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 CO 2 

### 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

L ocation of Injection Well: Morgan County, IL; 26−16N−9W; 39.80097 oN 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

use d to validate and adjust the geological models used to predict the distribution of the CO 2 

### 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

CO 2 

### and brine leakage out of the injection zone and for the protection of USDWs. Central to this
moni toring strategy is the measurement of CO 2 

### saturation within the reservoir using three reservoir access tubes (RATs) extending thro ugh the base of the Moun t Simon Formation and
int o the Precambrian basement. The CO 2 

### saturation will be measured using pulsed-neutron capture (PNC) logging across the injection zone and primary confining zone. The three wells
ha ve been placed at increasing radial distances from the injection site to provide measures of

CO 2 

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

### plumes, respectively. The three RAT installations have also been distributed across three different azimuthal directions, providing CO 2 

### arrival information for three of the four predicted lobes of
the CO 2 

### 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
dire ctly 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 CO 2 

### ( sc CO 2 

### ) breakthrough occurs, these wells can no longer provide representative fluid samples because of
the two-phase fluid characteristics and buoyancy of sc CO 2



### .

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

fr om the reservoir as early as possible. This will be accomplished by monitoring for CO 2 

### andTesting 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

c ompleted 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 cha racterize aqueou s 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

a queous chemistry.

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

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

pe riodically 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.

C omparison 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 CO 2 

### containment and/or assessing the long-term environmental impacts of any CO 2 

### 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
de velopment of the pressure front, which results from the injection of CO 2 

### . 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

pre ssure front from the distribution of seismic events, and 3) identifying features that may
indi cate 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

progr am as needed, including the option to install additional wells in outyears to verify CO 2 

### plume and pressure front evolution and/or evaluate leakage potenti al (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 inj ection and will be located outside the CO 2 

### 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 detectionTesting 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 CO 2 

### 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
fa cilitate 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

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

re commended 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 samp led 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),

a s described below.

Samples of the CO2 stream will be collected regularly (e.g., quarterly) for chemical analysis of the pa rameters listed in Table 2. Continuous monitoring is described in Table 1 of this plan.

Table 2

. Parameters and Frequency for CO 2 Stream Analysis.

Parameter/Analyte Frequency

Pressure C ontinuous Temperature Continuous

CO 2 (%) 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 CO 2 

### stream will be obtained for analysis of gases, including CO 2 

### , O 2 

### , H2 S, Ar, and water moisture. Samples of the CO 2 

### stream will be collected from the CO 2 

### pipeline at a location where the material is representative of injection conditions. A sa mpling station will be
inst alled in the ground or on a structure close to the pipeline and connected to the pipeline via a

sa mpling manifold with pressure and temperature (P/T) instrumentation to acc ommodate doublesided constant pressure sampling cylinders that will be used to collect the samples. The collection procedure is designed to collect and preserve representative CO 2 

### 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 CO 2


### 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 CO 2 

### 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 CO 2 

### injected into the well field will be measured by a flow meter skid
with a Corioli s 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

mete rs 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 CO 2 

### storage site SCADA system for continuous monitoring and control of the CO 2 

### injection rate into each well.

Continuous Recording of Injection Pressure

The pressure of the injected CO 2 

### will be continuously measured for each well at a regular frequency by an electronic pressure transmitter with analog output mounted on the CO 2 

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

c onnected to the annulus pressurization system (APS ) programmable logic controller (PLC)
loca ted in the Control Building adjacent to the injection well pad.

Continuous Recording of Injection Temperature

The temperature of the injected CO 2 

### 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 CO 2 

### line 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
tempe rature 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 CO 2 

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

mea sured at the surface via real-time P/T instruments installed in the CO 2 

### pipeline near the pipeline interface with the wellhead.

The CO 2 

### 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 CO 2 

### Pipeline and Storage Project. The P/T will also be monitor ed 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 limit ation 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

re quirements 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

CO 2 

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

in jection 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
wil l 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

in jection well by running wireline casing inspection logs (CILs). The frequency of running these
tub ing 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

we ll.

 Ultrasonic tools, which are capable of measuring wall thickness in addition to the inner
dia meter (radius) of the well tubular and can also provide information about the outer
surf ace 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

suc h 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

- Resolution Vertilog (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 m eet the requirements of 40 CFR 146.90(d ).

F utureGen 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

S andstone. Details about these wells are in T able 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' 0 1.24"N

, 90 ° 0 4'41.87"W

ACZ2: 39 ° 48' 0 1.06"N

, 90 ° 0 5'16.84"W USDW1: 39 ° 48' 0 1.73"N

, 90 ° 0 4'41.87"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 ( F igure 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 C 10 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 CO 2 

### ) 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 C 11 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 CO 2 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 CO 2 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 con tinuous monitoring, see Table 1

.Testing and Monitoring Plan for FutureGen Alliance Page C 12 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 CO 2 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 con tinuous monitoring, see Table 1

.



### Sampling methods:

Sampling and analytical requirements for target parameters are g iven 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

li st was based on relevance for detecting the presence of fugitive brine and CO 2



### .

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
fie ld probes will follow the manufacturer’s instructions using standard calibration solutions. A comprehensive list of target analytes under consideration and groundwater sample collection

re quire ments is provided in Table 8

.

