### Decatur, Illinois October 

### 2014

You’re invited

U.S. EPA will hold a formal public hearing on the ADM draft permit from

7 to 8 p.m. Wednesday, Nov

. 5 at: Decatur Public Library

130 N. Franklin St

.

Or al and written comments will be recorded or accepted. U.S. EPA will provide a summary of its proposed

decision but will not answer questions during the hearing.



### How to comment

In additi on to accepting comments at the public hearing, U.S. EPA will accept written comments from

October 2 until Friday, Nov. 7

. Send

your c omments to :

Andrew Greenhagen U.S. EPA (WU

- 16J)

77 W. Jackson Blvd. Chicago, IL 60604

- 3590 greenhagen.andrew@epa.gov



### For more information
To learn more, visit: www.epa.gov/region5/water/uic/adm/

For more information, call the U.S.

EPA ’s Chicago regional office toll

- free

at 800

- 621

- 8437, 8:30 a.m.

– 4 :30 p.m., weekdays. 

# Second Carbon Storage Draft

Permit f or Ethanol Facility in

Central Illinois

The U.S. Environmental Protection Agency is accepting comments from the public ( see box, left

) on its intent to issue what the Agency calls a Class VI permit for the Archer Daniels Midland Co

. to inject carbon dioxide , or CO 2 , in to a well at its Decatur facility. This we ll is Carbon Capture and Sequestration #1 , known as CCS#1

. ADM has been injecting CO 2 at th is well

since 2011 under a Class I permit issued by the Illinois E PA

.

U.S. EPA issued a Class VI permit Sept. 23 , allowing ADM to construct the

CCS#2 well. When injection begins at CCS#2, the two wells will essentially

operate as one , and anything required by the draft permit for CCS#1 will be

done in coordination with similar requirements of the CCS#2 permit. This

ensure s that drinking water sources are protected and that ADM appropriately manages both wells.

CO 2 is a greenhouse gas that contributes to climate change. Carbon sequestration is a means of reducing greenhouse gas emissions. CO 2 is created when ADM makes ethanol. In carbon capture and storage, the CO 2 is captured before it goes into the air. It is then put under high pressure and turned into a liquid so it can be injected deep into the ground through wells.

ADM selected the well location after a long period of scientific research and planning. This is to make sure the well w ork s as planned according to local geography and geology. Scientists are studying the storage site to make sure

the CO 2 remains in place. This information will be used to help similar projects in other places.

## See Page 3 for Technical Information on the Draft Permit

How did EPA make it s decision ? In reviewing ADM’s permit application, U.S. EPA

evaluat ed technical information and project

- specific

data

, such as :

 A dvanced computational modeling to determine

the proposed project area.

 The rock layers above and within the formation

where the CO 2 is stored to confirm that the CO 2 will stay where injected.

 The location of drinking water resources near the project and how they will be protected.

 The well ’s construction

.

 The characteristics of the injected CO 2

.

 The approach and technologies ADM will use to monitor the proj ect until site closure is

authorized

.

 The financial resources ADM will have available to responsibly operate, monitor and close the project

.

 ADM’s appro ach to ensure that t he project will protect underground sources of drinking water, public health and the environment.



### What happens next in the permit process? U.S. EPA will review all public comments before making a final decision on granting the permit. The Agency will respond to all comments.

If U.S. EPA decides to issue the final permit, ADM

would be free to conduct Class VI activities as described in the permit. Furthermore, U.S. EPA expects Illinois EPA will make it possible to terminate its Class I permit once the federal Class VI permit becomes effective. 

### Information Repositor y
The d raft permit and fact sheet are available at: Decatur Public Library
130 N. Franklin St.



### Administrative Record The full administrative record, including all data submitted by Archer Daniels Midland Co. in support of its permit application, is available for public review at U.S. EPA’s Chicago regional office. The office is open 8:30 a.m.

– 4:30 p.m.

