Leak calls into question safety of CO2 sequestration under Lake Decatur
The United States Environmental Protection Agency issued a Notice of Violation of the Safe Drinking Water Act against Archer-Daniels-Midland Company at one of its carbon dioxide sequestration monitoring wells in Decatur on August 14, 2024. Specifically, the USEPA stated that ADM Co. failed to meet its sequestration permit requirements in three ways: 1) ADM’s sequestration activity allowed the movement of fluids (i.e., CO2) into unauthorized places, 2) the company failed to follow its Emergency Response and Remediation Plan required as a condition of the permit, and 3) ADM failed to monitor the well as required in the permit. Thankfully, in this incident there was no reported impact on the city’s drinking water quality.
ADM was apparently aware of the corrosion in one of its two deep monitoring wells in March. The corrosion of the well resulted in 8,000 metric tons of CO2 and formation fluid entering underground areas for which ADM did not have a permit. ADM is already subject to a class action lawsuit that was filed last year alleging that the company did not obtain pore space rights from landowners. Combined, these events could call into question the reliability and predictability of carbon sequestration operations being performed in Decatur.
The leak associated with ADM’s sequestration operations illustrates the potential health risks that sequestration poses and the lack of safeguards in place for notifying the public when a problem is identified. At its March 20, 2023 meeting, the Decatur City Council authorized the city manager to negotiate the terms and conditions for a carbon sequestration easement. At the meeting, city council members were assured that carbon sequestration was safe and there would not be leaks. A year and a half later, the city learns through the media (not ADM or the USEPA) that there was a CO2 leak through a corroded well. It is also concerning that ADM allegedly did not follow its own Emergency Response and Remediation Plan. Wouldn’t one of the first calls regarding a CO2 leak be to the city of over 68,000 residents, home of the North American headquarters of ADM? Given the CO2 leak, and that the U.S. Department of Labor found that a lack of preventative maintenance played a major role in an explosion that injured 3 workers at ADM’s West Plant in Decatur on April 20, 2023, city leaders would be justified in asking questions about whether some of the activities that ADM is engaged in are safe for workers and residents of the city.
MORE QUESTIONS THAN ANSWERS
There are many unanswered questions from this incident. For example, could the corrosion of a well take place closer to the surface thereby posing a health threat to the public? Does the amount of sequestration activity influence the rate of corrosion? The amount of CO2 predicted to be sequestered under Lake Decatur is substantially greater than what has been done in the past and the well corroded after approximately 10 years of operation.
To my knowledge, no one from the City of Decatur was notified of the leak until after the USEPA action in August. The leak took place months prior to the city reaching a final agreement with ADM that permitted the company to sequester carbon under Lake Decatur, the city’s main drinking water source. It is fair to say that knowledge of the CO2 leak when it happened could have influenced the city council’s decision on whether CO2 sequestration was in the city’s best interest and could have influenced terms of the easement agreement. Why weren’t city employees and the city council notified? Does ADM’s Emergency Response and Remediation Plan include contacting the City of Decatur and its water department?
Who from the State of Illinois knew of the leak prior to the USEPA Notice of Violation? This incident took place around the time negotiations of the “Safety and Aid for the Environment in Carbon Capture and Sequestration Act” were taking place. It is fair to say that knowledge of the leak could have led to greater protections from sequestration activities under drinking water sources including the Mahomet Aquifer.
Why did it take the USEPA months to issue a Notice of Violation of the Safe Drinking Water Act? While the city’s water supply thankfully was not impacted in this incident, it was not even notified until months afterward. Can we expect the same lack of transparency from ADM and USEPA if the leak took place 10 ft. underground? The incident took place in March, the USEPA issued a violation on August 14, and the public was not made aware of the incident until September 13 thanks to an article in POLITICO’s E&E News written by Carlos Anchondo. ADM and the USEPA have failed the city of Decatur and its residents, and their lack of timely incident reporting may have ensured that Decatur residents live with the threats of carbon storage permanently.
VIOLATIONS OF THE SAFE DRINKING WATER ACT MUST END
Residents should expect ADM to cease injection of CO2 into unauthorized zones, to follow its Emergency Response and Remediation Plan, and to monitor CO2 injection wells in accordance with its USEPA permits. Thankfully, this incident did not impact water quality, but given that the City of Decatur recently approved an easement with ADM to significantly increase its carbon sequestration activities under Lake Decatur these alleged violations are concerning and must not happen again.
In the signing of the “Safety and Aid for the Environment in Carbon Capture and Sequestration Act”, Governor Pritzker stated “Every marginal reduction in planetary warming that we can achieve, every fraction of a percent, represents billions of dollars in savings for our economy here.” It could also be said that failure to timely report CO2 leaks to interested parties could have preserved billions of dollars to companies that will profit from sequestration, while potentially putting at risk the future water supply for hundreds of thousands of Illinois residents.