DOE/EA-1828 

Final Environmental Assessment 

Industrial Carbon Capture and Sequestration (ICCS) 

Area 1 Project 

“CO2 Capture from Biofuels Production and Sequestration 

into the Mt. Simon Sandstone” 

Archer Daniels Midland Company 

Decatur, Illinois 

For 

U.S. Department of Energy 

National Energy Technology Laboratory 

DE-FE0001547 

April 2011 

ACKNOWLEDGEMENT 

This report was prepared with the support of the U.S. Department of Energy (DOE) under 

Award No. DE-FE0001547 (Recovery Act - Industrial Carbon Capture and Sequestration (ICCS) 

Area 1 Project/National Energy Technology Laboratory/Office of Fossil Energy). 
INTENTIONALLY LEFT BLANK
COVER SHEET 

Responsible Agency: U.S. Department of Energy (DOE) 

Title: CO2 Capture from Biofuels Production and Sequestration into the Mt. Simon Sandstone 

(DOE/EA-1828D)

Contact: For additional copies or more information about this environmental assessment (EA), 

please contact: 

Mrs. Pierina Fayish 

U.S. Department of Energy 

National Energy Technology Laboratory 

P.O. Box 10940, MS 922-M218 

Pittsburgh, PA 15236 

Facsimile: (412) 386-4775 

E-mail: Pierina.Fayish@netl.doe.gov

Abstract: DOE prepared this EA to evaluate the potential environmental consequences of 

providing a financial assistance grant under the American Recovery and Reinvestment Act of 

2009 (ARRA) in a cooperative agreement with Archer Daniels Midland Company (ADM). If 

ADM received the funding, the company would demonstrate an integrated system of carbon 

dioxide (CO2) capture in an industrial setting and geologic sequestration in a sandstone reservoir. 

The CO2 that would be sequestered is currently a by-product of ADM’s Decatur fuel-grade 

ethanol production facility. ADM would capture approximately one million short tons of CO2

per year using dehydration and compression. The compressed CO2 would be piped 

approximately one mile to an injection well and sequestered in the Mount (Mt.) Simon 

Sandstone Formation, a saline reservoir. The project team members include ADM, the Illinois 

State Geological Survey, Schlumberger Carbon Services, and Richland Community College. 

DOE’s proposed action would provide approximately $141.4 million in financial assistance in a 

cost-sharing arrangement to ADM. The cost of the proposed project would be approximately 

$207.9 million. 

This EA evaluates the environmental resource areas DOE commonly addresses in its EAs and 

identifies no significant adverse environmental impacts for the proposed project. The proposed 

project could result in beneficial impacts to the nation’s energy efficiency and the local 

economy, and could contribute to a minor reduction of greenhouse gases. 

Availability: The draft EA is available on DOE’s National Energy Technology Laboratory 

website at http://www.netl.doe.gov/publications/others/nepa/ea.html and at: 

Decatur Public Library 

130 N. Franklin Street 

Decatur, IL 62523 

(217) 424-2900 
INTENTIONALLY LEFT BLANK 
Industrial Carbon Capture and Sequestration (ICCS) 

Area 1 Project Final Environmental Assessment

Table of Contents i April 2011 

TABLE OF CONTENTS 

LIST OF TABLES ......................................................................................................................... iv

LIST OF FIGURES ....................................................................................................................... iv

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

USE OF SCIENTIFIC NOTATION .............................................................................................. ix

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

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

1.2 Purpose and Need ............................................................................................................. 2

1.3 Related Project ................................................................................................................. 3

1.4 Scope of DOE Decision ................................................................................................... 3

1.5 Legal Framework ............................................................................................................. 5

2.0 PROPOSED ACTION AND ALTERNATIVES ............................................................. 12

2.1 ADM’s Proposed Project ............................................................................................... 12

2.1.1 Project Location ...................................................................................................... 12

2.1.2 Construction ............................................................................................................ 16

2.1.2.1 CO2 Supply ...................................................................................................... 16

2.1.2.2 Pressurized Pipeline ......................................................................................... 16

2.1.2.3 Electrical Substation and Power Lines ............................................................ 17

2.1.2.4 Injection Well .................................................................................................. 17

2.1.2.5 Quantifying the Fate of Injected CO2 .............................................................. 18

2.1.2.6 Monitoring, Verification, and Accounting of CO2 Containment .................... 18

2.1.2.7 Injection Well Surface Facilities ..................................................................... 19

2.1.2.8 Community College Outreach Facility ............................................................ 20

2.1.3 Operations and Maintenance ................................................................................... 20

2.1.3.1 General............................................................................................................. 20

2.1.3.2 Target Zone and Operational Integrity ............................................................ 21

2.1.3.3 Integrity of the Pipeline ................................................................................... 23

2.1.4 Decommissioning ................................................................................................... 24

2.2 Alternatives .................................................................................................................... 24

2.2.1 No-Action ............................................................................................................... 25

2.3 Issues Considered and Dismissed .................................................................................. 25

3.0 THE ENVIRONMENTAL ANALYSIS APPROACH .................................................... 27

3.1 Approach to the Analysis ............................................................................................... 27

3.2 Analysis of Significance................................................................................................. 27

4.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT AND ENVIRONMENTAL 

EFFECTS ...................................................................................................................................... 30

4.1 Air Quality ...................................................................................................................... 30

4.1.1 Description .............................................................................................................. 30

4.1.1.1 Climate and Weather ....................................................................................... 30

4.1.1.2 National Ambient Air Quality Standards and Attainment Status .................... 30

4.1.1.3 Local Ambient Air Quality .............................................................................. 30

4.1.1.4 Existing Facility Emissions ............................................................................. 31

4.1.1.5 Greenhouse Gases and Global Warming ......................................................... 32

4.1.2 Effects of ADM’s Proposed Project ....................................................................... 33

4.1.2.1 Estimated Emissions and General Conformity ................................................ 33
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4.1.2.2 Regulatory Review .......................................................................................... 34

4.1.2.3 Greenhouse Gas Emissions ............................................................................. 34

4.1.3 Effects of No-Action ............................................................................................... 35

4.1.4 Cumulative Effects .................................................................................................. 36

4.2 Geology and Soils .......................................................................................................... 36

4.2.1 Description .............................................................................................................. 36

4.2.2 Effects of ADM’s Proposed Project ....................................................................... 41

4.2.3 Effects of No-Action ............................................................................................... 43

4.2.4 Cumulative Effects .................................................................................................. 43

4.3 Water Resources ............................................................................................................. 43

4.3.1 Description .............................................................................................................. 43

4.3.2 Effects of ADM’s Proposed Project ....................................................................... 44

4.3.3 Effects of No-Action ............................................................................................... 46

4.3.4 Cumulative Effects .................................................................................................. 46

4.4 Wetlands and Floodplains .............................................................................................. 46

4.4.1 Description .............................................................................................................. 47

4.4.2 Effects of ADM’s Proposed Project ....................................................................... 48

4.4.3 Effects of No-Action ............................................................................................... 49

4.4.4 Cumulative Effects .................................................................................................. 49

4.5 Terrestrial Vegetation ..................................................................................................... 49

4.5.1 Description .............................................................................................................. 49

4.5.2 Effects of ADM’s Proposed Project ....................................................................... 50

4.5.3 Effects of No-Action ............................................................................................... 52

4.5.4 Cumulative Effects .................................................................................................. 52

4.6 Wildlife ........................................................................................................................... 52

4.6.1 Description .............................................................................................................. 52

4.6.2 Effects of ADM’s Proposed Project ....................................................................... 53

4.6.3 Effects of No-Action ............................................................................................... 54

4.6.4 Cumulative Effects .................................................................................................. 54

4.7 Land Use ........................................................................................................................ 54

4.7.1 Description .............................................................................................................. 54

4.7.2 Effects of ADM’s Proposed Project ....................................................................... 55

4.7.3 Effects of No-Action ............................................................................................... 56

4.7.4 Cumulative Effects .................................................................................................. 56

4.8 Socioeconomic Resources .............................................................................................. 57

4.8.1 Population ............................................................................................................... 57

4.8.1.1 Description....................................................................................................... 57

4.8.1.2 Effects of ADM’s Proposed Project ................................................................ 58

4.8.1.3 Effects of No-Action ....................................................................................... 58

4.8.1.4 Cumulative Impacts ......................................................................................... 58

4.8.2 Employment and Income ........................................................................................ 59

4.8.2.1 Description....................................................................................................... 59

4.8.2.2 Effects of ADM’s Proposed Project ................................................................ 60

4.8.2.3 Effects of No-Action ....................................................................................... 60

4.8.2.4 Cumulative Impacts ......................................................................................... 61

4.8.3 Infrastructure ........................................................................................................... 61
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Table of Contents iii April 2011 

4.8.3.1 Description....................................................................................................... 61

4.8.3.2 Effects of ADM’s Proposed Project ................................................................ 62

4.8.3.3 Effects of No-Action ....................................................................................... 63

4.8.3.4 Cumulative Impacts ......................................................................................... 63

4.8.4 Parks and Recreation............................................................................................... 64

4.8.4.1 Description....................................................................................................... 64

4.8.4.2 Effects of ADM’s Proposed Project ................................................................ 64

4.8.4.3 Effects of No-Action ....................................................................................... 64

4.8.4.4 Cumulative Impacts ......................................................................................... 64

4.8.5 Visual Resources ..................................................................................................... 65

4.8.5.1 Description....................................................................................................... 65

4.8.5.2 Effects of ADM’s Proposed Project ................................................................ 65

4.8.5.3 Effects of No-Action ....................................................................................... 65

4.8.5.4 Cumulative Impacts ......................................................................................... 65

4.8.6 Noise ....................................................................................................................... 66

4.8.6.1 Description....................................................................................................... 67

4.8.6.2 Effects of ADM’s Proposed Project ................................................................ 68

4.8.6.3 Effects of No-Action ....................................................................................... 70

4.8.6.4 Cumulative Impacts ......................................................................................... 70

4.8.7 Environmental Justice ............................................................................................. 70

4.8.7.1 Description....................................................................................................... 71

4.8.7.2 Effects of ADM’s Proposed Project ................................................................ 71

4.8.7.3 Effects of No-Action ....................................................................................... 71

4.8.7.4 Cumulative Impacts ......................................................................................... 71

4.9 Human Health and Safety .............................................................................................. 72

4.9.1 Description .............................................................................................................. 72

4.9.2 Effects of ADM’s Proposed Project ....................................................................... 73

4.9.3 Effects of No-Action ............................................................................................... 77

4.9.4 Cumulative Effects .................................................................................................. 77

4.10 Cultural Resources ...................................................................................................... 77

4.10.1 Description .............................................................................................................. 78

4.10.2 Effects of ADM’s Proposed Project ....................................................................... 78

4.10.3 Effects of No-Action ............................................................................................... 79

4.10.4 Cumulative Effects .................................................................................................. 79

4.11 Waste Management .................................................................................................... 80

4.11.1 Description .............................................................................................................. 80

4.11.2 Effects of ADM’s Proposed Project ....................................................................... 81

4.11.3 Effects of No-Action ............................................................................................... 82

4.11.4 Cumulative Impacts ................................................................................................ 82

5.0 CONSULTATION AND COORDINATION .................................................................. 83

5.1 Preparation for Development of this Environmental Assessment ................................. 83

5.2 Agency Coordination ..................................................................................................... 83

5.2.1 U.S. Fish and Wildlife Service ............................................................................... 83

5.2.2 State Historic Preservation Office (SHPO) ............................................................. 83

5.2.3 Bureau of Indian Affairs ......................................................................................... 83

5.2.4 State Agencies ......................................................................................................... 83
Industrial Carbon Capture and Sequestration (ICCS) 

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Table of Contents iv April 2011 

6.0 LIST OF PREPARERS..................................................................................................... 85

6.1 Mangi Environmental Group ......................................................................................... 85

7.0 REFERENCES ................................................................................................................. 86

8.0 GLOSSARY ..................................................................................................................... 93

APPENDICES .............................................................................................................................. 98

Appendix A Air Emission Calculations ............................................................................... 98

Appendix B Noise Calculations ......................................................................................... 102

Appendix C USFWS Consultation .................................................................................... 104

Appendix D SHPO Consultation ....................................................................................... 106

Appendix E Consultation with Tribes ............................................................................... 115

Appendix F State Agencies ............................................................................................... 121

Appendix G Environmental Synopsis ................................................................................ 128

Appendix H NWI Online Wetlands Mapper ...................................................................... 140

Appendix I Correspondence with USEPA Region 5 ........................................................ 141

LIST OF TABLES 

Table 1.4. Comparison of Impacts ................................................................................................. 4

Table 3.2. Impact Significance Thresholds .................................................................................. 28

Table 4.1.1.3. NAAQS and Monitored Air Quality Concentrations ........................................... 31

Table 4.1.1.4. Existing (2009) Air Emissions for Decatur ADM Complex ................................ 32

Table 4.1.2.1. Proposed Project Emissions Compared to Applicability Thresholds ................... 34

Table 4.1.2.3. Net CO2 Emissions for ADM’s Proposed Project ................................................ 35

Table 4.8.2.1. Household Income for 2008 ................................................................................. 59

Table 4.8.3.2-1. Well Construction Transport Estimate for the Injection Well ........................... 62

Table 4.8.3.2-2. Transport Estimate for the Substation Construction ......................................... 62

Table 4.8.3.2-3. Transport Estimate for the National Sequestration Education Center Building 

Construction .................................................................................................................................. 63

Table 4.8.6-1. Common Sounds and Their Levels ...................................................................... 66

Table 4.8.6-2. State of Illinois Environmental Noise Standards .................................................. 67

Table 4.8.6.1. Estimated Existing Noise Levels at Nearby Noise Sensitive Areas ..................... 68

Table 4.8.6.2-1. Noise Levels Associated with Outdoor Construction ....................................... 68

Table 4.8.6.2-2. Compressor Noise Levels at Nearest NSA Compared to Noise Standards ....... 69

Table 4.9.1. Comparison of Natural Gas Pipelines to CO2 Pipelines from 1995 to 2005 ........... 73

Table A-1. Drilling Emissions ..................................................................................................... 98

Table A-2. Construction Emissions ............................................................................................. 99

Table A-3. CO2 Emission Calculations ...................................................................................... 101

Table B-1. Drilling Noise .......................................................................................................... 102

Table B-2. Compressor Noise .................................................................................................... 103

LIST OF FIGURES 

Figure 2.1.1-1. Regional Vicinity Map ........................................................................................ 14

Figure 2.1.1-2. Project Area Map ................................................................................................ 15

Figure 4.2.1-1. Illinois Basin’s Stratigraphic Column of Key Formations for CO2 Injections ... 37

Figure 4.2.1-2. Map of Soil Types over the ADM ICCS Facility Site ........................................ 40
Industrial Carbon Capture and Sequestration (ICCS) 

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Table of Contents v April 2011 

Figure 4.4.1. Floodplains near the ADM ICCS Site .................................................................... 48
Industrial Carbon Capture and Sequestration (ICCS) 

Area 1 Project Final Environmental Assessment

Acronyms and Abbreviations vi April 2011 

ACRONYMS AND ABBREVIATIONS 

μg/m3 Micrograms per Cubic Meter 

μS/cm Microsiemens per Centimeter 

°C Degrees Celsius 

°F Degrees Fahrenheit 

2D Two Dimensional 

3D Three Dimensional 

A.M. ante meridiem (i.e. before noon)

ADM Archer Daniels Midland Company 

ARRA American Recovery and Reinvestment Act of 2009 

AQCR Air Quality Control Region 

AQCR 075 West Central Illinois Intrastate AQCR 

BMP Best Management Practice 

CAA Clean Air Act 

CCAR California Climate Action Registry 

CCS Carbon Capture and Sequestration 

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 Centimeters 

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 

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 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 

ft Feet 

ft2

 Square Feet 
Industrial Carbon Capture and Sequestration (ICCS) 

Area 1 Project Final Environmental Assessment

Acronyms and Abbreviations vii April 2011 

ft3 Cubic Feet 

GHG Greenhouse Gas 

H2S Hydrogen Sulfide 

HAPs Hazardous Air Pollutants 

HFCs Hydrofluorocarbons 

hp Horsepower 

Hz Hertz 

i.e. id est, that is 

IAC Illinois Administrative Code 

ICCS Industrial Carbon Capture and Sequestration 

IEPA Illinois Environmental Protection Agency 

IHPA Illinois Historic Preservation Agency 

IL Illinois 

ILCS Illinois Compiled Statutes 

IPCC Intergovernmental Panel on Climate Change 

ISGS Illinois State Geological Survey 

kg Kilograms 

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 Millidarcies 

MDT Modular Formation Dynamics Tester 

MEA Mono Ethanol Amine 

MGSC Midwest Geological Sequestration Consortium 

Mt. Mount 

MVA Monitoring, Verification, and Accounting 

MW Megawatt 

N2O Nitrous Oxide 

NAAQS National Ambient Air Quality Standards 

NEPA National Environmental Policy Act 

NESHAP National Emission Standards for Hazardous Air Pollutants 

NETL National Energy Technology Laboratory 

NHPA National Historic Preservation Act 

NO2 Nitrogen Dioxide 

NOx Nitrogen Oxides 

NPDES National Pollutant Discharge Elimination System 

NRHP National Register of Historic Places 
Industrial Carbon Capture and Sequestration (ICCS) 

Area 1 Project Final Environmental Assessment

Acronyms and Abbreviations viii April 2011 

NSA Noise Sensitive Area 

NSPS New Source Performance Standards 

NSR New Source Review 

O3 Ozone 

OSHA Occupational Safety and Health Administration 

P.M. post meridiem (i.e. after noon) 

Pb Lead 

PEMAf Palustrine emergent temporarily or semi-permanently flooded wetland 

PFCs Perfluorocarbons 

PM10 Particulate Matter of 10 Micrometers or Less in Aerodynamic Diameter 

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

ppb Parts per Billion 

ppm Parts per Million 

ppmv Parts per Million by Volume 

PSD Prevention of Significant Deterioration 

psi Pounds per Square Inch 

psig Pounds per Square Inch Gauge 

PWL Power Level 

RCC Richland Community College 

RCRA Resource Conservation and Recovery Act 

Rd. Road 

Recovery Act American Recovery and Reinvestment Act of 2009, Public Law 111-5 

RRA Resource Rich Areas 

SDWA Safe Drinking Water Act 

sec Seconds 

SF6 Sulfur Hexafluoride 

SHPO State Historic Preservation Office or Officer 

SIP State Implementation Plan 

SO2 Sulfur Dioxide 

SOx Sulfur Oxides 

TEG Triethylene Glycol 

TL Transmission Loss 

TMDL Total Maximum Daily Load 

tpy Tons per Year 

U.S. United States 

UIC Underground Injection Control 

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 

USGS U.S. Geological Survey 

VOC Volatile Organic Compounds 

VSP Vertical Seismic Profile 
Industrial Carbon Capture and Sequestration (ICCS) 

Area 1 Project Final Environmental Assessment

Use of Scientific Notation ix April 2011 

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 

 

10-3 

 = 

1 = 0.001 10 x 10 x 10 

 

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. 
Industrial Carbon Capture and Sequestration (ICCS) 

Area 1 Project Final Environmental Assessment

Introduction 1 April 2011 

1.0 INTRODUCTION 

1.1 Summary 

High concentrations of carbon dioxide (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 in 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), 

believe there a danger from even a modest increase in the Earth’s temperature (called “global 

warming”) as it 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) funds projects that would demonstrate the capture of CO2 from industrial sources 

and subsequent geologic sequestration of the captured gas. 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. 

