EPA should not allow CO2 sequestration under Decatur's drinking water supply
The drinking water source for over 68,000 residents of Decatur may be even more vulnerable to CO2 sequestration than previously thought. According to an article published in Energywire by Annie Snider on November 5, 2024, there have been 24 wells constructed over the past 100 years that have penetrated some of the shale layers that separate CO2 that ADM Co. would inject with the surface. Thus, if ADM were to have a CO2 leak during sequestration operations in Decatur, the escaped CO2 may use these 24 previously dug wells as a pathway to reach the surface and potentially endanger the city’s drinking water supply.
ADM SHOULD TERMINATE ITS CO2 SEQUESTRATION EASEMENT WITH THE CITY OF DECATUR
The easiest solution to permanently protect the city’s drinking water supply is for ADM to rescind its carbon sequestration easement agreement with the City of Decatur and pledge not to sequester CO2 under Lake Decatur. While it was negotiating the terms of the easement agreement with the city, there were two surface leaks, one subsurface leak, and one deep underground leak, all of which the company was aware of, and did not disclose to the city during easement negotiations. For a company that has a global reputation for business ethics, it is difficult to see how the failure to disclose substantive, material information during negotiations was anything but unethical, and certainly would have impacted whether the city council would have approved an easement in the first place.
WILL EPA FOLLOW THROUGH ON ITS COMMITMENTS?
According to EPA 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 EPA is committed to projects that reflect the best science and the needs and inputs of local communities, it will reject ADM’s proposed permit allowing sequestration under 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.
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, and 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 environmentally distressed communities.
In its announcement of a proposed order against ADM for violating the Safe Drinking Water Act 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 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. In fact, thanks to reporting in Energywire, Decatur residents now know there are 24 potential pathways in which supposedly permanent storage of CO2 could rise to the surface.