Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E1 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

ATTACHMENT E: POST-INJECTION SITE CARE (PISC) AND SITE CLOSURE 

PLAN 

Facility Information 

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 Post-Injection Site Care and Site Closure (PISC) plan describes the activities that the 

FutureGen Alliance will perform to meet the requirements of 40 CFR 146.93. The FutureGen 

Alliance will monitor ground water quality and track the position of the carbon dioxide plume 

and pressure front for fifty years of post-injection site care and may not cease post-injection 

monitoring and site care until a demonstration of non-endangerment of USDWs has been 

approved by the UIC Program Director pursuant to 40 CFR 146.93(b)(3). Following approval for 

site closure, the FutureGen Alliance will plug all monitoring wells, restore the site to its original 

condition, and submit a Site Closure report and associated documentation. 

Pre- and Post-Injection Pressure Differential 

The information regarding pre- and post-injection pressure differentials, as required by 40 CFR 

146.93(a)(2)(i) is presented below. 

The maximum injection pressure differential is 479 psi at the injection well when injection stops. 

The magnitude and area of elevated pressure gradually decreases over time after injection stops; 

as further detailed in Table 1.

Figure 1 shows the pressure differential versus time for monitoring well locations in the Area of 

Review (AoR) and at the geometric centroid of the four horizontal injection wells. Simulated 

pressures at the injection “point” increase during the 20-year injection period from 1,779 psi to a 

maximum of 2,258 psi. The highest pressures are in the immediate vicinity of each injection 

well. As shown, pressures at the injection and monitoring well locations decline over time after 

injection ceases. Despite the modeled pressure of 2,258 psi, current permit limitations will 

require the pressure in the injection well not to exceed 2,252 psi. 

Figure 2 presents aqueous pressure differentials from baseline at the top of the injection zone and 

the extent of the carbon dioxide plume at 20 years after the start of injection (i.e., the end of 

injection) and 70 years after the start of injection (i.e., at site closure). 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E2 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 1. Pressure differential to baseline conditions at well locations near the base of the Ironton Formation 

for Above Confining Zone Well 1 (ACZ1) and ACZ2 and at the middle of the Mount Simon 11 layer 

in the injection zone for the rest of the wells during and after. 

Pressure Differential (psi)

Year SLR1 SLR2 ACZ1 ACZ2 Injection Well

Distance from Injection Well (ft) 3740 6555 1010 3740 0

Elevation (ft) -3371 -3414 -2763 -2751 -3390

0 (Start injection) 0 0 0 0 0

1 223 125 0 0 350

2 277 165 0 0 394

3 311 192 0 0 417

4 333 211 0 0 431

5 348 225 0 0 441

10 393 274 0 0 466

15 413 313 1 1 475

20 (Stop injection at year end) 425 338 2 2 479

21 255 235 2 2 259

22 (Approximate maximum extent of CO2

Plume) 199 186 2 2 200

23 167 157 2 2 167

24 145 137 3 3 145

25 129 121 3 3 128

30 85 81 4 4 84

35 64 61 4 4 63

40 51 49 5 5 50

45 42 40 5 5 41

50 36 34 5 5 35

60 27 26 5 5 26

70 22 21 5 5 21

80 18 17 5 5 17

90 15 14 5 5 14

100 13 12 4 4 12

SLR1 Single-Level in-Reservoir #1

SLR2 Single-Level in-Reservoir #2

ACZ1 Above Confining Zone #1

ACZ2 Above Confining Zone #2

Injection Well Geometric centroid of four horizontal laterals
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E3 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Figure 1. Simulated aqueous pressure differential versus time at monitoring well locations near the base of 

the Ironton Formation for ACZ1 and ACZ2 and at the middle of the Mount Simon 11 layer in the 

injection zone for the rest of the wells.

Figure 2. Aqueous pressure differentials from baseline condition at the top of the injection zone and CO2

plume extents at 20 years (end of injection) and 70 years (site closure) after start of injection. 

-100

0

100

200

300

400

500

600

0 10 20 30 40 50 60 70 80 90 100

Pressure Build-Up (psi)

Time (year)

SLR1 (Elev. = -3371 ft)

SLR2 (Elev. = -3414 ft)

ACZ1 (Elev. = -2763 ft)

ACZ2 (Elev. = -2751 ft)

Injection Well (Elev. = -3390 ft)
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E4 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Predicted Position of the CO2 Plume and Associated Pressure Front Upon Cessation of 

Injection and at Site Closure 

The information regarding the predicted position of the carbon dioxide plume and associated 

pressure front at site closure, as required by 40 CFR 146.93(a)(2)(ii) is presented below. 

The areal extent of the CO2 plume increases during injection and for 2 years post-injection. As 

the areal extent decreases (at year 22), the plume migrates predominately upward. The 

computational modeling results indicate that the sequestered CO2 will migrate above the Mount 

Simon Sandstone, into the Elmhurst as well as the lower part of the Lombard. 

Figure 3 and Figure 4 show the upward migration of the CO2 plume near the injection wells at 20 

and 70 years. These two-dimensional images demonstrate various levels of gas saturation or 

upward migration into the injection zone (Mount Simon Formation, Elmhurst Sandstone, and the 

lower part of the Lombard). The computational model results indicate that the Model Layer 

“Lombard 5” is the top unit containing a fraction of injected CO2 during the 100-year simulation. 

The top of the injection zone is set at 3,153 ft ( below MSL) at the FutureGen stratigraphic well, 

corresponding to the top of the Lombard 5 layer of the numerical model. 

The computational model estimates that the CO2 plume forms a cloverleaf pattern as a result of 

the four lateral-injection-well design. The plume grows both laterally and vertically as injection 

continues. Most of the CO2 resides in the Mount Simon Sandstone. A small amount of CO2

enters into the Elmhurst and the lower part of the Lombard Formation. When injection ceases at 

20 years, the lateral growth becomes negligible but the plume continues to move slowly 

primarily upward. Once CO2 reaches the low-permeability zone in the upper Mount Simon it 

begins to move laterally. 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E5 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Figure 3. Cutaway view of CO2-rich phase saturation along A-A’ (Injection Wells 1 and 3) at 20 and 70 years. 

The red dashed line indicates the top of the injection zone. 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E6 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Figure 4. Cutaway view of CO2-rich phase saturation along B-B’ (Injection Wells 2 and 4) at 20 and 70 years. 

The red dashed line indicates the top of the injection zone. 

Reservoir conditions are such that the CO2 remains in the supercritical state throughout the 

domain and for the entire simulation period. The three-dimensional distribution of the CO2-rich 

(or separate-) phase saturation is presented for selected times (i.e., 20 and 70 years). 

Additionally, to better illustrate the CO2 migration through time and space, a cross-sectional 

view of the CO2 plume is presented as slices through the center of the injection wells and along 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E7 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

the well traces. Figure 3 and Figure 4 show the CO2-rich (or separate) phase saturation for 

selected times for slices A-A’ and B-B’, respectively. 

The maximum pressure differential corresponds to the end of the injection period (year 20). 

After that time, the pressure slowly dissipates, resulting in the maximum pressure differential 

being below 30 psi at 70 years, and below 20 psi at 100 years. The pressure differential 

distribution has been presented instead of a defined pressure front because the calculated 

pressure head in the Mt. Simon is greater than the calculated pressure head in the lowermost 

underground source of drinking water (USDW), the St. Peter Sandstone, under initial conditions 

prior to injection. Figure 2 presents aqueous pressure differentials from baseline at the top of the 

injection zone and the extent of the carbon dioxide plume at 20 years after the start of injection 

(i.e., the end of injection) and 70 years after the start of injection (i.e., at site closure). 

The model predicts that the areal extent of the CO2 plume (defined as 99.0 percent of the 

separate-phase CO2 mass) increases during injection and for 2 years post-injection and then 

begins to decrease as buoyancy forces dominate and plume migration is predominately upward. 

Figure 5 shows the cumulative area of the CO2 mass plume with time. The maximum plume 

extent, 6.46 mi2, occurs at 22 years after the start of injection (2 years after the cessation of 

injection). 

Figure 5. Simulated plume area over time (the vertical dashed line denotes the time CO2 injection ceases). 

The predicted extent of the CO2 plume at the time of site closure, 50 years after the cessation of 

CO2 injection, was determined from the computational model results. 

Figure 6 shows the predicted areal extent of the CO2 plume (defined as 99.0 percent of the 

separate-phase CO2 mass) at the time of site closure. The simulation predictions show that 99.0 

percent of the separate-phase CO2 mass would be contained within an area of 6.35 mi2

at the 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E8 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

time of site closure. This plume is only 1.7% smaller than the maximum plume area, which 

occurs at 22 years after the start of injection (Figure 5). 

