Emergency and Remedial Response Plan for ADM CCS#2 

Permit Number: IL-115-6A-0001 Page F1 of 15

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 (CO2) movement have already been undertaken in accordance with 

risk analysis, this plan is about actions to be taken, and to be prepared to take, if unexpected 

movement or any other emergency events occur. 

Facility Name: Archer Daniels Midland, CCS#2 Well

IL-115-6A-0001

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

during the life of the project. 

Injection Well Location: 39o53’08”, -89o53’19” 

Near the center of Section 32

Township 17N, Range 3E (Whitmore Township) 

Decatur, Macon County, Illinois 

This emergency and remedial response plan (ERRP) describes actions that the owner / operator 

(ADM) shall take to address movement of the injection fluid or formation fluid in a manner that 

may endanger an underground source of drinking water (USDW) during construction, operation, 

or post-injection site care periods. 

If ADM obtains evidence that the injected CO2 stream and/or associated pressure front may 

cause an endangerment to a USDW, ADM must perform the following actions: 

1. Initiate shutdown plan for the injection well.

2. Take all steps reasonably necessary to identify and characterize any release.

3. Notify the permitting agency (UIC Program Director) of the emergency event within 24 

hours. 

4. Implement applicable portions of the approved ERRP. 

Where the phrase “initiate shutdown plan” is used, the following protocol will be employed: 

ADM will immediately cease injection. However, in some circumstances, ADM will, in 

consultation with the UIC Program Director, determine whether gradual cessation of injection 

(using the parameters set forth in Attachment A of the Class VI permit) is appropriate.

Part 1: Local Resources and Infrastructure 

Resources in the vicinity of the IL-ICCS project that may be impacted as a result of an 

emergency event at the project site include: underground sources of drinking water (USDWs); 

potable water wells; the Sangamon River; Bois Du Sangamon Nature Preserve; and Lake 

Decatur.
Emergency and Remedial Response Plan for ADM CCS#2 

Permit Number: IL-115-6A-0001 Page F2 of 15

Infrastructure in the vicinity of the IL-ICCS project that may be impacted as a result of an 

emergency at the project site include: the wellhead; Richland Community College structures; and 

ADM facilities. A map of the local area is provided as Figure F-2 at the end of this plan. 

Part 2: Potential Risk Scenarios 

The following events related to the IL-ICCS project could potentially result in an emergency 

response: 

• Injection or monitoring (verification) well integrity failure;

• Injection well monitoring equipment failure (e.g., shut-off valve or pressure gauge, etc.); 

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

• Fluid (e.g. brine) leakage to a USDW;

• CO2 leakage to 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.

In the event of an emergency requiring cessation of injection, CO2 slated for injection may be 

released to the atmosphere.

Part 3: Emergency Identification and Response Actions 

Steps to identify and characterize the event will be dependent on the specific issue identified, 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#2 

Permit Number: IL-115-6A-0001 Page F3 of 15

Well Integrity Failure. 

Integrity loss of the injection well and/or verification well may endanger USDWs. Integrity loss 

may have occurred if the following events occur: 

a. Automatic shutdown devices are activated.

• Wellhead pressure exceeds the specified shutdown pressure specified in the 

permit; 

• Annulus pressure indicates a loss of external or internal well containment; 

ADM is required to notify the UIC Program Director within 24 hours (40 CFR 

146.91(c)(3)of any triggering of a shut-off system (i.e., down-hole or at the service). 

b. Mechanical integrity test results identify 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 Initiate shutdown plan. 

o Shut in well (close flow valve). 

o Vent CO2 from surface facilities.

o Limit access to wellhead 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 and determine the cause and extent of failure; identify

and implement appropriate 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, inititate shutdown 

plan. 

o Shut in well (close flow valve). 

o Vent CO2 from surface facilities.

o Reset automatic shutdown devices. 

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

integrity loss and 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#2 

Permit Number: IL-115-6A-0001 Page F4 of 15

Injection Well Monitoring Equipment Failure. 

The failure of monitoring equipment for wellhead pressure, temperature, and/or annulus pressure 

may indicate a problem with the injection well that could endanger USDWs. 

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 Initiate shutdown plan. 

o Shut in well (close flow valve). 

o Vent CO2 from surface facilities.

o Limit access to wellhead 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 (manually if 

necessary) to determine the cause and extent of failure. 

o Identify and, if necessary, 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, initiate shutdown plan. 

o Shut in well (close flow valve).

o Vent CO2 from surface facilities.

o Reset or repair automatic shutdown devices. 

o Monitor well pressure, temperature, and annulus pressure (manually if 

necessary) to determine the cause and extent of 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#2 

Permit Number: IL-115-6A-0001 Page F5 of 15

Potential Brine or CO2 Leakage to USDW. Elevated concentrations of indicator parameter(s) 

in groundwater sample(s) or other evidence of fluid (brine) or CO2 leakage into a USDW.

 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 all Emergencies (Major, Serious, or Minor): 

o Initiate shutdown plan. 

o Shut in well (close flow valve). 

o Vent CO2 from surface facilities.

o Collect a confirmation sample(s) of groundwater and analyze for 

indicator parameters.

o If the presence of indicator parameters are 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 USDW to mitigate any unsafe 

conditions (e.g., install system to intercept/extract brine or CO2or 

“pump and treat” to aerate CO2-laden water).

o Continue groundwater remediation and monitoring on a frequent basis 

(frequency 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#2 

Permit Number: IL-115-6A-0001 Page F6 of 15

Natural Disaster. Well problems (integrity loss, leakage, or malfunction) may arise as a result 

of a natural disaster impacting the normal operation of the injection well. An earthquake may 

disturb surface and/or subsurface facilities; and weather-related disasters (e.g., tornado or 

lightning strike) may impact surface facilities.