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

a ssurance 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

mana gement 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 sig nature 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
modi fications to the permits through the process described in 40 C.F.R. Part 144.Testing and Monitoring Plan for FutureGen Alliance Page C 13 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), HNO 3 to pH <2 60 days

Trace Metals: Sb, As, Cd, Cr, Cu, Pb, Se, Tl 20

- mL plastic vial Filtered (0.45 μm), HNO 3 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), HNO 3 to pH <2 28 days

Anions: Cl
-

, Br -

, F -

, SO 4 2

-

, NO 3 - 125

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

Total and Bicarbonate Alkalinity (as CaCO 3 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 H 2 SO 4 to pH <2, Cool 4°C 28 days

Dissolved Inorganic Carbon (DIC) 250

- mL plastic vial Filtered (0.45 μm) , H 2 SO 4 to pH <2,
Cool 4°C 28 days

Total Organic Carbon (TOC) 250

- mL amber glass Unfiltered, H 2 SO 4 to pH <2, Cool

4°C 28 days

Dissolved Organic Carbon (DOC) 125

- mL plastic vial Filtered (0.45 μm)

, H 2 SO 4 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 UV

irradiated for additional sterilization 7 days

Stable Carbon Isotopes 13/12 C ( δ 13 C) of DIC in

Water 60

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

Radiocarbon 14 C of DIC in Water 60

- mL plastic or glass Filtered (0.45 μm), Cool 4°C 14 days
Hydrogen and Oxygen Isotopes 2/1 H ( δ D) and

18/16 O ( δ 18 O) of Water 60

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

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

2/1 H) 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 N 2 , CO 2 , O 2 , Ar, H 2 , He,

CH 4 , C 2 H 6 , C 3 H 8 , iC 4 H 10 , nC 4 H 10 , iC 5 H 12 , nC 5 H 12 , and C 6 +) 1

- L dissolved gas
bottle or flask Benzalkonium chloride capsule,
Cool 4°C 90 days

Radon ( 222 Rn) 1.25

- L PETE Pre

- concentrate into 20

- mL
scintillation c o c k

tail. Maintain

g r ou n d w a t e r temperature prior to

pre

- concentration 1 day

pH Field parameter None <1 h

Specific Conductance Field parameter None <1 h

HDPE = high

- density polyethylene; PETE = polyethylene terephthalate

.Testing and Monitoring Plan for FutureGen Alliance Page C 14 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 μ g/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 μ g/L 

### A.1.20 ±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 -

,

SO 4 2

-

, NO 3 - 

### 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 CaCO 3 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 Density



### A.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 μg/L 

### A.1.67 ±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

13/12 C (1 13 C) of DIC in

Water 

### A.1.76 Gas Bench for 13/12 C 

### 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 C 15 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 14 C of DIC

in Water AMS for 14 C 

### 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 2/1 H (δ ) and

18/16 O (1 18 O) of Water



### A.1.85 CRDS H 2 O Laser 

### A.1.86 Range:

- 500‰ to
200‰ vs.

VSMOW 

### A.1.87 2/1 H: ± 2.0‰



### A.1.88 18/16 O:

± 0.3‰ 

### A.1.89 Duplicates and working

standards at 10%



### A.1.90 Carbon and Hydrogen

Isotopes ( 14 C, 13/12 C,

2/1 H) of Dissolved
Methane in Water



### A.1.91 Offline Prep & Dual Inlet IRMS for

13 C; AMS for 14 C 

### A.1.92 14 C Range: 0 & DupMC 

### A.1.93 14 C:

±0.5pMC



### A.1.94 13 C: ±0.2‰



### A.1.95 2/1 H: ±4.0‰



### A.1.96 Duplicates and working

standards at 10%



### A.1.97 Compositional Analysis

of Dissolved Gas in Water (including N 2 , CO 2 , O 2 , Ar, H 2 , He,
CH 4 , C 2 H 6 , C 3 H 8 , iC 4 H 10 , nC 4 H 10 , iC 5 H 12 , nC 5 H 12 , and C 6 +)



### 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 ( 222 Rn)



### A.1.102 Liquid scintillation after pre

concentration 

### 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 Specific Conductance



### 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 = i sotope 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.

Ac cess 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 C 16 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

re quirements 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 CO 2 

### injection, subsequent runs will be compared to the baseline to determine changing fluid flow conditions

a djacent 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 CO 2 

### migration out of the CO 2 

### storage zone. The PNC logging tool will be run twice during each event: once in the gas-view mode to detect CO 2 

### 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 log s 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.

T able 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 CO 2 pipeline, instruments, and other lines; remove Christmas tree valves for maintenance or replacement 0.5 7

Reinstall Christmas tree valves, re

- connect CO 2 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 willTesting and Monitoring Plan for FutureGen Alliance Page C 17 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

P ressure.”

All m onitoring 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.

T able 11. Schedule for 5-Year Injection Well Maintenance Events (per W el l).

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 CO 2 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 CO 2 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 22Testing and Monitoring Plan for FutureGen Alliance Page C 18 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 CO 2 

### inj ection over time ;

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

pre ssure 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

purpo se 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

tra nsient-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 C 19 of 56

Permit Number: IL- 137

- 6A -0003 (Well #3) 

### Carbon Dioxide Plume and Pressure-Front Tracking

FutureGen will conduct direct and indirect CO 2 

### 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 pressurefr ont monitoring (monitoring wells used for monitoring above the confining zone are described
above in the Ground water 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

we ll). These wells will be used to monitor within the injection zone beyond the east and west
ends of the horizontal CO 2 

### -injection laterals.

Monitored parameters: pressure, temperature, and hydrogeochemical indicators of CO 2



### . To meet permit requirements for pressure front monitoring, at least one additional SLR well will
be installed outside the lateral extent of the CO 2 

