ML062760003

to Hydrogeologic Investigation Report, Fleetwide Assessment, Clinton Power Station.

ML062760003
Person / Time
Site:	Clinton
Issue date:	09/30/2006
From:	Conestoga-Rovers & Associates
To:	Exelon Generation Co, Office of Nuclear Reactor Regulation
References
045136 (14), FOIA/PA-2010-0209
Download: ML062760003 (454)

Text

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

HYDROGEOLOGIC INVESTIGATION REPORT

FLEETWIDE ASSESSMENT

CLINTON POWER STATION

DE WITT COUNTY, ILLINOIS Prepared For:

Exelon Generation Company, LLC

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

SEPTEMBER 2006 R EF. NO. 045136 (14)

Prepared by:

Conestoga-Rovers

& Associates 651 Colby Drive Waterloo, Ontario

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

Revision 1 TABLE OF CONTENTS Page EXECUTIVE

SUMMARY

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

1.0 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...........................................................................3 2.4 STATION SETTING............................................................................................3 2.4.1 TOPOGRAPHY AND SURFACE WATER FEATURES.................................4 2.4.2 GEOLOGY............................................................................................................4 2.4.2.1 OVERBURDEN DEPOSITS................................................................................4 2.4.2.2 BEDROCK............................................................................................................6 2.4.3 HYDROGEOLOGY.............................................................................................6 2.5 AREA GROUNDWATER USE..........................................................................8 3.0 AREAS FOR FURTHER EVALUATION...........................................................................10 3.1 SYSTEMS EVALUATIONS..............................................................................10 3.2 HISTORICAL RELEASES................................................................................13 3.3 STATION INVESTIGATIONS.........................................................................13 3.3.1 PRE-OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM.............................................................................13 3.3.2 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM......14 3.3.3 HISTORIC INVESTIGATIONS.......................................................................15 3.3.3.1 BASELINE SOIL AND GROUNDWATER INVESTIGATION...................15 3.4 IDENTIFIED AREAS FOR FURTHER EVALUATION...............................15 4.0 FIELD METHODS.................................................................................................................19 4.1 STAFF GAUGE INSTALLATION...................................................................19 4.2 GROUNDWATER MONITORING WELL INSTALLATION.....................19 4.3 GROUNDWATER MONITORING WELL DEVELOPMENT....................21 4.4 WELL INVENTORY.........................................................................................22 4.5 SURVEY..............................................................................................................22 4.6 GROUNDWATER AND SURFACE WATER ELEVATION MEASUREMENTS............................................................................................23 4.7 GROUNDWATER, SURFACE WATER AND WATER SAMPLE COLLECTION..................................................................................24 4.8 DATA QUALITY OBJECTIVES.......................................................................26 4.9 SAMPLE IDENTIFICATION...........................................................................27 4.10 CHAIN-OF-CUSTODY RECORD...................................................................27 4.11 QUALITY CONTROL SAMPLES...................................................................27 4.12 LABORATORY ANALYSES............................................................................28 045136 (14) Clinton Power Station C ONESTOGA-R OVERS & A SSOCIATES Revision 1 TABLE OF CONTENTS Page 5.0 RESULTS

SUMMARY

..........................................................................................................29

5.1 STATION

GEOLOGY.......................................................................................29 5.2 STATION HYDROGEOLOGY........................................................................31 5.2.1 GROUNDWATER FLOW DIRECTIONS......................................................31 5.2.2 MAN-MADE INFLUENCES ON GROUNDWATER FLOW.....................33 5.2.3 VERTICAL HYDRAULIC GRADIENTS........................................................33 5.2.4 LATERAL GROUNDWATER FLOW AND VELOCITY.............................34 5.3 GROUNDWATER QUALITY..........................................................................35 5.3.1

SUMMARY

OF BETA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS.................................................................................35 5.3.2

SUMMARY

OF GAMMA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS.................................................................................36 5.3.3

SUMMARY

OF FIELD MEASUREMENTS...................................................36 5.4 SURFACE WATER QUALITY.........................................................................36 5.4.1

SUMMARY

OF BETA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS.................................................................................37 5.4.2

SUMMARY

OF GAMMA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS.................................................................................37 5.5 WATER QUALITY-UNIT 2 PIT......................................................................37 5.5.1

SUMMARY

OF BETA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS.................................................................................38 5.5.2

SUMMARY

OF GAMMA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS.................................................................................38 6.0 RADIONUCLIDES OF CONCERN AND SOURCE AREAS.........................................39 6.1 GAMMA-EMITTING RADIONUCLIDES.....................................................39 6.2 BETA-EMITTING RADIONUCLIDES...........................................................39 6.3 TRITIUM.............................................................................................................39 6.3.1 GENERAL CHARACTERISTICS....................................................................39 6.3.2 DISTRIBUTION IN STATION GROUNDWATER.......................................40 6.3.3 DISTRIBUTION IN STATION SURFACE WATER......................................41 6.3.4 DISTRIBUTION IN STATION WATER- UNIT 2 PIT..................................41 6.3.5 CONCEPTUAL MODEL OF TRITIUM RELEASE AND MIGRATION...41 7.0 EXPOSURE PATHWAY ASSESSMENT............................................................................44 7.1 HEALTH EFFECTS OF TRITIUM...................................................................44

7.2 BACKGROUND

CONCENTRATIONS OF TRITIUM................................45 7.2.1 GROUNDWATER.............................................................................................45 7.2.2 PRECIPITATION DATA..................................................................................45 7.2.3 SURFACE WATER DATA...............................................................................46 7.2.4 DRINKING WATER DATA............................................................................47 045136 (14) Clinton Power Station C ONESTOGA-R OVERS & A SSOCIATES Revision 1 TABLE OF CONTENTS Page 7.2.5 EXPECTED TRITIUM BACKGROUND FOR THE STATION...................47 7.3 IDENTIFICATION OF POTENTIAL EXPOSURE PATHWAYS AND POTENTIAL RECEPTORS......................48 7.3.1 POTENTIAL GROUNDWATER MIGRATION TO DRINKING WATER USERS OFF THE STATION PROPERTY.................48 7.3.2 POTENTIAL GROUNDWATER MIGRATION TO SURFACE WATER USERS OFF THE STATION PROPERTY....................49 7.3.3 POTENTIAL GROUNDWATER MIGRATION TO SURFACE WATER ON THE STATION PROPERTY..................................50 7.4

SUMMARY

OF POTENTIAL TRITIUM EXPOSURE PATHWAYS..........50 7.5 OTHER RADIONUCLIDES.............................................................................51

8.0 CONCLUSION

S....................................................................................................................52 9.0 RECOMMENDATIONS.......................................................................................................57 9.1 DATA GAPS......................................................................................................57 9.2 GROUNDWATER MONITORING................................................................57

10.0 REFERENCES

CITED...........................................................................................................58 045136 (14) Clinton Power Station C ONESTOGA-R OVERS & A SSOCIATES Revision 1 LIST OF FIGURES (Following Text)

FIGURE 1.1 SITE LOCATION MAP FIGURE 1.2 STATION BOUNDARIES AND FEATURES FIGURE 2.1 STATION SURFACE WATER FLOW FIGURE 2.2 REGIONAL STRATIGRAPHIC CROSS-SECTION FIGURE 3.1 AREAS FOR FURTHER EVALUATION FIGURE 4.1 GROUNDWATER AND SURFACE WATER MONITORING LOCATIONS FIGURE 4.2 UNIT 2 PIT WATER SAMPLING LOCATIONS FIGURE 5.1 GEOLOGIC CROSS-SECTION LOCATION MAP FIGURE 5.2 GEOLOGIC CROSS-SECTION A-A' FIGURE 5.3 GEOLOGIC CROSS-SECTION B-B' FIGURE 5.4 GEOLOGIC CROSS-SECTION C-C' FIGURE 5.5 POTENTIOMETRIC SURFACE CONTOURS MAY 2006 - SHALLOW GROUNDWATER ZONE FIGURE 5.6 POTENTIOMETRIC SURFACE CONTOURS AUGUST 2006 - SHALLOW GROUNDWATER ZONE FIGURE 5.7 POTENTIOMETRIC SURFACE CONTOURS MAY 2006 - INTERMEDIATE GROUNDWATER ZONE FIGURE 5.8 POTENTIOMETRIC SURFACE CONTOURS AUGUST 2006 -

INTERMEDIATE GROUNDWATER ZONE FIGURE 5.9 TRITIUM CONCENTRATIONS - SURFACE WATER, WATER, AND SHALLOW GROUNDWATER FIGURE 5.10 TRITIUM CONCENTRATIONS - INTERMEDIATE GROUNDWATER FIGURE 5.11 RADIONUCLIDE CONCENTRATIONS - GROUNDWATER, WATER, AND SURFACE WATER 045136 (14) Clinton Power Station C ONESTOGA-R OVERS & A SSOCIATES Revision 1 LIST OF TABLES (Following Text)

TABLE 4.1

SUMMARY

OF MONITORING WELL INSTALLATION DETAILS TABLE 4.2

SUMMARY

OF MONITORING WELL DEVELOPMENT PARAMETERS TABLE 4.3

SUMMARY

OF GROUNDWATER ELEVATIONS TABLE 4.4

SUMMARY

OF SURFACE WATER ELEVATIONS TABLE 4.5

SUMMARY

OF MONITORING WELL PURGING PARAMETERS TABLE 4.6 SAMPLE KEY TABLE 5.1

SUMMARY

OF VERTICAL HYDRAULIC GRADIENTS TABLE 5.2 ANALYTICAL RESULTS

SUMMARY

- TRITIUM IN GROUNDWATER TABLE 5.3 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER TABLE 5.4 ANALYTICAL RESULTS

SUMMARY

- TRITIUM IN SURFACE WATER TABLE 5.5 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN SURFACE WATER TABLE 5.6 ANALYTICAL RESULTS

SUMMARY

- TRITIUM IN WATER TABLE 5.7 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN WATER 045136 (14) Clinton Power Station C ONESTOGA-R OVERS & A SSOCIATES Revision 1 LIST OF APPENDICES APPENDIX A MONITORING WELL LOGS APPENDIX B QUALITY ASSURANCE PROGRAM - TELEDYNE BROWN ENGINEERING, INC.

APPENDIX C LABORATORY ANALYTICAL REPORTS APPENDIX D DATA VALIDATION MEMORANDUM 045136 (14) Clinton Power Station C ONESTOGA-R OVERS & A SSOCIATES Revision 1 EXECUTIVE

SUMMARY

This Hydrogeologic Investigation Report (HIR) documents the results of Conestoga-Rovers & Associates' (CRA's) May 2006 Hydrogeologic Investigation Work

Plan (Work Plan) pertaining to the Clinton Power Station (Station) in De Witt County, Illinois. CRA prepared this HIR for Exelon Generation Company, LLC (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 historical releases, the structures, components, and areas of the Station that have the potential to release tritium or other radioactive liquids to the environment and past hydrogeologic investigations at the Station. CRA used this information, comb ined with its understanding of groundwater flow at the Station to identify the Area s for Further Evaluation (AFEs) and sample locations for the Station.

CRA collected 17 groundwater samples and six surface water samples at the Station.

CRA also collected a full round of water levels on two occasions from the newly installed and existing wells and measured surface water levels. In addition, five water samples were collected from the Unit 2 Pit drainage system on June 27, 2006. All groundwater and surface water samples were analyzed for tritium, strontium-89/90, and gamma-emitting radionuclides. The Unit 2 Pit water samples were analyzed for gamma emitting-radionuclides and tritium.

The results of the hydrogeologic investigation are:

Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than their respective Lower Limits of Detection (LLDs) in any of the groundwater, surface water or Unit 2 Pit 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 at concentrations greater than the United States Environmental Protection Agency drinking water standard of 20,000 pCi/L in any of the groundwater, surface water or Unit 2 Pit water samples obtained during the course of this investigation; 045136 (14) Clinton Power Station i C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Low levels of tritium were detected at concentrations greater than the LLD of 200 pCi/L in only four of the 17 groundwater samples collected; 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 of 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 (14) Clinton Power Station ii C ONESTOGA-R OVERS & A SSOCIATES Revision 1

1.0 INTRODUCTION

Conestoga-Rovers & Associates (CRA) has pr epared this Hydrogeologic Investigation Report (HIR) for Exelon Generation Company, LLC (Exelon) as part of its Fleetwide Program to determine whether groundwater at and near its nuclear power generating facilities has been adversely impacted by any releases of radionuclides. This report documents the results of CRA's May 2006 Hydrogeologic Investigation Work Plan (Work Plan), as well as several other invest igative tasks recommended by CRA during the course of the investigation. These investigations pertain to Exelon's Clinton Nuclear Power Station in De Witt County, Illinois (Station) (see Figure 1.1).

The Site, including the Station, is defined as all property, structures, systems, and components owned and operated by AmerGen Energy Company LLC (AmerGen) located at RR 3 Box 228, Clinton, Illinois. The approximate Site and Station boundaries are depicted on Figures 1.1 and 1.2.

Pursuant to the Work Plan, CRA assessed groundwater quality at the Station in locations designated as Areas for Further Ev aluation (AFEs). The process by which CRA identified AFEs is discussed in Section 3.0 of this report.

The objectives of the Work Plan were to:

characterize the geologic and hydrogeo logic conditions beneath 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, quality, concentrations, and potential sources of tritium and other radionuclides in the groundwater, if any; define the probable sources of any radionuclides released at the Station; evaluate potential human, ecological or environmental receptors of any

radionuclides that might have been released to the groundwater; and evaluate whether interim respon se activities are warranted.

045136 (14) Clinton Power Station 1 C ONESTOGA-R OVERS & A SSOCIATES Revision 1

2.0 STATION

DESCRIPTIONThe 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 wa ter features, geology, hydrogeology, and groundwater flow conditions. This section also presents an overview of groundwater

use in the area.

2.1 STATION

LOCATION The property owned by AmerGen consists of approximately 14,000 acres (the Site), of which approximately 461 acres (the Station) are used for generating electricity (Figure 1.1). The other 13,539 acres of property include an approximate 4,895-acre Clinton Lake, the land associated with the aqueduct, and surrounding agricultural and recreational land. The Station's address is RR 3 Box 228, Clinton, Illinois 61727. The Site is owned and operated by AmerGen.

The Station, for the purpose of this report, is defined as the PA and the adjacent support areas. This HIR excludes land associated with Clinton Lake, the land associated with the downstream portion of the aqueduct, and su rrounding agricultural and recreational land. 2.2 OVERVIEW OF COOLING WATER OPERATIONSThe Station is a nuclear power plant, whic h produces electricity for subsequent distribution to the United States' Eastern Interconnect System. Construction of the Station began in the fall of 1975 and the operations started in February 1987. The Station operates one 1,140 gross megawatt electric, boiling water reactor to generate power under Nuclear Regulatory Commission (NRC) Operating License No. NPF-62.

Cooling water for the Station is withdrawn from the North Fork leg of Salt Creek by way of three large pumps. The North Fork of Salt Creek is part of Clinton Lake, which is a man-made lake. The Circulating Water System is routed through the circulating water lines to deliver water to the main condenser in sufficient quantities to condense the turbine exhaust steam. After the cooling wate r is used to condense steam, this cooling water is then piped to the Seal Well, and then to the discharge flume. The discharge

flume is the starting point of the aqueduct, which is an unlined, earthen, man-made 045136 (14) Clinton Power Station 2 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 river, which routes the cooling water along a 3.1-mile route where it discharges into the Salt Creek leg of Clinton Lake. The Station discharges water to Clinton Lake via several outfalls under one National Pollutant Disc harge Elimination System (NPDES) Permit IL0036919 (McLaren and Hart, 1999a). The portion of Clinton Lake between the point of discharge and the point of withdrawal (approximately 9.9 miles) is known as the cooling loop. Tritium-containing materials are stored and treated within the Radioactive Waste (Radwaste) Building and excess liquids are stor ed within the Cycled Condensate Storage Tank, which is to the north of the Station. Along with cooling water, the Station is permitted to discharge Radwaste treatment syst em effluent to the discharge flume. The Station's last discharge of waste treatment system effluent was in September 1992. Since 1992, the Station has used evaporators, filter s, demineralizers, and carbon beds, which are in the Radwaste Building, to treat the effluent.

2.3 SURROUNDING

LAND USE Based on information from the United States Geologic Survey (USGS) Geographic Information System (GIS) Layer of National Landcover Data Set for Central Illinois, 82 percent of the land surrounding the Station is used for farming (USGS, 1990). The Station leases a large portion of their property back to farmers for agricultural use. Land to the north of the Station is used for agricu ltural purposes. Most of the remaining land around the Station is used for recreational purposes. These recreational areas include the 9,300-acre Clinton Lake Recreational Area, which includes the 4,895-acre Clinton Lake and Mascoutin State Park (USGS, 1990), located west of the Station. The land to the east and south of the Station is undeveloped. The land surrounding the Station is depicted on Figure 1.1.

2.4 STATION

SETTING The following section presents 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 these reports:

Draft Site Redress Plan for Exelon Early Site Permit, prepared by CH2M Hill, dated

January 2003; 045136 (14) Clinton Power Station 3 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Draft Emergency Plan for Exelon Early Site Permit, prepared by CH2M Hill, dated January 2003; Draft Site Safety Analysis Report for Exel on Early Site Permit, prepared by CH2M Hill, dated January 2003; and Draft Environmental Report for Exelon Early Site Permit, prepared by CH2M Hill, dated January 2003.

2.4.1 TOPOGRAPHY

AND SURFACE WATER FEATURESFigure 1.2 presents portions of some of the relevant surface water features on the Station property such as the sewage treatment lagoons, sediment ponds, and the aqueduct. The topography at the Station is generally flat, bu t slopes steeply near Clinton Lake. Surface water drains through the storm water system and man-made ditches and flows generally to the south. Surface water flow directions near the Station are shown on Figure 2.1.

The largest nearby surface water body is Clinton Lake, which is a 4,895-acre man-made cooling reservoir. Clinton Lake was formed by constructing an earthen dam 1,200 feet downstream from the confluence of the North Fork of Salt Creek and Salt Creek.

The PA and surrounding land is generally fl at and covered by paved areas, roadways, and parking lots. These areas are drained by a storm water system that drains to the northwest corner of the PA, as shown on Figure 2.1.

2.4.2 GEOLOGYThis

section presents an overview of the ge ology near the Station based upon Illinois geologic publications. Figure 2.2 presents a geologic cross-section of the regional stratigraphy near the Station based on info rmation from the Early Site Permit reports identified in Section 2.4, above.

2.4.2.1 OVERBURDEN DEPOSITSThe Station is located within the Illinois Basin west of the LaSalle Anticlinal Belt. The regional geology is comprised of an average of 250 feet of Quaternary overburden deposits. These glacial features are larg ely Wisconsinan, Illinoian, and pre-Illinoian 045136 (14) Clinton Power Station 4 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 aged deposits such as alluvial outwash, windblown loess, and lakebed clays or silts as well as icelaid till (Illinois Power, 2001).

The alluvial deposits, known as the Henry Form ation, consist of fine-grained flood plain deposits overlying coarse-grained outwash deposits (Illinois Power, 2001). The floodplain deposits are commonly silt with so me fine sand and clay. Outwash consists of sand and gravel with varying amounts of clay. The thickness of the Henry Formation varies, ranging up to 48 feet in some location

s. The Henry Formation is only found near creeks and is not present beneath the Station (Illinois Power, 2001).

Overburden units at the Station were mapped in 1998 and were reported in the Stack Unit Mapping report (ISGS, 1988). The overburden units were variable across the Station, as described as follows:

bJ(p) - most of the southeastern, eastern, and northeastern portions of the Station.

Richland Loess less than 6 meters (19 feet) thick overlying the Wedron Clay Till Formation of loamy and sandy diamictons greater than 6 meters (19 feet) thick, overlying a discontinuous portion of the Glasford Formation of silty and clayey diamictons less than 6 meters (19 feet) thick. These units go to approximately 15 meters (48 feet) below ground surface (bgs) (ISGS, 1988). ah(p)- the northwestern portion of the Station. Cahokia Alluvium less than 6 meters (19 feet) thick overlying the Henry Formation less than 6 meters (19 feet) thick, overlying a discontinuous portion of the Glasford Formation of silty and clayey diamictons less than 6 meters (19 feet) thick. These units go to approximately 15 meters (48 feet) bgs (ISGS, 1988).

The sequence of overburden deposits encountered during excavation activities associated with construction of the Station were, in descending order, as follows (Illinois Power, 2001):

Richland Loess - clayey silt (approximate thickness of 5 feet); Wedron Clay Till Formation (Wisconsinan) - clayey sandy silt till with interbedded discontinuous lenses of stratified silt, sand or gravel (approximate thickness of 35 to 45 feet); Robien Silt - silt with some organics and trace clay and fine-grained sand (reportedly only 2 feet thick); Glasford Formation (Illinoian) - sandy silt till with interbedded discontinuous lenses of stratified silt, sand or sandy silt (approximate thickness of 790 feet); and 045136 (14) Clinton Power Station 5 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Banner Formation (Kansan) - stratified silt, sand clay till and sand and gravel outwash (reported thickness of up to 140 feet).

In general, the pre-Illinoian strata occur abov e depths of 35 feet bgs [700 feet above mean sea level (AMSL)]. The Illinoian Glasford Formation is encountered at depths below 35 feet bgs and ranges from approximately 570 feet AMSL to 700 feet AMSL. Older Kansan-aged lacustrine deposits and till were encountered beneath the Glasford Formation from elevations that ranged from approximately 500 to about 570 feet AMSL (Illinois Power, 2001).

2.4.2.2 BEDROCKThe top of bedrock is found regionally at elevations ranging from 360 to 510 feet AMSL.

Beneath the Station, boring data confirm that bedrock occurs at an elevation of approximately 550 feet AMSL (or 180 feet bgs).

The uppermost bedrock in the Station ar ea is Pennsylvanian aged, interbedded limestone, siltstone, and shale of the McLeansboro Group and Modesto Formation. The Pennsylvanian bedrock is characte rized by sharp changes vertically in rock type and by lateral continuity of units such as limestone and coal.

Mississippian-Silurian-Devonian age bedrock lies beneath the Pennsylvanian strata and consists primarily of thick-bedded Mississi ppian limestone and sandstone underlain by a Devonian-aged shale, which in turn overlies Devonian-Silurian dolomite and limestone.

