Post

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### ATTACHMENT E : POST

- INJECTION SITE CARE AND SITE CLOSURE P LAN

Facility Information

Facility name: Archer Daniels Midland, CCS#2 Well IL -115-6A-0001

Facility contact: Mr. Mark Burau , Plant Manager, 4666 Faries Parkway, Decatur, IL, (217 ) 424-5750, mark.burau@adm.com

Well l ocation: Decatur, Macon County, IL; 39o53’08”, -89o53’19”

This Post- Injection Site Care and Site Closure (PISC) plan describes the activities that ADM will perform to meet the requirements of 40 CFR 146.93. ADM will monitor ground water quality and track the position of the carbon dioxide plume and pressure front for ten (10) years. This alternative post

- injection sit e care timeframe was approved by EPA , but ADM may not cease post- injection monitoring until a demonstration of non-endangerment of USDWs has been approved by the UIC Program Director pursuant to 40 CFR 146.93(b)(3). Following approval for site closure, ADM will plug all monitoring wells, restore the site to its original condition, and submit a Site Closure report and associated documentation.

Pre - and Post

- Injection Pressure Differential

The formation pressure at the injection well is predicted to decline rapidly within the first 4 years following cessation of injection. Based on the modeling of the pressure front as part of the AoR delineation, pressure is expected to decrease to pre-injection levels by the end of the PISC timeframe. Additional informatio n on the projected post- injection pressure declines and differentials is presented in the permit application and the Area of Review and Corrective Action Plan (Attachment B to this permit)

.

Predicted Position of the CO 2 

### Plume and Associated Pressure Front at Site Closure

Figure 1 shows the predicted extent of the plume and pressure front at the end of the 10 year PISC timeframe , representing the maximum extent of the plume and pressure front

. This map is based on the final AoR delineation modeling results submitted in January 2014, per 40 CFR 146.84.Post

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- 0001 Figure 1: Predicted Extent of the CO 2 plume and pressure front at site closure (Est Yr 2030)



### Post -Injection Monitoring Plan

Performing ground water quality monitoring and plume and p ressure front tracking as described in the following sections during the post- injection phase will meet the requirements of 40 CFR 146.93(b)(1). The results of all post- injection phase testing and monitoring will be submitted annually, within 60 days of the anniversary date of the date on which injection ceases, as described under “Schedule for Submitting Post-Injection Monitoring Results,” below.

A quality assurance and surveillance plan (QASP) for all testing and monitoring activities during the injecti on and post injection phases is provided in the Appendix to the Testing and Monitoring Plan

.

Ground Water Quality Monitoring

Tables 1 and 2 present the planned direct and indirect monitoring methods, locations, and frequencies for ground water quality monitoring above the confining zone in the Quaternary and/or Pennsylvanian strata, the St. Peter Formation , and the Ironton- Galesville Sandstone. All of the monitoring wells are located on ADM property. Figure 2 shows the locations of the monitoring wells.Post

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- 0001 Table 1. Post

- Injection Phase Direct Ground Water Monitoring Above Confining Zone (1,2)

Target Formation Monitoring Activity Monitoring Location(s) Frequency: Year 1 Frequency: Years 2 -3 Frequency: Years 4 -9 Frequency: Year 10

Quaternary

and/or Pennsylvanian
strata Fluid sampling Shallow monitoring wells: MVA10LG, MVA11LG, MVA12LG, MVA13LG Annual Annual Annual Annual

Distributed Temperature S ensing (DTS) CCS#1 Continuous None None None

CCS#2 Continuous None None None

St. Peter Fluid sampling GM#2 Annual Annual Annual Annual

Pressure/ temperature monitoring GM#2 Continuous Continuous Annual Annual

DTS CCS#1 Continuous None None None

CCS#2 Continuous None None None

Ironton

Galesville Fluid sampling VW#2 Annual Annual Annual Annual

Pressure/ temperature monitoring VW#2 Continuous Continuous Annual Annual

DTS CCS#1 Continuous None None None

CCS#2 Continuous None None None

Note s : 1. Collection and recording of continuous monitoring data will occur at the frequencies described in Table 4. 2. Annual sampling and monitoring will occur up to 45 days before the anniversary date of cessation of injection or alternatively scheduled with the prior approval of the UIC Program Director.Post

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- 0001 Table 2. Post

- Injection Phase Indirect Ground Water Monitoring Above the Confining Zone (1)

Target Formation Monitoring Activity Monitoring Location(s) Frequency: Year 1 Frequency: Years 2 -3 Frequency: Years 4 -9 Frequency: Year 10

Quaternary and/or

Pennsylvanian
strata Pulse Neutron Logging/RST VW#1 Year 1 Year 3 Year 5, Year 7 Year 10

