Testing and Monitoring Plan for FutureGen Alliance Page C1 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

ATTACHMENT C: TESTING AND MONITORING PLAN 

Facility Information 

Facility Name: FutureGen 2.0 Morgan County CO2 Storage Site 

IL-137-6A-0003 (Well #3) 

Facility Contacts: Kenneth Humphreys, Chief Executive Officer, 

FutureGen Industrial Alliance, Inc., Morgan County Office, 

73 Central Park Plaza East, Jacksonville, IL 62650, 217-243-8215 

Location of Injection Well: Morgan County, IL; 26−16N−9W; 39.80097oN and 90.07544oW 

Approach and Strategy of the Monitoring Network 

This Testing and Monitoring Plan describes how the FutureGen Alliance will monitor the site 

pursuant to 40 CFR 146.90. In addition to demonstrating that the well is operating as planned, 

the carbon dioxide plume and pressure front are moving as predicted, and that there is no 

endangerment to underground sources of drinking water (USDWs), the monitoring data will be 

used to validate and adjust the geological models used to predict the distribution of the CO2

within the injection zone to support AoR reevaluations and a non-endangerment demonstration. 

The monitoring network (Figure 1) is a comprehensive network designed to detect unforeseen 

CO2 and brine leakage out of the injection zone and for the protection of USDWs. Central to this 

monitoring strategy is the measurement of CO2 saturation within the reservoir using three 

reservoir access tubes (RATs) extending through the base of the Mount Simon Formation and 

into the Precambrian basement. The CO2 saturation will be measured using pulsed-neutron 

capture (PNC) logging across the injection zone and primary confining zone. The three wells 

have been placed at increasing radial distances from the injection site to provide measures of 

CO2 saturation at locations within the outer edges of the predicted 1-, 2- and 4-year CO2 plumes,

respectively. The three RAT installations have also been distributed across three different 

azimuthal directions, providing CO2 arrival information for three of the four predicted lobes of 

the CO2 plume. 

The monitoring network will also include two Single-Level in-Reservoir (SLR) wells, completed 

across the planned injection interval within the Mount Simon Formation to continuously and 

directly measure for pressure, temperature, and specific conductance (P/T/SpC) over the 

injection and post-injection monitoring periods. Pressure at these locations will be compared 

with numerical model predictions and used to calibrate the model as necessary. These wells will 

initially be sampled for aqueous chemistry. However, once supercritical CO2 (scCO2) 

breakthrough occurs, these wells can no longer provide representative fluid samples because of 

the two-phase fluid characteristics and buoyancy of scCO2. 

Another central component of the monitoring strategy is to monitor for any unforeseen leakage 

from the reservoir as early as possible. This will be accomplished by monitoring for CO2 and 
Testing and Monitoring Plan for FutureGen Alliance Page C2 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

brine intrusion immediately above the confining zone. These two “early-detection” wells will be 

completed in the first permeable unit above the Eau Claire caprock, within the Ironton 

Sandstone. These wells will be continuously monitored for P/T/SpC, and periodically sampled 

to characterize aqueous chemistry. Leakage detected at the Above Confining Zone (ACZ) wells 

would most likely be identified based on pressure response, but it may also result in changes in

aqueous chemistry. 

The monitoring network will also include one well located in the lowermost USDW, the St. Peter 

Sandstone. This well will be instrumented to monitor continuously for P/T/SpC, and 

periodically samples will be collected for characterizing aqueous chemistry. This USDW well is 

co-located with the ACZ well located closest to the injection well site. 

Comparison of observed and simulated arrival responses at the early-detection wells and 

shallower monitoring locations will be continued throughout the life of the project and will be 

used to calibrate and verify the model, and improve its predictive capability for confirming CO2

containment and/or assessing the long-term environmental impacts of any CO2 leakage. If deep 

early-detection monitoring locations indicate that primary confining zone leakage has occurred, a 

comprehensive near-surface-monitoring program will be activated to fully assess environmental 

impacts relative to baseline conditions. 

Beyond the direct measures of the monitoring well network, two indirect monitoring 

techniques—deformation monitoring and microseismic monitoring—will be used to detect the 

development of the pressure front, which results from the injection of CO2. The objective of the 

deformation monitoring is to provide a means to detect the development of an asymmetric plume 

that would be different from the predicted plume shape. The objective of the microseismic 

monitoring network is to accurately determine the locations, magnitudes, and focal mechanisms 

of injection-induced seismic events with the primary goals of 1) addressing public and 

stakeholder concerns related to induced seismicity, 2) estimating the spatial extent of the 

pressure front from the distribution of seismic events, and 3) identifying features that may 

indicate areas of caprock failure and possible containment loss. 

The monitoring network will address transport uncertainties by adopting an “adaptive” or 

“observational” monitoring approach (i.e., the monitoring approach will be adjusted as needed 

based on observed monitoring and updated modeling results). This monitoring approach will 

involve continually evaluating monitoring results and making adjustments to the monitoring 

program as needed, including the option to install additional wells in outyears to verify CO2

plume and pressure front evolution and/or evaluate leakage potential (any such changes to this 

testing and monitoring approach will be made in consultation with the UIC Program Director). 

Specifically, as part of this adaptive monitoring approach, a pressure-monitoring well will be 

constructed within 5 years of the start of injection. The final placement/location of this well will 

be informed by any observed asymmetry in pressure front development during the early years of 

injection and will be located outside the CO2 plume extent. The distance from the plume 

boundary will be based on the monitoring objective of providing information that will be useful 

for both leakage detection and model calibration within the early years of project operation. It is 

estimated that the well will be located less than 5 miles from the predicted plume extent in order 

to provide an intermediate-field pressure monitoring capability that would benefit leak detection 
Testing and Monitoring Plan for FutureGen Alliance Page C3 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

capabilities and meet the requirement for direct pressure monitoring of the pressure front (i.e., 

outside the CO2 plume area). 

A second but less desirable approach would be to locate the well at a more distal location (e.g., 

15-20 miles) so that there is time to install the well prior to pressure front arrival (at Waverley it 

is predicted to take 4 to 5 years). This location would have very limited benefit from a leak 

detection perspective, but it would be useful for calibrating the reservoir model. 

Quality assurance and surveillance measures: 

Data quality assurance and surveillance protocols adopted by the project have been designed to 

facilitate compliance with the requirements specified in 40 CFR 146.90(k). Quality Assurance 

(QA) requirements for direct measurements within the injection zone, above the confining zone, 

and within the shallow USDW aquifer that are critical to the Testing and Monitoring program 

(e.g., pressure and aqueous concentration measurements) are described in the Quality Assurance 

and Surveillance Plan (QASP) that is attached to this Testing and Monitoring Plan. These 

measurements will be performed based on best industry practices and the QA protocols 

recommended by the geophysical services contractors selected to perform the work. The QASP 

is presented in Appendix G of this Plan.

Collection and recording of continuous monitoring data will occur at the frequencies described in 

Table 1. 

Table 1. Sampling and Recording Frequencies for Continuous Monitoring.

Well Condition Minimum sampling 

frequency: once every

Minimum recording 

frequency: once every

For operating injection wells that are required to 

monitor continuously:

5 seconds 5 minutes 1

For injection wells that are shut-in: 4 hours 4 hours

For monitoring wells (USDW, ACZ, SLR): 30 minutes 2 hours

1 This can be an average of the sampled readings* over the previous 5-minute recording interval, or the maximum 

(or minimum, as appropriate) value identified over that recording interval

Notes:

Sampling frequency refers to how often the monitoring device obtains data from the well for a particular 

parameter. For example, a recording device might sample a pressure transducer monitoring injection pressure 

once every two seconds and save this value in memory.

Recording frequency refers to how often the sampled information gets recorded to digital format (such as a 

computer hard drive). Following the same example above, the data from the injection pressure transducer might 

be recorded to a hard drive once every minute.
Testing and Monitoring Plan for FutureGen Alliance Page C4 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Figure 1. Monitoring Network Layout and Predicted Plume Extents at Multiple Time Intervals.
Testing and Monitoring Plan for FutureGen Alliance Page C5 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Carbon Dioxide Stream Analysis 

FutureGen will conduct injection stream analysis to meet the requirements of 40 CFR 146.90(a), 

as described below. 

Samples of the CO2 stream will be collected regularly (e.g., quarterly) for chemical analysis of 

the parameters listed in Table 2. Continuous monitoring is described in Table 1 of this plan. 

Table 2. Parameters and Frequency for CO2 Stream Analysis. 

Parameter/Analyte Frequency

Pressure Continuous

Temperature Continuous

CO2 (%) quarterly

Water (lb/mmscf) quarterly

Oxygen (ppm) quarterly

Sulfur (ppm) quarterly

Arsenic (ppm) quarterly

Selenium (ppm) quarterly

Mercury (ppm) quarterly

Argon (%) quarterly

Hydrogen Sulfide (ppm) quarterly

Sampling methods: 

Grab samples of the CO2 stream will be obtained for analysis of gases, including CO2, O2, H2S,

Ar, and water moisture. Samples of the CO2 stream will be collected from the CO2 pipeline at a 

location where the material is representative of injection conditions. A sampling station will be 

installed in the ground or on a structure close to the pipeline and connected to the pipeline via a 

sampling manifold with pressure and temperature (P/T) instrumentation to accommodate doublesided constant pressure sampling cylinders that will be used to collect the samples. The 

collection procedure is designed to collect and preserve representative CO2 fluid samples from 

the pipeline to maintain pressure, phase, and constituent integrity and facilitate sample transport 

for analysis. 

Analytical techniques: 

See Section B.1.4 of the FutureGen QASP for analytical techniques for indirect CO2

measurement. 

Laboratory to be used/chain-of-custody procedures: 

See Sections B.1.4 through B.1.7 of the FutureGen QASP for laboratory quality and Section 

B.1.3 for sample handling and custody. 

Quality assurance and surveillance measures: 

See the FutureGen QASP, including Sections B.14 for data management, B.1 for CO2 sampling 

and analysis, and B.1.3 and B.14 for analytical techniques and chain of custody procedures. 
Testing and Monitoring Plan for FutureGen Alliance Page C6 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Continuous Recording of Injection Pressure, Rate, and Volume; Annulus Pressure 

FutureGen will conduct continuous monitoring of injection parameters to meet the requirements 

of 40 CFR 146.90(b), as described below. 

Continuous Recording of Injection Mass Flow Rate 

The mass flow rate of CO2 injected into the well field will be measured by a flow meter skid 

with a Coriolis mass flow transmitter for each well. Each meter will have an analog output 

(Micro Motion Coriolis Flow and Density Meter Elite Series or similar). A total of six flow 

meters will be supplied, providing for two spare flow meters to allow for flow meter servicing 

and calibration. The flow meters will be connected to the main CO2 storage site SCADA system 

for continuous monitoring and control of the CO2 injection rate into each well. 

Continuous Recording of Injection Pressure 

The pressure of the injected CO2 will be continuously measured for each well at a regular 

frequency by an electronic pressure transmitter with analog output mounted on the CO2line 

associated with each injection well at a location near the wellhead. The transmitter will be 

connected to the annulus pressurization system (APS) programmable logic controller (PLC) 

located in the Control Building adjacent to the injection well pad. 

Continuous Recording of Injection Temperature 

The temperature of the injected CO2 will be continuously measured for each well at a regular 

frequency by an electronic temperature transmitter. The temperature transmitter will be mounted 

in a temperature well in the CO2line at a location close to the pressure transmitter near the 

wellhead. The transmitter will be connected to the APS PLC located in the Control Building 

adjacent to the injection well pad. 

Instruments for measuring surface injection pressure and temperature will be calibrated initially 

before commencing injection and recalibrated periodically as needed based on regular (e.g., 

quarterly) instrument checks. These instruments for measuring surface injection pressure and 

temperature will be recalibrated annually. 

Bottomhole Pressure and Temperature 

An optical or electronic P/T gauge will be installed on the outside of the tubing string, 

approximately 30 ft above the packer, and ported into the tubing to continuously measure CO2

injection P/T inside the tubing at this depth. In addition, injection P/T will be continuously 

measured at the surface via real-time P/T instruments installed in the CO2 pipeline near the 

pipeline interface with the wellhead. 

The CO2 injection stream will be continuously monitored at the surface for pressure, 

temperature, and flow, as part of the instrumentation and control systems for the FutureGen CO2

Pipeline and Storage Project. The P/T will also be monitored within each injection well at a 

position located immediately above the injection zone at the end of the injection tubing. The 

downhole sensor will be the point of compliance for maintaining injection pressure below 90% 
Testing and Monitoring Plan for FutureGen Alliance Page C7 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

of formation fracture pressure. If the downhole probe goes out between scheduled maintenance 

events then the surface pressure limitation noted in Attachment A of this permit will be used as a 

backup until the downhole probe/gauge is repaired or replaced. 

Corrosion Monitoring 

FutureGen will conduct corrosion monitoring of well materials quarterly to meet the 

requirements of 40 CFR 146.90(c), as described below. 

Corrosion of well materials will be monitored using the corrosion coupon method. Corrosion 

monitoring of well casing and tubing materials will be conducted using coupons placed in the 

CO2 pipeline. The coupons will be made of the same material as the long string casing and the 

injection tubing. The coupons will be removed quarterly and assessed for corrosion using the 

ASTM International (ASTM) G1-03, Standard Practice for Preparing, Cleaning, and Evaluating 

Corrosion Test Specimens (ASTM 2011). Upon removal, coupons will be inspected visually for 

evidence of corrosion (e.g., pitting). The weight and size (thickness, width, length) of the coupons 

will also be measured and recorded each time they are removed. 

The corrosion rate will be calculated as the weight loss during the exposure period divided by the 

duration (i.e., weight loss method). 

Casing and tubing will also be evaluated periodically for corrosion throughout the life of the 

injection well by running wireline casing inspection logs (CILs). The frequency of running these 

tubing and casing inspection logs will be determined based on site-specific parameters and well 

performance. Wireline tools will be lowered into the well to directly measure properties of the 

well tubulars that indicate corrosion. The tools (described in Table 3), which may be used to 

monitor the condition of well tubing and casing, include: 

 Mechanical casing evaluation tools, referred to as calipers, which have multiple “fingers” 

that measure the inner diameter of the tubular as the tool is raised or lowered through the 

well.

 Ultrasonic tools, which are capable of measuring wall thickness in addition to the inner 

diameter (radius) of the well tubular and can also provide information about the outer 

surface of the casing or tubing. 

 Electromagnetic tools, which are able to distinguish between internal and external 

corrosion effects using variances in the magnetic flux of the tubular being investigated. 

These tools are able to provide mapped (circumferential) images with high resolution 

such that pitting depths, due to corrosion, can often be accurately measured. 
Testing and Monitoring Plan for FutureGen Alliance Page C8 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 3. Wireline Tools for Monitoring Corrosion of Casing and Tubing.

Tool Name Mechanical Ultrasonic Electromagnetic

Multifinger Imaging Tool(a) Ultrasonic Imager Tool(a) High-ResolutionVertilog(b)

Parameter(s)

Measured

Internal radius; does not

measure wall thickness

Inner diameter, wall thickness,

acoustic impedance, cement

bonding to casing

Up to 180 measurements per

revolution

Magnetic flux leakage

(internal and external) Full

360-degree borehole coverage

Tool OD (in.) 1.6875, 2.75, 4 (multiple

versions available)

3.41 to 8.625 2.2 to 8.25

Tubular Size That

Can Be Measured

Min/Max (in.)

2/4.5, 3/7, 5/10 (multiple

versions available)

4.5/13.375 4.5/9.625

Comments,

limitations,special

requirements, etc.

Typically run on memory

using slickline. Can also be

run in surface real-time mode.

Can detect evidence of

defects/corrosion on casing

walls(internal/external),

quality of cement bond to pipe,

and channels in cement.

Moderate logging speed (30

ft/min) is possible.

Can distinguish between

general corrosion, pitting, and

perforations. Can measure

pipe thickness.

High logging speed (200

ft/min) is possible.

Cannot evaluate multiple

strings of tubular

simultaneously.

(a) Schlumberger Limited 

(b) Baker Hughes, Inc. 
Testing and Monitoring Plan for FutureGen Alliance Page C9 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Groundwater Quality Monitoring

FutureGen will conduct groundwater quality/geochemical monitoring above the confining zone 

to meet the requirements of 40 CFR 146.90(d). 

FutureGen will conduct periodic fluid sampling throughout the injection phase in three wells 

constructed for the purpose of this project: two ACZ monitoring wells in the Ironton Sandstone 

(the first permeable unit above the confining zone) and a lowermost USDW well in the St. Peter 

Sandstone. Details about these wells are in Table 4, and Figure 1 is a map with the well 

locations. The coordinates (in decimal degrees) of the wells are in Appendix A of this plan. 

Well construction information and well schematics are in Appendix B of this plan.

Table 4. Monitoring Wells to Be Used for GroundWater/Geochemical Sampling Above the Confining Zone. 

Above Confining Zone (ACZ) USDW

Number of Wells 2 1

Total Depth (ft) 3,470 2,000

Lat/Long (WGS84) ACZ1: 39°48'01.24"N, 90°04'41.87"W

ACZ2: 39°48'01.06"N, 90°05'16.84"W

USDW1: 39°48'01.73"N, 90°04'41.87"W

Monitored Zone Ironton Sandstone St. Peter Sandstone

Monitoring

Instrumentation

Fiber-optic (microseismic) cable

cemented in annulus;

P/T/SpC probe in monitored interval*

P/T/SpC probe in

monitored interval*

* The P/T/SpC (pressure, temperature, specific conductance) probe is an electronic downhole multi-parameter

probe incorporating sensors for measuring fluid P/T/SpC within the monitored interval. The probe is installed

inside the tubing string, which is perforated (slotted) over the monitoring interval. Sensor signals are multiplexed 

to a surface data logger through a single conductor wireline cable. 

FutureGen will also conduct baseline sampling in the shallow, semi-consolidated glacial 

sediments that make up the surficial aquifer. This sampling will use nine private water wells and

one shallow monitoring well that has been drilled for the project (Figure 2). The locations of the 

surficial aquifer monitoring wells are tabulated in Appendix C of this plan. 
Testing and Monitoring Plan for FutureGen Alliance Page C10 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Figure 2. Surficial Aquifer Monitoring Well Locations. Well FG-1 is a dedicated well drilled for the purposes 

of the FutureGen 2.0 Project. FGP-1 through FGP-10 are local landowners’ wells. 

The tables below list the parameters that will be measured and the sampling frequencies. They 

include both dissolved gas compositional analysis (including CO2) and measurements of 

dissolved inorganic carbon and pH. Continuous monitoring is described in Table 1 of this plan.
Testing and Monitoring Plan for FutureGen Alliance Page C11 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 5. Sampling Schedule for Surficial Aquifer Monitoring Wells. 

Monitoring well name/location/map reference: Surficial aquifer monitoring wells (Figure 2)

Well depth/formation(s) sampled: Shallow glacial sediments (approx. 17 ft – 49 ft)

Parameter/Analyte Frequency

(Baseline)

Frequency

(Injection Phase)

Dissolved or separate-phase CO2 At least 3 sampling events None planned

Water-level At least 3 sampling events None planned

Temperature At least 3 sampling events None planned

Other parameters, including total dissolved solids, pH, 

specific conductivity, major cations and anions, trace 

metals, dissolved inorganic carbon, total organic

carbon, carbon and water isotopes, and radon

At least 3 sampling events None planned

Table 6. Sampling Schedule for the USDW Monitoring Well. 

Monitoring well name/location/map reference: One USDW monitoring well (see Figure 1)

Well depth/formation(s) sampled: St. Peter Sandstone (2,000 ft)

Parameter/Analyte Frequency

(Baseline)

Frequency

(Injection Phase)

Dissolved or separate-phase CO2 At least 3 sampling events Quarterly for 3 years, then semi-annually 

for 2 years and annually thereafter

Pressure Continuous, 1 year 

minimum

Continuous

Temperature Continuous, 1 year 

minimum

Continuous

Other parameters, including total

dissolved solids, pH, specific conductivity,

major cations and anions, trace metals,

dissolved inorganic carbon, total organic

carbon, carbon and water isotopes, and

radon

At least 3 sampling events Quarterly for 3 years, then semi-annually 

for 2 years and annually thereafter

Note: For details and information on continuous monitoring, see Table 1.
Testing and Monitoring Plan for FutureGen Alliance Page C12 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 7. Sampling Schedule for ACZ Monitoring Wells 

Monitoring well name/location/map reference: Two ACZ monitoring wells (see Figure 1)

Well depth/formation(s) sampled: Ironton Sandstone (3,470 ft)

Parameter/Analyte Frequency (Baseline) Frequency (Injection Phase)

Dissolved or separate-phase CO2 At least 3 sampling events Quarterly for 3 years, then semi-annually

for 2 years and annually thereafter

Pressure Continuous, 1 year 

minimum

Continuous

Temperature Continuous, 1 year 

minimum

Continuous

Other parameters, including total

dissolved solids, pH, specific conductivity,

major cations and anions, trace metals,

dissolved inorganic carbon, total organic

carbon, carbon and water isotopes, and

radon

At least 3 sampling events Quarterly for 3 years, then semi-annually

for 2 years and annually thereafter

Note: For details and information on continuous monitoring, see Table 1.

Sampling methods: 

Sampling and analytical requirements for target parameters are given in Tables 8 and 9,

respectively. A comprehensive suite of geochemical and isotopic analyses will be performed on 

collected fluid samples and analytical results will be used to characterize baseline geochemistry 

and provide a metric for comparison during operational phases. Selection of this initial analyte 

list was based on relevance for detecting the presence of fugitive brine and CO2. 

During all groundwater sampling, field parameters (pH, specific conductance, and temperature) 

will be monitored for stability and used as an indicator of adequate well purging (i.e., parameter 

stabilization provides indication that a representative sample has been obtained). Calibration of 

field probes will follow the manufacturer’s instructions using standard calibration solutions. A 

comprehensive list of target analytes under consideration and groundwater sample collection 

requirements is provided in Table 8. 

All sampling and analytical measurements will be performed in accordance with project quality 

assurance requirements, samples will be tracked using appropriately formatted chain-of-custody 

forms, and analytical results will be managed in accordance with a project-specific data 

management plan. 

The relative benefit of each analytical measurement will be evaluated throughout the design and 

initial injection testing phase of the project to identify the analytes best suited to meeting project 

monitoring objectives under site-specific conditions. If some analytical measurements are shown 

to be of limited use, they will be removed from the analyte list and not carried forward through 

the operational phases of the project. This selection process will consider the uniqueness and 

signature strength of each potential analyte and whether their characteristics provide for a highvalue leak-detection capability. Any modification to the parameter list in Table 8 will be made in 

consultation with the UIC Program Director. Modifications to the parameter list will also require 

modifications to the permits through the process described in 40 C.F.R. Part 144. 
Testing and Monitoring Plan for FutureGen Alliance Page C13 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 8. Aqueous Sampling Requirements for Target Parameters. 

Parameter Volume/Container Preservation

Holding

Time

Major Cations: Al, Ba, Ca, Fe, K, Mg, Mn,

Na, Si,

20-mL plastic vial Filtered (0.45 μm), HNO3 to pH <2 60 days

Trace Metals: Sb, As, Cd, Cr, Cu, Pb, Se, Tl 20-mL plastic vial Filtered (0.45 μm), HNO3 to pH <2 60 days

Cyanide (CN-) 250-mL plastic vial NaOH to pH > 12, 0.6 g ascorbic 

acid Cool 4°C, 

14 days

Mercury 250-mL plastic vial Filtered (0.45 μm), HNO3 to pH <2 28 days

Anions: Cl-, Br-, F

-

, SO4

2-

, NO3

- 125-mL plastic vial Filtered (0.45 μm), Cool 4°C 45 days

Total and Bicarbonate Alkalinity (as CaCO3

2-

) 100-mL HDPE Filtered (0.45 μm), Cool 4°C 14 days

Gravimetric Total Dissolved Solids (TDS) 250-mL plastic vial Filtered (0.45 μm), no preservation,

Cool 4°C

7 days

Water Density 100-mL plastic vial No preservation, Cool 4°C

Total Inorganic Carbon (TIC) 250-mL plastic vial H2SO4 to pH <2, Cool 4°C 28 days

Dissolved Inorganic Carbon (DIC) 250-mL plastic vial Filtered (0.45 μm), H2SO4 to pH <2, 

Cool 4°C

28 days

Total Organic Carbon (TOC) 250-mL amber glass Unfiltered, H2SO4 to pH <2, Cool

4°C

28 days

Dissolved Organic Carbon (DOC) 125-mL plastic vial Filtered (0.45 μm), H2SO4 to pH <2, 

Cool 4°C

28 days

Volatile Organic Analysis (VOA) Bottle set 1: 3-40-mL 

sterile clear glass vials

Bottle set 2: 3-40-mL 

sterile amber glass vials 

Zero headspace, Cool <6 °C, Clear 

glass vials will be UV-irradiated for 

additional sterilization

7 days

Methane Bottle set 1: 3-40-mL 

sterile clear glass vials

Bottle set 2: 3-40-mL 

sterile amber glass vials

Zero headspace, Cool <6 °C, Clear 

glass vials (bottle set 1) will be UVirradiated for additional sterilization

7 days

Stable Carbon Isotopes 13/12C (δ

13C) of DIC in 

Water

60-mL plastic or glass Filtered (0.45 μm), Cool 4°C 14 days

Radiocarbon 14C of DIC in Water 60-mL plastic or glass Filtered (0.45 μm), Cool 4°C 14 days

Hydrogen and Oxygen Isotopes 2/1H (δD) and 

18/16O (δ18O) of Water

60-mL plastic or glass Filtered (0.45 μm), Cool 4°C 45 days

Carbon and Hydrogen Isotopes (14C, 13/12C, 

2/1H) of Dissolved Methane in Water

1-L dissolved gas 

bottle or flask

Benzalkonium chloride capsule, 

Cool 4°C

90 days

Compositional Analysis of Dissolved Gas in 

Water (including N2, CO2, O2, Ar, H2, He, 

CH4, C2H6, C3H8, iC4H10, nC4H10, iC5H12, 

nC5H12, and C6+)

1-L dissolved gas 

bottle or flask

Benzalkonium chloride capsule, 

Cool 4°C

90 days

Radon (

222Rn) 1.25-L PETE Pre-concentrate into 20-mL

scintillation cocktail. Maintain

groundwater temperature prior to

pre-concentration

1 day

pH Field parameter None <1 h

SpecificConductance Field parameter None <1 h

HDPE = high-density polyethylene; PETE = polyethylene terephthalate.
Testing and Monitoring Plan for FutureGen Alliance Page C14 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 9. Analytical Requirements. 

Parameter Analysis Method

Detection 

Limit or 

Range

Typical 

Precision/ 

Accuracy QC Requirements

A.1.1 Major Cations: Al, Ba,

Ca, Fe, K, Mg,

A.1.2 Mn, Na, Si,

A.1.3 ICP-AES, EPA Method 6010B or 

similar

A.1.4 1 to 80 μg/L

(analyte

dependent)

A.1.5 ±10%A.1.6 Daily calibration; blanks, LCS, 

and duplicates and matrix 

spikes at 10% level per batch 

of 20

A.1.7 Trace Metals: Sb, As,

Cd, Cr, Cu, Pb, Se, Tl

A.1.8 ICP-MS, EPA Method 6020 or 

similar

A.1.9 0.1 to 2 μg/L 

(analyte 

dependent)

A.1.10 ±10%A.1.11 Daily calibration; blanks, LCS, 

and duplicates and matrix 

spikes at 10% level per batch 

of 20

A.1.12 Cyanide (CN-)A.1.13 SW846 9012A/B A.1.14 5 μg/L A.1.15 ±10%A.1.16 Daily calibration; blanks, LCS, 

and duplicates at 10% level per 

batch of 20

A.1.17 Mercury A.1.18 CVAA SW846 7470A A.1.19 0.2 A.1.20 μg/L ±20%A.1.21 Daily calibration; blanks, LCS, 

and duplicates and matrix 

spikes at 10% level per batch 

of 20

A.1.22 Anions: Cl-, Br-, F

-

,

SO4

2-

, NO3

-

A.1.23 Ion Chromatography, EPA Method 

300.0A or similar

A.1.24 33 to 133 

μg/L (analyte 

dependent)

A.1.25 ±10%A.1.26 Daily calibration; blanks, LCS, 

and duplicates at 10% level per 

batch of 20

A.1.27 Total and Bicarbonate 

Alkalinity (as CaCO3

2-

)

A.1.28 Titration, Standard Methods 2320B A.1.29 1 mg/L ±10%A.1.30 Daily calibration; blanks, LCS, 

and duplicates at 10% level per 

batch of 20

A.1.31 Gravimetric Total

Dissolved Solids (TDS

A.1.32 Gravimetric Method Standard 

Methods 2540C

A.1.33 10 mg/L A.1.34 ±10%A.1.35 Balance calibration, duplicate 

samples

A.1.36 Water DensityA.1.37 ASTM D5057 0.01 g/mL A.1.38 ±10%A.1.39 Balance calibration, duplicate 

samples

A.1.40 Total Inorganic Carbon

(TIC)

A.1.41 SW846 9060A or equivalent

A.1.42 Carbon analyzer, phosphoric acid 

digestion of TIC

A.1.43 0.2 mg/L A.1.44 ±20%A.1.45 Quadruplicate analyses, daily 

calibration

A.1.46 Dissolved Inorganic

Carbon (DIC)

A.1.47 SW846 9060A or equivalent

A.1.48 Carbon analyzer, phosphoric acid 

digestion of DIC

A.1.49 0.2 mg/L A.1.50 ±20%A.1.51 Quadruplicate analyses, daily 

calibration

A.1.52 Total Organic Carbon

(TOC)

A.1.53 SW846 9060A or equivalent

Total organic carbon is converted to 

carbon dioxide by chemical 

oxidation of the organic carbon in the 

sample. The carbon dioxide is 

measured using a non-dispersive 

infrared detector.

