ML092450278

Enclosure 1 to NG-09-0641 - Index of Documents Provided in Response to NRC Request, Part 2 of 2

ML092450278
Person / Time
Site:	Duane Arnold
Issue date:	08/21/2009
From:	NextEra Energy Duane Arnold
To:	Office of Nuclear Reactor Regulation
References
NG-09-0641
Download: ML092450278 (593)

Text

{{#Wiki_filter:Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 C.1 a Berger 2008, Cultural Resource Assessment of the Duane Arnold Energy Center Property, Near Palo, Linn County, Iowa, June.Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 C.1 a Berger 2008, Cultural Resource Assessment of the Duane Arnold Energy Center Property, Near Palo, Linn County, Iowa, June. CULTURAL RESOURCE ASSESSMENT OF THE DUANE ARNOLD ENERGY CENTER PROPERTY, NEAR PALO LINN COUNTY, IOWA Prepared for.O~i. hArruifdf ?Tq'60-Florida Power & Light Energy LLC Duane Arnold Energy Center 3277 DAEC Road Palo, Iowa 52324 The Louis Berger Group, Inc..950 50' Street Marion, Iowa 52302 Prepared By:June 2008 CULTURAL RESOURCE ASSESSMENT OF THE DUANE ARNOLD ENERGY CENTER PROPERTY, NEAR PALO LINN COUNTY, IOWA Prepared for: ener'SY., Quaile Prepared By: June 2008 . Florida Power & Light Energy LLC Duane Arnold Energy Center 3277 DAEC Road Palo, Iowa 52324 The Louis Berger Group, Inc.. . . 950 50 th Street. Marion, Iowa 52302 F],Arhrln PnwvýR, t Ligh F"nr20 Ifln~n nwort iak rnrmJune 2n 2008 I. INTRODUCTION The Louis Berger Group, Inc. (Berger) has completed a cultural resource assessment for a 900-acre property owned by Florida Power & Light Energy located north of the town of Palo, Iowa (Appendix A: Figures 1 and 2). Florida Power & Light Energy wants to have a document in hand to define what potential cultural resources are located within the overall property boundary. It is possible that future federal involvement will trigger the requirements of Section 106 of the National Historic Preservation Act of 1966 (16 U.S.C. § 470 et. seq.). This study was completed to provide information on the potential for cultural resources within the general area of the property currently owned by Florida Power & Light Energy. Once the exact nature of a federal involvement in the project becomes clear, Berger recommends that the scope of the federal undertaking be defined and an area of potential effect (APE) for the project be delineated. An APE is defined as "a geographic area within which an undertaking may directly or indirectly cause changes in the character of use of historic properties, if any such properties exist." (36 CFR §800.16(d)). The APE will not necessarily correspond with the existing property boundary.Currently, Florida Power and Light Energy have no defined plans for development which will trigger the requirements of Section 106 within the 900-acre property boundary that includes the Duane Arnold Energy Center. The 900 acres is located in portions of Sections 3, 4, 9 and 10, Fayette Township (T84N-R8W; see Appendix A: Figure 2).The purpose of the present investigation was to identify potential cultural resource issues that may require additional investigation or mitigation and includes consideration of potential impacts for both archaeological and architectural properties within the entire property boundary. This document will also provide recommendations for further archaeological investigations to follow to adequately survey the parcel for the presence or absence of archaeological sites within the 900-acre parcel. A completedNational Archaeological Database Form is provided in Appendix B.II. OBJECTIVES The overall objectives of the report are to determine: (1) what cultural resources are listed in the National Register of Historic Places (NRII{P) within the current project boundary; (2) what has been previously surveyed within the current project boundary; and (3) what if any additional inventory or evaluation work is needed within the current project boundary. A preliminary historic-architectural assessment was performed for the entire 900-acre property. The architectural assessment included a review of architectural property information currently on file at the Iowa SHPO and a preliminary or windshield survey of the project area. The study was designed to identify: (1) the location of all architectural properties currently listed on the NRHP; and (2) allarchitectural properties within the project area that are greater than 50 years of age and may needevaluation with regard to NRHP Criteria. In general, properties must be 50 years of age to be considered eligible for listing in the NRHP. However, properties that are less than 50 years of age and of exceptionalimportance may also be considered for listing in the NRHP. This study provides recommendations regarding the need for additional architectural survey and evaluation. The Phase I archaeological reconnaissance encompassed the entire 900-acre project location and included completion of the following tasks: (1) identified the location of known archaeological resources based on information currently on file with the Office of the State Archaeologist (OSA); (2) identified areas with potential to contain undocumented archaeological sites based on historic and archival research, field reconnaissance of the project area; and (3) identified areas with little or no potential to contain undisturbed archaeological resources. These findings are described in the following report that specifies the location of known and potential resources, identifies those considered eligible for the NRHP, assesses I The Louis Berger Group, Inc.Florida Power & Light Energy June 20. 2008 1. INTRODUCTION The Louis Berger Group, Inc. (Berger) has completed a cultural resource assessment for a 900-acre property owned by Florida Power & Light Energy located north of the town of Palo, Iowa (Appendix A: . Figures 1 and 2). Florida Power & Light Energy wants to have a document in hand to defme what potential cultural resources are located within the overall property boundary. It is possible that future federal involvement will trigger the requirements of Section 106 of the National Historic Preservation Act of 1966 (16 U.S.C. § 470 et. seq.). This study was completed to provide information on the potential for cultural resources within the general area of the property currently owned by Florida Power & Light Energy. Once the exact nature of a federal involvement in the project becomes clear, Berger recommends that the scope of the federal undertaking be defmed and an area of potential effect (APE) for the project be delineated. An APE is defmed as "a geographic area within which an undertaking may directly or indirectly. cause changes in the character of use of historic properties, if any such properties exist." (36 CFR §800.16(d>>. The APE will not necessarily correspond with the existing property boundary. Currently, Florida Power and Light Energy have no defmed plans for development which will trigger the requirements of Section 106 within the 900-acre property boundary that includes the Duane Arnold Energy Center. The 900 acres is located in portions of Sections 3, 4, 9 and 10, Fayette Township R8W; see Appendix A: Figure 2). The purpose of the present investigation was to identify potential cultural resource issues that may require additional investigation or mitigation and includes consideration of potential impacts for both archaeological and architectural properties within the entire property boundary. This document will also provide for further archaeological investigations to follow to adequately survey the parcel for the presence or absence of archaeological sites within the 900-acre parcel. A completed National Archaeological Database Form is provided in Appendix B. II. OBJECTIVES The overall objectives ofthe report are to determine: (1) what cultural resources are listed in the National Register of Historic Places (NRHP) within the current project boundary; (2) what has been previously surveyed within the current project boundary; and (3) what if any additional inventory or evaluation work is needed within the current project boundary. A preliminary historic-architectural assessment was performed for the entire 900-acre property. The architectural assessment included a review of architectural property information currently on file at the Iowa SHPO and a preliminary or windshield survey of the project area. The study was designed to identify: (1) the location of all architectural properties currently listed on the NRHP; and (2) all architectural properties within the project area that are greater than 50 years of age and may need eval!Jation with regard to NRHP Criteria. In general, properties must be 50 years of age to be considered eligible for listing in the NRHP. However, properties that are less than 50 years of age and of exceptional importance may also be considered for listing in the NRHP. This study provides recommendations regarding the need for additional architectural survey and evaluation. . The Phase I archaeological reconnaissance encompassed the entire 900-acre project location and included completion of the following tasks: (1) identified the location of known archaeological resources based on . information currently on file with the Office of the State Archaeologist (OSA); (2) identified areas with potential to contain undocumented archaeological sites based on historic and archival research, field reconnaissance of the project area; and (3) identified areas with little or no potential to contain undisturbed archaeological resources. These fmdings are described in the following report that specifies the location of known and potential resources, identifies those considered eligible for theNRHP, assesses 1 The Louis Berger Group, Inc. ?o;R Florida Power&~ T-hyIt Enoo, ij~ 02 the project's potential to have an adverse effect on those resources, and provides recommendationsregarding the need for additional archaeological study or mitigation. I1H. NRHP-LISTED PROPERTIES No archaeological or architectural properties are listed in the NRIHP within the 900-acre project boundary. IV. PREVIOUS CULTURAL RESOURCE INVESTIGATIONS Four previous archaeological or architectural surveys have been conducted within the current project boundary. Three of these projects were associated with developments within the Duane Arnold Energy Center, facility (Butler 2005; Fishel 2001; and Schoen and Chadderdon 2005). In 2001, the Office of the State Archaeologist (OSA) conducted a Phase I archaeological survey of the location of a proposed dry spent fuel storage facility (Fishel 2001) with no archaeological site being identified. In 2005, The Louis Berger Group, Inc. conducted two Phase I archaeological surveys on the property (Butler 2005 and Schoen and Chadderdon 2005). One project was associated with a telecommunication tower site (Schoenand Chadderdon 2005), while the other project was associated with the placement of rip-rap to prevent erosion along the west bank of the Cedar River (Butler 2005). No archaeological sites were located during these investigations. The fourth project conducted within the property boundary was a selective survey of portions of Linn County conducted by Leah Rogers and William C. Page in the early 1990s.The purpose of the survey was to provide a comprehensive planning document for Linn County with the identification of potentially significant archaeological, historical and architectural properties within Linn County (Rogers and Page 1993). Four archaeological sites were identified within the property boundary during the survey including Sites 13LN362, 13LN363, 13LN365, 13LN366 (Rogers and Page 1993; see Figure 2). All four sites were recorded as historic Euroamerican artifact scatters associated with former farmsteads/residences. Three of the four archaeological sites were recommended as potentially eligible for listing in the National Register of Historic Places (NRHP) including Sites 13LN363, 13LN365, and 13LN366. Site 13LN362 was recommended as not eligible for listing in the NRHP.As many as six other archaeological surveys have taken place within a one-mile radius of the project boundary. Projects that have been conducted include three archaeological surveys associated with the development of the Pleasant Creek Reservoir located northwest of the property boundary (Benn 1974;Benn and Hovde 1976; and Weichman 1974); one road realignment project (Perry 1983); one wetland mitigation project (Shields 1999); and one survey of a portion of the Wickiup Hill County Park located one the east side of the Cedar River in the Iowa State Preserve system (Halpin and Phillippe 1991). As many as 50 archaeological sites were identified and/or tested during the investigations associated with the Pleasant Creek Reservoir (Benn 1974; Bean and Hovde 1976; and Weichman 1974). Six archaeological sites were located during Perry's (1983) investigation; and four archaeological sites were tested during Shields (1999) investigation. No archaeological sites were identified during the Halpin and Phillippe 1991 investigation.V. CULTURAL RESOURCE POTENTIAL A. POTENTIAL ARCHITECTURAL RESOURCES The architectural assessment included a review of architectural property information currently on file at the Iowa State Historic Preservation Office and a windshield survey of the project area. There are no standing structures within the property boundary that are greater than 50 years of age, including theDuane Arnold Energy Center, and there are no previously recorded or NRHP-listed properties within the property boundary. The permit for construction of the Duane Arnold Energy Center was obtained in June of 1970 and construction proceeded soon after June of 1970 (Florida Power & Light website).2 The Louis Berger Group, Inc.Florida Power & Light Energy June 20. 2008 the project's potential to have an adverse effect on those resources, and provides recommendations regarding the need for additional archaeological study or mitigation. III. NRHP-LISTED PROPERTIES No archaeological or architectural properties are listed in the NRHP within the 900-acre project boundary. IV. PREVIOUS CULTURAL RESOURCE INVESTIGATIONS Four previous archaeological or architectural surveys have been conducted within the current project boundary. 'Three of these projects were associated with developments within the Duane Arnold Energy Center facility (Butler 2005; Fishel 2001; and Schoen and Chadderdon 2005). In 2001, the Office of the State Archaeologist (OSA) conducted a Phase I archaeological survey of the location of a proposed dry spent fuel storage facility (Fishel 2001) with no archaeological site being identified. In 2005, The Louis Berger Group, Inc. conducted two Phase I archaeological surveys on the property (Butler 2005 and Schoen and Chadderdon 2005). One project was associated with a telecommunication tower site (Schoen and Chadderdon 2005), while the other project was associated with the placement of rip-rap to prevent erosion along the west bank of the Cedar River (Butler 2005)., No archaeological sites were located during these investigations. The fourth project conducted within the property boundary was a selective survey of portions of Linn County conducted by Leah Rogers and William C. Page in the early 1990s. The purpose of the survey was to provide a comprehensive planning document for Linn County with the identification of potentially significant archaeological, historical and architectural properties within Linn County (Rogers and Page 1993). Four archaeological sites'were identified with'in the property boundary during the survey including Sites 13LN362, 13LN363, 13LN365, 13LN366 (Rogers and Page 1993; see Figure 2). All four sites were recorded as historic Euroamerican artifact scatters associated with former farmsteads/residences. Three of the four archaeological sites were recommended as potentially eligible faT listing in the National Register of Historic Places (NRHP) including Sites 13LN363,' 13LN365, and 13LN366. Site 13LN362 was recommended as not eligible for listing in the NRHP. As many as six other archaeological surveys have taken place within a one-mile radius of the project boundary. Projects that have been conducted include three archaeological surveys associated with the development of the Pleasant Creek Reservoir located northwest of the property boundary (Benn 1974; Benn and Hovde 1976; and Weichman 1974); one road realignment project (Perry 1983); one wetland mitigation project (Shields 1999); and one survey of a portion of the Wickiup Hill County Park located one the east side of the Cedar River in the Iowa State Preserve system (Halpin and Phillippe 1991). As many as 50 archaeological sites were identifiedandlor tested during the investigations associated with the Pleasant Creek Reservoir (Benn 1974; Benn and Hovde 1976; and Weichman 1974). Six archaeological sites were located during Perry's (1983) investigation; and four archaeoiogical sites were tested during Shields (1999) investigation. No archaeological sites were identified during the Halpin and Phillippe 1991 investigation. V. CULTURAL RESOURCE POTENTIAL A. POTENTIAL ARCHITECTURAL RESOURCES The architectural assessment included a review of architectural property information currently on file at the Iowa State Historic Preservation Office and a windshield survey of the project area. There are no standing structures within the property boundary that are greater than 50 years of age, including the Duane Arnold Energy Center, and there are no previously recorded or NRHP-listed properties within the property boundary. The permit for construction of the Duane Arnold Energy Center was obtained in June of 1970 and construction proceeded after June of 1970 (Florida Power & Light website). 2 The Louis Berger Group, Inc. .June 20. 2008 Florida P-w.r & L.i..ht nrav ......2. 2008B. POTENTIAL FOR UNREPORTED ARCHAEOLOGICAL RESOURCES One May 6, 2008, Archaeologist Todd Butler conducted background research for the project by first accessing site files on-line via I-Sites (OSA 2008) maintained by the Office of the State Archaeologist, Iowa City, Iowa. I-Sites depicts the location of previously recorded archaeological sites and also documents the archaeological investigations that have taken place in the immediate vicinity of the projectlocation. During this same period, further background research was conducted at the Office of the State Archaeologist, the University of Iowa Libraries, and the State Historical Society Library in Iowa City, Iowa to obtain copies of archaeological survey reports conducted in the vicinity of the project; acquire copies of historic plats and atlases; and downloadable aerial photographs of the project area available on-line at the Iowa Geographic Map Server (Iowa Geographic Map Server 2008). In addition to I-Sites (OSA 2008), further background research was conducted on-line via Landmass (Landmass 2008)maintained by the Iowa OSA in partnership with the United States Department of Agriculture. The Landmass website provides the Official Series Description for nearly 450 soil series that are named in the Natural Resources Conservation Service soil surveys of Iowa including Linn County and it provides archaeologist's with information to help interpret the lithology, relative age, and stratigraphic nomenclature of the surface geologic materials in which the soils of Iowa are formed. The information from the Landmass website can be used to assess the area's geological potential to contain prehistoricarchaeological resources and how deeply buried these deposits may be. This information is then used to determine an appropriate survey methodology for the project area. Other resources reviewed prior to the field reconnaissance included the soil survey for Linn County, Iowa (Schermerhorn and Highland 1975)and county/state histories (Sage 1974; and Andreas 1875).On May 7, 2008, Berger Archaeologist Todd L. Butler with the assistance of Duane Arnold employees Herb Giorgio, Jim Zalesky and Jim Probst conducted a Phase I reconnaissance of the entire 900-acre property boundary. Archaeological reconnaissance consisted of a visual examination of the landforms within the project boundary noting the types of land use and previous disturbance. The reconnaissance also focused on examining landforms throughout the project area for the presence of prehistoric burialmounds. No prehistoric burials mounds were identified on high potential upland landforms in the property boundary. Further Phase I investigations may locate burial mounds that might have been missed during the reconnaissance survey. Field reconnaissance determined that approximately 40 percent of the project boundary is under agricultural cultivation (i.e., corn, soybeans fields), 40 percent is within area of timber/tall-grass pasture,20% has been disturbed by modem developments (i.e., Duane Arnold Energy Center construction or development, roads, storage areas, and existing rail lines) (see Appendix A: Figure 3).Known Archaeological Sites: Approximately 16.1 acres of the 900-acre property boundary have been formerly surveyed for archaeological sites within the 900-acre property boundary and four archaeological sites have been recorded including Sites 13LN362, 13LN363, 13LN365, 13LN366 (Rogers and Page 1993; see Figure 2). All four sites were recorded as historic Euroamerican artifact scatters associated with former farmsteads/residences. Three of the four archaeological sites were recommended as potentially eligible for listing in the National Register of Historic Places (NRHP) including Sites 13LN363, 13LN365, and 13LN366 (Rogers and Page 1993). Site 13LN362 was recommended as not eligible for listing in the NRHP (Rogers and Page 1993).As many as 40 archaeological sites (27 prehistoric, 7 historic, and 6 multi-component historic/ prehistoric archaeological sites) have been recorded within a one-mile radius of the project boundary suggesting that additional unreported sites may exist within the property boundary (OSA 2008). Detailed information on these sites is provided in Appendix C. Seven of the 27 prehistoric archaeological sites are recorded as the 3 The Louis Berger Group, Inc.Florida Power & Light Energy June 20. 2008 B. POTENTIAL FOR UNREPORTED ARCHAEOLOGICAL RESOURCES One May 6, 2008, Archaeologist Todd Butler conducted background research for the project by frrst accessing site files on-line via I-Sites (OSA 2008) maintained by the Office of the State Archaeologist, Iowa City, Iowa.* I-Sites depicts the location of previously recorded archaeological sites and also documents the archaeological investigations that have taken place in the immediate vicinity of the project location. During this same period, further background research was conducted at the Office of the State Archaeologist, the University of Iowa Libraries, and the State Historical Society Library in Iowa City, Iowa to obtain copies of archaeological survey reports conducted in the vicinity of the project; acquire copies of historic plats and atlases; and downloadable aerial photographs of the project area available line at the Iowa Geographic Map Server (Iowa Geographic Map Server 2008). In addition to I-Sites (OSA 2008), further background research was conducted on-line via Landmass (Landmass 2008) maintained by the Iowa OSA in partnership with the United States Department of Agriculture. The Landmass website provides the Official Series Description for nearly 450 soil series that are named in the Natural Resources Conservation Service soil surveys of Iowa including Linn County and it provides archaeologist's with information to help interpret the lithology, relative age, and stratigraphic nomenclature of the surface geologic materials in which the soils of Iowa are formed. The information from the Landmass website can be used to assess the area's geological potential to contain prehistoric archaeological resources and how deeply buried these deposits may be. This information is then used to determine an appropriate survey methodology for the project area. Other resources reviewed prior to the field reconnaissance included the soil survey for Linn County, Iowa (Schermerhorn and Highland 1975) and county/state histories (Sage 1974; and Andreas 1875). . On May 7, 2008, Berger Archaeolo8ist Todd L. Butler with the assistance of Duane Arnold employees Herb Giorgio, Jim Zalesky and Jim Probst conducted a Phase I reconnaissance of the entire 900-acre property boundary. Archaeological reconnaissance consisted of a visual examination of the landforms within the project boundary noting the types of land use and previous disturbance. The reconnaissance also focused on examining landforms throughout the project area for the presence of prehistoric burial mounds. No prehistoric burials mounds were identified on high potential upland landforms in the property boundary. Further Phase I investigations may locate burial mounds that might have been missed during the reconnaissance survey. . Field reconnaissance determined that approximately 40 percent of the project boundary is under agricultural cultivation (i.e., com, soybeans fields), 40 percent is within area oftimber/tall-grass pasture, 20% has been disturbed by modem developments (i.e., Duane Arnold Energy Center construction or development, roads, storage areas, and existing rail lines) (see Appendix A: Figure 3). Known Archaeological Siies: Approximately 16.1 acres of the 900-acre property boundary have been formerly surveyed for archaeological sites within the 900-acre property boundary and four archaeological sites have been recorded including Sites 13LN362, 13LN363, 13LN365, 13LN366 (Rogers and Page 1993; see Figure 2). All four sites were recorded as historic Euroamerican artifact scatters associated with former farmsteads/residences. Three of the four archaeological sites were recommended as potentially eligible for listing in the National Register of Historic Places* (NRHP) including Sites 13LN363, 13LN365, and i3LN366 (Rogers and Page 1993). Site 13LN362 was recommended as not -eligible for listing in the NRHP (Rogers and Page 1993). As many as 40 archaeological sites (27 prehistoric, 7 historic, and 6 multi-component historic/ prehistoric archaeological sites) have been recorded within a one-mile radius of the project boundary suggesting that additional unreported sites may exist within the property boundary (OSA 2008). Detailed information on these sites is provided in Appendix C. Seven of the 27 prehistoric archaeological sites are recorded as the 3 The Louis Berger Group, Inc. .bmp. 21) 2flfR FInridn Power & Duht F" June 2f) 2008 location of burial mounds (13LN22, 13LN87, 13LN88, 13LN93, 13LN186, 13LN247, and 13LN522).All of the recorded burial mounds are located on the east side of the Cedar River on upland ridgesoverlooking the river. Burial mounds are eligible for listing in the National Register of Historic (NRHP)under Criterions C and D and are protected by state and federal laws. The remaining 20 prehistoric archaeological sites include 12 artifact scatters (13LN78 through 13LN81, 13LN84, 13LN90, 13LN92, 13LNl 12, 13LNI14, 13LNI 19, 13LN187, and 13LN248), seven open habitations (13LN77, 13LN248, 13LN519 through 13LN521, 13LN525, and 13LN526); and one site associated with maple sugar procurement camp (13LN251). Additional Phase I investigations were recommended for Site 13LN525 (OSA 2008). No further work was recommended at Site 13LN526. Phase II investigations were recommended at Site 13LN519 (OSA 2008) and the remaining 24 prehistoric sites were not evaluated for eligibility to the NRHP.Five of the seven historic archaeological sites were recorded as artifact scatters including Sites 13LN340, 13LN341, 13LN364, 13LN373 and 13LN367). These sites were not evaluated for eligibility for listing in the NRHP. The two remaining historic sites included one former school (13LN342) and one historic quarry (13LN3 83).Six multi-component sites are also located within a one-mile radius of the project boundary including two prehistoric and historic artifact scatters (13LN337 and 13LN338); three prehistoric open habitations andhistoric farmstead/residences (13LN85, 13LN518, and 13LN524); and one prehistoric open habitation and historic refuse dump (13LN523). Based on the previously recorded archaeological sites within the immediate vicinity of the project boundary, the kind of archaeological sites that might be located in the project area include prehistoric lithic scatters and open habitations, potential prehistoric burial mounds,and historic residence/farmsteads. Potential for Unreported Archaeological Sites: Information regarding the potential for additional, but unreported archaeological sites can be drawn from four principle sources: local residents knowledgeable about artifact collection spots or other historic places; historic documents that record the location of early settlements that no longer exist; observed patterns of site occurrence, especially with regard to the landform types preferred by prehistoric inhabitants; and assessing the geologic potential for deeply buried archaeological deposits. The following assessment is based on a review of historic maps and aerialphotographs, depicting the location of late 19th and early. 2 0th century residences and other buildings that are no longer extant; regional information about the location of previously recorded sites; and examination of the types of soils within the project area to determine the potential for buried archaeological sites.Generally speaking, most prehistoric sites are located on well-drained, level ground surfaces. Valleybottoms situated near springs or other sources of water were preferred locations, particularly streamterraces, benches and upland ridges. The current project boundary includes portions of both upland andfloodplain landforms overlooking or within-the Cedar River valley. The overall project location is bounded by the Cedar River to the east and is also located between the confluences of the Cedar River with Pleasant Creek approximately

0.5 miles

to the northwest and Bear Creek approximately 1.25 miles to the south. Approximately 40 percent of the project area is located on floodplain landforms associated with the Cedar River. The remaining 60 percent of the project area is located on upland landforms on the western and southwestern margins of the project area. Thus, there are several basic landform types withinthe current project area including uplands, upland slopes, and floodplain terraces all of which have the potential for archaeological sites (including prehistoric burial mounds, lithic scatters and open habitations).As well as identifying the types of landforms within a project area, assessing archaeological site potential also requires an approximation of the relative time periods that different types of landforms and soils 4 The Louis Berger Group, Inc.Florida Power & Light Energy June 20, 2008 location of burial mounds (13LN22, 13LN87, 13LN88, 13 LN93 , 13LNI86, 13LN247, and 13LN522). All of the recorded burial mounds are located on the east side of the Cedar River on upland ridges overlooking the river. Burial mounds are eligible for listing in the National Register of Historic (NRHP) under Criterions C and D and are protected by state and federal laws. The remaining 20 prehistoric archaeological sites include 12 artifact scatters (13LN78 through 13LN81, 13LN84, 13 LN9 0, 13LN92, 13LN112, 13LN114, 13LN119, 13LN187, and 13LN248), seven open habitations (13LN77, 13LN248, 13LN519 through 13LN521, 13LN525, and 13LN526); and one site associated with maple sugar procurement camp (13LN251). Additional Phase I investigations were recommended for Site 13LN525 (OSA 2008). No further work was recommended at Site 13LN526. Phase II investigations were recommended at Site 13LN519 (OSA 2008) and the remaining 24 prehistoric sites were not evaluated for eligibility to the NRHP. Five of the seven historic archaeological sites were recorded as artifact scatters including Sites 13LN340, 13LN341, 13LN364, 13LN373 and 13LN367). These sites were not evaluated for eligibility for listing in the NRHP. The two remaining historic sites included one former school (13LN342) and one historic quarry (13LN383). Six mUlti-component sites are also located within a one-mile radius of the project boundary including two prehistoric and historic artifact scatters (13LN337 and 13LN338); three prehistoric open habitations and historic farmstead/residences (13LN85, 13LN518, and 13LN524); and one prehistoric open habitation and historic refuse dump (13LN523). Based on the previously recorded archaeological sites within the immediate vicinity of the project boundary, the kind of archaeological sites that might be located in the project area include prehistoric lithic scatters and open habitations, potential prehistoric burial mounds, and historic residence/farmsteads. Potential for Unreported Archaeological Sites: Information regarding the potential for additional, but unreported archaeological sites can be drawn from four principle sources: local residents knowledgeable about artifact collection spots or other historic places; historic documents that record the location of early settlements that no longer exist; observed patterns of site oqcurrence, especially with regard to the landform types preferred by prehistoric inhabitants; and assessing the geologic potential for deeply buried archaeological deposits. The following assessment is based on a review of historic maps and aerial photographs, depicting the location of late 19 th and early. 2Qth century residences and other buildings that are no longer extant; regional ,information about the location of previously recorded sites; and examination of the types of soils within the project area to determine the potential for buried . archaeological sites. Generally speaking, most prehistoric sites are ldcated on well-drained, level ground surfaces. Valley bottoms situated near springs or other sources of water were preferred locations, particularly stream terraces, benches and upland ridges. The current project boundary includes portions of both upland and floodplain landforms overlooking or within the Cedar River valley. The overaH project location is bounded by the Cedar River to the east and is also located between the confluences of the Cedar River with Pleasant Creek approximately

0.5 miles

to the northwest and Bear Creek approximately 1.25 miles to the south. Approximately 40 percent of the project area is located on floodplain landforms associated with the Cedar River. The remaining 60 percent of the project area is located on upland landforms on the western and southwestern margins of the project area. Thus, there are several basic landform types within the current project area including uplands, upland slopes, and floodplain terraces all of which have the potential for archaeological sites (including prehistoric burial mounds, lithic scatters and open habitations). As well as identifying the types of landforms within a project area, assessing archaeological site potential also requires an approximation of the relative time periods that different types of landforms and soils 4 The Louis Berger Group, Inc. Flnrlda Power k Light Fnprpv June 20. 2008 located within a given. project area were established to determine whether or not there is buriedarchaeological site potential. Figure 3 (see Appendix A) was prepared to highlight the various types of landforms within the project area and show the relative age of the deposits within the current project boundary, On or near the surface, archaeological sites are frequently located on upland landforms that have not been subjected to flooding events; while deeply buried archaeological sites tend to be located on floodplain landforms. The upland landforms located in the western portions of the project area consist of windblown loess(a.k.a. loess mantled terrace) deposited during the Late Wisconsinan glacial period (circa 21,000 to 16,500 BP). Thus, any prehistoric archaeological .sites on the loess mantled terrace can be expected to belocated on or near the current ground surface. In various segments of the property boundary, such as immediately east of the loess mantled terrace, are glaciofluvial (outwash) sediments which consist of deposits that have been eroded from the loess mantled terrace or are located on portions of what appear to be former stream terraces or Eolian sand which are also often located on Wisconsinan-age stream terrace (see Appendix A: Figure 3). Thus, prehistoric archaeological sites (if present) in these portions of the project have the potential to be buried below the current ground surface.Geomorphic studies in central Iowa (Bettis and Littke 1987) have also identified a series of Holocene-age alluvial deposits found along toeslopes, footslopes, floodplains and terraces in Iowa that potentiallycontain buried archaeological deposits. These deposits compose the DeForest Formation and consist of four members: Gunder terrace (valley alluvium, 10,000 to 3,000 BP); Corrington (alluvial fan, 10,000 to 2,500 BP); Roberts Creek terrace (valley alluvium, 4000 to 500 BP); and Camp Creek (valley alluvium, 400 BP to present). Members located within the current project area include Gunder terrace, Roberts Creek terrace and minimal representation of Camp Creek deposits.Much of the smaller drainages within the property consist of soils associated with the Gunder terrace or Roberts Creek terrace deposits (see Appendix A: Figure 3). Gunder terrace deposits within the project area consist of A horizon deposits located at the surface or near surface (within two feet or 60 centimeters). Potential prehistoric sites within Gunder deposits are thus fairly close to the present ground surface. Roberts Creek soils consist of a fairly thick A horizon that may extend to 100 centimeters (three feet) below ground surface. These areas may have a mantle of Roberts Creek deposits overlying the Gunder terrace or have a much more complicated geomorphology than other portions of the project area.Thus, prehistoric archaeological sites (if present) have a high potential to be buried in these portions of the project area.A series of late 19f" and early 20t' century historic maps and a series of aerial photographs (USDA and Iowa Geographic Map Server 2008) were examined to help assess the potential for unreported historic archaeological sites within the current project area. Historic plats and atlases for Linn County dating from 1859 (see Appendix A: Figure 4), 1869, 1875 (see Appendix A: Figure 5), 1895 (see Appendix A; Figure 6), 1907 (see Appendix A: Figure 7), 1914, 1921, 1930, and 1938 were examined (Andreas 1875;Barnes 1914; Bergendahl 1895; Iowa Publishing Co. 1907; Kenyon Company, Inc 1930; McWilliams and Thompson 1859; Thompson and Everts 1869; and Woods Atlas Co. 1938). Aerial photographs of the project area dating from 1934 to 1939 (see Appendix A: Figure 8), 1970, 1994, 2006, and 2007 wereexamined (Iowa Geographic Map Server 2008 or Schermerhorn and Highland 1975). Review of these historic maps and aerial photographs indicates that there are as many as nine locations (#1 through 9)within the current property boundary that have the potential for historic archaeological sites or for more deposits associated with previously recorded archaeological sites (see Appendix A: Figure 2 and Table 1).Four of the nine potential archaeological sites identified Within this report are locations that have been recorded as archaeological sites but have potential for additional archaeological deposits and they are Sites 13LN365 (#2), 13LN363 (#3), 13LN362 (#7), and 13LN366 (#9). Four of the remaining five potential historic archaeological sites (see Table 1: #1, 4, 5 and 8) are the locations of possible former 5 The Louis Berger Group, Inc. Florida Power & Light Energv June 20, 2008 located within a given, project area were established to determine whether or not there is buried archaeological site potential. Figure 3 (see Appendix A) was prepared to highlight the various types of landforms within the project area and show the relative age of the deposits within the current project boundary, On or near the surface, archaeological sites are frequently located on upland landforms that have not been SUbjected to flooding events; while deeply buried archaeological sites tend to be located on floodplain landforms. The upland landforms located in the western portions of the project area consist of windblown loess (a.k.a. loess mantled terrace) deposited during the Late Wisconsinan glacial period (circa 21,000 to 16,500 BP). Thus, any prehistoric archaeological sites on the loess mantled terrace can be expected to be located on or near the current ground surface. In various segments of the property boundary, such as immediately east of the loess mantled terrace, are glaciofluvial (outwash) sediments which consist of deposits that have been eroded from the loess mantled terrace or are located on portions of what appear to be former stream terraces or Eolian sand which are also often located on Wisconsinan-age stream terrace (see Appendix A: Figure 3). Thus, prehistoric archaeological sites (if present) in these portions of the project have the potential to be buried below the current ground surface. Geomorphic studies in central Iowa (Bettis and Littke 1987) have also identified a series of Holocene-age alluvial deposits found along toeslopes, footslopes, floodplains and terraces in Iowa that potentially contain burled archaeological deposits. These deposits compose the DeForest Formation and consist of four members: Gunder terrace (valley alluvium, 10,000 to 3,000 BP); Corrington (alluvial fan, 10,000 to 2,500 BP); Roberts Creek terrace (valley alluvium, 4000 to 500 BP); and Camp Creek (valley alluvium, 400 BP to present). Members located within the current project area include Gunder terrace, Roberts Creek terrace and minimal representation of Camp Creek deposits. Much of the smaller drainages within the property consist of soils associated with the Gunder terrace or Roberts Creek terrace deposits (see Appendix A: Figure 3). Gunder terrace deposits within the project area consist of A horizon deposits located at the surface or near surface (within two feet or 60 centimeters). Potential prehistoric sites within Gunder are thus fairly close to the present ground surface. Roberts Creek soils consist of a fairly thick A horizon that may extend to 100 centiineters'(three feet) below ground surface. These' areas may have a mantle of Roberts Creek deposits overlying the Gunder terrace or have a much more complicated geomorphology than other portions ofthe project area. Thus, prehistoric archaeological sites (if presen't) have a high potential to be buried in these portions of the project area. A series of late 19 th and early 20 th century historic maps and a series of aerial photographs (USDA and Iowa Geographic Map Server 2008) were examined to help assess the potential for unreported historic archaeological sites within the current project area. Historic plats and atlases for Linn County dating from 1859 (see Appendix A: Figure 4), 1869, 1875 (see Appendix A: Figure 5), 1895 (see Appendix A; Figure 6), 1907 (see Appendix A: Figure 7), 1914, 1921, 1930, and 1938 were examined (Andreas 1875; Barnes 1914; Bergendah11895; Iowa Publishing Co. 1907; Kenyon Company, Inc 1930; McWilliams and Thompson 1859; Thompson and Everts 1869; and Woods Atlas Co. 1938). Aerial photographs of the project area dating from 1934 to 1939 (see Appendix A: Figure 8), 1970, 1994, 2006, and 2007 were examined (Iowa Geographic Map Server 2008 or Schermerhorn and Highland 1975). Review of these historic maps and aerial photographs indicates that there are as many as nine locations (#1 through 9) . within the current property boundary that have the potential for historic archaeological sites or for more deposits associated with previously recorded archaeological sites (see Appendix A: Figure 2 and Table 1). Four of the nine potential archaeological sites identified within this report are locations that have been recorded as archaeological sites but have potential for additional archaeological deposits and they are Sites 13LN365 (#2), 13LN363 (#3), 13LN362 (#7), and 13LN366 (#9). Four of the remaining five potential historic archaeological sites (see Table 1: #1, 4, 5 and 8) are the locations of possible former 5 The Louis Berger Group, Inc. Fl-rida P__ Aý T ight 17-?D 7OOR farmstead/residences (see Appendix A: Figure 2). Potential archaeological site #6 is the platted location of the town of Macksville, which was indicated on the 1859 historic map of the property boundary (see Appendix A: Figure 2 and Table 1). Site 13LN362 was recorded as a historic artifact scatter and was recommended not eligible for listing in the NRHP (Rogers and Page 1993). It is likely that the deposits for Site 13LN362 are associated with potential farmsteads/residence

1. 7. It is also highly probable that.Site 13LN365 and potential archaeological site and #8 are associated with the same overall farmstead/residence.

No recorded pioneer graves or other platted cemeteries are recorded within or near the property boundary. A description of each of the potential or previously recorded historic archaeological sites follows. Table 1. Potential or Previously Recorded Historic Archaeological Sites Within the Current.Project Boundary Potential or Previously Legal Location Period of Occupation Recommendation Recorded Historic Archaeological Site#I SE'A, NW1/4A, SE'A of-Section 4, Early 20t

c. Additional records search and T84N-RSW subsurface shovel testing 2 (Site 13LN365) SE1/4, SE1/4, SW'A of Section 4, Late 19th to Late 20e c. Additional records search and T84N-R8W subsurface shovel testing 3 (Site 13LN363) NE'A, SW1/44 , NE1/4 of Section 9, Late 19th to Late 20h c. Additional records search and T84N-R8W subsurface shovel testing 4 NWI/A, NW'A, SW' of Section 3, Late 191h to Early 20'h c. Additional records search and T84N-R8W subsurface shovel testing 5 SW'A, SW' of Section 10, T84N- Mid 19" c. Additional records search and R8W subsurface shovel testing 6 SE'A, SE1/4, SE'A of Section. 4, Mid c. Additional records search and T84N-R8W subsurface shovel testing7 (Site 13LN362) SE1/4/, SE1/4/, SE1/4 of Section 9, Mid 19h c. Additional records search and T84N-RSW subsurface shovel testing 8 SW1/4/, SE1/4A, SEVA of Section 4, Mid 20t' c. to Late 20"h Additional records search 'ind T84N-R8W c. subsurface shovel testing 9 (Site 13LN366) NWVA, NEVA, NE'A of Section 9, Mid 19"' c. to Mid 20"' Additional records search and T84N-R8W subsurface shovel testing Potential Historic Archaeological Site #1 (see Appendix A: Figure 2) appears to be a former residence/farmstead dating to early 2 0& century and located within the SE1/4, NW'/, SEA of Section 4, T84N-RSW southeast of the intersection of Power Plant Road and MeClintock Road. The residence/farmstead is not depicted on the 1859, 1869, 1875, 1875, 1895, 1914, 1930, and 1938 historic plats and atlases. The residence/farmstead is first depicted on the 1907 (see Appendix A; Figure 7) and 1921 historic plats as being owned by J.W. McClintock. The residence/farmstead is not depicted on the 1934 to 1939, 1970, 1990, and 2006 USDA and Iowa Geographic Map Server aerial photographs.

Thus, it appears that sometime during the mid 1930s that all of the structures have been demolished and the area appears to have returned to pasture (Iowa Geographic Map Server 2008). Immediately south of potential archaeological site #1 was the former alignment of a historic road that ran east-west with a crossing over the Cedar River. The road is depicted in various alignments on historic pjats and atlases dating from as early as 1859 (see Appendix A: Figure 4); 1875 (see Appendix A: Figure 5); 1895 (see Appendix A: Figure 6); 1907 (see Appendix A: Figure 7); 1914; and 1921. By 1930, the road no longer crosses the.Cedar River and a smaller extension heads north on the east side of potential archaeological site #1. This alignment is also depicted on the historic plat for 1938. The 1934 to 1939 aerial photograph indicates that the extension of road heading 'east-west no longer exists as a formal road put appears to used as a field access (see Appendix A: Figure 8). It is possible that remains of the former alignment may exist as an 6 The Louis Berger Group, Inc.6 The Louis Berger Group, Inc.Florida Power & Light Energy June 20. 2008 farmstead/residences (see Appendix A: Figure 2). Potential archaeological site #6 is the platted location of the town of Macksville, which was indicated on the 1859 historic map of the property boundary (see Appendix A: Figure 2 and Table 1). Site 13LN362 was recorded as a historic artifact scatter and was recommended not eligible for listing in the NRHP (Rogers and Page 1993). It is likely that the deposits for Site 13LN362 are associated with potential farmsteads/residence

1. 7. It is also highly probable that. Site 13LN365 and potential archaeological site and #8 are associated with the same overall farmstead/residence.

No recorded pioneer graves or other platted cemeteries are recorded within or near the property boundary. A* description of each of potential or previously recorded historic archaeological sites follows . . Table 1. Potential or Previously Recorded Historic Archaeological Sites Within the (:urrent . . Project Boundary Potential or Previously Recorded Historic Archaeological Site # -2 (Site 13LN365) 3 (Site 13LN363) 4 5 ' 6 7 (Site 13LN362) 8 9 (Site 13LN366) Legal Location Perio4 of Occupation Recommendation SEY.., NWY.., SEll.! of -Section 4, E.arly 20 th c. T84N-R8W SEll.!, SEll.!, SWlI.! of Section 4, Late 19 th to Late 20 th c. T84N-R8W NEll.!, SWlI.!, NEll.! of Section 9, Late 19 th to Late 20 th c. T84N-R8W . NWlI.!, NWlI.!, SWlI.! of Section 3, Late 19 th to Early 20 th c. T84N-R8W SWlI.!, SWlI.! of Section 10, T84N-Mid 19 th c. R8W SEY.., SEv.., SEll.! of Section 4, Mid-19 th c. T84N-R8W sm-'<, SEll.!, SEv.. of Section 9, Mid 19 th C. T84N-R8W SWlI.!, SEll.!, SEll.! of Section 4, Mid 20 th c. to Late 20 th T84N-R8W c.. NWlI.!, NEll.!, NEll.! of Section 9, Mid 19 th c. to Mid 20 th T84N-R8W C. Additional records search and subsuiface shovel testing Additional records search and subsurface shovel testing Additional records search and subsurface shovel testing Additional records search and subsurface shovel testing Additional records search and subsurface shovel testing Additional records search and subsurface shovel testing Additional records search and subsurface shovel testing Additional records search imd subsurface shovel testing Additional records search and subsurface shovel testing Potential Historic Archaeological Site #1 (see Appendix A: Figure 2) appears to be a former residence/farmstead dating to early 20 th century and located within the SEY-I; NWY-I, SEY-I of Section 4, T84N-R8W southeast of the intersection of Power Plant Road and McClintock Road. The residence/farmstead is not depicted on the 1859, 1869,' 1875, 1875, 1895, 1914, 1930, and 1938 histone plats and atlases. The residence/farmstead is ftrst depicted on the 1907 (see Appendix A; Figure 7) and 1921 historic plats as being owned by J.W. McClintock. The residence/farmstead is not depicted on the 1934 to 19J9, 1970, 1990, and 2006 USDA and Iowa Geographic Map Server aerial photographs. Thus, it appears that sometime during the mid 193 Os that all of the structUres have been demolished and the area appears to have returned to pasture (Iowa Geographic Map Server 2008). Immediately south of potential archaeological site #1 was the former alignment of a historic road that ran east-west with a crossing over the Cedar River. The road is depicted in various alignments on historic plats and atlases dating from as early as 1859 (see Appendix A: Figure 4); 1875 (see Apperidix A: Figure 5); 1895 (see Appendix A: Figure 6); 1907 (see Appendix A: Figure" 7); 1914; and 1921. By 1930, the road no longer crosses the* Cedar River and a smaller extension heads north on the east side of potential archaeological site # 1. This alignment is also depicted on the historic plat for 1938. The 1934 to 1939 aerial photograph that the extension of road heading ,'east-west no longer exists as a formal road put appears to used as a fteld access (see Appendix A: Figure 8). It is possible that remains of the fonner alignment may exist as an 6 The Louis Berger Group, Inc. h- 7n )t)f).Q PinriAn Pnwo,' A~. F ;~1.# Fnnrm, (into 90 91)AParchaeological site and will need to be recorded as such if a Phase I survey identifies portions of the, former road grade or bridge abutments. Potential Historic Archaeological Site #2 (Site 13LN365) (see Appendix A: Figure 2) appears to be aformer residence/farmstead location within the SE1/4, SE'A, SW/4 of Section 4, T84N-R8W dating from the late 19'h to late 20'h century. The residence/farmstead was previously recorded as Site 13LN365 by Rogers and Page (1993). The site was recommended as potentially eligible for listing in the National Register of Historic Places (Rogers and Page 1993). The residence/farmstead is not depicted on the 1859, 1869, 1875, 1914, 1930, and 1938 historic plats and atlases. The farmstead/residence is first depicted onhistoric maps dating to 1895 as being owned by Sarah McClintock (see Appendix A: Figure 6).Subsequent historic maps dating to 1907 (see Appendix A; Figure 8), 1914, and 1921 depict the farmstead as being owned by Jonathon McClintock. The farmstead/residence including nine structures is first depicted on aerial photographs dating from 1934 to 1939 (see Appendix A: Figure 8; Iowa Geographic Map Server 2008) of the property area. The 1970 aerial photograph also depicts the presence of approximately nine structures (Schermerhorn and Highland 1975: Sheet 44). By the 1990s, aerial photographs suggest that these structures were removed and area was allowed to go back to pasture and timber regrowth. The residence/farmstead is not depicted on the 1982 photo-revised USGS Shellsburg 7.5' Series topographic map of the property boundary. The 1990 and 2006 aerial photographs indicate that all of the structures associated with the residence/farmstead have been demolished and the area was allowed to go back to pasture and timber regrowth. No intact archaeological features were identified during Rogers and Page's (1993) investigation, however they noted that the site has high probability for the presence of subsurface features (Rogers and Page 1993:3-23). Potential Historic Archaeological Site #3 (Site 13LN363) (see Appendix A: Figure 2) appears to be a former residence/farmstead location within the NE1/4, SW1/4, NE4 of Section 9, T84N-R8W dating to the late 19th to late 20"' century. The residence/farmstead was previously recorded as Site 13LN363 by Rogers and Page (1993). The site was recommended as potentially eligible for listing in the National Register of Historic Places (Rogers and Page 1993). The residence/farmstead is not depicted on the 1859, 1869, 1914, 1930, 1938 historic plats and atlases. The farmstead/residence is first depicted on historic maps dating to 1875 as being owned by John H. Ray (see Appendix A: Figure 5). Subsequent historicmaps dating to 1907 (see Appendix A; Figure 8) and 1921 depict the farmstead as being owned by Jonathon McClintock. The farmstead/residence is not depicted on the series of aerial photographs aerial photographs dating from 1934 to 1939 (see Appendix A: Figure 8; Iowa Geographic Map Server 2008); 1970; 1990; and 2006 within the property boundary. It appears that the structures located at Site 13LN363 were removed sometime prior to 1934 and area was allowed to go back to pasture and timberregrowth. The residence/farmstead is not depicted on the 1982 photo-revised USGS Shellsburg 7.5'Series topographic map of the property boundary. One intact archaeological feature was identified during Rogers and Page's (1993) investigation, consisting of a limestone foundation (Rogers and Page 1993:3-23). Rogers and Page (1993) noted that site has high probability for the presence of additional subsurface features (Rogers and Page 1993:3-23). The current archaeological reconnaissance of the Site 13LN363 confirmed the location of a limestone foundation as well as the location of a concrete lined well. Potential Historic Archaeolpgical Site #4 (see Appendix A: Figure 2) appears to be the location ef a former residence/farmstead location within the NW1/4, NW1/4, SW1/4 of Section 3, T84N-R8W dating to the late 19t to early 20&" century. The residence/farmstead is not depicted on the 1859, 1869, 1875, 1914, 1921, 1930, 1938 historic plats and atlases. The residence/farmstead is first depicted on the 1895 historic plat as being owned by Joseph Bubbuge (see Appendix A: Figure 6). The residence/farmstead is also depicted on the 1907 historic map as being owned by J.W. McClintock (see Appendix A: Figure 7).' The residence/farmstead is not depicted on the aerial photographs dating from 1934 to 1939, 1970, USDA andIowa Geographic Map Server aerial photographs. The series of aerial photographs indicate that all of the 7 The Louis Berger Group, Inc.Florida Power & Light Energy June 20. 2008 archaeological site and will need to be recorded as such if a Phase I survey identifies portions of the* former road grade or bridge abutments. Potential Historic Archaeological Site #2 (Site 13LN365) (see Appendix A: Figure 2) appears to bea former residence/farmstead location within the of Section 4, T84N-R8Wdating from the late 19 th to late 20 th century. The residence/farmstead was previously recorded as Site 13LN365 by Rogers and Page (1993). The site was recommended as potentially eligible for listing in the National Register of Historic Places (Rogers and Page 1993). The residence/farmstead is not depicted on the 1859, 1869, 1875, 1914, 1930, and 1938 historic plats and atlases. The farmstead/residence is fIrst depicted on historic maps dating to 1895 as being owned by Sarah McClintock (see Appendix A: Figure 6). Subsequent historic maps dating to 1907 (see Appendix A; Figure 8), 1914, and 1921 depict the farmstead as being owned by Jonathon McClintock. The farmstead/residence including nine structures is first depicted on aerial photographs dating from 1934 to 1939 (see Appendix A: Figure 8; Iowa Geographic Map Server 2008) of the property area. The 1970 aerial photograph also depicts the presence of approximately nine structures (Schermerhorn and Highland 1975: Sheet 44). By the 1990s, aerial photographs suggest that these structures were removed and area was allowed to go back to pasture and timber regrowth. The residence/farmstead is not depicted on the 1982 photo-revised USGS Shellsburg' 7.5' Series topographic map of the property boundary. The '1990 and 2006 aerial photographs indicate that all of the structures associated with the residence/farmstead have been demolished and the area was allowed to go back to pasture and timber regrowth. No intact archaeological features were identified during Rogers and Page's (1993) investigation, however they noted that the site has high probability for , the presence of subsurface features (Rogers and Page 1993 :3-23). ' ' Potential Historic Archaeological Site #3 (Site J3LN363) (see Appendix A: Figure 2) appears to be a former residence/farmstead location within the of Section 9, T84N-R8W dating to the late 19 th to late 20 th century. The residence/farmstead was previously recorded as Site 13LN363 by Rogers and Page (1993). The site was recommended as potentially eligible for listing in the National Register of Historic Places (Rogers and Page 1993). The residence/farmstead is not depicted on the 1859, 1869, 1914, 1930, 1938 historic plats and atlases. The farmstead/residence is first depicted on historic maps dating to 1875 as being owned by John H. Ray (see Appendix A: Figure 5). Subsequent historic maps dating to 1907 (see Appendix A; Figure 8) and 1921 depict the farmstead as being owned by Jonathon McClintock. The farmstead/residence is not depicted on the series of aerial photographs aerial photographs dating from 1934 to 1939 (see Appendix A: Figure 8; Iowa Geographic Map Server 2008); 1970; 1990; and 2006 within the property boundary .. It appears that the structures located at Site 13LN363 were removed sometime prior to 1934 and area was allowed to go back to pasture and timber regrowth. The residence/farmstead is not depicted on the 1982 photo-revised USGS Shellsburg 7.5' Series topographic map of the property boundary. One intact archaeological feature was identified during Rogers and Page's (1993) investigation, consisting of a limestone foundation (Rogers and Page 1993:3-23). Rogers and Page (1993) noted that site has high probability for the presence of additional subsurface features (Rogers and Page 1993:3-23). The current archaeological reconnaissance of the Site 13LN363 confirmed the location of a limestone foundation as well as the location of a concrete lined well. Potential Historic Archaeolpgical Site #4 (see Appendix' A: Figure 2) appears to be the location of a former residence/farmstead location within the NWY-I, SWY-I of Section 3, T84N-R8W dating to the late 19 th to early 20 th century. The residence/farmstead is not depicted on the 1859, 1869, 1875, 1914, 1921, 1930, 1938 historic plats and atlases. The residence/farmstead is first depicted on the 1895 historic plat as being owned by Joseph (see Appendix A: Figure 6). The residence/farmstead is also depicted on the 1907 historic map as being by J.W. McClintock (see Appendix A: Figure 7).' The residence/farmstead is not depicted on the aerial photographs dating from 1934 to 1939, 1970, USDA and Iowa Geographic Map Server aerial photographs. The series of aerial photographs indicate that all of the 7 The Louis Berger Group, Inc. plnriýý PýYar X T Y*aht F"20 2008 P~fbifi P~m,. I~hl~tJ~wr, 1June 2f) 20018 structures were demolished prior to 1934 to 1939 and the area appears to have returned to pasture (Iowa Geographic Map Server 2008).Potential Historic Archaeological Site #5 (see Appendix A: Figure 2) appears to be the possible location of a platted townsite known as Macksville located within the SW1/4, SW1/4 of Section 10, T84N-R8W on the west side of the Cedar River. The town appears to have been platted as early as 1859 (see Appendix A: Figure 4), but does not appear to have been settled. The 1859 plat indicates that the property was owned by W. Bully. Subsequent plats and atlases do not depict the location of Macksville, Linn County, Iowa, nor is there any mention of the town of Macksville, Linn County, Iowa in any readily available historic synopisis of Linn County (Andreas 1875; Western Historical Company 1878). Further historical research on the townsite known as Macksville, Linn County, Iowa will be necessary. The potential site is located in a cultivated field. Potential Historic Archaeological Site #6 (see Appendix A: Figure 2) appears to be the location of a former residence/farmstead location within the SE1/4, SE1/4, SE1/4 of Section 4, T84N-R3W dating to the mid 19t century. The residence/farmstead is not depicted on the 1869, 1875, 1907, 1914, 1930, and 1938 historic plats and atlases. However, the farmstead/residence is depicted as being in this vicinity on the 1859 historic plat as being owned by J.W. McClintock (see Appendix A: Figure 4). The series of USDA and Iowa Geographic Map Server aerial photographs do not depict a former structure in the vicinity, of this location.Potential Historic Archaeological Site #7 (Site 13LN362) (see Appendix A: Figure 2) appears to be the location of a former residence/farmstead location within the SE1/4, SE1/44 , SE1/4 of Section 32, T84N-R3W dating to the mid 19 th century. The residence/farmstead is not depicted on the 1869, 1875, 1907, 1914, 1930, and 1938 historic plats and atlases. However, the farmstead/residence is depicted as being in this vicinity on the 1859 historic plat as being owned by J. Craya (see Appendix A: Figure 4). The series of USDA and Iowa Geographic Map Server aerial photographs do not depict a former structure in the vicinity of this location. Site 13LN362 is recorded approximately 40 to 60 meters west of the plotted location of potential historic archaeological site #7. It highly probable that the artifact scatter associated with Site 13LN362 was derived from the former farmstead at this location. No intact archaeological features were identified during Rogers and Page's (1993) investigation and the sitewas recommended as not having potential for listing in the National Register of Historic Places. Given the spatial discrepancy between the location of historic structures between the historic maps and the previously recorded location of artifacts during Rogers and Page's (1993) investigation, Berger recommends that further Phase I testing be completed to determine if intact subsurface features still remain.Potential Historic Archaeological Site #8 (see Appendix A: Figure 3) appears to be the location of a former residence/farmstead or possible outbuildings associated with 13LN365 within the SW1/4, SE1/4I,* SE1/4 of Section 4, T84N-R8W dating to the mid to late 20th century. The residence/farmstead or possible outbuildings are not depicted on the 1859, 1869, 1875, 1907, 1914, 1930, and 1938 historic plats and atlases. However, several structures are depicted as being in this vicinity on the aerial photographs dating from 1934 to 1939 (see Appendix A: Figure 8; Iowa Geographic Map Server 2008) of the property area.The 1970 aerial photograph -also depicts the presence of at least one structure (Schermerhorn and Highland 1975: Sheet 44). By the 1990s, aerial photographs suggest that these structures were removed and area was allowed to go back to pasture and timber regrowth.Potential Historic Archaeological Site #9 (Site 13LN366) (see Appendix A: Figure 2) appears to be anartifact scatter or a former residence/farmstead location within the NE1/4, SW1/4A, NE/4 of Section 9, T84N-RSW dating to the mid 19'h to mid 20'h century. The artifact scatter or residence/farmstead was previously recorded as Site 13LN366 by Rogers and Page (1993). Rogers and Page (1993) collected a sparse number of artifacts at the site, no subsurface features were located. The site was recommended as 8 The Louis Berger Group, Inc.Florida Power & Light Energv June 20. 2008 structures were demolished prior to 1934 to 1939 and area appears to have returned to pasture (Iowa Geographic Map Server 2008). Potential Historic Archaeological Site #5 (see Appendix A: Figure 2) appears to be the possible location of a platted townsite known as Macksville located within the SWt.4, SWt.4 of Section 10, T84N-R8W on the west side of the Cedar River. The town appears to have been platted as early as 1859 (see Appendix A: Figure 4), but does not appear to have been settled. The 1859 plat indicates that the property was owned by W. Bully. Subsequent plats and atlases do not depict the location of Macksville, Linn County, Iowa, nor is there any mention of the town of Macksville, Linn County, Iowa in any readily available historic synopisis of Linn County (Andreas 1875; Western Historical Company 1878). Further historical research on the townsite known as Macksville, Linn County, Iowa will be necessary. The potential site is located in a cultivated field. . Potential Historic Archaeological Site #6 (see Appendix A: Figure 2) appears to be the location of a former residence/farmstead location within the 8E'I4, SE'I4, SE'14 of Section 4, T84N-R3W dating to the mid 19 th century. The residence/farmstead is not depicted on the 1869, 1875, 1907, 1914, 1930, and 1938 historic plats and atlases. However, the farmstead/residence is depicted as being in this vicinity on the 1859 historic plat as being owned by J.W. McClintock (see Appendix A: Figure 4). The series of USDA and Iowa Geographic Map Server aerial photographs do not depict a fonner structure in the vicinity. of this location. Potential Historic Archaeological Site #7 (Site 13LN362) (see Appendix A: Figure 2) appears to be the location of a fonner residence/farmstead location within the SE'I4, SEt.4, SE'14 of Section 32, T84N-R3W dating to the mid 19 th century. The residence/farmstead is not depicted on the 1869, 1875, 1907, 1914, 1930, and 1938 historic plats and atlases. However, the farmstead/residence is as being in this vicinity on the 1859 historic plat as being owned by J. Craya (see Appendix A: Figure 4). The series of USDA and Iowa Geographic Map Server ,aerial photographs do not depict a former structure in the vicinity of this location. Site 13LN362 is recorded approximately 40 to 60 meters west of the plotted location of potential historic archaeological site #7. It highly probable that the artifact scatter associated with Site 13LN362 was derived from the former farmstead at this location. No intact archaeological features were identified during Rogers and Page's (1993) investigation and the site.was recommended as not having potential for listing in the National Register of Historic Places. Given the spatial discrepancy between the location of historic structures between the historic maps and the previously recorded location of artifacts during Rogers and Page's (1993) investigation, Berger recommends that further Phase I testing be completed to determine if intact subsurface features still remain. . Potential Historic Archaeological Site #8 (see Appendix A: .Figure 3) appears to be the location of a former residence/farmstead or possible outbuildings associated with 13LN365 within the SE'I4, SEY10,000 BP Glaciofluvial Sediment and Eolian Sand Recent Channel Deposits (Loamy Alluvial Sediments) Water SOURCE IDNRGIS- SSURGO, Linn County, Iowa 1999, from Shernerhorn and Highland 1975 FIGURE 3: Landform Types and Age Distribution o Property Boundary o 0.5 __ IMjles 0.25 200 400 soo o 800 Metern LEGEND I,,':c"q Roberts Creek Terrace or Gunder , Terrace 10,500 to 500 BP GunderTerrace: 10,500 to 3,000 BP o Loess Mantled Terrace, Late Wisconsinan Loess: >10,000 BP FIGURE 3: Landform Types and Age Distribution o Glaciofluvial Sediment and Eolian Sand Recent Channel Deposits '',,,' (Loamy Alluvial Sediments) Bwater 44**1 v t"-.. ...1-'p. .."'to Is,. .5 ,,,' .... .~ *. ._g

• U* , ! ' o A*A *0V:';'" '.t" .... z,. ' .'t. , .., .." we 4*P ..,.%0' *a~*t 16 0 l~~~~ mA I , LEGENDN 00 0.25 0.5 *MM Property Boundary 00.25 0.5 Miles o 200 400 600 Bil Meters FIGURE 4: Property Boundary, 1859 SOURCE: Mc Williams & Thompson 1859 FIGURE 4: Property Boundary, 1859 SOURCE. Mc~filliams

& Thompson 18597 . .. LEGEND N IilII Property Boundary o 0.25 0.5 i 'Miles 200 400 600 BOO 'Meters o FIGURE 4: Property Boundary, 1859 SOURCE: McWilliams & Thompson 1859 A7 T II im LEGENDN 0 0.25 0.5 Property Boundary FIGURE 5: Property Boundary, 1875 FI Miles 0 200 400 600 800--wm IMetersSOURCE. Andreas, 1875 LEGEND fill Property Boundary FIGURE 5: Property Boundary, 1875 o o i 200 0.25 400 N 600 0.5 i 'Miles 800* JMeters SOURCE: Andreas, 1875 '4--~no~a 137&lt0rnAr I a tM't4~ I ~3/4~ AA/r&SRcgA~aj .',y. -7.4 _d6 L V~lzg%*3 ~i ilii I '1 m i a=3 4 4 1~ ~r ~&y: I 1*4 I IN1 Il 4fft Ay-7r 07 tt VIC'%~ t S ct IHe XSB O40'A" C 0 'ýT Hk IRS--u I IL J LEGEND N 0 0.25 0.5 Pr t Bo I Miles 0Property Boundary 200 400 600 Met,u--rI"aIuu: ao Meters FIGURE 6: Property Boundary, 1895 SOURCE. Parsons, Treat& Wardle 1895 LEGEND N 0.25 0.5 i 'Miles 200 400 600 800 'Meters o o FIGURE 6: Property Boundary, 1895 SOURCE: Parsons, Treat & Wardle 1895 --j ILL A ile LEGEND Property Boundary 0 0.25 0.5 Miles 0 200 400 600 800 r

• r IMi eters FIGURE 7: Property Boundary, 1907 SOURCE.LEGEND N 0 0.25 0.5 i I ijjjji!Miles 0 200 400 600 800 I iOIMeters III Property Boundary FIGURE 7: Property Boundary, 1907 SOURCE:

LEGEND M Property Boundary 0 0.25 0.5 Miles 0 200 400 600 800 Meters SOURCE: Iowa Geographic Map Server, 1934-1939 Aerial Photographs FIGURE 8: Property Boundary on 1934-1939 Aerial Photograh 0 0 200 i SOURCE: Iowa FIGURE 8: Property Boundary on 1934-1939 Aerial Photograh 0.25 400 600 Map Server. 1934-0.5 ! 'Miles 800 ' Meters /LEGENDRoberts Creek Terrace and Roberts Creek Terrace/Gunder Terrace: Subsurface Testing m Late Wisconsinan Terrace, Glaciofluvial Sediment/Eolian Sand, and Gunder Terrace: Pedestrian Survey or Subsurface Testing 2- Disturbed Area: No Survey Potential Archaeological Site:Records Search and Subsurface Testing Recent Channel Deposits: Periodic Subsurface Testing" Shermerhom and Highland 1975 FIGURE 9: Survey Needs D Property Boundary ________ 'MJles 200 400 600 800 o FIGURE 9: Survey Needs LEGEND 1.';'1 Roberts Creek Terrace and li\;g;g,,; Roberts Creek Terrace/GunderTerrace: Subsurface Testing O Late Wisconsinan Terrace, Glaciofluvial . Sediment/Eolian Sand, and Gunder Terrace: Pedestrian Surveyor Subsurface Testing Disturbed Area: No Survey N I t I _ Potential Archaeological Sile: _ Records Search and Subsurface Testing O Channel Deposits: Penodlc Subsurface Testing

• Water SOURCE: IDNRGIS -SSURGO, Unn County, Iowa 1999, from Shermerhom and Highland 1975 APPENDIX BNATIONAL ARCHAEOLOGICAL DATABASE FORM APPENDIXB NATIONAL ARCHAEOLOGICAL DATABASE FORM Database Doe Number: NATIONAL ARCHAEOLOGICAL DATABASE -REPORTS DATA ENTRY FORM

1. R&C#: 2. Authors: Butler, Todd L. and Camilla Deiber Year of Publication:

2008 3. Title: Phase IA Cultural Resource Assessment of the Duane Arnold Energy Center Property, Linn County, Iowa 4. Report Title: Volume #: Publisher: Place: 5....Unp.....b.....sh....d

5. Unpublished Report #: NTIS: Sent From: The Louis Berger Group, Inc.Sent to: Florida Power & Light Energy, LLC Contract #: 6. Federal Agency: Department of Energy (DOE)7. State: Iowa County: Linn Town: Palo 8. Work Type: 86 9. Keyword: 0-Types of Resources/Features 2-Taxonomic Names 4-Geogrpahic Names/Locations 6-Project Names/Study Unit 900 acres [ 71 Southern Iowa Drift Plain [4]Cedar River [4]Cedar River Basin [4]10._____Zoe:______

[1____ ___ ____ ___ [1 10. UTM Zone: ___ Basting: _____1-Generic Terms/Research Questions 3-Artifact Types/Material Classes 5-Time Periods 7-Other Key Words___ ___ __ ___ __ []___ ___ __ ___ __ []Northing: Northing: _____Northing: _____Northing:__ ____FBasting:_ Fasting:___ Easting: 11. Township: 84N Range: 8W Database Doc Number:, ________ _ NATIONAL ARCHAEOLOGICAL DATABASE -REPORTS DATA ENTRY FORM 1. R&C#:

2. Authors: Butler, Todd L. and Camilla Deiber Year of Publication:

2008 3. Title: Phase IA Cultural Resource Assessment of the Duane Arnold Energy Center Property, Linn County, Iowa 4. Report Title: Volume #: _______ Report #: Publisher: Place: 5. Unpublished Sent From: : Sent to: The Louis Berger Group, Inc. Florida Power & Light Energy, LLC Contract#:

6. Federal Agency: Department of Energy (DOE) 7. State: Iowa -=-=:,..:..:..:'-----

County: Linn ---::----- Town: Palo -"-'-----8. Work Type: _8::..:6=--- __ _ 9. Keyword: 0-Types of ResourceslF eatures 2-Taxonomic Names 4-Geogrpahic N ameslLocations 6-Project Names/Study Unit 900 acres [ 7] Southern Iowa Drift Plain [ 4] Cedar River [ 4] Cedar River Basin [4] [ ] [ ] [ ] [ ] Northing:

10. UTM Zone: ___ Basting: __ Easting: Basting: __ Easting: Northing:

______ Northirig: _______ Northing:

11. Township:

84N Range: __ _________ NTIS: I-Generic Terms/Research Questions 3-Artifact TypeslMaterial Classes 5-Time Periods 7-Other Key Words [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] Other Publication Types: 12. Monograph Name Place: 13. Chapter: In: 14. Journal: Volume: 15. Dissertation: First: Last: Issue: First: Last: Degree: Ph.D. LL.D M.A. M.S. B.A. B.S. Institute:

16. Paper: Meeting: Place: Date: 17. Other: Reference Line: 18. Site #: 13LN362 13LN363 13LN365 13LN366 19. Quad Map: Name: Shellsburg, Iowa Date: 1968 (Photo-revised 1982)Other Publication Types: 12. Monograph Name Place: 13. Chapter: In: _-'-__ First: ---,;.--------------_

... ------14. Journal: Volume: 15. Dissertation: Degree: Ph.D. Last: ----Issue: First: Last: ----------LL.D M.A. M.S. B.A. B.S. Institute:

16. Paper: Meeting'L:

__________________ --:::---____________ _ Place: Date: 17. Other: 18. Site #: Reference Line: 13LN362 13LN363 13LN365 13LN366 19. Quad Map: Name: Shellsburg, Iowa Date: 1968 (photo-revised 1982) APPENDIX CPREVIOUSLY RECORDED ARCHAEOLOGICAL SITES WITHIN ONE-MILE OF THE CURRENTPROPERTY BOUNDARY APPENDIXC PREVIOUSLY RECORDED ARCHAEOLOGICAL SITES WITHIN ONE-MILE OF THE CURRENT PROPERTY BOUNDARY Previously Recorded Archaeological Sites Within One Mile of the Property Boundary (Sites in Bold are Located Within the Current Property Boundary)Site Site Type Cultural/Temp Landform NRHP Status References Number oral Affiliation 13LN22 Prehistoric mound group Undetermined Upland ridge Eligible OSA 2008 13LN77 Prehistoric open habitation Undetermined Upland ridge/ side slope Not evaluated OSA2008 13LN78 Prehistoric scatter Undetermined Upland ridge Not evaluated OSA 2008 13LN79 Prehistoric scatter Undetermined Upland ridge Not evaluated OSA 2008 13LN80 Prehistoric scatter Undetermined Upland ridge Not evaluated OSA 2008 13LN81 Prehistoric scatter Undetermined Upland ridge/side slope Not evaluated OSA 2008 13LN84 Prehistoric scatter Undetermined Upland ridge/ side 'slope Not evaluated OSA 2008 13LN85 Prehistoric open habitation/ Prehistoric: Early Terrace/Bench Phase II Recommended OSA 2008 Historic farm/residence Archiac through Late Woodland;Historic: 1850 through 1950 13LN87 Prehistoric mound group Undetermined Upland ridge Eligible OSA 2008 13LN88 Prehistoric mound group Undetermined Upland ridge Eligible OSA 2008 13LN90 Prehistoric scatter Undetermined Upland ridge/ side slope Not evaluated OSA 2008 13LN92 Prehistoric scatter Undetermined Upland ridge! side slope Not evaluated OSA 2008 13LN93 Prehistoric mound group Undetermined Upland ridge Eligible OSA 2008 13LNI 12 Prehistoric scatter Undetermined Uplands Not evaluated OSA 2008 13LNI 14 Prehistoric scatter Undetermined Upland ridge Not evaluated OSA 2008 13LNI 19 Prehistoric scatter Undetermined Uplands Not evaluated OSA 2008 13LN186 Prehistoric mound group Undetermined Upland ridge Eligible OSA 2008 13LN187 Prehistoric scatter Undetermined Upland ridge Not evaluated OSA 2008 13LN233 Prehistoric open habitation Undetermined Upland ridge/ side slope Not evaluated OSA 2008 13LN247 Prehistoric mound group Undetermined Upland ridge/ side Eligible OSA 2008 slopes 13LN248 Prehistoric scatter Undetermined Floodplain Not evaluated OSA 2008 13LN251 Prehistoric resource Undetermined Floodplain/ Not evaluated OSA 2008 procurement -Maple sugar Upland sideslope camps footslope13LN337 Prehistoric and Historic Undetermined Floodplain Not evaluated OSA 2008 artifact scatter 13LN338 Prehistoric and Historic Undetermined Terrace/Bench Not evaluated OSA 2008 artifact scatter Floodplain 13LN340 Historic scatter Undetermined Floodplain Not evaluated OSA 2008 13LN341 Historic scatter Undetermined Floodplain Not evaluated OSA 2008 13LN342 Historic scatter Undetermined Floodplain Not evaluated OSA 2008 13LN362 Historic scatter Undetermined Floodplain Not eligible OSA 2008 13LN363 Historic scatter Undetermined Floodplain Potentially eligible OSA 2008 13LN364 Historic scatter Undetermined Uplands Not evaluated OSA 2008 13LN365 Historic scatter Undetermined Upland ridge Potentially eligible OSA 2008 13LN366 Historic scatter Undetermined Upland ridge Potentially eligible OSA 2008 13LN367 Historic scatter Undetermined Uplands Not evaluated OSA 2008 13LN373 Historic farmstead/residence Undetermined Upland ridge Not evaluated OSA 2008 13LN383 Historic quarry Undetermined Upland sideslope Not evaluated OSA 2008 13LN518 Prehistoric open habitation Prehistoric: Floodplain and Sand Phase II Recommended OSA 2008 and Historic farm/residence Middle to Late dune Woodland;Historic: 1850-1875 13LN519 Prehistoric open habitation Woodland Sand dune Phase 11 recommended OSA 200813LN520 Prehistoric open habitation Late Woodland Uplands Additional Phase I OSA 2008 13LN521 Prehistoric open habitation Undetermined Uplands No further work OSA 2008 13LN522 Prehistoric mound group Early Woodland Uplands Eligible OSA 2008 13LN523 Prehistoric open habitation Prehistoric: Terrace/Bench Additional Phase I OSA 2008 and Historic refuse dump Woodland;Historic: 1950-2000 13LN524 Prehistoric open habitation; Prehistoric: Middle Terrace/Bench No further work OSA 2008 Historic farm/residence and to Late Woodland;scatter Historic: 1950-2000 13LN525 Prehistoric open habitation Late Woodland Uplands Additional Phase I OSA 2008 13LN526 Prehistoric open habitation Undetermined Uplands No further work OSA 2008 Site Number 13LN22 13LN77 13LN78 13LN79 13LN80 13LN81 13LN84 13LN85 13LN87 13LN88 13LN90 13LN92 13LN93 13LNl12 13LNI14 13LN119 13LN186 13LN187 13LN233 13LN247 13LN248 13LN251 13LN337 13LN338 13LN340 13LN341 13LN342 13LN362 13LN363 13LN364 13LN365 13LN366 13LN367 13LN373 13LN383 13LN518 13LN519 13LN520 13LN521 13LN522 13LN523 13LN524 13LN525 13LN526 *Previously Recorded Archaeological Sites Within One Mile of the Property Boundary (Sites in Bold are Located Within the Current Property Boundary) Site Type Cultura1JTemp Landform NRHP Status References oral Affiliation Prehistoric mound group Prehistoric open habitation Prehistoric scatter Prehistoric scatter Prehistoric scatter Prehistoric scatter Prehistoric scatter Prehistoric open habitation! Historic farm/residence Prehistoric mound group Prehistoric mound group Prehistoric scatter Prehistoric scatter Prehistoric mound group Prehistoric scatter Prehistoric scatter Prehistoric scatter Prehistoric mound group Prehistoric scatter Prehistoric open habitation Prehistoric mound group Prehistoric scatter Prehistoric resource procurement -Maple sugar camps Prehistoric and Historic artifact scatter Prehistoric and Historic artifact scatter Historic scatter Historic scatter Historic scatter Historic scatter Historic scatter Historic scatter Historic scatter Historic scatter Historic scatter Historic farmstead/residence Historic quarry Prehistoric open habitation and Historic farm/residence Prehistoric open habitation Prehistoric open habitation Prehistoric open habitation Prehistoric mound group Prehistoric open habitation and Historic refuse dump Prehistoric open habitation; Historic farm/residence and scatter Prehistoric open habitation Prehistoric open habitation Undetermined

Undetermined Undetermined Undetermined Undetermined

Undetermined Undetermined Prehistoric: Early Archiac through Late Woodland; Historic: 1850 through 1950 Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Undetermined Prehistoric: Middle to Late Woodland; Historic: 1850-1875 Woodland Late Woodland Undetermined Early Woodland Prehistoric: Woodland; Historic: 1950-2000 Prehistoric: Middle to Late Woodland; Historic: 1950-2000 Late Woodland Undetermined Upland ridge Upland ridge! side slope Upland ridge Upland ridge Upland ridge Upland ridge/ side slope Upland ridge/ side 'slope TerracelBench Upland ridge Upland ridge Upland ridge/ side slope Upland ridge! side slope Upland ridge Uplands . Upland ridge Uplands Upland ridge Upland ridge Upland ridge/ side slope Upland ridge! side slopes Floodplain Floodplain! Upland sideslope footslope Floodplain Terrace!Bench Floodplain Floodplain Floodplain Floodplain Floodplain Floodplain Uplands Upland ridge Upland ridge Uplands Upland ridge Upland sideslope Floodplain and Sand dune Sand dune Uplands Uplands Uplands TerracelBench TerraceIBench Uplands Uplands Eligible Not evaluated Not evaluated Not evaluated Not evaluated Not evaluated Not evaluated Phase II Recommended Eligible Eligible Not evaluated Not evaluated Eligible Not evaluated Not evaluated Not evaluated Eligible Not eValuated Not evaluated Eligible Not evaluated Not evaluated Not evaluated Not evaluated Not evaluated Not evaluated Not evaluated Not eligible Potentially eligible Not evaluated Potentially eligible Potentially eligible Not evaluated Not evaluated Not evaluated Phase II Recommended Phase 11 recommended Additional Phase [ No further work Eligible Additional Phase I No further work . Additional Phase I No further work OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA20OS OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 OSA2008 Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 C.lb NextEra Energy Duane Arnold Letter, R. Anderson Vice President, DAEC, to D. Jones, Review and Compliance Program Manager, State Historic Society of Iowa, dated July 9, 2009. NG-09-0550. Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 C.1 b NextEra Energy Duane Arnold Letter, R. Anderson Vice President, DAEC, to D. Jones, Review and Compliance Program Manager, State Historic Society of Iowa, dated July 9, 2009. NG-09-0550. ENERGYQ S DUANE ARNOLD July 9, 2009 NG-09-0550 Douglas W Jones Review and Compliance Program Manager Archaeologist State Historic Society of Iowa 600 East Locust Street Des Moines, IA 50319 Dear Mr. Jones;As discussed with members of our staff during the Nuclear Regulatory Commission Environmental Audit associated with our License Renewal process, we are submitting for your review a copy of a reconnaissance we had performed of the Duane Arnold site. The reconnaissance was performed in June 2008 by The Louis Berger Group of Marion, Iowa. We would appreciate any feedback regarding the document.If you have any questions please contact: Herb Giorgio License Renewal Environmental Lead 3277 DAEC Rd Palo IA 52324 319-851-7264 Richard L. Andersj Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC

Enclosure:

Cultural Resource Assessment of the Duane Arnold Energy Center Property, Near Palo Linn County Iowa, June 2008 Cc: K. Putnam w/o attachment H. Giorgio w/o attachment IRMS NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, 1A 52324 July 9,2009 Douglas W Jones Review and Compliance Program Manager Archaeologist State Historic Society of Iowa 600 East Locust Street Des Moines, IA 50319 Dear Mr. Jones; NG-09-0550 As discussed with members of our staff during the Nuclear Regulatory Commission Environmental Audit associated with our License Renewal process, we are submitting for your review a copy of a reconnaissance we had performed of the Duane Arnold site. The reconnaissance was performed in June 2008 by The Louis Berger Group of Marion, Iowa. We would appreciate any feedback regarding the document. If you have any questions please contact: Herb Giorgio License Renewal Environmental Lead 3277 DAEC Rd Palo IA 52324 319-851-7264 Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC

Enclosure:

Cultural Resource Assessment of the Duane Arnold Energy Center Property, Near Palo Linn County Iowa, June 2008 Cc: K. Putnam wlo attachment H. Giorgio wlo attachment IRMS NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324 Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 C.2 Rogers, Leah D. and William C. Page, 1993, Linn County Comprehensive Planning Project Phase Two: Archaeological, Historical, and Architectural Survey Subsection E (Fayette Township), Volume 1. September 30.Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 C.2 Rogers, Leah D. and William C. Page, 1993, Linn County Comprehensive Planning Project Phase Two: Archaeological, Historical, and Architectural Survey Subsection E (Fayette Township), Volume 1. September

30.

Linn County Comprehensive Planning Project Phase Two: ce lica1, fistorial,an SVMbsection E Township)Prepared by Co-Principal Investigators: Leah D.Rogers and William C. Page DUNBAR/JONES PARTNERSHIP J Prepared for Linn County Historic Preservation Commission and the State Historical Society of Iowa, Historic Preservation Bureau September 30, 1993 Comprehensive PRannijrng lProject Phase Two: . " gicai, Historical, and . 'Architectural Survey . . . Subsection E (Fayette* Township) Prepared by Co-Principal Investigators: Leah Do Rogers and William' Ce Page DUNBAR/JONES PARTNERSHIP Prepared for Linn County Historic Preservation Commission and the State Historical Society of Iowa, Historic Preservation Bureau September 30, 1993 r. .. " : '., 7-7;? :?.!/Linn County Comprehensive Planning Project Phase Two: Archaeological, Historical, and Architectural Survey Subsection E (Fayette Township)Prepared for Linn County Historic Preservation Commission and the State Historical Society of Iowa, Historic Preservation Bureau Prepared by Leah D. Rogers 217 NW 5th Street Mount Vernon, Iowa and William C. Page Dunbar/Jones Partnership 104 SW 4th Street Des Moines, Iowa This project has been funded with the assistance of a matching grant-in-aid agreementfrom the State Historical Society of Iowa, Historic Preservation Bureau,through the Department of the Interior National Park Service, under the provisions of the National Historic Preservation Act of 1966.The opinions expressed herein are not necessarily those of the Department of Interior.All phases of the project were conducted under the direction of Co-Principal Investigators: Leah D. Rogers and William C. Page with the assistance of G. Clark Rogers, Project Assistant, Local Volunteers, and the Linn County Historic Preservation Commission September 30, 1993 i i Linn County Comprehensive Planning Project Phase Two: Archaeological, Historical, and , Architectural Survey Subsection. E (Fayette Township) Prepared for Linn County Historic Preservation Commission and the State Historical Society of Iowa, Historic Preservation Bureau Prepared by Leah D. Rogers 217 NW 5th Street Mount Vernon, Iowa and William C. Page Dunbar/Jones Partnership 104 SW 4th Street Des Moines, Iowa This project has been funded with the assistance of a matching grant-in-aid agreement from the State Historical Society of Iowa, Historic Preservation Bureau, through the Department of the Interior National Park Service, under the provisions of the National Historic Preservation Act of 1966. The opinions expressed herein are not necessarily those of the Department of Interior. All phases of the project were conducted under the direction of Co-Principal Investigators: Leah D. Rogers and William C. Page with the assistance of G. Clark Rogers, Project Assistant, Local Volunteers, and the Linn County Historic Preservation Commission September 30, 1993 7--7'7':;:;:'/,*; .I, .,) LF .. !? 0 c:"S; t::-' .1._') v' I czq '30 (", 'A... ERRATA Due to an overlap in site numbering, site 13LN374 in this report has been changed to site 13LN295 for future reference purposes. This is the Lewis Bottoms Church Site. Site number 374 will be re-assigned. I+I , .. , ! . . ERRATA Due to an overlap in site numbering, site 13LN374 in this report has been changed to site 13LN295 for future reference purposes. This is the Lewis Bottoms Church Site. Site number 374 will be re-assigned. i-ABSTRACT The project reported in this document represents the second phase of a multi-year preservation plan being implemented by the Linn County Historic Preservation Commission, with the ultimate goal being the identification, evaluation, and registration ofhistoric properties in Linn County, Iowa. The first phase consisted of the compilation of a comprehensive preservation plan for this program, with the second phase being the initiation of the survey and inventory of historic resources. This phase focused on the survey of the resources within an area designated as Subsection E, which encompasses all but a small portion of Fayette Township in west-central Linn County. The survey included the identification and recording of historic period archaeological and architectural siteswithin Subsection E. A total of 47 local volunteers donated over 380 hours to the field survey and research activities, with a total of 55 archaeological sites and 115 architectural resources recorded. The archaeological survey also involved the examination of approximately 2590 acres. Of the 115 architectural resources, 77 were located in the town of Palo, while 38 were rural resources. This survey provided a model which combined field survey techniques and historic context development and appears to have worked wellin Subsection E. This model will have applications to other survey subsections as well.The evaluation of the archaeological survey results from Subsection E indicates that 24 of the 55 archaeological sites ame potentially individually eligible for nomination to the National Register of Historic Places. Recommendations were also made for two potentialMultiple Property Documentation Forms (MPDF) and related nominations based on the archaeological resources concerning early settlement and agricultural development. It wasfurther recommended, however, that the compilation of these cover documents and related nominations not proceed until additional areas of the county have been surveyed and the results compared to the resources and evaluations in Fayette Township. It is probable that these potential MPDFs are stronger at the county level than at the individual township level.In addition to these two potential MPDFs, a third MPDF was identified in the study area concerning the rural architectural and archaeological resources associated with the Lewis Bottoms Rural Neighborhood. As with the other two potential MPDFs, it was recommended that the compilation of a cover document and nominations for the Lewis Bottoms Rural Neighborhood be delayed until additional surveys can be conducted in other subsections of Linn County and the results integrated with the present study. At this time, it is difficult to assess whether the resources of this rural neighborhood are among the most authentic surviving expressions of this type of extended family settlement in the county, or whether this type of settlement is prevalent throughout the county and perhaps better preserved in other areas.The evaluation of the architectural survey results from Subsection E indicates that twohistoric districts are potentially eligible for nomination to the National Register as well as 15 individually eligible resources. Of the 15 individually eligible resources, seven are located in the town of Palo and eight are located in the rural area of Fayette Township. One of the recommended districts, a commercial resource, is presented in this report within the framework of a traditional historic context and would be a relatively easy district to nominate to the National Register. The other district is presented within a nontraditionalcontext. For this reason, a final evaluation of the latter district must be withheld until future phases of the Linn County survey has verified or contradicted its validity. Finally, thisreport recommends two Multiple Property Documentation Forms and associated nominations, which focus on the resources in Palo constructed of concrete building products manufactured in that community and on the resources associated with the Lewis Bottoms Rural Neighborhood as noted above.ABSTRACT The project reponed in this document represents the second phase of a multi-year preservation plan being implemented by the Linn County Historic Preservation Commission, with the ultimate goal being the identification, evaluation, and registration of historic properties in Linn County, Iowa. The first phase consisted of the compilation of a comprehensive preservation plan for this program, with the second phase being the initiation of the survey and inventory of historic resources. This phase focused on the survey of the resources within an area designated as Subsection E, which encompasses all but a small portion of Fayette Township in west-central Linn County. The survey included the identification and recording of historic period archaeological and architectural sites within Subsection E. A total of 47 local volunteers donated over 380 hours to the field survey and research activities, with a total of 55 archaeological sites and 115 architectural* resources reconied. The archaeological survey also involved the examination of approximately 2590 acres. Of the 115 architectural resources, 77 were located in the town of Palo, while 38 were rural resources. This survey provided a model which combined field survey techniques and historic context development and appears to have worked well in Subsection E. This model will have applications to other survey subsections as well. The evaluation of the archaeological survey results from Subsection E indicates that 24 of the 55 archaeological sites are potentially individually eligible for nomination to the National Register of Historic Places. Recommendations were also made for two potential Multiple Property Documentation Forms (MPDF) and related nominations based on the archaeological resources concerning early settlement and agricultural development It was further recommended, however, that the compilation of these cover documents and related nominations not proceed until additional areas of the county have been surveyed and the results compared to the resources and evaluations in Fayette Township. It is probable that these potential MPDFs are stronger at the county level than at the individual township level. In addition to these two potential MPDFs, a thin! MPDF was identified in the study area concerning the rural architectural and archaeological resources associated with the Lewis Bottoms Rural NeighbOIhood. As with the other two potential MPDFs, it was recommended that the compilation of a cover docwnent and nominations for the Lewis Bottoms Rural Neighborhood be delayed until additional surveys can be conducted in other subsections of Linn County and the results integrated with the present study. At this time, it is difficult to assess whether the resources of this rural neighborhood are among the most authentic surviving expressions of this type of extended family settlement in the county, or whether this type of settlement is prevalent throughout the county and perhaps better preserved. in other areas. The evaluation of the architectural survey results from Subsection E indicates that two historic districts are potentially eligible for nomination to the National Register as well as 15 individually eligible resources. Of the 15 individually eligible resources, seven are located in the town of Palo and eight are locatedin the rural area of Fayette Township. One of the recommended districts, a commercial resource, is presented in this repon within the framework of a traditional historic context and would be a relatively easy district to nominate to the National Register. The other district is presented within a nontraditional context For this reason, a fmal evaluation of the latter district must be withheld until future phases of the Linn County survey has verified or contradicted its validity. Finally, this report recommends two Multiple Property Documentation Forms and associated nominations, which focus on the resources in Palo constructed of concrete building products manufactured in that community and on the resources associated with the Lewis Bottoms Rural Neighborhood as noted above. ii ACKNOWLEDGMENTS This project would not have been possible without the hard work and dedication of a number of individuals and organizations. First and foremost, the authors wish to thank the property owners of Fayette Township and the City of Palo for cooperating with the survey and graciously giving of their time and knowledge toward the completion of the project. Of additional note were the many volunteers, who devoted a number of hours in less than ideal weather conditions to the project activities and whose enthusiasm and dedication were greatly appreciated, and to Project Assistant, Clark Rogers, for his contributions to the project. Thanks also to: the City of Palo for providing a meeting place at the Community Center, Linn County General Services for providing mailing and copy support and a van for field survey;, Jean Oxley of the Linn County Board of Supervisors for her support and contributions; the Linn County Historical Museum for providing lab facilities for processing the artifacts; the Genealogical Society of Linn County for assisting in the historical research; Dunbar/Jones Partnership of Des Moines for providing computer and copy support; the Pleasant Creek State Park rangers and Iowa Electric Light and Power for permission to survey the park and Duane Arnold Energy Center properties; Tom Fruehling of the Cedar Rapids Gazette for providing project publicity; the Palo Atom Burst for publishing project updates and survey schedules; the Linn County Historic Preservation Commission and Advisory Council for their support and participation; and CarolineMarquardt and William Zeller for hospitality in their homes.A very special thanks to all of the volunteers who contributed to the completion of thisproject: Nancy Beadle, Leslie and Bob Blin, Kay Bronson, Jim and Laura Browne, David Brunius, Deb and Doug Conklin, Jeff and Shannon Craft, Ruth Darling, Jane Fisher,Barbara and William Flecksing, Eleanor Flitsch, Pauline Grovert, Adam and Bobbie Hoffmann, Mark Hunter, Amy Justice, Bill Kreuger, Amy Larson, Caroline Marquardt, Dustin, Jeffrey, Sheila, and Steve Mason, Brenda and Lynne McDole, Howard Neff, Ron and Sue Neil, Bill Paeth, Nathan Pollock, Jim Probst, Ben Pugh, Jim Sanders, Patricia Schnell, Craig Shissler, Brian Smith, Leona Jean Smith, Dan Sullivan, Rick Walters,Eleanor Zeller, and Kathy and William Zeller. Special thanks also to property owners andoral history informants who provided historical information and photographs related to the sites: Ronald Beatty, Ray Buelow, the Bull family, Wesley Cabrnoch, Dr. and Mrs.Robert Dennis, Wahneita Dobbe, Mrs. Alfred Frantz, Floyd Frantz, Tom Lewis, Max Melton, David Nemacek, Cheryl Ortmann, Melvin Young, the Railsback family, the Stodola family, the Urbanek family, and all of the other property owners who graciously allowed us to survey on their land.A note of appreciation to the Linn County Recorder's, Auditor's, and Assessor's offices,the Linn County Conservation Commission, and the Linn County Engineer's Office for providing information and documents concerning the project area. Thanks also to the Office of the State Archaeologist in Iowa City for providing site records and project reports pertaining to the project area and to Kathy Gourley, Ralph Christian, and Lowell Soike of the State Historical Society Historic Preservation Bureau for their help and support throughout this project., i I i :: 1 , , : ) : .I : : \ ! '. i! . ) : ! , [ : ! ii ACKNOWLEDGMENTS This project would not have been possible without the hard work and dedication of a number of individuals and organizations. Hrst and foremost, the authors wish to thank the property owners of Fayette Township and the City of Palo for cooperating with the survey and graciously giving of their time and knowledge toward the completion of the project. Of additional note were the many volunteers, who devoted a number of hours in less than ideal weather conditions to the project activities and whose enthusiasm and dedication were greatly appreciated. and to Project Assistant, Clark Rogers. for his contributions to the project. Thanks also to: the City of Palo for providing a meeting place at the Connnunity Center; Linn County General Services for providing mailing and copy support and a van for field survey; Jean Oxley of the Linn County Board of Supervisors for her support and contributions; the Linn County Historical Museum for providing lab facilities for processing the artifacts; the Genealogical Society of Linn County for assisting in the historical research; Dunbar/Jones Partnership of Des Moines for providing computer and copy support; the Pleasant Creek State Park. rangers and Iowa Electric Light and Power for pennission to survey the park and Duane Arnold Energy Center properties; Tom Fruehling of the Cedar Rapids Gazette for providing project publicity; the Palo Atom Bwst for publishing project updates and survey schedules; the Linn County Historic Preservation Commission and Advisory Council for their support and participation; and Caroline Marquani[ and William Zeller for hospitality in their homes. A very special thanks to all of the volunteers who contributed to the completion of this project Nancy Beadle, Leslie and Bob Blin, Kay Bronson, lim and Laura Browne, David Brunius, Deb and Doug Conklin, Jeff and Shannon Craft, Ruth Darling, Jane Fisher, Barbara and William Flecksing, Eleanor Flitsch, Pauline Grovert, Adam and Bobbie Hoffmann, Mark Hunter, Amy Justice, Bill Kreuger, Amy Larson, Caroline Marquardt, Dustin, Jeffrey, Sheila. and Steve Mason, Brenda and Lynne McDole, Howard Neff, Ron and Sue Neil, Bill Paeth, Nathan Pollock, Jim Probst, Ben Pugh, Jim Sanders, Patricia Schnell, Craig Shissler, Brian Smith, Leona Jean Smith, Dan Sullivan, Rick Walters, Eleanor Zeller, and Kathy and William Zeller. Special thanks also to property owners and oral history infonnants who provided historical information and photographs related to the sites: Ronald Beatty, Ray Buelow, the Bull family, Wesley Cabrnoch, Dr. and Mrs. Roben Dennis, Wahneita Dobbe, Mrs. Alfred Frantz, Floyd Frantz, Tom Lewis, Max Melton, David Nemacek, Cheryl Ortmann, Melvin Young, the Railsback family, the Stodola family, the Urbanek family, and all of the other property owners who graciously allowed us to survey on their land. A note of appreciation to the Linn County Recorder's, Auditor's, and Assessor's offices, the Linn County Conservation Commission, and the Linn County Engineer's Office for providing information and documents concerning the project area Thanks also to the Office of the State Archaeologist in Iowa City for providing site records and project repons pertaining to the project area and to Kathy Gourley, Ralph Christian, and LOwell Soike of the State Historical Society Historic Preservation Bureau for their help and support throughout this project . iii Table of Contents Volume Oe Chapter Page List of Figures --List of Tables ----------------------------------------......------------------------ v 1. Introduction ---.-.-----.------ ..--------- ..---.-.---.------------------- 1.1 I. PROJECT DESCRIPTON 1-1 II. GEOGRAPHICAL AND ENVIRONMENTAL SETTING ----------------------... 1-2 2. Statement of Historic Contexts -..............------ .------------ 2-1 I. INTODUCTION

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2-1 I. ARCHAEOLoaICAL CONTEXTS -------------------------------------- 2-1 A. Native American Contact Along the Cedar River ----------------.-----. 2-I B. Early Settlement of Fayette Township --.....................------------ 2-2 C. Agricultural Development of Fayette Township ----------- 2-3 D. Industrial Development of Fayette Township --------------- -- 2-6 E. Transportation Development in Fayette Township- --........ 2-8 F. Religion and Education in Fayette Township 2-10 G. Consolidation Era Resource Development in Fayette Township----2-11 III. HISTORICAL AND ARCHITECTURAL CONTEXTS----1 A. Introduction

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2-12 B. Rise of an Agricultural Economy --...-------...............---------- 2-14 C. Town Building --. ------------ 2-17 D. Transportation----- --.-.. ..... ....- ....... -...-..2-21 E. Architectural Resources of Fayette Township-

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2-21 3. Associated Property Types -.-.....................------------------ 3-1 I.

SUMMARY

OF SURVEY RESULTS ------------------------------ 3-1 II. ARCHAEOLOGICAL PROPERTY TYPES -----............----------..-----.-- 3-2A. Native American Contact Along the Cedar River ---------------......... .3-2 B. Early Settlement of Fayette Township --.----- .......-------------------- 3-4 C. Agricultural Development of Fayette Township -...-----------...---- 3-7 D. Industrial Development of Fayette Township---.. ---..-. 3-8 E. Transportation Development in Fayette Township ----------------------- 3-9 F. Religion and Education in Fayette Township ------------------------- 3-10 G. Consolidation Era Resource Development in Fayette Township----3-11 111. HISTORICAL AND ARCHITECTURAL PROPERTY TYPES ------------ 3-11 A. Introduction

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3-11 B. Rise of an Agricultural Economy -------------------------- 3-12 C. Town Building --------------------------- 3-15 D. Transportation ...........

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-.---- 3-16 E. Architectural Resources of Fayette Township ---------------- 3-18 4. Summary of Identification and Evaluation Methods----- 4.1 I. OVERVIEW OF PROJECT ADMINISTRATION

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4-1 II. ARCHAEOLOGICAL METHODS- ------ ------ 4-3 III. HISTORICAL AND ARCHITECTURAL METHODS -------------- 4-4 1 I Chapter 2. 3. iii 'fable of Contell1ts VohIlme OIDle Page A bstra.ct i Ackn owl edgmen 1s -------------------------------------------------- i i List of Figures----------------------------------------------------- v List ()f Introduction

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1*1 I. PROJEcr DESCRIPTION

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1-1 II. GEOGRAPHICAL AND ENvIRONMENTAL SETfING ------------------------- 1-2 Sta.tement of Historic Contexts ----------------------------------- 2-1 I. IN1RODUcnON------------------------------------------------------------ 2-1 II. ARCHAEOLOGICAL CONTEXTS ----------------------------------------- 2-1 A. Native American Contact Along the Cedar River ------------------------ 2-1 B. Early Settlement of Fayette Township -.;.--------------------------------- 2-2 C. Agricultural Development of Fayette Township ------------------------- 2-3 D. Industrial Development of Fayette Township -------------------------- 2-6 E. Transportation Development in Fayette Township

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2-8 F. Religion and Education in Fayette Township -----------------------2-10 G. Consolidation Era Resource Development in Fayette Township---2-11 III. HISTORICAL AND ARCHITECTURAL CONTEXTS ------------------------2-12 A. Introduction

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... ----------------------------------2-12 B. Rise of an Agricultural Economy -------------------------------------2-14 C. Town Building ------------------------------------------------------2-17 D. Transportation------------------------------------------------------2-21 E. Architectural Resources of Fayeue Township-----------------------2-21 Associated Property Types ----------------------------------------- 3-1 I.

SUMMARY

OF SURVEY RESULTS ---------------------------------- 3-1 II. ARCHAEOLOGICAL PROPERTY TYPES------------------------------------- 3-2 A. Native American Contact Along the Cedar River------------------------ 3-2 B. Early Settlement of Fayette Township ---------------------------------3-4 C. Agricultural Development of Fayette Township ---------------------- 3-7 D. Industrial Development of Fayette Township 3-8 E. Transportation Development in Fayette Township ----------------------- 3-9 F. Religion and Education in Fayette Township ---------------------------3-10 G. Consolidation Era Resource Development in Fayette Township----3-11 III. HISTORICAL AND ARCHITECTURAL PROPERTY TYPES--------------------3-11 A. Introduction

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3-11 B. Rise of an Agricultural Economy ------------------------------------------3-12 C. Town Buiiding------------------------------:-------------------------------3-15 D. Transportation-----------'---------------------------------------------------3-16 E. Architectural Resources of Fayette Township---------------------------

3-18 Summary of Identification and Evaluation Methods-----1 r. OVERVIEW OF PROJECT AOMINlSTRA TION ----------------------------------- 4-1 II. ARCHAEOLOGICAL METHODS --------------------------------------------- 4-3 III. HISTORICAL AND ARCHITECTURAL MErnODS ----------------------------- 4-4 iv 5. Conclusions and Recommendations -............... s-i A. Archaeological Survey -------- ------------------ 5-B. Historical and Architectural Surveys-- -... 5-2 II. RECOMMENDATIONS 5-3 A. Archeological Resources .....-- 5-3 B. Historical and Architectural Resources--5-4

6. Major Bibliographical References

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6.1 Appendices

--.- ...--- ..-.---...............----------------- ------ --------- A-1 A. Project and Artifact Photographs

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--A-1 B. Artifact Descriptions B-----------------B1 C. Project Publicity and Review Correspondence -...-.-- --I Volume Two Iowa Site Inventory Forms Volume Three Iowa Archaeological Site Inventory Record Forms On file Office of the State Archaeologist, Iowa City, Iowa Not for public dirtribudon Volume Four Photographic Products On file State Historical Society of Iowa, Historic Preservation Bureau, Des Moines, Iowa and Linn County Administrative Building, Cedar Rapids, Iowa , (' : ; .: I : ] i ! : i : 1 ! ) , i ] ! t : i iv S" Conclusions and Recommendations 5 1 I. CONCLUSIONS-------------------------,....----------------------------- 5-1 A. Archaeological Survey -------------------------------------------- 5-1 B. Historical and Architectural Surveys ----------c--------------------- 5-2 II. nONS 5-3 A. Archaeological Resources

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5-3 B. Historical and Architectural Resources------------------------- 5-4 60 Major Bibliographical References----------------------------------- 6 .. 1 Appendices

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.----------------------------------------------A-l A. Project and Artifact Photographs------------------------------------------A-l B

• Artifact J)escriptions

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• ____________________________________________

B-1 C. Project Publicity and Review Correspondence

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:..--------C-l V ohmrne Two Iowa Site Inventory Forms V ohllme 1fJburee Iowa Archaeological Site Inventory Record Forms On me Office of the State Archaeologist, Iowa City. Iowa Not for public distribution V olume IF our Photographic Products Onflle State Historical Society of Iowa, Historic Preservation Bureau, Des Moines, Iowa and Linn COWlty Administrative Building.

Cedar Rapids, Iowa V LIST OF FI GURES Figure Page 1-1 Location of Survey Subsections in Linn County, Iowa ----------1-4 1-2 Location of Project Area ----------...---------------------------------.------------- 1-5 1-3 Landform Regions of Iowa -..... ----------------------. -------------- 1 -6 1-4 GLO Map Showing Project Area ------ --...-----------.......... ------------- 1-7 1-5 1875 Map of Fayette Township ---------.........................------------------- 1-8 2-1 1859 Map of Fayette Township --------- ........................-------------------- 2-39 2-2 1869 Map of Fayette Township -------.............................----------------- 2-40 2-3 Location of Railroads in Linn County -------------------------- 2-41 2-4 1906 Plat of Palo ---------------------------- 2-------------------------------2-422-5 Location of Roadways in Linn County by 1914---- --------------------- 2-43 2-6 1931 Sanborn Fire Insurance Map -------...........................--------------- 2-44 2-7 Linn County Road System -------.-.-- ............................------------------ 2-45 2-8 Highway Planning Map ----- ------ ... ........................ ..--- -.---------

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2-46 2-9 1908 Sears Catalogue

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2-47 2-10 1908 Sears Catalogue

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...--------- 2-48 2-11 1908 Sears Catalogue

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2-49 2-12 1908 Sears Catalogue

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2-50 3-1 Results of the Archaeological Investigation of Subsection E -----3-29 3-2 Areas Surveyed for Archaeological Resources in Subsection E ----------------- 3-30 3-3 Areas with Potential for Buried Historic Archaeological Sites ----------- 3-313-4 Location of Rural Architectural Properties Recorded During Survey ------3-32 3-5 Location of Architectural Properties Recorded in Palo ---------------------------- 3-33 LIST OF TIABLES Table Page 2-1 Post-World War II Plats ---------------------------------------------------

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2-20 3-1 Archaeological Site Summary -------------------------------------.

3-21 3-2 Archaeological Site Historical Associations

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3-25 3-3 Artifact Collections Summary -------------------------------------------------------- 3-27. ! . , i v LIST OF FIGURES Figure Page 1-1 Location of Survey Subsections in Linn County, lowa--------------------------1-4 1-2 I..ocation of Project Area ------------------------------------------------------------ 1-5 1-3 Landform Regions of Iowa------.:------------------------------------------------- 1-6 1-4 OW Map Showing Project Area -------------------------------------------------- 1-7 1-5 1875 Map of Fayette Township----------------------------------------------------- 1-8 2-1 1859 Map of Fayette Township---------------------------------------------------- 39 2-2 1869 Map of Fayette Township----------------------------------------------------- 2-40 2-3 Location of Railroads in Linn County-----------------------------------------------2-41 2-4 1906 Plat of Palo --------------------------------------------------------------------2-42 2-5 Location of Roadways in Linn County by 2-6 1931 Sanborn Fire Insurance Map -------------------------------------------------2-44 2-7 Linn County Road System ----------------------------------------------------------2-45 2-8 Highway Planning Map----------------------------------------------------------2-46 2-9 1908 Sears Catalogue

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2-47 2-10 1908 Sears Catalogue

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2-48 2-11 1908 Sears Catalogue

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2-49 2-12 1908 Sears Catalogue

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50 3-1 Results of the Archaeological Investigation of Subsection E--------------------3-29 3-2 Areas Surveyed for Archaeological Resources in Subsection E -----------------3-30 3-3 Areas with Potential for Buried Historic Archaeological Sites ------------------ 31 3-4 Location of Rural Architectural Properties Recorded Dming Survey -----------3-32 3-5 Location of Architectural Properties Recorded in Palo----------------------------3-33 Table Page 2-1 Post-World War II Plats ----------------------------------------------------------- 20 3-1 Archaeological Site Summary -------------------------------------------------------

3-21 3-2 Archaeological Site Historical Associations

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3-25 3-3 Artifact Collections Summary --------------------------------------------------------

3-27 1-1 INTRODUCTION

1. PROJECT DESCRIPTION The following project was conducted by the Linn County Historic Preservation Commission (HPC) under a grant-in-aid agreement with the State Historical Society of Iowa, Historic Preservation Bureau (SHSI-HPB) through the Certified Local Government (CLG) grants program. The primary objective of this project was to conduct a pilot survey of a minimum of one subsection (designated as Subsection E in the Scope of Work) of Linn County, with the possibility of surveying an additional subsection (Subsection S) as time and budget permitted (Figure 1-1). The survey included examination and recording of architectural and archaeological sites dating from the period 1837-1942.