VW#2 Year 1 Year 3 Year 5, Year 7 Year 10

CCS#1 Year 1 Year 3 Year 5, Year 7 Year 10

CCS#2 Year 1 Year 3 Year 5, Year 7 Year 10

St. Peter Pulse Neutron Logging/RST VW#1 Year 1 Year 3 Year 5, Year 7 Year 10

VW#2 Year 1 Year 3 Year 5, Year 7 Year 10

CCS#1 Year 1 Year 3 Year 5, Year 7 Year 10

CCS#2 Year 1 Year 3 Year 5, Year 7 Year 10

Ironton

- Galesville Pulse Neutron Logging/RST VW#1 Year 1 Year 3 Year 5, Year 7 Year 10

VW#2 Year 1 Year 3 Year 5, Year 7 Year 10

CCS#1 Year 1 Year 3 Year 5, Year 7 Year 10

CCS#2 Year 1 Year 3 Year 5, Year 7 Year 10

Note 1 : Logging surveys will occur within 45 days before the anniversary date of cessation of injection or alternat iv ely scheduled with the prior approval of the UIC Program Director.Post

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### Table 3 identifies the parameters to be monitored and the analytical methods ADM will employ.

Table 3 . Indirect Summary of analytical and field parameters for groundwater samples

P ara m eters A na ly tical M eth o ds (1)

Quaternary/Pennsylvanian

Cations: Al, Ba, Mn, As, Cd, Cr, Cu, Pb, Sb Se, and Tl IC P

- MS

, E P A M ethod 6 0 20
Cations: Ca, Fe, K, Mg, Na, and Si ICP- OES, EPA Method 6010B
Anions: Br, Cl, F, NO 3 , and SO 4 Ion Chromatography, EPA Method 300.0

Dissolved CO 2 Coulometric titration, ASTM D513

- 11

Total Dissolved Solids Gravimetry; APHA 2540C

W ater D en sit y(field) Oscillating body method

A lkalinit y APHA 2320B

pH (field) EPA 150.1

S pecif ic con d uc t ance (field) APHA 2510

Tem peratu r e (field) Ther m ocouple

St Peter

Cations: Al, Ba, Mn, As, Cd, Cr, Cu, Pb, Sb Se, and Tl IC P

- MS

, E P A M ethod 6 0 20
Cations: Ca, Fe, K, Mg, Na, and Si ICP

- OES, EPA Method 6010B
Anions: Br, Cl, F, NO 3 , and SO 4 Ion Chromatography, EPA Method 300.0

Dissolved CO 2 Coulometric titration, ASTM D513

- 11
Isotopes: δ 13 C of DIC Isotope ratio mass spectrometry

Total Dissolved Solids Gravimetry; APHA 2540C

W ater D en sit y(field) Oscillating body method

A lkalinit y APHA 2320B

pH (field) EPA 150.1

S pecif ic con d uc t ance (field) APHA 2510

Tem peratu r e (field) Ther m ocouple

Ironton

- Galesville

Cations: Al, Ba, Mn, As, Cd, Cr, Cu, Pb, Sb Se, and Tl IC P

- MS

, EP A M ethod 6 0 20
Cations: Ca, Fe, K, Mg, Na, and Si ICP

- OES, EPA Method 6010B
Anions: Br, Cl, F, NO 3 , and SO 4 Ion Chromatography, EPA Method 300.0

Dissolved CO 2 Coulometric titration, ASTM D513

- 11Post

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- 0001 P ara m eters A na ly tical M eth o ds (1)

Isotopes: δ 13 C of DIC Isotope ratio mass spectrometry

Total Dissolved Solids Gravimetry; APHA 2540C

W ater D en sit y(field) Oscillating body method

A lkalinit y APHA 2320B

pH (field) EPA 150.1

S pecif ic con d uc t ance (field) APHA 2510

Tem peratu r e (field) Ther m ocouple
ICP = inductively coupled plasma; MS = mass spectrometry; OES = optical emission spectrometry; GC

- P = gas chromatography - pyrolysis. Note 1: An equivalent method may be employed with prior approval of the UIC Program Director.



### • Sampling will be performed as described in section B.2 of the QASP; this section of the QASP describes the ground water sampling methods to be employed, includ ing sampling SOPs (section B.2.a/b), and sample preservation (section B.2.g).

• Sample handling and custody will be performed as described in section B.3 of the QASP.

• Quality control will be ensured using the methods described in section B.5 of the QASP.

T able 4. Sampling and Recording Frequencies for Continuous Monitoring

Well Condition Minimum sampling frequency: once every Minimum recording frequency: once every

For continuous monitoring of the injection well: 5 seconds 5 minutes 1

For the well when shut

- in: 4 hours 4 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 fr equency refers to how often the sampled information gets recorded to digital format (such as a computer hard drive). Following the same example above, the data from the injection pressure transducer might be recorded to a hard drive once every minute.Post

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- 0001 Figure 2: Location of existing shallow groundwater monitoring wells and planned deep wells.Post

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### Carbon Dioxide Plume and Pressure Front Tracking

ADM will employ direct and indirect methods to track the extent of the carbon dioxide plume and the presence or absence of elevated pressure

.