### 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 CO 2 

### flooding of the borehole, which can distort the CO 2 

### saturation measurements.

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

Details about these wells are provided in Ta ble 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 C 20 of 56
Permit Number: IL- 137

- 6A -0003 (Well #3)

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

Single

- Level In

- Reservoir (SLR) Reservoir Access Tube (RAT)

Number of Wells 2 3

Total Depth (ft) 4,150 4,465

Lat/Long ( WGS84 ) SLR1: 39 ° 48' 0 1.56"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 a re completed in the injection zone. P/T monitoring in the injection well and all monitoring

we lls 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

c alibration 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

c alibrated 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 C 21 of 56
Permit Number: IL- 137

- 6A -0003 (Well #3) 

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

c alibrated 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

pre ssure gauges will demonstrate accuracy by u sing 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,

ma y 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 CO 2 

### 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 M oun t Simon/4,030 ft. Continuous Continuous

Injection Well 2 M oun t Simon/4,030 ft. Continuous Continuous

Injection Well 3 M ount Simon/4,030 ft. Continuous Continuous

Injection Well 4 M oun t Simon/4,030 ft. Continuous Continuous

Two single

- level monitoring
wells (SLR Wells 1 and 2) M oun t Simon/4,150 ft. Continuous Continuous

Note: For details and information on con tinuous 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 CO 2 

### plum e monitoring to meet the requirements of 40 CFR 146.90( g)(1).Testing and Monitoring Plan for FutureGen Alliance Page C 22 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 CO 2 

### injection. The samples will be analyzed for chemical parameter changes that are indicators of the presence of CO 2 

### and/or reactions caused by the presence of CO 2



### . Direct fluid

sa mpling 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: M oun t Simon Sandstone (4,150 ft)

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

Dissolved or separate

- phase CO 2 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 water

quality parameters (pH, alkalinity, total
dissolved solids, specific gravity), and any

tracers added to the CO 2 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 con tinuous monitoring, see Table 1

.



### Sampling methods:

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

z one. Fluid samples will be collected using an appropriate method to preserve the fluid sample at
in jection 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

a l. 2005).

Fluid samples will be analyzed for parameters that are indicators of CO 2 

### 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

g eochemistry are expected in the injection zone. Analysis of carbon and oxygen isotopes in injection zone fluids and

the injection stream ( 13/12 

### C, 18/16 

### O) provides another potential supplemental measure of CO 2 

### mi gration. Where stable isotopes are included as an analyte, data

qua lity 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 g iven 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 throughTesting and Monitoring Plan for FutureGen Alliance Page C 23 of 56
Permit Number: IL- 137

- 6A -0003 (Well #3) 

### the operational phases of the project. This selection process will consider the uniqueness andsignature 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
modi fications to the permits through the process described in 40 C.F.R. Part 144.Testing and Monitoring Plan for FutureGen Alliance Page C 24 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), HNO 3 to pH

<2 60 days

Trace Metals: Sb, As, Cd, Cr, Cu, Pb, Se,
Tl 20

- mL plastic vial Filtered (0.45 μm), HNO 3 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), HNO 3 to pH

<2 28 days

Anions: Cl
-

, Br -

, F -

, SO 4 2

-

, NO 3 - 125

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

Total and Bicarbonate Alkalinity (as

CaCO 3 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 H 2 SO 4 to pH <2, Cool 4°C 28 days

Dissolved Inorganic Carbon (DIC) 250

- mL plastic vial Filtered (0.45 μm) , H 2 SO 4 to pH <2, Cool 4°C 28 days

Total Organic Carbon (TOC) 250

- mL amber glass Unfiltered, H 2 SO 4 to pH <2, Cool

4°C 28 days

Dissolved Organic Carbon (DOC) 125

- mL plastic vial Filtered (0.45 μm)

, H 2 SO 4 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 UV

- irradiated for additional
sterilization 7 days

Stable Carbon Isotopes 13/12 C ( δ 13 C) of

DIC in Water 60

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

Radiocarbon 14 C of DIC in Water 60

- mL plastic or glass Filtered (0.45 μm), Cool 4°C 14 days
Hydrogen and Oxygen Isotopes 2/1 H ( δ D)

and 18/16 O ( δ 18 O) of Water 60

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

Carbon and Hydrogen Isotopes ( 14 C,

13/12 C, 2/1 H) 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 N 2 , CO 2 , O 2 , Ar, H 2 , He, CH 4 , C 2 H 6 , C 3 H 8 , iC 4 H 10 , nC 4 H 10 , iC 5 H 12 , nC 5 H 12 , and C 6 +) 1

- L dissolved gas bottle
or flask Benzalkonium chloride capsule,
Cool 4°C 90 days

Radon ( 222 Rn) 1.25

- L PETE Pre

- concentrate into 20

- mL
scintillation c o c k

tail. Maintain

g r ou n d w a t e r temperature prior to

pre

- concentration 1 day

pH Field parameter None <1 hTesting and Monitoring Plan for FutureGen Alliance Page C 25 of 56
Permit Number: IL- 137

- 6A -0003 (Well #3)

Parameter Volume/Container Preservation Holding

Time
Specific Conductance Field parameter None <1 h

HDPE = high

- density polyethylene; PETE = polyethylene terephthalate

.Testing and Monitoring Plan for FutureGen Alliance Page C 26 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 μ g/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 μ g/L 

### A.1.136 ±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 -

,

SO 4 2

-

, NO 3 - 

### 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 CaCO 3 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 Density



### A.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 Q uadruplicate 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 μg/L 

### A.1.183 ±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

13/12 C (1 13 C) of DIC in

Water 

### A.1.192 Gas Bench for 13/12 C 

### 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 C 27 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 14 C of DIC

in Water AMS for 14 C 

### 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 2/1 H (δ ) and

18/16 O (1 18 O) of Water



### A.1.201 CRDS H 2 O Laser 

### A.1.202 Range:

- 500‰ to
200‰ vs.

