Emergency and Remedial Response Plan for FutureGen Alliance 

Permit Number: IL-137-6A-0003 (Well #3) Page F1 of 28

ATTACHMENT F: EMERGENCY AND REMEDIAL RESPONSE PLAN 

Facility Name: FutureGen 2.0 Morgan County CO2 Storage Site 

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

Facility Contacts: Kenneth Humphreys, Chief Executive Officer, 

FutureGen Industrial Alliance, Inc., Morgan County Office, 

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

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

This Emergency and Remedial Response Plan (ERRP) describes actions the permittee (the 

FutureGen Alliance) will take at the FutureGen 2.0 Morgan County CO2 storage site in the 

unlikely event of an emergency that could endanger any underground source of drinking water 

(USDW) within the project Area of Review (AoR) during construction, operation or postinjection site care. Such events may include unplanned CO2 release or detection of unexpected 

movement of CO2 or associated fluids in or from the injection zone. This plan demonstrates how 

the FutureGen Alliance will comply with 40 CFR 146.94. 

If information from the FutureGen 2.0 monitoring network (described in the Testing and 

Monitoring Plan) indicates that injected CO2 and/or associated fluid migration or pressures have 

occurred which could endanger a USDW, the FutureGen Alliance will take the following 

actions: 

1. Cease injection according to the procedures in the Class VI permit and close down the 

injection wells. 

2. Perform appropriate steps to identify and characterize the source and cause of the 

adverse incident that has the potential to endanger a USDW or release CO2. 

3. Notify the U.S. Environmental Protection Agency (EPA) Underground Injection 

Control (UIC) Program Director of the adverse incident within 24 hours. 

4. Implement necessary remedial actions, including those outlined in this Emergency 

Response and Remediation Plan 

Part 1: Resources or Infrastructure Potentially Affected

Four USDW aquifer zones are located in the AoR, ranging from the deep St. Peter Sandstone 

(approximately 2,000 ft above the top of the injection zone) to the surficial aquifer system 

approximately 3,700 ft above the injection zone. The surficial aquifer system is a significant 

groundwater resource within the AoR. Response actions to CO2 or saline migration into a 

USDW would vary according to the aquifer. It should be noted that the leak would be detected 

and response actions would be conducted in the lowermost USDW—St. Peter Sandstone—far in 

advance before shallower USDWs would be affected unless a leak were to occur along an 

injection well or deep monitoring well. 

The land is used primarily for agriculture. Residences and farm-related buildings are scattered 

across the land surface, particularly along roads. Surface-water features such as creeks, streams, 
Emergency and Remedial Response Plan for FutureGen Alliance 

Permit Number: IL-137-6A-0003 (Well #3) Page F2 of 28

and impoundments formed by small earthen dams are also present in the area. Limited stretches 

of woodland parallel stretches of streams. Most of the land surface is farmland. Shallow (<100ft 

bgs) groundwater-supply wells are associated with residences. The injection site will eventually 

have a pipeline and some small buildings. Figure 1 shows the surface water features within the 

AoR for this project. Figure 2 shows additional surface features in the survey area. 

Figure 1. Map of Surface-Water Features within the Area of Review.
Emergency and Remedial Response Plan for FutureGen Alliance 

Permit Number: IL-137-6A-0003 (Well #3) Page F3 of 28

Figure 2. Map of Survey Area including Residences, Water Wells, and Surface-Water Features above the 

predicted extent of the CO2 plume after 22 years. 
Emergency and Remedial Response Plan for FutureGen Alliance 

Permit Number: IL-137-6A-0003 (Well #3) Page F4 of 28

Part 2: Identification of Adverse Incidents 

The possible adverse incident scenarios identified in Table 1 consist of both slow and sudden 

releases of CO2 or brine. Such releases will result in the implementation of emergency or 

remedial actions as described in Part 3 (of this plan). It should be noted that the worst-case 

consequences of various scenarios are developed to ensure that response plans are in place for all 

eventualities. 

Table 1 lists the types of potential adverse incidents that will trigger response actions to protect 

USDWs if the incidents occur during the construction, injection, and post-injection site-care 

periods. The activities that the FutureGen Alliance will undertake in response to these incidents 

are described in Part 3 (of this plan). 

Table 1. Potential Adverse Incidents

Construction Period

• Over-pressurized natural gas (blow out)

• Movement of brine between formations during drilling

Injection Period

• Loss of mechanical integrity (injection or monitoring wells)

• Rapid and/or unexpected movement of CO2 outside defined AoR

• Migration of CO2 from injection zone through faults and fractures

• Migration of CO2 from injection zone through undocumented wells

• Migration of CO2 from injection zone through failure of the confining zone (loss of containment)

• Monitoring equipment failure or malfunction

• Movement of brine or CO2 from injection zone to overlying USDW

• Natural disaster (such as severe weather)

• Seismic event

Post-Injection Site-Care Period

• Loss of mechanical integrity (monitoring wells)

• Rapid and/or unexpected movement of CO2 outside defined AoR

• Migration of CO2 from injection zone through faults and fractures

• Migration of CO2 from injection zone through undocumented wells

• Migration of CO2 from injection zone through failure of the confining zone (loss of containment)

• Monitoring equipment failure or malfunction

• Movement of brine or CO2 from injection zone to overlying USDW

• Natural disaster (such as severe weather)

• Seismic event
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Permit Number: IL-137-6A-0003 (Well #3) Page F5 of 28

Remedial response actions implemented at the FutureGen 2.0 site will be proportional to the 

severity of the condition triggering the emergency actions. The severity of the emergency 

condition are categorized as major, serious, or minor as defined in Table 2. 

Table 2. Definition of the Severity of Adverse Incidents

Consequence Degree of Severity Definition

HIGH (Major Emergency)

Known release or indication of a potential incident which poses an 

immediate (acute) risk to human health, resources, or 

infrastructure. Response actions involving local authorities 

(evacuation, isolation of areas, or restrictions on water usage) 

should be initiated. Example:well blowout during injection.

MEDIUM (Serious Emergency)

Incidents/releases posing potential (chronic) risk to human health, 

resources, or infrastructure if conditions worsen or no 

(mitigative/remedial) response actions are taken. Examples: well 

seal failures, detection of increased pressure or indicators of CO2 in 

zones above caprock.

LOW (Minor Emergency)

Incident poses a challenge to confinement barrier but does not 

result in the immediate release of CO2 or brine posing a risk to 

human health, resources or infrastructure. Example: higher than 

anticipated pressure in monitoring wells.

