## Illinois Industrial Carbon Capture and Sequestration (IL

- ICCS) P roject Class VI Injection Well: Quality Assurance and Surveillance Plan

U.S. EPA ID Number ( IL

- 115

- 6A

- 0001 )

April 2014

Prepared by: Archer Daniels Midland Company (ADM)

### ii 

## Table of Contents

**A. PROJECT MANAGEMEN T**  **1**

A.1. Project/Task Organization 1 A.1.a/b. Key Individuals and Responsibilities 1 A.1.c. Independence from Project QA Manager and Data Gathering 1 A.1.d. QA Project Plan Responsibility 1 A.1.e. Organizational Chart for Key Project Personnel 1

A.2. Problem Definition/Background 2
A.2.a Reasoning 2

A.2.b. Reasons for Initiating the Project 3 A.2.c. Regulatory Information, Applicable Criteria, Action Limits 3

A.3. Project/Task Description 3 A.3.a/b. Summary of Work to be Performed and Work Schedule 3 A.3.c. Geographic Locations 10

A.3.d. Resource and Time Constraints 11

A.4.Quality Objectives and Criteria 11 A.4.a. Performance/Measurement Criteria 11

A.4.b. Precision 19

A.4.c. Bias 19 A.4.d. Representativeness 19 A.4.e. Completeness 20 A.4.f. Comparability 20 A.4.g. Metho d Sensitivity 20

A.5. Special Training/Certifications 21 A.5.a. Specialized Training and Certifications 21 A.5.b/c. Training Provider and Responsibility 22

A.6. Documentation and Records 22 A.6.a. Report Format and Package Information 22 A.6.b. Other Project Documents, Records, and Electronic Files 22 A.6.c/d. Data Storage and Duration 22 A.6.e. QASP Distribution Responsibility 22

**B. DATA GENERATION A ND ACQUISITION**  **22**

B.1. Sampling Process Design (Experimental Design) 22
B.1.a. Design Strategy 23

CO 2 Stream Monitoring Strategy 23

### iii Corrosion Monitoring Strategy 23 Shallow Groundwater Monitoring Strategy 23 Deep Groundwater Monitoring Strategy 23 GM#2 Sampling 24 VW#1 Sampling 24 VW#2 Sampling 24 B.1.b Type and Number of Samples/Test Runs 24 B.1.c. Site/Sampling Locations 24 B.1.d. Sampling Site Contingency 25 B.1.e. Activity Schedule 25 B.1.f. Critical/Informational Data 25 B.1.g. Sources of Variability 25

B.2. Sampling Methods 25 B.2.a/b. Sampling SOPs 26

B.2.c. In

- situ Monitoring. 27 B.2.d. Continuous Monitoring. 27

B. 2.e. Sample Homogenization, Composition, Filtration. 27 B.2.f. Sample Containers and Volumes 27 B.2.g. Sample Preservation 27 B.2.h. Cleaning/Decontamination of Sampling Equipment 28 B.2.i Support Facilities 28 B.2.j. Corrective Action, Personnel, and Documentation 28

B.3. Sample Handling and Custody 29 B.3.a Maximum Hold Time/Time Before Retrieval 29 B.3.b. Sample Transportation 29 B.3.c. Sampling Documentation 29 B.3.d. Sample Identification 29 B.3.e. Sample Chain

- of

- Custody 31

B.4. Analytical Methods 31

B.4.a. A nalytical SOPs 31

B.4.c. Method Performance Criteria 31 B.4.d. Analytical Failure 31 B.4.e. Sample Disposal 31

B.4.f Labo ratory Turnaround 31 B.4.g. Method Validation for Nonstandard Methods 32

B.5. Quality Control 35

B.5.a. QC activities 35

Blanks 35 Duplicates 35 B.5.b. Exceeding Control Limits 35

### iv B.5.c. Calculating Applicable QC Statistics 35 Charge Balance 35

Mass Balance 35

Outliers 36

B.6. Instrument/Equipment Testing, Inspection, and Maintenance 36

B.7. Instrument/Equipment Calibration and Frequency 36 B.7.a. Calibration and Frequency of Calibration 36

B.7.b. Calibration Methodolo gy 36

B.7.c. Calibration Resolution and Documentation 36

B.8. Inspection/Acceptance for Supplies and Consumables 37 B.8.a/b. Supplies, Consumables, and Responsibilities 37

B.9. Nondirect Measurements 37 Seismic Monitoring Methods 37

B.9.a Data Sources 37 B.9.b. Relevance to Project 37

B.9. c. Acceptance Criteria 37 B.9.d. Resources/Facilities Needed 37 B.9.e. Validity Limits and OperatingCconditions 38

B.10. Data Management 38 B.10.a. Data Management Scheme 38

B.10.b. Record

- keeping and Tracking Practices 38 B.10.c. Data Handling Equipment/Procedures 38 B.10.d. Responsibility 38

B.10.e. Data Archival and Retrieval 38 B.10.f. Hardware and Software Configurations 38
B.10.g. Checklists and Forms 38

**C. ASSESSMENT AND OV ERSIGHT**  **38**

C.1. Assessments and Response Actions 38

C.1.a. Activities to be Conducted 38 C.1.b. Responsibility for Conducting Assessments 38
C.1.c. Assessment Reporting 39

C.1.d. Corrective Action 39

C.2. Reports to Management 39 C.2.a/b. QA status Reports 39

**D. DAT A VALIDATION AND USA**  **BILITY 39** 

### v D.1. Data Review, Verification, and Validation 39 D.1.a. Criteria for Accepting, Rejecting, or Qualifying Data 39

D.2. Verification and Validation Methods 40

D.2.a. Data Verification and Validation Processes 40 D.2.b. Data Verification and Validation Responsibility 40 D.2.c. Issue Resolution Process and Responsibility 40
D.2.d. Checklist, Forms, and Calculations 40

D.3. Reconciliation with User Requirements 40 D.3.a. Evaluation of Data Uncertainty 40 D.3.b. Data Limitations Reporting 40

**REFERENCES 41** 

ASTM, 2005, Method D64 52

- 99 (reapproved 2005), Standard Guide for Purging Methods for Wells Used for

Ground

- Water Quality Investigations , ASTM International, 100 Barr Harbor Drive, West Conshohocken, PA. 41

**APPENDICES 43** 

APPENDIX A. DTS and Do wn
- hole Pressure Gauge Information 43

APPENDIX B. Log Quality Control Reference Manual (LQCRM) 48

### vi 

### List of Tables

TABLE 1. SUMMARY OF TESTING AND MONITORI NG. 4

TABLE 2. INSTRUMENTATION SU MMARY. T = TEMPERATU RE; P = PRESSURE; DT S = DISTRIBUTED TEMP ERATURE SYSTEM; F = FLOW (CO NTINUED ON PAGE 9). 7

TABLE 3 . GEOPHYSICAL SURVEY S SUMMARY. 9

TABLE 4. SUMMARY OF ANALYTICA L AND FIELD PARAMETERS FOR QUATERNARY/PE NNSYLVANIAN

GROUNDWATER SAMPLES. 13

TABLE 5. SUMMARY OF ANALYTICA L AND FIELD PARAMETERS FOR ST PETER RESE RVOIR GROUNDWATER

SAMPLES. 14

TABLE 6. SUMMARY OF ANALYTICA L AND FIELD PARAMETE RS FOR IRONTON

- GALESVILLE GROUNDWAT ER

SAMPLES. 15

TABLE 7. SUMMARY OF ANALYTICA L AND FIELD PARAMETE RS FOR MT SIMON GROU NDWATER SAMPLES. 16

TABLE 8 . SUMMARY OF ANALYTICAL PARAMETERS FOR C O 2 GAS STREAM. 17

TABLE 6 . SUMMARY OF ANALYTICAL PARAMETERS FOR C ORROSION COUPONS. 18

TABLE 7 . SUMMARY OF MEASURE MENT PARAMETERS FOR FIELD GAUGES. 18

TABLE 8 . ACTIONABLE TESTING AND MONITORING OUTPU TS. 19

TABLE 12 . PRESSURE AND TEMPE RATURE

— DOWNHOLE QUAR TZ GAUGE SPECIFICATI ONS. 20

TABLE 10 . LOGGING TOOL SPECI FICATIONS. 20

TABLE 11 . PRESSURE FIELD GAU GE PIT

- 009

— INJECTION TUBING PRE SSURE. 20

TABLE 12 . PRESSURE FIELD GAU GE PIT

- 014

— ANNULS PRESSURE. 21

TABLE 13 . PRESSURE FIELD GAU GE PIT

- 012. 21

TABLE 14 . TEMPERTATURE FIELD GAUGE TIT

- 019

— INJECTION TUBING TEM PERATURE. 21

TABLE 15 . MASS FLOW RATE FIE LD GAUGE

— FT

- 006 CO 2 MASS FLOW RATE. 21

TABLE 16 . WESTBAY FIELD GAUG E— WESTBAY (MOSDAX) PRE SSURE. 21

TABLE 17. STABILIZATION CRITERIA OF WATE R QUALITY PARAMETERS DURING SHALLOW WELL PURGING. 26

TABLE 18. SUMMARY OF SAMPLE CONTAINERS, P RESERVATION TREATMEN TS, AND HOLDING TIME S FOR CO 2 GAS

STREAM ANALYSIS. 28

TABLE 19 . SUMMARY OF ANTICIPATED SAMPLE CONTAINE RS, PRESERVATION TRE ATMENTS, AND HOLDING TIMES.

30

TABLE 20. EXAMPLE TA BLE OF CRITERIA USED TO EVALUATE DATA QUA LITY. 40



### List of F **igures**

FIGURE 1. ARCHER DAN IELS MIDLAND COMPANY KEY PROJECT PERSONNE L. 2

FIGURE 4. IL

- ICCS PROJECT AREA SH OWING LOCATION OF EXISTING SHALLOW GROUNDWATER MONITORING

WELLS AND PLANNED DE EP WELLS. 10

FIGURE 5. EXAMPLE LA BEL FOR GROUNDWATER SAMPLE BOTTLES. 31

FIGURE 6. EXAMPLE OF CO 2 GAS STREAM ANALYSIS AUTHORIZATION FORM. 33

FIGURE 7. EXAMPLE CH AIN- OF

- CUSTODY FORM. 34

### vii Distribution List The following project participants should receive the completed Quality Assurance and Surveillance Plan (QASP) and all future updates for the duration of the project. T he ADM Corn Plant Manager will be responsible for ensuring that all those on the distribution list will receive the most current copy of the approved Quality Assurance and Surveillance Plan. Names in bold are the primary points of contact with
addresses listed below.

ADM
Mark Burau
Dean Frommelt
Sean Stidham
Mark Atkinson

Archer Daniels Midland Company – Corn Processing Facilities Contact : Mr. Mark Burau, Corn Plant Manager Mailing Address : 4666 Faries Parkway Decatur, IL 62526
Phone : 217

- 424

- 5750

### 1 

## A. Project Management

**A.1. Project/Task Organization**

A.1.a/b. Key Individuals and R esponsibilities

The project, led by Archer Daniels Midland Company ( ADM ) , include s participation from several
subcontractors . The Testing and Monitoring Activities responsibilities will be shared between ADM and their designated subcontractor and the program will be broken in six subcategories:

I) Shallow Groundwater Sampling

II) Deep Groundwater Sampling

III) Well Logging

IV) Mechanical I ntegrity Testing (MIT)

V) Pressure/Temperature Monitoring

VI) CO 2 

### Stream Analysis

VII) Geophysical Monitoring

A.1.c. Independence from Project QA Ma nager and D ata G athering

The majority of the physical samples collected and data gathered as part of the MVA program is analyzed, processed, or witnessed by third parties independent and outside of the project management

structure.

A.1.d. QA Project Plan Responsibility

ADM will be responsible for maintaining and distributing official, approved QA Project Plan. ADM will periodically review this QASP and consult with USEPA if/when changes to the plan are warranted.