A.1.54 0.2 mg/L A.1.55 ±20%A.1.56 Quadruplicate analyses, daily 

calibration

A.1.57 Dissolved Organic

Carbon (DOC)

A.1.58 SW846 9060A or equivalent

A.1.59 Total organic carbon is converted to 

carbon dioxide by chemical 

oxidation of the organic carbon in the 

sample. The carbon dioxide is 

measured using a non-dispersive 

infrared detector.

A.1.60 0.2 mg/L A.1.61 ±20%A.1.62 Quadruplicate analyses, daily 

calibration

A.1.63 Volatile Organic 

Analysis (VOA)

A.1.64 SW846 8260B or equivalent

A.1.65 Purge and Trap GC/MS

A.1.66 0.3 to 15 A.1.67μg/L ±20%A.1.68 Blanks, LCS, spike, spike 

duplicates per batch of 20

A.1.69 Methane A.1.70 RSK 175 Mod

A.1.71 Headspace GC/FID

A.1.72 10 μg/L A.1.73 ±20%A.1.74 Blanks, LCS, spike, spike 

duplicates per batch of 20

A.1.75 Stable Carbon Isotopes 

13/12C (113C) of DIC in 

Water

A.1.76 Gas Bench for 13/12C A.1.77 50 ppm of 

DIC

A.1.78 ±0.2p A.1.79 Duplicates and working 

standards at 10%
Testing and Monitoring Plan for FutureGen Alliance Page C15 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Parameter Analysis Method

Detection 

Limit or 

Range

Typical 

Precision/ 

Accuracy QC Requirements

A.1.80 Radiocarbon 14C of DIC 

in Water

AMS for 14C A.1.81 Range: 0 i 

200 pMC

A.1.82 ±0.5 pMC A.1.83 Duplicates and working 

standards at 10%

A.1.84 Hydrogen and Oxygen 

Isotopes 2/1H (δ ) and 

18/16O (118O) of Water

A.1.85 CRDS H2O Laser A.1.86 Range: -

500‰ to

200‰ vs. 

VSMOW

A.1.87 2/1H: ±2.0‰

A.1.88 18/16O: 

±0.3‰

A.1.89 Duplicates and working 

standards at 10%

A.1.90 Carbon and Hydrogen 

Isotopes (14C, 13/12C, 

2/1H) of Dissolved 

Methane in Water

A.1.91 Offline Prep & Dual Inlet IRMS for 

13C; AMS for 14C

A.1.92 14C Range: 0 

& DupMC

A.1.93 14C: 

±0.5pMC

A.1.94 13C: ±0.2‰

A.1.95 2/1H: ±4.0‰

A.1.96 Duplicates and working 

standards at 10%

A.1.97 Compositional Analysis 

of Dissolved Gas in 

Water (including N2, 

CO2, O2, Ar, H2, He, 

CH4, C2H6, C3H8, 

iC4H10, nC4H10, iC5H12, 

nC5H12, and C6+)

A.1.98 Modified ASTM 1945D A.1.99 1 to 100 ppm 

(analyte 

dependent)

A.1.100 Varies by 

compon-ent

Duplicates and working 

standards at 10%

A.1.101 Radon (

222Rn)A.1.102 Liquid scintillation after preconcentration

A.1.103 5 mBq/L A.1.104 ±10%A.1.105 Triplicate analyses

A.1.106 pH A.1.107 pH electrode A.1.108 2 to 12 pH 

units

A.1.109 0.2 pH unit 

For 

indication 

only

A.1.110 User calibrate, follow 

manufacturer 

recommendations

A.1.111 SpecificConductance A.1.112 Electrode A.1.113 0 to 100 

mS/cm

A.1.114 1% of 

reading

For 

indication 

only

A.1.115 User calibrate, follow 

manufacturer 

recommendations

A.1.116 ICP-AES = inductively coupled plasma atomic emission spectrometry; ICP-MS = inductively coupled plasma mass 

spectrometry; LCS = laboratory control sample; GC/MS = gas chromatography–mass spectrometry; GC/FID = gas 

chromatography with flame ionization detector; AMS = accelerator mass spectrometry; CRDS = cavity ring down 

spectrometry; IRMS = isotope ratio mass spectrometry; LC-MS = liquid chromatography-mass spectrometry; ECD = electron 

capture detector

Laboratory to be used/chain-of-custody procedures: 

Samples will be tracked using appropriately formatted chain-of-custody forms. See Sections 

B.4.3 thru B.4.7 of the FutureGen QASP (Appendix G of this plan) for additional information. 

Plan for guaranteeing access to all monitoring locations: 

The land on which the ACZ and USDW wells are located will either be purchased or leased for 

the life of the project, so access will be secured. 

Access to the surficial aquifer wells will not be required over the lifetime of the project. Access 

to wells for baseline sampling has been on a voluntary basis by the well owner. Nine local 

landowners agreed to have their surficial aquifer wells sampled. See Figure 2 for well locations. 
Testing and Monitoring Plan for FutureGen Alliance Page C16 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Mechanical Integrity Testing 

FutureGen will conduct external mechanical integrity testing (MIT) annually to meet the 

requirements of 40 CFR 146.90(e), as described below. The following MITs will be performed: 

 Pulsed-neutron capture (PNC) logging to quantify the flow of water in or around the 

borehole. Following a baseline PNC log prior to the start of CO2 injection, subsequent 

runs will be compared to the baseline to determine changing fluid flow conditions 

adjacent to the well bore (i.e., formation of channels or other fluid isolation concerns 

related to the well).

 Temperature logging to identify fluid movement along channels adjacent to the well 

bore. In addition to identifying injection-related flows behind casing, temperature logs 

can often locate small casing leaks. 

To satisfy the annual MIT requirement, a PNC logging tool will be run in each injection well 

once per year to look for evidence of upward CO2 migration out of the CO2 storage zone. The 

PNC logging tool will be run twice during each event: once in the gas-view mode to detect CO2

and once in the oxygen-activation mode to detect water. 

A temperature log will also be collected in conjunction with each PNC logging run. Because the 

primary purpose of the external MIT is to demonstrate that there is no upward leakage of fluid 

out of the storage zone, the PNC logging tool will be run to a depth greater than the bottom of 

the caprock. Because the injection tubing will extend to a depth below the caprock, the PNC 

logs will be run inside the tubing; therefore, it will not be necessary to remove the injection 

tubing to conduct the PNC logging. A preliminary schedule for the annual well maintenance 

event is provided in Table 10. 

Table 10. Schedule for Annual Injection Well Maintenance (per Well).

Activity Work

Days

Cum. 

Days

Shut down injection, isolate surface system 1 1

Allow well to sit undisturbed for 24 hours 1 2

Conduct PNC logging (external MIT) 2 4

Kill well 2 6

Slickline set plug in tubing above packer 0.5 6.5

Disconnect CO2 pipeline, instruments, and other lines; remove 

Christmas tree valves for maintenance or replacement

0.5 7

Reinstall Christmas tree valves, re-connect CO2 pipeline, 

instruments, and other lines

1 7

Slickline pull plug from packer 1 9

Perform annular pressure test, internal MIT 1 10

Return well to service 1 10

MIT = mechanical integrity test; PNC = pulsed-neutron capture.

MITs are also required to demonstrate that there are no significant leaks in the casing, tubing, or 

packer. This requirement will be met by continuously monitoring injection pressure on the 

annulus between tubing and long-string casing and annulus fluid volume. These functions will 
Testing and Monitoring Plan for FutureGen Alliance Page C17 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

be provided by the Annular Pressurization System (APS), which is discussed in the Section of 

this document on “Continuous Recording of Injection Pressure, Rate, and Volume; Annulus 

Pressure.” 

All monitoring wells required under this permit will establish and maintain mechanical integrity. 

After construction, each monitoring well must establish Internal and External mechanical 

integrity. Wells that do not have a tubing and packer shall perform a pressure test on the casing. 

Each monitoring well that reaches the Eau Claire (the confining zone) shall establish mechanical 

integrity after construction, shall conduct an Internal mechanical integrity test at least every five 

years or continuously monitor the annulus, and shall conduct an External mechanical integrity 

test at least every five years. The testing of monitoring wells that reach the Eau Claire shall 

continue until they are plugged.It is also anticipated that it will be necessary to replace selected 

well components throughout the 20-year injection period, although the identity of the 

components and their frequency of replacement cannot be determined in advance. However, the 

components most likely to require replacement include the wellhead valves (selected portions), 

the tubing string, the packer, and the bottom-hole P/T gauge and associated cable. A preliminary 

schedule for the 5-year well maintenance event is provided in Table 11. 

Table 11. Schedule for 5-Year Injection Well Maintenance Events (per Well). 

Activity

Work 

Days Cum. Days

Shut down injection, disassemble surface system 1 1

Arrive onsite with equipment rig-up/set-up 3 4

Conduct PNC logging (external MIT) 2 6

Kill well 2 8

Slickline set plug in tubing above packer 0.5 8.5

Disconnect CO2 pipeline, instruments, and other lines; remove 

Christmas tree valves for maintenance or replacement

0.5 9

Pull tubing and P/T gauge and cable 1.5 10.5

Trip back in to pull packer 0.5 11

Pull packer 0.5 11.5

Reinstall new packer w/ plug, trip out to get P/T gauge and cable 1.5 13

Reinstall new P/T gauge and cable and injection tubing 1.5 14.5

Reinstall Christmas tree valves, re-connect CO2 pipeline, 

instruments, and other lines.

1.5 16

Slickline pull plug from packer 1 17

Rig down and demobilize 3 20

Perform annular pressure test, internal MIT 1 21

Return well to service 1 22
Testing and Monitoring Plan for FutureGen Alliance Page C18 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Pressure Fall-Off Testing 

FutureGen will conduct annual pressure fall-off testing to meet the requirements of 40 CFR 

146.90(f), as described below. Pressure fall-off tests will provide the following information: 

 Confirmation of hydrogeologic reservoir properties; 

 Long-term pressure buildup in the injection reservoir(s) due to CO2 injection over time; 

 Average reservoir pressure, which can be compared to modeled predictions of reservoir 

pressure to verify that the operation is responding as modeled/predicted and identify the 

need for recalibration of the AoR model in the event that the monitoring results do not 

match expectations; and 

 Formation damage (skin) near the well bore, which can be used to diagnose the need for 

well remediation/rehabilitation. 

In the pressure fall-off test, flow is maintained at a steady rate for a period of time, then injection 

is stopped, the well is shut-in, and bottom-hole pressure is monitored and recorded for a period 

of time sufficient to make a valid observation of the pressure fall-off curve. Downhole or surface 

pressure gauges will be used to record bottom-hole pressures during the injection period and the 

fall-off period. Pressure gauges that are used for the purpose of the fall-off test shall have been 

calibrated no more than one year prior to the date of the fall-off test with current calibration 

certificates provided with the test results to EPA. In lieu of removing the injection tubing, the 

calibration of downhole pressure gauges will demonstrate accuracy by using a second pressure 

gauge, with current certified calibration, that will be lowered into the well to the same depth as 

the permanent downhole gauge. Calibration curves, based on annual calibration checks (using 

the second calibrated pressure gauge) developed for the downhole gauge, can be used for the 

purpose of the fall-off test. If used, these calibration curves (showing all historic pressure 

deviations) will accompany the fall-off test data submitted to EPA. Pressures will be measured 

at a frequency that is sufficient to measure the changes in bottom-hole pressure throughout the 

test period, including rapidly changing pressures immediately following cessation of injection. 

The fall-off period will continue until radial flow conditions are observed, as indicated by 

stabilization of pressure and leveling off of the pressure derivative curve. The fall-off test may 

also be truncated if boundary effects are encountered, which would be indicated as a change in 

the slope of the derivative curve, or if radial flow conditions are not observed. In addition to the 

radial flow regime, other flow regimes may be observed from the fall-off test, including spherical 

flow, linear flow, and fracture flow. Analysis of pressure fall-off test data will be done using 

transient-pressure analysis techniques that are consistent with EPA guidance for conducting 

pressure fall-off tests (EPA 1998, 2002). 

See Section B.6 of the FutureGen QASP for details on pressure fall-off testing. 
Testing and Monitoring Plan for FutureGen Alliance Page C19 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Carbon Dioxide Plume and Pressure-Front Tracking 

FutureGen will conduct direct and indirect CO2 plume and pressure-front monitoring to meet the 

requirements of 40 CFR 146.90(g). 

The following describes FutureGen’s planned monitoring well network for plume and pressurefront monitoring (monitoring wells used for monitoring above the confining zone are described 

above in the Groundwater Quality Monitoring section).

The design to be used for plume and pressure-front monitoring in the injection zone is as follows: 

 Two SLR wells (one of which is a reconfiguration of the previously drilled stratigraphic 

well). These wells will be used to monitor within the injection zone beyond the east and west 

ends of the horizontal CO2-injection laterals. 

Monitored parameters: pressure, temperature, and hydrogeochemical indicators of CO2. To 

meet permit requirements for pressure front monitoring, at least one additional SLR well will 

be installed outside the lateral extent of the CO2 plume but within the lateral extent of the 

defined pressure front AoR. This well will be installed within 5 years of the start of 

injection.

 Three RAT wells. These are fully cased wells, which support PNC logging. The wells will 

not be perforated to preclude CO2 flooding of the borehole, which can distort the CO2

saturation measurements. 

Monitored parameters: quantification of CO2 saturation across the reservoir and caprock. 

Details about these wells are provided in Table 12 (the well locations are presented in Figure 1). 

The coordinates (in decimal degrees) of the wells are provided in Appendix A of this plan. Well 

construction information and well schematics are provided in Appendix B of this plan. 
Testing and Monitoring Plan for FutureGen Alliance Page C20 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 12. Monitoring Wells to Be Used for Plume and Pressure-Front Monitoring. 

Single-LevelIn-Reservoir (SLR) Reservoir Access Tube (RAT)

Number of Wells 2 3

Total Depth (ft) 4,150 4,465

Lat/Long (WGS84)

SLR1: 39°48'01.56"N, 90°05'16.84"W

SLR2: 39°48'24.51"N, 90°03'10.73"W

RAT1: 39°48'01.28"N, 90°05'10.59"W

RAT2: 39°47'13.09"N, 90°04'08.50"W

RAT3: 39°47'32.25"N, 90°05'20.46"W

Monitored Zone Mount Simon Sandstone Mount Simon Sandstone

Monitoring

Instrumentation

Fiber-optic P/T (tubing conveyed)*

P/T/SpC probe in monitored interval** Pulsed-neutron capture logging equipment

* Fiber-optic cable attached to the outside of the tubing string, in the annular space between the tubing and casing. 

** The P/T/SpC (pressure, temperature, specific conductance) probe is an electronic downhole multi-parameter

probe incorporating sensors for measuring fluid P/T/SpC within the monitored interval. The probe is

installed inside the tubing string, which is perforated (slotted) over the monitoring interval. Sensor signals 

are multiplexed to a surface data logger through a single conductor wireline cable. 

Direct Pressure Monitoring 

FutureGen will conduct direct pressure-front monitoring to meet the requirements of 40 CFR 

146.90(g)(1). 

Continuous monitoring of injection zone P/T will be performed with sensors installed in wells 

that are completed in the injection zone. P/T monitoring in the injection well and all monitoring 

wells will be performed using a real-time monitoring system with surface readout capabilities so 

that pressure gauges do not have to be removed from the well to retrieve data. 

The following measures will be taken to ensure that the pressure gauges are providing accurate 

information on an ongoing basis: 

 High-quality (high-accuracy, high-resolution) gauges with low drift characteristics will 

be used.

 Gauge components (gauge, cable head, cable) will be manufactured of materials designed

to provide a long life expectancy for the anticipated downhole conditions. 

 Upon acquisition, a calibration certificate will be obtained for every pressure gauge. The 

calibration certificate will provide the manufacturer’s specifications for range, accuracy 

(% full scale), resolution (% full scale), drift (< psi per year), and calibration results for 

each parameter. The calibration certificate will also provide the date that the gauge was 

calibrated and the methods and standards used.

 P/T gauges will be installed in the injection wells above any packers so they can be 

removed if necessary by removing the tubing string without pulling the packer. P/T 

gauges will be installed either above or below the packer in the SLR monitoring wells 

that will have tubing and packer. Redundant gauges may be run on the same cable to 

provide confirmation of downhole P/T. 

 Upon installation, all gauges will be tested to verify they are functioning 

(reading/transmitting) correctly. 
Testing and Monitoring Plan for FutureGen Alliance Page C21 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

 Pressure gauges that are used for the purpose of direct pressure monitoring will be 

calibrated on an annual basis with current annual calibration certificates kept on file with 

the monitoring data. In lieu of removing the injection tubing, the calibration of downhole 

pressure gauges will demonstrate accuracy by using a pressure gauge, with current 

certified calibration, that will be lowered into the well to the same depth as the permanent 

downhole gauge. Calibration curves, based on all annual calibration checks (using the 

second calibrated gauge method described above) developed for the downhole gauge, 

may be used for the purpose of direct pressure monitoring. If used, these calibration 

curves, showing all historic pressure deviations, will be kept on file with the monitoring 

data.

 Gauges will be pulled and recalibrated whenever a workover occurs that involves 

removal of tubing. A new calibration certificate will be obtained whenever a gauge is

recalibrated.

Injection P/T will also be continuously measured at the surface via real-time P/T instruments 

installed in the CO2 pipeline near the pipeline interface with the wellhead. The surface 

instruments will be checked, and if necessary, recalibrated or replaced on a regular basis (e.g., 

semi-annually) to ensure they are providing accurate data. 

Direct pressure monitoring in the injection zone will take place as indicated in Table 13. 

Continuous monitoring is described in Table 1 of this plan. 

Table 13. Monitoring Schedule for Direct Pressure-Front Tracking. 

Well Location/Map

Reference Depth(s)/Formation(s) Frequency (Baseline)

Frequency (Injection

Phase)

Injection Well 1 Mount Simon/4,030 ft. Continuous Continuous

Injection Well 2 Mount Simon/4,030 ft. Continuous Continuous

Injection Well 3 Mount Simon/4,030 ft. Continuous Continuous

Injection Well 4 Mount Simon/4,030 ft. Continuous Continuous

Two single-level monitoring

wells (SLR Wells 1 and 2)

Mount Simon/4,150 ft. Continuous Continuous

Note: For details and information on continuous monitoring, see Table 1.

See Section B.7 of the FutureGen QASP for further discussion of pressure monitoring. 

Plan for guaranteeing access to all monitoring locations: 

The land on which these wells are located will either be purchased or leased for the life of the 

project, so access will be secured. 

Direct Geochemical Plume Monitoring 

FutureGen will conduct direct CO2 plume monitoring to meet the requirements of 40 CFR 

146.90(g)(1). 
Testing and Monitoring Plan for FutureGen Alliance Page C22 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Fluid samples will be collected from monitoring wells completed in the injection zone before, 

during, and after CO2

injection. The samples will be analyzed for chemical parameter changes that 

are indicators of the presence of CO2 and/or reactions caused by the presence of CO2

. Direct fluid 

sampling in the injection zone will take place as indicated in Table 14. Continuous monitoring is 

described in Table 1 of this plan. 

Table 14. Monitoring Schedule for Direct Geochemical Plume Monitoring. 

Monitoring well name/location/map reference: Two SLR monitoring wells (see Figure 1)

Well depth/formation(s) sampled: Mount Simon Sandstone (4,150 ft)

Parameter/Analyte Frequency (Baseline) Frequency (Injection Phase)

Dissolved or separate-phase CO2 At least 3 sampling events Quarterly for 3 years, then semi-annually

for 2 years and annually thereafter

Pressure Continuous, 1 year 

minimum

Continuous

Temperature Continuous, 1 year 

minimum

Continuous

Other parameters, including major cations

and anions, selected metals, general waterquality parameters (pH, alkalinity, total

dissolved solids, specific gravity), and any

tracers added to the CO2 stream

At least 3 sampling events

Quarterly for 3 years, then semi-annually

for 2 years and annually thereafter

Note: For details and information on continuous monitoring, see Table 1.

Sampling methods: 

Periodically, fluid samples will be collected from the monitoring wells completed in the injection 

zone. Fluid samples will be collected using an appropriate method to preserve the fluid sample at

injection zone temperature and pressure conditions. Examples of appropriate methods include 

using a bomb-type sampler (e.g., Kuster sampler) after pumped or swabbed purging of the 

sampling interval, using a Westbay sampler, or using a pressurized U-tube sampler (Freifeld et

al. 2005). 

Fluid samples will be analyzed for parameters that are indicators of CO2 dissolution (Table 15),

including major cations and anions, selected metals, and general water-quality parameters (pH,

alkalinity, total dissolved solids [TDS], specific gravity). Changes in major ion and trace element 

geochemistry are expected in the injection zone. Analysis of carbon and oxygen isotopes in

injection zone fluids and the injection stream (

13/12C, 18/16O) provides another potential 

supplemental measure of CO2 migration. Where stable isotopes are included as an analyte, data 

quality and detectability will be reviewed throughout the active injection phase and discontinued 

if these analyses provide limited benefit. Sampling and analytical requirements for target 

parameters are given in Tables 15 and 16 respectively. 

The relative benefit of each analytical measurement will be evaluated throughout the design and 

initial injection testing phase of the project to identify the analytes best suited to meeting project 

monitoring objectives under site-specific conditions. If some analytical measurements are shown 

to be of limited use, they will be removed from the analyte list and not carried forward through 
Testing and Monitoring Plan for FutureGen Alliance Page C23 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

the operational phases of the project. This selection process will consider the uniqueness and 

signature strength of each potential analyte and whether their characteristics provide for a highvalue leak-detection capability. Any modification to the parameter list in Table 8 will be made in 

consultation with the UIC Program Director. Modifications to the parameter list will also require 

modifications to the permits through the process described in 40 C.F.R. Part 144. 
Testing and Monitoring Plan for FutureGen Alliance Page C24 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 15. Aqueous Sampling Requirements for Target Injection Zone Parameters. 

Parameter Volume/Container Preservation

Holding

Time

Major Cations: Al, Ba, Ca, Fe, K, Mg,

Mn, Na, Si,

20-mL plastic vial Filtered (0.45 μm), HNO3 to pH

<2

60 days

Trace Metals: Sb, As, Cd, Cr, Cu, Pb, Se,

Tl

20-mL plastic vial Filtered (0.45 μm), HNO3 to pH

<2

60 days

Cyanide (CN-) 250-mL plastic vial NaOH to pH > 12, 0.6 g ascorbic 

acid Cool 4°C, 

14 days

Mercury 250-mL plastic vial Filtered (0.45 μm), HNO3 to pH

<2

28 days

Anions: Cl-, Br-, F

-

, SO4

2-

, NO3

- 125-mL plastic vial Filtered (0.45 μm), Cool 4°C 45 days

Total and Bicarbonate Alkalinity (as 

CaCO3

2-

)

100-mL HDPE Filtered (0.45 μm), Cool 4°C 14 days

Gravimetric Total Dissolved Solids (TDS) 250-mL plastic vial Filtered (0.45 μm), no

preservation, Cool 4°C

7 days

Water Density 100 mL plastic vial No preservation, Cool 4°C

Total Inorganic Carbon (TIC) 250-mL plastic vial H2SO4 to pH <2, Cool 4°C 28 days

Dissolved Inorganic Carbon (DIC) 250-mL plastic vial Filtered (0.45 μm), H2SO4 to pH 

<2, Cool 4°C

28 days

Total Organic Carbon (TOC) 250-mL amber glass Unfiltered, H2SO4 to pH <2, Cool

4°C

28 days

Dissolved Organic Carbon (DOC) 125-mL plastic vial Filtered (0.45 μm), H2SO4 to pH 

<2, Cool 4°C

28 days

Volatile Organic Analysis (VOA) Bottle set 1: 3-40-mL 

sterile clear glass vials

Bottle set 2: 3-40-mL 

sterile amber glass vials 

Zero headspace, Cool <6 °C, 

Clear glass vials will be UVirradiated for additional 

sterilization

7 days

Methane Bottle set 1: 3-40-mL 

sterile clear glass vials

Bottle set 2: 3-40 mL 

sterile amber glass vials

Zero headspace, Cool <6 °C, 

Clear glass vials (bottle set 1) will 

be UV-irradiated for additional 

sterilization

7 days

Stable Carbon Isotopes 13/12C (δ

13C) of 

DIC in Water

60-mL plastic or glass Filtered (0.45 μm), Cool 4°C 14 days

Radiocarbon 14C of DIC in Water 60-mL plastic or glass Filtered (0.45μm), Cool 4°C 14 days

Hydrogen and Oxygen Isotopes 2/1H (δD) 

and 18/16O (δ

18O) of Water

60-mL plastic or glass Filtered (0.45μm), Cool 4°C 45 days

Carbon and Hydrogen Isotopes (14C, 

13/12C, 2/1H) of Dissolved Methane in 

Water

1-L dissolved gas bottle 

or flask

Benzalkonium chloride capsule, 

Cool 4°C

90 days

Compositional Analysis of Dissolved Gas 

in Water (including N2, CO2, O2, Ar, H2, 

He, CH4, C2H6, C3H8, iC4H10, nC4H10, 

iC5H12, nC5H12, and C6+)

1-L dissolved gas bottle 

or flask

Benzalkonium chloride capsule, 

Cool 4°C

90 days

Radon (

222Rn) 1.25-L PETE Pre-concentrate into 20-mL

scintillation cocktail. Maintain

groundwater temperature prior to

pre-concentration

1 day

pH Field parameter None <1 h
Testing and Monitoring Plan for FutureGen Alliance Page C25 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Parameter Volume/Container Preservation

Holding

Time

SpecificConductance Field parameter None <1 h

HDPE = high-density polyethylene; PETE = polyethylene terephthalate.
Testing and Monitoring Plan for FutureGen Alliance Page C26 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 16. Analytical Requirements. 

Parameter Analysis Method

Detection Limit 

or Range

Typical 

Precision/ 

Accuracy QC Requirements

A.1.117 Major Cations: Al, Ba,

Ca, Fe, K, Mg,

A.1.118 Mn, Na, Si,

A.1.119 ICP-AES, EPA Method 6010B or 

similar

A.1.120 1 to 80 μg/L

(analyte

dependent)

A.1.121 ±10%A.1.122 Daily calibration; blanks, LCS, 

and duplicates and matrix 

spikes at 10% level per batch 

of 20

A.1.123 Trace Metals: Sb, As,

Cd, Cr, Cu, Pb, Se, Tl

A.1.124 ICP-MS, EPA Method 6020 or 

similar

A.1.125 0.1 to 2 μg/L 

(analyte 

dependent)

A.1.126 ±10%A.1.127 Daily calibration; blanks, LCS, 

and duplicates and matrix 

spikes at 10% level per batch 

of 20

A.1.128 Cyanide (CN-)A.1.129 SW846 9012A/B A.1.130 5 μg/L A.1.131 ±10%A.1.132 Daily calibration; blanks, LCS, 

and duplicates at 10% level per 

batch of 20

A.1.133 Mercury A.1.134 CVAA SW846 7470A A.1.135 0.2 A.1.136 μg/L ±20%A.1.137 Daily calibration; blanks, LCS, 

and duplicates and matrix 

spikes at 10% level per batch 

of 20

A.1.138 Anions: Cl-, Br-, F

-

,

SO4

2-

, NO3

-

A.1.139 Ion Chromatography, EPA Method 

300.0A or similar

A.1.140 33 to 133 

μg/L (analyte 

dependent)

A.1.141 ±10%A.1.142 Daily calibration; blanks, LCS, 

and duplicates at 10% level per 

batch of 20

A.1.143 Total and Bicarbonate 

Alkalinity (as CaCO3

2-

)

A.1.144 Titration, Standard Methods 2320B A.1.145 1 mg/L ±10%A.1.146 Daily calibration; blanks, LCS, 

and duplicates at 10% level per 

batch of 20

A.1.147 Gravimetric Total

Dissolved Solids (TDS

A.1.148 Gravimetric Method Standard 

Methods 2540C

A.1.149 10 mg/L A.1.150 ±10%A.1.151 Balance calibration, duplicate 

samples

A.1.152 Water DensityA.1.153 ASTM D5057 0.01 g/mL A.1.154 ±10%A.1.155 Balance calibration, duplicate 

samples

A.1.156 Total Inorganic Carbon

(TIC)

A.1.157 SW846 9060A or equivalent

A.1.158 Carbon analyzer, phosphoric acid 

digestion of TIC

A.1.159 0.2 mg/L A.1.160 ±20%A.1.161 Quadruplicate analyses, daily 

calibration

A.1.162 Dissolved Inorganic

Carbon (DIC)

A.1.163 SW846 9060A or equivalent

A.1.164 Carbon analyzer, phosphoric acid 

digestion of DIC

A.1.165 0.2 mg/L A.1.166 ±20%A.1.167 Quadruplicate analyses, daily 

calibration

A.1.168 Total Organic Carbon

(TOC)

A.1.169 SW846 9060A or equivalent

Total organic carbon is converted to 

carbon dioxide by chemical 

oxidation of the organic carbon in the 

sample. The carbon dioxide is 

measured using a non-dispersive 

infrared detector.

