Illinois Industrial Carbon Capture and Sequestration (IL-ICCS) Project 

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 MANAGEMENT 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. Method 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 AND ACQUISITION 22

B.1. Sampling Process Design (Experimental Design) 22

B.1.a. Design Strategy 23

CO2 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. Analytical SOPs 31

B.4.c. Method Performance Criteria 31

B.4.d. Analytical Failure 31

B.4.e. Sample Disposal 31

B.4.f Laboratory 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 Methodology 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 OVERSIGHT 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. DATA VALIDATION AND USABILITY 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 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. 41

APPENDICES 43

APPENDIX A. DTS and Down-hole Pressure Gauge Information 43

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

TABLE 1. SUMMARY OF TESTING AND MONITORING. 4

TABLE 2. INSTRUMENTATION SUMMARY. T = TEMPERATURE; P = PRESSURE; DTS = DISTRIBUTED TEMPERATURE 

SYSTEM; F = FLOW (CONTINUED ON PAGE 9). 7

TABLE 3. GEOPHYSICAL SURVEYS SUMMARY. 9

TABLE 4. SUMMARY OF ANALYTICAL AND FIELD PARAMETERS FOR QUATERNARY/PENNSYLVANIAN 

GROUNDWATER SAMPLES. 13

TABLE 5. SUMMARY OF ANALYTICAL AND FIELD PARAMETERS FOR ST PETER RESERVOIR GROUNDWATER 

SAMPLES. 14

TABLE 6. SUMMARY OF ANALYTICAL AND FIELD PARAMETERS FOR IRONTON-GALESVILLE GROUNDWATER 

SAMPLES. 15

TABLE 7. SUMMARY OF ANALYTICAL AND FIELD PARAMETERS FOR MT SIMON GROUNDWATER SAMPLES. 16

TABLE 8. SUMMARY OF ANALYTICAL PARAMETERS FOR CO2 GAS STREAM. 17

TABLE 6. SUMMARY OF ANALYTICAL PARAMETERS FOR CORROSION COUPONS. 18

TABLE 7. SUMMARY OF MEASUREMENT PARAMETERS FOR FIELD GAUGES. 18

TABLE 8. ACTIONABLE TESTING AND MONITORING OUTPUTS. 19

TABLE 12. PRESSURE AND TEMPERATURE—DOWNHOLE QUARTZ GAUGE SPECIFICATIONS. 20

TABLE 10. LOGGING TOOL SPECIFICATIONS. 20

TABLE 11. PRESSURE FIELD GAUGE PIT-009—INJECTION TUBING PRESSURE. 20

TABLE 12. PRESSURE FIELD GAUGE PIT-014—ANNULS PRESSURE. 21

TABLE 13. PRESSURE FIELD GAUGE PIT-012. 21

TABLE 14. TEMPERTATURE FIELD GAUGE TIT-019 —INJECTION TUBING TEMPERATURE. 21

TABLE 15. MASS FLOW RATE FIELD GAUGE—FT-006 CO2 MASS FLOW RATE. 21

TABLE 16. WESTBAY FIELD GAUGE—WESTBAY (MOSDAX) PRESSURE. 21

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

TABLE 18. SUMMARY OF SAMPLE CONTAINERS, PRESERVATION TREATMENTS, AND HOLDING TIMES FOR CO2 GAS 

STREAM ANALYSIS. 28

TABLE 19. SUMMARY OF ANTICIPATED SAMPLE CONTAINERS, PRESERVATION TREATMENTS, AND HOLDING TIMES.