Congress appropriated significant funding for Industrial Carbon Capture and Sequestration 

(ICCS) in the American Recovery and Reinvestment Act of 2009, Public Law 111-5 (Recovery 

Act) in order to stimulate the economy and reduce unemployment in addition to furthering 

DOE’s ICCS program. DOE solicited applications for this funding by issuing a competitive 

Funding Opportunity Announcement (DE-FOA-0000015), Carbon Capture and Sequestration 

from Industrial Sources and Innovative Concepts for Beneficial CO2 Use on June 8, 2009. The 

announcement invited applications in two areas of interest: (1) large-scale industrial carbon 

capture and sequestration (CCS) projects from industrial sources, and (2) Innovative concepts for 

beneficial CO2 use. The application period closed on August 7, 2009, and DOE received 92 

proposals across the two areas of interest. DOE selected 24 projects based on the evaluation 

criteria set forth in the funding opportunity announcement. Only 23 projects received awards. 

This project, CO2 Capture from Biofuels Production and Sequestration into the Mount (Mt.) 

Simon Sandstone, was one of the projects DOE selected for Phase I funding in Area of Intent 1. 

In Phase I, awardees received funding to perform administrative work to complete a Phase II 

proposal. Phase II projects were then competitively selected from the pool of Phase I awardees. 

This project was one of nine selected for a Phase II award. One part of the Phase II selection 

process considered potential environmental impacts of all responsive applications pursuant to 10 

Code of Federal Regulations (CFR) § 1021.216. 

DOE’s Proposed Action is to provide $141.4 million in financial assistance in a cost sharing 

arrangement with the project proponent, Archer Daniels Midland Company (ADM). The total 

cost of the project is estimated at $207.9 million. 
Industrial Carbon Capture and Sequestration (ICCS) 

Area 1 Project Final Environmental Assessment

Introduction 2 April 2011 

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, requires NETL to 

review and, where possible, mitigate projected impacts to global climate change caused 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. The focus 

of NETL’s “Carbon Capture and Sequestration from Industrial Sources and Innovative Concepts 

for Beneficial CO2 Use” initiative 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 NETL 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 porous and permeable subsurface rock 

formations in such a way that they remain permanently stored. 

The purpose of the proposed ADM project would be to demonstrate the ability of the Mt. Simon 

Sandstone to accept and retain one million short tons per year or approximately 2.5 million short 

tons (2.26 million metric tons) of CO2 injected over a period of 2.5 years (ADM, 2009a); thus 

testing large-scale sequestration sooner than might otherwise be possible. 

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

additional research and demonstration 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 from large-scale injections is necessary to validate the models and 

demonstrate that scientific understanding is correct (DOE, 2003). 

Two-thirds of the United States has deep saline formations beneath it. 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 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 resolve uncertainties associated with the 

reactions that may occur between CO2, brine, and minerals in the surrounding strata (DOE, 

2007a). 

The project, under carefully controlled and monitored conditions, would 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 
Industrial Carbon Capture and Sequestration (ICCS) 

Area 1 Project Final Environmental Assessment

Introduction 3 April 2011 

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). 

If funded, the proposed project 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 development of large scale 

projects 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 multiple high volume injection at a scale similar to what would 

be done if CO2 from power plants were captured and sequestered. 

1.3 Related Project 

ADM’s Decatur ethanol plant is the host site for another DOE project, Midwest Geological 

Sequestration Consortium (MGSC) Phase III Large-Scale Field Test (DE-FC26-05NT42588). 

That project was the subject of a separate environmental assessment (EA) (DOE/EA-1626) that 

resulted in a finding of no significant impact (FONSI) dated November 28, 2008. 

The proximity of the two projects requires the analysis of any cumulative impacts on the 

environment from the current MGSC project and proposed ICCS project. Cumulative impacts 

are addressed under each resource area in Chapter 4 of this document. 

1.4 Scope of DOE Decision 

The decision for DOE is to either fund or not fund the proposed project including the associated 

drilling and injection activities. The No-Action Alternative would be no DOE funds provided to 

ADM for its proposed project, and ADM would not pursue the drilling and injection activities if 

DOE’s decision was to not fund the project. Thus, the No-Action Alternative would involve no 

drilling and injection activities. Table 1.4 below is based on that premise. 
Industrial Carbon Capture and Sequestration (ICCS) 

Area 1 Project Final Environmental Assessment

Introduction 4 April 2011 

Table 1.4. Comparison of Impacts 

Resource No-Action Alternative ADM’s Proposed Project 

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 project 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 (see 

Section 4.2.2). 

Water Resources No impacts The proposed project 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/Floodplains 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. 

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. 
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Table 1.4. Comparison of Impacts 

Resource No-Action Alternative ADM’s Proposed Project 

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. 

Visual Resources No impacts The proposed project 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 low- income 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.

1.5 Legal Framework 

DOE has prepared this EA in accordance with the Council on Environmental Quality (CEQ) 

“Regulations for Implementing the Procedural Provisions of the National 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 
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Introduction 6 April 2011 

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 to prepare an 

Environmental Impact Statement (EIS) or a 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 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 

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 
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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. 

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. 

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. 
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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 

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 
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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 Fish 

and Wildlife Service (USFWS) 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 

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 
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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 meters (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. 

 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 
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 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 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 

DOE’s Proposed Action is to provide ADM with $141.4 million in financial assistance in a costsharing arrangement to demonstrate the ability of the Mt. Simon Sandstone, a major regional 

saline reservoir in the Illinois Basin, to accept and retain approximately 2.5 million short tons of 

CO2 injected over a period of 2.5 years (ADM, 2009a). This Proposed Action would also 

meaningfully assist in the nation’s economic recovery by creating jobs in the United States in 

accordance with the objectives of the Recovery Act. 

2.1 ADM’s Proposed Project 

The objective of the proposed project evaluated in this EA is to demonstrate an integrated system of 

CO2 capture in an industrial setting and geologic sequestration in a sandstone reservoir. The CO2

that would be sequestered is currently a by-product in ADM’s Decatur fuel-grade ethanol 

production facility. ADM would capture approximately one million tons of CO2 per year using 

dehydration and compression. The compressed CO2 would be piped approximately one mile to 

an injection well and sequestered in the Mt. Simon Sandstone Formation, a saline reservoir. 

The proposed project would include the construction of a compression/dehydration facility, 

approximately 5,290-feet (1,611 m) of 8-inch pipeline, 1,224 feet (373 m) of 24-inch pipeline, 

one electrical substation, up to 4.67 miles (7.52 kilometer (km)) of electrical power line, one

injection well with associated equipment, and one verification well for monitoring of the 

sequestered CO2 (ADM, 2010a; ADM, 2010b). The project would also include construction of a 

12,000 ft2 (1,115 m2) building on the Richland Community College Campus – the National 

Sequestration Education Center (NSEC), a center for outreach and education that will be 

operated by and eventually owned by the College. The compression facility has a design capacity 

to capture and condition 2,183 short tons (1,980 metric tons) per day of biogenically produced CO2

from the ADM biofuels production plant. An additional 1,091 short tons (990 metric tons) per day of 

CO2 from the MGSC project will be included when that project completes its injection period in the 

first quarter of 2014. The project would not operate continuously at its design capacity and overall 

project production levels would be targeted at a carbon capture and storage goal of up to one million 

short tons (0.9 million metric tons) per year by 2014. The captured CO2 would be compressed, 

transported via pipeline to the injection well, and injected into the Mount Simon Sandstone reservoir 

for permanent geologic sequestration. 

The proposed project would continue to refine previously developed Monitoring, Verification, 

and Accounting (MVA) 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 accounted for (DOE, 2008). 

2.1.1 Project Location 

The project 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 
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Proposed Action and Alternatives 13 April 2011 

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

supercritical fluid from the compression/dehydration facility to the injection well following, as 

much as possible, an existing pipeline corridor that transfers steam to the Richland Community 

College campus. 

The ADM ICCS Site infrastructure would be integrated into the current footprint of the Decatur 

ADM Complex and would be constructed north of the railroad tracks and south of the MGSC 

injection well (ADM, 2009b). No space outside the existing Decatur ADM Complex footprint 

would be required for the compression/dehydration facility, except for a 200-foot (61 m) pipeline 

easement on the Richland Community College property. 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 (DOE, 2008). 
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Proposed Action and Alternatives 14 April 2011 

Figure 2.1.1-1. Regional Vicinity Map 

ADM ICCS Site 
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Proposed Action and Alternatives 15 April 2011 

Figure 2.1.1-2. Project Area Map 
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Proposed Action and Alternatives 16 April 2011 

2.1.2 Construction 

Proposed new construction would include the construction of a compression/dehydration facility, 

approximately 5,290-feet (1,611 m) of 8-inch pressurized pipeline, 1,224 feet (373 m) of 24-inch 

pipe carrying CO2 at approximately 10 pounds per square inch gauge (psig), one electrical 

substation, up to 4.67 miles (7.52 km) of electrical power line, and one injection well with 

associated equipment. The facility would include the CO2 treatment, compression, and 

dehydration equipment necessary to condition the CO2 from the ADM ethanol production plants. 

The facility would be capable of delivering approximately 1.0 million short tons per year. The 

pipeline would deliver the CO2 from the compression/dehydration facility to the injection well 

(ADM, 2009a; ADM, 2010b). 

2.1.2.1 CO2 Supply 

The proposed sequestration site at the ADM facility will be supplied with 99 percent pure CO2

from the ethanol production part of ADM’s operations. The CO2 will be moisture laden and at 

atmospheric pressure from the fermentation vessels, so it will need to be dehydrated and 

compressed to approximately 2500 pounds per square inch (psi) and delivered to the wellhead as 

supercritical CO2. 

A 24-inch (61 centimeter (cm)) 1,224-ft pipe will carry the CO2 at approximately 10 psig from 

the outlet of the booster gas blower to the dehydration/compression facility. The 

dehydration/compression facility is proposed near the northern boundary of the ADM facility. 

The CO2 will be dehydrated, compressed to approximately 2500 psig and 95 degrees Fahrenheit 

(F) , and then moved about 5,290-feet through an 8-inch (15.24 cm) pipe to the injection well 

location. That well location will be on a tract of approximately 207 acres, also owned by ADM 

and located adjacent to their plant (ADM, 2010b). 

Outlet CO2 streams from ethanol fermentor vents are typically 99% + pure CO2, saturated with 

water vapor at 80 degrees Fahrenheit (°F) and atmospheric pressure. Common impurities are 

ethanol and nitrogen in the range of 600 to 1000 parts per million by volume (ppmv) each. Other 

impurities in lesser amounts often include oxygen, methanol, acetaldehyde, and hydrogen 

sulfide. Early compositional analysis of the source stream has aided in the equipment selection 

and materials specification. 

2.1.2.2 Pressurized Pipeline 

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

injection site would be an 8-inch diameter schedule 40 or 80 steel pipe designed to meet 

standards for the temperature and pressure of the CO2 stream. The pressurized pipeline length 

would be approximately 5,290-foot (ADM, 2010b). The first 4,000 feet of the pipeline would be 

installed aboveground using existing pipe bridges and racks, and following the current pipeline 

alleys at the Decatur ADM Complex (Figure 2.1.1-2). The pipeline would be located on Decatur 

ADM Complex property, until it reaches Reas Bridge Road just south of Richland Community 

College (RCC). At this point, the pipeline will be routed underground and will use RCC’s 

property easement for about 200 feet (ft) until the pipeline reaches the ADM property line. The 
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Proposed Action and Alternatives 17 April 2011 

pipeline would continue underground until it reaches the injection well (1,100 ft). The pipeline 

alignment would follow as much as possible the current pipeline alleys or easements that deliver 

steam to the Richland Community College campus (ADM, 2010b). 

2.1.2.3 Electrical Substation and Power Lines 

A 100MW Electrical Substation with an area of 250,000 square feet (ft2) (23,225 square meters 

(m2

)) would be constructed and located on the former golf course (ADM land) east of the ADM 

plant. The substation construction will include electrical power lines that connect the substation 

with the existing power grid. The power lines will follow one of two possible corridors to make 

this connection as shown on Figure 2.1.1-2. The power line routing shown as Alternative A 

would be 4.67 miles (7.52 km) in length. Alternative B routing would be 4.25 miles (6.8 km) in 

length. The substation would be constructed within the ADM property. Power lines would be 

constructed either on ADM property or using utility easements that would be obtained from 

property owners. 

2.1.2.4 Injection Well 

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

industrial complex and east of the Richland Community College campus (Figure 2.1.1-2). 

Previously, this field was used for agriculture and agricultural expositions that have left simple 

unoccupied structures on the injection site. The proposed injection rate is approximately one 

million short tons per year of supercritical CO2 (ADM, 2010a, ADM, 2010b). 

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 determined based on well logs, core samples, and drill stem tests from the initial well 

drilled on the site prior to injection (DOE, 2008). 

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

analyses suggest that an 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 up to one million 

short tons a year injection rate into the injection tubing. Although subsurface information will be 

available from the MGSC project, pre-drilling modeling may be revised once well logs and core 

samples are recovered from the injection and reservoir monitoring well installation. Perforating 

the well casing would occur in the Mt. Simon formation before CO2 injection begins, assuming 

identification of a high 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 (DOE, 

2008). 

The installation, operation, and eventual closure of the injection well is carefully governed by a 

regulatory program—the UIC permit program administered by USEPA, and delegated to 

qualified states such as the state of Illinois. ADM currently has a Class I – Non-Hazardous area 

permit for CO2 injection. 
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ADM is in discussion with US EPA Region 5 and Illinois EPA regarding a permitting path 

forward and will comply with all Class VI injection well regulations. 

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 

Underground Source of Drinking Water (USDWs) by addressing the potential pathways through 

which injected fluids can migrate into USDWs. These programmatic components are most 

recently described in a proposed rule for Class VI injection wells, published in the Federal 

Register, Volume 74, Number 167 on Monday, August 31, 2009. 

2.1.2.5 Quantifying the Fate of Injected CO2

Pressure and gas composition in the well annulus can be continuously monitored to determine 

the integrity of the injection string and the packer inside the casing used to isolate the injection 

zone from the remainder of the well. Changes in pressure or composition can be rapidly detected 

using pressure sensors or analyzers and the well shut-in to determine the cause of the change. 

The verification well drilled near the injection well will allow sampling of reservoir fluids as 

well as track the downhole temperature and pressure. This will allow for monitoring of the 

interaction of the CO2 with the formation. While it will probably be too early to identify 

mineralization of the CO2 (via cores) in these wells, ADM should be able to get information on 

the fate of the CO2 as it interacts with the formation water. In addition, time-lapse fluid 

sampling from these wells will allow detailed geochemical analysis of the CO2/saline water 

interaction. 

The impact of NaCl concentrations on CO2 solubility is well known and is shown in Duan and 

Sun (2003) and Duan, Sun, Zhu, and Chou (2006). Injected supercritical CO2 will be partitioned 

between the injected free phase, CO2 trapped by capillary forces to develop a residual saturation 

of CO2, and CO2 that will dissolve in the brine. The effects can be readily modeled both in 

advance and, more accurately, once the injection well is drilled and site-specific data are 

collected. 

Cement integrity measurements would be run periodically to determine the status of the bond 

between the rock and the well casing. Advanced ultrasonic devices can be used for more 

detailed analysis: characterization of formation/cement and cement/casing interfaces, hydraulic 

communication maps, and monitoring of the cement degradation. Casing and tubing corrosion 

can be estimated using a variety of measurements. 

2.1.2.6 Monitoring, Verification, and Accounting of CO2 Containment 

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

period, data developed from the MGSC injection and reservoir monitoring wells drilled 
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approximately 1 mile from the proposed injection site, data developed from the ICCS projects 

injection and reservoir monitoring wells, data collected when the MGSC project begins injection 

and from data collected when the ICCS project begins injection. During Phase 1 of this project, 

the project team has characterized 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. During Phase 2 of this project, the project team will conduct a 

full three-dimensional (3D) seismic survey to provide additional detail of the geological structure 

at the site and better predict the CO2 plume shape and development. Next, the injection 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, when combined with information produced for 

the MGSC project, would enable better understanding of injected CO2 distribution and potential 

reactivity of the CO2 and CO2-laden brine with the reservoir and the seals. 

