FutureGenTM 

ALLIANCE 

Clean Energy for a Secure Future 

November 19,2013 

Rebecca Harvey 

Chief, Underground Injection Control Branch 

United States Environmental Protection Agency 

77 West Jackson Blvd 

Chicago,IL 60604-3590 

FutureGen Industrial Alliance, Inc. 

73 Central Park Plaza East 

Jacksonville, ll 62650 

www.FutureGenAIIiance.org 

Kenneth Humphreys 

Chief Executive Officer 

217-243-8215 

Subject: Request for Additional Information #1 Regarding, FutureGen Applications for UIC 

Permit nos. IL-137-6A-0001, -0002, -0003 & -0004, dated October 31,2013 

Dear Ms. Harvey, 

Please find enclosed one printed copy and one compact disc with an electronic copy of the 

Futw:eGen Alliance's responses to your Request for Additional Information (RAI #1) on the 

Futw:eGen Alliance's UIC applications dated October 31, 2013. 

Inquiries concerning the contents of the enclosure may be directed to Tyler Gilmore by telephone 

(509) 371-7171 or by email to tyler.gilmore@pnnl.gov. 

Sincerely, 

Mr. Kenneth Humphreys 

Chief Executive Office 

Futw:eGen Industrial Alliance, Inc. 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 1 of 30

 

10-31-2013: Letter from Rebecca Harvey (EPA) to Kenneth K. Humphreys (Alliance), “Request for Additional Information Regarding four FutureGen 2.0 Wells, United States Environmental Protection Agency Underground 

Injection Control (UIC) Permit Applications for Four Geologic Sequestration Wells; United States Environmental Protection Agency UIC Permit Nos. IL-137-6A-0001, -0002, -0003, & -0004

RAI # Subject Page Doc. Sec. Par. EPA Comment / Question / Request FutureGen Response Footnote / Reference Citation

10-31-2013_001 Seismic 

Reflection 

Survey

&

Vertical Seismic 

Profiling Data

2.26 2.3.1.1 1 “The Illinois State Geological Survey (ISGS) recently acquired a 

new 120-mi long seismic reflection survey across central 

Illinois as part of a DOE-sponsored research project to 

characterize reservoir rocks for geologic storage of carbon 

dioxide. The continuous east-west line extends from 

Meredosia to southwestern Champaign County (Figure 2.14). 

This line, which is currently under re-processing, will supply 

additional information about the structure of the sedimentary 

layers which will be correlated to the observations made on 

both profiles L101 and L201.”

“Future efforts at Morgan County will also include the 

acquisition of vertical seismic profiling data in the 

stratigraphic well to better evaluate the cause of the vertical 

disruptions in seismic reflections observed on the two existing 

seismic profiles.”

EPA: Have these tests been completed?

Please report the results.

A discussion regarding these specific requests is presented in Appendix A. A summary of the 

response is as follows:

(1) The current processed Knox line was reviewed by Dr. John McBride, Brigham Young University, 

and formerly of the ISGS. Dr. McBride is an expert in Illinois seismic data. Dr. McBride’s 

conclusion on the ISGS Knox line west of Ashland, Illinois, which is directly north of the proposed 

FutureGen storage site, is that there is no discernible faulting west of Ashland.

1

 Dr. McBride also 

suggested that current plans to reprocess the ISGS Knox line would not likely result in a greatly 

improved image.

2

As a result, the technical team has cancelled plans to reprocess the ISGS Knox 

Line. 

Dr. McBride’s interpretation of flat-lying, sedimentary layers with no major faults on the ISGS 

Knox Line west of Ashland correlates well with the technical team’s interpretation of similar 

conditions on the Morgan County two-dimensional (2D) profiles L101 and L201. 

(2) A three-component vertical seismic profiling (VSP) data set was acquired from the FutureGen 

stratigraphic well in March 2013 and processed by Schlumberger Carbon Services. Dr. Bob 

Hardage of the University of Texas concluded3that no faults are present in the 15 2D seismic 

lines formed by the 15 offset VSP locations. These lines represent a lateral interrogation extent 

of 800−1600 feet radially from the stratigraphic well. The VSP data also do not contain the 

disruptions observed in the two original 2D seismic profiles (L101 and L201) of the proposed 

storage site.

A second opinion evaluation of the vertical disruptions in the 2D Lines L101 and L201 was 

undertaken by Dr. John McBride, who concluded1 that although the presence of small throw 

faults cannot completely be ruled out, the seismic anomalies in the 2D lines are most likely 

related to incompletely removed surface static noise, or due to the application of suboptimal 

filters during processing.

1

Phone Conference of Battelle Technical 

Team with John McBride, September 16, 

2013. 

2 John McBride. Personal Communication 

with Charlotte Sullivan, October 29, 2013.

3

Bob Hardage, Personal Communication 

with Charlotte Sullivan, August 1, 2013. 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 2 of 30

10-31-2013: Letter from Rebecca Harvey (EPA) to Kenneth K. Humphreys (Alliance), “Request for Additional Information Regarding four FutureGen 2.0 Wells, United States Environmental Protection Agency Underground 

Injection Control (UIC) Permit Applications for Four Geologic Sequestration Wells; United States Environmental Protection Agency UIC Permit Nos. IL-137-6A-0001, -0002, -0003, & -0004

RAI # Subject Page Doc. Sec. Par. EPA Comment / Question / Request FutureGen Response Footnote / Reference Citation

10-31-2013_002 Mini-frac Tests

Leak-off Tests

2.30 2.4 3 “Various supportive geomechanical data were collected, but 

there are no available “mini-frac” or leak-off tests to directly 

measure fracture pressure in either the injection or confining 

zones. Mini-frac or leak-off data are required to definitively 

calculate site-specific fracture gradients, and to produce highconfidence failure plots, fault slip tendency estimates, and 

critical pore fluid pressure increase estimates. All of these 

tests will be realized in 2013 during the second phase of the 

project”

EPA: Have these tests been completed?

Please report the results.

(1) Geomechanical characterization testing is currently being conducted (November 2013) with first 

analysis results expected late December 2013 or early January 2014.

Geomechanical testing of the reservoir and basement rock is currently being conducted in the 

FutureGen stratigraphic well (November 2013). Testing involves a combination of Hydraulic 

Fracturing (HF) tests and Hydraulic Tests on Preexisting Fractures (HTPFs) that will be conducted in 

the existing, open-borehole section of the FutureGen stratigraphic well, to determine the state-ofstress at depth. Given the present situation in which the stratigraphic well is cased down to the 

Mount Simon Formation, the hydraulic testing in the Eau Claire Formation is postponed until the 

drilling of the injection pilot well.

The testing program is designed to provide a more comprehensive characterization of the variation in 

magnitude for the minimum principal stress within the Mount Simon sandstone, as well as the 

required knowledge for the stress gradient in the Precambrian basement. This level of 

geomechanical characterization within both rock formations is necessary for determining the 

maximum acceptable reservoir pressure during future CO2 injections.

(2) Additional Geomechanical Characterization Tests at the Injection well site (second quarter, 

2014) 

Pending issuance of a Underground Injection Control (UIC) permit, an injection well will be drilled at 

the proposed injection site. Additional geomechanical tests (HF tests and/or HTPFs) will be 

conducted in this well in the primary confining zone and in the injection zone.

10-31-2013_003 Triaxial CorePlug Tests2.31 2.4.2 1 “Uncalibrated geomechanical stress properties logs were 

calculated from the density log and the compressional and 

shear wave sonic log data. These geomechanical logs indicate 

there is strong stress anisotropy. These uncalibrated 

geomechanical logs will later have been calibrated over the 

cored interval with six triaxial core-plug tests.”

EPA: Has this analysis been completed?

If so, please report the results.

The triaxial core-plug tests’ results were provided to Schlumberger, who used them to calibrate the 

geomechanical log data. The original triaxial test data are provided in the Supporting Documentation 

for the Alliance's Class VI UIC permit applications (Tables 2.10 and 2.11). The resulting calibrated 

Schlumberger geomechanical logs still indicate strong anisotropy. However, only geomechanical field 

tests currently being conducted in the existing stratigraphic wellbore and planned in the Pilot Well 

will result in a quantification of the site stress regime.

10-31-2013_004 Horizontal 

Components of 

Stress

2.32 2.4.2.2 2 “Data are insufficient at this stage of analysis to be able to 

quantify the horizontal components of stress and thus 

distinguish between normal and strike-slip regimes.”

EPA: How will you obtain and when will you have 

sufficient data?

The data from the on-going borehole geomechanical tests (November 2013) include a combination of 

HF tests and of HTPFs, which are very well suited for identifying stress fields at depth (Cornet 1993; 

Haimson and Cornet 2003). The results will provide the data necessary to quantify the horizontal 

components of stress and be able to distinguish between extensional, compressional, and strike-slip 

regimes. The results of this testing will be provided to the U.S. Environmental Protection Agency 

(EPA) soon after they have been analyzed, which is anticipated to be in late December 2013 or early 

January 2014..

Cornet F.H.; 1993; The HTPF and the 

Integrated stress determination methods; 

Comprehensive Rock Engineering (Hudson 

ed.); Vol 3, ch. 15, pp 413-432 

Pergammon Press, Oxford.

Haimson B.C. and F.H. Cornet; 2003; ISRM 

Suggested Methods for rock stress 

estimation; Part III:Hydraulic fracturing 

methods ; Int. Jou. Rock. Mech. Min. Sc., 

vol. 40, 7/8, pp 1011-1020.