2.4.3 HYDROGEOLOGYThis

section describes the hydrogeology at the Station, as known prior to the completion of this hydrogeologic investigation. The Station-specific hydrogeology determined from the investigation completed pursuant to the Work Plan is discussed in Section 5.2.

Groundwater in the region originates from these aquifer systems near the Station (Illinois Power, 2001):

recent alluvial deposits (flood plain silts and fluvial sands and gravels) along streams; 045136 (14) Clinton Power Station 6 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 layers and lenses of sand or sand and gravel within the sequence of Wisconsian and Illinoian lacustrine silts and glacial tills; Kansan-aged glacial outwash sands and grav els located in buried bedrock valleys; Pennsylvanian-aged limestone/sandstone aquifers; and Mississippian and Devonian-Silurian dolomite/limestone aquifers.

The recent alluvial deposits provide good water supplies where thick sequences of sand and gravel are present, typically near larger streams with well-developed flood plains.

Water supply wells in the alluvial deposits adjacent to Kickapoo Creek are an example of a groundwater source from the a lluvial deposits (Illinois Power, 2001).

Approximately 200 feet of glacial drift underlie the Station. These deposits are divided into two hydrogeologic units. The sha llow (Wisconsinan and Illinoian) overburden sequence (up to 150 feet deep) consists of lacustrine silts and silty/clayey tills, which have limited groundwater availability. Older (Kansan) sand and sand and gravel deposits that underlie the fine-grained material in-fill buried bedrock valleys and produce prodigious quantities of good quality groundwater (Illinois Power, 2001).

The Wisconsinan deposits are typically fine grained with only occasional, shallow and very localized sand and gravel. Groundwate r in the Wisconsinan deposits occurs under unconfined conditions, usually within 2 to 20 feet bgs. Regional groundwater movement in the Wisconsinan till plain is generally west and southwest towards the Illinois River. The water table mimics the l and surface and topography influences local groundwater movement, particularly near tributary streams that receive recharge from the shallow groundwater regime (Illinois Power, 2001).

The distribution of sand lenses and layers also controls groundwater availability in the underlying Illinoian tills. Compared to th e Wisconsin strata, the sands within the Illinoian tills are thicker and more laterally extensive, providing small to moderate amounts of groundwater. Groundwater in these deeper overburden deposits is confined (Illinois Power, 2001).

Kansan sand and gravel deposits of the Banner Formation in the buried Mahomet Bedrock Valley comprise the major aquifer in the area. Yields of up to 2,000 gallons per minute (gpm) may be obtained from a suit ably constructed well located in the main channel of the valley. As discussed in Section 2.4.4, the deep Kansan outwash provides most of the major public groundwater supplies in the region (Illinois Power, 2001). The 045136 (14) Clinton Power Station 7 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Pennsylvanian bedrock also provides minor amounts of groundwater, which are typically of poor quality (Illinois Power, 2001).

The groundwater system of most interest at the Station is the upper glacial deposits. The groundwater table in the upper glacial deposits (Wisconsinan) beneath the Station generally occurs within 15 feet bgs. The highest groundwater level in the Station area measured during previous investigatio ns was an elevation of 729.7 feet AMSL.

Several discontinuous sand lenses, ranging in thickness from several inches to 22 feet were encountered in these previous bori ngs completed near the Station between an elevation of 650 feet AMSL and 730 feet AMSL. The excavation for construction of the nuclear plant extended to an approximate elevation of 680 feet AMSL, penetrating some of these lenses. Most of the sand deposits encountered at and near the Station are discontinuous pockets or lenses (Illinois Power, 2001).

Additional groundwater elevation data from piezometers installed in July 2002 indicate that the water table elevation in the shallow groundwater zone, which corresponds to the clayey sandy silt till of the Wisconsinan Wedron Clay Till Formation, is between 725 feet AMSL and 730 feet AMSL (Illinois Power, 2001).

2.5 AREA GROUNDWATER USE The Station does not use groundwater as a potable resource. The Station obtains its potable water from the North Fork leg of Sa lt Creek. Groundwater is available from a number of sources near the Station. Grou ndwater is found chiefly in local sand and gravel deposits in the shallow overburden and extensive sand and gravel deposits near the base of the overburden sequence in buried bedrock valleys (Illinois Power, 2001).

Bedrock wells are not used in any of the public water supply systems within 15 miles of the Station; however, minor amounts of groundwater are obtained from the shallow bedrock. Use of bedrock groundwater supply is limited because of poor regional water quality and the availability of shallower sources of potable groundwater (Illinois Power, 2001). The largest volumes of groundwater are ex tracted from the deep sand and gravel aquifers in the region. These deep aquifers are the principal source of drinking water for many municipalities in the region and individual wells may produce 500 gpm. The Updated Final Safety Analysis Report (Illinois Power, 2001) reported that within 045136 (14) Clinton Power Station 8 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 15 miles of the Station, approximately 65 percent of the total public groundwater supplies are pumped from the Mahomet Bedr ock Valley aquifer. Shallow alluvial deposits associated with present day stre ams are also locally important sources of drinking water. For example, water supply wells in the alluvial deposits adjacent to Kickapoo Creek supply water to the town of Heyworth, McLean County at rates up to 200 gpm (Illinois Power, 2001).

Groundwater in the shallow overburden occurs in silty clay or clayey silt tills at depths of 5 to 15 feet bgs. Occasionally, shallow large diameter wells are dug into the till and may yield relatively small water sources. Records show that most domestic wells near the Station are less than 150 feet deep and produce from local sand lenses in the upper

glacial tills rather than from the deeper Mahomet Bedrock Valley aquifer (Illinois Power, 2001). The town of De Witt is approximately 2.5 miles to the east of the Station. The town

obtains its drinking water from a well that is approximately 1.6 miles to the east of the Station. The well is cross-gradient of the Station, is reportedly several hundred feet deep, and is completed in the Mahomet Aquifer (Illinois Power, 2001).

045136 (14) Clinton Power Station 9 C ONESTOGA-R OVERS & A SSOCIATES 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 discusse s the process by which AFEs were selected.

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

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

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

CRA then designed an investigation to dete rmine whether any confirmed or potential

releases or any other release of radionuclides adversely affected groundwater. This entailed evaluating whether existing Stat ion 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

EVALUATIONSExelon launched an initiative to systemat ically 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 contai n potentially radioactively contaminated liquids. The following presents a list of these systems.

045136 (14) Clinton Power Station 10 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 System Identification Description 1 Condensate System 2 Cycled Condensate System 3 Fuel Pool Cooling and Clean-up 4 Low Pressure Core Spray 5 Suppression Pool System 6 Shut Down Service Water System 7 Plant Service Water System 8 Circulation Water System 9 Laundry Equipment Floor Drains 10 High Pressure Core Spray 11 Residual Heat Removal System 12 Sewage Treatment System 13 Reactor Core Isolation Cooling System 14 Containment, Auxiliary, and Fu el Building Equipment Drains 15 Containment, Auxiliary, and Fuel Building Floor Drains 16 Turbine, Radwaste, Control Building, and Diesel Generators Equipment Drains 17 Turbine, Radwaste, Control Building, and Diesel Generators Floor Drains After these systems were identified, Exelon developed a list of the various structures, components and areas of the systems (e.g., piping, tanks, 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; 045136 (14) Clinton Power Station 11 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 surface water bodies (i.e., basins, pits, ponds, or lagoons); trenches; underground storage tanks; and vaults. The Station then individually evaluated the various system components to determine the potential for any release of radioact ively contaminated liquid to enter the environment. Each structure or identi fied component was evaluated against the following seven primary criteria:

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

., stainless steel or steel tanks); construction methodologies (i.e., we lded or mechanical pipe joints); concentration of radioactively contam inated liquid stored or conveyed; amount of radioactively 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 no t 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 or radioactively contaminated liquid to the environment and the potential magnitude of any release.

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

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

045136 (14) Clinton Power Station 12 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 These factors were then used to rank the systems and system components as to the risk for a potential release of radioactively contaminated liquid to the environment. The evaluation process resulted in the identifica tion of structures, components, and areas to be considered for further evaluation.

3.2 HISTORICAL

RELEASESCRA also reviewed information concerning conf irmed or potential historical releases of radionuclides at the Station, including repo rts and documents previously prepared by Exelon and compiled for CRA's review. CRA evaluated this information in identifying the AFEs. Any historical releases identified during the course of this assessment that may have a current impact on Station 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 su mmary of the pre-operational radiological environmental monitoring program, past st ation investigations, and the radiological environmental monitoring program.

3.3.1 PRE-OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM A pre-operational radiological environmental monitoring program (pre-operational REMP) was conducted to establish background radioactivity levels prior to operation of the Station. The environmental media samp led and analyzed during the pre-operational REMP were atmospheric radiation, fall-out, domestic water, surface water, marine life and foodstuffs. The pre-operational REMP was initiated in May 1980 and completed during the first quarter of 1987 with initial reactor criticality on February 27, 1987 (Clinton Power Station, 1987).

Atmospheric radiation monitoring consisted of gas and air particulate radioactivity measurements; direct radiation monitoring consisted of using thermoluminescence dosimeters to measure and record exposure to penetrating radiation; domestic water

monitoring consisted of well water sample analysis; surface water monitoring consisted of sampling water and silt from Clinton Lake; marine life monitoring included sampling of fish and aquatic organisms (periphyton)

and foodstuffs monitoring included 045136 (14) Clinton Power Station 13 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 sampling of green leafy vegetables, grass, milk (control only) and meat (indicator only), when available.

The locations from which these samples were collected are at the same stations for which samples are collected for the radiol ogical environmental monitoring program (REMP), which is discussed in Section 3.3.2.

The analytical results from samples collected from water wells CCL-7 and CCL-12 included in the pre-operational REMP indicate that tritium was not detected in any groundwater samples at concentrations greater than the Lower Limit of Detection (LLD) of 200 to 300 picoCuries per liter (pCi/L). Gross beta analytical results ranged from 1.1 +/- 0.9 pCi/L to a maximum detected activity of 5.1 +/- 3.7 pCi/L.

The analytical results from samples collected from surface water locations (i.e., at Clinton Lake, at the intake screenhouse, at an upstream location and at a downstream location) indicated that out of 26 quarterly co mposite samples, tritium was detected once at 330 pCi/L in lake water at CL-13 (CL-13 is 3.6 miles southwest of the Station) and once at 220 pCi/L at the intake screenhouse; all other samples contained concentrations of tritium less than the LLD, which ranged from 174 to 300 pCi/L. Gross beta analytical results ranged from 1.1 pCi/L to a maximum detected activity of 7.6 +/- 1.5 pCi/L.

Pre-weapons testing tritium concentrations ranged from 6 to 24 pCi/L. The tritium concentrations detected in the lake wate r during the pre-operational REMP were attributed to fallout from weapons testing.

The pre-operational REMP concluded that an evaluation of the data from the pre-operational environmental survey indicates there is "nothing unusual in sources of radiation and radioactivity". The pre-operational REMP identifies that detections of radioactivity were influenced by the Cherno byl Nuclear Power Plant accidental release and fallout from nuclear weapons testing (Eisenbud, 1987).

3.3.2 RADIOLOGICAL

ENVIRONMENTAL MONITORING PROGRAMThe REMP was initiated in 1987. 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-emi tting radionuclides, tritium, iodine-131, and/or strontium as established in the procedures developed for the REMP. The samples are collected at established locations, id entified as stations, so that trends in the data can be monitored.

045136 (14) Clinton Power Station 14 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 An annual report is prepared providing a desc ription of the activities performed and the results of the analysis of the samples collected from the various media. The latest report reviewed by CRA was prepared by Clinto n Power Station and is entitled, Annual Radiological Environmental Operating Re port, Clinton Power Station - Docket Number 50-461; January 1 through December 31, 2004. This report concluded, "-all comparisons among operational data and pre-operational data showed that during 2004, the operation of Clinton Power Station had no measurable effects upon the surrounding

environment." The annual report is submitted to the NRC.

3.3.3 HISTORIC

INVESTIGATIONS This section summarizes historic investigations undertaken at the Station prior to this hydrogeologic investigation, related to actual or potential releases of radioactively contaminated liquids to the subsurface.

3.3.3.1 BASELINE SOIL AND GROUNDWATER INVESTIGATION McLaren and Hart performed a Baseline Soil and Groundwater Investigation in association with the Station property transfer in 1999. During the investigation, two monitoring wells (MW-1 and MW-2) and 12 soil boring/groundwater screenings

were sampled and analyzed for tritium. Tritium wa s not detected at concentrations greater than the LLD of 200 pCi/L (McLaren and Hart, 1999b).

No groundwater remediation has been required at the Station.

3.4 IDENTIFIED

AREAS FOR FURTHER EVALUATION CRA used the information presented in the ab ove sections along with its understanding of the hydrogeology at the Station to 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 ther e is the greatest potential for impact to groundwater.

045136 (14) Clinton Power Station 15 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Specifically, AFEs were identified based on these six considerations:

systems evaluations; risk evaluations; review of confirmed and/or potential releases; 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 CR A to become familiar with Station operations and potential systems that may impact grou ndwater. CRA then evaluated information concerning historic releases as provided by the Station. This information, along with a review of the results from historic 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.

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 rele ases 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 liqui ds to the environment combined with its 045136 (14) Clinton Power Station 16 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 understanding of groundwater flow at the Station, CRA has identified the following as the AFEs (see Figure 3.1).

AFE-Clinton Cycled Condensate System The Cycled Condensate System was identi fied as an AFE because de-mineralized primary cooling water is transferred thro ugh underground pipes to the Cycled Condensate Aboveground Storage Tank (AST), which is roughly 200 feet north of the PA. On May 3, 2006, after a recent rainfall, Station personnel collected a sample of water, which had collected in the contained valve sump located next to the Cycled Condensate Storage Tank. The results of the analysis from this sample indicated elevated concentrations of tritium in the water with in the contained valve sump. Information provided by the Station suggests that the lik ely source of the detected tritium is the result of historical maintenance practices.

AFE-Clinton Reactor Core Isolation Cooling System The Reactor Core Isolation Cooling System was identified as an AFE in order to investigate any residual impact related to a previous release of tritium in this area.

AFE-Clinton Circulating Water System The Circulating Water System was identified as an AFE because, until September 1992, this system received permitted discharges of liquid radioactive effluent. This system includes the 3.1-mile unlined aqueduct.

AFE-Clinton North Power Block Discharge - Radwaste and Turbine Building Sumps This system includes a series of floor drai ns in the Turbine and Radwaste buildings and underground pipes that have the potential to convey tritiated water from the northern end of the power block to the sediment pond. There have been no documented releases

of tritiated water from the floor drains and underground pipes.

045136 (14) Clinton Power Station 17 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 AFE-Clinton South Power Block Discharge -

Control Building/Diesel Generator Building Sumps There are six sumps that could potentially contain tritiated water. There is no historical data that the liquids discharged from these sumps were sampled for tritium.

AFE-Clinton Shut Down Service Water System The Shut Down Service Water System was id entified as an AFE because effluent from the Containment Building has the potential to contain radioactively contaminated liquids. 045136 (14) Clinton Power Station 18 C ONESTOGA-R OVERS & A SSOCIATES Revision 1

4.0 FIELD

METHODS The field investigations completed for this HIR were completed in April, May, July, and August 2006. CRA supervised the installation of monitoring wells and staff gauges, and collected water samples from the newly-installed and existing monitoring wells as well as surface water locations. The field investigations were completed in accordance with

the methodologies presented in the Work Plan (CRA, 2006).

4.1 STAFF

GAUGE INSTALLATIONFigure 4.1 presents the location of the si x surface water monitoring locations. CRA installed new staff gauges or used benchmarks of existing structures to measure surface water elevations as part of this investigatio

n. CRA installed staff gauges at the south sediment pond (SW-2) and in the aqueduct (S W-7). Benchmarks were established at the remaining surface water monitoring location

s. Station personnel provided elevation data to CRA for Clinton Lake that were used to determine the lake elevation at SW-1.

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. Additionally, an air knife was utilized to verify utilities were not present at the proposed location to a depth to 12 feet bgs.

Fourteen new monitoring wells were in stalled for the fleetwide hydrogeologic investigation (MW-CL-12I, MW-CL-13S/I, MW-CL-14S, MW-CL-15S/I, MW-CL-16S, MW-CL-17S, MW-CL-18S/I, MW-CL-19S, MW-CL-20S, MW-CL-21S, and MW-CL-22S). Figure 4.1 presents the locations of the 14 new monitoring wells. These locations were selected based on a review of all data pr ovided, the hydrogeology at the Station, and current understanding of identified AFEs. Table 4.1 summarizes the well completion details. The monitoring well stratigraphic and instrumentation logs are presented in Appendix A.

The designation "S" in the well names denotes a shallow well. These "S" wells were

installed and screened in the shallow groundwater zone. The designation "I" in the well 045136 (14) Clinton Power Station 19 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 names denotes an intermediate depth well.

These "I" wells were installed in the intermediate groundwater zone, approximately 25 feet deeper than the shallow wells.

The monitoring well boreholes were comple ted in unconsolidated materials using 4.25-inch inside diameter hollow-stem auger (HSA) drilling techniques with split spoon sampling. Down hole drilling equipment was thoroughly steam cleaned between drilling locations and prior to leaving the Station. Decontamination fluids were containerized in 55-gallon drums, labeled and were staged at the Station pending characterization and management by the Station.

Specific installation protocols for the shallow monitoring wells were:

each borehole was advanced to a depth of 12 feet below grade using vacuum excavation equipment (air knife) to ensu re no underground utilities were damaged; the borehole was then advanced to the target depth using 4.25-inch inside diameter

HSA; continuous split spoon samples were collected during HSA advancement. At depths greater than 30 feet below grade the sampling interval was increased to every 5 feet; a nominal 2-inch diameter No. 10 slot PVC screen, 10 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 silica sand filter sand pack was installed in the annulus between the screen/riser pipe and the borehole 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; the remaining portion of the annulus was filled with concrete and a 6-inch diameter protective above-grade casing or in higher traffic areas a flush road-way protective casing was installed; and cement-filled bollard posts were installed ar ound selected monitoring well locations.

The overburden was classified using the Unified Soil Classification System (USCS). Soil cuttings and spoils from the vacuum excavation were containerized in 55-gallon drums, labeled and are staged at the Station pending characterization and management by the Station. 045136 (14) Clinton Power Station 20 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Monitoring well MW-12I, located on the northwest side of the PA between the Station and Clinton Lake, was initially proposed as a shallow monitoring well location. This monitoring well was intended to monitor shallow groundwater conditions downgradient of the Station. However, shallow groundwater was not encountered during the borehole advancement. Therefore, the monitoring well was completed as an intermediate depth well. This location is al so along the top edge of a steep slope with approximately 30 feet of vertical relief, which is believed to account for the shallow

water-bearing unit not being encountered.

4.3 GROUNDWATER

MONITORING WELL DEVELOPMENT To establish good hydraulic communication with the aquifer and to reduce the volume of sediment in the monitoring well, monitoring well development was conducted in

accordance with these procedures:

Monitoring wells were surged using a pre-cleaned surge block or bailer for at least 10 minutes. Water was purged from the monitoring well using an electric submersible or

peristaltic pump. Groundwater was collected at regular in tervals and the pH, temperature, and conductivity measured using field instrume nts. These instruments were calibrated daily according to the manufacturer's specif ications. Additional observations such as color, odor, and turbidity of the purged water were recorded. Development continued until the turbidity and silt content of the monitoring wells was significantly reduced and three consis tent readings of pH, temperature, and conductivity were recorded, or a maxi mum of eight-well volumes were purged.

A summary of the well development para meters is provided in Table 4.2.

In the event that a monitoring well was purg ed dry prior to stabilization, the well was allowed to recharge and purging was cont inued. This process continued until stabilization was achieved or a maximum of eight well volumes were removed. Development equipment was decontaminated between monitoring wells and new tubing was used at each monitoring wells. Water generated during development was containerized in 55-gallon drums, which were subsequently processed by the Station in accordance with their NPDES permit.

045136 (14) Clinton Power Station 21 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 4.4 WELL INVENTORYFigure 4.1 presents a map of the Station including the pre-existing monitoring well/piezometer network. CRA completed an inventory of the pre-existing well network to evaluate the integrity and status of the wells. This inventory included the opening of each well cap, measuring the de pth-to-water, sounding the total well depth and recording the condition of the well.

The results of the inventory identified:

pre-existing monitoring wells MW-8, MW-9, MW-10, and MW-11, are no longer present and were apparently abandoned. Seven of the 11 pre-existing monitoring wells are useable; the concrete pad at monitoring well MW-6 was heaved above the adjacent ground level but the well was still usable for hydraulic monitoring; the well casing at monitoring well MW-2 was bent at a depth of 4 feet below the top

of the casing, which prevented lowering the groundwater sampling pump into the well. However, CRA sampled the well using a peristaltic pump; and piezometer E-4B was not inspected due to it s distance from the Station. Three of the four existing piezometers are still usable.

The integrity and condition of the remaining monitoring wells and piezometers were

found to be acceptable. Well construction logs were not available for the existing wells/piezometers.

CRA did not perform a public and private wa ter supply well inventory as part of this hydrogeologic investigation due to the Station setting.

4.5 SURVEY

The 14 new monitoring wells and six new staff gauges 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 045136 (14) Clinton Power Station 22 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 ground elevation at each well to the nearest 0.10 foot relative to the NGVD, and the well location to the nearest 1.0 foot. A reference point was also marked on each staff gauge.

4.6 GROUNDWATER

AND SURFACE WATER ELEVATION MEASUREMENTS On May 22, 2006, CRA collected a round of water level measurements from the new monitoring wells and staff gauges installed in accordance with the Work Plan and from ten existing monitoring wells/piezometers. On August 8, 2006, CRA collected a second round of water level measurements from the monitoring wells/piezometers and staff gauges at the Station. Based on the measur ed depth to water from the reference point and the surveyed elevation of the referenc e point, the groundwater and surface water elevations were calculated. A summary of groundwater elevations for both events is presented in Table 4.3. Staff gauge meas urements and corresponding surface water elevations are presented in Table 4.4.

