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Illinois Storage Corridor - CarbonSAFE Phase III: Policy, Regulatory, Legal and Permitting Characteristics; Subtask 5.5

The Illinois Storage Corridor (ISC) project aims to advance the commercial development and implementation of carbon capture and storage (CCS) technologies within a region in Illinois of suitable geology for carbon dioxide (CO 2 ) storage in deep saline aquifers. The project partners have annual emissions greater than 6.5 million tonnes per year; storage hubs are being explored at two sites—one near the One Earth Energy facility in east-central Illinois, and one near the Prairie State Generating Company campus in southwest Illinois. To implement the technology, legal, policy, and economic considerations must be explored. The United States Environmental Protection Agency (US EPA) administers the Underground Injection Control (UIC) program and is responsible for issuing Class VI permits to construct and operate CO 2 injection wells, i.e., a UIC Class VI well permit is required to inject CO 2 into the subsurface for geologic sequestration. The largest consideration of the Class VI well requirements is to protect underground sources of drinking water (USDWs). Additionally discussed are considerations for Class VI permits relating to public engagement. Besides permitting, property rights to storage sites, subsurface pore spaces, and areas for pipeline transportation must be secured. Pore space rights is still a novel concept being explored and not yet addressed by the Illinois legislature. It is believed that surface property rights are required for the subsurface pore space below, so long as there is not a separated mineral estate in the subsurface. Illinois legislature has addressed securing rights-of-way for CO 2 transportation, allowing for easements and the exercise of eminent domain to secure such rights. Economically, the incentives for CCS are ever-expanding. Recently, the federal government broadened the availability and increased the dollar-amounts for the § 45Q tax credits for geological storage of carbon oxides. Congress has also authorized the Advanced Industrial Facilities Development Program which allocates billions of dollars in funds to installing technology at industrial facilities to reduce greenhouse gas emissions. On the state level, Illinois has had its own incentives for CCS projects since 2009 and expanded its emission-related goals again in 2021. The law enacted in 2021 specifically creates a commission to explore implementing CCS at Prairie State Generating Company, a partner on the Illinois Storage Corridor project.

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Illinois Storage Corridor, CarbonSAFE Phase III: UIC Class VI Permitting Plan

The Illinois Storage Corridor (ISC) project evaluated two distinct sites to determine the feasibility of commercial-scale CO₂ storage at each. The project leveraged the region's exceptional geological characteristics, particularly the well-characterized Cambro-Ordovician Storage Complex, to enable permanent geological storage of more than 50 million tonnes of CO₂ over 30 years. The two storage sites are located at One Earth Energy (OEE) facility in northcentral Illinois and Prairie State Generating Company (PSGC) in southcentral Illinois. Once operational, these facilities will combine to capture and store more than 6.5 million tonnes of CO₂ per year, positioning the ISC among the largest carbon storage regions globally. Preliminary homogeneous dynamic modeling based on regional and site-specific reservoir characteristics indicates promising injection capabilities at both locations. For the OEE site, modeling predicts a maximum allowable injection rate of 3.7 MTPA, with a baseline scenario of 1.7 MTPA over 30 years producing a CO₂ plume radius of 1.4 miles at end of injection. For the PSGC site, incorporating recent well data, modeling indicates a single-well maximum injection rate of 2.1 MTPA, with a plume radius of 4.2 miles at end of injection for the 60 MT over 30 years scenario. The primary objective of this CarbonSAFE Phase III project is to develop and submit Class VI Underground Injection Control (UIC) permit applications to the U.S. Environmental Protection Agency Region 5. The permitting plan outlines comprehensive site characterization, Area of Review delineation, monitoring programs, well construction designs, financial responsibility provisions, and post-injection site care procedures necessary to demonstrate safe, permanent CO₂ storage protective of underground sources of drinking water. Three UIC Class VI permit applications for the OEE site were submitted to EPA in October 2022 and are progressing through technical review, with final permit decision projected by June 2026. Through five rounds of Requests for Additional Information and responses, the applications have been refined to address computational modeling, area of review delineation, well integrity, monitoring protocols, and financial assurance requirements. For the PSGC site, finalized characterization and permitting documentation was delivered directly to the facility in July 2023 due to business constraints precluding formal federal regulatory submission. This comprehensive permitting effort builds upon extensive prior subsurface evaluations and demonstration projects that have confirmed the feasibility of widespread commercial-scale carbon storage in the region.