If a natural disaster occurs that affects normal operation of the injection well, perform the 

following: 

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 Initiate shutdown plan. 

o Shut in well (close flow valve). 

o Vent CO2 from surface facilities.

o Limit access to wellhead 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 and 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 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, inititate shutdown 

plan. 

o Shut in well (close flow valve). 

o Vent CO2 from surface facilities.

o Limit access to wellhead 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#2 

Permit Number: IL-115-6A-0001 Page F7 of 15

Induced Seismic Event. Induced seismic events typically refer to minor seismic events that are 

caused by human activity which alters the stresses and fluid pressures in the earth's crust. 

Induced seismicity 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 and 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 a 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 state with the threshold conditions and operational response actions. 
Emergency and Remedial Response Plan for ADM CCS#2 

Permit Number: IL-115-6A-0001 Page F8 of 15

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 normal operation within permitted levels.

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 normal operation within permitted levels.

2. Within 24 hours of the incident, notify the UIC Program Director

and ISGS of the operating status of the well.

Orange 

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

Local observation or felt report (3).

1. Continue normal operation within permitted levels.

2. Within 24 hours of the incident, notify the UIC Program Director, 

ISGS, and ADM Communications of the operating status of the 

well. 

3. Review seismic and operational data.

4. Report findings to the UIC Program Director and issue corrective 

actions (5). 

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. Onset of damage is defined as cosmetic damage to structures – such as bricks dislodged from chimneys and parapet walls, broken windows, 

and fallen 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#2 

Permit Number: IL-115-6A-0001 Page F9 of 15

Table F-2b. ADM Decatur Seismic Monitoring System (1) 

Operating State Threshold Condition Response Action

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

Local observation or report (3). 

1. Initiate rate reduction plan.

2. Vent CO2 from surface facilities.

3. Within 24 hours of the incident, notify the UIC Program Director, 

ISGS, and ADM Communications of the operating status of the 

well.

4. Limit access to wellhead to authorized personnel only. 

5. Communicate with ADM personnel and local authorities to initiate 

evacuation plans, as necessary. 

6. 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). 

7. Determine if leaks to ground water or surface water occurred. 

8. If USDW contamination is detected, 

a. Notify the UIC Program Director within 24 hours of 

the determination. 

b. Initiate shutdown plan.

c. Shut in well (close flow valve).

d. Vent CO2 from surface facilities.

e. Identify and implement appropriate remedial actions 

(in consultation with the UIC Program Director). 

9. Review seismic and operational data.

10. Report findings to the UIC Program Director and issue corrective 

actions (5).

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 fallen 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#2 

Permit Number: IL-115-6A-0001 Page F10 of 15

Table F-2c. ADM Decatur Seismic Monitoring System (1) 

Operating State Threshold Condition Response Action

Red 

Seismic event greater than M2.0 (2);

Local observation or report (3); and 

Local report and confirmation of damage (4). 

1. Initiate shutdown plan.

2. Shut in well (close flow valve). Vent CO2 from surface 

facilities.

3. Within 24 hours of the incident, notify the UIC Program 

Director, ISGS, and ADM Communications of the operating 

status of the well. 

4. Limit access to wellhead to authorized personnel only. 

5. Communicate with ADM personnel and local authorities to 

initiate evacuation plans, as necessary. 

6. 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). 

7. Determine if leaks to ground water or surface water occurred. 

8. If USDW contamination is detected, 

a. Notify the UIC Program Director within 24 hours of 

the determination. 

b. Identify and implement appropriate remedial actions 

(in consultation with the UIC Program Director). 

9. Review seismic and operational data.

10. Report findings to the 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 fallen 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#2 

Permit Number: IL-115-6A-0001 Page F11 of 15

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#2 

Permit Number: IL-115-6A-0001 Page F12 of 15

Part 4: Response Personnel and Equipment

Site personnel, project personnel, and local authorities will be relied upon to implement this 

ERRP. The injection well and areas to the west and southwest are located within the limits of 

the City of Decatur; however, adjacent areas to the southeast, east, and north are outside of 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 

Director.

Local Authorities (including but not limited to): 

Agency: 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) 312-886-6234 

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 (cessation of injection, well shut-in, and 

evacuation) will generally not require specialized equipment to implement. Where specialized 

equipment (such as a drilling rig or logging equipment) is required, the designated Subcontractor 

Project Manager shall be responsible for its procurement. 
Emergency and Remedial Response Plan for ADM CCS#2 

Permit Number: IL-115-6A-0001 Page F13 of 15

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 Communications, 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 

public (through either interview, press release, Web posting, or other) in the event of an 

emergency situation related to the injection 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 

emergency.

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 Media@adm.com. 
Emergency and Remedial Response Plan for ADM CCS#2 

Permit Number: IL-115-6A-0001 Page F14 of 15

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 area of review (AOR) re-evaluation, 

• within a prescribed period (to be determined by the permitting agency) following any 

significant changes to the injection process, the injection 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.

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 SOP 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 

trained and possess the required skills to perform their relevant emergency response activities 

described in the ERRP.
Emergency and Remedial Response Plan for ADM CCS#2 

Permit Number: IL-115-6A-0001 Page F15 of 15

Figure F-2. Local area map for the IL-ICCS project. Emergency & remedial response activities will most likely be within the “area of review” highlighted on the map. Source: ISGS and ISWS well databases, current as of May 10, 2011.