Text

NPDES Permit Schedule of Compliance Condition Concerning Groundwater Monitoring
	ML081190573
Person / Time
Site:	Callaway
Issue date:	04/22/2008
From:	Graessle L; AmerenUE
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	ULNRC-05511
	Download: ML081190573 (79)
	v • d • e

AmerenUE Cal/away Plant PO Box 620 Fulton, MO 65251 April 22, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 A Ameren UF ULNRC-05511 Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 CALLAWAY PLANT NPDES PERMIT SCHEDULE OF COMPLIANCE CONDITION CONCERNING GROUNDWATER MONITORING Please find enclosed the Union Electric Company (AmerenUE) response to the Missouri Department of Natural Resource questions pertaining to our current NPDES Permit Schedule of Compliance concerning ground water monitoring. Although the enclosed information involves no changes or renewals of the NPDES permit itself, the information concerns a compliance condition(s) associated with the permit.

AmerenUE is therefore submitting the attached in consideration of the reporting provisions of Callaway Plant Operating License NPF-30, Appendix B, Section 3.2.

This letter does not contain any new commitments. Please contact Tom Elwood, Supervising Engineer, Regulatory Affairs and Licensing at 573-676-6479 for any questions you may have regarding this issue.

Sincerely, Luke H. Graessle Manager, Regulatory Affairs

Enclosure:

Ameren letter to the Missouri Department of Natural Resources, dated April 18, 2008.

a subsidiary of Ameren Corporation

ULNRC-05511 April 22, 2008 Page 2 cc:

Mr. Elmo E. Collins, Jr.

Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mohan C. Thadani (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-8G14 Washington, DC 20555-2738

ULNRC date Page 3 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4200 South Hulen, Suite 630 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via Responses and Reports ULNRC Distribution:

C. D. Naslund A. C. Heflin T. E. Herrmann G. A. Hughes S. M. Maglio T. B. Elwood L. H. Graessle S. L. Gallagher L. M. Belsky (NSRB)

Mr. Ron Reynolds, Director (SEMA)

Mr. Edward Gray, Senior REP Planner (SEMA)

Mr. John Campbell, REP Planner (SEMA)

Ms. Diane M. Hooper (WCNOC)

Mr. Dennis Buschbaum (TXU)

Mr. Scott Bauer (Palo Verde)

Mr. Stan Ketelsen (PG&E)

Mr. Scott Head (STP)

Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Mr. Floyd Gilzow (DNR)

Ameren Services One Ameren Plaza 1

1901 Chouteau Avenue Environmental Services P0 Box 66149 314.554.2824 (Phone)

St. Louis, MO 63166-6149 314.554.4182 (Facsimile) 314.621.3222 ggary@ameren.com April 18, 2008 Mr. Robert K. Morrison, P.E., Chief Water Pollution Control Branch Post Office Box 176 Jefferson City, Missouri 65102-0176

SUBJECT:

Callaway Plant Groundwater Monitoring Plan W'Amefen NPDES Schedule of Compliance Condition NPDES Permit No. MO-0098001

Dear Mr. Morrison:

In accordance with your February 22, 2008 letter of request, we are providing detailed information on Callaway's groundwater monitoring program as it pertains to our current NPDES Permit Schedule of Compliance concerning groundwater monitoring.

During recent years, Callaway Plant has developed a fairly comprehensive groundwater monitoring plan as part of our radiological environmental monitoring program. This program is currently in the process of being re-evaluated and further improved to incorporate all of the requirements of the recent industry initiative for groundwater protection. During the past few years, the nuclear power industry established a set of guidelines to improve our groundwater protection programs. In August 2007, the Nuclear Energy Institute developed and issued NEI 07-07, "Industry Ground Water Protection Initiative - Final Guidance Document".

A copy of this document is provided in Attachment E. The industry (including Callaway Plant) has committed to meeting all the requirements of this initiative by August 31, 2008.

In addressing the objective of the Schedule of Compliance (Paragraph C on page 11 of 16) in our current NPDES Permit to implement a groundwater monitoring program that will adequately detect any radiological groundwater contamination originating from the reactor building or proximal structures, Callaway identified three monitoring wells (936, 937B, 937E) and the groundwater sump located plant east of the reactor building containment and the spent fuel pool building.

Utilization of these wells and this sump for radiological release monitoring was proposed in a letter to DNR dated November 28, 2006. We believe monitoring at these locations will provide an early indication of any radiological contamination released to groundwater from leakage of components or equipment located in the a subsidiary of Ameren Corporation

vicinity of the reactor building or proximal structures. These four monitoring locations will be the focus of our response. Please note that additional monitoring wells are located around the power block and at other locations on Ameren property such as along the current blowdown/discharge pipeline. However, we consider these beyond the scope of the NPDES permit condition obligation.

In accordance with your letter, each request for additional information along with Callaway Plant's responses is listed below:

Designation of existing and proposed monitoring wells to be used for the monitoring program, along with their design or construction specifications, including date of installation (if previously installed), screen length, total depth, materials used in construction, methods used for drilling, and logs of borings drilled. In addition, the dimensions and description of the groundwater sump structure should be included; The three monitoring wells we proposed for this requirement (936, 937B and 937E) were originally installed in 1995 to assist in the recovery of diesel fuel oil in the Unit 1 backfill with assistance from DNR and in accordance with the Missouri Department of Natural Resources guidelines for well construction. Monitoring well certification records are provided in Attachment A. Several diagrams containing the location and dimensions of the groundwater sump are also included in this attachment. These wells were installed by drilling through the Category 1 granular backfill (a well graded limestone rock from the Callaway formation) to the Graydon Chert (approximately 30 feet deep). The monitoring wells were installed with a maximum nominal 4" diameter and drilled to the Graydon Chert.

A casing of Schedule 40 PVC pipe for the monitoring wells was installed the entire depth of the wells. The casing included screened sections starting at or near the bottom of the wells and extending to within 8 to 10 feet of the surface. The casing was also centered in the bore hole and backfilled with clean rock or sand to within 2 to 3 feet of the surface. The balance of the borehole was filled with bentonite clay to form a seal around the casing. The groundwater sump consists of a 24 inch corregated metal pipe installed to the Graydon Chert in the Category 1 backfill material and was used for recovery of diesel fuel oil from approximately 1995 to 2000.

Historic water quality data (i.e.; recent tritium sampling efforts) collected from any of the plant site wells should be included in this plan (in tabular format) in an effort to clearly identify the area(s) of contamination resulting from plant operations; A table containing all tritium data from the monitoring program for-the three monitoring wells and the groundwater sump that was initiated in 2006 is included as Attachment B. All tritium concentrations are in pCi/liter. While several positive tritium concentrations are indicated, the levels identified are near the limit of detection and no other radionuclides have been detected in samples obtained from these wells. We believe the sporadic and low concentrations of tritium present in monitoring wells is likely due to washout (tritium present in gaseous

effluent is washed out by rain or snow) in and around the power block area. This has been recognized at other nuclear power plants. Air conditioner condensate collected on-site has confirmed washout is occurring. The NRC recognizes this phenomenon and has issued Regulatory Issue Summary (RIS) 2008-03 to provide guidance to licensees.

Documentation of compliance with all provisions of the Missouri Well Construction Rules contained at 10 CSR 23-4; The monitoring well certification records provided in Attachment A contain documentation of compliance with all provisions of the Missouri Well Construction Rules along with the name of the contractor who completed the well installation.

A summary of site-specific geologic information appropriate for identifying and justifying the hydrostratigraphic zone that is appropriate to monitor, including a discussion of the geologic materials present and their hydrologic properties; Callaway Plant structures are founded on a Graydon Chert conglomerate which consist of gravel to boulder size chert particles in a clay or silt matrix. The chert conglomerate is overlaid with 30 to 40 feet of nonindurated glacial and post glacial deposits consisting of modified loess, accretion-gley, and glacial till. When the plant was constructed, the glacial deposits were excavated and removed down to the Graydon Chert for the entire power block and supporting nuclear safety related buildings except the Ultimate Heat Sink Pond. All power block and safety related buildings are founded on the Graydon Chert or on granular structural fill. The fill material, known as Category 1 Structural Fill, is a well graded limestone rock from the Callaway formation. As the buildings were constructed the excavated areas were backfilled with Category I Structural Backfill, which is very similar to the fill but with a slightly lower density requirement, and capped with a 2 foot thick clay blanket to limit surface water seepage into the ground. The undisturbed areas surrounding the power block still have the original glacial till and loess.

Prior to construction of the plant, Geological Engineers with Dames and Moore performed extensive studies on the geological and groundwater features of the site.

Part of these preconstruction studies included vertical and horizontal permeability rates for site materials. The existing glacial deposits were found to have extremely low permeability rates. Values of vertical permeability determined from laboratory tests of the modified loess, accretion-gley, and glacial till ranged from 5.5 x 10-9 to 4.6 x 10-7 cm/sec. The results of 17 falling head permeameter tests performed in seven piezometers situated in the overburden at the site indicated horizontal permeability's ranging from 4.5 x 10-8 to 4.6 x 10-6 cm/sec with an average of 1.6 x 10-6 cm/sec. The average horizontal permeability rate for the soil at the site is less than 20 inches in a year. The combination of the extremely low permeability rates of the Graydon Chert and natural soil on this plateau with the very high permeability rates of the granular structural backfill has resulted in a persistent shallow perched groundwater condition at the site. Over the years storm water has

entered the power block excavation through various breaks in the clay blanket such as manholes and pipe penetrations at a much faster rate than it can be dispersed which has resulted in a perched groundwater table.

As mentioned above, the Callaway Unit 1 power block is situated on top of approximately 30 feet of Category 1 porous material that was backfilled during plant construction. This backfilled material extends down to the Graydon Chert which exhibits extremely low permeability. The three monitoring wells and the ground water sump were installed within this backfill material, adjacent to and in close proximity to the reactor building and proximal structures. Monitoring wells located within this porous backfill material should provide an early indication of any leakage from the reactor building or proximal structures.

Potentiometric data from any construction-era evaluations of site-wide shallow groundwater as historically collected from any previously installed wells associated with site construction (exact number of wells historically installed, locations, design, purpose, present condition, accessibility, etc.) This data would be very useful in identifying groundwater presence, gradient(s) and other hydro geologic factors associated with groundwater monitoring when devising a groundwater monitoring network; Fifty four piezometers were installed in preconstruction borings within the site area. Attachment C provides potentiometric data referenced in this discussion.

The piezometer locations are shown on Figure 2.4-29. During preconstruction investigative phases, the piezometers were utilized to evaluate different groundwater parameters. The ground-water levels varied with changing rates of precipitation and with the drawdown influence of pumping tests. Readings of water levels in the preconstruction piezometers are given in Table 2.4-23. Prior to start-up of construction, the piezometers were sealed from the bottom to the surface and abandoned.

Ten permanent monitoring piezometers are installed within the plant exclusion area boundary. These piezometers were utilized for monitoring ground-water levels and water quality as required. Piezometer monitoring locations are shown on Figure 2.4-30. To provide a monitoring system that encircles the plant area, locations were selected on the basis of general ground-water gradients. Average permeabilities of the formations monitored are presented in Table 2.4-24. Initial water level readings and intervals monitored are presented in Table 2.4-25. The piezometer monitoring data from construction of the plant is contained in the construction record files and was not available for inclusion in this response.

Additional monitoring was performed in the last two years to support.the Combined Construction/Operating License Application for the propvosed Callaway Unit 2. This data has not been finalize at this time but should be available in July 2008.

The piezometers required from 1 to 3 weeks to stabilize either after installation or after falling head permeameter tests were run. After reaching a static level, the water levels generally had greater fluctuations in the upper units down to and

including the Bushberg Sandstone than in the underlying Callaway and Cotter-Jefferson City formations.

Site figures that display units and structures that are related to potential tritium releases or may affect groundwater flow, including a map of the plant raw water system which has been described as a source of leakage; Attachment D provides several drawings displaying the Callaway Plant site layout.

Callaway Plant drawing 8600-X-88 100 displays the buildings and structures located on-site. An enhanced portion of this drawing has been included to better show the approximate location of the three monitoring wells and the groundwater sump. We note that the primary focus of your letter and the Schedule of Compliance upon which it is based is targeted at detection of potential leakage to groundwater "near the reactor building". Callaway Plant's detection of contamination from normal operation of the air release valves located along the plant discharge line and our prior reporting of our investigation and initial corrective actions is beyond the scope of the terms and conditions of our NPDES permit. Nonetheless, Figure D-2 is included to provide an overview of the Callaway plant discharge pipeline in relationship to the plant site. This figure also indicates the approximate location of sixteen groundwater monitoring wells installed to investigate radioactive contamination due to releases from normal operation of these air release valves.