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Illinois Storage Corridor CarbonSAFE Phase III: Stakeholder Engagement and Outreach Plan

The Stakeholder Engagement and Outreach Plan provides a comprehensive framework for engaging stakeholders of the Illinois Storage Corridor (ISC) project. The ISC project is a CarbonSAFE Phase III project designed to facilitate commercial deployment of carbon capture, utilization, and storage (CCUS) in Illinois. The project aims to establish a multi-industry carbon storage corridor through development of storage sites near the One Earth Energy (OEE) ethanol production facility in north-central Illinois and the Prairie State Generating Company (PSGC) coal-fired power plant in south-central Illinois, with combined annual CO 2 capture ultimately exceeding 8.6 million tons per year. Stakeholder engagement is recognized as a critical component for successful CCUS deployment, alongside technical and economic considerations. As an emerging technology, CCUS may not be well understood by the general population, and lack of public awareness can lead to opposition that poses significant barriers to project development. This plan addresses this challenge through systematic stakeholder identification, analysis, planning, and implementation of engagement actions. The plan is structured around four main sections: Communication, Stakeholder Analysis, Stakeholder Engagement, and Environmental Justice. Activities will be conducted under Tasks 1 and 4 of the project's Statement of Project Objectives, with two key subtasks: (1) developing a stakeholder analysis and engagement plan through face-to-face meetings, facilitated discussions, and surveys; and (2) implementing stakeholder engagement and public outreach activities including meetings, open houses, and permit hearings. The Illinois State Geological Survey (ISGS) will manage engagement activities following DOE-NETL best practices, focusing on providing objective, fact-based information about CCUS and the ISC project. A comprehensive Communication Plan establishes protocols for media contacts, site visits, and crisis communications. The stakeholder analysis follows a structured workflow process divided into Pre-feasibility and Feasibility phases, incorporating contextual understanding, assessment, data collection, and analysis. Key stakeholder groups include government bodies, educational organizations, conservation and environmental groups, agricultural communities, and religious organizations. The plan addresses common stakeholder questions regarding project risks, benefits, safety, property values, liability, and environmental impacts. Recommendations emphasize developing clear messaging, creating informational materials, and preparing to address both project-specific and broader environmental concerns to ensure transparent communication and build stakeholder support throughout project implementation.

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lllinois Storage Corridor CarbonSAFE Phase III: Pre-drilling Site Assessment: Prairie State Generating Company

The Illinois Storage Corridor project will drill a stratigraphic test well as part of the Illinois Storage Corridor CarbonSAFE Phase 3 project near the Prairie State Generating Company coal-fired power plant near Marissa, Illinois. The pre-drilling site evaluation has considered the primary target reservoirs, the Potosi Dolomite and St. Peter Sandstone, and primary seal, the Maquoketa Group. Data to be collected from the well include core, fluid samples, in situ well tests, geophysical logs intended to provide information on lithologic, geomechanical, and geophysical characteristics to determine the feasibility for the geologic sequestration of 50 million metric tons or more of injected carbon dioxide. The planned drilling site has been evaluated using available subsurface geologic data and analyses from the Illinois Basin. These data provide lithologic and structural information, shallow groundwater resource distribution, location of known nearby wellbores, and regional drilling characteristics. The data were used to generate geologic structure and isopach maps for the target reservoir and caprock strata and for prognosing the tops of major lithologic units to aid drilling and coring procedures. The regional analyses indicate that no known structural features are expected to negatively impact the target storage reservoir or caprock. No protected and sensitive areas, groundwater resources, or existing resource development are expected to be impacted by the proposed well drilling activities. The well is planned to be drilled to a total depth of approximately 5,600 feet (1,707 m) and terminate in the Precambrian. Cores (up to 5 intervals) will be collected from the Maquoketa Group, confining units above the St. Peter Sandstone, St. Peter Sandstone, confining units of the Potosi Dolomite and the Potosi Dolomite. Water samples will be attempted to be collected from the St. Peter Sandstone and Potosi Dolomite. Potential impact on drilling progress is a lost circulation zone in the Potosi Dolomite, which has been demonstrated to have intermittent cavernous porosity from karstification elsewhere in the Illinois Basin. This document also presents a preliminary coring and sampling program, proposed logging suite, and well testing program, all of which will be reviewed during drilling.