30

TABLE 20. EXAMPLE TABLE OF CRITERIA USED TO EVALUATE DATA QUALITY. 40

List of Figures

FIGURE 1. ARCHER DANIELS MIDLAND COMPANY KEY PROJECT PERSONNEL. 2

FIGURE 4. IL-ICCS PROJECT AREA SHOWING LOCATION OF EXISTING SHALLOW GROUNDWATER MONITORING 

WELLS AND PLANNED DEEP WELLS. 10

FIGURE 5. EXAMPLE LABEL FOR GROUNDWATER SAMPLE BOTTLES. 31

FIGURE 6. EXAMPLE OF CO2 GAS STREAM ANALYSIS AUTHORIZATION FORM. 33

FIGURE 7. EXAMPLE CHAIN-OF-CUSTODY FORM. 34
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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. The 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 Responsibilities

The project, led by Archer Daniels Midland Company (ADM), includes 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 Integrity Testing (MIT)

V) Pressure/Temperature Monitoring

VI) CO2 Stream Analysis

VII) Geophysical Monitoring

A.1.c. Independence from Project QA Manager and Data Gathering

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 Chart for Key Project Personnel

Figures 1 shows the organization structure of the project. ADM will provide to the UIC Program Director 

a contact list of individuals fulfilling these roles. 
2 

Figure 1. Archer Daniels Midland Company project organization structure.

A.2. Problem Definition/Background

A.2.a Reasoning

The Illinois Industrial Carbon Capture and Storage (IL-ICCS) Project’s monitoring, verification, and 

accounting (MVA) program has operational monitoring, verification, and environmental monitoring 

components. Operational monitoring is used to ensure safety with all procedures associated with fluid 

injection, monitor the response of storage unit, and the movement of the CO2 plume. Key monitoring 

parameters include the pressure of injection well tubing & annulus, storage unit, above seal strata, and 

the lowermost USDW reservoir. 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 CO2 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 provides a high level of confidence that the storage unit (Mt Simon) is capable to accept and 

permanently retain the injectate. The primary goal of the IL-ICCS MVA program is to demonstrate that 

project activities are protective of human health and the environment. 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 Injection Control (UIC) Program for Class VI wells. 
3 

A.2.b. Reasons for Initiating the Project

The goal of the IL-ICCS injection project is to demonstrate the ability of the Mt. Simon Sandstone to 

accept and retain industrial-scale volumes of CO2 for permanent geologic sequestration to reduce 

atmospheric concentrations of CO2. In order to demonstrate that this can be done safely and at 

commercial scale, a rigorous MVA plan is proposed to ensure the injected CO2 is retained within the 

intended storage reservoir. 

A.2.c. Regulatory Information, Applicable Criteria, Action Limits

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 

permit application, and that underground sources of drinking water (USDWs) are not endangered. These 

monitoring activities include mechanical integrity tests (MITs), injection well testing during operation, 

monitoring of ground water quality in several zones, tracking of the CO2 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 making decisions 

during the life of the project.

A.3. Project/Task Description

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

Table 1 describes the Testing and Monitoring tasks, reasoning, responsible parties, locations and testing 

frequency. Tables 2 and 3 summarize the instrumentation 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 

Technique Lab/Custody Purpose

Carbon dioxide stream 

analysis Compressor Direct sampling 2 years: 

Quarterly Quarterly None Chemical analysis TBD Monitor injectate

After CO2

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- ContinuousYr 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 ContinuousYr 2-10 – N/A

Direct 

measurement N/A Wellbore integrity

Cement evaluation 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 injectionapproximately 

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 

geophones 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 groundwater

(Quaternary & 

Pennsylvanian)

Figure 2 In-situ 2 years: 

Quarterly

Year 1–2: 

Quarterly

Year 3–5: Biannually

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 

monitoring and CO2

detection in storage 

reservoir.

VW2 In-situ 1 sample Annually Annually Chemical analysis Table 7

Detection of changes 

in groundwater 

quality, geochemical 

monitoring and CO2

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 CO2

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 CO2

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 CO2 Plume Tracking

Method Location Pre-injection—Baseline Operation Period—5 years PISC Period—10 Years Purpose