The extent of the plume movement would be calculated through the dynamic model after the 

input of every new data point. Continuous monitoring of downhole pressure will provide 

valuable input to the model on a frequent scale. Periodic monitoring with a visual sampling 

program will allow frequent updating with relevant plume migration imaging. Time-lapse 

logging in all wells, along with the full complement of monitoring and verification technologies, 

will be input to the dynamic model as acquired, and the model tuned to fit the data. The 

Monitoring, Verification and Accounting (MVA) program proposed for this project would allow the 

extent of the plume aerial to be assessed periodically (ADM, 2009a). 

Microseismicity is commonly used for hydrofrac monitoring in the oil and gas industry. In low 

permeability formations, real-time microseismicity events detection allows imaging the fracture 

extension to help controlling injection parameters (pressure and rate) to avoid fracturing the caprock. Fracture propagation and geomechanical models can be calibrated by comparing 

observations and predictions. Temperature contrast between the injected CO2 and the formation 

may favor the failure of completion components, which may also lead to microseismic events 

(ADM, 2009a). 

The monitoring of the environment is essentially focused on the detection of leaks, either directly 

by monitoring CO2 concentration and fluxes (together with other fracture-pathfinder geogas), or 

indirectly by measuring their consequences on the environment. This involves measurements in 

shallower formations (aquifers, vadose zone, surface, or atmosphere). 

The project will also employ a combination of direct air sampling and electronic monitors to 

measure near surface CO2 concentrations and along with simple air safety detectors based on 

OSHA standards. 

2.1.2.7 Injection Well Surface Facilities 

Temporary facilities and improvements would be constructed or placed at the ground surface 

within a 300 feet (91.44 m) by 300 feet 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. At the conclusion of the well construction the temporary facilities 
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would be removed leaving only an access road and pad around the injection wellhead. The site 

would be fenced off and monitored daily. During well construction the temporary facilities 

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), 

 20 parking stalls, 

 Three operations trailers, 

 An office/conference room facility, and 

 A communications shack. 

2.1.2.8 Community College Outreach Facility 

The ICCS project will also include construction of a building on the Richland Community 

College Campus – the National Sequestration Education Center (NSEC), a center for outreach 

and education that will be operated by and eventually owned by the College. This 12,000 ft2

(1,115 m2) building will be located at the entrance to the developed (Farm Progress Site) area 

north of the Richland Community College Campus. 

2.1.3 Operations and Maintenance 

2.1.3.1 General 

The proposed total project period injection of approximately 2.5 million short tons of 

supercritical CO2, at the rate of up to one million short tons per year would use the Mt. Simon 

formation as a target storage zone. Injection would be by one well at the Decatur ADM 

Complex. There is one operating 88-foot deep hydrocarbon well site near the Decatur ADM 
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Complex, and the closest known penetration of the Mt. Simon formation is the MGSC injection 

and reservoir monitoring well located north of the compression/dehydration facility. These wells 

are beyond the radius of influence (1,250 feet (381 m)) of the proposed injection well. 

Prior to injection, the CO2 stream would need to be dewatered and compressed. The minimum 

compression is to the critical point of CO2, which is 88 °F (31.1 degrees Celsius (°C)) and 73 

atmospheres pressure (7,395 kilopascals (kPa)). 

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, and it will be 

carefully controlled in view of the high pressure of the system proposed. 

All well construction materials will be acid-resistant and are duplicates of those used in the 

MGSC well, which uses CO2-resistant cement across the reservoir and primary seal, and 13-

chrome steel casing in the lower 2,000 ft of the injection and seal zone and in the entire length of 

the injection tubing. The packer utilized will also be constructed of CO2-resistant metals and 

special elastomers rated for CO2 service. 

Non-potable saline water is produced during drill stem testing and on-going sampling from the 

verification well (DOE, 2008). In addition, water byproduct 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 triethylene glycol (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 compressors and noise-generating equipment 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 project 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 are 

addressed by design considerations of the compression-dehydration system. Corrosion 

monitoring would be an integral part of the operations of the aboveground facilities. Once 

operational without significant corrosion, the compression-dehydration system would be a 

simple operation with little environmental impact. 

Target Zone

The chosen target zone is the Mt. Simon formation. The estimated top of the Mt. Simon 

formation is between 5,000 and 6,000 feet (1.52 – 1.83 km) at the Decatur ADM Complex 

(DOE, 2008). It is very thick sandstone, overlain by the impermeable Eau Claire shale 

formation. The estimated Eau Claire thickness is 300-500 feet (91.44 – 152.40 m) in the 

injection area. Further, impermeable confining formations are the Maquoketa shale (about 2,500 
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feet (762 m) below grade) and at lesser depth still the New Albany shale (1,800 feet (548.64 m) 

below land surface). 

Unlike the MGSC carbon sequestration project, there is no need to set aside a long leading time 

period for the evaluation of the target zone, selection of the injection zone within the Mt. Simon 

formation, and construction of infrastructure and facilities prior to commencing project 

operations. A significant amount of data has been acquired to characterize the target zone during 

the MGSC project as well as the ICCS project Phase 1 and planned activity during the Phase 2 

design and construction periods. 

The ICCS well has a close enough proximity (less than 1 mile from the MGSC Phase 3 injection 

and monitoring wells) that the information developed from the MGSC project (well cores and 

logs) should be similar and applicable to the ICCS well. The ADM project will confirm 

parameters of porosity and permeability, but the time required for this evaluation is significantly 

reduced from what was required for the MGSC project. 

The distance between the two project’s injection wells is approximately 1 mile; therefore, no 

significant differences between the two sites have been observed or are expected. Additionally, 

the MGSC project should be in the operation period (injecting) for approximately one year 

before operations commence for the ICCS project. Because of these factors, the ICCS project 

has no requirement for additional data acquisition or monitoring to occur between the 

construction (drilling) and operational (injection) period. 

Since CO2 would likely rise within the sandstone, it could do the following (ADM, 2008). 

 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. Models of one million metric 

tonnes of injected CO2 after a one hundred year post-injection period show that injected 

CO2 will not reach the base of the Eau Claire shale making the long-term potential for 

dissolution of the shale highly unlikely. 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. Prior to injection well operation, 

ADM 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 UIC permit 

modification. 
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Tests of the Mt. Simon Formation

Site-specific geologic information has been developed for the MGSC carbon sequestration 

project. The evaluation of data collected during drilling, evaluation, and initial operation of the 

MGSC injection well would be used to determine final depths of injection and operational 

conditions for the ICCS project. Geologic, geomechanical, and operational information collected 

during well installation, evaluation, and operation 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. 

2.1.3.3 Integrity of the Pipeline 

System pressure would be monitored closely, as a loss of pressure is indicative of loss of the CO2

supercritical fluid (DOE, 2008). 

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, and release of a large gas cloud as the supercritical fluid is 

converted to CO2 gas. The gas is nontoxic, 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 (DOE, 2008). 

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 has significant past experience compressing, treating, and handling CO2 liquids. ADM has 

a well established emergency response plan that coordinates with the appropriate external 

agencies and is aligned with the needs of an integrated manufacturing complex. These 

established procedures will be applied and, if needed, modified to suit the needs of this specific 

process, therefore ADM will have contingency and maintenance plans to avoid and to respond to 

leaks, explosions, and overpressure events. 
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The process control system for the CO2 compression facility is designed to prevent and to alert 

operations personnel in the event of a significant deviation of the normal operating process 

parameters (e.g., CO2 temperature, pressure, and flow). For example, in the event of an 

overpressure event, the process control system will automatically spillback CO2 to the first stage 

of compression reducing the flow to the injection well. If the over pressure situation persists, the 

control system will open the atmospheric vent to bring the pressure down. During this period, 

the operations personnel will receive numerous alarms alerting them of the process deviation 

allowing them the opportunity to take corrective actions. 

In the event of a failure, the compression facility will be equipped with emergency stops and 

automated isolation valves that will allow operations personnel to quickly shutdown, isolate, and 

depressurize the unit. These and other systems along with personnel trained on the unit specific 

operating and maintenance procedures will promote safe operation of the plant. Additionally, all 

unit operations and maintenance personnel will be given safety and emergency response training 

prior to commissioning the unit. 

This facility will be designed and constructed to meet appropriate ASME standards, e.g., the 

process piping will be designed in conformance with the ASME B31.3 standard. Existing 

standards that govern mechanical integrity (e.g. API 510) were developed for facilities 

processing flammable and reactive materials. This facility will be processing CO2 which is non 

flammable and non reactive, therefore these standards are not appropriate for this process 

service. Because ADM understands the hazards that compressed CO2 presents and to insure the 

mechanical integrity of the facility, maintenance and inspection procedures will be developed 

that will cover the future operation of the CO2 compression and transmission infrastructure. 

Emergency response and mechanical integrity testing specific to the sub surface facility 

(injection well bore), has been developed and is detailed in the UIC permit’s Appendices. 

2.1.4 Decommissioning 

ADM would have two choices available to them: 

First, they may decide to continue the sequestration project as part of their ongoing operations. 

In that case, regulatory approval would be obtained as necessary. 

Second, if they do not choose to continue or if the demonstration project has not shown 

unequivocally favorable results, the plant site does not require decommissioning immediately. 

However, the well would have to be abandoned, and the pipeline could be abandoned in place or 

the aboveground sections removed. Well abandonment would be according to Illinois 

Environmental Protection Agency (IEPA) UIC regulations. All decommissioning would be done 

in compliance with applicable laws and regulations. 

2.2 Alternatives 
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DOE’s alternatives to this project consist of the 83 technically acceptable applications received 

in response to the Funding Opportunity Announcement, Carbon Capture and Sequestration from 

Industrial Sources and Innovative Concepts for Beneficial CO2 Use. Prior to selection, DOE 

made preliminary determinations regarding the level of review required by NEPA based on 

potentially significant impacts identified in reviews of acceptable applications. DOE conducted 

these preliminary environmental reviews pursuant to 10 C.F.R. § 1021.216. These preliminary 

NEPA determinations and reviews were provided to the selecting official, who considered them 

during the selection process. A synopsis of the potential environmental consequences of the 

proposed projects is attached as Appendix G, in accordance with 10 C.F.R. § 1021.216 (h). 

Because DOE’s Proposed Action is limited to providing financial assistance in cost-sharing 

arrangements to projects submitted by applicants in response to a competitive funding 

opportunity, DOE’s decision is limited to either accepting or rejecting the project as proposed by 

the proponent, including its proposed technology and selected sites. DOE’s consideration of 

reasonable alternatives is therefore limited to the technically acceptable applications and a noaction alternative for each selected project. 

2.2.1 No-Action 

DOE’s provision of cost sharing in ADM’s proposed project is the Federal action that brings 

the proposed project under NEPA. Under the No-Action alternative, DOE would not provide 

partial funding for the proposed project. In the absence of DOE funding, project proponents 

(ADM) would not proceed with the proposed project tasks. Thus, the components of the 

proposed project (including building of a compression/dehydration and injection of CO2 facility) 

would not occur under the No-Action alternative. 

2.3 Issues Considered and Dismissed 

The Purpose and Need section above highlighted the importance of the overall program of 

evaluating ICCS 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. Because of the lack of potential impact to certain issues due to the 

specific characteristics of the proposed project, 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. 
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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. 

Harm Tribal Lands No lands affiliated with Native American tribes 

would be impacted by ADM’s Proposed Project. 
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3.0 THE ENVIRONMENTAL ANALYSIS APPROACH 

This chapter describes how the environmental review team analyzed the potential impacts of this 

ADM’s Proposed Project (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 ADM’s proposed project along with an analysis of environmental effects if the 

proposed project 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 project 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. 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. 

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. 

 Site clearing could 

cause 

 Soil erosion? which could 

cause

 Damage to stream species? 
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Table 3.2. Impact Significance Thresholds 

Resource Area 

Impact Significance Thresholds 

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 project 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 and 

Floodplains 

Any impacts to wetlands/floodplains 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. 

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 ICCS 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. 
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Table 3.2. Impact Significance Thresholds 

Resource Area 

Impact Significance Thresholds 

An impact would be significant if it EXCEEDS the following conditions. 

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. The consultations with the SHPO and any 

other potentially affected groups would result in the determination of effect under 

Section 106 of the NHPA of 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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& 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 

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 (54.6 cm) (DOE, 2008). 

4.1.1.2 National Ambient Air Quality Standards and Attainment Status 

USEPA Region 5 and the 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: PM10, 

PM2.5, SO2, CO, nitrogen oxides (NOx), 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 project area 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 project 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. 

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 project area (Table 4.1.1.3). With the exception of the 
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& Environmental Effects 

eight-hour O3 and PM2.5 standards, air-quality measurements are below the NAAQS (USEPA, 

2008). 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 area is in attainment. 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 and was granted 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 Sangamon County 1-Hour Maximum3 (ppm) 35 (None) 3 

NO2

Annual Arithmetic Mean (ppm) 

1-Hour Maximum8

 (ppm) 

0.053 

0.100 

0.053 

0.100 (no data available) - 

Ozone

8-Hour Maximum4 (ppm) 0.08 0.12 0.069 Macon County 

PM2.5

Annual Arithmetic Mean5 (μg/m3) 15 15 12 Macon County 24-Hour Maximum6 (μg/m3

) 35 35 29 

PM10

Annual Arithmetic Mean7 (μg/m3) 50 50 24 Macoupin County 24-Hour Maximum3 (μg/m3

) 150 150 54 

SO2

Annual Arithmetic Mean (ppm) 0.03 (None) 0.003 

24-Hour Maximum3 (ppm) 0.14 (None) 0.025 Macon County 

3-Hour Maximum3 (ppm) 

1-Hour maximum9

 (ppm) 

- 

0.075 

0.5 

(None) 

0.042 

0.050 

 1 - Source: 40 CFR 50.1-50.12. 

 2 - Source: (USEPA, 2008). 

 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

. 

8 - To attain this standard, the 3-year average of the 98th percentile of the daily maximum 1-hour average at each 

monitor within an area must not exceed 100 parts per billion (ppb) (effective January 22, 2010). 

9 - Final rule signed June 2, 2010. To attain this standard, the 3-year average of the 99th percentile of the daily 

maximum 1-hour average at each monitor within an area must not exceed 75 ppb. 

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 
Industrial Carbon Capture and Sequestration (ICCS) 

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Description of the Affected Environment 32 April 2011 

& Environmental Effects 

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. CO2 emissions are not reported by the facility since the first annual reporting of CO2

emissions under the USEPA Reporting Rule is for calendar year 2010. 

Table 4.1.1.4. Existing (2009) Air Emissions for Decatur ADM Complex 

Criteria Pollutants Decatur ADM Complex 

Annual Emissions (Short Tons per Year) 

CO 2993.5 

NOx 1685.34 

PM10 1,478.5 

PM2.5 415.36 

SO2 7087.5 

VOC 3543.29 

Source: (ADM, 2010c). 

4.1.1.5 Greenhouse Gases 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: CO2, nitrous oxide (N2O), 

methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride 

(SF6) (UNFCCC, 2008; 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 (DOE, 2008). 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).

Since 1900, the Earth's average surface air temperature has increased by about 1.2 to 1.4oF. The 

eight warmest global average temperatures on record have all occurred within the past 10 years, 

with the warmest year being 2005 (USEPA, 2009a). With this in mind, DOE, while preserving 

their core operations, is poised to support climate-changing initiatives to reduce GHG emissions. 
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& Environmental Effects 

4.1.2 Effects of ADM’s Proposed Project 

Short-term minor impacts to air quality would be expected with the implementation of the 

proposed project. 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. Dehydration reboilers, which could generate limited air emissions, would be 

the only expected sources 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 action(s) they 

engage in or permit 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 project 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, and drilling, 

 Construction and operation of transport pipeline, 

 Operation and maintenance of injection facilities, and 

 Subsurface injections of CO2. 

Construction and drilling 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 for the well. The operational emissions would primarily be due to vehicle 

operation and the proposed natural gas-fired dehydration reboiler in the regenerator column. 

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 project 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 project, it is not 

anticipated that the estimated emissions would make up 10 percent or more of regional emissions 

for any criteria pollutant and not be regionally significant. A detailed breakdown of drilling, 

construction, and operation emissions is located in Appendix A. 
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& Environmental Effects 

Table 4.1.2.1. Proposed Project Emissions Compared to Applicability Thresholds 

Annual emissions (Short Tons Per 

Year) 

De minimis

threshold 

(Short Tons 

Per Year)

Would emissions 

exceed applicability 

thresholds? [Yes/No] 

Activity 

(Annual) CO NOx VOC SOx PM10 PM2.5

Drilling and 

Construction 4.8 8.7 1.17 <0.01 0.4 0.4 

100 No Facility 

Operations 0.0 0.2 0.0 0.0 0.0 0.0 

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), 

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, 2002). 

The Decatur ADM Complex is in an attainment area and would introduce a limited 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. 

4.1.2.3 Greenhouse Gas Emissions 

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 2.5 million short tons of CO2 would be sequestered during the initial 2.5-year 
Industrial Carbon Capture and Sequestration (ICCS) 

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& Environmental Effects 

injection period. However, the overall amount of CO2 generated would increase due to the 

burning of diesel fuel during drilling, the additional electrical demand (10-12 megawatt (MW)), 

and worker commutes. The net CO2 emissions for the project were estimated (Table 4.1.2.3). A 

net decrease of approximately 2.3 million short tons of CO2 emission would be realized over the 

life of the project. These 2.5 million short tons of CO2 are currently vented to the atmosphere 

and would not be if the proposed project were implemented. This is less than 0.0001% of the 

global CO2 emissions. The additional 190,177 short tons of CO2 from the drilling, construction, 

and electricity usage would not be generated at all without the implementation of the proposed 

project. 

