administrative Code 

IDNR Illinois Department of Natural Resources 

IEPA Illinois Environmental Protection Agency 

IHPA Illinois Historic Preservation Agency 

IL Illinois 

ILCS Illinois Compiled Statutes 

IPCB Illinois Pollution Control Board 

IPCC Intergovernmental Panel on Climate Change 

IRGA Infrared Gas Analyzer 

ISGS Illinois State Geological Survey 

kg Kilogram 

km Kilometer 

kPa Kilopascals 

kW Kilowatt 

kWh Kilowatt Hour 

lbs. Pounds 

Ldn Equivalent Day Night Level 

Leq Equivalent Sound Level 

Lw Sound Power Levels 

m Meter 

m

2 Square Meter 

m3 Cubic Meter 

MACT Maximum Achievable Control Technology 

mD Millidarcy 

MDT Modular Formation Dynamics Tester 

MGSC Midwest Geological Sequestration Consortium 

mm Millimeter 

MMV Monitoring, Mitigation, and Validation 

Mt. Mount 

MW Megawatt 

N2O Nitrous Oxide 

NAAQS National Ambient Air Quality Standards 

NEPA National Environmental Policy Act 
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Acronyms and Abbreviations viii October 2008 

NESHAP National Emission Standards for Hazardous Air Pollutants 

NETL National Energy Technology Laboratory 

NHPA National Historic Preservation Act 

NIOSH National Institute for Occupational Safety and Health 

NO2 Nitrogen Dioxide 

NOx Nitrogen Oxides 

NOAA National Oceanic and Atmospheric Administration 

NPDES National Pollutant Discharge Elimination System 

NPS National Park Service 

NRHP National Register of Historic Places 

NSA Noise Sensitive Area 

NSPS New Source Performance Standards 

NSR New Source Review 

O3 Ozone 

OSHA Occupational Safety and Health Administration 

Pb Lead 

PEMAf Palustrine, Emergent, Temporarily Flooded, Farmed 

PFCs Perfluorocarbons 

PM2.5 Particulate Matter Less than 2.5 Micrometers in Aerodynamic Diameter 

PM10 Particulate Matter of 10 Micrometers or Less in Aerodynamic Diameter 

ppm Parts per Million 

ppmv Parts per Million by Volume 

PSD Prevention of Significant Deterioration 

psi Pounds per Square Inch 

psia Pounds per Square Inch Absolute 

psig Pounds per Square Inch Gauge 

PVC Polyvinyl Chloride 

PWL Power Level 

R&D Research and Development 

RCRA Resource Conservation and Recovery Act 

Rd. Road 

RRA Resource Rich Area 

SDWA Safe Drinking Water Act 

sec Second 

SF6 Sulfur Hexafluoride 

SHPO State Historic Preservation Office or Officer 

SIP State Implementation Plan 

SO2 Sulfur Dioxide 

SOx Sulfur Oxides 

sqft Square Feet 

TEG Triethylene Glycol 

THPO Tribal Historic Preservation Officer 

TL Transmission Loss 

TMDL Total Maximum Daily Load 

tpy Tons per Year 

U.S. United States 
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Acronyms and Abbreviations ix October 2008 

UIC Underground Injection Control 

UNFCCC United Nations Framework Convention on Climate Change 

USC United States Code 

USDA U.S. Department of Agriculture 

USDW Underground Source of Drinking Water 

USEPA U.S. Environmental Protection Agency 

USFWS U.S. Fish and Wildlife Service 

VOC Volatile Organic Compounds 

VSP Vertical Seismic Profile 
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Use of Scientific Notation x October 2008 

USE OF SCIENTIFIC NOTATION 

Very small and very large numbers are sometimes written using scientific notation rather than as 

decimals or fractions. This notation uses exponents to indicate the power of 10 as a 

multiplier (i.e., 10n

, or the number 10 multiplied by itself n times; 10-n, or the reciprocal of the 

number 10 multiplied by itself n times). 

For example: 103

 =10 x 10 x 10 =1,000 

 ______1___ 

 10-3= 10 x 10 x 10 =0.001 

In scientific notation, large numbers are written as a decimal between 1 and 10 multiplied by the 

appropriate power of 10: 

4,900 is written 4.9 × 103

 = 4.9 × 10 × 10 × 10 = 4.9 × 1,000 = 4,900. 

0.049 is written 4.9 × 10-2. 

1,490,000 or 1.49 million is written 1.49 × 106

. 

A positive exponent indicates a number larger than or equal to one; a negative exponent indicates 

a number less than one. 
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National Energy Technology Laboratory Final Environmental Assessment

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Introduction 1 October 2008 

1.0 INTRODUCTION 

1.1 Summary 

Carbon dioxide (CO2) is a natural and important component of the atmosphere: animals and 

plants produce CO2 during respiration, and plants need it for photosynthesis; however, high 

concentrations of CO2 in the atmosphere can exert a “greenhouse” effect that traps heat within 

the Earth’s atmosphere. Global emissions of CO2 from human activity have increased from an 

insignificant level two centuries ago to over twenty-one billion metric tons per year by 2003 

(DOE, 2007a). The most notable human activity associated with the generation of CO2

emissions is the combustion of carbon-based fuels (including oil, natural gas, and coal). Many 

scientists, including the Intergovernmental Panel on Climate Change (IPCC), recognize a danger 

that even a modest increase in the Earth’s temperature (called “global warming”) could alter the 

global climate and cause significant adverse consequences for human health and welfare (DOE, 

2007a). 

In one of many governmental efforts to address the concerns outlined above, the Department of 

Energy (DOE) established the Carbon Sequestration Program in 1997 with the focus of 

conducting research and development (R&D) activities to evaluate and develop carbon 

sequestration technologies. Carbon sequestration involves capturing and storing CO2 emissions 

prior to release into the atmosphere, as well as enhancing natural carbon uptake and storage 

processes. Geologic sequestration involves the permanent storage of CO2 in deep unmineable 

coal seams, depleted oil and gas reservoirs, or saline (saltwater-filled) formations. Impermeable 

caprocks and/or geologic structural or stratigraphic traps retain the CO2 in the formation similar 

to natural gas storage trapping mechanisms. As a part of this program, DOE formed a 

nationwide network of regional partnerships to help determine the best approaches for capturing 

and permanently storing gases that can contribute to global climate change. The Regional 

Carbon Sequestration Partnerships are a government/industry effort tasked with determining the 

most suitable technologies, regulations, and infrastructure needs for carbon capture, storage, and 

sequestration in different areas of the country. The regional partnerships’ initiative is being 

implemented in three phases: 

• Phase I, Characterization (2003-2005): Characterized opportunities for carbon 

sequestration, including potential geologic storage formations and trapping mechanisms; 

• Phase II, Validation (2005-2009): Small scale field tests are currently under way to verify 

the injection rates, storage media, and trapping mechanisms; and 

• Phase III, Deployment (2008-2017): Conduct large volume carbon storage validation 

tests. 

Geographical differences in fossil fuel use and available sequestration sinks across the United 

States dictate regional approaches to sequestration of CO2 and other greenhouse gases. The 

seven partnerships that currently form this network include over 350 state agencies, universities, 

and private companies, spanning 41 states, two Indian nations, and four Canadian provinces. In 

addition, agencies from six member countries of the Carbon Sequestration Leadership Forum are 

participating in the Validation Phase field tests. The Midwest Geological Sequestration 

Consortium (MGSC) is one of these regional partnerships and this Environmental Assessment 

(EA) focuses on one of its proposed projects. 
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Introduction 2 October 2008 

The current annual CO2 emissions in the MGSC region are 336 million short tons (304 million 

metric tons). Previous research indicates that the target Mount (Mt.) Simon Sandstone has an 

estimated 29.8 to 119.4 billion short tons (27.1 to 108.6 billion metric tons) of CO2 storage 

capacity. The low end of this capacity is enough to hold half of the region’s estimated CO2

emissions for the next 100 years, which would be 16.6 billion short tons (15.1 billion metric 

tons) sequestered (NETL, 2008a). 

DOE proposes to co-fund an $84,274,927 project located on property of the MGSC partner 

Archer Daniels Midland Company (ADM). DOE’s 79.2% share is $66,730,912 and the nonDOE 20.8% share is $17,544,015. The Decatur ADM Complex is on the east side of the city of 

Decatur, Illinois, in Macon County. The overall objective of this project would be to 

demonstrate the ability of the Mt. Simon Sandstone, a major regional saline reservoir in the 

Illinois Basin, to accept and retain approximately 1.1 million short tons (1 million metric tons) of 

CO2 injected over a period of three years. 

The major efforts of this proposed project would include: 

• Regional geologic characterization, 

• Public outreach and education, 

• Permitting and NEPA compliance, 

• Site geologic characterization and modeling, 

• Well drilling and completion, 

• Infrastructure development, 

• CO2 procurement, 

• Transportation and injection operations, 

• Operational and environmental monitoring, 

• Site closure, 

• Post injection monitoring and modeling, 

• Project assessment, and 

• Post-test site planning (MGSC, 2008). 

New construction would include a surface facility, an approximately 3,000-foot (914 meter (m)) 

long pressurized pipeline, and 2,000 feet (609 m) of ductwork carrying uncompressed CO2. The 

facility would include the CO2 compression and dehydration equipment necessary to capture and 

condition the CO2 from the ADM ethanol production plant. The facility would be capable of 

delivering approximately 1.1 million short tons (1 million metric tons) of CO2 over a three-year 

period. The pressurized pipeline would deliver the CO2 from the compression-dehydration 

facility to the injection well. Prior to construction of the facility, all required permits would be 

obtained from the Illinois Environmental Protection Agency (IEPA) and other appropriate 

regulatory authorities. 

The outlet CO2 stream from the fermentor section of the ethanol production plant typically 

contains greater than 99% pure CO2, saturated with water vapor at 80 degrees Fahrenheit (oF) 

(approximately 27 degrees Celsius (°C)) and atmospheric pressure. Common impurities in the 

fermentor gas stream are hydrocarbons, nitrogen, and acetaldehyde in concentrations typically 
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Introduction 3 October 2008 

less than 200 parts per million by volume (ppmv). Other impurities in lesser amounts can 

include ethyl acetate, ethanol, oxygen, methanol, and hydrogen sulfide (Fisher, 2008). 

The compression-dehydration facility includes an inlet water knockout prior to the first phase of 

compression. The first phase of compression would use one or more electrically driven screw 

compressors to compress the low pressure CO2 from atmospheric pressure to 290 - 315 pounds 

per square inch absolute (psia) (2000 - 2170 kilopascals (kPa)). Cooling of the CO2 after the 

initial compression phase would be achieved using an air-cooled exchanger or water-cooled 

shell-and-tube heat exchanger (Fisher, 2008). 

A water knockout would be necessary before the 290 - 315 psia (2000 - 2170 kPa) CO2 stream is 

routed to the next stage of compression. After being compressed to approximately 800 pounds 

per square inch gauge (psig) (5,516 kPa), the CO2 will pass through the final stage of intercooling and water knockout, and then into a triethylene glycol (TEG) dehydrator system. 

Water-saturated CO2 would be fed to the bottom of an absorber tower containing structured 

packing where it would contact TEG counter-currently. The water laden “rich” TEG would 

leave the bottom of the absorber and would cross exchange with “lean” TEG in a heat exchange 

that cools the lean TEG on its way to the top of the absorber. 

A propane-fired heater would heat the TEG to remove water vapor and regenerate the TEG in the 

stripper (Fisher, 2008). The dehydrated CO2 would exit the top of the absorber and go to the 

final stage of compression, bringing the pressure to approximately 1200 - 1400 psig (8,274 – 

9,653 kPa). If higher pressures are needed, the supercritical CO2 will be pumped to the final 

required pressure using a multi-stage centrifugal pump (Fisher, 2008). 

The pipeline that would transfer the CO2 from the compression-dehydration facility to the CO2

injection well would be a 4-inch to 6-inch (10.16 centimeter (cm) to 15.24 cm) diameter 

schedule 40 or 80 steel pipe designed to meet standards for the temperature and pressure of the 

CO2 stream. The pipeline would be installed aboveground, following as much as possible the 

current pipeline alleys at the Decatur ADM Complex. The pipeline would be located only on 

ADM property. 

The decision for DOE is to either fund or not fund the Proposed Action including the associated 

drilling and injection activities. ADM would not pursue the drilling and injection activities if 

DOE’s decision is to not fund the Proposed Action. Table 1.1 below is based on that premise. 
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National Energy Technology Laboratory Final Environmental Assessment

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Introduction 4 October 2008 

Table 1.1. Comparison of Impacts 

Resource No-Action Alternative Proposed Action 

Air Quality No impacts, except the loss of 

beneficial impacts from reducing 

greenhouse gas, are expected. 

Short-term, minor impacts would be 

limited to temporary diesel emissions 

and limited air emissions from a 

dehydration reboiler. The project 

would not produce emissions that 

would impede the area’s conformity 

with the State Implementation Plan 

under the Clean Air Act. In contrast, 

there would be some beneficial 

impacts due to the reduction of 

greenhouse gas emissions. 

Geology and Soils No impacts Some long-term increase in 

subsurface pressures due to CO2

injection would be expected; 

however, the Proposed Action would 

not be expected to cause any 

measurable leakage of CO2 from the 

storage formation to the surface or 

into another area in the subsurface. 

There is no more than an 

imperceptible risk of inducing 

seismic events due to increased 

reservoir pressure. 

Water Resources No impacts The Proposed Action may cause 

some modest increase in water usage 

due to the drilling of injection and 

monitoring wells; however, any 

changes to water quality and quantity 

would likely be at the lowest 

detectable levels and full recovery of 

the resource would likely occur in a 

reasonable time*. 

Wetlands No impacts No substantial impacts to local 

wetlands would be expected. Any 

unexpected impacts to wetlands 

would be confined to the immediate 

project area and would not cause any 

regional impacts. 
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National Energy Technology Laboratory Final Environmental Assessment

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Introduction 5 October 2008 

Table 1.1. Comparison of Impacts 

Resource No-Action Alternative Proposed Action 

Terrestrial Vegetation No impacts The injection site is fallow. No 

critical habitats are present. Changes 

would be limited to a small area and 

would not be expected to affect the 

viability of the resources. 

Wildlife No impacts Some local disturbance and 

displacement of wildlife may occur; 

however, any changes to wildlife 

would be limited to a small portion 

of the population and would not be 

expected to affect the viability of the 

resource. Full recovery would occur 

in a reasonable time, considering the 

size of the project and the affected 

species’ natural state. 

Land Use No impacts Impacts to land use, if any, would be 

localized and limited to the 

immediate project area. 

Population No impacts The effect on size and demographic 

characteristics of the local 

population, if any, would be minimal.

Employment and 

Income 

No impacts The effect on the local economy, 

labor conditions, and availability of 

production or consumer resources, if 

any, would be primarily beneficial, 

temporary, and of short duration. 

Infrastructure No impacts Some minor impacts to the existing 

traffic patterns and level of 

congestion could be expected during 

drilling and construction activities; 

however, no long-term impacts in the 

immediate or surrounding area are 

expected. 

Parks and Recreation No impacts Minimal impact to recreational 

activities in the immediately 

surrounding area but any disturbance 

would be minor, temporary in 

duration, and in character with 

existing uses of the project area 

including a nearby park. 
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Table 1.1. Comparison of Impacts 

Resource No-Action Alternative Proposed Action 

Visual Resources No impacts The Proposed Action site is a 

previously disturbed industrial site. 

The project is unlikely to change 

visual landscape in a way that would 

be objectionable to local residents or 

frequent visitors. 

Noise No impacts Temporary minor noise impacts are 

expected during construction and 

drilling. During operation, there may 

be minor increases in operational 

noise; however, noise levels in the 

project area are not expected to 

exceed ambient noise level standards 

as determined by the Federal, state, 

and/or local government. 

Environmental Justice No impacts No disproportionately high or 

adverse impacts to minority or lowincome communities are expected. 

Human Health and 

Safety 

No impacts, except the loss of an 

opportunity to reduce greenhouse 

gas emissions, are expected. 

The project, operated in accordance 

with state and Federal regulations, 

would pose no more than a minimal 

risk to the health and safety of on-site 

workers and the local population. 

Cultural Resources No impacts The project area is previously 

disturbed, and no cultural resources 

have been found. No substantial 

impacts are expected. 

Waste Management No impacts The action is not expected to cause 

air, water, or soil to be contaminated 

with any hazardous material that 

poses a threat to human or ecological 

health and safety. 

* Recovery in a reasonable time: Constant, sustainable improvement is apparent and measurable when the site is 

routinely observed, and full recovery is achieved over a period of no more than several years.

1.2 Purpose and Need 

The DOE’s National Energy Technology Laboratory (NETL) has a mission to implement a 

research, development, and demonstration program to resolve the environmental, supply, and 

reliability constraints of producing and using fossil energy sources. One aspect of that mission, 

the resolution of environmental constraints to producing and using fossil fuels, now requires 

NETL to review and, where possible, mitigate projected impacts to global climate change caused 
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by the use of fossil fuels. One possible mitigation technique under review is the capture and 

long-term removal of CO2 from the atmosphere through a process called carbon sequestration. 

NETL is implementing the DOE Carbon Sequestration Program, which was established in 1997 

to evaluate and develop carbon sequestration technologies. The focus of this Carbon 

Sequestration Program involves capturing and storing CO2 emissions prior to release into the 

atmosphere, as well as enhancing natural carbon uptake and storage processes. The principal 

goal of the Carbon Sequestration Program is to gain a scientific understanding of carbon 

sequestration options and to provide cost-effective, environmentally sound technology options 

that ultimately may lead to a reduction in greenhouse gas intensity and stabilization of 

atmospheric concentrations of CO2 (DOE, 2007a). One of those options, geologic sequestration, 

involves the placement of CO2 or other greenhouse gases into subsurface porous and permeable 

rocks in such a way that they remain permanently stored. 

In 2003, DOE selected seven regional partnerships, consisting of stakeholders in geographic 

regions across the United States and Canada, to evaluate and pursue opportunities for carbon 

sequestration infrastructure development. The MGSC is one such partnership, which focuses on 

sequestration opportunities in the Illinois Basin and includes the states of Illinois, Kentucky, and 

Indiana. During the first phase, or Characterization Phase, the MGSC characterized the Illinois 

Basin’s opportunities to store CO2 in deep saline formations, unmineable coal seams, and 

depleted oilfields. 

At the end of Characterization Phase in 2005, the MGSC identified promising opportunities for 

sequestration projects. During Phase II of the project, or Validation Phase (now underway), the 

MGSC is working on several small-scale carbon sequestration field projects. For example, they 

have completed the injection of CO2 at the Louden Oilfield in southern Illinois to evaluate 

carbon sequestration with enhanced oil recovery (EOR). The partnership hopes to complete 

three additional EOR field projects and one coal seam sequestration project by September 2009. 

The lessons learned from the first two phases of the regional partnership initiative by the MGSC 

have enabled the partnership to select a promising location for the large-scale field test based on 

the regional characterization work. 

The ADM Phase III Test Site is on the property of ADM on the east side of the city of Decatur, 

Illinois, and would use ADM’s existing ethanol fermentation operation there as the source of 

CO2. A detailed pre-injection site assessment and drilling of one well would enable the MGSC 

to characterize the site and ensure its suitability. The knowledge gained during the Phase II field 

projects have supported the design of a state-of-the-art large-scale storage project with a number 

of regional and national organizations providing field services, simulation efforts, and 

monitoring support that would not have been possible without the previous investment. A map 

of the regional carbon sequestration partnerships is on the next page. 
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Figure 1.2. Map of Regional Carbon Sequestration Partnerships 
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Introduction 9 October 2008 

During the Deployment Phase, or Phase III, the purpose of the proposed MGSC project would 

be to demonstrate the ability of the Mt. Simon Sandstone to accept and retain approximately 1.1 

million short tons (1 million metric tons) of injected CO2 over a three year period, thus testing 

large-scale sequestration sooner than might otherwise be possible. Phase III focuses on: 

• Testing the acceptance of the CO2 by the deep saline reservoir (injectivity); 

• The ability of the reservoir to store CO2 (storage capacity); 

• The seal integrity of the entire site (to ensure that CO2 does not leak to the surface or 

other sub-surface formations); and 

• The entire process of pre-injection characterization, injection process monitoring, and 

post-injection monitoring to understand the CO2 fate (monitoring, mitigation, and 

validation (MMV)) (MGSC, No date). 

Although the processes of geologic sequestration are relatively well known, there is a need for 

additional research to fill gaps in our scientific understanding of carbon sequestration; ensure the 

protection of human health and the environment; reduce costs; and facilitate the full-scale 

deployment of this technology. Extensive laboratory investigations, modeling studies, and 

limited small-scale field studies assessed how CO2 geologic sequestration would work in the 

subsurface. Comparing predictions from bench scale tests and numerical models with field 

results is necessary to validate the models and demonstrate that scientific understanding is 

correct (DOE, 2003). 

While the oil and gas industry has years of extensive experience with CO2 injection for EOR, 

this information is inadequate for validating CO2 sequestration because the fate of the injected 

CO2 has not been routinely quantified. CO2 injected for EOR can be absorbed in the oil, held by 

capillary forces in pore space, trapped by buoyancy forces in stratigraphic or structural 

compartments, dissolved in pore water, produced and reused, or leaked from the injection zone 

through the soils and/or penetrations. The absence of data to account for CO2 fate in the 

complex EOR system leaves a gap in scientific understanding (DOE, 2003). 

Two-thirds of the United States has deep saline formations beneath landmasses and the ocean’s 

continental shelf. These formations have an estimated CO2 storage capacity of up to 3.5 trillion 

short tons. Many of these formations are located in close proximity to major point sources of 

CO2 emissions, such as fossil-fuel power plants, which offer the benefit of reducing costs for 

transportation of CO2 to the injection site. This proposed large-scale field project would help to 

answer uncertainties associated with the reactions that may occur between CO2, brine, and 

minerals in the surrounding strata (DOE, 2007a). 

Two key issues distinguish CO2 sequestration in saline formations from sequestration in oil and 

gas fields. First, oil and gas fields result from the presence of a geologic structural or 

stratigraphic trap that acts as a seal, keeping oil and natural gas from leaking from the reservoir. 

These same types of traps are likely to retain sequestered CO2 when injected into the depleted oil 

or gas reservoir. Identification of such effective traps may be more difficult in aqueous 

formations due to the lack of a detailed knowledge base on many of these formations and their 

caprocks, which may require new approaches for establishing the integrity and extent of a 

caprock. Second, injection of CO2 into a saline formation is not usually accompanied by 
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removal of water from the formation. In the case of EOR, oil and brine are simultaneously 

withdrawn while CO2 is injected. Injection of CO2 into a saline formation, on the other hand, 

would lead to an increase in formation pressure. 

The project, under carefully controlled and monitored conditions, will determine whether, and to 

what extent, large-scale pressurization would affect caprock integrity, cause land surface 

deformation, and induce seismic hazards. Successful large-scale application of this technology 

demands that these potential effects, regardless of the probability of their occurrence, must be 

better understood to design safe and effective sequestration in saline formations. Another 

possible issue pertains to the acceptable leakage rate from the formation into overlying strata 

(DOE, 2007a). 

Injection into a deep saline formation and potential leakage into overlying formations is a 

relevant, even if possibly unlikely concern, particularly where drinking water sources are in the 

vicinity. Most studies to date have been concerned with breaching the caprock; formation 

capacity and injectivity; and CO2, water, and host/seal rock interaction. Less work has been 

done to understand the possible effects of displacing the saline water from the deeper basin into 

shallower outcrops, subcrops, or into freshwater regions of the same formation. This proposed 

large-scale field project would provide data that would contribute to the better understanding of 

the magnitude and probability of risks associated with brine movement caused by CO2 injection 

(DOE, 2007a). 

To address and better understand these experience and knowledge gaps, DOE is co-sponsoring a 

field experiment in a high-porosity, high-permeability formation similar to those that could 

eventually be used to sequester large volumes of CO2. The Proposed Action would be closely 

monitored to determine whether the CO2 remains within the injection zone and to maximize 

scientific understanding. 

If funded, the Proposed Action would: 

• Reduce greenhouse gas emissions on a local scale and contribute significantly to broader 

knowledge that will reduce global warming on a larger scale, 

• Ensure that health and safety and environmental risks are minimized, 

• Obtain results quickly so that experience can be used in moving to large pilots in other 

parts of the world, and 

• Optimize costs preceding full scale deployment. 

The test location would provide an opportunity for matching numerical model results with field 

observations under conditions of high volume injection at a scale similar to what would be done 

if CO2 from power plants were captured and sequestered. 

1.3 Legal Framework 

The legal framework for this EA involves both substantive legal requirements (what must be 

done or not done) and procedural legal requirements (how the agency must carry out its 

responsibilities). DOE has prepared this EA in accordance with the Council on Environmental 

Quality (CEQ) “Regulations for Implementing the Procedural Provisions of the National 
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Introduction 11 October 2008 

Environmental Policy Act,” codified in Title 40 of the Code of Federal Regulations in Parts 1500 

through 1508 (40 CFR 1500-1508). These implement the procedural requirements of the 

National Environmental Policy Act (NEPA), found in Title 40 of the United States Code in 

Section 4321 and following sections (42 USC § 4321 et seq.). 

NEPA requires Federal agencies to consider the potential environmental consequences of a 

Proposed Action in their decision-making processes. NEPA encourages Federal agencies to 

protect, restore, or enhance the environment through well-informed Federal decisions. The CEQ 

NEPA regulations specify that an EA be prepared to: 

• Provide sufficient analysis and evidence for determining whether or not to prepare an 

Environmental Impact Statement (EIS) or a Finding of No Significant Impact (FONSI). 

• Aid in an agency's compliance with NEPA when no EIS is deemed necessary. 

• Facilitate EIS preparation when one is necessary. 

Further, the CEQ NEPA regulations encourage agencies to integrate NEPA requirements with 

other environmental review and consultation requirements. Relevant environmental 

requirements are contained in other Federal statutes, such as the Clean Air Act and the Clean 

Water Act, and their state counterparts. The following Federal and state statutes and regulations 

are relevant to this EA. Federal and state permits that may be required are also listed. 

Clean Air Act 

The Clean Air Act (CAA), 42 USC § 7401 et seq., establishes the National Ambient Air Quality 

Standards (NAAQS) developed by the U.S. Environmental Protection Agency (USEPA) for the 

pervasive pollutants: sulfur dioxide (SO2), carbon monoxide (CO), ozone (O3), nitrogen dioxide 

(NO2), lead (Pb), and particulate matter (both PM10 and PM2.5). The NAAQS are expressed as 

concentrations of the criteria pollutants in the ambient air, the outdoor air to which the general 

public is exposed. The CAA also contains emission control permit programs to protect the 

nation’s air quality and establishes New Source Performance Standards that establish design 

standards, equipment standards, work practices, and operational standards for new or modified 

sources of air emissions. Where the NAAQS emphasize air quality in general, the New Source 

Performance Standards focus on particular industrial categories or sub-categories (e.g., fossil fuel 

fired generators, grain elevators, and steam generating units). Regulations implementing the 

CAA are found in 40 CFR Parts 50-95. Illinois has been delegated CAA authority under Chapter 

415 of Illinois Compiled Statutes (ILCS) Section 5/3 and following sections (415 ILCS § 5/3 et 

seq.) (Note: Provisions dealing with Regulations (415 ILCS §5/26 et seq.), Enforcement (415 

ILCS § 5/30 et seq.), Variances (451 ILCS § 5/35 et seq.), and Permits (415 ILCS § 5/39 et seq.) 

apply to all of the authority within Chapter 415 of ILCS that follow). 

Clean Water Act 

The Clean Water Act (CWA), 33 USC § 1251 et seq., establishes a comprehensive framework of 

standards, technical tools, and financial assistance to address “point source” pollution from 

municipal and industrial wastewater discharges and “nonpoint source” pollution from urban and 

rural areas. Applicants for federal licenses or permits to conduct any activity that may result in a 

discharge to navigable waters must provide the Federal agency with a state CWA Section 401 
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certification that the discharge would comply with applicable provisions of the CWA. CWA 

Section 404 establishes a permit program to regulate the discharge of dredged and fill material 

into waters of the United States, including wetlands. CWA Section 402 establishes the National 

Pollutant Discharge Elimination System (NPDES), which requires point sources of pollutants to 

obtain permits to discharge effluents and storm water to surface waters. Regulations for 

implementing relevant CWA programs are found in 33 CFR Parts 320-331 and 40 CFR Parts 

400-503. Illinois has been delegated CWA authority under 415 ILCS §§ 5/11 and 5/19.1 et seq., 

and 20 ILCS § 830. 

Safe Drinking Water Act 

The Safe Drinking Water Act (SDWA), 42 USC 300 et seq., gives USEPA the responsibility and 

authority to regulate public drinking water supplies by establishing drinking water standards, 

delegating authority for enforcement of drinking water standards to the states, and protecting 

aquifers from hazards such as injection of wastes and other materials into wells. Important for 

this EA are the SDWA provisions relating to injection wells. Congress passed the Safe Drinking 

Water Act in 1974. In part, the SDWA requires USEPA to develop minimum federal 

requirements for Underground Injection Control (UIC) programs and other safeguards to protect 

public health by preventing injection wells from contaminating underground sources of drinking 

water. Illinois has been delegated SDWA authority under 415 ILCS §§ 5/19.1 et seq. and 55/1 et 

seq. On July 31 2008, USEPA proposed draft regulations for a UIC program modification 

specifically developed for CO2 geologic sequestration (73 FR 43491). 

Resource Conservation and Recovery Act 

The Resource Conservation and Recovery Act (RCRA), 42 USC § 6901 et seq., regulates the 

treatment, storage, and disposal of solid and hazardous wastes. RCRA sets “cradle to grave” 

standards for both solid waste and hazardous waste management. Certain wastes are specifically 

excluded because they are regulated under other statutes. Some examples are domestic sewage 

and septic tank waste; agricultural wastes; industrial discharges; some nuclear wastes; and 

mining overburden. RCRA regulations are found in 40 CFR Parts 239-282. Illinois has been 

delegated RCRA authority under 415 ILCS § 5/20 et seq. 

Comprehensive Environmental Response, Compensation, and Liability Act/Emergency 

Planning and Community Right-to-Know Act 

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 

USC § 9601 et seq., also known as “Superfund,” established a tax on the chemical and petroleum 

industries and provided broad federal authority to respond directly to releases or threatened 

releases of hazardous substances that may endanger public health or the environment. CERCLA 

also establishes requirements for closed and abandoned hazardous waste sites, provides for the 

liability of persons responsible for the release of hazardous substances, and established a trust 

fund to pay for orphan facility cleanup and closure. Regulations for implementing CERCLA are 

found in 40 CFR Parts 300-312. 
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The Emergency Planning and Community Right-to-Know Act (EPCRA), 42 USC § 1001 et seq., 

requires Federal agencies to provide information on hazardous and toxic chemicals to state 

emergency response commissions, local emergency planning committees, and USEPA. 