This comprehensive survey also involved the formulation of a survey model that will be applied to future surveys in other subsections of the county. The specific work elements included archival research, identification of potential site locations, field survey, informant andproperty owner interviews, and preparation of the project end products. Local volunteers participated in all phases of the project and donated over 380 hours to its completion. The project began in August 1992 and will be completed in June of 1993. The archaeological fieldwork was conducted in September-November 1992 and March-April 1993, with the architectural fieldwork conducted in August 1992 and January-August 1993. Historic research, informant interviews, evaluation, and volunteer training wereconducted throughout the project. A training workshop was held as part of the Linn County historic preservation conference on August 30, 1992, with additional presentations given to the Troy Mills Historical Society, the Genealogical Society of Linn County, the Linn County Historical Museum's "History for Lunch" series, and at the Palo Community Center at various times throughout the project. Project and survey publicity was provided through articles in the Cedar Rapids Gazette, the Palo Atom Burst, and through individual mailings of project updates and survey notices to project volunteers, HPC members, and historical groups in the county. A presentation of the project results was given at a workshop as part of the Linn County Historic Preservation Conference on June 13, 1993.This project represents the second phase in a long-term program proposed by the Linn County HPC to identify, evaluate, and register historic properties in Linn County forplanning and preservation purposes. The ultimate goal is to record the historic resources in the entire county outside of the limits of the City of Cedar Rapids. The first phase was conducted in 1991-92 and involved the compilation of a comprehensive planning document, which included the identification of historic contexts and property types associated with the historic development of Linn County as well as the compilation of a bibliography of published and archival holdings and recommendations for future surveys (Rogers 1992). The present, second-phase project is based on these recommendations and expands upon the historic contexts developed by that project.While the period of significance for the present investigation is limited to 1837-1942, the archaeological survey did include the recording of prehistoric period sites when they were encountered during the course of the field survey. Several of the historic period sites were ii II l i \ I , 1 i i j l , i 1-1 1 INTRODUCTION I. PROJECT DESCRIPTION The following project was conducted by the Linn County Historic Preservation Commission (HPC) under a grant-in-aid agreement with the State Historical Society of Iowa, Historic Preservation Bureau (SHSI-HPB) through the Certified Local Government (CLG) grants program. The primary objective of this project was to conduct a pilot survey of a minimum of one subsection (designated as Subsection E in the Scope of Work) of Linn County, with the possibility of surveying an additional subsection (Subsection S) as time and budget pennitted (Figure 1-1). The survey included examination and recording of architectural and archaeological sites dating from the period 1837-1942. This comprehensive survey also involved the fonnulation of a survey model that will be applied to future surveys in other subsections of the county. The specific work elements included archival research, identification of potential site locations, field survey, infonnant and property owner interviews, and preparation of the project end products. Local volunteers participated in all phases of the project and donated over 380 hours to its completion. The project began in August 1992 and will be completed in June of 1993. The archaeological fieldwork was conducted in September-November 1992 and March-April 1993, with the architectural fieldwork conducted in August 1992 and January-August 1993. Historic research, infonnant interviews, evaluation, and volunteer training were conducted throughout the project. A training workshop was held as part of the Linn County historic preservation conference on August 30, 1992, with additional presentations given to the Troy Mills Historical Society, the Genealogical Society of Linn County, the Linn County Historical Museum's "History for Lunch" series, and at the Palo Community Center at various times throughout the project Project and survey publicity was provided through articles in the Cedar Rapids Gazette, the Palo Atom Burst, and through individual mailings of project updates and survey notices to project volunteers, HPC members, and historical groups in the county. A presentation of the project results was given at a workshop as part of the Linn County Historic Preservation Conference on June 13, 1993. This project represents the second phase in a long-tenn program proposed by the Linn County HPC to identify, evaluate, and register historic properties in Linn County for planning and preservation purposes. The ultimate goal is to record the historic resources in the entire county outside of the limits of the City of Cedar Rapids. The first phase was conducted in 1991-92 and involved the compilation of a comprehensive planning document, which included the identification of historic contexts and property types associated with the historic development of Linn County as well as the compilation of a bibliography of published and archival holdings and recommendations for future surveys (Rogers 1992). The present, second-phase project is based on these recommendations and expands upon the historic contexts developed by that project. While the period of significance for the present investigation is limited to 1837-1942, the archaeological survey did include the recording of prehistoric period sites when they were encountered during the course of the field survey. Several of the historic period sites were 1-2 situated in areas that had also been the locus for prehistoric habitation and are, therefore, recorded as multi-component archaeological sites. The beginning date for the survey period of significance relates to the first permanent Euro-American settlement in the county, while the end date represents the arbitrary 50 year cut-off date for inclusion in the National Register of Historic Places (NRHP). All of the historic properties recorded during the course of this project were evaluated as to their potential eligibility for nomination to the NRHP.][. GEOGRAPHICAL AND ENVIRONMENTAL SETTING The project area is situated in the west-central portion of Linn County, Iowa, and encompasses roughly all but the southern tier of sections within the legal boundaries of Fayette Township and including the incorporated town of Palo (Figure 1-2). The survey area is bounded on the north and east by the present course of the Cedar River, on the westby the Linn/Benton county line, and on the south by Yates Road. The southern boundary line is actually an extension of the original Subsection E boundary line, which was drawn along Highway 94/E36 (Shellsburg Road) (see Figure 1-1). It was decided during the course of the survey to extend this boundary further south in order to better record the resources associated with the town of Palo. Therefore, the potential survey area of Subsection J to the south has been reduced. Time did not permit an examination of Subsection S (or Fl as it was labeled in the SOW), and as a result, this subsection remains for future investigations. Linn County and the project area are situated at the southeastern edge of the landform region known as the Iowan Surface at its intersection with the Southern Iowa Drift Plain (Figure 1-3). The Iowan Surface is characterized by level to gently rolling terrain with stepped topography toward drainage divides and well established, dendritic drainage systems. Areas of poor drainage and wetlands are typical of this region as well as scattered areas of large fieldstones or glacial erratics across the ground surface. Slopes are steeper in the larger river valleys of the southern third of the Iowan Surface region, and prominent, elongated ridges and "isolated oblong hills, known as paha" are characteristic features of the landscape (Prior 1991:72). Paha are erosional remnants of the once higher and older Pre-Illinoian glacial plain and are preserved by thick windblown, loess deposits. A paha is present to the northwest of the town of Palo in the vicinity of the Pleasant Creek State Park.The Iowan Surface region was "last visited by glaciers in Pre-Illinoian time and since then has lain exposed to various episodes of weathering and soil development, erosion, and loess deposition" (Prior 1991:69). A variety of Pleistocene sediments, including Wisconsinan-age loess, mantle the near-surface limestone bedrock of this region. The accessibility of this bedrock has made quarrying a common activity in this region, including the project area, both historically and to the present (lbid.:75). A small portion of the Southern Iowa Drift Plain fingers into the southeast comer of the project area (see Figure 1-3). This landform region is characterized by "level upland divides, steeply rolling hillslopes, and lowland valley floors" (Prior 1991:64). In east-central Iowa, this landform region is more dissected and deeply cut by streams than other areas of this region (Ibid.:63-64). The Southern Iowa Drift Plain was formed by successive glacial ice sheet advances and retreats, with the most recent having occurred during the Kansan stage of glaciation. The landscape has a moderate to thick loess mantle,with Pre-Illinoian glacial drift and the underlying sedimentary bedrock exposed within the deeper stream valleys. The limestone bedrock of this landform region is also commonly quarried (Ibid.:60-67). 1-2 situated in areas that had also been the locus for prehistoric habitation and are, therefore, recorded as mUlti-component archaeological sites. The beginning date for the survey period of significance relates to the first pen:nanent Eum-American settlement in the county, while the end date represents the arbitrary 50 year cut-off date for inclusion in the National Register of Historic Places (NRHP). All of the historic properties recorded during the course of this project were evaluated as to their potential eligibility for nomination to the NRHP. n. GEOGRAPHICAL AND ENVIRONMENTAL SETTING The project area is situated in the west-central portion of Linn County, Iowa, and encompasses roughly all but the southern tier of sections within the legal boundaries of Fayette Township and including the incorporated town of Palo (Figure 1-2). The survey area is bounded on the north and east by the present course of the Cedar River, on the west by the LinnlBenton county line, and on the south by Yates Road. The southern boundary line is actually an extension of the original Subsection E boundary line, which was drawn along Highway 941E36 (Shellsburg Road) (see Figure 1-1). It was decided during the course of the survey to extend this boundary further south in order to better record the resources associated with the town of Palo. Therefore, the potential survey area of Subsection J to the south has been reduced. Time did not permit an examination of Subsection S (or Fl as it was labeled in the SOW), and as a result, this subsection remains for future investigations. Linn County and the project area are situated at the southeastern edge of the landfonn region known as the Iowan Surface at its intersection with the Southern Iowa Drift Plain (Figure 1-3). The Iowan Surface is characterized by level to gently rolling terrain with stepped topography toward drainage divides and well established, dendritic drainage systems. Areas of poor drainage and wetlands are typical of this region as well as scattered areas of large fieldstones or glacial erratics across the ground surface. Slopes are steeper in the larger river valleys of the southern third of the Iowan Surface region, and prominent, 'elongated ridges and "isolated oblong hills, known as palla" are characteristic features of the landscape (Prior 1991 :72). Paba are erosional remnants of the once higher and older Pre-lllinoian glacial plain and are preserved by thick windblown, loess deposits. A paba is present to the northwest of the town of Palo in the vicinity of the Pleasant Creek State Parle The Iowan Surface region was "last visited by glaciers in Pre-lllinoian time and since then has lain exposed to various episodes of weatheripg and soil development, erosion, and loess deposition" (Prior 1991:69). A variety of Pleistocene sediments. including Wisconsinan-age loess, mantle the near-surface limestone bedrock of this region. The accessibility of this bedrock has made quarrying a common activity in this region, including the project area, both historically and to the present (Ibid.:75). A small portion of the Southern Iowa Drift Plain fingers into the southeast comer of the project area (see Figure 1-3). This landform region is characterized by "level upland divides, steeply rolling hillslopes, and lowland valley floors" (Prior 1991 :64). In central Iowa, this landform region is more dissected and deeply cut by streams than other areas of this region (Ibid.:63-64). The Southern Iowa Drift Plain was formed by successive glacial ice sheet advances and retreats, with the most recent having occurred during the Kansan stage of glaciation. The landscape has a moderate to thick loess mantle, with Pre-Dlinoian glacial drift and the underlying sedimentary bedrock exposed within the deeper stream Valleys. The limestone bedrock of this landfonn region is also commonly quarried (Ibid.:60-67). 1-3 The bedrock underlying the project area is primarily of the Devonian system (formed 365-387 millions of years ago), with some deposits of the Silurian system (415-435 millions of years ago) also present (Linn County Zoning Commission 1961:13; Prior 1991:16-17). The Devonian system, in particular, is "one of the most valuable sources of usable commercial stone in Iowa," with its shale used in the manufacture of brick and tile and its limestone used to make cement, road stone, and concrete aggregate (Linn County Zoning Commission 1961:13-14). Historically, these deposits were quarried in Linn County for building stone and for burning to manufacture mortar lime. Both activities were carried out in the project area, with at least six known quarries and one lime kiln having been in operation at various times in Fayette Township.In the project area, the Cedar River Valley "displays extensive terrace formations, low-lying abandoned meanders, sloughs, and oxbow lakes" (Perry 1983:3). In the LewisBottoms and Pleasant Creek vicinity, colluvial and alluvial footslope and fan deposits line the bluff base. The 800 ft elevation contour line demarcates the rolling, dissected upland bluffs, while the footslope and fan deposits are outlined by the 770-800 contours. In addition, the 750 ft contour roughly marks the escarpment between the extensive terraces and the lower, more recent alluvial deposits and features of the Cedar River floodplain (Ibid.).The environmental context of the project area at the time of Euro-American settlement is shown in Figure 1-4, which shows that much of the project area was covered by timber when the General Land Office (GLO) original survey was made 1841. Small patches of prairie and wet lands were present north of Bear Creek and near the Cedar River, with the area south of Bear Creek being largely covered by prairie (see Figure 1-4). By 1875 the timbered areas had been reduced, although large groves still remained in the upland areas of northern Fayette Township along the Linn/Benton county line (Figure 1-5). The diversity of this landscape supported a variety of subsistence resources and made the area attractive to early settlers. The timber provided both fuel and building materials, while the prairiemargins provided a clear area for the first fields, some of which are shown on Figure 1-4.The proximity to the river and its rich soils and biotic resources was also attractive to early settlers.1-3 The bedrock underlying the project area is primarily of the Devonian system (formed 365-387 millions of years ago), with some deposits of the Silurian system (415-435 millions of years ago) also present (Linn County Zoning Commission 1961:13; Prior 1991:16-17). The Devonian system, in particular, is "one of the most valuable sources of usable commercial stone in Iowa," with its shale used in the manufacture of brick and tile and its limestone used to make cement, road stone, and concrete aggregate (Linn County Zoning Commission 1961: 13-14). HistoricalJy, these deposits were quarried in Linn County for building stone and for burning to manufacture mortar lime. Both activities were carried out in the project area, with at least six known quarries and one lime kiln having been in operation at various times in Fayette Township. In the project area, the Cedar River Valley "displays extensive terrace fonnations, lying abandoned meanders, sloughs, and oxbow lakes" (perry 1983:3). In the Lewis Bottoms and Pleasant Creek vicinity, colluvial and alluvial footslope and fan deposits line the bluff base. The 800 ft elevation contour line demarcates the rolling, dissected upland bluffs, while the footslope and fan deposits are outlined by the 770-800 contours. In addition, the 750 ft contour roughly marks the escarpment between the extensive terraces and the lower, more recent alluvial deposits and features of the Cedar River floodplain (Ibid.). The environmental context of the project area at the time of Bum-American settlement is shown in Figure 1-4, which shows that much of the project area was covered by timber when the General Land Office (GW) original survey was made 1841. Small patches of prairie and wet lands were present north of Bear Creek and near the Cedar River, with the area south of Bear Creek being largely covered by prairie (see Figure 1-4). By 1875 the timbered areas had been reduced, although large groves still remained in the upland areas of northern Fayette Township along the LinnlBenton county line (Figure 1-5). The diversity of this landscape supported a variety of subsistence resources and made the area attractive to early settlers. The timber provided both fuel and building materials, while the prairie margins provided a clear area for the ftrst ftelds, some of which are shown on Figure 1-4. The proximity to the river and its rich soils and biotic resources was also attractive to early settlers. 1-4 i--i ii Original I .. 1 aI Adjusted iL .-" boundary , U H 1 It, PA.'L T O44 SBETO O IFAIRFAXJ 14T. VERNODN 0 1-33 Ev incorporated CitylUnincorporated Community FIGURE1-LOCATION OF SURVEY SUBSECTIONS IN LINN COUNTYý IOWA I , I 1-4 ------r I I I I IlAL)(ER 0 i A COGGON c B D I I I .\ r I 1145 [;J I .\ I I H IlWY. 13 Original boundary Adjusted .+-__ boundary J I I FAIRFAX JI" I 1( 1-300 r* : 1 ntRTRAM .r Q I .' Wt!8Tr.ruf I F.r.e ......... u..... ..... _._.,. ________ _ ---_. Incorporated City Cl Unincorporated Community

• FIGURE 1 .. 1 LOCATION OF SURVEY SUBSECTIONS IN LINN COUNTY, IOWA A-1...... i W m* I 8 888 !8.m.J Oha* .-. .8888 -~VI j *88 8K' I 081 I 0880*88. IA~* j .1.'-. __I 88? AVAt, 8018 I* *.-.-.88 8880 Oj b8N8~I 8.~~~1* 8*8 43.18 I __W,8fl8*88 V 8 8 8 100888888881 I I V~~'L880 *8 , l@*tooowj.ii>. ..~.'1 78*888,0 I H 0 800.1 81 0*8 81~I -~ 8 kY I8A.8~A 6* .180* or' 8.3.80 88*808! 0.88*8~~ 1C 40 MIlt ... ....... "-.. -.:.--..}

FIGURE 1 .. 3 LANDFORM REGIONS OF low A (From Prior 1991) 1-7= = = = ---== ---- -w = = ---U Iý3 -GROVES -CREEKS 3 -HOUSES E] -FI=S~o ROADS & TRAITZ * .HILL PONDl OR HILL FIGURE 1-4 GLO SURVEY MAP SHOWING PROJECT AREA 1-7 / 'fI.j (3 \." J . I , U i i ,0 'l (,\ -GROVES '""-."-'"

• CRIlEKS II
• HOUSES o* rrm.os -ROI\OS (. TAAlJ.s * . HILL POND OR HILL FIGURE 1 .. 4 GLO SURVEY MAP SHOWING PROJECT AREA 1-8 FIGURE 1-5 1875 MAP OF FAYETTE TOWNSHIP (FROM ANDREAS 1970): ) : i* : ! ] : i 1-8 FIGURE 1 .. 5 1875 MAP OF FAYETTE TOWNSHIP (FROM ANDREAS 1970) 2-1 aTATEMENTS OF HISTORIC CONTEXTS 1. INTRODUCTION The following historic contexts are based on the contexts developed in the first phase comprehensive planning document (Rogers 1992). That study identified four major contexts based on the general historical/chronological developments that affected Linn County during the historic period. These contexts involved four eras of development and included:

Native American Contact, 1830s-1870s; Early Settlement, 1837-1859; Expansion, 1859-1913; and Consolidation, 1913-present (Ibid.:9). Within each era, a number of subcontexts were also identified and consisted of the development of communities, commercial districts, transportation, agriculture, industry, religion, education, social culture, and architecture in the county as well as identifying some of the notable persons associated with these developments. The present study expands upon these contexts in addition to identifying new contexts pertinent to the historical development of the study area.H. ARCHAEOLOGICAL CONTEXTS A. Native American Contact Along theC River The Native American Contact Era represents a period when Native American groups such as the Mesquakie and Winnebago were coming into contact with Euro-American settlers within the borders of present-day Linn County. While Native Americans were present in this area prior to the advent of Euro-Americans, this contact marks the beginning of the"historic" period as opposed to the previous "proto-historic" and "prehistoric" periods in this region. The presence of Native Americans in Linn County during the prehistoric period is documented in the habitation sites and burial mounds recorded to date along theCedar River and its tributaries, including a number of such sites recorded in the Pleasant Creek State Park prior to the creation of the lake (Benn and Hovde 1976), but was not the focus of the present investigation. In the project area, contacts with the Mesquakie after 1830 are documented in the historical accounts of this area, particularly near the Cedar River and in the Palo vicinity (Browne 1980; Centennial Committee 1979; Mills 1958). Generally, these encounters were friendly ones, although one account noted that "a tribe of Indians invaded Sarah McClintock's farm kitchen and took most of their food supplies" (Centennial Committee 1979:17). The McClintock farm was located approximately

2.5 miles

north-northeast of Palo. There is some evidence that Hiram Usher, whose family settled along the Cedar River southeast ofPalo, operated a trading post at an early date near the later town of Covington (Browne 1980). The location of this post, however, is outside of the present survey area. While the historical accounts are not very specific on the location of the camp sites where the Mesquakie were encountered by the early settlers, it is expected that habitable areas along the Cedar River and its tributaries would have been good locations for such sites.2-1 2 STATEMENTS OF HISTORIC**CONTEXTS I. INTRODUCTION The following historic contexts are based on the contexts developed in the first phase comprehensive planning document (Rogers 1992). That study identified four major contexts based on the general historical/chronological developments that affected Linn County during the historic period. These contexts involved four eras of development and included: Native American Contact, 18308*1870s; Early Settlement, 1837-1859; Expansion, and Consolidation, 1913-present (Ibid.:9). Within each era. a number of subcontexts were also identified and consisted of the development of communities, cOtmllercial districts, transportation, agriculture, industry, religion, education, social cultme, and architecture in the county as well as identifying some of the notable persons associated with these developments. The present study expands upon these contexts in addition to identifying new contexts pertinent to the historical development of the study area. n. ARCHAEOLOGICAL CONTEXTS A. Native American Contact Along the Cedar Riyer The Native American Contact Era represents a period when Native American groups such as the Mesquakie and Winnebago were coming into contact with Euro-American settlers within the borders of present-day Linn County. While Native Americans were present in this area prior to the advent of Euro-Americans, this contact marks the beginning of the "historic" period as opposed to the previous "proto-historic" and "prehistoric" periods in this region. The presence of Native Americans in Linn County during the prehistoric period is documented in the habitation sites and burial mounds recorded to date along the Cedar River and its tributaries, including a number of such sites recorded in the Pleasant Creek State Park prior to the creation of the lake (Benn and Hovde 1976), but was not the focus of the present investigation. In the project area. contacts with the Mesquakie after 1830 are documented in the historical accounts of this area, particularly near the Cedar River and in the Palo vicinity (Browne 1980; Centennial Committee 1979; Mills 1958). Generally, these encounters were friendly ones, although one account noted that "a tribe of Indians invaded Sarah McClintock's fann kitchen and took most of their food supplies" (Centennial Committee 1979: 17). The McClintock fann was located approximately

2.5 miles

north-northeast of Palo. There is some evidence that Hiram Usher, whose family settled along the Cedar River southeast of Palo, operated a trading post at an early date near the later town of Covington (Browne 1980). The location of this post, however, is outside of the present survey area. While the historical accounts are not very specific on the location of the camp sites where the Mesquakie were encountered by the early settlers, it is expected that habitable areas along the Cedar River and its tributaries would have been good locations for such sites. 2-2 B. Early Settlement of Fayette TownshipThe Early Settlement Era in the project area began two years later than in the county as a whole, with the first permanent settler arriving in 1839, rather than in 1837. This settler was Joseph Strawn, who migrated from Pennsylvania and settled 3-1/2 miles northwest of the later town of Palo on March 28, 1839 (Centennial Committee 1979:3). He was soon followed by Thomas and John Lewis, who arrived in Fayette Township in April that same year. The Lewis brothers had migrated from Ohio and were subsequently followed by the many members of their family (Ibid.). The bottomland in the northern portion of Fayette Township is named Lewis Bottoms in their honor as were the Lewis Bottom school and church. Thomas Lewis' farm consisted of 400 acres in northern Fayette Township by 1859, while other Lewis family holdings comprised an additional estimated 520 acres in central and southwestern Fayette Township. John Lewis also built the first gristmill in thetownship northwest of Palo on Bear Creek near the Linn/Benton county line. The Lewis family remain among the prominent landholders of the township to the present day, with a large portion of the original holdings still under Lewis family ownership. The Lewis Bottoms neighborhood created by the settlement of this family and their relations is further discussed in Section Ill-B of this chapter.Other settlers arriving before 1859 included: John Cue, who settled one mile north of Paloin 1839; P.B. Yates, who settled just southeast of Palo in 1850 and for whose family Yates Road was named; John Mills, who settled 1/2 mile west-southwest of Palo in 1852;Samuel and W.J. Whiting, who settled 3/4 mile southeast; Nathaniel Chipman, who settled 1-1/4 miles west of Palo c. 1848; James McArthur and Joseph McMannis, who came in 1846 and 1851, respectively, and settled on farms less than one mile south of Palo;Stephen Morris, who settled near John Cue in 1854; John G. Cole, who purchased a farm in 1854; and Peter McVay, who settled less than one mile northwest of Palo (Centennial Committee 1979:3-5; Western Historical Company 1878:585-586). Some early settlers, such as William Wheeler, settled here for a short time before moving further west;however, many of the earliest settlers were still in the township by 1859.Figure 2-1 shows the landholdings and house locations in the study area in 1859. As canbe seen, approximately 2,500 acres, mainly in the northern half of the township and bordering the bank of the Cedar River, were still unentered by that time. There were fewer houses in the northern half as well, with the densest population being located within a two mile radius of the town of Palo. Compared with other areas in Linn County that bordered the major waterways and had virtually the same environmental context as this township, the project area was not as densely settled during the early settlement era. One probable reasonfor the large amount of unentered land in the northern half of Fayette Township, and the low settlement density in that area, is the fact that much of the bottomland in this area is still characterized by extensive marshes and oxbow lakes to the present day and would have been difficult to put into agricultural production without large-scale drainage efforts. As a result, a notable percentage of the township's land surface was not suitable for early agriculture and, therefore, retarded settlement. In 1856, Fayette Township had a total population of 491, a number which comprised only 3% of the total population of Linn County. Of the 491 persons, 270 were males and 221 were females, representing 88 families and 88 dwelling houses (Iowa State Population Census 1856).The town of Palo had its beginnings when John Hollenbeck settled at the future townsite, although the exact date of this initial settlement is not known except that it was between 1839 and 1845. Much of his farm later became the town of Palo, with Hollenbeck platting the entire north addition to the town in 1857. He also deeded the lots for the Methodist Church and parsonage, served as Palo's first preacher and postmaster, and operated the first hotel and tavern along the stage road from Marion. The post office was established in; ! ; i \ i : j 2-2 B. Early Settlement of Fayette Township The Early Settlement Era in the project area began two years later than in the county as a whole, with the first pennanent settler arriving in 1839, rather than in 1837. This settler was Joseph Strawn, who migrated from Pennsylvania and settled 3-1/2 miles northwest of the later town of Palo on March 28.1839 (Centennial Committee 1979:3). He was soon followed by Thomas and John Lewis, who arrived in Fayette Township in April that same year. The Lewis brothers had migrated from Ohio and were subsequently followed by the many members of their family (Ibid.). The bottomland in the northern portion of Fayette Township is named Lewis Bottoms in their honor as were the Lewis Bottom school and church. Thomas Lewis' fann consisted of 400 acres in northern Fayette Township by 1859, while other Lewis family holdings comprised an additional estimated 520 acres in central and southwestern Fayette Township. John Lewis also built the first gristmill in the township northwest of Palo on Bear Creek near the Linn/Benton county line. The Lewis family remain among the prominent landholders of the township to the present day, with a large portion of the original holdings still under Lewis family ownership. The Lewis Bottoms neighborhood created by the settlement of this family and their relations is fwther discussed in Section Ill-B of this chapter. Other settlers arriving before 1859 included: John Cue, who settled one mile north of Palo in 1839; P.B. Yates, who settled just southeast of Palo in 1850 and for whose family Yates Road was named; John Mills, who settled 1/2 mile west-southwest of Palo in 1852; Samuel and W J. Whiting, who settled 3/4 mile southeast; Nathaniel Chipman, who settled 1-1/4 miles west of Palo c. 1848; James McArthur and Joseph McMannis, who came in 1846 and 1851, respectively, and settled on farms less than one mile south of Palo; Stephen Morris, who settled near John Cue in 1854; John G. Cole, who purchased a farm in 1854; and Peter McVay, who settled less than one mile northwest of Palo (Centennial Committee 1979:3-5; Western Historical Company 1878:585-586). Some early settlers, . such as William Wheeler, settled here for a short time before moving further west; however, many of the earliest settlers were still in the township by 1859. Figure 2-1 shows the landholdings and house locations in the study area in 1859. As can be seen, approximately 2,500 acres, mainly in the northern half of the township and bordering the bank of the Cedar River, were still unentered by that time. There were fewer houses in the northern half as well, with the densest population being located within a two mile radius of the town of Palo. Compared with other areas in Linn County that bordered the major waterways and had virtually the same environmental context as this township, the project area was not as densely settled during the early settlement era. One probable reason for the large amount of unentered land in the northern half of Fayette Township, and the low settlement density in that area, is the fact that much of the bottomland in this area is still characterized by extensive marshes and oxbow lakes to the present day and would have been difficult to put into agricultural production without large-scale drainage efforts. As a result, a notable percentage of the township'S land surface was not suitable for early agriculture and, therefore, retarded settlement. In 1856, Fayette Township had a total population of 491, a number which comprised only 3% of the total population of Linn County. Of the 491 persons, 270 were males and 221 were females, representing 88 families and 88 dweUing houses (Iowa State Population Census t 856). The town of Palo had its beginnings when John Hollenbeck settled at the future townsite, although the exact date of this initial settlement is not known except that it was between 1839 and 1845. Much of his farm later became the town of Palo, with Hollenbeck platting the entire north addition to the town in 1857. He also deeded the lots for the Methodist Church and parsonage, served as Palo's first preacher and postmaster, and operated the first hotel and tavern along the stage road from Marion. The post office was established in 2-3 1848 and was first named Hollenbeck in honor of the postmaster. The town of Palo was not officially platted until 1854 and was located in the northwest quarter of Section 29, T84N-R8W. It was the ninth town established in Linn County (Centennial Committee 1979:1; Rogers 1992:23; Western Historical Company 1878:585). Among the early settlers in the town of Palo were: John G. Cole, who settled south of Dry Creek in 1854 and had the townsite surveyed by John McArthur that same year;, George C.McCorkle, stepson of John Hollenbeck and who settled here in 1845; Curtis Dunklee, who was a cooper and settled near Hollenbeck in 1856; John McCray, who erected the first log cabin in the southwest part of town in 1854 and operated a sawmill at this location for a short time before his untimely death; John Stratford, who established a shoe and boot store that operated for 20 years; Thomas J. McConaly, who operated a blacksmith shop for a number of years starting in 1854; and David Johnson, who worked as a carpenter after he settled here in 1856 (Centennial Committee 1979:5-6). By 1859, the businesses of Palo included a shoe/boot shop, a general store, at least two blacksmith shops, a drugstore, two hotels, and a sawmill (Centennial Committee 1979; Western Historical Company 1878:585-587). According to the 1856 state census in the township as a whole, there were 82 farmers, five carpenters, four blacksmiths, three laborers, three stage drivers, one millwright, one cooper, one shoe maker, one gunsmith, and one physician, with the majority of businesses excluding farming being located in Palo. Another exception is the millwright, who was operating the gristmill on Bear Creek Of the 491 people enumerated in the 1856 state census for Fayette Township, only 22 (5%)were foreign born, with the majority being persons who hailed from the Eastern and Old Northwest states of Ohio (n= 174), New York (n= 53), Pennsylvania (n= 42), and Indiana (n= 39). Early settlers who were Iowa born numbered 74. Other states represented in lesser numbers were Illinois (n= 33), Virginia (n= 13), New Jersey (n= 9), Massachusetts (n= 7), Connecticut (n= 4), Maine (n=l ), Vermont (n= 1), Maryland (n= 2), Mississippi (n= 2), Michigan (n= 2), North Carolina (n= 1), Delaware (n= 1), Kentucky (n= 1), and New Hampshire (n= 1). One entry had an unknown birthplace because of an illegible entry in the census. Of the 22 foreign-born, 13 were from Canada, two were from Sweden, two were from Scotland, two were from England, two were from Germany, and one was from Ireland.In comparison with the nativity of early settlers in Linn County as a whole, Fayette Township generally reflects the same pattern, with Ohio being the highest percentage in both the township and the county, and Pennsylvania and New York also ranking high (Brewer and Wick 1911:322). Similarly, the percentage of foreign-born was comparable for both the township and the county, with this segment comprising 5% and 8%, respectively of the total populations. While the number of Canadians in Fayette Township suggests something of a small enclave, this number comprises only four households and likely represents an extended family settlement, while the other foreign-born represent only one household for each group.C. Agricultural Development of Fayette Township During the Early Settlement Erm the main focus of agriculture was on subsistence, with the main crops being wheat and com. These crops were relatively easy for the early farmers to grow in Linn County and gave them products on which they could subsist as well as use for a market commodity when the opportunity arose. The raising of corn, wheat, and other grain crops was supplemented with livestock raising, including hogs, cattle, horses, and sheep. Hogs were the primary market income producers and required little in the way of j i i , J ; i : .1 ; : j t : i : 1 2-3 1848 and was first named Hollenbeck in honor of the postmaster. TIle town of Palo was not officially platted until 1854 and was located in the northwest quarter of Section 29, T84N-R8W. It was the ninth town established in Linn County (Centennial Committee 1979:1; Rogers 1992:23; Western Historical Company 1878:585). Among the early settlers in the town of Palo were: John G. Cole, who settled south of Dry Creek in 1854 and had the townsite surveyed by John McArthur that same year, George C. McCorkle, stepson of John Hollenbeck and who settled here in 1845; Curtis Dunklee, who was a cooper and settled near Hollenbeck in 1856; John McCray, who erected the first log cabin in the southwest part of town in 1854 and operated a sawmill at this location for a shon time before his untimely death; John Stratford, who established a shoe and boot store that operated for 20 years; Thomas J. McConaly, who operated a blacksmith shop for a number of years starting in 1854; and David Johnson. who worked as a carpenter after he settled here in 1856 (Centennial Committee 1979:5-6). By 1859, the businesses of Palo included a shoe/boot shop, a general store, at least two blacksmith shops, a drugstore. two hotels, and a sawmill (Centennial Committee 1979; Western Historical Company 1878:585-587). . According to the 1856 state census in the township as a whole, there were 82 farmers, five carpenters, four blacksmiths, three laborers, three stage drivers, one millwright, one cooper, one shoe maker, one gunsmith, and one physician, with the majority of businesses excluding fanning being located in Palo. Another exception is the millwright, who was operating the gristmill on Bear Creek.. . Of the 491 people enumerated in the 1856 state census for Fayette Township. only 22 (5%) were foreign born. with the majority being persons who hailed from the Eastern and Old Northwest states of Ohio (n= 174), New York (n= 53), Pennsylvania (n= 42), and Indiana (n= 39). Early settlers who were Iowa born numbered 74. Other states represented in lesser numbers were TIlinois (n= 33), Virginia (n= 13), New Jersey (n= 9), Massachusetts (n= 7), Connecticut (n= 4), Maine (n=1 ), Vennont (n= 1), Maryland (n= 2), Mississippi (n= 2). Michigan (n= 2), North Carolina (n= 1), Delaware (n= I), Kentucky (n= I), and New Hampshire (n= 1). One entry had an unknown birthplace because of an illegible entry in the census. Of the 22 foreign-born, 13 were from Canada, two were from Sweden, two were from Scotland, two were from England, two were from Gennany, and one was from Ireland. In comparison with the nativity of early settlers in Linn County as a whole, Fayette Township generally reflects the same pattern, with Ohio being the highest percentage in both the township and the county, and Pennsylvania and New York also ranking high (Brewer and Wick 1911 :322). Similarly, the percentage of foreign-born was comparable for both the township and the county, with this segment comprising 5% and 8%, respectively of the total populations. While the number of Canadians in Fayette Township suggests something of a small enclave, this number comprises only four households and likely represents an extended family settlement, while the other foreign-born represent only one household for each group. . C. Agricultural Development of Fayette Township During the Early Settlement the main focus of agriculture was on subsistence, with the main crops being wheat and com. These crops were relatively easy for the early fanners to grow in Linn County and gave them products on which they could subsist as well as use for a market commodity when the opportunity arose. The raising of corn, wheat, and other grain crops was supplemented with livestock raising, including hogs, cattle, horses, and sheep. Hogs were the primary market income producers and required little in the way of 2-4 tending because livestock were allowed to range freely during this era without the restriction of fencing. Cattle were raised almost exclusively to supply the need for broodand milk cows, with oxen being raised for pulling wagons and plows. Very little beef was either eaten or shipped out. Likewise, sheep were raised primarily for their wool and seldom for their meat (Strong 1990:65, 72, 120-127).Early agriculture in Fayette Township followed much the same pattern, with wheat being"the great crop grown" by the pioneers (Mills 1958:205). It was, in fact, the only "money crop" many farmers had, and "although it was thought to be hard on the land, it was grown in large quantities for a number of years" (Ibid.:205-206). Corn, on the other hand, was a crop of lesser importance, with each farmer generally raising only "enough for his own useand a little more that could be sold if that needed to be done but nearly all the corn raised by any settler was fed to the stock on his own farm" (Ibid.:206). A description of early agriculture in Fayette Township has noted that:hogs were fattened on corn but most farmers raised not many more than enough to supply their families with what meat would be needed throughout the year. Eight or ten cowsmade up a good herd, there being practically no sale for milk any where. Most men kept what horses and oxen were needed for the farm work and perhaps a riding horse or a buggy team if he could afford to have them, but nor a great deal of grain was needed to feed the stock on an average farm (Mills 1958:205). Other crops grown besides wheat and corn were buckwheat, flax, and hay. Maple sugar gathering was also a noted activity in Fayette Township at an early date, following a Native American practice that the early settlers observed (Centennial Committee 1979:17; Mills 1958). Sheep were also of some importance in Fayette Township, with some farmers going "into the sheep raising business in a big way" (Mills 1958:212). Sheep and hogs, however, were prone to disease because they tended to huddle close together at night, and the raising of such livestock was a risky business.The 1856 Iowa State Census also tallied the agricultural statistics, and in Fayette Townshipthese showed that in actuality the primary crop grown was corn (2195 acres; 51, 300 bushels) followed by wheat (486 acres; 6617 bushels), oats (304 acres; 8962 bushels), and potatoes (12 acres; 1598 bushels). The number of hogs sold was tallied at 662, while only 128 cattle had been sold. Domestic and general manufactures included butter (4125 lbs.), cheese (104 lbs.), and wool (499 lbs.). In addition, 153 tons of hay had been harvested. The predominance of corn production over wheat is somewhat at odds with the historical accounts, but may reflect the fact that true subsistence farming did not persist much beyond the initial years of frontier settlement, and that Fayette Township farmers were becoming more involved in market-oriented agriculture by the mid- 1850s. The arrival of the railroad into Linn County in 1859 signaled the beginning of a long progression of agricultural changes that extended through the late nineteenth and twentieth centuries. Early Settlement Era farmsteads were generally small in size, with the average size in the state being 165 acres with that in Linn County being slightly smaller. In 1860 the greatest number of farms in Linn County were between 20-100 acres in size (U.S. Agricultural Census 1860). In Fayette Township, the size of the, 93 farmsteads by 1859 ranged from a low of 20 to a high of 400 acres, with the average farm size being approximately 107 acres.Early Settlement Era farmsteads: in Linn County generally consisted of few buildings other than the house, a root cellar, stables, and rudimentary corncribs and granaries. Hay was stacked outdoors, and livestock was commonly allowed to roam free. The benefits of barns and sheds was largely unrecognized at this early date; however, in Fayette Township, the typical pioneer farmstead also included log or straw barns and sheep shedsthat afforded some protection for the livestock from the cold winter weather. At least one*. I :. I , ! I 2-4 tending because livestock were allowed to range freely during this era without the restriction of fencing. Cattle were raised almost exclusively to supply the need for brood and milk cows, with oxen being raised for pulling wagons and plows. Very little beef was either eaten or shipped out. Likewise, sheep were raised primarily for their wool and seldom for their meat (Strong 1990:65.72, 120-127). Early agriculture in Fayette Township followed much the same pattern, with wheat being "the great crop grown" by the pioneers (Mills 1958:205). It was, in fact, the only "money crop" many fanners had, and "although it was thought to be hard on the land, it was grown in large quantities for a number of years" (Ibid.:205-206). Com, on the other hand, was a crop of lesser imponam;:e, with each farmer generally raising only "enough for his own use and a little more that could be sold if that needed to be done but nearly all the com raised by any settler was fed to the stock on his own farm" (Ibid.:206). A description of early agriculture in Fayette Township has noted that: hogs were fattened on com but most farmers raised nol many more than enough to supply their families with what meal would be needed throughout the year. Eight or ten cows made up a goOd herd, there being pmctically no sale for milk any where. Most men kept what horses and oxen were needed for the fann work. and perhaps a riding horse or a buggy team jf he could afford to have them, but not a great deal of gnUn was needed to feed the stock on an average fann (Mills 1958:205). Other crops grown besides wheat and com were buckwheat, flax, and hay. Maple sugar gathering was also a noted activity in Fayette Township at an early date, following a Native American practice that the early settlers observed (Centennial Committee 1979:17; Mills 1958). Sheep were also of some imponance in Fayette Township, with some farmers going "into the sheep raising business in a big way" (Mills 1958:212). Sheep and hogs, however, were prone to disease because they tended to huddle close together at night, and the raising of such livestock was a risky business. The 1856 Iowa State Census also tallied the agricultural statistics, and in Fayette Township these showed that in actuality the primary crop grown was com (2195 acres; 51,300 bushels) followed by wheat (486 acres; 6617 bushels), oats (304 acres; 8962 bushels), and potatoes (12 acres; 1598 bushels). The number of hogs sold was tallied at 662, while only 128 cattle had been sold. Domestic and general manufactuIes included butter (41251bs.), cheese (l041bs.), and wool (4991bs.). In addition, 153 tons of hay had been harvested. The predominance of corn production over wheat is somewhat at odds with the historical accounts, but may reflect the fact that true subsistence farming did not persist much beyond the initial years of frontier settlement, and that Fayette Township farmers were becoming more involved in market-oriented agriculture by the mid-1850s. The arrival of the railroad into Linn County in 1859 signaled the beginning of a long progression of agricultural changes that extended through the late nineteenth and twentieth centmies. Early Settlement Era farmsteads were generally small in size, with the average size in the state being 165 acres with that in Linn County being slightly smaller. In 1860 the greatest number of farms in Linn County were between 20-100 acres in size (U.S. Agricultural Census 1860). In Fayette Township, the size of the 93 farmsteads by 1859 ranged from a low of 20 to a high of 400 acres, with the average fann size being approximately 107 acres. Early Settlement Era farms,teadg in Linn County generally consisted of few buildings other than the house. a root cellar, stables, and rudimentary corncribs and granaries. Hay was stacked outdoors, and livestock was commonly allowed to roam free. The benefits of barns and sheds was largely unrecognized at this early date; however, in Fayette Township, the typical pioneer fannstead also included log or straw barns and sheep sheds that afforded some protection for the livestock from the cold winter weather. At least one \ 2-5 Early Settlement Era farmstead in Fayette Township had a heavy timber frame barn by the late 1850s. The first houses in this township were often log cabins, although the early construction of sawmills made cut lumber available at an early date (Mills 1958:38-40). During the Early Settlement Era, the greatest impetus for agricultural change came with the invention of the steel plow, which enabled farmers to efficiently and effectively break the prairie sod and allowed for settlement away from the groves and watersheds of the region.Scouring plows were being manufactured in Linn County in the early l840s by Andrew Safely, who settled near St. Julian in 1838. His plows were in great demand for a time;however, this enterprise was overshadowed when John Deere opened his large factory in Moline, Illinois, and began manufacturing steel plows in 1847. The general availability of John Deere's steel plow by the 1860s opened new areas to settlement, and, for the first time, the rich agricultural potential of the Iowa Prairie could be fully realized (Strong 1990:56-59). Increasingly, the emphasis became one of corn, hog, and cattle production, with the added emphasis on dairy farming in some areas of Linn County.During the Expansion Era, agriculture changed in large part due to the presence of the railroad system. Improvements in the transportation system led to the opening of "eastern markets to western farmers, who began to produce surplus crops for shipment to these markets" (Conard 1990:E2-3). Corn and livestock raising became increasingly more common, while wheat production went into decline. In Linn County and the state of Iowa, wheat production reached its zenith in the 1870s, and by 1880 "the prevalence of scab, rust, and chinch bugs, together with increasing profits realized from producing corn, hogs, and cattle and butter caused wheat to cease being a going business in Linn County" (Strong 1990:66). Wheat re-emerged as a viable crop in the early 1900s, and while it rose again in production, it never regained the place it once held in Iowa agriculture.As wheat growing went into decline during the Expansion Era, cattle raising increased and expanded, with cattle raising for dairy products and beef becoming more prevalent and profitable (Strong 1990:126). Butter production in Linn County in 1870 ranked second in the state, with 37,465 lbs. of butter produced in Fayette Township. The 1870 agricultural statistics of Fayette Township also show that swine production ranked first followed by cattle and milch cows and sheep. Corn was the highest producing crop at 74,270 bushels followed by oats (18,481 bu.) and spring wheat (7379 bu.). Butter, potatoes (4606 lbs.), wool (1602 lbs.), and hay (1538 tons) rounded out the products raised and manufactured. Forest products were also of some importance in the township in 1870, with $10,448 worth produced.A creamery was in operation in Fayette Township by the 1880s and was owned by Alva Hollenbeck and a Mr. Ayer. Historical accounts note that they did well with this creamery and that they ran two wagons to gather cream and churned about 1000 lbs. of butter per week. To this operation they added a 30 barrel cistern to hold buttermilk and expected to increase production to 1000 lbs. of butter per day. Reportedly, this creamery was located in the Lewis Bottoms neighborhood (Centennial Committee 1979:11).Farm size increased slightly during the Expansion Era, with the average size in Linn County in 1880 being 117 acres, increasing to 127 acres but dropping to 119 acres by 1910. In Fayette Township the average farm size by 1895 was 107 acres representing 136 farms. Although the number of farms had increased over that of 1859, the average farm size had remained the same. Hogs were at the top of commercial livestock production in the county by the end of the Expansion Era followed by cattle and lesser amounts of sheep.Of the cattle raised, 38% were dairy cows, a slight increase over the dairy production levels in the county in 1870. During the Expansion Era, there was a steady movement towards improvements in agricultural techniques, chief among these being the construction of better; 1 , 1 i 1 :" \ ! Early Settlement Era fannstead in Fayette Township had a heavy timber frame bam by the late 1850s. The first houses in this township were often log cabins, although the early construction of sawmills made cut lwnber available at an early date (Mills 1958:38-40). During the Early Settlement Era. the greatest impetus for agricultural change came with the invention of the steel plow, which enabled farmers to efficiently and effectively break: the prairie sod and allowed for settlement away from the groves and watersheds of the region. Scouring plows were being manufactured in Linn County in the early 1840s by Andrew Safely, who settled near St. Julian in 1838. His 'plows were in great demand for a time; however, this enterprise was overshadowed when John Deere opened his large factory in Moline, nIinois, and began manufacturing steel plows in 1847. The general availability of John Deere's steel plow by the 1860s opened new areas to settlement, and, for the first time, the rich agricultural potential of the Iowa Prairie could be fully realized (Strong 1990:56-59). Increasingly, the emphasis became one of corn, hog, and cattle production, with the added emphasis on dairy fanning in some areas of Linn County. ' Dwing the Expansion Era, agriculture changed in large part due to the presence of the railroad system Improvements in the transportation system led to the opening of "eastern markets to western fanners, who began to produce surplus crops for shipment to these markets" (Conard 1990:E2-3). Corn and livestock raising became increasingly more common, while wheat production went into decline. In Linn County and the state of Iowa, wheat production reached its zenith in the 1870s, and by 1880 "the prevalence of scab, rust, and chinch bugs, together with increasing profits realized from producing corn, hogs, and cattle and butter caused wheat to cease being a going business in Linn County" (Strong 1990:66). Wheat re-emerged as a viable crop in the early 1900s, and while it rose again in production, it never regained the place it once held in Iowa agriculture. As wheat growing went into decline during the Expansion Era, cattle raising increased and expanded, with cattle raising for dairy products and beef becoming more prevalent and profitable (Strong 1990:126). Butter production in Linn County in 1870 ranked second in the state, with 37,465 Ibs. of butter produced in Fayette Township. The 1870 agricultural statistics of Fayette Township also show that swine production ranked first followed by cattle and milch cows and sheep. Corn was the highest producing crop at 74;270 bushels followed by oats (18,481 bu.) and spring wheat (7379 bu.). Butter, potatoes (46061bs.), wool (16021bs.), and hay (1538 tons) rounded out the products raised and manufactured. Forest products were also of some importance in the township in 1870, with $10,448 worth produced. A creamery was in operation in Fayette Township by the 1880s and was owned by Alva Hollenbeck and a Mr. Ayer. Historical accounts note that they did well with this creamery and that they ran two wagons to gather cream and churned about 1000 lbs. of butter per week. To this operation they added a 30 barrel cistern to hold buttermilk and expected to increase production to 1000 Ibs. of butter per day. Reportedly, this creamery was located in the Lewis Bottoms neighborhood (Centennial Committee 1979:11). Fann size increased slightly during the Expansion Era, with the average size in Linn County in 1880 being 117 acres, increasing to 127 acres but dropping to 119 acres by 1910. In Fayette Township the average fann size by 1895 was 107 acres representing 136 fanns. Although the number of farms had increased over that of 1859, the average farm size had remained the same. Hogs were at the top of commerciallivest.ock production in the county by the end of the Expansion Era followed by cattle and lesser amounts of sheep. Of the cattle raised, 38% were dairy cows, a slight increase over the dairy production levels in the county in 1870. During the Expansion Era, there was a steady movement towards improvements in agricultural techniques, chief among these being the construction of better 2-6 livestock shelters and more control over feed and breeding. Farms were fenced during thisperiod, and large barns and a profusion of outbuildings began to dot the landscape (U.S.Agricultural Census 1870, 1880, 1890, 1910; Western Historical Company 1878:482). Linn County agriculture during the Consolidation Era of the Twentieth Century, continued to change and was characterized by specialization, intensification, and mechanization. This industry also consolidated during the Twentieth Century, with farms becoming lauger and fewer, a trend which continues to the present day. The primary technological change in agriculture was the introduction of mechanized farm equipment beginning with the tractor which became popular after World War I (Ewoldt 1988:30). Scientific changes also benefited agriculture and included the development of hybrid seed corn and highly specialized livestock breeds (Strong 1990:63).The farmers of Linn County did, however, experience a long period of economic decline beginning in the 1920s following the end of World War I and continuing on a downward spiral into the 1930s. Between 1930 and 1940 the number of farms in the county dropped and the proportion of land area in farms also slightly decreased. By 1940 the average farmsize was 160 acres, although farm size in general would increase steadily after 1940, reaching an average size of 219 acres by 1964 (U.S. Agricultural Censuses 1920-64). Atpresent, the average farm size in Fayette Township is approximately 134 acres representing 70 farms, although the amount of acreage in farm production has been drastically reduced in recent years due to the large land acquisitions for the Pleasant Creek State Park and the Duane Arnold Energy Center. The Energy Center continues to lease farm ground albeit in asmaller overall acreage than this area produced prior to the plant construction. Additionally, the amount of wetlands in the township has removed some acreage from production in recent years, although areas such as the Palo Marsh and the low bottoms in the north part of the township have always been too wet to support much in the way of agricultural production. D. Industrial Development of Fayette Township Industrial development during the Early Settlement Era in Fayette Township involved primarily the milling industry, with grist and sawmills among the earliest commercial enterprises of this area. The first gristmill in the township was built in the early 1840s on Bear Creek by John Lewis, who was also a blacksmith by trade. Reportedly, he made the burr stones himself (Centennial Committee 1979:4). This mill was shown on the 1859 map with amill pond to the west (see Figure 2-1). It was still owned by the Lewis fanily at that time. By 1870 it was being operated by Bowe and Walker and was producing an average of 370 bushels per day with two wheels and two tuns of stone (1870 IndustrialCensus). By 1880 the company was known as S.A. Bowe and Company, with a daily capacity of 280 bushels, and running on a Leffel wheel and a 10 ft water fall (1880 Industrial Census). It reportedly operated year-round and employed anywhere from two to seven hands (1870 and 1880 Industrial Censuses). In 1856 the millwright was JacobGoldsmith, followed by Jacob Haight in 1870 and Jim Moody in later years (Wahneita Dobbe, personal communication 1992; 1856 Iowa State Census; 1870 U.S. Population Census). By 1900 the mill was out of operation, and the mill structure was literally floated downriver where it was remodeled into a barn, which burned down in 1976 (Wahneita Dobbe, personal communication 1992). Descriptions of this barn indicate that the mill structure had been built of walnut timbers and was three to four stories in height (Ibid.).Gristmills were important during the Early Settlement Era and into the early decades of the Expansion Era because of the early emphasis on the raising of wheat and other grains and because of the waterpower afforded by the region's streams and rivers. As with the Lewis mill on Bear Creek, the early mills were predominantly water-powered mills requiring a: 1 ; : ! I livestock shelters and more control over feed and breeding. Farms were fenced during this period, and large bams and a profusion of outbuildings began to dot the landscape (U.S. Agricultural Census 1870, 1880, 1890.1910; Western Historical Company 1878:482). Linn County agriculture during the Consolidation Era of the Twentieth Century, continued to change and was characterized by specialization, intensification, and mechanization. This industry also consolidated during the Twentieth Century, with fanns becoming latgerand fewer. a trend which continues to the present day. TIle primary technological change in agriculture was the introduction of mechanized farm equipment beginning with the tractor which became popular after World War I (Ewoldt 1988:30). Scientific changes also benefited agriculture and included the development of hybrid seed com and highly specialized livestock breeds (Strong 1990:63). The farmers of Linn County did, however. experience a long period of economic decline beginning in the 19208 following the end of World War I and continuing on a downward spiral into the 19308. Between 1930 and 1940 the number of farms in the county dropped and the proponion of land area in fanns also slightly decreased. By 1940 the average farm size was 160 acres, although farm size in general would increase steadily after 1940, reaching an average size of 219 acres by 1964 (U.S. Agricultural Censuses 1920-64). At present, the average fann size in Fayette Township is approximately 134 acres representing 70 farms, although the amount of acreage in farm production has been drastically reduced in recent years due to the large land acquisitions for the Pleasant Creek State Park and the Duane Arnold Energy Center. The Energy Center continues to lease fann ground albeit in a smaller overall acreage than this area produced prior to the plant construction. Additionally. the amount of wetlands in the township has removed some acreage from production in recent years, although areas such as the Palo Marsh and the low bottoms in the north part of the township have always been too wet to support much in the way of agricultural production. D. Industrial DevelO,pment of Fayette Township Industrial development during the Early Settlement Era in Fayette Township involved primarily the milling industry, with grist and sawmills among the earliest commercial enterprises of this area. The first gristmill in the township was built in the early 18408 on Bear Creek by John Lewis, who was also a blacksmith by ttade. Reportedly, he made the burr stones himself (Centennial Committee 1979:4). This mill was shown on the 1859 map with a mill pond to the west (see Figure 2-1). It was still owned by the Lewis family at that time. By 1870 it was being operated by Rowe and Walker and was producing an average of 370 bushels per day with two wheels and two tuns of stone (1870 Industrial Census). By 1880 the company was known as S.A. Bowe and Company, with a daily capacity of 280 bushels, and running on a Leffel wheel and alOft water fall (1880 Industrial Census). It reportedly operated year-round and employed anywhere from two to seven hands (1870 and 1880 Industrial Censuses). In 1856 the millwright was Jacob Goldsmith, followed by Jacob Haight in 1870 and Jim Moody in later years (Wahneita Dobbe, personal communication 1992; 1856 Iowa State Census; 1870 U.S. Population Census). By 1900 the mill was out of operation, and the mill structure was literally floated downriver where it was remodeled into a barn, which burned down in 1976 (Wahneita Dobbe, personal communication 1992). Descriptions of this barn indicate that the mill structure had been built of walnut timbers and was three to four stories in height (IbieL). Gristtnills were important during the Early Settlement Era and into the early decades of the Expansion Era because of the early emphasis on the raising of wheat and other grains and because of the waterpower afforded by the region's streams and rivers. As with the Lewis mill on Bear Creek, the early mills were predominantly water-powered mills requiring a 2-7 darn to back up the water to provide sufficient water force to turn the wheel. Bear Creek was ideal for a milling operation because of its deep and swift waters (Mills 1958). The need for gristmills declined, however, towards the end of the Expansion Era because of the decline in wheat production and the competition from larger Mills, such as those in Cedar Rapids, which could produce mass quantities of processed flour at lower prices. As a result, most of the rural grist and flour Mills in Linn County were either in serious decline or out of business by 1913. During the Consolidation Era of the Twentieth Century, the local milling industry turned to the grinding of feed, often involving small portable Mills.This trend was followed in Palo where in 1929, R.C. Langton was operating a feed mill known as the Jay Bee Feed Grinders (Rogers 1992:67, 95).Sawmills were also important during the Early Settlement Era because the early settlers desired cut lumber in order to improve their early dwellings. The plentiful timber resources of Fayette Township were a boon to this early industry with the first sawmills built in the Fayette Township vicinity in 1841 by Daniel Richards and Seymour Usher. The Usher sawmill was built to the southeast of Palo and outside of the project area, while the Richard sawmill was built a few miles to the north in the vicinity of the later steamboat landing known as Katieville (Ibid.:9, 13). Another sawmill was that of John McCray and was built in Palo by the 1850s (Centennial Committee 1979:6). According to the 1870 U.S.Population Census, David Blackburn was then operating a sawmill in Fayette Township in the Lewis Bottoms area. Blackburn lived near Daniel Richards, who was then listed as a farmer, and may have taken over the Richards sawmill. The small parcels of land in the, timbered areas of the Pleasant Creek Valley, as shown on the 1869 map (Figure 2-2), suggest that these parcels were timber tracts. The richness of this resource continued to be exploited into the late Nineteenth Century, with J.H. Richards operating a steam-powered sawmill in the Lewis Bottoms neighboirhood as late as 1888 (Centennial Committee 1979:11).The local sawmill industry also declined during the Expansion Era because of the availability of cut lumber shipped by rail from larger Mills that could produce great quantities at less Cost. With the arrival of the Burlington, Cedar Rapids, and Northern (BCR & N) Railroad to Palo in 1869-70, the need for local sawmills declined.In addition to the Milling industry, extractive industries also had an impact on the development of Fayette Township. These industries included the limestone and clay industries, although that of the stone industry was to have a much greater impact. The clay industry in Fayette Township is represented by a small-scale brick manufactory that operated in Palo at an early date. Several of the earliest structures were built of this soft brick and are noted in the architectural portion of this study. The location of this early brickyard is not known, and it appears to have been on a small scale on the level of scove kiln production, which did not involve permanent kiln structures. Some of the brick could have been fired on site where the buildings were being constructed. This type of one-time production was used in the construction of the John McClintock house in 1863, with McClintock and his sons making the bricks themselves on site (Centennial Committee 1979:17).The limestone industry involved both the quarrying stone for construction and the burning of limestone to make lime. Quarries were kno 'wn from an early date, with the foundation for the Lewis gristmill being built of limestone quarried from a nearby outcrop. That quarry continued to provide stone through the years, even into the Consolidation Era when it was reopened in the late 1930s to provide crushed rock for road construction. The 1869map shows two quarries and one lime kiln then in operation (see Figure 2-2). The lime kiln was located in the extreme northern portion of the township near a quarry on Daniel Richards' property. According to the 1870 U.S. Population Census, the lime kiln was 2-7 dam to back up the water to provide sufficient water force to tum the wheel. Bear Creek was ideal for a milling operation because of its deep and swift waters (Mills 1958). The need for gristmills declined. however, towards the end of the Expansion Era because of the decline in wheat production and the competition from larger mills. such as those in Cedar Rapids. which could produce mass quantities of processed flour at lower prices. As a result, most of the rural grist and flour mills in Linn County were either in serious decline or out of business by 1913. During the Consolidation Era of the Twentieth Century, the local milling industry tmned to the grinding of feed. often involving small portable mills. This trend was followed in Palo where in 1929. R.C. Langton was operating a feed mill known as the Jay Bee Feed Grinders (Rogers 1992:67, 95). Sawmills were also important dming the Early Settlement Era because the early settlers desired cut lumber in order to improve their early dwellings. The plentiful timber resources of Fayette Township were a boon to this early industry with the first sawmills built in the Fayette Township vicinity in 1841 by Daniel Richards and Seymour Usher. The Usher sawmill was built to the southeast of Palo and outside of the project while the Richard sawmill was built a few miles to the north in the vicinity of the later steamboat landing known as Katieville (Ibid.:9, 13). Another sawmill was that of John McCray and was built in Palo by the 1850s (Centennial Committee 1979:6). According to the 1870 U.S. Population Census, David Blackburn was then operating a sawmill in Fayette Township in the Lewis Bottoms area. Blackburn lived near Daniel Richards, who was then listed as a farmer, and may have taken over the Richards sawmill. The small parcels of land in the ' timbered areas of the Pleasant Creek Valley, as shown on the 1869 map (Figure 2-2). suggest that these parcels were timber tracts. 'The richness of this resource continued to be exploited into the late Nineteenth Century, with J.H. Richards operating a steam-powered sawmill in the Lewis Bottoms neighborhood as late as 1888 (Centennial Committee 1979:11). The local sawmill industry also declined during the Expansion Era because of the aVailability of cut lumber shipped by rail from larger mills that could produce great quantities at less cost With the arrival of the Burlington. Cedar Rapids, and Nonhem (BCR & N) Railroad to Palo in 1869-70, the need for local sawmills declined. In addition to the milling industry, extractive industries also had an impact on the development of Fayette Township. These industries included. the limestone and clay industries, although that of the stone industry was to have a much greater impact. The clay industry in Fayette Township is represented by a small-scale brick manufactory that operated in Palo at an early date. Several of the earliest structures were built of this soft brick and are noted in the architectural portion of this study. The location of this early brickyard is not known. and it appears to have been on a small scale on the level of scove kiln production, which did not involve permanent kiln structures. Some of the brick could have been fired on site where the buildings were being constructed. This type of one-time production was used in the construction of the John McClintock house in 1863, with McOintock and his sons making the bricks themselves on site (Centennial Committee 1979:17). The limestone industry involved both the quarrying stone for construction and the burning of limestone to make lime. Quarries were known from an early date, with the foundation for the Lewis gristtni11 being built of limestone quarried from a nearby outcrop. That quarry continued to provide stone through the years, even into the Consolidation Era when it was reopened in the late 1930s to provide crushed rock fOr road construction. The 1869 map shows two quarries and one lime kiln then in operation (see Figure 2-2). The lime kiln was located in the extreme nonhero portion of the township near a quarry on Daniel Richards' property. According to the 1870 U.S. Population Census, the lime kiln was 2-8 operated by George Lockley. The other quarry was located in the southwest corner of the township and outside of the project area. Examination of the topographic quadrangle maps for Fayette Township (USGS Center Point and Shellsburg 1968) identified seven quarries within the boundaries of the township, while field survey has identified one more. The majority of these quarries were mined primarily during the Nineteenth Century, although a few were reopened in the early to mid-Twentieth Century. At least one continues toproduce crushed rock for road construction on a small scale to the present day.E, Transrm~tion Development in Ea=et TownshiR Transportation in Fayette Township during the Early Settlement Era came in two modes: road and river travel. According to the GLO original survey plat dating from 1841, therewas one major road into the township leading from Cedar Rapids to Bear Creek and just west of the future town of Palo, while another local road extended from Hollenbeck's house at the Palo townsite to the north-northwest to what was N.F. Miller's house by 1859 (see Figure 1-4). By 1859 a system of roadways had been established giving access to most areas of the township, while avoiding the marshlands and the steepest terrain (see Figure 1-5).With the establishment of a post office at Hollenbeck's house in 1848, "mail came each week by stagecoach from Marion" (Centennial Committee 1979:1). By 1853 the Western Stage Company was operating a stage and mail line along the "Cedar Rapids to Vinton Road" through Palo three times a week, and by 1856 was operating a daily line of four-horse coaches along this road. The early road from Cedar Rapids to Fayette Township as shown on the GLO map (see Figure 1-4) followed much the same route as the later Cedar Rapids to Vinton Road except that it was later routed into Palo. A second stage line operated by John Weare from Cedar Rapids to Cedar Falls also stopped in Palo. Three stage stops were eventually established in Palo: the Hollenbeck tavern and post office;Samuel Wells' Palo House hotel; and D. Cain's Iowa House hotel. Horses were stabled in a barn at the west edge of town that had been constructed with timbers salvaged from the old Blair's ferryboat (Centennial Committee 1979:18; Mills 1958:204).Reportedly, the stagecoaches drove through Palo, "then north of town going northwest to Vinton," with deep wheel ruts made by the coaches still visible on a ridge three miles north-northwest of Palo (Centennial Committee 1979:18). Another account indicates that the earliest Cedar Rapids to Vinton stage road angled through John Mills' property southwest of Palo along much the same route as the GLO road (see Figure 1-4) and a projected railroad route as shown on Figure 2-1 (Mills 1958:191). During the Early Settlement Era, the nearest river crossings were the Blair's and Usher ferries to the southeast and a ford, known as "Ford's Crossing" or "French's Ford," downriver from Usher's Ferry. None of these locations are within the project area, although Blair's Ferry was within the boundaries of Fayette Township (see Figure 2-1) and in the Palo vicinity. Historical accounts further indicate that people often crossed the river during the winter wherever the ice was solid, a dangerous but expedient way to cross the river (Mills 1958:196). Once the river was bridged, which first occurred at Cedar Rapids in the late 1850s, the need for ferries was reduced and eventually they were discontinued(Western Historical Company 1878:500-501). In addition to road travel, there were early attempts during the Early Settlement Era to successfully navigate the Cedar River on a regular basis. In the early 1840s the Maid of Iowa was the first steamboat to ply the Cedar River as far north as Cedar Rapids. Over thenext decade, "numerous steamers plied back and forth developing considerable trade between St. Louis, Keokuk, Burlington, and Cedar Rapids" (Clements 1967:18). Other[ i , I 2-8 operated by George Lockley. The other quarry was located in the southwest comer of the township and outside of the project area. Examination of the topographic quadrangle maps for Fayette Township (USGS Center Point and Shellsburg 1968) identified seven quarries within the boundaries of the township, while field survey has identified one more. The majority of these quarries were mined primarily during the Nineteenth Century, although a few were reopened in the early to mid-Twentieth CentW)'. At least one continues to produce crushed rock for road construction on a small scale to the present day. E. Transportation Deyelqpment in Fayette Township Transportation in Fayette Township dwing the Early Settlement Era came in two modes: road and river travel. According to the GW original survey plat dating from 1841, there was one major road into the township leading from Cedar Rapids to Bear Creek and just west of the future town of Palo. while another local road extended from Hollenbeck's house at the Palo townsite to the north-northwest to what was N.F. Miller's house by 1859 (see Figure 1-4). By 1859 a system of roadways had been established giving access to most areas of the township, while avoiding the marshlands and the steepest terrain (see Figure 1-5). With the establishment of a post office at Hollenbeck's house in 1848, "mail came each week by stagecoach from Marion" (Centennial 1979:1). By 1853 the Western Stage Company was operating a stage and mail line along the "Cedar Rapids to Vinton Road" through Palo three times a week. and by 1856 was operating a daily line of horse coaches along this road. The early road from Cedar Rapids to Fayette Township as shown on the GW map (see Figure 1-4) followed much the same route as the later Cedar Rapids to Vinton Road except that it was later routed into Palo. A second stage line operated by John Weare from Cedar Rapids to Cedar Falls also stopped in Palo. Three stage stops were eventually established in Palo: the Hollenbeck tavern and post office; Samuel Wells' Palo House hotel; and D. Cain's Iowa House hotel. Horses were stabled in a barn at the west edge of town that had been constructed with timbers salvaged from the old Blair's fenyboat (Centennial Committee 1979:18; Mills 1958:204). Reportedly, the stagecoaches drove through Palo, "then north of town going northwest to Vinton," with deep wheel ruts made by the coaches still visible on a ridge three miles northwest of Palo (Centennial Committee 1979: 18). Another account indicates that the earliest Cedar Rapids to Vinton stage road angled through John Mills' property southwest of Palo along much the same route as the GW road (see Figure 1-4) and a projected railroad route as shown on Figure 2-1 (Mills 1958:191). During the Early Settlement Era, the nearest river crossings were the Blair's and Usher ferries to the southeast and a ford, known as "Ford's Crossing" or "French's Ford," downriver from Usher's Ferry. None of these locations are within the project area, although Blair's Ferry was within the boundaries of Fayette Township (see Figure 2-1) and in the Palo vicinity. Historical accounts further indicate that people often crossed the river during the winter wherever the ice was solid; a'dangerous but expedient way to cross the river (Mills 1958:196). Once the river was bridged, which first occurred at Cedar Rapids in the late 1850s, the need for ferries was reduced and eventually they were discontinued (Western Historical Company 1878:500-501). In addition to road travel, there were early attempts during the Early Settlement Era to successfully navigate the Cedar River on a regular basis. In the early 1840s the Maid of Iowa was the first steamboat to ply the Cedar River as far north as Cedar Rapids. Over the next decade, "numerous steamers plied back and forth developing considerable trade between St. Louis, Keokuk, Burlington, and Cedar Rapids" (Clements 1967:18). Other 2-9 steamboats traveled upstream of the rapids from Cedar Rapids to Waterloo. These boats included the Export built in 1858 by a stock company in Cedar Rapids and renamed the Blackhawk in 1859. The Blackhawk operated until 1861 when it was sold and taken south for use as a Government supply boat. Other boats, such as the small sternwheeler Carrie Wallace, plied the upper Cedar River into the late 1870s; however, the arrival of the railroad into Linn County in 1859 signaled the end of river travel as an important means of transportation and shipping along the river (Centennial Committee 1979:16; Lazell 1908:2;Harbert 1904-05:91-103). There were a number of steamboat landings along the Cedar River north of Cedar Rapids.These included: a landing east of Main Street at Palo; a landing at "McGivins Chute" two miles north of Palo near the present Alfred Frantz farm; a landing at Blackhawk's Prairie that was possibly on the east side of the river, a landing at "Katieville Prairie" at a bend in the river-, a landing at Blue Banks south of Center Point on the east bank of the river, and a landing at "Snag Bend" one mile north of Blue Banks. Except for Blue Banks and possibly Blackhawk's Prairie and Snag Bend, all of the above noted landings were located within the project area (Centennial Committee 1979:16; Lazell 1908:3). Two of these,Katieville and McGivins Chute are represented on the 1859 map as the speculative townsites of "Fayette" and "Macksville" (see Figure 2-1). Katieville was also known as Horseshoe Bend. Neither townsite proved successful, and by 1869, neither was represented on the map (see Figure 2-2). Katieville was somewhat typical of theselandings in that it had a pier where the Blackhawk landed from 1858 to 1862 and had some settlement in association where "the pioneers intended to build a town, named Katieville,[and] Daniel Richards built the first sawmill here in 1841, but the town was never platted and became extinct" (Centennial Committee 1979:13).The arrival of the railroad into Fayette Township came ten years after the railroads had first entered Linn County. The railroad into the township was the third railroad undertaking in the county and began as the Burlington, Cedar Rapids, and Minnesota Railroad in 1869.This project was roomoted by influential Cedar Rapids businessmen including Judge George Greene and S.L. Dows and was originally pushed as a link between Cedar Rapids, Vinton, and Waterloo. Promoters from Burlington later joined in the project and the line was then projected from Burlington to St. Paul, Minnesota. The line between Cedar Rapids and Waterloo was completed in 1870, with the line from Cedar Rapids to Burlington completed by 1871-72, and from Waterloo to St. Paul by that same time. When completed, this line provided connections from St. Paul to St. Louis. The railroad was reorganized as the Burlington, Cedar Rapids, and Northern (BCR & N) in 1879 and waslater absorbed by the Rock Island system. In Linn County, the line running northwest to Vinton and Waterloo from Cedar Rapids was completed in 1869-70 and extended along the southwest side of Palo, with a second line from Linn Junction to Decorah built in 1871-73 and having Toddville, Center Point, and Walker as stops along this line. Figure 2-3 shows the railroad system in Linn County at its zenith. Because the railroad tracks for the BCR &N did not extend into the platted town of Palo, the depot and elevator were located nearly 1/4 mile southwest of the main commercial district (Figure 2-4). Interestingly, the town never really built out to the rail line as many communities did When faced with a similar situation but instead made do with the distance from the businesses to the rail connection. By the 1920s the rail lines in Linn County, as in the state as a whole, began to streamlineand consolidate in face of the competition with the automobile industry. By the early 1940s passenger service along Linn County's railroads had been largely discontinued. This was followed by a reduction in freight stops and the abandonment of some lines altogether. In Palo, the rail line remains in use to the present day; however, passenger and freight service at Palo had ceased by the mid-Twentieth Century. The depot was torn down c. 1960 (Centennial Committee 1979:18; Rogers 1992:92).2-9 steamboats traveled upstream of the rapids from Cedar Rapids to Waterloo. These boats included the Expon built in 1858 by a stock company in Cedar Rapids and renamed the Blackhawk in 1859. The Blfickhawk operated until 1861 when it was sold and taken south. for use as a Government supply boat Other boats, such as the small stemwheeler Carrie Wallace, plied the upper Cedar River into the lare 1870s; however. the arrival of the railroad into Linn County in 1859 signaled the end of river travel as an important means of transportation and shipping along the river (Cenrennial Committee 1979:16; LazeU 1908:2; Harbert 1904-05:91-103), There were a number of steamboat landings along the Cedar River north of Cedar Rapids. These included: a landing east of Main Street at Palo; a landing at "McGivins Chute" two miles north of Palo near the present Alfred Frantz fann; a landing at Blackhawk's Prairie that was possibly on the east side of the river; a landing at "Katieville Prairie" at a bend in the river; a landing at Blue Banks south of Center Point on the east bank of the river; and a landing at "Snag Bend" one mile north of Blue Banks. Except for Blue Banks and possibly Blackhawk's Prairie and Snag Bend, all of the above noted landings were located within the project area (Centennial Committee 1979:16; Lazelll908:3). Two of these, Katieville and McGivins Chute are represented on the 1859 map as the speculative town sites of "Fayette" and "Macksville" (see Figure 2-1). Katieville was also known as Horseshoe Bend. Neither townsite proved successful, and by 1869. neither was represented on the map (see Figure 2-2). Katieville was somewhat typical of these landings in that it had a pier where the Blackhawk landed from 1858 to 1862 and had some settlement in association where "the pioneers intended to build a town, named Katieville, [and] Daniel Richards built the first sawmill here in 1841, but the town was never platted and became extinct" (Centennial Committee 1 fJ79: 13). The arrival of the railroad into Fayette Township came ten years after the railroads had first entered Linn County. The railroad into the township was the third railroad undertaking in the county and began as the Burlington, Cedar Rapids, and Minnesota Railroad in 1869. This project was promoted by influential Cedar Rapids businessmen including Judge George Greene and S.L. Dows and was originally pushed as a link between Cedar Rapids, Vinton, and Waterloo. Promoters from Burlington later joined in the project and the line was then projected from Burlington to Sl Paul, Minnesota. The line between Cedar Rapids and Waterloo was completed in 1870, with the line from Cedar Rapids to Burlington completed by 1871-72, and from Waterloo to Sl Paul by that same time. When completed, this line provided connections from Sl Paul to St. Louis. The railroad was reorganized as the Burlington, Cedar Rapids, and Northern (BCR & N) in 1879 and was later absorbed by the Rock Island system. In Linn County, the line running northwest to' Vinton and Waterloo from Cedar Rapids was completed in 1869-70 and extended along the southwest side of Palo, with a second line from Linn Junction to Decorah built in 1871-73 and having Toddville, Center Point, and Walker as stops along this line. Figure 2-3 shows the railroad system in Linn County at its zenith. Because the railroad tracks for the BCR & N did not extend into the platted town of Palo, t4e depot and elevator were located nearly 1/4 mile southwest of the main commercial district (Figure 2-4). Interestingly. the town never really built out to the rail line as many connnunities did when faced with a similar situation but instead made do with the distance from the businesses to the rail connection. By the 1920s the rail lines in Linn County. as in the state as a whole, began to streamline and consolidate in face of the competition with the automobile industry. By the early 1940s passenger service along Linn County's railroads had been largely discontinued. This was followed by a reduction in freight stops and the abandonment of some lines altogether. In Palo, the rail line remains in use to the present day; however. passenger and freight service at Palo had ceased by the mid-Twentieth Century. The depot was tom down c. 1960 (Centennial Committee 1979: 18; Rogers 1992:92). 2-10 The beginning of the Consolidation Era in Linn County was marked by the establishment of the Lincoln Highway in 1913 and the subsequent rise of the automobile industry at the expense of the railroads. Road improvements followed on the heels of the Lincoln Highway, with most of Linn County's major roadways being paved between the 1920s-1940s. One highway of note in the project area was that known as the Red Ball route as shown on Figure 2-5, although Thompson (1989) indicates that the Red Ball route did not extend through Palo but rather traveled due west out of Cedar Rapids on its way northwest to Waterloo. Thompson (Ibid.) further indicates that the main roadway into Palo and then west was registered as both the Diagonal Trail in 1918 and the Cedar Rapids, Urbana-Independence Short Line in 1923. This roadway was later designated as U.S. Highway 94 between Cedar Rapids and Palo, and County Road E36 (Shellsburg Road) where it heads to the west from Palo. E36 has also been extended in recent years to the east along thenorth side of Palo and over the Cedar River as part of the re-routed Blairs Ferry Road.This re-routing was necessitated by the closing of the Chain Lakes bridge southeast of Palo to automobile traffic. At present in Fayette Township, the only paved roadways are Highway 94, County Road E36, Blairs Ferry Road, and a portion of County Road W36, or the Palo Marsh Road north of Palo to the Pleasant Creek State Park. Otherwise, the township's roadways are gravel or dirt.F. Religion and Education in Fayette TownshipThe religious development of. Fayette Township began with the formation of a Methodist religious society at Palo in 1846-47 under the sponsorship of John Hollenbeck and P.B.Yates. When Mr. Yates died shortly thereafter, Mr. Hollenbeck joined his fledgling congregation with that of the Methodist Episcopal society which had been formed before 1854. Services were held in private homes and then in the schoolhouse until 1870 when a frame church building was constructed. This building remains standing and is still used by the Methodist Church in its present form as the United Methodist Church. A Ladies Aid Society and young peoples' groups were established in association with the Methodist church (Centennial Committee 1979:19).In addition to the church in Palo, Fayette Township was served by two rural churches including the Lewis Bottoms Methodist Church approximately 3-1/2 miles north of Palo and the Lincoln United Brethren Church located 3-1/2 miles southwest of Palo and outside of the project area. The Lewis Bottoms Church, also known locally as "the Church on the Hilltop" was organized and built in 1878. It was abandoned by the 1970s and is no longer extant. The Lincoln U.B. Church was built in 1900 and was still an active congregation in the 1970s (Centennial Committee 1979:20).The educational development of Fayette Township also had its early beginnings in the Palo vicinity where a subscription school was taught as early as 1843 by John Slonaker in his cabin near Palo. The Reverend Johnson also taught school in 184 "north of Palo in acabin where he lived on the Thomas Lewis claim" (Centennial Committee 1979:21). The first Palo town school was built in 1858 and operated until 1871 when the second school was built north of the business district. This school was used until 1922 when the Palo Consolidated School was built. The Palo town school and the rural districts consolidated in 1917, with the first combined classes held in 1920 in the 1871 building as well as in the MWA Hall and a temporary building on the proposed school grounds referred to by the students as the "Sheep Shed" (Ibid.:22-23). The first rural schoolhouse was a log cabin school built in 1848 near the Cedar River in the Lewis Bottoms, with the first schoolteacher being Martha Lewis, wife of John Lewis.This school was replaced in 1876 with a two story frame school, commonly referred to as; ;, i f j: The beginning of the Consolidation Era in Linn County was marked by the establishment of the Lincoln Highway in 1913 and the subsequent rise of the automobile industry at the expense of the railroads. Road improvements followed on the heels of the Lincoln Highway. with most of Linn County's major roadways being paved between the 1920s-194Os. One highway of note in the project area was that known as the Red Ball route as shown on Figure 2-5, although Thompson (1989) indicates that the Red Ball route did not extend through Palo but rather traveled due west out of Cedar Rapids on its way northwest to Waterloo. Thompson (Ibid.) further indicates that the main roadway into Palo and then west was registered as both the Diagonal Trail in 1918 and the Cedar Rapids, Independence Short Line in 1923. This roadway was later designated as U.S. Highway 94 between Cedar Rapids and Palo, and County Road E36 (Shellsburg Road) where it heads to the west from Palo. E36 has also been extended in recent years to the east along the north side of Palo and over the Cedar River as part of the re-routed Blairs Ferry Road. This re-routing was necessitated by the closing of the Chain Lakes bridge southeast of Palo to automobile traffic. At present in Fayette Township, the only paved roadways are Highway 94, County Road E36, Blairs Ferry Road, and a portion of County Road W36, or the Palo Marsh Road north of Palo to the Pleasant Creek State Park. Otherwise. the township's roadways are gravel or dirt. F. Religion and Education in Fayette Township The religious development of Fayette Township began with the formation .of a Methodist religious society at Palo in 1846-47 under the sponsorship of John Hollenbeck and P.B. Yates. When Mr. Yates died shortly thereafter, Mr. Hollenbeck joined his fledgling congregation with that of the Methodist Episcopal society which had been fonned before 1854. Services were held in private homes and then in the schoolhouse until 1870 when a frame chmch building was constructed. This building remains standing and is still used by the Methodist Church in its present form as the United Methodist Church. A Ladies Aid Society and young peoples' groups were established in association with the Methodist church (Centennial Connnittee 1979:19). In addition to the church in Palo, Fayette Township was served by two rural churches including the Lewis Bottoms Methodist Church approximately 3-1/2 miles north of Palo and the Lincoln United Brethren Chmch located 3-1/2 miles southwest of Palo and outside of the project area. The Lewis Bottoms Church, also known locally as "the Church on the Hilltop" was organized and built in 1878. It was abandoned by the 1970s and is no longer extant The Lincoln Church was built in 1900 and was still an active congregation in the 19708 (Centennial Committee 1979:20). The educational development of Fayette Township also had its early beginnings in the Palo vicinity whefC a subscription school was taught as early as 1843 .by John Slonaker in his cabin near Palo. The Reverend Johnson also taught school in 1846 "north of Palo in a cabin where he lived on the Thomas Lewis claim" (Centennial Committee 1979:21). The first Palo town school was built in 1858 and operated until 1871 when the second school was built north of the business district. This school was used until 1922 when the Palo Consolidated School was built The Palo town school and the rural districts consolidated in 1917, with the first combined classes held in 1920 in the 1871 building as well as in the MW A Hall and a temporary building on the proposed school grounds referred to by the students as the "Sheep Shed" (Ibid.:22*23). The fll'St rural schoolhouse was a log cabin school built in 1848 near the Cedar River in the Lewis Bottoms, with the ftrst schoolteacher being Martha Lewis, wife of John Lewis. This school was replaced in 1876 with a two story frame school, commonly referred to as 2-11 the Lewis Bottoms 'Double Deck" Schoolhouse and was also known by the designation of Independent District No. 1. This school was used for 71 years before disbanding in 1947 when the district joined the Palo Consolidated School. The building in Section 6 is no longer extant, and the site has since been inundated by the~waters of the Pleasant Creek reservoir (Centennial Conmmittee 1979: 15).Other rural schools included Round Prairie in Section 16, Bear Creek in Section 17, DryCreek Independent in Section 30, Cedar Bend Independent in Section 33, and the "Goose Hill" School located one miAle west of Palo in Section 19. All except the Cedar Bend school are within the project area. The Goose Hill school was a brick building in use from c.1858 until c. 1869. Bear Creek and Round Prairie were in use by 1859, although the Round Prairie School was originally located to the southeast of its later location and neare the river (see Figures 2-1 and 2-2). The Bear Creek School also changed location and, for a time, was sited further west than its later location. Dry Creek and Cedar Bend were in use by 1869, and all but the Goose Hill School were still in operation in the early 1900s (see Figure 2-2). At least three of the school buildings are extant; however, they have been moved from their original sites.G. Consolidation Era Resourc-el Deveomenit in Faet -TownshpDuring the Consolidation Era in Fayette Township, resource development has had a major impact on the landscape of this township as well as its historical and archaeological resources. These developments include the Pleasant Creek State Park, the Palo Marsh County Park, and the Duane Arnold Energy Center. The Pleasant Creek State Park wasconstructed between 1973-1984 and resulted in the creation of a 4 10 acre lake surrounded by 1,517 acres of land (Centennial Committee 1979:52-53). This land acquisition involved the purchase of farmsteads and the removal of standing buildings. As a result a number of archaeological sites were created, while others were destroyed by the construction of the lake. Luther College conducted a study of the prehistoric archaeological resources of the Pleasant Creek area in 1974, although historic sites were not given much attention nor systematically recorded- The Palo Marsh County Park was also established in recent years and consists of a natural marshland and wildlife preserve just north of Palo. As a natural marshland, it is unlikely that any cultural resources were impacted by the creation of this park.The Duane Arnold Energy Center began operations in 1974 and was the first nuclear powergenerating plant in the state of Iowa (Centennial Committee 1979:40-41). The construction of this power plant involved the acquisition of nearly 800 acres of land surrounding theplant itself. As with the Pleasant Creek Park, this land acquisition included several farmisteads, which were subsequently demolished and are in varying states of archaeological preservation. No systematic archaeological study was conducted of the property prior to plant construction. 2*11 the Lewis Bottoms "Double Deck" Schoolhouse and was also known by the designation of Independent District No.1. This school was used for 71 years before disbanding in 1947 when the district joined the Palo Consolidated School. The building in Section 6 is no longer extant. and the site has since been inundated by the,waters of the Pleasant Creek reservoir (Centennial Committee 1979:15). Other rural schools included Round Prairie in Section 16, Bear Creek in Section 17. Dry Creek Independent in Section 30, Cedar Bend Independent in Section 33, and the "Goose Hill" School located one mile west of Palo in Section 19. All except the Cedar Bend school are within the project area.. The Goose Hill school was a brick building in use from c.1858 until c. 1869. Bear Creek and Round Prairie were in use by 1859, although the Round Prairie School was originally located to the southeast of its later location and nearer the river (see Figures 2-1 and 2-2). The Bear Creek School also changed location and, for a time, was sited further west than its later location. Dry Creek and Cedar Bend were in use by 1869, and all but the Goose Hill School were still in operation in the early 1900s (see Figme 2-2). At least three of the school buildings are extant; howevef, they have been moved from their original sites. G. Consolidation Era Resource Development in Fayette Township During the Consolidation Era in Fayette Township, resource development has had a major impact on the landscape of this township as well as its historical and archaeological resources. These developments include the Pleasant Creek State Park, the Palo Marsh County Park, and the Duane Arnold Energy Center. The Pleasant Creek State Park was constructed between 1973-1984 and resulted in the creation of a 410 acre lake surrounded . by 1,517 acres of land (Centennial Committee 1979:52-53). This land acquisition involved the purchase of fannsteads and the removal of standing buildings. As a result a number of archaeological sites were created, while others were destroyed by the construction of the lake. Luther College conducted a study of the prehistoric archaeological resources of the Pleasant Oeek area in 1974, although historic sites were not given much attention nor systematically recorded. The Palo Marsh County Park was also established in recent years and consists of a natural marshland and wildlife preserve just north of Palo. As a natural marshland, it is unlikely that any cultural resources were impacted by the creation of this park. The Duane Arnold Energy Center began operations in 1974 and was the first nuclear power generating plant in the state ofIowa (Centennial Committee 1979:40-41). The construction of this power plant involved the acquisition of nearly 800 acres of land surrounding the plant itself. As with the Pleasant Creek Park, this land acquisition included several farmsteads. which were subsequently demolished and are in varying states of archaeological preservation. No systematic archaeological study was conducted of the property prior to plant construction. 2-12 MI. HISTORICAL AND ARCHITECTURAL CONTEXTS A. Intrj~fio The history of Fayette Township can be understood through an analysis of four historic contexts. Thiis section of the report discusses each of these themes. The discussion begins with a study of local demographics and continues with each of the following contexts: Rise of an Agricultural Economny Town Building Transportation Architectural Resurces of Fayette Township The analysis of historic population growth and decline in Iowa has just begun. What is presented here is, therefore, a prelimninary accounting and analysis of certain statewide trends and local experiences as they relate to the study area of this report. Demographics help the historian trace the evolution of communities in several ways. A community's population growth and/or decline pr~vides one factor in determining periods of significance for its local history. Population patterns are also suggestive of economic, social, industrial, technological, and other changes within the community. Finally, the study of demography helps trace the evolution of land-use areas in the community. Population statistics can, for example, be analyzed in conjunction with the evolution of a town's original plat, its later additions, and subsequent subdivisions. One can begin to understand the unfolding history of a community through local responses to demographic needs and how these needs are met within the specific opportunities and constraints of a specific locale. A note concerning the study area of this report is appropriate here. Both Fayette Township and Palo have small populations. A relatively few number of families can make a big impact on population statistics and skew interpretation. Iowa experienced a "great migration" in the 1850s. The state's population increased 251 percent in the decade between 1850 and 1860. The majority of new settlers came from states of the Old Northwest and the Mfiddle Atlantic region (Ross 1951:27). In succeeding decades of the Nineteenth Century, Iowa's population continued growing, but at a slower rate. This statewide experience was also generally reflected in Linn County during the Expansion Era. Between 1870 and 1880, for example, the population of Linn County increased by 17%. Between 1890 and 1900, it increased by 18%. During the same periods, the population of Iowa increased by 27% and 14% respectively. The first decade of the Twentieth Century saw major relocations of population in Iowa, calling attention to a realignment of the farming community then occurring. Several population trends were evident. First, many of the Iowa farmers, who were relocating elsewhere in the nation, comprised the maturing generation of farm children for whomIowa land at affordable prices was hard to find. Second, a movement of farmers to towns and cities was going on, as the earlier generation of farmers reached retirement age. In the study area of this report, insufficient census data are available for Palo to compare and contrast these trends. Two points can, however, be made. Linn County bucked the trend and grew by 9% during the decade. Fayette Township, on the other hand, conformed to the state-wide trend, decreasing by 2%.Other statewide trends during the early years of the Twentieth Century also found exceptions in Linin County. Although the years between 1900 and 1910 saw an overall population decline in many incorporated communities in Iowa, the City of Cedar Rapids grew by an impressive 22%. Unfortunately insufficient population statistics are available 2-12 HI *. HIS'JI'OlltiCAL AND ARCHITECTURAL CONTEXTS A. Introduction The history of Fayette Township can be understood through an analysis of four historic contexts. This section of the report discusses each of these themes. The discussion begins with a study of local demographics and continues with each of the following contexts: Rise of an Agricultural Economy Town Building Transportation Architectural Resources of Fayette Township The analysis of historic population growth and decline in Iowa has just begun. What is presented here is. therefore, a preliminary accounting and analysis of certain statewide trends and local experiences as they relate to the study area of this Demographics help the historian trace the evolution of communities in several ways. A community's population growth and/or decline provides one factor in detennining periods of significance for its local history. Population patterns are also suggestive of economic, social, industtial, technological. and other changes within the community. Finally. the study of demography helps trace the evolution of land-use areas in the community. Population statistics can, for example, be analyzed in conjunction with the evolution of a town's original plat. its later additions. and subsequent subdivisions. One can begin to understand the unfolding history of a community through local responses to demographic needs and how these needs are met within the specific opportunities and constraints of a specific locale. A note concei-ning the study area of this report is appropriate here. Both Fayette Township and Palo have small populations. A relatively few number of families can make a big impact on population statistics and skew interpretation. Iowa experienced a "great migration" in the 1850s. The state's population increased 251 percent in the decade between 1850 and 1860. The majority of new settlers came from states of the Old Northwest and the Middle Atlantic region (Ross 1951 :27). In succeeding decades of the Nineteenth Century, Iowa's population continued growing. but at a slower rate. This statewide experience was also generally reflected in Linn County during the Expansion Era. Between 1870 and 1880, for example, the population of Linn County increased by 17%. Between 1890 and 1900, it increased by 18%. During the same periods, the population of Iowa increased by 27% and 14% respectively. The first decade of the Twentieth Century saw major relocations of population in Iowa, calling attention to a realignment of the fanning community then occurring. Several population trends were evident. First, many of the Iowa farmers, who were relocating elsewhere in the nation, comprised the maturing generation of farm children for whom Iowa land at affordable prices was hard to find. Second, a movement of fanners to towns and cities was going on, as the earlier generation of farmers reached retirement age. In the study area of this report, insufficient census data are available for Palo to compare and contrast these trends. Two points can, however, be made. Linn County bucked the trend and grew by 9% during the decade. Fayette Township, on the other hand, conformed to the state-wide trend, decreasing by 2%. . Other statewide !rends during the early years of the Twentieth Century also found exceptions in Linn County. Although the years between 1900 and 1910 saw an overall population decline in many incorporated communities in Iowa, the City of Cedar Rapids grew by an impressive 22%. Unfortunately insufficient population statistics are available 2-13 to compare and contrast this experience in Palo. Thbe year 1910 also marked a population watershed in state history. The federal census of that year revealed that 50 % of all Iowans lived in incorporated communities (Gaudy 1988:1). Prior to this time, the major-ity of the state's residents had lived in rural area. Not until 1960, however, did the population ofPalo outnumber that of rural Fayette Township. During the Consolidation Era and throughout the 1920s, Linn County and Palo continued to increase in population. By 1920 the county had, for example, grown to 74,004 and Palo had reached 224. During the same period, Fayette Township's population remained relatively stable, increasing by 3% between 1920 and 1930.The Great Depression hit the rural population hard. Between 1930 and 1940, for example, the township's population declined by 13%. Palo, in contrast, increased by 18% during the same decade, its largest growth in three decades. While Linn County also increased in population, the rate was limited to 8%, the lowest growth rate in the county since its founding.Several important population trends in the study are emerged following World War 11.The population of unincorporated Fayette Township, which had stabilized in the 1950s after declines during the Great Depression, began in the 1960s an unparalleled population decline. The 1970s, for example, saw a 11I% loss of rural population, while the 1980s saw 14%. These statistics tell only part of the decline in the farn population because a number of individuals and families settled in unincorporated areas of the township on suburban acreages. By 1980, the population of Fayette Township numbered less than 35% of its 1910 size.Palo's population story has been very different. The community has seen steady growth beginning in the 1940s and continuing into the 1980s. The city's proximity to Cedar Rapids and the Duane Arnold Energy Center encouraged new tract housing, and Palo became a bedroom community. Until recently, no decade following World War H1 saw the city's population decline. Indeed, in the 1950s, the community grew by 26% over the previous decade. By 1960, the population of Palo was larger than that of Fayette Township's unincorporated areas. The 1980s posted a 3% population loss for Palo, which may now become a new trend.Finally, two new phases of settlement in Fayette Township emerged in the 1970s and 1980s. One of these is traditional in character, while the other is not. At Palo, new tracts of land were annexed into the city. Lots were sold and single-family dwellings were erected near the corporate limits--one at the south end and one at the north end of the city.Both these tracts were located near highways into Cedar Rapids. These real estate developments included paved roads, all utilities, and other amenities. As such, they are typical of many other tract developments in Linn County, Iowa, and the nation.A second type of new settlement has also recently emerged in the township. Construction of a lake and park facilities at Pleasant Creek State Park, completed in 1984, encouraged the redevelopment of surrounding farmland. Located in a picturesque, hilly environment, large residential lots adjacent to the park were sold to individuals, who proceeded to construct large single-family dwellings on them. This developme-nt is exurban in character.No paved roads serve the area, which is deeply imbedded in the countryside. Separated by acres of farmland from Palo, this development is made possible by the automobile and the willingness of people to commnute and to incur other inconveniences in order to benefit from seclusion and enjoy beautiful natural surroundings.

! 2-13 to compare and contrast this experience in Palo. The year 1910 also marked a population watershed in state history. The federal census of that year revealed that 50 % of all Iowans lived in incorporated communities (Goudy 1988: 1). Prior to this time, the majority of the state's residents had lived in rural areas. Not until 1960, however, did the population of Palo outnumber that of rural Fayette Township.

During the Consolidation Era and throughout the 1920s, Linn County and Palo continued to increase in population. By 1920 the county had, for example, grown to 74,004 and Palo had reached 224. During the same period, Fayette Township's population remained relatively stable, increasing by 3% between 1920 and 1930. The Great Depression hit the rural popUlation hard Between 1930 and 1940, for example. the township's population declined by 13%. Palo, in contrast, increased by 18% during the same decade, its largest growth in three decades. While Linn County also increased in population. the rate was limited to 8%. the lowest growth rate in the county since its . Several important population trends in the study area emerged following World War n. The population of unincorporated Fayette Township, which had stabilized in the 19508 after declines dming the Great Depression, began in the 1960s an unparalleled population decline. The 19708, for example, saw a 11 % loss of rural population, while the 19808 saw 14%. These statistics tell only part of the decline in the farm population because a number of individuals and families settled in unincorporated areas of the township on suburban acreages. By 1980. the population of Fayette Township numbered less than 35% of its 1910 size. Palo's population story has been very different. The community has seen steady growth beginning in the 19408 and continuing into the 1980s. The city's proximity to Cedar Rapids and the Duane Arnold Energy Center encouraged new tract housing. and Palo became a bedroom cormnunity. Until recently. no decade following World War IT saw the city's population decline. Indeed, in the 19508, the community grew by 26% over the previous decade. By 1960, the population of Palo was larger than that of Fayette Township's unincorporated areas. The 1980s posted a 3% population loss for Palo, which may now become a new trend. Finally. two new phases of settlement in Fayette Township emerged in the 1970s and 1980s. One of these is traditional in character, while the other is not. At Palo, new tracts of land were annexed into the city. Lots were sold and single-family dwellings were erected near the corporate limits--one at the south end and one at the north end of the city. Both these tracts were located near highways into Cedar Rapids. These real estate developments included paved roads, all utilities, and other amenities. As such, they are typical of many other tract developments in Linn County, Iowa, and the nation. A second type of new settlement has also recently emerged in the township. Construction of a lake and park facilities at Pleasant Creek State Park, completed in 1984, encouraged the redevelopment of surrounding farmland. Located in a picturesque, hilly environment, large .residential lots adjacent to the. park were sold to individuals, who proceeded to construct large single-family dwellings on them. This development is exurban in character. No paved roads serve the area, which is deeply imbedded in the countryside. Separated by acres of farmland from Palo, this development is made possible by the automobile and the willingness of people to commute and to incur other inconveniences in order to benefit from seclusion and enjoy beautiful natural surroundings. 2-14 While these two settlement patterns have altered the countryside, the pre-World War 11suburban acreage movement also continues. In 1991, for example, the Urbanek Family purchased the McArthur Farmhouse and several acres in Section 32 of the Lewis Bottoms.Vacant and threatened with demolition, this farmhouse with several acres of its historic farmland were purchased by the Urbaneks. The house now provides shelter for this family on a suburban acreage site.While both exurban and suburban settlement have added population to Fayette Township, the population of this rural area continues to experience stress. In the early 1990s, for example, the Mobry Farmstead in Section 30 was sold, following the death of its nonagenarian matriarch. The land was sold and continues to be farmed, but no one now lives on the land and the farmhouse is abandoned. B. Rise of an Agdicultural EconomyThe rise of an agricultural economy in Fayette Township has already been discussed in theprevious section (U-C) pertaining to archaeological resources, therefore, the following will specifically address this context as it relates to the architectural resources of the township.The rise of the township's agricultural economy spanned three eras: the Early Settlement Era, the Expansion Era, and the Consolidation Era. Of these, the architectural impact of the Consolidation Era (post-1913) is most prevalent on the current landscape of the township, although scattered resources relating to the earlier eras are extant.1. Early Settlement Era Agriculture During the Early Settlement Era the agriculture of Fayette Township focused primarily on subsistence level farming with some market income provided by the raising of livestock,particularly hogs. While this level of fanming tended to require little in the way of structuralshelters such as barns, at least one Early Settlement Era barn is known in the Fayette Township area. This barn is found in Section 17, TB4N-8W, on the Railsback farmstead which was established in the 1840s, with the barn reportedly built

c. 1857-58 towards the end of the Early Settlement Era. This early investment in a large building constructed solely for the purpose of housing livestock and their feed indicates movement towards amarket-oriented farm economy. At least one other barn of this type and relative age was known in the township but which has since been demolished.

That barn was built for the McClintock family, early settlers in Section 4, T84N-R8W, to the northeast of theRailsback farmstead. Among the early settlers of Fayette Township, the Lewis family had perhaps the greatest impact and influence on the agricultural settlement throughout the township's historic period. Thomas and John Lewis arrived in Fayette Township in April 1839 following close on the heels of the first Euro-American settler, Joseph Strawn, who had arrived a fewweeks before. The Lewises were natives of Pennsylvania who came to Linn County via Ohio and Indiana. Thomas Lewis lived to the age of one hundred years passing away in 1909. The 1911 county history noted that "for six decades [he] was numbered among the most respected and substantial citizens of this county" (Brewer and Wick 1911:27-28). In 1878 his property comprised 400 acres of land then valued at $12,000 and specialized in the raising of corn and hogs. He also held the offices of Justice of the Peace and Township Trustee (Chapman Brothers 1887:499; Western Historical Company 1878:764). He and his wife, Mary (White), had six children, among whom were Thomas C. Lewis, who married Alice Railsback and who took over the "old homestead place" upon reaching "his majority" (Ibid.). By 1911 this farmstead was comprised 400 acres of land in Sections 29, 31, and 32, T85N-R8W, in the neighborhood known as Lewis Bottoms. The Thomas Lewis farmstead is represented by Rural Architectural Site 12, which will be discussed in: i ; j . ! 2-14 While these two settlement patterns have altered the countryside. the pre-World War n suburban acreage movement also continues. In 1991, for example, the Urbanek Family purchased the McArthur Farmhouse and several aCres in Section 32 of the Lewis Bottoms. Vacant and threatened with demolition, this fannhouse with several acres of its historic farmland were purchased by the Urbaneks. The house now provides shelter for this family on a suburban acreage site. . While both exurban and suburban settlement have added popUlation to Fayette Township

• the population of this rural area continues to experience stress. In the early 19905, for example, the Mobry Fannstead in Section 30 was sold, following the death of its nonagenarian matriarch.

The land was sold and continues to be fanned. but no one now lives on the land and the fannhouse is abandoned. B. Rise of an Agricultural Economy The rise of an agriculttrral economy in Fayette Township has already been discussed in the previous section (ll-C) pertaining to archaeological resources, therefore, the following will specifically address this context as it relates to the architeCtural resources of the township. The rise of the township's agricultural economy spanned three eras: the Early Settlement Era, the Expansion Era, and the Consolidation Era. Of these, the architectural impact of the Consolidation Era (post-1913) is most prevalent on the current landscape of the township, although scattered resources relating to the earlier eras are extant. 1 . Early Settlement Era Agriculture During the Early Settlement Era the agriculture of Fayette Township focused primarily on subsistence level farming with some market income provided by the raising of livestock, particularly hogs. While this level of farming tended to require little in the way of structural shelters such as barns, at least one Early Settlement Era barn is known in the Fayette Township area. This bam is found in Section 17. T84N-8W, on the Railsback farmstead which was established in the 184Os, with the barn reportedly built c. 1857-58 towards the end of the Early Settlement Era. This early investment in a large building constructed solely for the purpose of housing livestock and their feed indicates movement towards a market-oriented fann economy. At least one other barn of this type and relative age was known in the township but which has since been demolished. That bam was built for the McClintock family, early settlers in Section 4, T84N-RSW, to the northeast of the Railsback farmstead. Among the early settlers of Fayette Township, the Lewis family had perhaps the greatest impact and influence on the agricultural settlement throughout the township's historic period. Thomas and John Lewis arrived in Fayette Township in April 1839 foHowing close on the heels of the fIrst Eum-American settler, Joseph Strawn, who had arrived a few weeks before. The Lewises were natives of Pennsylvania who carne to Linn County via Ohio and Indiana. Thomas Lewis lived to the age of one hundred years passing away in 1909. The 1911 county history noted that "for six decades [he] was numbered among the most respected and substantial citizens of this county" (Brewer and Wick 1911 :27 -28). In 1878 his property comprised 400 acres of land then valued at $12,000 and specialized. in the raising of corn and hogs. He also held the offices of Justice of the Peace and Township Trustee (Chapman Brothers 1887:499; Western Historical Company 1878:764). He and his wife, Mary (White), had six children, among whom were Thomas C. Lewis, who married Alice Railsback and who took over the "old homestead place" upon reaching "his majority" (Ibid.). By 1911 this farmstead was comprised 400 acres of land in Sections 29, 31, and 32, T85N-R8W, in the neighborhood known as Lewis Bottoms. The Thomas Lewis farmstead is represented by Rural Architectural Site 12, which will be discussed in 2-15 the next chapter. Another son, John Lewis, originally took over the family homestead in 1885 and operated the farm for two years before he moved into Palo where he was"engaged in merchandising for about six years in partnership with his father-in-law, under the firm name of Rawson and Lewis" (Clarke 1901:414). In 1893 he returned to the Lewis family farm where he engaged in general farming and stock raising (hogs and cattle) on a parcel adjacent to that of his brother Thomas C. Lewis (Ibid.). The John Lewis farmstead is represented by Rural Architectural Site 11 in Section 32, T85N-R8W.The other original Lewis family settler, John Lewis, brother of Thomas,"broke and improved the first farm west of Cedar Rapids and became the owner of over two hundred acres of very valuable and productive land" (Brewer and Wick 1911:401). Ilis son William J. "also possessed a tract of similar size and continued to engage in its cultivation and improvement up to the time of his death" (Ibid.). William J. Lewis married Johanna Blackburn, whose family also came from Ohio and settled in Fayette Township about tenyears after the Lewis family. Charles W. Lewis, son of William and Johanna, took over the management of his father's farmstead at age 18 when his father passed away. He farmed this property until 1900 when he rented it out. He subsequently moved into Benton County. Charles married Amy D. Matherin 1887 (Ibid.:401-402). The William J.and Charles W. Lewis farm was located in Section 5, T85N-R8W, and is represented by Rural Architectural Site 38, while the location of John Lewis's original farmstead may have been either in Section 8 or in Section 18 near the gristmill that he established on Bear Creek at an early day. Unfortunately, the available map data do not pinpoint the specific location of John Lewis's original house site, and there is at present no known archaeological or architectural association other than with archaeological site 13LN333 (see Chapter 3).In general the Lewis family holdings in the Lewis Bottoms neighborhood included bothprime floodplain farmland and upland timber tracts and livestock grazing lands. The Thomas Lewis property was predominantly bottomland, although he owned at least 120 acres of upland timber in Section 31, T85N-R8W, by 1859 (see Figure 2-1). TheWilliam J. and Charles W. Lewis property was situated entirely in the uplands.Examination of the available historic maps indicate that timber tracts were a common part of the surrounding farm properties well into the 1 890s. These tracts were small parcels, 40 acres or less, surrounding Pleasant Creek and along the Cedar River. These tracts were often separate from the main farm property but located in close proximity. Along Bear Creek, however, there were no small timber tracts. Along this valley, many of the farm parcels were oriented in an elongated north-south orientation in such a way that full advantage could be taken of both the timber and prairie margin (see Figure 2-1).Among the properties associated with the Lewis family are at least five extant farmsteads, one cemetery, and several archaeological properties including the Lewis Bottoms Church (site 13LN374), the Lewis gristmill and quarry (sites 13LN333 and 13LN334) along BearCreek, and the Thomas Lewis homestead archaeological site (13LN375). A school known as the Double Decker or Lewis Bottom school was located in the neighborhood and was attended by many of the Lewis family children. This school is non-extant and the archaeological remains inundated by the Pleasant Creek reservoir. The main impact of the Lewis family upon the township's history is their long-standing presence in the township, a presence which continues to. the p resert day- their successful farm enterprises; and theirinterrelations with other settlers through marriage which has spread the Lewis family tie over much of the township and neighboring areas. Some of these relations include ties with the Railsback, Elson, Mather, Blackburn, and possibly the McClintock and McArthur families. Other sites recorded in association with these related families may includearchaeological sites 13LN336, 13LN347, 13LN349, 13LN365, 13LN366, 13LN373, and. I . ! 2*15 the next chapter. Another son, John Lewis, originally took over the family homestead in 1885 and operated the farm for two years before he moved into Palo where he was "engaged in merchandising for about six years in partnership with his father-in-law, under the finn name of Rawson and Lewis" (Clarke 1901:414). In 1893 he returned to the Lewis family farm where he engaged in . general fanning and stock raising (hogs and cattle) on a parcel adjacent to that of his brother Thomas C.l.ewis (Ibid.). The John Lewis farmstead is represented by Rural Architectural Site 11 in Section 32. T85N-R8W. The other original Lewis family settler, John Lewis, brother of Thomas ,"broke and improved the first farm west of Cedar Rapids and became the owner of over two hundred acres of very valuable and productive (Brewer and Wick 1911:401). His son William J. "also possessed a tract of similar size and continued to engage in its cultivation and improvement up to the time of his death" (Ibid.). William J. Lewis married Johanna Blackburn, whose family also came from Ohio and settled in Fayette Township about ten years after the Lewis family. Charles W. Lewis, son of William and Johanna, took over the management of his father's farmstead at age 18 when his father passed away. He farmed this propeny until 1900 when he rented it out. He subsequently moved into Benton County. Charles married Amy D. Mather in 1887 (Ibid.:401-402). The WilliamJ. and Charles W. Lewis fann was located in Section 5, T8SN-R8W, and is represented by Rural Architectural Site 38, while the location of John Lewis's original fannstead may have been either in Section 8 or in Section 18 near the gristmill that he established on Bear Creek at an early day. Unfortunately, the available map data do not pinpoint the specific location of John Lewis's original house site, and there is at present no known arehaeological or arehitectura1 association other than with archaeological site 13LN333 (see Chapter 3). In general the Lewis family holdings in the Lewis Bottoms neighborhood included both prime floodplain fannland and upland timber tracts and livestock grazing lands. The Thomas Lewis property was predominantly bottomland, although he owned at least 120 acres of upland timber in Section 31, T85N-R8W, by 1859 (see Figure 2-1). The*William J. and Charles W. Lewis property was situated entirely in the uplands. Examination of the available historic maps indicate that timber tracts were a common part of the surrounding fann properties well into the 1890s. These tracts were small parcels, 40 acres or less, surrounding Pleasant Creek and along the Cedar River. These tracts were often separate from the main farm property but located in close proximity. Along Bear Creek, however, there were no small timber tracts. Along this valley, many of the farm parcels were oriented in an elongated nonh-south orientation in such a way that full advantage could be taken of both the timber and prairie margin (see Figure 2-1). Among the properties associated with the Lewis family are at least five extant fannsteads, one cemetery, and several arehaeological properties including the Lewis Bottoms Church (site13LN374), the Lewis gristmill and quarry (sites 13LN333 and 13LN334) along Bear Creek, and the Thomas Lewis homestead archaeological site (13LN375). A schoollrnown as the Double Decker or Lewis Bottom school was located in the neighborhood and was attended by many of the Lewis family children. This school is non-extant and the archaeological remains inundated by the Pleasant Creek reservoir. The main impact of the Lewis family upon the township's history is their long-standing presence in the township, a presence which continues to the p'resent day. their successful farm enterprises; and their interrelations with other settlers through marriage which has spread the Lewis family tie over much of the township and neighboring areas. Some of these relations include ties with the Railsback, Elson, Mather, Blackburn, and possibly the McClintock and McArthur families. Other sites recorded in association with these related families may include archaeological sites I3LN336, 13LN347, 13LN349, 13LN365, 13LN366, 13LN373, and 2-16 13LN386 and rural architectural sites 9, 10, 17, 18, 21, 35, and 37 (see Chapter 3 for a discussion of these sites).At present the ties between the Lewis family and the Katieville steamboat landing settlement are unclear;, however, the landing was located in the heart of the Lewis Bottoms neighborhood and indicates the initial strength and promise of this neighborhood as a settlement enclave.2. Expansion Era Agicult =During the Expansion Era between 1859 and 1913, corn and livestock raising became increasingly more important, with wheat production and subsistence level production disappearing from the scene. Agriculture in general in the late Nineteenth Century began to focus on market production. During this period in Fayette Township the raising of hogs and cattle gained the forefront of agricultural production, with corn and other grains raised largely for feed and sale. To a certain extent, dairy production was a part of the Fayette Township agricultural economy during this period, with at least one creamery in operation by the 1880s in the Lewis Bottoms neighborhood (Centennial Committee 1979:11).Farm size increased slightly during the Expansion Era, with the average farm size in Fayette Township being 107 acres by 1895 and representing 136 farms. Timber tracts, on the other hand, began to decrease in number by the early 1900s indicating that these areasmay have been largely logged out by that time, and the ground put into agricultural production as either cultivated ground or pasturage.

3. Consolidation Era Agriculture The Consolidation Era was ushered in c. 1913 with the establishment of the Lincoln Highway through Linn County. While this context is generally defined by the rise of automobile and truck transportation, these events had a dramatic impact on the evolution of the county's agricultural economy and rural settlement as well. During the Twentieth Century, agriculture became characterized by specialization, intensification, and mechanization, with farms becoming larger and fewer in number. The improvement of the rural road system resulted in a farm-to-market network whereby products could be more easily transported to market, with the consumer items available in the towns and cities of the county becoming more affordable and accessible to rural customers.The improvement of the transportation system also resulted in the extension of suburban residential areas into the rural areas as well as the general increase in the number of rural residences either constructed or converted from older farmsteads for use by commuters.

Ofthe 55 extant rural habitation/farmstead properties presently in the project area portion of Fayette Township, 2 farmsteads have been completely abandoned, 18 former farmsteads have been converted into rural residences with the land rented out or worked by an absentee owner, 16 are functioning farmsteads (a combination of both historic farmsteads and modem farmsteads), and 19 consist of modern residences. One of the latter functions as a residence for a truck farm; however, the associated buildings and the truck farm operation are all of recent origin.As a result, the present rural landscape of Fayette Township has changed dramatically from its historic pre-1942 appearance. Modem residences are now interspersed with historic farmsteads, with some of the latter having been "rebuilt" through the construction of modem houses and/or outbuildings replacing the historic structures. An even more dramatic impact has been made by the construction of the Pleasant Creek Reservoir and the Duane Arnold Energy Center. The construction of the latter resulted in the destruction of at!rT . 1 i i i i . ;: [ 2-16 13LN386 and rural architectural sites 9, 10, 17, 18,21,35. and 37 (see Chapter 3 for a discussion of these sites). At present the ties between the Lewis family and the Katieville steamboat landing settlement are unclear; hOVv'ever, the landing was located in the heart of the Lewis Bottoms neighborhood and indicates the initial strength and promise of this neighborhood as a settlement enclave. 2. Expansion Era Agriculture During the Expansion Era between 1859 and 1913, com and livestock raising became increasingly more important, with wheat production and subsistence level production disappearing from the scene. Agriculture in general in the late Nineteenth Century began to focus on market production. During this period in Fayette Township the raising of hogs and cattle gained the forefront of agricultural production, with com and other grains raised largely forfeed and sale. To a certain extent, dairy production was a part of the Fayette Township agricultural economy during this period, with at least one creamery in operation by the 1880s in the Lewis Bottoms neighborhood (Centennial Committee 1979: 11). Farm size increased slightly during the Expansion Era, with the average farm size in Fayette Township being 107 acres by 1895 and representing 136 farms. Timber tracts, on the other hand, began to decrease in number by the early 19008 indicating that these areas may have been largely logged out by that time, and the ground put into agricultural production as either cultivated ground or pasturage.

3. Consolidation Era Agriculture The Consolidation Era was ushered in c. 1913 with the establishment of the Lincoln Highway through Linn County. While this context is generally defined by the rise of automobile and truck transportation, these events had a dramatic impact on the evolution of the county's agricultural economy and rural settlement as well. During the Twentieth Century, agriculture became characterized by specialization, intensification.

and . mechanization, with farms becoming larger and fewer in number. The improvement of the rural road system resulted in a farm-ta-market network whereby products could be more easily transported to market, with the consumer items available in the towns and cities of the county becoming more affordable and accessible to rural customers . The improvement of the transportation system also resulted in the extension of suburban residential areas into the rural areas as well as the general increase in the number of rural residences either constructed or converted from older farmsteads for use by commuters. Of the 55 extant rural habitationlfarmstead properties presently in the project area portion of Fayette Township, 2 farmsteads have been completely abandoned, 18 fonner farmsteads have been converted into rural residences with the land rented out or worked by an absentee owner, 16 are functioning farmsteads (a combination of both historic farmsteads and modern farmsteads). and 19 consist of modem residences. One of the latter functions as a residence for a truck farm; however. the associated buildings and the truck farm operation are all of recent origin. As a result, the present rural landscape of Fayette Township has changed dramatically from its historic pre-1942 appearance. Modem residences are now interspersed with historic with some of the latter having been "rebuilt" through the construction of modem houses and/or outbuildings replacing the historic strucrures. An even more dramatic impact has been made by the construction of the Pleasant Creek Reservoir and the Duane Arnold Energy Center. The construction of the latter resulted in the destruction of at / 2-17 least three historic farmsteads, while the construction of the reservoir resulted in the destruction of at least eight historic farmsteads. Some of these destroyed properties are evidenced by archaeological remains or have been covered over by the waters of the reservoir. While the majority of Consolidation Era farmsteads in Linn County and Fayette Township were geared increasingly toward livestock-corn-soybeans production, a number of Fayette Township farms also participated in dairy production well into the late twentieth century.The raising of sheep has also continued in the township to the present day although only on a few farmsteads. C. Town Building This section of the report discusses the evolution of town building in Palo. During the Expansion Era, the community's growth illustrates an emerging specialization of land use and improvements within the built environment, which were all affected by numerous historic influences. Transportation corridors, for example, provided powerful stimuli and profoundly affected the development of the community. (They are discussed in the following section of this report.) Commonly accepted practices and assumptions about the built environment also affected this historical development. The town's early plats, for example, illustrate certain town planning assumptions and continue to exert an abiding influence on the community. The railroad strongly influenced the evolution of the community. In the Twentieth Century, the center of Fayette Township's population beganto shift from the countryside to Palo. During the Consolidation Era, in-fill construction occurred in the community as a result of this influx. The automobile revolutionized Americans' life style and enabled people to live more distant from employment than ever in the past. Palo also experienced this revolution, symbolized by modem tract housing developments, which sprang up on its edges, to provide housing for commuters to Cedar Rapids and the Duane Arnold Energy Center. While the evolution of town building in Palo calls attention to these developments, understanding its significance requires wider historic context to provide a framework for evaluation. The surveying of more subsections in the Linn County Comprehensive Planning Project will help provide his context. The significance of town building practices in Palo will then begin to emerge, in greater or lesser relief, when compared with other communities of similar size and age in the county.I. Early Town Building, The location of Palo near what was then known as the Red Cedar River provided an inviting place for early settlement. Fayette Township was first settled in 1839 and was formally established in 1841. As the population of Fayette Township and Palo increased, government land available for sale vanished because it was improved for agricultural purposes. By the 1840s, the evolution of rural land into small communities, such as Palo, had begun. A subsequent evolution saw certain sections of the community develop specialized uses, such as residential and commercial. Areas of semi-public activities, typically in transitional areas between the commercial and residential sections, also emerged. Historic transportation corridors, which were intra- and inter-county in scope, affected this evolution, as well as local factors. Originally platted as Cedar Camp, the present town of Palo is the creation of John G. Cole, proprietor of the land. In 1854, Cole purchased a farm on this site from Mr. Pierce and lived on it south of Dry Creek (Centennial Committee 1979:5).***1 l "\ :. ! 2-17 least three historic fannsteads, while the construction of the reservoir resulted in the destruction of at least eight historic fannsteads. Some of these destroyed properties are evidenced by archaeological remains or have been covered over by the waters of the reservoir. While the majority of Consolidation Era fannsteads in Linn County and Fayette Township were geared increasingly toward livestock-corn-soybeans production, a number of Fayene Township fanns also participated in dalry production well into the late twentieth century. The raising of sheep has also continued in the township to the present day although only on a few fannsteads. C. Town Building This section of the report discusses the evolution of town building in Palo. Dwing the Expansion Era, the community's growth illustrates an emerging specialization of land use and improvements within the built environment, which were all affected by numerous historic influences. Transportation corridors, for example, provided powerful stimuli and profoundly affected the development of the community. (They are discussed in the following section of this report.) Commonly accepted practices and assumptions about the built environment also affected this historical development. The town's early plats, for example, illustrate cenain town planning assumptions and continue to exert an abiding influence on the community. The railroad strongly influenced the evolution of the community. In the Twentieth Century, the center of Fayette Township's population began to shift from the countryside to Palo. During the Consolidation Era. in-fill construction occurred in the community as a result of this influx. The automobile revolutionized Americans' life style and enabled people to live more distant from employment than ever in the past Palo also experienced this revolution, symbolized by modem tract housing developments. which sprang up on its edges, to provide housing for commuters to Cedar Rapids and the Duane Arnold Energy Center. While the evolution of town building in Palo calls attention to these developments, understanding its significance requires wider historic context to provide a framework for evaluation. The surveying of more subsections in the Linn County Comprehensive Planning ,Project will help provide his context The significance of town building practices in Palo will then begin to emerge. in greater or lesser relief, when compared with other communities of similar size and age in the county. 1. Early Town Building The location of Palo near what was then known as the Red Cedar River provided an inviting place for early settlement. Fayette Township was fIrst settled in 1839 and was formally established in 1841. As the population of Fayene Township and Palo increased, government land available for sale vanished because it was improved for agricultural purposes. By the 1840s. the evolution of rural land into small communities, such as Palo, had begun. A subsequent evolution saw certain sections of the community develop specialized uses, such as residential and commercial. Areas of semi-public activities, typically in transitional areas between the commercial and residential sections, also emerged. Historic transportation corridors, which were intra-and inter-county in scope, affected this evolution, as well as local factors. Originally platted as Cedar Camp, the present town of Palo is the creation of John G. Cole, proprietor of the land. In 1854, Cole purchased a farm on this site from Mr. Pierce and lived on it south of Dry Creek (Centennial Committee 1979:5). 2-18 Two plats--the Original Town and Hollenbeck's Addition--stand at the core of Palo (see Figure 2-4). These two plats provided the community with sufficient land for residential, commercial, and other development for more than a century. Platted in 1854 by John McArthur, under the employ of John G. Cole, the original townplat consisted of eight equally sized city blocks, organized in a grid, each divided into eight lots facing east and west, and organized along Main Street as a spine. The plan was filed for the public record on September 7, 1855. Four blocks were situated north of this spine,and four blocks were situated south of it. There were, in addition, two other blocks located in the southeast, Block 9, which comprised eight lots, and Block 10, which consisted of only three lots. This plat made efficient use of land available for settlement. The northern boundary of the town corresponded with a section line (possibly because Cole owned only to this boundary), while the southern boundary avoided, as much as possible, the flood plain of Dry Creek. The nature of this plat had a strongly east-west feeling to it. The plat was served by three east-west streets, Palo Avenue (now known as Vinton Street) on the north, Main Street through the center, and Church Street on the south. North-south streets were designated, from the east, as Iowa Avenue, First Street, Second Street, and ThirdStreet. Alleys in the original town were platted north to south.In 1858, John Hollenbeck filed for the public record a plat for the first addition to Palo.Known as Hollenbeck's Addition, it virtually doubled the size of the community. Thisplat, also organized in grid fashion to the points of the compass, extended the town'sstreets as they had previously been laid out. The new addition sited its lots, however, in a north-south orientation, in opposition to the earlier design. This would later have an important effect on the evolution of the central business district in Palo. Hollenbeck named Clinton Street the principal east-west street through his addition, while he named as VintonStreet that portion of his addition which abutted the original town plat. (Vinton Street has since supplanted Palo Avenue as the name for this thoroughfare.) Alleys in Hollenbeck's Addition were platted east to west.The American Civil War (1861-1865) profoundly affected the development of Fayette Township, interrupting town building in Palo. Following the war, Hollenbeck erected asubstantial, two-story, brick house on Vinton Street, which was used as both a hotel and as his private residence. The building remains standing today. Other residences, such as the gable-front and wing forms, may have also been erected at this time, or even earlier.By circa 1869, Palo had evolved its basic town configuration, which remains today. Laidout on a grid system of streets, oriented to the points of the compass, a commercial districtstood at the heart of the community with residential sections surrounding it.The effects of town building are particularly dramatic within Palo's commercial district.During the early years of the community, business operations evolved in a random fashion, with their locations determined by where their proprietors lived. "The first blacksmith shop," for example, "was operated by P. B. Yates, east of town" (Centennial Committee 1979:6.) By the late Nineteenth Century, however, the center of the business section of Palo was firmly established along Vinton Street, the corner of First Street being its hub.As already mentioned, the character of Palo's first plat and addition strongly influenced the evolution of the central business district. Vinton Street formed the dividing line between these two plats. While the north side of Vinton Street between First and Second Streets contained, for example, five frontage lots, the south side of Vinton Street only contained two frontage lots. As a result, the north side of Vinton Street evolved in a more densely improved fashion than the south side of the street because lots were more readily available. The juxtaposition of these two plats also forms the basis for the anomaly that the former; j 2-18 Two plats--the Original Town and Hollenbeck's Addition--stand at the core of Palo (see Figure 2-4). These two plats provided the community with sufficient land for residential, commercial. and other development for more than a century. Platted in 1854 by John McArthur, under the employ of John G. Cole, the original town plat consisted of eight equally sized city blocks, organized in a grid, each divided into eight lots facing east and west, and organized along Main Street as a spine. The plan was filed for the public record on September 7,1855. Four blocks were situated north of this spine. and four blocks were situated south of it. There were, in addition, two other blocks located in the southeast, Block 9, which comprised eight lots, and Block 10, which consisted of only three lots. This plat made efficient use of land available for settlement The northern boundary of the town corresponded with a section line (possibly because Cole owned only to this boundary), while the southern boundary avoided. as much as possible. the flood plain of Dry Creek. The nature of this plat had a strongly east-west feeling to it. The plat was served by three east-west streets. Palo A venue (now known as Vinton Street) on the north, Main Street through the center, and Church Street on the North-south streets were designated, from the east, as Iowa A venue, First Street, Second Street, and Third Street Alleys in the original town were platted north to south. In 1858. John Hollenbeck filed for the public record a plat for the first addition to Palo. Known as Hollenbeck's Addition, it vinually doubled the size of the community. This plat, also organized in grid fashion to the points of the compass, extended the town's streets as they had previously been laid out The new addition sited its lots, however, in a north-south orientation, in opposition to the earlier design. This would later have an important effect on the evolution of the central business district in Palo. Hollenbeck named Clinton Street the principal east-west street through his addition, while he named as Vinton Street that portion of his addition which abutted the original town plat (Vinton Street has since supplanted Palo Avenue as the name for this thoroughfare.) Alleys in Hollenbeck's Addition were platted east to west. The American Civil War (1861-1865) profoundly affected the development of Fayette Township, interrupting town building in Palo. Following the war, Hollenbeck erected a substantial, two-story, brick house on Vinton Street, which was used as both a hotel and as his private residence. The building remains standing today. Other residences. such as the gable-front and wing forms, may have also been erected at this time, or even earlier. By circa 1869, Palo had evolved its basic town configuration, which remains today. Laid out on a grid system of streets, oriented to the points of the compass, a connnercial district stood at the hean of the community with residential sections surrounding it The effects of town building are particularly dramatic within Palo's commercial district. During the early years of the community, business operations evolved in a random fashion, with their locations detennined by where their proprietors lived. "The first blacksmith shop," for example, "was operated by P. B. Yates, east of town" (Centennial Committee 1979:6.) By the late Nineteenth Century, however, the center of the business section of Palo was fumly established along Vinton Street, the corner of First Street being its hub. As already mentioned, the character of Palo's first plat and addition strongly influenced the evolution of the central business district. Vinton Street fanned the dividing line between these two plats. While the north side of Vinton Street between First and Second Streets contained, for example, five frontage Jots, the south side of Vinton Street only contained two frontage lots. As a result, the nonh side of Vinton Street evolved in a more densely improved fashion than the south side of the street because lots were more readily available. The juxtaposition of these two plats also fonns the basis for the anomaly that the former 2-19 Post Office and tavern, located on the southwest comer of Vinton and First, faces east, while the Yates Bros. General Store, Site #2 at 100-102 Vinton Street (now the U. S. Post Office), faces south.Concerning institutional development in Palo, the story is less definite. Although the evolution of land use patterns probably affected the development of land use patterns for institutions such as churches and lodges in the community, the incidence of such resources in the area is small and precludes analysis.2. The Railroad's InfluenceThe advent of the Burlington, Cedar Rapids, and Minnesota Railroad in 1869 introduced anew factor in the evolution of town building in Palo. During the 1860s, Clinton Street hadevolved as the'major east-west street in the community. With the arrival of the railroad, Main Street began to emerge as another corridor of importance. Still, because Palo was established prior to the arrival of the railroad, this new form of transportation affected town building to a lesser extent than if the community had been platted and laid out strictly as arailroad town. Although the railroad was located nearby, its tracks actually ran obliquely from the northwest to the southeast on the southwest edge of the town, about one-quarter mile from town center. A depot and ancillary buildings were erected here to serve the railroad. A grain elevator, scale house, and other related outbuildings were also established to handle shipments of farm products.The railroad profoundly affected the development of Fayette Township because it provided a convenient means to import and export products. As to land use, the road also made a significant impact. While town building had previously concentrated on development in the Original Plat and Hollenbeck's Addition, the railroad stimulated interest in land on the western edge of Palo. This was particularly true along Main Street, the most convenient street linking town center and the railroad yard. Main Street was extended to the west,giving access from Palo to the new railroad. A railroad-related commercial node evolved thereafter in this area, focused on businesses heavily dependent on the railroad for transportation. A lumber yard was established, for example, near the tracks, as well as the businesses mentioned above.To a lesser degree, 2nd Street evolved as a secondary corridor, with a doctor's officelocated at 704 Second Street and a hardware store located across the street. Residential land use was also affected by the railroad, as the evolution of Main Street as a residencecorridor attests. In spite of the railroad's influence, the development of the western sections of Palo required many years. As late as the 1920s, first generation homes were still being constructed in this area. A secondary commercial node never evolved adjacent to the railroad. In each case, the small population of Palo precluded such upbuilding.

