Emergency and Remedial Response Plan for ADM CCS#1

Permit Number: IL- 115

- 6A -0002 Page F1 of 14 ATTACHMENT F: EMERGENCY AND REMEDIAL RESPONSE PLAN

This plan is provided to meet the requirements of 40 CFR 146.94. As steps to prevent unexpected carbon dioxide ( CO 2 ) movement have already been undertaken in accordance with a risk analysis and under an injection well permit issued by Illinois Environmental Protection Age ncy (IEPA Permit No.: UIC-012- ADM ), this plan is about actions to be taken, and to be prepared to take, if unexpected movement or any other emergency events occur at the CCS#1 Illinois Basin-Decatur Project (IBDP).

Facility Name: Archer Daniels Midland, CCS#1 Well

IL

- 115-6A-0002

Facility Contacts: A site-specific list of facility contacts will be developed and maintained

during the life of the project.

Injection Well Location: Decatur, Macon County, Illinois 39° 52’ 37.06469” N, 88° 53’ 36.25685” W

This emergency and remedial response plan (ERRP) describes actions that the owner/operator (A DM) shall take to address movement of the injection fluid or formation fluids in a manner that

ma y endanger an underground source of drinking water (USDW) during Class VI activities, including post- in

jection site care, for the IBDP CCS#1 well.

The CCS#1 well is related to CCS#2. Delineation of the area of review (AoR) for CCS#1 incorporates injection activities at CCS#2 (i.e., the two wells will create a single CO 2 plume and pressure front). Therefore, an emergency event related to either well will require a coordinated
response.
If ADM obtains evidence that the injected CO 2 stream and/or associated pressure front may cause an endangerment to a USDW, ADM must perform the following actions:

1. Take all steps reasonably necessary to identify and characterize any release. 2. Notify the permitting agency (UIC Program Director) of the emergency event within 24 hours. 3. Implement applicable portions of the approved ERRP.

Part 1: Local Resources and Infrastructure Resources in the vicinity of the IBDP CCS#1 well that may be impacted as a result of an

e mergency event at the project site include: USDWs; potable water wells; the Sangamon River; Bois Du Sangamon Nature Preserve; and Lake Decatur.

Infrastructure in the vicinity of the IBDP CCS#1 well that may be impacted as a result of an

e mergency at the project site include: the wellhead; Richland Community College structures ; He artland Community Church; residential areas; commercial properties; recreational facilities;

a nd ADM facilities. A map of the local area is provided as Figure F-2 at the end of this plan.Emergency and Remedial Response Plan for ADM CCS#1

Permit Number: IL- 115

- 6A -0002 Page F2 of 14 Part 2: Potential Risk Scenarios The following events related to the IBDP CCS#1 well could potentially result in an emergency
response:

 Well integrity failure at CCS#1 or a monitoring well;

 A natural disaster (e.g., earthquake, tornado, lightning strike);

 Fluid (e.g. brine) or CO 2 leakage to a USDW or land surface; or

 Induced seismic event.

Response actions will depend on the severity of the event(s) triggering an emergency response. “Emergency events” are categorized as follows:

TABLE F

- 1. DEGREES OF RISK FOR EMERGENCY EVENTS
Emergency Condition Definition Major Emergency Event poses immediate substantial risk to human health, resources, or infrastructure. Emergency actions involving local authorities (evacuation or isolation of areas) should be initiated. Serious Emergency Event poses potential serious (or significant) near term risk to human health, resources, or infrastructure if conditions worsen or no response actions taken. Minor Emergency Event poses no immediate risk to human health, resources, or infrastructure.

Part 3: Emergency Identification and Response Actions Steps to identify, characterize, and respond to the event will be dependent on the specific issue identifie d, and the severity of the event. The potential risk scenarios identified in Part 2 are detailed below.

In the event of an emergency requiring outside assistance, the project contact lead shall call the ADM Security Dispatch at (217) 424-4444 and ADM Corporate Communications at (217) 424-5413.Emergency and Remedial Response Plan for ADM CCS#1

Permit Number: IL- 115

- 6A -0002 Page F3 of 14 Well Integrity Failure

. A loss of integrity at CCS#1 or a moni toring well may endanger USDWs at the IBDP site. Integrity loss may have occurred if the mechanical integrity test results indi cate a loss of mechanical integrity.