Prior to the water level measurements, the wells were identified and located. Once the wells were identified, CRA completed a thorou gh 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. The water level measurements were obtained using these 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 until contact with the water was indicated. The tip was slowly raised until the buzzer beg an to activate. This indicated the static water level. The reading at the reference point was noted to the nearest hundredth of a foot. The reading was then re-checked. The water level was then recorded, and the water level meter decontaminated prior to use at the next well location.

045136 (14) Clinton Power Station 23 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 4.7 GROUNDWATER, SURFACE WATER AND WATER SAMPLE COLLECTION CRA conducted two groundwater sampling even ts during the completion of the Work Plan for this hydrogeologic investigation. A total of 14 monitoring wells and one piezometer were sampled between May 22 and May 25, 2006 and two additional monitoring wells were sampled on August 4, 2006. Of the 17 monitoring wells/piezometers sampled, 14 were newly installed. The two existing wells (MW-1 and MW-2) were selected for inclusion in this monitoring program based on their proximity to the AFEs. Piezometer B-3 wa s selected as a background monitoring location. The new monitoring wells were in stalled to complete the monitoring network

near the AFEs. The sampling was scheduled to allow for 2 weeks to elapse between well development and groundwater sample collection.

CRA conducted the sampling using electric su bmersible pumps or pe ristaltic pumps and dedicated polyethylene tubing to employ lo w flow purging techniques as described in Puls and Barcelona (1996).

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

The wells were located and identified. 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 (mL/min). Initial purging began us ing 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, th e pumping rate was increased dependent on the behavior of the well. During purging, the pumping rate and groundwater level were measured and recorded every 10 minutes. The field parameters [pH, temperature, conductivity, oxidation-reduction potential (ORP), dissolved oxygen (DO), and turbidity]

were monitored during the purging to 045136 (14) Clinton Power Station 24 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 evaluate the stabilization of the purged gr oundwater. Stabilization was considered to be achieved when three consecutive readings for each parameter, taken at 5-minute intervals, were within these limits:

pH +/- 0.1 pH units of the average value of the three readings; Temperature +/- 3 percent of the aver age 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 aver age 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 (NTU). Once purging was complete, the groundwater samples were collected directly from the pump/tubing directly into the sample containers. 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.

The purging parameters are presented in Table 4.5.

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, as described in Section 4.9. The samples were then screened by the Station for shipment to Teledyne Brown Engineering, Inc. (Teledyne Brown). A sample key is presented in Table 4.6.

CRA containerized the water purged from the Station wells during the sampling, as well as the water purged from all of the wells du ring the hydrogeological investigation. The water was placed into 55-gallon drums, which will be processed by the Station in accordance with its NPDES permit.

Station personnel collected water samples from five locations within the Unit 2 Pit drainage system on June 27, 2006. The Unit 2 Pit sampling locations are shown on Figure 4.2. The water samples from the drainage system within the Unit 2 Pit were collected in response to an evaluation of the May 22, 2006 groundwater elevation data, which indicated that the shallow groundwater beneath the PA and most of the Station flows toward and discharges into the Unit 2 Pit.

045136 (14) Clinton Power Station 25 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 On May 24, 2006, surface water samples were collected by CRA personnel at the four staff gauges and at the two locations on the north end of the Cooling Lake, just south of the Site. The surface water sampling locations are shown on Figure 4.1.

The samples were collected by submerging the sample container at the determined sample locations until completely filled.

All samples were shipped to Teledyne Brown for analysis. Teledyne Brown's Quality Assurance Program is provided in Appendix B.

A sample key is presented in Table 4.6.

4.8 DATA QUALITY OBJECTIVESCRA has validated the analytical data to establish the accuracy and completeness of the data reported. Teledyne Brown provided the analytical services. The Quality Assurance Programs for the laboratory are described in Appendix B. Analytical data for groundwater and surface water samples collected in accordance with the Work Plan are presented in Appendix C. Data validation reports are presented in Appendix D. The data validation included the following information and evaluations:

sample preservation; sample holding times; laboratory method blanks; laboratory control samples; 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 these techniques:

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

045136 (14) Clinton Power Station 26 C ONESTOGA-R OVERS & A SSOCIATES Revision 1

4.9 SAMPLE

IDENTIFICATION Systematic sample identification codes were us ed to uniquely identify all samples. The identification code format used in the field was: WG-CL-MW-CL-20S-052306-JKAD-02. A sample key listing all the samples collect ed during the fleetwide investigation is presented in Table 4.6.

WG - Sample matrix -groundwater WS - Sample matrix - surface water RB - Sample matrix - rinse blank CL - Station code MW-CL-20S - Sample location 052306 - Date JKAD - Sampler initial 02 - Sample number 4.10 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.

4.11 QUALITY CONTROL SAMPLES Quality control samples were collected to evaluate the sampling and analysis process.

Field Duplicates Field duplicates were collected to verify th e accuracy of the analytical laboratory by providing two samples collected at the same location and then comparing the analytical results for consistency. Field duplicate 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 sample s were selected in the field during the performance of sample collection activities. The duplicate samples were collected simultaneously with the actual sample and were analyzed for the same parameters as the actual samples.

045136 (14) Clinton Power Station 27 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Rinsate Blank Samples Rinsate blanks were collected to verify that decontamination procedures conducted in the field were adequate. Rinsate blanks were collected by routing Station-supplied demineralized water through decontaminated sampling equipment. Rinsate blanks were collected at a frequency of one rinsate blank for every day samples were collected using non-disposable or non-dedicated equi pment. Two Rinsate blanks were collected.

Split Samples Split samples were collected for the NRC fo r tritium simultaneousl y with the actual sample during the May 2006 sampling event.

Samples were collected at each sample location. Split samples were delivered to the Station personnel and transferred to the NRC. 4.12 LABORATORY ANALYSES Groundwater and surface water samples were analyzed for tritium and gamma-emitting radionuclides as listed in NUREG-1302 and strontium-89/90 as listed in 40 CFR 141.25.

Water samples from the Unit 2 Pit drainage system were analyzed for gamma-emitting radionuclides and tritium.

045136 (14) Clinton Power Station 28 C ONESTOGA-R OVERS & A SSOCIATES Revision 1

SUMMARY

This section provides a summary of Statio n-specific geology and hydrogeology, along with a discussion of hydraulic gradients, groundwater elevations, and groundwater 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 The geology beneath the Site consists of a relatively thick overburden deposit that overlies alternating layers of limestone, sandstone, shale, and coal. Figure 5.1 displays the locations of the hydrogeologic cross-sections across the Site. Hydrogeologic cross-sections in south-north, east-west, and north-south profiles are presented on Figures 5.2, 5.3, and 5.4, respectively. Thes e locations were chosen because of their close proximity to the AFEs and structures potent ially influencing groundwater flow patterns.

The stratigraphic units encountered during monitoring well installation activities consisted of the following:

Richland Loess; Wedron Clay Till Formation; and Glasford Formation.

The Robien Silt, if contacted, could not be differentiated in the field from the Glasford Formation.

Monitoring wells MW-CL-14S, MW-CL-16S, and MW-CL-22S were installed in the PA adjacent to the Seal Well, Reactor Core Isolation Cooling Storage Tank, and Diesel Generating Building, respectively. At these locations compacted construction fill material, associated with the Station construc tion excavation, was en countered. This fill material consisted of compacted layers of silt and sand including concrete mud mats.

During construction, concrete mud mats were poured at specific locations, as the excavation was backfilled. These mud mats consisted of a lower strength concrete mixture that was poured to make a stable working platform to install pipes and conduits. Concrete mud mats were encountered between depths of 13.5 feet and 20 feet below grade (716 and 722 feet AMSL) at MW-CL-14S and at depths of 18 to 26 feet below grade (709 to 717 feet AMSL) at MW-CL-16S.

The concrete mud mat was penetrated at 045136 (14) Clinton Power Station 29 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 both locations and the monitoring well scr eens were installed across the concrete and into the soil below.

Eight shallow monitoring wells (MW-CL-13S, MW-CL-15S, MW-CL-16S, MW-CL-17S, MW-CL-18S, MW-CL-19S, MW-CL-20S, and MW-CL-21S) were screened within the Wedron Clay Till Formation. The Wedron Clay Till Formation is the shallow overburden water bearing unit beneath the Site and is primarily a clayey, sandy, silt till with interbedded lenses of silt, sand, and gravel. The monitoring well logs for the new monitoring wells are presented in Appendix A.

Four intermediate depth monitoring wells were installed at an elevation that corresponds to the Glasford Formation. The Glasford Formation, reportedly is a sandy silt till with sand lenses and discontinuous sand layers (Illinois Power, 2001). Monitoring well MW-CL-12I was installed in a saturated section of sandy gray clay just above the sand layer that the other three intermediate wells are screened in and extends

slightly into the sand layer.

Intermediate depth monitoring wells MW-CL-15I, MW-CL-13I, and MW-CL-18I, were

installed in a sand layer. The top of the sand layer was encountered at depths that ranged from approximately 55 feet to 64 feet below grade with elevations ranging from 670 to 680 feet AMSL. The borings were terminated in the sand layer and did not penetrate to a deep unit. The maximum thickness penetrated was 7 feet at MW-CL-13I.

As shown on the hydrogeologic cross-sections this sand layer appears to be continuous beneath the Station since the sand was encountered in each of the boreholes advanced.

Profile A-A' (Figure 5.2) is a north-south profile through the middle of the Site. The cross-section begins at Clinton Lake and te rminates at MW-CL-20S near the Discharge Flume/aqueduct. This profile transects with AFEs Clinton 3 and 4 along the northern limit of the PA and AFEs Clinton 2 and 5 in the western portion of the PA. This profile

also shows the relationship between the groundwater and the geology, Clinton Lake, the Unit 2 Pit, and building foundation excavations for Unit 1. The Unit 2 Pit is an approximately 35-foot deep excavation. This pit was excavated during Station construction for a second reactor. The seco nd reactor was never constructed and the pit was never backfilled. The profile shows that the shallow groundwater unit intersects the Unit 2 Pit and illustrates the influence of the drainage system at the base of the pit on

the groundwater table. This profile shows the groundwater divides near the aqueduct and near Clinton Lake. Profile A-A' also illu strates that the sand unit representing the intermediate groundwater unit is below the pit elevation (approximately 700 feet AMSL).

045136 (14) Clinton Power Station 30 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Profile B-B' (Figure 5.3) is an east-west profile that intersects AFE-Clinton-3. This cross-section begins in the west near the sediment ponds (AFE-Clinton-4) and runs northward to MW-CL-18S/I and north of AFE 4 to MW-CL-12I where it crosses AFE-Clinton-3 and then transects monitoring wells MW-CL-19S and MW-CL-13I/S, the

latter of which is adjacent to AFE-Clinton-1.

This profile shows the relationship between the groundwater and geology between the PA and the sediment ponds. This profile shows that the shallow groundwater unit near the Cycled Condensate Storage Tank is nearly at the same elevation as the pit located next to the storage tank. These data indicate that the base of the pit is in clos e contact with the shallow water table. This profile also indicates that the base of the se diment ponds is in contact with the shallow groundwater unit. This profile also shows that the shallow groundwater unit discharges to the ditch near monitoring well MW-CL-19S.

Profile C-C' (Figure 5.4) is a north-south profile through the eastern portion of the PA extending to the north into AFE-Clinton-1 (at MW-CL-13I/S). In addition to the features shown on Figure 5.4, this profile depicts the stratigraphic unit adjacent to the Radwaste Building and the Unit 2 Pit based on the geology encountered during the drilling of MW-CL-13S. This profile also shows the major influence that the Unit 2 Pit has on flow within the shallow groundwater system.

5.2 STATION

HYDROGEOLOGY This section describes the Station hydrogeology. There were two distinct groundwater flow regimes encountered during the investigat ion: the shallow regime, which is in the interbedded layers of the Wedron Clay Till Formation (above 690 feet AMSL) and the intermediate regime, which is in the sand layer beneath the Wedron Clay Till Formation (below 690 feet AMSL).

5.2.1 GROUNDWATER

FLOW DIRECTIONSGroundwater flow directions are provided on Figures 5.5 and 5.6 for the shallow groundwater system and Figures 5.7 and 5.8 for the intermediate system. Figures 5.5 and 5.7 represent water levels measured in May 2006. Figures 5.6 and 5.8 represent water levels measured in August 2006.

The May and August groundwater flow directions are similar.

045136 (14) Clinton Power Station 31 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 As shown on Figures 5.5 and 5.6, the shallow groundwater beneath the PA and most of the Station flows toward the Unit 2 Pit, which is approximately 35 feet deep. This flow pattern is not consistent with the hydrogeo logic information used to develop the Work Plan. The radial shallow groundwater flow pattern is the result of the passive drainage system beneath the Unit 2 Pit. In response to this observation water samples from five locations within the Unit 2 Pit drainage system were collected on June 27, 2006.

North of the PA, the groundwater elevation at monitoring well MW-CL-18S is higher than the surface water elevation of Clinton Lake.

This indicates there is a flow divide in the shallow groundwater flow regime between the Unit 2 Pit and Clinton Lake. North of the flow divide, shallow groundwater discharges into Clinton Lake. South of the PA, there is a flow divide near monitoring wells MW-7 and B-2. South of these wells groundwater flows west and eventually discharges into Clinton Lake.

The surface water elevation in the aqueduct on May 22, 2006 (723.75 feet AMSL) was lower than the groundwater elevation at nearby shallow monitoring well MW-CL-20S (724.69 feet AMSL). This indicates that shallow groundwater discharges into the aqueduct. The surface water elevations in the primary lagoon and secondary lagoon are approximately 9 feet higher than the ground water elevations measured in the closest shallow monitoring well, MW-CL-20S. This indicates that groundwater does not discharge to these surface water features and they act as local sources of recharge for the shallow groundwater system.

West of the PA, the shallow groundwater flow s west towards Clinton Lake. This area appears to be beyond the hydraulic influence of the Unit 2 Pit and probably represents the natural groundwater flow direction fo r the shallow groundwater. Groundwater elevations in this area are higher than the elevation of Clinton Lake indicating shallow

groundwater west of the PA discharges into Clinton Lake.

The intermediate groundwater potentiometric elevation data are shown on Figures 5.7 and 5.8. As shown, this deeper groundwater flows westward towards Clinton Lake. The groundwater elevation at monitoring well MW-CL-18I is higher than the surface water elevation of Clinton Lake. This su ggests that the intermediate groundwater system also discharges to Clinton Lake. As shown on Figures 5.2 and 5.4, the groundwater elevation within the intermedia te zone is below the foundation of the Reactor Buildings. As shown on Figure 5.7, there is a radial flow pattern near the Unit 2 Pit. The base of the Unit 2 Pit is at 698 feet AMSL and is below the potentiometric surface of the intermediate groundwater in dicating intermediate groundwater also locally discharges to the Unit 2 Pit.

045136 (14) Clinton Power Station 32 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 5.2.2 MAN-MADE INFLUENCES ON GROUNDWATER FLOW The PA is between Clinton Lake and the Unit 2 Pit (Figure 1.2). As shown on Profile A-A', Clinton Lake has an elevation of approximately 690 feet AMSL. There is a road adjacent to the Lake and then the ground surface rises sharply to the south to an elevation of approximately 735 feet AMSL. Shallow and intermediate groundwater discharges to Clinton Lake (See Section 5.2.1).

The foundation of the Reactor Building was installed to an elevation of 712 to 702 feet AMSL, which is below the water table as shown on Figure 5.2 (foundation elevation information provided by Station En gineering). The foundation of the building is beneath the water table so it is expected to act as a local diversion of groundwater flow. As shown on Profiles A-A' and C-C', the Unit 2 Pit has a base elevation of 698 feet AMSL, which is also below the water table. Therefore, the groundwater table in the vicinity of the Unit 2 Pit flows toward and discharges into the pit. The Unit 2 Pit is in turn drained by a passive drainage system that discharges to Clinton Lake. Figures 1.2 and 4.2 illustrate this drainage system. The drainage system consists of several collection pipes connected by underg round drainage pipes installed just below the base of the pit, which is mainly covere d with concrete. There is also a concrete

collection trough in the northern corner of the pit. The drainage system drains to a drainage pipe that runs under the Reactor Building. This drainage pipe was originally intended to be the cooling water Circulating Water System Pipe for the second reactor, which was never constructed. The elevation of the drainage system is approximately 695 feet AMSL and the elevation of the lake is 690 feet AMSL therefore, the pressure head is back towards the lake.

5.2.3 VERTICAL

HYDRAULIC GRADIENTSThree monitoring well nests (MW-CL-13S

/I, MW-CL-15S/I, and MW-CL-18S/I) have been installed with wells in the shallow till and in the intermediate sand to determine the vertical distribution of impacted groundwater, and the vertical hydraulic gradient.

The calculated vertical hydraulic gradients using the August 2006 water level data for the Site are provided in Table 5.1. Downwa rd vertical hydraulic gradients that ranged from 0.11 feet/foot to 0.52 feet/foot were calculated at all three locations. The 045136 (14) Clinton Power Station 33 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 magnitude of the vertical hydraulic gradie nt is consistent and is greater than the horizontal hydraulic gradients.

5.2.4 LATERAL

GROUNDWATER FLOW AND VELOCITY The spacing of the shallow groundwater elevation contours provided on Figure 5.5 indicate that the horizontal hydraulic gradient in the shallow groundwater is variable. The horizontal hydraulic gradient along seve ral groundwater flow paths was calculated by dividing the change in groundwater elev ation along the groundwater flow path by the corresponding distance along the flow path.

As shown on Figure 5.5, immediately south of the Unit 2 Pit the horizontal hydraulic gradient in the shallow groundwater zone is steep, on the order of 0.1 feet/foot. This strong gradient is consistent with a relative ly low hydraulic conductivity soil such as the clayey, sandy, silt till. On the other sides of the Unit 2 Pit the horizontal hydraulic gradient decreases as low as 0.03 feet/foot. The gradient increases as the shallow groundwater approaches the Unit 2 Pit, wh ich is typical of a discharge boundary.

With a gradient of 0.02 to 0.1 feet/foot, the average horizontal groundwater velocity in the shallow groundwater zone can be calculated to be 0.3 feet/year to 1.5 feet/year. This is based on a porosity of 0.25 (Illinois Power, 2001) and a hydraulic conductivity of 0.01 feet/day from field hydraulic testing (Illinois Power, 2001).

West of the PA, beyond the influence of the groundwater that flows towards the Unit 2 Pit, the shallow groundwater flows west. He re the horizontal hydraulic gradient is lower still at 0.02 feet/foot and may be more representative of the natural groundwater gradient.

The calculated horizontal hydraulic gradient in the intermediate groundwater beneath the PA is 0.008 feet/foot. The spacing of the intermediate groundwater elevation contours provided on Figure 5.7 is fairly uniform, indicating that there is a limited variation in the horizontal hydraulic gradient in the intermediate sand. The lower hydraulic gradient is also consistent with the more permeable sands that the intermediate wells are screened in. The ho rizontal hydraulic gradient increases with increasing proximity to the Unit 2 Pit, sim ilar to the shallow groundwater. Using the hydraulic gradient of 0.008 feet/foot with a hydraulic conductivity of 28 feet/day (Illinois Power, 2001) and a typical porosity of 0.32 (USEPA, 1996) yields an estimated horizontal groundwater velocity in the in termediate groundwater of 256 feet/year.

045136 (14) Clinton Power Station 34 C ONESTOGA-R OVERS & A SSOCIATES Revision 1

5.3 GROUNDWATER

QUALITYCRA collected 17 groundwater samples from all 14 newly installed monitoring wells and existing monitoring wells/piezometers MW-1, MW-2, and B-3 in accordance with the Work Plan. Teledyne Brown provided the analytical services. The Quality Assurance Program for the laboratory is described in Appendix B. The analytical data reports are provided in Appendix C.

The analytical data presented herein has 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 does not include the results of recounts that

the laboratory completed, except if those results ultimately replaced an initial report. The tables and figures, therefore, includ e only the first analysis reported by the laboratory. Where multiple samples were collected over time, the most recent result has been used in the discussion, below.

5.3.1

SUMMARY

OF BETA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS A summary of the tritium results for the gr oundwater samples collected during this investigation is provided in Table 5.2 and shown on Figures 5.9 and 5.10.

All tritium concentrations were below the United States Environmental Protection Agency (USEPA) drinking water standard of 20,000 pCi/L. Tritium was not detected above the LLD of 200 pCi/L in 13 of the 17 groundwater samples collected.

The four samples that contained tritium at a concentration greater than the LLD of 200 pCi/L were collected from the shallow groundwater zone. These include samples from the following monitoring wells: MW-CL-13S (230 +/- 114 pCi/L), MW-CL-14S (201 +/- 107 pCi/L), MW-CL-21S (545 +/- 138 pCi/L), and MW-CL-22S (278 +/- 122 pCi/L) in the duplicate. The initial groundwater sample collected from monitoring well MW-CL-22S did not reveal a tritium co ncentration greater than the LLD.

Strontium-89/90 was not detected at concentrations greater than the LLD of 2.0 pCi/L.

A summary of the strontium-89/90 results for the groundwater samples collected as 045136 (14) Clinton Power Station 35 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 part of the investigation that is the subject of this HIR is provided in Table 5.3 and shown on Figure 5.11.

5.3.2

SUMMARY

OF GAMMA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS Gamma-emitting target radionuclides were no t detected at concentrations greater than their respective LLD. A summary of the ga mma-emitting radionuclides results for the groundwater samples collected as part of the in vestigation that is the subject of this HIR is provided in Table 5.3 and shown on Figure 5.11.

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) coul d be definitively evaluated as being naturally occurring due to the lack of presence of other radionuclides which would otherwise indicate the potential of production from the Station.

5.3.3

SUMMARY

OF FIELD MEASUREMENTSTable 4.5 presents a summary of field measur ements collected during the purging of the monitoring wells prior to sampling. These field measurements included pH, dissolved oxygen, conductivity, turbidity and temperature. The field parameters were typical of shallow glacial deposits. As such the pH values were found to be neutral with pH values around 7.0 and the conductivity was indicative of a shallow water table system subject to surface water recharge. Of note were the slightly elevated temperature readings (above 25 degrees Celsius) in the purge water from MW-CL-14S, which is located adjacent to the Seal Well, which re ceives circulating water from the Turbine Building.