VSMOW 

### A.1.203 2/1 H: ± 2.0‰



### A.1.204 18/16 O:

± 0.3‰ 

### A.1.205 Duplicates and working

standards at 10%



### A.1.206 Carbon and Hydrogen

Isotopes ( 14 C, 13/12 C,

2/1 H) of Dissolved
Methane in Water



### A.1.207 Offline Prep & Dual Inlet IRMS for

13 C; AMS for 14 C 

### A.1.208 14 C Range: 0 & DupMC 

### A.1.209 14 C:

±0.5pMC



### A.1.210 13 C: ±0.2‰



### A.1.211 2/1 H: ±4.0‰



### A.1.212 Duplicates and working

standards at 10%



### A.1.213 Compositional Analysis

of Dissolved Gas in

Water (including N 2 , CO 2 , O 2 , Ar, H 2 , He,
CH 4 , C 2 H 6 , C 3 H 8 , iC 4 H 10 , nC 4 H 10 , iC 5 H 12 , nC 5 H 12 , and C 6 +)



### 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 ( 222 Rn)



### A.1.218 Liquid scintillation after pre

concentration 

### 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 Specific Conductance



### 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, s ee S ection 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 C 28 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 Eng ineering Design process. The selected indirect technologies will include the following:

 PNC logging for determination of reservoir CO 2 

### 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.

Monitoring Technique 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 min imum 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 min imum Continuous (1 scene per month)

Note: For details and information on con tinuous monitoring, see Table 1

.



### Pulsed-neutron capture logging

Once the reservoir model has been refined based on site-specific information from the injection
si te, predictive simulations of CO 2 

### a rrival 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,
inc luding 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

pe rmanent Global Positioning System (GPS) stations, tiltmeters, supplemented with annual Differential GPS (DGPS) surveys, and larger-scale Differential Interferometric SyntheticTesting and Monitoring Plan for FutureGen Alliance Page C 29 of 56
Permit Number: IL- 137

- 6A -0003 (Well #3) 

### Aperture Radar (DInSAR) surveys to detect and map temporal ground-surface deformation.
The se data reflect the dynamic geomechanical behavior of the subsurface in response to CO 2 

### 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.

Da ta 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 t ime -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 CO 2 

### 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
sub surface caused by

the migration of fluids, which could potentially help define the areal extent
of the CO 2 

### 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

F igure 3

. The coordinates (in decimal degrees) of the stations are provided in Appendix D.Testing and Monitoring Plan for FutureGen Alliance Page C 30 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

pre ssure front from the distribution of seismic events, and 3) identifying features that may indicate areas of caprock failure and possible containment loss. Seismic monitoring

c onsiderations are also addressed in the Emergency and Remedial Response Plan (Attachment F of this per

mit).

T esting & Monitoring Techniques and Procedures

The techniques and procedures in the Testing & Monitoring Plan may be revised to incorporate
be st practices that develop over time. Such revisions will be governed under Section B of this

pe rmit “PERMIT ACTIONS.”Testing and Monitoring Plan for FutureGen Alliance Page C 31 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

- 90.08901656Testing and Monitoring Plan for FutureGen Alliance Page C 32 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

 SLR 1 Well Construction and Drilling Information

 SLR2 Well Construction and Drilling Information

 RAT Well Construction and Drilling InformationTesting and Monitoring Plan for FutureGen Alliance Page C 33 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 si ngle-level in-reservoir well 1 (SLR1). These

se lected 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

re servoir wells, and three reservoir access tubes [RATs]). The ACZ wells will be used to collect fluid samples a nd for continuous pressure, temperature, specific conductance (P/T/SpC) and

mi croseismic 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

ne ar 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
Dolomi te. 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

F ormation 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 th e 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.

Af ter 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

a bove 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 C 34 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 C 35 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 C 36 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 C 37 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

re servoir. 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 sing le 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 c asing 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 C 38 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 C 39 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 C 40 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 C 41 of 56
Permit Number: IL- 137

- 6A -0003 (Well #3) 

### SLR 1 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.

Onc e 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

c ement 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 CO 2 

### infiltration into the more-reactive cement pores. Above the caprock and overlying the CO 2 

### 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.

T able 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 base d 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 C 42 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 C 43 of 56
Permit Number: IL- 137

- 6A -0003 (Well #3) Figure B- 6. Construction Detail for SLR1Testing and Monitoring Plan for FutureGen Alliance Page C 44 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 CO 2 

### -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 CO 2 

### -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 C 45 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 C 46 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, 9 48 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 C 47 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 CO 2 

### plum e based on numerical simulations of injected CO 2 

### movement. The RAT locations were selected to provide information about CO 2 

### arrival at different distances from the injection wells and at multiple lobes of the CO 2 

### plume. The RAT installations are planned for the collection of pulsed-neutron capture logs of the FutureGen CO 2 

### reservoir—the Mount Simon and Eau Claire
for mations. Design and construction requirements for the RAT installations are discussed in the following paragraphs.Testing and Monitoring Plan for FutureGen Alliance Page C 48 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 C 49 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 CO 2


### - 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 C 50 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

Diam eter (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 C 51 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

- 90.0427Testing and Monitoring Plan for FutureGen Alliance Page C 52 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

- 90.07408Testing and Monitoring Plan for FutureGen Alliance Page C 53 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 injection. 247 39.79997642140