Table 5 presents the direct and indirect methods that ADM will use to monitor the CO 2 

### plume, including the activities, locations, and frequencies ADM will employ. ADM will conduct fluid sampl ing and analysis to detect changes in ground water in order to directly monitor the carbon dioxide plume. The parameters to be analyzed as part of f luid sampling in the Mt. Simon (and associated analytical methods) are presented in Table 6. Indirect plume monitoring will be employed using pulsed neutron capture/reservoir saturation tool (RST) logs to monitor CO 2 

### saturation and 3D surface seismic surveys. Quality assurance procedures for seismic monitoring methods are presented in Section B.9 of the QASP.

Table 5

. Post

- Injection Phase Plume Monitoring

Target Formation Monitoring Activity Monitoring Location(s) Frequency: Year 1 Frequency: Years 2 -3 Frequency: Years 4 -9 Frequency: Year 10

Direct Plume Monitoring

Mt. Simon Fluid sampling VW#2 Annual Annual Annual Annual

Indirect Plume Monitoring

Mt. Simon Pulse Neutron Logging/RST VW#1 Year 1 Year 3 Year 5, Year 7 Year 10

VW#2 Year 1 Year 3 Year 5, Year 7 Year 10

CCS#1 Year 1 Year 3 Year 5, Year 7 Year 10

CCS#2 Year 1 Year 3 Year 5, Year 7 Year 10

3D surface seismic survey Northern extent of plume area (fold coverage ~ 600 acres) Once (Year 1) (Est 2020) None None Once (Year 10) (Est 2030)

Note 1: Sampling and geophysical surveys will occur within 45 days before the anniversary date of cessation of injection or alternatively scheduled with the prior approval of the UIC Program Director. Note 2: Seismic surveys will be performed in the 4th quarter before or the 1st quarter of the calendar year shown or alternativel y scheduled with the prior approval of the UIC Program Director.Post

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- 0001 Table 6 . Summary of analytical and field parameters for fluid sampling in the Mt. Simon (1)

P ara m eters A na ly tical M eth o ds (1)

Cations: Al, Ba, Mn, As, Cd, Cr, Cu, Pb, Sb Se, and Tl IC P

- MS

, EP A M ethod 6 0 20
Cations: Ca, Fe, K, Mg, Na, and Si ICP

- OES, EPA Method 6010B
Anions: Br, Cl, F, NO 3 , and SO 4 Ion Chromatography, EPA Method 300.0

Dissolved CO 2 Coulometric titration, ASTM D513

- 11
Isotopes: δ 13 C of DIC Isotope ratio mass spectrometry

Total Dissolved Solids Gravimetry; APHA 2540C

W ater D en sit y(field) Oscillating body method

A lkalinit y APHA 2320B

pH (field) EPA 150.1

S pecif ic con d uc t ance (field) APHA 2510

Te m peratu r e (field) Ther m ocouple ICP = inductively coupled plasma; MS = mass spectrometry; OES = optical emission spectrometry; GC

P = gas chromatography - pyrolysis. Note 1: An equivalent method may be employed with the prior approval of the UIC Program Director.



### Table 7 presents the direct and indirect methods that ADM will use to monitor the pressure front, including the activities, locations, and frequencies ADM will employ.

ADM will deploy pressure/temperature monitors and distributed temperature sensors to directly monitor the position of the pressure front. Passive seismic monitoring using a combination of borehole and surface seismic stations to detect local events over M 1.0 within the AoR will also be performed. Quality assurance procedures for seismic monitoring methods are presented in Section B.9 of the QASP.Post

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- 0001 Table 7

. Post

- Injection Phase Pressure Front Monitoring (1,2)

Target Formation Monitoring Activity Monitoring Location(s) Frequency: Year 1 Frequency: Years 2 -3 Frequency: Years 4 -9 Frequency: Year 10

Direct Pressure Front Monitoring

Mt. Simon Pressure/ temperature monitoring VW#2 Continuous 4 Intervals Continuous 4 Intervals Continuous 4 Intervals Continuous 4 Intervals

CCS#1 Continuous Continuous Annual Annual

CCS#2 Continuous Continuous Annual Annual

Distributed Temperature S ensing (DTS) CCS#1 Continuous None None None

CCS#2 Continuous None None None

Other Monitoring

Multiple Passive seismic A combination of borehole and surface seismic stations located within the AoR. Continuous Continuous Continuous Continuous

Note 1 : Collection and recording of continuous monitoring data will occur at the frequencies described in Table 4. Note 2: Annual monitoring surveys will occur up to 45 days before the anniversary date of cessation of injection or alternatively scheduled with the prior approval of the UIC Program Director.



### Schedule for Submitting Post

- Injection Monitoring Re sul ts

All p ost- injection site care monitoring data and monitoring results (i.e., resulting from the ground water monitoring and plume and pressure front tracking described above) will be submitted to EPA in annual reports . These reports will be submitted each year

, within 60 days following the anniversary date of the date on which injection ceases or alternatively with the prior approval of the UIC Program Director

. The annual reports will contain information and data generated during the reporting period; i.e. seismic data acquisition, well -based monitoring data, sample analysis, and the results from updated site models.

