Save Our Illinois Land files testimony opposing proposed CO2 pipeline



SPRINGFIELD — On behalf of the citizens group Save Our Illinois Land, a Champaign attorney last week filed dozens of pages of written testimony in opposition to One Earth Sequestration LLC’s proposed OES Pipeline, with concerns voiced by affected landowners, first responders of a carbon dioxide pipeline rupture four years ago in Mississippi, and industry experts.

Attorney Joseph Murphy of the Meyer Capel law firm filed the direct testimony on Wednesday, Feb. 28, after earlier having filed a petition to intervene in the Illinois Commerce Commission’s hearing process for OES’s requested permit to allow the 7.34-mile, $19 million pipeline to be built and operated in western Ford and eastern McLean counties.

Called SOIL for short, Save Our Illinois Land’s testimony raised concerns about the safety of the proposed pipeline — and carbon capture and sequestration in general — including the risk of a rupture and CO2 leak. OES’s pipeline would transport liquid CO2 captured from parent company One Earth Energy’s ethanol facility in Gibson City to three sequestration wells in McLean County, where the CO2 would be injected more than 6,000 feet beneath the ground and stored permanently.

A sign posted in a yard in the 500 block of East Pells Street in Paxton says “No CO2 Storage,” in opposition to carbon sequestration projects.

The testimony on behalf of SOIL — which is part of a broader opposition group called the Coalition to Stop CO2 Pipelines — came from 10 people:

Richard Kuprewicz
Kuprewicz — who serves as president of Accufacts Inc., which is located in Redmond, Wash., and provides pipeline safety expertise for gas and liquid pipelines — called the Pipeline and Hazardous Materials Safety Administration’s existing safety regulations for liquid CO2 pipelines “seriously inadequate,” noting that PHMSA regulations do not prevent pipeline failures.

“Serious improvements in PHMSA pipeline safety regulations are needed quickly to address the many challenges associated with a rush of proposed carbon sequestration pipelines across the country,” he said.

Kuprewicz also said OES needs to provide more information about the type, grade and thickness of the steel used to build the pipeline, noting that OES “appears to be rushing forward with this proposal (despite) missing or lacking critical information to permit the commission to make an informed decision.”

Kuprewicz also said “pipeline release modeling” should “play an important role” in the siting of any CO2 pipeline, but he has yet to see any modeling done. As was “clearly demonstrated” in the rupture of a larger, 24-inch-diameter pipeline on Feb. 22, 2020, in Satartia, Miss., he noted, dispersion modeling “can easily be misused to understate, distort and misrepresent the real capabilities of heavier-than-air carbon dioxide rupture releases to travel large distances from the pipeline.”

“Such releases can travel many miles, and many CO2 release modeling approaches are clearly inaccurate, inappropriate and unsuitable,” Kuprewicz said. “A 16-inch-diameter pipeline rupture (like could happen with OES’s project) is easily capable of releasing many hundreds, if not thousands of tons of CO2 once mainline valves are finally closed, which is never immediately, especially for larger valves on a 16-inch-diameter pipeline.. The commission needs to pursue this important modeling issue critical to prudent CO2 pipeline siting.”

Ted Schettler
Schettler, a retired physician who is now the science director for the Science and Environmental Health Network, testified about the hazards of carbon dioxide exposure in humans and the risks of unintended exposure to CO2.

“Carbon dioxide is colorless, odorless and heavier than air,” Schettler said. “In the event of a CO2 pipeline rupture, suddenly depressurized liquid or supercritical CO2 will be released in a cloud of very cold CO2, often with particles of dry ice (solid CO2 that will then transform into gas over time), that will lie low on the ground and displace oxygen from the ambient air within the plume. Anyone within the plume as it disperses will thus be breathing ambient air with reduced oxygen content and increased CO2 content. The risk of asphyxiation and/or CO2 toxicity will depend on the level and duration of CO2 exposure and oxygen deprivation for a given person in their particular circumstances.