Site figures that indicate soil and groundwater sampling data and locations associated with known areas of tritium releases (to gain perspective of those soil or groundwater detections in comparison to proposed monitoring well locations);

We note that a comprehensive report prepared by Terracon entitled Discharge Pipeline Manhole Tritium Investigation Phase II has been completed for Callaway Plant and is currently available in draft form. Although beyond the scope of our NPDES permit obligations, this extensive report will be included in its entirety in the 2007 Annual Radiological Environmental Operating Report for Callaway Plant and will be provided to the Missouri DNR on or before May 1, 2008. The Terracon Report will contain figures providing all of the soil and groundwater sample results for the discharge line investigation. In addition, the report will include figures showing the monitoring well locations.

Development of any cross-sections in the area of the proposed monitoring wells, as based on data from well logs, historic construction data, wells and/or below-grade construction features. These cross-sections are requested to depict geologic units, areas of construction excavation and backTill, the hydrostratigraphic zone to be monitored, screened intervals of wells, water levels of wells (potentiometric surface) and any structural features that impact the movement of groundwater (utility or piping trenches);

Attachment F provides plant drawings showing cross-sections of the power block buildings and structures.

Complete list of radionuclide's (including tritium) to be included in the monitoring program; The three monitoring wells along with the groundwater sump are sampled and analyzed quarterly for tritium and primary gamma emitters.

Sampling methodology, handling, and associated laboratory QA/QC information; Attachment G contains a description of the quality assurance/quality control programs required for our contract environmental laboratory. Actual interlaboratory comparison program results are provided each year as Appendix A to the Annual Radiological Environmental Operating Report for Callaway Plant which will be transmitted to the Department of Natural Resources around May 1, 2008.

Proposed schedule for future quarterly monitoring of these wells and protocol for submittal of data.

At this time we are evaluating more general elements of our current groundwater monitoring program, but currently see no justification to change the current program that requires quarterly monitoring of these wells and the groundwater sump. All groundwater monitoring data collected during each calendar year is submitted to the NRC on or before May Is' of the following year in the Annual Radiological Environmental Operating Report for Callaway Plant. A copy of this report is also submitted to the Regional Administrator, Missouri Department of Natural Resources, Central Regional Office. The 2007 Annual Radiological Environmental Operating Report for Callaway Plant will be completed and mailed on or before May 1, 2008.

Additional Comments Installation of the three monitoring wells located in the vicinity of the power block did not require a hydrogeological evaluation since this area was excavated and filled during plant construction. We believe the monitoring program associated with these three wells and the groundwater sump fully addresses the scope and intent of the Schedule of Compliance.

Please note that a separate comprehensive groundwater monitoring program document is currently being prepared to comply with the new requirements of the NEI 07-07 Groundwater Protection Initiative. A copy of groundwater monitoring program document can be provided upon your request (expected completion in early September 2008).

Hydrogeological expertise was utilized for the blowdown/discharge pipeline study.

Terracon, the primary contractor for this study, has performed essentially all of the

recent monitoring well installations, drilled the boring samples, and has collected all environmental water and soil samples. Qualifications for the specific individuals involved can be provided at your request. Samples were shipped directly to Environmental, Inc. Midwest Laboratory for radiological analyses.

Upon request, we can also provide specific qualification information for the environmental laboratory.

We believe that this response contains all the information you have requested concerning the Callaway Plant groundwater monitoring program. Please contact Gail Gary of my staff (314-554-2824) should you need additional information or if you have any further questions.

Finally, in a letter from Mr. Doyle Childers dated April 2, 2007, DNR proposed that Callaway Plant enter a "Cooperative Agreement" with the Missouri Department of Natural Resources associated with environmental management issues to allow staff from the Department's Hazardous Waste Program, Federal Facilities Section (FFS) to oversee any current or future radiological or chemical environmental issues. Based on our current comprehensive environmental radiological monitoring program and the fact that detailed information is and will be provided to the Missouri DNR, we believe that a cooperative agreement is not warranted. Should any leak, spill or release of radioactive material from Callaway Plant to the environment occur, the Missouri DNR will be contacted in a timely manner. In addition, the Annual Radiological Environment Operating Report containing all the detailed radiological environmental information is provided to DNR each year at the same time it is sent to the NRC. In fact, the environmental radiological program at Callaway Plant is assessed routinely and falls under the jurisdiction of the Nuclear Regulatory Commission.

Sincerel, John C. Pozzo Managing Supervisor Water Quality Attachments

ATTACHMENTS A.

Monitoring Well Certification Records and Sketches for Groundwater Sump B.

Tritium Concentation in Monitoring Wells C.

Preconstruction Piezometer Water Level Readings, Permeabilities and Map Table 2.4-23 (Preconstruction Piezometer Water Level Readings)

Table 2.4-24 (Average Permeability for Permanent Piezometers)

Table 2.4-25 (Permanent Piezometer Water Level Readings)

Figure 2.4-29 (Location of Preconstruction Piezometers)

D.

Drawing 86-X-88100 (Property-Site Layout)

Blowup of Power Block Area and Monitoring Wells Terracon Figure D-2 (Map of Discharge Pipeline and Monitoring Wells)

E.

NEI 07-07, Industry Ground Water Protection Initiative - Final Guidance Document, dated August 2007 F.

Cross-Sectional Drawings of the Power Block Fill and Backfill 8600-X-88130 8600-X-88133 8600-X-88134 8600-X-88139 8600-X-88140 G.

Laboratory QA/QC Program

ATTACHMENT A

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ATTACHMENT B

ATTACHMENT B Tritium Located Concentrations in Monitoring Wells Near the Callaway Plant Power Block Date" 936 937B 937E GWS*

1/19/06 195+/-106.

209+/-120*

4/11/06 155+/-82 254+/-88:

7/6/06 191+/-98

<173 10/4/06

'164+/-84 199+/-88

<146 1/9/07 185+/-86 438+/-906 152+/-84' 4/9/07

<180

<180 4/10/07 260+/-99 4/18/07

<180 7/25/07 270+/-85 7/26/07

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GWS - Groundwater Sump All tritium concentrations are in pCi/liter.

Analyses were completed by Environmental, Inc. Midwest Laboratory.

Gamma Isotopics were also completed for each sample with all results indicating less than detectable for other radionuclides.

ATTACHMENT C

CALLAWAY - SA TABLE 2.4-23 PRECONSTRUCTION PIEZOMETER WATER LEVEL READINGS WATER LEVEL DEPTH WATER LEVEL ELEVATION PTFZOMETER DATE PIEZOMETER R-1-20 Interval:

5-20 (3-22)

Graydon chert conglomerate R-1-83 Interval:

47-83 (44-84)

Snyder Creek Formation 9-17-73 9-18-73 9-19-73 9-22-73 9-27-73 10-06-73 10-16-73 11-07-73 1-08-74 2-24-74 6-24-74 8-29-74 10-30-74 9-17-73 9-18-73 9-19-73 9-22-73 9-27-73 10-07-73 10-16-73 11-07-73 1-08-74 2-24-74 6-24-74 8-29-74 10-30-74 9-17-73 9-18-73 9-19-73 9-22-73 9-27-73 10-07-73 10-16-73 11-07-73 1-08-74 2-24-74 6-24-74 3.6 9.7 8.3 14.9 19.9 22.8 22.4 22.8 22.5.

13.6 33.1 32.8 35.8 34.5 34.2 34.2 34.6 33.9 34.5 32.8 33.5 110.2 115.8 111.8 120.6 123.1 127.5 131.9 142.0 147.4 148.0 788.3 785.2 786.6 780.0 775.0 772.1 772.5 772.1 772.4 Dry Dry Dry Dry Dry 778.3 762.1 762.4 759.4 760.7 761.0 761.0 760.6 761.3 760.7 762.4 761.7 681.7 679.2 680.2 674.4 671.9 667.5 663.1 653.0 647.6 647.0 R-1-148 Interval:

115-148 (107-148)

Joachim Formation to Cotter-Jefferson City Formation Dry Effective interval given in parenthesis interval if intervals differ.

Interval are to the nearest foot.

following slotted depths reported Rev. OL-13 5/03

CALLAWAY - SA TABLE 2.4-23 (Sheet 2)

WATER LEVEL DEPTH WATER LEVEL ELEVATION PIEZOMETER DATE R-1-148 (cont'd)

R-2-49 Interval:

29-49 (25-49)

Graydon chert conglomerate to Burlington Formation R-2-179 Interval:

114-179 (109-179)

Callaway Formation to Cotter-Jefferson City Formation R-4-127 8-29-74 10-30-74 9-15-73 9-19-73 9-22-73 9-27-73 10-07-73 10-16-73 11-07-73 1-08-74 2.24-74 6-24-74 8-29-74 10-30-74 9-15-73 9-19-73 9-22-73 9-27-73 10-07-73 10-16-73 11-07-73 1-08-74 2-24-74 8-29-74 10-30-74 8-23-73 9-13-73 9-14-73 9-18-73 9-19-73 9-22-73 9-27-73 10-07-73 10-16-73 11-07-73 1-08-74 2-24-74 6-24-74 8-29-74 10-30-74 6.8 795.3 32.9 772.5 39.9 765.5 39.8 765.6 39.8 765.6 39.9 765.5 41.1 764.3 Frozen above ground surface 43.0 762.4 43.7 761.7 24.7 780.7 36.1 769.3 Dry Dry 123.5 166.4 162.8 173.7 180.0 181.2 182.0 181.4 Dry Dry Dry Interval:

60-127 Snyder Creek Formation to Cotter-Jefferson City-Formation 63.2 72.0 72.3 58.0 55.1 56.3 57.0 60.1 62.4 67.1 74.9 80.5 92.6 95.4 678.6 639.0 642.6 631.7 624.4 624.2 623.4 624.0 755.5 749.9 749.7 764.0 766.9 765.7 765.0

-761.9 759.6 754.9 747.1 741.5 729.4 726.6 Dry Rev. OL-13 5/03

CALLAWAY - SA TABLE 2.4-23 (Sheet 3)

WATER LEVEL DEPTH WATER LEVEL ELEVATION PIEZOMETER DATE R 6 8 Interval:

40-68 (5-68)

Loess, Accretion gley to Graydon chert R-6-208 Interval:

185-208 (180-208)

Cotter-Jefferson City Formation 8-23-73 9-13-73 9-14-73 9-19-73 9-22-73 9-27-73 10-07-73 10-16-73 11-07-73 1-08-74 2-24-74 6-24-74 8-29-74 10-30-74 9-06-73 9-13-73 9-19-73 9-22-73 9-27-73 10-07-73 10-16-73 10-07-73 1-08-74 2-24-74 6-25-74 8-29-74 10-30-74 2-07-75 8-23-73 8-30-73 9-06-73 9-06-73 9-14-73 9-18-73 9-19-73 9-22-73 9-27-73 10-03-73 10-04-73 10-04-73 10-05-73 10-05-73 10-08-73 21.5 25.5 25.5 24.9 25.0 25.2 25.3 25.5 26.2 26.4 26.6 24.8 24.7 25.3 169.3 192.6 199.9 200.9 201.7 202.6 203.2 203.4 203.7 203.3 203.0 203.0 200.4 64.3 64.8 67.0 67.0 67.7 63.4 68.1 65.8 66.7 66.5 66.6 66.6 66.9 66.8 66.7 802.5 801.6 801.6 802.2 802.1 801.9 801.8 801.6 800.9 800.7 800.5 802.4 802.4 801.8 663.5 642.5 635.2 634.2 633.4 45' 632.5 631.9 631.7 631.4 631.8 632.1 632.1 632.4 Plugged @

P-1-87 Interval:

77-87 Graydon chert conglomerate to Bushberg Formation 787.0 786.5 784.3 784.3 785.7 790.0 785.3 787.6 786.7 786.7 786.8 786.8 786.5 786.6 786.7 Rev. OL-13 5/03

CALLAWAY - SA TABLE 2.4-23 (Sheet 4)