Time lapse VSP GM1 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

CO2 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 strata

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 strata 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

well head

Tubing Continuous Tubing Continuous Monitoring operational, equipment, and permit 

parameters

P Annulus Continuous Annulus Continuous Monitoring well integrity

DTS All geologic 

strata

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 

IrontonGalesville

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 IrontonGalesville

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

Seismometers 

& 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 Mechanical Integrity

VW#1

Cement evaluation 

tool 1 Baseline None None Mechanical Integrity

Pulse neutron 1 Baseline Year 2, 4 Year 1, 3, 5, 7, 10 Fluid movement, salinity, CO2

detection, mechanical integrity

VW#2

Cement evaluation 

tool 1 Baseline None None Mechanical Integrity

Pulse neutron 1 Baseline Year 2, 4 Year 1, 3, 5, 7, 10 Fluid movement, salinity, CO2

detection, mechanical integrity

CCS#1

Pulse neutron 1 Baseline Year 2, 4 Year 1, 3, 5, 7, 10 Fluid movement, salinity, CO2

detection, mechanical integrity

Casing inspection 1 Baseline None None Mechanical Integrity

Cement evaluation 

tool 1 Baseline None None Mechanical Integrity

CCS#2

Pulse neutron 1 Baseline Year 2, 4 Year 1, 3, 5, 7, 10 Fluid movement, salinity, CO2

detection, mechanical integrity

Casing inspection 1 Baseline None None Mechanical Integrity

Cement evaluation 

tool 1 Baseline None None Mechanical Integrity

Seismic

GM#1 Time-lapse VSP 

survey 2013, 2014, 2015 None None Monitor spatial extent of plume

Area 3D surface seismic 

survey

1 Baseline Year 2 (2018) Year 1, Year 10 Monitor spatial extent of plume
10

A.3.c. Geographic Locations

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 Time Constraints

At the conclusion of the IBDP project, the availability of wells associated with that project (VW#1, GM#1, 

CCS#1) are potential resource constraints for IL-ICCS. Under 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 constraints 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 Criteria

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-injection phases of the project. Shallow and deep 

groundwater monitoring wells will be used to gather water-quality samples and pressure data. All the 

groundwater analytical and field monitoring parameters 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

• Aqueous 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. CO2 Stream Analysis

• CO2 Purity (% v/v, [GC])

• Oxygen (O2, ppm v/v)

• Nitrogen (N2, ppm v/v)

• Carbon Monoxide (CO, ppm v/v)

• Oxides of Nitrogen (NOx, ppm v/v)

• Total Hydrocarbons (THC, ppm v/v as CH4) 

• Methane (CH4, ppm v/v)

• Acetaldehyde (AA, ppm v/v)
12

• Sulfur Dioxide (SO2, ppm v/v)

• Hydrogen Sulfide (H2S ppm v/v)

• Ethanol (ppm v/v) 

VII. Geophysical Monitoring

• Seismic data files (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.

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

Cations:

Al, Ba, Mn, As, Cd, Cr, Cu, Pb, Sb Se, 

and Tl

ICP-MS, 

EPA Method 6020

0.001 to 0.1 mg/L 

(analyte, dilution and matrix dependent)

±15% Daily calibration; blanks, duplicates

and matrix spikes 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

(analyte, dilution and matrix dependent) ±15%

Daily calibration; blanks, duplicates

and matrix spikes at 10% or greater 

frequency

Anions: 

Br, Cl, F, NO3, and SO4

Ion Chromatography,

EPA Method 300.0

0.02 to 0.13 mg/L

(analyte, dilution and matrix dependent) ±15% Daily calibration; blanks and duplicates at 10% or greater frequency

Dissolved CO2

Coulometric titration, 

ASTM D513-11 25 mg/L ±15% Duplicate measurement; standards at10% or greater frequency

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

Water Density(field) Oscillating body method 0.0000 to 2.0000 ±0.0002 g/mL Duplicate measurements

Alkalinity APHA 2320B 4 mg/L ±3 mg/L Duplicate analysis

pH (field) EPA 150.1 2 to 12 pH units ±0.2 pH unit User calibration per manufacturer 

recommendation 

Specific conductance (field) APHA 2510 0 to 200 mS/cm ±1% of reading User calibration per manufacturer 

recommendation 

Temperature (field) Thermocouple -5 to 50°C ±0.2°C Factory calibration

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.