“Unintended releases of carbon dioxide from a pipeline can be life-threatening to someone who is exposed to concentrations of 4% carbon dioxide or higher in the ambient air for 30 minutes or longer. Some people are more tolerant of CO2 than others. Risk of unconsciousness or death rises quickly as concentrations exceed 7% and persist. Urgent removal from these concentrations is essential to protect life and health.”

Dr. Steven Culman
Culman, an agronomist who serves as the distinguished endowed chair of soil health in potato cropping systems at Washington State University, testified about the impact of natural gas pipeline construction on soils and crops.

Studies that Culman led in Ohio showed pipeline construction can cause soil degradation via increased compaction and soil mixing, paired with decreased aggregate stability and soil carbon, leading to declines in plant productivity, he said.

“Underground pipelines are an important aspect of our nation’s energy portfolio with more pipelines projected to be installed in the coming years,” Culman said. “But farmers should be appropriately compensated for soil degradation and sustained crop yield losses from these activities. Current easement payments should likely be revisited, as all available evidence from our work in Ohio suggests that degradation often persists for more than three or four years after installation and remediation is complete. I would also encourage any state authority that can dictate the conditions of pipeline construction to require the pipeline builders to employ best practices in excavation and replacement of soil, including a prohibition against working in saturated soil.”

Kathleen Campbell
Campbell, a SOIL member who is vice president of Citizens Against the Heartland Greenway Pipeline and owns land in Glenarm along the now-canceled Navigator pipeline project route, testified that setbacks need to be “sufficient to ensure that, in the event of a rupture, CO2 concentrations do not exceed 5,000 ppm at any occupied buildings and preferably below that level to allow for evacuation with rural EMS teams.”

Given OES’s proposed routing, however, Campbell said, “OES apparently plans to put residents at risk of that exposure level in the event of a rupture.”

So far, OES has “refused to provide any plume modeling results” to inform the ICC and homeowners of the safety risks, Campbell noted, adding that “OES has — by its own admission — not taken any plume modeling into account to guide routing.”

“OES’s irresponsibility when our human lives are at stake is unacceptable,” Campbell said. “A plume model after routing decisions are made is far too late. Surely, OES doesn’t plan to evaluate geohazards after the pipeline route is approved, but the risks of the routing may be more critical to human life.”

Rather than PHAST modeling, Campbell suggested that Computational Fluid Dynamics (CFD) plume modeling be used in predicting CO2 concentrations in the event of a rupture. She said PHAST modeling used in other pipeline projects has “greatly underestimated the distance a rupture CO2 release would travel.”

“SOIL is working to identify universities around the world that can run CFD models for us, but the results of our tests will not be available in time for this hearing,” Campbell said.

In the event of a CO2 pipeline rupture, residents would have only minutes before being “overwhelmed with the CO2 cloud if they are a mile or less from the rupture,” Campbell said.

“Further, gas combustion engines will not work,” Campbell said, “so residents will not be able to self-evacuate and EMS will not be able to rescue them in time. Consequently, it is essential that the pipeline is routed far enough away from any occupied building that residents are not exposed to dangerously high CO2 concentrations if a rupture or leak occurs. The CO2 plume from a pipeline rupture must have time and distance to dissipate to the point that it no longer threatens life and health before it gets to any residences or normally inhabited structures. …

“Although I have not measured the exact distance, I must observe that a rupture near the OES source plant could put some or all of Gibson City at risk, particularly if wind from the west blows a CO2 plume in that direction. OES has provided no plan on how these people will be rescued or self-evacuated if they can be. That information including a complete EMS manual and a list of all the needed EMS equipment with guaranteed funding should be publicly available for review now so that we have time for review and comment.”

Campbell said the number of CO2 pipeline accidents are not decreasing but instead increasing. Campbell noted that the PHMSA was aware of 17 reported accidents from 2001 to 2005, 28 from 2006 to 2010, 23 from 2011 to 2015, and 33 from 2016 to 2020.