WATER LEVEL DEPTH WATER LEVEL ELEVATION PIEZOMETER DATE R-1-87 (cont'd)

P-1-287 Interval:

170-287 (143-287)

Callaway Formation to Cotter-Jefferson City Formation P-lA-27 10-09-73 10-11-73 10-12-73 11-07-73 1-03-74 2-24-74 6-25-74 8-29-74 10-29-74 2-06-75 8-23-73 8-30-73 9-06-73 9-14-73 9-18-73 9-19-73 9-22-73 9-27-73 10-03-73 10-04-73 10-05-73 10-08-73 10-09-73 10-11-73 10-12-73 11-07-73 1-03-74 2-24-74 6-25-74 8-29-74 10-29-74 2-06-75 8-23-73 8-30-73 9-06-73 9-13-73 9-14-73 9-19-73 9-22-73 9-27-73 10-03-73 10-04-73 10-05-73 66.6 66.6 66.5 67.3 66.7 67.7 69.0 67.9 62.8 211.2 211.4 210.0 213.3 213.4 213.3 213.2 213.9 213.3 212.9 213.1 212.9 219.0 220.5 220.2 224.7 223.2 224.5 230.0 253.9 225.1 222.8 642.2 642.0 643.4 640.1 640.0 640.1 640.2 639.5 640.1 640.5 640.3 640.5 634.4 632.9 633.2 628.7 630.2 628.9 623.4 599.5 626.2 628.5 786.8 786.8 786.9 786.1 786.7 785.7 784.4 785.5 790.6 Dry Interval:

87-97 (85-97)

Graydon chert con-glomerate to Snyder Creek Formation 57.9 58.4 58.0 60.1 61.1 60.7 60.9 60.7 60.4 60.9 61.2 793.4 792.9 793.3 794.0 793.0 793.4 793.2 793.4 793.8 793.2 792.9 Rev. OL-13 5/03

CALLAWAY - SA TABLE 2.4-23 (Sheet 5)

WATER LEVEL DEPTH WATER LEVEL ELEVATION PIEZOMETER DATE R-IA-27 (cont'd.)

P-2-69 Interval:

41-69 (47-69)

Graydon chert con-glomerate to Burlington Formation 10-05-73 10-08-73 10-09-73 10-11-73 10-12-73 11-07-73 1-03-74 6-25-74 8-29-74 10-29-74 2-06-75 8-23-73 8-30-73 9-06-73 9-13-73 9-14-73 9-19-73 9-22-73 9-27-73 i0-04-73 10-04-73 10-05-73 10-05-73 10-08-73 10-09-73 10-11-73 10-12-73 11-0.7-73 1-03-74 2-24-74 8-28-74 10-29-74 2-06-75 8-23-73 8-30-73 9-06-73 9-13-73 9-14-73 9-19-73 9-22-73 9-27-73 10-04-73 10-04-73 10-05-73 61.1 60.9 60.6 60.7 60.8 61.6 61.6 63.3 60.2 69.1

66. 9 33.5 33.2 36.5 38.3 38.5 38.0 38.8 38.1 38.3 38.1 38.6 38.6 38.3 38.6 38.2 38.3 39.2 37.5 37.3 36.4 37.2 34.5 112.6 112.5 110.0 113.6 113.4 111.7 111.6 112.1 112.5 112.4 112.7 793.0 793.2 793.5 793.4 793.3 792.5 792.5 790.8 793.9 782.2 784.4 816.2 816.5 813.2 814.0 814.0 814.3 813.5 814.2 814.0 814.2 813.7 813.7 814.0 813.7 814.1 814.0 813.1 814.8 815.0 815.9 816.4 815.2 737.1 737.2 739.7 738.7 738.9 740.6 740.7 740.2 739.8 739.9 739.6 P-2-135 Interval:

115-135 (106-135)

Snyder Creek Formation to Callaway Formation Rev. OL-13 5/03

CALLAWAY - SA TABLE 2.4-23 (Sheet 6)

WATER LEVEL DEPTH WATER LEVEL ELEVATION PIEZOMETER DATE P-2-135 (cont'd.)

P-3-155 Interval:

153-155 (149-155)

Cotter-Jefferson City Formation 10-05-73 10-08-73 10-09-73 10-11-73 10-12-73 11-07-73 1-03-74 2-24-74 8-28-74 10-29-74 2-06-75 9-13-73 9-15-73 9-19-73 9-22-73 9-27-73 10-03-73 10-05-73 10-08-73 10-11-73 10-12-73 11-07-73 1-03-74 2-24-74 6-25-74 8-28-74 10-28-74 2-06-75 8-30-73 9-06-73 9-13-73 9-15-73 9-19-73 9-22-73 9-27-73 10-04-73 10-12-73 11-07-73 1-03-74 2-24-74 6-25-74 8-29-74 10-29-74 2-06-75 112.6 112.5 112.5 112.4 112.4 114.5 115.8 117.6 120.0 126.7 130.0 155.3 155.9 156.0 156.0 155.6 155.6 155.9 155.88 155.8 156.0 157.5 158.0 739.7 739.8 739.8 739.9 739.9 737.8 736.5 734.7 732.3 725.6 719.7 701.1 700.6 700.4 700.4 700.8 700.8 700.5 700.6 700.6 700.4 598.9 698.4 Dry Dry Dry Dry Dry P-4-115 Interval:

95-115 (93-120)

Bushberg Formation to Snyder Creek Formation 38.7 35.3 36.1 36.0 35.7 35.5 34.9 34.7 34.8 35.1 34.1 33.1 32.9 32.3 33.5 30.8 815.0 818.4 817.6 817.7 818.0 818.2 818.8 819.0 818.9 818.6 819.6 820.6 820.8 821.4 820.2 820.6 Rev. OL-13 5/03

CALLAWAY - SA TABLE 2.4-23 (Sheet 7)

WATER LEVEL DEPTH WATER LEVEL ELEVATION PIEZOMETER DATE P-5A-89 Interval:

77-89 (72-89)

Graydon chert con-glomerate to Snyder Creek Formation P-SA-153 Interval:

113-153 (107-156) 9-14-73 9-17-73 9-19-73 9-22-73 9-27-73 10-03-73 10-04-73 10-05-73 10-08-73 10-11-73 10-12-73 11-07-73 1-03-74 2-24-74 6-25-74 10-29-74 2-07-75 9-14-73 9-17-73 9-19-73 9-22-73 9-27-73 10-03-73 10-04-73 10-05-73 10-08-73 10-11-73 10-12-73 11-07-73 1-03-74 2-24-74 6-25-74 8-28-74 10-29-74 2-07-75 8-08-73 8-15-73 8-23-73 8-30-73 9-06-73 9-13-73 9-14-73 9-19-73 23.0 62.0 61.2 63.8 62.8 62.9 63.0 63.3 62.9 63.4 62.8 63.4 63.0 62.9 61.1 62.1 59.1 83.5 119.9 130.2 136.5 145.8 146.0 146.2 146.4 146.2 146.1 146.3 147.7 154.8 147.0 152.8 79.0 82.3 82.9 83.5 83.0 86.6 86.5 80.9 820.1 783.2 784.0 781.4 782.4 782.3 782.2 781.9 782.3 781.8 782.4 781.8 782.2 782.3 784.1 781.0 784.0 759.6 725.6 715.3 709.0 699.7 699.5 699.3 699.1 699.3 699.4 699.2 697.8 690.7 698.5 690.3 767.8 764.5 763.9 763.3 763.8 763.2 763.3 768.9 Callaway Formation to Cotter-Jefferson City Formation P-6-91 Dry Dry Dry Interval:

77-91 (74-91)

Burlington Formation to Snyder Creek Formation Rev. OL-13 5/03

CALLAWAY - SA TABLE 2.4-23 (Sheet 8)

WATER LEVEL DEPTH WATER LEVEL ELEVATION PIEZOMETER DATE P-6-91 (cont'd) 9-22-73 9-27-73 10-04-73 10-05-73 10-08-73 10-09-73 10-11-73 10-12-73 11-07-73 1-03-74 2-24-74 6-25-74 8-28-74 10-28-74 2-06-75 9-13-73 9-17-73 9-19-73 9-22-73 9-27-73 10-04-73 10-05-73 10-08-73 10-09-73 10-11-73 10-12-73 11-07-73 1-03-74 2-24-74 6-25-74 8-29-74 10-28-74 82.7 84.2 84.9 85.0 85.4 85.7 90.0 85.7 86.7 87.2 88.3 88.5 767.1 765.6 764.9 764.8 764.4 764.1 759.8 764.1 763.1 762.6 761.5 761.3 Dry Dry Dry P-6A-83 Interval:

13-83 (5-83 Loess, Accretion gley to Burlington Formation 38.8 40.6 38.6 45.1 61.6 67.2 67.8 68.4 68.6 68.7 69.0 72.9 73.3 72.5 80.6 72.5 74.6 811.1 809.3 811.3 804.8 788.3 782.7 782.1 781.5 781.3 781.2 780.9 777.0 776.6 777.4 769.3 777.4 775.3 Piezometer Plugged @ 77.5' P-6A-123 Interval:

113-123 (109-123)

Callaway Formation 9-13-73 9-17-73 9-19-73 9-22-73 9-27-73 10-04-73 10-05-73 10-08-73 10-09-73 10-11-73 122.1 125.3 130.2 107.8 117.5 121.0 121.5 122.5 125.6 122.9 728.0 724.8 719.9 742.3 732.6 729.1 728.6 727.6 724.5 727.2 Rev. OL-13 5/03

CALLAWAY - SA TABLE 2.4-23 (Sheet 9)

WATER LEVEL DEPTH WATER LEVEL ELEVATION PIEZOMETER DATE P-6A-123 (cont'd) 10-12-73 11-07-73 1-03-74 2-24-74 122.9 126.1 125.0 727.2 724.0 725.1 PVC Pipe blocked

@ 2.2' P-7-47 Interval:

42-47 (41-47)

Till To Graydon chert conglomerate 8-23-73 8-30-73 9-06-73 9-13-73 9-15-73 9-18-73 9-19-73 9-22-73 9-27-73 10-03-73 10-04-73 10-05-73 10-08-73 10-11-73 10-12-73 11-07-73 1-03-74 2-25-74 6-25-74 8-29-74 10-28-74 2-06-75 8-31-73 9-06-73 9-24-73 9-27-73 10-03-73 10-05-73 10-08-73 10-11-73 10-12-73 11-07-73 1-03-74 2-25-74 6-25-74 8-29-74 10-28-74 2-06-75 27.0 48.6 48.6 45.7 28.2 34.1 39.6 43.1 43.1 44.3 44.7 44.9 45.0 47.9 Dry Dry Dry Dry Dry Dry Dry Dry 824.5 804.7 804.7 807.6 825.1 819.2 813.7 810.2 810.2 809.0 808.6 808.4 808.3 805.4 P-8-155 Interval:

116-155 (113-155)

Callaway Formation to Cotter-Jefferson City Formation 110.3 137.0 155.6 156.4 157.0 157.2 157.3 157.2 157.2 157.6 157.1 157.6 155.0 746.2 719.5 703.6 702.8 702.2 702.0 701.9 702.0 702.0 701.6 702.1 701.6 701.5 Dry Dry Dry Rev. OL-13 5/03

CALLAWAY - SA TABLE 2.4-23 (Sheet 10)

PIEZOMETER WATER LEVEL DEPTH DATE WATER LEVEL ELEVATION P-9-75 Interval:

65-75 (40-75)

Graydon chert conglomerate to Burlington Formation P-10-145 8-23-73 8-30-73 9-06-73 9-13-73 9-15-73 9-19-73 9-22-73 9-27-73 10-04-73 10-05-73 10-08-73 10-11-73 10-12-73 11-07-73 1-03-74 2-24-74 6-25-74 8-28-74 10-29-74 2-07-75 8-23-73 8-30-73 9-06-73 9-13-73 9-15-73 9-19-73 9-22-73 9-27-73 10-04-73 10-05-73 10-08-73 10-11-73 10-12-73 11-07-73 1-03-74 2-24-74 6-25-74 8-24-74 10-29-74 2-07-75 35.8 36.5 33.2 38.3 38.9 38.3 38.5 38.3 38.6 38.8 38.6 38.5 38.4 39.1 39.1 42.5 37.5 38.2 39.3 36.2 46..8 54.3 71.8 73.0 73.4 54.8 56.9 59.9 62.0 62.5 63.0 63.6 63.8 68.2 70.0 71.7 72.7 75.4 75.6 812.5 811.8 815.0 811.7 811.1 811.7 811.5 811.7 811.4 811.2 811.4 811.6 811.6 810.9 810.9 807.5 812.5 811.8 809.0 812.1 801.5 794.0 776.5 777.1 776.7 795.3 793.2 790.2 788.1 787.6 787.1 786.5 786.3 781.9 779.4 778.4 777.4 772.9 772.7 Interval:

125-145 (111-145)

Snyder Creek Formation to Cotter-Jefferson City Formation Dry Rev. OL-13 5/03

CALLAWAY - SA TABLE 2.4-23 (Sheet 11)

PIEZOMETER WATER LEVEL DEPTH WATER LEVEL ELEVATION DATE P-11-82 Interval:

77-82 (75-82)

Graydon chert con-glomerate to Snyder Creek Formation 8-23-73 8-30-73 9-06-73 9-13-73 9-15-73 9-19-73 9-22-73 9-27-73 10-04-73 10-05-73 10-08-73 10-11-73 10-12-73 11-07-73 1-03-74 2-24-74 6-25-74 8-28-74 10-29-74 2-07-75 8-23-73 74.8 74.7 78.2 80.7 81.2 80.6 80.5 80.6 82.3 82.7 84.3 83.3 83.3 83.9 83.5 83.1 80.5 83.4 82.0

.776.2.

