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2.1 S T A T I O N LOCATION The Station is a former nuclear power generati ng facility that, in the early spring of 1998, converted both units' generators to sync hronous condensers that provide voltage stability to the northeast Illinois power grid. The Station encompasses approximately 250 acres (Ex e lon, 2004). Figure 1.2 presents a Station Boundaries and Features plan.
2.1 S T A T I O N LOCATION The Station is a former nuclear power generati ng facility that, in the early spring of 1998, converted both units' generators to sync hronous condensers that provide voltage stability to the northeast Illinois power grid. The Station encompasses approximately 250 acres (Ex e lon, 2004). Figure 1.2 presents a Station Boundaries and Features plan.
The Station is located on the eastern edge of Zion between 23rd and 29th Streets, from the Chicago and Northwestern Railroad tracks to Lake Michigan.
The Station is located on the eastern edge of Zion between 23rd and 29th Streets, from the Chicago and Northwestern Railroad tracks to Lake Michigan.
The Station is being maintained and monito red under the "SAFSTOR" (safe storage of components of the nuclear power plant) p hase of decommissioning, as is discussed below. 2.2 OVERVIEW OF COOLING WATER OPERATIONS Former Operations In the mid-1950s, Commonwealth Edison Comp any (ComEd) purchased about 250 acres on the eastern edge of Zion. The Station operated as a dual unit pressurized water reactor plant. A construction permit was issu ed in December 1968. An operating license was issued October 19, 1973 for Unit 1 and November 14, 1973 for Unit  
The Station is being maintained and monito red under the "SAFSTOR" (safe storage of components of the nuclear power plant) p hase of decommissioning, as is discussed below. 2.2 OVERVIEW OF COOLING WATER OPERATIONS Former Operations In the mid-1950s, Commonwealth Edison Comp any (ComEd) purchased about 250 acres on the eastern edge of Zion. The Station operated as a dual unit pressurized water reactor plant. A construction permit was issu ed in December 1968. An operating license was issued October 19, 1973 for Unit 1 and November 14, 1973 for Unit
: 2. Commercial operations commenced in December 1973 for Unit 1 and September 1974 for Unit 2.
: 2. Commercial operations commenced in December 1973 for Unit 1 and September 1974 for Unit 2.
Unit 1 operations ended on February 21, 1997 and Unit 2 operations ended on September 19, 1996. All fuel was removed from the reactor and placed in the spent fuel pool on April 27, 1997 for Unit 1 and on February 25, 1998 for Unit  
Unit 1 operations ended on February 21, 1997 and Unit 2 operations ended on September 19, 1996. All fuel was removed from the reactor and placed in the spent fuel pool on April 27, 1997 for Unit 1 and on February 25, 1998 for Unit
: 2. Commercial operation of the plant ended on January 14, 1998 when the Unicom Corporation and ComEd Boards of Directors authorized the permanent cessation of operations at the Station. Ex elon submitted the certification of fuel transfer on March 9, 1998. In addition 045 136 (22) Zi on St ati o n 2 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 to maintaining the synchronous condensers, the Station's employees also monitor the safe storage of spent fuel.
: 2. Commercial operation of the plant ended on January 14, 1998 when the Unicom Corporation and ComEd Boards of Directors authorized the permanent cessation of operations at the Station. Ex elon submitted the certification of fuel transfer on March 9, 1998. In addition 045 136 (22) Zi on St ati o n 2 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 to maintaining the synchronous condensers, the Station's employees also monitor the safe storage of spent fuel.
Discharges from the Station are subject to the requirements of Nuclear Regulatory Commission (NRC) Operating Licenses DP R-39 and DPR-48. Discharges from the Station are also subject to regulation under the Illinois Environmental Protection Agency (EPA) National Pollutant Discharge Elim ination System (NPDES) Permit IL0002763.
Discharges from the Station are subject to the requirements of Nuclear Regulatory Commission (NRC) Operating Licenses DP R-39 and DPR-48. Discharges from the Station are also subject to regulation under the Illinois Environmental Protection Agency (EPA) National Pollutant Discharge Elim ination System (NPDES) Permit IL0002763.
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Circulating water is drawn from Lake Michig an by way of an intake pipe that ex tends approx imately a half mile into the Lake. Circ ulating water is returned to Lake Michigan by way of two discharge pipes that ex tend approx imately a q u arter mile into the lake.
Circulating water is drawn from Lake Michig an by way of an intake pipe that ex tends approx imately a half mile into the Lake. Circ ulating water is returned to Lake Michigan by way of two discharge pipes that ex tend approx imately a q u arter mile into the lake.
Liquid wastes have been discharged under th e NRC permit through the blowdown line, which is piped to the circulating water di scharge pipe located east of the Turbine Building.
Liquid wastes have been discharged under th e NRC permit through the blowdown line, which is piped to the circulating water di scharge pipe located east of the Turbine Building.
Voltage Stabilization and SAFSTOR The Station is being decommissioned under the NRC regulatory process. The Station is currently in the "SAFSTOR" phase of the de commissioning process where the Station is maintained in a condition that allows it to be safely stored and subseq uently decontaminated to levels that permit its release for unrestricted use.  
Voltage Stabilization and SAFSTOR The Station is being decommissioned under the NRC regulatory process. The Station is currently in the "SAFSTOR" phase of the de commissioning process where the Station is maintained in a condition that allows it to be safely stored and subseq uently decontaminated to levels that permit its release for unrestricted use.
 
2.3 SURROUNDING LAND USE The Station is located on the shore of Lake Michigan, in the eastern portion of the City of Zion, and adjacent to the Illinois Beach State Park.
===2.3 SURROUNDING===
LAND USE The Station is located on the shore of Lake Michigan, in the eastern portion of the City of Zion, and adjacent to the Illinois Beach State Park.
The Illinois Beach State Park is located alon g the Lake Michigan shoreline and is divided into a northern unit and a southern unit, with the Station situated between the two units. The Illinois Beach State Park encompasse s 4,160 acres and received approximately 2.75 million visitors in 1998. The Park is considered a natural resource (ATSDR, 2000).
The Illinois Beach State Park is located alon g the Lake Michigan shoreline and is divided into a northern unit and a southern unit, with the Station situated between the two units. The Illinois Beach State Park encompasse s 4,160 acres and received approximately 2.75 million visitors in 1998. The Park is considered a natural resource (ATSDR, 2000).
The land located to the west of the Statio n is generally undeveloped with a limited number of industrial/commercial facilities present along Deborah Avenue. Residential areas and the City of Zion downtown are located west of the Chicago & Northwestern Railroad, which is west of the Station. Lake Michigan borders the Station to the east.
The land located to the west of the Statio n is generally undeveloped with a limited number of industrial/commercial facilities present along Deborah Avenue. Residential areas and the City of Zion downtown are located west of the Chicago & Northwestern Railroad, which is west of the Station. Lake Michigan borders the Station to the east.
045 136 (22) Zi on St ati o n 4 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 2.4 S T A T I O N SETTING The following sections present a summary of the topography, surface water features, geology, hydrogeology, and groundwater flow conditions in the region surrounding the Station. The information was primarily gathered from Sections 2.1 and 2.3 of the Zion Defueled Safety Analysis Report (DSAR) la st revision dated October 2004 (Ex e lon, 2004). The main references the DSAR relies upon ar e listed in Section 10.0 of this HIR. CRA checked and verified all DSAR refe rences that apply to this HIR.  
045 136 (22) Zi on St ati o n 4 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 2.4 S T A T I O N SETTING The following sections present a summary of the topography, surface water features, geology, hydrogeology, and groundwater flow conditions in the region surrounding the Station. The information was primarily gathered from Sections 2.1 and 2.3 of the Zion Defueled Safety Analysis Report (DSAR) la st revision dated October 2004 (Ex e lon, 2004). The main references the DSAR relies upon ar e listed in Section 10.0 of this HIR. CRA checked and verified all DSAR refe rences that apply to this HIR.
 
2.4.1 TOPOGRAPHY AND SURFACE WATER FEATURES Lake County consists of moraines, outwash pl ains, lake plains, kames, stream terraces, flood plains, beaches, and bogs. The county is in the Wheaton Morainal country of the Great Lakes section of the Central Lowland pr ovince. Relief in Lake County was caused by differences in the thickness of deposits le ft by the most recent glacier. The land surface gradually slopes to the south or so utheast. The highest point in the county, 957 feet above mean sea level (AMSL), is located on Gander Mountain in the northwest corner of the county. The lowest point is at the Lake Michigan shore near Waukegan.
====2.4.1 TOPOGRAPHY====
AND SURFACE WATER FEATURES Lake County consists of moraines, outwash pl ains, lake plains, kames, stream terraces, flood plains, beaches, and bogs. The county is in the Wheaton Morainal country of the Great Lakes section of the Central Lowland pr ovince. Relief in Lake County was caused by differences in the thickness of deposits le ft by the most recent glacier. The land surface gradually slopes to the south or so utheast. The highest point in the county, 957 feet above mean sea level (AMSL), is located on Gander Mountain in the northwest corner of the county. The lowest point is at the Lake Michigan shore near Waukegan.
Several moraines run through the county. From east to west, they are the Lake Border Morainic System, the Tinley Moraine, the Va lparaiso Morainic System, and the Fox Lake Moraine. In general, Lake County has a poorly defined drainage pattern. Many drainage ways terminate in depressions and ma rshes. The land area falls into four major watersheds and 26 drainage basins. Th e Chicago River, Des Plaines River, Fox River, and Lake Michigan watersheds are all s hared with neighboring counties in Illinois and Wisconsin (NRCS, 2005).
Several moraines run through the county. From east to west, they are the Lake Border Morainic System, the Tinley Moraine, the Va lparaiso Morainic System, and the Fox Lake Moraine. In general, Lake County has a poorly defined drainage pattern. Many drainage ways terminate in depressions and ma rshes. The land area falls into four major watersheds and 26 drainage basins. Th e Chicago River, Des Plaines River, Fox River, and Lake Michigan watersheds are all s hared with neighboring counties in Illinois and Wisconsin (NRCS, 2005).
The Lake Michigan shoreline between North Chicago, Illinois and Kenosha, Wisconsin comprises the Zion beach-ridge plain. The Zion beach-ridge plain consists of linear, generally coast-parallel mounds of sand and gravel that have been built up by wave action to extend the coast outward into Lake Michigan. The Zion beach-ridge plain has a max i mum width of approx imately 1 mile ne ar the City of Zion (Chrzastowski and Frankie, 2000). The older dunes become root-bou nd by vegetation resulting in long lines of sandy ridges separated by linear marshes.
The Lake Michigan shoreline between North Chicago, Illinois and Kenosha, Wisconsin comprises the Zion beach-ridge plain. The Zion beach-ridge plain consists of linear, generally coast-parallel mounds of sand and gravel that have been built up by wave action to extend the coast outward into Lake Michigan. The Zion beach-ridge plain has a max i mum width of approx imately 1 mile ne ar the City of Zion (Chrzastowski and Frankie, 2000). The older dunes become root-bou nd by vegetation resulting in long lines of sandy ridges separated by linear marshes.
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The Dead River passes through the Illinois Beach State Park as shown on Figure 1.1. The Dead River flows into Lake Michigan at a point approx imately 2.3 miles south of the Station.
The Dead River passes through the Illinois Beach State Park as shown on Figure 1.1. The Dead River flows into Lake Michigan at a point approx imately 2.3 miles south of the Station.
The Dead River was so named because the mout h is periodically blocked by shifting sandbars on the Lake Michigan shoreline.
The Dead River was so named because the mout h is periodically blocked by shifting sandbars on the Lake Michigan shoreline.
Storm water runoff from the switchyard is ca ptured by the perimeter ditch, which is a drainage channel that follows the Station's oute r fence. The perimeter ditch connects to Lake Michigan to the north and south of the Pr otected Area (PA). Figure  
Storm water runoff from the switchyard is ca ptured by the perimeter ditch, which is a drainage channel that follows the Station's oute r fence. The perimeter ditch connects to Lake Michigan to the north and south of the Pr otected Area (PA). Figure 2.1 presents a depiction of the perimeter ditch and the stormwater drainage ditches that control surface water at the Station. On the wester n portion of the Station property some of these drainage systems intercept the shallow groundwater. This is not the case on the eastern portion of the Station property wher e the stormwater drainage system is located above the water table as it drops towards Lake Michigan.
 
2.4.2 G E O L O G Y This section presents an overview of Stat ion geology based upon the 1967 Foundation Investigation (Dames and Moore, 1967) and other geologic publications. The Station is underlain by overburden deposits and a regi onally extensive sequence of consolidated 045 136 (22) Zi on St ati o n 6 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 sedimentary deposits. The major stratigraphi c features can be divided into Paleozoic aged bedrock and Quaternary Period overbu rden deposits. Figure 2.2 presents a stratigraphic cross-section representative of bedrock units in Lake County, Illinois.
===2.1 presents===
a depiction of the perimeter ditch and the stormwater drainage ditches that control surface water at the Station. On the wester n portion of the Station property some of these drainage systems intercept the shallow groundwater. This is not the case on the eastern portion of the Station property wher e the stormwater drainage system is located above the water table as it drops towards Lake Michigan.
2.4.2 G E O L O G Y This section presents an overview of Stat ion geology based upon the 1967 Foundation Investigation (Dames and Moore, 1967) and other geologic publications. The Station is underlain by overburden deposits and a regi onally extensive sequence of consolidated 045 136 (22) Zi on St ati o n 6 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 sedimentary deposits. The major stratigraphi c features can be divided into Paleozoic aged bedrock and Quaternary Period overbu rden deposits. Figure  
 
===2.2 presents===
a stratigraphic cross-section representative of bedrock units in Lake County, Illinois.
Figure 2.3 presents a cross-section of the ov erburden deposits associated with the Zion beach-ridge plain.
Figure 2.3 presents a cross-section of the ov erburden deposits associated with the Zion beach-ridge plain.
Rocks of the Cambrian through Silurian Periods are marine in origin and were deposited in a sea that covered all of Illinois (Willman, 1971). The rocks consist of sandstones, shales, and carbonates for a combined thickn ess of approx imately 2,500 feet. Southerly long shore currents have eroded the Root River delta and transported the sediments along the western shore of Lake Michig an to form the Zion beach-ridge plain (Chrzastowski and Frankie, 2000).
Rocks of the Cambrian through Silurian Periods are marine in origin and were deposited in a sea that covered all of Illinois (Willman, 1971). The rocks consist of sandstones, shales, and carbonates for a combined thickn ess of approx imately 2,500 feet. Southerly long shore currents have eroded the Root River delta and transported the sediments along the western shore of Lake Michig an to form the Zion beach-ridge plain (Chrzastowski and Frankie, 2000).
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Simon Formation (Visocky et al., 1985).
Simon Formation (Visocky et al., 1985).
Lake Michigan acts as a major regional discharge zone for groundwater. The groundwater flow in both unconsolidated de posits and bedrock units in the region is generally toward the lake; however, localiz ed pumping induces variations in flow directions in the bedrock aquifers.
Lake Michigan acts as a major regional discharge zone for groundwater. The groundwater flow in both unconsolidated de posits and bedrock units in the region is generally toward the lake; however, localiz ed pumping induces variations in flow directions in the bedrock aquifers.
045 136 (22) Zi on St ati o n 7 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 2.5 AREA GROUNDWATER USE A water well inventory compiled as part of this investigation indicates a number of wells located (or formerly located) near the Stat ion. The locations of wells in the vicinity of the Station are provided on Figure 2.4. A water well report was prepared using Illinois water well databases and associated we ll logs, and is provided in Appendix A. The well records for locations nearest to the Station (map identifiers 5, 6, and  
045 136 (22) Zi on St ati o n 7 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 2.5 AREA GROUNDWATER USE A water well inventory compiled as part of this investigation indicates a number of wells located (or formerly located) near the Stat ion. The locations of wells in the vicinity of the Station are provided on Figure 2.4. A water well report was prepared using Illinois water well databases and associated we ll logs, and is provided in Appendix A. The well records for locations nearest to the Station (map identifiers 5, 6, and
: 10) are mis-located (Map Id. 5 1), not a water well (Map Id. 6 2), or no longer ex ist (Map Ids. 6 and 10 3). With the exception of Map Ids. 6 and 10, the wells identified in the water well report have not been field verified and it is ex pected that many of the wells listed have been abandoned.
: 10) are mis-located (Map Id. 5 1), not a water well (Map Id. 6 2), or no longer ex ist (Map Ids. 6 and 10 3). With the exception of Map Ids. 6 and 10, the wells identified in the water well report have not been field verified and it is ex pected that many of the wells listed have been abandoned.
The City of Zion provides municipal water to the City residents and the surrounding area. The City purchases water from the Lake County Public Water District (LCPWD).
The City of Zion provides municipal water to the City residents and the surrounding area. The City purchases water from the Lake County Public Water District (LCPWD).
The LCPWD obtains its water from Lake Mich igan by means of an intake pipe located approx imately 1.1 mile north of the Station and ex tending 3,000 feet into the Lake. The City of Zion municipal code requires all im proved properties to be connected to the City's water supply. It is "unlawful for any person to construct, permit or maintain a private well or water supply system within the City which uses groundwater as a potable water supply" (City of Zion, 2004). The only ex ception is for ex isting wells constructed prior to March 2, 2004 at proper ties located more than 100 feet from the municipal supply system, which must:  
The LCPWD obtains its water from Lake Mich igan by means of an intake pipe located approx imately 1.1 mile north of the Station and ex tending 3,000 feet into the Lake. The City of Zion municipal code requires all im proved properties to be connected to the City's water supply. It is "unlawful for any person to construct, permit or maintain a private well or water supply system within the City which uses groundwater as a potable water supply" (City of Zion, 2004). The only ex ception is for ex isting wells constructed prior to March 2, 2004 at proper ties located more than 100 feet from the municipal supply system, which must:
: 1) en ter into an agreement with the City, and  
: 1) en ter into an agreement with the City, and
: 2) demonstrate that the well water is unlikely to contain any contaminant at concentrations exceeding the United States Environmental Protection Agency (USEPA) drinking water standards (City of Zion, 2004).
: 2) demonstrate that the well water is unlikely to contain any contaminant at concentrations exceeding the United States Environmental Protection Agency (USEPA) drinking water standards (City of Zion, 2004).
The Station is connected to the Zion municipal water supply and does not use groundwater in its operations.
The Station is connected to the Zion municipal water supply and does not use groundwater in its operations.
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The t o t a l dept h was 15 feet. This boring was inst alled as part of a st udy document ed in Fraser and Hest er (1974).
The t o t a l dept h was 15 feet. This boring was inst alled as part of a st udy document ed in Fraser and Hest er (1974).
045 136 (22) Zi on St ati o n 8 C ONESTOGA-R OVERS & A SSOCIATES 3 Map ID 10 is a wat e r well inst alled by F H Fergus on at 'Zion Estates' at an unknown date. The t o t a l dep t h of t h e well was 138 feet. The locat i on sp ecified in t h e well record (42.446046N, 87.800889W) indicat e s t h at t h is well was locat e d on t h e east ern edge of what is now t h e Z i on St at ion.  'Zion Est a t e s' may have been part of t h e Hosah Beach subdivision (see Bannon-Nilles 2003) which was p u rchased b y C o m Ed in ab out 1967. This well is not current ly p r esent at t h e Zion Sta t ion.
045 136 (22) Zi on St ati o n 8 C ONESTOGA-R OVERS & A SSOCIATES 3 Map ID 10 is a wat e r well inst alled by F H Fergus on at 'Zion Estates' at an unknown date. The t o t a l dep t h of t h e well was 138 feet. The locat i on sp ecified in t h e well record (42.446046N, 87.800889W) indicat e s t h at t h is well was locat e d on t h e east ern edge of what is now t h e Z i on St at ion.  'Zion Est a t e s' may have been part of t h e Hosah Beach subdivision (see Bannon-Nilles 2003) which was p u rchased b y C o m Ed in ab out 1967. This well is not current ly p r esent at t h e Zion Sta t ion.
Revision 1  
Revision 1 3.0 AREAS FOR FURTHER EVALUATION CRA considered all Station operations in asse ssing groundwater q u ality at the Station. During this process, CRA identified area s at the Station that warranted further evaluation or "AFEs". This section discusse s the process by which AFEs were selected.
 
===3.0 AREAS===
FOR FURTHER EVALUATION CRA considered all Station operations in asse ssing groundwater q u ality at the Station. During this process, CRA identified area s at the Station that warranted further evaluation or "AFEs". This section discusse s the process by which AFEs were selected.
CRA's identification of AFEs in volved the following components:
CRA's identification of AFEs in volved the following components:
Station inspection on March 22 to 23, 2006; interviews with Station personnel; evaluation of Station systems; investigation of confirmed and unconfirmed releases of radionuclides; and review of previous Station investigations.
Station inspection on March 22 to 23, 2006; interviews with Station personnel; evaluation of Station systems; investigation of confirmed and unconfirmed releases of radionuclides; and review of previous Station investigations.
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The ARMS survey showed that cosmic ray ex posure rate was substantially less than the northern Illinois background radiation level (ComEd, 1999).
The ARMS survey showed that cosmic ray ex posure rate was substantially less than the northern Illinois background radiation level (ComEd, 1999).
Soil samples contained small concentratio ns of uranium-238 and thorium-232.
Soil samples contained small concentratio ns of uranium-238 and thorium-232.
Cesium-137 activity in soil samples ranged from 0.276 to 0.40 picoCuries per gram (pCi/g) (ComEd, 1999).  
Cesium-137 activity in soil samples ranged from 0.276 to 0.40 picoCuries per gram (pCi/g) (ComEd, 1999).
 
3.3.2 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM The REMP at the Station was initiated in 1973. The REMP includes the collection of multi-media samples including air, surface water, groundwater, fish, sediment, and vegetation. The samples are analyzed fo r beta and gamma-emitting radionuclides, tritium, iodine-131, and/or strontium as esta blished in the procedures developed for the REMP. The samples are collected at established locations, identified as stations, so that trends in the data can be monitored.
====3.3.2 RADIOLOGICAL====
ENVIRONMENTAL MONITORING PROGRAM The REMP at the Station was initiated in 1973. The REMP includes the collection of multi-media samples including air, surface water, groundwater, fish, sediment, and vegetation. The samples are analyzed fo r beta and gamma-emitting radionuclides, tritium, iodine-131, and/or strontium as esta blished in the procedures developed for the REMP. The samples are collected at established locations, identified as stations, so that trends in the data can be monitored.
An annual report is prepared providing a desc ription of the activities performed and the results of the analysis of the samples collected from the various media. The latest report generated was prepared by Station personne l and is entitled Final Monthly Progress Report to Ex elon Nuclear, Radiological En vironmental Monitoring Program -
An annual report is prepared providing a desc ription of the activities performed and the results of the analysis of the samples collected from the various media. The latest report generated was prepared by Station personne l and is entitled Final Monthly Progress Report to Ex elon Nuclear, Radiological En vironmental Monitoring Program -
2005. This report concluded that the operation of the St ation had no adverse radiological impact on the environment. The annual report is submitted to the NRC.
2005. This report concluded that the operation of the St ation had no adverse radiological impact on the environment. The annual report is submitted to the NRC.
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After 1998, surface water samples were collect ed at the following four locations along Lake Michigan:
After 1998, surface water samples were collect ed at the following four locations along Lake Michigan:
Kenosha, Wisconsin (intake located 10 miles north of the Station); Lake County Public Water District (intake located 1.1 miles north of the Station); Waukegan, Illinois (intake located 6 miles south of the Station); and Lake Forest, Illinois (intake located 16.5 miles south of the Station).
Kenosha, Wisconsin (intake located 10 miles north of the Station); Lake County Public Water District (intake located 1.1 miles north of the Station); Waukegan, Illinois (intake located 6 miles south of the Station); and Lake Forest, Illinois (intake located 16.5 miles south of the Station).
Lake Michigan surface water data are colle c t e d a s p a r t o f t h e R E M P. T r i t i u m concentrations in surface water samp les from Lake Michigan ranged from non-detect to 660 pCi/L.  
Lake Michigan surface water data are colle c t e d a s p a r t o f t h e R E M P. T r i t i u m concentrations in surface water samp les from Lake Michigan ranged from non-detect to 660 pCi/L.
 
3.3.3 DEFUELED SAFETY ANALYSIS REPORT In October 2004, Ex elon updated the Defueled Safety Analysis Report (DSAR). The DSAR discusses the overall adeq uacy of the Station for safety, storing, and handling of fuel and radioactive waste, and to monitor pote ntial radiological effluent release paths.
====3.3.3 DEFUELED====
SAFETY ANALYSIS REPORT In October 2004, Ex elon updated the Defueled Safety Analysis Report (DSAR). The DSAR discusses the overall adeq uacy of the Station for safety, storing, and handling of fuel and radioactive waste, and to monitor pote ntial radiological effluent release paths.
It provides information on Station and lo cal characteristics such as geography, demography, meteorology, geology, and hydrogeology.
It provides information on Station and lo cal characteristics such as geography, demography, meteorology, geology, and hydrogeology.
The DSAR states that intermittent liquid effluents from the Station will not affect groundwater supplies in the adjacent area in ex cess of concentrations in 10 CFR 20 due to local drainage patterns, release rates, and specific features of the sources of water supplies.
The DSAR states that intermittent liquid effluents from the Station will not affect groundwater supplies in the adjacent area in ex cess of concentrations in 10 CFR 20 due to local drainage patterns, release rates, and specific features of the sources of water supplies.
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Discharged liquid wastes are monitored to assure compliance with 10 CFR 20. Radioactiv ity levels should not exceed permissible concentrations at the cooling water outlet in Lake Michigan. The two closest municipal water intakes are the LCPWD (approx imately 1 mile north) and the Waukegan Waterworks (approx imately 6 miles south).
Discharged liquid wastes are monitored to assure compliance with 10 CFR 20. Radioactiv ity levels should not exceed permissible concentrations at the cooling water outlet in Lake Michigan. The two closest municipal water intakes are the LCPWD (approx imately 1 mile north) and the Waukegan Waterworks (approx imately 6 miles south).
The February 2005 REMP report indicates that there have been no tritium concentratio ns detected in surface water samples at concentrations ex ceeding the lower limit of detection (LLD) of 200 pCi/L.
The February 2005 REMP report indicates that there have been no tritium concentratio ns detected in surface water samples at concentrations ex ceeding the lower limit of detection (LLD) of 200 pCi/L.
045 136 (22) Zi on St ati o n 14 C ONESTOGA-R OVERS & A SSOCIATES Revision 1  
045 136 (22) Zi on St ati o n 14 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 3.3.4 WISCONSIN DEPARTMENT OF HEALTH AND FAMILY SERVICES MONITORING The Wisconsin Public Health Statutes 254.41 mandates the Department of Health and Family Services (DHFS) to conduct enviro nmental radiation monitoring around the nuclear power facilities that impact Wiscon sin. The Station is included in this monitoring due to its prox imity to th e Wisconsin border. In the 2004 Zion Environmental Radioactivity Survey , the Wisconsin DHFS concluded:
 
====3.3.4 WISCONSIN====
DEPARTMENT OF HEALTH AND FAMILY SERVICES MONITORING The Wisconsin Public Health Statutes 254.41 mandates the Department of Health and Family Services (DHFS) to conduct enviro nmental radiation monitoring around the nuclear power facilities that impact Wiscon sin. The Station is included in this monitoring due to its prox imity to th e Wisconsin border. In the 2004 Zion Environmental Radioactivity Survey , the Wisconsin DHFS concluded:
air particulate analysis shows no evidence of influence by the Station on air q u ality; the average yearly exposure of ambient ga mma radiation is at background levels and is comparable to other areas within Wisconsin; the surface water samples showed no unus ual concentrations of gross beta, gross gamma, tritium, and strontium; the gamma isotopic analysis for surface wa ter indicated radioisotopes below their respective minimum detectable concentration; the gamma isotopic analysis on vegetation detected only a small amount of the naturally occurring elements potassium-40 and beryllium-7; the gamma isotopic analysis for soil detected potassium-40 and cesium-137.
air particulate analysis shows no evidence of influence by the Station on air q u ality; the average yearly exposure of ambient ga mma radiation is at background levels and is comparable to other areas within Wisconsin; the surface water samples showed no unus ual concentrations of gross beta, gross gamma, tritium, and strontium; the gamma isotopic analysis for surface wa ter indicated radioisotopes below their respective minimum detectable concentration; the gamma isotopic analysis on vegetation detected only a small amount of the naturally occurring elements potassium-40 and beryllium-7; the gamma isotopic analysis for soil detected potassium-40 and cesium-137.
These were also detected in previous years and are naturally occurring  (potassium-40) or attributable to fallout from previous atmospheric nuclear tests (cesium-137); and doses of radiation as a result of gaseous and liq uid effluent are less than the limits allowed for an average individual as stated in Federal Regulations.  
These were also detected in previous years and are naturally occurring  (potassium-40) or attributable to fallout from previous atmospheric nuclear tests (cesium-137); and doses of radiation as a result of gaseous and liq uid effluent are less than the limits allowed for an average individual as stated in Federal Regulations.
 
3.4 IDENTIFIED AREAS FOR FURTHER EVALUATION CRA used the information presented in the ab ove sections along with its understanding of the hydrogeology at the Station to identi fy AFEs, which were a primary consideration in the development of the scope of work in th e Work Plan. The establishment of AFEs is a standard planning practice in hydrogeologic investigations to focus the investigation activities at areas where ther e is the greatest potential for impact to groundwater.
===3.4 IDENTIFIED===
AREAS FOR FURTHER EVALUATION CRA used the information presented in the ab ove sections along with its understanding of the hydrogeology at the Station to identi fy AFEs, which were a primary consideration in the development of the scope of work in th e Work Plan. The establishment of AFEs is a standard planning practice in hydrogeologic investigations to focus the investigation activities at areas where ther e is the greatest potential for impact to groundwater.
Specifically, AFEs were identified based on these six considerations:
Specifically, AFEs were identified based on these six considerations:
systems evaluations; risk evaluations; review of confirmed and/or potential releases; 045 136 (22) Zi on St ati o n 15 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 review of documents; review of the hydrogeologic conditions; and Station inspection completed on March 22 and 23, 2006.
systems evaluations; risk evaluations; review of confirmed and/or potential releases; 045 136 (22) Zi on St ati o n 15 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 review of documents; review of the hydrogeologic conditions; and Station inspection completed on March 22 and 23, 2006.
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The scope of work presented in the Work Pl an included the installation and sampling of nine permanent monitoring wells and the colle ction of a surface water sample. Based on the concentrations of tritium detected in monitoring well MW-ZN-01S, additional investigative activities were recommended by CRA, and implemented in June and July 2006. The additional investigative tasks included a second round of sampling at MW-ZN-01S and the installation and sampling of two permanent and four temporary monitoring wells. The additional investigat ive activities provided plume delineation and additional hydraulic information cross-gradient and down-gradient of MW-ZN-01S.
The scope of work presented in the Work Pl an included the installation and sampling of nine permanent monitoring wells and the colle ction of a surface water sample. Based on the concentrations of tritium detected in monitoring well MW-ZN-01S, additional investigative activities were recommended by CRA, and implemented in June and July 2006. The additional investigative tasks included a second round of sampling at MW-ZN-01S and the installation and sampling of two permanent and four temporary monitoring wells. The additional investigat ive activities provided plume delineation and additional hydraulic information cross-gradient and down-gradient of MW-ZN-01S.
The groundwater sampling events undertaken as part of the investigation are:
The groundwater sampling events undertaken as part of the investigation are:
May 24-26, 2006 sampling of MW-ZN-01S through MW-ZN-09S; June 28, 2006 sampling of MW-ZN-01S (second round); July 17, 2006 sampling of TW-ZN-100 through TW-ZN-103; and July 28, 2006 sampling of MW-ZN-10S and MW-ZN-11S.  
May 24-26, 2006 sampling of MW-ZN-01S through MW-ZN-09S; June 28, 2006 sampling of MW-ZN-01S (second round); July 17, 2006 sampling of TW-ZN-100 through TW-ZN-103; and July 28, 2006 sampling of MW-ZN-10S and MW-ZN-11S.
 
4.1 STAFF GAUGE INSTALLATION Figure 4.1 presents the location of the staff ga uge installed as part of this investigation.
===4.1 STAFF===
GAUGE INSTALLATION Figure 4.1 presents the location of the staff ga uge installed as part of this investigation.
CRA installed staff gauge SG-ZN-01, which is a notch in a bridge within the Intake Crib.
CRA installed staff gauge SG-ZN-01, which is a notch in a bridge within the Intake Crib.
The Intake Crib is hydraulically connected to Lake Michigan via the intake tunnel that ex tends approx imately 1/2 mile into Lake Michigan.  
The Intake Crib is hydraulically connected to Lake Michigan via the intake tunnel that ex tends approx imately 1/2 mile into Lake Michigan.
 
4.2 GROUNDWATER MONITORING WELL INSTALLATION Prior to completing any ground penetration activities, CRA completed subsurface utility clearance procedures to minimi ze the potential of injury to workers and/or damage to subsurface utility structures. The subsur face clearance procedures consisted of completing an electronic survey within a mi nimum of 10-foot radius of the proposed location utilizing electromagnetic and gr ound penetrating radar technology.
===4.2 GROUNDWATER===
MONITORING WELL INSTALLATION Prior to completing any ground penetration activities, CRA completed subsurface utility clearance procedures to minimi ze the potential of injury to workers and/or damage to subsurface utility structures. The subsur face clearance procedures consisted of completing an electronic survey within a mi nimum of 10-foot radius of the proposed location utilizing electromagnetic and gr ound penetrating radar technology.
045 136 (22) Zi on St ati o n 18 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Additionally, a vacuum soft dig was used to verify utilities were not present at the proposed location to a depth to 10 feet bgs.
045 136 (22) Zi on St ati o n 18 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Additionally, a vacuum soft dig was used to verify utilities were not present at the proposed location to a depth to 10 feet bgs.
Fifteen new monitoring wells were inst alled for the fleetwide hydrogeologic investigation, including 11 permanent and 4 temporary monitoring wells.
Fifteen new monitoring wells were inst alled for the fleetwide hydrogeologic investigation, including 11 permanent and 4 temporary monitoring wells.
Monitoring well construction logs are provided in Appendix B. Figure  
Monitoring well construction logs are provided in Appendix B. Figure 4.1 presents the location of the 15 new monitoring wells. These locations we re selected based on a review of all data provided, the hydrogeology at the Station, and current understanding of identified AFEs, and modified based on conditions encountered during the investigation.
 
===4.1 presents===
the location of the 15 new monitoring wells. These locations we re selected based on a review of all data provided, the hydrogeology at the Station, and current understanding of identified AFEs, and modified based on conditions encountered during the investigation.
Table 4.1 summarizes the well installation details.
Table 4.1 summarizes the well installation details.
Specific installation protocols for the perm anent monitoring wells are described below:
Specific installation protocols for the perm anent monitoring wells are described below:
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10 slot) PVC screen, 10 or 20 feet in length, attached to a sufficient length of 2-inch diameter sc hedule 40 PVC riser pipe to extend to the surface, was placed into the borehole through the augers; a filter sand pack consisting of silica sand was installed to a minimum height of 2 feet above the top of the screen as the augers were removed; a minimum 2-foot thick seal consisting of 3/8-inch diameter bentonite pellets or chips was placed on top of the sand pack and hydrated using potable water; the remaining borehole annulus was sealed to within 3 feet of the surface using pure bentonite chips (the soft-dig portion of th e borehole was backfilled with a mixture of soil and bentonite); and the remaining portion of the annulus was fille d with concrete and a 6-inch diameter protective above-grade casing. The well he ad was fitted with a water-tight lockable cap. Specific installation protocols for the temp orary monitoring wells are described below:
10 slot) PVC screen, 10 or 20 feet in length, attached to a sufficient length of 2-inch diameter sc hedule 40 PVC riser pipe to extend to the surface, was placed into the borehole through the augers; a filter sand pack consisting of silica sand was installed to a minimum height of 2 feet above the top of the screen as the augers were removed; a minimum 2-foot thick seal consisting of 3/8-inch diameter bentonite pellets or chips was placed on top of the sand pack and hydrated using potable water; the remaining borehole annulus was sealed to within 3 feet of the surface using pure bentonite chips (the soft-dig portion of th e borehole was backfilled with a mixture of soil and bentonite); and the remaining portion of the annulus was fille d with concrete and a 6-inch diameter protective above-grade casing. The well he ad was fitted with a water-tight lockable cap. Specific installation protocols for the temp orary monitoring wells are described below:
the borehole was advanced to the target de pth using a 2-inch direct push technology (DPT) drill rig; a nominal 1-inch diameter (No.
the borehole was advanced to the target de pth using a 2-inch direct push technology (DPT) drill rig; a nominal 1-inch diameter (No.
10 slot) PVC screen, 15 or 20 feet in length, attached to a sufficient length of 1-inch diameter sc hedule 40 PVC riser pipe to extend to the surface, was placed into the borehole through the DPT casing; a filter sand pack consisting of silica sand was installed to a minimum height of 2 feet above the top of the screen as the augers were removed; 045 136 (22) Zi on St ati o n 19 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 a minimum 2-foot thick seal consisting of bentonite powder was placed on top of the sand pack; and the remaining borehole annulus was sealed at the surface using bentonite powder or chips. The shallow soil borings completed in unconsolid ated materials that were to be used for monitoring well installation were installed us ing either DPT or 4.25-inch inside diameter HSA drilling techniques. The borehole depths r anged from 19 to 45 feet bgs. During the subsurface utility clearance activities descri bed above, the borehole was periodically ex amined and the soil types documented. A description was added to each monitoring well construction log. The overburden so ils were classified using the Unified Soil Classification System (USCS).  
10 slot) PVC screen, 15 or 20 feet in length, attached to a sufficient length of 1-inch diameter sc hedule 40 PVC riser pipe to extend to the surface, was placed into the borehole through the DPT casing; a filter sand pack consisting of silica sand was installed to a minimum height of 2 feet above the top of the screen as the augers were removed; 045 136 (22) Zi on St ati o n 19 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 a minimum 2-foot thick seal consisting of bentonite powder was placed on top of the sand pack; and the remaining borehole annulus was sealed at the surface using bentonite powder or chips. The shallow soil borings completed in unconsolid ated materials that were to be used for monitoring well installation were installed us ing either DPT or 4.25-inch inside diameter HSA drilling techniques. The borehole depths r anged from 19 to 45 feet bgs. During the subsurface utility clearance activities descri bed above, the borehole was periodically ex amined and the soil types documented. A description was added to each monitoring well construction log. The overburden so ils were classified using the Unified Soil Classification System (USCS).
 
4.3 GROUNDWATER MONITORING WELL DEVELOPMENT To establish good hydraulic communication wi th the aquifer and reduce the volume of sediment in the permanent monitoring wells, well development was conducted in accordance with the procedure outlined below:
===4.3 GROUNDWATER===
MONITORING WELL DEVELOPMENT To establish good hydraulic communication wi th the aquifer and reduce the volume of sediment in the permanent monitoring wells, well development was conducted in accordance with the procedure outlined below:
monitoring wells were surged using a pre-cleaned bailer for a period of at least 5 minutes; a minimum of one well volume of water was purged using a submersible pump; the monitoring well was surged for 5 minutes again; water was purged from the monitoring well using an electric submersible pump; groundwater was collected at regular in tervals and the pH, temperature, and conductivity were measured using field instruments. These instruments were calibrated daily according to the manufact urer's specifications. Additionally, observations such as color, odor, and turb idity of the purged water were recorded; and development continued until the turbidity and silt content of the monitoring wells were significantly reduced and three consis tent readings of pH, temperature, and conductivity were recorded, or a mi nimum of ten well volumes was purged.
monitoring wells were surged using a pre-cleaned bailer for a period of at least 5 minutes; a minimum of one well volume of water was purged using a submersible pump; the monitoring well was surged for 5 minutes again; water was purged from the monitoring well using an electric submersible pump; groundwater was collected at regular in tervals and the pH, temperature, and conductivity were measured using field instruments. These instruments were calibrated daily according to the manufact urer's specifications. Additionally, observations such as color, odor, and turb idity of the purged water were recorded; and development continued until the turbidity and silt content of the monitoring wells were significantly reduced and three consis tent readings of pH, temperature, and conductivity were recorded, or a mi nimum of ten well volumes was purged.
A summary of the monitoring well developm ent parameter measurements is presented in Table 4.2.
A summary of the monitoring well developm ent parameter measurements is presented in Table 4.2.
045 136 (22) Zi on St ati o n 20 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 4.4 S U R V E Y The 15 monitoring wells and surface water ga uge were surveyed to establish reference elevations relative to mean sea level.
045 136 (22) Zi on St ati o n 20 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 4.4 S U R V E Y The 15 monitoring wells and surface water ga uge were surveyed to establish reference elevations relative to mean sea level.
The top of each well casing was surveyed to the nearest 0.01 foot relative to the National Geodetic Vertical Datum (NGVD), and the survey point was marked on the well casing. The survey included the ground elevation at each well to the nearest 0.10 foot relative to the NGVD, and the horizontal well location to the nearest 1.0 foot. A reference point was also marked on the concrete at the surface water elevation measuring location.
The top of each well casing was surveyed to the nearest 0.01 foot relative to the National Geodetic Vertical Datum (NGVD), and the survey point was marked on the well casing. The survey included the ground elevation at each well to the nearest 0.10 foot relative to the NGVD, and the horizontal well location to the nearest 1.0 foot. A reference point was also marked on the concrete at the surface water elevation measuring location.
The Lake Michigan shoreline was surveyed at the Station using a handheld Global Positioning System (GPS) with an estimated a ccuracy of +/- 12 feet. The GPS survey was conducted on June 30, 2006.  
The Lake Michigan shoreline was surveyed at the Station using a handheld Global Positioning System (GPS) with an estimated a ccuracy of +/- 12 feet. The GPS survey was conducted on June 30, 2006.
 
4.5 GROUNDWATER AND SURFACE WATER ELEVATION MEASUREMENTS On May 23, 2006 and July 27, 2006, CRA collected water level measurements from the monitoring wells and the staff gauge at the Station in accordance with the Work Plan.
===4.5 GROUNDWATER===
AND SURFACE WATER ELEVATION MEASUREMENTS On May 23, 2006 and July 27, 2006, CRA collected water level measurements from the monitoring wells and the staff gauge at the Station in accordance with the Work Plan.
Based on the measured depth to water from the reference point and the surveyed elevation of the reference point, the gr oundwater or surface water elevation was calculated.
Based on the measured depth to water from the reference point and the surveyed elevation of the reference point, the gr oundwater or surface water elevation was calculated.
A summary of groundwater and surface water elevations is provided in Table 4.3.
A summary of groundwater and surface water elevations is provided in Table 4.3.
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Cross-Section B-B' (Figure 5.3) is an west-e ast profile that runs from monitoring well MW-ZN-07 through the Station to Lake Michigan and intersects AFE-Zion-1 and 045 136 (22) Zi on St ati o n 28 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 AFE-Zion-3.
Cross-Section B-B' (Figure 5.3) is an west-e ast profile that runs from monitoring well MW-ZN-07 through the Station to Lake Michigan and intersects AFE-Zion-1 and 045 136 (22) Zi on St ati o n 28 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 AFE-Zion-3.
This cross-section shows the relationship between the groundwater and geology, and building foundations.
This cross-section shows the relationship between the groundwater and geology, and building foundations.
5.2 S T A T I O N HYDROGEOLOGY This section presents the Station hydrogeolo gy, including groundwater flow direction, man-made influences on groundwater flow, vertical hydraulic gradients, and lateral groundwater flow and velocity.  
5.2 S T A T I O N HYDROGEOLOGY This section presents the Station hydrogeolo gy, including groundwater flow direction, man-made influences on groundwater flow, vertical hydraulic gradients, and lateral groundwater flow and velocity.
 
5.2.1 GROUNDWATER FLOW DIRECTIONS The shallow groundwater flows to the east toward Lake Michigan. The building foundations restrict the groundwater flow , which causes the groundwater to flow around the Station. As mentioned previous ly, the shallow water table intercepts the stormwater drainage ditches in the west area of the Station property, but does appear to affect the flow of groundwater to the east and toward Lake Michigan.
====5.2.1 GROUNDWATER====
FLOW DIRECTIONS The shallow groundwater flows to the east toward Lake Michigan. The building foundations restrict the groundwater flow , which causes the groundwater to flow around the Station. As mentioned previous ly, the shallow water table intercepts the stormwater drainage ditches in the west area of the Station property, but does appear to affect the flow of groundwater to the east and toward Lake Michigan.
Groundwater flow directions for May 2006 are provided on Fi gure 5.4, flow directions for July 2006 are provided on Figure 5.5. Both figures present groundwater flow in the shallow groundwater system. The sheet pile wall lim its the flow of groundwater towards Lake Michigan. Groundwater between the sheet p ile wall and the Turbine Building flows to the north or south around the wall. Althou gh groundwater flow circumscribes the sheet pile wall, a small component of leakage through the wall is expected.
Groundwater flow directions for May 2006 are provided on Fi gure 5.4, flow directions for July 2006 are provided on Figure 5.5. Both figures present groundwater flow in the shallow groundwater system. The sheet pile wall lim its the flow of groundwater towards Lake Michigan. Groundwater between the sheet p ile wall and the Turbine Building flows to the north or south around the wall. Althou gh groundwater flow circumscribes the sheet pile wall, a small component of leakage through the wall is expected.
The sheet pile wall is constructed of MZ-27 steel sheet piling. MZ-27 sheet piling is comprised of z-shaped sheet steel sections which are 18-inches wide with a 12-inch offset. The sections are 45 feet long, 3/8-inch thick, and weigh 27 pounds per sq uare foot of wall.
The sheet pile wall is constructed of MZ-27 steel sheet piling. MZ-27 sheet piling is comprised of z-shaped sheet steel sections which are 18-inches wide with a 12-inch offset. The sections are 45 feet long, 3/8-inch thick, and weigh 27 pounds per sq uare foot of wall.
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045 136 (22) Zi on St ati o n 29 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 During the construction of the Station, a sheet pile wall was installed along the Lake Michigan shoreline to prevent lake water from entering the excavation. The sheet pile wall was modified over the course of the co nstruction and currently ex tends to a depth of approximately 45 feet bgs. The top of th e sheet pile wall is lined with boulders and forms a breakwall, which is shown on Figure 5.3.
045 136 (22) Zi on St ati o n 29 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 During the construction of the Station, a sheet pile wall was installed along the Lake Michigan shoreline to prevent lake water from entering the excavation. The sheet pile wall was modified over the course of the co nstruction and currently ex tends to a depth of approximately 45 feet bgs. The top of th e sheet pile wall is lined with boulders and forms a breakwall, which is shown on Figure 5.3.
Shallow groundwater will flow into the stormw ater drainage ditches located on the west portion of the Station property. However, the groundwater in this area is upgradient of the PA and areas within the Station that potent ially contain tritiated water. As such the groundwater discharge to these stormwater sy stems is not expected to be impacted by tritium. 5.2.3 VERTICAL HYDRAULIC GRADIENTS The Upper Sand Unit is a high permeability unit that is directly connected to Lake Michigan, which is a regional discharge feature, and which generally allows unrestricted lateral groundwater flow. Vertical ground water flow is limited by the underlying Silt-Clay Unit, which has a low permeability and is approximately 30 feet thick.
Shallow groundwater will flow into the stormw ater drainage ditches located on the west portion of the Station property. However, the groundwater in this area is upgradient of the PA and areas within the Station that potent ially contain tritiated water. As such the groundwater discharge to these stormwater sy stems is not expected to be impacted by tritium. 5.2.3 VERTICAL HYDRAULIC GRADIENTS The Upper Sand Unit is a high permeability unit that is directly connected to Lake Michigan, which is a regional discharge feature, and which generally allows unrestricted lateral groundwater flow. Vertical ground water flow is limited by the underlying Silt-Clay Unit, which has a low permeability and is approximately 30 feet thick.
To the ex tent that vertical flow can occur, the vertic al gradient is ex pected to be upward based on the artesian pressure observed in the Lower Sand Unit during the 1967 Foundation Investigation (Dames and Moore, 1967).  
To the ex tent that vertical flow can occur, the vertic al gradient is ex pected to be upward based on the artesian pressure observed in the Lower Sand Unit during the 1967 Foundation Investigation (Dames and Moore, 1967).
 