10-31-2013_005 New Knowledge 

About the Site

5.4 5.1.2 1 “As additional characterization data are collected, the site 

conceptual model will be revised and the modeling steps 

described above will be updated to incorporate new 

knowledge about the site”. i.e., they will add information to 

this section as it becomes available

EPA: When will this be done? 

The site conceptual model will be updated after key data collection efforts are completed or when 

new information becomes available that could substantially modify the conceptual model. This will 

be an on-going and iterative process over the life of the project. The next data collection effort, 

which may provide data that will update or modify the conceptual model, is the geomechanical 

testing in the stratigraphic well. Therefore, the next conceptual model update could occur following 

interpretation of the geomechanical data. We anticipate making that determination in early January

2014.
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 3 of 30

10-31-2013: Letter from Rebecca Harvey (EPA) to Kenneth K. Humphreys (Alliance), “Request for Additional Information Regarding four FutureGen 2.0 Wells, United States Environmental Protection Agency Underground 

Injection Control (UIC) Permit Applications for Four Geologic Sequestration Wells; United States Environmental Protection Agency UIC Permit Nos. IL-137-6A-0001, -0002, -0003, & -0004

RAI # Subject Page Doc. Sec. Par. EPA Comment / Question / Request FutureGen Response Footnote / Reference Citation

10-31-2013_006 Indirect 

Monitoring 

Approaches

5.8 5.1.4 1 “The location of any wells required to support implementation 

of indirect monitoring approaches will be determined once 

candidate technologies have been evaluated and the selection 

process completed.“ FutureGen has selected locations for the 

monitoring wells based on the preliminary modeling. Once 

they begin on-site activity, these locations may change. If the 

locations do change, the monitoring wells will retain the intent 

described in this plan.

EPA: When will these technologies be evaluated and 

when will any changes be proposed?

The screening of the indirect monitoring approaches was conducted as part of the Front End 

Engineering Design process. The selected indirect technologies will include the following:

 pulsed neutron capture logging or determination of reservoir CO2 saturation

 integrated deformation monitoring

 time-lapse gravity 

 microseismic monitoring. 

In addition, a baseline VSP survey in at least one of the “Above Caprock Zone” (ACZ) wells will be 

conducted after construction of the monitoring well network and if the EPA provides approval of the 

UIC permit application.

The monitoring well locations have been identified; however land owner agreements still need to be 

finalized. We anticipate that we will have the final agreements before the end of January, 2014 and 

can map the locations at that time.

10-31-2013_007 EPA Form 

7520-14

6 EPA Form 7520-14 (Plugging & Abandonment Plan) is 

missing.

EPA: Please provide for each well.

EPA Form 7520-14 has been completed for open-hole and cased-hole completions with laterals of 

1,500 ft and 2,500 ft (4 forms, in Appendix B). These forms were unintentionally missing in the UIC 

Permit Application and are being submitted with this response.

10-31-2013_008 EverCrete 

Cement 

Information

6 Information concerning the slurry volume and slurry weight 

of the EverCrete cement is needed

(1) The slurry volume (yield) is 1.12 ft3/sack.

(2) The slurry weight is 15.82 lb/gal.

(3) Lab analyses of the EverCRETE-5 cement blend and a technical report are also attached (Appendix 

C).

Note that the Alliance plans to use a Class H cement, and the product brand, EverCRETE-5, is an 

example of a class H cement.

10-31-2013_009 Casing & 

Retainer in 

Figure 6.2

6.5 6 In Figure 6.2, the 7” casing is set at 3400 feet, however a 

cement retainer will be at 3900 feet, which is below the cased 

hole.

EPA: Please correct.

The carbon-steel casing will be run to a depth of 3,400 ft and stainless steel casing will be run from 

3,400 ft to 3,950 ft. For clarity, an updated version of Figure 6.2 is attached in Appendix D. For 

consistency, Figures 4.4, 4.5, and 6.1 have also been updated and are provided in Appendix D. 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 4 of 30

10-31-2013: Letter from Rebecca Harvey (EPA) to Kenneth K. Humphreys (Alliance), “Request for Additional Information Regarding four FutureGen 2.0 Wells, United States Environmental Protection Agency Underground 

Injection Control (UIC) Permit Applications for Four Geologic Sequestration Wells; United States Environmental Protection Agency UIC Permit Nos. IL-137-6A-0001, -0002, -0003, & -0004

RAI # Subject Page Doc. Sec. Par. EPA Comment / Question / Request FutureGen Response Footnote / Reference Citation

10-31-2013_010 Financial 

Mechanisms

9.2 9 Table 9.1. Approach to Meeting Financial Responsibility 

Requirements – several financial mechanisms state that they 

are to be “Created prior to injection.” These must be 

established prior to drilling of the wells.

EPA: Please provide the mechanism to EPA.

As described in Chapter 9.0 of the Supporting Documentation for the Alliance's Class VI UIC permit 

applications, the Alliance intends to establish a CO2 Storage Trust Fund for the payment of costs 

related to any needed corrective actions as well as costs related to injection well plugging and postinjection site care and site closure. The Alliance intends to obtain third-party insurance for costs 

related to any required emergency and remedial response action.

The Alliance has selected a trustee for the CO2 Storage Trust Fund (U.S. Bank) and is actively working 

with the trustee to complete a trust agreement that includes the terms recommended by the EPA.

The Alliance will expedite these efforts and provide a schedule for completion of the trust agreement 

to the EPA at the earliest possible time.

With respect to third-party insurance, the Alliance is continuing to work with its insurance advisor to

obtain the necessary insurance for the drilling, injection, and post-injection phases of the FutureGen 

2.0 Project. During the drilling phase of the project, the potential to incur emergency and remedial 

response costs will be even less than the potential for such costs during the later injection and postinjection phases. For this reason, the Alliance is planning to purchase a pollution policy with a $10 

million limit for the drilling phase. This will contain coverage outlined in Appendix D to the 

Supporting Documentation (McGriff, Seibels & Williams, Inc., "Insurance Review to Support 

FutureGen Alliance's UIC Permit Application," September 2012). Prior to injection, the Alliance will 

increase the limits of this policy to at least $100 million. At that time, the Alliance will also purchase 

various other insurance policies including Control of Well and General Liability insurance and 

Umbrella/Excess coverage. The Alliance will provide updates to its insurance acquisition efforts as 

they become available.

The Alliance recognizes that, in accordance with 40 CFR 146.85(a)(5)(i), the EPA must approve 

financial responsibility demonstrations for all phases of the geologic sequestration project prior to 

the issuance of a Class VI permit. To this end, the Alliance will provide such demonstrations at the 

earliest opportunity. The Alliance may wish to discuss with the EPA representatives the 

documentation considered necessary to demonstrate financial responsibility for each phase of the 

project.

10-31-2013_011 Endangered 

Species Act

In accordance with 40 CFR 144.4 (c), the U. S. Environmental 

Protection Agency (EPA) is required to comply with the 

Endangered Species Act (ESA) when issuing permit decisions. 

Therefore, when considering a permit application, the 

Underground Injection Control (UIC) Branch must consider 

the potential impacts from the new or existing injection well 

to endangered species present in the area. In order to 

determine whether an injection well will adversely impact 

endangered and threatened species, the UIC branch must have 

location-specific ecological information, such as the presence 

of certain vegetation, soils or surface water bodies. The U. S. 

Fish and Wildlife Service has listed the following in Morgan 

County :

In siting the components of the FutureGen 2.0 Project, including the site for the four proposed 

injection wells, the Alliance has successfully avoided potential impacts on threatened or endangered 

species that are listed for Morgan County, Illinois (Indiana bat, decurrent false aster, and eastern 

prairie fringed orchid) and the critical habitats for these species. The U.S. Department of Energy 

(DOE) has also considered the potential impacts on these species, and other environmental 

resources, and documented its findings in its FutureGen 2.0 Environmental Impact Statement issued 

final in October 2013 (Final Environmental Impact Statement for the FutureGen 2.0 Project,

http://www.netl.doe.gov/publications/others/nepa/feis_1013.html) (The EPA rated the draft 

environmental impact statement as LO-1). With assistance from the Alliance, DOE submitted a 

Biological Assessment to the U.S. Fish and Wildlife Service (USFWS) in accordance with the 

Endangered Species Act that encompassed the entire project, power plant, pipeline, and injection 

wells. Recently, the USFWS concurred with DOE's conclusion that the FutureGen 2.0 Project as a 

whole, including the injection well site, could affect but is not likely to affect any of the threatened or 

endangered species in Morgan County. A copy of the USFWS letter is attached (Appendix E).