5.4 SURFACE

WATER QUALITYSix surface water samples were collected from the locations shown on Figure 4.1. The samples were 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 B. The analytical data reports are provided in Appendix C.

045136 (14) Clinton Power Station 36 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 5.4.1

SUMMARY

OF BETA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS A summary of the tritium results for the surface water samples collected in this investigation is provided in Table 5.4 and shown on Figure 5.9.

Tritium was not detected at concentrations greater than the LLD of 200 pCi/L.

Strontium-89/90 was not detected at concentrations greater than the LLD of 2.0 pCi/L. A summary of the strontium-89/90 results for th e surface water samples collected in this investigation is provided in Table 5.5 and shown on Figure 5.11.

5.4.2

SUMMARY

OF GAMMA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS Gamma-emitting target radionuclides were no t detected at concentrations greater than their respective LLD. A summary of the ga mma-emitting radionuclides results for the surface water samples collected in this investigation is provided in Table 5.5 and shown on Figure 5.11.

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) coul d be definitively evaluated as being naturally occurring due to the lack of presence of other radionuclides which would otherwise indicate the potential of production from the Station.

5.5 WATER

QUALITY-UNIT 2 PITFive water samples were collected from the Unit 2 Pit drainage system at the locations shown on Figure 4.2. The samples were analyzed for tritium and gamma-emitting radionuclides. Teledyne Brown provided the analytical services. The Quality Assurance Program for the laboratory is described in Appendix B. The analytical data

reports are provided in Appendix C.

045136 (14) Clinton Power Station 37 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 5.5.1

SUMMARY

OF BETA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS A summary of the tritium results for the Unit 2 Pit water samples collected in this investigation is provided in Table 5.6 and shown on Figure 5.9.

Tritium was not detected above the LLD of 200 pCi/L in four of the five water samples collected. Tritium was detected at a concentration of 227 +/- 126 pCi/L in the water

sample collected from Drainage Pipe - 1D (see Figure 4.2).

5.5.2

SUMMARY

OF GAMMA-EMITTING RADIONUCLIDES ANALYTICAL RESULTS Gamma-emitting target radionuclides were no t detected at concentrations greater than their respective LLD. A summary of the ga mma-emitting radionuclides results for the water samples collected in this investigation is provided in Table 5.7 and shown on Figure 5.11.

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) coul d be definitively evaluated as being naturally occurring due to the lack of presence of other radionuclides which would otherwise indicate the potential of production from the Station.

045136 (14) Clinton Power Station 38 C ONESTOGA-R OVERS & A SSOCIATES Revision 1

6.0 RADIONUCLIDES

OF CONCERN AND SOURCE AREAS This section discusses radionuclides evaluated in this investigation, potential sources of the radionuclides detected, and their distribution.

6.1 GAMMA-EMITTING RADIONUCLIDES Gamma-emitting target radionuclides were no t detected at concentrations greater than their respective LLD. Other non-targeted radi onuclides were also included in the tables but excluded from discussion in this re port. 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 potent ial of production from the Station.

6.2 BETA-EMITTING RADIONUCLIDES Strontium-89/90 was not detected in any of the groundwater or surface water samples collected at concentrations greater than the LLD of 2.0 pCi/L. Tritium was detected in five of the 28 total sample locations. Dete cted concentrations of tritium ranged from 201 +/- 107 pCi/L to 545 +/- 138 pCi/L.

Since only tritium was detected at concentr ations greater than the LLDs, the following sections focus on tritium; specifically, pr oviding general characteristics of tritium, potential sources, distribution in groundwa ter, and a conceptual model for migration.

6.3 TRITIUMThis

section discusses the general characteristic s of tritium, the distribution of tritium in groundwater and surface water, and the conceptual model of tritium release and migration.

6.3.1 GENERAL

CHARACTERISTICSTritium (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 (14) Clinton Power Station 39 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 water behaves the same as ordinary water in both the environment and the body. Tritium can be taken into the body by drinki ng water, breathing air, eating food, or absorption through skin. Once tritium 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 uppe r 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, tritiate d water is colorless and odorless. Tritiated water behaves chemically and physically like non-tritiated water in the subsurface, and

therefore tritiated water will travel at the same velocity as the average groundwater velocity.

Tritium has a half-life of approximately 12.3 ye ars. It decays spontaneously to helium-3 (3He). This radioactive decay releases a beta particle (low-energy electron). The radioactivity of tritium is the so urce 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 in groundwater beneath the Station.

Shallow Groundwater Tritium was detected in only four of the 17 monitoring wells/piezometers sampled during this investigation at concentrations greater than the LLD of 200 pCi/L:

045136 (14) Clinton Power Station 40 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 MW-CL-13S at 230 +/- 114 pCi/L, which is located east of the PA and adjacent to the Cycled Condensate System; MW-CL-14S at 201 +/- 107 pCi/L, which is located along the east side of the PA, west of the Seal Well; MW-CL-21S at 545 +/- 138 pCi/L, which is

located downgradient (upper water bearing unit) of the Cycled Condensate System; and the duplicate sample collected from MW-CL-22S at 278 +/- 122 pCi/L, which is located downgradient of the Reactor Core Isolation Cooling System, South Power Block Discharge Control Buildings and Diesel Gene rator Sumps, and the Shut Down Service Water System. As shown in Table 5.2, tritium concentrations were less than the LLD of 200 pCi/L for all other groundwater samples.

Intermediate Groundwater Groundwater samples collected from the intermediate depth monitoring wells MW-1 (existing from prior investigations), MW-CL-12I, MW-CL-15I, MW-CL-13I, and MW-CL-18I did not contain tritium at concen trations greater than the LLD of 200 pCi/L.

Based upon the results of this investigation, there is no evidence of any tritium impact to the intermediate groundwater zone.

6.3.3 DISTRIBUTION

IN STATION SURFACE WATERTritium was not detected at concentrations greater than the LLD of 200 pCi/L in any of the six surface water samples collected.

6.3.4 DISTRIBUTION

IN STATION WATER- UNIT 2 PITTritium was detected in only one of the five water samples collected from the Unit 2 Pit drainage system at a concentration greater than the LLD of 200 pCi/L: Drainage Pipe - 1D at 227 +/- 126 pCi/L, located on the west side of the Unit 2 Pit, along the side of the power block (see Figure 4.2).

6.3.5 CONCEPTUAL

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

045136 (14) Clinton Power Station 41 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 The intermediate groundwater system discharges into Clinton Lake. Groundwater moving within the intermediate groundwater zone is separated from the regional bedrock aquifer zones by the Wedron Clay Till and several other fine-grained glacial deposits collectively exceeding 200 feet in thickn ess. As of the date of this report, no tritium has been detected above the LLD of 200 pCi/L in any of the intermediate

monitoring wells. This groundwater quality da ta further support the role of the Wedron Clay Till as an aquitard. As such, the focus of CRA's conceptual hydrogeologic model is the migration of groundwater and trit ium within the shallow groundwater.

The shallow groundwater near the PA flows toward and discharges into the Unit 2 Pit. The Unit 2 Pit is approximately 35 feet deep and extends below the water table. There is a storm water collection system in the base of the Unit 2 Pit. This drainage system is the

discharge point for all of the shallow ground water beneath the PA and adjacent support areas. The collected groundwater discharges along with any storm water that enters the Unit 2 Pit, into Clinton Lake under the Station's NPDES Outfall No. 010.

North of the PA, there is a hydrologic divi de in the shallow groundwater flow regime between the Unit 2 Pit and Clinton Lake. To the north of the divide, shallow groundwater discharges into Clinton Lake.

There are six surface water bodies at the Station. Two of the surface water bodies act as local sources of recharge for the shallow groundwater system. Groundwater discharges into four of the surface water bodies, as is described below.

The surface water elevations in the pr imary lagoon and secondary lagoon are approximately 9 feet higher than the ground water elevations measured in the closest shallow monitoring well, MW-CL-20S. This indicates that groundwater does not discharge to the lagoons and they likely act as local sources of recharge for the shallow groundwater zone.

North of the PA shallow groundwater discharges into Clinton Lake. There is no evidence of detectable concentrations of tritium within this groundwater flow path.

East of the PA shallow groundwater discharges into the aqueduct. There is no evidence of detectable concentrations of tritiu m within this groundwater flow path.

During the May 2006 monitoring event, the su rface water elevations in the sediment ponds were approximately 0.3 feet lower than the groundwater elevations measured in the closest shallow monitoring well. This in dicates that groundwater discharges to these 045136 (14) Clinton Power Station 42 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 surface water features. However, if the groundwater level drops more than 0.3 feet, the sediment ponds could act as local sources of recharge for the shallow groundwater system. To the west of the PA, the shallow groundwater flows west and discharges into Clinton Lake. There is no evidence of detectable concentrations of tritium within this

groundwater flow path.

Tritium concentrations slightly greater than the LLD of 200 pCi/L were detected in groundwater that flows towards and discharges into the Unit 2 Pit. If higher concentrations of tritium were noted in the groundwater, it is likely that the concentration of any tritium will decrease as it migrates slowly toward the Unit 2 Pit due to natural decay as well as dilution from unimpacted groundwater also discharging to the Unit 2 Pit. Specifically, tritium was detected at concentrations greater than the LLD in samples collected from MW-CL-13S, MW-CL-14S, MW-CL-21S, and MW-CL-22S. A drainage system installed in the base of the Unit 2 Pit collects this groundwater and discharges it to Clinton Lake. Water samples collected from the drainage system located within the Unit 2 Pit contained only one dete ction of tritium (of five samples collected) slightly greater than the LLD of 200 pCi/L.

045136 (14) Clinton Power Station 43 C ONESTOGA-R OVERS & A SSOCIATES 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 re lated to the Station operations, and based upon radionuclide analyses of groundwater sa mples, the primary constituent of concern (COC) is tritium. The discussions that follo w are restricted to the exposure pathways related to tritium.

Teledyne Brown reports all samples to their statistically derived Minimum Detectable Concentration (MDC) of 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 emi tting a low-energy beta particle that cannot penetrate deeply into tissue or travel far in air. A person's exposure to tritium is primarily through the ingestion of water (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 (14) Clinton Power Station 44 C ONESTOGA-R OVERS & A SSOCIATES Revision 1

7.2 BACKGROUND

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

7.2.1 GROUNDWATERTritium

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 6 Li (92.5 percent abundance) and 7 Li (7.5 percent abundance) present in crystalline rocks by neutrons produced by the radioactive decay of uranium and thorium. Lithogenic production of tritiu m is usually negligible compared to other sources due to the limited abundance of lit hium in rock. The lithogenic tritium is introduced directly to groundwater.

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

7.2.2 PRECIPITATION

DATAPrecipitation samples are routinely collected at stations around the world for the analysis of tritium and other radionuclides. Two publicly available databases that provided tritium concentrations in precipit ation are Global Network of Isotopes in Precipitation (GNIP) and USEPA's RadNet database. GNIP provides tritium precipitation concentration data for 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 concentratio ns peaked around 1963. This peak, which 045136 (14) Clinton Power Station 45 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 approached 10,000 pCi/L for some stations, coincided with the atmospheric testing of thermonuclear weapons. Tritium concentrat ions 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, MN) did not show the same trend, which can attributed to pre-1995 data handling procedures. The pre-1995 data were rounded to the nearest 100 pCi/L, which damped 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 a 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 th e 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 DATATritium 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 Rive r), Morris (Illinois River), Oregon (Rock River), and Zion (Lake Michigan). As is the case for the RadNet precipitation data, the pre-September 1995 Illinois surface water data was rounded to the nearest 100 pCi/L, creating a dampening of variances in the 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.

045136 (14) Clinton Power Station 46 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 The pre-operational REMP data indicate that out of 26 quarterly composite samples, tritium was detected only twice at concentrations of 330 pCi/L and 220 pCi/L. All other samples contained concentrations of trit ium less than the LLD, which ranged from 174 to 300 pCi/L.

The USEPA RadNet surface water data typi cally 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, the typical background data provided may be subject to measurement uncertainty of approximately 70 to 100 pCi/L.

7.2.4 DRINKING

WATER DATATritium concentrations in drinking water fr om 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 has dampened out variances due to rounding the data to the nearest 100 pCi/L. The post-1995 results show tritiu m concentrations in samples of drinking water were less than 100 pCi/L and less than the tritium concentrations found in

precipitation and surface water.

The pre-operational REMP data indicate that tritium was not detected in any

groundwater samples at the laboratory limit of detection ranging from 200 to 300 pCi/L.

7.2.5 EXPECTED

TRITIUM BACKGROUND FOR THE STATION As reported in the GNIP and RadNet databases, since 1980, tritium concentrations in U.S. Midwest precipitation has typically been less than 100 pCi/L. Additionally, since 1995, tritium concentrations reported in the RadNet database for Illinois surface water and groundwater, have typically been less than 100 pCi/L. Based on the 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 interval. Tritium concentrations in surface water and drinking water are expected to be comparable or less based on historical data and trends. 045136 (14) Clinton Power Station 47 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Concentrations in groundwater similar to surface water and drinking water are expected to be less than precipitation values. The lo wer groundwater concentrations are related to the age of the groundwater as compared to the half-life of tritium. Deep aquifers in proximity to crystalline basement rock, ho wever, can potentially show elevated concentrations of tritium due to lithogenic sources.

As was noted in Section 7.0, the analytical laboratory is reporting tritium results to a 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 Three potential exposure pathways were considered during the evaluation of tritium in groundwater.

groundwater migration off the Station Property to private and public groundwater users (drinking water exposure); groundwater migration off the Station Property to a surface water body (recreational exposure); and surface water migration (or groundwater migr ation) from the PA to the storm drain system in the Unit 2 Pit (Exelon Clinton worker exposure).

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

7.3.1 POTENTIAL

GROUNDWATER MIGRATION TO DRINKING WATER USERS OFF THE STATION PROPERTY The groundwater beneath the Station is not used as a potable resource for its operations.

The Station obtains its water from North Fo rk leg of Salt Creek. Shallow tritiated groundwater would migrate either to Clinton Lake or to the Unit 2 Pit. Also, the shallow groundwater occurs in the Wedron Cl ay Till, which is relatively impermeable 045136 (14) Clinton Power Station 48 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 and not used as a source of potable water.

Therefore, there is no complete exposure pathway for shallow groundwater ingestion.

While the intermediate groundwater may be viable as a potable groundwater source, the groundwater flow path is not consistent with groundwater migration from the Station.

The intermediate groundwater flows north beneath the PA and discharges into Clinton Lake. Intermediate groundwater has not been impacted by tritium. The lower potion of the Wedron Clay Till may isolate the intermediate groundwater from shallow tritiated groundwater. Therefore, there is no co mplete exposure pathway for intermediate groundwater ingestion.

Given the flow path towards Clinton Lake, th e absence of tritium in the intermediate groundwater zone, and the decreasing concentr ation of tritium with depth, there is no complete exposure pathway for ingestion of groundwater from deeper zones.

Accordingly, there is no complete exposure pathway from groundwater in the shallow, intermediate or deep groundwater to drinki ng water users off the Station property, and there is no current risk of exposure associated with groundwater ingestion.

7.3.2 POTENTIAL

GROUNDWATER MIGRATION TO SURFACE WATER USERS OFF THE STATION PROPERTY Under this potential exposure pathway, grou ndwater migrates off the Station Property to Clinton Lake.

Tritium has not been detected at concentrat ions greater than the LLD of 200 pCi/L in the intermediate groundwater zone. The concentrations of tritium in shallow groundwater are only slightly greater than the LLD of 200 pCi/L and are orders of magnitude less than the USEPA drinking water standard of 20,000 pCi/L. Furthermore, one out of five water samples collected from the Unit 2 Pi t drainage system contained tritium at a concentration that was only slightly greater than the LLD. Therefore, although this

migration pathway is potentially complete, there is no current risk of exposure associated with groundwater migration to surface water off the Station property.

045136 (14) Clinton Power Station 49 C ONESTOGA-R OVERS & A SSOCIATES Revision 1

7.3.3 POTENTIAL

GROUNDWATER MIGRATION TO SURFACE WATER ON THE STATION PROPERTY Under this potential exposure pathway, groundwater containing tritium would have discharged to surface water located on Site such as the sediment ponds, the primary lagoon, the secondary lagoon or the aqueduct.

The surface water elevations in the pr imary lagoon and secondary lagoon are approximately 9 feet higher than the ground water elevations measured in the closest shallow monitoring well, MW-CL-20S. This indicates that there is no potential for groundwater to discharge into the primar y lagoon, the secondary lagoon or the aqueduct.

The surface water elevation in the sediment ponds is 0.3 feet lower than the water table.

Therefore, there is a potential groundwater to surface migration in this area of the Site. However, the concentrations of tritium in shallow groundwater are orders of magnitude below the USEPA drinking water standard of 20,000 pCi/L.

The shallow groundwater unit beneath most of the Station discharges into the Unit 2 Pit. The Unit 2 Pit is drained by a passive drainag e system that in turn discharges to Clinton Lake via a drainage pipe that runs under the Reactor Building and to the Lake.

Therefore, there is a potential groundwater to surface water pathway in this area of the Station. However, the concentrations of tritium in shallow groundwater are orders of magnitude lower than the USEPA drinking water standard of 20,000 pCi/L.

Therefore, although this potential exposure pathway is partially complete, there is no current risk of exposure associated with groundwater migration to surface water on the Station property.

7.4

SUMMARY

OF POTENTIAL TRITIUM EXPOSURE PATHWAYS In summary, there are three potential exposure pathways for tritium originating in or adjacent to the PA:

potential groundwater migration off the St ation Property to private and public groundwater users; potential groundwater migration off the Station Property to a surface water body; and 045136 (14) Clinton Power Station 50 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 potential groundwater migration from the PA to surface water bodies on Station Property.

Based upon the groundwater, surface water, and Unit 2 Pit 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 US EPA drinking water standards (20,000 pCi/L).

7.5 OTHER

RADIONUCLIDES Target radionuclides were not detected at concentrations greater than their respective LLD in any of the groundwater, surface water, or Unit 2 Pit 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) coul d be definitively evaluated as being naturally occurring due to the lack of presence of other radionuclides which would otherwise indicate the potential of production from the Station.

045136 (14) Clinton Power Station 51 C ONESTOGA-R OVERS & A SSOCIATES Revision 1

8.0 CONCLUSION

S Based on this hydrogeologic investigation, CRA concludes:

Groundwater Flow The shallow groundwater beneath the Station primarily flows radially toward the Unit 2 Pit. The excavation is approximately 35 feet deep and contains a storm water collection system that drains to Clinton Lake. The intermediate groundwater flows west and discharges into Clinton Lake. The

groundwater elevation within the intermediate zone is below the Unit 2 Pit and the foundation of the Containment Building.

Groundwater Quality Tritium was not detected in groundwater at concentrations greater than the USEPA drinking water standard of 20,000 pCi/L. Tritium was not detected at concentrations greater than the LLD of 200 pCi/L in 13 of the 17 groundwater samples collected as part of this investigation. Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than their respective LLDs in any of the 17

groundwater samples collected as part of this investigation. Strontium-89/90 was not detected at a concentration greater than the LLD of 2.0 pCi/L in any of the 17 groundwater samples collected as part of this investigation.

Surface Water Quality Tritium was not detected in surface water at concentrations greater than the USEPA drinking water standard of 20,000 pCi/L. Tritium was not detected at concentrations greater than the LLD of 200 pCi/L in any

of the six surface water samples collect ed as part of this investigation. Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than their respective LLDs in any of the six surface water samples collected as part of this investigation.

045136 (14) Clinton Power Station 52 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Strontium-89/90 was not detected at a concentration greater than the LLD of 2.0 pCi/L in any of the six surface water samples collected as part of this investigation.

Unit 2 Pit Water Quality Tritium was not detected in Unit 2 Pit water samples at concentrations greater than

the USEPA drinking water standard of 20,000 pCi/L. Tritium was not detected at concentrations greater than the LLD of 200 pCi/L in four

of the five Unit 2 Pit water samples colle cted as part of this investigation. Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than their respective LLDs in any of the five Unit 2 Pit water samples collected as part of this investigation.

AFE-Clinton Cycled Condensate System Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than their respective LLDs in any of the groundwater samples collected from the monitoring wells in the vicinity of AFE-Clinton-1. Strontium-89/90 was not detected at a concentration 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-Clinton-1. Tritium was detected at a concentration above the LLD (200 pCi/L) in the groundwater samples collected from MW-CL-14S (201 +/- 107 pCi/L) and MW-CL-21S (545 +/- 138 pCi/L), which are downgradient of the Cycle Condensate System.

Tritium was also detected in the groundwater sample collected from MW-CL-13S, which is upgradient of the Cycled Condensate System, at a concentration of 230 +/- 114 pCi/L.

AFE-Clinton Reactor Core Isolation System Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than their respective LLDs in any of the

groundwater samples collected from the monitoring wells in the vicinity of AFE-Clinton-2.

045136 (14) Clinton Power Station 53 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Strontium-89/90 was not detected at a concentration 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-Clinton-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 the Reactor Core Isolation System, except the trace co ncentration in the duplicate groundwater sample collected from MW-CL-22S (278 +/- 122 pCi/L).

AFE-Clinton Circulating Water System Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than their respective LLDs in any of the groundwater samples collected from the monitoring wells in the vicinity of AFE-Clinton-3. Strontium-89/90 was not detected at a concentration 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-Clinton-3. 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 the Circulating Water System, except the trace concentrat ion in the groundwater sample collected from MW-CL-14S (201 +/- 107 pCi/L). Gamma-emitting radionuclides, tritium, and strontium-89/90 were not detected in the surface water sample collected and analyzed from the aqueduct.

AFE-Clinton North Power Block Discharge - Radwaste and Turbine Building Sumps Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than their respective LLDs in any of the

groundwater samples collected from the monitoring wells in the vicinity of AFE-Clinton-4. Strontium-89/90 was not detected at a concentration 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-Clinton-4. Tritium was not detected at concentrations greater than the LLD of 200 pCi/L in six of the seven groundwater samples collected from monitoring wells near

AFE-Clinton-4. A trace concentration of tritium (201 +/- 107 pCi/L) was detected in groundwater samples from the seventh monitoring well.