5.2.4 LATERAL GROUNDWATER FLOW AND VELOCITY Fifteen monitoring wells were installed at the Station as part of the 2006 hydrogeologic investigation.
====5.2.4 LATERAL====
GROUNDWATER FLOW AND VELOCITY Fifteen monitoring wells were installed at the Station as part of the 2006 hydrogeologic investigation.
Shallow groundwater is present at a depth less than 12 feet bgs in the Upper Sand Unit. The shallow water-bearin g zone is isolated from the underlying regional bedrock aquifers by the underlying Silt-Clay Unit. The Silt-Clay Unit is approx imately 30 feet thick and ex tends approximately 15 feet below the deepest structural feature at the Station.
Shallow groundwater is present at a depth less than 12 feet bgs in the Upper Sand Unit. The shallow water-bearin g zone is isolated from the underlying regional bedrock aquifers by the underlying Silt-Clay Unit. The Silt-Clay Unit is approx imately 30 feet thick and ex tends approximately 15 feet below the deepest structural feature at the Station.
Shallow groundwater flows is generally to wards Lake Michigan. A potentiometric surface contour map is provided on Figure 5.4 (May 2006) and Figure 5.5 (July 2006).
Shallow groundwater flows is generally to wards Lake Michigan. A potentiometric surface contour map is provided on Figure 5.4 (May 2006) and Figure 5.5 (July 2006).
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OF FIELD MEASUREMENTS Table 4.5 presents a summary of monitoring well purging parameters collected during the well purging and sampling activities.
OF FIELD MEASUREMENTS Table 4.5 presents a summary of monitoring well purging parameters collected during the well purging and sampling activities.
These field measurements included pH, dissolved oxygen, conductivity, turbidity, and temperature. The field parameters were typical of a shallow sand aq uifer. The pH values ranged from 5.51 standard units to 045 136 (22) Zi on St ati o n 32 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 10.42 standard units. The conductivity was indicative of a shallow water table system subject to surface water recharge.
These field measurements included pH, dissolved oxygen, conductivity, turbidity, and temperature. The field parameters were typical of a shallow sand aq uifer. The pH values ranged from 5.51 standard units to 045 136 (22) Zi on St ati o n 32 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 10.42 standard units. The conductivity was indicative of a shallow water table system subject to surface water recharge.
Of note were the elevated turbidity read ings above 900 NTU collected from the lower portion of the screen at MW-ZN-04S; howeve r, the elevated turbidity readings are indicative of the very loose and fine-grained organic material at this well's lower screen interval, as shown on the MW-ZN-04S stratigr aphic log. Overall, the readings were within the ex pected ranges for naturally occurring groundwater.  
Of note were the elevated turbidity read ings above 900 NTU collected from the lower portion of the screen at MW-ZN-04S; howeve r, the elevated turbidity readings are indicative of the very loose and fine-grained organic material at this well's lower screen interval, as shown on the MW-ZN-04S stratigr aphic log. Overall, the readings were within the ex pected ranges for naturally occurring groundwater.
 
5.4 SURFACE WATER QUALITY One surface water sample was collected from Lake Michigan at the location shown on Figure 4.1. This sample was analyzed fo r tritium, gamma-emitting radionuclides, and strontium-89/90. Teledyne Brown provided the analytical services. The Quality Assurance Program for the laboratory is desc ribed in Appendix C. The analytical data reports are provided in Appendix D.
===5.4 SURFACE===
WATER QUALITY One surface water sample was collected from Lake Michigan at the location shown on Figure 4.1. This sample was analyzed fo r tritium, gamma-emitting radionuclides, and strontium-89/90. Teledyne Brown provided the analytical services. The Quality Assurance Program for the laboratory is desc ribed in Appendix C. The analytical data reports are provided in Appendix D.
5.4.1 S U M M A R Y O F B E T A-E M I T T I N G R A D I O N U C L I D E ANALYTICAL RESULTS Tritium was not detected at concentrations ex ceeding the LLD of 200 pCi/L. A summary of the tritium result for the surface water sample collected in this investigation is provided in Table 5.1 and shown on Figure 5.6.
5.4.1 S U M M A R Y O F B E T A-E M I T T I N G R A D I O N U C L I D E ANALYTICAL RESULTS Tritium was not detected at concentrations ex ceeding the LLD of 200 pCi/L. A summary of the tritium result for the surface water sample collected in this investigation is provided in Table 5.1 and shown on Figure 5.6.
Strontium-89/90 was not detected at concentrat ion exceeding the LLD of 2.0 pCi/L. The strontium-89/90 result for the surface water sa mple collected in this investigation is provided in Table 5.2 and shown on Figure 5.7.
Strontium-89/90 was not detected at concentrat ion exceeding the LLD of 2.0 pCi/L. The strontium-89/90 result for the surface water sa mple collected in this investigation is provided in Table 5.2 and shown on Figure 5.7.
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Other non-targeted radionuclides are incl uded in the tables but excluded from discussion in this report.
Other non-targeted radionuclides are incl uded in the tables but excluded from discussion in this report.
These radionuclid es were either a) naturally occurring and 045 136 (22) Zi on St ati o n 33 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 thus not produced by the Station, or b) coul d be definitively evaluated as being naturally occurring due to the lack of presence of other radionuclides which would otherwise indicate the potential of production from the Station.
These radionuclid es were either a) naturally occurring and 045 136 (22) Zi on St ati o n 33 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 thus not produced by the Station, or b) coul d be definitively evaluated as being naturally occurring due to the lack of presence of other radionuclides which would otherwise indicate the potential of production from the Station.
045 136 (22) Zi on St ati o n 34 C ONESTOGA-R OVERS & A SSOCIATES Revision 1  
045 136 (22) Zi on St ati o n 34 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 6.0 RADIONUCLIDES OF CONCERN AND SOURCE AREAS This section discusses radionuclides evaluated in this investigation, potential sources of the radionuclides detected, and their distribution.
 
===6.0 RADIONUCLIDES===
OF CONCERN AND SOURCE AREAS This section discusses radionuclides evaluated in this investigation, potential sources of the radionuclides detected, and their distribution.
6.1 G A M M A-E M I T T I N G RADIONUCLIDES Gamma-emitting target radionuclides were not detected at concentration exceeding their respective LLD. Other non-targeted radionuclid es were also included in the tables but excluded from discussion in this report. These radionuclides were either a) naturally occurring and thus not produced by the Station, or b) could be definitively evaluated as being naturally occurring due to the lack of presence of other radionuclides which would otherwise indicate the potentia l of production from the Station.
6.1 G A M M A-E M I T T I N G RADIONUCLIDES Gamma-emitting target radionuclides were not detected at concentration exceeding their respective LLD. Other non-targeted radionuclid es were also included in the tables but excluded from discussion in this report. These radionuclides were either a) naturally occurring and thus not produced by the Station, or b) could be definitively evaluated as being naturally occurring due to the lack of presence of other radionuclides which would otherwise indicate the potentia l of production from the Station.
6.2 B E T A-E M I T T I N G RADIONUCLIDES Strontium-89/90 was not detected in any of the samples collected at concentrations that were greater than the LLD of 2.0 pCi/L. Tritium was detected in one of the six t een total sample locations.
6.2 B E T A-E M I T T I N G RADIONUCLIDES Strontium-89/90 was not detected in any of the samples collected at concentrations that were greater than the LLD of 2.0 pCi/L. Tritium was detected in one of the six t een total sample locations.
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Although tritium can be a gas, its most common form is in water because, like non-radioactive hydrogen, radioactive tritiu m reacts with oxygen to form water. Tritium replaces one of the stable hydrogen atoms in the water molecule and is called tritiated water. Like normal water, tritiate d water is colorless and odorless. Tritiated water behaves chemically and physically like non-tritiated water in the subsurface, and therefore tritiated water will travel at the same velocity as the average groundwater velocity.
Although tritium can be a gas, its most common form is in water because, like non-radioactive hydrogen, radioactive tritiu m reacts with oxygen to form water. Tritium replaces one of the stable hydrogen atoms in the water molecule and is called tritiated water. Like normal water, tritiate d water is colorless and odorless. Tritiated water behaves chemically and physically like non-tritiated water in the subsurface, and therefore tritiated water will travel at the same velocity as the average groundwater velocity.
Tritium has a half-life of approx imately 12.3 ye ars. It decays spontaneously to helium-3 (3 He). This radioactive decay releases a be ta particle (low-energy electron). The radioactivity of tritium is the so urce of the risk of exposure.
Tritium has a half-life of approx imately 12.3 ye ars. It decays spontaneously to helium-3 (3 He). This radioactive decay releases a be ta particle (low-energy electron). The radioactivity of tritium is the so urce of the risk of exposure.
Tritium is one of the least dangerous radionuc lides because it emits very weak radiation and leaves the body relatively quickly. Since tritium is almost always found as water, it goes directly into soft tissues and organs. The associated dose to these tissues is generally uniform and is dependent on the water content of the specific tissue.  
Tritium is one of the least dangerous radionuc lides because it emits very weak radiation and leaves the body relatively quickly. Since tritium is almost always found as water, it goes directly into soft tissues and organs. The associated dose to these tissues is generally uniform and is dependent on the water content of the specific tissue.
 
6.3.2 DISTRIBUTION IN STATION GROUNDWATER This section provides an overview of the la teral and vertical distribution of tritium detected in groundwater at the Station.
====6.3.2 DISTRIBUTION====
IN STATION GROUNDWATER This section provides an overview of the la teral and vertical distribution of tritium detected in groundwater at the Station.
Tritium was detected in groundwater at concentrations ex ceeding the LLD of 200 pCi/L.
Tritium was detected in groundwater at concentrations ex ceeding the LLD of 200 pCi/L.
Tritium concentrations in groundwater are pr esented on Figure  
Tritium concentrations in groundwater are pr esented on Figure 5.6. Tritium was only detected in groundwater samples from mo nitoring well MW-ZN-01S in May 2006 from both the upper sampling interval (261  124 pCi/L, 22 feet bgs) and the lower sampling interval (586  141 pCi/L, 35 feet bgs). Tritium was only detected in groundwater 045 136 (22) Zi on St ati o n 36 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 samples from monitoring well MW-ZN-01S in June 2006 in the upper sampling interval (220  123 pCi/L, 22 feet bgs). Tritium was not detected above the LLD of 200 pCi/L in June 2006 at the MW-ZN-01S lower sampling interval.
 
6.3.3 CONCEPTUAL MODEL OF TRITIUM RELEASE AND MIGRATION This Section presents CRA's conceptual mode l of groundwater and tritium migration at the Station.
===5.6. Tritium===
 
was only detected in groundwater samples from mo nitoring well MW-ZN-01S in May 2006 from both the upper sampling interval (261  124 pCi/L, 22 feet bgs) and the lower sampling interval (586  141 pCi/L, 35 feet bgs). Tritium was only detected in groundwater 045 136 (22) Zi on St ati o n 36 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 samples from monitoring well MW-ZN-01S in June 2006 in the upper sampling interval (220  123 pCi/L, 22 feet bgs). Tritium was not detected above the LLD of 200 pCi/L in June 2006 at the MW-ZN-01S lower sampling interval.  
 
====6.3.3 CONCEPTUAL====
MODEL OF TRITIUM RELEASE AND MIGRATION This Section presents CRA's conceptual mode l of groundwater and tritium migration at the Station.
A conceptual model of groundwater and trit ium migration is provided herein.
A conceptual model of groundwater and trit ium migration is provided herein.
This model is then used to discuss the recent detections of tritium observed during the hydrogeologic investigations presented in this HIR.
This model is then used to discuss the recent detections of tritium observed during the hydrogeologic investigations presented in this HIR.
Groundwater flows within the Upper Sand Un it at the Station in response to the regional discharge point located to the east of the Station (Lake Michigan).
Groundwater flows within the Upper Sand Un it at the Station in response to the regional discharge point located to the east of the Station (Lake Michigan).
Groundwater moving within the Upper Sand Unit is separated from the regional bedrock aquifer zones by the underlyi n g l o w-p e r m e a b i l i t y S i l t-C l a y U n i t. Groundwater in the Upper Sand Unit generally flows to the east and discharges to Lake Michigan. Groundwater flowing in Upper Sand Unit is affected by the building foundations which, in some cases, extend into the underlying glacial silts and clays. The sheet pile wall also limits the flow of ground water towards Lake Michigan. There is no indication from the HIR investigation that tritium-impacted groundwater is migrating off the Station property.  
Groundwater moving within the Upper Sand Unit is separated from the regional bedrock aquifer zones by the underlyi n g l o w-p e r m e a b i l i t y S i l t-C l a y U n i t. Groundwater in the Upper Sand Unit generally flows to the east and discharges to Lake Michigan. Groundwater flowing in Upper Sand Unit is affected by the building foundations which, in some cases, extend into the underlying glacial silts and clays. The sheet pile wall also limits the flow of ground water towards Lake Michigan. There is no indication from the HIR investigation that tritium-impacted groundwater is migrating off the Station property.
 
6.3.4 ATTENUATION OF TRITIUM WITHIN THE SHALLOW GROUNDWATER SYSTEM Tritium in the groundwater system would be affected by the infiltration from precipitation recharge. This could result in the upper water table zone of the sand aq uifer having lower concentrations of trit ium than deeper portions (these upper and lower zones are only separated by 10 feet).
====6.3.4 ATTENUATION====
OF TRITIUM WITHIN THE SHALLOW GROUNDWATER SYSTEM Tritium in the groundwater system would be affected by the infiltration from precipitation recharge. This could result in the upper water table zone of the sand aq uifer having lower concentrations of trit ium than deeper portions (these upper and lower zones are only separated by 10 feet).
The permeable nature of the Upper Sand Unit also supports attenuation of the tritium through lateral groundwater movement. The dispersion of the tritium as it flows through the Upper Sand Unit along with its natural decay rate will allow for reduction in concentrations over time and with dist ance from a release into the groundwater.
The permeable nature of the Upper Sand Unit also supports attenuation of the tritium through lateral groundwater movement. The dispersion of the tritium as it flows through the Upper Sand Unit along with its natural decay rate will allow for reduction in concentrations over time and with dist ance from a release into the groundwater.
045 136 (22) Zi on St ati o n 37 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Tritium was not detected at concentrations ex ceeding the LLD of 200 pCi/L in the four temporary wells located downgradient of MW-ZN-01S and in surface water sample collected from Lake Michigan, which is the ultimate receptor of groundwater discharge from the Station. There is no indica tion from the HIR investigation that tritium-impacted groundwater is mi grating off the Station property.
045 136 (22) Zi on St ati o n 37 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Tritium was not detected at concentrations ex ceeding the LLD of 200 pCi/L in the four temporary wells located downgradient of MW-ZN-01S and in surface water sample collected from Lake Michigan, which is the ultimate receptor of groundwater discharge from the Station. There is no indica tion from the HIR investigation that tritium-impacted groundwater is mi grating off the Station property.
045 136 (22) Zi on St ati o n 38 C ONESTOGA-R OVERS & A SSOCIATES Revision 1  
045 136 (22) Zi on St ati o n 38 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 7.0 EXPOSURE PATHWAY ASSESSMENT This section addresses the groundwater impact s from tritium and other radionuclides at the Station and potential risks to human health and the environment.
 
===7.0 EXPOSURE===
PATHWAY ASSESSMENT This section addresses the groundwater impact s from tritium and other radionuclides at the Station and potential risks to human health and the environment.
Based upon historical knowledge and data re lated to the Station operations, and based upon radionuclide analyses of groundwater sa mples, the primary constituent of concern (COC) is tritium. The discussions that follo w are restricted to the exposure pathways related to tritium.
Based upon historical knowledge and data re lated to the Station operations, and based upon radionuclide analyses of groundwater sa mples, the primary constituent of concern (COC) is tritium. The discussions that follo w are restricted to the exposure pathways related to tritium.
Teledyne Brown reports all samples to their statistically derived minimum detectable concentration (MDC) of approx imately 150 to 170 pCi/L, which is associated with 95 percent confidence interval on their hardcop y reports. However, the laboratory uses a 99 percent confidence range ( 3-sigma) for determining whether to report the sample activity concentration as detected or not.
Teledyne Brown reports all samples to their statistically derived minimum detectable concentration (MDC) of approx imately 150 to 170 pCi/L, which is associated with 95 percent confidence interval on their hardcop y reports. However, the laboratory uses a 99 percent confidence range ( 3-sigma) for determining whether to report the sample activity concentration as detected or not.
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135.75) pCi/L.
135.75) pCi/L.
Ex elon has specified a LLD of 200 pCi/L for the Fleetwide assessment. Ex elon has also required the laboratory to report related pe aks identified at the 95 percent confidence level (2-sigma).
Ex elon has specified a LLD of 200 pCi/L for the Fleetwide assessment. Ex elon has also required the laboratory to report related pe aks identified at the 95 percent confidence level (2-sigma).
This HIR, therefore, screens and assesses data using Ex elon's LLD of 200 pCi/L. As is outlined below, this concentration is also a reasonable approx imation of the background concentration of tritium in groundwater at the Station.  
This HIR, therefore, screens and assesses data using Ex elon's LLD of 200 pCi/L. As is outlined below, this concentration is also a reasonable approx imation of the background concentration of tritium in groundwater at the Station.
 
7.1 HEALTH EFFECTS OF TRITIUM Tritium is a radionuclide that decays by emi tting a low-energy beta particle that cannot penetrate deeply into tissue or travel far in air. A person's exposure to tritium is primarily through the ingestion of water (d rinking water) or through ingestion of water-bearing food products. Inhalation of tr itium req u ires the water to be in a vapor form (i.e., through evaporation or vaporizatio n due to heating). Inhalation is a minor exposure route when compared to direct in gestion or drinking of tritiated water.
===7.1 HEALTH===
EFFECTS OF TRITIUM Tritium is a radionuclide that decays by emi tting a low-energy beta particle that cannot penetrate deeply into tissue or travel far in air. A person's exposure to tritium is primarily through the ingestion of water (d rinking water) or through ingestion of water-bearing food products. Inhalation of tr itium req u ires the water to be in a vapor form (i.e., through evaporation or vaporizatio n due to heating). Inhalation is a minor exposure route when compared to direct in gestion or drinking of tritiated water.
Absorption of tritium through skin is possible, but tritium exposure is more limited here versus direct ingestion or drinking of tritiated water.
Absorption of tritium through skin is possible, but tritium exposure is more limited here versus direct ingestion or drinking of tritiated water.
045 136 (22) Zi on St ati o n 39 C ONESTOGA-R OVERS & A SSOCIATES Revision 1  
045 136 (22) Zi on St ati o n 39 C ONESTOGA-R OVERS & A SSOCIATES Revision 1  
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The RadNet database for several stations in the U.S. Midwest (Chicago, Columbus, Indianapolis, Lansing, Madison, Minneapolis , Painesville, Toledo, and Welsch) did not show the same trend, which can be attrib uted to pre-1995 data handling procedures.
The RadNet database for several stations in the U.S. Midwest (Chicago, Columbus, Indianapolis, Lansing, Madison, Minneapolis , Painesville, Toledo, and Welsch) did not show the same trend, which can be attrib uted to pre-1995 data handling procedures.
The pre-1995 data were rounded to the nearest 100 pCi/L, which dampened out variances in the data. The post-1995 RadNet data, where rounding was not applied, exhibit much more scatter, and similar to th e GNIP data, the vast majority of the data were less than 100 pCi/L.
The pre-1995 data were rounded to the nearest 100 pCi/L, which dampened out variances in the data. The post-1995 RadNet data, where rounding was not applied, exhibit much more scatter, and similar to th e GNIP data, the vast majority of the data were less than 100 pCi/L.
CRA constructed a non-parametric upper toler ance limit with a confidence of 95 percent and coverage of 95 percent based on RadN et data for USEPA Region 5 from 2004 to 2005. The resulting upper tolerance limit is 133 pCi/L, which indicates that CRA is 95 percent confident that 95 percent of the ambient precipitation concentration results are below 133 pCi/L. The statistical confidence, however, must be compared with the limitations of the underlying RadNet da ta, which does not include the minimum detectable concentration for a majority of th e measurements. Some of the RadNet values below 200 pCi/L may be approx imated. Nevertheless, these results show a background contribution for precipitation of up to 133 pCi/L.  
CRA constructed a non-parametric upper toler ance limit with a confidence of 95 percent and coverage of 95 percent based on RadN et data for USEPA Region 5 from 2004 to 2005. The resulting upper tolerance limit is 133 pCi/L, which indicates that CRA is 95 percent confident that 95 percent of the ambient precipitation concentration results are below 133 pCi/L. The statistical confidence, however, must be compared with the limitations of the underlying RadNet da ta, which does not include the minimum detectable concentration for a majority of th e measurements. Some of the RadNet values below 200 pCi/L may be approx imated. Nevertheless, these results show a background contribution for precipitation of up to 133 pCi/L.
 
7.2.3 SURFACE WATER D A TA Tritium concentrations are routinely measured in large surface water bodies, including Lake Michigan and the Mississippi River. Surf ace water data from the RadNet database for Illinois sampling stations include East Moline (Mississippi River), Moline (Mississippi River), Marseilles (Illinois Rive r), Morris (Illinois River), Oregon (Rock River), and Zion (Lake Michigan). As is the case for the RadNet precipitation data, the pre-September 1995 Illinois surface water data was rounded to the nearest 100 pCi/L, creating a dampening of variances in the da ta. The post-1995 Illinois surface water data, similar to the post-1995 Midwest precipitation data, were less than 100 pCi/L, with the exception of the Moline (Mississippi Rive r) station. Tritium surface water concentrations at this location varied between 100 and 800 pCi/L, which may reflect local natural or anthropogenic inputs.
====7.2.3 SURFACE====
WATER D A TA Tritium concentrations are routinely measured in large surface water bodies, including Lake Michigan and the Mississippi River. Surf ace water data from the RadNet database for Illinois sampling stations include East Moline (Mississippi River), Moline (Mississippi River), Marseilles (Illinois Rive r), Morris (Illinois River), Oregon (Rock River), and Zion (Lake Michigan). As is the case for the RadNet precipitation data, the pre-September 1995 Illinois surface water data was rounded to the nearest 100 pCi/L, creating a dampening of variances in the da ta. The post-1995 Illinois surface water data, similar to the post-1995 Midwest precipitation data, were less than 100 pCi/L, with the exception of the Moline (Mississippi Rive r) station. Tritium surface water concentrations at this location varied between 100 and 800 pCi/L, which may reflect local natural or anthropogenic inputs.
The RadNet surface water data typically has a reported 'Combined Standard Uncertainty' of 35 to 50 pCi/L. According to USEPA, this corresponds to a  
The RadNet surface water data typically has a reported 'Combined Standard Uncertainty' of 35 to 50 pCi/L. According to USEPA, this corresponds to a  
+/- 70 to 100 pCi/L 95 percent confidence bound on each given measurement.
+/- 70 to 100 pCi/L 95 percent confidence bound on each given measurement.
Therefore,    045 136 (22) Zi on St ati o n 41 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 the typical background data provided may be subject to measurement uncertainty of approx imately +/- 70 to 100 pCi/L.  
Therefore,    045 136 (22) Zi on St ati o n 41 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 the typical background data provided may be subject to measurement uncertainty of approx imately +/- 70 to 100 pCi/L.
 
7.2.4 DRINKING WATER DATA Tritium concentrations in drinking water fr om the RadNet database for three Illinois sampling stations (Chicago, Morris, and East Chicago) ex hibit similar trends as the precipitation and surface water data. As wi th the precipitation and surface water data, the pre-1995 data have dampened out variances due to rounding the data to the nearest 100 pCi/L. The post-1995 results show tritiu m concentrations in samples of drinking water were less than 100 pCi/L.
====7.2.4 DRINKING====
7.2.5 EXPECTED TRITIUM BACKGROUND FOR THE STATION As reported in the GNIP and RadNet database s, tritium concentrations in U.S.
WATER DATA Tritium concentrations in drinking water fr om the RadNet database for three Illinois sampling stations (Chicago, Morris, and East Chicago) ex hibit similar trends as the precipitation and surface water data. As wi th the precipitation and surface water data, the pre-1995 data have dampened out variances due to rounding the data to the nearest 100 pCi/L. The post-1995 results show tritiu m concentrations in samples of drinking water were less than 100 pCi/L.  
Midwest precipitation have typically been less than 100 pCi/L since 1980. Tritium concentrations reported in the RadNet database for Illinoi s surface water and groundwater, at least since 1995, have typically been less than 100 pC i/L. Based on USEPA Region 5's 2004 to 2005 RadNet precipitation data, 95 percent of the ambient concentrations of tritiated water in Illinois are expected to be less than 133 pCi/L, based on a 95 percent confidence limit. Tritium concentrations in surface wa ter and drinking water at the Station are expected to be comparable or less ba sed on historical data and trends.
 
====7.2.5 EXPECTED====
TRITIUM BACKGROUND FOR THE STATION As reported in the GNIP and RadNet database s, tritium concentrations in U.S.
Midwest precipitation have typically been less than 100 pCi/L since 1980. Tritium concentrations reported in the RadNet database for Illinoi s surface water and groundwater, at least since 1995, have typically been less than 100 pC i/L. Based on USEPA Region 5's 2004 to 2005 RadNet precipitation data, 95 percent of the ambient concentrations of tritiated water in Illinois are expected to be less than 133 pCi/L, based on a 95 percent confidence limit. Tritium concentrations in surface wa ter and drinking water at the Station are expected to be comparable or less ba sed on historical data and trends.
Concentrations in groundwater similar to su rface water and drinking water are ex pected to be less than precipitation values. The lo wer groundwater concentrations are related to the age of the groundwater as compared to the half-life of tritium. Deep aquifers in proximity to crystalline basement rock, ho wever, can potentially show elevated concentrations of tritium due to lithogenic sources.
Concentrations in groundwater similar to su rface water and drinking water are ex pected to be less than precipitation values. The lo wer groundwater concentrations are related to the age of the groundwater as compared to the half-life of tritium. Deep aquifers in proximity to crystalline basement rock, ho wever, can potentially show elevated concentrations of tritium due to lithogenic sources.
The Pre-Operational REMP report noted that lake water was sampled at five public water intakes. Generally, the gross beta radioactivity of Lake Michigan was less than 10 pCi/L. Typical values from throughout th e Lake were between 3 to 6 pCi/L. Gross alpha radioactivity was typically less than 3 pCi/L (ComEd, 1971).
The Pre-Operational REMP report noted that lake water was sampled at five public water intakes. Generally, the gross beta radioactivity of Lake Michigan was less than 10 pCi/L. Typical values from throughout th e Lake were between 3 to 6 pCi/L. Gross alpha radioactivity was typically less than 3 pCi/L (ComEd, 1971).
Tritium levels in Lake Michigan water were st udied in the vicinity of Zion throughout 1970 (prior to the construction of the Statio n). The concentration of tritium in Lake Michigan near Zion ranged from approx imately 311  20 pCi/L to 374  34 pCi/L and averaged 340 pCi/L. There was no statistica l difference in average tritium levels among 045 136 (22) Zi on St ati o n 42 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 the sample locations (eight sample locations from Kenosha to Waukegan) (ComEd, 1971).
Tritium levels in Lake Michigan water were st udied in the vicinity of Zion throughout 1970 (prior to the construction of the Statio n). The concentration of tritium in Lake Michigan near Zion ranged from approx imately 311  20 pCi/L to 374  34 pCi/L and averaged 340 pCi/L. There was no statistica l difference in average tritium levels among 045 136 (22) Zi on St ati o n 42 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 the sample locations (eight sample locations from Kenosha to Waukegan) (ComEd, 1971).
As was noted in Section 7.0, the reporting lim its for the tritium results are to an LLD of 200 pCi/L. This concentration also repr esents a reasonable representation of background groundwater quality, given the da ta for precipitation, surface water, and drinking water.
As was noted in Section 7.0, the reporting lim its for the tritium results are to an LLD of 200 pCi/L. This concentration also repr esents a reasonable representation of background groundwater quality, given the da ta for precipitation, surface water, and drinking water.
Based on the evaluation presented above, th e background concentration for tritium at the Station is reasonably represented by the LLD of 200 pCi/L.  
Based on the evaluation presented above, th e background concentration for tritium at the Station is reasonably represented by the LLD of 200 pCi/L.
 
7.3 IDENTIFICATION OF POTENTIAL EXPOSURE PATHWAYS AND POTENTIAL RECEPTORS There are two potential exposure pathways for tritium originating in or adjacent to the Station:  potential groundwater migration off the St ation property to private and public groundwater users; and potential groundwater migration off the Station property to Lake Michigan.
===7.3 IDENTIFICATION===
The following section provides an overview of each of these two potential exposure pathways for tritium in groundwater.
OF POTENTIAL EXPOSURE PATHWAYS AND POTENTIAL RECEPTORS There are two potential exposure pathways for tritium originating in or adjacent to the Station:  potential groundwater migration off the St ation property to private and public groundwater users; and potential groundwater migration off the Station property to Lake Michigan.
7.3.1 POTENTIAL GROUNDWATER MIGRATION TO DRINKING WATER USERS OFF THE STATION PROPERTY Based upon the groundwater and surface water data presented in this HIR, groundwater flow is to the east towards Lake Michigan. The horizontal ex tent of the elevated concentrations of tritium in th e direction of groundwater flow has been established, and is limited to the area arou nd MW-ZN-01S. Tritium was not detected in the four temporary well installed near the shoreline above the LLD of 200 pCi/L. The tritium concentrations in groundwater samp les collected from MW-ZN-01S ranged from less than LLD (most recently) to 586 +/- 141 pCi/L (lower interval), 220 +/- 123 pCi/L to 261 +/- 124 pCi/L (upper interval), which are si gnificantly less than the USEPA drinking water standard of 20,000 pCi/L. No tritium was detected above the LLD (200 pCi/L) in the other fourteen monitoring wells across the Station. In addition, there are no potable water supply wells downgradient of the Station or of monitoring well MW-ZN-01S.
The following section provides an overview of each of these two potential exposure pathways for tritium in groundwater.  
045 136 (22) Zi on St ati o n 43 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 The direction of groundwater flow is east towards Lake Michigan. Tritium was not detected at concentrations greater than the LLD (200 pCi/L) in the four temporary wells located downgradient of MW-ZN-01S. There is no potentially complete exposure pathway, and therefore there is no current ri sk of exposure associ ated with groundwater ingestion off the Station property.
 
7.3.2 POTENTIAL GROUNDWATER MIGRATION TO SURFACE WATER USERS Based upon the groundwater and surface water data presented in this HIR, groundwater flow is to the east towards Lake Michigan. The horizontal ex tent of the elevated concentrations of tritium is lim ited to the area around MW-ZN-01S.
====7.3.1 POTENTIAL====
GROUNDWATER MIGRATION TO DRINKING WATER USERS OFF THE STATION PROPERTY Based upon the groundwater and surface water data presented in this HIR, groundwater flow is to the east towards Lake Michigan. The horizontal ex tent of the elevated concentrations of tritium in th e direction of groundwater flow has been established, and is limited to the area arou nd MW-ZN-01S. Tritium was not detected in the four temporary well installed near the shoreline above the LLD of 200 pCi/L. The tritium concentrations in groundwater samp les collected from MW-ZN-01S ranged from less than LLD (most recently) to 586 +/- 141 pCi/L (lower interval), 220 +/- 123 pCi/L to 261 +/- 124 pCi/L (upper interval), which are si gnificantly less than the USEPA drinking water standard of 20,000 pCi/L. No tritium was detected above the LLD (200 pCi/L) in the other fourteen monitoring wells across the Station. In addition, there are no potable water supply wells downgradient of the Station or of monitoring well MW-ZN-01S.
045 136 (22) Zi on St ati o n 43 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 The direction of groundwater flow is east towards Lake Michigan. Tritium was not detected at concentrations greater than the LLD (200 pCi/L) in the four temporary wells located downgradient of MW-ZN-01S. There is no potentially complete exposure pathway, and therefore there is no current ri sk of exposure associ ated with groundwater ingestion off the Station property.  
 
====7.3.2 POTENTIAL====
GROUNDWATER MIGRATION TO SURFACE WATER USERS Based upon the groundwater and surface water data presented in this HIR, groundwater flow is to the east towards Lake Michigan. The horizontal ex tent of the elevated concentrations of tritium is lim ited to the area around MW-ZN-01S.
The tritium concentrations detected in grou ndwater samples collected from MW-ZN-01S ranged from less than LLD (200 pCi/L)  (most recently) to 586  
The tritium concentrations detected in grou ndwater samples collected from MW-ZN-01S ranged from less than LLD (200 pCi/L)  (most recently) to 586  
+/- 141 pCi/L (lower interval) and 220 +/- 123 pCi/L to 261 +/- 124 pCi/L (upper interval), which are significantly less than the USEPA drinking wa ter standard of 20,000 pCi/L. No tritium was detected above the LLD (200 pCi/L) in the other 14 monitoring wells across the Station. In addition, no tritium was de tected above the LLD (200 pCi/L) in the downgradient monitoring wells (MW-ZN-11S and TW-ZN-100 through TW-ZN-103) and the surface water sample collected from Lake Michigan at station SW-ZN-01, adjacent to the Station.
+/- 141 pCi/L (lower interval) and 220 +/- 123 pCi/L to 261 +/- 124 pCi/L (upper interval), which are significantly less than the USEPA drinking wa ter standard of 20,000 pCi/L. No tritium was detected above the LLD (200 pCi/L) in the other 14 monitoring wells across the Station. In addition, no tritium was de tected above the LLD (200 pCi/L) in the downgradient monitoring wells (MW-ZN-11S and TW-ZN-100 through TW-ZN-103) and the surface water sample collected from Lake Michigan at station SW-ZN-01, adjacent to the Station.
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045 136 (22) Zi on St ati o n 46 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Surface Water Quality Tritium was not detected in the surface wa ter sample at a concentration greater than the USEPA drinking water standard of 20,000 pCi/L. Tritium was not detected in the surface wa ter sample at a concentration greater than the LLD of 200 pCi/L. Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than thei r LLDs in the sample collected as part of this investigation. Strontium-89/90 was not detected at concentrations greater than the LLD of 2.0 pCi/L in the sample collected as part of this investigation.
045 136 (22) Zi on St ati o n 46 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Surface Water Quality Tritium was not detected in the surface wa ter sample at a concentration greater than the USEPA drinking water standard of 20,000 pCi/L. Tritium was not detected in the surface wa ter sample at a concentration greater than the LLD of 200 pCi/L. Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than thei r LLDs in the sample collected as part of this investigation. Strontium-89/90 was not detected at concentrations greater than the LLD of 2.0 pCi/L in the sample collected as part of this investigation.
AFE-Zion-1:  Main Complex Area, AFE-Zion
AFE-Zion-1:  Main Complex Area, AFE-Zion
-3:  Unit 2 (Northern) AST Area, and AFE-Zion-4:  Wastewater Treatment Plant Area Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than their respective LLDs in any of the groundwater samples collected from the moni toring wells in the vicinity of AFEs Zion-1, 3, and 4. Strontium-89/90 was not detected at concentrations greater than the LLD of 2.0 pCi/L in any of the groundwater samples collected from the monitoring wells in the vicinity of AFEs-Zion-1, 3, and 4. Tritium was detected in groundwater sa mples collected from monitoring well MW-ZN-01S. These concentrations ranged from less than LLD (most recently) to 586 +/- 141 pCi/L (lower interval) and 220 +/- 123 pCi/L to 261 +/- 124 pCi/L (upper interval). The tritium is localized to th e area in the vicinity of monitoring well MW-ZN-01S. No tritium was detected in the four temporary wells and MW-ZN-11S, located downgradient of monitoring well MW-ZN-01S. This well is located in close prox imity to AFEs Zion 1, 3, and  
-3:  Unit 2 (Northern) AST Area, and AFE-Zion-4:  Wastewater Treatment Plant Area Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than their respective LLDs in any of the groundwater samples collected from the moni toring wells in the vicinity of AFEs Zion-1, 3, and 4. Strontium-89/90 was not detected at concentrations greater than the LLD of 2.0 pCi/L in any of the groundwater samples collected from the monitoring wells in the vicinity of AFEs-Zion-1, 3, and 4. Tritium was detected in groundwater sa mples collected from monitoring well MW-ZN-01S. These concentrations ranged from less than LLD (most recently) to 586 +/- 141 pCi/L (lower interval) and 220 +/- 123 pCi/L to 261 +/- 124 pCi/L (upper interval). The tritium is localized to th e area in the vicinity of monitoring well MW-ZN-01S. No tritium was detected in the four temporary wells and MW-ZN-11S, located downgradient of monitoring well MW-ZN-01S. This well is located in close prox imity to AFEs Zion 1, 3, and
: 4. The so urce of tritium in this location is likely attributable to historical releases in this area. However, the most recent sample results are within the range of background concentrations.
: 4. The so urce of tritium in this location is likely attributable to historical releases in this area. However, the most recent sample results are within the range of background concentrations.
AFE-Zion-2:  Unit 1 (Southern) Ab oveground Storage Tank (AST) Area Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than their respective LLDs in any of the groundwater samples collected from the monitoring wells in the vicinity of AFE-Zion-2.
AFE-Zion-2:  Unit 1 (Southern) Ab oveground Storage Tank (AST) Area Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than their respective LLDs in any of the groundwater samples collected from the monitoring wells in the vicinity of AFE-Zion-2.
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Revision 0 045136 (22) Zion Station APPENDIX C QUALITY ASSURANCE PROGRAM - T ELEDYNE BROWN ENGINEERING, INC.   
Revision 0 045136 (22) Zion Station APPENDIX C QUALITY ASSURANCE PROGRAM - T ELEDYNE BROWN ENGINEERING, INC.   


Page 2 of 32 TABLE OF CONTENTS Section Title Page   
Page 2 of 32 TABLE OF CONTENTS Section Title Page 1.0 KNOXVILLE QAM SECTION INTRODUCTION 7 2.0 QUALITY SYSTEM 10 2.1 Policy 10 2.2 Quality System Structure 10 2.3 Quality System Objectives 10 2.4 Personnel Orientation, Training, and Qualification 11 3.0 ORGANIZATION, AUTHORITY, AND RESPONSIBILITY 12 4.0 PERSONNEL ORIENTATION, DATA INTEGRITY, TRAINING, AND QUALIFICATION 13 4.1 Orientation 13 4.2 Data Integrity 13 4.3 Training 13 4.4 Qualification 13 4.5 Records 13 5.0 CUSTOMER INTERFACES 14 5.1 Interface Personnel 14 5.2 Bid Requests and Tenders 14 5.3 Contracts 14 5.4 TBE's Expectation of Customers 14 5.5 Customer Satisfaction 15 5.5.1 Customer Complaints 15 5.5.2 Customer Confidentiality 15 6.0 DOCUMENTATION GENERATION AND CONTROL 16 6.1 General 16 6.2 New Documentation 16 6.3 Documentation Changes 16 Page 3 of 32 TABLE OF CONTENTS - Continued


===1.0 KNOXVILLE===
6.4 Documentation Lists and Distributions 16 6.5 Other Documentation 16 6.6 Documentation Reviews 16
QAM SECTION INTRODUCTION 7


===2.0 QUALITY===
7.0 DESIGN OF LABORATORY CONTROLS 17 7.1 General 17 7.2 Facility 17 7.3 Technical Processes and Methods 17 7.3.1 Operational Flow 17 7.3.2 Methods 18 7.3.3 Data Reduction and Analysis 18 7.4 Verification of Technical Processes, Methods, and Software 18  7.4.1 Operational Flow Verification 18  7.4.2 Method Verifications 18 7.4.3 Data Reduction and Analysis Verification 18 7.5 Design of Quality Controls 18  7.5.1 General 19 7.5.2 Demonstration of Capability  (D of C) 19 7.5.3 Process Control Checks 19 7.6 Counting Instrument Controls 20
SYSTEM 10


===2.1 Policy===
8.0 PURCHASING AND SUBCONTRACT CONTROLS 21 8.1 General 21 8.2 Source Selection 21 8.3 Procurement of Supplies and Support Services 21  8.3.1 Catalog Supplies 21 8.3.2 Support Services 21 8.3.3 Equipment and Software 22 8.4 Subcontracting of Analytical Services 22 8.5 Acceptance of Items or Services 22 Page 4 of 32  TABLE OF CONTENTS - Continued
10 2.2 Quality System Structure 10


===2.3 Quality===
9.0 TEST SAMPLE IDENTIFICATION AND CONTROL 23 9.1 Sample Identification 23 9.2 LIMS 23 9.3 Sample Control 23
System Objectives 10


===2.4 Personnel===
10.0 SPECIAL PROCESSES, INSPECTION, AND TEST 24 10.1 Special Processes 24 10.2 Inspections and Tests 24 10.2.1 Intra Laboratory Checks (QC Checks) 24 10.2.2 Inter Laboratory Checks 24 10.2.3 Data Reviews 24 10.3 Control of Sampling of Samples 24 10.4 Reference Standards / Material 24 10.4.1 Weights and Temperatures 25  10.4.2 Radioactive Materials 25 11.0 EQUIPMENT MAINTENANCE AND CALIBRATION 26 11.1 General 26 11.2 Support Equipment 26 11.3 Instruments 26 11.4 Nonconformances and Corrective Actions 26 11.5 Records 27
Orientation, Training, and Qualification 11 3.0 ORGANIZATION, AUTHORITY, AND RESPONSIBILITY 12


===4.0 PERSONNEL===
12.0 NONCONFORMANCE CONTROLS 28 12.1 General 28 12.2 Responsibility and Authority 28 12.3 10CFR21 Reporting 28
ORIENTATION, DATA INTEGRITY, TRAINING,  AND QUALIFICATION 13


===4.1 Orientation===
Page 5 of 32 TABLE OF CONTENTS - Continued
13 4.2 Data Integrity 13


===4.3 Training===
13.0 CORRECTIVE AND PREVENTIVE ACTIONS 29 13.1 General 29 13.2 Corrective Actions 29 13.3 Preventive Actions 29 14.0 RESULTS ANALYSIS AND REPORTING 30 14.1 General 30 14.2 Results Review 30 14.3 Reports 30
13


===4.4 Qualification===
15.0 RECORDS 31 15.1 General 31 15.2 Type of Records 31 15.3 Storage and Retention 31 15.4 Destruction or Disposal 31 16.0 ASSESSMENTS 32 16.1 General 32 16.2 Audits 32 16.3 Management Reviews 32
13


===4.5 Records===
Page 6 of 32 REVISION HISTORY
13


===5.0 CUSTOMER===
Revision 7 Complete re-write January 1, 2005 Bill Meyer
INTERFACES 14


===5.1 Interface===
Revision 8 Updated organization  chart, minor change to  1.0, 4.4, 7.5.3.2,  10.2.3, and 12.3 Page 7 of 32 1.0 Knoxville QAM Section Introduction This Quality Assurance Manual (QAM) and related Procedures describes the Knoxville Environmental Services Laboratory's QA system. This system is designed to meet multiple quality standards imposed by Customers and regulatory agencies including:
Personnel 14 5.2 Bid Requests and Tenders 14
NRC's 10 CFR 50 Appendix B NRC's Regulatory Guide 4.15


===5.3 Contracts===
DOE's Order 414.1
14


===5.4 TBE's===
DOE's QSAS
Expectation of Customers 14


===5.5 Customer===
ANSI N 42.23
Satisfaction 15


====5.5.1 Customer====
ANSI N 13.30
Complaints 15


====5.5.2 Customer====
NELAC Standard, Chapter 5  
Confidentiality 15


===6.0 DOCUMENTATION===
The Environmental Services (ES) Laboratory does low level radioactivity analyses for Power Plants and other customers. It primarily analyzes environmental samples (natural products from around plants such as milk), in-plant samples (air filters, waters), bioassay samples from customer's employees, and waste disposal samples (liquids and solids).  
GENERATION AND CONTROL 16


===6.1 General===
Potable and non-potable water sample s are tested using methods based on EPA standards as cited in State licenses (see Procedure 4010). The listing [current as of initial printing of this Manual - see current index for revision status and additions / deletions] of implementing Procedures (SOPs) covering Administration, Methods, Counting Instruments, Technical, Miscellaneous, and LIMS is shown in Table 1-1. Reference to these Procedures by number is made throughout this QAM.  
16 6.2 New Documentation 16


===6.3 Documentation===
Table 1-1 Number Title Part 1 Administrative Procedures 1001 Validation and Verification of Computer Programs for Radiochemistry Data Reduction 1002 Organization and Responsibility 1003 Control, Retention, and Disposal of Quality Assurance Records 1004 Definitions 1005 Data Integrity 1006 Job Descriptions 1007 Training and Certifications 1008 Procedure and Document Control 1009 Calibration System 1010 Nonconformance Controls 1011 10CFR21 Reporting 1012 Corrective Action and Preventive Action Page 8 of 32 Number Title 1013 Internal Audits and Management Reviews 1014 RFP, Contract Review, and Order Entry  (formerly 4001) 1015 Procurement Controls Part 2 Method Procedures 2001 Alpha Isotopic and Plutonium-241 2002 Carbon-14 Activity in Various Matrices 2003 Carbon-14 and Tritium in Soils, Solids, and Biological Samples; Harvey Oxidizer Method 2004 Cerium-141 and Cerium-144 by Radiochemical Separation 2005 Cesium-137 by Radiochemical Separation 2006 Iron-55 Activity in Various Matrices 2007 Gamma Emitting Radioisotope Analysis 2008 Gross Alpha and/or Gross Beta Activity in Various Matrices 2009 Gross Beta Minus Potassium-40 Activity in Urine and Fecal Samples 2010 Tritium and Carbon-14 Analysis by Liquid Scintillation 2011 Tritium Analysis in Drinking Water by Liquid Scintillation 2012 Radioiodine in Various Matrices 2013 Radionickel Activity in Various Matrices 2014 Phosphorus-32 Activity in Various Matrices 2015 Lead-210 Activity in Various Matrices 2016 Radium-226 Analysis in Various Matrices 2017 Total Radium in Water Samples 2018 Radiostrontium Analysis by Chemical Separation 2019 Radiostrontium Analysis by Ion Exchange 2020 Sulfur-35 Analysis 2021 Technetium-99 Analysis by Eichrom Resin Separation 2022 Total Uranium Analysis by KPA 2023 Compositing of Samples 2024 Dry Ashing of Environmental Samples 2025 Preparation and Standardization of Carrier Solutions 2026 Radioactive Reference Standard Solutions and Records 2027 Glassware Washing and Storage 2028 Moisture Content of Various Matrices 2029 Polonium-210 Activity in Various Matrices 2030 Promethium-147 Analysis Page 9 of 32  Number Title Part 3 Instrument Procedures 3001 Calibration and Control of Gamma-Ray Spectrometers 3002 Calibration of Alpha Spectrometers 3003 Calibration and Control of Alpha and Beta Counting Instruments 3004 Calibration and Control of Liquid Scintillation Counters 3005 Calibration and Operation of pH Meters 3006 Balance Calibration and Check 3008 Negative Results Evaluation Policy 3009 Use and Maintenance of Mechanical Pipettors 3010 Microwave Digestion System Use and Maintenance Part 4 Technical Procedures 4001 Not Used 4002 QC Checks on Data 4003 Sample Regent and Control 4004 Data Package Preparation and Reporting 4005 Blank, Spike, and Duplicate Controls 4006 Inter-Laboratory Comparison Study Process 4007 Method Basis and Initial Validation Process 4008 Not Used 4009 MDL Controls 4010 State Certification Process 4011 Accuracy, Precision, Efficiency, and Bias Controls and Data Quality Objectives 4012 Not Used 4013 Not Used 4014 Facility Operation and Control 4015 Documentation of Analytical Laboratory Logbooks  (formerly 1002) 4016 Total Propagated Uncertainty  (formerly 1004) 4017 LIMS Operation 4018 Instrument Calibration System 4019 Radioactive Reference Material Standards Part 5 Miscellaneous Procedures 5001 Laboratory Hood Operations 5002 Operation and Maintenance of Deionized Water System 5003 Waste Management 5004 Acid Neutralization and Purification System Operation Procedure Page 10 of 32 Part 6 LIMS 6001 LIMS Raw Data Processing and Reporting 6002 Software Development and/or Pilots of COTS Packages 6003 Software Change and Version Control 6004 Backup of Data and System Files 6005 Disaster Recovery Plan 6006 LIMS Hardware 6007 LIMS User Access 6008 LIMS Training 6009 LIMS Security 2.0 QUALITY SYSTEM The TBE-ES QA system is designed to comply with multiple customer- and regulatory agency-imposed specifications related to quality. This quality system applies to all activities of TBE-ES that affect the quality of analyses performed by the laboratory.
Changes 16 Page 3 of 32 TABLE OF CONTENTS - Continued
2.1 Policy The TBE quality policy, given in Company Policy P-501, is "TBE will continually improve our processes and effectiveness in providing products and services that exceed our customer's expectations."


===6.4 Documentation===
This policy is amplified by this Laboratory's commitment, as attested to by the title page signatures, to perform all work to good professional practices and to deliver high quality services to our customers with full data integrity.  (See Section 4.0 and Procedure 1005).
Lists and Distributions 16
2.2 Quality System Structure The Quality System is operated by the organizations described in Section 3.0 of this Manual. The Quality System is described in this Manual and in the Procedures Manual, both of which are maintained by the QA Manager. Procedures are divided into 6 sections - Administrative, Methods, Equipments, Technical, Miscellaneous, and LIMS. This Manual is structured as shown in the Table of Contents and refers to Procedures when applicable. Cross references to the various imposed quality specifications are contained in Appendices to this Manual.
2.3 Quality System Objectives The Quality System is established to meet the objective of assuring all operations are planned and executed in accordance with system requirements. The Quality System also assures that performance evaluations are performed (see Procedure 4006), and that appropriate verifications are performed (see Procedures in the 1000 and 4000 series) to further assure compliance. Verification includes Page 11 of 32 examination of final reports (prior to submittal to customers) to determine their quality (see Procedure 4004). 