Part 3: Emergency Identification and Response Actions to Protect USDWs 

This arrangement of responses is conceptual; the severity of an adverse incident will determine 

the actual response(s) deployed and will be executed following notification of, and in 

consultation with, the UIC Program Director. If any adverse incident has the potential to 

endanger a USDW, the FutureGen Alliance will notify the UIC Program Director within 24 

hours. After the implementation of actions taken to address the emergency, the FutureGen 

Alliance will demonstrate the efficacy of the remedial response actions to the satisfaction of the 

UIC Program Director before resuming injection operations. Injection operations will resume 

when authorized by the UIC Program Director after having established that all requirements have 

been met. 

Where the phrase “initiate shutdown plan” is used, the following protocol will be employed: the 

FutureGen Alliance will immediately cease injection and will notify the power plant that it is not 

currently injecting CO2. 

If an adverse incident occurs, the FutureGen Alliance will deploy a variety of emergency or 

remedial responses depending on the circumstances (e.g., the location, type, and volume of a 

release) to protect USDWs. Any unanticipated incident or condition observed to pose a threat to 

groundwater, surface water, infrastructure, or people will be treated as an adverse incident 

(“emergency”). Response actions will depend upon the severity of the adverse incident, as 

defined in Table 2. This part of the ERRP summarize the types of adverse incidents that could 

occur and the likely sequence of responses that would be undertaken to protect USDWs during 

construction, injection, and post-injection site care. Emergency and remedial responses will be 

considered in a sequence of progressively more extensive actions corresponding to the degree of 

severity. The list for each adverse incident is ordered accordingly.
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Permit Number: IL-137-6A-0003 (Well #3) Page F6 of 28

ADVERSE INCIDENTS POTENTIALLY AFFECTING USDWS: CONSTRUCTION 

PERIOD 

Event/Description: Over-pressurized fluid (blowout): This event could occur during well 

drilling, if a pocket of high pressure gas or fluid is encountered resulting in a sudden release. 

Severity: High

Time of Event: Drilling

Avoidance Measures: Care in drilling; use and maintain blow out preventer at wellhead; 

control drilling fluid density.

Detection Methods: Well pressure, annulus pressure monitoring. Drilling fluid (mud) return 

flow and density, pressure.

Potential Response Actions: Specific response will depend on the type of well (injection or 

monitoring). In general, the following will be undertaken: 

• Stop drilling. 

• Notify the UIC Program Director within 24 hours of the incident, per 40 CFR 

146.91(c)(3). 

• Verify proper and complete operation of blowout preventer hardware. 

• Inject heavy fluid to regain hydrostatic control. 

• Close flow valve (wellhead). 

• Check the drilling and mud logs in an attempt to identify cause. 

• See Part 3.1 for details on further response. 

Response Personnel: Drilling crew, supervising professionals, geotechnical subcontractors.

Equipment: Existing or newly mobilized drill rig, logging equipment, cement or casing as 

required. 

Event/Description: Movement of brine between formations: As a well is drilled, multiple 

concentric strings of casing are installed and cemented. If the cement seal with the outer annulus 

or inner annuli failed, there will be a pathway for cross contamination of formations, including 

USDWs. 

Severity: Medium

Time of Event: Construction/drilling

Avoidance Measures: Care in well construction particularly with respect to cement placement.

Detection Methods: Monitoring of drilling column pressure, well pressure, annulus pressure, 

drilling fluid (mud) return flow, and density pressure.
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Potential Response Actions: Specific response will be dependent on the type of well (injection 

or monitoring). In general, the following will be undertaken: 

• Stop drilling. 

• Notify the UIC Program Director within 24 hours of the incident, per 40 CFR 

146.91(c)(3). 

• Seal off leaking formation by setting packer. 

• Check the monitoring record in an attempt to identify cause. 

• Run well logging tools to locate source of cross contamination. 

• Identify and implement corrective actions, such as grout injection to seal off zone, redrill.

Response Personnel: Drilling crew, supervising professionals, geotechnical subcontractors.

Equipment: Existing or newly mobilized drill rig, logging equipment, cement, or casing as 

required.
Emergency and Remedial Response Plan for FutureGen Alliance 

Permit Number: IL-137-6A-0003 (Well #3) Page F8 of 28

ADVERSE INCIDENTS POTENTIALLY AFFECTING USDWS: INJECTION PERIOD 

Event/Description: Loss of Mechanical Integrity: If the cement behind casing or inner annuli 

failed, there could be a pathway for cross contamination of formations, including USDWs. 

During injection, CO2 could travel through geologic formations above the injection and 

confining zones into a USDW. 

Severity: Medium 

Time of Event: Operations/injection 

Avoidance Measures: Care in well construction particularly with respect to cement placement, 

including use of casing centralizers.

Detection Methods: Well pressure, annulus pressure, gas flow rate monitoring; well annulus 

pressure maintenance and monitoring system; continuous monitoring of injection mass flow rate, 

pressure, temperature, annular pressure, and fluid volume; oxygen-activation tracer logging; 

noise logging; temperature logging; pressure fall-off testing. See the Testing and Monitoring 

Plan for specific information. 

Potential Response Actions: Specific response will depend on the type of well (injection or 

monitoring). In general, the following will be undertaken: 

• Initiate shutdown plan. 

• Notify the UIC Program Director within 24 hours of the incident, per 

40 CFR 146.91(c)(3). 

• Close flow valve (wellhead). 

• Check the monitoring record in an attempt to identify cause. 

For Major or Serious Emergency 

• Monitor well pressure, temperature, annulus pressure. 

• Log hole; check casing and borehole condition. 

• Determine cause and extent of failure. 

• Grout or install chemical sealant barrier in an adjoining well to block leak. 

• Abandon well by completely closing it (seal with cement). 

• Drill new well if necessary. 

• Identify and implement appropriate remedial actions to repair damage to the well (in 

consultation with the UIC Program Director). 

• If contamination is detected, conduct groundwater remediation as required (in 

consultation with the UIC Program Director). 

For Minor Emergency 

• Reset automatic shutdown devices. 

• Monitor well pressure, temperature, annulus pressure. 

• Verify integrity loss and determine cause and extent of failure. 

• Identify and implement corrective actions. 

• See Part 3.1 for details on further response. 

Response Personnel: Drilling crew, supervising professionals, geotechnical subcontractors. 

Equipment: Existing or newly mobilized drill rig, logging equipment, cement or casing as 

required. 
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Event/Description: Migration of CO2 from injection zone through faults and fractures: 

This event could occur as a result of CO2 migrating through existing, unknown faults or fractures 

or new, seismically induced faults or fractures. 