Figure 6. Simulated areal extent of the CO2 plume at the time of site closure (70 years after CO2 injection was 

initiated). 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E9 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Post-Injection Monitoring Plan 

FutureGen will perform post-injection monitoring, as required by 40 CFR 146.93(b), as 

described below. 

Pressure monitoring of the injection zone will occur in three monitoring wells. The Testing and 

Monitoring Plan (Attachment C of this permit) describes the planned monitoring activities. 

Quality assurance and surveillance measures: 

Data quality assurance and surveillance protocols adopted by the project are designed to 

facilitate compliance with the requirements specified in 40 CFR 146.90(k). Quality Assurance 

(QA) requirements for direct measurements within the injection zone, above the confining zone, 

and within the shallow USDW aquifer that are critical to the post-injection monitoring, program 

(e.g., pressure and aqueous concentration measurements) are described in the Quality Assurance 

and Surveillance Plan (QASP) that is presented in Appendix G of the Testing and Monitoring 

Plan. These measurements will be performed based on best industry practices and the QA 

protocols recommended by the geophysical services contractors selected to perform the work. 

Location of Monitoring Wells 

Monitoring well locations are described in the Testing and Monitoring Plan (Attachment C of 

this permit). Their coordinates are provided in Appendix A of this plan. The objective of the 

monitoring program is to select and implement a suite of monitoring technologies that are both 

technically robust and provide an effective means of 1) evaluating CO2 mass balance, 2) 

detecting any unforeseen containment loss, and 3) evaluating pressure changes in the reservoir to 

ensure that monitored values corroborate modeled expectations. 

As part of the project’s design optimization, the monitoring well network has been configured 

(Figure 7) to effectively monitor and account for the injected CO2 and pressure changes. The 

design includes a total of nine monitoring wells: 

 Two Above Confining Zone (ACZ) wells. These wells will be used to monitor 

immediately above the Eau Claire caprock in the Ironton Sandstone. Monitored 

parameters include: pressure, temperature, and hydrogeochemical indicators of CO2

(Table 6). 

 Two Single-Level in-Reservoir (SLR) wells (one of which is a reconfiguration of the 

previously drilled stratigraphic well). These wells will be used to monitor within the 

injection zone beyond the east and west ends of the horizontal CO2-injection laterals. 

Monitored parameters include: pressure, temperature, and hydrogeochemical indicators 

of CO2 (Table 6). One additional SLR well (a tenth monitoring well) will be installed 

outside of the expected CO2 plume to monitor pressure effects in the injection zone. 

 Three Reservoir Access Tubes (RAT) wells. These are fully cased wells, which allow 

access for monitoring instrumentation in the reservoir via pulsed neutron capture (PNC) 

logging equipment. To avoid two-phase flow near the borehole, which can distort the 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E10 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

CO2 saturation measurements, the wells will not be perforated. Monitoring parameters 

include: quantification of CO2 saturation across the reservoir and caprock. 

 One USDW well. This well will be used to monitor the lowermost USDW (the St. Peter 

Sandstone). Monitored parameters include: pressure, temperature, and hydrogeochemical 

indicators of CO2 (Table 6). 

Although monitoring of the shallow surficial aquifer is not required or anticipated during the 

post-injection period, the network remains available for monitoring activities should the need 

arise.
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E11 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Figure 7. Map of monitoring well locations. 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E12 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Figure 8. Surficial aquifer monitoring locations. Well FG-1 is a dedicated well drilled for the purposes of the 

FutureGen project, while wells FGP-1 through FGP-10 wells are local landowner wells. 

Summary of Planned Post-Injection Monitoring Activities 

The suite of indirect geophysical monitoring methods that will be used to monitor the areal 

extent, evolution, and fate and transport of the injected CO2 plume during PISC include: PNC 

logging, passive seismic monitoring, integrated surface deformation monitoring, and time-lapse 

gravity surveys. Table 2 summarizes the testing and monitoring activities planned for the postinjection phase; collection and recording of continuous monitoring data will occur at the 

frequencies described in Table 13. 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E13 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 2. Summary of post-injection monitoring activities. 

Monitoring Category Monitoring Method/Location Frequency 

(Post-Injection Phase)

Groundwater Quality and 

Geochemistry Monitoring

Fluid sampling in surficial aquifers: 9 local 

landowner wells and 1 project-drilled well None Planned

Fluid sampling in St. Peter: one lowermost USDW 

well

Geochemistry Every 5 years

Continuous temperature and 

pressure monitoring

Fluid sampling in Ironton: two ACZ wells

Geochemistry Every 5 years

Continuous temperature and 

pressure monitoring

Injection Zone Monitoring

Fluid sampling in Mount Simon: SLR monitoring 

wells Every 5 years

Pulsed-neutron capture (PNC) logging at 3 RAT 

wells Every 5 years

Pressure monitoring in Mount Simon: two SLR 

monitoring wells Continuous

Indirect Geophysical 

Monitoring Techniques 

Integrated deformation monitoring: five surface 

monitoring stations Continuous

Passive deep microseismic arrays in two ACZ 

wells and five seismometers in shallow cased bore 

holes. Continuous

Note: For details and information on continuous monitoring, see Table 13.

Groundwater Quality Monitoring 

FutureGen will conduct groundwater sampling every 5 years according to the procedures 

described below. 

Specific information concerning the sampling methods, analytical techniques, laboratories and 

quality assurance for sampling for the post-injection monitoring program are presented in the 

FutureGen QASP; see Table A.2 for Monitoring Tasks, Methods, and Schedule. 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E14 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Sampling will take place at the frequencies specified in Table 3 (for the surficial aquifers), Table 

4 (for the St. Peter), and Table 5 (for the Ironton). Because near-surface environmental impacts 

are not expected, surficial aquifer (<100 ft bgs) monitoring will only be conducted for a 

sufficient duration to establish baseline conditions (minimum of three sampling events) prior to 

start of the injection phase of the project. 

 Surficial aquifer monitoring is not planned during the post-injection phase; however, the 

need for additional surficial aquifer monitoring will be continually evaluated throughout 

the operational phases of the project, and may be reinstituted if conditions warrant or if 

requested by the EPA UIC Program Director. 

 Target parameters for the ACZ wells include pressure, temperature, hydrogeochemical 

indicators of CO2, and brine composition (Table 6). 

 Target parameters for the USDW and surficial aquifer wells include pressure, 

temperature, hydrogeochemical indicators of CO2, and brine composition (Table 6). 

If a leakage response is observed in the ACZ early-detection monitoring wells (Ironton) then the 

decision not to institute USDW aquifer triggers will be reevaluated based on the magnitude of 

the observed leakage response and predictive simulations of CO2 transport between the Ironton 

and the St. Peter Formations. 

Table 3. Sampling schedule for surficial aquifer monitoring wells. 

Monitoring well name/location/map reference: Surficial aquifer monitoring wells 

Well depth/formation(s) sampled: Shallow glacial sediments (approx. 17 ft – 49 ft)

Parameter/Analyte Frequency 

(Post-Injection Phase)

Dissolved or separate-phase CO2 None Planned

Pressure None Planned

Temperature None Planned

Other parameters, including total dissolved solids, pH, specific 

conductivity, major cations and anions, trace metals, dissolved inorganic 

carbon, total organic carbon, carbon and water isotopes, and radon

None Planned

Table 4. Sampling schedule for the USDW monitoring well. 

Monitoring well name/location/map reference: One USDW monitoring well (see Figure 7)

Well depth/formation(s) sampled: St. Peter Sandstone (2,000 ft)

Parameter/Analyte Frequency 

(Post-Injection Phase)

Dissolved or separate-phase CO2 Every 5 years

Pressure Continuous

Temperature Continuous

Other parameters, including total dissolved solids, pH, specific 

conductivity, major cations and anions, trace metals, dissolved inorganic 

carbon, total organic carbon, carbon and water isotopes, and radon

Every 5 years

Note: For details and information on continuous monitoring, see Table 13. 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E15 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 5. Sampling schedule for ACZ monitoring wells. 

Monitoring well name/location/map reference: Two ACZ monitoring wells (see Figure 7) 

Well depth/formation(s) sampled: Ironton Sandstone (3,470 ft)

Parameter/Analyte Frequency 

(Post-Injection Phase)

Dissolved or separate-phase CO2 Every 5 years

Pressure Continuous

Temperature Continuous

Other parameters, including total dissolved solids, pH, specific 

conductivity, major cations and anions, trace metals, dissolved inorganic 

carbon, total organic carbon, carbon and water isotopes, and radon

Every 5 years

Note: For details and information on continuous monitoring, see Table 13.

Note: collection and recording of continuous monitoring data will occur at the frequencies 

described in Table 13. 

Sampling methods: 

Sampling procedures are discussed below, and specific details are provided in the FutureGen 

QASP Table A.2. 