===6.5 Other===
To further these objectives, various in-process assessments of data, as well as assessments of the system, via internal audits and management reviews, are performed. Both internal experts and customer / regulatory agencies perform further assessments of the system and compliance to requirements.
Documentation 16
2.4 Personnel Orientation, Tr aining, and Qualification TBE provides indoctrination and training to employees and performs proficiency evaluation of technical personnel.
This effort is described in Section 4.0.
Page 12 of 32 3.0 ORGANIZATION, AUTHORITY, AND RESPONSIBILITY TBE has established an effective organization for conducting laboratory analyses at the Knoxville Environmental Services Laboratory. The basic organization is shown in Figure 3-1. Detail organization charts with names, authorities, and responsibilities are given in Procedure 1002. Job descriptions are given in Procedure 1006.


===6.6 Documentation===
This organization provides clearly established Quality Assu rance authorities, duties, and functions. QA has t he organizational freedom needed to:
Reviews 16


===7.0 DESIGN===
(1) Identify problems (2) Stop nonconforming work (3) Initiate investigations (4) Recommend corrective and preventive actions (5) Provide solutions or recommend solutions (6) Verify implementation of actions
OF LABORATORY CONTROLS 17


===7.1 General===
All Laboratory personnel have the authority and resources to do their assigned duties and have the freedom to act on problems. The QA personnel have direct, independent access to Company management as shown in Figure 3-1.   
17 7.2 Facility 17
 
===7.3 Technical===
Processes and Methods 17
 
====7.3.1 Operational====
Flow 17
 
====7.3.2 Methods====
18 7.3.3 Data Reduction and Analysis 18
 
===7.4 Verification===
of Technical Processes, Methods, and Software 18  7.4.1 Operational Flow Verification 18  7.4.2 Method Verifications 18 7.4.3 Data Reduction and Analysis Verification 18 7.5 Design of Quality Controls 18  7.5.1 General 19
 
====7.5.2 Demonstration====
of Capability  (D of C) 19
 
====7.5.3 Process====
Control Checks 19
 
===7.6 Counting===
Instrument Controls 20
 
===8.0 PURCHASING===
AND SUBCONTRACT CONTROLS 21
 
===8.1 General===
21 8.2 Source Selection 21
 
===8.3 Procurement===
of Supplies and Support Services 21  8.3.1 Catalog Supplies 21
 
====8.3.2 Support====
Services 21
 
====8.3.3 Equipment====
and Software 22
 
===8.4 Subcontracting===
of Analytical Services 22
 
===8.5 Acceptance===
of Items or Services 22 Page 4 of 32  TABLE OF CONTENTS - Continued
 
9.0 TEST SAMPLE IDENTIFICATION AND CONTROL 23
 
===9.1 Sample===
Identification 23 9.2 LIMS 23
 
===9.3 Sample===
Control 23
 
10.0 SPECIAL PROCESSES, INSPECTION, AND TEST 24 10.1 Special Processes 24 10.2 Inspections and Tests 24 10.2.1 Intra Laboratory Checks (QC Checks) 24 10.2.2 Inter Laboratory Checks 24 10.2.3 Data Reviews 24 10.3 Control of Sampling of Samples 24 10.4 Reference Standards / Material 24 10.4.1 Weights and Temperatures 25  10.4.2 Radioactive Materials 25 11.0 EQUIPMENT MAINTENANCE AND CALIBRATION 26 11.1 General 26 11.2 Support Equipment 26 11.3 Instruments 26 11.4 Nonconformances and Corrective Actions 26 11.5 Records 27
 
12.0 NONCONFORMANCE CONTROLS 28 12.1 General 28 12.2 Responsibility and Authority 28 12.3 10CFR21 Reporting 28
 
Page 5 of 32 TABLE OF CONTENTS - Continued
 
13.0 CORRECTIVE AND PREVENTIVE ACTIONS 29 13.1 General 29 13.2 Corrective Actions 29 13.3 Preventive Actions 29 14.0 RESULTS ANALYSIS AND REPORTING 30 14.1 General 30 14.2 Results Review 30 14.3 Reports 30
 
15.0 RECORDS 31 15.1 General 31 15.2 Type of Records 31 15.3 Storage and Retention 31 15.4 Destruction or Disposal 31 16.0 ASSESSMENTS 32 16.1 General 32 16.2 Audits 32 16.3 Management Reviews 32
 
Page 6 of 32 REVISION HISTORY
 
Revision 7 Complete re-write January 1, 2005 Bill Meyer
 
Revision 8 Updated organization  chart, minor change to  1.0, 4.4, 7.5.3.2,  10.2.3, and 12.3 Page 7 of 32 1.0 Knoxville QAM Section Introduction This Quality Assurance Manual (QAM) and related Procedures describes the Knoxville Environmental Services Laboratory's QA system. This system is designed to meet multiple quality standards imposed by Customers and regulatory agencies including:
NRC's 10 CFR 50 Appendix B NRC's Regulatory Guide 4.15
 
DOE's Order 414.1
 
DOE's QSAS
 
ANSI N 42.23
 
ANSI N 13.30
 
NELAC Standard, Chapter 5
 
The Environmental Services (ES) Laboratory does low level radioactivity analyses for Power Plants and other customers. It primarily analyzes environmental samples (natural products from around plants such as milk), in-plant samples (air filters, waters), bioassay samples from customer's employees, and waste disposal samples (liquids and solids).
 
Potable and non-potable water sample s are tested using methods based on EPA standards as cited in State licenses (see Procedure 4010). The listing [current as of initial printing of this Manual - see current index for revision status and additions / deletions] of implementing Procedures (SOPs) covering Administration, Methods, Counting Instruments, Technical, Miscellaneous, and LIMS is shown in Table 1-1. Reference to these Procedures by number is made throughout this QAM.
 
Table 1-1 Number Title Part 1 Administrative Procedures 1001 Validation and Verification of Computer Programs for Radiochemistry Data Reduction 1002 Organization and Responsibility 1003 Control, Retention, and Disposal of Quality Assurance Records 1004 Definitions 1005 Data Integrity 1006 Job Descriptions 1007 Training and Certifications 1008 Procedure and Document Control 1009 Calibration System 1010 Nonconformance Controls 1011 10CFR21 Reporting 1012 Corrective Action and Preventive Action Page 8 of 32 Number Title 1013 Internal Audits and Management Reviews 1014 RFP, Contract Review, and Order Entry  (formerly 4001) 1015 Procurement Controls Part 2 Method Procedures 2001 Alpha Isotopic and Plutonium-241 2002 Carbon-14 Activity in Various Matrices 2003 Carbon-14 and Tritium in Soils, Solids, and Biological Samples; Harvey Oxidizer Method 2004 Cerium-141 and Cerium-144 by Radiochemical Separation 2005 Cesium-137 by Radiochemical Separation 2006 Iron-55 Activity in Various Matrices 2007 Gamma Emitting Radioisotope Analysis 2008 Gross Alpha and/or Gross Beta Activity in Various Matrices 2009 Gross Beta Minus Potassium-40 Activity in Urine and Fecal Samples 2010 Tritium and Carbon-14 Analysis by Liquid Scintillation 2011 Tritium Analysis in Drinking Water by Liquid Scintillation 2012 Radioiodine in Various Matrices 2013 Radionickel Activity in Various Matrices 2014 Phosphorus-32 Activity in Various Matrices 2015 Lead-210 Activity in Various Matrices 2016 Radium-226 Analysis in Various Matrices 2017 Total Radium in Water Samples 2018 Radiostrontium Analysis by Chemical Separation 2019 Radiostrontium Analysis by Ion Exchange 2020 Sulfur-35 Analysis 2021 Technetium-99 Analysis by Eichrom Resin Separation 2022 Total Uranium Analysis by KPA 2023 Compositing of Samples 2024 Dry Ashing of Environmental Samples 2025 Preparation and Standardization of Carrier Solutions 2026 Radioactive Reference Standard Solutions and Records 2027 Glassware Washing and Storage 2028 Moisture Content of Various Matrices 2029 Polonium-210 Activity in Various Matrices 2030 Promethium-147 Analysis Page 9 of 32  Number Title Part 3 Instrument Procedures 3001 Calibration and Control of Gamma-Ray Spectrometers 3002 Calibration of Alpha Spectrometers 3003 Calibration and Control of Alpha and Beta Counting Instruments 3004 Calibration and Control of Liquid Scintillation Counters 3005 Calibration and Operation of pH Meters 3006 Balance Calibration and Check 3008 Negative Results Evaluation Policy 3009 Use and Maintenance of Mechanical Pipettors 3010 Microwave Digestion System Use and Maintenance Part 4 Technical Procedures 4001 Not Used 4002 QC Checks on Data 4003 Sample Regent and Control 4004 Data Package Preparation and Reporting 4005 Blank, Spike, and Duplicate Controls 4006 Inter-Laboratory Comparison Study Process 4007 Method Basis and Initial Validation Process 4008 Not Used 4009 MDL Controls 4010 State Certification Process 4011 Accuracy, Precision, Efficiency, and Bias Controls and Data Quality Objectives 4012 Not Used 4013 Not Used 4014 Facility Operation and Control 4015 Documentation of Analytical Laboratory Logbooks  (formerly 1002) 4016 Total Propagated Uncertainty  (formerly 1004) 4017 LIMS Operation 4018 Instrument Calibration System 4019 Radioactive Reference Material Standards Part 5 Miscellaneous Procedures 5001 Laboratory Hood Operations 5002 Operation and Maintenance of Deionized Water System 5003 Waste Management 5004 Acid Neutralization and Purification System Operation Procedure Page 10 of 32 Part 6 LIMS 6001 LIMS Raw Data Processing and Reporting 6002 Software Development and/or Pilots of COTS Packages 6003 Software Change and Version Control 6004 Backup of Data and System Files 6005 Disaster Recovery Plan 6006 LIMS Hardware 6007 LIMS User Access 6008 LIMS Training 6009 LIMS Security
 
===2.0 QUALITY===
SYSTEM The TBE-ES QA system is designed to comply with multiple customer- and regulatory agency-imposed specifications related to quality. This quality system applies to all activities of TBE-ES that affect the quality of analyses performed by the laboratory.
 
===2.1 Policy===
The TBE quality policy, given in Company Policy P-501, is "TBE will continually improve our processes and effectiveness in providing products and services that exceed our customer's expectations."
 
This policy is amplified by this Laboratory's commitment, as attested to by the title page signatures, to perform all work to good professional practices and to deliver high quality services to our customers with full data integrity.  (See Section 4.0 and Procedure 1005).
 
===2.2 Quality===
System Structure The Quality System is operated by the organizations described in Section 3.0 of this Manual. The Quality System is described in this Manual and in the Procedures Manual, both of which are maintained by the QA Manager. Procedures are divided into 6 sections - Administrative, Methods, Equipments, Technical, Miscellaneous, and LIMS. This Manual is structured as shown in the Table of Contents and refers to Procedures when applicable. Cross references to the various imposed quality specifications are contained in Appendices to this Manual.
 
===2.3 Quality===
System Objectives The Quality System is established to meet the objective of assuring all operations are planned and executed in accordance with system requirements. The Quality System also assures that performance evaluations are performed (see Procedure 4006), and that appropriate verifications are performed (see Procedures in the 1000 and 4000 series) to further assure compliance. Verification includes Page 11 of 32 examination of final reports (prior to submittal to customers) to determine their quality (see Procedure 4004). 
 
To further these objectives, various in-process assessments of data, as well as assessments of the system, via internal audits and management reviews, are performed. Both internal experts and customer / regulatory agencies perform further assessments of the system and compliance to requirements.
 
===2.4 Personnel===
Orientation, Tr aining, and Qualification TBE provides indoctrination and training to employees and performs proficiency evaluation of technical personnel.
This effort is described in Section 4.0.
Page 12 of 32 3.0 ORGANIZATION, AUTHORITY, AND RESPONSIBILITY TBE has established an effective organization for conducting laboratory analyses at the Knoxville Environmental Services Laboratory. The basic organization is shown in Figure 3-1. Detail organization charts with names, authorities, and responsibilities are given in Procedure 1002. Job descriptions are given in Procedure 1006.
 
This organization provides clearly established Quality Assu rance authorities, duties, and functions. QA has t he organizational freedom needed to:
 
(1) Identify problems (2) Stop nonconforming work (3) Initiate investigations (4) Recommend corrective and preventive actions (5) Provide solutions or recommend solutions (6) Verify implementation of actions
 
All Laboratory personnel have the authority and resources to do their assigned duties and have the freedom to act on problems. The QA personnel have direct, independent access to Company management as shown in Figure 3-1.   


Figure 3.1. Laboratory Organization President VP A dministration & Q A VP Environmental Product Assurance Director Lab QA Manager Lab Operations Mana g er Program Mana g ers Lab SupervisorAdministration Staff Page 13 of 32 4.0 PERSONNEL ORIENTATION, DATA INTEGRITY, TRAINING, AND  QUALIFICATION  
Figure 3.1. Laboratory Organization President VP A dministration & Q A VP Environmental Product Assurance Director Lab QA Manager Lab Operations Mana g er Program Mana g ers Lab SupervisorAdministration Staff Page 13 of 32 4.0 PERSONNEL ORIENTATION, DATA INTEGRITY, TRAINING, AND  QUALIFICATION  


===4.1 Orientation===
4.1 Orientation All laboratory personnel must receive orientation to the quality program if their work can affect quality. Orientation includes a brief review of customer- and regulatory agency-imposed quality requirements, the structure of the QAM, and the implementing procedures. The goal of orientation is to cover the nature and goals of the QA program.
All laboratory personnel must receive orientation to the quality program if their work can affect quality. Orientation includes a brief review of customer- and regulatory agency-imposed quality requirements, the structure of the QAM, and the implementing procedures. The goal of orientation is to cover the nature and goals of the QA program.
4.2 Data Integrity The primary output of the Laboratory is data. Special emphasis and training in data integrity is given to all personnel whose work provides or supports data delivery. The Laboratory Data Integrity Procedure (Procedure 1005) describes training, personnel attestations, and monitoring operations. Annual reviews are required.
4.2 Data Integrity The primary output of the Laboratory is data. Special emphasis and training in data integrity is given to all personnel whose work provides or supports data delivery. The Laboratory Data Integrity Procedure (Procedure 1005) describes training, personnel attestations, and monitoring operations. Annual reviews are required.  
4.3 Training The Quality Assurance Manager (QAM) maintains a training matrix indicating which laboratory personnel need training in which specific Procedures. This matrix is updated when personnel change or change assignments. All personnel are trained per these requirements and procedures. This training program is described in Procedure 1007. The assi gned responsibilities for employees are described in Procedure 1002 (See Section 3.0) on Organization and in Procedure 1006, Job Descriptions. Refresher training or re-tra ining is given annually as appropriate.
 
4.4 Qualification Personnel are qualified as required by their job description. Management and non-analysts are evaluated based on past experience, education, and management's assessment of their capabilities. Formal qualification is required of analysts and related technical personnel who perform laboratory functions. Each applicable person is given training and then formally evaluated by the Operations Manager (or his designees) and by QA. Each analyst must initially demonstrate capability to perform each assigned analytical effort. Each year, thereafter, he or she must perform similar analyses on Interlab Comparison Samples (see Procedure 4006) or on equivalent blanks and spikes samples. Acceptable results extend qualifications (certification). Unacceptable results require retraining in the subject method / Procedures.  (See Procedure 1007 for added information, records, forms, etc. used.)
===4.3 Training===
4.5 Records Records of training subjects, contents, attendees, instructors, and certifications are maintained by QA.
The Quality Assurance Manager (QAM) maintains a training matrix indicating which laboratory personnel need training in which specific Procedures. This matrix is updated when personnel change or change assignments. All personnel are trained per these requirements and procedures. This training program is described in Procedure 1007. The assi gned responsibilities for employees are described in Procedure 1002 (See Section 3.0) on Organization and in Procedure 1006, Job Descriptions. Refresher training or re-tra ining is given annually as appropriate.  
 
===4.4 Qualification===
Personnel are qualified as required by their job description. Management and non-analysts are evaluated based on past experience, education, and management's assessment of their capabilities. Formal qualification is required of analysts and related technical personnel who perform laboratory functions. Each applicable person is given training and then formally evaluated by the Operations Manager (or his designees) and by QA. Each analyst must initially demonstrate capability to perform each assigned analytical effort. Each year, thereafter, he or she must perform similar analyses on Interlab Comparison Samples (see Procedure 4006) or on equivalent blanks and spikes samples. Acceptable results extend qualifications (certification). Unacceptable results require retraining in the subject method / Procedures.  (See Procedure 1007 for added information, records, forms, etc. used.)  
 
===4.5 Records===
Records of training subjects, contents, attendees, instructors, and certifications are maintained by QA.
Page 14 of 32 5.0 CUSTOMER INTERFACES
Page 14 of 32 5.0 CUSTOMER INTERFACES


===5.1 Interface===
5.1 Interface Personnel The Laboratory has designated Program Managers as the primary interface with all customers. Other interfaces may be the QA Manager or the Lab Operations Manager.
Personnel The Laboratory has designated Program Managers as the primary interface with all customers. Other interfaces may be the QA Manager or the Lab Operations Manager.
5.2 Bid Requests and Tenders The Program Managers respond to customer requests for bids and proposals per Procedure 1014 for bids, proposals, and contract reviews. They clarify customer requests so both the customer and the lab staff understand requests. As responses are developed, internal reviews are conducted to ensure that requirements are adequately defined and documented and to verify that the Laboratory has adequate resources in physical capabilities, personal skills, and technical information to perform the work. Accreditation needs are reviewed. If subcontracts are required to perform any analysis, the subcontractor is similarly evaluated and the client notified in writing of the effort. Most qualifications are routi ne with standard pricing and the review of these quotes is performed by the Program Manager. Larger or more complex quotes are reviewed by the Operations Manager and the QA Manager (or designees). Evidence of review is by initialing and dating applicable papers, signatures on quotations, or by memo.
5.2 Bid Requests and Tenders The Program Managers respond to customer requests for bids and proposals per Procedure 1014 for bids, proposals, and contract reviews. They clarify customer requests so both the customer and the lab staff understand requests. As responses are developed, internal reviews are conducted to ensure that requirements are adequately defined and documented and to verify that the Laboratory has adequate resources in physical capabilities, personal skills, and technical information to perform the work. Accreditation needs are reviewed. If subcontracts are required to perform any analysis, the subcontractor is similarly evaluated and the client notified in writing of the effort. Most qualifications are routi ne with standard pricing and the review of these quotes is performed by the Program Manager. Larger or more complex quotes are reviewed by the Operations Manager and the QA Manager (or designees). Evidence of review is by initialing and dating applicable papers, signatures on quotations, or by memo.  
5.3 Contracts The Program Manager's receive contract awards (oral or written) and generate the work planning for initiation pr eparation (charge numbers, data structure or contents in LIMS, etc.). They review contracts for possible differences from quotations and, if acceptable, contracts are processed. Do cumentation of the review is by initials and date as a minimum. Contract changes receive similar reviews and planning.
 
5.4 TBE's Expectation of Customers TBE expects customers to provide samples suitable for lab analysis. These expectations include:  
===5.3 Contracts===
The Program Manager's receive contract awards (oral or written) and generate the work planning for initiation pr eparation (charge numbers, data structure or contents in LIMS, etc.). They review contracts for possible differences from quotations and, if acceptable, contracts are processed. Do cumentation of the review is by initials and date as a minimum. Contract changes receive similar reviews and planning.  
 
===5.4 TBE's===
Expectation of Customers TBE expects customers to provide samples suitable for lab analysis. These expectations include:  


Accurate and unambiguous identification of samples Proper collection and preservation of samples Use of appropriate containers free from external and internal contamination Integrity preservation during shipment and timely delivery of samples that are age sensitive Adequate sized samples that allow for retest, if needed Specification of unique MOA/MDC requirements Alerting the lab about abnormal samples (high activity, different chemical contents, etc.) Chain of custody init iation, when required.
Accurate and unambiguous identification of samples Proper collection and preservation of samples Use of appropriate containers free from external and internal contamination Integrity preservation during shipment and timely delivery of samples that are age sensitive Adequate sized samples that allow for retest, if needed Specification of unique MOA/MDC requirements Alerting the lab about abnormal samples (high activity, different chemical contents, etc.) Chain of custody init iation, when required.
Page 15 of 32  5.5 Customer Satisfaction TBE's quality policy centers on customer satisfaction (See 2.0). TBE will work to satisfy customers through full compliance with contract requirements, providing accurate data and properly responding to any questions or complaints.
Page 15 of 32  5.5 Customer Satisfaction TBE's quality policy centers on customer satisfaction (See 2.0). TBE will work to satisfy customers through full compliance with contract requirements, providing accurate data and properly responding to any questions or complaints.
Customers are provided full cooperation in their monitoring of Laboratory performance. Customers are notified if any applicable State Accreditation is withdrawn, revoked, or suspended.  
Customers are provided full cooperation in their monitoring of Laboratory performance. Customers are notified if any applicable State Accreditation is withdrawn, revoked, or suspended.
 
5.5.1 Customer Complaints Any customer complaints are documented and tracked to closure. Most complaints concern analysis data and are received by Program Managers. They log each such complaint, order retests for verification, and provide documented results to customers. Co mplaints may also be received by QA or Operations.  
====5.5.1 Customer====
Complaints Any customer complaints are documented and tracked to closure. Most complaints concern analysis data and are received by Program Managers. They log each such complaint, order retests for verification, and provide documented results to customers. Co mplaints may also be received by QA or Operations.  


If complaints are other than re-test type, the nonconformance and corrective action systems (Sections 12 and 13) are used to resolve them and record all actions taken. 5.5.2 Customer Confidentiality All laboratory personnel maintain confidentiality of customer-unique information.
If complaints are other than re-test type, the nonconformance and corrective action systems (Sections 12 and 13) are used to resolve them and record all actions taken. 5.5.2 Customer Confidentiality All laboratory personnel maintain confidentiality of customer-unique information.
Page 16 of 32 6.0 DOCUMENTATION GENERATION & CONTROL  
Page 16 of 32 6.0 DOCUMENTATION GENERATION & CONTROL  


===6.1 General===
6.1 General The documentation generation and control system is detailed in Procedure 1008. An overview is given below. The basic quality system documents are described in Section 2.0.
The documentation generation and control system is detailed in Procedure 1008. An overview is given below. The basic quality system documents are described in Section 2.0.
6.2 New Documentation Each Procedure and this QAM is written by appropriate personnel, validated if applicable (see Section 7.0), reviewed for adequacy, completeness, and correctness, and, if acceptable, accepted by the authorized approver [QA Manager, Operations Manager (or their designee)]. Both approvals are required if a Procedure affects both QA and Operations.  (See Responsibilities in Section 3.0). These procedures control the quality m easurements and their accuracy.  
6.2 New Documentation Each Procedure and this QAM is written by appropriate personnel, validated if applicable (see Section 7.0), reviewed for adequacy, completeness, and correctness, and, if acceptable, accepted by the authorized approver [QA Manager, Operations Manager (or their designee)]. Both approvals are required if a Procedure affects both QA and Operations.  (See Responsibilities in Section 3.0). These procedures control the quality m easurements and their accuracy.  


Each document carries a unique identification number, a revision level, dates, page numbers and total page count, and approver identification and sign off. If TBE writes code for software, the software is version identified and issued after Verification and Valida tion per Section 7.0.  
Each document carries a unique identification number, a revision level, dates, page numbers and total page count, and approver identification and sign off. If TBE writes code for software, the software is version identified and issued after Verification and Valida tion per Section 7.0.
 
6.3 Documentation Changes Each change is reviewed in the same manner and by the same people as new documentation. Revision identifications are updated and changes indicated by side bars, italicized words, or by revision description when practical. Obsolete revisions are maintained by QA after being identified as obsolete.
===6.3 Documentation===
6.4 Documentation Lists and Distributions Computer indexes of documents are maintained by Quality showing the current authorized revision level of each document. These revisions are placed on the Laboratory server and obsolete ones are removed so that all personnel have only the current documents. If hard copies are produced and distributed, separate distribution lists are maintained indicating who has them and their revision level(s). Copies downloaded off the server are uncontrolled unless verified by the user (on the computer) to be the latest revision.
Changes Each change is reviewed in the same manner and by the same people as new documentation. Revision identifications are updated and changes indicated by side bars, italicized words, or by revision description when practical. Obsolete revisions are maintained by QA after being identified as obsolete.  
6.5 Other Documentation In addition to TBE-generated documentation, QA maintains copies of applicable specifications, regul ations, and standard methods.
 
6.6 Documentation Reviews Each issued document is reviewed at least every third year by the approving personnel. This review determines continued suitability for use and compliance with requirements.
===6.4 Documentation===
Lists and Distributions Computer indexes of documents are maintained by Quality showing the current authorized revision level of each document. These revisions are placed on the Laboratory server and obsolete ones are removed so that all personnel have only the current documents. If hard copies are produced and distributed, separate distribution lists are maintained indicating who has them and their revision level(s). Copies downloaded off the server are uncontrolled unless verified by the user (on the computer) to be the latest revision.  
 
===6.5 Other===
Documentation In addition to TBE-generated documentation, QA maintains copies of applicable specifications, regul ations, and standard methods.  
 
===6.6 Documentation===
Reviews Each issued document is reviewed at least every third year by the approving personnel. This review determines continued suitability for use and compliance with requirements.
Page 17 of 32 7.0 DESIGN OF LABORATORY CONTROLS  
Page 17 of 32 7.0 DESIGN OF LABORATORY CONTROLS  


===7.1 General===
7.1 General The Laboratory and its operating procedures are designed specifically for low level (environmental and in-plant) radioactive sample analysis. The various aspects of the laboratory design include the following which are discussed in subsequent paragraphs of this Section:  
The Laboratory and its operating procedures are designed specifically for low level (environmental and in-plant) radioactive sample analysis. The various aspects of the laboratory design include the following which are discussed in subsequent paragraphs of this Section:  


(a) Facility (b) Technical Processes and Methods (c) Verification of Design of Pr ocesses, Methods, and Software. (d) Design of Quality Controls (e) Counting Instrument Controls  
(a) Facility (b) Technical Processes and Methods (c) Verification of Design of Pr ocesses, Methods, and Software. (d) Design of Quality Controls (e) Counting Instrument Controls 7.2 Facility The facility was designed and built in 2000 to facilitate correct performance of operations in accordance with good laboratory practices and regulatory requirements. It provides security for operations and samples. It separates sample storage areas based on activity levels, separates wet chemistry from counting instrumentation for contamination control, and provides space and electronic systems for documentation, analysis, and record storage. Procedure 4014 describes the facility, room us es, layouts, etc.
 
7.3 Technical Processes and Methods 7.3.1 Operational Flow The laboratory design provides for sample receipt and storage (including special environmental provisions for perishable items) where samples are received from clients and other labs (see Section 9.0). The samples are logged into the computer based Laboratory Information Management System (LIMS) and receive unique identification numbers and bar code labels. (See Procedure 4017 for LIMS description and user procedures). The Program Managers then plan the work and assure LIMS contains any special instructions to analysts. Samples then go to sample preparation, wet chemistry (for chemical separation), and counting based on the radionuclides. See Procedures in the 2000 and 3000 series. Analysts perform the required tasks with data being entered into logbooks, LIMS, and counting equipment data systems as appropriate. Results are collected and reviewed by the Operations Manager and Program Managers and reports to clients are generated (See Section 14.0). All records (electronic or hard copy) are maintained in files or in back-up electronic copies (see Section 15.0). After the required hold periods and client notification and approval, samples are disposed of in compliance with regulatory requirements (s ee Procedures 5003 and 5004).  
===7.2 Facility===
The facility was designed and built in 2000 to facilitate correct performance of operations in accordance with good laboratory practices and regulatory requirements. It provides security for operations and samples. It separates sample storage areas based on activity levels, separates wet chemistry from counting instrumentation for contamination control, and provides space and electronic systems for documentation, analysis, and record storage. Procedure 4014 describes the facility, room us es, layouts, etc.  
 
===7.3 Technical===
Processes and Methods
 
====7.3.1 Operational====
Flow The laboratory design provides for sample receipt and storage (including special environmental provisions for perishable items) where samples are received from clients and other labs (see Section 9.0). The samples are logged into the computer based Laboratory Information Management System (LIMS) and receive unique identification numbers and bar code labels. (See Procedure 4017 for LIMS description and user procedures). The Program Managers then plan the work and assure LIMS contains any special instructions to analysts. Samples then go to sample preparation, wet chemistry (for chemical separation), and counting based on the radionuclides. See Procedures in the 2000 and 3000 series. Analysts perform the required tasks with data being entered into logbooks, LIMS, and counting equipment data systems as appropriate. Results are collected and reviewed by the Operations Manager and Program Managers and reports to clients are generated (See Section 14.0). All records (electronic or hard copy) are maintained in files or in back-up electronic copies (see Section 15.0). After the required hold periods and client notification and approval, samples are disposed of in compliance with regulatory requirements (s ee Procedures 5003 and 5004).  


Page 18 of 32 7.3.2  Methods The laboratory methods documented in the 2000 and 3000 series of Procedures were primarily developed by senior TBE laboratory personnel based on years of experience at our prior facility in New Jersey. They have been improved, supplemented and implemented here. Where EPA or other accepted national methods exist (primarily for water analyses under State certification programs - see Procedure 4010), the TBE methods conform to the imposed requirements or State accepted alternate requirements. Any method modifications are documented and described in the Procedure. There are no nationally recognized methods for most other analysis methods but references to other method documents are noted where applicable.
Page 18 of 32 7.3.2  Methods The laboratory methods documented in the 2000 and 3000 series of Procedures were primarily developed by senior TBE laboratory personnel based on years of experience at our prior facility in New Jersey. They have been improved, supplemented and implemented here. Where EPA or other accepted national methods exist (primarily for water analyses under State certification programs - see Procedure 4010), the TBE methods conform to the imposed requirements or State accepted alternate requirements. Any method modifications are documented and described in the Procedure. There are no nationally recognized methods for most other analysis methods but references to other method documents are noted where applicable.
7.3.3  Data Reduction and Analysis Whenever possible automatic data capture and computerized data reduction programs are used. Calculations are either performed using commercial software (counting system operating systems) or TBE developed and validated software is used (see 7.4 below). Analysis of reduced data is performed as described in Section 14.0 and Procedure 4004.   
7.3.3  Data Reduction and Analysis Whenever possible automatic data capture and computerized data reduction programs are used. Calculations are either performed using commercial software (counting system operating systems) or TBE developed and validated software is used (see 7.4 below). Analysis of reduced data is performed as described in Section 14.0 and Procedure 4004.
7.4 Verification of Technical Processes, Methods, and Software


===7.4 Verification===
7.4.1  Operational Flow Verification The entire QA Manual and related procedures describe the verification of elements of the technical process flow and the establishment of quality check points, reviews, and controls.
of Technical Processes, Methods, and Software
7.4.2  Method Verifications Methods are verified and validated per Procedure 4007 prior to use unless otherwise agreed to by the client. For most TBE methods initial validation occurred well in the past. New or significantly revised Methods receive initial validation by demonstration of their performance using known analytes (NIST traceable) in appropriate matrices. Sufficient samples are run to obtain statistical data that provides evidence of process capability and control, establishes detection levels (see procedure 4009), bias and precisi on data (see Procedure 4011). All method procedures and validation data are available to respective clients. Also see Section 7.5 below for the Demonstration of Capability program.
7.4.3  Data Reduction and Analysis Verification Data reduction and analysis verification is performed by personnel who did not generate the data. (See Section 14.0).
7.5  Design of Quality Controls


====7.4.1 Operational====
Page 19 of 32 7.5.1  General There are multiple quality controls designed into the laboratory operations. Many of these are described elsewhere in this manual and include personnel qualification (Section 4.0), Document control (6.0), Sample identification and control (9.0), Use of reference standards (10.0), intra- and inter- laborator y tests (10.0), etc. This Section describes the basic quality control systems used to verify Method capability and performance.
Flow Verification The entire QA Manual and related procedures describe the verification of elements of the technical process flow and the establishment of quality check points, reviews, and controls.
7.5.2 Demonstration of Capability (D of C)
 
The demonstration of capability system verifies and documents that the method, analyst, and the equipment can perfo rm within acceptable limits. The D of C is certified for each combination of analyte, method, and instrument type. D of C's are certified based on objective evidence at least annually. This program is combined with the analyst D of C program (See Section 4.0). Initial D of C's use the method validation effort as covered above. Subsequent D of C's use Inter- Laboratory samples (Procedure 4006) or, if necessary, laboratory generated samples using NIST traceable standards. If results are outside of control limits, re-demonstration is required after investigation and corrective action is accomplished (See Sections 12.0 and 13.0) 7.5.3 Process Control Checks Process control checks are designed to include Inter-Lab samples, Intra-lab QC check samples, and customer provided check samples. 10% of laboratory analysis samples are for process control purposes.
====7.4.2 Method====
Verifications Methods are verified and validated per Procedure 4007 prior to use unless otherwise agreed to by the client. For most TBE methods initial validation occurred well in the past. New or significantly revised Methods receive initial validation by demonstration of their performance using known analytes (NIST traceable) in appropriate matrices. Sufficient samples are run to obtain statistical data that provides evidence of process capability and control, establishes detection levels (see procedure 4009), bias and precisi on data (see Procedure 4011). All method procedures and validation data are available to respective clients. Also see Section
 
===7.5 below===
for the Demonstration of Capability program.
7.4.3  Data Reduction and Analysis Verification Data reduction and analysis verification is performed by personnel who did not generate the data. (See Section 14.0).
 
===7.5 Design===
of Quality Controls
 
Page 19 of 32 7.5.1  General There are multiple quality controls designed into the laboratory operations. Many of these are described elsewhere in this manual and include personnel qualification (Section 4.0), Document control (6.0), Sample identification and control (9.0), Use of reference standards (10.0), intra- and inter- laborator y tests (10.0), etc. This Section describes the basic quality control systems used to verify Method capability and performance.  
 
====7.5.2 Demonstration====
of Capability (D of C)
The demonstration of capability system verifies and documents that the method, analyst, and the equipment can perfo rm within acceptable limits. The D of C is certified for each combination of analyte, method, and instrument type. D of C's are certified based on objective evidence at least annually. This program is combined with the analyst D of C program (See Section 4.0). Initial D of C's use the method validation effort as covered above. Subsequent D of C's use Inter- Laboratory samples (Procedure 4006) or, if necessary, laboratory generated samples using NIST traceable standards. If results are outside of control limits, re-demonstration is required after investigation and corrective action is accomplished (See Sections 12.0 and 13.0)  
 
====7.5.3 Process====
Control Checks Process control checks are designed to include Inter-Lab samples, Intra-lab QC check samples, and customer provided check samples. 10% of laboratory analysis samples are for process control purposes.
7.5.3.1 Inter- Lab Samples. Inter-lab samples are procured or obtained from sources providing analytes of interest in matrices similar to normal client samples. These samples may be used for Demonstration of Capability of analyst's, equipment and methods. They also provide for independent insight into the lab's process capabilities. Any value reported as being in the warning zone (over 2 sigma) is reviewed and improvements taken. Any value failing (over 3 sigma) is documented on an NCR and formal investigation per Section 12.0 and 13.0 is performed. If root causes are not clearly understood and fixed, re-tests are required using lab prepared samples (See Procedure 4006).
7.5.3.1 Inter- Lab Samples. Inter-lab samples are procured or obtained from sources providing analytes of interest in matrices similar to normal client samples. These samples may be used for Demonstration of Capability of analyst's, equipment and methods. They also provide for independent insight into the lab's process capabilities. Any value reported as being in the warning zone (over 2 sigma) is reviewed and improvements taken. Any value failing (over 3 sigma) is documented on an NCR and formal investigation per Section 12.0 and 13.0 is performed. If root causes are not clearly understood and fixed, re-tests are required using lab prepared samples (See Procedure 4006).
7.5.3.2 QC Samples. QC samples, along with Inter-lab samples and customer check samples, are 10% of the annual lab workload for the applicable analyte and method. If batch processing is used, some specifications require specific checks with each batch or each day rather than as continuous process controls. (See Procedure 4005)  
7.5.3.2 QC Samples. QC samples, along with Inter-lab samples and customer check samples, are 10% of the annual lab workload for the applicable analyte and method. If batch processing is used, some specifications require specific checks with each batch or each day rather than as continuous process controls. (See Procedure 4005)  
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(a)  Method blanks (b)  Blank spikes (c)  Matrix spikes Page 20 of 32 (d)  Duplicates (e)  Tracers and carriers Acceptance limits for these samples are given in Procedures or in lab standards. The number, frequency, and use of these sample types varies with the method, matrix, and supplemental requirements. The patterns of use versus method and the use of the resulting test dat a is described in Procedure 4005.
(a)  Method blanks (b)  Blank spikes (c)  Matrix spikes Page 20 of 32 (d)  Duplicates (e)  Tracers and carriers Acceptance limits for these samples are given in Procedures or in lab standards. The number, frequency, and use of these sample types varies with the method, matrix, and supplemental requirements. The patterns of use versus method and the use of the resulting test dat a is described in Procedure 4005.
7.5.3.3 Customer Provided Check Samples. Customers may provide blind check samples and duplicates to aid in their evaluation of the Laboratory. When the lab is notified that sa mples are check samples their results are included in the QC sample percentage counts. Any report ed problems are treated as formal complaints and investigated per Section 5.  
7.5.3.3 Customer Provided Check Samples. Customers may provide blind check samples and duplicates to aid in their evaluation of the Laboratory. When the lab is notified that sa mples are check samples their results are included in the QC sample percentage counts. Any report ed problems are treated as formal complaints and investigated per Section 5.
 
7.6 Counting Instrument Controls The calibration of instruments is their primary control and is described in Section 11.0. In addition, counting procedures (3000 series) also specify use of background checks (method blank data is not used for this) to evaluate possible counting equipment contamination. Instrument calibration checks using a lab standard from a different source than the one used for calibration are also used. Background data can be used to adjust client and test data. Checks with lab standards indicate potential calibration changes.
===7.6 Counting===
Instrument Controls The calibration of instruments is their primary control and is described in Section 11.0. In addition, counting procedures (3000 series) also specify use of background checks (method blank data is not used for this) to evaluate possible counting equipment contamination. Instrument calibration checks using a lab standard from a different source than the one used for calibration are also used. Background data can be used to adjust client and test data. Checks with lab standards indicate potential calibration changes.


Page 21 of 32 8.0 PURCHASING AND SUBCONTRACT CONTROLS  
Page 21 of 32 8.0 PURCHASING AND SUBCONTRACT CONTROLS  


===8.1 General===
8.1 General Procurement and Subcontracts efforts use the Huntsville-based Cost Point computer system to process orders. The Laboratory-generated Purchase Requisitions are electronically copied into Purchase Orders in Huntsville. The Laboratory also specifies sources to be used. Procured items and services are received at the Laboratory where receiving checks and inspections are made. Laboratory Procedure 1015 provides details on the procurement control system at the Laboratory and references the H untsville procedures as applicable.
Procurement and Subcontracts efforts use the Huntsville-based Cost Point computer system to process orders. The Laboratory-generated Purchase Requisitions are electronically copied into Purchase Orders in Huntsville. The Laboratory also specifies sources to be used. Procured items and services are received at the Laboratory where receiving checks and inspections are made. Laboratory Procedure 1015 provides details on the procurement control system at the Laboratory and references the H untsville procedures as applicable.  
8.2 Source Selection Sources for procurements of items and services are evaluated and approved by QA as described in Procedure 1015. Nationally recognized catalog item sources are approved by the QA Manager based on reputation. Maintenance services by an approved distributor or the equipment manufacturing company are pre-approved. Sources for other services are evaluated by QA, based on service criticality to the quality system, by phone, mail out, or site visit.  


===8.2 Source===
Subcontract sources for laboratory analysis services are only placed with accredited laboratories (by NELAP, NUPIC, State, Client, etc.) as applicable for the type of analysis to be performed. QA maintains lists of approved vendors and records of evaluations performed.
Selection Sources for procurements of items and services are evaluated and approved by QA as described in Procedure 1015. Nationally recognized catalog item sources are approved by the QA Manager based on reputation. Maintenance services by an approved distributor or the equipment manufacturing company are pre-approved. Sources for other services are evaluated by QA, based on service criticality to the quality system, by phone, mail out, or site visit.  
8.3 Procurement of Supplies and Support Services 8.3.1 Catalog Supplies The Laboratory procures reagents, processing chemicals, laboratory "glassware," consumables, and other catalog items from nationally known vendors and to applicable laboratory grades, purities, concentrations, accuracy levels, etc. Purchase Requisitions for t hese items specify catalog numbers or similar call-outs for these off-the-shelf items. Requisitions are generated by the personnel in the lab needing the item and are approved by the Operations or Production Manager.
Reagents are analytical reagent grade only.
8.3.2 Support Services Purchase Requisitions for support services (such as balance calibration, equipment maintenance, etc.) are processed as in 8.3.1 but technical requirements are specified and reviewed before approvals are given.  


Subcontract sources for laboratory analysis services are only placed with accredited laboratories (by NELAP, NUPIC, State, Client, etc.) as applicable for the type of analysis to be performed. QA maintains lists of approved vendors and records of evaluations performed.
Page 22 of 32 8.3.3 Equipment and Software Purchase Requisitions for new equipment, software programs, and major facility modifications affecting the quality system are reviewed and approved by the Operations Manager and the QA Manager.
 
8.4 Subcontracting of Analytical Services When necessary, the Laboratory may subcontract analytical services required by a client. This may be because of special needs, infrequency of analysis, etc. Applicable quality and regulatory requirements are imposed in the Purchase Requisition and undergo a technical review by QA. TBE reserves the right of access by TBE and our client for verification purposes.
===8.3 Procurement===
8.5 Acceptance of Items or Services Items and services affecting the quality system are verified at receipt based on objective evidence supplied by the vendor. Supply items are reviewed by the requisitioner and, if acceptable, are accepted via annotation on the vendor packing list or similar document. Similarly, equipment services are accepted by the requisitioning lab person. Calibration services are accepted by QA based on certification reviews.
of Supplies and Support Services
(See Section 11.0.)  
 
====8.3.1 Catalog====
Supplies The Laboratory procures reagents, processing chemicals, laboratory "glassware," consumables, and other catalog items from nationally known vendors and to applicable laboratory grades, purities, concentrations, accuracy levels, etc. Purchase Requisitions for t hese items specify catalog numbers or similar call-outs for these off-the-shelf items. Requisitions are generated by the personnel in the lab needing the item and are approved by the Operations or Production Manager.
Reagents are analytical reagent grade only.
 
====8.3.2 Support====
Services Purchase Requisitions for support services (such as balance calibration, equipment maintenance, etc.) are processed as in 8.3.1 but technical requirements are specified and reviewed before approvals are given.
 
Page 22 of 32 8.3.3 Equipment and Software Purchase Requisitions for new equipment, software programs, and major facility modifications affecting the quality system are reviewed and approved by the Operations Manager and the QA Manager.  
 
===8.4 Subcontracting===
of Analytical Services When necessary, the Laboratory may subcontract analytical services required by a client. This may be because of special needs, infrequency of analysis, etc. Applicable quality and regulatory requirements are imposed in the Purchase Requisition and undergo a technical review by QA. TBE reserves the right of access by TBE and our client for verification purposes.  
 
===8.5 Acceptance===
of Items or Services Items and services affecting the quality system are verified at receipt based on objective evidence supplied by the vendor. Supply items are reviewed by the requisitioner and, if acceptable, are accepted via annotation on the vendor packing list or similar document. Similarly, equipment services are accepted by the requisitioning lab person. Calibration services are accepted by QA based on certification reviews.
  (See Section 11.0.)  


Data reports from analytical subcontractors are evaluated by Program Managers and subsequently by the Operations Manager (or designee) as part of client report reviews.
Data reports from analytical subcontractors are evaluated by Program Managers and subsequently by the Operations Manager (or designee) as part of client report reviews.
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Page 23 of 32 9.0 TEST SAMPLE IDENTIFICATION AND CONTROL  
Page 23 of 32 9.0 TEST SAMPLE IDENTIFICATION AND CONTROL  


===9.1 Sample===
9.1 Sample Identification Incoming samples are inspected for customer identification, container condition, chain of custody forms, and radioactivity levels. If acceptable, the sample information is entered into LIMS which generates bar coded labels for attachment to the sample(s). The labels are attached and samples stored in the assigned location. If environmental controls are needed (refrigeration, freezing, etc.), the samples are placed in these storage locations. If not acceptable, the Program Manager is notified, the customer contacted, and the problem resolved (return of sample, added data receipts, etc.). See Procedure 4003 for more information on sample receipt.
Identification Incoming samples are inspected for customer identification, container condition, chain of custody forms, and radioactivity levels. If acceptable, the sample information is entered into LIMS which generates bar coded labels for attachment to the sample(s). The labels are attached and samples stored in the assigned location. If environmental controls are needed (refrigeration, freezing, etc.), the samples are placed in these storage locations. If not acceptable, the Program Manager is notified, the customer contacted, and the problem resolved (return of sample, added data receipts, etc.). See Procedure 4003 for more information on sample receipt.
9.2 LIMS  The LIMS is used to schedule work, provide special information to analysts, and record all actions taken on samples. See Procedure 4017 and the 6000 series of procedures for more information on LIMS operations.
9.2 LIMS  The LIMS is used to schedule work, provide special information to analysts, and record all actions taken on samples. See Procedure 4017 and the 6000 series of procedures for more information on LIMS operations.  
9.3 Sample Control The sample, with its bar coded label, is logged out to the applicable lab operation where the sample is processed per the applicable methods  (Procedures 2000 and 3000). The LIMS-assigned numbers are used for identification through all operations to record data. Data is entered into LIMS, log books (kept by the analysts) or equipment data systems to record data. The combination of LIMS, logbooks, and equipment dat a systems provide the Chain of Custody data and document all actions taken on samples. Unused sample portions are returned to its storage area for possible verification use. Samples are discarded after required time limits are passed and after client notification and approval , if required.
 
===9.3 Sample===
Control The sample, with its bar coded label, is logged out to the applicable lab operation where the sample is processed per the applicable methods  (Procedures 2000 and 3000). The LIMS-assigned numbers are used for identification through all operations to record data. Data is entered into LIMS, log books (kept by the analysts) or equipment data systems to record data. The combination of LIMS, logbooks, and equipment dat a systems provide the Chain of Custody data and document all actions taken on samples. Unused sample portions are returned to its storage area for possible verification use. Samples are discarded after required time limits are passed and after client notification and approval , if required.
Page 24 of 32 10.0 SPECIAL PROCESSES, INSPECTION, AND TEST  
Page 24 of 32 10.0 SPECIAL PROCESSES, INSPECTION, AND TEST  


Revision as of 12:08, 13 July 2019

to Hydrogeologic Investigation Report, Fleetwide Assessment, Zion Station.
ML062760017
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 09/30/2006
From:
Conestoga-Rovers & Associates
To:
Exelon Generation Co, NRC/FSME
References
045136 (22), FOIA/PA-2010-0209
Download: ML062760017 (678)
v • d • e


Text

Worldwide Engineering, Environmental, Construction, and IT Services Revision 1 Certain figures in this Report contain sensitive, security-related information protected from public disclosure by Federal and State law. This Report is suitable for public disclosure only after these figures are removed.

HYDROGEOLOGIC INVESTIGATION REPORT

FLEETWIDE ASSESSMENT

ZION STATION

ZION, ILLINOIS

Prepared For:

Exelon Generation Company, LLC

D ISCLAIMER: SOME FORMATTING CHANGES MAY HAVE OCCURRED WHEN THE ORIGINAL DOCUMENT WAS PRINTED TO PDF; HOWEVER , THE ORIGINAL CONTENT REMAINS UNCHANGED.

SEPTEMBER 2006 R EF. NO. 045136 (22)

Prepared by:

Conestoga-Rovers

& Associates 651 Colby Drive Waterloo, Ontario

Canada N2V 1C2 Office: (519) 884-0510 Fax: (519) 884-0525 web: http:\\www.CRAworld.com

Revision 1 TABLE OF CONTENTS Page EXECUTIVE

SUMMARY

..............................................................................................................

......i 1.0 INTROD UCTION...............................................................................................................

....1 2.0 STATION DESCRIPTION

.....................................................................................................

2 2.1 STATION L O CATION.......................................................................................

2 2.2 OVERVIEW OF COOLING WATE R OPERATIONS

.....................................

2 2.3 SURROUNDING LAND USE

...........................................................................

4 2.4 STATION SETTING............................................................................................

5 2.4.1 TOPOGRAPHY AND SURF ACE WATER FE ATURES.................................

5 2.4.2 GEOLOGY

............................................................................................................