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

Cations:

Al, Ba, Mn, As, Cd, Cr, Cu, Pb, Sb Se, 

and Tl

ICP-MS, 

EPA Method 6020

0.001 to 0.1 mg/L 

(analyte, dilution and matrix dependent)

±15% Daily calibration; blanks, duplicates

and matrix spikes 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

(analyte, dilution and matrix dependent) ±15%

Daily calibration; blanks, duplicates

and matrix spikes at 10% or greater 

frequency

Anions: 

Br, Cl, F, NO3, and SO4

Ion Chromatography,

EPA Method 300.0

0.02 to 0.13 mg/L

(analyte, dilution and matrix dependent) ±15% Daily calibration; blanks and duplicates at 10% or greater frequency

Dissolved CO2

Coulometric titration, 

ASTM D513-11 25 mg/L ±15% Duplicate measurement; standards at10% or greater frequency

Isotopes: δ13C of DIC Isotope ratio mass spectrometry2 12.2 mg/L HCO3

- for δ13C ±0.15‰ for δ13C 10% duplicates; 4 standards/batch

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

Water Density(field) Oscillating body method 0.0000 to 2.0000 ±0.0002 g/mL Duplicate measurements

Alkalinity APHA 2320B 4 mg/L ±3 mg/L Duplicate analysis

pH (field) EPA 150.1 2 to 12 pH units ±0.2 pH unit User calibration per manufacturer 

recommendation

Specific conductance (field) APHA 2510 0 to 200 mS/cm ±1% of reading User calibration per manufacturer 

recommendation 

Temperature (field) Thermocouple -5 to 50°C ±0.2°C Factory calibration

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

Note:2: Gas 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 Accreditation Program. Isotope and dissolved CO2 

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.

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

Cations:

Al, Ba, Mn, As, Cd, Cr, Cu, Pb, Sb Se, 

and Tl

ICP-MS, 

EPA Method 6020

0.001 to 0.1 mg/L 

(analyte, dilution and matrix dependent)

±15% Daily calibration; blanks, duplicates

and matrix spikes 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

(analyte, dilution and matrix dependent) ±15%

Daily calibration; blanks, duplicates

and matrix spikes at 10% or greater 

frequency

Anions: 

Br, Cl, F, NO3, and SO4

Ion Chromatography,

EPA Method 300.0

0.02 to 0.13 mg/L

(analyte, dilution and matrix dependent) ±15% Daily calibration; blanks and duplicates at 10% or greater frequency

Dissolved CO2

Coulometric titration, 

ASTM D513-11 25 mg/L ±15% Duplicate measurement; standards at10% or greater frequency

Isotopes: δ13C of DIC Isotope ratio mass spectrometry2 12.2 mg/L HCO3

- for δ13C ±0.15‰ for δ13C 10% duplicates; 4 standards/batch

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

Water Density(field) Oscillating body method 0.0000 to 2.0000 ±0.0002 g/mL Duplicate measurements

Alkalinity APHA 2320B 4 mg/L ±3 mg/L Duplicate analysis

pH (field) EPA 150.1 2 to 12 pH units ±0.2 pH unit User calibration per manufacturer 

recommendation 

Specific conductance (field) APHA 2510 0 to 200 mS/cm ±1% of reading User calibration per manufacturer 

recommendation

Temperature (field) Thermocouple -5 to 50°C ±0.2°C Factory calibration

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

Note:2: Gas 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.