Table 4.1.2.3. Net CO2 Emissions for ADM’s Proposed Project 

Activity/Source Emissions (Short Tons) 

Drilling and Construction 494 

Electricity Usage 188,587 

Worker Commutes 602 

Sequestration (2,500,000) 

Total Emissions Reduction (2,309,823) 

Fugitive CO2 Emissions and Compressor Blowdown. Because sequestration of CO2 is an 

integral part of research and development activities for the proposed project, fugitive air 

emissions of CO2 would occur during routine operations. Sources of emissions during 

sequestration operations include 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 project. 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.

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 allow for 2.5 million short tons 

of CO2 not to be sequestered, and therefore vented into the atmosphere. This would 

incrementally increase the amount of GHG in the atmosphere and continue to contribute to 

global warming. 
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& Environmental Effects 

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 project, when considered in addition to 

comparable emissions from the related MGSC project, would be de minimis and would not be 

regionally significant. Therefore, it is not anticipated that the proposed project would contribute 

substantially to adverse cumulative effects to air quality. 

4.2 Geology and Soils 

4.2.1 Description 

The ADM ICCS Facility 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 sites are located on the 

existing Decatur ADM Complex. Project activities are planned northeast 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 area has been previously leased for agricultural uses (DOE, 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 sites are 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 (DOE, 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 

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 sites is the MGSC Phase III injection and reservoir monitoring wells. They are about 

3,900 feet (1,200 meters) to the south of the proposed injection well location. 
Industrial Carbon Capture and Sequestration (ICCS) 

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Description of the Affected Environment 37 April 2011 

& Environmental Effects 

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

Source: (DOE, 2008). 
Industrial Carbon Capture and Sequestration (ICCS) 

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Description of the Affected Environment 38 April 2011 

& Environmental Effects 

Core and well data from the existing well, drilled for the Midwest Geologic Sequestration 

Consortium project1, located less than one mile from the proposed site, demonstrate that 497 feet 

of the Eau Claire Formation are present. The upper 300 feet of the Eau Claire Formation at this 

location are comprised of tight dolomitic siltstone, dolomite, and limestone, in descending order. 

The bottom 197 feet of the Eau Claire is shale with little or no carbonate stingers present. 

Geochemical and geophysical analyses confirm the presence of this thick shale. X-ray 

diffraction and other geochemical analysis are currently underway on the Eau Claire samples and 

information from these analyses will be included in subsequent UIC Class VI permit 

applications. 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 two sites. The nearest well with a porosity log for 

the entire thickness of the Mt. Simon, the MGSC Phase III site, was drilled on ADM property 

3,900 feet from the proposed project. The MGSC III well drilled through 7164.7 feet of Mt. 

Simon before drilling into the Precambrian granite (Weibel, 2010). 

The gross thickness of the MGSC III well had an average porosity, calculated from wireline logs, 

of 13.4 percent and a permeability of 26 milidarcys. The MGSC III 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 (DOE, 2008). 

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 sites. 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 (DOE, 2008). 

Analysis of Mt. Simon Sandstone thin sections from 90 feet (27 m) of core demonstrate that the 

sandstone is cemented by silicate cements with little to no evidence of carbonate cements. 

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 only two known penetrations. The 

MGSC III project’s injection and reservoir monitoring wells are located about 3,900 feet from 

the proposed injection well. The next nearest penetration of the Eau Claire seal is over 17-miles 

(27.36 km) from the site. The MGSC well is being continually monitored for integrity and other 

parameters. Thus, 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 site locations (DOE, 2008). 

The primary confining zone (seal) at the sites 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 sites. The estimated top of the Eau Claire Formation 

 

1

 The legal name of this well is ADM CCS #1. For the purpose of distinguishing existing wells from proposed ICCS 

project wells, this well is identified as an “MGSC well” in this document. 
Industrial Carbon Capture and Sequestration (ICCS) 

Area 1 Project Final Environmental Assessment

Description of the Affected Environment 39 April 2011 

& Environmental Effects 

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 sites, 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 

Formation are expected to be relatively tight and would tend to act as sealing lithologies (DOE, 

2008). 

There are two secondary seals expected at the sites. The Ordovician-age Maquoketa Shale is 

laterally continuous across the sites and is estimated to be over 200 feet (60.96 m) thick at the 

sites 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 (DOE, 2008). 

There are no mapped regional faults and fractures within a 25-mile (40.23 km) radius of the 

proposed sites. A preliminary 2-D seismic survey has been completed during Phase I of the 

ICCS as well as a 3-D and vertical seismic profile (VSP) as part of the MGSC project. 

Additional 3-D and VSP data are planned as part of this project to further characterize the site 

geology and monitor the fate of the CO2.

Soils. Soils in the area were mapped by the U.S. Department of Agriculture (USDA) (Figure 

4.2.1-2). Nine loam units have been mapped within the project site with Drummer silty clay 

loam (152), and Flanagan silt loam (154A) as most prevalent of the loam types. The most 

common soil type is the Flanagan silt loam. This 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. Drummer, which is characterized by a nearly level poorly drained 

soil that occurs in broad, flat areas on outwash or till plains, 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. 
Industrial Carbon Capture and Sequestration (ICCS) 

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Description of the Affected Environment 40 April 2011 

& Environmental Effects 

Figure 4.2.1-2. Map of Soil Types over the ADM ICCS Facility Site 

Source: (NRCS, 2007). 
Industrial Carbon Capture and Sequestration (ICCS) 

Area 1 Project Final Environmental Assessment

Description of the Affected Environment 41 April 2011 

& Environmental Effects 

 Source: (NRCS, 2009). 

At the sites, the low topographic relief suggests that there is essentially no potential for 

landslides, and negligible risk of subsidence (DOE, 2008). 

4.2.2 Effects of ADM’s Proposed Project 

The main potential negative effects of the proposed project (injection of approximately 2.5 

million short tons of CO2 over 2.5 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 surrounding 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). 

Under these circumstances, the injected CO2 would have had time to interact with organic and 

mineral matter in the reservoir and potentially contain dissolved organic compounds and other 

contaminants. In related CO2-Enhanced Oil Recovery (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 sites. 

Relatively slow leakage from the well bores due to casing and/or cement problems are likely to 

be detected ahead of time by the Mechanical Integrity Testing likely to be proposed in the UIC 

Permit application (DOE, 2008). 
Industrial Carbon Capture and Sequestration (ICCS) 

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Description of the Affected Environment 42 April 2011 

& Environmental Effects 

MGSC models of one million metric tons of injected CO2 after a one hundred year post-injection 

period show that injected CO2 will not reach the base of the Eau Claire shale making the longterm potential for dissolution of the shale and subsequent leakage of the CO2 highly unlikely. 

The Mt. Simon Sandstone is a clean, second-cycle sediment dominated by silicate minerals 

cemented by quartz. The availability of cations such as calcium is limited; therefore, the ability 

of precipitates to form and alter injectability is limited. The reaction rate for carbonate cement to 

form is very slow. Since the expected time period for carbonate cement formation is hundreds to 

thousands of years post-injection, the increase of availability of CO2 in the Mt. Simon brine is 

highly unlikely to decrease permeability. 

The USGS National Earthquake Information Center website 

(http://earthquake.usgs.gov/regional/neic/) indicates no record of significant seismic activity (M3 

or greater) in Macon County. 

 

The nearest earthquakes, all in the M3 to M3.99 range are 

1. in southeastern Christian County, about 28 miles from the injection site 

2. in northern Piatt County, about 32 miles from the injection site 

3. just south of Bloomington, in central McLean County, about 38 miles from the injection 

site 

The proposed injection site in Decatur Illinois is well away from the New Madrid and Wabash 

Valley seismic zones and there is no site-specific manifestation of these zones at the Decatur site. 

In fact, there are no mapped regional faults or fracture zones with a 25-mile radius of the 

proposed site. Thus, there are no evident planes of failure that could potentially allow bedrock 

movement that would impact the integrity of the site and with any possible relationship to fluid 

injection pressures that could activate these surfaces. 

Seismicity in the southern Illinois region of the Wabash Valley seismic zone is related to deepseated northeast trending normal and strike-slip faulting in the Precambrian basement. Decatur 

is not on this trend and in fact this structural trend angles away from Decatur as you proceed 

north from southern Illinois. 

The nine largest events in this zone from 1958 to 1987 occurred at depths of 16,100 to 76,800 ft, 

much too deep to be affected by any fluid injection in the Mt. Simon Sandstone at Decatur, and 

not at the distances involved. Additionally, the earthquakes of record do not correlate with any 

known structures in the Paleozoic sedimentary section, which includes the Mt. Simon, thus any 

impact from daily injection pressures at Decatur is highly unlikely. Any microseismic activity 

detectable by instruments (not an earthquake) is likely to be related to fluid flow through 

tortuous pathways in the injection zone. 

Timothy H. Larson, Ph. D., Geophysicist with Illinois State Geological Survey states that a deep 

well injection for disposing of waste has not caused seismic activity. He also believes that the 

injection pressures of the CO2 at the Decatur site are not high enough to cause fracturing of the 

rock. High injection pressures have resulted in seismic activities in other areas of the U.S. 
Industrial Carbon Capture and Sequestration (ICCS) 

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Description of the Affected Environment 43 April 2011 

& Environmental Effects 

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 project 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 (ADM, 2010d). Since there are no substantial 

impacts to geological and soil resources from the proposed project or the related MGSC project 

with its comparable effects, the proposed project 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 proposed project 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 project 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

)/second (sec) (211.23 cubic meter (m3)/sec) and recorded a maximum peak flow of 

31,800 ft3/sec (9692.64 m3/sec) in May of 2002 (USGS, 2007). 

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 (DOE, 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 
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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 ICCS project 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 (DOE, 2008). 

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 (DOE, 2008). 

4.3.2 Effects of ADM’s Proposed Project 

The current regulatory framework for USEPA’s UIC permitting program includes multiple 

provisions for safeguarding and preventing injected fluid movement into USDWs (See Section 

2.1.2.4). The permitted Class I injection wells on the ADM site would employ accepted industry 

standards in meeting the specified permit provisions and conditions. 

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 (approximately 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 ICCS Site because of the: 

 Depth of the proposed injection zone, 

 Multiple sequences of shale seals between the injection zone and USDW, and 

 Absence of seismic activity in the local area. 

The main potential negative effects of the proposed project 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 project 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 
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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 contaminants. 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). There is no expectation of any crude oil in the reservoir at the ADM sites. 

Relatively slow leakage from the well bore due to casing and/or cement problems are easily 

detected ahead of time by the Mechanical Integrity Testing likely to be 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. 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. These include 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 

seals for known hydrocarbon traps within the basin (DOE, 2008). The lowermost seal, the Eau 

Claire, has only two known penetrations. The MGSC III project’s injection and reservoir 

monitoring wells are located about 3,900 feet from the proposed injection well. The next nearest 

penetration of the Eau Claire seal is over 17-miles from the site. However, the MGSC well is 

being continually monitored for integrity and other parameters. Thus, 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 radius of the 

project site (DOE, 2008). 

Section 4.2.1 also states that the expected thicknesses of the confining layers at the project site 

are substantial, likely measuring 300-500 feet for the primary Eau Claire formation, over 200 

feet for the Maquoketa formation, and 140 feet for the New Albany Shale formation. The 

shallower secondary formations have already demonstrated their effectiveness as regional seals 

for oilfields (DOE, 2008). 

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 
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values as high as 0.871 mD are expected to be relatively tight and tend to act as sealing 

lithologies (DOE, 2008). 

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 (DOE, 2008) application, no faults have been documented within 25 

miles (40.23 km) of the project site. Section 4.2.1 indicates a preliminary 2-D seismic survey 

has been completed during Phase I of the ICCS as well as a 3-D and VSP as part of the MGSC 

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) (DOE, 2008). 

The injection process does not require 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 to the east of the ADM ICCS 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, ADM will obtain all necessary permits for construction storm 

water discharges (ADM, 2010d). 

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. 

4.3.3 Effects of No-Action 

If the No-Action alternative is implemented, the construction and injection activities of the 

proposed project 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 (ADM, 2010d). Since there are no substantial 

impacts to water resources from the proposed project or the related MGSC project with its 

comparable effects, the proposed project 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 
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This section identifies and describes wetlands and floodplains potentially impacted by the 

proposed project. In addition, this section provides the required floodplain and wetland 

assessment and public review for compliance with 10 CFR Part 1022, “Compliance with 

Floodplain and Wetland Environmental Review Requirements.” 

4.4.1 Description 

There are no wetlands designated within the project area boundaries according to the National 

Wetlands Inventory (USFWS, 1987)(See Appendix H). The facility would be built within the 

existing industrial setting of the Decatur ADM Complex, and the project facilities would not be 

located near any wetland area. The nearest wetland is located adjacent to the western boundary 

of the ADM complex with a road separating it from the project site (DOE, 2008). 

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, 2009a). Palustrine system 

designations include all non-tidal wetlands dominated by trees, shrubs, persistent emergent 

vegetation, emergent mosses, or lichens. 

Project construction that would be nearest to the wetland unit is the proposed electrical lines. 

These lines would be located along ADM’s western property boundary along the east side of 

North Brush College Road, with the road passing between the wetland unit and the proposed 

electrical lines. 

There are no floodplains in the ADM complex area. The nearest floodplain is associated with an 

unnamed tributary off the Sangamon River and Lake Decatur to the east of the project site 

approximately 0.36 miles (0.58 km) (Illinois State Water Survey, 1996). Figure 4.4.1 shows the 

location of the floodplains to the test site. 
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Figure 4.4.1. Floodplains near the ADM ICCS Site 

4.4.2 Effects of ADM’s Proposed Project 

As there are no wetlands or floodplains in the project site, wetland resources and floodplains 

would not be impacted by construction of the proposed project. The injection well and 

verification well would be drilled far enough away so that there would be no impacts to the 

wetland located outside the study area. Furthermore, it is not likely that wetlands would be 

impacted by the discharge of wastewater from project activities. Similarly, the well would be far 

enough away so that there would be no impacts to floodplains. 

Only the proposed electrical lines are near the identified wetland unit on the west side of North 

Brush College Road. At this location, the electrical lines would be placed on new wooden poles 

constructed on the east side of North Brush College Road. The ground disturbance associated 

with the electrical line construction is minimal and will have only a negligible effect on the 

wetlands unit at this location. 

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 project site. Wetland vegetation and 

water quality could be impacted by increased concentrations of CO2, possibly resulting in 
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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 project would not be expected to exceed the 

significance threshold. 

4.4.3 Effects of No-Action 

Under the No-Action alternative, the proposed project 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. 

When considering the effects of these ongoing projects, along with minimally adverse effects 

generated by the related MGSC project, the proposed project would not pose any additional 

threats to wetlands or floodplains in the project area, aside from the unlikely leakage of CO2 to 

the surface from either this project or the related project, which would have widespread 

consequences on wetlands and floodplains. However, given the larger impacts to wetlands and 

floodplains from other 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 project facilities would be located in an area characterized by the Bailey 

Ecoregion classification as the Prairie Parkland (Temperate) 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. 
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The proposed project site consists of land within the Decatur ADM Complex that has been 

disturbed from its natural state. Surrounding land is industrial, residential, or agricultural. A 

fallow agricultural field north of the primary industrial complex and north and east of the 

Richland Community College campus comprises most of the project site. Low growing grasses 

occur on the project site, which has been previously disturbed. 

The Illinois Department of Natural Resources has compiled an inventory of resource rich areas 

(RRA) in Illinois (DOE, 2008). The proposed project 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 project site, is the closest RRA. 

No critical habitats or federally listed plant species exist in the vicinity of the project site. One 

federally listed plant species, the Eastern prairie fringed orchid (Platanthera leucophaea) -

threatened, and one Illinois state listed endangered plant species, wild hyacinth (Camassia 

angusta), occur in Macon County (USFWS, 2009b; IDNR, 2008), but are not likely to be found 

in the project area. A review of the USFWS technical assistance website (USFWS, 2009c) on 

January 26, 2010 for federally listed threatened and endangered species resulted in a conclusion 

that the proposed project would have “no effect” on listed species, their habitats, or proposed or 

designated critical habitat. 

4.5.2 Effects of ADM’s Proposed Project 

Construction activities associated with the proposed project would occur within currently 

developed and fallow field areas in the interior and at the perimeter of the primary industrial 

complex where there is mostly non-native vegetation growing. The new proposed well and 

pipeline would 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. Part of the pipeline 

would be underground and co-located with steam lines in a 200-foot easement on the property of 

Richland Community College, which mainly consists of paved surfaces. 

Approximately a 300 foot by 300 foot area around the injection well would be disturbed by 

installation of facilities and improvements as described in Section 2.1.2.7. For the injection well, 

the well pad and the surrounding operations area would disturb approximately 2 acres (8,094 

m

2

), on which there would be very little vegetation. Installation of a verification well 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 vegetation. Installation of the 5,290-foot pressurized pipeline would be 

aboveground for most of its length, following the current pipeline alleys at the Decatur ADM 

Complex as much as possible; a small portion would be co-located with steam lines in an 

easement on the property of Richland Community College. Thus, pipeline construction would 

not likely disturb more than 1 acre (4,050 m2) on which there would be very little, if any, 

vegetation. Installation of 1,224 feet of ductwork carrying uncompressed CO2 would also 

disturb vegetation along its length. 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. 
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A new ICCS facility would be constructed near the north boundary of the ADM complex. The 

footprint for this facility would be 30,000 ft2 (2,787 m2). Vegetation on this site would be 

cleared; however, most plants are non-native and the area has been previously disturbed. Heavy 

equipment may cause temporary disturbance in adjacent areas beyond the footprint of 

construction. Repeated disturbance of vegetation (i.e., due to vehicle passes) during these 

activities would cause damage to plants and destruction of the vegetation mat. There would also 

be localized vegetation disturbance from foot traffic during construction. The overall impact on 

vegetation would be reduced by concentrating the area of disturbance to the smallest area 

necessary to complete the project. 

