EPA Accuses ADM of Violating Carbon Sequestration Permit, Involving Injection and Monitoring Processes
In August, the U.S. Environmental Protection Agency (EPA) issued a notice of violation to Archer-Daniels-Midland (ADM), accusing it of violations in injection and monitoring processes at a carbon capture and storage (CCS) well in Decatur, Illinois. The notice states that violations occurred between January 2022 and July 2024, involving injected fluids entering unauthorized zones, missing monitoring, and failure to comply with emergency response plans. ADM stated that the issue stemmed from corrosion in a monitoring well at approximately 5,000 feet deep, which has been sealed and taken out of service, with no impact on surface, groundwater, or public health.
At a Glance
- The U.S. Environmental Protection Agency (EPA) issued a violation notice in August to agricultural supply chain management and processing company Archer-Daniels-Midland (ADM), alleging injection and monitoring process violations at a carbon capture and storage (CCS) well in Decatur, Illinois. The notice is not currently public; its existence was first reported by Politico's E&E News on Friday, and CFO Dive's sister publication ESG Dive obtained and reviewed the notice.
- The EPA alleges the violations occurred between January 2022 and July 2024, including: operating the well in a manner that allowed injected fluids to enter "any unauthorized zone," failing to conduct monitoring, and failing to comply with emergency response and remediation plans in the permit.
- According to a statement ADM sent to ESG Dive on Monday, the violation involves a monitoring well—one of two used to monitor the flow of stored carbon dioxide—that corroded at a depth of about 5,000 feet and has since been plugged and taken out of service. ADM stated: "At no time was there any impact to surface or groundwater sources, nor any threat to public health."
Deep Dive
The news comes as ADM also faces scrutiny over an accounting scandal that surfaced earlier this year. ADM's new Chief Financial Officer, Monish Patolawala, has recently committed to addressing the root causes of the company's accounting issues.
According to ADM's response documents filed with the EPA, ADM was the first U.S. company to operate an EPA-permitted Class VI well, with its first well going into service in 2011. In 2017, ADM received a Class VI permit to operate a second well, injecting and storing captured carbon dioxide in geological formations 5,550 to 7,000 feet below the surface in Illinois. The corroded monitoring well was used to monitor this second injection project.
The agribusiness said it reported progress on the monitoring well's corrosion and failure to the EPA in semi-annual reports, at the time it became aware of these issues. According to ADM's response to the EPA filed on August 22 (obtained by ESG Dive on Monday), the company also met with the EPA in February to discuss proposals to restore the well to operational status. ADM's response also insisted that there was no impact on groundwater, surface water, or public health.
ADM said in a statement: "We take our responsibility to safely operate this technology very seriously, learning along the way and making adjustments as needed. Our CCS operations have extensive monitoring measures in place to ensure we can detect, address, and learn from issues promptly."
ADM said in its response that it first noticed "intermittent" failures in the second monitoring well at a depth of just over 5,000 feet in September 2020, and by January 2022 (when the alleged violations began), all instruments in the well had failed.
The company said that after failing to restore its function in October 2023, it began pulling the well tubing and discovered corrosion that prevented full recovery of the tubing. At that point, the company plugged the well and relied on the injection well, the still-operating monitoring well, and the monitoring network of ADM's first Decatur well for monitoring, ADM's response stated.
In March of this year—after meeting with the EPA to discuss restoring the monitoring well—ADM discovered injected fluids at about 5,000 feet through routine testing and monitoring, and concluded this was related to corrosion in the previously plugged well, according to the response documents.
The EPA said in the notice that it is seeking to resolve the violation through an administrative order. ADM said in its response to the EPA that it looks forward to meeting to discuss its response and compliance efforts.
ADM said in a press statement: "ADM continues to be an industry pioneer, having successfully and safely operated the Decatur CCS wells for over a decade. We remain confident in the safety, reliability, and effectiveness of carbon capture and storage as a greenhouse gas reduction technology."