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.

Oral 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 addition to accepting comments at 

the public hearing, U.S. EPA will 

accept written comments from 

October 2 until Friday, Nov. 7. Send 

your comments 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 for 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 CO2 , 

into a well at its Decatur facility. This well is Carbon Capture and 

Sequestration #1, known as CCS#1. ADM has been injecting CO2 at this well 

since 2011 under a Class I permit issued by the Illinois EPA.

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 

ensures that drinking water sources are protected and that ADM appropriately 

manages both wells.

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

sequestration is a means of reducing greenhouse gas emissions. CO2 is created 

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

before it goes into the air. It is then put under high pressure and turned into a 

liquid so it can be injected deep into the ground through wells.

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

planning. This is to make sure the well works as planned according to local 

geography and geology. Scientists are studying the storage site to make sure

the CO2 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 its decision?

In reviewing ADM’s permit application, U.S. EPA 

evaluated technical information and project-specific 

data, such as: 

 Advanced computational modeling to determine 

the proposed project area.

 The rock layers above and within the formation 

where the CO2 is stored to confirm that the CO2

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 CO2.

 The approach and technologies ADM will use 

to monitor the project until site closure is 

authorized.

 The financial resources ADM will have 

available to responsibly operate, monitor and 

close the project.

 ADM’s approach to ensure that the project will

protect underground sources of drinking water, 

public health and the environment. 

What happens next in the permit process?

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 Repository

The draft permit and fact sheet are available at:

Decatur Public Library

130 N. Franklin St.

Administrative Record

The full administrative record, including all data 

submitted by Archer Daniels Midland Co. in 

support of its permit application, is available for 

public review at 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 additional information, contact Andrew 

Greenhagen at 312-353-7648, 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 

Appeals Board; only after all agency review 

procedures have been exhausted may you file an 

action in the appropriate Circuit Court of Appeals.
Technical background 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 

permits. 

In accordance with 40 CFR 124.8, below is information and 

highlighted permit conditions for the well. 

Area of Review and Corrective Action: In accordance 

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

area surrounding the injection well where any improperly 

sealed, completed or abandoned wells that penetrate the 

confining zone could provide a conduit for fluid migration. 

The AoR for this well has a radius of approximately two 

miles and was delineated pursuant to 40 CFR 146.84(c)(1) 

using a model that predicts the movement of the CO2 plume 

and pressure front based on available information about 

planned injection operations and the subsurface rock 

formations. 

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

within the AoR that penetrate the confining zone. Both 

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

were properly constructed. 

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

AoR by re-running the models at least every five years over 

the life of the project to verify, based on monitoring and 

operating data, that the CO2 plume and pressure front are 

moving as predicted. If there are any changes from 

predictions, ADM must revise the project-specific plans 

described here and U.S. EPA will modify the permit per 40 

CFR 144.39. 

Underground Sources of Drinking Water: USDWs are 

defined by UIC regulations as aquifers or portions thereof 

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 CO2 without fracturing and that the 

confining zone will provide a suitable trap so that the CO2 

will remain in place and USDWs will not be endangered, as 

required under 40 CFR 146.83. 

Construction Requirements: All Class VI wells must be 

constructed with materials and cements that can withstand 

exposure to CO2 and CO2/water mixtures without excessive 

corrosion over the life of the project. Class VI wells must 

also be cased and cemented to prevent the movement of 

fluids into or between USDWs. The 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 CO2 has been injected since CCS#1 began 

operating in 2011. The source of the CO2 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 CO2 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 CO2 plume and 

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

pressure/temperature monitoring) and indirect methods 

(e.g., seismic surveys) to verify that the CO2 plume and 

pressure front are moving as predicted or to provide early 

warning if they are not. 

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 

method, 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 

remedial response measures. 

ADM will use a corporate guarantee to cover these costs 

and demonstrate financial responsibility. The cost estimates 

must be updated within 60 days prior to the anniversary date 

of the establishment of the financial instruments. This 

ensures resources are available to perform these 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 CO2/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 CO2-compatible materials to ensure 

they cannot serve as conduits for fluid movement and will 

restore the site to its original condition by removing all 

equipment and planting vegetation. 

Issuance and Effective Date of Permit: In accordance 

with 40 CFR 124.15, the permit will become effective 

immediately upon issuance if no public comments 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.