A.1.e. Organizational C hart for K ey P roject P ersonnel

Figures 1 show s the organization structure of the projec t. ADM will provide to the UIC Program Director

a contact list of individuals fulfilling these roles

.

### 2 Figure 1. Archer Daniels Midland Company p roject organization structure

.



### A.2

**. Problem Definition/Background** 

A.2.a Reasoning

The Illinois Industrial Carbon Capture and S torage ( IL

- ICCS ) Project’s monitoring, verification, and accounting ( MVA ) program has operational monitoring, verification, and environmental monitoring
components. Operational monitoring is used to en sure safety with all procedures associated with fluid injection , monitor the response of storage unit, and the movement of the CO 2 

### plume. Key monitoring parameters include the pressure of injection well tubing & annulus, storage unit, above seal strata

, and
the lowermost USDW re servoir. Other monitoring parameters include injection rate , total mass & volume injected, injection well temperature profile, and passive seismic. The verification component will provide information to evaluate if leakage of CO 2 

### through the caprock is occurring . This includes pulse neutron logging , pressure, and temperature monitoring. The environmental monitoring components will determine if the injectate is being released into the shallow subsurface or biosphere

. This monitoring includes pulse neutron logging and ground water monitoring.

A robust MVA program has been developed for the IL

- ICCS project based on the experience gained through the Illinois Basin

– Decatur Project (IBDP)

. The knowledge and experience gained through the

IBDP provide s a high level of confidence that the storage unit (Mt Simon) is capable to accept and
permanent ly retain the injectate. The p rimary goal of the IL

- ICCS MVA program is to demonstrate that project activities are protective of human health and the environme nt. To help achieve this goal, this Quality Assurance Surveillance Plan (QASP) was developed to insure the quality standards of the testing and monitoring program meet the requirements of the U.S. Environmental Protection Agency’s (USEPA) Underground Injec tion Control (UIC) Program for Class VI wells.

### 3 A.2.b. Reasons for I nitia ting the P roject

The goal of the IL

- ICCS injection project is to demonstrate the ability of the Mt. Simon Sandstone to accept and reta in industrial

- scale volumes of CO 2 

### for permanent geologic s equestration to reduce atmospheric concentrations of CO 2 

### . In order to demonstrate that this can be done safely and at commercial scale , a rigorous MVA plan is proposed to ensure the injected CO 2 

### is retained within the
intended stora ge reservoir

. A.2.c. Regulatory I nformation, A pplicable Criteria, A ction L imits

The Class VI Rule requires owners or operators of Class VI wells to perform several types of activities during the lifetime of the project in order to ensure that the injection well maintains its mechanical integrity, that fluid migration and the extent of pressure elevation are within the limits described in the

p ermit application, and that underground sources of drinking water ( USDWs ) are not endangered. These monitoring activ ities include mechanical integrity tests (MITs), injection well testing during operation, monitoring of ground water quality in several zones, tracking of the CO 2 

### plume and associated pressure front. This document details both the measurements that will be taken as well as the steps to ensure that the quality of all the data is such that the data can be used with confidence in m aking decisions during the life of th e project.



### A.3. Project/Task Description

A.3.a /b . Summary of W ork to be Performed and W ork Schedule

Table 1 describes the Testing and Monitoring tasks, reasoning, responsible parties, locations and testing frequency. Tables 2 and 3 summarize the instrument ation and geophysical surveys, respectively.

### 4 Table 1. Summary of testing and monitoring

. Frequency

Parameter Location Method Pre

- injection

— Baseline Operation
Period

— 5 years PISC Period

— 10

years Analytical

T echnique Lab/Custody Purpose

Carbon dioxide stream analysis Compressor Direct sampling 2 years: Quarterly Quarterly None Chemical analysis TBD Monitor injectate

After CO 2 dehydration Direct sampling 2 years: Quarterly Quarterly None Chemical analysis TBD Monitor injectate

Continuous recording

Injection rate and
volume After compression Flow meter N/A Continuous N/A Direct

measurement N/A Monitor rate and
volume

Injection pressure CCS2
Wellhead Pressure gauge N/A Continuous N/A Direct

measurement N/A Monitor injection

pressure

Annular pressure CCS2
Wellhead Pressure gauge N/A Continuous N/A Direct

measurement N/A Monitor annular

pressure DTS Fiber Optic Temperature CCS2
Wellbore Fiber optic
cable N/A Continuous Yr 1 - Continuous

Yr 2- 10 - N/A Direct

measurement N/A Wellbore integrity

Downhole pressure/temperature CCS2 : Mt
Simon Downhole

gauge N/A Continuous Yr 1

- 3
Continuous

Yr 4

- 10 – Annual Direct

measurement N/A Monitor reservoir

Corrosion monitoring After compression Coupon N/A Quarterly N/A Chemical analysis TBD Monitor injectate, wellbore integrity

Mechanical Integrity CCS2 Various Prior to operation Annually Prior to P/A § 146.87 (a)(4) § 146.89 (c)(2) N/A Wellbore integrity

DTS Fiber Optic CCS2 Fiber optic
cable Continuous Continuous Yr 1 Continuous

Yr 2

- 10 – N/A Direct

measurement N/A Wellbore integrity

Cement e valuation CCS2 Logging Baseline N /A N/A Cement evaluation log N/A Wellbore integrity

Pressure fall off testing CCS2: Mt.
Simon Pressure gauge N/A During injection approximately half way through

the injection phase and at the
end of the injection period. N/A Direct

measurement N/A Wellbore integrity

Microseismic Various monitoring

stations Multilevel geophone s and

seismometers Continuous Continuous Continuous Direct

measurement N/A Reservoir integrity

### 5 Table 1. Summary of testing and monitoring (continued).

Groundwater

monitoring Frequency

Level Location Depth Method Pre

- injection

— Baseline Operation
Period

— 5 years PISC Period

— 10 years Analytical Technique Parameters Purposes

Shallow g roundwater (Quaternary & Pennsylvanian) Figure 2 In

- situ 2 years: Quarterly Year 1

– 2: Quarterly

Year 3

– 5: Bi

annually Annually Chemical analysis Table 4 Detection of changes in groundwater quality for a shallow

USDW.

Lowermost USDW (St. Peter) GM2 Swab valve or other method 1 sample Annually Annually Chemical analysis Table 5 Detection of changes in groundwater quality in lowermost

USDW.

Above confining zone (Ironton- Galesville) VW1 In

- situ 1 sample Baseline;

Year 1

- 3: Annual

Year 4

- 5: N/A None Chemical analysis Table 6 Detection of changes in groundwater quality for reservoir directly above the

confining zone.

VW2 In

- situ 1 sample Annually Annually Chemical analysis Table 6 Detection of changes in groundwater quality for reservoir directly above the

confining zone.

In

- zone monitoring (Mt. Simon) VW1 In

- situ 1 sample Baseline;

Year 1

- 3: Annual

Year 4

- 5: N/A None Chemical analysis Table 7 Detection of changes in groundwater quality, geochemical

moni toring and CO 2 detection in storage

reservoir.

VW2 In

- situ 1 sample Annually Annually Chemical analysis Table 7 Detection of changes in groundwater quality, geochemical monitoring and CO 2 detection in storage

reservoir.

### 6 Table 1. Summary of testing and monitoring (continued).

Direct Geochemical

Measurement Frequency

Location Depth (ft) Method Pre

- injection

— Baseline Operation
Period

— 5 years PISC Period — 10 years Analytical Technique Parameters Purposes

VW1 (Mt. Simon) 6,637

– 6,832

KB In

- situ 1 sample Baseline;

Year 1

- 3: Annual

Year 4

- 5: N/A None Chemical analysis Table 7 Detection of changes in groundwater quality, geochemical monitoring and CO 2 detection in storage

reservoir.

VW2 (Mt. Simon) 5,800 6,300 & 6,800 KB In

- situ 1 sample Annually Annually Chemical analysis Table 7 Detection of changes in groundwater quality, geochemical monitoring and CO 2 detection in storage

reservoir. * Samples collected using downhole sampling tool run into well on wireline

. * Swab samples collected at surface after well has been swabbed with ample volume to ensure reservoir fluid at surface

.

Indirect Methods of CO 2 Plume Tracking

Method Location Pre

- injection

— Baseline Operation Period

— 5 years PISC Period

— 10 Years Purpose

Time lapse VSP GM 1 2013, 2014, 2015 None None Indirect measurement of plume size

Time lapse 3D Injection area Baseline survey Year 2 (2018 ) Year 1 and Year 10 Indirect measurement of plume size

### 7 Table 2

. Instrumentation summary . T = Temperature; P = Pressure; DTS = Distributed Temperature System; F = Flow.

Operational Period

— 5 Years PISC Period

— 10 Years

Monitoring

Location Instrument Type Monitoring Target (Formation or Other) Data Collection Location(s) Frequency Data Collection Location(s) Frequency Explanation

CO 2 Facility T, P, F Surface Discharge High Pressure Pumps Continuous Discharge high

pressure pumps NA Monitoring the operational, equipment, and permit parameters

CCS#1 DTS All s trata Distributed

measurement to 6325 KB/5631 MSL. Continuous Distributed

measurement to 6325 KB/5631 MSL. Yr 1: Continuous

Yr 2

– 10: None Monitoring operational parameters and well integrity

T, P Mt

. Simon 1 interval

PT @ 6325 KB/5631 MSL
Perfs @ 6982

– 7050 KB

6288

– 6356 MSL Continuous
1 interval 1 interval PT @ 6325 KB/5631

MSL Perfs @ 6982

– 7050

KB
6288

– 6356 MSL Yr 1

– 3:
Continuous

Yr 4

– 10: Annual Monitoring operational and equipment
parameters

Geophones All s trata 3 interval array Note 1. 3 intervals Note 1. Note 1: Operator will maintain a passive seismic monitoring system that has the ability to detect
seismic events over M1.0 within the AoR.

CCS#2 T, P Surface

w ell head Tubing Continuous Tubing Continuous Monitoring operational, equipment, and permit
parameters

P Annulus Continuous Annulus Continuous Monitoring well integrity

DTS All geologic

s trata Distributed

measurement to 6325 KB/5631 MSL. Continuous Distributed

measurement to 6325 KB/5631 MSL. Yr 1: Continuous

Yr 2

– 10: None Monitoring operational parameters and well integrity

T, P Mt. Simon 1 interval T, P @ 6325 KB/5631

MSL Perfs @ 6718

– 6881 KB

6024

– 6187 MSL Continuous 1 interval T, P @ 6325 KB/5631

MSL Perfs @ 6718

– 6881

KB
6024

– 6187 MSL Yr 1

– 3:
Continuous

Yr 4

– 10: Annual Monitoring operational, equipment, and permit
parameters

VW1 T, P Ironton

Galesville 1 interval

4918

– 5000 KB

4224

– 4306 MSL Year 1

- 3: Continuous

Year 4

- 5: None 1 interval

4918

– 5000 KB

4224

– 4306 MSL None Monitoring seal formation integrity

Mt. Simon 1 interval

6945

– 5654 KB
6251

– 4960 MSL Year 1

- 3: Continuous

Year 4

- 5: None 1 interval

6945

– 5654 KB
6251

– 4960 MSL None Monitoring plume pressure and temperature front

### 8 Table 2

. Instrumentation summary. T = Temperature; P = Pressure; DTS = Distributed Temperature System; F = Flow (continued).

Operational Period

— 5 Years PISC Period

— 10 Years

Monitoring

Location Instrument Type Monitoring Target (Formation or Other) Data Collection Location(s) Frequency Data Collection Location(s) Frequency Explanation

VW2 T, P Ironton

Galesville 1 interval

5000 KB
4918 MSL Baseline

Continuous 1 interval

5000 KB
4918 MSL Yr 1

– 3:
Continuous

Yr 4

– 10:
Annual Monitoring seal formation integrity

T,P Mt. Simon 4 intervals 7000, 6800, 6300, 5800 KB

6306, 6106, 5606, 5106

MSL Continuous 4 intervals 7000, 6800, 6300, 5800 KB

6306, 6106, 5606, 5106

MSL Continuous Monitoring plume pressure and temperature front

GM1 Geophones All strata 20 interval array Note 1. 20 interval array Note 1. Note 1: Operator will maintain a passive seismic monitoring system that has the ability to detect
seismic events over M1.0 within the AoR.