776.3 772.8 772.3 771.8 772.4 772.5 772.4 770.7 770.3 768.7 769.7 769.7 769.1 769.5 769.9 772.5 769.6 769.0 Dry P-12-81 Interval:

Piezometer In-operative plugged

@ 2.3' 45-81 (41-81)

Graydon chert conglomerate P-13-73 Interval:

63-73 (61-73)

Graydon chert con-glomerate to Snyder Creek Formation 8-23-73 8-30-73 9-06-73 9-13-73 9-15-73 9-19-73 9-22-73 9-27-73 10-04-73 10-05-73 10-08-73 10-11-73 10-12-73 11-07-73 1-03-74 2-25-74 6-25-74 29.2 31.4 31.0 32.6 33.0 33.0 33.9 32.7 32.8 33.1 32.8 33.5 32.6 33.1 32.7 32.1 31.6 818.8 816.6 817.0 817.2 816.7 816.7 815.8 817.0 816.9 816.6 816.9 816.2 817.1 816.6 817.0 817.6 818.1 Rev. OL-13.

5/03

CALLAWAY - SA TABLE 2.4-23 (Sheet 12)

WATER LEVEL DEPTH WATER LEVEL ELEVATION PIEZOMETER DATE P-13-73 (cont'd)

P-15-78 Interval:

42-78 Graydon chert conglomerate 8-28-74 10-29-74 8-30-73 9-06-73 9-13-73 9-15-73 9-19-73 9-22-73 9-27-73 10-03-73 10-05-73 10-08-73 10-11-73 10-12-73 10-13-73 11-07-73 1-03-74 2-24-74 6-25-74 8-29-74 10-28-74 2-07-75 8-30-73 9-13-73 9-15-73 9-19-73 9-22-73 9-27-73 10-03-73 11-07-73 1-03-74 2-25-74 6-25-74 8-29-74 10-28-74 9-13-73 9-15-73 9-19-73 9-22-73 9-27-73 10-04-73 10-05-73 31.4 33.1 49.0 75.0 77.3 74.9 75.5 76.9 77.5 78.8 77.8 78.5 77.9 76.8 78.8 79.5 Dry Dry Dry Dry Dry Dry 818.3 816.6 804.8 778.8 777.7 780.1 779.5 778.1 777.5 776.2 777.2 776.6 777.1 778.2 776.2 775.5 P-16-78 Interval:

53-78 Graydon chert con-glomerate to Bushberg Formation 31.4 41.0 42.0 37.6 39.3 42.2 45.7 47.6 47.2 812.0 803.5 802.5 806.9 805.2 802.3 798.8 796.9 797.3 Dry Dry Dry Piezometer Plug-ged @ 47.5' P-17-127 Interval:

97-127 119.2 120.6 117.4 117.9 115.0 116.8 118.8 719.5 718.1 721.3 720.8 723.7 722.0 719.9 Callaway Formation Rev. OL-13 5/03

CALLAWAY - SA TABLE 2.4-23 (Sheet 13)

WATER LEVEL DEPTH WATER LEVEL ELEVATION PIEZOMETER DATE P-17-127 (cont'd)

P-22-304 Interval:

130-304 (122-304)

Callaway Formation to Cotter-Jefferson City Formation PS-IA-51.3 Interval:

26-51 (24-53)

Graydon chert conglomerate PS-lB-20 Interval:

5-19 (5-20)

Loess, Accretion gley, Till 10-08-73 10-11-73 10-12-73 11-07-73 1-03-74 2-25-74 6-25-74 10-28-74 2-07-75 9-21-73 9-22-73 9-27-73 10-03-73 10-05-73 10-08-73 10-11-73 10-12-73 11-09-73 1-03-74 2-25-74 6-25-74 8-29-74 10-28-74 12-13-73 12-22-73 1-04-74 1-08-74 2-25-74 6-26-74 8-29-74 10-28-74 12-23-74 12-13-73 12-22-73 1-04-74 1-08-74 2-25-74 6-26-74 8-29-74 10-28-74 12-23-74 2-07-75 118.3 118.7 118.7 121.7 121.2 121.9 122.5 119.6 244.2 262.8 269.5 269.3 269.6 269.0 269.2 269.3 270.1 269.6 270.1 262.0 267.8 270.7 Dry 720.5 720.0 720.0 717.1 717.5 716.8 716.2 716.7 600.7 582.1 575.4 575.6 575.3 576.0 575.7 575.6 574.8 575.3 574.8 582.9 577.1 574.2 53.6 54.0 54.9 53.8 29.1 26.3 28.5 25.6 12.4 Dry Dry Dry Dry Dry Dry Dry Dry Dry Dry 787.0 786.6 785.7 785.8 811.5 814.3 812.1 815.0 828.1 Rev. OL-13 5/03

CALLAWAY - SA TABLE 2.4-23 (Sheet 14)

WATER LEVEL DEPTH WATER LEVEL ELEVATION PIEZOMETER DATE PS-2-33 Interval:

29-33 (28-33)

Graydon chert conglomerate PS-3-35 Interval:

30-35 (29-35) 12-13-73 12-22-73 1-04-74 1-08-74 2-25-74 6-26-74 8-29-74 10-28-74 12-23-74 11-19-75 1-28-76 2-23-76 3-26-76 12-13-73 12-22-73 1-04-74 1-08-74 2-25-74 6-26-74 8-28-74 10-28-74 12-23-74 2-06-75 11-19-75 1-22-76 2-23-76 3-26-76 12-17-73 12-22-73 1-04-74 1-08-74 2-25-74 6-26-74 8-29-74 10-28-74 12-23-74 30.2 23.9 19.7 19.1 17.6 21.4 15.3 19.0 15.7 12.0 14.0 14.0 17.0 29.4 25.8 24.2 24.0 23.9 26.7 24.4 25.0 25.2 25.3 22.0 23.0 23.0 24.0 31.4 30.0 30.3 29.6 28.7 32.4 22.1 29.6 27.0 809.7 816.0 820.2 820.8 822.3 818.5 824.6 820.9 824.2 820.5 822.5 822.5 823.5 813.3 816.9 818.5 818.7 818.8 816.0 818.3 817.7 817.5 817.4 814.1 815.1 815.1 816.1 817.8 819.2 818.9 819.6 820.5 816.8 827.1 819.6 822.2 Graydon chert conglomerate PS-4A-84.5 Interval:

38-85 Graydon chert conglomerate Rev. OL-13 5/03

CALLAWAY - SA TABLE 2.4-23 (Sheet 15)

WATER LEVEL DEPTH WATER LEVEL ELEVATION PIEZOMETER DATE PS-4B-32.5 Interval:

7-33 (5-33)

Loess, Accretion gley, Till PS-5-40 Interval:

36-40 (35-41)

Graydon chert conglomerate 12-17-73 12-22-73 1-04-74 1-08-74 2-25-74 6-26-74 8-29-74 10-28-74 12-23-74 2-07-75 12-15-73 12-22-73 1-04-74 1-08-74 2-25-74 6-26-74 8-29-74 10-28-74 12-23-74 12.23-74 11-19-75 1-28-76 2-29-76 3-26-76 12-17-73 12-22-73 1-04-74 1-08-74 2-24-74 6-25-74 8-29-74 10-29-74 12-23-74 11-19-75 1-22-76 2-23-76 3-26-76 26.5 26.3 26.6 26.3 26.1 25.6 24.8 27.8 24.8 25.1 37.6 37.1 30.1 29.6 29.2 27.3 27.2 30.3 30.3 26.8 21.0 25.0 26.5 822.6 822.8 822.5 822.8 823.0 823.5 824.3 821.3 824.3 824.0 814.1 814.6 821.6 822.1 822.5 824.4 824.5 821.4 821.4 824.9 819.1 823.1 824.6 Under Water PS-6-36.7 Interval:

32-37 Graydon chert conglomeratge 26.5 26.5 26.7 26.5 26.1 28.5 24.5 28.2 25.7 22.0 23.0 24.0 25.0 821.4 821.4 821.2 821.4 821.8 819.4 823.4 819.7 822.2 818.5 819.5 820.5 821.5 Rev. OL-13 5/03

CALLAWAY - SA TABLE 2.4-23 (Sheet 16)

WATER LEVEL DEPTH WATER LEVEL ELEVATION PIEZOMETER DATE DATE HS-1-31 Interval:

5-31 (5-32)

Modified Loess, Accretion gley, Till HS-2-33 Interval:

31-33 (31-34)

Graydon chert conglomerate HS-3-30.7 12-18-73 12-22-73 1-04-74 1-08-74 2-25-74 6-25-74 8-28-74 10-28-74 12-23-74 2-06-75 11-19-75 1-28-76 2-29-76 3-26-76 12-17-73 12-22-73 1-04-74 1-08-74 2-25-74 6-25-74 8-28-74 10-28-74 12-23-74 2-06-75 12-18-73 12-22-73 1-04-74 1-08-74 2-25-74 6-25-74 8-28-74 10-28-74 12-23-74 2-06-75 12-18-73 12-22-73 1-04-74 1-08-74 2-25-7 4 6-25-74 8-28-74 10-28-74 Interval:

9.0 18.0 19.8 21.9 22.6 22-.5 17.0 20.0 29-31 (28-31) 35.1 34.8 11.1 23.1 24.5 24.6 24.3 24.2 32.4 27.5 26.6 16.9 20.4 19.6 19.2 18.6 20.5 18.7 6.9 5.9 5.6 6.2 6.5 7.3 8.6 Dry Dry Dry Dry 841.3 832.3 830.5 828.4 827.7 827.8 822.3 Under Water 827.3 Under Water Dry Dry Dry 810.4 810.7 834.4 822.4 821.0 820.9 821.2 821.3 808.5 813.4 814.3 824.0 820.0 821.3 821.7 822.3 820.4 818.9 830.7 831.7 832.0 831.4 831.1 830.3 829.0 Graydon chert conglomerate HS-4-19.5 Interval:

5-20 Modified Loess, Accretion gley, Till Rev. OL-13 5/03

CALLAWAY - SA TABLE 2.4-23 (Sheet 17)

WATER LEVEL DEPTH WATER LEVEL ELEVATION PIEZOMETER DATE HS-4-19.5 (cont'd.)