3. In-fill Construction Certain specific lots within Palo's plats emerged as locations of preference for commercial, institutional, and residential construction.

Comer lots in particular were prized. These locations allowed merchants maximum pedestrian and vehicular traffic to pass their doors, while the prominent siting that comer lots lent residences recommended them to homeowners. The north side of Clinton Street in the 100 block provides a good example.During the 1860s and 1870s, the Methodist Church in Palo erected a new church on the , I, 2-19 Post Office and tavern, located on the southwest comer of Vinton and First, faces east, while the Yates Bros. General Store, Site #2 at 100-102 Vinton Street (now the U. S. Post Office), faces south. Concerning institutional development in Palo, the story is less definite. Although the evolution of land use patterns probably affected the development of land use patterns for institutions such as churches and lodges in the community, the incidence of suth resources in the area is small and precludes analysis.

2. The Railroad's Influence The advent of the Burlington, Cedar Rapids, and Minnesota Railroad in 1869 introduced a new factor in the evolution of town building in Palo. During the 1860s, Clinton Street had evolved as the *major east-west street in the community.

With the arrival of the Main Street began to emerge as another corridor of importance. Still, because Palo was established prior to the arrival of the railroad, this new fonn of transportation affected town building to a lesser extent than if the community had been platted and laid out strictly as a railroad town. Although the railroad was located nearby, its tracks actually ran obliquely from the northwest to the southeast on the southwest edge of the town, about one-quarter mile from town center. A depot and ancillary buildings were erected here to serve the railroad. A grain elevator, scale house, and other related outbuildings were also established to handle shipments of farm products. The railroad profoundly affected the development of Fayette Township because it provided a convenient means to import and export products. As to land use. the road also made a significant impact. While town building had previously concentrated on development in the Original Plat and Hollenbeck's Addition, the railroad stimulated interest in land on the western edge of Palo. This was particularly true along Main Street, the most convenient street linking town center and the railroad yard Main Street was extended to the west, giving access from Palo to the new railroad. A railroad-related commercial node evolved thereafter in this area. focused on businesses heavily dependent on the railroad for transportation. A lumber yard was established, for example. near the tracks, as well as the businesses mentioned above. To a lesser degree, 2nd Street evolved as a secondary corridor, with a doctor's office located at 704 Second Street and a hardware store located across the street Residential land use was also affected by the railroad, as the evolution of Main Street as a residence corridor attests. In spite of the railroad's influence, the development of the western sections of Palo required many years. As late as the 19208, first generation homes were still being constructed in this area. A secondary commercial node never evolved adjacent to the railroad. In each case, the small population of Palo precluded such upbuilding.

3. In-fill Construction Certain specific lots within Palo's plats emerged as locations of preference for commercial.

institutional, and residential construction. Comer lots in particular were prized These locations allowed merchants maximum pedestrian and vehicular traffic to pass their doors, While the prominent siting that comer lots lent residences recommended them to homeowners. The north side of Clinton Street in the 100 block provides a good example. During the 1860s and 1870s, the Methodist Church in Palo erected a new church on the 2-20 west comer, while a substantial I-story single-family dwelling was erected on the east cormer.As the population of Palo increased, property between the corners became more atractive for construction. As a result, lots were sometimes subdivided and in-fill construction appeared. This is readily apparent on the south side of Vinton Street in the 200 block.Here, houses dating from the late Nineteenth Century occupied the two lots facing the street. In 1903 the Modem Woodsmen of America acquired a portion of Lot 1 and builttheir lodge hall on this interior site. About 1941, a single-family dwelling was erected next door to it on land sold-off from Lot 2 (see Figure 2-4).4. Modem DevelotM=Land use in Palo began to change radically in the 1950s. A series of plats and Auditor's Plats transformed two areas adjacent to the city's core into parcels suitable for tract housing development. Table 2-1POST-WORLD WAR I" PLATS PALD, IOWA Year filed Name of Plat 1956 Auditor's Plat 362 1956 Auditor's Plat 384 1957 Auditor's Plat 397 n. d. Auditor's Plat 421 1966 Minor's First Addition to Palo 1970 Drake's First Addition 1970 Sanders First Addition n. d. Auditor's Plat 427 1975 Auditm's Plat 470 1979 Mel Thompson's First Addition 1980 Mel Thompson's Second Addition Although all these plats postdate the 50-year National Register cut-off date (and consequently were not surveyed for this report), the evolution of this land use is significantfor Palo for several reasons.The location of Auditor's Plat 362, the earliest of these plats and directly adjacent on the west to the Original Town plat, reinforces the east-west axial focus established by the community's first plats. The platting of A. P. 421 retains this same pattern. Both plats are noncontiguous to the highway. Later plats, however, dramatically break this pattern. They establish through their relationship with each other and with the highway a north-south axis. The curvilinear design of Lincoln and Thompson Drives further accentuates thedifferent character of these residential plats from the standard grid of earlier town building.Since the 1970s, another secondary commercial node has evolved in Palo. Located nearthe intersection of 1st Street and County Road E36, several business have been established on property, formerly given over to agriculture, to profit from vehicular traffic at this key intersection. Although these businesses are outside the period of this survey's concern,their establishment dramatically illustrates town building in response to opportunities provided by new transportation patterns.2-20 west comer. while a substantial I-story single-family dwelling was erected on the east comer. As the population of Palo increased, property between the comers became more attractive for construction. As.a result, lots were sometimes subdivided and in-fill construction appeared This is readily apparent on the south side of Vinton Street in the 200 block. Here, houses dating from the late Nineteenth Century occupied the two lots facing the street. In 1903 the Modem Woodsmen of America acquired a portion of Lot 1 and built their lodge hall on this interior site. About 1941. a single-family dwelling was erected next door to it on land sold-offfrom Lot 2 (see Figure 2-4). 4. Modem Development Land use in Palo began to change radically in the 1950s. A series of plats and Auditor's Plats transformed two areas adjacent to the city's core into parcels suitable for tract housing development. year filed 1956 1956 1957 n. d. 1966 1970 1970 n. d. 1975 1979 1980 Table 2-1 POST-WORlD WARn PLATS PALO,IOWA Name of Plat Auditor's Plat 362 Auditor's Plat 384 Auditor's Plat 397 Al1ditor's Plat 421 Minor's First Addition to Palo Drake's rust Addition Sanders rIl'St Addition Auditor's Plat 427 Auditor's Pla1470 Mel Thompson's rll'St Addition Mel Thompson's Second Addition Although all these plats postdate the 50-year National Register cut-off date (and consequently were not surveyed for this report). the evolution of this land use is significant for Palo for several reasons. The location of Auditor's Plat 362, the earliest of these plats and directly adjacent on the west to the Original Town plat, reinforces the east-west axial focus established by the community'S first plats. The platting of A. P. 421 retains this same pattern. Both plats are noncontiguous to the highway. Later plats, however, dramatically break this pattern. They establish through their relationship with each other and with the highway a north-south axis. The curvilinear design of Lincoln and Thompson Drives further accentuates the different character of these residential plats from the standard grid of earlier town building. Since the 19705, another secondary commercial node has evolved in Palo. Located near the intersection of 1st Street and County Road E36. several business have been established on property, fonnerly given over to agriculture, to profit from vehicular traffic at this key intersection. Although these businesses are outside the period of this survey's concern, their establishment dramatically illustrates town building in response to opportunities provided by new transportation patterns. 2-21 ii 5. £onc1usionl The attempt to classify Palo's experience in town building in terms of standard terminology for urban development may or may not be appropriate. Terms like "residential district,""commercial district," and "central business district" may not have had meaning to local residents in describing their built environment. The random fashion of development suggested in the last paragraph on page 2-18 may give a more accurate sense of townbuilding in Palo. In this regard, the community's experience may be that of a hybrid wagon haul community and rural crossroads, with a limited influence from the railroad overlaid. It is this particular type of development as a "rural village," which may make Palo significant. These judgments, however, cannot really be made until more results fromI i subsection surveys elsewhere in Linn County are available. !i ~D. Tran _sorafonFayette Township in Linn County provides a good model to analyze and evaluate transportation systems because the township occupied a strategic geographic location.Situated on the Cedar River and at a midway point between Marion-Cedar Rapids and Vinton in Benton County, Palo profited from overland transportation. The section on "Transpmoaution Development in Fayette Township" in the archaeological portion of this chapter discusses in detail the evolution of transportation patterns on the local scene.E. Arhitecturai Resources of Fayette TownshipArchitectural resources within the study area can be divided into the following three subcontexts.

1. The Architecture of Palo 2. Resources of John Livermore 3. Rural Architecture Each of them is discussed in detail below.1. The Architecture of Palo A modesty of architectural detailing, the small scale of numerous buildings, and a general lack of strong stylistic influences in its housing stock characterize the historic architecture of Palo. The community's architecture can be analyzed and evaluated through the study of its building materials, scale, form, and stylistic influences.

The following section of this report discusses each of these topics.

a. Building Materials Building materials are significant because they determine the physical opportunities and constraints imposed on architecture.

They also profoundly affect architectural embellishment. The earliest construction in the study area employed locally available building materials. They included stone, timber, locally produced brick, and a limited amount of building materials imported by overland animal-powered drayage. With arrival of the railroad, the importation of manufactured building materials became more convenient. A more standardized architecture resulted as the Nineteenth Century drew to a close and local 5. Conclusion The attempt to classify Palo's experience in town building in tenns of standard tenninology for urban development may or may not be appropriate. Tenns like "residential district," "commercial district," and "Central business district" may not have had meaning to local residents in describing their built environment. The random fashion of development suggested in the last paragraph on page 2-18 may give a more accurate sense of town building in Palo. In this regard., the community's experience may be that of a hybrid wagon haul community and rural crossroads, with a limited influence from the railroad overlaid. It is this particular type of development as a "rural village," which may make Palo significant These judgments, however, cannot really be made until more results from subsection surveys elsewhere in Linn County are available. D. Transportation Fayette Township in Linn County provides a good model to analyze and evaluate transportation systems because the township occupied a strategic geographic location. Situated on the Cedar River and at a midway point between Marion-Cedar Rapids and Vinton in Benton County, Palo profited from overland transportation. The section on "Transportation Development in Fayette Township" in the archaeological portion of this chapter discusses in detail the evolution of transportation patterns on the local scene. E. Architectural ResourceS of Fayette Township Architectural resources within the study area can be divided into the following three subcontexts.

l. The Architecture of Palo 2. Resources of John Livermore

3. Rural Architecture Each of them is discussed in detail below. 1 . The Architecture of Palo A modesty of architectural detailing, the small scale of numerous buildings, and a general lack of strong stylistic influences in its housing stock characterize the historic architecture of Palo. The community's architecture can be analyzed and evaluated through the study of its building materials, scale, form, and stylistic influences.

The following section of this repon discusses each of these topics. a. Building Materials Building materials are significant because they detennine the physical opportunities and constraints imposed on architecture. They also profoundly affect architectural embellishment. The earliest construction in the study area employed locally available building materials. They included stone, timber, locally produced brick, and a limited amount of building materials imported by overland animal-powered drayage. With arrival of the railroad, the importation of manufactured building materials became more convenient. A more standardized architecture resulted as the Nineteenth Century drew to a close and local 2-22 construction in the study area moved into mainstream American design. As new technologies became available--concrete and concrete block, for example--these also changed the complexion of local architecture. Resources constructed of concrete block comprise an important body of historic buildings and structures within the survey area.For this reason, considerable space is given over in this report to this building material. A specific subcontext, "Resources of John Livermore," follows near the end of this section.Several of the earliest surviving edifices in Palo are constructed of brick, including the John Hollenbeck House at 112 Vinton Street (Site #10) and a I-story cottage at 101 ClintonStreet (Site

1. 50). Constructed of locally extracted clay, this brick was sun-dried.

During the fourth quarter of the Nineteenth Century, brick fell from favor in the community. Until the 1960s, brick virtually vanished from the palette of residential building materials. When it reappeared, it was as a decorative element, veneered on ranch style houses, such as the example at 112 Main Street.Limestone is widely available in the area, and this stone provided foundation material for early homes. During the reconnaissance survey, volunteer surveyors identified in the field a number of buildings, structures, and historic sites associated with these building materials. The Hollenbeck House, Site #10 at 112 Vinton Street in Palo, provides a good example of this employment as a foundation material. Such resources are significant because they date from an early period in the area's development; because they call attention to important early occupations, including stone masons, quarrymen, and lime manufacturers; because they might call attention to certain ethnic building practices; and because they contribute to the aesthetics of the architectural design.In spite of the quality and availability of limestone in Fayette Township, its use was limited primarily to foundations.. The Hollenbeck House also exemplifies this limited use because its lintels and sills are fabricated of wood and its water table is fashioned in brick.When stone reappeared in Fayette Township, it served a decorative rather than a structural purpose. For example, one Craftsman-inspired house in Palo (Site #50 at 808 2nd Street)extensively employs fieldstone, while a circa 1962 house (Site #46 at 600 Main Street) uses stone veneer to embellish a portion of its facade.The use of concrete building materials, like those of stone and soft brick, exemplifies the use of local building products. Concrete products became popular during the early years of the Twentieth Century and comprise a widely employed building material in Fayette Township. Many of these products were actually manufactured in Palo. Cement as an Iowa-manufactured product is relatively new, dating from the first decade of the Twentieth Century. The Northwestern States Portland Cement Company of Mason City established the first large-scale plant in Iowa in 1906. In 1910 the Lehigh Portland Cement Company located a second plant in Mason City. Cement production rapidly became one of the Hawkeye State's primary mineral products. In 1952, for example, cement ranked second only to coal as Iowa's most valuable mineral product (Petersen 1952:25).The Cedar River Valley contains a particularly outstanding quality of sand for mixing with Portland cement to form concrete. This sand also occurs in a wide range of sizes so thatconcrete manufacturers could, after grading the sand, use it directly from the pits without importing aggregatives. Extensive deposits of sand insured that these products could be produced at competitive prices. Because of these local resources, the Cedar River valley 2-22 construction in the study area moved into mainstream American design. As new technologies became available--concrete and concrete block. for example--these also changed the complexion of local architecture. Resources constructed of concrete block comprise an imponant body of historic buildings and structures within the survey area. For this reason, considerable space is given over in this report to this building material. A specific subcontext., "Resources of John Livennore," follows near the end of this section. Several of the earliest surviving edifices in Palo are constructed of brick, including the John Hollenbeck House at 112 Vinton Street (Site #10) and a I-story cottage at 101 Clinton Street (Site #50). Constructed of locally extracted clay, this brick was sun-dried. During the fourth quarter of the Nineteenth Century. brick fell from favor in the community. Until the 1960s, brick vinually vanished from the palette of residential building materials. When it reappeared, it was as a decorative element, veneered on ranch style houses, such as the example at 112 Main Street. Limestone is widely available in the area, and this stone provided foundation material for early homes. During the reconnaissance survey, volunteer surveyors identified in the field a number of buildings, structures, and historic sites associated with these building materials. The Hollenbeck House, Site #10 at 112 Vinton Street in Palo, provides a good example of this employment as a foundation material. Such resources are significant because they date from an early period in the area's development; because they call attention to important early occupations, including stone masons, quarrymen, and lime manufacturers; because they might call attention to certain ethnic building practices; and because they contribute to the aesthetics of the architectural design. In spite of the quality and availability of limestone in Fayette Township, its use was limited primarily to foundations.. The Hollenbeck House also exemplifies this limited use because its lintels and sills are fabricated of wood and its water table is fashioned in brick. When stone reappeared in Fayette Township, it served a decorative rather than a structural purpose. For example, one Craftsman-inspired house in Palo (Site #50 at 808 2nd Street) extensively employs fieldstone, while a circa 1962 house (Site #46 at 600 Main Street) uses stone veneer to embellish a portion of its facade. The use of concrete building materials, like those of stone and soft brick, exemplifies the use of local building products. Concrete products became popular during the early years of the Twentieth Century and comprise a widely employed building material in Fayette Township. Many of these products were actually manufactured in Palo. Cement as an Iowa-manufactured product is relatively new, dating from the flI"St decade of the Twentieth Century. The Northwestern States Portland Cement Company of Mason City established the first large-scale plant in Iowa in 1906. In 1910 the Lehigh Portland Cement Company located a second plant in Mason City. Cement production rapidly became one of the Hawkeye State's primary mineral products. In 1952, for example, cement ranked second only to coal as Iowa's most valuable mineral product (Petersen 1952:25). The Cedar River Valley contains a particularly outstanding quality of sand for mixing with Portland cement to fonn concrete. This sand also occurs in a wide range of sizes so that concrete manufacturers could, after grading the sand, use it directly from the pits without importing aggregatives. Extensive deposits of sand insured that these products could be produced at competitive prices. Because of these local resources, the Cedar River valley 2-23 area developed important local industries to produce concrete building materials. In Eastern Iowa, Waterloo developed a particularly strong industry to produce these materials. Some definitions are appropriate at this point. Portland cement concrete (PCC) is a mixture of Portland cement, sand, gravel aggregate, and water. Some structures, like highways and sidewalks, have large sized aggregate material in them, while other PCC products, like concrete blocks, have smaller aggregate. Asphaltic cement concrete (ACC) is a mixture of asphalt, cement, sand, and gravel. This material is used primarily for transportation surfaces. Stucco is a mixture of Portland cement, sand, and water. Because the mixture usually lacks course aggregate (like PCC), stucco is used for surfaces that require less strength than concrete. Stucco was traditionally applied with a plaster's trowel to form the cladding for exterior and interior walls and for ceilings. In the Twentieth Century, stucco began to be applied using an air gun.Concrete blocks were touted at the beginning of the Twentieth Century as an ideal building material for residential, commercial, and industrial construction. These blocks were fire resistant, very durable, and required minimal maintenance. Because they could be fabricated of local materials, cost could be kept low. Concrete blocks did not require firing in a kiln and saved these production costs, but they were as strong as fired brick. Concrete block had disadvantages in comparison with brick, however. A major objection revolved around aesthetics. With its grey color and massive feeling, a concrete block house presented a somber appearance. When combined with grey slate roofs, which are occasionally encountered, this feeling is even stronger. While such an image might be appropriate for commercial and industrial buildings, residential uses for concrete block presented challenges. During the early years of the Twentieth Century, many architectural pattern books featured houses constructed entirely of concrete block. These widely disseminated sources advocated the material as novel and new. Even more houses were built with foundations constructed of concrete block. Finally, numerous decorative elements were made in concrete. These included porch posts and capitals, balustrades, lintels, sills, stringcourses, fence posts, and other architectural detailing. As in the 1960s, when the "all electric house" was trendy, so too the all concrete house was understood to be innovative in the early years of this century and many contractor-builders and homeowners employed the new building material.The Sears, Roebuck and Company's mail-order catalogue, doyen of popular American civilization, provides a good example of the growing acceptance of concrete block as a building material. Although the 1902 edition makes no mention of concrete as a building material, the 1908 edition (catalogue No. 117) contained six and one-half pages of products designed to fabricate concrete block. (See Figures 2-9 to 2-12). By this time, the company also published a special concrete building block machinery catalogue, which treats at length upon the concrete building block branch of industry, in which the farmer, the village building material dealer, the small contractor or builder, and the ordinary property owner is most interested. (Sears, Roebuck and Company 1969:574.) The same catalogue only included a one-half-page advertisement for a brick-making machine--a telling contrast between products designed to fabricate brick and concrete. (See Figure 2-12.)Concerning Palo specifically, its central business district suffered a major fire in 1912.Businesses in Palo quickly responded to this disaster in several ways. Decisions were made to replace the lost buildings. Business people also showed considerable concern that 2-23 area developed important local industries to produce concrete building materials. In Eastern Iowa, Waterloo developed a particularly strong industry to produce these materials. Some definitions are appropriate at this point Portland cement concrete (PeC) is a mixture of Portland cement, sand, gravel aggregate, and water. Some structures, like highways and sidewalks. have large sized aggregate material in them, while other PCC products, like concrete blocks. have smaller aggregate. Asphaltic cement concrete (ACC) is a mixture of asphalt, cement, sand. and gravel. This material is used primarily for transportation surfaces. Stucco is a mixture of Portland cement, sand, and water. Because the mixture usually lacks course aggregate (like PCC), stucco is used for surfaces that require less strength than concrete. Stucco was traditionally applied with a plaster's trowel to form the cladding for exterior and interior walls and for ceilings. In the Twentieth Century, stucco began to be applied using an air gun. Concrete blocks were touted at the beginning of the Twentieth Century as an ideal building material for residential. commercial, and industrial construction. These blocks were fIre resistant, very durable, and required minimal maintenance. Because they could be fabricated of local materials, cost could be kept low. Concrete blocks did not require firing in a kiln and saved these production costs, but they were as strong as f1red brick. Concrete block had disadvantages in comparison with brick, however. A major objection revolved around aesthetics. With its grey color and massive feeling, a concrete block house presented a somber appearance. When combined with grey slate roofs, which are occasionally encountered, this feeling is even stronger. While such an image might be appropriate for commercial and industrial buildings, residential uses for concrete block presented challenges. During the early years of the Twentieth Century, many architectural pattern books featured houses constructed entirely of concrete block. These widely disseminated sources advocated the material as novel and new. Even more houses were built with foundations constructed of concrete block. Finally, numerous decorative elements were made in concrete. These included porch posts and capitals, balusttades, lintels, sills, stringcourses. fence posts, and other architectural detailing. As in the 1960s, when the "all electric house" was trendy, so too the all concrete house was understood to be innovative in the early years of this century and many contractor-builders and homeowners employed the new building material. The Sears, Roebuck and Company's mail-order catalogue, doyen of popular American civilization, provides a good example of the growing acceptance of concrete block as a building material. Although the 1902 edition makes no mention of concrete as a building material, the 1908 edition (catalogue No. 117) contained six and one-half pages of products designed to fabricate concrete block. (See Figures 2-9 to 2-12). By this time, the company also published a special concrete building block machinery catalogue, which treats at length upon the concrete building block branch of industry, in which the farmer, the village building material dealer, the small contractor or builder, and the ordinary property owner is most interested. (Sears, Roebuck and Company 1969:574.) The same catalogue only included a one-half-page advertisement for a brick-making rnachine--a telling contrast between products designed to fabricate brick and concrete. (See Figure 2-12.) Concerning Palo specifically, its central business district suffered a major fire in 1912. Businesses in Palo quickly responded to this disaster in several ways. Decisions were made to replace the lost buildings. Business people also showed considerable concern that 2-24 these new buildings would be more fire-resistant than hitherto. The story of thisreconstruction is discussed below in the section on "Resources of John Livermore." At all periods of Palo's development, wood frame has comprised the most popular building material for residential construction. Because of the quantity of these resources and their lack of distinguishing characteristics, wood frame was excluded from the diagnostic of building materials. Few other building materials have been used in Palo's residential architecture in addition to those already mentioned. Exceptional, in this regard, is the single use of fieldstone in the house at 808 2nd Street (Site #60). Constructed in 1920 and influenced by Craftsman styling, this 1-1/2-story single-family dwelling originally featured a 1-story facade porch. Sometime after original construction, the house underwent considerable alteration. These changes included installation of a fireplace with an exterior wall chimney, removal of the front porch and construction of a new porch on the south elevation, and, apparently, facing the exposed foundation of the house. All these improvements featured fieldstone as a building material.A final note is in order concerning building materials in Palo. Stucco, widely found throughout Iowa during the years before and after World War I, made little inroad in Palo.Perhaps the dominance of concrete block in the community supplanted its popularity. Atany rate, stucco is much less popular as a building material in Palo than in many other Iowa communities.

b. Scale Scale, understood as the size of buildings and structures in relationship to others of a similar functional type, provides one criterion for architectural evaluation.

Resources in one study area can be compared using this criterion with similar resources in another study area, and conclusions may be made from these comparisons to evaluate their architectural design and construction. Scale is an important criterion to evaluate resources in the studyarea, because a number of residential and commercial buildings exhibit an unusually small size. By extension, scale can provide other clues about the history of Fayette Township, financial capability, for example.Concerning residential resources, while 1-story houses are most frequently encountered, 1-1/2-story residences are fairly well scattered throughout the community. The number of 2-story houses is restricted. The small scale of many residences in Palo has meant that, over the years, many additions have been added to these buildings. The cottage at 41 Vinton Street, for example, now has a gable-front addition.As might be expected, the larger houses in Palo also generally exhibit richer architectural detail and more complex design than smaller residences. While these larger houses would not stand out as large in Cedar Rapids, Marion, or Mount Vernon, they do so in Palo because of its context.Commercial buildings in Palo tend to be small in size. The floor space provided by such buildings has historically been adequate to commercial enterprise in the community. Yet Palo (and other towns in Linn County, such as Prairieburg) feature commercial buildings of remarkably small size.2-24 these new buildings would be more fire-resistant than hitherto. The story of this reconstruction is discussed below in the section on "Resources of John Livennore." At all periods of Palo's development, wood frame has comprised the most popular building material for residential construction. Because of the quantity of these resources and their lack of distinguishing characteristics, wood frame was excluded from the diagnostic of building materials. Few other building materials have been used in Palo's residential architecture in addition to those already mentioned. Exceptional, in this regard, is the single use of fieldstone in the house at 808 2nd Street (Site #60). Constructed in 1920 and influenced by Craftsman styling, this I-II2-story single-family dwelling originally featured a I-story facade porch. Sometime after original construction, the house underwent considerable alteration. These changes included installation of a fireplace with an exterior wall chimney, removal of the front porch and construction of a new porch on the south elevation, and, apparently, facing the exposed foundation of the house. All these improvements featured fieldstone as a building materiaL A final note is in order concerning building materials in Palo. Stucco, widely found throughout Iowa during the years before and after World War I, made little inroad in Palo. Perhaps the dominance of concrete block in the community supplanted its popularity. At any rate, stucco is much less popular as a building material in Palo than in many other Iowa communities. ' b. Scale, understood as the size of buildings and structures in relationship to others of a similar functional type, provides one criterion for architectural evaluation. Resources in one study area can be compared using this criterion with similar resources in another study area, and conclusions may be made from these comparisons to evaluate their architectural design and construction. Scale is an important criterion to evaluate resources in the study area, because a number of residential and commercial buildings exhibit an unusually small size. By extension, scale can provide other clues about the history of Fayette Township, financial capability, for example. Concerning residential resources, while I-story houses are most frequently encountered, 1-1/2-story residences are fairly well scattered throughout the community. The number of 2-story houses is restricted. The -small scale of many residences in Palo has meant that, over the years, many additions have been added to these buildings. The cottage at 41 Vinton Street, for example, now has a gable-front addition. As might be expected, the larger houses in Palo also generally exhibit richer architectural detail and more complex design than smaller residences. While these larger houses would not stand out as large in Cedar Rapids, Marion, or Mount Vernon, they do so in Palo because of its context. Commercial buildings in Palo tend to be small in size. The floor space provided by such buildings has historically been adequate to commercial enterprise in the community. Yet Palo (and other towns in Linn County, such as Prairieburg) feature commercial buildings of remarkably small size. 2-25 A pair of twin one-story, frame buildings at 104 and 106 Vinton Street in Palo provide fine examples. Both are clad in weatherboard and feature a two-bay facade with a boom town front. The width of their facades measures only about 12 feet. They are both located on property where the Yates Brothers General Store stood prior to its destruction by fire.Each of these buildings stands independent of all others with some footage in between them. This design suggests lessons learned through the Fire of 1912 and a conscious attempt to limit fire damage in the future.The Palo Savings Bank at 116 Vinton Street provides another good example of a small-scale commerial building. Standing on a stone foundation and constructed of brick, the footprint of this building measures approximately 14'x36'. Although small in size, the building features a richness of building materials and architectural detail unusual in Palo.c. FQrm Another potential for diagnostic analysis is form. For the purposes of this survey, form refers to a resource's volume and massing, the most distinctive element of which is roof shape. A typology was developed for this element. This typology embraces other elements, which contribute to a building's volume--namely ground plan and elevation. Taken together, these three factors determine much of any building's design. They are particularly useful to analyze vernacular architecture and were developed in this survey because much of the surveyed architecture is vernacular in nature.Residential resources in the study area comprise, almost without exception, single-family dwellings. No examples were found of duplexes, double houses, apartments buildings, or other multi-family dwellings originally constructed as such. For this reason, a typology ofresidential function has limited use for this study area and was not developed for this report Residential function is mentioned, however, for possible use in future surveys of Linn County.Although restricted in their function (defined as the resource's intended use), the residential resources in the study area exhibit a variety of forms. Some are associated with specific periods in time. The compound roof, for example, was popular at the, turn of the Twentieth Century. In other instances, ground and roof plans, such as the side-gable, persisted over a long period of time.The following typology of roof shapes was developed for this survey.I. Gable-Front

2. Gable-Front-and Wing 3. Side-Gabled

4. Pyramidal 5. Compound 6. Other Shapes: i 2-25 A pair of twin one-story, frame buildings at 104 and 106 Vinton Street in Palo provide fme examples.

Both are in weatherboard and feature a two-bay facade with a boom town front The width of their facades measures only about 12 feet. They are both located on property where the Yates Brothers General Store stood prior to its destruction by fire. Each of these buildings stands independent of all others with some footage in between them. 'This design suggests lessons learned through the Fire of 1912 and a conscious attempt to limit fire damage in the future. The Palo Savings Bank at 116 Vinton Street provides another good example of a scale commercial building. Standing on a stone foundation and constructed of brick, the footprint of this building measures approximately 14'x36'. Although small in size, the building features a richness of building materials and architectural detail unusual in Palo. c. Em:m Another potential for diagnostic analysis is form. For the purposes of this survey, form refers to a resource's volume and massing, the most distinctive element of which is roof shape. A typology was developed for this element This typology embraces other elements, which contribute to a building's volume--namely ground plan and elevation. Taken together, these three factors detennine much of any building's design. They are particularly useful to analyze vernacular architecrure and were developed in this survey because much of the surveyed architecture is vernacular in nature. Residential resources in the study area comprise, almost without exception, single-family dwellings. No examples were found of duplexes, double houses, apartments buildings, or other multi-family dwellings originally constructed as such. For this reason, a typOlogy of residential function has limited use for this study area and was not developed for this report. Residential function is mentioned. however. for possible use in future surveys of Linn County. Although restricted in their function (d.efmed as the resource's intended use), the residential resources in the study area exhibit a variety of forms. Some are associated with specific periods in time. The compound roof, for example, was popular at the'tum of the Twentieth Century. In other instances. ground and roof plans, such as the side-gable, persisted over a long period of time. The following typOlogy of roof shapes was developed for this survey. 1. Gable-Front

2. Gable-Front-and Wing 3. Side-GabJed

4. Pyramidal

5. Compound 6. Other Shapes 2-26 The subsections which follow discuss each of these shapes.1. Gable-Front The following resources in the study area exhibit gable-front roof plans: lz;tp # Wjetnrir-Kamp AAAdvp-flatp of ri etmet;nn 17 House 18 House 22 House 38 House 305 Vinton Street 206 Vinton Street 300 Vinton Street 208 Main Street Undetamined Between 1931-50 Circa 1940 c. 1905 ?The gable-front is one of the earliest residential designs in the study area. The simple house at 206 Vinton Street, Site #18, illustrates an example dating from the 1930s, 1940s, or early 1950s. Its rise-over-run (the proportion of its roof distance to the area it covers) comprises about 9' over 12'. (Sometimes the proportion can be considerably greater, such as the Queen Anne-influenced house at 201 Vinton Street, Site #9, which features about an 13' over 12' rise-over-run.)

2. Gable-Front and Wing The following resources in the study area exhibit gable-front-and-wing roof plans: C. a ; 1.4 W A !LR 2 h:*I.fJ. OLM-954 flULftAR -JdU %it %.tmtt5uitUasd 3A House 10 John HoUenbeck House 39 House 61 House 107 Vinton Street 112 Vinton Street 111 Main Street 611 Main Street Late 19th Century c. 1870 Late 19th Century Late 19th Century This type combines a gable-front design with a side gable wing. The wing, which is placed slightly setback from the gable front, is covered by a side gable roof, intersecting the gable front at right angles. The wing can contain two-stories, such as Site #39 at 111 Main Street, one and a half-stories, such as Site #61 at 611 Main Street. One-story examples were not encountered during the survey. Although the gable-front portion of the building can vary in the number of its stories, the gable-front is always as high, if not higher, than the side wing.3. Side-Gabled The following resources in the study area exhibit side-gabled roof plans: The subsections which follow discuss each of these shapes. 1. Gable-Front The following resources in the study area exhibit gable-front roof plans: # Hismrik Nam!:: Address Date of ConSDllction 17 House 305 Vinton Street Undetermined 18 House 206 Vinton Street. Between 1931-50 22 House 300 Vinton Street Circa 1940 38 House 208 Main Street c. 1905? The gable-front is one of the earliest residential designs in the study area. The simple house at 206 Vinton Street, Site #18, illustrates an example dating:from the 1930s, 194Os, or early 1950s. Its rise-over-run (the proportion of its roof distance to the area it covers) comprises about 9' over 12'. (Sometimes the proportion can be considerably greater, such as the Queen Anne-influenced house at 201 Vinton Street, Site #9, which features about an 13' over 12' rise-over-run.)

2. Gable-Front and Wing The following resources in the study area exhibit gable-front-and-wing roof plans: Site # Histori k Agdress Date ofCcnstructiw 3A Hoose 107 Vinton Street. Late 19th Century 10 John Hollenbeck House 112 Vinton Street c. 1870 39 Hoose 111 Main Street Late 19th Century 61 House 611 Main Street Late 19th Century This type combines a gable-front design with a side gable wing: The wing. which is placed slightly setback from the gable front, is covered by a side gable roof, intersecting the gable front at right angles. The wing can contain two-stories, such as Site #39 at 111 Main Street, one and a half-stories, such as Site #61 at 611 Main Street. One-story examples were not encountered during the survey. Although the gable-front portion of the building can vary in the number of its stories, the front is always as high, if not higher, than the side wing. 3. Side-Gabled The following resources in the study area exhibit side-gabled roof plans:

2-27 qQ;f.' # U; '4 M -AtArpee T),ti- of rnnetnirtinn 2 34 U M 3B House 13 House 15 House 20 House 24 House 26 House 33 House 40 House 50 House I07-1/2 Vinton Street 207 Vinton Street 211 Vinton Street 210 Vinton Street 302 Vinton Street Unknown After 1931 Late 19th Century Late 1890s 1930s or 1940s 46 Vinton Street Late 1930s-early 1940s 43 Main Street 300 Main Street 100 Clinton Street

c. 1948 1960s c. 1868 The side-gabled form provided an early solution for both linear and masseddesigns. The one-story, brick example at 100 Clinton Street (Site #50) illustrates a linear ground plan, two units situated side-by-side forming the facade. The example at 46 Vinton Street (Site #26) illustrates a massed design, each floor being two-units deep.The pitch of side-gables can vary dramatically and illustrate architectural influence.

Site #50 has, for example, a rise over run approximately 4 in 12. The example at 43 Main Street (Site #33) features an approximately 8 over 12 rise over run, about twice as steep a pitch. The steep pitch of Site #33 points to Colonial Revival influences. The so-called I-House is an important sub-type of the side-gable shape in the Midwest. The I-House contains two stories, each story being one unit in depth, and covered by a side-gable roof.Site #15 at 211 Vinton Street shows a 1-1/2 story I-House design. This example also features a one-story, rear wing.The house at 32 Vinton Street (Site #28) illustrates a two-story I-House. The impressive facade of this building is further emphasized by a one-story front porch,stretching across most of the facade. While this porch has been altered, the placement of such a porch element is typical of I-House design. In spite of its wide-spread popularity in the Midwest, the incidence of I-Houses in the study area is relatively low. One finds in Palo, for example, the following:

U ": _: A AA..~....3z9 It SIO a' LINa'e PUW-Us ale VA %1Lsm ,, I-u",UtLat 15 House 28 House 211 Vinton Street 32 Vinton Street Late 19th Century Late 19th Century 4. Pyramidal The following resources in the study area exhibit pyramidal roof plans: 2-27 #

Date Qf COOSl.t!.H<tjon 3B House 107-1/2 Vinton Street Unknown 13 House 207 Vinton Street After 1931 15 Hoose 211 Vinton Street Late 19th Century 20 Hoose 210 Vinton Street Late 1890s 24 House 302 Vinton Street 1930s or 19408 26 House 46 Vinton Street Late 1930s-early 19408 33 House 43 Main Street c. 1948 40 House 300 Main Street 1960s SO House J 00 Clinton Street c. 1868 The side-gabled fonn provided an early solution for both linear and massed designs. The one-story. brick example at 100 Clinton Street (Site #50) illustrates a linear ground plan, two units situated side-by-side fonning the facade. The example at 46 Vinton Street (Site #26) illustrates a massed design, each floor being two-units deep. The pitch of side-gables can vary dramatically and illustrate architectural influence. Site #50 has, for example, a rise over run approximately 4 in 12. The example at 43 Main Street (Site #33) features an approximately 8 over 12 rise over run, about twice as steep a pitch. The steep pitch of Site #33 points to Colonial Revival influences. The so-called I-House is an imponant sub-type of the side-gable shape in the Midwest. The I-House contains two stories, .each story being one unit in depth, and covered by a side-gable roof. Site # 15 at 211 Vinton Street shows a 1-1/2 story I-House design. This example also features a one-story, rear wing. The house at 32 Vinton Street (Site #28) illustrates a two-story I-House. The impressive facade of this building is fmther emphasized by a one-story front porch, stretching across most of the facade. While this porch has been altered, the placement of such a porch element is typical of I-House design. In spite of its wide-spread popularity in the Midwest, the incidence of I-Houses in the study area is relatively low. One finds in Palo, for example, the following: Site # Historic Name 15 Hoose 28 House 4. Pyramidal Ad<lress Date of COOStDlction 211 Vinton Street Late 19th Century 32 Vinton Street Late 19th Century The following resources in the study area exhibit pyramidal roof plans: 2-28 Sito.# Historic, Name.. Address Date of Construction 23 House 49 Vinton Street 1910-1925 35 House 101 Main Street Late IM90s 55 House 507 Main Street Early 1900s Covered with a hipped roof, the pyramidal shape provides a massed ground plan for either a one- or a two-story building. The floor plan usually consists of four units per floor, two units situated back-to-back to the other two. The roof is usually moderately steeply pitched, sometimes truncated with a deck rather than reaching an apex, although the latter is more frequent. The pyramidal shape provides an efficient design because a single roof covers theentire block. This design became more popular toward the end of the Nineteenth Century. American Four Square styled houses employ this basic shape, although one-story, cube cottages also belong to this type. They were widely employed as company housing in coal mining areas of Iowa, as in the White City section of Chariton.Site #23, at 49 Vinton Street, is a good example of a pyramidal cube cottage. The inset front porch, which stands on the northwest comer of the building, shows careful regard to the siting of the house. Located on the corner of Vinton and 1st Streets, this house is situated on one of the community's key vehicular intersections. The front porch is designed to give its occupants full view of both these streets, while it also provides the building with a strong physical presence when viewed from the street. Site #35, at 101 Main Street, is an example of a pyramidal cottage covered with a hipped roof truncated with a deck.The pyramidal cottage could be enlarged. Site #55 at 507 Main Street shows, for example, how such a house could accommodate a useable second story through the introduction of a dormer window. In this particular example, the house also features a porch on the facade. The porch is covered with an extension of the hipped roof of the main block. The dormer and porch combine to provide additional room to the cottage, as well as give the building added visual presence.The pyramidal shape also provided a useful design for small institutional buildings. The former Palo Town School, Site #48 on 1st Street, illustrates one such use.5. Compound The following resources in the study area exhibit compound roof plans.Site # Historic Name Address Date of Construction 14B House 200 Vinton Street c. 1900 16 House 204 Vinton Street c. 1900 37 House Main Street Late 19th CenturyThese examples, which mostly date from the late Nineteenth and early Twentieth Centuries, deviate from the simpler roof configurations more typical of architecture 2-28 # HiStQri!;; Nam!;< Ag dre ll5 O[ ConSt!llkUOO 23 House 49 Vinton Street 1910-1925 35 House 101 Main Street Late 18908 55 House 507 Main Street Early 19008 Covered with a hipped roof, the pyramidal shape provides a massed ground plan for either a one-or a two-story building. 'The floor plan usually consists of four units per floor, two units situated back-to-back to the other two. The roof is usually moderately steeply pitched, sometimes truncated with a deck rather than reaching an apex. although the Jatter is more frequent. . The pyramidal shape provides an efficient design because a single roof covers the entire block. This design became more popular toward the end of the Nineteenth Century. American Four Square styled houses employ this basic shape, although one-story, cube cottages also belong to this type. They were widely employed as company housing in coal mining areas of Iowa, as in the White CitY section of Chariton. Site #23, at 49 Vinton Street, is a good example of a pyramidal cube cottage. The inset front porch, which stands on the northwest corner of the building, shows careful regard to the siting of the house. Located on the comer of Vinton and 1 st Streets, this house is situated on one of the community's key vehicular intersections. The front porch is designed to give its occupants full view of both these streets, while it also provides the building with a strong physical presence when viewed from the street. Site #35, at 101 Main Street, is an example of a pyramidal cottage covered with a hipped roof truncated with a deck. The pyramidal cottage could be enlarged. Site #55 at 507 Main Street shows, for example, how such a house could accommodate a useable second story through the introduction of a dormer window. In this particular example, the house also features a porch on the facade. The porch is covered with an extension of the hipped roof of the main block. The dormer and porch combine to provide additional room to the cottage, as well as give the building added visual presence. The pyramidal shape also provided a useful design for small institutional buildings. The fonner Palo Town School, Site #48 on 1st Street, illustrates one such use. 5. Compound The following resources in the study area exhibit compound roof plans. Siw # Hilltoric Name Agdress Paw Of Coostrus:tion 14B House 200 Vinton Street c. 1900 16 House 204 Vinton Street c. 1900 37 Hoose Main Street Late 19th Century These examples, which mostly date from the late Nineteenth and early Twentieth Centuries, deviate from the simpler roof configurations more typical of architecture ,2-29 in Fayette Township. As such, they illustrate a certain financial capability during the Expansion Era in this area.6. Other Shapes Other buildings exhibit shapes other than the above described ones. Generally, these houses are more complex in their configuration, having irregular ground plans and compound roof systems. They also frequently exhibit a greater richness of architectural detail than those described above. For these reasons, such houses are classified as to stylistic influence and are discussed below.d. Stylistic Influences Architectural style, one category of significance under National Register Criterion C, embraces buildings and structures whose design and construction call attention to the evolution of design and how it manipulates building materials according to contemporary taste. This report uses vocabulary, typology, and periodization as developed in Virginia and Lee McAlester's A Field Guide to American Houses.The period between 1830 and 1890 saw the establishment of most towns and cities in Iowa- Much of the urban construction during the early years of this period was rough, impermanent, and constructed of locally produced building materials. The industrialization of the building materials industry, the invention of the balloon frame technique, and the arrival of railroads radically transformed construction in Iowa. By the post-Civil War era and certainly by the 1880s, buildings were much more likely to be built of imported materials and classified by contemporaries as "permanent." The number of buildings surviving from this early era in the study area is, nonetheless, limited.In the years between 1890 and 1930, more houses were built in the United States than in all earlier periods combined. Sometimes classified as "Post Victorian" or "Suburban," these houses call attention to a period of great confidence in the United States. Local statistics from Linn County confirm this national trend. In Cedar Rapids, for example, much of the city's buildings in 1940 were constructed between 1890 and 1930. Vinton (in nearby Benton County) experienced the same phenomenon. Although these statistics are unavailable for Palo, one might also expect a richness of examples calling attention to stylistic evolution during the late Expansion Era-By 1935, the Great Depression gripped the nation and curtailed much new home construction. New construction in Cedar Rapids between 1930 and 1940 amounted to little of the city's building stock. This also held true in Vinton. New home construction ceased during World War II. With the return of peace, a great post-war boom exploded across the nation. Tract developments, beyond town perimeters, became the standard, as did the ranch style house.Although no residential buildings in the study area appear architect-designed, a number of the major architectural styles popular in Iowa and the nation between circa 1840 and circa 1985 are represented, at least by influence, among the area's resources. What follows encapsulates brief descriptions of stylistic influences. The characteristics of these influences affected residential, commercial and institution, and, to a lesser extent, rural architecture. Sections IlI-B, Ill-C, and III-D of this report discuss the specific effects of these influences on resources in the study area.'2-29 in Fayette Township. As such, they illustrate a certain fmancial capability during the Expansion Era in this area. 6. OtherShapes Other buildings exhibit shapes other than the above described ones. Generally, these houses are more complex in their configuration, having irregular ground plans and compound roof systems. They also frequently exhibit a greater richness of architectural detail than those described above. For these reasons, such houses are classified as to stylistic influence and are discussed below. d. Stylistic Influences Architectural style, one category of significance under National Register Criterion C, embraces buildings and structures whose design and construction call attention to the evolution of design and how it manipulates building materials according to contemporary taste. This report uses vocabulary, typology, and periodization as developed in Virginia and Lee McAlester's A Field Guide to American Houses. The period between 1830 and 1890 saw the establishment of most towns and cities in Iowa. Much of the urban consnuction during the early years of this period was rough, impennanent, and constructed of locally produced building materials. The industrialization of the building materials industry, the invention of the balloon frame technique. and the anival of railroads radically transformed construction in Iowa. By the post-Civil War era and certainly by the 18808, buildings were much more likely to be built of imported materials and classified by contemporaries as "permanent II The number of buildings surviving from this early era in the study area is, nonetheless, limited. In the years between 1890 and 1930, more houses were built in the United States than in all earlier periods combined Sometimes classified as "Post Victorian" or "Suburban," these houses call attention to a period of great confidence in the United States. Local statistics from Linn County confinn this national trend. In Cedar Rapids, for example, much of the city's buildings in 1940 were constructed between 1890 and 1930. Vinton (in nearby Benton County) experienced the same phenomenon. Although these statistics are unavailable for Palo, one might also expect a richness of examples calling attention to stylistic evolution during the late Expansion Era. By 1935, the Great Depression gripped the nation and curtailed much new home construction. New construction in Cedar Rapids between 1930 and 1940 amounted to little of the city's building srock. This also held true in Vinton. New home construction ceased during World War II. With the return of peace, a great post-war boom exploded across the nation. Tract developments, beyond town perimeters. became the standanL as did the ranch style house. . Although no residential buildings in the study area appear architect-designed, a number of the major architectural styles popular in Iowa and the nation between circa 1840 and circa 1985 are represented, at least by influence, among the area's resources. What follows encapsulates brief deScriptions of stylistic influences. The characteristics of these influences affected residential, commercial and institution, and, to a lesser extent, rural architecture. Sections III-B, ill-C, and llI-D of this report discuss the specific effects of these influences on resources in the study area. 2-30 1. Greek Revival Greek Revival comprised one of the earliest architectural influences in the study area. In Fayette Township, the most prominent feature of this influence, as it affected local architecture, was the the gable front roof configuration (see Site #10).An asymmetrical configuration of bays on the facade is another influence of this taste.2. Italianate Italianate taste arrived in Linn County about the same time it became popular across the nation. Although it frequently comprises the earliest architecural influence in many Iowa communities, this is not so in Linn County because of its early settlement in comparison with other parts of Iowa. Italianate remained popular from the 1840s through the Civil War, and important residual influences remained on local construction into the 1890s. Italianate styling is generally one of the two most widely employed styles during the Nineteenth Century in Iowa (the other is Queen Anne). The importance of Italianate styling and its influence is suggested by the number of houses constructed in communities during the period when this style held sway.Also called the bracket style, Italianate taste often included asymmetrical floorplans, wide overhanging eaves with brackets, low-pitched roofs, and sometimes towers or cupolas. Although most Italianate residences in Iowa are frame, a number of brick examples were also constructed. Such brick examples often constitute the most prized historic homes in the area's communities. Since frame is, however, more physically fragile and readily altered than brick, expectations as to integrity need to be commensurate. The incidence of Italianate influence in the study area is somewhat modest.Although no one building clearly possesses high style characteristics, a certain number of vernacular houses from this period remain extant. Architectural details on these buildings are, of course, less elaborate than high style example. The McArthur Farmhouse (Rural Architectural Site #351) in Section 32 of Fayette Township provides a good example. Based on an ell-shaped ground plan and covered by a low-pitched, hipped roof, this house features such exterior detailing as a moderately wide cornice as well as comer boards with spiral quarter round.Restraint is, nonetheless, a hallmark of this house. Brackets, for example, are totally absent.Sometimes the main architectural influence on Italianate resources in the study area is the shape of roof and the ground plan. This can be seen in the house at 301 Main Street (Site #43) in Palo. Here the square-like ground plan and low-pitched hipped roof with deck evince the influence, which a later constructed wrap-around porch somewhat masks.3. Gothic Revival Characterized by steeply pitched roofs, faced with decorative vergeboards on the gables, and featuring Gothic pointed arched openings throughout, the Gothic Revival style was popular nationally between about I840 and 1880. It is found only in limited instances in Linn County.2-30 1. Greek Revival Greek Revival comprised one of the earliest architectural influences in the study area. In Payette Township, the most prominent feature of this influence, as it affected local architecture, was the the gable front roof configuration (see Site #10). An asymmetrical configuration of bays on the facade is another influence of this taste. 2. ltalianate Italianate taste arrived in Linn County about the same time it became popular across the nation. Although it frequently comprises the earliest an::hitectma1 influence in many Iowa communities. this is not so in Linn County because of its early settlement in comparison with other parts of Iowa. ltalianate remained popular from the 1840s through the Civil War, and important residual influences remained on local construction into the 1890s. ltalianate styling is generally one of the two most widely employed styles during the Nineteenth Century in Iowa (the other is Queen Anne). The importance of Italianate styling and its influence is suggested by the number of houses constructed in communities during the period when this style held sway. Also called the bracket style, ltalia,nate taste often included asymmetrical floorplans. wide overhanging eaves with brackets. low*pitched roofs, and sometimes towers or cupolas. Although most Italianate residences in Iowa are frame, a number of brick examples were also constructed. Such brick examples often constitute the most prized historic homes in the area's communities. Since frame is. however. more physically fragile and readily altered than brick. expectations as to integrity need 'to be commensurate. The incidence of Italianate influence in the study area is somewhat modest. Although no one building clearly possesses high style characteristics, a certain number of vernacular houses from this period remain extant. Architectural details on these buildings are, of course, less elaborate than high style example. The McAnhur Fannhouse (Rural Architectural Site #351) in Section 32 of Fayette Township provides a good example. Based on an ell-shaped ground plan and covered by a low-pitched, hipped roof, this house features such exterior detailing as a moderately wide cornice as well as comer boards with spiral quarter round. Restraint is, nonetheless" a hallmark of this house. Brackets, for example, are totally absent. Sometimes the main architectural influence on ltalianate resources in the study area is the shape of roof and the ground plan. This can be seen in the house at 301 Main Street (Site #43) in Palo. Here the square-like ground plan and low-pitched hipped roof with deck evince the influence, which a later constructed wrap-around porch somewhat masks. 3. Gothic Revival Characterized by steeply pitched roofs, faced with decorative vergeboards on the gables, and featuring Gothic pointed arched openings throughout, the Gothic Revival style was popular nationally between about 1840 and 1880. It is found only in limited instances in Linn County. 2-31The incidence of Gothic Revival is notable in Marion, early seat of government for Linn County, and more apparent here than in any other community in Linn County.The financial capability to erect homes of pretension, the local abilities to construct such buildings, and a familiarity with national tastes call attention to Marion's early position as a railroad point, as well as its success in industrial development. No examples; of Gothic Revival influence were identified in Fayette Township.

4. Second EmpireSecond Empire styling is infrequently encountered in Linn County. Also called the mansard style because of its fascination with the dual-'pitched hipped roof, this styleremained current during the 1870s. Isolated examples in Linn County were erected as showplaces.

None was identified in Fayette Township.5. Stick Style Popular nationally between circa 1860 and 1890, but especially in the Eastern United States, Stick style seeks to convey a picturesque feeling, achieved throughsteeply gabled roofs, half-timbering on walls, trusses on gables and dormers, and a variety of wooden cladding materials to render exterior walls decorative. Stick style influenced architecture in Linn County in limited instances and hardly at all in rural areas. Linn County was still a young society. Financially capable individuals still tended to erect fashionable residences influenced by Italianate taste (such as Site #43 at the southwest corner of Main and 3rd Streets in Palo). No examples of Stick Style were identified in the survey.6. Queen Anne Embracing the years between circa 1885 and circa 1910, Queen Anne is the second major architectural influence in the study area during the Nineteenth Century.Queen Anne designs strive for complex relationships of shapes, materials, and surface textures. The roof becomes a dominant architectural element, frequently composed of intersecting gables, steep pitches, and massive proportions. A wide range of cladding materials are found on exterior walls. Massing is arranged to produce a feeling of weight and substance. Queen Anne influenced houses are most readily identifiable when constructed on a large scale. Smaller-scale cottagesalso call attention to this design, but they are less frequently encountered. Queen Anne is predominantly worked in frame in Linn county, and brick examples are few. This is in contrast to Italianate styling where brick examples are relatively numerous. The Queen Anne influence is also encountered ubiquitously in Linn County without regard to urban, town, or country settings.Queen Anne taste stands at the apogee of architectural sophistication in Palo.During the decades between circa 1895 and 1915, when this styling influence held sway in the community, Palo experienced its apogee during the Expansion Era.Buildings constructed during this period reflect this financial capability. Houses, for example, express sophistication through a richness of architectural detail and a complexity of roof and porch design, unequalled before and since in the community. While Colonial Revival styling also held somec influence in Palo during this period (Site #45 at '401 Main Street provides a good example), it never achieved the wide-spread popularity of the Queen Anne taste.. 2-31 The incidence of Gothic Revival is notable in Marion, early seat of government for Linn County. and more apparent here than in any other community in Linn County. TIle financial capability to erect homes of pretension, the local abilities to construct such buildings. and a familiarity with national tastes call attention to Marion's early position as a railroad point, as well as its success in industrial development. No examples of Gothic Revival influence were identified in Fayette Township.

4. Second Empire Second Empire styling is infrequently encountered in County. Also called the mansard style because of its fascination with the dual-pitched hipped roof, this style remained current during the 1870s. Isolated examples in Linn County were erected as showplaces.

None was identified in Fayette Township.

5. Stick Style Popular nationally between circa 1860 and 1890, but especially in the Eastern United States. Stick style seeks to convey a picturesque feeling, achieved through steeply gabled roofs, half-timbering on walls, trusses on gables and donners, and a variety of wooden cladding materials to render exterior walls decorative.

Stick style influenced architecture in Linn County in limited instances and hardly at all in rural areas. Linn County was still a young society. Financially capable individuals still tended to erect fashionable residences influenced by ltalianate taste (such as Site #43 at the southwest comer of Main and 3rd Streets in Palo). No examples of Stick Style were identified in the survey. 6. Queen Anne Embracing the years between circa 1885 and circa 1910, Queen Anne is the second major architectural influence in the study area during the Nineteenth Century. Queen Anne designs strive for complex relationships of shapes, materials, and smface textures. The roof becomes a dominant architectural element, frequently composed of intersecting gables. steep pitches, and massive proportions. A wide range of cladding materials are found on exterior walls. Massing is arranged to produce a feeling of weight and substance. Queen Anne influenced houses are most readily identifiable when constructed on a large scale. Smaller-scale cottages also call attention to this design. but they are less encountered. Queen Anne is predominantly worked in frame in Linn county, and brick examples are few. This is in contrast to Italianate styling where brick examples are relatively numerous. The Queen Anne influence is also encountered ubiquitously in Linn County without regard to urban, town, or country settings. . Queen Anne taste stands at the apogee of architectural sophistication in Palo. During the decades between circa 1895 and 1915, when this styling influence held sway in the community, Palo experienced its apogee during the Expansion Era. Buildings constructed during this period reflect this fmancial capability. Houses, for example, express sophistication through a richness of architecnrral detail and a complexity of roof and porch design, unequalled before and since in the community. While Colonial Revival styling also held some influence in Palo dming this period (Site #45 at 401 Main Street provides a good example), it never achieved the wide-spread popularity of the Queen Anne taste. 2-32Palo possesses a series of one and one-half-story Queen Anne houses. Often gable-front and wing in form, several of these buildings retain their originalporches, which are located in the ell. These historic resources also contain a relatively high degree of architectural detail, with variations in cladding materials and complex roof designs. The house at 200 Vinton Street (Site #14B) is a particularly fine example. The house at the southeast corner of 1st and Clinton Streets (Site 4168) is the finest example in Palo and evaluated as individually eligible for nomination to the National Register for this reason.The House at 201 Vinton Street (Site #9) is another example. Here the main block consists of a gable-front. This design is enriched with a wrap-around porch.Situated on a corner lot, the wrap-around porch of this building effectively provides it with a double facade. The. building appears to face both Vinton Street and 2nd Street, giving the edifice added presence. The double facade is further emphasized by the gable-fronts on the shed-roofed porch, which stand above both porch entrances. Although the house at 119 Vinton Street (Site #7) also stands on a corner lot and possesses a wrap-around porch, the wrap-around porch in this example achieves a similar feeling of presence using a different technique. Here the wrap-around is boldly oriented toward one street--Vinton Street, historically the principal thoroughfare of Palo.Not all these houses in Palo remain pristine. The house at 108 Clinton Street (Site#52) shows how a Queen Anne design could be updated to reflect Craftsman styling.7. Colonial Revival Colonial Revival, popular between circa 1890 and 1915 in Linn County, comprises a number of variants, all featuring architectural elements and details influenced by colonial English and Dutch architecture as practiced on the eastern seaboard of the United States. Certain architectural details are singled out for special treatment by Colonial Revival styling. These include window and do~or openings, where classically inspired porticos are frequent, while cornices with dentils, also abound.Colonial Revival is found in many towns and cities in Linn County, but to a lesser extent than Queen Anne styling.Colonial Revival never achieved popularity in Fayette Township. In Palo, for example, only one house, Site #47 at 401 Main Street, exhibits a certain Colonial Revival feeling.8. American Four SquareThe American Four Square comprises a basic form rather than an architectural style.Characterized by a simple square ground plan, these buildings feature hipped roofs with at least one dormer window located on the facade. Usually a full-width, one-story porch is also situated on the facade. American Four Square houses can be constructed of wood frame, brick, concrete block, stucco, and tile block, although fr-ame examples clad in clapboard predominant in Linn County. The Four Square can feature eclectic details from several styles popular between circa 1890 and 1925. Rural Architectural Site #18 illustrates architectural elements influenced by the Prairie Style, for example. Although several American Four Square houses are , i. I " 2-32 Palo possesses a series of one and one-half-story Queen Anne houses. Often gable-front and wing in fonn, several of these buildings retain their original porches, which are located in the ell. These historic resources also contain a relatively high degree of architectural detail, with variations in cladding materials and complex roof designs. The house at 200 Vinton Street (Site #14B) is a particularly fine example. The house at the southeast comer of lst and Clinton Streets (Site #68) is the finest example in Palo and evaluated as individually eligible for nomination to the National Register for this reason. The House at 201 Vinton Street (Site #9) is another example. Here the main block consists of a gable-front. This design is enriched with a wrap-around porch. Situated on a corner lot, the wrap-around porch of this building effectively provides it with a double facade. The building appears to face both Vinton Street and 2nd Street, giving the edifice added presence. The double facade is further emphasized by the gable-fronts on the shed-roofed porch, which stand above both porch entrances. Although the house at 119 Vinton Street (Site #7) also stands on a corner lot and possesses a wrap-around porch, the wrap-around porch in this example achieves a similar feeling of presence using a different technique. Here the wrap-around is boldly oriented toward one street--Vinton Street, historically the principal thoroughfare of Palo. Not all these houses in Palo remain pristine. The house at 108 Clinton Street (Site #52) shows how a Queen Anne design could be updated to reflect Craftsman styling. 7. Colonial Revival Colonial Revival, popular between circa 1890 and 1915 in Linn County, comprises a number of variants. all fearuring architectural elements and details influenced by colonial English and Dutch architecture as practiced on the eastern seaboard of the United States. Cenain architectural details are singled out for special treatment by Colonial Revival styling. 11lese include window and door openings, where classically inspired porticos are frequent, while cornices with dentils also abound. Colonial Revival is found in many towns and cities in Linn County, but to a lesser extent than Queen Anne styling. Colonial Revival never achieved Popularity in Fayette Township. In Palo, for example, only one house, Site #47 at 401 Main Street. exhibits a certain Colonial Revival feeling. 8. American Four Square The American Four Square comprises a basic form rather than an architectural style. Characterized by a simple square ground plan, these buildings feature hipped roofs with at least one dormer window located on the facade. Usually a full-width, story porch is also situated on the facade. American Four Square houses can be constructed of wood frame, brick, concrete block, stucco, and tile block, although frame examples clad in clapboard predominant in Linn County. The Four Square can feature eclectic details from several styles popular between circa 1890 and 1925. Rural Architectural Site #18 illustrates architectural elements influenced by the Prairie Style, for example. Although several American Four Square houses are 2-33 situated in Palo, the incidence is low. Perhaps this design, which produces a large house, was not in harmony with the more modest residential needs of Palo and Fayette Township.9. Prairie During the first decade of the Twentieth Century, influences spread to Iowa from Chicago's emerging Prairie School of architecture. Characterized by low-pitched roofs, widely overhanging eaves, and emphasis on horizontal lines, these stylistic elements entered the architectural vocabulary of many Iowa communities, although to a limited degree. The influence does not appear to have extended much beyond the end of World War I.The incidence of Prairie School designs in the study area is restricted. While numerous examples can be found in Cedar Rapids--the style having attained popularity among the city's dlite--the Prairie influence is less evident in rural locations of Linn County.Notable in this regard is the farmhouse located on the northwest comer of Lewis Bottoms and Power Plant Roads (Rural Architectural Site #R4). American Four Square in form, the porch of this building distinguishes it from similar American Four Square designs. Brick piers supply support for the roof and these piers are enriched with cast concrete detailing.

10. Craftsman/Bungalow Inspired by California architects, Craftsman type houses received much publicity across the nation beginning about 1905. The one-story Craftsman influenced residence quickly became the most popular design in America. These resources are frequently referred to as bungalows.

The popularity of these buildings began to wane about 1930.Identifying features include low-pitched roofs with wide, overhanging eaves supported by decorated braces and exposed roof rafters, porches with roofs supported by large piers often slanted, and window configurations featuring multi-paned designs. Houses influenced by this style are legion in many Iowa communities. The historical designation of this property type is hindered by the richness of their numbers and the perception among some that these buildings are too new to be historic.Although the Craftsman influence was felt in Palo, buildings constructed under its sway never equalled the richness of architectural detailing achieved by those reflecting the Queen Anne taste in the community. Several examples can be cited in Palo. Site #43 at 43 Vinton Street illustrates a modest, Craftsman-influenced house. Site #57 at 601 Main Street represents a somewhat more complex example, employing, as it does, concrete block for the three columns supporting its front porch. Cast concrete also forms the capitals for these columns. These materials were almost certainly the products of John Livermore. The most exuberant example of Craftsman-influenced styling in Palo is certainly Site #60 at 808 2nd Street. Here fieldstone is employed to enrich the texture of its exterior walls.i iEi ., 2*33 situated in Palo, the incidence is low. Perhaps this design, which produces a large house, was not in hannony with the more modest residential needs of Palo and Fayette Township.

9. Prairie During the first decade of the Twentieth Century, influences spread to Iowa from Chicago's emerging Prairie School of architecture.

Characterized by low-pitched roofs, widely overhanging eaves, and emphasis on horizontal lines, these stylistic elements entered the architecrural vocabulary of many Iowa communities, although to a limited degree. The influence does not appear to have extended much beyond the end of World War I. The incidence of Prairie School designs in the study area is restricted. While numerous examples can be found in Cedar Rapids--the style having attained popularity among the city's elite--the Prairie influence is less evident in rural locations of Linn County. Notable in this regard is the farmhouse located on the nonhwest corner of Lewis Bottoms and Power Plant Roads (Rural Architectural Site #R4). American Four Square in form, the porch of this building distinguishes it from similar American Four Square designs. Brick piers supply support for the roof and these piers are enriched with cast concrete detailing.

10. Oaftsman/Bungalow Inspired by California architects, Craftsman type houses received much publicity across the nation beginning about 1905. 'The one-story Craftsman influenced residence quicldy became the most popular design in America. These resources are frequently referred to as bungalows.

The popularity of these buildings began to wane about 1930. Identifying features include low-pitched roofs with wide, overhanging eaves supported by decorated braces and exposed roof rafters, porches with roofs supported by large piers often slanted, and window configurations featuring paned designs. Houses influenced by this style are legion in many Iowa communities. The historical designation of this property type is hindered by the richness of their numbers and the perception among some that these buildings are too new to be historic. Although the Craftsman influence was felt in Palo, buildings constructed under its sway never equalled the richness of architectural detailing achieved by those reflecting the Queen Anne taste in the community. Several examples can be cited in Palo. Site #43 at 43 Vinton Street illustrates a modest, Craftsman-influenced house. Site #57 at 601 Main Street represents a somewhat more complex example. employing, as it does, concrete block for the three columns supporting its front porch. Cast concrete also forms the capitals for these columns. These materials were almost certainly the products of John Livennore. The most exuberant example of Craftsman-influenced styling in Palo is certainly Site #60 at 808 2nd Street Here fieldstone is employed to enrich the texture of its exterior walls. 2-34 11. Period Revivals Period Revival influences embrace a wide variety of buildings. Dating from circa 1915 to the 1930s, these resources include Tudor Revival and several Mediterranean Revival influences. Tudor Revival strongly influenced residential architecture in parts of Iowa. The number of residences influenced by this taste and erected in the emerging automobile suburbs is large. Other revival types, such as the Mediterranean, are much less numerous, and appear as isolated examples.Identifying features of Tudor Revival include steeply pitched roofs, half-timbered exterior walls usually in-fiilled with stucco, and use of stone trim for decoration.Examples occur in brick, clapboard, and stucco.The quality of building materials used in construction can provide important points for architectural significance. Many neighborhoods in Linn County, developed during the Consolidation Era, contain Tudor Revival buildings. They oftentimes occur as in-fill on lots that previously had remained vacant-Despite their popularity nationwide, however, no examples of Tudor Revival buildings were encountered in the study area.12. Neo-Colonial Revival Beginning in the late 1930s, buildings in the study area began to reflect national trends toward Neo-Colonial styling. Characteristics of residential Neo-Colonial styling include a concern for symmetry, side-gable roof configuration, small panedwindows, and other features of colonial American architecture, as well as the Colonial Revival movement of the 1890s and early Twentieth Century. The Cape Cod cottage became a hallmark of Neo-Colonial design. This taste remainedsomewhat popular following World War II, although the ranch house came to dominate new construction. Generally speaking, Neo-Colonial styling is not strongly represented in Linn County outside the major urban centers. Several examples were encountered in Palo, including the house at 43 Main Street (Site #33).2. Resources of John Livermore A carpenter by trade, John Livermore established a concrete block factory in Palo about 1908. By this time, concrete building products had achieved a wide-spread popularity throughout the United States. (See the section on concrete in the "Building Materials" portion of this chapter.)The establishment of Livermore's factory Palo provided property owners with a durable and inexpensive building material. In the succeeding years, this product was used on numerous occasions for both commercial and residential purposes, with concrete block used extensively for foundations. Livermore also had the capability to manufacture otherconcrete products, such as lintels, sills, column caps, and other small building elements.Items of street furniture, such as hitching posts and multi-purpose poles, were also produced by him. Although the source of his production equipment is not known, mail order catalogues from the period offered them for sale (see Figures 2-9, 2-10, 2-11, 2-12).The Livermore operation was a family business. John and "Jake" Livermore, his son,worked together as a team. John also worked as a contractor-builder. In 1908, for., i I 2. 2-34 11. Period. Revivals Period Revival influences embrace a wide variety of buildings. Dating from circa 1915 to the 1930s, these resources include Tudor Revival and several Mediterranean Revival influences. Tudor Revival strongly influenced residential architecture in parts of Iowa. The number of residences influenced by this taste and erected in the emerging automobile suburbs is large. Other revival types, such as the Mediterranean, are much less numerous, and appear as isolated examples. Identifying features of Tudor Revival include steeply pitched roofs, half-timbered exterior walls usually in-fIlled with stucco, and use of stone trim for decoration. Examples occur in brick, and stucco. The quality of building materials used in construction can provide important points for architectural significance. Many neighborhoods in Linn County, developed during the Consolidation Era, contain Tudor Revival buildings. They oftentimes occur as in-fill on lots that previously had remained vacant Despite their popularity nationwide, however, no examples of Tudor Revival builclings were encountered in the study area. 12. Nee-Colonial Revival Beginning in the late 1930s. buildings in the study area began to reflect national trends toward Nee-Colonial styling. Characteristics of residential Nee-Colonial styling include a concern for symmetry, side-gable roof configuration, small paned windows, and other features of colonial American architecture, as well as the Colonial Revival movement of the 1890s and early Twentieth Century. The Cape Cod cottage became a hallmark of Neo-Colonial design. This taste remained somewhat popular following World War II, although the ranch house came to dominate new construction. Generally speaking, Nee-Colonial styling is not strongly represented in Linn County outside the major urban centers. Several examples were encountered in Palo, including the house at 43 Main Street (Site #33). Resources of John Livermore A* carpenter by trade, John Livermore established a concrete block factory in Palo about 1908. By this time, concrete building products had achieved a wide-spread popularity throughout the United States. (See the section on concrete in the "Building Materials" ponion of this chapter.) The establishment of Livennore's factory Palo provided property owners with a durable and inexpensive building material. In the succeeding years, this product was used on mnnerous occasions for both commercial and residential prrrposes, with concrete block used extensively for foundations. Livermore also had the capability to manufacture other concrete products, such as lintels, sills, column caps, and other small building elements. Items of street furniture, such as hitching posts and multi-purpose poles, were also produced by him. Although the source of his production equipment is not known, mail order catalogues from the period offered them for sale (see Figures 2-9, 2-10,2-11,2-12). The Livermore operation was a family business. John and "Jake" Livermore, his son, worked together as a team. John also worked as a contractor-builder. In 1908, for 2-35 example, he and Jake constructed the W. C. Wright Grocery Store (Site #12 at 114 Vinton Street).The concrete products were produced from Livermore's factory, located at 607-1/2 2nd Street (Site #73B), directly south of the Livermore House (Site #73A). A counter shaft ran through the factory with large wooden pulleys made by him to handle the materials. The shaft was run by a one-cylinder, water cooled gas engine, which stood outside the factory.John also made the jigs for his concrete products.Livermore's manufacturing business operated about 18 years, from circa 1908 to circa 1926. John died about 1943. At that time, Ralph Livermore, another son, purchased the home property from John's estate. In the 1980s, Norma Livermore Wright, John's only daughter, acquired the property.Livermore was able to produce at least three different types of concrete block. Two of these were in standard size. One of them featured a rusticated face, while the other featured a smooth face. A third type, smaller in size, also had a smooth face. This variety enabled the contractor-builder to give textural interest to a new building. Livermore does not, however, seem to have had the capability (or desire) to produce polychromatic concrete block. While some contractor-builders (notably in Waverly, Iowa) employed colorful block to add further interest to their work, this was not true in Palo. Livermore's production also lacked a range of architectural detailing. His factory evidently did not manufacture quoins or other architectural elements, such as columns and balustrades. John Livermore made a lasting impact on the architecture of Palo. Long after his factory ceased operations, concrete block remained a viable and appealing building material in the community. Following World War II, for example, Edwin and Ivan Booth of Palo purchased a concrete block machine and produced the materials for their new concrete block house at 112 Main Street (Site #34). The Booths also retailed these products to their neighbors. Five or six resources are known to have basements of Booth block. Another concrete block house in Palo, located at 302 Vinton Street (Site #24) and constructed circa 1948, calls further attention to the continued local interest in this material and may be the product of the Booths. This is particularly notable because concrete block had, by this time, fallen from favor across the nation as an exterior wall material.3. Rurm Architectre The rural architecture of the project area in Fayette Township is dominated by Consolidation Era construction, although a few resources representative of the Early Settlement and Expansion Eras are extant. Associations with the residential architecture of Palo can be drawn in the countryside, while the agricultural outbuildings are unique in their configuration and type to the rural areas.The typology of roof shapes and stylistic influences defined in the previous sections for the residential resources of Palo also applies to the rural residential properties and includes the gable-front, gable-front-and wing, side-gabled, pyramidal, and compound roof shapes and Greek Revival, Italianate, Queen Anne, Colonial Revival, American Four Square, Prairie, Craftsman/Bungalow, and Neo-Colonial Revival stylistic influences. Added to this is one example of an early I-House, which exhibits Federal-style influence in its five-rank fenestration and central-hall plan. Of the 36 (two farmsteads have two houses each)recorded rural residential properties in the project area, 14 can be defined as having a pyramidal or hipped roof type including both pyramidal and truncated hip types; 12 have side-gabled roofs; 5 have gable-front-and wing shapes; 3 are front-gabled, and I has a compound roof shape. Stylistic influences discernible include 5 American Four-Square; 4 2-35 example, he and Jake constructed the W. C. Wright Grocery Store (Site #12 at 114 Vinton Street). The concrete products were produced from Livermore's factory, located at 6(J7 -1/2 2nd. Street (Site #73B), directly south of the Livermore House (Site #73A). A counter shaft ran through the factory with large wooden pulleys made by him to handle the materials. The shaft was run by a water cooled gas engine, which stood outside the factory. John also made the jigs for his concrete products. Livermore's manufacturing business operated about 18 years, from circa 1908 to circa 1926. John died about 1943. At that time, Ralph Livennore, another son, pW'Chased the home propeny from John's estate. In the 19808, Norma Livermore Wright, John's only daughter, acquired the property. Livermore was able to produce at least three different types of concrete block. Two of these were in standard size. One of them featured a rusticated face, while the other featured a smooth face. A third type, smaller in size, also had a smooth face. This variety enabled the contractor-builder to give textural interest to a new building. Livermore does not, however, seem to have had the capability (or desire) to produce polychromatic concrete block:. While some contractor-builders (notably in Waverly, Iowa) employed colorful block to add further interest to their work, this was not true in Palo. Livermore's production also lacked a range of architectural detailing. His factory evidently did not manufacture quoins or other architectural elements, such as columns and balustrades. John Livermore made a lasting impact on the architecture of Palo. Long after his factory ceased operations, concrete block remained a viable and appealing building material in the community. Following World War n, for example, Edwin and Ivan Booth of Palo purchased a concrete block machine and produced the materials for their new concrete block house at 112 Main Street (Site #34). The Booths also retailed these products to their neighbors. Five or six resources are known to have basements of Booth block. Another concrete block house in Palo, located at 302 Vinton Street (Site #24) and constructed circa 1948, calls funher attention to the continued local interest in this material and may be the product of the Booths. This is particularly notable because concrete block had, by this time, fallen from favor across the nation as an exterior wall material.

3. Rural Architecture The rural architecture of the project area in Fayette Township is dominated by Consolidation Era construction, although a few resources representative of the Early Settlement and Expansion Eras are extant. Associations with the residential architecture of Palo can be drawn in the countryside, while the agricultma1 outbuildings are unique in their configuration and type to the rural areas. The typology ofmof shapes and stylistic influences defined in the previous sections for the residential resources of Palo also applies to the rural residential properties and includes the gable-front, gable-front-and wing, side-gabled, pyramidal, and compound roof shapes and Greek Revival, ltaJianate, Queen Anne, Colonial Revival, American Four Square, Prairie, Craftsman/Bungalow, and NecrColonial Revival stylistic influences.

Added to this is one example of an early I-House. which exhibits Federal-style influence in its five-rank fenestration and central-hall plan. Of the 36 (two farmsteads have two houses each) recorded rural residential properties in the project area. 14 can be defined as having a pyramidal or hipped roof type including both pyramidal and truncated hip types; 12 have side-gabled roofs; 5 have gable-front-and wing shapes; 3 are front-gabled, and 1 has a compound roof shape. Stylistic influences discernible include 5 American Four-Square; 4 2-36 Italianate; 3 Bungalow; 2 Neo-Colonial Revival; 1 Federal; and 1 Colonial Revival influenced property. The remainder of the residential resources exhibit little or no stylistic influences and reflect common vernacular gabled farmhouse types. Residential building materials are predominated by frame construction with masonry foundations. The latter consist primarily of poured concrete, concrete block, or tile block construction, with the older Early Settlement Era and Expansion Era homes having limestone foundations. Both of the Neo-Colonial Revival styled houses are of brick construction with concrete or block foundation/basements. Roofing materials are almost exclusively asphalt shingled, although some original. wood shingled roofs are likely masked by later applications of asphalt shingles.The agricultural outbuildings in the rural area of Fayette Township are defined by function, form, and building materials. Functions include barns, other livestock shelters, granaries,silos, and cribs for storage, machine sheds, automobile garages, domestic support structures, and food processing structures such as milk houses. Privies are notably scarceon the Fayette Township rural landscape as extant structures. Of the agricultural outbuildings, the barn is the primary support building and dominates the landscape of the area's farmsteads. Barn forms present in the study area include general purpose gable (n= 9) and gambrel (n= 12) roofed types, three-bay gabled (n= 6) and shed-monitor gabled (n= I) feeder barns, and gothic arched (n= I) dairy barns as defined by Soike (1989:167). The general purpose gabled barns date from the Early Settlement and Expansion eras (1839-early 1900s), while the gambrel-roofed general purpose barns date from the Expansion and early Consolidation eras (1880s-1920s). The latter have a light frame dimension plank lumber or balloon frame type of construction, while the former are commonly heavy timber frame in construction. The three-bay feeder barns generally date from the 1890s-1920s, with the shed-monitor type dating primarily from the early twentieth century. Hay was stored in the center of these structures with feeding stalls housed within the surrounding shed which commonly wraps around the taller central portion in a U shape. The Gothic arched barn type is relatively modem in construction becoming common in the 1940s. This type of barn is "constructed of factory-made, flue-laminated,self-supporting arches" (Soike 1989:167) and was the forerunner of the modem prefabricated metal buildings which began to dominate Iowa farmsteads in the late Twentieth Century. With the changing farmstead in the Twentieth Century, the need for conventional barns has been replaced with feedlots, cattle and hog sheds, and metal machine sheds. As a result, many of the historic barns in the project area are currentlyunused except for storage, while others are underused relative to their size and interior space. A significant number have been razed.Building materials used in barn construction in Fayette Township are predomi-nat bywood and concrete, with the superstructure of most barns being of lumber and the foundations and floors of poured concrete. Only the earlier gable-roofed general purpose barns have limestone foundations despite the abundance of this building material in the township. Clay tile block was also of limited use in the township, with cement being thepreferred foundation material for barns and other outbuildings. Several concrete block outbuildings are present, although the vast majority are of frame construction with some all-metal and metal-sided buildings present as well. Of the frame buildings, the use of vertical board-and-batten, horizontal drop siding, and horizontal carboard siding prevail.Roofing material is presently typified by steel sheet roofing, although wood shingled andasphalt shingled examples were noted.One notable agricultural structure which stands out on the rural landscape in the project area is the silo. Of the 13 silos present on recorded farmsteads, 7 are of concrete construction

" '" f . " 2-36 Italianate; 3 Bungalow; 2 Neo-Colonial Revival; 1 Federal; and 1 Colonial Revival influenced property.

TIle remainder of the residential resources exhibit little or no stylistic influences and reflect common vernacular gabled fannhouse types. Residential building materials are predominated by frame construction with masonry foundations. The latter consist primarily of poured concrete, concrete block, or tile block construction, with the older Early Settlement Era and Expansion Era homes having limestone foundations. Both of the Nco-Colonial Revival styled houses are of brick construction with concrete or block foundationlbasements. Roofing materials are almost exclusively asphalt shingled, although some original, wood shingled roofs are likely masked by later applications of asphalt shingles. The agricultural outbuildings in the rural area of Fayette Township are defmed by function, fonn, and building materials. Functions include bams, other livestock shelters. granaries, silos, and cribs for storage, machine sheds, automobile garages, domestic support structures, and food processing structures such as milk houses. Privies are notably scarce on the Fayette Township rural landscape as extant structures. Of the agricultural outbuildings, the barn is the primary support building and dominates the landscape of the area's fannsteads. Barn fonns present in the study area include general purpose gable (n= 9) and gambrel (n= 12) roofed types. three-bay gabled (n= 6) and shed-, monitor gabled (n= 1) feeder barns, and gothic arched (n= 1) dairy barns as defined by Soike (1989: 167). The general purpose gabled barns date from the Early Settlement and Expansion eras (1839-early 1900s), while the gambrel-roofed general purpose barns date from the Expansion and early Consolidation eras (1880s-1920s). The latter have a light frame dimension plank lumber or balloon frame type of construction, while the fanner are commonly heavy timber frame in construction. The three-bay feeder bams generally date from the 1890s-1920s, with the shed-monitor type dating primarily from the early twentieth century. Hay was stored in the center of these structures with feeding stalls housed within the surrounding shed which commonly wraps around the taller central portion in aU shape. The Gothic arched barn type is relatively modern in construction becoming common in the 1940s. This type of barn is "constructed of factory-made, flue-laminated, self-supporting arches" (Soike 1989: 167) and was the forerunner of the modem prefabricated metal buildings which began to dominate Iowa fannsteads in the late Twentieth Century. With the changing fannstead in the Twentieth Century, the need for conventional barns has been replaced with feedlots, cattle and hog sheds, and metal machine sheds. As a result, many of the historic barns in the project area are currently unused except for storage, while others are underused relative to their size and interior space. A significant number have been razed. Building materials used in bam construction in Fayette Township are predominated by wood and concrete, with the superstructure of most barns being of lumber and the foundations and floors of poured concrete. Only the earlier gable-roofed general purpose barns have limestone foundations despite the abundance of this building material in the township. Clay tile block was also of limited use in the township, with cement being the preferred foundation material for barns and other outbuildings. Several concrete block outbuildings are present, although the vast majority are of frame construction with some all-metal and metal-sided buildings present as well. Of the frame buildings, the use of vertical board-and-batten. horizontal drop siding, and horizontal carboard siding prevail. Roofing material is presently typified by steel sheet roofing, although wood shingled and asphalt shingled examples were noted. One notable agricultural structure which stands out on the rural landscape in the project area is the silo. Of the 13 silos present on recorded fannsteads, 7 are of concrete construction 2-37 with rounded metal roofs, 4 are of Harvestore glass-fused to steel construction, and two are of plain steel construction. The Harvestore silos date from 1955-1980, while the concrete silos have a temporal range of 1910-1970s (Soike 1989:170). Windbreaks of pines and cedars are present around most farmsteads and commonly placed on the north and west sides to protect from the prevailing winter winds. The siting of the farmsteads sometimes offered shelter from the winds as well, with upland farmsteads often sited on slight hillslopes or up against steeper slopes. The topography of the project area also dictated the siting and configuration of farmsteads as well as playing a determining role in the type of agriculture practiced on particular farmsteads. Two general siting types were noted including upland ridgetop/sideslope farmsteads and level bottomland terrace and benchtop farmsteads. The latter could have a greater emphasis on row crop production in addition to livestock raising and dairying, while the upland farmsteads were confined more to livestock and dairy production. Of the 34 farmsteads recorded, 12 were in upland locations and 22 were in level bottornland locations. The siting of the farmstead also affected the size and layout of the farmstead, with the upland farmsteads more restricted by the landscape to compact or linear layouts and the bottomland farmsteads more able to spread out and approximate more square or rectangular layout configurations. As noted in the archaeological section, ethnicity does not appear to have played much of a role in the development or settlement of the rural agricultural community nor is there astrong ethnic influence to the building construction. The only potential "ethnic"-influenced property may have been the Railsback barn (Rural Architectural Site #37), which is a heavy timber frame "Pennsylvania"-type banked barn with a cantilevered forebay that has a German or Bavarian/Swiss immigrant association and was built on the Sweitzer Plan (Janik 1990; Rawson 1990). The Railsback family, for whom this building was constructed in the late 1850s, hailed from Indiana and Ohio (1870 United States Population Census). The other known former example of a Pennsylvania type barn in the project area was built for the McClintock family at about the same time. The McClintocks also hailed from Ohio (Brewer and Wick 1911:164), and the presence of this type of barn may reflect the regional background of these families more so than their ethnic background. The rural architecture of the project area also includes rural school buildings (all since moved and converted into agricultural outbuildings) and rural cemeteries, both representative of designed historic landscapes. As noted in the archaeological section of this report, the rural school buildings in use during the Expansion and Consolidation Eras.included the Lewis Bottoms Double Decker school (destroyed by Pleasant Creek Reservoir), the Round Prairie School (extant), the Goose Hill School (non-extant), the Dry Creek School (extant but moved), and the Bear Creek School (extant but moved). Except for the Lewis Bottoms school, these were one-story gabled buildings of frame construction, although the Goose Hill school was a brick building.Interestingly, none of the four cemeteries in the project area were associated with churches.Rather, the majority appeared to have begun as family burying grounds, such as the Strawn Cemetery and the Pleasant Ridge Cemetery (also known as the Lewis Bottoms cemetery). This type of rural cemetery reflects the strong role that extended family settlement played in settlement pattern of the township. The cemeteries reflect these Early Settlement Era family"neighborhoods" in their composition and distribution across the landscape, with the Strawn Cemetery containing the graves of the Strawn, Penrose, McClintock, Railsback,and Rife families; the Pleasant Ridge Cemetery the graves of the Lewis extended family;and the Old Palo Cemetery the graves of the Mills, Cue, and McManus families. All of the cemeteries exhibit a north-south orientation to the rows of graves, with markers generally facing west, although a few exceptions are present in the older cemeteries. Marker types are commonly of granite and limestone, with three of the cemeteries also having "white.. ) ; I : i 2-37 with rounded metal roofs, 4 are of Harvestore glass-fused to steel construction, and two are of plain steel construction. The Harvestore silos date from 1955-1980, while the concrete silos have a temporal range of 191O-1970s (Soike 1989:170). Windbreaks of pines and cedars are present around most fannsteads and commonly placed on the north and west sides to protect from the prevailing winter winds. The siting of the farmsteads sometimes offered shelter from the winds as well, with upland farmsteads often sited on slight hillslopes or up against steeper slopes. The topography of the project area also dictated the siting and configuration of fannsteads as well as playing a detennining role in the type of agriculture practiced on particular farmsteads. Two general siting types were noted including upland ridgetop/sideslope fannsteads and level bottomland terrace and benchtop farmsteads. The latter could have a greater emphasis on row crop production in addition to livestock raising and dairying. while the upland farmsteads were confined more to livestock and dairy production. Of the 34 farmsteads recorded, 12 were in upland locations and 22 were in level bottomland locations. The siting of the fannstead also affected the size and layout of the fannstead. with the upland fannsteads more restricted by the landscape to compact or linear layouts and the bottomland fannsteads more able to spread out and approximate more square or rectangular layout configurations. As noted in the archaeological section, ethnicity does not appear to have played much of a role in the development or settlement of the rural agricultural community nor is there a strong ethnic influence to the building construction. The only potential "ethnic"-influenced property may have been the Railsback barn (Rural Architectural Site #37), which is a heavy timber frame "Pennsylvania"-type banked bam with a cantilevered forebay that has a German or Bavarian/Swiss immigrant association and was built on the Sweitzer Plan (Janik 1990; Rawson 1990). The Railsback family, for whom this building was constructed in the late 1850s, hailed from Indiana and Ohio (1870 United States Population Census). The other known fonner example of a Pennsylvania type bam in the project area was built for the McClintock family at about the same time. The McClintocks also hailed from Ohio (Brewer and Wick 1911: 164), and the presence of this type of bam may reflect the regional background of these families more so than their ethnic background. The rural architecture of the project area also includes rural school buildings (all since moved and converted into agricultural outbuildings) and rural cemeteries, both representative of designed historic landscapes. As noted in the archaeological section of this report, the rural school buildings in use during the Expansion and Consolidation Eras. included the Lewis Bottoms Double Decker school (destroyed by Pleasant Creek Reservoir), the Round Prairie School (extant), the Goose Hill School (non-extant), the Dry Creek School (extant but moved), and the Bear Creek School (extant but moved). Except for the Lewis Bottoms school, these were one-story gabled buildings of frame construction, although the Goose Hill school was a brick building. Interestingly, none of the four cemeteries in the project area were associated with churches. Rather, the majority appeared to have begun as family burying grounds, such as the Strawn Cemetery and the Pleasant Ridge Cemetery (also known as the Lewis Bottoms cemetery). This type of rural cemetery reflects the strong role that extended family settlement played in settlement pattern of the township. The cemeteries reflect these Early Settlement Era family "neighborhoods" in their composition and distribution across the landscape, with the Strawn Cemetery containing the graves of the Strawn, Penrose, McClintock, Railsback, and Rife families; the Pleasant Ridge Cemetery the graves of the Lewis extended family; and the Old Palo Cemetery the graves of the Mills, Cue, and McManus families. All of the cemeteries exhibit a north-south orientation to the rows of graves, with markers generally facing west, although a few exceptions are present in the older cemeteries. Marker types are commonly of granite and limestone, with three of the cemeteries also having "white 2-38 bronze" markers manufactured in Des Moines and the fourth (i.e., the Strawn Cenetery)having several gravesites delineated by concrete grave frames.V co." i l r 2-38 bronze" markers manufactured in Des Moines and the fourth (i.e., the Strawn CemeteIy) having several gravesites delineated by concrete grave frames. 2-39 N .&A TS I'r r", i elf... ' J V_Z,..w;. ,: ~ .- .." ... ... ..' ..'" .F -' ; ... , .... A , ' ...;, ,,,-t " .. ..FIGURE 2-1 1859 MAP OF FAYETTE TOWNSHIP (From McWilliams Thompson 1859)1 I ... , . , !-c-'" .., . .., '" , <-, -; UI 2-39 ...

• I',\IU",w, ,r FIGURE 2 .. 1 1859 MAP OF FAYETTE TOWNSHIP (From McWilliams and Thompson 1859)

...... r.., 7 A'i "jeD r ..... ..,..,.FIGURE 2-2 1869 MAP OF FAYETTE TOWNSHIP (From Thompson and Everts 1869)2-40 FIGURE 2 .. 2 1869 MAP OF FA VETTE TOWNSHIP (From Thompson and Everts 1869) 2-41.......__ _____'o-:..j> I A.'WCF &R N= " Wa o. Cad, Pal, adh]rhc BC. & ' &uriNto(1Cd87Ra-d73an),rt.cs C47 & NC(191n-14W.. CRNDC CPda Raisad oaC S DR 1 0a (yanD FG2D & SWN (1186-- 6 LOWCAN R &D C A1987d=C ~~~ ~ ý 1 NW(81-z2" NW(89 DC & SW (1861-64)0 (1 65CS & D= (18into 2ea ais dNrr-C1 & 879Cicg ndNrh ~-CRANDANC C1d 1914s )"Iwa., FCUR &- NW 86o -6 3 % 7 C&,9 (85 I & sW= -'0xu a] otw l.LOATO R"A DALOD IN (190 1OUT02c;:',)i' CA&NW= Chicago, Aamn~zd Northerntc 2-41 FIGURE 2 .. 3 LOCATION OF RAILROADS IN LINN COUNTY llCR &. 1-1= Burlington, Ccd", RApids, and Northcrr WCF &. 1-1= W.terloo, Ccd.,. Falb, and Northern BCR &. N= Burlington. Ccdar R opids, and CM &. SIP" Chicaso, Milw,ukee, and Sl raul C &. NW= Chic.go and N(')l'th Western CRANDJC= Ccd", RApids ""d Jo"" City SA & D= Sabula, Ackley, Md Da.l:ota D &. SW= DuboJqllC and Soulhw""tem lC= lllinoi. Central CAN= Chicago, Anamosa. and Nonhem tKo INO FIGURE 2-4 1906 PLAT OF PALO (From Iowa Publishing Company 1907)FIGURE 1906 PLAT OF PALO (From Iowa Publishing Company 1907) N I J:>, N 2-43 t, I' tý v15 Ez t-tt it~_1 It __ 313 4 7 TJs P~~(KitI tTo lb 15 15 tb % w~LZ m 7 :ttat i.J FIGURE 2=5 LOCATION OF ROADWAYS IN LINN COUNTY BY 1914 (From Wingert and Lxzfers 1914)""j I 2-43 FIGURE 2 ... 5 LOCATION OF ROADWAYS IN LINN COUNTY BY 1914 (From Wingert and Leefers 1914) 2-44 I 0' 'CLINTON '..5T 0 El L VINTO1M-,___ 7 L -, i L LZ FIGU-a 2-6.': i 00 4 !7 FIGuRE 26 1931 SANBORN FnMF INSURANCE MAP o '" r I-$ o [J o * . -, o o . . ( ." D ill .,' , r;1 G \ r a z: a v hJ of) 2-44 I" I* e 10,' .t,' 4" I.. * .. *.* ** #,.. ... -CLINTON ...s To . . .... -........ ,. ........................... . ! l.!J u-, < MAIN \-.------'!---ST. o iy FJouRE2-6 .. " e . .. *.* , .' o -...... I { 1--Vl , I LQ < 1 < I I L_ ,LL .... ", .. r ,., .. .. /:: .. -: .. " .... , '" 1931 SANBORN FIRE INSURANCE MAP .-,.. ......... .. , ............ JJ 0 r.: t : , ; '. -I . , 2-45 U)1!! I ~ 17 LINN 'COUNTY P.LAN, AND PROFILE OF PROPOSED DIPROVEMEN'T COlJNry R,3Af) MCA 14 FROM RENTON COUN¶'Y LINETHRUld PALO(tAN]) C-OVINCTON' TO CED)AR RAPII)S (CLESPLAN I INC:H -100 FT.PR()r(LC-HCUe I INC.1 jCOFT-Vrj~, J INLt, ie-w r 2 z U ,7" I7 :t:. /...I.N x.LAYOUT FIGURE 2-7'0 ' -*** ,I.,. 17 , I, i i : _ , ,e,(!-.y. I\. "1, ;t '. I ');--.-.T' \:,\, ,I'* ! I* .,.-'" i:1 ie ! .......... . ! !:-::1 / :.' ... -:.: .. .;:.::. . ..:": -LAYOUT 2-45 I JNN . COllNTY COUN1'Y ROAD --=CIl1Il1i_a G C01lN ry R. 'M) Nr, r 4 COlWfY U':\E 'fIIRU P '\lA) AN)) COViN(;TON TO ('J.::IHR RAPIDS . liNCH 100 FT. . SCAlES PR0"ILC'HL'U. J INc.H N ) I -r I I FIGURE 2-7 Nsf.ýc 19y ,r ,Ac 0 0 0 7rd7/ kI6 w/14 is0rl 6. 73 7k 14- L f.T W e' tr&.. ~,3..J4 C*~'CS). 4)5 r 4 .S.5 --.5* '4 I CLA.rvnrCO '5.-n* *1- "4 Cw.os Or-.i ,,-,- -'4 \. \'4 az~ -e 3 0 ze tnrrrr ,.~ ~C.,. Si. .x~r 73 0TOW or FA~L) O~17 tiI Swe9 ~SecA, Oc' m 74 .CQ HIGH WAY PLANNING MAP ~~W o o S=19 k'br:s ;<Y PI ";:?.-.JJd o Sec .30 s"c e9 o ru LJ-(l /0 ! o N o o 0 N 'J rAy*rTl: TbdN ,"",OW MY'Er.rr, TJ'YP TMi/p(':V'-: Of PAl.() o FIGURE 2-8 HIGHWA Y PLANNING MAP "-"=-y . J;;O;$;o,'PI . or SID (}.j",j/?

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q --"l\ _ .. , ... ;,....a..... 14 IS. 73 1 ,"'4 dJ<>:r. ctJt:* .. **'-'!1 CP .., -.1') . I'Al /Z79 -:-.-:- 2-47`5 74 SEARS, ROEBUCK & CO., CHICAGO, ILL. CATALOGUE No. 117.OUR CONCRETE BLOCK MACHINES ARE THE BEST IN THE WORLD.THEY WILL MAKE MORE BLOCKS PER DAY THAN ANY OTHER MACHINES, THEY WILL MAKE BETTER PROPORTIONED AND BETTER FINISHED BLOCKS THAN ANY OTHER MACHINES AND THEY WILL MAKE MORE MONEY FOR YOU. OUR PRICES ARE LESS THAN ONE-HALF THE PRICES ASKED FOR OTHER MACHINES NOT HALF SO GOOD AS OUR MACHINES.THERE IS BIG PROFIT IN MAKING CONCRETE BUILDING BLOCKS.THIS REMARKABLY PROFITABLE BUSINESS M,," de'ipedd 1r the past few years u [tit now It is one of the leading Industries or the country. It is of groat interest to the property owner because concrete buiding bloks oae better and chieaper than either lumber, brick or stone, and by their usa his builirigs can be erected cheaper, better and more artiseic in design than with other building materisi at the same time insuring warmth in winter, cool-ness In summer, more substantifi construction and protection against fire. It is beneficial to tile contractor end butlder because of the cheapness of concrete bui dlng blocks compared with other building materials and because of its adapt-ability to all building purposes. It is a boon to tire village lumber and building rmateril-dealer because it enables him to build up his business by adding concrete products to his line with most satisfactory profits to himself and with still greater profits it lie makes blocks to sell in his own Yards. He can purchase either a simple or a very complete outfit from us at wonderfully low prices.who have rXY-Oel FARMERS AND SMALL LAND OWNERS banks o. lair the ones who can reap the grealtest benefits and mzke the In the ute o btidtng block machines, because, ask cement used, which is only about one-fillh of tre wiloe, their material lutely nothing, while they can sell the blocks for as much as the man peltcd to buy his sand and gravel. The farmer can employ men to crete blocks all the time and with big profit to himself, or ris help cr blocks on rainry days and at other idle periods, or he can make the if lie employs no help. He can build his own house, his barns and buildings all with material of his own making,. and ite can sell iris Surp at a large profit. A modest concrete block making outfit of our ma very little and every farmer who can use one to advantage should in making the investment. The saving you would make on one bu wotrld more than pay for a good outfit, aside from the profit you wot selling theoblocks. WE PUBLISH A SPECIAL CONCRETE BUILDING SLOCK'MACH I NwERY CATALO ch Will be sent tree to enyonen cwhno will write and MACHNERYCATA OGUE,,k or it. T~lls saleasble hook ootlsa ,arrge and hralldso"ne IliuArttland or elr Complete 110ee Of g ultlt e ta chneory. tho hiest grade 5al vary best ceroet block machslaeI ,eer produced. It ahowa the machloe cotplete and n e nd compltei dccrlptlos of everything. It expiates to too Vrhy o or taselhlnm ore beter. loalster and mere Petrect flion snos Other miahnes and scales the Machines at prices below airll copetitio. Thins bit ftr hbook e ve .. a orld of tato..otlon ir~rt -S shebout tile concrete lodestry snd tire past end present uses of concrete-I ite various terms. ItIontrle linstratlons o1 the prgoroswales I 1 i.--- mcan he made n-a our Machinecry AS well as pletures or h1.e.uolt es-t.ot-tge homes, etc.. hichIc can be built from these products. It ii ,-elves maoy rosoen why concrete Is so error to all Other bulkdl ma.terlal.. i treats at lenth Upon e concrete bauldiog Stock hnbrtech of nduustry. Ito which toe rarmer. toe vllbag b.Urdineg I .0 ca , the small contracthr or 5ildero and the ordInary property owner Is most ithoes5d. 50 tells Yoe wht cement Is tia~de or. wh, t kind or cement and nther nttealtl to use Lor ditfferent pur-poses, hta t,, proportion tnd mix the ce.ent sod o m1er material for suacessful concrete block wore., Sah to make the blocts. hOW to color the face seta or els Sek.otCdsod rw much cotoring to use, how om'ond uar the oeeIelDc how to mix the mortar r to aylo tre blocks.10 to lo plasr directly 00 thehntois. hbo to epi ly pebhle dash or any other fisleh aod row to waterpr~ o tee hlochs. ts[.Aet, this free bnh)k tells sOU nl sbout concrete Clock Making. snd how to secure rho bent ,e.UaiS rsnd tile prolts by usOn Our tow pried,higlt trade, up to the .moute conCrete block moshhres.CONCRETE IS A BUILDING MATERIAL nedetof ..... e, sed let vec cAtied agcrregles, and dampened with water. The cggroeates may consist or either sand.gravel or erilired s10ne, or allot toIr es4 hombined, the proportions o0 the cement and the sg-Cerrslt's allr Ibh, amoIrrt of water used being regulated by the tequired. strengett of the con-Crete product, the by whlih the mixture ts made late form.s and the masuer la wbhic It Is 10 lie ousti. There arn two methods o0 matieg Concrete. One Is keown as the wet proc-ess. wig r !!:r tite nriatre to maria Wet easoes sothat It can be poulred Into a speclilly ore-paired Iorrr, ii wrlrh it rcrfrrilm urttl it Irths set and lardeneod. Tile other Is toeen as tile dry irrrrI, rrlich thr mrxtlrree ts dsmrerrrd only enough to couse the cement and the ag-grogr'sIs to direrv Oi' crI- liriltoer under ollght pressure so tMit %oics the mixture is tamped hlitO a '1rrcrille lriheolil ire 4la4it cr ran be .rermroved as soe it ts Made Into the desired form sind st, to iore rlda to dry arid GROUTING, WHICH IS THE WET PROCESS MIXTURE, r be.torrarnre of yeas. 'Ii has'ren dietrmined thai Ire pyrarenid of Erypt iore oade oby trio tito T. ba rerrv' ',r it rre rbtilding,,4 n itaore ovoi rare beeSn Usir 'rr'over 1. 40 sMer: i "rr..i ,r r:rrrl rire, are utaihs ear ,rirrs rr1:hi iwere bails of otil ma tertaL rlrir ' < )[ If T rtlr roth [rr,-rurt Ira l IhAl onerete Is tile most dOtrabhr' 'SI roll n.Uilding Tiir. "l'rri 'leim4l arted .rrveeoer~rr ni rt il arOlelcd tIlls rlrterial aru nbIrliaceextrosive Irrri "rrir'rio rreri' Cli

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hrr rsrtva rare, air.. :55 tireerr rare-r:nii. rrrcerra dril .rri clr 10 h iii hl dire "rOn'. trer. e;rrers and lii Le ,i rierrr dcocriirir,h 'Tire ti'er irroccs to rot rteiir.l'alr' tired secant hater, trio "iaal 1,iir' ttl Orlirrori' r, oi liraitioriis iririet rrari ist Outr i -irclir 1 500cro, ! r re iri. era, t"ri rilihe titnsrrs Slid at,,, b cust Inc:,peal -for el t ery I'r IL 0 tile r'-- Il ""Iut~r h, heovnh n[machines. for marinebzllll blocks ace" i eft~(. t .a, n.te I r/e ai 1. -e 0r ,,:Rtrp ( r,l:e owner 1 4 fi the airier bilearrila t.(Ir' tho a11,.S re made Cby the dr" iri.cre HOLLOW CONCRETE BUILDING BLOCKS ....... tire obty h' dre. by 5inch cenrtrnr proi-ets eon ho nMade In n nCr¢hine allo;ine the fornmed hnock to be re-n di'eudrd e In m or fiosk tnd tire 0 be canatiuoyforrnatik n ..di One loecks. a' (obllrr. si;rit)e' or la s. i r i ert iiid r 'ctisary, frouladi:)tv 0n11' tnly li, Irli, i luS' orlt ot Iti c r;irrr. airr rrlr)'nro alflhe 111th or of iLhoirt 6ikit or rirstou i lt5 e riiioei =tri ne,ke erItclct. blurts aii iri b din ock nra.cines. d eels, r i: tr i nilri!^.4 are Irotli simple arid tectret 5 the1nrc linnut tinl whirh re s.gO-,ir e are arq i al a, lte that no esi cas lo 1bt0li s.iiataory reOnlo.d r'tth roam.Concrete lt tksr to r ulldrmr lrpOda are encrelly rIa hrlio,. , irerit ab iellilon in lire ilwils iit 111o0 lirr O r liesl e 11orr15 thre alocks to ble nuade ol tlih catred Sazi and waith lire A] t a it irirr Ir[s ronsistirot ith tilhre irered mlielg5h. rm xtrire Is tamped trt lire mieoi or TI ;1k m nra macIinrie arid when t le biririrl Is cousrrlr.)!-, i a is rketl out ct thr insarhl(r rut Ira tirilaty to u i dego the rannoc procin 4 which take$troli tenl I .i t olit I' lat. P ir-I'.1 tie 'aurine thlr i.,i erye'rl:.ae'. ,lstrI It .lllvr h ar i ht. rcl' , to be Iatll "It i ti11 11 .1 runt till rrrerairiorr4ribnrrfl'sitrh'.rSr I r 00 n .'.c0.' o.#i-%A Yr0.01nC a"lltirv like s1) In tranS.ANYONE, ANYWHERE, CAN MAKE MONEY ritd loin et it by elglcing in tllit hemoend otlerc[lac 'i'hara it a hig .te'.rrn$d ar! oCurrt1¢et troildie !Sboieks ond , th. 0d rnon"d strides. .'liirirai, rl,.rlni ire, 'arcv roles i in h .i r ' I r r,.rt I/- rb d-itli r i : tir l t. it ll li.i rs a'ilid tlii i'liil'r. 'ilie rle I..r n Iatue ri.) hrorha hll' lar te,, 'r thll r t. lt 3., 5. d ln t l T.rilI,C;rr Iu toulrd allin. h' y. ho' cria Irleiosi nothingc. 1111.1 Ih .,lt rirrri rQs be hNorelit o' .i"r'.irrlr', Ir0 A Cortege hutI 01 dl: Conrrete Buridrng Bltocks.expecrjlera is lrceauSn tl Ie ,ork ts Almp e rn nior iri;otroctiosns rel thruedhe and a. Ot oCir cexlrellow pricrs you ral, pircelis err' oa rte. fOilrret trIllid irtk lmchiilr nd 'll 0 r ',r a Very amail nMouirt 1 ieic" W, wi a:ii C ll ethlos ailt relsutc In tle OtCitlv,' or aonly to Oll In ily da'n saiiv e rli). rou0 \ii nlri it urefltbhr.irmiri y-u nIe f y- ici" Uer bloct h tosJ lou .cur )c tir ,rn hatdlies ciii nlQrU -in isie rcoa tha rIrey iti ,- goo mochlse.OUR CONCRETE BUILDING BLOCK MA brick msachines, concrete mixere, etc., which are sir very hetei;t cya oed highest evade or coenrele ork Manitfacture, hi Is partoutdlrli tree s rn elation n s o Clastl~nee, waleh are the heat desinted and boot made asýj g M'rw r U pos Improvping O0 cree machinery and Keepli of l other Mac SON. M~.. PU R I C E Shc ,h EXTREMELY L OUc. porch careumns, baelustilde and retining wall lt While tilh qAllr' aend ft!built of hollow Coecrete Bualdtlg Btocks. of our concrete wer'ine tO*"-ry is en hign as the hn our'priren sea reel ea0uch lower haon other, ask for Machines of nfterior ;ecde At habout eon-thlf the prices you would r compelled to pe for maochinen which woul where eeonrear a I"n e alily, and see honestl believe that yao cannot bu where at any price ,tnen aoes clroadndjatilers 0sUn. We ca. aford to 10e pr"cs beatre ýe 50 r Ca e t ed 1 seerr large quantittes under contrates Tile ilI.. havtorers tare no wiling or etlleetion experses. as we tage their and psiy them spie aSh foe everythine Our method of selloc direct to the snse ir Is ecotiomical tSr ttrso oh the adlinary dealer: there ena lohers'. nlotoleaters'. se middlmen'ss roaits oa heIr tie to I'y. our prices ore bosed ou tre actua l nst material ard lhbor titli sir our one ameit prot added. attowlnog u5 to neli to s e rieis at pricers Ye t ae- rgtralL s lair or lower than the biggest lotbers s.oud nave to play moe clas-9 et -ees a to'e unIoh )'oo the best concrete working mach:nerr hieh oadee and we ehtect ' blf monr'at'long. or you l^ ar csordeutully low prices.OUR THIRTY DAYS' FREE TRIAL AND TEST OFI V'hile the stahte ntC whi'chivn mnhr in relalopto our ceo t machiniry, oa wet other gooda ae ero ahoolololy trea rcd not 1. .% way.ee , ed peed u.pon ther i.rt-Meid aloe fyo orderyrI son e mar fneay r0 errS ,w IIaloe C. '9t1yylrr e u"ou thir' Sod$' fire trial. lor cat'lree sirorid vra order e irlos`d cOncrer¢ Suiildre.taehmertorom ,ai w00,aula have thirty' days froin the time yod rerlhred the mar rel ich to dairiho. r't ir ,w ii I{od to compare It In vaise eicen. Stircd asS pee o0 produact %vheh irdhroitl-ier erkclinos. no crotter uhat ties price 01 the oI t-rr mafty the. I t rein J ~If itse irdad %t a h( ri "zlrsrd 1t all tlal III claim Ior It. that it trade hii crei' rwsy. tiir It 5 strong and dourable. that It doCa better end ,ater wi ge'.4 yOU i.Nttir anhy otihrr macchine you could hay, or it rOli ate 00 ed A it rou have rreIv wr,,! y hb' p orhniroig ltol es, roil car retirern tLIre rchie CO IliOCe Slii eirr'[ n'?r~llli [I rldI"rryour ione i inirretrac You for trie (irciht ),rvlleri fort rncrired tin' iiirehr. 'hil are tire sore s(ir only Judge 01 rie IrYllir..e sets ,Ii ft oaU nnacir1irs. Tile .el%.t please I.nd sti'sl1- wou or you Cee yoar monoe WE GUARANTEE OUR CONCRETE MACHINERY oai, .l , o,n=f Shlp tnt'r'oal ' .lr 'ill ilt i 0ship rnt, c y 1Iihrll ire agree that shioulldil.r plar, iuO nhl lrri li rsr ot IfeilcI in i, l.'rOlt! in work-'m ohia l p) dtlr !Ii-" k,,r!,l at t.he ý i ri'rrurni S dl 30l pr t'.ur oh to trite mie ilari ol t0,a delclire eGUARANTEE SAFE D E L IV E R Y , O Aro. ....ete preptred aed Drotrqied horesh i-meeitI in te best po$eiblt teen- lnerr. llr'arae. a or Imrs Pt Irrlts fe(w iii tt rlett It vorlF. crier tillS. nbOlrorr an, port be broien or lOst retIlIe In ri lIte, ire o'll tiromptiy send iyosrn 011e1h ~ree lleeelrq to eplalestire ItI(1 seed. heoseoi or O0r tisri., tree at0.-sId 0basrge, sod Winn Lrpr-es'y ile tlens-e ABOUT THE FREIGHT CHARGES. ýoir Oensrr-chin". oro thiredt direct irom the fecer. 0nd lake oanery tow r"tI of treiehr. oril r lois 40U;,,,r l00e o I or 200 rl trL) priientd Ier 100 rr ,lure l,,r all" aqf ' ,ilS a 1>,Ir A Small SIoaC BPilding rmeo 0f Cc-"cr B u ilding!;,20 nor'i Illr. C,,C d' ror l001 ' 'irilh8. '1'11 treiter Cl trere OIl CIhe Wizerd Concrrte Il'lirdlin ]i ock. mchlne %rith ftul WCveluilint S10Iw 520 Ili000S. 10 AIbrilt.tildll., ' 0 b SirOlt Si.70 or ito d.0 Afhle. Ilar 21t .I ltrac tricns. 011ll 0. "rhr recloir, chrege ifbl nId ha pl' NrC. Is'r 1 , ilil lire. acer sarah ao teI nrt 'tlil! 'co' a'mrnd .4,1 t 'the esril w11ll tnak,- hFy srruhlac 'our order aO er, Don't lci the Iled t rIoentloa wmorn' save you motley ao rIstier wherr you FIGURE 2-9 1908 SEARS CATALOGUE 2-47 SEARS, ROEBUCK &' CO CHICAGO, ILL. CATALOGUE No, 117. C'ONCRE* E BUILDING BLOCK ACHIN OUR CONCRETE BLOCK MACHINES ARE THE BEST IN THE WORLD. THEY WIL.L MAKE MORE BLOCKS PER DAY THAN ANY OTH;ER MACHINES, TH"EY WILL MAKE BETTER PROPORTIONED AND BETTER FINISHED BLOCKS THAN ANY OTHER MACHINES AND THEY WILL MAKE MORE MONEY FOR YOU. OUR PRICES ARE tESS THAN ONE-HALF THE ;.P_R_'_C_E_S .... A.;.S_K;.;.;.E.:O .... F..;O;;.R;.:; OTHER MACHINES NOT HAL.F SO GOOD AS OUR MACHINES. THERE IS BIG PROFIT IN MAKING CONCRETE BUILDING BLOCKS. THIS REMARKABLY PROFITABLE BUSINESS the pa.st tew yea.rs until now 1t Is Olle of the l.adlllg IndustrIes or the country. 11 Is of Inleresl to the property owner bec.use concrele building blocks are beller nnd ehoaper thnn either lumber. brick or Slone, .M. by their usc hIs can be Netted eh.uper. beUer "nel mOre m (Iosisn than beneficial to Ille conlractor nnd builder because or lhe cheapness of concrele building blocks' compared with other building moterl.ls .nd because of its ada pl-: ability to all building purposes. It Is a. boon 10 the ..-Ulage lumber and building material deuler because It ennbles him to build up his business by adding concrete products 10 his line with most satisfactory profits to himself and wlllt still greater profits it JIO makes blocks to sell In his o\\,n Yards. He can purchase either a simple or " ver)' complete outfit from us nl wonderfully lolV prices. OONCRETE IS' A BUILDING MATEBIAL cnlled lI.:rfcl::ntcs::, and dampened with WAter. The rna)' conslst or elther s.l.Dd. or slone. Or tl.tt of combined. the propon,\cn.'! at the cement and tbe

wd

>\mQIIJJt of \.\":r.tCY used b<:lnc regulated bY the requIred strcngt.h ot the (':\'\C I>roduet.. \11(' m{tlh('Hl by whlch t.he mixture Ls IO.ade lot() (orm. and tn.:l.Ouer 10 It 10 ho U .. >CII. 1'hl'tO two methods or making Ono Is the wet CA!;, Ia\ whl{'h lite l.:; m:1dc wet ellou::h so It. can be policed Into 3. speCle-lly nlrJllltl, III wht,:!! it fCfI\:\JUS lUltH It lIn!i set nnd Tile ot'her Is known !;!.S the <In' in whl.fJh lho! mtXllIr(! l .. U:intDCIIC'd on\y to the cr.ment :l!'ld the as* r:rl'l!l\!1'3 \0 :'HlIl'?rt* 01' cHm: uml.er llUg:ht pressure s<? th:\t when the Is tamped hit..) :\. :ll,\{'iline lul)..I,I1l1 \Jr 11\1,1: it bi'! .rc.nlo\'ed soon It. 13 m::1.l1c Into lb.;;! form til (.M t.) Llr), :\J\\.I h;H*(j(!II. GROUTING, WHIGH IS THE WET PROCESS MIXTURE,

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i:1 ,11111 !rd;thd there tlrc l'/L-iU{"f>

!flit wllidl were villit. o! this .JI' rt:

l t1:,;:\ pul1l1l.: f:lld\ fl.!> h:\r-I)/), \\,:\Il.C;. lHI":,\kw!\ler;'f. l*lr .. :,,\(.1 the com-tn 1I! e:>'l<':tI:"\\'1,' 1,\:\Mln:! lH,'\*!\II..tI' the (Min (I' m(JUld I\u:st be buill rvr C\'Cr)' p:l.tt. or thl' '*'In'l.tttH*lh'r \\*urk. h*!!, 1lie lo\'('ntlun of {or mnldm; [mliO"l!:: blocks 01 the otHer U;)\\' hI U:'i(:. HOLLOW CONCRETE BUILDING BLOCKS Which c(,ncrcle products (:In he made In!\ rn;u;hinc

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Ihe formed blt>ck to be re .. fllo\'cd inlmedi:'lcel), tCf)1t1 thc mould or flO!;$k ond Ihe [0 be ror m"J,;inlt n\!dlfi..,ntl.l blockS. ,.\r.)' (Ql'iIt. SharK' 0(' d(;,1/!.{1I 11(' /tI:\dc hj.' m(lcbln.crr. 11111\11 Ih." ('l!lIipnH;nl or tile ll'l:ll:ili:IC'S, (lIlt.! lUI fOil\! ('Hiler with or wlLh('lllt "'Icle Rrc SA) ,.:;hn)){('

'lHd NJlIl,fNC (11M no olle C:1n 1::..11 leJ (lot::l.lIl s:Hi:-::!a('!orr

<<'Hh ('nncrcle bluc\:.s (I}r hUlltllll:': Me m:ulc hf)\lU'.\'. If) permit In 1111:. nf tho \\'llill! Mill I\llo\\'lru:: the blocks to l,t" 01 tll:-("'):recl !!.till t Oul ot the: 1tl:1t'hlll(' fill lu tl:,lkt :tllll. ::\.\\'31 to the-curine pn>(.":';I, wllleh (:I.kes from ttn In 1",\'('1\1\' 11.'\\'". lht' "urlc:\! thl,' 'hll1l."'k Il7.t".t \llltll Jt 1""('11111('110 !Ianl to be 1:'\111 hi \\'ul:. ;1IHI l111.!! "Mln:nJ,'s r rom lIe.s. .. :In(j ANYONE, ANYWHERE, CAN M A K E MONEY :md loU of It h\' cngltt:ir.J! in tlli;!: ne:w nnLl ollr;ldh'c l>ur,!('\,,,,.I... Th!!ft i$ Il biK Iictr.!llId ({lr ":'m..:tt'tC \)LliJdinj{ blLlck" :Ind wit h wonderfnl (*u"lIt'r(*(t.' l'flW 1)I.:lr.;..:' \1111\'1'(1'1.(11>" II.".'lf [,.r 1)11 the brm. nil' "iI::l!!Nl

lIh1 itl {*Jlj(*s.