Alternative Post

- Injection Site Care Timeframe

ADM will conduct post-injection monitoring for ten years following the cessation of injection operations. ADM demonstrated that an alternative PISC timefram e is appropriate, pursuant to 40 CFR 146.93(c)(1). This demonstration is based on the computational modeling to delineate the AoR; predictions of plume migration, pressure decline, and carbon dioxide trapping; site- specific geology; well construction; and the distance between the injection zone and the nearest USDWs.Post

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### ADM will conduct all of the monitoring described under “Ground Water Quality Monitoring” and “Carbon Dioxide Plume and Pressure Front Tracking” above and report the results as described under the “Schedule for Submitting Post-Injection Monitoring Results .” This will continue until ADM demonstrates, based on monitoring and other site-specific data, that no additional monitoring is needed to ensure that the project does not pose an endangerment to any USDWs , per the requirements at 40 CFR 146.93(b) (2) or (3).

If any of the information on which the demonstration was based changes or the actual behavior of the site varies significantly from modeled predictions, e.g., as a result of an AoR reevaluation, ADM may update this PISC and Site Closure Plan pursuant to 40 CFR 146.93(a)(4). ADM will update the PISC and Site Closure Plan, within six months of ceasing injection or demonstrate that no update is needed and as necessary during the duration of the PI SC timeframe

.

Non

- Endangerment Demonstration Criteria

Prior to approval of the end of the PISC period, the operator will submit a demonst ra tion of nonendang er ment of USDWs to the UI C P rog ra m Dir ec tor, per 40 CFR 146.93(b) (2) or (3).

The operator will issue a report to the UI C P rogra m Direc to r . This report will make a demonst ra tion of USDW non-endang er ment based on the evaluation of the site monito r ing da ta used in conjunction with the project’s computational model. The report will detail how the non-endangerment demonstration evaluation uses site-specific conditions to confirm and demonstrate non- endangerment . T he re por t will in clude a ll re leva nt monitoring da ta and int er p re tations upon which the non-endangerment demonst ra tion is b ased, model documentation and all supporting data, and any othe r in formation n ece ssary for the UI C Prog ra m Dir ec tor to review the analysis. The report will include the following sections:

Su mmar y of Existing Monitoring Data

A summary of a ll p re vious monito ring da ta collected a t the sit e, pursuant to the Testing and Monitoring Plan (Attachment C of this permit) and th is PISC and Site Closure Plan

, in cluding da ta collected during the inj ec tion and PISC phases of the proj ec t, will be submitt ed to help demonst ra te non-endang er ment. Da ta sub mitt a ls will be in a format acceptable to the UIC Program Director [40 CFR 146.91 (e) ], and will include a n arra tive explanation of monitoring

ac tiviti es, including the date s of a ll monito ring events, change s to the monitoring pr og ra m over tim e, and an explana tion of a ll mon i to ring in fra st ruc tu re th at ha s ex ist ed a t the sit e. Da ta will be comp are d w ith b ase line da ta collected during site ch ar act er ization [40 CF R 1 46.82 (a)( 6) and 146.87(d)(3)].

Com parison of Monitor ing Data and Mode l Predi ct ions and Mode l Documentation

The re sults of computati on a l mod e ling used for AoR de lin ea tion and for demonst ra tion of an

a lt er na tive PI SC tim efr a me will be comp ar ed to monito ring data coll ec te d during the operational and the PI SC period. The data will include time- lapse temperature, pressure, ground water analysis, passive seismic, and geophysical surveys (i.e. logging, operating-phase VSP, and 3D surface seismic surveys), used to update the computational model and to monitor the site. Data generated during the PISC period will be used to help show that thePost

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### computational model accurately represents the storage site and can be used as a proxy to determine the plume’s properties and size. The operator will demonstrate this degree of accuracy by comparing the monito ring data obtained during the PISC period against the model ’s p re dicted properties (i.e. plume location, rate of movement, and p re ssu re decay). Statistical methods will be employed to correlate the data and confirm the model’s ability to accurately represent the storage site. The validation of the computational model with the large volume of available data will be a significant element to suppor t the non-endangerment demonst ra tion. Further, the validation of the complete model over the areas, and at the points, where direct data collection has taken place will help to ensure confidence in the model for those areas where surface infrastructure preclude geophysical data collection and where direct observation wells cannot be placed.

Evalua t ion of Car bon Dioxide Plume

The operator will use a combination of time

- lapse RST logs, time -lapse VSP surveys, and potentially other seismic methods (2D or 3D surveys) to locate and track the ext ent of the CO 2 

### plume. Figure 3 and Figure 4 present examples of how the data may be correlated against the model prediction. In Figure 3 , a series of RST logs are compared against the model’s predicted plume vertical extent at a specific point location at a specified time interval. A good correlation between the two data sets will help provide strong evidence in validating the model’s ability to represent the storage system. Similarly, Figure 4 illustrates a comparison of the time

- lapse VSPs against the predicted spa t ial extent of the plume at a specified time interval. Also, limited 2D and 3D seismic surveys may be employed to determine the plume location at specific times. The data produced by these activities will be compared against the model using statistical methods to validate the model’s ability to accurately represent the storage site.

