frequently asked questions.

Wabash Valley Resources (WVR) is offering this Q&A as a best effort to answer the community’s most common questions from the EPA hearing and town hall events. If you have a question we haven’t answered, please submit them on the Contact page.

The company strives to provide stakeholders with current, accurate, and transparent information. The information and opinions provided in this Q&A are based on the best information available to the company at this time. The company reserves the right to update, amend, or remove the information at any time.

Background and Benefits

Wabash Valley Resources (WVR) is a $1.2 billion entrepreneurial venture established to demonstrate the
industrial application of net-zero-carbon-capable manufacturing processes to produce low-carbon intensity
anhydrous ammonia fertilizer. In other words, it rids America of environmental waste and makes clean fertilizer
for farmers.

Indiana does not currently have any ammonia production facilities. Adding supply will put downward pressure
on fertilizer prices for midwestern farmers. The lack of low-carbon-intensity fertilizer is also a key factor keeping
farm products and biofuels, like ethanol, from markets in California and Japan, which have requirements for
carbon intensity scoring.


This project will put Indiana at the forefront of low-carbon intensity ammonia fertilizer production and
industrial-scale carbon storage technology while creating jobs, helping farmers lower costs, reducing fertilizer
supply chain risks, and attracting investment.

America’s farmers are currently dependent on imported fertilizer. Producing fertilizer in America gives farmers
fertilizer independence. Through the production of clean ammonia fertilizer, WVR will displace half of the
imported ammonia supply to Illinois, Indiana, and Ohio. This will put downward pressure on prices.

In addition to helping farmers, WVR’s $1.2 billion investment will spur economic development, remediate
environmental degradation, support workers, and create good-paying jobs. Specifically, the project is expected
to:
1. Add over 1,100 direct and indirect jobs, including the creation of up to 500 union construction jobs at
peak employment, and add over 100 permanent jobs at the facility;
2. Remediate environmental waste via a chemical process and capture and permanently store CO2 instead
of releasing this greenhouse gas into the atmosphere;
3. Reinvest in the workforce talent of Vigo and Vermillion counties; and
4. Repurposes the former SG Solutions coal gasification facility.

1. WVR will purchase and use environmental waste to produce low-carbon-intensity ammonia fertilizer.
2. It will also capture, transport via pipeline, and permanently store carbon dioxide (CO2) deep underground, preventing the emission of greenhouse gases
Carbon storage technology has been a national priority for the last four presidential administrations. It is seen as an essential part of the transition from fossil fuels to green energy. The Inflation Reduction Act (IRA) further incentivized the technology to the point that it is now believed to be economically viable. There are currently 130 permit applications pending before the U.S. Environmental Protection Agency for CO2 storage projects.

Regulatory Oversight and Current Status

In 1974, with the enactment of the Safe Drinking Water Act, the federal government took an active role in
underground injection control. In response to the act, the EPA promulgated the UIC regulations in 1980.
Since then, more than 150 Federal Register notices have been published regarding UIC, including additional
regulations, amended regulations, explanations of procedures, and guidance. In 1986, Congress created a
larger federal role in protecting all groundwater from sources other than underground injection.

Injection into the subsurface is one of the primary means of disposing of liquid wastes in the United States. More than 760,000 injection wells1 are known to be in operation, disposing of millions of gallons of hazardous and nonhazardous fluid wastes.

1U.S. Environmental Protection Agency (n.d.). FY 2021 State UIC Inventory. Underground Injection Control (UIC). https://www.epa.gov/uic/uic-injection-well-inventory
Injection of CO2 is not a new technology. Oil and gas producers in the U.S. have been using CO2 injection technology to enhance oil recovery (EOR) since 19722. There are roughly 150,000 EOR injection wells currently in operation or idle3. There are currently two CO2 sequestration wells in operation, and several more projects have been approved in North Dakota. As of August 11, 2023, 130 Class VI permit applications are pending before the EPA4.