EPCRA’s goal is to provide this information to ensure that local emergency plans are sufficient 

to respond to unplanned releases of hazardous substances. Regulations implementing EPCRA 

are found in 40 CFR Parts 350-374. Illinois EPCRA authority is found in 415 ILCS § 5/20 et 

seq. and § 5/25b-1 et seq. 

National Historic Preservation Act 

The National Historic Preservation Act (NHPA), 16 USC § 470 et seq., requires DOE to consult 

with the State Historic Preservation Officer (SHPO) prior to any construction to ensure that no 

historical properties would be adversely affected by a proposed project. DOE must also afford 

the Advisory Council on Historic Preservation a reasonable opportunity to comment on the 

proposed project. Regulations for implementing NHPA are found in 36 CFR 800-812. Illinois 

historic preservation authority is found in 20 ILCS § 3420/1 et seq. 

Archaeological Resources Protection Act 

The Archaeological Resources Protection Act, 16 USC § 470aa et seq., requires a permit for 

excavation or removal of archaeological resources from publicly held or Native American lands. 

The Act requires that excavations further archaeological knowledge in the public interest and 

that the resources removed remain the property of the United States. Regulations for 

implementing the Act are found in 43 CFR 7 and 36 CFR 296. Illinois archaeological protection 

authority is found in 20 ILCS § 3420/1 et seq. 

American Indian Religious Freedom Act 

The American Indian Religious Freedom Act, 42 USC § 1996, establishes policy to protect and 

preserve the inherent and Constitutional right of Native Americans to believe, express, and 

exercise their traditional religions. The law ensures the protection of sacred locations; access of 

Native Americans to those sacred locations and traditional resources that are integral to the 

practice of their religions; and establishes requirements that would apply to Native American 

sacred locations, traditional resources, or traditional religious practices potentially affected by 

construction and operation of proposed facilities. Regulations for implementing the Act are also 

found in 43 CFR 7. Illinois Native American protection authority is found in 20 ILCS § 3420/1 

et seq. 

Native American Graves Protection and Repatriation Act 

The Native American Graves Protection and Repatriation Act, 25 USC § 3001, directs the 

Secretary of the Interior to guide the repatriation of federal archaeological collections and 

collections that are culturally affiliated with Native American tribes and held by museums that 

receive federal funding. DOE would follow the provisions of this Act if any excavations 

associated with the proposed construction led to unexpected discoveries of Native American 
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Introduction 14 October 2008 

graves or grave artifacts. Regulations for implementing the Act are found in 43 CFR 10. Illinois 

Native American protection authority is found in 20 ILCS § 3420/1 et seq. 

Endangered Species Act 

The Endangered Species Act (ESA), 16 USC 1531 et seq., establishes a national program for the 

conservation of threatened and endangered species of fish, wildlife, and plants, as well as the 

preservation of the ecosystems on which they depend. ESA Section 7 requires any federal 

agency authorizing, funding, or carrying out any action to ensure that the action is not likely to 

jeopardize the continued existence of any endangered species or threatened species, or result in 

the destruction or adverse modification of critical habitat of such species. Regulations 

implementing the ESA interagency consultation process are found in 50 CFR Part 402. Illinois 

endangered species protection authority is found in 520 ILCS § 10/1 et seq. 

Fish and Wildlife Conservation Act/Fish and Wildlife Coordination Act 

The Fish and Wildlife Conservation Act, 16 USC § 2901 et seq., encourages Federal agencies to 

conserve and promote conservation of non-game fish and wildlife species and their habitats. In 

addition, the Fish and Wildlife Coordination Act, 16 USC § 661 et seq., requires Federal 

agencies undertaking projects affecting water resources to consult with the United States (U.S.) 

Fish and Wildlife Service and the state agency responsible for fish and wildlife resources. 

Compliance with these statutes is internalized in the DOE NEPA process. Illinois fish and 

wildlife authority is found in 515 ILCS § 5/5-5 et seq. and 520 ILCS §§ 20 and 25. 

Noise Control Act 

The Noise Control Act of 1972, 42 USC § 4901 et seq., directs federal agencies to carry out 

programs in their jurisdictions to the fullest extent within their authority and in a manner that 

furthers a national policy of promoting an environment free from noise that jeopardizes health 

and welfare. This would involve complying with applicable municipal noise ordinances to the 

maximum extent practicable. Illinois regulates noise at the state level with authority found in 

415 ILCS 5/23 et seq. 

Farmland Protection Policy Act 

The Farmland Protection Policy Act, 7 USC § 4201 et seq., directs federal agencies to identify 

and quantify adverse impacts of Federal programs on farmlands in order to minimize the 

unnecessary and irreversible conversion of agricultural land to non-agricultural uses. 

Regulations implementing the Act are found in 7 CFR 658. Illinois farmland protection 

authority is contained in 505 ILCS §§ 5 and 75. 

Occupational Safety and Health Act 

The Occupational Safety and Health Act, 29 USC § 651 et seq., requires employers to furnish 

employees employment and a place of employment that are free from recognized hazards that are 

causing or are likely to cause death or serious physical harm to the employees, and to comply 
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Introduction 15 October 2008 

with occupational safety and health standards promulgated by the Occupational Safety and 

Health Administration (OSHA). OSHA standards are implemented under regulations found in 

29 CFR Parts 1900-2400. Illinois regulates OSHA requirements through authority found in 820 

ILCS § 225 et seq. 

Pollution Prevention Act 

The Pollution Prevention Act, 42 USC § 13101 et seq., establishes a national policy for waste 

management and pollution control that focuses first on source reduction, and then on 

environmentally safe waste recycling, treatment, and disposal. Three executive orders provide 

guidance to agencies to implement the Pollution Prevention Act: Executive Order 12873, 

“Federal Acquisition, Recycling, and Waste Prevention,” Executive Order 13101, “Greening the 

Government through Waste Prevention, Recycling, and Federal Acquisition,” and Executive 

Order 13148, “Greening the Government through Leadership in Environmental Management.” 

Federal Aviation Administration Act 

49 USC §§ 106(f) and (g) give the Administrator of the Federal Aviation Administration (FAA) 

a number of powers, including the authority to regulate objects affecting navigable airspace. 

Regulations requiring FAA notification if any structure of more than 200 feet (60.96 m) high 

would be constructed are found in 14 CFR Part 77. The FAA then determines if the structures 

would or would not be an obstruction to air navigation. Illinois regulates navigable airspace 

under authority found in 620 ILCS §25 et seq. 

Executive Orders 

A number of presidential executive orders in addition to those noted above provide additional 

guidance to Federal agencies in developing EAs, including this EA. The most relevant of them 

include: 

• Executive Order 11514, “Protection and Enhancement of Environmental Quality” 

• Executive Order 11988, “Floodplain Management” 

• Executive Order 12856, “Right to Know Laws and Pollution Prevention Requirements” 

Executive Order 12898, “Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations” 

• Executive Order 13112, “Invasive Species” 

• Executive Order 13186, “Responsibilities of Federal Agencies to Protect Migratory 

Birds” 

• Executive Order 13423, “Strengthening Federal Environmental, Energy, and 

Transportation Management” 

Federal executive orders can be accessed at: http://www.archives.gov/federal-register/

codification/. 

Federal and State Permitting 

The following are potentially applicable federal and state permitting requirements to construct 

and operate the proposed facilities. 
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• Acid Rain Permit, 40 CFR Part 72 

• Airspace Obstruction Control Permit, 14 CFR Part 77 

• Clean Air Act Prevention of Significant Deterioration Permit, Acid Deposition Control 

Permit, and Operating Permit, 40 CFR Parts 50-96 

• Clean Water Act, Section 401 Certification, Section 402 NPDES Permit, Section 404 

Wetlands Permit, and Pretreatment Authorization for Discharge of Wastewater to 

Municipal Collection System, 40 CFR Parts 104-140, 403 

• Safe Drinking Water Act Underground Injection Control Permit, 40 CFR Part 144 

• Rivers and Harbor Act Permit, 33 CFR Part 322 

• Notice to the Federal Aviation Administration, 14 CFR Part 77 

• RCRA, 40 CFR Parts 239 through 299 

• Sales Tap Approval, 18 CFR 157.211, approval would be required to tap into or modify 

existing interstate gas pipelines. 

Illinois State Permits 

• Accommodation of Utilities on Right-of-Way, 92 Illinois Administrative Code (IAC) 

Part 530 

• Air Construction Permit, 35 IAC Parts 201 and 203 

• Air Operating Permit, 35 IAC Part 201, 203 and 205 

• Certificate of Public Convenience and Necessity, Section 3-105 and 8-406 of the Illinois 

Public Utilities Act 

• Interconnection Agreement from the Illinois Commerce Commission may be required. 

• NPDES Permit, 35 IAC Part 309, 35 IAC, Subtitle C, Chapter 1 

• Permit for Groundwater Monitoring Wells, 77 IAC 920 

• Permit for Nonhazardous Onsite Waste Disposal Facility, 35 IAC Parts 812 and 813 

• Potable Water Supply Connection Permits, ILCS, Chapter 415 

• Prevention of Significant Deterioration (PSD) Permit, 40 CFR 52.21 

• RCRA Permit Program, 35 IAC 702 and 703 

• UIC Permit, 35 IAC Parts 704 and 730 

• Wastewater Facility Construction Approval, ILCS, Chapter 415 
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2.0 PROPOSED ACTION AND ALTERNATIVES 

2.1 Proposed Action 

DOE is proposing to provide cost-shared funding for an $84,274,927 project, including 

$66,730,912 in a federal fund cost-share, to demonstrate the ability of the Mt. Simon Sandstone, 

a major regional saline reservoir in the Illinois Basin, to accept and retain approximately 1.1 

million short tons (1 million metric tons) of CO2 injected over a period of three years (MGSC, 

2008). 

Table 2.1. MGSC Project Timeline 

Activity 2008 2009 2010 2011 2012 2013 2014 2015 

Site Characterization and 

Development 

 

Injection and Monitoring Operations 

Site Closure and Assessment 

The project would include the construction of a surface facility, an approximately 3,000-foot (914.4 

m) long pressurized pipeline, and 2,000 feet (609.6 m) of ductwork carrying uncompressed CO2. 

The facility would contain CO2 compression and dehydration equipment necessary to capture and 

condition CO2 from the ADM ethanol production plant. The pipeline would deliver the CO2 from 

the compression-dehydration facility to the injection well. Installation of verification wells would 

result in similar operational activities as the CO2 injection well (MGSC, 2008). 

The pipeline that would transfer the CO2 from the compression-dehydration facility to the CO2

injection would be 4-inch to 6-inch (10.16 cm to 15.24 cm) diameter schedule 40 or 80 steel pipe 

designed to meet standards for the temperature and pressure of the CO2 stream. The pipeline would 

be installed primarily aboveground with a small portion of undetermined length installed 

underground near the injection well. The pipeline would follow as much as possible the current 

pipeline alleys at the Decatur ADM Complex (MGSC, 2008). 

Reservoir modeling would incorporate data developed during the pre-injection site assessment 

period, data developed from the initial well drilled on the injection site, and data collected as 

injection proceeds. The MGSC would initially characterize the project site using orthogonal 

two-dimensional (2D) seismic lines to confirm the geological structure at the site and to test for 

any seismically resolvable faults that may exist. A well would then be drilled through the entire 

Mt. Simon Sandstone to the underlying granitic basement, followed by extensive logging, core 

sampling, and fluid sampling to build a comprehensive site reservoir model. The model would 

enable understanding of injected CO2 distribution and potential reactivity of the CO2 and CO2-

laden brine with the reservoir and the seals. The model would be expanded using a baseline 

three dimensional (3D) seismic survey and would help predict where additional geophysical 

surveys should be taken as CO2 is injected (MGSC, No date). 

The proposed project would continue to refine previously developed MMV techniques and 

incorporate new technologies to understand potential leakage pathways of the larger scale test, 

provide post-injection monitoring, and provide assurance that health and safety requirements are 

fully taken into account (MGSC, No date). 
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2.1.1 Project Location 

The ADM Phase III Test Site would be on the east side of the city of Decatur, Illinois, in Macon 

County (Figure 2.1.1-1). This site would be located in Section 5 of Township 16 North Range 3 

East, surveyed from the 3rd Principal Meridian, and on flat terrain within the Decatur ADM 

Complex. The compression-dehydration facility would be located within the industrial complex 

to the south of the proposed injection well site (Figure 2.1.1-2). A pipeline would transport CO2

as a supercritical fluid from the compression facility to the injection well following, as much as 

possible, an existing pipeline alley and overhead catwalk that allows the pipeline to cross the 

railroad track, and would be protected from accidental injury following ADM current 

construction policies (MGSC, 2008). 

The ADM Phase III Test Site infrastructure would be integrated into the current footprint of the 

Decatur ADM Complex and would be constructed between existing structures at the Decatur 

ADM Complex. No space outside the existing Decatur ADM Complex footprint would be 

required for the compression-dehydration facility. An agricultural field and wastewater treatment 

facility, both owned by ADM, are located near the CO2 injection well. A field drainage ditch is 

located on the northeast corner of the field. Buildings, tanks, roads, etc., associated with 

manufacturing operations are also on the Decatur ADM Complex (MGSC, 2008). 
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Figure 2.1.1-1. Regional Vicinity Map 
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Figure 2.1.1-2. Project Area Map 
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2.1.2 Construction 

Proposed new construction would include a surface facility, an approximately 3,000-foot (914.4 

m) long pressurized pipeline, and 2,000 feet (609.6 m) of ductwork carrying uncompressed CO2. 

The facility would include the CO2 compression and dehydration equipment necessary to capture 

and condition the CO2 from the ADM ethanol production plant. The facility would be capable of 

delivering approximately 1.1 million short tons (1 million metric tons) of CO2 over a three-year 

period or approximately 367,700 short tons (365,000 metric tons) per year. The pipeline would 

deliver the CO2 from the compression-dehydration facility to the injection well (MGSC, 2008). 

2.1.2.1 CO2 Supply 

The source of the CO2 for this project would be the ethanol fermentation tanks located south and 

slightly east of the proposed compression-dehydration facility. The outlet CO2 stream from the 

ethanol fermentation facility is typically greater than 99% pure CO2, saturated with water vapor 

at 80oF and atmospheric pressure (MGSC, 2008). Collection pipes and fans/blowers would be 

used to pull/push the CO2 to the compression-dehydration facility. Wet, uncompressed CO2

would be transported in stainless steel ductwork, thereby eliminating corrosion as a potential 

concern. Precise pipeline length is currently unknown, but the approximate uncompressed CO2

pipeline length would be 2,000 feet (609.6 m) (Carroll, 2008a). 

2.1.2.2 Compression-dehydration Facility 

The compression-dehydration facility would consist of an inlet water knockout prior to the first 

stage of compression. The first stage of compression would use an electrically driven screw 

compressor to compress the low pressure CO2 from atmospheric pressure to approximately 300 

psia (2,069 kPa). Cooling of the CO2 after the initial compression stage would be achieved using 

an air-cooled exchanger or tube heat exchanger. A water knockout would be necessary before 

the 290 - 315 psia (2000 - 2170 kPa) CO2 stream is routed to a once-through scrubber to remove 

alcohol and other impurities (MGSC, 2008). 

Next, the CO2 stream would pass through a packed-bed water scrubber to remove impurities 

such as acetaldehyde, methanol, and other water-soluble organic chemicals. The CO2 stream 

would then be dehydrated using a TEG absorbing solution. Water-saturated CO2 would be fed to 

the bottom of a packed-bed absorber tower where it would contact TEG in a countercurrent flow. 

The water laden TEG would leave the bottom of the absorber and would cross exchange with 

pure TEG in a heat exchange that cools the TEG on its way to the top of the absorber. A fuelfired heater would heat the TEG to remove water vapor and regenerate the TEG in the stripper 

(MGSC, 2008). 

The dehydrated CO2 would leave the top of the absorber and go to a multi-stage reciprocating 

compressor. The two-stage reciprocating compressor would compress the CO2 to the density and 

pressure needed for injection. Interstage cooling between compression steps would be 

performed using a heat exchanger. It is anticipated the outlet pressure of CO2 would be 1,200-
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1,400 psig (9,653 kPa). The critical pressure for CO2 is 1056 psig (7,281 kPa), so the CO2 would 

be at supercritical conditions prior to injection (MGSC, 2008). 

2.1.2.3 Pressurized Pipeline 

The pipeline that would transfer the CO2 from the compression-dehydration facility to the CO2

injection well would be 4-inch (10.16 cm) to 6-inch (15.24 cm) diameter schedule 40 or schedule 

80 steel pipe designed to meet standards for the temperature and pressure of the CO2 stream. 

The pipeline would be installed aboveground, following the current pipeline alleys at the Decatur 

ADM Complex as much as possible (Figure 2.1.1-2). The pipeline would be located only on 

Decatur ADM Complex property. The pressurized pipeline length would be approximately 

3,000 feet (914 m) (MGSC, 2008). 

2.1.2.4 Injection Well 

The injection well and verification wells would be located in a field north of the primary 

industrial complex (Figure 2.1.1-2). Previously, this field was used for grain farming and laid 

fallow. The proposed injection rate is approximately 1,100 short tons/day (1,000 metric 

tons/day) of supercritical CO2 with a cumulative amount of approximately 1.1 million short tons 

(1 million metric tons) over three years. If the Proposed Action is funded, it is scheduled to 

begin in December 2009 (NETL, 2008b). 

Based on regional geology, the specific injection interval within the Mt. Simon is planned to be 

near the base of the Mt. Simon Sandstone and the granite basement rock. The injection interval 

would be identified based on well logs, core samples, and drill stem tests from the initial well 

drilled on the site during Phase II (NETL, 2008b). 

For the anticipated Mt. Simon net thickness and permeability, reservoir modeling and nodal 

analyses suggest that a single injection well with 95/8 inch (24.45 cm) diameter injection casing 

and 4.5-inch (11.43 cm) diameter injection tubing would be adequate to meet the 1,100 short 

tons/per day (approximately 1,000 metric tons/day) injection rate into the injection tubing. Predrilling modeling would be revised once well logs and core samples are recovered from the 

Phase II well. The proposed project timeline calls for a 12-15 month period between completing 

the Phase II well (drilling and casing) and CO2 injection during Phase III. Perforating the well 

casing would occur in the Mt. Simon formation shortly before CO2 injection beings, assuming 

identification of a highly permeability zone. If the potential injectivity of this interval is not 

large enough or the interval is not found, the well could be perforated at different depths and 

permeability tests conducted so that an appropriate injection interval could be determined 

(NETL, 2008b). 

The installation, operation, and eventual closure of this injection well are carefully governed by a 

regulatory program administered by USEPA, and delegated to qualified states such as the state of 

Illinois, known as the Underground Injection Control (UIC) permit program. MGSC has applied 

for a UIC permit for the establishment of this injection well as a Class 1 well, a designation of 

wells that inject industrial non-hazardous liquids, municipal wastewaters or hazardous wastes 

beneath the lowermost Underground Source of Drinking Water (USDW). 
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USEPA’s UIC regulations prohibit injection wells from causing “the movement of fluid 

containing any contaminant into an underground source of drinking water, if the presence of that 

contaminant may cause a violation of any primary drinking water regulation...or may otherwise 

adversely affect the health of persons” (40 CFR 144.12(a)). The federal UIC Program has been 

implemented since 1980 and has responsibility for managing over 800,000 injection wells. The 

programmatic components of the UIC Program are designed to prevent fluid movement into 

USDWs by addressing the potential pathways through which injected fluids can migrate into 

USDWs. These programmatic components are described in general below (USEPA, 2008a): 

• Siting: Injection wells are to be sited to inject into a zone capable of storing the fluid, and 

to inject below a confining system that is free of known open faults or fractures. 

• Area of Review (AOR) and Corrective Action: Examination required of the vertical and 

horizontal extent of the area potentially influenced by injection and storage activities; and 

identification of all artificial penetrations in the area that may act as conduits for fluid 

movement into USDWs (e.g., active and abandoned wells) and, as needed, perform 

corrective action to these open wells (i.e., artificial penetrations). 

• Well Construction: USEPA requires injection wells to be constructed using well materials 

and cements that can withstand injection of fluids over the anticipated life span of the 

project. 

• Operation: Injection pressures must be monitored so that fractures that could serve as 

fluid movement conduits are neither propagated into the layers in which fluids are 

injected or initiated in the confining systems above. 

• Mechanical Integrity Testing: The integrity of the injection well system must be 

monitored at an appropriate frequency to provide assurance that the injection well is 

operating as intended and is free of significant leaks and fluid movement in the well bore. 

• Monitoring: Owners or operators must monitor the injection activity using available 

technologies to verify the location of the injected fluid, the pressure front, and 

demonstrate that injected fluids are confined to intended storage zones (and, therefore, 

injection activities are protective of USDWs). 

• Well Plugging and Post-Injection Site Care: At the end of the injection project, USEPA 

requires injection wells to be plugged in a manner that ensures that these wells will not 

serve as conduits for future fluid movement into USDWs. Additionally, owners or 

operators must monitor injection wells to ensure fluids in the storage zone do not pose an 

endangerment to USDWs. 

2.1.2.5 Verification Wells 

There are plans to drill and complete up to two verification wells within the Mt. Simon. Because 

of the research aspects of this project, these wells would be drilled to verify the location of the 

CO2 within the Mt. Simon. The placement of these verification wells would be based on the 

location of the CO2 plume as inferred from other techniques such as a seismic survey (ADM, 

2008a). 

The verification wells would be drilled and cased. As the verification wells are drilled, 

completed, and tested, the monitoring program would expand to include these additional wells. 

The verification wells would be drilled between years two and four of the project to provide 
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information to confirm geophysical and modeling estimates of plume location and 

geochemical/geomechanical effects of the CO2 on the injection reservoir and caprock (NETL, 

2008b). 

The verification wells would use a state-of-the-art system designed by Schlumberger Oilfield 

Services to monitor and collect fluid samples and take pressure measurements in the target 

formation and a number of other formations overlying the Mount Simon Sandstone. The 

WestBay SystemTM consists of series of sampling ports situated at different intervals along the 

casing and separated by hydraulic packers, which can be used to isolate each sampling location 

to reduce the number of required monitoring wells (Schlumberger, 2008a). 

2.1.2.6 Groundwater Monitoring Wells 

UIC programs help protect underground sources of drinking water from contamination by 

injection wells (See Section 1.3). ADM submitted a permit application for a Class I Nonhazardous Permit (ADM, 2008a). The Proposed Action would comply with the stipulations of 

the permit. 

Four shallow, groundwater monitoring wells would be drilled around the injection well to the 

bedrock (200-300 feet (60.96 – 91.44 m) deep) to serve as a regulatory basis to monitor 

groundwater quality. Up to twelve additional wells would be drilled at the edges of the ADM 

Phase III Test Site to establish the general direction of groundwater movement prior to CO2

injection (ADM, 2008a). The precise location of these wells will be determined after initial 

geological data is gathered and analyzed from the injection well site. 

Using this information, groundwater modeling would be used to determine locations and 

necessity of additional groundwater monitoring wells. Wells would likely be spaced at different 

increments from the injection well (e.g., 25-150 feet (7.62 – 45.72 m)) once the modeling is 

completed. Additional work would be done to identify existing groundwater wells in the 

immediate area of the injection well that can be used for monitoring (ADM, 2008a). 

At this time, there is one existing shallow groundwater well, completed under Phase II, relatively 

close to the proposed injection site. The area of review has a 2.5-mile (4.02 kilometers (km)) 

radius. However, during the 3 years of active injection of this proposed project, the CO2 would 

be expected to move no more than 1,250 feet (381 m) laterally in the deepest part of the Mt. 

Simon, and much less than that as it would migrated towards the top of the injection formation. 

Monitoring of all of the identified existing groundwater wells in the 2.5 mile (4.02 km) radius in 

the UIC area of review (AOR) would be unnecessary because of the planned number and 

location of new shallow groundwater monitoring wells within the immediate injection well area 

and the extensive monitoring planned for the injection zone (ADM, 2008a). 

All groundwater monitoring wells would be installed and eventually abandoned according to 

Illinois Department of Public Health regulations. During drilling, continuous cores would be 

collected from selected monitoring well locations and archived at the Illinois State Geological 

Survey. Field descriptions of the cores would be recorded and the potential monitoring interval 

identified (ADM, 2008a). 
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Monitoring wells would be constructed with 2-inch (5.08 cm) polyvinyl chloride (PVC) pipe 

with threaded connections. Well screens, slotted screen with 0.010-inch (0.254 millimeter (mm)) 

slots, would be used for groundwater monitoring wells. The screened interval would have a sand 

pack of appropriate thickness based on the monitoring interval identified from core samples. 

Bentonite would be placed above the sand pack to near surface. Concrete pad and a well 

protector would be placed around each well at the surface. The elevations of the monitoring 

wells would be determined by level surveying, based on the known elevation of a local 

benchmark. Prior to implementing the sampling schedule, all wells would be developed. 

Dedicated bladder pumps and pressure transducers would be installed in each well (ADM, 

2008a). 

It is anticipated that background samples would be collected until approximately November 

2009, allowing a minimum of one year of background monitoring. Groundwater samples would 

be collected monthly to determine background water quality near the CO2 injection site. Up to 

sixteen monitoring wells would be installed at or near the injection site. After collecting baseline 

data on water chemistry, temperatures, pH, and pressure, the groundwater would be collected on 

a quarterly basis. Data from the four wells closest to the injection well would fulfill the 

regulatory requirements of the UIC permit and the remaining wells would be used for research 

purposes only (ADM, 2008a). 

2.1.2.7 Vadose Zone Soil Vapor Monitoring Stations 

Vadose zone samplers would be installed to provide soil gas samples. The samplers would 

monitor CO2 concentrations to validate integrity of seal formation, injection well, and other 

potential migration pathways to the biosphere (MGSC, No date). Vadose zone samples located at 

varying depths using field tile drains and drive point samplers may be used to provide soil gas 

samples that would be collected on a periodic basis (NETL, 2008b). 

Indirect strategies include geophysical monitoring of the deep and shallow bedrock, aerial or 

satellite imagery, and multi-phase/multi-component flow models for simulating gas and liquidphase flow in the injection formation (in-zone) and the near-surface environment (out-of-zone) 

(MGSC, No date). 

2.1.2.8 Atmospheric Modeling Data Collection Stations 

Direct measurement of CO2 concentrations in the air is an integral part of the MMV program to 

ensure the health and safety of the public and to curtail environmental impacts. Because of the 

natural variations in CO2 concentrations and fluxes in the near surface environment that arise 

from soil, plant, and subsurface processes, several monitoring techniques would be employed 

(MGSC, No date). 

Eddy covariance is a technique using an Infrared Gas Analyzer (IRGA) and numerous 

micrometeorological variables including wind velocity, relative humidity, and temperature to 

determine CO2 fluxes over a large area. This technique would be employed with the Proposed 

Action because it could be a cost-effective technique to monitor CO2 fluxes. The complexity of 
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the Decatur ADM Complex with respect to potential CO2 sources (industrial, residential, 

vehicular) and temporal releases may make data interpretation difficult. This technique would 

require a minimum of one year of background data and would be deployed early in the MMV 

program. Based on predominant wind directions and area to be monitored, two eddy covariance 

systems may be constructed (MGSC, No date). 

2.1.2.9 Injection Well Surface Facilities 

Facilities and improvements would be constructed or placed at the ground surface within a 300 

feet (91.44 m) by 300 feet (91.44) area in the immediate vicinity of the injection well (see Figure 

2.1.1-2). These facilities, many of which are temporary to the drilling activity, would support 

well construction, operation, and project monitoring. In addition to the wellhead itself, these 

would include: 

• Pipe tubs (to hold drill pipe and casing), 

• Tubs, Catwalk (ramp at the side of the drill rig where pipe is laid out be lifted to the 

derrick floor), 

• Catwalk water tank, 

• Fuel trailer, 

• Frac tanks (tanks to hold fluid for stimulating the well), 

• Pumps (used to pump drilling mud during drilling operations), 

• Drill rig, pumps, 

• Trip tank (a small mud tank used to ascertain the amount of mud necessary to keep the 

wellbore full with the exact amount of mud that is displaced by drill pipe), 

• Steel pits (a temporary steel containment for holding wellbore fluids, 

• Mudlogger ( a person who records information derived from examination and analysis of 

formation cuttings made by the bit and of mud circulated out of the hole to determine the 

presence of natural gas or oil), 

• Pits, Mudlogger, 50,000 gallon (189.27 kiloliter) reserve pit (an earthen, plastic-lined pit 

to clean out the mud pump and store excess drilling mud), 

• 150,000 gallon (567.81 kiloliter) reserve pit (settling or shaker an earthen, plastic-lined 

pit adjacent to the shale shaker where the drill cuttings are separated from the mud, 

• Manifold rack (a pipe fitting with several side outlets to connect it with other pipes), 

• Flare pit (usually a water-filled, plastic-lined, earthen pit over which, a flare is lit to burn 

off an produced natural gas during drilling operations), 

• pit, 20 parking stalls, 

• Three operations trailers, 

• An office/conference room facility, and 

• A communications shack. 

2.1.3 Operations and Maintenance 

2.1.3.1 General 

The proposed injection of approximately 1.1 million short tons (1 million metric tons) of 

supercritical CO2, at the rate of 25.5 pounds (lbs)/second (sec) (1,000 metric tons/day) would 

utilize the Mt. Simon formation as a target storage zone. Injection would be by a single well at 
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the Decatur ADM Complex, an ethanol producer at Decatur, Illinois. There is one operating 

hydrocarbon well site on the Decatur ADM Complex, and the closest known penetration of the 

Mt. Simon formation is approximately 17 miles away (27.36 km) (NETL, 2008b). This is 

expected to be far beyond the radius of influence (1,250 feet (381 m)) of the proposed injection 

well (ADM, 2008a). 

Prior to injection, the CO2 stream from the ADM ethanol fermentor would need to be dewatered 

and compressed. The minimum compression is to the critical point of CO2, which is 88°F 

(31.1°C) and 73 atmospheres pressure (7,395 kPa). In practice, a higher pressure would be 

required, given that the Mt. Simon formation pressure may be between 2,165 psig (14,928 kPa) 

and 2,598 psig (17, 910 kPa) (NETL, 2008b). 