With respect to the EPA's specific requests:

a. The area proposed for the injection wells has been determined by the USFWS (Appendix E) to not 

contain any critical habitat for any threatened or endangered species..

b. The 9.5 acres that are expected to be disturbed during the construction of the injection wells, 

including the approximately 5 acres that will contain the four proposed injection wells, are primarily 

plowed fields. A small portion includes an unoccupied dwelling, which will be removed. A few trees 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 5 of 30

10-31-2013: Letter from Rebecca Harvey (EPA) to Kenneth K. Humphreys (Alliance), “Request for Additional Information Regarding four FutureGen 2.0 Wells, United States Environmental Protection Agency Underground 

Injection Control (UIC) Permit Applications for Four Geologic Sequestration Wells; United States Environmental Protection Agency UIC Permit Nos. IL-137-6A-0001, -0002, -0003, & -0004

RAI # Subject Page Doc. Sec. Par. EPA Comment / Question / Request FutureGen Response Footnote / Reference Citation

As a result, we are requiring the following information to be 

submitted in each permit application.

a. A summary of the critical habitat which, if present, 

may support one the above-listed species. Detailed 

information on critical habitat can be found at the 

following web address: 

http://www.fws.gov/midwest/endangered/section7/s7proce

ss/lifehistory.html

b. A survey of the surface vegetation, soils, topography 

and hydrologic features in the action area in 

sufficient detail to address the presence or absence 

of critical habitat for any endangered, threatened, or 

candidate species. This will include descriptions 

such as “mature mixed forest”, plowed field” or 

“stabilized dunes”, and may also include specific 

trees or plants listed as critical to a species.

and bushes are used as landscaping near the dwelling. As noted above, and in the attached USFWS 

consultation letter, the area has not been designated as critical habitat for any threatened or 

endangered species, and there will be no cutting of trees, which could provide summer habitat for 

listed bat species.
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 6 of 30

Appendix A 

RAI# 10-31-2013_001 

Additional Information Regarding 

Seismic Reflection Survey 

and 

Vertical Seismic Profiling Data 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 7 of 30

The following discussion addresses the specific request for additional information regarding 2D-seismic profiles 

and vertical seismic profiling data (RAI# 10-31-2013_001). 

We first present a review of the existing 2D seismic data, and a summary of the evaluation by outside seismic 

consultant, Dr. John McBride. Dr. McBride’s review includes both the Morgan County 2D data and of the western 

end the ISGS Knox line, which runs east-west through Cass County, about three miles north of our Line L201. We 

then review the status of new VSP data acquisition and a summary of the interpretation of the VSP data by outside 

seismic consultant, Dr. Bob Hardage. 

1. Introduction 

Subsurface data relative to seismic characterization of the Morgan County site include the following: 

 A total of fifteen miles of 2D-seismic data, acquired along line L101 and L201, processed and interpreted 

First Quarter, 2011; reprocessed Third Quarter, 2012. 

 A suite of well logs, including density and dipole sonic (for construction of synthetic seismograms), 

acquired in the FutureGen2.0 characterization well, Fourth Quarter, 2011. 

 15 offset VSP’s and a zero offset VSP, acquired in the characterization well, First Quarter, 2013. 

Figure 1 shows the locations where these data were acquired, relative to the stratigraphic well and the proposed 

injection well. 

Figure 1. Location of Seismic Data Acquired for Characterization of the Morgan County Site. 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 8 of 30

2. Review of 2D-Seismic Profiles 

2.1 FutureGen Site 2D Seismic Survey 

Two orthogonal seismic lines were acquired and processed across the FutureGen 2.0 sequestration site in Morgan 

County, Illinois, during the period January to February, 2011. Surface seismic data were acquired as singlecomponent data, so only P-P images have been made along Line 101 and Line 201 (Figure 1).

The original data exhibit vertical discontinuities with little to no offset, and a severe loss of frequency and 

resolution below a two-way time (TWT) depth of about 0.3 seconds (S), approximately coincident with the top of 

the Galena limestone at a depth of 1,400 feet. The original data were evaluated by Dr. Hardage1, who concluded 

that the discontinuities could be acquisition/processing artifacts or could be very small offset faults. In August, 

2012, these lines were reprocessed by Exploration Development, Inc., and re-evaluated by Dr. Hardage2

. Although 

the reprocessed data had less seismic noise, vertical discontinuities remained (Figure 2), especially at locations 

where the seismic lines crossed small streams. 

A second interpretation of the Morgan County 2D lines was provided by Dr. John McBride (geophysicist from 

Brigham Young University, formerly ISGS), “There are no large scale features in the Morgan County site data that 

cut into the shallow section, however it cannot be definitively determined that there are no faults in the Morgan 

County data. Some anomalies coincide with streams; others may be related to binning issues. Better static 

corrections may be required in order to determine if offsets in the shallow (0-400 ms) section are actual small faults 

or are just distortions due to unaccounted-for lateral velocity changes (e.g., associated with small stream 

valleys).”

3

. 

 

1

 Bob Hardage. Personal Communication with Charlotte Sullivan, March 7, 2011.

2

 Bob Hardage. Personal Communication with Charlotte Sullivan , January 22, 2013.

3

Phone Conference of Battelle Technical Team with John McBride September 16, 2013. 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 9 of 30

Figure 2. Reprocessed Morgan County P-P seismic data. The data are presented in a gray-scale squash-plot 

format to emphasize vertical discontinuities. Line 101 is 8 miles long; Line 201 is approximately 7 miles long. The 

Mount Simon is at a two way time depth of about 0.6 seconds; Precambrian basement about 0.68S. Artifacts are 

especially pronounced at depth and on edges of images. 

2.2 Knox Line 2D-Seismic Survey 

The Illinois State Geological Survey (ISGS) acquired a 120-mile-long 2D seismic survey across central Illinois as part 

of a U.S. Department of Energy-sponsored research project. The line extends from Meredosia to southern 

Champaign County (Figure 3).

The ISGS Knox 2D-seismic line runs east-west, through Cass County, about 3 miles north of the FutureGen 2.0 CO2

storage site. Dr. McBride reviewed the data that are closest to the FutureGen 2.0 site: “There do not appear to be 

any obvious, indisputable large faults in the western part of the ISGS line [west of Ashland]; however, seismic 

interpretations shown by ISGS personnel along the western part of the regional Knox Line 101 [east of Ashland]

indicate down-to-the-east normal faults that affect the Mt. Simon Sandstone, although not necessarily the Eau 

Claire Shale (base of Knox). For example, such a fault has been tentatively interpreted below about CDP 9000. This 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 10 of 30

is located about 2.5 miles northwest of Pleasant Plains and almost 6 miles northeast of the northern end of Morgan 

Co. L101”

4

. 

Figure 3. Location of the Knox seismic-reflection survey (ISGS, 2013) 

3. Vertical Seismic profile (VSP) 

3.1 Principle, objectives and data acquisition 

Vertical seismic profile (VSP) surveys are conducted by activating seismic sources (vibroseis trucks using vehiclemounted vibrator plates, in the case of the 2013 FutureGen 2.0 survey) at the Earth’s surface and recording the 

seismic signals with an array of receivers that are placed in a borehole. The use of three component geophones at 

the Morgan County site allowed both reflected compressional wave and shear wave data to be captured. 

If a single seismic energy source position is used within a few hundred feet of the borehole, the survey is referred 

to as being zero offset VSP ; at a longer seismic source-source distance, the borehole survey is an offset VSP (Figure 

4).

The fundamental objective of the Morgan County VSP program was to determine if visible faults cut the Mount 

Simon or Eau Claire in any of the 12 azimuths imaged by 15 offset VSP’s (Figure 5).

 

4

John McBride. Personal Communication with Charlotte Sullivan, October 29, 2013.
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 11 of 30

Figure 4. Schematic Drawings of a A) Zero Offset and B) Offset VSP. The seismic source is at the Earth’s surface; 

geophones are in the wellbore. 

The original VSP data-acquisition plan was to acquire data with 17 source stations encircling the FGA-1 

stratigraphic well (Figure 5). Due to wet, thawed soil conditions in the fields, all source stations had to be 

positioned on local roads; and data were not acquired at source stations 4 and 6. The location and lateral widths 

of the 2D seismic images generated by each source station is indicated in Figure 5 by a spoke wheel pattern 

radiating away from the FGA-1 well. A separate P-P and P-SV (wave converted from P to S in the subsurface) 

seismic image was generated for the zero offset and for each offset VSP; the lateral length of each 2D image is 

listed in Table 1. 

Figure 5: Offset VSP Source Stations. The lateral lengths of good-quality VSP images (Table 1) are indicated by 

the lengths of the lines in the spoke wheel pattern centered on the FGA-1 well. Distance from the stratigraphic 

well to Station 15 is approximately 4000 ft. 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 12 of 30

Table 1. Lateral lengths of VSP P-P and P-SV Images across the Mt. Simon Interval. 

3.2 Data-interpretation 

The resulting P-P and P-SV data were interpreted by Dr. Bob Hardage, who determined that no discontinuities of 

the type observed in 2D Line L101 or L201 are present in the VSP images5 and that there is no evidence of faults in 

any of the images6. Dr. Hardage pointed out that the areas imaged by the short 2D lines generated by the VSP 

surveys still represent a small part of the site. 

4. Summary 

Neither the 2D-seismic profiles (Line L101 and L201) acquired at the FutureGen 2.0 site nor the Knox profile exhibit 

any large scale structural features near the Morgan County site. 

Reprocessing of the ISGS Knox line was postponed until after evaluation of all 2D lines by Dr. John McBride, who is 

a specialist on Illinois seismic data and subsurface structure, and who is familiar with the different generations 

(original plus two reprocessed versions) of the Knox line data. Dr. McBride’s conclusions are that there are no 

discernible faults in either the Knox line west of Ashville Illinois (about 5 miles NNE of the Morgan County site) or in 

the 15 miles of 2D data acquired along roads at the Morgan County site, although the presence of small-throw 

faults cannot be completely ruled out by 2D seismic data. As a result of Dr. McBride’s interpretation, it was 

determined that reprocessing the Knox line will not provide additional information. 