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One Earth Energy Static and Dynamic Reservoir Modeling

This report presents the static and dynamic reservoir modeling conducted for the CarbonSAFE Phase III Illinois Storage Corridor project to assess the feasibility of commercial-scale CO 2 storage in the Mt. Simon Sandstone at the One Earth Energy (OEE) site in McLean County, Illinois. Three-dimensional geocellular models of the Mt. Simon storage complex were developed in Petrel ® by integrating petrophysical log data, core analyses, and seismic surveys from the OEE #1 stratigraphic test well and two nearby wells, with multiple model versions created as new data became available. Dynamic reservoir simulations, performed using Landmark's Nexus software, progressed through three phases (preliminary, sensitivity, and UIC Class VI permit studies) evaluating injection scenarios across varying rates, well orientations, permeability models, and multi-well configurations. Results demonstrate that commercial-scale storage is feasible: three injection wells spaced approximately one mile apart can store a total of 90 million tonnes of CO 2 over 20 years, producing a combined plume with an equivalent radius of 3.2 miles and a maximum pressure-front-defined Area of Review of 178 mi 2 at the end of injection that diminishes to 34 mi 2 after 50 years of post-injection monitoring. Sensitivity analyses indicate that a 20% change in porosity or permeability yields approximately a 7% change in AoR radius, and that perforating the high-permeability arkosic zone minimizes the pressure front compared to injection in the upper Mt. Simon Sandstone.

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Storage Field Development Plan: One Earth Energy

This Storage Field Development plan presents the Storage Complex characterization results, construction, monitoring, and operational plans, and costs associated with the proposed One Earth Sequestration Carbon Capture and Storage (OES-CCS) site in McLean County, Illinois, near Gibson City. The proposed storage complex, known as the Mt. Simon Storage Complex, comprises the Cambrian Mt. Simon Sandstone reservoir and the primary seal, the Cambrian Eau Claire Formation. The lowermost Underground Source of Drinking Water (USDW) identified for the site is the Ordovician St. Peter Sandstone. Geologic characterization of the Mt. Simon Storage Complex at the OES-CCS site was performed by the Illinois Storage Corridor CarbonSAFE Phase III project, which also prepared and submitted three UIC Class VI applications to construct three injection wells; the permit applications were submitted and are in the federal EPA review process. A characterization well, OEE #1, was drilled to collect site-specific data. These data were analyzed and used to develop the UIC Class VI applications. The OEE #1 well will be converted to an in-zone monitoring (IZM) well for the injection phase. The proposed buildout for the OES-CCS site includes (1) three injection wells (OES #1, OES #2, and OES #3), (2) two IZM wells, (3) two above confining zone (ACZ) monitoring wells, one of which will be used to monitor the lowermost USDW, (4) capture and compression facilities, and (5) transportation facilities, i.e., pipelines. A pre-operational testing program was proposed in the Class VI permit application and will be employed at the site pending approval. Additional pre-injection (baseline), syn-injection, and post-injection monitoring and site care procedures will be followed by OES to ensure that injection activities are protective of human health and the environment. Injection is scheduled to begin in 2025, distributed across the three injection wells in accordance with the permit operating conditions. One Earth Sequestration intends to inject up to 90 million tonnes of CO 2 over a period of approximately 20 years. Injection will begin at approximately 0.5 million tonnes of CO 2 annually and ramp up to a maximum of 4.5 million tonnes annually. Daily injection rates are expected to range from 1,400 to 1,500 tonnes per day initially and reach a maximum of approximately 4,225 tonnes per day, depending on site geology and injectivity at each injection well location, and CO 2 availability. The costs associated with the OES-CCS project include pre-operational costs (e. g. additional seismic data acquisition and well drilling), capture and transportation facility and equipment costs, predicted field operating expenditures (OpEx), and decommissioning and post-injection site care (PISC) costs. The risks associated with project activities, such as site construction, injection operations, and verification of secure storage were evaluated, and mitigation strategies proposed to alleviate those risks.