, weekdays. To review the administrative record

, or for addit ional information

, contact Andrew Greenhagen at 312

- 353

- 7 648

, or greenhagen.andrew @epa.gov

.



### On the Web

For more information about the ADM project , visit www.epa.gov/region5/water/uic/adm

.



### Legal Notice To preserve your right to appeal any final permit decision, you must either participate in the public hearing or send in written comments on the draft permit decision by the end of the comment period

.

The first appeal must be made to the Environmental Ap peals Board; only after all agency review procedures have been exhausted may you file an action in the appropriate Circuit Court of Appeals.

## Technical background on ADM’s carbon storage project

U.S. EPA’s review of ADM’s permit application indicates no significant environmental impact should result from the proposed Class VI activities, so U.S. EPA intends to issue a permit for this well.

Title 40 of the Code of Federal Regulations Parts 144 and 146, require U.S. EPA permits, known as Class VI permits, for carbon storage to specify conditions for the construction, operation, monitoring, reporting, plugging, post-injection site care and site closure of Class VI injection wells to prevent the movement of fluids into any underground source of drinking water, or USDW. See 40 CFR Parts 144 and 146 for the general provisions of underground injection

p ermits.

In accordance with 40 CFR 124.8, below is information and highlighted permit conditions for the well.

Area of Review and Corrective Action: In accordance with 40 CFR 146.84, the Area of Review, or AoR, is the area surrounding the injection well where any improperly sealed, completed or abandoned wells that penetrate the confining zone could provide a conduit for fluid migration. The AoR for this well has a radius of approximately two miles and was delineated pursuant to 40 CFR 146.84(c)(1) using a model that predicts the movement of the CO 2 plume and pressure front based on available information about planned injection operations and the subsurface rock

formations.

Based on a search of well records, there are two wells within the AoR that penetrate the confining zone. Both belong to ADM – CCS#1 and Verification Well #1 – and were properly constructed.

As required at 40 CFR 146.84(e), ADM will re-evaluate the AoR by re-running the models at least every five years over the life of the project to verify, based on monitoring and operating data, that the CO 2 plume and pressure front are moving as predicted. If there are any changes from predictions, ADM must revise the project-specific plans described here and U.S. EPA will modify the permit per 40

CF R 144.39.

Underground Sources of Drinking Water: USDWs are defined by UIC regulations as aquifers or portions thereof that contain less than 10,000 milligrams per liter of total dissolved solids and are being used, or could be used, as a source of drinking water. The base of the lowermost possible USDW in the vicinity of the well, the St. Peter Sandstone formation, is approximately 2,604 feet below the ground surface. Injection and Confining Zone: The Mount Simon formation is the injection zone for this project. Injection occurs between 5,545 feet and 7,051 feet below ground. This zone is separated from the lowest USDW by approximately 2,941 feet of rock, including an impermeable confining zone that will act as barrier to fluid movement. U.S. EPA has reviewed company information, including maps, well logs, cores and the results of seismic surveys, and determined that the regional and local geologic features

at the site will allow the Mount Simon formation to receive and store the injected CO 2 without fracturing and that the confining zone will provide a suitable trap so that the CO 2 will remain in place and USDWs will not be endangered, as required under 40 CFR 146.83.

Construction Requirements: All Class VI wells must be

constructed with materials and cements that can withstand

exposure to CO 2 and CO 2 /water mixtures without excessive corrosion over the life of the project. Class VI wells must also be cased and cemented to prevent the movement of fluids into or between USDWs. The injection well, which was constructed in 2009, meets the criteria of 40 CFR

146.86.

Injection Fluid: Approximately 900,000 metric tons of 99 percent pure CO 2 has been injected since CCS#1 began operating in 2011. The source of the CO 2 is ADM’s biofuel production facility.