A new 500 ft (152 m) by 500 ft electrical substation is proposed on the former golf course land 

owned by ADM that is east of the primary industrial complex. The footprint for this facility 

would be 250,000 ft2

 (23,225 m2). Vegetation on this site would be cleared; however, most 

plants are non-native and the area has been previously developed as a golf course. Heavy 

equipment may cause temporary disturbance in adjacent areas beyond the footprint of 

construction. Repeated disturbance of vegetation (i.e., due to vehicle passes) during these 

activities would cause damage to plants and destruction of the vegetation mat. There would also 

be localized vegetation disturbance from foot traffic during construction. The overall impact on 

vegetation would be reduced by concentrating the area of disturbance to the smallest area 

necessary to complete the project. 

Total vegetation disturbance/clearing from construction and installation of all project 

components would occur on approximately 10 acres (40,470 m2

). 

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, 

Best Management Practices (BMPs) would be employed to ensure that imported material does 

not contain exotic plant material. 

 Obtaining gravel and fill for construction or maintenance from certified noxious weedfree sources. Gravel pits and fill sources would be inspected to identify weed-free 

sources. 

 Limiting the area of disturbance. For example, heavy construction equipment would be 

kept on road surfaces to the extent possible. 

 Monitoring and removing any invasive species observed subsequent to project 

completion. 

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 
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(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 proposed project 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 complex has been previously cleared for ADM industrial development 

and agricultural practices, including the related MGSC project. These activities have involved 

removal, trampling, or destruction of vegetation and disturbance of ground cover. Any 

vegetation disturbance associated with the proposed project 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, including less than one acre of disturbance for the injection well and less than 0.5 acres 

disturbance for each of four monitoring wells for the related MGSC project, 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 near 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 project site or in Macon County. One federally 

listed wildlife species, the 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 (USFWS, 2009b; IDNR, 2008). Of these species, only the 

Bewick’s wren has been documented as occurring approximately one mile south of the project 
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site. A review of the USFWS technical assistance website (USFWS, 2009c) on January 26, 2010 

for federally listed threatened and endangered species resulted in a conclusion that the proposed 

project would have “no effect” on listed species, their habitats, or proposed or designated critical 

habitat. 

4.6.2 Effects of ADM’s Proposed Project 

Activities for construction of the CO2 compression-dehydration facility, installation of an 

injection well and pipeline, vehicle traffic, lighting during night work, and human presence 

would cause temporary displacement and disturbance of resident wildlife for the 2.5-year 

duration of the project. Species are expected to return to the area after construction and injection 

is completed, although there may still be some minimal disturbance during the duration of post 

injection monitoring. These impacts would be localized and limited to the immediate area of the 

project area. 

It is estimated that approximately 10 acres of wildlife habitat would be disturbed by installation 

of an injection well and pipeline. A 300 foot by 300 foot area around the injection well would be 

disturbed by installation of facilities and improvements as described in Section 2.1.2.7. The 

injection well pad and the surrounding operations area would disturb a total of approximately 

four acres (16,187 m2), on which there would be very little, if any, wildlife habitat. Installation 

of the verification well would disturb a very small area around each well, probably less than 0.5 

acre total, on which there would be very little, if any, wildlife habitat. Construction of the 5,290-

foot pressurized pipeline would be aboveground for most of its length, following the current 

pipeline alleys at the Decatur ADM Complex as much as possible; a small portion would be colocated with steam lines in an easement on the property of Richland Community College. Thus, 

pipeline construction would not likely disturb more than 1 acre on which there would be very 

little, if any, wildlife habitat. Installation of 1,224 feet of 24-inch pipe carrying uncompressed 

CO2 would also disturb wildlife habitat along its length. A new 30,000 square feet 

compression/dehydration facility would be constructed near the north boundary of the ADM 

complex. A new 500 ft by 500 ft electrical substation is proposed on the former golf course land 

owned by ADM that is east of the primary industrial complex. The footprint for this facility 

would be 250,000 ft2

. All wildlife habitat on these two building sites would be disturbed and/or 

destroyed. 

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 
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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 project 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 proposed project 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, including the 

recent development of the related MGSC project. Habitat disturbance associated with new 

infrastructure as part of the proposed project 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 

more widespread consequences on wildlife and habitat. Cumulative impacts from the proposed 

project when added to other past, present, and reasonably foreseeable future actions, including 

the related MGSC project, would be minimally adverse and are not expected to exceed the 

threshold of significance. 

4.7 Land Use 

4.7.1 Description 

The ADM ICCS Site would be located near Decatur, Illinois, within Macon County. The 

injection site and most of the project improvements are located entirely within the large Decatur 

ADM Complex that is owned and managed by ADM. A 200-foot portion of the pressurized 8-

inch pipeline is located within an easement on Richland Community College property. A 

proposed education center is located on Richland Community College property and will 

ultimately be owned and managed by the college. 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 

(DOE, 2008). 

The Decatur ADM complex consists of various processing facilities including cogeneration and a 

corn wet milling plant with ethanol production, which would be the sources of CO2 for this 

project. Additional primary facilities include bio-products, oilseed processing, and vegetable oil 

refining. 
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Nearby properties and/or land uses include Richland Community College; Caterpillar, Inc.; 

industry-related commercial businesses; and a private farm (Figure 2.1.1-2). Macon County and 

the City of Decatur have developed and implemented a comprehensive plan in July 2009 that 

establishes existing and compatible future land uses. The proposed project area with its 

industrial land use is consistent with the recently adopted City/County comprehensive plan 

(Decatur, 2009). 

Land utilized for the proposed ADM compression/dehydration facility and much of the pipeline 

construction are either visibly industrial in nature or are planned for industrial development, 

which is in concert with their industrial designation as part of the Decatur ADM Complex. The 

injection well area and the pipeline are also within the Decatur ADM Complex, except for a 200-

foot segment of the pipeline that passes through an easement on the property of the Richland 

Community College. The land utilized for the electrical substation is a former golf course. The 

land was previously purchased by ADM to accommodate expansion, as represented here by the 

electrical substation. The Decatur ADM Complex is a secured and fenced area that would also 

include the compression/dehydration facility and the injection well sites 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 project site based on the 

Soil Survey of Macon County (Figure 4.2.1-2)(DOE, 2008). All of these soils are considered 

characteristic of prime farmland. 

Project design parameters indicate that if the injected CO2 plume would migrate off site, it would 

take several years. ADM is aware of the legal and mineral rights issues should the plume move 

off site and when work begins on Phase 2, ADM would take necessary steps to secure mineral 

rights and additional permitting and requirements specified by law. 

An agricultural ground cover is planned surrounding the areas where the injection well would be 

located. 

4.7.2 Effects of ADM’s Proposed Project 

The proposed project would slightly expand the visual and physical industrial character of the 

very large Decatur ADM Complex while remaining almost entirely within existing ADM 

property. The current Decatur ADM Complex developed property size is 300 acres (1,214,057 

m

2

) while the proposed facility and injection well site would be almost 5 acres. 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, 

including an annual agricultural exhibition that has resulted in some simple structures that 

remain on the site. With the exception of a 300 foot by 300 foot area for injection well surface 

improvements, the injection well area that is disturbed would be replanted in agricultural ground 

cover, retaining much of the agricultural appearance of this area of the project and minimizing 

any effects on identified prime farmland resources. 
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& Environmental Effects 

New elevated pipelines required by the project are planned to follow existing elevated pipe 

corridors on Decatur ADM Complex property, except for the portion beyond the entry into the 

easement on the Community College property, which would be placed underground. 

The ADM compression/dehydration facility would be set adjacent to other heavy industrial uses 

featuring cooling towers and other plant facilities and equipment that are typical of this type of 

industrial facility. The appearance and operation of this part of the project would be compatible 

with its immediately surrounding land uses. 

The ADM compression/dehydration facility and pipeline will be built almost entirely within the 

Decatur ADM Complex (excluding the pipeline easement on the Community College property) 

and will be integrated with the control of ADM's processing facilities. ADM may choose to 

continue operation of the compression/dehydration facility, pipeline, and injection well after the 

proposed DOE 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 ICCS Site. Equipment that is 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. 

Pore space rights may be necessary if the injected plume migrates offsite. ADM is aware of this 

need and would take required steps when that becomes necessary. 

The effects of the proposed project are that land use impacts would be limited to a small area and 

would not noticeably alter any particular land use at the ICCS 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 project are not expected to exceed the 

significance threshold. 

4.7.3 Effects of No-Action 

Under the No-Action alternative, the ADM ICCS Site work would not be implemented. No 

impacts to land use would occur because of this alternative. 

4.7.4 Cumulative Effects 

No additional land use development is currently planned near the project outside of Decatur 

ADM Complex property (DOE, 2008). ADM has no major development planned beyond routine 
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& Environmental Effects 

expansion of current plant facilities (ADM, 2010d) and the recently completed MGSC project. 

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, and especially the related and similar MGSC project. 

4.8 Socioeconomic Resources 

This section describes the socioeconomic conditions that may be affected by implementation of 

the proposed project and addresses any potential impact that may result. 

4.8.1 Population 

4.8.1.1 Description 

The project site would be located on the east side of the metropolitan area of Decatur, Illinois, 

and is primarily 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 2009 estimated population of 73,799 

residents (Census, 2009a), 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 108,204 in 2009 (Census, 2009b). Incorporated communities within a 15 mile 

(24.14 km) radius of Decatur include: Argenta – population 825; Forsyth – population 3,007; 

Harristown - population 1,236; Long Creek - population 1,342; Macon - population 1,128; 

Mount Zion - population 5,232; Oreana - population 814; and Warrensburg - population 1,160 

(Census, 2009c). Block data (Census, 2000a) for the area immediately surrounding the project 

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 project site are classified by the U.S. Census 

as rural. 

The 2009 estimated population for the city of Decatur, 73,799 shows a 9.8 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, 2008a). In 2009, Decatur supported a total 

of 37,657 housing units with a median value of $77,000 (Census, 2009b). The occupancy rate 

for all units in the city was 84.2 percent. The average population density for the metropolitan 

area of Decatur is 1,799 persons per square mile (2,589,988 m2

), with a housing density of 918.5 

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, 39.7 years. Approximately 

25.3 percent of the population is 19 years old or younger, with 6.8 percent under the age of five 

and 16 percent aged 65 and over (Census, 2009a). 

The estimated population of Macon County in 2009 was 108,204 residents; a slight decrease of 

5.7 percent from the 2000 total of 114,706 (Census, 2009d). In 2009, there were a total of 
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52,509 housing units in the county, with an occupancy rate of 86.9 percent and an estimated 

average density of 90.4units per square mile (2,589,988 m2). Population density for this year 

was estimated to be 186.4 persons per square mile (2,589,988 m2) (Census, 2000b). Residents 

aged 19 years and younger represented 25.4 percent of the total population. Children under five 

years of age account for 6 percent of the county’s population and persons 65 years of age and 

older make up 16.3 percent of the population (Census, 2009e). 

4.8.1.2 Effects of ADM’s Proposed Project 

Implementation of the proposed project would have only a minor, if not negligible, effect on the 

size and demographic characteristics of the local population. Any additional, permanent fulltime employment generated as a result of this alternative would be minimal. Labor requirements 

would be temporary and limited to the construction of the well, pipeline, education center, 

substation, and compressor facilities. Estimates for the additional workforce required at the site 

range from 200-220 personnel during peak construction, estimates indicate that approximately 

800 jobs will be created during the projects 5-year period. This temporary increase would be 

easily accommodated by existing local resources. 

ADM’s proposed project would be in keeping with the industrial character existing in the project 

area and would not introduce any new or incompatible uses. The proposed ICCS site would be 

located primarily within the existing Decatur ADM Complex boundaries with the exception of a 

200-foot length of pipeline that lies within an easement on the Richland Community College 

property and an education center that is operated by and will eventually be owned by Richland 

Community College. 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 project are expected to be below the significance threshold. 

4.8.1.3 Effects of No-Action 

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 project site. 

In the absence of DOE funding, the proposed alternative would not proceed. 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 project 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 

The introduction of the proposed ICCS site operation would not be expected to account for any 

noticeable changes in the size or demographic characteristics of the local population and would 
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& Environmental Effects 

not contribute to any substantial changes in local community character and setting. As in this 

project, the small population increases as a result of the related MGSC project were temporary 

and are not considered additive to the small temporary increases from this project. When 

considered in combination with ADM’s current and proposed management of the existing site 

and the future site condition, including the related MGSC project, 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 

occupations continue to be a major source of employment in the Macon County area. Per capita 

personal income for the city of Decatur in 2008 was $23,290. Employment statistics for the year 

indicate that the city supported a total civilian labor force of 36,121 workers, with an 

unemployment rate of 6.9 percent or 2,492 workers. The largest occupational categories 

included: management, professional, and related occupations, with 9,719 workers, or 28.9 

percent of the workforce; sales and office occupations, with 9,624 workers or 28.6 percent of the 

workforce; and service occupations with 6,040 workers, or 18.0 percent of the total. Median 

household income in 2006 was $39,394 (Census, 2008b). 

The leading employment sectors for Macon County in 2008 were manufacturing, with 19.1 

percent of total employment; health care and social assistance, with 24.4 percent; and retail trade, 

with 11.7 percent of the total (Census, 2008c). Employment statistics for November 2009 

indicate that the county supported a total labor force of 54,472 workers, with an unemployment 

rate of 12.6.percent, or 6,872 workers. This represents an increase of 5.4 percent from the 2008 

annual average unemployment (BLS, 2010). The per capita personal income in 2008 was 

$25,912 (Census, 2008c). Median household income for 2008 was $45,649 (Census, 2008c). A 

summary of income distribution by household is presented in Table 4.8.2.1. 

Table 4.8.2.1. Household Income for 2008 

Number Percent 

Less than $10,000 2,712 5.9% 

$10,000 to $14,999 2,803 6.1% 

$15,000 to $24,999 5,497 12.0% 

$25,000 to $34,999 6,520 14.2% 

$35,000 to $49,999 7,936 17.3% 

$50,000 to $74,999 8,639 18.8% 

$75,000 to $99,999 6,106 13.3% 

$100,000 to $149,999 3,336 7.3% 

$150,000 to $199,999 981 2.1% 

$200,000 or more 1,429 3.1% 

Total Households 45,959 100% 

 Source: (Census, 2008c). 
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& Environmental Effects 

4.8.2.2 Effects of ADM’s Proposed Project 

Implementation of the proposed project 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 or from the available local labor force. 

Labor requirements for the construction of an injection well, pipeline, education center, 

substation, and capture facilities would be temporary and of short duration. 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 substantial change in regional employment would be 

anticipated. However, the local labor market has experienced a sharp increase in unemployment 

during the past 18 months. Temporary employment associated with the proposed alternative 

would result in a minor beneficial impact to the creation of new employment in the local area. 

Funding for this project is estimated at approximately $208 million. 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. 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. Since the ADM plant 

produces its own electricity, additional demand created by the proposed alternative would not 

impact industrial or residential users in the local area. Similarly, water requirements would be 

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 project are expected to be 

below the significance threshold. 

4.8.2.3 Effects of No-Action 

In the absence of federal funding, the proposed project would likely not proceed. ADM’s current 

management and operations at the project 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 project 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. 
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& Environmental Effects 

4.8.2.4 Cumulative Impacts 

The introduction of the proposed project to other planned or reasonably foreseeable actions at the 

study site or in the surrounding area, including the recently completed and related MGSC 

project, would be expected to have only a minor effect on the local economy. As described in 

Chapter 2, ADM’s proposed 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. The use of these resources for the related MGSC project has already 

occurred and so are not cumulative when considered relative to the current ADM project. 

Therefore, it would not be expected to contribute to any cumulative effect. Some potential 

benefit would be derived from the small additional labor requirement and from additional 

expenditures in the local economy associated with the proposed project. 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 

4.8.3.1 Description 

The ICCS Project 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 carbon capture site is bounded by Reas Bridge Road (Rd.) (Illinois (IL)- 

24). North Brush College Rd. (IL-1) forms the western boundary of the project site. To the east 

and somewhat removed from the project site boundary, Gun Club Road joins Christmas Tree 

Road to intersect with Reas Bridge road approximately one-half mile from the northeastern 

corner of the project 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 Brush College 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. The current daily truck traffic into and out of the Decatur ADM 

Complex is estimated at approximately 1,750 trips (DOE, 2008). 

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 project 

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. 

The project will draw electrical power from an onsite electrical power plant that would be 

supplemented by power from the local grid. The electrical substation and power line 

construction is proposed in this project to enable provision of power from the local grid. The 

substation will be located on ADM property and the power lines will be located either on ADM 

property or in utility easements acquired from property owners. 
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& Environmental Effects 

4.8.3.2 Effects of ADM’s Proposed Project 

ADM’s proposed project would not substantially alter existing traffic patterns, level of 

congestion, or road conditions in the immediate and surrounding area of the project site. Typical 

increases in traffic that might result from the proposed project are presented in Tables 4.8.3.2-1, 

4.8.3.2-2, and 4.8.3.2-3 below. 

Table 4.8.3.2-1. Well Construction Transport Estimate for the Injection Well 

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, 2008). 

Table 4.8.3.2-2. Transport Estimate for the Substation Construction 

Description of Transport Number* Type of Vehicle 

Movement of grading equipment & equipment trailers 10 loads flatbeds 

Delivery of ground cover 20 loads Dump Trucks 

Visits by ADM, etc. 10 cars/trucks 

Cementing trucks 10 loads pump trucks 

Building 2 flat bed 

Fencing Materials 2 loads flat beds 

Fencing Crews 2 cars/trucks 

Materials-Poles, wire, equipment, etc.. 20 loads flat beds 

Crane 2 loads flat bed & crane 

Crew changes, daily for personnel 4 cars/trucks 

Vacuum trucks, waste disposal trucks, etc. 2 vacuum trucks 

Ameren Personnel daily 3 trucks/utility trailer 

Other miscellaneous trucks, vehicles 4 F150's, cars, vans 
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& Environmental Effects 

Table 4.8.3.2-2. Transport Estimate for the Substation Construction 

Description of Transport Number* Type of Vehicle 

* Number of vehicles per week or number of loads 

Note: Traffic will peak during set-up, mobilization & demobilization, cementing & gravel runs as well as 

when compaction of yard is complete.