045136 (14) Clinton Power Station 54 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 AFE-Clinton South Power Block Discharge -

Control Building/Diesel Generator Building Sumps Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than their respective LLDs in any of the groundwater samples collected from the monitoring wells in the vicinity of AFE-Clinton-5. Strontium-89/90 was not detected at a concentration 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-Clinton-5. 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 the South Power Block Discharge, except the trace concentration in the duplicate groundwater sample collected from MW-CL-22S (278 +/- 122 pCi/L). Gamma-emitting radionuclides, tritium, and strontium-89/90 were not detected in the surface water sample collected and analyzed from Clinton Lake.

AFE-Clinton Shutdown Service Water System Gamma-emitting radionuclides associated wi th licensed plant operations were not detected at concentrations greater than their respective LLDs in any of the groundwater samples collected from the four monitoring wells in the vicinity of AFE-Clinton-6. Strontium-89/90 was not detected at a concentration 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-Clinton-6. 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 the Shutdown Service Water System, except the trace co ncentration in the duplicate groundwater sample collected from MW-CL-22S (278 +/- 122 pCi/L). Gamma-emitting radionuclides, tritium, and strontium-89/90 were not detected in the surface water sample collected and analyzed from Clinton Lake.

045136 (14) Clinton Power Station 55 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 Potential Receptors Based on the results of this investigation 1, 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. Based on the results of this investigation, there are no known active releases into the groundwater at the Station.

1 Using the LLD specified in this HIR.

045136 (14) Clinton Power Station 56 C ONESTOGA-R OVERS & A SSOCIATES 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 hydrogeologi c investigation, there are no data gaps remaining to support CRA's conclusions regarding the characterization of the groundwater regime and potential impact s from radionuclides at the Station.

9.2 GROUNDWATER

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

045136 (14) Clinton Power Station 57 C ONESTOGA-R OVERS & A SSOCIATES Revision 1

10.0 REFERENCES

CITED CH2M Hill, 2003a. Draft Site Redress Plan for Exelon Early Site Permit.

CH2M Hill, 2003b. Draft Emergency Pl an for Exelon Early Site Permit.

CH2M Hill, 2003c. Draft Site Safety Analysis Report for Exelon Early Site Permit.

CH2M Hill, 2003d. Draft Environmental Re port for Exelon Early Site Permit. Clinton Power Station, 1987. Preoperational Radiological Environmental Monitoring Report (Pre-Operational REMP), 1980 to 1987. Clinton Power Station, 1992. 10CFR 50.75(g) Reactor Core Isolation Cooling Tank Overflow Report. Clinton Power Station. Annual Radiolog ical Environmental Monitoring Program (REMP) Report, 1987 to 2000. Clinton Power Station. Annual Radiological Environmental Operating Report, 2001 to 2004. Conestoga-Rovers & Associates, Inc., May 2006. Hydrogeologic Investigation Work Plan, Fleetwide Tritium Assessment, C linton Generating Station, De Witt County, Illinois, prepared for Exelon Generation Company, LLC. Correspondence May 5, 2006. Email from Kevin Hersey (Exelon) forwarded by Scott Sklenar (Exelon) to Phil Harvey (CRA).

Eisenbud, 1987. Environmental Radioactivity, M. Eienbud, 1987 (EI87). Illinois Power, 1982. Clinton Power Station Environmental Report Operating License Stage, Supplement 3. Illinois Power, 2001. Clinton Power Station Updated Final Safety Analysis Report, Rev. 9. Illinois State Geological Survey, Stack-Unit Ma pping of Geologic Materials in Illinois to a Depth of 15 Meters, Circular 542, 1988.

McLaren and Hart, March 1999 (1999a). Facility Assessment Report. McLaren and Hart, May 1999 (1999b). Baseline Soil and Groundwater Investigation Report. Puls, R.W., and M.J. Barcelona, April 1996. Low-Flow (Minimal Drawdown) Ground-Water Sampling Procedures, EPA Ground Water Issue , EPA/540/S-92/005, R. S. Kerr Environmenta l Research Center, United States Environmental Protection Agency, Ada, Oklahoma.

045136 (14) Clinton Power Station 58 C ONESTOGA-R OVERS & A SSOCIATES Revision 1 USEPA, May 1996. "Soil Screening Guidance Technical Background Document", Office of Solid Waste and Emergency Response, Washington, DC EPA/540/R95/128. USGS, 1990. U.S. Geological Survey, GIS Layer of National Landcover Data Set for Central Illinois. USGS, 1992. U.S. Geological Survey, Topo graphic Map, Clinton 7.5-minute USGS Quadrangle.

045136 (14) Clinton Power Station 59 C ONESTOGA-R OVERS & A SSOCIATES SITESTATIONSOURCE: USGS QUADRANGLE MAP; 05000ft2500CLINTON MOSAIC, ILLINOIS (1992)figure 1.1SITE LOCATION MAPCLINTON POWER STATIONEXELON GENERATION COMPANY, LLC45136-22(014)GN-WA001 JUL 12/2006 figure 2.2REGIONAL STRATIGRAPHIC CROSS-SECTIONCLINTON POWER STATIONEXELON GENERATION COMPANY, LLC45136-22(014)GN-WA006 JUL 12/2006SOURCE: CH2M HILL 0 735 725 715 705 695 685 675 665ELEVATION (ft. AMSL) 735 725 715 705 695 685 675 665ELEVATION (ft. AMSL)DISTANCE (ft.)MW-CL-18S/IMW-CL-16SMW-CL-15S/IMW-CL-20SFENCERAILROADROADROADCLINTON LAKEMWPHWHSE #2WHSE #3 ANORTH A'SOUTHAQUEDUCT 1500 3000ROADROADROADROADMW-CL-15SMW-CL-15IMW-CL-18SMW-CL-18I 500 1000 2000 2500 712'FOUNDATIONBUILDINGUNIT 2 PITMW-CL-22SROADScale:Source

Reference:

Project Manager:Reviewed By:Project N:

oDate:Report N: oDrawing N o:THIS BAR MEASURES 1" ON ORIGINAL. ADJUST SCALE ACCORDINGLY.SCALE VERIFICATIONEXELON GENERATION COMPANY, LLCCLINTON, ILLINOISGEOLOGIC CROSS-SECTION A-A'CLINTON POWER STATIONFLEETWIDE ASSESSMENTS. QUIGLEYA. DEALAUGUST 200645136-22 014figure 5.245136-22(014)GN-WA020 AUG 23/2006AS SHOWNMW-CL-16SCLAY SANDWEDRON FORMATIONCONCRETESILTPOTENTIOMETRIC SURFACEINTERMEDIATE GROUNDWATERPOTENTIOMETRIC SURFACEREVISION 1 MW-CL-18S/IMW-CL-12IMW-CL-19SMW-CL-13S/IMWPH 0 735 725 715 705 695 685 675 665ELEVATION (ft. AMSL) 735 725 715 705 695 685 675 665ELEVATION (ft. AMSL)DISTANCE (ft.)

1500 500 1000 B'EAST BWESTROADMW-CL-13SMW-CL-18SMW-CL-13IMW-CL-18IBLDG.MW-3MW-2ROADFENCEFENCEFENCE 2000 2500 712'FOUNDATIONBUILDINGScale:Source

Reference:

Project Manager:Reviewed By:Project N:

oDate:Report N: oDrawing N o:THIS BAR MEASURES 1" ON ORIGINAL. ADJUST SCALE ACCORDINGLY.SCALE VERIFICATIONEXELON GENERATION COMPANY, LLCCLINTON, ILLINOISGEOLOGIC CROSS-SECTION B-B'CLINTON POWER STATIONFLEETWIDE ASSESSMENTS. QUIGLEYA. DEALJULY 200645136-22 014figure 5.345136-22(014)GN-WA020 AUG 23/2006AS SHOWNMW-CL-12I SANDWEDRON FORMATIONPOTENTIOMETRIC SURFACEINTERMEDIATE GROUNDWATERPOTENTIOMETRIC SURFACEREVISION 1 0 735 725 715 705 695 685 675 665ELEVATION (ft. AMSL) 735 725 715 705 695 685 675 665ELEVATION (ft. AMSL)DISTANCE (ft.)

1500 500 1000 C'SOUTH CNORTHMW-CL-13S/IMW-CL-13SMW-CL-13IMW-CL-15S/IWHSE #2MW-CL-15SMW-CL-15IMW-CL-14SROADRAD WASTE BUILDINGROADROADUNIT 2 PITScale:Source

Reference:

Project Manager:Reviewed By:Project N:

oDate:Report N: oDrawing N o:THIS BAR MEASURES 1" ON ORIGINAL. ADJUST SCALE ACCORDINGLY.SCALE VERIFICATIONEXELON GENERATION COMPANY, LLCCLINTON, ILLINOISGEOLOGIC CROSS-SECTION C-C'CLINTON POWER STATIONFLEETWIDE ASSESSMENTS. QUIGLEYA. DEALAUGUST 200645136-22 014figure 5.445136-22(014)GN-WA020 AUG 23/2006AS SHOWNMW-CL-12ICLAY SANDWEDRON FORMATIONCONCRETESILTPOTENTIOMETRIC SURFACEINTERMEDIATE GROUNDWATERPOTENTIOMETRIC SURFACEGRAVELREVISION 1

Page 1 of 1 TABLE 5.2 ANALYTICAL RESULTS

SUMMARY

- TRITIUM IN GROUNDWATER FLEETWIDE ASSESSMENT CLINTON POWER STATION CLINTON, ILLINOIS Sam ple LocationSam p le Identi ficationQC Sam p l e Sam ple DateTritium (p Ci/L)R esult ErrorB-3WG-CL-MW-CL-B-3-052406-JKAD-165/24/2006ND (200) -MW-1WG-CL-MW-CL-1-052506-JKAD-245/25/2006ND (200) -

MW-2WG-CL-MW-CL-2-052506-JKAD-235/25/2006ND (200) -

MW-CL-12IWG-CL-MW-CL-12S-052306-JKAD-095/23/2006ND (200) -

MW-CL-13IWG-CL-MW-CL-13I-052306-JKAD-055/23/2006ND (200) -

MW-CL-13SWG-CL-MW-CL-13S-052306-JKAD-065/23/2006230 +/-114 MW-CL-14SWG-CL-MW-CL-14S-052406-JKAD-145/24/2006201 +/-107 MW-CL-15IWG-CL-MW-CL-15I-052306-JKAD-045/23/2006ND (200) -

MW-CL-15SWG-CL-MW-CL-15S-052306-JKAD-035/23/2006ND (200) -

MW-CL-16SWG-CL-MW-CL-16S-052406-JKAD-135/24/2006ND (200) -

MW-CL-17SWG-CL-MW-CL-17S-052506-JKAD-155/25/2006ND (200) -

MW-CL-18IWG-CL-MW-CL-18I-052306-JKAD-125/23/2006ND (200) -

MW-CL-18SWG-CL-MW-CL-18S-052306-JKAD-115/23/2006ND (200) -

MW-CL-19SWG-CL-MW-CL-19S-052306-JKAD-075/23/2006ND (200) -

MW-CL-19SWG-CL-MW-CL-19S-052306-JKAD-08Duplicate (07)5/23/2006ND (200) -

MW-CL-20SWG-CL-MW-CL-20S-052306-JKAD-025/23/2006ND (200) -

MW-CL-21SWG-CL-MW-CL-21S-080406-JL-1008/4/2006545 +/-138 MW-CL-22SWG-CL-MW-CL-22S-080406-JL-1028/4/2006ND (200) -

MW-CL-22SWG-CL-MW-CL-22S-080406-JL-103Duplicate (102)8/4/2006278 +/-122 Notes: Samples analyzed by: Teledyne Brown Engineering, Inc.

QC - Quality Control

ND ( ) - Non-detect; value in parentheses is the LLD.

LLD - Lower limit of detection.

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

CRA 045136 (14) Clinton Power Station q012AI-XT2-WG WS W-0506 0606 0806-37-TH 8/11/2006 Revision 1 TABLE 5.3 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER FLEETWIDE ASSESSMENT CLINTON POWER STATION CLINTON, ILLINOIS Page 1 of 5Sample Location:B-3B-3MW-1MW-1MW-2MW-2MW-CL-12IMW-CL-12ISample Identification:WG-CL-MW-CL-B-3-052406-JKAD-16ResultWG-CL-MW-CL-1-052506-JKAD-24ResultWG-CL-MW-CL-2-052506-JKAD-23ResultWG-CL-MW-CL-12S-052306-JKAD-09ResultSample Date:5/24/2006Error5/25/2006Error5/25/2006Error5/23/2006Error Units Target RadionuclidesBarium-140pCi/LND (60) -ND (60) -ND (60) -ND (60) -Cesium-134pCi/LND (10) -ND (10) -ND (10) -ND (10) -

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

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

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

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

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

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

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

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

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

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

Non-Target Radionuclides (1)Potassium-40 pCi/L98.84 +/-40.79RNI-RNI-RNI-Thorium-228 pCi/LRNI-RNI-RNI-RNI-Notes: Samples analyzed by: Teledyne Brown (1) - These non-targeted radionuclides are included

in this table but excluded from the 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.

RNI - Radionuclide Not Identified during analysis.

ND ( ) - Non-detect; 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.

CRA 045136 (14) Clinton Power Station q012AI-XT2-WG WS W-0506 0606 0806-37-TH 8/10/2006 Revision 1 TABLE 5.3 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER FLEETWIDE ASSESSMENT CLINTON POWER STATION CLINTON, ILLINOIS Page 2 of 5 Sample Location:

Sample Identification:

Sample Date:

Units Target RadionuclidesBarium-140pCi/LCesium-134pCi/L Cesium-137pCi/L Cobalt-58pCi/L Cobalt-60pCi/L Iron-59pCi/L Lanthanum-140pCi/L Manganese-54pCi/L Niobium-95pCi/L Strontium-89/90 (Total)pCi/L Zinc-65pCi/L Zirconium-95pCi/L Non-Target Radionuclides (1)Potassium-40 pCi/L Thorium-228 pCi/L Notes: Samples analyzed by: Teledyne Brown (1) - These non-targeted radionuclides are included

in this table but excluded from the 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.

RNI - Radionuclide Not Identified during analysis.

ND ( ) - Non-detect; 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. MW-CL-13IMW-CL-13IMW-CL-13SMW-CL-13SMW-CL-14SMW-CL-14SMW-CL-15IMW-CL-15IWG-CL-MW-CL-13I-052306-JKAD-05ResultWG-CL-MW-CL-13S-052306-JKAD-06ResultWG-CL-MW-CL-14S-052406-JKAD-14ResultWG-CL-MW-CL-15I-052306-JKAD-04Result5/23/2006Error5/23/2006Error5/24/2006Error5/23/2006ErrorND (60) -ND (60) -ND (60) -ND (60) -

ND (10) -ND (10) -ND (10) U*-ND (10) U*-

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

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

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

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

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

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

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

ND (10) -ND (10) -ND (10) -ND (10) -RNI-RNI-RNI-RNI-RNI-RNI-RNI-RNI-CRA 045136 (14) Clinton Power Station q012AI-XT2-WG WS W-0506 0606 0806-37-TH 8/10/2006 Revision 1 TABLE 5.3 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER FLEETWIDE ASSESSMENT CLINTON POWER STATION CLINTON, ILLINOIS Page 3 of 5 Sample Location:

Sample Identification:

Sample Date:

Units Target RadionuclidesBarium-140pCi/LCesium-134pCi/L Cesium-137pCi/L Cobalt-58pCi/L Cobalt-60pCi/L Iron-59pCi/L Lanthanum-140pCi/L Manganese-54pCi/L Niobium-95pCi/L Strontium-89/90 (Total)pCi/L Zinc-65pCi/L Zirconium-95pCi/L Non-Target Radionuclides (1)Potassium-40 pCi/L Thorium-228 pCi/L Notes: Samples analyzed by: Teledyne Brown (1) - These non-targeted radionuclides are included

in this table but excluded from the 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.

RNI - Radionuclide Not Identified during analysis.

ND ( ) - Non-detect; 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. MW-CL-15SMW-CL-15SMW-CL-16SMW-CL-16SMW-CL-17SMW-CL-17SMW-CL-18IMW-CL-18IWG-CL-MW-CL-15S-052306-JKAD-03ResultWG-CL-MW-CL-16S-052406-JKAD-13ResultWG-CL-MW-CL-17S-052506-JKAD-15ResultWG-CL-MW-CL-18I-052306-JKAD-12Result5/23/2006Error5/24/2006Error5/25/2006Error5/23/2006ErrorND (60) -ND (60) -ND (60) -ND (60) -ND (10) U*-ND (10) -ND (10) -ND (10) U*-ND (18) -ND (18) -ND (18) -ND (18) -

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

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

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

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

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

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

ND (10) -ND (10) -ND (10) -ND (10) -RNI-RNI-RNI-RNI-RNI-RNI-RNI-RNI-CRA 045136 (14) Clinton Power Station q012AI-XT2-WG WS W-0506 0606 0806-37-TH 8/10/2006 Revision 1 TABLE 5.3 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER FLEETWIDE ASSESSMENT CLINTON POWER STATION CLINTON, ILLINOIS Page 4 of 5 Sample Location:

Sample Identification:

Sample Date:

Units Target RadionuclidesBarium-140pCi/LCesium-134pCi/L Cesium-137pCi/L Cobalt-58pCi/L Cobalt-60pCi/L Iron-59pCi/L Lanthanum-140pCi/L Manganese-54pCi/L Niobium-95pCi/L Strontium-89/90 (Total)pCi/L Zinc-65pCi/L Zirconium-95pCi/L Non-Target Radionuclides (1)Potassium-40 pCi/L Thorium-228 pCi/L Notes: Samples analyzed by: Teledyne Brown (1) - These non-targeted radionuclides are included

in this table but excluded from the 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.

RNI - Radionuclide Not Identified during analysis.

ND ( ) - Non-detect; 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. MW-CL-18SMW-CL-18SMW-CL-19SMW-CL-19SMW-CL-19SMW-CL-19SMW-CL-20SMW-CL-20SWG-CL-MW-CL-18S-052306-JKAD-11ResultWG-CL-MW-CL-19S-052306-JKAD-07ResultWG-CL-MW-CL-19S-052306-JKAD-08ResultWG-CL-MW-CL-20S-052306-JKAD-02Result5/23/2006Error5/23/2006Error5/23/2006Error5/23/2006Error DuplicateND (60) -ND (60) -ND (60) -ND (60) -

ND (10) -ND (10) -ND (10) U*-ND (10) -

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

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

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

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

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

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

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

ND (10) -ND (10) -ND (10) -ND (10) -RNI-RNI-RNI-RNI-RNI-RNI-RNI-RNI-CRA 045136 (14) Clinton Power Station q012AI-XT2-WG WS W-0506 0606 0806-37-TH 8/10/2006 Revision 1 TABLE 5.3 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN GROUNDWATER FLEETWIDE ASSESSMENT CLINTON POWER STATION CLINTON, ILLINOIS Page 5 of 5 Sample Location:

Sample Identification:

Sample Date:

Units Target RadionuclidesBarium-140pCi/LCesium-134pCi/L Cesium-137pCi/L Cobalt-58pCi/L Cobalt-60pCi/L Iron-59pCi/L Lanthanum-140pCi/L Manganese-54pCi/L Niobium-95pCi/L Strontium-89/90 (Total)pCi/L Zinc-65pCi/L Zirconium-95pCi/L Non-Target Radionuclides (1)Potassium-40 pCi/L Thorium-228 pCi/L Notes: Samples analyzed by: Teledyne Brown (1) - These non-targeted radionuclides are included

in this table but excluded from the 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.

RNI - Radionuclide Not Identified during analysis.

ND ( ) - Non-detect; 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. MW-CL-21SMW-CL-21SMW-CL-22SMW-CL-22SMW-CL-22SMW-CL-22SWG-CL-MW-CL-21S-080406-JL-100ResultWG-CL-MW-CL-22S-080406-JL-102ResultWG-CL-MW-CL-22S-080406-JL-103Result8/4/2006Error8/4/2006Error8/4/2006Error DuplicateND (60) -ND (60) -ND (60) -ND (10) U*-ND (10) U*-ND (10) -ND (18) -ND (18) -ND (18) -

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

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

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

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

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

ND (10) -ND (10) -ND (10) -ND (2) -ND (2) -ND (2) -ND (30) U*-ND (30) U*-ND (30) -ND (10) -ND (10) -ND (10) -RNI-114.3 +/-39.13RNI-6.64 +/-3.1349.487 +/-5.377RNI-CRA 045136 (14) Clinton Power Station q012AI-XT2-WG WS W-0506 0606 0806-37-TH 8/10/2006 Revision 1

TABLE 5.5 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN SURFACE WATER FLEETWIDE ASSESSMENT CLINTON POWER STATION CLINTON, ILLINOIS Page 1 of 2Sample Location:SW-CL-1SW-CL-1SW-CL-2SW-CL-2SW-CL-2SW-CL-2SW-CL-4SW-CL-4Sample Identification:WS-CL-SW-CL-1-052306-JKAD-10ResultWS-CL-SW-CL-2-052406-JKAD-17ResultWS-CL-SW-CL-3-052406-JKAD-18ResultWS-CL-SW-CL-4-052406-JKAD-19ResultSample Date:5/23/2006Error5/24/2006Error5/24/2006Error5/24/2006Error Duplicate Units Target RadionuclidesBarium-140pCi/LND (60) -ND (60) -ND (60) -ND (60) -Cesium-134pCi/LND (10) -ND (10) U*-ND (10) -ND (10) -

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

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

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

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

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

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

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

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

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

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

Notes: Samples analyzed by: Teledyne Brown

ND ( ) - Non-detect; 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.