6 2.4.3 HYDROGE O LOGY.............................................................................................

7 2.5 ARE A GROUNDWATE R USE..........................................................................

8 3.0 ARE A S FOR FURT HE R EVAL UATION.............................................................................

9 3.1 SYSTEMS EVAL UATIONS................................................................................

9 3.2 HISTORIC AL RELEASES................................................................................

12 3.3 STATION INVESTIG ATIONS.........................................................................

12 3.3.1 PRE-OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

.......................................

12 3.3.2 RADIOLOG ICAL ENVI RONME N TAL MONITORING PROGRAM

......13 3.3.3 DEFUELED SAFETY ANALYSIS REPORT

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14 3.3.4 WISCONSIN DEPARTMENT OF HEALTH AND FAMILY SE RVICES MONITORING

..............................................................

15 3.4 IDENTIFIED AREAS FOR FURTHER EVAL UATION...............................

15 4.0 FIELD METHODS..............................................................................................................

...18 4.1 STAFF GAUGE INSTALLATION

...................................................................

18 4.2 GROUND WATE R MONITORING WELL INSTALL A TI ON.....................

18 4.3 GROUND WATE R MONITORING WELL DEVELOPME N T....................

20 4.4 SURVEY

..............................................................................................................

21 4.5 GROUNDWATER AND SURFACE WATER ELEVATION MEASUREMENTS

....................................................................

21 4.6 GROUND WATE R AND SURF AC E WATE R SAMPLE COLLECTION

...22 4.7 DATA QUALITY OBJECTIVES

.......................................................................

24 4.8 SAMPLE IDENTIFICATION

...........................................................................

25 4.9 CHAIN-OF-CUSTODY RECORD...................................................................

25 4.10 QUALITY CONTROL SAMPLES

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26 4.11 ANALYSES

.........................................................................................................

26 045 136 (22) Zi on St ati o n C ONESTOGA-R OVERS & A SSOCIATES Revision 1 TABLE OF CONTENTS Page 5.0 RESUL T S

SUMMARY

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27 5.1 STATION GEOLOGY.......................................................................................

27 5.2 STATION HYDROGEOLOGY

........................................................................

29 5.2.1 GROUND WATE R FLOW DIRECTIONS

......................................................

29 5.2.2 MAN-MAD E INFLUENCES ON GROUNDWATER FLOW

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29 5.2.3 VERTIC AL HYDRAULI C GRADIENTS

........................................................

30 5.2.4 LATERAL GROUND WATE R FLOW AND VELOCITY

.............................

30 5.3 GROUND WATE R QUALITY..........................................................................

31 5.3.1

SUMMARY

OF BETA-EMITTING RADIONUCLIDES ANALYTIC AL RESULTS

.................................................................................

31 5.3.2

SUMMARY

OF GAMMA-EMITTING RADIONUCLIDES ANALYTIC AL RESULTS

.................................................................................

32 5.3.3

SUMMARY

OF FIELD MEASURE M ENTS...................................................

32 5.4 SURF ACE WATE R QUALITY.........................................................................

33 5.4.1

SUMMARY

OF BETA-EMITTING RADIONUCLIDE ANALYTIC AL RESULTS

.................................................................................

33 5.4.2

SUMMARY

OF GAMMA-EMITTING RADIONUCLIDES ANALYTIC AL RESULTS

.................................................................................

33 6.0 RADIONUCLIDES OF CONCERN AND SOURCE AREAS

.........................................

35 6.1 GAMMA-E M ITTING RADIONUC LIDES.....................................................

35 6.2 BETA-EMITTING RADI ONUCLIDE S...........................................................

35 6.3 TRITIUM

.............................................................................................................

35 6.3.1 GENERAL CHARACTERISTICS

....................................................................

35 6.3.2 DISTRIBUTION IN STATION GROUNDWATE R.......................................

36 6.3.3 CONCEPTUAL MODEL OF TRITIUM RELEASE AND MIGRATION.........................................................................

37 6.3.4 ATTENUATION OF TRITIUM WITHIN THE SHALLOW GROUND WATE R SYSTEM............................................................................

37 7.0 EXPOSURE PATHWAY ASSESSME NT............................................................................

39 7.1 HEALTH E FFECTS OF TRITIUM

...................................................................

39

7.2 BACKGROUND

CONCENTR ATI O NS OF TRITIUM

................................

40 7.2.1 GROUND WATE R.............................................................................................

40 7.2.2 PRECIPITATION DATA..................................................................................

40 7.2.3 SURF ACE WATE R DATA...............................................................................

41 7.2.4 DRINKING WATE R DATA............................................................................

42 7.2.5 EXPECTED TRITIUM BACKGROUND FOR THE STATION

...................

42 7.3 IDENTIFICATION OF POTENTIAL EXPOSURE PATHWAYS AND POTENTIAL RE CEPTORS............................................

43 7.3.1 POTENTIAL GROUNDWATER MIGRATION TO DRINKING WATE R USERS OFF THE STATION PROPERTY

.......................................

43 045 136 (22) Zi on St ati o n C ONESTOGA-R OVERS & A SSOCIATES Revision 1 TABLE OF CONTENTS Page 7.3.2 POTENTIAL GROUNDWATER MIGRATION TO SURF ACE WATE R USERS..............................................................................

44 7.4

SUMMARY

OF POTENTIAL TR ITI U M EXPOSURE PATHWAYS

..........

44 7.5 OTHER RADIONUCLIDES

.............................................................................

45 8.0 CONCLUSI ONS................................................................................................................

....46 9.0 RECOMME NDATIONS.......................................................................................................

49 9.1 DATA G A PS......................................................................................................

49 9.2 GROUND WATE R MONITORING

................................................................

49 10.0 REFERENC E S................................................................................................................

........50 045 136 (22) Zi on St ati o n C ONESTOGA-R OVERS & A SSOCIATES Revision 1 LIST OF FIGURES (Following Text)

FIGURE 1.1 STATION LOCATION MAP FIGURE 1.2 STATION BOUNDARIES AND FEATURES FIGURE 2.1 STATION SURFACE WATER FEATURES FIGURE 2.2 REGIONAL STRATIGRAPHIC CROSS-SECTION FIGURE 2.3 CROSS-SECTION OF THE ZION BEACH-RIDGE PLAIN FIGURE 2.4 PRIVATE/PUBLIC WATER SUPPLY WELL LOCATIONS FIGURE 3.1 AREAS FOR FURTHER EVALUATION FIGURE 4.1 GROUNDWATER AND SURFACE WATER MONITORING LOCATIONS FIGURE 5.1 STATION GEOLOGIC CROSS-SECTION LOCATION MAP FIGURE 5.2 GEOLOGIC CROSS-SECTION A-A' FIGURE 5.3 GEOLOGIC CROSS-SECTION B-B' FIGURE 5.4 POTENTIOMETRIC SURFACE CONTOURS - MAY 2006 -

SHALLOW GROUNDWATER ZONE FIGURE 5.5 POTENTIOMETRIC SURFACE CONTOURS - JULY 2006 -

SHALLOW GROUNDWATER ZONE FIGURE 5.6 TRITIUM CONCENTRATIONS - GROUNDWATER AND SURFACE WATER FIGURE 5.7 RADIONUCLIDE CONCENTRATIONS - GROUNDWATER AND SURFACE WATER 045 136 (22) Zi on St ati o n C ONESTOGA-R OVERS & A SSOCIATES Revision 1 LIST OF TABLES (Following Text)

TABLE 4.1

SUMMARY

OF MONITORING WELL INSTALLATION DETAILS TABLE 4.2

SUMMARY

OF MONITORING WELL DEVELOPMENT PARAMETERS TABLE 4.3

SUMMARY

OF GROUNDWATER AND SURFACE WATER ELEVATIONS TABLE 4.4 SAMPLE KEY TABLE 4.5

SUMMARY

OF MONITORING WELL PURGING PARAMETERS TABLE 5.1 ANALYTICAL RESULTS

SUMMARY

-

TRITIUM IN GROUNDWATER AND SURFACE WATER TABLE 5.2 ANALYTICAL RESULTS

SUMMARY

-

RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER 045 136 (22) Zi on St ati o n C ONESTOGA-R OVERS & A SSOCIATES Revision 1 LIST OF APPENDICES APPENDIX A WATER WELL INVENTORY RECORDS A.1 BANKS 2006 WATER WELL REPORT A.2 ISWS LOGS APPENDIX B BORING LOGS B.1 2006 STRATIGRAPHIC AND INSTRUMENTATION LOGS B.2 HISTORIC GEOTECHNICAL LOGS APPENDIX C QUALITY ASSURANCE PROGRAM - TELEDYNE BROWN ENGINEERING, INC.

APPENDIX D LABORATORY ANALYTICAL REPORTS APPENDIX E DATA VALIDATION MEMORANDUM 045 136 (22) Zi on St ati o n C ONESTOGA-R OVERS & A SSOCIATES Revision 1 EXECUTIVE

SUMMARY

This Hydrogeologic Investigation Report (HIR) documents the results of Conestoga-Rovers

& Associates' (CRA's) Ma y to July 2006 hydrogeologic investigation pertaining to the Zion Station (Station). CRA prepared this HIR for Exelon as part of its Fleetwide Program to determine whether grou ndwater at and in the vicinity of its nuclear power generating facilities has been adversely impacted by any releases of radionuclides.

CRA collected and analyzed information on any historical releases, the structures, components, and areas of the Station that have the potential to release tritium or other radioactive liquids to the environment and past hydrogeologic investigations at the Station. CRA used this information, comb ined with its understanding of groundwater flow at the Station to identify the Areas fo r Further Evaluation (AFEs) for the Station.

Fifteen new monitoring wells were installed, including 11 permanent and 4 temporary monitoring wells. CRA also collected two rounds of water levels from the newly installed wells and the surface water staff gauge. All groundwater and surface water samples were analyzed for tritium, strontium-89/90, and gamma-emitting radionuclides. Field activities were completed between May and July 2006.

The results of the hydrogeologic investigation are:

Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than th eir respective Lower Limits of Detection (LLDs) in any of the groundwater or su rface water samples obtained and analyzed during the course of this investigation; Strontium-89/90 was not detected at a concentration greater than the LLD of 2.0 picoCuries per liter (pCi/L) in any of the groundwater or surface water samples obtained and analyzed during the course of this investigation; Tritium was not detected within any area in or adjacent to the Station at levels above the United States Environmental Protecti on Agency drinking water standard of 20,000 pCi/L in any of the groundwater or surface water samples obtained and analyzed during the course of this investigation; Low levels of tritium were detected at concentrations greater than the LLD of 200 pCi/L, which is considered background; Tritium was detected in groundwater sa mples collected from monitoring well MW-ZN-01S. These concentrations ranged from less than LLD (most recently) to 586 +/- 141 pCi/L (lower interval) and 220 +/- 123 pCi/L to 261 +/- 124 pCi/L (upper 045 136 (22) Zi on St ati o n i C ONESTOGA-R OVERS & A SSOCIATES Revision 1 interval). The detected concentrations ar e significantly less than applicable drinking water standard. The source of tritium in this location is likely attributable to historical releases in this area. However, the most recent sample results are within the range of background concentrations; Based on the results of this investigation, tritium is not migrating off the Station property at detectable concentrations; Based on the results of this investigation, there is no current risk from exposure to radionuclides associated with licensed plant operations through any of the identified potential exposure pathways; and Based on the results of this investigation, there are no known active releases into the groundwater at the Station.

Based upon the information collected to date, CRA recommends that Ex elon conduct periodic monitoring of selected sample locations.

045 136 (22) Zi on St ati o n ii C ONESTOGA-R OVERS & A SSOCIATES Revision 1 1.0 I N TRO D U CTIO N Conestoga-Rovers

& Associates (CRA) has pr epared this Hydrogeologic Investigation Report (HIR) for Exelon Generation Company, LLC (Exelon) as part of its fleetwide program to determine whether groundwater at and near its nuclear power generating facilities has been adversely impacted by any releases of radionuclides. This report documents the results of CRA's May 2006 Hydrogeologic Investigation Work Plan (Work Plan), as well as several other invest igative tasks recommended by CRA during the course of the investigation.

These inve stigations pertain to Ex elon's Zion Station (Station) in Zion, Illinois (see Figure 1.1). The Station is defined as all property, structures, systems, and components owned and operated by Ex elon LLC and located at 101 Shiloh Boulevard, Zion, Lake County, Illinois.

The approximate property boundaries are depicted on Figure 1.2.

Pursuant to the Work Plan, CRA assessed groundwater q u ality at the Station in locations designated as areas for further ev aluation (AFEs). The process by which CRA identified AFEs is discussed in Section 3.0 of this report.

The objectives of the Work Plan were to:

characterize the geologic and hydrogeolo gic conditions at the Station including subsurface soil types, the presence or abse nce of confining layers, and the direction and rate of groundwater flow; characterize the groundwater/

surface water interaction at the Station, including a determination of the surface water flow regime; evaluate groundwater q u ality at the Statio n including the vertical and horizontal ex tent, q u antity, concentrations, and potential sources of tritium and other radionuclides in the groundwater, if any; define the probable sources of any radionuclides released at the Station; evaluate potential human, ecological , or environmental receptors of any radionuclides that might have been released to the groundwater; and evaluate whether interim respon se activities are warranted.

045 136 (22) Zi on St ati o n 1 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 2.0 S T A T I O N DESCRIPTION The following section presents a general summa ry of the Station location and definition, overview of Station operations, surrounding l and use, and an overview of both regional and Station-specific topography, surface wa ter features, geology, hydrogeology, and groundwater flow conditions. This section also presents an overview of groundwater use in the area.

2.1 S T A T I O N LOCATION The Station is a former nuclear power generati ng facility that, in the early spring of 1998, converted both units' generators to sync hronous condensers that provide voltage stability to the northeast Illinois power grid. The Station encompasses approximately 250 acres (Ex e lon, 2004). Figure 1.2 presents a Station Boundaries and Features plan.

The Station is located on the eastern edge of Zion between 23rd and 29th Streets, from the Chicago and Northwestern Railroad tracks to Lake Michigan.

The Station is being maintained and monito red under the "SAFSTOR" (safe storage of components of the nuclear power plant) p hase of decommissioning, as is discussed below. 2.2 OVERVIEW OF COOLING WATER OPERATIONS Former Operations In the mid-1950s, Commonwealth Edison Comp any (ComEd) purchased about 250 acres on the eastern edge of Zion. The Station operated as a dual unit pressurized water reactor plant. A construction permit was issu ed in December 1968. An operating license was issued October 19, 1973 for Unit 1 and November 14, 1973 for Unit

2. Commercial operations commenced in December 1973 for Unit 1 and September 1974 for Unit 2.

Unit 1 operations ended on February 21, 1997 and Unit 2 operations ended on September 19, 1996. All fuel was removed from the reactor and placed in the spent fuel pool on April 27, 1997 for Unit 1 and on February 25, 1998 for Unit

2. Commercial operation of the plant ended on January 14, 1998 when the Unicom Corporation and ComEd Boards of Directors authorized the permanent cessation of operations at the Station. Ex elon submitted the certification of fuel transfer on March 9, 1998. In addition 045 136 (22) Zi on St ati o n 2 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 to maintaining the synchronous condensers, the Station's employees also monitor the safe storage of spent fuel.

Discharges from the Station are subject to the requirements of Nuclear Regulatory Commission (NRC) Operating Licenses DP R-39 and DPR-48. Discharges from the Station are also subject to regulation under the Illinois Environmental Protection Agency (EPA) National Pollutant Discharge Elim ination System (NPDES) Permit IL0002763.

The NPDES permit provides limits on parame ters such as pH, total suspended solids, and oil and grease.

Cooling Water Operations 1973-1997 The Station is comprised of two nearly id entical pressurized water reactors with supporting facilities. Both primary reac tor coolant systems were designed by Westinghouse Corporation and each is comprised of a reactor vessel and four heat transfer loops. Each loop contains a reactor coolant pump, steam generator, and associated piping and valves. In addition , each system includes a pressurizer, a pressurizer relief tank, interconnecting pipi ng, and the instrumentation necessary for operational control.

Each Containment Building is cylindrical with a shallow dome roof and has a flat slab foundation.

The entire structure is inter nally lined with a welded steel plate and completely encloses the primary coolant syst em, steam generators, reactor coolant loops, and portions of the auxiliary and engineered safety feature systems.

Heat produced in the reactor was converted to electrical energy by the power conversion system between 1973 and 1997. A turbine generator converted the thermal energy of steam produced in the steam generators in to mechanical shaft power and then into electrical energy.

The exhaust steam from the turbine was condensed and deaerated in the main condenser. The waste heat in the main co ndenser was removed by the circulating water system. Circulating water was withdrawn fr om Lake Michigan, approx imately 450 feet east of the condensate storage tank, via an intake pipe connected to the circulating water pumps. After circulating through the plant condensers, the cooling water was routed back to the lake via discharge lines (ComEd, 1999).

045 136 (22) Zi on St ati o n 3 C ONESTOGA-R OVERS & A SSOCIATES Primary coolant was treated to remove impuri ties and recirculated through the primary water (PW) system. Primary coolant was st ored in two above ground storage tanks (ASTs) located on the east side of the Turbine Building.

Revision 1 Secondary cooling water (condensate cooling water) was treated to remove impurities and recirculated through the condensate (CD/SC) system. Secondary cooling water is stored in ASTs located on the ea st side of the Turbine Building.

Circulating water is drawn from Lake Michig an by way of an intake pipe that ex tends approx imately a half mile into the Lake. Circ ulating water is returned to Lake Michigan by way of two discharge pipes that ex tend approx imately a q u arter mile into the lake.

Liquid wastes have been discharged under th e NRC permit through the blowdown line, which is piped to the circulating water di scharge pipe located east of the Turbine Building.

Voltage Stabilization and SAFSTOR The Station is being decommissioned under the NRC regulatory process. The Station is currently in the "SAFSTOR" phase of the de commissioning process where the Station is maintained in a condition that allows it to be safely stored and subseq uently decontaminated to levels that permit its release for unrestricted use.

2.3 SURROUNDING LAND USE The Station is located on the shore of Lake Michigan, in the eastern portion of the City of Zion, and adjacent to the Illinois Beach State Park.

The Illinois Beach State Park is located alon g the Lake Michigan shoreline and is divided into a northern unit and a southern unit, with the Station situated between the two units. The Illinois Beach State Park encompasse s 4,160 acres and received approximately 2.75 million visitors in 1998. The Park is considered a natural resource (ATSDR, 2000).

The land located to the west of the Statio n is generally undeveloped with a limited number of industrial/commercial facilities present along Deborah Avenue. Residential areas and the City of Zion downtown are located west of the Chicago & Northwestern Railroad, which is west of the Station. Lake Michigan borders the Station to the east.

045 136 (22) Zi on St ati o n 4 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 2.4 S T A T I O N SETTING The following sections present a summary of the topography, surface water features, geology, hydrogeology, and groundwater flow conditions in the region surrounding the Station. The information was primarily gathered from Sections 2.1 and 2.3 of the Zion Defueled Safety Analysis Report (DSAR) la st revision dated October 2004 (Ex e lon, 2004). The main references the DSAR relies upon ar e listed in Section 10.0 of this HIR. CRA checked and verified all DSAR refe rences that apply to this HIR.

2.4.1 TOPOGRAPHY AND SURFACE WATER FEATURES Lake County consists of moraines, outwash pl ains, lake plains, kames, stream terraces, flood plains, beaches, and bogs. The county is in the Wheaton Morainal country of the Great Lakes section of the Central Lowland pr ovince. Relief in Lake County was caused by differences in the thickness of deposits le ft by the most recent glacier. The land surface gradually slopes to the south or so utheast. The highest point in the county, 957 feet above mean sea level (AMSL), is located on Gander Mountain in the northwest corner of the county. The lowest point is at the Lake Michigan shore near Waukegan.

Several moraines run through the county. From east to west, they are the Lake Border Morainic System, the Tinley Moraine, the Va lparaiso Morainic System, and the Fox Lake Moraine. In general, Lake County has a poorly defined drainage pattern. Many drainage ways terminate in depressions and ma rshes. The land area falls into four major watersheds and 26 drainage basins. Th e Chicago River, Des Plaines River, Fox River, and Lake Michigan watersheds are all s hared with neighboring counties in Illinois and Wisconsin (NRCS, 2005).

The Lake Michigan shoreline between North Chicago, Illinois and Kenosha, Wisconsin comprises the Zion beach-ridge plain. The Zion beach-ridge plain consists of linear, generally coast-parallel mounds of sand and gravel that have been built up by wave action to extend the coast outward into Lake Michigan. The Zion beach-ridge plain has a max i mum width of approx imately 1 mile ne ar the City of Zion (Chrzastowski and Frankie, 2000). The older dunes become root-bou nd by vegetation resulting in long lines of sandy ridges separated by linear marshes.

The main portion of the Station is located on a sand ridge that runs parallel to the Lake Michigan shoreline as shown on Figure 1.2. The area in the immediate vicinity of the Station has been leveled and is paved. Th e ground elevation at the main complex is 591 feet AMSL. The average lake level is 577 feet AMSL. The eastern portion of the 045 136 (22) Zi on St ati o n 5 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Station is a beach gently sloping to the Lake Michigan shoreline. The area to the west of the Station is a low-lying wet area.

Lake Michigan has a surface area of 22,300 sq uare miles, with a mean depth of 276 feet and a volume of 1,170 cubic miles.

Lake Michigan has a natural outlet through the Straits of Mackinac on the north end of the lake and a second outlet through the Illinois Waterway near Chicago (USEPA, 1995).

The average surface elevation of Lake Michig an is 577 feet AMSL. The surface elevation of Lake Michigan varies daily and annually , and is affected by hydrologic and atmospheric conditions and flow through th e two outlets. Water levels in Lake Michigan typically vary about 1 foot in elevation between annual low and high measurements. Generally, the lowest leve ls occur in winter when much of the precipitation is locked up in ice and snow on land, and dry winter air masses pass over the lakes enhancing evaporation. Levels ar e highest in summer after the spring thaw when runoff increases (USEPA, 1995).

The low-lying wet area on the western portion of the Station is in the watershed of the Dead River, which flows through the marshy swales located to the west of the longitudinal sand dunes that follow the Lake Michigan shoreline.

The Dead River passes through the Illinois Beach State Park as shown on Figure 1.1. The Dead River flows into Lake Michigan at a point approx imately 2.3 miles south of the Station.

The Dead River was so named because the mout h is periodically blocked by shifting sandbars on the Lake Michigan shoreline.

Storm water runoff from the switchyard is ca ptured by the perimeter ditch, which is a drainage channel that follows the Station's oute r fence. The perimeter ditch connects to Lake Michigan to the north and south of the Pr otected Area (PA). Figure 2.1 presents a depiction of the perimeter ditch and the stormwater drainage ditches that control surface water at the Station. On the wester n portion of the Station property some of these drainage systems intercept the shallow groundwater. This is not the case on the eastern portion of the Station property wher e the stormwater drainage system is located above the water table as it drops towards Lake Michigan.

2.4.2 G E O L O G Y This section presents an overview of Stat ion geology based upon the 1967 Foundation Investigation (Dames and Moore, 1967) and other geologic publications. The Station is underlain by overburden deposits and a regi onally extensive sequence of consolidated 045 136 (22) Zi on St ati o n 6 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 sedimentary deposits. The major stratigraphi c features can be divided into Paleozoic aged bedrock and Quaternary Period overbu rden deposits. Figure 2.2 presents a stratigraphic cross-section representative of bedrock units in Lake County, Illinois.

Figure 2.3 presents a cross-section of the ov erburden deposits associated with the Zion beach-ridge plain.

Rocks of the Cambrian through Silurian Periods are marine in origin and were deposited in a sea that covered all of Illinois (Willman, 1971). The rocks consist of sandstones, shales, and carbonates for a combined thickn ess of approx imately 2,500 feet. Southerly long shore currents have eroded the Root River delta and transported the sediments along the western shore of Lake Michig an to form the Zion beach-ridge plain (Chrzastowski and Frankie, 2000).

2.4.3 H Y D R O G E O L O G Y Groundwater in the region occurs in shallow glacial, alluvial, and lacustrine deposits.

The shallow water-bearing zone is isolated from the underlying regional bedrock aq uifers by a significant thickness of glacial or lacustrine silts and clays.

Bedrock units form three major aquifer syste ms in northeastern Illinois. The uppermost bedrock aq uifer consists of the Silurian do lomites. The underlying Maq u oketa Group shales hydraulically separate the S ilurian aq uifer from deeper units.

The deeper aquifer systems include the Cambrian-Ordovician aq uifer group, which includes the St.

Peter and Ironton-Galesville sandstones. The underlying Eau Claire Formation hydraulically separates the Ca mbrian-Ordovician aq uifer group from the deeper Mt. Simon Aq uifer (Visocky et al., 1985).

The sandstones of the Mt.

Simon Formation are not typically used for potable water because of undesirable characteristics includ ing high concentrations of total dissolved solids and natural radioactivity. Crystallin e basement rock underlies the Mt.

Simon Formation (Visocky et al., 1985).

Lake Michigan acts as a major regional discharge zone for groundwater. The groundwater flow in both unconsolidated de posits and bedrock units in the region is generally toward the lake; however, localiz ed pumping induces variations in flow directions in the bedrock aquifers.

045 136 (22) Zi on St ati o n 7 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 2.5 AREA GROUNDWATER USE A water well inventory compiled as part of this investigation indicates a number of wells located (or formerly located) near the Stat ion. The locations of wells in the vicinity of the Station are provided on Figure 2.4. A water well report was prepared using Illinois water well databases and associated we ll logs, and is provided in Appendix A. The well records for locations nearest to the Station (map identifiers 5, 6, and

10) are mis-located (Map Id. 5 1), not a water well (Map Id. 6 2), or no longer ex ist (Map Ids. 6 and 10 3). With the exception of Map Ids. 6 and 10, the wells identified in the water well report have not been field verified and it is ex pected that many of the wells listed have been abandoned.

The City of Zion provides municipal water to the City residents and the surrounding area. The City purchases water from the Lake County Public Water District (LCPWD).

The LCPWD obtains its water from Lake Mich igan by means of an intake pipe located approx imately 1.1 mile north of the Station and ex tending 3,000 feet into the Lake. The City of Zion municipal code requires all im proved properties to be connected to the City's water supply. It is "unlawful for any person to construct, permit or maintain a private well or water supply system within the City which uses groundwater as a potable water supply" (City of Zion, 2004). The only ex ception is for ex isting wells constructed prior to March 2, 2004 at proper ties located more than 100 feet from the municipal supply system, which must:

1) en ter into an agreement with the City, and
2) demonstrate that the well water is unlikely to contain any contaminant at concentrations exceeding the United States Environmental Protection Agency (USEPA) drinking water standards (City of Zion, 2004).

The Station is connected to the Zion municipal water supply and does not use groundwater in its operations.

The Illinois Beach State Park is serviced by municipal water.

1 Map ID 5 is a privat e wat e r well at Lot #1, Beac h Homeland subdivision, Beach Park, Illinois.

The lat i t u de and longit ude list e d in t h e ISWS dat a base is inconsist e nt wit h t h e address list e d in the well log (Beach Park is located between Zion and Waukegan).

2 Map ID 6 is an engineering t e st hole inst alled b y Norm Hest er of t h e ISG S on Nov e m b er 1, 1972.

The t o t a l dept h was 15 feet. This boring was inst alled as part of a st udy document ed in Fraser and Hest er (1974).

045 136 (22) Zi on St ati o n 8 C ONESTOGA-R OVERS & A SSOCIATES 3 Map ID 10 is a wat e r well inst alled by F H Fergus on at 'Zion Estates' at an unknown date. The t o t a l dep t h of t h e well was 138 feet. The locat i on sp ecified in t h e well record (42.446046N, 87.800889W) indicat e s t h at t h is well was locat e d on t h e east ern edge of what is now t h e Z i on St at ion. 'Zion Est a t e s' may have been part of t h e Hosah Beach subdivision (see Bannon-Nilles 2003) which was p u rchased b y C o m Ed in ab out 1967. This well is not current ly p r esent at t h e Zion Sta t ion.

Revision 1 3.0 AREAS FOR FURTHER EVALUATION CRA considered all Station operations in asse ssing groundwater q u ality at the Station. During this process, CRA identified area s at the Station that warranted further evaluation or "AFEs". This section discusse s the process by which AFEs were selected.

CRA's identification of AFEs in volved the following components:

Station inspection on March 22 to 23, 2006; interviews with Station personnel; evaluation of Station systems; investigation of confirmed and unconfirmed releases of radionuclides; and review of previous Station investigations.

CRA analyzed the information collected fr om these components combined with information obtained from CRA's study of hydrogeologic conditions at the Station to identify those areas where groundwater potent ially could be impacted from operations at the Station.

CRA then designed an investigation to dete rmine whether any confirmed or potential releases or any other release of radionuclid es adversely affected groundwater. This entailed evaluating whether ex isting Stat ion groundwater monitoring systems were sufficient to assess the groundwater q u ality at the AFEs. If the systems were not sufficient to adequately investigate ground water q u ality associated with any AFE, additional monitoring wells were installed by CRA.

The following sections describe the above cons iderations and the identification of AFEs.

The results of CRA's investigation are discussed in Section 5.0.

3.1 S Y S T E M S EVALUATIONS Exelon launched an initiative to systemat ically assess the structures, systems and components that store, use, or convey pote ntially radioactively contaminated liquids.

Maps depicting each of these systems were developed and provided to CRA for review.

The locations of these systems are presented on Figure 3.1. The Station identified a total of 17 systems that contain or could contai n potentially radioactively contaminated liquids. The following presents a list of these systems.

045 136 (22) Zi on St ati o n 9 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 System Identification Description A D A u x i l i a r y D r a i n s A X A u x i l i a r y S t e a m BD Blowdown System C F C a v i t y F i l l C W C i r c u l a t i n g W a t e r VC Chemical and Volume Control C C C o m p o n e n t C o o l i n g CD/SC Condensate and Condensate Storage M S M a i n S t e a m P W P r i m a r y W a t e r R R R e s i n R e m o v a l S I S a f e t y I n j e c t i o n S W S e r v i c e W a t e r S F S p e n t F u e l TD Turbine Building Drains W D W a s t e D i s p o s a l W T W a s t e W a t e r After these systems were identified, Exelon developed a list of the various structures, components and areas of the systems (e.g., pi ping, tanks, and process eq uipment) that handle or could potentially handle any radioactively contaminated liq uids. The structures, components, and areas may include:

aboveground storage tanks; condensate vents; areas where confirmed or potential historical releases, spills, or accidental discharges may have occurred; pipes; pools; sumps; surface water bodies (i.e., basins, pits, ponds, or lagoons); trenches; underground storage tanks; and vaults. 045 136 (22) Zi on St ati o n 10 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 The Station then individually evaluated th e various system components to determine the potential for any release of radioact ively contaminated liquid to enter the environment. Each structure or identi fied component was evaluated against the following seven primary criteria:

location of the component (i.e., basement or second floor of building); component construction material (i.e

., stainless steel or steel tanks); construction methodologies (i.e., we lded or mechanical pipe joints); concentration of radioactively contam inated liquid stored or conveyed; amount of radioactively contami nated liquid stored or conveyed; ex isting controls (i.e., containment and detection); and maintenance history.

System components, which were located inside a building or that otherwise had some form of secondary containment, such that a release of radioactively contaminated liq uid would not be discharged directly to the en vironment, were eliminated from further evaluation.

System components that are no t located within buildings or did not have some other form of secondary containmen t were retained for further qualitative evaluation of the risk of a release of radioactively contaminated liq uid to the environment and the potential magnitude of any release.

Exelon's risk evaluation took in to consideration factors such as:

the potential concentration of radionuclides; the volume of liq uid stored or managed; the probabilities of the systems actually containing radioactively contaminated liquid; and the potential for a release of radioactiv ely contaminated liquid from the system component.

These factors were then used to rank the systems and system components according to the risk for a potential release of a radioactiv ely contaminated liquid to the environment.

The evaluation process resulted in the iden tification of structures, components, and areas to be considered for further evaluation.

045 136 (22) Zi on St ati o n 11 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 3.2 H I S T O R I C A L RELEASES CRA also reviewed information concerning conf irmed or potential historical releases of radionuclides at the Station, including repo rts and documents previously prepared by Exelon and compiled for CRA's review. CRA evaluated this information in identifying the AFEs. Any historical releases identified during the course of this assessment that may have a current impact on Station conditio ns are further discussed in Section 3.4.

3.3 S T A T I O N INVESTIGATIONS CRA considered previous Station investigations in the process of selecting the AFEs for the Station. This section presents a su mmary of the pre-operational radiological environmental monitoring program (pre-operati onal REMP), past station investigations, and the radiological environmen tal monitoring program (REMP).

3.3.1 PRE-OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM A pre-operational REMP was conducted to es tablish background radioactivity levels prior to operation of the Station. The environmental media sampled and analyzed during the pre-operational REMP were surfac e water, well water, air particulates, milk, locally grown vegetables, and aq uatic plants and animals (ComEd, 1971). The results of the monitoring were detailed in the report entitled, 1971 Zion Station Final Safety Analysis Report, December 1971.

The pre-operational REMP report noted that surface water was sampled at five public water intakes. Generally, the gross beta radioactivity of Lake Michigan was less than 10 picoCuries per liter (pCi/L) with typical co ncentrations between 3 pCi/L to 6 pCi/L.

Gross alpha radioactivity was typically less than 3 pCi/L (ComEd, 1971).

Tritium levels in Lake Michigan water were studied in the vicinity of Zion Station throughout 1970. The concentration of trit ium in the surface water samples from the Lake at Zion ranged from approx imately 311 20 pCi/L to 374 34 pCi/L and averaged 340 pCi/L. There was no statistical differenc e in average tritium concentrations among the stations (eight stations from Kenosha to Waukegan) (ComEd, 1971).

045 136 (22) Zi on St ati o n 12 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 1973 Aerial Radiological Measuring System An Aerial Radiological Measuring System (A RMS) survey was conducted at the Station prior to the startup of the reactors in 1973. The ARMS survey was conducted using small aircraft flying at an altitude between 300 and 500 feet.

Ground-based measurements were obtained from two loca tions as part of the study. Tritium measurements were not included in the ARMS survey (ComEd, 1999).

The ARMS survey showed that cosmic ray ex posure rate was substantially less than the northern Illinois background radiation level (ComEd, 1999).

Soil samples contained small concentratio ns of uranium-238 and thorium-232.

Cesium-137 activity in soil samples ranged from 0.276 to 0.40 picoCuries per gram (pCi/g) (ComEd, 1999).

3.3.2 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM The REMP at the Station was initiated in 1973. The REMP includes the collection of multi-media samples including air, surface water, groundwater, fish, sediment, and vegetation. The samples are analyzed fo r beta and gamma-emitting radionuclides, tritium, iodine-131, and/or strontium as esta blished in the procedures developed for the REMP. The samples are collected at established locations, identified as stations, so that trends in the data can be monitored.

An annual report is prepared providing a desc ription of the activities performed and the results of the analysis of the samples collected from the various media. The latest report generated was prepared by Station personne l and is entitled Final Monthly Progress Report to Ex elon Nuclear, Radiological En vironmental Monitoring Program -

2005. This report concluded that the operation of the St ation had no adverse radiological impact on the environment. The annual report is submitted to the NRC.

Prior to the cessation of power generation in 1998, surface water samples were collected at the following six locations along Lake Michigan:

Kenosha, Wisconsin (intake located 10 miles north of the Station); Lake County Public Water District (intake located 1.1 miles north of the Station); Waukegan, Illinois (intake located 6 miles south of the Station); North Chicago, Illinois (intake located 10 miles south of the Station);

045 136 (22) Zi on St ati o n 13 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Great Lakes NTS (intake located 13 miles south of the Station); and Lake Forest, Illinois (intake located 16.5 miles south of the Station).

After 1998, surface water samples were collect ed at the following four locations along Lake Michigan:

Kenosha, Wisconsin (intake located 10 miles north of the Station); Lake County Public Water District (intake located 1.1 miles north of the Station); Waukegan, Illinois (intake located 6 miles south of the Station); and Lake Forest, Illinois (intake located 16.5 miles south of the Station).

Lake Michigan surface water data are colle c t e d a s p a r t o f t h e R E M P. T r i t i u m concentrations in surface water samp les from Lake Michigan ranged from non-detect to 660 pCi/L.

3.3.3 DEFUELED SAFETY ANALYSIS REPORT In October 2004, Ex elon updated the Defueled Safety Analysis Report (DSAR). The DSAR discusses the overall adeq uacy of the Station for safety, storing, and handling of fuel and radioactive waste, and to monitor pote ntial radiological effluent release paths.

It provides information on Station and lo cal characteristics such as geography, demography, meteorology, geology, and hydrogeology.

The DSAR states that intermittent liquid effluents from the Station will not affect groundwater supplies in the adjacent area in ex cess of concentrations in 10 CFR 20 due to local drainage patterns, release rates, and specific features of the sources of water supplies.

The DSAR also states that the Station's ra dioactive liquid waste generated is collected, treated and either recycled or discharged.

Discharged liquid wastes are monitored to assure compliance with 10 CFR 20. Radioactiv ity levels should not exceed permissible concentrations at the cooling water outlet in Lake Michigan. The two closest municipal water intakes are the LCPWD (approx imately 1 mile north) and the Waukegan Waterworks (approx imately 6 miles south).

The February 2005 REMP report indicates that there have been no tritium concentratio ns detected in surface water samples at concentrations ex ceeding the lower limit of detection (LLD) of 200 pCi/L.

045 136 (22) Zi on St ati o n 14 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 3.3.4 WISCONSIN DEPARTMENT OF HEALTH AND FAMILY SERVICES MONITORING The Wisconsin Public Health Statutes 254.41 mandates the Department of Health and Family Services (DHFS) to conduct enviro nmental radiation monitoring around the nuclear power facilities that impact Wiscon sin. The Station is included in this monitoring due to its prox imity to th e Wisconsin border. In the 2004 Zion Environmental Radioactivity Survey , the Wisconsin DHFS concluded:

air particulate analysis shows no evidence of influence by the Station on air q u ality; the average yearly exposure of ambient ga mma radiation is at background levels and is comparable to other areas within Wisconsin; the surface water samples showed no unus ual concentrations of gross beta, gross gamma, tritium, and strontium; the gamma isotopic analysis for surface wa ter indicated radioisotopes below their respective minimum detectable concentration; the gamma isotopic analysis on vegetation detected only a small amount of the naturally occurring elements potassium-40 and beryllium-7; the gamma isotopic analysis for soil detected potassium-40 and cesium-137.

These were also detected in previous years and are naturally occurring (potassium-40) or attributable to fallout from previous atmospheric nuclear tests (cesium-137); and doses of radiation as a result of gaseous and liq uid effluent are less than the limits allowed for an average individual as stated in Federal Regulations.

3.4 IDENTIFIED AREAS FOR FURTHER EVALUATION CRA used the information presented in the ab ove sections along with its understanding of the hydrogeology at the Station to identi fy AFEs, which were a primary consideration in the development of the scope of work in th e Work Plan. The establishment of AFEs is a standard planning practice in hydrogeologic investigations to focus the investigation activities at areas where ther e is the greatest potential for impact to groundwater.

Specifically, AFEs were identified based on these six considerations:

systems evaluations; risk evaluations; review of confirmed and/or potential releases; 045 136 (22) Zi on St ati o n 15 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 review of documents; review of the hydrogeologic conditions; and Station inspection completed on March 22 and 23, 2006.

Prior to CRA completing its analysis and determination of AFEs, Station personnel completed an ex haustive review of all histor ic and current management of systems that may contain potentially radioactively contaminated liq uids. CRA reviewed the systems identified by the Station, which have the potential for the release of radioactively contaminated liq uids to the environment, and groundwater flow at the Station. This evaluation allowed CR A to become familiar with Station operations and potential systems that may impact grou ndwater. CRA then evaluated information concerning historic releases as provided by the Station. This information, along with a review of the results from historic site investigations, was used to refine CRA's understanding of areas likely to have the high est possibility of impacting groundwater.

Where at risk systems or identified historical releases were located in close proximity or were located in areas which could not be evaluated separately, the systems and historical releases were combined into a si ngle AFE. At times, during the Station investigation, separate AFEs were combined into one or were otherwise altered based on additional information and consideration.

This HIR details the AFEs investigated.

Finally, CRA used its understanding of known hydrogeologic conditions (prior to this investigation) to identify AFEs. Groundwate r flow was an important factor in deciding whether to combine systems or historical rele ases into a single AFE or create separate AFEs. For ex ample, groundwater beneath se veral systems that contain radioactively contaminated liq uids that flows toward a common discharge point were likely combined into a single AFE. The AFEs we re created based on known groundwater flow conditions prior to the work completed during this investigation.

Based upon its review of information conc erning confirmed or potential historical releases, historic investigations, and the systems at the Station that have the potential for release of radioactively contaminated liq ui ds to the environment combined with its understanding of groundwater flow at the St ation, CRA has identified four AFEs (see Figure 3.1).

045 136 (22) Zi on St ati o n 16 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 AFE-Zion-1: Main Complex Area This area was identified to evaluate the main area of the facility, which includes the two containment structures, the Fuel Building that contains spent fuel, the Auxiliary Building, and the Turbine Building.

AFE-Zion-2: Unit 1 (Southern) Ab oveground Storage Tank (AST) Area This area was identified to evaluate the qu ality of groundwater in the area around the Unit 1 systems including the primary water storage tank, the secondary condensate tank, oil separator, discharge tunnel, and di scharge outfall. This AFE was established based on information regarding the storage, handling, and historical releases in this area. AFE-Zion-3: Unit 2 (Northern) AST Area This area was identified to evaluate the qu ality of groundwater in the area around the Unit 2 systems including the primary water storage tank, secondary condensate tank, oil separator, discharge tunnel, and discharge ou tfall. This AFE was established based on information regarding the storage, handling, and historical releases in this area.

AFE-Zion-4: Wastewater Treatment Plant Area This area comprises the Wastewater Treatm ent Plant in the northeast corner of the Station. Groundwater monitoring was initiated in this area of the Station to evaluate the wastewater treatment and associated systems.

045 136 (22) Zi on St ati o n 17 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 4.0 F I E L D METHODS The field investigations completed for this HIR were completed in May to July 2006. CRA supervised the installation of monitori ng wells and a staff gauge, and collected samples from the newly-installed monitoring wells and the surface water location. The field investigations were completed in acco rdance with the methodologies presented in the Work Plan (CRA, 2006).

The scope of work presented in the Work Pl an included the installation and sampling of nine permanent monitoring wells and the colle ction of a surface water sample. Based on the concentrations of tritium detected in monitoring well MW-ZN-01S, additional investigative activities were recommended by CRA, and implemented in June and July 2006. The additional investigative tasks included a second round of sampling at MW-ZN-01S and the installation and sampling of two permanent and four temporary monitoring wells. The additional investigat ive activities provided plume delineation and additional hydraulic information cross-gradient and down-gradient of MW-ZN-01S.

The groundwater sampling events undertaken as part of the investigation are:

May 24-26, 2006 sampling of MW-ZN-01S through MW-ZN-09S; June 28, 2006 sampling of MW-ZN-01S (second round); July 17, 2006 sampling of TW-ZN-100 through TW-ZN-103; and July 28, 2006 sampling of MW-ZN-10S and MW-ZN-11S.

4.1 STAFF GAUGE INSTALLATION Figure 4.1 presents the location of the staff ga uge installed as part of this investigation.

CRA installed staff gauge SG-ZN-01, which is a notch in a bridge within the Intake Crib.

The Intake Crib is hydraulically connected to Lake Michigan via the intake tunnel that ex tends approx imately 1/2 mile into Lake Michigan.

4.2 GROUNDWATER MONITORING WELL INSTALLATION Prior to completing any ground penetration activities, CRA completed subsurface utility clearance procedures to minimi ze the potential of injury to workers and/or damage to subsurface utility structures. The subsur face clearance procedures consisted of completing an electronic survey within a mi nimum of 10-foot radius of the proposed location utilizing electromagnetic and gr ound penetrating radar technology.

045 136 (22) Zi on St ati o n 18 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Additionally, a vacuum soft dig was used to verify utilities were not present at the proposed location to a depth to 10 feet bgs.

Fifteen new monitoring wells were inst alled for the fleetwide hydrogeologic investigation, including 11 permanent and 4 temporary monitoring wells.

Monitoring well construction logs are provided in Appendix B. Figure 4.1 presents the location of the 15 new monitoring wells. These locations we re selected based on a review of all data provided, the hydrogeology at the Station, and current understanding of identified AFEs, and modified based on conditions encountered during the investigation.

Table 4.1 summarizes the well installation details.

Specific installation protocols for the perm anent monitoring wells are described below:

the borehole was advanced to the target depth using 4.25-inch inside diameter hollow-stem augers (HSA); a nominal 2-inch diameter (No.

10 slot) PVC screen, 10 or 20 feet in length, attached to a sufficient length of 2-inch diameter sc hedule 40 PVC riser pipe to extend to the surface, was placed into the borehole through the augers; a filter sand pack consisting of silica sand was installed to a minimum height of 2 feet above the top of the screen as the augers were removed; a minimum 2-foot thick seal consisting of 3/8-inch diameter bentonite pellets or chips was placed on top of the sand pack and hydrated using potable water; the remaining borehole annulus was sealed to within 3 feet of the surface using pure bentonite chips (the soft-dig portion of th e borehole was backfilled with a mixture of soil and bentonite); and the remaining portion of the annulus was fille d with concrete and a 6-inch diameter protective above-grade casing. The well he ad was fitted with a water-tight lockable cap. Specific installation protocols for the temp orary monitoring wells are described below:

the borehole was advanced to the target de pth using a 2-inch direct push technology (DPT) drill rig; a nominal 1-inch diameter (No.

10 slot) PVC screen, 15 or 20 feet in length, attached to a sufficient length of 1-inch diameter sc hedule 40 PVC riser pipe to extend to the surface, was placed into the borehole through the DPT casing; a filter sand pack consisting of silica sand was installed to a minimum height of 2 feet above the top of the screen as the augers were removed; 045 136 (22) Zi on St ati o n 19 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 a minimum 2-foot thick seal consisting of bentonite powder was placed on top of the sand pack; and the remaining borehole annulus was sealed at the surface using bentonite powder or chips. The shallow soil borings completed in unconsolid ated materials that were to be used for monitoring well installation were installed us ing either DPT or 4.25-inch inside diameter HSA drilling techniques. The borehole depths r anged from 19 to 45 feet bgs. During the subsurface utility clearance activities descri bed above, the borehole was periodically ex amined and the soil types documented. A description was added to each monitoring well construction log. The overburden so ils were classified using the Unified Soil Classification System (USCS).

4.3 GROUNDWATER MONITORING WELL DEVELOPMENT To establish good hydraulic communication wi th the aquifer and reduce the volume of sediment in the permanent monitoring wells, well development was conducted in accordance with the procedure outlined below:

monitoring wells were surged using a pre-cleaned bailer for a period of at least 5 minutes; a minimum of one well volume of water was purged using a submersible pump; the monitoring well was surged for 5 minutes again; water was purged from the monitoring well using an electric submersible pump; groundwater was collected at regular in tervals and the pH, temperature, and conductivity were measured using field instruments. These instruments were calibrated daily according to the manufact urer's specifications. Additionally, observations such as color, odor, and turb idity of the purged water were recorded; and development continued until the turbidity and silt content of the monitoring wells were significantly reduced and three consis tent readings of pH, temperature, and conductivity were recorded, or a mi nimum of ten well volumes was purged.

A summary of the monitoring well developm ent parameter measurements is presented in Table 4.2.

045 136 (22) Zi on St ati o n 20 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 4.4 S U R V E Y The 15 monitoring wells and surface water ga uge were surveyed to establish reference elevations relative to mean sea level.

The top of each well casing was surveyed to the nearest 0.01 foot relative to the National Geodetic Vertical Datum (NGVD), and the survey point was marked on the well casing. The survey included the ground elevation at each well to the nearest 0.10 foot relative to the NGVD, and the horizontal well location to the nearest 1.0 foot. A reference point was also marked on the concrete at the surface water elevation measuring location.

The Lake Michigan shoreline was surveyed at the Station using a handheld Global Positioning System (GPS) with an estimated a ccuracy of +/- 12 feet. The GPS survey was conducted on June 30, 2006.

4.5 GROUNDWATER AND SURFACE WATER ELEVATION MEASUREMENTS On May 23, 2006 and July 27, 2006, CRA collected water level measurements from the monitoring wells and the staff gauge at the Station in accordance with the Work Plan.

Based on the measured depth to water from the reference point and the surveyed elevation of the reference point, the gr oundwater or surface water elevation was calculated.

A summary of groundwater and surface water elevations is provided in Table 4.3.

Prior to the water level measurements, the we lls and staff gauges were identified and located. Once the wells were identified, CR A completed a thorough inspection of each well and noted any deficiencies. Water le vel measurements were collected using an electronic depth-to-water probe accurate to 0.01 foot. The measurements were made from the designated location on the inner ri ser or steel casing of each monitoring well and reference point on the staff gauge.