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Geology of the One Earth Energy Site

The One Earth Energy site is one of two sites in the Illinois Storage Corridor (ISC) project. The objectives of the ISC project is to accelerate commercial deployment of carbon capture utilization and storage at two individual sites and receive approvals for Underground Injection Control (UIC) Class VI permits for construction at each site. At the One Earth Energy site, an extensive data collection program was undertaken, which included the drilling of a test well (One Earth Energy #1 [OEE #1]), four 2D seismic lines, and a small 3D seismic survey. The OEE #1 well was drilled in 2022 and acquired extensive core, log, and testing data to characterize the subsurface geology of the site. Coring was focused on the storage interval, the Mt. Simon Sandstone, and the confining interval, the Eau Claire Formation. The core and log data were used to evaluate the sedimentology and sequence stratigraphy, as well as to develop the conceptual geologic model. This report includes the geological summaries of the Mt. Simon Sandstone and the Eau Claire Formation. The extensive analysis of the log data is included in the petrophysical section, showing ranges of porosity, estimated pore size, and the mineral content of selected zones in the well. The separate petrographic technical report entitled “Petrographic and Advanced Geologic Characterization Report on One Earth Energy #1 (API# 1211325373)”, report number DOE-UIUC-0031892-04, details thin section point-counting analysis that includes mineralogical and pore space analysis, including grain size analysis, annotated thin section photomicrographs, scanning electron microscopy (SEM) with energy dispersive X-ray spectroscopy (EDS), and statistics of grain size analysis on Mt. Simon thin sections from OEE #1. The final OEE #1 well data to be included in this geology report is the routine core analysis of both whole core plugs and rotary sidewall core plugs. In addition to the OEE #1 well, four 2D seismic lines and a small 3D survey were acquired as part of the overall subsurface geological characterization. This geology report references the seismic interpretation report, entitled “One Earth Energy Site Seismic Interpretation Task 5.0”, report number DOE-UIUC-0031892-07. This report details the stratigraphic and structural interpretation of the 2D and 3D seismic data acquired at the One Earth Energy site. The 2D seismic data was acquired in 2019 and 2021, and the 3D survey was acquired in 2022. The objectives of the seismic programs were to contribute to the subsurface characterization of the Mt. Simon-Eau Claire Storage Complex by evaluating the continuity of potential storage reservoirs and containment intervals across the project area, and to determine if any geologic features are present that would increase containment risk to the proposed carbon storage project.

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One Earth Energy Seismic Interpretation

The objectives of the Illinois Storage Corridor (ISC) project are to accelerate commercial deployment of carbon capture utilization and storage at two individual sites and receive approvals for Underground Injection Control (UIC) Class VI permits for construction at each site (ISC Project Narrative, 2020). As part of this project, and as part of the subsurface geologic characterization, 2D seismic data was acquired at both sites. This report summarizes the findings from the 2D and 3D seismic interpretation at the One Earth Energy site near Gibson City, Illinois. The seismic data confirms the stratigraphic continuity of the Mt. Simon Arkose Zone storage interval and the Eau Claire confining unit across the project area. The seismic data also indicates that there are faults that transect the Mt. Simon Arkose Zone Sandstone storage reservoir within the modeled CO 2 plume (for more detailed information, see Faults and Fractures section of One Earth Energy Class VI Permit applications). However, the seismic data also shows that there are no faults within the modeled CO 2 plume that transect the confining unit Eau Claire Formation. The faults that transect the Mt. Simon Arkose Zone Sandstone storage reservoir all tip out in the Lower Mt. Simon Formation and do not reach the overlying Eau Claire confining unit. A small 3D survey acquired around the One Earth Energy #1 characterization well confirms these findings.