- 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

- 90.05850696Testing and Monitoring Plan for FutureGen Alliance Page C 54 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

- 90.08801028Testing and Monitoring Plan for FutureGen Alliance Page C 55 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 surfaceTesting and Monitoring Plan for FutureGen Alliance Page C 56 of 56
Permit Number: IL- 137

- 6A -0003 (Well #3)



### APPENDIX G: Quality Assurance and Surveillance Plan

# FutureGen 2.0

–

CO 2 

# 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

–

CO 2 

# 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 Di stribution 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 CO 2 

### 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

A ppendix B ...................................................................................................................................... App. B-1



### List of Figures

A.1 CO 2 

### 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 CO 2 

### (scCO 2 

### ) 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 CO 2 

### 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 CO 2 

### 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 Annul us 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

CO 2 

### 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 i onization 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...? (P acific Northwest National Laboratory’s web

- based syste m 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

scCO 2 

### 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 in organic 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
di oxide (CO 2 

### ) 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 CO 2 

### 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

T yler. G ilmore@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 ; CO 2 Plume and Pressure

- Front Tracking 509

- 371

- 7170

V ince. V ermeul@pnnl.gov

M. E. Kelley Battelle Columbus Task Lead

− CO 2 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

F rank. S pane@pnnl.gov

### A.10



### A.4 Project/Task Organization

The high-level project organizational structure for the FutureGen 2.0 CO 2 

### Pipeline and Storage Project is shown in Figure A. 1 (Alliance 2013a).

Figure A

. 1 . CO 2 

### 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 CO 2 

### Pipeline and Storage Project is led by the Chief Executive Officer (CE O) 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 CO 2 

### 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 updat ing 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

dat a. 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 CO 2 

### 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 CO 2 

### 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 CO 2 

### off-gas from a oxycombustion coal-fueled power plant located in Meredosia, Morgan County, Illinois. Using safe and proven pipeline technology, the CO 2 

### 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 CO 2 

### each year, for a planned duration of at least 20 years.

The objective of the CO 2 

### Pipeline and Storage project is to demonstrate utility-scale integration of transport and permanent storage of captured CO 2 

### in a deep geologic formation (a.k.a. geologic sequestration) and to demonstrate that this can be done safely and ensure that the injected CO 2 

### is retained within the intended storage reservoir.

A.5.2 Background

The U.S. Environmental Protection Agency (EPA) established requirements for CO 2 

### 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 CO 2 

### 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 CO 2 

### plume and pressure-front tracking. These requirements (40

C FR 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 CO 2 

### Pipeline and Storage Project will undertake testing and monitoring as part of its

MV A program to verify that the Morgan County CO 2 

### storage site is operating as permitted and is not endangering any USDWs. The MVA program includes operational CO 2 

### 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 process es as sociated with CO 2 

### 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 Post

Injection 50 yr

CO 2 Stream Analysis Grab sampling and

analysis 3 events, during commissioning Quarterly Quarterly Quarterly NA

Continuous Recording of

I njection

P ressure, Rate

, and Annulus

P ressure 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 Semi

Annual Annual 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 Fall

Off Testing Injection well pressure

fall

- off testing NA Every 5 yr Every 5 yr Every 5 yr NA

Direct CO 2 Plume and

Pressure

- Front Monitoring Fluid sample collection

and analysis in SLR monitoring wells 3 events Quarterly Semi

Annual Annual Every 5 yr

Electronic P/T/SpC probes
installed in SLR wells 1 yr min Continuous Continuous Continuous Continuous

Indirect CO 2 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 CO 2 

### Injection Stream and Corrosion/Well Integrity Monitoring

The CO 2 

### 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 CO 2 

### Pipeline and Storage Project. Periodic grab samples will also be collected and analyzed to track CO 2 

### 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.

CO 2 

### Stream Analysis

The composition and purity of the CO 2 

### 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 CO 2 

### 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

t hermocouples (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) ev aluating CO 2 

### 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). B oth 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 CO 2 

### is effectively sequestered within the

t argeted 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 CO 2 

### . The results for this comprehensive set of analytes will be evaluated and a determination made regarding which analytes to carry forward through the operational phas es 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.

I ndicator parameters will be used to inform the monitoring program. Once baseline conditions and early

CO 2 

### 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 CO 2 

### 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,

wh ich 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 CO 2 

### , wells will initially be monitored for changes in geochemical and isotopic signatures that may provide indication of CO 2 

### 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 monitor ing 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 CO 2 

### (scCO 2 

### ) 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

CO 2 

### or CO 2 

### -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 casingand 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.

CO 2 

### 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 CO 2 

### or CO 2 

### -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 CO 2 

### saturation levels. Once supercritical carbon dioxide ( sc CO 2 

### ) arrives, these wells can no longer provide representative fluid samples because of the two-phase fluid characteristics and buoyancy of scCO 2



### .

Indirect CO 2 

### Plume and Pressure-Front Tracking

The primary objectives of indirect (e.g., geophysical) monitoring are 1) tracking CO 2 

### plume evolution and

CO 2 

### 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 CO 2 

### saturations within the Mount Simon injection zone or reservoir (Muller et al. 2007). PNC logging will serve as the primary

measure for CO 2 

### 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 CO 2 

### plume based on numerical simulations of injected CO 2 

### movement. The RAT locations were selected to provide information about CO 2 

### arrival at different distances from the injection wells and at multiple lobes of the CO 2 

### plume.

Geophysical Monitoring

Table A.4. Monitoring Technologies and Decision to Include in Monitoring Plans

Technology Purpose Analysis & Limitations

Pulsed

- Neutron Capture Logging Monitors CO 2 saturation changes along

boreholes. Used for reservoir model
calibration and leak detection. Will provide quantitative CO 2 saturations. Sensitive only to region around the borehole.