Compression of the gas stream and cooling would cause the water vapor in the CO2 to condense, 

but a condensate of almost pure water and CO2 is a highly corrosive mixture, which could not be 

tolerated in view of the high pressure of the system proposed. The alternative is dehydration 

with a glycol, such as TEG prior to compression or during compression stages. The TEG 

systems, though well known in the oil and gas industry, usually operate at high pressure. 

Engineering experience with low-pressure dehydration is much more limited, although it should 

in principle be workable. 

The current concept is for multiple stages of compression, accompanied by cooling and water 

knock-out, with a TEG system in the final stage. The intent is to avoid the corrosion that would 

occur. This final design is still under consideration for the aboveground facilities, primarily 

because the pressures to be encountered are yet determined from the data collected from the 

injection well. The compression system and final design are yet to be chosen, because the 

pressure of the Mt. Simon formation must await the drilling program for the injection and 

production wells (NETL, 2008b). It is anticipated, however, that the compressors would be 

electrical, since an electrical power supply at the Decatur ADM Complex already exists. 

Non-potable saline water would be produced during drill stem testing and on-going sampling 

from verification wells (ADM, 2008a). In addition, water by-product of the CO2 conditioning 

process prior to injection would be condensation water from the dehydration, which would 

consist of essentially distilled water with a small mole fraction of TEG and perhaps traces of 

ethanol. This fluid would be handled through the existing ADM wastewater system for 

treatment, testing, and disposal. 

Noise control would be maintained by housing the compressors in a dedicated process building. 

2.1.3.2 Target Zone and Operational Integrity 

ADM (2008a) has recognized that the successful operation of the Proposed Action would 

primarily be an issue of the integrity of the test site and would require a number of monitoring 

processes. In principle, compression and dehydration are straightforward matters in petroleum 

engineering. They would be complicated in this instance by issues of corrosion control that in 

part would have to be answered by design considerations of the compression-dehydration 

system. Corrosion monitoring would be an integral part of the operations of the aboveground 
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facilities. Once operational without significant corrosion, the compression-dehydration system 

would be a simple operation with little environmental impact. 

Target Zone

The target zone chosen by the MGSC is the Mt. Simon formation. The top of the Mt. Simon 

formation is thought to be between 5, 000 and 6,000 feet (1.52 – 1.83 km) at the Decatur ADM 

Complex (NETL, 2008b). It is described as very thick sandstone, overlain by the highly 

impermeable Eau Claire formation. The Eau Claire is expected to be 300-500 feet (91.44 – 

152.40 m) thick in the injection area. Further, impermeable confining formations are the 

Maquoketa shale (about 2,500 feet (762 m) below grade) and at lesser depth still the New 

Albany shale (1,800 feet (548.64 m) below land surface). 

For the Proposed Action, the MGSC has set aside 10-12 months between drilling of the injection 

well during Phase II operations and CO2 injection during Phase III for the evaluation of the target 

zone, selection of the injection zone within the Mt. Simon formation, and the construction of 

infrastructure and facilities. While some information from the distant wells suggests that the Mt. 

Simon may show the highest permeability at depth, and show adequate permeability in the top 

200 feet (60.96 m), the MGSC plans to evaluate the full Mt. Simon interval in order to attain the 

target injection rate at a depth as low in the Mt. Simon formation as possible (NETL, 2008b). 

Since CO2 would likely rise within the sandstone, it could do the following (ADM, 2008a). 

• First, the CO2 could dissolve in the saline formation water; this would be expected to be 

an important process at the high pressures involved, and should acidify the water; 

• Second, the acidic water could attack the carbonaceous cements that are sometimes 

present in sandstone, but are limited at this site; this could be a favorable effect in that it 

would improve the permeability to fluid flow. However, initial computer simulations of 

geochemistry suggest that this effect would not be a major one. 

• The Eau Claire formation, being dolomitic, is subject to attack by any residual CO2 that 

had not been consumed by reactions in the target zone. However, it is highly unlikely 

that approximately 1.1 million short tons (1 million metric tons) of CO2 would cause 

sufficient breakdown of the Eau Claire to allow penetration to a higher zone; if that were 

to happen, the CO2 could not penetrate the overlying shale layers, as these would be 

mostly inert to CO2. 

Cement Integrity

The well would be cemented according to Illinois regulations. There would be a period of 10-12 

months between drilling and perforating, and initial use of the injection well. This is, in part, 

intended to allow for core material to be studied such that the best injection depth interval can be 

chosen and perforated. During this period, the MGSC would run casing logs (cement bond logs) 

to check cement integrity prior to deployment. 

The initial cementing of well casing strings would be performed according to requirements of the 

Illinois EPA Underground Injection Control Regulations and defined in the permit application 

(ADM, 2008a). 
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Tests of the Mt. Simon Formation

The closest well penetrating the Mt. Simon formation is over 17 miles (27.36 km) from the ADM 

Phase III Test Site. It follows that little site-specific geologic information exists, and projections 

have been made from existing geological trends. The evaluation of data collected during drilling 

of the CO2 injection well would be used to determine final depths of injection and operational 

conditions. Geologic, geomechanical, and operational information collected during well 

installation includes: 

• The formation pressure, 

• The formation fracture pressure, 

• The fracture gradient of the confining Eau Claire formation, 

• Porosity, 

• Permeabilities, horizontal and vertical (if possible), to CO2 and water, 

• Radius of influence, 

• Injectivity, and 

• Drill stem tests. 

The results of the above would determine the injection pressure, which would not exceed the 

fracture pressure plus some built-in margin of safety. This in turn would determine the pipe size 

required for the planned injection rate and the duty of the compression system. 

Integrity of the Pipeline

System pressure would be monitored closely, as a loss of pressure is indicative of loss of the CO2

supercritical fluid (ADM, 2008a). 

Since CO2 is neither toxic nor explosive, the worst case would be a sudden complete failure of 

pipe. This would release all the CO2 in the pipe. The result would be dry ice formation at the 

break due to the sudden expansion, plus release of a large gas cloud as the supercritical fluid is 

converted to CO2 gas. The gas is non-toxic, but a sudden, large release from the pipeline might 

displace air for the workers at the Decatur ADM Complex, or perhaps at the outskirts of Decatur 

if the release was into a confined area (NETL, 2008b). 

This scenario, though highly unlikely, would be modeled, taking into account the sudden release 

and its atmospheric dispersion. If, after the final design is chosen, the modeling suggests a 

possibility of health effects or even fatalities due to air displacement, it would be necessary to 

install automatic low-pressure shut-downs at intervals along the pipe. The effect of this would 

be to limit the amount of CO2 that could escape in a sudden, complete failure of the pipe (See 

Section 4.9). 

ADM (2008a) has presented a contingency plan for system failure that includes the proposed 

high-pressure compression facility. 
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Summary

The integrity of the system against CO2 release would be dependent on the following: 

• Continuous corrosion testing, 

• Frequent moisture testing of the dehydrated gas, and 

• Continuous pressure monitoring of the pipeline, with automatic shut-down systems. 

Prior to injection, the wells would be logged to determine the casing integrity over the cemented 

intervals (cement bond log) as per ADM UIC Injection Control Permit (ADM, 2008a). 

2.1.3.3 Monitoring, Mitigation, and Validation (MMV) Programs 

A number of intermittent studies or continuous programs would be undertaken: 

Air Dispersion

USEPA models for atmospheric dispersion of gases would be run to estimate dispersion of offgases from the compressor, as well as the issue of sudden CO2 release referred to above. The 

outcomes would be used to assist and direct pilot operation decisions, and to some extent design 

of the facility. In addition, the models would be run to ensure public safety should a complete 

pipe rupture occur (NETL, 2008b). 

Fluid Flow Modeling

A variety of models would be run to gain insight into the nature of fluid flows in the project area, 

including injection zone fluid flow modeling (reservoir simulation), geochemical and mechanical 

modeling, basin wide modeling, groundwater modeling, and near-surface modeling (NETL, 

2008b). The intent of these programs would be to utilize observation well and system pressure 

data for the purpose of understanding the physical processes that would be encountered as a 

consequence of the sequestration. The purpose of this type of modeling is mainly for research. 

History matching of observation well results and wellhead pressures at given flow rates would 

require a number of assumptions to be made due to reservoir and injection rate unknowns. These 

assumptions will be verified or modified as a result of this project and will provide information 

about subsurface processes important to future operations. 

Groundwater Monitoring

Standard groundwater monitoring programs would be used to detect any changes in 

groundwater. Such changes are considered unlikely in the potable groundwater zone due to the 

depth of the targeted Mt. Simon sandstone and the presence of numerous shale gas migration 

barrier formations between the Mt. Simon and the deepest potable groundwater zone. 

The water changes in the injection zone would be monitored by chemical analysis of fluids 

recovered from observation wells. In these wells, it is conceivable that pH changes and 

hardness, as well as alkalinity changes may be observed. Trace element concentration changes 

may also take place. 
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Injection Fluid Sampling

The injected fluids would be sampled prior to injection in accordance with the UIC permit to test 

for the presence of non-condensable gases and certain organic components that may arise from 

the ethanol fermentor (ADM, 2008a). 

Operations Monitoring

The MGSC would utilize automated devices to measure injection volumes, well pressures, 

annulus pressures, and formation temperatures. These would be used to determine the smooth 

functioning of the operation, absence of leaks, and absence of flow behind the injection pipe. 

Continuous pressure readings in pipelines, at the wellhead, and in the wellbore annulus that are 

outside the permit limits would lead to automatic shutdown of the injection system, if necessary, 

per the injection control permit. 

After some months of operation, it would likely be found that some monitoring techniques would 

provide more useful information than others. The frequency of the less helpful measurements 

would then be decreased (ADM, 2008a). 

2.1.4 Decommissioning 

ADM would have several choices available to them: 

First, they may decide to continue the sequestration program as part of their ongoing operations. 

In that case, regulatory approval would be obtained as necessary (ADM, 2008a). 

Second, if they do not choose to continue or if the pilot has not shown unequivocally favorable 

results, the plant site does not require decommissioning immediately. However, the wells would 

have to be abandoned, and the pipeline could be abandoned in place or the aboveground sections 

removed. Well abandonment would be according to IEPA UIC regulations. All 

decommissioning would be done in compliance with applicable laws and regulations. 

2.2 No-Action 

DOE’s provision of cost sharing in the Proposed Action is the Federal action that brings the 

Proposed Action under NEPA regulations. Under the No-Action alternative, DOE would not 

provide partial funding for the proposed project. In the absence of DOE funding, project 

proponents would not proceed with the proposed project tasks. Thus, the components of the 

Proposed Action (including injection of CO2 and building of compression-dehydration facility) 

would not occur under the No-Action alternative. 

2.3 Alternatives Considered but Eliminated from Detailed Analysis 

It is important to remember that the decision under review in this EA is for DOE to either fund or 

not fund the Proposed Action. Two additional alternatives were available for satisfying DOE’s need 
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Proposed Action and Alternatives 32 October 2008 

for developing information on potential technological solutions for geological carbon sequestration 

in this region. 

Alternatives to the Proposed Action include: 

• Conducting the experiment at another field site in the same sedimentary basin and 

• Conducting the experiment in another geographic area (different sedimentary basin). 

The Proposed Action site was selected based on an optimum and advantageous combination of site 

characteristics, including: 

• Regional geologic characteristics (depth and thickness of Mt. Simon, lack of faulting, and 

caprock’s presence and thickness); 

• Local availability of large volumes of CO2,; and 

• Willingness of the industrial partner to cooperate in this effort. 

Other sites that were investigated by the MGSC lacked the strength of the ADM Phase III Test 

Site in one or more of these characteristics. Alternative sites typically would have required 

significantly longer pipelines for transporting CO2 and had less information regarding the 

geologic character of the injection formation and overlying caprocks. Therefore, these other 

sites were eliminated. 

2.4 Issues Considered and Dismissed 

The Purpose and Need section above highlighted the importance of the overall program of 

evaluating carbon capture and storage (CCS) as one tool among many to address global climate 

change while providing this nation with a secure energy future. Many potential impact issues 

associated with EAs were reviewed to compile this EA for DOE. Because of the lack of 

potential impact to certain issues due to the specific characteristics of the Proposed Action, the 

following issues were considered but dismissed from detailed analysis: 

Right-of-Way Acquisition There was no need for additional right-of-way. 

Wild & Scenic Rivers There are no designated Wild & Scenic Rivers 

within a 75-mile (120 km) distance from the project 

site. 

Increase Local Government Expenditures The expected population dynamics of the temporary 

workforce are not expected to impose additional 

local government expenditures through need for 

new roads, schools, etc. 

Impact Property Values This is a minor expansion within an existing 

industrial facility. 

Alter Local Hydrology Patterns None of the proposed construction would impact 

drainage in the local watershed. 
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National Energy Technology Laboratory Final Environmental Assessment

______________________________________________________________________________ 

Proposed Action and Alternatives 33 October 2008 

Harm Tribal Lands No lands affiliated with Native American tribes 

would be impacted by the Proposed Action. 
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National Energy Technology Laboratory Final Environmental Assessment

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The Environmental Analysis Approach 34 October 2008 

3.0 THE ENVIRONMENTAL ANALYSIS APPROACH 

This chapter describes how the environmental review team analyzed the potential impacts of this 

Proposed Action (i.e., injection and analysis of potential for geologic storage of CO2). Chapter 4 

provides a description of the affected environment and the potential environmental effects of the 

Proposed Action along with an analysis of environmental effects if the Proposed Action was not 

implemented. 

3.1 Approach to the Analysis 

An EA is intended to be a clear, focused analysis of impacts. It is not intended to be merely a 

compilation of encyclopedic information about the project or about the environment. 

Accordingly, the environmental review team used a systematic approach to identifying, and then 

answering the relevant impact questions. 

 The initial step was to develop a detailed description of the components of the CO2 storage 

process to be used at this test site to study the potential of geologic sequestration of CO2. This 

description was presented in Chapter 2. 

For each project component (e.g., underground injection of CO2), the team sought to identify all 

the types of direct effects which that activity could cause on any environmental resource. For 

example, clearing a site of vegetation could cause soil erosion. In doing this preliminary 

identification of the types of impacts that potentially could occur, the team drew upon their 

experience with previous projects. 

For each potential direct effect, the team then sought to identify the potential indirect effects on 

other environmental resources. For example, soil erosion could cause sedimentation in nearby 

streams, which could in turn harm the fish and other species in the stream. 

 

In some cases, the team identified multiple effects on the same resource, which are shown in 

diagrams (Figure 3-1). Figure 3-1 is the overall Cause-Effect-Question diagram for the entire 

project. This served as the framework of the analysis of impacts. That is, the team focused their 

efforts on answering these questions as to whether these effects would in fact occur, and if so, 

how extensive, how severe, and how long-lasting they would be. 

Note that Figure 3.1 (next pages) contains references to the specific section of the document 

where each impact is addressed. 

 Site clearing could 

cause 

 Soil erosion? which could 

cause

 Damage to stream species? 
U.S. Department of Energy MGSC Phase 

National Energy Technology Laboratory Final Environmental Assessm

___________________________________________________________________________The Environmental Analysis Approach 35 October 2

Site Selection, 

Preparation, & 

Construction 

for CO2

Injection

Remove and 

Disturb Soils?

Section 4.2

Damage Wetlands?

Section 4.4.2

Generate Dust and 

Emissions?

Section 4.1.2.1

Generate 

Noise?

Section 4.8.6

Degrade Air 

Quality?

Section 4.1.2.1

Increase in Operations Related Noise? 

Section 4.8.6.2

Disturb Adjacent Landowners or Sens

Section 4.8.6.2

Increase Risk for 

Chemical/ Fuel 

Spills?

Sections 4.2.2, 

4.9.2, & 4.8.6.2

Contaminate the Soils? Section 4.2.2

Contaminate Surface or Groundwater? Section 4.9.2

Heavy 

Equipment Will 

Be Used 

During 

Construction

Damage Archeological or Cultural Resources?

Section 4.10.2

Removal of 

Vegetation?

Section 4.5.2

Loss of Habitat? Section 4.5.2 Harm Wildlife? Section 4.5.2 Harm Protected S

Harm Human Health and Safety? Sections 4.8.6.2 & 4.9.2

Drilling

Disposal of Waste Mud/Debris?

Section 4.11.2

Disposal of Wastewater? Section 4.11.2

Generate Noise/Vibrations? Section 4.8.6.2

Increase in Construction Related Noise? 

Section 4.8.6.2

Figure 3.1-1. Cause-Effect-Questions Page 1
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National Energy Technology Laboratory Final Environmental Assessm

___________________________________________________________________________The Environmental Analysis Approach 36 October 2

Increase Local Jobs?

Section 4.8.2.2

Site Selection, 

Preparation, & 

Construction 

for CO2

Injection

(continued)

Increase Income and Spending 

in the Local Area?

Section 4.8.2.2

Purchase of 

Materials and 

Equipment

There Will Be 

a Commitment 

of Land

Change in Land Use?

Section 4.7.2

Degrade Visual/Aesthetics?

Section 4.7.2 

Env

Create 

Local 

Jobs?

Section 

4.8.2.2 Increase in Local Spending? Section 4.8.2.2

Increase Local Population?

Section 4.8.1.2

Increased Risk to Pedestrians and Other Vehicular T

Section 4.9.2

Increase in Traffic?

Section 4.9.2

Transport of 

Equipment, 

Materials, and 

Personnel to 

and from Site

Harm Wetlands/Wildlife?

Section 4.4.2 See Heavy Equipment above

Figure 3.1-2. Cause-Effect-Questions Page 2 
U.S. Department of Energy MGSC Phase 

National Energy Technology Laboratory Final Environmental Assessm

___________________________________________________________________________The Environmental Analysis Approach 37 October 2

Operation 

and 

Maintenance 

of CO2

Injection 

Facilities

Changes to Human Health a

Section 4.9.2

Changes in Contribution to 

Section 4.1.2

Transport, 

Storage, and 

Handling of CO2

for Injection

Degrade Air Quality?

Section 4.1.2

Increase in Energy Usage?

Sections 4.1.2.3 & 4.8.2.3

Increase Risk for Accidents or Spills?

Section 4.9.2

Increase Local Traffic?

Section 4.9.2

Harm Human H

Sec

Contaminate S

Se

Increase in Noise and 

Light Emissions 

Disturb Adjacent Property Owners or Sensitive Receptors?

Section 4.8.6.2

Alter Character of the Neighborhood?

Section 4.7.2

Prepare CO2 Prior to 

Injection

Compression/Dehydration of 

CO2 Prior to Injection?

Section 4.9.2

Disposal of Condensate?

Section 4.11.2

Air Emissions Generated at 

the Facility Will Change

See Site Selection, Preparation, & 

Construction for CO2 Injection

Figure 3.1-3. Cause-Effect-Questions Page 3 
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National Energy Technology Laboratory Final Environmental Assessm

___________________________________________________________________________The Environmental Analysis Approach 38 October 2

Route Selection, 

Construction, 

and Operation 

of CO2 

Transport 

Pipeline

Selecting 

Pipeline Routes

Pipeline Use Will Require 

Maintenance and May Possibly 

Leak CO2 or VOCs

Harm Archeological/Cultural Resources?

Section 4.10.2

Increase in Invasive Species in Right-of-Way?

Section 4.5.2

Harm Surface Vegetation?

Section 4.5.2

Harm Human Health and Safety?

Section 4.9.2

Heavy Equipment Will Be 

Used During Construction 

See Site Selection, Preparation, & Construction fo

Purchase of Materials and 

Equipment

Transport of Equipment, 

Materials, and Personnel to 

and from Site

There Will Be 

a Commitment of Land

Harm Trib

Section 

Harm Historic 

Section 4

Figure 3.1-4. Cause-Effect-Questions Page 4 
U.S. Department of Energy MGSC Phase 

National Energy Technology Laboratory Final Environmental Assessm

___________________________________________________________________________The Environmental Analysis Approach 39 October 2

Subsurface 

Injections of 

CO2

Heavy Equipment Will Be 

Used During Injection

See Site Selection, Preparation, & Construction for CO2 Injection Purchase of Materials and 

Equipment

Transport of Equipment, 

Materials, and Personnel to 

and from Site

Changes to Local 

Employment 

Availability

Disturb Nearby Residents and Sensitive Receptors?

Section 4.8.6.2

Decrease Value of Adjacent Property?

Section 4.8.6.2

Increases in 

Noise and 

Light 

Disturbances

Injection of 

CO2 

Underground

Increased Risk of CO2 Leaks?

Section 4.2.2

Harm Vegetation?

Section 4.5.2

Harm Human Health a

Safety?

Section 4.9.2

Increases in 

Produced Water 

Management 

Issues at the 

Surface

Increased Risk of Leaks and Spills?

Sections 4.4.2 & 4.9.2

Harm Health and Human Safety?

Section 4.9.2

Increased Risk of Wastewater Containing VOCs?

Section 4.9.2

Increased Risk of Hole Stability and Flow 

Control Problems in Older Wells?

Section 4.2.2

Disposal of Wastewater

Harm 

Protected 

Species?

Section 4.5.2

Degrade Air Quality?

Section 4.1.2 See Site Selection, Preparation, & Construction for CO2 Injection

Degrade Water Quality?

Section 4.3.2

See Site Selection, Preparation, & Con

for CO2 Injection

Cause Soil Interactions?

Section 4.2.2

Cause Leaks of CO2?

Sections 4.9.2, 4.4.2, & 4.5.2

Figure 3.1-5. Cause-Effect-Questions Page 5 
U.S. Department of Energy MGSC Phase III 

National Energy Technology Laboratory Final Environmental Assessment

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The Environmental Analysis Approach 40 October 2008 

3.2 Analysis of Significance 

The review team used a systematic process to evaluate the importance, or significance, of the 

predicted impacts. This process involved comparing the predictions to the significance criteria 

established by the team and set out below in Table 3.2. These significance criteria were based on 

legal and regulatory constraints and on team members’ professional technical judgment. 

Table 3.2. Impact Significance Thresholds 

Impact Significance Thresholds 

Resource Area An impact would be significant if it EXCEEDS the following conditions. 

Air Quality The project would not produce emissions that would impede the area’s 

conformity with the State Implementation Plan under the Clean Air Act. 

Geologic Formations The Proposed Action would cause no measurable leakage of CO2 from the 

storage formation to the surface or into another area in the subsurface, and 

there is no more than an imperceptible risk of inducing seismic events due to 

increased reservoir pressure. 

Soils Any changes in soil stability, permeability, or productivity would be limited 

in extent. Full recovery would occur in a reasonable time*, considering the 

size of the project. Mitigation, if needed, would be simple to implement and 

proven to be effective in previous applications. 

Surface Water Any changes to surface water quality or hydrology would be confined to the 

immediate project area. Full recovery would occur in a reasonable time, 

considering the size of the project and the affected area’s natural state. 

Groundwater 

Any changes to groundwater quality and quantity would be at the lowest 

detectable levels. Full recovery would occur in a reasonable time. 

Mitigation, if needed, would be proven to be effective in previous 

applications. 

Wetlands Any impacts to wetlands would be confined to the immediate project area 

and would not cause any regional impacts. Planned mitigation measures 

would fully compensate for lost wetland values in a reasonable time. 

Terrestrial 

Vegetation 

Any changes to native vegetation would be limited to a small area and would 

not affect the viability of the resources. Full recovery would occur in a 

reasonable time, considering the size of the project and the affected 

resource’s natural state. Mitigation, if needed, would be proven to be 

effective in previous applications. 

Wildlife Any changes to wildlife would be limited to a small portion of the population 

and would not affect the viability of the resource. Full recovery would occur 

in a reasonable time, considering the size of the project and the affected 

species’ natural state. 

Threatened or 

Endangered Species 

Any effect to a federally listed species or its critical habitat would be so small 

that it would not be of any measurable or perceptible consequence to the 

protected individual or its population. This negligible effect would equate to 

a “no effect” determination in U.S. Fish and Wildlife Service terms. 
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National Energy Technology Laboratory Final Environmental Assessment

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The Environmental Analysis Approach 41 October 2008 

Land Use 

Any change in land use would be limited to a small area and would not 

noticeably alter any particular land use at the ADM Phase III Test Site or in 

adjacent areas. The affected areas would fully recover in a reasonable time 

once the project is completed. 

Population and 

Employment 

Changes to the normal or routine functions of the affected community are 

short-term or do not alter existing social or economic conditions in a way that 

is disruptive or costly to the community. 

Infrastructure 

The project would not noticeably affect or disrupt the normal or routine 

functions of public institutions, roads, electricity, and other public utilities 

and services in the project area. 

Parks and Recreation Any disturbance would be minor, temporary in duration, and in character 

with existing uses of the project area. 

Visual Resources 

The action, along with planned mitigation, would not permanently change the 

visual landscape in a way that is objectionable to a number of local residents 

or frequent visitors. 

(or) 

The action, along with planned mitigation, would not change the visual 

resource classification of the affected area. 

Noise Noise levels in the project area would not exceed ambient noise level 

standards as determined by the Federal, state, and/or local government. 

Environmental 

Justice 

Neither minority nor low-income groups within the affected community 

would experience proportionately greater adverse effects than other members 

of the community would. 

Human Health and 

Safety 

The project, with current and planned mitigation measures, would pose no 

more than a minimal risk to the health and safety of on-site workers and the 

local population. 

Cultural Resources 

The action would not affect the context or integrity features (including visual 

features) of a site listed or eligible for listing on the National Register of 

Historic Places or of other cultural significance. Following consultations 

with the SHPO/Tribal Historic Preservation Office(r) (THPO) and any other 

potentially affected groups including Indian Tribes, local governments, and 

the National Park Service (NPS), the determination of effect under Section 

106 of the NHPA would be no adverse effect. 

Waste Management 

The action, along with planned mitigation measures, would not cause air, 

water, or soil to be contaminated with hazardous material that poses a threat 

to human or ecological health and safety. 

* Recovery in a reasonable time: Constant, sustainable improvement is apparent and measurable when the site is 

routinely observed, and full recovery is achieved over a period of no more than several years.
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National Energy Technology Laboratory Final Environmental Assessment

______________________________________________________________________________ 

Description of the Affected Environment 42 October 2008 

& Environmental Effects 

4.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT AND 

ENVIRONMENTAL EFFECTS 

4.1 Air Quality 

4.1.1 Description 

This is a description of regional climate, ambient air quality with respect to attainment of 

National Ambient Air Quality Standards (NAAQS), and identification of applicable air quality 

regulations. 

4.1.1.1 Climate and Weather 

Decatur, Illinois, average winter temperature is 25.7°F. The average summer temperature is 

74.6°F. The total annual precipitation is 39 inches (99.06 cm) with 58% of this falling in April 

through September. The growing season for most crops also falls within the April through 

September period. The average seasonal snowfall is 21.5 inches (54.61 cm) (MGSC, 2008). 

4.1.1.2 National Ambient Air Quality Standards and Attainment Status 

USEPA Region 5 and the Illinois Environmental Protection Agency (IEPA) regulate air quality 

in Illinois. The CAA (42 USC 7401-7671q), as amended, gives the USEPA the responsibility to 

establish the primary and secondary NAAQS (40 CFR Part 50) that set acceptable concentration 

levels for seven criteria pollutants: fine particulate matter (PM10),very fine particulate matter 

(PM2.5), sulfur dioxide (SO2), carbon monoxide (CO), nitrous oxides (NOx), ozone (O3), and 

lead. Short-term standards (1-, 8-, and 24-hour periods) have been established for pollutants 

contributing to acute health effects, while long-term standards (annual averages) have been 

established for pollutants contributing to chronic health effects. Based on the severity of the 

pollution problem, nonattainment areas are categorized as marginal, moderate, serious, severe, or 

extreme. Each state has the authority to adopt standards stricter than those established under the 

federal program. However, the State of Illinois accepts the federal standards. 

Federal regulations designate Air-Quality Control Regions (AQCRs) in violation of the NAAQS 

as “nonattainment” areas. Federal regulations designate AQCRs with levels below the NAAQS 

as “attainment” areas. “Maintenance” AQCRs are areas that have previously been designated 

“nonattainment” and have been redesignated to “attainment” for a probationary period through 

implementation of maintenance plans. The ADM Phase III Test Site is completely within the 

West Central Illinois Intrastate AQCR (AQCR 075) (40 CFR 81.264). Federal regulations 

designate AQCR 075 as an attainment area for all criteria pollutants (40 CFR 81.314). Because 

the study area is in an attainment region, the air conformity regulations do not apply. However, 

the project’s emissions of criteria pollutants and the applicability thresholds under the general 

conformity rules were carried forward for more detailed analysis to determine the level of impact 

under NEPA. 
U.S. Department of Energy MGSC Phase III 

National Energy Technology Laboratory Final Environmental Assessment

______________________________________________________________________________ 

Description of the Affected Environment 43 October 2008 

& Environmental Effects 

4.1.1.3 Local Ambient Air Quality 

Existing ambient air quality conditions can be estimated from measurements conducted at air 

quality monitoring stations close to the study area (Table 4.1.1.3). With the exception of the 

eight-hour O3 and PM2.5 standards, air-quality measurements are below the NAAQS (USEPA, 

2008b). The reported maximum of 0.091 parts per million (ppm) for the eight-hour level 

exceeds the standard of 0.08 ppm within the region. However, the 3-year average of the fourth 

highest daily maximum 8-hour average O3 concentrations over each year has not exceeded 0.08 

ppm; hence, the attainment status. The reported maximum of 37 micrograms per cubic meter 

(μg/m3) for the 24-hour PM2.5 level exceed the standards of 35 μg/m3. However, it was only 

exceeded once; hence, the attainment status. 

Table 4.1.1.3. NAAQS and Monitored Air Quality Concentrations 

Pollutant and Averaging Time Primary 

NAAQS1

Secondary 

NAAQS1

Monitored 

Data2

Location of 

Station 

CO 

8-Hour Maximum3 (ppm) 9 (None) 2 

1-Hour Maximum3 (ppm) 35 (None) 3 Sangamon County

NO2

Annual Arithmetic Mean (ppm) 0.053 0.053 (no data available) - 

Ozone

8-Hour Maximum4 (ppm) 0.08 0.12 0.091 Macoupin County

PM2.5

Annual Arithmetic Mean5 (μg/m3) 15 15 14 

24-Hour Maximum6 (μg/m3) 35 35 37 Macon County 

PM10

Annual Arithmetic Mean7 (μg/m3) 50 50 24 

24-Hour Maximum3 (μg/m3) 150 150 54 Macoupin County

SO2

Annual Arithmetic Mean (ppm) 0.03 (None) 0.003 

24-Hour Maximum3 (ppm) 0.14 (None) 0.05 Sangamon County

3-Hour Maximum3 (ppm) - 0.5 0.198 

 1 - Source: 40 CFR 50.1-50.12. 

 2 - Source: (USEPA, 2008b). 