P-80ML Interval:

4-8 (3-9)

Modified Loess u

P-80AG Interval:

14-17 (13-18) 12-23-74 1-14-75 2-06-75 12-19-74 12-20-74 12-23-74 1-06-75 1-07-75 1-14-75 1-17-75 1-18-75 1-20; 1-21; 1-22; 1-24-75 1-25-75 12-19; 12-20-74 12-23-74 1-06-75 1-07-75 1-14-75 1-17-75 1-18-75 1-20; 1-21; 1-22; 1-24-75 1-25-75 12-19-74 12-20-74 12-23-74 1-06-74 1-07-75 1-14-75 1-18-75 1-18-75 1-20; 1-21; 1-22;;1-24-75 1-25 Dry Dry Dry Dry Dry Dry Dry Dry Dry 6.5 7.8 5.3 5.0 4.5 5.1 4.1 4.2 5.1 4.1 4.1 4.1 4.1 831.1 829.8 832.3 834.7 835.2 834.6 835.6 835.5 834.6 835.6 835.6 835.6 835.6 Accretion gley P-80T Interval:

23-27 (22-28)

Till 823.3 16.3 16.3 16.5 16.1 17.2 16.4 16.4 16.4 16.4 16.4 823.4 823.4 823.2 823.6 822.5 823.3 823.3 823.3 823.3 823.3 Rev. OL-13 5/03

CALLAWAY - SA TABLE 2.4-23 (Sheet 18)

WATER LEVEL DEPTH WATER LEVEL ELEVATION PTE2OMETER DATE PIEZOMETER DEPTH P-104ML Interval:

4-9 (3-10)

Modified Loess P-104AG Interval:

14-17 (13-18)

Accretion 12-19-74 12-20-74 12-23-74 1-06-75 1-07-75 1-14-75 1-15-75 1-17-75 1-18-75 1-20; 1-21; 1-22; 1-24-75 1-25-75 12-19-74 12-20-74 12-23-74 1-06-75 1-07-75 1-14-75 1-15-75 1-17-75 1-18-75 1-20; 1-21; 1-22; 1-23-75 1-25-75 12-19-74 12-20-74 12-23-74 1-06-75 1-07-75 1-14-75 1-15-75 1-17-75 1-18-75 1-20; 1-21; 1-22; 1-24-75 1-15-75 Dry Dry Dry Dry Dry Dry Dry Dry Dry Dry Dry 15.9 16.0 16.2 16.3 16.4 16.5 16.3 16.7 16.6 16.6 16.6 25.1 24.3 23.6 22.8 22.8 22.8 22.8 22.7 22.6 22.6 22.6 824.5 824.4 824.2 824.1 824.0 823.9 824.1 823.7 823.8 823.8 823.8 815.2 816.0 816.7 817.5 817.5 817.5 817.5 817.6 817.7 817.7 817.7 P-104T Interval:

24 (23-28)

Till Rev. OL-13 5/03

CALLAWAY - SA (Sheet 1 of 1)

TABLE 2.4-24 AVERAGE PERMEABILITY FOR PERMANENT MONITORING PIEZOMETERS AVERAGE GEOLOGIC PERMEABILITYC UNIT(s)a PIEZOMETERb (cm/sec)

Dc, Ojc M1 8.3 x 10-7 Mbs, Dsc M2 1.4 x 10-6 Mbs, Dsc, Ojc M3 8.5 x 10-7 Pgc M4 8.5 x 10-6 Ojc (Middle)

M5 3.4 x 10-6 Pgc M6 8.5 x 10-6 Dc M7 4.1 x 10-6 Ojc (Upper)

M8 3.7 x 10-6 Ojc (Middle)

M9 3.4 x 10-6 Pgc M10 8.5 x 10-6 a

Geologic units are designated as follows:

Pgc - Pennsylvanian Graydon Chert Conglomerate; Mbs - Mississippian Bushberg Sandstone; Dsc - Devonian Snyder Creek Shale; Dc - Devonian Callaway Limestone; Ojc - Ordovician Cotter - Jefferson City Formation.

b Piezometer effective intervals are given in FSAR Table 2.4-25. Piezometer locations are shown on FSAR Figure 2.4-30.

c Averages taken from similar depths tested.

Rev. OL-16a 12/07

CALLAWAY - SA (Sheet 1 of 1)

TABLE 2.4-25 PERMANENT PIEZOMETER WATER LEVEL READINGS PIEZOMETER EFFECTIVE INTERVAL*

(feet)

UNITS SCREENED TOP OF CASING ELEVATION (MSL)

DATE WATER LEVEL DEPTH (BELOW TOP OF CASING)

(feet)

WATER LEVEL ELEVATION (MSL)

REMARKS M1 M2 M3 M4 M5 M6 M7 M8 M9 M10 97-169 83-138 72-125 35-58 234-300 24-45 95-126 130-170 230-296 40-51 Callaway Upper Cotter-Jefferson City Bushberg Snyder Creek Callaway Bushberg Snyder Creek Callaway Graydon Middle Cotter-Jefferson City Graydon Callaway Upper Cotter-Jefferson City Middle Cotter-Jefferson City Graydon 845.2 853.02 847.41 847.96 848.37 829.42 829.81 829.57 829.90 845.12 7/25/79 8/9/79 7/25/79 8/9/79 7/25/79 8/9/79 7/25/79 8/9/79 7/25/79 8/9/79 7/25/79 8/9/79 7/25/79 8/9/79 7/25/79 8/9/79 7/25/79 8/9/79 7/25/79 8/9/79 82.69 82.84 119.20 126.17 51.81 57.05 263.37 32.74 33.05 124.68 125.68 117.72 117.77 267.79 266.83 34.18 34.90 770.33 770.78 728.21 721.24 796.15 790.91 585.05 796.68 796.37 705.13 704.13 711.85 711.80 562.11 563.07 810.94 810.22 Dry Dry Possibly not stabilized Possibly not stabilized 7/25/79 not completed I

Effective interval depths reported to nearest foot below ground.

Rev. OL-16a 12/07

ATTACHMENT D

THIS PAGE IS AN OVERSIZED DRAWING OR

FIGURE, THAT CAN BE VIEWED AT THE RECORD TITLED:

"PROPERTY-SITE LAYOUT OWNER CONTROLLED AREA AND SURROUNDING AREA, FSAR FIGURE 1.2-44, REV. 59."

WITHIN THIS PACKAGE... OR BY SEARCHING USING THE D-01X

200 400 836

ATTACHMENT E

NEI 07-07 [Final]

INDUSTRY GROUND WATER PROTECTION INITIATIVE - FINAL GUIDANCE DOCUMENT August 2007

NEI 07-07 [Final]

Nuclear Energy Institute INDUSTRY GROUND WATER PROTECTION INITIATIVE m FINAL GUIDANCE DOCUMENT August 2007 Nuclear Energy Institute, 1776 1 Street N. W., Suite 400, Washington D.C. (202.739.8000)

ACKNOWLEDGEMENTS NEI appreciates the extensive efforts of the utility members of the Ground Water Protection Task Force in developing and reviewing this document, as well as their utility management's support for the members' participation.

Jim Breeden, Dominion Al Gould, Florida Power & Light Larry Haynes, Duke Ziggy Karpa, Exelon Geoff Schwartz, Entergy Bill Wendland, American Nuclear Insurers Kathleen Yhip, Southern California Edison Rita Sipe, Duke (representing the NEI Communications Task Force)

NEI also extends its thanks to the following organizations who were instrumental in the completion of this guidance:

Participants and presenters in the February 8-9, 2007 Groundwater Protection Workshop to identify lessons learned including NEI member companies, the Nuclear Regulatory Commission, as well as others. A special acknowledgement is accorded to community representatives who made significant input at this conference:

Lori Hucek - Kewaunee County Emergency Management Hugh Curley - Connecticut Yankee Community Decommissioning Advisory Committee The following persons also made significant contribution related to the development of the Groundwater Protection Initiative Interim Guidelines during 2006:

Mark Rigsby, Progress Energy Terry Cellmer, Public Service Electric & Gas John Gaffniey, Arizona Public Service Don Mayer, Entergy Acknowledgement is also due to various member companies for their comments on the development of the Groundwater Protection Initiative Interim Guidelines during 2006 and various drafts of this final guidance during 2007.

NOTICE Neither NEI, nor any of its employees, members, supporting organizations, contractors, or consultants make any warranty, expressed or implied, or assume any legal responsibility for the accuracy or completeness of, or assume any liability for damages resulting from any use of, any information apparatus, methods, or process disclosed in this report or that such may not infringe privately owned rights.

7NEI 07-07 (Final)

August 2007 EXECUTIVE

SUMMARY

NEI 07-07 was developed to describe the industry's Ground Water Protection Initiative. The Ground Water Protection Initiative identifies actions to improve utilities' management and response to instances where the inadvertent release of radioactive substances may result in low but detectible levels of plant-related materials in subsurface soils and water. The inadvertent releases addressed by this Initiative fall outside the current requirements of the Nuclear Regulatory Commission (NRC) and are well below the NRCs limits that ensure protection of public health and safety. Planned liquid and airborne releases performed in accordance with NRC's regulations are not included in the scope of the Initiative or this document. The Initiative also includes guidance on how the utilities should communicate with their stakeholders about those instances.

The Ground Water Protection Initiative identifies those actions necessary for implementation of a timely and effective ground water protection program. In addition, objectives are specified to accomplish each action and the acceptance criteria to demonstrate that the objectives have been met. If a licensee reaches an agreement on communication with their stakeholders that differs from the guidance in this document, that difference shall be documented and retained as part of plant records.

It is expected that this Initiative will be implemented by each member company currently operating or decommissioning a nuclear power plant and by each member company constructing a new plant after year 2006. In the event that new or amended NRC regulations are enacted that address ground water protection or inadvertent releases of radioactive liquids, this Initiative should be revisited by the Nuclear Strategic Issues Advisory Committee.

i

NEI 07-07 (Final)

August 2007 TABLE OF CONTENTS EXECUTIVE SUMMIVARY..............................................................................

I I NTRODUCTION.....................................................................................2.

PURPOSE..........................................................................................

1.

BACKGROUND....................................................................................

1

1.

GROUND WATER PROTECTION PROGRAM...............................................

3 OBJECTIVE 1.1 SITE HYDROLOGY AND GEOLOGY................................

3 OBJECTIVE 1.2 SITE RISK ASSESSMENT...............................................

4 OBJECTIVE 1.3 ON-SITE GROUND WATER MONITORING........................ 5 OBJECTIVE 1.4 REMEDIATION PROCESS..............................................

5 OBJECTIVE 1.5 RECORD ]KEEPING.......................................................

6 2

COMVMUNICATION..................................................................................................

6 OBJECTIVE 2.1 STAKEHOLDER BRIEFING............................................

6 OBJECTIVE 2.2 VOLUNTARY COMMUNICATION...................................

7 OBJECTIVE 2.3 THIRTY-DAY REPORTS...............................................

10 OBJECTIVE 2.4 ANNUAL REPORTING.................................................

11 3

PROGRAM OVERSIGHT....................................................................

+/-12 OBJECTIVE 3.1 PERFORM A SELF-ASSESSMENT...................................

12 OBJECTIVE 3.2 REVIEW THE PROGRAM UNDER THE AUSPICES OF NEI... 12 GLOSSARY.......................................................................................

13 ATTACHMENT 1................................................................................

14 ATTACHMENT 2................................................................................

15 APPENDIX A......................................................................................

16 APPENDIX B......................................................................................

17 111

NEI 07-07 (Final)

August 2007 INDUSTRY GROUND WATER PROTECTION INITIATIVE - FINAL GUIDANCE DOCUMENT INTRODUCTION Over the last ten years, there have been instances of nuclear power plants and materials licensees detecting contamination from inadvertent releases of licensed material to soil and/or groundwater. While none of the identified instances has threatened public health and safety or compromised environmental protection, local stakeholders have expressed concern.

Under the Industry Ground Water Protection Initiative (GPI), each member company operating or decommissioning a nuclear power plant was required to develop and implement a site-specific/company ground water protection program to assure timely and effective management of situations involving inadvertent releases of licensed material* to ground water* and to implement voluntary* communication programs by July 31, 2006. Each member company constructing a new plant after year 2006 shall develop the appropriate site procedures and/or programs to meet the GPI and implement them prior to initial receipt of nuclear fuel. An effective, technically sound ground water protection program may take at least a year to implement and requires on-goinig review'and evaluation.

PURPOSE The Industry Ground Water Protection Initiative will help licensees to:

1. Improve management of situations involving inadvertent radiological releases that getý into ground water.

2. Improve communication with external stakeholders to enhance trust and confidence on the part of local communities, States, the NRC, and the public in the nuclear industry's commitment to a high standard of public radiation safety and protection of the environment.