Response Actions:

 Immediately notify the ADM plant superintendent or designee.

 Notify the UIC Program Director within 24 hours of the emergency event, per 40 CFR 146.91(c).

 The plant superintendent will make an initial assessment of the situation and determine which other project personnel to notify.

 Project contacts will determine the severity of the event, based on the information available, within 24 hours of notification.

 For a Major or Serious Emergency:

o Shut in well (close flow valve), if applicable.

o Vent CO 2 from surface facilities, if applicable.

o Limit facility access to authorized personnel only.

o Communicate with ADM personnel and local authorities to initiate evacuation plans, as necessary.

o Monitor well pressure, temperature, and annulus pressure to verify integrity loss

a nd determine the cause and extent of failure; identify and implement

a ppropriate remedial actions to repair damage to the well (in consultation with the UIC Program Director).

o If contamination is detected, identify and implement appropriate remedial actions (in consultation with the UIC Program Director).

 For a Minor Emergency:

o Conduct assessment to determine whether there has been a loss of mechanical integrity.

o If there has been a loss of mechanical integrity:.

 Shut in well (close flow valve), if applicable.

 Vent CO 2 from surface facilities, if applicable.

o Monitor well pressure, temperature, and annulus pressure to verify integrity loss

a nd determine the cause and extent of failure; identify and, if necessary, implement appropriate remedial actions (in consultation with the UIC Program Director).Emergency and Remedial Response Plan for ADM CCS#1

Permit Number: IL- 115

- 6A -0002 Page F4 of 14 Potential Brine or CO 2 Leakage to USDW

. This may be detected through elevated concentrations of indicator parameter(s) in groundwater sample(s) or other evidence of fluid (brine) or CO 2 leakage into a USDW.

R esponse Actions:

 Immediately notify the ADM plant superintendent or designee.

 Notify the UIC Program Director within 24 hours of the emergency event, per 40 CFR 146.91(c).

 The plant superintendent will make an initial assessment of the situation and determine which other project personnel to notify.

 Project contacts will determine the severity of the event, based on the information

a vailable, within 24 hours of notification.

 For all Emergencies (Major, Serious, or Minor):

o Shut in well (close flow valve), if applicable.

o Vent CO 2 from surface facilities, if applicable.

o Collect confirmation sample(s) of groundwater and analyze for indicatorparameters (a list of potential indictors is listed in Attachment E, the PostI njection Site Care and Site Closure Plan, Table 3).

o If the presence of indicator parameters is confirmed, develop (in consultation with the UIC Program Director) a case-specific work plan to:

 Install additional groundwater monitoring points near the impacted groundwater well(s) to delineate the extent of impact, and

 Remediate unacceptable impacts to the impacted USDW.

o Arrange for an alternate potable water supply, if the USDW was being utilized and has been caused to exceed drinking water standards.

o Proceed with efforts to remediate USDWs to mitigate any unsafe conditions (e .g., install system to intercept/extract brine or CO 2 or “pump and treat” to
aerate CO 2 -laden water).

o Continue groundwater remediation and monitoring on a frequent basis (f requency to be determined by ADM and the UIC Program Director) until unacceptable adverse USDW impact has been fully addressed.Emergency and Remedial Response Plan for ADM CCS#1

Permit Number: IL- 115

- 6A -0002 Page F5 of 14 Natural Disaster . Well problems (integrity loss, leakage, or malfunction) may arise as a result of a natural disaster impacting normal operations at the site. An earthquake may disturb surface

a nd/or subsurface facilities; and weather-related disasters (e.g., tornado or lightning strike) may impact surface facilities.

Response Actions:

 Immediately notify the ADM plant superintendent or designee.

 Notify the UIC Program Director within 24 hours of the emergency event, per 40 CFR 146.91(c).

 The plant superintendent will make an initial assessment of the situation and determine which other project personnel to notify.

 Project contacts will determine the severity of the event, based on the information available, within 24 hours of notification.