Severity: Medium

Time of Event: Operations/injection

Avoidance Measures: Extensive geophysical characterization has not identified faults or 

fractures.

Detection Methods: Early leak-detection monitoring in Above Confining Zone (ACZ) well; 

USDW aquifer monitoring in USDW well. See the Testing and Monitoring Plan for specific 

information. 

Potential Response Actions: 

• Initiate shutdown plan.

• Notify the UIC Program Director within 24 hours, per 40 CFR 146.91(c)(3) 

• Assess cause by reviewing monitoring data. 

• Conduct geophysical survey in an attempt to locate leaks. 

• If warranted, resume injection, but reduce injection pressure by reducing flow rate or 

inject through additional injection wells. 

• Intensify monitoring to determine whether migration continues with continued injection. 

• Lower reservoir pressure by removing liquids (water, brine, etc.) from the storage 

reservoir. 

• Intersect the migration with extraction wells in the vicinity of the leak, withdraw and reinject. 

• Lower the reservoir pressure by promoting new pathways to access new volumes or strata 

in the storage reservoir. 

• Create a hydraulic barrier by increasing reservoir pressure upstream of the leak. 

• Inject grout or chemical sealant to block the leak. 

• If contamination is detected, identify and implement appropriate remedial actions (in 

consultation with the UIC Program Director). 

• See Part 3.2 for details on further response. 

Response Personnel: Onsite operating staff, supervising professionals, geophysical consultants.

Equipment: Newly mobilized drill rig, geophysics monitoring trucks.

Event/Description: Migration of CO2 from injection zone through undocumented wells: 

This event could occur as a result of undocumented wells serving as artificial conduits for fluid 

migration. 

Severity: Medium to high depending upon location

Time of Event: Operations/injection

Avoidance Measures: Drilling records reviews and site walkthroughs were conducted. Only 

three wells were identified and none penetrate the confining zone.
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Detection Methods: Early leak-detection monitoring in ACZ well; evidence of gas/water 

venting at or near the surface proximate to the undocumented well; USDW aquifer monitoring in 

USDW well. See the Testing and Monitoring Plan for specific information. 

Potential Response Actions: 

• Initiate shutdown plan. 

• Notify the UIC Program Director within 24 hours of the incident, per 

40 CFR 146.91(c)(3). 

• Assess the cause by reviewing monitoring data. 

• Conduct a geophysical survey in an attempt to locate migration. 

• Repair leaking wells by re-plugging with cement. 

• Plug and abandon wells that cannot be repaired. 

• Create a hydraulic barrier by increasing reservoir pressure upstream of the leak. 

• Install chemical sealant or grout barriers to block leaks. 

• If contamination is detected, identify and implement appropriate remedial actions 

(in consultation with the UIC Program Director). 

• See Part 3.2 for details on further response. 

Response Personnel: Drilling crew, supervising professionals, geotechnical subcontractors. 

Equipment: Newly mobilized drill rig, logging equipment, cement or casing as required. 

Event/Description: Migration of CO2 from injection zone through failure of the confining 

zone (loss of containment): This event could occur as a result of CO2 migrating through a 

compromised confining zone. 

Severity: Medium

Time of Event: Operations/injection

Avoidance Measures: Careful monitoring and control of injection flow and pressure with 

periodic monitoring well sampling.

Detection Methods: Early leak-detection monitoring in ACZ well. See the Testing and 

Monitoring Plan for specific information. 

Potential Response Actions: 

• Initiate shutdown plan. 

• Notify the UIC Program Director within 24 hours of the incident, per 

40 CFR 146.91(c)(3). 

• Verify integrity of well bore. 

• Proceed to response for migration of CO2 through loss of mechanical integrity, through 

faults or fractures, or through undocumented abandoned wells according to location of 

migration and conduct groundwater remediation as required. 

• See Part 3.2 for details on further response. 

Response Personnel: Onsite operating staff, supervising professionals, geophysical consultants.

Equipment: Newly mobilized drill rig, geophysics monitoring trucks.
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Permit Number: IL-137-6A-0003 (Well #3) Page F11 of 28

Event/Description: Monitoring well equipment malfunction: Failure or malfunction of well 

instrumentation that monitors wellhead pressure, temperature, or annulus pressure could result in 

false readings. In this event, the reservoir could become over-pressurized, possibly resulting in 

fractures in the confining zone. 

Severity: Low; Possibly Medium if injection is not stopped and results in overpressurization

Time of Event: Operations/ injection

Avoidance Measures: Preventive maintenance of equipment.

Detection Methods: Pressure fall-off testing; monitoring of well pressure, temperature, specific 

conductivity. See the Testing and Monitoring Plan for specific information.

Potential Response Actions: 

• Notify the UIC Program Director within 24 hours of the incident, per 

40 CFR 146.91(c)(3). 

• Repair monitoring instrumentation 

• If repairs cannot be made within hours, then: 

‒ Initiate shutdown plan. 

‒ Repair or replace instrumentation. 

‒ Review monitoring records. 

‒ Perform reservoir injection tests to determine whether and where fracturing has 

occurred. 

‒ Completely close the well (seal with cement). 

‒ Drill new well if necessary. 

‒ Conduct groundwater remediation as required (in consultation with the UIC Program 

Director). 

• See Part 3.6 for details on further response. 

Response Personnel: Drilling crew, supervising professionals, geotechnical and instrument 

subcontractors.

Equipment: Newly mobilized drill rig and/or instrument repair truck.

Event/Description: Movement of brine from injection zone: This event could occur as a result 

of CO2 migration along existing unknown faults or fractures, seismically induced faults or 

fractures, or failure of the confining zone (loss of containment). 

Severity: Medium

Time of Event: Operations/injection

Avoidance Measures: Careful monitoring and control of injection flow and pressure with 

periodic monitoring well sampling. 

Detection Methods: Early leak-detection monitoring in ACZ well; USDW aquifer monitoring in 

USDW well. See the Testing and Monitoring Plan for specific information. 

Potential Response Actions: 

• Initiate shutdown plan.
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• Notify the UIC Program Director within 24 hours of the incident, per 40 CFR 

146.91(c)(3).

• Assess cause by reviewing monitoring data. 

• Proceed to response for migration of CO2 from injection zone through faults or fractures 

according to location of migration and conduct groundwater remediation as required. 

• See Part 3.3 for details on further response. 

Response Personnel: Onsite operating staff, supervising professionals, geophysical consultants. 