This Industry Initiative only-applies to licensed radioactive materials that are or were generated as a result of plant operations BACKGROUND Nuclear power plant licensees are required to control and monitor releases of radioactive liquids and airborne materials to ensure that they remain below regulatory limits anddo not pose a threat to public health and safety. Over time, licensees have progressively reduced their releases to the environment such that individuals living near these facilities typically would not receive more than I millirem per year due to these controlled discharges. Licensees establish programs and procedures to carefully control radioactive material, however, leaks and spills occasionally occur wherever indicated, see glossary I

NEI 07-07 (Final)

August 2007 and equipment can fail. As plants began to undergo decommissioning in the late 1990s to early 2000s, instances of subsurface and/or ground water contamination were identified. In addition, several operating facilities also identified ground water contamination resulting from spills and leaks or equipment failure. In one instance, low levels of licensed material were detected in a private well located on property adjacent to a nuclear power plant.

The industry recognized that these instances of inadvertent contamination posed a public confidence challenge even though the releases themselves were not a significant public health issue. In May 2006, the U.S. commercial nuclear power plants adopted the Nuclear Energy Institute (NEI) Groundwater Protection Initiative (GPI) (Attachment 1). The Nuclear Strategic Issues Advisory Committee of NEI unanimously voted to implement these voluntary measures to minimize the potential. for inadvertent releases of radioactive liquids to the environment and to enhance public trust and confidence in the industry.

Working in parallel, the NRC formed a Liquid Radioactive Release Lessons Learned Taskforce to assess the inadvertent release of radioactive liquid to the environment at power reactor sites.

On July 10, 2006, the NRC issued Information Notice 2006-13 "Ground-water Contamination -

due to Undetected Leakage of Radioactive Water" that summarized its review of radioactive contamination of ground water at multiple facilities as a result of undetected leakage from facility structures, systems, or components that contain or transport radioactive fluids. Licensees were instructed to review the information for applicability to their facilities and consider actions, as appropriate, to avoid similar problems. The final report of the NRC's Taskforce was issued on September 1, 2006 and included twenty-six recommendations for additional consideration by the NRC. The report stated:

"The most significant conclusion of the task force regarded public health impacts.

Although there have been a number of industry events where radioactive liquid was released to the environment in an unplanned and unmonitored fashion, based on the data available, the task force did not identify any instances where the health of the public was impacted."

Nuclear power provides a significant portion of the electricity needed by society today and must be part of the future diversified generation mix, helping to reduce this nation's reliance on fossil fuels and to reduce the emission of greenhouse gases. Each licensee has voluntarily implemented the Groundwater Protection Initiative and will continue to do so in the future, recognizing that public confidence and trust are critical to the continued successful operation of their facilities.

2

NEI 07-07 (Final)

August 2007 I

GROUND WATER PROTECTION PROGRAM ACTION 1 Improve management of situations involving inadvertent radiological releases that get into ground water Each licensee shall develop a written Ground Water Protection Initiative (GPI) program that describes their approach to assure timely detection and effective response to situations involving inadvertent radiological releases to ground water to prevent migration of licensed radioactive material off-site and to quantify impacts on decommissioning. The GPI program shall specify the frequency at which and/or conditions under which each program element is performed to ensure that the licensee's understanding of the site, the potential for leaks or spills to occur, or for equipment to degrade over time accurately reflect actual conditions.

The Electric Power Research Institute (EPRI) is sponsoring development of a technical guideline for implementation of ground water protection programs at nuclear power plants to meet Action

1. The stated objectives of the EPRI "Guideline for Implementing a Groundwater Protection Program at Nuclear Power Plants" is to demonstrate a commitment to controlling licensed material, minimize potential unplanned, unmonitored releases to the environment from plant operations, and minimize long-term costs associated with potential ground water and subsurface contamination. Other technically sound, documented approaches that meet the baseline requirements and recommendations in the EPRI Guideline may also be used.

OBJECTIVE 1.1 SITE HYDROLOGY AND GEOLOGY Ensure that the site characterization of geology and hydrology provides an understanding of predominant ground water gradients based upon current site conditions.

Acceptance Criteria:

a. Perform hydrogeologic and geologic studies to determine predominant ground water' flow characteristics and gradients.

b. As appropriate, review existing hydrogeologic and geologic studies, historical environmental studies, and permit or license related reports.

c. Identify potential pathways for ground water migration from on-site locations to off-site locations through ground water.

d. Establish the frequency for periodic reviews of site hydrogeologic studies. As a minimum, reviews should be performed whenever any of the following occurs:

Substantial on-site construction,

> Substantial disturbance of site property, Substantial changes in on-site or nearby off-site use of water, or Substantial changes in on-site or nearby off-site pumping rates of ground water.

e. As appropriate, update the site's Final Safety Analysis Report with changes to the characterization of hydrology and/or geology.

3

NEI 07-07 (Final)

August 2007 OBJECTIVE 1.2 SITE RISK ASSESSMENT Identify site risks based on plant design and work practices:

1.2.1 Evaluate all systems, structures, or components (SSCs) that contain or could contain licensed material and for which there is a credible mechanism for the licensed material to reach ground water.

1.2.2 Evaluate work practices that involve licensed material and for which there is a credible mechanism for the licensed material to reach ground water.

Acceptance Criteria:

a. Identify each SSC and work practice that involves or could reasonably be expected to involve licensed material and for which there is a credible mechanism for the licensed material to reach ground water. Examples of SSCs of interest include: refueling water storage tanks, if outdoors; spent fuel pools; spent fuel pool leak detection systems; outdoor tanks; outdoor storage of contaminated equipment; buried piping; retention ponds or basins or reservoirs; lines carrying steam.

b. Identify existing leak detection methods for each SSC and work practice that involves or could involve licensed material and for which there is a credible potential for inadvertent releases to ground water. These may include ground water monitoring, operator rounds, engineering walkdowns or inspections, leak-detection systems, or periodic integrity testing.

c. Identify potential enhancements to leak detection systems or programs. These may include additional or increased frequency of rounds or walkdowns or inspections, or integrity testing.

d. Identify potential enhancements to prevent spills or leaks from reaching ground water. These may include resealing or paving surfaces or installing spill containment measures.

e. Identify the mechanism or site process for tracking corrective actions.

f. Establish long term programs to perform preventative maintenance or surveillance activities to minimize the potential for inadvertent releases of licensed materials due to equipment failure.

g. Establish the frequency for periodic reviews of SSCs and work practices.

4

NEI 07-07 (Final)

August 2007 OBJECTIVE 1.3 ON-SITE GROUND WATER MONITORING Establish an on-site ground water monitoring program to ensure timely detection of inadvertent radiological releases to ground water.

Acceptance Criteria

a. Using the hydrology and geology studies developed under Objective 1.1, consider placement of ground water monitoring wells downgradient from the plant but within the boundary defined by the site license.

b. Consider, as appropriate, placing sentinel wells closer to SSCs that have the highest potential for inadvertent releases that could reach ground water or SSCs where leak detection capability is limited.

c. Establish sampling and analysis protocols, including analytical sensitivity requirements, for ground water and soil. Sampling for tritium in the vadose or unsaturated zone may not be practicable and may require additional evaluation. For split or duplicate samples, analytical sensitivity levels should be discussed with and agreed to by those external stakeholders responsible for the analyses to preclude future disputes.

d. Establish a formal, written program for longterm ground water monitoring. For those ground water monitoring locations that are included in the REMP*, revise the site's ODCM/ODAM*.

e. Periodically review existing station or contract lab(s) analytical capabilities. An important consideration is the time needed to obtain results.

f. Establish a long-term program for preventative maintenance of ground water wells.

g. Establish the frequency for periodic review of the ground water monitoring program.

OBJECTIVE 1.4 REMEDIATION PROCESS Establish a remediation protocol to prevent migration of licensed material off-site and to minimize decommissioning impacts.

Acceptance Criteria

a. Establish written procedures outlining the decision making process for remediation of leaks and spills or other instances of inadvertent releases. This process is site specific and shall consider migration pathways.

b. Evaluate the potential for detectible levels of licensed material resulting from planned releases of liquids and/or airborne materials.

c. Evaluate and document, as appropriate, decommissioning impacts resulting from remediation activities or the absence thereof.

wherever indicated, see glossary 5

NEI 07-07 (Final)

August 2007 OBJECTIVE 1.5 RECORD KEEPING Ensure that records of leaks, spills, remediation efforts are retained and retrievable to meet the requirements of 10 CFR 50.75(g).

Acceptance Criteria

a. Establish a record keeping program to meet the requirements of 10 CFR 50.75(g). Note that these records are used to determine an area's classification for purposes of performing surveys (see NRC Regulatory Issue Summary 2002-02 Lessons Learned Related to Recently Submitted Decommissioning Plans and License Termination Plans).

2 COMMUNICATION ACTION 2 Improve communication with external stakeholders to enhance trust and confidence on the part of local communities, States, the NRC, and the public in the nuclear industry's commitment to a high standard of public radiation safety and protection of the environment.

OBJECTIVE 2.1 STAKEHOLDER BRIEFING Each licensee should conduct initial and periodic briefings of their site specific GPI program with the designated State/Local officials.

Acceptance Criteria

a. The licensee should discuss:

> The background or industry events that led to the GPI.

> If there is additional information that the State/Local officials need to better understand the issue or place it in perspective for their constituents.

> "How" the State/Local officials will use or distribute the information.

b. Licensees should consider including additional information or updates on ground water protection in periodic discussions with State/Local officials.

c. For licensees that are in States where multiple nuclear power plants are located and multiple owner companies, it is highly recommended that the licensees coordinate their efforts and communicate with each other. The initial briefing for the State/local officials and the contents of a voluntary communication should be consistent.

6

NEI 07-07 (Final)

August 2007 OBJECTIVE 2.2 VOLUNTARY COMMUNICATION Make informal communication as soon as practicable to appropriate State/Local officials, with follow-up notification to the NRC, as appropriate, regarding significant* on-site leaks/spills into ground water and on-site or off-site water sample results exceeding the criteria in the REMP as described in the ODCMIODAM.

Acceptance Criteria:

This guidance provides a threshold for voluntary communication. Some States may require different communication thresholds; the licensee shall document any agreements with State/Local officials that differs from Industry guidance.

a. Communication to the designated State/Local officials shall be made before the end of the next business day if an inadvertent leak or spill to the environment has or can potentially get into the ground water and exceeds any of the following criteria:

i.

If a spill or leak exceeding 100 gallons from a source containing licensed

material, ii.

If the volume of a spill or leak cannot be quantified but is likely to exceed 100 gallons from a source containing licensed material, or iii.

Any leak or spill, regardless of volume or activity, deemed by the licensee to warrant voluntary communication.

To determine whether a leak or spill would trigger voluntary communication, consider the clarification in the following three text boxes in addition to 2.2.a i to iii above:

LEAK OR SPILL: The "leak or spill" represents an inadvertent event or perturbation in a system or component's performance. This event threshold is intended to ensure that State/Local officials are made aware that there has been an event of interest at the site and to keep them apprised of the licensee's action to contain and, as needed, remediate the event. "Leak or spill" events that meet the criteria shall be communicated regardless of whether or not the on-site ground water is, or could be used as, a source of drinking water.

The quantity of liquid resulting from leaks or spills of solid materials or waste or steam leaks should be evaluated with respect to 2.2.a. i to iii, inclusive.

wherever indicated, see glossary 7

NEI 07-07 (Final)

August 2007 SOURCE CONTAINING LICENSED MATERIAL: A liquid, including steam, for which a statistically valid positive result is obtained when the sample is analyzed to the following a priori lower limits of detection (analytical sensitivity).

The analytical sensitivity for identifying a source containing licensed material is, at a minimum, the licensee's lower limits of detection that are required for radioactive liquid effluents for all isotopes.

POTENTIAL TO REACH GROUND WATER Spills or leaks with the potential to reach ground water:

Spill or leak directly onto native soil or fill, Spill or leak onto an artificial surface (i.e. concrete or asphalt) if the surface is cracked or the material is porous or unsealed, Spill or leak that is directed into unlined or non impervious ponds or retention basins (i.e. water hydrologically connected to ground water).

A spill or leak inside a building or containment unit is generally unlikely to reach ground water, particularly if the building or containment unit has a drain and sump system. However, the sump and drain system should be evaluated as part of the SSC risk assessment.

A spill or leak to a semi-impermeable or impermeable surface that is recaptured or remediated per Objective 1.4 before the close of the next business day does not trigger the voluntary communication protocol.

The licensee shall document any agreement with State/Local officials that differs from this Industry guidance as part of their record. For example, some states or local authorities have indicated that they do not wish leaks/spills to be included in the voluntary communication protocol or that the voluntary communication should be completed in a shorter timeframe.