 For a Major or Serious Emergency:

o Shut in well (close flow valve), if applicable.

o Vent CO 2 from surface facilities, if applicable.

o Limit facility access to authorized personnel only.

o Communicate with ADM personnel and local authorities to initiate evacuation plans, as necessary.

o Monitor well pressure, temperature, and annulus pressure to verify well status

a nd determine the cause and extent of any failure.

o Determine if any leaks to ground water or surface water occurred.

o If contamination or endangerment is detected, identify and implement

a ppropriate remedial actions (in consultation with the UIC Program Director).

 For a Minor Emergency:

o Conduct assessment to determine whether there has been a loss of mechanical integrity.

o If there has been a loss of mechanical integrity:

 Shut in well (close flow valve), if applicable.

 Vent CO 2 from surface facilities, if applicable.

o Limit facility access to authorized personnel only.

o Monitor well pressure, temperature, and annulus pressure to verify integrity loss and determine the cause and extent of any failure.

o Identify and, if necessary, implement appropriate remedial actions (in consultation with the UIC Program Director).Emergency and Remedial Response Plan for ADM CCS#1

Permit Number: IL- 115

- 6A -0002 Page F6 of 14 Induced Seismic Event . Induced seismic events typically refer to minor seismic events that are caused by human activity which alter the stresses and fluid pressures in the earth's crust. Induced

se ismicity could potentially result from the injection of fluids into subsurface formations that lubricate and/or change the stress state of pre-existing faults which causes fault plane movement

a nd energy release. Most induced seismic events are extremely small (microseismic) but in some instances are great enough to be felt by humans. Case histories of induced seismic events associated with fluid disposal wells show seismic events as far away as about 10 to 12 km (6

. 2 to 7

. 4 miles). Based on the project operating conditions, it is highly unlikely that injection operations would ever induce a seismic event outside an eight (8 ) mile radius from the wellhead. Therefore this portion of the response plan is developed for any seismic event with an epicenter within an eight (8) mile radius of the injection well.

To monitor the area for seismicity, the site has installed five (5) surface seismic monitoring stations and three (3) borehole monitoring stations that continuously record the site’s seismic activity. In addition to these stations, the USGS has deployed a network of nine (9) surface seismic monitoring stations and three (3) borehole monitoring stations. Based on the periodic analysis of the monitoring data, observed level of seismic activity, and local reporting of felt events, the site will be assigned an operating state. The operating state is determined using threshold criteria which correspond to the site’s potential risk and level of seismic activity. The operating state provides operating personnel information about the potential risk of further seismic activity and guides them through a series of response actions. In the following table the ADM Decatur Seismic Monitoring System is presented. The table corresponds each level of operating status with the threshold conditions and operational response actions.Emergency and Remedial Response Plan for ADM CCS#1

Permit Numbe r: IL

- 115

- 6A -0002 Page F7 of 14 Table F-2a. ADM Decatur Seismic Monitoring System (1) Operating State Threshold Condition Response Action 

## Green Seismic events less than or equal to M1.5 (2) 1. Continue site activities per permit conditions

. 

## Yellow Five (5) or more seismic events within a 30 day

period having a magnitude greater than M1.5 (2) but less than or equal to M2.0 (2)

. 1. Continue site activities per permit conditions

. 2. Within 24 hours of the incident, n otify the UIC Program Director and ISGS of the operating stat us of the facility

.



## Orange Seismic event greater than M1.5 (2) ; and

l ocal observation or felt report (3)

. 1. Continue site activities per permit conditions. 2. Within 24 hours of the incident, n otify the UIC Program Director
, ISGS, and ADM Communications of the operating status of the facility

. 3. Review seismic and operational data. 4. Report findings to the UIC Program Director and issue corrective actions ( 4 )

. Seismic event greater than M2.0 (2) and no felt report

1. Seismic events > M1.0 with an epicenter within an 8 mile radius of the injection well. 2. Determined by the local ADM or USGS seismic monitoring stations or reported by the USGS National Earthquake Information Center using the national seismic network. 3. Confirmed by local reports of felt ground motion or reported on the USGS “Did You Feel It?” reporting system. 4. Within 25 business days (five weeks) of change in operating state.Emergency and Remedial Response Plan for ADM CCS#1

Permit Numbe r: IL

- 115

- 6A -0002 Page F8 of 14 Table F-2b. ADM Decatur Seismic Monitoring System (1) Operating State Threshold Condition Response Action



## Magenta Seismic event greater than M2.0 (2) ; and

l ocal observation or report (3)