Equipment: Newly mobilized drill rig, geophysics monitoring trucks.

Event/Description: Seismic event: If a seismic event were to occur inducing movement along 

faults or fractures, well leakage could occur. 

Severity: Low to Medium depending upon quake magnitude and location

Time of Event: Operations/injection

Avoidance Measures: The site is located in a seismically stable region. 

Detection Methods: Passive seismic monitoring (microseismicity). See the Testing and 

Monitoring Plan for specific information. 

Potential Response Actions: 

• Initiate shutdown plan to stabilize reservoir system. 

• Notify the UIC Program Director within 24 hours of the incident, per 40 CFR 

146.91(c)(3). 

• Evaluate integrity of storage volume by gas pressure response and monitoring 

instrumentation. 

• If a leak is detected, conduct a geophysical survey to locate new fracture zone. 

• If warranted, resume injection but reduce injection pressure by reducing flow rate or 

inject through additional injection wells. 

• Intensify monitoring to determine whether migration is continuing with continued 

injection. 

• Lower reservoir pressure by removing liquids (water, brine, etc.) from the storage 

reservoir. 

• Intersect the migration with extraction wells in the vicinity of the leak, withdraw, and reinject. 

• Lower the reservoir pressure by promoting new pathways to access new volumes or strata 

in the storage reservoir. 

• Create a hydraulic barrier by increasing reservoir pressure upstream of the leak. 

• Inject grout or chemical sealant to block leak. 

• Extract CO2 from reservoir, and re-inject in more suitable location. 

• If contamination is detected, identify and implement appropriate remedial actions (in 

consultation with the UIC Program Director). 

• Investigate the cause of the seismic event. 

− If the event was induced as a result of injection activities, determine whether any 

operational changes are needed to reduce the likelihood or magnitude of future 

events. 
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− Communicate the investigation and findings to the public (see Part 5). 

• See Part 3.4 for details on further response. 

Response Personnel: Onsite operations staff, drilling crew, supervising professionals, 

geotechnical contractors, mechanical contractors, as required. 

Equipment: Newly mobilized drill rig, logging equipment, cement or casing, as required.

Event/Description: Groundwater/USDW contamination: If there were a failure of the 

confining zone, failure of the injection or monitoring well, or if the plume encounters an 

undocumented AoR well, CO2 or brine could reach groundwater, requiring remediation. 

Severity: Medium to High depending upon location

Time of Event: Operations/injection

Avoidance Measures: The entire CO2 injection project is focused on preventing escape of CO2

while sequestering the CO2. The FutureGen oxy-combustion process incorporates gas-cleaning 

processes to remove at least 97% of contaminants, including mercury, prior to injection. Trace 

contaminants that might be entrained in CO2 leaking into USDWs will pose inconsequential risk 

to the water quality. 

Detection Methods: USDW aquifer monitoring in USDW well. See the Testing and Monitoring 

Plan for specific information.

Potential Response Actions: 

• Initiate shutdown plan. 

• Notify the UIC Program Director within 24 hours of the incident, per 40 CFR 

146.91(c)(3).

• Assess cause by reviewing monitoring data. 

• Conduct a geophysical survey in an attempt to locate migration. 

• Identify and implement appropriate remedial actions (in consultation with the UIC 

Program Director). If the leak cannot be located or while pursuing corrective measures 

for the leak, the following remedies may be considered: 

− Drill wells to intersect accumulations in groundwater, preferably near CO2 aquifer 

entrance zones. 

− Extract groundwater contaminated with gaseous or dissolved CO2 water and treat ex 

situ. 

− Dissolve mineralized CO2 (carbonates) in water and extract as a dissolved phase 

through an extraction well for ex situ air stripping. 

− Extract groundwater with metals mobilized by CO2 and treat ex situ to remove metals 

and residual CO2. 

− Use hydraulic barriers to immobilize and contain contaminants by deploying injection 

and extraction wells. 

− Deploy in situ chemical or biological treatment technologies to enhance biochemical 

degradation or stabilization of CO2 -related contaminants. 

− Create a hydraulic barrier by increasing reservoir pressure upstream of a leak. 

− Place grouts or chemical sealant barriers to block leaks. 
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− Discontinue injection. 

− Provide individual water-treatment systems for each water-supply well user. The 

configuration for each ex situ treatment system will be determined by water 

chemistry. Applicable treatment technologies include but are not limited to aeration, 

pH adjustment, ion exchange, oxidizing filter (manganese greensand), membrane 

filtration, etc.). 

• See Parts 3.2 and 3.3 for details on further response. 

Response Personnel: Drilling crew, supervising professionals, geotechnical subcontractors, 

environmental or water-treatment contractors.

Equipment: Water-treatment equipment, new wellhead plumbing to and from water-treatment 

equipment, reagents for optional in situ treatment, newly mobilized drill rig, logging equipment, 

cement or casing, as required. 
Emergency and Remedial Response Plan for FutureGen Alliance 

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ADVERSE INCIDENTS POTENTIALLY AFFECTING USDWS: POST-INJECTION 

SITE-CARE PERIOD

Event/Description: Loss of mechanical integrity (monitoring wells): During the postinjection period, CO2 could travel through a compromised monitoring well into a USDW. 

Severity: Medium

Time of Event: Post-injection site care

Avoidance Measures: Care in well construction particularly with respect to cement placement.

Detection Methods: Monitoring of well pressure, temperature, specific conductivity. See the 

Testing and Monitoring Plan for specific information. 

Potential Response Actions: 

In general, the following will be undertaken: 

• Notify the UIC Program Director within 24 hours, per 40 CFR 146.91(c)(3). 

• Check the monitoring record in an attempt to identify cause. 

• Log hole; check casing and borehole condition. 

• Repair annulus seal or replace casing. 

• Grout or install chemical sealant barrier in an adjoining well to block leak. 

• Abandon well by completely closing it (seal with cement). 

• Drill new well if necessary. 

• Investigate whether USDW contamination occurred. 

• If contamination is detected, identify and implement appropriate remedial actions (in 

consultation with the UIC Program Director). 

• See Part 3.2 for details on further response. 

Response Personnel: Drilling crew, supervising professionals, geotechnical subcontractors.

Equipment: Existing or newly mobilized drill rig, logging equipment, cement or casing as 

required.

Event/Description: Migration of CO2 from injection zone through faults and fractures: 

This event could occur as a result of CO2 migrating through existing, unknown faults or fractures 

or new, seismically induced faults or fractures. 

Severity: Medium

Time of Event: Post-injection site care

Avoidance Measures: Extensive geophysical characterization has not identified faults or 

fractures.