A.1.170 0.2 mg/L A.1.171 ±20%A.1.172 Quadruplicate analyses, daily 

calibration

A.1.173 Dissolved Organic

Carbon (DOC)

A.1.174 SW846 9060A or equivalent

A.1.175 Total organic carbon is converted to 

carbon dioxide by chemical 

oxidation of the organic carbon in the 

sample. The carbon dioxide is 

measured using a non-dispersive 

infrared detector.

A.1.176 0.2 mg/L A.1.177 ±20%A.1.178 Quadruplicate analyses, daily 

calibration

A.1.179 Volatile Organic 

Analysis (VOA)

A.1.180 SW846 8260B or equivalent

A.1.181 Purge and Trap GC/MS

A.1.182 0.3 to 15 A.1.183 μg/L ±20%A.1.184 Blanks, LCS, spike, spike 

duplicates per batch of 20

A.1.185 Methane A.1.186 RSK 175 Mod

A.1.187 Headspace GC/FID

A.1.188 10 μg/L A.1.189 ±20%A.1.190 Blanks, LCS, spike, spike 

duplicates per batch of 20

A.1.191 Stable Carbon Isotopes 

13/12C (113C) of DIC in 

Water

A.1.192 Gas Bench for 13/12C A.1.193 50 ppm of 

DIC

A.1.194 ±0.2p A.1.195 Duplicates and working 

standards at 10%
Testing and Monitoring Plan for FutureGen Alliance Page C27 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Parameter Analysis Method

Detection Limit 

or Range

Typical 

Precision/ 

Accuracy QC Requirements

A.1.196 Radiocarbon 14C of DIC 

in Water

AMS for 14C A.1.197 Range: 0 i 

200 pMC

A.1.198 ±0.5 pMC A.1.199 Duplicates and working 

standards at 10%

A.1.200 Hydrogen and Oxygen 

Isotopes 2/1H (δ ) and 

18/16O (118O) of Water

A.1.201 CRDS H2O Laser A.1.202 Range: -

500‰ to 

200‰ vs. 

VSMOW

A.1.203 2/1H: ±2.0‰

A.1.204 18/16O: 

±0.3‰

A.1.205 Duplicates and working 

standards at 10%

A.1.206 Carbon and Hydrogen 

Isotopes (14C, 13/12C, 

2/1H) of Dissolved 

Methane in Water

A.1.207 Offline Prep & Dual Inlet IRMS for 

13C; AMS for 14C

A.1.208 14C Range: 0 

& DupMC

A.1.209 14C: 

±0.5pMC

A.1.210 13C: ±0.2‰

A.1.211 2/1H: ±4.0‰

A.1.212 Duplicates and working 

standards at 10%

A.1.213 Compositional Analysis 

of Dissolved Gas in 

Water (including N2, 

CO2, O2, Ar, H2, He, 

CH4, C2H6, C3H8, 

iC4H10, nC4H10, iC5H12, 

nC5H12, and C6+)

A.1.214 Modified ASTM 1945D A.1.215 1 to 100 ppm 

(analyte 

dependent)

A.1.216 Varies by 

compon-ent

Duplicates and working 

standards at 10%

A.1.217 Radon (

222Rn)A.1.218 Liquid scintillation after preconcentration

A.1.219 5 mBq/L A.1.220 ±10%A.1.221 Triplicate analyses

A.1.222 pH A.1.223 pH electrode A.1.224 2 to 12 pH 

units

A.1.225 0.2 pH unit 

For 

indication 

only

A.1.226 User calibrate, follow 

manufacturer 

recommendations

A.1.227 SpecificConductance A.1.228 Electrode A.1.229 0 to 100 

mS/cm

A.1.230 1% of 

reading

For 

indication 

only

A.1.231 User calibrate, follow 

manufacturer 

recommendations

A.1.232 ICP-AES = inductively coupled plasma atomic emission spectrometry; ICP-MS = inductively coupled plasma mass 

spectrometry; LCS = laboratory control sample; GC/MS = gas chromatography–mass spectrometry; GC/FID = gas 

chromatography with flame ionization detector; AMS = accelerator mass spectrometry; CRDS = cavity ring down 

spectrometry; IRMS = isotope ratio mass spectrometry; LC-MS = liquid chromatography-mass spectrometry; ECD = electron 

capture detector

Laboratory to be used/chain-of-custody procedures: 

See Section B.4 of the FutureGen QASP for groundwater and brine sampling, analysis, chain-ofcustody procedures. Additionally, see Section B.7 of the FutureGen QASP for protocols for 

plume and pressure-front tracking. 

Plan for guaranteeing access to all monitoring locations: 

The land on which these wells are located will either be purchased or leased for the life of the 

project, so access will be secured. 
Testing and Monitoring Plan for FutureGen Alliance Page C28 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Indirect Carbon Dioxide Plume and Pressure-Front Tracking 

FutureGen will conduct indirect plume and pressure-front monitoring to meet the requirements of 

40 CFR 146.90(g)(2). 

The screening of the indirect monitoring approaches was conducted as part of the Front End 

Engineering Design process. The selected indirect technologies will include the following: 

 PNC logging for determination of reservoir CO2 saturation; 

 Integrated deformation monitoring; 

 Time-lapse gravity; and 

 Microseismic monitoring. 

The monitoring schedule for these techniques is provided in Table 17. Continuous monitoring is 

described in Table 1 of this plan. The sections below describe these indirect methods. 

Table 17. Monitoring Schedule for Indirect Plume and Pressure-Front Monitoring. 

MonitoringTechnique Location

Frequency

(Baseline)

Frequency (Injection

Phase)

Pulsed-neutron capture logging RAT Wells 1, 2, and 3 3 events Quarterly for 5 years

and annually thereafter

Integrated deformation

monitoring

5 locations (see Figure 1) 1 year minimum Continuous

Time-lapse gravity monitoring 46 locations (see Figure 3) 3 events Annually

Passive seismic monitoring

(microseismicity)

Surface measurements (see

Figure 1) plus downhole sensor

arrays at ACZ Wells 1 and 2

1 year minimum Continuous

(1 scene per month)

Note: For details and information on continuous monitoring, see Table 1.

Pulsed-neutron capture logging

Once the reservoir model has been refined based on site-specific information from the injection 

site, predictive simulations of CO2 arrival response will be generated for each RAT installation. 

These predicted responses will be compared with monitoring results throughout the operational 

phase of the project and significant deviation in observed response would result in further action, 

including a detailed evaluation of the observed response, calibration/refinement of the numerical 

model, and possible modification to the monitoring approach and/or storage site operations. 

The coordinates (in decimal degrees) of the RAT wells are in Appendix A of this plan. Well 

construction information and well schematics are in Appendix B of this plan.

Integrated deformation monitoring

Integrated deformation monitoring (see Figure 1 for locations) integrates ground data from 

permanent Global Positioning System (GPS) stations, tiltmeters, supplemented with annual 

Differential GPS (DGPS) surveys, and larger-scale Differential Interferometric Synthetic 
Testing and Monitoring Plan for FutureGen Alliance Page C29 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Aperture Radar (DInSAR) surveys to detect and map temporal ground-surface deformation. 

These data reflect the dynamic geomechanical behavior of the subsurface in response to CO2

injection. These measurements will provide useful information about the evolution and 

symmetry of the pressure front. These results will be compared with model predictions 

throughout the operational phase of the project and significant deviation in observed response 

would result in further action, including a detailed evaluation of the observed response, 

calibration/refinement of the numerical model, and possible modification to the monitoring 

approach and/or storage site operations. 

Orbital SAR data will be systematically acquired and processed over the storage site with at least 

1 scene per month to obtain advanced InSAR time series. These data will come from X-band 

TerraSAR-X, C-band Radarsat-2, X-Band Cosmo-Skymed or any other satellite instrument that 

will be available at the time of data collection. 

Widespread overall temporal decorrelation is anticipated except in developed areas (e.g., roads, 

infrastructure at the site, and the neighboring towns) and for the six corner cubes reflectors that 

will be deployed on site. These isolated coherent pixels will be exploited to measure deformation 

over time and different algorithms (e.g., persistent scatters, small baseline subsets, etc.) will be 

used to determine the best approach for the site. 

Data from 5 permanent tiltmeters and GPS stations will be collected continuously (MS1-MS5 

locations in Figure 1). In addition, annual geodetic surveys will be conducted using the RealTime Kinematic (RTK) technique where a single reference station gives the real-time 

corrections, providing centimeter-level or better accuracy. Deformations will be measured at 

permanent locations chosen to measure the extent of the predicted deformation in the AoR and 

also used by the gravity surveys (see time-lapse gravity monitoring). 

To establish a comprehensive geophysical and geomechanical understanding of the FutureGen 

site, InSAR and field deformation measurements will be integrated and processed with other 

monitoring data collected at the site: microseismicity, gravity, pressure and temperature. This 

unique and complete geophysical data set will then be inverted to constrain the CO2 plume 

shape, extension and migration in the subsurface. 

Time-lapse gravity monitoring

The objective of gravity monitoring is to observe changes in density distribution in the 

subsurface caused by the migration of fluids, which could potentially help define the areal extent 

of the CO2 plume or detect leakage. 

FutureGen will use a network of forty six permanent stations that were established in 2011 

during a gravity survey for the purpose of future reoccupation surveys. Approximately 35 

complementary stations will be established for a total of 81 stations. A map of the gravity 

stations is provided in

Figure 3. The coordinates (in decimal degrees) of the stations are provided in Appendix D. 
Testing and Monitoring Plan for FutureGen Alliance Page C30 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Figure 3. Permanent Gravity Station Locations (with supplemental DGPS). 

Passive seismic monitoring (microseismicity)

The microseismic monitoring network (see Figure 1; downhole arrays will also be installed at the 

two ACZ wells) will be used to accurately determine the locations, magnitudes, and focal 

mechanisms of injection-induced seismic events with the primary goals of 1) addressing public 

and stakeholder concerns related to induced seismicity, 2) estimating the spatial extent of the 

pressure front from the distribution of seismic events, and 3) identifying features that may 

indicate areas of caprock failure and possible containment loss. Seismic monitoring 

considerations are also addressed in the Emergency and Remedial Response Plan (Attachment F 

of this permit). 

Testing & Monitoring Techniques and Procedures 

The techniques and procedures in the Testing & Monitoring Plan may be revised to incorporate 

best practices that develop over time. Such revisions will be governed under Section B of this 

permit “PERMIT ACTIONS.”
Testing and Monitoring Plan for FutureGen Alliance Page C31 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

APPENDIX A: Deep Monitoring Wells Coordinates 

Well ID Well Type Latitude

(WGS84)

Longitude

(WGS84)

ACZ1 Above Confining Zone 1 39.80034315 -90.07829648

ACZ2 Above Confining Zone 2 39.80029543 -90.08801028

USDW1 Underground Source of Drinking Water 39.80048042 -90.0782963

SLR1 Single-Level in-Reservoir 1 39.8004327 -90.08801013

SLR2 Single-Level in-Reservoir 2 39.80680878 -90.05298062

RAT1 Reservoir Access Tube 1 39.80035565 -90.08627478

RAT2 Reservoir Access Tube 2 39.78696855 -90.06902677

RAT3 Reservoir Access Tube 3 39.79229199 -90.08901656
Testing and Monitoring Plan for FutureGen Alliance Page C32 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

APPENDIX B: Monitoring Well Construction and Schematics 

 ACZ Well Construction and Drilling Information

 USDW Well Construction and Drilling Information

 SLR1 Well Construction and Drilling Information

 SLR2 Well Construction and Drilling Information

 RAT Well Construction and Drilling Information
Testing and Monitoring Plan for FutureGen Alliance Page C33 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

ACZ Well Construction and Drilling Information 

Construction detail for the Above Confining Zone (ACZ) wells is provided in Figure B-1. One 

of the ACZ wells will be located approximately 1,000 ft west of the injection well site, within the 

region of highest pressure buildup. The other ACZ well will be located approximately 0.75 mi 

west of the injection site on the same drill pad as single-level in-reservoir well 1 (SLR1). These 

selected ACZ locations focus early-detection monitoring within the region of elevated pressure 

and are proximal to six of nine project-related caprock penetrations (four injection wells, two 

reservoir wells, and three reservoir access tubes [RATs]). The ACZ wells will be used to collect 

fluid samples and for continuous pressure, temperature, specific conductance (P/T/SpC) and 

microseismic monitoring. A fiber-optic cable with integral geophones for microseismic 

monitoring will be secured to the outside of the casing and cemented in place. This design will 

permit unobstructed access to the inside of the casing and screen for planned sampling and 

monitoring activities. 

To begin, a 30-in. borehole will be drilled and 24-in.-OD conductor casing will be installed to 

near the contact with Pennsylvanian bedrock (150 ft) (Figure B-1). Next, the boring will step 

down to a 20-in. borehole and 16-in. casing to approximately 600 ft. Below 600 ft, the hole will 

step down to a 14-3/4-in. hole lined with 10-3/4-in. casing to below the base of the Potosi 

Dolomite. Casing to the base of the Potosi Dolomite (~3,100 ft) is needed to case off the karstic 

lost-circulation zone encountered while drilling the stratigraphic well. After cementing the 10-

3/4-in. casing in place a 9-1/2-in. borehole will be drilled into the top of the underlying confining 

zone. The base of the Ironton Sandstone in the stratigraphic well was 3,425 ft bgs. The bottom 

of the ACZ wells should be drilled a bit further (to ~3,470-ft depth) into the top of the Eau Claire 

Formation to positively identify the Ironton/Eau Claire contact and to create sufficient borehole 

to accommodate a 50-ft-long section of blank 5-1/2-in. casing below the well screen. If the 

ongoing modeling effort focused on evaluating early-detection capabilities in the ACZ wells 

indicates that detection is improved by moving the screen to near the top of the Ironton 

Formation, then the borehole will be plugged back prior to well completion. 

After the 9-1/2-in. borehole has been drilled to total depth, the borehole will be developed to 

remove mud cake, cuttings, and drill fluids via circulation. Development will continue until all 

drilling mud has been effectively removed from the borehole wall. After the borehole has been 

circulated clean, a final casing string will be installed. The final casing string will be 5-1/2-in. 

OD and will include a ~20-ft-long stainless-steel well screen installed across the selected 

monitoring interval. A 50-ft-long section of blank casing will be attached below the screen to 

provide a sump for collecting any debris that may enter the well over time. A swellable packer 

may be placed immediately above and below the screened interval to help ensure zonal isolation 

(see Figure B-2). The annulus casing packer (ACP) and a stage-cement tool will be placed 

above the well screen to isolate and keep cement away from the screen. In addition to the 

stainless-steel well screen, the lowermost 200 ft of the 5-1/2-in. casing string (including the 

section that spans the Ironton Sandstone [3,286−3,425 ft bgs]) will be a corrosion-resistant alloy 

material (e.g., S13Cr110). The remainder of the 5-1/2-in. casing string will be carbon steel. 

Corrosion-resistant cement will be used to cement the final casing string up to ~3,100-ft depth. 

Regular cement will be used to seal the remainder of the 5-1/2-in. casing to ground surface. All 

other casing strings will be cemented with standard well cement. A summary of the borehole 

and casing program for the ACZ wells is in figure B.1. 
Testing and Monitoring Plan for FutureGen Alliance Page C34 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Table B.1. Casing and Borehole Program for the ACZ Monitoring Wells. 

Section

Borehole 

Depth (ft)

Borehole 

Diam. 

(in.)

Casing 

OD (in.) Casing Grade

Casing 

weight 

(lb/ft)

Casing 

Connection

Conductor Casing 150 30 (min.) 24 B 140 PEB

Surface Casing 600 20 16 K-55 84 BTC

Intermediate Casing 3,100 14-3/4 10-3/4 K-55 51 BTC

Long Casing (with a 20-

ft-long screened 

section)

3,470 9-1/2 5-1/2 J-55 (0-3,100 ft); 

S13Cr110 

(3,100−3,470 ft)

17 LTC (J-55); Vam

Top or similar 

(S13Cr110)

Grade B is equivalent to line pipe; BTC = buttress thread connection; Cr = chromium; LTC = long thread 

connection; PEB = plain end beveled.

Notes: 

Actual casing grades and weights may differ based on material available at the time of construction. 

All depths are approximate and may be adjusted based on information obtained when the well is drilled.
Testing and Monitoring Plan for FutureGen Alliance Page C35 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Figure B-1. Well Construction Diagram for the ACZ Monitoring Wells. 
Testing and Monitoring Plan for FutureGen Alliance Page C36 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Figure B-2. Construction Detail for ACZ Monitoring Wells. 
Testing and Monitoring Plan for FutureGen Alliance Page C37 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

USDW Well Construction and Drilling Information 

A single monitoring well (USDW1) will be installed in the Ordovician St. Peter Sandstone, the 

lowermost underground sources of drinking water (USDW) above the FutureGen injection 

reservoir. The St. Peter Sandstone is considered the lowermost USDW, because the measured 

total dissolved solids (TDS) content from this unit at the FutureGen stratigraphic well was 3,700 

mg/L, which is below the regulatory limit of 10,000 mg/L for designation as a potential USDW. 

A single regulatory compliance well will be installed within this lowermost USDW aquifer, on 

the same drill pad with the ACZ1 early-detection monitoring well, which is within the region of 

highest pressure buildup. 

The USDW1 well will be a 5-1/2-in.-OD well with a 20-ft-long, stainless-steel screen section 

placed across the monitoring interval (estimated at 1,930 to 1,950 ft). An evaluation of 

monitoring requirements for this well indicates that a 5-1/2-in.-OD casing string will be 

sufficient to meet project objectives (i.e., allow access for fluid sampling and installation of 

downhole P/T/SpC probes. The current plan calls for free hanging the P/T/SpC probes by 

wireline within the 5-1/2-in. casing; however, the design may be revised to include tubing and 

packer to secure the probe. A well schematic is shown in Figure B-3. 

To begin, a 20-in. borehole will be drilled and 16-in. conductor casing will be installed to near 

the contact with Pennsylvanian bedrock (Figure B-3). Next, the boring will step down to a 14-

3/4-in. borehole and 10-3/4-in. casing to approximately 600 ft. After cementing the 10-3/4-in. 

casing in place, a 9-1/2-in. borehole will be drilled to a short distance below the base of the 

USDW (St. Peter Sandstone) (to ~2,000-ft depth) to positively identify the St. Peter 

Sandstone/Shakopee Dolomite contact. After the 9-1/2-in. borehole has been drilled to total 

depth, the borehole will be developed to remove mud cake, cuttings, and drill fluids via 

circulation. Development will continue until all drilling mud has been effectively removed from 

the borehole wall. After the borehole has been circulated clean, a final casing string will be 

installed. The final casing string will be 5-1/2-in. OD and will include a ~20-ft-long stainlesssteel well screen near the bottom (see screened interval construction detail for USDW1 in Figure 

B-4). 

Stainless-steel casing (e.g., 13Cr), 5-1/2-in. OD, will be used in the lower 300 ft of the well 

including the entire St. Peter Sandstone. Standard carbon-steel casing will be used above depths 

of ~1,700 ft. A 20-ft-long, 5-1/2-in.-OD stainless-steel well screen will be incorporated into the 

final casing string and positioned to span the desired monitoring interval. Approximately 50 ft of 

blank casing will extend from immediately below the screen to the bottom of the well (Figure B3). External swellable packers may be placed above and below the screened interval to help 

ensure zonal isolation (see Figure B-4). A removable bridge plug may be installed just below the 

screen to isolate it from the rat hole below. Standard well cement will be used to cement all 

casing strings. 

A summary of the borehole and casing program for the USDW1 well is provided in Table B-2. 
Testing and Monitoring Plan for FutureGen Alliance Page C38 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Figure B-3. Well Construction Diagram for the USDW1 Monitoring Well. 
Testing and Monitoring Plan for FutureGen Alliance Page C39 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Figure B-4. Construction Detail for USDW1. 
Testing and Monitoring Plan for FutureGen Alliance Page C40 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Table B-2. Casing and Borehole Program for the USDW Monitoring Well. 

Section

Borehole 

Depth 

(ft)

Borehole 

Diam. 

(in.)

Casing 

OD 

(in.) Casing Grade

Casing 

weight 

(lb/ft)

Casing 

Connection

Conductor Casing 150 20 16 B 55 PEB

Surface Casing 600 14-3/4 10-3/4 J-55 40.5 BTC

Intermediate Casing NA NA NA NA NA NA

Long Casing (with 20-

ft-long screened section)

2,000 9-1/2 5-1/2 J-55 (0-1,700 ft); 

S13Cr110 

(1,700−2,000 ft)

17 LTC (J-55); Vam 

Top or similar 

(S13Cr110)

Grade B is equivalent to line pipe; BTC = buttress thread connection; Cr = chromium; LTC = long thread 

connection; PEB = plain end beveled.

Notes: 

Actual casing grades and weights may differ based on material available at the time of construction. 

All depths are approximate and may be adjusted based on information obtained when the well is drilled.

As discussed above, the well will be developed by air lift prior to installing the downhole 

P/T/SpC probe. If necessary, further development via air lift or pumping may be conducted after 

the well has been completed. During development activities, groundwater samples will be 

collected and tested for turbidity and other field parameters to ensure adequate development. 
Testing and Monitoring Plan for FutureGen Alliance Page C41 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

SLR1 Well Construction and Drilling Information 

As illustrated in Figure B-5, a 20-in.-diameter conductor casing within a 26- to 30-in. hole will 

be installed into the Pennsylvanian bedrock to 150 ft bgs. This will be followed by a 17-1/2-in. 

hole lined with 13-3/8-in. casing to ~600 ft before drilling a 12-1/4-in. hole lined with 9-5/8-in. 

intermediate casing into the top of the confining zone (Proviso member) to a depth of 

approximately 3,450 ft bgs. Next, cement grout will be emplaced, under pressure, in the annular 

space behind the 9-5/8-in. casing and around the casing shoe until it rises to the surface. This 

will be followed by a downhole cement bond log and pressure testing to ensure there are no 

leakage pathways behind the 9-5/8-in. casing or shoe. After testing the seal integrity of the 9-

5/8-in. casing, an uncased 7-7/8-in. to 8-1/2-in. open borehole will be drilled to ~4,150 ft bgs. 

Once at total depth, the open portion of the borehole will be developed to remove all cuttings and 

drill fluids via circulation and pumping of formation water. Development will continue until all 

drilling mud has been effectively removed from the borehole wall and pumped water is clear of 

particulates. Following development, a final 5-1/2-in.-OD casing string will be installed and 

cemented in place. Once the casing installation is complete, the 5-1/2-in. casing and surrounding 

cement will be perforated over the interval between 4,000 and 4,100 ft bgs, creating a 100-ft 

monitoring interval within the injection zone. 

The portion of the 5-1/2-in. casing that penetrates the reservoir and the Eau Claire caprock (from 

total depth to ~3,450 ft bgs) will be composed of corrosion-resistant alloy material (e.g., 

S13Cr110) (Figure B-6). Corrosion-resistant cement will be used to cement the final casing 

string across this same interval. This specially formulated type of cement is more finely ground 

than regular cement and thus resists CO2 infiltration into the more-reactive cement pores. Above 

the caprock and overlying the CO2 reservoir, regular cement will be used to seal the remainder of 

the 5-1/2-in. casing (i.e., above 3,450 ft). All other casing strings will be cemented with standard 

well cement. A summary of the borehole and casing program for the SLR1 well is provided in 

Table B-3. 

Table B-3. Casing and Borehole Program for the SLR1 Monitoring Well. 

Section

Borehole 

Depth (ft)

Borehole 

Diam. (in.)

Casing 

OD (in.) Casing Grade

Casing 

weight (lb/ft)

Casing 

Connection

Conductor casing 150 26 to 30 20 B 94 PEB

Surface casing 600 17-1/2 13-3/8 J-55 61 BTC

Intermediate casing 3,450 12-1/4 9-5/8 J-55 36 STC

Long casing (with 

100-ft perforated 

section)

4,150 7-7/8 or 

8-1/2

5 -1/2 J-55 (0-3,450 ft); 

S13Cr110 (3,450-

4,150 ft)

17 LTC (J-55); 

Vam Top or 

similar 

(S13Cr110)

Tubing 4,100 NA 2-7/8 13Cr80 6.5 EUE

Grade B is equivalent to line pipe; BTC = buttress thread connection; Cr = chromium; EUE = externally upset end; 

LTC = long thread connection; PEB = plain end beveled; STC = short thread connection.

Notes: 

Actual casing grades and weights may differ based on material available at the time of construction. 

All depths are approximate and may be adjusted based on information obtained when the well is drilled.
Testing and Monitoring Plan for FutureGen Alliance Page C42 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Figure B-5 Construction Diagram for the New Single-Level in-Reservoir Monitoring Well (SLR1). 
Testing and Monitoring Plan for FutureGen Alliance Page C43 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Figure B-6. Construction Detail for SLR1 
Testing and Monitoring Plan for FutureGen Alliance Page C44 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

SLR2 Well Construction and Drilling Information 

Currently, the stratigraphic well is cased to 3,948 ft with 10-3/4-in. casing to below the top of the 

Mount Simon Sandstone (Figure ). Below this is a 14-3/4-in. open borehole to a depth of 4,018 

ft, then a 9-1/2-in. borehole to a total depth of 4,812 ft, which extends approximately 400 ft into 

Precambrian basement rock. The borehole below the intermediate casing is currently uncased. 

The planned design for the reconfigured stratigraphic well (SLR2) includes backfilling the 

bottom 660 ft of the borehole with CO2-resistant cement to ~4,150 ft (Figure B-8) before 

installing a 7-in.-OD casing string to 4,150 ft bgs. The 7-in casing will then be cemented in 

place using CO2-resistant cement to near the top of the caprock (3,450 ft) followed by regular 

cement to the surface. The 7-in. well will be constructed using 7-in stainless steel (S13Cr110) 

casing to a depth of approximately 4,000 ft. Above this depth, carbon-steel casing will be used. 

After the cement job has been completed, the 7-in. casing and cement will be perforated to 

construct a 100-ft-long Mount Simon Sandstone monitoring interval between the depths of 4,000 

and 4,100 ft. Following perforation and well development activities, a removable bridge plug 

may be installed just below the perforated interval to isolate it from the rathole below. A 2-7/8-

in.-OD tubing string will then be run inside the 7-in. casing to near the bottom of the perforated 

interval. The installed tubing will be perforated (slotted) across the 4,000- to 4,100-ft-depth 

interval and isolated to this zone via a tubing packer above (Figure B-8). A summary of the 

borehole and casing program for the SLR2 well is provided in Table B-4. 
Testing and Monitoring Plan for FutureGen Alliance Page C45 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Figure B-7. Construction Diagram for the Stratigraphic Well Reconfigured as a Single-Level in-Reservoir 

Monitoring Well (SLR2). 
Testing and Monitoring Plan for FutureGen Alliance Page C46 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Figure B-8. Construction Detail for SLR2 

Table B-4. Casing and Borehole Program for the SLR2 Monitoring Well 

Section

Borehole 

Depth (ft)

Borehole 

Diam (in.)

Casing 

OD (in.) Casing Grade

Casing 

weight 

(lb/ft)

Casing 

Connection

Conductor casing 132 30 24 PEB 140 Welded

Surface casing 556 20 16 J-55 84 BTC

Intermediate casing 3,948 14-3/4 10-3/4 N-80 51 BTC

Long casing (with 

100-ft perforated 

section)

4,150 9-1/2 to 

14-3/4

7 N-80 (0-3,500):

S13Cr110 

(3,500-TD)

29 LTC (N-80);

VAM TOP 

(S13Cr110)

Tubing 4,100 NA 2-7/8 13Cr80 6.5 EUE

BTC = buttress thread connection; Cr = chromium; EUE = externally upset end; LTC = long thread connection; 

PEB = plain end beveled.

Note: Actual casing grades and weights may differ based on material available at the time of construction. 
Testing and Monitoring Plan for FutureGen Alliance Page C47 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

RAT Well Construction and Drilling Information 

The monitoring network will also include three RAT installations (Figure B-9). These 

monitoring points will be located within the predicted lateral extent of the 1- to 3-year CO2

plume based on numerical simulations of injected CO2 movement. The RAT locations were 

selected to provide information about CO2 arrival at different distances from the injection wells 

and at multiple lobes of the CO2 plume. The RAT installations are planned for the collection of 

pulsed-neutron capture logs of the FutureGen CO2 reservoir—the Mount Simon and Eau Claire 

formations. Design and construction requirements for the RAT installations are discussed in the 

following paragraphs. 
Testing and Monitoring Plan for FutureGen Alliance Page C48 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Figure B-9. Construction Diagram for the Three Reservoir Access Tube Installations.
Testing and Monitoring Plan for FutureGen Alliance Page C49 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

To begin, a 26-in. borehole will be drilled and 20-in.-OD conductor casing will be installed to 

near the contact with Pennsylvanian bedrock (150 ft) (Figure B-9). Next, the boring will step 

down to a 17-1/2-in. borehole and 13-3/8-in. casing to approximately 600 ft. Below 600 ft, the 

hole will step down to a 12-1/4-in. hole lined with 9-5/8-in. casing down to the top of the 

confining unit (~3,450 ft) into the Proviso member. After cementing the 9-5/8-in. casing in place 

a 7-7/8-in. borehole will be drilled into the Precambrian basement rock (~4,465 ft). Next, a 4-

1/2-in. stainless-steel casing will be lowered to the bottom of the hole and surrounded by CO2-

resistant cement, which will be allowed to rise 25 ft up inside the bottom of the 4-1/2-in. casing. 

