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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)
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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 DISCLAIMER: Prepared by:

SOME FORMATTING CHANGES MAY HAVE OCCURRED WHEN THE ORIGINAL DOCUMENT WAS PRINTED TO PDF; HOWEVER, Conestoga-Rovers THE ORIGINAL CONTENT REMAINS UNCHANGED. & Associates 651 Colby Drive Waterloo, Ontario Canada N2V 1C2 Office: (519) 884-0510 Fax: (519) 884-0525 SEPTEMBER 2006 web: http:\\www.CRAworld.com REF. NO. 045136 (22)

Worldwide Engineering, Environmental, Construction, and IT Services

Revision 1 TABLE OF CONTENTS Page EXECUTIVE

SUMMARY

.................................................................................................................... i

1.0 INTRODUCTION

...................................................................................................................1 2.0 STATION DESCRIPTION .....................................................................................................2 2.1 STATION LOCATION .......................................................................................2 2.2 OVERVIEW OF COOLING WATER OPERATIONS.....................................2 2.3 SURROUNDING LAND USE ...........................................................................4 2.4 STATION SETTING............................................................................................5 2.4.1 TOPOGRAPHY AND SURFACE WATER FEATURES.................................5 2.4.2 GEOLOGY ............................................................................................................6 2.4.3 HYDROGEOLOGY .............................................................................................7 2.5 AREA GROUNDWATER USE ..........................................................................8 3.0 AREAS FOR FURTHER EVALUATION.............................................................................9 3.1 SYSTEMS EVALUATIONS................................................................................9 3.2 HISTORICAL RELEASES ................................................................................12 3.3 STATION INVESTIGATIONS.........................................................................12 3.3.1 PRE-OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM .......................................12 3.3.2 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ......13 3.3.3 DEFUELED SAFETY ANALYSIS REPORT...................................................14 3.3.4 WISCONSIN DEPARTMENT OF HEALTH AND FAMILY SERVICES MONITORING ..............................................................15 3.4 IDENTIFIED AREAS FOR FURTHER EVALUATION ...............................15 4.0 FIELD METHODS.................................................................................................................18 4.1 STAFF GAUGE INSTALLATION...................................................................18 4.2 GROUNDWATER MONITORING WELL INSTALLATION.....................18 4.3 GROUNDWATER MONITORING WELL DEVELOPMENT ....................20 4.4 SURVEY ..............................................................................................................21 4.5 GROUNDWATER AND SURFACE WATER ELEVATION MEASUREMENTS....................................................................21 4.6 GROUNDWATER AND SURFACE WATER 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 ...................................................................26 4.11 ANALYSES.........................................................................................................26 045136 (22) Zion Station CONESTOGA-ROVERS & ASSOCIATES

Revision 1 TABLE OF CONTENTS Page 5.0 RESULTS

SUMMARY

..........................................................................................................27 5.1 STATION GEOLOGY .......................................................................................27 5.2 STATION HYDROGEOLOGY ........................................................................29 5.2.1 GROUNDWATER FLOW DIRECTIONS ......................................................29 5.2.2 MAN-MADE INFLUENCES ON GROUNDWATER FLOW .....................29 5.2.3 VERTICAL HYDRAULIC GRADIENTS........................................................30 5.2.4 LATERAL GROUNDWATER FLOW AND VELOCITY.............................30 5.3 GROUNDWATER QUALITY..........................................................................31 5.3.1

SUMMARY

OF BETA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS.................................................................................31 5.3.2

SUMMARY

OF GAMMA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS.................................................................................32 5.3.3

SUMMARY

OF FIELD MEASUREMENTS ...................................................32 5.4 SURFACE WATER QUALITY.........................................................................33 5.4.1

SUMMARY

OF BETA-EMITTING RADIONUCLIDE ANALYTICAL RESULTS.................................................................................33 5.4.2

SUMMARY

OF GAMMA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS.................................................................................33 6.0 RADIONUCLIDES OF CONCERN AND SOURCE AREAS .........................................35 6.1 GAMMA-EMITTING RADIONUCLIDES.....................................................35 6.2 BETA-EMITTING RADIONUCLIDES ...........................................................35 6.3 TRITIUM.............................................................................................................35 6.3.1 GENERAL CHARACTERISTICS ....................................................................35 6.3.2 DISTRIBUTION IN STATION GROUNDWATER.......................................36 6.3.3 CONCEPTUAL MODEL OF TRITIUM RELEASE AND MIGRATION.........................................................................37 6.3.4 ATTENUATION OF TRITIUM WITHIN THE SHALLOW GROUNDWATER SYSTEM ............................................................................37 7.0 EXPOSURE PATHWAY ASSESSMENT............................................................................39 7.1 HEALTH EFFECTS OF TRITIUM...................................................................39

7.2 BACKGROUND

CONCENTRATIONS OF TRITIUM ................................40 7.2.1 GROUNDWATER.............................................................................................40 7.2.2 PRECIPITATION DATA ..................................................................................40 7.2.3 SURFACE WATER DATA ...............................................................................41 7.2.4 DRINKING WATER DATA ............................................................................42 7.2.5 EXPECTED TRITIUM BACKGROUND FOR THE STATION ...................42 7.3 IDENTIFICATION OF POTENTIAL EXPOSURE PATHWAYS AND POTENTIAL RECEPTORS ............................................43 7.3.1 POTENTIAL GROUNDWATER MIGRATION TO DRINKING WATER USERS OFF THE STATION PROPERTY .......................................43 045136 (22) Zion Station CONESTOGA-ROVERS & ASSOCIATES

Revision 1 TABLE OF CONTENTS Page 7.3.2 POTENTIAL GROUNDWATER MIGRATION TO SURFACE WATER USERS ..............................................................................44 7.4

SUMMARY

OF POTENTIAL TRITIUM EXPOSURE PATHWAYS ..........44 7.5 OTHER RADIONUCLIDES.............................................................................45

8.0 CONCLUSION

S....................................................................................................................46 9.0 RECOMMENDATIONS.......................................................................................................49 9.1 DATA GAPS ......................................................................................................49 9.2 GROUNDWATER MONITORING ................................................................49

10.0 REFERENCES

........................................................................................................................50 045136 (22) Zion Station CONESTOGA-ROVERS & ASSOCIATES

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 045136 (22) Zion Station CONESTOGA-ROVERS & ASSOCIATES

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 045136 (22) Zion Station CONESTOGA-ROVERS & ASSOCIATES

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 045136 (22) Zion Station CONESTOGA-ROVERS & ASSOCIATES

Revision 1 EXECUTIVE

SUMMARY

This Hydrogeologic Investigation Report (HIR) documents the results of Conestoga-Rovers & Associates' (CRA's) May 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 groundwater 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, combined with its understanding of groundwater flow at the Station to identify the Areas for 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 with licensed plant operations were not detected at concentrations greater than their respective Lower Limits of Detection (LLDs) in any of the groundwater or surface 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 Protection 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 samples 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 045136 (22) Zion Station i CONESTOGA-ROVERS & ASSOCIATES

Revision 1 interval). The detected concentrations are 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 Exelon conduct periodic monitoring of selected sample locations.

045136 (22) Zion Station ii CONESTOGA-ROVERS & ASSOCIATES

Revision 1

1.0 INTRODUCTION

Conestoga-Rovers & Associates (CRA) has prepared 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 investigative tasks recommended by CRA during the course of the investigation. These investigations pertain to Exelon'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 Exelon 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 quality at the Station in locations designated as areas for further evaluation (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 hydrogeologic conditions at the Station including subsurface soil types, the presence or absence 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 quality at the Station including the vertical and horizontal extent, quantity, 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 response activities are warranted.

045136 (22) Zion Station 1 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 2.0 STATION DESCRIPTION The following section presents a general summary of the Station location and definition, overview of Station operations, surrounding land use, and an overview of both regional and Station-specific topography, surface water features, geology, hydrogeology, and groundwater flow conditions. This section also presents an overview of groundwater use in the area.

2.1 STATION LOCATION The Station is a former nuclear power generating facility that, in the early spring of 1998, converted both units' generators to synchronous condensers that provide voltage stability to the northeast Illinois power grid. The Station encompasses approximately 250 acres (Exelon, 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 monitored under the "SAFSTOR" (safe storage of components of the nuclear power plant) phase of decommissioning, as is discussed below.

2.2 OVERVIEW OF COOLING WATER OPERATIONS Former Operations In the mid-1950s, Commonwealth Edison Company (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 issued 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. Exelon submitted the certification of fuel transfer on March 9, 1998. In addition 045136 (22) Zion Station 2 CONESTOGA-ROVERS & ASSOCIATES

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 DPR-39 and DPR-48. Discharges from the Station are also subject to regulation under the Illinois Environmental Protection Agency (EPA) National Pollutant Discharge Elimination System (NPDES) Permit IL0002763.

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

Cooling Water Operations 1973-1997 The Station is comprised of two nearly identical pressurized water reactors with supporting facilities. Both primary reactor 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 piping, 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 internally lined with a welded steel plate and completely encloses the primary coolant system, 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 into 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 condenser was removed by the circulating water system. Circulating water was withdrawn from Lake Michigan, approximately 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).

Primary coolant was treated to remove impurities and recirculated through the primary water (PW) system. Primary coolant was stored in two above ground storage tanks (ASTs) located on the east side of the Turbine Building.

045136 (22) Zion Station 3 CONESTOGA-ROVERS & ASSOCIATES

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 east side of the Turbine Building.

Circulating water is drawn from Lake Michigan by way of an intake pipe that extends approximately a half mile into the Lake. Circulating water is returned to Lake Michigan by way of two discharge pipes that extend approximately a quarter mile into the lake.

Liquid wastes have been discharged under the NRC permit through the blowdown line, which is piped to the circulating water discharge 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 decommissioning process where the Station is maintained in a condition that allows it to be safely stored and subsequently 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 along 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 encompasses 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 Station 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.

045136 (22) Zion Station 4 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 2.4 STATION 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) last revision dated October 2004 (Exelon, 2004).

The main references the DSAR relies upon are listed in Section 10.0 of this HIR. CRA checked and verified all DSAR references that apply to this HIR.

2.4.1 TOPOGRAPHY AND SURFACE WATER FEATURES Lake County consists of moraines, outwash plains, 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 province. Relief in Lake County was caused by differences in the thickness of deposits left by the most recent glacier. The land surface gradually slopes to the south or southeast. 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 Valparaiso Morainic System, and the Fox Lake Moraine. In general, Lake County has a poorly defined drainage pattern. Many drainage ways terminate in depressions and marshes. The land area falls into four major watersheds and 26 drainage basins. The Chicago River, Des Plaines River, Fox River, and Lake Michigan watersheds are all shared 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 maximum width of approximately 1 mile near the City of Zion (Chrzastowski and Frankie, 2000). The older dunes become root-bound 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. The ground elevation at the main complex is 591 feet AMSL. The average lake level is 577 feet AMSL. The eastern portion of the 045136 (22) Zion Station 5 CONESTOGA-ROVERS & ASSOCIATES

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 square 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 Michigan 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 the two outlets. Water levels in Lake Michigan typically vary about 1 foot in elevation between annual low and high measurements. Generally, the lowest levels 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 are 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 approximately 2.3 miles south of the Station. The Dead River was so named because the mouth is periodically blocked by shifting sandbars on the Lake Michigan shoreline.

Storm water runoff from the switchyard is captured by the perimeter ditch, which is a drainage channel that follows the Station's outer fence. The perimeter ditch connects to Lake Michigan to the north and south of the Protected 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 western 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 where the stormwater drainage system is located above the water table as it drops towards Lake Michigan.

2.4.2 GEOLOGY This section presents an overview of Station geology based upon the 1967 Foundation Investigation (Dames and Moore, 1967) and other geologic publications. The Station is underlain by overburden deposits and a regionally extensive sequence of consolidated 045136 (22) Zion Station 6 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 sedimentary deposits. The major stratigraphic features can be divided into Paleozoic aged bedrock and Quaternary Period overburden 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 overburden 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 thickness of approximately 2,500 feet. Southerly long shore currents have eroded the Root River delta and transported the sediments along the western shore of Lake Michigan to form the Zion beach-ridge plain (Chrzastowski and Frankie, 2000).

2.4.3 HYDROGEOLOGY Groundwater in the region occurs in shallow glacial, alluvial, and lacustrine deposits.

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

Bedrock units form three major aquifer systems in northeastern Illinois. The uppermost bedrock aquifer consists of the Silurian dolomites. The underlying Maquoketa Group shales hydraulically separate the Silurian aquifer from deeper units.

The deeper aquifer systems include the Cambrian-Ordovician aquifer group, which includes the St. Peter and Ironton-Galesville sandstones. The underlying Eau Claire Formation hydraulically separates the Cambrian-Ordovician aquifer group from the deeper Mt. Simon Aquifer (Visocky et al., 1985).

The sandstones of the Mt. Simon Formation are not typically used for potable water because of undesirable characteristics including high concentrations of total dissolved solids and natural radioactivity. Crystalline 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 deposits and bedrock units in the region is generally toward the lake; however, localized pumping induces variations in flow directions in the bedrock aquifers.

045136 (22) Zion Station 7 CONESTOGA-ROVERS & ASSOCIATES

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 Station. 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 well 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. 51), not a water well (Map Id. 62), or no longer exist (Map Ids. 6 and 103). 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 expected 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 Michigan by means of an intake pipe located approximately 1.1 mile north of the Station and extending 3,000 feet into the Lake. The City of Zion municipal code requires all improved 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 exception is for existing wells constructed prior to March 2, 2004 at properties located more than 100 feet from the municipal supply system, which must: 1) enter 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 private water well at Lot #1, Beach Homeland subdivision, Beach Park, Illinois.

The latitude and longitude listed in the ISWS database is inconsistent with the address listed in the well log (Beach Park is located between Zion and Waukegan).

2 Map ID 6 is an engineering test hole installed by Norm Hester of the ISGS on November 1, 1972.

The total depth was 15 feet. This boring was installed as part of a study documented in Fraser and Hester (1974).

3 Map ID 10 is a water well installed by F H Ferguson at 'Zion Estates' at an unknown date. The total depth of the well was 138 feet. The location specified in the well record (42.446046N, 87.800889W) indicates that this well was located on the eastern edge of what is now the Zion Station. 'Zion Estates' may have been part of the Hosah Beach subdivision (see Bannon-Nilles 2003) which was purchased by ComEd in about 1967. This well is not currently present at the Zion Station.

045136 (22) Zion Station 8 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 3.0 AREAS FOR FURTHER EVALUATION CRA considered all Station operations in assessing groundwater quality at the Station.

During this process, CRA identified areas at the Station that warranted further evaluation or "AFEs". This section discusses the process by which AFEs were selected.

CRA's identification of AFEs involved 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 from these components combined with information obtained from CRA's study of hydrogeologic conditions at the Station to identify those areas where groundwater potentially could be impacted from operations at the Station.

CRA then designed an investigation to determine whether any confirmed or potential releases or any other release of radionuclides adversely affected groundwater. This entailed evaluating whether existing Station groundwater monitoring systems were sufficient to assess the groundwater quality at the AFEs. If the systems were not sufficient to adequately investigate groundwater quality associated with any AFE, additional monitoring wells were installed by CRA.

The following sections describe the above considerations and the identification of AFEs.

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

3.1 SYSTEMS EVALUATIONS Exelon launched an initiative to systematically assess the structures, systems and components that store, use, or convey potentially 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 contain potentially radioactively contaminated liquids. The following presents a list of these systems.

045136 (22) Zion Station 9 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 System Identification Description AD Auxiliary Drains AX Auxiliary Steam BD Blowdown System CF Cavity Fill CW Circulating Water VC Chemical and Volume Control CC Component Cooling CD/SC Condensate and Condensate Storage MS Main Steam PW Primary Water RR Resin Removal SI Safety Injection SW Service Water SF Spent Fuel TD Turbine Building Drains WD Waste Disposal WT Waste Water After these systems were identified, Exelon developed a list of the various structures, components and areas of the systems (e.g., piping, tanks, and process equipment) that handle or could potentially handle any radioactively contaminated liquids. 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.

045136 (22) Zion Station 10 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 The Station then individually evaluated the various system components to determine the potential for any release of radioactively contaminated liquid to enter the environment. Each structure or identified 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., welded or mechanical pipe joints);

concentration of radioactively contaminated liquid stored or conveyed;

amount of radioactively contaminated liquid stored or conveyed;

existing 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 liquid would not be discharged directly to the environment, were eliminated from further evaluation. System components that are not located within buildings or did not have some other form of secondary containment were retained for further qualitative evaluation of the risk of a release of radioactively contaminated liquid to the environment and the potential magnitude of any release.

Exelon's risk evaluation took into consideration factors such as:

the potential concentration of radionuclides;

the volume of liquid stored or managed;

the probabilities of the systems actually containing radioactively contaminated liquid; and

the potential for a release of radioactively 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 radioactively contaminated liquid to the environment.

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

045136 (22) Zion Station 11 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 3.2 HISTORICAL RELEASES CRA also reviewed information concerning confirmed or potential historical releases of radionuclides at the Station, including reports 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 conditions are further discussed in Section 3.4.

3.3 STATION INVESTIGATIONS CRA considered previous Station investigations in the process of selecting the AFEs for the Station. This section presents a summary of the pre-operational radiological environmental monitoring program (pre-operational REMP), past station investigations, and the radiological environmental monitoring program (REMP).