. 1. Within 24 hours of the incident, n otify the UIC Program Director
, ISGS, and ADM Communications of the operating stat us of the facility

. 2. Limit facility access to authorized personnel only. 3. Communicate with ADM personnel and local authorities to initiate evacuation plans, as necessary. 4. Monitor well pressure, temperature, and annulus pressure to verify well status and determine the cause and extent of any failure; identify and implement appropriate remedial actions (in consultation with the UIC Program Director). 5. Determine if leaks to ground water or surface water occurred. 6. If USDW contamination is detected,

a. N otify the UIC Program Director within 24 hours of the determination. b. I dentify and implement appropriate remedial actions (in consultation with the UIC Program Director). 7. Review seismic and operational data. 8. Report findings to the UIC Program Director and issue corrective actions ( 4 )

. 1. Seismic events > M1.0 with an epicenter within an 8 mile radius of the injection well. 2. Determined by the local ADM or USGS seismic monitoring stations or reported by the USGS National Earthquake Information Center using the national seismic network. 3. Confirmed by local reports of felt ground motion or reported on the USGS “Did You Feel It?” reporting system. 4. Within 25 business days (five weeks) of change in operating state.Emergency and Remedial Response Plan for ADM CCS#1

Permit Numbe r: IL

- 115

- 6A -0002 Page F9 of 14 Table F-2c. ADM Decatur Seismic Monitoring System (1) Operating State Threshold Condition Response Action



## Red Seismic event greater than M2.0 (2) ;

l ocal observation or report (3) ; and

l ocal report and confirmation of damage (4)

. 1. Within 24 hours of the incident, n otify the UIC Program Director , ISGS, and ADM Communications of the operating status of the facility

. 2. Limit facility access to authorized personnel only. 3. Communicate with ADM personnel and local authorities to initiate evacuation plans, as necessary. 4. Monitor well pressure, temperature, and annulus pressure to verify well status and determine the cause and extent of any failure; identify and implement appropriate remedial actions (in consultation with the UIC Program Director). 5. Determine if leaks to ground water or surface water occurred. 6. If USDW contamination is detected,

a. N otify the UIC Program Director within 24 hours of the determination. b. Identify and implement appropriate remedial actions (in consultation with the UIC Program Director). 7. Review seismic and operational data. 8. Report findings to t

he UIC Program Director and issue corrective actions ( 5 )

. Seismic event >M3.5 (2)

1. Seismic events > M1.0 with an epicenter within an 8 mile radius of the injection well. 2. Determined by the local ADM or USGS seismic monitoring stations or reported by the USGS National Earthquake Information Center using the national seismic network. 3. Confirmed by local reports of felt ground motion or reported on the USGS “Did You Feel It?” reporting system. 4. Onset of damage is defined as cosmetic damage to structures – such as bricks dislodged from chimneys and parapet walls, broken windows, and f allen objects from walls, shelves, and cabinets. 5. Within 25 business days (five weeks) of change in operating state.Emergency and Remedial Response Plan for ADM CCS#1

Permit Number: IL

- 115

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- 00 02 Page F 10 of 14 Figure F-1

. The process by which seismic data are acquired, transmitted, processed, and evaluated by ADM to support the process.

1. Seismic data is recorded in real time from all stations. 2. Data from specific borehole and surface stations is transferred to a central data acquisition system where it is processed to determine the magnitude of the seismic event. 3. An email alert notification is sent out for events with magnitudes greater than M1.0. 4. If the seismic activity results in the site’s operational state escalating above yellow, additional data from remote seismic stations will be retrieved. 5. The seismic data will undergo additional processing to refine the magnitude and determine location of the event(s). 6. The data will be evaluated by subject matter experts and a report of findings and recommendations will be issued within 25 business days.Emergency and Remedial Response Plan for ADM CCS#1

Permit Number: IL

- 115

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- 00 02 Page F 11 of 14 Part 4: Response Personnel and Equipme nt Site personnel, project personnel, and local authorities will be relied upon to implement this ERRP. Portions of the AoR are located within the limits of the City of Decatur and other portion s are outside of the city limits. Therefore, both city and county emergency responders (as well as state agencies) may need to be notified in the event of an emergency.