Because these access tubes are designed for geophysical monitoring, no open interval will exist 

for direct measurement or collection of water samples or parameters. See Table B-5 for the RAT 

casing and borehole program details. 

Figure B-10. Surface Completion Diagram for Reservoir Access Tube Installations. 

The surface completion for the RAT installations will consist of a wellhead centered over a 

concrete pad. The wellhead will include a main shut-in valve and pressure gauge. The top of the 

access tube will be secured with a lockable cap along with four removeable steel protective posts 

outside each corner of the concrete pad (Figure B-10).
Testing and Monitoring Plan for FutureGen Alliance Page C50 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Table B-5. Casing and Borehole Program for the Reservoir Access Tubes. 

Section

Borehole 

Depth (ft)

Borehole 

Diameter

(in.)

Casing 

OD (in.) Casing Grade

Casing 

weight 

(lb/ft)

Casing 

Connection

Conductor Casing 150 26 to 30 20 B 94 PEB

Surface Casing 600 17 1/2 13 3/8 J-55 61 BTC

Intermediate 

Casing

~3,450 12 1/4 9 5/8 J-55 36 STC

Long Casing ~4,465 7 7/88 to 

8 1/2

4 1/2 J-55 (0-3,500 ft); 

S13Cr110 

(3,500-4,465 ft.)

10.5 STC

Grade B is equivalent to line pipe; BTC = buttress thread connection; Cr = chromium; LTC = long thread 

connection; PEB = plain end beveled.

Notes: 

Actual casing grades and weights may differ based on material available at the time of construction.

All depths are approximate and may be adjusted based on information obtained when the well is drilled.
Testing and Monitoring Plan for FutureGen Alliance Page C51 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

APPENDIX C: Surficial Aquifer Monitoring Well Locations

Well ID Well Type Latitude Longitude

FG-1 FutureGen Shallow Monitoring Well 39.80675 -90.05283

FGP-1 Private Well 39.79888 -90.0736

FGP-2 Private Well 39.78554 -90.0639

FGP-3 Private Well 39.79497 -90.0746

FGP-4 Private Well 39.79579 -90.0747

FGP-5 Private Well 39.81655 -90.0622

FGP-6 Private Well 39.81086 -90.057560

FGP-7 Private Well 39.81444 -90.065241

FGP-9 Private Well 39.80829 -90.0377

FGP-10 Private Well 39.81398 -90.0427
Testing and Monitoring Plan for FutureGen Alliance Page C52 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

APPENDIX D: Permanent Gravity Station Locations 

Station# Latitude Longitude

0 39.73424 -90.22926

= NGS PID#KC0540, monument at Central Plaza Park, 

Jacksonville - point tied to 137 on 11/10/11 - this will 

be the reference used in future surveys.

5 39.79266 -90.07426 Nailed Permanent Stations

21 39.79449 -90.07424

37 39.79617 -90.07425

53 39.79814 -90.07427

65 39.79991 -90.08316

66 39.79990 -90.08090

67 39.79989 -90.07886

68 39.79988 -90.07616

69 39.79989 -90.07384

83 39.80164 -90.07889

86 39.80176 -90.07240

99 39.80349 -90.07888

102 39.80352 -90.07239

107 39.80348 -90.05998

108 39.80295 -90.05766

109 39.80332 -90.05519

110 39.80339 -90.05277

115 39.80526 -90.07887

118 39.80529 -90.07237

126 39.80544 -90.05216

131 39.80710 -90.07886

134 39.80721 -90.07154

135 39.80720 -90.06922

136 39.80720 -90.06687

137 39.80727 -90.06485

147 39.80888 -90.07885

153 39.80842 -90.06413

154 39.80894 -90.06224

163 39.81078 -90.07885

171 39.81077 -90.06002

179 39.81248 -90.07884

187 39.81265 -90.05999

188 39.81283 -90.05770

189 39.81286 -90.05538

193 39.81447 -90.08326

194 39.81447 -90.08103

195 39.81451 -90.07870

196 39.81449 -90.07629

197 39.81457 -90.07419

205 39.81443 -90.05513

206 39.81436 -90.05287

207 39.81435 -90.05064

208 39.81437 -90.04825

213 39.81609 -90.07408

229 39.81790 -90.07408
Testing and Monitoring Plan for FutureGen Alliance Page C53 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

Station# Latitude Longitude

245 39.81971 -90.07407

246 39.79996722210 -90.08494295 Permanent Stations to be added prior to commencing 

247 39.79997642140 injection. -90.08680687

248 39.79998533330 -90.08861842

249 39.79999393550 -90.09043265

250 39.80000198450 -90.09213566

251 39.80001079270 -90.09400542

252 39.80001951540 -90.09586339

253 39.80003000000 -90.09810508

254 39.81088084490 -90.09544073

255 39.81088937800 -90.09358759

256 39.81211009600 -90.0932439

257 39.81361707930 -90.0931657

258 39.81450582940 -90.09142522

259 39.81450590850 -90.08939647

260 39.81450595100 -90.08745444

261 39.81450596010 -90.0853458

262 39.79094794920 -90.07434558

263 39.78955807990 -90.07434813

264 39.78808280800 -90.07435083

265 39.78655838880 -90.07435362

266 39.78543344990 -90.08777897

267 39.78542392910 -90.08587085

268 39.78541218410 -90.0835256

269 39.78540044900 -90.08119175

270 39.78540873070 -90.07875712

271 39.78542609070 -90.07656216

272 39.78533023230 -90.07434254

273 39.78541496330 -90.07234073

274 39.78538771320 -90.07041894

275 39.78537326690 -90.06835921

276 39.78537180190 -90.06658679

277 39.78537006050 -90.06452139

278 39.78536811720 -90.06226638

279 39.78533703980 -90.06040206

280 39.78532614220 -90.05850696
Testing and Monitoring Plan for FutureGen Alliance Page C54 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

APPENDIX E: Microseismic Monitoring and Integrated Deformation Station Locations 

Well 

ID/Station ID Well / Station Type Latitude (WGS84)

Longitude

(WGS84)

MS1  Microseismic monitoring Station 1(shallow borehole)

 Integrated deformation monitoring station 39.8110768 -90.09797015

MS2  Microseismic monitoring Station 2 (shallow borehole)

 Integrated deformation monitoring station 39.78547402 -90.05028403

MS3  Microseismic monitoring Station 3 (shallow borehole)

 Integrated deformation monitoring station 39.81193502 -90.06016279

MS4  Microseismic monitoring Station 4 (shallow borehole)

 Integrated deformation monitoring station 39.78558513 -90.09557015

MS5  Microseismic monitoring Station 5 (shallow borehole)

 Integrated deformation monitoring station 39.80000524 -90.07830287

ACZ1  Deep microseismic station (deep borehole) 39.80034315 -90.07829648

ACZ2  Deep microseismic station (deep borehole) 39.80029543 -90.08801028
Testing and Monitoring Plan for FutureGen Alliance Page C55 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

APPENDIX F: Injection Well Continuous Monitoring Device Locations 

Sampling Locations for Continuous Monitoring 

Test Description Location

Annular Pressure Monitoring Surface

Injection Pressure Monitoring Surface

Injection Pressure Monitoring -

primary

Reservoir - 3,850 feet below 

ground surface

Injection Rate Monitoring Surface

Injection Volume Monitoring Surface

Temperature Monitoring - primary Surface

Temperature Monitoring Reservoir - 3,850 feet below 

ground surface
Testing and Monitoring Plan for FutureGen Alliance Page C56 of 56 

Permit Number: IL-137-6A-0003 (Well #3) 

APPENDIX G: Quality Assurance and Surveillance Plan
FutureGen 2.0 –

CO2 Pipeline and Storage Project 

Quality Assurance and Surveillance 

Plan 

Revision 1 

FutureGen Industrial Alliance, Inc. 

1101 Pennsylvania Ave., Sixth Floor 

Washington, DC 20004 

August 2014 
A.1 

A. Project Management 

A.1 Title and Approval Sheet 

FutureGen 2.0 –

CO2 Pipeline and Storage Project 

Quality Assurance and Surveillance Plan 

Revision 1 

FutureGen Industrial Alliance, Inc. 

1101 Pennsylvania Ave., Sixth Floor 

Washington, DC 20004

Approvals: 

Project Manager ________________________________ ____________

Battelle Tyler J Gilmore Date 

Monitoring, Verification, and 

Accounting Task Lead ________________________________ ____________ 

Battelle Vince R. Vermeul Date 

Project Quality Engineer ________________________________ ____________ 

Battelle William C. Dey Date 
A.2 

A.2 Table of Contents

A. Project Management ......................................................................................................................... A.1

A.1 Title and Approval Sheet ....................................................................................................... A.1

A.2 Table of Contents .................................................................................................................. A.2

A.3 Distribution List .................................................................................................................... A.9

A.4 Project/Task Organization ................................................................................................... A.10

A.4.1 Alliance Chief Executive Officer ........................................................................ A.12

A.4.2 Project Manager .................................................................................................. A.12

A.4.3 Quality Engineer ................................................................................................. A.12

A.4.4 Monitoring, Verification, and Accountability Task Lead ................................... A.12

A.4.5 Subject Matter Experts/Subtask Task Leads ....................................................... A.12

A.5 Problem Definition/Background ......................................................................................... A.12

A.5.1 Purpose and Objectives ....................................................................................... A.12

A.5.2 Background ......................................................................................................... A.13

A.6 Project/Task Description ..................................................................................................... A.13

A.6.1 CO2 Injection Stream and Corrosion/Well Integrity Monitoring ........................ A.15

A.6.2 Storage Site Monitoring ...................................................................................... A.15

A.7 Quality Objectives and Criteria for Measurement Data ...................................................... A.21

A.7.1 Quality Objectives ............................................................................................... A.21

A.7.2 Measurement Performance/Acceptance Criteria ................................................. A.22

A.8 Special Training/Certifications ............................................................................................ A.27

A.9 Documentation and Records ............................................................................................... A.28

B. Data Generation and Acquisition ...................................................................................................... B.1

B.1 Carbon Dioxide Stream Analysis .......................................................................................... B.1

B.1.1 Sampling Process Design (Experimental Design) ................................................ B.2

B.1.2 Sampling Methods ................................................................................................ B.2

B.1.3 Sample Handling and Custody .............................................................................. B.2

B.1.4 Analytical Methods ............................................................................................... B.2

B.1.5 Quality Control ..................................................................................................... B.2

B.1.6 Instrument/Equipment Testing, Inspection, and Maintenance .............................. B.3

B.1.7 Instrument/Equipment Calibration and Frequency ............................................... B.3

B.2 Continuous Recording of Injection Pressure, Rate, and Volume; Annulus Pressure ............ B.3

B.2.1 Sampling Process Design (Experimental Design) ................................................ B.3

B.2.2 Sampling Methods ................................................................................................ B.3

B.2.3 Sample Handling and Custody .............................................................................. B.4

B.2.4 Analytical Methods ............................................................................................... B.4

B.2.5 Quality Control ..................................................................................................... B.4

B.2.6 Instrument/Equipment Testing, Inspection, and Maintenance .............................. B.4

B.2.7 Instrument/Equipment Calibration and Frequency ............................................... B.4

B.3 Corrosion Monitoring ............................................................................................................ B.5

B.3.1 Sampling Process Design (Experimental Design) ................................................ B.5

B.3.2 Sampling Methods ................................................................................................ B.5

B.3.3 Sample Handling and Custody .............................................................................. B.5

B.3.4 Analytical Methods ............................................................................................... B.6

B.3.5 Quality Control ..................................................................................................... B.6

B.3.6 Instrument/Equipment Testing, Inspection, and Maintenance .............................. B.6

B.3.7 Instrument/Equipment Calibration and Frequency ............................................... B.6

B.4 Groundwater Quality Monitoring (ACZ and USDW wells) ................................................. B.7

B.4.1 Sampling Process Design (Experimental Design) ................................................ B.7

B.4.2 Sampling Methods ................................................................................................ B.7
A.3 

B.4.3 Sample Handling and Custody .............................................................................. B.8

B.4.4 Analytical Methods ............................................................................................... B.8

B.4.5 Quality Control ..................................................................................................... B.8

B.4.6 Instrument/Equipment Testing, Inspection, and Maintenance .............................. B.9

B.4.7 Instrument/Equipment Calibration and Frequency ............................................... B.9

B.5 External Mechanical Integrity Testing .................................................................................. B.9

B.5.1 Sampling Process Design (Experimental Design) .............................................. B.10

B.5.2 Sampling Methods .............................................................................................. B.11

B.5.3 Sample Handling and Custody ............................................................................ B.11

B.5.4 Analytical Methods ............................................................................................. B.11

B.5.5 Quality Control ................................................................................................... B.12

B.5.6 Instrument/Equipment Testing, Inspection, and Maintenance ............................ B.12

B.5.7 Instrument/Equipment Calibration and Frequency ............................................. B.12

B.6 Pressure Fall-Off Testing .................................................................................................... B.12

B.6.1 Sampling Process Design (Experimental Design) .............................................. B.12

B.6.2 Sampling Methods .............................................................................................. B.13

B.6.3 Sample Handling and Custody ............................................................................ B.14

B.6.4 Analytical Methods ............................................................................................. B.14

B.6.5 Quality Control ................................................................................................... B.15

B.6.6 Instrument/Equipment Testing, Inspection, and Maintenance ............................ B.15

B.6.7 Instrument/Equipment Calibration and Frequency ............................................. B.15

B.7 Carbon Dioxide Plume and Pressure-Front Tracking ......................................................... B.15

B.7.1 Sampling Process Design (Experimental Design) .............................................. B.15

B.7.2 Sampling Methods .............................................................................................. B.17

B.7.3 Sample Handling and Custody ............................................................................ B.17

B.7.4 Analytical Methods ............................................................................................. B.18

B.7.5 Quality Control ................................................................................................... B.18

B.7.6 Instrument/Equipment Testing, Inspection, and Maintenance ............................ B.18

B.7.7 Instrument/Equipment Calibration and Frequency ............................................. B.19

B.8 Pulsed-Neutron Capture Logging ........................................................................................ B.19

B.8.1 Sampling Process Design (Experimental Design) .............................................. B.19

B.8.2 Sampling Methods .............................................................................................. B.19

B.8.3 Sample Handling and Custody ............................................................................ B.20

B.8.4 Analytical Methods ............................................................................................. B.20

B.8.5 Quality Control ................................................................................................... B.20

B.8.6 Instrument/Equipment Testing, Inspection, and Maintenance ............................ B.20

B.8.7 Instrument/Equipment Calibration and Frequency ............................................. B.20

B.9 Integrated Deformation Monitoring .................................................................................... B.21

B.9.1 Sampling Process Design (Experimental Design) .............................................. B.21

B.9.2 Sampling Methods .............................................................................................. B.21

B.9.3 Sample Handling and Custody ............................................................................ B.21

B.9.4 Analytical Methods ............................................................................................. B.22

B.9.5 Quality Control ................................................................................................... B.22

B.9.6 Instrument/Equipment Testing, Inspection, and Maintenance ............................ B.22

B.9.7 Instrument/Equipment Calibration and Frequency ............................................. B.22

B.10 Time-Lapse Gravity Monitoring ......................................................................................... B.22

B.10.1 Sampling Process Design (Experimental Design) .............................................. B.22

B.10.2 Sampling Methods .............................................................................................. B.23

B.10.3 Sample Handling and Custody ............................................................................ B.23

B.10.4 Analytical Methods ............................................................................................. B.23

B.10.5 Quality Control ................................................................................................... B.23
A.4 

B.10.6 Instrument/Equipment Testing, Inspection, and Maintenance ............................ B.23

B.10.7 Instrument/Equipment Calibration and Frequency ............................................. B.23

B.11 Microseismic Monitoring .................................................................................................... B.23

B.11.1 Sampling Process Design (Experimental Design) .............................................. B.24

B.11.2 Sampling Methods .............................................................................................. B.24

B.11.3 Sample Handling and Custody ............................................................................ B.25

B.11.4 Analytical Methods ............................................................................................. B.25

B.11.5 Quality Control ................................................................................................... B.25

B.11.6 Instrument/Equipment Testing, Inspection, and Maintenance ............................ B.25

B.11.7 Instrument/Equipment Calibration and Frequency ............................................. B.25

B.12 Inspection/Acceptance of Supplies and Consumables ........................................................ B.25

B.13 Non-direct Measurements (e.g., existing data) .................................................................... B.26

B.14 Data Management................................................................................................................ B.26

B.14.1 Data Management Process .................................................................................. B.26

B.14.2 Record Keeping Procedures ................................................................................ B.26

B.14.3 Data Handling Equipment and Procedures ......................................................... B.26

B.14.4 Configuration Management and Change Control ............................................... B.26

C. Assessment and Oversight ................................................................................................................ C.1

C.1 Assessments and Response Actions ...................................................................................... C.1

C.2 Reports to Management ......................................................................................................... C.1

D. Data Validation and Usability ........................................................................................................... D.1

D.1 Data Review, Verification, and Validation ........................................................................... D.1

D.2 Verification and Validation Methods .................................................................................... D.1

D.3 Reconciliation with User Requirements ................................................................................ D.2

E. References .......................................................................................................................................... E.1

Appendix A ...................................................................................................................................... App. A-1

Appendix B ...................................................................................................................................... App. B-1

List of Figures 

A.1 CO2 Pipeline and Storage Project Structure (after Alliance 2013a) ................................................ A.10

A.2 Task Level Project Organization Relevant to Well Testing and Monitoring .................................. A.11

A.3 Nominal Monitoring Well Layout and Modeled Supercritical CO2 (scCO2) Plume at 

different times. Note that the monitoring well locations are approximate and subject 

to landowner approval. .................................................................................................................... A.17

A.4 Locations of Permanent and Proposed Permanent Gravity and Supplemental DGPS Stations ...... A.20

List of Tables 

A.1 Distribution List ................................................................................................................................ A.9

A.2 Monitoring Tasks, Methods, and Frequencies by Project Phase..................................................... A.14

A.3 Planned Monitoring Wells in the Network ..................................................................................... A.16

A.4 Monitoring Technologies and Decision to Include in Monitoring Plans ........................................ A.19

A.5 CO2 Injectate Monitoring Requirements ......................................................................................... A.23

A.6 Mechanical Integrity Testing and Corrosion Requirements ........................................................... A.24

A.7 Groundwater Geochemical and Indicator Parameter Requirements ............................................... A.25

A.8 Required Minimum Specifications for Real-Time Parameter Measurements ................................ A.26

A.9 Indirect Geophysical Monitoring Requirements ............................................................................. A.27

B.1 Parameters and Frequency for CO2 Stream Analysis........................................................................ B.2

B.2 Quality Control Samples ................................................................................................................... B.8
A.5 

Acronyms and Abbreviations 

3D three-dimensional

4D

ACP

four-dimensional

annulus casing packer

ACZ above confining zone

AMS accelerator mass spectrometry

AoR Area of Review

API American Petroleum Institute

APS Annulus Pressurization System

ASTM ASTM International (formerly the American Society for Testing and Materials)

bgs below ground surface

CCS carbon capture and storage

CEO Chief Executive Officer

CFR Code of Federal Regulations

CMP Configuration Management Plan

CO2 carbon dioxide

CVAA cold vapor atomic absorption

DGPS Differential Global Positioning System

DIC dissolved inorganic carbon

DInSAR Differential Interferometric Synthetic Aperture Radar

DOC dissolved organic carbon

ECD electron capture detector

EPA U.S. Environmental Protection Agency

GC gas chromatography

GC/FID gas chromatography with flame ionization detector

GC/HID gas chromatography with helium ionization detector

GC/MS gas chromatography-mass spectrometry

GC/SCD gas chromatograph with sulfur chemiluminescence detector

GPS Global Positioning System

GS Geologic Sequestration

HDI How Do I...? (Pacific Northwest National Laboratory’s web-based system for 

deploying requirements and procedures to staff)

IARF infinite-acting radial flow

ICP inductively coupled plasma

ICP-AES inductively coupled plasma atomic emission mass spectrometry

ICP-MS inductively coupled plasma mass spectrometry

IRMS isotope ratio mass spectrometry

ISBT International Society of Beverage Technologists

LC-MS liquid chromatography-mass spectrometry

LCS laboratory control sample
A.6 

MIT mechanical integrity testing

MMT million metric tons

MS mass spectrometry

MVA Monitoring, Verification, and Accounting

NA not applicable

OD outside diameter

OES optical emission spectrometry

P pressure

P/T pressure-and-temperature

P/T/SpC pressure, temperature, and specific conductance

PDMP Project Data Management Plan

PFT perfluorocarbon tracer

PLC programmable logic controller

PM Project Manager

PNC pulsed-neutron capture

PNWD Battelle Pacific Northwest Division

QA quality assurance

QASP Quality Assurance and Surveillance Plan

QC quality control

QE Quality Engineer

RAT reservoir access tube

RTD resistance temperature detector

RTK Real-Time Kinematic

RTU remote terminal unit

SAR Synthetic Aperture Radar

SCADA Supervisory Control and Data Acquisition

scCO2 supercritical carbon dioxide

SLR single-level in-reservoir

SME subject matter expert

SNR signal-to-noise ratio

SpC specific conductance

T temperature

TC thermocouple

TCD thermal conductivity detector

TDMP Technical Data Management Plan

TIC total inorganic carbon

TOC total organic carbon

UIC Underground Injection Control

USDW underground source of drinking water

VOA Volatile Organic Analysis

WS-CRDS wavelength scanned cavity ring-down spectroscopy
A.7 
A.8 

Definitions 

Injection interval: The open (e.g., perforated) section of the injection well, through which the carbon 

dioxide (CO2) is injected. 

Injection zone: A geologic formation, group of formations, or part of a formation that is of sufficient 

areal extent, thickness, porosity, and permeability to receive CO2 through a well or wells associated 

with a geologic sequestration project.

Prover: A device that verifies the accuracy of a gas meter. 

Reservoir: A subsurface body of rock having sufficient porosity and permeability to store and transmit 

fluids (Schlumberger Oilfield Glossary). Used interchangeably with injection zone. 

Sigma: A measure of the decay rate of thermal neutrons as they are captured.
A.9 

A.3 Distribution List 

Table A.1 lists the individuals that should receive a copy of the approved Quality Assurance and 

Surveillance Plan (QASP) and any subsequent revisions. 

Table A.1. Distribution List 

Name Organization Project Role(s)

Contact Information

(telephone / email)

K. Humphreys FutureGen Industrial 

Alliance, Inc.

Chief Executive Officer 202-756-2492

Khumphreys@futgen.org

T. J. Gilmore Battelle PNWD Project Manager 509-371-7171

Tyler.Gilmore@pnnl.gov

W. C. Dey Battelle PNWD Quality Engineer 509-371-7515

William.Dey@pnnl.gov

V. R. Vermeul Battelle PNWD Task Lead – Monitoring,

Verification, and Accounting; 

Groundwater Quality Monitoring; 

CO2 Plume and Pressure-Front 

Tracking

509-371-7170

Vince.Vermeul@pnnl.gov

M. E. Kelley Battelle Columbus Task Lead − CO2 Injection 

Stream Monitoring; Corrosion 

Monitoring; External Well 

Integrity Testing

614-424-3704

kelleym@battelle.org

A. Bonneville Battelle PNWD Task Lead – Indirect Geophysical 

Monitoring

509-371-7263

Alain.Bonneville@pnnl.gov

R. D. Mackley Battelle PNWD Task Lead – USDW Groundwater 

Geochemical Monitoring, and 

Indicator Parameter Monitoring

509-371-7178

rdm@pnnl.gov

F. A. Spane Battelle PNWD Task Lead – Hydrologic Testing; 

Pressure Fall-Off Testing

509-371-7087

Frank.Spane@pnnl.gov 
A.10 

A.4 Project/Task Organization 

The high-level project organizational structure for the FutureGen 2.0 CO2 Pipeline and Storage Project is 

shown in Figure A.1 (Alliance 2013a). 

Figure A.1. CO2 Pipeline and Storage Project Structure (after Alliance 2013a) 
A.11 

The organizational structure specific to well testing and monitoring is shown in Figure A.2. 

Figure A.2. Task Level Project Organization Relevant to Well Testing and Monitoring 
A.12 

A.4.1 Alliance Chief Executive Officer 

The FutureGen 2.0 CO2 Pipeline and Storage Project is led by the Chief Executive Officer (CEO) of the 

FutureGen Industrial Alliance, Inc. (Alliance), who is responsible on a day-to-day basis for the project. 

The Alliance CEO reports to a board of directors composed of industry executives (one executive for each 

company contributing funds on an equal basis to the Alliance). 

A.4.2 Project Manager 

The Project Manager (PM) plays a central role in the implementation of all data gathering and analysis for 

the CO2 Pipeline and Storage Project and provides overall coordination and responsibility for all 

organizational and administrative aspects. The PM is responsible for the planning, funding, schedules, 

and controls needed to implement project plans and ensure that project participants adhere to the plan. 

A.4.3 Quality Engineer 

The role of the Quality Engineer (QE) is to identify quality-affecting processes and to monitor 

compliance with project requirements. The QE is responsible for establishing and maintaining the project 

quality assurance plans and monitoring project staff compliance with them. The QE is responsible for 

ensuring that this Quality Assurance and Surveillance Plan (QASP) meets the project’s quality assurance 

requirements. 

A.4.4 Monitoring, Verification, and Accounting Task Lead 

Well testing and monitoring activities are the responsibility of the Monitoring, Verification, and 

Accounting (MVA) Task Lead. The MVA Task Lead is responsible for developing, maintaining, and 

updating all well testing and monitoring plans, including this QASP. 

A.4.5 Subject Matter Experts/Subtask Task Leads 

Well Testing and Monitoring Subject Matter Experts (SMEs) and Task Leads comprise both internal 

(Battelle Pacific Northwest Division [PNWD]) and external (Battelle Columbus and other subcontractors) 

geologists, hydrologists, chemists, atmospheric scientists, ecologists, etc. The role of these SMEs is to 

develop testing and monitoring plans, to collect environmental data specified in those plans using best 

practices, and to maintain and update those plans as needed. 

The SMEs, assisted by the MVA Task Lead, are responsible for planning, collecting, and ensuring the 

quality of testing and monitoring data and managing all necessary metadata and provenance for these 

data. The SMEs are also often responsible for data analysis and data products (e.g., publications), and 

acquisition of independent data quality/peer reviews. 

A.5 Problem Definition/Background 

A.5.1 Purpose and Objectives 

The FutureGen CO2 Pipeline and Storage Project is part of the larger FutureGen 2.0 Project aimed at 

demonstrating the technical feasibility of oxy-combustion technology as an approach to implementing 

carbon capture and storage (CCS) from new and existing coal-fueled energy facilities. The advancement 

of CCS technology is critically important to addressing CO2 emissions and global climate change 

concerns associated with coal-fueled energy. The objective of this project is to design, build, and operate 
A.13 

a commercial-scale CCS system capable of capturing, treating, and storing the CO2 off-gas from a oxycombustion coal-fueled power plant located in Meredosia, Morgan County, Illinois. Using safe and 

proven pipeline technology, the CO2 will be transported to a nearby storage site, located near 

Jacksonville, Illinois, where it will be injected into the Mount Simon and Eau Claire formations at a rate 

of 1.1 million metric tons (MMT) of CO2 each year, for a planned duration of at least 20 years. 

The objective of the CO2 Pipeline and Storage project is to demonstrate utility-scale integration of 

transport and permanent storage of captured CO2 in a deep geologic formation (a.k.a. geologic 

sequestration) and to demonstrate that this can be done safely and ensure that the injected CO2 is retained 

within the intended storage reservoir. 

A.5.2 Background 

The U.S. Environmental Protection Agency (EPA) established requirements for CO2 geologic 

sequestration under the Underground Injection Control (UIC) Program for Geologic Sequestration (GS) 

Class VI Wells. These federal requirements (codified in the U.S. Code of Federal Regulations [40 CFR 

146.81 et seq.], known as the Class VI Rule) set minimum technical criteria for CO2 injection wells for 

the purposes of protecting underground sources of drinking water (USDWs). Testing and Monitoring 

Requirements (40 CFR 146.90) under the Class VI Rule require owners or operators of Class VI wells to 

develop and implement a comprehensive testing and monitoring plan that includes injectate monitoring; 

corrosion monitoring of the well’s tubular, mechanical, and cement components; pressure fall-off testing; 

groundwater quality monitoring; and CO2 plume and pressure-front tracking. These requirements (40 

CFR 146.90[k]) also require owners and operators to submit a QASP for all testing and monitoring 

requirements. 

This QASP details all aspects of the testing and monitoring activities that will be conducted, and ensures 

that they are verifiable, including the technologies, methodologies, frequencies, and procedures involved. 