3.3.1 PRE-OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM A pre-operational REMP was conducted to establish background radioactivity levels prior to operation of the Station. The environmental media sampled and analyzed during the pre-operational REMP were surface water, well water, air particulates, milk, locally grown vegetables, and aquatic 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 concentrations 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 tritium in the surface water samples from the Lake at Zion ranged from approximately 311 +/- 20 pCi/L to 374 +/- 34 pCi/L and averaged 340 pCi/L. There was no statistical difference in average tritium concentrations among the stations (eight stations from Kenosha to Waukegan) (ComEd, 1971).

045136 (22) Zion Station 12 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 1973 Aerial Radiological Measuring System An Aerial Radiological Measuring System (ARMS) 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 locations as part of the study. Tritium measurements were not included in the ARMS survey (ComEd, 1999).

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

Soil samples contained small concentrations 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 for beta and gamma-emitting radionuclides, tritium, iodine-131, and/or strontium as established 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 description 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 personnel and is entitled Final Monthly Progress Report to Exelon Nuclear, Radiological Environmental Monitoring Program - 2005. This report concluded that the operation of the Station 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);

045136 (22) Zion Station 13 CONESTOGA-ROVERS & ASSOCIATES

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 collected 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 collected as part of the REMP. Tritium concentrations in surface water samples from Lake Michigan ranged from non-detect to 660 pCi/L.

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

It provides information on Station and local 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 excess 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 radioactive liquid waste generated is collected, treated and either recycled or discharged. Discharged liquid wastes are monitored to assure compliance with 10 CFR 20. Radioactivity levels should not exceed permissible concentrations at the cooling water outlet in Lake Michigan. The two closest municipal water intakes are the LCPWD (approximately 1 mile north) and the Waukegan Waterworks (approximately 6 miles south). The February 2005 REMP report indicates that there have been no tritium concentrations detected in surface water samples at concentrations exceeding the lower limit of detection (LLD) of 200 pCi/L.

045136 (22) Zion Station 14 CONESTOGA-ROVERS & ASSOCIATES

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 environmental radiation monitoring around the nuclear power facilities that impact Wisconsin. The Station is included in this monitoring due to its proximity to the 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 quality;

the average yearly exposure of ambient gamma radiation is at background levels and is comparable to other areas within Wisconsin;

the surface water samples showed no unusual concentrations of gross beta, gross gamma, tritium, and strontium;

the gamma isotopic analysis for surface water 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 liquid 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 above sections along with its understanding of the hydrogeology at the Station to identify AFEs, which were a primary consideration in the development of the scope of work in the Work Plan. The establishment of AFEs is a standard planning practice in hydrogeologic investigations to focus the investigation activities at areas where there 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; 045136 (22) Zion Station 15 CONESTOGA-ROVERS & ASSOCIATES

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 exhaustive review of all historic and current management of systems that may contain potentially radioactively contaminated liquids.

CRA reviewed the systems identified by the Station, which have the potential for the release of radioactively contaminated liquids to the environment, and groundwater flow at the Station. This evaluation allowed CRA to become familiar with Station operations and potential systems that may impact groundwater. 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 highest 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 single 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. Groundwater flow was an important factor in deciding whether to combine systems or historical releases into a single AFE or create separate AFEs. For example, groundwater beneath several systems that contain radioactively contaminated liquids that flows toward a common discharge point were likely combined into a single AFE. The AFEs were created based on known groundwater flow conditions prior to the work completed during this investigation.

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

045136 (22) Zion Station 16 CONESTOGA-ROVERS & ASSOCIATES

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) Aboveground Storage Tank (AST) Area This area was identified to evaluate the quality 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 discharge 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 quality 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 outfall. 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 Treatment 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.

045136 (22) Zion Station 17 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 4.0 FIELD METHODS The field investigations completed for this HIR were completed in May to July 2006.

CRA supervised the installation of monitoring 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 accordance with the methodologies presented in the Work Plan (CRA, 2006).

The scope of work presented in the Work Plan included the installation and sampling of nine permanent monitoring wells and the collection 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 investigative 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 gauge 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 extends approximately 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 minimize the potential of injury to workers and/or damage to subsurface utility structures. The subsurface clearance procedures consisted of completing an electronic survey within a minimum of 10-foot radius of the proposed location utilizing electromagnetic and ground penetrating radar technology.

045136 (22) Zion Station 18 CONESTOGA-ROVERS & ASSOCIATES

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 installed 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 were 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 permanent 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 schedule 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 the borehole was backfilled with a mixture of soil and bentonite); and

the remaining portion of the annulus was filled with concrete and a 6-inch diameter protective above-grade casing. The well head was fitted with a water-tight lockable cap.

Specific installation protocols for the temporary monitoring wells are described below:

the borehole was advanced to the target depth 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 schedule 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; 045136 (22) Zion Station 19 CONESTOGA-ROVERS & ASSOCIATES

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 unconsolidated materials that were to be used for monitoring well installation were installed using either DPT or 4.25-inch inside diameter HSA drilling techniques. The borehole depths ranged from 19 to 45 feet bgs. During the subsurface utility clearance activities described above, the borehole was periodically examined and the soil types documented. A description was added to each monitoring well construction log. The overburden soils were classified using the Unified Soil Classification System (USCS).

4.3 GROUNDWATER MONITORING WELL DEVELOPMENT To establish good hydraulic communication with 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 intervals and the pH, temperature, and conductivity were measured using field instruments. These instruments were calibrated daily according to the manufacturer's specifications. Additionally, observations such as color, odor, and turbidity of the purged water were recorded; and

development continued until the turbidity and silt content of the monitoring wells were significantly reduced and three consistent readings of pH, temperature, and conductivity were recorded, or a minimum of ten well volumes was purged.

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

045136 (22) Zion Station 20 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 4.4 SURVEY The 15 monitoring wells and surface water gauge 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 accuracy 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 groundwater 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 wells and staff gauges were identified and located. Once the wells were identified, CRA completed a thorough inspection of each well and noted any deficiencies. Water level 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 riser or steel casing of each monitoring well and reference point on the staff gauge. The water level measurements were obtained using the following procedures:

the proper elevation of the meter was checked by inserting the tip into water and noting if the contact was registering correctly;

the tip was dried, and then slowly lowered 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; 045136 (22) Zion Station 21 CONESTOGA-ROVERS & ASSOCIATES

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 the water level meter decontaminated prior to use at the next location.

Surface water measurements for Lake Michigan were obtained from the National Oceanic and Atmospheric Administration (NOAA) gauging stations at Milwaukee, Wisconsin (Station 9087057), and Calumet Harbor, 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 conducted 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 the screened interval. The lower sampling interval targets potential releases from deep structural features such as the basement of the Auxiliary Building. The upper sampling interval targets potential surface and near surface releases such as spills from the primary cooling water ASTs.

045136 (22) Zion Station 22 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 The groundwater in the monitoring wells was sampled by the following low-flow procedures:

the wells were located and the well identification 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 fixed 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 pumping rate between 100 to 500 milliliters per minute. Initial purging began using the lower 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 increased 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, conductivity, oxidation-reduction potential (ORP), dissolved oxygen (DO), and turbidity] were monitored during the purging to evaluate the stabilization of the purged groundwater. 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 groundwater samples were collected directly from the pump/tubing directly into the sample containers; and 045136 (22) Zion Station 23 CONESTOGA-ROVERS & ASSOCIATES

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 unique 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 shipment 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 surface water sampling location is presented on Figure 4.1.

The surface water sample was collected by directly 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 establish 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 collected 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; 045136 (22) Zion Station 24 CONESTOGA-ROVERS & ASSOCIATES

Revision 1

laboratory duplicates;

verification of laboratory qualifiers; and

field quality control (field blanks and duplicates).

Following the completion of field activities, 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 SAMPLE IDENTIFICATION Systematic sample identification codes were used 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 identification 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 CHAIN-OF-CUSTODY RECORD The samples were delivered to Station personnel under chain-of-custody protocol.

Subsequently, the Station shipped the samples under chain-of-custody protocol to Teledyne Brown for analyses.

045136 (22) Zion Station 25 CONESTOGA-ROVERS & ASSOCIATES

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 the accuracy of the analytical laboratory by providing two samples collected at the same location and then comparing the analytical results for consistency. Field duplicate samples were collected at a frequency of one duplicate for every ten samples collected. A total of three duplicate samples were collected. The locations of duplicate samples 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 with the actual sample at every sample location. Split samples were delivered to the Station personnel and (if requested) made available to the NRC. Split samples from the temporary monitoring wells were collected directly by the NRC and the Illinois Emergency Management Agency (IEMA).

4.11 ANALYSES 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.

045136 (22) Zion Station 26 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 5.0 RESULTS

SUMMARY

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

5.1 STATION GEOLOGY Geologic cross-sections in both a south-north and east-west profile have been developed.

Figure 5.1 displays the cross-section locations 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 structures potentially influencing groundwater flow patterns.

The Station is underlain by overburden deposits and a regionally extensive sequence of consolidated sedimentary deposits as discussed in Section 2.4.3. In descending order, the following overburden stratigraphic units have been identified and characterized during the various Station investigations:

Upper Sand Unit: Dense to very dense granular 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 approximately 555 feet AMSL.

Silt-Clay Unit: Hard silt, silty clay, clayey silt, and sandy silt, which contain some sand and gravel and occasional cobbles and boulders. Depth ranges from approximately 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 approximately 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.

045136 (22) Zion Station 27 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 The Silt-Clay Unit is consistent with quiet water lacustrine deposits and may be associated with post-glacial Lake Michigan (Nipissing Phase).

The Lower Sand Unit is consistent with recurring sequences of beach and quiet water lacustrine deposits and may be associated with the extreme Lake level fluctuations. As Lake levels rose, beach deposits moved westward with the shoreline and were followed by quiet water silt and clay deposits (a transgressive sequence). As Lake levels fell, the beach moved eastward with the shoreline (a regressive sequence).

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 Ordovician 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 constructed to depths of approximately 60 feet bgs.

Excavations were completed from grade, through the Upper Sand Unit and into the topmost portion of the Silt-Clay Unit. Excavated 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-Clay 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 groundwater and the geology, excavated areas, and reactor containment and building foundations.

Cross-Section B-B' (Figure 5.3) is an west-east profile that runs from monitoring well MW-ZN-07 through the Station to Lake Michigan and intersects AFE-Zion-1 and 045136 (22) Zion Station 28 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 AFE-Zion-3. This cross-section shows the relationship between the groundwater and geology, and building foundations.

5.2 STATION HYDROGEOLOGY This section presents the Station hydrogeology, 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 previously, 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 Figure 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 limits the flow of groundwater towards Lake Michigan. Groundwater between the sheet pile wall and the Turbine Building flows to the north or south around the wall. Although 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 square foot of wall.

5.2.2 MAN-MADE INFLUENCES ON GROUNDWATER FLOW The building foundations of the main complex extend through the Upper Sand Unit and into the top of the underlying silts and clays. Deep structures include the Reactor Containment Buildings, the Fuel Storage Building, the Auxiliary Building, the Turbine Building, and the crib area. The deep building foundations act as hydraulic barriers for shallow groundwater as is discussed below.

045136 (22) Zion Station 29 CONESTOGA-ROVERS & ASSOCIATES

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 construction and currently extends to a depth of approximately 45 feet bgs. The top of the sheet pile wall is lined with boulders and forms a breakwall, which is shown on Figure 5.3.

Shallow groundwater will flow into the stormwater 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 potentially contain tritiated water. As such the groundwater discharge to these stormwater systems 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 groundwater flow is limited by the underlying Silt-Clay Unit, which has a low permeability and is approximately 30 feet thick. To the extent that vertical flow can occur, the vertical gradient is expected 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-bearing zone is isolated from the underlying regional bedrock aquifers by the underlying Silt-Clay Unit. The Silt-Clay Unit is approximately 30 feet thick and extends approximately 15 feet below the deepest structural feature at the Station.

Shallow groundwater flows is generally towards 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 expected to be approximately 12 feet per day based on the median measurement from a study conducted along the Illinois-Indiana border of the shallow aquifer along Lake Michigan (USGS, 1996). The velocity of the shallow 045136 (22) Zion Station 30 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 groundwater may be roughly approximated using the Station-specific hydraulic gradient with the literature value for hydraulic conductivity and a typical value for porosity. Using the hydraulic gradient range 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 GROUNDWATER QUALITY CRA personnel collected groundwater samples from fifteen wells. The samples were analyzed for tritium and additional radionuclides. Teledyne Brown provided the analytical services. The Quality 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 results ultimately replaced an initial report. The tables and figures, therefore, include only the first analysis reported by the laboratory.

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

Two samples were collected from two different elevations in each permanent monitoring well except 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-ZN-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 equivalent 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 groundwater 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 045136 (22) Zion Station 31 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 exception of MW-ZN-09S). Groundwater samples 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 exceeding the LLD of 200 pCi/L were only detected in groundwater samples collected from monitoring 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 exceeding 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 this 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 not detected at concentration greater than their respective LLD. A summary of the gamma-emitting radionuclides results for the groundwater samples collected as part of the investigation that is the subject of this HIR is provided in Table 5.2 and presented graphically on Figure 5.7.

Other non-targeted radionuclides are 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 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 aquifer. The pH values ranged from 5.51 standard units to 045136 (22) Zion Station 32 CONESTOGA-ROVERS & ASSOCIATES

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 readings above 900 NTU collected from the lower portion of the screen at MW-ZN-04S; however, 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 stratigraphic log. Overall, the readings were within the expected 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 for tritium, gamma-emitting radionuclides, and strontium-89/90. Teledyne Brown provided the analytical services. The Quality Assurance Program for the laboratory is described in Appendix C. The analytical data reports are provided in Appendix D.

5.4.1

SUMMARY

OF BETA-EMITTING RADIONUCLIDE ANALYTICAL RESULTS Tritium was not detected at concentrations exceeding 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 concentration exceeding the LLD of 2.0 pCi/L. The strontium-89/90 result for the surface water sample 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-emitting radionuclides results for the surface water sample collected in this investigation is provided in Table 5.2 and shown on Figure 5.7.

Other non-targeted radionuclides are included in the tables but excluded from discussion in this report. These radionuclides were either a) naturally occurring and 045136 (22) Zion Station 33 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 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 potential of production from the Station.

045136 (22) Zion Station 34 CONESTOGA-ROVERS & ASSOCIATES

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 GAMMA-EMITTING RADIONUCLIDES Gamma-emitting target radionuclides were not detected at concentration exceeding their respective LLD. Other non-targeted radionuclides 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 potential of production from the Station.

6.2 BETA-EMITTING 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 sixteen total sample locations. Concentrations of tritium 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 general characteristics of tritium, potential sources, distribution in groundwater, and a conceptual model for migration.

6.3 TRITIUM This section discusses the general characteristics of tritium, the distribution of tritium in groundwater and surface water, and the conceptual model of tritium release and migration.

6.3.1 GENERAL CHARACTERISTICS Tritium (chemical symbol H-3) is a radioactive 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 essentially those of ordinary hydrogen. Tritiated 045136 (22) Zion Station 35 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 water behaves the same as ordinary water in both the environment and the body.

Tritium can be taken into the body by drinking water, breathing air, eating food, or absorption through skin. Once tritium enters 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. Organically bound tritium (tritium that is incorporated in organic compounds) can remain in the body for a longer period.

Tritium is produced naturally in the upper atmosphere when cosmic rays strike air molecules. Tritium is also produced during nuclear weapons explosions, 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 tritium 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, tritiated 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 approximately 12.3 years. It decays spontaneously to helium-3 (3He). This radioactive decay releases a beta particle (low-energy electron). The radioactivity of tritium is the source of the risk of exposure.

Tritium is one of the least dangerous radionuclides 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 lateral and vertical distribution of tritium detected in groundwater at the Station. Tritium was detected in groundwater at concentrations exceeding the LLD of 200 pCi/L.

Tritium concentrations in groundwater are presented on Figure 5.6. Tritium was only detected in groundwater samples from monitoring 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 045136 (22) Zion Station 36 CONESTOGA-ROVERS & ASSOCIATES

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 model of groundwater and tritium migration at the Station.

A conceptual model of groundwater and tritium 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 Unit 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 underlying low-permeability Silt-Clay Unit.

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 groundwater 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 aquifer having lower concentrations of tritium 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 distance from a release into the groundwater.

045136 (22) Zion Station 37 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 Tritium was not detected at concentrations exceeding 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 indication from the HIR investigation that tritium-impacted groundwater is migrating off the Station property.

045136 (22) Zion Station 38 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 7.0 EXPOSURE PATHWAY ASSESSMENT This section addresses the groundwater impacts from tritium and other radionuclides at the Station and potential risks to human health and the environment.

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

Teledyne Brown reports all samples to their statistically derived minimum detectable concentration (MDC) of approximately 150 to 170 pCi/L, which is associated with 95 percent confidence interval on their hardcopy 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 equates to 150 (+/- 135.75) pCi/L.

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

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

7.1 HEALTH EFFECTS OF TRITIUM Tritium is a radionuclide that decays by emitting 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 (drinking water) or through ingestion of water-bearing food products. Inhalation of tritium requires the water to be in a vapor form (i.e., through evaporation or vaporization due to heating). Inhalation is a minor exposure route when compared to 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.

045136 (22) Zion Station 39 CONESTOGA-ROVERS & ASSOCIATES

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 GROUNDWATER Tritium is created in the environment from naturally occurring processes both cosmic and subterranean, as well as from anthropogenic (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 6Li (92.5% abundance) and 7Li (7.5% abundance) present in crystalline rocks by neutrons produced by the radioactive 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 comes 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 prior to the signing of the Limited Test Ban Treaty in 1963, which prohibited atmospheric nuclear tests.