 

5

Bob Hardage. Personal Communication with Charlotte Sullivan, October 18, 2013.

6

 Bob Hardage, Personal Communication with Charlotte Sullivan, August 1, 2013. 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 13 of 30

Discontinuities observed in the Morgan County 2D lines were not resolved by reprocessing the lines in 2012; two 

independent seismic specialists conclude that the remaining vertical discontinuities have a high probability of 

being artifacts due to acquisition and processing, specifically related to incomplete removal of surface seismic 

noise caused by offsets in acquisition lines (“crooked lines”) and streams, by the choice of filters used during 

processing, and other processing parameters. 

A zero offset VSP and 15 offset VSP’s were acquired in March 2013 to better determine if faults or fracture zones 

are present at the site. The VSP images are good quality, and no vertical discontinuities were observed in any of 

the offsets. Interpretation by Dr. Bob Hardage7 of the data indicates there is no evidence of faulting within the VSP 

image space. 

5. Cited Reference 

ISGS, 2013. “Seismic Line Data Release to Spur Additional Oil Exploration”. http://www.isgs.illinois.edu/?q=seismicline-data-release-spur-additional-oil-exploration. Last accessed on November 20, 2013. 

 

7

Bob Hardage, Personal Communication with Charlotte Sullivan, August 1, 2013. 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 14 of 30

Appendix B 

RAI# 10-31-2013_007 

Form 7520-14: Plugging and Abandonment Plan 

for 

Cased Well Completion, 1,500 ft Lateral 

Cased Well Completion, 2,500 ft Lateral 

Uncased Well Completion, 1,500 ft Lateral 

Uncased Well Completion, 2,500 ft Lateral 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 15 of 30

 

OMB No. 2040·0042 Approval Expires 11130/2014 

United States Environmental Protection Agency 

~EPA Washington, DC 20460 

PLUGGING AND ABANDONMENT PLAN 

Name and Address of Faclllt Name and Address of Owner/Operator 

1 ~~organ County Class VI UIC Well I FutureGen Alliance, Inc. I (cased well completion, 1,500 ft lateral) [address not yet available] 73 Central Park Plaza East, Jacksonville,lL 62650 

State I Count)r! Permit Number Locate Well and Outline Unit on llllinois I jMorgan ll luot yet issued Section Plat · 640 Acres I Surface Location Description N 

~ 1/4 of @ 114 of ~1/4 of .~/4 of Section Townshi (@] Rangel9W I j_L_j_ j_L_j_ Locate well in two directions from nearest lines of quarter section and drilling unit 

r- I I I 1- I I I 

r--t-1--t- 1--t-r--t- Surface 

Location D ft. frm (N~Line of quarter section ,_J._L..l_ 1-J._LJ._ and D ft. from (E/W) Line of quarter section. 

I I I I I I TYPE OF AUTHORIZATION WELL ACTIVITY w E 0 Individual Permit D CLASS I _ ..l_L..l_ ,_J._LJ. _ 0 Area Permit 0 CLASS II I I I · I I I 0 Rule 0 Brine Disposal --t-r--t- --t-r--t- _ ..l_LJ._ _..l_LJ. _ Number of Wells II J 0 Enhanced Recovery 

0 Hydrocarbon Storage I I I I xl I 0 CLASS Ill 

Lease Name! I s Well Number I CASING AND TUBING RECORD AFTER PLUGGING METHOD OF EMPLACEMENT OF CEMENT PLUGS 

SIZE WT(LB/FT) TO BE PUT IN WELL (FT) TO BE LEFT IN WELL (FT) HOLE S IZE IZJ The Balance Method 

~ U::4JI.Q I 1140' 11140' I l3o" I l:] The Dump Bailer Method 

I1E:J IS~~ Jl570' I [57o' 1120" I LJ The Two·Piug Method 

lro 3/4") I3Tll I 13,150' 113150' llll4 3/4" I 0 Other 

[E:J 12:~ !l 116,004' 116,004' I 19 ll2" I CEMENTING TO PLUG AND ABANDON DATA: PLUG 111 PLUG 112 PLUG 113 PLUG #4 PLUG #5 PLUG 116 PLUG 117 

Size of Hole or Pipe in which Plug Will Be Placed (lnche' 17" 117" 117" 117" I II II I 

Depth to Bottom of Tubing or Drill Pipe (ft 13,950 113,900 111,80() 11700 I II II I 

Sacks of Cement To Be Used (each plug) 1450 11150 II 53 11124 I I I I S lurry Volume To Be Pumped (cu. ft.) 1504 11168 1162.5 'It I II I Calculated Top of Plug (ft.) 13,900 113,100 111,500 I II II I 

Measured Top of Plug (if tagged ft.) 13,900 113,100 111,500 I II II I 

S lurry Wt. (Lb./Gal.) Jl5.82 J 115.82 1115.6 1115.6 I I I I I I 

Type Cement or Other Material (Class Ill) I EverCrcte I I EverCrefe I I Class A I IClass A I I II I LIST ALL OPEN HOLE AND/OR PERFORATED INTERVALS AND INTERVALS WHERE CASING WILL BE VARIED (if any) 

From To From To 

1!7" l!erforated casing}3,950 f!lJILJ 16,004 ftMD I I 

==.! ~ 

Estimated Cost to Plug Wells 

lilug #1 Set through a cement retainer set at 3,900 ft !viD 

$600,000.00 I 

Certification 

I certify under the penalty o f law tha t I have personally examined and am familiar with the Information submitted In this document and all 

attachments and that, based on my Inquiry of those Individuals immediately responsible for obtaining the information, I believe that the 

information is true, accurate, and comple te. I am aware that there are significant penalties for submitting false Information, Including the 

possibility of fine and Imprisonment. (Ref. 40 CFR 144.32) 

Name and Official Title {Please type or print) Signature Date Signed 

IKeJmcth K Humphreys, Chief Executive Officer 

I ~-"-~v ~ l11/t<6/J3 I EPA Form 7520·14 (Rev. 12·11) 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 16 of 30

 

OMB No. 2040-0042 Approval Expires 11/30/2014 

United States Environmental Protection Agency 

~EPA Washington, DC 20460 

PLUGGING AND ABANDONMENT PLAN 

Name and Address of Faclllt" Name and Address of Owner/Operator 

~~organ County Class VI UJC Well 

(cased well completion, 2,500 ft lateral) [address not yet available] I FulurcGen Alliance, Inc. I 73 Central Park Plaza East, Jacksonville, IL 62650 

State I Count~ Ji Permit Number Locate Well and Outline Unit on 

Section Plat • 640 Acres jminois I jMorgan . I not yet issued I 

N 

Surface Location Description 

j_L_j_ j_L_j_ @IJ114 of @0114 of JiE]114 of J~J/4 of Section E/Townshlp~ Rangei9W I 

Locate well In two directions from nearest lines of quarter section and drilling unit 

t- I I I c- I I I 

t--t-t--t- r--t-t--t- Surface 

Location 0 ft. frm (NIS} .OLtne of quarter section t-J._LJ._ r-.1-LJ._ and D ft. from (EIW) oL·I-nc of quarter section. 

I I I I I I 

lYPE OF AUTHORIZATION WELL ACTIVITY w E 0 Individual Permit 0 CLASS I r-J._LJ._ _ _l_LJ._ 0 Area Permit D CLASS II 

I I I I I. I 0 Rule 0 Brine Disposal r--t-t--t- --t-t--t- _ _l_LJ. _ _ _l_LJ._ Number of WellsU 

0 Enhanced Recovery 

0 Hydrocarbon Storage . I I I I xl I D CLASS Ill 

Lease Namet s I Well Number I I 

CASING AND TUBING RECORD AFTER PLUGGING METHOD OF EMPLACEMENT OF CEMENT PLUGS 

SIZE WT(LBIFT) TO BE PUT IN WELL (FT) TO BE LEFT IN WELL (FT) HOLE SIZE ~ The Balance Method 

IMCJ IITQ:o:==J ll4Q' 11140' I l3o" I LJ The Dump Bailer Method 

~ [&J!:j 11570' 11570' 1!120" I [j The Two-Plug Method 

Do 3/£:] I3I] I 13,150' 111:150' I 114 314" I 0 Other 

u::=::i f"W"o----1 17,004 117,004 I [~ ll2" J 

CEMENTING TO PLUG AND ABANDON DATA: PLUG #1 PLUG #2 PLUG #3 PLUG #4 PLUG #5 PLUG #6 PLUG #7 

Size of Hole or Pipe In which Plug Will Be Placed (lnche' [7" 1 17" 1 17" 117" II I II I 

Depth to Bottom of Tubing or Drill Pipe (ft 13,950 113,900 ILLsoo 11700 I I I I I 

Sacks of Cement To Be Used (each plug} 1666 I [150 1153 11124 II I I I 

Slurry Volume To Be Pumped (cu. ft.} [746 I 1168 I 162.5 I 046.3 II II II I 

Calculated Top of Plug (ft.} 13,900 1[3,100 1 11,500 IIO(GL) II I I II I 

Meas ured Top of Plug (If tagged ft.) Q,900 II3100 J 11,500 IJO(GL) _j I I I I I I 

Slurry Wt. (Lb./Gal.} I 15.82 1[15.82 1115.6 1115.6 I I I II I 

Type Cement or Other Material (Class Ill) IEverCrete I [EvcrCrclc I [Class A II class A L_~ I II I 

LIST ALL OPEN HOLE AND/OR PERFORATED INTERVALS AND INTERVALS WHERE CASING WILL BE VARIED (If any) 

From To From To 

IC7" Qerforatcd casing) 3,950 Jl MD I 17,004 flMD I 

I I 

c=::: 

Estimated Cost to Plug Wells If lug #1 Set through a cement retainer set at3,900 ft MD 

$600,000.00 I 

Certification 

I certify under the penalty of law that I have personally examined and am familiar with the information submitted in this document and all 

attachments and that, based on my Inquiry of those Individuals Immediately responsible for obtaining the Information, I believe that the 

Information Is true, accurate, and complete. I am aware that there are significant penalties for submitting false Information, Including the 

possibility of fine and Imprisonment. (Ref. 40 CFR 144.32) .. 

