Emergency and Remedial Response Plan for ADM CCS#2 Permit Number: IL

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- 000 1 Page F 1 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 ( CO 2 ) 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
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Facility Contacts: A site

- specific list of facility contacts will be devel oped 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) describe s 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 ca re periods.

I f 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. I nitiate 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.

Whe re 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 (U SDWs); 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

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- 000 1 Page F 2 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 projec t could potentially result in an emergency

res ponse:

• 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;

• CO 2 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 EMERG ENCY 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. Serio us 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 infr astructure.

In the event of an emergency requiring cessation of injection, CO 2 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 Dispat ch at (217) 424-4444 and ADM Corporate Communications at (217) 424-5413.Emergency and Remedial Response Plan for ADM CCS#2 Permit Number: IL

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- 000 1 Page F 3 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. Automati c shutdown devices are activated.

• Wellhead pressure exce eds 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 h ours (40 CFR 146.91(c)(3) of any triggerin g 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 determin e 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 CO 2 from surface facilities.

o Limit access to wellhead to autho rized 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 I f there has been a loss of mechanical integrity, inititate shutdown plan.

o Shut in well (close flow valve).

o Vent CO 2 from surfac e facilities.

o Reset a utomatic 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 Pro gram Director)

.Emergency and Remedial Response Plan for ADM CCS#2 Permit Number: IL

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- 000 1 Page F 4 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:

• Im mediately 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 CO 2 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 appropri ate 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

mec hanical integrity

. o I f there has been a loss of mechanical integrity, initiate shutdown plan.

o Sh ut in well (close flow valve).

o Vent CO 2 from surface facilities.

o Reset or repair automatic shutdown devices.

o Monitor well pressure, temperature, and annulus pre ssure (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

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- 000 1 Page F 5 of 15 Potential Brine or CO 2 Leakage to USDW . Elevated concentratio ns of indicator parameter(s) in groundwater sample(s) or other evidence of fluid (brine) or CO 2 leakage into a USDW.

Response Actions:

• Immediately notify the ADM plant superintendent or designee.

• Notify the UIC Program Director within 24 hours of the eme rgency 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 CO 2 from surface facilities.

o Collect a confirmation sample(s) of groundwater and analyze for indicator para meters.

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 ex tent 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 mitigat e 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 (frequency to be determined by ADM and the UIC Program Direc tor) until unacceptable adverse USDW impact has been fully addressed.Emergency and Remedial Response Plan for ADM CCS#2 Permit Number: IL

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- 000 1 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 earthq uake 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 we ll, 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 d etermine 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 CO 2 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 I f there has been a loss of mechanical integrity, inititate shutdown plan.

o Shut in well (close flow valve).

o Vent CO 2 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 app ropriate remedial actions (in consultation with the UIC Program Director).Emergency and Remedial Response Plan for ADM CCS#2 Permit Number: IL

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- 000 1 Page F 7 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 eart h's crust. I nduced 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 condition s , it is highly unlikely that injection operations would ever induce a seismic event outside a n 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 s ite ’ 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 s eismic 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

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- 0001 Page F 8 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, n otify the UIC Program Director and ISGS of the operating stat us 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 th e incident, n otify 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 M 2.0 (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 Cente r using the nat ional 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

, bro ken 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

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- 0001 Page F 9 of 15 Table F

- 2b. ADM Decatur Seismic Monitoring System (1) Operating State Threshold Condition Response Action



## Magenta Sei smic event greater than M2.0 (2) ; and Local observation or report (3)

. 1. Initiate rate reduction plan. 2. Vent CO 2 from surface facilities. 3. Within 24 hours of the incident, n otify the UIC Program Director

, ISGS, and ADM Communications of the operating stat us 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. N otify the UIC P rogram Director within 24 hours of the determination. b. Initiate shutdown plan.

c. Sh ut in well (close flow valve). d. Vent CO 2 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

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- 0001 Page F 10 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 CO 2 from surface facilities. 3. Within 24 hours of the incident, n otify the UIC Program Director , ISGS, and ADM Communications of the operating
stat us of the well. 4. Limit access to wellhead to authorized personnel only. 5. Communicate with ADM personnel and local a uthorities 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. 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). 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. S eismic event s < 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 Cente r 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
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- 0001 Page F 11 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 o f the seismic event. 3. An email alert notification is sent out for events with magnitudes greater than M 1.0. 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 locatio n 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
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- 0001 Page F 12 of 15 Part 4: Response Personnel and Equipment Site personnel, project personnel, and local authori ties 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 EP A National Response Center (24 hr) 800-424-8802 Illinois State Geologi cal 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. Resp onse 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
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- 0001 Page F 13 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 C ommunication s, in consultation with the UIC Program Director

, will determine t he 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 wit h 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 indivi dual 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
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- 0001 Page F 14 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 indic ates that no amendments to the ERRP are necessary, provide the perm itting 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 “ Envi ronmental Training, Awareness and Competence.” Periodic t raining will be provided, not less than annually, to well operators, plant safety and environmental personnel, the plant manager, plant superintendent, and corporate communications. The t raining pl an 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

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- 0001 Page F 15 of 15 Figure F-2

. Local area map for the IL

- ICCS project. Emergency & remedial r esponse activities will most likely be within the “area of review” highlighted on the map. Source: ISGS and ISWS well databa ses, current as of May 10, 2011.