Integrated Surface
Deformation Monitoring Monitors subtle changes in the E arth’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 CO 2 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 CO 2 

### 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 CO 2 

### 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 CO 2 

### injection.



### A.7 Quality Objectives and Criteria for Measurement Data

T he primary goal of testing and monitoring activities is to verify that the Morgan County CO 2 

### storage site

i s 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 we ll 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 Cl ass VI Ru le 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 CO 2 

### 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 CO 2 

### 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- CO 2 

### 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 CO 2 

### 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 CO 2 

### 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 CO 2 

### 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 criteri a.

### A.23 Table A.5. CO 2 

### Injectate Monitoring Requirements

Analytical

Parameter Analytical Method # Detection Limit or (Range) Typical

Precision/Accuracy Q C Requirements

P ressure Analog gauges,

pressure transmitters 0

- 2500 psi Accuracy: ±0.065% of span CO 2 Pressure Transmitter,

Mfg: Rosemount Part No: 3051TG4A2B21AS5M5Q4

T emperature Thermocouples, or

resistance
temperature detectors 0

- 150 ° F Accuracy: ±0.03% of

span CO 2 Temperature Transmitter

Mfg: Rosemount Part No: 644HANAXAJ6M5F6Q4

F low 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.

CO 2 GC/TCD 0.1

- 100% ± 10% Replicate analyses within 10% of
each other

O 2 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/m 3 (filtered

volume) ±10% Daily calibration

Selenium ICP

- MS, EPA

Method 6020 5 ng/m 3 (filtered

volume) ±10% Daily calibration

Mercury (Hg) Cold vapor atomic

absorption (CVAA) 0.25 μg/m 3 ± 10% Daily calibration

H 2 S 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) o r equivalent. Method subject to change in subsequent rev isions.

### 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 f or 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 (qualit y 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
Annul us 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 requireme nts

Pressure Fall

- Off Testing
Well pressure; CO 2 injection rate

history. 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 CO 2 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 μ g/L 

### A.7.17 ±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 μ g/L 

### A.7.22 ±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 -

,

SO 4 2

-

, NO 3 - 

### 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 CaCO 3 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 Density



### A.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 μg/L 

### A.7.67 ±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

13/12 C (1 13 C) of DIC in

Water 

### A.7.78 Gas Bench for 13/12 C 

### 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 14 C of DIC

in Water AMS for 14 C 

### 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 2/1 H (δ) and

18/16 O (1 18 O) of Water



### A.7.87 CRDS H 2 O Laser 

### A.7.88 Range:

- 500‰ to

200‰ vs.

VSMOW 

### A.7.89 2/1 H: ± 2.0‰



### A.7.90 18/16 O:

± 0.3‰ 

### A.7.91 Duplicates and working

standards at 10%



### A.7.92 Carbon and Hydrogen

Isotopes ( 14 C, 13/12 C,

2/1 H) of Dissolved
Methane in Water



### A.7.93 Offline Prep & Dual Inlet IRMS for

13 C; AMS for 14 C 

### A.7.94 14 C Range: 0 & DupMC 

### A.7.95 14 C:

±0.5pMC



### A.7.96 13 C: ±0.2‰



### A.7.97 2/1 H: ±4.0‰



### A.7.98 Duplicates and working

standards at 10%



### A.7.99 Compositional Analysis

of Dissolved Gas in Water (including N 2 , CO 2 , O 2 , Ar, H 2 , He,
CH 4 , C 2 H 6 , C 3 H 8 , iC 4 H 10 , nC 4 H 10 , iC 5 H 12 , nC 5 H 12 , and C 6 +)



### 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 pre

concentration 

### 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 Specific Conductance



### 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

T emperature 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 C alibration 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 re calibration

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 re calibration

Temperature T emperature

logging 0

- 350 ° F 0.2 ° F Manufacturer calibration and periodic r e calibration

Gamma G amma

- ray

logging NA 1 count/API Manufacturer calibration and periodic re calibration

Velocity Passive seismic:

geophone 145 dB; 1

− 350 Hz 10

- 7 m/s Manufacturer calibration and periodic re calibration

Velocity Passive seismic:

seismometer 165dB ; 0.01

− 150

Hz 10

- 9 m/s Manufacturer calibration and periodic re calibration

Acceleration Passive seismic:

force balance
accelerometer 155 dB; DC

- 200

Hz 10

- 6 m / s 2 Manufacturer calibration and

periodic re calibration

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 re calibration

Deformation Integrated

deformation:

D InSAR NA <10 mm Space Agency calibration

Acceleration Time

- lapse gravity NA 10

- 8 m / s 2 (10

- 6 Gal) Manufacturer calibration and

periodic re calibration



### 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

r ecords 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 CO 2 

### 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 (CO 2 

### ) 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 ( sc CO 2 

### ) 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 CO 2 

### injection; determine whether the injected CO 2 

### 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.

We ll testing and monitoring activities are broken into eight main categories/subtasks, as listed below.