Detection Methods: Early leak-detection monitoring in ACZ well; USDW aquifer monitoring in 

USDW well. See the Testing and Monitoring Plan for specific information. 

Potential Response Actions: 
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• Notify the UIC Program Director within 24 hours of the incident, per 40 CFR 

146.91(c)(3).

• Assess cause by reviewing monitoring data. 

• Conduct geophysical survey in an attempt to locate leaks. 

• Intensify monitoring to determine whether migration continues. 

• Lower reservoir pressure by removing liquids (water, brine, etc.) from the storage 

reservoir. 

• Intersect the migration with extraction wells in the vicinity of the leak, withdraw and reinject. 

• Lower the reservoir pressure by promoting new pathways to access new volumes or strata 

in the storage reservoir. 

• Create a hydraulic barrier by increasing reservoir pressure upstream of the leak. 

• Inject grout or chemical sealant to block the leak. 

• Extract CO2 from the reservoir, and re-inject in a more suitable location. 

• If contamination is detected, identify and implement appropriate remedial actions (in 

consultation with the UIC Program Director). 

• See Parts 3.2 and 3.3 for details on further response. 

Response Personnel: Onsite operating staff, supervising professionals, geophysical consultants. 

Equipment: Newly mobilized drill rig, geophysics monitoring trucks. 

Event/Description: Migration of CO2 from injection zone through undocumented wells:

This event could occur as a result of undocumented wells serving as artificial conduits for fluid 

migration. 

Severity: Medium to High depending on location.

Time of Event: Post-injection site care 

Avoidance Measures: Drilling records and site walkthroughs were conducted. Only three wells 

were identified and none penetrate the confining zone. 

Detection Methods: Early leak-detection monitoring in ACZ well; USDW aquifer monitoring in 

USDW well. See the Testing and Monitoring Plan for specific information. 

Potential Response Actions: 

• Notify the UIC Program Director within 24 hours of the incident, per 40 CFR 

146.91(c)(3). 

• Assess the cause by reviewing monitoring data. 

• Conduct a geophysical survey in an attempt to locate migration. 

• Locate undocumented well(s). 

• Repair leaking wells by re-plugging with cement. 

• Repair leaking undocumented functional wells with well-recompletion techniques such as 

replacing casing and packers or re-cementing annular spaces. 

• Plug and abandon wells that cannot be repaired. 

• Create a hydraulic barrier by increasing reservoir pressure upstream of the leak. 

• Install chemical sealant or grout barriers to block leaks. 
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• Identify and implement appropriate remedial actions (in consultation with the UIC 

Program Director). 

• See Part 3.2 for details on further response. 

Response Personnel: Drilling crew, supervising professionals, geotechnical subcontractors.

Equipment: Newly mobilized drill rig, logging equipment, cement or casing as required.

Event/Description: Migration of CO2 from injection zone through failure of the confining 

zone (loss of containment): This event could occur as a result of CO2 migrating through a 

compromised confining zone. 

Severity: Medium

Time of Event: Post-injection site care 

Avoidance Measures: Careful monitoring of pressure with periodic monitoring well sampling. 

Detection Methods: Early leak-detection monitoring in ACZ well. See the Testing and 

Monitoring Plan for specific information. 

Potential Response Actions: 

• Notify the UIC Program Director within 24 hours of the incident, per 40 CFR 

146.91(c)(3). 

• Verify integrity of well bore. 

• Proceed to response for migration of CO2 through well bore, through faults or fractures, 

or through undocumented abandoned wells according to location of migration and 

conduct groundwater remediation as required. 

• See Part 3.2 for details on further response. 

Response Personnel: Onsite operating staff, supervising professionals, geophysical consultants.

Equipment: Newly mobilized drill rig, geophysics monitoring trucks.

Event/Description: Monitoring well equipment malfunction: Failure or malfunction of well 

instrumentation that monitors wellhead pressure, temperature, or annulus pressure could result in 

false readings. In this event, the reservoir could become over-pressurized, possibly resulting in 

fractures in the confining zone. 

Severity: Low; Possibly Medium if injection is not stopped and results in overpressurization

Time of Event: Post-injection site care

Avoidance Measures: Preventive maintenance of equipment.

Detection Methods: Pressure fall-off testing; monitoring of well pressure, temperature, specific 

conductivity. See the Testing and Monitoring Plan for specific information.

Potential Response Actions: 

• Notify the UIC Program Director within 24 hours of the incident, per 

40 CFR 146.91(c)(3). 
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• Repair monitoring instrumentation 

• If repairs cannot be made within hours, then: 

‒ Initiate shutdown plan. 

‒ Repair or replace instrumentation. 

‒ Review monitoring records. 

‒ Perform reservoir injection tests to determine whether and where fracturing has 

occurred. 

‒ Completely close the well (seal with cement). 

‒ Drill new well if necessary. 

‒ Conduct groundwater remediation as required (in consultation with the UIC Program 

Director). 

• See Part 3.6 for details on further response. 

Response Personnel: Drilling crew, supervising professionals, geotechnical and instrument 

subcontractors.

Equipment: Newly mobilized drill rig and/or instrument repair truck.

Event/Description: Movement of brine from injection zone: This event could occur as a result 

of CO2 migration along existing unknown faults or fractures, seismically induced faults or 

fractures, or failure of the confining zone (loss of containment). 

Severity: Medium

Time of Event: Post-injection site care 

Avoidance Measures: Careful monitoring of injected CO2 pressure and distribution with 

periodic monitoring well sampling. 

Detection Methods: Early leak-detection monitoring in ACZ well; USDW aquifer monitoring in 

USDW well. See the Testing and Monitoring Plan for specific information. 

Potential Response Actions: 

• Notify the UIC Program Director within 24 hours of the incident, per 40 CFR 

146.91(c)(3). 

• Assess cause by reviewing monitoring data. 

• Proceed to response for migration of CO2 from injection zone through faults or fractures 

according to location of migration and conduct groundwater remediation as required. 

• See Part 3.2 for details on further response. 

Response Personnel: Onsite operating staff, supervising professionals, geophysical consultants.

Equipment: Newly mobilized drill rig, geophysics monitoring trucks. 

Event/Description: Seismic event: If a seismic event were to occur inducing movement along 

faults or fractures, well leakage could occur. 

Severity: Low to Medium depending upon quake magnitude and location

Time of Event: Post-injection site care 
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Avoidance Measures: The site is located in a seismically stable region. 

Detection Methods: Passive seismic monitoring (microseismicity). See the Testing and 

Monitoring Plan for specific information. 