Th e water level measurements were obtained using the following procedures:

the proper elevation of the meter was chec ked by inserting the tip into water and noting if the contact was registering correctly; the tip was dried, and then slowly lowere d into the well or surface water body until contact with the water was indicated; the tip was slowly raised until the light and/or buzzer just began to activate. This indicated the static water level; 045 136 (22) Zi on St ati o n 21 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 the reading at the reference point was noted to the nearest hundredth of a foot; the reading was then re-checked; and the water level was then recorded, and th e water level meter decontaminated prior to use at the next location.

Surface water measurements for Lake Mich igan were obtained from the National Oceanic and Atmospheric Administration (N OAA) gauging stations at Milwaukee, Wisconsin (Station 9087057), and Calumet Harb or, Illinois (Station 9087044) for the date and time when the water levels in monitoring wells were measured (NOAA, 2006).

Station Time Period Median Lake Elevation 9087057 Milwaukee May 23, 2006 8:00-13:00 577.99 9087044 Calumet Harbor May 23, 2006 8:00-13:00 577.94 May 23, 2006 8:00-13:00 Average 577.97 9087057 Milwaukee July 27, 2006 9:15-11:10 577.91 9087044 Calumet Harbor July 27, 2006 9:15-11:10 577.96 July 27, 2006 9:15-11:10 Average 577.93 4.6 GROUNDWATER AND SURFACE WATER SAMPLE COLLECTION CRA conducted one round of groundwater sampling during the hydrogeologic investigation, with additional samples collected from monitoring well MW-ZN-01S.

A total of 15 monitoring wells were sampled between May 24, 2006 and July 28, 2006.

Eleven new permanent monitoring wells were installed. The sampling was scheduled to allow for 2 weeks to elapse between well development and groundwater sample collection. Four temporary monitoring wells were installed and sampled in July 2006.

At the monitoring well locations, CRA cond ucted the sampling using peristaltic pumps and dedicated polyethylene tubing to employ low flow purging techniques, as described in Puls and Barcelona (1996).

For permanent monitoring wells with 20-foot screen lengths (MW-ZN-01S through MW-ZN-08S, MW-ZN-10S and MW-ZN-11S), separate samples were collected from the lower portion and the upper portion of th e screened interval. The lower sampling interval targets potential releases from deep structural features such as the basement of the Auxiliary Building. The upper sampling in terval targets potential surface and near surface releases such as spills fr om the primary cooling water ASTs.

045 136 (22) Zi on St ati o n 22 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 The groundwater in the monitoring wells was sampled by the following low-flow procedures:

the wells were located and the well id entification numbers were verified; a water level measurement was taken; the well was sounded by carefully lowering the water level tape to the bottom of the well (so as to minimize penetration and disturbance of the well bottom sediment), and comparing the sounded depth to the installed depth to assess the presence of any excess sediment or drill cuttings; the pump or tubing was lowered slowly into the well and fix e d into place such that the intake was located at the mid-point of the well screen, or a minimum of 2 feet above the well bottom/sediment level; the purging was conducted using a pump ing rate between 100 to 500 milliliters per minute. Initial purging began using the lo wer end of this range. The groundwater level was monitored to ensure that a drawdown of less than 0.3 foot occurred. If this criterion was met, the pumping rate was in creased dependent on the behavior of the well. During purging, the pumping rate and groundwater level were measured and recorded approximately every 10 minutes; the field parameters [pH, temperature, co nductivity, ox idation-reduction potential (ORP), dissolved oxygen (DO), and turbidity]

were monitored during the purging to evaluate the stabilization of the purged gr oundwater. Stabilization was considered to be achieved when three consecutive readings for each parameter, taken at 5-minute intervals, were within the following limits:

pH 0.1 pH units of the average value of the three readings, Temperature 3 percent of the average value of the three readings, Conductivity 0.005 milliSiemen per centimeter (mS/cm) of the average value of the three readings for conductivity <1 mS/cm and 0.01 mS/cm of the average value of the three readings for conductivity >1 mS/cm, ORP 10 millivolts (mV) of the average value of the three readings, DO 10 percent of the average value of the three readings, and Turbidity 10 percent of the average value of the three readings, or a final value of less than 5 nephelometric turbidity units (NTUs); once purging was complete, the groundwate r samples were collected directly from the pump/tubing directly into the sample containers; and 045 136 (22) Zi on St ati o n 23 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 in the event that the groundwater recharge to the monitoring well was insufficient to conduct the low-flow procedure, the well was pumped dry and allowed to sufficiently recharge prior to sampling.

All groundwater samples were labeled with a uniq ue sample number, the date and time, the parameters to be analyzed, the job number , and the sampler's initials. The samples were then screened by the Station for sh ipment to Teledyne Brown Engineering Inc. (Teledyne Brown).

A sample key is presented in Table 4.4; field measurements for the hydrogeologic investigation are presented in Table 4.5.

CRA containerized the water purged from the monitoring wells during the sampling, as well as the water purged from all of the wells during the hydrogeologic investigation.

The water was placed into 55-gallon drums, which will be processed by the Station in accordance with its NPDES permit.

One surface water sample was collected on May 26, 2006 from Lake Michigan at station SW-ZN-1, adjacent to the Station.

The surf ace water sampling location is presented on Figure 4.1.

The surface water sample was collected by di rectly filling the sample container from the composite sampler at the determined location until completely filled. A sample key is presented in Table 4.4.

4.7 DATA QUALITY OBJECTIVES CRA has validated the analytical data to esta blish the accuracy and completeness of the data reported. Teledyne Brown provided the analytical services.

The Quality Assurance Program for the laboratory is described in Appendix C. Analytical data for groundwater and surface water samples collect ed in accordance with the Work Plan are presented in Appendix D. Data validation reports are presented in Appendix E. The data validation included the following information and evaluations:

sample preservation; sample holding times; laboratory method blanks; laboratory control samples; 045 136 (22) Zi on St ati o n 24 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 laboratory duplicates; verification of laboratory qualifiers; and field q u ality control (field blanks and duplicates).

Following the completion of field activiti es, CRA compiled and reviewed the geologic, hydrogeologic, and analytical data.

The data were reviewed using the following techniques:

data tables and databox figures; hydrogeologic cross-sections; and hydraulic analyses.

4.8 S A M P L E IDENTIFICATION Systematic sample identification codes were us ed to uniquely identify all samples. The identification code format used in the field was:

WG - Zion -

MW-8L - 052406 - MS - 001. A summary of sample identifica tion numbers is presented in Table 4.4.

WG - Sample matrix -groundwater WS - Sample matrix - surface water Zion - Station code ZN - Station code MW-8L - Well location 052406 - Date MS - Sampler initial 001 - Sample number 4.9 C H A I N-O F-C U S T O D Y RECORD The samples were delivered to Station pe rsonnel under chain-of-custody protocol.

Subseq uently, the Station shipped the samp les under chain-of-custody protocol to Teledyne Brown for analyses.

045 136 (22) Zi on St ati o n 25 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 4.10 QUALITY CONTROL SAMPLES Quality control samples were collected to evaluate the sampling and analysis process.

Field Duplicates Field duplicates were collected to verify th e accuracy of the analytical laboratory by providing two samples collected at the same location and then comparing the analytical results for consistency.

Field duplicate sa mples were collected at a freq uency of one duplicate for every ten samples collected. A total of three duplicate samples were collected.

The locations of duplicate sample s were selected in the field during the performance of sample collection activities. The duplicate samples were collected simultaneously with the actual sample and were analyzed for the same parameters as the actual samples.

Split Samples Split samples from permanent monitoring wells and surface water were collected for the NRC for tritium simultaneously wi th the actual sample at every sample location. Split samples were delivered to the Station personne l and (if req u ested) made available to the NRC. Split samples from the temporary monito ring wells were collected directly by the N R C a n d t h e I l l i n o i s E m e r g e n c y M a n a g e m e n t A g e n c y (I E M A). 4.1 1 A N ALYSES Groundwater and surface water samples were analyzed for tritium and gamma-emitting radionuclides as listed in NUREG-1301, and strontium-89/90 as listed 40 CFR 141.25.

045 136 (22) Zi on St ati o n 26 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 5.0 R E S U L T S

SUMMARY

This section provides a summary of Statio n-specific geology and hydrogeology, along with a discussion of hydraulic gradients, groundwater elevations, and flow directions in the vicinity of the Station. This section al so presents and evaluate s the analytical results obtained from activities performed in accordance with the Work Plan.

5.1 S T A T I O N GEOLOGY Geologic cross-sections in both a south-nort h and east-west profile have been developed.

Figure 5.1 displays the cross-section locati ons across the Station and the cross-sections are provided on Figures 5.2 and 5.3. These cross-section locations were chosen because of their close proximity to the AFEs and st ructures potentially influencing groundwater flow patterns.

The Station is underlain by overburden deposi ts and a regionally ex tensive seq u ence of consolidated sedimentary deposits as discusse d in Section 2.4.3. In descending order, the following overburden stratigraphic unit s have been identified and characterized during the various Station investigations:

Upper Sand Unit:

Dense to very dense gr anular soils which range in gradation from very fine sand to fine to coarse sand, and which contains some gravel and occasional cobbles and boulders.

Depth ranges from the ground surface to an elevation of approx imately 555 feet AMSL. Silt-Clay Unit:

Hard silt, silty clay, clay ey silt, and sandy silt, which contain some sand and gravel and occasional cobbles and boulders. Depth ranges from approx imately 525 feet to 555 feet AMSL. Lower Sand Unit:

Dense to very dense sands and silty sands which contain some gravel, occasional cobbles and boulders, and layers of hard silty clay, clayey silt, and sandy silt. Depth ranges from approx imately 480 feet to 525 feet AMSL (ComEd, 1969).

The Upper Sand Unit includes the surficial deposits of the Zion beach-ridge plain and consists of sand and gravel of the Lake Michigan Formation. The Lake Michigan Formation describes Holocene shallow-water, near-shore beach sediments predominantly consisting of medium-grained sand with local lenses of sandy gravel, and containing beds of silt.

045 136 (22) Zi on St ati o n 27 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 The Silt-Clay Unit is consistent with qu iet water lacustrine deposits and may be associated with post-glacial La ke Michigan (Nipissing Phase).

The Lower Sand Unit is consistent with re curring seq u ences of beach and q u iet water lacustrine deposits and may be associated wi th the extreme Lake level fluctuations. As Lake levels rose, beach deposits moved west ward with the shoreline and were followed by quiet water silt and clay deposits (a transgr essive sequence).

As Lake levels fell, the beach moved eastward with the shoreline (a regressive seq u ence). The overburden sediments are underlain by Silurian carbonate bedrock of the Niagaran Series, which was encountered at depths ranging from 102 to 116 feet bgs (ComEd, 1969). In northeastern Illinois the Niagaran Series includes the Racine, Sugar Run, and Joliet Formations (Willman et al., 1975). Below the Silurian carbonates lie Pre-Cambrian through Ordovici an sedimentary rocks, including shales, carbonates, and sandstone.

Crystalline basement rock is located at a depth of approximately 2,500 feet. The sedimentary bedrock strata are generally horizontal with a gentle dip to the east (Visocky et al., 1985).

Some of the Station structures are constructe d to depths of approx imately 60 feet bgs. Excavations were completed from grade, th rough the Upper Sand Unit and into the topmost portion of the Silt-Clay Unit. Ex cavated sands were stockpiled during the construction and used as backfill (Exelon, 2004), and are considered to be hydraulically similar to the Upper Sand Unit.

The fifteen new monitoring wells (MW-ZN-01S, MW-ZN-02S, MW-ZN-03S, MW-ZN-04S, MW-ZN-05S, MW-ZN-06S, MW-ZN-07S, MW-ZN-08S, MW-ZN-09S, MW-ZN-10S, MW-ZN-11S, TW-ZN-100, TW-ZN-101, TW-ZN-102, and TW-ZN-103) were installed within the Upper Sand Unit or fill, which consists of a primarily fine-grained sand that overlies the Silt-Cla y Unit. The monitoring well logs wells are presented in Appendix B.

Cross-Section A-A' (Figure 5.2) is a north-south profile through the east side of the Station. It begins at monitoring well MW-ZN-08S and terminates at MW-ZN-05S.

This cross-section transects AFE-Zion-2, AFE-Zion-3 , and AFE-Zion-4. This cross-section also shows the relationship between the groundwa ter and the geology, ex cavated areas, and reactor containment and building foundations.

Cross-Section B-B' (Figure 5.3) is an west-e ast profile that runs from monitoring well MW-ZN-07 through the Station to Lake Michigan and intersects AFE-Zion-1 and 045 136 (22) Zi on St ati o n 28 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 AFE-Zion-3.

This cross-section shows the relationship between the groundwater and geology, and building foundations.

5.2 S T A T I O N HYDROGEOLOGY This section presents the Station hydrogeolo gy, including groundwater flow direction, man-made influences on groundwater flow, vertical hydraulic gradients, and lateral groundwater flow and velocity.

5.2.1 GROUNDWATER FLOW DIRECTIONS The shallow groundwater flows to the east toward Lake Michigan. The building foundations restrict the groundwater flow , which causes the groundwater to flow around the Station. As mentioned previous ly, the shallow water table intercepts the stormwater drainage ditches in the west area of the Station property, but does appear to affect the flow of groundwater to the east and toward Lake Michigan.

Groundwater flow directions for May 2006 are provided on Fi gure 5.4, flow directions for July 2006 are provided on Figure 5.5. Both figures present groundwater flow in the shallow groundwater system. The sheet pile wall lim its the flow of groundwater towards Lake Michigan. Groundwater between the sheet p ile wall and the Turbine Building flows to the north or south around the wall. Althou gh groundwater flow circumscribes the sheet pile wall, a small component of leakage through the wall is expected.

The sheet pile wall is constructed of MZ-27 steel sheet piling. MZ-27 sheet piling is comprised of z-shaped sheet steel sections which are 18-inches wide with a 12-inch offset. The sections are 45 feet long, 3/8-inch thick, and weigh 27 pounds per sq uare foot of wall.

5.2.2 MAN-MADE INFLUENCES ON GROUNDWATER FLOW The building foundations of the main comple x ex tend through the Upper Sand Unit and into the top of the underlying silts and cl ays. Deep structures include the Reactor Containment Buildings, the Fuel Storage Bu ilding, the Auxiliary Building, the Turbine Building, and the crib area. The deep build ing foundations act as hydraulic barriers for shallow groundwater as is discussed below.

045 136 (22) Zi on St ati o n 29 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 During the construction of the Station, a sheet pile wall was installed along the Lake Michigan shoreline to prevent lake water from entering the excavation. The sheet pile wall was modified over the course of the co nstruction and currently ex tends to a depth of approximately 45 feet bgs. The top of th e sheet pile wall is lined with boulders and forms a breakwall, which is shown on Figure 5.3.

Shallow groundwater will flow into the stormw ater drainage ditches located on the west portion of the Station property. However, the groundwater in this area is upgradient of the PA and areas within the Station that potent ially contain tritiated water. As such the groundwater discharge to these stormwater sy stems is not expected to be impacted by tritium. 5.2.3 VERTICAL HYDRAULIC GRADIENTS The Upper Sand Unit is a high permeability unit that is directly connected to Lake Michigan, which is a regional discharge feature, and which generally allows unrestricted lateral groundwater flow. Vertical ground water flow is limited by the underlying Silt-Clay Unit, which has a low permeability and is approximately 30 feet thick.

To the ex tent that vertical flow can occur, the vertic al gradient is ex pected to be upward based on the artesian pressure observed in the Lower Sand Unit during the 1967 Foundation Investigation (Dames and Moore, 1967).

5.2.4 LATERAL GROUNDWATER FLOW AND VELOCITY Fifteen monitoring wells were installed at the Station as part of the 2006 hydrogeologic investigation.

Shallow groundwater is present at a depth less than 12 feet bgs in the Upper Sand Unit. The shallow water-bearin g zone is isolated from the underlying regional bedrock aquifers by the underlying Silt-Clay Unit. The Silt-Clay Unit is approx imately 30 feet thick and ex tends approximately 15 feet below the deepest structural feature at the Station.

Shallow groundwater flows is generally to wards Lake Michigan. A potentiometric surface contour map is provided on Figure 5.4 (May 2006) and Figure 5.5 (July 2006).

The hydraulic gradient ranges from 0.001 feet per foot near the switchyard (west of the Station) to 0.008 feet per foot near the eastern portion of the Station. The hydraulic conductivity of the surficial sands is expect ed to be approximately 12 feet per day based on the median measurement from a study cond ucted along the Illinois-Indiana border of the shallow aq uifer along Lake Michigan (USGS, 1996). The velocity of the shallow 045 136 (22) Zi on St ati o n 30 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 groundwater may be roughly approx imated using the Station-specific hydraulic gradient with the literature value for hydr aulic conductivity and a typical value for porosity. Using the hydraulic gradient r ange of 0.001 to 0.008 feet per foot with a hydraulic conductivity of 12 feet per day and an assumed porosity of 0.32 yields a velocity range of 14 to 110 feet per year (USEPA, 1996).

5.3 G R O U N D W A T E R QUALITY CRA personnel collected groundwater sample s from fifteen wells. The samples were analyzed for tritium and additional radi onuclides. Teledyne Brown provided the analytical services. The Qua lity Assurance Program for the laboratory is described in Appendix C. The analytical data reports are provided in Appendix D. The analytical data presented herein have been subjected to CRA's data validation process. CRA has used the data with appropriate qualifiers where necessary.

The data reported in the figures and tables do not include the results of recounts that the laboratory completed, except if those result s ultimately replaced an initial report. The tables and figures, therefore, include only th e first analysis reported by the laboratory.

Where multiple samples were collected over ti me, then the most recent result has been used in the discussion, below.

Two samples were collected from two di fferent elevations in each permanent monitoring well ex cept for monitoring well MW-ZN-09S. The samples were collected at 16 feet above the well bottom for the upper sample and 3 feet above the well bottom for the lower sample. At monitoring well MW-Z N-09S there was not a sufficient depth of water for both samples to be collected and a single sample at MW-ZN-09S was collected at 3 feet above the well bottom, which is the eq uivalent of an upper sample in the other monitoring wells.

5.3.1

SUMMARY

OF BETA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS A summary of the tritium results for the gr oundwater samples collected during this investigation is provided in Table 5.1 and shown on Figure 5.6.

Groundwater samples were collected from the upper and lower portions of the screen in each monitoring well with a 20-foot screen (MW-ZN-01S through MW-ZN-11S with the 045 136 (22) Zi on St ati o n 31 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 ex ception of MW-ZN-09S). Groundwater samp les were also collected from Temporary Wells (TW-ZN-100 through TW-ZN-103). All tritium concentrations were below the USEPA drinking water standard of 20,000 pCi/L. Tritium was not detected greater than the LLD of 200 pCi/L in samples collected from 14 of the 15 monitoring wells.

Concentrations of tritium ex ceeding the LLD of 200 pCi/L were only detected in groundwater samples collected from monito ring well MW-ZN-01S. The concentrations of tritium detected in the initial round of sampling were 586 141 pCi/L in the lower portion of the screen and 261 124 pCi/L in the upper portion of the screen.

MW-ZN-01S was re-sampled on June 28, 2006 and the concentrations of tritium were less than the LLD of 200 pCi/L in the lower portion of the screen and 220 pCi/L in the upper portion of the screen.

Strontium-89/90 was not detected at concentrations ex ceeding the LLD of 2.0 pCi/L. A summary of the strontium-89/90 results for the groundwater samples collected as part of the investigation that is the subject of th is HIR is provided in Table 5.2 and shown on Figure 5.7.

5.3.2

SUMMARY

OF GAMMA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS Gamma-emitting target radionuclides were no t detected at concentration greater than their respective LLD. A summary of the ga mma-emitting radionuclides results for the groundwater samples collected as part of the in vestigation that is the subject of this HIR is provided in Table 5.2 and pres ented graphically on Figure 5.7.

Other non-targeted radionuclides are incl uded in the tables but excluded from discussion in this report.

These radionuclid es were either a) naturally occurring and thus not produced by the Station, or b) coul d be definitively evaluated as being naturally occurring due to the lack of presence of other radionuclides, which would otherwise indicate the potential of production from the Station.

5.3.3

SUMMARY

OF FIELD MEASUREMENTS Table 4.5 presents a summary of monitoring well purging parameters collected during the well purging and sampling activities.

These field measurements included pH, dissolved oxygen, conductivity, turbidity, and temperature. The field parameters were typical of a shallow sand aq uifer. The pH values ranged from 5.51 standard units to 045 136 (22) Zi on St ati o n 32 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 10.42 standard units. The conductivity was indicative of a shallow water table system subject to surface water recharge.

Of note were the elevated turbidity read ings above 900 NTU collected from the lower portion of the screen at MW-ZN-04S; howeve r, the elevated turbidity readings are indicative of the very loose and fine-grained organic material at this well's lower screen interval, as shown on the MW-ZN-04S stratigr aphic log. Overall, the readings were within the ex pected ranges for naturally occurring groundwater.

5.4 SURFACE WATER QUALITY One surface water sample was collected from Lake Michigan at the location shown on Figure 4.1. This sample was analyzed fo r tritium, gamma-emitting radionuclides, and strontium-89/90. Teledyne Brown provided the analytical services. The Quality Assurance Program for the laboratory is desc ribed in Appendix C. The analytical data reports are provided in Appendix D.

5.4.1 S U M M A R Y O F B E T A-E M I T T I N G R A D I O N U C L I D E ANALYTICAL RESULTS Tritium was not detected at concentrations ex ceeding the LLD of 200 pCi/L. A summary of the tritium result for the surface water sample collected in this investigation is provided in Table 5.1 and shown on Figure 5.6.

Strontium-89/90 was not detected at concentrat ion exceeding the LLD of 2.0 pCi/L. The strontium-89/90 result for the surface water sa mple collected in this investigation is provided in Table 5.2 and shown on Figure 5.7.

5.4.2

SUMMARY

OF GAMMA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS Gamma-emitting target radionuclides were not detected at concentration exceeding their respective LLD. A summary of the gamma-emi tting radionuclides results for the surface water sample collected in th is investigation is provided in Table 5.2 and shown on Figure 5.7.

Other non-targeted radionuclides are incl uded in the tables but excluded from discussion in this report.

These radionuclid es were either a) naturally occurring and 045 136 (22) Zi on St ati o n 33 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 thus not produced by the Station, or b) coul d be definitively evaluated as being naturally occurring due to the lack of presence of other radionuclides which would otherwise indicate the potential of production from the Station.

045 136 (22) Zi on St ati o n 34 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 6.0 RADIONUCLIDES OF CONCERN AND SOURCE AREAS This section discusses radionuclides evaluated in this investigation, potential sources of the radionuclides detected, and their distribution.

6.1 G A M M A-E M I T T I N G RADIONUCLIDES Gamma-emitting target radionuclides were not detected at concentration exceeding their respective LLD. Other non-targeted radionuclid es were also included in the tables but excluded from discussion in this report. These radionuclides were either a) naturally occurring and thus not produced by the Station, or b) could be definitively evaluated as being naturally occurring due to the lack of presence of other radionuclides which would otherwise indicate the potentia l of production from the Station.

6.2 B E T A-E M I T T I N G RADIONUCLIDES Strontium-89/90 was not detected in any of the samples collected at concentrations that were greater than the LLD of 2.0 pCi/L. Tritium was detected in one of the six t een total sample locations.

Concentrations of tr itium ranged between less than the LLD of 200 pCi/L to 586 141 pCi/L.

Since only tritium was detected above the radionuclides' LLDs, the following sections focus on tritium; specifically, providing ge neral characteristics of tritium, potential sources, distribution in groundwater, and a conceptual model for migration.

6.3 T R I T I U M This section discusses the general characteristic s of tritium, the distribution of tritium in groundwater and surface water, and the co nceptual model of tritium release and migration.

6.3.1 G E N E RAL CH ARACTERISTICS Tritium (chemical symbol H-3) is a radioact ive isotope of hydrogen. The most common forms of tritium are tritium gas and tritium oxide, which is also called "tritiated water." The chemical properties of tritium are essent ially those of ordinary hydrogen. Tritiated 045 136 (22) Zi on St ati o n 35 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 water behaves the same as ordinary water in both the environment and the body.

Tritium can be taken into the body by drinki ng water, breathing air, eating food, or absorption through skin. Once tritium ente rs the body, it disperses quickly and is uniformly distributed throughout the body.

Tritium is excreted primarily through urine within a month or so after ingestion. Or ganically bound tritium (tritium that is incorporated in organic compounds) can remain in the body for a longer period.

Tritium is produced naturally in the uppe r atmosphere when cosmic rays strike air molecules. Tritium is also produced during nuclear weapons ex plosions, as a by-product in reactors producing electricity, and in special production reactors, where the isotopes lithium-7 and/or boron-10 are bombarded to produce tritium.

Although tritium can be a gas, its most common form is in water because, like non-radioactive hydrogen, radioactive tritiu m reacts with oxygen to form water. Tritium replaces one of the stable hydrogen atoms in the water molecule and is called tritiated water. Like normal water, tritiate d water is colorless and odorless. Tritiated water behaves chemically and physically like non-tritiated water in the subsurface, and therefore tritiated water will travel at the same velocity as the average groundwater velocity.

Tritium has a half-life of approx imately 12.3 ye ars. It decays spontaneously to helium-3 (3 He). This radioactive decay releases a be ta particle (low-energy electron). The radioactivity of tritium is the so urce of the risk of exposure.

Tritium is one of the least dangerous radionuc lides because it emits very weak radiation and leaves the body relatively quickly. Since tritium is almost always found as water, it goes directly into soft tissues and organs. The associated dose to these tissues is generally uniform and is dependent on the water content of the specific tissue.

6.3.2 DISTRIBUTION IN STATION GROUNDWATER This section provides an overview of the la teral and vertical distribution of tritium detected in groundwater at the Station.

Tritium was detected in groundwater at concentrations ex ceeding the LLD of 200 pCi/L.

Tritium concentrations in groundwater are pr esented on Figure 5.6. Tritium was only detected in groundwater samples from mo nitoring well MW-ZN-01S in May 2006 from both the upper sampling interval (261 124 pCi/L, 22 feet bgs) and the lower sampling interval (586 141 pCi/L, 35 feet bgs). Tritium was only detected in groundwater 045 136 (22) Zi on St ati o n 36 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 samples from monitoring well MW-ZN-01S in June 2006 in the upper sampling interval (220 123 pCi/L, 22 feet bgs). Tritium was not detected above the LLD of 200 pCi/L in June 2006 at the MW-ZN-01S lower sampling interval.

6.3.3 CONCEPTUAL MODEL OF TRITIUM RELEASE AND MIGRATION This Section presents CRA's conceptual mode l of groundwater and tritium migration at the Station.

A conceptual model of groundwater and trit ium migration is provided herein.

This model is then used to discuss the recent detections of tritium observed during the hydrogeologic investigations presented in this HIR.

Groundwater flows within the Upper Sand Un it at the Station in response to the regional discharge point located to the east of the Station (Lake Michigan).

Groundwater moving within the Upper Sand Unit is separated from the regional bedrock aquifer zones by the underlyi n g l o w-p e r m e a b i l i t y S i l t-C l a y U n i t. Groundwater in the Upper Sand Unit generally flows to the east and discharges to Lake Michigan. Groundwater flowing in Upper Sand Unit is affected by the building foundations which, in some cases, extend into the underlying glacial silts and clays. The sheet pile wall also limits the flow of ground water towards Lake Michigan. There is no indication from the HIR investigation that tritium-impacted groundwater is migrating off the Station property.

6.3.4 ATTENUATION OF TRITIUM WITHIN THE SHALLOW GROUNDWATER SYSTEM Tritium in the groundwater system would be affected by the infiltration from precipitation recharge. This could result in the upper water table zone of the sand aq uifer having lower concentrations of trit ium than deeper portions (these upper and lower zones are only separated by 10 feet).

The permeable nature of the Upper Sand Unit also supports attenuation of the tritium through lateral groundwater movement. The dispersion of the tritium as it flows through the Upper Sand Unit along with its natural decay rate will allow for reduction in concentrations over time and with dist ance from a release into the groundwater.

045 136 (22) Zi on St ati o n 37 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Tritium was not detected at concentrations ex ceeding the LLD of 200 pCi/L in the four temporary wells located downgradient of MW-ZN-01S and in surface water sample collected from Lake Michigan, which is the ultimate receptor of groundwater discharge from the Station. There is no indica tion from the HIR investigation that tritium-impacted groundwater is mi grating off the Station property.

045 136 (22) Zi on St ati o n 38 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 7.0 EXPOSURE PATHWAY ASSESSMENT This section addresses the groundwater impact s from tritium and other radionuclides at the Station and potential risks to human health and the environment.

Based upon historical knowledge and data re lated to the Station operations, and based upon radionuclide analyses of groundwater sa mples, the primary constituent of concern (COC) is tritium. The discussions that follo w are restricted to the exposure pathways related to tritium.

Teledyne Brown reports all samples to their statistically derived minimum detectable concentration (MDC) of approx imately 150 to 170 pCi/L, which is associated with 95 percent confidence interval on their hardcop y reports. However, the laboratory uses a 99 percent confidence range ( 3-sigma) for determining whether to report the sample activity concentration as detected or not.

This 3-sigma confidence range typically eq uates to 150 (+/-

135.75) pCi/L.

Ex elon has specified a LLD of 200 pCi/L for the Fleetwide assessment. Ex elon has also required the laboratory to report related pe aks identified at the 95 percent confidence level (2-sigma).

This HIR, therefore, screens and assesses data using Ex elon's LLD of 200 pCi/L. As is outlined below, this concentration is also a reasonable approx imation of the background concentration of tritium in groundwater at the Station.

7.1 HEALTH EFFECTS OF TRITIUM Tritium is a radionuclide that decays by emi tting a low-energy beta particle that cannot penetrate deeply into tissue or travel far in air. A person's exposure to tritium is primarily through the ingestion of water (d rinking water) or through ingestion of water-bearing food products. Inhalation of tr itium req u ires the water to be in a vapor form (i.e., through evaporation or vaporizatio n due to heating). Inhalation is a minor exposure route when compared to direct in gestion or drinking of tritiated water.

Absorption of tritium through skin is possible, but tritium exposure is more limited here versus direct ingestion or drinking of tritiated water.

045 136 (22) Zi on St ati o n 39 C ONESTOGA-R OVERS & A SSOCIATES Revision 1

7.2 BACKGROUND

CONCENTRATIONS OF TRITIUM The purpose of the following paragraphs is to establish a background concentration through review of various media.

7.2.1 G R O U N D W A T E R Tritium is created in the environment from naturally occurring processes both cosmic and subterranean, as well as from anthropogen ic (i.e., man-made) sources. In the upper atmosphere, "cosmogenic" tritium is produced from the bombardment of stable nuclides and combines with oxygen to form tritiated water, which will then enter the hydrologic cycle. Below ground, "lithogenic" tritium is produced by the bombardment of natural lithium isotopes 6 Li (92.5% abundance) and 7 Li (7.5% abundance) present in crystalline rocks by neutrons produced by the radi oactive decay of uranium and thorium. Lithogenic production of tritium is usually negligible compared to other sources due to the limited abundance of lithium in rock. The lithogenic tritium is introduced directly to groundwater.

A major anthropogenic source of tritium come s from the former atmospheric testing of thermonuclear weapons. Levels of tritium in precipitation increased during the 1950s and early 1960s, coinciding with the release of significant amounts of tritium to the atmosphere during nuclear weapons testing pr ior to the signing of the Limited Test Ban Treaty in 1963, which prohibited atmospheric nuclear tests.

7.2.2 P R E C I P I T A T I O N D A TA Precipitation samples are routinely collected at stations around the world for the analysis of tritium and other radionuclides.

Two publicly available databases that provided tritium concentrations in precipit ation are Global Network of Isotopes in Precipitation (GNIP) and USEPA's RadNet database. GNIP provides tritium precipitation concentration data for sample s collected world wide from 1960 to 2006.

RadNet provides tritium precipitation conc entration data for samples collected at Stations through the U.S. from 1960 up to and including 2006.

Based on GNIP data for sample stations loca ted in the U.S.

Midwest including Chicago, St. Louis and Madison, Wisconsin, as well as Ottawa, Ontario, and data from the University of Chicago, tritium concentratio ns peaked around 1963. This peak, which approached 10,000 pCi/L for some stations, coincided with the atmospheric testing of 045 136 (22) Zi on St ati o n 40 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 thermonuclear weapons.

Tritium concentrat ions showed a sharp decline up until 1975 followed by a gradual decline since that ti me. Tritium concentrations in Midwest precipitation have typically been below 100 pCi/L since around 1980.

The RadNet database for several stations in the U.S. Midwest (Chicago, Columbus, Indianapolis, Lansing, Madison, Minneapolis , Painesville, Toledo, and Welsch) did not show the same trend, which can be attrib uted to pre-1995 data handling procedures.

The pre-1995 data were rounded to the nearest 100 pCi/L, which dampened out variances in the data. The post-1995 RadNet data, where rounding was not applied, exhibit much more scatter, and similar to th e GNIP data, the vast majority of the data were less than 100 pCi/L.

CRA constructed a non-parametric upper toler ance limit with a confidence of 95 percent and coverage of 95 percent based on RadN et data for USEPA Region 5 from 2004 to 2005. The resulting upper tolerance limit is 133 pCi/L, which indicates that CRA is 95 percent confident that 95 percent of the ambient precipitation concentration results are below 133 pCi/L. The statistical confidence, however, must be compared with the limitations of the underlying RadNet da ta, which does not include the minimum detectable concentration for a majority of th e measurements. Some of the RadNet values below 200 pCi/L may be approx imated. Nevertheless, these results show a background contribution for precipitation of up to 133 pCi/L.

7.2.3 SURFACE WATER D A TA Tritium concentrations are routinely measured in large surface water bodies, including Lake Michigan and the Mississippi River. Surf ace water data from the RadNet database for Illinois sampling stations include East Moline (Mississippi River), Moline (Mississippi River), Marseilles (Illinois Rive r), Morris (Illinois River), Oregon (Rock River), and Zion (Lake Michigan). As is the case for the RadNet precipitation data, the pre-September 1995 Illinois surface water data was rounded to the nearest 100 pCi/L, creating a dampening of variances in the da ta. The post-1995 Illinois surface water data, similar to the post-1995 Midwest precipitation data, were less than 100 pCi/L, with the exception of the Moline (Mississippi Rive r) station. Tritium surface water concentrations at this location varied between 100 and 800 pCi/L, which may reflect local natural or anthropogenic inputs.

The RadNet surface water data typically has a reported 'Combined Standard Uncertainty' of 35 to 50 pCi/L. According to USEPA, this corresponds to a

+/- 70 to 100 pCi/L 95 percent confidence bound on each given measurement.

Therefore, 045 136 (22) Zi on St ati o n 41 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 the typical background data provided may be subject to measurement uncertainty of approx imately +/- 70 to 100 pCi/L.

7.2.4 DRINKING WATER DATA Tritium concentrations in drinking water fr om the RadNet database for three Illinois sampling stations (Chicago, Morris, and East Chicago) ex hibit similar trends as the precipitation and surface water data. As wi th the precipitation and surface water data, the pre-1995 data have dampened out variances due to rounding the data to the nearest 100 pCi/L. The post-1995 results show tritiu m concentrations in samples of drinking water were less than 100 pCi/L.

7.2.5 EXPECTED TRITIUM BACKGROUND FOR THE STATION As reported in the GNIP and RadNet database s, tritium concentrations in U.S.

Midwest precipitation have typically been less than 100 pCi/L since 1980. Tritium concentrations reported in the RadNet database for Illinoi s surface water and groundwater, at least since 1995, have typically been less than 100 pC i/L. Based on USEPA Region 5's 2004 to 2005 RadNet precipitation data, 95 percent of the ambient concentrations of tritiated water in Illinois are expected to be less than 133 pCi/L, based on a 95 percent confidence limit. Tritium concentrations in surface wa ter and drinking water at the Station are expected to be comparable or less ba sed on historical data and trends.

Concentrations in groundwater similar to su rface water and drinking water are ex pected to be less than precipitation values. The lo wer groundwater concentrations are related to the age of the groundwater as compared to the half-life of tritium. Deep aquifers in proximity to crystalline basement rock, ho wever, can potentially show elevated concentrations of tritium due to lithogenic sources.

The Pre-Operational REMP report noted that lake water was sampled at five public water intakes. Generally, the gross beta radioactivity of Lake Michigan was less than 10 pCi/L. Typical values from throughout th e Lake were between 3 to 6 pCi/L. Gross alpha radioactivity was typically less than 3 pCi/L (ComEd, 1971).

Tritium levels in Lake Michigan water were st udied in the vicinity of Zion throughout 1970 (prior to the construction of the Statio n). The concentration of tritium in Lake Michigan near Zion ranged from approx imately 311 20 pCi/L to 374 34 pCi/L and averaged 340 pCi/L. There was no statistica l difference in average tritium levels among 045 136 (22) Zi on St ati o n 42 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 the sample locations (eight sample locations from Kenosha to Waukegan) (ComEd, 1971).

As was noted in Section 7.0, the reporting lim its for the tritium results are to an LLD of 200 pCi/L. This concentration also repr esents a reasonable representation of background groundwater quality, given the da ta for precipitation, surface water, and drinking water.

Based on the evaluation presented above, th e background concentration for tritium at the Station is reasonably represented by the LLD of 200 pCi/L.

7.3 IDENTIFICATION OF POTENTIAL EXPOSURE PATHWAYS AND POTENTIAL RECEPTORS There are two potential exposure pathways for tritium originating in or adjacent to the Station: potential groundwater migration off the St ation property to private and public groundwater users; and potential groundwater migration off the Station property to Lake Michigan.

The following section provides an overview of each of these two potential exposure pathways for tritium in groundwater.

7.3.1 POTENTIAL GROUNDWATER MIGRATION TO DRINKING WATER USERS OFF THE STATION PROPERTY Based upon the groundwater and surface water data presented in this HIR, groundwater flow is to the east towards Lake Michigan. The horizontal ex tent of the elevated concentrations of tritium in th e direction of groundwater flow has been established, and is limited to the area arou nd MW-ZN-01S. Tritium was not detected in the four temporary well installed near the shoreline above the LLD of 200 pCi/L. The tritium concentrations in groundwater samp les collected from MW-ZN-01S ranged from less than LLD (most recently) to 586 +/- 141 pCi/L (lower interval), 220 +/- 123 pCi/L to 261 +/- 124 pCi/L (upper interval), which are si gnificantly less than the USEPA drinking water standard of 20,000 pCi/L. No tritium was detected above the LLD (200 pCi/L) in the other fourteen monitoring wells across the Station. In addition, there are no potable water supply wells downgradient of the Station or of monitoring well MW-ZN-01S.

045 136 (22) Zi on St ati o n 43 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 The direction of groundwater flow is east towards Lake Michigan. Tritium was not detected at concentrations greater than the LLD (200 pCi/L) in the four temporary wells located downgradient of MW-ZN-01S. There is no potentially complete exposure pathway, and therefore there is no current ri sk of exposure associ ated with groundwater ingestion off the Station property.

7.3.2 POTENTIAL GROUNDWATER MIGRATION TO SURFACE WATER USERS Based upon the groundwater and surface water data presented in this HIR, groundwater flow is to the east towards Lake Michigan. The horizontal ex tent of the elevated concentrations of tritium is lim ited to the area around MW-ZN-01S.

The tritium concentrations detected in grou ndwater samples collected from MW-ZN-01S ranged from less than LLD (200 pCi/L) (most recently) to 586

+/- 141 pCi/L (lower interval) and 220 +/- 123 pCi/L to 261 +/- 124 pCi/L (upper interval), which are significantly less than the USEPA drinking wa ter standard of 20,000 pCi/L. No tritium was detected above the LLD (200 pCi/L) in the other 14 monitoring wells across the Station. In addition, no tritium was de tected above the LLD (200 pCi/L) in the downgradient monitoring wells (MW-ZN-11S and TW-ZN-100 through TW-ZN-103) and the surface water sample collected from Lake Michigan at station SW-ZN-01, adjacent to the Station.

The Lake County Public Works Department ob tains its water for the City of Zion from Lake Michigan by means of an intake pipe located approx imately 1 mile to the north of the Station and ex tending 3,000 feet into the Lake.

Since tritium was not detected at concentrations greater than LLD (200 pCi/L) in the four temporary wells and MW-ZN-11S (which are downgradient of MW-ZN-01S) or the Lake Michigan surface water sample, there is an incomplete exposure pathway. Therefore, there is no current risk of exposure associated with ingestion and recreational use off the Station property.

7.4

SUMMARY

OF POTENTIAL TRITIUM EXPOSURE PATHWAYS There are two potential groundwater exposure pathways for tritium originating at the Station: groundwater migration off the Station Prop erty to private and public groundwater users (drinking water exposure); and 045 136 (22) Zi on St ati o n 44 C ONESTOGA-R OVERS & A SSOCIATES groundwater migration off the Station Prop erty to Lake Michigan (drinking water ex posure and recreational ex posure).

Revision 1 Based upon the groundwater and surface wate r data provided and referenced in this investigation, none of the potential receptors ar e at risk of ex posure to concentrations of tritium in ex cess of USEPA drinking water standard (20,000 pCi/L).

7.5 O T H E R RADIONUCLIDES Target radionuclides were not detected at concentrations greater than their respective LLDs in the groundwater and surface water samples collected. Other non-targeted radionuclides were also included in the tabl es but excluded from discussion in this report. These radionuclides were either a) naturally occurring and thus not produced by the Station, or b) could be definitively eval uated as being naturally occurring due to the lack of presence of other ra dionuclides which would otherwis e indicate the potential of production from the Station.

045 136 (22) Zi on St ati o n 45 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 8.0 C O N C L U S I O N S Based on all of the studies completed to da te at the Zion Station, CRA concludes:

Groundwater Flow The water table is in the Upper Sand Un it. The depth to water ranged from 5 to 14 feet bgs. The shallow groundwater at the Station generally flows to the east towards Lake Michigan. Groundwater flow at the Station is affected by the construction (basements/foundations) of the Reactor, Turbine, and Auxiliary Buildings, which were constructed into the Silt-Clay Unit.

These buildings are barriers to lateral flow. A sheet pile wall was initially installed to limit the infiltration of Lake Michigan water into the construction excavation for the main Station buildings. The wall currently influences groundwater flow on th e east side of the Station by diverting the groundwater around the wall.

Groundwater Quality None of the detected tritium concentrat ions in the groundwater exceeded the USEPA drinking water standard of 20,000 pCi/L. Tritium was not detected at concentrations greater than the LLD (200 pCi/L) in 14 of the 15 monitoring wells collected as part of this investigation. Tritium was detected in groundwater sa mples collected from monitoring well MW-ZN-01S. These concentrations ranged from less than LLD (most recently) to 586 +/- 141 pCi/L (lower interval) and 220 +/- 123 pCi/L to 261 +/- 124 pCi/L (upper interval). Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than their respective LLDs in any of the sample collected as part of this investigation. Strontium-89/90 was not detected at concentrations greater than the LLD of 2.0 pCi/L in any sample collected as part of this investigation. Tritium is not migrating off the Station property.

045 136 (22) Zi on St ati o n 46 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Surface Water Quality Tritium was not detected in the surface wa ter sample at a concentration greater than the USEPA drinking water standard of 20,000 pCi/L. Tritium was not detected in the surface wa ter sample at a concentration greater than the LLD of 200 pCi/L. Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than thei r LLDs in the sample collected as part of this investigation. Strontium-89/90 was not detected at concentrations greater than the LLD of 2.0 pCi/L in the sample collected as part of this investigation.

AFE-Zion-1: Main Complex Area, AFE-Zion

-3: Unit 2 (Northern) AST Area, and AFE-Zion-4: Wastewater Treatment Plant Area Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than their respective LLDs in any of the groundwater samples collected from the moni toring wells in the vicinity of AFEs Zion-1, 3, and 4. Strontium-89/90 was not detected at concentrations greater than the LLD of 2.0 pCi/L in any of the groundwater samples collected from the monitoring wells in the vicinity of AFEs-Zion-1, 3, and 4. Tritium was detected in groundwater sa mples collected from monitoring well MW-ZN-01S. These concentrations ranged from less than LLD (most recently) to 586 +/- 141 pCi/L (lower interval) and 220 +/- 123 pCi/L to 261 +/- 124 pCi/L (upper interval). The tritium is localized to th e area in the vicinity of monitoring well MW-ZN-01S. No tritium was detected in the four temporary wells and MW-ZN-11S, located downgradient of monitoring well MW-ZN-01S. This well is located in close prox imity to AFEs Zion 1, 3, and

4. The so urce of tritium in this location is likely attributable to historical releases in this area. However, the most recent sample results are within the range of background concentrations.

AFE-Zion-2: Unit 1 (Southern) Ab oveground Storage Tank (AST) Area Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than their respective LLDs in any of the groundwater samples collected from the monitoring wells in the vicinity of AFE-Zion-2.

045 136 (22) Zi on St ati o n 47 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Strontium-89/90 was not detected at concentrations greater than the LLD of 2.0 pCi/L in any of the groundwater samples collected from the monitoring wells in the vicinity of AFE-Zion-2. Tritium was not detected at concentrations greater than the LLD of 200 pCi/L in any of the groundwater samples collected from the monitoring wells near AFE-Zion-2. There have been no impacts to groundwater from AFE-Zion-2.

Potential Receptors Based on the results of this investigation 4 , there is no current risk from exposure to radionuclides associated with licensed plant operations through any of the identified potential exposure pathways.

General Conclusions Based on the results of this investigation, tritium is not migrating off the Station property at detectable concentrations; and Based on the results of this investigation, there are no known active releases into the groundwater at the Station.

4 Using t h e LLDs specified in t h is HIR. 045 136 (22) Zi on St ati o n 48 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 9.0 R E C O M M E N D A T I O N S The following presents CRA's recommendations for proposed activities to be completed at the Station.

9.1 D A T A G A PS Based on the results of this hydrogeologi c investigation, there are no data gaps remaining to support CRA's conclusions regarding the characterization of the groundwater regime and potential impact s from radionuclides at the Station.

9.2 G R O U N D W A T E R MONITORING Based upon the information collected to date, CRA recommends that Ex elon conduct periodic monitoring of selected sample locations.

Temporary Well Abandonment Four temporary wells were installed on th e beach between the sheet pile wall and the normal high water mark. These temporary we lls are not expected to survive the winter due to storms and ice buildup and should be properly abandoned before the onset of cold weather.

045 136 (22) Zi on St ati o n 49 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 1 0.0 R E F E R E N C E S ATSDR, 2000. Public Health Assessment, Asbe stos Contamination at Illinois Beach State Park, Illinois Beach Park, Zion, Lake County, Illinois, EPA Facility Id:

ILD984840140, Illinois Department of Public Health and the Agency for Toxic Substances and Disease Registry.

Bannon-Nilles, 2003. Phyllis L. Bannon-Nilles, A Park in the Making: the History of the Development of Illinois Beach State Park, Open File Series 2003-8, Illinois State Geological Survey, Champaign, Illinois, 2003.

Berg and Kempton, 1988. Richard C. Berg and John P. Kempton, Stack-Unit Mapping of Geologic Materials in Illinois to a Depth of 15 Meters, Circular 542, Illinois State Geological Survey, Champaign, Illinois.

Chrzastowski and Frankie 2000. Michael J.

Chrzastowski and Wayne T. Frankie, Guide to the Geology of Illinois Beach State Park and the Zion Beach-Ridge Plain, Lake County, Illinois, Illinois State Geological Survey, 2000.

City of Zion, 2004. 04-O-9, An Ordinance Am ending Sections 94-47 and 94-48 of the City of Zion Code Relative to the Provision of Water Service, City of Zion, Lake County, Illinois, passed on March 2, 2004.

City of Zion, 2006. Annual Water Quality Re port, Water Testing Performed in 2005, City of Zion, Zion Public Works Department, June 23, 2006.

ComEd, 1967. Drawing B-1A, Location of Bo rings, Zion Station, Commonwealth Edison Co., Chicago, Illinois.

ComEd, 1971. Zion Station Final Safety Analysis Report, Amendment 17, Commonwealth Edison Company, December 1971.

ComEd, 1999. Zion Station Historical Site Assessment, ComEd Decommissioning Projects & Zion Station.

ComEd, November 1968. Drawings B-10 through B-14, Log of Borings, Zion Station, Commonwealth Edison Co., Chicago, Illinois.

CRA, May 2006. Hydrogeologic Investig ation Work Plan, Fleetwide Tritium Assessment, Zion Generating Station, Zion, Illinois, prepared for Exelon Generation Company, LLC by Conestoga-Rovers & Associates, Inc.

Dames and Moore, 1967. Report: Foundation Investigation, Proposed Nuclear Power Plant, Zion, Illinois (Rough Draft), prepared for the Commonwealth Edison Company by Dames and Moore, October 9, 1967.