As the project evolves, this QASP will be updated in concert with the Testing and Monitoring Plan. 

A.6 Project/Task Description 

The FutureGen CO2 Pipeline and Storage Project will undertake testing and monitoring as part of its 

MVA program to verify that the Morgan County CO2 storage site is operating as permitted and is not 

endangering any USDWs. The MVA program includes operational CO2 injection stream monitoring, 

well corrosion and mechanical integrity testing, geochemical and indicator parameter monitoring of both 

the reservoir and shallow USDWs, and indirect geophysical monitoring, for characterizing the complex 

fate and transport processes associated with CO2 injection. Table A.2 summarizes the general Testing 

and Monitoring tasks, methods, and frequencies. 
A.14 

Table A.2. Monitoring Tasks, Methods, and Frequencies by Project Phase 

Monitoring 

Category

Monitoring 

Method

Baseline

3 yr

Injection

(startup)

~3 yr

Injection

~2 yr

Injection

~15 yr

PostInjection

50 yr

CO2 Stream 

Analysis

Grab sampling and 

analysis

3 events, during 

commissioning

Quarterly Quarterly Quarterly NA

Continuous 

Recording of 

Injection 

Pressure, Rate,

and Annulus 

Pressure 

Continuous monitoring of 

injection process 

(injection rate, pressure, 

and temperature; annulus 

pressure and volume)

NA Continuous Continuous Continuous NA

Corrosion 

Monitoring 

Corrosion coupon 

monitoring of Injection 

Well Materials

NA Quarterly Quarterly Quarterly NA

Groundwater 

Quality 

Monitoring

Fluid sample collection 

and analysis in all ACZ 

and USDW monitoring 

wells

3 events Quarterly SemiAnnualAnnual Every 5 yr

Electronic P/T/SpC probes 

installed in ACZ and 

USDW wells 

1 yr min Continuous Continuous Continuous Continuous

External Well 

Mechanical 

Integrity 

Testing 

PNC and Temperature 

logging 

Once after well 

completion

Annual Annual Annual Annual until 

wells 

plugged

Cement-evaluation and 

casing inspection logging

Once after well 

completion

During well 

workovers

During well 

workovers

During well 

workovers

NA

Pressure FallOff TestingInjection well pressure 

fall-off testing

NA Every 5 yr Every 5 yr Every 5 yr NA

Direct CO2

Plume and 

Pressure-Front 

Monitoring

Fluid sample collection 

and analysis in SLR 

monitoring wells

3 events Quarterly SemiAnnualAnnual Every 5 yr

Electronic P/T/SpC probes 

installed in SLR wells 

1 yr min Continuous Continuous Continuous Continuous

Indirect CO2

Plume and 

Pressure-Front

Monitoring

Passive seismic 

monitoring 

(microseismicity)

1 yr min Continuous Continuous Continuous Continuous

Integrated deformation 

monitoring

1 yr min Continuous Continuous Continuous Continuous

Time-lapse gravity 3 events Annual Annual Annual NA

PNC logging of RAT 

wells

3 events Quarterly Quarterly Annual Annual

ACZ = above confining zone; NA = not applicable; PNC = pulsed-neutron capture; P/T/SpC = pressure, temperature, 

and specific conductance; RAT = reservoir access tube; SLR = single-level in-reservoir; USDW = underground source 

of drinking water. 
A.15 

A.6.1 CO2 Injection Stream and Corrosion/Well Integrity Monitoring 

The CO2 injection stream will be continuously monitored at the surface for pressure, temperature, and 

flow, as part of the instrumentation and control systems for the FutureGen 2.0 CO2 Pipeline and Storage 

Project. Periodic grab samples will also be collected and analyzed to track CO2 composition and purity. 

The pressure and temperature will be monitoring within each injection well at a position located 

immediately above the injection zone at the end of the injection tubing. The downhole sensor will be the 

point of compliance for maintaining injection pressure below 90 percent of formation fracture pressure. 

CO2 Stream Analysis 

The composition and purity of the CO2 injection stream will be monitored through the periodic collection 

and analysis of grab samples. 

Continuous Recording of Injection Pressure, Rate, and Volume; Annulus Pressure 

Pressure monitoring of the CO2 stream at elevated pressure will be done using local analog gauges, 

pressure transmitters, or pressure transmitters with local digital readouts. Flow monitoring will be 

conducted using Coriolis mass type meters. Normal temperature measurements will be made using 

thermocouples (TCs) or resistance temperature detectors (RTDs). A Supervisory Control and Data 

Acquisition (SCADA) system will be used to transmit operational power plant, pipeline, and injection 

well data long distances (~30 mi) for the pipeline and storage project. 

Corrosion Monitoring 

Samples of injection well materials (coupons) will be periodically monitored for signs of corrosion to 

verify that the well components meet the minimum standards for material strength and performance and 

to identify well maintenance needs. 

External Well Mechanical Integrity Testing 

Wireline logging, including pulsed-neutron capture (PNC) logs (both in the gas-view and oxygenactivation modes) and temperature logs, and cement-evaluation and casing inspection logging, will be 

conducted to verify the absence of significant fluid movement through potential channels adjacent to the 

injection well bore and/or to determine the need for well repairs. 

A.6.2 Storage Site Monitoring 

The objective of the storage site monitoring program is to select and implement a suite of monitoring 

technologies that are both technically robust and cost-effective and provide an effective means of 

1) evaluating CO2 mass balance (i.e., verify that the site is operating as permitted) and 2) detecting any 

unforeseen containment loss (i.e., verify that the site is not endangering any USDWs). Both direct and 

indirect measurements will be used collaboratively with numerical models of the injection process to 

verify that the storage site is operating as predicted and that CO2 is effectively sequestered within the 

targeted deep geologic formation and is fully accounted for. The approach is based in part on reservoirmonitoring wells, pressure fall-off testing, and indirect (e.g., geophysical) methods. Early-detection 

monitoring wells will target regions of increased leakage potential (e.g., proximal to wells that penetrate 

the caprock). During baseline monitoring, a comprehensive suite of geochemical and isotopic analyses 

will be performed on fluid samples collected from the reservoir and overlying monitoring intervals. 
A.16 

These analytical results will be used to characterize baseline geochemistry and provide a metric for 

comparison during operational phases. Selection of this initial analyte list was based on relevance for 

detecting the presence of fugitive brine and CO2. The results for this comprehensive set of analytes will 

be evaluated and a determination made regarding which analytes to carry forward through the operational 

phases of the project. This selection process will consider the uniqueness and signature strength of each 

potential analyte and whether its characteristics provide for a high-value leak-detection capability. 

Indicator parameters will be used to inform the monitoring program. Once baseline conditions and early 

CO2 arrival responses have been established, observed relationships between analytical measurements and 

indicator parameters will be used to guide less-frequent aqueous sample collection and reduced analytical 

parameters in later years. 

Monitoring Well Network (Geochemical and Indicator Parameter Monitoring) 

The monitoring well network will address transport uncertainties by using an “adaptive” or 

“observational” approach to monitoring (i.e., the monitoring approach will be adjusted as needed based 

on observed monitoring results). 

Two aquifers above the primary confining zone will be monitored for any unforeseen leakage of CO2

and/or brine out of the injection zone. These include the aquifer immediately above the confining zone 

(Ironton Sandstone, monitored with above confining zone [ACZ] wells) and the St. Peter Sandstone, 

which is separated from the Ironton by several carbonate and sandstone formations and is considered to 

be the lowermost USDW. In addition to directly monitoring for CO2, wells will initially be monitored for 

changes in geochemical and isotopic signatures that may provide indication of CO2 leakage. Wells will 

also be instrumented to detect changes in the stress regime (via pressure in all wells and microseismicity 

in selected wells) to avoid over-pressurization within the injection or confining zones that could 

compromise sequestration performance (e.g., caprock fracturing). Table A.3 describes the planned 

monitoring well network for geochemical and indicator parameter monitoring. Figure A.3 illustrates the 

nominal monitoring well layout. 

Table A.3. Planned Monitoring Wells in the Network 

Single-Level In-Reservoir (SLR) Above Confining Zone (ACZ) USDW

Number of Wells 2 2 1

Total Depth (ft) 4,150 3,470 2,000

Monitored Zone Mount Simon SS Ironton SS St. Peter SS

Monitoring 

Instrumentation

P/T/SpC probe in monitored 

interval(a)

Fiber-optic (microseismic) cable 

cemented in annulus; P/T/SpC 

probe in monitored interval(a)

P/T/SpC probe in 

monitored interval(a)

(a) The P/T/SpC probe is an electronic downhole multi-parameter probe incorporating sensors for measuring fluid 

pressure (P), temperature (T), and specific conductance (SpC) within the monitored interval. The probe will be 

installed inside a tubing string, which is perforated (slotted) over the monitoring interval. Measurements will be 

recorded with a data logger at each well location and also transmitted to the MVA data center in the control 

building.

SS = sandstone.
A.17 

Figure A.3. Nominal Monitoring Well Layout and Modeled Supercritical CO2 (scCO2) Plume at 

different times. Note that the monitoring well locations are approximate and subject to 

landowner approval. 
A.18 

Groundwater Quality Monitoring 

Fluid sampling (and subsequent geochemical analyses) and continuous monitoring of indicator 

parameters will be conducted at each ACZ and USDW monitoring well. 

Indicator Parameter Monitoring – Fluid pressure, temperature, and specific conductance (P/T/SpC) will 

be monitored continuously. These are the most important parameters to be measured in real time within 

the monitoring interval of each well. These are the primary parameters that will indicate the presence of 

CO2 or CO2-induced brine migration into the monitored interval. A data-acquisition system will be 

located at the surface to store the data from all sensors at the well site and will periodically transmit the 

stored data to the MVA data center in the control building. 

In addition, in the two ACZ wells, a fiber-optic cable with integral geophones (fiber Bragg grating optical 

accelerometer) will extend from ground surface to the monitoring interval (i.e., to the annulus casing 

packer [ACP] just above the monitoring interval); this cable will be strapped to the outside of the casing 

and permanently cemented in place to support the microseismic monitoring program. Data from the fiberoptic sensors will be transmitted back to the MVA data center via a local-area fiber-optic network where 

the data-acquisition system will be located. 

Geochemical Monitoring – Aqueous samples will be collected from each ACZ and USDW well, initially 

on a quarterly basis and decreasing in frequency as the system stabilizes over time, to determine the 

hydrochemistry in the monitoring interval fluids. 

CO2 Plume and Pressure-Front Tracking 

Fluid sampling (and subsequent geochemical analyses) and continuous monitoring of indicator 

parameters will be conducted at each single-level in-reservoir (SLR) monitoring well. 

Indicator Parameter Monitoring – Fluid P/T/SpC will be monitored continuously. They are the most 

important parameters to be measured in real time within the monitoring interval of each well. They are 

the primary parameters that will indicate the presence of CO2 or CO2-induced brine migration into the 

monitored interval. A data-acquisition system will be located at the surface to store the data from all 

sensors at the well site and will periodically transmit the stored data to the MVA data center in the control 

building. 

Geochemical Monitoring – Aqueous samples will be collected from each SLR well, initially on a 

quarterly basis and decreasing in frequency as the system stabilizes over time, to determine the 

hydrochemistry in the monitoring interval fluids. Aqueous sampling will not be used to assess CO2

saturation levels. Once supercritical carbon dioxide (scCO2) arrives, these wells can no longer provide 

representative fluid samples because of the two-phase fluid characteristics and buoyancy of scCO2.

Indirect CO2 Plume and Pressure-Front Tracking 

The primary objectives of indirect (e.g., geophysical) monitoring are 1) tracking CO2 plume evolution and 

CO2 saturation levels; 2) tracking development of the pressure front; and 3) identifying or mapping areas 

of induced microseismicity, including evaluating the potential for slip along any faults or fractures 

identified by microseismic monitoring. Table A.4 summarizes potential geophysical monitoring 

technologies and identifies those included in the Testing and Monitoring Plan. 
A.19 

Pulsed-Neutron Capture Logging – The monitoring network will also include three reservoir access tube 

(RAT) installations designed for the collection of PNC logs to indirectly quantify CO2 saturations within 

the Mount Simon injection zone or reservoir (Muller et al. 2007). PNC logging will serve as the primary 

measure for CO2 saturation changes that occur within the injection zone. These monitoring points will be 

located within the predicted lateral extent of the 1- to 3-year CO2 plume based on numerical simulations 

of injected CO2 movement. The RAT locations were selected to provide information about CO2 arrival at 

different distances from the injection wells and at multiple lobes of the CO2 plume. 

Geophysical Monitoring 

Table A.4. Monitoring Technologies and Decision to Include in Monitoring Plans 

Technology Purpose Analysis & Limitations

Pulsed-Neutron 

Capture Logging

Monitors CO2 saturation changes along 

boreholes. Used for reservoir model 

calibration and leak detection.

Will provide quantitative CO2

saturations. Sensitive only to 

region around the borehole. 

Integrated Surface 

Deformation 

Monitoring

Monitors subtle changes in the Earth’s 

surface due to geomechanical response 

to injection.

Will be able to measure 

expected deformation. 

Monitor for anomalies in 

pressure-front development. 

DInSAR can be difficult in 

vegetated areas.

Passive 

Microseismic

For locating fracture opening and slip 

along fractures or faults; may indicate 

location of the pressure front.

Can accurately detect seismic 

events. Not likely to detect 

limit of CO2 plume.

Time-Lapse 

Gravity 

Monitors changes in density 

distribution in the subsurface, caused 

by the migration of fluids. Relatively 

inexpensive.

Non-unique solution, must be 

used in conjunction with 

integrated surface 

deformation monitoring.

Passive Microseismic Monitoring – The objective of the microseismic monitoring network is to 

accurately determine the locations, magnitudes, and focal mechanisms of injection-induced seismic 

events with the primary goals of 1) addressing public and stakeholder concerns related to induced 

seismicity; 2) estimating the spatial extent of the pressure front from the distribution of seismic events; 

and 3) identifying features that may indicate areas of caprock failure and possible containment loss. The 

proposed seismic monitoring network consists of five shallow borehole stations, surface stations, and two 

deep borehole stations. The shallow borehole stations will be drilled to at least the uppermost competent 

bedrock (~100 m). Actual noise levels and sensor magnitude detection limits at the stations will not be 

determined until after the sensors have been emplaced and monitored for a period of time. The results of 

this preliminary evaluation will guide the location of a small number (fewer than five) of additional 

surface stations. 

Deep borehole sensors will be clamped to the outside of the casing of the two ACZ monitoring wells and 

cemented in place. A 24-level three-component borehole array will be installed in each well. The use of 

24-level arrays results in a slight improvement in event location, but more importantly offers redundant 

sensors in case of failure. Optical three-component accelerometers are technically optimal due to their 

designed long-term performance characteristics. 
A.20 

Time-Lapse Gravity – The objective of this technique is to estimate the areal extent of the CO2 plume, 

based on observed changes in density distribution in the subsurface, caused by the migration of fluids. 

Gravity changes at the surface are expected to be small but averaging many measurements and/or analysis 

of long-term trends may allow for tracking of the CO2 plume. The solution is non-unique and is most 

useful when combined with Differential Global Positioning System (DGPS) surveys and other integrated 

surface deformation methods and/or seismic surveys. The locations of permanent and proposed 

permanent station monuments are shown in Figure A.4. 

Figure A.4. Locations of Permanent and Proposed Permanent Gravity and Supplemental DGPS 

Stations 

Integrated Deformation Monitoring – Integrated deformation monitoring integrates ground-surface data 

from permanent Global Positioning System (GPS) stations and tiltmeters, supplemented with annual 

DGPS surveys and larger-scale Differential Interferometric Synthetic Aperture Radar (DInSAR) surveys 

to detect and map temporal ground-surface deformation. The DInSAR and proposed GPS network are 
A.21 

expected to resolve sub-centimeter surface changes and accurately measure the anticipated injectioninduced surface deformation. Permanent GPS and tiltmeter stations will be co-located with the shallow 

microseismic locations and are expected to have the spatial coverage needed to characterize the overall 

shape and evolution of the geomechanical changes that occur as a result of CO2 injection. 

A.7 Quality Objectives and Criteria for Measurement Data 

The primary goal of testing and monitoring activities is to verify that the Morgan County CO2 storage site 

is operating as permitted and is not endangering any USDWs. The Class VI Rule requires that the owner 

or operator submit the results of testing and monitoring as part of the required semi-annual reports (40 

CFR 146.91(a)(7)). 

A.7.1 Quality Objectives 

The overall Quality Assurance (QA) objective for testing and monitoring is to provide results, 

interpretation, and reporting that provide reasonable assurance that decision errors regarding compliance 

with permitting and protection of USDWs are unlikely. The EPA (2013 EPA 816-R-13-001 – Testing 

and Monitoring Guidance) provides a number of recommendations that can be used as qualitative 

measures/criteria against which the testing and monitoring results can be compared to evaluate 

compliance.

Mechanical Integrity Testing 

Demonstrating and maintaining the mechanical integrity of a well is a key aspect of protecting USDWs 

from possible endangerment and a specific requirement for Class VI wells in the UIC Program. The 

Class VI Rule requires mechanical integrity testing (MIT) to be conducted prior to injection (40 CFR 

146.87(a)(4)), during the injection phase (40 CFR 146.89), and prior to well plugging after injection has 

ceased (40 CFR 146.92(a)). The EPA further identified a number of acceptable MIT methods. 

A Class VI well can be demonstrated to have mechanical integrity if there is no significant leak (i.e., fluid 

movement) in the injection tubing, packer, or casing (40 CFR 146.89(a)(1)), and if there is no significant 

fluid movement through channels adjacent to the injection well bore (40 CFR 146.89(a)(2)). Note that the 

UIC Program Director will evaluate the results and interpretations of MIT to independently assess the 

integrity of the injection wells. 

Operational Testing and Monitoring During Injection 

The Class VI Rule requires owners or operators to monitor injectate properties, injection rate, pressure, 

volume, corrosion of well materials, and perform pressure fall-off testing (40 CFR 146.90(a), (b), (c), and 

(f)), to indicate possible deviation from planned project operations, verify compliance with permit 

conditions, and to inform Area of Review (AoR) reevaluations. The results are expected to be interpreted 

with respect to regulatory requirements and past results. Note the UIC Program Director will evaluate the 

results to ensure that the composition of the injected stream is consistent with permit conditions and that it 

does not result in the injectate being classified as a hazardous waste. 

Plume and Pressure-Front Tracking 

The EPA (2013 EPA 816-R-13-001 – Testing and Monitoring Guidance) indicates that identification of 

the position of the injected CO2 plume and the presence or absence of elevated pressure (i.e., the pressure 
A.22 

front) are integral for verifying the storage reservoir is behaving as predicted, informing the reevaluation 

of the AoR, and protecting the USDWs. The temporal changes will be analyzed by comparing the new 

data to previously collected data, and time-series graphs will be developed and interpreted for each well, 

taking into consideration the injection rate and well location. Spatial patterns will also be analyzed by 

constructing maps that present contours of pressure and/or hydraulic head. Increases in pressure in wells 

above the confining zone may be indicative of fluid leakage. Increases in pressure within the injection 

zone will be compared to modeling predictions to determine whether the AoR is consistent with 

monitoring results. Pressure increases at a monitoring well location greater than predicted by the current 

site AoR model, or increases at a greater rate, may indicate that the model needs to be revised. 

Geochemical Monitoring 

The results of groundwater monitoring will be compared to baseline geochemical data collected during 

site characterization (40 CFR 146.82(a)(6)) to obtain evidence of fluid movement that may affect 

USDWs. The EPA (2013 EPA 816-R-13-001 – Testing and Monitoring Guidance) suggests that trends 

in groundwater concentrations may be indicative of fluid leakage—such as changes in total dissolved 

solids, major cations and anions, increasing CO2 concentrations, decreasing pH, increasing concentration 

of injectate impurities, increasing concentration of leached constituents, and/or increased reservoir 

pressure and/or static water levels. The EPA also suggests that geochemical data be compared to results 

from rock-water-CO2 experiments or geochemical modeling. 

Note that the UIC Program Director will evaluate the groundwater monitoring data to independently 

assess data quality, constituent concentrations (including potential contaminants), and the resulting 

interpretation to determine if there are any indications of fluid leakage and/or plume migration and 

whether any action is necessary to protect USDWs (EPA 2013 EPA 816-R-13-001 – Testing and 

Monitoring Guidance). 

A.7.2 Measurement Performance/Acceptance Criteria 

The qualitative and quantitative design objective of the FutureGen CO2 Pipeline and Storage Project’s 

testing and monitoring activities is to monitor the performance of the storage reservoir relative to permit 

and USDW protection requirements. The design of these activities is intended to provide reasonable 

assurance that decision errors regarding compliance with the permit and/or protection of the USDW are 

unlikely. In accordance with EPA 2013 EPA 816-R-13-001 – Testing and Monitoring Guidance, the well 

testing and monitoring program includes operational CO2 injection stream monitoring, well MIT, 

geochemical and indicator parameter monitoring of both the reservoir and lowermost USDWs, and 

indirect geophysical monitoring. Table A.5 lists the field and laboratory analytical parameters, methods, 

and performance criteria for CO2 injection stream monitoring. Table A.6 shows the MIT parameters, 

methods, and performance criteria. Table A.7 lists the groundwater geochemical and indicator 

parameters, methods, and performance criteria. Table A.8 lists the performance criteria for continuously 

recorded parameter measurements. Table A.9 lists the indirect geophysical parameters, methods, and 

performance criteria. 
A.23 

Table A.5. CO2 Injectate Monitoring Requirements 

Analytical 

Parameter Analytical Method #

Detection Limit or 

(Range)

Typical 

Precision/Accuracy QC Requirements

Pressure Analog gauges, 

pressure transmitters

0-2500 psi Accuracy: ±0.065% 

of span 

CO2 Pressure Transmitter, 

Mfg: Rosemount Part No: 

3051TG4A2B21AS5M5Q4

Temperature Thermocouples, or 

resistance 

temperature detectors

0-150 °F Accuracy: ±0.03% of 

span

CO2 Temperature Transmitter

Mfg: Rosemount Part No: 

644HANAXAJ6M5F6Q4

Flow Coriolis mass meter Range spanning 

maximum anticipated 

injection rate per well

±0.5 % A single flow prover will be installed 

to calibrate the flow meters, and 

piping and valving will be configured 

to permit the calibration of each flow 

meter.

CO2 GC/TCD 0.1-100% ± 10% Replicate analyses within 10% of 

each other

O2 GC/TCD 0.1-100% ± 10% Replicate analyses within 10% of 

each other

Total sulfur ISBT 14.0 (GC/SCD) 0.01 μL/L to 50 μL/L 

(ppmv) dilution 

dependent

± 10% Daily blank, daily standard within 

10% of calibration, secondary 

standard after calibration

Arsenic ICP-MS, EPA 

Method 6020

1 ng/m3(filtered 

volume)

±10% Daily calibration

Selenium ICP-MS, EPA 

Method 6020

5 ng/m3(filtered 

volume)

±10% Daily calibration

Mercury (Hg) Cold vapor atomic 

absorption (CVAA)

0.25 μg/m3 ± 10% Daily calibration

H2S ISBT 14.0 (GC/SCD) 0.01 μL/L to 50 μL/L 

(ppmv) dilution 

dependent

± 10% Daily blank, daily standard within 

10% of calibration, secondary 

standard after calibration

Ar GC/TCD 0.1-100% ± 10% Replicate analyses within 10% of 

each other

Water vapor 

(moisture)

GC/HID* < 100 ppm ± 10% Replicate analyses within 10% of 

each other

GC/TCD – gas chromatography with a thermal conductivity detector

ISBT – International Society of Beverage Technologists

GC/SCD – gas chromatography with a sulfur chemiluminescence detector

GC/HID - gas chromatography with helium Ionization detector

* Andrawes (1983) or equivalent. Method subject to change in subsequent revisions.
A.24 

Table A.6. Mechanical Integrity Testing and Corrosion Requirements 

Analytical Parameter Analytical Method # QC Requirements

Corrosion of Well Tubulars

Corrosion of well casing and tubing Corrosion coupon monitoring 

(visual, weight, and size); U.S. 

EPA SW846 Method 1110A –

“Corrosivity Toward Steel” (or a 

similar standard method).

Proper preparation of coupons per

ASTM G1-03, Standard Practice for Preparing, 

Cleaning, and Evaluating Corrosion Test 

Specimens.

Refer to SW846 Method 1110A for measurement 

QC requirements.

Corrosion of well casing (internal 

radius, wall thickness; general

corrosion, pitting, and

perforations)

Wireline logging (mechanical, 

ultrasonic, electromagnetic); casing 

evaluation would only be done 

during well workovers that require 

removal of tubing string.

Vendor calibration of well logging tool(s) per 

manufacturer recommendations.

Well cement corrosion (quality of 

cement bond to pipe, and channels in 

cement)

Wireline logging (acoustic, 

ultrasonic); casing evaluation 

would only be done during well 

workovers that require removal of 

tubing string.

Baseline cement evaluation logs prior to start of 

injection.

Vendor calibration of well logging tool(s) per 

manufacturer recommendations

External Mechanical Integrity

Temperature adjacent to the well Temperature logging to identify 

fluid movement adjacent to well 

bore 

Baseline temperature log prior to start of injection.

Vendor calibration of well logging tool(s) per 

manufacturer recommendations

Fluid composition adjacent to the 

well; fluid movement 

Pulsed-neutron logging in oxygen 

activation mode and thermal 

capture cross-section (sigma) mode

Baseline log prior to start of injection.

Tool calibration per 

manufacturer recommendations

Internal Mechanical Integrity

Continuous measurement of fluid 

pressure and fluid volume in annulus 

between tubing and long casing string 

during injection

Pressure and fluid volumes will be 

measured and logged automatically 

using electronic pressure sensors 

and fluid level indicators that are 

incorporated into the annulus 

pressurization system (APS).

Initial and ongoing calibration of pressure and 

fluid level sensors will be done as part of the 

Annulus Pressurization System Operations and 

Maintenance program.

Initial annulus pressure test prior to 

start of injection and following 

workovers that involve removing 

tubing and/or packer.

Annular pressure test per EPA UIC 

requirements 

Pressure Fall-Off Testing

Well pressure; CO2 injection ratehistory.Pressure transient analysis methods 

will be used to analyze pressure 

fall-off test data to assess well 

condition (skin) that could indicate 

need for well rehabilitation.

Initial and ongoing calibration of in-well pressure 

sensors.

Initial and ongoing calibration (proving) of CO2

flow-rate meters.
A.25 

Table A.7. Groundwater Geochemical and Indicator Parameter Requirements 

Parameter Analysis Method

Detection 

Limit or 

Range

Typical 

Precision/ 

Accuracy QC Requirements

A.7.3 Major Cations: Al, Ba,

Ca, Fe, K, Mg,

A.7.4 Mn, Na, Si,

A.7.5 ICP-AES, EPA Method 6010B or 

similar

A.7.6 1 to 80 μg/L

(analyte

dependent)

A.7.7 ±10%A.7.8 Daily calibration; blanks, LCS, 

and duplicates and matrix 

spikes at 10% level per batch 

of 20

A.7.9 Trace Metals: Sb, As,

Cd, Cr, Cu, Pb, Se, Tl

A.7.10 ICP-MS, EPA Method 6020 or 

similar

A.7.11 0.1 to 2 μg/L 

(analyte 

dependent)

A.7.12 ±10%A.7.13 Daily calibration; blanks, LCS, 

and duplicates and matrix 

spikes at 10% level per batch 

of 20

A.7.14 Cyanide (CN-)A.7.15 SW846 9012A/B A.7.16 5 μA.7.17 g/L ±10%A.7.18 Daily calibration; blanks, LCS, 

and duplicates at 10% level per 

batch of 20

A.7.19 Mercury A.7.20 CVAA SW846 7470A A.7.21 0.2 A.7.22 μg/L ±20%A.7.23 Daily calibration; blanks, LCS, 

and duplicates and matrix 

spikes at 10% level per batch 

of 20

A.7.24 Anions: Cl-, Br-, F

-

,

SO4

2-

, NO3

-

A.7.25 Ion Chromatography, EPA Method 

300.0A or similar

A.7.26 33 to 133 

μg/L (analyte 

dependent)

A.7.27 ±10%A.7.28 Daily calibration; blanks, LCS, 

and duplicates at 10% level per 

batch of 20

A.7.29 Total and Bicarbonate 

Alkalinity (as CaCO3

2-

)

A.7.30 Titration, Standard Methods 2320B A.7.31 1 mg/L ±10%A.7.32 Daily calibration; blanks, LCS, 

and duplicates at 10% level per 

batch of 20

A.7.33 Gravimetric Total

Dissolved Solids (TDS)

A.7.34 Gravimetric Method Standard 

Methods 2540C

A.7.35 10 mg/L A.7.36 ±10%A.7.37 Balance calibration, duplicate 

samples

A.7.38 Water DensityA.7.39 ASTM D5057 0.01 g/mL A.7.40 ±10%A.7.41 Balance calibration, duplicate 

samples

A.7.42 Total Inorganic Carbon

(TIC)

A.7.43 SW846 9060A or equivalent Carbon 

analyzer, phosphoric acid digestion 

of TIC

A.7.44 0.2 mg/L A.7.45 ±20%A.7.46 Quadruplicate analyses, daily 

calibration

A.7.47 Dissolved Inorganic

Carbon (DIC)

A.7.48 SW846 9060A or equivalent Carbon 

analyzer, phosphoric acid digestion 

of DIC

A.7.49 0.2 mg/L A.7.50 ±20%A.7.51 Quadruplicate analyses, daily 

calibration

A.7.52 Total Organic Carbon

(TOC)

A.7.53 SW846 9060A or equivalent

Total organic carbon is converted to 

carbon dioxide by chemical 

oxidation of the organic carbon in the 

sample. The carbon dioxide is 

measured using a non-dispersive 

infrared detector.