Appendix A provides a flowchart for the communication protocol as it applies to leaks or spills or groundwater sample results.

8'

NEI 07-07 (Final)

August 2007

b. Communication with the designated State/Local officials shall be made before the end of the next business day for a water sample result

i.

Of off-site ground water or surface water that exceeds any of the REMP reporting criteria for water as described in the ODCM/ODAM, or ii.

Of on-site surface water, that is hydrologically connected to ground water, or ground water that is or could be used as a source of drinking water, that exceeds any of the REMP reporting criteria for water as described in the ODCM/ODAM The licensee shall document the basis for concluding that the on-site ground water is not or would not be considered a source of drinking water. Examples of a defensible basis are documents from the regulatory agency with jurisdiction over ground water use.

Appendix A provides a flowchart for the communication protocol as it applies to groundwater sample results.

c. When communicating to the State/Local officials, be clear and precise in quantifying the actual release information as it applies to the appropriate regulatory criteria (i.e.

put it in perspective). The following information should be provided as part of the informal communication:

i.

A statement that the communication is being made as part of the NEI Ground Water Protection Initiative, ii.

The date and time of the spill, leak, or sample result(s),

iii.

Whether or not the spill has been contained or the leak has been stopped, iv.

If known, the location of the leak or spill or water sample(s),

v.

The source of the leak or spill, if known, vi.

A list of the contaminant(s) and the verified concentration(s),

vii. Description of the action(s) already taken and a general description of future

actions, viii. An estimate of the potential or bounding annual dose to a member of the public if available at this time, and ix.

An estimated time/date to provide additional information or follow-up.

d. Voluntary communication to State and/or Local officials may also require NRC notification under 10 CFR 50.72(b)(2)(xi). Licensees should perform these notifications consistent with their existing program.

e. Contact NEI by email to GW Noticegnei.org as part of a voluntary communication event as described in Objective 2.2.

9

NEI 07-07 (Final)

August 2007 OBJECTIVE 2.3 THIRTY-DAY REPORTS Submit a written 30-day report to the NRC for any water sample result for on-site ground water that is or may be used as a source of drinking water that exceeds any of the criteria in the licensee's existing REMP as described in the ODCM/ODAM for 30-day reporting of off-site water sample results. Copies of the written 30-day reports for both on-site and off-site water samples shall also be provided to the appropriate State/Local officials.

Acceptance Criteria:

a. All ground water samples taken for the Industry Initiative shall be analyzed and compared to the standards and limits contained in the station's REMP as described in the ODCM/ODAM. Pre-2006 ODCM/ODAM requirements specify a written 30-day report to the NRC for REMP sample results that exceed any of the REMP reporting criteria.

Under the Initiative, a written 30-day NRC report is also required for all on-site sample results that exceed any of the REMP reporting criteria and could potentially reach the ground water that is or could be used in the future as a source of drinking water. If the ground water is not currently used for drinking water but is potable, each station should consider the ground water as a potential source of drinking water (see objective 2.2 acceptance criterion b for documentation needed to establish a defensible basis for determining the beneficial use(s) of ground water).

The initial discovery of ground water contamination greater than the REMP reporting criterion is the event documented in a written 30-day report. It is not expected that a written 30-day report will be generated each time a subsequent sample(s) suspected to be from the same "plume" identifies concentrations greater than any of the REMP criteria as described in the ODCM/ODAM. The licensee should evaluate the need for additional reports or communications based on unexpected changes in conditions.

b. The 30-day special report should include:

i. A statement that the report is being submitted in support of the GPI, ii. A list of the contaminant(s) and the verified concentration(s),

iii. Description of the action(s) taken, iv. An estimate of the potential or bounding annual dose to a member of the public, and

v. Corrective action(s), if necessary, that will be taken to reduce the projected annual dose to a member of the public to less than the limits in 10 CFR 50 Appendix I.

c. All written 30-day NRC reports generated under item 2.3.a are to be concurrently forwarded to the designated State/Local officials.

10

NEI 07-07 (Final)

August 2007 OBJECTIVE 2.4 ANNUAL REPORTING Document all on-site ground water sample results and a description of any significant on-site leaks/spills into ground water for each calendar year in the Annual Radiological Environmental Operating Report (AREOR) for REMP or the Annual Radioactive Effluent Release Report (ARERR) for the RETS as contained in the appropriate reporting procedure, beginning with the report for calendar year 2006.

Acceptance Criteria:

a. The appropriate changes to the ODCM/ODAM or to the appropriate procedures were expected to be completed in a timeframe to support the 2007 report of 2006 performance for plants that were operating or decommissioning when the GPI was adopted. For new plants, appropriate procedures that require inclusion of significant on-site leaks/spills into ground water and all on-site ground water results shall be developed and implemented prior to initial receipt of nuclear fuel.

b. Reporting of on-site ground water sample results shall be as follows:

i.

Ground water sample results that are taken in support of the GPI but are not part of the REMP program (e.g. samples obtained during the investigatory phase of the Action Plan circa year 2006) are reported in the ARERR required by 10 CFR 50.36a (a)(2).

ii. Once the longterm monitoring sample points have been established per Objective 1.3, acceptance criterion d, the results are reported in the AREOR for those sample points that are included in the REMP as described in the ODCM/ODAM. The sample results for those longterm monitoring sample points that are not included in REMP are reported in the ARERR.

c. In addition to 2.4.b, voluntary communications shall be included in an annual report as follows:

i. A description of all spills or leaks that were communicated per Objective 2.2 acceptance criterion a shall be included in the ARERR.

ii. All on-site or off-site ground water sample results that exceeded the REMP reporting thresholds as described in the ODCM/ODAM that were communicated per Objective 2.2 acceptance criterion b shall be included in either the ARERR and/or in the AREOR.

11

NEI 07-07 (Final)

August 2007 3

PROGRAM OVERSIGHT ACTION 3 Perform program oversight to ensure effective implementation of the GPI program OBJECTIVE 3.1 PERFORM A SELF-ASSESSMENT Perform a self-assessment of the GPI program (see Appendix B).

Acceptance Criteria:

a. An independent, knowledgeable individual(s) shall perform the initial self-assessment within one year of implementation. For existing plants, this means no later than December 31, 2008; for new plants this means within one year after initial criticality.

b. Perform periodic self-assessment of the GPI program at least once every 5 years after initial self-assessment.

c. The self-assessment, at a minimum, shall include evaluating implementation of all of the objectives identified in this document.

d. The self-assessment shall be documented consistent with applicable station procedures and programs.

OBJECTIVE 3.2 REVIEW THE PROGRAM UNDER THE AUSPICES OF NEI Conduct a review of the GPI program, including at a minimum the licensee's self-assessments, under the auspices of NEI.

Acceptance Criteria:

a. An independent, knowledgeable individual(s) shall perform the initial review within one year of the initial self-assessment performed per Objective 3.1.a above.

b. Periodic review of the GPI program should be performed every 5 years, subsequent to the license's periodicself-assessment performed per Objective 3.1.b. above.

12

NEI 07-07 (Final)

August 2007 GLOSSARY AREOR means the Annual Radiological Environmental Operating Report - summarizes the results of the REMP to the NRC.

ARERR means the Annual Radioactive Effluent Release Report as required by 10 CFR 50.36a (a)(2) - summarizes the releases of liquid, airborne, and solid wastes from the facility and provides the calculated doses attributable to those releases.

Ground water as used in the GPI, means any subsurface water, whether in the unsaturated or vadose zone, or in the saturated.zone of the earth.

Informal (communication) means a communication, typically by telephone, between licensee personnel and the State/Local officials. Subsequent notification of the NRC under 10 CFR 50.72 should be performed consistent with station policy.

Licensed material (from 10 CFR 20.1003) means source material, special nuclear material, or byproduct material received, possessed, used, transferred or disposed of under a general or specific license issued by the Commission.

ODCM/ODAM means the Offsite Dose Calculation Manual or Offsite Dose Assessment Manual or equivalent document. The licensee's manual required by Technical Specification that contains the dose assessment methodology and radiological effluent technical specifications.

REMP means the Radiological Environmental Monitoring Program specified by the ODCM/ODAM that provides measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides, which lead to the highest potential radiation exposures of individuals resulting from the station operation.

RETS means the Radiological Effluent Technical Specifications required to control the release of radioactive liquids and airborne materials from the site. Standard radiological effluent technical specifications are found in NUREG CR-1301.

Significant (leak or spill) means an item or incident that is of interest to the public or stakeholders. It does not imply or refer to regulatory terminology nor is it intended to indicate that the leak or spill has public health and safety or environmental protection consequences.

Voluntary as used in the GPI, means not required by statute or regulation.

Verbs "may", "shall", "should", "will", and "would" have the meanings commonly used in the nuclear power industry (see ANSI N42.14-1999). "Shall" denotes a requirement; "should" denotes a recommendation; "may" denotes permission 13

NEI 07-07 (Final)

August 2007 ATTACHMENT 1 Nuclear Energy institute Industry Initiative on Ground Water Protection May 2006 Obiectives:

1. Improve management of situations involving inadvertent radiological releases that get into ground water.

2. Enhance trust and confidence on the part of local communities, States, the NRC, and the public in the nuclear industry's commitment to a high standard of public radiation safety and protection of the environment.

Actions:

By July 31, 2006, each member company operating or decommissioning a nuclear power plant will:

1. Put in place a company/site-specific action plan(s) to help assure timely detection and effective response to situations involving inadvertent radiological releases in ground water to prevent migration of licensed radioactive material offsite and quantify impacts on decommissioning.

2. Expand the scope of the licensee's existing Radiological Environmental Monitoring Program (REMP) reporting requirements to include additional voluntary formal and informal reporting as follows:

2.1 Document all onsite ground water sample results and a description of any significant onsite leaks/spills into ground water for each calendar year in the Annual REMP Report, beginning with the report covering the calendar year 2006; 2.2 Submit a 30-day report to the NRC for any water sample result for onsite ground water that is or may be used as a source of drinking water that exceeds the criteria in the licensee's existing REMP for 30-day reporting of offsite water sample results. Copies of 30-day reports for both onsite and offsite water samples will also be provided to the appropriate State agency; and 2.3 Make informal notification as soon as practicable to appropriate State/Local officials, with follow-up notification to the NRC, as appropriate, regarding significant onsite leaks/spills into ground water (see Item 2.1) and onsite or offsite water sample results exceeding the criteria in the REMP (see Item 2.2).

14

NEI 07-07 (Final)

August 2007 ATTACHMENT 2 FREQUENTLY ASKED QUESTIONS

1) Q: Does the commitment to "develop and implement a site-specific/company ground water protection program" specifically include a commitment to drill more monitoring wells, modify plant systems, structures, or components, etc?

A: No. Companies are expected to complete an evaluation of the specific situation at each site and identify and schedule needed improvements to meet the objective of "help[ing]

assure timely detection and effective response to situations involving inadvertent radiological releases to ground water to prevent migration of licensed radioactive material off-site and minimize the impacts on decommissioning." The scope of the needed improvements will largely depend on site-specific conditions, e.g., the history of leaks or spills and the extent and quality of current programs for detecting leaks and monitoring on-site ground water. The evaluation should be periodically reassessed.

2) Q: How does the voluntary communication protocol under Action 2 relate to reporting requirements in effect before 2006?

A: Every licensee already has certain reporting requirements specified in their license, i.e., in the RETS, REMP, or ODCM/ODAM, although these criteria may vary somewhat from site to site. 10 CFR Parts 20 and 50 also contain relevant reporting requirements that apply to all licensees. In addition, some licensees may have reporting requirements or commitments that involve State or local agencies and officials. The voluntary communication protocol is intended to supplement the existing body of reporting requirements at each site in order to assure that all sites, at a minimum, consistently inform appropriate State and local officials, and the NRC as appropriate, regarding conditions and occurrences related to inadvertent radiological releases to the ground water at the site.

3) What is meant by "substantial on-site construction" or "substantial disturbance of site property" in acceptance criterion d to Objective 1. 1?

A: "Substantial" refers to the likelihood that the construction or disturbance has affected the subsurface flow of ground water. Licensees at new plants should, for example, review their pre-licensing characterization of hydrology and geology for changes that result from construction of buildings and structures or compaction of soil.