Environmental Inc., 2005. Final Monthly Progress Report to Ex elon Nuclear, Radiological Environmental Monitoring Pr ogram (REMP), for Zion Station, Zion, Illinois, Environmental Incorporated Mi dwest Laboratory, Northbrook, Illinois.

045 136 (22) Zi on St ati o n 50 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Ex elon, 2005. Quad Cities Nuclear Po wer Station, 2004 Annual Radiological Environmental Operating Report.

Ex elon, 2006. Offsite Dose Calculation M anual, Revision 15, Dockets 50-295 and 50-304 (Zion), Ex elon Nuclear, February 2006.

Ex elon, October 2004. Zion Station Defueled Safety Analysis Report (DSAR) and DSAR Update, Revision 3, Exelon Ge neration, Warrenville, Illinois.

Foote, 1982. Gary Ray Foote, Fracture Anal ysis in Northeastern Illinois and Northern Indiana, University of Illinois, Urbana, Illinois, 1982.

Fraser and Hester 1974. Gordon S.

Fraser and Norman C. Hester, Sediment Distribution in a Beach Ridge Complex and its Applicat ion to Artificial Beach Replenishment, Environmental Geology Notes #67, I llinois State Geological Survey, 1974.

Hansel, 1983. Ardith K. Hansel, The Wa dsworth Till Member of Illinois and the Equivalent Oak Creek Formation of Wisconsi n, in Geoscience Wisconsin, Vol.

7, July 1983.

International Joint Commission, August 1997. 1995-97 Priorities and Progress Under the Great Lakes Water Quality Agreement, http://www.ijc.org/php/publications/html/pr9597.html , International Joint Commission.

Larson and Schaetzl, 2001. Grahame Larson and Randall Schaetzl, Origin and Evolution of the Great Lakes, in the Journal of Great Lakes Research, Vol. 27, No. 4, pp. 518-546, 2001.

Nicholas and Healy, 1988. J.R. Nicholas and R.W. Healy, Tritium Migration From a Low-Level Radioactive-Waste Disposal Site Near Chicago, Illinois, USGS Water Supply Paper 2333, U.S. Geological Survey, Denver Colorado, 1988.

NOAA, June 2006. NOAA Tides & Currents:

Great Lakes Water Level Data, http://tidesandcurrents.noaa.gov/, U.S. National Oceanic and Atmospheric Administration, Center for Operational Oceanographic Products and Services (CO-OPS), Silver Spring, Maryland.

NRC, 2006. Facility Information Finder, Operating Nuclear Power Reactors, http://www.nrc.gov/info-finder.html , U.S. Nuclear Regulatory Commission, accessed June 29, 2006.

NRCS, June 2005. Soil Survey of Lake County, Illinois, U.S.

Department of Agriculture, Natural Resources Conservation Service.

Puls and Barcelona, April 1996. Low-Fl ow (Minimal Drawdown)

Ground-Water Sampling Procedures, EPA Ground Water Issue, EPA/540/S-95/504, R.S.

Kerr Environmental Research Center, Ada, Oklahoma.

045 136 (22) Zi on St ati o n 51 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 045136 (22) Zion Station 52 C ONESTOGA-R OVERS & A SSOCIATES SEWRPC and WGNHS, 2002. Groundwater Re sources of Southeastern Wisconsin, Technical Report No. 37, Southeastern Wisconsin Regional Planning Commission and Wisconsin Geological and Na tural History Survey, June 2002. Underwood et al., 2003. Chad A. Underwood, Michele L. Cooke, J.A. Simo and Maureen A. Muldoon, Stratigraphic Controls on Vertical Fracture Patterns in Silurian Dolomite, Northeastern Wisconsin, AAPG Bulletin v. 87, no. 1, American Association of Petrol eum Geologists, January 2003. University of Wisconsin, 1970. Pleistocene Geology of Southern Wisconsin, Information Circular Number 15, Geological and Natural History Survey, University of Wisconsin, 1970. US AEC, 1972. Final Environmental Statemen t Related to Operation of Zion Nuclear Power Station Units 1 and 2, Commonwealth Edison Company, Docket Nos. 50-295 and 50-304, U.S. Atomic Energy Commission, December 1972. USEPA and Environment Canada, 1995. "The Great Lakes: An Environmental Atlas and Resource Book", Chicago, Illinois. USEPA, 1996. Soil Screening Guidance: Technical Background Document, EPA/540/R-95/128, Office of Solid Waste and Emergency Response, United States Environmental Protecti on Agency, Washington, DC. USEPA, May 1996. "Soil Screening Guidance Technical Background Document", Office of Solid Waste and Emergency Response, Washington, DC EPA/540/R95/128. USGS, 1996. Robert T. Kay, Richard F. Duwelius, Timothy A. Brown, Frederick A. Micke, and Carol A. Witt-Smith, Geohydrol ogy, Water Levels and Directions of Flow, and Occurrence of Light-Nonaqueous-Phase Liquids on Ground Water in Northwestern Indiana and the Lake Calu met Area of Northeastern Illinois, U.S. Geological Survey, De Kalb, Illinois. Visocky et al., 1985. Adrian P. Visocky, Marvin G. Sherrill, and Keros Cartwright, Geology, Hydrology, and Water Qua lity of the Cambrian and Ordovlclan Systems In Northern Illinois, Cooperative Groundwater Report 10, Illinois State Geological Survey, Illinois State Wa ter Survey, Champaign, Illinois. Willman, 1971. H.B. Willman, Summary of the Geology of the Chicago Area, Circular 460, Illinois State Geolog ical Survey, Urbana, Illinois. Zeizel et al., 1962. Arthur J. Zeizel, William C. Walton, Robert T. Sasman, and Thomas A. Prickett, Ground-Water Resources of DuPage County, Illinois, Cooperative Report No. 2, Illinois State Water Survey, Illinois State Geological Survey, Urbana, Illinois, 1962.

STATIONSOURCE: USGS QUADRANGLE MAP; 04000ft2000ZION, ILLINOIS (1993)figure 1.1STATION LOCATION MAPZION STATIONEXELON GENERATION COMPANY, LLC45136-30(022)GN-WA001 AUG 24/2006 SOURCES: MAP: USGS QUADRANGLE MAP; 0800ft400ZION, ILLINOIS (1993)figure 2.1STATION SURFACE WATER FEATURESZION STATIONEXELON GENERATION COMPANY, LLC45136-30(022)GN-WA024 SEP 07/2006WELL LOCATIONS: BANKS INFORMATION SOLUTIONS, INC.WATER WELL REPORT, JUNE 7, 2006LEGENDPROPERTY LINEREVISION 1DITCH figure 2.2REGIONAL STRATIGRAPHIC CROSS-SECTIONZION STATIONEXELON GENERATION COMPANY, LLC45136-30(022)GN-WA007 AUG 24/2006SOURCE: ILLINOIS STATE GEOLOGICAL SURVEY,INTRODUCTION TO 3-D VISUALIZATION OFBEDROCK IN LAKE COUNTY, ILLINOIS figure 2.3CROSS-SECTION OF THE ZION BEACH-RIDGE PLAINZION STATIONEXELON GENERATION COMPANY, LLC45136-30(022)GN-WA016 AUG 24/2006SOURCE: GUIDE TO THE GEOLOGY OF ILLINOIS BEACH STATE PARKAND THE ZION BEACH-RIDGE PLAIN, LAKE COUNTY,ILLINOIS STATE GEOLOGICAL SURVEY, 2000.CROSS-SECTION LOCATION STATION 10 58 59 36 35 54 55 38 48 56 40 42 57 49 45 51 53 47 43 52 44 50 39 41 46 6 1 2 4 7 8 31 21 30 24 19 32 25 23 26 34 33 14 17 16 13 11 12 18 22 20 27 28 37 9 5 15 3LIMIT OFSTUDY AREASOURCES: MAP: USGS QUADRANGLE MAP; 03000ft1500ZION, ILLINOIS (1993)figure 2.4PRIVATE/PUBLIC WATER SUPPLY WELL LOCATIONSZION STATIONEXELON GENERATION COMPANY, LLC45136-30(022)GN-WA008 AUG 24/2006WELL LOCATIONS: BANKS INFORMATION SOLUTIONS, INC.WATER WELL REPORT, JUNE 7, 2006 40GROUNDWATER WELL/WELL CLUSTER 600590580570560550540530520510500490480470460ELEVATION (ft. AMSL)MW-ZN-05SMW-ZN-04SMW-ZN-03SMW-ZN-02SBH7 (offset 150' W)MW-ZN-01SMW-ZN-08S50010001500 A'NORTH600590580570560550540530520510500490480470460ELEVATION (ft. AMSL)

ASOUTHTURBINE BUILDINGINTAKE CRIBTURBINE BUILDINGDISTANCE (ft.)INTAKELINELINEDISCHARGE 0BH1 (offset 660' W)BH70 (offset 61' E)BH71 (offset 49' E)BH46 (offset 274' W)BH19 (offset 488' W)LINEDISCHARGEBOTTOM OF SHEET PILE WALLMW-ZN-10S (offset 224' W)MW-ZN-11S (offset 58' E)Scale:Source

Reference:

Project Manager:Reviewed By:Project N:

oDate:Report N: oDrawing N o:THIS BAR MEASURES 1" ON ORIGINAL. ADJUST SCALE ACCORDINGLY.SCALE VERIFICATIONEXELON GENERATION COMPANY, LLCZION, ILLINOISGEOLOGIC CROSS SECTION A-A'ZION STATIONFLEETWIDE ASSESSMENTS. QUIGLEYJ. RABYAUGUST 200645136-30 022figure 5.245136-30(022)GN-WA023 AUG 09/2006AS SHOWNMW-ZN-05SFILLUPPER/LOWER SAND UNITSILT-CLAY UNITBASEMENT / FOUNDATIONSMEASUREMENTS TAKEN ON MAY 23, 2006 0 600 590 580 570 560 550 540 530 520 510 500 490 480 470 460ELEVATION (ft. AMSL)DISTANCE (ft.)MW-ZN-07S BWEST B'EASTMW-ZN-09SBH7MW-ZN-02SCONTAINMENT BUILDINGAUXILIARY BUILDINGTURBINE BUILDINGINTAKE CRIBLAKE MICHIGANBREAK WALL 500 1000 1500 2000 600 590 580 570 560 550 540 530 520 510 500 490 480 470 460ELEVATION (ft. AMSL)BH1INTAKE LINEDISCHARGE LINESHEET PILE WALLBH19BH46BH71TW-ZN-100 (offset 150.6' N)TW-ZN-103 (offset 162.9' N)Scale:Source

Reference:

Project Manager:Reviewed By:Project N:

oDate:Report N: oDrawing N o:THIS BAR MEASURES 1" ON ORIGINAL. ADJUST SCALE ACCORDINGLY.SCALE VERIFICATIONEXELON GENERATION COMPANY, LLCZION, ILLINOISGEOLOGIC CROSS SECTION B-B'ZION STATIONFLEETWIDE ASSESSMENTS. QUIGLEYJ. RABYAUGUST 200645136-30 022figure 5.345136-30(022)GN-WA023 AUG 24/2006AS SHOWNMW-ZN-07SFILLUPPER/LOWER SAND UNITSILT-CLAY UNITNIAGARA DOLOMITEBASEMENT / FOUNDATIONSMEASUREMENTS TAKEN ON MAY 23, 2006

TABLE 4.2

SUMMARY

OF MONITORING WELL DEVELOPMENT PARAMATERS FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Page 1 of 5 Sample Gallons Water Location Date Well Volume Purged Level pH Conductivity Temperature Turbidity Observations Pump Type (gallons)(Std. Units)

(µS/cm) 1 (°C)(ntu) 2 MW-ZN-01S 5/3/2006 5.0 5 13.3 NA NA NA NA brown, turbid, silty Peristaltic 10 7.46 757 17.0> 1000 brown, turbid, silty 15 NA NA NA NA brown, turbid, silty 20 7.38 699 17.0> 1000 brown, turbid, silty 25 7.20 662 15.7> 1000 brown, turbid, silty 30 7.31 640 16.1> 1000 brown, turbid, silty 35 7.33 633 17.1> 1000 brown, turbid, silty 40 622 16.5> 1000 brown, turbid, silty 45 7.48 607 19.2> 1000 brown, turbid, silty 50 7.43 599 16.6> 1000 brown, turbid, silty 55 7.41 591 16.5 340 brown, turbid, silty 60 7.41 593 16.3 164 brown, turbid, silty 65 7.43 593 16.3 164 brown, turbid, silty 70 7.44 580 17.4 99.6 brown, turbid, silty 75 7.45 589 15.9 95.3 brown, turbid, silty 80 7.43 586 16.1 82 brown, turbid, silty MW-ZN-02S 5/4/2006 3.5 4 13.6 7.97 653 12.5> 1000 silty, gray Peristaltic 8 7.80 614 14.6> 1000 silty, gray 12 7.74 605 14.5> 1000 silty, gray 18 7.83 595 14> 1000 silty, gray 22 7.63 582 13.3> 1000 silty, gray 26 7.64 577 13> 1000 silty, gray 30 7.62 199.5 12.6> 1000 silty, gray 34 7.58 95.6 13.3> 1000 silty, gray 40 7.57 196.3 12.6> 1000 silty, gray 44 7.61 195.1 12.9 896 getting less cloudy 48 7.60 96.3 12.8 702 getting less cloudy CRA 45136 (22) Zion Station Revision 1 TABLE 4.2

SUMMARY

OF MONITORING WELL DEVELOPMENT PARAMATERS FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Page 2 of 5 Sample Gallons Water Location Date Well Volume Purged Level pH Conductivity Temperature Turbidity Observations Pump Type (gallons)(Std. Units)

(µS/cm) 1 (°C)(ntu) 2 MW-ZN-03S 5/5/2006 3.72 4 13.12 7.44 666 11.3> 1000 cloudy, brown Peristaltic 8 7.41 628 11.3> 1000 cloudy, brown 12 7.46 608 10.9> 1000 cloudy, brown 16 7.43 604 10.5> 1000 cloudy, brown 20 7.47 200 10.7> 1000 cloudy, brown 24 7.43 192.2 10.4> 1000 cloudy, brown 28 7.43 188.8 10.7> 1000 cloudy, brown 32 7.40 188.0 10.9 834 cloudy, brown 36 7.42 186.1 10.6 838 cloudy, brown 40 7.40 181.3 10.5> 1000 cloudy, brown 44 7.40 181.7 10.9> 1000 cloudy, brown 48 7.40 178.9 10.4> 1000 cloudy, brown 52 7.41 177.0 10.4 1000 cloudy, brown MW-ZN-04S 5/5/2006 8 14.27 7.24 188.9 12.9> 1000 cloudy, brown Peristaltic 12 7.50 185.5 12.6> 1000 cloudy, brown 16 7.51 553 12.8> 1000 cloudy, brown 20 7.50 179.0 12.8> 1000 cloudy, brown 24 7.49 177.6 12.8 689 cloudy, brown 28 7.50 176.5 12.8 508 cloudy, brown 32 7.48 175.2 12.8 312 slightly cloudy, brown 36 7.48 176.0 12.6 267 slightly cloudy, brown 40 7.47 173.4 12.6 180 slightly cloudy, brown 44 7.47 173.4 12.6 114 slightly cloudy, brown 48 7.46 172.2 12.6 85.1 slightly cloudy, brown 52 7.46 171.7 12.6 52.8 slightly cloudy, brown CRA 45136 (22) Zion Station Revision 1 TABLE 4.2

SUMMARY

OF MONITORING WELL DEVELOPMENT PARAMATERS FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Page 3 of 5 Sample Gallons Water Location Date Well Volume Purged Level pH Conductivity Temperature Turbidity Observations Pump Type (gallons)(Std. Units)

(µS/cm) 1 (°C)(ntu) 2 MW-ZN-05S 5/8/2006 4.1 5 25.63 7.28 140.0 12.4> 1000 cloudy, brown Peristaltic 10 7.21 141.5 12.6 879 cloudy, brown 15 7.22 142.3 12.8> 1000 cloudy, brown 20 7.25 140.7 12.5 588.0 cloudy, brown 25 7.25 142.2 12.5 228.00 slightly cloudy, brown 30 7.25 144.3 12.3 482.00 slightly cloudy, brown 35 7.22 147.1 12.5 60.00 clear 40 7.24 145.2 12.6 32.6 clear 45 7.23 144.5 12.7 19.7 clear 50 7.23 144.6 12.7 16 clear 55 7.25 144.0 12.7 16.2 clear 60 7.25 144.0 12.6 10.2 clear MW-ZN-06S 5/8/2006 3.52 3.5 3.52 7.12 135.2 12.8> 1000 silty, gray Peristaltic 7.0 7.09 133.7 10.3> 1000 silty, gray 10.5 7.08 137.6 11.0> 1000 silty, gray 14.0 7.05 137.6 10.3> 1000 silty, gray 17.5 7.04 139.0 10.7> 1000 silty, gray 21.0 7.35 122.5 10.8 1000 silty, gray 24.5 7.24 124.7 10.5 232 clearer 28.0 7.13 126.8 10.0> 1000 clear 31.5 7.07 128.3 10.3 520 clear 35.0 7.08 128.5 10.2 148 silty 38.5 7.03 128.8 10.0> 1000 silty 41.0 6.99 132.0 10.5 458 clear 44.5 7.10 129.1 10.4 143 clear 48 7.01 131.4 10.5 137.8 clear CRA 45136 (22) Zion Station Revision 1 TABLE 4.2

SUMMARY

OF MONITORING WELL DEVELOPMENT PARAMATERS FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Page 4 of 5 Sample Gallons Water Location Date Well Volume Purged Level pH Conductivity Temperature Turbidity Observations Pump Type (gallons)(Std. Units)

(µS/cm) 1 (°C)(ntu) 2 MW-ZN-07S 5/8/2006 4.3 4.3 5.20 7.15 139.5 10.5> 1000 silty, gray Peristaltic 8.6 7.11 141.3 10.7> 1000 silty, gray 12.9 7.11 137.6 10.8> 1000 silty, gray 16.2 7.13 136.1 10.6> 1000 silty, gray 20.5 7.13 139.0 10.7> 1000 silty, gray 24.8 7.05 138.6 10.3> 1000 silty, gray 29.1 7.05 137.6 10.5 872 silty, gray 33.4 7.07 138.2 10.3 569 silty, gray 37.7 7.07 113.7 10.7> 1000 silty, gray 42.0 7.06 140.1 10.4 520 silty, gray 45.3 7.06 138.5 10.8 213 silty, gray 49.6 7.04 139.3 10.4 89.7 silty, gray MW-ZN-08S 5/8/2006 3.86 3.9 8.17 7.45 143.6 13.0> 1000 NA Peristaltic 9.8 7.47 136.8 12.8 1000 NA 11.7 7.40 138.5 12.9 628 NA 15.6 7.42 139.4 13.3> 1000 NA 19.5 7.42 138.4 12.6 898 NA 23.4 7.41 138.1 12.6 898 NA 27.3 7.41 141.5 13.3 898 NA 31.2 7.42 138.1 13.0 387 NA 35.1 7.33 138.1 12.6 198 NA 39.0 7.41 138.4 13.0 101 NA 42.9 7.39 139.3 12.4 75.2 NA 46.8 7.42 138.7 12.6 50.9 NA MW-ZN-09S 5/8/2006 1.58 2 9.89 8.97 158.7 11.9> 1000 cloudy, gray Peristaltic 4 9.13 159.7 11.7> 1000 septic odor 6 9.18 158.6 11.7> 1000 septic odor 8 9.15 156.3 11.7 484 septic odor 10 9.13 155.3 11.7 245 slightly cloudy, gray 12 9.00 152.1 11.8> 1000 slightly cloudy, gray 14 9.10 151.1 11.8 277 slightly cloudy, gray 16 9.07 150.2 11.8 44.7 slightly cloudy, gray 18 9.09 148.6 11.8 13.10 clear, septic odor 20 9.09 147.7 11.7 9.93 clear, septic odor 22 9.04 147.2 11.7 8.67 clear, septic odor CRA 45136 (22) Zion Station Revision 1 TABLE 4.2

SUMMARY

OF MONITORING WELL DEVELOPMENT PARAMATERS FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Page 5 of 5 Sample Gallons Water Location Date Well Volume Purged Level pH Conductivity Temperature Turbidity Observations Pump Type (gallons)(Std. Units)

(µS/cm) 1 (°C)(ntu) 2 MW-ZN-10S 7/14/2006 4 90*13.58 6.89 913.0 16.7 151.00 cloudy Peristaltic 94 7.18 776.0 15.0 132.00 cloudy 98 7.26 738.0 14.0 281.00 cloudy 102 7.34 748.0 13.8 112 clear 106 7.37 738.0 13.8 75.5 clear MW-ZN-11S 7/14/2006 3 3 10.5 7.47 863.0 17.3>1000 cloudy, brown Peristaltic 6 7.31 842.0 16.8>1000 cloudy, brown 9 7.35 839.0 16.1>1000 cloudy, brown 12 7.36 832.0 16.2 243 clear 15 7.31 828.0 16.0 162 clear 18 7.31 806.0 16.0 88.80 clear 24 7.28 654.0 16.7>1000 clear 27 7.28 827.0 15.9 258.00 clear 30 7.33 503.0 16.7 83.7 clear 33 7.33 791.0 16.4 52 clear 36 7.27 802 16.2 105 clear 45 7.27 799 15.6 50 clear 51 7.36 792 15.6 23.6 clear 56 7.27 798 15.7 22 clear Notes: 1 µS/cm - microSiemens per centimeter 2 ntu - nephelometric turbidity units

  • purged 90 gallons from well before taking readings CRA 45136 (22) Zion Station Revision 1

TABLE 5.1 ANALYTICAL RESULTS

SUMMARY

- TRITIUM IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Page 1 of 1 Sample Location (1)Sample IdentificationQC SampleSample DateTritium (pCi/L)Result ErrorMW-ZN-01S(L)WG-ZN-MW-ZN-01L-052606-DS-075/26/2006586 +/-141MW-ZN-01S(L)GW-062806-PG-026/28/2006ND (200) -MW-ZN-01S(U)WG-ZN-MW-ZN-01U-052606-DS-055/26/2006261 +/-124 MW-ZN-01S(U)GW-062806-PG-016/28/2006220 +/-123MW-ZN-02S(L)WG-ZN-MW-ZN-02L-052606-DS-065/26/2006ND (200) -MW-ZN-02S(U)WG-ZN-MW-ZN-02U-052606-DS-045/26/2006ND (200) -MW-ZN-03S(L)WG-ZN-MW-ZN-03L-052506-DS-035/25/2006ND (200) -MW-ZN-03S(U)WG-ZN-MW-ZN-03U-052506-DS-015/25/2006ND (200) -

MW-ZN-03S(U)WG-ZN-MW-ZN-03U-052506-DS-02Duplicate (01)5/25/2006ND (200) -MW-ZN-04S(L)WG-ZION-MW-4L-052406-MB-0045/24/2006ND (200) -MW-ZN-04S(U)WG-ZION-MW-4U-052406-MB-0025/24/2006ND (200) -MW-ZN-05S(L)WG-ZION-MW-5L-052606-MS-0135/26/2006ND (200) -MW-ZN-05S(U)WG-ZION-MW-5U-052606-MS-0175/26/2006ND (200) -MW-ZN-06S(L)WG-ZION-MW-6L-052506-MS-0095/25/2006ND (200) -MW-ZN-06S(U)WG-ZION-MW-6U-052606-MS-0115/26/2006ND (200) -MW-ZN-07S(L)WG-ZION-MW-7L-052506-MS-0075/25/2006ND (200) -MW-ZN-07S(U)WG-ZION-MW-7U-052406-MS-0055/24/2006ND (200) -MW-ZN-08S(L)WG-ZION-MW-8L-052406-MS-0015/24/2006ND (200) -MW-ZN-08S(U)WG-ZION-MW-8U-052406-MS-0035/24/2006ND (200) -MW-ZN-09SWG-ZN-MW-ZN-09-052606-DS-085/26/2006ND (200) -

MW-ZN-09SWG-ZN-MW-ZN-09-052606-DS-09Duplicate (08)5/26/2006ND (200) -MW-ZN-10S(L)WG-ZN-MW-ZN-10L-072806-MS-0057/28/2006ND (200) -MW-ZN-10S(U)WG-ZN-MW-ZN-10U-072806-MS-0037/28/2006ND (200) -

MW-ZN-10S(U)WG-ZN-MW-ZN-10U-072806-MS-0047/28/2006ND (200) -MW-ZN-11S(L)WG-ZN-MW-ZN-11L-072806-TL-0027/28/2006ND (200) -MW-ZN-11S(U)WG-ZN-MW-ZN-11U-072806-TL-0017/28/2006ND (200) -SW-ZN-1WS-ZION-LAKE-052606-MS-0155/26/2006ND (200) -TW-ZN-100GW-071706-JL-TW-ZN-1007/17/2006ND (200) -

TW-ZN-101GW-071706-JL-TW-ZN-1017/17/2006ND (200) -

TW-ZN-102GW-071706-JL-TW-ZN-1027/17/2006ND (200) -

TW-ZN-103GW-071706-JL-TW-ZN-1037/17/2006ND (200) -

Notes: Samples anal y zed b y: Teled y ne Brown En g ineerin g , Inc.(1) Sample locations include the well identifier followed b y a sample depth indicator of 'U' for the upper portion of the screen or 'L' for the lower portion of the screen.

ND ( ) - Not detected at a concentration above the LLD. Value in parentheses is the LLD.

LLD - Lower limit of detection.

- -Non-detect value, +/- value not reported.

CRA 45136 (22) Zion Station q014aI-XT-WG-all-45136-30-MC 8/10/2006 Revision 1 TABLE 5.2 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Page 1 of 10 Sample Location (1):MW-ZN-01S(L)MW-ZN-01S(L)MW-ZN-01S(U)MW-ZN-01S(U)MW-ZN-02S(L)MW-ZN-02S(L)

Sam p le Identi fication:WG-ZN-MW-ZN-01L-052606-DS-07 ResultWG-ZN-MW-ZN-01U-052606-DS-05 ResultWG-ZN-MW-ZN-02L-052606-DS-06 R esult Sam ple Date:5/26/2006Error5/26/2006Error5/26/2006Error Units Tar g et RadionuclidesBarium-140pCi/LND (60) -ND (60) -ND (60) -Cesium-134pCi/LND (10) -ND (10) -ND (10) -

Cesium-13 7pCi/LND (18) -ND (18) -ND (18) -Cobalt-58pCi/LND (15) -ND (15) -ND (15) -

Cobalt-60pCi/LND (15) -ND (15) -ND (15) -

Iron-59pCi/LND (30) -ND (30) -ND (30) -

Lanthanum-140pCi/LND (15) -ND (15) -ND (15) -

Man ganese-54pCi/LND (15) -ND (15) -ND (15) -Niobium-95pCi/LND (10) -ND (10) -ND (10) -

Strontium-89/90 (Total)pCi/LND (2) -ND (2) -ND (2) -

Zinc-65pCi/LND (30) -ND (30) -ND (30) -

Zirconium-95pCi/LND (10) -ND (10) -ND (10) -

Non-Target Radionuclides (2)Actinium-228pCi/L35.23 +/-10.3RNI-RNI-Potassium-40pCi/L53.04 +/-34.2RNI-81.03 +/-42.45 Notes: Samples anal y zed b y: Teled y ne Brow n (1) - Sample locations include the well identifier followed b y a depth indicator of 'U' for the upper portion of the screen

or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturall y occurrin g.RNI- Radionuclide Not Identified durin g anal y sis.ND ( ) - Not detected at a concentration above the LLD. Value in parentheses is the LLD.

LLD - Lower limit of detection.

U* - Compound/Anal y te not detected.

Peak not identified, but forced activit y concentration exceeds Minimu m Detectable Concentration and 3 si g ma.- -Non-detect value, +/- value not reported.

CRA 45136 (22) Zion Station q014aI-XT-WG-all-45136-30-MC 8/10/2006 Revision 1 TABLE 5.2 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Page 2 of 10 Sample Location (1): Sam p le Identi f ication: Sam p le Date: Units Tar g et RadionuclidesBarium-140pCi/LCesium-134pCi/L

Cesium-13 7 pCi/LCobalt-58pCi/L Cobalt-60pCi/L Iron-59pCi/L Lanthanum-140pCi/L

Man ganese-54pCi/LNiobium-95pCi/L Strontium-89/90 (Total)pCi/L Zinc-65pCi/L Zirconium-95pCi/L Non-Target Radionuclides (2)Actinium-228pCi/LPotassium-40pCi/L Notes: Samples anal y zed b y: Teled y ne Brow n (1) - Sample locations include the well identifier followed b y a depth indicator of 'U' for the upper portion of the screen

or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturall y occurrin g.RNI- Radionuclide Not Identified durin g anal y sis.ND ( ) - Not detected at a concentration above the LLD. Val u LLD - Lower limit of detection.

U* - Compound/Anal y te not detected.

Peak not identified, but forced activit y concentration exceeds Minimu m Detectable Concentration and 3 si g ma.- -Non-detect value, +/- value not reported. MW-ZN-02S(U)MW-ZN-02S(U)MW-ZN-03S(L)MW-ZN-03S(L)MW-ZN-03S(U)MW-ZN-03S(U)

WG-ZN-MW-ZN-02U-052606-DS-04 ResultWG-ZN-MW-ZN-03L-052506-DS-03 ResultWG-ZN-MW-ZN-03U-052506-DS-01 R esult5/26/2006Error5/25/2006Error5/25/2006ErrorND (60) -ND (60) -ND (60) -ND (10) -ND (10) -ND (10) -

ND (18) -ND (18) -ND (18) -

ND (15) -ND (15) -ND (15) -

ND (15) -ND (15) -ND (15) -

ND (30) -ND (30) -ND (30) -

ND (15) -ND (15) -ND (15) -

ND (15) -ND (15) -ND (15) -

ND (10) -ND (10) -ND (10) -ND (2) -ND (2) -ND (2) -ND (30) -ND (30) -ND (30) -

ND (10) -ND (10) -ND (10) -RNI-RNI-RNI-73.65 +/-44.4 7RNI-RNI-CRA 45136 (22) Zion Station q014aI-XT-WG-all-45136-30-MC 8/10/2006 Revision 1 TABLE 5.2 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Page 3 of 10 Sample Location (1): Sam p le Identi f ication: Sam p le Date: Units Tar g et RadionuclidesBarium-140pCi/LCesium-134pCi/L

Cesium-13 7 pCi/LCobalt-58pCi/L Cobalt-60pCi/L Iron-59pCi/L Lanthanum-140pCi/L

Man ganese-54pCi/LNiobium-95pCi/L Strontium-89/90 (Total)pCi/L Zinc-65pCi/L Zirconium-95pCi/L Non-Target Radionuclides (2)Actinium-228pCi/LPotassium-40pCi/L Notes: Samples anal y zed b y: Teled y ne Brow n (1) - Sample locations include the well identifier followed b y a depth indicator of 'U' for the upper portion of the screen

or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturall y occurrin g.RNI- Radionuclide Not Identified durin g anal y sis.ND ( ) - Not detected at a concentration above the LLD. Val u LLD - Lower limit of detection.

U* - Compound/Anal y te not detected.

Peak not identified, but forced activit y concentration exceeds Minimu m Detectable Concentration and 3 si g ma.- -Non-detect value, +/- value not reported. MW-ZN-03S(U)MW-ZN-03S(U)MW-ZN-04S(L)MW-ZN-04S(L)MW-ZN-04S(U)MW-ZN-04S(U)

WG-ZN-MW-ZN-03U-052506-DS-02 ResultWG-ZION-MW-4L-052406-MB-004 ResultWG-ZION-MW-4U-052406-MB-002 R esult5/25/2006Error5/24/2006Error5/24/2006Error D u p licateND (60) -ND (60) -ND (60) -ND (10) U*-ND (10) -ND (10) -ND (18) -ND (18) -ND (18) -

ND (15) -ND (15) -ND (15) -

ND (15) -ND (15) -ND (15) -

ND (30) -ND (30) -ND (30) -

ND (15) -ND (15) -ND (15) -

ND (15) -ND (15) -ND (15) -

ND (10) -ND (10) -ND (10) -ND (2) -ND (2) -ND (2) -ND (30) U*-ND (30) -ND (30) -ND (10) -ND (10) -ND (10) -RNI-RNI-RNI-RNI-85.89 +/-44.24RNI-CRA 45136 (22) Zion Station q014aI-XT-WG-all-45136-30-MC 8/10/2006 Revision 1 TABLE 5.2 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Page 4 of 10 Sample Location (1): Sam p le Identi f ication: Sam p le Date: Units Tar g et RadionuclidesBarium-140pCi/LCesium-134pCi/L

Cesium-13 7 pCi/LCobalt-58pCi/L Cobalt-60pCi/L Iron-59pCi/L Lanthanum-140pCi/L

Man ganese-54pCi/LNiobium-95pCi/L Strontium-89/90 (Total)pCi/L Zinc-65pCi/L Zirconium-95pCi/L Non-Target Radionuclides (2)Actinium-228pCi/LPotassium-40pCi/L Notes: Samples anal y zed b y: Teled y ne Brow n (1) - Sample locations include the well identifier followed b y a depth indicator of 'U' for the upper portion of the screen

or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturall y occurrin g.RNI- Radionuclide Not Identified durin g anal y sis.ND ( ) - Not detected at a concentration above the LLD. Val u LLD - Lower limit of detection.

U* - Compound/Anal y te not detected.

Peak not identified, but forced activit y concentration exceeds Minimu m Detectable Concentration and 3 si g ma.- -Non-detect value, +/- value not reported. MW-ZN-05S(L)MW-ZN-05S(L)MW-ZN-05S(U)MW-ZN-05S(U)MW-ZN-06S(L)MW-ZN-06S(L)

WG-ZION-MW-5L-052606-MS-013 ResultWG-ZION-MW-5U-052606-MS-017 ResultWG-ZION-MW-6L-052506-MS-009 R esult5/26/2006Error5/26/2006Error5/25/2006ErrorND (60) -ND (60) -ND (60) -ND (10) -ND (10) -ND (10) U*-

ND (18) -ND (18) -ND (18) -

ND (15) -ND (15) -ND (15) -

ND (15) -ND (15) -ND (15) -

ND (30) -ND (30) -ND (30) -

ND (15) -ND (15) -ND (15) -

ND (15) -ND (15) -ND (15) -

ND (10) -ND (10) -ND (10) U*-ND (2) -ND (2) -ND (2) -ND (30) -ND (30) -ND (30) U*-

ND (10) -ND (10) -ND (10) -RNI-RNI-RNI-RNI-RNI-RNI-CRA 45136 (22) Zion Station q014aI-XT-WG-all-45136-30-MC 8/10/2006 Revision 1 TABLE 5.2 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Page 5 of 10 Sample Location (1): Sam p le Identi f ication: Sam p le Date: Units Tar g et RadionuclidesBarium-140pCi/LCesium-134pCi/L

Cesium-13 7 pCi/LCobalt-58pCi/L Cobalt-60pCi/L Iron-59pCi/L Lanthanum-140pCi/L

Man ganese-54pCi/LNiobium-95pCi/L Strontium-89/90 (Total)pCi/L Zinc-65pCi/L Zirconium-95pCi/L Non-Target Radionuclides (2)Actinium-228pCi/LPotassium-40pCi/L Notes: Samples anal y zed b y: Teled y ne Brow n (1) - Sample locations include the well identifier followed b y a depth indicator of 'U' for the upper portion of the screen

or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturall y occurrin g.RNI- Radionuclide Not Identified durin g anal y sis.ND ( ) - Not detected at a concentration above the LLD. Val u LLD - Lower limit of detection.

U* - Compound/Anal y te not detected.

Peak not identified, but forced activit y concentration exceeds Minimu m Detectable Concentration and 3 si g ma.- -Non-detect value, +/- value not reported. MW-ZN-06S(U)MW-ZN-06S(U)MW-ZN-07S(L)MW-ZN-07S(L)MW-ZN-07S(U)MW-ZN-07S(U)

WG-ZION-MW-6U-052606-MS-011 ResultWG-ZION-MW-7L-052506-MS-007 ResultWG-ZION-MW-7U-052406-MS-005 R esult5/26/2006Error5/25/2006Error5/24/2006ErrorND (60) -ND (60) -ND (60) -ND (10) -ND (10) U*-ND (10) U*-

ND (18) -ND (18) -ND (18) -

ND (15) -ND (15) -ND (15) -

ND (15) -ND (15) -ND (15) -

ND (30) -ND (30) -ND (30) -

ND (15) -ND (15) -ND (15) -

ND (15) -ND (15) -ND (15) -

ND (10) -ND (10) -ND (10) -ND (2) -ND (2) -ND (2) -ND (30) -ND (30) -ND (30) U*-

ND (10) -ND (10) -ND (10) -RNI-RNI-RNI-RNI-RNI-RNI-CRA 45136 (22) Zion Station q014aI-XT-WG-all-45136-30-MC 8/10/2006 Revision 1 TABLE 5.2 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Page 6 of 10 Sample Location (1): Sam p le Identi f ication: Sam p le Date: Units Tar g et RadionuclidesBarium-140pCi/LCesium-134pCi/L

Cesium-13 7 pCi/LCobalt-58pCi/L Cobalt-60pCi/L Iron-59pCi/L Lanthanum-140pCi/L

Man ganese-54pCi/LNiobium-95pCi/L Strontium-89/90 (Total)pCi/L Zinc-65pCi/L Zirconium-95pCi/L Non-Target Radionuclides (2)Actinium-228pCi/LPotassium-40pCi/L Notes: Samples anal y zed b y: Teled y ne Brow n (1) - Sample locations include the well identifier followed b y a depth indicator of 'U' for the upper portion of the screen

or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturall y occurrin g.RNI- Radionuclide Not Identified durin g anal y sis.ND ( ) - Not detected at a concentration above the LLD. Val u LLD - Lower limit of detection.

U* - Compound/Anal y te not detected.

Peak not identified, but forced activit y concentration exceeds Minimu m Detectable Concentration and 3 si g ma.- -Non-detect value, +/- value not reported. MW-ZN-08S(L)MW-ZN-08S(L)MW-ZN-08S(U)MW-ZN-08S(U)MW-ZN-09SMW-ZN-09S WG-ZION-MW-8L-052406-MS-001 ResultWG-ZION-MW-8U-052406-MS-003 ResultWG-ZN-MW-ZN-09-052606-DS-08 R esult5/24/2006Error5/24/2006Error5/26/2006ErrorND (60) -ND (60) -ND (60) -ND (10) U*-ND (10) -ND (10) -ND (18) -ND (18) -ND (18) -

ND (15) -ND (15) -ND (15) -

ND (15) -ND (15) -ND (15) -

ND (30) -ND (30) -ND (30) -

ND (15) -ND (15) -ND (15) -

ND (15) -ND (15) -ND (15) -

ND (10) -ND (10) -ND (10) -ND (2) -ND (2) -ND (2) -ND (30) -ND (30) -ND (30) -

ND (10) -ND (10) -ND (10) -RNI-RNI-RNI-RNI-69.37 +/-45.71RNI-CRA 45136 (22) Zion Station q014aI-XT-WG-all-45136-30-MC 8/10/2006 Revision 1 TABLE 5.2 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Page 7 of 10 Sample Location (1): Sam p le Identi f ication: Sam p le Date: Units Tar g et RadionuclidesBarium-140pCi/LCesium-134pCi/L

Cesium-13 7 pCi/LCobalt-58pCi/L Cobalt-60pCi/L Iron-59pCi/L Lanthanum-140pCi/L

Man ganese-54pCi/LNiobium-95pCi/L Strontium-89/90 (Total)pCi/L Zinc-65pCi/L Zirconium-95pCi/L Non-Target Radionuclides (2)Actinium-228pCi/LPotassium-40pCi/L Notes: Samples anal y zed b y: Teled y ne Brow n (1) - Sample locations include the well identifier followed b y a depth indicator of 'U' for the upper portion of the screen

or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturall y occurrin g.RNI- Radionuclide Not Identified durin g anal y sis.ND ( ) - Not detected at a concentration above the LLD. Val u LLD - Lower limit of detection.

U* - Compound/Anal y te not detected.

Peak not identified, but forced activit y concentration exceeds Minimu m Detectable Concentration and 3 si g ma.- -Non-detect value, +/- value not reported. MW-ZN-09SMW-ZN-09SMW-ZN-10S(L)MW-ZN-10S(L)MW-ZN-10S(U)MW-ZN-10S(U)

WG-ZN-MW-ZN-09-052606-DS-09 ResultWG-ZN-MW-ZN-10L-072806-MS-005 ResultWG-ZN-MW-ZN-10U-072806-MS-003 R esult5/26/2006Error7/28/2006Error7/28/2006Error D u p licateND (60) -ND (60) -ND (60) -ND (10) -ND (10) -ND (10) -

ND (18) -ND (18) -ND (18) -

ND (15) -ND (15) -ND (15) -

ND (15) -ND (15) -ND (15) -

ND (30) -ND (30) -ND (30) -

ND (15) -ND (15) -ND (15) -

ND (15) -ND (15) -ND (15) -

ND (10) -ND (10) -ND (10) -ND (2) -ND (2) -ND (2) -ND (30) -ND (30) -ND (30) -

ND (10) -ND (10) -ND (10) -RNI-RNI-RNI-RNI-RNI-83.66 +/-42.25 CRA 45136 (22) Zion Station q014aI-XT-WG-all-45136-30-MC 8/10/2006 Revision 1 TABLE 5.2 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Page 8 of 10 Sample Location (1): Sam p le Identi f ication: Sam p le Date: Units Tar g et RadionuclidesBarium-140pCi/LCesium-134pCi/L

Cesium-13 7 pCi/LCobalt-58pCi/L Cobalt-60pCi/L Iron-59pCi/L Lanthanum-140pCi/L

Man ganese-54pCi/LNiobium-95pCi/L Strontium-89/90 (Total)pCi/L Zinc-65pCi/L Zirconium-95pCi/L Non-Target Radionuclides (2)Actinium-228pCi/LPotassium-40pCi/L Notes: Samples anal y zed b y: Teled y ne Brow n (1) - Sample locations include the well identifier followed b y a depth indicator of 'U' for the upper portion of the screen

or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturall y occurrin g.RNI- Radionuclide Not Identified durin g anal y sis.ND ( ) - Not detected at a concentration above the LLD. Val u LLD - Lower limit of detection.

U* - Compound/Anal y te not detected.

Peak not identified, but forced activit y concentration exceeds Minimu m Detectable Concentration and 3 si g ma.- -Non-detect value, +/- value not reported. MW-ZN-10S(U)MW-ZN-10S(U)MW-ZN-11S(L)MW-ZN-11S(L)MW-ZN-11S(U)MW-ZN-11S(U)

WG-ZN-MW-ZN-10U-072806-MS-004 ResultWG-ZN-MW-ZN-11L-072806-TL-002 ResultWG-ZN-MW-ZN-11U-072806-TL-001 R esult7/28/2006Error7/28/2006Error7/28/2006ErrorND (60) -ND (60) -ND (60) -ND (10) U*-ND (10) U*-ND (10) U*-ND (18) -ND (18) -ND (18) -

ND (15) -ND (15) -ND (15) -

ND (15) -ND (15) -ND (15) -

ND (30) -ND (30) -ND (30) -

ND (15) -ND (15) -ND (15) -

ND (15) -ND (15) -ND (15) -

ND (10) -ND (10) -ND (10) -ND (2) -ND (2) -ND (2) -ND (30) U*-ND (30) -ND (30) U*-ND (10) -ND (10) -ND (10) -RNI-RNI-RNI-RNI-RNI-RNI-CRA 45136 (22) Zion Station q014aI-XT-WG-all-45136-30-MC 8/10/2006 Revision 1 TABLE 5.2 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Page 9 of 10 Sample Location (1): Sam p le Identi f ication: Sam p le Date: Units Tar g et RadionuclidesBarium-140pCi/LCesium-134pCi/L

Cesium-13 7 pCi/LCobalt-58pCi/L Cobalt-60pCi/L Iron-59pCi/L Lanthanum-140pCi/L

Man ganese-54pCi/LNiobium-95pCi/L Strontium-89/90 (Total)pCi/L Zinc-65pCi/L Zirconium-95pCi/L Non-Target Radionuclides (2)Actinium-228pCi/LPotassium-40pCi/L Notes: Samples anal y zed b y: Teled y ne Brow n (1) - Sample locations include the well identifier followed b y a depth indicator of 'U' for the upper portion of the screen

or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturall y occurrin g.RNI- Radionuclide Not Identified durin g anal y sis.ND ( ) - Not detected at a concentration above the LLD. Val u LLD - Lower limit of detection.

U* - Compound/Anal y te not detected.

Peak not identified, but forced activit y concentration exceeds Minimu m Detectable Concentration and 3 si g ma.- -Non-detect value, +/- value not reported. SW-ZN-1SW-ZN-1TW-ZN-100TW-ZN-100TW-ZN-101TW-ZN-101TW-ZN-101TW-ZN-101 WS-ZION-LAKE-052606-MS-015 ResultGW-071706-JL-TW-ZN-100 ResultGW-071706-JL-TW-ZN-101 ResultGW-071706-JL-TW-ZN-101 R esult5/26/2006Error7/17/2006Error7/17/2006Error7/17/2006Error R e-runND (60) -ND (60) -ND (60) -ND (60) -ND (10) -ND (10) -ND (10) -ND (10) U*-

ND (18) -ND (18) -ND (18) -ND (18) -

ND (15) -ND (15) -ND (15) -ND (15) -

ND (15) -ND (15) -ND (15) -ND (15) -

ND (30) -ND (30) -ND (30) -ND (30) -

ND (15) -ND (15) -ND (15) -ND (15) -

ND (15) -ND (15) -ND (15) -ND (15) -

ND (10) -ND (10) -ND (10) -ND (10) -ND (2)-ND (2) -ND (2) ---ND (30) -ND (30) -ND (30) -ND (30) U*-

ND (10) -ND (10) -ND (10) -ND (10) -RNI-RNIRNI-RNI-106.8 +/-48.41RNI--RNI-RNI-CRA 45136 (22) Zion Station q014aI-XT-WG-all-45136-30-MC 8/10/2006 Revision 1 TABLE 5.2 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Page 10 of 10 Sample Location (1): Sam p le Identi f ication: Sam p le Date: Units Tar g et RadionuclidesBarium-140pCi/LCesium-134pCi/L

Cesium-13 7 pCi/LCobalt-58pCi/L Cobalt-60pCi/L Iron-59pCi/L Lanthanum-140pCi/L

Man ganese-54pCi/LNiobium-95pCi/L Strontium-89/90 (Total)pCi/L Zinc-65pCi/L Zirconium-95pCi/L Non-Target Radionuclides (2)Actinium-228pCi/LPotassium-40pCi/L Notes: Samples anal y zed b y: Teled y ne Brow n (1) - Sample locations include the well identifier followed b y a depth indicator of 'U' for the upper portion of the screen

or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturall y occurrin g.RNI- Radionuclide Not Identified durin g anal y sis.ND ( ) - Not detected at a concentration above the LLD. Val u LLD - Lower limit of detection.

U* - Compound/Anal y te not detected.