Potential Response Actions: 

• Notify the UIC Program Director within 24 hours of the incident, per 40 CFR 

146.91(c)(3). 

• Evaluate integrity of storage volume by gas pressure response and monitoring 

instrumentation. 

• If a leak is detected, conduct a geophysical survey to locate new fracture zone. 

• Intensify monitoring to determine whether migration is continuing over time. 

• Lower reservoir pressure by removing liquids (water, brine, etc.) from the storage 

reservoir. 

• Intersect the migration with extraction wells in the vicinity of the leak, withdraw, and reinject. 

• Lower the reservoir pressure by promoting new pathways to access new volumes or strata 

in the storage reservoir. 

• Create a hydraulic barrier by increasing reservoir pressure upstream of the leak. 

• Inject grout or chemical sealant to block leak. 

• If contamination is detected, identify and implement appropriate remedial actions (in 

consultation with the UIC Program Director). 

• Investigate the cause of the seismic event. 

• Communicate the investigation and findings to the public (see Part 5). 

• See Part 3.4 for details on further response. 

Response Personnel: Onsite operations staff, drilling crew, supervising professionals, 

geotechnical contractors, mechanical contractors, as required. 

Equipment: Newly mobilized drill rig, logging equipment, cement or casing, as required. 

Event/Description: Groundwater/ USDW contamination: If there were a failure of the 

confining zone, failure of the injection or monitoring well, or if the plume encounters an 

undocumented AoR well, CO2 or brine could reach groundwater, requiring remediation. 

Severity: Medium to High depending upon location

Time of Event: Post-injection site care 

Avoidance Measures: The entire CO2 injection project is focused on preventing escape of CO2

while sequestering the CO2. The FutureGen oxy-combustion process incorporates gas-cleaning 

processes to remove at least 97% of contaminants, including mercury, prior to injection. Trace 

contaminants that might be entrained in CO2 leaking into USDWs will pose inconsequential risk 

to the water quality. 

Detection Methods: USDW aquifer monitoring in USDW well. See the Testing and Monitoring 

Plan for specific information. 

Potential Response Actions: 
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• Notify the UIC Program Director within 24 hours of the incident, per 40 CFR 

146.91(c)(3).

• Assess cause by reviewing monitoring data. 

• Conduct a geophysical survey in an attempt to locate migration. 

• Identify and implement appropriate remedial actions (in consultation with the UIC 

Program Director). If the leak cannot be located or while pursuing corrective measures 

for the leak, the following remedies may be considered: 

− Drill wells to intersect accumulations in groundwater, preferably near CO2 aquifer 

entrance zones. Extract groundwater contaminated with gaseous or dissolved CO2

water and treat ex situ. 

− Dissolve mineralized CO2 (carbonates) in water and extract as a dissolved phase 

through an extraction well for ex situ air stripping. 

− Extract groundwater with metals mobilized by CO2 and treat ex situ to remove metals 

and residual CO2. 

− Use hydraulic barriers to immobilize and contain contaminants by deploying injection 

and extraction wells. 

− Deploy in situ chemical or biological treatment technologies to enhance biochemical 

degradation or stabilization of CO2 -related contaminants. 

− Create a hydraulic barrier by increasing reservoir pressure upstream of a leak. 

− Place grouts or chemical sealant barriers to block leaks. 

− Provide individual water-treatment systems for each water-supply well user. The 

configuration for each ex situ treatment system will be determined by water 

chemistry. Applicable treatment technologies include but are not limited to aeration, 

pH adjustment, ion exchange, oxidizing filter, membrane filtration, etc. 

• See Parts 3.2 and 3.3 for details on further response actions. 

Response Personnel: Drilling crew, supervising professionals, geotechnical subcontractors, 

environmental or water-treatment contractors. 

Equipment: Water-treatment equipment, new wellhead plumbing to and from water-treatment 

equipment, reagents for optional in situ treatment, newly mobilized drill rig, logging equipment, 

cement, or casing, as required. 

3.1 Potential Response Actions to Loss of Injection Well Integrity 

If a well blowout occurs during drilling, the blowout preventer will activate automatically. In the 

unlikely event of blowout preventer failure, heavy fluid would be injected in an attempt to regain 

hydrostatic control of the well column. If control could not be achieved, new wells that intersect 

pressurized accumulations of formation fluid and CO2 could be drilled and pumped to relieve 

downhole pressures that are driving the release and cement could be injected to permanently 

close the well(s). 

If a well blowout were to occur during injection operations, injection would be stopped 

immediately. One or more responses would then be implemented depending on the conditions 

encountered. The master valves would be closed. The well could be killed or permanently closed 

by pumping cement or heavy kill fluid down the well bore until the well stops flowing. If the 

flow continued, a heavier kill fluid could be pumped until the hydrostatic pressure of the fluid 
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column in the well stopped and contained the flow. If the release were to remain uncontrolled, 

new wells that intersect pressurized accumulations of formation fluid and CO2 could be drilled 

and pumped to relieve downhole pressures that are driving the release. 

A slow release of CO2 could occur with a lesser failure of mechanical integrity for an injection 

well. Responses to such situations would involve equipment repair, temporary cessation of 

injection operations, and modification of injection equipment or procedures. If a leak occurred 

outside the outermost casing of an injection well, due to fractures of a confining formation in the 

immediate vicinity of the well string, localized application of grout sealant would be among the 

remedial actions considered. Implementation of such a remedy would entail drilling a new well 

into the affected area and injecting grout sealant into the formation where the formation 

geometry and properties facilitate lateral dispersion of the sealant into the compromised zone 

around the exterior of the CO2 injection well. 

Onsite drilling or operations personnel would correct the leakage, depending on when the leak 

occurs. Equipment used to correct the leak may involve a workover rig and wire-line tools, pipe, 

packers, bridge plug, and pressure-control equipment. In the extremely unlikely situation that a 

new well is required to relieve pressure, well casing, wellhead equipment, cement or mud 

equipment, and a secondary drill rig would be required. 

3.2 Response Actions to Fluid Movement into USDWs 

The immediate and primary responses to detection of injection-related fluid migration into any 

USDW would be similar to the remedies for a release via mechanical failure or confining 

formation failure: cessation of injection, notification, identification, and location of the source of 

the release, and implementation of corrective action to seal or stop the release. The location, size 

of the release, and access to the problem will control the particular course of remedial action. In 

the improbable event of an impact on water quality within the surficial aquifer system directly 

affecting water-supply wells, either point of use, withdrawal water treatment, or alternate watersupply remedies would be provided as appropriate. 