During all groundwater sampling, field parameters (pH, specific conductance, and temperature) 

will be monitored for stability and used as an indicator of adequate well purging (i.e., parameter 

stabilization provides indication that a representative sample has been obtained). Calibration of 

field probes will follow the manufacturer’s instructions using standard calibration solutions. A 

comprehensive list of target analytes and groundwater sample collection requirements is 

provided in Table 6. All analyses will be performed in accordance with the analytical 

requirements listed in Table 7. Additional analytes may be included for the shallow USDW 

based on landowner requests (e.g., coliform bacteria). 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E16 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 6. Aqueous sampling requirements for target parameters. 

Parameter Volume/Container Preservation Holding

Time

Major Cations: Al, Ba, Ca, Fe,

K, Mg, Mn, Na, Si,

20-mL plastic vial Filtered (0.45 μm), HNO3 to pH <2 60 days

Trace Metals: Sb, As, Cd, Cr,

Cu, Pb, Se, Tl

20-mL plastic vial Filtered (0.45 μm), HNO3 to pH <2 60 days

Cyanide (CN-) 250-mL plastic vial NaOH to pH > 12, 0.6g ascorbic acid 

Cool 4°C, 

14 days

Mercury 250-mL plastic vial Filtered (0.45 μm), HNO3 to pH <2 28 days

Anions: Cl-, Br-, F

-

, SO4

2-

, NO3

-

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

Total and Bicarbonate 

Alkalinity (as CaCO3

2-

)

100-mL HDPE Filtered (0.45 μm), Cool 4°C 14 days

Gravimetric Total Dissolved

Solids (TDS)

250-mL plastic vial Filtered (0.45 μm), no preservation,

Cool 4°C

7 days

Water Density 100-mL plastic vial No preservation, Cool 4°C

Total Inorganic Carbon (TIC) 250-mL plastic vial H2SO4 to pH <2, Cool 4°C 28 days

Dissolved Inorganic Carbon

(DIC)

250-mL plastic vial Filtered (0.45 μm), H2SO4 to pH <2, 

Cool 4°C

28 days

Total Organic Carbon (TOC) 250-mL amber glass Unfiltered, H2SO4 to pH <2, Cool 4°C 28 days

Dissolved Organic Carbon

(DOC)

125-mL plastic vial Filtered (0.45 μm), H2SO4 to pH <2, 

Cool 4°C

28 days

Volatile Organic Analysis 

(VOA)

Bottle set 1: 3-40-mL 

sterile clear glass 

vials

Bottle set 2: 3-40-mL 

sterile amber glass 

vials 

Zero headspace, Cool <6 °C, Clear 

glass vials will be UV-irradiated for 

additional sterilization

7 days

Methane Bottle set 1: 3-40-mL 

sterile clear glass 

vials

Bottle set 2: 3-40-mL 

sterile amber glass 

vials

Zero headspace, Cool <6 °C, Clear 

glass vials (bottle set 1) will be UVirradiated for additional sterilization

7 days

Stable Carbon Isotopes 13/12C 

(δ

13C) of DIC in Water

60-mL plastic or 

glass

Filtered (0.45-μm), Cool 4°C 14 days

Radiocarbon 14C of DIC in 

Water

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

Hydrogen and Oxygen Isotopes 

2/1H (δD) and 18/16O (δ18O) of 

Water

60-mL plastic or glass Filtered (0.45-μm), Cool 4°C 45 days
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E17 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Parameter Volume/Container Preservation Holding

Time

Carbon and Hydrogen Isotopes 

(

14C, 13/12C, 2/1H) of Dissolved 

Methane in Water

1-L dissolved gas 

bottle or flask

Benzalkonium chloride capsule, Cool 

4°C

90 days

Compositional Analysis of 

Dissolved Gas in Water 

(including N2, CO2, O2, Ar, H2, 

He, CH4, C2H6, C3H8, iC4H10, 

nC4H10, iC5H12, nC5H12, and 

C6+)

1-L dissolved gas 

bottle or flask

Benzalkonium chloride capsule, Cool 

4°C

90 days

Radon (

222Rn) 1.25-L PETE Pre-concentrate into 20-mL

scintillation cocktail. Maintain

groundwater temperature prior to preconcentration

1 day

pH Field parameter None <1 h

SpecificConductance Field parameter None <1 h

HDPE = high-density polyethylene; PETE = polyethylene terephthalate
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E18 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 7. Analytical requirements. 

Parameter Analysis Method

Detection 

Limit or 

Range

Typical 

Precision/ 

Accuracy QC Requirements

A.1.1 Major Cations: Al, Ba,

Ca, Fe, K, Mg,

A.1.2 Mn, Na, Si,

A.1.3 ICP-AES, EPA Method 6010B or 

similar

A.1.4 1 to 80 μg/L

(analyte

dependent)

A.1.5 ±10%A.1.6 Daily calibration; blanks, LCS, 

and duplicates and matrix 

spikes at 10% level per batch 

of 20

A.1.7 Trace Metals: Sb, As,

Cd, Cr, Cu, Pb, Se, Tl

A.1.8 ICP-MS, EPA Method 6020 or 

similar

A.1.9 0.1 to 2 μg/L 

(analyte 

dependent)

A.1.10 ±10%A.1.11 Daily calibration; blanks, LCS, 

and duplicates and matrix 

spikes at 10% level per batch 

of 20

A.1.12 Cyanide (CN-)A.1.13 SW846 9012A/B A.1.14 5 μA.1.15 g/L ±10%A.1.16 Daily calibration; blanks, LCS, 

and duplicates at 10% level per 

batch of 20

A.1.17 Mercury A.1.18 CVAA SW846 7470A A.1.19 0.2 A.1.20 μg/L ±20%A.1.21 Daily calibration; blanks, LCS, 

and duplicates and matrix 

spikes at 10% level per batch 

of 20

A.1.22 Anions: Cl-, Br-, F

-

,

SO4

2-

, NO3

-

A.1.23 Ion Chromatography, EPA Method 

300.0A or similar

A.1.24 33 to 133 

μg/L (analyte 

dependent)

A.1.25 ±10%A.1.26 Daily calibration; blanks, LCS, 

and duplicates at 10% level per 

batch of 20

A.1.27 Total and Bicarbonate 

Alkalinity (as CaCO3

2-

)

A.1.28 Titration, Standard Methods 2320B A.1.29 1 mg/L ±10%A.1.30 Daily calibration; blanks, LCS, 

and duplicates at 10% level per 

batch of 20

A.1.31 Gravimetric Total

Dissolved Solids (TDS

A.1.32 Gravimetric Method Standard 

Methods 2540C

A.1.33 10 mg/L A.1.34 ±10%A.1.35 Balance calibration, duplicate 

samples

A.1.36 Water DensityA.1.37 ASTM D5057 0.01 g/mL A.1.38 ±10%A.1.39 Balance calibration, duplicate 

samples

A.1.40 Total Inorganic Carbon

(TIC)

A.1.41 SW846 9060A or equivalent

A.1.42 Carbon analyzer, phosphoric acid 

digestion of TIC

A.1.43 0.2 mg/L A.1.44 ±20%A.1.45 Quadruplicate analyses, daily 

calibration

A.1.46 Dissolved Inorganic

Carbon (DIC)

A.1.47 SW846 9060A or equivalent

A.1.48 Carbon analyzer, phosphoric acid 

digestion of DIC

A.1.49 0.2 mg/L A.1.50 ±20%A.1.51 Quadruplicate analyses, daily 

calibration

A.1.52 Total Organic Carbon

(TOC)

A.1.53 SW846 9060A or equivalent

Total organic carbon is converted to 

carbon dioxide by chemical 

oxidation of the organic carbon in the 

sample. The carbon dioxide is 

measured using a non-dispersive 

infrared detector.

A.1.54 0.2 mg/L A.1.55 ±20%A.1.56 Quadruplicate analyses, daily 

calibration

A.1.57 Dissolved Organic

Carbon (DOC)

A.1.58 SW846 9060A or equivalent

A.1.59 Total organic carbon is converted to 

carbon dioxide by chemical 

oxidation of the organic carbon in the 

sample. The carbon dioxide is

measured using a non-dispersive 

infrared detector.