Peak not identified, but forced activit y concentration exceeds Minimu m Detectable Concentration and 3 si g ma.- -Non-detect value, +/- value not reported. TW-ZN-102TW-ZN-102TW-ZN-103TW-ZN-103 GW-071706-JL-TW-ZN-102 ResultGW-071706-JL-TW-ZN-103 R esult7/17/2006Error7/17/2006ErrorND (60) -ND (60) -ND (10) -ND (10) -

ND (18) -ND (18) -

ND (15) -ND (15) -

ND (15) -ND (15) -

ND (30) -ND (30) -

ND (15) -ND (15) -

ND (15) -ND (15) -

ND (10) -ND (10) -ND (2) -ND (2) -ND (30) -ND (30) -

ND (10) -ND (10) -RNI-RNI-RNI-RNI-CRA 45136 (22) Zion Station q014aI-XT-WG-all-45136-30-MC 8/10/2006 Revision 1 Revision 0 045136 (22) Zion Station APPENDIX A WATER WELL INVENTORY RECORDS A.1 BANKS 2006 WATER WELL REPORT A.2 ISWS LOGS Revision 0 045136 (22) Zion Station A.1 BANKS 2006 WATER WELL REPORT Water Well Report June 7, 2006

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Conestoga-Rovers &

Associates 8615 W Bryn Mawr Avenue Chicago, IL 60631 Zion Generating Station Zion, IL Lake County 060706-001 CLIENT SITE P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

S h e r i d a n R d I l l i n o i s N S h e r i d a n R d G a l i l e e A v e G i l b o a A v e 2 7 t h S t E l i z a b e t h A v e W W a d s w o r t h R d 2 0 t h S t 2 1 s t S t 2 2 n d S t C t y A 1 3 1 7 t h S t 1 5 t h S t P a t o m o s A v e F u l t o n A v e#Y#Y#Y#Y##Y#Y#Y#Y#Y#Y#Y#Y#Y##Y####Y#Y#Y#Y#Y##Y##Y#Y##Y####Y##Y##Y#####Y#Y##############1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 1 3 1 4 1 5 1 6 1 7 1 8 1 9 2 0 2 1 2 2 2 3 2 4 2 5 2 6 2 7 2 8 2 9 3 0 3 1 3 2 3 3 3 4 3 5 3 6 3 7 3 8 3 9 4 0 4 1 4 2 4 3 4 4 4 5 4 6 4 7 4 8 4 9 5 0 5 1 5 2 5 4 5 5 5 6 5 7 5 8 5 9 5 3 B a n k s I n f o r m a t i o n S o l u t i o n s , I n c.W a t e r W e l l R e p o r t T M M a p o f W e l l s w i t h i n 1 M i l e N`A i r p o r tP H o s p i t a l H i g h w a y P r i m a r y r o a d S e c o n d a r y a n d c o n n e c t i n g r o a d L o c a l r o a d A c c e s s r o a dÚS u b j e c t S i t e#G r o u n d W a t e r W e l l#Y G r o u n d W a t e r W e l l s (C l u s t e r)W a t e r b o d y P a r k S t a t e 0 0.5 1 1.5 2 M i l e s B a n k s I n f o r m a t i o n S o l u t i o n s , I n c.P.O. B o x 1 2 8 5 1 , C a p i t o l S t a t i o n A u s t i n , T e x a s 7 8 7 1 1 7 0 0 N. L a m a r , S u i t e 2 0 0 A u s t i n , T e x a s 7 8 7 0 3 5 1 2-4 7 8-0 0 5 9 F A X 5 1 2-4 7 8-1 4 3 3 E M a i l: B A N K S@B A N K S I N F O.C O M J u n e 7 , 2 0 0 6 Water Well Report DETAILSŽBanks Information

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1709700030 1209702313 J. Sekowski 1/1/1950-87.83276 42.45169 62 'N/A 1 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700033 1209702312 W.T. Loblow N/A-87.83159 42.44537 200 'N/A 2 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700031 1209702317 J. Sekowski 1/1/1952-87.83524 42.4499 82 'N/A 3 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700034 1209702314 Shiloh Park N/A-87.83524 42.4499 1569 'N/A 3 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700032 1209702316 Zion City Well N/A-87.82679 42.44535 1025 'N/A 4 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700036 1209702051 Heat Plant N/A-87.82679 42.44535 175 'N/A 4 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700039 1209737424 Tom C. Hanson N/A-87.80674 42.45072 180 'N/A 5 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700040 1209726844 City of Zion 11/1/1972-87.81565 42.44982 15 'N/A 6 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700041 1209702319 F.H. Ferguson N/A-87.82311 42.44623 154 'N/A 7 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700042 1209702320 Hotel Zion Home N/A-87.8231 42.44804 225 'N/A 8 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700043 1209702926 Alvin Justin 8/7/1969-87.80287 42.45683 120 'N/A 9 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700044 1209703060 Harry G. Spencer 11/20/1970

-87.80156 42.45683 142 'N/A 9 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700045 1209702322 Zion Estates N/A-87.80146 42.44612 138 'N/A 10 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700065 1209702292 Clude Koontr 9/1/1940-87.83029 42.46073 266 'N/A 11 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700070 1209725154 Busch & Larson 1/1/1976-87.82809 42.46127 219 'N/A 12 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700071 1209725155 Busch & Larson 1/24/1977-87.82865 42.46128 195 'N/A 12 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700088 1209733751 Don Falstad 9/30/1977-87.8285 42.46182 160 'N/A 12 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700075 1209703280 Paul Richardson 7/1/1971-87.82885 42.45895 322 'N/A 13 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700066 1209702617 C. Edwards 1/1/1963-87.82662 42.46526 146 'N/A 14 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700067 1209702618 C. Edwards 1/1/1963-87.82662 42.46526 160 'N/A 14 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700068 1209702619 H. Jorgenson 1/1/1963-87.82666 42.46526 137 'N/A 14 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700069 1209702798 A.R. Casteel 5/1/1968-87.82527 42.46472 315 'N/A 14 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700074 1209703883 O'Neal Humphries 10/27/1972

-87.82666 42.46526 127 'N/A 14 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700076 1209703399 Jerry Moyer 10/1/1971-87.8256 42.46414 242 'N/A 14 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700077 1209724153 Si Henarichs Agency 11/12/1973

-87.82705 42.4684 138 'N/A 15 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700080 1209726697 Bruce Griffith 9/21/1978-87.82715 42.46295 145 'N/A 16 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700081 1209726818 Clayton Watts 12/1/1977-87.82908 42.46408 274 'N/A 17 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700073 1209725157 Howard Freemark 12/1/1976-87.82668 42.46256 190 'N/A 18 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700084 1209727962 William Blagg, Jr.

2/14/1986-87.82664 42.46163 168 'N/A 18 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700087 1209733750 Veterans Administration 265 12/8/1983-87.82514 42.46636 150 'N/A 19 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700090 1209702287 William Nacker 1/1/1940-87.82231 42.46317 119 'N/A 20 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700108 1209727833 Tim Hough 11/30/1985

-87.82114 42.46289 55 'N/A 20 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700091 1209702288 Camp Logan 1/1/1941-87.80954 42.46519 110 'N/A 21 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700094 1209702615 Homer McNabb 1/1/1963-87.82425 42.46162 66 'N/A 22 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700096 1209702796 William Walters 8/11/1968-87.81839 42.46853 160 'N/A 23 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700097 1209702797 Jim Middleton 4/5/1968-87.81566 42.46434 80 'N/A 24 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700098 1209725066 Craig Anderson 11/18/1976

-87.8169 42.46845 127 'N/A 25 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700093 1209702614 James Fout 1/1/1963-87.81682 42.47065 130 'N/A 26 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700101 1209703882 Pitcher Construction Co.

4/3/1973-87.81686 42.47065 138 'N/A 26 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700104 1209703416 Billy Holland 11/1/1971-87.81811 42.46991 141 'N/A 26 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700105 1209724152 Sihendrick Agency 1/1/1974-87.82027 42.4628 266 'N/A 27 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700095 1209702616 Harold McNabb 1/1/1963-87.81929 42.46341 177 'N/A 28 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700100 1209703881 Ray Neal 6/2/1972-87.81807 42.46249 134 'N/A 28 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700102 1209703921 Steve Markabrad 5/1/1973-87.8179 42.46237 143 'N/A 28 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700106 1209724846 Busch & Larson 6/12/1976-87.81931 42.46291 199 'N/A 28 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700107 1209724252 Albert Klemin 7/1/1974-87.82197 42.45803 167 'N/A 29 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700109 1209729270 Ron Conde 3/3/1987-87.81524 42.46257 46 'N/A 30 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700110 1209728125 Stacy Dickerson 5/15/1986-87.81318 42.45892 136 'N/A 31 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700092 1209703077 C.N. Clark 1/1/1971-87.81844 42.46637 77 'N/A 32 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700099 1209724431 R. Conde 4/1/1975-87.82049 42.46625 61 'N/A 32 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700103 1209703357 Glen Martin 9/1/1971-87.81933 42.46704 147 'N/A 32 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700111 1209731926 Ron Conde 2/10/1989-87.81932 42.46703 56 'N/A 32 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700113 1209733748 Jim Fout 5/24/1979-87.81943 42.46661 49 'N/A 32 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700112 1209733747 Mary Barclay 4/2/1979-87.82261 42.46762 89 'N/A 33 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700114 1209733749 Glen Martin 4/5/1977-87.82049 42.46935 116 'N/A 34 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700115 1209702911 Grace Sills 7/3/1969-87.80023 42.46109 123 'N/A 35 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700117 1209702795 William Jenko 11/15/1968

-87.80139 42.46192 180 'N/A 35 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700116 1209702993 Rudy Copen 11/21/1969

-87.80208 42.4589 125 'N/A 36 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700118 1209733746 Progressive Builders 9/27/1979-87.80505 42.46026 104 'N/A 37 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700123 1209702454 E.C. Buese 2/1/1968-87.83155 42.43991 225 'N/A 38 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700128 1209702802 James Barnes 11/1/1968-87.8288 42.43442 147 'N/A 39 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700191 1209733862 Don Miesner 10/5/1979-87.82881 42.43518 156 'N/A 39 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700129 1209702803 Mrs. Michael Lester 12/1/1968-87.82673 42.43017 146 'N/A 40 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

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1709700190 1209733861 Jim Middleton 5/25/1979-87.82585 42.42971 195 'N/A 40 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700209 1209735998 J & E Builders 8/9/1990-87.82687 42.43084 160 'N/A 40 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700215 1209736004 Victor Smith 4/12/1989-87.82687 42.43084 163 'N/A 40 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

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1709700218 1209736295 Vivian Edwards 7/19/1991-87.82687 42.43084 187 'N/A 40 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700130 1209725067 Busch & Larson 11/1/1976-87.83021 42.43512 198 'N/A 41 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700131 1209724432 H. Khayat 12/5/1975-87.82669 42.42893 220 'N/A 42 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700231 1209738419 Robert May 7/20/1994-87.82684 42.42902 165 'N/A 42 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700237 1209737098 Scott Walldan 8/10/1992-87.82689 42.42902 159 'N/A 42 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700240 1209745167 Extra Value Liquors N/A-87.82689 42.42902 0 'Public Supply 42 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700241 1209745166 Al's Tap N/A-87.82684 42.42902 0 'Public Supply 42 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700133 1209725159 Parker Peterson 2/1/1977-87.8312 42.43315 152 'N/A 43 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700138 1209703079 Charles Lotz 1/1/1971-87.83117 42.4338 165 'N/A 43 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700144 1209703281 Charles T. Mason 5/1/1971-87.83129 42.43237 65 'N/A 43 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700125 1209702623 J. Fortner 1/1/1963-87.83171 42.4345 185 'N/A 44 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700146 1209724711 Hamms Concrete 10/1/1974-87.83257 42.43445 232 'N/A 44 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700164 1209729070 Victor Smith 2/9/1987-87.83166 42.43476 215 'N/A 44 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700227 1209738345 Gary Reinhardt 7/6/1994-87.83167 42.4345 190 'N/A 44 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700235 1209737096 Sheila Fetherline 6/25/1992-87.83171 42.4345 269 'N/A 44 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700127 1209702625 Mike Paslowsky 1/1/1963-87.8317 42.42905 176 'N/A 45 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700168 1209727858 Helen Khayat 3/13/1986-87.8309 42.42959 174 'N/A 45 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700229 1209737741 Bruce & Chris Galgan 8/5/1993-87.8317 42.42905 180 'N/A 45 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700119 1209701450 Lotz Construction 6/1/1970-87.82746 42.43267 144 'N/A 46 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700172 1209729422 Mike Dugan 6/16/1987-87.82807 42.43361 150 'N/A 46 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700183 1209733854 David Ernstmeyer 8/12/1980-87.82882 42.43302 142 'N/A 46 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700205 1209735994 C & S Builders 1/10/1991-87.82925 42.43267 157 'N/A 46 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700207 1209735996 Stacy Dickerson 9/20/1990-87.82929 42.43267 43 'N/A 46 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700217 1209736294 Perry Dalke 6/1/1991-87.82685 42.43447 180 'N/A 46 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700153 1209728546 Robert Middleton 10/7/1986-87.83052 42.43177 225 'N/A 47 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700165 1209730365 Gary Post 4/25/1988-87.83052 42.43172 153 'N/A 47 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700187 1209733858 R.L. Humphres 6/28/1976-87.83052 42.43177 155 'N/A 47 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700189 1209733860 Carl Michelsen 11/15/1980

-87.83052 42.43177 170 'N/A 47 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700194 1209733865 Pitcher Construction 2/24/1975-87.83052 42.43177 166 'N/A 47 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700195 1209733866 Pitcher Construction 6/16/1975-87.83052 42.43177 166 'N/A 47 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700196 1209733867 Pitcher Construction Co.

10/11/1976

-87.83047 42.43177 169 'N/A 47 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700213 1209736002 Lucy's Appliances 11/9/1990-87.83052 42.43177 155 'N/A 47 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700216 1209736005 Victor L. Smith 9/28/1990-87.83052 42.43177 166 'N/A 47 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700199 1209738700 Thersa Wilbanks 9/15/1983-87.83476 42.43919 180 'N/A 48 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700135 1209724485 Bill Nikkila 8/1/1975-87.82916 42.42895 186 'N/A 49 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700139 1209724592 Herbert Wubbell 9/1/1975-87.8286 42.42854 173 'N/A 49 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700143 1209703922 Robert Ernstmeyer 5/1/1973-87.82939 42.42882 176 'N/A 49 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700156 1209727421 Ken Kruse 7/31/1985-87.82932 42.42904 175 'N/A 49 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700171 1209727949 Brooks Builders 4/1/1986-87.83044 42.42855 194 'N/A 49 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700210 1209735999 Helena Khavat 4/27/1990-87.82932 42.42904 168 'N/A 49 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700211 1209736000 Helena Khavat 3/22/1990-87.82932 42.42904 200 'N/A 49 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700212 1209736001 Helena Khavat 10/27/1989

-87.82932 42.42904 156 'N/A 49 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700163 1209726713 Bo Rea 8/1/1978-87.83395 42.4346 160 'N/A 50 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700221 1209737885 Reggie Mosley 10/15/1993

-87.83414 42.43451 175 'N/A 50 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700223 1209738706 Ram Builders 1/23/1995-87.83414 42.43451 182 'N/A 50 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700228 1209737740 Helen Binning 7/2/1993-87.83414 42.43451 170 'N/A 50 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700136 1209725218 Lester Carman 4/1/1977-87.83146 42.43024 167 'N/A 51 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700170 1209727931 Eija Tuovinen 2/10/1986-87.83268 42.43069 222 'N/A 51 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700220 1209736482 Helen Binning 12/17/1991

-87.83169 42.43087 172 'N/A 51 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700224 1209737425 Carol Donev 10/2/1992-87.83174 42.43087 170 'N/A 51 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700120 1209703010 D. Spiegelberg 10/1/1969-87.83313 42.43376 190 'N/A 52 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700157 1209729906 Victor Smith 8/17/1987-87.83289 42.4336 169 'N/A 52 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700158 1209727465 Tobey Delaney 7/20/1985-87.83263 42.43251 164 'N/A 52 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700166 1209730397 James Wolden 11/11/1987

-87.83172 42.43269 196 'N/A 52 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700184 1209733855 Warren Esperson 12/23/1982

-87.83215 42.43253 55 'N/A 52 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700222 1209738624 Ram Builders 9/20/1994-87.83289 42.4336 172 'N/A 52 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700225 1209738151 Ram Builders 3/14/1994-87.83293 42.43365 170 'N/A 52 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700234 1209737095 Joe Buttera 5/31/1992-87.83168 42.43269 192 'N/A 52 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700150 1209724992 English Construction 11/1/1976-87.82938 42.4302 184 'N/A 53 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700151 1209724993 Smythe Construction 9/1/1976-87.82827 42.42977 165 'N/A 53 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700155 1209727349 James Wolden 7/11/1985-87.82926 42.43085 200 'N/A 53 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700161 1209726711 Lester Carman 9/1/1978-87.8295 42.43036 200 'N/A 53 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700167 1209726821 Busch & Larson 3/1/1979-87.83034 42.43108 198 'N/A 53 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700175 1209727174 Al Larson 3/11/1985-87.83025 42.43002 220 'N/A 53 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700180 1209733851 Busch & Larson 3/2/1979-87.82992 42.4311 198 'N/A 53 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700236 1209737097 David Johnson 6/10/1992-87.82926 42.43085 168 'N/A 53 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700239 1209727293 Larry Patrone 2/19/1990-87.82926 42.43085 175 'N/A 53 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700246 1209747796 IL Beach Park/Concession 7/18/2002-87.80718 42.43252 8 'N/A 54 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700247 1209747797 IL Beack Park/Concession 7/18/2002-87.80718 42.43252 15 'N/A 54 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700249 1209747800 IL Beack Park/Concession 7/18/2002-87.80724 42.43251 8 'N/A 54 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700248 1209747799 IL Beach Park/Concession 7/18/2002-87.80658 42.43023 15 'N/A 55 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700251 1209747798 IL Beach Park/Concession 7/18/2002-87.80658 42.43023 15 'N/A 55 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700252 1209702324 F.H. Ferguson N/A-87.82192 42.43807 149 'N/A 56 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700253 1209702325 Geo Shaw N/A-87.82438 42.43077 156 'N/A 57 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID 1709700254 1209702321 Beach State Park N/A-87.80473 42.43066 510 'N/A 58 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report DETAILSŽBanks Information

Solutions, Inc.

1709700255 1209747795 IL Beach Park/Concession 7/18/2002-87.80472 42.43249 8 'N/A 59 State ID Banks ID Owner Of Well Type Of Well Depth Drilled Completion Date Longitude Latitude MAP ID P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

Water Well Report

SUMMARY

ŽBanks Information

Solutions, Inc.

Water Well Report Research Mapping Protocol

ŽThe Banks Information Solutions, Inc. Water Well Report is prepared from existing state water well databases and additional file data/records research conducted at Texas' regulatory authorities. Submission of driller's log records

upon completion of a drilled water well became mandatory in 1985. The state of Texas has processed these records

into several different filing systems within two state regulatory authorities. The water well files, records and map

locations are maintained by the Texas Commission on Environmental Quality (TCEQ) and the Texas Water

Development Board (TWDB). Actual water well site locations of this report are geocoded and geoplotted directly from

the drilling records, drilling schedules, and driller's logs and maps submitted by the water well driller and maintained

at these two primary water well regulatory authorities. Below is a description of the four filing systems utilized for well

drilling records.

ŽTexas Water Development Board (TWDB)

Texas Water Development Board maintains a file system of located water well locations. These well files are water well site locations that have been verified with a field inventory inspection by TWDB personnel. The wells are assigned a

State Identification Number unique to that well and plotted on county base maps, U.S.G.S. 7.5 minute topographical

quadrangle maps, and in-house geographic information system. Records will also include analytical data attached with

each drilling record. This is the current protocol for maintaining water well records within the TWDB.

Texas Commission on Environmental Quality (TCEQ)

The Texas Commission on Environmental Qualit y maintains a file system of plotted, partially numbered, and un-numbered water well locations. Plotted water well files are water well site locations that have been determined from

map information submitted on water well logs and subsequently plotted on TWDB county highway base maps. This

type of mapping and filing procedure ceased in June 1986. Partially numbered water well files are water well site

locations processed from 1986 through 1990. These wells are provided a State Identification Number which

establishes the well location somewhere within a 2.5 minute quadrant of a 7.5 minute quadrangle map, but the site

location has never been precisely mapped or verified by a State of Texas staff member. Un-numbered water well files

are water well site locations that have been processed since June 1990. These well records are filed solely on their

county location and are not provided a State Identifiation Number nor are they mapped. This is the current protocol for

maintaining water well records within the TCEQ.

Disclaimer Banks Information Solutions, Inc. has performed a thorough and diligent search of all wells recorded with the Texas Water Development Board and the Texas Commission on Environmental Qualit

y. All mapped locations are based on

information obtained from the TWDB and the TCEQ. Although Banks performs quality assurance and quality control on

all research projects, we recognize that any inaccuracies of the records and mapped well locations could possibl y be traced to the appropriate regulatory authority or the water well driller. Many water well schedules may have never been

submitted to the regulatory authority by the water well driller and, thus, may explain the possible unaccountability of

private drilled wells. It is uncertain if the above listing provides 100% of the existing well locations within the area of

review. Therefore, Banks Information Solutions, Inc. cannot gaurantee the accuracy of the data or well location(s) of

those maps and records maintained by Texas' regulatory authorities.

P.O. Box 12851, Capitol Station, Austin, TX 78711 700 N. Lamar, Suite 200 Austin, TX 78703 512.478.0059 FAX 512.478.1433 e-mail banks@banksinfo.com Copyright 1998 by Banks Information Solutions, Inc.

1 MAP ID 2 MAP ID 3 MAP ID 3 MAP ID 4 MAP ID 4 MAP ID 5 MAP ID 6 MAP ID 7 MAP ID 8 MAP ID 9 MAP ID 9 MAP ID 10 MAP ID 11 MAP ID 12 MAP ID 12 MAP ID 12 MAP ID 13 MAP ID 14 MAP ID 14 MAP ID 14 MAP ID 14 MAP ID 14 MAP ID 14 MAP ID 15 MAP ID 16 MAP ID 17 MAP ID 18 MAP ID 18 MAP ID 19 MAP ID 20 MAP ID 20 MAP ID 21 MAP ID 22 MAP ID 23 MAP ID 24 MAP ID 25 MAP ID 26 MAP ID 26 MAP ID 26 MAP ID 27 MAP ID 28 MAP ID 28 MAP ID 28 MAP ID 28 MAP ID 29 MAP ID 30 MAP ID 31 MAP ID 32 MAP ID 32 MAP ID 32 MAP ID 32 MAP ID 32 MAP ID 33 MAP ID 34 MAP ID 35 MAP ID 35 MAP ID 36 MAP ID 37 MAP ID 38 MAP ID 39 MAP ID 39 MAP ID 40 MAP ID 40 MAP ID 40 MAP ID 40 MAP ID 40 MAP ID 41 MAP ID 42 MAP ID 42 MAP ID 42 MAP ID 42 MAP ID 42 MAP ID 43 MAP ID 43 MAP ID 43 MAP ID 44 MAP ID 44 MAP ID 44 MAP ID 44 MAP ID 44 MAP ID 45 MAP ID 45 MAP ID 45 MAP ID 46 MAP ID 46 MAP ID 46 MAP ID 46 MAP ID 46 MAP ID 46 MAP ID 47 MAP ID 47 MAP ID 47 MAP ID 47 MAP ID 47 MAP ID 47 MAP ID 47 MAP ID 47 MAP ID 47 MAP ID 48 MAP ID 49 MAP ID 49 MAP ID 49 MAP ID 49 MAP ID 49 MAP ID 49 MAP ID 49 MAP ID 49 MAP ID 50 MAP ID 50 MAP ID 50 MAP ID 50 MAP ID 51 MAP ID 51 MAP ID 51 MAP ID 51 MAP ID 52 MAP ID 52 MAP ID 52 MAP ID 52 MAP ID 52 MAP ID 52 MAP ID 52 MAP ID 52 MAP ID 53 MAP ID 53 MAP ID 53 MAP ID 53 MAP ID 53 MAP ID 53 MAP ID 53 MAP ID 53 MAP ID 53 MAP ID 54 MAP ID 54 MAP ID 54 MAP ID 55 MAP ID 55 MAP ID 56 MAP ID 57 MAP ID 58 MAP ID 59 MAP ID Revision 0 045136 (22) Zion Station A.2 ISWS LOGS

Revision 1 045136 (22) Zion Station APPENDIX B BORING LOGS B.1 2006 STRATIGRAPHIC AND INSTRUMENTATION LOGS B.2 HISTORICAL GEOTECHNICAL LOGS Revision 1 045136 (22) Zion Station B.1 2006 STRATIGRAPHIC AND INSTRUMENTATION LOGS 1 2 3 4 5 6 7 8 9 10 11 12 13 0 55 80 80 65 95 95 90 90 100 75 0 70 10 16 15 19 29 44 62 21 44 25 28 29 50 GRAVEL SAND (FILL) - trace to some gravel, trace organics, fine to medium grained, brown, moist SP-SAND, trace to some gravel, loose to compact, wet, fine to medium grained, brown SM-SAND, with trace to some silt, trace gravel, compact, fine grained, brown, wet- dense to very dense at 23.0ft BGS SP-SAND, trace to some silt, compact to dense, fine grained, brown, wet- getting coarser and grey for next 6" at 27.5ft BGS ML-SILT, dense, fine grained, grey, wet CL-CLAY, till (clay, trace to some silt, trace 4" 0 above

/ground protective

casing Concrete 2" 0 PVC/Well Riser Bentonite Seal 4.25" 0/Borehole 2" 0 PVC/Well Screen Sand 591.33 581.43 574.43 567.43 562.18 552.43 551.93 INTERVAL SAMPLEREC (%)NUMBER'N' VALUE (OVERBURDEN)

Page 1 of 2 MW-ZN-01S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 1, 2006 DRILLING METHOD: Vacuum/HSA

FIELD PERSONNEL: D. NICHOLLSOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 594.10 591.43 gravel), dense, grey, gravel, very well embedded in finer matrix, dry, till END OF BOREHOLE @ 39.5ft BGS WELL DETAILS Screened interval:

572.43 to 551.93ft AMSL

19.00 to 39.50ft BGS

Length: 20.5ft

Diameter: 2in

Slot Size: 10

Material: PVC

Sand Pack:

574.43 to 551.93ft AMSL

17.00 to 39.50ft BGS

Material: #5 Quartz Sand INTERVAL SAMPLEREC (%)NUMBER'N' VALUE (OVERBURDEN)

Page 2 of 2 MW-ZN-01S STRATIGRAPHIC AND INSTRUMENTATION LOG 42 44 46 48 50 52 54 56 58 60 62 64 66 68 70 72 74 76 78 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 1, 2006 DRILLING METHOD: Vacuum/HSA

FIELD PERSONNEL: D. NICHOLLSOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well ELEV.ft AMSL 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 15 30 30 30 30 40 95 50 30 50 40 10 25 8 4--18 19 5 6 20 9 4 17 19 64 2 GRAVEL & GRASS SAND with GRAVEL (FILL), presence of organics (trace), fine grained, brown, moist SAND (FILL), trace to with silt, trace gravel, very loose to compact, fine grained, brown, moist- trace organics, piece of wood, black (1cm x 1cm) at 13.5ft BGS- getting wet at 14.0ft BGS CL-SILTY CLAY TILL (silty clay, trace sand, trace gravel), fine grained, brownish-grey, wet SM-SILT & SAND, trace clay, trace gravel, very loose, fine grained, brown, wet, clay till

lenses observed within sandy material

between 0.5" to 4" in thickness SW-SAND, medium to coarse grained, trace silt, compact, wet CL-CLAY TILL (clay, trace to with silt, trace gravel, trace sand), compact, grey, moist, coarse material well embedded in fine matrix SILT & SAND, trace clay, trace gravel, very loose to loose, brown, wet, 1" to 3" thick

lenses 4" 0 above

/ground protective

casing Concrete Bentonite and Cuttings 2" 0 PVC/Well Riser Bentonite Seal 4.25" 0/Borehole 2" 0 PVC/Well Screen Sand Bentonite 591.11 581.21 571.21 570.96 556.21 555.71 555.21 INTERVAL SAMPLEREC (%)NUMBER'N' VALUE (OVERBURDEN)

Page 1 of 2 MW-ZN-02S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 2, 2006 DRILLING METHOD: Vacuum/HSA

FIELD PERSONNEL: D. NICHOLLSOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 593.78 591.21 15 16 40 40 9 12 of clay observed END OF BOREHOLE @ 45.5ft BGS Bentonite WELL DETAILS Screened interval:

576.21 to 556.21ft AMSL

15.00 to 35.00ft BGS

Length: 20ft

Diameter: 2in

Slot Size: 10

Material: PVC

Sand Pack:

577.91 to 556.21ft AMSL

13.30 to 35.00ft BGS

Material: #5 Quartz Sand 545.71 INTERVAL SAMPLEREC (%)NUMBER'N' VALUE (OVERBURDEN)

Page 2 of 2 MW-ZN-02S STRATIGRAPHIC AND INSTRUMENTATION LOG 42 44 46 48 50 52 54 56 58 60 62 64 66 68 70 72 74 76 78 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 2, 2006 DRILLING METHOD: Vacuum/HSA

FIELD PERSONNEL: D. NICHOLLSOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well ELEV.ft AMSL WELL DETAILS Screened interval:

576.29 to 555.54ft AMSL

15.25 to 36.00ft BGS

Length: 20.75ft 1 2 3 4 5 6 7 8 9 10 11 12 13 70 50 20 20 20 30 15 10 15 5 30 100 40 25 9 6

6 4 18 35 1 7

1 5

8 10 GRAVEL SAND (FILL), trace to with silt, trace to with gravel, fine grained, brown, moist SM-SAND WITH SILT, fine grained, trace gravel, compact, brown, moist CL-SILTY CLAY TILL (silty clay, trace gravel, trace sand), compact, moist, grey ML-SILT & SAND, trace gravel, very loose to loose, greyish brown, wet ML-SILT WITH SAND, trace clay, trace gravel, fine grained, very loose, brownish-grey, wet, 0.5" to 2" clay lenses, with

silt, trace gravel, trace sand, very loose, wet, brownish-grey CL-CLAY TILL (clay, some silt, trace sand and gravel), loose, grey, wet END OF BOREHOLE @ 36.0ft BGS 4" 0 above

/ground protective

casing Concrete Bentonite and Cuttings 2" 0 PVC/Well Riser Bentonite Seal 4.25" 0/Borehole 2" 0 PVC/Well Screen Sand 591.44 581.54 580.54 579.54 574.54 556.54 555.54 INTERVAL SAMPLEREC (%)NUMBER'N' VALUE (OVERBURDEN)

Page 1 of 2 MW-ZN-03S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 2, 2006 DRILLING METHOD: Vacuum/HSA

FIELD PERSONNEL: D. NICHOLLSOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 594.02 591.54 Diameter: 2in Slot Size: 10

Material: PVC

Sand Pack:

578.54 to 555.54ft AMSL

13.00 to 36.00ft BGS

Material: #5 Quartz Sand INTERVAL SAMPLEREC (%)NUMBER'N' VALUE (OVERBURDEN)

Page 2 of 2 MW-ZN-03S STRATIGRAPHIC AND INSTRUMENTATION LOG 42 44 46 48 50 52 54 56 58 60 62 64 66 68 70 72 74 76 78 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 2, 2006 DRILLING METHOD: Vacuum/HSA

FIELD PERSONNEL: D. NICHOLLSOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well ELEV.ft AMSL 1 2 3 4 5 6 7 8 9 10 11 12 13 40 95 70 80 100 90 100 55 90 65 80 70 100 1 29 18 35 25 23 24 29 41 10 15 31 20 SAND & SILT (FILL), trace gravel, trace cobbles, fine grained, brown, dry SM-SAND & SILT(FILL), trace clay, trace gravel, loose to compact, fine grained, brown, moist- 3" thick layer of silty clay till (silty clay, trace sand & gravel), compact grey, moist at 11.0ft

BGS- getting wet at 12.0ft BGS- thick layer of sandy organic material, very soft, black, wet (no odor presence of roots)

at 13.8ft BGS- 3" thick layer of silty clay till (silty clay, trace sand & gravel), compact grey, moist at 23.0ft

BGS- getting softer (very soft), saturated at 24.0ft BGS- silt with sand, trace clay, compact, brown, wet at 29.0ft BGS- 0.5" x 0.4" diagonal layer of dark grey to black organic material, very loose, fine

grained, wet at 30.0ft BGS ML-SILT, trace to with sand, trace clay, loose, grey wet CL-CLAY TILL (clay with silt, trace sand &

gravel), dense, grey, dry END OF BOREHOLE @ 36.0ft BGS 4" 0 above

/ground protective

casing Concrete Bentonite and Cuttings 2" 0 PVC/Well Riser Bentonite Seal 4.25" 0/Borehole Sand 2" 0 PVC/Well Screen WELL DETAILS Screened interval:

576.01 to 556.01ft AMSL

15.00 to 35.00ft BGS

Length: 20ft 583.01 557.51 555.21 555.01 INTERVAL SAMPLEREC (%)NUMBER'N' VALUE (OVERBURDEN)

Page 1 of 2 MW-ZN-04S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 3, 2006 DRILLING METHOD: Vacuum/HSA

FIELD PERSONNEL: D. NICHOLLSOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 593.82 591.01 Diameter: 2in Slot Size: 10

Material: PVC

Sand Pack:

578.01 to 556.01ft AMSL

13.00 to 35.00ft BGS

Material: #5 Quartz Sand INTERVAL SAMPLEREC (%)NUMBER'N' VALUE (OVERBURDEN)

Page 2 of 2 MW-ZN-04S STRATIGRAPHIC AND INSTRUMENTATION LOG 42 44 46 48 50 52 54 56 58 60 62 64 66 68 70 72 74 76 78 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 3, 2006 DRILLING METHOD: Vacuum/HSA

FIELD PERSONNEL: D. NICHOLLSOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well ELEV.ft AMSL 1 2 3 4 5 6 7 8 9 10 11 12 13 40 70 70 60 65 60 70 80 75 70 4.5 80 50 1 29 18 35 25 23 24 29 41 10 15 41 20 3.0 4.5 11 10.2 9.8 11 9.8 10.1 10.3 9.7 18 10.1 8.4 SAND & SILT (FILL), trace gravel, fine grained, brown, dry SM-SAND, trace to some silt, very soft, fine to medium grained, brown, wet GP-GRAVEL & SAND, trace silt, loose to compact, medium to coarse grained, dark

brown, wet SM-SAND, trace silt, compact, fine to medium grained, brown, wet, trace gravel- finer, silt & sand, (4" thick layer, black) at 9.0ft BGS- finer, silt & sand, (4" thick layer, black) at 11.5ft BGS- finer, silt & sand, (4" thick layer, black) at 13.0ft BGS- silt, grey at 15.0ft BGS SP-SAND, trace silt, medium to coarse grained, brown to grey, wet SM-SAND, trace silt, compact, fine to medium grained, brown, wet, trace gravel- finer, silt & sand at 21.5ft BGS CL-CLAY, trace silt, trace sand, trace of brown to black organics, compact, wet SP-SAND, medium to coarse grained, grey compact, wet SM-SAND, trace silt, compact, grey, fine grained, wet ML-SILT, trace sand, compact, grey, fine grained, moist END OF BOREHOLE @ 30.0ft BGS 4" 0 above

/ground protective

casing Concrete Bentonite and Cuttings Bentonite Seal 2" 0 PVC/Well Riser 4.25" 0/Borehole Sand 2" 0 PVC/Well Screen WELL DETAILS Screened interval:

575.72 to 555.72ft AMSL

10.00 to 30.00ft BGS

Length: 20ft

Diameter: 2in

Slot Size: 10

Material: PVC

Sand Pack:

577.82 to 555.72ft AMSL

7.90 to 30.00ft BGS

Material: #5 Quartz Sand 581.72 578.92 577.72 566.72 565.72 561.72 560.22 559.72 558.72 555.72 INTERVAL SAMPLEREC (%)NUMBER'N' VALUEPID (PPM)(OVERBURDEN)

Page 1 of 1 MW-ZN-05S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 4, 2006 DRILLING METHOD: Vacuum/HSA

FIELD PERSONNEL: D. NICHOLLSOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 588.64 585.72 PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 5, 2006 DRILLING METHOD: Vacuum/HSA

FIELD PERSONNEL: D. NICHOLLSOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 592.66 589.78 1 2 3 4 5 6 7 8 9 10 70 60 60 40 70 60 60 60 50 70 18 17 46 40 24 58 51 51 37 40 1.0 2.0 1.0 1.0 SAND with SILT, trace gravel, brown, moist SM-SAND, some silt, soft, fine, grained, brown, wet GM-SAND & GRAVEL, medium to coarse grained, compact, grey, wet SM-SAND, some silt, soft, fine, grained, brown, wet GM-SAND & GRAVEL, medium to coarse grained, compact, grey, wet SM-SAND, some silt, soft, fine, grained, brown, wet GM-SAND & GRAVEL, medium to coarse grained, compact, grey, wet ML-SILT, some sand, fine grained, greyish brown, trace gravel, compact to dense, wet GM-SAND & GRAVEL, trace silt, compact to dense, brown, wet, coarser grained ML-SILT, trace sand, brown, dense, fine grained, wet CL-CLAY, (clay till, trace silt, trace sand &

gravel), gravel well embedded in finer matrix, very dense, grey, moist to dry END OF BOREHOLE @ 30.0ft BGS 4" 0 above

/ground protective

casing Concrete Bentonite and Cuttings Bentonite 2" 0 PVC/Well Riser 4.25" 0/Borehole Sand 2" 0 PVC/Well Screen WELL DETAILS Screened interval:

579.78 to 559.78ft AMSL

10.00 to 30.00ft BGS

Length: 20ft

Diameter: 2in

Slot Size: 10

Material: PVC

Sand Pack:

581.53 to 559.78ft AMSL

8.25 to 30.00ft BGS

Material: #5 Quartz Sand 579.78 578.78 577.78 576.78 575.78 574.78 573.78 564.78 564.18 560.78 559.78 INTERVAL SAMPLEREC (%)NUMBER'N' VALUEPID (PPM)(OVERBURDEN)

Page 1 of 1 MW-ZN-06S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 DEPTH ft BGS Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 589.82 587.08 1 2 3 4 5 6 7 8 9 10 11 12 13 40 50 40 50 60 50 50 70 50 50 50 80 0 0 16 25 50 29 56 43 35 19 82 31 28 50 SAND with SILT, trace gravel, fine grained, brown, moist SM-SAND WITH SILT, trace gravel, very loose, fine grained, brown, wet GM-GRAVELLY SAND, trace silt, loose to compact, medium grained, brown, wet SM-SAND, trace silt, trace to with gravel, fine to coarse grained, compact, brown, wet- less gravel at 10.0ft BGS GM-GRAVELLY SAND, trace silt, loose to compact, medium grained, brown, wet ML-SILT & SAND, loose to compact, fine grained, brown, wet SW-SAND, coarse grained, compact to dense, brown, wet ML-SILT & SAND, trace gravel, dense, brown, fine grained, wet ML-SILT, trace sand, compact, grey, wet, fine grained SM-SAND & SILT, compact, brown, wet, fine grained ML-SILT, trace sand, very dense, grey, wet

SM-SAND & SILT, compact, brown, wet, fine grained ML-SILT, trace sand, grey, wet, fine grained

SM-SAND & SILT, compact, brown, wet

ML-SILT, trace sand, grey, wet, fine grained END OF BOREHOLE @ 30.0ft BGS 4" 0 above

/ground protective

casing Concrete Bentonite and Cuttings Bentonite Seal 2" 0 PVC/Well Riser 4.25" 0/Borehole Sand 2" 0 PVC/Well Screen WELL DETAILS Screened interval:

577.08 to 557.08ft AMSL

10.00 to 30.00ft BGS

Length: 20ft

Diameter: 2in

Slot Size: 10

Material: PVC

Sand Pack:

579.28 to 557.08ft AMSL

7.80 to 30.00ft BGS

Material: #5 Quartz Sand 583.08 581.08 579.08 575.58 571.28 570.08 569.58 565.28 565.08 563.58 563.08 562.08 561.08 560.08 557.08 INTERVAL SAMPLEREC (%)NUMBER'N' VALUE (OVERBURDEN)

Page 1 of 1 MW-ZN-07S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 8, 2006 DRILLING METHOD: Vacuum/HSA

FIELD PERSONNEL: D. NICHOLLSOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 1 2 3 4 5 6 7 8 9 10 11 12 60 70 85 60 80 70 60 70 60 60 80 25 13 28 11 33 19 13 54 24 11 23 57 10.6 13.8 11.6 11.0 9.1 9.7 10.4 9.3 9.6 10.2 10.4--SAND, trace silt, trace gravel, trace organics, fine grained, moist SM-SAND, trace silt, trace gravel, compact, fine to coarse grained, brown, wet GP-GRAVEL, trace sand, medium to coarse grained, compact, brown, wet ML-SILT, trace sand, loose to compact, fine grained, brown, wet SM-SAND, trace gravel, medium to coarse grained, loose to compact, brown, wet ML-SILT, trace fine sand, brown, compact to dense, wet SM-SAND & SILT, fine to medium grained, very loose to compact, brown, wet ML-SILT, trace sand, compact to dense, fine grained, brown, wet SM-SAND, trace, silt, fine to coarse grained, very loose to loose, brown, wet ML-SILT, trace sand, compact, brownish-grey, wet SM-SAND, trace silt, medium to coarse grained, loose, brown, wet ML-SILT, trace sand, compact to dense, grey, wet- SM, 6" thick layer of sand, medium to coarse grained, compact brown, wet at 21.0ft BGS- SM, 6" thick layer of sand, medium to coarse grained, compact brown, wet at 23.0ft BGS- CL, 2" thick layer of clay, trace silt, grey, wet, compact at 25.5ft BGS- SM, 6" thick layer of sand, medium to coarse grained, compact brown, wet at 25.9ft BGS- SM, 6" thick layer of sand, medium to coarse grained, compact brown, wet at 27.6ft BGS ML-SAND & SILT, compact to very dense, fine to coarse grained, brown, wet END OF BOREHOLE @ 30.0ft BGS 4" 0 above

/ground protective

casing Concrete Bentonite and Cuttings Bentonite Seal 2" 0 PVC/Well Riser 4.25" 0/Borehole Sand 2" 0 PVC/Well Screen WELL DETAILS Screened interval:

575.85 to 555.85ft AMSL

10.00 to 30.00ft BGS

Length: 20ft

Diameter: 2in

Slot Size: 10

Material: PVC

Sand Pack:

578.15 to 555.85ft AMSL

7.70 to 30.00ft BGS

Material: #5 Quartz Sand 579.85 578.85 577.85 576.85 574.35 573.85 570.35 569.85 568.35 567.85 566.85 557.85 555.85 INTERVAL SAMPLEREC (%)NUMBER'N' VALUEPID (PPM)(OVERBURDEN)

Page 1 of 1 MW-ZN-08S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 5, 2006 DRILLING METHOD: Vacuum/HSA

FIELD PERSONNEL: D. NICHOLLSOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 588.73 585.85 1 2 3 4 5 75 20 5 90 50 25 10 1 3

1 5.2 6.0 6.0 4.0 4.0 SAND WITH SILT (FILL), trace gravel, trace cobbles, fine grained, moist SM-SAND & SILT (FILL), trace gravel, up to 2" diameter trace cobbles, very loose to

compact, fine grained, moist to wet GM-GRAVEL WITH SAND (FILL), trace silt, very loose, grey, well rounded gravel, wet END OF BOREHOLE @ 20.0ft BGS Refusal on Unknown Material 4" 0 above

/ground protective

casing Concrete Bentonite and Cuttings Bentonite Seal 2" 0 PVC/Well Riser 4.25" 0/Borehole Sand 2" 0 PVC/Well Screen WELL DETAILS Screened interval:

582.18 to 572.18ft AMSL

9.00 to 19.00ft BGS

Length: 10ft

Diameter: 2in

Slot Size: 10

Material: PVC

Sand Pack:

584.43 to 572.18ft AMSL

6.75 to 19.00ft BGS

Material: #5 Quartz Sand 581.18 573.68 571.18 INTERVAL SAMPLEREC (%)NUMBER'N' VALUEPID (PPM)(OVERBURDEN)

Page 1 of 1 MW-ZN-09S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 3, 2006 DRILLING METHOD: Vacuum/HSA

FIELD PERSONNEL: D. NICHOLLSOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 593.84 591.18 Page 1 of 2NUMBERINTERVAL SAMPLEREC (%)MW-ZN-10 STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS 0 0 0

0 0

0 0 Vac cleared to 11.0ft BGS Sand, fine grained, trace to some silt, some gravel, dry to moist, brown Sand, some silt and gravel, fine grained, loose, dark brown, wet Silty and fine sand, trace gravel, trace clay, loose to compact, lighter brown, moist- saturated at 15.0ft BGS- trace organics, black, fine grained at 16.5ft BGS- 4" thick layer of silty clay, soft, trace organics, trace silt, trace of gravel embedded within finer matrix at 18.0ft BGS Sand, trace silt, fine to medium grained, loose, grayish brown, wet Silt and fine sand, loose, fine grained, brownish gray, wet Sand, trace gravel, trace silt, loose, brown, wet- compact at 30.0ft BGS Silt, trace sand, compact, fine grained, wet, brownish gray END OF BOREHOLE @ 34.0ft BGS Concrete Soil Cuttings and Bentonite 4" 0 Steel

/Well Casing Bentonite Sand 2" 0 PVC/Well Screen 0 0 0

0 0 580.0 579.0 568.0 566.0 564.5 558.5 557.0'N' VALUEPID (PPM)(OVERBURDEN)

MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: July 13, 2006 DRILLING METHOD: Vacuum/HSA

FIELD PERSONNEL: D. NICHOLLSOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 8/6/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 593.7 591.0

'N' VALUEPID (PPM)(OVERBURDEN)

Page 2 of 2NUMBERINTERVAL SAMPLEREC (%)MW-ZN-10 STRATIGRAPHIC AND INSTRUMENTATION LOG 42 44 46 48 50 52 54 56 58 60 62 64 66 68 70 72 74 76 78 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: July 13, 2006 DRILLING METHOD: Vacuum/HSA

FIELD PERSONNEL: D. NICHOLLSOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 8/6/06 Monitoring Well ELEV.ft AMSL WELL DETAILS Screened interval:

577.0 to 557.0ft AMSL

14.0 to 34.0ft BGS

Length: 20ft

Diameter: 2in

Slot Size: 10

Material: PVC

Sand Pack:

579.0 to 557.0ft AMSL

12.0 to 34.0ft BGS

Material: Silica Sand #5 0 0 0

0 0

0 0

0 0

0 Vac cleared to 10.0ft BGS Sand, some gravel, trace of silt, fine grained, brown, moist- wet at 9.0ft BGS Sand, trace silt, trace gravel, fine to medium grained, compact, brown, wet- 7" thick layer of gravel with coarse sand, dense, wet, brown at 16.0ft BGS- 8" thick layer of gravel with coarse sand, dense, wet, brown at 17.0ft BGS- 6" thick layer of silt, trace sand, dense, fine grained, grayish-brown, wet at 19.5ft BGS- 8" thick layer of gravel with coarse sand, dense, wet, brown at 21.0ft BGS- 6" thick layer of coarse sand, dense, wet, brown at 23.0ft BGS- 6" thick layer of silt, trace sand, dense, fine grained, grayish-brown, wet at 23.5ft BGS Silt, trace sand, compact, fine grained, grayish-brown, wet Sand, trace silt, trace gravel, fine to medium grained, compact, brown, wet Silt, trace sand, compact, fine grained, grayish-brown, wet END OF BOREHOLE @ 30.0ft BGS Concrete Soil Cuttings and Bentonite 4" 0 Steel

/Well Casing Bentonite Sand 2" 0 PVC/Well Screen WELL DETAILS Screened interval:

576.5 to 556.5ft AMSL

10.0 to 30.0ft BGS

Length: 20ft

Diameter: 2in

Slot Size: 10

Material: PVC

Sand Pack:

578.5 to 556.5ft AMSL

8.0 to 30.0ft BGS

Material: Silica Sand #5 576.5 559.5 558.5 557.5 556.5'N' VALUEPID (PPM)(OVERBURDEN)

Page 1 of 1NUMBERINTERVAL SAMPLEREC (%)MW-ZN-11 STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: July 14, 2006 DRILLING METHOD: Vacuum/HSA

FIELD PERSONNEL: D. NICHOLLSOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 8/6/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 589.5 586.5 (SW) Fine grained sand, dry (SP) Med-Fine grained sand, saturated (SP) Coarse grained sand, larger stones, saturated END OF BOREHOLE @ 21.5ft BGS Bentonite Seal 2" 0 Borehole

/Sand 1" 0 PVC/Well Screen WELL DETAILS Screened interval:

578.8 to 563.8ft AMSL

6.5 to 21.5ft BGS

Length: 15ft

Diameter: 1in

Slot Size: 10

Material: PVC

Sand Pack:

579.8 to 563.8ft AMSL

5.5 to 21.5ft BGS

Material: Sand 577.8 571.8 563.8'N' VALUE (OVERBURDEN)

Page 1 of 1NUMBERINTERVAL SAMPLEREC (%)TW-ZN-100 STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: July 7, 2006 DRILLING METHOD: Geoprobe

FIELD PERSONNEL: M. BORKOWSKIOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 8/6/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 590.0 585.3 (SW) Fine grained sand, dry (SP) Med-Fine grained sand, saturated (SP) Coarse grained sand, larger stones, saturated END OF BOREHOLE @ 19.0ft BGS Bentonite Seal 2" 0 Borehole

/Sand 1" 0 PVC/Well Screen WELL DETAILS Screened interval:

580.3 to 565.3ft AMSL

4.0 to 19.0ft BGS

Length: 15ft

Diameter: 1in

Slot Size: 10

Material: PVC

Sand Pack:

581.3 to 565.3ft AMSL

3.0 to 19.0ft BGS

Material: Sand 576.8 570.8 565.3'N' VALUE (OVERBURDEN)

Page 1 of 1NUMBERINTERVAL SAMPLEREC (%)TW-ZN-101 STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: July 7, 2006 DRILLING METHOD: Geoprobe

FIELD PERSONNEL: M. BORKOWSKIOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 8/6/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 588.7 584.3 (SW) Fine grained sand, dry (SP) Med-Fine grained sand, saturated (SP) Coarse grained sand, larger stones, saturated END OF BOREHOLE @ 21.0ft BGS Bentonite Seal 2" 0 Borehole

/Sand 1" 0 PVC/Well Screen WELL DETAILS Screened interval:

578.3 to 563.3ft AMSL

6.0 to 21.0ft BGS

Length: 15ft

Diameter: 1in

Slot Size: 10

Material: PVC

Sand Pack:

579.3 to 563.3ft AMSL

5.0 to 21.0ft BGS

Material: Sand 576.8 570.8 563.3'N' VALUE (OVERBURDEN)

Page 1 of 1NUMBERINTERVAL SAMPLEREC (%)TW-ZN-102 STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: July 7, 2006 DRILLING METHOD: Geoprobe

FIELD PERSONNEL: M. BORKOWSKIOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 8/6/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 588.6 584.3 (SW) Fine grained sand, dry (SP) Med-Fine grained sand, saturated (SP) Coarse grained sand, larger stones, saturated END OF BOREHOLE @ 30.0ft BGS Bentonite Seal 2" 0 Borehole

/Sand 1" 0 PVC/Well Screen WELL DETAILS Screened interval:

573.7 to 553.7ft AMSL

10.0 to 30.0ft BGS

Length: 20ft

Diameter: 1in

Slot Size: 10

Material: PVC

Sand Pack:

574.7 to 553.7ft AMSL

9.0 to 30.0ft BGS

Material: Sand 576.2 570.2 553.7'N' VALUE (OVERBURDEN)

Page 1 of 1NUMBERINTERVAL SAMPLEREC (%)TW-ZN-103 STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 DEPTH ft BGS PROJECT NAME: ZION GENERATION STATION PROJECT NUMBER: 45136-30

CLIENT: EXELON GENERATION COMPANY LLC

LOCATION: ZION, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: July 7, 2006 DRILLING METHOD: Geoprobe

FIELD PERSONNEL: M. BORKOWSKIOVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 8/6/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 587.5 583.7 Revision 0 045136 (22) Zion Station B.2 HISTORICAL GEOTECHNICAL LOGS

Revision 0 045136 (22) Zion Station APPENDIX C QUALITY ASSURANCE PROGRAM - T ELEDYNE BROWN ENGINEERING, INC.