2 U.S. Department of Energy, National Energy Technology Laboratory (n.d.). The Southwest Regional Partnership Carbon Sequestration. Carbon Storage Atlas. https://www.netl.doe.gov/coal/carbon-storage/atlas/swp/phaseII/sacroc

3 U.S. Environmental Protection Agency (n.d.). FY 2021 State UIC Inventory. Underground Injection Control (UIC). https://www.epa.gov/uic/uic-injection-well-inventory, Class II.

4 U.S. Environmental Protection Agency (n.d.). Table of Class VI Wells Permitted by EPA. Class VI Wells Permitted by EPA. https://www.epa.gov/uic/class-vi-wells-permitted-epa#table

Per the EPA, among all classes of injection wells, there are over 18,000 in Indiana and over 42,000 in Illinois.

U.S. Environmental Protection Agency (n.d.). FY 2021 State UIC Inventory. Underground Injection Control
(UIC). https://www.epa.gov/uic/uic-injection-well-inventory, Indiana and Illinois.

Yes, 50 miles NW from our site, Cabot Oil has been injecting safely for over 50 years. They inject wastes
produced in the chemical manufacturing process. There have been no known safety or water contamination
issues.

No, the storage area is not near a source of drinking water.

The definition of an underground source of drinking water (USDW) is codified in 40 CFR 146.3. The USDW
definition ensures that potential sources of drinking water are protected as stringently as those sources
currently used for drinking water. The application of a quality-based groundwater standard rather than a
usage-based standard provides for both the protection of the groundwater resource and public health.
Groundwater containing between 3,000 and 10,000 mg/L total dissolved solids (TDS) is not suitable for human
consumption.

The Total Dissolved Solid level in the target strata was measured at 34,250 mg/L TDS. This is unsuitable for
drinking water and is close to the salinity of seawater

Injection Well Safety

Underground natural gas storage wells offer the best comparison to CO2 storage wells. Since 2009, the primary cause of underground natural gas storage events has been the corrosion of the wells. Corrosion accounts for 44% of post-2009 incidents.

Li, H. Z., Saint-Vincent, P. M. B., Mundia-Howe, M., & Pekney, N. J. (2022). A national estimate of U.S.
Underground natural gas storage incident emissions. Environmental Research Letters, 17, 084013.
https://doi.org/10.1088/1748-9326/ac8069, Page 5.

Wabash Valley Resources has designed the injection wells using materials specifically designed for CO2 service. These include using high chrome steel and specialty cement. In addition to the very specialized materials of construction, WVR is required by the draft EPA permit to perform both continuous and periodic monitoring and testing of the wells to ensure that at no time is the mechanical integrity of the well compromised.

The wells will have control systems designed to continuously monitor the wellhead instrumentation for
predetermined conditions or deviations in pressure or temperature that require the wellhead to be shut down.
If alarm or shutdown conditions are detected, the automated block valve at the wellhead will be closed, and
operations staff will be notified simultaneously of the shut-in condition.

1. Methane is a significantly more toxic gas than CO2. Methane is highly combustible, while CO2 is inert, non-flammable, and non-toxic. 2. Due to its structure, Methane traps more heat in the atmosphere per molecule than CO2, making it 80 times more harmful than CO2 as a greenhouse gas.

Indiana Carbon Capture Legislation

In 2011, the Indiana General Assembly enacted a law codifying that the transportation of CO2 via CO2 pipeline is in the public interest and a benefit to the welfare and people of Indiana. This law was passed in 2011 by the Indiana General Assembly to support the development of a syngas plant in Rockport, Indiana. This was also when the general assembly codified the laws related to eminent domain for CO2 pipelines.
1. Clarification of property ownership. For the first time in Indiana, it was clarified that the subsurface space (also known as “pore space”) is owned by the property owner and not the mineral rights owner. This gives the property owners an economic benefit that did not exist before.