Regarding the sep ara te-phase carbon dioxide plum e, the PISC monitoring data will be used to support a demonstration of the stabilization of the CO 2 

### plume as the reservoir pressure returns
to ward its pre

- injection state. The storage site (Mt . Simon) is considered to be an open reservoir system with a regio nal dip oriented NW (up-dip) to SE (down- dip) and having excellent porosity (20%) and permeability (120 mD). Locally, the storage interval has thin stratigraphic bands of low permeability siltstone to mudstone. These bands act as baffles that restrict th e plume’s vertical movement. Modeling performed to delineate the plume and pressure front predicts that, d uring the PISC period, the CO 2 

### will gradually rise through the reservoir until it encounters a baffle at which time it pools and spreads laterally. Based on the results of a 50
year post injection simulation, the top of the CO 2 

### plume is about 900 vertical feet below the primary seal formation (Eau Claire Shale). Additionally, the model predicts that over half the CO 2 

### will have become immobilized with in the formation. This, in conjunction with the reservoir pre ssu re returning to its pre

- injection state

, will be used to indicate th ere is essentially no driving force to cause significant plume movement. Indeed, the middle Mt. Simon contains intervals of eolian sandstone which are very tightly cemented by quartz overgrowths with some facies having permeabilities <0.01 mD. These intervals will act as more than a baffle and will significantly impede any ver tical plume migration due to buoyancy forces.Post

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- 0001 Figure 3 : Comparison of the time

- lapse RST logs against the predicted vertical extent of the plume at a specific time interval during the operational and PISC period can provide validation of the model’s accuracy

.

Figure 4 : Comparison of the time

- lapse VSPs against the predicted spa t ial extent of the plume at specific time intervals during the operational and PISC period can provide validation of the model’s accuracy. 

### Time Lapse RST logs show the development of the vertical extent of CO 2 

### over time.



### Time Lapse VSP surveys show the development of the vertical and lateral extent of CO 2 

### over time.Post

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- 0001 Figure 5 : Comparison of the time

- lapse surface 3D against the predicted spa t ial extent of the plume at specific time intervals during the operational and PISC period can provide validation of the model’s accura cy.



### The stabilization of the site conditions combined with the site’s characteristic of not having any local penetrations of the seal formation will be the central focus of the operator’s demonstration of

non- endangerment. Equalization of plume to the site’s pre -injection conditions will be one element in demonstrating non- endangerment . To demonstrate this

, a case was examined to determine how long it would take a slowly expanding plume to reach the nearest penetration of the seal formation. Show n in Figure 9 , the closest penetration of the seal formation is approximately 17 miles from the injection well. Assuming the plume continues to grow a t 1% per year, it would take over 600 years for the plume to reach this plugged and abandoned well. Because this well is down dip from the injection well, it is likely the plume will never reach this location.

Evalua t ion of Mobilized F luids

In addition to car bon di ox id e , mobi lized fluids may pose a risk to USDWs. The se in clude

na tive f luids th a t ar e high in TD S and ther ef ore may imp a ir a US DW , and fluids containing mobili zed drinking wa ter conta min ant s (e .g., ar se ni c, mercury, hydrogen sulf id e)

. The geoche mi ca l d a ta collected fr om monito ring we lls will be used to demonstrate th a t no mobilized f luids have moved above the seal formation and therefore after the PISC periodPost

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- 0001 

### would not pose a ri sk to USDWs. In order to demonstrate non

- endangerment, t he operator will compare the operational and PISC period samples from layers above the injection zone, including the lowermost USDW

, against the pre

- injection baseline samples. This comparison will support a demonstration that no significant changes in the fluid properties of the overlying formations have occurred and that no mobilized formation fluids have moved through the seal formation. This validation of seal integrity will help demonstrate that the injectate and or mobilized fluids would not represent an endangerment to any USDWs.

Additionally, RST logs will be used to monitor the salinity of the reservoir fluids in the observation zone above the Eau Claire Shale seal. Figure 6 shows the relationship between salinity and sigma for two different temperatures while Table 8 shows the compositions of the ground water at various intervals. This table shows the differenc e between the salinity level of the Mt Simon and the Ironton Galesville (the interval directly above the confining zone). By comparing the time lapse R S T logs against the pre

- injection baseline logs, the operator will be able to monitor any changes in res ervoir fluid salinity. RST logs indicating steady salinity levels within each zone would indicate no movement of fluids out of the storage unit, confirming the integrity of the well and seal formation.

Figure 6 : The red and blue lines show the relationship between salinity and sigma for at 100°F and 200°F.Post

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- 0001 Table 8. Fluid parameters for the Pennsylvanian, Ironton

- Galesville, and Mt Simon.