7.2.2 PRECIPITATION DATA 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 precipitation are Global Network of Isotopes in Precipitation (GNIP) and USEPA's RadNet database. GNIP provides tritium precipitation concentration data for samples collected world wide from 1960 to 2006.

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

Based on GNIP data for sample stations located 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 concentrations peaked around 1963. This peak, which approached 10,000 pCi/L for some stations, coincided with the atmospheric testing of 045136 (22) Zion Station 40 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 thermonuclear weapons. Tritium concentrations showed a sharp decline up until 1975 followed by a gradual decline since that time. 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 attributed 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 the GNIP data, the vast majority of the data were less than 100 pCi/L.

CRA constructed a non-parametric upper tolerance limit with a confidence of 95 percent and coverage of 95 percent based on RadNet 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 data, which does not include the minimum detectable concentration for a majority of the measurements. Some of the RadNet values below 200 pCi/L may be approximated. Nevertheless, these results show a background contribution for precipitation of up to 133 pCi/L.

7.2.3 SURFACE WATER DATA Tritium concentrations are routinely measured in large surface water bodies, including Lake Michigan and the Mississippi River. Surface water data from the RadNet database for Illinois sampling stations include East Moline (Mississippi River), Moline (Mississippi River), Marseilles (Illinois River), 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 data. 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 River) 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, 045136 (22) Zion Station 41 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 the typical background data provided may be subject to measurement uncertainty of approximately +/- 70 to 100 pCi/L.

7.2.4 DRINKING WATER DATA Tritium concentrations in drinking water from the RadNet database for three Illinois sampling stations (Chicago, Morris, and East Chicago) exhibit similar trends as the precipitation and surface water data. As with 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 tritium 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 databases, 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 Illinois surface water and groundwater, at least since 1995, have typically been less than 100 pCi/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 water and drinking water at the Station are expected to be comparable or less based on historical data and trends.

Concentrations in groundwater similar to surface water and drinking water are expected to be less than precipitation values. The lower 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, however, 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 the 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 studied in the vicinity of Zion throughout 1970 (prior to the construction of the Station). The concentration of tritium in Lake Michigan near Zion ranged from approximately 311 +/- 20 pCi/L to 374 +/- 34 pCi/L and averaged 340 pCi/L. There was no statistical difference in average tritium levels among 045136 (22) Zion Station 42 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 the sample locations (eight sample locations from Kenosha to Waukegan)

(ComEd, 1971).

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

Based on the evaluation presented above, the 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 Station 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 extent of the elevated concentrations of tritium in the direction of groundwater flow has been established, and is limited to the area around 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 samples 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 significantly 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.

045136 (22) Zion Station 43 CONESTOGA-ROVERS & ASSOCIATES

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 risk of exposure associated 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 extent of the elevated concentrations of tritium is limited to the area around MW-ZN-01S. The tritium concentrations detected in groundwater 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 water 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 detected 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 obtains its water for the City of Zion from Lake Michigan by means of an intake pipe located approximately 1 mile to the north of the Station and extending 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 Property to private and public groundwater users (drinking water exposure); and

groundwater migration off the Station Property to Lake Michigan (drinking water exposure and recreational exposure).

045136 (22) Zion Station 44 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 Based upon the groundwater and surface water data provided and referenced in this investigation, none of the potential receptors are at risk of exposure to concentrations of tritium in excess of USEPA drinking water standard (20,000 pCi/L).

7.5 OTHER 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 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 potential of production from the Station.

045136 (22) Zion Station 45 CONESTOGA-ROVERS & ASSOCIATES

Revision 1

8.0 CONCLUSION

S Based on all of the studies completed to date at the Zion Station, CRA concludes:

Groundwater Flow

The water table is in the Upper Sand Unit. 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 the east side of the Station by diverting the groundwater around the wall.

Groundwater Quality

None of the detected tritium concentrations 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 samples 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 with 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.

045136 (22) Zion Station 46 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 Surface Water Quality

Tritium was not detected in the surface water sample at a concentration greater than the USEPA drinking water standard of 20,000 pCi/L.

Tritium was not detected in the surface water sample at a concentration greater than the LLD of 200 pCi/L.

Gamma-emitting radionuclides associated with licensed plant operations were not detected at concentrations greater than their 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 with 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 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 samples 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 the 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 proximity to AFEs Zion 1, 3, and 4. 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.

AFE-Zion-2: Unit 1 (Southern) Aboveground Storage Tank (AST) Area

Gamma-emitting radionuclides associated with 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.

045136 (22) Zion Station 47 CONESTOGA-ROVERS & ASSOCIATES

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 investigation4, 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 the LLDs specified in this HIR.

045136 (22) Zion Station 48 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 9.0 RECOMMENDATIONS The following presents CRA's recommendations for proposed activities to be completed at the Station.

9.1 DATA GAPS Based on the results of this hydrogeologic investigation, there are no data gaps remaining to support CRAs conclusions regarding the characterization of the groundwater regime and potential impacts from radionuclides at the Station.

9.2 GROUNDWATER MONITORING Based upon the information collected to date, CRA recommends that Exelon conduct periodic monitoring of selected sample locations.

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

045136 (22) Zion Station 49 CONESTOGA-ROVERS & ASSOCIATES

Revision 1

10.0 REFERENCES

ATSDR, 2000. Public Health Assessment, Asbestos 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 Amending 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 Report, Water Testing Performed in 2005, City of Zion, Zion Public Works Department, June 23, 2006.

ComEd, 1967. Drawing B-1A, Location of Borings, 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 Investigation 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 Exelon Nuclear, Radiological Environmental Monitoring Program (REMP), for Zion Station, Zion, Illinois, Environmental Incorporated Midwest Laboratory, Northbrook, Illinois.

045136 (22) Zion Station 50 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 Exelon, 2005. Quad Cities Nuclear Power Station, 2004 Annual Radiological Environmental Operating Report.

Exelon, 2006. Offsite Dose Calculation Manual, Revision 15, Dockets 50-295 and 50-304 (Zion), Exelon Nuclear, February 2006.

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

Foote, 1982. Gary Ray Foote, Fracture Analysis 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 Application to Artificial Beach Replenishment, Environmental Geology Notes #67, Illinois State Geological Survey, 1974.

Hansel, 1983. Ardith K. Hansel, The Wadsworth Till Member of Illinois and the Equivalent Oak Creek Formation of Wisconsin, 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-Flow (Minimal Drawdown) Ground-Water Sampling Procedures, EPA Ground Water Issue, EPA/540/S-95/504, R.S. Kerr Environmental Research Center, Ada, Oklahoma.

045136 (22) Zion Station 51 CONESTOGA-ROVERS & ASSOCIATES

Revision 1 SEWRPC and WGNHS, 2002. Groundwater Resources of Southeastern Wisconsin, Technical Report No. 37, Southeastern Wisconsin Regional Planning Commission and Wisconsin Geological and Natural 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 Petroleum 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 Statement 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 Protection 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, Geohydrology, Water Levels and Directions of Flow, and Occurrence of Light-Nonaqueous-Phase Liquids on Ground Water in Northwestern Indiana and the Lake Calumet 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 Quality of the Cambrian and Ordovlclan Systems In Northern Illinois, Cooperative Groundwater Report 10, Illinois State Geological Survey, Illinois State Water Survey, Champaign, Illinois.

Willman, 1971. H.B. Willman, Summary of the Geology of the Chicago Area, Circular 460, Illinois State Geological 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.

045136 (22) Zion Station 52 CONESTOGA-ROVERS & ASSOCIATES

0 2000 4000ft STATION SOURCE: USGS QUADRANGLE MAP; ZION, ILLINOIS (1993) figure 1.1 STATION LOCATION MAP ZION STATION EXELON GENERATION COMPANY, LLC 45136-30(022)GN-WA001 AUG 24/2006

0 400 800ft SOURCES: MAP: USGS QUADRANGLE MAP; ZION, ILLINOIS (1993) figure 2.1 WELL LOCATIONS: BANKS INFORMATION SOLUTIONS, INC.

WATER WELL REPORT, JUNE 7, 2006 STATION SURFACE WATER FEATURES LEGEND ZION STATION PROPERTY LINE EXELON GENERATION COMPANY, LLC DITCH 45136-30(022)GN-WA024 SEP 07/2006 REVISION 1

SOURCE: ILLINOIS STATE GEOLOGICAL SURVEY, INTRODUCTION TO 3-D VISUALIZATION OF BEDROCK IN LAKE COUNTY, ILLINOIS figure 2.2 REGIONAL STRATIGRAPHIC CROSS-SECTION ZION STATION EXELON GENERATION COMPANY, LLC 45136-30(022)GN-WA007 AUG 24/2006

SOURCE: GUIDE TO THE GEOLOGY OF ILLINOIS BEACH STATE PARK AND THE ZION BEACH-RIDGE PLAIN, LAKE COUNTY, ILLINOIS STATE GEOLOGICAL SURVEY, 2000.

CROSS-SECTION LOCATION figure 2.3 CROSS-SECTION OF THE ZION BEACH-RIDGE PLAIN ZION STATION EXELON GENERATION COMPANY, LLC 45136-30(022)GN-WA016 AUG 24/2006

0 1500 3000ft 34 26 LIMIT OF 15 33 23 25 STUDY AREA 32 19 17 14 16 24 21 20 27 28 22 30 12 35 18 11 37 13 31 36 9

1 3 5 6

8 STATION 7

2 4 10 38 48 56 50 41 44 39 46 52 43 47 54 59 51 53 57 45 40 55 58 49 42 SOURCES: MAP: USGS QUADRANGLE MAP; ZION, ILLINOIS (1993) 40 GROUNDWATER WELL/WELL CLUSTER WELL LOCATIONS: BANKS INFORMATION SOLUTIONS, INC.

WATER WELL REPORT, JUNE 7, 2006 figure 2.4 PRIVATE/PUBLIC WATER SUPPLY WELL LOCATIONS ZION STATION EXELON GENERATION COMPANY, LLC 45136-30(022)GN-WA008 AUG 24/2006

MW-ZN-05S A A' SOUTH NORTH MW-ZN-10S (offset 224' W)

TURBINE BUILDING TURBINE BUILDING BH19 (offset 488' W) BH46 (offset 274' W)

INTAKE CRIB MW-ZN-03S BH70 (offset 61' E) BH71 (offset 49' E) BH7 (offset 150' W) 600 600 MW-ZN-11S (offset 58' E)

MW-ZN-04S BH1 (offset 660' W) MW-ZN-02S MW-ZN-01S FILL MW-ZN-08S UPPER/LOWER SAND UNIT MW-ZN-05S 590 590 SILT-CLAY UNIT BASEMENT / FOUNDATIONS 580 580 MEASUREMENTS TAKEN ON MAY 23, 2006 570 570 560 560 550 550 INTAKE LINE BOTTOM OF SHEET PILE WALL 540 540 ELEVATION (ft. AMSL) ELEVATION (ft. AMSL)

DISCHARGE DISCHARGE 530 LINE LINE 530 520 520 510 510 500 500 490 490 480 480 SCALE VERIFICATION THIS BAR MEASURES 1" ON ORIGINAL. ADJUST SCALE ACCORDINGLY.

470 470 EXELON GENERATION COMPANY, LLC 460 460 FLEETWIDE ASSESSMENT 0 500 1000 1500 DISTANCE (ft.)

GEOLOGIC CROSS SECTION A-A' ZION STATION ZION, ILLINOIS Source

Reference:

Project Manager: Reviewed By: Date:

S. QUIGLEY J. RABY AUGUST 2006 Scale: Project N o : Report N o : Drawing N o :

AS SHOWN 45136-30 022 figure 5.2 45136-30(022)GN-WA023 AUG 09/2006

MW-ZN-07S B B' CONTAINMENT BUILDING WEST EAST AUXILIARY BUILDING TURBINE BUILDING INTAKE CRIB 600 600 TW-ZN-100 (offset 150.6' N)

MW-ZN-09S MW-ZN-02S BREAK WALL TW-ZN-103 (offset 162.9' N)

FILL BH19 BH46 BH71 MW-ZN-07S BH1 BH7 UPPER/LOWER SAND UNIT 590 590 SILT-CLAY UNIT LAKE MICHIGAN NIAGARA DOLOMITE BASEMENT / FOUNDATIONS 580 580 MEASUREMENTS TAKEN ON MAY 23, 2006 SHEET PILE WALL 570 570 560 560 INTAKE LINE 550 550 540 540 DISCHARGE LINE ELEVATION (ft. AMSL) ELEVATION (ft. AMSL) 530 530 520 520 510 510 500 500 490 490 480 480 SCALE VERIFICATION THIS BAR MEASURES 1" ON ORIGINAL. ADJUST SCALE ACCORDINGLY.

470 470 EXELON GENERATION COMPANY, LLC 460 460 FLEETWIDE ASSESSMENT 0 500 1000 1500 2000 GEOLOGIC CROSS SECTION B-B' DISTANCE (ft.) ZION STATION ZION, ILLINOIS Source

Reference:

Project Manager: Reviewed By: Date:

S. QUIGLEY J. RABY AUGUST 2006 Scale: Project N o : Report N o : Drawing N o :

AS SHOWN 45136-30 022 figure 5.3 45136-30(022)GN-WA023 AUG 24/2006

TABLE 4.2 Page 1 of 5

SUMMARY

OF MONITORING WELL DEVELOPMENT PARAMATERS FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS 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 Page 2 of 5

SUMMARY

OF MONITORING WELL DEVELOPMENT PARAMATERS FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS 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 Page 3 of 5

SUMMARY

OF MONITORING WELL DEVELOPMENT PARAMATERS FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS 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 Page 4 of 5

SUMMARY

OF MONITORING WELL DEVELOPMENT PARAMATERS FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS 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 Page 5 of 5

SUMMARY

OF MONITORING WELL DEVELOPMENT PARAMATERS FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS 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 Page 1 of 1 ANALYTICAL RESULTS

SUMMARY

- TRITIUM IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Sample Location (1) Sample Identification QC Sample Sample Date Tritium (pCi/L) Result Error MW-ZN-01S(L) WG-ZN-MW-ZN-01L-052606-DS-07 5/26/2006 586 +/-141 MW-ZN-01S(L) GW-062806-PG-02 6/28/2006 ND (200) -

MW-ZN-01S(U) WG-ZN-MW-ZN-01U-052606-DS-05 5/26/2006 261 +/-124 MW-ZN-01S(U) GW-062806-PG-01 6/28/2006 220 +/-123 MW-ZN-02S(L) WG-ZN-MW-ZN-02L-052606-DS-06 5/26/2006 ND (200) -

MW-ZN-02S(U) WG-ZN-MW-ZN-02U-052606-DS-04 5/26/2006 ND (200) -

MW-ZN-03S(L) WG-ZN-MW-ZN-03L-052506-DS-03 5/25/2006 ND (200) -

MW-ZN-03S(U) WG-ZN-MW-ZN-03U-052506-DS-01 5/25/2006 ND (200) -

MW-ZN-03S(U) WG-ZN-MW-ZN-03U-052506-DS-02 Duplicate (01) 5/25/2006 ND (200) -

MW-ZN-04S(L) WG-ZION-MW-4L-052406-MB-004 5/24/2006 ND (200) -

MW-ZN-04S(U) WG-ZION-MW-4U-052406-MB-002 5/24/2006 ND (200) -

MW-ZN-05S(L) WG-ZION-MW-5L-052606-MS-013 5/26/2006 ND (200) -

MW-ZN-05S(U) WG-ZION-MW-5U-052606-MS-017 5/26/2006 ND (200) -

MW-ZN-06S(L) WG-ZION-MW-6L-052506-MS-009 5/25/2006 ND (200) -

MW-ZN-06S(U) WG-ZION-MW-6U-052606-MS-011 5/26/2006 ND (200) -

MW-ZN-07S(L) WG-ZION-MW-7L-052506-MS-007 5/25/2006 ND (200) -

MW-ZN-07S(U) WG-ZION-MW-7U-052406-MS-005 5/24/2006 ND (200) -

MW-ZN-08S(L) WG-ZION-MW-8L-052406-MS-001 5/24/2006 ND (200) -

MW-ZN-08S(U) WG-ZION-MW-8U-052406-MS-003 5/24/2006 ND (200) -

MW-ZN-09S WG-ZN-MW-ZN-09-052606-DS-08 5/26/2006 ND (200) -

MW-ZN-09S WG-ZN-MW-ZN-09-052606-DS-09 Duplicate (08) 5/26/2006 ND (200) -

MW-ZN-10S(L) WG-ZN-MW-ZN-10L-072806-MS-005 7/28/2006 ND (200) -

MW-ZN-10S(U) WG-ZN-MW-ZN-10U-072806-MS-003 7/28/2006 ND (200) -

MW-ZN-10S(U) WG-ZN-MW-ZN-10U-072806-MS-004 7/28/2006 ND (200) -

MW-ZN-11S(L) WG-ZN-MW-ZN-11L-072806-TL-002 7/28/2006 ND (200) -

MW-ZN-11S(U) WG-ZN-MW-ZN-11U-072806-TL-001 7/28/2006 ND (200) -

SW-ZN-1 WS-ZION-LAKE-052606-MS-015 5/26/2006 ND (200) -

TW-ZN-100 GW-071706-JL-TW-ZN-100 7/17/2006 ND (200) -

TW-ZN-101 GW-071706-JL-TW-ZN-101 7/17/2006 ND (200) -

TW-ZN-102 GW-071706-JL-TW-ZN-102 7/17/2006 ND (200) -

TW-ZN-103 GW-071706-JL-TW-ZN-103 7/17/2006 ND (200) -

Notes:

Samples analyzed by: Teledyne Brown Engineering, Inc.