Name and Official Title (Please type or print)_ Signature Date Signed 

IKeamcth K Humphreys, Chief Executive Officer 

I ~"'il-~~ LiilLfl/flJ 

EPA Form 7520 14 (Rev. 12 11) ' 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 17 of 30

 

OMB No. 2040-0042 Approval Expires 11/30/2014 

United States Environmental Protection Agency 

&EPA Washington, DC 20460 

PLUGGING AND ABANDONMENT PLAN 

Name and Address of Facili t~ Name and Address of Owner/Oeerator 

~~organ County Class VI UIC Well I FutureGcn Alliance, Inc. I (opeo1 well completion, 1,500 ft lateral) (address not yet available) 73 Central Park Plaza East, Jacksonville, rL 62650 

State I= I Permit Number Locate Well and Outline Unit on 

Section Plat - 640 Acres !Illinois II loot yet issued =.J I Morga;, 

N Surface Location Description 

I I I I I I !ill 114 of al114 of ~1/4 of .[ ]114 of Section IE:]Townshipll4!iJ Rangei9W l _J._ LJ._ r-J._LJ._ Locate well In two directions from nearest lines of quarter section and drilling unit 

I I I I I I 

--r-t--t- r- -t-t--t- Surface 

Location 0 fl. frm (N/S) D une of quarter section _J._LJ._ r-.l_L.l_ and D ft. from (E/W) o ·Ci'nc of quarter section. I I I I I I TYPE OF AUTHORIZATION WELL ACTIVITY 

w E I?.J Individual Permit D CLASS I _ J._LJ._ ,_.l_L.l _ 0 Area Permit 0 CLASS II I I I I I I 0 Rule 0 Brine Disposal t--t--t--t-- --r-t--t--

t-.1-LJ. _ _ .l_LJ._ Number of Wells I 1 I 0 Enhanced Recovery 

0 Hydrocarbon Storage I I I I x l I 0 CLASS Ill 

Lease Name I I s Well Number l I 

CASING AND TUBING RECORD AFTER PLUGGING METHOD OF EMPLACEMENT OF CEMENT PLUGS 

SIZE WT(LB/FT) TO BE PUT IN WELL (FT) TO BE LEFT IN WELL (FT) HOLE SIZE 0 The Balance Method 

I1E:J trnl:o=::l 140' 1140' I 130" I LJ The Dump Baller Method 

IILJ I&H l 11570' 1570' I 20" [J The Two-Plug Method 

IJ03t4"l 1!1.0 113,150' 113,150' I 114 314" 0 Other 

rz:=J :l~!l 113,950 113:950 119 112" 

CEMENTING TO PLUG AND ABANDON DATA: PLUG 111 PLUG 112 PLUG 113 PLUG 114 PLUG 115 PLUG 116 PLUG 117 

Size of Hole or Pipe In which Plug Will Be Placed (lnche' 17" 117" 117" 117" II II II .J 

Depth to Bottom of Tubing or Drill Pipe (f! 13.9s:c=J 13,900 111,800 11700 II II II I 

Sacks of Cement To Be Used (each plug) 11 ,200 IPso 1153 11124 II II II I 

Slurry Volume To Be Pumped (cu. fl.) 11,344 62.s I 0.:46.3 I I II II I 

Calculated Top of Plug (ft.) 13,900 l1 ,5oo I jo (GLl I I - ]I I I I 

Measured Top of Plug (If tagged ft.) 13,900 I 3 1oo rt:Soo I IO{GL} II II II I 

Slurry WI. (Lb./Gal.) 115.82 1 115.82 1115.6 1 115.6 II I I I 

Type Cement or Other Material (Class Ill) IEverCretel IEverCrctc I I c l ass A II class A II I l I 

LIST ALL OPEN HOLE AND/OR PERFORATED INTERVALS AND INTERVALS WHERE CASING WILL BE VARIED (if any) 

From To From To 

1(9 1/2" open hole) 3,950 ft MD I 16,004 ft MD I 

J t= 

Estimated Cost to Plug Wells 

l;lug #I Set through a cement retainer set at 3,900 ft MD 

$600,000.00 I 

Certification 

I certify under the penalty of law that I have personally examined and am familiar with the information submitted in this document and all 

attachments and that, based on my Inquiry of those individuals Immediately responsible for obtaining the Information, I believe that the 

information Is true, accurate, and complete. I am aware that there are significant penalties for submitting false Information, Including the 

possibility of fine and Imprisonment. (Ref. 40 CFR 144.32) 

Name and Official Title (Please type or print) Signature Date Signed 

IKcomcth K. Humphreys, Chief Executive Officer I ~ '"tt-.. ~~ u /1 e /13 I EPA Form 7520-14 (Rev. 12-11) 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 18 of 30

 

OMB No 2040-0042 Approval Expires 11/30/2014 

United States Environmental Protection Agency 

oEPA Washlngtoo, DC 20460 

PLUGGING AND ABANDONMENT PLAN 

Name and Address of Facillt)! Name and Addr'!.,SS of Owner/Ooerator II Morgan County Class VI UIC Well I FuturcGen Alliance, li\C. I (open well completion, 2,500 ft lateral) (address not yet available] 73 CenlTal Park Plaza East, Jacksonville, IL 62650 

State ,, Count~ Permit Number 

locate Well and Outline Unit on I Illinois !!Morgan II ~~yet issued Section Plat • 640 Acres I N Surface Location Description 

I I I I I I ~ 1/4 of §]114 of Jili]114 of §14 of Section IE]Townshtp(ijji) Rangei'9WJ 

r-_l_L_L_ 1-J._L_l_ Locate well In two directions from nearest lines of quarter section and drilling unit 

I I I I I I 

1---t-t--t-1--t-t--t- Surface 

location 0 ft. frm (N[52Line of quarter section r-_l _ LJ._ 1-_l_L_l_ and 0 ft. from (E/W) Line of quarter section. I I I I I I TYPE OF AUTHORIZATION WELL ACTIVITY 

w E 0 Individual Permit D CLASS I r-_l_L_l_ 1-_l_L_l_ 0 Area Permit 0 CLASS II 

I I I I I I 0 Rule CJ Brine Disposal r--t-t--t- r--t-t--tr-_l_L_l_ r-.l_L_l _ Number of Wells iLJ 0 Enhanced Recovery 

0 Hydrocarbon Storage 

I I I I xi I 0 CLASS Ill 

lease Name I I s Well Number I 

CASING AND TUBING RECORD AFTER PLUGGING METHOD OF EMPLACEMENT OF CEMENT PLUGS 

SIZE WT(LB/FT) TO BE PUT IN WELL (FT) TO BE LEFT IN WELL (FT) HOLE SIZE 1!:) The Balance Method 

I1E::J OJM 11140' 11!40' I l3o" I 1:] The Dump Bailer Method 

liE:] rn41! I 1570' 11570' 11120" J LJ The Two-Plug Method 

[10374"1 [il.:O I [I. ISO' IIJ...!2l' 1114 3/4" J 0 Other 

rz:::=J !Z2:.0 I 13,950 113,950 1191/2" I 

CEMENTING TO PLUG AND ABANDON DATA: PLUG #1 PLUG #2 PLUG #3 PLUG #4 PLUG #S PLUG #6 PLUG #7 

Sl%e of Hole or Pipe In which Plug Will Be Placed (inche• 17" J 17" I 7" 17'' II II II I 

Depth to Bottom of Tubing or Drill Pipe (ft 13,950 113,90() I 1700 II II II I 

Sacks of Cement To Be Used (each plug) 11,500 lit so I s3 1124 I I I I 

Slurry Volume To Be Pumped (cu. ft.) 11,680 11168 lim I 1146.3 I II II I 

Calculated Top of Plug (fl.) 13,900 113,100 llt,SOO IIQ_(GL) I II II I 

Measured Top of Plug (If tagged ft.) 13,900 113,100 llt,SOO IIO(GL) I I I II I 

Slurry WI. (Lb./Gal.) ps.s2 I 115.82 llt5.6 1115.6 I II II I 

Type Cement or Other Material (Class Ill) EverCrete IEyerC~ !class A II class A I IlL .J I I 

LIST ALL OPEN HOLE AND/OR PERFORATED INTERVALS AND INTERVALS WHERE CASING WILL BE VARIED (If any) 

From To From To 

[{9 1/2" OQen hole) 3,950 ft MD I 17,004 ft MD I 

II I I. 

I - II 

Estimated Cost to PIUQ Wells II Plug #I Set through a cement retainer set at3,900 ft MD I $600,000.00 . 