CRA 045136 (14) Clinton Power Station q008AI-XT2-WG WS-0506 Groundwater Surface Water-37-TH 7/12/2006 Revision 1 TABLE 5.5 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN SURFACE WATER FLEETWIDE ASSESSMENT CLINTON POWER STATION CLINTON, ILLINOIS Page 2 of 2 Sample Location:

Sample Identification:

Sample Date:

Units Target RadionuclidesBarium-140pCi/LCesium-134pCi/L Cesium-137pCi/L Cobalt-58pCi/L Cobalt-60pCi/L Iron-59pCi/L Lanthanum-140pCi/L Manganese-54pCi/L Niobium-95pCi/L Strontium-89/90 (Total)pCi/L Zinc-65pCi/L Zirconium-95pCi/L Notes: Samples analyzed by: Teledyne Brown

ND ( ) - Non-detect; 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. SW-CL-5SW-CL-5SW-CL-6SW-CL-6SW-CL-7SW-CL-7WS-CL-SW-CL-5-052406-JKAD-20ResultWS-CL-SW-CL-6-052406-JKAD-21ResultWS-CL-SW-CL-7-052406-JKAD-22Result5/24/2006Error5/24/2006Error5/24/2006ErrorND (60) -ND (60) -ND (60) -

ND (10) -ND (10) -ND (10) -

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

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

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

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

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

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

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

ND (10) -ND (10) -ND (10) -

CRA 045136 (14) Clinton Power Station q008AI-XT2-WG WS-0506 Groundwater Surface Water-37-TH 7/12/2006 Revision 1 Page 1 of 1 TABLE 5.6 ANALYTICAL RESULTS

SUMMARY

- TRITIUM IN WATER FLEETWIDE ASSESSMENT CLINTON POWER STATION CLINTON, ILLINOIS Sam ple LocationSam p le Identi f icatio n Sam ple DateTritium (p Ci/L)R esult Erro rAboveground Pipe - 1A1A 13576/27/2006ND (200) -Aboveground Pipe - 1B1B 14026/27/2006ND (200) -

Aboveground Pipe - 1E1E 14276/27/2006ND (200) -

Drainage Pipe - 1D1D 14206/27/2006227 +/-126 Flushmount Collection - 1C1C 14126/27/2006ND (200) -

Notes: Samples analyzed by: Teledyne Brown Engineering, Inc.

ND ( ) - Non-detect; value in parentheses is the LLD.

LLD - Lower limit of detection.

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

CRA 045136 (14) Clinton Power Station q012AI-XT2-WG WS W-0506 0606 0806-37-TH 8/11/2006 Revision 1 TABLE 5.7 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN WATER FLEETWIDE ASSESSMENT CLINTON POWER STATION CLINTON, ILLINOIS Page 1 of 2Sample Location:Aboveground Pipe - 1AAboveground Pipe - 1AAboveground Pipe - 1BAboveground Pipe - 1BAboveground Pipe - 1EAboveground Pipe - 1EDrainage Pipe - 1DDrainage Pipe - 1DSample Identification:1A 1357Result1B 1402Result1E 1427Result1D 1420ResultSample Date:6/27/2006Error6/27/2006Error6/27/2006Error6/27/2006Error Units Target RadionuclidesBarium-140pCi/LND (74.68) *-ND (63.46) *-ND (77.95) *-ND (84.29) *-Cesium-134pCi/LND (10) U*-ND (10) -ND (10) -ND (10) -

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

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

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

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

Lanthanum-140pCi/LND (24.82) *-ND (22.88) *-ND (26.87) *-ND (27.51) *-

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

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

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

Zirconium-95pCi/LND (11.91) *-ND (10) -ND (11.85) *-ND (12.96) *-

Non-Target Radionuclides (1)Beryllium-7pCi/L207.2 +/-39.48RNI-194 +/-41.91RNI-Potassium-40pCi/L904.6 +/-70.67RNI-186.6 +/-58.94230.8 +/-72.62 Radium-226 pCi/L146.8 +/-86.08RNI-RNI-RNI-Thorium-228 pCi/L54.04 +/-5.498RNI-RNI-RNI-Thorium-232 pCi/L47.55 +/-8.946RNI-RNI-RNI-Notes: Samples analyzed by: Teledyne Brown (1) - These non-targeted radionuclides are included

in this table but excluded from the 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.

RNI - Radionuclide Not Identified during analysis.

ND ( ) - Non-detect; value in parentheses is the LLD.

LLD - Lower limit of detection.

• - Non-detect at the value in the parentheses.

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.

CRA 045136 (14) Clinton Power Station q012AI-XT2-WG WS W-0506 0606 0806-37-TH 8/10/2006 Revision 1 TABLE 5.7 ANALYTICAL RESULTS

SUMMARY

- RADIONUCLIDES IN WATER FLEETWIDE ASSESSMENT CLINTON POWER STATION CLINTON, ILLINOIS Page 2 of 2 Sample Location:

Sample Identification:

Sample Date:

Units Target RadionuclidesBarium-140pCi/LCesium-134pCi/L Cesium-137pCi/L Cobalt-58pCi/L Cobalt-60pCi/L Iron-59pCi/L Lanthanum-140pCi/L Manganese-54pCi/L Niobium-95pCi/L Zinc-65pCi/L Zirconium-95pCi/L Non-Target Radionuclides (1)Beryllium-7pCi/LPotassium-40pCi/L

Radium-226 pCi/L

Thorium-228 pCi/L

Thorium-232 pCi/L Notes: Samples analyzed by: Teledyne Brown (1) - These non-targeted radionuclides are included

in this table but excluded from the 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.

RNI - Radionuclide Not Identified during analysis.

ND ( ) - Non-detect; value in parentheses is the LLD.

LLD - Lower limit of detection.

• - Non-detect at the value in the parentheses.

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. Flushmount Collection - 1CFlushmount Collection - 1C1C 1412Result6/27/2006ErrorND (93.61) *-ND (10) U*-ND (18) -

ND (15) -

ND (15) -

ND (30) -ND (29.97) *-ND (15) -

ND (10) -ND (30) U*-ND (14.09) *-

72.52 +/-44.77

737.6 +/-81.19

273.6 +/-110.7

65.71 +/-7.524

69.32 +/-17.11 CRA 045136 (14) Clinton Power Station q012AI-XT2-WG WS W-0506 0606 0806-37-TH 8/10/2006 Revision 1 Revision 1 045136 (14) Clinton Power Station APPENDIX A MONITORING WELL LOGS 14 18 14 18 19 21 38 27 17 30 ASPHALT GRAVEL No sample vacuum excavated to 12 ft BGS CL-CLAY, brownish-gray, silty clay, compact, stiff, dry, well graded, coarse to fine riverbed-type gravel mixed throughout- very stiff at 18.0ft BGS- as above with traces of fine gravel sand, becomes hard at 24.0ft BGS Concrete 2" 0 PVC/Well Casing 8" 0 Borehole

/Bentonite 731.27 731.02 719.52'N' VALUE (OVERBURDEN)

Page 1 of 2NUMBERINTERVAL SAMPLEREC (%)MW-CL-12I STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

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

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 1, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: D. NEWTONOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well GROUND SURFACE TOP OF CASING ELEV.ft AMSL 731.52 730.99 22 14 25 CH-CLAY, high plasticity, greenish-blue, dry CL-CLAY, some silt, grayish, small lense of coarse gravels, moist to wet, fine to coarse grained sands- gray clay, compact, fines at 50.0ft BGS END OF BOREHOLE @ 57.0ft BGS Sand 2" 0 PVC/Well Screen WELL DETAILS Screened interval:

684.52 to 674.52ft AMSL

47.00 to 57.00ft BGS

Length: 10ft

Diameter: 2in

Slot Size: #10

Sand Pack:

686.52 to 674.52ft AMSL

45.00 to 57.00ft BGS

Material: #30 Sand 685.02 682.52 674.52'N' VALUE (OVERBURDEN)

Page 2 of 2NUMBERINTERVAL SAMPLEREC (%)MW-CL-12I STRATIGRAPHIC AND INSTRUMENTATION LOG 42 44 46 48 50 52 54 56 58 60 62 64 66 68 70 72 74 76 78 DEPTH ft BGS PROJECT NAME: CLINTON POWER STATION PROJECT NUMBER: 45136-22

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 1, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: D. NEWTONOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well ELEV.ft AMSL 7 42 40 30 22 21 25 32 36 NO SOIL SAMPLING, vacuum excavated to 12 ft BGS (note: spoils appear to be hard/silty clay)SM-SAND, silty sand, light brown, saturated- dry friable, compact at 15.0ft BGS SM-SAND, fine grained, some silt, little rounded gravel, grayish-brown, dry SILTY SANDS, fines compacted, coarse riverbed type gravels mixed throughout, dry SP-SAND, fine to medium grained, trace gravel, poorly graded, wet, brown, dense- wet at 24.0ft BGS CL-CLAY, silty clay, compacted, stiff, silty fine sands, friable SP-SANDS, gray, fines, moist to wet, loose

CL-CLAY, silty clay, compacted, stiff, fine sands, dry SP-SANDS, gray, fines, moist to wet, loose CL-CLAY, slity clay, grayish brown, moist to dry- mixed with light brown-gray, sands, saturated at 14.0ft BGS CL-CLAY, gray, silty clay, compact, stiff, dry SP-SAND, gray, fine grained, moist to wet, dense CL-CLAY, gray, silty clay, compact, stiff, dry, becoming greyish-black Concrete 2" 0 PVC/Well Casing 8" 0 Borehole

/Bentonite 723.27 721.77 719.27 714.77 709.77 709.27 708.47 707.27 706.27 700.27 699.77'N' VALUE (OVERBURDEN)

Page 1 of 2NUMBERINTERVAL SAMPLEREC (%)MW-CL-13I STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

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

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: April 27, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: D. NEWTONOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 738.14 735.27 19 15 40 53 71 33- very stiff clay at 55.0ft BGS SP-SAND, fine grained, some gravel, brown, low recovery, gravelly, saturated END OF BOREHOLE @ 67.0ft BGS 2" 0 PVC/Well Screen Sand WELL DETAILS Screened interval:

678.27 to 668.27ft AMSL

57.00 to 67.00ft BGS

Length: 10ft

Diameter: 2in

Slot Size: #10

Sand Pack:

679.77 to 668.27ft AMSL

55.50 to 67.00ft BGS

Material: #30 Sand 675.27 668.27'N' VALUE (OVERBURDEN)

Page 2 of 2NUMBERINTERVAL SAMPLEREC (%)MW-CL-13I STRATIGRAPHIC AND INSTRUMENTATION LOG 42 44 46 48 50 52 54 56 58 60 62 64 66 68 70 72 74 76 78 DEPTH ft BGS PROJECT NAME: CLINTON POWER STATION PROJECT NUMBER: 45136-22

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: April 27, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: D. NEWTONOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well ELEV.ft AMSL NO SOIL SAMPLING, vacuum excavated to 12 ft BGS (note: spoils appear to be hard/silty clay)Refer to stratigraphic and instrumentation log for MW-CL-13I for stratigraphic details.

END OF BOREHOLE @ 26.0ft BGS Concrete Bentonite 2" 0 PVC/Well Casing 8" 0 Borehole

/Sand 2" 0 PVC/Well Screen WELL DETAILS Screened interval:

719.25 to 709.25ft AMSL

16.00 to 26.00ft BGS

Length: 10ft

Diameter: 2in

Slot Size: #10

Sand Pack:

721.25 to 709.25ft AMSL

14.00 to 26.00ft BGS

Material: #30 Sand 709.25'N' VALUE (OVERBURDEN)

Page 1 of 1NUMBERINTERVAL SAMPLEREC (%)MW-CL-13S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

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

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: April 27, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: D. NEWTONOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 738.09 735.25 61 84 52>100 0 0 0

0 GRAVEL (FILL) (note vacuum excavation to 12 ft BGS)CL-CLAY (FILL), medium plasticity, stiff, brown, moist CONCRETE (MUD MAT), very hard surface SAND, with gravel, brown, coarse to medium sand SW-SAND, some gravel, little silt, coarse to medium grained sand, very dense, well graded, brown, saturated END OF BOREHOLE @ 28.0ft BGS Concrete Bentonite 2" 0 PVC/Well Casing 8" 0 Borehole

/Sand 2" 0 PVC/Well Screen WELL DETAILS Screened interval:

718.26 to 708.26ft AMSL

18.00 to 28.00ft BGS

Length: 10ft

Diameter: 2in

Slot Size: #10

Sand Pack:

720.26 to 708.26ft AMSL

16.00 to 28.00ft BGS

Material: #30 Sand 731.26 722.76 716.26 714.26 708.26'N' VALUEPID (PPM)(OVERBURDEN)

Page 1 of 1NUMBERINTERVAL SAMPLEREC (%)MW-CL-14S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

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

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 10, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: W. POCHRONOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well GROUND SURFACE TOP OF CASING ELEV.ft AMSL 736.26 736.04 NA NA NA NA 9 6 13 8 18 GRAVEL (FILL)

No sample vacuum excavation to 12 ft BGS (note spoils appear to be hard silty clay ML-SILT, wet, mixed with little clay, silty, light brown, trace gravel, sandy, compact and stiff, clayey- loose sands, well-graded at 13.5ft BGS

ML-SILT, fine sands, wet, light, brown

CL-CLAY, grayish-brown, stiff, dry, mixed little coarse gravel- 2" silt seam at 15.8ft BGS

- brownish-gray, soft, low plasticity, dry, trace shale pieces throughout at 16.0ft BGS- very soft at 28.0ft BGS- grayish-blue color at 39.0ft BGS Concrete 2" 0 PVC/Well Casing 8" 0 Borehole

/Bentonite 735.59 723.84 721.84 721.44'N' VALUE (OVERBURDEN)

Page 1 of 2NUMBERINTERVAL SAMPLEREC (%)MW-CL-15I STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

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

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: April 25, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: D. NEWTONOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well GROUND SURFACE TOP OF CASING ELEV.ft AMSL 735.84 735.58 9 61 58 77- gray color, hard at 44.0ft BGS- friable, some silt, little soil, hard at 49.0ft BGS

- wet at 54.0ft BGS SM-SAND, silty, little gravel, very dense, saturated (note blind drill 56 to 60 ft BGS)

END OF BOREHOLE @ 60.0ft BGS Sand 2" 0 PVC/Well Screen WELL DETAILS Screened interval:

685.84 to 675.84ft AMSL

50.00 to 60.00ft BGS

Length: 10ft

Diameter: 2in

Slot Size: #10

Sand Pack:

687.84 to 675.84ft AMSL

48.00 to 60.00ft BGS

Material: #30 Sand 680.84 675.84'N' VALUE (OVERBURDEN)

Page 2 of 2NUMBERINTERVAL SAMPLEREC (%)MW-CL-15I STRATIGRAPHIC AND INSTRUMENTATION LOG 42 44 46 48 50 52 54 56 58 60 62 64 66 68 70 72 74 76 78 DEPTH ft BGS PROJECT NAME: CLINTON POWER STATION PROJECT NUMBER: 45136-22

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: April 25, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: D. NEWTONOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well ELEV.ft AMSL GRAVEL (FILL)

NO SOIL SAMPLING, vacuum excavation to 12 ft BGS (note spoils appear to be hard silty clay)Refer to stratigraphic and instrumentation log for MW-CL-13I for stratigraphic details.

END OF BOREHOLE @ 24.0ft BGS Concrete Bentonite 2" 0 PVC/Well Casing Sand 8" 0 Borehole

/2" 0 PVC/Well Screen WELL DETAILS Screened interval:

721.90 to 711.90ft AMSL

14.00 to 24.00ft BGS

Length: 10ft

Diameter: 2in

Slot Size: #10

Sand Pack:

723.90 to 711.90ft AMSL

12.00 to 24.00ft BGS

Material: #30 Sand 735.65 711.90'N' VALUE (OVERBURDEN)

Page 1 of 1NUMBERINTERVAL SAMPLEREC (%)MW-CL-15S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

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

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: April 25, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: D. NEWTONOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well GROUND SURFACE TOP OF CASING ELEV.ft AMSL 735.90 735.43 75 77 39>100 22 0 0 0

0 0 NO SOIL SAMPLING, vacuum excavated to 12 ft BGS.Spoil Observations:- 0 to 2 ft BGS, Fill Gravel- 2 to 4 ft BGS Compacted Silty Clay SW-SAND, fine to medium grained, trace of coarse grained, trace of cobbles and silt, brown, moist, very dense CONCRETE (MUD MAT)(NO SOIL SAMPLING)

CL-CLAY, trace cobbles and silt, very stiff, gray, wet END OF BOREHOLE @ 30.5ft BGS Concrete 2" 0 PVC/Well Casing Bentonite 8" 0 Borehole

/Sand 2" 0 PVC/Well Screen WELL DETAILS Screened interval:

714.60 to 704.60ft AMSL

20.50 to 30.50ft BGS

Length: 10ft

Diameter: 2in

Slot Size: #10

Sand Pack:

717.10 to 704.60ft AMSL

18.00 to 30.50ft BGS

Material: #30 Sand 725.10 717.10 709.10 706.10 704.60'N' VALUEPID (PPM)(OVERBURDEN)

Page 1 of 1NUMBERINTERVAL SAMPLEREC (%)MW-CL-16S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

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

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 10, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: D. NEWTONOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 737.80 735.10 14 38 13 9 8 NO SOIL SAMPLING, vacuum excavated to 12 ft BGS Spoil Observations:- 0 to 1 ft BGS Gravel- 1 to 12 ft BGS Brown Silty Clay CL-SILTY CLAY, grayish-brown, fine grained, compacted sands, dry, very stiff, low recovery (wet sluff material in top of spoon)- brown, stiff- 6" sand seam, fine to coarse grained, brown, saturated from 19 to 19.5 ft BGS- silty clay lense, wet, gravelly coarse sands mixed with fine sands at 19.0ft BGS (NO SOIL SAMPLING)

Blind Drill to 28 ft BGS END OF BOREHOLE @ 28.0ft BGS Concrete 2" 0 PVC/Well Casing Bentonite 8" 0 Borehole

/Sand 2" 0 PVC/Well Screen WELL DETAILS Screened interval:

717.28 to 707.28ft AMSL

18.00 to 28.00ft BGS

Length: 10ft

Diameter: 2in

Slot Size: #10

Sand Pack:

719.28 to 707.28ft AMSL

16.00 to 28.00ft BGS

Material: #30 Sand 723.28 713.28 707.28'N' VALUE (OVERBURDEN)

Page 1 of 1NUMBERINTERVAL SAMPLEREC (%)MW-CL-17S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

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

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 3, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: D. NEWTONOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 738.16 735.28 11 32 25 16 13 25 23 24 22 27 NO SOIL SAMPLING, vacuum excavated to 12 ft BGS Spoil Observations:- 0 to 0.8 ft BGS, Fill Gravel- 0.8 to 12 ft BGS, Brown Silty Clay CL-CLAY, silty, little fine sand, moist, medium plasticity, grayish-brown- wet sluff material-sand in top of spoon at 16.0ft BGS- very stiff at 36.0ft BGS Concrete 2" 0 PVC/Well Casing 8" 0 Borehole

/Bentonite 724.49'N' VALUE (OVERBURDEN)

Page 1 of 2NUMBERINTERVAL SAMPLEREC (%)MW-CL-18I STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

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

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 3, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: D. NEWTONOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 739.06 736.49 24 24 27 35>100 46 0- sand content increases at 58.0ft BGS SW-SAND, fine to coarse grained, little gravel, well graded, brown, saturated END OF BOREHOLE @ 68.0ft BGS Sand 2" 0 PVC/Well Screen WELL DETAILS Screened interval:

678.49 to 668.49ft AMSL

58.00 to 68.00ft BGS

Length: 10ft

Diameter: 2in

Slot Size: #10

Sand Pack:

680.49 to 668.49ft AMSL

56.00 to 68.00ft BGS

Material: #30 Sand 672.49 668.49'N' VALUE (OVERBURDEN)

Page 2 of 2NUMBERINTERVAL SAMPLEREC (%)MW-CL-18I STRATIGRAPHIC AND INSTRUMENTATION LOG 42 44 46 48 50 52 54 56 58 60 62 64 66 68 70 72 74 76 78 DEPTH ft BGS PROJECT NAME: CLINTON POWER STATION PROJECT NUMBER: 45136-22

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 3, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: D. NEWTONOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well ELEV.ft AMSL WELL DETAILS Screened interval:

728.61 to 718.61ft AMSL

8.00 to 18.00ft BGS

Length: 10ft

Diameter: 2in

Slot Size: #10

Sand Pack:

730.61 to 718.61ft AMSL

6.00 to 18.00ft BGS

Material: #30 Sand NO SOIL SAMPLING, vacuum excavated to 12 ft BGS Refer to the stratigraphic and instrumentation log for MW-CL-18I for stratigraphic details.