(1) Sample locations include the well identifier followed by 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.

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TABLE 5.2 Page 1 of 10 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS 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)

Sample Identification: WG-ZN-MW-ZN-01L-052606-DS-07 Result WG-ZN-MW-ZN-01U-052606-DS-05 Result WG-ZN-MW-ZN-02L-052606-DS-06 Result Sample Date: 5/26/2006 Error 5/26/2006 Error 5/26/2006 Error Units Target Radionuclides Barium-140 pCi/L ND (60) - ND (60) - ND (60) -

Cesium-134 pCi/L ND (10) - ND (10) - ND (10) -

Cesium-137 pCi/L ND (18) - ND (18) - ND (18) -

Cobalt-58 pCi/L ND (15) - ND (15) - ND (15) -

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

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

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

Manganese-54 pCi/L ND (15) - ND (15) - ND (15) -

Niobium-95 pCi/L ND (10) - ND (10) - ND (10) -

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

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

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

(2)

Non-Target Radionuclides Actinium-228 pCi/L 35.23 +/-10.3 RNI - RNI -

Potassium-40 pCi/L 53.04 +/-34.2 RNI - 81.03 +/-42.45 Notes:

Samples analyzed by: Teledyne Brown (1) - Sample locations include the well identifier followed by a depth indicator of 'U' for the upper portion of the screen or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturally occurring.

RNI- Radionuclide Not Identified during analysis.

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

LLD - Lower limit of detection.

U* - Compound/Analyte not detected.

Peak not identified, but forced activity concentration exceeds Minimum Detectable Concentration and 3 sigma.

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

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TABLE 5.2 Page 2 of 10 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Sample Location (1) : MW-ZN-02S(U) MW-ZN-02S(U) MW-ZN-03S(L) MW-ZN-03S(L) MW-ZN-03S(U) MW-ZN-03S(U)

Sample Identification: WG-ZN-MW-ZN-02U-052606-DS-04 Result WG-ZN-MW-ZN-03L-052506-DS-03 Result WG-ZN-MW-ZN-03U-052506-DS-01 Result Sample Date: 5/26/2006 Error 5/25/2006 Error 5/25/2006 Error Units Target Radionuclides Barium-140 pCi/L ND (60) - ND (60) - ND (60) -

Cesium-134 pCi/L ND (10) - ND (10) - ND (10) -

Cesium-137 pCi/L ND (18) - ND (18) - ND (18) -

Cobalt-58 pCi/L ND (15) - ND (15) - ND (15) -

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

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

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

Manganese-54 pCi/L ND (15) - ND (15) - ND (15) -

Niobium-95 pCi/L ND (10) - ND (10) - ND (10) -

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

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

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

(2)

Non-Target Radionuclides Actinium-228 pCi/L RNI - RNI - RNI -

Potassium-40 pCi/L 73.65 +/-44.47 RNI - RNI -

Notes:

Samples analyzed by: Teledyne Brown (1) - Sample locations include the well identifier followed by a depth indicator of 'U' for the upper portion of the screen or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturally occurring.

RNI- Radionuclide Not Identified during analysis.

ND ( ) - Not detected at a concentration above the LLD. Valu LLD - Lower limit of detection.

U* - Compound/Analyte not detected.

Peak not identified, but forced activity concentration exceeds Minimum Detectable Concentration and 3 sigma.

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

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TABLE 5.2 Page 3 of 10 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Sample Location (1) : MW-ZN-03S(U) MW-ZN-03S(U) MW-ZN-04S(L) MW-ZN-04S(L) MW-ZN-04S(U) MW-ZN-04S(U)

Sample Identification: WG-ZN-MW-ZN-03U-052506-DS-02 Result WG-ZION-MW-4L-052406-MB-004 Result WG-ZION-MW-4U-052406-MB-002 Result Sample Date: 5/25/2006 Error 5/24/2006 Error 5/24/2006 Error Duplicate Units Target Radionuclides Barium-140 pCi/L ND (60) - ND (60) - ND (60) -

Cesium-134 pCi/L ND (10) U* - ND (10) - ND (10) -

Cesium-137 pCi/L ND (18) - ND (18) - ND (18) -

Cobalt-58 pCi/L ND (15) - ND (15) - ND (15) -

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

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

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

Manganese-54 pCi/L ND (15) - ND (15) - ND (15) -

Niobium-95 pCi/L ND (10) - ND (10) - ND (10) -

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

Zinc-65 pCi/L ND (30) U* - ND (30) - ND (30) -

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

(2)

Non-Target Radionuclides Actinium-228 pCi/L RNI - RNI - RNI -

Potassium-40 pCi/L RNI - 85.89 +/-44.24 RNI -

Notes:

Samples analyzed by: Teledyne Brown (1) - Sample locations include the well identifier followed by a depth indicator of 'U' for the upper portion of the screen or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturally occurring.

RNI- Radionuclide Not Identified during analysis.

ND ( ) - Not detected at a concentration above the LLD. Valu LLD - Lower limit of detection.

U* - Compound/Analyte not detected.

Peak not identified, but forced activity concentration exceeds Minimum Detectable Concentration and 3 sigma.

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

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TABLE 5.2 Page 4 of 10 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Sample Location (1) : MW-ZN-05S(L) MW-ZN-05S(L) MW-ZN-05S(U) MW-ZN-05S(U) MW-ZN-06S(L) MW-ZN-06S(L)

Sample Identification: WG-ZION-MW-5L-052606-MS-013 Result WG-ZION-MW-5U-052606-MS-017 Result WG-ZION-MW-6L-052506-MS-009 Result Sample Date: 5/26/2006 Error 5/26/2006 Error 5/25/2006 Error Units Target Radionuclides Barium-140 pCi/L ND (60) - ND (60) - ND (60) -

Cesium-134 pCi/L ND (10) - ND (10) - ND (10) U* -

Cesium-137 pCi/L ND (18) - ND (18) - ND (18) -

Cobalt-58 pCi/L ND (15) - ND (15) - ND (15) -

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

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

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

Manganese-54 pCi/L ND (15) - ND (15) - ND (15) -

Niobium-95 pCi/L ND (10) - ND (10) - ND (10) U* -

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

Zinc-65 pCi/L ND (30) - ND (30) - ND (30) U* -

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

(2)

Non-Target Radionuclides Actinium-228 pCi/L RNI - RNI - RNI -

Potassium-40 pCi/L RNI - RNI - RNI -

Notes:

Samples analyzed by: Teledyne Brown (1) - Sample locations include the well identifier followed by a depth indicator of 'U' for the upper portion of the screen or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturally occurring.

RNI- Radionuclide Not Identified during analysis.

ND ( ) - Not detected at a concentration above the LLD. Valu LLD - Lower limit of detection.

U* - Compound/Analyte not detected.

Peak not identified, but forced activity concentration exceeds Minimum Detectable Concentration and 3 sigma.

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

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TABLE 5.2 Page 5 of 10 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Sample Location (1) : MW-ZN-06S(U) MW-ZN-06S(U) MW-ZN-07S(L) MW-ZN-07S(L) MW-ZN-07S(U) MW-ZN-07S(U)

Sample Identification: WG-ZION-MW-6U-052606-MS-011 Result WG-ZION-MW-7L-052506-MS-007 Result WG-ZION-MW-7U-052406-MS-005 Result Sample Date: 5/26/2006 Error 5/25/2006 Error 5/24/2006 Error Units Target Radionuclides Barium-140 pCi/L ND (60) - ND (60) - ND (60) -

Cesium-134 pCi/L ND (10) - ND (10) U* - ND (10) U* -

Cesium-137 pCi/L ND (18) - ND (18) - ND (18) -

Cobalt-58 pCi/L ND (15) - ND (15) - ND (15) -

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

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

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

Manganese-54 pCi/L ND (15) - ND (15) - ND (15) -

Niobium-95 pCi/L ND (10) - ND (10) - ND (10) -

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

Zinc-65 pCi/L ND (30) - ND (30) - ND (30) U* -

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

(2)

Non-Target Radionuclides Actinium-228 pCi/L RNI - RNI - RNI -

Potassium-40 pCi/L RNI - RNI - RNI -

Notes:

Samples analyzed by: Teledyne Brown (1) - Sample locations include the well identifier followed by a depth indicator of 'U' for the upper portion of the screen or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturally occurring.

RNI- Radionuclide Not Identified during analysis.

ND ( ) - Not detected at a concentration above the LLD. Valu LLD - Lower limit of detection.

U* - Compound/Analyte not detected.

Peak not identified, but forced activity concentration exceeds Minimum Detectable Concentration and 3 sigma.

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

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TABLE 5.2 Page 6 of 10 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Sample Location (1) : MW-ZN-08S(L) MW-ZN-08S(L) MW-ZN-08S(U) MW-ZN-08S(U) MW-ZN-09S MW-ZN-09S Sample Identification: WG-ZION-MW-8L-052406-MS-001 Result WG-ZION-MW-8U-052406-MS-003 Result WG-ZN-MW-ZN-09-052606-DS-08 Result Sample Date: 5/24/2006 Error 5/24/2006 Error 5/26/2006 Error Units Target Radionuclides Barium-140 pCi/L ND (60) - ND (60) - ND (60) -

Cesium-134 pCi/L ND (10) U* - ND (10) - ND (10) -

Cesium-137 pCi/L ND (18) - ND (18) - ND (18) -

Cobalt-58 pCi/L ND (15) - ND (15) - ND (15) -

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

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

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

Manganese-54 pCi/L ND (15) - ND (15) - ND (15) -

Niobium-95 pCi/L ND (10) - ND (10) - ND (10) -

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

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

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

(2)

Non-Target Radionuclides Actinium-228 pCi/L RNI - RNI - RNI -

Potassium-40 pCi/L RNI - 69.37 +/-45.71 RNI -

Notes:

Samples analyzed by: Teledyne Brown (1) - Sample locations include the well identifier followed by a depth indicator of 'U' for the upper portion of the screen or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturally occurring.

RNI- Radionuclide Not Identified during analysis.

ND ( ) - Not detected at a concentration above the LLD. Valu LLD - Lower limit of detection.

U* - Compound/Analyte not detected.

Peak not identified, but forced activity concentration exceeds Minimum Detectable Concentration and 3 sigma.

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

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TABLE 5.2 Page 7 of 10 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Sample Location (1) : MW-ZN-09S MW-ZN-09S MW-ZN-10S(L) MW-ZN-10S(L) MW-ZN-10S(U) MW-ZN-10S(U)

Sample Identification: WG-ZN-MW-ZN-09-052606-DS-09 Result WG-ZN-MW-ZN-10L-072806-MS-005 Result WG-ZN-MW-ZN-10U-072806-MS-003 Result Sample Date: 5/26/2006 Error 7/28/2006 Error 7/28/2006 Error Duplicate Units Target Radionuclides Barium-140 pCi/L ND (60) - ND (60) - ND (60) -

Cesium-134 pCi/L ND (10) - ND (10) - ND (10) -

Cesium-137 pCi/L ND (18) - ND (18) - ND (18) -

Cobalt-58 pCi/L ND (15) - ND (15) - ND (15) -

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

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

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

Manganese-54 pCi/L ND (15) - ND (15) - ND (15) -

Niobium-95 pCi/L ND (10) - ND (10) - ND (10) -

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

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

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

(2)

Non-Target Radionuclides Actinium-228 pCi/L RNI - RNI - RNI -

Potassium-40 pCi/L RNI - RNI - 83.66 +/-42.25 Notes:

Samples analyzed by: Teledyne Brown (1) - Sample locations include the well identifier followed by a depth indicator of 'U' for the upper portion of the screen or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturally occurring.

RNI- Radionuclide Not Identified during analysis.

ND ( ) - Not detected at a concentration above the LLD. Valu LLD - Lower limit of detection.

U* - Compound/Analyte not detected.

Peak not identified, but forced activity concentration exceeds Minimum Detectable Concentration and 3 sigma.

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

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TABLE 5.2 Page 8 of 10 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Sample Location (1) : MW-ZN-10S(U) MW-ZN-10S(U) MW-ZN-11S(L) MW-ZN-11S(L) MW-ZN-11S(U) MW-ZN-11S(U)

Sample Identification: WG-ZN-MW-ZN-10U-072806-MS-004 Result WG-ZN-MW-ZN-11L-072806-TL-002 Result WG-ZN-MW-ZN-11U-072806-TL-001 Result Sample Date: 7/28/2006 Error 7/28/2006 Error 7/28/2006 Error Units Target Radionuclides Barium-140 pCi/L ND (60) - ND (60) - ND (60) -

Cesium-134 pCi/L ND (10) U* - ND (10) U* - ND (10) U* -

Cesium-137 pCi/L ND (18) - ND (18) - ND (18) -

Cobalt-58 pCi/L ND (15) - ND (15) - ND (15) -

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

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

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

Manganese-54 pCi/L ND (15) - ND (15) - ND (15) -

Niobium-95 pCi/L ND (10) - ND (10) - ND (10) -

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

Zinc-65 pCi/L ND (30) U* - ND (30) - ND (30) U* -

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

(2)

Non-Target Radionuclides Actinium-228 pCi/L RNI - RNI - RNI -

Potassium-40 pCi/L RNI - RNI - RNI -

Notes:

Samples analyzed by: Teledyne Brown (1) - Sample locations include the well identifier followed by a depth indicator of 'U' for the upper portion of the screen or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturally occurring.

RNI- Radionuclide Not Identified during analysis.

ND ( ) - Not detected at a concentration above the LLD. Valu LLD - Lower limit of detection.

U* - Compound/Analyte not detected.

Peak not identified, but forced activity concentration exceeds Minimum Detectable Concentration and 3 sigma.

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

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TABLE 5.2 Page 9 of 10 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Sample Location (1) : SW-ZN-1 SW-ZN-1 TW-ZN-100 TW-ZN-100 TW-ZN-101 TW-ZN-101 TW-ZN-101 TW-ZN-101 Sample Identification: WS-ZION-LAKE-052606-MS-015 Result GW-071706-JL-TW-ZN-100 Result GW-071706-JL-TW-ZN-101 Result GW-071706-JL-TW-ZN-101 Result Sample Date: 5/26/2006 Error 7/17/2006 Error 7/17/2006 Error 7/17/2006 Error Re-run Units Target Radionuclides Barium-140 pCi/L ND (60) - ND (60) - ND (60) - ND (60) -

Cesium-134 pCi/L ND (10) - ND (10) - ND (10) - ND (10) U* -

Cesium-137 pCi/L ND (18) - ND (18) - ND (18) - ND (18) -

Cobalt-58 pCi/L ND (15) - ND (15) - ND (15) - ND (15) -

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

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

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

Manganese-54 pCi/L ND (15) - ND (15) - ND (15) - ND (15) -

Niobium-95 pCi/L ND (10) - ND (10) - ND (10) - ND (10) -

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

Zinc-65 pCi/L ND (30) - ND (30) - ND (30) - ND (30) U* -

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

(2)

Non-Target Radionuclides Actinium-228 pCi/L RNI - RNI RNI - RNI -

Potassium-40 pCi/L 106.8 +/-48.41 RNI -- RNI - RNI -

Notes:

Samples analyzed by: Teledyne Brown (1) - Sample locations include the well identifier followed by a depth indicator of 'U' for the upper portion of the screen or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturally occurring.

RNI- Radionuclide Not Identified during analysis.

ND ( ) - Not detected at a concentration above the LLD. Valu LLD - Lower limit of detection.

U* - Compound/Analyte not detected.

Peak not identified, but forced activity concentration exceeds Minimum Detectable Concentration and 3 sigma.

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

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TABLE 5.2 Page 10 of 10 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER AND SURFACE WATER FLEETWIDE ASSESSMENT ZION STATION ZION, ILLINOIS Sample Location (1) : TW-ZN-102 TW-ZN-102 TW-ZN-103 TW-ZN-103 Sample Identification: GW-071706-JL-TW-ZN-102 Result GW-071706-JL-TW-ZN-103 Result Sample Date: 7/17/2006 Error 7/17/2006 Error Units Target Radionuclides Barium-140 pCi/L ND (60) - ND (60) -

Cesium-134 pCi/L ND (10) - ND (10) -

Cesium-137 pCi/L ND (18) - ND (18) -

Cobalt-58 pCi/L ND (15) - ND (15) -

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

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

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

Manganese-54 pCi/L ND (15) - ND (15) -

Niobium-95 pCi/L ND (10) - ND (10) -

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

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

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

(2)

Non-Target Radionuclides Actinium-228 pCi/L RNI - RNI -

Potassium-40 pCi/L RNI - RNI -

Notes:

Samples analyzed by: Teledyne Brown (1) - Sample locations include the well identifier followed by a depth indicator of 'U' for the upper portion of the screen or 'L' for the lower portion of the screen.

(2) - Radionuclide is naturally occurring.

RNI- Radionuclide Not Identified during analysis.

ND ( ) - Not detected at a concentration above the LLD. Valu LLD - Lower limit of detection.

U* - Compound/Analyte not detected.

Peak not identified, but forced activity concentration exceeds Minimum Detectable Concentration and 3 sigma.