Post-Injection Monitoring and Reporting Requirements: In accordance with 40 CFR 146.90 and 146.93, ADM will implement post-injection testing and monitoring, as described in its approved Post-Injection Site Care and Site

Closure Plan.

ADM will monitor the environment near the well to verify that the project and the injected CO 2 are behaving as predicted. ADM must perform groundwater quality monitoring in shallow wells quarterly from the time the permit is issued through the first two years of injection at CCS#2, and every six months after that. ADM must also monitor groundwater quality in deeper wells annually to detect geochemical changes that may be a result of changes

– such as leaching or mobilization of heavy metals and organic compounds or fluid displacement – that could impact USDWs.ADM will also track the movement of the CO 2 plume and pressure front using direct methods (e.g., fluid sampling and pressure/temperature monitoring) and indirect methods (e.g., seismic surveys) to verify that the CO 2 plume and pressure front are moving as predicted or to provide early warning if they are not.

ADM will also be required to demonstrate the integrity of CCS#1 and all monitoring wells at the site throughout the monitoring period. ADM must demonstrate internal mechanical integrity using a pressure test or casing inspection log and external mechanical integrity using a noise log, oxygen activation log, or another approved

m ethod, every five years.

In accordance with 40 CFR 144.54 and 146.91, ADM will submit results of this monitoring to the U.S. EPA annually or within 30 days of the completion of a mechanical integrity test or other required testing.

Emergency and Remedial Response: In accordance with 40 CFR 146.94, ADM developed a site-specific Emergency and Remedial Response Plan that identifies the resources that may be at risk, including USDWs, drinking water wells, the Sangamon River, Bois Du Sangamon Nature Preserve, and Lake Decatur; and infrastructure, including the wellhead, ADM facilities, Richland Community College, Heartland Community Church, residential areas, commercial properties and recreational facilities. The Plan, an enforceable part of the permit, also describes the responses that would be taken to address adverse events, and the staff and equipment available to support this and other such activities. The Emergency and Remedial Response provisions of the permit will facilitate expedient responses and prevent or mitigate harm to the environment, including USDWs should an emergency occur or remediation become necessary.

Financial Responsibility: In accordance with 40 CFR 146.85, ADM has demonstrated, and will maintain, adequate financial responsibility to perform all needed corrective action on wells in the AoR, to plug the injection well, to perform all required post-injection site care and close the site, and to conduct any needed emergency and

r emedial response measures.

ADM will use a corporate guarantee to cover these costs and demonstrate financial responsibility. The cost estimates must be updated within 60 days prior to the anniversary date

of the establishment of the financial instruments. Thisensures resources are available to perform these USDWprotective activities without using public/taxpayer money.

Plugging and Abandonment: In accordance with 40 CFR 146.92, the permit includes an Injection Well Plugging Plan for environmentally protective well closure after monitoring via CCS#1 is complete. The well will be plugged using approved materials that are compatible with CO 2 /water

mixtures to ensure the well will not serve as a conduit for

fluid movement.

Site Closure: In accordance with 40 CFR 146.93, ADM must perform the activities described under “Post-Injection Monitoring and Reporting Requirements” above for at least 10 years and until they can demonstrate, based on monitoring and other site data, that the site does not pose a risk to USDWs and that site closure may be authorized.

Following authorization of site closure, ADM will plug all monitoring wells with CO 2 -compatible materials to ensure they cannot serve as conduits for fluid movement and will restore the site to its original condition by removing all equipment and planting vegetation.

Issuance and Effective Date of Permit: In accordance with 40 CFR 124.15, the permit will become effective immediately upon issuance if no public comments are received that request a change in the draft permit. However, in the event that public comments are received that request a change in the draft permit, then the permit will become effective 45 days after the date of issuance unless the permit is appealed.

In accordance with 40 CFR 144.36(a), the permit will be in effect for the life of the project unless it is otherwise modified, revoked and reissued, or terminated as provided at 40 CFR 144.39, 144.40 and 144.41.