15

NEI 07-07 (Final)

August 2007 APPENDIX A COMMUNICATION PROTOCOL FOR LEAK/SPILL AND GROUNDWATER SAMPLE RESULTS NOTE: ALL ON-SITE GROUNDWATER SAMPLE RESULTS INCLUDED IN ARERR OR AREOR 2.4 b 16

NEI 07-07 (Final)

August 2007 APPENDIX B SELF ASSESSMENT CHECKLIST OBJECTIVE 3.1 Plant or Utility Being Reviewed:

Reviewers:

Date of Review Guideline Section Met Section ObjectivelAcceptance Criteria Yes-No Comments As Required 1.1 Ensure that the site characterization of geology and hydrology provides an understanding of predominant ground water

_W_

_7 gradients based pon current site conditions.

w Perform hydrogeologic and geologic studies to determine predominant ground water flow charactensemcs and gradients.

.1..b As appropriate, review existing hydrogeologic and geologic studies, historical environmental studies, and permit or license related reports 1.21.c Identify potential pathways for ground water migration from on-site locations to off-site locations through ground water.

1.d Establish the frequency for periodic reviews of site hydrogeologic studies.*

1.1C.e As appropriate, update the Final Safety Analysis Report with changes to the hydrolo tey and/or ideolory.

1.2 Identify site risk based on plant design and work practices*

1.2.a Identify each SSC and work practice that involves or could reasonably be expected to involve licensed material and for which there is a credible mechanism for the licensed material to reach ground water.*

1.2.b Identify existing leak detection methods for each SSC and work practice that involves or could involve licensed material and for which there is a credible potential for inadvertent releases to ground water.*

12..c Identify potential enhancements to leak detection systems or programs.*

1.2.d Identify potential enhancements to prevent spills or leaks from reaching ground water.*

1.2.e Identify the mechanism or site process for tracking corrective actions.

12f Establish long term programs to perform preventative maintenance or surveillance activities to minimize the potential for inadvertent releases of licensed materials due to equipment failure.

1.2.g Establish the frequency for periodic reviews of SSCs and work practices.

1.3 Establish an on-site ground water monitoring program to ensure timely detection of inadvertent radiological releases to ground water.

J,7t Lz 1.3.a Using the hydrology and geology studies developed under Objective 1.1, consider placement of ground water monitoring wells downgradient from the plant but within the boundary defined by the site license.

1.3.b Consider, as appropriate, placing sentinel wells closer to SSCs that have the highest potential for inadvertent releases that could reach ground water or SSCs where leak detection capability is limited.

1.3.c Establish sampling and analysis protocols, including analytical sensitivity requirements, for ground water and soil.*

1.3.d Establish a formal, written program for longterm ground water monitoring.*

1.3.e Periodically review existing station or contract lab(s) analytical capabilities.*

1.3.f Establish a longterm program for preventative maintenance of ground water wells.

17

NEI 07-07 (Final)

August 2007 Plant or Utility Being Reviewed:

Reviewers:

Date of Review Guideline Section Met Section Objective/Acceptance Criteria Yes-No Comments As Required 1.3.g Establish the frequency for periodic review of the ground water monitoring program.

1.4 Establish a remediation protocol to prevent migration of licensed material off-site and to minimize decommissioning impacts Establish written procedures outlining the decision making process for remediation of leaks and spills or other 1.4.a instances of inadvertent releases. This process Is site specific and shall consider migration pathways Evaluate the potential for detectible levels of licensed material resulting from planned releases of liquids and/or 1.4.b airborne materials.

Evaluate and document, as appropriate, decommissioning impacts resulting from remediation activities or the 1.4.c absence thereof.

1.5 Ensure that records of leaks, spills, remediation efforts are retained and retrievable to meet the requirements of 10 CFR 50.75(g).

1.5.a Establish a record keeping program to meet the requirements of 10 CFR 50.75(g) 2.1 Each licensee should conduct initial and periodic briefings of their site specific GPI program with the designated State/Local officials The licensee should discuss i) The background or industry events that led to the GPI 11) If there is additional information that the State/Local officials need to better understand the issue or place it in perspective for their 2.1.a constituents iii) "How" the State/Local officials will use or distribute the information Licensees should consider including additional information or updates on ground water protection in periodic 2.1.b discussions with State/Local officials For licensees that are in States where multiple nuclear power plants are located and multiple owner companies, it is highly recommended that the licensees coordinate their efforts and communicate with each other. The initial 2.1.c briefing for the State/local officials and the contents of a voluntary communication should be consistent.

2.2 Make informal communication as soon as practicable to appropriate State/Local officials, with follow-up notifications to the NRC, as appropriate, regarding significant "on-site leaks/spills into ground water and on-site or off-site water sample results exceeding the criteria in the REMP as described in the OCDM/ODAM.*

Communication with the designated State/Local officials shall be made before the end of the next business day if an inadvertent leak or spill to the environment has or can potentially get into groundwater and exceeds any of the 2.2.a following criteria: i) If a spill or leak exceeding 100 gallons from a source containing licensed material; ii) If the volume of a spill or leak can not be quantified, but is likely to exceed 100 gallons, from a source containing licensed material, or iii) Any leak of spill, regardless of volume or activity, deemed by the licensee to warrant voluntary communication.

Communication with the designated State/Local officials shall be made before the end of the next business day for a water sample result (i) of off-site ground water or surface water that exceeds any of the REMP reporting criteria 2.2.b for water as described in the ODCM/ODAM, or (ii) of on-site surface water, that is hydrologically connected to ground water, or ground water that is or could be used as a source of drinking water, exceed any of the REMP reporting criteria for water as described in the ODCM/ODAM 2.2.c When communicating to the State/Local officials, be clear and precise in quantifying the actual release information as it applies to the appropriate regulatory criteria.

Voluntary communication to State and/or Local officials may also require NRC notification under 10 CFR 2.2.d 50.72(b)(2)(xi). Licensees should perform these notifications consistent with their existing program 2.2.e Contact NEI by email to GW Notice@nei.org as part of a voluntary communication event 18

NEI 07-07 (Final)

August 2007 Plant or Utility Being Reviewed:

Reviewers:

Date of Review Guideline Section Met Section Objective/Acceptance Criteria Yes-No Comments As Required 2.3 Submit a written 30-day report to the NRC for any water sample result for on-site ground water that is or may be used as a source of drinking water that exceeds any of the criteria in the licensee's existing REMP/ODCM for 30-day reporting of off-site water sample results. Copies of the written 30-day reports for both on-site and off-site water samples shall also be provided to the appropriate State/Local officials.

All ground water samples taken for the Industry Initiative shall be analyzed and compared to the standards and 2.3.a limits contained in the station's REMP as described in the ODCR/ODAa*

2.3.f b The 30-day special report should include the items listed*

S All written 30-day NRC reports generated under item 2.3.a are to be concurrently forwarded to the designated 2.3. c State/Local officials1 2.4 Document all on-site ground water sample results and a description of any significant on-site leaks/spills into ground water for W

each calendar year in the Annual Radiological Environmental Operating Report (AREOR) for REMP or the Annual Radioactive Effluent Release Report (ARERR) for the RETS as contained in the appropriate Site reporting procedure, beginning with the report for calendar year 2006.

Complete appropriate changes to the ODCM/ODAM or to the appropriate procedures to support the 2007 report.

For new plants, appropriate procedures that require inclusion of significant on-site leaks/spills into ground water 2.4.a and all on-site ground water results shall be developed and implemented prior to initial receipt of nuclear fuel*

Report on-site ground water sample results as follows, i) Ground water sample results that are taken in support of the GPI but not part of REMP in the ARERR ii) For longterm sample points that are included in the REMP as described in the ODCM/ODAM, the results are reported in the AREOR; those longterm sample points that are not 2.4.b included in REMP, the results are reported in the ARERR

In addition to 2.1.b, voluntary communications shall be included as follows: the following are to be included in either the ARERR and/or the AREOR i) A description of all spills or leaks that were communicated per Objective 2.2 acceptance criterion a shall be included in the ARERR ii) All on-site or off-site ground water sample results that exceeded the REMP reporting thresholds as described in the ODCM/ODAM that were communicated per 2.4.c Objective 2.2 acceptance criterion b shall be included in either the ARERR and/or the AREOR 3.1 Perform a self-assessment of the GPI program (references this check sheet)

An independent, knowledgeable individual(s) shall perform the initial self assessment within one year of 3.1.a implementation.*

3.1.b Perform periodic self-assessments of the GPI program at least once every five years after initial self-assessment.

3.1.c The self-assessment, at a minimum, shall evaluate implementation of all objectives identified in this document.

3.1.d The self-assessment shall be documented consistent with applicable procedures.

3.2 Conduct a review of the GPI program, including at a minimum the licensee's self assessments, under the auspices of NEI.

R 47..

An independent, knowledgeable individual(s) shall perform the initial review within one year of the initial self-3.2.a assessment performed per objective 3.1.a above Periodic review of the GPI program should be performed every five years, subsequent to the license's periodic self-assessment performed per Objective 3.1.b above.

Additional Comments As Required:

J J

-Detailed requirements are in the Industry Ground Water Protection Initiative Final Guidance document - August 2007 19

ATTACHMENT F

ATTACHMENT G

ATTACHMENT G The US Nuclear Regulatory Commission requires participation in an interlaboratory comparison program to ensure that independent checks on the precision and accuracy of measurements of radioactive materials in environmental matrices are performed as part of the Quality Assurance program for environmental monitoring. Participation in an interlaboratory comparison program ensures the measurement results are valid for the purpose of compliance with Section IV.B.2 of Appendix I to 10 CFR 50. This requirement is contained in the Callaway Plant Final Safety Analysis Report, Section 16.11.4.3.

All environmental monitoring samples, including well water samples, are analyzed by Environmental Inc., Midwest Laboratory (EIML). EIML participates in intercomparison studies for proficiency testin q in drinking water administered by Environmental Resources Associates (ERA). This program serves as a replacement for studies previously conducted by the US EPA Environmental Monitoring Systems Laboratory, Las Vegas, NV. This program supplies environmental type water samples containing concentrations of radionuclides known to ERA, but not to participant laboratories. The purpose of this program is to provide an independent check on EIML's analytical procedures and to alert EIML of any potential problems. EIML also participates in the Department of Energy Mixed Analyte Performance Evaluation Program (MAPEP) for vegetation, soil, air filter, and water matrices. The MAPEP is administered by the Radiological and Environmental Sciences Laboratory (RESL), under the direction of DOE Office of Health, Safety, and Security (HS&S). The MAPEP performance criteria is described elsewhere2.

In these programs, participant laboratories measure the concentration of specified radionuclides and report the results to the issuing agency. Several months later, the issuing agency reports the known values to the participant laboratories and specifies control limits. Results consistently higher or lower than the known values or outside the control limits indicate a need to check the instruments or procedures.

In addition to the Interlaboratory Comparison Programs, EIML also conducts an in-house intralaboratory comparison program whereby spiked samples prepared with NIST traceable sources, blank samples, and duplicate samples are prepared by the EIML Quality Assurance Dept. and are submitted for analysis alongside customer samples.

1 Environmental Resources Associates (ERA) maintains A2LA Proficiency Testing Provider and NQA USA ISO 9001 accreditation. All of ERA's proficiency testing (PT) standards and quality control (QC) standards - DMRQA, water pollution, water supply, soil/hazardous waste, UST, microbiology and radiochemistry - are covered by one or more of their accreditations.

2 The Handbook for the Department of Energy's Mixed Analyte Performance Evaluation Program, Marlette, Guy, US DOE Radiological and Environmental Sciences Laboratory, Idaho Falls, ID.

February, 2008.

ATTACHMENT G The results of the interlaboratory comparison programs and the in-house intralaboratory comparison program are provided in the Annual Radiological Environmental Operating Report (AREOR). The AREOR is submitted to the US NRC pursuant to 10 CFR 50, and to the Missouri Department of Natural Resources pursuant to the requirements of the Callaway Plant NPDES Permit.

ULNRC-05511, NPDES Permit Schedule of Compliance Condition Concerning Groundwater Monitoring

Contents

Text

Enclosure:

SUBJECT:

Dear Mr. Morrison:

1.8

SUMMARY

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ULNRC-05511, NPDES Permit Schedule of Compliance Condition Concerning Groundwater Monitoring

Text

Enclosure:

SUBJECT:

Dear Mr. Morrison:

1.8

SUMMARY

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