 3 - Not to be exceeded more than once per year 

 4 - The 3-year average of the fourth highest daily maximum 8-hour average O3 concentrations over each year 

must not exceed 0.08 ppm. 

 5 - The 3-year average of the weighted annual mean PM2.5 concentrations from must not exceed 15.0 μg/m3

. 

 6 - The 3-year average of the 98th percentile of 24-hour concentrations at each population-oriented monitor must 

not exceed 65 μg/m3

. 

 7 - The 3-year average of the weighted annual mean PM10 concentration at each monitor within an area must not 

exceed 50 μg/m3

. 

 ppm = parts per million 

 μg/m3

 = micrograms per cubic meter 

 NO2 = Nitrogen dioxide 

 
U.S. Department of Energy MGSC Phase III 

National Energy Technology Laboratory Final Environmental Assessment

______________________________________________________________________________ 

Description of the Affected Environment 44 October 2008 

& Environmental Effects 

4.1.1.4 Existing Facility Emissions 

The Decatur ADM Complex operates a variety of grain processing activities, including milling, 

oil refining, alcohol, and ethanol production. It has many stationary sources of air emissions. 

Significant sources of emissions include storage tanks, dryers, boilers, evaporators, and 

conveyers. Insignificant sources include small boilers, storage tanks, and internal combustion 

engines. Based on the facility’s potential to emit, Decatur ADM Complex is a major source of 

volatile organic compounds (VOC), PM, CO, hazardous air pollutants (HAPs), NOx, and SO2. A 

facility-wide Title V permit (permit number 115015AAE) was issued on August 18, 2004 (IEPA, 

2004). As part of the permit requirements, the facility must comply with emission limits and 

operational hours for individual pieces of equipment, and submit an annual facility-wide 

emission statement. Table 4.1.1.4 lists the overall annual emissions for the Decatur ADM 

Complex. Notably, because CO2 is not currently regulated, CO2 emissions are not tracked at the 

facility. 

Table 4.1.1.4. Existing (2007) Air Emissions for Decatur ADM Complex 

Criteria Pollutants Decatur ADM Complex 

Annual Emissions (Short Tons per Year) 

CO 3000 

NOx 2665 

PM10 1476 

PM2.5 439 

SO2 9206 

VOC 3881 

Source: (ADM, 2008b). 

4.1.1.5 Greenhouse Gasses and Global Warming 

Greenhouse gases (GHG) are components of the atmosphere that contribute to the greenhouse 

effect and global warming. Some greenhouse gases occur naturally in the atmosphere, while 

others result from human activities such as the burning of fossil fuels. Federal agencies, states, 

and local communities address global warming by preparing GHG inventories and adopting 

policies that will result in a decrease of GHG emissions. According to the Kyoto Protocol and 

California Climate Action Registry (CCAR), there are six GHGs: carbon dioxide (CO2), nitrous 

oxide (N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur 

hexafluoride (SF6) (UNFCCC, 2007; CARB, 2007a). Although the direct GHG (CO2, CH4, and 

N2O) occur naturally in the atmosphere, human activities have increased their atmospheric 

concentrations. From the pre-industrial era (i.e., ending about 1750) to 2004, concentrations of 

CO2 have increased globally by 35 percent. Within the United States, fossil fuel combustion 

accounted for 94 percent of all CO2 emissions released in 2005. On a global scale, fossil fuel 

combustion added approximately 30 x109 short tons (27 x109 metric tons) of CO2 to the 

atmosphere in 2004, of which the United States accounted for about 22 percent (USEPA, 2007a). 

DOE’s Energy Information Administration (EIA) report indicates that United States’ CO2

emissions have grown by an average of 1.2 percent annually since 1990 and energy-related CO2

emissions constitute as much as 83 percent of the total annual CO2 emissions (DOE, 2007b). 
U.S. Department of Energy MGSC Phase III 

National Energy Technology Laboratory Final Environmental Assessment

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Description of the Affected Environment 45 October 2008 

& Environmental Effects 

Since 1900, the Earth's average surface air temperature has increased by about 1.2 to 1.4oF. The 

warmest global average temperatures on record have all occurred within the past 10 years, with 

the warmest year being 2005 (USEPA, 2007b). With this in mind, DOE, while preserving their 

core operations, is poised to support climate-changing initiatives to reduce GHG emissions. 

4.1.2 Effects of Proposed Action 

Short-term minor impacts to air quality would be expected with the implementation of the 

Proposed Action. Direct and indirect air emission would not exceed applicability thresholds, be 

“regionally significant,” or contribute to a violation of any federal, state, or local air regulation. 

Air emissions would be limited to temporary diesel emissions from drilling equipment during 

well development and drilling of the observation and groundwater monitoring wells. A 

dehydration reboiler, which could generate limited air emissions, is the only expected source of 

air emissions during injection or monitoring operations. In summary, the project would not 

produce emissions that would impede the area’s conformity with the State Implementation Plan 

under the Clean Air Act. 

4.1.2.1 Estimated Emissions and General Conformity 

The general conformity rules require Federal agencies to determine whether their action(s) would 

increase emissions of criteria pollutants above preset threshold levels (40 CFR 93.153(b)). 

These de minimis (of minimal importance) rates vary depending on the severity of the 

nonattainment and geographic location. Because AQCR 075 is in attainment, the air conformity 

regulations do not apply. However, all direct and indirect emissions of criteria pollutants were 

estimated and compared to applicability threshold levels of 100 short tons per year (tpy) to 

determine whether implementation of the Proposed Action would cause significant 

environmental impacts. The total direct and indirect emissions associated with the following 

activities were accounted for (Table 4.1.2.1). 

• Site preparation & construction, 

• Construction and operation of transport pipeline, 

• Operation and maintenance of injection facilities, and 

• Subsurface injections of CO2. 

Construction emissions would primarily be due to the use of diesel drilling rigs, mud pumps, 

diesel generators and motors, heavy construction equipment, deliveries to the site, the application 

of architectural coatings, and fugitive dust. Drill rig operations during well construction are 

anticipated to occur 24 hours per day and 7 days per week for no more than three months. The 

operational emissions would primarily be due to vehicle operation, and the proposed propanefired dehydration reboiler at the new facilities. There are no planned operational activities along 

the proposed pipeline or at the well sites that would generate emissions of criteria pollutants. 

The total direct and indirect emissions associated with the Proposed Action would not exceed 

applicability threshold levels. Because AQCR 075 is an attainment area, there is no existing 

emission budget. However, due to the limited size and scope of the Proposed Action, it is not 

anticipated that the estimated emissions would make up 10 percent or more of regional emissions 
U.S. Department of Energy MGSC Phase III 

National Energy Technology Laboratory Final Environmental Assessment

______________________________________________________________________________ 

Description of the Affected Environment 46 October 2008 

& Environmental Effects 

for any criteria pollutant and not be regionally significant. A detailed breakdown of drilling, 

construction, and operation emissions is located in Appendix A. 

Table 4.1.2.1. Proposed Action Emissions Compared to Applicability Thresholds 

Annual emissions (Short Tons Per Year) 

Activity (Year) CO NOx VOC SOx PM10 PM2.5

De 

minimis

threshold 

(Short 

Tons Per 

Year)

Would emissions 

exceed 

applicability 

thresholds? 

[Yes/No] 

Drilling and 

Construction (2008) 4.8 8.7 1.2 0.01 0.4 0.4 100 No 

Operational Emissions 0.0 0.1 0.0 0.0 0.0 0.0 100 No 

Note: SOx is sulfur oxides. 

4.1.2.2 Regulatory Review 

New stationary sources of emissions may be subject to both federal and state permitting 

requirements. These requirements include, but are not limited to, New Source Review (NSR), 

Prevention of Significant Deterioration (PSD), and New Source Performance Standards (NSPS) 

for selected categories of industrial sources. In addition, under the National Emission Standards 

for Hazardous Air Pollutants (NESHAP), new and modified stationary sources of air emissions 

may be subject to Maximum Achievable Control Technology (MACT) requirements if their 

potential to emit HAPs exceeds either 10 short tons per year of a single HAP, or 25 short tons per 

year of all regulated HAPs. These regulations are outlined in Title 35 of the Illinois 

Administrative Code Subpart B, Air Emission Regulations (IPCB, 2008). 

The Decatur ADM Complex is in an attainment area and would introduce only one new 

insignificant stationary source of air emissions; the dehydration reboiler. However, since it 

would be located at an existing major source, it is possible that the reboiler would need a permit 

to construct, and be added to the list of insignificant sources outlined in the facility’s Title V 

permit. At the final design stages, the reboiler would be chosen and permitting requirements 

correspondingly determined. 

The construction and drilling activities would be accomplished in full compliance with Illinois 

regulatory requirements through the use of compliant practices and/or products. Some 

applicable sections may include: 

• Subchapter C: Part 212: Visible and Particulate Matter Emissions, 

• Subchapter C: Part 215: Organic Material Emissions Standards and Limitations, and 

• Subchapter I: Part 237: Open Burning. 

Construction and drilling activities would be expected to cause some localized dust. Standard 

mitigation techniques such as watering, erecting wind breaks, and using covers where practicable 

would be employed to minimize its effects. 
U.S. Department of Energy MGSC Phase III 

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4.1.2.3 Greenhouse Gasses and Global Warming 

Direct and Indirect CO2 Emissions. Carbon emissions from the Decatur ADM Complex would 

be captured and sequestered in the Mt. Simon deep saline reservoir. It is anticipated that 

approximately 1.1 million short tons (1 million metric tons) of CO2 would be sequestered during 

the project three year injection period. However, the overall amount of CO2 generated would 

increase due to the burning of diesel fuel during drilling, the additional electrical demand (5-6 

megawatt (MW)), and worker commutes. The net CO2 emissions for the project were estimated 

(Table 4.1.2.3). A net decrease of approximately 988,000 short tons of CO2 emission would be 

realized over the life of the project. These 988,000 short tons of CO2 are currently vented to the 

atmosphere and would not be if the sequestration project is successful. This is less than 0.0001% 

of the global CO2 emissions. The additional 115,000 short tons of that would be generated 

would not be generated at all without the implementation of the Proposed Action. 

Table 4.1.2.3. Net CO2 Emissions for the Proposed Action 

Activity/Source Emissions (Short Tons) 

Drilling and Construction 494 

Electricity Usage 113120 

Worker Commutes 722 

Sequestration (1102300) 

Total Emissions (987964) 

Fugitive CO2 Emissions and Compressor Blowdown. Because sequestration of CO2 is an 

integral part of research and development activities for the Proposed Action, fugitive air 

emissions of CO2 would occur during routine operations. Sources of emissions during 

sequestration operations could include injection and monitoring wells; and aboveground valves, 

piping, and wellheads that comprise the transmission pipeline. In addition, compressors are 

often equipped with automatic blowdown valves that depressurize compressors, bottles, 

separators, and interconnecting lines in the event of a shutdown. 

It is expected that emissions from these sources would be very small. The majority of the CO2

stream that would feed the system would otherwise be vented to the atmosphere without the 

Proposed Action. Therefore, CO2 that is vented from the unit during this project are emissions 

that would otherwise have occurred if the compression unit, pipeline, and wells were not in 

place. Therefore, these sources of fugitive emissions would not increase overall CO2 emissions.

Atmospheric monitoring and modeling for CO2. Direct measurement of CO2 concentrations in 

the air would be an integral part of the MMV Program to ensure the health and safety of the 

public and to curtail environmental impacts. Because of the natural variations in CO2

concentrations and fluxes in the near surface environment that arise from soil, plant, and 

subsurface processes several monitoring techniques would be employed. In addition, to track 

potential leaks the Hybrid Single-Particle Lagrangian Integrated Trajectory Model (HYSPLIT), 

developed by the National Oceanic and Atmospheric Administration (NOAA) and Australia's 

Bureau of Meteorology, would be used to simulate the atmospheric dispersion and the 

concentration distribution of CO2 from multiple-source emissions of CO2, and/or other potential 

pollutants associated with a CO2 release. 
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4.1.3 Effects of No-Action 

Selecting the No-Action alternative would result in no direct impact to ambient air-quality 

conditions. No drilling or construction would be undertaken and no changes in facility 

operations would be expected. Ambient air-quality conditions would remain as described in 

Section 4.1.1.3. 

Selecting the No-Action alternative could have minor indirect impacts to air quality. No-Action, 

meaning that this project is not carried out in any setting, would delay planned larger-scale 

sequestration projects by perhaps several years. The increased understanding of subsurface 

behavior of CO2 would not be gained. Additionally, an example of successful and safe 

sequestration, on any scale, could not be offered to the public in support of a larger, more 

expensive project. The complexities of a larger pilot might translate to long delays in public and 

regulatory approval, thereby jeopardizing goals of rapid action on climate change issues. A 3-

year delay in initiating large-scale sequestration efforts would lead to an increase CO2 emissions 

by approximately 5% and atmospheric concentrations of CO2 would increase by as much as 6 

ppm before any stabilization effort would be started. 

4.1.4 Cumulative Effects 

The State of Illinois takes into account the effects of all past, present, and reasonably foreseeable 

emissions during the development of the State Implementation Plan (SIP). The State of Illinois 

accounts for all significant stationary, area, and mobile emission sources in the development of 

this plan. Estimated emissions generated by the Proposed Action would be de minimis and 

would not be regionally significant. Therefore, it is not anticipated that the Proposed Action 

would contribute substantially to adverse cumulative effects to air quality. 

4.2 Geology and Soils 

4.2.1 Description 

The ADM Phase III Test Site is located on the east side of the city of Decatur, Illinois, which lies 

in Macon County (Section 5 of Township 16 North Range 3 East). The site is located on the 

existing Decatur ADM Complex. Project activities are planned immediately north of the main 

ADM plant in an open field owned by ADM. The land use of the Decatur ADM Complex is 

characterized as industrial, although the test site has been previously leased for agricultural uses 

(MGSC, 2008). Water bodies in the vicinity include Lake Decatur, which was formed in 1920s 

by the damming of the Sangamon River, a principal tributary of the Illinois River (Decatur, 

2008a; IDNR, 2003). This river and reservoir provide surface drainage for the surrounding land 

and water supply for the city of Decatur (Decatur, 2008a). The site is located on essentially flat 

topography with slopes less than 5% as determined from topographic maps covering the area. 

There is no evidence of karst topography (such as sinkholes) in the area (MGSC, 2008). 

Subsurface. The subsurface geology of the Illinois Basin (Figure 4.2.1-1) in the project area 

consists of a thick sedimentary sequence of Cambrian to Pennsylvanian geologic formations 
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overlain by unconsolidated moraine deposits of the Quaternary-age Wedron Group (ISGS, 

1996). The thickest and most widespread brine reservoir in the Illinois Basin is the basal 

Cambrian-age Mt. Simon Sandstone. It is overlain by the Cambrian Eau Claire Formation, a 

regionally extensive very low-permeability shale, and underlain by Precambrian granitic 

basement. The deposition of the Mt. Simon Sandstone is commonly interpreted to be a shallow, 

subtidal marine environment. In general, the paleogeography of Illinois at the time of uppermost 

Mt. Simon deposition was one of a low-relief coastal setting in a subsiding basin that was open 

to the ocean to the south. In the northern half of Illinois, the Mt. Simon is used extensively for 

natural gas storage. Detailed reservoir data are available from these projects. Data from ten Mt. 

Simon gas storage projects shows that the upper 200 feet (60.96 m) has porosity and 

permeability high enough to be a good sequestration target. The closest Mt. Simon penetration 

to the test site is the Harrison #1 well about 17 miles (27.36 km) to the southeast (ADM, 2008a). 
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Figure 4.2.1-1. Illinois Basin’s Stratigraphic Column of Key Formations for CO2 Injection 

Source: (NETL, 2008b). 
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Mapping from regional data suggests that the gross thickness of the Mt. Simon is 1,000 to 1,600 

feet (304.8 – 487.68 m) at the test site. The nearest well with a porosity log for the entire 

thickness of the Mt. Simon, the Humble Oil Weaber-Horn #1 well, was drilled on the Loudon 

Field anticline in Fayette County, a major oilfield 51 miles (82.08 km) south of the project area. 

The Weaber-Horn #1 drilled through 1,300 feet (396.24 m) of Mt. Simon before drilling into the 

Precambrian granite (ADM, 2008a). 

The top of the Mt. Simon at the Weaber-Horn #1 well was at 7,000 feet (2.14 km) and the gross 

thickness had an average porosity, calculated from wireline logs, of about 12 percent. The 

Weaber-Horn #1 well log porosity data are similar to those found in the Hinton #7, the deepest 

well at the Manlove Field in Champaign County, approximately 37 miles (59.55 km) northeast of 

the project area. The Manlove Field is the deepest Mt. Simon natural gas storage field in the 

Illinois Basin (NETL, 2008b). 

A regional Mt. Simon structure map suggests that the top of the Mt. Simon is between 5,000 and 

6,000 feet (1.52 and 1.83 km) measured depth at the test site. For the CO2 injection portion of 

this research project, the injection interval would not be the entire thickness of the Mt. Simon; 

rather it would be a subinterval within the gross thickness of this massive sandstone geologic 

unit that has acceptable permeability properties (NETL, 2008b). 

Within the Illinois Basin, three thick shale units function as major regional seals. These are, 

from shallowest to deepest, the Devonian-age New Albany Shale, Ordovician-age Maquoketa 

Formation, and the Cambrian-age Eau Claire Formation. There are also many minor, thinner 

Mississippian- and Pennsylvanian-age shale beds that form seals for known hydrocarbon traps 

within the Basin. The lowermost seal, the Eau Claire, has no known penetrations within a 17-

mile (27.36 km) radius surrounding the test site; therefore, there are no existing wellbores whose 

integrity would be of concern. All three major seals are laterally extensive and appear, from 

subsurface wireline correlations, to be continuous within a 100-mile (160.93 km) radius of the 

test site (NETL, 2008b). 

The primary confining zone (seal) at the test site is the Cambrian age Eau Claire Formation. An 

isopach map based on regional well control suggests that the Eau Claire should be 300–500 feet 

(91.44 – 152.40 m) thick at the proposed test site. The estimated top of the Eau Claire Formation 

would occur between 4,500 to 5,500 feet. The Eau Claire Formation is composed primarily of a 

silty, argillaceous dolomitic sandstone or sandy dolomite in northern Illinois and becomes a 

siltstone or shale in the central part of the Illinois Basin. Regionally, the Eau Claire is a 

persistent shale interval above the Mt. Simon that is expected to provide a good seal. 

The database of UIC and gas storage wells with cores from the Eau Claire was also used to 

derive seal qualities. Data show that the Eau Claire’s median permeability is 0.000026 

millidarcies (mD) and median porosity is 4.7%. At the Ancona Gas Storage Field, located 80 

miles (128.75 km) to the north of the proposed test site, cores were obtained through 414 feet 

(126.19 m) of the Eau Claire, and 110 analyses were performed on a foot-by-foot basis on the 

recovered core. Most vertical permeability analyses showed values of less than 0.001 mD up to 

0.001 mD. Only five analyses were in the range of 0.100–0.871 mD, the latter being the 

maximum value in the data set. Thus, even the more permeable beds in the Eau Claire 
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Formation are expected to be relatively tight and would tend to act as sealing lithologies (NETL, 

2008b). 

There are two secondary seals expected at the test site. The Ordovician-age Maquoketa Shale is 

laterally continuous across the test site and is estimated to be over 200 feet (60.96 m) thick at the 

test site at an estimated depth of between 2,500 to 2,600 feet (762 to 792.48 m) measured depth. 

This shale is a regional seal for oil reservoirs from the Ordovician Galena (Trenton) Limestone. 

The Devonian-Mississippian-age New Albany Shale at a depth of approximately 1,800 feet 

(548.64 m) is about 140 feet (42.67 m) thick in the project area. Extensive well control from 

oilfields shows that this shale is a good seal for oil accumulations. Thus, it should also be a good 

secondary seal against the vertical migration of CO2 (NETL, 2008b). 

There are no mapped regional faults and fractures within a 25-mile (40.23 km) radius of the 

proposed site. A preliminary 2-D seismic survey has been completed during Phase II of the 

project. Additional 2-D, 3-D, and vertical seismic profile (VSP) data are planned to further 

characterize the site geology and monitor the fate of the CO2 (ADM, 2008a).

Soils. Soils in the area were mapped by the U.S. Department of Agriculture (USDA) in 1990 

(Figure 4.2.1-2). Five silt loam soil units have been mapped within the project site: the 

Drummer silty clay loam (152), Flanagan silt loam (154A), Proctor silt loam (148B), Catlin silt 

loam (171B) and Dana silt loam (56B). The most common soil type is the Drummer, which is 

characterized by a nearly level poorly drained soil that occurs in broad, flat areas on outwash or 

till plains. This soil is not highly susceptible to erosion due to the flat topography. The Flanagan 

silt loam is a nearly level, somewhat poorly drained soil located on broad ridges on till plains and 

moraines. The soil is not highly susceptible to erosion due to the flat topography. The land 

capability classification, or the suitability of a soil type for a particular field crop, for the 

Flanagan and Drummer soil types are moderately limited in the selection of species and require 

moderate conservation measures (NRCS, 2008). Specifically for these soil types, the land 

capability class of IIw denote that excess water (ponding/flooding) can interfere with crop 

productivity. 
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Figure 4.2.1-2. Map of Soil Types over the ADM Phase III Test Site 

Source: (NRCS, 2008). 
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Table 4.2.1. Map Legend to NRCS-derived Soils Map for ADM Phase III Test Site 

Map Unit Symbol Map Unit Name Acres (m2) in Area of 

Interest 

Percent of Area of 

Interest 

56B Dana silt loam, 2 to 5 

percent slopes 

9.3 (37,635) 6.1% 

148B Proctor silt loam, 2 to 

5 percent slopes 

5.9 (23,876) 3.9% 

152A Drummer silty clay 

loam, 0 to 2 percent 

slopes 

64.9 (262,641) 42.9% 

154A Flanagan silt loam, 0 

to 2 percent slopes 

62.1 (251,310) 41.1% 

171B Catlin silt loam, 2 to 5 

percent slopes 

4.3 (17,401) 2.8% 

198A Elburn silt loam, 0 to 

2 percent slopes 

4.0 (16,187) 2.7% 

679B Blackberry silt loam, 

2 to 5 percent slopes 

0.6 (2,428) 0.4% 

802B Orthents loamy, 

undulating 

0.1 (404) 0.0% 

Totals for Area of 

Interest 

 151.2 (611,885) 100.0% 

Source: (NRCS, 2008). 

The Proctor, Catlin, and Dana soils are generally well drained to moderately well drained and 

have moderate rates of air and water movement. These soils have medium surface runoff, high 

water capacity, and moderate organic matter content. They have a land capability classification 

of IIe suggesting the soils have moderate limitations due to their susceptibility to erosion or prior 

damage due to erosion. The maintenance of adequate plant cover can mitigate their vulnerability 

to erosion (NRCS, 2008). 

At the test site, the low topographic relief suggests that there is essentially no potential for 

landslides, and negligible risk of subsidence (ADM, 2008a). 

4.2.2 Effects of Proposed Action 

The main potential negative effects of the Proposed Action (injection of approximately 1.1 

million short tons (1 million metric tons) of CO2 over three years) are identified in the following 

paragraphs with accompanying notations regarding their likelihood of occurrence. 

A sudden release of CO2 to the surface would be considered unlikely because of the well 

technology to be used and the expertise of the technology providers. If it was to occur, such an 

event is unlikely to have a large impact on the soil resources surrounded the well. Effects would 

be very localized and readily remediated. The main risk to the soils would be if a sudden release 

occurred late in the project after substantial injection had occurred (in Year 3 for example). 
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Under these circumstances, the injected CO2 would have had time to interact with organic and 

mineral matter in the reservoir and potentially have dissolved organic compounds and other 

contaminates. In related CO2-EOR experience when sudden releases have occurred, the main 

adverse outcome to soils around the wellhead has been well blowout of dry ice contaminated 

with crude oil. There is no expectation of any crude oil in the reservoir at the ADM site. This 

has been readily cleaned up by removal and replacement with new soil. 

Relatively slow leakage from the well bore due to casing and/or cement problems are likely to be 

detected ahead of time by the Mechanical Integrity Testing proposed in the UIC Permit 

application (ADM, 2008a). 

Relatively slow or extremely slow leakage from the injection zone through the seal and 

ultimately into the soils is an extremely unlikely event even on a time scale of hundreds of years. 

Due to the highly unlikely nature of the above-described effects, the conclusion is that there 

would be no measurable leakage of CO2 from the storage formation to the surface or into another 

area in the subsurface. 

4.2.3 Effects of No-Action 

If the No-Action alternative is implemented, the construction and injection activities of the 

Proposed Action do not take place. Thus, no impacts to soils and geology would occur. 

4.2.4 Cumulative Effects 

ADM has no other projects planned for the area (Carroll, 2008b). Since there are no substantial 

impacts to geological and soil resources, the Proposed Action and the No-Action alternative do 

not substantially contribute to the cumulative impacts to these resources in the project area or its 

vicinity. 

4.3 Water Resources 

4.3.1 Description 

The only significant source of surface water in the immediate vicinity is Lake Decatur, which is 

located approximately 1 mile (1.61 km) to the east of the ADM Phase III Test Site. Lake 

Decatur is a 3,090 acre reservoir formed by the damming of the Sangamon River, a major 

tributary to the Illinois River. Lake Decatur is the source of drinking water for the City of 

Decatur (Decatur, 2008a). 

Water flows in the Sangamon River are monitored by the United States Geological Survey 

(USGS) downstream of the test site (05573540: Sangamon River at Route 48) and the Sangamon 

Dam. Hydrometric records from 1983-2007 indicate an annual mean flow of 693 cubic feet 

(ft3

)/sec (211.23 cubic meter (m3)/sec) and achieved a maximum peak flow of 31,800 ft3/sec 

(9692.64 m3

/sec) in May of 2002 (USGS, 2007). 
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Surface water quality was assessed on the Sangamon River in Decatur, Illinois, between the 

years 1978-1997. Specific conductance was measured between 300-1010 microsiemens per 

centimeter (μS/cm) with a mean value of 586.6 μS/cm. The pH of surface water samples had a 

field test range between 6.4 and 8.8 over the 1978-1997 sampling period (USGS, 2008). 

Lake Decatur and the upstream reaches of the Sangamon River were identified on the IEPA’s 

2006 Section 303(d) (of the Clean Water Act) list of impaired waters (waters in which at least 

one applicable use is not fully supported). Uses not supported for Lake Decatur on the 2006 list 

were aquatic life, fish consumption, public and food processing water supplies, and aesthetic 

quality. The use not supported by upstream segments of the Sangamon River on the 2006 list 

was primary contact. Although still impaired, these waters have been removed from the 2008 

list because a Total Maximum Daily Load (TMDL) has been established by IEPA. The 

exception is that Lake Decatur is on the 2008 303(d) list for not supporting aquatic life and fish 

consumption (IEPA, 2008; IEPA, 2006). 

The City of Decatur also relies on ten groundwater wells to supplement its water supply in times 

of drought. The source of groundwater is the Mahomet Aquifer, located 6 miles to the north of 

the ADM test site, where water is pumped into the Sangamon River to supplement water levels 

in Lake Decatur (Roadcap and Wilson, 2001). The Mahomet aquifer is a major aquifer at 150 – 

300 foot depth capable of yielding significant amounts of water (usually greater than 1,000 

gallons per minute or approximately greater than 3,800 liters per minute). Other shallower 

aquifers are found in the Banner Formation, the Glasford Formation, and more recent sediments 

(ADM, 2008a). 

Sand and gravel aquifers are likely to be thin or absent in the Banner Formation, the lower 

portion of the Glasford Formation, and the more recent sediments. Sand and gravel aquifers are 

likely to be 5 to 20 feet thick in the upper portion of the Glasford Formation and are likely found 

within 100 feet of the ground surface (ADM, 2008a). 

4.3.2 Effects of Proposed Action 

As summarized in Section 2.1.2.4, the current regulatory framework for USEPA’s UIC 

permitting program includes multiple provisions for safeguarding and preventing injected fluid 

movement into USDWs. The permitted Class I injection well on the ADM test site would 

employ accepted industry standards in meeting the specified permit provisions and conditions. 

The findings of this section are valid only if the UIC permit application is successful and a Class 

I permit is issued for the ADM test site injection well. 

The sequestration of CO2 in deep brine reservoirs involves possible drilling through USDWs and 

a slow upward migration of sequestered CO2 that has the potential to impact groundwater quality 

if not adequately trapped by confining layers. CO2 interacts with the host brine to generate a low 

pH solution (on the order of 2.8 to 3.0). This acid water is known to mobilize metals adsorbed to 

mineral grains. Injection of CO2 could also cause pressure gradients that can result in 

displacement of brine into overlying aquifers. These outcomes are of relatively low risk for the 

ADM Phase III Test because of the: 

• Depth of the proposed injection zone, 
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• Multiple sequences of shale seals between the injection zone and USDW, 

• Absence of seismic activity in the local area, and 

• Relatively low injection rates of CO2 compared to proposed commercial projects or the 

FutureGen project. 

The main potential negative effects of the Proposed Action (injection of approximately 1.1 

million short tons (1 million metric tons) of CO2 over three years) are identified in the following 

paragraphs with accompanying notations regarding their likelihood of occurrence. 

A sudden release of CO2 to the surface involves extreme volume expansion of CO2 from 

supercritical liquid state to gas and the large adiabatic decompression that occurs in such events 

are explosive in nature and result in high velocity ejection of dry ice and frozen formation water. 

Some of this material would be injected into the shallow aquifers around the wellhead. This type 

of event is considered unlikely for the Proposed Action because of the well technology to be 

used and the expertise of the technology providers. If it does occur, such an event is unlikely to 

have a large impact on the water resources surrounding the well. Effects would be very localized 

and readily remediated (Skinner, 2003). 

The main risk to water resources would be if a blowout occurred late in the project after 

substantial injection had occurred (in Year 3 for example). Under these circumstances, the 

injected CO2 would have had time to interact with organic and mineral matter in the reservoir 

and potentially have dissolved organic compounds and other contaminates. In CO2-EOR 

experiences when blowouts have occurred, the main adverse outcome to shallow groundwater, 

immediately around the wellhead, has been well blowout of dry ice contaminated with crude oil 

(Skinner, 2003). This has been readily cleaned up by standard groundwater remediation 

methods. 

Relatively slow leakage from the well bore due to casing and/or cement problems are highly 

likely to be detected ahead of time by the Mechanical Integrity Testing proposed in the UIC 

Permit application. 