2. Notification Requirements. Ensures notification to property owners. For the first time, a company in Indiana is required to notify the property owners. Prior to this, none of the 18,000 injection wells had any requirement to notify the property owners.

3. Compensation Offer. Previously, Indiana state law did not mandate injection well operators to make any payment to the property owners for the subsurface migration of fluids injected. Senate Bill 451 mandates that a written offer of compensation be made to the property owners for the subsurface migration of CO2. The offer of compensation is based on a reference published by Purdue University. The payments are annual for the duration of the project.

No, there is no injury or property damage liability protection for WVR. WVR will have potential liability in the
event of property damage or injury to a person or an animal caused by WVR’s operations.

Payment to Property Owners

It is anticipated that WVR will commence injection in 2026 or 2027 and cease in 2038 or 2039.

Based on the reference formula in Indiana Code 14-39-1-17, the annual payments are projected to be an average of $150/acre per year over the duration of the project. This payment will commence when the CO2 migrates under the property and continue until the project is completed and injection is ceased.
Yes. However, WVR has no current plans to utilize eminent domain. WVR strongly prefers to negotiate with property owners directly. Since 2011, CO2 pipeline operators that receive a certificate of authority from the state of Indiana have had access to eminent domain.

Carbon Capture and Sequestration (CCS)

CCS is a technology that captures carbon dioxide (CO2) emissions from industrial processes and power plants before they are released into the atmosphere. The captured CO2 is then transported and stored in geological formations deep underground to prevent its release into the atmosphere
CCS is important because it significantly reduces CO2 emissions from large industrial sources. It can play a crucial role in mitigating climate change by helping to limit global temperature rise and achieve emissions reduction goals.
The benefits of CCS include significantly reducing CO2 emissions, the potential to use fossil fuels in a transitional phase towards cleaner energy sources, the preservation of jobs and industries, and contributing to meeting climate goals.

CCS is often seen as a complementary technology to renewable energy sources, as it can help reduce emissions
from existing industrial processes that are challenging to decarbonize.

CCS is not the same as “fracking.” As described in the EPA draft permit, the maximum injection pressure shall
not exceed 90% of the fracture pressure of the targeted injection zone, pursuant to 40 CFR 146.88(a). In turn,
this ensures that the injection pressure would not cause the movement of injection or formation fluids into
the uppermost underground source of drinking water (USDW) as prohibited by 40 CFR 146.86(a).

The maximum allowable injection pressure is limited by the EPA to ensure that at no point the stability or
integrity of the formation is threatened. The injection well will be equipped with automated shutdowns
associated with this pressure indication.

The confining layer is continuous across the entire area of sequestration. The EPA evaluates and ensures the
confining layer is continuous across the entire region as part of the UIC Class VI permitting process.

There is a confining layer above and below the injection zone. These layers are over a thousand feet thick, and
their quality is verified by the EPA as part of the UIC Class VI permitting process.

Earthquakes within the region originate much deeper (15-20,000 feet deep) than the targeted injection zone. Since injection pressure is limited to less than the fracture pressure, geologists don’t anticipate induced seismic activity from the injection and storage of CO2.
In the event of an earthquake, there is no impact on the sequestered CO2 or the injection well. Per the draft permit, there are specific steps that must be taken to verify the integrity and safety of the injection well after seismic activity is recorded.

Injection Well Construction and Operations

Materials will be selected and used based on their compatibility with CO2. The main casing will be made of a high-chrome alloy designed to withstand the CO2, temperature, and pressure of the well service.

Annual non-destructive testing will be conducted by a third party. These services include running instrumented
devices the length of the well that can detect anomalies and or damage and inform WVR of the need to repair
or replace the well casing. The wells will be maintained to the specifications outlined in the final issued EPA
permit.

The Injection wells will be monitored 24/7 by the control system. Alarms and automatic shutdowns will be
implemented and verified for functionality before any injection occurs.

The draft permits only allow CO2 produced by WVR at the ammonia facility in West Terre Haute, IN, to be sequestered in these wells.

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