GM2 P St. Peter 1 interval

3300 KB
2606 MSL Continuous 1 interval

3300 KB
2606 MSL Yr 1

– 3:
Continuous

Yr 4

– 10:
Annual Monitoring seal formation integrity

Geophones All strata 5 interval array Note 1. 5 interval array Note 1. Note 1: Operator will maintain a passive seismic monitoring system that has the ability to detect
seismic events over M1.0 within the AoR.

Seismic
Stations S eismometers & geophones All strata Combination of surface and borehole monitoring

stations Note 1. Various Note 1. Note 1: Operator will maintain a passive seismic monitoring system that has the ability to detect
seismic events over M1.0 within the AoR.

### 9 Table 3

. Geophysical surveys summary

.

Monitoring

Activity Well Tools or Survey Description Pre

- Injection - Baseline Operation Period - 5

Years PISC Period - 10

Years 

### Explanation

Logging GM#1 CBL 1 Baseline None None Mechanical Integrity

GM#2 CBL 1 Baseline None None Mechan ic al Integrity

VW#1 Cement evaluation
tool 1 Baseline None None Mechan ic al Integrity

Pulse neutron 1 Baseline Year 2

, 4 Year 1, 3, 5, 7, 10 Fluid movement, salinity

, CO 2 detection , mechanical integrity

VW#2 Cement evaluation
tool 1 Baseline None None Mechan ic al Integrity

Pulse neutron 1 Baseline Year 2

, 4 Year 1, 3, 5, 7, 10 Fluid movement, salinity

, CO 2 detection , mechanical integrity

CCS#1 Pulse neutron 1 Baseline Year 2 , 4 Year 1, 3, 5, 7, 10 Fluid movement, salinity

, CO 2 detection , mechanical integrity
Casing inspection 1 Baseline None None Mechan ic al Integrity

Cement evaluation
tool 1 Baseline None None Mechan ic al Integrity

CCS#2 Pulse neutron 1 Baseline Year 2 , 4 Year 1, 3, 5, 7, 10 Fluid movement, salinity

, CO 2 detection , mechanical integrity
Casing inspection 1 Baseline None None Mechan ic al Integrity

Cement evaluation
tool 1 Baseline None None Mechan ic al Integrity

Seismic GM# 1 Time

- lapse VSP

survey 2013, 2014, 2015 None None Monitor spat ial extent of plume

Area 3D surface seismic

survey 1 Baseline Year 2 (2018 ) Year 1, Year 10 Monitor spa t ial extent of plume

### 10 A.3.c. Geographic L ocations

Figure 2 shows the IL

- ICCS site and monitoring infrastructure.

Figure 2. IL

- ICCS Project area showing location of existing shallow groundwater monitoring wells and planned deep wells.

### 11 A.3.d. Resource and T ime C onstraints

At the conclusion of the IBDP project , the availability of wells associated with that project (VW# 1, GM#1, CCS#1) are potential resource constraint s for IL

- ICCS . U nder its current state

- issued UIC permit, IBDP
post

- injection monitoring will continue for at least 2 to 3 years after injection ceases in November 2014

. Thereafter, the status and availability of the IBDP wells for use by the IL

- ICCS project is uncertain. No
additional resource or time constraint s have been identified for the IL

- ICCS testing and monitoring plan beyond project funding levels and the proposed timeline.



### A.4. **Quality Objectives and Criteria**

A.4.a. Performance/Measurement C riteria

The overall QA objective for monitoring is to develop and implement procedures for subsurface monitoring, field sampling, laboratory analysis, and reporting which will provide results that will meet
the characterization and non

- endangerment goals of this project

. Groundwater monitoring will be conducted during the pre

- injection, injection

, and post

- in jection phases of the project. Shallow and deep groundwater m onitoring wells will be used to gather water

- quality samples and pressure data. All the groundwater analytical and field monitoring para meters for each interval are listed in Table 4 through
Table 7

. Table 8 , Table 9 and Table 10 show analytical parameters for CO2 stream gas monitoring, corrosion coupon assessment, and gauge specifications. Table 11 shows the monitoring outputs

. The list of analytes may be reassessed periodically and adjusted to include or exclude analytes based on their
effectiveness to the overall monitoring program goals.

Key testing and monitoring areas include :

I. Shallow Groundwater Sampling

• A queous chemical concentrations

II. Deep Formation Fluid Sampling

• Aqueous chemical concentrations

III. Well Logging

• pulse neutron

IV. Mechanical Integrity Testing (MIT)

• Pulsed neutron, temperature, cement evaluation logging

V. Pressure/Temperature Monitoring

• Pressure /temperature from in

- situ gauges

• Pressure/temperature from surface gauges VI. CO 2 

### Stream Analysis

• CO 2 

### Purity (% v/v, [GC])

• Oxygen (O 2 

### , ppm v/v)

• Nitrogen (N 2 

### , ppm v/v)

• Carbon Monoxide (CO, ppm v/v)

• Oxides of Nitrogen ( NOx, ppm v/v)

• Total Hydrocarbons (THC, ppm v/v as CH 4 

### )

• Methane (CH 4 

### , ppm v/v)

• Acetaldehyde (AA, ppm v/v)

### 12 • Sulfur Dioxide (SO 2 

### , ppm v/v)

• Hydrogen Sulfide (H 2 

### S ppm v/v)

• Ethanol (ppm v/v )

VII. Geophysical Monitoring

• Seismic data file s (e .g., segd file)

• Processed time

- lapse report

### 13 Table 4. Summary of analytical and field parameters for Quaternary/Pennsylvanian groundwater samples

. All analysis will all be performed by ADM or a designated third party laboratory. ICP = inductively coupled plasma; MS = mass spectrometry; OES = optical emission spectrometry; GC

- P = gas chromatography - pyrolysis.

P ara m eters A na ly tical M eth o ds (1) D ete c tion Li m it/Range Typical P re ci sio ns Q C Require m en ts

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

, EP A M ethod 6 0 20 0.001 to 0.1 mg/L (a na lyt e, dilution and matrix depende n t) ± 15% D ai l y ca l ibr a tio n ; b l anks, du p li c ates and m atrix s pikes at 10% or greater frequency

Cations: Ca, Fe, K, Mg, Na, and Si ICP

- OES, EPA Method 6010B 0.005 to 0.5 mg/L (a na lyt e, dilution and matrix depende n t) ± 15% D ai l y ca l ibr a tio n ; b l anks, du p li c ates and m atrix s pikes at 10% or greater frequency

Anions: Br, Cl, F, NO 3 , and SO 4 Ion Chromatography, EPA Method 300.0 0.02 to 0.13 mg/L ( a na l y t e, dilution and matrix depende n t) ± 15% Daily calibration; blanks and duplicates at 10% or greater frequency

Dissolved CO 2 Coulometric titration,
ASTM D513

- 11 25 mg/L ± 15% Duplicate measurement; standards at 10% or greater frequency

Total Dissolved Solids Gravimetry; APHA 2540C 12 mg/L ±10% Balance calibration, duplicate analysis

W ater D en sit y (field) Oscillating body method 0.0000 to 2.0000 ± 0.0002 g/ mL Duplicate m ea s ure m ents

A lkalinit y APHA 2320B 4 m g/L ± 3 m g/L Duplicate analysis

pH (field) EPA 150.1 2 to 12 pH un i ts ± 0.2 pH un i t Us er ca l ibr a t ion per m anuf a ct

u

rer

reco mm endatio n

S pecif ic con d uc t ance (field) APHA 2510 0 to 200 mS /cm ± 1% of r e ading Us er ca l ibr a t ion per m anuf a ct

u

rer

reco mm endatio n

Te m peratu re (field) Ther m ocouple -5 to 50 °C ± 0.2 °C F acto r y ca l ibr ati on

Note 1: : An equivalent method may be employed with the prior approval of the UIC Program Director.

### 14 Table 5. Summary of analytical and field parameters for St Peter Reservoir groundwater samples. All analysis will be performed by ADM or a designated third party laboratory. ICP = inductively coupled plasma; MS = mass spectrometry; OES = optical emission spectrometry; GC

- P = gas chromatography - pyrolysis.

P ara m eters A na ly tical M eth o ds (1) D ete c tion Li m it/Range Typical P re ci sio ns Q C Require m en ts

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

, EP A M ethod 6 0 20 0.001 to 0.1 mg/L (a na lyt e, dilution and matrix depende n t) ± 15% D ai l y ca l ibr a tio n ; b l anks, du p li c ates and m atrix s pikes at 10% or greater frequency

Cations : Ca, Fe, K, Mg, Na, and Si ICP

- OES, EPA Method 6010B 0.005 to 0.5 mg/L (a na lyt e, dilution and matrix depende n t) ± 15% D ai l y ca l ibr a tio n ; b l anks, du p li c ates and m atrix s pikes at 10% or greater frequency

Anions: Br, Cl, F, NO 3 , and SO 4 Ion Chromatography, EPA Method 300.0 0.02 to 0.13 mg/L (a na lyt e, dilution and matrix depende n t) ± 15% Daily calibration; blanks and duplicates at 10% or greater frequency

Dissolved CO 2 Coulometric titration,
ASTM D513

- 11 25 mg/L ± 15% Duplicate measurement; standards at 10% or greater frequency

Isotopes: δ 13 C of DIC Isotope ratio mass spectrometry 2 12.2 mg/L HCO 3 - for δ 13 C ±0.15‰ for δ 13 C 10% duplicates; 4 standards/batch

Total Dissolved Solids Gravimetry; APHA 2540C 12 mg/L ±10% Balance calibration, duplicate analysis

W ater D en sit y (field) Oscillating body method 0.0000 to 2.0000 ± 0.0002 g/ mL Duplicate m ea s ure m ents

A lkalinit y APHA 2320B 4 m g/L ± 3 m g/L Duplicate analysis

pH (field) EPA 150.1 2 to 12 pH un i ts ± 0.2 pH un i t Us er ca l ibr a t ion per m anuf a ct

u

rer

reco mm endatio n

S pecif ic con d uc t ance (field) APHA 2510 0 to 200 mS /cm ± 1% of r e ading Us er ca l ibr a t ion per m anuf a ct

u

rer

reco mm endatio n

Te m peratu re (field) Ther m ocouple -5 to 50 °C ± 0.2 °C F acto r y ca l ibr ati on

Note 1: An equivalent method may be employed with the prior approval of the UIC Program Director.

Note:2: G as evolution technique by Atekwana and Krishnamurthy (1998), with modifications made by Hackley et al. (2007)

### 15 Table 6. Summary of analytical and field parameters for Ironton

- Galesville groundwater samples. Note: Cation, anion, TDS, and alkalinity measurements will all be performed by a laboratory meeting the requirements under the USEPA Environmental Laboratory Accreditati on Program

. Isotope and dissolved CO 2 analyses will be performed by ADM or a designated laboratory

. ICP = inductively coupled plasma; MS = mass spectrometry; OES = optical emission spectrometry; GC

- P = gas chromatography - pyrolysis.