A.1.60 0.2 mg/L A.1.61 ±20%A.1.62 Quadruplicate analyses, daily 

calibration

A.1.63 Volatile Organic 

Analysis (VOA)

A.1.64 SW846 8260B or equivalent

A.1.65 Purge and Trap GC/MS

A.1.66 0.3 to 15 A.1.67μg/L ±20%A.1.68 Blanks, LCS, spike, spike 

duplicates per batch of 20

A.1.69 Methane A.1.70 RSK 175 Mod

A.1.71 Headspace GC/FID

A.1.72 10 μg/L A.1.73 ±20%A.1.74 Blanks, LCS, spike, spike 

duplicates per batch of 20

A.1.75 Stable Carbon Isotopes 

13/12C (113C) of DIC in 

Water

A.1.76 Gas Bench for 13/12C A.1.77 50 ppm of 

DIC

A.1.78 ±0.2p A.1.79 Duplicates and working 

standards at 10%
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E19 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Parameter Analysis Method

Detection 

Limit or 

Range

Typical 

Precision/ 

Accuracy QC Requirements

A.1.80 Radiocarbon 14C of DIC 

in Water

AMS for 14C A.1.81 Range: 0 i 

200 pMC

A.1.82 ±0.5 pMC A.1.83 Duplicates and working 

standards at 10%

A.1.84 Hydrogen and Oxygen 

Isotopes 2/1H (δ ) and 

18/16O (118O) of Water

A.1.85 CRDS H2O Laser A.1.86 Range: -

500‰ to 

200‰ vs. 

VSMOW

A.1.87 2/1H: ±2.0‰

A.1.88 18/16O: 

±0.3‰

A.1.89 Duplicates and working 

standards at 10%

A.1.90 Carbon and Hydrogen 

Isotopes (14C, 13/12C, 

2/1H) of Dissolved 

Methane in Water

A.1.91 Offline Prep & Dual Inlet IRMS for 

13C; AMS for 14C

A.1.92 14C Range: 0 

& DupMC

A.1.93 14C: 

±0.5pMC

A.1.94 13C: ±0.2‰

A.1.95 2/1H: ±4.0‰

A.1.96 Duplicates and working

standards at 10%

A.1.97 Compositional Analysis 

of Dissolved Gas in 

Water (including N2, 

CO2, O2, Ar, H2, He, 

CH4, C2H6, C3H8, 

iC4H10, nC4H10, iC5H12, 

nC5H12, and C6+)

A.1.98 Modified ASTM 1945D A.1.99 1 to 100 ppm 

(analyte 

dependent)

A.1.100 Varies by 

compon-ent

Duplicates and working 

standards at 10%

A.1.101 Radon (

222Rn)A.1.102 Liquid scintillation after preconcentration

A.1.103 5 mBq/L A.1.104 ±10%A.1.105 Triplicate analyses

A.1.106 pH A.1.107 pH electrode A.1.108 2 to 12 pH 

units

A.1.109 0.2 pH unit 

For 

indication 

only

A.1.110 User calibrate, follow 

manufacturer 

recommendations

A.1.111 SpecificConductance A.1.112 Electrode A.1.113 0 to 100 

mS/cm

A.1.114 1% of 

reading

For 

indication 

only

A.1.115 User calibrate, follow 

manufacturer 

recommendations

A.1.116 ICP-AES = inductively coupled plasma atomic emission spectrometry; ICP-MS = inductively coupled plasma mass 

spectrometry; LCS = laboratory control sample; GC/MS = gas chromatography–mass spectrometry; GC/FID = gas 

chromatography with flame ionization detector; AMS = accelerator mass spectrometry; CRDS = cavity ring down 

spectrometry; IRMS = isotope ratio mass spectrometry; LC-MS = liquid chromatography-mass spectrometry; ECD = electron 

capture detector

Laboratory to be used/chain-of-custody procedures:

Samples will be tracked using appropriately formatted chain-of-custody forms. The sample 

handling and chain of custody of water, formation fluids, and environmental gas or air samples 

will conform to EPA guidance, and be conducted as discussed in Sections B.1.3 and B.1.5 thru 

B.1.7 of the FutureGen QASP (Appendix G of the Testing and Monitoring Plan). 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E20 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Plan for guaranteeing access to all monitoring locations: 

The land on which the ACZ and USDW wells are located will either be purchased or leased for 

the life of the project, so access will be secured. 

Access to the surficial aquifer wells will not be required over the lifetime of the project. Access 

to wells for baseline sampling has been on a voluntary basis by the well owner. Nine local 

landowners agreed to have their surficial aquifer wells sampled although sampling is not 

anticipated in surficial wells during the PISC period. 

Carbon Dioxide Plume and Pressure-Front Tracking 

Direct Pressure Monitoring: 

FutureGen will conduct direct pressure-front monitoring to meet the requirements of 40 CFR 

146.93(b). Continuous monitoring of injection zone pressure and temperature (P/T) will be 

performed with sensors installed in wells that are completed in the injection zone. P/T monitoring 

in the monitoring wells will be performed using a real-time monitoring system with surface 

readout capabilities so that pressure gauges do not have to be removed from the well to retrieve 

data. 

The following measures will be taken to ensure that the pressure gauges are providing accurate 

information on an ongoing basis: 

• High-quality (high-accuracy, high-resolution) gauges with low drift characteristics will 

be used.

• Gauge components (gauge, cable head, cable) will be manufactured of materials designed 

to provide a long life expectancy for the anticipated downhole conditions. 

• Upon acquisition, a calibration certificate will be obtained for every pressure gauge. The 

calibration certificate will provide the manufacturer’s specifications for range, accuracy 

(% full scale), resolution (% full scale), drift (< psi per year), and calibration results for 

each parameter. The calibration certificate will also provide the date that the gauge was 

calibrated and the methods and standards used. 

• Gauges will be installed above any packers so they can be removed if necessary for 

recalibration by removing the tubing string. Redundant gauges may be run on the same 

cable to provide confirmation of downhole pressure and temperature. Pressure gauges will 

be calibrated on an annual basis with current annual calibration certificates provided with test 

results to the EPA. In lieu of removing the injection tubing, the calibration of downhole 

pressure gauges will demonstrate accuracy by using a second pressure gauge, with current 

certified calibration, that will be lowered into the well to the same depth as the permanent 

downhole gauge. Calibration curves, based on annual calibration checks (using the second 

calibrated pressure gauge) developed for the downhole gauge, can be used for the purpose of 

the fall-off test. If used, these calibration curves (showing all historic pressure deviations) 

will accompany the fall-off test data submitted to the EPA.
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E21 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

• Upon installation, all gauges will be tested to verify they are functioning 

(reading/transmitting) correctly. 

• Gauges will be pulled and recalibrated whenever a workover occurs that involves 

removal of tubing. A new calibration certificate will be obtained whenever a gauge is 

recalibrated.

Direct pressure monitoring in the injection zone will take place as indicated in Table 8.

Collection and recording of continuous monitoring data will occur at the frequencies described in 

Table 13. 

Table 8. Monitoring schedule for direct pressure-front tracking. 

Well Location/Map Reference Depth(s)/Formation(s) Frequency 

(Post-Injection Phase)

Two SLR monitoring wells (SLR 

Wells 1 and 2, see Figure 7)

Mount Simon/4,150 ft. Continuous

Note: For details and information on continuous monitoring, see Table 13.

Direct Geochemical Plume Monitoring: 

FutureGen will conduct direct CO2 plume monitoring to meet the requirements of 40 CFR 

146.93(b). Target parameters include pressure, temperature, and hydrogeochemical indicators of 

CO2 (Table 6) and brine composition. 

In addition to direct plume sampling and characterization, indirect montoring of the CO2 plume 

will be conducted by continuing the periodic PNC logging across the injection zone and primary 

confining zone. PNC logging is a proven method for quantifying CO2 saturation around a 

borehole. The PNC logging will be conducted using the three RAT wells. The RAT wells will be 

logged every 5 years during the post-injection period. Information collected will be compared with 

prior logs to determine trends. 

Direct fluid sampling in the injection zone will take place as indicated in 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E22 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 9 (collection and recording of continuous monitoring data will occur at the frequencies 

described in Table 13). 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E23 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 9. Monitoring schedule for direct geochemical plume monitoring. 

Monitoring well name/location/map reference: Two SLR monitoring wells (see Figure 7) 

Well depth/formation(s) sampled: Mount Simon Sandstone (4,150 ft)

Parameter/Analyte Frequency 

(Post-Injection Phase)

Dissolved or separate-phase CO2 Every 5 years

Pressure Continuous

Temperature Continuous

Other parameters, including major cations and anions, selected metals, 

and general water-quality parameters (pH, alkalinity, total dissolved 

solids, specific gravity)

Every 5 years

Note: For details and information on continuous monitoring, see Table 13.

Sampling methods: 

The FutureGen QASP and Testing and Monitoring Plan provide supplemental details about the 

sampling and analysis protocols for the direct fluid sampling that are outlined below. 

Fluid samples will be collected from the monitoring wells completed in the injection zone as 

detailed in Table 9 above. Fluid samples will be collected using an appropriate method to 

preserve the fluid sample at injection zone temperature and pressure conditions. Examples of 

appropriate methods include using a bomb-type sampler (e.g., Kuster sampler) after pumped or 

swabbed purging of the sampling interval, using a Westbay sampler, or using a pressurized Utube sampler (Freifeld et al. 2005). 