3.3 Response Actions to Rapid and Unexpected Movement Beyond Modelled Predictions 

If a rapid movement of injection-related fluids were detected or inferred outside of where they 

are predicted to be, the following response actions would be performed: 

 Immediately notify the power plant, owner, and other designated project contacts. 

 Notify the UIC Program Director within 24 hours of the incident per 40 CFR 

146.91(c)(3). 

 Project contacts will determine the severity of the event, based on the information 

available. 

For a major or serious emergency: 

 Cease injection according to the procedures in the permit. 
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 Shut in well (close flow valve). 

 Communicate with local authorities to initiate evacuation plans, as necessary. 

 Monitor injection well conditions to verify well status. 

 Determine if there has been a loss of mechanical integrity of injection or monitoring 

wells. 

 Identify and initiate remedial actions. 

For a minor emergency: 

 Monitor injection and monitoring well conditions to verify well status. 

 Determine if there has been a loss of containment in the reservoir. 

 Adjust injection rate as necessary to maintain containment in reservoir. 

Once the source and pathway of the release were identified, remedial actions appropriate for the 

situation would be implemented as described above. 

3.4 Response Actions to a Seismic Event 

A tiered approach and response will be taken based on event magnitude and proximity to the 

storage site. 

After a seismic event has been identified, a decision must be made regarding the level of impact 

a given event could have on storage site operations, whether a response is required, and what the 

appropriate response will be. This decision and response framework will consist of an automated 

event location and magnitude determination, followed by an alert for a technical review in order 

to reduce the likelihood of false positives. 

Identification of events with sufficient magnitude or that are located in a sensitive area (caprock) 

should be used as input for decisions that guide the adaptive strategy. Seismic events that affect 

the operations of CO2 injection can be divided into two groups/tiers: 1) events that create felt 

seismicity at the surface and may lead to public concern or structural damage, and 2) events not 

included in group one, but that might indicate failure or impending failure of the caprock. The 

operational protocol for responding to events in group one (Tier I) will follow a “traffic light” 

approach (modified after Zoback 2012; National Research Council 2012) that uses three 

operational states: 

1. Green: Continue normal operations unless injection-related seismicity is observed with 

magnitudes greater than M = 2. 

2. Yellow: Injection-related seismic events are observed with magnitude 2 < M < 4. The 

injection rate will be slowed and the relationship between rate and seismicity will be 

studied to guide mitigation procedures, including reduced operational flow rates. The 

FutureGen Alliance will notify the EPA UIC Program Director of any such event within 

24 hours providing information on the status of the storage site. 

3. Red: Magnitude 4 or greater seismic events are observed that are related to CO2 injection. 

Injection operations will stop and an evaluation will be performed to determine the 
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source and cause of the ground motion. The FutureGen Alliance will notify the EPA UIC 

Program Director of any such event within 24 hours providing information on the status 

of the storage site. 

Tier II operational responses to an event or collection of events that indicate possible failure of 

the primary confining zone may include initiation of supplemental adaptive monitoring activities, 

injection rate reduction in one or more injection laterals, or pressure reduction using brine 

extraction wells. 

3.5 Response Actions to a Natural Disaster 

If a natural disaster occurs that affects normal operation of the injection well, the FutureGen 

Alliance will perform the following response actions: 

 Immediately notify the power plant, owner, and other designated project contacts. 

 Notify the UIC Program Director within 24 hours of the incident per 40 CFR 

146.91(c)(3). 

 Project contacts will determine the severity of the event, based on the information 

available, 

For a major or serious emergency: 

 Cease injection according to the procedures in the permit. 

 Shut in well (close flow valve). 

 Communicate with local authorities to initiate evacuation plans, as necessary. 

 Monitor injection well conditions to verify well status. 

 Determine if there has been a loss of mechanical integrity of injection and monitoring 

wells. 

 Identify and initiate remedial actions. 

For a minor emergency: 

 Monitor injection well conditions to verify well status. 

 Determine if there has been a loss of mechanical integrity of a single barrier in an 

injection well and/or in any monitoring wells. 

 Initiate notification in accordance with permit conditions 

 Identify and initiate remedial actions, as needed. 

3.6 Response Actions to Monitoring Equipment Failure 

If a device malfunctions and requires repair, a backup monitoring scheme will be initiated. This 

may include temporary use of manual measurements to compensate for non-functioning 

equipment or the replacement of equipment with spares. Replacement sensors and repair parts 

will be maintained onsite to facilitate repair. 
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Part 4: Emergency Contacts 

4.1 FutureGen and Local Agency Notification 

If a CO2 release outside of the injection zone were detected, the Emergency Coordinator and 

Emergency Operations Manager on duty would be notified immediately. The Emergency 

Coordinator will be responsible for notifying offsite emergency agencies and resources. If the 

Emergency Coordinator is not available, the Emergency Operations Manager will contact outside 

emergency response organizations (listed in Table 3) appropriate for the situation. The EPA 

Region 5 UIC Program Director will also be notified within 24 hours. 

4.2 Injection Operations Staff 

Monitoring, control, and routine maintenance of the injection operations at the FutureGen 2.0 

storage site in Morgan County will be the responsibility of the Injection Operations Staff. The 

staff is expected to include the minimum positions as listed in Table 4. 

Table 3. Outside Emergency Response

Agency Location Phone

Fire Alexander, IL 911

217-478-3341

Ambulance Jacksonville, IL 911

217-245-7540

Passavant Area Hospital Jacksonville, IL 217-245-9541

State Police 217-786-7101

Illinois Emergency Management 

Agency

Springfield, IL 217-782-7860

Jacksonville/Morgan County 

Emergency Services & Disaster 

Agency

Jacksonville, IL 217-479-4616

Sheriff Jacksonville, IL 217-245-4143
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Table 4. Operations Staff Descriptions

Position Function Qualifications

Emergency 

Coordinator

Responsible for notification of offsite support 

agencies in accordance with written procedures. 

Responsible for coordination and overseeing 

contact with the media.

Trained in the Communications 

Plan and Emergency 

Notification Procedures 

requirements as contained in the 

ERRP.

Emergency Operations 

Manager

Serves as the Alliance Emergency Response 

Manager responsible for the overall management 

of the Alliance Incident Response Team. 

Manages facility operations and personnel 

during an emergency and is responsible for 

implementation of appropriate emergency 

procedures and their follow-up.

Trained in the requirements of 

the ERRP and facility 

operations.