P ara m eters A na ly tical M eth o ds (1) D ete c tion Li m it/Range Typical P re ci sio ns Q C Require m en ts

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

, EP A M ethod 6 0 20 0.001 to 0.1 mg/L (a na lyt e, dilution and matrix depende n t) ± 15% D ai l y ca l ibr a tio n ; b l anks, du p li c ates and m atrix s pikes at 10% or greater frequency

Cations: Ca, Fe, K, Mg, Na, and Si ICP

- OES, EPA Method 6010B 0.005 to 0.5 mg/L (a na lyt e, dilution and matrix depende n t) ± 15% D ai l y ca l ibr a tio n ; b l anks, du p li c ates and m atrix s pikes at 10% or greater frequency

Anions: Br, Cl, F, NO 3 , and SO 4 Ion Chromatography, EPA Method 300.0 0.02 to 0.13 mg/L ( a na l y t e, dilution and matrix depende n t) ± 15% Daily calibration; blanks and duplicates at 10% or greater frequency

Dissolved CO 2 Coulometric titration,
ASTM D513

- 11 25 mg/L ± 15% Duplicate measurement; standards at 10% or greater frequency

Isotopes: δ 13 C of DIC Isotope ratio mass spectrometry 2 12.2 mg/L HCO 3 - for δ 13 C ±0.15‰ for δ 13 C 10% duplicates; 4 standards/batch

Total Dissolved Solids Gravimetry; APHA 2540C 12 mg/L ±10% Balance calibration, duplicate analysis

W ater D en sit y (field) Oscillating body method 0.0000 to 2.0000 ± 0.0002 g/ mL Duplicate m ea s ure m ents

A lkalinit y APHA 2320B 4 m g/L ± 3 m g/L Duplicate analysis

pH (field) EPA 150.1 2 to 12 pH un i ts ± 0.2 pH un i t Us er ca l ibr a t ion per m anuf a ct

u

rer

reco mm endatio n

S pecif ic con d uc t ance (field) APHA 2510 0 to 200 mS /cm ± 1% of r e ading Us er ca l ibr a t ion per m anuf a ct

u

rer

reco mm endatio n

Te m peratu re (field) Ther m ocouple -5 to 50 °C ± 0.2 °C F acto r y ca l ibr ati on

Note 1: An equivalent method may be employed with the prior approval of the UIC Program Director.

Note:2: G as evolution technique by Atekwana and Krishnamurthy (1998), with modifications made by Hackley et al. (2007)

### 16 Table 7. Summary of analytical and field parameters for Mt Simon groundwater samples. All analysis will be performed by ADM or a designated third party laboratory. ICP = inductively coupled plasma; MS = mass spectrometry; OES = optical emission spectrometry; GC

- P = gas chromatography - pyrolysis.

P ara m eters A na ly tical M eth o ds (1) D ete c tion Li m it/Range Typical P re ci sio ns Q C Require m en ts

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

, EP A M ethod 6 0 20 0.001 to 0.1 mg/L (a na lyt e, dilution and matrix depende n t) ± 15% D ai l y ca l ibr a tio n ; b l anks, du p li c ates and m atrix s pikes at 10% or greater frequency

Cations: Ca, Fe, K, Mg, Na, and Si ICP

- OES, EPA Method 6010B 0.005 to 0.5 mg/L (a na lyt e, dilution and matrix depende n t) ± 15% D ai l y ca l ibr a tio n ; b l anks, du p li c ates and m atrix s pikes at 10% or greater frequency

Anions: Br, Cl, F, NO 3 , and SO 4 Ion Chromatography, EPA Method 300.0 0.02 to 0.13 mg/L (a na lyt e, dilution and matrix depende n t) ± 15% Daily calibration; blanks and duplicates at 10% or greater frequency

Dissolved CO 2 Coulometric titration,
ASTM D513

- 11 25 mg/L ± 15% Duplicate measurement; standards at 10% or greater frequency

Isotopes: δ 13 C of DIC Isotope ratio mass spectrometry 2 12.2 mg/L HCO 3 - for δ 13 C ±0.15‰ for δ 13 C 10% duplicates; 4 standards/batch

Total Dissolved Solids Gravimetry; APHA 2540C 12 mg/L ±10% Balance calibration, duplicate analysis

W ater D en sit y (field) Oscillating body method 0.0000 to 2.0000 ± 0.0002 g/ mL Duplicate m ea s ure m ents

A lkalinit y APHA 2320B 4 m g/L ± 3 m g/L Duplicate analysis

pH (field) EPA 150.1 2 to 12 pH un i ts ± 0.2 pH un i t Us er ca l ibr a t ion per m anuf a ct

u

rer

reco mm endatio n

S pecif ic con d uc t ance (field) APHA 2510 0 to 200 mS /cm ± 1% of r e ading Us er ca l ibr a t ion per m anuf a ct

u

rer

reco mm endatio n

Te m peratu re (field) Ther m ocouple -5 to 50 °C ± 0.2 °C F acto r y ca l ibr ati on

Note 1: An equivalent method may be employed with the prior approval of the UIC Program Director.

Note:2: G as evolution technique by Atekwana and Krishnamurthy (1998), with modifications made by Hackley et al. (2007)

### 17 Table 8. Summary of a nalytical p arameters for CO 2 gas stream

. All analysis will be performed by ADM or a designated third party laboratory.

Parameters Analytical Methods (1) Detection Limit/Range Typical Precisions QC Requirements

Oxygen ISBT 4.0 (GC/DID) 1 uL/L to 5,000 uL/L (ppm by volume) ± 10 % of reading daily standard within 10 % of calibration, secondary standard after calibration

GC/TCD 0.1 % to 100 % 5

- 10 % relative across the range, RT ± 0.1 min daily standard, duplicate analysis within 10 % of each other

Nitrogen ISBT 4.0 GC/DID 1 uL/L to 5,000 uL/L (ppm by volume) ± 10 % of reading daily standard within 10 % of calibration, secondary standard after calibration

GC/TCD 0.1 % to 100 % 5

- 10 % relative across the range, RT ± 0.1 min daily standard, duplicate analysis within 10 % of each other

Carbon Monoxide ISBT 5.0 Colorimetric 5 uL/L to 100 uL/L (ppm by volume) ± 20 % of reading duplicate analysis

ISBT 4.0 (GC/DID) 1 uL/L to 5,000 uL/L (ppm by volume) ± 10 % of reading daily standard within 10 % of calibration, secondary standard after calibration

Oxides of Nitrogen ISBT 7.0 Colorimetric 0.2 uL/L to 5 uL/L (ppm by volume) ± 20 % of reading duplicate analysis

Total Hydrocarbons ISBT 10.0 THA (FID) 1 uL/L to 10,000 uL/L (ppm by volume) 5

- 10 % of reading relative across the range daily blank, daily standard within 10 % of calibration, secondary standard after calibration

Methane ISBT 10.1 GC/FID) 0.1 uL/L to 1,000 uL/L (ppm by volume)

- dilution dependent 5

- 10 % of reading relative across the range daily blank, daily standard within 10 % of calibration, secondary standard after calibration

Acetaldehyde ISBT 11.0 (GC/FID) 0.1 uL/L to 100 uL/L (ppm by volume)

- dilution dependent 5

- 10 % of reading relative across the range daily blank, daily standard within 10 % of calibration, secondary standard after calibration

Sulfur Dioxide ISBT 14.0 (GC/SCD) 0.01 uL/L to 50 uL/L (ppm by volume)

- dilution dependent 5

- 10 % of reading relative across the range daily blank, daily standard within 10 % of calibration, secondary standard after calibration

Hydrogen Sulfide ISBT 14.0 (GC/SCD) 0.01 uL/L to 50 uL/L (ppm by volume)

- dilution dependent 5

- 10 % of reading relative across the range daily blank, daily standard within 10 % of calibration, secondary standard after calibration

Ethanol ISBT 11.0 (GC/FID) 0.1 uL/L to 100 uL/L (ppm by volume)

- dilution dependent 5

- 10 % of reading relative across the range daily blank, daily standard within 10 % of calibration, secondary standard after calibration

CO 2 Purity ISBT 2.0 Caustic absorption Zahm

Nagel 99.00% to 99.99% ± 10 % of reading User calibration per manufacturer recommendation

ALI method SAM 4.1 subtraction method (GC/DID) 1 ppm for each target analyte (analyte dependent) - refer to Oxygen and Nitrogen analysis. 5- 10 % relative across the

range duplicate analysis within 10 % of each other

GC/TCD 0.1 % to 100 % 5

- 10 % relative across the range, RT ± 0.1 min standard with every sample, duplicate analysis within 10 % of each other
Note 1: An equivalent method may be employed with the prior approval of the UIC Program Director.

### 18 Table 9. Summary of a nalytical p arameters for c orrosion c oupons

. P ara m eters A na ly tical M eth o ds D ete c tion Li m it/Range Typical P re ci sio ns Q C Require m en ts

Mass NACE RP0775

- 2005 .005mg +/

- 2% Annual Calibration of Scale (3 rd Party Aldinger

Co. – Cert #664896F)

Thickness NACE RP0775

- 2005 .001mm +/

- 005mm F acto r y ca l ibr a t i on

Table 10

. Summary of measurement p arameters for f ield g auges

. P ara m eters M eth o ds D ete c tion Li m it/Range Typical P r e ci s i o ns Q C Require m en t s

Booster pump discharge pressure (PIT

012) ANSI Z540

- 1

- 1994 +/

- 0.001 psi / 0

- 3000 psi +/

- 0.01 psi Annual Calibration of Scale (3 rd party)

Injection Tubing Temperature (TIT

019) ANSI Z540

- 1

- 1994 +/

- 0.001 F / 0

- 500 F +/

- 0.01 F Annual Calibration of Scale (3 rd party)

Annulus Pressure (PIT

- 014) ANSI Z540 -1- 1994 +/

- 0.001 psi / 0

- 3000 psi +/ - 0.01 psi Annual Calibration of Scale (3 rd party)

Injection Tubing Pressure (PIT

- 009) ANSI Z540

- 1

- 1994 +/

- 0.001 psi / 0

- 3000 psi +/

- 0.01 psi Annual Calibration of Scale (3 rd party)

Injection Mass Flow Rate (FIT

- 006) UNKNOWN +/

- 0.1000% of rate /

50,522

- 303,133 lb/hr +/

- 0.01 lbs/hr Annual Calibration of Scale (3 rd party)

Westbay Pressures (MOSDAX) UNKNOWN +/0 0.001 psi / 0

- 4000 PSI +/

- 0.01 psi Annual Calibration of Scale (3 rd party)

### 19 Table 11

. Actionable testing and monitoring outputs

. 

### Project Action Limit Detection L imit Anticipated R eading

MIT

— Pulse

neutron logging Action taken when RST
indicates CO 2 

### outside of expected range +/ - 0.5 SIGM Brine saturated ~ 60

CO 2 

### saturated ~ 8

Wellbore integrity

— annular

pressure gauge <3% pressure loss over 1
hour Refer to Appendix A (annular pressure gauge table) >3% pressure loss over 1 hour

Surface and
downhole

pressure
g auge s Action will be taken when pressures are well outside of modeled/expected

range Refer to Table 11
and 12 for surface

gauges Refer to Table 9 for downhole gauge Within injection formation:

>8 0% fracture gradient 0.71 psi/ft

Wellbore integrity

— DTS fiber optic
temperature Action will be taken when there is an anomaly in temperature profile Refer to Appendix A DTS provides continuous temperature profile

Seismic data
files Detected CO 2 

### outside the

AOR Dependent on fluid saturation, and
formation velocities CO 2 

### plume migration similar to
modeled outcome

A.4.b. P recision

For groundwater sampling, data accuracy will be assessed by the collection and analysis of field blanks to test sampling procedures and matrix spikes to test lab procedures. Field blanks will be taken no less than one per sampling day to spot check fo r sample bottle contamination. Laboratory assessment of analytical precision will be the responsibility of the individual laboratories per their st andard operating procedures.

Table 12 summarizes the specifications of each monitoring method. For direct pressure and logging measurements, precision data is presented in Table 13



### .
A.4.c. B ias

Laboratory assessment of analytical bias will be the responsibility of the individual laboratories per their standard operating procedures and analytical methodologies. For direct pressure or logging measurements, there is no bias.

A.4.d. R epresentativeness

For groundwater sampling, d ata representativeness expresses the de gree to which data accurately and precisely represents a characteristic of a population, parameter variations at a sampling point, a process condition, or an environmental condition. The sampling network has been designed to provide data

repr esentative of site conditions. For analytical results of individual groundwater samples, representativeness will be estimated by ion and mass balances. Ion balances with ± 10% error or less will
be considered valid. M ass balance assessment will be used in cases where the ion balance is greater
than ± 10% to help determine the source of error. For a sample and its duplicate, if the relative percent difference is greater than 10 % , t he sample may be considered non

- representative.