Fluid samples will be analyzed for parameters that are indicators of CO2 dissolution, including 

major cations and anions, selected metals, and general water-quality parameters (pH, alkalinity, 

TDS, specific gravity). Analysis of carbon and oxygen isotopes in injection zone fluids and the 

injection stream (13/12C, 18/16O) provides another potential supplemental measure of CO2

migration. Where stable isotopes are included as an analyte, data quality and detectability will be 

reviewed throughout the active injection phase, and upon the UIC Program Director’s approval, 

will be discontinued if these analyses provide limited benefit. Sampling and analytical 

requirements for target parameters are listed in Table 10 and Table 11, respectively. 

Laboratory to be used/chain-of-custody procedures:

See FutureGen QASP Sections B.4.3 thru B.4.7.
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E24 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 10. Aqueous sampling requirements for target parameters. 

Parameter Volume/Container Preservation Holding

Time

Major Cations: Al, Ba, Ca,

Fe, K, Mg, Mn, Na, Si,

20-mL plastic vial Filtered (0.45 μm), HNO3 to pH <2 60 days

Trace Metals: Sb, As, Cd,

Cr, Cu, Pb, Se, Tl

20-mL plastic vial Filtered (0.45 μm), HNO3 to pH <2 60 days

Cyanide (CN-) 250-mL plastic vial NaOH to pH > 12, 0.6g ascorbic acid 

Cool 4°C, 

14 days

Mercury 250-mL plastic vial Filtered (0.45 μm), HNO3 to pH <2 28 days

Anions: Cl-, Br-, F

-

, SO4

2-

,

NO3

-

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

Total and Bicarbonate 

Alkalinity (as CaCO3

2-

)

100-mL HDPE Filtered (0.45 μm), Cool 4°C 14 days

Gravimetric Total Dissolved

Solids (TDS)

250-mL plastic vial Filtered (0.45 μm), no preservation,

Cool 4°C

7 days

Water Density 100-mL plastic vial No preservation, Cool 4°C

Total Inorganic Carbon

(TIC)

250-mL plastic vial H2SO4 to pH <2, Cool 4°C 28 days

Dissolved Inorganic Carbon

(DIC)

250-mL plastic vial Filtered (0.45 μm), H2SO4 to pH <2, 

Cool 4°C

28 days

Total Organic Carbon (TOC) 250-mL amber glass Unfiltered, H2SO4 to pH <2, Cool 4°C 28 days

Dissolved Organic Carbon

(DOC)

125-mL plastic vial Filtered (0.45 μm), H2SO4 to pH <2, 

Cool 4°C

28 days

Volatile Organic Analysis 

(VOA)

Bottle set 1: 3-40-mL 

sterile clear glass 

vials

Bottle set 2: 3-40-mL 

sterile amber glass 

vials 

Zero headspace, Cool <6 °C, Clear 

glass vials will be UV-irradiated for 

additional sterilization

7 days

Methane Bottle set 1: 3-40-mL 

sterile clear glass 

vials

Bottle set 2: 3-40-mL 

sterile amber glass 

vials

Zero headspace, Cool <6 °C, Clear 

glass vials (bottle set 1) will be UVirradiated for additional sterilization

7 days

Stable Carbon Isotopes 13/12C 

(δ

13C) of DIC in Water

60-mL plastic or 

glass

Filtered (0.45-μm), Cool 4°C 14 days

Radiocarbon 14C of DIC in 

Water

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

Hydrogen and Oxygen 

Isotopes 2/1H (δD) and 

60-mL plastic or glass Filtered (0.45-μm), Cool 4°C 45 days
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E25 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Parameter Volume/Container Preservation Holding

Time

18/16O (δ18O) of Water

Carbon and Hydrogen 

Isotopes (14C, 13/12C, 2/1H) of 

Dissolved Methane in Water

1-L dissolved gas 

bottle or flask

Benzalkonium chloride capsule, Cool 

4°C

90 days

Compositional Analysis of 

Dissolved Gas in Water 

(including N2, CO2, O2, Ar, 

H2, He, CH4, C2H6, C3H8, 

iC4H10, nC4H10, iC5H12, 

nC5H12, and C6+)

1-L dissolved gas 

bottle or flask

Benzalkonium chloride capsule, Cool 

4°C

90 days

Radon (

222Rn) 1.25-L PETE Pre-concentrate into 20-mL

scintillation cocktail. Maintain

groundwater temperature prior to preconcentration

1 day

pH Field parameter None <1 h

SpecificConductance Field parameter None <1 h

HDPE = high-density polyethylene; PETE = polyethylene terephthalate
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E26 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 11. Analytical requirements. 

Parameter Analysis Method

Detection 

Limit or 

Range

Typical 

Precision/ 

Accuracy QC Requirements

A.1.117 Major Cations: Al, Ba,

Ca, Fe, K, Mg,

A.1.118 Mn, Na, Si,

A.1.119 ICP-AES, EPA Method 6010B or 

similar

A.1.120 1 to 80 μg/L

(analyte

dependent)

A.1.121 ±10%A.1.122 Daily calibration; blanks, LCS, 

and duplicates and matrix 

spikes at 10% level per batch 

of 20

A.1.123 Trace Metals: Sb, As,

Cd, Cr, Cu, Pb, Se, Tl

A.1.124 ICP-MS, EPA Method 6020 or 

similar

A.1.125 0.1 to 2 μg/L 

(analyte 

dependent)

A.1.126 ±10%A.1.127 Daily calibration; blanks, LCS, 

and duplicates and matrix 

spikes at 10% level per batch 

of 20

A.1.128 Cyanide (CN-)A.1.129 SW846 9012A/B A.1.130 5 μA.1.131 g/L ±10%A.1.132 Daily calibration; blanks, LCS, 

and duplicates at 10% level per 

batch of 20

A.1.133 Mercury A.1.134 CVAA SW846 7470A A.1.135 0.2 A.1.136 μg/L ±20%A.1.137 Daily calibration; blanks, LCS, 

and duplicates and matrix 

spikes at 10% level per batch 

of 20

A.1.138 Anions: Cl-, Br-, F

-

,

SO4

2-

, NO3

-

A.1.139 Ion Chromatography, EPA Method 

300.0A or similar

A.1.140 33 to 133 

μg/L (analyte 

dependent)

A.1.141 ±10%A.1.142 Daily calibration; blanks, LCS, 

and duplicates at 10% level per 

batch of 20

A.1.143 Total and Bicarbonate 

Alkalinity (as CaCO3

2-

)

A.1.144 Titration, Standard Methods 2320B A.1.145 1 mg/L ±10%A.1.146 Daily calibration; blanks, LCS, 

and duplicates at 10% level per 

batch of 20

A.1.147 Gravimetric Total

Dissolved Solids (TDS

A.1.148 Gravimetric Method Standard 

Methods 2540C

A.1.149 10 mg/L A.1.150 ±10%A.1.151 Balance calibration, duplicate 

samples

A.1.152 Water DensityA.1.153 ASTM D5057 0.01 g/mL A.1.154 ±10%A.1.155 Balance calibration, duplicate 

samples

A.1.156 Total Inorganic Carbon

(TIC)

A.1.157 SW846 9060A or equivalent

A.1.158 Carbon analyzer, phosphoric acid 

digestion of TIC

A.1.159 0.2 mg/L A.1.160 ±20%A.1.161 Quadruplicate analyses, daily 

calibration

A.1.162 Dissolved Inorganic

Carbon (DIC)

A.1.163 SW846 9060A or equivalent

A.1.164 Carbon analyzer, phosphoric acid 

digestion of DIC

A.1.165 0.2 mg/L A.1.166 ±20%A.1.167 Quadruplicate analyses, daily 

calibration

A.1.168 Total Organic Carbon

(TOC)

A.1.169 SW846 9060A or equivalent

Total organic carbon is converted to 

carbon dioxide by chemical 

oxidation of the organic carbon in the 

sample. The carbon dioxide is 

measured using a non-dispersive 

infrared detector.

A.1.170 0.2 mg/L A.1.171 ±20%A.1.172 Quadruplicate analyses, daily 

calibration

A.1.173 Dissolved Organic

Carbon (DOC)

A.1.174 SW846 9060A or equivalent

A.1.175 Total organic carbon is converted to 

carbon dioxide by chemical 

oxidation of the organic carbon in the 

sample. The carbon dioxide is 

measured using a non-dispersive 

infrared detector.