Constituent Pennsylvanian Ironton

- Galesville Mt. Simon

Conductivity (mS/cm) 1.5 80 170 TDS (mg/L) 1,000 65,600 190,000

Cl - (mg/L) 170 36,900 120,000

Br - (mg/L) 1 180 680 Alkalinity (mg/L) 380 130 80

Na + (mg/L) 140 17,200 50,000

Ca 2+ (mg/L) 100 5,200 19,000

K + (mg/L) 1 520 1,700 Mg 2+ (mg/L) 50 950 1,800

pH (units) 7.2 6.9 5.9



### Evalua t ion of Re s er voir Pre ssu re
The operator will also support a demonstration of non-endangerment to USDWs by showing that during the PISC period, the pressure within the Mt. Simon rapidly decreases to ward its
pre

- injection static reservoir pressure. Because the incr ea sed pre ssu re during injection is the
pr im ar y d r iving fo rc e for fluid moveme nt th a t m ay endanger a USDW, the decay in the
p re ssu re di ffe rentia ls w ill provide strong justification that the injectate does not pose a risk to any USDWs.

The operator will monitor the downhole reservoir pressure at various locations and intervals using a combination of surface and downhole pressure gauges. The measured pressure at a specific depth interval will be compared against the pressure predicted by the computational model. Agreement between the actual and the predicted values will help validate the accuracy of the model and further demonstr ate non

- endangerment. Figure 7 provides an illustrative example of how the operator will demonstrate agreement between the computational model prediction and the actual measured parameters at the various monitoring wells and respective measurement depths. This figure shows that during the 10 ye ar s of the PISC period, the actual reservoir p re ssu re (red line) falls to pre

- injection levels and has a decay rate similar to the rate predicted by the model. Based on r isk -based cr it er ia list e d in the PI SC a nd Site Closu re Pl an, p re ssu re dec line to ward p re -inj ec tion levels is one fac tor indica tive of USDW nonendangerment. The close alignment between the predicted and actual pressures will further validate the model’s accuracy in representing the reservoir system.Post

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- 0001 Figure 7 : Illustration of Verification Well #2 comparison of actual dP versus the predicted monitoring interval dP during PISC period through year 2030.


### One of the key comparisons that may be made is between the observed injection reservoir pressure and the model predicted pressure. Figure 8 shows the differential reservoir pressure predicted for three years after injection ceases relative to original static reservoir pressure. The contour southwest of the CCS#2 well is the 10 psi contour as predicted by the computational model. Direct observations will be utilized during the PISC period to verify that pressure observations at CCS#2 have declined in conformance with the model. Pressure decline to this level within this time frame is an indication of the excellent later al continuity within the regionally extensive, open Mt. Simon reservoir. Observed reduction of reservoir pressure to this extent would help validate the model and indicate substantial reduction in the potential of injection -pressure induced brine or CO 2 

### migration. -20 -10

0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160

2010 2015 2020 2025 2030 

## VW#2

- Pressure Differentials [P(t i 

## )

- P(t 0 

## )]

6,800

Actual 6,800 Pressure Port Mean Depth (ft)

Year(P[t]-P[0])[psi]Post

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- 0001 Figure 8 : Direct pressure measurements at CCS#1, CCS#2, & VW#2 will support the 10 psi differential pressure contour as predicted by the flow model (inside red circle) shown at January 1, 2023.



### Evalua t ion of Po te nt ial Conduits for F luid Moveme nt

As shown in the alternative PISC timeframe demonstration, other than the project wells, there
are no p otential conduits for flu id movement, or leakage pa th ways within the AoR. As shown in Figure 9 , the closest penetration of the seal formation is approximately 17 miles from the injection well. Based on the computational model, if the plume were to continue to grow at 1% per year it wo uld take over 600 years for the plume to reach this well. Because this well is down dip from the injection well, it is likely the plume will never reach this location. Based on this information, the potential for fluid movement through artificial penetra tions of the seal formation does not present a risk of endangerment to any USDWs. Aggregate reservoir pressure ha s returned to pre

- injection conditions

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- 0001 Figure 9 : The closest penetration the seal formation (Eu Claire) is 17.2 miles from CCS#2. Based on a plume growth of 1.0% per year, it would take over 600 years for the project’s CO 2 plume to reach this well.



### Evalua t ion of P assive Seismic Data

Fi nally, passive seismic monitoring will be used to help further demonstrate seal formation integrity. The operator will provide seismic monitoring data showing that no seismic event s have occurred that would indicate fracturing or fault activation near or through the seal formation. This validation of seal integrity will provide further support for a demonstration that the CO 2 

### plume is no longer an endangerment to any USDWs. Figure 10 illustrates how these data could be presented. This figure shows a subset of locatable microseismic events occurring during part of the IBDP project’s operational period. From this figure one can see that a majority of the microseismic events occur in the lower Mt Simon and the Precambrian basement. No events are observed near the Eau Claire seal formation indicating that no f racturing or fault activation is occurring within this formation. This provides additional verification of the Eau Claire formation’s seal integrity and indicates that to date the response to the imposed fluid pressures due to injection are confined to the vicinity of the injection zone and below.Post

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- 0001 Figure 10 : Visual representation showing the microseismic activity occurring during the injection and post injection periods. (Figure provided by IBDP project)