With regard to relatively slow or extremely slow leakage from the injection zone through the seal 

into USDW, data in the specific test location is not yet available, but proxy information from 

other similar wells in the region may be used to infer such values by analogy and the proposed 

12 to 15 month pre-injection data monitoring and modeling period for the ADM Phase III Test 

Program will confirm and modify that proxy information as necessary. Potential impacts to 

groundwater will also be anticipated and minimized by implementation of a monitoring and 

mitigation plan that focuses on potential leakage pathways. For this test, there are four 

geological factors to consider when assessing the possibility that upward migration of the 

injected and sequestered CO2 into USDWs. They are the number of intervening confining layers 

that occur between the injection zone and USDWs, thickness of those confining layers, the 

permeability and porosity of the confining layers, and the potential for fracture to occur in the 

confining layers. 

Section 4.2.1 indicated that there are three thick shale units that function as major regional seals. 

There are also many minor, thinner Mississippian- and Pennsylvanian-age shale beds that form 
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seals for known hydrocarbon traps within the basin (ADM, 2008a). Just as important, the 

lowermost Eau Claire seal has no known penetrations within a 17-mile (27.36 km) radius 

surrounding the site; therefore, integrity of existing wellbores is not as significant an issue as in 

some shallower formations. All three major seals are laterally extensive and appear, from 

subsurface wireline correlations, to be continuous within a 100-mile (160.93 km) radius of the 

test site (ADM, 2008a). 

Section 4.2.1 also states that the expected thicknesses of the confining layers at the test site are 

substantial, likely measuring 300-500 feet (91.44 – 152.40 m) for the primary Eau Claire 

formation, over 200 feet (60.96 m) for the Maquoketa formation, and 140 feet (42.67 m) for the 

New Albany Shale formation. The shallower secondary formations have already demonstrated 

their effectiveness as regional seals for oilfields (NETL, 2008b). 

Section 4.2.1 summarizes porosity and permeability values from nearby gas storage wells, 

concluding that even the more permeable beds in the Eau Claire formation, with permeability 

values as high as 0.871 mD are expected to be relatively tight and tend to act as sealing 

lithologies (NET, 2008b). 

The main faults and or fracture zones of concern are ones that may penetrate through the seals 

into the reservoir (that is ones that penetrate the containment zone). Based on information 

presented in the UIC permit (ADM, 2008a) application, no faults have been documented within 

25 miles (40.23 km) of the test site. Section 4.2.1 indicates that a preliminary 2-D seismic 

survey has been completed during Phase II of the project. Additional 2-D, 3-D, and VSP data 

are planned to further characterize the site geology and monitor the fate of the CO2. There is no 

specific data available on the fracture pressure of the Eau Claire Formation, but there are 

indications of successful storage of gas in the Mt. Simon without fracturing the overlying Eau 

Claire for 10 underground natural gas storage reservoirs in Illinois operating in the Mt. Simon at 

depths ranging from 1,420 to 3,950 feet (432.82 to 1,203 m) (ADM, 2008a). 

The injection process does not utilize substantial volumes of water. Therefore, there should not 

be a direct impact on the supply of water resources of the area. 

The surface water resources primarily represented by Lake Decatur are subject to the same 

subsurface effects described above for USDWs. The difference is the potential effects are 

reduced by the greater vertical separation from the saline reservoir as well as horizontal 

separation from the lake, which is approximately 1 mile (1.61 km) to the east of the ADM Phase 

III Test Site. As described earlier, a sudden CO2 release to the surface causes formation of dry 

ice and frozen formation water, and the effects are very localized. 

The soils are not highly erodible (See Section 4.2), so water contamination from increased runoff is not a major issue. Further, the facility has received a construction permit under the 

General NPDES permit for construction storm water discharges (Keller, 2008). 

For reasons presented above, the project has limited potential to have negative effects on the 

availability and current uses of water resources and the potential to cause impairment of water 

resources through construction and operation of the sequestration project. 
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4.3.3 Effects of No-Action 

If the No-Action alternative is implemented, the construction and injection activities of the 

Proposed Action do not take place. Thus, no impacts to water resources are expected to occur. 

4.3.4 Cumulative Effects 

ADM has no other projects planned for the area (Carroll, 2008b). Since there are no substantial 

impacts to water resources, the Proposed Action and the No-Action alternative do not 

substantially contribute to the cumulative impacts to these resources in the project area or its 

vicinity. 

4.4 Wetlands and Floodplains 

4.4.1 Description 

There are no wetlands designated within the project area boundaries according to the National 

Wetlands Inventory (USFWS, 1987). The facility would be built within the existing industrial 

setting of the Decatur ADM Complex, and the pipeline would not be located near any wetland 

area. The nearest wetland is located adjacent to the western boundary of the ADM Phase III Test 

Site with a road separating it from the test site (Figure 4.4.1-1). Additionally, there is a manmade settling pond at the test site that collects surface runoff and/or drain tile water. 

The National Wetlands Inventory map unit outside of the northwest site boundary is classified as 

PEMAf (USFWS, 1987). The PEMAf unit is an emergent wetland classified as palustrine 

emergent temporarily or semi-permanently flooded (USFWS, 2008a). Palustrine system 

designations include all non-tidal wetlands dominated by trees, shrubs, persistent emergent 

vegetation, emergent mosses, or lichens. 

There are no floodplains in the ADM Phase III Test Site area. The nearest floodplain is 

associated with an unnamed tributary off the Sangamon River and Lake Decatur to the east of the 

test site approximately 0.36 miles (0.58 km) (Illinois State Water Survey, 1996). Figure 4.4.1-2 

(second page) shows the location of the floodplains to the test site. 
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Figure 4.4.1-1. Water Bodies and Wetlands near the Test Site 
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Figure 4.4.1-2. Floodplains near the ADM Phase III Test Site 
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4.4.2 Effects of Proposed Action 

As there are no wetlands or floodplains in the test site, wetland resources and floodplains would 

not be impacted by construction of the Proposed Action. Although three wells would be drilled 

along the western boundary of the test site, they would be far enough away so that there would 

be no impacts to the wetland located across the road outside the study area. Furthermore, it is 

not likely that wetlands would be impacted by the discharge of wastewater from project 

activities. Similarly, the wells drilled on the eastern boundary of the test site should be far 

enough away so that there would be no impacts to floodplains. 

The unlikely event of leakage of injected CO2 to the surface could pose detrimental effects on 

wetlands and floodplains near or at some distance from the test site. Wetland vegetation and 

water quality could be impacted by increased concentrations of CO2, possibly resulting in 

changes in species composition, plant death, changes in pH, and water quality (International 

Energy Agency, 2007). 

Although leakage of CO2 to the surface affecting wetlands and floodplains in a widespread area 

is possible, it is more likely that any impacts to wetlands and floodplains would be confined to 

the immediate project area and would not cause any regional impacts. Thus, impacts on 

wetlands and floodplains by the Proposed Action would not be expected to exceed the 

significance threshold. 

4.4.3 Effects of No-Action 

Under the No-Action alternative, the ADM Phase III Test Site work by the MGSC would not be 

implemented. No impacts to wetlands or floodplains would occur as a result of this alternative. 

4.4.4 Cumulative Effects 

Previous industrial development of the project area by ADM and recent agricultural practices 

may have resulted in impacts to any wetlands that may have occurred onsite at one time. 

Wetlands in the project area vicinity are subject to adverse effects from ongoing agricultural, 

residential, and industrial activities; these activities are likely to continue in the future. The 

proposed project would not pose any threats to wetlands or floodplains in the project area, aside 

from the unlikely leakage of CO2 to the surface, which would have widespread consequences on 

wetlands and floodplains. However, given the larger impacts to wetlands and floodplains from 

past, present, and future activities, cumulative impacts contributed by the proposed project would 

be minimally adverse and are not expected to exceed the threshold of significance. 

4.5 Terrestrial Vegetation 

4.5.1 Description 

The proposed new CO2 injection wells and observation wells would be located in an area 

characterized by the Bailey Ecoregion classification as the Prairie Parkland (Temperate) 
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Province of the Prairie Division (National Atlas, 2008). This ecoregion covers an extensive area 

from Canada to Oklahoma, with alternating prairie and deciduous forest. Vegetation in this 

province is forest-steppe, characterized by intermingled prairie, groves, and strips of deciduous 

trees (Bailey, 1995). Trees often cover the highest hills. Grasses are the dominant prairie 

vegetation. The most prevalent type of grassland is bluestem prairie, dominated by such plants 

as big bluestem, little bluestem, switchgrass, and Indian grass, along with many species of 

wildflowers and legumes. In many places where grazing and fire are controlled, deciduous forest 

is encroaching on the prairies. Due to generally favorable conditions of climate and soil, most of 

the area is cultivated, and little of the original vegetation remains. The upland forest in this 

province is dominated by oak and hickory. 

The Proposed Action site consists of land within the Decatur ADM Complex that has been 

disturbed from its natural state. Surrounding land is industrial, residential, or agricultural. An 

adjacent fallow agricultural field owned by ADM comprises most of the test site. Low growing 

grasses occur on the area surrounding the Anaerobic Wastewater Treatment Facility, which has 

been previously disturbed. 

The Illinois Department of Natural Resources has compiled an inventory of resource rich areas 

(RRA) in Illinois (MGSC, 2008). The Proposed Action site does not lie within a designated 

natural area. The Sangamon River RRA, approximately seven miles (11.27 km) to the northeast 

of the Proposed Action site, is the closest RRA. 

No critical habitats or federally listed plant species exist in the vicinity of the test site. Two 

federally listed plant species, Eastern prairie fringed orchid (Platanthera leucophaea) and prairie 

bush clover (Lespedeza leptostachya) – both threatened, and one Illinois state listed endangered 

plant species, wild hyacinth (Camassia angusta), occur in Macon County (USFWS, 2007; IDNR, 

2008), but are not likely to be found in the project area. A review of the U.S. Fish and Wildlife 

technical assistance website (USFWS, 2008b) on June 10, 2008, for federally listed threatened 

and endangered species resulted in a conclusion that the Proposed Action would have “no effect” 

on listed species, their habitats, or proposed or designated critical habitat. An official 

consultation request and documentation memo are included in Appendix B. 

4.5.2 Effects of Proposed Action 

Construction activities associated with the Proposed Action would occur in the fallow field north 

of the main ADM plant where there is no native vegetation growing, or in the complex itself. 

Some of the new proposed wells and pipeline may be placed in the areas of low growing grasses, 

which may be disturbed or removed for well and pipeline installation. The majority of 

disturbance would occur in previously disturbed areas, minimizing adverse impacts on 

vegetation. The CO2 compression-dehydration surface facility and part of the pipeline would be 

in the industrial complex part of the Decatur ADM Complex, which mainly consists of paved 

surfaces. 

Approximately a 100-foot (30.48 m) radius around the injection well would be disturbed during 

installation. The injection well pad and the surrounding operations area would disturb less than 

one acre, on which there would be very little, if any, vegetation. Installation of the two 
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verification wells, four onsite groundwater monitoring wells, and up to 12 additional 

groundwater monitoring wells (outside of the project boundary) would disturb a very small area 

around each well, probably less than 0.5 acre (2023 m2

) total, on which there would be very 

little, if any, vegetation. Construction of the 3000-foot (914.4 m) pressurized pipeline would 

disturb ground for less than half its length as much of the pipeline follows paved surfaces, likely 

not more than 0.5 acre (2023 m2

) on which there would be very little, if any, vegetation. There 

could also be localized vegetation disturbance from foot traffic during installation, injection, and 

monitoring; however, this area would likely be minimal and limited to the areas immediately 

surrounding the equipment. 

Exotic plants or seeds could be brought to the site with fill material or on equipment. New 

introductions could allow for exotic plants to become established and spread, especially in areas 

where the ground is newly disturbed by construction activities. Exotic plants currently growing 

in the area can also become established and spread on newly disturbed substrates. However, 

mitigation to ensure that imported material does not contain exotic plant material would be 

implemented. 

As no critical habitats or federally listed plant species exist in the vicinity of the project area, 

there would be no impacts on threatened or endangered species. 

The unlikely event of leakage of injected CO2 to the surface could pose detrimental effects on 

vegetation near or at some distance from the project area. Although atmospheric CO2 promotes 

plant growth, increased concentrations in the soil could lead to root asphyxiation and plant death 

(International Energy Agency, 2007). Impacts of seepage on on-shore ecosystems could also 

include altered biological diversity and changes to the composition and numbers of species in the 

local environment. The range of effects on terrestrial ecosystems could extend to entire 

ecosystems and could be chronic, acute, or lethal depending on species affected and 

concentrations of CO2. However, aerial imaging of the injection site would monitor vegetative 

conditions to validate integrity of seal formation, injection well, and other potential migration 

pathways to the biosphere. Any irregularities, such as dieback, that are detected would trigger 

remediation measures. 

Any changes to native vegetation would be limited to a small area and would not affect the 

viability of the resources. Full recovery would occur in a reasonable time, considering the size 

of the project and the affected resource’s natural state. Therefore, impacts on terrestrial 

vegetation would not be expected to exceed the significance threshold. 

4.5.3 Effects of No-Action 

Under the No-Action alternative, the ADM Phase III Test Site work by the MGSC would not be 

implemented. No impacts to terrestrial vegetation would occur as a result of this alternative. 

4.5.4 Cumulative Effects 

Vegetation in the ADM Phase III Test Site has been previously cleared for ADM industrial 

development and agricultural practices. These activities have involved removal, trampling, or 
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destruction of vegetation and disturbance of ground cover. Any vegetation disturbance 

associated with the Proposed Action would occur in previously disturbed areas or areas devoid of 

any vegetation. It is also possible that an unlikely leakage of CO2 to the surface would have 

wider spread consequences on vegetation. Overall, cumulative impacts from the proposed 

project when added to other past, present, and reasonably foreseeable future actions would be 

minimally adverse and are not expected to exceed the threshold of significance. 

4.6 Wildlife 

4.6.1 Description 

Common mammals that occur in rural areas in the vicinity of Decatur, Illinois, include white-tail 

deer, groundhog, skunk, mink, red and gray fox, and river otter. Common birds include Canada 

goose, owls, hawks, turkey vulture, and mourning dove. Reptiles include snapping turtle, 

spotted turtle, timber rattlesnake, western fox snake, eastern milk snake, and bull snake. 

No critical habitat exists in the vicinity of the test site or in Macon County. One federally listed 

wildlife species, Indiana bat (Myotis sodalis) - endangered, and two Illinois state listed 

endangered species, upland sandpiper (Bartramia longicauda) and Bewick’s wren (Thryomanes 

bewickii), occur in Macon County (IDNR, 2008). Of these species, only the Bewick’s wren has 

been documented as occurring approximately one mile (1.61 km) south of the test site. A review 

of the U.S. Fish and Wildlife Service (USFWS) technical assistance website (USFWS, 2008b) on 

June 10, 2008, for federally listed threatened and endangered species resulted in a conclusion 

that the Proposed Action would have “no effect” on listed species, their habitats, or proposed or 

designated critical habitat. An official consultation request and a documentation memo are 

included in Appendix B. 

4.6.2 Effects of Proposed Action 

Activities for construction of the CO2 compression-dehydration facility, installation of wells and 

pipeline, vehicle traffic, lighting during night work, and human presence would cause temporary 

displacement and disturbance of resident wildlife for the two year duration of construction and 

installation and three year injection period. Species are expected to return to the area after 

construction and injection is completed, although there may still be some minimal disturbance 

during the additional two years of post injection monitoring (MMV would take place 

concurrently with the three year injection period). These impacts would be localized and limited 

to the immediate area of the project area. 

It is estimated that very minimal (less than one acre (4,047 m2

)) of wildlife habitat would be 

disturbed by installation of wells and pipeline. Approximately a 100-foot (30.48 m) radius 

around the injection well would be disturbed during installation. The injection well pad and the 

surrounding operations area would disturb less than one acre (4,047 m2

), on which there would 

be very little, if any, wildlife habitat. Installation of the two verification wells, four onsite 

groundwater monitoring wells, and up to 12 additional groundwater monitoring wells (outside of 

the project boundary) would disturb a very small area around each well, probably less than 0.5 

acre (2,023 m2

) total, on which there would be very little, if any, wildlife habitat. Construction 
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of the 3,000-foot (914.4 m) pressurized pipeline would disturb ground for less than half its length 

as much of the pipeline follows paved surfaces, likely not more than 0.5 acre (2,023 m2

) on 

which there would be very little, if any, wildlife habitat. 

As no critical habitats or federally listed animal species exist in the vicinity of the project area, 

there would be no impacts on threatened or endangered species. 

The unlikely event of leakage of injected CO2 to the surface could pose detrimental effects on 

wildlife near or at some distance from the project area. Effects of a leak would decrease in 

severity in a series of concentric rings, with those organisms closest to the leak suffering from 

acute or even lethal concentrations of CO2 (International Energy Agency, 2007). Changes in 

subsurface biogeochemical processes could lead to changes in soil pH with associated negative 

effects on microbial populations, leading to a change in nutrients present which would progress 

up the food chain. Changes in the quality of groundwater would have serious consequences on 

water resources. Both food chain and water resource impacts would likely have detrimental 

effects on animal health. Additionally, prolonged exposure to high CO2 concentrations may 

result in increased risk of asphyxiation for some wildlife (International Energy Agency, 2007). 

Any impacts on wildlife from the Proposed Action would be limited to a small portion of the 

population and would not affect the viability of the resource. Full recovery would occur in a 

reasonable time, considering the size of the project and the affected species’ natural state. 

Therefore, impacts on wildlife would not be expected to exceed the significance threshold. 

4.6.3 Effects of No-Action 

Under the No-Action alternative, the ADM Phase III Test Site work by the MGSC would not be 

implemented. No impacts to wildlife would occur as a result of this alternative. 

4.6.4 Cumulative Effects 

Wildlife and habitat in the project area have been, and continue to be, subject to disturbance and 

damage by ADM industrial development and activities, and agricultural practices. Habitat 

disturbance associated with new infrastructure as part of the Proposed Action would be limited, 

and wildlife displacement and disturbance would be temporary lasting only for the duration of 

the construction, injection, and monitoring period. It is also possible that an unlikely leakage of 

CO2 to the surface would have wider spread consequences on wildlife and habitat. Cumulative 

impacts from the proposed project when added to other past, present, and reasonably foreseeable 

future actions would be minimally adverse and are not expected to exceed the threshold of 

significance. 

4.7 Land Use 

4.7.1 Description 

The ADM Phase III Test Site would be located near Decatur, Illinois, within Macon County and 

entirely within the large Decatur ADM Complex that is owned and managed by ADM, one of the 
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consortium partners of the MGSC. ADM is one of the world’s largest processors of soybeans, 

corn, wheat, and cocoa. ADM is a leading manufacturer of biodiesel, ethanol, soybean oil and 

meal, corn sweeteners, flour, and other value-added food and feed ingredients (ADM, 2008a). 

The Decatur ADM complex consists of various processing facilities including a corn wet milling 

plant with ethanol production, which would be the source of CO2 for this project. Additional 

primary facilities include cogeneration, bio-products, oilseed processing, and vegetable oil 

refining. 

Nearby properties and/or land uses include Richland Community College; Caterpillar, Inc.; 

industry-related commercial businesses; and private farm (Figure 2.1.1-2). Macon County has a 

comprehensive plan under development that will establish existing and future land use plans, but 

these plans were not available for this analysis. 

Land utilized for the proposed CO2 compression-dehydration facility and much of the pipeline 

construction are visibly industrial in nature, which is in concert with their industrial designation 

as part of the Decatur ADM Complex. The injection well area and the remainder of the pipeline 

are would also be within the Decatur ADM Complex. The Decatur ADM Complex is a secured 

and fenced area that would also include the injection well area once this project commences. 

The Drummer silty clay loam (152), Flanagan silt loam (154A), Proctor silt loam (148B), Catlin 

silt loam (171B) and Dana silt loam (56B) have all been identified at the test site based on the 

Soil Survey of Macon County (Figure 4.2.1-2)(MGSC, 2008). All of these soils are considered 

characteristic of prime farmland. 

An alfalfa ground cover is planned for the vacant field where the injection well would be located 

beginning in the summer of 2008. 

4.7.2 Effects of Proposed Action 

The proposed project would slightly expand the visual and physical industrial character of the 

very large Decatur ADM Complex while remaining entirely within existing ADM property. The 

current Decatur ADM Complex developed property size is 300 acres (1,214,057 m2

) while the 

proposed project would be four acres (Carroll, 2008c). Current industrial land use designations 

would be unaffected by this project. Though the proposed injection well site is industrial 

property, there have been past uses there that were agricultural. With the exception of a 300 foot 

by 300 foot (91.44 m by 91.44 m) area for injection well surface improvements, the injection 

well area would be planted in alfalfa, retaining much of the agricultural appearance of this area 

of the project and minimizing any effects on identified prime farmland resources. 

New elevated pipelines required by the project are planned to follow existing elevated pipe 

corridors on Decatur ADM Complex property, except for the portion immediately preceding the 

injection well area, which would be placed underground. 

The compression-dehydration facility would be set among other heavy industrial uses featuring 

cooling towers and other plant facilities and equipment that are typical of this type of industrial 
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facility. The appearance and operation of this part of the project would be compatible with its 

immediately surrounding land uses. 

The compression and pipeline facility will be built fully within the Decatur ADM Complex and 

will be integrated with the control of ADM's processing facilities. ADM may, therefore, choose 

to continue operation of the compression-dehydration facility, pipeline, and injection well after 

the project is complete. That decision will be based on value of that operation with respect to 

greenhouse gas mitigation laws that may come into effect between now and 2014 at the 

conclusion of the project. Should requirements for emissions reductions applicable to companies 

like ADM be adopted, then ADM may continue operations consistent with permitting 

requirements for geological sequestration that may be in effect at that time and considering the 

relative value of the facility with respect to other options available to the company. 

Should ADM choose not to operate the facility, the disposition of the equipment will be made in 

accordance with regulatory requirements and project closeout options available to ADM and to 

DOE in view of DOE's role in supporting the ADM Phase III Test Site. Equipment that may be 

readily moved may be salvaged and other installed components, such a concrete foundation slabs 

and buried pipeline segments, may be put to other uses within the Decatur ADM Complex. The 

injection well would be plugged in accordance with the UIC permit issued at the time of its 

initial operation (Finley, 2008; ADM, 2008a). 

The effects of the Proposed Action are that land use impacts would be limited to a small area and 

would not noticeably alter any particular land use at the test site or in adjacent areas. The 

affected areas would fully recover in a reasonable time once the project is completed. Therefore, 

the impacts to land use from implementing the Proposed Action are not expected to exceed the 

significance threshold. 

4.7.3 Effects of No-Action 

Under the No-Action alternative, the ADM Phase III Test Site work by the MGSC would not be 

implemented. No impacts to land use would occur as a result of this alternative. 

4.7.4 Cumulative Effects 

No additional land use development is currently planned in the vicinity of the project outside of 

Decatur ADM Complex property (Carroll, 2008b; Chamber, 2008; Decatur, 2008b). ADM has 

no major development planned beyond routine expansion of current plant facilities (Carroll, 

2008b). This project would expand industrial development in a predominately industrial land 

use area, so cumulative impacts would be negligible with regard to most unplanned development 

that may occur in this area and should be considered compatible with the current industrial 

character of the project area. 

4.8 Socioeconomic Resources 

The socioeconomic assessment considers those elements of the human social environment that 

may be sensitive to changes resulting from implementation of the Proposed Action. Specifically, 
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the assessment is concerned with how the Proposed Action would affect people, institutions, 

communities, and the local economy, as well as larger infrastructure, social, and economic 

systems. This section describes the socioeconomic conditions that may be affected by 

implementation of Proposed Action and addresses the potential impact that may result from 

actions undertaken as a part of the Proposed Action. 

4.8.1 Population 

4.8.1.1 Description 

The project area would be located on the east side of the metropolitan area of Decatur, Illinois, 

and is entirely contained by the existing ADM industrial complex. Within the corporate limits of 

the City of Decatur, the project area would be surrounded by a mixture of industrial and 

agricultural land with some residential and commercial properties located in the area, but 

substantially removed from the site proper. With a 2006 estimated population of 77,047 

residents (Census, 2007a), Decatur is the county seat and also the largest city in Macon County. 

The city is part of the larger Decatur Metropolitan Statistical Area, which had an estimated 

population of 109,061 in 2007 (Census, 2008). Incorporated communities within a 15 mile 

(24.14 km) radius of Decatur include: Argenta – population 841, Forsyth - population 2,871, 

Harristown - population 1,252, Long Creek - population 1,317, Macon - population 1,146, 

Mount Zion - population 5,061, Oreana - population 941, and Warrensburg - population 1,193 

(Census, 2007a) Block data (Census, 2000a) for the area immediately surrounding the test site 

indicate a total of 51 residents living in 19 housing units, with an occupancy rate of 100 percent. 

Despite the predominately urban character of the Decatur region, 46.3 percent, or nine of the 

residential units in the areas neighboring the test site are classified by the U.S. Census as rural. 

The estimated population for the city of Decatur shows a 5.9 percent decline from the 2000 

population of 81,860, continuing a trend from the previous decade in which the city declined 

from its 1990 population of 83,885 (Census, No date). In 2000, Decatur supported a total of 

37,239 housing units with a median value of $63,200. The occupancy rate for all units in the city 

was 91.5 percent. The average population density for the metropolitan area of Decatur is 1,923 

persons per square mile (2,589,988 m2

), with a housing density of 855.1 units per square mile 

(2,589,988 m2

) (Census, 2000b). The median age of Decatur residents, 37.2 years, is slightly 

lower than that for the surrounding county, 39.3 years. Approximately 76.0 percent of the 

population is 18 years or older, with 6.7 percent under the age of five and 16.4 percent aged 65 

and over (Census, 2000a). 

The estimated population of Macon County in 2006 was 109,309 residents; a slight decrease 

from the 2000 total of 114,706 (Census, 2007b). In 2000, there were a total of 51,738 housing 

units in the county, with an occupancy rate of 90.3 percent and an average density of 86.5 units 

per square mile (2,589,988 m2

). Population density for this year was 86.5 persons per square 

mile (2,589,988 m2) (Census, 2000b). Residents aged 18 years and older represented 75.4 

percent of the total population. Children five years of age and younger account for 6.4 percent of 

the county’s population and persons 65 years of age and older make up 15.2 percent (Census, 

2000a). 
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4.8.1.2 Effects of Proposed Action 

Implementation of the Proposed Action would have only a minor, if not negligible, effect on the 

size and demographic characteristics of the local population. No additional, permanent full-time 

employment would be generated as a result of this alternative. Any increased labor requirement 

would be temporary and limited to the construction of the well, pipeline, and compressor 

facilities. Estimates for the additional workforce required at the site range from 9 to 39 

personnel, depending on the particular stage of the process (Schlumberger, 2008b). This 

temporary increase would be easily accommodated by existing local resources. 

The Proposed Action would be in keeping with the industrial character existing in the project 

area and would not introduce any new or incompatible uses. The proposed well, compressiondehydration plant, and the associated pipeline would be located entirely within the existing 

Decatur ADM Complex boundaries. No additional land outside the existing footprint would be 

needed. As a result, no substantial impact would be associated with the potential to change the 

community character and setting, demographic composition, or housing availability beyond that 

already existing under ADM’s current operation. Therefore, the impacts from implementing the 

Proposed Action are expected to be below the significance threshold. 

4.8.1.3 Effects of No-Action 

Continuation of the No-Action alternative would mean that DOE funds would not be used to 

support the proposed drilling, construction, and monitoring and data collection activities on the 

test site. Correspondingly, no change would occur in the existing condition, and the current 

management of the site would continue. No changes to local demographic composition or 

community setting and character would be anticipated under this alternative. Any future changes 

in the use or infrastructure of the site would be dependent on ADM short and longer-term 

corporate planning and any specific future use determinations for the test site that may derive 

from that process. Therefore, the impacts from implementing the No-Action alternative are 

expected to be below the significance threshold. 

4.8.1.4 Cumulative Impacts 

As noted under the Proposed Action, the introduction of the Proposed Action would not be 

expected to account for any noticeable changes in the size or demographic characteristics of the 

local population and would not contribute to any substantial changes in local community 

character and setting. When considered in combination with ADM’s current and proposed 

management of the existing site and the future site condition, the cumulative effects would be 

expected to be minor and are not expected to exceed the threshold of significance. 

4.8.2 Employment and Income 

4.8.2.1 Description 

The local economy of the City of Decatur is characterized by a combination of heavy and light 

industries along with large-scale agricultural production and services. Farming and farm-related 
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occupations continue to be a major source of employment in the Macon County area. Per capita 

personal income for the city of Decatur in 2006 was $19,761. Employment statistics for the year 

indicate that the city supported a total civilian labor force of 36,551 workers, with an 

unemployment rate of 6.8 percent or 2,489 workers. The largest occupational categories 

included: management, professional, and related occupations, with 10,843 workers, or 31.8 

percent of the workforce; sales and office occupations, with 7,954 workers or 23.4 percent of the 

workforce; and service occupations with 7,107 workers, or 20.9 percent of the total. Median 

household income in 2006 was $34,877 (Census, 2006a). 

The leading employment sectors for Macon County in 2006 were manufacturing, with 24.46 

percent of total employment; health care and social assistance, with 15.05 percent; and retail 

trade, with 12.75 percent of the total (BLS, 2006). Employment statistics for March 2008 

indicate that the county supported a total labor force of 55,183 workers, with an unemployment 

rate of 6.1 percent, or 3,356 workers. This represents an increase of 0.3 percent from the 2007 

annual average unemployment (BLS, 2008). The per capita personal income of $34,133 for that 

year was 89 percent of the state average, $38,409. Total personal income for the county was 

$3.7 billion (BEA, 2006). Median household income for 2006 was $41,009 (Census, 2006b). A 

summary of income distribution by household is presented in Table 4.8.2.1. 

Table 4.8.2.1. Household Income for 2006 

Number Percent 

Less than $10,000 4,859 10.39 

$10,000 to $14,999 3,710 7.93 

$15,000 to $24,999 5,739 12.27 

$25,000 to $34,999 6,179 13.21 

$35,000 to $49,999 6,473 13.84 

$50,000 to $74,999 8,321 17.79 

$75,000 to $99,999 5,782 12.37 

$100,000 to $149,999 4,040 8.64 

$150,000 to $199,999 890 1.90 

$200,000 or more 768 1.64 

Total Households 46,761 100 

 Source: (Census, 2006b). 

4.8.2.2 Effects of Proposed Action 

Implementation of the Proposed Action would be expected to have only minimal effect on the 

local economy, labor conditions, and the availability of production or consumer resources in the 

surrounding community. Permanent, longer term labor requirements for operation, monitoring, 

and maintenance of the proposed facility would not be expected to be substantial and could 

easily be accommodated by ADM’s existing labor force. 