A.7.54 0.2 mg/L A.7.55 ±20%A.7.56 Quadruplicate analyses, daily 

calibration

A.7.57 Dissolved Organic

Carbon (DOC)

A.7.58 SW846 9060A or equivalent

A.7.59 Total organic carbon is converted to 

carbon dioxide by chemical 

oxidation of the organic carbon in the 

sample. The carbon dioxide is 

measured using a non-dispersive 

infrared detector.

A.7.60 0.2 mg/L A.7.61 ±20%A.7.62 Quadruplicate analyses, daily 

calibration

A.7.63 Volatile Organic 

Analysis (VOA)

A.7.64 SW846 8260B or equivalent

A.7.65 Purge and Trap GC/MS

A.7.66 0.3 to 15 A.7.67μg/L ±20%A.7.68 Blanks, LCS, spike, spike

A.7.69 1 duplicate per batch of 20

A.7.70 Methane A.7.71 RSK 175 Mod

A.7.72 Headspace GC/FID

A.7.73 10 μg/L A.7.74 ±20%A.7.75 Blanks, LCS, spike, spike

A.7.76 1 duplicate per batch of 20

A.7.77 Stable Carbon Isotopes 

13/12C (113C) of DIC in 

Water

A.7.78 Gas Bench for 13/12C A.7.79 50 ppm of 

DIC

A.7.80 ±0.2p A.7.81 Duplicates and working 

standards at 10%
A.26 

Table A.7. (contd) 

Parameter Analysis Method

Detection 

Limit or 

Range

Typical 

Precision/ 

Accuracy QC Requirements

A.7.82 Radiocarbon 14C of DIC 

in Water

AMS for 14C A.7.83 Range: 0 to

200 pMC

A.7.84 ±0.5 pMC A.7.85 Duplicates and working 

standards at 10%

A.7.86 Hydrogen and Oxygen 

Isotopes 2/1H (δ) and 

18/16O (118O) of Water

A.7.87 CRDS H2O Laser A.7.88 Range: -

500‰ to 

200‰ vs. 

VSMOW

A.7.89 2/1H: ±2.0‰

A.7.90 18/16O: 

±0.3‰

A.7.91 Duplicates and working 

standards at 10%

A.7.92 Carbon and Hydrogen 

Isotopes (14C, 13/12C, 

2/1H) of Dissolved 

Methane in Water

A.7.93 Offline Prep & Dual Inlet IRMS for 

13C; AMS for 14C

A.7.94 14C Range: 0 

& DupMC

A.7.95 14C: 

±0.5pMC

A.7.96 13C: ±0.2‰

A.7.97 2/1H: ±4.0‰

A.7.98 Duplicates and working

standards at 10%

A.7.99 Compositional Analysis 

of Dissolved Gas in 

Water (including N2, 

CO2, O2, Ar, H2, He, 

CH4, C2H6, C3H8, 

iC4H10, nC4H10, iC5H12, 

nC5H12, and C6+)

A.7.100 Modified ASTM 1945D A.7.101 1 to 100 ppm 

(analyte 

dependent)

A.7.102 Varies by 

component

Duplicates and working 

standards at 10%

A.7.103 Radon (

222

Rn)A.7.104 Liquid scintillation after preconcentration

A.7.105 5 mBq/L A.7.106 ±10%A.7.107 Triplicate analyses

A.7.108 pH A.7.109 pH electrode A.7.110 2 to 12 pH 

units

A.7.111 0.2 pH unit 

For 

indication 

only

A.7.112 User calibrate, follow 

manufacturer 

recommendations

A.7.113 SpecificConductance A.7.114 Electrode A.7.115 0 to 100 

mS/cm

A.7.116 1% of 

reading

For 

indication 

only

A.7.117 User calibrate, follow 

manufacturer 

recommendations

A.7.118 ICP-AES = inductively coupled plasma atomic emission spectrometry; ICP-MS = inductively coupled plasma mass 

spectrometry; LCS = laboratory control sample; GC/MS = gas chromatography–mass spectrometry; GC/FID = gas 

chromatography with flame ionization detector; AMS = accelerator mass spectrometry; CRDS = cavity ring down 

spectrometry; IRMS = isotope ratio mass spectrometry; LC-MS = liquid chromatography-mass spectrometry; ECD = electron 

capture detector

Table A.8. Required Minimum Specifications for Real-Time Parameter Measurements 

Parameter Range Resolution Accuracy Additional Requirements

Pressure 0 – 2000 psi 0.05 psi ±2 psi Calibration per manufacturer 

recommendations

Temperature 50 – 120 °F 0.1 °F ±2 °F Calibration per manufacturer 

recommendations

Specific 

Conductance

0 – 85 mS/cm 0.002 mS/cm ±0.01 mS/cm Calibration during sampling events
A.27 

Table A.9. Indirect Geophysical Monitoring Requirements 

Analytical 

Parameter

Analytical 

Method #

Detection Limit or 

(Range)

Typical 

Precision/Accuracy QC Requirements

Sigma neutron 

capture cross 

section

PNC Dependent on 

formation and well 

completion. 

Salinity >40

Kppm; porosity 

>0.10 

0.5 c.u. Manufacturer calibration and 

periodic recalibration

Carbon/Oxygen 

inelastic 

PNC Dependent on 

formation and well 

completion. 

Porosity >0.15;

Dependent on log 

time. Requires slow 

(5−8 ft/min) logging 

speed

Manufacturer calibration and 

periodic recalibration

Temperature Temperature 

logging

0-350 °F 0.2 °F Manufacturer calibration and 

periodic recalibration

Gamma Gamma-ray 

logging

NA 1 count/API Manufacturer calibration and 

periodic recalibration

Velocity Passive seismic: 

geophone

145 dB; 1−350 Hz 10-7 m/s Manufacturer calibration and 

periodic recalibration

Velocity Passive seismic: 

seismometer

165dB ; 0.01−150

Hz

10-9 m/s Manufacturer calibration and 

periodic recalibration

Acceleration Passive seismic: 

force balance 

accelerometer

155 dB; DC-200

Hz

10-6 m/s

2 Manufacturer calibration and 

periodic recalibration

Acceleration Passive seismic: 

fiber-optic 

accelerometer

0.01−2000 Hz < 5. 10-7 m/s

2

/ √Hz Manufacturer calibration

Position Integrated 

deformation: GPS

NA 5 mm+1 ppm horiz.; 

10 mm +1 ppm vert.

Manufacturer calibration and 

periodic recalibration

Deformation Integrated 

deformation: 

DInSAR

NA <10 mm Space Agency calibration

Acceleration Time-lapse gravity NA 10-8 m/s

2

(10-6 Gal) Manufacturer calibration and 

periodic recalibration

A.8 Special Training/Certifications 

Wireline logging, indirect geophysical methods, and some non-routine sampling will be performed by 

trained, qualified, and certified personnel, according to the service company’s requirements. The 

subsequent data will be processed and analyzed according to industry standards (Appendix A). 

Routine injectate and groundwater sampling will be performed by trained personnel; no specialized 

certifications are required. Some special training will be required for project personal, particularly in the 

areas of PNC logging, certain geophysical methods, certain data-acquisition/transmission systems, and 

certain sampling technologies. 

Training of project staff will be conducted by existing project personnel knowledgeable in projectspecific sampling procedures. Training documentation will be maintained as project QA records. 
A.28 

A.9 Documentation and Records 

The Class VI Rule requires that the owner or operator submit the results of testing and monitoring as part 

of the required semi-annual reports (40 CFR 146.91(a)(7)). These reports will follow the format and 

content requirement specified in the final permit, including required electronic data formats. 

All data are managed according to the Project Data Management Plan (Bryce et al. 2013). All project 

records are managed according to the project records management requirements. All data and project 

records will be stored electronically on secure servers and routinely backed-up. 

The FutureGen CO2 Pipeline and Storage Facility PM (assisted by the QEngineer) will be responsible for 

ensuring that all affected project staff (as identified in the distribution list) have access to the current 

version of the approved QASP. 
B.1 

B. Data Generation and Acquisition 

The primary goal of testing and monitoring activities is to verify that the Morgan County carbon dioxide 

(CO2) storage site is operating as permitted and is not endangering any underground sources of drinking 

water (USDWs). To this end, the primary objectives of the testing and monitoring program are to track 

the lateral extent of supercritical carbon dioxide (scCO2) within the target reservoir; characterize any 

geochemical or geomechanical changes that occur within the reservoir, caprock, and overlying aquifers; 

monitor any change in land-surface elevation associated with CO2 injection; determine whether the 

injected CO2 is effectively contained within the reservoir; and detect any adverse impact on USDWs. 

This element of the Quality Assurance and Surveillance Plan (QASP) addresses data-generation and datamanagement activities, including experimental design, sampling methods, sample handling and custody, 

analytical methods, quality controls, and instrumentation/equipment specific to each testing and 

monitoring method. It should be noted that not all of these QASP aspects are applicable to all testing and 

monitoring methods. Other QASP aspects, such as inspection/acceptance of supplies and consumables 

(Section B.12), non-direct measurements (e.g., existing data) (Section B.13), and data management 

(Section B.14), are applicable to all techniques and are discussed separately. 

Well testing and monitoring activities are broken into eight main categories/subtasks, as listed below. 

1. CO2 Injection Stream Analysis – includes CO2 injection stream gas sampling and chemical 

analyses. See Section B.1. 

2. Continuous Recording of Injection Pressure, Rate, and Volume, and Annulus Pressure. See 

Section B.2. 

3. Corrosion Monitoring – includes sampling and analysis of corrosion coupons. See Section B.3. 

4. Groundwater Quality Monitoring – includes formation fluid sampling within the Ironton 

Sandstone (Above Confining Zone) and St. Peter Sandstone (lowermost USDW) and subsequent 

geochemical analyses, as well as continuous monitoring of indicator parameters. See 

Section B.4. 

5. External Mechanical Integrity Testing – includes temperature logging and pulsed-neutron capture 

(PNC) logging (both gas-view and oxygen-activation mode), as well as cement-evaluation and 

casing inspection logging. See Section B.5. 

6. Pressure Fall-Off Testing. See Section B.6. 

7. Direct CO2 Plume and Pressure-Front Tracking − includes all formation fluid sampling within the 

Mount Simon Sandstone, as well as continuous monitoring of pressure, temperature, and fluid 

specific conductance. See Section B.7. 

8. Indirect CO2 Plume and Pressure-Front Tracking – includes PNC logging, passive seismic 

monitoring, integrated deformation monitoring, and time-lapse gravity. Optional supplementary 

methods may include three-dimensional (3D) multicomponent surface seismic, and 

multicomponent vertical seismic profiling. See Sections B.8 through B.11. 

B.1 Carbon Dioxide Stream Analysis 

The Alliance will conduct injection stream analysis to meet the requirements of 40 CFR 146.90(a). This 

section describes the experimental design, sampling methods, sample handling and custody, analytical 

methods, quality controls, and instrumentation/equipment specific to CO2 stream analysis monitoring 
B.2 

activities. Refer to Sections B.12 through B.14 for general descriptions of material inspection/acceptance 

methods, non-direct measurements (e.g., existing data), and data management. 

B.1.1 Sampling Process Design (Experimental Design) 

Based on the anticipated composition of the CO2 stream, a list of parameters has been identified for 

analysis. Samples of the CO2 stream will be collected regularly (e.g., quarterly) for chemical analysis. 

Table B.1. Parameters and Frequency for CO2 Stream Analysis 

Parameter/Analyte Frequency

Pressure Continuous

Temperature Continuous

CO2 (%) quarterly

Water (lb/mmscf) quarterly

Oxygen (ppm) quarterly

Sulfur (ppm) quarterly

Arsenic (ppm) quarterly

Selenium (ppm) quarterly

Mercury (ppm) quarterly

Argon (%) quarterly

Hydrogen Sulfide (ppm) quarterly

B.1.2 Sampling Methods 

Grab samples of the CO2 stream will be obtained for analysis of gases, including CO2, O2, H2S, Ar, and 

water moisture. Samples of the CO2 stream will be collected from the CO2 pipeline at a location where 

the material is representative of injection conditions. A sampling station will be installed in the ground or 

on a structure close to the pipeline and connected to the pipeline via small-diameter stainless steel tubing 

to accommodate sampling cylinders that will be used to collect the samples. A pressure regulator will be 

used to reduce the pressure of the CO2 to approximately 250 psi so that the CO2 is collected in the gas 

state rather than as a supercritical liquid. Cylinders will be purged with sample gas (i.e., CO2) prior to 

sample collection to remove laboratory-added helium gas and ensure a representative sample. 

B.1.3 Sample Handling and Custody 

Samples will be transported to the Monitoring, Verification, and Accounting (MVA) laboratory space in 

the control building for processing, packaging, and shipment to the contracted laboratory, following 

standard sample handling and chain-of-custody guidance (EPA 540-R-09-03, or equivalent). 

B.1.4 Analytical Methods 

Analytical methods are listed in Table A.5 

B.1.5 Quality Control 

A wide variety of monitoring data will be collected specifically for this project, under appropriate quality 

assurance (QA) protocols. Data QA and surveillance protocols will be designed to facilitate compliance 

with requirements specified in 40 CFR 146.90(k). 
B.3 

B.1.6 Instrument/Equipment Testing, Inspection, and Maintenance

For sampling, field equipment will be maintained, serviced, and calibrated per manufacturers’ 

recommendations. Spare parts that may be needed during sampling will be included in supplies on-hand 

during field sampling. 

For all laboratory equipment, testing, inspection, and maintenance will be the responsibility of the 

analytical laboratory per method-specific protocols and the laboratory’s QA program, which will be 

reviewed by the Alliance prior to contract award. 

B.1.7 Instrument/Equipment Calibration and Frequency

Calibration of all laboratory instrumentation/equipment will be the responsibility of the analytical 

laboratory per method-specific protocols and the laboratory’s QA program, which will be reviewed by the 

Alliance prior to contract award.

B.2 Continuous Recording of Injection Pressure, Rate, Volume, and Annulus Pressure 

This section describes the experimental design, sampling methods, sample handling and custody, 

analytical methods, quality controls, and instrumentation/equipment specific to continuous monitoring of 

injection parameters. Refer to Sections B.12 through B.14 for general descriptions of material 

inspection/acceptance methods, non-direct measurements (e.g., existing data), and data management. 

B.2.1 Sampling Process Design (Experimental Design) 

The Alliance will conduct continuous monitoring of injection parameters to meet the requirements of 40 

CFR 146.90(b). These activities include continuous recording of injection pressure, temperature, flow 

rate, and volume, as well as the annulus pressure. 

B.2.2 Sampling Methods 

Continuous Recording of Injection Pressure and Temperature

An electronic P/T gauge will be installed on the outside of the tubing string, approximately 30 ft above 

the packer, and ported into the tubing to continuously measure CO2 injection P/T inside the tubing at this 

depth. Mechanical strain gauges and thermocouples will be the primary monitoring devices for pressure 

and temperature. 

Injection P/T will also be continuously measured at the surface via real-time P/T instruments installed in 

the CO2 pipeline near the pipeline interface with the wellhead. The P/T of the injected CO2 will be 

continuously measured for each well. The pressure will be measured by electronic pressure transmitter 

with analog output mounted on the CO2 line associated with each injection well. The temperature will be 

measured by an electronic temperature transmitter mounted in the CO2 line at a location near the pressure 

transmitter, and both transmitters will be located near the wellhead. The transmitters will be connected to 

the Annulus Pressurization System (APS) programmable logic controller (PLC) located in the Control 

Building adjacent to the injection well pad. 
B.4 

Continuous Recording of Injection Mass Flow Rate 

The mass flow rate of CO2 injected into the well field will be measured by a flow meter skid with a 

Coriolis mass flow transmitter for each well. Each meter will have analog output (Micro Motion Coriolis 

Flow and Density Meter Elite Series or similar). A total of six flow meters will be supplied, providing for 

two spare flow meters to allow for flow meter servicing and calibration. Valving will be installed to 

select flow meters for measurement and for calibration. A single flow prover will be installed to calibrate 

the flow meters, and piping and valving will be configured to permit the calibration of each flow meter. 

The flow transmitters will each be connected to a remote terminal unit (RTU) on the flow meter skid. 

The flow meters will be connected to the main CO2 storage site SCADA system for continuous 

monitoring and control of the CO2 injection rate into each well. The flow rate into each well will be 

controlled using a flow-control valve located in the CO2 pipeline associated with each well. The control 

system will be programmed to provide the desired flow rate into three of the four injection wells, with the 

fourth well receiving the balance of the total flow rate. 

B.2.3 Sample Handling and Custody 

No specialized sample/data handling procedures are required. Electronic sensor data (e.g., pressure data) 

will be networked through the local-area fiber-optic network using Ethernet network interfaces back to 

data-acquisition systems located in the MVA data center. 

Electronic data and field records will be transferred to laptop and/or desktop computers and/or backed-up 

on secured servers at least quarterly, as well as scanned copies of all pertinent hardcopy field 

records/notes. 

B.2.4 Analytical Methods 

Continuously recorded injection parameters will be reviewed and interpreted on a regular basis, to

evaluate the injection stream parameters against permit requirements. Trend analysis will also help 

evaluate the performance (e.g., drift) of the instruments, suggesting the need for maintenance or 

calibration. 

B.2.5 Quality Control 

Continuous monitoring equipment will be calibrated according to the manufacturers’ recommendations. 

If trends or other unexplained variability in the data are observed that might indicate a suspect response, 

instruments will be evaluated and, if required, recalibrated or replaced. 

B.2.6 Instrument/Equipment Testing, Inspection, and Maintenance

The surface instruments will be maintained according to manufacturers’ recommendations; however, if 

data trends indicate a suspect response, instruments will be evaluated and, if required, recalibrated or 

replaced. 

B.2.7 Instrument/Equipment Calibration and Frequency

Because the bottom-hole P/T gauge will be attached to the tubing string, the gauge will be recalibrated or 

replaced only when the injection well tubing string is pulled, which would occur only if warranted by a 
B.5 

downhole issue that can only be addressed by performing a well workover. The surface P/T instruments 

will be calibrated according to manufacturers’ recommendations. 

B.3 Corrosion Monitoring 

This section describes the experimental design, sampling methods, sample handling and custody, 

analytical methods, quality controls, and instrumentation/equipment specific to corrosion-monitoring 

activities. Refer to Sections B.12 through B.14 for general description of material inspection/acceptance 

methods, non-direct measurements (e.g., existing data), and data management. 

B.3.1 Sampling Process Design (Experimental Design) 

The Alliance will conduct corrosion monitoring of well materials to meet the requirements of 40 CFR 

146.90(c). Corrosion-monitoring activities are designed to monitor the integrity of the injection wells 

throughout the operational period. This includes using corrosion coupons as well as periodic cementevaluation and casing inspection logs when tubing is removed from the well (i.e., during well workovers). 

Corrosion coupons will be made of the same materials as the long string of casing and the injection 

tubing, and will be placed in the CO2 pipeline for ease of access. 

B.3.2 Sampling Methods 

Corrosion monitoring will include corrosion coupons as well as periodic cement-evaluation and casing 

inspection logs. 

Corrosion Coupon Monitoring 

Corrosion coupons will be made of the same material as the long string of casing and the injection tubing 

and placed in the CO2 injection pipeline. The coupons will be removed quarterly and assessed for 

corrosion using the ASTM International (ASTM) G1-03, Standard Practice for Preparing, Cleaning, and 

Evaluating Corrosion Test Specimens (ASTM 2011). Upon removal, coupons will be inspected visually 

for evidence of corrosion (e.g., pitting). The weight and size (thickness, width, length) of the coupons 

will also be measured and recorded each time they are removed. The corrosion rate will be calculated as 

the weight loss during the exposure period divided by the duration (i.e., weight loss method). 

Cement-evaluation and Casing Inspection Logging 

Cement-evaluation and casing inspection logs will be run periodically, on an opportunistic basis, 

whenever tubing is removed from the well (i.e., during well workovers). See Section B.5 on external 

mechanical integrity testing. 

B.3.3 Sample Handling and Custody 

Corrosion monitoring will include corrosion coupons as well as periodic cement-evaluation and casing 

inspection logs. No specialized sample handling or chain-of-custody procedures are needed. The 

coupons will be removed from the pipeline, then taken to the nearby mobile lab (field trailer) where they 

will be cleaned, inspected, weighed, and measured. They will be immediately returned to the pipeline. 

Cement-evaluation and casing inspection log data will be handled using best management practices. See 

Section B.5 on external mechanical integrity testing. 
B.6 

B.3.4 Analytical Methods 

The corrosion coupons will be cleaned, inspected visually for evidence of corrosion (e.g., pitting), 

weighed, and measured each time they are removed (ASTM G1-03, Standard Practice for Preparing, 

Cleaning, and Evaluating Corrosion Test Specimens). The corrosion rate will be calculated as the weight 

loss during the exposure period divided by the duration (i.e., weight loss method).

See Section B.5 on external mechanical integrity testing for cement-evaluation and casing inspection 

logging analytical methods.

B.3.5 Quality Control 

Two groups of four replicate corrosion coupons of each material type will be placed in proximity to each 

other within two different locations within the CO2 injection pipeline. A third group of four replicate 

samples of each material type will placed in proximity to each other within a simulated injection pipeline 

as a control (not exposed to CO2). All samples will be removed quarterly and subjected to the same 

visual and measurement methodologies. This approach will allow an evaluation of the potential spatial 

variability in corrosion rates within the injection tubing, as well as the natural variability between coupon 

samples. Corrosion rates (calculated as the weight loss during the exposure period divided by the 

duration, i.e., weight loss method) and statistical analyses (e.g., t-test) will be independently reviewed and 

documented. 

See Section B.5 on external mechanical integrity testing for cement-evaluation and casing inspection 

logging quality control methods.

B.3.6 Instrument/Equipment Testing, Inspection, and Maintenance

Equipment and instrumentation for visual inspection and measurement of the corrosion coupons will 

consist of materials to clean corrosion products off the coupons as well as equipment and instrumentation 

for visual inspection and measurement in accordance with ASTM G1-03. Key inspection and 

measurement equipment may include calipers, an analytical balance (e.g., electronic scale), and a lowpower microscope or hand lens (e.g., 7X to 30X). The analytical balance should be able to measure to 

with + or -0.2 to 0.02 mg. Calipers should be able to measure to about 1% of the area measured (ASTM 

G1-03). 

Maintenance (e.g., charging, batteries, etc.) and instrument checks will be performed quarterly, prior to 

each sampling event. All equipment and materials will be visually inspected for damage, calibration 

dates, battery life, etc. prior to use. Fresh batteries and backup equipment/instrumentation will be stored 

in the mobile lab/field trailer. 

See Section B.5 on external mechanical integrity testing for instrumentation and equipment testing, 

inspection, and maintenance relative to cement-evaluation and casing inspection logging.

B.3.7 Instrument/Equipment Calibration and Frequency 

Calipers, analytical balances, and other measuring and testing instrumentation will be calibrated by the 

manufacturer, according to its recommended procedures and frequencies. See Section B.5 on external 

mechanical integrity testing for instrumentation and equipment calibration relative to cement-evaluation 

and casing inspection logging.
B.7 

B.4 Groundwater Quality Monitoring (ACZ and USDW wells) 

This section describes the experimental design, sampling methods, sample handling and custody, 

analytical methods, quality controls, and instrumentation/equipment specific to groundwater quality 

monitoring activities. Refer to Sections B.12 through B.14 for general description of material 

inspection/acceptance methods, non-direct measurements (e.g., existing data), and data management. 

B.4.1 Sampling Process Design (Experimental Design) 

The Alliance will conduct ground-water-quality/geochemical monitoring above the confining zone to 

meet the requirements of 40 CFR 146.90(d). 

The planned groundwater quality monitoring well network layout, number of wells, well design, and 

sampling regimen are based upon site-specific characterization data, and consider structural dip, the 

locations of existing wells, expected ambient flow conditions, and the potential for heterogeneities or 

horizontal/vertical anisotropy within the overburden materials (see also Section A.6.2). The planned 

monitoring network consists of two wells within the first permeable interval immediately above the 

primary confining zone (Ironton Sandstone), and one well within the lowermost USDW (St. Peter 

Sandstone) (Figure A.3). The above confining zone (ACZ) wells will be completed in the Ironton 

Sandstone and monitor for changes in pressure, groundwater chemistry, indicator parameters, and 

microseismicity. The ACZ monitoring interval is located immediately above the primary confining zone. 

One of these wells will be located ~1,000 ft west of the injection site adjacent to the western injection 

lateral; the other will be located ~1,500 ft west of the western injection lateral terminus. The USDW well 

(USDW1) will be installed at the base of the St. Peter Sandstone to monitor the groundwater quality of 

the lowermost USDW. 

The Alliance plans to conduct periodic fluid sampling as well as continuous pressure, temperature, and 

specific conductance (P/T/SpC) monitoring throughout the injection phase in the two ACZ monitoring 

wells and the USDW well. (Table A.3 lists the parameters and instrumentation that will be used at each 

of the ACZ and USDW monitoring wells. Minimum specifications for the planned continuous 

measurements are listed in Table A.8.) 

The Alliance will also conduct baseline surficial aquifer sampling in the shallow, semi-consolidated 

glacial sediments, using approximately nine local landowner wells and one well drilled for the project. 

Because near-surface environmental impacts are not expected, surficial aquifer (<100 ft bgs) monitoring 

will only be conducted for a sufficient duration to establish baseline conditions (minimum of three 

sampling events). Surficial aquifer monitoring is not planned during the injection phase; however, the 

need for additional surficial aquifer monitoring will be continually evaluated throughout the operational 

phases of the project, and may be reinstituted if conditions warrant. 

B.4.2 Sampling Methods 

Fluid samples will be collected at monitored formation depths and maintained at formation pressures 

within a closed pressurized sample container to prevent the escape of dissolved gases. Access to the 

monitored intervals at the ACZ and USDW monitoring wells will be through the 5-1/2-in. casing that is 

cemented into the borehole. 

Aqueous samples will be collected from each monitoring well, initially on a quarterly basis and later less 

frequently, to determine the concentration of CO2 and other constituents in the monitoring interval fluids. 

The fluid samples will be collected within the open interval of each monitoring well using a flow-through 
B.8 

sampler with a 950-cc (or larger) sample chamber. The samples will be maintained at formation pressure 

within a closed sample container to prevent the escape of dissolved gases. Prior to sampling, the P/T/SpC 

probe will be monitored as the well is purged (up to three times the volume of the well-screen section will 

be discharged from the well before collecting the sample). The probe will then be removed from the well 

and the sampler will be run into the borehole on the same wireline cable to collect the pressurized fluid 

sample. Additional purging may be conducted just prior to collection of the pressurized fluid sample if 

mixing between the fluid column and sampling interval during insertion of the sampler is a concern. 

B.4.3 Sample Handling and Custody 

After removing the sampler from the well, the closed and pressurized sample container(s) will be 

transported to the MVA laboratory space in the control building for processing following standard chainof-custody procedures. 

B.4.4 Analytical Methods 

The analytical methods for groundwater quality monitoring in the ACZ and USDW wells are summarized 

in Table A.7.. Where possible, methods are based on standard protocols from EPA or Standard Methods 

for the Examination of Water and Wastewater (American Public Health Association, American Water 

Works Association, Water Environment Federation, 19th edition or later, Washington, D.C.). 

Laboratories shall have standard operating procedures for the analytical methods performed. 

B.4.5 Quality Control 

The quality control (QC) elements in this section are used to help evaluate whether groundwater samples 

are free of contamination and whether the laboratories performed the analyses within acceptable accuracy 

and precision requirements. Several types of field and laboratory QC samples are used to assess and 

enhance data quality (Table B.2) 

Table B.2. Quality Control Samples 

Field QC

Sample Type Primary Characteristic Evaluated Frequency

Trip Blank Contamination from containers or transportation 1 per sampling event

Field Duplicates Reproducibility 1 per sampling event

Laboratory QC

Sample Type Primary Characteristic Evaluated Frequency

Method Blank Laboratory contamination 1 per batch

Lab Duplicate Laboratory reproducibility (a)

Matrix Spike Matrix effects and laboratory accuracy (a)

Matrix Spike Duplicate Laboratory reproducibility/accuracy (a)

Laboratory Control Sample Method accuracy 1 per batch

(a) As defined in the laboratory contract and analysis procedures (typically 1 per 10 samples). 

Field QC samples consist of trip blanks and duplicate samples. Trip blanks are preserved sample bottles 

that are filled with deionized water and transported unopened to the field in the same storage container 

that will be used for samples collected that day. Trip blanks evaluate bottle cleanliness, preservative 

purity, equipment decontamination, and proper storage and transport of samples. The frequency of 

collection for trip blanks is one per sampling event. Field duplicates are replicate samples that are 

collected at the same well. After each type of bottle is filled, a second, identical bottle is filled for each 

type of analysis. Both sets of samples are stored and transported together. Field duplicates provide 
B.9 

information about sampling and analysis reproducibility. The collection frequency for field duplicates is 

one per sampling event. 