A.1.176 0.2 mg/L A.1.177 ±20%A.1.178 Quadruplicate analyses, daily 

calibration

A.1.179 Volatile Organic 

Analysis (VOA)

A.1.180 SW846 8260B or equivalent

A.1.181 Purge and Trap GC/MS

A.1.182 0.3 to 15 A.1.183 μg/L ±20%A.1.184 Blanks, LCS, spike, spike 

duplicates per batch of 20

A.1.185 Methane A.1.186 RSK 175 Mod

A.1.187 Headspace GC/FID

A.1.188 10 μg/L A.1.189 ±20%A.1.190 Blanks, LCS, spike, spike 

duplicates per batch of 20

A.1.191 Stable Carbon Isotopes 

13/12C (113C) of DIC in 

Water

A.1.192 Gas Bench for 13/12C A.1.193 50 ppm of 

DIC

A.1.194 ±0.2p A.1.195 Duplicates and working 

standards at 10%
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E27 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Parameter Analysis Method

Detection 

Limit or 

Range

Typical 

Precision/ 

Accuracy QC Requirements

A.1.196 Radiocarbon 14C of DIC 

in Water

AMS for 14C A.1.197 Range: 0 i 

200 pMC

A.1.198 ±0.5 pMC A.1.199 Duplicates and working 

standards at 10%

A.1.200 Hydrogen and Oxygen 

Isotopes 2/1H (δ ) and 

18/16O (118O) of Water

A.1.201 CRDS H2O Laser A.1.202 Range: -

500‰ to 

200‰ vs. 

VSMOW

A.1.203 2/1H: ±2.0‰

A.1.204 18/16O: 

±0.3‰

A.1.205 Duplicates and working 

standards at 10%

A.1.206 Carbon and Hydrogen 

Isotopes (14C, 13/12C, 

2/1H) of Dissolved 

Methane in Water

A.1.207 Offline Prep & Dual Inlet IRMS for 

13C; AMS for 14C

A.1.208 14C Range: 0 

& DupMC

A.1.209 14C: 

±0.5pMC

A.1.210 13C: ±0.2‰

A.1.211 2/1H: ±4.0‰

A.1.212 Duplicates and working 

standards at 10%

A.1.213 Compositional Analysis 

of Dissolved Gas in 

Water (including N2, 

CO2, O2, Ar, H2, He, 

CH4, C2H6, C3H8, 

iC4H10, nC4H10, iC5H12, 

nC5H12, and C6+)

A.1.214 Modified ASTM 1945D A.1.215 1 to 100 ppm 

(analyte 

dependent)

A.1.216 Varies by 

compon-ent

Duplicates and working 

standards at 10%

A.1.217 Radon (

222Rn)A.1.218 Liquid scintillation after preconcentration

A.1.219 5 mBq/L A.1.220 ±10%A.1.221 Triplicate analyses

A.1.222 pH A.1.223 pH electrode A.1.224 2 to 12 pH 

units

A.1.225 0.2 pH unit 

For 

indication 

only

A.1.226 User calibrate, follow 

manufacturer 

recommendations

A.1.227 SpecificConductance A.1.228 Electrode A.1.229 0 to 100 

mS/cm

A.1.230 1% of 

reading

For 

indication 

only

A.1.231 User calibrate, follow 

manufacturer 

recommendations

A.1.232 ICP-AES = inductively coupled plasma atomic emission spectrometry; ICP-MS = inductively coupled plasma mass 

spectrometry; LCS = laboratory control sample; GC/MS = gas chromatography–mass spectrometry; GC/FID = gas 

chromatography with flame ionization detector; AMS = accelerator mass spectrometry; CRDS = cavity ring down 

spectrometry; IRMS = isotope ratio mass spectrometry; LC-MS = liquid chromatography-mass spectrometry; ECD = electron 

capture detector
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E28 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Indirect Carbon Dioxide Plume and Pressure-Front Tracking 

FutureGen will track the CO2 plume and pressure front to meet the requirements of 40 CFR 

146.93(b) using integrated deformation monitoring and passive seismic monitoring. 

The frequency of indirect plume and pressure-front monitoring activities during the postinjection phase, is given in Table 12 (collection and recording of continuous monitoring data will 

occur at the frequencies described in Table 13). The coordinates of the monitoring wells/stations 

are provided in Appendix C of this Plan. 

Table 12. Monitoring schedule for indirect plume and pressure-front monitoring. 

Monitoring Technique Location Frequency 

(Post-Injection Phase)

Integrated deformation monitoring 5 locations (see Figure 7) Continuous

Passive seismic monitoring 

(microseismicity)

Surface measurements (see Figure 7) 

plus downhole sensor arrays at ACZ 

Wells 1 and 2

Continuous

Integrated deformation monitoring

Integrated deformation monitoring integrates ground data from permanent Global Positioning 

System (GPS) stations, and tiltmeters, supplemented with annual Differential GPS (DGPS) 

surveys, and larger-scale Differential Interferometric Synthetic Aperture Radar (DInSAR) 

surveys to detect and map temporal ground-surface deformation. These data reflect the dynamic 

geomechanical behavior of the subsurface in response to CO2 injection. These measurements 

will provide useful information about the evolution and symmetry of the pressure front. These 

results will be compared with model predictions throughout the operational phase of the project 

and significant deviation in observed response would result in further action, including a detailed 

evaluation of the observed response, calibration/refinement of the numerical model, and possible 

modification to the monitoring approach and/or storage site operations. Integrated deformation 

monitoring will take place at the locations shown in Figure 7. 

Passive seismic monitoring (microseismicity) 

The objective of the microseismic monitoring network (Figure 7; five stations and downhole 

arrays in the two ACZ wells) is to accurately determine the locations, magnitudes, and focal 

mechanisms of any potential injection-induced seismic events with the primary goals of 1) 

addressing public and stakeholder concerns related to induced seismicity, 2) estimating the 

spatial extent of the pressure front from the distribution of any potential seismic events, and 3) 

identifying features that may indicate areas of caprock failure and possible containment loss. 

The Emergency and Remedial Response Plan (Attachment F to this permit) provides additional 

information about seismic monitoring). 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E29 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

Table 13. Sampling and Recording Frequencies for Continuous Monitoring.

Well Condition

Minimum sampling 

frequency: once every

Minimum recording 

frequency: once every

For operating injection wells that are required to 

monitor continuously: 5 seconds 5 minutes 1

For injection wells that are shut-in: 4 hours 4 hours

For monitoring wells (USDW, ACZ, SLR): 30 minutes 2 hours

1 This can be an average of the sampled readings over the previous 5-minute recording interval, or the maximum 

(or minimum, as appropriate) value identified over that recording interval

Notes:

Sampling frequency refers to how often the monitoring device obtains data from the well for a particular 

parameter. For example, a recording device might sample a pressure transducer monitoring injection pressure 

once every two seconds and save this value in memory.

Recording frequency refers to how often the sampled information gets recorded to digital format (such as a 

computer hard drive). Following the same example above, the data from the injection pressure transducer might 

be recorded to a hard drive once every minute.

Proposed Schedule for Submitting Post-Injection Monitoring Results

During the PISC period, monitoring reports will be prepared and submitted to the EPA Region 5 

UIC office annually. The reports will summarize methods and results of the groundwater-quality 

monitoring, CO2 storage zone pressure tracking, and indirect geophysical monitoring for CO2

plume tracking. See Table 14. 

Table 14. Post-injection phase reporting schedule. 

Planned Testing/Monitoring Reporting Schedule

Groundwater Quality Monitoring Data Annual

Carbon Dioxide Plume and Pressure-Front 

Tracking Data

Annual

Direct Pressure Monitoring Data Annual

Indirect Carbon Dioxide Plume and PressureFront Tracking Data

Annual

The PISC and Site Closure Plan will be reviewed every 5 years during the PISC period (e.g., 

concurrent with or as a result of 5-year reevaluations of the AoR). Results of the plan review will 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E30 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

be included in the PISC monitoring reports. Monitoring and operational results will be reviewed 

for adequacy in relation to the objectives of PISC monitoring. The monitoring locations, 

methods, and schedule will be analyzed in relation to the size of the CO2 storage zone, pressure 

front, and protection of USDWs. In case of changes to the PISC plan, a modified plan will be 

submitted to the EPA Region 5 UIC Branch Office for not less than 30 days prior to the planned 

intiation of the changes. 

Alternative Post-Injection Site Care Time Frame 

FutureGen is not requesting an alternative PISC time frame. As indicated in Section O(6)(b)(v) 

of this permit, the permittee shall continue to conduct post-injection site monitoring for at least 

50 years or for the duration of any alternative timeframe approved pursuant to 40 CFR 146.93(c).

Non-Endangerment Demonstration Criteria 

Prior to approval of the end of the PISC period, FutureGen will submit a demonstration of nonendangerment of USDWs to the UIC Program Director (40 CFR 146.93(b)(3)). 

FutureGen will issue a report to the UIC Program Director. This report will make a 

demonstration of USDW non-endangerment based on the evaluation of the site monitoring 

data used in conjunction with the project’s computational model. The report will include 

information detailing how the non-endangerment demonstration evaluation uses site-specific 

conditions to confirm and demonstrate non-endangerment. The report will include all relevant 

monitoring data and interpretations upon which the non-endangerment demonstration is based 

and any other information necessary for the UIC Program Director to replicate the analysis.