Labor requirements for the construction of the well, pipeline, and compressor facilities would be 

temporary and of short duration. Workforce estimates for the well drilling operations include 

from 24 to 39 personnel working 24 hours per day seven days per week for from four to seven 
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days during initial set up of the drill rig. After drilling begins, the rig-based workforce would 

decline to approximately 9 to 18 personnel. At peak times, such as during logging or cementing 

operations, this number could potentially double (Schlumberger, 2008b). These requirements 

represent skill areas that could be accommodated by ADM’s existing workforce or from the 

larger Decatur and Macon County workforce without major impact or stress to existing labor 

availability in the area. As a result, no change in regional employment would be anticipated. 

The planning, construction, operation, monitoring, and post injection activities proposed under 

Proposed Action would result in a total project spending of $84,274,927, including $66,730,912 

in federal funds. The local economy of the City of Decatur and surrounding Macon County is 

sufficient to capture much of this additional spending. This represents a potential beneficial 

impact to the local economy in the form of wages and salaries paid to local workers and income 

to local commercial entities providing goods and services. Assuming that all expenditures were 

captured by the local economy, the Proposed Action spending over three years would be equal to 

approximately 2.4 percent of the annual total income for Macon County. However, it is likely 

that at least a portion of project expenditures might be spent outside the local economy for labor 

goods or services not locally available, so that the actual benefit would probably be somewhat 

less. 

Resource requirements for the project would not be expected to result in substantial changes in 

the provision of infrastructure and other services to local residents. The compressiondehydration facility is estimated to require an increased electrical demand of 5 to 6 MW over the 

three-year injection period. Since the ADM plant produces its own electricity, this increase 

would not impact industrial or residential users in the local area. Similarly, water and 

wastewater treatment requirements would not have a local impact. The proposed requirement for 

220 barrels (9,240 gallons or approximately 35 kiloliters) of water is within existing capacity, 

and wastewater would be directed to the wastewater treatment facility or the water-reuse system 

that currently exists for the Decatur ADM Complex. No additional impact on supply or rate 

structure would be anticipated for local users in the surrounding community. Therefore, the 

impacts from implementing the Proposed Action are expected to be below the significance 

threshold. 

4.8.2.3 Effects of No-Action 

In the absence of federal funding, the Proposed Action would likely not proceed. ADM’s current 

management and operations at the test site would be expected to continue unchanged. As a 

result, no change would be expected to occur in the existing condition or uses of the test site. 

Current trends in employment, production, and commercial activity would be expected to 

continue in their present pattern with no additional direct or indirect impact to the local economy. 

Therefore, the impacts from implementing the No-Action alternative are expected to be below 

the significance threshold. 

4.8.2.4 Cumulative Impacts 

The introduction of the Proposed Action to other planned or reasonably foreseeable actions at the 

study site or in the surrounding area would be expected to have only a minor effect on the local 
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economy. As noted under the Proposed Action, the project would have minimal or no adverse 

impact on local employment or the availability and cost of local resources and services in the 

Decatur or larger Macon County economy. Therefore, it would not be expected to contribute to 

any cumulative effect. Some potential benefit would be derived from the small, but potential 

additional labor requirement and from additional expenditures in the local economy associated 

with the Proposed Action. These benefits could be experienced without adverse consequences 

and would not alter the existing condition or contribute substantially to the cumulative effect.

4.8.3 Infrastructure 

Characterization of the current transportation and other infrastructural elements of the project 

area focuses on the ability of these elements to serve existing demand as well as any increase that 

may result from implementation of the Proposed Action. 

4.8.3.1 Description 

The ADM Phase III Test Site would be located in an industrial area adjacent to the urbanized 

area of Decatur. The road system in the surrounding region is a combination of intra-urban and 

rural roads. To the north, the test site is bounded by Reas Bridge Road (Rd.) (Illinois (IL)- 24). 

North Brush College Rd. (IL-1) forms the western boundary of the test site. To the east and 

somewhat removed from the test site boundary, Gun Club Road joins Christmas Tree Road to 

intersect with Reas Bridge road approximately one-half mile (805 m) from the northeastern 

corner of the test site. To the south, the Decatur ADM Complex supports a network of service 

roads of varying capacity. 

Traffic volume studies for the segment of North College Brush Road running north from the 

intersection at Faries Parkway indicate an average daily volume of 11,300 vehicles, increasing to 

20,700 vehicles by 2025 (Blank et al., 2004). The current daily truck traffic into and out of the 

Decatur ADM Complex is estimated at approximately 1,750 trips (Litynski, 2008a). 

There are no utility transmission lines within the boundaries of the project area, apart from those 

servicing ADM facilities. A pipeline right-of way crosses the southeastern corner of the test site 

and continues south along the site border to the Decatur ADM Complex. A freight rail line of 

the Illinois Central Railroad crosses east to west in the area between the compressiondehydration facility and the injection well. A spur connects this line to the Decatur ADM 

Complex. 

4.8.3.2 Effects of Proposed Action 

The Proposed Action would not substantially alter existing traffic patterns, level of congestion, 

or road conditions in the immediate and surrounding area of the project area. Temporary 

increases in traffic resulting from the proposed action are presented in Table 4.8.3.2 below. 
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Table 4.8.3.2. Well Construction Transport Estimate 

Description of Transport Number* Type of vehicle 

Movement of rig & components to site 39-56 loads flatbeds 

Normal delivery of mud chemicals, bits, 4 flatbed 

Visits by ADM, Illinois State Geological 

Survey (ISGS), etc. 10 cars/trucks 

Cementing trucks 4 pump trucks & cement bins 

Logging trucks & tools 2 logging trucks w/tools 

Drill pipe, jars, drill collars, etc. 3 flat beds 

20 inch casing 3 flat beds 

13 3/8 inch casing 7-9 flat beds 

9 5/8 inch casing 11-13 flat beds 

Crew changes, daily for rig personnel 3 cars or vans 

Vacuum trucks, waste disposal trucks, etc. 2 vacuum trucks 

Casing running, lay down machines 5 2 Short Ton + 4 flatbeds 

Other miscellaneous trucks, vehicles 4 F150's, cars, vans 

 

* Number of vehicles per week or number of loads 

Note: Traffic will peak during set-up, mobilization & demobilization, cementing & 

logging runs as well as when running pipe

Adapted from: (Schlumberger, 2008c). 

Any temporary increases in traffic during the construction phase would not be sufficient to cause 

a substantial change in conditions during these periods. No activities occurring at the test site 

would be likely to disturb power or other utility transmission lines in the area. Therefore, the 

impacts from implementing the Proposed Action are expected to be below the significance 

threshold. 

4.8.3.3 Effects of No-Action 

Operations at the existing Decatur ADM Complex are ongoing. In the event that the Proposed 

Action is not implemented, any subsequent effect on traffic flow and patterns would be 

considered part of the current traffic conditions in the area. No additional impact would be 

anticipated. There are no public utilities at the site which might be disturbed either under current 

conditions. Therefore, the impacts from implementing the No-Action alternative are expected to 

be below the significance threshold. 

4.8.3.4 Cumulative Impacts 

Cumulative impacts would not be anticipated in association with the Proposed Action. There are 

no planned or reasonably foreseeable actions for the project area which when added to the effect 

of the Proposed Action would substantially change local road use or traffic patterns. There 

would be limited potential to alter or disturb power or other infrastructure services to the area as 
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a result of the Proposed Action, but these potential impacts are not expected to exceed the 

threshold of significance. 

4.8.4 Parks and Recreation 

4.8.4.1 Description 

Major facilities in the surrounding area include: 

• Faries Park – a 7 acre (28,328 m2) picnic and recreational area located approximately 1.8 

miles (2.9 km) from the test site to the southeast (Moore, 2008; Carroll, 2008d; Litynski, 

2008b). 

• Nelson Golf Course and Park – a 45 acre (182,109 m2) facility with picnic playground 

and sports facilities, located approximately three miles (4.83 km) to the southeast of the 

test site; 

• Lions Park – a 2.5 acre (10,117 m2) site that serves as a neighborhood park with picnic 

and court facilities, located approximately two miles (3.22 km) to the northwest of the 

test site; and 

• Chandler Park – a 17.5 acre (70,820 m2) lakefront park with picnic facilities, located 

approximately 2 miles (3 km) to the southwest of the test site (Decatur Park District, No 

date). 

4.8.4.2 Effects of Proposed Action 

The addition of the well, pipeline, and compression-dehydration facility to the existing Decatur 

ADM Complex would generate negligible impact to recreational activities in the immediately 

surrounding area. No facilities exist in the immediate vicinity of the test site that might be 

disturbed by site activities. The Proposed Action would be in keeping with the existing 

industrial character of test site and does not alter the existing setting or interfere with the user 

experience of more remotely located facilities. Therefore, the impacts from implementing the 

Proposed Action are expected to be below the significance threshold. 

4.8.4.3 Effects of No-Action 

Parks and recreational opportunities both nearby and in the larger Decatur area have historically 

existed along with ADM operations at the Decatur ADM Complex. No additional impact would 

be anticipated from continuing management practices or site activities. Therefore, the impacts 

from implementing the No-Action alternative are expected to be below the significance 

threshold. 

4.8.4.4 Cumulative Impacts 

The addition of the Proposed Action to ongoing activities at the Decatur ADM Complex would 

have no substantial impact to the character, setting, or visitor experience associated with parks or 

other recreational opportunities in the immediately surrounding and larger Decatur communities.
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4.8.5 Visual Resources 

4.8.5.1 Description 

There are no scenic vistas or aesthetic landscapes in the vicinity of the Proposed Action. The test 

site would be on the east side of Decatur, Illinois, and within the Decatur ADM Complex. The 

compression-dehydration facility would be located within the industrial complex to the south of 

the proposed injection well site. The pipeline would travel from the compression-dehydration 

facility to the injection well following, as much as possible, an existing pipeline alley and 

overhead catwalk to allow the pipeline to cross the railroad track. 

4.8.5.2 Effects of Proposed Action 

Under the Proposed Action, construction of a CO2 compression-dehydration facility (which is 

outside of the ADM Phase III Test Site but on ADM property), one injection well, monitoring 

wells, and pipeline would minimally alter the visual elements of the project area much of which 

is currently a fallow agricultural field. However, facilities constructed under the Proposed 

Action would not contrast with the present landscape as industrial features are common in the 

vicinity of the test site. 

The unlikely event of leakage of injected CO2 to the surface could pose detrimental effects on 

terrestrial ecosystems, having impacts on visual resources if areas of vegetation are altered. 

Changes in species composition, frequency and density of plants, or vegetation dieback could 

alter visual elements in the landscape and viewsheds. 

Overall, it is not likely that the Proposed Action would change the visual landscape in a way that 

would be objectionable to local residents or frequent visitors. Thus, impacts on visual resources 

would not be expected to exceed the significance threshold. 

4.8.5.3 Effects of No-Action 

Under the No-Action alternative, the ADM Phase III Test Site work by the MGSC would not be 

implemented. No impacts to visual resources would occur as a result of this alternative. 

4.8.5.4 Cumulative Impacts 

Visual quality at the test site has been predominantly altered by the past ADM industrial 

development. Agriculture, residential, and other ongoing industrial activities have also affected 

the visual quality of the surrounding area. Given the larger impacts to visual resources from 

past, present, and future activities, cumulative impacts added from the proposed project would be 

minimally adverse and are not expected to exceed the threshold of significance. 

4.8.6 Noise 

Noise is defined as any sound that is undesirable because it interferes with communication, is 

intense enough to damage hearing, or is otherwise intrusive. Human response to noise varies 
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depending on the type and characteristics of the noise, distance between the noise source and the 

receptor, receptor sensitivity, and time of day. Noise is often generated by activities part of 

everyday life, such as construction or vehicular traffic. 

Sound varies by both intensity and frequency. Sound pressure level, measured in decibels (dB), 

is used to quantify sound intensity. The dB is a logarithmic unit that expresses the ratio of a 

sound pressure level to a standard reference level. Hertz (Hz) are used to quantify sound 

frequency. The human ear responds differently to different frequencies. A-weighting, described 

in a-weighted decibels (dBA), approximates this frequency response to express accurately the 

perception of sound by humans. Sounds encountered in daily life and their approximate level in 

dBA are provided in Table 4.8.6-1. 

Table 4.8.6-1. Common Sounds and Their Levels 

Outdoor 

Sound level 

(dBA) Indoor 

Snowmobile 100 Subway train 

Tractor 90 Garbage disposal 

Noisy restaurant 85 Blender 

Downtown (large city) 80 Ringing telephone 

Freeway traffic 70 TV audio 

Normal conversation 60 Sewing machine 

Rainfall 50 Refrigerator 

Quiet residential area 40 Library 

 Source: (Harris, 1998). 

The dBA noise metric describes steady noise levels. However, very few noises are, in fact, 

constant; therefore, a noise metric, Day-night Sound Level (DNL) has been developed. DNL is 

defined as the average sound energy in a 24-hour period with a 10-dB penalty added to the 

nighttime levels (10 P.M. to 7 A.M.). DNL is a useful descriptor for noise because it averages 

ongoing yet intermittent noise, and it measures total sound energy over a 24-hour period. In 

addition, Equivalent Sound Level (Leq) is often used to describe the overall noise environment. 

Leq is the average sound level in dB. 

The Noise Control Act of 1972 (Public Law 92-574) directs Federal agencies to comply with 

applicable federal, state, interstate, and local noise control regulations. In 1974, the USEPA 

provided information suggesting that continuous and long-term noise levels in excess of DNL 65 

dBA are normally unacceptable for noise-sensitive land uses such as residences, schools, 

churches, and hospitals. 

The State of Illinois’s Environmental Protection Act of 1985 limits noise to levels that protect 

the health, general welfare, and property. The State of Illinois limits the noises in individual 

frequency ranges at noise sensitive land uses (Table 4.8.6-2) (35 IAC H.901.101) (IL, 2008). 

There are no maximum overall levels outlined in the regulation. In addition, Decatur has a local 

noise regulation as part of the zoning code that states it is unlawful to generate sound louder than 

80 dBA at the property line (Decatur Zoning Code Section XVII Subpart D) (Decatur, 2008c). 
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Sounds generated from construction activities are exempt from both the state and local 

regulations. 

Table 4.8.6-2. State of Illinois Environmental Noise Standards 

Allowable Octave Band Sound Pressure Levels (dB) of 

Octave Band Sound Emitted to Noise Sensitive Land Uses 

Center Frequency 

(Hz) 

Industrial 

Source 

Commercial 

Source 

Residential 

Source 

31.5 75 72 72 

63 74 71 71 

125 69 65 65 

250 64 57 57 

500 58 51 51 

1000 52 45 45 

2000 47 39 39 

4000 43 34 34 

8000 40 32 32 

Sources: (IL, 2008; Decatur, 2008c). 

4.8.6.1 Description 

The Decatur ADM Complex and adjacent areas are primarily mixed use industrial and 

recreational with Faries Park recreational complex to the east, and a community college to the 

north, and a rail station to the south of the project area. The nearest noise sensitive area (NSA) is 

a community college north of the Decatur ADM Complex. Existing sources of noise at NSAs 

near the Decatur ADM Complex, compressor location, and drilling site include rail traffic 

traveling east of the Wabash Rail Station, local road traffic, high-altitude aircraft overflights, and 

natural noises such as leaves rustling, and bird vocalizations. It is also possible that industrial 

noise contributes to overall noise environment outside of the facilities property boundary. For 

analysis purposes, the NSAs surrounding the facility have been categorized as quiet suburban 

residential areas. This would constitute the worst case existing noise conditions. The noise 

environment consists of light traffic conditions where no mass transportation vehicles and 

relatively few automobiles and trucks pass. The background sound either is distant traffic or is 

difficult to identify by residents.

Table 4.8.6.1. Estimated Existing Noise Levels at Nearby Noise Sensitive Areas 

 

Closest 

Noise Sensitive Area (NSA) 

Estimated Existing 

Sound Levels (dBA) 

Site Distance Direction Type 

Land Use 

Category DNL 

Leq 

(Daytime) 

Leq 

(Nighttime)

Drilling Site 

1,800 feet 

549 m North School 

Compressor 

Site 

4,100 feet 

1,250 m North School 

Quiet 

Suburban 

Residential

55 53 47 

Source: (ANSI, 2003). 
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4.8.6.2 Effects of Proposed Action 

Short-term and long-term minor adverse effects to the noise environment would be expected 

with the implementation of the Proposed Action. The effects would be primarily due to heavy 

equipment noise during construction and drilling, and the operation of the proposed compressor. 

This evaluation considers significant sound sources that could affect NSAs. 

Construction Noise. There would be some form of moderate to heavy construction at the 

Decatur ADM Complex and the well locations. Individual pieces of construction equipment 

typically generate noise levels of 80 to 90 dBA at a distance of 50 feet (15.24 m). Table 4.8.6.2-

1 presents typical noise levels (dBA at 50 feet (15.24 m)) that USEPA has estimated for the main 

phases of outdoor construction. 

Table 4.8.6.2-1. Noise Levels Associated with Outdoor Construction 

Construction Phase 

Leq (dBA) at 50 feet (15.24 

m) from Source 

Ground Clearing 84 

Excavation, Grading 89 

Foundations 78 

Structural 85 

Finishing 89 

 Source: (USEPA, 1974). 

With multiple items of equipment operating concurrently, noise levels can be relatively high 

during daytime periods at locations within several hundred feet of an active construction sites. 

The zone of relatively high construction noise levels typically extends to distances of 400 to 800 

feet (121.92 to 243.84 m) from the site of major equipment operations. Locations within 1,000 

feet (304.8 m) would experience substantial levels (greater than 62 dBA) of construction noise. 

However, there are no NSAs within 1,000 feet (304.8 m) of the construction sites. Therefore, 

affects due to construction noise would be considered minor. Construction activities are exempt 

from both the state and local regulations. 

These effects would be temporary and would be considered minor. The following best 

management practices (BMPs) would be used to reduce these already limited effects: 

• Construction would predominately occur during normal weekday business hours in areas 

adjacent to noise-sensitive land uses such as residential areas; and 

• Construction equipment mufflers would be properly maintained and in good working 

order. 

Drilling Noise. The Proposed Action would involve drilling operations for the injection and 

monitoring wells. Components of the drilling equipment include the drill rig, mud pumps, and 

diesel generators. Drilling equipment is expected to operate twenty-four hours per day, seven 

days per week, for up to three months. The nearest NSA is 1,800 feet (549 m) north of the 

injection well location. A DNL of 54 dBA and a Leq of 48 dBA were estimated for the drilling 

operations at the nearest NSA. These levels are below the USEPA threshold of 65 dBA (DNL), 
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are temporary, and would have only a minor effect on the noise environment. Detailed noise 

calculations are located in Appendix C. 

The generator and combined diesel driven systems would have the standard exhaust muffles. 

Barriers can be installed around the noisy components to diminish the noise but would not likely 

be necessary given the distance to the nearest NSA. Drilling noise would be expected to 

dominate the soundscape for all on-site personnel. Personnel, and particularly equipment 

operators, would utilize adequate personal hearing protection to limit exposure and ensure 

compliance with federal health and safety regulations. 

Operational Noise. The compressor facility is in the preliminary design stages. Therefore, a 

complete equipment list and associated manufacturers specifications is not finalized. However, 

the only major noise-producing equipment expected is a 6000 horsepower (hp) [4474 kilowatt 

(kW)] reciprocating compressor. This compressor would operate 24 hours per day 7 days per 

week. Noise levels that would be generated by operation of the compressor at the nearest NSA 

have been compared to the levels outlined in the state and local noise regulation (Table 4.8.6.2-

2). 

Table 4.8.6.2-2. Compressor Noise Levels at Nearest NSA Compared to 

Noise Standards 

Octave Band Center 

Frequency (Hz) 

Allowable Sound 

Pressure Levels (dB) 

Predicted 

Compressor 

Noise Levels 

Exceeds 

Standard 

(Yes/No) 

31.5 75 55 No 

63 74 52 No 

125 69 51 No 

250 64 47 No 

500 58 44 No 

1000 52 44 No 

2000 47 40 No 

4000 43 27 No 

8000 40 9 No 

Leq (dBA) 80 48 No 

 Sources: (IL, 2008; Decatur, 2008c). 

Because of the limited amount of noise and the distance to the nearest NSA, violations of neither 

the state nor the local noise regulations are expected. Special variances to the state or local noise 

ordinance, mitigation measures, or both would not likely be required. Overall, these effects 

would be considered minor. Therefore, the impacts from implementing the Proposed Action are 

expected to be below the significance threshold. 

4.8.6.3 Effects of No-Action 

The No-Action alternative would have no impacts to noise because no drilling would occur, and 

no additional equipment would be installed. Noise levels would remain at their existing levels. 
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4.8.6.4 Cumulative Impacts 

The Proposed Action would introduce long-term incremental increases the noise environment. 

However, these increases would be relatively small when compared to the existing conditions 

and would be considered minor. 

4.8.7 Environmental Justice 

Executive Order 12898, “Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations” (The White House, February 11, 1994), requires that 

Federal agencies consider as a part of their action any disproportionately high and adverse 

human health or environmental effects to minority and low income populations. Agencies are 

required to ensure that these potential effects are identified and addressed. 

The USEPA defines environmental justice as “the fair treatment and meaningful involvement of 

all people regardless of race, color, national origin, or income with respect to the development, 

implementation, and enforcement of environmental laws, regulations, and policies.” For 

purposes of assessing environmental justice under NEPA, the CEQ defines a minority population 

as one in which the percentage of minorities exceeds 50 percent or is substantially higher than 

the percentage of minorities in the general population or other appropriate unit of geographic 

analysis (CEQ, 1997). 

Consideration of the potential consequences of the Proposed Action for environmental justice 

requires three main components: 

• A demographic assessment of the affected community to identify the presence of 

minority or low income populations that may be potentially affected; 

• An assessment of all potential impacts identified to determine if any result in significant 

adverse impact to the affected environment; and 

• An integrated assessment to determine whether any disproportionately high and adverse 

impacts exist for minority and low-income groups present in the study area. 

4.8.7.1 Description 

For the environmental justice analysis, the immediate site vicinity is defined as those census 

blocks that contain a portion of the project area or immediately adjacent to the project area. In 

2000, minority populations accounted for 17.5 percent of the total population of immediate site 

vicinity or a total of 9 residents (Census, 2000a). This is substantially lower than the minority 

percentage for the population of the City of Decatur as a whole. In 2000, minority population 

accounted for 22.3 percent of the city’s total population or 18,331 individuals. Hispanic or 

Latino populations (of any race) represented 1.2 percent of the total, or 978 individuals. 

Socioeconomically disadvantaged individuals, those living at or below the poverty line, 

constituted 16.5 percent of the population or 12,999 individuals in 2000 (Census, 2006c). 

Minority populations made up approximately 15.2 percent of the total population of Macon 

County. Hispanic or Latino residents (of any race) constitute approximately one percent of the 
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total population or 1,120 individuals. In 2000, there were 14,316 individuals living at or below 

the poverty level, or 12.9 percent of the population (Census, 2006c). 

4.8.7.2 Effects of Proposed Action 

Minority and lower income groups are generally not present in the study area in significantly 

greater proportions than for the Decatur community as a whole and the larger Macon County 

area. Additionally, both direct and indirect effects to local populations, resources, and the 

character and setting of the local community would be anticipated to be minimal for all 

populations in the immediate study area and for the surrounding communities. Therefore, no 

disproportionately high or adverse impacts to minority or low-income communities would be 

expected. 

4.8.7.3 Effects of No-Action 

The present management of the test site by ADM would be expected to continue with no 

appreciable change to the existing activities at the Decatur ADM Complex. No disproportionate 

impact to minorities or low-income populations would be anticipated under the No-Action 

alternative. 

4.8.7.4 Cumulative Impacts 

The Proposed Action considered by this EA would add only minimally to existing conditions in 

the project area and surrounding communities. As a result, any incremental impact would not be 

expected to be sufficient to exceed the significance threshold and would most likely be 

experienced evenly across all populations. 

4.9 Human Health and Safety 

4.9.1 Description 

Air pollution causes human health problems. Air pollution can cause breathing problems; throat 

and eye irritation; cancer; birth defects; and damage to immune, neurological, reproductive, and 

respiratory systems (USEPA, 2007c). National and state ambient air quality standards represent 

the maximum allowable atmospheric concentrations that may occur and still protect public health 

and welfare with a reasonable margin of safety (See Section 4.1). In addition, OSHA regulations 

specify appropriate protective measures for all employees. 

Spills from the construction of the Proposed Action and its operation could also a source of 

possible impacts to human health and safety. Spills can introduce soil contamination and allow 

exposure pathways to workers and the public. The risks and effects of a spill depend on its 

composition. A common material used in construction and operation that can be spilled is 

gasoline. Gasoline irritates the lungs and is a skin irritant. Enough gasoline exposure can cause 

death or nervous system damage (ATSDR, 2007). Similarly, waste management also is a source 

of possible human health and safety risks from exposure to contaminants (See Section 4.11). 
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A primary concern to human health and safety within the project area would be CO2 leaks. CO2

is heavier than ambient air, colorless, and odorless, which makes it an invisible hazard (DOE, 

2007a). Since it is denser than ambient air, leaked CO2 will typically pool in hollows and 

confined spaces until dispersed by wind or other ventilation methods (DOE, 2007a; IPCC, 2005). 

CO2 under pressure or at high concentration levels can cause suffocation and permanent brain 

injury from lack of air (DOE, 2007a). Headache, impaired vision, labored breathing, and mental 

confusion also can occur from exposure to CO2. The pressure drop from CO2 leaks from vessels 

(pipes) creates a cold hazard, and even the vapor can cause frostbite (IPCC, 2005). Generally, 

the pooling and large, rapid releases of the CO2 are the situations of concern for human health 

and safety instead of small gradual leaks due to concentration level differences (IPCC, 2005; 

DOE, 2007a). 

No general CO2 exposure standards exist yet for the general public (DOE, 2007a). The 

immediately dangerous to life and health level of exposure for CO2 is 5% or 40,000 ppm. For up 

to several hours, exposure to 0.5 to 1.5% CO2 in the air typically is not harmful for people with 

normal health. However, people with impaired health (such as cerebral disease), children, and 

people involved in complex tasks are more susceptible to the effects of CO2 exposure. CO2

exposure impedes people’s performance of complex tasks by causing labored breathing, 

headache, and mental confusion. The occupational standard of maximum allowable 

concentration of CO2 in air for eight hours of continuous exposure is 0.5%, and for a short 

period, it is 3.0% (IPCC, 2005). 

CO2 once leaked can cause human health issues in the water as well as air. CO2 underground 

injection can contaminate groundwater if the CO2 migrates to underground aquifers (See Section 

4.3). This contamination can occur by the CO2 causing the mobilization of chemicals such as 

metals in the soil into the aquifers. Despite monitoring and permitting requirements (USEPA’s 

UIC program), the risk to human health from potable water contamination still exists from 

underground injection. Similar to air emissions of CO2, gradual releases of CO2 into water 

sources typically do not cause substantial harm to human health, but rapid releases could (DOE, 

2007a). 

Between 1994 and 2006, there were 31 CO2 pipeline accidents reported, but there were no 

injuries or fatalities from these incidents in the United States (DOE, 2007c). Some historical 

causes of CO2 pipeline incidences are relief valve failure (4 failures), weld/gasket/valve packing 

failure (3 failures), corrosion (2 failures), and outside force (1 failure). The incident rate from 

1990 to 2002 for CO2 pipelines in the United States was 0.0002 mile-1 yr-1 (0.00032 km-1 yr-1) 

(IPCC, 2005). This rate of failure is comparatively small. For comparison with natural gas 

pipelines, see Table 4.9.1. 

Table 4.9.1. Comparison of Natural Gas Pipelines to CO2 Pipelines from 1995 to 2005 

Category Natural Gas CO2

Miles (km) of Pipeline 304,001 (489,242) (in 2003) 3,300 (5,311) 

Number of Incidents 960 12 

Property Damage per Incident $484,000 $42,000 

Injuries from Incidents 82 0 
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Table 4.9.1. Comparison of Natural Gas Pipelines to CO2 Pipelines from 1995 to 2005 

Category Natural Gas CO2

Fatalities 29 0 

 Source: (DOE, 2007a). 

The workers on the project would be subject to the same types of health risks that are generally 

associated with their professions (DOE, 2007a). There is a rate of 15.2 deaths per 100,000 for 

construction workers, which is the third highest rate of death from injury (NIOSH, No date). 

The construction incident rate of total recordable cases of nonfatal occupational injuries and 

illnesses in 2006 was 5.9 per 100 full-time workers (BLS, 2007). 

4.9.2 Effects of Proposed Action 

The Proposed Action would include pipe installation; construction and operation of a 

compression-dehydration facility; collection and transportation of CO2; drilling of injection and 

observation wells; and injection of supercritical CO2 (See Section 2.1). These could all present 

risks to human health and safety. The materials and equipment used for construction and 

operation would meet prescribed standards (MGSC, 2008). 

The equipment that would be used for the implementation of the Proposed Action represents 

only minimal risks to human health and safety under normal operating conditions (DOE, 2007a). 

Thus, if BMPs, maintenance, and regulations are followed, the equipment should pose little 

impact to human health and safety. Drilling into pressurized formations could release flammable 

gases like methane. Preventative measures to minimize well blowouts or venting of dangerous 

gases should be implemented. Measures to avoid the equipment failure caused by high pressure 

would be executed (DOE, 2007a). ADM’s safety plans would be updated to include the new 

risks from handling the pressurized CO2 (MGSC, 2008; MGSC, No date). 

Since all of the construction and operation of the Proposed Action is on ADM property, the 

increase in traffic from workers and delivery of equipment and materials should be partially 

limited to onsite, which reduces risk to pedestrians and the general public. However, the 

Proposed Action would still represent an increase in traffic, which increases the potential for 

accidents. The current truck traffic in and out of the Decatur ADM Complex is approximately 

1,750 trucks per day (Litynski, 2008a). The expected increase in the number of trips due to the 

Proposed Action from the current level of vehicle activity is minor. Thus, the impact to human 

health and safety from the increase in transportation is not expected to exceed the level of 

significance threshold (See Sections 4.8.1 and 4.8.3). 

Air emissions from the Proposed Action are not anticipated to be regionally significant (See 

Section 4.1). Thus, the impacts to human health from air emissions would not be expected to 

exceed the significance threshold. Following mitigation measures and BMPs would reduce any 

impacts to human health from air quality. Further, workers would follow OSHA procedures, 

which would further reduce the impact to human health. The propane burning from the 

dehydration reboiler would produce some limited air pollutants, such as formaldehyde, which 

can cause shortness of breath and blurred vision (ILO, 2004; MGSC, 2008). However, the 

Proposed Action only produces a very small amount of these air pollutants, and these are the 
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same types and quantities as with any burning of propane. Thus, there would be a minimal risk 

to human health and safety. A risk assessment is in process for the compression-dehydration 

facility. 