Source: (ADM, 2010e) 

Table 4.8.3.2-3. Transport Estimate for the National Sequestration Education Center 

Building Construction 

Description of Transport Number* Type of vehicle 

Movement of grading equipment & equipment trailers 5 loads flatbeds 

Visits by ADM, etc. 10 cars/trucks 

Cementing trucks 17 loads pump trucks 

Building-steel & misc. materials 6 loads flat bed 

Cranes, forklifts, aerial lift equipment, & etc. 4 flat bed & crane 

Crew changes, daily for personnel 4 cars/trucks 

Vacuum trucks, waste disposal trucks, etc. 2 vacuum trucks 

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 also after building foundation 

completion.

Source: (ADM, 2010e)

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 project site 

would be likely to disturb power or other utility transmission lines in the area. Therefore, the 

impacts from implementing the proposed project 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 

project 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 project. There are 

no planned or reasonably foreseeable actions for the project area which when added to the effect 

of the proposed project would substantially change local road use or traffic patterns. This is true 
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& Environmental Effects 

also of the related MGSC project, the majority of whose potentially cumulative infrastructure 

demands have already occurred. There would be limited potential to alter or disturb power or 

other infrastructure services to the area as a result of the proposed project, 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 project site to the southeast. 

 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 

project 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 

project 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 project site (DOE, 2008). 

4.8.4.2 Effects of ADM’s Proposed Project 

The addition of the injection well, pipeline, education center, substation, 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 project site that might be disturbed by site activities. The 

proposed project would be in keeping with the existing industrial character of the project 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 project 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 project to ongoing activities at the Decatur ADM Complex, 

including the recently completed and related MGSC project, 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 project. The 

project site would be on the east side of Decatur, Illinois, and primarily within the Decatur ADM 

Complex. The ADM compression/dehydration facility would be located within the industrial 

complex to the south of the proposed injection well site. An electrical substation would be 

constructed on a former golf course adjacent to the industrial complex that is currently owned by 

ADM. An education center would be located on property belonging to the Richland Community 

College. The pipeline would travel from the compression/dehydration facility to the injection 

well following, as much as possible, an existing pipeline corridor that transports steam to 

Richland Community College. 

4.8.5.2 Effects of ADM’s Proposed Project 

Under the proposed project, construction of a compression/dehydration facility (which is located 

immediately south of the MGSC injection well site on ADM property), an electrical substation, 

and education center, one injection well, various deep and shallow monitoring wells, and 

pipeline would minimally alter the visual elements of the project area, much of which are 

agricultural fields. In the area of the injection well, simple structures remain on the site from 

previous agricultural exhibitions that will continue to be conducted after the injection well is in 

place. However, facilities constructed under the proposed project would not contrast with the 

present landscape as industrial features are common in the immediate vicinity of the ICCS 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 project 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 ICCS Site work by ADM would not be implemented. No 

impacts to visual resources would occur because of this alternative. 

4.8.5.4 Cumulative Impacts 

Visual quality at the project site has been predominantly altered by the past ADM industrial 

development, including the MGSC carbon sequestration project. 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, and the 
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similar character of the nearby MGSC project, 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 

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 that are 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. 
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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, 2008b). 

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 

Octave Band 

Center Frequency 

(Hz) 

Allowable Octave Band Sound Pressure Levels (dB) of 

Sound Emitted to Noise Sensitive Land Uses 

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, 2008b). 

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.
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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 

860 ft 

261 m West 

School 

Quiet 

Suburban 

Residential 

55 53 47 

Compressor Site 

2,500 ft 

790 m North 

Source: (ANSI, 2003). 

4.8.6.2 Effects of ADM’s Proposed Project 

Short-term and long-term minor adverse effects to the noise environment would be expected 

with the implementation of the proposed project. 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 (15.2 m). Table 4.8.6.2-1 

presents typical noise levels (dBA at 50 feet (15.2 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 

(15.2 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 (122 to 244 m) from the site of major equipment operations. Locations within 1,000 feet 

(305 m) would experience substantial levels (greater than 62 dBA) of construction noise. There 

are no NSAs within 1,000 feet of the construction sites except for the proposed education center. 

Although the existing college is within 1,000 feet of the proposed education center, building of 

the education center would be temporary and end with the construction phase. These effects 

would be minor. Construction activities are exempt from both the state and local regulations. 

These effects would be temporary and would be considered minor. The following 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 
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 Construction equipment mufflers would be properly maintained and in good working 

order. 

Drilling Noise. ADM’s Proposed Project would involve drilling operations for the injection well. 

Components of the drilling equipment include the drill rig, mud pumps, and diesel generators. 

The generator and combined diesel driven systems would have the standard exhaust muffles. 

Noise from heavy equipment would be temporary and end with the drilling phase. Drilling 

equipment is expected to operate twenty-four hours per day, seven days per week, for up to six 

months. The noise would be clearly audible at the nearest NSA 860 feet (261 m) west of the 

injection well location. At this distance, the DNL would be approximately 62 dB. These levels 

would be below the threshold for land use incompatibility for long-term noise sources. Noise 

levels within the buildings would be significantly less, and unlikely to interfere with classroom 

operation. Although unlikely, if the drilling noise became loud enough to interfere with normal 

levels of verbal communication inside the buildings, sound barriers would be effective in 

reducing noise levels. Due to the short-term nature of the drilling activities, and given the 

primary function of the college is indoors, these effects would be minor under NEPA. 

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. The only 

major noise-producing equipment would be four 3,250 horsepower (hp) reciprocating 

compressors, two 2,000 hp blowers, and two 500 hp multistage pumps. Only one pump and one 

blower would be operated at a time. The compressors would be an order of magnitude louder 

than the proposed pumps or blowers and would mask them completely. The compressors would 

operate 24 hours per day, 7 days per week. Noise levels that would be generated by operation of 

the compressors 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 47 No 

63 74 43 No 

125 69 48 No 

250 64 46 No 

500 58 43 No 

1000 52 44 No 

2000 47 46 No 

4000 43 33 No 

8000 40 11 No 

Leq (dBA) 80 50 No 

 Sources: (IL, 2008; Decatur, 2008b). 
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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 project 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. 

4.8.6.4 Cumulative Impacts 

ADM’s Proposed Project would introduce long-term incremental increases in the noise 

environment. However, these increases would be relatively small when compared to the existing 

conditions, including the similar long-term compressor noise contribution of the related MGSC 

project, 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 project 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. 
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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, 2006). 

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 

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, 2006). 

4.8.7.2 Effects of ADM’s Proposed Project 

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 project 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 project considered by this EA would add only minimally to existing conditions for 

environmental justice in the project area, which includes the related MGSC project, 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. 
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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, 2009b). 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 project 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 and extent of pollution. 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, 2008). Similarly, waste 

management also is a source of possible human health and safety risks from exposure to 

contaminants (See Section 4.11). 

CO2 leaks are a concern to human health and safety within the project area. 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 CO2 exposure. 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 public (DOE, 2007a). The immediately 

dangerous level of exposure for CO2 to life and health 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). 

Leaked CO2 can cause human health issues in the water and in air. CO2 underground injection 

can contaminate groundwater if the CO2 migrates to underground aquifers (See Section 4.3). 

This contamination can occur when CO2 causes 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 
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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 in the United States, but 

no injuries or fatalities (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 U.S. was 0.0002 mile-1 year

-1 (0.00032 km-1

 year

-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 

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). The most fatalities of any industry in the private 

sector in 2008 occurred in the construction industry with 404 deaths in 2008 (BLS, 2009a). The 

construction incident rate of total recordable cases of non-fatal occupational injuries and illnesses 

in 2008 was 4.7 per 100 full-time workers (BLS, 2009b). 

4.9.2 Effects of ADM’s Proposed Project 

ADM’s proposed project would include pipe installation; construction and operation of a 

compression-dehydration facility; construction and operation of an education center; 

construction and operation of an electrical substation; 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 (DOE, 2008). 

The equipment that would be used for the implementation of the proposed project 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 procedures will be updated as necessary for 

the new project components (ADM, 2010d). 

Since almost all of the construction and operation of the proposed project is on ADM property, 

the increase in traffic from workers and delivery of equipment and materials should be partially 
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limited to onsite, which reduces risk to pedestrians and the public. However, the proposed 

project 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 (DOE, 2008). The expected increase in the number of trips due to the proposed project 

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 project 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 natural gas burning from the 

dehydration reboiler would produce limited air pollutants (ADM, 2010d). However, the 

proposed project only produces a very small amount of these air pollutants, and these are the 

same types and quantities as with any burning of natural gas. Thus, there would be a minimal 

risk to human health and safety. All necessary risk assessments would be conducted as part of 

the planning process and would be built on existing MGSC documentation as appropriate. 

The soils are not highly erodible (See Section 4.2); therefore, 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 will soon begin the construction permit process for the 

construction storm water discharges (ADM, 2010d). Water collected during the dehydration of 

the CO2 will be used for cooling tower make up water or send to the process water pretreatment 

plant. The pretreated water is subsequently sent to the City of Decatur Publicly Owned 

Treatment Works (DOE, 2008). Therefore, the overall effect of the proposed project to surface 

water quality is expected to not exceed the significance threshold. 

The only hazardous or toxic material used in the proposed project is CO2 (ADM, 2009a). Thus, 

if safety procedures and BMPs were 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. All necessary risk assessments would be 

conducted as part of the planning process and would be built on existing MGSC documentation 

as appropriate. All personnel would wear safety gear appropriate to the materials handled 

(ADM, 2010d). 

The design of the proposed project’s MVA plan would be to avoid, detect, and correct any 

unintended CO2 emissions (ADM, 2009a). The Eau Claire Formation, the Mt. Simon Sandstone, 

and the thick shale units present at the proposed injection site make groundwater contamination 

highly unlikely (DOE, 2008). However, groundwater monitoring would still occur to detect 

problems and initiate corrective action, if necessary. The groundwater monitoring would include 

testing for metals, ammonia, CO2, pH, dissolved oxygen, and other possible contaminants 

(ADM, 2010d) (See Section 4.3). This would allow for early detection and appropriate measures 
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to be initiated if there were any problems. This would reduce the risk to human health and 

safety. The final injection pressure would be below any fracture pressure for the formation, 

which will be estimated once the reservoir monitoring study and other information is completed 

(ADM, 2010d). Remaining below the fracture pressure 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, 2008; 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. 

Public education/outreach 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 public (DOE, 2007a). The primary human 

health risk from the proposed project to the 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, 2007a). In general, CO2 injection has occurred safely for over twenty years 

with oil and gas activities (NETL, 2008). Moreover, CO2 comprises the dominant (sometimes 

more than 90%) of many acid gas injections (hydrogen sulfide (H2S), CO2, and other 

constituents). Acid gas injections have occurred for years without causing any substantial harm 

from known incidents. Operational error rather than mechanical error has been the cause of most 

acid gas incidents (Heinrich et al., 2004). Thus, adherence to BMPs and following industry 

standards will be important to prevent incidents. Finally, there have been no fatalities or injuries 

among the public from an acid gas incident in the last 50 years (AERCB, 2008). Therefore, with 

proper safety procedures and plans, the risk to the public should not exceed the significance 

threshold. 

The wet, uncompressed CO2 would be transported in a 24-inch pipeline. Leaks from this wet, 

uncompressed CO2 would not be a substantial concern for human health and safety as it is 

currently discharged to the atmosphere (DOE, 2008). 

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 CO2 pipeline would be mostly aboveground, but will be installed underground as it enters a 

perpetual easement on approximately 200 feet on the Richland Community College property. 

Line markers would be used to locate the pipeline, and the location would be entered into the 

ADM database of plant facilities and information (ADM, 2010d). 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 would reduce the risk for 

CO2 leaks, and the mitigation measures would reduce the consequences of any incidents. 

Current monitoring systems will be used (ambient CO2 monitoring and alarm system). Any 
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additional necessary monitoring identified in the planning and design process would be initiated 

(ADM, 2010d). 

Too much pressure would cause automatic venting of the compressor and injection system to 

reduce the safety risks from equipment malfunction. Pipeline inspection and monitoring would 

reduce the risks of failures and thus to human health. A common mitigation measure for a 

leaking casing is venting the CO2 under appropriate controlled conditions (DOE, 2008). 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 (ADM, 2009a). 

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 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 project site and vicinity from worst case scenario(s) of 

atmospheric CO2 releases would be conducted in order to develop and 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 (ADM, 2010d). 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 project 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 and has experience with CO2 at supercritical conditions through the MGSC project 

(DOE, 2008). ADM’s safety procedures will be updated as necessary for the new project 
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components (ADM, 2010d). Workers would also be updated on safety procedures, especially 

ones related to handling of high pressure CO2 (DOE, 2008). Additionally, the proposed project 

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 MSGS has been completed, further risk 

assessments are likely to occur as part of the planning and designed phases as needed. 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 project 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 project’s purpose is to further the research for options in preventing global 

climate 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 

project in combination with any existing projects in the area (IPCC, 2005). There are no planned 

projects in or near the project area (ADM, 2010d). The cumulative impacts of existing activities 

in and around the project area, including the related MGSC project, 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 

project are 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 project 

(thus, implementing the No-Action alternative) would have an adverse impact on the progress 

toward 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 
Industrial Carbon Capture and Sequestration (ICCS) 

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& Environmental Effects 

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 (DOE, 2008). The closest National Register of Historic Places 

(NRHP) property is approximately 3 miles (5 km) away to the northeast from the project site 

boundary (HAARGIS, 2002; NPS, 2008a). Within the project area, the majority of the land is 

already disturbed (Figure 2.1.1-2). No archeological or historical resources have been found so 

far at the project site. Further, the project area is outside the "high archaeological resource 

potential area." This is defined as the presence of certain soil types, such 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 (NPS, 2008b). As part of the EA process, DOE will send 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 closest cemetery to the project area is St. John cemetery, which is 

approximately 1.5 miles (2.4 km) south from the project site boundary. 

ADM has not performed a cultural resources survey in the project area (ADM, 2010b). 

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 ADM’s Proposed Project 

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 project 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 
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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. 

During the EA process, the SHPO would make a determination on what level, if any, the project 

would have on cultural resources. However, 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 project. 

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 miles or 5 km), there should be no substantial impacts to visual resources 

to any known eligible or existing NRHP sites. During the EA process, DOE would send 

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. All issues these groups raise would be resolved. 

The cemetery is not in the location of the construction and operation. Thus, the proposed project 

should not have any direct impacts to the cemetery. The cemetery is in an industrial site, so the 

impacts from the proposed project should be no greater than what the cemetery has experienced 

in the past (See Sections 4.8.5 and 4.8.6). 

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 historic properties or human remains, then the construction component would need 

to be relocated elsewhere or other acceptable mitigation performed as per consultation with the 

SHPO and any relevant Tribes or agencies. 

Based on the information above, the impacts from implementing the proposed project are not 

expected to exceed the impact significance threshold. 

4.10.3 Effects of No-Action 

Under the No-Action alternative, ADM would not construct and operate the ICCS project. 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 (ADM, 2010d). Since there are no substantial 

impacts to cultural resources, the proposed project and the No-Action alternative do not 

substantially contribute to the cumulative impacts to cultural resources in the vicinity of the 
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& Environmental Effects 

project area or in the project area, considering also the finding of no substantial impacts to 

cultural resources for the related MGSC project. As impacts to cultural resources are generally 

local (heavy machinery crushing resources, etc.), the proposed project 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 an injection 

well and verification well, different types 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. 

All drilling waste disposal methods will be in accordance with existing ADM conditions for the 

Decatur ADM Complex as well as any and all applicable local/federal or state regulations as 

indicated from any permit requirements for the project. An earthen pit would be constructed and 

properly lined to contain and prevent ground water migration of drill cuttings, water-based 

drilling fluids, rig wash water and to a certain degree, rain water. 

As cuttings are produced by the drilling operation, they will be diverted to a lined earthen pit. 

After drilling operations are completed, the pit will be returned 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 (DOE, 2008). The permit application also indicated shallow groundwater monitoring 

wells would be drilled using appropriate coring tools, which would require the use of bentonite 

based drilling mud, or the use of hollow stem augers. 
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& Environmental Effects 

All wastewater would be directed to the wastewater treatment facility or the water re-use system 

that exists for the Decatur ADM Complex. Wastewater from the drilling would be evaluated, 

then treated, and discharged into the City system. If that cannot be the case, then ADM will 

dispose of it with its wastewater contract; it will be disposed of properly. 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 were selected for use, approximately 48 waste glycol 

particulate filters (half rich, half lean) would be generated per year. Glycol carbon filters are 

changed as needed. 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. 

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 would have weight enough to be in excess of formation pressure, 

thus no flow back is expected. Only during times when sampling is occurring would 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 (DOE, 2008). 

4.11.2 Effects of ADM’s Proposed Project 

Based on the volumes of drill waste generated, it is not anticipated that there will be any drilling 

wastes that exceed the significance threshold (DOE, 2008). All drilling waste disposal methods 

would be in accordance with existing local, state, or regulations. 
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& Environmental Effects 

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 

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 

capture, conditioning, 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, 

related to the drilling requirements of the proposed project, would not be expected to exceed the 

threshold of significance. Since drilling of the MGSC well has already occurred, the impact 

from that drilling activity is not considered cumulative to the proposed ADM project. 

Potential cumulative impacts related to the waste products from the compression and 

transportation of CO2 for the proposed project 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. The effects of the related 

MGSC project are additive to those of the proposed projects, but the combined total is still not 

expected to be substantial. 