### 20 A.4.e. C omple teness

For groundwater sampling, data completeness is a measure of the amount of valid data obtained from a measurement system compared to the amount that was expected to be ob tained under normal
conditions. It is anticipated that d ata completeness of 90% for groundwater sampling will be acceptable

to meet monitoring goals. For direct pressure and temperature measurements, it is expected that data
will be recorded no less than 90% of the time.

A.4.f. C omparability

Data comparability expresses the confidence with which one data set can be compared to another. The
data set s to be generated by this project will be very comparable to future data sets because of the use of standard methods and the level of QA/QC effort. If historical groundwater quality data become available from other sources, their applicability to the project and level of quality will be assessed prior to use with data gathered on this project. Direct pressure, temperature, and logging measurements will be directly compar able to previously obtained data.

A.4.g. M ethod S ensitivity

Table 14

– 

### Table 19 provide additional details on gauge specifications and sensitivities

.

Table 12

. Pressure and t emperature

— downhole quartz g auge s pecifications

. Calibrated working pressure range Atmospheric to 10,000 psi

Initial pressure accuracy <+/

- 2 psi over full scale

Pressure resolution 0.005 psi at 1

- s sample rate

Pressure drift stability <+/

- 1 psi per year over full scale

Calibrated working temperature range 77

– 266° F

Initial temperature accuracy <+/

- 0.9°F per +/

- 0.27° F

Temperature resolution 0.009° F at 1

- s sample rate

Temperature drift stability <+/

- 0.1° F per year at 302

Max temperature 302° F

Table 13

. Representative L ogging tool specifications

.
RST CBL USI Isolation Scanner

Logging speed 1,800 ft/hr 3,600 ft/hr Standard resolution: 2,700 ft/hr High resolution: 563 ft/hr Standard resolution: 2,700 ft/hr High resolution: 563 ft/hr

Vertical resolution 15 inches 3 ft Standard resolution: 0.6 in High speed: 6 in High resolution: 0.6 in High speed: 6 in

Investigation Formation Casing, annulus, and formation Casing and annulus Casing and annulus

Temperature rating 302° F 350° F 350° F 350° F

Pressure rating 15,000 psi 20,000 psi 20,000 psi 20,000 psi

Table 14

. Pressure Field Gauge PIT -009— Injection Tubing Pressure

. Calibrated working pressure range 0 to 3000 psi and 4

– 20 mA

Initial pressure accuracy < 0.04375 %

Pressure resolution 0.001 psi and 0.00001 mA

### 21 Pressure drift stability To be determine d after first year

Table 15

. Pressure Field Gauge PIT -014— Annuls Pressure

. Calibrated working pressure range 0 to 3000 psi and 4

– 20 mA

Initial pressure accuracy < 0.02500 %

Pressure resolution 0.001 psi and 0.00001 mA

Pressure drift stability To be determine d after first year

Table 16

. Pressure Field Gauge PIT -012. Calibrated working pressure range 0 to 3000 psi and 4

– 20 mA

Initial pressure accuracy < 0.03125 %

Pressure resolution 0.001 psi and 0.00001 mA

Pressure drift stability To be determine d after first year

Table 17

. Temperature Field Gauge TIT -019 — Injection Tubing Temperature

. Calibrated working temperature range 0 to 500° F and 4– 20 mA

Initial temperature accuracy < 0.0055 %

Temperature resolution 0.001° F and 0.0001 mA

Temperature drift stability To be determine d after first year

Table 18

. Mass Flow Rate Field Gauge

— FT -006 CO 2 Mass Flow Rate

. Calibrated working flow rate range 50,522 to 303,133 lbs/hr and

4– 20 mA
Initial mass flow rate accuracy < 0.18%

Mass flow rate resolution 0.0001 lb/hr

Mass flow rate drift stability To be determine d after first year

Table 19

. Westbay Field Gauge

— Westbay (MOSDAX) Pressure

. Calibrated working pressure range 0 to 4000 psi

Initial pressure accuracy < 0.01 %

Pressure resolution 0.001 psi

Pressure drift stability To be determine after first year



### A.5. **Special Training/Certifications**

A.5.a. S pecialized T raining and C ertifications

The geophysical survey equipment and w ireline logging tools will be operated by trained, qualified, and certified personnel, according to the service company which provides the equipment. The subsequent data will be processed and analyzed according to industry standards (Appendix B ). No specialized
certifications are required for personnel conducting groundwater sampling, but field sampling will be

c onducted by trained personnel. Groundwater sampling will be conducted by personnel trained to understand and follow the project specific sampling procedures. Upon request ADM will provide the agency with all laboratory SOPs developed for the specific parameter using the appropriate sta ndard method. Each laboratory technician conducting the analysis on the samples will be trained on the SOP

### 22 developed for each standard method. ADM will include the technician’s training certification with the biannual report.

A.5.b/c. Training P rovid er and R esponsibility

Training for personnel will be provided by the operator or by the subcontractor responsible for the data collection activity

. 

### A.6

**. Documentation and Records** 

A.6.a. Report F ormat and P ackage I nformation

A semi

- annual report from ADM to USEPA will contain all required project data, including testing and monitoring information as specified by the UIC Class VI permit

. Data will be provided in electronic or other formats as required by the UIC Program Director

.
A.6.b. Other P roje ct D ocuments , Records, and E lectronic F iles

Other documents, records, and electronic files such as well logs, t est results , or other data will be provided as required by the UIC Program Director.

A.6.c /d . Data Storage and D uration

ADM or a designated contr actor will maintain the required project data as provided elsewhere in the permit.

A.6.e. QASP D istribution R esponsibility

T he ADM Corn Plant Manager will be responsible for ensuring that all those on the distribution list will receive the most current copy of the approved Quality Assurance and Surveillance Plan

. 

## B. Data Generation and Acquisition

**B.1. Sampling Process Design (Experimental Design)** 

Disc ussion in this section is focused on groundwater and fluid sampling and does not address monitoring
methods that do not gather physical samples (e.g.

, logging, seismic monitoring, and pressure/temperature monitoring ). During the pre

- injection and injection phases, groundwater sampling is planned to include a n extensive set of chemical parameters to establish aqueous geochemical reference data. Parameters will include sele cted constituents that: ( 1) have primary and secondary USEPA drinking water maximum con taminant levels, ( 2) are the most responsive to
interaction with CO 2 

### or brine, ( 3) are needed for quality control, and ( 4) may be needed for geochemical modeling. The full set of parameters for each sampling interval is given in Table 4

- Table 7



### . After a
sufficient baseline is established

, monitoring scope may shift to a subset of indicator parameters that

are (1) the most responsive to interaction with CO 2 

### or brine and (2) a re needed for quality control. Implementation of a reduced set of parameters would be done in consultation with the USEPA. Isotopic analyses will be performed on baseline samples to the degree that the information helps verify a
condition or es tablish an understanding of non

- project related variations. For non

- baseline samples, isotopic analyses may be reduced in all monitoring wells if a review of the historical project results or
other data determines that further sampling for isotopes is unneeded

. During any period where a reduced set of analytes is used, i f statistically significant trends are obser ved that are the result of
unintended CO 2 

### or brine migration, the analytical list would be expanded to the full set of monitoring
parameters. T he Ironton

- Galesville groundwater samples will be analyzed using a laboratory meeting

### 23 the requirements under the USEPA Environmental Laboratory Accreditation Program

. All other samples
will be analyzed by the operato r or a third party laboratory. Dissolved CO 2 

### will be analyzed by methods
consistent with Test Method B of ASTM D 513

- 06, “Standard Test Methods for Total and Dissolved Carbon Dioxide in Water” or equivalent. Isotop ic analysis w ill be conducted using established methods.

B.1.a. Design S trategy

CO 2 

### Stream M onitoring S trategy The primary purpose of analyzing the carbon dioxide stream is to evaluate the potential interactions of carbon dioxide and/or other constituents of the injectate with formation solids and fluids. This analysis can also identify (or rule out) potential interactions with well materials. Establishing the chemical composition of the in jectate also supports the determination of whether the injectate meets the qualifications of hazardous waste under the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. 6901 et seq. (1976), and/or the Comprehensive Environmental Response, Compensati on, and Liability Act, (CERCLA) 42 U.S.C. 9601 et seq. (1980). Additionally, monitoring the chemical and physical characteristics of the carbon dioxide (e.g., isotopic signature, other constituents) may help distinguish the injectate from the native fluids and gases if unintended leakage from the storage reservoir occurred. Injectate monitoring is required at a sufficient frequency to detect changes to any physical and chemical properties that may result in a deviation from the permitted specifications.

C alibration of transmitters used to monitor pressures, temperatures, and flow rates of CO 2 

### into the injection well at the injection well and at the verification well shall be conducted annually (e.g., Durkin Equi pment Company, St. Louis, MO). Reports shall contain test equipment used to calibrate the

transmitters

, including test equipment manufacturers, model numbers, serial numbers, calibration dates and expiration dates.

Corrosion Monitoring S trategy Corrosion coupon analyses will be conducted quarterly t o aid in ensuring th e mechanical integrity of the equipment in contact with the carbon dioxide. Coupons shall be sent quarterly to a company for analysis (e.g., SGS) and an analysis conducted in accordance with NACE Standard RP

- 0775 (or similar) to
determine and document corrosion wear rates based on mass loss.

Shallow G roundwater M onitoring S trategy Four dedicated monitoring wells have been selected for shallow groundwater monitoring. These wells have already been installed and screened in the Quate rnary

- age deposits to depths less than 150 ft below ground surface ( bgs )

. The local Quaternary

- age deposits are used predominantly as private water well sources in the area. The wells are designated as IL

- ICCS

- MVA 10LG, IL

- ICCS

- MVA 11LG, IL

- ICCS

- MVA 12LG, and IL

- ICCS

- MVA 13LG ( Figure 2 ) . The wells were selected to give a spatial distribution around the planned CO 2 

### injection well ( CCS#2 ) location

. Deep G roundwater M onitoring S trategy

M onitoring of the deeper St. Peter and Ironton

- Galesville Sandstones will be used for early leakage
detection in formations that are much closer to the Mt. Simon Sandstone injection reservoir. Fluid sampling at wells VW#1

, VW#2, and GM# 2 in combination with pressure monitoring, temperature monitoring, and pulse neutron logging will be used to determine if leakage is occurring at or near the injection well. T he Ironton

- Galesville Sandstone , has sufficient permeability (over 100 mD) such t hat pressure monitoring at the verification wells would detect a failure of the confinin g zone should it occur. MIT testing and DTS monitoring at the injection well will also provide data to insure the mechanical integrity of the well is maintained

. With t he planned sampling and monitoring frequencies, it is expected that baseline conditions can be documented, natural variability in conditions can be characterized,

### 24 unintended brine or CO 2 

### leakage could be detected if it occurred, and sufficient data will be collected to
demonstrate that the effects of CO 2 

### injection are limited to the intended storage reservoir. No groundwater fluid sampl ing is planned for the Mt Simon intervals where free phase CO 2 

### has broken through

.
GM#2 S ampling

The IL

- ICCS geophysical monitoring well

, GM#2

, will be used for fluid sampling of the St. Peter Sandstone, a USEPA identified USDW. At prescribed frequencies (in consultation with USEPA), fluid sampling will occur using a portable swabbing rig or other available sampling technolo gies

. Samples will be analyzed for constituents listed in Table 5 to document baseline fluid chemistry and to detect changes in fluid chemistry that could result from the movement of brine or CO 2 

### from the storage interval through the seal formation.

VW#1 S ampling The IBDP verification well, VW#1, will be used to monitor the pressure and temperature in the Ironton

Galesville Sandstone above the Eau Claire Formation, the primary reservoir seal. This well will serve as an early leak detection system by allow ing the operator to monitor for changes above the primary caprock

. Groundwater s amples will collected and analyzed for constituents listed in Table 6 to document baseline fluid chemistry and to detect changes in fluid chemistry that could result from the movement of
brine or CO 2 

### from the storage interval through the seal formation. The well has been completed with a Westbay multilevel sampling system and fluid samples will be collected as described by Locke et al. (2013).