The soils are not highly erodible (See Section 4.2), so water contamination from increased runoff, which could lead to human health and safety risks, is not a major issue (See Section 4.3). 

Further, the facility has received a construction permit under the General NPDES permit for the 

construction storm water discharges (Keller, 2008). Further, wastewater would be collected and 

pretreated. The pretreated water is subsequently sent to the City of Decatur Publicly Owned 

Treatment Works (MGSC, 2008). Therefore, the overall effect of the Proposed Action to surface 

water quality is expected to not exceed the significance threshold. 

The only hazardous or toxic material used in the Proposed Action is CO2 (MGSC, 2008). Thus, 

if safety procedures and BMPs are followed, spills and leaks from equipment and processes 

(other than CO2) would be of low concentrations as well as nonhazardous and not toxic. This 

would represent a low risk to human health and safety (DOE, 2007c). Under normal conditions, 

hazardous and toxic materials can be used safely when appropriate safety precautions are 

followed (DOE, 2007a). Thus, the minimal concentrations of VOCs in the collected CO2 should 

be a minimal risk to human health and safety. A risk assessment is in process for compressiondehydration facility. 

The design of the Proposed Action’s MMV plan would be to avoid, detect, and correct any 

unintended CO2 emissions (MGSC, No date). The Eau Claire Formation, the Mt. Simon 

Sandstone, and the thick shale units present at the proposed injection site make groundwater 

contamination highly unlikely (ADM, 2008a). However, groundwater monitoring would still 

occur to detect problems and initiate corrective action if necessary (ADM, 2008a; MGSC, No 

date). The groundwater monitoring would include testing for metals, ammonia, CO2, pH, 

dissolved oxygen, and other possible contaminants (MGSC, No date) (See Section 4.3). This 

would allow for early detection and appropriate measures to be initiated if there were any 

problems. This would reduce the risk to human health and safety. The maximum surface 

injection pressure of 2,200 pounds per square inch (15,300 kPa) is under the anticipated fracture 

pressure for the area (ADM, 2008a). This reduces the possibility of air and water contamination 

by CO2 from fractures (See Section 4.2). The probability of hazardous leaks from the storage is 

small (NETL, 2008c; Heinrich et al., 2004). With proper monitoring and mitigation, the risk 

from induced seismicity and fractures would be expected to be below the significance threshold. 

ADM along with the MGSC would have a public outreach program that would inform multiple 

groups, such ADM staff and their families as well as general public and regulatory and 

governmental agencies, about CO2 sequestration (MGSC, No date). Education about potential 

threats and processes could reduce the risks and consequences of health and safety issues like 

accidents. A local emergency response plan would help reduce the risk of impact to the workers 

and the general public (DOE, 2007a). The primary human health risk from the Proposed Action 

to the general public would be pipeline leaks releasing CO2 (DOE, 2007a). A rapid release of 

CO2 has a very low probability due to monitoring, proper siting, and BMPs (DOE, 2007a). The 

risks could be minimized by having appropriate safety and operating procedures currently in 

place for gas processing facilities and pipelines including monitoring and inspections (DOE, 
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2007a). In general, CO2 injection has occurred safely for over twenty years with oil and gas 

activities (NETL, 2008c). Therefore, with proper safety procedures and plans, the risk to the 

general public should not exceed the significance threshold. 

The wet, uncompressed CO2 would be transported in stainless steel ductwork, which reduces the 

corrosion concerns. However, even this CO2 would be scrubbed. Thus, leaks from this wet, 

uncompressed CO2 would not be a substantial concern for human health and safety as it is 

currently permitted for discharge to atmosphere (Carroll, 2008a). 

Other than having a smaller diameter, the CO2 pipeline from the compression-dehydration 

facility to the injection site would be similar to most CO2 pipeline systems. The carbon steel 

pipe segments are nominally 40 feet (12.19 m) long with welded seams. Stainless steel is not 

necessary for this section of the CO2 piping as the CO2 is dehydrated. Wall thickness would be 

determined based on final operating outlet pressure of the compression system plus appropriate 

safety allowances. 

The right of way for the pipeline would be both aboveground on a pipe bridge across the railroad 

tracks south of the test site and below ground as it approaches the wellhead. Line markers would 

be used to locate the pipeline, and the location would be entered into the ADM database of plant 

facilities and information. Having the pipeline location information known in the database 

should help reduce the risk of accidents from construction and operation of other onsite 

activities. All the monitoring for CO2 (See Section 2.1.3.3) would reduce the risk for CO2 leaks, 

and the mitigation measures would reduce the consequences of any incidents. A risk assessment 

is in progress to quantify these risks. 

The Proposed Action would include an ambient CO2 monitoring and alarm system during 

injection operations (MGSC, No date). Under the Proposed Action, ADM would install pressure 

and temperature alarms along the pipeline to inform personnel of problems. Incorrect pressure 

(too much or too little) would cause automatic shutdown of the compressor and injection system 

to reduce the safety risks from equipment malfunction (ADM, 2008a). Pipeline inspection and 

monitoring would reduce the risks of failures and thus to human health. A common mitigation 

measure for leaking casing is venting the CO2 under appropriate controlled conditions (MGSC, 

No date). One of the major concerns regarding pipeline safety is water and other contaminants 

causing corrosion leading to pipe failure (DOE, 2007a). However, the CO2 would be dried and 

removed of contaminants, which reduces the risk from pipeline failure (MGSC, 2008). 

A detailed plan including human health, safety, and environment concerns would be written 

(MGSC, No date). Atmospheric gas monitors with alarms would be installed along the CO2

pipeline and in close proximity to the CO2 injection wells. In the event that atmospheric CO2

concentrations increase to a prescribed concentration, alarms would be sounded to alert workers 

of a potential CO2 release. In addition, an Eddy Covariance tower would be installed downwind 

of the CO2 pipeline and injection well to continuously measure atmospheric CO2 fluxes. In the 

event of a substantial CO2 release, employees would have been informed and trained regarding 

appropriate evacuation procedures following ADM safety plans. Further, modeling of 

atmospheric dispersion and CO2 concentration distribution around the test site and vicinity from 

worst case scenario/s of atmospheric CO2 releases would be conducted in order to develop and 
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implement additional emergency response plans that are essential to reduce impacts to human 

health and the environment. 

The workers on the project would be subject to the same types of health risks that are generally 

associated with their professions (DOE, 2007a). Protective equipment such as hard hats, safety 

shoes, hearing protection (earplugs), and safety glasses would be worn (MGSC, 2008). Any 

further safety equipment needed for the possible hazards should be used such as a respirator or 

dust mask for someone working with equipment that generates dust. Following safety hazards 

would minimize occupational hazards (DOE, 2007a). 

The risks to human health and safety from a rapid release of CO2 as a result of activities 

associated with the Proposed Action would depend on the amount released and conditions (such 

as wind direction and strength) at the time of the release (DOE, 2007c). A sudden and rapid 

release of CO2 from equipment, such as a wellhead being removed, would likely be detected 

quickly. The processes for containing well blow-outs would be employed to stop such a release. 

Workers on-site would be the primary group affected. If concentrations of CO2 greater than 7 to 

10% in the air were created, it would cause immediate danger to humans. Depending on the 

amount released and the pressure, the leak could take hours to days to contain, but it could take 

as little as minutes (IPCC, 2005; Heinrich et al., 2004). However, the leaked CO2 amount is 

likely to be minimal compared to the amount injected due to dispersion of CO2 in the ground 

away from injection site (Heinrich et al., 2004; IPCC, 2005). Once the release is over, no 

lingering effects would occur (Heinrich et al., 2004). In addition, the oil and gas industry 

employs engineering and administrative controls to manage these types of hazards regularly 

(IPCC, 2005). Therefore, while the risk of accidents exists, the risks to human health and safety, 

with the proper response plans and monitoring, should be below the significance threshold. 

Currently, ADM staff handles and transports CO2 and has experience with high-pressure 

pipelines (ADM, 2008c). This experience is not with CO2 at supercritical conditions. However, 

the personnel are already familiar with the general risks and procedures associated with CO2. 

ADM’s current process safety management plan would be amended. Workers would also be 

updated on safety procedures, especially ones related to handling of high pressure CO2 (MGSC, 

2008). Additionally, the Proposed Action should be implemented in accordance with applicable 

guidance from the OHSA (Occupational Safety and Health Standards: 29 CFR 1910) as well as 

other applicable industry standards and regulations (DOE, 2007a). Decommissioning of the 

facility would represent the same types of risks as the operation. Thus, with proper safety 

procedures, the impact to human health and safety should be minimal. While a risk assessment 

for Richland College has been completed, further risk assessments are planned. With the low 

failure rate of CO2 pipelines, proper siting, and the monitoring involved, the overall risk to 

human health and safety is not expected to exceed the significance threshold. 

4.9.3 Effects of No-Action 

Under the No-Action alternative, there would be no construction, operation, or decommissioning 

of the sequestration test site. Thus, none of the risks listed in the previous section would occur, 

which would mean no impacts to human health and safety. The exception would be the fact that 

the Proposed Action’s purpose is to further the research for options in preventing global climate 
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change. Possible deaths from sea levels rising, deaths from increased severity of storms, 

increase respiratory diseases, and increased deaths from heat are some of the wide variety of 

potential human health and safety impacts from global climate change (Miller, 2003). However, 

as many other projects are in operation or being proposed to assist in the reduction of risk from 

global climate change, not all of the global climate change risks are attributable to the No-Action 

alternative. Nevertheless, the No-Action alternative does represent some risk to human health 

and safety, but not a substantial one. 

4.9.4 Cumulative Effects 

Since CO2 is not flammable, there is less of a risk to human health and safety from the Proposed 

Action in combination with any existing projects in the area (IPCC, 2005). There are no planned 

projects in or near the project area (ADM, 2008b; Chamber, 2008; Decatur, 2008b). The 

cumulative impacts of existing activities in and around the project area does not represent a 

substantial risk to human health and safety with existing and upcoming mitigation and safety 

procedures in place, which means the cumulative impacts with implementing the Proposed 

Action is not expected to exceed the significance criteria. 

Since the current projects in the area do not pose a substantial risk to human health and safety, 

the No-Action alternative does not represent any additional risks to human health and safety. As 

described in the previous section, the exception is that not implementing the Proposed Action 

(thus, implementing the No-Action alternative) would have an adverse impact to the progress 

towards solutions for global climate change. However, since this is a single project of many, the 

cumulative impacts to human health and safety for the No-Action alternative are not expected to 

exceed the threshold of significance. 

4.10 Cultural Resources 

Cultural and historic resources are protected by a variety of laws and regulations, including the 

NHPA, as amended, and the Archaeological Resources Protection Act. Section 106 of the 

National Historic Preservation Act and implementing regulations (36 CFR 800) outline the 

procedures to be followed in the documentation, evaluation, and mitigation of impacts cultural 

resources. The Section 106 process applies to any federal undertaking that has the potential to 

affect cultural resources. The Illinois Historic Preservation Agency (IHPA) is the SHPO for 

Illinois (IHPA, 2007). 

4.10.1 Description 

No historical sites, federal or state historical areas, or Native American Indian reservations occur 

in the proposed project area (EDR, 2008; MGSC, 2008). The closest National Register of 

Historic Places (NRHP) property is approximately 3.5 miles (5.7 km) away to the northeast from 

the test site boundary (HAARGIS, 2002). Within the project area, the majority of the land is 

already disturbed (Figure 2.1.1-2). With this disturbance, no archeological or historical 

resources have been found (See Appendix D). Further, the project area is outside the "high 

archaeological resource potential area." This is defined as the presence of certain soil types, such 
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as Parkland Sand and Mackinaw Member, and within a buffer of stream floodplains 

(ISM, 1994). 

Two federally recognized Native American tribes have land claims in Macon County, the 

Kickapoo Tribe of Indians of the Kickapoo Reservation in Kansas and the Kickapoo Tribe of 

Oklahoma (Lavallee, 2006). DOE sent consultation letters to the nearby Native American Tribes 

and appropriate Bureau of Indian Affairs Regional Offices to inform them of the project, invite 

input, and request information of any known sites or issues in the project area. The Bureau of 

Indian Affairs, which was the only response received, requested a particular consultation process 

including contacting the SHPO (See Appendix E). DOE performed this process, and no 

concerns were found. The closest cemetery to the project area is St. John cemetery, which is 

approximately 0.7 miles (1 km) south from the test site boundary (Figure 4.10.1). 
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Figure 4.10.1. Cemeteries and NRHP-listed Sites near Project Area 
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ADM has not performed a cultural resources survey in the project area (Carroll, 2008e). 

Fossils need to be at or near the surface to allow access to them. Fossils are formed in 

sedimentary rock. There are no outcropping surface sedimentary rocks in the project area, so 

there should be no readily accessible fossils (See Section 4.2). 

4.10.2 Effects of Proposed Action 

The potential for impacts to cultural resources is the greatest during the construction phase. 

Discovery of previously unknown cultural resources can occur during construction activities in 

historically undisturbed areas. The construction noise and earthmoving activities can also 

deteriorate the use of the area for Native American activities (DOE, 2007a). 

Some construction activities occurring under the Proposed Action with the potential to disturb 

cultural resources are land clearing, transporting equipment, leveling, drilling, and laying 

pipelines. These earthmoving activities can cause an adverse impact to cultural resources by 

altering drainage patterns, creating fugitive dust, and crushing the resources. Altered drainage 

patterns and runoff can deteriorate the artifacts or move them. Fugitive dust can cover and 

remove, in the case of paintings, artifacts. Spills from refueling equipment also damages cultural 

resources, which reduces the information potentially gained by the items. Further, construction 

activities can alter or destroy the context of the cultural resources. Operational impacts include 

use of heavy equipment, which is described above, and improved access to the area, which 

increases the possibility of illegal collection of properties (DOE, 2007a). Decommissioning 

would require similar heavy equipment but would be a relatively short time frame relative to the 

operation and construction phases. Thus, decommissioning would be the same type of possible 

impacts as described above. 

The SHPO also states that there are no historical properties that would be affected by the project 

(See Appendix D). The project area is previously disturbed. Consequently, since no cultural 

resources have been found yet, there would be less of a possibility for discovering cultural 

resources during the Proposed Action. 

As there is no surface sedimentary rock, the risk to fossils (paleontological resources) that could 

be used for scientific/educational purposes is negligible (See Section 4.2). Due to distance to the 

nearest NRHP site (3.5 miles or 5.7 km), there should be no substantial impacts to visual 

resources to any known eligible or existing NRHP sites. DOE sent consultation letters to 

the nearby Native American Tribes and appropriate Bureau of Indian Affairs Regional Offices to 

inform them of the project, invite input, and request information of any known sites or issues in 

the project area. The Bureau of Indian Affairs, which was the only response received, requested 

a particular consultation process including contacting the SHPO. DOE performed this process, 

and no concerns were found (See Appendix E). 

The cemetery is not in the location of the construction and operation. Thus, the Proposed Action 

should not have any direct impacts to the cemetery. The cemetery is in an industrial site, so the 

impacts from the Proposed Action should be no greater than what the cemetery has experienced 

in the past (See Sections 4.8.5 and 4.8.6). 
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If cultural resources were discovered during the construction, the construction would be stopped, 

and the SHPO, any relevant Tribes, or other agencies consulted. If the cultural resources were 

found to be substantial, then the construction component would need to be relocated elsewhere 

or other acceptable mitigation performed as SHPO and any relevant tribes or agencies dictate. 

Based on the information above, the impacts from implementing the Proposed Action are not 

expected to exceed the impact significance threshold. 

4.10.3 Effects of No-Action 

Under the No-Action alternative, ADM would not conduct the CO2 test or put the corresponding 

infrastructure in place. Thus, there would be no construction, operation, or decommissioning 

activities. Therefore, there would be no impacts to cultural resources. However, the No-Action 

alternative would not fulfill the need of the project. 

4.10.4 Cumulative Effects 

ADM has no other projects planned for the area (Carroll, 2008b). Since there are no substantial 

impacts to cultural resources, the Proposed Action and the No-Action alternative do not 

substantially contribute to the cumulative impacts to cultural resources in the vicinity of the 

project area or in the project area. As impacts to cultural resources are generally local (heavy 

machinery crushing resources, etc.), the Proposed Action and the No-Action alternative both are 

unlikely to contribute to impacts to cultural resources outside the vicinity of the project area, and 

those local impacts would not be expected to exceed the threshold of significance. 

4.11 Waste Management 

4.11.1 Description 

During the drilling stage of the proposed project, which would include the drilling of one 

injection well and two verification wells, a number of wastes would be generated. These wastes 

could potentially include: 

• Lubricating oils and greases, 

• Used solvents, 

• Used hydraulic fluid, 

• Metal parts, wire and cable, 

• Oily rags, 

• Domestic sewage, 

• Domestic solid waste, 

• Contaminated soil from spills, 

• Discarded cement, 

• Containers (metal, wood, plastic, etc.), 

• Produced water (oily and/or saline), and 

• Drilling mud and cuttings. 
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All drilling waste disposal methods will be in accordance with existing ADM conditions for the 

Decatur ADM Complex and or any and all local/federal or state regulations as indicated from 

any permit requirements for the project (Litynski, 2008c). An earthen “reserve pit” or earthen pit 

will be constructed and properly lined for drill cuttings, water-based drilling fluids, rig wash 

water and to a certain degree, rain water. 

As cuttings are developed by the drilling operation, they will be diverted to this lined earthen 

reserve pit and after the drilling/completion operations are completed, the pit will be “farmed” 

back to as close to its original state as possible, keeping in mind future operations for each of the 

wells to be drilled in the area. All used engine oils and any other chemical-related items that 

need to be changed/rolled out as part of the drilling process, will be placed in sealed barrels, 

properly labeled and transported to an appropriate disposal location. 

The underground injection control permit application indicated that upon decommissioning, 

tubing would be sold as scrap metal, and the site would not treat, store or dispose of hazardous 

waste (ADM, 2008a). The permit application also indicated shallow groundwater monitoring 

wells would be drilled using wireline coring tools, which would require the use of bentonite 

based drilling mud, or the use of hollow stem augers. 

A project environmental questionnaire indicated that 9,240 gallons (35 kiloliters) of wastewater 

would be produced from the dehydration/compression/cooling processes (MGSC, 2008). The 

water would be directed to the wastewater treatment facility or the water re-use system that 

exists for the Decatur ADM Complex. Additionally, the operation of a compressor would 

generate waste products that could include: 

• Used lube oil, 

• Spent glycols, 

• Used metal parts, 

• Used gaskets, 

• Oily rags, 

• Filters, 

• Containers, 

• Contaminated soils from spills and leaks, and 

• Domestic solid wastes. 

The final compressor selections have not been made but would likely include an electric driven 

multi-stage reciprocating compressor. The exact nature and volumes of waste generated would 

be dependent on the final compressor selection. It is assumed that frame lubrication oil (which is 

typically lower weight mineral or synthetic oil) would typically be changed twice per year and 

cylinder oil (which is typically an animal fat for this application) would be continuously metered 

into the compressor cylinders at low rates and would remain in the CO2 stream. Each type of oil 

has a filter, and it is projected that approximately 8 to 16 filters would be used per year. The 

lubrication oil and oil filters would be sent either to a waste oil recycler or disposed in 

accordance with applicable regulations. 

If a TEG glycol dehydration unit would be selected for use, approximately 48 waste glycol 

particulate filters (half rich, half lean) would be generated per year. Glycol carbon filters are 
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changed as needed and it is estimated 200 lbs/year (90.72 kilograms (kg)/year) waste carbon 

would be generated from regular maintenance. The glycol particulate filters and the spent 

carbon would be disposed of offsite in accordance applicable regulations. The exact disposal 

protocol would follow that established by ADM to dispose of their other wastes. No hazardous 

waste would be generated. 

There should be little to no saline water brought to the surface that is not controlled through well 

control or direct sampling via drill stem test (DST) or modular formation dynamics tester 

(MDT). The drilling fluids will have weight enough to be in excess of formation pressure, thus 

no flow back is expected. Only during times when sampling is occurring will fluids be brought 

to surface in contained jugs and/or sample chambers, likely using MDT. If large amounts of 

fluids are required, a DST would be used and there may be some fluid spillage on the rig floor, 

which will be washed to the reserve pit (Greenberg, 2008). 

4.11.2 Effects of Proposed Action 

Based on the volumes of drill waste generated, it is not anticipated that there will be any drilling 

wastes that exceed the significance threshold (Litynski, 2008c). All drilling waste disposal 

methods will be in accordance with existing local, state, or regulations. 

Waste lube oil, filters, and spent carbon generated from dehydration/compression/cooling and 

transportation processes would be handled according to applicable regulations and should not 

exceed any significance thresholds. Other waste streams generated should not pose significant 

waste management problem as they would not be unique to the carbon sequestration process. 

Based on the anticipated volumes of domestic wastes to be generated and the approved disposal 

options available the impacts from these waste streams should not exceed significance 

thresholds. No hazardous waste is to be generated. Therefore, no hazardous waste management 

issues should arise. 

Any waste formation brine resulting from geochemical sampling would be in sufficiently low 

enough volumes that a suitable disposal option would be available. Therefore, impacts from 

waste management are not expected to exceed the significance threshold. 

4.11.3 Effects of No-Action 

Under the No-Action alternative, no drilling waste would be generated. No wastes from the 

dehydration/compression/cooling and transportation of the CO2 would be generated and no waste 

formation brine from sampling would be realized. 

4.11.4 Cumulative Impacts 

Potential cumulative impacts related to the drilling of the wells would include disposal of drilling 

mud and a minor quantity of produced water. Provided all regulatory requirements were met and 

wastes were disposed of through an approved waste receiver, the cumulative waste impacts, 
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related to the drilling requirements of the Proposed Action, would not be expected to exceed the 

threshold of significance. 

Potential cumulative impacts related to the waste products from the compression and 

transportation of CO2 for the Proposed Action are not expected to be substantial assuming 

suitable collection and handling of solid wastes, lubricating oils and coolants, and the treatment 

and/or re-use of the wastewater stream at the Decatur ADM Complex. 

There would likely to be negligible cumulative impacts regarding wastes related to sampling and 

monitoring of the wells due to the relatively small volumes of waste that would be generated 

from these activities. 

Overall, the Proposed Action would not cause air, water, or soil to be contaminated with 

hazardous materials (assuming appropriate drilling waste management and compressor waste 

containment strategies are in place) to a degree that would pose a threat to human or ecological 

health and safety. 
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5.0 CONSULTATION AND COORDINATION 

A kick-off meeting was held on May 14, 2008, at the NETL office in Morgantown, West 

Virginia, with representatives from NETL, the University of Texas, and Mangi Environmental 

Group to formally begin the EA process. Subsequent to that meeting, a review was made of 

available information necessary for the completion of the EA and data gaps were submitted to 

NETL. A site visit and project briefing from the MGSC was held on May 22, 2008 in 

Champaign, Illinois, and Decatur, Illinois, where opportunities were provided to ask questions 

and interview key personnel from the MGSC project. 

5.1 Agency Coordination 

The CEQ’s regulations for implementing NEPA allows Federal agencies to invite comment from 

tribal, state, and local agencies, as well as other Federal agencies in the preparation of EAs. The 

purpose of this coordination is to obtain special expertise with respect to environmental and 

cultural issues in order to enhance interdisciplinary capabilities, and otherwise ensure successful, 

effective consultation in decision-making. 

5.1.1 U.S. Fish and Wildlife Service (USFWS) 

The mission of the USFWS is to conserve, protect, and enhance fish, wildlife, and plants and 

their habitats for the continuing benefit of American people. The email from USFWS requested 

the Endangered Species Section 7(a)(2) Consultation process. The analysis addressed issues 

raised by USFWS in the body of the document, which incorporated the requested process, and 

the necessary documentation memo is in Appendix B. 

See Appendix B for letters sent to and received from agency. 

5.1.2 State Historic Preservation Office (SHPO) 

NHPA requires DOE to consult with the SHPO prior to any construction to ensure that no 

historical properties would be adversely affected by a proposed project. DOE must also afford 

the Advisory Council on Historic Preservation a reasonable opportunity to comment on the 

proposed project. The SHPO had no objection to the project. 

See Appendix D for letters sent to and received by the agency. 

5.1.3 Bureau of Indian Affairs 

The American Indian Religious Freedom Act, 42 USC § 1996, establishes policy to protect and 

preserve the inherent and Constitutional right of Native Americans to believe, express, and 

exercise their traditional religions. The law ensures the protection of sacred locations; access of 

Native Americans to those sacred locations and traditional resources that are integral to the 

practice of their religions; and establishes requirements that would apply to Native American 

sacred locations, traditional resources, or traditional religious practices potentially affected by 

construction and operation of proposed facilities. Only the Bureau of Indian Affairs responded. 
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Their only concern was to conduct a particular consultation process, such as contacting the 

SHPO, which DOE performed and the analysis addressed in the text of the document. 

See Appendix E for letters sent to the Bureau of Indian Affairs and Tribal Councils and the one 

letter received. 

5.2 Public Involvement 

The public comment period on the Draft EA was August 25 to September 25, 2008. An article 

informing the public of the availability of the Draft EA at the Decatur Public Library ran in the 

Herald & Review on August 25th and 26th. DOE received no comments from the public (Noceti, 

2008). 
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6.0 LIST OF PREPARERS 

6.1 Mangi Environmental Group 

James Mangi; Contract Management 

Randy Williams, Program Manager 

Dave Henney; MGSC Assessment Project Manager, Proposed Action; No-Action, Project 

Location; Alternatives, Land Use 

Dick Wildermann; Purpose and Need, Threshold Significance Criteria, 

Meghan Morse; Associate Project Manager, Document/Administrative Record Management, 

Human Health and Safety, Cultural Resources; Cause-Effect-Questions 

Ian Duncan; Geology and Soils; Water Resources 

Eveline Martin; Wetlands, Wildlife, Terrestrial Plants, Visual Resources 

Tim Lavallee; Air Quality, Noise 

Bud Watson; Legal Framework 

Rick Heffner; Socioeconomics 

Mark Blevins; GIS 

Lisa Edouard; Glossary 

6.2 Wiebe Environmental Services 

 

Jason Breakey; Operations/Program Manager 

Ed Osborne; Project Management, Soils 

Craig Robertson; Water Resources and Geology 

John Railton; Review for Threshold Impact and Public Significance 

Harald Thimm; Construction, Operation and Decommissioning. 

Kai Nielsen; Waste Management 

Kate Forbes; Background Research and Report Preparation. 
U.S. Department of Energy MGSC Phase III 

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References 99 October 2008 

7.0 REFERENCES 

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(Census, No date). Census Bureau, American FactFinder. No date provided. Population FinderDecatur city, IL. Accessed June 2008 at 

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(CEQ, 1997). Council on Environmental Quality. 1997. Environmental Justice Guidance Under 

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(Chamber, 2008). Decatur Chamber of Commerce. 2008. Personal Communication. Proposed 

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(Decatur, 2008a). The City of Decatur, IL. 2008. 2008 Annual Water Quality Report: PWS ID 

1150150. Accessed July 2008 at 

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(Decatur, 2008b). Planning and Zoning Department, City of Decatur, IL. 2008. Personal 

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(Decatur, 2008c). The City of Decatur. 2008. Land Development Code. Accessed June 2008 at 

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(Decatur Park District, No date). Decatur Park District. No date provided. Parks in the Decatur 

Park District. Accessed August 2008 at http://www.decatur-parks.org/main/parks_map.php. 
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References 102 October 2008 

(DOE, 2007a). U.S. Department of Energy, National Energy Technology Laboratory. 2007. 

Carbon Sequestration Program Environmental Reference Document. Accessed June 2008 at 

http://www.netl.doe.gov/technologies/carbon_seq/refshelf/nepa/index.html. 

(DOE, 2007b). U.S. Department of Energy, Energy Information Administration. 2007. 

International Energy Outlook 2007. Accessed June 2008 at http://www.eia.doe.gov/oiaf/ieo/. 

(DOE, 2007c). U.S. Department of Energy. 2007. FutureGen Environmental Impact Statement. 

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(DOE, 2003). U.S. Department of Energy. 2003. Final Environmental Assessment for Pilot 

Experiment for Geological Sequestration of Carbon Dioxide in Saline Aquifer Brine Formations. 

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(EDR, 2008). Environmental Data Resources. 2008. EDR NEPACheck® for 4666 Faries 

Parkway, Decatur, IL 62521. Inquiry Number 2237495.2s. 31 pp. 

(Finley, 2008). Finley, R. Director, Energy and Earth Resources Center, Illinois State Geological 

Survey. 2008. Personal Communication. Disposition of Compression and flow lines. July 18, 

2008. 

(Fisher, 2008). Fisher, K. Principal Engineer, Trimeric Corp. 2008. Personal Communication. 

Flow Diagram text descriptions for EA. July 23, 2008. 

(Greenberg, 2008). Greenberg, S. Sequestration Communications Coordinator, Illinois State 

Geological Survey. 2008. Personal Communication. Quantity and disposition of produced saline 

water. July 17, 2008. 

 

(HAARGIS, 2002). Historic Architectural/Archeological Resources. 2002. HAARGIS: Main. 

Accessed June 2008 at http://gis.hpa.state.il.us/hargis/. 

(Harris, 1998). Harris, Cecil M. 1998. Handbook of Acoustical Measurement and Noise Control. 

New York: Acoustical Society of America. 

(Heinrich et al., 2004). Jason J. Heinrich, Howard J. Herzog, and David M. Reiner. 2004. 

Environmental Assessment of Geologic Storage of CO2. Accessed July 2008 at 

http://sequestration.mit.edu/pdf/LFEE_2003-002_RP.pdf. 

(IDNR, 2008). Illinois Department of Natural Resources. 2008. Illinois Threatened and 

Endangered Species by County - Illinois Natural Heritage Database. Accessed June 2008 at 

http://dnr.state.il.us/ORC/list_tande_bycounty.pdf. 

(IDNR, 2003). Illinois Department of Natural Resources. 2003. Illinois Rivers and Lakes Fact 

Sheets. Accessed July 2008 at 

http://dnr.state.il.us/lands/education/CLASSRM/aquatic/CL_A.PDF. 
U.S. Department of Energy MGSC Phase III 

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References 103 October 2008 

(IEPA, 2008). Illinois Environmental Protection Agency. 2008. Illinois Integrated Water Quality 

Report and Section 303(d) List-2008. Accessed August 2008 at 

http://www.epa.state.il.us/water/tmdl/303d-list.html. 