The fur IIl:l"lIu: th*! 1J1nc'ks {rulll {he {"I'II1(>1It.1h:H !.s. S:I:\II .Ittl! 1.'T:1\*('1. CaU found ('u>>(.,S .,lmost. nl)tlllo:,:. l!ti" {'('Ill('nt . ... A built of Con.:tC'(e I.1uihUng Utock$. the wor;; ts

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stnlctlonS ME' UlorntH!*h.

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{'OIH*jel.o 011/('" JU:'Ic}!lnr

1011 ',UI,

!! :'n' :1 ,'(Orr ..!J(H!kll nmoum "£

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In the bu.o:.iuC'M tlxlclI:\:\,t'ty Or on!,}' to 011 FARMERS AND SMALL LAND OWNERS .. cemenl used * .,hieh is onh' about one"fifth o[ the whole, t lutelY nothin!;. ",lIlIe ther can seU the blocks for a. much ns pelled to buy his sand and gra\*el. The farmer can employ

'I;ke If he emplors no helt>. He can build his own house. his barns buildi"gs all wIth material of hIs own making .* ail he c.n sell his at a profit. A modest concrete blcck making outfit of very little

>."d ever)' farmer who can use one to adnnt.r:e In making the investment..

The savin: you would make ... on wOllld more theW paj* [Dr a good OU&'fil, aside from t*be you selling tho* block *. FREIGHT HARGES. ehinu aro 'hippcd direef from the helMY II r.d t,'l:ke 11. \'ery low rAte of frcip:hl. l):I'r :11)out 40 <'til'S :I':r )1)1) p;)'lIId!:l lor 100 A Smail SlOl'c OIJHdj(lJ: or C ...... Sui ,\\,1:.:\rl.1 CO:'lcr,'tO' Ihilldl:ltt 'H:ocl-: m"thlnc wo:-ti!..!lin!: 10 A\IOUnl. W<lll:d :>t: n,ll('O\lL Sl.72 orlto /'I1:1JII(,.

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j!j,I,iO, 'rho: [rch:!nt, dl:trges B!\\'C )'ou money O() I!13.HCr wbcrll rou \ll"e. . FIGURE 2-9 1908 SEARS CATALOGUE SEE INDEX, PIMPi ' AUTOMATIC J +E RAPID BLOCK Al) CONCRETE BUILDING BLOCI a pressriued on te tothe ale wing three puage repr tneocuy rateý building blolk mchioery, nod so lor'1m l oCh .achines on the market ao the st>se l*ih. anti eopoinge they are lacked a Itomaticoly, sthe*~ tir penure 01 tbe loot against a toot lever causes ths li¶tsort.

Them sie ,'hlneo produce n perfect blaeh beesd~ od open witwhout uie., and beeusa e the soape ireDl before she cores ore enmred Into the soy pjred t ,arelo; tine below the cores to forse the bloeV S Inochesr o Ichtnes. I t to h camped bosrw line sepisandopnntte in u RSl whicbrshe theg'-rtireblock ma0kr who uses the usot type 01 mac____ Vizard.E iZA lD BLOCK MA)CHINE mot, ft, 4 tt Inched tone, we can lurnlsh separate nshlnosor Incheles; Oaes]0 I neee10 belie or 12 Inoebes wide, nod to-~Isle 0 tap ir0te etachtneeno I )kncg100 blOCkS 8 Inchsee Iish 7'111O c"a porch sn a neporate machine tor etch alse of se state machlnes 000 05 many Ot the dIfn eent anoter d sg U .n th0 coerplntene-s 01 the O'ttit you wont. beco nt, onet the cvame or $tlnd and each, t complete.h chane, cwhich ehanie con be made eoolly and qule made AVith onr con reto building block macblioes arethis In to ntlow A oe tore mortar joint, 2-48 PAGES 525 T0"534, TO FIND WHAT YOU WANT, 575 ,1 BLOCK M CIE IN THE REAL SENSE OF THE WORD PRODUCERS-THE BIG MONEY MAKERS KMACHINES .llchust~ratcd, THE WIZARD IS THE MOST RAPID BLOCK MAKER Om thex ar-toot eke very" hi/est type of Is striotly a one-man mnachaine; that Is, one man ean operate it as easily Sas we know they amrektie only ad we believe as rapidly as two men can operate an ordinary machine cOoliygat tIme. They ace automatic twice as mnuclt as tee ask for tie Wizard. ThIs tes what tite lUtomatio freaturee boees ure drawn auloesatlcnlly o cores to enter ani sake taeir accomplish for YOu; in other words, we durnish you a milachine at about Otlne-lal! ause they ausre up perfectly, thn e price others ak with which you can make blocks about twice as last as on o of the cocen ta ohe n that no other machines.outd, consesUently titere is no 7In h ýe fourteen dlfet to crack. as there In to block THE FOLLOWING ILLUSTRATIONS elowhI can be ma desonot ime a loeottheandc trio atri eaco he sz f, and the eatring 01 the machine Wizard Building Block chlnehnes. wvilh the face plate$ and end doos (or toe 'b Ie we soW- hurt bloks arid causes the gr etest lleess. and wterbever

Lcw design kecomer popular ce t ntad it to or line. These Sloe. There Is none 01 this Hlnsutailons slow blocks wllti tw0 cores, as mode on hi ihatnr m1c'e acs. Tin lilucI)0' mI dc on tile 24-1netn machlocs hins three colrs. otllerurliC their general alucarugoce Is tho same Si ous sizes, to meet all renitre- In these liuttralIons.

Block's Made on the Wiusrd macbla have shoot 3a $ per cent el ott to andnrd length O bflueh, or core as'es and 0,$ pee cent concrete materialits belie the a gandari p1 procrlane I.katg blocks fllnches highby recognised a os reqtstte Itr Iroser triegreth l the litck and economy In mater als. Face the 2-j-inch length .1 block we plates tor tokhio. one halt block and two quarter blocksi else omae time as shown, .thek bh' 0110cr Inches or 1f locien lat.nt these fifteen Ilustralions. an bfr furnished Ion eithe!rell 1t aoIhz e no eke block, or you con purchase to n difsrent desiGns. The roelar outilk cock eQach iehinto inchiden u sCc ot I5cr pl.tes 1nod end iangeablesoolds as you with, doors toe macris .aedord piin lll ce blocks ald A cit ol lace pliaiog -.nd eoll doors Inc maklig use alt O1 the dlfferent stoes oa Standard rock face blocks, there bohlg Isce pixie tqe whole bfsiko and a l lse Plate t,-haves wIth all tie parts cecessary to arid quarters in each set. You con eroec ývair Iackne fitted iltlb sees 11 ete ias sad cod 017., 50 heteht and Is length dinos for any two or the different denigcsio pIlce 01 thi e toer f tafitloed, d us esignb witti extra Inch less than the moasures clargo and yot can order aIn ts te lace plate arid c wlii rhlrar f tire other dr'algau as eort, shtW ainioh. n0o r t er l additlo.al oe r,J'eetor r.t-Sreaderd Plain Face.Ml Alher Face, Style A.WaS~ter Table Fuce.Standard ROnk Face.Broken Ashier Face, Style B.Cobbloatne Face.Panel Focal Tooled Edgec Rock Face. Toolsid FaceBroken Ashlcr Facer S ty'l C Broken Ashler Fled, Style D. Brohen Ashile Face, Style BýAS'$_ -a-l"11-ý R MEE -.......... A .....Scroll Face, OUR MACHINES MAKE THE BLOCKS PACE DOWN , a iS t a FOUR-INCH COURSE BLOCK ATTACHMENTS. weo. uno oiihedd'at hiock canhe mde' rf n neiet foe the facn and coarse material for the lul height block, 18 Inches) coehe used for heir courres slid s Ciile the onto tabln tarts e hblock. You catrhake ke lace mixture so I as yon wish tnd die Sod- mixtuie In most genceruly used for this purpose, il Is reivenilr .ieslraii to in eC blocks r nly 4 I,1b4e ,'th mnatlest asorut of cement allowable. ekeh ssrd c eetlully laced to liest foe be-t Ond 1ricing coCuill Thrs.1 Inch lh~ckr r ris l used .i ci.n1oect ic bu tire reisa, possble cost.. Y'ou cmI make blocankso any'deslred color In the faceimnI-wIth-ihbocks ooklaina broken. ashler elre, .ctlr letr r emi fttt t richh,:)uroe bloc!OuwithOt teustIng coloring matter In tire buoy o1 tig boek ; and scith as perfect a machine: attlsehteos whih elther Wizard or Buceye ibuldip bluock macli i:cs. A 4-Inch cvurse blick s the Wizard to, osle a correct toixture and tunspint It toebmeot coosists of a lae plate fsr mairltis tsr, iboie.. roperly. you are a-sured oS 5 perlectly made and per- blocka a face p1e10 toe making two hals and iogr quarier* ,- mclit flniihed kiosk erecy time, blocks, a 001r of teteU end doors, Iour di'ldtce itaira i-uT O n blocks d 0rnal=n tire lall had tquarler blocks. srtd tieosdil'ldh .THE SHAPE OF THE COU ES with the Wizard (l"lI ior ele ut tie hiocks. At 'otli sole Block hiachlnes, a' shown in ,iiliusirnlion, In radically We Only furnlish to dieidine paliets %St tlt heu cth- -dioffecrnt frnthat lgce 1r usi. ,o.,Itthesmoke mce bet yobut il requie us malnydh'itliog potters at ol Iblcks wlth squarescred cores. compettieg the operNtor yap WIsh to mte1,u0vld, ree day. sod thice sg'lt le enh lamp Slitim ntlre nest is tire lore 01 the biock befor ordered wheo suit order tile stiacbsrea: how-c'cr., ltcte* the cores are Inserted it ele mould, titus le.na hard Same diildini pslleto iom aed c'liii nttnchiou;s for ..amfind. siitro -ner Tir sore tine Of the bloc which dteert designs of J!"okl .These attlclrmerhrc coon be makes It weak and liable to orack or setaritte. This parr- ,Inlen ed only lee-hlojke of Sire lOilOihtr designs: 1n5.0 w" -, Ing line and the ahuare core cornere arc tie causes In e. rock lace, pone face and tooled lace. a5rc -

Block Cores, result In cracket blocks rnd only a 'erySilght a I ec reins yous moat ho eereltr to tell 3s whicii 2'.a It rb eecred tn crack the blocks Cor these ercumstnsrceo, desice o1 lace vOn nent aid to alinow sir cats- Obil mloc.u t ,. b relttlca Tists aflors vou to -the lace m-terial, insert )ogtue prJce for e attachmentl t od nird lor such ealro a..1( Ictttd hitl the mouldld With coarse materesi = ato startleg to tOmp., hontie o tie taints- deivdIng po let no you sea n t. to orrder.* ,,Iter lortsows the cora.01dm and the mixtorolI tamped to thefieeof the block nwd CIRCLE AWItUMIITw-, Circula y wrsdnw. or swell ftrontsorcir t-hesrrnJoeast' harde Cnnnynthetpor.al thel' b and wthiron asyl-mpeds.Crt IRCg BLOCKAntAUin OtUlIt.,mItIS. colorcorners equireblockshoving onveS*ere are no e corners do trt ernehs anti the arethd loin eo arides adds fore" r ct I arfccss. eanf unrnb furn tO thither Wtnardorluekc'ebuildhtig hintS truarnom Fa-foes i , tcmtofthe block. te your nilseurn li the, and euro the and 5-f<sot rndies eirct irhlock. ai,.c,,si ,,tnciira to Ie 'eo 'OLsoti.,d been Ore. ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ l' err blc made it hriid ohn il oai 's~en oe c hpee.cnock. d.11100, that is .plalt lace arnd rock lace, hod lit tire tarer table d0rsiert, Suit-Is rqtlarfes J[]I;IT.-furnishnda-bib o~ur aparute Otteehntent tsr cas~h diflereni. radius and lace deulcir. A tirreloe bik atlnchmeni15 othe Eyou .00 matte stetndard plain fuse and standard reck fae onn.... 01 ... Isce pltebr sc'hoin blocks and s pale -t core rhwi lUr ritt-ldtn 1' b ~ l t i c o re 0n o s d r e t u r n e a rs , O i' h e .u fo r " e r o r tn r s o a t s c b r adi u s y o u o sr n id a n d to a o n noti -c a t a lo e n a pr i ec I n c t ke s ti t., .' S .zi Chblocks. SVC nalh e attachments and extras or these .rchtr , whh ore us .I , lii ike price el the machinsca hbu whlte con be ordered at the tletemachine The rg~t ufto d : "M aort ny other time at the prices dlisovn Incur... talneue. Thes ataclen01 an SPECiIA FAC .. .re...gn irhle outfit 05 Otir .... pni'id'lroidimed deernet, eomahtg whole, halt and quarter biock., with plain ends. cure ends stud returnruttimi slit f!-hon with ... widowa are gs...ly made standard p15i0 tace and ni,,ir.rd (medium) rock Icco no, or 'our e$nc e, tic iWIHDOW ' =In t atrhei Of .(5 degrees but the uleslene illustrated on this pair. If you4 scch tory tf.JeOrher ade at any anotn dosired ~ ' r'nae\yrw;'ae. ire to et:al :c5'It.ri , d.,lrckitp desle t si r e uui ri d tillon ru u Iiiustateong stiown hor so lay up hay BayvW~ndow Bloclrs " -Ohrsondeqlee lyo~ineli.etersdur-idlnrour she Orki. ck.oe, .no asgto rakm oints h md tt-c msc lis. .t tins brim- rilns Oar ,t'ullhiiir s'tnjlc ( 1 sith either Wizard or Back- _____"_______-_'____ blOCks hue lees ri:tes u ,irr. ukine- fr.'L:bunnO rioete & minic tfo, iltln AVIntuit 50r1 10 Irn wbay 0ot iec n as emilns ty ou meld. -____ ;dh airy ' m1C0 Imnrni~ ' 'loockPt K enmp~. llhwl raueufecisrin mm rf 's 15h0 mriCii'ta: ,h.-Sm+ th:.*nluilO crrtiiit indr Ft a-r pae ond ohteede nboke 5les tAdo bbe -t Vgn of ye1 ib k otten se eonitmt-O st face -'cent) Inc inol r-oriir Iat mI are slates bit ., as adluatabin cad -pinee..or r retur ew a n o Catalogue p rice r yon .1 t0 ml e ivCtid a r ...t .extrs .these m er Occare i oe ,gc ed or -ee acoetie. bu,11hcnb ree a h etem.hnI 1 6 l~~d'IIdn end 01t he k'. hed f. --)1:1(,.. t drblocks and quartoI Or at) tbe Usedes show In ourn Caaou.hhsretchint PEILFCEDSGS hays follods w blocks nm--wiseclscrecnýuaB.eS war h newsre enakial chine- s-L,*... " " its. o, ),o end cOraul .Sho blni n rer-trui e ti-re boI'heloik ii h e yvU lie od wic it-il -b.u dBam 'ind~ stalin. .0cii din ro e 10very; corieirunt. i Those attashmeata can be 1Itleninhed Only 101' blncke 01 the tend doors flriii,Insi ent SirhLle macirine coo SO rmrdJ ii tosintir -ul tlty too.: deegltet si c.c l,: Ibve inn be I~d Iln un .f1h 0 1c¢on t r,,ii l lace rack lo.e. pufe, 1.... ded edg cork P.ey tooled le ..id I BLE L S , VS tec h antotc.... Ih o ire .. moe in ay ,e a,,otc gtne sh w ith. W ihen ord ering y u m oot he ear elr 0 teB u ck W h l O m s Of nce O tr I d il pl i ior ctatsloge pcrce rIc attochment. -this hork hwilllncnfursd wits tue snackioc i( FIGURE 2-10' I, ]1908 SEARS CATALOGUE TO FINO WHAT YOU WANT. 575 CONCRETE BUilDING BLOCK ACHINES THE WORD BIG MONEY MAKERS o IS THE MOST RAPID BLOCK MAKER th;ncFait an machine; that is, one Inall can operate it as easily rn.pidly as two men can operate nn ordinn.rv machine cost.ing we ask for the Wi.aTu, This Is the au'tolnatic

in o.t,her w?rds, we furnish you a machine abo lit one-hal! ask, wIth whIch YOU cnn make blocks al.>out twice as fast as OIl FOUR*INCH COURSE, BLOnK ATT A.CHMENTS.

r:re full heighl blocks (8 inches) ce,n'tle used for bell alld while the 'Wnter (able h.,; *. fri with g .. ln<:h blocks t.ooblaln

a. brOken .ashier eN'c('t.ln Ult! Wft:J. \\'1' fu:nlS!1 -!-J.llcll bloc}. attfLchuleDts with WI::t;ud or b!()(:k ;:n3chi:u:s, A "-Inch Cl)lJnsc bh'('ii at.* ! blockS, R J)31r of ret-\Im end doors, lout" (l1\'hlllH:

tor tn:lklog the hall and Cjtl;ll't<lr blocks, ;lIlO t\\'o di\'ltllm; ment, but. rou will as ma.ny uh'id\nr: 6:lmc !llvldlll!; p:1.I1cts t:\)\ be wllh ... n;s tor desll;ns o( hlocks. These 8,t.tl'lchmclHs enn Ltc furnll'Jbcd onl}' 'or blocks of tile l'l:'Iln Ir;t e G=tJJt: dlvldlng ,PAllet3 1\5 !r'ou sec nt to CIRCLE BLOCK 'ATTACHMENTS. or cirCular faceS. "re ea.n rurnlsb with 'VI-z;nrdor nuckc)'e build}'l; lIl:l.chln("';S mdlus, ]()o.:OOI, radl\1s Q.ntl tad Ius 'Circle h)ock, a.ttachmcn Ix tn 1he twu sL.'"I.ntlntd which rndlu5 you wnnt. nnd to sHow OUt Catnlol;ue price Ivr \.be outflt. '.' SPECIAL FACE DESIG uS The ,.gula, outfit oj"o,;, :wI,!'iid'nolldln. BI.,>, n ,.'\'nchines includes (he bee. plfHt"Jt. Jilf\d end ctvon 10t makh:i." whole, hoM rind qU:l.rler bJOt:Klt. wIth pJe.ln ends, CIHO onds nth) tl'c.urll l!fHix; the . . £:wt' or:\ hea\' rlH:".1nre ,be sIlte to IH!lh: F'IGURE2-10 1908 SEARS CATALOGUE whlt;h de.f:lIJIII \'011 w:iUl jinll :.f}':\IIIJ\r uur cu. ... ::11l:';1.I1.! prl('c f;lr wh1,'h you V[(\I.!J We: tho. for WIH}!C 1,I()c$-;s, t.hc ' rl}r fr,'l..ttlur,i\! hloC':II:<:, atH)' ri .... !.t* h:;';ld .':tnd JcfL tl.;:l.Od , 1-<1 lhal, you ilc .... u j':'S ll!HI cml .I<H;r:-' yo.; I".d t)t J';\I'll lilt 3ny onC YCII. , I' 1;II.;c lor '1 H.' rUr h:\U qUarte.:: ncJ :lont! One h;; l-eml

InC cor"""

Inc.: n .;:In), of the fillet do--. Ihe: divicHIl£" plc.u for 2-49 SEARS, ROEBUCK & CO., CHICAGO, ILL. CATALOGUE No. 117.516 576 I THE WIZARD IS THE BEST 8X8X18 CONCRETE BUILDING BLOCK MACHINE MADE INCHES It contains all up to date seitntiflc Improve-mente known to this-class of macnery. In CO MPLE offering you this U.h grade machine, we claim it has no equal and that it Is superior to concrete block machines which are sold WITH-a s high as from $100.00 to $200.00.- BIG OUTF STHIS ILLUSTRATIO h -shos a wizard Concrete lding Block Machine closed and ready to receive the concrete material As listed for the block. Observe Its coinact con-struction sod note thiat every part is mechanical in detail; described that isE. wit l automatically accomplish the work itself with hut little assistance from the operator. These iachines should not be confused with many concrete block machines of other makes, which are no more than mould boxes, flasks and-4orms. The -Wizard is made to perform practically all the work and not you, and such a valuable consideration, together with many other superior qualities, places the Wizard in a higher class than so called concrete block machines which are only mere contfivances-made to assist hand-labor. We give you aquachine which Will do the work in greater proportion and much faster than it can be accom-plished byany other method.TUlE FRAME is well proportioned and supported Te flRAMk wothl ibs f nd braces which prevent.the flak or mould from jarring sagging or shift-ing when the block is being maNe.. a large percent-age of blo-ks are broken during the process of their making In other machines -because the frame or stand of tke machine they- are made on is -too weak to prevent Ihe jarring of the. flask. A mere glance-.at the Wizard wiLl show- the substantial 'construction of -the frame of our machine, which elirnlcdtes all possibility of blocks becoming cracked or broken by, jarring of tlhe flask, fir i rmould.l ." S r nouerld.' m iMOUL IcOnsttrtucfted accord-TA A A I ULU ing to the face down:r All parts of the flask or mould swing from perfect cen-ters which gives the mould a perfectly square shape when it is closed and completely re-leases the block whoa the mould is opened. -The face down feature of the mould gives " the block a sharp and compact face, enables you to obtain a better proportioned mIXture and mekaes It elec --to use colorisg oany tor the tace of the block I also makes It possible to ae a fine' quality of mlxture for the face of the block and a " cosesr mixture for the body of the block. The mould is proport oned so as to permit the proper percentages ot air sace ard bearing area, masna them about 33% per cent air space or cores and 66K3oer cent bearine nurfsco. All parts of the moud which are nto action due"ns the process of atlog a block, work automaticrlly I1 orcn-n I lad elceing t~e form; Ihs Is produeed by c richr whE 1 are~moved by t he opera-tor.THE LEV--J ~~~~ERS .r~r;,Z? a.,d .ae tnedb ek --war s of releasing the Slock. The end doors ace seaae frm the blasAe whaenthe levers are tpread and the face Plate ts W ithdrawn by a straight) ~Away" release Wbhe ] the--II levers are IIted: also the .entire mould 1i swung back ad away f ram the block with the same operation whir 13 used In withdrawing the face slate. These three9 actions comapletely release the block Wo that It can be carred away on Its pallet.In scleat, the mould the "ena levers ace J ta-e actihe osme number of operations blre ureqead. The tume required for all opera-tloan both ,1t releaing and In closing the mould hs ColY a estitl traruca of A miute anesa the wor Li all bX tie two levers and does reire the hanfIIIg of any other part cI the macrle. This In one at the automatle features of our Wizard mact ne.THE CORES ARE TWO IN-- NUMBER otthe td-incch Achiba NU BRand three of"' tmaro tled en Ie 24-lnch machins. They are cocsncd Ie seth a mainer a to allow tre)tcatrate whia t int tamiard ample 00'pertuDatr to talow thL e a-rtes oa the cores to a point dIrectly under the reeler of cithe aorta Th s shane core Is very suserlor to all others bernIae it geves the block firm~$ diroll t undtr the cores and sufliclent strength to the tic pices which ellml.which all Ltbt l:T Of the blocks =o khle or breakilg whil Snagremoved from the machinek rhe core' are stitched to tLi Autetat Cri extractor by a steel rail whIth SwlniTA "'.weep a, yoke. Ths preveoas blidilg whon they are being witadraira by the etc. : "e TE IT tnd on, OUR AUTOMATIC -CORE EXTRACTOR XTRACTOR emn oncrete block mlchinery. Tise old way a textraci by hand, weights and levers has bean overcome by tIs method, It takes a great deal of time to insert snd ext hand and it is hard work, considering thu way the concr, tamped around the cores. OUR WIZARb CONCRE MACHINE Is provided with this automati-core ext extracts the cores automatically-when thelflsuk is Itll release the stone and the simple act of stepping on the inserts the cores when the mould Is turned gack for rhi the concrete mixture for a new block.we furnish1 with this THE REGULAR OUTFIT wzc sh n'has is most genera M iakig a standard variety of blocks. Special attuci as Bay Window. Circle Block and 4-Inch Courts Bri ments. are extra and are furnished only When ordered and allowed.' The regular outfits furnished with the machines a and described on the following page.THE SHELF adds. e r Wiosrd snd the shell Is a moat cuevooloot place open which01 to lat:a tht 1 and keep them wltiln cuss ouch when hA Want otherwise they would be iberwa 00 thle accrual(-mating it riecesery to look tor theta wasted. All at iths takes time and-ae tha great amount of time sand--.saved by" tuacii hef hiock marhise beuausea upen If. \rent sod oasvsi renek the blocks. Wood netinvo HAS 05 On c 0e Of Other iroee your it nd greater Vs-l Y k'a YOU SAVE LABOR on o: from the li'oard airke perfect blocks.and no other machIln will make them so rapidly sad with as little exertion ad xperse oa the parot o the ope-rater as the Winasd. We know of several Inofances where one w has made & per-fet, blocken e Wicard in One mlnu.'ssma time. We do not mean to say that every-one under all eonditaons can make a block for every minute oa theworkindg d butwe simply mean to lhlitirate the speed of which a gs- l$ 'mabin tneo scapable and tre grout amount of work It i tasshi t e00 to do alone Os this mahtoie. Iif Ii k-bsm 0 tOmen to operte o ather of hOCrete hlock murklram In order to get a lair product for ose day-ne work ad te cart Oi th.or to do the wmrk Is approximately 12.00 ner day for cach man, add $2.00 A day fer every day (oii use a man to sealst you to vie price o tite ma.chrne snd 'oe wii find that a it will m he m Ieh na n e o si 'e one- You buy o0, Stiasrd Concrete is0hk hachlae and you operate it alone cc block and .a.ut o many blocks sot tn- riea coals make as the that. $2.00 a iAy thlt rou woolSd hav to pay for imae loan o deduct tl)at $2.01 ev'd racr day lern tne price p I od tlerue W5 tills sarlng of $2.00 a 1 ay wlil di a very 81sort tile cr-s fr 'oar tint can be applied to yror net prOaLts. Should yoU choose toc Block hacbIae with too asa you ma do eo asd by so doing You.E2-11 CATALOGUE FIGUE 1908 SEARS.... j I : ! f. THE WIZARD IS THE BEST CONCRETE BUILDING BLOCK MACHINE MADE It eontlUns aU up to date scientific men ts known to *thl S class of machinery. In to concrete block machines Which are sold _s high as trom $100.00 to $200.00.-- THIS ILLUSTRATION closed and ready to receive the concrete material for making the block. Observe Its compact COIl-6truction and note every parI mechanical in detail; that Is it .. ill automatlcally accomplish the work itself .. ith but little assistance from the operMor. These ma.chines should not be confused wi th many concrete block machines 01 other makes. which a.re no more than mould boxes. flasks and *.Iorms. The ,Wizard Is made to perform practically all the work and not you, and sucb a consideration. tQ!(Cther )Vitll ,!,any other superior qualitIes. places the Wizard III Ill,llgher than so caued concrete block machines wluch lire tnere contfi,llnces*roade to assist hand*labor. We give you which wjil do the work in greater proportion DJld ,much Ia.,ter than it can b.e accom-pU5hed by*c.ny other methOd. ... , T lH:' FRAME Is well proportioned* and supported ns;. m with.r1bs and braces Which prevent* the lla.&k or mould from jar:rln.g1

• sagdng or ing when. the block Is being mane.. If. large age of bloeks are broken during the .process of thelt making In other

'because the frame or sland of the machine tbey* are made on is ,too weak to prevent the Janing of the .1Iask. A mere g'lance**at f.he Wizard w1U show. the substanthd 'constructlon at ,the frame 01* our ma.chine. which eliminates all ty of blocks 1>ecornlng .cracked or broken by-!Ilmng Of the .flusk* or. mould. ' tHE *FUSlC OR MOULD tace down*. Prfuclple. All parts ot tne ftask or would Swill&' trom perfect ters whlch gi..-es the mould a perfectly s'lull!'e shape when it Is closed and comJlletely leases the block when the mould is opened. The face do"",, feature 01 the mould gives the block .. sharp and (nce. enables 'you to obtain 8 better proportioned m\;etute A.nd QWJ.1tty of mb:ture for the lAce 01 the block nnd Q C>>ar'$I:r mlxtW'c l"r the body of the block. Tile mould is proport oncd .so a.s to t.be oI ms.klt}g 0. blo)ct work ftutoU1nl\C'{'.lly In openln; end clas.1ng t,be torm; this Is to lelvers 'wh1oh nre moved by the opc.ra* tor. THE LEY-ERS and are u!.Cd*b operAtor In turclng th.e. mould" for ... ward ie the COurse of rdeuing the The end doore n.t'c sepa.rated trom t.he bloCk when the levers arc lipread A 8x8xl6 INCHES COMPtETE WITH BIG OLJ.TFIT As listed and des crib e don. page 577 . n WilY 'telC83e w beD the Jevru'8 IHted: also the . 80 that. It can be CAN-ied AWP,y on Its p:R.Uet. requlrod. Tbe tJmc reQuJred tor aft opera-the work is all fr!'"lormed bX the two levers and. leaturea or OUr WiU.rd F'lGURE2-1908 SEARS CATALOGUE 2-50 YOUR MONEY WILL BE IMMEDIATELY RETURNED TO YOU FOR ANY GOODS NOT PERFECTLY SATISFACTORY. 501:: NIQUE. PORCH COLU N. PIER,!1 ANL ND BALUSTER', 'O ULD$UNQUESTIONABLY THE BEST MONEY !!j, $1 00 InKE lthe business, because 90pe 6ntfteon with an outfit for maing porchs p a trI ls and the demand for oc EtsrioC tor us WE ARE OFERINP 1.. o lun..P.er with conceals blockc housean meIa Bauseeou.,d Puier -buildings Is becoming grent.sr ev c l 0 I. te. 1n either tonihior Gothi Porch Materials cfommand bilev -on oter as or Ars outfit tn afa os~eee hnwe acon 1their scriyadftdSusmse 1I2fo i le ounso Mootd with* ~ ~ ~ ~ ~ ~ con scrct and i It-..= _ .i fluted Attachment for maklnA plain and fltd 0lms upnte deig 0 the mater ial as to the C.l iotfr t 'shn il ndfue om psilco y-ou receive. WVe believe that an 0 s IClm aia nete oni orGbl outi luch u we t ielb y aesnd 1s" 0 .Reound Column Base Mou 1 0. a, u e .ontli fs .uid; ier o. Moidt In choice of desi n; s benrthpies bu~t~w1 o , bring you thpa en ofPIrP 0 MaouidlIn etither Plain or Erg adLa th Prd o ths e brm perl ca ofi Pli M rs " ould' It Set 01 Four htaif Balaster a s Molds n Top Ri ould In either Piin or E and WILL ~ ~ ~ ~ ~ ~ D nn HTOU E0 ThicsmlIiusirations on fli puge tshe" YOU WILL UBLEcoHplete TutLt 01 inulds and the two column aed- rail 1-- .ions on each dido Olis pi show the produ si -; "- il ISOl ~IN othe products mwhich can be mde wilth the moulds. %verycolumn toddie Is r of outhi t at comptt, for making p lAin ir a toed COtimes. $0 that It rn5kms enormously large prcfitin, bocanice of the artistic de.tgns and the no dutienco you order thlSpart, benaus It IS iuflshed comp et. 00 lht corn lone form in whiclh rtey are mode, and t heir compsrs-tlvely IYOU can isahe t lal. p11olumn nivtn or, without, ornnmosts pIer Or n~i" or you-cract holumn w ithor , iout, ornit entot per ortrail e sure tol¢,I vi"a I cost

• l attract ... e -tienti. .of every builde. Nu reel e r I ,wnted, and besicg of ca.putal, pier snd roll wntI .th cone in omplte "wio a porch, and nO conree block plant e yld rhne B Isl cOrsint ltiuor i nqg oc Mo5l Otit.Wh not Ie u. TH wAROU DES rN wtoutmo u dr are 00 oilo tp io al If1 younr a~e cto'reote block manufaoturer end comploto ed Mtar in Rock Face, and Bush Rok ame, Panel d aes~n.Theid Faceln of ie 1your ie by addingaxhs big profit making outfit to your list? You Cap is Plain aed ggg and Dart Moulding.

The design of Tnp Rail is plain* will Isavo to show t'he customer what you make before ho buys from Naed fe e and Dart Mouidine. The deuc of Column Capitals are Othit and-you. Perhaps I It thinks that such a complete and artistic line of Ioonic. to ordesng your outft or sparate souldS, state the s15e 01 c0lun porch materials cannot ho made of concrete, If so, it is up to y L wanted and theIo design of vareous moulds wnteed.d nto ehow him that it caste made, and the o nl to do so loe to cont W E G U ARAN TEE EVERY OU T FIT orIs:, d obe p rfc in o o L,.14OLII stractio and.I motrft blcn1d vic oreffrtb ucoiga uftsonu at ur-son*h-no Dbud nOnnf Euleetr, a[%tor ten days' ulut yo mo reyTturn osme aso~:*I 'ingly kow prince. .... .: -..i xisense and weo will relund all tooney pald. together with ireight ehargos, PRICE LIST OF UN IUE OUTFITS AND SEPARAE NOULDSI GNI O. 32K5830 tO-inch U nique Porch CotuIn, Pier Rail and B atasier Moutd Outfii complete State desIgn watited Shipping weight, 130, pousns. P'rim ................................

................... ".............. '........ ..................... " .......... "$ 72 flu .3 2 1(553 12- itioh U nique Porch Col umn.. Pier Ra it and B al ont or M tould O utfit, com plete. St ate des ign w a uted. Shipp ing w eight, " i:757 psouds. Price..............................................--..............Fluthi Caputni Rockh 'OR 50I-iN'CH GOL.UMN { FOR 52-INCH t t lain Cotumn with cP ,d it d SPAriTg MOULDS wtv -tunic C.. t a,, Pond DutPe s and~ail. "Catalogue No, lhn, Price Catalogue No. lbs* P'rice Cap and Rail. aCombintion Pinand Fluted Cotumn'tour l 32I83 t I 1.25 321d 5845 f 3.40 -A , Ornamental Cap htould.(Oothtorieonicd)

.. 321(5 B36 I00~ 8.02] 7121(846 100O 10.30 -- ,O, .0. Pier Base Mould ........... 32K(8837 I701 0.92t 321847 I051 8.30 -'Pier Body Moutd, (State detsignwsed)..I 32K(5838 0 5 5".621 32K 0848 I 5I 6.22 /[ :-d..PierCap Mould (Plate orMggand Dart)...325839 0 8.25h 325848 1751 9.45 ,.r o "; No. 32K5856 PorchTop Ralf Moust.c Plng weight, 7in of C se A ,04- d Mo porch niateria; can32no5t54 Porch Bottom Rail " StoId. S eh ip g wesght. Sf psuds. Peiho.. .70. 22 a.u .32rices, .a... t. tta. f Mould Sh pi ht. you... ..... .. ... Pi ......,05 ....032 pounds PON i... de. I ............................. ...................................................... ....0.05.2 ccI r2I TWO-WAY UR 157"HANDY~TEN-BRIOK SIZEBRC AHNIT IS TIlE ONLY TWO-WAY BRICK MALCHINE MADE THA WILL WAICE.ACE DOWN AND RO*CGH WALL BRICK FACE VP. ONE PlAN CAN IeARE 3,000 PERFECT CONCRETE BRICK IN ONE DAY.CONCRETE BRICK IS JUSTLY POPULAR becaue it replaces the eommnn elay and is Jut s dulo. tinlebed tend miore duabhl thuo the clabrck, Concrete hrick poset the sauqte ,lu .s Ecogr bloc)n, They become harder by age end cannos be destroyed bi ure. Co....nte trck butidinic, togeter with oncrete block and oTeve buledlng, hnve lived throngh teve reile such as tlie moru suit Ssn Francisco fires, in which buidlnus oh elayhrlck and stone Iire been totalIy destroyed. NO CONCRETE BLOCK PLANT IS COMPLETE Veyo,, our ,.odY Two-Wy 4 cansTcn-it), Si ze Masc hriquntc be-casi ouarek nth olncrchte building m~trate Ji~b leS I o itesttc oefeun al for cotecreto brIck by peopln who want concrete building materlal other than concrete blocks, .ThISis tS bern tac cjpereleuce cI mny O1 OUr cuonomers wit dId nut pouscs9 a good concrono brick nihlnel apd as they bad fr mahitig concrcen brieh they lost souse icrle and proiltaboi orders or concrete brick. We recommend that Ino he preparsd Ior such einergenclrs by powesaslg one of our Randy Two-Way Ten-rck Size stan THi about 30 pCN cool Bess then common clay brick about e5 per teat oiss than resued cla blch itahs bout 1 50 wOrth 01 material to niste m.8 uiet byers a, ndIt bii cos o, t .ar o n ortndy T'eo'W, Ten-lrirl Sloe bMchtine k St,20 per tOS0 brick, the mit 011,000 concret brich matt on the Reaody taeiine. lncluding materlal and laohr. ;ooulS he 0 E. The average cost Of ,omosnit cl, y orl' ; I d An. p .OU D 055 the avrergc oes 1 presase cisy or ck to 017.00 tier Ost. T~hese urcs. which are taken as an average, tout iii dltterent lorioltis. would matke the cels oh coct erto bric1 Ato per .000 less than common clay brick Fnd per 1,000 less than pressed clay brick.-,ses-UI Tln I:( IfNlalt when you buy our liand2o Tweo-tVay TeiwBe ek'S'iee llehine, thetiIs, a YOU RECEIVE TWO MACHINES IN O11NE II1 nlchtse that witi mahk bricks 0n i ther the faun down or face op principle. BrIcl; machines which are Id byotle e brick only one way,.either on the 10cc doen principle or I lae up prlo-elple, slid even tiers they ask over s c tho the price we ask fr our Rndy ToW ay Tes-Brlek ie aline. .fa .u pelts A PEFECTIMITTIONTHE QUALITY AND FINISH To',o-elindy Brick Site Machinea ins thn very beat,. ,very pcr-O F T HE F I NE ST .-. _ tit*anonctaetwit.ti the for*minrgej f thek bric"TITmulecud nod 'itltled ever plre0I teiuo PRESSED BRICK rsde on for tle di -ifion plates and ends are 01 tile =eotqusnlity r~andy Two WauesseekSzeaahsebcue n colred and better 'sOttei hnown, and they ground by Iod h ln.wf to d xc v is iniosnn oept dt! Y o- y Tca-Brick Size beccause yd)u can s.clo d a btes a o t macltne whe the hecs are ae on -the tace down prin.cpl,.. all. so In e r then e"kWEmtACEtsl as conceete blockho are made on orW .ard Coucreta B eok 't chnI,, .b ,j~*t-st any styles n rnitentol design brcheonbemodeont chi ne becauseItison and` bwllieao kt.llh thitso- , .P1 e.,ed heir.- r .t Jtlt dow prttteh .tie ous. 'in make a common concrete belck that Is not Aniseed on /TV W-. Sloe ...ln...-ts.pct toienrr toy ace ti ~~~~the Orst uteebn obtainable h vrosttoTwo-Wes 'renltr c S chtbe also b uol ththis c tee aro ed lor flhlla -I.

• nd form thatu to shape a .bi .inev -ac t dm n-h or the bulldhltg 01 hich walla or swile w~dth do sot retluie p Osnshed p eetue /

.' o, B ,. .. ..: 'ailI rns¢ tor that gsele thesnes cocrl brnc k: s aexa¢ d en-y tl it, I ' tbelch tk whaeh t e n d te ate m dlreeo sha p e t 4tqh e .Tb3 tplectto 01k mshi on ti hebric i ppncr pest eOutputhaeat 1.0 brc a I .., f[red leomrt-te "-elin ti ' ar 't.s "sitr aet"i r titn the tote dlowo prlnciple tray. be muse it l Ies co sor t tan t le race downo I. s'at l.sit alo aid tile. ede ore.. sheP an "d 50... O ddrly e n o rci the e torn iu e ...r to rte the bri=h. lite ..... SA A r E 1`o.. .. .en 5011odtat the~c mochie : HE o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ i tile eaito It -on' ' ..' .. n vey Otn fOu u ~ ~ gic Iid imt ee adeo the tac doses Epr, ne,p 11, g r .al bltt. sI ndy Tý e~'o y Te-Bikile __t oci aso inie trialLI fo omoton his ch ost whe Ru a. ""A",iydh.shid'sioniltets uie o ii'~~~~~~~~~~~~~~~~~ ~~~~~~~ 01,be padte risfrcm o brc adyoruttterot nu fntota il- dAys tril. yo d thesyreiosAre thatianed we iltdhe. 'Z v .toiled hi s ordth e ' tf c d o m sol a br ick w h en h c.or b ered IL ee I s rIcs .and he paid you or funt re bind y ou she h oney 'Im ld o r it..tolce she e w ith ihvr on op urt nU o c hire u.ui lty." "evei. thot in what yo wOul d have -dol sos , po'uasd the te l tuTMrIITIIT fofl T olo oi cour.l andy Tw0.W.c Ten'aBrITk SSAeE GUARAeTneu*cn s Oitd by [ome Others. beaus it. son id te one H1- the- teo princpes: hertoe 1 t# t *sl .i one -Iopperi;-one w olet.,':ono floa, :S one ntee ateiher i tie c ¢ U p O r y o, W o u l d h ov e ith wo n t i o i td le lc t mIeh t c os 0 0 l si e s t o ie n It e q u a l t o ta n tw o s ao urt w o o d ' t o t i o l a. Snhip p e d , i r t t th e f ac t o rey .n ' C , t tr n l tscoes n .. .-QT'y iiefourO ot NitatdyTwO-Feay Ten-Bri e R forclo... lomm in oeis inndy Two- .., e. 32r. i8to a Oriole.Stoenioc,,cumptete'w tbrriileroutiits.. lhll g stun S ie1line. you co Citan ordr toynv d1.v prectc orfor en uon hrems wointt. 440 oevfl5.. .Pe;ce ."... -.- .-..": ....I , 1 l f t' b el st y a n ti b ritk w h , e nw ie 'e .' ci i (b e pIn at e m n -i t u r it ch oo 'O. t h e I n Wrc on ii ,o l c e W i th W cl'.n t 2 'Up tt.'Wetl, tha is wht, iloesul hrit dol brie isc~. o y s ome t hol; rstt ,tult iss price a iced b' tie onie of l lit ay prihi p Ge J 2-l't1h .2 fac ..... r-.i ]1908 SEARS CATALOGUE 1': 2-50 YOU WILL HAVE NO TROUBLE IN DISPOSING enormously Ip-rge profits, because of arllstic desgns and the dence Is complete withou.t a. porch, and no concrete block plant is complete without our Unique Porch OuWt. Why not be UJl to dnle If you are a con*crete block manul. and com Jllete your liue by adding this big profit making outfit to your list? You will have to show the customer what you make bel ore he buys from you. Perhaps he think,; that such a complete and anislic line of porch matenals cannot be made 01 concrete? II so. it is up to you lngly)ow prices. .-.. . . .: .:. IE l S sl500 0 OUTFIT FOR s57 25 PRICE LIST OF UNIQUE OUTFJTS AND SEPARATE MOULDS,* No. 32K5830 lo-jnch Unique Porch Column. Picr RAiJ and Mould Outfit, complete. State deslcn wnnted. Shipping weight. 032 pound *. Pr)"" ..................................

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

$S7.25 . No. 32K583 t 12 .. lneh Unique Porc.h C<Jlumn, Pier R,ail and Bah.1slcl' Mould Outfit, complete. State :11e:slcn wll.Dt-C'd. Shipping weight, . 7.')7 pounds. .******.*.

t. 0 ***** 0 ** 0 *** 0 ***** 00 ***** 0 0 ************************************

0 ** 0 ****** ,$65.50 FOR lO-INCH COLUMN FOR 12-INCH COIXMN SEPARATE MOULDS WI. "" Wt. l'rlce '. CalA'ol!\lo No. tb'. Price No, tbs. ------O. O. Round Column Bnse Mould ****** , ... 32KS834 40 $ 04*.32 32K5844 GO S 5.18 CombinAtion Plllin and Fluted Column fltouJd t30 32K5845 165 13.40 Ornsmenfa I en]) Mould* (GoUde Or lODle) ** 0 80 10.35 (leSic'n 32K5837 70 8.30 32K5838 as 85 6.22 Pier Cap Mould (Platn or Egg and DElft) *** 0 32K5839 60 8.25 32K5849 75 S.4.§. -No. 32K5854 Porch BoHorn RAil hlou1d. Sblpp1ng welf:ht. 0, POUDW. Price ........ $5.22 !ij'.:'rW* 70 1.04 pouDl1S .. Prtco ........................................................................... 6.05 1908 SPARS CATALOGUE 3-1 ASSOCIATED PROPERTY TYPES I.

SUMMARY

OF SURVEY RESULTS The property type descriptions presented in this chapter are based on the results of the archaeological and architectural survey of Subsection E in Linn County. This study was grounded in the previous comprehensive planning project which identified four general eras of historic development and subcontexts related to that development. The survey examined approximately 2590 ac (1036 ha) and resulted in the recording of 55 archaeological and 115architectural properties (Figures 3-1 and 3-2). Of the archaeological sites, 41 represent farmstead or habitation sites, 6 are industrial sites, 2 represent transportation-relatedproperties, and 6 represent churches and schools. Of the architectural properties, 77 are located in the town of Palo, while 38 are rural properties. Time did not permit the examination of alternate Subsection S (or FI as it is designated in the SOW); however, the original boundaries of Subsection E were extended to the south three quarters of a mile in order to more fully assess the properties historically associated with the Palo vicinity.A total of 47 volunteers froni around Linn County participated in field survey, research, and labwork. They donated over 380 hours toward the completion of this project.Volunteers actively participated in both the archaeological and architectural field surveys and learned how to identify and record sites. A workshop was held at the outset of the project as part of the annual Linn County Historic Preservation Conference in August 1992. This workshop laid the groundwork for the training and participation of volunteers and was supplemented by hands-on activities conducted in the field between October 1992 and April 1993. An additional workshop was held in June 1993 and involved a presentation of the survey results.Only a few previous cultural resource investigations have been conducted in the project area, with no historic sites having been officially recorded in this area prior to the presentstudy. The major studies conducted in this area were those done by Michael Weichman in 1974 as part of the Cedar River Basin study and by Luther College in 1974-76 prior to the construction of the Pleasant Creek Lake impoundment and State Park. Both studies notedhistoric components associated with some of the prehistoric sites recorded; however, none of these components were documented in the official site records (Benn and Hovde 1976;Weichman 1974). The recent Linn County phase one comprehensive planning project (Rogers 1992) added the historic components to 13 of these sites as supplemental site records. Of the 13 sites, 10 were located in the present study area, and of these 10, at least seven have since been destroyed or inundated by the Pleasant Creek lake construction. The remainder were re-evaluated as part of the present investigation. The destroyed sites include sites 13LN27, 13LN29, 13LN33, 13LN35, 13LN37, 13LN39, and 13LN54. Inaddition, at least three other potential historic sites, not recorded during the 1974-76 studies, have also been inundated by the lake. Among these sites is the former location of the Lewis Bottoms Double Deck Schoolhouse. A more recent cultural resources investigation in the Fayette Township area was conductedby Michael Perry of the Office of the State Archaeologist in 1983 along County Road W36 for a road improvement project (Perry 1983). While that study did not officially record any; i ) I .l ,. , , , 3-1 3 ASSOCIATED PROPERTY TYPES I.

SUMMARY

OF SURVEY RESULTS The property type descriptions presented in this chapter are based on the results of the archaeological and architectural survey of Subsection E in Linn County. This study was grounded in the previous comprehensive planning project which identified four general eras of historic development and subcontexts related to that development The survey examined approximately 2590 ac (1036 ha) and resulted in the recording of 55 archaeological and 115 architectural properties (Figures 3-1 and 3-2). Of the archaeological sites, 41 represent fannstead or habitation sites, 6 are industrial sites, 2 represent transportation-related properties, and 6 represent churches and schools. Of the architectural properties, 77 are located in the town of Palo, while 38 are rural properties. Time did not pennit the examination of alternate Subsection S (or Fl as it is designated in the however, the original boundaries of Subsection E were extended to the south three quarters of a mile in order to more fully assess the properties historically associated with the Palo vicinity. A total of 47 volunteers froni around Linn County participated in field survey, research, and labwork. They donated over 380 hours toward the completion of this project Volunteers actively participated in both the archaeological and architectural field surveys and learned how to identify and record sites. A workshop was held at the outset of the project as part of the annual Linn County Historic Preservation Conference in August 1992. This workshop laid the groundwork for the training and participation of volunteers and was supplemented by hands-on activities conducted in the field between October 1992 and April 1993. An additional workshop was held in June 1993 and involved a ' presentation of the survey results. Only a few previous cultural resource investigations have been conducted in the project area, with no historic sites having been officially recorded in this area prior to the present study. The major studies conducted in this area were those done by Michael Weichman in 1974 as part of the Cedar River Basin study and by Luther College in 1974-76 prior to the construction of the Pleasant Creek Lake impoundment and State Parle. Both studies noted historic components associated with some of the prehistoric sites recorded; however, none of these components were documented in the official site records (Benn and Hovde Weichman 1974). The recent Linn County phase one comprehensive planning project (Rogers 1992) added the historic components to 13 of these sites as supplemental site records. Of the 13 sites, 10 were located in the present study area, and of these 10, at least seven have since been destroyed or inundated by the Pleasant Creek lake construction. The remainder were re-evaluated as part of the present investigation. The destroyed sites include sites 13LN27, 13LN29, 13LN33, 13LN35, 13LN37, 13LN39, and 13LN54. In addition, at least three other potential historic sites, not recorded during the 1974-76 studies, have also been inundated by the lake. Among these sites is the former location of the Lewis Bottoms Double Deck Schoolhouse. A more recent cultural resources investigation in the Fayette Township area was conducted by Michael Perry of the Office of the State Archaeologist in 1983 along County Road W36 for a road improvement project (perry 1983). While that study did not officially record any 3-2 historic sites, a farmstead site was noted near the project corridor but out of the right-of-way. That site was evaluated during the present investigation and was found to have been destroyed by bulldozing and excavation associated with the construction of a modem house in ,1983. Plate I in Appendix A is a historic photograph of the original house associated with this former farmstead site. The house had been built in 1856 and was the McClintock and later the Melton family home. It was abandoned and derelict by 1919 when the photograph in Plate 1 was taken.11. ARCHAEOLOGICAL PROPERTY TYPESThe following archaeological property types are based on the contexts presented in Chapter 2 and on the survey results:A. Sites Associated with Native American Contact Along the Cedar River The property types associated with Native American contact along the Cedar River are archaeological in nature and include the following potential site types: camp sites, burial grounds and individual burials, and maple sugaring sites. Such sites are expected in the proximity of the major river and creek valleys in Linn County and the project area, particularly on river terraces, blufftops overlooking the valleys, and within or near the areas that were timber-covered during the contact period. Because contact period Native American sites are not well documented, other than through largely anecdotal accounts in local and county history books of the area, sites associated with this context would be potentially significant under National Register Criterion D for their ability to yield information important in history. Of particular significance would be those sites that have the ability to yield information concerning the impact of Euro-American contact on NativeAmerican culture and how this is reflected in the archaeological record.The presence of the Mesquakie, and possibly the Winnebago, in the Fayette Township area has been documented in the early historical accounts given by the early settlers. Georgia Mills in her 1958 book entitled West of the River relates her family's experiences with theMesquakie, including clan chief Kennesaw. One passage noted that when John Mills (a.k.a. "John Brandon" in her narrative) and his family arrived at their cabin just southwest of Palo in 1852, there were "about three or four hundred Indians" of the Mesquakie tribe camped in the timber at the edge of which stood the Mills' cabin (Mills 1958:4). Relations with these Indians were friendly as were most of the contacts documented in the Linn County area. Two early house sites associated with John Mills were recording during the present survey and designated as sites 13LN332 and 13LN357 (see Figure 3-1). Whileboth sites have mid-Nineteenth Century archaeological components, map data suggest that site 13LN357 represents John Mills' first log cabin site, with site 13LN332 representing the family's second home, which was built between 1859-1869. Interestingly, the artifactassemblage collected from site 13LN332 contained Native American artifacts in the form of chert flakes. While there is some potential that these flakes were produced by the Mesquakies who camped in the vicinity, it is perhaps more likely that they were produced by prehistoric peoples who lived along Dry Creek.This points to the difficulty in positively identifying contact period sites. A further aspect of this problem is that a few of the mid-Nineteenth Century historic sites identified by the present study as Euro-American sites may, in fact, have been contact period Native American sites, which show little or no evidence of their traditional material culture but rather show a more complete assimilation into Euro-American material culture. Morecertain evidence of Native American contact sites would be found in artifact assemblages that included classic trade good items such as glass beads, copper beads and ornaments, 3-2 historic sites, a farmstead site was noted near the project corridor but out of the way. That site was evaluated during the present investigation and was found to have been destroyed by bulldozing and excavation associated with the construction of a modem in J 983. Plate 1 in Appendix A is a historic phOtograph of the original house associated with this fonner fannstead site. The house had been built in 1856 and was the McClintock and later the Melton family home. It was abandoned and derelict by 1919 when the photograph in Plate 1 was taken. H. ARCHAEOLOGICAL PROPERTY TYPES The follOwing archaeological propeny types are based on the contexts presented in Chapter. 2 and on the survey results: A. Sites Associated with Native American Contact Along the Cedar River 1be property types associated with Native American contact along the Cedar River are archaeological in nature and include the following potential site types: camp sites, burial grounds and individual burials, and maple sugaring sites. Such sites are expected in the proximity of the major river and creek valleys in Linn County and the project area, particularly on river terraces, bluff tops overlooking the valleys, and within or near the areas that were timber-covered during the contact period Because contact period Native American sites are not well documented, other than through largely anecdotal accounts in local and county history books of the area, sites associated with this context would be potentially significant under National Register Qiterion D for their ability to yield information important in history. Of particular significance would be those sites that have the ability to yield infonnation concerning the impact of Eum-American contact on Native American culture and how this is reflected in the archaeological record. The presence of the Mesquakie, and possibly the Winnebago, in the Fayette Township area has been documented in the early historical accounts given by the early settlers. Georgia Mills in her 1958 book entitled West of the River relates her family's experiences with the Mesquakie, including clan chief Kennesaw. One passage noted that when John Mills (a.lc.a "John Brandon" in her narrative) and his family anlved at their cabin just southwest of Palo in 1852, there were "about three or four hundred Indians" of the Mesquakie tribe camped in the timber at the edge of which stood the Mills' cabin (Mills 1958:4). Relations with these Indians were friendly as were most of the contacts documented in the Linn County area. Two early house sites associated with John Mills were recording during the present survey and designated as sites 13LN332 and 13LN357 (see Figure 3-1). While both sites have mid-Nineteenth Century archaeological components, map data suggest that site 13LN357 represents John Mills' ftrst log cabin site, with site 13LN332 representing the family's second home, which was built between 1859-1869. Interestingly, the artifact assemblage collected from site 13LN332 contained Native American artifacts in the form of chert flakes. While there is some potential that these flakes were produced by the Mesquakies who camped in the vicinity, it is perhaps more likely that they were produced by prehistoric peoples who lived along Dry Creek. . This points to the difficulty in positively identifying contact period sites. A further aspect of this problem is that a few of the mid-Nineteenth Century historic sites identified by the present study as Euro-American sites may, in fact, have been contact period Native American sites, which show little or no evidence of their traditional material culture but rather show a more complete assimilation into Eum-American material CUlture. More certain evidence of Native American contact sites would be found in artifact assemblages that included classic trade good items such as glass beads, copper beads and ornaments, 3-3 metal arrow points, and gun parts. Only one of the sites recorded during the present survey contains artifacts of these types consisting of a single brass rolled cone (possible"tinkling cone") found on site 13LN338. In addition, 22 of the 41 historic habitation sites recorded have artifact assemblages dating from the 1830s-I870s (Table 3-1), which corresponds to the Native American contact era in Linn County; however, the majority of these sites were found to have been associated with documented Euro-American settlement. Of the 22 mid- to late Nineteenth Century site assemblages, four also contained Native American artifacts in the form of chert flakes and include sites 13LN332, 13LN347, 13LN338, and 13LN378 (see Figure 3-1). At present, these chert flakes are considered evidence of prehistoric habitation; however, there is some potential that they were produced by historic Native groups camping in the vicinity of these early historic sites. The lithic items from site 13LN378 also included a stemmed projectile point base that dates from the prehistoric period; thus indicating a multi-component prehistoric/historic site rather than a contact period site. In addition, flakes were recovered from sites 13LN337 and 13LN377, the assemblages of which are primarily non-diagnostic historic items; thus precluding further identification of these sites as having possible contact period components. Three of the sites previously recorded in the Pleasant Creek Valley had been concluded to be potential proto-historic or early historic period Native American sites. These included sites 13LN33, 13LN37, and 13LN71 (Benn and Hovde 1976; Weichman 1974). Of these, site 13LN33 has been inundated by the lake construction and cannot be further investigated, while site 13LN37 appears to have been destroyed by construction associated with the park facilities. Site 13LN37 was noted as a "proto-historic" site on the state site record but with no indication as to why it was concluded to be such. Benn and Hovde (1976:35-36) described this site simply as aLate Woodland habitation site, rather than as a Late Prehistoric or Proto-Historic era site. Site 13LN7 1, on the other hand, was suspected to have a contact component due to the presence of a rolled copper cone, or "tinkling cone," which is commonly found on Native American contact sites as part of a trade good assemblage (Benn and Hovde 1976:68). The rolled copper cone recovered from Site 13LN338 is a suspected contact period item and was found with an assemblage that was mid-Nineteenth Century in date and included a chert flake. However, the location of this site along Bear Creek also suggests a high potential for prehistoric habitation sites as well, thus precluding further speculation into the association of the chert flake and the copper cone at this time. Site 13LN71 was re-examined in September of 1993 and found to contain primarily prehistoric material, with only two historic items noted, an undecorated Whiteware rimsherd and a piece of non-diagnostic bottle glass. This assemblage was left at the site location and appears to indicate a multi-component prehistoric/historic site with no indication of a contact period component. Site 13LN33 was speculated to have been an early contact site because of the presence of an early bottle glass fragment that exhibits retouch similar to that found on lithic tools (Benn and Hovde 1976:28-29). Interestingly, two sites in the present study (13LN332 and 13LN363) contained early bottle glass (one piece per site) which exhibit retouch. In the case of 13LN332, this site contains a mid- to late Nineteenth Century assemblage as well as chert flakes, with the retouched glass perhaps lending some credence to a possible Native American contact period component. Site 13LN363, on the other hand, is predominantly a late Nineteenth-early Twentieth Century historic site with no chert flakes, although it is located near the Cedar River in an area that would have been potentially visited by Native Americans during the early historic period. While the present investigation found only tenuous evidence of contact period Native American sites, the potential still remains high for the presence of these sites in the Fayette Township area. It is suspected that the majority will be found in a buried context along the Cedar River Valley floodplain or in colluvial/alluvial footslope/fan positions and will f ! metal arrow points, and gun parts. Only one of the sites recorded during the present survey contains artifacts of these types consisting of a single brass rolled cone (possible "tinkling cone") found on site 13LN338. In addition, 22 of the 41 historic habitation sites recorded have artifact assemblages dating from the 18308-1870s (Table 3-1), which corresponds to the Native American contact era in Linn County; however, the majority of these sites were found to have been associated with documented Eum-American settlement. Of the 22 mid-: to late Nineteenth Century site assemblages, four also contained Native American artifacts in the fonn of chert flakes and include sites 13LN332, 13LN347, 13LN338, and 13LN378 (see Figure 3-1). At present, these chert flakes are considered evidence of prehistoric habitation; however, there is some potential that they were produced ' by historic Native groups camping in the vicinity of these early historic sites. The lithic items from site 13LN378 also included a stemmed projectile point base that dates from the prehistoric period; thus indicating a multi-component prehistoric/historic site rather than a contact period site. [n addition, flakes were recovered from sites 13LN337 and 13LN377, the assemblages of which are primarily non-diagnostic historic items; thus precluding further identification of these sites as having possible contact period components. Three of the sites previously recorded in the Pleasant Creek Valley had been concluded to be potential proto-historic or early historic period Native American sites. 1bese included sites 13LN33, 13LN37, and 13LN71 (Benn and Hovde 1976; Weichman 1974). Of these, site 13LN33 has been inundated by the lake construction and cannot be fmther investigated, while site 13LN37 appears to have been destroyed by construction associated with the park facilities. Site 13LN37 was noted as a "proto-historic" site on the state site record but with no indication as to why it was concluded to be such. Benn and Hovde (1976:35-36) described this site simply as a Late Woodland habitation site, rather than as a Late Prehistoric or Proto-Historic era site. Site 13LN71, on the other hand, was suspected to have a contact component due to the presence of a rolled copper cone, or "tinkling cone," which is connnonly found on Native American contact sites as part of a trade good assemblage (Benn and Hovde 1976:68). The rolled copper cone recovered from Site 13LN338 is a suspected contact period item and was found with an assemblage that was mid-Nineteenth Century in date and included a chert flake. However, the location of this site along Bear Creek also suggests a high potential for prehistoric habitation sites as well, thus precluding further speculation into the association of the chert flake and the copper cone at this time. Site 13LN71 was re-examined in September of 1993 and found to contain primarily prehistoric material, with only two historic items noted, an undecorated Whiteware rimsherd and a piece of non-diagnostic bottle glass. This assemblage was left at the site location and appears to indicate a multi-component prehistoric/historic site with no indication of a contact period component Site 13LN33 was speculated to have been an early contact site because of the presence of an early bottle glass fragment that exhibits retouch similar to that found on lithic tools (Benn and Hovde 1976:28-29). Interestingly, two sites in the present study (l3LN332 and 13LN363) contained early bottle glass (one piece per site) which exhibit retouch. In the case of 13LN332, this site contains a mid-to late Nineteenth Century assemblage as well as chert flakes, with the retouched glass perhaps lending some credence to a possible Native American contact period component. Site 13LN363, on the other hand, is predominantly a late Nineteenth-early Twentieth Century historic site with no chert flakes, although it is located near the Cedar River in an area that would have been potentially visited by Native Americans during the early historic period. While the present investigation found only tenuous evidence of contact period Native American sites, the potential still remains high for the presence of these sites in the Fayette Township area. It is suspected that the majority will be found in a buried context along the Cedar River Valley floodplain or in colluvia1/alluvial footslope/fan positions and will 3-4 require more intensive field methodology in order to locate and evaluate these sites. Such an effort is beyond the scope of the present investigation. It is noted herein to alert future investigations in the project area to the possibility that such sites may be encountered in a buried context and should be a concern for construction projects on the floodplain and the terraces and alluvial fans at the footslope of the Cedar River bluffs. These potential areas for buried sites are indicated on Figure 3-3. Furthermore, it should be noted that the present investigation could not cover every inch of ground in the study area and that additional historic period sites, potentially including Native American contact sites, will be found in both a surface and subsurface context.Because of the rarity of Native American contact sites in the archaeological record of Iowa, the registration requirements for such sites should allow for marginal integrity situations. However, the site deposit would still have to be able to yield significant data concerning the contact period occupation in order to be considered National Register eligible. The less impacted the site deposit, the higher the degree of integrity and the greater the eligibility potential for the National Register.B. Sites Associated with Early Settlement of Fayette Township.The property types associated with the early settlement of Fayette Township include both archaeological and architectural properties. This section will deal with the archaeologicalremains, which include the following potential site types: habitation sites, farmstead sites, early industrial and institutional sites, and transportation-related sites. The industrial, institutional, and transportation sites will be discussed below under those separate sections, with the following discussion focusing on the habitation and farmstead sites representing the early settlement period. Such sites are expected to occur over virtually the entire project area but particularly in those areas that were at or near the forest-prairie margins during the early settlement period. The period of significance for this period is between 1839-1869 as determined by the first permanent Euro-American settlement and the arrival of the railroadinto Fayette Township. This period differs slightly from the Early Settlement Era previously defined for the entire county and dating from 1837-1859. It is expected that theearly settlement period of significance will be slightly different for other areas of Linn County as well.Early settlement period archaeological sites are primarily eligible under Criterion D, although there will be some sites that will achieve significance under Criteria A, B, or even C if they have substantial structural remains of importance. The significance of early settlement period sites lies in their importance to the establishment and early growth of the township and county and in their ability to provide a clearer picture of frontier life and material culture than can be provided by historical accounts and legal records.A total of 22 early settlement period archaeological sites was recorded by the present investigation and includes sites 13LN332, 13LN338, 13LN341, 13LN343, 13LN345, 13LN346, 13LN347, 13LN349, 13LN351, 13LN352, 13LN353, 13LN354, 13LN355, 13LN357, 13LN361, 13LN362, 13LN367, 13LN368, 13LN369, 13LN370, 13LN375, and 13LN378 (see Figure 3-1 and Table 3-1). These sites are all historic habitation sites that likely functioned as farmsteads. Some sites, such as site 13LN332, had evidence of support structures while the majority primarily represented the house or cabin location.Twenty-one of these sites have artifact assemblages that are either entirely mid-Nineteenth Century in temporal range or have substantial mid-Nineteenth Century components. The remaining site had a non-diagnostic assemblage and was identified as an early settlement era site from historic map and other data. Based on the recovered artifact assemblages from the 22 sites, 14 were occupied only during the mid- to late Nineteenth Century, while the remainder were occupied into the late Nineteenth Century. These sites were located 3-4 require more intensive field methodology in order to locate and evaluate these sites. Such an effort is beyond the scope of the present investigation. It is noted herein to alert futw"e investigations in the project area to the possibility that such sites may be encountered in a btnied context and should be a concern for construction projects on the floodplain and the terraces and alluvial fans at the footslope of the Cedar River bluffs. These potential areas for buried sites are indicated on Figure 3-3. Furthermore, it should be noted that the present investigation could not cover every inch of ground in the study area and that additional historic period sites, potentially including Native American contact sites, will be found in both a surface and subsurface context. Because of the rarity of Native American contact sites in the archaeological record of Iowa, the registration requirements for such sites should allow for marginal integrity situations. However, the site deposit would still have to be able to yield significant data concerning the contact period occupation in order to be considered National Register eligible. The less impacted the site deposit, the higher the degree of integrity and the greater the eligibility potential for the National Register. B. Sites Associated with Early Settlement of Fayette Township The property types associated with the early settlement 'of Fayette Township include both archaeological and properties. This section will deal with the archaeological remains, which include the following potential site types: habitation sites, farmstead sites, early industrial and institutional sites, and transportation-related sites. The industrial, institutional, and transportation sites will be discussed below under those separate sections, with the following discussion focusing on the habitation and farmstead sites representing the early settlement period. Such sites are expected to occur over virtually the entire project area but particularly in those areas that were at or near the forest-prairie margins during the early settlement period. The period of significance for this period is between 1839-1869 as detennined by the first permanent Euro-American settlement and the arrival of the railroad into Fayette Township. This period differs slightly from the Early Settlement Era previously defined for the entire county and dating from 1837-1859. It is expected that the early settlement period of significance will be slightly different for other areas of Linn County as well. Early settlement period archaeological sites are primarily eligible under Criterion D, although there will be some sites that will achieve significance under Criteria A, B, or even C if they have substantial structural remains of importance. The significance of early . settlement period sites lies in their importance to the establishment and early growth of the township and county and in their ability to provide a clearer picture of frontier life and material culture than can be provided by historical accounts and legal records. A total of 22 early settlement period archaeological sites was recorded by the present investigation and includes sites 13LN332, 13LN338, 13LN341, 13LN343, 13LN345, 13LN346, 13LN347, 13LN349, 13LN351. 13LN352, 13LN353, 13LN354, 13LN355. 13LN357, 13LN361, 13LN362, 13LN367, 13LN368, 13LN369. 13LN370, 13LN375, and 13LN378 (see Figure 3-1 and Table 3-1). These sites are all historic habitation sites' that likely functioned as farmsteads. Some sites, such as site 13LN332, had evidence of support structures while the majority primarily represented the house or cabin location. Twenty-one of these sites have artifact assemblages that are either entirely mid-Nineteenth Century in temporal range or have substantial mid-Nineteenth Century components. The remaining site had a non-diagnostic assemblage and was identified as an early settlement era site from historic map and other data. Based on the recovered artifact assemblages from the 22 sites, 14 were occupied only during the mid-to late Nineteenth Century, while the remainder were occupied into the late Nineteenth Century. These sites were located 3-5 through a combination of historic map data and oral history informant data. The majority were represented on either or both the 1859 and 1869 maps (Table 3-2), with only site 13LN367 not represented on any of the available maps.Of the potential house sites represented on the historic maps, 19 were found to have extant farmsteads (recorded during the architectural survey) and 5 have been destroyed either by extensive bulldozing or modern house and other types of construction. Several sites shown on the historic maps were found to have no archaeological remains despite good field conditions, no potential for buried deposits, and intensive survey. These "missing" sites may have been incorrectly located on the original maps or may have been short-term occupations that left little in the way of archaeological remains. The maps, however, proved to be an invaluable tool in locating early settlement era sites and were generally fairly accurate in their representations, although a number of archaeological sites were found to be in the proximity of their map representations rather than at the exact spot on the map.The artifact assemblages from these sites (Table 3-3; see also Appendix B) comprise aninteresting collection of decorated earthenwares and regionally manufactured stonewares that will provide an important data base for ceramic research in the county but will alsohave applications to studies at the state and regional levels. Plates 2-22 in Appendix A show representative diagnostic items from these early assemblages. As can be seen, the commonly recurring earthenware decorative types are shell edge, transfer printed, polychrorne floral handpainted, sponge stamped and textured, annular, flow blue handpainted, and flow blue transfer printed Pearlwares and Whitewares. Ironstone was either undecorated or exhibited mold-decorated patterns and were of a variety that George NMiller (1987) categorizes as "Provincial Blue" Ironstones. In general, these ceramic assemblages have a temporal range of 1820, or earlier, into the 1880s or 90s; however, taken as a whole, and in association with the pre-1870 bottle glass found on these sites, they represent a predominantly mid-Nineteenth Century ceramic assemblage with none of the definite late nineteenth to Twentieth Century ceramics, such as decalcomania, gilded, and mold-decorated Whitewares, present.Other mid-Nineteenth Century artifacts found on these sites include blowpipe and glass-tipped pontil marked bottle bases, Lacy-patterned pressed glass tablewares, early moldblown figural flask fragments, applied-tooled and folded bottle lip/necks, and kaolin or ball clay pipes (see Plates 5, 11, 12, 16, 17, 20, and 22, Appendix A). The glass, in particular, has a temporal range confined to the mid-Nineteenth Century, with most diagnostic glass items on these sites having a pre-1870s origin.Other artifacts of note include the limestone and brick fragments observed and recovered from many of these sites. The brick was generally of soft-mud handmade manufacture and exhibited either sandstruck or waterstruck finishes, while the limestone was of local originand often showed evidence of burning. Limestone was generally present in greater concentrations than brick suggesting that the building foundations were of stone, while the chimneys were of brick. The presence of burned limestone suggests that either the houses were burned down or that some of the chimneys or hearths were constructed of stone.Of the artifacts recovered from these early settlement sites, those with perhaps the greatest research potential are the stonewares and utilitarian earthenwares, which include a sizeable assemblage of what is commonly termed Redware and exhibiting both clear lead and dark brown manganese glazes. The stonewares are of particular interest because the majorityappear to have been manufactured locally or regionally and are predominated by what would commonly be termed as "seconds," or wares that have imperfections and defects thatwould have lowered their cost to the consumer. These defects include uneven glazes, r**f: r I' . )' I, I' " 3-5 through a combination of historic map data and oral history informant data. The majority were represented on either or both the 1859 and 1869 maps (Table 3-2), with only site 13LN367 not represented on any of the available maps. Of the potential house sites represented on the historic maps, 19 were' found to have extant fannsteads (recorded during the architectural survey) and 5 have been destroyed either by extensive bulldozing or modem house and other types of construction. Several sites shown on the historic maps were found to have no archaeological remains despite good field conditions, no potential for buried deposits, and intensive survey. These "missing" sites may have been incorrectly located on the original maps or may have been short-tem1 occupations that left little in the way of archaeological remains. TIle maps, however, proved to be an invaluable tool in locating early settlement era sites and were generally fairly accurate in their representations, although a number of archaeological sites were found to be in the proximity of their map representations rather than at the exact spot on the map. The artifact assemblages from these sites (Table 3-3; see also Appendix B) comprise an interesting collection of decorated earthenwares and regionally manufactured stonewares that will provide an important data base for ceramic research in the county but will also have applications to studies at the state and regional levels. Plates 2-22 in Appendix A show representative diagnostic items from these early assemblages. As can be seen, the commonly recurring earthenware decorative types are shell edge, transfer printed. polychrome floral handpainted, sponge stamped and textured, annular, flow blue handpainted. and flow blue transfer printed Pearl wares and Whitewares. Ironstone was either undecorated or exhibited mold-decorated patterns and were of a variety that George Miller (1987) categorizes as "Provincial Blue" Ironstones. In general, these ceramic assemblages have a temporal range of 1820, or earlier, into the 18805 or 90s; however, taken as a whole, and in association with the pre-1870 bottle glass found on these sites, they represent a predominantly mid-Nineteenth Century ceramic assemblage with none of the definite late nineteenth to Twentieth Century ceramics, such as decalcomania, gilded. and mold-decorated Whitewares, present. Other mid-Nineteenth Century artifacts found on these sites include blowpipe and tipped pontil marked bottle bases, Lacy-patterned pressed g1ass tablewares, early moldblown figural flask fragments, applied-tooled and folded bottle lip/necks, and kaolin or ball clay pipes (see Plates 5, 11, 12, 16, 17,20, and 22, Appendix A). The glass, in particular, has a temporal range confmed to the mid-Nineteenth Century, with most diagnostic g1ass items on these sites having a pre-1870s origin. Other artifacts of note include the limestone and brick fragments observed and recovered from many of these sites. The brick was generally of soft-mud handmade manufacture and exhibited either sandstruck or waterstruck finishes, while the limestone was of local origin and often showed evidence of burning. Limestone was generally present in greater concentrations than brick suggesting that the building foundations were of stone, while the chimneys were of brick. The presence of burned limestone suggests that either the houses were burned down or that some of the chimneys or hearths were constructed of stone. Of the artifacts recovered from these early settlement sites, those with perhaps the greatest research potential are the stonewares and utilitarian earthenwares, which include a sizeable assemblage of what is commonly tenned Redware and exhibiting both clear lead and dark brown manganese glazes. The stonewares are of particular interest because the majority appear to have been manufactured locally or regionally and are predominated by what would commonly be tenned as "seconds," or wares that have imperfections and defects that would have lowered their cost to the consumer. These defects include uneven glazes, 3-6 overfiring, and indentations that would have occurred during the manufacturing process (see Plates 2, 3, 10, 14, and 15, Appendix A). These wares were likely sold to the occupants of these sites by traveling peddlers. Of the 22 early settlement sites, 12 have stoneware assemblages characterized by seconds, while the remainder with stoneware present (n= 7; Table 3-3) have assemblages of a higher, retail grade indicating differences in personal preferences, a higher economic level, or differential access to better grades of stonewares. At present, the origin of the stonewares recovered from these sites is unknown; they may have been manufactured in Cedar Rapids or upriver in Waterloo or Cedar Falls. A further possibility is that they were brought in overland from other potterycenters in eastern or central Iowa. There were no documented potteries in Fayette Township.As for the location of the early settlement period sites, five of the 14 sites occupied only during the mid-19th century were subsequently abandoned because they were positioned too far away from the road system as it developed in the late Nineteenth Century. As a result, the farmsteads associated with these properties were relocated along the new roadways, with the earlier house sites abandoned. In addition, five of the eight sites occupied in the mid- to late Nineteenth Century but abandoned by the Twentieth Century were also located off the developing road system, with the occupations then moved to moreaccessible locations. Several sites may also have been abandoned because they were originally oriented to the river and the steamboat travel and had to relocate once river travelceased to be of importance. Another reason for early settlement period site abandonment was likely due to the trend towards larger farms in the late Nineteenth to Twentieth Centuries, with the earlier homestead absorbed into larger farms that had the farmstead located elsewhere on theproperty. Flooding may also have been a factor in some site abandonment on those sites located on the low terraces of the Cedar River floodplain and along its tributary creeks.The potential exists for early settlement period archaeological sites within and associated with the town of Palo. While several architectural properties dating from this period are extant and were recorded during this survey, no archaeological sites were recorded. One potential site, the former location of the stagecoach barn, appears to have been destroyed by modem construction. Despite the lack of recorded archaeological sites for this period in Palo, future investigations in this area should note that the potential still exists but was difficult to assess during the present survey because the site locations were in maintained yard areas with no surface visibility. The early settlement of Fayette Township appears to have been little influenced by ethnicity; rather, the guiding influence in early settlement appears to have been regional in nature with the primary states of origin having been in the Old Northwest and along the Eastern seaboard. While there were no ethnic enclaves, there was at least one neighborhood settlement that was formed when one family and their relatives and friends migrated from Ohio and settled in Fayette Township. This was the Lewis family for whom the LewisBottoms neighborhood is named and who are still represented among the landowners and residents of this township. Of the early settlement sites recorded, one habitation site (site 13LN375), one church site (site 13LN374), and two industrial sites (13LN333 and 13LN334) were associated directly with the Lewis family, while others (13LN347 and 13LN349 as well as potentially associated later sites 13LN365, 13LN366, 13LN373,13LN386, and 13LN336) were probably associated with Lewis family relations including in-laws, cousins, and friends. However, it remains for future intensive research of these sites to identify all of the Lewis family associated sites. Site 13LN375 is reportedly the"original" Thomas Lewis cabin site and it does have a mid-Nineteenth Century assemblage component; however, map data suggest that this was the second Thomas Lewis house site;the first having been located further to the southwest in an area that has since been 3-6 overfuing, and indentations that would have occurred during the manufacturing process (see Plates 2. 3, 10. 14, and 15, Appendix A). These wares were likely sold to the occupants of these sites by traveling peddlers. Of the 22 early settlement sites, 12 have stoneware assemblages characterized by seconds, while the remainder with stoneware present (n= 7; Table 3-3) have assemblages of a higher, retail grade indicating differences in personal preferences, a higher economic level, or differential access to better grades of stonewares. At present, the origin of the stonewares recovered from these sites is unknown; they may have been manufactured in Cedar Rapids or upriver in Waterloo or Cedar Falls. A further possibility is that they were brought in overland from other pottery centers in eastern or central Iowa. There were no documented potteries in Fayette Township. As for the location of the early settlement period sites, five of the 14 sites occupied only during the mid-19th century were subsequently abandoned because they were positioned too far away from the road system as it developed in the late Nineteenth Century. As a result, the farmsteads associated with these properties were relocated along the new roadways, with the earlier house sites abandoned. In addition, five of the eight sites occupied in the mid-to late Nineteenth Century but abandoned by the Twentieth Century were also located off the developing road system, with the occupations then moved to more accessible locations. Several sites may also have been abandoned because they were originally oriented to the river and the steamboat travel and had to relocate once river travel ceased to be of importance. Another reason for early settlement period site abandonment was likely due to the trend towards larger farms in the late Nineteenth to Twentieth Centuries, with the earlier homestead absorbed into larger farms that had the fannstead located elsewhere on theproperty. Flooding may also have been a factor in some site abandonment on those sites located on the low terraces of the Cedar River floodplain and along its tributary creeks. The potential exists for early settlement period archaeological sites within and associated with the town of Palo. While several architectural properties dating from this period are extant and were recorded during this survey, no archaeological sites were recorded. One potential site, the former location of the stagecoach barn, appears to have been destroyed by modern construction. Despite the lack of recorded archaeological sites for this period in Palo, future investigations in this area should note that the potential still exists but was difficult to assess during the present survey because the site locations were in maintained yard areas with no surface visibility. The early settlement of Fayette Township appears to have been little influenced by ethnicity; rather, the guiding influence in early settlement appears to have been regional in nature with the primary states of origin having been in the Old Northwest and along the Eastern seaboard. While there were no ethnic enclaves, there was at least one neighborhood settlement that was fonned when one family and their relatives and friends migrated from Ohio and settled in Fayette Township. This was the Lewis family for whom the Lewis Bottoms neighborhood is named and who are still represented among the landowners and residents of this township. Of the early settlement sites recorded, one habitation site (site 13LN375), one church site (site 13LN374), and two industrial sites (13LN333 and 13LN334) were associated directly with the Lewis family, while others (13LN347 and 13LN349 as well as potentially associated later sites 13LN365, 13LN366, 13LN373, 13LN386, and 13LN336) were probably associated with Lewis family relations including in-laws, cousins, and friends. However, it remains for future intensive research of these sites to identify all of the Lewis family associated sites. Site 13LN375 is reportedly the "original" Thomas Lewis cabin site and it does have a mid-Nineteenth Century assemblage component; however, map data suggest that this was the second Thomas Lewis house site; the first having been located further to the southwest in an area that has since been 3-7 destroyed by road construction (see Figures 3-1, 2-1, and 2-2). Site 13LN375 is represented on the 1869 map but not on the 1859 map. Descendants of the original settlers, however, view site 13LN375 as the original cabin site (Tom Lewis, personal communication 1993), therefore, this too remains for future intensive archival and archaeological investigation to clarify.Registration requirements for early settlement period sites should be based on archaeological integrity, with the more significant and eligible sites being those that have discrete, low-impacted deposits dating from the early settlement period. Of the 22 sites recorded in Fayette Township, 13 initially meet this requirement. These sites will require Phase II level subsurface testing to determine if they have substantial sub-plow zone deposits and features before a final determination of eligibility can be made; however, such testing should not be considered a high priority unless the sites are threatened by construction projects or other destructive activities, or if the property owners desire that the sites be nominated. C. Sites Associated with the Agricultural Development of Fayette Township The property types associated with the agricultural development of Fayette Township include sites also associated with the early settlement period since the majority of those sites functioned as farmsteads. The agricultural development is represented by both archaeological and architectural properties; however, this section will deal only with the archaeological remains, which include the following potential site types: farmsteads, isolated agricultural buildings, and commercial and industrial properties associated with agriculture such as gristmills, creameries, and grain elevators. It is expected that the majority of rural historic sites encountered in Fayette Township and Linn County as a whole will be agricultural in nature and association. The period of significance for this context is from 1839-1942+ in Fayette Township and slightly earlier for other areas of the county.Sites associated with this context could be significant under Criteria A, B, C, or D, although the majority of the archaeological sites would be eligible under Criterion D. The significance of these sites would be in their ability to yield important data concerning the evolution of agriculture in the township and county and the nature of the settlement patterns, farmstead layouts, and material culture associated with this evolution. Sites would not have to be representative of the whole spectrum of change in order to beconsidered significant. Registration requirements should be based on the integrity of the archaeological deposits, with the more significant sites having discrete, low-impacteddeposits or features associated with one or more stages of agricultural development. A site that was occupied over the full period of significance but which has archaeological deposits that were adversely impacted by the more recent occupations will have less research potential and therefore less significance than a site that has intact earlier features as well as later features. At present, 20 of the 42 sites recorded in association with this context during the present investigation potentially meet these requirements and would require Phase II testing if the sites were threatened by construction projects, or the property owners request that they be nominated (Table 3-1).Of the 42 recorded sites, 41 rural are habitation or farmstead sites and one is a gristmill site that will be discussed in Section D. The 41 farmstead sites include the 22 already noted in Section C as well as sites 13LN335, 13LN337, 13LN339, 13LN340, 13LN344,13LN358, 13LN360, 13LN363, 13LN364, 13LN365, 13LN366, 13LN371, 13LN372, 13LN373, 13LN376, 13LN377, 13LN379, 13LN385, and 13LN386 (see Figure 3-1). Of the 41 farmstead sites, 14 were occupied only during the early settlement period, 13 were occupied from the early settlement period into the late Nineteenth Century, and 14 were 3-7 destroyed by road construction (see Figures 3-1, 2-1, and 2-2). Site 13LN375 is represented on the 1869 map but not on the 1859 map. Descendants of the original settlers, however, view site 13LN375 as the original cabin site (Tom Lewis, personal communication 1993), therefore, this too remains for future intensive archival and archaeological investigation to clarify. Registration requirements for early settlement period sites should be based on archaeological integrity, with the more significant and eligible sites being those that have discrete, low-impacted deposits dating from the early settlement period. Of the 22 sites recorded in Fayette Township, 13 initially meet this requirement. These sites will require Phase n level subswface testing to detennine if they have substantial sub-plow zone deposits and features before a final detennination of eligibility can be made; however, such testing should not be considered a high priority unless the sites are threatened by construction projects or other destructive activities, or if the property owners desire that the sites be nominated. C. Sites Associated with the Agricultural Development of Fayette Township The property types associated with the agricultural development of Fayette Township include sites also associated with the early settlement period since the majority of those sites functioned as farmsteads. The agricultural development is represented by both archaeological and architectural properties; however, this section will deal only with the archaeological remains, which include the following potential site types: farmsteads, isolated agriCUltural buildings, and commercial and industrial properties associated with agriCUlture such as gristmills, creameries, and grain elevators. It is expected that the majority of rural historic sites encountered in Fayette Township and Linn County as a whole will be agricultural in nature and association. The period of significance for this context is from 1839-1942+ in Fayette Township and slighdy earlier for other areas of the county. Sites associated with this context could be significant under Criteria A, B, C, or D, although the majority of the archaeological sites would be eligible under Criterion D. The significance of these sites would be in their ability to yield important data concerning the evolution of agriculture in the township and county and the nature of the settlement patterns, fannstead layouts, and material culture associated with this evolution. Sites would not have to be representative of the whole spectrum of change in order to be considered significant Registration requirements should be based on the integrity of the archaeological deposits, with the more significant sites having discrete, low-impacted deposits or features associated with one or more stages of agricultural development. A site that was occupied over the full period of significance but which has archaeological deposits that were adversely impacted by the more recent occupations will have less research potential and therefore less significance than a site that has intact earlier features as well as later features. At present, 20 of the 42 sites recorded in association with this context during the present investigation potentially meet these requirements and would require Phase II testing if the sites were threatened by construction projects, or the property owners request that they be nominated (Table 3-1). Of the 42 recorded sites, 41 rural are habitation or farmstead. sites and one is a gristmill site that will be discussed in Section D. The 41 fannstead sites include the 22 already noted in Section C as well as sites 13LN335, 13LN337, 13LN339, 13LN340, 13LN344. I3LN358, 13LN360, 13LN363, 13LN364, 13LN365, l3LN366, 13LN371, 13LN372, 13LN373. 13LN376, 13LN377, 13LN379, 13LN385, and 13LN386 (see Figure 3-1). Of the 41 fannstead sites, 14 were occupied only during the early settlement period, 13 were occupied from the early settlement period into the late Nineteenth Centmy, and 14 were 3-8 occupied in the late Nineteenth to early or mid-Twentieth Centuries. Representative artifacts from these later sites are shown in Plates 23-25 in Appendix A, while all recovered artifacts are described in Appendix B and summarized in Table 3-3.A total of 11 sites had intact foundation remains of brick, limestone, and concrete construction, although limestone was the most common foundation type present (Table 3-1). One site (13LN364) had more than one foundation of differing age and type whichincluded a limestone barn foundation and a concrete pad outbuilding foundation of a more recent age. Only sites I3LN339 and 13LN344 had extant buildings on the sites associatedwith the historic farmstead occupations, while sites 13LN385 and 13LN386 consisted of historic farmhouse foundations located in the frontyards of modem houses (see Figure 3-J 1).Figure 3-1 shows the location of farmsteads that are extant, have been destroyed, or are represented by archaeological sites. All of the extant farmsteads which contain pre-1942 buildings were recorded during the architectural survey (see Section III of this chapter). Ofthe archaeological sites, at least 25 represent farmsteads that were generally abandoned inthe late Nineteenth Century due to the changing road system and/or to the evolution towards larger and fewer farms, a pattern which continues to the present day.D. Sites Associated with Industrial Development of Fayette Township The property types associated with the industrial development of Fayette Township are represented by both archaeological and architectural properties, with the archaeological sites discussed in this section. Potential site types include: mill sites and associated features such as dams and mill ponds and races; limestone quarries and kilns; brickyards; and concrete block manufactories. The period of significance for this context is from 1839-1942+ in Fayette Township, with some properties also associated with other contexts suchas early settlement and agricultural development. Sites associated with the industrial context could be significant under Criteria A, B, C, or D. Industrial sites would be significant for the information they can provide concerning the development and growth of the township and county, the nature of these industries through time, and for their associations with persons significant in the industrial development of towns and rural communities. Registration requirements should be based on archaeological integrity, with the more significant sites being those that represent industries that were integral to the growth of a community or rural area and have archaeological and/or structural remains that are well preserved and represent the time period when that industry was important. Comparisons with other sites of this type should also be used to determine relative degrees of integrity and significance. Of the six archaeological sites recorded in Fayette Township related to industrial development, only two potentially meet these requirements. These include a quarry (site 13LN381) and potential sawmill site (13LN336) in the northern part of Fayette Township (see Figure 3-1). Both sites will require a more intensive examination before a final determination can be made but neither is threatened by construction or other activities at the present time.The six industrial-related sites recorded during the present investigation include the Lewis Gristmill site (13LN333), a possible sawmill site in the Katieville vicinity (13LN336), and four limestone quarries (13LN334, 13LN381, 13LN382, and 13LN383) (see Figure 3-1).Of the latter, site 13LN381 appears to have the greatest integrity because it represents an early quarry and potential limekiln operation that was not quarried extensively in the Twentieth Century. The other quarries have all been adversely impacted by relatively recent quarrying activities related to the production of crushed rock for road construction(Plate 26, Appendix A) as opposed to quarries used exclusively for building stone or early lime burning operations. l l < 3-8 occupied in the late Nineteenth to early or mid-Twentieth Centuries. Representative artifacts from these later sites are shown in Plates 23-25 in Appendix A, while all recovered artifacts are descriped in Appendix B and summarized in Table 3-3. A total of 11 sites had intact foundation remains of brick, limestone, and concrete construction, although limestone was the most common foundation type present (Table 3-1). One site (13LN364) had more than one foundation of differing age and type which included a limestone bam foundation and a concrete pad outbuilding foundation of a more recent age. Only sites 13LN339 and 13LN344 had extant buildings on the sites associated with the historic fannstead occupations, while sites 13LN385 and 13LN386 consisted of historic farmhouse foundations located in the frontyards of modem houses (see Figure 3-1). . Figure 3-1 shows the location of fannsteads that are extant, have been or are represented by archaeological sites. All of the extant farmsteads which contain pre-1942 buildings were recorded during the architectural survey (see Section III of this chapter). Of the archaeological sites, at least 25 represent farmsteads that were generally abandoned in the late Nineteenth Century due to the changing road system and/or to the evolution towards larger and fewer farms, a pattern which continues to the present day. D. Sites Associated with Industrial Development of Fayette Township The propeny types associated with the industrial development of Fayette Township are represented by both archaeological and architectural properties, with the archaeological sites discussed in this section. Potential site types include: mill sites and associated features such as darns and mill ponds and races; limestone quarries and kilns; brickyards; and concrete block manufactories. The period of significance for this context is from 1839-1942+ in Fayette Township, with some properties also associated with other contexts such as early settlement and agricultural development. Sites associated with the industrial context could be significant under Criteria A, B, C, or D. Industrial sites would be significant for the information they can provide concerning the development and growth of the township and county, the nature of these industries through time, and for their associations with persons significant in the industrial development of towns and nrral communities. Registration requirements should be based on archaeological integrity. with the more significant sites being those that represent industries that were integral to the growth of a community or rural area and have archaeological and/or structural remains that are well preserved and represent the time period when that industry was important. Comparisons with other sites of this type should also be used to detennine relative degrees of integrity and significance. Of the six archaeological sites recorded in Fayette Township related to industrial development, only two potentially meet these requirements. These include a quarry (site 13LN381) and potential sawmill site (13LN336) in the nonhern pan of Fayette Township (see Figure 3-1). Both sites will require a more intensive examination before a final detennination can be made but neither is threatened by construction or other activities at the present time. The six industrial-related sites recorded during the present investigation include the Lewis Gristmill site (13LN333). a possible sawmill site in the Katieville vicinity (13LN336), and four limestone quarries (13LN334, 13LN381, 13LN382. and 13LN383) (see Figure 3-1). Of the latter, site 13LN381 appears to have the greatest integrity because it represents an early quarry and potential limekiln operation that was not quarried extensively in the Twentieth Century. The other quarries have all been adversely impacted by relatively recent quarrying activities related to the production of crushed rock for road construction (plate 26, Appendix A) as opposed to quarries used exclusively for building stone or early lime burning operations. 3-9 While site 13LN336 is suspected to have been an early sawmill site associated with Daniel Richards' mill at Katieville, it may simply be a house site associated with that steamboat landing and is also enumerated in Section E below. At present, the sparse artifacts recovered from this site are inconclusive as to site function (see Table 3, Appendix B), and the site will require subsurface testing before a final determination of both function and National Register eligibility can be made.The Lewis Gristmill site (13LN333) was an important industry during the early settlement period of the township and was associated with John Lewis, one of the early settlers of the area. The archaeological remains of this site consist of a highly impacted limestone foundation along the banks of Bear Creek northwest of the town of Palo (see Figure 3-1 and Plate 27, Appendix A). The mill itself was still standing in recent memory but had been moved to another location and remodeled into a barn. It has since burned to the ground. No evidence of a mill race was observed at the mill site location, nor any substantial remains of the dam. The location of an old bridge that crossed the creekjust west of the mill is still evident, although the bridge and associated roadway have been removed or modified. A modern house has also adversely impacted the former location of the millers' house or cabin to the south of the mill site (Plate 28, Appendix A). A limestone foundation for this cabin was uncovered during the house construction and subsequently destroyed. Comparisons with the Notbohm mill site in the former town of Lafayette in Linn County indicate that the relative integrity of the Lewis Gristmill site is low and makes this property ineligible for nomination to the National Register. The Notbohm mill site (13LN296), while dating from the later Expansion Era, was an important mill during thisperiod and retains a high degree of archaeological integrity having a relatively intact foundation, mill race, and mill pond in addition to a small quarry where the stone for the foundation was extracted. While it is known that a small-scale brick manufactory operated in the town of Palo during the early settlement period, the location of this industry is not known from present data.The products from this plant are evidenced, however, in the brick buildings and foundations of Palo and potentially in the brick used at some of the rural properties as well.The concrete block factory that operated in Palo at a later date is still standing and was recorded in the architectural portion of this survey. No archaeological remains associated with this industry have been identified. E. Sites Associated with Trans.ortation Development in Fayette Township The property types associated with transportation development in Fayette Township arerepresented primarily by archaeological properties, although architectural properties areknown. Potential archaeological site types include: abandoned road remnants and associated sites such as stagecoach stops and liveries; steamboat and ferry landings;shipwrecks, and railroad-related sites such as depots and abandoned railroad grades. The period of significance for this context is from 1839-1942+, although most archaeological properties will date from the Nineteenth Century. Sites associated with this context could be significant under Criteria A, B, C, or D, although the majority will be significant under either A, for their historical significance, or under D, for their ability to yield important information concerning transportation development. River, road, and railroad transportation development were integral to the overall growth and development of the township and county. Towns often lived or died by their transportation connections or lack thereof. While railroad development was comparatively well documented in the historical accounts, legal records, and maps of the day, much less is known about the early road systems and river travel making sites associated with these early transportation developments particularly significant. 3-9 While site 13LN336 is suspected to have been an early sawmill site associated with Daniel Richards' mill at Katieville, it may simply be a house site associated with that steamboat landing and is also enumerated in Section E below. At present, the sparse artifacts recovered from this site are inconclusive as to site function (see Table 3, Appendix B), and the site will require subsurface testing before a fInal detennination of both function and National Register eligibility can be made. The Lewis Gristmill site (13LN333) was an important industry during the early settlement period of the township and was associated with John Lewis, one of the early settlers of the area. The archaeological remains of this site consist of a highly impacted limestone foundation along the banks of Bear Creek northwest of the town of Palo (see Figure 3-1 and Plate 27. Apperidix A). The mill itself was still standing in recent memory but had been moved to another location and remodeled into a barn. It has since burned to the ground. No evidence of a mill race was observed at the mill site location, nor any substantial remains of the dam. The location of an old bridge that crossed the creek just west of the mill is still evident, although the bridge and associated roadway have been removed or modified. A modern house has also adversely impacted the former location of the millers' house or cabin to the south of the mill site (plate 28, Appendix A). A limestone foundation for this cabin was uncovered during the house construction and subsequently destroye4 Comparisons with the Notbohm mill site in the fonner town of Lafayette in Linn County indicate that the relative integrity of the Lewis Gristmill site is low and makes this property ineligible for nomination to the National Register. The Notbohm mill site (13LN296), while dating from the later Expansion Era, was an important mill during this period and retains a high degree of archaeological integrity having a relatively intact foundation, mill race, and mill pond in addition to a small quarry where the stone for the foundation was extracted. . While it is known that a small-scale brick manufactory operated in the town of Palo during the early settlement period, the location of this industry is not known from present data. The products from this plant are evidenced, however. in the brick buildings and foundations of Palo and potentially in the brick used at some of the rural properties as well. The concrete block factory that operated in Palo at a later date is still standing and was recorded in the architectural portion of this survey. No archaeological remains associated with this industry have been identified. E. Sites Associated with Transportation Develqpment in Fayette TownshiIJ The property types associated with transportation development in Fayette Township are represented primarily by archaeological properties, although architectural properties are known. Potential archaeological site types include: abandoned road remnants and associated sites such as stagecoach stops and liveries; steamboat and ferry landings; shipwrecks, and railroad-related sites such as depots and abandoned railroad grades. The period of significance for this context is from 1839-1942+. although most archaeological properties will date from the Nineteenth Century. Sites associated with this context could be significant under Criteria A, B, C, or D, although the majority will be significant under either A, for their historical significance, or under D, for their ability to yield important information concerning transportation development River, road, and railroad transportation development were integral to the overall growth and development of the township and county. Towns often lived or died by their transportation connections or lack thereof. While railroad development was comparatively well documented in the historical accounts, legal records, and maps of the day, much less is known about the early road systems and river travel making sites associated with these early transponation developments particularly significant. 3-10 As with the other property types, registration requirements for transportation sites should be based on archaeological integrity and historical associations with significant transportation developments. Rarity should also be taken into consideration, such as an old road remnant that has been preserved in virtually its original state. Of the four sites recorded in Fayette Township related to transportation development, two potentially meet these requirements and include sites 13LN336 and 13LN384 (see Figure 3-1). The first one will require subsurface testing before a final determination of eligibility can be made,while the second will require more intensive archival and oral historical investigation. Neither are threatened with destruction at the present time.The four recorded sites include: the possible sawmill or habitation site associated with the steamboat landing community known as Katieville (13LN336, also enumerated underSection D); a habitation site associated with the steamboat landing known as McGivins Chute or Macksville (1 3LN362, also enumerated under Section B); an early wagon road remnant (13LN384); and the Palo depot (13LN380). The Palo depot site is concluded to be ineligible because the depot was still standing until 1960 and is well documented in the historic photographs and records and the archaeological remains have little potential to yield any further significant data having been adversely impacted by post-occupation bulldozing. Other potential transportation-related sites included the stagecoach barn in Palo, potential stage road remnants, and remains associated with the steamboat landing at Palo. As noted previously, the stagecoach barn site in Palo has been adversely impacted by modem construction, while the potential locations of stage road remnants have not been confirmed through field investigation. Likewise, no remains associated with the Palo landing have been located, although there is some potential for remains in a buried or submerged context.One final potential should be noted; the potential for steamboat and other early boat wrecks in the Cedar River and buried in abandoned channels of that river. One such potential site was noted in the Fayette Township vicinity but has not been given an archaeological sitedesignation. This potential site is the remains of the Carrie Wallace, a small sternwheeler that burst its boiler and sank seven miles above Cedar Rapids in the vicinity of Blue Banks upriver from Katieville. More extensive archival research is required to pinpoint other potential buried shipwreck sites along the Cedar River.F. Sites Associated with Religion and Education in Fayette Town hinThe property types associated with religious and educational developments in Fayette Township are represented primarily by both archaeological and architectural properties,with the architectural properties discussed under Section III. Potential archaeological site types include churches and school sites. The period of significance for this context is from 1839-1942+. Sites associated with this context could be significant under Criteria A, B, C,or D, although religious properties must also meet Criteria Consideration A, which states that such a property must derive its primary significance from architectural or artistic distinction or historical importance. As with the other property types, registration requirements for sites associated with this context should be based on archaeological integrity and historical associations with significant religious or educational institutions. Of the six sites recorded associated with this context during the present investigation, none meet these requirements and all are considered ineligible for nomination to the National Register.The six sites include five rural school sites and one rural church. The latter is the remains of the Lewis Bottoms Methodist Episcopal Church (13LN374) which was built in 1878. , i :. ; 3-10 As with the other property types, registration requirements for transponation sites should be based on archaeological integrity and historical associations with significant transponation developments. Rarity should also be taken into consideration, such as an old road remnant that has been preserved in virtually its original state. Of the four sites recorded in Fayette Township related to transportation development, two potentially meet these requirements and include sites 13LN336 and 13LN384 (see Figure 3-1). The tITSt one will require subsurface testing before a final detennination of eligibility can be made, while the second will require more intensive archival and oral historical investigation. Neither are threatened with destruction at the present time; The four recorded sites include: the possible sawmill or habitation site associated with the steamboat landing community known as Katieville (13LN336, also enumerated under Section D); a habitation site associated with the steamboat landing known as McGivins Chute or Macksville (13LN362, also enumerated under Section B); an early wagon road remnant (13LN384); and the Palo depot (13LN380). The Palo depot site isconc1uded to be ineligible because the depot was still standing until 1960 and is well documented in the historic photographs and records and the archaeological remains have little potential to yield any further significant data having been adversely impacted by post-occupation bulldozing. Other potential transportation-related sites included the stagecoach bam in Palo, potential stage road remnants, and remains associated. with the steamboat landing at Palo. Asnote<! previously, the stagecoach barn site in Palo has been adversely impacted by modem construction, while the potential locations of stage road remnants have not been confirmed. through field investigation. Likewise, no remains associated with the Palo landing have been located, although there is some potential for remains in a buried or submerged context. One final potential should be noted; the potential for steamboat and other early boat wrecks in the Cedar River and buried in abandoned channels of that river. One such potential site was noted in the Fayette Township vicinity but has not been given an archaeological site designation. This potential site is the remains of the Carrie Wallace, a small stemwheeler that burst its boiler and sank seven miles above Cedar Rapids in the vicinity of Blue Banks upriver from Katieville. More extensive archival research is required to pinpoint other potential buried shipwreck sites along the Cedar River. F. Sites ASsociated with Religion and Education in Fayette Township The property types associated with religious and educatjonal developments in Fayette Township are represented primarily by both archaeological and architectural properties. with the architectural properties discussed under Section m. Potential archaeological site types include churches and school sites. The period of significance for this context is from 1839-1942+. Sites associated with this context could be significant under Criteria A, B, C, or D, although religious properties must also meet Criteria Consideration A. which states that such a property must derive its primary significance from architectural or artistic distinction or historical importance. As with the other property types. registration requirements for sites associated with this context should be based on archaeological integrity and historical associations with significant religious or educational institutions. Of the six sites recorded. associated with this context during the present investigation, none meet these requirements and all are considered ineligible for nomination to the National Register. The six sites include five rural school sites and one rural church. The latter is the remains of the Lewis Bottoms Methodist Episcopal Church (13LN374) which was built in 1878 3-11 and was abandoned by the mid-Twentieth Century (Centennial Committee 1979:20). The limestone foundation of the church remains extant, with the site impacted only marginally by road construction into the Pleasant Creek State Park. The site is considered potentially eligible under the proposed Lewis Bottoms Rural Neighborhood MPDF cover document as a well preserved remnant associated with this important neighborhood settlement. Whether it meets the exceptional significance criterion required for religious properties remains for further research to determine. The five rural school sites include: the Round Prairie School site (13LN342); the Bear Creek School at its c. 1881-1895 location (13LN348); the Bear Creek School at its c.1859-1869 and c. 1906 location (13LN350); the Goose Hill School, c. 1869 (13LN356); and the Dry Creek Independent School, c. 1895-early 1900s (13LN359) (see Figure 3-1).The former schoolhouse structures for three of these sites are extant but have been moved to other locations and remodeled into outbuildings. These include the former Round Prairie School, the c. 1881-1895 Bear Creek School, and the Dry Creek School. None of the school sites or structures are eligible for the National Register and require no further investigation. G. Sites Associated with Consolidation Era Resource Development in Fayette Township Potential property types associated with Consolidation Era resource development include parks, conservation areas, lake impoundments, and power plants. This context was developed for the Fayette Township area to illustrate some of the major impacts from urbanexpansion and development and that these impacts often go beyond residential developments. In the study area, the Pleasant Creek State Park and the Duane Arnold Energy Center (DAEC) comprise the two resource developments that have had a major impact on the landscape and cultural resources of Fayette Township. As a result of these developments, a number of farmsteads and former fields have been abandoned, demolished, and taken out of cultivation, although some of the ground around the DAEC isleased out to local farmers. While some archaeological sites were "created" by this development and were recorded during the present investigation, other historic sites were completely destroyed without having been recorded. The construction of the park and energy center also impacted the road system in the township, with at least one north-south road completely rerouted around the lake and park, and another road closed on the energy center property. New roads have also been improved and paved to accommodate the added traffic attracted by both developments. At present, neither the Pleasant Creek State Park nor the Duane Arnold Energy Center are eligible for the National Register because both post-date the period for inclusion in the Register. However, the DAEC may one day be considered to have sufficient historical significance to be considered for the Register because it was the first nuclear power plant in the state of Iowa. Further contextual research is required before such a determination can be made.11. HISTORICAL AND ARCHITECTURAL PROPERTY TYPES A. Introduction A list of the historic districts and individual resources found eligible for nomination to the National Register within these property types is attached at the end of each discussion of the property type. Information about specific resources is included in Volume Two of this report. This volume also contains lists of contributing and noncontributing resources , , r ; ! 1 3-11 and was abandoned by the mid-Twentieth Century (Centennial Committee 1979:20). The limestone foundation of the church remains extant, with the site impacted only marginally by road construction into the Pleasant Creek State Park. The site is considered potentially eligible under the proposed Lewis Bottoms Rural Neighborhood MPDF cover document as a well preserved remnant associated with this important neighborhood settlement. Whether it meets the exceptional significance criterion required for religious properties remains for further research to detennine. The five rural school sites include: the Round Prairie School site (13LN342); the Bear Creek School at its c. 1881-1895 location (13LN348); the Bear Creek School at its c. 1859-1869 and c. 1906 location (13LN350); the Goose Hill School, c. 1869 (13LN356); and the Dry Creek Independent School, c. 1895-early 1900s (13LN359) (see Figure 3-1). The fonner schoolhouse structures for three of these sites are extant but have been moved to other locations and remodeled into outbuildings. These include the fonner Round Prairie School, the c. 1881-1895 Bear Creek School, and the Dry Creek School. None of the school sites or sttuctures are eligible for the National Register and require no further investigation. G. Sites Associated with Consolidation Era Resource Development in Fayette Township Potential property types associated with Consolidation Era resource development include parks, conservation areas, lake impoundments, and power plants. This context was developed for the Fayette Township area to illustrate some of the major impacts from tirban expansion and development and that these impacts often go beyond residential developments. In the study area, the Pleasant Creek State Park and the Duane Arnold Energy Center (DAEC) comprise the two resource developments that have had a major impact on the landscape and cultural resources of Fayette Township. As a result of these developments, a number of farmsteads and former fields have been abandoned, demolished, and taken out of cultivation, although some of the ground around the DAEC is leased out to local fanners. While some archaeological sites were "created" by this development and were recorded during the present investigation, other historic sites were completely destroyed without having been recorded The construction of the park and energy center also impacted the road system in the township, with at least one north-south road completely rerouted around the lake and park, and another road closed on the energy center property. New roads have also been improved and paved to accomniodate the added traffic attracted by both developments. At present, neither the Pleasant Creek State Park nor the Duane Arnold Energy Center are eligible for the National Register because both post-date the period for inclusion in the Register. However, the DAEC may one day be considered to have sufficient historical significance to be considered for the Register because it was the first nuclear power plant in the state of Iowa. Further contextual research is required before such a determination can , HI. HISTORICAL AND ARCHITECTURAL PROPERTY TYPES A. Introduction A list of the historic districts and individual resources found eligible for nomination to the National Register within these property types is attached at the end of each discussion of the property type. Information about specific resources is included in Volume Two of this report. This volume also contains lists of contributing and noncontributing resources 3-12 within the historic districts and Multiple Property Listings. It should be noted that many historic resources are found eligible for nomination to the National Register under several historic contexts and criteria.B. Districts. Buildings. Structures. Sites. and Features Associated with Rise of An Agricultnal Economy I1.