### Site Closure Plan

ADM will conduct site closure activities to meet the requirements of 40 CFR 146.93(e) a s descri bed below. ADM will submit a final Site Closure Plan and notify the permitting agency at least 120 days prior of its intent to close the site. Once the permitting agency has approved closure of the site, ADM will plug the verification well (s) and geophysical well (s) ; restore the site and move out all equipment ; and submit a site closure report to EPA. The activities

, as described below, represent the planned activities based on information provided to EPA in November 2013. The actual site closure plan may employ different methods and procedures . A final Site Cl osure Plan will be submitted to the UIC Program Director for approval with the notification of the intent to close the site. Injection Period PISC Period Microseismic Locations



### CCS2Post

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### Plugging the Verification Well (s)

T he well will be flushed with a kill weight brine fluid. A minimum of three tubing volumes will be injected without exceeding fracture pressure. A final external MIT will be conducted to ensure mechanical integrity. Detailed plugging procedure s are provided below. All casing in this well will be cemented to surface and will not be retrievable at abandonment. After injection ceases and after the appropriate post -injection monitoring period is finished, the completion equipment will be removed from the well

.
Type and Quantity of Plugging Materials, Depth Intervals

The volume and depth of the plug or plugs will depend on the final geology and downhole conditions of the well as assessed during construction. Well cementing software (e.g. Schlumberger’s CemC ade) will be used to model the plugging and aid in the plug design. The cements used for plugging will be tested in the lab prior to plug placement and both wet and dry samples will be collected during plugging for each plug to ensure quality of the plug.

All of the casing strings will be cut off at least 3 feet below the surface, below the plow line. A blanking plate with the required permit information will be welded to the top of the cutoff casing.

Volume Calculations

Volumes will be calculated for the specific abandonment wellbore environment based on desired plug diameter and length required. The methodology employed will be to:

1) Choose the following: a. Length of the cement plug desired. b. Desired setting depth of base of plug. c. Amount of spacer to be pumped ahead of the slurry.

2) Determine the following: a. Number of sacks of cement required. b. Volume of spacer to be pumped behind the slurry to balance the plug. c. Plug length before the pipe is withdrawn. d. Length of mud freefall in drill pipe. e. Displacement volume required to spot the plug.Post

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### Plugging and Abandonment Procedure:

At the end of the serviceable life of the verification well, the well will be plugged and abandoned. In summary, the plugging procedure will consist of removing all components of the completion system and then placing cement plugs along the entire length of the well. Prior to placing the cement plugs

, casing inspection and temperature logs will be run confirming external mechanical integrity. If a loss of integrit y is discovered then a plan to repair using the cement squeeze method will be prepared and submitted to the agency for review and approval. At the surface

, the well head will be removed ; and the casing will be cut off 3 feet below surface. A detailed proce dure follows:

1. Move in workover unit with pump and tank. 2. Record bottom hole pressure using down hole instrumentation and calculate kill fluid density. Pressure test annulus as per annual MIT requirements. 3. Fill both tubings with kill weight brine as calcula ted from Bottom hole pressure measurement (expected approximately 9.5 ppg). 4. Nipple down well head and nipple up BOPs. 5. Remove all completion equipment from well. 6. Keep hole full with workover brine of sufficient density to maintain well control. 7. Log well wi th CBL, temp erature , mechanical inspection log to confirm external mechanical integrity. 8. Pick up work string (either 2 7/8’’ or 3 1⁄2’’) and trip in hole to PBTD. 9. Circulate hole two wellbore volumes to ensure that uniform density fluid is in the well. 10. The lower section of the well will be plugged using CO 2 

### resistant cement from TD around 7000ft to around 1000ft above the top of the Eau Claire formation (to approximately 4000 ft). This will be accomplished by placing plugs in 500 foot increments. Using a den sity of 15.9 ppg slurry with a yield of 1.11 cf/sk, approximately 360 sacks of cement will be required ( to incorporate a safety factor , 423 sacks are assumed: 3000 ft X .1305 cu ft/ft x 1.2 excess / 1.11 cf/sk = 423 sacks). Actual cement volume will depend upon actual weight of the casing within the plugged zone. This will require at least six plugs of 500 feet in length. No more than two plugs will be set before cement is allowed to set and plugs verified by setting work string weight down onto the plug. 11. Pull ten stands of tubing (600 ft) out and shut down overnight to wait on cement curing. 12. After appropriate waiting period, TIH ten stands and tag the plug. Resume plugging procedure as before and continue placing plugs until the last plug reaches the surfac e. 13. Nipple down BOPs. 14. Remove all well head components and cut off all casings below the plow line. 15. Finish filling well with cement from the surface if n eeded. Total of approximately 442 sacks total cement used in all remaining plugs above 4000 feet (4000 ft X .1305 cu ft/ft / 1.18 cu ft/sk = 442 sks). Cement calculations based on using Class A cement from 4000 ft back to surface with a density of 15.6 ppg and a yield of 1.18 cu ft /sk. Lay down all work string, etc. Clean cellar to where a plate can be wel ded with well name onto lowest casing string at 3 feet, or as per permitting agency directive. 16. If required, install permanent marker back to surface on which all pertinent well information is inscribed.Post

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### 17. Fill cellar with topsoil. 18. Rig down workover unit and move out all equipment. Haul off all workover fluids for proper disposal. 19. Reclaim surface to normal grade and reseed location. 20. Complete plugging forms and send in with charts and all lab information to the regulatory agency. Plugging report shall be cer tified as accurate by ADM and shall be submitted within 60 days after plugging is completed.