Site personnel to be notified (not listed in order of notification) :

1. ADM Project Engineer(s) 2. ADM Plant Safety Manager(s) 3. ADM Environmental Manager(s) 4. ADM Plant Manager 5. ADM Plant Superintendent 6. ADM Corporate Communications

A site-specific emergency contact list will be developed and maintained during the life of the project. ADM will provide the current site-specific emergency contact list to the UIC Program Dire ctor.

Local Authorities (including but not limited to):

Age ncy: Phone No. City of Decatur Police Department 217-424 -2711 City of Decatur Fire Department 217-424 -2811 Macon County Sheriff 217-424 -1311 Illinois State Police 217-786 -7107 Illinois Emergency Management Agency 800-782 -7860 Macon County Emergency Management Agency 217-424 -1327 Bodine Environmental Services 800-637 -2379 UIC Program Director (US EPA Region V ) 312-353 -7 648 US EPA National Response Center (24 hr) 800-424 -8802 Illinois State Geological Survey 217-244 -8389, 4068 217-649 -1744

Equipment needed in the event of an emergency and remedial response will vary, depending on the triggering emergency event. Response actions will generally not require specialized equipment to implement. Where specialized equipment (such as a drilling rig or logging

e quipment) is required, the designated Subcontractor Project Manager shall be responsible for its procurement.Emergency and Remedial Response Plan for ADM CCS#1

Permit Number: IL

- 115

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- 00 02 Page F 12 of 14 Part 5: Emergency Communications Plan ADM will communicate to the public about any event that requires an emergency response, in consultation with the UIC Program Director.

In the event of an emergency requiring outside assistance, the project contact lead shall call the ADM Security Dispatch at (217) 424-4444 and ADM Corporate Communications at (217) 424-5413.

 Emergency communications with the public will be handled by ADM Corporate Communications.

 ADM Corporate Communication s, in consultation with the UIC Program Director, will determine the method, frequency, and extent of public communication based upon the emergency event’s severity and impact to the public.

 ADM will describe what happened, any impacts to the environment or other local resources, how the event was investigated, what responses were taken, and the status of the response (including any updates, as necessary).

 ADM Corporate Communications will manage all ADM media communications with the publi c (through either interview, press release, Web posting, or other) in the event of an emergency situation related to the project.

 The individual to be designated by ADM will be the first contact during an emergency
event.

 This individual will contact the crisis communication team as appropriate. Emergency responses to the media from ADM will be dealt with ONLY by the personnel so designated by ADM.

 Those individuals should try to be reachable 24 hours a day for contact in the event of an

e mergency.
In the event that anyone else at ADM is contacted to comment on any situation deemed an “emergency event, ” the media contact should be directed to ADM’s 24/7 media line at 217-424- 5413 or Me dia@adm.com

.

Part 6: Plan Review This ERRP shall be reviewed:

 at least once every five (5) years following its approval by the permitting agency,

 within one (1) year of an AoR re-evaluation,

 within a prescribed period (to be determined by the permitting agency) following any significant changes to the facility or an emergency event, or

 as required by the permitting agency.

If the review indicates that no amendments to the ERRP are necessary, provide the permitting agency with the documentation supporting the “no amendment necessary” determination.

If the review indicates that amendments to the ERRP are necessary, amendments shall be made and submitted to the permitting agency within six (6) months following an event that initiates the ERRP review procedure.Emergency and Remedial Response Plan for ADM CCS#1

Permit Number: IL

- 115

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- 00 02 Page F 13 of 14 Part 7: Staff Training and Exercise Procedures ADM will integrate the ERRP into the plant specific standard operating procedures and training program as described in the SO P entitled 180.60.ENV.130 “ Environmental Training, Awareness and Competence.” Periodic training will be provided, not less than annually, to well operators, plant safety and environmental personnel, the plant manager, plant superintendent, and corporate communications. The training plan will document that the above listed personnel have been
tra ined and possess the required skills to perform their relevant emergency response activities described in the ERRP.Emergency and Remedial Response Plan for ADM CCS#1

Permit Number: IL

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- 00 02 Page F 14 of 14 Figure F-2. Local area map for the IBDP CCS#1. Emergency & remedial response activities will most likely be within the AoR highlighted on the map. Source: ISGS and ISWS well databases, current as of May 10, 2011.