END OF BOREHOLE @ 18.0ft BGS Concrete Bentonite 2" 0 PVC/Well Casing Sand 2" 0 PVC/Well Screen 8" 0 Borehole

/718.61'N' VALUE (OVERBURDEN)

Page 1 of 1NUMBERINTERVAL SAMPLEREC (%)MW-CL-18S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

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

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: May 3, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: D. NEWTONOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 739.18 736.61 4 2 13 13 8 15 14 NO SOIL SAMPLING, vacuum excavated to 12 ft BGS Spoil Observations:- 0 to 0.5 ft BGS, Gravel- 0.5 to 12 ft BGS, Brown Silty Clay CL-CLAY, brownish-gray, soft medium to high plasticity, slightly moist to dry SM-SAND, silty, fine sand, wet to saturated, little gravelly CL-CLAY, brownish-gray, compact, very stiff, dry, hard- slightly sticky at 18.0ft BGS- becoming more gray, grayish-black streaking at 20.0ft BGS- very stiff, dry, hard at 24.0ft BGS END OF BOREHOLE @ 26.0ft BGS Concrete 2" 0 PVC/Well Casing Bentonite 8" 0 Borehole

/2" 0 PVC/Well Screen Sand WELL DETAILS Screened interval:

710.64 to 700.64ft AMSL

16.00 to 26.00ft BGS

Length: 10ft

Diameter: 2in

Slot Size: #10

Sand Pack:

712.64 to 700.64ft AMSL

14.00 to 26.00ft BGS

Material: #30 Sand 714.64 710.64 709.44 700.64'N' VALUE (OVERBURDEN)

Page 1 of 1NUMBERINTERVAL SAMPLEREC (%)MW-CL-19S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

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

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: April 28, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: D. NEWTONOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well GROUND SURFACE TOP OF CASING ELEV.ft AMSL 726.64 726.20 4 12 12 14 12 14 12 11 10 12 NO SOIL SAMPLING, vacuum extraction to 12 ft BGS Spoil Observations:- 0 to 1 ft BGS, Topsoil- 1 to 12 ft BGS, Brown Silty Clay CL-CLAY, some silt, trace gravel, soft, brownish-gray clay, compact silty-clay, very low plasticity, dry, uniform- silty, stiff at 14.0ft BGS- becoming darker gray at 22.0ft BGS- becoming more friable, little sand at 24.0ft BGS- slight increase in silty sand material at 26.0ft BGS END OF BOREHOLE @ 32.0ft BGS Concrete Bentonite 2" 0 PVC/Well Casing Sand 2" 0 PVC/Well Screen 8" 0 Borehole

/Sand Bentonite WELL DETAILS Screened interval:

723.07 to 713.07ft AMSL

6.00 to 16.00ft BGS

Length: 10ft

Diameter: 2in

Slot Size: #10

Sand Pack:

725.07 to 713.07ft AMSL

4.00 to 16.00ft BGS

Material: #30 Sand 717.07 697.07'N' VALUE (OVERBURDEN)

Page 1 of 1NUMBERINTERVAL SAMPLEREC (%)MW-CL-20S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

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

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: April 28, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: D. NEWTONOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 6/15/06 Monitoring Well TOP OF RISER GROUND SURFACE ELEV.ft AMSL 731.56 729.07 70 75 40 0 85 80 75 90 25 19 33 15 17 10 12 7 0 0 0 0 0 0

0 CLAY/SILT, trace fine to coarse gravel, hard, dry, gray- wet zone, clayey 2" at 23.0ft BGS END OF BOREHOLE @ 28.0ft BGS Concrete Bentonite Grout 2" 0 PVC/Well Casing Bentonite Pellets 8" 0 Borehole

/Sand 2" 0 PVC/Well Screen WELL DETAILS Screened interval:

718.40 to 708.40ft AMSL

18.00 to 28.00ft BGS

Length: 10ft

Diameter: 2in

Slot Size: #10

Material: PVC

Sand Pack:

722.40 to 708.40ft AMSL

14.00 to 28.00ft BGS

Material: #5 Sand 708.40 INTERVAL SAMPLEREC (%)NUMBER'N' VALUEPID (PPM)(OVERBURDEN)

Page 1 of 1 MW-CL-21S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

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

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: July 19, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: J. HARGENSOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 8/10/06 Monitoring Well TOP OF CASING GROUND SURFACE ELEV.ft AMSL 738.50 736.40 20 50 65 50 80 40 90 75 70 70 80 24 31 36 35 27 51 80 38 65 96 0 0 0

0 0

0 0

0 0

0 0 FILL, sand, little fine to coarse gravel, fine to coarse, brown, compact, moist vacuum boring from 0 to 12.0ft BGS- trace clay from 24.0 to 26.0ft BGS- wet at 34.0ft BGS Concrete 2" 0 PVC/Well Casing Bentonite Grout 8" 0 Borehole

/Bentonite Pellets Sand 2" 0 PVC/Well Screen 723.80 INTERVAL SAMPLEREC (%)NUMBER'N' VALUEPID (PPM)(OVERBURDEN)

Page 1 of 2 MW-CL-22S STRATIGRAPHIC AND INSTRUMENTATION LOG 2 4 6

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

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: July 20, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: J. HARGENSOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 8/10/06 Monitoring Well TOP OF CASING GROUND SURFACE ELEV.ft AMSL 739.04 735.80 END OF BOREHOLE @ 40.0ft BGS WELL DETAILS Screened interval:

706.30 to 696.30ft AMSL

29.50 to 39.50ft BGS

Length: 10ft

Diameter: 2in

Slot Size: #10

Material: PVC

Sand Pack:

709.80 to 695.80ft AMSL

26.00 to 40.00ft BGS

Material: #5 Sand 695.80 INTERVAL SAMPLEREC (%)NUMBER'N' VALUEPID (PPM)(OVERBURDEN)

Page 2 of 2 MW-CL-22S STRATIGRAPHIC AND INSTRUMENTATION LOG 42 44 46 48 50 52 54 56 58 60 62 64 66 68 70 72 74 76 78 DEPTH ft BGS PROJECT NAME: CLINTON POWER STATION PROJECT NUMBER: 45136-22

CLIENT: EXELON GENERATION COMPANY, LLC

LOCATION: CLINTON, ILLINOIS HOLE DESIGNATION:

STRATIGRAPHIC DESCRIPTION & REMARKS MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE NOTES: DATE COMPLETED: July 20, 2006 DRILLING METHOD: 4-1/4" Hollow Stem Auger

FIELD PERSONNEL: J. HARGENSOVERBURDEN LOG 45136-22.GPJ CRA_CORP.GDT 8/10/06 Monitoring Well ELEV.ft AMSL Revision 0 045136 (14) Clinton Power Station APPENDIX B QUALITY ASSURANCE PROGRAM - T ELEDYNE BROWN ENGINEERING, INC.

Page 2 of 32 TABLE OF CONTENTS Section Title Page

1.0 KNOXVILLE

QAM SECTION INTRODUCTION 7

2.0 QUALITY

SYSTEM 10

2.1 Policy

10 2.2 Quality System Structure 10

2.3 Quality

System Objectives 10

2.4 Personnel

Orientation, Training, and Qualification 11 3.0 ORGANIZATION, AUTHORITY, AND RESPONSIBILITY 12

4.0 PERSONNEL

ORIENTATION, DATA INTEGRITY, TRAINING, AND QUALIFICATION 13

4.1 Orientation

13 4.2 Data Integrity 13

4.3 Training

13

4.4 Qualification

13

4.5 Records

13

5.0 CUSTOMER

INTERFACES 14

5.1 Interface

Personnel 14 5.2 Bid Requests and Tenders 14

5.3 Contracts

14

5.4 TBE's

Expectation of Customers 14

5.5 Customer

Satisfaction 15

5.5.1 Customer

Complaints 15

5.5.2 Customer

Confidentiality 15

6.0 DOCUMENTATION

GENERATION AND CONTROL 16

6.1 General

16 6.2 New Documentation 16

6.3 Documentation

Changes 16 Page 3 of 32 TABLE OF CONTENTS - Continued

6.4 Documentation

Lists and Distributions 16

6.5 Other

Documentation 16

6.6 Documentation

Reviews 16

7.0 DESIGN

OF LABORATORY CONTROLS 17

7.1 General

17 7.2 Facility 17

7.3 Technical

Processes and Methods 17

7.3.1 Operational

Flow 17

7.3.2 Methods

18 7.3.3 Data Reduction and Analysis 18

7.4 Verification

of Technical Processes, Methods, and Software 18 7.4.1 Operational Flow Verification 18 7.4.2 Method Verifications 18 7.4.3 Data Reduction and Analysis Verification 18 7.5 Design of Quality Controls 18 7.5.1 General 19

7.5.2 Demonstration

of Capability (D of C) 19

7.5.3 Process

Control Checks 19

7.6 Counting

Instrument Controls 20

8.0 PURCHASING

AND SUBCONTRACT CONTROLS 21

8.1 General

21 8.2 Source Selection 21

8.3 Procurement

of Supplies and Support Services 21 8.3.1 Catalog Supplies 21

8.3.2 Support

Services 21

8.3.3 Equipment

and Software 22

8.4 Subcontracting

of Analytical Services 22

8.5 Acceptance

of Items or Services 22 Page 4 of 32 TABLE OF CONTENTS - Continued

9.0 TEST SAMPLE IDENTIFICATION AND CONTROL 23

9.1 Sample

Identification 23 9.2 LIMS 23

9.3 Sample

Control 23

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

12.0 NONCONFORMANCE CONTROLS 28 12.1 General 28 12.2 Responsibility and Authority 28 12.3 10CFR21 Reporting 28

Page 5 of 32 TABLE OF CONTENTS - Continued

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

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

Page 6 of 32 REVISION HISTORY

Revision 7 Complete re-write January 1, 2005 Bill Meyer

Revision 8 Updated organization chart, minor change to 1.0, 4.4, 7.5.3.2, 10.2.3, and 12.3 Page 7 of 32 1.0 Knoxville QAM Section Introduction This Quality Assurance Manual (QAM) and related Procedures describes the Knoxville Environmental Services Laboratory's QA system. This system is designed to meet multiple quality standards imposed by Customers and regulatory agencies including:

NRC's 10 CFR 50 Appendix B NRC's Regulatory Guide 4.15

DOE's Order 414.1

DOE's QSAS

ANSI N 42.23

ANSI N 13.30

NELAC Standard, Chapter 5

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

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

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

2.0 QUALITY

SYSTEM The TBE-ES QA system is designed to comply with multiple customer- and regulatory agency-imposed specifications related to quality. This quality system applies to all activities of TBE-ES that affect the quality of analyses performed by the laboratory.

2.1 Policy

The TBE quality policy, given in Company Policy P-501, is "TBE will continually improve our processes and effectiveness in providing products and services that exceed our customer's expectations."

This policy is amplified by this Laboratory's commitment, as attested to by the title page signatures, to perform all work to good professional practices and to deliver high quality services to our customers with full data integrity. (See Section 4.0 and Procedure 1005).

2.2 Quality

System Structure The Quality System is operated by the organizations described in Section 3.0 of this Manual. The Quality System is described in this Manual and in the Procedures Manual, both of which are maintained by the QA Manager. Procedures are divided into 6 sections - Administrative, Methods, Equipments, Technical, Miscellaneous, and LIMS. This Manual is structured as shown in the Table of Contents and refers to Procedures when applicable. Cross references to the various imposed quality specifications are contained in Appendices to this Manual.

2.3 Quality

System Objectives The Quality System is established to meet the objective of assuring all operations are planned and executed in accordance with system requirements. The Quality System also assures that performance evaluations are performed (see Procedure 4006), and that appropriate verifications are performed (see Procedures in the 1000 and 4000 series) to further assure compliance. Verification includes Page 11 of 32 examination of final reports (prior to submittal to customers) to determine their quality (see Procedure 4004).

To further these objectives, various in-process assessments of data, as well as assessments of the system, via internal audits and management reviews, are performed. Both internal experts and customer / regulatory agencies perform further assessments of the system and compliance to requirements.

2.4 Personnel

Orientation, Tr aining, and Qualification TBE provides indoctrination and training to employees and performs proficiency evaluation of technical personnel.

This effort is described in Section 4.0.

Page 12 of 32 3.0 ORGANIZATION, AUTHORITY, AND RESPONSIBILITY TBE has established an effective organization for conducting laboratory analyses at the Knoxville Environmental Services Laboratory. The basic organization is shown in Figure 3-1. Detail organization charts with names, authorities, and responsibilities are given in Procedure 1002. Job descriptions are given in Procedure 1006.

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

(1) Identify problems (2) Stop nonconforming work (3) Initiate investigations (4) Recommend corrective and preventive actions (5) Provide solutions or recommend solutions (6) Verify implementation of actions

All Laboratory personnel have the authority and resources to do their assigned duties and have the freedom to act on problems. The QA personnel have direct, independent access to Company management as shown in Figure 3-1.

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

4.1 Orientation

All laboratory personnel must receive orientation to the quality program if their work can affect quality. Orientation includes a brief review of customer- and regulatory agency-imposed quality requirements, the structure of the QAM, and the implementing procedures. The goal of orientation is to cover the nature and goals of the QA program.

4.2 Data Integrity The primary output of the Laboratory is data. Special emphasis and training in data integrity is given to all personnel whose work provides or supports data delivery. The Laboratory Data Integrity Procedure (Procedure 1005) describes training, personnel attestations, and monitoring operations. Annual reviews are required.

4.3 Training

The Quality Assurance Manager (QAM) maintains a training matrix indicating which laboratory personnel need training in which specific Procedures. This matrix is updated when personnel change or change assignments. All personnel are trained per these requirements and procedures. This training program is described in Procedure 1007. The assi gned responsibilities for employees are described in Procedure 1002 (See Section 3.0) on Organization and in Procedure 1006, Job Descriptions. Refresher training or re-tra ining is given annually as appropriate.

4.4 Qualification

Personnel are qualified as required by their job description. Management and non-analysts are evaluated based on past experience, education, and management's assessment of their capabilities. Formal qualification is required of analysts and related technical personnel who perform laboratory functions. Each applicable person is given training and then formally evaluated by the Operations Manager (or his designees) and by QA. Each analyst must initially demonstrate capability to perform each assigned analytical effort. Each year, thereafter, he or she must perform similar analyses on Interlab Comparison Samples (see Procedure 4006) or on equivalent blanks and spikes samples. Acceptable results extend qualifications (certification). Unacceptable results require retraining in the subject method / Procedures. (See Procedure 1007 for added information, records, forms, etc. used.)

4.5 Records

Records of training subjects, contents, attendees, instructors, and certifications are maintained by QA.

Page 14 of 32 5.0 CUSTOMER INTERFACES

5.1 Interface

Personnel The Laboratory has designated Program Managers as the primary interface with all customers. Other interfaces may be the QA Manager or the Lab Operations Manager.

5.2 Bid Requests and Tenders The Program Managers respond to customer requests for bids and proposals per Procedure 1014 for bids, proposals, and contract reviews. They clarify customer requests so both the customer and the lab staff understand requests. As responses are developed, internal reviews are conducted to ensure that requirements are adequately defined and documented and to verify that the Laboratory has adequate resources in physical capabilities, personal skills, and technical information to perform the work. Accreditation needs are reviewed. If subcontracts are required to perform any analysis, the subcontractor is similarly evaluated and the client notified in writing of the effort. Most qualifications are routi ne with standard pricing and the review of these quotes is performed by the Program Manager. Larger or more complex quotes are reviewed by the Operations Manager and the QA Manager (or designees). Evidence of review is by initialing and dating applicable papers, signatures on quotations, or by memo.

5.3 Contracts

The Program Manager's receive contract awards (oral or written) and generate the work planning for initiation pr eparation (charge numbers, data structure or contents in LIMS, etc.). They review contracts for possible differences from quotations and, if acceptable, contracts are processed. Do cumentation of the review is by initials and date as a minimum. Contract changes receive similar reviews and planning.

5.4 TBE's

Expectation of Customers TBE expects customers to provide samples suitable for lab analysis. These expectations include:

Accurate and unambiguous identification of samples Proper collection and preservation of samples Use of appropriate containers free from external and internal contamination Integrity preservation during shipment and timely delivery of samples that are age sensitive Adequate sized samples that allow for retest, if needed Specification of unique MOA/MDC requirements Alerting the lab about abnormal samples (high activity, different chemical contents, etc.) Chain of custody init iation, when required.

Page 15 of 32 5.5 Customer Satisfaction TBE's quality policy centers on customer satisfaction (See 2.0). TBE will work to satisfy customers through full compliance with contract requirements, providing accurate data and properly responding to any questions or complaints.

Customers are provided full cooperation in their monitoring of Laboratory performance. Customers are notified if any applicable State Accreditation is withdrawn, revoked, or suspended.

5.5.1 Customer

Complaints Any customer complaints are documented and tracked to closure. Most complaints concern analysis data and are received by Program Managers. They log each such complaint, order retests for verification, and provide documented results to customers. Co mplaints may also be received by QA or Operations.

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

Page 16 of 32 6.0 DOCUMENTATION GENERATION & CONTROL

6.1 General

The documentation generation and control system is detailed in Procedure 1008. An overview is given below. The basic quality system documents are described in Section 2.0.

6.2 New Documentation Each Procedure and this QAM is written by appropriate personnel, validated if applicable (see Section 7.0), reviewed for adequacy, completeness, and correctness, and, if acceptable, accepted by the authorized approver [QA Manager, Operations Manager (or their designee)]. Both approvals are required if a Procedure affects both QA and Operations. (See Responsibilities in Section 3.0). These procedures control the quality m easurements and their accuracy.

Each document carries a unique identification number, a revision level, dates, page numbers and total page count, and approver identification and sign off. If TBE writes code for software, the software is version identified and issued after Verification and Valida tion per Section 7.0.

6.3 Documentation

Changes Each change is reviewed in the same manner and by the same people as new documentation. Revision identifications are updated and changes indicated by side bars, italicized words, or by revision description when practical. Obsolete revisions are maintained by QA after being identified as obsolete.

6.4 Documentation

Lists and Distributions Computer indexes of documents are maintained by Quality showing the current authorized revision level of each document. These revisions are placed on the Laboratory server and obsolete ones are removed so that all personnel have only the current documents. If hard copies are produced and distributed, separate distribution lists are maintained indicating who has them and their revision level(s). Copies downloaded off the server are uncontrolled unless verified by the user (on the computer) to be the latest revision.

6.5 Other

Documentation In addition to TBE-generated documentation, QA maintains copies of applicable specifications, regul ations, and standard methods.

6.6 Documentation

Reviews Each issued document is reviewed at least every third year by the approving personnel. This review determines continued suitability for use and compliance with requirements.

Page 17 of 32 7.0 DESIGN OF LABORATORY CONTROLS

7.1 General

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

(a) Facility (b) Technical Processes and Methods (c) Verification of Design of Pr ocesses, Methods, and Software. (d) Design of Quality Controls (e) Counting Instrument Controls

7.2 Facility

The facility was designed and built in 2000 to facilitate correct performance of operations in accordance with good laboratory practices and regulatory requirements. It provides security for operations and samples. It separates sample storage areas based on activity levels, separates wet chemistry from counting instrumentation for contamination control, and provides space and electronic systems for documentation, analysis, and record storage. Procedure 4014 describes the facility, room us es, layouts, etc.

7.3 Technical

Processes and Methods

7.3.1 Operational

Flow The laboratory design provides for sample receipt and storage (including special environmental provisions for perishable items) where samples are received from clients and other labs (see Section 9.0). The samples are logged into the computer based Laboratory Information Management System (LIMS) and receive unique identification numbers and bar code labels. (See Procedure 4017 for LIMS description and user procedures). The Program Managers then plan the work and assure LIMS contains any special instructions to analysts. Samples then go to sample preparation, wet chemistry (for chemical separation), and counting based on the radionuclides. See Procedures in the 2000 and 3000 series. Analysts perform the required tasks with data being entered into logbooks, LIMS, and counting equipment data systems as appropriate. Results are collected and reviewed by the Operations Manager and Program Managers and reports to clients are generated (See Section 14.0). All records (electronic or hard copy) are maintained in files or in back-up electronic copies (see Section 15.0). After the required hold periods and client notification and approval, samples are disposed of in compliance with regulatory requirements (s ee Procedures 5003 and 5004).

Page 18 of 32 7.3.2 Methods The laboratory methods documented in the 2000 and 3000 series of Procedures were primarily developed by senior TBE laboratory personnel based on years of experience at our prior facility in New Jersey. They have been improved, supplemented and implemented here. Where EPA or other accepted national methods exist (primarily for water analyses under State certification programs - see Procedure 4010), the TBE methods conform to the imposed requirements or State accepted alternate requirements. Any method modifications are documented and described in the Procedure. There are no nationally recognized methods for most other analysis methods but references to other method documents are noted where applicable.

7.3.3 Data Reduction and Analysis Whenever possible automatic data capture and computerized data reduction programs are used. Calculations are either performed using commercial software (counting system operating systems) or TBE developed and validated software is used (see 7.4 below). Analysis of reduced data is performed as described in Section 14.0 and Procedure 4004.

7.4 Verification

of Technical Processes, Methods, and Software

7.4.1 Operational

Flow Verification The entire QA Manual and related procedures describe the verification of elements of the technical process flow and the establishment of quality check points, reviews, and controls.

7.4.2 Method

Verifications Methods are verified and validated per Procedure 4007 prior to use unless otherwise agreed to by the client. For most TBE methods initial validation occurred well in the past. New or significantly revised Methods receive initial validation by demonstration of their performance using known analytes (NIST traceable) in appropriate matrices. Sufficient samples are run to obtain statistical data that provides evidence of process capability and control, establishes detection levels (see procedure 4009), bias and precisi on data (see Procedure 4011). All method procedures and validation data are available to respective clients. Also see Section

7.5 below

for the Demonstration of Capability program.

7.4.3 Data Reduction and Analysis Verification Data reduction and analysis verification is performed by personnel who did not generate the data. (See Section 14.0).

7.5 Design

of Quality Controls

Page 19 of 32 7.5.1 General There are multiple quality controls designed into the laboratory operations. Many of these are described elsewhere in this manual and include personnel qualification (Section 4.0), Document control (6.0), Sample identification and control (9.0), Use of reference standards (10.0), intra- and inter- laborator y tests (10.0), etc. This Section describes the basic quality control systems used to verify Method capability and performance.

7.5.2 Demonstration

of Capability (D of C)

The demonstration of capability system verifies and documents that the method, analyst, and the equipment can perfo rm within acceptable limits. The D of C is certified for each combination of analyte, method, and instrument type. D of C's are certified based on objective evidence at least annually. This program is combined with the analyst D of C program (See Section 4.0). Initial D of C's use the method validation effort as covered above. Subsequent D of C's use Inter- Laboratory samples (Procedure 4006) or, if necessary, laboratory generated samples using NIST traceable standards. If results are outside of control limits, re-demonstration is required after investigation and corrective action is accomplished (See Sections 12.0 and 13.0)

7.5.3 Process

Control Checks Process control checks are designed to include Inter-Lab samples, Intra-lab QC check samples, and customer provided check samples. 10% of laboratory analysis samples are for process control purposes.

7.5.3.1 Inter- Lab Samples. Inter-lab samples are procured or obtained from sources providing analytes of interest in matrices similar to normal client samples. These samples may be used for Demonstration of Capability of analyst's, equipment and methods. They also provide for independent insight into the lab's process capabilities. Any value reported as being in the warning zone (over 2 sigma) is reviewed and improvements taken. Any value failing (over 3 sigma) is documented on an NCR and formal investigation per Section 12.0 and 13.0 is performed. If root causes are not clearly understood and fixed, re-tests are required using lab prepared samples (See Procedure 4006).

7.5.3.2 QC Samples. QC samples, along with Inter-lab samples and customer check samples, are 10% of the annual lab workload for the applicable analyte and method. If batch processing is used, some specifications require specific checks with each batch or each day rather than as continuous process controls. (See Procedure 4005)

QC samples consist of multiple types of samples including:

(a) Method blanks (b) Blank spikes (c) Matrix spikes Page 20 of 32 (d) Duplicates (e) Tracers and carriers Acceptance limits for these samples are given in Procedures or in lab standards. The number, frequency, and use of these sample types varies with the method, matrix, and supplemental requirements. The patterns of use versus method and the use of the resulting test dat a is described in Procedure 4005.