1. CO 2 

### Injection Stream Analysis – includes CO 2 

### 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 CO 2 

### 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 CO 2 

### Plume and Pressure-Front Tracking – includes PNC logging, passive seismic

m onitoring, 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 CO 2 

### 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 CO 2 

### stream, a list of parameters has been identified for analysis. Samples of the CO 2 

### stream will be collected regularly (e.g., quarterly) for chemical analysis.

Table B.1. Parameters and Frequency for CO 2 

### Stream Analysis

Parameter/Analyte Frequency

Pressure Continuous Temperature Continuous

CO 2 (%) 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 CO 2 

### stream will be obtained for analysis of gases, including CO 2 

### , O 2 

### , H 2 

### S, Ar, and water moisture. Samples of the CO 2 

### stream will be collected from the CO 2 

### 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 CO 2 

### to approximately 250 psi so that the CO 2 

### is collected in the gas

state rather than as a supercritical liquid. Cylinders will be purged with sample gas (i.e., CO 2 

### ) 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

T his 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 materia l 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

r ate, and volume, as well as the annulus pressure.

B.2.2 Sampling Methods

Continuous Recording of Injection Pressure and Temperatu re

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 CO 2 

### 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 CO 2 

### pipeline near the pipeline interface with the wellhead. The P/T of the injected CO 2 

### will be continuously measured for each well. The pressure will be measured by electronic pressure transmitter with analog output mounted on the CO 2 

### line associated with each injection well. The temperature will be measured by an electronic temperature transmitter mounted in the CO 2 

### 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 CO 2 

### 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 CO 2 

### storage site SCADA system for continuous monitoring and control of the CO 2 

### injection rate into each well. The flow rate into each well will be controlled using a flow-control valve located in the CO 2 

### 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

ev aluate 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 manufacturer s’ 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 wellsthroughout 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 CO 2 

### 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 CO 2 

### 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

fo r 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

t he 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

l ogging 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 CO 2 

### 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 CO 2 

### ). 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

l ogging 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 andmeasurement 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,

i nspection, 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

sa mpling 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 CO 2 

### 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 betransported 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, 19 th ed ition 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

ana lytes(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, sa mpling 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 CO 2 

### 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 CO 2 

### will have a cooling or heating effect on the natural temperature in the storage reservoirs, depending on the temperature of the injected CO 2 

### 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”

si gnature 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 CO 2 

### and the reservoir temperature. The greater the contrast in the CO 2 

### when

i t 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 CO 2 

### 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 CO 2 

### in jection 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 ( 16 

### O) to produce an isotope of nitrogen ( 16 

### N) 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

sour ce) 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

2 008) 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 CO 2 

### 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 inj ec tion 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

conduc ted on an opportunistic basis, for example, when each well is taken out of service. Temperature

and PN C 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 run s.

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 In strument/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;

h omogeneous vs. fractured media) as well as changes in near-well/reservoir conditions that may affect operational CO 2 

### 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

r eservoir 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 CO 2 

### 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 ofthe 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) recommendsthat 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

f all-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 frompurely 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 CO 2 

### ), 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 CO 2 

### 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

pr ogressively 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 (addition al 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

manufacturer s’ 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

ca libration, 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 CO 2 

### 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 CO 2 

### 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 CO 2 

### 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

CO 2 

### -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 CO 2 

### plume.

Three RAT wells will be installed within the boundaries of the projected 1- to 3-year CO 2 

### plume. The RAT well locations were selected to provide information about CO 2 

### arrival at different distances from the injection wells and at multiple lobes of the CO 2 

### plume. The RATs will be completed with nonperforated, cemented casings and will be used to monitor CO 2 

### 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 CO 2 

### plume and fully account for the injected

CO 2 

### 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 CO 2 

### 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 CO 2 

### or CO 2 

### - induced brine migration into the monitored interval. In addition, pH and Eh (oxidation potential) measurements may be useful for detecting dissolved CO 2 

### 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 CO 2 

### 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 CO 2 

### injection. The samples will be analyzed for chemical parameter changes that are indicators of the presence of CO 2 

### and/or reactions caused by the presence of CO 2 

### . 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 CO 2 

### 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 CO 2 

### saturation levels. Once scCO 2 

### arrives, these wells can no longer provide representative fluid samples because of the two-phase fluid characteristics and buoyancy of scCO 2



### .

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 se cured 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 betransported 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, 19 th ed. or later, Washington, D.C.). Laboratories shall be

r equired 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 calibrat ed

, 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

manufacturer s’ recommendations, and current calibration certificates will be kept on file with the

m onitoring data.



### B.8 Pulsed-Neutron Capture Logging

PNC wireline logs will be used to quantify CO 2 

### saturation relative to depth in each of three monitoring

RAT wells. These indirect measurements of CO 2 

### saturation will be used to detect and quantify CO 2 

### 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 CO 2 

### leakage across the primary confining zone. Numerical modeling will be used to predict the CO 2 

### plume growth and migration over time by integrating

the calculated CO 2 

### saturations in the three RAT wells with the geologic model and other monitoring data.

B.8.1 Sampling Process Design (Experimental Design)

PN C logs operate by generating a pulse of high-energy neutrons and subsequently measuring the neutron decay over time and across a wide energy spectrum. PN C 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 CO 2 

### saturation from PNC logs and will be simultaneously acquired.

PN C logging has been successfully implemented at a number carbon sequestration sites and while the

PN C method has been shown to work quite well, problems associated with CO 2 

### flooding the casing and perforation zone s have been identified. PN C 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 an alyzing response times from multiple detectors in the

tool. Porosities with in the reservoir at the FutureGen 2.0 storage site are moderate and the PN C logs are expected to adequately quantify CO 2 

### 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 CO 2 

### 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 CO 2 

### 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

CO 2 

### 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 In tegrated 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.

D ifferential 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.

Wi despread 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.

D ata 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 Custo dy

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 se t will then be inverted to constrain the CO 2 

### 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 annual ly

.