Certification 

I certify under the penalty of law that I have personally examined and am familiar with the Information submitted In this document and all 

attachments and that, based on my Inquiry of those Individuals Immediately responsible for obtaining the Information, I believe that the 

Information Is true, accurate, and complete. I am aware that there are significant penalties for submitting false Information, Including the 

possibility of line and Imprisonment. (Ref. 40 CFR 144.32) 

Name and Official Title (Please type or print) Signature 

~ Date Signed 

JJKetmeth K. Humphreys, Chief Executive Officer I ~ Y{_, lllilJ<6 ~~ I EPA Form 7520-14 (Rev. 12-11) v 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 19 of 30

Appendix C 

RAI# 10-31-2013_008

EverCrete Cement Information
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 20 of 30

Schlumberger 

Laboratory Cement Test Report-CAR1 0-384 EverCRETE-5 

Fluid No : 

Date : Oct-17-2010 

Job Type 

BHST 

Client 

Well Name 

Location I Rig 

Field 

Depth 7200.0 ft 

BHCT 107 degF 

Time to Temp. 00:37 hr:mn 

Sl natures 

:Wildcat I ~ Mark Meade 

TVD 7200.0 ft 

BHP 4340psi 

Starting Temp. Heating Rate (degF/min) 

Startina Pressure 

Production 

123 degF 

80 degF 

510 osi nme to Pressure 00:37 hr:mn Schedule 9.6-1 

Composition 

Slurry Density 15.82 lblgal 

Solid Vol. Fraction 58.0 % 

Yield 

Porosity 

Blend ADM Eve!.frtal!i~~ ~f.~~:fir.l~;~; ·~ r EverCRETE 100 lb/sk 

... . --- ADM EverCRET 100 lb of BLEND 

Fresh water 2.946 qaVsk 

D174 10.000 %BWOC 

D206 0.050 gaVsk 

D145A 0.100 gaVsk 

D500 0.400 gaVsk 

D177 0.020 gaVsk 

Rheology (Average readings) . ... . . 300 128.5 115.0 

200 102.5 95.0 

100 73.0 73.0 

60 61.0 64.0 

30 51 .0 56.0 

6 37.0 40.0 

3 31 .0 32.0 

1 10 sec Gel 27 

33 

I Temperature 80 degF 107 degF 

Pv: 193.092 cP Pv: 144.553cP 

Tr: 44.841bf/100ft2 Ty: 52.631bf/100ft2 

Thickening Time . 

100Bc 07:53 hr:mn 

70 Be 07:05 hr:mn 

SO Be 05:36 hr:mn 

Remark : Thickening time do not include 2 hour batch time 

Free FlUid 

0.0 mU250mL 

At 107 degF and 0 deg incl. 

Sedimentation 

in 2 hrs 

None 

1.12 ft3/sk 

42.0 % 

. .. Blend 

Base Fluid 

Expanding ce 

An!Hoam 

Dispersant 

GASBLOKLT 

Retarder 

Fluid Loss 

API Fluid Loss 

14 mL in 

Mix Fluid 

Slurry type 

: - .. -

157.63 lblft3 

3.516 gaVsk 

Conventional 

. .. 

TUOJ0241AO 

S0818101 

09402023 

CY10220316 

2009248AP 

28 mL 

30min at 107 degF and 1000 osi 

UCA Com~essive Streng_th 

15:04 hr:mn 50_251 

15:35 hr:mn 100 psi 

18:37 hr.mn 500 psi 

24:00 hr:mn 1463_p_sl 

72:00hr:mn 4607 psi 

105:00 hr:mn 5223~si 

Paget 

I 

1 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 21 of 30

Client 

Formation 

Country 

Thickinging Time Graph ,_,l 

·-1 

'""" 

'""" 

UCA Graph 

100 

.. 

.. 

70 

Well 

District 

.. -... 

Page2 

12:00 

,,. 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 22 of 30
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 23 of 30

Appendix D 

RAI# 10-31-2013_009 

Figures 4.4, 4.5, 6.1, and 6.2 

of

UIC Permit Supporting Documentation 

 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 24 of 30

Figure 4.4 Injection Well Schematic – Cased-Hole Completion (geology and depths shown in this 

 diagram are based on site-specific characterization data obtained from the FutureGen 2.0 

 stratigraphic well) 

FutureGen (Morgan County, IL) 

Depth 

(ft) 

System Name Lithology 

Depth 

(ft bgs) Horizontal Injection Well 

(Cemented and Perforated) 

Pleist I--F=F==::;; =:ai=::' po ';;'===t=====r-T. I·· -: ••JT" :-=-· T'TTIIIT"'T~-:-T. J:·-: •• :r -- Conductor Casing 

'----lll•e~st 13~0 ft[!ltl __ =::.~;::=:::=rt' 30 .__: ' · • ----.J_ 140 ft. of 24", 140 #/ft Grade B, 

: .. sam:lstQne(:' . · PEB (or K-55, MTC) set in 30" hole 

Spoon-Carbondale (1 97ft) .:::-c::snale.::.,-0 ·." .: •. Lead: 400 sks Class A with 2% 

u~~7;::~~~r.~~:;~di==~t. ~L~ui~s (4 ft ) =~~Fr.~•li~m~e~s~to~n~j: m ,~;:and 0.25#/sk cell flake, 15.6 

-~ Salem (134 It) 506 • • • . • • Fill-up: 0 - 140ft 

-~ ~~-W~V~a~rrrs ~alw~78~~,.:~ ftl =-:-:- ~-s~h~a!Ef~t 584 Orill ·• ' " .. l_ ;:: Keokuk-Burlington (227ft) l=rlimestone Surface Casing ;:: , 570ft of 16", 84.0 #/ft, K-55, BTC 

::E Hannibal (125 tt) -:..""shale--- 811 ' set in 20" hole Lead: 225 sks 65/35/1 0 Pozmix 

1_000_ f-- New Albany (91 ft) .stiale-- 936 ·." , with 0.25 #/sk cell flake, 11.2 #/gal. 

Devon J":'"-t--_; :::.:.! :::ia!!. 41 f.!)_~~~~~~ 8~~ Fill-up: 0-420 ft 

-~~I---+---S:::,ilu::,:::::,:.l.:. 11 ft::,)"---!i'i~ioilhi;i;m);ie;;i;sti;iio;i;:n;;ioe~ . . Tail: 200 sks Class A with 2% CaCI Silurian ~ 1,1 86 .• and 0.25 #/sk cell flake, 15.6 #/gal. 

c 

'ij "' 

Maquoketa (197 It) 

Galena (141 ft) 

Plattevile (1 24ft) 

Joachim-Gienwood (92 It) 

St. Peter (202 ft) 

------

=~s.hi!!<L~- - - ----

f!;limeston·e= 

~;rc;~~~~ 

P':'iloloniite"r 

;,iii!~~~ 

1,383 

1,524 

1,848 

1,740 

Fill-up: 420 - 570 ft 

+~+----- 9.5 #/gal. corrosion-inhibited KCI 

brine or similar annular fluid 

1,942 

2,000- ~ ~-===~=~- Shakopee (390 It) (;::zdolo ~~~mite

~ = 

Intermediate Casjng 

r-- 3,150 It of 10-3/4", 51 .0 #Itt, K-55, 

BTC set in 14-3/4" hole. 

3,000-

4,000-

5,000-

c 

.!1 

.0 

E 

u "' 

L~::=:~~:--~~~~t 2,332 New Richmond (1 02ft) , sandstone, 

1.;.;.:.-:~~ :...;.;:...._~~~ t 2,434 

Oneota (200 ft) (;::zdolomite:;: 

Gunter f2 tt 

Eminence (90 It) 

. . d . . . 2,634 ' san stone· 2 706 

'"' 

To be cemented in two stages. 

Multiple stage cementing collar set 

at 2,750 tt 

Stage I 

250 sks Class A ESC with 10 #/sk 

Cal Seal and 1 0% slat, 16.6 #/gal. 

Fill-up: 2,750- 3,150 It 

~ 

Potosi (276 ft) •

dolom'te= 2

:

796 

Lost 

Circulation 

Zone 

r---::---:::-:-:-::-:--1~~~~ 3.072 

Lead: 755 sks 65/35/1 0 Pozmix, 

12.5 #/gal. 

Fill-up: 0 - 2,250 It 

Tail: 215 sks 50/50/10 Pozmix, 

14.8 #/gal. 

Franconia (214 It) j':zdolomite:;= 

-ijol: siltstone 3·

244 

Ironton-Galesville (139ft) ;'s'~~Clsto~{ 3

'

286 

1----------1'"""';.,.,;;,,.;;,.~+- 425 

Eau Claire (479 It) 

Explanation 

Dash 1nd1cates 

Uncertainty 

3,581 

::-.'dole mitE£-_ 

------ ------

4,812 

··- Fill-up: 2,250 - 2, 750 It 

nsition from 7" diameter Carbon Steel 

ing to 7" diameter corrosion-resistant 

y Stainless Steel casing at MD = 3,400 ft 

3,900 It Injection (3,81 9 ft Tubing TVD) o'-.. f 3.5", -....,..'111!•••••••••••••••• 9.3 #/ft, N-80 8 Rd., EUE, set 

on injection packer. 