Senior 

Geologist/Geophysicist

Responsible for injection operation, 

maintenance, and monitoring. Lead incident 

response manager regarding injection and 

storage zone operation at the facility.

Graduate degree in 

geology/geophysics with at least 

5 years of experience in geologic 

reservoir dynamics and relevant 

monitoring interpretation.

Geologist/Geophysicist

Professional associate assisting in operation, 

maintenance, and monitoring of injection 

process. Conducts routine data management and 

interpretation. Assists in implementing response 

actions, particularly in regard to injection zone 

integrity.

Undergraduate degree in 

geophysics or geology with 

specialization in hydrology/fluid 

mechanics.

Operations Engineer

Manages mechanical and fluid management 

operation of the injection wells, annulus pressure 

control system, and well head piping systems. 

Maintains and repairs injection-related 

equipment, including valves, instruments, 

piping. Assists in mechanical and electronic 

control of injection process.

Undergraduate degree in 

engineering, preferably related 

to mechanical, chemical or 

process control. At least 2 years 

of direct hands on operation and 

service of equipment and 

instruments related to 

pressurized well systems and 

wellhead controls.

4.3 Agency Notification 

Agency emergency response services will also be provided by the Illinois State Geological 

Survey, Illinois Department of Natural Resources, and U.S. Geological Survey Water Resources 

for Illinois. In addition to the emergency contact lists, a list of contacts for state agencies having 

jurisdiction within the AoR is presented in Table 5. At this time, there are no federally 

recognized Native American Tribes located within the AoR or the State of Illinois 

(http://www.ncsl.org/research/state-tribal-institute/list-of-federal-and-state-recognizedtribes.aspx). If a federally recognized Native American Tribe exists in the AoR or the State of 

Illinois at the time of a site emergency, it will be notified of the site emergency at that time. 
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Table 5. Agency Emergency Response

Agency Person Position Address and Phone

USEPA Region 5 Jeffrey

McDonald

UIC Program

Contact

Chicago, IL

(312) 353-6288

Illinois State 

Geological Survey

Randall A. 

Locke, II

Environmental 

Geochemist and 

Head 

Geochemistry 

Section

Room 387, Natural Resources Building 15 

E. Peabody, University of Illinois 

Champaign, IL 61820

217-333-3866

Illinois Department 

of Natural 

Resources

- Office of Law 

Enforcement

One Natural Resources Way Springfield, 

IL 62702

217-785-8407

U.S. Geological 

Survey Water 

Resources for 

Illinois

- 1201 W. University Avenue, Suite 100 

Urbana, IL 61801

217-328-8747

Part 5: Emergency Communications Plan 

Prior to the start of CO2 injection operations, the FutureGen Alliance will formally communicate 

with landowners living adjacent to the storage site to provide information about the nature of the 

operations, potential risks, and appropriate response approaches under various emergency 

scenarios. 

An emergency contact list will be maintained during the life of the project. In the event of an 

emergency, the Emergency Coordinator will start the call tree and make sure the appropriate 

personnel are contacted.

Emergency communications with the public will be handled by the FutureGen Alliance. The 

Emergency Coordinator is a FutureGen Alliance-designated individual who will coordinate 

responses to the media. 

The FutureGen Alliance will communicate to the public about any event that requires an 

emergency response to ensure that the public understands what happened and any environmental 

or safety implications. The amount of information, timing, and communications method(s) will 

be appropriate to the event, its severity, whether any impacts to drinking water or other 

environmental resources occurred, any impacts to the surrounding community, and their 

awareness of the event. 

The FutureGen Alliance will describe what happened and the location of any emergency event 

(e.g., at the injection well or wells; within the AoR; at a monitoring well location), any impacts 

to the environment or other local resources, how the event was investigated, what responses were 

taken, and the status of the response. For responses that occur over the long-term (e.g., ongoing 

cleanups), the FutureGen Alliance will provide periodic updates on the progress of the response 

action(s). 
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If a seismic event occurs, the FutureGen Alliance will provide information about whether the 

event was naturally occurring or induced by the injection; whether any damage to the well or 

other structures in the area occurred; the investigative process; and what responses, if any, were 

taken by the FutureGen Alliance or others. 

The FutureGen Alliance will also communicate with entities who may need to be informed about 

or take action in response to the event, including local water systems, CO2 source(s) and pipeline 

operators, land owners, and Regional Response Teams (as part of the National Response Team). 

Response personnel will receive information including but not limited to: 

 The location of the injection and monitoring wells (coordinates and directions to the 

storage site); 

 A map of the area including the location of the wells, nearby population centers, and 

sensitive environments; 

 Schematics and diagrams of the facility and the well, including the location of monitoring 

equipment and emergency shutoffs. 

In the event that anyone else is contacted to comment on any situation deemed an “emergency,” 

the media contact should be directed to the FutureGen Alliance -designated individual, who will 

oversee all media communications with the public (through either interview, press release, Web 

posting, or other) in the event of an emergency situation related to the injection project. 

Part 6: Plan Review 

The FutureGen Alliance will annually review and, as necessary, revise its ERRP. In addition, the 

FutureGen Alliance will review and, as necessary, revise its ERRP within one year of an AoR 

reevaluation or within one year after any significant changes to the facility such as the addition 

of injection or monitoring wells. Any revised plan will be submitted to the EPA UIC Program 

Director for approval. If, after a review, the FutureGen Alliance determines that no revisions are 

necessary, the FutureGen Alliance will submit its determination and the basis for such a 

determination to the EPA UIC Program Director. 

Part 7: Staff Training and Exercise Procedures 

All operations employees will receive training related to health and safety, operational 

procedures, and emergency response according to the roles and responsibilities of their work 

assignments. Initial training will be conducted by, or under the supervision of, a project 

operations manager or a designated representative. Trainers will be thoroughly familiar with the 

Operations Plan and ERRP. 

Facility personnel will participate in annual training that teaches them to perform their duties in 

ways that prevent the discharge of CO2. The training will include familiarization with operating 

procedures and equipment configurations appropriate to the job assignment, as well as 
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emergency response procedures, equipment, and instrumentation. New personnel will be 

instructed before beginning their work. 

Refresher training will be conducted at least annually for all operations personnel. Monthly 

briefings will be provided to operations personnel according to their respective responsibilities 

and will highlight recent operating incidents, actual experience in operating equipment, and 

recent storage reservoir monitoring information. 

Only personnel who have been properly trained will participate in drilling, construction, 

operations, and equipment repair at the storage site. A record including the person’s name, date 

of training, and the instructor’s signature will be maintained.