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

Cations:

Al, Ba, Mn, As, Cd, Cr, Cu, Pb, Sb Se, 

and Tl

ICP-MS, 

EPA Method 6020

0.001 to 0.1 mg/L 

(analyte, dilution and matrix dependent)

±15% Daily calibration; blanks, duplicates

and matrix spikes 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

(analyte, dilution and matrix dependent) ±15%

Daily calibration; blanks, duplicates

and matrix spikes at 10% or greater 

frequency

Anions: 

Br, Cl, F, NO3, and SO4

Ion Chromatography,

EPA Method 300.0

0.02 to 0.13 mg/L

(analyte, dilution and matrix dependent) ±15% Daily calibration; blanks and duplicates at 10% or greater frequency

Dissolved CO2

Coulometric titration, 

ASTM D513-11 25 mg/L ±15% Duplicate measurement; standards at10% or greater frequency

Isotopes: δ13C of DIC Isotope ratio mass spectrometry2 12.2 mg/L HCO3

- for δ13C ±0.15‰ for δ13C 10% duplicates; 4 standards/batch

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

Water Density(field) Oscillating body method 0.0000 to 2.0000 ±0.0002 g/mL Duplicate measurements

Alkalinity APHA 2320B 4 mg/L ±3 mg/L Duplicate analysis

pH (field) EPA 150.1 2 to 12 pH units ±0.2 pH unit User calibration per manufacturer 

recommendation

Specific conductance (field) APHA 2510 0 to 200 mS/cm ±1% of reading User calibration per manufacturer 

recommendation 

Temperature (field) Thermocouple -5 to 50°C ±0.2°C Factory calibration

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

Note:2: Gas evolution technique by Atekwana and Krishnamurthy (1998), with modifications made by Hackley et al. (2007)
17

Table 8. Summary of analytical parameters for CO2 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

CO2 Purity ISBT 2.0 Caustic absorption ZahmNagel 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 analytical parameters for corrosion coupons. 

Parameters Analytical Methods Detection Limit/Range Typical Precisions QC Requirements

Mass NACE RP0775-2005 .005mg +/-2% Annual Calibration of Scale (3rd Party Aldinger

Co. – Cert #664896F)

Thickness NACE RP0775-2005 .001mm +/-005mm Factory calibration

Table 10. Summary of measurement parameters for field gauges.

Parameters Methods Detection Limit/Range Typical Precisions QC Requirements

Booster pump discharge pressure (PIT012)

ANSI Z540-1-1994 +/- 0.001 psi / 0-3000 psi +/- 0.01 psi Annual Calibration of Scale (3rd party)

Injection Tubing Temperature (TIT019)

ANSI Z540-1-1994 +/- 0.001 F / 0-500 F +/- 0.01 F Annual Calibration of Scale (3rd party)

Annulus Pressure (PIT-014) ANSI Z540-1-1994 +/- 0.001 psi / 0-3000 psi +/- 0.01 psi Annual Calibration of Scale (3rd party)

Injection Tubing Pressure (PIT-009) ANSI Z540-1-1994 +/- 0.001 psi / 0-3000 psi +/- 0.01 psi Annual Calibration of Scale (3rd 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 (3rd party)

Westbay Pressures (MOSDAX) UNKNOWN +/0 0.001 psi / 0-4000 PSI +/- 0.01 psi Annual Calibration of Scale (3rd party)
19

Table 11. Actionable testing and monitoring outputs.

Project Action Limit Detection Limit Anticipated Reading

MIT—Pulse 

neutron 

logging

Action taken when RST 

indicates CO2 outside of 

expected range

+/- 0.5 SIGM Brine saturated ~ 60

CO2 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 

gauges 

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: 

>80% 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 CO2 outside the 

AOR

Dependent on fluid 

saturation, and 

formation velocities

CO2 plume migration similar to 

modeled outcome

A.4.b. Precision

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 for sample bottle contamination. Laboratory assessment of 

analytical precision will be the responsibility of the individual laboratories per their standard 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. Bias

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. Representativeness

For groundwater sampling, data representativeness expresses the degree 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 

representative 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. Mass 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%, the sample may be considered non-representative. 
20

A.4.e. Completeness

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 obtained under normal 

conditions. It is anticipated that data 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. Comparability

Data comparability expresses the confidence with which one data set can be compared to another. The 

data sets 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 comparable to previously obtained data. 

A.4.g. Method Sensitivity

Table 14–

Table 19 provide additional details on gauge specifications and sensitivities. 