Description:

There are a variety of resources associated with the rise of an agricultural economy in Fayette Township related to the three eras of development: Early Settlement (1839-1859), Expansion (1859-1913), and Consolidation (post-1913). Rural resources for the Early Settlement Era are scarce on the present landscape and are confined to cemeteries and individual house and barn buildings on otherwise late-Nineteenth to Twentieth Century farmsteads. The recorded properties associated with this era include: the Pleasant Ridge Cemetery (Rural Architectural Site 13); the Strawn Cemetery (#22); the Old Palo Cemetery (#19); the Joseph Strawn house (#34), and the Edward Railsback barn (#37) (see Figure 3-4).Resources for the Expansion Era are more prevalent on the landscape and include farmsteads, individual houses and barns on otherwise Twentieth Century farmsteads, and cemeteries. The recorded properties associated with this era include: the Palo Cemetery (#2); the houses on the George McCorkle (#3), the James D. Hayes (#4), the McManus (#8), the McClintock/Melton (#9), the Mather/Lewis (#10), the T.C. Lewis (#12), the Earhart (#17), the Railsback/Lewis (#18), the Dickinson (#20), the Lightfoot (#24), the McCorkle (#27), the Carl Rabe (#32), the Emory McArthur (#35), and the S.A. Mobry (#36) farmsteads; the house and two of the barns on the Lewis Penrose farmstead (#23); and the entire John Lewis farmstead (#11) (see Figure 3-4). The remainder of the recorded properties (#1, 5-7, 15, 16, 21, 25, 26, 28-31, 33, and 38) are solely related to the Consolidation Era of development (see Figure 3-4). Of the 34 recorded farmsteads, 21 (62%) are predominated by Twentieth Century Consolidation Era buildings and structures.

2. Significance:

Significance of the agricultural development of the study area derives from the associations and representations of an individual property, multiple properties, or districts with important historical developments in rural settlement patterns and farmstead evolution. Of particular note in the study area, is the early settlement pattern of related families settling in neighborhoods and strongly shaping the development of these neighborhoods throughout the historic period. Of the neighborhood settlements in Fayette Township, that of the Lewis Bottoms neighborhood, settled by the Lewis family and their extended relations has had the most significant impact on the rural development of the township from 1839 well into the Twentieth Century.3. Registration Requirements: Criterion A. Resources must have a demonstrative association with significant rural settlement patterns or events. Criterion B. Resources must be representative of and have a direct association with the lifework and accomplishments of persons who had a significant impact on rural development. Criterion C. Resources must reflect important architectural and/or stylistic characteristics associated with rural architectural development. They may also 3-12 within the historic districts and Multiple Property Listings. It should be noted that many historic resources are found eligible for nomination to the National Register under several historic contexts and criteria. B. Districts. Buildings. Structures. Sites. and Features Associated with Rise of An Agriculnrral Economy 1 .

Description:

There are a variety of resources associated with the rise of an agricultural economy in Fayette Township related to the three eras of development: Early Settlement (1839-1859), Expansion (1859-1913), and Consolidation (post-1913). Rural resources for the Early Settlement Era are scarce on the present landscape and are confined to cemeteries and individual house and bam*buildings on otherwise late-Nineteenth to Twentieth Century fannsteads. The recorded properties associated with this era include: the Pleasant Ridge Cemetery (Rural Architectural Site 13); the Strawn Cemetery (#22); the Old Palo Cemetery (#19); the Joseph Strawn house (#34), and the Edward Railsback bam (#37) (see Figure 3-4). Resources for the Expansion Era are more prevalent on the landscape and include farmsteads, individual houses and bams on otherwise Twentieth Century farmsteads, and cemeteries. The recorded properties associated with this era include: the Palo Cemetery (#2); the houses on the George McCorkle (#3), the James D. Hayes (#4), the McManus (#8), the McClintocklMelton (#9), the Mather/Lewis (#10), the T.C. Lewis (#12), the Earhan (#17), the RailsbacklLewis (#18), the Dickinson (#20), the Lightfoot (#24), the McCorkle (#27), the Carl Rabe* (#32), the Emory McArthur (#35), and the S.A. Mobry (#36) farmsteads; the house and two of the barns on the Lewis Penrose farmstead (#23); and the entire John Lewis farmstead (#11) (see Figure 3-4). The remainder of the recorded properties (#1.5-7. 15, 16,21,25,26,28-31,33, and 38) are solely related to the Consolidation Era of development (see Figure 3-4). Of the 34 recorded farmsteads. 21 (62%) are predominated by Twentieth Century Consolidation Era buildings and structures.

2. Significance:

Significance of the agricultural development of the study area derives from the associations and representations of an individual property, multiple properties, or districts with important historical developments in rural settlement patterns and farmstead evolution. Of particular note in the study area, is the early settlement pattern of related families settling in neighborhoods and strongly shaping the development of these neighborhoods throughout the historic period. Of the neighborhood settlements in Fayette Township. that of the Lewis Bottoms neighborhood, settled by the Lewis family and their extended relations has had the most significant impact on the rural development of the township from 1839 well into the Twentieth Century. 3. Registration Requirements: Criterion A. Resources must have a demonstrative association with significant rural settlement patterns or events. Criterion B. Resources must be representative of and have a direct association with the lifework and accomplishments of persons who had a significant impact on rural development Criterion C. Resources must reflect important architectural and/or stylistic characteristics associated with rural architectural development They may also 3-13 represent the work and craftsmanship of a skilled builder/designer who influenced the local built environment Criterion D. Has already been addressed in the archaeological section of this report-Integrity Considerations: All of the farmsteads in the Fayette Township study area have been impacted to varying degrees by modem construction and destruction ofhistoric buildings and structures. This is also typical of much of the rural built environment across the state of Iowa. Therefore, integrity considerations should give some leeway to modem intrusions and historic removals, particularly if these events reflect the continuation of significant agricultural evolutionary developments. However, if both the historic (i.e., pre-1942) house and barn are non-extant, then the integrity of the farmstead as a district has been compromised making the property ineligible for the National Register under Criteria A-C, If one or the other of the house or barn is non-extant, the evaluation of the property must consider the significance of the remaining primary structure and secondary support structures as well as the archaeological potential of the farmstead as a whole, particularly if the farmstead is eligible under Criterion A. Otherwise, standard integrity considerations of location, setting, materials, design, workmanship, feeling, and association would apply to any rural resource evaluation. Consideration Exception D may apply to rural cemetery properties, such as the Pleasant Ridge Cemetery in the Lewis Bottoms neighborhood, for their association with significant historic patterns or events; in this case, the Early Settlement Era rural neighborhood development associated with the Lewis family and their extended family members.4. Potentially Eligible Properties: Historic Distcts While originally, the Lewis Bottoms neighborhood likely constituted a rural district under Criterion A, the adverse impacts from the construction of the Pleasant Creek Reservoir, which destroyed farmsteads, the Lewis Bottoms school, and re-routed the road system in this area, has compromised the integrity of this potential rural district. No other rural districts were identified in the study area due to the adverse impacts from modem (post-1942) suburban and highway construction in additionto the widespread impacts associated with the Pleasant Creek Reservoir and the Duane Arnold Energy Center.Resources of the Lewis Bottoms Rural Neighborhood Multiple Property Document Despite the impacts to the potential rural district based on the Lewis Bottoms settlement, there remains a good potential eligibility for a Multiple Property Document Form and associated nominations based on the extant architectural and archaeological resources associated with the Lewis family and this important early settlement as well as its impact on the rural settlement and development of the township as a whole from the Early Settlement Era through the Consolidation Era.Such a document would be potentially eligible under Criteria A and C, although a Phase H-level investigation is required to fully evaluate the historical and architectural significance of the Lewis Bottoms properties. Eligibility under Criterion D will also require Phase fl-level archaeological investigation to fully 3*13 represent the work and craftsmanship of a skilled builder/designer who influenced the local built environment Criterion D. Has already been addressed in the archaeological section of this report. Integrity Considerations: All of the fannsteads in the Fayette Township study area have been impacted to varying degrees by modem construction and destruction of historic buildings and structmes. This is also typical of much of the rural built environment across the state of Iowa. Therefore, integrity considerations should give some leewi;ly to modem intrusions and historic removals, particularly if these events reflect the continuation of significant agricultural evolutionary developments. However. if both the historic (i.e., pre-1942) house and bam are non-extant, then the integrity of the fannstead as a district has been compromised inaking the property ineligible for the National Register under Criteria A-C. If one or the other of the house or barn is non-extant, the evaluation of the property must consider the significance of the remaining primary structure and secondary support structures as well as the archaeological potential of the farmstead as a whole, particularly if the fannstead is eligible under Criterion A. Otherwise, standard integrity considerations of location, setting, materials, design, workmanship, feeling, and association would apply to any rural resource evaluation. Consideration Exception D may apply to rural cemetery properties, such as the Pleasant Ridge Cemetery in the Lewis Bottoms neighborhood, for their association with significant historic patterns or events; in this case, the Early Settlement Era rural neighborhood development associated with the Lewis family and their extended family members. 4. Potentially Eligible Properties: Historic Districts While originally. the Lewis Bottoms neighborhood likely constituted a rural district under Criterion A, the adverse impacts from the construction of the Pleasant Creek ReseIVoir, which destroyed farmsteads, the Lewis Bottoms school, and re-routed the road system in this area, has compromised the integrity of this potential rural district. No other rural districts were identified in the study area due to the adverse impacts from modern (post-1942) suburban and highway construction in addition to the widespread impacts associated with the Pleasant Creek Reservoir and the Duane Arnold Energy Center. Resources of the Lewis Bottoms Rural Multiple Property Document FQnn Despite the impacts to the potential rural district based on the Lewis Bottoms settlement, there remains a good potential eligibility for a Multiple Property Document Form and associated nominations based on the extant architectural and archaeological resources associated with the Lewis family and this important early settlement as well as its impact on the rural settlement and development of the township as a whole from the Early Settlement Era through the Consolidation Era. Such a document would be potentially eligible under Criteria A and C, although a Phase II-level investigation is required to fully evaluate the historical and architectural significance of the Lewis Bottoms properties. Eligibility under Criterion D will also require Phase II-level archaeological investigation to fully 3-14 assess site integrity. Based on the results of the present survey, the following architectural resources have been identified as potentially eligible for nomination under this multiple property cover document:John Lewis Farmstead (Rural Architectural Site #11)T85N-R8W, Section 32, SEI/4, NWI/4 Lewis Bottoms Road north of Palo, Iowa Thomas C. Lewis Farmstead (Rural Architectural Site#12)T85N-R8W, Section 32, SE1/4, NW1/4 Lewis Bottoms Road north of Palo, Iowa Pleasant Ridge Cemetery (Rural Architectural Site #13)T85N-R8W, Section 31, NEI/4, SEI/4 North edge of Pleasant Creek Reservoir north of Palo, Iowa John Lewis extended family rural residences (Rural Architectural Site #16)T85N-R8W, Section 32, SW1/4, SE1/4 Lewis Bottoms Road north of Palo, Iowa J.D. Lewis Farmstead (Rural Architectural Site #18)T84N-R8W, Section 8, SEI/4, SW1/4 NW comer Lewis Bottoms and Power Plant Roads northwest of Palo, Iowa W.J. and C.W. Lewis Farmstead (Rural Architectural Site #38)T84N-R8W, Section 5, SWI/4, SEI/4 Lewis Bottoms Road northwest of Palo, Iowa Mather/Lewis Farmstead (Rural Architectural Site #10)TS4N-R8W, Section 5, SEI/4, NEI/4 McClintock Road, north of Palo, Iowa Lewis Bottoms M.E. Church Site (Archaeological Site 13LN374)SE corner of Lewis Bottoms Road and McClintock Road Thomas Lewis House Site (Archaeological Site 13LN375)Palo Marsh Road north of Palo Individuals In addition to the above potentially eligible nominations under the proposed Multiple Property Document Form are the following individual properties that are potentially eligible as individual farmstead units or districts based on Criterion C as they reflect important trends in the rural architectural landscape of the township.George McCorkle Farmstead (Rural Architectural Site #3)T84N-R8W, Section 20, SEI/4, NE1/4 Palo Marsh Road north of Palo, Iowa F.S. Rogers Farmstead (Rural Architectural Site #6)T84N-R8W, Section 16, NE1/4, NW 1/4 Power Plant Road northeast of Palo, Iowa J.N. Dickinson Farmstead (Rural Architectural Site #20)T84N-R8W, Section 20, NEI/4, SWI/4 Hollenbeck Road northwest of Palo, Iowa assess sIte mtegrity. Based on the results of the present survey, the following architectural resources have been identified as potentially eligible for nomination under this multiple property cover document: John Lewis Farmstead (Rural Architectural Site #11) Section 32, SEI/4, NWI/4 Lewis Bottoms Road north of Palo. Iowa Thomas C. Lewis Farmstead (Rural Architectural Site#12) Section 32, SEl/4. NWl/4 Lewis Bottoms Road north of Palo, Iowa Pleasant Ridge Cemetery (Rural Architectura1 Site # 13) T85N-RSW. Section 31. NEl/4, SEl/4 North edge of Pleasant Creek Reservoir north of Palo, Iowa John Lewis extended family rural residences (Rural Architectural Site #16) T85N-RSW, Section 32, SWl/4. SEI/4 Lewis Bottoms Road north of Palo, Iowa J.D. Lewis Farmstead (Rural Architectural Site #18) T84N-R8W. Section 8, SEl/4, SWl/4 NW comer Lewis Bottoms and Power Plant Roads northwest of Palo, Iowa W J. and C.W. Lewis Farmstead (Rural Architectural Site #38) T84N-R8W. Section 5, SWl/4. SEl/4 Lewis Bottoms Road northwest of Palo, Iowa Mather/Lewis Farmstead (Rural Architectura1 Site # 10) T84N-R8W, Section 5. SEl/4, NEl/4 McClintock Road, north of Palo, Iowa Lewis Bottoms ME. Church Site (Archaeological Site 13LN374) SE comer of Lewis Bottoms Road and McClintock Road Thomas Lewis House Site (Archaeological Site 13LN375) Palo Marsh Road north of Palo Individuals In addition to the above potentially eligible nominations under the proposed Multiple Property Document Form are the following individual properties that are potentially eligible as individual farmstead units or districts based on Criterion C as they reflect important trends in the rural architectural landscape of the township. George McCorkle Farmstead (Rural Architectural Site #3) T84N-R8W, Section 20. SEI/4. NEI/4 Palo Marsh Road north of Palo. Iowa F.S. Rogers Farmstead (Rural Architectural Site #6) T84N-R8W, Section 16, NEI/4, NWI/4 Power Plant Road northeast of Palo, Iowa J.N. Dickinson Farmstead (Rural Architectural Site #20) .T84N-R8W. Section 20, NEt/4, SWI/4 Hollenbeck Road northwest of Palo, Iowa 3-15 Lewis Penrose Farmstead (Rural Architectural Site #23)T84N-R8W, Section 7, NEI/4, SW1/4 Strawn Road northwest of Palo, Iowa E.A. Myers Farmstead (Rural Architectural Site #25)T84N-RSW, Section 20, NW1/4, NW1/4McVay Road northwest of Palo, Iowa Charles Beatty Farmstead (Rural Architectural Site #29)T84N-R8W, Section 29, NEI/4, SWI/4Yates Road southwest of Palo, Iowa Emory A. McArthur Farmstead (Rural Architectural Site

1. 35)[This property may also have a historical association with the Lewis Bottoms settlementand should be more intensively researched in order to determine whether such a connectioncan be made.]T85N-R8W, Section 30, SW1/4, NEI/4 Palo Marsh Road north of Palo, Iowa Edward Railsback Barn (Rural Architectural Site #37)[Also potentially eligible under Criterion A or even as a ruin under Criterion D given itsdeteriorating condition but significant above-ground remains]T84N-R8W, Section 17, SW1/4, NWI/4 Hollenbeck Road northwest of Palo, Iowa The remaining rural resources (Rural Architectural Sites #1, 2, 4, 5, 7-9, 12, 14,15, 17, 19, 21, 22, 24, 26, 27, 28, 30-34, 36 and 38) were determined to be ineligible for nomination to the National Register based on the lack of sufficient integrity and/or significance. These properties require no further evaluation, whilethe above-noted potentially eligible properties will require Phase H-level investigation before a final determination of eligibility and National Register nominations can be made.C. Districts. Buildings. Structures.

Sites. and Features Associated with Town 1.

Description:

There are a variety of resources associated with town building.Resources differ as to property type and can include city plats, city blocks or portions of blocks, central business districts, semi-public clusters of institutional resources, residential neighborhoods, and resources adjacent to corridors of transportation, all of which call attention to specific town building activities or to the community's cumulative town building traditions and practices as evolved over a period of time.2. Significance: Significance can derive from specific town planning activities, such as the platting and laying out of land, which affect future physical growth of a community. Significance can also derive from the evolution of land use over time, illustrating individual or community responses to environmental, economic, transportation, and/or other local factors.3. Registration Requirements: Criterion A. Property types directly associated with formal town building practices, such as the surveying, platting, and laying out of land for a town, subdivision, park, transportation network, or other purpose. Also property types directly associated with the evolution of land use, whether agents for change or[I J ! c. 1. 2. 3*15 Lewis Penrose Fannstead (Rural Architeclmal Site #23) T84N*R8W, Section 7, NEI/4, SWl/4 Strawn Road northwest of Palo, Iowa E.A. Myers Fannstead (Rural Archit.ecrural Si.te fl25) T84N*RSW, Section 20, NWl/4, NWl/4 McVay Road northwest of Palo, Iowa Charles Beatty Fannstead (Rural Architectural Site #29) T84N-RSW. Section 29. NEI/4. SWl/4 Yates Road southwest of Palo, Iowa EmOl)' A. McArthur Fannstead (Rural Architectural Site #35) [This propeny may also have a historical association with the Lewis BOUOms settlement and should be more intensively researched in order to determine whether such a connection can be made.) T85N*R8W. Section 30, SWl/4, NEl/4 Palo Marsh Road north of Palo, Iowa Edward Railsback Bam (Rural Architectural Site #37) [Also potentially eligible under Criterion A or even as a ruin under Criterion D given its deteriorating condition but significant above-ground remains) T84N-RSW, Section 17. SWI/4. NWI/4 Hollenbeck Road northwest of Palo. Iowa The remaining rural resources (Rural Architectural Sites #1,2,4,5, 7-9, 12, 14, IS, 17, 19,21,22,24,26,27,28,30-34,36 and 38) were detennined to be ineligible for nomination to the National Register based on the lack of sufficient integrity and/or significance. These properties require no further evaluation, while the above-noted potentially eligible properties will require Phase IT-level investigation before a final determination of eligibility and National Register nominations can be made. Districts, Buildings. Structures, Sites, and Features Associated with Town Building.

== Description:==

There are a variety of resources associated with town building. Resources differ as to property type and can include city plats, city blocks or portions of blocks, central business districts, semi-public clusters of institutional resources, residential neighborhoods, and resources adjacent to corridors of transportation, all of which call attention to specific town building activities or to the community's cumulative town building traditions and practices as evolved over a period of time. Significance: Significance can derive from specific town planning activities, such as the platting and laying out of land, which affect future physical growth of a community. Significance can also derive from the evolution of land use over time, illustrating individual or community responses to environmental, economic, transportation, and/or other local factors. 3. Registration Requirements: Criterion A. Property types directly associated with fonnal town building practices. such as the surveying, platting, and laying out of land for a town, subdivision, park, transportation network, or other purpose. Also property types directly associated with the evolution of land use, whether agents for change or 3-16 responses to new opportunities brought about by these changes. Such property types include new facilities, which by their construction alter established patterns ina community, as well as properties, which call attention to events, which have affected such changes.Criterion B. There is little evidence to support employment of this criterion in evaluating properties associated with town building. When identified, such properties must be directly linked with an individual or group significant to town building. The John Hollenbeck House might qualify in this regard, but significance is not claimed for Criterion B in this report because the resource qualifies under two other criteria, each of which is easier to justify.Criterion C. Properties that reflect architectural design or others characteristics resultant from town building decisions or responses to these decisions. Criterion D. Sites of nonextant properties, which contain intact subsurface deposits with good information potential concerning the material culture of identifiable and significant town building practices. Integrity Considerations: Unless a property has lost most of the characteristics that convey a sense of time and place associated with its town building function or nolonger has the ability to provide important information with respect to spatial patterns, building type, planning activity, or other subject of scholarly interest within this context, it should be considered eligible.4. Potentially Eligible Properties: Historic Districts Palo Historic Commercial District Palo, IA Vinton Sreet Historic District Palo, IA Individual None D. Districts, Buildings, Structures. Sites. and Features Associated with Transportation. 1.

Description:

Resources associated with transportation vary as to property type.Property types can comprise an entire transportation system, such as a road or highway. Property types can also comprise a portion of such systems, such as bridge, culverts, signage, and/or other historic feature. Property types situated adjacent to transportation corridors and dependent on them for their development may also be eligible. They include residential neighborhoods (whether single or contiguous plats, or portions of them), commercial districts, clusters of public and semi-public institutional resources, and industrial and light-industrial districts. Individual properties may also be eligible as they relate to transportation. They include stagecoach stops and holsteries, railroad depots, freight houses, bridges, 3-16 responses to new opportunities brought about by these changes. Such property types include new facilities, which by their construction alter established patterns in a community, as well as properties, which call attention to events, which have affected such changes. Criterion B. There is little evidence to support employment of this criterion in evaluating properties associated with town building. When identified. such properties must be directly linked with an individual or group significant to town building. The John Hollenbeck House might qualify in this regard, but significance is not claimed for Criterion B in this report because the resource qualifies under two other criteria, each of which is easier to justify. Criterion C. Properties that reflect architectural design or others characteristics resultant from town building decisions or responses to these decisions. Criterion'D. Sites of nonextant properties, which contain intact subsurface deposits with good information potential concerning the material culture of identifiable and significant town building practices. Integrity Considerations: Unless a property has lost most of the characteristics that convey a sense of time and place associated with its town building function or no longer has the ability to provide important information with respect to spatial patterns, building type, planning activity, or other subject of scholarly interest within this context, it should be considered eligible.

4. Potentially Eligible Properties:

Historic Districts Palo Historic Commercial District Palo, IA Vinton Street Historic District Palo, IA Individual None D. Districts. Buildings. Structures. Sites. and Features Associated with Transportation. 1 .

Description:

Resources associated with transportation vary as to property type. Property types can comprise an entire transportation system, such as a road or highway. Property types can also comprise a portion of such systems, such as bridge, culverts, sign age, and/or other historic feature. Property types situated adjacent to transportation corridors and dependent on them for their development may also be eligible. They include residential neighborhoods (whether single or contiguous plats, or portions of them), commercial districts, clusters of public and semi-public institutional resources, and industrial and light-industrial districts. Individual properties may also be eligible as they relate to transportation. They include stagecoach stops and holsteries, railroad depots, freight houses, bridges, 3-17 gas stations, hotels, tourist camps, motels, roadside commercial enterprises, and other tourist and over-the-road related resources.

2. Significance:

Significance for transportation--be they railroad, road and highway, water, or other--derives from their historic propensity to act as magnets attracting many different kinds of development at strategic points along their routes. The variety of this development and its concentration often distinguishes it from similar properties.

3. Registration Requirements:

Criterion A. Resources must have a demonstrative association with transportation, serving either a direct function, a support service, a technological contribution, or call attention to an evolutionary response as a result of a transportation system.Criterion B. Although there is little current evidence to support employment of this criterion in evaluating properties associated with transportation, if identified, such properties must be directly linked with an individual or group associated with transportation. Criterion C. Eligible properties must reflect design elements developed to service transportation, or that reflect other aspects of architectural history associated with transportation. Criterion D. Sites of nonextant properties, which contain intact subsurface deposits with good information potential concerning the material culture of identifiable and significant transportation systems.Integrity Considerations: Although few historic resources survived to call direct association to the railroad in Fayette Township, standard criteria for evaluation should not be waived in the evaluation of those resources remaining extant. The Scale House (Site #46 at 614 Main Street in Palo), associated with the industrial center which evolved at Palo's railroad yard, has been moved several times.Criteria Consideration B should not be claimed in this regard. Several resources have been tentatively identified, which are associated with stage coach travel.Established during the Early Settlement Era, these historic resources are often difficult to document because of their age. The evaluation of such historic resources should be deferred until more is known about stage coach resources in Linn County.4. Potentially Eligible Properties:Historic Districts Palo Historic Commercial District Palo, IA Vinton Street Historic District Palo, IA 2. 3*17 gas stations, hotels, tourist camps. motels, roadside corrnnercial enterprises, and other tourist and over-the-road related resources. Significance: Significance for transportation--be they railroad, road and highway, water, or other--derives from their historic propensity to act as magnets attracting many different kinds of development at strategic points along their routes. The variety of this development and its concentration often distinguishes it from similar properties.

3. Registration Requirements:

Criterion A. Resources must have a demonstrative association with transportation, serving either a direct function, a suppon service, a technological contribution, or call attention to an evolutionary response as a result of a transportation system. Criterion B. Although there is little cUrrent evidence to support employment of this criterion in evaluating properties associated with transportation, if identified, such properties must be directly linked with an individual or group associated with transportation. Criterion C. Eligible properties must reflect design elements developed to service transportation, or that reflect other aspects of architectural history associated with transportation. Criterion D. Sites of nonextant properties, which contain intact subsurface deposits with good infonnation potential concerning the material culture of identifiable and significant transportation systems. Integrity Considerations: Although few historic resources survived to call direct association to the railroad in Fayette Township, standard criteria for evaluation should not be waived in the evaluation of those resources remaining extant The Scale House (Site #46 at 614 Main Street in Palo), associated with the industrial center which evolved at Palo's railroad yard. has been moved several times. Criteria Consideration B should not be claimed in this regard. Several resources have been tentatively identified, which are associated with stage coach travel. Established during the Early Settlement Era, these historic resources are often difficult to document because of their age. The evaluation of such historic resources should be deferred until more is known about stage coach resources in Linn County. 4. Potentially Eligible Properties: Historic Qistricts Palo Hisloric Commercial District Palo,IA Vinton Street Hisloric District Palo,IA 3-18 Individual House (Site #28) (deferred) 32 Vinton Street Palo, IA E. Districts. Buildings. Structures. Sites, and Features Associated with Architectural Resources of Fayette Township.1 .Description: Resources differ as to property type and can include central business districts, neighborhood commercial districts, public and semi-public clusters, industrial and light-industrial concentrations, and farmsteads. Resources can also include individually eligible properties, such as commercial and business stores, shops, and offices; public and semi-public resources such as schools and churches, social and other meeting halls; and agricultural resources such as farmhouses, barns, silos, and other outbuildings. Designed historic landscapes may qualify under this historic context and can include parks, recreational areas, cemeteries, windbreaks, hedgerows, and/or other manifestations of human planning and manipulation of the natural environment.

2. Significance:

Significance can derive from building materials, whose physical opportunities and constraints affect residential architecture; from significant characteristics of scale and its employment; and from form as it provides diagnostic analysis for architectural significance. Significance can also derive from the variety of ways in which stylistic influences have contributed to the architectural heritage of the study area. Finally, significance can derive from contractor-builders who have contributed to the local built environment Although scale and form comprise defining characteristics for these historic resources, the significance claimed must be rigorously linked to a comprehensive evaluation of resources in the study area exhibiting similar characteristics. A compelling case must also be made for their significance over-and-above the diagnostic analysis provided in this report.

3. Registration Requirements:

Criterion A. Properties associated only with this context will not have significance under Criterion A.Criterion B. Proper-ties that are directly associated with individuals, groups, or other associations of people who played a leading, pivotal, or important role in shaping architectural developments in the study area during the Early Settlement Era, Expansion Era, or Consolidation Era.Criterion C. Eligible properties include vernacular building types that contribute to the distinctive character of Fayette Township. Eligible properties also include identified buildings, structures, districts, and Multiple Property Document Forms associated with individuals and/or firms that have made or constructed unusual, important, or otherwise distinctive designs. Finally, eligible properties include examples of architecture calling attention to the widely varied stylistic influences, which have affected the study area.Criterion D. Sites of nonextant properties, which contain intact subsurface deposits with good information potential concerning the material culture of identifiable and significance architectural resources. Individual House (Site #28) (deferred) 32 Vinton Street Palo. IA 3*18 E. Districts. Buildings. Structures. Sites. and Features Associated with Architectural Resources of Fayette Township. 1 .

Description:

Resources differ as to property type and can include central business districts, neighborhood commercial districts. public and semi-public clusters, industrial and light-industrial concentrations, and fannsteads. Resources can also include individually eligible properties, such as commercial and business stores, shops, and offices; public and semi-public resources such as schools and churches, social and other meeting halls; and agriculnrral resources such as farmhouses, barns, silos, and other outbuildings. Designed historic landscapes may qualify under this historic context and can include parks, recreational areas, cemeteries, windbreaks, hedgerows, and/or other manifestations of human planning and manipulation of the natural environment.

2. Significance:

Significance can derive from building materials, whose physical opportunities and constraints affect residential architecture; from significant characteristics of scale and its employment; and from form as it provides diagnostic analysis for architectural significance. Significance can also derive from the variety of ways in which stylistic influences have contributed to the architectural heritage of the study area. Finally, significance can derive from contractor-builders who have contributed to the local built environment Although scale and form comprise defining characteristics for these historic resources, the significance claimed must be rigorously linked to a comprehensive evaluation of resources in the study area exhibiting similar characteristics. A compelling case must also be made for their significance over-and-above the diagnostic analysis provided in this report. 3. Registration Requirements: Criterion A. Properties associated only with this context will not have significance under Criterion A. Criterion B. Properties that are directly associated with individuals, groups, or other associations of people who played a leading, pivotal, or important role in shaping architectural developments in the study area during the Early Settlement Era, Expansion Era, or Consolidation Era. Criterion C. Eligible properties include vernacular building types that contribute to the distinctive character of Fayette Township. Eligible properties also include identified buildings, structures, districts, and Multiple Property Document Forms associated with individuals and/or firms that have made or constructed unusual, important, or otherwise distinctive designs. Finally, eligible properties include examples of architecture calling attention to the widely varied stylistic influences, which have affected the study area Criterion D. Sites of nonextant properties, which contain intact subsurface deposits with good information potential concerning the material culture of identifiable and significance architectural resources. 3-19 Integrity Considerations: Many of the residential buildings in Palo were originally built small in scale and of a basic design. Because of this small scale, much of this housing stock has expanded over the years with the addition of wings and additions. As a consequence, building alterations and changes are frequently encountered in Palo. Because these alterations have been imposed on small buildings, such changes are usually quite evident Recognition should be made for this phenomenon but should not over-ride standard integrity considerations. Few, if indeed any, distinctions were found to differentiate institutional or residential architecture as practiced in the countryside and in Palo. For this reason, the same integrity considerations can be employed to evaluate these resources.

4. Potentially Eligible Properties:

Histtoric Districts Palo Historic Commercial District Palo, IA Vinton Street Historic District Palo, IAResources Eligible Under a Iohn Livermore Multiple Property Document Form Yates Bros. General Store (Site #2)100-102 Vinton Street Palo, IA W. C. Wright Grocery Store (Site #12)114 Vinton Street Palo, IA Commercial Building (Site # I C)105 1st Street Palo, IA John Livermore House (Site #73A)607 2nd Street Palo, IAJohn Livermore Factory (Site #73B)609 2nd Street Palo, IAPrivy (Site

1. 75)106-1/2 Vinton Street Palo, IAGarage (Site
2. 76)104-1/2 Vinton Street Palo, IA (I ! 3-19 Integrity Considerations:

Many of the residential buildings in Palo were originally built small in scale and of a basic design. Because of this small scale, much of this housing stock has expanded over the years with the addition of wings and additions. As a consequence, building alterations and changes are frequently encountered in Palo. Because these alterations have been imposed on small buildings. such changes are usually quite evident. Recognition should be made for this phenomenon but should not over-ride standard integrity considerations. Few, if indeed any, distinctions were found to differentiate institutional or residential architecture as practiced in the countryside and in Palo. For this reason, the same integrity considerations can be employed to evaluate these resources.

4. Potentially Eligible Properties:

Historic Districts Palo Historic Commercial District Palo,IA Vinton Street Historic District Palo,IA Resources Eligible Under a John Liyennore Multiple Pro.perty Document Fonn Yates Bros. GenernI Store (Site #2) 100-102 Vinton Street Palo,IA W. C. Wright Grocery Store (Site #12) 114 Vinton Street Palo,lA Commercial Building (Site #Ie) 105 I st Street Palo,IA John Livennore House (Site #73A) 6fJ7 2nd Street Palo,IA John Livennore Factory (Site #73B) 609 2nd Street Palo,IA Privy (Site #75) 106-1/2 Vinton Street Palo,IA Garage (Site #76) 104-1/2 Vinton Street Palo,IA 3-20 House (Site #28) (dfefed)32 Vinton Street Palo, IAHouse (Site

1. 43)301 Main Street Palo, IAHouse (Site
2. 47)401 Main Street Palo, IA House (Site #49)501 Main Street Palo, IA House (Site #50)101 Clinton Street Palo, IA House (Site #60)808 2nd Street Palo, IA House (Site #68)1st Street, 1st House South of Clinton Street on East Side Palo, IA Individuals House (Site #28) (deferred) 32 Vinton Street Palo,IA House (Site #43) 301 Main Street Palo,IA House (Site #47) 40 1 Main Street Palo,IA House (Site #49) 501 Main Street Palo,IA House (Site #50) 101 Clinton street Palo,IA House (Site #60) 808 2nd Street Palo; IA House (Site #68) 3*20 1st Street, 1st House South of Clinton Street on East Side Palo,IA TABLE 3-1. ARCHAEOLOGICAL SITE

SUMMARY

Site No. Location Landform Site Temporal Subsurface Extant Bldgs/ Plowed Artifact Surface Shovel Site NRHP Sect-T-R Position Type. Range* Feat Pot. Foundations Density Vis. Tested Area** Potential 13LN 23 31-85-8 Ridgetop P/H hab unknown Low 13LN 41 6-84-8 Ridgetop P/H hab unknown Low 13LN 71 6-84-8 Slope P/H hab unknown LOw 13LN332 29-84-8 Terrace P/H hab mid-late 19th High c.1869-c.1881 13LN333 18-84-8 Tenre H mill no artifacts Low c. 1859-1900 13LN334 18-84-8 Bluff H quarry no artifacts Low c. 1840s-1950s 13LN335 18-84-8 Bench H hab no artifacts High 20th century 13LN336 32-85-8 Terrace H mill? non-diagnostic High c.1859-c.1881 13LN337 17-84-8 Terace P/H hab non-diagnostic Low c.1869-c.1881 13LN338 17-84-8 Tamnce P/H hab mid-19th c.+ High c.1859-c.1869 13LN339 19-84-8 Footslope H hab 20th c. High c.1869-1960s 13LN340 16-84-8 Terrace H hab late 19th c.+ Low c. 1881 13LN341 16-84-8 Terrace H hab mid 19th c. Low c.1859-c.1881 13LN342 16-84-8 Terrace H school early 20th c. Low c.1869-1914+ 13LN343 16-84-8 Terrace H hab mid-late 19th Low c.1869 13LN344 16-84-8 T~race H 1mb 20th c. LOw c.1869-1938+ 13LN345 17-84-8 Ridgetop H hab mid 19th c. High c. 1859-c.1869 No Yes No Yes No Yes No/LS Found Yes No/LS Found No No/C Found No No/C Found No No Yes No Yes No Yes Yes/both No No Yes No Yes No Yes No Yes Yes Yes No Yes unknown No unknown No unknown No Dense Good Yes Sparse Poor No Sparse Fair No Sparse Poor No Sparse Good No Sparse Good No Dense Good Yes Dense Poor Yes Mod. Fair No Mod. Fair No Sparse Fair No Mod. Good No Mod. Fair NoMod. Good No V? No.? No.? No 8280 Yes 150 No 8280 No 100 No 8280 Yes 5550 No 6920 Yes 8280 Yes 3720 No 900 No 900 No 1830 No2025 No 2745 Yes I-.TABLE 3-1. ARCHAEOLOGICAL SITE

SUMMARY

Site No. Location Landform Site Temporal Subsurface Extant Bldgs/ Plowed Artifact Surface Shovel Site NRHP Sect-ToR Position Type Range'" Feat Pot. Foundations Density Vis. Tested Area"'* Potential 13LN23 31-85-8 Ridgetop PIR hah unknown Low No Yes unknown No 7l No 13LN 41 6-84-8 Ridgetop P/H bab unknown Low No Yes unknown No ?? No 13LN 71 6-84-8 Slope P/H bab unknown Low No Yes unknown No ?! No 13LN332 29-84-8 Terntee P/H hab mid-late 19th High NolLS Found Yes Dense Good Yes 8280 Yes c.I869-c.1881 13LN333 18-81H Terrace H mill no artifacts Low NolLS Found No Sparse Poor No 150 No c.1859-1900 I3LN334 18-84-8 Bluff Hquarry no artifacts Low No/CFound No Sparse Fair No 8280 No c. 1840s*1950s 13LN335 18-84-S Bench Hhab no artifacts High No/CFound No Sparse Poor No 100 No w I 20th century tv 13LN336 32-85-8 Terntee H mill? non-diagnostic High No Yes Sparse Good No 8280 Yes I-' c.lS59-c.l8S1 13LN337 17-84-8 Terrace P/H hah non-diagnostic Low No Yes Sparse Good No 5550 No c.1869-c.1881 13LN338 17-84-8 Tmace P/H hah mid-19th c.+ High No Yes Dense Good Yes 6920 Yes c.1859-c.1869 13LN339 19-84-8 Footslope H bab 20th c. High Yes/both No Dense Poor Yes 8280 Yes c.1869-1%Qs 13LN340 16-84-8 Terntee Hbab late 19th c.+ Low No Yes Mod. Fair No 3720 No c. 1881 13LN341 16-84-8 Terntee Hhab mid 19th c. Low No Yes Mod. Fair No 900 No 13LN342 16-84-8 Terrace H school early 20th c. Low No Yes Sparse Fair No 900 No c.1869-1914+ 13LN343 16-84-8 Tmace Hhab mid-late 19th Low No Yes Mod. Good No 1830 No c.1869 13LN344 16-84-8 Terrnce Hhab 20th c. Low Yes Yes Mod. Fair No 2025 No c.l869-1938+ 13LN345 17-84-8 Ridgetop Hhab mid 19th c. High No Yes Mod. Good No 2745 Yes c.1859-c.1869 Site No. Location Landfom Site Sect-T-R Position Type 13LN346 18-84-8 Footslope H hab 13LN347 18-84-8 Terrace P/H hab 13LN348 18-84-8 Terrace H school 13LN349 17-84-8 Terrace H hab 13LN350 17-84-8 Terrace H school 13LN351 19-84-8 Slope Hhab 13LN352 19-84-8 Slope H hab 13LN353 19-84-8 Slope H hab 13LN354 19-84-8 Ridgetop H hab 13LN355 19-84-8 Knoll H hab 13LN356 19-84-8 Knoll H school13LN357 29-84-8 Terrace H hab 13LN358 30-84-8 Terrace H hab 13LN359 30-84-8 Footslope H school 13LN360 28-84-8 Terrae H hab 13LN361 28-84-8 Terrace H hab 13LN362 9-84-8 Terrace H hab 13LN363 9-84-8 Knoll H hab TABLE 3-1. CONTINUED Temporal Subsurface Extant Bldgs/ Plowed Artifact Surface Shovel Site NRHP Range* Feat Pot. Foundations Density Vis. Tested Area** Potential mid 19th+ High No/LS Found No Mod. Fair No 3721 Yes c.1859-1938+ mid 19th c. Low No Yes Mod. Good No 225 No c.1859-c.1869 no artifacts Low No/Buried No Sparse Poor No 225 No c.1881-c.1895 mid 19th c. High No Yes Mod. Poor No 900 Yes c.1869 non-diagnostic Low No Yes Sparse Fair No 675 No c.1859-c.1869 mid 19th c. Low No Yes Sparse Good No 900 No c.1859-1869 mid 19th c. High No Yes Mod. Fair No 2025 Yes c.1859-c.1869 mid 19th c. High No Yes Sparse Fair No 900 Yes c.1859-c.1869 mid 19th c. High No Yes Dense Fair No 3720 Yes c.1859-c.1881 mid-late 19th Low No Yes Sparse Good No 80 No c.1869 non-diagnostic Low No Yes Sparse Fair No 1140 No c.1869mid-19th c. Low No Yes Sparse Good No 530 No c.1859-c.1881 19th c. Low No Yes Sparse Fair No 900 No c.1869 19th-20th

c. Low No Yes Mod. Fair No 900 No c.1895-c.1906 latel9th-20th High No Yes Dense Fair No 2745 No c.1881-1930+

mid 19th c. Low No Yes Sparse Fair No 530 No c. 1859 19th c. Low No Yes Sparse Good No 1035 No c.1859-c.1869 late 19th-20th High No/LS Found No Sparse Poor Yes 8280 Yes c.1869-20th c.W (A)N, TABLE 3-1. CONTINUED Site No. Location Landform Site Temporal Subsurface Extant Bldgs/ Plowed Artifact Surface Shovel Site NRHP Sect-ToR Position TYU e Range* Feat Pot Foundations Density Vis. Tested Area"' Potential 13LN346 18-84-8 Footslope H hab mid 19th+ High NolLS Found No Mod. Fair No 3721 Yes c.1859-193S+ 13LN347 18-84-8 Terrace P/H hab mid 19th c. Low No Yes Mod. Good No 225 No c.1859-c.1869 13LN348 18-84-8 Terrace H school no artifacts I:ow NQlBuried No Sparse Poor No 225 No c.l881-c.1895 13LN349 17-84-8 Tenace Hbab mid 19th c. High No Yes Mod. Poor No 900 Yes c.l869 13LN350 17-84-8 Terrace Hschool non-diagnostic Low No Yes Sparse Fair No 675 No c.l859-c.1869 13LN351 19-84-8 Slope Hhab mid 19th c. Low No Yes Sparse Good No 900 No c.1859-1869 13LN352 19-84-8 Slope : Hhab mid 19th c. High No Yes Mod. Fair No 2025 Yes c.1859-c.l869 13LN353 19-84-8 Slope Hhab mid 19th c. High No Yes Sparse Fair No 900 Yes w c. 1859-c. 1869 1 13LN354 19-84-8 Ridgetop Hhab mid 19th c. High No Yes Dense Fair No 3720 Yes N N c.1859-c.l881 13LN355 19-84-8 Knoll Hbab mid-late 19th Low No Yes Sparse Good No SO No c.I869 13LN356 19-84-8 Knoll H school non-diagnostic Low No Yes Sparse Fair No 1140 No c.1869 13LN357 29-84-8 Tenace Hhab mid-19th c. Low No Yes Sparse Good No 530 No c.1859-c.1881 13LN358 30-84-8 Terrace Hhab 19th c. Low No Yes Sparse Fair No 900 No c.1869 13LN359 30-84-8 Footslope H school 19th-20th

c. Low No Yes Mod. Fair No 900 No c.l895-c.1906 13LN360 28-84-8 Terrace Hhab Iate19th-20th High No Yes Dense Fair No 2745 No c.1881-1930+

13LN361 "28-84-8 Terrace Hhab mid 19th c. Low No Yes Sparse Fair No 530 No c.1859 13LN362 9-84-S Terrace Hhab 19th c. Low No Yes Sparse Good No 1035 No c.I859-c.lS69 13LN363 9-84-8 Knoll Hhab late 19th-20th High NolLS Found No Sparse Poor Yes 8280 Yes c.l869-20th

c.

Site No. Location Landfrm Site Pnehinn Tvnp 13LN364 9-84-8 Fan H hab 13LN365 9-84-8 Ridgetop H hab 13LN366 4-84-8 Ridgetop H hab 13LN367 8-84-8 Terrace H hab 13LN368 7-84-8 Ridgetop H hab 13LN369 7-84-8 Toeslope H hab 13LN370 7-84-8 Ridgetop P/H hab 13LN371 6-84-8 Ridgetop H hab 13LN372 6-84-8 Ridgetop H hab 13LN373 5-84-8 Blufftop H hab 13LN374 5-84-8 Blufftop H church13LN375 32-85-8 Fan H hab 13LN376 29-85-8 Terrace H hab 13LN377 19-85-8 Terrace P/H hab 13LN378 16-84-8 Tmeff H hab 13LN379 30-85-8 Ridgetop H hab sideslope 13LN380 29-84-8 Terrace H depot 13LN381 19-85-8 Bluffedge H quarry TABLE 3-1. CONTINUED Temporal Subsurface Extant Bldgs! Plowed Artifact Surface Shovel Site NRHP Range* Feat Pot. Foundations Density Vis. Tested Are** Potential late I9th-20th High No/Found No Sparse Poor Yes 5550 Yes c. 1869+19th-20th

c. High No No Sparse Poor No 900 Yes v.1859-c.1881 19th c, High No No Sparse Poor No 3720 Yes c.1869-1930+

mid-latel9th Low No -Yes Mod. Fair No 2025 No not on maps mid 19th c. High No No Dense Fair No 900 Yes c.1859-c.1869 mid-late 19th High No No Mod. Fair No 450 Yes c.1859-c.1869 mid 19th c.+ High No Yes Dense Fair No 1444 Yes c.1859-c.1869 no artifacts High No/C Found No Sparse Poor No 900 No c. 1869-1960s no artifacts Low No No Sparse Poor No 900 No v.1895-1960s late 19th-20th High No Yes Mod. Good No 1350 Yes c.1869-1930+ no artifacts Low No/LS Found No Sparse Poor No 900 Yes c.1881-1930+ mid-late 19th High No Yes Mod. Fair No 3720 Yes c.1869-c.1881 late l9th-20th High No/LS Found Yes Dense Fair No 1140 Yes c.1869-1960s non-diagnostic L.w No Yes Sparse Good No 225 No c.1869 mid-late 19th Low No No Mod. Good No 1035 No c.1869-1906+ no artifacts High No/LS Found No Sparse Poor No 1830 Yes c.1869 no artifacts Low No/C Found No Sparse Poor No 225 No c.1869-1960 no artifacts Low No No Sparse Poor No 14,760 Yes c.1869 W W TABLE 3a!. CONTINUED Site No. Location Landfonn Site Temporal Subsurface Extant Bldgs/ Plowed Artifact Surface Shovel Site NRHP Sect-ToR Position Type Range1/< feat Pot. Foundations Density Vis. Tested Area';'1/< Potential 13LN364 9-84-8 Fan Hhab late 19th-20th High NolFound No Sparse Poor Yes 5550 Yes c.1869+ 13LN365 9-84-8 Ridgetop Hhab 19th-20th

c. High No No Sparse Poor No 900 Yes c.1859-c.1881 13LN366 4-84-8 Ridgetop Hhab 19th c. High No No Sparse Poor No 3720 Yes c.1869-1930+

13LN367 8-84-8 Terrace Hhab mid-latel9th Low No-Yes Mod. Fair No 2025 No not on maps 13LN368 7-84-8 Ridgetop Hhab mid 19th c. High No No Dense Fair No 900 Yes c.1859-c.l869 13LN369 7-84-8 ToesJope Hhab mid-late 19th High No No Mod. Fair No 450 Yes c.1859-cJ 869 13LN370 7-84-8 Ridgetop PIH hah mid 19th c.+ High No Yes Dense Fair No 1444 Yes c. 1859-c. 1869 13LN371 6-84-8 Ridgetop Hhab no artifacts High NolCFound No Sparse Poor No 900 No c.1869-1960s w I 13LN372 6-84*8 Ridgetop Hhab no artifacts Low No No Sparse Poor No 900 No N c.1895-1960s w 13LN373 5*84-8 Blufftop Hhab late 19th-20th High No Yes Mod. Good No 1350 Yes c.1869-1930+ 13LN374 5*84-8 Blufftop Hchurch no artifacts Low No/LSFound No Sparse Poor No 900 Yes c.1881-1930+ 13LN375 32-85-8 Fan Hhab mid-late 19th High No Yes Mod. Fair No 3720 Yes c.1869-c.1881 13LN376 29-85-8 Terrace Hhab late 19th-20th High No/LSFound Yes Dense Fair No 1140 Yes c.1869-1960s 13LN377 19-85-8 Terrace PIH hab non-diagnostic LOw No Yes Sparse Good No 225 No c.1869 13LN378 16-84-8 Terrace Hhab . mid-late 19th Low No No Mod. Good No 1035 No c.l869-1906+ 13LN379 30-85-8 Ridgetop Hhab no artifacts High No/LSFound No Sparse Poor No 1830 Yes sideslope c.l869 I3LN380 29-84-8 Terrnce Hdepot no artifacts Low No!CFound No Sparse Poor No 225 No c.1869-1960 13LN381 19-85-8 Bluffedge Hquarry no artifacts Low No No Sparse Poor No 14,760 Yes c.l869 TABLE 3-1. CONTINUEDSite No. Location Landform Site Temporal Subsurface Extant Bldgs/ Plowed Artifact Surface Shovel Site NRHP Sect-T-R Position Type Range* Feat Pot. Foundations Density Vis. Tested Area** Potential 13LN382 18-84-8 Bluffedge H quarry no artifacts Low No No Sparse Poor No 3720 No l9th-20th c, 13LN383 4-84-8 Bluffedge H quany no artifacts Low No No Sparse Poor No 3720 No 13LN384 31-85-8 Ridgetop Hroad no artifacts Low No No Sparse Poor No 6360 Yes c.1859 13LN385 8-84-8 Ridgetop H hab no artifacts Low Yes/LS Found No Sparse Poor No 225 No c.1881-1930+ 13LN386 17-84-8 Terrace H hab no artifacts Low Yes/LS Found No Sparse Poor No 225 No c.1869-c.1895First line temporal range based on diagnostic artifacts collected; second line based on historic map data Site area is calculated in square feet H= Historic N Prehistoric habI+/- Habitation site C-= Concrete/cement foundation LS= Limestone foundation Vis.= Visibility [Poor = 0-30%; Fair = 30-70%; Good= 70-100%]Feat. Pot.= Featue potential NRHIP= National Register of Historic PlacesMod.= Moderate LA]TABLE 3-1. CONTINUED Site No. Location Landfomt Site Temporal Subsurface Extant Bldgs/ Plowed Artifact Surface 13LN382 13LN383 13LN384 13LN385 13LN386 *$= H= P= hab= C= LS= Vis.= Feat. Pot.= NRHP= Mod.= Sect-T-R Position Type Range$ Feat Pot. Foundations Density Vis. 18-84-8 Bluffedge Hquarry no artifacts Low No No Sparse Poor 19th-20th

c. 4-84-8 Bluffedge Hquarry no artifacts Low No No Sparse Poor 31-85-8 Ridgetop Hroad no artifacts Low No No Sparse Poor c.1859 8-84-8 Ridgetop Hbab no artifacts Low Yes/LS Found No Sparse Poor c.1881-1930+

17-84-8 Termce Hbab no artifacts Low Yes/LS Found No Sparse Poor c.1869-c.l895 First line tempomI range based on diagnostic artifacts collected; second line based on historic map data Site area is calculated in square feet Historic Prehistoric Habitation site Concrete/cement foundation Limestone foundation Visibility [Poor = 0-30%; Fair = 30-70%; Good>:: 70-100%] Feature potential National Register of Historic Places Moderate Shovel Site Tested Area** No 3720 No 3720 No. 6360 No 225 No 225 NRHP Potential No No Yes No No W I N TABLE 3-2. ARCHAEOLOGICAL SITE HISTORICAL ASSOCIATIONS. Site ..... ........ .-..... ........ ...Shown on H istoricalMaps .... ... ........ ... .. ......... ..... ... ..Number 1859-1869 1881-1895 1906-1914 1930-1938 13LN 23 13LN 41 13LN 71 13LN332 13LN333 13LN334 13LN335 13LN336 13LN337 13LN338 13LN339 13LN340 13LN341 13LN342 13LN343 13LN344 13LN345 13LN346 13LN347 13LN348 13LN349 13LN350 13LN351 13LN352 13LN353 13LN354 13LN355 13LN356 13LN357 13LN358 13LN359 13LN360 13LN361 13LN362 13LN363 none none none/L.W. Johnson none/John Mills John Lewis/F. Potter John Lewis/F. Potter none Katieville/D. Richards none/John Cue John Cue none/M. Chipman none G. 'Bouton/J. Conkirk none/school none/N. Wells none/A. Fletcher N. Miller/J. Vankirk J. Strawn J. Railsback nonenone/J. Railsback school S. McVay/C. McVay M. Reed/J. Rife W. Roberts/E. Cue?Fisher/E. Fisher N. Miller?/E. Miller none/school J. Mills/J. Whitney none/iJ. Cue nonenone/M. McMannus? J. McMannus/unknownunknown/G. Drage none/J. Ray none none C.N. Evans/none E. Mills/none Bowe & Walker/R. Bowe Bowe & Walker/R. Bowe none D. Richards/none John Cue/none none M. Chipman/B.F. Yates G. Jackson/none G. Davidson/none school/school unknown/none M. Fish/M. Fish, estate none M. Strawn none school none moved to another location unknown/none J. Rife?/none none A. Fisher/none none unknown/none J. Trontman, estate/none none none/school J. McMannus none none J. Ray none none none none/none Moved in 1900 N.Stookey none none none none H.A. Yates/L.B. Young none none school/school none N. Oyer none M. Strawn/S, Stookey none unknown none returned to site?none none none none none none none none school/none A. McMannus none none J. McClintock/unknown none none none none/none Burned 1976N.Stookey/NW Mutual unknown none none none C. Frantz none none none noneJ. McCorkle none S. Stookey/M. Stookey none none none none none none none none none none none none none E. Drake none none unknown (Yr TABLE 382. ARCHAEOLOGICAL SITE HISTORICAL ASSOCIA nONS. Site ------------------------------------Shown on Historical Maps----------------------------------------------------- Number 1859-1869 1881-1895 1906-1914 1930*1938 13LN23 none none none none 13LN 41 none none none none 13LN71 nonelL.W. Johnson C.N. Evans/none none none 13LN332 none/John Mills E. Mills/none none/none none/none 13LN333 John Lewis/F. Potter Rowe & Walker/R. Bowe Moved in 1900 Burned 1976 13LN334 John Lewis/F. Potter Bowe & Walker/R. Bowe N.Stookey N.Stookey,INW Mutual 13LN335 none none none unknown 13LN336 Katieville/D. Richards D. Richards/none none none 13LN337 none/John Cue lohn Cue/none none none 13LN338 John Cue none none none 13LN339 nonelM. Chipman M. Chipman/B.F. Yates H.A. Yates/L.B. Young C. Frantz 13LN340 none G. Jackson/none none none 13LN341 G. 'Bouton/J. Conkirk G. Davidson/none none . none 13LN342 none/school schooVschool schooVschool none 13LN343 noneIN. Wells unknown/none none none w 13LN344 none/A. Fletcher M. FishIM. Fish, estate N.Oyer J. McCorkle I N 13LN345 N. MillerlJ. Vankirk none none none Ul 13LN346 J. Strawn M. Strawn M. Strawn/S. Stookey S. StookeylM. Stookey 13LN347 1. Railsback none none none 13LN348 none school unknown none 13LN349 none/I. Railsback none none none 13LN350 school moved to another location returned to site? none 13LN351 S. McVay/C. McVay unknown/none none none 13LN352 M. Reed/J, Rife J. Rife?/none none none 13LN353 W. RobertslE. Cue? none none none 13LN354 FisherlE. Fisher A. Fisher/none none none 13LN355 N. Miller?/E. Miller none none none 13LN356 none/school unknown/none none none 13LN357 J. Mills/J. Whitney J. Trontman, estate/none none none 13LN358 none/J. Cue none none none 13LN359 none none/school schooVnone none 13LN360 J. McMannus A. McMannus E.Drake 13LN361 J. McMannus/unknown none none none 13LN362 unknown/G. Drage none none none 13LN363 none/J. Ray J. Ray J. McClintock/unknown unknown TABLE 3-2. CONTINUED. Site .... .. ... ..... .... ..... ... .. ..Sh ow n on Historical M aps-------- ........ ... ....-Number 1859-1869 1881-1895 1906-1914 1930-1938 13LN364 none/unknown J. Shurtleff J. Shurleff J. Shurteff/unknown 13LN365 J. McClintock/C. Harris W. Beatty/none none none 13LN366 none/J. McClintock J. McClintock/S. McClintock J. McClintock J. McClintock, estate 13LN367 none none Railsback?/none none 13LN368 N. Smith/D. Hunter none none none 13LN369 N. Smith/D. Hunter none none none 13LN370 0. Swallum/G. Swallum none none none 13LN371 none/S. Knight none/W. Mather none 0. Lint 13LN372 none none/S. Mather R. Mather Mather/C. Stodula 13LN373 none/A. Elson A. Elson A. Elson J. Stodula 13LN374 none M.E. Church Church Church 13LN375 none/Thomas Lewis Thomas Lewis/none none none 13LN376 none/J. Rice S. Hanover/G. Hannover G. Hannover/A. Stockton L. Kelly 13LN377 none/R. Patterson none none none 13LN378 Goldsmith?Leipold & Langguth Leipold & Langguth/none E. Langguth/none none 13LN379 none/D. Richards none none none 13LN380 none Palo depot Palo depot Palo depot 13LN381 none/G. Lockley none none none 13LN382 none none none none 13LN383 none none none none 13LN384 possibly shown in 1859 none none none 13LN385 none/possibly shown, illegible N.F. Miller/J.C. Adair J.C. Adair C. Adair 13LN386 none/J. Railsback J. Railsback none none W TABLE 3-2. CONTINUED. Site _________________________________________ Shown on Historical Maps----------------------------------------------- Number 1859-1869 1881-1895 1906-1914 1930-1938 13LN364 none/unknown J. Shurtleff J. Shurtleff J.Shurtlefqunknown 13LN365 J. McClintock/C. Harris W. Beatty/none none none 13LN366 nonen. McClintock J. McClintock/S. McClintock J. McClintock J. McClintock, estate 13LN367 none none Railsback? /none none 13LN368 N. Smith/D. Hunter none none none 13LN369 N. Smith/D. Hunter none none none 13LN370 O. Swallum/G. Swallum none none none 13LN371 none/So Knight none/W. Mather none O. Lint 13LN372 none none/S. Mather R. Mather Mather/C. Stodula 13LN373 none/A. Elson A. Elson A. Elson J. Stodula 13LN374 none M.E. Church Church Church 13LN375 nonefIbomas Lewis Thomas Lewis/none none none 13LN376 none/J. Rice S. Hanover/G. Hannover G. Hannover/A. Stockton L. Kelly 13LN377 none/R. Patterson none none none 13LN378 GOldsmith?Leipold & Langguth Leipold & Langguth/none E.Langguth/none none w I 13LN379 noneID. Richards none none none tv 13LN380 none Palo depot Palo depot Palo depot Q) 13LN381 none/G. LocIdey none none none 13LN382 none none none none 13LN383 none none none none 13LN384 possibly shown in 1859 none none none 13LN385 none/possibly shown, illegible N.F. Milier/J.C. Adair J.C. Adair C. Adair 13LN386 none/J. Railsback J. Railsback none none 3-27 TABLE 3-3. ARTIFACT COLLECTION

SUMMARY

.Site -Ceranics -Glass---- Metal Other Lime- Prehistoric Total Number EW SW OTBR BG WG TB OT N OT Material stone Count 13LN23 13LN41 13LN.71 13LN332 13LN333 13LN334 13LN335 13LN336 13LN337 13LN338 13LN339 13LN340 13LN341 13LN342 13LN343 13LN344 13LN345 13LN346 13LN347 13LN348 13LN349 13LN350 13LN351 13LN352 13LN353 13LN354 13LN355 13LN356 13LN357 13LN358 13LN359 13LN360 13LN361 13LN362 13LN363 13LN364 13LN365 13LN366 13LN367 13LN368 13LN369 13LN370 13LN371 13LN372 13LN373 13LN374 13LN375 13LN376 13LN377 13LN378 13LN379 5 2 0 0 0 1 119 501 0 0 0 0 0 0 0 2 0 45 28 16 1 20 19 28 9 1 0 11 6 11 6 39 3 14 0 34 10 0 0 17 9 2 0 29 8 13 7 14 3 45 13 20 8 2 0 8 0 16 0 10 0 21 25 10 3 10 0 24 14 6 1 2 71 1 17 448 26 32 2 88 23 0 0 0 0 18 15 0 0 34 14 43 35 1 0 38 8 0 0 0 0 0 0 0 0 4 44 0 0 0 0 0 0 0 2 0 1 1 12.1 12 0 0 1 1 0 1 0 0 0 0 0 1 0 1 2 1 0 0 0 3 0 1 0 2 0 0 0 1 1 1 0 1 0 1 0 0 0 0 0 0 3 **0 0 0 11 12 0 4 0 1 0 1 0 0 1 5 0 0 4 ]0 0 0. 0 1 0 0 0 0 21 5 0 01 1 0 0 2 2 0 2 0 0 15 28 0 0 0 0 0 0 0 0 1 1 9 7 76 4 19 5 2 10 1 2 6 2 2 4 5 10 3 8 2 5 0 0 2 3 0 7 9 7 4 2 3 1 13 15 4 10 0 6 1 0 0 0 3 0 12 2 0 0 0 0 6 1 11 121 3 0 0 3 2 18 12 1 2 5 14 0 0 0 0 7 4 0 0 5 2 32 13 0 3 13 10 0 0 0 0 0 0 0 0 7 2 0 1 0 0 0 0 0 0 0 0 2 0 8 25 2 4 0 2 0 0 0 1 2 0 0 0 0 0 0 0 0 0 0 2 0 0 0 0 0 0 0 0 3 01 0 0 0 0 1 0 0 0 1 6 4 0 0 0 0 0 0 0 1 1 41 0 0 0 0 10 2 0 2 0 0 0 0 0 2 5 0 03 1 6 4 0 0 0 5 0 01 0 0 4 0 1 7 19 0 0 0 0 0 0 0 2 2 9 23 40 25 35 1 2 0 0 0 0 0 0 0 0 0 0 0 1 9 2 0 0 0 1 0 0 4 2 0 0 0 0 0 5 0 01 0 0 0 0 0 0 0 0 1 0 0 0 03 11 9 3 0 0 0 0 1 2 6 1 0 1 2 6 0 0 0 0 0 0 0 0 0 2 0 4 0 1 0 0 0 0 0 7 0 24 0 0 0 0 1 4 25 5 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 1 0 0 0 0 0 0 8 0 0 0 0 0 0 27 0 0 0 0 1 34 0 3 2 1 0 0 2 1 2 0 0 50+2 1 0 0 0 0 0 0 1 0 2 2 2 0 0 0 0 3 0 12 13 2 349 2 0 0 4 19 205 228 80 54 6 26 26 61 28 82 0 37 60 62 26 24 98 46-11 10 17 15 74 13 12 74 47 20 4 31 129 42 156 0 0 52 0 63 152 7 85 0 3-27 TABLE 3-3. ARTlTFACT COLLECTION

SUMMARY

. Site --Ceramics-- --Glass--Metal Other Lime-Prehistoric Total Number EW SW OT BR BOWG TB OT N OT Material stone CQunt 13LN23 5 2 0 0 2 2 0 0 I 0 0 0 II< 12 13LN41 0 0 0 0 0 2 0 0 0 4 7 0 II< 13 13LN71 0 1 0 0 0 0 0 0 0 1 0 0

• 2 13LN332 119 50 4 44 15 28 7 2 7 19 24 27 3 349 13LN333 1 0 0 0 0 0 0 1 0 0 0 0 0 2 13LN334 0 0 0 0 0 0 0 0 0 0 0 0 0 0 13LN335 0 0 0 0 0 0 0 0 0 0 0 0 0 0 13LN336 0 0 0 2 0 0 0 0 0 2 0 0 0 4 13LN331 2 0 0 I 1 1 0 0 2 9 I 1 I 19 13LN338 45 28 1 12 9 7 2 0 23 40 4 34 1 205 13LN339 16 1 1 12 76 4 8 25 25 35 25 0 0 228 13LN340 20 19 0 0 19 5 2 4 1 2 5 3 0 80 13LN341 28 9 1 1 2 10 0 2 0 0 0 2 0 54 13LN342 1 0 0 1 1 2 0 0 0 0 0 I 0 6 13LN343 11 6 0 0 6 2 0 1 0 0 0 0 0 26 13LN344 11 6 0 0 2 4 2 0 0 0 1 0 0 26 13LN345 39 3 0 1 5 10 0 0 o 0 1 2 0 61 13LN346 14 0 0 1 3 8 0 0 0 1 0 1 0 28 13LN347 34 10 2 1 2 5 0 0 9 2 0 2 15 82 13LN348 0 0 0 0 0 0 0 0 0 0 0 0 0 0 13LN349 17 9 0 3 2 3 0 2 0 1 0 0 0 37 13LN350 2 0 0 1 0 7 0 0 0 0 0 50+ 0 60 13LN351 29 8 0 2 9 7 0 0 4 2 0 1 0 62 13LN352 13 7 0 0 4 2 0 0 0 0 0 "' 0 26 13LN3S3 14 3 0 1 3 1 0 0 0 0 0 2 0 24 13LN3S4 4S 13 1 1 13 15 3 0 0 5 1 1 0 98 13LN355 20 8 0 1 4 10 1 0 0 0 1 1 0 46 13LN356 2 0 0 1 0 6 0 0 1 0 1 0 0 11 13LN357 8 0 0 0 1 0 0 1 0 0 0 0 0 10 13LN358 16 0 0 0 0 0 0 0 0 0 I 0 0 17 13LN359 10 0 0 0 3 0 0 1 0 0 1 0 0 15 13LN360 21 25 3 ** 12 2 6 4 0 I 0 ** 0 74 13LN361 10 3 0 0 0 0 0 0 0 0 0 0 0 13 13LN362 10 0 0 I 0 0 0 0 0 0 0 1 0 12 13LN363 24 14 1 12 6 1 0 0 3 11 1 1 0 74 13LN364 6 1 0 4 11 12 0 1 9 3 0 1 0 47 13LN365 2 7 0 1 1 3 1 4 0 0 0 1 0 20 13LN366 1 1 0 1 0 0 1 0 0 0 0 0 0 4 13LN367 17 4 0 0 3 2 0 0 1 2 0 2 0 31 13LN368 48 26 1 5 18 12 0 10 6 1 1 1 0 129 13LN369 32 2 0 0 1 2 2 0 0 1 0 2 0 42 13LN370 88 23 4 I 5 14 2 0 2 6 0 2 9 156 13LN37 I 0 0 0 0 0 0 0 0 0 0 0 0 0 0 13LN372 0 0 O. 0 0 0 0 0 0 0 o . 0 0 0 13LN373 18 15 I 0 7 4 2 5 0 0 0 "'* 0 52 13LN374 0 0 0 0 0 0 0 0 0 0 0 0 0 0 13LN375 34 14 0 2 5 2 3 1 0 2 0 0 0 63 13LN376 43 35 1 5 32 13 6 4 0 4 8 1 0 152 13LN377 1 0 0 0 0 3 0 0 0 1 1 "'* 1 7 13LN378 38 8 I I 13 10 0 5 0 0 0 3 6 85 13LN379 0 0 0 0 0 0 0 0 0 0 0 0 0 0 3-28 TABLE 3-3. CONTINUED.

Site -Ceramics-Glass---- Metal Other Lime- Prehistoric Total Number EW SW OT BR BG WG TB OT N OT Material stone Count 13LN380 0 0 0 0 0 0 0 0 0 0 0 0 0 0 13LN381 0 0 0 0 0 0 0 0 0 0 0 0 0 0 13LN382 0 0 0 0 0 0 0 0 0 0 0 0 0 0 13LN383 0 0 0 0 0 0 0 0 0 0 0 0 0 0 13LN384 0 0 0 0 0 0 0 0 0 0 0 0 0 0 13LN385 0 0 0 0 0 0 0 0 0 0 0 0 0 0 13LN386 0 0 0 0 0 0 0 0 0 0 0 0 0 0*= Prehistoric artifacts present but not included in total; see Benn and Hovde 1976.**= Material present but not collected. EW= Earthenware SW= Stoneware OT= Other ceramic, glass, or metal BR= Brick BG= Bottle glass WG= Window glass Th= Tableware glass N= Nails 3-28 TABLE 3-3. CONTINUED. Site --Ceramics-- ---Glass-- Metal Other Lime-Prehistoric Total Number EW SW OT BR BGWG TB OT N OT Material stone Count 13LN380 0 0 0 0 0 0 0 0 0 0 0 0 0 0 13LN381 0 0 0 0 0 0 0 0 0 0 0 0 0 0 13LN382 0 0 0 0 0 0 0 0 0 0 0 0 0 0 13LN383 0 0 0 0 0 0 0 0 0 0 0 0 0 0 13LN384 0 0 0 0 0 0 0 0 0 0 0 0 0 0 13LN385 0 0 0 0 0 0 0 0 0 0 0 0 0 0 13LN386 0 0 0 0 0 0 0 0 0 0 0 0 0 0 10<= Prehistoric artifacts present but not included in total; see Benn and Hovde 1976. **= Material present but not collected. EW= Earthenware SW= Stoneware OT= Other ceramic, glass, or metal BR= Brick BG= Bottle glass WG= Window glass TB= Tableware glass N= Nails .. f 'I j J 0= Archaeology Sites Recorded i i!.i RESULTS OF THE FIGURE 3-1 ARCHAEOLOGICAL INVESTIGATION OF SUBSECTION E 1. i FIGURE 3 .. 1 RESULTS OF THE ARCHAEOLOGICAL INVESTIGATION OF SUBSECTION E 3-30 IN = Area Surveyed FIGURE 3-2 AREAS SURVEYED FOR ARCHAEOLOGICAL RESOURCES IN SUBSECTION E 3-30 = Area Surveyed FIGURE 3 .. 2 AREAS SURVEYED FOR ARCHAEOLOGICAL RESOURCES IN SUBSECTION E 7"-- = Areas with Potential for Buried Historic Resouro FIGURE 3-3 AREAS WITH POTENTIAL FOR BURIED HISTORIC ARCHAEOLOGICAL SITES 3-31 FIGURE 3-3 AREAS WITH POTENTIAL FOR BURIED HiSTORIC ARCHAEOLOGICAL SITES ; -::-= Areas with Potential . for Buried Historic Resouro li-"Jklo 5;-Sa. T'`36 it Ufa, E T! T 14 Big willm, 7?E K -LE-§ qESE"C ltw III CCU PAR.'Ac WIR &KA1 if i v M"..:ý4 3b..24, Fý, Al, Y-' E ý"T E i -.5 FIGURE 3-4 LOCATION OF RURAL ARCHITECTURAL PROPERTIES RECORDED DURING SURVEY FIGURE 3-4 l , :W{fIiCl",i.l JAb j ';')C' 0 ICOO ! LOCATION OF RURAL ARCHITECTURAL PROPERTIES RECORDED DURING SURVEY Note: Most ID numbers are placed at the rear of the buildings In.1.0p I I al-o .4 M66 48M M-63 56 4 li64 625 65 9 I 28 q 0C)* amal 61 59 57 55 53 51 49 0 D E 73A 41 738 39 17 35 ar[] a* a a Not to Scale Source: USGS 1:24,000 Series Map "Shellsburg, Iowa" FIGURE 3-5 L.OCATIOCN OF ARCTHTIT(IRAI, PROPERTIFS RECORDED IN PALO I I II II \. --' S ... ' , " Palo , .' . I II II I 1'1

• 19 21 42 44 -4S III II iii Ill' IilIlilIJi III II
• 61 59 57 55 53 51 49 J!1 47 0 0 -. Source: USGS 1:24,000 Series Map "Shellsburg.

Iowa" 65 Ii

• Clffr.on St, s ... Ii 24 22 II III Vinton t . -.. ..

17 40 'E .,., ., III &I III Main 51.

• II
• 43 45 III m iii-Churdl St, ill FIGURE 3-5 Note: Most ID numbers are placed at the rear of the buildings 67 &Iii II !Ill 66 481/1 l!i " 52 50 1.11 11 II 20 18 16 14B EllII ** R60 BI III ill 56 54 76 S91!1l _75 .. He 1210 8 6 2 1I111111il i!f 70 . III 26 Ill' .'63 III 1lI64 62 III III II lI! ,re * (I lA mll II II Ilm-15 13 11 9 1 5 3 18 Il!l 23 . 25 27 29 Ie. 1171 !Ii
• 36 II II ? Ii "( 36 '" 3-4 32 II i til III .72 11 I 11 13A Ij II III II all iii fI \I II 41 738 39 37 35 33 iii! II! 31
• 1'1 II ( *
• II iii III .. I
• II " ! Nol to Scale 0 1.0CATlON OF ARCfHTF.CTHRAI.

PROPERTIJi:..li RECORDED IN PALO '" I W W 4-1

SUMMARY

OF IDENTIFICATION AND EVALUATION METHODS I. OVERVIEW OF PROJECT ADMINISTRATION The survey of the historic archaeological and architectural properties of Subsection E inLinn County was accomplished through archival research, informant interviews, fieldwork, and evaluation. The project tasks were accomplished by local volunteers and project personnel, who included Project Assistant, G. Clark Rogers and Co-Principal Investigators, Leah D. Rogers and William C. Page. Research was conducted by localvolunteers, including members of the Genealogical Society of Linn County, Jane Fisher of the Linn County Historic Preservation Advisory Council, and the principal investigators. The project also benefitted from previous research conducted by: local historian, Laura Browne, who is also a member of the Advisory Council; the Palo Centennial Book Committee, who had compiled historic data and photographs concerning this community in the 1970s; and Palo residents, William and Kathy Zeller, who have an extensive historic photograph collection which aided the survey of buildings in Palo. The Zellers, Caroline Marquardt, and other Palo residents also provided a wealth of historical data concerning the houses and commercial buildings of the town and participated in the survey. The Zellers showed great zeal by reviewing each Iowa Site Inventory Form for Palo, conducting oral investigations, re-examining buildings, and adding considerably to the historical data base.Archival repositories visited included-the Office of the State Archaeologist in Iowa City;the State Historical Society of Iowa libraries in Iowa City and Des Moines; the Linn County Genealogical Research Center Library in Cedar Rapids; the Cedar Rapids Public Library; the Linn County Recorder's and Auditor's.offices in Cedar Rapids; and the Linn County Engineer's Office and Conservation Commission Headquarters near Marion.Resources examined included: historic photographs, maps, and atlases; county and local histories; population and agricultural census data; town plats; and aerial photographs. Informant interviews were conducted by project personnel and consisted of informal conversations held with property owners and local residents knowledgeable about particular sites and the project area's history. These interviews were notated but not otherwise recorded.Evaluations of recorded properties were based on the results of the survey and contextual associations and were made by the Co-Principal Investigators. Leah Rogers conducted the archaeological and rural architectural evaluations, while Will Page made the Palo architectural assessments. Ms. Rogers coordinated the project activities and carried the primary responsibility for the completion of the project and its end products. Mr. Page conducted the architectural survey portion of the project and compiled those end products and the applicable portions of the project report. G. Clark Rogers was responsible for the landowner contacts for the archaeological survey, conducted a major portion of that survey and the final processing of the artifact collections. Mr. Rogers also completed the archaeological survey results graphics for the project report, The Dunbar/Jones Partnership ): i: . '; i L 4.1

SUMMARY

OF IDENTIFICATION AND , EVALUATION METHODS OVERVIEW OF PROJECT ADMINISTRA nON The survey of the historic archaeological and architectural properties of Subsection E in Linn County was accomplished through archival research. infonnant interviews, fieldwork, and evaluation. The project tasks were accomplished by local volunteers and project personnel, who included Project Assistant, G. Clark Rogers and Co-Principal Investigators. Leah D. Rogers and William C. Page. Research was conducted by local volunteers, including members of the Genealogical Society of Linn County. Jane Fisher of the Linn County Historic Preservation Advisory Council, and the principal investigators. The project also benefitted from previous research conducted by: local historian, Laura Browne, who is also a member of the Advisory Council; the Palo Centennial Book Committee, who had compiled historic data and photographs concerning this community in the 19708; and Palo residents, William and Kathy Zeller, who have an extensive historic photograph collection which aided the survey of buildings in Palo. The Zellers,Caroline Marquardt, and other Palo residents also provided a wealth of historical data concerning the houses and commercial buildings of the town and participated in the survey. The Zellers showed great zeal by reviewing each Iowa Site Inventory Fonn for Palo, conducting oral investigations, re-examining buildings. and adding considerably to the historical data base. Archival.repositories visited included: the Office of the State Archaeologist in Iowa City; the State Historical Society of Iowa libraries in Iowa City and Des Moines; the Linn County Genealogical Research Center Library in Cedar Rapids; the Cedar Rapids Public Library; the Linn County Recorder's and Auditor's.offices in Cedar Rapids; and the Linn County Engineer's Office and Conservation Commission Headquarters near Marion. Resources examined included: historic photographs, maps, and atlases; county and local histories; population and agricultural census data; town plats; and aerial photographs. Informant interviews were conducted by project personnel and consisted of informal conversations held with property owners and local residents knowledgeable about particular sites and the project area's history. These interviews were notated but not otherwise recorded. Evaluations of recorded properties were based on the results of the survey and contextual associations and were made by the Co-Principal Investigators. Leah Rogers conducted the archaeological and rural architectural evaluations. while Will Page made the Palo architectural assessments. Ms. Rogers coordinated the project activities and carried the primary responsibility for the completion of the project and its end products. Mr. Page conducted the architectural survey portion of the project and compiled those end products and the applicable portions of the project report. G. Clark Rogers was responsible for the landowner contacts for the archaeological survey, conducted a major portion of that survey and the final processing of the artifact collections. Mr. Rogers also completed the archaeological survey results graphics for the project repon. The Dunbar/Jones Partnership 4-2 of Des Moines aided the project by providing the services of Mr. Page as well as computer, inventory site sheet compilation, and graphics support. Linn County General Services also provided mailing and copy support and a van for one of the volunteer field survey days. The City of Palo provided access to the Community Center for meetings on a number of occasions free of charge.The project began with a workshop held at the annual Linn County Historic Preservation Conference on August 30, 1992. This meeting was conducted by the Linn County Historic Preservation Commission, with the workshop led by Leah Rogers and Will Page. The meeting was attended by members of the Linn County Advisory Council and Historic Preservation Commission, local historical societies and commissions, and interested residents. The workshop focused on an introduction to the phase two survey and the National Register of Historic Places. Initial recruitment for project volunteers was also begun at this workshop,Archival research began immediately following the workshop in early September, with landowner interviews commencing on September 23, 1992. The archaeological fieldwork began in late September-early October and continued until November 21, 1992. After that time, the weather prohibited further fieldwork until March 1993. The archaeological fieldwork was largely completed by early April, although a few areas required re-examination between April and September as weather permitted. Project publicity and volunteer recruitmient were accomplished through newspaper articles, mailings, and public presentations. The latter included presentations given at the regular meetings of the Troy Mills Historical Society on September 10, 1992, the Genealogical Society of Linn County on September 24, 1992, the Lisbon Historic Preservation Commission on November 10, 1992, and the Linn County Museum's "History for Lunch" program on February 15, 1993. In addition, special presentations open to the generalpublic and held at the the Palo Community Center were given on January 14, 1993, and March 4, 1993. A second workshop was held in June 1993 to present the project results and to further training in architectural and archaeological survey for upcoming projects in the county. Articles were published concerning the project and the scheduled field and lab days for volunteers in the Cedar Rapids Gazette and the Palo Atom Burst (Appendix C).The November 5, 1992, article in the Gazette, in particular, aided tremendously in volunteer recruitment, with over 25 persons responding to that one article alone. As the survey progressed, a mailing list of all volunteers and Potential volunteers was compiled and individual notices of survey activities mailed to those individuals. A total of 47 volunteers participated donating over 380 hours to the project's activities. The response to the archaeological survey, in particular, was tremendous, although both the archaeological and architectural surveys suffered from inclement weather which discouraged volunteers and lowered attendance. Of the 47 volunteers, nearly a dozen or more have repeatedly participated in all phases of the survey and have become well trained in archaeological and architectural survey techniques. This training will be reinforced by continued surveys in the county because it is likely that the majority of this core group will continue their participation in other Subsection surveys.While we were unable to survey alternate Subsection S (a.k.a. Fl in the, SOW), we did expand the survey area of Subsection E three quarters of a mile to the south of Palo in order to better understand the resources of the Palo vicinity. A total of 2590 ac (1036 ha) was surveyed during the present investigation within Subsection E, with 55 archaeological sites and 115 architectural sites recorded. Three additional historic component archaeological sites had been recorded by previous investigations but were evaluated by the present investigation. 4-2 of Des Moines aided the project by providing the services of Mr. Page as well as computer, inventory site sheet compilation, and graphics support. Linn County General Services also provided mailing and copy support and a van for one of the volunteer field survey days. The City of Palo provided access to the Community Center for meetings on a number of occasions free of charge. The project began with a workshop held at the annual Linn County Historic Preservation Conference on August 30, 1992. This meeting was conducted by the Linn County Historic Preservation Commission, with the workshop led by Leah Rogers and Will Page. The meeting was attended by members of the Linn County Advisory Council and Historic Preservation Commission, local historical societies and commissions, and interested residents. The workshop focused on an introduction to the phase two survey and the National Register of Historic Places. Initial recruitment for project volunteers was also begun at this workshop. Archival research began immediately following the workshop in early September. with landowner interviews commencing on September 23, 1992. The archaeological fieldwork began in late September--early October and continued until November 21, 1992. After that time, the weather prohibited further fieldwork until March 1993. The archaeological fieldwork was largely completed by early April, although a few areas required examination between April and September as weather pennitted Project publicity and volunteer recruitment were accomplished through newspaper articles, mailings, and public presentations. The latter included presentations given at the regular meetings of the Troy Mills Historical Society on September 10, 1992, the Genealogical Society of Linn County on September 24, 1992. the Lisbon Historic Preservation Commission on November 10, 1992, and the Linn County Museum's "History for Lunch" program on February 15, 1993. In addition, special presentations open to the general public and held at the the Palo Community Center were given on January 14, 1993, and March 4, 1993. A second workshop was held in June 1993 to present the project results and to further training in architectural and archaeological survey for upcoming projects in the county. Articles were published concerning the project and the scheduled field and lab days for volunteers in the Cedar Rapids Gazette and the Palo Atom Burst (Appendix C). The November 5, 1992, article in the Gazette, in particular, aided tremendously in volunteer recruitment, with over 25 persons responding to that one article alone. As the survey progressed, a mailing list of all volunteers and potential volunteers was compiled and individual notices of survey activities mailed to those individuals. A total of 47 volunteers participated donating over 380 hours to the project's activities. The response to the archaeological survey, in particular, was tremendous, although both the archaeological and architectural surveys suffered from inclement weather which discouraged volunteers and lowered attendance. Of the 47 volunteers, nearly a dozen or more have repeatedly participated in all phases of the survey and have become welJ trained in archaeological and architectural survey techniques. This training will be reinforced by continued surveys in the county because it is likely that the majority of this core group will continue their participation in other Subsection surveys. While we were unable to survey alternate Subsection S (a.k.a. Fl in the SOW), we did expand the survey area of Subsection E three quartets of a mile to the south of Palo in order to better understand the resources of the Palo A total of 2590 ac (1036 ha) was surveyed during the present investigation within Subsection E, with 55 archaeological sites and 115 architectural sites recorded. Three additional historic component archaeological sites had been recorded by previous investigations but were evaluated by the present investigation. 4-3 11. ARCHAEOLOGICAL METHODS The archaeological portion of the project began with archival research which focused on the historic maps and atlases for the project area. The house site location data and other potential site locations from these maps were plotted on USGS topographic quad maps of the project area, thus pinpointing the high potential survey areas. The landowners of these parcels were then contacted in person to obtain permission to conduct surveys on their property and to learn mome about the potential sites. The response from the property owners was most encouraging and gracious. There were no refusals, and the majority were very cooperative and generous with historic information and photographs. Several provided informal tours of their property to show where sites were located. The project would certainly have suffered had the landowner response not been so tremendous. All contacts with property owners and tenants were recorded on special forms and retained in the project records. Property owners were presented with a letter of introduction to further explain the project's purpose and intentions (see Appendix C)., Once the map data had been compiled and the property owners contacted, the actual field survey began in late September-early October 1992. The survey consisted of pedestrian surface survey over areas with fair to good surface visibility and shovel testing in those areas with poor visibility. Site limits were determined primarily by surface survey and general artifact collection. Most of the sites that appeared to have potential NRHP eligibility were also examined by systematic shovel test excavations to determine the vertical limits and deposit integrity. The general artifact collections focused on the retrieval of diagnostic artifacts and representative artifact types. Each new site was assigned a field number prior to designation with an official state site number. Site locations were plottedon topographic maps and site formns completed in the field.Field sessions were held for volunteer participation on the following days: November 7, 8, 14, 15, and 21, 1992; March 13, 14, 21, and 28, 1993; and April 4, 1993. Volunteers conducted pedestrian surface survey in systematic transects and learned how to delineate artifact scatter limits with flags, identify and collect artifacts, and complete the site record forms (Plate 29, Appendix A). They also conducted controlled shovel test excavations on several sites (Plate 30, Appendix A). In addition to the field surveys, volunteers also participated in two special lab days on January 4 and March 27, 1993, where artifacts were washed, catalogued, and labeled. The Linn County Museum in Cedar Rapids provided the use of their laboratory facilities for these sessions.Additional field survey was conducted by the Project Assistant whenever weather and field conditions permitted. Unfortunately, both the weather and field conditions were less than ideal both in the fall and spring portions of the survey. The survey was delayed in the fall by the late harvest, particularly of the corn crop, and the early snow. Two advertised field sessions for volunteers in December had to be cancelled because of the snow cover. T'he wet conditions of March and April, coupled with a lingering winter, further hampered field survey and volunteer participation in the Spring. Therefore, much of the field survey had to be conducted under marginal conditions, necessitating some additional field investigation following submittal of the draft report. The results of the final field investigations were incorporated into the final report and end products, The artifacts collected were processed and analyzed according to current professional standards and the guidelines of the Office of the State Archaeologist, which will be the curation repository for the materials collected during this survey. While the Linn County Historical Museum is interested in having the collections curated in the county, the museum, i " 4-3 H. ARCHAEOLOGICAL METHODS The archaeological portion of the project began with archival research which focused on the historic maps and atlases for the project area. The house site location data and other potential site locations from these maps were plotted on USGS topographic quad maps of the project area, thus pinpointing the high potential survey areas. The landowners of these parcels were then contacted in person to obtain pennission to conduct surveys on their property and to learn more about the potential sites. The response from the property owners was most encouraging and gracious. There were no refusals, arid the majority were very cooperative and generous with historic infonnation and photographs. Several provided infonnal tours of their property to show where sites were located. The project would certainly have suffered had the landowner response not been so tremendous. All contacts with property owners and tenants were recorded on special fonns and retained in the project records. Property owners were presented with a letter of introduction to further explain the project's pmpose and intentions (see Appendix C). ' Once the map data had been compiled and the property owners contacted, the actual field survey began in late September-early October 1992. The survey consisted of pedestrian surface survey over areas with fair to good surface visibility and shovel testing in those areas with poor visibility. Site limits were determined primarily by surface survey and general artifact collection. Most of the sites that appeared to have potential NRHP eligibility were also examined by systematic shovel test excavations to detennine the vertical limits and deposi t integrity. The general artifact collections focused on the retrieval of diagnostic artifacts and representative artifact types. Each new site was assigned a field number prior to designation with an official state site number. Site locations were plotted on topographic maps and site forms completed in the field. Field sessions were held for volunteer participation on the following days: November 7, 8, 14, 15, and 21, 1992; March 13, 14,21, and 28, 1993; and April 4, 1993. Volunteers conducted pedestrian surface survey in systematic transects and learned how to delineate artifact scatter limits with flags, identify and collect artifacts, and complete the site record forms (plate 29, Appendix A). They also conducted controlled shovel test excavations on several sites (plate 3D, Appendix A). In addition to the field surveys, volunteers also participated in two special lab days on January 4 and March 27, 1993, where artifacts were washed, catalogued, and labeled. The Linn County Museum in Cedar Rapids provided the use of their laboratory facilities for these sessions. Additional field survey was conducted by the Project Assistant whenever weather and field conditions pennitted. Unfortunately, both the weather and field conditions were less than ideal both in the fall and spring portions of the survey. The survey was delayed in the fall by the late harvest, particularly of the com crop, and the early snow. Two advertised field sessions for volunteers in December had to be cancelled because of the snow cover. The wet conditions of March and April, coupled with a lingering winter, further hampered field survey and volunteer participation in the Spring. Therefore, much of the field survey had to be conducted under marginal conditions, necessitating some additional field investigation following submittal of the draft report. The results of the final field investigations were incorporated into the final report and end products. The artifacts collected were processed and analyzed according to current professional standards and the guidelines of the Office of the State Archaeologist, which will be the curation repository for the materials col1ected during this survey. While the Linn County Historical Museum is interested in having the collections curated in the county, the museum 4-4 does not presently have sufficient space to serve as the repository. If the museum expands or builds a new facility in the future, it is likely that a loan agreement can be arranged with the University of Iowa and the Office of the State Archaeologist to return the collections to the county. In the meantime, loans of display items could certainly be arranged should the museum desire to have some on exhibit.All recorded archaeological sites were evaluated as to their potential eligibility for nomination to the National Register of Historic Places. Properties were evaluated according to the significance criteria and integrity considerations as set forth by the Department of the Interior, Washington, D.C. Additional consideration was given to the draft guidelines of National Register Bulletin 36: Evaluating and Registering Historical Archaeology Sites and Districts published by the Department of the Interior. These guidelines note that integrity is a prerequisite for the listing of archaeological properties in the National Register, and among the demonstrations of "intactness" cited by this bulletin is the "lack of serious disturbance to the property's archaeological deposits" (U.S.Department of the Interior 1991a:7). Furthermore, the bulletin states that: the archaeological integrity of historical archaeology properties is measured in terms ofthe quality of the archaeological remains. One way of doing this is to determine howwell the activities represented at the property and the archaeological remains can be interpreted. ..If the archaeological remains cannot be interpreted, then it is highly unlikely that a study of them can yield important information (Ibid.: 12-13).All of the archaeological sites recorded during this survey were evaluated in light of these considerations. For example, the evaluation of the mid-Nineteenth Century early settlement sites took into consideration the fact that these site deposits had not been impacted by later occupations and were therefore relatively intact and able to represent the activities represented by these properties and provide interpretations of mid-Nineteenth Century frontier life in Linn County.even though many of these deposits had been impacted to some extent by cultivation. While the impacts from cultivation were considered in the evaluation of integrity, they were not considered as major detractors from the sites' overall integrity. Finally, while the scope-of-work for this project did not require geomorphological assessment of the project area, an initial evaluation of the potential for buried historic resources was made and areas pinpointed that will require geomorphological investigation should future projects impact these areas.]II. HISTORICAL AND ARCHITECTURAL METHODSThe intent of this project was an "intensive level" survey of historical and architectural resources inFayette Township (Subsection E) of Linn County, Iowa. A primary focus of attention for this survey was the identification of resources that illustrate the historic contexts developed in the 1992"Comprehensive Planning Project, Linn County, Iowa" (Rogers 1992).Sources of information came from three areas. Archival materials were first consulted. These include the standard late Nineteeth and early Twentieth Century histories of Linn County. They also included fire insurance maps and construction plans, which were found in the archives of the Iowa Department of Transportation in Ames. Atlases were also consulted and appropriate maps from them xeroxed for analysis.Windshield and pedestrian surveys were also conducted in the study area. Iowa Site Inventory Forms were used at that time to record information visually evident from the resources. Property owners, neighbors, passers-by, and other potentially knowledgable people were asked questions':: ... ; i does not presently have sufficient space to serve as the repository. If the museum expands or builds a new facility in the future, it is likely that a loan agreement can be arranged with the University of Iowa and the Office of the State Archaeologist to return the collections to the county. In the meantime, loans of display items could certainly be arranged should the museum desire to have some on exhibit. All recorded archaeological sites were evaluated as to their potential eligibility for nomination to the National Register of Historic Places. Properties were evaluated according to the significance criteria and integrity considerations as set forth by the Department of the Interior, Washington, D.C. Additional consideration was given to the draft guidelines of National Register Bulletin 36: Evaluating and Registering Historical Archaeology Sites and Districts published by the Department of the Interior. These guidelines note that integrity is a prerequisite for the listing of archaeological properties in the National Register, and among the demonstrations of "intactness" cited by this bulletin is the "lack of serious disturbance to the property's archaeological deposits" (U.S. Department of the Interior 1991a:7). Furthennore, the bulletin states that: the archaeological integrity of historical archaeology properties is measured in tenns of the quaJity of !he archaeologica1 remains. One way of doing !his is to determine how well the activities represented at the property and the archaeological remains can be interpreted. .* .If the archaeological remains cannot be interpreted, then it is highly unlikely that a study of them can yield important information (Ibid.: 12-13). All of the archaeological sites recorded during this survey were evaluated in light of these considerations. For example, the evaluation of the mid-Nineteenth Century early settlement sites took into consideration the fact that these site deposits had not been impacted by later occupations and were therefore relatively intact and able to represent the activities represented by these properties and provide interpretations of mid-Nineteenth Century frontier life in Linn County.even though many of these deposits had been impacted to some extent by cultivation. While the impacts from cultivation were considered in the evaluation of integrity, they were not considered as major detractors from the sites' overall integrity. Finally, while the scope-of-work for this project did not require geomorphological assessment of the project area, an initial evaluation of the potential for buried historic resources was made and areas pinpointed that will require geomorphological investigation should future projects impact these areas. HI. HISTORICAL AND ARCHITECTURAL METHODS The intent of this project was an "intensive level" survey of historical and architectural resources in Fayette Township (Subsection E) of Linn County, Iowa. A primary focus of attention for this survey was the identification of resources that illustrate the historic contexts developed in the 1992 "Comprehensive Planning Project, Linn County, Iowa" (Rogers 1992). Sources of information came from three areas. Archival materials were first consulted. These include the standard late Nineteeth and early Twentieth Century histories of Linn County. They also included fire insurance maps and construction plans, which were found in the archives of the Iowa Department of Transportation in Ames. Atlases were also consulted and appropriate maps from them xeroxed for analysis. Windshield and pedestrian surveys were also conducted in the study area. Iowa Site Inventory Forms were used at that time to record infOImation visually evident from the resources. Property owners, neighbors, passers-by, and other potentially knowledgable people were asked questions 4-5 about those properties, which appeared to have particular interest. From these field surveys a large data base of information emerged. The photographs taken during the windshield and pedestrian surveys were carefully studied,analyzed, and reanalyzed. From them, and impressions gained during the field surveys, the consultant formulated a series of architectural categories. These ultimately became the property types associated with the formulated historic contexts. The four historic contexts, which this survey identified, emerged from archival, field, and analytical work.Chapter 6 of this report contains full bibliographical citations of the documentary resources usedfor this survey, including the numerous individuals who provide information through personal communications. Property types were selected because of their historical associations, land use, building materials, scale, form, stylistic influence, and/or function. Property types were developed from data gatheredduring the field survey of Fayette Township. These property types should not be considered definitive. Although they are based on a good-faith intensive survey, future survey activities may discover contexts of additional significance. Moreover, as more information comes to light about the historic contexts developed in this report, these, too, may need revisions. 4-5 about those properties, which appeared to have particular interest. From these field surveys a large data base of infonnation emerged. The photographs taken during the windshield and pedestrian surveys were carefully studied, analyze<L and reanalyzed. From them, and impressions gained during the field surveys, the consultant formulated a series of architectural categories. These ultimately became the property types associated with the formulated historic contexts. TIte four historic contexts, which this survey identified, emerged from archival, field, and analytical work. Chapter 6 of this report contains full bibliographical citations of the documentary resources used for this survey, including the numerous individuals who provide information through personal communications. Property types were selected because of their historical associations, land use. building materials, scale, fonn, stylistic influence, and/or function. Property types were developed from data gathered during the field survey of Fayette Township. These property types should not be considered defmitive. Although they are based on a good-faith intensive survey, future survey activities may discover contexts of additional significance. Moreover, as more information comes to light about the historic contexts developed in this report, these, too, may need revisions. 5-1 CONCLUSIONS AND ECOMMENDATIONS I. CONCLUSIONS The phase two survey of the historic architectural and archaeological resources of Subsection E, which encompasses the majority of Fayette Township in Linn County, resulted in the recording of 55 previously unrecorded archaeological sites and 115 architectural properties. A total of 2590 ac (1036 ha) was surveyed within the project area which was expanded 3/4mile south from its original boundary line (see Figure 1-1).A. Archaeological Survey Of the 55 archaeological sites, 24 were found to be potentially eligible for nomination to the National Register of Historic Places, with the remainder concluded to be ineligible and requiring no further archaeological investigation (see Table 3-1). While the potentially eligible archaeological sites noted in Table 3-I are individually eligible, there is further potential for Multiple Property Documentation Forms (MPDF) based on the results of this survey. One specific MPDF could be based on the contexts and resources associated with the early settlement of Fayette Township including the early habitation sites and the associated industrial, transportation-related, and agricultural sites that date from the early settlement periodL While such an MPDF and its associated individual property nominations could be completed for the Fayette Township resources using the present document as a guideline, the contexts and resources that will likely be encountered in other survey subsections of Linn County will substantially add to the significance and scope of an MPDF based on the early settlement context. There is also some potential for an MPDF based on the agricultural development of the township, although this too will be strengthened by the expanded data base and deeper context that will be provided by additional surveys in other areas of the county. A final potential MNPDF is that proposed for the Lewis Bottoms Rural Neighborhood under which both architectural and archaeological sites could be individually nominated. The challenge here will be to show through comparative survey elsewhere in the county as to whether or not this rural neighborhood truly reflects a distinctive and important context and collection resources. The survey model for the archaeological portion of the project was based on the con-elation of historic map data and site locations. This technique was supplemented with informant interviews and archival research which identified additional site locations. The survey results demonstrated the utility of this approach, with the majority of sites found having been shown on one or more of the historic maps, although not always at the exact location. While this technique by no means guarantees that all of the historic archaeological sites that exist in the project area were found and recorded, it did provide wide coverage and a manageable survey area given the constraints of time and budget. It was simply not possible to physically walk over every inch of ground, and it is recognized that additional historic sites may be encountered. It should also be noted that the survey dealt primarily with potential sites in a surface context, with no deep testing conducted in areas where buried deposits might exist, such as on the Cedar River floodplain and within the alluvial fans at the footslopes along the bluff edge (see Figure 3-3). Such testing was beyond the, t j 5-1 CONCLUSIONS AND RECOMMENDATIONS I. CONCLUSIONS The phase two survey of the historic architectural and archaeological resources of Subsection E, which encompasses the majority of Fayette Township in Linn County. resulted in the recording of 55 previously unrecorded archaeological sites and 115 architectural properties. A total of 2590 ac (1036 hal was surveyed within the project area which was expanded 3/4 mile south from its original boundary line (see Figure 1-1). A. Archaeological Survey Of the 55 archaeological sites, 24 were found to be potentially eligible for nomination to the National Register of Historic Places, with the remainder concluded to be ineligible and requiring no further archaeological investigation (see Table 3-1). While the potentially eligible archaeological sites noted in Table 3-1 are individually eligible, there is further potential for Multiple Property Documentation Fonns (MPDF) based on the results of this survey. One specific MPDF could be based on the contexts and resources associated with the early settlement of Fayette Township including the early habitation sites and the associated industrial, transportation-related, and agricultural sites that date from the early settlement period. While such an MPDF and its associated individual property nominations could be completed for the Fayette Township resources using the present document as a guideline, the contexts and resources that will likely be encountered in other smvey subsections of Linn County will substantially add to the significance and scope of an MPDF based on the early settlement context There is also some potential for an MPDF based on the agricultural development of the township, although this too will be strengthened by the expanded data base and deeper context that will be provided by additional surveys in other areas of the county. A final potential MPDF is that proposed for the Lewis Bottoms Rural Neighborhood under which both architectural and archaeological sites could be individually nominated. The challenge here will be to show through comparative survey elsewhere in the county as to whether or not this rural neighborhood truly reflects a distinctive and important context and collection resources. The survey model for the archaeological portion of the project was based on the correlation of historic map data and site locations. This technique was supplemented with informant interviews and archival research which identified additional site locations. The survey results demonstrated the utility of this approach, with the majority of sites found having been shown on one or more of the historic maps, although not always at the exact location. While this technique by no means guarantees that all of the historic archaeological sites that exist in the project area were found and recorded, it did provide wide coverage and a manageable survey area given the constraints of time and budget. It was simply not possible to physically walk over every inch of ground, and it is recognized that additional historic sites may be encountered. It should also be noted that the survey dealt primarily with potential sites in a surface context, with no deep testing conducted in areas where buried deposits might exist, such as on the Cedar River floodplain and within the alluvial fans at the footslopes along the bluff edge (see Figure 3-3). Such testing was beyond the 5-2 scope and budget constraints of this project, although the buried potential is recognized and pinpointed in Figure 3-3.The historic contexts that had been previously identified in the phase one comprehensiveplanning document worked well with the results of the archaeological survey and provided the framework upon which the Fayette Township archaeological contexts were based. The contexts specifically developed for this township will be applicable to other survey areas in the county as well and will provide the basis for the recommended multiple property cover documents and associated individual nominations. B. Historical and Architectural SurveysThe phase two survey of the historic and architectural resources of Subsection E resulted in the recording of 115 resources. They included 77 town properties in Palo and 38 rural properties within the unincorporated areas. Of the 38 rural properties, 34 represent farmsteads or portions thereof and four represent cemeteries. The evaluation of these properties resulted in the definition of one potential Multiple Property Documentation Form based on the Lewis Bottoms Rural Neighborhood (number of resources potentially eligible under this MPDF = seven architectural and two archaeological) and eight potential individual listings. For the town properties, the assessment concluded that two potentialdistricts, one MPDF, and seven individually eligible properties are present in Palo.In order to analyze and evaluate the town resources, a series of three historic contexts were developed. Each of these contexts focused on a different aspect of history. Some contexts embraced more town resources than others. Some contexts were more useful than others.What follows here is a discussion of conclusions drawn from the historic contexts and identified property types associated with them."Rural Architecture" continues to challenge the preservation planner and several possibilities emerged from the variety of historic resources in the study area."Town Building" also emerged as an important context. It attempts to make sense of the rich mixture of formal planning decisions, human responses to them, advances in technology, and haphazard occurrences, which affect the evolution of a community."Transportation" provides considerable potential for the identification and evaluation of historic resources in Fayette Township and other sections of Linn County. Major river, railroad, and vehicular mutes have acted as magnets for development. The property types associated with this development can be analyzed and evaluated along closely defined and linear continuums."Architectural Resources of Fayette Township" embraces virtually all the standing structures in the area. Several subcontexts were established to facilitate the analysis and it will be of particular research interest to determine how other subsections in Linn County compare. Under the "The Architecture of Palo" subcontext, the examination of building materials proved particularly fecund, with the local manufacturing of concrete products constituting a theme stretching over half a century in time and including at least two family business operations. The examination of the scale of buildings also addressed an interesting aspect of architecture in Fayette Township. Although it illustrated a limited financial capability in the study area, this subcontext lacked real depth for architecturalanalysis. In a similar vein, the examination of form provided only limited usefulness, partly because of integrity problems related to the ubiquitous fragility of these mostly wood frame resources and partly because the forms of vernacular architecture can elude analysis.The examination of stylistic influences also resulted in a blind alley because the architecture 5-2 scope and budget constraints of this project, although the buried potential is recognized and pinpointed in Figure 3-3. The historic contexts that had been previously identified in the phase one comprehensive planning document worked well with the results of the archaeological survey and provided the framework upon which the Fayette Township archaeological contexts were based. The contexts specifically developed for this township will be applicable to other survey areas in the county as well and will provide the basis for the recommended multiple property cover documents and associated individual nominations. B. Historical and Architectural Surveys The phase two survey of the historic and architectural resources of Subsection E resulted in the recording of 115 resources. They included 77 town properties in Palo and 38 rural properties within the unincorporated areas. Of the 38 rural properties. 34 represent fannsteads or portions thereof and four represent cemeteries. The evaluation of these properties resulted in the defmition of one potential Multiple Property Documentation Fonn based on the Lewis Bottoms Rural Neighborhood (number of resources potentially eligible under this MPDF == seven architectural and two archaeological) and eight potential individual listings. For the town properties, the assessment concluded that two potential districts, one MPDF, and seven individually eligible properties are present in Palo. In order to analyze and evaluate the town resources, a series of three historic contexts were developed. Each of these contexts focused. on a different aspect of history. Some contexts embraced more town resources than others. Some contexts were more useful than others. What follows here is a discussion of conclusions drawn from the historic contexts and identified property types associated with them. "Rural Architecture" continues to challenge the preservation planner and several possibilities emerged from the variety of historic resources in the study area. "Town Building" also emerged as an important context It attempts to make sense of the rich mixture of formal planning decisions, human responses to them. advances in technology, and haphazard occurrences, which affect the evolution of a community. "Transportation to provides considerable potential for the identification and evaluation of historic resources in Fayette Township and other sections of Linn County. Major river. railroad, and vehicular routes have acted as magnets for development. The property types associated with this development can be analyzed and evaluated along closely defined and linear continuums. "Architectural Resources of Fayette Township" embraces virtually all the standing structures in the area. Several subcontexts were established to facilitate the analysis and it will be of particular research interest to determine how other subsections in Linn County compare. Under the "The Architecture of Palo" subcontext, the examination of building materials proved particularly fecund, with the local manufacturing of concrete products constituting a theme stretching over half a century in time and including at least two family business operations. The examination of the scale of buildings also addressed. an interesting aspect of architecture in Fayette Township. Although it illustrated a limited financial capability in the study area, this subcontext lacked real depth for architectural analysis. In a similar vein, the examination of form provided only limited usefulness, partly because of integrity problems related to the ubiquitous fragility of these mostly wood frame resources and partly because the forms of vernacular architecture can elude analysis. The examination of stylistic influences also resulted in a blind alley because the architecture 5-3 in the study area is mostly plain and simple in concept Taking a cue from this subcontext, the forgotten story of John Livermore emerged as the big winner in the historical and architectural survey. Developed as an historic context in its own right, these resources provide exciting possibilities for preservation planning. They open new ground for group nominations to the National Register of Historic Places within the State of Iowa.11. RECOMMENDATIONS Based on the results of the archaeological and architectural survey of Subsection E, it is recommended that the survey model utilized during this survey be applied to other subsections of the county in order to produce a consistent and comparable data base from which individual, multiple property, and district nominations can be drawn. The next phase of the county-wide survey project is already underway through a Historic Resource Development Program (HRDP) grant and will examine the resources of Subsections C and Q (see Figure 1-1). It is recommended that the Linn County Historic Preservation Commission continue in their efforts to obtain grants to continue the progress of the survey, with the next two recommended subsections being S and B (see Figure 1-1). The reasons for these selections are two-fold: 1. Subsection S was the alternate subsection planned for the present, phase twosurvey had there been sufficient time and budget. While we were able to expand the survey area for Subsection E, there was not sufficient time to complete a comprehensive survey of Subsection S. Therefore, it is recommended that the phase four survey include Subsection S which has a number of known and potential early historic period sites and is greatly threatened by the urban expansion of Cedar Rapids.2. Subsection B is recommended for the phase four survey because it includes an area in northern Linn County that has a high potential for early historic sites as well as the varied resources associated with the community of Central City.Furthermore, the Central City Historical Society is very active in historic preservation and would utilize the survey results to further historic preservation efforts in their community. In general, the recommendation to continue the survey effort lies in the momentum that is generated by each survey and which can be lost by any major gaps in the survey schedule. This morentum particularly applies to the volunteer participation and training that is part ofeach survey and will lead to greater commitments to historic preservation at the local level and will hopefully eventually be self-sustaining as a grass-roots preservation program.Furthermore, the broader based the local support for historic preservation and the morepeople well-versed in preservation programs and techniques, the more successful the county-wide preservation efforts will be and the more effective the Historic Preservation Commission will become as the guiding force for historic preservation in the county.Specific recommendations concerning the cultural resources identified and evaluated by the present investigation are as follows: A. Archaeological Resources Table 3-1 lists the archaeological sites recorded in Subsection E that were concluded to have some potential eligibility for nomination to the NRHP. At present, none of these sites are threatened with destruction, although most will continue to be degraded by cultivation. It is not recommended that any be listed in the NRHP at the present time, unless property 5*3 in the study area is mostly plain and simple in concept Taking a cue from this subcontext, the forgotten story of John Livennore emerged as the big winner in the historical and architectural survey. Developed as an historic context in its own right, these resources provide exciting possibilities for preservation planning. They open new ground for group nominations to the National Register of Historic Places within the State of Iowa. U. RECOMMENDATIONS Based on the results of the archaeOlogical and architectural survey of Subsection E, it is recommended that the survey model utilized during this survey be applied to other subsections of the county in order to produce a consistent and comparable data base from which individual, mUltiple propeny, and district nominations can be drawn. The next phase of the county-wide survey project is already underway through a Historic Resource Development Program (HRDP) grant and will examine the resources of Subsections C and Q (see Figure 1-1). It is recommended that the Linn County Historic Preservation Commission continue in their efforts to obtain grants to continue the progress of the survey, with the next two recommended subsections being S and B (see Figure 1-1). The reasons for these selections are two-fold:

1. Subsection S was the alternate subsectioQ planned for the present, phase two survey had there been sufficient time and budget While we were able to expand the survey area for Subsection E. there was not sufficient time to complete a comprehensive survey of Subsection S. Therefore, it is recommended that the phase four survey include Subsection S which has a number of known and potential early historic period sites and is greatly threatened by the urban expansion of Cedar Rapids. 2. Subsection B is recommended for the phase four survey because it includes an area in northern Linn County that has a high potential for early historic sites as well as the varied resources associated with the community of Central City. Furthermore, the Central City Historical Society is very active in historic preservation and would utilize the survey results to further historic preservation efforts in their community.

In general, the recommendation to continue the survey effort lies in the momentum that is generated by each survey and which can be lost by any major gaps in the survey schedule. This momentum particularly applies to the volunteer participation and training that is part of each survey and will lead to greater commitments to historic preservation at the local level and will hopefully eventually be self-sustaining as a grass-roots preservation program. Furthermore, the broader based the local support for historic preservation and the more peop]e weB-versed in preservation programs and techniques, the more successful the county-wide preservation efforts will be and the more effective the Historic Preservation Commission will become as the guiding force for historic preservation in the county. Specific recommendations concerning the cultural resources identified and evaluated by the present investigation are as follows: A. Archaeological Resources Table 3-1 lists the archaeological sites recorded in Subsection E that were concluded to have some potential eligibility for nomination to the NRHP. At present, none of these sites are threatened with destruction, although most will continue to be degraded by cultivation. It is not recommended that any be listed in the NRHP at the present time, unless property 5-4 owners request this listing. There is a good potential for Multiple Property Documentation Forms and associated individual nominations based on the archaeological resources of the early settlement period and the agricultural development of the township as well as on the architectural and archaeological resources of the Lewis Bottoms Rural Neighborhood. However, such multiple property cover documents and nominations would be strengthened by an expanded data base and the deeper contexts that could be drawn from the survey results of other subsections of the county.The results of the archaeological survey should be made available to the widest possible professional audience in order to assure that future investigations in this area take the results into consideration and to promote further research into material culture and settlement studies of the region. Thbe curation of the project artifact collections and survey data at the Office of the State Archaeologist in Iowa City will ensure the dissemination of this important archaeological data base. The results should also find a wide audience among the residents of Linn County, although the archaeological site records themselves must be kept confidential. It is hoped that the property owners will have a greater appreciation for the cultural resources on their land and will continue to cooperate with preservation efforts in the future. It is also hoped that property owners will limit access to the significant sites to all but controlled investigations because the loss of artifacts and the destruction of below plow zone deposits that can result from uncontrolled, unscientific investigations will adversely impact the integrity and research potential of the sites and lessen or destroy their eligibility for inclusion in the National Register of Historic Places.B .Historic and A-rchitectural Resources The historical and architectural surveys reiterate comments made within the archaeological recommendations concerning continued survey and preservation planning. The level and quality of voluntarism contributed to this intensive survey indicate a real concern locally for preservation issues.Fayette Township contains a number of historic resources whose potential for nomination to the National Register of Historic Places should be pursued. These include two historic districts, two Multiple Property Documentation Forms and associated resource nominations, and 15 individual nominations. The following discussion summarizes these findings.1. RESOURCES OF JOHN LIVERMORE MULTiPLE PROPERTY DOCUMENTATION FORM.Significant locally under National Register Criteria C, the group of resources individually eligible under this MPDF comprise seven buildings. They are all located in Palo, Iowa.

2. PALO HISTORIC COMMERCIAL DISTRICT.

The Palo Historic Commercial District is significant locally under National Register Criteria A and C. It contains 14 buildings, nine contributing and five noncontributing resources. These include two single-family dwellings and 12 commercial buildings, a mixed land use historically significant for thecomm unity.