VW#2 S ampling

The IL

- ICCS verification well, VW#2

, will allow monitoring within the Mt

. Simon injection zone a s well a s immediately above the Eau Claire Formation. This well will serve as an early leak detection system by
allow ing the operator to monitor for changes above the primary caprock. VW# 2 will be equipped with a
multi level pressure and temperature monitoring system with fluid sampling capability at four (4 )
intervals (perforation intervals 2

- 5; 6800, 6300, 5800, 5000 KB)

. The system uses packers to isolate each perforation interval and hydraulically operated sliding sleeves to facilitate sampling. Pressure a nd temperature will be continuously monitored and recorded in each of the five (5) perforation intervals ( perforation intervals 1

- 5; 7000, 6800, 6300, 5800, 5000 KB ) . The pressure inside the tubing just above the uppermost packer (~4900 Kb) will be monitor ed and recorded. At prescribed frequencies (in
consultation with USEPA)

, fluid sampling will occur by opening the appropriate sliding sleeve across from the zone to be sampled. Each sample interval will be analyzed for constituents list in Table 6 for the
Ironton Galesville or Table 7 for the Mt Simon to document baseline fluid chemistry and to detect changes in fluid chemistry that could result from the movement of brine or CO 2 

### from the storage interval through the seal f ormation.
B.1.b Type and N umber of Samples/T est R uns

Groundwater sampling frequencies are detailed in Table 1.
CO 2 

### gas stream and corrosion coupon frequencies are detailed in Table 1.
B.1.c. Site/S ampling L ocations

Shallow grou ndwater monitoring will use existing wells IL

- ICCS

- MVA 10LG, IL

- ICCS

- MVA 11LG, IL

- ICCS

MVA 12LG, and IL

- ICCS

- MVA 13LG ( Figure 2 ) as noted in Section B.1.a

. Deep groundwater monitoring will use existing wells VW#1, VW#2, and GM# 2 ( Figure 2 ) as noted in Section B.1.a.

CO 2 

### gas stream and corrosion coupon sampling locations will occur in the compressor building after the last stage of compression.

### 25 B.1.d. Sampling S ite C ontingency

The shallow and deep groundwater monitoring wells are located on property of the project participants (e.g., ADM , R i ch land Community College ) and access permissions h ave already been granted. No problems of site inaccessibility are anticipated. If inclement weather makes site access difficult, sampling schedules will be reviewed and alternative dates may be select ed that would still meet permit

- related
conditions.

No problems of site inaccessibility are anticipated for CO 2 

### gas stream or corrosion coupon sampling. If inclement weather makes site access difficult, sampling schedules will be reviewed and alternative dates may be selected that would still meet permit relat ed conditions.

B.1.e. Activity S chedule

The groundwater sampling activities and frequencies are summarized in Table 1.
The CO 2 

### gas stream and corrosion coupon sampling activities and frequencies are summarized in Table

1.
B.1.f. Critical/ I nformational D ata

During both groundwater sampling and analytical efforts

, detailed field and laboratory documentation
will be taken. D ocumentation will be recorded in field and laboratory forms and notebooks. Critical
information will include time and date of activity, person/s performing activity, location of activity (well field sampling) or instrument (lab analysis), field or laboratory instrument calibration data, purge volume, field parameter values. For laboratory analyses

, much of the critical data are generated during the analysis and provided to end users in d igital and printed formats. Non critical data may i nclude appearance and odor of the sample, problems with well or sampling equipment, and weather
conditions.

B.1.g. Sources of V ariability

Potential sources of variability related t o monitoring activities include ( 1) natural variation in fluid quality, formation pressure and temperature and seismic activity; ( 2) variation in fluid quality, formation pressure and temperature, and seismic activ ity due to projec t operations; ( 3) changes in recharge due to rainfall, drought, and snowfall ; ( 4) changes in instrument calibration during sampling or analytical activity ; 5) different staff collecting or analyzing samples ; ( 6) differences in environmental conditions
d uri ng field sampling activities; ( 7) changes in analytical data quality during life of project ; and ( 8) data entry errors related to maintaining project database.

Activities to eliminate, reduce, or reconcile variability related t o monitoring activities include ( 1)
collect ing long

- term baseline data to observe and document natural variation in monitoring parameters, ( 2) evaluat ing data in timely manner after collection to observe anomalies in data that can be addressed
be resampl ed or reanaly zed

, ( 3) cond ucting statistical analysis of monitoring data to determine whether variability in a data set is the result of project activities or natural variation, ( 4) maintain ing weather

related data using on

- site weather monitoring data or data collected near project site (such as from local airports) , ( 5) check ing instrument calibration before, during and after sampling or sample analysis, ( 6) thoroughly train ing staff, ( 7) conduct ing laboratory quality assurance checks using third party reference materials, blind a nd replicate sample checks, and ( 8) develop ing a systematic review process of data that can include sample

- specific data quality checks (i

. e. , cation/anion balance for aqueous samples).



### B.2. **Sampling Methods**

### 26 Logging, geophysical monitoring, and pressure/te mperature monitoring does not apply to this section,
and is omitted.

B.2.a /b . Sampling SOPs

Groundwater samples will be collected primarily using a low

- flow sampling method consistent with

ASTM D6452

- 99 (2005) or Puls and Barcelona (1996). If a flow

- through cell is not used, field parameters will be measured in grab samples. Groundwater wells will be purged to e nsure samples are representative of formation water quality. Static water levels in each well will be determined using an
electronic water lev el indicator before any purging or sampling activities begin . Dedicated pumps (e.g., bladder pumps) will be installed in each monitoring well to minimize potential cross contamination
between wells. Groundwater pH, temperature, specific conductance, and di ssolved oxygen will be monitored in the field using portable probes and a flow

- through cell consistent with standard methods (e.g., APHA, 2005) given sufficient flow rates and volumes. Field chemistry probes will be calibrated at the beginning of each samp ling day according to equipment manufacturer procedures using standard
reference solutions. When a flow

- through cell is used, field parameters will be continuously monitored
and will be considered stable when three successive measurements made three minute s apart meet the
criteria listed in Table 20

.

Table 20

. Stabilization criteria of water quality parameters during shallow well purging

. 

### FIELD PARAMETER STABILIZATION CRITERIA pH +/

- 0.2 units Temperature +/

- 1° C Specific Conductance +/

- 3% of reading in μS/cm Dissolved Oxygen +/

- 10% of reading or 0.3 mg/L whichever is greater

After field parameters have stabilized, samples will be collected. Samples requiring filtration will be filtered through 0.45 μm flow

- through filter cartridges as appropriate and consistent with ASTM D6564

- 00. Prior to sample collection, filters will be purged with a minimum of 100 m L of well water (or more if required by the filter manufacturer). For alkalinity and total CO 2 

### samples, efforts will be made to minimize exposure to the atmosphere during filtration, collection in sample containers, and analysis

.

For deep groundwater sampling of VW#1, I SGS

- SOP

- WB

- V1 .14 (dated August 10, 2012) will be used for the collection and processing of Westbay samples. Wells GM#2 and VW#2 will not have a Westbay installation for sampling and are anticipated to use a wireline sampling system with a sampling device (e.g., Kuster sampler or similar) capable of collecting a sample from a discrete interval. Samples from GM#2 and VW#2 will be processed in a manner consistent with ISGS

- SOP

- WB

- V1.14.

VW#1 was developed and purged extensiv ely at the time of completion and similar plans to develop VM#2 are in place and will be executed when completion occurs. Prior to sampling

, each zone will be purged to ensure representative samples are collected. Due to the extensive well development , t he amount of fluid to be purged at the time of sampling will be relatively small. If a three

- foot zone is perforated (similar to VW#1)

, then the annular space between the 2

- 7/8

- in. tubing and the 5

- 1/2

- in. casing is only 1.92 ga l. Thus, relatively small purge volumes will adequately refresh each isolated sampling interval. Similar purging techniques will be used for VW#1 and VW#2. Additional information about sampling procedures at VW#1 are given in Locke et al. (2013).

For VW#2, it is anticipated that air lift ing with nitrogen will be used to draw fluid into the well for purging . A gas lift valve will be placed in the tubing string at approximately 1

, 200 f t below ground

### 27 surface at the time of the completion. The sampler will be positioned at the same elevation as the discrete perforated interval, and a sample would be collected after sufficient purging.

B.2.c. In

- situ M onitoring.

In- situ monitoring of groundwater chemistry parameters is not currently planned.

B.2.d. Continuous M onitoring.

Pressure data will be collected from shallow groundwater wells on a periodic basis (e.g., hourly to daily) using dedicated pressure transducers with data loggers to generally characterize shallow water level
trends. The se data are informational only.

B.2.e. Sample Homogenizatio n, C omposition, Filtration.

Described in section B.2.b.

B.2.f. Sample C ontainers and V olumes

For CO 2 

### stream monitoring, samples will be collected in a clean sample container rated for the appropriate collection pressure (i.e. mini cylinders or polybags provided by Airborne Labs International Inc., Somerset, NJ ).

Assay for CO 2 

### Quarterly Gas Analysis :

• CO 2 

### Purity (% v/v, [GC])

• Oxygen (O 2 

### , ppm v/v)

• Nitrogen (N 2 

### , ppm v/v)

• Carbon Monoxide (CO, ppm v/v)

• Oxides of Nitrogen (NOx, ppm v/v)

• Total Hydrocarbons (THC, ppm v/v as CH 4 

### )

• Methane (CH 4 

### , ppm v/v)

• Acetaldehyde (AA, ppm v/v)

• Sulfur Dioxide (SO 2 

### , ppm v/v)

• Hydrogen Sulfide (H 2 

### S ppm v/v)

• Ethanol (ppm v/v)

For shallow and deep groundwater sample s, all sample bottles will be new. S ample bottles and bags for analytes will be used as received (ready for use) from the vendor or contract analytical laboratory for the analyte of interest. A summary of sample containers is presented in Table 22



### . B.2.g. Sample P reservation

For groundwater and other aqueous samples

, the preservation methods in Table 22 

### will be used.

No preservation is required or used for CO 2 

### gas stream, and additional details of sampling requirements

are shown in Table 21

. Corrosion coupon sampling only requires that the coupons be physically separated (e.g., sleeves, baggies) during transportation to prevent physical abrasion

.

### 28 Table 21

. Summary of sample containers, preservation treatments, and holding times for CO 2 gas stream analysis

.

**Target P ara**  **m eters**  **Volume/Container**

**Material Preservation**  **Technique Sample Holding time**  **(max)**

CO 2 gas stream 

### (2) 2L MLB Polybags

(1) 75 cc Mini Cylinder Sample Storage

Cabinets 5 Business Days

B.2.h. Cleaning/D econtamination of S ampling E quipment

Dedicated pumps (e.g., bladder pumps) will be installed in each groundwater monitoring well to minimize potential cross contamination between wells. These pumps will remain in each well throughout the project period except for maintenance. Prior to installation

, the pumps will be cl eaned
on the outside with a non

- phosphate detergent. Pumps will be rinsed a minimum of three times with
deionized water and a minimum of 1 L of deionized water will be pumped through pump and sample tubing. Individual cleaned pumps and tubing will be placed in plastic garbage bags for transport to the
field for installation. All field glassware (pipets, beakers, filter holder s, etc

. ) are cleaned with tap water to remove any loose dirt, washed in a dilute nitric acid solution

, and rinsed three times with deionized

water before use

.

CO 2 

### gas stream sampling containers will be either disposed or decontaminated by the analytical l ab.

No sampling equipment will be utilized with the corrosion coupons or annual field gauge calibrations.

B.2.i Support Facilities

For sampling of groundwater, the following are required: air compressor, vacuum pump, generator,
multi

- electrode water quality sonde, analytical meters (pH, specific conductance, etc.). Field activities are usually completed in field vehicles and portable laboratory trailers located on site.