The report will include the sections discussed below. 

Summary of Existing Monitoring Data

A summary of all previous monitoring data at the site, including data collected during the 

injection and PISC phases of the project, will be submitted to help demonstrate nonendangerment. Data submittals will be in a format acceptable to the UIC Program Director (40 

CFR 146.91(e)), and will include a narrative explanation of monitoring activities, including the 

dates of all monitoring events, changes to the monitoring program over time, and an 

explanation of all monitoring infrastructure that has existed at the site. 

Comparison of Monitoring Data and Model Predictions and Model Documentation

The results of computational modeling used for AoR delineation will be compared to 

monitoring data collected during the operational and the PISC period. Monitoring data will also 

be compared with baseline data collected during site characterization, per 40 CFR 146.82(a)(6) 

and 146.87(d)(3). The data used to update the computational model and to monitor the site will 

include both direct (e.g., temporal measurements of pressure, temperature, groundwater 

quality, and injection zone fluid composition) and indirect geophysical methods (e.g., passive 

seismic and integrated deformation monitoring, PNC logging). Data generated during the PISC 
Post-Injection Site Care and Site Closure Plan for FutureGen Alliance Page E31 of 64 

Permit Number: IL-137-6A-0003 (Well #3) 

period will be used to show that the computational model accurately represents the storage site 

and can be used as a proxy to determine the plume’s properties and size. FutureGen will 

demonstrate this degree of accuracy by comparing the monitoring data obtained during the 

PISC period against the model’s predicted properties (i.e., plume location, rate of movement, 

and pressure decay). Statistical methods will be employed to correlate the data and confirm the 

model’s ability to accurately represent the storage site. The validation of the computational 

model with the large volume of available data will be a significant element to support the nonendangerment demonstration. Further, the validation of the complete model over the areas, 

and at the points, where direct data collection has taken place will ensure confidence in the 

model for those areas where surface infrastructure preclude geophysical data collection and 

where there are no direct observation wells. 

Evaluation of Carbon Dioxide Plume

FutureGen will use a combination of monitoring data, logs, geophysical surveys, and seismic 

methods to locate and track the movement of the CO2 plume. The data produced by these 

activities will be compared against the modeled predictions (see Figure 6) using statistical 

methods to validate the model’s ability to accurately represent the storage site. Regarding the 

separate-phase carbon dioxide plume, the PISC monitoring data will show the stabilization of 

the CO2 plume as the reservoir pressure returns to its near pre-injection state. For the separatephase carbon dioxide plume, the risk to USDWs will decrease when the extent of pure-phase 

carbon dioxide ceases to grow either laterally or vertically. The stabilization of the plume 

combined with the lack of local penetrations of the confining formation will be significant 

factors in FutureGen’s demonstration of non-endangerment. Furthermore, FutureGen’s 

monitoring wells screened above the confining layer may be used to determine aqueous-phase 

concentrations of carbon dioxide and mobilized constituents in order to assess USDW 

endangerment. If a demonstration can be made, in conjunction with monitoring data, that a 

vast majority of the carbon dioxide has been immobilized via trapping mechanisms, this is 

strong evidence that the risk to USDWs posed by the carbon dioxide plume has decreased. 

Modeling may also be used to estimate future plume migration. Modeling results, including 

sensitivity analyses, may be used to demonstrate that plume migration rates are negligible 

based on available site characterization, monitoring, and operational data. 

Evaluation of Mobilized Fluids

In addition to carbon dioxide, mobilized fluids may pose an ongoing risk to USDWs. These 

include native fluids that are high in TDS and therefore may impair a USDW, and fluids 

containing mobilized drinking water contaminants (e.g., arsenic, mercury, hydrogen sulfide). 

The geochemical data collected from monitoring wells will be used to demonstrate that no 

mobilized fluids have moved above the confining formation and, therefore after the PISC 

period, would not pose a risk to USDWs. Of particular importance are any monitoring wells 

that are screened above the primary confining zone, within any USDWs, and in the vicinity of 

any known leakage pathways. Monitoring data indicating steady or decreasing trends of 

potential drinking water contaminants below actionable levels (e.g., secondary and maximum 

contaminant levels) will be used for this demonstration. In order to demonstrate nonendangerment, FutureGen will compare the operational and PISC period samples of the 
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lowermost USDW against the pre-injection baseline samples. This comparison will show that 

no significant changes have occurred in the fluid properties of the overlying formations. This 

will demonstrate that no mobilized formation fluids have moved through the confining 

formation. This validation of confining zone integrity will demonstrate that the injectate and/or 

mobilized fluids would not represent an endangerment to any USDWs. 

Evaluation of Reservoir Pressure

FutureGen will also demonstrate non-endangerment to USDWs by showing that during the 

PISC period, the pressure within the Mount Simon rapidly decreases to its near pre-injection 

static reservoir pressure. Because the increased pressure is the primary driving force for fluid 

movement that may endanger a USDW, the decay in the pressure differentials will provide 

strong justification that the injectate no longer poses a risk to any USDWs. 

FutureGen will monitor the downhole reservoir pressure at various locations and intervals using 

a combination of surface and downhole pressure gauges. The measured pressure at a specific 

depth interval will be compared against the pressure predicted by the computational model (see 

Figures 1 and 2). Agreement between the actual and the predicted values will validate the 

accuracy of the model and further demonstrate non-endangerment. 

Evaluation of Potential Conduits for Fluid Movement

Other than the project and monitoring wells, other distant potential conduits for fluid movement, 

or leakage pathways within the AoR are adequately constructed and/or plugged. Based on this 

information, the potential for fluid movement through artificial penetrations of the confining 

formation does not present a risk of endangerment to any USDWs. 

Evaluation of Passive Seismic Data

Seismic monitoring will be used to further demonstrate confining formation integrity. 

FutureGen will provide seismic monitoring data showing that no seismic events have occurred 

that would indicate fracturing or fault activation near or through the confining formation. This 

validation of confining zone integrity will provide further support to demonstrate that the CO2

plume is no longer an endangerment to any USDWs, by indicating that the response to the 

imposed fluid pressures due to injection are confined to the vicinity of the injection zone and 

below. 

Site Closure Plan 

FutureGen will conduct site closure activities to meet the requirements of 40 CFR 146.93(e). 

Site closure will occur at the end of the PISC period. Site closure activities will include 

decommissioning surface equipment, plugging monitoring wells, restoring the site, and preparing 

and submitting site closure reports. 

The EPA Region 5 UIC Branch Office will be notified at least 120 days before site closure. In 

addition, state and local agencies including the Illinois State Geological Survey and Illinois 
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Department of Natural Resources, as well as City of Jacksonville and Morgan County agencies 

will be notified prior to the scheduled site closure. At this time, there are no federally recognized 

Native American Tribes located within the AoR or the State of Illinois. If a federally recognized 

Native American Tribe exists in the AoR or the State of Illinois at the time of site closure, it will 

be notified of site closure at that time. 

A revised site closure plan will be submitted to the EPA Region 5 UIC Branch Office and state 

and local (and tribal) governmental agencies, if any changes have been made to the original site 

closure plan. After site closure is authorized, site closure field activities will be completed. 

Planned Remedial/Site Restoration Activities 

At the end of the PISC phase, FutureGen will ensure the site is reclaimed and returned to 

predevelopment condition to meet the requirements of 40 CFR 146.93(e). 

Surface equipment decommissioning will occur in two phases: the first phase will occur after the 

active injection phase, and the second phase will occur at the end of PISC phase. The surface 

facilities at the storage site will include the Site Control Building and the APS (Annulus 

Pressurization System) Building. 

At the end of the active injection period, plume monitoring will continue, but there will be no 

further need for the pumping and control equipment. The Site Control Building will be 

demolished. All features will be removed except the APS Building, a 12-ft-wide access road with 

five parking spaces, a concrete sidewalk from the parking lot to the building, underground 

electrical and telephone services, and a chain-link fence surrounding the building. The common 

wall between the APS Building and the Site Control Building will be converted to an exterior 

wall. The injection wells will be plugged and capped below grade (see the Injection Well 

Plugging Plan in Attachment D of this permit). The gravel pad will be removed. The APS 

Building at the storage site will be repurposed to act as the collection node for data from the 

plume monitoring equipment. The building will contain equipment to receive real-time data from 

the monitoring wells and other monitoring stations and send the data via an internet connection 

to be analyzed offsite during the 50-year post-injection monitoring period. 

All surface facilities will be removed at the end of the PISC phase. These facilities will include 

the APS Building, the access road with parking spaces, all sidewalks, underground electrical and 

telephone services, and fencing at the injection well sites. The site will be reclaimed and returned 

to predevelopment condition. 