Table 12. Pressure and temperature—downhole quartz gauge specifications. 

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 Logging 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 determined 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 determined 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 determined 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 determined after first year

Table 18. Mass Flow Rate Field Gauge—FT-006 CO2 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 determined 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. Specialized Training and Certifications

The geophysical survey equipment and wireline 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 

conducted 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 standard 

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 Provider and Responsibility

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 Format and Package Information

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 Project Documents, Records, and Electronic Files

Other documents, records, and electronic files such as well logs, test results, or other data will be 

provided as required by the UIC Program Director.

A.6.c/d. Data Storage and Duration

ADM or a designated contractor will maintain the required project data as provided elsewhere in the 

permit. 

A.6.e. QASP Distribution Responsibility

The 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)

Discussion 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 an extensive set of chemical parameters to establish aqueous 

geochemical reference data. Parameters will include selected constituents that: (1) have primary and 

secondary USEPA drinking water maximum contaminant levels, (2) are the most responsive to 

interaction with CO2 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 CO2 or brine and (2) are 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 establish 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, if statistically significant trends are observed that are the result of 

unintended CO2 or brine migration, the analytical list would be expanded to the full set of monitoring 

parameters. The 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 operator or a third party laboratory. Dissolved CO2 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. Isotopic analysis will be conducted using established methods.

B.1.a. Design Strategy 

CO2 Stream Monitoring Strategy

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 injectate 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, Compensation, 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. 

Calibration of transmitters used to monitor pressures, temperatures, and flow rates of CO2 into the 

injection well at the injection well and at the verification well shall be conducted annually (e.g., Durkin 

Equipment 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 Strategy

Corrosion coupon analyses will be conducted quarterly to aid in ensuring the 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 Groundwater Monitoring Strategy

Four dedicated monitoring wells have been selected for shallow groundwater monitoring. These wells 

have already been installed and screened in the Quaternary-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 CO2 injection well (CCS#2) location. 

Deep Groundwater Monitoring Strategy

Monitoring 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. The Ironton-Galesville Sandstone, has sufficient permeability (over 100 mD) such that

pressure monitoring at the verification wells would detect a failure of the confining 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 the 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 CO2 leakage could be detected if it occurred, and sufficient data will be collected to 

demonstrate that the effects of CO2 injection are limited to the intended storage reservoir. No 

groundwater fluid sampling is planned for the Mt Simon intervals where free phase CO2 has broken 

through. 

GM#2 Sampling

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 technologies. 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 CO2 from the storage 

interval through the seal formation. 

VW#1 Sampling

The IBDP verification well, VW#1, will be used to monitor the pressure and temperature in the IrontonGalesville Sandstone above the Eau Claire Formation, the primary reservoir seal. This well will serve as 

an early leak detection system by allowing the operator to monitor for changes above the primary 

caprock. Groundwater samples 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 CO2 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 Sampling

The IL-ICCS verification well, VW#2, will allow monitoring within the Mt. Simon injection zone as well as 

immediately above the Eau Claire Formation. This well will serve as an early leak detection system by 

allowing the operator to monitor for changes above the primary caprock. VW#2 will be equipped with a 

multilevel 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 and 

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 monitored 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 CO2 from the storage 

interval through the seal formation. 

B.1.b Type and Number of Samples/Test Runs 

Groundwater sampling frequencies are detailed in Table 1. 

CO2 gas stream and corrosion coupon frequencies are detailed in Table 1.

B.1.c. Site/Sampling Locations 

Shallow groundwater monitoring will use existing wells IL-ICCS-MVA 10LG, IL-ICCS-MVA 11LG, IL-ICCSMVA 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.

CO2 gas stream and corrosion coupon sampling locations will occur in the compressor building after the 

last stage of compression.
25

B.1.d. Sampling Site Contingency

The shallow and deep groundwater monitoring wells are located on property of the project participants 

(e.g., ADM, Richland Community College) and access permissions have 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 selected that would still meet permit-related 

conditions.

No problems of site inaccessibility are anticipated for CO2 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 related conditions. 