3. VINTON STREET HISTORIC DISTRICT.

Significant locally under National Register Criteria A and C, the Vinton Street Historic District contains eight buildings, five contributing and three noncontributing resources. 5-4 owners request this listing. There is a good potential for Multiple Property Documentation Fonns and associated individual nominations based on the archaeological resources of the early settlement period and the agricultural development of the township as well as on the architectural and archaeological resources of the Lewis Bottoms Rural Neighborhood. However, such multiple property cover documents and nominations would be strengthened. by an expanded data base and the deeper contexts that could be drawn from the survey results of other subsections of the county. The results of the archaeological survey should be made available to the widest possible professional audience in order to assure that future investigations in this area take the results into consideration and to promote further research into material culture and settlement studies of the region. The curalion of the project artifact collections and survey data at the Office of the State Archaeologist in Iowa City will ensure the dissemination of this important archaeological data base. The results should also.fmd a wide audience among the residents of Linn County, although the archaeological site records themselves must be kept confidential. It is hoped that the property owners will have a greater appreciation for the cultural resources on their land and will continue to cooperate with preservation efforts in the future. It is also hoped that property owners will limit access to the significant sites to all but controlled investigations because the loss of artifacts and the destruction of below plow zone deposits that can result from uncontrolled, unscientific investigations will adversely impact the integrity and research potential of the sites and lessen or destroy their eligibility for inclusion in the National Register of Historic Places. B . Historic and Architectural Resources The historical and architectural surveys reiterate comments made within the archaeological recommendations concerning continued survey and preservation planning. The level and quality of voluntarism contributed to this intensive survey indicate a real concern locally for preservation issues. Fayette Township contains a number of historic resources whose potential for nomination to the N ationaI Register of Historic Places should be pursued. These include two historic districts, two Multiple Property Documentation Forms and associated resource nominations, and 15 individual nominations. The following discussion summarizes these findings. I. RESOURCES OF JOHN UVERMORE MULTIPLE PROPERTY DOCUMENrATION mRM. Significant locally under National Register Criteria C, the group of resources individually eligible under this MPDF comprise seven buildings. They are all located in Palo, Iowa. 2. PALO HISTORIC COMMERCIAL DISTRlCf. TIle Palo Historic Commercial District is significant locally under National Register Criteria A and C. It contains 14 buildings, nine contributing and five noncontributing resources. These include two single-family dwellings and 12 commercial buildings, a mixed land use historically significant for the community.

3. VINTON STREET HISTORIC DISTRICf.

Significant locally under National Register Criteria A and C, the Vinton Street Historic District contains eight buildings, five contributing and three noncontributing resources. 5-5 4. LEWIS BOTr'MS RURAL NEIGHBORHOOD MULTIPLE PROPERTY DOCUMENTATION FORM. Significant locally under National Register Criterion A and potentially C. The group of resourmes individually eligible under this MPDF comprise six fannsteadsualresidences, one cemetery, and two archaeological sites.Although each of these property types was determined eligible for nomination, each varies in terms of historic context, significance, number of identified resources, and complexity. Because of this variation, each of these property types was evaluated according to their difficulty of nomination. To this end, the above list begins with the "easiest" nomination and proceeds with the more difficult. The rationale here is that more difficult jobs become easier as more experience is gained doing the easier tasks.The Resources of John Livermore comprises a closely defined group of resources, tightly linked with one another in historic context and dating from a relatively narrow spectrum oftime. While not a difficult process, this will require the completion of a cover documentand individual nomination forms for each resource.The Palo Historic Commercial District is associated with several historic contexts, issignificant under several criteria, and contains more resources than the proposed Livermore MPDF. Although this district is somewhat complex, it is a very good candidate for nomination. The fact that a number of its resources are also eligible within the Livermore MPDF would would facilitate the historic district's nomination. The Vinton Street Historic District is somewhat thin in terms of resource numbers. It contains only eight resources, three of which are noncontributing. Its significance--aresidential corridor whose development is linked to the evolving importance of atransportation route--has not yet been attempted in Iowa. For these reasons, this districtlacks the strength of the property types already mentioned. This report evaluates the district as eligible because basic integrity remains extant and also because it provides a model for future analysis and evaluation of similar residential property types in the on-going survey of Linn County.One final note is necessary for the Palo Historic Commercial District and the Vinton Street Historic District. Given the present uncertainty concerning appropriate terminology to describe town building in Palo (see the conclusion portion of the Town Building section of Chapter 2), the question remains whether there should be one historic district here or two.The fact remains that the two areas are contiguous and largely linear, and both illustrate aspects of related phenomena. While listing these districts separately as commercial and residential property types follows a more traditional registration approach in Iowa, the one district concept might more accurately reflect the community's historical evolution. The resources of the Lewis Bottoms Rural Neighborhood are linked through theirassociation with, and representations of, the early settlement and subsequent development of Fayette Township by the Lewis family and their relations. At present, few rural multiple property listings have been attempted and, therefore, would also lack the strength of the property types already mentioned. This proposed MPDF would be greatly strengthened by the broader comparative data base that will be generated by future surveys in the county and should be deferred for further evaluation based on an expanded data base.As a result of these considerations, this report recommends that preservation planning in Fayette Township undertake the nominations of the Resources of John Livermore Multiple Property Documentation Form and the Palo Historic Commercial District to the National Register of Historic Places, as a first priority. These two property types are historically 5-5 4. LEWIS BOTIOMS RURAL NEIGHBORHOOD MULTIPLE PROPERTY DOCUMENTATION roRM. Significant locally under National Register Criterion A and potentially C. The group of resources individually eligible under this MPDF comprise six fannsteads/rural residences, one cemetery, and two archaeological sites. Although each of these property types was determined eligible for nom.ination. each varies in tenns of historic context, significance, number of identified resources, and complexity. Because of this variation, each of these property types was evaluated according to their difficulty of nomination. To this end, the above list begins with the "easiest" nomination and proceeds with the more difficult. The rationale here is that more difficult jobs become easier as more experience is gained doing the easier tasks. The Resources of John Livermore comprises a closely defined group of resources, tightly linked with one another in historic context and dating from a relatively narrow spectrum of time. While not a difficult process, this will require the completion of a cover document and individual nomination fonns for each resource. The Palo Historic Commercial District is associated with several historic contexts, is . significant under several criteria, and contains more resources than the proposed Livermore MPDF. Although this district is somewhat complex, it is a very good candidate for nomination. The fact that a number of its resources are also eligible within the Livermore MPDF would would facilitate the historic district's nomination. The Vinton Street Historic District is somewhat thin in tenns of resource numbers. It contains only eight resources, three of which are noncontributing. Its significance--a residential conidor whose development is linked to the evolving importance of a transportation route--has not yet been attempted in Iowa. For these reasons, this district lacks the strength of the property types already mentioned. This repon evaluates the district as eligible because basic integrity remains extant and also because it provides a model for future analysis and evaluation of similar residential property types in the on-going survey of Linn County. One fmal note is necessary for the Palo Historic Commercial District and the Vinton Street Historic District Given the present uncertainty concerning appropriate teIminology to describe town building in Palo (see the conclusion portion of the Town Building section of Chapter 2). the question remains whether there should be one historic district here or two. The fact remains that the two areas are contiguous and largely linear, and both illustrate aspects of related phenomena. While listing these districts separately as commercial and residential property types follows a more traditional registration approach in Iowa, the one district concept might more accurately reflect the community's historical evolution. The resources of the Lewis Bottoms Rural Neighborhood are linked through their association with, and representations of, the early settlement and subsequent development of Fayette Township by the Lewis family and their relations. At present, few rural multiple property listings have been attempted and, therefore, would also lack the strength of the property types already mentioned. This proposed MPDF would be greatly strengthened by the broader comparative data base that win be generated by future surveys in the county and should be deferred for further evaluation based on an expanded data base. As a result of these considerations, this report recommends that preservation planning in Fayette Township undertake the nominations of the Resources of John Livennore Multiple Property Documentation Fonn and the Palo Historic Commercial District to the National Register of Historic Places, as a first priority. These two property types are historically 5-6 intertwined in terms of period of significance, building materials, and contractor-builders. The listing of the commercial district in the National Register might also provide an incentive for preservation through the federal tax credits, which then become available. This report recommends, however, the nominations of the Vinton Steet Historic District and the Lewis Bottom.s Rural Neighborhood Multiple Property Documentation Form be de until nominations numbered one and two above are accomplished. At that time, a reevaluation of these should be undertaken in light of the additional survey work in other subsections of Linn County, which will then be accomplished. As to the resources found individually eligible for nomination, preservation planning inFayette Township either can approach them on an ad hoc basis or possibly include them as one component within the MPDF/district project recommended above. Other planning issues and budget considerations will help clarify the proper course here. A further consideration for individual nominations is property owner consent, which is required for all individually nominated properties as well as for the majority of properties within the proposed districts. The historic contexts developed in this survey should be continued and applied to futuresubsection surveys in Linn County. The "Transportation" historic context should, inparticular, provide an important concept to test as it applies to other rural and town environments in the county. County-wide linkages may become apparent between propertytypes adjacent to certain transportation corridors, which might otherwise be understood in a narrow context.intertwined in terms of period of significance, building materials, and contractor-builders. The listing of the commercial district in the National Register might also provide an incentive for preservation through the federal tax credits, which then become available. This report recommends, however, the nominations of the Vinton Street Historic District and the Lewis Bottoms Rural Neighborhood Multiple Pro.perty Documentation Fenn be deferred until nominations numbered one and two above are accomplished. At that time, a reevaluation of these should be undertaken in light of the additional survey work in other subsections of Linn County, which will then be accomplished. As to the resources found individually eligible for nomination, preservation planning in Fayette Township either can approach them on an ad hoc basis or possibly include them as one component within the MPDF/district project recommended above. Other planning issues and budget considerations will help clarify the proper course here. A further consideration for individual nominations is property owner consent, which is required for all individually nominated properties as well as for the majority of properties within the proposed districts. The historic contexts developed in this survey should be continued and applied to future subsection surveys in Linn County. The "Transportation" historic context should, in particular, provide an important concept to test as it applies to other rural and town environments in the county. County-wide linkages may become apparent between property types adjacent to certain transportation corridors, which might otherwise be understood in a narrow context. 6-1 MAJOR BIBLIOGRAPHICAL REFERENCES PRINT Andreas, A.T.1875 Illustrated Atlas -of the State of Iowa (reprinted 1970). Andreas Atlas Company, Chicago.Benn, David W., and David Hovde 1976 Archaeological Remains in the Pleasant Creek Reservoir, Iowa. Luther College Archaeological Research Laboratory, Decorah, Iowa.Bergendahl, C.G., compiler 1895 Atlas of Linn County. Iowa. S.N. Parnson, W.G. Treat, and J.D. Wardie, Marion.Brewer, Luther A., and Barthinius L. Wick 1911 History of Linn County., Iowa, Volume I. Pioneer Publishing Company, Chicago.Browne, Laura 1980 Henry A. Usher Family History, Linn County, Iowa. Manuscript Collections, State Historical Society Library, Iowa. City.Centennial Committee 1979 Palo, Iowa: 1854-1979. 125 Years History. Palo, Iowa.Clements, Ralph 1967 Tales of the Town: Little Known Anecdotes of Life in Cedar Rapids, Iowa. Stamats Publishing Company, Cedar Rapids. Code of Iowa 1913 Supplement "Registration of Highway Routes." Section 1527 s22-s29.Conard, Rebecca 1990 The Advent and Development of Railroads in Iowa: 1855-1940. National Register of Historic Places Multiple Property cover document on file at the State Historical Society Historic Preservation Bureau, Des Moines.Ewoldt, Harold F.1988 Cedar Rapids: The Magnificent Century. Windsor Publications, Inc., Northridge,California. Giese, Henry 1946 'Trends in Farm Structures." In A Century of Farming in Iowa 1846-1946, byIowa State College Staff. Iowa State College Press, Ames.Goudy, Willis 1988 Population in Iowa's Incorporated Places: 1850-1986. Iowa State UniversityExtension pamphlet CRD 263, March, 1988, Ames, Iowa.MAJOR BIBLIOGRAPHICAL REFERENCES PRINT Andreas, A.T. 1875 lliustrate<i Atlas of the State of Iowa (reprinted 1970). Andreas Atlas Company, Chicago. Benn, David W., and David Hovde 1976 Archaeological Remains in the Pleasant Creek Reservoir. Iowa. Luther College Archaeological Research Laboratory, Decorah, Iowa. Bergendahl, C.G., compiler 1895 Atlas of Linn County. Iowa. S.N. Pam son , W.O. Treat, and J.D. Wardie, Marion. Brewer, Luther A., and Barthinius L. Wick 1911 History of Linn County. Iowa. Volume I. Pioneer Publishing Company, Chicago. Browne, Laura 1980 Henry A. Usher Family History, Linn County, Iowa. Manuscript Collections, State Historical Society Library, Iowa. City. Centennial Committee 1979 Palo. Iowa: 1854-1979. 125 Years History. Palo, Iowa. Clements, Ralph 1967 Tales of the Town: Little Known Anecdotes of Life in CedarRapids. Iowa. Stamats Publishing Company, Cedar Rapids. Code of Iowa 1913 Supplement "Registration of Highway Routes." Section 1527 s22-s29. Conard, Rebecca 1990 The Advent and Development of Railroads in Iowa: 1855-1940. National Register of Historic Places Multiple Property cover document on file at the State Historical Society Historic Preservation Bureau, Des Moines. Ewoldt, Harold F. 1988 Cedar Rapids: The Magnificent Centwy. Windsor Publications, Inc., Northridge,California. Giese, Henry 1946 'Trends in Farm Structures." In A Century of Farming in Iowa 1846-1946, by Iowa State College Staff. Iowa State College Press, Ames. Goudy, Willis 1988 Population in Iowa's Incorporated Places: 1850-1986. Iowa State University Extension pamphlet CRD 263, March, 1988, Ames, Iowa. 6-2 Gulliford, Andrew 1991 America's Country Schools. The Preservation Press, Washington, D. C.Harbert, Albert N., editor 1904-05 Proceedings of the Linn County Historical Society. Volume I. Linn County Historical Society, Cedar Rapids.Hopkins, John 1946 The Pattern of Farm Management. In A Century of Farming in Iowa 1846-j2146,by Iowa State College Staff. Iowa State College Press, Ames.Huebinger, M.1910 H uebnger's MaD and Guide for River to River Road The Iowa Publishing Company, Des Moines. From the collection of Ivyl and Irene Emehiser.Iowa Department of Transportation (IDOT)1925 County Road Number 14 Proposed Improvement Plan Maps. On file at Records Management at the Iowa Department of Transportation, Ames, Iowa.Iowa Press Association 1940 lowa Press Association's Who's Who in Iowa, A Biographical Record of Iowa's Leaders in Business. Professional and Public Life. Iowa Press Association, Des Moines, Iowa.Iowa Publishing Company 1906 Atlas of Linn County. Iowa. Iowa Publishing Company, Davenport. Jackson, Donald C.1988 Great American Bridges and Dam-s. The Preservation Press, Washington, DC.Janik, Carolyn 1990 The Barn Book. Gallery Books, New York.Kenyon Company.1930-35 Kenyon's Plat Book of Linn Couny. Iowa. Kenyon Company.Lazell, Frederick John 1908 Down the Cedar River: An Account of a Little Voyage from Vinton to Cedar Rapids. with Many Landings on the Way. The Torch Press, Cedar Rapids.Linn County Zoning Commission 1961 Background for Planning. Linn County Zoning Commission, Cedar Rapids. McAlester, Virginia & Lee 1984 A Field Guide to American Houses. Alfred A. Knopf, New York.McWilliams and Thompson 1859 Map of Linn County, Iowa. McWilliams and Thompson.Miller, George 1987 An Introduction to English Ceramics for Archaeologists. A one-day seminar presented at the Second Conference on Historic Archaeology in Illinois, August, Illinois State University, Normal.6-2 Gulliford, Andrew 1991 America's Country Schools. The Preservation Press, Washington, D. C. Harbert, Albert N., editor 1904-05 Proceedings of the Linn County Historical Society. Volume I. Linn County Historical Society, Cedar Rapids. Hopkins, John 1946 The Pattern ofFann Management. In A Centmy of Fanning in Iowa 1846-Iowa State College Staff. Iowa State College Press, Ames. Huebinger, M. 1910 Huebinger's Map and Guide for Riyer to River Road. The Iowa Publishing Company, Des Moines. From the collection of Ivy} and Irene Emehiser. Iowa Department of Transportation (IDOT) 1925 County Road Number 14 Proposed Improvement Plan Maps. On fIle at Records Management at the Iowa Department of Transportation, Ames, Iowa. Iowa Press Association 1940 Iowa Press Association's Who's Who in Iowa. A Biographical Record of Iowa's Leaders in Business. Professional and Public Life. Iowa Press Association, Des Moines, Iowa. . Iowa Publishing Company 1906 Atlas of Linn County. Iowa. Iowa Publishing Company, Davenport. Jackson, Donald C. 1988 QIYatAtllericilll.Bridges and Dams' The Preservation Press, Washington, DC. Janik, Carolyn 1990 The Barn Book. Gallery Books, New York. Kenyon Company. 1930-35 Kenyon's Plat Book of Linn County. Iowa. Kenyon Company. Laz.e11. Frederick John 1908 Down the Cedar River; An Account of a Little Voyage from Vinton to Cedar Rapids. with ManY Landings on the Way. The Torch Press, Cedar Rapids. Linn County Zoning Commission 1961 Background for Planning. Linn County Zoning Commission, Cedar Rapids. McAlester, Virginia & Lee 1984 A Field Guide to American Houses. Alfred A. Knopf, New York. McWilliams and Thompson 1859 Map of Linn County. Iowa. McWilliams and Thompson. Miller, George 1987 An Introduction to English Ceramics for Archaeologists. A one-day seminar presented at the Second Conference on Historic Archaeology in TIlinois, August, minois State University, Normal. 6-3Mills, Georgia 1958 West of the River. The Torch Press, Cedar Rapids.Page, William C. and Leah D. Rogers 1992 Reconnaissance Historical and Architectural Survey of Black Hawk & Bremer QCunties. Three volumes. Des Moines, State Historical Society of Iowa.Perry, Michael J.1983 RS-4834 Linn Count Local Roads. IDOT Project Completion Report 7(78), Office of the State Archaeologist, Iowa City.Peterson, William J.1952 The Story of Iowa: The Progmrss of An American State. Two volumes. Lewis Historical Publishing Company, Inc., New York.Prior, Jean C.1991 Landfo=ms of Iow. University of Iowa Press, Iowa City.Rifkind, Carole 1980 A Field Guide to American Architecture. Bonanza Books, New York Rogers, Leah D.1992 Comprehensive Planning Project: Linn County. Iowa. Prepared for the Linn County Historic Preservation Commission, Cedar Rapids, and the StateHistorical Society of Iowa, Historic Preservation Bureau, Des Moines.-j Ross, Earle D.1951 Iowa Agriculure: An Historical Survey. The State Historical Society of Iowa, Iowa City.Sage, Leland L.1974 A History of.Iowa. The Iowa State University Press, Ames.Sanborn Map Company 1931 Fire Insurance Map of Palo. Iowa. Sanborn Map Company, New York.Sears, Roebuck and Company 1969 The 1902 Edition of the Sears Roebuck Catalogue (reprint). Bounty Books, New York.Sears, Roebuck and Company1969 Sears. Roebuck and Company 1908 Catalogue No. 117 (reprint). The Gun Digest Company, Chicago.Soike, Lowell 1983 Without Right Angles. Iowa State Historical Department, Des Moines, Iowa.Soike, Lowell 1989 Viewing Iowa's Farmsteads. In Take This Exit: Rediscovering the Iowa Landscape,Robert F. Sayre, editor. Iowa State University Press, Ames.: I i i J 6-3 Mills, Georgia 1958 West of the River. The Torch Press, Cedar Rapids. Page, William C. and Leah D. Rogers 1992 Reconnaissance Historical and Architectural Survey of Black Hawk & Bremer Counties. Three volumes. Des Moines, State Historical Society of Iowa. Perry, Michael J. 1983 RS-4834 Linn County Local Roads. lOOT Project Completion Report 7(78). Office of the State Archaeologist, Iowa City. Peterson, William J. 1952 The StorY of Iowa; The Progress of An AmeriCan State. Two volumes. Lewis Historical Publishing Company, Inc., New York. Prior, Jean C. 1991 Landfouns of Iowa. University of Iowa Press, Iowa City. Rifkind, Carole 1980 A Field Guide to American Architectll:1J(. Bonanza Books, New York. Rogers. Leah D. 1992 Comprehensive Planning Proiect: Linn County. Iowa. Prepared for the Linn County Historic Preservation Commission, Cedar Rapids, and the State Historical Society of Iowa, Historic Preservation Bureau, Des Moines. Ross, Earle D. 1951 Iowa Agriculture; An Historical S\U"'VkY. The State Historical Society of Iowa, Iowa City. Sage, Leland L. 1974 A Histoty ofIowa. The Iowa State University Press, Ames. Sanborn Map Company 1931 Fire Insurance Map of Palo, Iowa. Sanborn Map Company. New York. Sears, Roebuck and Company 1969 The 1902 Edition of the Sears Roebuck CatalogPv (reprint). Bounty Books, New York. Sears, Roebuck and Company 1969 Sears, Roebuck and Company 1908 Catalogue No. 117 (reprint). The Gun Digest Company, Chicago. Soike, Lowell 1983 Without Right Angles. Iowa Stare Historical Department, Des Moines, Iowa. Soike, Lowell 1989 Viewing Iowa's Farmsteads. In Take This Exit: Rediscovering the Iowa Landscape,Roben F. Sayre, editor. Iowa State University Press, Ames. 6-4 Strong, Jean, editor 1990 A Prairie Almanac. 1839-1919: An Eyewitness Account of Everyday Life in Early Iowa. by Isaac N. Kramer. Bella Vista, Arkansas. Thompson and Evens 1869 Map of Linn County. Iowa. Thompson and Everts, Geneva, Illinois. Thompson, William H.1989 Transportation in Iowa, A Histoical Summary. Iowa Department of Transportation, Ames, Iowa.Throne, Mildred 1973 "Book Farming" in Iowa, 1840-1870. In Patternsand Perspectives in Iowa Histry, edited by Dorothy Schwieder. Iowa State University Press, Ames.U.S. Department of the Interior1991a National Register Bulletin 36: Evaluating and Registering Historical Archaeology Sites and Districts, Draft. National Park Service, InteragencyResource Division, Washington, D.C.1991b National Register Bulletin 16: Guidelines for Completing National Register of Historic Places Forms. National Park Service, National Register Branch, Interagency Resources Division, Washington, D.C.Wall, Joseph Frazier 1978 Iowa: A Bicentennial History. W. W. Norton & Company, Inc., New York, and American Association for State and Local History, Nashville. Warner and Foote 1881 Map of Linn County. Iowa. Warner and Foote, Minneapolis and Philadelphia. Weichman, Michael 1974 Pleasant Creek Reservoir Survey: A Preliminary Repot Report on file at the Office of the State Archaeologist, Iowa City.Western Historical Company 1878 History of Linn County. Iowa. Western Historical Company, Chicago. Wood Atlas Company 1938 New Atlas of Linn County. Iowa. Wood Atlas Company, Albia, Iowa.6-4 Strong, Jean, editor 1990 A Prairie Almanac. 1839-1919: An Eyewitness Account of Everyday Lire in Early Iowa, by Isaac N. Kramer. Bella Vista, Arkansas. Thompson and Everts 1869 Map of Linn CountY. Iowa. Thompson and Everts, Geneva, lllinois. Thompson, William H. 1989 Transportation in Iowa: A Historical Summaty. Iowa Department of Transponation, Ames, Iowa. Throne, Mildred 1973 "Book Fanning" in Iowa, 1840-1870. In Patterns and Perspectives in Iowa History, edited by Dorothy Schwieder. Iowa State University Press, Ames. U.S. Department of the Interior 1991a National Register Bulletin 36; Eyaluating and Registering Historical Archaeology Sites and Districts, Draft National Park Service, Interagency Resource Division, Washington, D.C. 1991 b National Register Bulletin 16: Guidelines for Completing N alional Register of Historic Places Fonns. National Park Service, National Register Branch, Interagency Resources Division, Washington, D.C. Wall, Joseph Frazier 1978 Iowa: A Bicentennial History. W. W. Norton & Company, Inc" New York, and American Association for State and Local History, Nashville. Warner and Foote 1881 Map of Lion CountY. Iowa. Warner and Foote, Minneapolis and Philadelphia. Weichman, Michael 1974 Pleasant Creek Reservoir Survey: A Prelirnimuy Re.port. Report on file at the Office of the State Archaeologist, Iowa City. Western Historical Company Up8 History or Linn County. Iowa. Western Historical Company, Chicago. Wood Atlas Company 1938 New Atlas of Linn County. Iowa. Wood Atlas Company, Albia, Iowa. 6-5 CENSUSES EXAMINED Iowa State Population Census 1856 Iowa State Industrial Censuses 1870, 1880 U.S. Agricultural Censuses 1860, 1870, 1880, 1890, 1910 ORAL INFORMANTS Dobbe, Wahneita 1992 Personal communication with Leah D. Rogers. Lewis, Tom 1993 Personal communication with G. Clark Rogers. Marquardt, Caroline 1993 Personal communication with William C. Page.Zeller, William 1993 Personal communication with William C. Page.6-5 CENSUSES EXAMINED Iowa State Population Census 1856 Iowa State Industrial Censuses 1870, 1880 U.S. Agricultural Censuses 1860, 1870, 1880, 1890, 1910 ORAL INFORMANTS Dobbe. Wahneita 1992 Personal corrnnunication with Leah D. Rogers. Lewis, Tom 1993 Personal communication with G. Clark Rogers. Marquardt, Caroline 1993 Personal communication with William C. Page. Zeller, William 1993 Personal communication with William C. Page. 0 PROJECT AND ARTIFACT PHOTOGRAPHS APPENDIX A: PROJECT AND ARTIFACT PHOTOGRAPHS FT. I Plate 1. Historic Photograph of McClintock/Melton House (non-extant). ]Plate 2. Stoneware, Site 13LN332.: : Plate 1. Historic Photograph of McClintock/Melton House (non-extant). Plate 2. Stoneware, Site 13LN332. .:v., .W w ~~:',.A70 Plate 3. Redware, Site 13LN332.v..0 5cm Plate 4. Decorated Earthenware, Site 13LN332.Plate 3. Redware, Site 13LN332. Plate 4. Decorated Earthenware, Site 13LN332. 9 5cm Plate 5. Bottle and Pressed Glass, Site 13LN332.C-' q;Plate 6. Cast Iron Stove Parts, Site 13LN332.j. i, Plate 5. Bottle and Pressed Glass, Site 13LN332. Plate 6. Cast Iron Stove Parts, Site 13LN332.

• wt ..'A Plate B, i H (t08a L Cent(Sit ......Plate 7. British Half Penny (Site 13LN338) and Large Cent (Site 13LN332).Plate 8. Harness Part and Machine Cut Nail, Site 13LN338.

Plate 7. British Half Penny (Site 13LN338) and Large Cent (Site 13LN332). Plate 8. Harness Part and Machine Cut Nail, Site 13LN338. Plate 9. Refined and Utilitarian Ceramics-Site 13LN338...... ............. 0 :..Plate 10. Stoneware, Decorated Ceramics, and Bitters Bottle Glass, Site 13LN345.Plate 9. Refined and Utilitarian Ceramics; Site 13LN338. Plate 10. Stoneware, Decorated Ceramics" and Bitters Bottle Glass, Site 13LN345. Plate 11. Blowpipe Pontil Mark, Decorated Ceramics, and Brass Button, Site 13LN346.!V ~btf Plate 12. Decorated Ceramics, Clay Pipes, and Blowpipe Pontil Marks, Site 13LN347.Plate 11. Blowpipe Pontil Mark, Decorated Ceramics, and Brass Button, Site 13LN346. Plate 12. Decorated Ceramics, Clay Pipes, and Blowpipe Ponti! Marks, Site 13LN347. Plate 13. Decorated Ceramics, Site 13LN349.Plate 14. Stoneware and Decorated Ceramics, Site 13LN351.T Plate 13. Decorated Ceramics, Site 13LN349. Plate 14. Stoneware and Decorated Ceramics, Site 13LN351. AjPlate 15. Stoneware, Bottle Glass, and Decorated Ceramics, Site 13LN352.Plate 16. Stoneware, Blowpipe Pontil Mark, and Decorated Ceramics, Site 13LN353.l: ! Ii I' i: ! j: i I Plate 15. Stoneware, Bottle Glass, and Decorated Ceramics, Site 13LN352. Plate 16. Stoneware, Blowpipe Pontil Mark, and Decorated Ceramics, Site 13LN353. '4, ' 4 '.. .......~ '~ J* ;44,........4.............. Plate 17. Stoneware, Decorated Ceramics, Applied-Tooled Bott le Neck, andBlowpipe Pontil Mark, Site 13LN354.5em Plate 18. Stoneware and Decorated Ceramics, Site 13LN355.Plate 17. Stoneware, Decorated Ceramics, Applied-Tooled Bottle Neck, and Blowpipe Ponti! Mark, Site 13LN354. Plate 18. Stoneware and Decorated Ceramics, Site 13LN355. Plate 19. Stoneware and Decorated Ceramics, Site 13LN367.Plate 20. Stoneware, Decorated Ceramics, and Folded Bottle Lip, Site 13LN368.Plate 19. Stoneware and Decorated Ceramics, Site 13LN367. Plate 20. Stoneware, Decorated Ceramics, and Folded Bottle Lip, Site 13LN368. Plate 21. Stoneware and Decorated Ceramics, Site 13LN369.Plate 22. Stoneware, Decorated Ceramics, Lacy Pressed Glass, and Kaolin Pipe Bowl, Site 13LN370.Plate 21. Stoneware and Decorated Ceramics, Site 13LN369. Plate 22. Stoneware, Decorated Ceramics, Lacy Pressed Glass, and Kaolin Pipe Bowl, Site 13LN370. Plate 23. Stoneware, Bottle and Tableware Glass, and Decorated Ceramics, Site 13LN360.Plate 24. Decorated Ceramics and Stoneware, Site 13LN373... , i I ) Plate 23. Stoneware, Bottle and Tableware Glass, and Decorated Ceramics, Site 13LN360 . Plate 24. Decorated Ceramics and Stoneware, Site 13LN373. Plate St ar Plate 25. Stoneware, Bottle Glass, and Decorated Ceramics, Site 13LN376.ii, Plate 26. Limestone Quarry (Site 13LN334), View to the North.Plate 25. Stoneware, Bottle Glass, and Decorated Ceramics, Site 13LN376. Plate 26. Limestone Quarry (Site 13LN334), View to the North. Plate 27. Lewis Gristmill Limestone Foundation (Site 13LN333), View to the Southwest. 1 7-+ -1 SARW 9 ' -Plate 28. Lewis Gristmill Site (13LN333), View to the South.[Foundation visible in creek bank, with old bridge abutment to right], I : J Plate 27. Lewis 'Gristmill Limestone Foundation (Site 13LN333), View to the Southwest. Plate 28. Lewis Gristmill Site (13LN333), View to the South. [Foundation visible in creek bank, with old bridge abutment to right] ~Ac.Plate 29. Surface Survey of Site 13LN332, View to the Southwest. Plate 30. Shovel Testing at Site 13LN332, View to the South-Southeast. I , \ r Plate 29. Surface Survey of Site 13LN332, View to the Southwest.

. f :. J Plate 30. Shovel Testing at Site 13LN332, View to the South-Southeast.

ARTIFACT DESCRIPTIONS ApPE DIXB: ARTIFACT DESCRIPTIONS Table 1. Artifacts From Site 13LN332.Provenience Count Descriptioni"" '1 I Surface 1 1 2 1 40 2 1 2 1 3 6 5 1 1 17 3 1 2 1 1 14 1 43 1 14 5 2 3 7 1 1 I 1 2 3 1 I 1 1 1 1 1 1 I 1 1 1 3 Porcelain undecorated sherd Porcelain figurine fragment Pearlware undecorated sherds Pearlware flow blue handpainted sherd Whiteware undecorated sherds Whiteware undecorated sherds, maker's marks Whiteware flow blue handpainted w/floral handpainted sherd Whiteware floral handpainted sherd Whiteware annular decorated sherd Whiteware light blue transfer printed sherds Whiteware blue shell edge decorated sherds Whiteware polychrome sponge decorated sherds Whiteware blue sponge decorated sherd Whiteware mold decorated sherd Ironstone undecorated sherds, four Provincial Blue Ironstone mold decorated sherds, two-Provincial Blue Stoneware early Bristol glazed bottle sherd Yelloware undecorated sherds Stoneware salt glazed, cobalt blue stamped sherd Stoneware alkaline glazed sherd Stoneware slip glazed sherds Redware lead glazed sherd Stoneware salt glazed sherds Stoneware unslipped sherd Brick fragments, five glazed Limestone fragments, three burned Drain tile fragments Asphalt shingle fragments Cast iron stove parts Cast iron kettle body Iron wagon wheel band Iron chain/ring Iron handle Iron machine cut nail fragments Iron buckle Zinc canning jar lid fragment Brass kerosene lamp wick holder ring Brass/nickel plated decorative plate Copper large cent, braided hair, 1840s-57Lead disk Lead disk/ring Whetstone fragment Bone fragment Glass bottle base, glass-tipped pontil mark, blue Glass moldblown bottle base, blue Glass moldblown bottle base, blue, embossed/lettered Glass moldblown flask base, blue, possible retouch Glass moldblown bottle body, blue I Provenience Surface Table 1. Artifacts From Site 13LN332. Count 1 1 2 1 40 2 1 2 1 3 6 5 1 1 17 3 1 2 1 1 14 1 43 1 14 5 2 3 7 1 1 1 1 2 1 1 1 1 1 1 1 1 1 1 1 1 1 3 Description Porcelain undecorated shew Porcelain figurine fragment Pearlware undecorated sherds Pearlware flow blue handpainted sherd Whiteware undecorated sherds Whiteware undecorated sherds, maker's marks Whiteware flow blue handpainted wlfloral handpainted sherd Whiteware floral handpainted sherd Whiteware annular decorated sherd Whiteware light blue transfer printed sherds Whiteware blue shell edge decorated sherds Whiteware polychrome sponge decorated sherds Whiteware blue sponge decorated sherd Whiteware mold decorated sherd Ironstone undecorated sherds. four Provincial Blue Ironstone mold decorated sherds, two'Provincial BIue Stoneware early Bristol glazed bottle sherd Yelloware undecorated sherds Stoneware salt glazed. cobalt blue stamped sherd Stoneware alkaline glazed sherd Stoneware slip glazed sherds Redware lead glazed sherd Stoneware salt glazed sherds Stoneware unslipped sherd Brick fragments, five glazed Limestone fragments. three burned Drain tile fragments Asphalt shingle fragments Cast iron stove parts Cast iron kettle body Iron wagon wheel band Iron chain/ring Iron handle Iron machine cut nail fragments Iron buckle Zinc canning jar lid fragment Brass kerosene lamp wick holder ring Brass/nickel plated decorative plate Copper large cent, braided hair, 184Os-57 Lead disk Lead disklring Whetstone fragment Bone fragment Glass bottle base, glass-tipped pontil mark, blue Glass moldblown bottle base, blue Glass moldblown bottle base, blue, embossed/lettered Glass moldblown flask base, blue, possible retouch Glass moldblown bottle body, blue Table 1. Continued. Provenience Count Description Surface continued ST1/0-10cm bs ST1/10-20cm bs STl/20-30cm bs ST1/30-40cm bs ST1/40-50cm bs STI/50-60cm bs ST2/0-10cm bs ST2/10-20cm bs ST2/20-30cm bs ST2W30-40cm bs 4 1 1 1 2 1 4 26 2 1 2 1 1 3 1 2 2 2 3 5 2 1 1 1 3 5 1 1 5 3 1 1 4 1 1 1 1 1 1 1 3 1Glass moldblown bottle body, blue, embossed/lettered Glass bottle lip, applied tooled/cork finish, blueGlass bottle base, brown Glass machine pressed jar body, opaque white Glass pressed Lacy Pattern tableware body, clearGlass pressed tumbler base, amethyst Glass pressed tableware body, amethyst Glass flat window fragments, 3=1.25, 2=1.5, 6=1.75, 6=2, 4=2.25, 3=2.5, 1=2.75, 1=3mm thick Chert flakes Iron machine cut nail fragment Mortar fragmentsBrick fragment Iron machine cut nail fragment Brick fragments Mortar fragment Coal cinders Brick fragments Limestone fragments Brick fragments Mortar fragments Limestone fragment Yelloware undecorated sherd Drain tile fragment Brick fragments Mortar fragments Limestone fragment Iron unidentifiable nail fragment Brick fragmentsLimestone fragments Iron machine cut nail fragment Glass flat window fragment, 1.5mm thick Limestone fragmentsBrick fragment Iron machine cut nail fragment Iron barbed wire fragment Redware lead glazed sherd Glass fragment, blue Glass moldblown bottle lip/neck, improved tooled/cork finish, amethyst Limestone fragment Limestone fragments Limestone fragment'[ i i [1 ; i ;" 1 ! i , j ; I ! i i I 'i , ! : , i i , I , I i ! ! j ! 1 : i '. ' I j Provenience Count Surface continued 4 1 1 1 2 1 4 26 2 STl/O-IOcm bs 1 2 1 STl/1O-2Ocm bs 1 3 1 2 STl/20-30cm bs 2 2 STl/30-4Ocm bs 5 2 1 1 I STI/40-5Ocm bs 3 5 1 1 STl/50-6Ocm bs 5 3 1 1 ST2/O-10em bs 4 1 1 1 1 I 1 ST2/1O-2Ocm bs 1 ST2/20-3Ocm bs 3 ST2/30-4Ocm bs 1 Table 1. Continued. Description Glass moldblown bottle body, blue, embossedllettered Glass bottle lip, applied tooled/cork finish, blue G lass bottle base, brown Glass machine pressed jar body, opaque white Glass pressed Lacy Pattern tableware body, clear Glass pressed tumbler base, amethyst Glass pressed tableware body, amethyst Glass flat window fragments, 3=1.25, 2=1.5, 6=1.75, 6=2, 4=2.25, 3=2.5, 1=2.75, 1=3mm thick Chert flakes Iron machine cut nail fragment Mortar fragments Brick fragment Iron machine cut nail fragment Brick fragments Mortar fragment Coal cinders Brick fragments Limestone fragments Brick fragments Mortar fragments Limestone fragment Yelloware undecorated sherd Drain tile fragment Brick fragments Mortar fragments Limestone fragment Iron unidentifiable nail fragment Brick fragments Limestone fragments Iron machine cut nail fragment Glass flat window fragment, 1.5mm thick Limestone fragments Brick fragment Iron machine cut nail fragment Iron barbed wire fragment Redware 1ead glazed sherd Glass fragment, blue Glass moldblown bottle lip/neck, improved tooled/cork finish, amethyst Limestone fragment Limestone fragments Limestone fragment Table 1. Continued. Provenience Count Description ST3/0-10cm bs ST3/10-20cm bs ST3/20-30cm bs ST4/0-10cm bs ST4/10-20cm bs ST5/0-10cm bs ST5/10-20cm bs ST6/O-1Ocm bs il Brick fragments Limestone fragments Yelloware undecorated sherd Redware manganese brown glazed sherds Whiteware undecorated sherd Whiteware floral handpainted/flow blue sherd Limestone fragment Mortar fragment Pearlware/Whiteware undecorated sherds Mortar fragment Stoneware slip glazed sherd Brick fragment Brick fragmentBrick fragments Redware manganese brown glazed sherd Brick fragments Mortar fragments Limestone fragments Whiteware blue sponge decorated sherd Mortar fragments Yelloware undecorated sherd Redware manganese glazed sherd Redware lead glazed sherd Pearlware blue sponge decorated sherd Pearlware floral handpainted sherd Glass flat window fragment, 2.3mm thick Chert flake! ]1 ST6/10-20cm bs!.Table 2. Artifacts From Site 13LN333.Provenience Count Description Surface 1 Glass melted fragment, blue 1 Porcelain blue transfer printed sherd r i: : i , \ : ? . I ; ! i ., I I ** 1 Provenience STI/O-IOcm bs ST3/1O-2Ocm bs STI!20-30cm bs ST4/O-1Ocm bs ST4/1O-2Ocm bs ST5/O-10em bs ST5/1O-20em bs ST6/O-10em bs ST6/10-2Ocm bs Count 3 2 1 2 1 1 1 1 2 1 1 I 1 3 1 2 3 3 1 2 1 1 1 1 1 1 1 Table 1. Continued. Description Brick fragments Limestone fragments Yelloware undecorated sherd Redware manganese brown glazed sherds Whiteware undecorated sherd Whiteware floral handpaintedlf10w blue sherd Limestone fragment Mortar fragment Pearlware/Whiteware undecorated sherds Mortar fragment Stoneware slip glazed sherd Brick fragment Brick fragment Brick fragments Redware manganese brown glazed sherd Brick fragments Mortar fragments Limestone fragments Whiteware blue sponge decorated sherd Mortar fragments Yelloware undecorated sherd Redware manganese glazed sherd Redware lead glazed sherd Pearlware blue sponge decorated sherd Pearlware floral handpainted sherd Glass flat window fragment, 2.3mm thick Chert flake Table 2. Artifacts From Site 13LN333. Provenience Surface Count 1 1 Description Glass melted fragment, blue Porcelain blue transfer printed sherd Table 3. Artifacts From Site 13LN336.I.Provenience Count Description Surface 2 Brick fragments 2 Brass sheet fragments Table 4. Artifacts From Site 13LN337.Provenience Count Description Surface I Concrete fragment 1 Limestone fragment 1 Brick fragment 1 Redware lead glazed sherd 1 Whiteware undecorated sherds 1 Glass flat window fragment, 2mm thick 1 Glass bottle/jar body, blue 2 Iron staples 1 Iron unidentifiable nail 5 Iron barbed wire fragments 2 Iron sheet fragments 1 Iron wire nail fragment I Chert flake , , :' " j '." 'I' , ", I ! : j Provenience Surface Provenience Surface Table 3. Artifacts From Site 13LN336. Count 2 2 Description Brick fragments Brass sheet fragments Table 4. Artifacts From Site 13LN337. Count 1 I 1 1 1 1 1 2 I 5 2 I 1 Description Concrete fragment Limestone fragment Brick fragment Redware lead glazed sherd Whiteware undecorated sherds Glass flat window fragment, 2mm thick Glass bottle/jar body, blue Iron staples Iron unidentifiable nail Iron barbed wire fragments Iron sheet fragments Iron wire nail fragment Chert flake Provenienceabl Con Dsrito Artifacts From Site 13LN338.Provenience Count Description Surface 1 3 2 1 1 1 I 1 1 1 4 1 1 1 3 5 2 1 1 1 1 13 1 1 1 1 2 4 5 3 3 I 1 3 1 1 1 6 1 1 2 3 3 22 5 8 8 Chert flake Lead slag chunk Lead disk fragments Brass cone Brass clothing rivet Brass hinge fragment Brass gear Brass button Copper half-penny, Great Britain, 1799Iron wagon ferrule Iron harness ring Iron harness bit/ring Iron buckle Cast iron stove parts Iron bar/strap fragments Iron machine parts Iron square nut (large)Iron chain Iron bracket Iron drawer handle Iron machine cut nails Iron wire nailIron handwrought nailIron unidentifiable fragment Iron buckle frame Iron barbed wire fragments Iron sheet fragments Brick fragments Limestone, two burned Shell, freshwater mussel Coal cinder Glass bottle base, blowpipe pontil mark, blue Glass moldblown bottle bases, blue Glass moldblown bottle body, blue Glass bottle body, green Glass bottle body, brown Glass, flat window fragments, 3=1.9, 1=2, 1=2.3, 1=2.7mm Glass tumbler fragment, amethystGlass decanter stopper, amethyst Yelloware mottled brown glazed sherds Redware manganese glazed sherdsRedware lead glazed sherds Stoneware salt glazed sherds Stoneware slip glazed sherds Ironstone undecorated Provincial Blue sherds Whiteware undecorated sherds Provenience Surface I ; i ! Count 1 3 2 1 1 1 1 1 1 1 1 1 1 3 5 2 1 1 1 1 13 1 1 1 1 2 4 5 3 3 1 1 3 1 1 1 6 1 1 2 3 3 22 5 8 8 Table S. Artifacts From Site 13LN338. Description Chen flake Lead slag chunk Lead disk fragments Brass cone Brass clothing rivet Brass hinge fragment Brass gear Brass button Copper half-penny, Great Britain, 1799 Iron wagon ferrule Iron harness ring Iron harness bit/ring Iron buckle Cast iron stove parts Iron bar/strap fragments Iron machine parts Iron square nut (large) Iron chain Iron bracket Iron drawer handle Iron machine cut nails Iron wire nail Iron handwrought nail Iron unidentifiable fragment Iron buckle frame Iron barbed wire fragments Iron sheet fragments Brick fragments Limestone, two burned Shell, freshwater mussel Coal cinder Glass bottle base, blowpipe pontil mark, blue Glass moldblown bottle bases, blue Glass moldblown bottle body, blue Glass bottle body, green Glass bottle body, brown Glass, flat window fragments, 3=1.9, 1=2, 1=2.3, 1=2.7mm Glass tumbler fragment, amethyst Glass decanter stopper, amethyst Yelloware mottled brown glazed sherds Redware manganese glazed sherds Redware lead glazed sherds Stoneware salt glazed sherds Stoneware slip glazed sherds Ironstone undecorated Provincial BIue sherds Whiteware undecorated sherds Table 5. Continued. Provenience Count Description Surface continued ST1/0-10cm bs STI/10-20cm bs ST1/20-30cm bs ST1/30-40cm bs ST2/0-10cm bs ST3/0-10cm bs ST3/10-20cm bs ST4/0-10cm bs ST4/10-20cm bs ST4/20-30cm bs ST5/0-0Ocm bs ST5/10-20cm bs ST6/0-10cm bs ST6/10-20cm bs ST7/0-10cm bs ST7/10-20cm bs ST7/20-30cm bs ST8/0-10cm bs ST8/10-20cm bs STIO/0-10cm bs STJO/10-20cm bs ST11/0-1Ocm bs STI 1/10-20cm bs Pearlware undecorated sherds Whiteware floral handpainted sherds Whiteware red transfer printed sherds Whiteware red transfer printed sherd, burned Whiteware blue transfer printed sherd Whiteware blue sponge decorated sherd Whiteware blue shell edge decorated sherd Whiteware annular decorated sherd Porcelain button Iron machine cut nail fragment Mortar fragments Limestone fragments Brick fragment Iron machine cut nail fragment Iron machine cut nail fragmentsLimestone fragmentLimestone fragmentsStoneware slip glazed sherd Glass bottle body, blue Limestone fragments Whiteware undecorated sherd Glass moldblown bottle base, aqua Brick fragment Iron machine cut nail Pearlware undecorated sherds Pearlware undecorated sherd Iron machine cut nail fragments Brick fragment Limestone fragments Brick fragment Whiteware undecorated sherd Limestone fragment Brick fragment Brick fragment Limestone fragments Iron wire fragment Limestone fragments Whiteware undecorated thick sherd Limestone fragments Glass flat window fragment, 1.4mm thick Limestone fragment Limestone fragment Brick fragment Iron machine cut nail fragment Provenience Count Surface continued 2 4 3 1 1 1 1 1 1 STlIO-lOem bs 1 2 STl/1O-20cm bs 2 STI/20-3Ocm bs 1 STl!30-4Ocm bs 1 ST2/O-10em bs 2 1 STI/O-lOem bs 5 1 1 STI/1O-20em bs 2 1 ST4/O-1Ocm bs 1 ST4/1O-2Ocm bs 1 I 3 ST4/20-30em bs 1 ST5/O-1Ocm bs 2 1 ST5/1O-20em bs 4 ST6/O-1Ocm bs 1 1 ST6/1O-2Ocm bs 1 1 STI/O-IOcm bs 1 2 1 STI/1O-2Ocm bs 3 Sn/20-3Ocm bs 1 ST8/O-1Ocm bs 5 STS/IO-2Ocm bs 1 STI 0/0-1 Oem bs 1 STlO/1O-2Ocm bs 1 STll/O-IOcm bs 1 STl1/1O-20cm bs 1 Table 5. Continued. Description Pearlware undecorated sherds Whiteware floral handpainted sherds Whiteware red transfer printed sherds Whiteware red transfer printed sherd, burned Whiteware blue transfer printed sherd Whiteware blue sponge decorated sherd Whiteware blue shell edge decorated sherd Whiteware annular decorated sherd Porcelain button Iron machine cut nail fragment Mortar fragments Limestone fragments Brick fragment Iron machine cut nail fragment Iron machine cut nail fragments Limestone fragment Limestone fragments Stoneware slip glazed sherd Glass bottle body, blue Limestone fragments Whiteware undecorated sherd Glass moldblown bottle base, aqua Brick fragment Iron machine cut nail Pearl ware undecorated sherds Pearlware undecorated sherd Iron machine cut nail fragments Brick fragment Limestone fragments Brick fragment Whiteware undecorated sherd Limestone fragment Brick fragment Brick fragment Limestone fragments iron wire fragment Limestone fragments Whiteware undecorated thick sherd Limestone fragments Glass flat window fragment, l.4mm thick Limestone fragment Limestone fragment Brick fragment Iron machine cut nail fragment Table 6. Artifacts From Site 13LN339.Provenience Count Description Surface ST 1/0-10cm bs ST1/10-20cm bs ST1/20-30cm bs STI/30-40cm bs ST1/4 0-50cm bs ST1/50-60cm bs ST4/0-0Ocm bs 1 23 1 1 5 1 6 1 1 2 3 1 6 2 3 2 5 2 9 1 3 2 4 2 1 1 I 1 1 3 2 5 2 9 1 7 8 6 5 1 1 1 1 20 1 1 1 2 Glass machine made bottle, lug finish, clear Glass jar lid liner fragment, opaque white Glass, flat window fragment, 2.3mm thickIron wire nail, 3" longZinc canning jar lids (Ball)Brass salt shaker lid Brass kerosene lamp wick holder Brass decorative plate, furniture Iron flat plate Whiteware undecorated sherds Whiteware mold decorated sherd Bone fragment, burned Leather boot fragments Glass goblet stem fragment, clear Glass bottle/jar body fragments, clear Glass machine made jar lip, clear Glass machine made jar lips, opaque white Iron staple Iron wire nail, 2-1/2" long Iron barbed wire fragmentsWhiteware undecorated sherdsGlass bottle/jar body, clear Glass machine made jar lips, clear Glass, flat window fragment, 2mm thickBrick fragment Leather shoe fragment Whiteware unidentifiable decorated sherd Iron wire fragment Brick fragments Iron wire fragments Glass bottle/jar body, clear Glass bottle/jar body, clear Mortar fragmentsConcrete fragmentCoal cinders/slagBrick fragments Tin cone-top beer can lids Tin bottle crown caps Iron bar fragment Iron clothing rivet Iron bolt/square nut Iron wood screwIron wire nails Iron staple Whiteware mold decorated sherdWhiteware decal/mold decorated sherd Whiteware decal decorated sherds!Table 6. Artifacts From Site 13LN339. Provenience Count Description Surface 1 Glass machine made bottle, lug fmish, clear 23 Glass jar lid liner fragment, opaque white 1 Glass, flat window fragment, 2.3mm thick 1 Iron wire nail, 3" long 5 Zinc canning jar lids (Ball) 1 . Brass salt shaker lid 1 Brass kerosene lamp wick holder 1 Brass decorative plate, furniture 1 Iron flat plate 2 Whiteware undecorated sherds 1 Whiteware mold decorated sherd 1 Bone fragment, burned ! "J ST 1/0-1 Oem bs 6 Leather boot fragments

l: 1 Glass goblet stem fragment, clear : I 2 Glass bottle/jar body fragments, clear 1 Glass machine made jar lip, clear i' 2 Glass machine made jar lips, opaque white !. : j STl/lO-20cm bs 1 Iron staple

• I 1 Iron wire nail, 2-1/2" long .. i 3 Iron barbed wire fragments I. 2 Whiteware undecorated sherds .. i 4 Glass bottle/jar body, clear 2 Glass machine made jar lips, clear 11 1 Glass, flat window fragment, 2mm thick : i! !. ) STlf20-30cm bs 1 Brick fragment 1 Leather shOe fragment "i L 1 Whiteware unidentifiable decorated sherd STl!30-40em bs 1 Iron wire fragment STl/40-5Ocm bs 3 Brick fragments 2 Iron wire fragments i 5 Glass bottle/jar body, clear i ; j STl/50-6Ocm bs 2 Glass bottle/jar body, clear ST4/O-1Ocm bs 9 Mortar fragments i 1 Concrete fragment i; ! 7 Coal cinders/slag 8 Brick fragments

!' 6 Tin cone-top beer can lids 5 Tin bottle crown caps 1 Iron bar fragment 1 Iron clothing rivet 1 Iron bolt/square nut 1 Iron wood screw 20 Iron wire nails 1 Iron staple 1 Whiteware mold decorated sherd 1 Whiteware decal/mold decorated sherd 2 Whiteware decal decorated sherds Table 6. Continued. Provenience Count Description ST4/0-10 cm cont.ST4/10-20cm bs 3 1 3 1 1 2 1 1 3 1 1 2 1 1 22 1 1 1 1 2 1 1 1 2 1 I 10 1 1 1 1 I.3 1 3 I 1 1 Whiteware undecorated sherds Stoneware salt glazed sherds Glass tableware fragment, opaque white/handpainted Glass machine made whole bottle, continuous thread, brown Glass machine made whole catsup bottle, amethyst Glass machine made whole bottles, continuous thread, clear Glass machine made whole bottle, tin screw lid, clear Glass pressed tableware rim, light yellow, Depression Glass Glass pressed tableware rims, light green, Depression Glass Glass, flat window fragment, 2.8mm thickGlass bottle body, brown, embossed/lettered Glass bottle body, clear, embossed/lettered Glass jar lid liner fragments, opaque white Glass machine made jar lip, continuous thread, clear Glass machine made jar lip, clear Glass bottle body, various colorsGlass machine made jar lip/neck, continuous thread, green Glass machine made milk bottle neck, amethyst Glass machine made bottle base, brown Glass machine pressed jar base, opaque white Glass machine made bottle bases, amethystGlass machine pressed jar base, amethyst Glass machine made jar body, amethyst Glass machine made jar base, aquaGlass machine made milk bottle body, color label, clear Glass machine made bottle base, amethyst Glass machine made bottle neck, brown Glass bottle body, amethystGlass bottle body, amethyst, embossed/letteredGlass bottle body, brownGlass bottle body, brown, embossed/lettered Glass, flat window fragment, 2. 1mm thick Glass moldblown bottle body, blue Glass moldblown bottle body, brown Whiteware undecorated sherds Kaolin pipe stem endpiece Iron wire nailsTin crown bottle cap with plastic liner Tin sardine can key Tin cone-top beer can lid\ ; r . i: Provenience Count ST4/0-1O em cont. 3 1 1 1 1 2 1 1 3 1 1 1 2 1 1 22 1 1 1 1 2 1 1 1 2 1 ST4/1O-2Ocm bs 1 10 1 1 1 I 1 1 3 1 3 1 1 1 Table 6. Continued. Description Whiteware undecorated sherds Stoneware salt glazed sherds Glass tableware fragment, opaque white/handpainted Glass machine made whole bottle, continuous thread, brown Glass machine made whole catsup bottle, amethyst Glass machine made whole bottles, continuous thread, clear Glass machine made whole bottle, tin screw lid, clear Glass pressed tableware rim, light yellow, Depression Glass Glass pressed tableware rims, light green, Depression Glass Glass, flat window fragment, 2.8mm thick ' Glass bottle body. brown, embossedllettered Glass bottle body, clear, embossed/lettered Glass jar lid liner fragments, opaque white Glass machine made jar lip, continuous thread, clear Glass machine made jar lip, clear Glass bottle body, various colors Glass machine made jar lip/neck, continuous thread, green Glass machine made milk bottle neck, amethyst Glass machine made bottle base, brown Glass machine pressed jar base, opaque white Glass machine made bottle bases, amethyst Glass machine pressed jar base, amethyst Glass machine made jar body, amethyst Glass machine made jar base, aqua Glass machine made milk bottle body, color label, clear Glass machine made bottle base, amethyst Glass machine made bottle neck, brown Glass bottle body. amethyst Glass bottle body, amethyst. embossed/lettered Glass bottle body, brown Glass bottle body, brown, embossed/lettered Glass. flat window fragment, 2.1mm thick Glass moldblown bottle body, blue Glass moldblown bottle body, brown Whiteware undecorated sherds Kaolin pipe stem endpiece Iron wire nails Tin crown bottle cap with plastic liner Tin sardine can key Tin cone-top beer can lid Table 7. Artifacts From Site 13LN340.Provenience Count Description Surface I Iron hinge 1 Iron sheet fragment I Iron machine cut nail 2 Stoneware salt glazed sherds 13 Stoneware slip glazed sherds 2 Stoneware salt/slip glazed milk bowl sherds 2 Stoneware Bristol/Albany slip glazed sherds 9 Whiteware undecorated sherds I Whiteware mold decorated sherd 8 Ironstone undecorated sherds, Provincial Blue 2 Porcelain undecorated sherds 2 Brick, soft mud 3 Shell, freshwater mussel 1 Shell/Brass button I Slate fragment 3 Limestone fragments, burned 5 Glass, flat window fragments, 1.25, 1.5, 2.25, 2.5, 2.75mm 3 Glass melted fragments 4 Glass bottle body, amethyst 2 Glass pressed tableware fragments, amethyst 1 Glass jar shoulder fragment, blue 1 Glass moldblown jar lip, screw thread/ground rim, blue1 Glass bottle body, blue, embossed/lettered 10 Glass bottle body, blue 2 Glass moldblown bottle bases, blue1 Glass insulator fragment, aqua Table 8. Artifacts From Site 13LN341.Provenience Count Description Surface 1 Brick fragment, soft mud 2 Limestone fragments, one burned 10 Glass flat window fragments, 4=1.75, 1=2.25, 4=2.5, 1=1.75mm thick I Glass kerosene chimney fragment, clear I Glass bottle body, blue 1 Glass melted fragment, blue I Glass moldblown bottle body, blue, embossed/lettered 7 Stoneware slip glazed sherds 2 Stoneware salt glazed sherds (one mold-made) 1 Yelloware annular decorated sherd I Porcelain toy cup fragment 9 Ironstone undecorated sherds, Provincial Blue 17 Whiteware undecorated sherds Provenience Surface Provenience Surface Table 7. Artifacts From Site 13LN340. Count 1 1 1 2 13 2 2 9 1 8 2 2 3 1 1 3 5 3 4 2 1 1 1 10 2 1 Description Iron hinge Iron sheet fragment Iron machine cut nail Stoneware salt glazed sherds Stoneware slip glazed sherds Stoneware salt/slip glazed milk bowl sherds Stoneware BristoVAlbany slip glazed sherds Whiteware undecorated sherds Whiteware mold decorated sherd Ironstone undecorated sherds, Provincial Blue Porcelain undecorated sherds Brick, soft mud Shell, freshwater mussel Shel1JBrass button Slate fragment Limestone fragments, burned Glass, flat window fragments, 1.25, 1.5,2.25,2.5, 2.75mm Glass melted fragments Glass bottle body, amethyst Glass pressed tableware fragments, amethyst Glass jar shoulder fragment, blue Glass moldblown jar lip, screw thread/ground rim, blue Glass bottle body, blue, embossed/lettered Glass bottle body, blue Glass moldblown bottle bases, blue Glass insulator fragment, aqua Table 8. Artifacts From Site 13LN341. Count 1 2 10 1 1 1 1 7 2 1 1 9 17 Description Brick fragment, soft mud Limestone fragments, one burned Glass flat window fragments, 4::::1.75, 1::::2.25,4=2.5, 1=1.75mm thick Glass kerosene chimney fragment, clear Glass bottle body, blue Glass melted fragment, blue Glass moJdblown bottle body, blue, embossedllettered Stoneware slip glazed sherds Stoneware salt glazed sherds (one mold-made) Yelloware annular decorated sherd Porcelain toy cup fragment Ironstone undecorated sherds, Provincial Blue Whiteware undecorated sherds Table 9. Artifacts From Site 13LN342. Provenience Count Description Surface 1 Whiteware undecorated sherd 2 Glass flat window fragments, 2.25 and 2.5mm thick 1 Glass machine made bottle lip/neck, blue 1 Limestone fragment1 Brick fragment, soft mud, sand struck Table 10. Artifacts From Site 13LN343.Provenience Count Description Surface 2 Glass flat window fragments, 1.75 and 2mm thick 4 Glass bottle body, blue 2 Glass moldblown bottle bases, blue 1 Yelloware Mocha decorated sherd 2 Whiteware undecorated sherds 2 Stoneware slip glazed sherds 2 Stoneware salt glazed sherds 2 Stoneware salt/slip glazed milk bowl sherds 1 Redware manganese glazed sherd6 Redware lead glazed sherds I Glass jar lid liner fragment, opaque white Table 11. Artifacts From Site 13LN344.Provenience Count Description Surface 3 Glass flat window fragments, 1=1.75, 2=2.25mm thick 1 Glass flat window, thick ridged fragment1 Glass bottle body, brown 1 Glass machine made jar lip, clear1 Glass tableware rim, opaque white I Glass pressed tableware body, opaque white 1 Slate fragment1 Brick, stiff mud with adhering mortar 2 Stoneware salt glazed sherds 1 Stoneware slip glazed sherd 2 Stoneware salt glazed milk bowl sherd I Stoneware Bristol/Bristol glazed, sponged decorated sherd 1 Yelloware annular decorated mold-made sherd 4 Whiteware undecorated sherds 1 Ironstone mold decorated sherd 1 Whiteware decal/handpainted sherd I Whiteware gold decal decorated sherd 2 Porcelain undecorated sherd 1 Porcelain handpainted rimband decorated sherd.'" . i : f . i ., I i 'r. : ; ; j " " I ; ! ! J ; J i I i .J Provenience Surface Provenience Surrace Provenience Surrace Table 9. Artifacts From Site 13LN342. Count 1 2 1 1 1 Description Whiteware undecorated sherd Glass flat window fragments, 2.25 and 2.5mm thick Glass machine made bottle lip/neck, blue Limestone fragment Brick fragment, soft mud, sand struck Table 10 . Artifacts From Site 13LN343. Count 2 4 2 1 2 2 2 2 1 6 1 Description Glass flat window fragments, 1.75 and 2mm thick Glass bottle body, blue Glass mold blown bottle bases, blue Yelloware Mocha decorated sherd Whiteware undecorated sherds Stoneware slip glazed sheIrls Stoneware salt glazed sherds Stoneware salt/slip glazed milk bowl sherds Redware manganese glazed sherd Redware lead glazed sherds Glass jar lid liner fragment, opaque white Table 11. Artifacts From Site 13LN344. Count 3 I 1 1 1 1 I 1 2 1 2 1 1 4 1 1 1 2 1 Description Glass flat window fragments, 1=1.75, 2=2.25mm thick Glass flat window, thick ridged fragment Glass bottle body, brown Glass machine made jar lip, clear Glass tableware rim, opaque white Glass pressed tableware body, opaque white Slate fragment Brick, stiff mud with adhering mortar Stoneware salt glazed sherds Stoneware slip glazed sherd Stoneware salt glazed milk bowl sherd Stoneware BristollBristol glazed, sponged decorated sherd Yelloware annular decOrated mold-made sherd Whiteware undecorated sherds . Ironstone mold decorated sherd Whiteware decal/handpainted sherd Whiteware gold decal decorated sherd Porcelain undecorated sherd Porcelain handpainted rimband decorated sherd Table 12. Artifacts From Site 13LN345.Provenience Count Description Surface 1 Brick fragment, soft mud, sand struck 2 Limestone fragments, one burned I Shell, freshwater mussel 5 Redware lead glazed sherds 5 Redware manganese brown glazed sherds 3 Stoneware salt glazed sherds I Whiteware blue shell edge decorated sherd I Whiteware red transfer printed sherd 1 Whiteware light blue transfer printed sherd 2 Whiteware unidentifiable blue decorated sherds 1 Whiteware floral handpainted sherd 18 Whiteware undecorated sherds 5 Ironstone undecorated sherds (4 Provincial Blue)2 Glass moldblown bottle body, olive green, embossed/lettered I Glass moldblown jar base, blue I Glass moldblown bottle base, blue I Glass moldblown bottle body, blue 10 Glass flat window fragments, 2=1.25, 1=1.5, 1=1.75, 3=2, 2=2.25, 1=2.5mm thick Table 13. Artifacts From Site 13LN346.Provenience Count Description Surface 1 Brick fragment, soft mud, water struck I Limestone fragment 8 Glass flat window fragments, 2=1.25, 2=1.5, 4=1.75mm 1 Glass bottle base, blowpipe pontil mark, blue 1 Glass moldblown bottle body, blue 1 Glass bottle body, blue 4 Redware lead glazed sherds I Ironstone undecorated sherd 4 Whiteware undecorated sherds I Whiteware floral handpainted sherd 1 Whiteware red transfer printed sherd 1 Whiteware light blue transfer printed sherd I Whiteware blue sponge decorated sherd I Whiteware overglaze handpainted/decal? decorated sherd 1 Brass button[ . j , " , f. : \ , Provenience Surface Provenience Surface Table 12. Artifacts From Site 13LN345. Count 1 2 1 5 5 3 1 1 1 2 1 18 5 2 1 1 1 10 Description Brick fragment, soft mud, sand struck Limestone fragments, one burned Shell, freshwater mussel Redware lead glazed sherds Redware manganese brown glazed sherds Stoneware salt glazed sherds Whiteware blue shell edge decorated sherd Whiteware red transfer printed sherd Whiteware light blue transfer printed sherd Whiteware unidentifiable blue decorated sherds Whiteware floral handpainted sherd Whiteware undecorated sherds Ironstone undecorated sherds (4 Provincial Blue) Glass moldblown bottle body, olive green, embossedllettered Glass moldblown jar base. blue Glass moldblown bottle base, blue Glass moldblown bottle body, blue Glass flat window fragments, 2=1.25. 1=1.5, 1::::1.75,3=2, 2=2.25, 1=2.5mm thick Table 13. Artifacts From Site 13LN346. Count 1 1 8 1 1 1 4 1 4 1 1 1 1 1 1 Description Brick fragment, soft mud, water struck Limestone fragment Glass flat window fragments, 2=1.25,2=1.5, 4::::1.75mm Glass bottle base, blowpipe pontil mark, blue Glass mold blown bottle body, blue Glass bottle body, blue Redware lead glazed sherds Ironstone undecorated sherd Whiteware undecorated sherds Whiteware floral handpainted sherd Whiteware red transfer printed sherd Whiteware light blue transfer printed sherd Whiteware blue sponge decorated sherd Whiteware overglaze handpainted/deca1? decorated sherd Brass button Table 14. Artifacts From Site 13LN347.Provenience Count Description Surface 1 Brick fragment, soft mud 2 Limestone fragments, one burned 5 Glass flat window fragments, 1=1.5, 2=1.75, 1=2, 2=2.25mm thick 1 Glass bottle base, blowpipe pontil, blue, embossed/lettered 1 Glass bottle base, blowpipe pontil, blue 3 Whiteware blue shell edge decorated sherds 2 Whiteware floral handpainted sherds I Whiteware blue transfer printed sherd 2 Whiteware unidentifiable decorated sherds 2 Whiteware transfer printed/handpainted sherds 2 Ironstone undecorated sherds 19 Whiteware undecorated sherds 6 Stoneware salt glazed sherds 4 Stoneware slip glazed sherds 2 Stoneware detached stem pipe bowl fragments 2 Redware manganese brown glazed sherds I Yelloware undecorated sherd 9 Iron machine cut nails 1 Iron scissors handle 1 Iron unidentifiable fragment 15 Chert flakes Table 15. Artifacts From Site 13LN349.Provenience Count Description Surface 3 Brick fragments, soft mud/water struck, one glazed 3 Glass flat window fragments, 1.25, 1.5, and 2.25mm thick 2 Glass melted fragments, blue 2 Glass bottle body, blue 4 Redware lead glazed sherds 1 Stoneware slip glazed sherd 8 Stoneware salt glazed sherds 4 Whiteware blue sponge decorated sherds 2 Whiteware undecorated sherds 1 Whiteware purple transfer printed sherd 1 Whiteware floral handpainted sherd 2 Whiteware annular decorated sherds 2 Whiteware flow blue transfer printed sherds 1 Whiteware burned sherd I Iron strap: ... { Provenience Surface . i : ; Provenience

j. Surface Table 14. Artifacts From Site 13LN347. Count 1 2 5 1 1 3 2 1 2 2 2 19 6 4 2 2 1 9 1 1 15 Description Brick fragment, soft mud Limestone fragments, one burned Glass flat window fragments, 1=1.5,2=1.75, 1=2, 2=2.25mm thick Glass bottle base, blowpipe pontil, blue, embossed/lettered Glass bottle base, blowpipe pontiI, blue Whiteware blue shell edge decorated sherds Whiteware floral handpainted sherds Whiteware blue transfer printed sherd Whiteware unidentifiable decorated sherds Whiteware transfer printedlhandpainted sherds Ironstone undecorated sherds Whiteware undecorated sherds Stoneware salt glazed sherds Stoneware slip glazed sherds Stoneware detached stem pipe bowl fragments Redware manganese brown glazed sherds Yelloware undecorated sherd Iron machine cut nails Iron scissors handle Iron unidentifiable fragment Chert flakes Table 15. Artifacts From Site 13LN349. Count 3 3 2 2 4 1 8 4 2 1 1 2 2 1 1 Description Brick fragments, soft mud/water struck, one glazed Glass flat window fragments, 1.25, 1.5, and 2.25mm thick Glass melted fragments, blue Glass bottle body, blue Redware lead glazed sherds Stoneware slip glazed sherd Stoneware salt glazed sherds Whiteware blue sponge decorated sherds Whiteware undecorated sherds Whiteware purple transfer printed sherd Whiteware floral handpainted sherd Whiteware annular decorated sherds Whiteware flow blue transfer printed sherds Whiteware burned sherd Iron*strap Table 16. Artifacts From Site 13LN350.Provenience Count Description Surface 7 Glass flat window fragments, 2=1.5, 1=1.75, 2=2, 1=2.25, 1=2.75mm thick 1 Brick fragment, soft mud 50+ Limestone fragments 2 Pearlware undecorated sherds Table 17. Artifacts From Site 13LN351.

Provenience Count Description Surface 1 Limestone fragment, burned 2 Brick fragments, soft mud, sand struck 7 Glass flat window fragments, 5=1.75, 1=2.25, 1=2.8mm 2 Glass bottle/jar body, melted, blue 1 Glass bottle/jar body, melted, amethyst I Glass bottle/jar body, amethyst 1 Glass bottle neck, blue 2 Glass bottle/jar body, blue 2 Glass bottle/jar body, blue, embossed/lettered 8 Stoneware salt glazed sherds 6 Redware lead glazed sherds I Yelloware undecorated sherd 12 Whiteware undecorated sherds 2 Pearlware undecorated sherds 4 Whiteware burned sherds I Ironstone mold decorated sherds, Provincial Blue 2 Whiteware floral handpainted sherds I Whiteware blue sponge decorated sherd 4 Iron machine cut nails I Iron unidentifiable fragment I Brass/nickel-plated buckle. " l" i. : j . i ". i : } ! Provenience Surface Provenience Surface Table 16. Artifacts From Site 13LN350. Count 7 1 50+ 2 Description Glass flat window fragments, 2=1.5, 1=1.75,2=2, 1=2.25, 1=2.75mm thick Brick fragment, soft mud Limestone fragments Pearlware undecorated sherds Table 17. Artifacts From Site 13LN351. Count 1 2 7 2 1 1 1 2 2 8 6 1 12 2 4 1 2 1 4 1 1 Description Limestone fragment, burned Brick fragments, soft mud, sand struck Glass flat window fragments, 5=1.75, 1=2.25, 1=2.8mm Glass bottle/jar body, melted, blue Glass bottle/jar body, melted, amethyst Glass bottle/jar body, amethyst Glass bottle neck, blue Glass bottle/jar body, blue Glass bottle/jar body, blue, embossedllettered Stoneware salt glazed sherds Redware lead glazed sherds Yelloware undecorated sherd Whitewate undeCorated sherds Pearlware undecorated sherds Whiteware burned sherds Ironstone mold decorated sherds, Provincial Blue Whiteware floral handpainted sherds Whiteware blue sponge decorated sherd Iron machine cut nails Iron unidentifiable fragment Brass/nickel-plated buckle Table 18. Artifacts From Site 13LN352.Provenience Count Description Surface 2 Glass flat window fragments, 1.5 and 2mm thick 3 Glass moldblown bottle body, blue 1 Glass moldblown figural flask body, blue 4 Stoneware salt glazed sherds 4 Redware lead glazed sherds 3 Stoneware slip glazed sherds I Yelloware undecorated sherd 1 Ironstone undecorated sherd2 Whiteware undecorated sherds I Pearlware undecorated sherd 1 Whiteware red transfer printed sherd2 Whiteware blue shell edge decorated sherds 1 Whiteware annular decorated sherd Table 19. Artifacts From Site 13LN353.Provenience Count Description Surface 2 Limestone fragments, burned 1 Brick fragment, soft mud, sand struck I Glass flat window fragment, 1.75mm thick 3 Stoneware salt glazed sherds 2 Redware lead glazed sherds 1 Ironstone mold decorated sherd, Provincial Blue 10 Whiteware undecorated sherds I Whiteware red sponge decorated sherd 1 Glass moldblown bottle base, blue 1 Glass moldblown scroll flask body, blue J: 1 : j Provenience Surface Provenience Surface Table 18. Artifacts From Site 13LN352. Count 2 3 1 4 4 3 1 1 2 1 1 2 1 Description Glass flat window fragments, L5 and 2mm thick Glass moldblown bottle body, blue Glass moldblown figural flask body, blue Stoneware salt glazed sherds Redware lead glazed sherds Stoneware slip glazed sherds YeUoware undecorated sherd Ironstone undecorated sherd Whiteware undecorated sherds Pearlware undecorated sherd Whiteware red transfer printed sherd Whiteware blue shell edge decorated sherds Whiteware annular decorated sherd Table 19. Artifacts From Site 13LN353. Count 2 1 1 3 2 1 10 1 1 1 Description Limestone fragments, burned Brick fragment, soft mud, sand struck Glass flat window fragment, L75mm thick Stoneware salt glazed sherds Redware lead glazed sherds Ironstone mold decorated sherd, Provincial Blue Whiteware undecorated sherds Whiteware red sponge decorated sherd Glass moldblown bottle base, blue Glass moldblown scroll flask body, blue Table 20. Artifacts From Site 13LN354.Provenience Count Description Surface 7 Stoneware salt glazed sherds 4 Stoneware slip glazed sherds 1 Stoneware salt/slip glazed milk bowl sherd 1 Stoneware bottle base, salt glazed, imported 10 Redware lead glazed sherds 2 Redware manganese brown glazed sherds 22 Whiteware undecorated sherds 3 Pearlware undecorated sherds1 Ironstone undecorated sherd1 Ironstone mold decorated, Provincial Blue I Whiteware/Pearlware shell edge (no color) decorated sherd2 Whiteware/Pearlware blue shell edge decorated sherds I Yelloware annular decorated sherd I Yelloware undecorated sherd I Yelloware mottled brown glazed sherd I Porcelain button fragment 1 Glass, bottle lip, applied/tooled cork finish, blue 2 Glass bottle bases, blowpipe pontil marks, blue1 Glass moldblown bottle base, blue, embossed/lettered 2 Glass moldblown bottle body, blue,.embossed/lettered 7 Glass bottle body, blue 1 Glass tableware fragment, amethyst I Glass tumbler base, amethyst 1 Glass tableware fragment, emerald green 15 Glass, flat window fragments, 1=2.75, 4=2.25, 2=2.5mm, 4=1.75, 2=1.5, 1=1.25, 1=2mm thick I Brick fragment, glazed1 Limestone fragment 1 Shell, freshwater mussel I Cast iron stove part I Iron hinge fragment 1 Iron horseshoe fragment I Iron square nut1 Iron strap Provenience Surface Table 20. Artifacts From Site 13LN354. Count 7 4 1 1 10 2 22 3 1 1 1 2 1 1 1 1 1 2 1 2 7 1 1 1 15 1 1 1 1 1 1 1 1 Description Stoneware salt glazed sherds Stoneware slip glared sherds Stoneware salt/slip glazed milk bowl sherd Stoneware bottle base, salt glared, imported. Redware lead glazed sherds Redware manganese brown glazed sherds Whiteware undecorated sherds Pearl ware undecorated sherds Ironstone undecorated sherd Ironstone mold decorated, Provincial Blue WhitewarelPearlware shell edge (no color) decorated. sherd WhitewarelPearlware blue shell edge decorated sherds Yelloware annular decorated sherd Yelloware undecorated sherd Yelloware mottled brown glazed. sherd Porcelain button fragment Glass, bottle lip, applied/tooled cork fmish, blue Glass bottle bases, blowpipe pontil marks, blue Glass moldblown bottle base, blue, embossed/lettered Glass moldblown bottle body, blue,.embossed/lettered Glass bottle body, blue Glass tableware fragment, amethyst Glass tumbler base, amethyst Glass tableware fragment, emerald green Glass, flat window fragments, 1=2.75,4=2.25, 2=2.5mm, 4=1.75,2=1.5, 1=1.25, 1=2mm thick Brick fragment, glazed ' Limestone fragment Shell, freshwater mussel Cast iron stove part Iron hinge fragment Iron horseshoe fragment Iron square nut Iron strap Table 21. Artifacts From Site 13LN355. Provenience Count Description Surface 1 Brick fragment, soft mud, sand struck 1 Limestone fragment 1 Concrete fragment, crude, large aggregate 10 Glass flat window fragments, 1=2, 2=2.25, 1=2.75, 3=1.75mm 3 Glass bottle body, blue 1 Glass moldblown bottle base, blue 1 Glass pressed compote base, clear2 Redware dark brown manganese glazed sherds 2 Redware lead glazed sherds 3 Stoneware slip glazed sherds I Stoneware Bristol/Bristol glazed sherd 4 Stoneware salt glazed sherds 7 Whiteware undecorated sherds 1 Whiteware flow blue sherd 1 Whiteware floral handpainted sherd 7 Ironstone undecorated sherds, Provincial Blue Table 22. Artifacts From Site 13LN356.Provenience Count Description Surface I Plaster/Mortar fragment1 Brick fragment, soft mud, water struck, adhering mortar 6 Glass flat window fragments, 4=1.5, 1=1.75, 1=2.25mm 1 Iron wire nail fragment 1 Redware lead glazed sherd 1 Whiteware undecorated sherd Table 23. Artifacts From Site 13LN357.Provenience Count Description Surface 7 Pearlware/Whiteware undecorated sherds 1 Pearlware/Whiteware mold decorated sherd 1 Glass melted fragment, clear 1 Glass moldblown bottle neck, dark green... j; Provenience Surface Provenience Surface Provenience Surface Table 21. Artifacts From Site 13LN355. Count 1 1 1 10 3 1 1 2 2 3 1 4 7 1 1 7 Description Brick fragment, soft mud, sand struck Limestone fragment Concrete fragment, crude, large aggregate Glass flat window fragments, 1=2,2=2.25, 1=2.75, 3=1.75mm Glass bottle body, blue . Glass moldblown bottle base, blue Glass pressed compote base, clear Redware dark brown manganese glazed sherds Redware lead glazed sherds Stoneware slip glazed sherds Stoneware Bristol/Bristol glazed sherd Stoneware salt glazed sherds Whiteware undecorated sherds Whiteware flow blue sherd Whiteware floral handpainted sherd Ironstone undecorated sherds, Provincial Blue Table 22. Artifacts From Site 13LN356. Count 1 1 6 1 1 1 Description Plaster!Mortar fragment Brick fragment, soft mud, water struck, adhering mortar Glass flat window fragments, 4=1.5, 1=1.75, 1==2.25mm Iron wire nail fragment Redware lead glazed sherd Whiteware undecorated sherd Table 23. Artifacts From Site 13LN357. Count 7 1 1 1 Description Pearlware/Whiteware undecorated sherds Pearlware/Whiteware mold decorated sherd Glass melted fragment, clear Glass moldblown bottle neck, dark green Table 24. Artifacts From Site 13LN358.i l i, Provenience Count Description Surface 1 Slate fragment 5 Whiteware undecorated sherds 2 Ironstone mold decorated sherds (one Provincial Blue) 5 Redware unglazed sherds 4 Redware lead glazed sherds Table 25. Artifacts From Site 13LN359.Provenience Count Description Surface 2 Whiteware undecorated sherds 1 Whiteware decal decorated sherd 1 Ceramic door knob fragment 4 Ironstone undecorated sherds, Provincial Blue 2 Ironstone undecorated sherds, maker's marks1 Shell, freshwater mussel 1 Glass jar lid liner, opaque white1 Glass moldblown bottle base, blue I Glass bottle fragment, blue 1 Glass bottle body, clear..... :. ; ; " ! I jj j, i , i 1 j' Provenience Surface Provenience Surface Count 1 5 2 5 4 Table 24 . Artifacts From Site 13LN358. Description Slate fragment Whiteware undecorated sherds Ironstone mold decorated sherds (one Provincial Blue) Redware unglazed sherds Redware lead glazed sherds Table 25. Artifacts From Site 13LN359. Count 2 1 1 4 2 1 1 1 1 1 Description Whiteware undecorated sherds Whiteware decal decorated sherd Ceramic door knob fragment Ironstone undecorated sherds, Provincial Blue Ironstone undecorated sherds, maker's marks Shell, freshwater mussel Glass jar lid liner, opaque white Glass moldblown bottle base, blue Glass bottle fragment, blue Glass bottle body, clear Table 26. Artifacts From Site 13LN360.Provenience Count Description Surface 1 Terra-Cotta flowerpot base 2 Yelloware undecorated sherds 3 Stoneware Bristol/Bristol glazed sherds (one jug lip)12 Stoneware salt glazed sherds 2 Stoneware salt/slip glazed milk bowl sherds 8 Stoneware slip glazed sherds (one preserves jar lip)1 Porcelain insulator, brown glazed 1 Porcelain toy cup sherd 1 Porcelain doll's leg 1 Whiteware annular decorated sherd 1 Whiteware blue sponge decorated sherd 1 Whiteware Willow blue transfer printed sherd 2 Whiteware mold decorated sherds 1 Whiteware mold decorated handle 3 Whiteware undecorated sherds 1 Ironstone undecorated sherd, Provincial Blue I Ironstone decal decorated sherd I Porcelain decal decorated sherd 1 Porcelain luster handpainted sherd I Porcelain handpainted sherd 3 Porcelain undecorated sherds 1 Unidentified metal button cap 2 Glass marbles 2 Glass pressed tableware fragments, orange, Depression Glass 1 Glass pressed tableware fragment, It. green, Depression Glass 1 Glass pressed tableware handle, amethyst 1 Glass body fragment, cobalt blue 1 Glass jar lid liner fragment, opaque white 1 Glass bottle lip, improved tooled/cork finish, amethyst 1 Glass tumbler fragment, amethyst 2 Glass bottle body, blue I Glass bottle body, clear 1 Glass moldblown bottle body, blue 2 Glass flat window fragments, 1.75 and 2.5mm thick 1 Glass melted fragment, amethyst 1 Glass machine made jar base, aqua 1 Glass machine made jar base, clear 1 Glass machine made bottle base, green I Glass machine made milk bottle lip, amethyst 1 Glass machine made bottle lip, threaded, amethyst 1 Glass machine made bottle lip, amethyst I Glass machine made jar lip, continuous thread, aqua Provenience I. i: Surface ii !i ." .. . Ii Ii i: Table 26. Artifacts From Site 13LN360. Count 1 2 3 12 2 8 1 1 1 1 1 1 2 1 3 1 1 1 1 1 3 1 2 2 1 1 1 1 1 1 2 1 1 2 1 1 1 1 1 1 1 1 Description Terra-Cotta flowerpot base Yelloware undecorated sherds Stoneware BristollBristol glazed sherds (one jug lip) Stoneware salt glazed sherds Stoneware salt/slip glazed milk bowl sherds Stoneware slip glazed sherds (one preserves jar lip) Porcelain insulator, brown glazed Porcelain toy cup sherd Porcelain doll's leg Whiteware annular decorated sherd Whiteware blue sponge decorated sherd Whiteware Willow blue transfer printed sherd Whiteware mold decorated sherds Whiteware mold decorated handle whiteware undecorated sherds Ironstone undecorated sherd, Provincial Blue Ironstone decal decorated sherd Porcelain decal decorated sherd Porcelain luster handpainted sherd Porcelain handpainted sherd Porcelain undecorated sherds Unidentified metal button cap Glass marbles Glass pressed tableware fragments, orange, Depression Glass Glass pressed tableware fragment, It. green, Depression Glass Glass pressed tableware handle, amethyst Glass body fragment, cobalt blue Glass jar lid liner fragment, opaque white Glass bottle lip, improved tooled/cork finish, amethyst Glass tumbler fragment, amethyst Glass bottle body, blue Glass bottle body, clear Glass moldblown bottle body, blue Glass flat window fragments, 1.75 and 2.5mm thick Glass melted fragment, amethyst Glass machine made jar base, aqua Glass machine made jar base, clear Glass machine made bottle green Glass machine made milk bottle lip, amethyst Glass machine made bottle lip, threaded, amethyst Glass machine made bottle lip, amethyst Glass machine made jar lip, continuous thread, aqua Table 27. Artifacts From Site 13LN361.Provenience Count Description Surface 8 Whiteware undecorated sherds 1 Whiteware light blue transfer printed sherd 1 Whiteware flow blue sherd 2 Stoneware salt glazed sherds 1 Stoneware slip glazed sherd Table 28. Artifacts From Site 13LN362.Provenience Count Description Surface 6 Whiteware undecorated sherds 1 Whiteware blue transfer printed sherd 2 Whiteware undecorated sherds, burned 1 Redware lead glazed sherd 1 Limestone fragment, burned1 Brick fragment, soft mud Provenience !. Surface ,0 1* o I '0 Provenience SUlface ; I o i , i: Table 27. Artifacts From Site 13LN361. Count 8 1 1 2 1 Description Whiteware undecorated sherds Whiteware light blue transfer printed sherd Whiteware flow blue sherd Stoneware salt glazed sherds Stoneware slip glazed sherd Table 28. Artifacts From Site 13LN362. Count 6 1 2 1 1 1 Description Whiteware undecorated sherds Whiteware blue transfer printed sherd Whiteware undecorated sherds, burned Redware lead glazed sherd Limestone fragment, burned Brick fragment, soft mud Table 29. Artifacts From Site 13LN363.Provenience Count Description Surface Stoneware salt glazed sherds Stoneware slip glazed sherds Stoneware salt/slip glazed jug sherd Clay marble fragment Porcelain undecorated sherdsWhiteware undecorated sherds Ironstone undecorated sherds Ironstone black transfer printed sherdWhiteware dark green transfer printed sherd Whiteware base sherd, maker's markIronstone decal decorated sherd Ironstone mold decorated sherd Glass moldblown bottle body, blue, possible retouch Glass moldblown jar lip, screw thread/ground rim, blueGlass bottle/jar body, blueGlass bottle/jar body, amethyst Brick fragments Limestone fragment Iron sheet fragments Iron axe head Cast iron stove parts Iron horseshoe Iron wagon part Brick fragmentsConcrete fragmentStoneware slip glazed sherd Whiteware undecorated sherd Whiteware undecorated sherd Brick fragment Cast iron machinery partWhiteware undecorated sherd Glass, flat window fragment, 2.1mm thickPorcelain undecorated thick sherd Glass jar lip, melted, blue Stoneware slip glazed sherdsIron machine cut nails Stoneware slip glazed sherd Iron square nut Whiteware undecorated sherds ST1/0-40cm bs ST5/0-10cm bs ST5/10-20cm bs ST5/20-30cm bs ST6/0-10cm bs ST7/0-10cm bs ST7/10-20cm bs ST8/0- 10cm bs ST8/10-20cm bs ST9/10-20cm bs Table 29. Artifacts From Site 13LN363. Provenience Count Description Surface 6 Stoneware salt glazed sherds 3 Stoneware slip glazed sherds 1 Stoneware salt/slip glazed jug sherd 1 Clay marble fragment 2 Porcelain undecorated sherds 8 Whiteware undecorated sherds 3 Ironstone undecorated sherds 1 Ironstone black transfer printed sherd 1 Whiteware dark green transfer printed sherd r' ii 1 Whiteware base sherd, maker's mark i" 1 Ironstone decal decorated sherd 1 Ironstone mold decorated sherd 1 Glass moldblown bottle body, blue, possible retouch 1 Glass moldblown jar lip, sere",!, thread/ground rim, blue 2 Glass bottle/jar body, blue 1 Glass bottle/jar body, amethyst 4 Brick fragments 1 Limestone fragment 2 Iron sheet fragments 1 Iron axe head I' 5 Cast iron stove parts I Iron horseshoe 1 Iron wagon part '. j STl/O-4Ocm bs 7 Brick fragments ; i 1 Concrete fragment ST5!O-lOem bs 1 Stoneware slip glazed sherd : I' ST5/1O-2Ocm bs 1 Whiteware undecorated sherd ' i; ! ST5/20-3Ocm bs 1 White ware undecorated sherd ST6/O-1Ocm bs 1 Brick fragment I 1 Cast iron machinery part ) i' S17/O-1Ocm bs 1 Whiteware undecorated sherd 1 Glass, flat window fragment, 2.1mm thick S17/1O-20em bs 1 Porcelain undecorated thick sherd ST8/0-10em bs 1 Glass jar lip, melted, blue 2 Stoneware slip glazed sherds 2 Iron machine cut nails ST8/l0-2Ocm bs 1 Stoneware slip glazed sherd ! 1 Iron square nut ST9/1O-2Ocm bs 2 Whiteware undecorated sherds ;': \ Table 30. Artifacts From Site 13LN364.Provenience Count Description Surface ST1/0-30cm bs ST3/20cm bs ST6/0-10cm bs ST6/10-20cm bs ST7/0-10cm bs ST7/20-30cm bs ST9/0-10cm bs ST9/10-20cm bs Brick fragmentWhiteware undecorated thick sherd Brick fragment Limestone fragment Brass ferrule Iron wire nails, 2-1/2" and 3" longIron suspender clasp Stoneware Bristol/Bristol glazed sherd Glass bottle body, brown Glass bottle body, clear Glass jar body/shoulder fragments, blue Glass bottle body, brownIron wire nail fragments Cast iron stove part Whiteware undecorated sherds Ironstone mold decorated sherd, Provincial Blue Glass body fragment, clear Glass moldblown jar lip, screw thread/ground rim, blueGlass moldblown jar lip, screw thread/grown rim, melted, blue Iron machine cut nails Glass, flat window fragment, 1.9mm thickWhiteware undecorated sherd Glass, flat window fragment, 1.9mm thick Brick fragment Iron wire nailGlass flat window fragments, 2=1.9, 1=2, 1=2.4mm thick Glass bottle/jar body, amethyst Brick fragmentIron unidentifiable nail Iron machine cut nail, 2" long Yelloware undecorated sherd Glass flat window fragments, 1=2, 3=1.9, 1=2.8mm thicki \ ! r' : i t : I' : i Provenience Surface STl/O-30cm bs ST3/2Ocmbs ST6/O-1Ocm bs ST6/1O-2Ocm bs STIfQ-1Ocm bs STI/20-3Ocm bs ST9/O-1Ocm bs ST9/l0-2Ocm bs Table 30. Artifacts From Site 13LN364. Count 1 1 1 1 1 2 1 1 1 1 5 1 2 1 2 1 1 1 1 2 1 1 1 1 1 4 1 1 1 I 1 5 Description Brick fragment Whiteware undecorated thick sherd Brick fragment Limestone fragment Brass ferrule Iron wire nails, 2-1/2" and 3" long Iron suspender clasp Stoneware BristoVBristol glazed sherd Glass bottle body, brown Glass bottle body, clear Glass jar body/shoulder fragments, blue Glass bottle body, brown Iron wire nail fragments Cast iron stove part Whiteware undecorated sherds Ironstone mold decorated sherd, Provincial Blue Glass body fragment, clear Glass moldblown jar lip, screw thread/ground rim, blue Glass moldblown jar lip, screw thread/grown rim, melted, blue Iron machine cut nails Glass, flat window fragment, 1.9mm thick Whiteware undecorated sherd Glass, flat window fragment, 1.9mm thick Brick fragment Iron wire nail Glass flat window fragments, 2=1.9, 1=2, 1=2.4mm thick Glass bottle/jar body, amethyst Brick fragment Iron unidentifiable nail Iron machine cut nail, 2" long Yelloware undecorated sherd Glass flat window fragments, 1=2, 3=1.9, 1=2.8mm thick .....!Table 31. Artifacts From Site 13LN365.Provenience Count Description Surface 2 Whiteware undecorated sherds 4 Stoneware salt glazed sherds 3 Stoneware slip glazed sherds1 Limestone fragment, burned 1 Brick fragment, soft mud 3 Glass flat window fragments, 1.75 and 2.25mm thick 4 Glass melted fragments, blue 1 Glass tumbler rim, amethyst 1 Glass bottle body, amethyst Table 32. Artifacts From Site 13LN366.Provenience Count Description Surface 1 Brick fragment, soft mud 1 Stoneware salt glazed handle 1 Whiteware undecorated sherd 1 Glass tableware fragment, amethyst Table 33. Artifacts From Site 13LN367.Provenience Count Description Surface 3 Whiteware blue sponge decorated sherds 1 Whiteware red sponge decorated sherd 1 Whiteware light blue transfer printed sherd 2 Whiteware blue shell edge decorated sherds 2 Whiteware floral handpainted sherds 5 Whiteware undecorated sherds, one burned 1 Ironstone handpainted tealeaf decorated sherd 1 Yelloware undecorated sherd I Yelloware annular decorated sherd 4 Stoneware salt glazed sherds 1 Iron machine cut nail I Iron strap 1 Iron unidentifiable fragment I Glass bottle body, olive green, melted 1 Glass bottle base, blue I Glass bottle body, blue 2 Glass flat window fragments, 1.75 and 1.5mm thick 2 Limestone fragments, one burned i fl i i Provenience Surface Provenience Surface Provenience Surface Count 2 4 3 1 1 3 4 I 1 Count 1 1 1 1 Table 31. Artifacts From Site 13LN365. Description Whiteware undecorated sherds Stoneware salt glazed sherds Stoneware slip glazed sherds Limestone fragment, burned Brick fragment, soft mud Glass flat window fragments, 1.75 and 2.25mm thick Glass melted fragments, blue Glass tumbler rim, amethyst Glass bottle body, amethyst Table 32. Artifacts From Site 13LN366. Description Brick fragtIlept,spftmud .. Stoneware salt glazed handle Whiteware undecorated sherd Glass tableware fragment, amethyst Table 33. Artifacts From Site 13LN367. Count 3 1 1 2 2 5 1 1 1 4 1 1 1 1 1 1 2 2 Description Whiteware blue sponge decorated sherds Whiteware red sponge decorated sherd Whiteware light blue transfer printed sherd Whiteware blue shell edge decorated sherds Whiteware floral handpainted sherds Whiteware undecorated sherds, one burned Ironstone handpainted tealeaf decorated sherd Yelloware undecorated sherd Yelloware annular decorated sherd Stoneware salt glazed sherds Iron machine cut nail Iron strap Iron unidentifiable fragment Glass bottle body, olive green, melted Glass bottle base, blue Glass bottle body, blue Glass flat window fragments, 1.75 and 1.5mm thick Limestone fragments, one burned Table 34. Artifacts From Site 13LN368.Provenience Count Description Surface 1 Limestone fragment, burned 5 Brick fragments, soft mud, sand struck 12 Glass flat window fragments, 3=1.5, 4=1.75, 1=2, 2=2.25, 1=2.5mm thick 1 Glass fragment, opaque white 9 Glass fragments, melted, green and blue 13 Glass bottle/jar body, blue 3 Glass body fragments, amethyst 1 Glass moldblown bottle body, blue, embossed/lettered1 Glass bottle lip, folded finish, blue 15 Stoneware salt glazed sherds 8 Stoneware slip glazed sherds 3 Stoneware salt/slip glazed milk bowl sherds 3 Redware unglazed sherds 2 Whiteware annular decorated sherds 2 Whiteware floral handpainted sherds 2 Whiteware blue sponge decorated sherds 9 Whiteware undecorated sherds 16 Pearlware undecorated sherds 10 Ironstone undecorated sherds, Provincial Blue 4 Yelloware undecorated sherds 1 Porcelain doll's head 6 Iron machine cut nails 1 Cast iron stove part 1 Shell, freshwater mussel Table 35. Artifacts From Site 13LN369.Provenience Count Description Surface 2 Stoneware salt glazed sherds 1 Redware lead glazed sherd 1 Yelloware undecorated sherd 12 Pearlware/Whiteware undecorated sherds 3 Whiteware blue sponge decorated sherds 3 Whiteware floral handpainted sherds 6 Whiteware blue shell edge decorated sherds 2 Whiteware unidentifiable blue decorated sherds (one burned) I Ironstone undecorated sherd, maker's mark 2 Porcelain undecorated sherds 1 Porcelain decal decorated sherd 1 Glass pressed tableware fragment, amethyst1 Glass tableware, frosted clear1 Glass bottle body, blue 2 Glass flat window fragments, 1.75 and 1.5mm thick 2 Limestone fragments, burned I Iron unidentifiable fragment Provenience Surface ( ' .. , \ . P j Provenience Surface Table 34. Artifacts From Site 13LN368. Count 1 5 12 1 9 13 3 1 1 15 8 3 3 2 2 2 9 16 10 4 1 6 1 1 Description Limestone fragment, burned Brick fragments, soft mud, sand struck Glass flat window fragments, 3=1.5, 4=1.75, 1=2, 2=2.25, 1=2.5mm thick Glass fragment, opaque white Glass fragments, melted, green and blue Glass bottleljar body, blue Glass body fragments, amethyst Glass moldblown bottle body, blue, embossed/lettered Glass bottle lip. folded finish, blue Stoneware salt glazed sherds Stoneware slip glazed sherds Stoneware salt/slip glazed milk: bowl sherds Redware unglazed sherds Whiteware annular decorated sherds Whiteware floral handpainted sherds Whiteware blue sponge decorated sherds Whiteware undecorated sherds Pearlware undecorated sherds Ironstone undecorated sherds, Provincial Blue Yelloware undecorated sherds Porcelain doll's head Iron machine cut nails Cast iron stove part Shell, freshwater mussel Table 35. Artifacts From Site 13LN369. Count 2 1 1 12 3 3 6 2 1 2 1 1 1 1 2 2 1 Description Stoneware salt glazed sherds Redware lead glazed sherd Yelloware undecorated sherd Pearl ware/Whiteware undecorated sherds Whiteware blue sponge decorated sherds Whiteware floral handpainted sherds Whiteware blue shell edge decorated sherds Whiteware unidentifiable blue decorated sherds (one burned) Ironstone undecorated sherd, maker's mark Porcelain undecorated sherds Porcelain decal decorated sherd Glass pressed tableware fragment, amethyst Glass tableware, frosted clear Glass bottle body, blue Glass flat window fragments, 1.75 and 1.5mm thick Limestone fragments, burned Iron unidentifiable fragment Table 36. Artifacts From Site 13LN370.Provenience Count Description Surface 9 Chert flakes 2 Limestone fragments, one burned 2 Iron machine cut nails 1 Iron buckle frame 1 Iron bar 3 Cast iron vessel body fragments 1 Iron handwrought door latch 14 Glass flat window fragments, 3=1.25, 4=1.5, 5=1.75, 2=21 Glass fragment, opaque dark blue1 Glass pressed Lacy Pattern tableware, clear 5 Glass moldblown bottle body, blue 2 Porcelain buttons I Brick fragment, soft mud 4 Redware manganese brown glazed sherds 15 Redware lead glazed sherds 23 Stoneware salt glazed sherds 3 Ironstone undecorated sherds 1 Yelloware undecorated sherds 3 Whiteware undecorated sherds 2 Whiteware undecorated sherds, burned 14 Pearlware undecorated sherds 6 Pearlware/Whiteware floral handpainted sherds 17 Pearlware/Whiteware sponge decorated sherds 1 Pearlware/Whiteware flow blue transfer printed sherd 5 Pearlware/Whiteware Mocha decorated sherds 7 Pearlware/Whiteware blue shell edge decorated sherds I Pearlware/Whiteware purple transfer printed sherd 1 Pearlware/Whiteware red transfer printed sherd 2 Pearlware/Whiteware Old Blue transfer printed sherds 2 Pearlware/Whiteware blue transfer printed sherds 2 Pearlware/Whiteware green transfer printed sherds 1 Pearlware/Whiteware Willow blue transfer printed sherd 1 Pearlware/Whiteware unidentifiable blue decorated sherd 2 Kaolin pipe bowl fragments Provenience Surface Table 36. Artifacts From Site 13LN370. Count 9 2 2 1 1 3 1 14 1 1 5 2 1 4 15 23 3 1 3 2 14 6 17 1 5 7 1 1 2 2 2 1 1 2 Description Chert flakes Limestone fragments, one burned Iron machine cut nails Iron buckle frame Iron bar Cast iron vessel body fragments Iron handwrought door latch Glass flat window fragments, 3=1.25, 4=1.5, 5=1.75, 2=2 Glass fragment, opaque dark blue Glass pressed Lacy Pattern tableware, clear Glass moldblown bottle body. blue Porcelain buttons Brick fragment, soft mud Red.ware manganese brown glazed sherds Redware lead glazed sherds Stoneware salt glazed sherds Ironstone undecorated sherds Yelloware undecorated. sherds Whiteware undecorated sherds Whiteware undecorated sherds, burned Pearlware undecorated sherds PearlwarelWhiteware floral handpainted sherds Pearlware/Whiteware sponge decorated sherds Pearlware/Whiteware flow blue transfer printed sherd PearlwarelWhiteware Mocha decorated sherds PearlwarelWhiteware blue shell edge decorated sherds Pearlware/Whiteware purple transfer printed sherd PearlwarelWhiteware red transfer printed sherd PearlwarelWhiteware Old Blue transfer printed sherds Pearlware/Whiteware blue transfer printed sherds PearlwarelWhiteware green transfer printed sherds Pearl warelWhiteware Willow blue transfer printed sherd PearlwarelWhitewareunidentifiable blue decorated. sherd Kaolin pipe bowl fragments Table 37. Artifacts From Site 13LN373.Provenience Count Description Surface 2 Glass flat window fragments, 2.25 and 2.75mm thick 7 Stoneware Bristol/Bristol glazed sherds 6 Stoneware slip glazed sherds 2 Stoneware salt glazed sherds 1 Terra-Cotta sherd 1 Porcelain doll's arm/hand 2 Porcelain mold decorated sherds 3 Whiteware mold decorated sherds 12 Whiteware undecorated sherds, several thick 2 Glass jar lid liner fragments, opaque white 2 Glass pressed tableware fragments, opaque white1 Glass bottle body, brown 2 Glass flat window fragments, 1 and 1.25mm thick 1 Glass melted fragment2 Glass melted fragments, clear and blue 4 Glass bottle body, blue 2 Glass bottle body, blue J Provenience Smface Table 37. Artifacts From Site 13LN373. Count 2 7 6 2 1 1 2 3 12 2 2 1 2 1 2 4 2 Description Glass flat window fragments, 2.25 and 2.75mm thick Stoneware Bristo1/Bristol glazed sherds Stoneware slip glazed sherds Stoneware salt glazed sherds Terra-Cotta sherd Porcelain doll's annIhand Porcelain mold decorated sherds Whiteware mold decorated sherds Whiteware undecorated sherds, several thick Glass jar lid liner fragments, opaque white Glass pressed tableware fragments. opaque white Glass bottle body, brown Glass flat window fragments, 1 and 1.25mm thick Glass melted fragment . Glass melted fragments, clear and blue Glass bottle body, blue Glass bottle body, blue Table 38. Artifacts From Site 13LN375.Provenience Count Description Surface 2 Brick fragments, soft mud, sand struck, one glazed, one has impressed insert (brick "frog")14 Whiteware undecorated sherds 3 Pearlware undecorated sherds 1 Ironstone undecorated sherd, Provincial Blue1 Ironstone mold decorated sherd I Whiteware mold decorated sherd 1 Pearlware light blue transfer printed sherd1 Whiteware sherd, burned 1 Whiteware annular decorated sherd 1 Whiteware floral handpainted sherd I Porcelain overglaze handpainted sherd 1 Stoneware salt/slip glazed milk bowl sherd 1 Stoneware salt glazed/cobalt blue handpainted sherd 2 Stoneware slip glazed sherds 10 Stoneware salt glazed sherds 9 Redware lead glazed sherds 2 Glass flat window fragments, 1 and 1.25mm thick I Glass melted fragment 1 Glass pressed tumbler base, amethyst 1 Glass pressed bowl rim, amethyst 1 Glass pressed tableware body, amethyst 1 Glass bottle base, kick-up, olive green 1 Glass bottle base, kick-up/pontil mark, blue 2 Glass bottle body, blue1 Glass bottle body, brown1 Brass band fragment 1 Cast iron stove part", i \ , i i I Table 38. Artifacts From Site 13LN375. Provenience Count Surface 2 14 3 1 1 1 1 1 1 1 1 1 1 2 10 9 2 1 1 1 1 1 1 2 1 1 1 Description Brick fragments, soft mud, sand struck, one glazed, one has impressed insert (brick "frog") Whiteware undecorated sherds Pearlware undecorated sherds Ironstone undecorated sherd, Provincial Blue Ironstone mold decorated sherd Whiteware mold decorated sherd Pearlware light blue transfer printed sherd Whiteware sherd, burned Whiteware annular decorated sherd Whiteware floral handpainted sherd Porcelain overglaze handpainted sherd Stoneware salt/slip glazed milk bowl sherd Stoneware salt glazed/cobalt blue handpainted sherd Stoneware slip glazed sherds Stoneware salt glazed sherds Redware lead glazed sherds Glass flat window fragments, 1 and 1.25mm thick Glass melted fragment Glass pressed tumbler base, amethyst Glass pressed bowl rim, amethyst Glass pressed tableware body, amethyst Glass bottle base, kick-up, olive green Glass bottle base, kick-up/pontil mark, blue Glass bottle body, blue Glass bottle body, brown Brass band fragment Cast iron stove part Table 39. Artifacts From Site 13LN376.Provenience Count Description Surface 5 1 6 2 1 1 1 1 13 I 1 2 2 5 7 10 3 1 1 1 1 1 1 3 2 1 I 1 1 7 4 2 1 9 12 1 1 1 18 11 2 1 1 1 2 2 Brick fragments, stiff mud and soft mud manufacture Limestone fragment Shell, freshwater mussel Slate fragments Iron weight with lead cap Iron stripIron button Brass grommet?Glass flat window fragments, 2=2.75, 8=2.25, 1=9, 1=5, 1=3mm thick Glass marble Glass jar lid liner fragments, opaque whiteGlass bottle body, brown Glass bottle body, clear Glass bottle body, amethyst Glass bottle body, blue Glass machine made jar bases, aqua Glass machine made bottle base, amethyst Glass moldblown bottle base, brown Glass kerosene chimney fragment, clear Glass bottle body, melted, amethystGlass bottle body, brown, embossed/lettered Glass bottle body, blue, embossed/lettered Glass pressed tableware body, amethyst Glass pressed tableware bases, amethyst Glass pressed tableware stopper, amethystYelloware undecorated sherd Yelloware mottled brown glazed sherd Terra-Cotta sherd Stoneware Bristol/Bristol glazed sherds Stoneware Bristol/Albany slip glazed sherds Stoneware salt/slip glazed milk bowl sherds Stoneware salt glazed/cobalt blue handpainted sherd Stoneware salt glazed sherds Stoneware slip glazed sherds Porcelain doll part Porcelain decal decorated sherd Porcelain undecorated sherd Whiteware undecorated sherds Ironstone undecorated sherds, Provincial Blue Whiteware handpainted sherds Whiteware red transfer printed sherd Whiteware blue transfer printed maker's marked sherd Whiteware mold decorated sherd Whiteware gold decal decorated sherds Whiteware decal decorated sherds Provenience Surface Count 5 1 6 2 1 1 1 1 13 1 2 2 5 7 10 3 1 1 1 1 1 1 3 2 1 1 1 1 7 4 2 1 9 12 1 1 1 18 11 2 1 1 1 2 2 Table 39. Artifacts From Site 13LN376. Description Brick fragments, stiff mud and soft mud manufacture Limestone fragment Shell, freshwater mussel Slate fragments Iron weight with lead cap Iron strip Iron button Brass grommet? Glass flat window fragments, 2=2.75, 8=2.25, 1=9, 1=5, 1=3mmthick Glass marble Glass jar lid liner fragments, opaque white Glass bottle body. brown Glass bottle body, clear Glass bottle body, amethyst Glass bottle body, blue Glass machine made jar bases, aqua Glass machine made bottle base, amethyst Glass moldblown bottle base, brown Glass kerosene chimney fragment, clear Glass bottle body, melted, amethyst Glass bottle body, brown, embossedllettered Glass bottle body. blue, embossed/lettered Glass pressed tableware body. amethyst Glass pressed tableware bases, amethyst Glass pressed tableware stopper, amethyst Yelloware undecorated sherd Yelloware mottled brown glazed sherd Terra-Cotta sherd Stoneware Bristo1!Bristol glazed sherds Stoneware Bristo1/Albany slip glazed sherds Stoneware salt/slip glazed milk bowl sherds Stoneware salt glazed/cobalt blue handpainted sherd Stoneware salt glazed sherds Stoneware slip glazed. sherds Porcelain doll part Porcelain decal decorated sherd Porcelain undecorated sherd Whiteware undecorated sherds Ironstone undecorated sherds, Provincial Blue Whiteware handpainted sherds Whiteware red transfer printed sherd Whiteware blue transfer printed maker's marked sherd Whiteware mold decorated sherd Whiteware gold decal decorated sherds Whiteware decal decorated sherds Table 40. Artifacts From Site 13LN377.Provenience Count Description Surface 3 Glass flat window fragments, 1=1.25 and 2=1.75mm thick 1 Metal unidentifiable fragment 1 Whiteware undecorated sherd 1 Bone? fragment 1 Chert flake Table 41. Artifacts From Site 13LN378.Provenience Count Description Surface 4 Chert flakes 1 Chert fragment 1 Chert point base, stemmed, ground base 1 Glass bottle lip/neck, applied tooled/cork finish, brown 2 Glass melted fragments, blue 3 Glass kerosene chimney fragments, amethyst 6 Glass body, amethyst 3 Glass bottle body, blue 3 Glass moldblown bottle bases, blue 10 Glass flat window fragments, 2=1.75, 1=2.75, 3=2.5, 4=2mm thick 4 Stoneware salt glazed sherds 4 Stoneware slip glazed sherds 1 Redware lead glazed sherd 2 Yelloware undecorated sherds 1 Yelloware annular decorated sherd 8 Ironstone undecorated sherds, Provincial Blue 1 Ironstone mold decorated sherd, Provincial Blue 17 Whiteware undecorated sherds, two burned I Whiteware handpainted rimband sherd I Whiteware beaded rim sherd 1 Whiteware blue shell edge decorated sherd 1 Whiteware late blue transfer printed sherd 1 Whiteware mulberry flow transfer printed sherd 1 Whiteware decal decorated sherd I Porcelain undecorated sherd 1 Porcelain door knob I Porcelain decal decorated sherd 3 Limestone fragments, burned I Brick fragment I i , : ! . I I 1 1 Provenience Count 'Surface 3 1 1 1 1 Table 40. Artifacts From Site 13LN377. DescrIption Glass flat window fragments. 1=1.25 and 2=1.75mm thick Metal unidentifiable fragment Whiteware undecorated sherd Bone? fragment Chert flake Table 41. Artifacts From Site 13LN378. Provenience Count Surface 4 1 1 1 2 3 6 3 3 10 4 4 1 2 1 8 1 17 1 1 1 1 1 1 1 1 1 3 1 Description ' Chert flakes Chert fragment Chert point base, stemmed, ground base Glass bottle lip/neck, applied tooled/cork finish, brown Glass melted fragments, blue Glass kerosene chimney fragments, amethyst Glass body, amethyst Glass bottle body, blue Glass moldblown bottle bases, blue Glass flat window fragments, 2=1.75, 1=2.75, 3=2.5, 4=2mmthick Stoneware salt glazed sherds Stoneware slip glazed sherds Redware lead glazed sherd Yelloware undecorated sherds Yellow are annular decorated sherd Ironstone undecorated sherds, Provincial Blue Ironstone mold decorated sherd, Provincial Blue Whiteware undecorated sherds, two burned Whiteware handpainted rimband sherd Whiteware beaded rim sherd Whiteware blue shell edge decorated sherd Whiteware late blue transfer printed sherd Whiteware mulberry flow transfer printed sherd Whiteware decal decorated sherd Porcelain undecorated sherd Porcelain door knob Porcelain decal decorated sherd Limestone fragments, burned Brick fragment APPENDIX CU PROJECT PUBLICITY AND REVIEW CORRESPONDENCE ,.). ! ' i :" 1 , j. * \' 1 . 1 j .! , ! . i ! . . , : ; : :i U , ; J ) 1 1 } , J . I I ApPENDIX C: PROJECT PUBLICITY AND REVIEW CORRESPONDENCE LEAH D. ROGERS 217 NW 5TH ST.MT. VERNON, IA 52314 319-895-8330 September 18, 1992 TO: Property owners/tenants in project area RE: Cultural Resources Survey for Certified Local Government Grant The Linn County Historic Preservation Commission has received a grant from the State Historical Society of Iowa to conduct an intensive survey in Fayette Township to record histOric archaeological and architectural properties. The purpose is to compile a record of the existing cultural resources and to determine if any of these*properties may be eligible for listing on the National Register of Historic Places. The goal is to ultimately survey the entire county so that the Commission will know what the county's important resources are and how best to preserve and-protect those resources. This does not involve-any land or property acquisition. It is simply an information gathering project to aid historic preservation efforts in the county. No property can be listed on the National Register without the owner's permission. There are, however, few restrictions, if any, that go along with a National Register listing and a number of tax. and grant funding incentives of which the property 6wner can'take advantage. Leah and Clark Rogers., Historic Preservation Consultants, are* conducting the archaeological survey portion of this project, while Will Page of Des Moines is-conducting the architectural survey.. We appreciate your cooperatioh in allowing access to your property for this survey. There will be no damage to either crops or property.The consultant is responsible for any injuries incurred during.the course of this survey.If you have any questions, please contact the project consultant Leah Rogers at the above address and phone number, or contact the Linn County Historic Preservation Commission Liaison, Steve Mdshier at 398-4082, General Services, Linn County Administrative Building, 930 First St. SW, Cedar Rapids, IA 52404-2161. Sincerely, Leah D. Rogers LEAH D. ROGERS 217 NW 5TH ST. MT. VERNON, IA 52314 September 18, 1992 319-895-8330 i TO: Property owners/tenants in project area I* **0, j .. i I i' t i , . i i I. i RE: Cultural Resources Survey for Certified Local Government Grant The Linn County Historic Preservation Commission has received a grant from the State Historical Society of Iowa to conduct an intensive survey in Fayette township to record histbric archaeological and architectural properties. The purpose is'to compile a record of the existing cultural resour6es and to determine i1 any of these properties may be eligible for listing on the National Register of Historic Places. The goal.is to ultimately survey the entire county so that the Commission Wil+ know what the county's important resources are and how best to preserve those res6urces. This does not involve 'any land or property acquisition. It is an information gathering project to aid historic efforts in the county. No propetty can be listed on the Natiorial Register without the owner's permission. There are, however, few if that go along with a National Register listing and a number of tax and grant funding incentives' of which the property dwner can take advantage. Leah and Clark Historic Consultants, are conducting the archaeological survey portion .of this proj ect, while Will Page of Des Moines is*conducting the architectural survey. We appreciate your cooperation in allowing access to your property for this survey. There will be no damage to either crops or property. The consultant is responsible for any injuries incurred during the course of this If you have any questions, please contac.t the proj ect consultant Leah Rogers at the above address and phone number, or contact 'the Linn County Historic Preservation Commission Liaison, Steve M6shier at 398-4082, General Services, Linn County Administrative 930 First St., SW, Cedar IA 52404-2i6l. Sincerely, Leah D. Rogers -By Toým Fruehling Gazette ~tWf writer History buffs who don't mind getting their hands W As: patofa: rottosrey; stud ofu t or b .sty .ar 'e .L ... " " 'Q* .- :!0 a : historic architecturaf and ar- countyw chaeologi6al -sites, throughout. the couinty, volu~te`&rs will be-gin sceuring Fay.te Ti.h ns.iy ., arud_-Palo_1his`1iohth._They o q historic' ignifi eanc te&-. ..... * : arobecti .puroejectR te('"se uers.an- .lslotric ýprEsevap n o ganswilbesogt u sLiant C fom .uny'shentagV.i:o uner,'ep s;tlneddt sad Faet onhpnrh d uho'h il ork unýwest of Cedar Rapis wascho der' thesupervisionofhr an.d sen--for ,the iii styb her husband fellow archatolof cause iofers. a wealth. of .gist, ClarkRgr histoi fcal nrhiteu raerte an'coirntu"Thme ,area artound ,the ýCehar. dire~to'r of g~al ser ics River -hais a nun~ber of pr hiJs.yth&ifrtiteie

y toric sites," Rotger o said,'And..

a'..d.wing a hi.sto'rical mp,.bthere were steamboat landings, Linn C.ounty. He feels it '.11býIndian sites, an early grist mill valuable strictly from an edu".and a stone quarry. There are catiorial standpoint.. Mor~eover, a wide variety of resources." it will- be used to guide' futur6 The survey will1 start. 8Satuý- development and nmay,. e'ven day an.d Sunda.y 'nd Will con-- lead tol, mvre tourism.tinue over at'least thý 'next Onge the survey is coMpletL weeen.M e.outings wllat Cbe .-aed, the county will seek desig-held if the weathera permits, nations, ftom thevstan d ad* en-.or I her husbfromth fsllow.ahcd5b na andi. th&' project .,will, p k .e' .- I;. .againe"h thi::.ofe spris'.tional gstr "ihf -histg ri't~~~~ric~ .ie ," " " ..pi.....plaes, as well -as wcompigingit Rogersi rsu ..th own county registry;.. thee'rete oa in !nWe're talking abou fe modelst ore iituar. oTfdhereaec non stanobl t M resources" r eso the fr ue Rot w&~ai: be used tonly weuayfwe Thpe srved y.cwfak -seva.l Syaur-s eeomn, idmy aIt is, fundedw6 sOltiz'o n- goet":re e toursm ' at stk&e~nd fedo prograns e hat scont ll seed Ten ogst.t Said.rhs .fime y can tbunty std; h _"isto prier 'iiir~ect._ W ryriserven a l .-. ,,.. ie.u -.oh i %6ftti m~tanc~guyyo':: can*out.Po elfr e fupi et.s t y qf ti * .-.......... f ...-, S ..-, ....... fd ., ..n nre e a e .e o r e ,..r.sEe..ýei .,og, y ,ra y snaps~ '0ti~ o~'r K 1o ga,$EPA. [: i 1: linrtounty: '\.' '; , . "; * , 'i : '. .' ,-.:..' ';: .:

• . _.BY Tom F:ruehling Gazeite staff writer History. buffs who don't mind -gettingth,elr.Jl?:pd,S.:,4.!r!:Y or blisters on.their Jeetare*be-. . iTIg' re'cruited:'to"Mi)ri"on

'an Leah' ambitious .projecLt.o.preserve . Rod9e: rs. To Je'ad study of county Linn County's*heritage.: ... * . .' As 'part of an' effort to 'survey , historiC and throughout the coUnty, volunteers will be-. '" gin sCQuring J!'!iyetfe Tpwnship' .',: . -.... tl:lis* .. *: . "The'area .' director' Riverh'as a . *,\:;*:says.i.thiEi'is,:

• toric* sites," ' .. at,dra\.Ving a there steamboat landings; Linn County. He feels it Indian sites, an early grist mill valuable strictly from an edu c' and a stone quarry. There are cafiorial standpoint

... Mbreover; a wide variety of resources." it will' be used to guide' future The Satui-development. and niaY*.evel1 . day an,dSunda,y'andwnl leadto)nore ' .. ,' ; tinue over at* least the next the sUrvey is complete weekend.*More outings will be ed, th,e county will seek held n:. the nations. from ,the . and ..