Laboratory QC samples include method blanks, laboratory duplicates, matrix spikes, matrix spike 

duplicates, and laboratory control samples (defined below). These samples are generally required by EPA 

method protocols. Frequencies of analysis are specified in Table B.2 and in the laboratories’ standard 

operating procedures. 

 Method blank – an analyte-free matrix to which all reagents are added in the same volumes or 

proportions as used in sample processing. The method blank is carried through the complete 

preparation and analysis process. Method blanks are used to quantify contamination from the 

analytical process. 

 Laboratory duplicate – an intra-laboratory split sample that is used to evaluate the precision of a 

method in a given sample matrix. 

 Matrix spike – an aliquot of a sample that is spiked with a known concentration of target 

analytes(s). The matrix spike is used to assess the bias of a method in a given sample matrix. 

Spiking occurs prior to sample preparation and analysis. 

 Matrix spike duplicate – a replicate spiked aliquot of a sample that is subjected to the entire 

sample preparation and analytical process. Matrix spike duplicate results are used to determine the 

bias and precision of a method in a given sample matrix. 

 Laboratory control sample – a control matrix (typically deionized water) spiked with analytes 

representative of the target analytes or a certified reference material that is used to evaluate 

laboratory accuracy. 

Besides these measures, the laboratories maintain internal QA programs and are subject to internal and 

external audits. 

B.4.6 Instrument/Equipment Testing, Inspection, and Maintenance 

For groundwater sampling, field equipment will be maintained, serviced, and calibrated according to the 

manufacturers’ recommendations. Spare parts that may be needed during sampling will be included in 

supplies on-hand during field sampling. 

For all laboratory equipment, testing, inspection, and maintenance will be the responsibility of the 

analytical laboratory according to method-specific protocols and the laboratory’s QA program, which will 

be reviewed by the Alliance prior to contract award.

B.4.7 Instrument/Equipment Calibration and Frequency

Calibration of all laboratory instrumentation/equipment will be the responsibility of the analytical 

laboratory according to method-specific protocols and the laboratory’s QA program, which will be 

reviewed by the Alliance prior to contract award.

B.5 External Mechanical Integrity Testing

This section describes the experimental design, sampling methods, sample handling and custody, 

analytical methods, quality controls, and instrumentation/equipment specific to external mechanical 
B.10 

integrity testing (MIT) activities. Refer to Sections B.12 through B.14 for general descriptions of material 

inspection/acceptance methods, non-direct measurements (e.g., existing data), and data management. 

B.5.1 Sampling Process Design (Experimental Design) 

The Alliance will conduct external MIT to meet the requirements of 40 CFR 146.90(e). These tests are 

designed to include temperature logging, PNC logging, and cement-evaluation logging. An initial 

(baseline) temperature and PNC logs will be run on the well after well construction but prior to 

commencing CO2 injection. These baseline log(s) will serve as a reference for comparing future 

temperature and PNC logs for evaluating external mechanical integrity. 

Temperature Logging 

Temperature logs can be used to identify fluid movement along channels adjacent to the well bore. In 

addition to identifying injection-related flows behind casing, temperature logs can often locate small 

casing leaks. Injection of CO2 will have a cooling or heating effect on the natural temperature in the 

storage reservoirs, depending on the temperature of the injected CO2 and other factors. Once injection 

starts, the flowing temperature will stabilize quickly (assuming conditions remain steady). 

When an injection well is shut-in for temperature logging, the well bore fluid begins to revert toward 

ambient conditions. Zones that have taken injectate, either by design or not, will exhibit a “storage” 

signature on shut-in temperature surveys (storage signatures are normally cold anomalies in deeper wells, 

but may be cool or hot depending on the temperature contrast between the injectate and the reservoir). 

Losses behind pipe from the injection zone can be detected on both flowing and shut-in temperature 

surveys and exhibit a “loss” signature. 

For temperature logging to be effective for detecting fluid leaks, there should be a contrast in the 

temperature of the injected CO2 and the reservoir temperature. The greater the contrast in the CO2 when 

it reaches the injection zone and the ambient reservoir temperature, the easier it will be to detect 

temperature anomalies due to leakage behind casing. Based on data from the stratigraphic well, ambient 

bottom-hole temperatures in the Mount Simon Sandstone are expected to be approximately 100°F; the 

temperature of the injected CO2 is anticipated to be on the order of 72°F to 90°at the surface (depending 

on time of year) but will undergo some additional heating as it travels down the well. After the baseline 

(i.e., prior to injection) temperature log has been run to determine ambient reservoir temperature in each 

well, it will be possible to determine whether there will be sufficient temperature contrast to make the 

temperature log an effective method for evaluating external mechanical integrity. 

The Alliance will consult the EPA Region 5 guidance for conducting temperature logging (EPA 2008) 

when performing this test. 

Oxygen-Activation Logging 

Oxygen activation is a geophysical logging technique that uses a PNC tool to quantify the flow of water 

in or around a borehole. For purposes of demonstrating external mechanical integrity, a baseline oxygen 

activation will be run prior to the start of CO2 injection and compared to later runs to determine changing 

fluid flow conditions adjacent to the well bore (i.e., formation of channels or other fluid isolation 

concerns related to the well). 
B.11 

The PNC tool emits high-energy neutrons that interact with water molecules present in the casingformation annular space, among others. This temporarily activates oxygen (16O) to produce an isotope of 

nitrogen (16N) that decays back to oxygen with a half-life of 7.1 seconds and emits an easily detected 

gamma ray. Typical PNC tools have two or three gamma-ray detectors (above and below the neutron 

source) to detect the movement of the activated molecules, from which water velocity can then be 

calculated. The depth of investigation for oxygen-activation logging is typically less than 1 ft; therefore, 

this log type provides information immediately adjacent to the well bore. 

Repeat runs will be made under conditions that mimic baseline conditions (e.g., similar logging speeds 

and tool coefficients) as closely as possible to ensure comparability between baseline and repeat data. 

The Alliance will consult the EPA Region 5 guidance for conducting the oxygen-activation logging (EPA 

2008) when performing this test. 

In addition to oxygen activation logging, the PNC tool will also be run in thermal capture cross-section 

(sigma) mode to detect the presence of CO2 outside the casing. 

PNC logging will be the primary method used to evaluate the external mechanical integrity of the 

injection wells.

Cement-Evaluation Logging 

Cement evaluation beyond the preliminary cement-bond log is not required for Class VI wells under MIT 

or corrosion monitoring (40 CFR 146.89 and 146.90). However, it is recognized that cement integrity 

over time can influence the mechanical integrity of an injection well. Therefore, cement-evaluation logs 

will be run when tubing is removed from the well (i.e., during well workovers that involve removing the 

tubing string). Some cement-evaluation logs are also capable of providing information about the 

condition of the casing string, such as wall thickness and inside diameter (e.g., Schlumberger isolation 

scanner tool).

B.5.2 Sampling Methods 

PNC logging will be the primary method used to evaluate the external mechanical integrity of the 

injection wells (EPA requires annual MIT demonstrations). PNC and temperature logging will be 

conducted on an opportunistic basis, for example, when each well is taken out of service. Temperature 

and PNC logging will be performed through the tubing and therefore will not require removal of the 

tubing and packer from the well. However, the cement-evaluation and casing-evaluation logging will be 

conducted only when tubing is removed from the well as this cannot be performed through tubing.

B.5.3 Sample Handling and Custody 

No specialized sample/data handling procedures are required. Logging data will be recorded on a 

computer located in the wireline logging truck. All electronic data and field records will be transferred to 

laptop and/or desktop computers and backed-up on secure servers at the conclusion of each logging event, 

as will scanned copies of all pertinent hardcopy field records/notes. 

B.5.4 Analytical Methods 

Wireline log data will be processed following industry best practices and coordinated with the boreholelogging operator to optimize data-collection parameters. Modeling can be done to simulate near-borehole 
B.12 

interferences and remove their effects from the signal. Modeling is a recommended procedure and 

requires knowledge of the target formations and fluids that must be obtained from cores and additional 

logging data. Each logging result will be compared for each well to the baseline or previous survey, as 

applicable, to determine changes. 

B.5.5 Quality Control 

Verification of vendor processing software and results will ensure that the acquired data are acceptable 

and are reproducible. Third-party logging and processing for a subset of boreholes and logging events 

can be used as part of the validation procedure. Failure of tool performance in the field or unreproducible 

“repeat sections” will result in non-acceptance of the data, and may trigger a return of the wireline tool to 

the manufacturer for recalibration or replacement. Off-normal results/comparisons to baseline will trigger 

additional evaluation and possible new logging runs.

B.5.6 Instrument/Equipment Testing, Inspection, and Maintenance

Examples of industry-published guidelines for calibration and field operation of the pulsed-neutron 

capture (PNC) wireline log hardware and data-collection software are provided in Appendix A.

B.5.7 Instrument/Equipment Calibration and Frequency

To ensure data acquisition quality, each logging tool will be calibrated for accuracy, checked to be in 

good working order, and verified by the manufacturer. All tools and field operation software will be 

provided by the manufacturer with an auditable verification record to ensure traceability. In addition to 

the initial manufacturer calibration, tool recalibration will be performed monthly and both prior to and 

after each logging event following the manufacturer’s guidelines. Examples of industry-published 

guidelines for calibration and field operation of wireline log hardware and data-collection software are 

provided in Appendix B.

B.6 Pressure Fall-Off Testing 

This section describes the experimental design, sampling methods, sample handling and custody, 

analytical methods, quality controls, and instrumentation/equipment specific to pressure fall-off testing 

activities. Refer to Sections B.12 through B.14 for general descriptions of material inspection/acceptance 

methods, non-direct measurements (e.g., existing data), and data management. 

B.6.1 Sampling Process Design (Experimental Design) 

Pressure fall-off testing will be conducted upon completion of the injection wells to characterize reservoir 

hydrogeologic properties and aquifer response model characteristics (e.g., nonleaky vs. leaky reservoir; 

homogeneous vs. fractured media) as well as changes in near-well/reservoir conditions that may affect 

operational CO2 injection behavior in accordance with 40 CFR 146.87(e)(1). Pressure fall-off testing will 

also be conducted at least once every five (5) years after injection operations begin, or more frequently if 

required by the UIC Program Director (40 CFR 146.90 (f)). Specifically, the objective of the periodic 

pressure fall-off testing is to determine whether any significant changes in the near-wellbore conditions 

have occurred that may adversely affect well/reservoir performance (e.g., well injectivity, anomalous 

reservoir pressure behavior). Detailed descriptions for conducting and analyzing pressure fall-off tests are 

provided by the EPA (2002, 2003, and 2012). These guidelines will be followed when conducting 

pressure fall-off tests for the FutureGen 2.0 CO2 Pipeline and Storage Project. 
B.13 

B.6.2 Sampling Methods 

Controlled pressure fall-off tests are conducted by terminating injection for a designed period/duration of 

time. The pressure fall-off test is initiated by terminating injection, shutting-in the well by closing the 

surface wellhead valve(s), and maintaining continuous monitoring the surface and downhole pressure 

recovery within the well/test interval system during the fall-off/recovery period. The designed duration of 

the pressure fall-off recovery test is a function of a number of factors, including the exhibited preoperational injection reservoir test response characteristics, the injection well history prior to termination 

(i.e., injection duration, rate history), and potential pressure interference effects imposed by any 

surrounding injection wells completed within the same reservoir. Because of the potential impact of 

injection-rate variability on early-time pressure fall-off recovery behavior, the EPA (2012) recommends 

that injection rates and pressures be uniform and held relatively constant prior to initiating a pressure falloff test. 

Upon shutting-in the well, in-well pressure measurements are monitored continuously in real time, both 

downhole (within or in proximity to the injection reservoir) and at the surface wellhead location. The 

EPA (2012) recommends the use of two pressure probes at each location, with one serving as a 

verification source and the other as a backup/replacement sensor if the primary pressure transducer 

becomes unreliable or inoperative. The duration of the shut-in period used in conducting the pressure 

fall-off test should be extended sufficiently beyond wellbore storage effects and when the pressure 

recovery is indicative of infinite-acting radial flow (IARF) conditions. The establishment of IARF 

conditions is best determined by using pressure derivative diagnostic analysis plots (Bourdet et al. 1989; 

Spane 1993; Spane and Wurstner 1993), and is indicated when the log-log pressure derivative/recovery 

time plot, plots as a horizontal line. When IARF pressure fall-off conditions are indicated, the pressure 

response vs. log of fall-off/recovery time plots as a straight line on a standard semi-log plot. The EPA 

(2012) recommends a general rule-of-thumb of extending pressure fall-off tests a factor of three to five 

beyond the time required to reach radial flow conditions, while Earlougher (1977) suggests extending 

recovery periods between 1 to 1.5 log cycles beyond when the pressure response starts to deviate from 

purely wellbore storage response characteristics (i.e., a unit slope, 1:1 on a standard log-log pressure falloff recovery plot). 

For projects like FutureGen 2.0 that will use multiple injection wells completed within the same reservoir 

zone, the EPA (2012) recommends special considerations to be used for pressure fall-off testing to 

minimize the pressure response impacts from neighboring injection wells on the pressure fall-off test well 

recovery response. For the neighboring injection wells (i.e., those not being tested), the EPA (2012) 

recommends that injection at these wells either should be terminated prior to initiating the pressure falloff test for a duration exceeding the planned shut-in period, or that injection rates at the neighboring 

injection wells be held constant and continuously recorded prior to and during the fall-off recovery test. 

After completion of the fall-off test, additional large-scale areal reservoir hydraulic/storativity 

characterization information may be derived for the injection reservoir by implementing a stepped-pulse 

pressure interference signal (by significantly increasing and/or decreasing injection rates) initiated from 

the neighboring injection wells. The arrival of the observed pulsed pressure signal at the fall-off test well 

provides information (i.e., due to arrival time and attenuation of the pressure pulse signal) about inter-well 

reservoir conditions (e.g., hydraulic diffusivity, directional lateral extent of injected CO2), particularly if 

compared to pre-injection interference test response characteristics. 
B.14 

B.6.3 Sample Handling and Custody 

No specialized sample/data handling procedures are required. Electronic sensor data (e.g., pressure data) 

will be recorded on data loggers. All electronic data and field records will be transferred to laptop and/or 

desktop computers and backed-up on secure servers at the conclusion of each test, as well as scanned 

copies of all pertinent hardcopy field records/notes. 

B.6.4 Analytical Methods 

Quantitative analysis of the pressure fall-off test response recorded following termination of injection for 

the test well provides the basis for assessing near well and larger-scale reservoir behavior. Comparison of 

diagnostic pressure fall-off plots established prior to operational injection of CO2 and periodic fall-off 

tests conducted during operational injection phases can be used to determine whether significant changes 

in well or injection reservoir conditions have occurred. Diagnostic derivative plot analysis (Bourdet et al. 

1989; Spane 1993; Spane and Wurstner 1993) of the pressure fall-off recovery response is particularly 

useful for assessing potential changes in well and reservoir behavior. 

The EPA (2002, 2003) provides a detailed discussion on the use of standard semi-log and log-log 

diagnostic and analysis procedures for pressure fall-off test interpretation. The plotting of downhole 

temperature concurrent with the observed fall-off test pressure is also useful diagnostically for assessing 

any observed anomalous pressure fall-off recovery response. Commercially available pressure gauges 

typically are self-compensating for environmental temperature effects within the probe sensor (i.e., within 

the pressure sensor housing). However, as noted by the EPA (2012), if temperature anomalies are not 

accounted for correctly (e.g., well/reservoir temperatures responding differently than registered within the 

probe sensor), erroneous fall-off pressure response results maybe be derived. As previously discussed, 

concurrent plotting of downhole temperature and pressure fall-off responses is commonly useful for 

assessing when temperature anomalies may be affecting pressure fall-off/recovery behavior. In addition, 

diagnostic pressure fall-off plots should be evaluated relative to the sensitivity of the pressure gauges used 

to confirm adequate gauge resolution (i.e., excessive instrument noise). 

Standard diagnostic log-log and semi-log plots of observed pressure change and/or pressure derivative 

plots versus recovery time are commonly used as the primary means for analyzing pressure fall-off tests. 

In addition to determining specific well performance conditions (e.g., well skin) and aquifer hydraulic 

property and boundary conditions, the presence of prevailing flow regimes can be identified (e.g., 

wellbore storage, linear, radial, spherical, double-porosity, etc.) based on characteristic diagnostic fall-off 

pressure derivative patterns. A more extensive list of diagnostic derivative plots for various formation 

and boundary conditions is presented by Horne (1990) and Renard et al. (2009). 

As discussed by the EPA (2002), early pressure fall-off recovery response corresponds to flow conditions 

within and in proximity to the well bore, while later fall-off recovery response is reflective of 

progressively more distant reservoir conditions from the injection well location. Significant divergence in 

pressure fall-off response patterns from previous pressure fall-off tests (e.g., accelerated pressure fall-off 

recovery rates) may be indicative of a change in well and/or reservoir conditions (e.g., reservoir leakage). 

A more detailed discussion of using diagnostic plot analysis of pressure fall-off tests for discerning 

possible changes to well and reservoir conditions is presented by the EPA (2002, 2003). 

As indicated by the EPA (2012), quantitative analysis of the pressure fall-off test data can be used to 

determine formation hydraulic property characteristics (e.g., permeability, transmissivity), and well skin 

factor (additional pressure change effects due to altering the permeability/storativity conditions of the 
B.15 

reservoir/well injection interval boundary). Determination of well skin is a standard result for pressure 

fall-off test analysis and is described in standard well-test analysis texts such as that by Earlougher 

(1977). Software programs are also commercially available (e.g., Duffield 2007, 2009) for analyzing 

pressure fall-off tests. Significant changes in well and reservoir property characteristics (as determined 

from pressure fall-off analysis), compared to those used in site computational modeling and AoR 

delineation, may signify a reevaluation of the AoR, as may be required by the UIC Program Director, as 

noted by the EPA (2012). 

B.6.5 Quality Control 

Periodic QC checks will be routinely made in the field, and on occasion, where permanent pressure 

gauges are used, a second pressure gauge with current certified calibration will be lowered into the well to 

the same depth as the permanent downhole gauge. 

B.6.6 Instrument/Equipment Testing, Inspection, and Maintenance

All field equipment will be visually inspected and tested prior to use. Spare instruments, batteries, etc. 

will be stored in the field support trailer. 

B.6.7 Instrument/Equipment Calibration and Frequency 

Pressure gauges that are used to conduct fall-off tests will be calibrated in accordance with 

manufacturers’ recommendations, and current calibration certificates will be provided with test results to 

the EPA. In lieu of removing the injection tubing to regularly recalibrate the downhole pressure gauges, 

their accuracy will be demonstrated by comparison to a second pressure gauge, with current certified 

calibration, that will be lowered into the well to the same depth as the permanent downhole gauge. 

Calibration curves, based on annual calibration checks (using the second calibrated pressure gauge) 

developed for the downhole gauge, can be used for the purpose of the fall-off test. If used, these 

calibration curves (showing all historic pressure deviations) will accompany the fall-off test data 

submitted to the EPA. 

B.7 Carbon Dioxide Plume and Pressure-Front Tracking 

This section describes the experimental design, sampling methods, sample handling and custody, 

analytical methods, quality controls, and instrumentation/equipment specific to CO2 plume and pressurefront tracking activities. Refer to Sections B.12 through B.14 for general descriptions of material 

inspection/acceptance methods, non-direct measurements (e.g., existing data), and data management. 

B.7.1 Sampling Process Design (Experimental Design) 

The Alliance will conduct direct and indirect CO2 plume and pressure-front monitoring to meet the 

requirements of 40 CFR 146.90(g). The planned reservoir-monitoring well network design is based on 

the Alliance’s current conceptual understanding of the site and predictive simulations of injected CO2 fate 

and transport. The number, layout, design, and sampling regimen of the monitoring wells are based upon 

site-specific characterization data collected from the stratigraphic well, as well as structural dip, expected 

ambient flow conditions, and potential for heterogeneities or horizontal/vertical anisotropy within the 

injection zone and model predictions. 

The planned monitoring well network for direct plume and pressure-front monitoring consists of two sets 

of monitoring wells: single-level in-reservoir (SLR) wells and reservoir access tube (RAT) wells (Figure 
B.16 

A.3). Two SLR wells will monitor the injection zone beyond the east and west ends of the horizontal 

CO2-injection laterals. One of the SLR wells (SLR2; reconfigured stratigraphic well) will be located to 

the east-northeast of the injection well pad between the projected 10- to 20-year plume boundaries and the 

other well (SLR1) will be located to the west of the injection well pad within the projected 2-year plume 

boundary. An additional SLR well will be constructed within 5 years from the start of injection. The 

location will be informed by any observed asymmetry in pressure front development and will be located 

outside the CO2 plume extent. The distance from the plume boundary will be based on the monitoring 

objective of providing information that will be useful for both leakage detection and model calibration 

within the early years of operation. It is estimated that the well will be located less than 5 miles from the 

projected plume extent in order to provide an intermediate-field pressure monitoring capability that would 

benefit leak detection capabilities and meet the EPA requirement for pressure monitoring outside the CO2

plume. 

Three RAT wells will be installed within the boundaries of the projected 1- to 3-year CO2 plume. The 

RAT well locations were selected to provide information about CO2 arrival at different distances from the 

injection wells and at multiple lobes of the CO2 plume. The RATs will be completed with nonperforated, 

cemented casings and will be used to monitor CO2 arrival and quantify saturation levels via downhole 

PNC (geophysical logging across the reservoir and confining zone). 

The reservoir-monitoring network will address transport uncertainties by using an “adaptive” or 

“observational” approach to monitoring (i.e., the monitoring approach will be adjusted as needed based 

on observed monitoring and updated modeling results). It is recognized that additional contingency wells 

may be required in out-years to monitor evolution of the CO2 plume and fully account for the injected 

CO2 mass. 

Direct Pressure Monitoring 

Continuous monitoring of P/T/SpC will be conducted in the SLR monitoring wells to track the pressure 

front and inform the monitoring and modeling programs. 

Instruments will be installed at each SLR monitoring well to facilitate near-continuous monitoring of 

indicator parameters of CO2 arrival and/or changes in brine composition. (Tables A.3 and A.8 list the 

parameters and instrumentation that will be used in the SLR wells.) 

Fluid P/T/SpC are the most important parameters to be measured in real time within the monitoring 

interval of each well. These are the primary parameters that will indicate the presence of CO2 or CO2-

induced brine migration into the monitored interval. In addition, pH and Eh (oxidation potential) 

measurements may be useful for detecting dissolved CO2 and assessing water chemistry changes in the 

monitored interval. An initial evaluation of probes that are capable of measuring the desired parameters 

will assess the measurement accuracy, resolution, and stability for each parameter prior to selection and 

procurement of sensors for the full monitoring well network. 

Pressure is expected to increase at the SLR monitoring wells installed within the injection reservoir soon 

after the start of injection and before the arrival of CO2 because of the pressurization of the reservoir. 

Pressure will also be monitored to ensure that pressure within the injection interval does not exceed 

design specifications and to determine whether any observed pressure changes above the primary 

confining zone could be associated with a leakage response. Changes in other parameters are expected to 

occur later in time than the initial increase of pressure. 
B.17 

Direct Geochemical Plume Monitoring 

Fluid samples will be collected from the SLR monitoring wells before, during, and after CO2 injection. 

The samples will be analyzed for chemical parameter changes that are indicators of the presence of CO2

and/or reactions caused by the presence of CO2. Baseline monitoring will involve collection and analysis 

of a minimum of three rounds of aqueous samples from each well completed in the targeted injection 

zone prior to initiation of CO2 injection. A comprehensive suite of geochemical and isotopic analyses 

will be performed on fluid samples collected from the reservoir. These analytical results will be used to 

characterize baseline geochemistry and provide a metric for comparison during operational phases. 

Aqueous sampling will not be used to assess CO2 saturation levels. Once scCO2 arrives, these wells can 

no longer provide representative fluid samples because of the two-phase fluid characteristics and 

buoyancy of scCO2.

B.7.2 Sampling Methods 

Direct Pressure Monitoring 

A single probe incorporating electronic sensors that will monitor indicator parameters (P/T/SpC) will be 

placed at reservoir depth in each monitored well. Each parameter will be measured at a 10-minute 

sampling interval and will be transmitted to the surface via the wireline cable. Additional sensors may be 

installed at the wellhead for measuring parameters such as wellhead pressure, barometric pressure, and 

ambient surface temperature. A data-acquisition system will be located at the surface to store the data 

from all sensors at the well site and will periodically transmit the stored data to the MVA data center in 

the control building. 

Direct Geochemical Plume Monitoring 

Fluid samples will be collected at monitored formation depths and maintained at formation pressures 

within a closed pressurized sample container to prevent the escape of dissolved gases. Access to the 

monitored interval at the SLR wells will be through an inner 2-7/8-in. tubing string extending to the 

monitoring interval and packed-off just above the screen. 

Fluid samples will be collected within the open interval of each monitoring well using a flow-through 

sampler with a 950-cc (or larger) sample chamber. The samples will be maintained at formation pressure 

within a closed sample container to prevent the escape of dissolved gases. Prior to sampling, the P/T/SpC 

probe will be monitored as the well is purged (up to three times the volume of the well-screen section will 

be discharged from the well before collecting the sample). The probe will then be removed from the well 

and the sampler will be run into the borehole on the same wireline cable to collect the pressurized fluid 

sample. Additional purging may be conducted just prior to collection of the pressurized fluid sample if 

mixing between the fluid column and sampling interval during insertion of the sampler is a concern. 

B.7.3 Sample Handling and Custody 

Direct Pressure Monitoring 

P/T/SpC measurements will be recorded by a data logger at each well site and also transmitted to dataacquisition systems located in the MVA data center. 
B.18 

Electronic data and field records will be transferred to laptop and/or desktop computers and/or backed-up 

on secured servers at least quarterly, as well as scanned copies of all pertinent hardcopy field 

records/notes. 

Direct Geochemical Plume Monitoring 

After removing the aqueous sampler from the well, the closed and pressurized sample container(s) will be 

transported to the MVA laboratory space in the control building for processing using standard chain-ofcustody procedures. 

B.7.4 Analytical Methods 

Table A.7 summarizes the analytical methods for groundwater quality monitoring in the SLR wells. 

Where possible, methods are based on standard protocols from the EPA or Standard Methods for the 

Examination of Water and Wastewater (American Public Health Association, American Water Works 

Association, Water Environment Federation, 19th ed. or later, Washington, D.C.). Laboratories shall be 

required to have standard operating procedures for the analytical methods performed. 

B.7.5 Quality Control 

Direct P/T/SpC and other continuous monitoring equipment will be calibrated according to 

manufacturers’ recommendations. If trends or other unexplained variability in the data are observed that 

might indicate a suspect response, instruments will be evaluated and, if required, recalibrated, or replaced. 

The QC practices for groundwater monitoring of the geochemical plume are the same as those specified 

for groundwater monitoring above the confining zone (Section B.4.5). Field QC samples include field 

blanks and field duplicates; a minimum of one of each type of sample shall be collected at each sampling 

event. Laboratory QC samples include method blanks, laboratory duplicates, matrix spikes, matrix spike 

duplicates, and laboratory control samples. The frequencies of these samples will be determined by the 

laboratory contract and standard method protocols. Typically, method blanks and laboratory control 

samples are analyzed with every analytical batch, while the remaining QC samples are run at a frequency 

of 1 per 10 samples. Table A.8 lists additional, method-specific requirements. 

B.7.6 Instrument/Equipment Testing, Inspection, and Maintenance 

High-quality (high-accuracy, high-resolution) gauges with low drift characteristics will be used. 

 Gauge components (gauge, cable head, cable) will be manufactured of materials designed to 

provide a long life expectancy for the anticipated downhole conditions. 

 Upon acquisition, a calibration certificate will be obtained for every pressure gauge. The 

calibration certificate will provide the manufacturer’s specifications for range, accuracy (% full 

scale), resolution (% full scale), and drift (< psi per year), and calibration results for each 

parameter. The calibration certificate will also provide the date that the gauge was calibrated, the 

methods and standards used, and the date calibration will expire. 

 Gauges will be installed above any packers so they can be removed if necessary for recalibration by 

removing the tubing string. Redundant gauges may be run on the same cable to provide 

confirmation of downhole pressure and temperature. 

 Upon installation, all gauges will be tested to verify that they are functioning (reading/transmitting) 

correctly. 
B.19 

For groundwater sampling, field equipment will be maintained, factory serviced, and factory calibrated 

according to the manufacturers’ recommendations. Spare parts that may be needed during sampling will 

be included in supplies on-hand during field sampling. 

For all laboratory equipment, testing, inspection, and maintenance will be the responsibility of the 

analytical laboratory per method-specific protocols and the laboratory’s QA program. The laboratory’s 

QA program will be reviewed by the Alliance prior to submission of samples for analysis. 

B.7.7 Instrument/Equipment Calibration and Frequency 

Pressure gauges that are used for direct pressure monitoring will be calibrated according to 

manufacturers’ recommendations, and current calibration certificates will be kept on file with the 

monitoring data. 