B.1.e. Activity Schedule 

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

The CO2 gas stream and corrosion coupon sampling activities and frequencies are summarized in Table 

1. 

B.1.f. Critical/Informational Data

During both groundwater sampling and analytical efforts, detailed field and laboratory documentation 

will be taken. Documentation 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 (wellfield 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 digital and printed formats. Noncritical data may include 

appearance and odor of the sample, problems with well or sampling equipment, and weather 

conditions.

B.1.g. Sources of Variability

Potential sources of variability related to 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 activity due to project 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 

during 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 to monitoring activities include (1) 

collecting long-term baseline data to observe and document natural variation in monitoring parameters, 

(2) evaluating data in timely manner after collection to observe anomalies in data that can be addressed 

be resampled or reanalyzed, (3) conducting statistical analysis of monitoring data to determine whether 

variability in a data set is the result of project activities or natural variation, (4) maintaining weatherrelated data using on-site weather monitoring data or data collected near project site (such as from local 

airports), (5) checking instrument calibration before, during and after sampling or sample analysis, (6) 

thoroughly training staff, (7) conducting laboratory quality assurance checks using third party reference 

materials, blind and replicate sample checks, and (8) developing 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/temperature 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 ensure samples are 

representative of formation water quality. Static water levels in each well will be determined using an 

electronic water level 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 dissolved 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 sampling 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 minutes 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 mL of well water (or more if 

required by the filter manufacturer). For alkalinity and total CO2 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, ISGS-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 extensively 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, the 

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 gal. 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 lifting 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 ft 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 Monitoring. 

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

B.2.d. Continuous Monitoring. 

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. These data are informational only. 

B.2.e. Sample Homogenization, Composition, Filtration. 

Described in section B.2.b.

B.2.f. Sample Containers and Volumes

For CO2 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 CO2 Quarterly Gas Analysis: 

• CO2 Purity (% v/v, [GC])

• Oxygen (O2, ppm v/v)

• Nitrogen (N2, ppm v/v)

• Carbon Monoxide (CO, ppm v/v)

• Oxides of Nitrogen (NOx, ppm v/v)

• Total Hydrocarbons (THC, ppm v/v as CH4) 

• Methane (CH4, ppm v/v)

• Acetaldehyde (AA, ppm v/v)

• Sulfur Dioxide (SO2, ppm v/v)

• Hydrogen Sulfide (H2S ppm v/v)

• Ethanol (ppm v/v)

For shallow and deep groundwater samples, all sample bottles will be new. Sample 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 Preservation 

For groundwater and other aqueous samples, the preservation methods in Table 22 will be used.

No preservation is required or used for CO2 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 CO2 gas stream analysis. 

Target Parameters Volume/Container 

Material

Preservation 

Technique

Sample Holding time 

(max)

CO2 gas stream (2) 2L MLB Polybags

(1) 75 cc Mini 

Cylinder

Sample Storage 

Cabinets 5 Business Days

B.2.h. Cleaning/Decontamination of Sampling Equipment

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 cleaned 

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 holders, 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. 

CO2 gas stream sampling containers will be either disposed or decontaminated by the analytical lab. 

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 valves required to sample the CO2 gas stream will be supplied by the 

analytical lab providing the sampling containers. Sampling will occur within the existing CO2 compression 

building.

Similarly, corrosion coupons will be removed from the CO2 injection line within the existing CO2

compression 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 field 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 approximately 

4°C until analysis. The samples 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 description 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 groundwater sampling 

personnel.

An analysis authorization form shall be provided with each CO2 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 (freshwater or brine), analyte, volume, 

filtration used (if any), and preservative used (if any). See Figure 3 for an example of a label. 
30

Table 22. Summary of anticipated sample containers, preservation treatments, and holding times.