Production Casing 

3,400 tt of 7", 29.0 #1ft, N-80 or P-110, 

BTC and 2,604 tt or 3,604 tt of 7", 

29.0 #Itt, 13Cr S-110 VAM TOP or similar 

premium connection set in 9-1/2" hole 

Lead: 380 sks 65/35 Pozmix with 2% 

gel, 12.5 #/gal. 

Fill-up: 0- 2,900 It 

Tail: 1,080 sks "EverCRETE" cp - resistant cement (or similar blend), 

15.82 #/gal. 

Fill-up: 2,900 - 6,004 or 7,004 ft 

I. 4,030 ft TVD 

500 or 500ft =4 

TVD = 4,030 It TVD = 4,030 It 

MD = 4,504 ft MD = 6,004 ft 

or7,004 It 

MD = Measured Depth 

TVD = Total Vertical Depth 

Not to Scale 

1 1/21/ 2013 

FUTUREGEN_HOZ_INJA02.COR 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 25 of 30

Figure 4.5 Injection Well Schematic – Open-Hole Completion (geology and depths shown in this 

 diagram are based on site-specific characterization data obtained from the FutureGen 2.0 

 stratigraphic well)

FutureGen (Morgan County, IL) 

Depth 

(ft) 

System Name Lithology 

Depth 

(ft bgs) Horizontal Injection Well 

(Open Hole Completion) 

Pleist~---F=F==;:;ac=; ;o: l D=-e=po= so:; it===t=====r-1. s I·· -:: •• r I :-:· "'T'"T"'TIIrT"'T.,.~-:-r. l·-.. :r -- Conductor Casing 

i----.(! loe!_!!sLt.11~30 ft[!J~'-----4=::.:T.::=:::=:t' 130 ~ ' · • ,:...-J- 140ft. of 24", 140 #/ft Grade B, : .. si1.0\:lstQ~!1 :' . · PEB (or K-55, MTC) set in 30' hole 

Penn ylva:~no~an~l= po n~ rbo~n le 1 =97= ft=) :-~ .. :.... ·""'~sfi~a~le~.:.""c.. ~ .. -f. 327 ·." ... •. Lead: 400 sks Class A with 2% Undifferen at~ St. Louis (45 It) p:.lim!)sjon~ 372 ,~;:.and 0.25#/sk cell flake. 15.6 

.!ll ~-~~a!!;le!!m!J~1~4~ft~-~~§~~506 . • • Fill-up: 0-140ft 

.~ ~~ W~aor~ors ~a·~78~~ol~ ftl =-:-:-~~-s~h~a e~t 584 C.. . . : ' .. Ill. 

;:: Keokuk-Burlington (227ft) t=IIimestone L Surface Casing ;:: , 570ft of 16", 84.0 #/ft, K-55, BTC 

::E Hannibal (125ft) -:...""shale--- 811 · set in 20" hole 

r--r-;t~~;=;::-;c;~'\---F-~~ g_ 936 • Lead: 225 sks 65/35/1 0 Pozmix 

1 000,_ New Albany (91 ft) .sliale-- ·• , with 0.25 #/sk cell flake, 11.2 #/gal. 

De•von,i,;. a-n ' Devonian (41 f!)_ ~~ ~~~~~'l~ ~~ 11 •• 006278 Fill-up: 0-420 ft 

.;;' Silurian (118ft) ~limestone= . . Tail: 200 sks Class A with 2% CaCI 

Silurian _ _ ____ 1,186 .. and 0.25#/skcellflake, 15.6#/gal. 

c 

'ij "' 

·:; 

2,000- -E 

3,000-

4,000-

5,000-

0 

c 

.!1 

.0 

E 

u "' 

Maquoketa (197ft) 

r---===::-::----1#~~~ 1,383 Galena ( 141 ft) f!; limeston = 

1------------.g,:e,~~ 1,524 

Plattevile (124ft) ~;rc;~~~~ 

ac-."" "' ooo=-:::-:: ft~)-f'"'ca'f . o"=l?'om '"¥.ite~ "r'l- 1 ·

848 

1,740 

St. Peter (202 ft) 

r~===~~~- iii 942 

Shakopee (390ft) ;:zdolomite= 

L~:=== New Richmond (1~~02ft) , sa~~~ ndstone, 332 l,;.;.:.::~~~~::..;,;:l~~~~t2 434 Oneota (200 ft) ;:zdolomite:;:: 

Gunter 12 nJ 

Eminence (90 It) 

. . d t' . . 2,634 ' san s one· 2 706 

Fill-up: 420 - 570 ft 

.J-+-;j----- 9.5 #/gal. corrosion-inhibited KCI 

brine or similar annular fluid 

'"' 

Intermediate Casing 

- 3,150 ftof 10-3/4", 51 .0#/ft, K-55, 

BTC set in 14-3/4' hole. 

To be cemented in two stages. 

Multiple stage cementing collar set 

at 2,750 ft 

Stage I 

250 sks Class A ESC with 10 #/sk 

Cal Seal and 1 0% slat, 16.6 #/gal. 

Fill-up: 2,750-3,150 ft 

~ 

Potosi (276 ft) •

dolom'te= 2

:

796 Lost 

Circulation 

Lead: 755 sks 65/35/1 0 Pozmix, 

12.5 #/gal. 

Fill-up: 0 - 2,250 ft 

'----=------:=-:-:-::-:-- ~~~~ Zone I 3,072 

Franconia (214 ft) ;:zdolomite:;= 

. ijol: siltstone 3-

244 

Ironton-Galesville ( 139 ft) s~~iisio~~ 3

'

286 

1---------e..,:.,.;;,..,.,~+- 3,425 

Eau Claire (479ft) 

Explanation 

Dash 1nd1cates 

Uncertainty 

3,581 

::-:dole mit<£-_ 

------ ------

4,812 

··-

Tail: 215 sks 50/50/10 Pozmix, 

14.8 #/gal. 

Fill-up: 2,250 - 2, 750 ft 

- Transition from 7" diameter Carbon Steel 

casing to T' diameter corrosion-resistant 

alloy Stainless Steel casing at MD = 3,400 ft 

lnjectjon Tubjnq 

~;__...!>.,,...--- 3,900 ft. of 3.5", 9.3 #/ft., N-80 8 

~Rd., EUE, set on injection packer. 

Production Casing 

3,400 ft. of 7', 29.0 #/ft., N-80 or 

P-110, BTC and 550 ft. of 7", 29.0 

#/ft., 13Cr S-110 VAM TOP or 

similar premium connection set in 

9-112' hole 

Lead: 380 sks 65/35 Pozmix with 

2% gel, 12.5 #/gal. 

Fill-up: 0 - 2,900 ft. 

Tail: 285 sks "EverCRETE' CO,-

resostant cement (or somilar blend), 

15.82 #/gal. 

Fill-up: 2,900 - 3,950 ft 

I. 4,030 ft TVD 

,50 or 500ft =4 

TVD = 4,030 ft TVD = 4,030 ft 

MD = 4,504 ft MD= 6,004 ft 

or7,004 ft 

MD = Measured Depth 

TVD = Total Vertical Depth 

Not to Scale 

11/21/ 2013 

FUTUREGEN_HOZ_INJB02.COR 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 26 of 30

Figure 6.1. Diagram of Cased Injection Well After Plugging and Abandonment 

Depth 

(ft) 

System 

c 

.!!1 

.0 

E 

u "' 

c 

.!!1 

li 

E 

"' u 

~ 

Cl. 

FutureGen (Morgan County, IL) 

Name 

Eau Claire (479 It) 

Mt. Simon 

(499 It) 

Precambrian 

Explanation 

Lithology 

Dash indicates 

Uncertainty 

Depth 

(ft bgs) Horizontal Injection Well 

(Cemented and Perforated) 

Conductor Casing 

140ft. of 24", 140 #/It Grade B, 

PEB (or K-55, MTC) set in 30" hole 

Lead: 400 sks Class A with 2% 

CaCI and 0 .25#/sk cell flake, 15.6 

#/gal. 

Fill-up: 0- 140 ft 

Surface Casing 

570ft of 16", 84.0 #/It, K-55, BTC 

set in 20" hole 

Lead: 225 sks 65/35/1 0 Pozmix 

with 0.25 #/sk cell flake, 11 .2 #/gal. 

Fill-up: 0-420 ft 

Tail: 200 sks Class A with 2% CaCI 

and 0.25 #/sk cell flake, 15.6 #/gal. 

Fill-up: 420 - 570 It 

Intermediate Casing 

3,150 ft of 10-3/4", 51 .0 #/It, K-55, 

BTC set in 14-3/4" hole. 

To be cemented in two stages. 

Multiple stage cementing collar set 

at 2,750 ft 

Stage I 

250 sks Class A ESC with 10 #/sk 

Cal Seal and 1 0% slat, 16.6 #/gal. 

Fill-up: 2,750 - 3,150 ft 

~ 

Lead: 755 sks 65/35/1 0 Pozmix, 

12.5 #/gal. 

Fill-up: 0 - 2,250 ft 

Tail: 215 sks 50/50/10 Pozmix, 

14.8 #/gal. 

Fill-up: 2,250 - 2, 750 ft 

----Transition from 7" diameter Carbon Steel 

casing to r diameter corrosion-resistant 

alloy Stainless Steel casing at MD = 3,400 It 

Production Casing 

3,400 It of 7", 29.0 #/It, N-80 or P-110, 

BTC and 2,604 It or 3,604 ft of 7", 

29.0 #/It, 13Cr S-110 VAM TOP or similar 

premium connection set in 9-1/2" hole 

Lead: 380 sks 65/35 Pozmix with 2% 

gel, 12.5 #/gal. 