There would likely be negligible cumulative impacts regarding wastes related to sampling and 

monitoring of the wells from both the MGC project and this proposed project due to the 

relatively small volumes of waste that would be generated from these activities. 

Overall, the proposed project would not cause air, water, or soil to be contaminated with waste 

(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. 
Industrial Carbon Capture and Sequestration (ICCS) 

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Consultation and Coordination 83 April 2011 

5.0 CONSULTATION AND COORDINATION 

5.1 Preparation for Development of this Environmental Assessment 

A kick-off teleconference occurred on August 23, 2010 by members of the team charged with the 

development of this EA. 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. 

5.2 Agency Coordination 

The Council on Environmental Quality’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. 

5.2.1 U.S. Fish and Wildlife Service 

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. 

See Appendix C for letter sent to agency. 

5.2.2 State Historic Preservation Office (SHPO) 

The National Historic Preservation Act (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. 

See Appendix D for letter sent to and received from the SHPO. 

5.2.3 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. 

See Appendix E for letters sent to the Bureau of Indian Affairs and Tribal Councils. 

5.2.4 State Agencies 
Industrial Carbon Capture and Sequestration (ICCS) 

Area 1 Project Final Environmental Assessment

Consultation and Coordination 84 April 2011 

Illinois Department of Natural Resources and Illinois Environmental Protection Agency were 

consulted, and correspondences with these agencies are in Appendix F. 
Industrial Carbon Capture and Sequestration (ICCS) 

Area 1 Project Final Environmental Assessment

List of Preparers 85 April 2011 

6.0 LIST OF PREPARERS 

6.1 Mangi Environmental Group 

James Mangi; Contract Management 

Dave Henney; EA Project Manager, Proposed Action; No-Action, Project Location; 

Alternatives, Land Use, Visual Resources 

Randy Williams; Water Resources, Waste Management 

Erica Earhart; Geology and Soils 

Meghan Morse; Associate Project Manager, Document/Administrative Record Management, 

Human Health and Safety, Cultural Resources 

Eveline Martin; Wetlands, Wildlife, Terrestrial Plants 

Tim Lavallee; Air Quality, Noise 

Rick Heffner; Socioeconomics 
Industrial Carbon Capture and Sequestration (ICCS) 

Area 1 Project Final Environmental Assessment

References 86 April 2011 

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(IPCB, 2002). Illinois Pollution Control Board. 2002. Environmental Regulations. Accessed 

February 2010 at http://www.ipcb.state.il.us/SLR/IPCBandIEPAEnvironmentalRegulationsTitle35.asp. 

(IPCC, 2005). Intergovernmental Panel on Climate Change. 2005. IPCC Special Report on

Carbon Dioxide Capture and Storage. Accessed on February 2010 at 

http://www.ipcc.ch/publications_and_data/publications_and_data_reports_carbon_dioxide.htm. 

(ISGS, 1996). Illinois State Geological Survey. 1996. Quaternary Deposits of Illinois. Accessed 

February 2010 at http://www.isgs.uiuc.edu/maps-data-pub/publications/pdf-files/quaternarydeposits-8x11.pdf. 

(ISM, 1994). Illinois State Museum. 1994. Archaeological Resource Potential in Illinois by 

County: ISM GIS Database archmod. Accessed February 2010 at 

http://www.isgs.uiuc.edu/nsdihome/outmeta/IL_Arch_Resource_Potential_Py.html. 

(Miller, 2003). Miller, G. Tyler. 2003. Environmental Science. 9th edition. Pacific Grove, 

California: Brooks/Cole-Thomson Learning. 

(National Atlas, 2008). National Atlas. 2008. Map Layers. Accessed February 2010 at 

http://nationalatlas.gov/maplayers.html?openChapters=chpbio#chpbio. 

(NETL, 2008). 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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References 91 April 2011 

Underground? Accessed February 2010 at 

http://www.netl.doe.gov/publications/factsheets/program/Prog064.pdf. 

(NPS, 2008a). National Park Service. 2008. National Register Listed Properties in Google Earth. 

Accessed February 2010 at http://nrhp.focus.nps.gov/natreg/docs/Download.html. 

(NPS, 2008b). National Park Service. 2008. Native American Consultation Database Search 

(NACD). Accessed February 2010 at http://home.nps.gov/nacd/. 

(NRCS, 2009). Natural Resources Conservation Service Soil Survey Staff, United States 

Department of Agriculture. 2009. Official Soil Series Data. Accessed September 2010 at 

http://soils.usda.gov/technical/classification/osd/index.html. 

(NRCS, 2008). Natural Resources Conservation Service Soil Survey Staff, United States 

Department of Agriculture. 2008. Official Soil Series Descriptions. Accessed September 2010 at 

http://soils.usda.gov/technical/classification/osd/index.html. 

(NRCS, 2007). Natural Resources Conservation Service Soil Survey Staff, United States 

Department of Agriculture. 2007. Official Soil Series Image. Accessed September 2010 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 February 2010 at www.sws.uiuc.edu/pubdoc/CR/ISWSCR2001-

11.pdf. 

(Schlumberger, 2008). 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, 2008). United Nations Framework Convention on Climate Change. 2008. Kyoto 

Protocol Reference Manual on Accounting of Emissions and Assigned Amounts. Accessed 

February 2010 at http://unfccc.int/resource/docs/publications/08_unfccc_kp_ref_manual.pdf. 

(USEPA, 2009a). U.S. Environmental Protection Agency. 2009. Climate Change. Accessed 

February 2010 at www.epa.gov/climatechange/basicinfo.html#emissions. 

(USEPA, 2009b). U.S. Environmental Protection Agency. 2009. Basic Information: Air and 

Radiation. Accessed February 2010 at http://www.epa.gov/air/basic.html. 

(USEPA, 2008). U.S. Environmental Protection Agency. 2008. USEPA AirDATA Website. 

Accessed February 2010 at http://www.epa.gov/oar/data/. 
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References 92 April 2011 

(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 February 2010 at 

http://www.nonoise.org/library/levels74/levels74.htm#table%20of%20contents. 

(USFWS, 2009a). United States Fish and Wildlife Service. 2009. Wetland Codes. Accessed 

February 2010 at http://www.fws.gov/wetlands/Data/wetlandcodes.html. 

(USFWS, 2009b). United States Fish and Wildlife Service. 2009. Endangered Species in Illinois 

County Distribution of Federally Threatened, Endangered, Proposed and Candidate Species - 

By County. Accessed February 2010 at 

http://www.fws.gov/midwest/endangered/section7/sppranges/illinois-cty.html. 

(USFWS, 2009c). United States Fish and Wildlife Service. 2009. Endangered Species Section 

7(a)(2) Consultation. Accessed February 2010 at 

http://www.fws.gov/midwest/endangered/section7/s7process/index.html. 

(USFWS, 1987). United States Fish and Wildlife Service. National Wetlands Inventory. 1987. 

Wetlands and Deepwater Habitats of the Conterminous United States - Illinois. Accessed 

February 2010 at http://www.fws.gov/wetlands/Data/DataDownload.html. 

(USGS, 2007). United States Geological Survey. 2007. Water-Data Report 2007 05573540 

Sangamon River at Route 48 at Decatur, IL. Accessed February 2010 at 

http://wdr.water.usgs.gov/wy2007/pdfs/05573540.2007.pdf. 

(Weibel, 2010). C. Pius Weibel, Senior Geologist. Illinois State Geological Survey. Personal 

Communication. Data gaps for EIV. February 3, 2010. 
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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. 

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. 

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. 

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. 
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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 longterm 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. 
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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. 

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. 

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 
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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. 

Particulate 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. 

pH – The measure of the acidity or alkalinity of a solution. 

Porosity – A measure of the void spaces in a material. 

Quaternary – The 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. 
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Supercritical CO2 – Carbon dioxide that is in a fluid state while also being at or above both its 

critical temperature and pressure. 

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 UseEquipment Type Number of Units Days on Site Hours Per Day Operating HoursBore/Drill Rigs 1 90 24 2160 Generator Sets 4 90 24 8640 Other Construction Equipment 3 90 24 6480 Drilling Equipment Emission Factors (pounds (lbs)/hour) Equipment CO NOx VOC SOx Bore/Drill Rigs 0.5281 1.3416 0.1295 0.0017 0Generator Sets 0.3461 0.6980 0.1075 0.0007 0Other Construction Equipment 0.4504 1.1575 0.1215 0.0013 0Source: (CARB, 2007b) Drilling Equipment Emissions (tons) Equipment CO NOx VOC SOx Bore/Drill Rigs 0.5704 1.4489 0.1399 0.0019 0Generator Sets 1.4952 3.0154 0.4642 0.0030 0Other Construction Equipment 1.4592 3.7504 0.3937 0.0041 0Total Equipment Emissions 3.5247 8.2147 0.9978 0.0090 0Drilling Worker Commutes Number of Workers 30Number of Trips 2Miles Per Trip 30Days of Drilling 90Total Miles 162000Pollutant CO NOx VOC SOx Emission Factor (lbs/mile) 0.0105 0.0011 0.0011 0.0000 0Total Emissions (lbs) 1708.85 178.67 174.83 1.74 Total Emissions (tons) 0.8544 0.0893 0.0874 0.0009 0Source: (CARB, 2007b) Total Drilling Emissions (tons) Activity/Source CO NOx VOC SOx Heavy Equipment 3.5247 8.2147 0.9978 0.0090 0Worker Commutes 0.8544 0.0893 0.0874 0.0009 0Total Drilling Emissions per well 4.3791 8.3040 1.0852 0.0099 0
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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 PMAir Compressors 0.3782 0.7980 0.1232 0.0007 0.0563 0.05Cement and Mortar Mixers 0.0447 0.0658 0.0113 0.0001 0.0044 0.00Cranes 0.6011 1.6100 0.1778 0.0014 0.0715 0.07Generator Sets 0.3461 0.6980 0.1075 0.0007 0.0430 0.04Tractors/Loaders/Backhoes 0.4063 0.7746 0.1204 0.0008 0.0599 0.05Source: (CARB, 2007b) Construction Equipment Emissions (tons)Equipment CO NOx VOC SOx PM10 PMAir Compressors 0.0227 0.0479 0.0074 0.0000 0.0034 0.00Cranes 0.0631 0.1691 0.0187 0.0001 0.0075 0.00Generator Sets 0.0363 0.0733 0.0113 0.0001 0.0045 0.00Tractors/Loaders/Backhoes 0.0427 0.0813 0.0126 0.0001 0.0063 0.00Total Equipment Emissions 0.1648 0.3716 0.0500 0.0003 0.0217 0.02Painting VOC Content 1.25 lbs/gallon Coverage 400 ft2/gallon Emission Factor 0.003125 lbs/ft2Building/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 
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Table A-2. Construction Emissions (Continued) 

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 Emission Factor (lbs/mile) 0.0219 0.0237 0.0030 0.0000 0.0009 Total Emissions (lbs) 79.02 85.37 10.77 0.09 3.08 Total Emissions (tons) 0.0395 0.0427 0.0054 0.0000 0.0015 Source: (CARB, 2007b) Worker Commutes Number of Workers 20 Number of Trips 2 Miles Per Trip 30 Days of Construction 30 Total Miles 36000 Pollutant (pounds/mile) CO NOx VOC SOx PM10 Emission Factor (lbs/mile) 0.0105 0.0011 0.0011 0.0000 0.0001 Total Emissions (lbs) 379.74 39.70 38.85 0.39 3.06 Total Emissions (tons) 0.1899 0.0199 0.0194 0.0002 0.0015 Source: (CARB, 2007b) Total Construction Emissions (tons) Activity/Source CO NOx VOC SOx PM10 Construction Equipment 0.1648 0.3716 0.0500 0.0003 0.0217 Painting 0.0000 0.0000 0.0094 0.0000 0.0000 Delivery of Equipment and Supplies 0.0395 0.0427 0.0054 0.0000 0.0015 Worker Commutes 0.1899 0.0199 0.0194 0.0002 0.0015 Total Construction Emissions 0.3942 0.4341 0.0842 0.0006 0.0248 
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Table A-3. CO2 Emission Calculations 

Drilling and Construction Diesel Fuel Usage 500 Gallons Per DayDrilling Period 90 DaysTotal Fuel 45000 GallonsTotal Fuel 170343 LitersEmission Factor 2.6304 kg CO2 per literTotal Emissions 448070.2 kgTotal Emissions 494 TonsElectricity Usage Electricity Usage 12000 kWHours 21900 HoursPower 262800000 Emission Factor 0.6510 kg CO2/KwhTotal Emissions 171082800 kgTotal Emissions 188587 TonsWorker Commutes Number of Workers 20 WorkersNumber of Trips 2 TripsMiles Per Trip 30 MilesDays of Operation 913 DaysTotal Miles 1095000 MilesEmission Factor 1.1 lbs/mileTotal Emissions 1204500 lbsTotal Emissions (tons) 602.0 tonsSource: (CARB, 2007b) Total CO2 Emissions (tons) Activity/Source Emissions (tons)Drilling and Construction 988 Electricity Usage 188587 Worker Commutes 602 Sequestration (2500000)Total Emissions Reduction (2309823)

Note: kWh is kilowatt hour, kW is kilowatt, and kg is kilogram. 
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Area 1 Project Final EnvirAppendix B 102 Appendix B Noise Calculations 

Table B-1. Drilling Noise

 Feet Meters NSA 1 - Community College 860 262 

Octave Band Center Frequency, Hz 

Source 31.5 63 125 250 500 1000 2000 

Drill Rig (at 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 inch 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) (at 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 (at 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 -62 -62 -62 -62 -62 -62 -62 Atmospheric Absorption 0 0 0 0 -1 -1 -2 Flat Sound Level 62 58 58 53 51 51 49 Octave Band A-Weighted Correction -39 -26 -16 -9 -3 0 1 A-Weighted Sound Level 23 32 42 44 48 51 50 Notes: Calculations based on available data from typical equipment set-ups, actual equipment would vary dependent on results of geotechnical evaluation and 

site-specific design. 

Calculations do not account for effect of topographic features, reflection, and natural barriers Lw is sound power levels, and Ldn is Equivalent Day Night Level. CF is center frequency 
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Table B-2. Compressor Noise

 Feet Meters NSA 1 - Community College 2500 762 

Octave Band Center Frequency, Hz 

Source 31.5 63 125 250 500 1000 2000 4000 

Reciprocating Compressor 12000.0 CF 11 15 10 11 13 10 5 8 

 Lw 129.5 PWL 119 115 120 119 117 120 125 122 

Total Sound Intensity 0.7108 0.2830 0.8949 0.7108 0.4485 0.8949 2.8298 1.4182 

Total PWL 119 115 120 119 117 120 125 122 

Hemispherical Spreading -72 -72 -72 -72 -72 -72 -72 -72 Atmospheric Absorption 0 0 0 -1 -2 -4 -7 -18 Octave Band A-Weighted Correction -39 -26 -16 -9 -3 0 1 1 A-Weighted Sound Level (without barrier) 8 17 32 37 40 44 47 33  Feet Meters  Critical Distance Calculation 1300 396 

Octave Band Center Frequency, Hz 

Source 31.5 63 125 250 500 1000 2000 4000 

Reciprocating Compressor 12000.0 CF 11 15 10 11 13 10 5 8 

 Lw 129.5 PWL 119 115 120 119 117 120 125 122 

Total Sound Intensity 0.7108 0.2830 0.8949 0.7108 0.4485 0.8949 2.8298 1.4182 

Total PWL 119 115 120 119 117 120 125 122 

Hemispherical Spreading -66 -66 -66 -66 -66 -66 -66 -66 Atmospheric Absorption 0 0 0 0 -1 -2 -4 -9 Octave Band A-Weighted Correction -39 -26 -16 -9 -3 0 1 1 A-Weighted Sound Level (without barrier) 14 23 38 43 47 52 56 48 
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Appendix C USFWS Consultation 
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Appendix D SHPO Consultation 
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Figure 1. ADM Project Map 
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Figure 2. ADM Topographic Map with NRHP site 
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Figure 3. ADM Site Plan 
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Figure 4. Side Exterior View of Blower Building 

Figure 5. Rear Exterior View of Blower Building 
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Figure 6. First Interior View of Blower Building 

Figure 7. Second Interior View of Blower Building 
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Figure 8. Third Interior View of Blower Building 
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SHPO Response
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Appendix E Consultation with Tribes 

The enclosures are at the section’s end. 
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ADM Project Map 
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No responses received
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Appendix F State Agencies 

The enclosure is at the section’s end. 
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ADM Project Map 
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Illinois DNR Response
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Illinois EPA Response
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Appendix G Environmental Synopsis 
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ENVIRONMENTAL SYNOPSIS 

Industrial Carbon Capture & Sequestration (ICCS) 

Technology Area I 

DE-FOA-0000015 

January 2011 

National Energy Technology Laboratory 

U.S. Department of Energy 

Morgantown, West Virginia 
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INTENTIONALLY LEFT BLANK 

 
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CONTENTS 

INTRODUCTION 1

BACKGROUND 1

PURPOSE AND NEED 134

ALTERNATIVES 3

ENVIRONMENTAL REVIEW 3

CONCLUSION 6
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INTENTIONALLY LEFT BLANK 
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INTRODUCTION

The U.S. Department of Energy (DOE or the Department) prepared this Environmental Synopsis pursuant 

to the Department’s responsibilities under section 216 of DOE’s National Environmental Policy Act 

(NEPA) Implementing Procedures set forth in 10 CFR Part 1021. This synopsis summarizes the 

consideration given to environmental factors and records that the relevant environmental consequences of 

reasonable alternatives were evaluated in the process of selecting awardees seeking financial assistance 

under Technology Area 1 of the Industrial Carbon Capture and Sequestration (ICCS) program In 

addition to financial and technical elements, DOE considered relevant environmental factors and 

consequences of the projects proposed to DOE in response to the funding opportunity announcement 

(FOA). DOE initially selected 12 applicants seeking financial assistance under Technology Area 1 and 

provided cost-shared funding for project definition activities; DOE then selected three of the initial twelve 

awardees for continued funding beyond project definition, pending completion of project-specific NEPA 

reviews. As required by section 216, this synopsis does not contain business, confidential, trade secret or 

other information that statutes or regulations would prohibit DOE from disclosing. It also does not 

contain data or other information that may in any way reveal the identity of the offerors.2

 

BACKGROUND

The ICCS program is a cost-shared collaboration between the government and industry to increase 

investment in clean industrial technologies and carbon capture and sequestration (CCS) projects. In 

contrast to other federally funded activities, these projects are not federal projects; instead, they are 

private projects seeking federal financial assistance. Under the ICCS funding opportunity, industry 

proposes projects that meet their needs and those of their customers while furthering the national goals 

and objectives of DOE. The successful development of advanced technologies and innovative concepts 

that reduce emissions of carbon dioxide into the atmosphere is a key objective of the nation’s effort to 

help mitigate the effects of climate change. 