,' tional";,register'

.. again ',th: .. ;-;:. places" as .weIhs . compi;lilig\ its Rogers sald*the resilltsof.the '. ownCQunty registrY ;:;':,A .. (pilotittir,oject .' . . .. , . . .. ' aboUt: .., model :for '." . rest or"the . ,. expe8ted . . it ;;i,s' .... U\.A."" ... *.*J".v.,.w..y. ARCHAEOLOGICAL SURVEY NOTICE Archaeological surveys will be conducted on two consecutive weekends in November in Fayette Township for the Linn County Certified Local Government Phase 11 grant project. Volunteers are needed to help look for and record historic archaeological sites in this township. The surveys will be conducted by Project Director, Leah D. Rogers, on November 7 and 8 and 14 and 15, 1992. Additional survey days may be scheduled as weather conditions permit. We will meet at the Linn County Administrative Building parking lot at 930 First St. SW in Cedar Rapids at 1:00 p.m. all four days.We will then car-pool to the project area and spend the afternoons doing survey. Be sure to dress appropriately for the weather. Survey conditionswill include wooded areas and harvested fields, so come prepared to do some walking. All equipment will be provided; all you need is an interest in history! If, you have any questions, please call Leah Rogers at (319) 895-8330.I ARCHAEOLOGICAL SURVEY NOTICE Archaeological surveys will be conducted on two consecutive weekends in November in Fayette Township for the Linn County Certified Local Government Phase II grant project. Volunteers are needed to help look for and record historic archaeological sites in this township. The surveys will be conducted by Project Director, Leah D. Rogers, on November 7 and 8 and 14 and 15, 1992. Additional survey days may be scheduled as weather conditions permit. We will, meet at the Linn County Administrative Building parking lot at 930 First SW in Cedar Rapids at 1:00 p.m. all four days. We will then car-pool to the project area and spend the afternoons doing survey. Be sure to dress appropriately for the weather. Survey conditions t1ill include "70oded areas a'1d harvested fields; so come prepared t.o do some walking. All equipment vlill be provided; all you need is an interest in history! If you have any questions, please call Leah Rogers at (319) 895-8330. PALO/FAYETTE TOWNSHIP ARCHITECTURAL HISTORY SURVEY NOTICE Architectural history surveys will be conducted in January in the town of Palo for the Linn County Certified Local Government Phase II grant project. Volunteers are needed to help look for and record historic buildings in this town and the surrounding township. The surveys will be conducted by Architectural Historian, Will C. Page, and Project Director, Leah D. Rogers, on January 14-17, 1992. We will begin with a public meeting on January 14th at 7 p.m. Palo to meet with local residents and explain the survey process. We will congregate at the city park north of the school and then meet in a local building (probably the school). The actual survey will begin at 9 a.m. on January 15th in the commercial district of Palo and will continue throughout the day. Subsequent surveys will begin at 9 a.m. on January 16th (Saturday) and 12 p.m. on January 17th (Sunday) and meeting in the city park in Palo. We will be recording commercial, public, and residential buildings in Palo and farmsteads in Fayette Township. All equipment and instructions will be provided.Everyone is invited to attend one or all of the sessions. If you have any questions, please call Leah Rogers at (319) 895-8330."', j . ) j ( i PALO/FAYETTE TOWNSHIP ARCHITECTURAL HISTORY SURVEY NOTICE Architectural history surveys will be conducted in January in the town of Palo for the Linn County Certified Local Government Phase II grant project. VolUnteers are nee.ded to help look for and record historic buildings in this town and the surrounding township. The surveys will be conducted by Architectural Historian, Will C. Page, and Project Director, Leah D. Rogers, on January 14-17, 1992. We will begin with a public meeting on January 14th at 7 p.m. Palo to meet with local residents and explain the survey process. will congregate at the city park north of the school and then meet in a local building (probably the school). The actual survey will begin at 9 a.m. on January 15th in the commercial district of Palo and will continue throughout the day. Subsequent surveys will begin at 9 o a.m. on January 16th (Saturday) and 12 p.m. on January 17th (Sunday)" and meeting in the city park in Palo. We will be recording commercial, public, and residential buildings in Palo and farmsteads in Fayette Township. All equipment and instructions will be provided. Everyone is invited to attend one or all of the sessions. If you have any questions, please call Leah Rogers at (319) 895-8330. LINN COUNTY HISTORICAL MUSEUM 101 EIGHTH AVENUE SE CEDAR RAPIDS, IOWA 52401-2022

TELEPHONE (319) 362-1501 BOARD OF DIRECTORS Connie Johnston 1 Dr Richaid Thomas I i Prcsidril Michelle Fischer Secretrlrr Michael S. Bohning Laura Deer J)an Fisher Cathie Frenzen Bruce Hamous Edward Horak. Jr Dr. Glenn JanusMarjorie Kinkead Ann Koontz" Ouentin Post Winifred ShuteleworthDr. Richard Thomas Marilyn Walsh Phyllis Wenner-mark Paul Zenisek BOARD OF TRUSTEESAnn Koontz Choian/ru Edward Horak, Jr.i 'cc. Chor1a0,Cl'rk Lord Acton Harold M, Becker Larry H. Christy Edward H, "Ted" Healey Connie Johnston Edward R. Kuba. Sr.Bill Munsell William F Olinger Senator Paul Pare Nancy Seifert Kay Shiw-Hcnry Winifred Shuttleiwrth February 15, 1993 Leah Rogers Historic Preservation Consultant 217 NW 5th Street Mount Vernon, IA 52314

Dear Leah:

.On behalf of the Board of Directors and Board of Trustees of the Linn County Historical Society, I would like to thank you for your presentation during the "History for Lunch" program today. It was good to hear about the Linn County Historical Project and the val-uable cultural. resources that we have nearby. I especially enjoyed.seeing the slides of the farm sites that were documented in .the 1889 Linn County history'and their appearance.at the present time.It shows an amazing continuity, but also the importance of pre-serving these valuable sites.Again, thank you very much for your presentation. If we can be of help to you in the future, please do not hesitate to call on us.Cordially, William R. Kreuger Executive Director cs Cynthia Smirh Scrrg LINN COUNTY HISTORlCAL MUSEUM r 101 EIGHTH AVENUE SE CEDAR RAPIDS, IOWA 52401-2022 TELEPHONE (319) 362-1501 BOAltD OF DIRECTORS ConnlC Johnston PrcSfdtfll Dr. Richard Thomas \ju prcsiiclII ", Michelle fischer I: SUrClttr.l' i Michael S. Bohning Tn(lsu,",r Laura Den i .J }d.nt fisher Cathie Frenzen Bruce Hamous ., I::" Edward Horak. Jr. Ii j; Dr. Glenn Janus Milrjorie Kinkead i .\: Ann Koont;r" Quentin Post , Winifred ShutTl.worth i Dr. Richard Thom .. 'to 'j ! ! i. i. Marilyn Walsh Phyllis \Venner-mark Paul BOARD OF TRUSTEES Ann Koontz elllli/1Il11I1 Edw.,d Ijorak. Jr. \ jcc*CI'(1it, r ltwICI .. *,/.; lord Ac;ton Harold Beck., tarry H. Christy Edward H. uTed l* Hcale)' Connie Johnston Edward R. Kub ** Sr. Bill Mun<<11 Willi,,,, F. Olinger Paul Pare Nancy Seifert Kay Shive.Henry Winifred Shuttleworth Cynthia Smirh Sure uu), -I I I February 15, 1993 Leah Rogers Preservation Consultant 217 NW 5th Street Mount Vernon, IA 52314

Dear Leah:

On behalf of the Board of Directors and Board of Trustees.of the Linn County Historical Society, I would like to thank you for your presentation during the "History for Lunch" program today. It was good to hear about the Linn County Historical Project and the uable cultural. resources that we have nearby. I especially enjoyed seeing the slides of the farm sites that were documented in .the 1889 Linn County history'and their appearance at the present time. It shows an amazing continuity, but also the importance of serving these valuable sites. Again, thank you very much for your presentation. If we can be of help to you in the future, please do not hesitate to calion us. Cordially, . William R. Kreuger Executive Director cs HISTORICAL SURVEY OF PALO AND FAYETTE TOWNSHIP Historic Buildings Survey: March 4 (Thursday)-- 7:00 p.m. Meeting to discuss project results to date and answer any questions about the project and National Register nominations. We will meet a the Community Center in Palo.March 5 (Friday)-- 1:00-4:00 p.m. Architectural historian, Will Page will give a walking tour of Palo and discuss how to record and evaluate historic buildings. Meet at Palo Community Center parking lot.March 6 (Saturday)-- 9:00 a.m.-4:00 p.m. Will Page will conduct a survey of farmsteads in! Fayette Township. Meet at Palo Community Center parking lot.Archaeological Sites Survey in Fayette Township (Meet at Palo Community Center Parking Lot): March 13 (Saturday)-- 9:00 a.m.-4:00 p.m.March 14 (Sunday)-- 12:30-4:00 p.m.March 21 (Sundayi-- 12:30-4:00 p.m.March 22 (Monday)-- 9:00 a.m.-4:00 p.m.Archaeological Labwork (artifact washing, labeling and identification): March 27 (Saturday)-- 1:00-4:00 p.m. at the Linn County Historical Museum in Cedar Rapids.Everyone is invited to attend any or all of these activities. If you need further information, please call Project Director, Leah Rogers at 895-8330.ADDITIONAL FIELD DAY Because of the bad weather recently, we will conduct one more field day in Fayette Township this month.We will meet at 12:30 on Sunday March 28th and spend the afternoon looking for archaeological sites. Be sure to wear your boots! Once again, however, this will depend on the weather.Hope to see you there.Leah Rogers 895-8330 i 1. i HISTORICAL SURVEY OF PALO AND FAYETTE TOWNSHIP Historic Buildings Survey: March 4 (Thursday)-- 7:00 p.m. Heeting to discuss project results to date and anS,.ler any questions about the project and < National Register nominations. We will meet a the Community Center in Palo. March 5 (Friday)-- 1:00-4:00 p.m. Architectural historian, Will Page will give a walking tour of Palo and discuss how to record and evaluate historic buildings. Meet at Palo Community Center parking lot. March 6 (Saturday)-- 9:00 a.m.-4:00 p.m. Will Page will conduct a . survey of farmsteads in: Fayette Township. Meet at Palo Community Center parking lot. Archaeological Sites Survey in Fayette Township (Meet at Palo Community Center Parking Lot): March 13 (Saturday)-- 9:00 a.m.-4:00 p.m. March 14 (Sunday)-- 12:30-4:00 p.m. March 21 ,(Sunday)-- 12:30-4:00 p.m. March 22 (Monday)-- 9:00 a.m.-4:00 p.m. Archaeological Labwork (artifact washing, labeling and identification): March 27 (Saturday)-- 1:00-4:00 p.m. at the Linn County Historical Museum in Cedar Rapids. Everyone is invited to attend any or all of these activities. If you need further information, please call Project Director, Leah Rogers at 895-8330. ADDITIONAL FIELD DAY B.ecause of the bad weather* recently, we will conduct one more field day in Fayette Township this month. We will meet at 12:30 on Sunday March 28th and spend the afternoon looking for archaeological sites. Be sure to wear your boots! Once again, however, this will depend on the weather. Hope to see you there. Leah Rogers 895-8330 MEMORANDUM TO: Kathy FROM: Lowell DATE: September 14, 1993

SUBJECT:

Review of history portions of draft survey report concerning most of Fayette Township, Linn County--Phase II survey project I have briefly reviewed the draft report and am pleased with both the information it contains and with the consultant's recommendations. The contents are well organized, thoughtfully presented, and delivered in a way that should prove very useful to the certified local government as its members contemplate future activities. My impression overall is that the extent of work accomplished exceeds the budgeted project costs with a considerable amount of extra consultant labor having been donated to the effort.It will be interesting to see how things work out on this phased survey strategy being pursued by the Linn County Historical Commission--an approach based on surveying parts of the county one at a time. This differs from the strategy of surveying one theme at a time of county history which mainly has been used to date elsewhere. What I read here shows high potential of yielding a variety of places with National Register potential. A few specifics follow below: 1. Page i. Abstract. I concur with Ralph's observation that the reference to the Multiple Property nomination is confusing. Ordinarily, the Multiple Property Documention Form is the vehicle used to set forth background information and to establish a comparative framework for assessing the significance and integrity of properties within the survey area. This then provides the basis for a series of individual and district nominations on National Register Registration Forms.It would also be useful to clarify whether the individual township survey results are intended to become one part of a county-wide Multiple Property Documentation assessment, with properties evaluated in their relationship to contexts of county development, or whether the intent is to prepare subsection by subsection Multiple Property Documentation evaluations which have their own contexts of local historical development. My assumption is that the evaluation of individual properties and districts is being done by weighing their characteristics in relation to the 1 ,. : j. TOg Kathy FROM: Lowell DATE: September 14, 1993

SUBJECT:

Review of history portions of draft survey report concerning most of Fayette Township, Linn County--Phase II survey project I have briefly reviewed the draft report and am pleased with both the information it contains and with the consultant's recommendations. The contents are well organized, thoughtfully presented, and delivered in a way that should prove very useful to the certified local government as its members contemplate future activities. My impression overall is that the extent of work accomplished exceeds the budgeted project costs with a considerable amount of extra consultant labor having been donated to the effort. It will be interesting to see how things work out on this phased survey strategy being pursued by the Linn County Historical commission--an approach based on surveying parts of the county one at a time. This differs from the strategy of surveying one theme at a time of county history which mainly has been used to date elsewhere. What I read here shows high potential of yielding a variety of places with National Register potential. A few specifics follow below: 1. Page i. Abstract. I concur with Ralph's observation that the reference to the Multiple Property nomination is confusing. Ordinarily, the Multiple Property Documention Form is the vehicle used to set forth background information and to establish a comparative framework for assessing the significance and integrity of properties within .the survey area. This then provides the basis for a series of individual and district nominations on National Register Registration Forms. It would also be useful to clarify whether the individual township survey results are intended to become one part of a county-wide Multiple Property Documentation assessment, with properties evaluated in their relationship to contexts of county development, or whether the intent is to prepare SUbsection by subsection Multiple Property Documentation evaluations which have their own contexts of local historical development. My assumption is that the evaluation of individual properties and districts is being done by weighing their characteristics in relation to the 2 leading themes of county rather than township history.2. Pages 2-14 through 2-17, and 3-11 through 3-15 concern the Rise of an Agricultural Economy and the kinds of places that best express the important events and patterns of that history. As the results of this survey show, there has been a great deal of change in farming areas and what remains to suggest the character of past farm development is fast passing from the scene. This underscores the importance of paying attention to the countryside, and this has ably been done here.In particular, the discovery of National Register potential in the group of farmsteads comprising the Lewis Bottoms Rural Neighborhood adds a heretofore unexplored dimension to rural analysis. Typically the only rural places found eligible for nomination based on their connections to historical events have been those associated with the settlement of ethnic groups. Now we have a rural neighborhood where owners share a common family ancestry.While the challenge here will be to show that the collection of existing buildings reflects something distinctive, important, and among the most authentic surviving expressions of such county development through conducting comparative surveys of similar neighborhoods elsewhere, the idea shows promise of tapping into an important aspect of understanding about patterns of rural life.One suggestion I would make is, given the fact that early expressions of farm development are fast disappearing, extra importance may wish to be attached to surveying, nominating, and preserving houses and barns that date to before the Civil War. One property that comes to mind here is the Railsback barn. Relatively few barns existed well into the 1870s in Iowa and this is one of a few that both date to the late 1850s and are of a substantial character when built.Not only that, it is a rare example of a Pennsylvania barn built on the Sweitzer plan with an unsupported forebay. Although its condition appears deteriorated, it seems deserving of further research as potentially meeting National Register Criteria "A", "C", or "D".The fast approaching deadlines for our comment preclude my going into further detail on the draft of this most promising study. I look forward to seeing a copy of the final report. It gives hope of becoming a model for stimulating similar efforts elsewhere. cc: Ralph Christian.. ,\ t* 2. 2 leading themes of county rather than township history. Pages 2-14 through 2-17, and 3-11 through 3-15 concern the Rise of an Agricultural Economy and the kinds of places that best express the important events and patterns of that history. As the results of this survey show, there has been a great deal of change in farming areas and what remains to suggest the character of past farm development is fast passing from the scene. This underscores the importance of paying attention to the countryside, and this has ably been done here

• In particular, the discovery of National Register potential in the group of farmsteads comprising the Lewis Bottoms Rural Neighborhood adds a heretofore unexplored dimension to rural analysis.

Typically the only rural places found eligible for nomination based on their connections to historical events have been those associated the settlement of ethnic groups. Now we have a rural neighborhood where owners share a common family ancestry. While the challenge here will be .to show that the collection of existing buildings reflects something distinctive, important, and among the most authentic surviving expressiqns of such county development through conducting comparative surveys of similar neighborhoods elsewhere, the idea shows promise of tapping into an important aspect of understanding about patterns of rural life. One suggestion I would make is, given the fact that early expressions of farm development are fast disappearing, extra importance may wish to be attached to surveying, nominating, and preserving houses and barns that date to before the civil War. One property that comes to mind here is the Railsback barn. Relatively few barns existed well into the 1870s in Iowa and this is one of a few that both date to the late 1850s and are of a substantial character when built. Not only that, it is a rare example of a Pennsylvania barn built on the Sweitzer plan with an unsupported forebay. Although its .condition appears deteriorated, it seems deserving of further research as potentially meeting National Register criteria "A", "ell, or "D". The fast approaching deadlines for our comment preclude my going into further detail on the draft of this most promising study. I look forward to seeing a copy of the final report. It gives hope of becoming a model for stimulating similar efforts elsewhere. cc: Ralph Christian September 13, 1993 To: Kathy From: Ralph

Subject:

Linn County Survey Report Draft The Report: page i: In the last paragraph, the statement about the multiple property approach needs to be restated. As it stands, it indicates that all the resources can be nominated in one document. What would be entailed is the preparation of a Multiple Property Cover Document plus individual National Register Nominations for each resource. This fallacy is repeated in other sections of the report as well."\. Page 2-16, paragraph 4: The Lincoln Highway was a route not a "system." This implies a larger road network, Pages 2-17-19: This whole section has the appearance of an artificial construction since the focus is on one town and context beyond it is missing.It is obvious that this context is not going to be very useful until several more townships are surveyed and one has some sort of comparative framework, and this fact shold be stated upfront. Given the lack of truly meaningful data, the surveyor is forced to focus primarily on architectural development, something which would more properly belong in the larger architectural context.I am also concerned about trying to pigeonhole Palo's development in terms of standard terminology for urban development. Terms like "residential district," "commercial district," and "central business district" probably had and probably even today have little meaning to local residents in terms of how they view their environment. The next to the last paragraph on Page 2-18 discussing the random fashion of development gives one a better sense of 'how the town has actually developed. I suspect what we really have here is something of a hybrid of a wagon haul community and rural crossroads with a limited amount of railroad influence thrown in. It is this particular type of development which one might for lack of a better term describe as "rural village" which may make Palo significant, but we are not really going to make this sort of judgment until more survey results are in. In the light of all this, should we have one historic district here and not two, given the fact that the two areas are contiguous and largely linear, the overall number of resources, and the fact they are both rather mixed bags?Pages 2-21-2-38: I would recommend some major revamping of this section. In my opinion, building materials, scale, form, and style are largely meaningless here in terms of providing applicable subcontexts. The information contained September 13, 1993 To: Kathy From: Ralph

Subject:

Lipn County Survey Report Draft The Report: page i: In the last paragraph, the statement about the mUltiple property approach needs to be restated. As it stands, it indicates that all the resources can be nominated in one document. What would be entailed is the preparation of a Multiple Property Cover Document plus individual National Register Nominations for each resource. This fallacy is repeated in other sections of the report as well. -'-..-Page 2-16, paragraph 4: The Lincoln Highway was a route not a "system." This implies a larger road network. Pages 2-17-19: This whole section has the appearance of an artificial construction since the focus is on one town and context beyond it is missing. It is obvious that this context is not going to be very useful until several more townships are surveyed and one has some sort of comparative framework, and this fact shold be stated upfront. Given the lack of truly meaningful data, the surveyor is forced to focus primarily on architectural development, something which would more properly belong in the larger architectural context. I am also concerned about trying to pigeonhole Palo's development in terms of standard terminology for urban development. Terms like "residential district," "commercial district," and "central business district" probably had and probably even today have little meaning to local residents in terms of how they view their environment. The next to the last paragraph on Page 2-18 discussing the of development gives one a better sense of how the town has actually developed. I suspect what we really have here is something of a hybrid of a wagon haul community and rural crossroads with a limited amount of railroad influence thrown in. It is this particular type of development which one might for lack of a better term describe as "rural village" which may make Palo significant, but we are not really going to make this sort of judgment until more survey results are in. In the light of all this, should we have one historic district here and not two, given the fact that the two areas are contiguous and largely linear, the overall number of resources, and the fact they are both rather mixed bags? Pages 2-21-2-38: I would recommend some major revamping of this section. In my opinion, building materials, scale, form, and style are largely meaningless here in terms of providing applicable subcontexts. The information contained in this sections, where it is applicable, should be worked into a new subcontext, "The Architecture of Palo," and into the two remaining subcontexts. Page 2-34, line 1: The term "Bungaloid" is usually applied to houses of more than one-story that exhibit "Bungalow" characteristics but are not technically bungalows because of their height. "Bungalow" is usually reserved for 1 and sometimes 1 1/2 story houses while anything with 2 full stories or more gets the monicker "Bungaloid." Page 3-12: The significance section should focus on "significance" and not the National Register criteria which is dealt with in section 3.Page 3-13-14: The eligibility section on the Lewis Bottoms needs to be rewritten to reflect fact that all this properties will need individual National Register forms as well as a Multiple Property Cover Document. The site sheets should reflect this as well since the district form has been adapted for a nomination format that no longer exists.., Page 5-2, paragraph 4: Correct reference regarding Lewis Bottoms relative to Multiple Property -...Site Sheets Property 14-A: There is a mention of "stylistic influence" but no mention of particular styles.Resources of John Livermore: Do not use the adapted site form for this purpose because it only creates confusion relative to the process for listing the properties significant within the framework of this context.Property 57: is this the correct photo? If so, there is nothing visible which would tie this house to the Livermore context. Photos should highlight those elements of this building that make it significant under this context.Property 75: We need a better photo of the privy since the one used in the report makes the facility appear stuccoed or covered up.Property 43: Given the generally unadorned nature of Palo architecture and the general lack of strong stylistic influences in its housing stock, I am somewhat surprised that this house has been evaluated as ineligible, especially given some of the buildings being determined eligible. I fear integrity concerns may be too focused on physical deterioration. More explanation is needed.Prooperty 49: The noneligibility finding for this house is even more surprising. Here "outstanding" seems to be a criteria when it does not seem to-2-in this sections, where it is applicable, should be worked into a new subcontext, "The Architecture of Palo," and into the two remaining subcontexts. Page 2-34, line 1: The term "Bungaloid" is usually applied to houses of more than one-story that exhibit "Bungalow" characteristics but are not technically bungalows because of their height. "Bungalow" is usually reserved for 1 and sometimes 1 1/2 story houses while anything with 2 full stories or more gets the monicker "Bungaloid." '! Page 3-12: The significance section should focus on "significance" and not the National Register criteria which is dealt with in section 3. Page 3-13-14: The eligibility section on the Lewis Bottoms needs to be rewritten to reflect fact that all this properties will need individual National Register forms as well as a Multiple Property Cover Document. The site sheets should reflect this as well since the district form has been adapted for a nomination format that no longer exists .,' Page 5-2, paragraph 4: Correct reference regarding Lewis Bottoms relative to Multiple Property'" Site Sheets Property 14-A: There is a mention of "stylistic influence" but no mention of particular styles. Resources of John Livermore: Do not use the adapted site form for this purpose because it only creates confusion relative to the process for listing the properties significant within the framework of this context. Property 57: is this the correct photo? If so, there is nothing visible which would tie this house to the Livermore context. Photos should highlight those elements of this building that make it significant under this context. Property 75: We need a better photo of the privy since the one used in the report makes the facility appear stuccoed or covered up. Property 43: Given the generally unadorned nature of Palo architecture and the general lack of strong stylistic influences in its housing stock, I am somewhat surprised that this house has been evaluated as ineligible, especially given some of the buildings being determined eligible. I fear integrity concerns may be too focused on physical deterioration. More explanation is needed. Prooperty 49: The noneligibility finding for this house is even more surprising. Here "outstanding" seems to be a criteria when it does not seem to have been applied across the board in other instances in the survey. The basic porch treatment, including pedimented gable is likely original, although the porch proper has been enclosed. I can't see the Craftsman feel and influence in the xeroxed photo. Is this the correct photo?cc: Lowell Soike-3-have been applied across the board in other instances in the survey. The basic porch treatment, including pedimented gable is likely original, although the porch proper has been enclosed. I can't see the Craftsman feel and influence in the xeroxed photo. Is this the correct photo? cc: Lowell Soike REVIEW COMMENTS ON ARCHEOLOGICAL PORTION* OF 1992 REPORT LINN COUNTY CLG GRANT 19-92-7012A.018 The funding acknowledgment statement does not appear in Volume I, but appears at the beginning of each of the other volumes. Please include it in Volume I as well. There are two errors in the funding statement. "National Park Services" should be "National Park Service." "co-investigators" should be "Co-Principal Investigators." Abstract, paragraph 3: The first sentence is unclear. Please revise it.Acknowledgments, paragraph 3, line 1: The words "Recorders," "Auditors," and"Assessors" should all have apostrophes. .Page 1-2, paragraph 3, line 3: occurs in line 7:" Page 1-2, paragraph 3, line 5: Page 2-3, paragraph 3, line 3: Page 2-3, paragraph 4, line 8: Page 2-3, paragraph 5, line 5: Page 2-4, paragraph 2, line 5: farmer generally raising." Page 2-4, paragraph 5, line 2: Page 2-4, paragraph 6, line 2: Page 2-6, paragraph 3, line 3: "Iowa Surface" should be "Iowan Surface." This same error"regions" should be "region.""on shoe maker" should be "one shoe maker." delete phrase "once again...Northwest." -"both township" should be "both the township.""with farmers generally raising" should be "with each"that that" should be "that the.""lower" should be "smaller." ,"Between 1930-1940" should be "Between 1930 and 1940." Page 2-6, paragraph 3, line 10. End sentence after the word "Center." New sentence should begin "The Duane Arnold Energy Center continues to....Page 2-6, paragraph 4, line 1: capitalize "Early Settlement Era."* As noted in the cover letter, our office will not review the architectural portion of this document because that portion of the "draft" is woefully incomplete. ,", j; . i : I : : r-" j ",: REVIEW COMMENTS ON ARCHEOLOGICAL PORTION* OF 1992 REPORT LINN COUNTY CLG GRANT 19-92-7012A.018 The funding acknowledgment statement does not appear in Volume If but appears at the beginning of each of the other volumes. Please .include it in Volume I as well. There are two errors in the funding statement. "National Park Services" should be "National Park Service." fIco-investigators" should be "Co-Principal Investigators." Abstract f paragraph 3: The first sentence is unclear. Please revise it. Acknowledgments, paragraph 3, line 1: The words "Recorders," "Auditors," and "Assessors" should all have apostrophes. I Page 1-2, paragraph 3, line 3: "Iowa Surface" should be "Iowan Surface." This same error occurs in line 1>,. Page 1-2, paragraph 3, line 5: "regions" should be "region." ' .. Page 2-3, paragraph 3, line 3: "on shoe maker" should be "one shoe maker." Page 2-3, paragraph 4, line 8: delete phrase "once again ... Northwest." : Page 2-3, paragraph 5, line 5: "both township" should be "both the township." .... Page 2-4, paragraph 2, line 5: "with farmers generally raising" should be "with each farmer generally raising. II

• Page 2-4, paragraph 5, line 2: "that that" should be "that the." Page 2-4, paragraph 6, line 2: "lower" should be "smaller." _ Page 2-6, paragraph 3, line 3: "Between 1930-1940" should be "Between 1930 and 1940." , Page 2-6, paragraph 3, line 10. End sentence after the word "Center." New sentence should begin "The Duane Arnold Energy Center continues to .... " Page 2-6, paragraph 4, line 1: capitalize "Early Settlement Era." ,
• As noted in the cover letter, our office will not review the architectural portion of this document because that portion of the "draft" is woefully incomplete.

4 Page 2-7, paragraph 5, line 6: "than" should be "then."`, Page 2-10, paragraph 4, line 6: "will" should be "was." Page 2-11, paragraph 2, last line: delete second "been." Page 3-1, paragraph 3, line 5: capitalize the words "lake," "state," and "park." Page 3-1, paragraph 3, line 9: "supplement" should be "supplemental." Page 3-3, paragraph 1, line 5: The sentence "None of the sites.. .settlement." doesn't seem to be completely accurate. Wouldn't it be more correct to say "None of the sites recorded during the present survey have yielded artifacts of these types...." Figure 2-3: A key to the abbreviations used in this figure must be provided.Figure 3-1: Were the standing buildings noted on this map inventoried? If they were, their survey numbers need to be noted on the map.All archeological site forms need to be typed.We understand that the final report will include all artifact descriptions (Appendix B).Chapter 6, Major Bibliographical References, is missing., The photograph log sheets contain several incomplete addresses. We must have complete addresses for each property.i ) "". Page 2-7. paragraph 5, line 6: "than" should be "then. ""', v' Page 2-10, paragraph 4, line 6: "will" should be "was." \.; Page 2-11, paragraph 2, last line: delete second "been." " \ Page 3-1, paragraph 3, line 5: capitalize the words "lake," "state," and "park." ,. Page 3-1, paragraph 3, line 9: "supplement" should be "supplemental." , Page 3-3, paragraph 1, line 5: The sentence "None of the sites ... settlement." doesn't seem to be completely accurate. Wouldn't it be more correct to say "None of the sites recorded during the present survey have yielded artifacts of these types .... " . , Figure 2-3: A key to the abbreviations used in this figure must be provided ..... Figure 3-1: Were the standing buildings noted on this map inventoried? If they were, their survey numbers need to be noted on the map.' All archeological site forms need to be typed. .: We understand that the final report will include all artifact descriptions (Appendix B). "," Chapter 6, Major Bibliographical References, is missing. "" The photograph log sheets contain several incomplete addresses. We must have complete addresses for each property. Additional errors found in Linn Co. CLO grant 92.018 Page 3-9, paragraph 5, line: "because depot" should be "because the depot." Page 3-10, paragraph 4, line 6: "exceptionable" should be "exceptional." 1ýAdditional errors found in Linn Co. CLG grant 92.018 Page 3 -9 I paragraph 5 I line: "because depot" should be "because the depot." . <l Page 3 -10 I paragraph 4, line 6: "exceptionable" should be "exceptional." Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 C.4 DAEC 2009. ACP Excavation and Trenching Controls, Administrative Control Procedure. ACP 1408.29. Revision 8. July.Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 C.4 DAEC 2009. ACP Excavation and Trenching Controls, Administrative Control Procedure. ACP 1408.29. Revision 8. July. ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 1 of 27 Usage Level 1 Information Use Effective Date: JUL 0 8 2009 Approved for 'Point-of-Use' printing IF NO DCFs are in effect for this procedure.(on designated printers)Record the following: Date / Time: /Printer ID: DA -Initials: _ _ .NOTE: Per ACP 106.1, a DCF/REV check shafl be performed and documented every 24 hours if active document use exceeds a 24 hour period as determined from the date and time recorded above.Document approval signatures on file ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 1 of 27 Usage Level Information Use JUL 08 2009 Approved for 'Point-of-Use' printing IF NO DCFs are in effect for this procedure. (on designated printers) Record the following: Date I Time: ________ I ______ _ Printer 10: DA -_________ Initials: ___ _ NOTE: Per ACP 106.1, a DCFIREV check shall be performed and documented every 24 hours if active document use exceeds a 24 hour period as determined from the date and time recorded above. Document approval signatures on file I Prepared By: Print Signature Date:1-IrrM Reviewed By: Date: Reviewed By: Print ....... Signature A)IB Reviewed By: Signature Date: ------I Print Approved By Signature Date: ---'-'--4_---1 Print ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 2 of 27 1.0 PURPOSE (1) This procedure provides controls for excavating activities at DAEC in order to:* Prevent damage to underground components, utilities, and structures.

• Ensure the safety of personnel that may encounter underground hazards (e.g., contact with underground utilities) or that may be exposed to hazards during excavation (e.g., cave-ins)Ensure protection of Archaeological, Cultural and Historical (AC&H) resources found as a result of ground moving, excavation, and trenching activities.

Ensure compliance of IDNR storm water construction requirements; when excavation activities disturb one or more acres of soil the activity requires an application to be sent into the IDNR requesting permission to do so.(2) This procedure is applicable for all activities in the owner-controlled area of DAEC that involves the piercing or movement of ground deeper than six inches. This includes activities performed by contracted personnel. Specific activities include:

• Pole erection* Post/rod driving (e.g., ground rods, pilings, stakes, etc.)* Augering" Trenching* Landscaping" Tunneling or boring" Grading, including road grading" Building erection, including temporary building/trailer erection or placement.
• Asphalt and concrete cutting or demolition work that goes deeper than six inches into the supporting material below the asphalt or concrete." Any other piercing or movement of ground deeper than six inches.(3) Excavations activities less than six (6) inches deep are exempt from the requirements of this procedure.

(4) Excavation activities required to mitigate an environmental spill are exempt from this procedure provided: 0 The Environmental Coordinator or designee maintains responsibility for and supervises the cleanup activities.

• For small amounts of spilled material, if hand digging with plastic or insulated shovels to remove the spilled material up to 12 inches below ground level.ACP 1408.29 EXCAVATION

& TRENCHING CONTROLS Rev. 8 Page 2 of 27 1.0 PURPOSE (1) This procedure provides controls for excavating activities at DAEC in order to:

• Prevent damage to underground components, utilities, and structures.
• Ensure the safety of personnel that may encounter underground hazards (e.g., contact with underground utilities) or that may be exposed to hazards during excavation (e.g., cave-ins)
• Ensure protection of Archaeological, Cultural and Historical (AC&H) resources found as a result of ground moving, excavation, and trenching activities.
• Ensure compliance of IDNR storm water construction requirements; when excavation activities disturb one or more acres of soil the activity requires an application to be sent into the IDNR requesting permission to do so. (2) This procedure is applicable for all activities in the owner-controlled area of DAEC that involves the piercing or movement of ground deeper than six inches. This includes activities performed by contracted personnel.

Specific activities include:

• Pole erection
• Post/rod driving (e.g., ground rods, pilings, stakes, etc.)
• Augering
• Trenching
• Landscaping
• Tunneling or boring
• Grading, including road grading
• Building erection, including temporary building/trailer erection or placement.
• Asphalt and concrete cutting or demolition work that goes deeper than six inches into the supporting material below the asphalt or concrete.
• Any other piercing or movement of ground deeper than six inches. (3) Excavations activities less than six (6) inches deep are exempt from the requirements of this procedure.

(4) Excavation activities required to mitigate an environmental spill are exempt from this procedure provided:

• The Environmental Coordinator or designee maintains responsibility for and supervises the cleanup activities.
• For small amounts of spilled material, if hand digging with plastic or insulated shovels to remove the spilled material up to 12 inches below ground level.

DMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 3 of 27 For large spills, if non-invasive removal methods are used that do not represent risk to buried equipment (e.g., "vacuum" truck).(5) This procedure is not applicable to activities involving the clean-up/removal of materials from paved surfaces such as sidewalks, roadways, or parking lots.(6) Activities involving the clean-up/removal of material piled on grade (earth, gravel, sand, etc.,) that do not disturb grade are exempt from this procedure.

2.0 DEFINITIONS

Archaeological, Cultural and Historical (AC&H) Resource -Item considered to be of cultural importance to the community, state, or nation, including but not limited to graves, archaeological sites, pottery, tools, weaponry and other implements, ritual artifacts and discarded materials (i.e.Indian mounds with shells and animal bones). Typically 50 or more years old.Assigned Supervisor: The person directly supervising the excavation activity. This person may be a contracted employee.Competent Person: A person trained in and capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees and who is authorized to take prompt corrective measures to eliminate them.Contractor Liaison: A NextEra Energy Duane Arnold employee assigned the responsibility of providing oversight of contract personnel working at DAEC.Excavation: Any man-made cut, cavity, trench, hole, or depression in an earth surface formed by earth removal or ground piercing activities. Hand Digging: The use of non-powered hand tools such as shovels, picks or hoes for careful removal of soil.Iowa Department of Natural Resources (IDNR) Storm Water Construction Permit -Iowa Department of Natural Resources requires a storm water discharge associated with industrial activity for Construction activities; NPDES General Permit #2.SHPO: State Historic Preservation Officer Soil Loosening: The use of an air-operated device (e.g., Soil Saber) to assist in loosening the soil, prior to hand digging.Vacuuming: The use of a vacuuming truck or other similar device designed for removing soil or other material.ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 3 of 27

• For large spills, if non-invasive removal methods are used that do not represent risk to buried equipment (e.g., "vacuum" truck). (5) This procedure is not applicable to activities involving the clean-up/removal of materials from paved surfaces such as sidewalks, roadways, or parking lots. (6) Activities involving the clean-up/removal of material piled on grade (earth, gravel, sand, etc. ,) that do not disturb grade are exempt from this procedure.

2.0 DEFINITIONS

Archaeological, Cultural and Historical (AC&H) Resource -Item considered to be of cultural importance to the community, state, or nation, including but not limited to graves, archaeological sites, pottery, tools, weaponry and other implements, ritual artifacts and discarded materials (Le. Indian mounds with shells and animal bones). Typically 50 or more years old. Assigned Supervisor: The person directly supervising the excavation activity. This person may be a contracted employee. Competent Person: A person trained in and capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees and who is authorized to take prompt corrective measures to eliminate them. Contractor Liaison: A NextEra Energy Duane Arnold employee assigned the responsibility of providing oversight of contract personnel working at DAEC. Excavation: Any man-made cut, cavity, trench, hole, or depression in an earth surface formed by earth removal or ground piercing activities. Hand Digging: The use of non-powered hand tools such as shovels, picks or hoes for careful removal of soil. Iowa Department of Natural Resources (IDNR) Storm Water Construction Permit -Iowa Department of Natural Resources requires a storm water discharge associated with industrial activity for Constru.ction activities; NPDES General Permit #2. SHPO: State Historic Preservation Officer Soil Loosening: The use of an air-operated device (e.g., Soil Saber) to assist in loosening the soil, prior to hand digging. Vacuuming: The use of a vacuuming truck or other similar device designed for removing soil or other material. ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 Rev. 8 EXCAVATION & TRENCHING CONTROLS Page 4 of 27 3.0 INSTRUCTIONS

3.1 RESPONSIBILITIES

3.1.1 MAINTENANCE

MANAGER (1) Overall responsibility for the implementation of this procedure.

3.1.2 EXCAVATION

PERMIT INITIATOR(1) Identification of activities that are within the scope of this procedure.(2) Applying for any IDNR storm water construction permits if necessary.

3.1.3 ASSIGNED

SUPERVISOR (1) Responsible for all excavating activities at the excavation site. (2) Responsible for compliance with the Excavation Permit.3.1.4 COMPETENT PERSON(1) Overall safety of workers at the excavation site (2) OSHA compliance at the excavation site 3.1.5 PLANNING DEPARTMENT(1) Identification of impacted or potentially impacted safety related structures, equipment, or components due to planned excavation activities.

3.1.6 ENGINEERING

DEPARTMENT(1) As appropriate, the identification of impacted or potentially impacted safety related structures, equipment, or components due to planned excavation activities.

3.1.7 ENVIRONMENTAL

COORDINATOR (1) Determines whether proposed activities will occur in the vicinity of any known historic properties listed in, or eligible for, the National Register of Historic Places.(2) Evaluates potential AC&H resources inadvertently discovered during excavation and trenching activities. (3) Coordinates communications between plant owner representatives and the State Historical Preservation Office (SHPO), as deemed necessary. EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 4 of 27 3.0 INSTRUCTIONS

3.1 RESPONSIBILITIES

3.1.1 MAINTENANCE

MANAGER* (1) Overall responsibility for the implementation of this procedure.

3.1.2 EXCAVATION

PERMIT INITIATOR (1) Identification of activities that are within the scope of this procedure. (2) Applying for any IDNR storm water construction permits if necessary.

3.1.3 ASSIGNED

SUPERVISOR (1) Responsible for all excavating activities at the excavation site. (2) Responsible for compliance with the Excavation Permit. 3.1.4 COMPETENT PERSON (1) Overall safety of workers at the excavation site (2) OSHA compliance at the excavation site 3.1.5 PLANNING DEPARTMENT (1) Identification of impacted or potentially impacted safety related structures, equipment, or components due to planned excavation activities.

3.1.6 ENGINEERING

DEPARTMENT (1) As appropriate, the identification of impacted or potentially impacted safety related structures, equipment, or components due to planned excavation activities.

3.1.7 ENVIRONMENTAL

COORDINATOR (1) Determines whether proposed activities will occur in the vicinity of any known historic properties listed in, or eligible for, the National Register of Historic Places. (2) Evaluates potential AC&H resources inadvertently discovered during excavation and trenching activities. (3) Coordinates communications between plant owner representatives and the State Historical Preservation Office (SHPO), as deemed necessary. I* ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 5 of 27 (4) Determines whether the proposed activities will require additional regulatory permitting such as Storm Water Pollution Construction permit or modifications to existing permits such as the site National Pollution Discharge Elimination System.(5) In some cases an Archaeological Survey may be required by a certified archaeologist. In such cases a copy of the Survey report shall be forwarded to the Environmental Coordinator.

3.2 GENERAL

REQUIREMENTS (1) All excavation activities shall be planned and implemented by use of the Excavation Permit (Attachment 1).(2) Design Engineering or Maintenance shall determine, by use of available drawings, any documented buried pipes, cables or underground equipment in the vicinity of the proposed excavation site.(a) Site drawings shall not be relied on as the sole source of information regarding underground components. (3) A survey of the excavation site shall be performed utilizing underground structure locating devices operated by qualified individuals. Attachment 2 identifies various locating methods that may be used. For other locating methods (GPR, EM, hydro-vacuum), arrangements should be made with the applicable contractor, as applicable. Use of multiple methods is recommended in order to obtain an accurate survey of underground components.(a) The responsible job supervisor will coordinate support activities.(b) Contact Electrical Maintenance, if appropriate, to arrange this support activity within the facility's Protected Area, Electrical Switchyard and Independent Spent Fuel Storage Installation (ISFSI).(c) Local state agencies should have the primary responsibility of locating electrical cables outside of the Protected Area, Electrical Switchyard and ISFSI.(d) The applicable phone company should have the primary responsibility of locating all phone cables.(e) The location of underground components shall be marked with spray paint and flag markers.(4) A review of the excavation site shall be performed by the Environmental Coordinator to determine whether any historic properties listed in, or eligible for, the National Register of Historic Places, are located in the vicinity of the proposed excavation site.(a) Work in culturally important areas requires a consultation with the SHPO.ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 5 of 27 (4) Determines whether the proposed activities will require additional regulatory permitting such as Storm Water Pollution Construction permit or modifications to existing permits such as the site National Pollution Discharge Elimination System. (5) In some cases an Archaeological Survey may be required by a certified archaeologist. In such cases a copy of the Survey report shall be forwarded to the Environmental Coordinator.

3.2 GENERAL

REQUIREMENTS (1) All excavation activities shall be planned and implemented by use of the Excavation Permit (Attachment 1). (2) Design Engineering or Maintenance shall determine, by use of available drawings, any documented buried pipes, cables or underground equipment in the vicinity of the proposed excavation site. (a) Site drawings shall not be relied on as the sole source of information regarding underground components. (3) A survey of the excavation site shall be performed utilizing underground structure locating devices operated by qualified individuals. Attachment 2 identifies various locating methods that may be used. For other locating methods (GPR, EM, hydro-vacuum), arrangements should be made with the applicable contractor, as applicable. Use of multiple methods is recommended in order to obtain an accurate survey of underground components. (a) The responsible job supervisor will coordinate support activities. (b) Contact Electrical Maintenance, if appropriate, to arrange this support activity within the facility's Protected Area, Electrical Switchyard and Independent Spent Fuel Storage Installation (ISFSI). (c) Local state agencies should have the primary responsibility of locating electrical cables outside of the Protected Area, Electrical Switchyard and ISFSI. (d) The applicable phone company should have the primary responsibility of locating all phone cables. (e) The location of underground components shall be marked with spray paint and flag markers. (4) A review of the excavation site shall be performed by the Environmental Coordinator to determine whether any historic properties listed in, or eligible for, the National Register of Historic Places, are located in the vicinity of the proposed excavation site. (a) Work in culturally important areas requires a consultation with the SHPO. ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 6 of 27 (b) If activities are restricted to areas of the site previously disturbed due to construction, consultation with the SHPO is not required.(5) Any encounter with unexpected obstructions or items of AC&H importance during locating or excavation operations shall be immediately reported to the Assigned Supervisor (and Environmental Coordinator in issues involving AC&H resources) including exact location, depth and description of material encountered. Information shall be entered in the Corrective Action Program for disposition. (6) Engineering shall, as appropriate, verify any discrepancy with plant documents, as to the actual location, depth or description of material encountered, and the appropriate documentation revised, according to plant procedures, to reflect the AS FOUND condition. (7) An Action Request shall be initiated to document the resolution of these discrepancies. (8) In work areas where the exact location of underground electric power lines is unknown, employees using jack-hammers, bars, or other hand tools which may contact a line shall be provided with insulated protective gloves.(9) At any time when underground components are uncovered, (whether anticipated or unplanned) and there are indications of degradation, corrosion, damage, etc the appropriate personnel shall be notified to: (a) Inspect the condition of the equipment (e.g., degradation, corrosion, etc.).(b) Determine if the equipment has sustained damage due to contact during excavation (damage to electrical insulation, protective coatings to prevent corrosion). NOTE Small nicks in protective coating on pipes or tanks can result in accelerated corrosion. (10) The Contractor Liaison is responsible for monitoring the performance of vendors and contractors to ensure excavation activities are performed in accordance with the requirements of this procedure. (11) If performing activities around the exterior of building or structures, verify the exterior wall configuration is in accordance with plant drawings and documents. If a discrepancy exists, Engineering shall be contacted for resolution. (Ref. 3, CAP053469) ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 6 of 27 (b) If activities are restricted to areas of the site previously disturbed due to construction, consultation with the SHPO is not required. (5) Any encounter with unexpected obstructions or items of AC&H importance during locating or excavation operations shall be immediately reported to the Assigned Supervisor (and Environmental Coordinator in issues involving AC&H resources) including exact location, depth and description of material encountered. Information shall be entered in the Corrective Action Program for disposition. (6) Engineering shall, as appropriate, verify any discrepancy with plant documents, as to the actual location, depth or description of material encountered, and the appropriate documentation revised, according to plant procedures, to reflect the AS FOUND condition. (7) An Action Request shall be initiated to document the resolution of these discrepancies. (8) In work areas where the exact location of underground electric power lines is unknown, employees using jack-hammers, bars, or other hand tools which may contact a line shall be provided with insulated protective gloves. (9) At any time when underground components are uncovered, (whether anticipated or unplanned) and there are indications of degradation, corrosion, damage, etc the appropriate personnel shall be notified to: (a) Inspect the condition of the equipment (e.g., degradation, corrosion, etc.). (b) Determine if the equipment has sustained damage due to contact during excavation (damage to electrical insulation, protective coatings to prevent corrosion). NOTE Small nicks in protective coating on pipes or tanks can result in accelerated corrosion. (10) The Contractor Liaison is responsible for monitoring the performance of vendors and contractors to ensure excavation activities are performed in accordance with the requirements of this procedure. (11) If performing activities around the exterior of building or structures, verify the exterior wall configuration is in accordance with plant drawings and documents. If a discrepancy exists, Engineering shall be contacted for resolution. (Ref. 3, CAP053469) ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 7 of 27 3.3 INITIATION OF THE EXCAVATION PERMIT NOTE The table below may be used to determine the person who initiates the Excavation Permit. Activity Control Method Initiator Excavation activity is to be controlled by a The maintenance or modification planner Work Order initiates the Excavation Permit as part of the job planning in accordance with appropriate procedures. Work group to perform the work. The Planner initiates the Excavation Permit as part of job planning.Contracted excavation services without use The Assigned Supervisor initiates the of a Work Order to control the activity. Excavation Permit when identifying actions and site requirements for contracted services in accordance with the Work Request.All other excavation activities. The Assigned Supervisor initiates the Excavation Permit.(1) Initiator performs the following: (a) Completes Part 1 of Attachment 1, "Excavation Permit" (b) Attaches a diagram of the excavation area 3.4 DEVELOPMENT OF THE EXCAVATION PERMIT NOTE Engineering assistance may be required in developing the excavation permit.(1) The initiator develops the Excavation Permit, and ensures the following activities are performed: (a) Review all documents affecting the area to be excavated; consult with the appropriate engineering/maintenance personnel for assistance as needed.(b) Complete a field walkdown of the excavation area.(c) Locate existing utilities and other commodities within, and adjacent to, the planned excavation area, using: (i) The Local state agency responsible for locating electrical cables/utilities outside of the Protected Area, Electrical Switchyard and ISFSI.ACP 1408.29 ,,' ... ,:(, -' ,--( .. ADMINISTRATIVE CONTROLPROCEDURE"2( , . . .. " .':; ',: . ,:.:, . , EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 7 of 27 3.3 INITIATION OF THE EXCAVATION PERMIT NOTE The table below may be used to determine the person who initiates the Excavation Permit. Excavation activity is to be controlled by a Work Order Work group to perform the work. Contracted excavation services without use of a Work Order to control the activity. All other excavation activities. (1) Initiator performs the following: nl"n,rQl"lures. The Planner initiates the Excavation Permit as rt of Ian The Assigned Supervisor initiates the Excavation Permit when identifying actions and site requirements for contracted services in accordance with the Work uest. The Assigned Supervisor initiates the Excavation Permit. (a) Completes Part 1 of Attachment 1, "Excavation Permit" (b) Attaches a diagram of the excavation area 3.4 DEVELOPMENT OF THE EXCAVATION PERMIT NOTE Engineering assistance may be required in developing the excavation permit. (1) The initiator develops the Excavation Permit, and ensures the following activities are performed: (a) Review all documents affecting the area to be excavated; consult with the appropriate engineering/maintenance personnel for assistance as needed. (b) Complete a field walkdown of the excavation area. (c) Locate existing utilities and other commodities within, and adjacent to, the planned excavation area, using: (i) The Local state agency responsible for locating electrical cables/utilities outside of the Protected Area, Electrical Switchyard and ISFSI. ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 8 of 27 (ii) Cable tracing methods (iii) Ground penetrating radar (iv) Other non-intrusive location methods NOTE Attachment 2, "Detection Tools" contains a list of tools that can be used to detect underground utilities and other commodities. Use of multiple methods is recommended.(d) Mark the ground at the excavation site indicating the location of utilities and other commodities, using paint, flags, etc.(e) Determine potentially impacted safety related structures, equipment, or components. (2) The initiator shall: (a) Complete Part 2 of the Excavation Permit, including the following: (i) A detailed map of the excavation area, showing all known underground utilities and other commodities. Marked-up plant drawings may be used.(ii) The method(s) of excavation to be used.(iii) The approved dimensions and depth of the excavation.(iv) Equipment affected or potentially affected.(b) Obtain Excavation Permit reviews and approval per Section 3.5 ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 8 of 27 (ii) Cable tracing methods (iii) Ground penetrating radar (iv) Other non-intrusive location methods NOTE Attachment 2, "Detection Tools" contains a list of tools that can be used to detect underground utilities and other commodities. Use of multiple methods is recommended. (d) Mark the ground at the excavation site indicating the location of utilities and other commodities, using paint, flags, etc. (e) Determine potentially impacted safety related structures, equipment, or components. (2) The initiator shall: (a) Complete Part 2 of the Excavation Permit, including the following: (i) A detailed map of the excavation area, showing all known underground utilities and other commodities. Marked-up plant drawings may be used. (ii) The method(s) of excavation to be used. (iii) The approved dimensions and depth of the excavation. (iv) Equipment affected or potentially affected. (b) Obtain Excavation Permit reviews and approval per Section 3.5 ADMINISTRATIVE CONTROL PROCEDURE ACIP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 9 of 27 3.5 EXCAVATION PERMIT REVIEW AND APPROVAL NOTE Reviews and approvals via telecom or electronic mail are permitted. (1) Excavation Permit reviews should be performed by the following departments, as indicated below: Department Activities Engineering As appropriate, per the initiator Operations All excavations that may affect plant operations Environmental Excavations that modify site land use, including:

• Movement of material from one area to another may affect storm water drainage* Disturbance of natural habitat, culturally important or historical areas* Involve chemical spills* Disturbance of one or more acres requires a storm water construction permit through the IDNR Safety Excavations that:* Use power operated equipment* Require use of shoring or other protective devices* Involve confined spaces* Are in the vicinity of buried utilities Radiation Protection Excavations which involve:* Radiological affected areas* Removal of excavated material from DAEC property Security All excavations within 20 feet of a security fence, or when security equipment is identified as potentially affected.(2) Departments should review the Excavation Permit, verifying that the following minimum requirements are addressed: (a) Engineering (i) Potentially impacted safety related structures, equipment, or components identified ACP 1408.29 EXCAVATION

& TRENCHING CONTROLS Rev. 8 Page 9 of 27 3.5 EXCAVATION PERMIT REVIEW AND APPROVAL NOTE Reviews and approvals via telecom or electronic mail are permitted. (1) Excavation Permit reviews should be performed by the following departments, as indicated below: Operations Environmental Safety Radiation Protection Security As appropriate, per the initiator All excavations that may affect plant rations Excavations that modify site land use, including:

• Movement of material from one area to another may affect storm water drainage
• Disturbance of natural habitat, culturally important or historical areas
• Involve chemical spills
• Disturbance of one or more acres
• Use power operated equipment
• Require use of shoring or other protective devices
• Involve confined spaces
• Are in the vicin of buried utilities Excavations which involve:
• Radiological affected areas
• Removal of excavated material from DAEC nrnn<=>rn/

All excavations within 20 feet of a security fence, or when security equipment is identified as ntial affected. (2) Departments should review the Excavation Permit, verifying that the following minimum requirements are addressed: (a) Engineering (i) Potentially impacted safety related structures, equipment, or components identified ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 10 of 27 (b) Environmental (i) Environmental Evaluation in accordance with National Pollution Discharge Elimination System (NPDES) Storm-Water Construction Permitting (ii) Industrial waste control (iii) Impacts to historical properties or potentially culturally important areas.(iv) Impacts to groundwater and/or the groundwater protection program.(c) Safety (i) Safe work practices (ii) OSHA compliance (iii) Worker health issues (d) Security(i) Work inside of, or adjacent to, security exclusion zones (ii) Effect or potential effect on security equipment (e) Operations (i) Affect on plant equipment (ii) Potential LCO Action Condition (iii) Contingency plans (f) Radiological Protection(i) Control of radiological waste (ii) Disposition of excavated material (offsite or onsite)(3) The above Reviewer(s) perform the following: (a) Review the Excavation Permit.(b) Document additional requirements in the applicable section of Part 3 of the Excavation Permit.ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 10 of 27 (b) Environmental (i) Environmental Evaluation in accordance with National Pollution Discharge Elimination System (NPDES) Storm-Water Construction Permitting (ii) Industrial waste control (iii) Impacts to historical properties or potentially culturally important areas. (iv) Impacts to groundwater and/or the groundwater protection program. (c) Safety (i) Safe work practices (ii) OSHA compliance (iii) Worker health issues (d) Security (i) Work inside of, or adjacent to, security exclusion zones (ii) Effect or potential effect on security equipment (e) Operations (i) Affect on plant equipment (ii) Potential LCO Action Condition (iii) Contingency plans (f) Radiological Protection (i) Control of radiological waste (ii) Disposition of excavated material (offsite or onsite) (3) The above Reviewer(s) perform the following: (a) Review the Excavation Permit. (b) Document additional requirements in the applicable section of Part 3 of the Excavation Permit. ADMINISTRATIVE CONTROL PROCEDUR E ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 11 of 27(c) If a notification prior to the start of excavation is required, then place a check mark in the applicable required block in Part 5 and include the name/title and phone number to be called.(d) Approve the Excavation Permit by signing Part 4 of the Excavation Permit.(4) Maintenance Manager/Designee Approval(a) When required departmental reviews and approvals are completed, then the Maintenance Manager or designee approves the Excavation Permit and document in Part 6 of the Excavation Permit. (5) Assigned Supervisor Review (a) Assigned supervisor reviews the Excavation Permit to ensure understanding of expectations and documents the review in Part 7 of the Excavation Permit.3.6 ACTIVITIES REQUIRED PRIOR TO EXCAVATING (1) Prior to excavation, the Assigned Supervisor performs the following: (a) Review the approved Excavation Permit (b) Inspect the excavation site and ensure the excavation area is clearly marked on the ground, including known locations of underground utilities and other commodities.(c) Conduct a pre-job brief.(i) A pre-job brief should normally be conducted at the excavation site. Required attendance includes the assigned supervisor and those individuals performing the excavation work. The Assigned Supervisor shall conduct the briefing.(ii) The individual performing the excavation prior to the start of work shall review:* information concerning underground structures" Guidance on AC&H Resources Identification (Attachment 5)" Procedural instructions on actions to take if AC&H resource(s) is/are discovered. (See step 3.6(14) of this procedure.)(d) Notify the Engineering Department, as appropriate, and document in Part 5 of the Excavation Permit.(e) Notify Operations Department and document in Part 5 of the Excavation Permit.ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 11 of 27 (c) If a notification prior to the start of excavation is required, then place a check mark in the applicable required block in Part 5 and include the name/title and phone number to be called. (d) Approve the Excavation Permit by signing Part 4 of the Excavation Permit. (4) Maintenance ManagerlDesignee Approval (a) When required departmental reviews and approvals are completed, then the Maintenance Manager or designee approves the Excavation Permit and document in Part 6 of the Excavation Permit. (5) Assigned Supervisor Review (a) Assigned supervisor reviews the Excavation Permit to ensure understanding of expectations and documents the review in Part 7 of the Excavation Permit. 3.6 ACTIVITIES REQUIRED PRIOR TO EXCAVATING (1) Prior to excavation, the Assigned Supervisor performs the following: (a) Review the approved Excavation Permit (b) Inspect the excavation site and ensure the excavation area is clearly marked on the ground, including known locations of underground utilities and other commodities. (c) Conduct a pre-job brief. (i) A pre-job brief should normally be conducted at the excavation site. Required attendance includes the assigned supervisor and those individuals performing the excavation work. The Assigned Supervisor shall conduct the briefing. (ii) The individual performing the excavation prior to the start of work shall review:

• information concerning underground structures
• Guidance on AC&H Resources Identification (Attachment

5)

• Procedural instructions on actions to take if AC&H resource(s) is/are discovered. (See step 3.6(14) of this procedure.) (d) Notify the Engineering Department, as appropriate, and document in Part 5 of the Excavation Permit. (e) Notify Operations Department and document in Part 5 of the Excavation Permit.

ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 12 of 27 (i) The Work Control Center (WCC) during day shift or Control Room during back shifts shall be notified prior to the start of any excavation activities and every daythat the excavation activities will occur.(f) Notify any other departments indicated as required and document in Part 5 of the Excavation Permit.3.7 EXCAVATING (1) When excavation activities are in progress, the approved Excavation Permit shall be located at the excavation site. (2) Use Excavation Permit approved excavation methods only.(3) Excavations are not to be deeper nor extend beyond boundaries stated on the Excavation Permit. If the scope of the excavation changes such that the initial boundaries of the excavation site need to be exceeded, then STOP WORK immediately and resubmit the Excavation Permit for revision and approval.(4) If mechanical equipment (backhoes and trenchers, for example) has been approved for use, then utilize a spotter 100% of the time during machine operation. The spotter shall be independent of the equipment operator. The spotter shall perform the following: (a) Monitor for the presence of underground and/or overhead utilities or other commodities.(b) Communicate to the equipment operator the location of hazards (such as overhead lines) in relation to the position of the equipment.(c) Assist the operator by providing instruction through hand signals, radio, or other means regarding operation of the vehicle.(d) Ensure the operator is complying with safety flagging, access routes, and other safety precautions discussed in the Pre-job Brief and based on excavation site conditions. (5) Treat buried cables as energized, unless verified otherwise. (6) If within five feet of electrical cables OR electrical cables are encountered, then hand dig, sluice or vacuum, using non-conducting tools only.(7) Provide temporary support for all uncovered and exposed cables, piping, etc., as required.(8) If electrical cables are exposed, then determine if protecting the cables using covers or barriers such as rubber blankets, split PVC, or some other non-conductive material is required.ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 12 of 27 (i) The Work Control Center (WCC) during day shift or Control Room during back shifts shall be notified prior to the start of any excavation activities and every day that the excavation activities will occur. (f) Notify any other departments indicated as required and document in Part 5 of the Excavation Permit. 3.7 EXCAVATING (1) When excavation activities are in progress, the approved Excavation Permit shall be located at the excavation site. (2) Use Excavation Permit approved excavation methods only. (3) Excavations are not to be deeper nor extend beyond boundaries stated on the Excavation Permit. If the scope of the excavation changes such that the initial boundaries of the excavation site need to be exceeded, then STOP WORK immediately and resubmit the Excavation Permit for revision and approval. (4) If mechanical equipment (backhoes and trenchers, for example) has been approved for use, then utilize a spotter 100% of the time during machine operation. The spotter shall be independent of the equipment operator. The spotter shall perform the following: (a) Monitor for the presence of underground and/or overhead utilities or other commodities. (b) Communicate to the equipment operator the location of hazards (such as overhead lines) in relation to the position of the equipment. (c) Assist the operator by providing instruction through hand signals, radio, or other means regarding operation of the vehicle. (d) Ensure the operator is complying with safety flagging, access routes, and other safety precautions discussed in the Pre-job Brief and based on excavation site conditions. (5) Treat buried cables as energized, unless verified otherwise. (6) If within five feet of electrical cables OR electrical cables are encountered, then hand dig, sluice or vacuum, using non-conducting tools only. (7) Provide temporary support for all uncovered and exposed cables, piping, etc., as required. (8) If electrical cables are exposed, then determine if protecting the cables using covers or barriers such as rubber blankets, split PVC, or some other non-conductive material is required. ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 13 of 27 (9) If it becomes necessary to use excavation methods other than those specified in the approved Excavation Permit, then STOP WORK and resubmit the Excavation Permit for revision and approval.(10) If unanticipated or unidentified items (including buried material to protect or warn workers of buried utilities) are encountered, then STOP WORK.(a) Notify the Assigned Supervisor.(b) Notify the Engineering Department, as appropriate.(c) The Assigned Supervisor shall evaluate the situation prior to allowing work to resume and shall ensure that the disposition is documented in the Corrective Action Program.(11) If any plant equipment is damaged due to excavation activities, then STOP WORK and notify the Control Room immediately.(a) Notify the Assigned Supervisor.(b) Initiate an Action Request.(12) Daily inspections of excavations, the adjacent areas, and protective systems shall be made by a competent person for evidence of a situation that could result in possible cave-ins, indications of failure of protective systems, hazardous conditions, and indications of AC&H resources (see Attachment 5 for examples). A Competent Person shall be on-site during excavations.(a) Inspect prior to the start of work and as needed throughout the shift.(b) Inspect after every rainstorm or other hazard-increasing occurrence.(c) Inspections are required only when employee exposure can be reasonably anticipated.(d) The daily inspection shall be signed and dated in the appropriate section of the excavation permit.(13) If the competent person finds evidence of a situation that could result in a possible cave-in, indications of failure of protective systems, hazardous atmospheres, or other hazardous conditions, then remove exposed workers from the hazardous area until the necessary precautions have been taken to ensure their safety.(14) If an AC&H resource is discovered, the STOP WORK.(a) Notify the Assigned Supervisor.(b) Notify the site Environmental Coordinator. ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 13 of 27 (9) If it becomes necessary to use excavation methods other than those specified in the approved Excavation Permit, then STOP WORK and resubmit the Excavation Permit for revision and approval. (10) If unanticipated or unidentified items (including buried material to protect or warn workers of buried utilities) are encountered, then STOP WORK. (a) Notify the Assigned Supervisor. (b) Notify the Engineering Department, as appropriate. (c) The Assigned Supervisor shall evaluate the situation prior to allowing work to resume and shall ensure that the disposition is documented in the Corrective Action Program. (11) If any plant equipment is damaged due to excavation activities, then STOP WORK and notify the Control Room immediately. (a) Notify the Assigned Supervisor. (b) Initiate an Action Request. (12) Daily inspections of excavations, the adjacent areas, and protective systems shall be made by a competent person for evidence of a situation that could result in possible ins, indications of failure of protective systems, hazardous conditions, and indications of AC&H resources (see Attachment 5 for examples). A Competent Person shall be site during excavations. (a) Inspect prior to the start of work and as needed throughout the shift. (b) Inspect after every rainstorm or other hazard-increasing occurrence. (c) Inspections are required only when employee exposure can be reasonably anticipated .. (d) The daily inspection shall be signed and dated in the appropriate section of the excavation permit. (13) If the competent person finds evidence of a situation that could result in a possible in, indications of failure of protective systems, hazardous atmospheres, or other hazardous conditions, then remove exposed workers from the hazardous area until the necessary precautions have been taken to ensure their safety. (14) If an AC&H resource is discovered, the STOP WORK. (a) Notify the Assigned Supervisor. (b) Notify the site Environmental Coordinator. ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 14 of 27 (c) The Environmental Coordinator shall evaluate the situation and shall initiate communication with plant owner representatives and the SHPO, if deemed necessary. The Environmental Coordinator may allow work to resume only after the situation has been addressed, the disposition has been documented in the Corrective Action Program, and a course of action has been determined. (15) If oxygen deficiency (atmospheres containing less than 19.5 percent oxygen)OR A hazardous atmosphere could reasonably be expected to exist then test the atmosphere in the excavation before employees enter excavations greater than 4 feet in depth. (Refer to ACP 1411.11, Confined Space Entry)(16) If shoring is required, then it shall be of an approved manufactured type. The competent person shall be contacted to determine if shoring is an approved type.(17) Employees shall not work in excavations in which there is accumulated water, or in excavations, in which water is accumulating, unless adequate precautions have been taken to protect employees against the hazards posed by water accumulation.(a) The precautions necessary to protect employees adequately vary with each situation, and may include special support or shield systems to protect from cave-ins, water removal to control the level of accumulating water, or use of a safety harness and lifeline.(18) The walls and faces of all excavations and trenches five (5) feet or more in depth, in which personnel are exposed to danger from moving ground shall be shored, sheeted, braced, sloped or otherwise supported by means of sufficient strength to protect the personnel working within them.(a) Refer to Attachment 3 as a guide for sloping the sides of excavations.(b) Refer to Attachment 4 for minimum requirements for trench timbering. (19) Sliding trench shields may be used for the protection of personnel in lieu of a shoring system or sloping provided such trench shields give protection equal to or greater than the shoring or sloping required.(20) In excavations which personnel may be required to enter, excavated or other material shall be effectively shored or retained at least two (2) feet (.61 m) from the edge of the excavation. (21) Trenches four (4) feet or more in depth in which personnel are working shall have exit ladders or steps installed. Steps or ladders shall be located so as to require no more than twenty-five (25) feet of lateral travel from any point in the trench.ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 14 of 27 (c) The Environmental Coordinator shall evaluate the situation and shall initiate communication with plant owner representatives and the SHPO, if deemed necessary. The Environmental Coordinator may allow work to resume only after the situation has been addressed, the disposition has been documented in the Corrective Action Program, and a course of action has been determined. (15) If oxygen deficiency (atmospheres containing less than 19.5 percent oxygen) OR A hazardous atmosphere could reasonably be expected to exist then test the atmosphere in the excavation before employees enter excavations greater than 4 feet in depth. (Refer to ACP 1411.11, Confined Space Entry) (16) If shoring is required, then it shall be of an approved manufactured type. The competent person shall be contacted to determine if shoring is an approved type. (17) Employees shall not work in excavations in which there is accumulated water, or in excavations, in which water is accumulating, unless adequate precautions have been taken to protect employees against the hazards posed by water accumulation. (a) The precautions necessary to protect employees adequately vary with each situation, and may include special support or shield systems to protect from cave-ins, water removal to control the level of accumulating water, or use of a safety harness and lifeline. (18) The walls and faces of all excavations and trenches five (5) feet or more in depth, in which personnel are exposed to danger from moving ground shall be shored, sheeted, braced, sloped or otherwise supported by means of sufficient strength to protect the personnel working within them. (a) Refer to Attachment 3 as a guide for sloping the sides of excavations. (b) Refer to Attachment 4 for minimum requirements for trench timbering. (19) Sliding trench shields may be used for the protection of personnel in lieu of a shoring system or sloping provided such trench shields give protection equal to or greater than the shoring or sloping required. (20) In excavations which personnel may be required to enter, excavated or other material shall be effectively shored or retained at least two (2) feet (.61 m) from the edge of the excavation. (21) Trenches four (4) feet or more in depth in which personnel are working shall have exit ladders or steps installed. Steps or ladders shall be located so as to require no more than twenty-five (25) feet of lateral travel from any point in the trench. ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 15 of 27 (22) When excavations are left open, warning devices, barriers, barricades or guardrails should be placed to protect personnel adequately. (23) If excavation concerns are not addressed by this procedure, then refer to the applicable OSHA standards as identified in 29 CFR 1926 Subpart P, "Excavations." These standards can be located at www.osha..ov. (24) If a storm water construction permit is required, all condition of the National Pollutant Discharge Elimination System (NPDES) General Permit #2 must be adhered to. The conditions include, but are not limited to:* Filing a Notice of Intent to the IDNR.* Provide a public notice in at least two newspapers.

• Submit appropriate application fees.* Provide a written storm water pollution prevention plan for the activity.* Signatory requirements for construction permits require a principal executive officer of at least the level of vice-president.
• Disturbed areas shall be inspected at least once every seven days and within 24 hours of a storm event 0.5 inches or greater.3.8 ACCEPTANCE REQUIREMENTS AND RESTORATION (1) Prior to backfill, ensure that all Inspections, required by work documents, have been performed and that all associated Action Requests regarding degradation or damage to underground equipment have been dispositioned.

(2) All uncovered items shall be surveyed/located before backfilling and, as built locations shall be identified on the appropriate drawing(s). (3) If a storm water construction permit was required, soil stabilization must be performed. Stabilization could be re-seeding, mulching, or other means to reduce runoff.4.0 REQUIRED RECORDS (1) Excavation Permits shall be retained with the applicable work documents.

5.0 REFERENCES

(1) OSHA, Occupational Safety and Health Standards for the Construction Industry, 29 CFR 1926, Sections 416(a)(2), 650, 651, 652 and 653 (2) Safety Rule Book (3) CAP053469(4) Iowa Dept. of Natural Resources National Pollutant Discharge Elimination System (NPDES) General Permit #2 ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 15 of 27 (22) When excavations are left open, warning devices, barriers, barricades or guardrails should be placed to protect personnel adequately. (23) If excavation concerns are not addressed by this procedure, then refer to the applicable OSHA standards as identified in 29 CFR 1926 Subpart P, "Excavations." These standards can be located at www.osha.gov. (24) If a storm water construction permit is required, all condition of the National Pollutant Discharge Elimination System (NPDES) General Permit #2 must be adhered to. The conditions include, but are not limited to:

• Filing a Notice of Intent to the IDNR.
• Provide a public notice in at least two newspapers.
• Submit appropriate application fees.
• Provide a written storm water pollution prevention plan for the activity.
• Signatory requirements for construction permits require a principal executive officer of at least the level of vice-president.
• Disturbed areas shall be inspected at least once every seven days and within 24 hours of a storm event 0.5 inches or greater. 3.8 ACCEPTANCE REQUIREMENTS AND RESTORATION (1) Prior to backfill, ensure that all Inspections, required by work documents, have been performed and that all associated Action Requests regarding degradation or damage to underground equipment have been dispositioned.

(2) All uncovered items shall be surveyed/located before backfilling and, as built locations shall be identified on the appropriate drawing(s). (3) If a storm water construction permit was required, soil stabilization must be performed. Stabilization could be re-seeding, mulching, or other means to reduce runoff. 4.0 REQUIRED RECORDS (1) Excavation Permits shall be retained with the applicable work documents.

5.0 REFERENCES

(1) OSHA, Occupational Safety and Health Standards for the Construction Industry, 29 CFR 1926, Sections 416(a)(2), 650, 651, 652 and 653 (2) Safety Rule Book (3) CAP053469 (4) Iowa Dept. of Natural Resources National Pollutant Discharge Elimination System (NPDES) General Permit #2 ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 16 of 27 ATTACHMENT I Page 1 of 8 FORM, QF-1306. EXCAVATION PERMIT (Example only -use current revision)Form QF-1 306, Rev. 4 ACP 1408.29 Work Order: EXCAVATION PERMIT N/A PART 1, INITIATION Initiator: Date: Phone: Reason for Excavation Permit: Expected Width x Expected Length_= Square Footage 1 acre equals 43560 sq. ft. or 4900 sq. yds Expected Depth: FT.Start Date: Projected Completion Date: Equipment uncovered will remain in operation? D] Yes E] No Vital equipment will be uncovered? F1 Yes Q] No Excavation within the Protected Area? ED Yes F No Excavation within 20 feet of Security fence? El Yes El No Sand/Soils to be removed from the Protected Area? EL Yes QI No Soils to be disturbed are considered to be previously disturbed? El Yes EL No ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 16 of 27 ATTACHMENT 1 Page 1 of 8 FORM, QF-1306, EXCAVATION PERMIT (Example only -use current revision) Form QF-1306, Rev. 4 ACP 1408.29 EXCAVATION PERMIT Work Order: __________ _ N/A _____ _ PART 1, !NITtA TtON Initiator: I Date: I Phone: Reason for Excavation Permit: Expected Width x Expected Length = Square Footage 1 acre equals 43560 sq. ft. or 4900 sq. yds Expected Depth: FT. Start Date: Projected Completion Date: Equipment uncovered will remain in operation? DYes D No Vital equipment will be uncovered? DYes D No Excavation within the Protected Area? DYes D No Excavation within 20 feet of Security fence? DYes D No Sand/Soils to be removed from the Protected Area? DYes D No Soils to be disturbed are considered to be previously disturbed? DYes D No ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 17 of 27 ATTACHMENT I Page 2 of 8 FORM. QF-1306, EXCAVATION PERMIT (Example only -use current revision)Form QF-1306, Rev. 4, ACP 1408.29 EXCAVATION PERMIT Specific Location and Depth of Excavation (Provide Diagram): (For trenches specify route, width and depth)F Extra Pages Attached ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 17 of 27 ATTACHMENT 1 Page 2 of 8 FORM, QF-1306, EXCAVATION PERMIT (Example only -use current revision) Form QF-1306, Rev. 4, ACP 1408.29 EXCAVATION PERMIT Specific Location and Depth of Excavation (Provide Diagram): (For trenches specify route, width and depth) D Extra Pages Attached ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 18 of 27 ATTACHMENT 1 Page 3 of 8 FORM, QF-1306, EXCAVATION PERMIT (Example only -use current revision)Form QF-1306, Rev.4, ACP 1408.29 EXCAVATION PERMIT PART 2 DEVELOPMENT Document/ Drawing

References:

D Extra Pages Attached Locating Methods to be Used: El Extra Pages Attached Affected or Potentially Affected Equipment: El Extra Pages Attached Requirements: El Extra Pages Attached Approved Excavation Depth: FT.Approved Excavation VVidth/Length: FT.Approved Methods of Excavation: Approved by: Date: Permit Initiator ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 18 of 27 ATTACHMENT 1 Page 3 of 8 FORM, QF-1306, EXCAVATION PERMIT (Example only -use current revision) Form QF-1306, Rev.4, ACP 1408.29 EXCAVATION PERMIT PART 2 DEVELOPMENT Document! Drawing

References:

D Extra Pages Attached Locating Methods to be Used: D Extra Pages Attached Affected or Potentially Affected Equipment: D Extra Pages Attached Requirements: D Extra Pages Attached Approved Excavation Depth: _________________ FT. Approved Excavation Width/Length: _______________ FT. Approved Methods of Excavation: _________________ _ Approved by: _________________ Date: _____ _ Permit Initiator ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 19 of 27 ATTACHMENT I Page 4 of 8 FORM, QF-1306, EXCAVATION PERMIT (Example only -use current revision)Form QF-1306, Rev. 4, ACP 1408.29 PART 3 REVIEWS Engineering EXCAVATION PERMIT Additional Requirements I El Extra Pages Attached Radioloqical Protection Additional Requirements I Ll Extra Pages Attached ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 19 of 27 ATTACHMENT 1 Page 4 of 8 FORM, QF-1306, EXCAVATION PERMIT (Example only -use current revision) Form QF-1306, Rev. 4, ACP 1408.29 EXCAVATION PERMIT PART 3 REVIEWS Engineering Additional Requirements I o Extra Pages Attached Radiological Protection Additional Requirements I o Extra Pages Attached ADMINISTRATIVE CONTROL PROCEDURE 'K= ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 20 of 27 ATTACHMENT I Page 5 of 8 FORM, QF-1306, EXCAVATION PERMIT (Example only -use current revision)Form QF-1306, Rev. 4, ACP 1408.29 Safety EXCAVATION PERMIT Additional Requirements 1 L Extra Pages Attached Security Additional Requirements I 0 Extra Pages Attached ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 20 of 27 ATTACHMENT 1 Page 5 of 8 FORM, QF-1306, EXCAVATION PERMIT (Example only -use current revision) Form QF-1306, Rev. 4, ACP 1408.29 EXCAVATION PERMIT Safety Additional Requirements I D Extra Pages Attached Security Additional Requirements I D Extra Pages Attached ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 21 of 27 ATTACHMENT 1 Page 6 of 8 FORM. QF-1306, EXCAVATION PERMIT (Example only -use current revision)Form QF-1306, Rev. 4, ACP 1408.29 Operations EXCAVATION PERMIT Additional Requirements E Ll Extra Pages Attached Environmental Additional Requirements I 0 Extra Paaes Attached Additional Reauirements I F] Extra Paaes Attached ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 21 of 27 ATTACHMENT 1 Page 6 of 8 FORM, QF-1306, EXCAVATION PERMIT (Example only -use current revision) Form QF-1306, Rev. 4, ACP 1408.29 EXCAVATION PERMIT Operations Additional Requirements I D Extra Pages Attached Environmental Additional Requirements I D Extra Pages Attached , i ADMINISTRATIVE CONTROL PROCEDURE .> ACP 1408.29 Rev. 8 EXCAVATION & TRENCHING CONTROLS Page 22 of 27 ATTACHMENT 1 Page 7 of 8 FORM, QF-1306, EXCAVATION PERMIT (Example only -use current revision)Form IF-i306, Rev. 4, ACP 1408.29 EXCAVATION PERMIT Daily Inspection Performed by: Date: i ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 22 of 27 ATTACHMENT 1 Page 7 of 8 FORM, QF-1306, EXCAVATION PERMIT (Example only -use current revision) Form QF-1306, Rev. 4, ACP 1408.29 EXCAVATION PERMIT Daily Inspection Performed by: Date: ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 23 of 27 ATTACHMENT 1 Page 8 of 8 FORM, QF-1306! EXCAVATION PERMIT (Example only -use current revision)Form QF-1306, Rev. 4, ACP 1408.29 PART 4 APPROVALS EXCAVATION PERMIT Department Approver Date Engineering N/A Li Operations N/A _ _Radiological Protection N/A El Environmental N/A E]Safety N/A E]Security N/A E]PART 5 NOTIFICATIONS Department Required Name/Title Phone No. Notified Date/Time Engineering LI El Operations* LI WCC E]CR QI Rad. Prot. EL EL Environmental L]Safety E] E]Security L] L_Maint. Mgr. E] El MOP El El*NOTE: Notify WCC / Control Room on every additional day excavation continues. DAEC Site-Specific Additional Notifications: Department Required Name/Title Phone No. Notified Date/Time Operations* Fi WCC LI CR LI Operations* El WCC LI cc EL Operations* LI WCC E]CR El Operations* El WCC Li CR EL PART 6 MAINTENANCE MANAGER I MANAGER OF PROJECTS APPROVAL Approved by: Maintenance Manager/Designee Date PART 7 ASSIGNED SUPERVISOR REVIEW I have reviewed and understand the requirements of this Excavation Permit:.Reviewed by:Assigned Supervisor /Date ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 23 of 27 ATTACHMENT 1 Page 8 of 8 FORM, QF-1306, EXCAVATION PERMIT (Example only -use current revision) Form QF-1306, Rev. 4, ACP 1408.29 EXCAVATION PERMIT PART 4 APPROVALS Dep_artment Approver Date Engineering N/A 0 Operations N/A 0 Radiological Protection N/A 0 Environmental N/A 0 Safety N/A 0 Security N/A 0 PART 5 NOTIFICATIONS Department Required NamelTitle Phone No. Notified DatelTime Engineering 0 0 Operations* 0 WCC 0 CR 0 Rad. Prot. 0 0 Environmental 0 Safety 0 0 Security 0 0 Maint. Mgr. 0 0 MOP 0 0 *NOTE: Notify WCC / Control Room on every additional day excavation continues. fi DAEC Site-Speci IC Additional Notifications: Department Required NamelTitle Phone No. Notified DatelTime Operations* 0 WCC 0 CR 0 Operations* 0 WCC 0 CC 0 Operations* 0 WCC 0 CR 0 Operations* 0 WCC 0 CR 0 PART 6 MAINTENANCE MANAGER I MANAGER OF PROJECTS APPROVAL Approved by: _--:-______ --___ -------/ ______ _ Maintenance Manager/Designee Date PART 7 ASSIGNED SUPERVISOR REVIEW I have reviewed and understand the requirements of this Excavation Permit: . Reviewed by: _______________ / ______ _ Assigned Supervisor Date ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 Rev. 8 EXCAVATION & TRENCHING CONTROLS Page 24 of 27 ATTACHMENT 2 DETECTION TOOLS (EXAMPLES) Tool Positives Negatives Local State buried utility- Accurately marks (flags) Needs to have some idea related cables and piping identified buried utility-related where the buried components components service cables and piping components are located. Buried electrical in a relatively fast manner components have to be energized Ground Penetrating Radar Identified buried components For buried components to be (GPR) in a relatively fast manner. seen, they have to be one inch in width or diameter for each foot below ground. GPR requires a Purchase Order and scheduling of service provider. GPR needs experienced operator to interpret the data.RD Radio Detection or Ditch Easy to use -light weight Will only locate cables. The Witch cable has to be energized and passing current.Phone Co. Able to locate fiber-optic and Primarily to locating phone copper phone cables. company cables. Also able to locate buried power cables.Able to locate buried power Required scheduling service cables days in advance.Hand Digging Relatively high positive control Slow process and can still result in damage to cables.Vacuum Truck Positive control Does not work as well in clay or compacted soils as it does in sandy soils.Sluice Device, Soil removal by Positive control Relocates soils only and soil pressurized water stream removal by some other means is necessary. Creates wet excavation area.ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 24 of27 ATTACHMENT 2 DETECTION TOOLS (EXAMPLES) Tool Positives Negatives Local State buried utility-Accurately marks (flags) Needs to have some idea related cables and piping identified buried utility-related where the buried components components service cables and piping components are located. Buried electrical in a relatively fast manner components have to be energized Ground Penetrating Radar Identified buried components For buried components to be (GPR) in a relatively fast manner. seen, they have to be one inch in width or diameter for each foot below ground. GPR requires a Purchase Order and scheduling of service provider. GPR needs experienced operator to interpret the data. RD Radio Detection or Ditch Easy to use -light weight Will only locate cables. The Witch cable has to be energized and passing current. Phone Co. Able to locate fiber-optic and Primarily to locating phone copper phone cables. company cables. Also able to locate buried power cables. Able to locate buried power Required scheduling service cables days in advance. Hand Digging Relatively high positive control Slow process and can still result in damage to cables. Vacuum Truck Positive control Does not work as well in clay or compacted soils as it does in sandy soils. Sluice Device, Soil removal by Positive control Relocates soils only and soil pressurized water stream removal by some other means is necessary. Creates wet excavation area. ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 25 of 27 ATTACHMENT 3 APPROXIMATE ANGLE OF REPOSE FOR SLOPING OF SIDES OF EXCAVATIONS Note: Clays, Silts, Loams or Nonnomo-geneous Soils Require Shoring and Bracing.The presence of ground water requires special treatment.-Cý(D 0 >a_0-O 0)CU a )Cu d CD<- cm'CU C.-E)0.C- l) COj- COI CL 0 O0-Cn)-0,0 0)r- D a) (D-o C ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 25 of 27 ATTACHMENT 3 APPROXIMATE ANGLE OF REPOSE FOR SLOPING OF SIDES OF EXCAVATIONS III -0) > ca ..... -0>-CD 0) ..... N 0. -0) "0 ca 0 0. -III V Note: Clays, Silts, roC ::::l 0) cn rn..-.. ..... <"> ..ecao 0>0) :=111 ca<"> Loams or Nonnomo-U)1IIa> C ..... "000) ..e<"> "0 0) geneous Soils Require <(0) 0) III 0) U)-0) "0 - ..-0) ..... 0) 0) "'C ** -::-"0 "0 0> Shoring and Bracing. "0"0 :;; 0> 0) U .... 0) 0) O)N..-C C 0) C>_ .... <"> .... --v ::::lca"O The presence of ground UCD U ..-oU) E ..... 0) ca -EO)LO ca ..-0) water requires special 0...->v 0."0 0) °ca-...!..(/)- treatment.

.= U"O 0> E .. U -0 0 ..... cO) oN 0) ..... ..-o ca 0) 0) ..-U) 0 ca"O --o .. OU)"O s:.3N 0..-0::._..-

ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 26 of 27 ATTACHMENT 4 MINIMUM REQUIREMENTS FOR TRENCH SHORING Size and spacing of members Uprights Stringers Cross braces*MaximumWidth of trench spacing Kind or Depth condition of Minimum Maximum Minimum Maximum Up to 3 to 6 to 9 to 12 12 to 15 Hori-of earth dimension spacing dimension spacing 3 ft 6 ft 9 ft ft ft Vertical zontal trench Feet Inches Feet Inches Feet In. In. In. In. In. Feet Feet 5-10 Hard Compact ......... 3x4or2x6 6 2x6 4x4 4x6 6x6 6x8 4 6 Likely to Crack ......... 3x4or2x6 3 4x6 4 2x6 4x4 4x6 6x6 6x8 4 6 Soft, sandy or Close filled ......................... 3x4or2x6 sheeting 4x6 4 4x4 4x6 6x6 6x8 8x8 4 6 Hydrostatic Close pressure .................. 3x4or2x6 sheeting 6x8 4 4x4 4x6 6x6 6x8 8x8 4 6 10-15 Hard ........................ 3x4or2x6 4 4x6 4 4x4 4x6 6x6 6x8 8x8 4 6 Likely to Crack ......... 3x4or2x6 2 4x6 4 4x4 4x6 6x6 6x8 8x8 6 Soft, sandy or Close filled ........................ 3x4or2x6 sheeting 4x6 4 4x6 6x6 6x8 8x8 8x10 4 6 Hydrostatic Close pressure ........................... 3x6 sheeting 8x10 4 4x6 6x6 6x8 8x8 8x10 4 6 15-20 All kinds or Close conditions ......................... 3x6 sheeting 4x12 4 4x12 6x8 8x8 8x10 10x10 4 6 Over All kinds or Close 20 conditions ......................... 3x6 sheeting 6x8 4 4x12 8x8 8x10 10x10 10x12 4 6*Trench jacks may be used in lieu of, or in combination with, cross braces. Shoring is not required in solid rock, hard shale, or hard slag.Where desirable, steel sheet piling and bracing of equal strength may be substituted for wood...

.. ACP 1408.29 EXCAVATION

& TRENCHING CONTROLS Rev. 8 Page 26 of 27 ATTACHMENT 4 MINIMUM REQUIREMENTS FOR TRENCH SHORING Size and spacing of members Uprights Stringers Cross braces* Maximum Width of trench spacing Kind or Depth condition of Minimum Maximum Minimum Maximum Up to 3 to 6 to 9 to 12 12 to 15 Hori-of earth dimension spacing dimension spacing 3ft 6ft 9ft ft ft Vertical zontal trench Feet Inches Feet Inches Feet In. In. In. In. In. Feet Feet 5-10 Hard Compact... ...... 3x40r2x6 6 2x6 4x4 4x6 6x6 6x8 4 6 Likely to Crack ......... 3x40r2x6 3 4x6 4 2x6 4x4 4x6 6x6 6x8 4 6 Soft, sandy or Close filled ......................... 3x40r2x6 sheeting 4x6 4 4x4 4x6 6x6 6x8 8x8 4 6 Hydrostatic Close pressure .................. 3x40r2x6 sheeting 6x8 4 4x4 4x6 6x6 6x8 8x8 4 6 10-15 Hard ........................ 3x40r2x6 4 4x6 4 4x4 4x6 6x6 6x8 8x8 4 6 Likely to Crack ......... 3x40r2x6 2 4x6 4 4x4 4x6 6x6 6x8 8x8 6 Soft, sandy or Close filled ........................ 3x40r2x6 sheeting 4x6 4 4x6 6x6 6x8 8x8 8x10 4 6 Hydrostatic Close pressure ........................... 3x6 sheeting 8x10 4 4x6 6x6 6x8 8x8 8x10 4 6 15-20 All kinds or Close conditions ......................... 3x6 sheeting 4x12 4 4x12 6x8 8x8 8x10 10x10 4 6 Over All kinds or Close 20 conditions ......................... 3x6 sheeting 6x8 4 4x12 8x8 8x10 10x10 10x12 4 6 *Trench jacks may be used in lieu of, or in combination with, cross braces. Shoring is not required in solid rock, hard shale, or hard slag. Where desirable, steel sheet piling and bracing of equal strength may be substituted for wood. ADMINISTRATIVE CONTROL PROCEDURE ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 27 of 27.ATTACHMENT 5 GUIDANCE FOR AC&H RESOURCE IDENTIFICATION Burial sites, mounds Earth piles, piles of smaller stones Bones and Bone Tools Animal, Human, tools made from bone might include digging tools, hooks, pipes Pottery Clay storage vessels, ceramic vases (intact or pieces), glass, several pieces found together Jewelry Buttons, metal buckles, beads Stone Tools and Projectile Points Axes, arrow heads, spear heads, knives Metals Coins, guns/gun pieces, buttons, buckles Brick Clay structures, foundations Wood Pieces Bow/arrows, spears, tool handles, wood pieces with wood or square nails Flacks of Stone Piles of small sharp stone pieces left from making stone tools ACP 1408.29 EXCAVATION & TRENCHING CONTROLS Rev. 8 Page 27 of 27 ATTACHMENT 5 GUIDANCE FOR AC&H RESOURCE IDENTIFICATION Burial sites, mounds Earth piles, piles of smaller stones Bones and Bone Tools Animal, Human, tools made from bone might include digging tools, hooks, pipes Pottery Clay storage vessels, ceramic vases (intact or pieces), glass, several pieces found together Jewelry Buttons, metal buckles, beads Stone Tools and Projectile Points Axes, arrow heads, spear heads, knives Metals Coins, guns/gun pieces, buttons, buckles Brick Clay structures, foundations Wood Pieces Bow/arrows, spears, tool handles, wood pieces with wood or square nails Flacks of Stone Piles of small sharp stone pieces left from making stone tools Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D. 1 FPL Energy Letter, w/ application R. L. Anderson, Vice President Duane Arnold Energy Center, to W. Hieb, NPDES Section, IDNR, "Waste Water Discharge NPDES Renewal" dated December 31, 2008, NG-08-0978. Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D.1 FPL Energy Letter, wI application R. L. Anderson, Vice President Duane Arnold Energy Center, to W. Hieb, NPDES Section, IDNR, "Waste Water Discharge NPDES Renewal" dated December 31, 200B, NG-OB-097B. FPL Energy Duane Arnold, LLC 3277 DAEC Road Palo, Iowa 52324 FPL Energy.Duane Arnold Energy Center December 31, 2008 NG-08-0978 Wendy Hieb NPDES Section Iowa Department of Natural Resources Wallace State Office Building Des Moines, IA 50319 Duane Arnold Energy Center DAEC File A-221 Waste Water Discharge NPDES Renewal Please find the enclosed application for renewal of FPL Energy Duane Arnold's National Pollutant Discharge Elimination System (NPDES) permit # 57-00-1-04. As my staff has previously discussed with you, in early 2007 the site had identified a water source that is part of the circulating water system which bypasses the normal circulating water system flow path. The source of this water is outflow from an inline corrosion monitor, inline pH monitors and the Pump House sump pumps. Periodically, the General Service Water (GSW)strainer following a backwash of the strainer also flows through this path.During the process of chlorination of the circulating system the discharge is de-chlorinated. The flow of this identified source bypasses the de-chlorination system. The bypass water flows 240 feet outside through a storm drain system and runs an additional 160 feet at ground level. At this point, it mixes with ouffall 001 for the remaining 1500 feet to the Cedar River.The approximate flow rate from this source is 15 to 25 gallons per minute of continuous flow and an additional 100 gpm for 6 minutes three times per day. See the enclosed map outlining the flow path.if you have any questions, please contact Jerald Hogan at (319) 851-7606. Jerald will be able to provide you with any additional information you might need in order to process our renewal.Sincerely, Richard L. Andersoin Vice President, Duane Arnold Energy Center FPL Energy Duane Arnold, LLC Enclosures cc: IRMS, Jerald Hogan, Neal McKenney FPLEnergy. Duane Arnold Energy Center December 31,2008 Wendy Hieb NPDES Section Iowa Department of Natural Resources Wallace State Office Building Des Moines, IA 50319 Duane Arnold Energy Center DAEC File A-221 Waste Water Discharge NPDES Renewal fPl Energy Duane Arnold, LLC 3277 DAEC Road Palo, Iowa 52324 NG-08-0978 Please find the enclosed application for renewal of FPL Energy Duane Arnold's National Pollutant Discharge Elimination System (NPDES) permit # 57-00-1-04. As my staff has previously discussed with you, in early 2007 the site had identified a water source that is part of the circulating water system which bypasses the normal circulating water system flow path. The source of this water is outflow from an inline corrosion monitor, inline pH monitors and the Pump House sump pumps. Periodically, the General Service Water (GSW) strainer following a backwash of the strainer also flows through this path. During the process of chlorination of the circulating system the discharge is de-chlorinated. The flow of this identified source bypasses the de-chlorination system. The bypass water flows 240 feet outside through a storm drain system and runs an additional 160 feet at ground level. At this point, it mixes with outfall 001 for the remaining 1500 feet to the Cedar River. The approximate flow rate from this source is 15 to 25 gallons per minute of continuous flow and an additional 100 gpm for 6 minutes three times per day. See the enclosed map outlining the flow path. If you have any questions, please contact Jerald Hogan at (319) 851-7606. Jerald will be able to provide you with any additional infori'nation you might need in order to process our renewal. Sincerely. Vice President, Duane Arnold Energy Center FPL Energy Duane Arnold, LLC Enclosures cc: IRMS, Jerald Hogan. Neal McKenney DNR Form 542-1376 IOWA DEPARTMENT OF NATURAL RESOURCES NPDES PERMIT APPLICATION FORM 1 FOR INDUSTRIAL FACILITIES OWINER INFORMATION FACILITY INFORMATION OPERATOR INFORMATION FACILITY LOCA TION CONTACT PERSON OPERATING PERMITS AND LICENSES ADDITIONAL PERMITTING FORM 1 -GENERAL INFORMATION NAME STREET ADDRESSFPL Energy Duane Arnold, LLC 700 Universe Boulevard P.O. BOX CITY STATE ZIP CODE P.O. 14000 Juno Beach FL 33480-0420 NAME STREET ADDRESS FPL Energy Duane Arnold, LLC 3277 Daec Road P.O. BOX CITY STATE ZIP CODE Palo Iowa 52324 NAME MAILING ADDRESS FPL Energy Duane Arnold 3277 DAEC Road TELEPHONE CITY STATE ZIP CODE 3198517606 Palo Iowa 52324 COUNTY: Linn LATITUDE LONGITUDE SECTION TOWNSHIP RANGE DEGREES MINUTES SECONDS DEGREES MINUTES SECONDS 9& 10 84N 8W 42 6 6 91 46 25 NAME TITLE TELEPHONE Jerald Hogan Senior Environmental Analyst 319 851 7606 ADDRESS CITY STATE ZIP CODE 3277 DAEC Road Palo IA 52324 Lisiall nvibnmetaipermts r lienss frrn ederl, tqteor pcaik~ecies i~qwre w j~ie&rethisfaality(it RCAKUCPS, at ue) I a~emi hs e~ apledfo bt ~a nt etb~n ssedVyii ~ppief~~s wie issue dte. ii TYPE OF PERMIT PERMIT NO. ISSUE DATE ISSUING AGENCY NPDES 57-00-1-04 07/06/2004 IDNR Water Supply 5715150 12/10/2007 IDNR Water Use 3046-MR5 07/01/2002 IDNR Water Use 3533-R3 03/14/2004 IDNR See Attachment A YES NO Do you or will you withdraw water from a well, watercourse, or lake? [-Do you or will you inject water below ground other than to a septic tank? .Is this a proposed stationary source which will potentially emit air pollutants []regulated under the Clean Air Act or may be located in a nonattainment area?Is this facility located on Indian lands? []IJ yu ~swe yesto ny J~'h-peeigqesinaanyeeo rprzitp riEiLfdityYulta 1.Form I -Page 1 DNR Form 542-1376 IOWA DEPARTMENT OF NATURAL RESOURCES NPDES PERMIT APPLICATION FORM 1 FOR INDUSTRIAL FACILITIES FORM 1 -GENERAL INFORMATION NAME STREET ADDRESS OWNER FPL Energy Duane Arnold, LLC 700 Universe Boulevard INFORMATION P.O. BOX CITY STATE P.O. 14000 lunD Beach FL NAME STREET ADDRESS FACILITY FPL Energy Duane Arnold, LLC 3277 Daec Road INFORMATION P.O. BOX CITY STATE Palo Iowa INAME MAILING ADDRESS OPE!/A.TOk FPL Energy Duane Arnold 3277 DAEC Road INFORMATION TELEPHONE CITY STATE 3198517606 Palo Iowa COUNTY: Linn LATITUDE FACILITY SECTION I TOWNSHIP RANGE DEGREES MINUTES I SECONDS DEGREES LOCATION 9& 10 . 84N 8W 42 6 6 91 NAME TITLE CONTACT Jerald Hogan Senior Environmental Analyst PERSON ADDRESS CITY STATE 3277 DAEC Road Palo IA ZIP CODE 33480-0420 ZIP CODE 52324 ZIP CODE 52324 LONGITUDE MINUTES 46 TELEPHONE 319851 7606 ZIP CODE 52324 SECONDS 25 OPERATiNG PERMITS AND LICENSES TYPE OF PERMIT PERMIT NO. ISSUE DATE ISSUING AGENCY NPDES 57-00-1-04 ' 07/06/2004 Water Supply 5715150 12/10/2007 Water Use 3046-MRS 07/0112002 Water Use 3533-R3 03114/2004 See Attachment A Do you or will you withdraw water from a well, watercourse, or lake? ADDITIONAL Do you or win you inject water below ground other than to a septic tank? PERMITTING Is this a proposed stationary source which will potentially emit air pollutants regulated UDder the Clean Air Act or may be located in a nonattainment area? Is this facility located on Indian lands? Form 1 -Page 1 IDNR IDNR IDNR IDNR YES NO o o o o sic CODES NA TURE OF BUSINESS FACILITY IMPROVEMENTS LOCATION MAP Number Description Number Description 491 1 Electric Companies..... Number Description Number Description besrib lrefl t~ nauret~fthe uiescnutda hsficlt. -- ----Electric generation through a boiling water reactor.fatmn eq Inpe`14 deScr'ib~_e rt uirmi d'escribe-tirepro~ii -a" -list the, i'~auired -and projected final'-"ýii N/A You 0us tahama ,arger trn~4"+/-1 ~.lbldt i i4tefaftcevg-5tre4~~~fl(S% age-- :§-2 same Inumb~eused ýIsew~e'.:- t Form I -Page 2 SIC CODES NATURE OF BUSINESS FACILITY iMPROVEMENTS LOCATION MAP Number Description Number Description 4911 Electric Companies Number Description Number Description 'J;l;lj; Electric generation through a boiling water reactor. Form 1-Page 2 RAW WA TER SOURCE SOURCE MILLION GALLONS PER DAY MUNICIPAL WATER SUPPLY N/A PRIVATE WATER SUPPLY N/A SURFACE WATER 12.26 GROUNDWATER 1.68 PRECIPITATION NI/A WA TER USAGE WITHIN PLANT WA TER LOSSES USE MILLION USE MILLION GALLONS PER DAY GALLONS PER DAY COOLING WATER 1.59 SANITARY SYSTEM .010 BOILER FEED WATER .036 OTHER (specify)PROCESS WATER .036 LIST DISCHARGES OR LOSSES OTHER THAN DIRECT DISCHARGES TO WATERS MILLION OF THE STATE GALLONS PER DAY NAME OF MUNICIPAL WASTE TREATMENT SYSTEMOn-site waste treatment is used N/A NAME OF WASTE HAULERMiene Septic Services, Inc. hauls slkdge .00023 INTERNAL CONSUMPTION Domestic Water Usage .001 EVAPORATION Cooling Towers 10.98OTHER (specify) IYoo ast attach a 4!e'rrigh v~gte'~ aeitk~S Mw'i pU ctiSsi, wasewi&Uy' bYbe~iylr akbility~omedis ~rge watei, ad stormwateir. A zcptbl ~~ki f LINE DRA WING Form 1 -Page 3 RAW WATER SOURCE WATER USAGE WITHIN PLANT WATER LOSSES LINE DRAWING SOURCE MILLION GALLONS PER DAY MUNICIPAL WATERSUPPLY N/A PRN A TE WATER SUPPLY NIA SURFACE WATER 12.26 GROUNDWATER 1.68 PRECIPITATION N/A USE MILLION USE GALLONS PER DAY COOLING WATER 1.59 SANITARY SYSTEM BOILER FEED WATER .036 OTHER (specify) PROCESS WATER .036 LIST DISCHARGES OR LOSSES 011IER THAN DIRECT DISCHARGES TO WATERS OF THE STATE NAME OF MUNICIPAL WASTE TREATMENT SYSTEM On-site waste treatment is used NAME OF WASTE HAULER Miene Septic Services, Inc. hauls shuige INTERNAL CONSUMPTION Domestic Water Usage EV APORA TION Cooling Towers OTHER (specify) Fonn I-Page 3 MILLION GALLONS PER DAY .010 MILLION GALLONS PER DA Y N/A .00023 .001 10.98 DNR Form 542-1382 IOWA DEPARTMENT OF NATURAL RESOURCES NPDES PERMIT APPLICATION FORM 5 -CERTIFICATION FOR INDUSTRIAL FACILITIES FACILI I Y NAME: FPIL Energy Luane Arnold _ FPKMI I NUMII-tK:

• [-UU-1-U4 Indicate which industrial NPDES application forms you have completed and are submitting:

[ Form 1 -General information[ Form 2 -Facilities which do not Discharge Process Wastewater[ Form 2F -Storm water Associated with Industrial Activity (must complete BOTH certifications below)[ Form 3 -Facilities Which Discharge Process Wastewater, Existing Sources El Form 4 -Facilities Which Discharge Process Wastewater, New Sources[ Form 5- Industrial Certification F-1 SuDplement -TDS and Chloride Data LoI( I I1"1 /- I IUr "i;ALL APPLICANTS MUST COMPLETE THE FOLLOWING CERTIFICATION. I certify under penalty of law that this document and each of the forms indicated above as being part of this application were prepared under my direct supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the information, the information is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. NAME OFFICIAL TITLE Richard A Site Vice President TELEPHONE NUMBER 319-851-7568 (.* k Upon request of the permitting authority, you must submit any other information necessary to assess wastewater treatment practices at the treatment works or identify appropriate permitting requirements. Form 5- Page 1 DNR Form 542-1382 IOWA DEPARTMENT OF NATURAL RESOURCES NPDES PERMIT APPLICATION FORM 5 -CERTIFICATION FOR INDUSTRIAL FACILITIES Indicate which rgj Form 1 -General information o Form 2 -Facilities which do not Discharge Process Wastewater {'gj Form 2F -Storm water Associated with Industrial Activity (must complete BOTH certifications below) rgj Form 3 -Facilities Which Discharge Process Wastewater, Existing Sources o Form 4 -Facilities Which Discharge Process Wastewater, New Sources {'gj Form 5 -Industrial Certification o Supplement -TDS and Chloride Data MUST COMPLETE THE FOLl.OWlNG CERTIFICATION. I certify under penalty of law that this document and each of the forms indicated above as being part of this application were prepared under my direct supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the information, the information is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submittin false information, includi the of fine and nt for knowing violations. 319-851-7568 OFFICIAL TITLE Site Vice President DATE /2. Upon request of the permitting authority, you must submit other information necessary to assess wastewater treatment practices at the treatment works or identify anr\rnr\ri requirements. Form 5 -Page 1 DNR Form 542-1382 CERTIFICATION 2: APPLICANTS SUBMITTING FORM 2F MUST COMPLETE THE FOLLOWING CERTIFICATION. I certify under penalty of law that the outfall(s) covered by the enclosed Form 2F been tested or evaluated for the presence of non storm water discharges, and that all non storm water discharges from the outfall(s) included in Form 2F are identified in either an accompanying Form 2 or Form 3.NAME OFFICIAL TITLE Richard Anderson Site Vice President TELEPHONE NUMBER 319-851-7568 SEND COMPLETED APPLICATION FORMS TO: IOWA DEPARTMENT OF NATURAL RESOURCES STEVE WILLIAMS, NPDES SECTION WALLACE STATE OFFICE BUILDING 502 EAST 9 T" STREET DES MOINES, IA 50319 Form 5 -Page 2 DNR Form 542-1382 CERTIFICATION 2: APPLICANTS SUBMITTING FORM 2F MUST COMPLETE THE FOLLOWING CERTIFICATION. I certify under penalty of law that the outfall(s) covered by the enclosed Form 2F been tested or evaluated for the presence of non storm water discharges, and that all non storm water discharges from the outfall(s) included in Form 2F are identified in either an accompanying Form 2 or Form 3. NAME OFFICIAL TITLE Richard Anderson Site Vice President SIGNA DATE SEND COMPLETED APPLICATION FORMS TO: IOWA DEPARTMENT OF NATURAL RESOURCES STEVE WILLIAMS, NPDES SECTION WALLACE STATE OFFICE BUILDING 502 EAST 9THSTREET DES MOINES, IA 50319 Form 5 -Page 2 DNR Form# 542-1380 IOWA DEPARTMENT OF NATURAL RESOURCES NPDES PERMIT APPLICATION FORM 2F FOR INDUSTRIAL FACILITIES FORM 2-F -STORM WATER ASSOCIATED WITH INDUSTRIAL ACTIVITY L Outfall LocationWorac hu"aIJ j;ti~ aiue~~xglid ~fisl ~er~ a~~.A. Outfall Number B. Latitude C. Longitude D. Receiving Stream Name 001 42 5 49 91 46 21 Cedar River D02 42 6 9 91 46 15 Cedar River II. Improvements ~~~A. Ar you n4 rqurdy n FedeItae orbi uliitl ee n;meeRiin hd'fr t~toIuPgrdn r~eaih~I NJ-atr W..eiirYn: rprcicso ayethrnB'riimna porasWic a 6dc eicarb ociedi i'aptat~i~ i~i inlues ht s o-1 imied to, p t icbiidition idi`i~ra4 drhor mn't orider ~frmn~oipa~ t~iai~oi Rf hcilityc 1. Identification of Conditions

2. Affected Outfalls 4. Final Compliance Date Agreements, Etc. Number Source of Discharge

3. Brief Description of Project required projected N/A N/A N/A N/A i.:IOu may auaco, aa.ouionai sneets a~ese ng any aononai waterpllution (or oier. environmental proects wcn wmayalec your Ot-.a rg) yo_..i aow haaye under.ay 6 r which you plan. Idicate whetier each pro snowunderi y.orpned, hediA: fom r eto .. : ..:;.,.:.: .: :::,: a , ..ii:: :,;;pqn ~ s ýji.: -i :2i i d !t:l.i -: :. .: i::::::::::

[:.: 111. Site Drainage Map pa-ac~ hst dranag ma. R--.tpopgraphJic Fap is.T' iýaýilbe dcPi aih ui oitkearkiddgesrotr edabýd, %. ajt s o do q.;eoa.P ý itrbOiA iiittowared6c e tawaevnfp dispsa Bsgiaatoiras eah"siigsrcal ebtp usn 'i n s.t1'. areinece ngru Form 2F -Page 1 DNR Form # 542-1380 IOWA DEPARTMENT OF NATURAL RESOURCES NPDES PERMIT APPLICATION FORM 2F FOR INDUSTRIAL FACILITIES of Project Form 2F -Page 1 Discharge 001 IV. Narrative Description of Pollutant Sources A. for e n~tfl, prord arie ae~tcr~n uldinig b ot.l 3 and:i si~ll~tet6lsxi~~~a ~ LifiIOutfall Area of Impervious Surface Total Area Drained Outfall Area of Impervious Surface Total Area Drained Number (provide units) (provide units) Number (provide units) (provide units)001 220,000 ft2 1,000,000 ft2 D02 390,000 ft2 2,000,000 ft2 Materials management practices at DAEC consist of using the warehouse (indoors) for all materials which could wash to the storm ins. No dry materials are stored outdoors.In the spring of 2007 and 2008 a licensed contractor applied herbicide to the gravel areas of the site switchyard. Du Pont's Krovar, Karmex, Oust, and Razor Pro C -tFres manou emen pro. ie s he ..ati .ad , dosist of using sth wrehus an(.indoors) c.l wash to the storm In the aprnd deriovof 00 ad 00 tratlic!ene sotorm actor appi~ed hrincidu tegavlaeso the sit swthad DuPont's rovri~e Karex dist and Razor~ Profiiear~ ocn~r aidleutinaehsosl f pyso 4Pr li wasteskifii _%pwrs -p u deanti4aormw 1 Outfall Treatment List Codes from Number Table 2F-1 001 Chlorinated for algae control 2-F 001 Dechlorination occurs prior to discharging 2-E 002 Grinding, and aerobic digestion occurs 1-L & 5-A 002 Chlorinated April through October 2-F V. Non-storm water Discharges I I Be!oPKYVid description-;pVV ofah "etrg m--L o r, .r.c',1"jh ' -: 6' ý; P 4'~.6te:.Allappbc~~~~~~~i:-ý S!~nitn lýlrn E~zutCri~ nFor- t'ac~cefnoi~stornppiq.hm!ý Oate dicagsa tl 7 M

• nV e'tteaudt it N~ mixes ito 00 saer. .ac.Sigifian t nekiolpil In Julybe 2006 a00 slUricacidtan lygeaked Lapproiately 1000rme gallonsintof th ctonrmetentapinmento berm.Acotrac cleangu inoecrha calerd to dclanrugte spoinled material02.