(IEPA, 2007). Illinois Environmental Protection Agency. 2007. Waste Management: 

Underground Injection Control Program. Accessed July 2008 at 

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(IEPA, 2006). Illinois Environmental Protection Agency. 2006. Illinois Integrated Water Quality 

Report and Section 303(d) List-2006. Accessed August 2008 at 

http://www.epa.state.il.us/water/tmdl/303d-list.html. 

(IEPA, 2004). Illinois Environmental Protection Agency. 2004. Decatur ADM Complex – Title V 

Permit Number 115015AAE. August 18, 2004. 1113 pp. 

(IHPA, 2007). Illinois Historic Preservation Agency. 2007. Illinois Historic Preservation 

Agency: Welcome. Accessed June 2008 at http://www.illinoishistory.gov/. 

(IL, 2008). The State of Illinois. 2008. Environmental Regulations for the State of Illinois.

Accessed June 2008 at 

http://www.ipcb.state.il.us/SLR/IPCBandIEPAEnvironmentalRegulations-Title35.asp. 

(Illinois State Water Survey, 1996). Illinois State Water Survey. 1996. One-Hundred and FiveHundred Year Flood Zones for Unincorporated Areas in Illinois. Urbana-Champaign, 

IL. Accessed July 2008 at http://www.isgs.uiuc.edu/nsdihome/webdocs/st-hydro.html. 

(ILO, 2004). International Labour Organization. 2004. ICSC 0275-Formaldehyde. Accessed June 

2008 at 

www.ilo.org/public/english/protection/safework/cis/products/icsc/dtasht/_icsc02/icsc0275.htm. 

(International Energy Agency, 2007). International Energy Agency. 2007. Study of Potential 

Impacts of Leaks from Onshore CO2 Storage Projects on Terrestrial Ecosystems. Greenhouse 

Gas R&D Programme Technical Study. Report Number: 2007/3. 

(IPCB, 2008). Illinois Pollution Control Board. 2008. Environmental Regulations. Accessed June 

2008 at http://www.ipcb.state.il.us/SLR/IPCBandIEPAEnvironmentalRegulations-Title35.asp. 

(IPCC, 2005). Intergovernmental Panel on Climate Change. 2005. IPCC Special Report on

Carbon Dioxide Capture and Storage. Accessed on June 2008 at 

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(ISGS, 1996). Illinois State Geological Survey. 1996. Quaternary Deposits of Illinois. Accessed 

October 2008 at http://www.isgs.uiuc.edu/maps-data-pub/publications/pdf-files/quaternarydeposits-8x11.pdf. 
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(ISM, 1994). Illinois State Museum. 1994. Archaeological Resource Potential in Illinois by 

County: ISM GIS Database archmod. Accessed August 2008 at 

http://www.isgs.uiuc.edu/nsdihome/outmeta/archmod.f.html. 

(Keller, 2008). Keller, A. Manager, Permit Section: Division of Water Pollution Control for 

Illinois Environmental Protection Agency. 2008. Personal Communication. Notice of Coverage 

Under Construction Site Activity Storm Water General Permit. February 25, 2008. 

(Lavallee, 2006). Lavallee, J. 2006. Native American Consultation Database Search (NACD).

Accessed June 2008 at http://home.nps.gov/nacd/. 

(Litynski, 2008a). Litynski, J. Project Manager, NETL. 2008. Personal Communication. Fwd Re 

MGSC Initial Internal Draft. July 10, 2008b. 

(Litynski, 2008b). Litynski, J. Project Manager, NETL. 2008. Personal Communication. Faries 

Park. August 22, 2008. 

(Litynski, 2008c). Litynski, J. Project Manager, NETL. 2008. Personal Communication. MGSC 

Initial Internal Draft. July 3, 2008. 

(MGSC, 2008). Midwest Geological Sequestration Consortium. 2008. Environmental 

Questionnaire. 31 pp. 

(MGSC, No date). Midwest Geological Sequestration Consortium. No date provided. An 

Assessment of Geological Carbon Sequestration Options in the Illinois Basin—Phase III 

Statement of Project Objectives. 26 pp. 

(Miller, 2003). Miller, G. Tyler. 2003. Environmental Science. 9th edition. Pacific Grove, 

California: Brooks/Cole-Thomson Learning. 

(Moore, 2008). Moore, M. Receptionist, Decatur Park District. 2008. Personal Communication. 

Faries Park. August 22, 2008. 

(National Atlas, 2008). National Atlas. 2008. Map Layers. Accessed June 2008 at 

http://nationalatlas.gov/maplayers.html?openChapters=chpbio#chpbio. 

(NETL, 2008a). National Energy Technology Laboratory. 2008. Program Facts: Carbon 

Sequestration: Midwest Geological Sequestration Consortium—Deployment Phase. Accessed 

July 2008 at http://www.netl.doe.gov/publications/factsheets/project/Proj491.pdf. 

(NETL, 2008b). National Energy Technology Laboratory. 2008. NETL Regional Carbon 

Sequestration Partnership Peer Review Meeting ADM Test Site Project Information Form. 15 

pp. 

(NETL, 2008c). National Energy Technology Laboratory. 2008. Lake Nyos and Mammoth 

Mountain: What Do They Tell Us about the Security of Engineered Storage of CO2
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Underground? Accessed July 2008 at 

http://www.netl.doe.gov/publications/factsheets/program/Prog064.pdf. 

(NIOSH, No date). National Institute for Occupational Safety and Health (NIOSH). No date 

provided. NIOSH Topic: Construction Safety. Accessed June 2008 at 

http://www.cdc.gov/niosh/topics/constructionsafety/. 

(Noceti, 2008). Noceti, Pierina. 2008. NEPA Document Manager, NETL. Personal 

Communication. Public Comments to Public Draft EA. September 26, 2008. 

(NRCS, 2008). Natural Resources Conservation Service Soil Survey Staff, United States 

Department of Agriculture. 2008. Official Soil Series Descriptions. Accessed July 2008 at 

http://soils.usda.gov/technical/classification/osd/index.html. 

(Roadcap and Wilson, 2001). Roadcap, G.S., Wilson, S.D., 2001. The Impact of Emergency 

Pumpage at the Decatur Wellfields on the Mahomet Aquifer: Model Review and 

Recommendations. Accessed July 2008 at www.sws.uiuc.edu/pubdoc/CR/ISWSCR2001-11.pdf. 

(Schlumberger, 2008a). Schlumberger. 2008. Westbay System: Multilevel Groundwater 

Monitoring in a Multiport System. Accessed July 2008 at 

http://www.slb.com/content/services/additional/water/monitoring/multilevel/westbay_multilevel

_well.asp. 

(Schlumberger, 2008b). Schlumberger Carbon Services. 2008. ADM Project Transport and JM 

Plan Summary. Prepared by P.T. Hughs, P.E. 5 pp. 

(Schlumberger 2008c). Schlumberger Carbon Services. 2008. ADM Project-Well Construction 

Transport Movement Estimate. Prepared by P.T. Hughs. P.E. 1 p. 

(Skinner, 2003). Skinner, L. 2003. CO2 Blowouts: An Emerging Problem. World Oil. 224 (1): 

38-42. 

(UNFCCC, 2007). United Nations Framework Convention on Climate Change. 2007. Kyoto 

Protocol Reference Manual on Accounting of Emissions and Assigned Amounts. Accessed June 

2008 at 

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ocol/application/pdf/rm_final.pdf. 

(USEPA, 2008a). U.S. Environmental Protection Agency. 2008. Federal Requirements Under 

the Underground Injection Control (UIC) Program for Carbon Dioxide (CO2) Geologic 

Sequestration (GS) Wells (Proposed Rule). Accessed August 2008 at 

http://www.epa.gov/fedrgstr/EPA-WATER/2008/July/Day-25/w16626.htm. 

(USEPA, 2008b). U.S. Environmental Protection Agency. 2008. USEPA AirDATA Website. 

Accessed June 2008 at http://www.epa.gov/oar/data/. 
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(USEPA, 2007a). U.S. Environmental Protection Agency. 2007a. Inventory of US Greenhouse 

Gas Emissions and Sinks: 1990–2005. EPA 430-R-07-002. April 15, 2007. U.S. Environmental 

Protection Agency. Washington, D.C. 

(USEPA, 2007b). U.S. Environmental Protection Agency. 2007b. Climate Change. Accessed 

June 2008 at www.epa.gov/climatechange/basicinfo.html#emissions. 

(USEPA, 2007c). U.S. Environmental Protection Agency. 2007. Basic Information: Air and 

Radiation. Accessed June 2008 at http://www.epa.gov/air/basic.html. 

(USEPA, 1974). U.S. Environmental Protection Agency. 1974. Information on Levels of 

Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin 

of Safety. Accessed October 2008 at 

http://www.nonoise.org/library/levels74/levels74.htm#table%20of%20contents. 

(USFWS, 2008a). United States Fish and Wildlife Service. 2008. Wetlands Geodatabase. 

Accessed June 2008 at http://wetlandsfws.er.usgs.gov/NWI/codes.html. 

(USFWS, 2008b). United States Fish and Wildlife Service. 2008. Endangered Species Section 

7(a)(2) Consultation. Accessed June 2008 at 

http://www.fws.gov/midwest/endangered/section7/s7process/index.htm. 

(USFWS, 2007). United States Fish and Wildlife Service. 2007. Endangered Species in Illinois 

County Distribution of Federally Threatened, Endangered, Proposed and Candidate Species - 

By County. Accessed June 2008 at 

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(USFWS, 1987). United States Fish and Wildlife Service. National Wetlands Inventory. 1987. 

Wetlands and Deepwater Habitats of the Conterminous United States - Illinois. Accessed June 

2008 at http://wetlandsfws.er.usgs.gov/NWI/download.html. 

(USGS, 2008). United States Geological Survey. 2008. Water Quality Samples for Illinois. 

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(USGS, 2007). United States Geological Survey. 2007. Water-Data Report 2007 05573540 

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8.0 GLOSSARY 

Adiabatic Decompression – Thermodynamic process in which no heat is transferred to or from 

the working fluid. 

Adsorbed – Condensed and forming a thin film on a surface.

Ambient – The natural surroundings of a location. 

Anthropogenic – Caused or produced by humans. 

Anticline – In structural geology, a fold that is convex up and has its oldest beds at its core. 

Argillaceous Dolomitic Sandstone – Sandstone containing substantial amounts of clay-like 

components and sedimentary carbonate rock. 

Asphyxiation – A condition of severely deficient supply of oxygen to the body that arises from 

being unable to breathe normally. 

Attainment Areas – A zone within which the level of a pollutant is considered to meet United 

States National Ambient Air Quality Standards. 

A-weighted Decibels – An expression of the relative loudness of sounds in air as perceived by 

the human ear. 

Best Management Practices – Innovative, dynamic, and improved environmental protection 

practices applied to oil and natural gas drilling and production to help ensure that energy 

development is conducted in an environmentally responsible manner. 

Blowdown – Minimum discharge of recalculating water to discharged materials contained in the 

water, the further buildup of which would cause concentration in amounts exceeding limits 

established by best engineering practice. 

Brine – Water saturated or nearly saturated with salt. 

Caprock – A non permeable rock formation that prevents fluids from migrating upward from a 

porous formation. 

Carbon Dioxide – Greenhouse gas created by combustion and emitted primarily from human 

activity such as the burning of fossil fuels to generate electricity and operate vehicles, 

abbreviated CO2. 

Carbon Sequestration – The capture and storage of carbon long-term in an effort to avoid 

release of that carbon as carbon dioxide in the atmosphere. 
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Class I Non-Hazardous – These wells have nonhazardous materials underneath the lowest 

underground source of drinking water (IEPA, 2007). 

Criteria Pollutants – The Clean Air Act requires USEPA to set standards for six common air 

pollutants. These commonly found air pollutants (also known as "criteria pollutants") are found 

all over the United States. They are particle pollution (often referred to as particulate matter), 

ground-level ozone, carbon monoxide, sulfur oxides, nitrogen oxides, and lead. 

Cultural Resources – Archaeological sites, historical sites (e.g. standing structures), NativeAmerican resources, and paleontological resources. 

Cumulative Effects – Those effects on the environment that result from the incremental effect 

of the action when added to past, present and reasonably foreseeable future actions regardless of 

what agency (federal or nonfederal) or person undertakes such other actions. 

Day-night Sound Level – The A-weighted equivalent sound level for a 24 hour period with an 

additional 10 dB imposed on the equivalent sound levels for night time hours of 10 P.M. to 7 

A.M. 

Decibel – A unit of measurement that expresses the magnitude of a physical quantity (usually 

intensity) relative to a specified or implied reference level. The decibel is useful for a wide 

variety of measurements in science (for this application, it is sound). 

Downhole – A location in the geologic strata that is lower/below a designated location. 

Endangered Species – A species whose numbers are so small that the species is at risk for 

extinction. A federal list of endangered species can be found in 50 CFR 17.11 (wildlife), 50 

CFR 17.12 (plants), and 50 CFR 222.23(a) (marine organisms). Illinois maintains its list of 

endangered species with the Illinois Endangered Species Protection Board. 

Effluent – Waste stream flowing into the atmosphere, surface water, groundwater, or soil. 

Emergent – Amphibious plants or ecosystems that are partially or temporarily in the water or 

but not continuously or entirely. 

EA – (Environmental Assessment), A concise public document, prepared in compliance with the 

National Environmental Policy Act, that briefly discusses the purpose and need for an action, 

alternatives to such action, and provides sufficient evidence and analysis of impacts to determine 

whether to prepare an environmental impact statement or finding of no significant impact (40 

CFR 1508.9). 

EIS – (Environmental Impact Statement), A detailed written statement required by Section 

102(2) (C) of the National Environmental Policy Act, analyzing the environmental impacts of a 

Proposed Action, adverse effects of the project that cannot be avoided, alternative courses of 

action, short-term uses of the environment versus the maintenance and enhancement of long-
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Glossary 109 October 2008 

term productivity, and any irreversible and irretrievable commitment of resources (40 CFR 

1508.11). 

Environmental Justice – The confluence of social and environmental movements, which deals 

with the inequitable environmental burden born by groups such as racial minorities, women, or 

residents of developing nations. 

Equivalent Sound Level – The level of a steady-state noise without impulses or tone 

components which is equivalent to the actual noise emitted over a period of time. 

Erodible – The erodibility of soils can be described as their sensitivity to the effects of wind and 

water on the soil structure. This property is expressed as an erodibility index, where low values 

indicate high susceptibility to erosion, and high values correspondingly indicate a low 

susceptibility to erosion. The erodibility index is determined by combining the effects of slope 

and soil type, rainfall intensity and land use. These aspects are represented by terrain 

morphology (soil and slope), mean annual rainfall, and broad land use patterns. 

FONSI – (Finding of No Significant Impact), A document prepared in compliance with the 

National Environmental Policy Act, supported by an environmental assessment, that briefly 

presents why a Federal action will have no significant effect on the human environment and for 

which an environmental impact statement, therefore, will not be prepared (40 CFR 1508.13). 

Greenhouse Gas – Greenhouse gases are the gases present in the earth's atmosphere which 

reduce the loss of heat into space and therefore contribute to global temperatures. 

Hazardous Waste – Waste substances which can pose a substantial or potential hazard to human 

health or the environment when improperly managed. 

Hertz – The frequency of sound waves. 

Hydrocarbon Traps – A subsurface pool of hydrocarbons contained in porous rock formations 

that are trapped by overlying rock formations with lower permeability. 

Isopach Map – A map with contours that display the stratigraphic thickness of a subsurface rock 

unit. 

Kilowatt – A measurement of electric power. 

Lithology – Geological field focusing on macroscopic hand-sample or outcrop-scale description 

of rocks. 

Median Household Income – The median household income is commonly used to provide data 

about geographic areas and divides households into two equal segments with the first half of 

households earning less than the average household income and the other half earning more. 
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Glossary 110 October 2008 

Minority – Individual(s) who are members of the following population groups: American Indian 

or Alaskan Native; Asian or Pacific Islander; Black, not of Hispanic origin; or Hispanic. 

Minority Population – Identified where either the affected area’s minority population exceeds 

50 percent or the affected area’s minority population percentage is meaningfully greater than the 

minority population percentage in the general population or other appropriate unit of geographic 

analysis. 

Moraine – Glacially formed accumulation of unconsolidated glacial debris (soil and rock) which 

can occur in currently glaciated and formerly glaciated regions, such as those areas acted upon 

by a past ice age. 

NAAQS – (National Ambient Air Quality Standards), Standards established by the USEPA that 

apply for outdoor air throughout the country. Primary standards are designed to protect human 

health, with an adequate margin of safety, including sensitive populations such as children, the 

elderly, and individuals suffering from respiratory disease. 

NEPA – (National Environmental Policy Act), Requires all agencies, including Department of 

Energy, to examine the environmental impacts of their actions, incorporate environmental 

information, and use public participation in the planning and implementation of all actions. 

Federal agencies must integrate NEPA with other planning requirements, and prepare 

appropriate NEPA documents to facilitate better environmental decision making (40 CFR 1500). 

New Source Performance Standards – Are pollution control standards issued by the USEPA. 

The term is used in the Clean Air Act Extension of 1070 to refer to air pollution emission 

standards, and in the Clean Water Act referring to standards for discharges of industrial 

wastewater to surface waters. 

Nonattainment Areas – The Clean Air Act and Amendments of 1990 define a "nonattainment 

area" as a locality where air pollution levels persistently exceed national standards or that 

contributes to ambient air quality in a nearby area that fails to meet standards. Designating an 

area as nonattainment is a formal rulemaking process, and USEPA normally takes this action 

only after air quality standards have been exceeded for several consecutive years. 

Paleogeography – The study of what the geography was in times past. It is most often used in 

connection with the physical landscape. 

Palustrine – Non-tidal wetlands. 

Particular Matter – Small solid particles and liquid droplets in the sir. 

Perfluorocarbons – (PFCs), Compounds derived from hydrocarbons by replacement of 

hydrogen atoms by fluorine atoms. PFCs are made up of carbon and fluorine atoms only. 

Permeability – Formations that transmit fluids readily, such as sandstones, are described as 

permeable and tend to have many large, well-connected pores. 
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pH – The measure of the acidity or alkalinity of a solution. 

Point Source Pollution – Single identifiable localized source of air, water, thermal, noise, or 

light pollution. 

Porosity – A measure of the void spaces in a material. 

Quaternary – The geologic time period after the Neogene Period roughly 1.8 million years ago 

to the present. 

Saline Formation – Layers of porous rock that are saturated with bring water. 

Sequestration – Development and demonstration of technologies for the placement of CO2 into 

a repository such that it will remain stored for very long periods of time (hundreds to thousands 

of years); the three potential pathways for storage are geologic sequestration, terrestrial 

sequestration, and ocean sequestration. 

Stakeholders – A person, company, group of people, etc., that have a concern and financial 

interest in an issue. 

Stratigraphy – A branch of geology; studies of rock layers and layering. 

Subsurface wireline correlations – Information derived from a logging procedure that consists 

of lowering a 'logging tool' on the end of a wireline into an oil well (or hole) to measure the rock 

and fluid properties of the formation.

Supercritical CO2 – Carbon dioxide that is in a fluid state while also being at or above both its 

critical temperature and pressure. 

Vadose Zone – Area of soil between the ground surface and the area directly above the 

groundwater surface (i.e., the water table) of unconfined aquifers. 

Vertical Seismic Profile – (VSP), A technique of seismic measurements used for correlation 

with surface seismic data. 

Wetland – Area inundated or saturated by surface or groundwater at a frequency and duration 

sufficient to support, and that under normal circumstances do support, a prevalence of vegetation 

typically adapted for life in saturated soil conditions. Wetlands generally include swamps, 

marshes, bogs, and similar areas. 
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APPENDICES Appendix A Air Emission Calculations 

Table A-1. Drilling Emissions

Heavy Equipment Use Equipment Type 

Number of

Units

Days on 

Site

Hours Per 

Day

Operating 

Hours

Bore/Drill Rigs 1 90 24 2160Generator Sets 4 90 24 8640Other Construction Equipment 3 90 24 6480Drilling Equipment Emission Factors 

(lbs/hour) 

Equipment CO NOx VOC SOx PM10 PM2.5Bore/Drill Rigs 0.5281 1.3416 0.1295 0.0017 0.0591 0.0591Generator Sets 0.3461 0.6980 0.1075 0.0007 0.0430 0.0430Other Construction Equipment 0.4504 1.1575 0.1215 0.0013 0.0503 0.0503Source: (CARB, 2007b) Drilling Equipment Emissions 

(tons) 

Equipment CO NOx VOC SOx PM10 PM2.5Bore/Drill Rigs 0.5704 1.4489 0.1399 0.0019 0.0638 0.0638Generator Sets 1.4952 3.0154 0.4642 0.0030 0.1858 0.1858Other Construction Equipment 1.4592 3.7504 0.3937 0.0041 0.1631 0.1631Total Equipment Emissions 3.5247 8.2147 0.9978 0.0090 0.4127 0.4127Drilling Worker Commutes Number of Workers 30Number of Trips 2 Miles Per Trip 30Days of Drilling 90Total Miles 162000
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Table A-1. Drilling Emissions

Pollutant CO NOx VOC SOx PM10 PM2.5Emission Factor (lbs/mile) 0.0105 0.0011 0.0011 0.0000 0.0001 0.0001Total Emissions (lbs) 1708.85 178.67 174.83 1.74 13.78 8.57Total Emissions (tons) 0.8544 0.0893 0.0874 0.0009 0.0069 0.0043Source: (CARB, 2007b) Total Drilling Emissions (tons) Activity/Source CO NOx VOC SOx PM10 PM2.5Heavy Equipment 3.5247 8.2147 0.9978 0.0090 0.4127 0.4127Worker Commutes 0.8544 0.0893 0.0874 0.0009 0.0069 0.0043Total Drilling Emissions 4.3791 8.3040 1.0852 0.0099 0.4195 0.4169

Table A-2. Construction Emissions

Construction Equipment Use Equipment Type 

Number of Units 

Days on Site 

Hours Per Day 

Operating Hours 

Air Compressors 1 30 4 120 Cement & Mortar Mixers 1 30 7 210 Cranes 1 30 7 210 Generator Sets 1 30 7 210 Tractors/Loaders/Backhoes 1 30 7 210 Construction Equipment Emission Factors (lbs/hour) Equipment CO NOx VOC SOx PM10 PM2.5Air Compressors 0.3782 0.7980 0.1232 0.0007 0.0563 0.0563Cement and Mortar Mixers 0.0447 0.0658 0.0113 0.0001 0.0044 0.0044Cranes 0.6011 1.6100 0.1778 0.0014 0.0715 0.0715Generator Sets 0.3461 0.6980 0.1075 0.0007 0.0430 0.0430Tractors/Loaders/Backhoes 0.4063 0.7746 0.1204 0.0008 0.0599 0.0599Source: (CARB, 2007b) 
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Table A-2. Construction Emissions

Construction Equipment Emissions (tons) Equipment CO NOx VOC SOx PM10 PM2.5Air Compressors 0.0227 0.0479 0.0074 0.0000 0.0034 0.0034Cranes 0.0631 0.1691 0.0187 0.0001 0.0075 0.0075Generator Sets 0.0363 0.0733 0.0113 0.0001 0.0045 0.0045Tractors/Loaders/Backhoes 0.0427 0.0813 0.0126 0.0001 0.0063 0.0063Total Equipment Emissions 0.1648 0.3716 0.0500 0.0003 0.0217 0.0217Painting VOC Content 1.25 lbs/gallon Coverage 400 sqft*/gallon Emission Factor 0.003125 lbs/sqft Building/Facility 

 Wall Surface 

 VOC [lbs] 

 VOC [tons] 

Compressor Housing 1000 3.125 0.0015625 Support Facilities 5000 15.625 0.0078125 Total 6000 18.75 0.009375 Source: (CARB, 2007b) Delivery of Equipment and Supplies Number of Deliveries 2 Number of Trips 2 Miles Per Trip 30 Days of Construction 30 Total Miles 3600 Pollutant (pounds/mile) CO NOx VOC SOx PM10 PM2.5Emission Factor (lbs/mile) 0.0219 0.0237 0.0030 0.0000 0.0009 0.0007Total Emissions (lbs) 79.02 85.37 10.77 0.09 3.08 2.66Total Emissions (tons) 0.0395 0.0427 0.0054 0.0000 0.0015 0.0013Source: (CARB, 2007b) Worker Commutes Number of Workers 20 
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Table A-2. Construction Emissions

Number of Trips 2 Miles Per Trip 30 Days of Construction 30 Total Miles 36000 Pollutant (pounds/mile) CO NOx VOC SOx PM10 PM2.5Emission Factor (lbs/mile) 0.0105 0.0011 0.0011 0.0000 0.0001 0.0001Total Emissions (lbs) 379.74 39.70 38.85 0.39 3.06 1.91Total Emissions (tons) 0.1899 0.0199 0.0194 0.0002 0.0015 0.0010Source: (CARB, 2007b) Total Construction Emissions (tons) Activity/Source CO NOx VOC SOx PM10 PM2.5Construction Equipment 0.1648 0.3716 0.0500 0.0003 0.0217 0.0217Painting 0.0000 0.0000 0.0094 0.0000 0.0000 0.0000Delivery of Equipment and Supplies 0.0395 0.0427 0.0054 0.0000 0.0015 0.0013Worker Commutes 0.1899 0.0199 0.0194 0.0002 0.0015 0.0010Total Construction Emissions 0.3942 0.4341 0.0842 0.0006 0.0248 0.0240

*Note: sqft=square feet 

Table A-3. CO2 Emission Calculations

Drilling and Construction Diesel Fuel Usage 500 Gallons Per DayDrilling Period 90 Days Total Fuel 45000 Gallons Total Fuel 170343 Liters Emission Factor 2.6304 kgCO2 per liter Total Emissions 448070.2 kg Total Emissions 494 Tons Electricity Usage Electricity Usage 6000 kW Hours 26280 Hours 
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Table A-3. CO2 Emission Calculations

Power 157680000 kWh Emission Factor 0.6510 kg CO2/kWh Total Emissions 102649680 kg Total Emissions 113120 Tons Worker Commutes Number of Workers 20 Workers Number of Trips 2 Trips Miles Per Trip 30 Miles Days of Operation 1095 Days Total Miles 1314000 Miles Emission Factor 1.1 lbs/mile Total Emissions 1444785.4 lbs Total Emissions (tons) 722.4 tons Source: (CARB, 2007b)Total CO2 Emissions (tons) Activity/Source Emissions (tons)Drilling and Construction 494 Electricity Usage 113120 Worker Commutes 722 Sequestration (1102300) Total Emissions (987964) 
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Appendix B USFWS Consultation 
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Appendix C Noise Calculations 

Table C-1. Drilling Noise

NSA 1 – Feet MetersCommunity College 1800 549

Octave Band Center Frequency, Hz 

Source 31.5 63 125 250 500 1000 2000 

Drill Rig (@25 Feet) 93 97 94 91 92 91 88 

Power level (PWL) 121 125 123 120 121 120 116 

Transmission Loss (TL) Enclosure (1/2" wood) 0.5 -5.5 -11.5 -17.5 -23.5 -29.5 -35.6 

PWL with enclosure 122 23 17 11 5 -1 -7 

Mud Handling (Shaker and Pump) (@25 Feet) 89 90 88 81 79 78 75 

PWL 118 119 117 110 108 107 104 

Generators (Light Plant) 325 435.5 CF 5 9 3 7 15 19 25 

Exhaust Noise Lw 145.1 140.1 136.1 142.1 138.1 130.1 126.1 120.1 

Muffler 

Correction 25 25 29 29 27 25 24 

 PWL 115.1 111.1 113.1 109.1 103.1 101.1 96.1  CF 4 11 13 13 12 9 8 

Inlet Noise Lw 107.6 PWL 103.6 96.6 94.6 94.6 95.6 98.6 99.6 

 CF 22 14 7 7 8 6 7 

Casing Noise Lw 118.1 PWL 96 104 111 111 110 112 111 

Excavator (@25 Feet) 84 85 81 81 81 78 

PWL 29 113 114 110 110 110 107 

Total Sound Intensity 2.4907 1.0575 1.0167 0.3944 0.2741 0.3185 0.2104 

Total PWL 124 120 120 116 114 115 113 

Hemispherical Spreading -69 -69 -69 -69 -69 -69 -69 Atmospheric Absorption 0 0 0 -1 -2 -3 -5 
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Table C-1. Drilling Noise

Flat Sound Level 55 52 51 47 44 44 40 Octave Band AWeighted Correction -39 -26 -16 -9 -3 0 1 A-Weighted Sound Level 16 26 35 38 41 44 41 Notes: Calculations based on available data from typical equipment set-ups, actual equipment would vary dependent on results of geotechnic

specific design. Lw is sound power levels, CF is center frequency, and Ldn is equivalent day night level. Calculations do not account for effect of topographic features, reflection, and natural barriers 

Table C-2. Compressor Noise

 Feet MetersNSA 1 - Community College 4000 1219

Octave Band Center Frequency, Hz 

Source 31.5 63 125 250 500 1000 2000 4

Reciprocating Compressor 6000.0 CF 11 15 10 11 13 10 5 

Lw 126.5 PWL 116 112 117 116 114 117 122 

Total Sound Intensity 0.3554 0.1415 0.4474 0.3554 0.2242 0.4474 1.4149 0.

Total PWL 116 112 117 116 114 117 122 

Hemispherical Spreading -76 -76 -76 -76 -76 -76 -76 Atmospheric Absorption 0 0 0 -1 -3 -6 -11 Octave Band A-Weighted Correction -39 -26 -16 -9 -3 0 1 A-Weighted Sound Level (without barrier) 1 10 24 30 31 35 36 
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Table C-2. Compressor Noise

Feet Meters

 Critical Distance Calculation 1000 305

Octave Band Center Frequency, Hz 

Source 31.5 63 125 250 500 1000 2000 4

Reciprocating Compressor 6000.0 CF 11 15 10 11 13 10 5 

Lw 126.5 PWL 116 112 117 116 114 117 122 

Total Sound Intensity 0.3554 0.1415 0.4474 0.3554 0.2242 0.4474 1.4149 0.

Total PWL 116 112 117 116 114 117 122 

Hemispherical Spreading -64 -64 -64 -64 -64 -64 -64 Atmospheric Absorption 0 0 0 0 -1 -2 -3 Octave Band A-Weighted Correction -39 -26 -16 -9 -3 0 1 A-Weighted Sound Level (without barrier) 13 22 37 43 46 51 56 
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Appendix D SHPO Consultation 
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Appendix E Contact with the Bureau of Indian Affairs and Tribal Councils 
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Enclosures
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