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

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

Revision 0 APPENDIX A WATER WELL INVENTORY RECORDS A.1 BANKS 2006 WATER WELL REPORT A.2 ISWS LOGS 045136 (22) Zion Station

Revision 0 A.1 BANKS 2006 WATER WELL REPORT 045136 (22) Zion Station

Banks '

Water Well Report Information Solutions, Inc. June 7, 2006 CLIENT Conestoga-Rovers & Associates 8615 W Bryn Mawr Avenue Chicago, IL 60631 SITE Zion Generating Station Zion, IL Lake County 060706-001 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 TM Banks Information Solutions, Inc. Map of Wells within 1 Mile 26 34

23 25 Y

15 15th St # 33 32 # #

Illinois 19 Y

21 14 24 #

17 17th St Elizabeth Ave

16 #

Y 20 27 28 Y18 #

Y #

Y#

Y 30 12 22 35 11 Y#

Y #

37 #

Y 20th St 31 36 13 29 9

21st St Y

22nd St Galilee Ave Fulton Ave 1

Sheridan Rd 5

6 #

Y3 #

8 7 27th St 10 2 4 # #

Y 38 48 #

56 Gilboa Ave 41 50 44 # 39 Y# Y #

Y 46 59 Y 43

Y #

Y 54 52 51 #

47 #

Y #

Y 53 57 Y # Y # Wadsworth Rd YW Y 58 Patomos Ave 45 #

Y# 40 Y # Y 42 55 49 N Sheridan Rd N

Cty A13

Ú Subject Site 0 0.5 1 1.5 2 Miles Y Ground Water Wells (Cluster)

Ground Water Well Airport Water body Park Banks Information Solutions, Inc.

P Hospital Highway State P.O. Box 12851, Capitol Station Austin, Texas 78711 Primary road 700 N. Lamar, Suite 200 Austin, Texas 78703 Secondary and connecting road Local road 512-478-0059 FAX 512-478-1433 E Mail: BANKS@BANKSINFO.COM Access road June 7, 2006

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209702313 MAP ID Banks ID 1709700030 1 Owner Of Well J. Sekowski Type Of Well N/A Depth Drilled 62 '

Completion Date 1/1/1950 Longitude -87.83276 Latitude 42.45169 State ID 1209702312 MAP ID Banks ID 1709700033 2 Owner Of Well W.T. Loblow Type Of Well N/A Depth Drilled 200 '

Completion Date N/A Longitude -87.83159 Latitude 42.44537 State ID 1209702317 MAP ID Banks ID 1709700031 3 Owner Of Well J. Sekowski Type Of Well N/A Depth Drilled 82 '

Completion Date 1/1/1952 Longitude -87.83524 Latitude 42.4499 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209702314 MAP ID Banks ID 1709700034 3 Owner Of Well Shiloh Park Type Of Well N/A Depth Drilled 1569 '

Completion Date N/A Longitude -87.83524 Latitude 42.4499 State ID 1209702316 MAP ID Banks ID 1709700032 4 Owner Of Well Zion City Well Type Of Well N/A Depth Drilled 1025 '

Completion Date N/A Longitude -87.82679 Latitude 42.44535 State ID 1209702051 MAP ID Banks ID 1709700036 4 Owner Of Well Heat Plant Type Of Well N/A Depth Drilled 175 '

Completion Date N/A Longitude -87.82679 Latitude 42.44535 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209737424 MAP ID Banks ID 1709700039 5 Owner Of Well Tom C. Hanson Type Of Well N/A Depth Drilled 180 '

Completion Date N/A Longitude -87.80674 Latitude 42.45072 State ID 1209726844 MAP ID Banks ID 1709700040 6 Owner Of Well City of Zion Type Of Well N/A Depth Drilled 15 '

Completion Date 11/1/1972 Longitude -87.81565 Latitude 42.44982 State ID 1209702319 MAP ID Banks ID 1709700041 7 Owner Of Well F.H. Ferguson Type Of Well N/A Depth Drilled 154 '

Completion Date N/A Longitude -87.82311 Latitude 42.44623 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209702320 MAP ID Banks ID 1709700042 8 Owner Of Well Hotel Zion Home Type Of Well N/A Depth Drilled 225 '

Completion Date N/A Longitude -87.8231 Latitude 42.44804 State ID 1209702926 MAP ID Banks ID 1709700043 9 Owner Of Well Alvin Justin Type Of Well N/A Depth Drilled 120 '

Completion Date 8/7/1969 Longitude -87.80287 Latitude 42.45683 State ID 1209703060 MAP ID Banks ID 1709700044 9 Owner Of Well Harry G. Spencer Type Of Well N/A Depth Drilled 142 '

Completion Date 11/20/1970 Longitude -87.80156 Latitude 42.45683 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209702322 MAP ID Banks ID 1709700045 10 Owner Of Well Zion Estates Type Of Well N/A Depth Drilled 138 '

Completion Date N/A Longitude -87.80146 Latitude 42.44612 State ID 1209702292 MAP ID Banks ID 1709700065 11 Owner Of Well Clude Koontr Type Of Well N/A Depth Drilled 266 '

Completion Date 9/1/1940 Longitude -87.83029 Latitude 42.46073 State ID 1209725154 MAP ID Banks ID 1709700070 12 Owner Of Well Busch & Larson Type Of Well N/A Depth Drilled 219 '

Completion Date 1/1/1976 Longitude -87.82809 Latitude 42.46127 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209725155 MAP ID Banks ID 1709700071 12 Owner Of Well Busch & Larson Type Of Well N/A Depth Drilled 195 '

Completion Date 1/24/1977 Longitude -87.82865 Latitude 42.46128 State ID 1209733751 MAP ID Banks ID 1709700088 12 Owner Of Well Don Falstad Type Of Well N/A Depth Drilled 160 '

Completion Date 9/30/1977 Longitude -87.8285 Latitude 42.46182 State ID 1209703280 MAP ID Banks ID 1709700075 13 Owner Of Well Paul Richardson Type Of Well N/A Depth Drilled 322 '

Completion Date 7/1/1971 Longitude -87.82885 Latitude 42.45895 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209702617 MAP ID Banks ID 1709700066 14 Owner Of Well C. Edwards Type Of Well N/A Depth Drilled 146 '

Completion Date 1/1/1963 Longitude -87.82662 Latitude 42.46526 State ID 1209702618 MAP ID Banks ID 1709700067 14 Owner Of Well C. Edwards Type Of Well N/A Depth Drilled 160 '

Completion Date 1/1/1963 Longitude -87.82662 Latitude 42.46526 State ID 1209702619 MAP ID Banks ID 1709700068 14 Owner Of Well H. Jorgenson Type Of Well N/A Depth Drilled 137 '

Completion Date 1/1/1963 Longitude -87.82666 Latitude 42.46526 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209702798 MAP ID Banks ID 1709700069 14 Owner Of Well A.R. Casteel Type Of Well N/A Depth Drilled 315 '

Completion Date 5/1/1968 Longitude -87.82527 Latitude 42.46472 State ID 1209703883 MAP ID Banks ID 1709700074 14 Owner Of Well O'Neal Humphries Type Of Well N/A Depth Drilled 127 '

Completion Date 10/27/1972 Longitude -87.82666 Latitude 42.46526 State ID 1209703399 MAP ID Banks ID 1709700076 14 Owner Of Well Jerry Moyer Type Of Well N/A Depth Drilled 242 '

Completion Date 10/1/1971 Longitude -87.8256 Latitude 42.46414 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209724153 MAP ID Banks ID 1709700077 15 Owner Of Well Si Henarichs Agency Type Of Well N/A Depth Drilled 138 '

Completion Date 11/12/1973 Longitude -87.82705 Latitude 42.4684 State ID 1209726697 MAP ID Banks ID 1709700080 16 Owner Of Well Bruce Griffith Type Of Well N/A Depth Drilled 145 '

Completion Date 9/21/1978 Longitude -87.82715 Latitude 42.46295 State ID 1209726818 MAP ID Banks ID 1709700081 17 Owner Of Well Clayton Watts Type Of Well N/A Depth Drilled 274 '

Completion Date 12/1/1977 Longitude -87.82908 Latitude 42.46408 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209725157 MAP ID Banks ID 1709700073 18 Owner Of Well Howard Freemark Type Of Well N/A Depth Drilled 190 '

Completion Date 12/1/1976 Longitude -87.82668 Latitude 42.46256 State ID 1209727962 MAP ID Banks ID 1709700084 18 Owner Of Well William Blagg, Jr.

Type Of Well N/A Depth Drilled 168 '

Completion Date 2/14/1986 Longitude -87.82664 Latitude 42.46163 State ID 1209733750 MAP ID Banks ID 1709700087 19 Owner Of Well Veterans Administration 265 Type Of Well N/A Depth Drilled 150 '

Completion Date 12/8/1983 Longitude -87.82514 Latitude 42.46636 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209702287 MAP ID Banks ID 1709700090 20 Owner Of Well William Nacker Type Of Well N/A Depth Drilled 119 '

Completion Date 1/1/1940 Longitude -87.82231 Latitude 42.46317 State ID 1209727833 MAP ID Banks ID 1709700108 20 Owner Of Well Tim Hough Type Of Well N/A Depth Drilled 55 '

Completion Date 11/30/1985 Longitude -87.82114 Latitude 42.46289 State ID 1209702288 MAP ID Banks ID 1709700091 21 Owner Of Well Camp Logan Type Of Well N/A Depth Drilled 110 '

Completion Date 1/1/1941 Longitude -87.80954 Latitude 42.46519 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209702615 MAP ID Banks ID 1709700094 22 Owner Of Well Homer McNabb Type Of Well N/A Depth Drilled 66 '

Completion Date 1/1/1963 Longitude -87.82425 Latitude 42.46162 State ID 1209702796 MAP ID Banks ID 1709700096 23 Owner Of Well William Walters Type Of Well N/A Depth Drilled 160 '

Completion Date 8/11/1968 Longitude -87.81839 Latitude 42.46853 State ID 1209702797 MAP ID Banks ID 1709700097 24 Owner Of Well Jim Middleton Type Of Well N/A Depth Drilled 80 '

Completion Date 4/5/1968 Longitude -87.81566 Latitude 42.46434 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209725066 MAP ID Banks ID 1709700098 25 Owner Of Well Craig Anderson Type Of Well N/A Depth Drilled 127 '

Completion Date 11/18/1976 Longitude -87.8169 Latitude 42.46845 State ID 1209702614 MAP ID Banks ID 1709700093 26 Owner Of Well James Fout Type Of Well N/A Depth Drilled 130 '

Completion Date 1/1/1963 Longitude -87.81682 Latitude 42.47065 State ID 1209703882 MAP ID Banks ID 1709700101 26 Owner Of Well Pitcher Construction Co.

Type Of Well N/A Depth Drilled 138 '

Completion Date 4/3/1973 Longitude -87.81686 Latitude 42.47065 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209703416 MAP ID Banks ID 1709700104 26 Owner Of Well Billy Holland Type Of Well N/A Depth Drilled 141 '

Completion Date 11/1/1971 Longitude -87.81811 Latitude 42.46991 State ID 1209724152 MAP ID Banks ID 1709700105 27 Owner Of Well Sihendrick Agency Type Of Well N/A Depth Drilled 266 '

Completion Date 1/1/1974 Longitude -87.82027 Latitude 42.4628 State ID 1209702616 MAP ID Banks ID 1709700095 28 Owner Of Well Harold McNabb Type Of Well N/A Depth Drilled 177 '

Completion Date 1/1/1963 Longitude -87.81929 Latitude 42.46341 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209703881 MAP ID Banks ID 1709700100 28 Owner Of Well Ray Neal Type Of Well N/A Depth Drilled 134 '

Completion Date 6/2/1972 Longitude -87.81807 Latitude 42.46249 State ID 1209703921 MAP ID Banks ID 1709700102 28 Owner Of Well Steve Markabrad Type Of Well N/A Depth Drilled 143 '

Completion Date 5/1/1973 Longitude -87.8179 Latitude 42.46237 State ID 1209724846 MAP ID Banks ID 1709700106 28 Owner Of Well Busch & Larson Type Of Well N/A Depth Drilled 199 '

Completion Date 6/12/1976 Longitude -87.81931 Latitude 42.46291 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209724252 MAP ID Banks ID 1709700107 29 Owner Of Well Albert Klemin Type Of Well N/A Depth Drilled 167 '

Completion Date 7/1/1974 Longitude -87.82197 Latitude 42.45803 State ID 1209729270 MAP ID Banks ID 1709700109 30 Owner Of Well Ron Conde Type Of Well N/A Depth Drilled 46 '

Completion Date 3/3/1987 Longitude -87.81524 Latitude 42.46257 State ID 1209728125 MAP ID Banks ID 1709700110 31 Owner Of Well Stacy Dickerson Type Of Well N/A Depth Drilled 136 '

Completion Date 5/15/1986 Longitude -87.81318 Latitude 42.45892 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209703077 MAP ID Banks ID 1709700092 32 Owner Of Well C.N. Clark Type Of Well N/A Depth Drilled 77 '

Completion Date 1/1/1971 Longitude -87.81844 Latitude 42.46637 State ID 1209724431 MAP ID Banks ID 1709700099 32 Owner Of Well R. Conde Type Of Well N/A Depth Drilled 61 '

Completion Date 4/1/1975 Longitude -87.82049 Latitude 42.46625 State ID 1209703357 MAP ID Banks ID 1709700103 32 Owner Of Well Glen Martin Type Of Well N/A Depth Drilled 147 '

Completion Date 9/1/1971 Longitude -87.81933 Latitude 42.46704 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209731926 MAP ID Banks ID 1709700111 32 Owner Of Well Ron Conde Type Of Well N/A Depth Drilled 56 '

Completion Date 2/10/1989 Longitude -87.81932 Latitude 42.46703 State ID 1209733748 MAP ID Banks ID 1709700113 32 Owner Of Well Jim Fout Type Of Well N/A Depth Drilled 49 '

Completion Date 5/24/1979 Longitude -87.81943 Latitude 42.46661 State ID 1209733747 MAP ID Banks ID 1709700112 33 Owner Of Well Mary Barclay Type Of Well N/A Depth Drilled 89 '

Completion Date 4/2/1979 Longitude -87.82261 Latitude 42.46762 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209733749 MAP ID Banks ID 1709700114 34 Owner Of Well Glen Martin Type Of Well N/A Depth Drilled 116 '

Completion Date 4/5/1977 Longitude -87.82049 Latitude 42.46935 State ID 1209702911 MAP ID Banks ID 1709700115 35 Owner Of Well Grace Sills Type Of Well N/A Depth Drilled 123 '

Completion Date 7/3/1969 Longitude -87.80023 Latitude 42.46109 State ID 1209702795 MAP ID Banks ID 1709700117 35 Owner Of Well William Jenko Type Of Well N/A Depth Drilled 180 '

Completion Date 11/15/1968 Longitude -87.80139 Latitude 42.46192 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209702993 MAP ID Banks ID 1709700116 36 Owner Of Well Rudy Copen Type Of Well N/A Depth Drilled 125 '

Completion Date 11/21/1969 Longitude -87.80208 Latitude 42.4589 State ID 1209733746 MAP ID Banks ID 1709700118 37 Owner Of Well Progressive Builders Type Of Well N/A Depth Drilled 104 '

Completion Date 9/27/1979 Longitude -87.80505 Latitude 42.46026 State ID 1209702454 MAP ID Banks ID 1709700123 38 Owner Of Well E.C. Buese Type Of Well N/A Depth Drilled 225 '

Completion Date 2/1/1968 Longitude -87.83155 Latitude 42.43991 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209702802 MAP ID Banks ID 1709700128 39 Owner Of Well James Barnes Type Of Well N/A Depth Drilled 147 '

Completion Date 11/1/1968 Longitude -87.8288 Latitude 42.43442 State ID 1209733862 MAP ID Banks ID 1709700191 39 Owner Of Well Don Miesner Type Of Well N/A Depth Drilled 156 '

Completion Date 10/5/1979 Longitude -87.82881 Latitude 42.43518 State ID 1209702803 MAP ID Banks ID 1709700129 40 Owner Of Well Mrs. Michael Lester Type Of Well N/A Depth Drilled 146 '

Completion Date 12/1/1968 Longitude -87.82673 Latitude 42.43017 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209733861 MAP ID Banks ID 1709700190 40 Owner Of Well Jim Middleton Type Of Well N/A Depth Drilled 195 '

Completion Date 5/25/1979 Longitude -87.82585 Latitude 42.42971 State ID 1209735998 MAP ID Banks ID 1709700209 40 Owner Of Well J & E Builders Type Of Well N/A Depth Drilled 160 '

Completion Date 8/9/1990 Longitude -87.82687 Latitude 42.43084 State ID 1209736004 MAP ID Banks ID 1709700215 40 Owner Of Well Victor Smith Type Of Well N/A Depth Drilled 163 '

Completion Date 4/12/1989 Longitude -87.82687 Latitude 42.43084 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209736295 MAP ID Banks ID 1709700218 40 Owner Of Well Vivian Edwards Type Of Well N/A Depth Drilled 187 '

Completion Date 7/19/1991 Longitude -87.82687 Latitude 42.43084 State ID 1209725067 MAP ID Banks ID 1709700130 41 Owner Of Well Busch & Larson Type Of Well N/A Depth Drilled 198 '

Completion Date 11/1/1976 Longitude -87.83021 Latitude 42.43512 State ID 1209724432 MAP ID Banks ID 1709700131 42 Owner Of Well H. Khayat Type Of Well N/A Depth Drilled 220 '