7.5.3.3 Customer Provided Check Samples. Customers may provide blind check samples and duplicates to aid in their evaluation of the Laboratory. When the lab is notified that sa mples are check samples their results are included in the QC sample percentage counts. Any report ed problems are treated as formal complaints and investigated per Section 5.

7.6 Counting

Instrument Controls The calibration of instruments is their primary control and is described in Section 11.0. In addition, counting procedures (3000 series) also specify use of background checks (method blank data is not used for this) to evaluate possible counting equipment contamination. Instrument calibration checks using a lab standard from a different source than the one used for calibration are also used. Background data can be used to adjust client and test data. Checks with lab standards indicate potential calibration changes.

Page 21 of 32 8.0 PURCHASING AND SUBCONTRACT CONTROLS

8.1 General

Procurement and Subcontracts efforts use the Huntsville-based Cost Point computer system to process orders. The Laboratory-generated Purchase Requisitions are electronically copied into Purchase Orders in Huntsville. The Laboratory also specifies sources to be used. Procured items and services are received at the Laboratory where receiving checks and inspections are made. Laboratory Procedure 1015 provides details on the procurement control system at the Laboratory and references the H untsville procedures as applicable.

8.2 Source

Selection Sources for procurements of items and services are evaluated and approved by QA as described in Procedure 1015. Nationally recognized catalog item sources are approved by the QA Manager based on reputation. Maintenance services by an approved distributor or the equipment manufacturing company are pre-approved. Sources for other services are evaluated by QA, based on service criticality to the quality system, by phone, mail out, or site visit.

Subcontract sources for laboratory analysis services are only placed with accredited laboratories (by NELAP, NUPIC, State, Client, etc.) as applicable for the type of analysis to be performed. QA maintains lists of approved vendors and records of evaluations performed.

8.3 Procurement

of Supplies and Support Services

8.3.1 Catalog

Supplies The Laboratory procures reagents, processing chemicals, laboratory "glassware," consumables, and other catalog items from nationally known vendors and to applicable laboratory grades, purities, concentrations, accuracy levels, etc. Purchase Requisitions for t hese items specify catalog numbers or similar call-outs for these off-the-shelf items. Requisitions are generated by the personnel in the lab needing the item and are approved by the Operations or Production Manager.

Reagents are analytical reagent grade only.

8.3.2 Support

Services Purchase Requisitions for support services (such as balance calibration, equipment maintenance, etc.) are processed as in 8.3.1 but technical requirements are specified and reviewed before approvals are given.

Page 22 of 32 8.3.3 Equipment and Software Purchase Requisitions for new equipment, software programs, and major facility modifications affecting the quality system are reviewed and approved by the Operations Manager and the QA Manager.

8.4 Subcontracting

of Analytical Services When necessary, the Laboratory may subcontract analytical services required by a client. This may be because of special needs, infrequency of analysis, etc. Applicable quality and regulatory requirements are imposed in the Purchase Requisition and undergo a technical review by QA. TBE reserves the right of access by TBE and our client for verification purposes.

8.5 Acceptance

of Items or Services Items and services affecting the quality system are verified at receipt based on objective evidence supplied by the vendor. Supply items are reviewed by the requisitioner and, if acceptable, are accepted via annotation on the vendor packing list or similar document. Similarly, equipment services are accepted by the requisitioning lab person. Calibration services are accepted by QA based on certification reviews.

(See Section 11.0.)

Data reports from analytical subcontractors are evaluated by Program Managers and subsequently by the Operations Manager (or designee) as part of client report reviews.

Items are not used until accepted and if items or services are rejected, QA is notified and nonconformance controls per Section 12.0 are followed. Vendors may be removed from the approved vendor's list if their performance is unacceptable.

Page 23 of 32 9.0 TEST SAMPLE IDENTIFICATION AND CONTROL

9.1 Sample

Identification Incoming samples are inspected for customer identification, container condition, chain of custody forms, and radioactivity levels. If acceptable, the sample information is entered into LIMS which generates bar coded labels for attachment to the sample(s). The labels are attached and samples stored in the assigned location. If environmental controls are needed (refrigeration, freezing, etc.), the samples are placed in these storage locations. If not acceptable, the Program Manager is notified, the customer contacted, and the problem resolved (return of sample, added data receipts, etc.). See Procedure 4003 for more information on sample receipt.

9.2 LIMS The LIMS is used to schedule work, provide special information to analysts, and record all actions taken on samples. See Procedure 4017 and the 6000 series of procedures for more information on LIMS operations.

9.3 Sample

Control The sample, with its bar coded label, is logged out to the applicable lab operation where the sample is processed per the applicable methods (Procedures 2000 and 3000). The LIMS-assigned numbers are used for identification through all operations to record data. Data is entered into LIMS, log books (kept by the analysts) or equipment data systems to record data. The combination of LIMS, logbooks, and equipment dat a systems provide the Chain of Custody data and document all actions taken on samples. Unused sample portions are returned to its storage area for possible verification use. Samples are discarded after required time limits are passed and after client notification and approval , if required.

Page 24 of 32 10.0 SPECIAL PROCESSES, INSPECTION, AND TEST

10.1 Special Processes The Laboratory's special processes are the methods used to analyze a sample and control equipment. These methods are defined in Procedures in the 2000 and 3000 series. These processes are performed to the qualified methods (see Section 7.0) by q ualified people (see 4.0).

10.2 Inspections and Tests The quality of the process is monitored by indirect means. This program involves calibration checks on counting equipments (see Section 11.0), intra-laboratory checks, and inter-laboratory checks. In addition, some customers submit quality control check samples (blinds, duplicates, external reference standards). All generated data gets independent reviews.

10.2.1 Intra Laboratory Checks (QC Checks)

The quantity and types of checks varies with the method, but basic checks which may include blanks, spiked blanks, matrix spikes, matrix spike duplicates, and duplicates are used as appropriate for customer samples. This process is described in Procedure 4005 and in Section 7.0.

10.2.2 Inter Laboratory Checks TBE participates in Inter-lab performance evaluation (check) programs with multiple higher level labs. These programs provide blind matrices for the types of matrix/analyte combinations routinely processed by the Lab, if available. This program is descri bed in Procedure 4006.

10.2.3 Data Reviews Raw data and reports are reviewed by the Operations Manager, or designees. This review checks for data logic, expected results, procedure compliance, etc. (See Section 14.0).

10.3 Control of Sampling of Samples Samples for analysis are supplied by customers preferably in quantities sufficient to allow re-verification analyses if needed. The samples are prepared for analysis by analysts and then an aliquot (partial sample extraction) is taken from the homogeneous customer sample for the initial analysis. Methods specify standard volumes of sample material required. Sampling data is recorded in LIMS and/or logbooks.

10.4 Reference Standards / Material

Page 25 of 32 10.4.1 Weights and Temperatures Reference standards are used by the Laboratory's calibration vendor to calibrate the Labs working instruments measuring weights and thermometers.

10.4.2 Radioactive Materials Reference radioactive standards, traceable to NIST, are procured from higher level laboratories. These reference materials are maintained in the standards area and are diluted down for use by laboratory analysts. All original and diluted volumes are fully traceable to source, procedure, analyst, dilution, and acquisition dates. See Section 11.0 and Procedure 1009.

Page 26 of 32 11.0 EQUIPMENT MAINTENANCE AND CALIBRATION

11.1 General There are two types of equipment used by the Laboratory: support equipment (scales, glassware, weights, thermometers, etc.) and instruments for counting. Standards traceable to NIST are used for calibration and are of the needed accuracy for laboratory operations. Procedures 1009, 4018, and 4019 describe the calibration and maintenance programs.

11.2 Support Equipment Analytical support equipment is purchased with the necessary accuracies and appropriate calibration data. If needed, initial calibration by the Laboratory or its calibration vendor is performed. Recalibration schedules are established and equipment recalibrated by the scheduled date by a calibration vendor or by Laboratory personnel. Maintenance is performed, as needed, per manufacturer's manuals or lab procedures.

In addition to calibrations and recalibrations, checks are made on the continued accuracy of items as described in Procedure 1009. Records are maintained of calibration and specified checks.

11.3 Instruments Instruments receive initial calibration using radioactive sources traceable to NIST. The initial calibration establishes statistical limits of variation that are used to set control limits for future checks and recalibration. This process is described in Procedure 4018. Instruments are maintained per Instrument Manual requirements.

Recalibrations are perfo rmed per the Procedure.

Between calibrations, check sources are used to assure no significant changes have occurred in the calibration of items. Background checks are performed to check for possible radioactive contamination. Background values are used to adjust sample results. Hardware and software are safeguarded from adjustments that could invalidate calibrations or results.

11.4 Nonconformances and Corrective Actions If calibrations or checks indicate a problem, the nonconformance system (Section 12.0) and corrective action system (Section 13.0) are initiated to document the problem and its resolution. Equipment is promptly removed from service if questionable.

Page 27 of 32 11.5 Records Records of calibrations are maintained. Calibration certificates from calibration vendors are maintained by QA. Other calibration data and check data is maintained in log books, LIMS, or instrument software as appropriate and as described in Procedures 1009, 4018, and 4019.

Page 28 of 32 12.0 NONCONFORMANCE CONTROLS

12.1 General The nonconformance control system is implemented whenever a nonconforming condition on any aspect of Laboratory analysis, testing, or results exist. The system takes graded actions based on the nature and severity of the nonconformance. Nonconforming items or processes are controlled to prevent inadvertent use. Nonconformances are documented and dispositioned. Notification is made to affected organizations, including clients. Procedure 1010 describes the procedures followed. Sample result s are only reported after resolution.

12.2 Responsibility and Authority Each Laboratory employee has the responsibility to report nonconformances and the authority to stop performing nonconforming work or using nonconforming equipment. Laboratory supervision can disposition and take corrective actions on minor problems. Any significant problem is documented by QA using the Laboratory's NCR system per Procedure 1010. QA conducts or assures the conduct of cause analyses, disposition of items or data, and initiation of corrective action if the nonconformance could recur.

12.3 10CFR21 Reporting The QA Manager reviews NCRs for possible need of customer and/or NRC notification per the requirements of 10CFR21. Procedure 1011 is followed in this review and for any required reporting.

Page 29 of 32 13.0 CORRECTIVE AND PREVENTIVE ACTIONS

13.1 General The Laboratory takes corrective actions on significant nonconformances (see Section 12.0). It also initiates preventive and improvement actions per the Company Quality Policy (see Section 2.0). The procedures for Corrective Action/Preventive Action systems are contained in Procedure 1012.

13.2 Corrective Actions Corrective actions are taken by Operations and Quality to promptly correct significant conditions adverse to quality. The condition is identified and cause analysis is performed to identify root causes. Solutions are evaluated and the optimum one selected that will prevent recurrence, can be implemented by the Laboratory, allows the Laboratory to meet its other goals, and is commensurate with the significance of the problem. All steps are documented, action plans developed for major efforts, and reports made to Management. QA verifies the implementation effectiveness. Procedure 1012 provides instructions and designates authorities and responsibilities.

13.3 Preventive Actions Preventive actions are improvements intended to reduce the potential for nonconformances. Possible preventive actions are developed from suggestions from employees and from analysis of Laboratory technical and quality systems by management. If preventive actions or improvements are selected for investigation, the issues, investigation, recommendat ions, and implementation actions are documented. Follow up verifies effectiveness.

Page 30 of 32 14.0 RESULTS ANALYSIS AND REPORTING

14.1 General The Laboratory's role is to provide measurement-based information to clients that is technically valid, legally defensible, and of known quality.

14.2 Results Review The results obtained from analytical efforts are collected and reviewed by the Operations Manager and the Program Manager. This review verifies the reasonableness and consistency of the results. It includes review of sample and the related QC activity data. Procedure 4002 describes the process. Any deficiencies are corrected by re-analyses, recalculations, or corrective actions per Sections 12.0 and 13.0. Use of the LIMS with its automatic data loading features (see Procedure 4017) minimizes the possibility of transcription or calculation errors.

14.3 Reports Reports range from simple results reporting to elaborate analytical reports based on the client requirements and imposed specifications and standards. (See Procedure 4004.) Reports present results accurately, clearly, unambiguously, objectively, and as required by the applicable Method(s). Reports include reproduction restrictions, information on any deviations from methods, and any needed data qualifiers based on QC data. If any data is supplied by analytical subcontractors (see Section 8.0), it is clearly identified and attributed to that Laboratory by either name or accreditation number.

If results are faxed or transmitted electronically, conf identiality statements are included in case of receipt by other than the intended client.

Reports are approved by the Program Manager and Operations Manager and record copies kept in file (See Section 15.0).

Page 31 of 32 15.0 RECORDS

15.1 General The Laboratory collects generated data and information related to quality or technical data and maintains them as records. Records are identified, prepared, reviewed, placed in storage, and maintai ned as set forth in Procedure 1003.

15.2 Type of Records All original observations, calculations, derived data, calibration data, and test reports are included. In addition QA data such as audits, management reviews, corrective and preventive actions, m anuals, and procedur es are included.

15.3 Storage and Retention Records are stored in files after completion in the lab. Files are in specified locations and under the control of custodians. Filing systems provide for retrieval. Electronic files are kept on Company servers (with regular back up) or on media stored in fireproof file cabinets. Records are kept in Laboratory files for at least 2 years after the last entry and then in Company files for another year as a minimum. Some customers specify larger periods - up to 7 years - which is also met. Generic records supporting multiple customers are kept for the longest applicable period.

15.4 Destruction or Disposal

Records may be destroyed after the retention period and after client notification and acceptance, if required. If the Laboratory closes, records will go in to company storage in Huntsville unless otherwise directed by customers. If the Laboratory is sold, either the new owner will accept record ownership or the records will go into Company st orage as stated above.

Page 32 of 32 16.0 ASSESSMENTS

16.1 General Assessments consist of internal audits and management reviews as set forth in Procedure 1013.

16.2 Audits Internal audits are planned, performed at least annually on all areas of the quality system, and are performed by qualif ied people who are as independent as possible from the activity audited. (The Laboratory's small size inhibits full independence in some technical areas.) Audits are coordinated by the Quality Manager who assures audit plans and checklists are generated and the results documented. Reports include descriptions of any findings and provide the auditor's assessment of the effectiveness of the audited activity. Report data includes personnel contacted.

Audit findings are re viewed with management and corrective actions agreed to and scheduled. Follow up is performed by QA to verify accomplishment and effectiveness of the corrective action.

16.3 Management Reviews The Annual Quality Assurance Report, prepared for some clients, is the Management Review vehicle. These reports cover audit results, corrective and preventive actions, external assessments, and QC and inter-laboratory performance checks. The report is reviewed with Management by the QA Manager for the continued suitability of the Quality Program and its effectiveness. Any needed improvements are defined, documented, and implemented. Follow ups are made to verify implementation and effectiveness.

Revision 1 045136 (14) Clinton Power Station APPENDIX C LABORATORY ANALYTICAL REPORTS L28785 1 of 192 L28785 2 of 192 L28785 3 of 192 L28785 4 of 192 L28785 5 of 192 L28785 6 of 192 L28785 7 of 192 L28785 8 of 192 L28785 9 of 192 L28785 10 of 192 L28785 11 of 192 L28785 12 of 192 L28785 13 of 192 L28785 14 of 192 L28785 15 of 192 L28785 16 of 192 L28785 17 of 192 L28785 18 of 192 L28785 19 of 192 L28785 20 of 192 L28785 21 of 192 L28785 22 of 192 L28785 23 of 192 L28785 24 of 192 L28785 25 of 192 L28785 26 of 192 L28785 27 of 192 L28785 28 of 192 L28785 29 of 192 L28785 30 of 192 L28785 31 of 192 L28785 32 of 192 L28785 33 of 192 L28785 34 of 192 L28785 35 of 192 L28785 36 of 192 L28785 37 of 192 L28785 38 of 192 L28785 39 of 192 L28785 40 of 192 L28785 41 of 192 L28785 42 of 192 L28785 43 of 192 L28785 44 of 192 L28785 45 of 192 L28785 46 of 192 L28785 47 of 192 L28785 48 of 192 L28785 49 of 192 L28785 50 of 192 L28785 51 of 192 L28785 52 of 192 L28785 53 of 192 L28785 54 of 192 L28785 55 of 192 L28785 56 of 192 L28785 57 of 192 L28785 58 of 192 L28785 59 of 192 L28785 60 of 192 L28785 61 of 192 L28785 62 of 192 L28785 63 of 192 L28785 64 of 192 L28785 65 of 192 L28785 66 of 192 L28785 67 of 192 L28785 68 of 192 L28785 69 of 192 L28785 70 of 192 L28785 71 of 192 L28785 72 of 192 L28785 73 of 192 L28785 74 of 192 L28785 75 of 192 L28785 76 of 192 L28785 77 of 192 L28785 78 of 192 L28785 79 of 192 L28785 80 of 192 L28785 81 of 192 L28785 82 of 192 L28785 83 of 192 L28785 84 of 192 L28785 85 of 192 L28785 86 of 192 L28785 87 of 192 L28785 88 of 192 L28785 89 of 192 L28785 90 of 192 L28785 91 of 192 L28785 92 of 192 L28785 93 of 192 L28785 94 of 192 L28785 95 of 192 L28785 96 of 192 L28785 97 of 192 L28785 98 of 192 L28785 99 of 192 L28785 100 of 192 L28785 101 of 192 L28785 102 of 192 L28785 103 of 192 L28785 104 of 192 L28785 105 of 192 L28785 106 of 192 L28785 107 of 192 L28785 108 of 192 L28785 109 of 192 L28785 110 of 192 L28785 111 of 192 L28785 112 of 192 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of 192 L28785 169 of 192 L28785 170 of 192 L28785 171 of 192 L28785 172 of 192 L28785 173 of 192 L28785 174 of 192 L28785 175 of 192 L28785 176 of 192 L28785 177 of 192 L28785 178 of 192 L28785 179 of 192 L28785 180 of 192 L28785 181 of 192 L28785 182 of 192 L28785 183 of 192 L28785 184 of 192 L28785 185 of 192 L28785 186 of 192 L28785 187 of 192 L28785 188 of 192 L28785 189 of 192 L28785 190 of 192 L28785 191 of 192 L28785 192 of 192 L29197 1 of 62 L29197 2 of 62 L29197 3 of 62 L29197 4 of 62 L29197 5 of 62 L29197 6 of 62 L29197 7 of 62 L29197 8 of 62 L29197 9 of 62 L29197 10 of 62 L29197 11 of 62 L29197 12 of 62 L29197 13 of 62 L29197 14 of 62 L29197 15 of 62 L29197 16 of 62 L29197 17 of 62 L29197 18 of 62 L29197 19 of 62 L29197 20 of 62 L29197 21 of 62 L29197 22 of 62 L29197 23 of 62 L29197 24 of 62 L29197 25 of 62 L29197 26 of 62 L29197 27 of 62 L29197 28 of 62 L29197 29 of 62 L29197 30 of 62 L29197 31 of 62 L29197 32 of 62 L29197 33 of 62 L29197 34 of 62 L29197 35 of 62 L29197 36 of 62 L29197 37 of 62 L29197 38 of 62 L29197 39 of 62 L29197 40 of 62 L29197 41 of 62 L29197 42 of 62 L29197 43 of 62 L29197 44 of 62 L29197 45 of 62 L29197 46 of 62 L29197 47 of 62 L29197 48 of 62 L29197 49 of 62 L29197 50 of 62 L29197 51 of 62 L29197 52 of 62 L29197 53 of 62 L29197 54 of 62 L29197 55 of 62 L29197 56 of 62 L29197 57 of 62 L29197 58 of 62 L29197 59 of 62 L29197 60 of 62 L29197 61 of 62 L29197 62 of 62 L29481 1 of 44 L29481 1 of 44 L29481 2 of 44 L29481 2 of 44 L29481 3 of 44 L29481 3 of 44 L29481 4 of 44 L29481 4 of 44 L29481 5 of 44 L29481 5 of 44 L29481 6 of 44 L29481 6 of 44 L29481 7 of 44 L29481 7 of 44 L29481 8 of 44 L29481 8 of 44 L29481 9 of 44 L29481 9 of 44 L29481 10 of 44 L29481 10 of 44 L29481 11 of 44 L29481 11 of 44 L29481 12 of 44 L29481 12 of 44 L29481 13 of 44 L29481 13 of 44 L29481 14 of 44 L29481 14 of 44 L29481 15 of 44 L29481 15 of 44 L29481 16 of 44 L29481 16 of 44 L29481 17 of 44 L29481 17 of 44 L29481 18 of 44 L29481 18 of 44 L29481 19 of 44 L29481 19 of 44 L29481 20 of 44 L29481 20 of 44 L29481 21 of 44 L29481 21 of 44 L29481 22 of 44 L29481 22 of 44 L29481 23 of 44 L29481 23 of 44 L29481 24 of 44 L29481 24 of 44 L29481 25 of 44 L29481 25 of 44 L29481 26 of 44 L29481 26 of 44 L29481 27 of 44 L29481 27 of 44 L29481 28 of 44 L29481 28 of 44 L29481 29 of 44 L29481 29 of 44 L29481 30 of 44 L29481 30 of 44 L29481 31 of 44 L29481 31 of 44 L29481 32 of 44 L29481 32 of 44 L29481 33 of 44 L29481 33 of 44 L29481 34 of 44 L29481 34 of 44 L29481 35 of 44 L29481 35 of 44 L29481 36 of 44 L29481 36 of 44 L29481 37 of 44 L29481 37 of 44 L29481 38 of 44 L29481 38 of 44 L29481 39 of 44 L29481 39 of 44 L29481 40 of 44 L29481 40 of 44 L29481 41 of 44 L29481 41 of 44 L29481 42 of 44 L29481 42 of 44 L29481 43 of 44 L29481 43 of 44 L29481 44 of 44 L29481 44 of 44 Revision 1 045136 (14) Clinton Power Station APPENDIX D DATA VALIDATION MEMORANDUM