Note: 7,000 ft 5 1⁄2” 17 #/ft (7000 ft X .1305 cu ft/ft = 914 cu ft) casing requires an estimated 914 cubic feet of cement to fill 14 plugs. An excess factor of 20% is being suggested on the lower 3000ft to accommodate cement that might be lost to the formation so total material used would be 423 sacks of EverCRETE CO 2 

### resistant cement and 442 sack Class A/H cement.

Approximately five days are required fr om move in to move out, depending on the operations at hand and the physical constraints of the well, weather, and other conditions.

See the figure below for a plugging schematic. (Perforation zone(s) are estimated. Well plugging plan will be updated and submitted with the well completion report.)Post

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- 0001 Figure 11 : Representative Plugging schematic - verification well

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### Plugging the Geophysical Well (s)

At the end of the serviceable life of the well, the well will be plugged and abandoned utilizing the following procedure:

1. Notify the permitting agency of abandonment at least 60 days prior to plugging the well. 2. Remove any monitoring equipment from well bore. Well will contain fresh water or a mixture of fresh water and native St. Peter formation water. 3. Nipple down well head and connect cement pump truck to 4 1⁄2 inch casing. Establish injection rate with fresh water. Mix and pump 247 sacks Class A cement (15.9 ppg). Slow injection rate to 1⁄2 bbl/min as cement starts to enter St. Pete r perforations. Continue squeezing cement into formation until a squeeze pressure of 500 psi is obtained. Monitor static cement level in casing for 12 hours and fill with cement if needed to top out. Plan to have 50 sacks additional cement above calculated volume on location to top out if needed. (T o incorporate a safety factor , 255 sacks are assumed: 3450 ft X .0873 cu ft/ft / 1.18 cu ft/sk = 255 sacks.) 4. After cement cures , cut off all well head components and cut off all casings below the plow line. 5. Insta ll permanent marker at surface, or as required by the permitting agency. 6. Reclaim surface to normal grade and reseed location.

See the figure below for a plugging schematic.Post

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- 0001 Figure 12 : Representative Plugging schematic - geophysical well

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### Planned Remedial/Site Restoration Activities

To restore the site to its pre -injection condition following site closure, ADM will be guided by the state rules for plugging and abandonment of wells located on leased property under The Illinois Oil and Gas Act: Title 62: Mining Chapter I: Department of Natural Resources - Part 240, Section 240.1170 - Plugging Fluid Waste Disposal and Well Site Restoration.

The following steps w ill be taken:

1. The free liquid fraction of the plugging fluid waste, which may consist of produced water and /or crude oil, shall be removed from the pit and disposed of in accordance with state and federal regulations (e.g., injection or in above ground tanks or containers pending disposal) prior to restoration. The remaining plugging fluid wastes shall be disposed of by

on- site burial. 2. All plugging pits shall be filled and leveled in a manner that allows the site to be returned to original use with no subsidence or leakage of fluids, and where applicable, with sufficient compaction to support farm machinery. 3. All drilling and production equipment, machinery, and equipment debris shall be removed from the site. 4. Casing shall be cut off at least four (4) feet below the surface of the ground, and a steel plate welded on the casing or a mushroomed cap of cement approximately one (1) foot in thickness shall be placed over the casing so that the top of the cap is at least three (3) feet below ground level. 5. Any drilling rat holes s hall be filled with cement to no lower than four (4) feet and no higher than three (3) feet below ground level. 6. The well site and all excavations, holes and pits shall be filled and the surface leveled.

Site Closure Report

A site closure report will be pr epared and submitted within 90 days following site closure, documenting the following:

• Plugging of the verification and geophysical wells (and the injection well if it has not previously been plugged),

• Location of sealed injection well on a plat of survey that has been submitted to the local zoning authority,

• Notifications to state and local authorities as required at 40 CFR 146.93(f)(2),

• Records regarding the nature, composition, and volume of the injected CO 2 

### , and

• Post- injection monitoring reco rds.

ADM will record a notation to the property’s deed on which the injection well was located that will indicate the following:

• That the property was used for carbon dioxide sequestration,Post

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### • The name of the local agency to which a plat of survey with injection well location was submitted,

• The volume of fluid injected,

• The formation into which the fluid was injected, and

• The period over which the injection occurred.

The site closure report will be submitted to the permitting agency and maintained by the opera tor for a period of 10 years following site closure. Additionally, the operator will maintain the records collected during the PISC period for a period of 10 years after which these records will be delivered to the Director.

Quality Assurance and Surveillance Plan (QASP)

The Q uality Assurance and Surveillance Plan is presented in the Appendix of the Testing and Monitoring Plan.