“Presumably, all of these pipelines met or exceeded PHMSA standards,” Campbell said, “and it should be likely that in the more recent as opposed to the earlier years, the pipelines would be less prone to accidents. Yet the accidents continue at an even higher rate.”

Campbell suggested the ICC wait to approve any CO2 pipeline projects until it finalizes new safety standards for CO2 pipelines, which are expected to be released in October.

“Even PHMSA has conceded that its existing pipeline standards are inadequate,” Campbell said.

Brent Lage
Lage, who farms several parcels of land in northeastern McLean County near Anchor, testified that the proposed pipeline would cross one of the parcels he farms and is near a few others. Lage said he has concerns about the pipeline route and asked that the ICC deny the permit for its construction and operation.

“First, the proposed OES Pipeline route crosses over — and therefore is in the vicinity of — several aging natural gas and petroleum pipelines,” Lage said. “In the last several years, several farmers in the area have had to abandon strips of ground above these pipelines or plant alternative crops due to concerns of the old pipelines becoming too shallow and the potential for contact with farm equipment.”

In the areas where there are decades-old pipelines, farmers have seen reduced yields, negative impacts on underground drainage systems, and the settling of the pipelines, resulting in collapsing drainage tile.

“The pipeline company may claim to return ground to original condition after installation, but it is impossible for it to be the same as it was before,” Lage said. “The idea that OES will compensate farmers for a few years of reduced yields does not remotely address the damage that installing another pipeline will cause,” Lage said. “A new CO2 pipeline crossing over and close to these old pipelines (as well as the practice of the CO2 injection) creates the possibility for small ground tremors, which would open the door for more problems for these old pipelines as well as the CO2 pipeline itself.”

Lage noted that the agricultural impact mitigation agreement that OES has signed with the Illinois Department of Agriculture “does not give me much comfort as a fill-in-the-blank form.”

“Even if OES actually abides by the guidelines in the form, I remain concerned by the long-term impact of the pipeline, again based on my experience with other pipelines,” Lage said.

Lage said he “absolutely” feels concerned about a pipeline rupture and CO2 leak, as well.

“Based on where I farm, I will be in the vicinity of the pipeline almost daily,” Lage said. “Whether I’m working on the farm directly above the pipeline, working on other farms in close proximity, or simply passing through, it is my understanding that, in case of a pipeline rupture, whatever combustion-based vehicle I’m in would be almost instantly immobilized by high CO2 concentrations and I would be stranded and potentially asphyxiated. My home is 2.5 miles away from the pipeline, and I don’t feel that is far enough. One Earth told me they expect the sequestered (buried) CO2 will radiate 3 miles or more from their wells underground, so I know I will be living on top of it eventually.”

Lage noted concerns about the stability of the ground along the path of the proposed pipeline.

“This area has many old gravel pits that have been filled in, as well as several old and deep coal mine shafts,” Lage said. “All of those raise concerns about the stability of the ground around the pipeline and how it could lead to a rupture. Even setting aside the chance of a catastrophic rupture, these old gravel pits and coal mines could provide a path for the sequestered CO2 to find its way back through these areas and into the (Mahomet) aquifer. I understand there is some question about whether the sequestration area is located above the Mahomet Sole-Source aquifer. Nevertheless, we have several creeks and watersheds in the area that feed the Mahomet aquifer. Also, everyone who lives around here, outside of any city limits, has their own private drinking water well. These wells are our only source and option for water and if anything were to contaminate our drinking water supplies then this area would be uninhabitable.”

Lastly, Lage said he does not agree with OES’s potential use of eminent domain to secure easements for the pipeline.

“OES is a private company trying to do this project for its private profit,” Lage said. “I hardly see any public benefit. This technology and practice of injecting CO2 for permanent storage is new and relatively unknown in longterm effects. There are many other avenues and ideas that need to be studied and considered, many of which don’t need pipelines or deep wells. I would encourage the commission to give these options careful consideration before approving a pipeline to permanently inject CO2 underground with no control of it post-injection and no way to retrieve it.”