B.9.7 Instrument/Equipment Calibration and Frequency

Calibration of DI n SAR 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/s 2 

### )—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 CO 2



### . providing an indirect method of tracing the displacement of the

CO 2 

### 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

bei ng the KC0540 station (Central Plaza Park monument, Jacksonville, Illinois). Th e emplacement ofeach 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 Vision TM 

### 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

m easurements 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 CO 2 

### have the potential to induce seismic events.

T he 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 the ir

as sembly, 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

r esponse 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 design ed 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

t he 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 CO 2 

### Pipeline and Storage Project includes numerous categories, methods, and frequencies of monitoring the performance of the CO 2 

### 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

i mprovement, 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 CO 2 

### 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

r eviews. 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 areplaced 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 CO 2 

### Pipeline and Storage Project, personnel changes over time can result in loss of institutional memory about th e 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. CO 2 

### Pipeline and Storage Project Phase II, Project Management Plan . FGA-02-PMP – Revision 1. Washington, D.C.

Alliance (FutureGen Industrial Alliance, Inc.). 2013b. Configuration Management Plan

. Phase II, FG02-CMP, Rev. 0, Washington, D.C.

American Public Health Association, American Water Works Association, Water Environment Federation, 19 th ed. or later, Washington, D.C.

American Society for Testing and Materials (ASTM). 2011. Standard Practice for Preparing, Cleaning,

and Eva luating Corrosion Test Specimens . ASTM G1-03(2011), American Society for Testing and Materials, Philadelphia, Pennsylvania.

Bourdet, D., Ayoub, J.A. and Y.M. Pirard. 1989. “Use of pressure derivative in well-test interpretation. ”

SPE Formation Evaluation , June 1989, pp. 293-302.

Bryce RW, GV Last, D C Lanigan, and TB Miley. 2013. FutureGen 2.0 – CO 2 

### Pipeline and Storage Project, Project Data Management Plan. Revision 2a, FG -02- PLN -PDMP, Rev 2a. Battelle Pacific Northwest Division, Richland, Washington.

Duffield, GM. 2007. AQ TESOLV for Windows Version 4.5 User's Guide . HydroSOLVE, Inc., Reston, Virginia ( http://www.aqtesolv.com ).

Duffield GM. 2009. "Upgrading Aquifer Test Analysis, by William C. Walton." Ground Water - Comment Discussion Paper , 47(6):756-757.

Earlougher RC. 1977. Advances in well test analysis . Monograph Vol. 5, Society of Petroleum Engineers, Richardson, Texas.

EPA (United States Environmental Protection Agency). 2002. “UIC Pressure Falloff Testing Guideline.” EPA Region 6, August 8 2002, Third Revision; available on the Internet at: http://www.epa.gov/region6/water/ swp/uic/guideline.pdf.

EPA (United States Environmental Protection Agency). 2003. “The Nuts and Bolts of Falloff Testing.” EPA Region 6, March 5, 2003; available on the Internet at: http://www.epa.gov/safewater/dwa/pdfs/ 2%20uic%20modules/dwaUIC-2003falloffseminar.pdf.

EPA (United States Environmental Protection Agency). 2008. Determination of the Mechanical Integrity of Injection Wells. United States Environmental Protection Agency, Region 5 – Underground Injection Control (UIC) Branch Regional Guidance #5, Revised February, 2008. Online at http://www.epa.gov/r5water/uic/r5guid/r5_05_2008.htm

EPA (United States Environmental Protection Agency). 2012. “Geologic Sequestration of Carbon Dioxide: Draft Underground Injection Control (UIC) Program Class VI Well Testing and Monitoring

### E.2

Guidance. ” January 2012; available on the Internet at: http://water.epa.gov/type/groundwater/ uic/class6/upload/epa816r13001.pdf.

EPA (U.S. Environmental Protection Agency). 2013. Geologic Sequestration of Carbon Dioxide: Underground Injection Control (UIC) Program Class VI Well Testing and Monitoring Guidance . EPA 816-R-13-001, Washington D.C.

Horne RN. 1990. Modern well test analysis: a computer-aided approach. Petroway, Inc., Palo Alto,

California.

Lanigan DC, GV Last, and TB Miley. 2013. FutureGen 2.0 – CO2 Pipeline and Storage Project, Well

C onstruction Data Management Plan . Revision 0a, FG -02- PLN -TDMP02, Rev 0a, Battelle Pacific Northwest Division, Richland, Washington.

Muller N, TS Ramakrishnan, A Boyd, and S Sakruai. 2007. Time-lapse carbon dioxide monitoring with pulsed neutron logging. International Journal of Greenhouse Gas Control 1(4):456-472.

R enard P, D Glenz, and M Mejias. 2009. “Understanding diagnostic plots for well-test interpretation.” Hydrogeology Journal

17(3):589-600.

Spane FA . 1993. Selected Hydraulic Test Analysis Techniques for Constant-Rate Discharge Tests. PNL-8539, Pacific Northwest Laboratory, Richland, Washington.

Spane FA and SK Wurstner. 1993. “DERIV: A program for calculating pressure derivatives for use in hydraulic test analysis.” Ground Water 31(5):814:822.

Vermeul VR, RW Bryce, GV Last, DC Lanigan, and TB Miley. 2014. FutureGen 2.0 – CO 2 

### Pipeline and Storage Project, Monitoring Data Management Plan

. FG -02-PLN-TDMP04, Rev 0, Battelle Pacific Northwest Division, Richland, Washington. (Not publicly available)

### 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 i n 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