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Prairie State Generating Company 2D Seismic Interpretation

The objectives of the Illinois Storage Corridor (ISC) project are to accelerate commercial deployment of carbon capture utilization and storage at two individual sites and receive approvals for Underground Injection Control (UIC) Class VI permits for construction at each site (ISC Project Narrative, 2020). As part of this project, and as part of the subsurface geologic characterization, two-dimensional (2D) seismic data was acquired at both sites. This report summarizes the findings from two phases of 2D acquisition and seismic interpretation at the Prairie State Generating Company site near Marissa, Illinois. The seismic data indicates the presence of three faults that completely transect the storage and confining units. The initial 2021 2D seismic acquisition revealed the presence of a feature two miles east of the Lively Grove #1 characterization well. The feature is a polyphase fault with a component of strike-slip motion, forming a small positive flower structure. The second phase of 2D seismic acquisition in 2022 constrained the maximum extent of the fault, indicating it has a relatively limited length. Other 2022 seismic lines revealed the presence of two other faults that transect the storage and confining units in the southwest and northeast portions of the 2D seismic acquisition area. The 2021 and 2022 2D seismic surveys have identified three specific locations within the project area that may have an elevated risk of out of zone CO 2 migration due to faulting. Further technical work will be needed to quantify this risk and determine how and if this risk will impact the placement of CO 2 injection wells across the project area.

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One Earth Energy FEED Process Design Basis

This report establishes the process design basis for the front-end engineering design (FEED) of a carbon capture and injection facility at One Earth Energy's (OEE) ethanol production plant in Gibson City, Illinois, developed as part of the Illinois Storage Corridor CarbonSAFE Phase III project. The facility is designed to compress and dehydrate up to approximately 458,000 metric tonnes of CO 2 per year, sourced directly from OEE's ethanol fermenters, for permanent injection into a saline aquifer approximately four miles from the plant. At normal operating conditions, the system will process 1,290 metric tonnes of CO 2 per day, assuming 355 operating days per year and an ethanol production rate of 160 million gallons per year. The proposed process trains a multistage centrifugal blower with a five-stage reciprocating compressor, delivering CO 2 to the injection wellhead at up to 1,500 psig. Triethylene glycol (TEG) dehydration, applied after the fourth compression stage, reduces water content to a target of 10 lb/MMscf, well within the 30 lb/MMscf injection limit. Beyond dehydration, no additional treatment is required; trace impurities including oxygen and nitrogen will remain in the injected stream. Key design considerations include the absence of spare cooling tower capacity at the site, necessitating new cooling infrastructure, and the need for a new electrical substation to support large motor loads. The facility is designed for continuous, largely unattended operation, monitored around the clock by existing OEE operations staff. This document serves as the foundational reference for all subsequent detailed engineering activities associated with the OEE CO 2 injection facility.

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Qualitative Risk Assessment of Legacy Wells within the Estimated Prairie State Generating Company Area of Review

This report details the digitization of a legacy wellbore database, including data processing assumptions, parameter estimation, and risk assessment methodology. The database, comprising 6,454 documents, was provided by ISGS. It includes valuable data from the Prairie State Generating Company (PSGC) and One Earth Energy (OEE) sites of the CarbonSAFE Phase III – Illinois Storage Corridor project. The report focuses on wells within a 15-mile radius from the Lively Grove #1 (LG#1) well at PSGC site, evaluating subsurface conditions and potential risks. A total of 4,386 wellbores within 15 miles of the LG#1 well were filtered based on depth and formation codes. LG#1 is the stratigraphic well at the PSGC site drilled in 2021. Ninety-four (94) wells penetrating the Maquoketa Shale Group (the primary confining unit) within the estimated area-of-review (AoR) for the PSGC site were evaluated using a qualitative risk assessment (QRA) methodology. The QRA developed by Arbad et al. 2022 focuses on legacy wells within the AoR and categorizes them based on well construction details. The QRA identifies wells that need immediate attention by categorizing them based on penetration depth and protection. Wells within the AoR were categorized into nine groups based on penetrations and protections. These categories range from Type 1 wells, with no documentation, to Type 9 wells, which do not penetrate the primary confining unit or storage reservoir (unit). Well accessibility within the AoR varies based on well status, including Dry & Abandoned (DA), Plugged & Abandoned (PA), Injection (INJ), Oil/Gas Producing (PROD), and Observation (Obs) wells. Accessibility levels were determined by well construction, with DA wells being the least accessible and Observation wells the most accessible, impacting gas leakage detection possibilities. Remedial action priority of wells decreases from Type 1 to Type 9 wells. Type 1 to Type 6 wells with status DA and PA require immediate attention, while Type 7 and Type 8 wells are low priority. A risk matrix used to prioritize corrective actions for legacy wells is proposed to categorize wells within an AoR based on penetrations, protections, and accessibility. The methodology involves data acquisition, well categorization into nine types, and determining CO 2 leakage pathways using well schematics and geospatial mapping. This approach is particularly useful for managing the integrity of legacy wells throughout the lifecycle of a Carbon Capture and Storage (CCS) project. A qualitative risk assessment of 94 wells within the AoR of the PSGC site identified 54 wells with high priority for corrective action due to penetration of the primary containment seal. The assessment utilizes color-coded maps to categorize well types and prioritize corrective actions, providing a comprehensive analysis. Schematics of wells penetrating the primary confining unit were drawn, and leakage pathways were identified. Details of all wells penetrating the confining zone are provided in the appendix, including information on well types, plugging, and casing status.