Awardees under this FOA would receive assistance using funds appropriated by the American Recovery 

and Reinvestment Act of 2009, Public Law 111-5, (Recovery Act). The Recovery Act’s purposes are to 

stimulate the economy and to create and retain jobs. Accordingly, special consideration was given to 

projects that promote and enhance job creation, preservation and economic recovery, in an expeditious 

manner. In accordance with the Recovery Act, and Section 703 of Public Law 110-140, DOE’s two 

specific objectives were identified in the FOA as (1) Technology Area 1 – Large-Scale Industrial CCS 

Projects from Industrial Sources; and (2) Technology Area 2 – Innovative Concepts for Beneficial CO2

Use. This synopsis specifically deals with the review process conducted for applications under 

Technology Area 1. 

The applications reviewed under this FOA were initially selected for a first phase funding in October 

2009 as the first of a two phase process for final awards of financial assistance. Under Phase I of the 

review process for Technology Area 1, DOE selected 12 projects related to the capture of CO2 from 

industrial sources for geological storage or enhanced oil recovery (EOR). During Phase I, DOE provided 

cost shared funding for applicants to conduct project definition activities (e.g. preliminary design and 

permitting) and to prepare information that would assist the Department in performing its obligations 

pursuant to NEPA. Near the end of Phase I, awardees were given an opportunity to submit renewal 

applications for Phase II awards that would provide financial assistance for detailed design, construction 

and demonstration of the proposed technologies. DOE received eight renewal applications from the 12 

projects selected under Phase I. 

 

2

 The three awardees selected for continued financial assistance are identified in this synopsis and information on 

these proposed projects will be available on the DOE National Energy Technology Laboratory web site at 

http://www.netl.doe.gov/technologies/iccs/index.html. 
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Applications under the ICCS program were evaluated against specific programmatic criteria: 

• Technology merit, technical plan, and site suitability; 

• Project organization and project management plan; 

• Commercial potential; 

• Funding plan; 

• Financial condition and capacity of proposed funding sources; 

• Financial commitment to meet cost-sharing requirements. 

These criteria represented the total evaluation scoring. However, the selection official also considered the 

results of the environmental evaluation and the applicant’s budget information and financial management 

system, as well as program policy factors, in making selections. 

As a federal agency, DOE must comply with NEPA (42 U.S.C. §§ 4321 et seq.) by considering potential 

environmental issues associated with its actions prior to deciding whether to undertake these actions. The 

environmental review of applications received in response to the ICCS FOA was conducted pursuant to 

Council on Environmental Quality Regulations (40 Code of Federal Regulations (CFR) Parts 1500 - 

1508) and DOE’s NEPA Implementing Procedures (10 CFR Part 1021), which provide directions specific 

to NEPA in the context of procurement and financial assistance actions. 

PURPOSE AND NEED

The purpose and need for DOE’s selections of awardees under the ICCS Program are to satisfy the 

responsibility Congress imposed on the Department to carry out a program to demonstrate technologies 

for the large-scale capture of CO2 from industrial sources. Technology Area 1 under the FOA focused on 

the demonstration of advanced technologies that capture and sequester carbon dioxide emissions from 

industrial sources into underground formations or put the CO2 to beneficial use in a manner that 

permanently prevents the CO2 from entering the atmosphere, including the expansion of CO2 use in EOR, 

while providing information on the cost and feasibility of deployment of sequestration technologies. 

Therefore, under the FOA, DOE sought projects with technologies that have progressed beyond the 

research and development stage to a point of readiness for operation at a scale that, if successful, could be 

readily replicated and deployed into commercial practice within the industry. 

The industrial technologies proposed could produce heat, fuels, chemicals, hydrogen or other useful 

products with or without production of electricity. Thus, industrial sources could include cement plants, 

chemical plants, refineries, steel and aluminum plants, manufacturing facilities, and power plants using 

opportunity fuels (petroleum coke, municipal waste, etc.). DOE sought projects at a sufficient scale to 

show the potential for market penetration upon successful demonstration of the technology, and be 

integrated with commercial plant operation. DOE also allowed for leading-edge technologies not 

currently deployed in the utility marketplace or CO2 injection industry, as opposed to new applications of 

commercial technologies or incremental improvements of commercial technologies or previously 

demonstrated technologies. DOE’s specific technical objectives included demonstrating: 

 Projects that capture and sequester amounts of CO2 approaching or exceeding a target of one 

million tons per plant per year; 

 Projects with large-scale CCS that include integration of CO2 capture, transportation and 

sequestration with comprehensive MVA;

 Geological sequestration in multiple geological settings as a means to evaluate costs, operational 

processes, and technical performance; 

 CO2 capture technologies that are integrated within existing or new industrial facilities;
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 Projects capable of operating technologies that make progress toward the capture and 

sequestration of seventy-five percent of CO2 from the treated stream, comprising at least ten 

percent of CO2 by volume that would otherwise be emitted to the atmosphere; and 

 Projects at a sufficient scale to show the potential for market penetration;

ALTERNATIVES

DOE received eight Phase II renewal applications out of the twelve projects selected for Phase I in ICCS 

Technology Area 1, all of which were determined to have met the mandatory eligibility requirements 

listed in the FOA. The applications proposed projects located in eight states: California, Illinois, Kansas, 

Louisiana, Michigan, Mississippi, Texas, and Washington. The criteria for evaluating Phase II 

applications under ICCS Technology Area 1 were published in the FOA. Technical and financial 

evaluations represented the total evaluation scoring; however, the environmental evaluation, which was 

not point-scored, entered into the evaluation and selection process. Each applicant was required to 

complete and submit a standard environmental information volume for each site or alternative site 

included in its application. 

The evaluations of the applications focused on the technical description of the proposed project, financial 

plans and budgets, potential environmental impacts, and other information that the applicants submitted. 

Following reviews by technical, environmental, and financial panels and a comprehensive assessment by 

a merit review board, a DOE official selected those applications that best met DOE’s purpose and need. 

By broadly soliciting proposals to meet the programmatic purpose and need for DOE action and by 

evaluating the potential environmental impacts associated with each proposal before selecting applicants, 

DOE considered a reasonable range of alternatives for meeting its purpose and need. 

Applications were divided into two broad categories: 

 Group 1: Addition of Carbon Capture Equipment at an Existing and Operating Facility; and 

 Group 2: Addition of Carbon Capture Equipment at a Planned or Yet-to-Be Constructed Facility. 

DOE received five applications for existing and operating facilities (Group 1) and three applications for 

planned or yet-to-be constructed facilities (Group 2). 

ENVIRONMENTAL REVIEW

DOE assembled environmental review teams to assess all applications that met the mandatory 

requirements. The review teams considered 20 resource areas that could potentially be impacted by the 

technologies and sites proposed under ICCS Technology Area 1. These resource areas consisted of: 

 Aesthetics 

 Air Quality 

 Biological Resources 

 Climate 

 Community Services 

 Cultural Resources 

 Environmental Justice 

 Floodplains 

 Geology 

 Ground Water 

 Human Health and Safety 

 Land Use 

 Noise 

 Socioeconomics 

 Soils 

 Surface Water 

 Transportation and Traffic 

 Utilities 

 Wastes and Materials 

 Wetlands 

The review teams were composed of environmental professionals with experience evaluating the impacts 

of industrial facilities, power plants, and energy-related projects in the resource areas considered by DOE. 
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The review teams considered the information provided as part of each application, which included 

narrative text, worksheets, and the environmental information volumes for the sites proposed by the 

applicant. In addition, reviewers independently verified the information provided to the extent practicable 

using available sources commonly consulted in the preparation of NEPA documents, and conducted 

preliminary analyses to identify the potential range of impacts that would be associated with each 

application. Reviewers identified both direct and indirect potential impacts to the resource areas 

mentioned above, as well as short-term impacts that might occur during construction and start-up, and 

long-term impacts that might occur over the expected operational life of the proposed project and beyond. 

The reviewers also considered any mitigation measures proposed by the applicant and any reasonably 

available mitigation measures that may not have been proposed. 

Reviewers assessed the potential for environmental issues and impacts using the following 

characterizations: 

 Beneficial – Expected to have a net beneficial effect on the resource in comparison to baseline 

conditions. 

 None (negligible) – Immeasurable or negligible in consequence (not expected to change baseline 

conditions). 

 Low – Measurable or noticeable but of minimal consequence (barely discernable change in baseline 

conditions). 

 Moderate – Adverse and considerable in consequence but moderate and not expected to reach a level 

of significance (discernable, but not drastic, alteration of baseline conditions). 

 High – Adverse and potentially significant in severity (anticipated substantial changes or effects on 

baseline conditions that might not be mitigable). 

For cases in which an application failed to provide sufficient information to support a determination 

among the above characterizations, the reviewers assigned one of the following characterizations: 

 Limited Concern – The potential for substantial adverse impacts would be negligible to low based 

on background information about the resource area with respect to the geographic location of the 

project. 

 Elevated Concern – The potential for substantial adverse impacts would be moderate to high based 

on background information about the resource area with respect to the geographic location of the 

project. 

Applications in Response to the FOA

Based on the technologies and sites proposed, none of the applications were deemed to have a high 

potential for adverse impacts in eighteen of the twenty resource areas. However, one application was 

considered to have potential for high adverse impacts to floodplains, with another having high potential 

for health and safety concerns. The following impacts by resource area were considered in the selection 

of candidates for award: 

Aesthetics –Low to moderate impacts would be expected for one facility. This site would be located 

within view of a residential area; however, it would be located where a previous facility stood that posed 

similar aesthetic issues, leading to little relative change. Low impacts were projected for all remaining 

sites. Temporary impacts could result at one site due to construction of a CO2 pipeline near a National 

Historic Trail. 

Air Quality – Moderate impacts would be expected for five projects, with three of them having elevated 

concerns due to new sources of criteria pollutants from planned or yet-to-be constructed plants. The other 

two facilities with expected moderate impacts would add new energy-generating systems to their plants as 
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part of the project. Low impacts were anticipated for the remaining three projects. Concerns included 

increases in emissions of volatile organic compounds from four sites, increases in NOx emissions from 

two sites, and increase in PM2.5 and SO2 emissions at one site. Temporary impacts from fugitive dust and 

combustion equipment were expected from all sites as a result of construction activities. 

Biological Resources – Moderate impacts would be expected for four projects due to plant construction 

and land clearing activities. Impacts to aquatic species and habitat would be a concern for two projects as 

a result of process water intake, water discharge, and potential for accidental chemical release. Low 

impacts would be expected for the remaining sites. 

Climate – Beneficial impacts would be expected for all projects as a result of greenhouse gas emissions 

reductions. 

Community Services – Low impacts would be expected for all but one project, which would involve a 

new power plant. Generally, projects anticipating a larger temporary workforce during construction 

would be expected to place a higher demand on community services – particularly in smaller, more rural 

communities where currently existing community services are more limited. 

Cultural Resources – Moderate impacts would be expected for two projects due to their proximity to 

multiple sites eligible for the National Register of Historic Places and other cultural resources. Low 

impacts would be expected for the remaining six projects. Potential impacts would include tribal 

concerns over pipeline routes. Impacts would vary with the extent of known tribal claims and their 

proximity to the proposed project or pipeline route. 

Environmental Justice – Moderate impacts would be expected for one project due to the potential for 

disproportionate effects on minorities if an accidental release of hazardous chemical were to occur. Low 

impacts would be expected for the remaining projects, typically a function of lesser concentrations of low 

income and minority populations in surrounding areas. 

Floodplains – Moderate to high impacts would be expected for three projects due to siting of the CO2

capture facilities partially or totally within floodplains, and there would be limited concern for one site for 

which the floodplains are not delineated. Low to no impacts would be expected for the remaining 

proposed facilities. Low to moderate potential impacts during pipeline construction or pipeline routing 

would be expected for all but one project for which there are no floodplains within the proposed route. 

Floodplains would be impacted by any activity that modifies the available flood storage within the 

designated area; however, long-term potential impacts on the corridors would be minimal provided the 

surface contours are returned to preconstruction conditions. 

Geology –Moderate impacts would be expected at one project due to sequestration within a rock 

formation largely untested for storage effectiveness. One project alternative presents elevated concern as 

it has potential for caprock fracture combined with abnormally high levels of hydrogen sulfide (H2S) in 

the formation water. The potential for low to moderate impacts exists for all applications, either from 

CO2 injection into saline aquifers or use for enhanced oil recovery. 

Ground Water – Low impacts would be expected for all projects. Impacts could include displacement of 

saline waters in reservoirs targeted for CO2 injection or loss of CO2 containment should injection 

pressures exceed appropriate thresholds. 

Human Health and Safety – Low to moderate impacts would be expected for all projects due to hazards 

associated with construction. The level of risk is generally related to the size and complexity of the 

planned construction. There could also be a risk to human health and safety from loss of containment of 

CO2 during transport and injection. This risk is present for all applications and generally varies from low 

to moderate with distance and is influenced by population density along the CO2 transport route. Shorter 

routes through sparsely populated areas were considered to have a lower risk than longer routes through 

regions of higher population. Low to moderate potential impacts could also be expected resulting from 
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hazards associated with use, storage, and transport of ammonia for the CO2 capture process. One project 

has a high potential impact due to the proximity of CO2 pipelines to seismic faults and potential 

fracturing. 

Land Use – Low impacts would be expected for all projects. 

Noise – Moderate temporary impacts would be expected during construction of the pipeline routes for 

two projects that would pass near sensitive receptors. Long-term impacts during operations would be 

expected to be low for all projects. 

Socioeconomics – Beneficial impacts would be expected for all projects. All projects would provide 

some additional employment as a result of construction, operations, and multiplier effects. Most 

employment opportunities would be in the local area. 

Soils – Low impacts would be expected for projects located on previously disturbed land or within 

proximity to other industrial facilities. Moderate impacts would be expected for those projects with 

disturbances to prime farmland soils. One project would be located on a brownfield site, requiring 

additional remediation. 

Surface Water – Moderate impacts would be expected for four projects due to proposed pipeline 

crossings of numerous streams and other water bodies, including one project where the pipeline crosses a 

major river. Moderate impacts would also be expected for two of the projects due to increased water 

demand. Low impacts would be expected for the remaining four projects. Increased sediment and 

nutrient loadings associated with increased stormwater runoff would be a concern for all projects. 

Transportation and Traffic – Low impacts would be expected for all projects. Temporary impacts from 

construction are likely; however, operations would not be expected to result in any long-term traffic 

problems. 

Utilities – Moderate impacts would be expected for five projects, associated with the supply of electricity 

for the CO2 capture and compression systems. Low impacts would be expected for the remaining three 

projects. 

Wastes and Materials – Low to moderate impacts would be expected for all projects due to required 

materials used and waste generated during operations of the CO2 capture facilities, and wastes generated 

during construction, typically proportional to the size of the project. 

Wetlands –Low impacts would be expected for all projects but one, which would have moderate impacts 

from more extensive wetland clearing as a result of CO2 pipeline construction and ROW clearing. 

CONCLUSION

The alternatives available to DOE from applications received in response to the FOA for ICCS 

Technology Area I provided reasonable alternatives for accomplishing the Department’s purpose and 

need to satisfy the responsibility Congress imposed on the Department to carry out a program to 

demonstrate technologies for the large-scale capture of CO2 from industrial sources. The alternatives 

available to DOE would also meet the Department’s goal of demonstrating advanced technologies that 

capture CO2 emissions from industrial sources and either sequester the CO2 in underground formations or 

put the CO2 to beneficial use that permanently prevents it from entering the atmosphere. An 

environmental review was part of the evaluation process of these applications. DOE prepared a critique 

containing information from this environmental review. That critique, summarized here, contained 

summary as well as project-specific environmental information. The critique was made available to, and 

considered by, the selection official before selections for financial assistance were made. 

DOE determined that selecting three applications in response to the FOA Technology Area 1 would meet 

the Department’s purpose and need. DOE selected three projects for awards of financial assistance: 
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 Archer Daniels Midland Company (Decatur, IL) – project location in Decatur, IL. CO2 capture 

from biofuels production and sequestration in the Mt. Simon sandstone formation; DOE 

determined that an environmental assessment is the appropriate level of environmental review for 

the proposed project. 

 Air Products & Chemicals, Inc. (Allentown, PA) – project location in Port Arthur, TX. CO2

capture from steam methane reforming process and transport to the Denbury Green Pipeline for 

use in EOR; DOE determined that an environmental assessment is the appropriate level of 

environmental review for the proposed project. 

 Leucadia Energy, LLC (New York, NY) – project location in Lake Charles, LA. CO2 capture 

from flue gas from yet-to-be constructed petroleum coke gasification plant and transport to the 

Denbury Green Pipeline for use in EOR; DOE determined that an environmental impact 

statement is the appropriate level of environmental review for the proposed project. 
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Appendix H NWI Online Wetlands Mapper Screen shot taken 14 April 2011 from http://137.227.242.85/wetland/wetland.html
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Appendix I Correspondence with USEPA Region 5 
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