Completion Date 12/5/1975 Longitude -87.82669 Latitude 42.42893 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209738419 MAP ID Banks ID 1709700231 42 Owner Of Well Robert May Type Of Well N/A Depth Drilled 165 '

Completion Date 7/20/1994 Longitude -87.82684 Latitude 42.42902 State ID 1209737098 MAP ID Banks ID 1709700237 42 Owner Of Well Scott Walldan Type Of Well N/A Depth Drilled 159 '

Completion Date 8/10/1992 Longitude -87.82689 Latitude 42.42902 State ID 1209745167 MAP ID Banks ID 1709700240 42 Owner Of Well Extra Value Liquors Type Of Well Public Supply Depth Drilled 0' Completion Date N/A Longitude -87.82689 Latitude 42.42902 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209745166 MAP ID Banks ID 1709700241 42 Owner Of Well Al's Tap Type Of Well Public Supply Depth Drilled 0' Completion Date N/A Longitude -87.82684 Latitude 42.42902 State ID 1209725159 MAP ID Banks ID 1709700133 43 Owner Of Well Parker Peterson Type Of Well N/A Depth Drilled 152 '

Completion Date 2/1/1977 Longitude -87.8312 Latitude 42.43315 State ID 1209703079 MAP ID Banks ID 1709700138 43 Owner Of Well Charles Lotz Type Of Well N/A Depth Drilled 165 '

Completion Date 1/1/1971 Longitude -87.83117 Latitude 42.4338 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209703281 MAP ID Banks ID 1709700144 43 Owner Of Well Charles T. Mason Type Of Well N/A Depth Drilled 65 '

Completion Date 5/1/1971 Longitude -87.83129 Latitude 42.43237 State ID 1209702623 MAP ID Banks ID 1709700125 44 Owner Of Well J. Fortner Type Of Well N/A Depth Drilled 185 '

Completion Date 1/1/1963 Longitude -87.83171 Latitude 42.4345 State ID 1209724711 MAP ID Banks ID 1709700146 44 Owner Of Well Hamms Concrete Type Of Well N/A Depth Drilled 232 '

Completion Date 10/1/1974 Longitude -87.83257 Latitude 42.43445 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209729070 MAP ID Banks ID 1709700164 44 Owner Of Well Victor Smith Type Of Well N/A Depth Drilled 215 '

Completion Date 2/9/1987 Longitude -87.83166 Latitude 42.43476 State ID 1209738345 MAP ID Banks ID 1709700227 44 Owner Of Well Gary Reinhardt Type Of Well N/A Depth Drilled 190 '

Completion Date 7/6/1994 Longitude -87.83167 Latitude 42.4345 State ID 1209737096 MAP ID Banks ID 1709700235 44 Owner Of Well Sheila Fetherline Type Of Well N/A Depth Drilled 269 '

Completion Date 6/25/1992 Longitude -87.83171 Latitude 42.4345 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209702625 MAP ID Banks ID 1709700127 45 Owner Of Well Mike Paslowsky Type Of Well N/A Depth Drilled 176 '

Completion Date 1/1/1963 Longitude -87.8317 Latitude 42.42905 State ID 1209727858 MAP ID Banks ID 1709700168 45 Owner Of Well Helen Khayat Type Of Well N/A Depth Drilled 174 '

Completion Date 3/13/1986 Longitude -87.8309 Latitude 42.42959 State ID 1209737741 MAP ID Banks ID 1709700229 45 Owner Of Well Bruce & Chris Galgan Type Of Well N/A Depth Drilled 180 '

Completion Date 8/5/1993 Longitude -87.8317 Latitude 42.42905 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209701450 MAP ID Banks ID 1709700119 46 Owner Of Well Lotz Construction Type Of Well N/A Depth Drilled 144 '

Completion Date 6/1/1970 Longitude -87.82746 Latitude 42.43267 State ID 1209729422 MAP ID Banks ID 1709700172 46 Owner Of Well Mike Dugan Type Of Well N/A Depth Drilled 150 '

Completion Date 6/16/1987 Longitude -87.82807 Latitude 42.43361 State ID 1209733854 MAP ID Banks ID 1709700183 46 Owner Of Well David Ernstmeyer Type Of Well N/A Depth Drilled 142 '

Completion Date 8/12/1980 Longitude -87.82882 Latitude 42.43302 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209735994 MAP ID Banks ID 1709700205 46 Owner Of Well C & S Builders Type Of Well N/A Depth Drilled 157 '

Completion Date 1/10/1991 Longitude -87.82925 Latitude 42.43267 State ID 1209735996 MAP ID Banks ID 1709700207 46 Owner Of Well Stacy Dickerson Type Of Well N/A Depth Drilled 43 '

Completion Date 9/20/1990 Longitude -87.82929 Latitude 42.43267 State ID 1209736294 MAP ID Banks ID 1709700217 46 Owner Of Well Perry Dalke Type Of Well N/A Depth Drilled 180 '

Completion Date 6/1/1991 Longitude -87.82685 Latitude 42.43447 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209728546 MAP ID Banks ID 1709700153 47 Owner Of Well Robert Middleton Type Of Well N/A Depth Drilled 225 '

Completion Date 10/7/1986 Longitude -87.83052 Latitude 42.43177 State ID 1209730365 MAP ID Banks ID 1709700165 47 Owner Of Well Gary Post Type Of Well N/A Depth Drilled 153 '

Completion Date 4/25/1988 Longitude -87.83052 Latitude 42.43172 State ID 1209733858 MAP ID Banks ID 1709700187 47 Owner Of Well R.L. Humphres Type Of Well N/A Depth Drilled 155 '

Completion Date 6/28/1976 Longitude -87.83052 Latitude 42.43177 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209733860 MAP ID Banks ID 1709700189 47 Owner Of Well Carl Michelsen Type Of Well N/A Depth Drilled 170 '

Completion Date 11/15/1980 Longitude -87.83052 Latitude 42.43177 State ID 1209733865 MAP ID Banks ID 1709700194 47 Owner Of Well Pitcher Construction Type Of Well N/A Depth Drilled 166 '

Completion Date 2/24/1975 Longitude -87.83052 Latitude 42.43177 State ID 1209733866 MAP ID Banks ID 1709700195 47 Owner Of Well Pitcher Construction Type Of Well N/A Depth Drilled 166 '

Completion Date 6/16/1975 Longitude -87.83052 Latitude 42.43177 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209733867 MAP ID Banks ID 1709700196 47 Owner Of Well Pitcher Construction Co.

Type Of Well N/A Depth Drilled 169 '

Completion Date 10/11/1976 Longitude -87.83047 Latitude 42.43177 State ID 1209736002 MAP ID Banks ID 1709700213 47 Owner Of Well Lucy's Appliances Type Of Well N/A Depth Drilled 155 '

Completion Date 11/9/1990 Longitude -87.83052 Latitude 42.43177 State ID 1209736005 MAP ID Banks ID 1709700216 47 Owner Of Well Victor L. Smith Type Of Well N/A Depth Drilled 166 '

Completion Date 9/28/1990 Longitude -87.83052 Latitude 42.43177 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209738700 MAP ID Banks ID 1709700199 48 Owner Of Well Thersa Wilbanks Type Of Well N/A Depth Drilled 180 '

Completion Date 9/15/1983 Longitude -87.83476 Latitude 42.43919 State ID 1209724485 MAP ID Banks ID 1709700135 49 Owner Of Well Bill Nikkila Type Of Well N/A Depth Drilled 186 '

Completion Date 8/1/1975 Longitude -87.82916 Latitude 42.42895 State ID 1209724592 MAP ID Banks ID 1709700139 49 Owner Of Well Herbert Wubbell Type Of Well N/A Depth Drilled 173 '

Completion Date 9/1/1975 Longitude -87.8286 Latitude 42.42854 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209703922 MAP ID Banks ID 1709700143 49 Owner Of Well Robert Ernstmeyer Type Of Well N/A Depth Drilled 176 '

Completion Date 5/1/1973 Longitude -87.82939 Latitude 42.42882 State ID 1209727421 MAP ID Banks ID 1709700156 49 Owner Of Well Ken Kruse Type Of Well N/A Depth Drilled 175 '

Completion Date 7/31/1985 Longitude -87.82932 Latitude 42.42904 State ID 1209727949 MAP ID Banks ID 1709700171 49 Owner Of Well Brooks Builders Type Of Well N/A Depth Drilled 194 '

Completion Date 4/1/1986 Longitude -87.83044 Latitude 42.42855 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209735999 MAP ID Banks ID 1709700210 49 Owner Of Well Helena Khavat Type Of Well N/A Depth Drilled 168 '

Completion Date 4/27/1990 Longitude -87.82932 Latitude 42.42904 State ID 1209736000 MAP ID Banks ID 1709700211 49 Owner Of Well Helena Khavat Type Of Well N/A Depth Drilled 200 '

Completion Date 3/22/1990 Longitude -87.82932 Latitude 42.42904 State ID 1209736001 MAP ID Banks ID 1709700212 49 Owner Of Well Helena Khavat Type Of Well N/A Depth Drilled 156 '

Completion Date 10/27/1989 Longitude -87.82932 Latitude 42.42904 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209726713 MAP ID Banks ID 1709700163 50 Owner Of Well Bo Rea Type Of Well N/A Depth Drilled 160 '

Completion Date 8/1/1978 Longitude -87.83395 Latitude 42.4346 State ID 1209737885 MAP ID Banks ID 1709700221 50 Owner Of Well Reggie Mosley Type Of Well N/A Depth Drilled 175 '

Completion Date 10/15/1993 Longitude -87.83414 Latitude 42.43451 State ID 1209738706 MAP ID Banks ID 1709700223 50 Owner Of Well Ram Builders Type Of Well N/A Depth Drilled 182 '

Completion Date 1/23/1995 Longitude -87.83414 Latitude 42.43451 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209737740 MAP ID Banks ID 1709700228 50 Owner Of Well Helen Binning Type Of Well N/A Depth Drilled 170 '

Completion Date 7/2/1993 Longitude -87.83414 Latitude 42.43451 State ID 1209725218 MAP ID Banks ID 1709700136 51 Owner Of Well Lester Carman Type Of Well N/A Depth Drilled 167 '

Completion Date 4/1/1977 Longitude -87.83146 Latitude 42.43024 State ID 1209727931 MAP ID Banks ID 1709700170 51 Owner Of Well Eija Tuovinen Type Of Well N/A Depth Drilled 222 '

Completion Date 2/10/1986 Longitude -87.83268 Latitude 42.43069 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209736482 MAP ID Banks ID 1709700220 51 Owner Of Well Helen Binning Type Of Well N/A Depth Drilled 172 '

Completion Date 12/17/1991 Longitude -87.83169 Latitude 42.43087 State ID 1209737425 MAP ID Banks ID 1709700224 51 Owner Of Well Carol Donev Type Of Well N/A Depth Drilled 170 '

Completion Date 10/2/1992 Longitude -87.83174 Latitude 42.43087 State ID 1209703010 MAP ID Banks ID 1709700120 52 Owner Of Well D. Spiegelberg Type Of Well N/A Depth Drilled 190 '

Completion Date 10/1/1969 Longitude -87.83313 Latitude 42.43376 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209729906 MAP ID Banks ID 1709700157 52 Owner Of Well Victor Smith Type Of Well N/A Depth Drilled 169 '

Completion Date 8/17/1987 Longitude -87.83289 Latitude 42.4336 State ID 1209727465 MAP ID Banks ID 1709700158 52 Owner Of Well Tobey Delaney Type Of Well N/A Depth Drilled 164 '

Completion Date 7/20/1985 Longitude -87.83263 Latitude 42.43251 State ID 1209730397 MAP ID Banks ID 1709700166 52 Owner Of Well James Wolden Type Of Well N/A Depth Drilled 196 '

Completion Date 11/11/1987 Longitude -87.83172 Latitude 42.43269 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209733855 MAP ID Banks ID 1709700184 52 Owner Of Well Warren Esperson Type Of Well N/A Depth Drilled 55 '

Completion Date 12/23/1982 Longitude -87.83215 Latitude 42.43253 State ID 1209738624 MAP ID Banks ID 1709700222 52 Owner Of Well Ram Builders Type Of Well N/A Depth Drilled 172 '

Completion Date 9/20/1994 Longitude -87.83289 Latitude 42.4336 State ID 1209738151 MAP ID Banks ID 1709700225 52 Owner Of Well Ram Builders Type Of Well N/A Depth Drilled 170 '

Completion Date 3/14/1994 Longitude -87.83293 Latitude 42.43365 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209737095 MAP ID Banks ID 1709700234 52 Owner Of Well Joe Buttera Type Of Well N/A Depth Drilled 192 '

Completion Date 5/31/1992 Longitude -87.83168 Latitude 42.43269 State ID 1209724992 MAP ID Banks ID 1709700150 53 Owner Of Well English Construction Type Of Well N/A Depth Drilled 184 '

Completion Date 11/1/1976 Longitude -87.82938 Latitude 42.4302 State ID 1209724993 MAP ID Banks ID 1709700151 53 Owner Of Well Smythe Construction Type Of Well N/A Depth Drilled 165 '

Completion Date 9/1/1976 Longitude -87.82827 Latitude 42.42977 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209727349 MAP ID Banks ID 1709700155 53 Owner Of Well James Wolden Type Of Well N/A Depth Drilled 200 '

Completion Date 7/11/1985 Longitude -87.82926 Latitude 42.43085 State ID 1209726711 MAP ID Banks ID 1709700161 53 Owner Of Well Lester Carman Type Of Well N/A Depth Drilled 200 '

Completion Date 9/1/1978 Longitude -87.8295 Latitude 42.43036 State ID 1209726821 MAP ID Banks ID 1709700167 53 Owner Of Well Busch & Larson Type Of Well N/A Depth Drilled 198 '

Completion Date 3/1/1979 Longitude -87.83034 Latitude 42.43108 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209727174 MAP ID Banks ID 1709700175 53 Owner Of Well Al Larson Type Of Well N/A Depth Drilled 220 '

Completion Date 3/11/1985 Longitude -87.83025 Latitude 42.43002 State ID 1209733851 MAP ID Banks ID 1709700180 53 Owner Of Well Busch & Larson Type Of Well N/A Depth Drilled 198 '

Completion Date 3/2/1979 Longitude -87.82992 Latitude 42.4311 State ID 1209737097 MAP ID Banks ID 1709700236 53 Owner Of Well David Johnson Type Of Well N/A Depth Drilled 168 '

Completion Date 6/10/1992 Longitude -87.82926 Latitude 42.43085 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209727293 MAP ID Banks ID 1709700239 53 Owner Of Well Larry Patrone Type Of Well N/A Depth Drilled 175 '

Completion Date 2/19/1990 Longitude -87.82926 Latitude 42.43085 State ID 1209747796 MAP ID Banks ID 1709700246 54 Owner Of Well IL Beach Park/Concession Type Of Well N/A Depth Drilled 8' Completion Date 7/18/2002 Longitude -87.80718 Latitude 42.43252 State ID 1209747797 MAP ID Banks ID 1709700247 54 Owner Of Well IL Beack Park/Concession Type Of Well N/A Depth Drilled 15 '

Completion Date 7/18/2002 Longitude -87.80718 Latitude 42.43252 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209747800 MAP ID Banks ID 1709700249 54 Owner Of Well IL Beack Park/Concession Type Of Well N/A Depth Drilled 8' Completion Date 7/18/2002 Longitude -87.80724 Latitude 42.43251 State ID 1209747799 MAP ID Banks ID 1709700248 55 Owner Of Well IL Beach Park/Concession Type Of Well N/A Depth Drilled 15 '

Completion Date 7/18/2002 Longitude -87.80658 Latitude 42.43023 State ID 1209747798 MAP ID Banks ID 1709700251 55 Owner Of Well IL Beach Park/Concession Type Of Well N/A Depth Drilled 15 '

Completion Date 7/18/2002 Longitude -87.80658 Latitude 42.43023 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209702324 MAP ID Banks ID 1709700252 56 Owner Of Well F.H. Ferguson Type Of Well N/A Depth Drilled 149 '

Completion Date N/A Longitude -87.82192 Latitude 42.43807 State ID 1209702325 MAP ID Banks ID 1709700253 57 Owner Of Well Geo Shaw Type Of Well N/A Depth Drilled 156 '

Completion Date N/A Longitude -87.82438 Latitude 42.43077 State ID 1209702321 MAP ID Banks ID 1709700254 58 Owner Of Well Beach State Park Type Of Well N/A Depth Drilled 510 '

Completion Date N/A Longitude -87.80473 Latitude 42.43066 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.

Banks '

Water Well Report Information Solutions, Inc. DETAILS State ID 1209747795 MAP ID Banks ID 1709700255 59 Owner Of Well IL Beach Park/Concession Type Of Well N/A Depth Drilled 8' Completion Date 7/18/2002 Longitude -87.80472 Latitude 42.43249 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.

Banks '

Water Well Report Information Solutions, Inc.

SUMMARY

Water Well Report 'Research Mapping Protocol The 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.

Texas 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 Quality 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 Quality. 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 possibly 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.