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Prairie State Generating Company Static and Dynamic Modeling

A reservoir modeling study was conducted to assess the feasibility of storing 162.5 million tonnes (8.125 million tonnes annually) of industrially sourced carbon dioxide (CO 2 ) in the St. Peter – Everton and Knox storage complexes at the Prairie State Generating Company’s (PSGC) site near Marissa, Washington County, Illinois (PSGC site). Two separate models were constructed for the St. Peter – Everton and the Knox storage complexes. The St. Peter and Everton sandstones are the target storage units for the St. Peter – Everton storage complex. The Knox Group formations are the target storage units for the Knox storage complex. The Maquoketa Shale is the primary confining unit for both storage complexes. The static reservoir models used as input to the dynamic reservoir models of the storage complexes were developed from interpretations of logs (e.g., gamma ray, resistivity, porosity, photoelectric, and sonic), structure surfaces using data from 36 wells, thickness maps, well test data, seismic data, and permeability data in PetrelTM.

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Prairie State Generating Company Site: Storage Field Development Plan

This Storage Field Development plan presents the Storage Complex characterization results, construction, monitoring, operational plans, and costs associated with the proposed Prairie State Energy Campus - Carbon Capture and Storage (PSEC-CCS) project in Washington County, Illinois, near Marissa. The proposed storage complex, known as the St. Peter-Everton Storage Complex, comprises the St. Peter Sandstone and Everton sandstone reservoirs, with the Maquoketa Shale serving as the primary confining unit and the Knox Group as lower confining unit. The lowermost Underground Source of Drinking Water (USDW) identified for the site is the Pennsylvanian section.

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OES CO 2 Pipeline FEED Project Design Basis Memorandum

The OES CO₂ Pipeline project will move captured carbon dioxide from two ethanol facilities near Gibson City, Illinois, roughly 7.8 miles southeast to three injection wells outside Anchor, where it will be permanently stored underground. The system is designed to handle up to 4.5 million metric tonnes per year of dense-phase CO₂ at pressures up to 2,500 psig, using 16-inch mainline pipe and 10.750-inch laterals made from API 5L X-60 and X-65 steel. Wall thicknesses vary depending on location, with thinner pipe in open country, heavier wall at road crossings, and the heaviest where the pipe passes under highways or railroads via horizontal directional drill. The pipe gets a fusion-bonded epoxy coating, with an added abrasion-resistant layer wherever it's bored or drilled. Major water crossings will use HDD rather than open trenching. The pipeline will be cathodically protected, equipped with SCADA-compatible pressure and temperature instrumentation, and monitored for leaks using a computational pipeline monitoring system per API RP 1130. Hydrostatic testing will be performed at 1.25 times design pressure, and an ILI caliper run will follow to catch any construction defects. Several items, including fracture toughness requirements, specific NDE methods, and ILI tool selection, are left for the detailed design phase. The whole system falls under 49 CFR Part 195 and ASME B31.4, and Gulf Interstate Engineering prepared this document as the FEED-level design basis under the CarbonSAFE Phase III program.

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