EPA should halt CO2 sequestration operations in Decatur
The USEPA is requesting public comment on its proposed order against ADM Co. for allegedly violating the Safe Drinking Water Act at its carbon sequestration facility in Decatur. Specifically, ADM is accused of sequestering CO2 in unauthorized areas in violation of its permit. While the order against ADM focuses on a leak that occurred in one unpermitted area in March 2024, ADM and the EPA were aware of two other surface leaks and one subsurface leak that took place between November 2021 and the end of 2022. The public was not informed of the leaks until September 2024 thanks to the efforts of an investigative reporter.
The four leaks, combined with a fluid anomaly that took place at a different well in September 2024, could lead to the conclusion that there are systemic problems at ADM’s carbon sequestration facility, ADM had an ethical responsibility to report all leaks to interested parties in a timely manner and failed to do so, and the EPA has demonstrated an inability to take appropriate action to protect the safety of Decatur’s residents and protect our environment.
Thankfully, the four leaks and a fluid anomaly at two different wells in less than 3 years have not reportedly impacted drinking water quality, however, citizens are justified in asking whether a more significant leak is inevitable, and why the USEPA would permit CO2 sequestration activities to take place in highly populated areas and under a municipality’s main drinking water source.
RESIDENTS CAN EXPRESS CONCERNS TO THE EPA
The EPA is accepting public comment on its proposed order against ADM for its alleged violations of the Safe Drinking Water Act. Public comments are due October 21, 2024. To learn more about the proposed order, visit: https://www.epa.gov/newsreleases/epa-announces-proposed-order-requiring-archer-daniels-midland-co-take-actions-ensure. To submit public comments about the proposed order, visit: https://www.epa.gov/il/forms/comment-form-adm-geologic-sequestration-well-proposed-order-sdwa-05-2025-0001?emci=7e0bfccb-418b-ef11-8473-0022483029fa&emdi=16943688-498b-ef11-8473-0022483029fa&ceid=14205839. Below is a draft of the letter that I am planning to submit to the EPA. Feel free to use this letter as a template for your own letter if you wish to write one.
SAMPLE LETTER TO THE EPA
Dear Regional Hearing Clerk,
This letter is regarding ADM Geologic Sequestration Well - Proposed Order SDWA-05-2005-0001. I am writing to request that the EPA order ADM to suspend CO2 sequestration operations at its current facility and reject ADM’s request for a permit that would allow the company to sequester CO2 under Lake Decatur.
According to Region 5 Administrator Debra Shore in a press release dated September 19, 2024, “The Biden-Harris Administration is committed to ensuring that carbon management projects are designed, built, and operated safely and responsibly, and in a way that reflects the best science and responds to the needs and inputs of local communities”. ADM has failed to build a sequestration facility that is safe from leaks and has been irresponsible in its lack of communication about multiple leaks taking place. Furthermore, if the USEPA is committed to projects that reflect the best science and the needs and inputs of local communities, it will not only suspend current sequestration operations, but it will also reject ADM’s proposed permit allowing sequestration under the city’s main drinking water source, Lake Decatur.
The current carbon sequestration operation was not built safely – ADM is using steel that may be unsafe for sequestration. As reported in an article in E&E News written by Snider and Lefebvre and published on October 9, 2024, “13 Chrome … appears to be vulnerable to corrosion when exposed to the liquids in carbon sequestration wells.” In other words, ADM Co. is using materials in its carbon sequestration wells that are vulnerable to leaks. Since November 2021, ADM Co. has reported 5 leaks at 2 wells.
The current carbon sequestration operation is not operated responsibly – Based on the multiple leaks that have taken place at the surface, subsurface, and 1000’s of feet deep, it can be concluded that there is a systemic problem with carbon sequestration operations. Decatur residents, and employees and elected officials of Decatur, were not notified of the first four leaks, and only became aware of one of them through an investigative journalist in the national media. ADM failed its basic ethical responsibility to notify interested parties in a timely manner.
Is the best science available adequate to protect human health and drinking water quality? – Even if one were to argue that ADM was using steel thought to be safe for sequestration, the fact that the steel corroded after approximately 10 years of operation is an indicator that the best available science is currently inadequate to protect human health and drinking water quality from carbon sequestration activities. It is also unclear whether the best science available is adequate to mitigate a substantial subsurface leak of CO2 into Lake Decatur, the city’s drinking water supply for 68,000 residents. Furthermore, the City of Decatur does not have a plan in the event of a significant CO2 surface leak such as the one that occurred in Satartia, Mississippi.
The current carbon sequestration operation does not reflect the needs and input of the local community –ADM was negotiating a carbon sequestration easement agreement with the City of Decatur around the time of the leak in March 2024, and was aware of three other leaks that occurred prior to that. However, residents were not made aware of the leaks until months after the March 2024 leak. How are residents able to effectively provide input when ADM withheld substantive, relevant facts that residents would need to provide such input? ADM through its lack of timely disclosure has completely disregarded the needs and input of our residents, many of whom live in distressed communities.
In its announcement of a proposed order against ADM on September 19, 2024, the EPA states “Safeguarding underground sources of drinking water and protecting human health and the environment continues to be EPA’s highest priority.” If this is the case, the EPA should suspend ADM’s current permit to sequester CO2 and reject ADM’s proposed permit to sequester CO2 under Lake Decatur. There is simply no compelling reason to risk the city’s drinking water source, public safety, and a crown jewel of our city to store CO2 from what appears to be imminent and substantial threat as defined by the Safe Drinking Water Act.
Thank you for your time and consideration.
Sincerely,
Dr. David J. Horn