Sampling tubing, connectors and valv es required to sample the CO 2 

### gas stream will be supplied by the analytical lab providing the sampling containers. Sampling will occur within the existing CO 2 

### compression building.

Similarly, corrosion coupons will be removed from the CO 2 

### injection line within the existing CO 2 

### compre ssion building.

Field gauges will be removed from the injection well and verification well utilizing existing standard industry tools and equipment. Deployment and retrieval of verification well gauges will be done using procedures and equipment recommended by the vendor, subcontractor, or is standard per industry practice.
B.2.j. Corrective Action, Personnel, and Documentation

Field staff will be responsible for properly testing equipment and performing corrective actions on broken or malfunctioning fiel d equipment. If corrective action cannot be taken in the field, then

### 29 equipment will be returned to the manufacturer for repair or replaced. Significant corrective actions affecting analytical results will be documented in field notes.



### B.3. **Sample Handling and Custody** 

Logging, geophysical monitoring, and pressure/temperature monitoring does not apply to this section,
and is omitted.

Sample holding times ( Table 22 

### ) will be consistent with those described in US EPA (1974), American Public Health Association (APHA, 2005), Wood (1976), and ASTM Method D6517

- 00 (2005). After collection, samples will be placed in ice chests in the field and maintained thereafter at approximat ely 4°C until analysis. The s amples will be maintained at their preservation temperature and sent to the designated laboratory within 24 hours

. Analysis of the samples will be completed within the holding
time listed in Table 22



### . B.3.a Maximum Hold Time/Time Before Retrieval

See Table 22



### . B.3.b. Sample Transportation

See descr iption at the beginning of Section B.3.

B.3.c. Sampling Documentation

Field notes will be collected for all groundwater samples collected. These forms will be retained and archived as reference. The sample documentation is the responsibility of g roundwate r sampling personnel.

An analysis authorization form shall be provided with each CO 2 

### gas stream sample provided for analysis
as shown by the example in Figure 4



### . B.3.d. Sample Identification

All sample bottles will have waterproof labels with information denoting project, sampling date, sampling location, sample identification number, sample type (fr eshwater or brine), analyte, volume, filtration used (if any), and preservative used (if any). See Figure 3 for a n example of a label

.

### 30 Table 22

. Summary of anticipated sample containers, preservation treatments, and holding times

.

Target P ar am eter s Volume/Container Material Preservation Technique Sample Holding time Relative Sampling Depth

Cations: Ca, Fe, K, Mg, Na, Si, Al, Ba, Mn, As, Cd, Cr, Cu, Pb, Sb Se, Tl 250 ml/ HDPE Filtered, nitric acid, cool 4°C 60 days Shallow

Dissolved CO 2 2 × 60 ml/ HDPE Filtered, cool 4°C 14 days Shallow

Dissolved CO 2 60 ml/ HDPE Filtered, cool 4°C 14 days Deep

Isotopes: 3 H, δD, δ 18 O, δ 34 S, and δ 13 C 2 × 60 ml/ HDPE Filtered, cool 4°C 4 weeks Shallow

Isotopes: δ 34 S 250 ml/ HDPE Filtered, cool 4°C 4 weeks Deep

Isotopes: δD, δ 18 O, δ 13 C 60 ml/ HDPE Filtered, cool 4°C 4 weeks Deep

Alkalinity, anions ( Br, Cl, F, NO 3 , SO 4 ) 500 ml/ HDPE Filtered, cool 4°C 45 days Shallow

Field Confirmation: Temperature, dissolved oxygen, specific conductance, pH 200 ml/glass jar N one < 1 hour Deep

Field Confirmation: D ensity 60 ml/ HDPE Filtered < 1 hour Deep

### 31 IL- ICCS_10LG_20A (fresh water)
01

- 23

- 2014 Metals, 60 ml, filtered, HNO 3

Figure 3. Example label for groundwater sample bottle s.



### B.3.e. Sample Chain

- of -C ustody

For CO 2 

### stream analysis , an a nalysis a uthorization form ( Figure 4) will accompan y the sample to th e lab at which point a chain

- of

- custody accompanies the sample through their processes

.

For groundwater samples, chain

- of

- custody will be documented using a standardized form

. A typical
form is sho wn in Figure 5 

### , and it or a similar form will be used for all groundwater sampling

. Copies of the form will be provided to the person/lab receiving the samples as well as the person/lab transferring the samples. These forms will be retained and archived to allow simplified tracking of sample status. The
chain

- of

- custody form and record keeping is the responsibility of groundwater sampling personnel.



### B.4

**. Analytical Methods** 

Logging, geophysical monitoring, and pressure/temperature monitoring does not apply to this section,
and is omitted.

B.4.a. Analytical SOPs

A nalytical SOPs are referenced in Table 4

- Table 7 

### . Other laboratory specific SOPs utilized by the laboratory will be determined after a contract laboratory has been selected. Upon request ADM will provide the agency with all laboratory SOPs developed for the specific parameter using the appropriate
standard method. Each laboratory technician conducting the analysis on the samples will be trained on the SOP developed for each standard method. ADM will include the technician’s training certification with the biannual report.

B.4.b. Equipment/Instrumentation Needed

Equipment and instrumentation is specified in the individual analytical methods referenced in Table 4

- Table 7



### .
B.4.c. Method Performance Criteria

Non standard method performance criteria are not anticipated for this project.

B.4.d. Analytical Failure

Each laboratory conducting the analyses in Table 4

- Table 7 

### will be responsible for appropriate ly addressing analytical failure according to their individual SOPs.

B.4.e. Sample Disposal

Each laboratory conducting the analyses in in Table 4

- Table 7 

### will be responsible for appropriate sample disposal according to their individual SOPs.

B.4.f Laboratory Turnaround

Laboratory turnaround will vary by laboratory, but generally turnaround of verified analytical results within one month will be suitable for project needs.

### 32 B.4.g. Method Validation for Nonstandard Methods

Nonstandard method s are not anticipated for this p roject. If non standard methods are needed or proposed in the future, the USEPA will be consulted on additional appropriate actions to be taken.

### 33 Figure 4

. Example of CO 2 gas stream analysis authorization form.

### 34 Figure 5

. Example c hain

- of -c ustody form

.

### 35 

### B.5. **Quality Control**

G eophysical monitoring and pressure/temperature monitoring does not apply to this section, and is
omitted. For log quality control, please refer to Appendix B.

B.5.a. QC activities

Blanks For shallow groundwater sampling, a field blank will be collected and analyzed for the inorganic analytes

in Table 4

- Table 7 

### at a frequency of 10% or greater. Field blanks will be exposed to the same fi eld and transport conditions as the groundwater samples. Blanks will also be utilized for deep groundwater sampling and analyzed for the inorganic analytes in Table 4

- Table 7 

### at a frequency of 10% or greater. Field blanks will be used to detect contamination resulting from the collection and transportation

process.
Duplicates For each shallow groundwater sampling round, a duplicate groundwater sample is collected from a well from a rotating schedule. Duplicate samples are collected from the same source immediately after the original sample in different sample containers and processed as all other samples. Duplicat e samples are used to assess sample heterogeneity and analytical precision.

B.5.b. Exceeding Control L imits

If the sample analytical results exceed control limits (i.e., ion balances > ±1 0 %) , further examination of the analytical results will be done by evaluating the ratio of the measured total dissolved solids (TDS) to
the calculated TDS (i.e., mass balance) per APHA method. The method indicates which ion analyses should be considered suspect based on the mass balance ratio

. Suspect ion analyses are then reviewed
in the context of historical data and interlaboratory results, if available. Suspect ion analyses are then brought to the attention of the analytical laboratory for confirmation and/or reanalysis. The ion balance is recalculated, and if the error is still not resolved, suspect data are identified and may be given less importance in data interpretations.

B.5.c. Calculating A pplicable QC S tatistics

Charge B alance The analytical results are evaluated to determine correctness of analyses based on anion

- cation charge
balance calculation . Because all potable waters are electrically neutral, the chemical analyses should yield equally negative and positive ionic activity. The anion

- cation charge balance will be calculated using the formula :

% dif ference = 100 ∑ cations

− ∑ anions ∑ cations + ∑ anions 

### , (E q uation 1)

where the sums of the ions are represented in milliequivalents (meq) per liter and the criteria for acceptable charge balance is ±10%

.

Mass Balance

The ratio of the measured TDS to the calculated TDS will be calculated in instances where the charge balance acceptance criteria are exceeded using the formula:

1.0 < measured TDS

calculated TDS 

### < 1.2

, (E q uation 2)

### 36 where the anticipated values are between 1.0 and 1.2.

Outliers A determination of one or more statistical outliers is essential prior to the statistical evaluation of groundwater. This project will use the USEPA’s Unified Guidance (March 2009) as a basis for s election of
recommended statistical methods to identify outliers in groundwater chemistry data sets as appropriate . These techniques include Probability Plots, Box Plots, Dixon’s test, and Rosner’s test. The

EPA

- 1989 outlier test may also be used as anothe r screening tool to identify potential outliers.



### B.6. **Instrument/Equipment Testing, Inspection, and Maintenance**

Logging tool equipment will be maintained as per wireline industry best practices (Appendix B).

For groundwater sampling, field equipment will be maintained, factory serviced, and factory calibrated per manufacturer’s 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 standard practice, method

- specific protocol, or NELAP requirement.



### B.7. **Instrument/Equipment Calibration and Frequency**

Geophysical monitoring does not apply to this section, and is o mitted.

B.7.a. Calibration and F requency of C alibration Pressure/temperature gauge calibration information is located in Table 12

- Table 19

. Logging tool calibration will be at the discretion of the service company pr oviding the equipment, following standard industry practices noted in Appendix B. Calibration frequency will be determined by standard industry practices.

For groundwater sampling, portable field meters or muliprobe sondes used to determine field
paramete rs (e.g., pH, temperature, specific conductance, dissolved oxygen) are calibrated according to manufacturer recommendations and equipment manuals (Hach, 2006) each day before sample collection begins. Recalibration is performed if any components yield atypical values or fail to stabilize during sampling.

B.7.b. Calibration M ethodology Logging tool calibration methodology will follow standard industry practices in Appendix B.

For groundwater sampling, standards used for calibration are typically 7 and 10 f or pH, a potassium
chloride solution yielding a value of 1413 microseimens per centimeter ( μS/cm ) at 25°C for specific
conductance , and a 100% dissolved O 2 

### solution for dissolved oxygen . Calibration is performed for the pH

meters per manufactuer’s specifications using a 2

- point calibration bounding the range of the sample

. For coulometry, sodium carbonate standards (typically yielding a concentration of 4

, 000 mg CO 2 

### /L) are routinely analyzed to evaluate instrument

.
B.7.c. Calibration Resolution and D ocumentation Logging tool calibration resolution and documentation will follow standard industry practices in Appendix B.

### 37 For groundwater sampling, calibration values are recorded in daily sampling records and any errors in
calibration are noted. For pa rameters where calibration is not acceptable, redundant equipment may be
used so loss of data is minimized.



### B.8. **Inspection/Acceptance for Supplies and Consumables**

B.8.a /b

. Supplies, Consumables, and Responsibilities

Supplies and consumables for field and laboratory operations will be procured, inspected, and accepted as required from vendors approved by ADM or the respective subcontractor responsible for the data
collection activit y. Acquisition of supplies and consumables related to groundwater analyses will be the responsibility of the laboratory per established standard methodology or operating procedures.



### B.9. **Non direct Measurements** 

Seismic M onitoring M ethods

B.9.a Data Sources For time lapse seismic surveys, repeatability is paramount for accurate differential comparison. Therefore, to ensure survey quality, the locations for the shots and acquisition methodology of sequential surveys will be consistent. Once these surveys are conducted, they will be compared to a baseline survey to track and monit or plume development.

For in

- zone pressure monitoring, the in

- zone pressure gauges in VW#1 and VW#2 will be used to gather pressure data.