Target Parameters 

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 CO2 2 × 60 ml/HDPE Filtered, cool 4°C 14 days Shallow

Dissolved CO2 60 ml/HDPE Filtered, cool 4°C 14 days Deep

Isotopes: 3H, δD, δ18O, δ34S, 

and δ13C 

2 × 60 ml/HDPE Filtered, cool 4°C 4 weeks Shallow

Isotopes: δ34S 250 ml/HDPE Filtered, cool 4°C 4 weeks Deep

Isotopes: δD, δ18O, δ13C 60 ml/HDPE Filtered, cool 4°C 4 weeks Deep

Alkalinity, anions (Br, Cl, F, 

NO3, SO4) 500 ml/HDPE Filtered, cool 4°C 45 days Shallow

Field Confirmation: 

Temperature, dissolved 

oxygen, specific conductance, 

pH

200 ml/glass jar None < 1 hour Deep

Field Confirmation: Density 60 ml/HDPE Filtered < 1 hour Deep
31

IL-ICCS_10LG_20A (fresh water)

01-23-2014

Metals, 60 ml, filtered, HNO3

Figure 3. Example label for groundwater sample bottles.

B.3.e. Sample Chain-of-Custody 

For CO2 stream analysis, an analysis authorization form (Figure 4) will accompany the sample to the 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 shown 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

Analytical 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

Nonstandard 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 appropriately 

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 methods are not anticipated for this project. If nonstandard 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 CO2 gas stream analysis authorization form.
34

Figure 5. Example chain-of-custody form. 
35

B.5. Quality Control

Geophysical 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 field 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. Duplicate samples are 

used to assess sample heterogeneity and analytical precision.

B.5.b. Exceeding Control Limits

If the sample analytical results exceed control limits (i.e., ion balances > ±10%), 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 Applicable QC Statistics

Charge Balance

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: 

% difference = 100 ∑ cations−∑ anions

∑ cations+∑ anions , (Equation 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, (Equation 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 selection 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 another 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 omitted. 

B.7.a. Calibration and Frequency of Calibration

Pressure/temperature gauge calibration information is located in Table 12-Table 19. Logging tool 

calibration will be at the discretion of the service company providing 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 

parameters (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 Methodology

Logging tool calibration methodology will follow standard industry practices in Appendix B.

For groundwater sampling, standards used for calibration are typically 7 and 10 for 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 O2 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 CO2/L) are 

routinely analyzed to evaluate instrument. 

B.7.c. Calibration Resolution and Documentation

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 parameters 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 activity. 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. Nondirect Measurements

Seismic Monitoring Methods

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 monitor 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 Project

Time lapse seismic surveys will be used to track changes in the CO2 plume in the subsurface. 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 CO2 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 stage within the AOR.

B.9.c. Acceptance Criteria

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, 

functional 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 

gain.

B.9.d. Resources/Facilities 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 OperatingCconditions

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 Management Scheme

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 Practices

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

B.10.c. Data Handling Equipment/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 Retrieval

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 Configurations

All ADM and vendor hardware and software configurations will be appropriately interfaced.

B.10.g. Checklists and Forms

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 Conducted

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

groundwater 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. Corrective Action

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 

monitoring 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 Reports

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 Accepting, Rejecting, or Qualifying Data

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 spreadsheet with periodic data review and analysis. ADM will 

retain copies 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, data 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 CO2 or brine seepage beyond the intended storage reservoir.
40

D.2. Verification and Validation Methods

D.2.a. Data Verification and Validation Processes

See sections D.1.a. and B.5. 

Appropriate statistical software will be used to determine data consistency. 

D.2.b. Data Verification and Validation Responsibility

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

D.2.c. Issue Resolution Process and Responsibility

ADM or its designated Coordinator will overview the groundwater data handling, management, and 

assessment process. Staff involved in these processes will consult with the Coordinator to determine 

actions required to resolve issues.

D.2.d. Checklist, Forms, and Calculations

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 criteria 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 13.60 -2.84 pass 760.50 785 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 14.90 1.96 pass 780.95 785 1.0 pass

D.3. Reconciliation with User Requirements

D.3.a. Evaluation of Data 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 (21st edition), American 

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, Method 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 groundwater 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 Drive, 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 

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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