Soil will be backfilled around the monitoring and geophysical wells to bring the area around the 

wells back to pre-well-installation grade. Any remaining surface facilities associated with the 

monitoring well will be reclaimed and the area will be returned to predevelopment condition. All 

gravel pads, access roads, and surface facilities will be removed, and the land will be reclaimed 

for agricultural or other beneficial pre-construction uses. 
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Plugging the Monitoring Wells 

Upon conclusion of the post-injection site care period (~50 years), all monitoring wells will be 

plugged and capped below grade in accordance with the approved monitoring well Plugging and 

Abandonment Plans (see Appendix E of this Plan). All deep monitoring wells at the site will be 

plugged to prevent any upward migration of the CO2 or formation fluids into USDWs. Each of 

the deep monitoring wells will be plugged and abandoned using best practices to prevent 

communication of fluids between the injection zone and USDWs. The deep monitoring wells in 

the injection interval have a direct connection between the injection formation and ground 

surface. The well-plugging program is designed to prevent communication between the injection 

zone and the USDWs. 

Before the wells are plugged, the internal and external integrity of the wells will be confirmed by 

conducting cement-bond, temperature, and noise logs on each of the wells. In addition, a 

pressure fall-off test will be performed above the perforated intervals (where present) to confirm 

well integrity. The results of the logging and testing will be reviewed and approved by 

appropriate regulatory agencies prior to plugging the wells. 

The wells with perforations (the SLR monitoring wells, the ACZ monitoring wells, and 

lowermost USDW monitoring well) will be plugged using a CO2-resistant cement retainer 

method to cement the perforated intervals and a balanced plug method to cement the well above 

the perforated zones and the cement retainer. The RAT monitoring wells will not have 

perforations; therefore, only the balanced plug method will be used to plug these wells. Once the 

interior of the casing has been properly plugged with cement, the casing will be cut off below 

ground and capped. Regulations at the time of the plugging and abandonment will dictate the 

specifications regarding the depth at which the casing is cut and the method used to cap the well. 

The cap will be inscribed with the well identification number and the date of plug and 

abandonment. 

Plugging the Geophysical Wells 

The FutureGen microseismic and deformation monitoring designs include five geophysical 

monitoring stations. Two types of well completions will be constructed at each of the five 

geophysical monitoring stations: both well types will be completed as sealed access tubes 

designed to support downhole installation of either microseismic or tiltmeter instrumention in a 

subsurface moisture free environment. Well construction and plugging schematics showing the 

exposed formation intervals, casing diameters, casing depths, depths to USDWs, and the 

placement of all plugs are presented for each well type in Figure 9. 
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Figure 9. Diagram of Microseismic and Tiltmeter Wells After Plugging and Abandonment. 

Upon conclusion of the post-injection site care period, all geophysical wells will be plugged and 

capped below grade in accordance with the approved monitoring well Plugging and 

Abandonment Plans (see Appendix E of this plan). All downhole instrumentation will be 

removed and each microseismic well casing and tiltmeter well casing will be plugged with 

cement to ensure that the well does not provide a conduit to the shallow USDW zone or ground 

surface. The procedures for plugging and abandoning both types of wells are very similar. 

However, cement volumes will differ depending upon the total depth of the well. 

For both well-completion designs, class A cement will be used to plug the well casing. The 

geophysical wells will not have perforations; therefore, the balanced plug method will be used to 

plug these wells. Once the interior of the casing has been properly plugged with cement, the 

casing will be cut off below ground and capped. Regulations at the time of the plugging and 

abandonment will dictate the specifications regarding the depth at which the casing is cut and the 

method used to cap the well. The cap will be inscribed with the well identification number and 

the date of plug and abandonment. 

The methods and materials described in this plan are based upon current understanding of the 

geology at the site and current well designs. If necessary, the plans will be updated to reflect the 

latest well designs. These new designs, materials, and methods will be described in the Notice of 

Intent to Plug submitted at least 60 days prior to the plugging of the wells. 

After the completion of the plugging activities, a plugging report will be submitted to the UIC 

Program Director describing the methods used and tests performed on the well during plugging. 

This report will be submitted to the UIC Program Director within 60 days of completing the 

plugging activities. 
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Site Closure Reporting 

A site closure report will be submitted to the EPA Region 5 UIC Branch Office and the 

previously notified state and local regulatory agencies within 90 days of site closure. The site 

closure report will include the following information: 

• Documentation of appropriate well plugging, including a survey plat of the injection well 

location; 

• Documentation of the well-plugging report to Illinois and local agencies that have 

authority over drilling activities at the facility site; and 

• Records reflecting the nature, composition, and volume of the CO2 injected in UIC wells. 

In association with site closure, a record of notation on the facility property deed will be added to 

provide any potential purchaser of the property with the following information: 

• Notification that the subsurface was used for CO2 storage; 

• The name of the Illinois and local agencies and the EPA Region 5 Branch Office to 

which the survey plat was submitted; and 

• The volume of fluid injected, the injection zone, and the period over which injection 

occurred. 

PISC and site closure records will be retained for 10 years after site closure. At the conclusion of 

the 10-year period, these records will be delivered to the EPA Region 5 UIC Branch Office for 

further storage. 
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APPENDIX A: Deep Monitoring Well Locations 

Well ID Well Type Latitude

(WGS84)

Longitude

(WGS84)

ACZ1 Above Confining Zone 1 39.80034315 -90.07829648

ACZ2 Above Confining Zone 2 39.80029543 -90.08801028

USDW1 Underground Source of Drinking Water 39.80048042 -90.0782963

SLR1 Single-Level in-Reservoir 1 39.8004327 -90.08801013

SLR2 Single-Level in-Reservoir 2 39.80680878 -90.05298062

RAT1 Reservoir Access Tube 1 39.80035565 -90.08627478

RAT2 Reservoir Access Tube 2 39.78696855 -90.06902677

RAT3 Reservoir Access Tube 3 39.79229199 -90.08901656
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APPENDIX B: Surficial Aquifer Monitoring Well Locations 

Well ID Well Type Latitude Longitude

FG-1 FutureGen Shallow Monitoring Well 39.80675 -90.05283

FGP-1 Private Well 39.79888 -90.0736

FGP-2 Private Well 39.78554 -90.0639

FGP-3 Private Well 39.79497 -90.0746

FGP-4 Private Well 39.79579 -90.0747

FGP-5 Private Well 39.81655 -90.0622

FGP-6 Private Well 39.81086 -90.057560

FGP-7 Private Well 39.81444 -90.065241

FGP-9 Private Well 39.80829 -90.0377

FGP-10 Private Well 39.81398 -90.0427
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APPENDIX C: Microseismic Monitoring and Integrated Deformation Station Locations

Well 

ID/Station ID Well/Station Type Latitude (WGS84)

Longitude

(WGS84)

MS1  Microseismic monitoring Station 1(shallow borehole)

 Integrated deformation monitoring station 39.8110768 -90.09797015

MS2  Microseismic monitoring Station 2 (shallow borehole)

 Integrated deformation monitoring station 39.78547402 -90.05028403

MS3  Microseismic monitoring Station 3 (shallow borehole)

 Integrated deformation monitoring station 39.81193502 -90.06016279

MS4  Microseismic monitoring Station 4 (shallow borehole)

 Integrated deformation monitoring station 39.78558513 -90.09557015

MS5  Microseismic monitoring Station 5 (shallow borehole)

 Integrated deformation monitoring station 39.80000524 -90.07830287

ACZ1  Deep microseismic station (deep borehole) 39.80034315 -90.07829648

ACZ2  Deep microseismic station (deep borehole) 39.80029543 -90.08801028
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APPENDIX D: Planned Construction Design and Plugging and Abandonment Plan 

Diagrams for Deep Monitoring Wells and Reservoir Access Tube Wells 
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Figure D-1. Construction design and plugging and abandonment plan for new 5.5-in.-diameter single-level 

in-reservoir monitoring well. 
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Figure D-2. Construction design and plugging and abandonment plan for 7-in.-diameter single-level inreservoir monitoring well to be reconfigured from the stratigraphic well. 
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Figure D-3. Construction design and plugging and abandonment plan for the Above Confining Zone 

monitoring wells. 
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Figure D-4. Construction design and plugging and abandonment plan for the USDW monitoring well. 
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Figure D-5. Construction design and plugging and abandonment plan for the reservoir access tube wells. 
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APPENDIX E:Plugging and Abandonment Plans for Deep Monitoring Wells, Reservoir 

Access Tube Wells, and Geophysical Wells 

Plugging and abandonment plans for the following monitoring wells are provided in this appendix: 

Monitoring wells 

 ACZ1 

 ACZ2 

 RAT1 

 RAT2 

 RAT3 

 SLR1-5.5" 

 SLR2-7" 

 USDW1 

Geophysical Wells 

 MS1 

 MS2 

 MS3 

 MS4 

 MS5 

 TM1 

 TM2 

 TM3 

 TM4 

 TM5 
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