B.9.b. Relevance to P roject Time lapse seismic surveys will be used to track changes in the CO 2 

### plume in the subsurf ace. Processing and comparing subsequent surveys to a baseline will allow project managers to monitor plume growth, as well as to ensure that the plume does not move outside of the intended storage reservoir. Numerical modeling will be used to predict the CO 2 

### plume growth and migration over time by combining the processed seismic data with the existing geologic model.

In

- zone pressure monitoring data will be used in numerical modeling to predict plume and pressure front behavior and confirm the plume stag e within the AOR.

B.9.c. Acceptance C riteria Following standard industry practices will ensure that the gathered seismic data will be used for accurate modeling and monitoring. Similar ground conditions, shot points located within tolerable limits,
functio nal geophones, and similar seismic input signal will be used from survey to survey to ensure repeatability.

When processing seismic data, several QA checks will be done in accordance with industry standards including reformatting to Omega structured files , geometry application, amplitude compensation, predictive deconvolution, elevation statics correction, RMS amplitude gain, velocity analysis every 2 km, NMO application using picked velocities, CMP stacking, random noise attenuation, and instantaneous gai n.
B.9.d. Resources/F acilities Needed

ADM will subcontract all necessary resources and facilities for the seismic monitoring

, in

- zone pressure monitoring , and groundwater sampling.

### 38 B.9.e. Validity Limits and O perating C conditions For seismic surveys and numerical modeling, intraorganizational checks between trained and experienced personnel will ensure that all surveys and numerical modeling are conducted conforming to standard industry practices.



### B.10. **Data Management**

B.10.a

. Data M anagement S cheme

ADM or a designated contractor will maintain the required project data as provided elsewhere in the permit . Data will be backed up on tape or held on secure servers.

B.10.b

. Record

- keeping and Tracking P ractices

All records of gathered data will be securely held and properly labeled for auditing purposes.

B.10.c. Data H andling E quipment/ Procedures

All equipment used to store data will be properly maintained and operated according to proper industry techniques. ADM SCADA system and vendor data acquisition systems will interface with one another and all subsequent data will be held on a secure server.

B.10.d. Responsibility

The primary project managers will be responsible for ensuring proper data management is maintained.

B.10.e. Data Archival and R etrieval

All data will be held by ADM

. These data will be maintained and stored for auditing purposes as
described in section B.10.a.

B.10.f. Hardware and Software C onfigurations

All ADM and vendor hardware and software configurations will be appropriately inter faced.

B.10.g. Checklists and F orms

Checklists and forms will be procured and generated as necessary. 

## C. Assessment and Oversight

**C.1. Assessments and Response Actions** 

C.1.a. Activities to be C onducted

Please refer to Table 1 in section A.3.a/b . ( Summary of work to be performed and work schedule );

g roundwater quality data will be collected at the frequency outlined in that table

. After completion of sample analysis, results will be reviewed for QC criteria as noted in section B.5. If the data quality fails to
meet criteria set in section B.5

. , samples will be reanalyzed, if still within holding time criteria

. If outside of holding time criteria, additional samples may be collected or sample results may be excluded from data evaluations and interpretations

. Evaluation for data consistency will be performed according to procedures described in the USEPA 2009 Unified Guidance (USEPA, 2009).

C.1.b. Responsibility for Conducting Assessments

Organizations gathering data will be responsible for conducting their internal assessments. All stop work orders will be handled internally within individual organizations.

### 39 C.1.c. Assessment Reporting

All assessment information should be reported to the individual organizations project manager outlined in A.1.a/b.

C.1.d. Corr ective A ction

All corrective action affecting only an individual organization’s data collection responsibility should be addressed, verified, and documented by the individual project managers and communicated to the other project managers as necessary. Corrective actions affecting multiple organizations should be addressed by all members of the project leadership and communicated to other members on the distribution list for the QASP. Assessments may require integration of information from multiple

monitori ng sources across organizations (operational, in

- zone monitoring, above

- zone monitoring) to determine whether correction actions are required and/or the most cost

- efficient and effective action to implement. ADM will coordinate multiorganization assessments and corrective actions as warranted.



### C.2. **Reports to Management**

C.2.a /b . QA status R eports

QA status reports should not be needed. If any testing or monitoring techniques are changed, the QASP will be reviewed and updated as appropriate in consultation with USEPA. Revised QASPs will be distributed by ADM to the full distribution list at the beginning of this document.



## D. **Data Validation and Usability**

**D.1. Data Review, Verification, and Validation** 

D.1.a. Criteria for A ccepting, R ejecting, or Qualifying D ata

Groundwater quality data validation will include the review of the concentration units, sample holding times, and the review of duplicate, blank and other appropriate QA/QC results. All groundwater quality results will be entered into a database or spr eadsheet with periodic data review and analysis

. ADM will

retain c opies of the laboratory analytical test results and/or reports

. Analytical results will be reported on a frequency based on the approved UIC permit conditions. In the periodic reports, dat a will be presented in graphical and tabular formats as appropriate to characterize general groundwater quality
and identify intrawell variability with time. After sufficient data have been collected, additional
methods

, such as those described in the USEPA 2009 Unified Guidance (USEPA, 2009)

, will be used to evaluate intrawell variations for groundwater constituents

, to evaluate if significant changes have
occurred that could be the result of CO 2 

### or brine seepage beyond the intended storage reservoir.

### 40 

### D. **2. Verification and Validation Methods** 

D.2.a. Data Verification and Validation Pr ocesses

See sections D.1.a

. and B.5.

Appropriate statistical software will be used to determine data consistency.

D.2.b. Data Verification and V alidation R esponsibility

ADM or its designated subcontractor will verify and validate groundwater sampling data.

D.2.c. Issue Resolution P rocess and Responsibility

ADM or its designated Coordinator will overview the groundwater data handling, management, and
assessment process. S taff involved in these processes will consult with the Coordinator to determine actions required to resolve issues.

D.2.d. Checklist, Forms, and C alculations

Checklists and forms will be developed specifically to meet permit requirements. Table 23 provides an example of the type of information used for data verification of groundwater quality data

.

Table 23

. Example table of cr iteria used to evaluate data quality.

MVA ID Anion charge Cation charge Charge
balance CB rating Calculated

TDS Measured

TDS TDS ratio TDS rating ICCS_10B_01A 14.4 13.6 0

- 2.84 pass 760.5 0 785 1.0 pass ICCS_10B_02A 14.26 15.06 2.73 pass 783.03 777 1.0 pass ICCS_10B_03A 14.39 14.96 1.94 pass 786.86 806 1.0 pass ICCS_10B_04A 14.39 14.79 1.38 pass 780.15 777 1.0 pass ICCS_10B_04B 14.33 14.9 0 1.96 pass 780.95 785 1.0 pass



### D.3. **Reconciliation with User Requirements**

D.3.a. E valuation of D ata Uncertainty

Statistical software will be used to determine groundwater data consistency using methods consistent
with USEPA 2009 Unified Guidance (USEPA, 2009).

D.3.b. Data Limitations Reporting

The organization

- level project managers will be responsible for ensuring that data developed by their respective organizations is presented with the appropriate data

- use limitations.

ADM will use the current operating procedure on the use, sharing

, and presentation of results and/or
data for the IL

- ICCS project. This procedure has been developed to ensure quality, internal consistency and facilitate tracking and record keeping of data end users and associated publications.

### 41 

## References

APHA, 2005, Standard methods for the examination of water and wastewater (21 st 

### edition), Am erican Public Health Association, Washington, DC.

ASTM, 2010, Method D7069

- 04 (reapproved 2010), Standard guide for field quality assurance in a ground

- water sampling event , ASTM International, 100 Barr Harbor Drive, West Conshohocken, PA.

ASTM, 2010, Me thod D6911

- 03 (reapproved 2010), Standard guide for packaging and shipping environmental samples for laboratory analysis , ASTM International, 100 Barr Harbor Drive, West Conshohocken, PA.

ASTM, 2005, Method D6517

- 00 (reapproved 2005), Standard guide for field preservation of ground

water samples , ASTM International, 100 Barr Harbor Drive, West Conshohocken, PA.

ASTM, 2005, Method D6564

- 00 (reapproved 2005), Standard guide for field filtration of ground

- water samples , ASTM International, 100 Barr Harbor Dr ive, West Conshohocken, PA.

ASTM, 2005, Method D6452

- 99 (reapproved 2005), Standard Guide for Purging Methods for Wells Used for Ground

- Water Quality Investigations , ASTM International, 100 Barr Harbor Drive, West Conshohocken, PA.

ASTM, 2002, Method D513

- 11

, Standard test methods for total and dissolved carbon dioxide in water

, ASTM International, 100 Barr Harbor Drive, West Conshohocken, PA.

ASTM, 2002, Method D6771

- 02, Standard guide for low

- flow purging and sampling for wells and devices used for ground

- water quality investigations , ASTM International, 100 Barr Harbor Drive, West Conshohocken, PA.

Gibb, J.P., R.M. Schuller, and R.A. Griffin, 1981, Procedures for the collection of representative water quality data from monitoring wells, Illinois State Geological Survey Cooperative Groundwater Report 7, Champaign, IL, 61 p.

Hach Company, February 2006, Hydrolab DS5X, DS5, and MS5 Water Quality Multiprobes User Manual

, Hach Company, 73 p.

Larson, D.R., B.L. Herzog , and T.H. Larson, 2003, Groundwa ter geology of DeWitt, Piatt, and Northern Macon Counties, Illinois. Illinois State Geological Survey Environmental Geology 155, 35 p.

Locke II, R.

, D. Larssen, W. Salden, C. Patterson, J. Kirksey, A. Iranmanesh, B. Wimmer, I. Krapac. Preinjection reservoir fluid characterization at a CCS demonstration site: Illinois Basin – Decatur Project,

USA . Proceedings of the 11th International Conference on Greenhouse Gas Technologies, November 18

– 22, 2012, Kyoto, Japan. Energy Procedia v. 37, 2013, p. 6,424

– 6,433. http://dx.doi.org/10.1016/j.egypro.2013.06.572

### 42 O’Dell, J.W., J.D. Pfaff, M.E. Gales, and G. D. McKee, 1984, Test Method

— The Determination of Inorganic Anions in Water by Ion Chromatograph y- Method 300 , U.S. Environmental Protection Agency, EPA

600/4

- 84

- 017.

Orion Research Inc., 1990, CO 2 

### Electrode Instruction Manual , Orion Research Inc., 36 p.

Puls, R.W., and M.J. Barcelona, 1996, Low

- Flow (Minimal Drawdown) Ground

- Water Sampling
Procedur es . U.S. Environmental Protection Agency, EPA

- 540/S

- 95/504.

U.S. Environmental Protection Agency ( US EPA ) , 2009, Statistical analysis of groundwater monit oring data at RCRA facilities

— Unified Guidance , US EPA, Office of Solid Waste, Washington, DC.

U.S. Environmental Protection Agency ( US EPA ) , 1974, Methods for chemical analysis of water and
wastes, US EPA Cincinnati, OH, EPA

- 625

- /6

- 74

- 003a.

Wood, W. W., 1976, Guidelines for collection and field analysis of groundwater samples for selected
unstable cons tituents , In U.S. Geological Survey, Techniques for Water Resources Investigations, Chapter

D- 2, 24 p.

### 43 

## Appendices

**APPENDIX A.**  **DTS and Down**

**- hole Pressure Gauge Information** 

# Copyrighted page(s) removed. Copyrighted material is not available in Regulations.gov since it may not be reproduced without consent of the copyright holder.

Removed pages can be viewed at the USEPA Docket Center, Public Reading Room.

Address: 1301 Constitution Ave, NW Room 3334 Washington, DC 20004

Telephone: 202-566-1744

Email: docket-customerservice@epa.gov

### 48 

### APPENDIX B. **Log Quality Control Reference Manual (LQCRM)**

# Copyrighted page(s) removed. Copyrighted material is not available in Regulations.gov since it may not be reproduced without consent of the copyright holder.

Removed pages can be viewed at the USEPA Docket Center, Public Reading Room.

Address: 1301 Constitution Ave, NW Room 3334 Washington, DC 20004

Telephone: 202-566-1744

Email: docket-customerservice@epa.gov