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Revision 0 A.2 ISWS LOGS 045136 (22) Zion Station

Revision 1 APPENDIX B BORING LOGS B.1 2006 STRATIGRAPHIC AND INSTRUMENTATION LOGS B.2 HISTORICAL GEOTECHNICAL LOGS 045136 (22) Zion Station

Revision 1 B.1 2006 STRATIGRAPHIC AND INSTRUMENTATION LOGS 045136 (22) Zion Station

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 1 of 2 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: MW-ZN-01S PROJECT NUMBER: 45136-30 DATE COMPLETED: May 1, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Vacuum/HSA LOCATION: ZION, ILLINOIS FIELD PERSONNEL: D. NICHOLLS ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS NUMBER INTERVAL 'N' VALUE AMSL REC (%)

4" 0/ above TOP OF RISER 594.10 ground GROUND SURFACE 591.43 protective casing GRAVEL 591.33 SAND (FILL) - trace to some gravel, trace Concrete 2 organics, fine to medium grained, brown, moist 4

6 2" 0/ PVC Well Riser 8

Bentonite 10 581.43 Seal SP-SAND, trace to some gravel, loose to compact, wet, fine to medium grained, brown 1 0 10 12 4.25" 0/ 2 55 16 Borehole 14 3 80 15 16 574.43 4 80 19 SM-SAND, with trace to some silt, trace 18 gravel, compact, fine grained, brown, wet 5 65 29 20 22

- dense to very dense at 23.0ft BGS 6 95 44 24 567.43 SP-SAND, trace to some silt, compact to dense, fine grained, brown, wet 2" 0/ PVC 7 95 62 Well Screen 26 8 90 21

- getting coarser and grey for next 6" at 27.5ft 28 BGS Sand 9 90 44 562.18 OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 ML-SILT, dense, fine grained, grey, wet 30 10 100 25 32 11 75 28 34 12 0 29 36 13 70 50 38 552.43 CL-CLAY, till (clay, trace to some silt, trace 551.93 NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 2 of 2 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: MW-ZN-01S PROJECT NUMBER: 45136-30 DATE COMPLETED: May 1, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Vacuum/HSA LOCATION: ZION, ILLINOIS FIELD PERSONNEL: D. NICHOLLS ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS NUMBER INTERVAL 'N' VALUE AMSL REC (%)

gravel), dense, grey, gravel, very well WELL DETAILS embedded in finer matrix, dry, till Screened interval:

42 END OF BOREHOLE @ 39.5ft BGS 572.43 to 551.93ft AMSL 19.00 to 39.50ft BGS Length: 20.5ft 44 Diameter: 2in Slot Size: 10 Material: PVC 46 Sand Pack:

574.43 to 551.93ft AMSL 17.00 to 39.50ft BGS 48 Material: #5 Quartz Sand 50 52 54 56 58 60 62 64 66 68 OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 70 72 74 76 78 NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 1 of 2 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: MW-ZN-02S PROJECT NUMBER: 45136-30 DATE COMPLETED: May 2, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Vacuum/HSA LOCATION: ZION, ILLINOIS FIELD PERSONNEL: D. NICHOLLS ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS NUMBER INTERVAL 'N' VALUE AMSL REC (%)

4" 0/ above TOP OF RISER 593.78 ground GROUND SURFACE 591.21 protective casing GRAVEL & GRASS 591.11 SAND with GRAVEL (FILL), presence of Concrete 2 organics (trace), fine grained, brown, moist Bentonite and 4 Cuttings 6

2" 0/ PVC Well Riser 8

Bentonite Seal 10 581.21 SAND (FILL), trace to with silt, trace gravel, very loose to compact, fine grained, brown, 1 15 8 moist 12 4.25" 0/ 2 15 4

- trace organics, piece of wood, black (1cm x Borehole 14 1cm) at 13.5ft BGS

- getting wet at 14.0ft BGS 3 30 --

16 4 30 18 18 5 30 19 20 571.21 CL-SILTY CLAY TILL (silty clay, trace sand, 570.96 trace gravel), fine grained, brownish-grey, wet 6 30 5 22 SM-SILT & SAND, trace clay, trace gravel, 2" 0/ PVC very loose, fine grained, brown, wet, clay till Well Screen lenses observed within sandy material between 0.5" to 4" in thickness 24 Sand 7 40 6 26 8 95 20 28 9 50 9 OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 30 10 30 4 32 11 50 17 34 556.21 12 40 19 SW-SAND, medium to coarse grained, trace 555.71 36 silt, compact, wet 555.21 CL-CLAY TILL (clay, trace to with silt, trace 13 10 64 gravel, trace sand), compact, grey, moist, 38 coarse material well embedded in fine matrix Bentonite SILT & SAND, trace clay, trace gravel, very 14 25 2 loose to loose, brown, wet, 1" to 3" thick lenses NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 2 of 2 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: MW-ZN-02S PROJECT NUMBER: 45136-30 DATE COMPLETED: May 2, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Vacuum/HSA LOCATION: ZION, ILLINOIS FIELD PERSONNEL: D. NICHOLLS ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS NUMBER INTERVAL 'N' VALUE AMSL REC (%)

of clay observed Bentonite 42 15 40 9 44 16 40 12 545.71 46 END OF BOREHOLE @ 45.5ft BGS WELL DETAILS Screened interval:

576.21 to 556.21ft AMSL 48 15.00 to 35.00ft BGS Length: 20ft Diameter: 2in 50 Slot Size: 10 Material: PVC Sand Pack:

52 577.91 to 556.21ft AMSL 13.30 to 35.00ft BGS Material: #5 Quartz Sand 54 56 58 60 62 64 66 68 OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 70 72 74 76 78 NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 1 of 2 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: MW-ZN-03S PROJECT NUMBER: 45136-30 DATE COMPLETED: May 2, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Vacuum/HSA LOCATION: ZION, ILLINOIS FIELD PERSONNEL: D. NICHOLLS ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS NUMBER INTERVAL 'N' VALUE AMSL REC (%)

4" 0/ above TOP OF RISER 594.02 ground GROUND SURFACE 591.54 protective casing GRAVEL 591.44 SAND (FILL), trace to with silt, trace to with Concrete 2 gravel, fine grained, brown, moist 4

Bentonite and 6 Cuttings 2" 0/ PVC Well Riser 8

10 581.54 SM-SAND WITH SILT, fine grained, trace gravel, compact, brown, moist 580.54 Bentonite 1 70 25 CL-SILTY CLAY TILL (silty clay, trace gravel, Seal 12 579.54 trace sand), compact, moist, grey ML-SILT & SAND, trace gravel, very loose to 2 50 9 14 loose, greyish brown, wet 4.25" 0/

Borehole 3 20 6 16 574.54 4 20 6 ML-SILT WITH SAND, trace clay, trace 18 gravel, fine grained, very loose, brownish-grey, wet, 0.5" to 2" clay lenses, with 5 20 4 silt, trace gravel, trace sand, very loose, wet, 20 brownish-grey 6 30 18 22 2" 0/ PVC Well Screen 7 15 35 24 Sand 8 10 1 26 9 15 7 28 10 5 1 OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 30 11 30 5 32 12 100 8 34 556.54 13 40 10 CL-CLAY TILL (clay, some silt, trace sand 36 and gravel), loose, grey, wet 555.54 END OF BOREHOLE @ 36.0ft BGS WELL DETAILS Screened interval:

38 576.29 to 555.54ft AMSL 15.25 to 36.00ft BGS Length: 20.75ft NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 2 of 2 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: MW-ZN-03S PROJECT NUMBER: 45136-30 DATE COMPLETED: May 2, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Vacuum/HSA LOCATION: ZION, ILLINOIS FIELD PERSONNEL: D. NICHOLLS ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS NUMBER INTERVAL 'N' VALUE AMSL REC (%)

Diameter: 2in Slot Size: 10 42 Material: PVC Sand Pack:

578.54 to 555.54ft AMSL 44 13.00 to 36.00ft BGS Material: #5 Quartz Sand 46 48 50 52 54 56 58 60 62 64 66 68 OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 70 72 74 76 78 NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 1 of 2 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: MW-ZN-04S PROJECT NUMBER: 45136-30 DATE COMPLETED: May 3, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Vacuum/HSA LOCATION: ZION, ILLINOIS FIELD PERSONNEL: D. NICHOLLS ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS NUMBER INTERVAL 'N' VALUE AMSL REC (%)

4" 0/ above TOP OF RISER 593.82 ground GROUND SURFACE 591.01 protective casing SAND & SILT (FILL), trace gravel, trace cobbles, fine grained, brown, dry Concrete 2

4 Bentonite and 6 Cuttings 2" 0/ PVC Well Riser 8 583.01 SM-SAND & SILT(FILL), trace clay, trace gravel, loose to compact, fine grained, brown, 1 40 1 moist 10

- 3" thick layer of silty clay till (silty clay, trace Bentonite 2 95 29 sand & gravel), compact grey, moist at 11.0ft Seal 12 BGS

- getting wet at 12.0ft BGS 3 70 18 14 - thick layer of sandy organic material, very 4.25" 0/

soft, black, wet (no odor presence of roots) Borehole at 13.8ft BGS 4 80 35 16 5 100 25 18 6 90 23 20 7 100 24 22

- 3" thick layer of silty clay till (silty clay, trace 8 55 29 sand & gravel), compact grey, moist at 23.0ft 24 BGS Sand

- getting softer (very soft), saturated at 24.0ft BGS 26 9 90 41 28 2" 0/ PVC Well Screen

- silt with sand, trace clay, compact, brown, 10 65 10 OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 wet at 29.0ft BGS 30

- 0.5" x 0.4" diagonal layer of dark grey to black organic material, very loose, fine 11 80 15 grained, wet at 30.0ft BGS 32 12 70 31 557.51 34 ML-SILT, trace to with sand, trace clay, loose, grey wet 13 100 20 36 555.21 CL-CLAY TILL (clay with silt, trace sand & 555.01 gravel), dense, grey, dry WELL DETAILS END OF BOREHOLE @ 36.0ft BGS Screened interval:

38 576.01 to 556.01ft AMSL 15.00 to 35.00ft BGS Length: 20ft NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 2 of 2 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: MW-ZN-04S PROJECT NUMBER: 45136-30 DATE COMPLETED: May 3, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Vacuum/HSA LOCATION: ZION, ILLINOIS FIELD PERSONNEL: D. NICHOLLS ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS NUMBER INTERVAL 'N' VALUE AMSL REC (%)

Diameter: 2in Slot Size: 10 42 Material: PVC Sand Pack:

578.01 to 556.01ft AMSL 44 13.00 to 35.00ft BGS Material: #5 Quartz Sand 46 48 50 52 54 56 58 60 62 64 66 68 OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 70 72 74 76 78 NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 1 of 1 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: MW-ZN-05S PROJECT NUMBER: 45136-30 DATE COMPLETED: May 4, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Vacuum/HSA LOCATION: ZION, ILLINOIS FIELD PERSONNEL: D. NICHOLLS ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS NUMBER INTERVAL 'N' VALUE PID (PPM)

AMSL REC (%)

4" 0/ above TOP OF RISER 588.64 ground GROUND SURFACE 585.72 protective casing SAND & SILT (FILL), trace gravel, fine grained, brown, dry Concrete 2

Bentonite and Cuttings 4 581.72 SM-SAND, trace to some silt, very soft, fine to medium grained, brown, wet 1 40 1 3.0 6 Bentonite Seal 578.92 2 70 29 4.5 GP-GRAVEL & SAND, trace silt, loose to 8 compact, medium to coarse grained, dark 577.72 brown, wet SM-SAND, trace silt, compact, fine to medium 2" 0/ PVC 3 70 18 11 Well Riser 10 grained, brown, wet, trace gravel

- finer, silt & sand, (4" thick layer, black) at 9.0ft BGS 4 60 35 10.2 12 - finer, silt & sand, (4" thick layer, black) at 11.5ft BGS 4.25" 0/ 5 65 25 9.8

- finer, silt & sand, (4" thick layer, black) at Borehole 14 13.0ft BGS

- silt, grey at 15.0ft BGS 6 60 23 11 16 7 70 24 9.8 18 566.72 Sand 8 80 29 10.1 SP-SAND, trace silt, medium to coarse 20 grained, brown to grey, wet 565.72 SM-SAND, trace silt, compact, fine to medium 9 75 41 10.3 grained, brown, wet, trace gravel 22 - finer, silt & sand at 21.5ft BGS 10 70 10 9.7 24 561.72 2" 0/ PVC CL-CLAY, trace silt, trace sand, trace of Well Screen brown to black organics, compact, wet 11 4.5 15 18 560.22 26 SP-SAND, medium to coarse grained, grey 559.72 compact, wet 558.72 12 80 41 10.1 SM-SAND, trace silt, compact, grey, fine 28 grained, wet ML-SILT, trace sand, compact, grey, fine 13 50 20 8.4 grained, moist OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 30 555.72 END OF BOREHOLE @ 30.0ft BGS WELL DETAILS Screened interval:

32 575.72 to 555.72ft AMSL 10.00 to 30.00ft BGS Length: 20ft 34 Diameter: 2in Slot Size: 10 Material: PVC 36 Sand Pack:

577.82 to 555.72ft AMSL 7.90 to 30.00ft BGS 38 Material: #5 Quartz Sand NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 1 of 1 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: MW-ZN-06S PROJECT NUMBER: 45136-30 DATE COMPLETED: May 5, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Vacuum/HSA LOCATION: ZION, ILLINOIS FIELD PERSONNEL: D. NICHOLLS ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS NUMBER INTERVAL 'N' VALUE PID (PPM)

AMSL REC (%)

4" 0/ above TOP OF RISER 592.66 ground GROUND SURFACE 589.78 protective casing SAND with SILT, trace gravel, brown, moist Concrete 2

Bentonite and Cuttings 4

Bentonite 6

8 2" 0/ PVC Well Riser 10 579.78 SM-SAND, some silt, soft, fine, grained, brown, wet 578.78 1 70 18 1.0 12 GM-SAND & GRAVEL, medium to coarse 577.78 grained, compact, grey, wet SM-SAND, some silt, soft, fine, grained, 576.78 4.25" 0/ 2 60 17 2.0 brown, wet Borehole 14 575.78 GM-SAND & GRAVEL, medium to coarse grained, compact, grey, wet 574.78 3 60 46 1.0 16 SM-SAND, some silt, soft, fine, grained, 573.78 brown, wet 4 40 40 1.0 GM-SAND & GRAVEL, medium to coarse 18 grained, compact, grey, wet ML-SILT, some sand, fine grained, greyish Sand 5 70 24 brown, trace gravel, compact to dense, wet 20 6 60 58 22 7 60 51 24 2" 0/ PVC Well Screen 564.78 8 60 51 GM-SAND & GRAVEL, trace silt, compact to 564.18 26 dense, brown, wet, coarser grained ML-SILT, trace sand, brown, dense, fine 9 50 37 grained, wet 28 560.78 10 70 40 CL-CLAY, (clay till, trace silt, trace sand &

OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 30 gravel), gravel well embedded in finer matrix, 559.78 very dense, grey, moist to dry WELL DETAILS END OF BOREHOLE @ 30.0ft BGS Screened interval:

32 579.78 to 559.78ft AMSL 10.00 to 30.00ft BGS Length: 20ft 34 Diameter: 2in Slot Size: 10 Material: PVC 36 Sand Pack:

581.53 to 559.78ft AMSL 8.25 to 30.00ft BGS 38 Material: #5 Quartz Sand NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 1 of 1 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: MW-ZN-07S PROJECT NUMBER: 45136-30 DATE COMPLETED: May 8, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Vacuum/HSA LOCATION: ZION, ILLINOIS FIELD PERSONNEL: D. NICHOLLS ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS NUMBER INTERVAL 'N' VALUE AMSL REC (%)

4" 0/ above TOP OF RISER 589.82 ground GROUND SURFACE 587.08 protective casing SAND with SILT, trace gravel, fine grained, brown, moist Concrete 2

Bentonite and Cuttings 4 583.08 SM-SAND WITH SILT, trace gravel, very loose, fine grained, brown, wet 1 40 0 6 581.08 Bentonite GM-GRAVELLY SAND, trace silt, loose to Seal compact, medium grained, brown, wet 2 50 16 8 579.08 SM-SAND, trace silt, trace to with gravel, fine to coarse grained, compact, brown, wet 2" 0/ PVC 3 40 25 Well Riser 10 - less gravel at 10.0ft BGS 4 50 50 575.58 12 GM-GRAVELLY SAND, trace silt, loose to compact, medium grained, brown, wet 4.25" 0/ 5 60 29 Borehole 14 6 50 56 16 571.28 ML-SILT & SAND, loose to compact, fine grained, brown, wet 570.08 7 50 43 SW-SAND, coarse grained, compact to 569.58 18 dense, brown, wet ML-SILT & SAND, trace gravel, dense, brown, Sand 8 70 35 fine grained, wet 20 9 50 19 22 565.28 ML-SILT, trace sand, compact, grey, wet, fine 565.08 grained 10 50 82 SM-SAND & SILT, compact, brown, wet, fine 563.58 24 grained 563.08 2" 0/ PVC Well Screen ML-SILT, trace sand, very dense, grey, wet 562.08 11 50 31 SM-SAND & SILT, compact, brown, wet, fine 26 grained 561.08 ML-SILT, trace sand, grey, wet, fine grained 560.08 12 80 28 28 SM-SAND & SILT, compact, brown, wet ML-SILT, trace sand, grey, wet, fine grained 13 0 50 OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 30 557.08 END OF BOREHOLE @ 30.0ft BGS WELL DETAILS Screened interval:

32 577.08 to 557.08ft AMSL 10.00 to 30.00ft BGS Length: 20ft 34 Diameter: 2in Slot Size: 10 Material: PVC 36 Sand Pack:

579.28 to 557.08ft AMSL 7.80 to 30.00ft BGS 38 Material: #5 Quartz Sand NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 1 of 1 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: MW-ZN-08S PROJECT NUMBER: 45136-30 DATE COMPLETED: May 5, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Vacuum/HSA LOCATION: ZION, ILLINOIS FIELD PERSONNEL: D. NICHOLLS ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS NUMBER INTERVAL 'N' VALUE PID (PPM)

AMSL REC (%)

4" 0/ above TOP OF RISER 588.73 ground GROUND SURFACE 585.85 protective casing SAND, trace silt, trace gravel, trace organics, fine grained, moist Concrete 2

Bentonite and Cuttings 4

Bentonite 6 579.85 Seal SM-SAND, trace silt, trace gravel, compact, fine to coarse grained, brown, wet 578.85 1 60 25 10.6 8 GP-GRAVEL, trace sand, medium to coarse 577.85 2" 0/ PVC grained, compact, brown, wet Well Riser ML-SILT, trace sand, loose to compact, fine 576.85 2 70 13 13.8 10 grained, brown, wet SM-SAND, trace gravel, medium to coarse grained, loose to compact, brown, wet 3 85 28 11.6 574.35 12 ML-SILT, trace fine sand, brown, compact to 573.85 dense, wet 4.25" 0/ 4 60 11 11.0 SM-SAND & SILT, fine to medium grained, Borehole 14 very loose to compact, brown, wet 5 80 33 9.1 570.35 16 ML-SILT, trace sand, compact to dense, fine 569.85 grained, brown, wet 6 70 19 9.7 SM-SAND, trace, silt, fine to coarse grained, 568.35 18 very loose to loose, brown, wet 567.85 ML-SILT, trace sand, compact, brownish-grey, Sand 566.85 7 60 13 10.4 wet 20 SM-SAND, trace silt, medium to coarse grained, loose, brown, wet 8 70 54 9.3 ML-SILT, trace sand, compact to dense, grey, 22 wet

- SM, 6" thick layer of sand, medium to coarse 9 60 24 9.6 grained, compact brown, wet at 21.0ft BGS 24 - SM, 6" thick layer of sand, medium to coarse 2" 0/ PVC grained, compact brown, wet at 23.0ft BGS Well Screen 10 60 11 10.2

- CL, 2" thick layer of clay, trace silt, grey, wet, 26 compact at 25.5ft BGS

- SM, 6" thick layer of sand, medium to coarse 11 80 23 10.4 grained, compact brown, wet at 25.9ft BGS 28 - SM, 6" thick layer of sand, medium to coarse 557.85 grained, compact brown, wet at 27.6ft BGS 12 57 --

OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 ML-SAND & SILT, compact to very dense, 30 fine to coarse grained, brown, wet 555.85 WELL DETAILS END OF BOREHOLE @ 30.0ft BGS Screened interval:

32 575.85 to 555.85ft AMSL 10.00 to 30.00ft BGS Length: 20ft 34 Diameter: 2in Slot Size: 10 Material: PVC 36 Sand Pack:

578.15 to 555.85ft AMSL 7.70 to 30.00ft BGS 38 Material: #5 Quartz Sand NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 1 of 1 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: MW-ZN-09S PROJECT NUMBER: 45136-30 DATE COMPLETED: May 3, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Vacuum/HSA LOCATION: ZION, ILLINOIS FIELD PERSONNEL: D. NICHOLLS ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS NUMBER INTERVAL 'N' VALUE PID (PPM)

AMSL REC (%)

4" 0/ above TOP OF RISER 593.84 ground GROUND SURFACE 591.18 protective casing SAND WITH SILT (FILL), trace gravel, trace cobbles, fine grained, moist Concrete 2

Bentonite and Cuttings 4

Bentonite 6 Seal 8

2" 0/ PVC Well Riser 10 581.18 SM-SAND & SILT (FILL), trace gravel, up to 2" diameter trace cobbles, very loose to 1 75 25 5.2 compact, fine grained, moist to wet 4.25" 0/

12 Borehole Sand 2 20 10 6.0 14 3 5 1 6.0 16 2" 0/ PVC Well Screen 4 90 3 4.0 573.68 18 GM-GRAVEL WITH SAND (FILL), trace silt, very loose, grey, well rounded gravel, wet 5 50 1 4.0 20 571.18 END OF BOREHOLE @ 20.0ft BGS WELL DETAILS Screened interval:

22 Refusal on Unknown Material 582.18 to 572.18ft AMSL 9.00 to 19.00ft BGS Length: 10ft 24 Diameter: 2in Slot Size: 10 Material: PVC 26 Sand Pack:

584.43 to 572.18ft AMSL 6.75 to 19.00ft BGS 28 Material: #5 Quartz Sand OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 6/15/06 30 32 34 36 38 NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 1 of 2 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: MW-ZN-10 PROJECT NUMBER: 45136-30 DATE COMPLETED: July 13, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Vacuum/HSA LOCATION: ZION, ILLINOIS FIELD PERSONNEL: D. NICHOLLS ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS INTERVAL 'N' VALUE PID (PPM)

AMSL NUMBER REC (%)

TOP OF RISER 593.7 GROUND SURFACE 591.0 Vac cleared to 11.0ft BGS Concrete 2 Sand, fine grained, trace to some silt, some gravel, dry to moist, brown 4

Soil Cuttings and Bentonite 6

4" 0/ Steel 8 Well Casing 10 Bentonite 580.0 Sand, some silt and gravel, fine grained, loose, 12 dark brown, wet 579.0 0 Silty and fine sand, trace gravel, trace clay, loose to compact, lighter brown, moist 14 0

- saturated at 15.0ft BGS Sand 16 0

- trace organics, black, fine grained at 16.5ft BGS 18 - 4" thick layer of silty clay, soft, trace organics, 0 trace silt, trace of gravel embedded within finer matrix at 18.0ft BGS 20 2" 0/ PVC 0 Well Screen 22 0 568.0 Sand, trace silt, fine to medium grained, loose, 24 grayish brown, wet 0 566.0 Silt and fine sand, loose, fine grained, brownish 26 gray, wet 0 564.5 Sand, trace gravel, trace silt, loose, brown, wet 28 0 OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 8/6/06 30 - compact at 30.0ft BGS 0 32 0 558.5 Silt, trace sand, compact, fine grained, wet, brownish gray 34 557.0 0 END OF BOREHOLE @ 34.0ft BGS 36 38 NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 2 of 2 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: MW-ZN-10 PROJECT NUMBER: 45136-30 DATE COMPLETED: July 13, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Vacuum/HSA LOCATION: ZION, ILLINOIS FIELD PERSONNEL: D. NICHOLLS ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS INTERVAL 'N' VALUE PID (PPM)

AMSL NUMBER REC (%)

WELL DETAILS Screened interval:

42 577.0 to 557.0ft AMSL 14.0 to 34.0ft BGS Length: 20ft 44 Diameter: 2in Slot Size: 10 Material: PVC 46 Sand Pack:

579.0 to 557.0ft AMSL 12.0 to 34.0ft BGS 48 Material: Silica Sand #5 50 52 54 56 58 60 62 64 66 68 OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 8/6/06 70 72 74 76 78 NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 1 of 1 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: MW-ZN-11 PROJECT NUMBER: 45136-30 DATE COMPLETED: July 14, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Vacuum/HSA LOCATION: ZION, ILLINOIS FIELD PERSONNEL: D. NICHOLLS ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS INTERVAL 'N' VALUE PID (PPM)

AMSL NUMBER REC (%)

TOP OF RISER 589.5 GROUND SURFACE 586.5 Vac cleared to 10.0ft BGS Concrete 2 Sand, some gravel, trace of silt, fine grained, brown, moist Soil Cuttings and Bentonite 4

4" 0/ Steel Well Casing 6

Bentonite 8

- wet at 9.0ft BGS 10 576.5 Sand, trace silt, trace gravel, fine to medium grained, compact, brown, wet 0 12 0

14 Sand 0 16 - 7" thick layer of gravel with coarse sand, dense, wet, brown at 16.0ft BGS 0

- 8" thick layer of gravel with coarse sand, 18 dense, wet, brown at 17.0ft BGS 0

- 6" thick layer of silt, trace sand, dense, fine 20 grained, grayish-brown, wet at 19.5ft BGS 2" 0/ PVC Well Screen

- 8" thick layer of gravel with coarse sand, 0 dense, wet, brown at 21.0ft BGS 22

- 6" thick layer of coarse sand, dense, wet, 0 brown at 23.0ft BGS 24

- 6" thick layer of silt, trace sand, dense, fine grained, grayish-brown, wet at 23.5ft BGS 0 26 559.5 0 Silt, trace sand, compact, fine grained, 28 grayish-brown, wet 558.5 Sand, trace silt, trace gravel, fine to medium 557.5 0 grained, compact, brown, wet OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 8/6/06 30 Silt, trace sand, compact, fine grained, 556.5 grayish-brown, wet WELL DETAILS END OF BOREHOLE @ 30.0ft BGS Screened interval:

32 576.5 to 556.5ft AMSL 10.0 to 30.0ft BGS Length: 20ft 34 Diameter: 2in Slot Size: 10 Material: PVC 36 Sand Pack:

578.5 to 556.5ft AMSL 8.0 to 30.0ft BGS 38 Material: Silica Sand #5 NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 1 of 1 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: TW-ZN-100 PROJECT NUMBER: 45136-30 DATE COMPLETED: July 7, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Geoprobe LOCATION: ZION, ILLINOIS FIELD PERSONNEL: M. BORKOWSKI ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS INTERVAL 'N' VALUE AMSL NUMBER REC (%)

TOP OF RISER 590.0 GROUND SURFACE 585.3 (SW) Fine grained sand, dry 2 Bentonite Seal 4

6 2" 0/ Borehole 577.8 8 (SP) Med-Fine grained sand, saturated 10 Sand 12 571.8 14 (SP) Coarse grained sand, larger stones, saturated 1" 0/ PVC Well Screen 16 18 20 563.8 22 END OF BOREHOLE @ 21.5ft BGS WELL DETAILS Screened interval:

578.8 to 563.8ft AMSL 24 6.5 to 21.5ft BGS Length: 15ft Diameter: 1in 26 Slot Size: 10 Material: PVC Sand Pack:

28 579.8 to 563.8ft AMSL 5.5 to 21.5ft BGS Material: Sand OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 8/6/06 30 32 34 36 38 NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 1 of 1 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: TW-ZN-101 PROJECT NUMBER: 45136-30 DATE COMPLETED: July 7, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Geoprobe LOCATION: ZION, ILLINOIS FIELD PERSONNEL: M. BORKOWSKI ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS INTERVAL 'N' VALUE AMSL NUMBER REC (%)

TOP OF RISER 588.7 GROUND SURFACE 584.3 (SW) Fine grained sand, dry 2 Bentonite Seal 4

6 2" 0/ Borehole 576.8 8 (SP) Med-Fine grained sand, saturated 10 Sand 12 570.8 14 (SP) Coarse grained sand, larger stones, saturated 1" 0/ PVC Well Screen 16 18 565.3 END OF BOREHOLE @ 19.0ft BGS WELL DETAILS 20 Screened interval:

580.3 to 565.3ft AMSL 4.0 to 19.0ft BGS 22 Length: 15ft Diameter: 1in Slot Size: 10 24 Material: PVC Sand Pack:

581.3 to 565.3ft AMSL 26 3.0 to 19.0ft BGS Material: Sand 28 OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 8/6/06 30 32 34 36 38 NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 1 of 1 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: TW-ZN-102 PROJECT NUMBER: 45136-30 DATE COMPLETED: July 7, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Geoprobe LOCATION: ZION, ILLINOIS FIELD PERSONNEL: M. BORKOWSKI ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS INTERVAL 'N' VALUE AMSL NUMBER REC (%)

TOP OF RISER 588.6 GROUND SURFACE 584.3 (SW) Fine grained sand, dry 2 Bentonite Seal 4

6 2" 0/ Borehole 576.8 8 (SP) Med-Fine grained sand, saturated 10 Sand 12 570.8 14 (SP) Coarse grained sand, larger stones, saturated 1" 0/ PVC Well Screen 16 18 20 563.3 END OF BOREHOLE @ 21.0ft BGS WELL DETAILS 22 Screened interval:

578.3 to 563.3ft AMSL 6.0 to 21.0ft BGS 24 Length: 15ft Diameter: 1in Slot Size: 10 26 Material: PVC Sand Pack:

579.3 to 563.3ft AMSL 28 5.0 to 21.0ft BGS Material: Sand OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 8/6/06 30 32 34 36 38 NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

STRATIGRAPHIC AND INSTRUMENTATION LOG (OVERBURDEN) Page 1 of 1 PROJECT NAME: ZION GENERATION STATION HOLE DESIGNATION: TW-ZN-103 PROJECT NUMBER: 45136-30 DATE COMPLETED: July 7, 2006 CLIENT: EXELON GENERATION COMPANY LLC DRILLING METHOD: Geoprobe LOCATION: ZION, ILLINOIS FIELD PERSONNEL: M. BORKOWSKI ELEV. SAMPLE DEPTH STRATIGRAPHIC DESCRIPTION & REMARKS ft Monitoring Well ft BGS INTERVAL 'N' VALUE AMSL NUMBER REC (%)

TOP OF RISER 587.5 GROUND SURFACE 583.7 (SW) Fine grained sand, dry 2 Bentonite Seal 4

6 2" 0/ Borehole 576.2 8 (SP) Med-Fine grained sand, saturated 10 Sand 12 570.2 14 (SP) Coarse grained sand, larger stones, saturated 1" 0/ PVC Well Screen 16 18 20 22 24 26 28 OVERBURDEN LOG 45136-30.GPJ CRA_CORP.GDT 8/6/06 30 553.7 END OF BOREHOLE @ 30.0ft BGS WELL DETAILS Screened interval:

32 573.7 to 553.7ft AMSL 10.0 to 30.0ft BGS Length: 20ft 34 Diameter: 1in Slot Size: 10 Material: PVC 36 Sand Pack:

574.7 to 553.7ft AMSL 9.0 to 30.0ft BGS 38 Material: Sand NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE

Revision 0 B.2 HISTORICAL GEOTECHNICAL LOGS 045136 (22) Zion Station

Revision 0 APPENDIX C QUALITY ASSURANCE PROGRAM - TELEDYNE BROWN ENGINEERING, INC.

045136 (22) Zion Station

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 TBEs 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 2 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 3 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 4 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 5 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 6 of 32

1.0 Knoxville QAM Section Introduction This Quality Assurance Manual (QAM) and related Procedures describes the Knoxville Environmental Services Laboratorys QA system. This system is designed to meet multiple quality standards imposed by Customers and regulatory agencies including:

NRCs 10 CFR 50 Appendix B NRCs Regulatory Guide 4.15 DOEs Order 414.1 DOEs 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 customers employees, and waste disposal samples (liquids and solids).

Potable and non-potable water samples 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 Validation and Verification of Computer Programs for Radiochemistry Data 1001 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 7 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 Carbon-14 and Tritium in Soils, Solids, and Biological Samples; Harvey 2003 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 8 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 9 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 customers expectations.

This policy is amplified by this Laboratorys 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 10 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, Training, and Qualification TBE provides indoctrination and training to employees and performs proficiency evaluation of technical personnel. This effort is described in Section 4.0.

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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 Assurance authorities, duties, and functions. QA has the 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.

President VP VP Administration & QA Environmental Product Assurance Director Lab QA Manager Lab Operations Manager Program Lab Administration Managers Supervisor Staff Figure 3.1. Laboratory Organization Page 12 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 assigned responsibilities for employees are described in Procedure 1002 (See Section 3.0) on Organization and in Procedure 1006, Job Descriptions. Refresher training or re-training 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 managements 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.

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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 routine 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 Managers receive contract awards (oral or written) and generate the work planning for initiation preparation (charge numbers, data structure or contents in LIMS, etc.). They review contracts for possible differences from quotations and, if acceptable, contracts are processed. Documentation of the review is by initials and date as a minimum. Contract changes receive similar reviews and planning.

5.4 TBEs 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 initiation, when required.

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5.5 Customer Satisfaction TBEs 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. Complaints 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.

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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 measurements 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 Validation 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, regulations, 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.

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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 Processes, 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 uses, 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 (see Procedures 5003 and 5004).

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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 precision 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 18 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- laboratory 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 perform 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 19 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 data 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 samples are check samples their results are included in the QC sample percentage counts. Any reported 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.

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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 Huntsville 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 these 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.

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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 vendors list if their performance is unacceptable.

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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 data 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.

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10.0 SPECIAL PROCESSES, INSPECTION, AND TEST 10.1 Special Processes The Laboratorys 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 qualified 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 described 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 24 of 32

10.4.1 Weights and Temperatures Reference standards are used by the Laboratorys 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.

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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 manufacturers 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 performed 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.

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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.

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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 results 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 Laboratorys 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.

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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, recommendations, and implementation actions are documented. Follow up verifies effectiveness.

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14.0 RESULTS ANALYSIS AND REPORTING 14.1 General The Laboratorys 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, confidentiality 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).

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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 maintained 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, manuals, and procedures 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 storage as stated above.

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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 qualified people who are as independent as possible from the activity audited. (The Laboratorys 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 auditors assessment of the effectiveness of the audited activity. Report data includes personnel contacted.

Audit findings are reviewed 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.

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Revision 1 APPENDIX D LABORATORY ANALYTICAL REPORTS 045136 (22) Zion Station

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