Timothy Christensen Jr.
Christensen, chief of the Saybrook-Arrowsmith Fire Protection District in McLean County, testified about the risks and costs of having a CO2 pipeline running through his fire district, in addition to the proposed sequestration wells.

“I believe every district through which this CO2 pipeline is routed will have similar risks and costs imposed on them by the presence of a CO2 pipeline,” Christensen said.

For one, Christensen said, the volunteer fire departments in McLean County do not have the training in hazardous materials that they would need to respond to a CO2 pipeline emergency.

“That training would require a considerable amount of time and financial commitment not only for the districts but also for the volunteer responders,” Christensen said. “We’re already asking our volunteers to give up time of their lives to respond to disasters in our community, and while myself and others are willing to attend the trainings to better understand such an emergency, it is another huge ask on an already-taxing role as a volunteer responder that regularly takes us away from our families. In addition, a fire department hazmat team is a unique denomination that requires yearly training and exercises to maintain that classification in addition to a significant stipend associated with the team for the added risk. That option is not available for most volunteers. The scope of our current training does not cover CO2 pipelines.”

Specialized equipment would also be needed, he said.

“It is my understanding that a compliant ‘electric fire engine’ that could operate in a low-oxygen environment would cost approximately $1 million and still have a very limited range,” Christensen said. “Even putting that aside, we would at least need a couple of electrical pickups to find and evacuate people.

“We would also need to update our currently inadequate SCBA (self-contained breathing apparatus) equipment. Our current stock is limited and allows only 30-minute, low-pressure bottles. By way of an initial investigation, I have obtained a quote for approximately $264,000 for 24 SCBA units, each with a 60-minute high-pressure bottle and a backup bottle along with a ‘buddy breathing’ connection capable of supporting a second mask on a single pack.

“We would also need a mobile air unit to refill SCBA tanks in the field. While the electric pick-up trucks I describe do not have the load capacity for such a unit, they do have the towing capacity for a mobile air unit trailer. But that would materially reduce the battery range of the trucks.

“We would also need a way to get accurate air direction and speed reading on scene to estimate direction and size of plume. We have also discussed the benefit of tethered drone on an ATV.”

Christensen noted that the fire departments in the area “are just investigating these issues ourselves and have gotten no input” from OES.

Since the initial costs for equipment would be “prohibitive,” Christensen asked that the ICC require that those initial costs as well as ongoing equipment maintenance be paid by OES.

“My initial calculation is that simply maintaining the SCBAs alone would cost about $3,000 annually with regular testing and an additional $3,000 every five years for required hydro tests,” Christensen said. “The effective lifespan of an SCBA bottle is 15 years, and while there is no mandated lifespan on the pack itself, it is our belief that they should be replaced every 15 years, as well. There is also the regular service of any EV in service as well as any air testing devices needed for a response.”

Meanwhile, Christensen said Gibson Area Hospital in Gibson City and its ambulance service have done no planning so far to prepare for a CO2-related emergency. Also, “up until quite recently, neither Ford County nor the Ford County (Emergency Management Agency) has been contacted” by OES to discuss preparedness concerns.

“As to Gibson City Hospital, in my opinion, due to its size and staffing, it is not equipped for a mass casualty event,” Christensen said.

Christensen said more information is needed from OES for the county, its hospital and its first-response agencies to develop emergency response plans of their own for CO2 pipeline ruptures.

“We have not received any information to calculate where any safety equipment will be,” Christensen noted. “We don’t know what types of setbacks OES will establish (or has established) between the pipeline and habitable structures or known populations that could be impacted by either a pipeline explosion or the resulting CO2 plume. We have also not seen any plume modeling that would help us to assess where we have populations that could be impacted by any pipeline emergency. We have not received any information on the depth of the pipeline underground or the soil types through which it will be routed. … Without any idea of this information, we are unable to get or give a clear understanding of the effects on public safety in our area.”

Wesley Ifft
Ifft, a member of SOIL, testified that he and his wife and their four children live within half a mile of the proposed pipeline, and he is concerned about the impact the project could have on the safety of his family and the value of their property.