Fill-up: 0- 2,900 ft 

Tail: 1,080 sks "EverCRETE" cp - resistant cement (or similar blend), 

15.82 #/gal. 

Fill-up: 2,900 - 6,004 or 7,004 It 

I. 4,030 It TVD 

500 or 500ft =4 

TVD = 4,030 ft TVD = 4,030 ft 

MD = 4,504 It MD= 6,004 It 

or7,004 ft 

MD = Measured Depth 

TVD = Total Vertical Depth 

Not to Scale 

1 1/21/ 2013 

FUTUREGEN_HOZ_INJA02_PLUG02.CDR 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 27 of 30

Figure 6.2. Diagram of Non-Cased Injection Well After Plugging and Abandonment

Depth 

(ft) 

System 

c 

.!!1 

.0 

E 

u "' 

c 

.!!1 

li 

E 

"' u 

~ 

Cl. 

Name 

FutureGen (Morgan County, IL) 

Lithology 

Depth 

(ft bgs) Horizontal Injection Well 

(Open Hole Completion) 

Conductor Casing 

140ft. of 24", 140 #/It Grade B, 

PEB (or K-55, MTC) set in 30" hole 

Lead: 400 sks Class A with 2% 

CaCI and 0.25#/sk cell flake, 15.6 

#/gal. 

Fill-up: 0- 140 ft 

Surface Casing 

570ft of 16", 84.0 #/It, K-55, BTC 

set in 20" hole 

Lead: 225 sks 65/35/1 0 Pozmix 

with 0.25 #/sk cell flake, 11.2 #/gal. 

Fill-up: 0-420 ft 

Tail: 200 sks Class A with 2% CaCI 

and 0.25 #/sk cell flake, 15.6 #/gal. 

Fill-up: 420 - 570 It 

Intermediate Casing 

3,150 It of 10-3/4", 51 .0 #/It, K-55, 

BTC set in 14-3/4' hole. 

To be cemented in two stages. 

Multiple stage cementing collar set 

at 2,750 ft 

Stage I 

250 sks Class A ESC with 10 #/sk 

Cal Seal and 1 0% slat, 16.6 #/gal. 

Fill-up: 2,750 -3,150 ft 

~ 

Lead: 755 sks 65/35/1 0 Pozmix, 

12.5 #/gal. 

Fill-up: 0 - 2,250 ft 

Tail: 215 sks 50/50/10 Pozmix, 

14.8 #/gal. 

Fill-up: 2,250 - 2, 750 ft 

- Transition from 7" diameter Carbon Steel 

Eau Claire (479 It) 

Mt. Simon 

(499 It) 

Precambrian 

Explanation 

Dash indicates 

Uncertainty 

Production Casing 

3,400 ft. of 7", 29.0 #/ft., N-80 or P110, BTC and 550ft. of 7", 29.0 

#/ft., 13Cr S-11 0 VAM TOP or 

similar premium connection set in 

9-112" hole 

Lead: 380 sks 65/35 Pozmix with 

2% gel, 12.5 #/gal. 

Fill-up: 0 - 2,900 ft. 

Tail: 285 sks "EverCRETE" CO,-

resistant cement (or similar blend), 

15.82 #/gal. 

Fill-up: 2,900 - 3,950 It 

casing to 7" diameter corrosion-resistant 

alloy Stainless Steel casing at MD = 3,400 ft 

I. 4,030 It TVD 

500 or 500ft =4 

TVD = 4,030 ft TVD = 4,030 ft 

MD = 4,504 It MD = 6,004 It 

or7,004 ft 

MD = Measured Depth 

TVD = Total Vertical Depth 

Not to Scale 

1 1/21/ 2013 

FUTUREGEN_HOZ_INJB02_PLUG02.COR 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 28 of 30

Appendix E 

RAI# 10-31-2013_011

Endangered Species Act Information From USFWS
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 29 of 30

United States Department of the Interior 

Mr. Cliff Whyte 

U.S. Department of Energy 

U.S. FISH AND WILDLIFE SERVICE 

Marion Illinois Sub-Office (ES) 

8588 Route 148 

Marion, Illinois 62959 

(618) 997-3344 

November 8, 2013 

National Energy Technology Laboratory 

3610 Collins Ferry Road, P.O. Box 880 

Morgantown, WV 26507 

Dear Mr. Whyte: 

Thank you for your October 28, 2013, letter requesting concurrence on the proposed FutureGen 

2.0 Project. The proposed project would be located in Morgan County, Illinois, and involves the 

construction and operation of a 168-megawatt gross output coal-fueled electric generation plant 

using advanced oxy-combustion technology and construction of a new underground pipeline 

approximately 30 miles long and 12 inches in diameter to transport captured C02 from the 

generation plant to a geologic storage area in eastern Morgan County, approximately 4,000 feet 

below the ground surface. These comments are provided under the authority of and in 

accordance with the provisions of the Endangered Species Act of 1973 (87 Stat. 884, as 

amended; 16 U.S.C. 1531 et seq.); Fish and Wildlife Coordination Act (48 Stat. 401, as 

amended; 16 U.S.C. 661 et seq.); and, the National Environmental Policy Act (83 Stat. 852, as 

amended P.L. 91-190,42 U.S.C. 4321 et seq.). 

To facilitate compliance with Section 7(c) of the Endangered Species Act of 1973, as amended, 

Federal agencies are required to obtain from the Fish and Wildlife Service (Service) information 

concerning any species, listed or proposed to be listed, which may be present in the area of a 

proposed action. The list for the proposed project area includes the endangered Indiana bat 

(Myotis soda/is), threatened decurrent false aster (Boltonia decurrens), threatened eastern prairie 

fringed orchid (P/atanthera /eucophaea), and northern long-eared bat (Myotis septentrionalis, 

proposed as endangered). There is no designated critical habitat in the project area at this time. 

Information in the October 2013 Biological Assessment (BA) indicates that the eastern prairie 

fringed orchid was not observed during surveys conducted in 2012 and 2013 and suitable habitat 

for the eastern prairie fringed orchid does not exist with the project area, thus DOE has 

determined the proposed project would have no effect on the eastern prairie fringed orchid. This 

precludes the need for further action on this project as required under Section 7 of the 

Endangered Species Act of 1973, as amended for the eastern prairie fringed orchid. 

Information provided in the BA indicates that proposed project will impact approximately 15.2 

acres of potential Indiana bat habitat. In order to minimize and avoid impacts, wooded areas 
U.S. Environmental Protection Agency Request for Additional Information #1, Regarding: 

FG-RPT-017, Revision 1, SUPPORTING DOCUMENTATION: Underground Injection Control Class VI Injection Well Permit Applications 

For FutureGen 2.0 Morgan County UIC Wells 1, 2, 3, and 4 

11/21/2013 Page 30 of 30

Mr. Cliff Whyte 

collocated with streams and wetlands would be bored under and any necessary tree clearing 

would occur during the winter months when Indiana bats would not be present. Based on this 

information and information provided in the Indiana bat habitat assessment datasheets the 

Service concurs that the proposed project is not likely to adversely affect the Indiana bat. 

According to the BA, the decurrent false aster was not observed during multiple vegetation 

surveys completed in 2011 and 2012 and additional surveys will be conducted in appropriate 

habitats prior to construction, because decurrent false aster can remain viable in the seed bank. 

Based on this information the Service concurs the proposed project is not likely to adversely 

affect the decurrent false aster. Should this project be modified or new information indicate 

listed or proposed species may be affected, consultation or additional coordination with this 

office, as appropriate, should be initiated. 

2 

The northern long-eared bat was proposed as endangered on October 2, 2013 and thus was not 

considered in the BA. A final decision on listing the species will be made prior to the proposed 

construction start date; therefore, we are providing additional information regarding this species. 

The northern long-eared bat hibernates in caves and roosts and forages in upland forests and 

woods. Potential habitat for this species occurs statewide, therefore, they are considered to 

potentially occur in any area with forested habitat. Minimization and avoidance measures for the 

northern long-eared bat are similar to the Indiana bat; therefore, the Service concurs that with 

implementation of the proposed minimization and avoidance measures for the Indiana bat the 

proposed project is not likely to adversely affect the northern long-eared bat. 

Although the bald eagle has been removed from the threatened and endangered species list, it 

continues to be protected under the Migratory Bird Treaty Act and the Bald and Golden Eagle 

Protection Act (BGEPA). The Service developed the National Bald Eagle Management 

Guidelines to provide landowners, land managers, and others with information and 

recommendations regarding how to minimize potential project impacts to bald eagles, 

particularly where such impacts may constitute "disturbance," which is prohibited by the 

BGEP A. The Service is unaware of any bald eagle nests in the proposed project area and none 

were found during a survey of the project area. If a bald eagle nest is found in the project area or 

vicinity of the project area in the future then our office should be contacted and the guidelines 

implemented. A copy of the guidelines is available at: 

http://www.fws.gov/migratorybirds/CurrentBirdlssues/Management/BaldEagle/NationalBaldEag 

leManagementGuidelines.pdf 

Thank you for the opportunity to provide information concerning threatened and endangered 

species. For additional coordination, please contact me at (618) 997-3344, ext. 345. 

Sincerely, 

Matthew T. Mangan 

Biologist in Charge