Page 2 of 32 TABLE OF CONTENTS Section Title Page 1.0 KNOXVILLE QAM SECTION INTRODUCTION 7 2.0 QUALITY SYSTEM 10 2.1 Policy 10 2.2 Quality System Structure 10 2.3 Quality System Objectives 10 2.4 Personnel Orientation, Training, and Qualification 11 3.0 ORGANIZATION, AUTHORITY, AND RESPONSIBILITY 12 4.0 PERSONNEL ORIENTATION, DATA INTEGRITY, TRAINING, AND QUALIFICATION 13 4.1 Orientation 13 4.2 Data Integrity 13 4.3 Training 13 4.4 Qualification 13 4.5 Records 13 5.0 CUSTOMER INTERFACES 14 5.1 Interface Personnel 14 5.2 Bid Requests and Tenders 14 5.3 Contracts 14 5.4 TBE's Expectation of Customers 14 5.5 Customer Satisfaction 15 5.5.1 Customer Complaints 15 5.5.2 Customer Confidentiality 15 6.0 DOCUMENTATION GENERATION AND CONTROL 16 6.1 General 16 6.2 New Documentation 16 6.3 Documentation Changes 16 Page 3 of 32 TABLE OF CONTENTS - Continued

6.4 Documentation Lists and Distributions 16 6.5 Other Documentation 16 6.6 Documentation Reviews 16

7.0 DESIGN OF LABORATORY CONTROLS 17 7.1 General 17 7.2 Facility 17 7.3 Technical Processes and Methods 17 7.3.1 Operational Flow 17 7.3.2 Methods 18 7.3.3 Data Reduction and Analysis 18 7.4 Verification of Technical Processes, Methods, and Software 18 7.4.1 Operational Flow Verification 18 7.4.2 Method Verifications 18 7.4.3 Data Reduction and Analysis Verification 18 7.5 Design of Quality Controls 18 7.5.1 General 19 7.5.2 Demonstration of Capability (D of C) 19 7.5.3 Process Control Checks 19 7.6 Counting Instrument Controls 20

8.0 PURCHASING AND SUBCONTRACT CONTROLS 21 8.1 General 21 8.2 Source Selection 21 8.3 Procurement of Supplies and Support Services 21 8.3.1 Catalog Supplies 21 8.3.2 Support Services 21 8.3.3 Equipment and Software 22 8.4 Subcontracting of Analytical Services 22 8.5 Acceptance of Items or Services 22 Page 4 of 32 TABLE OF CONTENTS - Continued

9.0 TEST SAMPLE IDENTIFICATION AND CONTROL 23 9.1 Sample Identification 23 9.2 LIMS 23 9.3 Sample Control 23

10.0 SPECIAL PROCESSES, INSPECTION, AND TEST 24 10.1 Special Processes 24 10.2 Inspections and Tests 24 10.2.1 Intra Laboratory Checks (QC Checks) 24 10.2.2 Inter Laboratory Checks 24 10.2.3 Data Reviews 24 10.3 Control of Sampling of Samples 24 10.4 Reference Standards / Material 24 10.4.1 Weights and Temperatures 25 10.4.2 Radioactive Materials 25 11.0 EQUIPMENT MAINTENANCE AND CALIBRATION 26 11.1 General 26 11.2 Support Equipment 26 11.3 Instruments 26 11.4 Nonconformances and Corrective Actions 26 11.5 Records 27

12.0 NONCONFORMANCE CONTROLS 28 12.1 General 28 12.2 Responsibility and Authority 28 12.3 10CFR21 Reporting 28

Page 5 of 32 TABLE OF CONTENTS - Continued

13.0 CORRECTIVE AND PREVENTIVE ACTIONS 29 13.1 General 29 13.2 Corrective Actions 29 13.3 Preventive Actions 29 14.0 RESULTS ANALYSIS AND REPORTING 30 14.1 General 30 14.2 Results Review 30 14.3 Reports 30

15.0 RECORDS 31 15.1 General 31 15.2 Type of Records 31 15.3 Storage and Retention 31 15.4 Destruction or Disposal 31 16.0 ASSESSMENTS 32 16.1 General 32 16.2 Audits 32 16.3 Management Reviews 32

Page 6 of 32 REVISION HISTORY

Revision 7 Complete re-write January 1, 2005 Bill Meyer

Revision 8 Updated organization chart, minor change to 1.0, 4.4, 7.5.3.2, 10.2.3, and 12.3 Page 7 of 32 1.0 Knoxville QAM Section Introduction This Quality Assurance Manual (QAM) and related Procedures describes the Knoxville Environmental Services Laboratory's QA system. This system is designed to meet multiple quality standards imposed by Customers and regulatory agencies including:

NRC's 10 CFR 50 Appendix B NRC's Regulatory Guide 4.15

DOE's Order 414.1

DOE's QSAS

ANSI N 42.23

ANSI N 13.30

NELAC Standard, Chapter 5

The Environmental Services (ES) Laboratory does low level radioactivity analyses for Power Plants and other customers. It primarily analyzes environmental samples (natural products from around plants such as milk), in-plant samples (air filters, waters), bioassay samples from customer's employees, and waste disposal samples (liquids and solids).

Potable and non-potable water sample s are tested using methods based on EPA standards as cited in State licenses (see Procedure 4010). The listing [current as of initial printing of this Manual - see current index for revision status and additions / deletions] of implementing Procedures (SOPs) covering Administration, Methods, Counting Instruments, Technical, Miscellaneous, and LIMS is shown in Table 1-1. Reference to these Procedures by number is made throughout this QAM.

Table 1-1 Number Title Part 1 Administrative Procedures 1001 Validation and Verification of Computer Programs for Radiochemistry Data Reduction 1002 Organization and Responsibility 1003 Control, Retention, and Disposal of Quality Assurance Records 1004 Definitions 1005 Data Integrity 1006 Job Descriptions 1007 Training and Certifications 1008 Procedure and Document Control 1009 Calibration System 1010 Nonconformance Controls 1011 10CFR21 Reporting 1012 Corrective Action and Preventive Action Page 8 of 32 Number Title 1013 Internal Audits and Management Reviews 1014 RFP, Contract Review, and Order Entry (formerly 4001) 1015 Procurement Controls Part 2 Method Procedures 2001 Alpha Isotopic and Plutonium-241 2002 Carbon-14 Activity in Various Matrices 2003 Carbon-14 and Tritium in Soils, Solids, and Biological Samples; Harvey Oxidizer Method 2004 Cerium-141 and Cerium-144 by Radiochemical Separation 2005 Cesium-137 by Radiochemical Separation 2006 Iron-55 Activity in Various Matrices 2007 Gamma Emitting Radioisotope Analysis 2008 Gross Alpha and/or Gross Beta Activity in Various Matrices 2009 Gross Beta Minus Potassium-40 Activity in Urine and Fecal Samples 2010 Tritium and Carbon-14 Analysis by Liquid Scintillation 2011 Tritium Analysis in Drinking Water by Liquid Scintillation 2012 Radioiodine in Various Matrices 2013 Radionickel Activity in Various Matrices 2014 Phosphorus-32 Activity in Various Matrices 2015 Lead-210 Activity in Various Matrices 2016 Radium-226 Analysis in Various Matrices 2017 Total Radium in Water Samples 2018 Radiostrontium Analysis by Chemical Separation 2019 Radiostrontium Analysis by Ion Exchange 2020 Sulfur-35 Analysis 2021 Technetium-99 Analysis by Eichrom Resin Separation 2022 Total Uranium Analysis by KPA 2023 Compositing of Samples 2024 Dry Ashing of Environmental Samples 2025 Preparation and Standardization of Carrier Solutions 2026 Radioactive Reference Standard Solutions and Records 2027 Glassware Washing and Storage 2028 Moisture Content of Various Matrices 2029 Polonium-210 Activity in Various Matrices 2030 Promethium-147 Analysis Page 9 of 32 Number Title Part 3 Instrument Procedures 3001 Calibration and Control of Gamma-Ray Spectrometers 3002 Calibration of Alpha Spectrometers 3003 Calibration and Control of Alpha and Beta Counting Instruments 3004 Calibration and Control of Liquid Scintillation Counters 3005 Calibration and Operation of pH Meters 3006 Balance Calibration and Check 3008 Negative Results Evaluation Policy 3009 Use and Maintenance of Mechanical Pipettors 3010 Microwave Digestion System Use and Maintenance Part 4 Technical Procedures 4001 Not Used 4002 QC Checks on Data 4003 Sample Regent and Control 4004 Data Package Preparation and Reporting 4005 Blank, Spike, and Duplicate Controls 4006 Inter-Laboratory Comparison Study Process 4007 Method Basis and Initial Validation Process 4008 Not Used 4009 MDL Controls 4010 State Certification Process 4011 Accuracy, Precision, Efficiency, and Bias Controls and Data Quality Objectives 4012 Not Used 4013 Not Used 4014 Facility Operation and Control 4015 Documentation of Analytical Laboratory Logbooks (formerly 1002) 4016 Total Propagated Uncertainty (formerly 1004) 4017 LIMS Operation 4018 Instrument Calibration System 4019 Radioactive Reference Material Standards Part 5 Miscellaneous Procedures 5001 Laboratory Hood Operations 5002 Operation and Maintenance of Deionized Water System 5003 Waste Management 5004 Acid Neutralization and Purification System Operation Procedure Page 10 of 32 Part 6 LIMS 6001 LIMS Raw Data Processing and Reporting 6002 Software Development and/or Pilots of COTS Packages 6003 Software Change and Version Control 6004 Backup of Data and System Files 6005 Disaster Recovery Plan 6006 LIMS Hardware 6007 LIMS User Access 6008 LIMS Training 6009 LIMS Security 2.0 QUALITY SYSTEM The TBE-ES QA system is designed to comply with multiple customer- and regulatory agency-imposed specifications related to quality. This quality system applies to all activities of TBE-ES that affect the quality of analyses performed by the laboratory.

2.1 Policy The TBE quality policy, given in Company Policy P-501, is "TBE will continually improve our processes and effectiveness in providing products and services that exceed our customer's expectations."

This policy is amplified by this Laboratory's commitment, as attested to by the title page signatures, to perform all work to good professional practices and to deliver high quality services to our customers with full data integrity. (See Section 4.0 and Procedure 1005).

2.2 Quality System Structure The Quality System is operated by the organizations described in Section 3.0 of this Manual. The Quality System is described in this Manual and in the Procedures Manual, both of which are maintained by the QA Manager. Procedures are divided into 6 sections - Administrative, Methods, Equipments, Technical, Miscellaneous, and LIMS. This Manual is structured as shown in the Table of Contents and refers to Procedures when applicable. Cross references to the various imposed quality specifications are contained in Appendices to this Manual.

2.3 Quality System Objectives The Quality System is established to meet the objective of assuring all operations are planned and executed in accordance with system requirements. The Quality System also assures that performance evaluations are performed (see Procedure 4006), and that appropriate verifications are performed (see Procedures in the 1000 and 4000 series) to further assure compliance. Verification includes Page 11 of 32 examination of final reports (prior to submittal to customers) to determine their quality (see Procedure 4004).

To further these objectives, various in-process assessments of data, as well as assessments of the system, via internal audits and management reviews, are performed. Both internal experts and customer / regulatory agencies perform further assessments of the system and compliance to requirements.

2.4 Personnel Orientation, Tr aining, and Qualification TBE provides indoctrination and training to employees and performs proficiency evaluation of technical personnel.

This effort is described in Section 4.0.

Page 12 of 32 3.0 ORGANIZATION, AUTHORITY, AND RESPONSIBILITY TBE has established an effective organization for conducting laboratory analyses at the Knoxville Environmental Services Laboratory. The basic organization is shown in Figure 3-1. Detail organization charts with names, authorities, and responsibilities are given in Procedure 1002. Job descriptions are given in Procedure 1006.

This organization provides clearly established Quality Assu rance authorities, duties, and functions. QA has t he organizational freedom needed to:

(1) Identify problems (2) Stop nonconforming work (3) Initiate investigations (4) Recommend corrective and preventive actions (5) Provide solutions or recommend solutions (6) Verify implementation of actions

All Laboratory personnel have the authority and resources to do their assigned duties and have the freedom to act on problems. The QA personnel have direct, independent access to Company management as shown in Figure 3-1.

Figure 3.1. Laboratory Organization President VP A dministration & Q A VP Environmental Product Assurance Director Lab QA Manager Lab Operations Mana g er Program Mana g ers Lab SupervisorAdministration Staff Page 13 of 32 4.0 PERSONNEL ORIENTATION, DATA INTEGRITY, TRAINING, AND QUALIFICATION

4.1 Orientation All laboratory personnel must receive orientation to the quality program if their work can affect quality. Orientation includes a brief review of customer- and regulatory agency-imposed quality requirements, the structure of the QAM, and the implementing procedures. The goal of orientation is to cover the nature and goals of the QA program.

4.2 Data Integrity The primary output of the Laboratory is data. Special emphasis and training in data integrity is given to all personnel whose work provides or supports data delivery. The Laboratory Data Integrity Procedure (Procedure 1005) describes training, personnel attestations, and monitoring operations. Annual reviews are required.

4.3 Training The Quality Assurance Manager (QAM) maintains a training matrix indicating which laboratory personnel need training in which specific Procedures. This matrix is updated when personnel change or change assignments. All personnel are trained per these requirements and procedures. This training program is described in Procedure 1007. The assi gned responsibilities for employees are described in Procedure 1002 (See Section 3.0) on Organization and in Procedure 1006, Job Descriptions. Refresher training or re-tra ining is given annually as appropriate.

4.4 Qualification Personnel are qualified as required by their job description. Management and non-analysts are evaluated based on past experience, education, and management's assessment of their capabilities. Formal qualification is required of analysts and related technical personnel who perform laboratory functions. Each applicable person is given training and then formally evaluated by the Operations Manager (or his designees) and by QA. Each analyst must initially demonstrate capability to perform each assigned analytical effort. Each year, thereafter, he or she must perform similar analyses on Interlab Comparison Samples (see Procedure 4006) or on equivalent blanks and spikes samples. Acceptable results extend qualifications (certification). Unacceptable results require retraining in the subject method / Procedures. (See Procedure 1007 for added information, records, forms, etc. used.)

4.5 Records Records of training subjects, contents, attendees, instructors, and certifications are maintained by QA.

Page 14 of 32 5.0 CUSTOMER INTERFACES

5.1 Interface Personnel The Laboratory has designated Program Managers as the primary interface with all customers. Other interfaces may be the QA Manager or the Lab Operations Manager.

5.2 Bid Requests and Tenders The Program Managers respond to customer requests for bids and proposals per Procedure 1014 for bids, proposals, and contract reviews. They clarify customer requests so both the customer and the lab staff understand requests. As responses are developed, internal reviews are conducted to ensure that requirements are adequately defined and documented and to verify that the Laboratory has adequate resources in physical capabilities, personal skills, and technical information to perform the work. Accreditation needs are reviewed. If subcontracts are required to perform any analysis, the subcontractor is similarly evaluated and the client notified in writing of the effort. Most qualifications are routi ne with standard pricing and the review of these quotes is performed by the Program Manager. Larger or more complex quotes are reviewed by the Operations Manager and the QA Manager (or designees). Evidence of review is by initialing and dating applicable papers, signatures on quotations, or by memo.

5.3 Contracts The Program Manager's receive contract awards (oral or written) and generate the work planning for initiation pr eparation (charge numbers, data structure or contents in LIMS, etc.). They review contracts for possible differences from quotations and, if acceptable, contracts are processed. Do cumentation of the review is by initials and date as a minimum. Contract changes receive similar reviews and planning.

5.4 TBE's Expectation of Customers TBE expects customers to provide samples suitable for lab analysis. These expectations include:

Accurate and unambiguous identification of samples Proper collection and preservation of samples Use of appropriate containers free from external and internal contamination Integrity preservation during shipment and timely delivery of samples that are age sensitive Adequate sized samples that allow for retest, if needed Specification of unique MOA/MDC requirements Alerting the lab about abnormal samples (high activity, different chemical contents, etc.) Chain of custody init iation, when required.

Page 15 of 32 5.5 Customer Satisfaction TBE's quality policy centers on customer satisfaction (See 2.0). TBE will work to satisfy customers through full compliance with contract requirements, providing accurate data and properly responding to any questions or complaints.

Customers are provided full cooperation in their monitoring of Laboratory performance. Customers are notified if any applicable State Accreditation is withdrawn, revoked, or suspended.

5.5.1 Customer Complaints Any customer complaints are documented and tracked to closure. Most complaints concern analysis data and are received by Program Managers. They log each such complaint, order retests for verification, and provide documented results to customers. Co mplaints may also be received by QA or Operations.

If complaints are other than re-test type, the nonconformance and corrective action systems (Sections 12 and 13) are used to resolve them and record all actions taken. 5.5.2 Customer Confidentiality All laboratory personnel maintain confidentiality of customer-unique information.

Page 16 of 32 6.0 DOCUMENTATION GENERATION & CONTROL

6.1 General The documentation generation and control system is detailed in Procedure 1008. An overview is given below. The basic quality system documents are described in Section 2.0.

6.2 New Documentation Each Procedure and this QAM is written by appropriate personnel, validated if applicable (see Section 7.0), reviewed for adequacy, completeness, and correctness, and, if acceptable, accepted by the authorized approver [QA Manager, Operations Manager (or their designee)]. Both approvals are required if a Procedure affects both QA and Operations. (See Responsibilities in Section 3.0). These procedures control the quality m easurements and their accuracy.

Each document carries a unique identification number, a revision level, dates, page numbers and total page count, and approver identification and sign off. If TBE writes code for software, the software is version identified and issued after Verification and Valida tion per Section 7.0.

6.3 Documentation Changes Each change is reviewed in the same manner and by the same people as new documentation. Revision identifications are updated and changes indicated by side bars, italicized words, or by revision description when practical. Obsolete revisions are maintained by QA after being identified as obsolete.

6.4 Documentation Lists and Distributions Computer indexes of documents are maintained by Quality showing the current authorized revision level of each document. These revisions are placed on the Laboratory server and obsolete ones are removed so that all personnel have only the current documents. If hard copies are produced and distributed, separate distribution lists are maintained indicating who has them and their revision level(s). Copies downloaded off the server are uncontrolled unless verified by the user (on the computer) to be the latest revision.

6.5 Other Documentation In addition to TBE-generated documentation, QA maintains copies of applicable specifications, regul ations, and standard methods.

6.6 Documentation Reviews Each issued document is reviewed at least every third year by the approving personnel. This review determines continued suitability for use and compliance with requirements.

Page 17 of 32 7.0 DESIGN OF LABORATORY CONTROLS

7.1 General The Laboratory and its operating procedures are designed specifically for low level (environmental and in-plant) radioactive sample analysis. The various aspects of the laboratory design include the following which are discussed in subsequent paragraphs of this Section:

(a) Facility (b) Technical Processes and Methods (c) Verification of Design of Pr ocesses, Methods, and Software. (d) Design of Quality Controls (e) Counting Instrument Controls 7.2 Facility The facility was designed and built in 2000 to facilitate correct performance of operations in accordance with good laboratory practices and regulatory requirements. It provides security for operations and samples. It separates sample storage areas based on activity levels, separates wet chemistry from counting instrumentation for contamination control, and provides space and electronic systems for documentation, analysis, and record storage. Procedure 4014 describes the facility, room us es, layouts, etc.

7.3 Technical Processes and Methods 7.3.1 Operational Flow The laboratory design provides for sample receipt and storage (including special environmental provisions for perishable items) where samples are received from clients and other labs (see Section 9.0). The samples are logged into the computer based Laboratory Information Management System (LIMS) and receive unique identification numbers and bar code labels. (See Procedure 4017 for LIMS description and user procedures). The Program Managers then plan the work and assure LIMS contains any special instructions to analysts. Samples then go to sample preparation, wet chemistry (for chemical separation), and counting based on the radionuclides. See Procedures in the 2000 and 3000 series. Analysts perform the required tasks with data being entered into logbooks, LIMS, and counting equipment data systems as appropriate. Results are collected and reviewed by the Operations Manager and Program Managers and reports to clients are generated (See Section 14.0). All records (electronic or hard copy) are maintained in files or in back-up electronic copies (see Section 15.0). After the required hold periods and client notification and approval, samples are disposed of in compliance with regulatory requirements (s ee Procedures 5003 and 5004).

Page 18 of 32 7.3.2 Methods The laboratory methods documented in the 2000 and 3000 series of Procedures were primarily developed by senior TBE laboratory personnel based on years of experience at our prior facility in New Jersey. They have been improved, supplemented and implemented here. Where EPA or other accepted national methods exist (primarily for water analyses under State certification programs - see Procedure 4010), the TBE methods conform to the imposed requirements or State accepted alternate requirements. Any method modifications are documented and described in the Procedure. There are no nationally recognized methods for most other analysis methods but references to other method documents are noted where applicable.

7.3.3 Data Reduction and Analysis Whenever possible automatic data capture and computerized data reduction programs are used. Calculations are either performed using commercial software (counting system operating systems) or TBE developed and validated software is used (see 7.4 below). Analysis of reduced data is performed as described in Section 14.0 and Procedure 4004.

7.4 Verification of Technical Processes, Methods, and Software

7.4.1 Operational Flow Verification The entire QA Manual and related procedures describe the verification of elements of the technical process flow and the establishment of quality check points, reviews, and controls.

7.4.2 Method Verifications Methods are verified and validated per Procedure 4007 prior to use unless otherwise agreed to by the client. For most TBE methods initial validation occurred well in the past. New or significantly revised Methods receive initial validation by demonstration of their performance using known analytes (NIST traceable) in appropriate matrices. Sufficient samples are run to obtain statistical data that provides evidence of process capability and control, establishes detection levels (see procedure 4009), bias and precisi on data (see Procedure 4011). All method procedures and validation data are available to respective clients. Also see Section 7.5 below for the Demonstration of Capability program.

7.4.3 Data Reduction and Analysis Verification Data reduction and analysis verification is performed by personnel who did not generate the data. (See Section 14.0).

7.5 Design of Quality Controls

Page 19 of 32 7.5.1 General There are multiple quality controls designed into the laboratory operations. Many of these are described elsewhere in this manual and include personnel qualification (Section 4.0), Document control (6.0), Sample identification and control (9.0), Use of reference standards (10.0), intra- and inter- laborator y tests (10.0), etc. This Section describes the basic quality control systems used to verify Method capability and performance.

7.5.2 Demonstration of Capability (D of C)

The demonstration of capability system verifies and documents that the method, analyst, and the equipment can perfo rm within acceptable limits. The D of C is certified for each combination of analyte, method, and instrument type. D of C's are certified based on objective evidence at least annually. This program is combined with the analyst D of C program (See Section 4.0). Initial D of C's use the method validation effort as covered above. Subsequent D of C's use Inter- Laboratory samples (Procedure 4006) or, if necessary, laboratory generated samples using NIST traceable standards. If results are outside of control limits, re-demonstration is required after investigation and corrective action is accomplished (See Sections 12.0 and 13.0) 7.5.3 Process Control Checks Process control checks are designed to include Inter-Lab samples, Intra-lab QC check samples, and customer provided check samples. 10% of laboratory analysis samples are for process control purposes.

7.5.3.1 Inter- Lab Samples. Inter-lab samples are procured or obtained from sources providing analytes of interest in matrices similar to normal client samples. These samples may be used for Demonstration of Capability of analyst's, equipment and methods. They also provide for independent insight into the lab's process capabilities. Any value reported as being in the warning zone (over 2 sigma) is reviewed and improvements taken. Any value failing (over 3 sigma) is documented on an NCR and formal investigation per Section 12.0 and 13.0 is performed. If root causes are not clearly understood and fixed, re-tests are required using lab prepared samples (See Procedure 4006).

7.5.3.2 QC Samples. QC samples, along with Inter-lab samples and customer check samples, are 10% of the annual lab workload for the applicable analyte and method. If batch processing is used, some specifications require specific checks with each batch or each day rather than as continuous process controls. (See Procedure 4005)

QC samples consist of multiple types of samples including:

(a) Method blanks (b) Blank spikes (c) Matrix spikes Page 20 of 32 (d) Duplicates (e) Tracers and carriers Acceptance limits for these samples are given in Procedures or in lab standards. The number, frequency, and use of these sample types varies with the method, matrix, and supplemental requirements. The patterns of use versus method and the use of the resulting test dat a is described in Procedure 4005.

7.5.3.3 Customer Provided Check Samples. Customers may provide blind check samples and duplicates to aid in their evaluation of the Laboratory. When the lab is notified that sa mples are check samples their results are included in the QC sample percentage counts. Any report ed problems are treated as formal complaints and investigated per Section 5.

7.6 Counting Instrument Controls The calibration of instruments is their primary control and is described in Section 11.0. In addition, counting procedures (3000 series) also specify use of background checks (method blank data is not used for this) to evaluate possible counting equipment contamination. Instrument calibration checks using a lab standard from a different source than the one used for calibration are also used. Background data can be used to adjust client and test data. Checks with lab standards indicate potential calibration changes.

Page 21 of 32 8.0 PURCHASING AND SUBCONTRACT CONTROLS

8.1 General Procurement and Subcontracts efforts use the Huntsville-based Cost Point computer system to process orders. The Laboratory-generated Purchase Requisitions are electronically copied into Purchase Orders in Huntsville. The Laboratory also specifies sources to be used. Procured items and services are received at the Laboratory where receiving checks and inspections are made. Laboratory Procedure 1015 provides details on the procurement control system at the Laboratory and references the H untsville procedures as applicable.

8.2 Source Selection Sources for procurements of items and services are evaluated and approved by QA as described in Procedure 1015. Nationally recognized catalog item sources are approved by the QA Manager based on reputation. Maintenance services by an approved distributor or the equipment manufacturing company are pre-approved. Sources for other services are evaluated by QA, based on service criticality to the quality system, by phone, mail out, or site visit.

Subcontract sources for laboratory analysis services are only placed with accredited laboratories (by NELAP, NUPIC, State, Client, etc.) as applicable for the type of analysis to be performed. QA maintains lists of approved vendors and records of evaluations performed.

8.3 Procurement of Supplies and Support Services 8.3.1 Catalog Supplies The Laboratory procures reagents, processing chemicals, laboratory "glassware," consumables, and other catalog items from nationally known vendors and to applicable laboratory grades, purities, concentrations, accuracy levels, etc. Purchase Requisitions for t hese items specify catalog numbers or similar call-outs for these off-the-shelf items. Requisitions are generated by the personnel in the lab needing the item and are approved by the Operations or Production Manager.

Reagents are analytical reagent grade only.

8.3.2 Support Services Purchase Requisitions for support services (such as balance calibration, equipment maintenance, etc.) are processed as in 8.3.1 but technical requirements are specified and reviewed before approvals are given.

Page 22 of 32 8.3.3 Equipment and Software Purchase Requisitions for new equipment, software programs, and major facility modifications affecting the quality system are reviewed and approved by the Operations Manager and the QA Manager.

8.4 Subcontracting of Analytical Services When necessary, the Laboratory may subcontract analytical services required by a client. This may be because of special needs, infrequency of analysis, etc. Applicable quality and regulatory requirements are imposed in the Purchase Requisition and undergo a technical review by QA. TBE reserves the right of access by TBE and our client for verification purposes.

8.5 Acceptance of Items or Services Items and services affecting the quality system are verified at receipt based on objective evidence supplied by the vendor. Supply items are reviewed by the requisitioner and, if acceptable, are accepted via annotation on the vendor packing list or similar document. Similarly, equipment services are accepted by the requisitioning lab person. Calibration services are accepted by QA based on certification reviews.

(See Section 11.0.)

Data reports from analytical subcontractors are evaluated by Program Managers and subsequently by the Operations Manager (or designee) as part of client report reviews.

Items are not used until accepted and if items or services are rejected, QA is notified and nonconformance controls per Section 12.0 are followed. Vendors may be removed from the approved vendor's list if their performance is unacceptable.

Page 23 of 32 9.0 TEST SAMPLE IDENTIFICATION AND CONTROL

9.1 Sample Identification Incoming samples are inspected for customer identification, container condition, chain of custody forms, and radioactivity levels. If acceptable, the sample information is entered into LIMS which generates bar coded labels for attachment to the sample(s). The labels are attached and samples stored in the assigned location. If environmental controls are needed (refrigeration, freezing, etc.), the samples are placed in these storage locations. If not acceptable, the Program Manager is notified, the customer contacted, and the problem resolved (return of sample, added data receipts, etc.). See Procedure 4003 for more information on sample receipt.

9.2 LIMS The LIMS is used to schedule work, provide special information to analysts, and record all actions taken on samples. See Procedure 4017 and the 6000 series of procedures for more information on LIMS operations.

9.3 Sample Control The sample, with its bar coded label, is logged out to the applicable lab operation where the sample is processed per the applicable methods (Procedures 2000 and 3000). The LIMS-assigned numbers are used for identification through all operations to record data. Data is entered into LIMS, log books (kept by the analysts) or equipment data systems to record data. The combination of LIMS, logbooks, and equipment dat a systems provide the Chain of Custody data and document all actions taken on samples. Unused sample portions are returned to its storage area for possible verification use. Samples are discarded after required time limits are passed and after client notification and approval , if required.

Page 24 of 32 10.0 SPECIAL PROCESSES, INSPECTION, AND TEST

10.1 Special Processes The Laboratory's special processes are the methods used to analyze a sample and control equipment. These methods are defined in Procedures in the 2000 and 3000 series. These processes are performed to the qualified methods (see Section 7.0) by q ualified people (see 4.0).

10.2 Inspections and Tests The quality of the process is monitored by indirect means. This program involves calibration checks on counting equipments (see Section 11.0), intra-laboratory checks, and inter-laboratory checks. In addition, some customers submit quality control check samples (blinds, duplicates, external reference standards). All generated data gets independent reviews.

10.2.1 Intra Laboratory Checks (QC Checks)

The quantity and types of checks varies with the method, but basic checks which may include blanks, spiked blanks, matrix spikes, matrix spike duplicates, and duplicates are used as appropriate for customer samples. This process is described in Procedure 4005 and in Section 7.0.

10.2.2 Inter Laboratory Checks TBE participates in Inter-lab performance evaluation (check) programs with multiple higher level labs. These programs provide blind matrices for the types of matrix/analyte combinations routinely processed by the Lab, if available. This program is descri bed in Procedure 4006.

10.2.3 Data Reviews Raw data and reports are reviewed by the Operations Manager, or designees. This review checks for data logic, expected results, procedure compliance, etc. (See Section 14.0).

10.3 Control of Sampling of Samples Samples for analysis are supplied by customers preferably in quantities sufficient to allow re-verification analyses if needed. The samples are prepared for analysis by analysts and then an aliquot (partial sample extraction) is taken from the homogeneous customer sample for the initial analysis. Methods specify standard volumes of sample material required. Sampling data is recorded in LIMS and/or logbooks.

10.4 Reference Standards / Material

Page 25 of 32 10.4.1 Weights and Temperatures Reference standards are used by the Laboratory's calibration vendor to calibrate the Labs working instruments measuring weights and thermometers.

10.4.2 Radioactive Materials Reference radioactive standards, traceable to NIST, are procured from higher level laboratories. These reference materials are maintained in the standards area and are diluted down for use by laboratory analysts. All original and diluted volumes are fully traceable to source, procedure, analyst, dilution, and acquisition dates. See Section 11.0 and Procedure 1009.

Page 26 of 32 11.0 EQUIPMENT MAINTENANCE AND CALIBRATION

11.1 General There are two types of equipment used by the Laboratory: support equipment (scales, glassware, weights, thermometers, etc.) and instruments for counting. Standards traceable to NIST are used for calibration and are of the needed accuracy for laboratory operations. Procedures 1009, 4018, and 4019 describe the calibration and maintenance programs.

11.2 Support Equipment Analytical support equipment is purchased with the necessary accuracies and appropriate calibration data. If needed, initial calibration by the Laboratory or its calibration vendor is performed. Recalibration schedules are established and equipment recalibrated by the scheduled date by a calibration vendor or by Laboratory personnel. Maintenance is performed, as needed, per manufacturer's manuals or lab procedures.

In addition to calibrations and recalibrations, checks are made on the continued accuracy of items as described in Procedure 1009. Records are maintained of calibration and specified checks.

11.3 Instruments Instruments receive initial calibration using radioactive sources traceable to NIST. The initial calibration establishes statistical limits of variation that are used to set control limits for future checks and recalibration. This process is described in Procedure 4018. Instruments are maintained per Instrument Manual requirements.

Recalibrations are perfo rmed per the Procedure.

Between calibrations, check sources are used to assure no significant changes have occurred in the calibration of items. Background checks are performed to check for possible radioactive contamination. Background values are used to adjust sample results. Hardware and software are safeguarded from adjustments that could invalidate calibrations or results.

11.4 Nonconformances and Corrective Actions If calibrations or checks indicate a problem, the nonconformance system (Section 12.0) and corrective action system (Section 13.0) are initiated to document the problem and its resolution. Equipment is promptly removed from service if questionable.

Page 27 of 32 11.5 Records Records of calibrations are maintained. Calibration certificates from calibration vendors are maintained by QA. Other calibration data and check data is maintained in log books, LIMS, or instrument software as appropriate and as described in Procedures 1009, 4018, and 4019.

Page 28 of 32 12.0 NONCONFORMANCE CONTROLS

12.1 General The nonconformance control system is implemented whenever a nonconforming condition on any aspect of Laboratory analysis, testing, or results exist. The system takes graded actions based on the nature and severity of the nonconformance. Nonconforming items or processes are controlled to prevent inadvertent use. Nonconformances are documented and dispositioned. Notification is made to affected organizations, including clients. Procedure 1010 describes the procedures followed. Sample result s are only reported after resolution.

12.2 Responsibility and Authority Each Laboratory employee has the responsibility to report nonconformances and the authority to stop performing nonconforming work or using nonconforming equipment. Laboratory supervision can disposition and take corrective actions on minor problems. Any significant problem is documented by QA using the Laboratory's NCR system per Procedure 1010. QA conducts or assures the conduct of cause analyses, disposition of items or data, and initiation of corrective action if the nonconformance could recur.

12.3 10CFR21 Reporting The QA Manager reviews NCRs for possible need of customer and/or NRC notification per the requirements of 10CFR21. Procedure 1011 is followed in this review and for any required reporting.

Page 29 of 32 13.0 CORRECTIVE AND PREVENTIVE ACTIONS

13.1 General The Laboratory takes corrective actions on significant nonconformances (see Section 12.0). It also initiates preventive and improvement actions per the Company Quality Policy (see Section 2.0). The procedures for Corrective Action/Preventive Action systems are contained in Procedure 1012.

13.2 Corrective Actions Corrective actions are taken by Operations and Quality to promptly correct significant conditions adverse to quality. The condition is identified and cause analysis is performed to identify root causes. Solutions are evaluated and the optimum one selected that will prevent recurrence, can be implemented by the Laboratory, allows the Laboratory to meet its other goals, and is commensurate with the significance of the problem. All steps are documented, action plans developed for major efforts, and reports made to Management. QA verifies the implementation effectiveness. Procedure 1012 provides instructions and designates authorities and responsibilities.

13.3 Preventive Actions Preventive actions are improvements intended to reduce the potential for nonconformances. Possible preventive actions are developed from suggestions from employees and from analysis of Laboratory technical and quality systems by management. If preventive actions or improvements are selected for investigation, the issues, investigation, recommendat ions, and implementation actions are documented. Follow up verifies effectiveness.

Page 30 of 32 14.0 RESULTS ANALYSIS AND REPORTING

14.1 General The Laboratory's role is to provide measurement-based information to clients that is technically valid, legally defensible, and of known quality.

14.2 Results Review The results obtained from analytical efforts are collected and reviewed by the Operations Manager and the Program Manager. This review verifies the reasonableness and consistency of the results. It includes review of sample and the related QC activity data. Procedure 4002 describes the process. Any deficiencies are corrected by re-analyses, recalculations, or corrective actions per Sections 12.0 and 13.0. Use of the LIMS with its automatic data loading features (see Procedure 4017) minimizes the possibility of transcription or calculation errors.

14.3 Reports Reports range from simple results reporting to elaborate analytical reports based on the client requirements and imposed specifications and standards. (See Procedure 4004.) Reports present results accurately, clearly, unambiguously, objectively, and as required by the applicable Method(s). Reports include reproduction restrictions, information on any deviations from methods, and any needed data qualifiers based on QC data. If any data is supplied by analytical subcontractors (see Section 8.0), it is clearly identified and attributed to that Laboratory by either name or accreditation number.

If results are faxed or transmitted electronically, conf identiality statements are included in case of receipt by other than the intended client.

Reports are approved by the Program Manager and Operations Manager and record copies kept in file (See Section 15.0).

Page 31 of 32 15.0 RECORDS

15.1 General The Laboratory collects generated data and information related to quality or technical data and maintains them as records. Records are identified, prepared, reviewed, placed in storage, and maintai ned as set forth in Procedure 1003.

15.2 Type of Records All original observations, calculations, derived data, calibration data, and test reports are included. In addition QA data such as audits, management reviews, corrective and preventive actions, m anuals, and procedur es are included.

15.3 Storage and Retention Records are stored in files after completion in the lab. Files are in specified locations and under the control of custodians. Filing systems provide for retrieval. Electronic files are kept on Company servers (with regular back up) or on media stored in fireproof file cabinets. Records are kept in Laboratory files for at least 2 years after the last entry and then in Company files for another year as a minimum. Some customers specify larger periods - up to 7 years - which is also met. Generic records supporting multiple customers are kept for the longest applicable period.

15.4 Destruction or Disposal

Records may be destroyed after the retention period and after client notification and acceptance, if required. If the Laboratory closes, records will go in to company storage in Huntsville unless otherwise directed by customers. If the Laboratory is sold, either the new owner will accept record ownership or the records will go into Company st orage as stated above.

Page 32 of 32 16.0 ASSESSMENTS

16.1 General Assessments consist of internal audits and management reviews as set forth in Procedure 1013.

16.2 Audits Internal audits are planned, performed at least annually on all areas of the quality system, and are performed by qualif ied people who are as independent as possible from the activity audited. (The Laboratory's small size inhibits full independence in some technical areas.) Audits are coordinated by the Quality Manager who assures audit plans and checklists are generated and the results documented. Reports include descriptions of any findings and provide the auditor's assessment of the effectiveness of the audited activity. Report data includes personnel contacted.

Audit findings are re viewed with management and corrective actions agreed to and scheduled. Follow up is performed by QA to verify accomplishment and effectiveness of the corrective action.

16.3 Management Reviews The Annual Quality Assurance Report, prepared for some clients, is the Management Review vehicle. These reports cover audit results, corrective and preventive actions, external assessments, and QC and inter-laboratory performance checks. The report is reviewed with Management by the QA Manager for the continued suitability of the Quality Program and its effectiveness. Any needed improvements are defined, documented, and implemented. Follow ups are made to verify implementation and effectiveness.

Revision 1 045136 (22) Zion Station APPENDIX D LABORATORY ANALYTICAL REPORTS L28833 R2 / 1 of 162 L28833 R2 / 2 of 162 L28833 R2 / 3 of 162 L28833 R2 / 4 of 162 L28833 R2 / 5 of 162 L28833 R2 / 6 of 162 L28833 R2 / 7 of 162 L28833 R2 / 8 of 162 L28833 R2 / 9 of 162 L28833 R2 / 10 of 162 L28833 R2 / 11 of 162 L28833 R2 / 12 of 162 L28833 R2 / 13 of 162 L28833 R2 / 14 of 162 L28833 R2 / 15 of 162 L28833 R2 / 16 of 162 L28833 R2 / 17 of 162 L28833 R2 / 18 of 162 L28833 R2 / 19 of 162 L28833 R2 / 20 of 162 L28833 R2 / 21 of 162 L28833 R2 / 22 of 162 L28833 R2 / 23 of 162 L28833 R2 / 24 of 162 L28833 R2 / 25 of 162 L28833 R2 / 26 of 162 L28833 R2 / 27 of 162 L28833 R2 / 28 of 162 L28833 R2 / 29 of 162 L28833 R2 / 30 of 162 L28833 R2 / 31 of 162 L28833 R2 / 32 of 162 L28833 R2 / 33 of 162 L28833 R2 / 34 of 162 L28833 R2 / 35 of 162 L28833 R2 / 36 of 162 L28833 R2 / 37 of 162 L28833 R2 / 38 of 162 L28833 R2 / 39 of 162 L28833 R2 / 40 of 162 L28833 R2 / 41 of 162 L28833 R2 / 42 of 162 L28833 R2 / 43 of 162 L28833 R2 / 44 of 162 L28833 R2 / 45 of 162 L28833 R2 / 46 of 162 L28833 R2 / 47 of 162 L28833 R2 / 48 of 162 L28833 R2 / 49 of 162 L28833 R2 / 50 of 162 L28833 R2 / 51 of 162 L28833 R2 / 52 of 162 L28833 R2 / 53 of 162 L28833 R2 / 54 of 162 L28833 R2 / 55 of 162 L28833 R2 / 56 of 162 L28833 R2 / 57 of 162 L28833 R2 / 58 of 162 L28833 R2 / 59 of 162 L28833 R2 / 60 of 162 L28833 R2 / 61 of 162 L28833 R2 / 62 of 162 L28833 R2 / 63 of 162 L28833 R2 / 64 of 162 L28833 R2 / 65 of 162 L28833 R2 / 66 of 162 L28833 R2 / 67 of 162 L28833 R2 / 68 of 162 L28833 R2 / 69 of 162 L28833 R2 / 70 of 162 L28833 R2 / 71 of 162 L28833 R2 / 72 of 162 L28833 R2 / 73 of 162 L28833 R2 / 74 of 162 L28833 R2 / 75 of 162 L28833 R2 / 76 of 162 L28833 R2 / 77 of 162 L28833 R2 / 78 of 162 L28833 R2 / 79 of 162 L28833 R2 / 80 of 162 L28833 R2 / 81 of 162 L28833 R2 / 82 of 162 L28833 R2 / 83 of 162 L28833 R2 / 84 of 162 L28833 R2 / 85 of 162 L28833 R2 / 86 of 162 L28833 R2 / 87 of 162 L28833 R2 / 88 of 162 L28833 R2 / 89 of 162 L28833 R2 / 90 of 162 L28833 R2 / 91 of 162 L28833 R2 / 92 of 162 L28833 R2 / 93 of 162 L28833 R2 / 94 of 162 L28833 R2 / 95 of 162 L28833 R2 / 96 of 162 L28833 R2 / 97 of 162 L28833 R2 / 98 of 162 L28833 R2 / 99 of 162 L28833 R2 / 100 of 162 L28833 R2 / 101 of 162 L28833 R2 / 102 of 162 L28833 R2 / 103 of 162 L28833 R2 / 104 of 162 L28833 R2 / 105 of 162 L28833 R2 / 106 of 162 L28833 R2 / 107 of 162 L28833 R2 / 108 of 162 L28833 R2 / 109 of 162 L28833 R2 / 110 of 162 L28833 R2 / 111 of 162 L28833 R2 / 112 of 162 L28833 R2 / 113 of 162 L28833 R2 / 114 of 162 L28833 R2 / 115 of 162 L28833 R2 / 116 of 162 L28833 R2 / 117 of 162 L28833 R2 / 118 of 162 L28833 R2 / 119 of 162 L28833 R2 / 120 of 162 L28833 R2 / 121 of 162 L28833 R2 / 122 of 162 L28833 R2 / 123 of 162 L28833 R2 / 124 of 162 L28833 R2 / 125 of 162 L28833 R2 / 126 of 162 L28833 R2 / 127 of 162 L28833 R2 / 128 of 162 L28833 R2 / 129 of 162 L28833 R2 / 130 of 162 L28833 R2 / 131 of 162 L28833 R2 / 132 of 162 L28833 R2 / 133 of 162 L28833 R2 / 134 of 162 L28833 R2 / 135 of 162 L28833 R2 / 136 of 162 L28833 R2 / 137 of 162 L28833 R2 / 138 of 162 L28833 R2 / 139 of 162 L28833 R2 / 140 of 162 L28833 R2 / 141 of 162 L28833 R2 / 142 of 162 L28833 R2 / 143 of 162 L28833 R2 / 144 of 162 L28833 R2 / 145 of 162 L28833 R2 / 146 of 162 L28833 R2 / 147 of 162 L28833 R2 / 148 of 162 L28833 R2 / 149 of 162 L28833 R2 / 150 of 162 L28833 R2 / 151 of 162 L28833 R2 / 152 of 162 L28833 R2 / 153 of 162 L28833 R2 / 154 of 162 L28833 R2 / 155 of 162 L28833 R2 / 156 of 162 L28833 R2 / 157 of 162 L28833 R2 / 158 of 162 L28833 R2 / 159 of 162 L28833 R2 / 160 of 162 L28833 R2 / 161 of 162 L28833 R2 / 162 of 162 L29109 1 of 17 L29109 2 of 17 L29109 3 of 17 L29109 4 of 17 L29109 5 of 17 L29109 6 of 17 L29109 7 of 17 L29109 8 of 17 L29109 9 of 17 L29109 10 of 17 L29109 11 of 17 L29109 12 of 17 L29109 13 of 17 L29109 14 of 17 L29109 15 of 17 L29109 16 of 17 L29109 17 of 17

L29402 1 of 61 L29402 2 of 61 L29402 3 of 61 L29402 4 of 61 L29402 5 of 61 L29402 6 of 61 L29402 7 of 61 L29402 8 of 61 L29402 9 of 61 L29402 10 of 61 L29402 11 of 61 L29402 12 of 61 L29402 13 of 61 L29402 14 of 61 L29402 15 of 61 L29402 16 of 61 L29402 17 of 61 L29402 18 of 61 L29402 19 of 61 L29402 20 of 61 L29402 21 of 61 L29402 22 of 61 L29402 23 of 61 L29402 24 of 61 L29402 25 of 61 L29402 26 of 61 L29402 27 of 61 L29402 28 of 61 L29402 29 of 61 L29402 30 of 61 L29402 31 of 61 L29402 32 of 61 L29402 33 of 61 L29402 34 of 61 L29402 35 of 61 L29402 36 of 61 L29402 37 of 61 L29402 38 of 61 L29402 39 of 61 L29402 40 of 61 L29402 41 of 61 L29402 42 of 61 L29402 43 of 61 L29402 44 of 61 L29402 45 of 61 L29402 46 of 61 L29402 47 of 61 L29402 48 of 61 L29402 49 of 61 L29402 50 of 61 L29402 51 of 61 L29402 52 of 61 L29402 53 of 61 L29402 54 of 61 L29402 55 of 61 L29402 56 of 61 L29402 57 of 61 L29402 58 of 61 L29402 59 of 61 L29402 60 of 61 L29402 61 of 61 Revision 1 045136 (22) Zion Station APPENDIX E DATA VALIDATION MEMORANDUM

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