He said OES has made no attempts to contact him or his neighbors to discuss the project and those “topics that are of immediate concern to me and my family.”

“I realize that my home sits just outside of the area they are required to notify,” Ifft said. “But in my estimation this seems like an attempt on their part to get as far as they can in the approval process without giving us a voice in the destruction of the safe, quiet, and tranquil area that we have chosen to make our home for the past 12 years.”

Among his specific concerns, Ifft said he wants to know from OES how residents in the area would be notified of a CO2 leak and what guarantees they would have that OES will follow through.

“Also, it is my understanding that a CO2 leak can spread very fast,” Ifft said. “How can we be confident that any notification will arrive in time? I don’t see how, in the few minutes between a pipeline rupture and when we would be exposed us to dangerous levels of CO2, we would be able to get out of harm’s way. … If I understand correctly, if a significant leak occurred, we would have around 10 +/- minutes to get out. This is absolutely impossible even in the best scenario.”

Community evacuation efforts would require specialized training and equipment that local first responders currently do not possess, Ifft added.

“I have spoken to multiple local volunteer firefighters, and they are unaware of any communication to help them be trained to respond to this type of situation,” Ifft said. “They also currently have no vehicles that are equipped to respond if the CO2 levels are too high to allow an internal combustion to run. Who would provide the needed funds for equipment and training for our local volunteers? This should absolutely not be an added burden placed on the taxpayers. However, for the safety of our first responders, and for them to be successful in rescue, it is an absolute necessity. Otherwise, they will be doing recovery missions after the fact, instead of rescue missions.”

Another concern of Ifft is the possibility that property values in the project area would decrease.

“I urge the commission to consider not just those whose property the pipeline would cross, but all those affected by this pipeline and deny the application for this pipeline,” Ifft said. “My family and my children deserve the ability to play at their own home without the fear of harm from CO2 poisoning.”

Sally Lasser
Lasser, a SOIL member who operates a farm and related business from her home in rural Gibson City and believes her property is either along the pipeline route or right next to it, testified that she is “very concerned about the impact of the proposed OES project and pipeline on my farm and my community.”

“OES has made no attempt to communicate to me or anyone that I am aware of as to how they would manage a pipeline leak or rupture or how they would even notify those of us in the vicinity,” Lasser said. “So far as I am aware, OES has not conducted and therefore not provided any plume modeling that would indicate who might be in harm’s way in case of a leak or rupture. I am simply concerned about my safety and the safety of my guests/workers in the case of a pipeline rupture or significant leak.”

In addition to safety concerns, Lasser is concerned about a decrease in land values, she said.

“If OES imposes an easement on my property through threat of eminent domain, I assume that will be added as a real-estate disclosure and as encumbrance on my deed,” Lasser said. “I am equally concerned that, even if the pipeline is routed on my neighbor’s land across the road from me, it might still be a necessary real-estate disclosure to any subsequent buyer of my land (and will be marked with large yellow signs stating its dangerous potential in any event). I have to conclude that it will significantly compromise the value of my property due to the obvious safety concerns.

“While I believe that the potential danger alone would be enough to impact my value, I actually have a more immediate and direct concern. I recently inquired with my insurance carrier whether the proximity of my property to the pipeline route and sequestration well heads would impact my rates. My insurance carrier told me that, if this project went through, I would be dropped. She actually sent me an email confirming this information. … I also spoke with an independent agent who stated she had word from her underwriters that landowners along the pipeline would become uninsurable.”

With no insurance, it would likely affect Lasser’s ability to retain her mortgage or get a new one, or obtain a loan for her business ventures, which include the possibility of developing a nature retreat center on her property with a “strong influence on agriculture and land conservation education.”

“That could not be possible if I cannot obtain the necessary liability insurance,” Lasser said. “Insurance aside, I don’t know how I could bring visitors to the property without making them aware of the danger, and I don’t know what visitors would want to spend time at the property once they became aware of the danger.”