B.8 Pulsed-Neutron Capture Logging 

PNC wireline logs will be used to quantify CO2 saturation relative to depth in each of three monitoring 

RAT wells. These indirect measurements of CO2 saturation will be used to detect and quantify CO2

levels over the entire logged interval. The PNC logging data will be used for calibration of reservoir 

models and to identify any unforeseen occurrences of CO2 leakage across the primary confining zone. 

Numerical modeling will be used to predict the CO2 plume growth and migration over time by integrating 

the calculated CO2 saturations in the three RAT wells with the geologic model and other monitoring data. 

B.8.1 Sampling Process Design (Experimental Design) 

PNC logs operate by generating a pulse of high-energy neutrons and subsequently measuring the neutron 

decay over time and across a wide energy spectrum. PNC logs can measure specific energy bins or a 

composite of energies, the latter of which is termed the thermal capture cross-section (sigma) operational 

mode. In sigma mode, all elements that capture and slow neutrons contribute to the measurement rather 

than just the characteristic energy levels associated with specific elements. Both measurement modes are 

useful for determining CO2 saturation from PNC logs and will be simultaneously acquired. 

PNC logging has been successfully implemented at a number carbon sequestration sites and while the 

PNC method has been shown to work quite well, problems associated with CO2 flooding the casing and 

perforation zones have been identified. PNC logs are only sensitive to a localized region surrounding the 

borehole (15−30 cm) and are therefore susceptible to interference from features very near the borehole, 

such as changing borehole fluids, poor cement, or invaded drilling fluids. The monitoring RAT wells are 

designed with small-diameter, nonperforated casings to minimize near-borehole interference effects. 

Borehole effects will also be accounted for by analyzing response times from multiple detectors in the 

tool. Porosities within the reservoir at the FutureGen 2.0 storage site are moderate and the PNC logs are 

expected to adequately quantify CO2 saturation along the RAT boreholes in order to calibrate reservoir 

models as well as identify possible leakage through the sealing layers. 

B.8.2 Sampling Methods 

Quarterly PNC logging will be conducted in RAT wells 1, 2, and 3. The locations of the RAT wells was 

chosen to sample various stages of the CO2 plume migration, with the emphasis on the areas with large 

expected changes in the first five (5) years. Downhole repeatability of the tool performance will be 

verified by conducting a “repeat section” of the logging run. Repeatability is used to validate the 
B.20 

measurement acquired during the main logging pass, as well as to identify anomalies that may arise 

during the survey for re-logging. Measurement depth is of critical importance in all borehole logs. Depth 

will be measured with respect to a fixed reference throughout the lifetime of the project. Verification of 

proper tool operation will be performed prior to each logging event following the manufacturer’s 

recommended procedure. Elastic cable stretch and slippage will be automatically compensated. 

Repeatability of logging depths will also be checked by repeat gamma-ray depth location of key strata or 

drill collar locators and can be used to correct depth measurements after logging is complete. 

B.8.3 Sample Handling and Custody 

No specialized sample-/data-handling procedures are required. PNC tool readings will be recorded on a 

computer located in the wireline logging truck. All electronic data and field records will be transferred to 

laptop and/or desktop computers and backed-up, on secure servers at the conclusion of each logging 

event, as will scanned copies of all pertinent hardcopy field records/notes. 

B.8.4 Analytical Methods 

PNC log data will be processed following industry best practices and coordinated with the boreholelogging operator to optimize data-collection parameters. Modeling can be done to simulate near-borehole 

interferences and remove their effects from the signal. Modeling is a recommended procedure and 

requires knowledge of the target formations and fluids that must be obtained from cores and additional 

logging data. Each logging result will be compared for each RAT well to the baseline or previous survey, 

as applicable, to determine changes in saturation. 

B.8.5 Quality Control 

Verification of vendor processing software and results will ensure that the acquired data are acceptable 

and that calculations of CO2 saturations are reproducible. Third-party PNC logging and processing for a 

subset of boreholes and logging events can be used as part of the validation procedure. Failure of tool 

performance in the field or unreproducible “repeat sections” will result in non-acceptance of the data and 

may trigger a return of the PNC tool to the manufacturer for recalibration or replacement. Off-normal 

CO2 saturation calculations will trigger additional evaluation and possible new logging runs. 

B.8.6 Instrument/Equipment Testing, Inspection, and Maintenance 

Examples of industry-published guidelines for calibration and field operation of the PNC wireline log 

hardware and data-collection software are provided in Appendix B.

B.8.7 Instrument/Equipment Calibration and Frequency 

To ensure data-acquisition quality, the logging tool will be calibrated for accuracy, checked to be in good 

working order, and verified by the manufacturer. All tools and field operation software will be provided 

by the manufacturer with an auditable verification record to ensure traceability. In addition to the initial 

manufacturer calibration, PNC tool recalibration will be performed monthly and both prior to and after 

each logging event using an onsite calibration vessel following the manufacturer’s guidelines. Examples 

of industry-published guidelines for calibration and field operation of the PNC wireline log hardware and 

data-collection software are provided in Appendix B. 
B.21 

B.9 Integrated Deformation Monitoring 

B.9.1 Sampling Process Design (Experimental Design) 

The deformation monitoring will include orbital DInSAR data (X-band TerraSAR-X, C-band Radarsat-2, 

X-Band Cosmo-Skymed, or any other satellite data that will be available at the time of data collection) 

and a field survey validation using permanent Global Positioning System (GPS) stations, permanent 

tiltmeters, and annual Differential Global Positioning System (DGPS) surveys. This approach will be 

used for the baseline before the injection and during the injection phase with modifications based on the 

experience gained during the two-year baseline-monitoring period. 

Differential Synthetic Aperture Radar (SAR) Interferometry (DInSAR) is a method of generating surface 

displacement maps from two images acquired by radar aboard a satellite at distinct times. Specific and 

complex processing is applied to obtain time series of displacements of the ground surface. All DInSAR 

deformation measurements are corrupted by spatiotemporal variations in the atmosphere and surface 

scattering properties. Advanced DInSAR time-series analyses exploit a subset of pixels in a stack of 

many SAR images to reduce atmospheric artifacts and decorrelation effects. These pixels exhibit high 

phase stability through time. The output products from these advanced techniques include a pixel average 

velocity accurate to 1−2 mm/yr and a pixel time series showing cumulative deformation accurate to 5−10 

mm for each of the SAR acquisition times. It should be noted that accuracy improves with time as the 

time series becomes larger. 

B.9.2 Sampling Methods 

Orbital SAR data will be systematically acquired and processed over the storage site with at least one 

scene per month to obtain an advanced DInSAR time series. These data will be obtained from the 

available orbital instruments available at the time of collection. It should be noted that the existing 

TerraSAR-X, Radarsat-2 and Cosmo-Skymed systems provide frequent systematic revisits of 11, 24, and 

4 days, respectively. 

Widespread overall temporal decorrelation is anticipated except in developed areas (e.g., roads, 

infrastructure at the site, and the neighboring towns) and for the six corner cube reflectors that will be 

deployed on site. These isolated coherent pixels will be exploited to measure deformation over time, and 

different algorithms (e.g., persistent scatters, small baseline subsets, etc.) will be used to determine the 

best approach for the site. 

Data from five permanent tiltmeters and GPS stations will be collected continuously. In addition, annual 

geodetic surveys will be conducted using the Real-Time Kinematic (RTK) technique where a single 

reference station gives the real-time corrections, providing centimeter-level or better accuracy. 

Deformations will be measured at permanent locations chosen to measure the extent of the predicted 

deformation in the AoR and also used by the gravity surveys (see Section B.10).

B.9.3 Sample Handling and Custody

DInSAR data will be acquired, processed, and archived by the vendor. Displacement maps and 

deformation time series will be archived on digital media by the Alliance. 

Permanent GPS and tiltmeter data will be collected in real time by the Alliance and stored on digital 

media on site. Differential GPS (DGPS) survey data will be archived on digital media by the Alliance. 
B.22 

B.9.4 Analytical Methods 

To establish a more comprehensive geophysical and geomechanical understanding of the FutureGen 2.0 

site, DInSAR and field deformation measurements will be integrated and processed with other monitoring 

data collected at the site: microseismicity, gravity, pressure, and temperature. This unique and complete 

geophysical data set will then be inverted to constrain the CO2 plume shape, extension, and migration in 

the subsurface. 

B.9.5 Quality Control 

Verification of vendor processing software and results will ensure that the acquired data are acceptable 

and results reproducible. 

B.9.6 Instrument/Equipment Testing, Inspection, and Maintenance

Testing of the whole DInSAR chain acquisition is routinely conducted by the space agencies. 

Permanent tiltmeters and GPS instruments installed onsite will be checked annually. 

The Trimble R8 receivers used for the annual DGPS surveys will be checked annually.

B.9.7 Instrument/Equipment Calibration and Frequency

Calibration of DInSAR chain acquisition is routinely conducted by the space agencies and the results will 

be compared to field measurements. 

Tiltmeters and GPS instruments installed onsite will be calibrated for accuracy, checked to be in good 

working order, and verified by the manufacturer. The Trimble R8 receivers used for the annual DGPS 

surveys will also be calibrated and verified by the manufacturer. 

All equipment and software will be provided by the manufacturer with an auditable verification record to 

ensure traceability. 

B.10 Time-Lapse Gravity Monitoring 

B.10.1 Sampling Process Design (Experimental Design) 

Four-dimensional (4D or time-lapse) microgravimetry—the temporal change of gravity at the microGal 

scale (1 μGal = 10-6 m/s2

)—is a cost-effective and relatively rapid means of observing changes in density 

distribution in the subsurface, particularly those caused by the migration of fluids. 

Time-lapse gravity monitoring is accomplished using repetitive annual surveys at a series of points 

located at the ground surface (permanent stations). Changes in gravity anomaly with time are determined 

and then interpreted in terms of changes in subsurface densities. These changes could be linked for 

example to replacement of water by CO2. providing an indirect method of tracing the displacement of the 

CO2 plume at depth. Due to the non-uniqueness of the solution, this monitoring method could rarely be 

used alone and gives the best results when used with other methods (deformation or seismic). 
B.23 

B.10.2 Sampling Methods 

Permanent station locations were established in November 2011 for the purpose of future reoccupation 

surveys (Figure A.4). These stations are located on the roadways inside the survey area, the reference 

being the KC0540 station (Central Plaza Park monument, Jacksonville, Illinois). The emplacement of 

each permanent station on the roadway is designated by a marker. Markers are approximately half-inchdiameter nails with a three-quarter-inch heads to provide good visibility from the surface. 

Because all the gravity measurements are relative, a tie to a gravity station outside the surveyed area must 

be made. This reference is station NGS# KC0540, a monument located in Central Plaza Park in 

Jacksonville, Illinois, which was tied to the absolute gravity station NGS# KC0319 located in Hannibal, 

Missouri. 

To compensate for the instrumental drift, measurements are taken on a 2-hour cycle at a local reference 

station at the center of the surveyed area (station 137) and at an offsite location (station KC0540) twice a 

day. 

B.10.3 Sample Handling and Custody 

Data will be archived on a digital media by the Alliance.

B.10.4 Analytical Methods 

Data reduction will be performed using the standardized methods to obtain Free Air and Bouguer 

anomalies. These anomalies will then be interpreted in terms of subsurface density anomalies by gravity 

direct or inverse modeling using the commercial software ENcom Model VisionTM 12.0. 

B.10.5 Quality Control 

Repeat measurements at the same field point is the only way to evaluate their quality. At least three 

measurements for each point will be recorded. 

B.10.6 Instrument/Equipment Testing, Inspection, and Maintenance

The gravity meter used will be a LaCoste & Romberg Model D belonging to Pacific Northwest National 

Laboratory. It is a steel mechanism, “zero length” spring meter with a worldwide range that is less prone 

to drift than quartz meters. The instrument is thermostatically controlled to approximately 50°C during 

the duration of the surveys. A full maintenance and inspection of the instrument needs to be completed 

every 10 years at the LaCoste and Romberg factory; the next one is scheduled in 2021. 

B.10.7 Instrument/Equipment Calibration and Frequency

No calibration of the instrument is required. 

B.11 Microseismic Monitoring 

Elevated pressures in the reservoir due to injection of CO2 have the potential to induce seismic events. 

The objective of the microseismic monitoring network is to accurately determine the locations, 

magnitudes, and focal mechanisms of seismic events. 
B.24 

B.11.1 Sampling Process Design (Experimental Design) 

A microseismic monitoring system must be able to detect a seismic event at a number of monitoring 

stations and use the signals to accurately determine the event location and understand the brittle failure 

mechanisms responsible for the event. The monitoring network consists of an array of seismic sensors 

placed either at the near-surface or within deeper monitoring boreholes. The accuracy of the network is 

dependent on both the geometry of the sensor array and the signal-to-noise ratio (SNR) at each of the 

sensor locations. The number and spatial distribution of sensors in a microseismic monitoring network 

must be designed to minimize the errors in estimating event location and origin times. The subsurface 

seismic velocity model also has a large influence on the predicted data and must be estimated as 

accurately as possible using borehole logs and data from vertical seismic profiling. Sensors need to have 

high sensitivity, flat response over the intended frequency range, a low noise floor, and stable 

performance over time. 

External noise sources often occur at the surface or from nearby subsurface activities such as drilling. 

Surface noise attenuates with distance below the surface and it is therefore advantageous to emplace 

surface sensors within shallow boreholes in order to reduce external noise to an acceptable level. Surface 

or shallow borehole sensors provide multiple sensing azimuths and offsets, but surface sensors typically 

suffer from lower SNRs. Shallow borehole installations, however, can achieve a noise floor approaching 

that of sensors located in deep boreholes. Deep borehole monitoring can provide a higher SNR if the 

microseismic event occurs close enough to the array, but precise event location can be difficult due to 

geometric constraints on the array.

B.11.2 Sampling Methods 

The microseismic network will consist of an array of near-surface shallow borehole sensors in addition 

two deep borehole sensor arrays installed within the ACZ wells. The network incorporates the benefits of 

both array types to improve the overall performance of the system and is expected to perform well for 

monitoring seismic events that occur in the AoR. 

Commonly used sensors for seismic applications include moving coil geophones that that have frequency 

bandwidths from 5−400 Hz. These devices are often built with signal conditioning and digitizer circuitry 

located on the sensor to improve the electrical performance; however, because of the complexity of their

assembly, their long-term deployment in a deep borehole environment results in reduced lifetimes. 

Permanent emplacement of standard moving coil geophones within a deep borehole would not be 

expected to last the lifetime of the FutureGen 2.0 project. Geophones will be placed in the shallow 

borehole stations and are expected to perform well in that environment, particularly for higher-frequency 

signals. 

Surface sensors also require higher sensitivities and lower noise floors than sensors placed in deep 

boreholes because the distance from the event to the surface is often much greater. High-quality 

broadband seismometers exhibit much higher sensitivity and extremely low noise floors compared to 

standard geophones. These seismometers have long working lifetimes and an excellent frequency 

response from 1 mHz to 200Hz. Seismometers will also be installed in each shallow borehole along with 

a borehole geophone. To minimize signal attenuation and site noise, the boreholes will be drilled to at 

least the uppermost bedrock unit, and the casing will be sealed and pumped dry prior to sensor 

emplacement. 
B.25 

Fiber-optic-based seismic sensors use backscattered light from a laser pulse that has been introduced into 

an optical fiber to measure the movement of a sensing element. The fiber can be coupled to a device to 

mechanically amplify the strain on the fiber and produce a sensor with performance as good as, or better 

than, standard geophones. A key feature of these sensors is that because they have no electronics located 

within a borehole they are extremely robust; their lifetimes and performance stability are designed to last 

several decades. Due to their superior sensitivity and expected longevity, an array of fiber-optic 

accelerometers will be installed within two, deep ACZ wells. Optical cables will be extended from each 

of the wells back to a central control building that will house the data-acquisition and storage systems. 

B.11.3 Sample Handling and Custody 

No specialized sample/data handling procedures are required. Microseismic signals from the shallow 

boreholes will be continuously recorded on a data logger located at each of the stations. All electronic 

data will be continuously transferred to a data storage and processing system located at a central control 

building. Digital copies of all pertinent hardcopy field records/notes will also be transferred to the central 

data server. 

B.11.4 Analytical Methods 

Microseismic data will be processed and stored following industry best practices. 

B.11.5 Quality Control 

Verification of vendor processing software and results will ensure that the acquired data are acceptable 

and that determinations of event locations and focal mechanisms are accurate. 

B.11.6 Instrument/Equipment Testing, Inspection, and Maintenance 

Regular maintenance and testing of the seismic hardware and data-collection software are critical to 

ensuring high-quality results. All hardware will be maintained in accordance with manufacturer 

recommendations. Software updates will be incorporated as they are released by the manufacturer. 

B.11.7 Instrument/Equipment Calibration and Frequency 

All microseismic equipment will be calibrated for accuracy, checked to be in good working order, and 

verified by the manufacturer. All equipment and software will be provided by the manufacturer with an 

auditable verification record to ensure traceability. In addition to the initial manufacturer calibration, 

seismometers and geophones will be periodically recalibrated following the manufacturers’ guidelines. In 

the event that damage is identified, it will be immediately reported and the equipment removed and 

replaced. 

B.12 Inspection/Acceptance of Supplies and Consumables 

Testing and monitoring supplies and consumables that may affect the quality of the results will be 

procured, inspected, and accepted in accordance with the Alliance representative’s administrative 

procedures (e.g., Pacific Northwest National Laboratory’s HDI Workflows and Work Controls). 

Critical items and responsible personnel will be identified in task-specific sampling and analysis plans, as 

appropriate. 
B.26 

B.13 Non-direct Measurements (e.g., existing data) 

Existing data, including literature files and historic data from surrounding areas and previous onsite 

characterization, testing, and monitoring activities, have been used to guide the design of the testing and 

monitoring program. However, these data are only ancillary to the well testing and monitoring program 

described here. These existing data will be used primarily for qualitative comparison to newly collected 

data. 

All data will continue to be evaluated for their acceptability to meet project needs, that is, that the results, 

interpretation, and reports provide reasonable assurance that the project is operating as permitted and is 

not endangering any USDWs. 

B.14 Data Management 

All project data, record keeping, and reporting will be conducted to meet the requirements of 40 CFR 

146.91(f). 

B.14.1 Data Management Process 

Project data will be managed in accordance with the Project Data Management Plan (Bryce et al. 2013). 

Management of all monitoring data is controlled by the subtier Monitoring Data Management Plan 

(Vermeul et al. 2014; not publicly available). Management of well MIT data is controlled by the subtier 

Well Construction Data Management Plan (Lanigan et al. 2013; not publicly available). All data will be 

managed by Alliance representatives throughout the duration of the project plus at least 10 years. 

B.14.2 Recordkeeping Procedures 

Project records will be managed according to project record management requirements and Alliance 

representatives’ internal records management procedures. 

B.14.3 Data Handling Equipment and Procedures 

All data will be managed in a centralized electronic data management system. The underlying electronic 

servers will be routinely maintained, updated, and backed-up to ensure the long-term preservation of the 

data and records. 

The centralized data-management system acts as a “data hub” to support collaborative analyses, enabling 

a diverse spectrum of experts—including geologists, hydrologists, numerical modelers, model developers, 

and others—to share data, tools, expertise, and computational models. This data-management system 

also acts as a “turn-key” data-management system that can be transferred to any future Alliance 

representatives or storage site operators. 

B.14.4 Configuration Management and Change Control 

The project’s Configuration Management Plan (Alliance 2013b) identifies configuration-management 

requirements and establishes the methodology for configuration identification and control of releases and 

changes to configuration items. Each Alliance contractor is required to use configuration management to 

establish document control and to implement, account for, and record changes to various components of 

the project under its responsibility. The project’s data configuration process is detailed in the Project 

Data Management Plan (Bryce et al. 2013) and its subsequent subtier data management plans. This data 
B.27 

configuration process controls how changes are made should errors or loss of data be detected during the 

course of routine data quality and readiness review checks and/or peer reviews. 

QC mechanisms, checklists, forms, etc. used to detect errors are highly data-specific, but generally rely on 

spot-checks against field and laboratory records, as well as manual calculations to validate electronic 

manipulation of the data. 
C.1 

C. Assessment and Oversight 

C.1 Assessments and Response Actions 

As described in Section A.6 and detailed in Table A.2, the Monitoring, Verification, and Accounting 

(MVA) program for the FutureGen 2.0 CO2 Pipeline and Storage Project includes numerous categories, 

methods, and frequencies of monitoring the performance of the CO2 storage site. FutureGen staff 

responsible for the associated technical element or discipline will analyze the monitoring data and initiate 

any needed responses or corrective actions. Management will have ready access to performance data and 

will receive monitoring and performance reports on a regular basis. 

In addition to the activities covered by the MVA program, data quality assessments will be performed to 

evaluate the state of configuration-controlled technical information in the FutureGen technical data 

repository to ensure that the appropriate data, analyses, and supporting information are collected, 

maintained, and protected from damage, deterioration, harm, or loss. These data quality assessments will 

be performed by a team consisting of the FutureGen 2.0 Data Manager, Project Quality Engineer, Subject 

Matter Experts, and additional knowledgeable and trained staff as appropriate for the scope and nature of 

the assessment. Assessments will be scheduled to occur at logical points in the project lifecycle, such as 

after completion and submission of a major deliverable that incorporates controlled technical information. 

Assessment results will be reported to management; deficiencies, weaknesses, opportunities for 

improvement, and noteworthy practices will be identified in the assessment reports. Assessment results 

will also be communicated to affected parties. Management will assign responsible staff to correct 

deficiencies and other nonconforming conditions and will ensure that corrective actions are implemented 

and verified in a timely manner. The Project Quality Engineer and FutureGen Data Manager will conduct 

follow-up surveillances to verify and document completion of corrective actions and to evaluate 

effectiveness. 

C.2 Reports to Management 

Management will be informed of the project status via the regular monitoring and performance reports 

generated by the MVA program, as well as reports of assessments conducted to verify data quality and 

surveillances performed to verify completed corrective actions. These reports are described in 

Section C.1; additional periodic reporting is not anticipated at this time. However, as directed by 

FutureGen management, targeted assessments by the Data Manager, Project Quality Engineer, or others 

will be conducted and reported to apprise management of project performance in areas of particular 

interest or concern. 
D.1 

D. Data Validation and Usability 

D.1 Data Review, Verification, and Validation 

The FutureGen 2.0 CO2 Pipeline and Storage Support Project has established a Project Data Management 

Plan (PDMP) (Bryce et al. 2013) to identify how information and data collected or generated for the 

project will be stored, organized, and accessed to support all phases of the project. The PDMP describes 

the institutional responsibilities and requirements for managing all relevant data, including the intended 

uses and level of quality assurance needed for the data, the types of data to be acquired, and how the data 

will be managed and made available to prospective users. In addition to the PDMP, the FutureGen 2.0 

project has issued discipline-specific subtier Technical Data Management Plans (TDMPs) to tailor data 

management processes to the needs of specific technical elements (e.g., computational modeling, 

geophysical, monitoring, site characterization). The PDMP and each TDMP define several categories of 

data, or Data Levels (consistent among all of the Data Management Plans), with corresponding data 

management, review, verification, validation, and configuration control requirements. The PDMP and 

TDMPs establish roles (e.g., Data Manager, Data Steward, Data Reviewer, Subject Matter Expert) and 

responsibilities for key participants in the data management process; project management assigns 

appropriate staff members to each role. Project staff who generate, review, verify, validate, or manage 

data are trained to the requirements of one or more Data Management Plans. Raw data (resulting from 

the use of a procedure or technology), defined as Level 1, are put under configuration control in the data 

management system at the time of upload to the system. Data defined at other Data Levels are put under 

configuration control when the data become reportable or decision-affecting. The procedures used to 

verify, validate, process, transform, interpret, and report data at each Data Level are documented and 

captured as part of the data management process. 

D.2 Verification and Validation Methods 

The Data Management Plans described in Section D.1 require that data packages undergo rigorous peer 

reviews. These reviews both validate the data—confirm that the appropriate types of data were collected 

using appropriate instruments and methods—and verify that the collected data are reasonable, were 

processed and analyzed correctly, and are free of errors. Data that have not undergone the peer-review 

process and are not yet under configuration control can be provided as preliminary information when 

accompanied by a disclaimer that clearly states that data are 1) preliminary and have not been reviewed in 

accordance with FutureGen’s quality assurance practices, 2) considered “For Information Only”, and 

3) not to be used for reporting purposes nor as the basis for project management decisions. Once data are 

placed under configuration control, any changes must be approved using robust configurationmanagement processes described in the Data Management Plans. The peer-review and configurationmanagement processes include methods for tracking chain-of-custody for data, ensuring that custody is 

managed and control is maintained throughout the life of the project. 

If issues are identified during a peer review, they are addressed and corrected by the data owner and peer 

reviewer (involving others, as necessary) as part of the peer-review process. These unreviewed data will 

not have been used in any formal work product nor as the basis for project management decisions, so the 

impacts of data errors will be minimal. If an error is identified in data under configuration control, in 

addition to correcting the error, affected work products and management decisions will be identified, 

affected users will be notified, and corrective actions will be coordinated to ensure that the extent of the 

error’s impact is fully addressed. 
D.2 

D.3 Reconciliation with User Requirements 

During the course of a long-duration project such as the FutureGen 2.0 CO2 Pipeline and Storage Project, 

personnel changes over time can result in loss of institutional memory about the organization’s data, 

thereby reducing the value of the data. New project staff may have little understanding of the content, 

intended uses, and pedigree of existing data sets. Metadata can help protect the organization’s investment 

in data by providing context and pedigree, as well as describing interrelationships between various data 

sets. The Data Management Plans described in Section D.1 provide for Subject Matter Experts (SMEs) to 

establish and document metadata requirements for the data sets created by the FutureGen 2.0 project. 

Complete metadata will support data interpretation, provide confidence in the data, and encourage 

appropriate use of the data. To establish meaningful metadata requirements, SMEs must understand how 

data users and decision-makers will use the data. By adhering to metadata requirements when loading 

data into the project data repository, project staff ensure that user requirements addressed by the metadata 

are satisfied. 

Data reviews, identification and resolution of data issues, and limitations on data use are discussed in 

Section D.2. 
E.1 

E. References 

40 CFR 146. Code of Federal Regulation, Title 40, Protection of Environment, Part 146, Underground 

Injection Control Program: Criteria and Standards. 

Alliance (FutureGen Industrial Alliance, Inc.). 2013a. CO2 Pipeline and Storage Project Phase II, 

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App. A-1 

Appendix A 

Quality Assurance for Logging and Vendor Processing of PulsedNeutron Capture (PNC) Logs 

This appendix contains wireline logging, indirect geophysical methods, and some non-routine sampling 

data processing and analysis industry standards. 

Example of Vendor QA for Pulsed-Neutron Capture Logging: Schlumberger registered brand name 

RST 

Reference: Schlumberger Wireline Log Quality Reference Manual accessed January 2014 

http://www.slb.com/resources/publications/books/lqcrm.aspx.

The sigma mode of PNC logs will also be used both for monitoring carbon dioxide transport and for 

mechanical integrity tests. 
App. A-2 
App. A-3 
App. A-4 
App. A-5 
App. A-6 
App. A-7 

Quality Control in Processing Pulsed-Neutron Capture Logs 

The following is an example from one vendor. 

Reference: Albertin, I. et al., 1996, Many Facets of Pulsed Neutron Cased Hole Logging: Schlumberger 

Oilfield Review Summer 1996. Available at: 

http://www.slb.com/~/media/Files/resources/oilfield_review/ors96/sum96/06962841.pdf

Additional information about the PNC tool is available at: 

http://www.slb.com/~/media/PremiumContent/evaluation/petrophysics/porosity/rst_client_book.pdf
App. A-8 
App. A-9 
App. A-10 
App. A-11 
App. B-1 

Appendix B

Quality Assurance for Wireline Logs Used in 

Mechanical Integrity Tests 

This appendix contains examples of vendor quality assurance (QA) on the following tools: 

 Ultrasonic Cement Evaluation tool: Example shown here is Schlumberger’s Isolation Scanner 

(registered trademark) 

 Cement Bond Log tool: Example shown is Schlumberger’s Cement Bond Tool (CBT) registered 

trademark 

 Cement Bond Logging QA 

 Cased hole temperature log 

 Cased hole gamma log 

 NOTE: Pulsed-neutron capture (PNC) logs are covered in Appendix A 

Reference: Schlumberger Wireline Log Quality Reference Manual accessed January 2014 at 

http://www.slb.com/resources/publications/books/lqcrm.aspx.
App. B-2 
App. B-3 
App. B-4 
App. B-5 
App. B-6 
App. B-7 

Cement Bond 

The example shown below is the QA for the sonic-based Schlumberger Cement Bond Tool (CBT) 

registered trademark. 

Reference : Schlumberger Wireline Log Quality Reference Manual accessed January 2014 

http://www.slb.com/resources/publications/books/lqcrm.aspx.
App. B-8 
App. B-9 
App. B-10 
App. B-11 
App. B-12 

Cement Bond Logging 
App. B-13 
App. B-14 
App. B-15 

Cased Hole Temperature Logging 

Cased hole temperature logging tools are often run as part of a multi-tool tool string, as described 

in the following Schlumberger example. 
App. B-16 

Cased Hole Gamma-Ray Logging 
App. B-17