Jack Willingham
Willingham, director of the Yazoo Emergency Management Agency, in Yazoo, Miss., testified about his experiences responding to a CO2 pipeline rupture that occurred near Satartia, Miss., on Feb. 22, 2020, and what he learned from managing the emergency.

“Although (the pipeline’s owner) did confirm the leak, it provided no guidance on the response or how to treat CO2 inhalation victims,” said Willingham, who noted that only one of the first responders on scene had any training in CO2 response.

“Once we established contact with (pipeline owner) Denbury, the company was able to provide a calculation for the volume of CO2 that was in the segment of pipeline between the two cutoff valves that had experienced the rupture,” Willingham said. “Eventually, I was able to share that volume of information with the state weather service, which was able to use that information to calculate the likely size, direction and speed of the plume moving away from the pipeline.”

The plume largely followed the topography downhill and into the town of Satartia.

“Once we began to understand what we were facing, we determined our responders would need self-contained breathing apparatuses, or SCBAs, to enter into Satartia and evacuate the town’s 42 residents (many of them elderly) and about 250 others who lived just outside town,” Willingham said. “By then, rescuers and residents were already in motion, fleeing the gas or evacuating others. … (We) had deputies evacuating without proper equipment. Some of them had to be hospitalized, and we had to order people without SCBA to get out. … Once we were able to determine better what was going on, we had stations on each end of the affected area for personnel to keep fresh breathing air bottles to supply SCBAs.”

The plume ultimately traveled 3 1/2 to 4 miles in the direction of the wind before it was deemed non-dangerous, Willingham said, adding that the pipeline finally stopped emitting CO2 almost four hours after it started.

“We got into town about four to five hours after the incident began,” Willingham said. “It looked like the zombie apocalypse. It was hazy. Because gas-powered vehicles stall out or shut down in a CO2 event, there were abandoned vehicles everywhere, many with doors ajar, many with their windows smashed from the rescue efforts.”

In addition to lessons learned, the emergency response cost Yazoo County “a pretty big outlay of money,” Willingham said.

“To my knowledge, Denbury was not required to compensate the county in any way,” Willingham said. “Denbury did, however, purchase a mass communication system for the county and bought some $6,000 air monitors for the fire department. I know those actions were voluntary.”

Jerry Briggs
Briggs — the fire coordinator for Warren County, Miss., which is directly southwest of Yazoo County — also testified about his experiences with the Satartia pipeline rupture. Briggs recalled how he and other first responders were unsure at first what kind of gas leak they were dealing with.

“When I got notification that something was occurring in Yazoo County. I was in Vicksburg,” Briggs said. “I initially saw reporting about a large explosion and called Jack Willingham, the director of the emergency management agency in Yazoo. Jack did not know the source or the explosion or the nature of the problem but asked for help. Jack was working from Yazoo City, which is north and east of Satartia. As I indicated, Warren County is southwest. So Jack was coming from the opposite side of the explosion.

“I started making calls and directed a couple of my guys to start getting equipment together and our side by side and to meet me at checkpoint in Yazoo County. Because I believed we were dealing with a gas emergency — maybe natural gas, maybe chlorine gas — I loaded it down with every kind of portable air equipment we had and required my crew to put on full turnout gear, including hazmat suits. By the time I entered into Yazoo County and hit my checkpoint near Satartia, no one yet knew what the gas was. As is common, we treated it as the worst gas and hoped for the best.”

Briggs recommended that any state authority considering the routing of a CO2 pipeline in the future require better communication.

“These companies need to be in contact with every local agency that would respond to an emergency, not just the state or local EMA,” Briggs said. “This information is a lot of times not passed down to the people who have the responsibility of protecting the people in their community.”

Also, “supplying equipment and training to these same departments is crucial to their success,” Briggs said.

“Most times these pipelines run through less-populated areas of counties, so odds are there will be a volunteer fire department responding to the emergency,” Briggs said. “In most cases, these departments are understaffed and underfunded. With that being said, it is vital that these companies reach out and help departments understand and be knowledgeable of the pipelines that are in their response areas.”