Onlyo atfew gaalplonefcdwareasdt the icagsfounvutironmentiduing. The inthial identioficatin ofath leak.SinfcnLekorSil n Setembr200 som petoleu cotamiatedsoilwas dentfie undrneah a oncrte.sructre.Delue Trnsfomer.it).hic as be6iing: replaced.W_.ýnw Th"olwsrmvdadsipe fst yCenHros Form 2F -Page 2 Discbarge 001 2006 a sulfuric acid tank approximately 1000 gallons into the concrete containment berm. A contract clean-up crew was to clean up the spilled material. Only a few gallons of acid was released to the environment during the initial identification of the September 2007 some petroleum contaminated soil was identified underneath a concrete structure (Deluge Transformer Pit) which being replaced. The soil was removed and shipped off site by Clean Harbors. Form 2F -Page 2 Discharge 001 VII. Discharge Information W I -4I Maximum Values Average Values Number Sources of Pollutants Certified (include units) (include units) of Laboratory Storm Number Pollutant Grab Sample Flow-weighted Grab Sample Flow-weighted Events Taken During Composite Taken During Composite Sampled First 30 First 30 Minutes Minutes Oil and Grease <5.0 MgIL N/A 5.0 Mg/L NIA 1 Stormwater 27 Biochemical <2 Mg/L <2 Mg/L 1 Stormwater 27 Oxygen Demand (BOD)Chemical Oxygen 18 Mg/L 18 Mg/L 1 Stormwater 27 Demand (COD)Total Suspended 1 20Mg/L 120 MgtL 1 Stormwater 27 Solids (TSS)Total Kjeldahl 0.5 Mg/L 0.5 Mg/L 1 Stormwater 27 Nitrogen (TKN)Nitrate plus 2.4 Mg/L 2.4 Mg/L 1 Stormwater 27 Nitrite Nitrogen Total Phosphorus 0.15 Mg/L 0.15 Mg/L 1 Stormwater 27 PH Minimum Maximum Minimum Maximum I 8.3 7.5 1 Stormwater Maximum Values Average Values Number Sources of Pollutants Certified of Laboratory (include units) (include units) Storm Number Events Pollutant Grab Sample Flow-weighted Grab Sample Flow-weighted Sampled and Taken During Composite Taken During Composite CAS Number First 30 First 30 (if available) Minutes Minutes Zinc, total <0.02 Mg/L <0.02 Mg/L I Stormwater 027 Chromium, total <0.02 Mg/L <0.02 Mg/L I Stormwater 027 Form 2F -Page 3 Discharge 001 Pollutant Pollutant and CAS Number (include units) (include units) Grab Sample Flow-weighted Grab Sample Taken During Composite Taken During First 30 First 30 Minutes Minutes Form 2F -Page 3 Storm Events Sampled of Storm Events Sampled Stormwater Stormwater Laboratory Number Discharge 001~~rtC~Ab WOEi~ 149 pli~~sh~y~ iflqffl~t~fl4' 44T cx~lll ~ ~.7 !-~f.~-r~nrem ~t~ 'n1 ion~taieh ~4} PP~. , -ITO .. ....Pollutant Maximum Values Average Values N .umber Sources of Pollutants Certified and (include units) (include units) of Laboratory Storm Number CAS Grab Sample Flow-weighted Grab Sample Flow-weighted Evet Number Taken During Composite Taken During Composite 'ved (if First 30 First 30 available) Minutes Minutes Copper <0.01 Mg/L <0.01 Mg/L 1 Stormwater 027 Total MWbas 0. 1 Mg/L 0.1 Mg/L I Stormwater 027 Fecal 1800/ 100 ml 1800/ 100 ml 1 Stormwater 027 Colifo Bromide <0.50 Mg/L <0.50 Mg/L 1 Stormwater 027 Color None None 1 Stormwater 027 Chromiu <0.05 Mg/L <0.05 Mg/L 1 Storrawater 027 m Hex PatD rvide dtefothsri 31ve ts w~h est1 inh-ajius~t ~ Ik~i4 iist ane I. 2. 3. 4. 5. 6. 7. 8.Date of Duration Total rainfall Number of hours Maximum flow rate Total flow Season Form of Storm of Storm during storm between during rain event from sample was precipitation Event (in event beginning of storm meas- (gallons/minute or rain event taken (rainfall, minutes) (in inches) ured and end of previous specify units) (gallons or snowmel)measurable rain event specify units)10123/2008 120 .24 168 <7 gpm 34,285 Fall Rainfall n* : : .'. i :: ,2. '-..j" *L :>:" ! '- r k .. .:k". ! ; ..:=:.: .o .: : ..i !; .-.~ ., --:' i. :i .:' "'"4*~~~~~~.~U LUvSUa~cjI~nrion~o u1nwiiawmn WIOJ4JJJ..lZ -i f. -Estimate Form 2F -Page 4 Discharge 001 Pollutant and CAS Number (if available) Copper Total Mba's Fecal Colifo Bromide Color Chromiu mHex Maximum Values (include units) Grab Sample Flow-weighted Taken During Composite First 30 Minutes <0.01 Mg/L 0.1 MgIL 1800/100 ml <0.50MgIL None <0.05 Mg/L Average Values (include units) Grab Sample Flow-weighted Taken During Composite First 30 Minutes <0.01 MgIL 0.1 MgIL 1800/100 ml <0.50MgIL None <0.05 MgIL Number of Storm Events Sampled "': Sources of Pollutants Stormwater Stormwater

Stormwater Stonnwater Stonnwater Stonnwater Certified Laboratory Number 027 027 027 027 027 027 I. 2. 3, 4. 5. 6. 7. 8. Date of Duration Total rainfall Number of hours Maximum flow rate Total flow Season Form of Storm of Storm during storm between during rain event from sample was precipitation Event (in event beginning of storm meas-(gallons Iminute or rain event taken (rainfaLL, minutes) (in inches) ured and end of previous specify units) (gal/ons or snowmelt) measurable rain event specifY units) 10123/2008 120 .24 168 <7 gpm 34,285 Fall Rainfall {i;: Estimate Form 2F -Page 4 Discharge 001 P..t .. .. ...t.....l .i~ ageio covered by .analysi ....... .s .... y .p ...tan ...d.nTb..F2...i~tnc ra ~ofasbsac DYes (list all such pollutants below) ~No VIII. Biological Toxicity Testing Data Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on a receiving water in relation to your discharge within the last 3 years?M Yes (list all such pollutants below) [:] NoEffluent Toxicity testing as required by the current NPDES permit was performed for the past three years in July. All test results"passed'.The results are attached.END .~ FORM. .........Form 2F -Page 5 Discharge 001 No testing as required by the current NPDES pennit was performed for the past three years in July. All test results Fonn 2F -Page 5 Discharge 002 Maximum Values(include units) average v ames(include units) INUIRWCI of Storm Events Sampled t., rulneu Laboratory Number Pollutant Grab Sample Taken During First 30 Minutes Flow-weighted Composite Grab Sample Taken During First 30 Minutes Flow-weighted Composite Oil and Grease <5.00 N/A <5.00 N/A 1 Stormwater 027 Biochemical <2 Mg/L <2 Mg/L I Stormwater 027 Oxygen Demand (BOD)Chemical Oxygen 31 Mg/i 31 Mg/L 1 Stormwater 027 Demand (COD)Total Suspended 17 Mg/iL 17 Mg/L 1 Stormwater 027 Solids (TSS)Total Kjeldahl .3 Mg/L .3 Mg/L 1 Stormwater 027 Nitrogen (TKN)Nitrate plus 1 .64 Mg/L .64 Mg/L 1 Stormwater 027 Nitrite Nitrogen Total Stormwater Phosphorus .13 Mg/L .13 mg/L 1 027 PH Minimum Maximum Minimum Maximum Stormwater 8.1 N/A 8.1 N/A 1 Maximum Values Average Values Number Sources of Pollutants Certified of Laboratory(include units) (include units) Storm Number Pollutant Grab Sample Flow-weighited Grrab Sample Flow-weigh~ted Events arid Taken During Composite Taken During Composite Sampled CAS Number First 30 First 30 (Wfavailable) Minutes Minutes _______________ Fecal Coliform < 10/lO00ml <10 /l100ml1 O02 effluent 027 Effluent _ _ ____Fecal Coliform, 180 / 100 ml 180 / 100 ml 1 Stormwater 027 Stormwater La Pollutant Pollutant and CAS Number Minutes 10/100ml 180 1100 ml N/A <2 MgIL 180 1100 rn1 Storm Events Composite Sampled Storm Events Sampled Stormwater Stormwater 002 effluent Stormwater Laboratory Number Discharge 002.P~-t C ~-List~o Uiar~t sb~owjn Ta1~s ~ aI hayoinpwdive~no ~~~n~~~t~~~uit~~~~~n'nj 2frditn2 ~1~nt ~hot~l Pollutant Maximum Values Average Values Number Sources of Pollutants Certified and (include units) (include units) of Laboratory ...Storm Number CAS Grab Sample Flow-weighted Grab Sample Flow-weighted Events Number Taken During Composite Taken During Composite Sampled (if First 30 First 30 available) Minutes Minutes Zinc, <0.02 Mg/L <0.02 Mg/L 1 Stormwater 027 Total Copper, <0.01 Mg/L <0.01 Mg/L I Stormwater 027 Total Color None None I Stormwater 027 Sulfate 5.9 Mg/L 5.9 Mg/L 1 Stormwater 027 Bromide <0.5 Mg/L <0.5 Mg/L 1 Stormwater 027 MBAS <0.1 Mg/L <0. I Mg/L 1 Stormwater 027 Chromiu <0.02 Mg/L <0.02 Mg/L I Stormwater 027 mr, Total Chromiu <0.05 Mg/L <0.05 Mg/L I Stormwater 027 in, hexavalnt a 1 -r 4 + * + I 4- -t.1. 4 4- 4 4 4 4 + 4 4- 1 4- 4-I + + 1 4 + +...... -.__ _ ........_ _ __, 61. 2. 3. 4. 5. 6. 7. 8.Date of Duration Total rainfall Number of hours Maximum flow rate Total flow Season Form of Storm of Storm during storm between during rain event from sample was precipitation Event (in event beginning of storm meas- (gallons/minute or rain event taken (rainfall, minutes) (in inches) ured and end of previous specify units) (gallons or snowmelt)measurable rain event specify units)10/2312008 120 .24 168 6 gal/mIn 58,000 fall rainfall~'.~O~te~ decntsn I~ il sAeflO. ox'noWimeasmrment-IPR Estimate Discharge 002 Pollutant Maximum Values Average Values Number Sources of Pollutants Certified and (include units) (include units) of Laboratory CAS Grab Sample Flow-weighted Grab Sample Flow-weighted Number Number Taken During Composite Taken During Composite Sampled (if First 30 First 30 available) Minutes Minutes Zinc, <O.02MgIL <0.02 MgIL Stormwater 027 Total Copper, <0.01 MgIL <0.01 Mg/L Stormwater 027 Total Color None None 1 Stormwater 027 Sulfate 5.9 MgIL 5.9MgIL 1 Storm water 027 Bromide <0.5 Mg/L <0.5 Mg/L Stormwater 027 MBAS <0.1 MgIL <0.1 MgIL Stormwater 027 Chromiu <O.02MgIL <0.02 Mg/L Stormwater 027 m, Total Chromiu <0.05 MgIL <0.05 MgIL Stormwater 027 m, hexavalnt I. 2. 3. 4. 5. 6. 7. 8. Date of Duration Total rainfall Number of hours Maximum flow rate Total flow Season Form of Storm of Storm during storm between during rain event from sample was precipitation Event (in event beginning of storm meas-(gallons lminute or rain event taken (rainfall. minutes) (in inches) ured and end of previous specify units} (gallons or snowmell) measurable rain event specify WliLS} 10/23/2008 120 .24 168 6 gaUmin 58,000 fall rainfall Estimate Discharge 002 PArt E -kPotentiaLd ghistd.; in e2F-.2 a T 1ubs t i n Which youi currently, iise., ornianiif.1ur asa nemdiate obr Ainalp6ic rbyrdc? *:[] Yes glist all such pollutants below) Z No VIII. Biological Toxicity Testing Data Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on a receiving water in relation to your discharge within the last 3 years?[] Yes (list all such pollutants below) Z No Discharge 002 have any or reason to believe that any biological test for acute or chronic toxicity has been made on any of your IIU1:;vlU1CI=:C:;:; or on a receiving water in relation to your discharge within the last 3 years? DNR Form 542-1378 IOWA DEPARTMENT OF NATURAL RESOURCES NPDES PERMIT APPLICATION FORM 3 FOR INDUSTRIAL FACILITIES riox4I r1VqLLjur..y avg I rax Idays/week I months/year JaJ.LLLVLUI (in days)001 Cooling tower blowdown, plant online 2.88 3.11 7/week 12mo/year 365 Process water from plant coolers 1.67 1.87 7/week 12mo/yr 365 Cooling tower blowdown, plant offline 2.70 7.24 7/week 1 mo/2yrs 30 Receiving Stream Name: IDischarge canal to the Cedar River 002 Sanitary drains/domestic water .010 .051 7/week 12mo/year 361 days a year Receiving Stream Name: Discharge Canal to the Cedar River Receiving Stream Name: Form 3 -Page 1 DNR Form 542-1378 IOWA DEPARTMENT OF NATURAL RESOURCES NPDES PERMIT APPLICATION FORM 3 FOR INDUSTRIAL FACILITIES FORM 3 -FACILITIES WHICH DISCHARGE PROCESS WASTEWATER-EXISTING SOURCES Stream Name: JISClliarge canal to the Cedar Stream Name: IUISCnar'Qe Canal to the Cedar River pl".",v,no Stream Name: Form 3 -Page 1 A. IS thiS tacility subject to a teaeral ellluent guioelne promuigatea unoer "ecuon .-uq uo we %zean water ACt.in Yes l No If "yes" list 40 CFR part number if known 423 B. Are the applicable effluent guidelines expressed in terms of production? (See Table 1 of the Instructions) D-]Yes f/ No C. If you answered "YES" to Item IB list the quantity or quantities which represent your actual production expressed in the same terms as anplicable. 1880 Currently Producing Mwth* .t. -__ __ _ ,, .-o ...gttach additional sheets if necessary. EfluntTxiit esin a eqirdbyth uren NDS eri fr ufal 01ws erome fr h psttre yar n u4gAl ts he esuts reatahd Seattachmadditiora shetais.if ne forsallry.c diie aeecoe Form 3 -Page 2 Is this facility subject to a federal effluent guideline promulgated under Section 304 of the Clean Water Act? [gJ Yes 0 No If "yes" list 40 CFR part number if known 423 Are the applicable effluent guidelines expressed in terms of production? (See Table 1 of the Instructions) DYes [gJ No If you answered "YES" to Item TIB list the quantity or quantities which represent your actual production expressed in the same DE1I1uent Toxicity testing as required by the current NPDES pennit for outfall 001 was performed for the past three years in July. All "passed". The results are attached. additional sheets Form 3 -Page 2

a. mocnemical lixygen liemandl (ISULJJ 20.0 .707 9.01 .3795zM/ b z/b. Chemical Oxygen Demand (COD) 36 1.40 36 1.40 1 m c. Total Organic Carbon (TOC) 11.9 .576 1 ag/1 lbs 007 d. Total Suspended Solids (TSS) 11.0 .934 11.0 .934 4 mg/I Ibs 027 e. Ammonia (as N) <0.5 0 1 mg/f. Flow .035 .016 365 g. Temperature 68 63 52 (October -March) ___MUNI__h. Temperature 79 73 53 MR6 (April -September)

I.PH Minimum maximum Minimum daximum -ýkpjg 16.82 8.4210AR a.- Bromide <0.5 0 I 1 mg/I Ibs 027 b. Chlorine, Total Residual 2.5 .609 -65 Apr/Oct mgi1 lbs j027 c. Color 7 -None N/A 1 0127 d. Es$cherichia colt (E. call) L e. Fluoride 1g Ibs 02 Form 3 -Page 3 Ibs 66 1 lbs Form 3 -Page 3

g. t1ucrogen Total Organic (as N) _ _ N h. Oil and Grease E<5.0 0 1 IS 027 1. Phosphorus, Total (as P) 1.4 32 mg/l lbs 027 (1) Alpha, Total (2) Beta, Total (3 )Radium, Total (4) Radium 226, Totalk. Sulfate (as S04) 620 14,053 1 mg/i lbs 027 I. Sulfide (as S) 0 m. Sulfite (as S03)n. Surfactants E 0.1 2.26 1 Mg/ lbs 027 o. Aluminum, Total E p. Barium, Total q. Boron, Total r. Cobalt, Total s. Iron, Totalt. Magnesium, Total 'u. Molybdenum, Total v. Manganese, Total l w. Tin, Total x. Titanium, Total Form 3 -Page 4 14,053 lbs mg/I Ibs 027 x. TItanium, Total Form 3 -Page 4 Lij L-i L 2M~. Arsenic, Total 3M. Beryllium, Total [ [4M. Cadmium, Total [SM. Chromium, Total El E] [] .008 .175 3 mg/i lbs 027/007 6M. Copper, Total El <0.01 0 1 mg/I lbs 027 7M. Lead, Total SM. Mercury, Total [ []-[]9M. Nickel, Total [ [XOM. Selenium, Total [I1M. Silver, Total j [12M. Thallium, Total l D [13M. Zinc, Total Z .0869 1.78 13 mg/I lbs 027/007 14M. Cyanide, Total ISM. Phenols, Total

]2,3,7, -Tetra- DESCRIBE RESULTS chlorodlbenzo-P-Li J I _Dioxin Form 3 -Page 5 Fonn 3 -Page 5 iv Rrjen u Li I 2V'. Acrylonitrile i 3V. Benzene [ [4V. Bromoform 5V. Carbon Tetrachlorlde 6V. Chlorobenizee ] [7V. Chlorodi-fl 5 []bromomethane SV. Chloroethane [ __........_ 9V. 2-Chloro-El ethylvlnyl Ether IOV. Chloroform El El 0 ilV. Dichloro- [ bromomethane

2. 1,-Dic-loro-5 ethane 13V.

LII [ethane 14V. 1,l-Dichloro-El ethylene ISV. 1,2-Dichloro propane 16V. 1,3-Dichloro-propylene 17M. Ethylbenzene E El 1SV. Methyl Bromide [ [ [19V. Methyl Chloride [ZoV. Methyl ene [][][Chloride-1'. 1,1,2,22 F] El Te chloroethan,., e ,, Form3 -Page 6 Fonn 3 -Page 6 z£hY. mcramooro-L ~ethylene L iIX Z3V. Toluene El I 24V. 1,2-Trani-El El Dithioroethylene S6V. 1,1,2-Trl:[][][ chloroethane 26v. 1,3,2.Trl.iIl chloroetbaue E 27V. Trichloro-El [][ethylene 28V. Vinyl Chloride [] El [1A. 2-Chlorophenol El El ZA. 2,4-Dichloro-El pheno 3A. 2,4-Dlmethyl. J El phenolCTE 4A. 4,6-Dinitro-O-El El Cresol 5A- 2,4-Dlnitro-0 F]phenol 6A. 2-Nitrophenol El ' z 8A. P-Chloro-M- [ El [Cresol A. Pentachloro-i phenol E 10A. Phenol ~E IIA. 2,4,6-Tni-E chlorophenol 113. Acenapbthene E.. .. .... ....ZB. Acenaphtylene 9 El .-!3B. Anthracene Form 3 -Page 7 Fonn 3 -Page 7 -. .Li Li LIN 50. Benzo (a) El 1: Anthracene 6B. Benzo (a) Pyrene ,E L 7B. 3,4-Denzo-L thoyranthene 8B. Beuzo (ghi) ' 1111 Peryene 9B. Benzo (k) AD M pupranthene 13B. Bis (2.Chlor- [thoxy) Methane I4B. Bis (2-ChBoro Ey '[I E Ethyl Ether hexyl).Phthalate 14B. 4-Bromo. phenyl E LI : Phenyl Ether _ISH. Butyl Benzyl L Pbthalate _______ _____17B. 4-Chioro-phenyl []L Phenyl Ether ____________ JOB. Chrysene [ LI 19B. Dibenzo (s,h)Anthracene_ 20B. 1,2-Dithloro El LI [benzene ZIB. 1,3-Dichloro-benzene 22B. Z,4-Dkhloro-benzene 23B. 3,3'-Dichlore LI bemzidine _ _Phthalate Form 3 -Page 8 FOnD 3 -Page 8

27. o2,4-Dinitro-toluene El 7288. 2,6-Dli utro- ] I toluene 29B. Di-N-Octy!

]l,,][Phthalate 30B. 1,2-Dlphenyl- -n hydrazine 3ZB.Fluorene 33B. Hexachloro-EL '" beanene 4B. Hexachloro-E -butadiene 35B. Hexachioro-E]cyciopentadlene 36D. Hexachloro-LI []ethane 37B. Indeno- (1,2,3- fl1 F cd) Pyrene ..38B. Isophorone [39B. Naphthalene 40B. Nitrobenzene D j sodimethylamine _4ZO. N -Nitrosodi-N- [] LI Propylamine _43D. N-Nltro- L Yodiphenylamlne 44B. Phenanthrene El 1 []-45B. Pyrene EL1 0 46B. 1,2,4-Tri-LI chlorobenzene Form 3 -Page 9 Form 3 -Page 9 ......... _L_ LiJ 7P. 4,4'-DDT " 8P. 4,4'-DDD I1P?. Alpha-Endosulfan 12P. Beta-Endosulfan " 13P. Endlosulfan ' ..Sulfate 14. Endrn LI 15P. Endrin Aldthyde LI 16P. Heptachlor [ LI Epoxide 18P. PCB-I242 LI LI 19P. PCB-1Z54 .20P. PCB-1221 [ LI 21P. PCB-1232 EL [22P. PCB-1248 23?. PCB-1260 El 24P. PCB-1016 -.25P, Toxaphene Form 3--Page 10 Fonn 3 -Page 10

a. .uen t vxyguvenu nuoo 6. 136 1 b I W b. Chemical Oxygen Demand (COD) 87 1972 Me/1 Ibs 027 c. Total Organic Carbon (TOC) 6.31 107.7 1 ag/1 Ibs 07 d. Total Suspended Solids (TSS) 140 3173 1 ra/1 lbs 027 e. Ammonia (as N) <0.5 0mg/I bs f. Flow 3.11 2.9165 g. Temperature 73.9 62.9 183 (October March)h. Temperature 88.8 83. 183 (April -September)ils 1 p HM n m m M x m m M inim um M axim um sfi "ft -g:N I b. ch~orlnTotal ReslduaI ] .1 2.16 .052 1 .05 365 mg/I lbs N/A*. Color LI ~ None N/A mng/I Ilbs 027 d. E$dterkhita coil (E. coilt)M.e, Fluoride f. Nitrate-Nltrite (as N) 12] 272 mg/I lbs 027 Form 3 -Page 3 d. Total e. Ammonia (as N) f. Flow 1.05 365 027 1 Form 3 -Page 3

g. ftNtrogen Total Organic (as N)lLI " Ild h. Oil and Grease ] [] <5.0 0 l mg/i1 lbs 027 I. Phosphorus, Total (as P) 7.0 .273 1 1 /mgi1 lbs 027 (1) Alpha, Total -_" p (-)l Bets-ý, To-tal -E (3 )Radiuns, Total (4) Radium 226, Total k. Sulfate (asSO 64) i 45 1.75 1 mg/1 lbs 027 1. Sulfide (as S)mi. Sulfite (as S03)n. Surfactants

] <1.0 0 1 mg/i lbs 027 o. Aluminum, Total p. Barium, Total q. Boron, Total r. Cobalt, Total El Z s. Iron, Total E t. Magnesium, Total D, u. Molybdenum, Total Y. Manganese, Total E w.Tin,Total

x. Titanium, Total-i -= -=Form 3 -Page 4 1.75 o. AlumInum, p. BarlulD, q. Boron, Fonn 3 -Page 4 ki~ I IIWJ, aUlvuv AOUa Lij Li 2M. Arsenic, Total '3M. Beryllium, Total 0 [ i 4M. Cadmium, Total --LI [5M. Chromium, Total -<0.02 0 1 mg/I lbs 027 6M. Copper, Total El 0l [Z <0.01 0 1 mg/I lbs 027 7M. Lead, Total E z SM. Mercury, Total 0 LI 9M. Nickel, Total fl IoM. Selenium, Total I -i i L 11M. Sllver, Total L 12M. Thallium, Total [ LI !13M. Zinc, Total El LI <0.02 0 1 mg/I l bs 027 14M. Cyanide, Total -11M. Phenols, Total, "I 2,3,7,8-Tetra-E] DESCRIBE RESULTS chlorodibenzo-P-LI LI LIForm 3 -Page 5 Form 3 -Page 5

.*. -L-... LI I _-2V. Acrylonitrile E] El []3V. Benzene 4V. Bromoform .LI sV. Carbon El 0 Tetrachloride 6V. Chlorobenzene 7V. Chlorodl- [bromomethane 8V. Chloroethane El El 9V. 2-Chloro-LI 5 ethylvlnyl Ether IOV. Chloroform fl Li [I IV. Dlcbloro-El LI bromomethane i2V. 1,1-Dichloro-LI ethane 13V. 1,2-Dlchloro-ethane 14V. I,I-Dichlor o- ]["[ethylene i1V. 1,2-Dichloro , propane 16V. 1,3-Dichioro-LIL propylene 17V. Ehylbenzene [f [18V. Methyl Bromide [ [19V. Methyl Chloride LI E ZOV. Methylene [ LI Chloride 2lV. 1,1,2,2 [ ][Tetrachloroethane Form 3 -Page 6 Fonn 3 -Page 6 4zv. Tetracntoro- __Li LiN ethylene _23V. Toluene 24V. 1,2-Trans-El Diehloroethylene z2sv. t,l,l-Tri- ][ 'chloroethane chloroethane 27V. Trichioro-El LI ethylene ZSV. Vinyl Chloride ' ] Eli [IA. 2-Chlorophenol 2A. 2,4-Dichioro-E pheno 3A. 2,4-Dimethyl-phenol 4A. 4,6-Dinlfro-O-I Cresol phenol A.2-Nitrophenol SA. P-Chloro-M- [Cresol 9A. Pentachloro-El z phenol IOA. Phenol [ [IIA. Z,4,6-Tri- ..chlorophenol lB. Acenaphthene El BE. Anthracene L3 Form 3 -Page 7 Fonn 3 -Page 7 .D. DemIZulUC I Li 12S 5B. Benzo (a) Z Anthracene 6B. Ben"o (a) Pyrene 7B. 3,4-Benzo-fluoranthene

85. Be"iO (ghl) L Perylene 9B. Benzo (k)Fuoranthene lOB. Bis CZ-Chlor-ethoxy) Methane ED 11B. Bis (2-Chloro LI Ethyl Ether _ _ _I2B. Di, (2-Chlorolo-

][][propyl) Ether 13B, Bi$ (Z-ethyl- [ ][hexyl) Phthalate 14B. 4-Bromo- phenyl 5 Phenyl Ether 155. Butyl Beuzyl I]Phthalate 16B. 2-Chloro-El 0 naphthalene 17B. 4-Chloro-phenyl [Pheny] Ether _ _ _18B. Chrysene 19B. Dibenzo (a,h) [ ][Anthracene 205. 1,2-Dikhloro E]E benzene _21D. 1,3-Dichloro-El [] Z benzene 22B. 1,4-Dichloro- ][benzene 23B. 3,3'-Dichloro [ [benzidine 24B. Diethyl Phthalate ][.]!25. Dimethyl Phthalate Form 3 -Page 8 Form 3 -Page 8 Phthelate Li Phtb~Iate Li-4 4 -+ 4 4 4 I F E713. 2,4-Dinitro-toluene U I " I Z8B. Z,6-Dihtro-D toluene ,9B. DI-N-OctyL E LI Phthalate 30B. 1,2-Dlphenyl-hydrazine ilB. Fluoranthene [] --o []-z 32B. Fluorene El benzene 34B. Hexachloro- [] Eli butadlene 35R. Hexachloro- [cyclopentadiene 36B. Hexachloro- [ Lj ethane i37. Indeno- (1,2,3- [cd) Pyrene 383. [sophorone 39D. Naphthalene El 40B. Nitrobe'zene LI []41B. N-Nltro- []sodimethylamine 42B. N -Nitrosodl-N- [ LI Propylamine 43B. N-Kltro- [ .. ][sodiphenylaminLe 144B. Phenanthrene l ,46.1,2,4-T- ] L I chlorobenzene -n Form 3 -Page 9 Form 3 -Page 9 ir,. ALarn Li Li 7F. 4,4'-DDT Li ElN 8P. 4,41-DDE El LI 9P. 4,4'-DDD ItOP. Dieldrin ] [II. Alph., s- L .Endosulfan 12P. Beta-Endosulfan [ ][1'3"P. Endosulfan [ " ][Sulfate 151'. Endrin Aldchyde ;il 16?. Heptachlor [][][17P. Septuehlor E'l E]Epoxide 18F.I PCB-17.42 [][]19P. PCB-J 254 [ ]20P. PCB-1221 LI LI [23P. PCB1260 [ L .25P'. Toxaphene E. [7 .Form 3 -Page 10 Forol3 -Page 10 List of Attachments DAEC map identifying GSW strainer backwash flow path Additional environmental permits Line drawing of DAEC water usage Topographical map showing DAEC and waterways Map of DAEC showing the drainage paths Toxicity testing results (3)Chemical Additives MSDS for chemical additives (10)Lab results for storm water and effluent sampling List of Attachments DAEC map identifying GSW strainer backwash flow path Additional environmental permits Line drawing ofDAEC water usage Topographical map showing DAEC and waterways Map ofDAEC showing the drainage paths Toxicity testing results (3) Chemical Additives MSDS for chemical additives (10) Lab results for storm water and effluent sampling Pot IX0 Additional Environmental Permits Air Emission Permits Issued to FPL Energy Duane Arnold by Linn County Public Health EP Description ATI # PTO #001 Auxiliary Boiler 4912 4863 002 1G-21 SBDG #1. 4913 4864 003 1G-31 SBDG #2 4914 4865 006 Diesel Fire Pump 4904 4866 013 TSC Diesel Generator 4915 4867 014 Sulfuric Acid Tank 4916 4868 015 50,000 Gallon UST 4917 4869 016 40,535 Gallon UST 4918 4870 Additional Environmental Permits Air Emission Permits Issued to FPL Energy Duane Arnold by Linn County Public Health EP Description ATI# PTO# 001 Auxiliary Boiler 4912 4863 002 1G-21 SBDG #l. 4913 4864 003 1 G-31 SBDG #2 4914 4865 006 Diesel Fire Pump 4904 4866 013 TSC Diesel Generator 4915 4867 014 Sulfuric Acid Tank 4916 4868 015 50,000 Gallon UST 4917 4869 016 40,535 Gallon UST 4918 4870 Form 1DAEC Line Drawing Cedar River 12.26 Ave. MGD Well .Water 1.68 Ave. MGD MGD Evaporation 10.98 MGD Outfall 001 2.88 Ave. MGD Evaporation .001 MGD 0U072 MGD Se\Treatmi Outfall 002 0.009 Ave. MGD Solid Waste 0.00023 Ave MGD CeClar River 12.26 Ave. MGD Form 1 DAEC Line Drawing 1.67 Ave. MGD __ w_at_e_r __ __ Circulating Water _____ -III'COOling Water Outfall 001 2.88 Ave. MGD Evaporation 10.98 MGD Evaporation 0.072 MGD Well Water 1.68 Ave. MGD 1 0.010 Ave MGD Evap/Losses .001 MGD Domestic Water I Sewage Treatment plant Outfall 002 0.009 Ave. MGD I Stormwater Solid Waste 0.00023 Ave MGD 91*48.000' W w b q0 z Z z-o 0 z bo 0, N z b0 0O w w TWr OM FEC ET 0 1000Im METER&Map cratd with TOPOIO 02002 Hatbna1~oogphi(wwwi~tulohwpirxoo opo)TOPOl map printed on 12/17/08 from "Iowa.tpo* and "untitled.tpg" 91°47 W 91° W z <=> o o Map meted with TOPOI8 NatioN! Oeog<opbi: (www-"'llioMlteoptq>hic.cotnltopo) ai o z <=> o o .0 o z '0 o o to 0 f -.-l.......I 4 I"-=------ 0£ -" I HHH!....C'- *s" -tS.- .,I -,, *, -,, .-, mimi L I ZV SITE MAP FOR ST--1--WATERPOLLUTION PREVENTION PLANDUANE ARNOLD ENERGY CENTER Lf-, I r.r--------------------- ____ .. -.. 1 8 i

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"L HYGIENIC LABORATORY Iowa's Environmental and THE6 1 Public Health Laboratory UNIVERSI"TY 2220 South Ankeny Blvd.OF IOWA Ankeny, Iowa 50023 SS-725-1600 Fax 515-725-1642 www.uhj.uiowa.edu August 3, 2006 Jerald Hogan Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 RE: UHL Sample Number: 200660353

Dear Mr. Hogan:

Analytical and toxicity test results for the sample listed above are enclosed. Thissample was received by our Laboratory for effluent toxicity testing on July 12, 2006.As required by the Iowa Department of Natural Resources, statistical analyses were performed on the 48 hour mortality data. These statistical analyses determined there was no significant difference in survival between the effluent dilution and the control.As a result, your sample, UHL Lab No. 200660353, "passed" the toxicity tests.The University Hygienic Laboratory appreciates this opportunity to provide you with our services. Questions regarding the test or results should be directed to Lee Wagner, Ryan Thompson, Dave Schelling or me. Test analysts can be contacted on the dedicated WET program phone line, (515) 725-1648.The charge for these tests is $425.00 for the WET test + $125.00 for sample collection for a grand total of $550.00. Following the end of the month a statement of this charge will be directed to the above address.Sincerely, JoG. Miller IIl Linmologist JM/hlw Enclosure c: Accounting Page 1 of 4_.' l THEm UNIVERSITY OF IOWA August 3,2006 Jerald Hogan Duane Arnold Energy Center 3277 DAEC Road Palo, LA 52324 RE: UHL Sample Number: 200660353

Dear Mr. Hogan:

HYGIENIC LABORATORY Iowa's Environmental and Public Health Laboratory 2220 South Ankeny Blvd. Ankeny, Iowa 50023 515-725-1600 'Fox 515-725-1642 www.uhl.uiowa,edu Analytical and toxicity test results for the sample listed above are enclosed. This sample was received by our Laboratory for effluent toxicity testing on July 12, 2006. As required by the Iowa Department of Natural Resources, statistical analyses were performed on the 48 hour mortality data. These statistical analyses determined there was no significant difference in survival between the effluent dilution and the control. As a result, your sample, UHL Lab No. 200660353, "passed" the toxicity tests. The University Hygienic Laboratory appreciates this opportunity to provide you with our services. Questions regarding the test or results should be directed to Lee Wagner, Ryan Thompson. Dave Schelling or me. Test analysts can be contacted on the dedicated WET program phone line, (515) 725-1648. The charge for these tests is $425.00 for the WET test + $125.00 for sample collection for a grand total of $550.00. Following the end of the month a statement of this charge will be directed to the above address. ' Sillcerely, JO):.!:III Limnologist JMJhlw Enclosure c: Accounting Page 1 of4 Form #542-1381 Iowa Department of Natural ResourcesEffluent Toxicity Testing Report Form 48-Hour Acute Test FACILITY DATA Facility Name Duane Arnold Energy Center NPDES # IA 57-00-1-04 Sampling Location Duane Arnold Energy Center Diluted effluent sample ratio (from permit) 4.40%Address 3277 DAEC Road City/State/Zip Palo, IA 52324 Lab Sample # 200660353 Date Collected _July 11, 2006, 14:30 Date Received July 12, 2006, 10:00 Temperature upon receipt 5 0 C ORGANISM DATA Pimephales promelas age 13 Days Reference Toxicant Sodium Chloride Reference LC 5 0 6.81 (95% Conf. Int 6.58- 7.04) gm/L Ceriodaphnia uika age <24 Hours Reference Toxicant Sodium Chloride Reference LC50 1.63 (95% Cont Int. 1.49-1.75) gm/L SAMPLE DATA (100% EFFLUENT)Temperature 25 oC, Initial D.O. 6.8 mg/L, D.O. (end of test) 6.9 mg/L, pH 8.2 Units, pH (end of test) 8.3 Units, Ammonia Nitrogen (as N) 0.20 mg/L, Total Ammonia (as NH 3) 0.24 mg/L, Unionized Ammonia (calculated as NH 3) 0.02 mg/L Total Residual Chlorine <0.1* mg/L, Specific Conductance 2100 pnhos MORTALITY DATA Laboratory (Name) University Hygienic Laboratory Test begun (Date) July 12, 2006, 12:30 Test ended (date) July 14, 2006, 12:30 Pimephales promelas Mortality Ceriodaihnia dubia Mortality (Number Dead/Number Tested) (Number Dead/Number Tested)Conc. Bk. I Bk. 2 Bk. 3 Bk. 4 Bk. 1 Bk. 2 Bk. 3 Bk. 4 P F P F a a a a s i s Ctrl. 0_W 015 0/5 0/5 s 1 0/5 0/5 0/5 0/5 s 4.40% 0/5 0/5 05 (X) (0) 0/15 0/5 0/_15 o/_5 (X) ()100% 0/5 0/5 0/5 0/5 (X) () 0/5 0/5 0/5 L/5 (X) ()EFFLUENT'TOXICITY TESTING RESULTS PASS (XXX) FAIL ( )U.S. EPA-821-R-02-012 October 2002 Comments:

• Total Residual Chlorine analyzed by Hach Colorimeter.
  • Sample filtered for removal of indigenous organisms or large particulates.

AUG 0 7 2006 Date Reported: Page 2 of 4 Form #542-1381 Iowa Department of Natllral Resources Effluent Toxicity Testing Report Fonn 48-Hour Acute Test FACILITY DATA Facility Name Duane Arnold Energy Center Lab Sample # _______ _ NPDES # IA ________ Date Collected July 11,2006, 14:30 Sampling Location Duane Arnold Energy Center Diluted effluent sampJe ratio (from permit) ---"4.;.,.;.4.;:...Oo/t;..;:o ____ ,Address 3277 DAEC Road Date Received July 12,2006, 10:00 City/StateJZip Palo, IA 52324 Temperature upon receipt 5°C ORGANISM DATA Pimephales promelas age -.;:.;13'-D:::...::.ay:..;;s _________ Ceriodaphnia dubia age .,.,<2-=-4:...;H:;.o:::-:UTS::.::-:,-- _______ _ Reference Toxicant Sodium Chloride Reference Toxicant Sodium Chloride Reference LCSO 6,81 (95% Conf. Int 6.58-7.04) gm!L Reference LC50 1.63 (95% Conf. lot 1.49-1.75) gmIL SAMPLE DATA (100% EFFLUENT) Temperature 25 "C, Initial D.O. 6.8 mg/L, D.O. (end oftest) 6.9 mgIL, pH 8.2 Units, pH (end of test) ___ Units, Ammonia Nitrogen (as N) _____ mgIL, Total Ammonia (as NH 3) 0.24 mg/L, Unionized Ammonia (calculated as NH3) 0.02 mglL Total Residual Chlorine <0.1* mg/L, Specific Conductance 2100 MORTALITY DATA Laboratory (Name) University Hygienic Laboratory Test begun (Date) July 12,2006, 12:30 . Test ended (date) July 14,2006, 12:30 Pimephales promelas Mortality Ceriodaphnia dubia Mortality (Number DeadINumber Tested) (Number DeadINumber Tested) Cone. Bk.l Bk.2 Bk. 3 Bk.4 Bk.l Bk. 2 Bk.3 Bk.4 P F P F a a a a s s i Ctr\' 0/5 0/5 0/5 S 0/5 0/5 0/5 0/5 s I 4.40% 015 015 0/5 015 (X) () 015 0/5 0/5 0/5 (X) () 100% 0/5 0/5 0/5 0/5 (X) () 015 0/5 0/5 1/5 (X) () EFFLUENT "TOXICITY TESTING RESUL TS PASS (XXX) FAIL ( ) U.S, EPA-821-R-02-012 October 2002 Comments:

• Total Residual Chlorine analyzed by Hach Colorimeter. "Sample filtered for removal of indigenous organisms or large particulates.

Date Reported: _A_U_6_0_1_200_ 6 Page 2 of4 STATISTICAL ANALYSIS OF BIOSCREEN DATA FOR SIGNIFICANT DIFFERENCE IOWA DEPARTMENT OF NATURAL RESOURCES VERSION 1.2 3-11-1992 File Name: data Calculations performed on Aug 03, 06 at 10:54:48 hrs Laboratory Number: 200660353 Facility Name: Duane Aronld Energy CenterTest Species: Pimephales promelas Number of concentrations in test = 3 Control -- Concentration 1 SURVIVORS

1. IN TEST TRANSFORMED DATA 5 5 5 5 5 5 5 1.345287 1.345287 1.345287 1.345287 SUM = 5.381146 MEAN = 1.345287 4.40% Effleunt -- Concentration 2 SURVIVORS # IN TEST TRANSFORMED DATA 5 5 1.3452B7 5 5 1.3452B7 5 5 1.345287 5 5 1.345287 SUM = 5.381146 MEAN = 1.345287=='>NOT A STATISTICALLY SIGNIFICANT DIFFERENCE IN SURVIVAL.

tt 100% Effluent-- Concentration 3 SURVIVORS

1. IN TEST S S 5 5 5 5 5 5 TRANSFORMED DATA 1.345287 1.345287 1.345287 1.345287 SUM = 5.381146 MEAN = 1.345287===>NOT A STATISTICALLY SIGNIFICANT DIFFERENCE IN SURVIVAL.

tt Page 3 of 4 File Name: STATISTICAL ANALYSIS OF BIOSCREEN DATA FOR SIGNIFICANT DIFFERENCE IOWA DEPARTMENT OF NATURAL RESOURCES VERSION 1.2 3-11-1992 data Calculations performed on Aug 03, 06 at 10:54:48 hrs Laboratory Number: 200660353 Facility Name; Test Species; Duane Aronld Energy Center Pimephales promelas Number of concentrations in test 3 Control --Concentration 1 SURVIVORS it IN TEST TRANSFORMED DATA 5 5 1.345287 5 5 1.345287 5 5 1.345287 5 5 1.345287 SUM 5.381146 MEAN 1.345287 4.40% Effleunt --Concentration 2 SURVIVORS 5 # IN TEST 5 5 5 5 SUM MEAN 5.381146 1.345287 5 5 5 TRANSFORMED DATA 1.345287 1.345287 1.345287 1.345287 A STATISTICALLY SIGNIFICANT DIFFERENCE IN SURVIVAL. tt 100% Effluent --Concentration 3 SURVIVORS S S 5 5 # IN TEST 5 5 5 5 SUM 5.381146 1.345287 TRANSFORMED DATA 1.345287 1.345287 1.345287 1.345287 A STATISTICALLY SIGNIFICANT DIFFERENCE IN SURVIVAL. tt Page 3 of4 STATISTICAL ANALYSIS OF BIOSCREEN DATA FOR SIGNIFICANT DIFFERENCE IOWA DEPARTMENT OF NATURAL RESOURCES VERSION 1.2 3-11-1992 File Name: Data Calculations performed on Aug 03, 06 at 10:56:08 hrs Laboratory Number-'Facility Name:Test Species: 200660353 Duane Aronld Energy Center Ceriodaphnia dubia Number of concentrations in test = 3 Control -- Concentration 1 SURVIVORS

1. IN TEST TRANSFORMED DATA 5 5 1.345287 5 5 1.345287 5 5 1.345287 5 5 1.345287 SUM = 5.381146 MEAN = 1.345287 4.40% Effluent-- Concentration 2 SURVIVORS
2. IN TEST 5 5 5 5 5 5 5.5 TRANSFORMED DATA 1.345287 1.345287 1.345287 1.345287 SUM = 5.381146 MEAN = 1.345287===>NOT A STATISTICALLY SIGNIFICANT DIFFERENCE IN SURVIVAL.

tt 100% Effluent -- Concentration 3 SURVIVORS

1. IN TEST 5 5 S 4 5 5 5 5 TRANSFORMED DATA 1.345287 1.345287 1.345287 1.107149 SUM = 5.143009 MEAN = 1.285752===>NOT A STATISTICALLY SIGNIFICANT DIFFERENCE IN SURVIVAL.

wr Page 4 of 4 STATISTICAL ANALYSIS OF BIOSCREEN DATA FOR SIGNIFICANT DIFFERENCE IOWA DEPARTMENT OF NATURAL RESOURCES VERSION 1.2 3-11-1992 File Name: Data Calculations performed on Aug 03, 06 at 10:56:08 hrs 200660353 Laboratory Number: 'Facility Name: Test Species: Duane Aronld Energy Center Ceriodaphnia dubia Number of concentrations in test = 3 Control --Concentration 1 SURVIVORS

1. IN TEST TRANSFORMED DATA 5 5 1.345287 5 5 1.345287 5 5 1.345287 5 5 1. 345287 SUM 5.381146 MEAN 1. 345287 4.40% Effluent --Concentration 2 SURVIVORS
2. IN TEST 5 5 5 5 5 SUM MEAN 5 5 '5 5.381146 1.345287 TRANSFORMED DATA 1.345287 1. 345287 1. 345287 1.345287 ===>NOT A STATISTICALLY SIGNIFICANT DIFFERENCE IN SURVIVAL.

tt 100% Effluent --Concentration 3 SURVIVORS

1. IN 5 5 5 4 SUM MEAN 5.143009 1.285752 5 5 5 5 TEST TRANSFORMED DATA 1. 345287 1.345287 1.345287 1.107149 ===>NOT A STATISTICALLY SIGNIFICANT DIFFERENCE IN SURVIVAL.

wr Page 4 of4 L~HYGIENC LABORATORY Iowa's Environmental and NLNVERS-I.Y Public Health Laboratory 2220 South Ankeny Boulevard OF IOWA Ankeny, iowa 50023 S15-725-1.600 Fox 515-72S-1642 www.uhl.uiowa.edu July 26, 2007 Jerald Hogan Duane Arnold Energy Center 3277 DAEC Road Palo, 1A 52324 RE: UHL Sample Number: 2007025083

Dear Mr. Hogan:

Analytical and toxicity test results for the sample listed above are enclosed. This sample was received by our Laboratory for effluent toxicity testing on July 18, 2007.As required by the Iowa Department of Natural Resources, statistical analyses were performed on the 48 hour mortality data. These statistical analyses determined there was no significant difference in survival between the effluent dilution and the control.As a result, your sample, UHL Lab No. 2007025083, "passed" the toxicity tests.The University Hygienic Laboratory appreciates this opportunity to provide you with our services. Questions regarding the test or results should be directed to Ryan Thompson, Dave Schelling, Tim Blake or me. Test analysts can be contacted on thededicated WET program phone line, (515) 725-1648.The charge for this tests is $425, plus $125 for sample collection, for a total of $550.Following the end of the month a statement of this charge will be directed to the above address.Sincerely, Joh~ Mller III Liniologist JM/rlt Enclosure c: Accounting Page 1 of 6 l UNIVERSllY OF IOWA July 26, 2007 Jerald Hogan Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 RE: UHL Sample Number: 2007025083

Dear Mr. Hogan:

HYGIENIC LABORATORY Iowa's Environmental and Public Health Laboratory 2220 South Ankeny Boulevard Ankeny, Iowa 50023 515-725-1600 FQ)( 515-725-1642 www.uhl.uiowa.edu Analytical and toxicity test results for the sample listed above are enclosed. This sample was received by our Laboratory for effluent toxicity testing on July 18, 2007. As required by the Iowa Department of Natural Resources, statistical analyses were performed on the 48 hour mortality data. These statistical analyses detetmined there was no significant difference in survival between the effluent dilution and the control. As a result, your sample, UHL Lab No. 2007025083, "passed" the toxicity tests. The University Hygienic Laboratory appreciates this opportunity to provide you with our services. Questions regarding the test or results should be directed to Ryan Thompson, Dave Schelling, Tim Blake or me. Test analysts can be contacted on the WET program phone line, (515) 725-1648. The charge for this tests is $425, plus $125 for sample collection, for a total of $550. Following the end of the month a statement of this charge will be directed to the above address. ' , Sincerely, JoJ'.b. Miller III Limnologist JM/rlt Enclosure c: Accounting Page 1 of6 Form #542-1381 Iowa Department of Natural Resources Effluent Toxicity Testing Report Form 48-Hour Acute Test FACILITY DATAFacility Name Duane Arnold Energy Center NPDES # LA 57-00-1-04 Sampling Location Outfall #001 Diluted effluent sample ratio (from permit) 4.40%Address 3277 DAEC Road City/State/Zip Palo, IA 52324 Lab Sample # 2007025083 Date Collected July 17, 2007, 14:00 Date Received July 18, 2007, 09:15 Temperature upon receipt ] °C ORGANISM DATA Pimephales promelas age 13 Days Reference Toxicant Sodium Chloride Reference LC 5 0 6.58 (95% Conf. Int 6.22-6.95) gm/L Ceriodaohnia dubia age <24 Hours Reference Toxicant Sodium Chloride Reference LC50 1.89 (95% Cont mnt 1.79-2.00) gm/L SAMPLE DATA (100% EFFLUENT)Temperature 24 °C, Initial D.O. 6.6 mg/L, D.O. (end of test) 6.7 mg/L, pH 7.8 Units, pH (end of test) 8.1 Units, Ammonia Nitrogen (as N) 0.19 mg/L, Total Ammonia (as NH 3) 0.23 mg/L, Unionized Ammonia (calculated as NH 3) <0.01 mg/L Total Residual Chlorine 0.12* mg/L, Specific Conductance 2000 limhos MORTALITY DATA Laboratory (Name) University Hygienic Laboratory Test begun (Date) July 18, 2007, 13:30 Test ended (date) July 20, 2007, 13:30 Pimephales promelas Mortality(Number Dead/Number Tested) Conc. Bk. I Bk. 2 Bk. 3 Bk. 4 Ceriodaphnia dubia Mortality (Number Dead/Number Tested) Bk. I Bk. 2 Bk- 3 Bk. 4 P F P F a a a a s i s 0/5 0/5 015 0/5 s 1 0/5 0/5 0/5 0/5 s Ctrl.4.40% 0/5 015 015 015 (X) () 0/ 05 015 015 (X) ()100% 0/5 0/5 0/5 05 (X) () o/.5 L/5 0/5 0/5 (X) ()EFFLUENT TOXICITY TESTING RESULTS PASS (XXX) FAIL ( )U.S, EPA-82I-R-02-012 October 2002 Comments:

• Total Residual Chlorine analyzed by Hach Colorimeter.
  • Sample filtered for removal of indigenous organisms or large particulates.
    • Dilution total residual chlorine <0.1.Date Reported:

rJUL 2 7 2007 Page 2 of 6 Form #542-1381 Iowa Department of Natural Resources Effluent Toxicity Testing Report Form 48-Hour Acute Test FACILITY DATA Facility Name Duane Arnold Energy Center Lab Sample # _______ _ NPDES # IA 57-00-1-04 Date Collected July 17,2007,14:00 Sampling Location Outfall #001 Diluted effluent sample ratio (from pennit) ____ ________ _ Address 3277 DAEC Road Date Received July 18,2007,09:15 City/State/Zip Palo, IA 52324 Temperature upon receipt ] °C ORGANISM DATA Pimephales promelas age ___________ Ceriodaphnia dubia age <24 Hours Reference Toxicant Sodium Chloride Reference Toxicant Reference LCSO 6.58 (95% Conf.lnt 622-6.95) gm/L Reference LCSO 1.89 (95% Conf. Int 1.79-2.00) gmIL SAMPLE DATA (100% EFFLUENT) Temperature 24 °C, Initial D.O. 6.6 mg/L, D.O. (end oftest) 6.7 mgIL, pH 7.8 Units, pH (end of test) ___ Units, Ammonia Nitrogen (asN) -.::;0.:.:.19==-- ______ mg/L, Total Ammonia (as NH3) 0.23 mgIL, Unionized Ammonia (calculated as NH3) <0.01 mgIL Total Residual Chlorine 0.12'" mg/L, Specific Conductance 2000 MORTALITY DATA _______ Test ended (date) July 20,2007, 13:30 Ceriodaphnia dubia Mortality (Number DeadINumber Tested) Bk. 1 Bk. 2 Ble. 3 Bk. 4 EFFLUENT TOXICITY TESTING RESULTS U.S. EPA-821-R-02-012 October 2002 F a () () PASS (XXX) Comments:

• Total Residual Chlorine analyzed by Hach Colorimeter.

0/5 0/5 015 0/5 015 0/5 FAIL ( ) uSampJe filtered for removal of indigenous organisms or large particulates.

• uDilution total residual chlorine <0.1. Date Reported:

fJUL 2 7 2007 Page 2 of6 0/5 0/5 0/5 015 0/5 0/5 P a s s (X) (X) F a () () Comparisons: Report Date: Analysis: Page 1 of I 23 Jul-07 10:24 AM 03-8223-5273/daec07f CETIS Analysis Detail E Fathead Minnow 48-h Acute Survival Test University of Iowa-Hygienic Laboratory STest No: 18B-2385-7052 Test Type: Survival (48h) Duration: 48h Start Date: 18 Jul-07 01:30 PM Protocol: EPA/821/R-02-012 (2002) Species: Pimephales promelas Ending Date: 20 Jul-07 01:30 PM Dil Water: Hard-Mod. Hard Synthetic Water Source: Environmental Protection Agency Setup Date: 18 Jul-07 01:30 PM Brine: t Sample No: 16-7755-9369 Code: 2007025083 Client: Duane Arnold Energy Center Sample Date: 17 Jul-07 02:00 PM Material: Power Plant Effluent Project: Iowa WET Test Receive Date: 18 Jul-07 09:15 AM Source: NPDES Permit

1. Sample Age: 23h (1 "C) Station: 57-00-1-04 Comments:

Sample filtered for the removal of indigenous organisms or large particulates. Endpoint Analysis Type Sample Link Control Link Date Analyzed Version 48h Proportion Survived Comparison 10-9293-4309 10-9293-4309 23 Jul-07 10:24 AM CETISvI.2 Alt H Data Transform ZetaINOEL LOEL Toxic Units ChV PMSD Wilcoxon Rank Sum Two-Sample C> T Angular (Corrected) 4.4 >4.4 22.7273 N/A 5.00%Group Comparisons Control vs Conc-% Statistic Critical P-Value Ties Decision(0.O5) Dilution Water 4.4 18 0.4429 4 Non-Significant Effect ANOVA Table Source Sum of Squares Mean Square OF F Statistic P-Value Decision(D.05) Between 0 0 1 65535.0 0.00000 Significant Effect Error 0 0 6 Total 0 0 7 ANOVA Assumptions Attribute Test Statistic Critical P-Value Declsion(O.01) Variances Modified Levene 65535.00000 13.74502 0.00000 Unequal Variances Data Summary Original Data Transformed DataConc-% Control Type Count Mean Minimum Maximum SD Mean Minimum Maximum SD 0 Dilution Water 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 4.4 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 Data Detail Conc-% Control Type Rep I Rep 2 Rep 3 Rep 4 Rep 5 Rep 6 Rep 7 Rep 8 0 Dilution Water 1.00000 1.00000 1.00000 1.00000 4.4 1.00000 1.00000 1.D0000 1.00000 Page 3 of 6 CETISTM v1.1.2revQ 000-205-102-2 Analyst: '*D Approvety0h U_CETIS Analysis Detail Fathead Minnow 48-h Acute Survival Test Test No: 18-2385-7052 Test Type: Survival (48h) Start Date: 18 Jut-07 01:30 PM Protocol: EPN821/R-02-012 (2002) Ending Date: 20 Jul-07 01 :30 PM Oil Water: Hard-Mod. Hard Synthetic Water Setup Date: 18 Jut-Ol 01 :30 PM Brine: Sample No: 16-n55-9369 Code: 2007025083 Sample Date: 17 Jul-07 02:00 PM Material: Power Plant Effluent Receive Date: 18 Jut-07 09:15 AM Source: NPDES Permit # Sample Age: 23h (1 *C) Station: 57-00-,-04 Comments: Sample filtered for the removal of indigenous organisms or large particulates. Comparisons: Report Date: Analysis: Page 1 of 1 23 Jul-07 10:24 AM 03-8223-5273/daec07f University of lowa-Hygienic laboratory Duration: 48h Species: Pimephales promelas Source: Environmental Protection Agency Client: Duane Arnold Energy Center Project: Iowa WET Test Endpoint Analysis Type SampleUnk Control Link Date Analyzed Version 48h Proportion Survived Comparison 10-9293-4309 10-9293-4309 23 Jul-07 10:24 AM CETISv1.1.2 Method Alt H Wilcoxon RanK Sum Two*Sample C>T Group Comparisons Control vs Conc-% Dilution Water 4.4 AN OVA Table Source Sum of Squares Between 0 Error 0 TOlal 0 ANOVA Assumptions Attribute Test Variances Modified Levene Data Summary Conc-% Control Type Count 0 Dilution Waler 4 4.4 4 Data DetaH Conc-% Control Type Rep 1 0 Dilution Waler 1.00000 4.4 1.00000 000-205-102-2 Data Transform Zeta NOEL LOEL Toxic Units ChV PMSD Angular (Corrected) 4.4 >4.4 22.7273 NfA 5.00% Statistic Critical P-Value TIes Decision(O.OS) 18 0.4429 4 Non-5ignificanl Effect Mean Square OF F Statistic P-Value Decision(O.05) 0 1 65535.0 0.00000 Significant Effect 0 6 0 7 Statistic Critical P-Value Declsion(O.01 ) 65535.00000 13.74502 0.00000 Unequal Variances Original Data Transformed Data Mean Minimum Maximum 50 Mean Minimum MaXimum SO 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 Rep 2 Rep 3 Rep 4 RepS RepS Rep 7 RepS 1.00000 1.00000 1.00000 1.00000 1.00000 1.00000 Page 3 of6 CETIS'" v1.1.2revQ Analyst: "Mn Comparisons: Report Date: Analysis: Page 1 of 123 Jul-07 10:24 AM 10-6267-65361daecO7f CETIS Analysis Detail[Fathead Minnow 48-h Acute Survival Test University of Iowa-Hygienic Laboratory Test No: 18-2385-7052 TestType: Survival (48h) Duration: 48h Start Date: 18 Jul-07 01:30 PM Protocol: EPA/821/R-02-012 (2002) Species: Pimephales promelas Ending Date: 20 Jul-07 01:30 PM Dil Water: Hard-Mod. Hard Synthetic Water Source: Envimnmental Protection Agency Setup Date: 18 Jul-07 01:30 PM Brine: Sample No: 16-7755-9369 Code: 2007025083 Client: Duane Arnold Energy Center Sample Date: 17 Jul-07 02:00 PM Material: Power Plant Effluent Project Iowa WET Test Receive Date: 18 Jul-07 09:15 AM Source: NPDES Permit

1. Sample Age: 23h (1 "C) Station: 57-00-1-04 Comments:

Sample filtered for the removal of indigenous organisms or large particulates. Endpoint Analysis Type Sample Link Control Link Date Analyzed Version 48h Proportion Survived Comparison 10-9293-4309 10-9293-4309 23 Jul-07 10:24 AM CETISv.,1.2 Method Alt H Data Transform Zeta M[NOEL LOEL Toxic Unite ChV PMSD Wilcoxon Rank Sum Two-Sample C > T Angular (Corrected) 100 >100 I N/A 5.DD%Group Comparisons Control vs Conc-% Statistic Criticai P-Value Ties Decslaon(0.05) Dilution Water 100 18 0.4429 4 Non-Significant Effect ANOVA Table Source Sum of Squares Mean Square DF F Statistic P-Value Decision(0.05) Between 0 0 1 65535.0 0.00000 Significant Effect Error 0 0 6 Total 0 0 7 ANOVA Assumptions Attribute Test Statistic Critical P-Value Decision(O.01) Variances Modified Levene 65535.00000 13.74502 0.0000D Unequal Variances Data Summary Original Data Transformed Data Conc-% Control Type Count Mean Minimum Maximum SO Mean Minimum Maximum SD 0 Dilution Water 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 100 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 oata Detail Conc-% Control Type Rep I Rep 2 Rep 3 Rep 4 Rep 5 Rep 6 Rep 7 Rep 8 0 Dilution Water 1.00000 1.00000 1.00000 1.00000 100 1.00000 1.00000 1.00000 1.00000 Page 4 of 6 0ETISTM v1.1.2revQ 000-205-102-2 Analyst: kr3 Approval-,19A -V_ -CETIS Analysis Detail Fathead Minnow 48-h Acute Survival Test Test No: 18-2385-7052 Test Type: Survival (48h) Start Date: 18 Jul-07 01:30 PM Protocol: EPAf821IR-02-012 (2002) Ending Date: 20 Jul-07 01:30 PM Oil Water: Hard-Mod. Hard Synthetic Water Setup Date: 18 Jul-07 01:30 PM Brine: Sample No: 1&-7755-9369 Code: 2007025083 Sample Date: 17 Jul-07 02:00 PM Material: Power Plant Effluent Receive Date: 18 JuJ-07 09:15 AM Source: NPDES Permit # Sample Age: 23h (1 *C) Station: 57-00-1-04 Comments: Sample fillered for the removal of indigenous organisms or large particulates. Comparisons: Report Date: Analysis: Page 1 of f 23 Jul-07 10:24 AM University of Iowa-Hygienic Laboratory Duration: 48h Species: Pimephales promelas Source: Environmental Protection Agency Client: Duane Arnold Energy Center Project: IQwa WETTest Endpoint AnalYSis Type Sample Link Control link Date Analyzed Version 48h Proportion Survived Comparison 10-9293-4309 10-9293-4309 23 Jul-07 10:24 AM CETISvt.1.2 Method Alt H Data Transform Zeta NOEL LOEL Toxic Units ChV PMSD Wilcoxon Rank Sum Two-Sample C>T Angular (Corrected) 100 >100 1 N/A 5.0D% Group Comparisons Control vs Conc-% Statistic Critical P-Value TIes Declsion(0_05) Dilution Water 100 18 0.4429 4 Non-Signlficant Effect ANOVA Table Source Sum of Squares Mean Square DF F StaUstic P-Value Declsion(D.05) SelWeen 0 0 1 65535.0 0.00000 Signlficant Effect Error 0 0 6 Tolal 0 0 7 ANOVA Assumptions Attribute Test Statistic Critical P-Value Decision(O.01 ) Variances Modified Levene 65535.00000 13.74502 0.00000 Unequal Variances Data Summary Original Data Transformed Data Conc-% Control Type Count Mean Minimum Maximum SO Mean Minimum Maximum SD 0 Dilution Water 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 100 4 1.00DOO 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 Data Detail Conc-% Control Type Rep 1 Rep 2 Rep 3 Rep 4 RepS RepS Rep 7 RepS 0 Dilution Water 1.00000 1.00000 100 1.00000 1.00000 000-:W5-102-2 1.00000 1.00000 1.00000 1.00000 Page 4 of6 CETIS TM v1.1.2revQ Analyst: Comparisons: Page 1 of 1 Report Date: 23 Jul-07 10:22 AM CETIS Analysis Detail Analysis: 1l-5964-gS9 daecO7c Ceriodaphnia 48-h Acute Survival Test University of Iowa-Hygienic Laboratory Test No: 10-1870-7871 Test Type: Survival (48h) Duration: 48h Start Date: 18 Jul-07 01:30 PM Protocol: EPAN821/R-02-012 (2002) Species: Cerlodaphnia dubia Ending Date: 20 Jul-07 01:30 PM Dif Water. Hard-Mod, Hard Synthetic Water Source: Environmental Protection Agency Setup Date: 18 Jul-07 01:30 PM Brine: Sample No: 16-7755-9369 Code: 2007025083 Client: Duane Arnold Energy Center Sample Date: 17 Jul-07 02:00 PM Material: Power Plant Effluent Project- Iowa WET Test Receive Date: 18 Jul-07 09:15 AM Source: NPDES Permit #Sample Age: 23h (1 °C) Station:w. 57-O0-1-04 1 Comments: Sample rftered for the removal of indigenous organisms or large particulates. Endpoint Analysis Type Sample Link Control Link Date Analyzed Version 48h Proportion Survived Comparison 06-7190-7087 06-7190-7087 23 Jul-07 10:22 AM CETISv0.1.2 Method Alt H Data Transform Zeta 11 NOEL LOEL Toxic Units ChV PMSD Wilcoxon Rank Sum Two-Sample C > T Angular (Corrected) "14.4 >4.4 22.7273 N/A 5.00%Group Comparisons Control vs Conc-% Statistic Critical P-Value Ties Decision(O.05) Dilution Water 4.4 18 0.4429 4 Non-Significant Effect Test Acceptability Attribute Statistic TAC Range Overlap Decision Control Response 1 0.9 -NL Yes Passes acceptability criteria ANOVA Table Source Sum of Squares Mean Square DF F Statistic P-Value Decision(O.05) Between 0 0 1 65535.0 0.00000 Significant Effect Error 0 0 6 Total 0 0 7 ANOVA Assumptions Attribute Test Statistic Critical P-Value Decision(O.O1) Variances Modified Levene 65535.00000 13.74502 0.00000 Unequal Variances Data Summary Original Data Transformed Data Conc-% Control Type Count Mean Minimum Maximum SD Mean Minimum Maximum SD 0 Dilution Water 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 4.4 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0,00021 Data Detail Conc-% Control Type Rep 1 Rep 2 Rep 3 Rep 4 Rep 5 Rep 6 Rep 7 Rep 8 Dilution Water 1.00000 1.00000 1.00000 1.00000 14.4 1.00000 1.00000 1.00000 1,0000D Page 5 of 6 000-205-102-2 CETISTm vl.i.2revQ Analyst:- Approval.,,2 CETIS Analysis Detail Ceriodaphnia 48-h Acute Survival Test Test No: 10-1870-7871 Test Type: Start Date: 18 Jul-07 01:30 PM Protocol: Ending Date: 20 Jul-07 01:30 PM Oil Water. Setup Date: 18 Jul-07 01:30 PM Brine: Sample No: 16-7755-9369 Code: Sample Date: 17 Jul-07 02:00 PM Material: Receive Date: 18 Jul-07 09: 15 AM Source: SampleAge: 23h (1°C) Station:, Survival (4811) EPAl821/R-02-012 (2002) Hard-Mod, Hard Synthetic Water 2007025083 Power Plant Effluent NPDES Permit # 57-00-1-04 Comparisons: Report Date: Analysis: Page 1 of 1 23 Jul-07 10:22 AM 11-5964-96841daec07c University of Iowa-Hygienic Laboratory Duration: 48h Species: Cerlodaphnia dubia Source: Environmental Protection Agency Client Duane Amold Energy Center Project: Iowa WET Test Comments: Sample filtered for the removal of indigenous organisms or large particulates, Endpoint Analysis Type Sample Link Control Link Date Analyzed Version 48h Proportion Survived Comparison 06-7190-7087 06-7190-7087 23 Jul-07 10:22 AM CETISv1,1.2 Method Alt H Data Transform Zeta NOEL LOEL Toxic Units ChV PMSD Wilcoxon Rank Sum Two-Sample C>T Angular (COrrected) 4.4 >4.4 22.7273 N/A 5.00% Group Comparlsons Control vs Conc-% Statistic Critical P-Value Ties Decislon(O.05} Dilution Water 4.4 18 0.4429 4 Non-Significant Effect Test Acceptability Attribute Statistic TAC Range Overlap Decision Control Response 1 ANOVATabl/t Source Sum of Squares BetWeen 0 Error 0 Total 0 ANOVA Assumptions Attribute Test Variances Modified Levene Data Summary Conc-% Control Type Count 0 Dilution Water 4 4.4 4 Data Detail Conc-% Control Type Rep 1 0 Dilution Water 1.00000 4,4 1.00000 000-205-102-2 0.9-NL Yes Passes acceptability criteria Mean Square OF F Statistic P-Value Decision(O.OS) 0 1 65535.0 0,00000 SigniflC8nt Effect 0 6 0 7 Statistic Critical P-Value Decision(O.01) 65535,00000 13.74502 0.00000 UnequalVanances Original Data Transformed Data Mean 1,00000 1.00000 Rep 2 1,00000 1.00000 Minimum Maximum SO 1.00000 1.00000 Rep 3 1.00000 1.00000 1.00000 0.00000 1.00000 0.00000 Rep 4 RepS 1,00000 1,00000 Page 5 of6 CETIS""' v1,1.2revQ Mean Minimum Maximum SO 1,34528 1.34528 0,00021 1.34528 1.34528 1,34528 0.00021 RepS Rep 7 Rep 8 Analyst: TvTS Comparisons: Page I of I Report Date: 23 Jul-07 10:22 AM CETIS Analysis Detail Analysis: 09-0416-1792/daecO7c FCeriodaphnia 48-h Acute Survival Test University of Iowa-Hygienic Laboratory] Test No: 10-1870-7871 Test Type: Survival (48h) Duration: 48h Start Date: 18 Jul-07 01:30 PM Protocol: EPA/821/R-02-012 (2002) Species: Cerlodaphnia dubia Ending Date: 20 Jul-07 01:30 PM Dil Water. Hard-Mod. Hard Synthetic Water Source: Environmental Protection Agency Setup Date: 18 Jul-07 01:30 PM Brine: Sample No: 16-7755-9369 Code: 2007025083 Client: Duane Arnold Energy Center Sample Date: 17 Jul-07 02:00 PM Material: Power Plant Effluent Project: Iowa WET Test Receive Date: 18 Jul-07 09:15 AM Source: NPDES Permit #Sample Age: 23h (1 *C) Station: 57-00-1-04 Comments: Sample filtered for the removal of indigenous organisms or large particulates. Endpoint Analysis Type Sample Link Control Link Date Analyzed Version 48h Proportion Survived Comparison 06-7190-7087 06-7190-7087 23 Jul-07 10:22 AM CETISv1.1.2W Rtkod Alt H Data Transform Zeta NOEL LOEL Toxic Units ChV PMSD Wilcoxohi Rank Sum Two-Sample C >T Angular (Corrected)} 100 >100 I NIA 5.00%Group Comparisons Control vs Conc-% Statistic Critical P-Value Ties Decision(0.05) Dilution Water 100 18 0.4429 4 Non-Significant Effect Test Acceptability Attribute Statistic TAC Range Overlap Decision Control Response 1 0.9 -NL Yes Passes acceptability criteria ANOVA Table Source Sum of Squares Mean Square DF F Statistic P-Value Decision(0.05) Between 0 0 1 85535.0 0.00000 Significant Effect Error 0 0 6 Total 0 0 7 ANO VA Assumptions Attribute Test Statistic Critical P-Value Decision(O.01) Variances Modified Levene 65535.00000 13.74502 0.00000 Unequal Variances Data Summary Original Data Transformed Data Conc-% Control Type Count Mean Minimum Maximum SD Mean Minimum Maximum SD 0 Dilution Water 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 100 4 1.00000 1,00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 Data Detail Conc-% Control Type Rep 1 Rep 2 Rep 3 Rep 4 Rep 5 Rep 6 Rep 7 Rep 8 0 Dilution Water 1.00000 1.00000 1.00000 1.00000 100 1.00000 1.00000 1.00D00 1.0000 Page 6 of 6 000-205-102-2 CETIS T h vl.1.2revQ Analyst: "F Approval: L Comparisons: CETIS Analysis Detail Report Date: Analysis: Page f of 1 23 Jul"()7 10:22 AM 09-0416-17921daec07 c Ceriodaphnia 48-h Acute Survival Test University of Iowa-Hygienic Laboratory Test No: 10-1870-7871 Test Type: Survival (48h) Duration: 4Sh Start Date: 18 Jul"()7 01:30 PM Protocol: EPN8211R-02"()12 (2002) Species: Cerlodaphnia dubia Ending Date: 20 Jul-07 01 :30 PM Oil Water: Hard-Mod. Hard Synthetic Water Source: Environmental Protection Agency Setup Date: 18 Jul-07 01:30 PM Brine: Sample No: 16-7755-9359 Code: 2007025083 Client: Duane Arnold Energy Center Sample Date: 17 Jul-07 02;00 PM Material: Power Plant Effluent Project: Iowa WET Test Receive Date: 18 Jul-07 09:15 AM Source: NPDES Permit # Sample Age: 23h (1 *C) Station: 57-oO-1"()4 Comments: Sample filtered for the removal of indigenous organisms or large particulates. Endpoint Analysis Type Sample Link Control Link Date Analyzed Version 4Bh Proportion Survived Comparison 06-7190-7087 06-7190-7087 23 Jul-D7 10:22 AM CETISv1.1.2 Method Alt H Data Transform Zeta NOEL LOEL Toxic Units ChV PMSD Wilcoxon Rank Sum Two-Sample C>T Angular (Corrected) 100 >100 1 NfA 5.00% -Group Comparisons Control vs Conc-% Statistic Critical P-YaJue Ties Decision(O.05) Dilution Water 100 18 0.4429 4 Non-Significant Effect Test Acceptability Attribute Statistic TAC Range Overlap Decision Conlrol Response 1 0.9-Nl Yes Passes acceptability criteria AN OVA Table Source SUm of Squares Mean Square OF F Statistic P-Value Decision(O.05) Between 0 0 1 65535.0 0.00000 SignifICant Effect Error 0 0 6 Total 0 0 7 ANOVA Assumptions Attribute Test Statistic Critical P-Value Decision(O.01 ) Variances Modified Levene 65535.00000 13.74502 0.00000 Unequal Variances Data Summary Original Data Transformed Data Conc-% Control Type Count Mea.n Minimum Max:imum SD Mean Minimum Maximum SO 0 Dilution Water 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34526 1.34528 0.00021 100 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 Data Detail Conc-% Control Type Rep 1 Rep 2 Rep 3 Rep 4 RepS Rep 6 Rep 7 RepS 0 Dilution Water 1.00000 1.00000 1.00000 1.00000* 100 1.00000 1.00000 1.00000 1.00000 000-205-102-2 Page 6 of6 CETIST10I v1.1.2revQ Analyst: /' "" I HYGIENIC LABORATOiY THE Iowa's Environmental and Public Health Laboratory UNIVEPITY Z20 South Ankeny Boulevad OF IOWA An keny, Iowa 50023 515-725-1600 Fax515-725-1642 www.uhl.uiowa.eduJuly 24, 2008Jerald Hogan Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 RE: UHL Sample Number: 2008025369

Dear Mr. Hogan:

Analytical and toxicity test results for the sample listed above are enclosed. This sample was received by our Laboratory for effluent toxicity testing on July 16, 2008.As required by the Iowa Department of Natural Resources, statistical analyses wereperformed on the 48 hour mortality data. These statistical analyses determined there was no significant difference in survival between the effluent dilution and the control.As a result, your sample, UHL Lab No. 2008025369, "passed" the toxicity tests.The University Hygienic Laboratory appreciates this opportunity to provide you with our services. Questions regarding the test or results should be directed to Ryan Thompson, Tim Blake, John Miller III, or me. Test analysts can be contacted on the dedicated WET program phone line, (515) 725-1648.The charge for this test is $425 plus a sampling charge of $125, makes the total cost$550. Following the end of the month a statement of this charge will be directed to the above address.Sincerely, David Schelling Limnologist JM/dms Enclosure c: Accounting Page 1 of 6 L THEfm UNlVERSI1Y OF IOWA July 24, 2008 Jerald Hogan Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 RE: UHL Sample Number: 2008025369

Dear Mr. Hogan:

HYGIENIC lABORAIDRY Iowa's EnvironmentaJ and Public Health Laboratory 2220 South Ankeny Boulellard Ankeny, Iowa 50023 515-725-1600 Fax 515-725-1642 www.unl.uiowa.edu Analytical and toxicity test results for the sample listed above are enclosed. This sample was received by our Laboratory for effluent toxicity testing on July 16,2008. As required by the Iowa Department of Natural Resources, statistical analyses were performed on the 48 hour' mortality data These statistical analyses determined there was no significant difference in survival between the effluent dilution and the control. As a result, your sample, UHL Lab No. 2008025369, "passed" the toxicity tests. The University Hygienic Laboratory appreciates this opportunity to provide you with our services. Questions regarding the test or results should be directed to Ryan Thompson, Tim Blake, John Miller flI, or me. Test analysts can be contacted on the dedicated WET program phone line, (SIS) 725-1648. The charge for this test is $425 plus a sampling charge of $125, makes the total cost $550. Following the end of the month. a statement of this charge will be directed to the above address. . Sincerely, David Schelling Limnologist JMldms Enclosure c: Accounting Page 1 of6 Form #542-1381 Iowa Department of Natural Resources Effluent Toxicity Testing Report Form 48-Hour Acute Test FACILITY DATA Facility Name Duane Arnold Energy Center NPDES # IA 57-00-1-04 Sampling Location Outfall #001 Diluted effluent sample ratio (from permit)Address 3277 DAEC Road City/State/Zip Palo, IA 52324 Lab Sample # 2008025369 Date Collected July 15, 2008, 15:45 4.40%Date Received July 16, 2008, 10:00 Temperature upon receipt 5 0 C ORGANISM DATA Pimephales promelas age 13 Days Reference Toxicant Sodium Chloride Reference LC50 6.81 (95% Conf. Int, 6.58-7.04) Ceriodaphnia a age <24 Hours Reference Toxicant Sodium Chloride gmIL Reference LC50 1.82 (95% Conf. Int. 1.68-1.95) gm/L SAMPLE DATA (100% EFFLUENT)Temperature 24 -C, Initial D.O. 7.0 mg/L, D.O. (end of test) 7.3 mg/L, pH 7.8 Units, pH (end of test) 8.3 Units, Ammonia Nitrogen (as N) 0.14 mg/L, Total Ammonia (as NH 3) 0.17 rmg/L, Unionized Ammonia (calculated as NH 3) <0.01 mg/L Total Residual Chlorine <0.1

• mg/L, Specific Conductance 2100 imhos MORTALITY DATA Laboratory (Name)Test begun (Date)University Hygienic Laboratory July 16, 2008, 13:40Test ended (date) July 18, 2008, 14:40 promelas Mortality (Number Dead/Number Tested)Conc. Bk. ] Bk. 2 Bk. 3 Bk. 4Ceriodaphnia dubia Mortality (Number Dead/Number Tested)Bk. I Bk. 2 Bk 3 Bk. 4 P F a a P F a a s i s i 01_5 015 o215 s t /5 o/__5 01__5 o/_5 s I Ctrl.4.40% 0/5 .0/5 015 0/5 , (X)() 0/5 0/5 0/5 0/5 (X) ()100% 0/5 0/5 0/5 0/5 MX) () o/5 0/5 0/5 0/5 (X) ()EFFLUENT TOXICITY TESTING RESULTS PASS (XXX) FAIL ( )U.S. EPA-822 -R-02-012 October 2002 Comments: "Total Residual Chlorine analyzed by Hach Colorimeter.
  • Sample filtered for removal of indigenous organisms or large particulates.

Date Reported: 'JUL 2 4 20068 Page 2 of 6 Form #542-1381 Iowa Department of Natural Resources Effluent Toxici.ty Testing Report Form 48-Hour Acute Test FACILITY DATA Facility Name Duane Arnold Energy Center Lab Sample # _______ _ NPDES # IA 57-00-1-04 Date Collected July 15,2008, 15:45 Sampling Location _____ ,...--_____________________ _ Diluted effluent sample ratio (from permit) _4.:.;.:...;..40.:.:%:..:o ______ Address 3277 DAEC Road Date Received July 16, 2008, 10;00 City/StatelZip Palo, lA 52324 Temperature upon receipt 5°C ORGANISM DATA Pimephales promelas age __ Ceriodapbnia dubia age Reference Toxicant Sodium Chloride Reference Toxicant Sodium Chloride Reference LC50 6.81 (95% Conf.lnt. 6.58-7.04) gmJL Reference LCSO 1.&2 (95% Cont. Inll.68-J.95) gmIL SAMPLE DATA (100% EFFLUENT) Temperature 24 cC, Initial D.O. 7.0 mg!L, D.O. (end of test) 7.3 mg/L, pH 7.8 Units, pH (end oftest) Units, Amm9nia Nitrogen (as N) _0,_1_4 _____ mg/L, Total Ammonia (as NH3) 0.17 mg/L, Unionized Ammonia (calculated as NH3) <0.01 mg/L Total Residual Chlorine <0.1

• mg!L, Specific Conductance 2100 f.U11hos MORTALITY DATA Laboratory (Name) University Hygienic Laboratory Test begun (Date) July 16,2008,13:40 Test ended (date) July 18,2008, 14:40 Pimephales promelas Mortality Ceriodaphnia dubia Mortality (Number DeadlNumber Tested) (Number DeadINumber Tested) Cone. Bk. I Bk.2 Bk. 3 Bk. 4 Bk. 1 Bk.2 Bk. 3 Bk.4 P F P F a a a a s i s Ctrl. 015 0(5 0(5 0/5 s 1 015 0/5 0/5 DIS s 4.40% 0/5 015 015 0/5 (X) () 0/5 m 0/5 0/5 (X) 0 100% 015 0/5 015 0/5 (X) () 0/5 0/5 0/5 0/5 (X) () EffLUENT TOXICl1Y TESTING RESULTS PASS (XXX ) FAIL ( ) U.S. EPA*82J-R-02-OJ2 October 2002 Comments:

"'Total Residual Chlorine analyzed by Hach Colorimeter. ""'Sample filtered for removal of indigenous organisms or large particulates. Date Reported: 'JUl 24 2008 Page 2 of6 Comparisons: Report Date: Analysis: Page I of 2 24 Jul-08 8:17 AM 07-5048-7443/daec08f CETIS Analysis Detail Fathead Minnow 48-h Acute Survival Test University of lowa-Hygienic Laboratory Test No: 04-4702-0090 Test Type: Survival (48h) Duration: 48h Start Date: 16 Jul-08 01:40 PM Protocol: EPA/821IR-02-012 (2002) Species: Pimephales promelas Ending Date: 18 Jul-08 01:40 PM Dil Water. Hard-Mod. Hard Synthetic Water Source: Aquatic Biosystems, CO Setup Date: 16 Jul-08 01:40 PM Brine: Sample No: 03-7354-1426 Code: 2008025369 Client: Duane Arnold Energy Center Sample Date: 15 Jul-08 03:45 PM Material: Industrial Effluent Project: Iowa WET Test Receive Date: 16 Jul-08 10:00 AM Source: NPDES Permit #Sample Age: 22h (5 °C) Station: 57-00-1-04 Comments: Sample filtered for removal of indigenous organisms or large particulates. Endpoint Analysis Type Sample Link Control Link Date Analyzed Version 48h Proportion Survived Comparison 09-0402-0055 09-0402-0055 23 Jul-08 11:44 AM CETISvl.1.2 Method Aft H Data Transform Zeta IINOEL LOEL Toxic Units ChV PMSD Wilcox'on Rank Sum Two-Sample C > T Angular (Corrected) II44 >4.4 22.7273 NIA 5.00%Group Comparisons Control vs Conc-% Statistic Critical P-Value Ties Decision(O.05) Dilution Water 4.4 18 0.4429 4 Non-Significant Effect ANOVA Table Source Sum of Squares Mean Square DF F Statistic P-Value Decision(0.05) Between 0 0 1 65535.0 0.00000 Significant Effect Error 0 0 6 Total 0 0 7 I ANOVA Assumptions Attribute Test Statistic Critical P-Value Decision(0.01) Variances Modified Levene 65535.00000 13.74502 0.00000 Unequal Variances Data Summary Original Data Transformed Data Conc-% Control Type Count Mean Minimum Maximum SD Mean Minimum Maximum SD 0 Dilution Water 4 1.00000 .1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 4.4 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 Data Detail Conc-% Control Type Rep I Rep 2 Rep 3 Rep 4 Rep 5 Rep 6 Rep 7 Rep 8 Rep 9 Rep 10 Dilution Water 1.00000 1,00000 1.00000 1.00000 4.4 1.00000 1.00000 1.00000 1.00000 Page 3 of 6 CETIST0 vl.A.2revQ Analysthm'.5, Approval: TiA-1-6 000-205-102-1 CETIS Analysis Detail Fathead Minnow 4IJ..h Acute SurviVal Test Test No: 04-4702-0090 Test Type: Survival (48h) Start Date: 16 Jul-oB 01:40 PM Protocol: EPAl821/R-02-012 (2002) Ending Date: 18 Jul-oa 01:40 PM Oil Water: Hard-Mod. Hard Synthetic Water Setup Date: 16 Jut-OB 01 :40 PM Brine: Sample No: 03-7354-1426 Code: 2008025389 Sample Date: 15 Jul-08 03:45 PM Material: Industrial Effluent Receive Date: 16 Jut-08 10:00 AM Source: NPDES Permit # Sample Age: 22h (5°C) StatIon: 57-00-1-04 Comments: Sample filtered for removal Cif indigenous organisms or larae particulates. Comparisons: Report Date: Analysis: Page 1 of 2 24 Jul-OS 8:17 AM 07-5048-7443/daec08f University of Iowa-Hygienic laboratory Duration: 48h Species: Pimephales promelas Source: Aquatic Biosystems, CO Client: Duane Arnold Energy Center Project: Iowa WET Test Endpoint Analysis Type SampleUnk Control Link Date Analyzed Version 48h Proportion Survived Comparison 09-0402-0055 09-0402-0055 23 Jul-08 11 :44 AM CETISv1.1.2 Method A1tH Wilcoxon Rank Sum Two-Sample C>T Group Comparisons Control vs Conc-% DUution Water 4.4 ANOVATable Source Sum of Squares Between 0 Error 0 Total 0 ANOVA Assumptions Attribute Test Variances Modified Levene Data Summary Conc-% Control Type Count 0 Dilution Water 4 4.4 4 Data Detail Conc-% Control Type Rep 1 0 Dilution Water 1.00000 4.4 1.00000 000-205-102-1 Data Transform Zeta NOEL LOEL Toxic Units ChV PMSD Angular (Corrected) 4.4 >4.4 22.7273 NlA 5.00% Statistic Critical P-Value Ties Decision(O.OS) 18 0.4429 4 Non-Significant Effect Mean Square OF F Statistic P-Value Declslon(O.05) 0 1 65535.0 0.00000 Signillcant Effect 0 6 0 7 Statistic Critical P-Value Decision(O.01 ) 65535.00000 13.74502 0.00000 Unequal Variances Original Data Transformed Data Mean Minimum Maximum SO Mean Minimum Maximum SO 1.00000 1.00000 1.00000 0.00000 1.34526 1.34526 1.34526 0.00021 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 Rep 2 Rep 3 Rep 4 RepS Rep 6 Rep 7 Rep 8 Rep 9 RepiD 1.00000 1.00000 1.00000 1.00000 1.00000 1.00000 Page 3 of6 CETIS"" v1.1.2revQ Analyst.l:)Ms Approval: Twb Comparisons: Report Date: Analysis: Page 2 of 2 24 Ju-08 8:17 AM 16-8721-3837/daec08f CETIS Analysis Detail IFathead Minnow 48-h Acute Survival Test University of Iowa-Hygienic Laboratory Test No: 044702-0090 Test Type. Survival (48h) Duration: 48hI Start Date' 16 Jul-08 01:40 PM Protocol: EPN821/R-02-012 (2002) Species: Pirnephales promelas Ending Date: 18 Jul-08 01:40 PM DOil Water Hard-Mod. Hard Synthetic Water Source: Aquatic Biosystems, CO Setup Date: 16 Jul08 01:40 PM Brine: Sample No: 03-7354-1426 Code: 2008025369 Client. Duane Arnold Energy Center Sample Date: 15 Jul-08 03:45 PM Material: Industrial Effluent Project: Iowa WET Test Receive Date: 16 Jul-08 10:00 AM Source: NPDES Permit#Sample Age: 22h (5 "C) Station: 57-00-1-04 Comments: Sample filtered for removal of indigenous organisms or large particulates. Endpoint Analysis Type Sample Link Control Link Date Analyzed Version48h Proportion Survived Comparison 09-0402-0055 09-0402-0055 23 Jul-08 11:45 AM CETISv1.1.2 Method Aft H Data Transform Zeta NOEL LOEL Toxic Units ChV PMSD Wilcoxon Rank Sum Two-Sample C> T Angular (Corrected) 100 >100 1 NIA 5.00%Group Comparisons Control vs Conc-% Statistic Critical P-Value Ties Decision(0.05) Dilution Water IDD 18 0.4429 4 Non-Significant Effect ANOVA Table Source Sum of Squares Mean Square DF F Statistic P-Value Decision(0.05) Between 0 0 1 65535.0 0.00DO Significant Effect Error 0 0 6 Total 0 0 7[ANOVA Assumptions Attribute Test Statistic Critical P-Value Decision(O.01) Variances Modified Levene 65535.00000 13.74502 0.00000 Unequal Variances lCData Summary Original Data Transformed Data Conc-% Control Type Count Mean Minimum Maximum SD Mean Minimum Maximum SD Dilution Water 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 100 4 1.0DO00 1.0D000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 Data Detail Conc-% Control Type Rep I Rep 2 Rep 3 Rep 4 Rep 5 Rep 6 Rep ? Rep 8 Rep 9 Rep 10 0 Dilution Water 1.00000 1.00000 1.00000 1.00000 100 1.00000 1.00000 1.00000 1.00000 Page 4 of 6 CETISTm vlt1p2revQ Analyst:.hftg -Approval. T-IV6 rrnnn --);.i1n?_1* CETIS Analysis Detail Fathead Minnow 48-f1 Acute Survival Test Test No: 04-4702-0090 Test Type: Survival {48h} Start Date: 16 Jul-08 01:40 PM Protocol: EPN821IR-02-o12 (2002) Ending Date: 1B Jut-OB 01 :40 PM Oil Water: Hard-Mod. Hard Synlhetlc Water Setup Date: 16 JuJ-OB 01:40 PM Brine: Sample No: 03-n54-1426 Code: 2008025369 Sample Date: 15 Jul-oB 03:45 PM Material: Industrial Effluent Receive Date: 16 Jul-0810:00 AM Source: NPDES Permit # Sample Age: 22h (5 *C) Station: 57-00-1-04 Comments: Sample finered for removal of indigenous organisms or large particulates. Comparisons: Report Date: Analysis: Page 2 of 2 24 Jul-08 8:17 AM 16-8721-3837/daecOSf University of Iowa-Hygienic Laboratory Duration: 48h Species: Pimephales promelas Source: Aquatic Biosystems, CO Client: Duane Amold Energy Center Project: Iowa WET Test Endpoint Analysis Type Sample L1nlt Control L1nlt Date Analyzed Version 48h Proportion Survived Comparison 09-0402-0055 09-0402-0055 23 Jul-08 11 :45 AM CETISv1.1.2 Method Aft H Wilcoxon Rank Sum Two-Sample C>T Group Comparisons Control vs Conc-% Dilution Water 100 ANOVATable S()urce Sum of Squares 0 Error 0 Total 0 AN OVA Assumptions Attribute Test Variances Modified Levene Data Summary Conc-% Control Type Count 0 Dilution Water 4 100 4 Data Detail Conc-% Control Type Rep 1 0 Dilution Water 1.00000 100 1.00000 Data Transform Zeta NOEL LOEL Toxic Units ChV PMSD Angular (Corrected) 100 >100 1 N/A 5.00% Statistic Critical P-Value Ties Oecislon(O.OS) 18 0.4429 4 Non-Significant Effect Mean Square OF F Statistic P-Value Oecision(O.OS) 0 1 65535.0 0.00000 Significant Effect 0 6 0 7 Statistic Critical P-Value Decislon(O.01 ) 65535.00000 13.74502 0.00000 Unequal Variances Original Data Transformed Data Mean Minimum Maximum SO Mean Minimum Maximum SO 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 Rep 2 Rep 3 Rep 4 RepS Rep 6 Rep 7 Rep 8 Rep 9 Rep 10 1.00000 1.00000 1.00000 1.00000 1.00000 1.00000 Page 4 of6 CETISlU v1.1.2revQ Analyst:2>t:t )' Approval: Comparisons: Page 1 of 2 Report Date: 24 Jul-08 8:18 AM CETIS Analysis Detail AnalysIs :t6-0088-7 dae0O Ceriodaphnia 48-h Acute Survival Test University of iowa-Hygienic Laboratory Test No: 06-0154-6441 Test Type: Survival (48h) Duration: 48h Start Date; 16 Jul-08 01:40 PM Protocol: EPA/821/R-02-012 (2002) Species: Ceriodaphnia dubia Ending Date: 18 Jul-08 01:40 PM Dil Water: Hard-Mod. Hard Synthetic Water Source: Aquatic Biosystems, CO Setup Date: 16 Jul-08 01:40 PM Brine: Sample No: 03-7354-1426 Code: 2008025369 Client: Duane Arnold Energy Center Sample Date: 15 Jul-08 03:45 PM Material: Industrial Effluent Project Iowa WET Test Receive Date: 16 Jul-08 10:00 AM Source, NPDES Permit #Sample Age: 22h (5 'C) Station: 57-00-1-04 Comments; Sample filtered for removal of indigenous organisms or large particulates. Endpoint Analysis Type Sample Link Control Link Date Analyzed Version 48h Proportion Survived Comparison 06-4728-0210 06-4728-0210 23 Jul-08 11:46 AM CETISv1.1.2 Alt H Data Transform Zeta INOEL LOEL Toxic Units cbV eMs Wilcoxon Rank Sum Two-Sample C > T Angular (Corrected)-4.4 >4.4 22.7273 N/A 5,00%Group Comparisons Control vs Conc-% Statistic Critical P-Value Ties Decision(O.05) Dilution Water 4.4 18 0.4429 4 Non-Significant Effect Test Acceptability Attribute Statistic TAC Range Overlap Decision Control Response 1 0.9 -NL Yes Passes acceptability criteria ANOVA Table Source Sum of Squares Mean Square DF F Statistic P-Value Decision(O.05) Between 0 0 1 65535.0 0.00000 Significant Effect Error 0 0 6 Total 0 0 7 ANOVA Assumptions Attribute Test Statistic Critical P-Value Decision(O.O1) Variances Modified Levene 65535.00000 13.74502 0.00000 Unequal VariancesData Summary Original Data Transformed Data Conc-% Control Type Count Mean Minimum Maximum SD Mean Minimum Maximum SD 0 Dilution Water 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 4.4 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 SData DetailConc-%/ Control Type Rep I Rep 2 Rep 3 Rep 4 Rep 6 Rep 6 Rep T Rep 8 Rep 9 Rep 100Dilution Water 1.100000 1.00000 1.00000 1.00000[4.4 1.00000 1.00000 1,00000 1.00000 Page 5 of 6 OD25121Cr=TIS'm v .1 .2revQ Analyst:____ Approval:____ CETIS Analysis Detail Ceriodaphnia 48-h Acute Survival Test Test No: 06-0154-6441 Test Type: Start Date: 16 Jul-08 01 :40 PM Protocol: Ending Date: 18 Jul-OB 01:40 PM Oil Water: Setup Date: 16 Jul-08 01:40 PM Brine: Sample No: 03-7354-1426 Code: Sample Date: 15 Jul-08 03:45 PM Material: Receive Date: 16 Jul-08 10:00 AM Source; Sample Age: 22h (5 *C) Station: SUrvival (48h) EPN821IR-02-012 (2002) Hard-Mod. Hard Synthetic Water 2008025369 Industrial Effluent NPDES Permit # 57-00-1-04 Comparisons: Report Date: Analysis; Page 1 of 2 24 Jul.{)8 8:18 AM 16-0088-96751daec08c University of Iowa-Hygienic Laboratory Duration: 4Bh Species: Cerlodaphnia dubia Source: Aquatic Blosystems, CO Client: Duane Amold Energy Center Project: Iowa WET Test Comments: Sample filtered for removal of indigenous organisms or large particulates. Endpoint AnalYSis Type Sample Link Control Link Date Analyzed Version 4Bh Proportion Survived Comparison 06-4728-0210 06-4728-0210 23 JuI-08 11 :46 AM CETISv1.1.2 Method Ait H Data Transform Zeta NOEL LOEL Toxic Units ChV PMSD Wilcoxon Rank Sum Two-Sample C>T Angular (Corrected) 4.4 >4.4 22.7273 NlA 5.00% Group Comparisons Control vs Conc-Of. Statistic Critical P-Value TieS DecisJon{O.05) Dilution Water 4.4 18 0.4429 4 Non-Significant Effect Test Acceptability Attribute Statistic TAC Range Overlap Decision Control Response 1 ANOVATabJe Source Sum of Squares Between 0 Error 0 Total 0 ANOVA Assumptions Attribute Test Variances Modified Levene Data Summary Cone-%' Control Type Count 0 Dilution Water 4 4.4 4 Data Detail Conc-Of. Control Type Rep 1 0 DilUllon Water 1.00000 4.4 1.00000 000-205-102-1 0.9 -NL Yes Passes acceptability criteria Mean Square DF F Statistic P-Value Decision(0.05) 0 1 65535.0 0.00000 Significant Effect 0 6 0 7 S.tatistic Critical P-Value Decision(O.01 ) 65535.00000 13.74502 0.00000 Unequal Variances Original Data Transformed Data Mean 1.00000 1.00000 Rep 2 1.00000 1.00000 Minimum Maximum SO 1.00000 1.00000 Rep 3 1.00000 1.00000 1.00000 0.00000 1.00000 0.00000 Rep 4 RepS 1.00000 1.00000 Page 5 of6 CErIS"'" v1.1.2revQ Mean Minimum Maximum SO 1.34528 1.34528 1.34528 0.00021 1.34528 1.34528 1.34528 0.00021 Rep 6 RepT Rep 6 Rep 9 Rep 10 Approval: __ _ Comparisons: Page 2 of 2 Report Date: 24 Jul-08 8:18 AM CETIS Analysis Detail Analysis: 05-6018-8449/daec08c Ceriodaphnia 48-h Acute Survival Test University of Iowa-Hygienic Laboratory Test No: 0"-0154-6441 Test Type: Survival (48h) Duration: 48h Start Date: 16 Jul-08 01:40 PM Protocol: EPN821/R-02-012 (2002) Species: Ceriodaphnia dubia Ending Date: 18 Jul-08 01:40 PM DiO Water: Hard-Mod. Hard Synthetic Water Source: Aquatic Biosystems, CO Setup Date: 16 Jul-08 01:40 PM Brine: Sample No: 03-7354-1426 Code: 2008025369 Client: Duane Arnold Energy Center Sample Date: 15 Jul-08 03:45 PM Material: Industrial Effluent Project: Iowa WET Test Receive Date: 16 Jul-08 10:00 AM Source: NPDES Permit # Sample Age: 22h (5 *C) Station: 57-00-1-04 Comments: Sample filtered for removal of indigenous organisms or large particulates. Endpoint Analysis Type Sample Link Control Link Date Analyzed Version 48h Proportion Survived Comparison 06-4728-0210 06-4728-0210 23 Jul-08 11:47 AM CETISv1.1.2 Method Aft H Data Transform Zt NOL LOEL Toxic Units ChV PMSD SWilcoxon Rank Sum Two-Sample C > T Angular (Corrected) 100 >100 1 N/A 5.00%Group Comparisons Control vs Conc-% Statistic Critical P-Value Ties Decision(O.05) Dilution Water 100 18 0.4429 4 Non-Significant Effect Test Acceptability Attribute Statistic TAC Range Overlap Decision Control Response 1 0.9 -NL Yes Passes acceptability criteria ANOVA Table Source Sum of Squares Mean Square DF F Statistic P-Value Declsion(0.05) Between 0 0 1 65535.0 0.00000 Significant Effect Error 0 0 6 Total 0 0 7 ANOVA Assumptions Attribute Test Statistic Critical P-Value Decision(O.01) Variances Modified Levene 65535.00000 13.74502 0.ODD0O Unequal Variances Data Summary Original Data Transformed Data Conc-% Control Type Count Mean Minimum Maximum SD Mean Minimum Maximum SD 0 Dilution Water 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 100 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 Data Detail Conc-% Control Type Rep I Rep 2 Rep 3 Rep 4 Rep 5 Rep 6 Rep 7 Rep 8 Rep 9 Rep 10 0 Dilution Water 1.00000 1.00000 1.00000 1.00000 100 1.00000 1.00000 1.00000 1.00000 Page 6 of6 000-205-102-1 v1.1.2revQ Analyst: .Approval: ..CETIS Analysis Detail Ceriodaphnia 48-h Acute Survival Test Test No: 05-0154-6441 Start Date: 16 Jul-08 01:40 PM Ending Date: 18 Jul-08 01:40 PM Setup Date: 16 Jul-OB 01:40 PM Sample No: 03-7354-1426 Sample Date: 15 Jul-08 03:45 PM Receive Date: 16 Jul-0810:00 AM Sample Age: 22h (5 *C) Test Type: Survival (4Bh) Protocol: EPAl821IR-02-012 (2002) Oil Water: Hard-Mod. Hard Synthetic Water Brine: Code: 2008025369 Material: Industrial Effluent Source: NPDES Permit # Station: 57-00-1-04 Comparisons: Report Date: Analysis: Page 2 of 2 24 Jul-08 8:18AM University of lowa-Hygienic Laboratory Duration: 48h Species: Ceriodaphnia dubia Source: Aquatic Biosystems, CO Client: Duane Amold Energy Center Project: Iowa WET Test Comments: Sample filtered for removal of indigenous organisms or large particulates. Endpoint Analysis Type Sample link Control Link Date Analyzed Version 48h Proportion Survived Comparison 06-4728-0210 06-4728-0210 23 Jul-08 11 :47 AM CETISv1.1.2 Method Aft H Data Transform Zeta NOEL LOa Toxic Units ChY PMSD Wilcoxon RanI< Sum Two-Sample C>T Angular (Corrected) 100 >100 1 N/A 5.00% Group Comparisons Control vs Conc-% Statistic Critical P*Value Ties Dilution Water 100 18 0.4429 4 Non-Significant Effect Test Acceptability Attribute Statistic TAC Range Overlap Decision Control Response 1 0.9-NL Yes Passes acceptabirlty criteria ANOYATable Source Sum of Squares Mean Square OF F Statistic P-Value Declsion(O.OS) Between 0 0 1 65535.0 0.00000 Significant Effect Error 0 0 6 Total 0 0 7 ANOVA Assumptions Attribute Test Statistic Critical P-Yalue Declsion(O.01 ) Variances Modified Levene 65535.00000 13.74502 0.00000 Unequal Variances Data Summary Original Data Transfonned Data Conc-% Control Type Count Mean Minimum Maximum SO Mean Minimum Maximum SO 0 Dilution Water 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 100 4 1.00000 1.00000 1.00000 0.00000 1.34528 1.34528 1.34528 0.00021 Data Detail Conc-% Control Type Rep 1 Rep 2 Rep 3 Rep 4 RepS RepS Rep 7 Rep 8 Rep 9 Rep 10 0 Dilution Water 1.00000 1.00000 1.00000 1.00000 100 1.00000 1.00000 1.00000 1.00000 000-205-102-1 Page 6 of6 CETISTM v1.1.2revQ Analyst: Approva!: llA./..-t> Manufacturer Manufacturers Name Usage Rates Purpose Injection point Discharge 001 ,,, GE Betz Continuum AEC 3110 50 gallons/day Corrosion Inhibitor Cooling Tower GE Betz Spectrus BD1501E 10 gallons/day Minimize Scaling Cooling tower GE Betz Inhibitor AZ8100 Currently not in use Corrosion Inhibitor Cooling tower K.A. Steel Chemicals Sodium Hypochlorite 200 gallon/day Algaecide Cooling tower Koch Sulfur Products Sulfuric Acid 93% 1000 gallon/day PH Balance Cooling tower 5 gallons/week GE Betz Spectrus NX1007 summer only Biocide Cooling tower Closed cooling GE Betz Corrshield MD4100 <10 gallons/year Corrosion Inhibitor systems Closed cooling GE Betz Spectrus NX1 105 <1 liter/year Biocide systems Closed cooling GE Betz .Spectrus NX1 106 < 1 liter/year Biocide systems Discharge 0022 1 Sewage_T rea t men t FMC Soda Ash 50 lbs/week pH Balance Basins Manufacturer Manufacturers Name Rates Purpose fniection point Discharge 001 GE Betz Continuum AEC 3110 50 _9_allons/day Corrosion Inhibitor Cooling Tower GE Betz Spectrus BD1501E 10 gallons/day Minimize Scaling Cooling tower GE Betz Inhibitor AZ81 00 Currently not in use Corrosion Inhibitor Coofing tower K.A. Steel Chemicals Sodium Hypochlorite 200 gallon/day Algaecide tower Koch Sulfur Products Sulfuric Acid 93% 1000 gallon/day pH Balance Cooling tower 5 gallons/week GE Betz Spectrus NX 1007 summer only Biocide Cooling tower . Closed cooling GE Betz Corrshield MD4100 < 10 Qallons/year Corrosion Inhibitor systems Closed cooling GE Betz Spectrus NX1105 < 1 liter/year Biocide sj'stems Closed cooling GE 8etz Spectrus NX1106 < 1 liter/year Biocide systems Discharge 002 Treatment FMC Soda Ash SO Ibslweek pH Balance Basins CONTINUUM AEC31 10 by BETZ DEARBORN FPL Energy Duane Arnold CONTINUUM AEC3110 BETZ DEARBORN FileName Language Internal ID Revision Date 000147 0082 1/3/2001 Table Of Contents 1 PRODUCT IDENTIFICATION 2 COMPOSITION / INFORMATION ON INGREDIENTS 3 HAZARDS IDENTIFICATION 4 FIRST AID MEASURES 5 FIRE FIGHTING MEASURES 6 ACCIDENTAL RELEASE MEASURES 7 HANDLING & STORAGE 8 EXPOSURE CONTROLS / PERSONAL PROTECTION 9 PHYSICAL & CHEMICAL PROPERTIES 10 STABILITY & REACTIVITY 11 TOXICOLOGICAL INFORMATION 12 ECOLOGICAL INFORMATION 13 DISPOSAL CONSIDERATIONS 14 TRANSPORT INFORMATION 15 REGULATORY INFORMATION 16 OTHER INFORMATION Hazards MSDS State NFPA HMIS (Active)Health 1 1 Flammability 1 1 Rea-tivity 0 0 Other B MATERIAL SAFETY DATA SHEET ISSUE DATE: 03-JAN-2001 BETZDEARBORN, DIVISION OF HERCULES INCORPORATED 4636 SOMERTON ROAD TREVOSE, PA 19053 BUSINESS TELEPHONE: (215) 355-3300 EMERGENCY TELEPHONE (HEALTH/ACCIDENT)

(800) 877-1940 (USA)HMIS RATINGS (SEE SECTION 16 FOR ADDITIONAL INFORMATION):

HEALTH 1 FLAMMABILITY 1 REACTIVITY 0 1 PRODUCT IDENTIFICATION Page 1 of 7 PRODUCT NAME: CONTINUUM AEC3110 PRODUCT APPLICATION AREA: WATER-BASED CORROSION INHIBITOR/DEPOSIT CONTROL AGENT.http://fplenergy.complyplus.com/MSDS/printbare.asp?S= 113&ShowTOC=I&ShowHazardRatings=l&... 6/17/2009 CONTINUUM AEC311 0 by BETZ DEARBORN FPL Energy Duane Arnold CONTINUUM AEC3110 FileName Language InternalID 000147 0082 Table Of Contents 1 PRODUCT IDENTIFICATION 2 COMPOSITION I INFORMATION ON INGREDIENTS 3 HAZARDS IDENTIFICATION 4 FIRST AID MEASURES 5 FIRE FIGHTING MEASURES 5 ACCIDENTAL RELEASE MEASURES 7 HANDLING & STORAGE 8 EXPOSURE CONTROLS I PERSONAL PROTECTION 9 PHYSICAL & CHEMICAL PROPERTIES 10 STABllm & REACTIVm II TOXICOLOGICAL INFORMATION 12 ECOLOGICAL INFORMATION 13 DISPOSAL CONSIDERATIONS 14 TRANSPORT INFORMATION 15 REGULATORY INFORMATION 16 OTHER INFORMATION Hazards MSDSState NFPA HMIS I Health 1 1 Flammability 1 1 Reactivity 0 0 Other B MATElUAL SAFETY DATA SHEET ISSUE DATE: 03-JAN-2001 BETZDEARBORN, DIVISION OF HERCULES INCORPORATED 4636 SOMERTON ROAD TREVOSE, PA 19053 BUSINESS TELEPHONE: (215) 355-3300 EMERGENCY TELEPHONE (HEALTH/ACCIDENT): (800) 877-1940 (USA) HMIS RATINGS (SEE SECTION 16 FOR ADDITIONAL INFORMATION): HEAL'l'H 1 FLAMMABILITY 1 REAC'I'IVITY 0 . 1 PRODUCT IDENTIFICATION PRODUCT NAME: CONTINUUM AEC3110 PRODUCT APPLICATION AREA: WATER-EASED CORROSION INHIBITOR/DEPOSIT CONTROL AGENT. Page 1 of7 BETZ DEARBORN Revision Date 1/3/2001 (Active) I http://fplenergy.complyplus.comIMSDS/print_bare.asp?S=113&ShowTOC=I&ShowHazardRatings:::l&... 6/17/2009 CONTINUUM AEC3 110 by BETZ DEARBORN Page 2 of 7 2 COMPOSITION / INFORMATION ON INGREDIENTSINFORMATION FOR SPECIFIC PRODUCT INGREDIENTS AS REQUIRED BY THE U.S. OSHA HAZARD COMMUNICATION STANDARD IS LISTED. REFER TO ADDITIONAL SECTIONS OF THIS MSDS FOR OUR ASSESSMENT OF THE POTENTIAL HAZARDS OF THIS FORMULATION. HAZARDOUS INGREDIENTS: CAS # CHEMICAL NAME 7558-79-4 DISODIUM PHOSPHATE (SODIUM PHOSPHATE, DIBASIC)IRRITANT (EYES)NO COMPONENT IS CONSIDERED TO BE A CARCINOGEN BY THE NATIONAL TOXICOLOGY PROGRAM, THE INTERNATIONAL AGENCY FOR RESEARCH ON CANCER, OR THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION AT OSHA THRESHOLDS FOR CARCINOGENS. 3 HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: WARNING: MAY CAUSE SLIGHT IRRITATION TO THE SKIN. MAY CAUSE SLIGHT IRRITATION TO THE EYES. MISTS/AEROSOLS MAY CAUSE IRRITATION TO UPPER RESPIRATORY TRACT.DOT HAZARD IS NOT APPLICABLE EMERGENCY RESPONSE GUIDE IS NOT APPLICABLE ODOR: MILD APPEARANCE: COLORLESS TO YELLOW, LIQUID FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE).PROPER FIRE-EXTINGUISHING MEDIA; DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER POTENTIAL HEALTH EFFECTS: ACUTE SKIN EFFECTS: PRIMARY ROUTE OF EXPOSURE; MAY CAUSE SLIGHT IRRITATION TO THE SKIN.ACUTE EYE EFFECTS: MAY CAUSE SLIGHT IRRITATION TO THE EYES.ACUTE RESPIRATORY EFFECTS: MISTS/AEROSOLS MAY CAUSE IRRITATION TO UPPER RESPIRATORY TRACT.INGESTION EFFECTS: MAY CAUSE SLIGHT GASTROINTESTINAL IRRITATION. TARGET ORGANS: NO EVIDENCE OF POTENTIAL CHRONIC EFFECTS.MEDICAL CONDITIONS AGGRAVATED: NOT KNOWN.SYMPTOMS OF EXPOSURE: MAY CAUSE REDNESS OR ITCHING OF SKIN.http://fplenergy.complyplus.com/MSDS/printbare.asp?S= 113&ShowTOC=l&ShowHazardRatings=l&... 6/17/2009 CONTINUUM AEC311 0 by BETZ DEARBORN 2 COMPOSITION / INFORMATION ON INGREDIENTS INFORMATION FOR SPECIFIC PRODUCT INGREDIENTS AS REQUIRED BY THE U.s. OSHA HAZARD COMMUNICATION STANDARD IS LISTED. REFER TO ADDITIONAL SECTIONS OF THIS MSDS FOR OUR ASSESSMENT OF THE POTENTIAL HAZARDS OF THIS FORMULATION. HAZARDOUS INGREDIENTS: CAS # 7558-79-4 CHEMICAL NAME DISODIUM PHOSPHATE (SODIUM PHOSPHATE, DIBASIC) IRRITANT (EYES) NO COMPONENT IS CONSIDERED TO BE A CARCINOGEN BY THE NATIONAL TOXICOLOGY PROGRAM, THE INTERNATIONAL AGENCY FOR RESEARCH ON CANCER, OR THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION AT OSHA THRESHOLDS FOR CARCINOGENS. 3 HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: WARNING: MAY CAUSE SLIGHT IRRITATION TO THE SKIN. MAY CAUSE SLIGHT IRRITATION TO THE EYES. MISTS/AEROSOLS MAY CAUSE IRRITATION TO UPPER RESPIRATORY TRACT. DOT HAZARD IS NOT APPLICABLE EMERGENCY RESPONSE GOlDE IS NOT APPLICABLE ODOR: MILD APPEARANCE: COLORLESS TO YELLOW, LIQUID FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE). PROPER FIRE-EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER POTENTIAL HEALTH EFFECTS: ACUTE SKIN EFFECTS: PRIMARY ROUTE OF EXPOSURE; MAY CAUSE SLIGHT IRRITATION TO THE SKIN. ACUTE EYE EFFECTS: MAY CAUSE SLIGHT IRRITATION TO THE EYES. ACUTE RESPIRATORY EFFECTS: MISTS/AEROSOLS MAY CAUSE IRRITATION TO UPPER RESPIRATORY TRACT. INGESTION EFFECTS: MAY CAUSE SLIGHT GASTROINTESTINAL IRRITATION. TARGET ORGANS: NO EVIDENCE OF POTENTIAL CHRONIC EFFECTS. MEDICAL CONDITIONS AGGRAVATED: NOT KNOWN. SYMPTOMS OF EXPOSURE: MAY CAUSE REDNESS OR ITCHING OF SKIN. Page 2 of7 http://fplenergy.complyplus.comlMSDS/print_ bare.asp?S= 1 13&ShowTOC= 1 &ShowHazardRatings= 1 &... 6/17/2009 CONTINUUM AEC3 110 by BETZ DEARBORN Page 3 of 7 4 FIRST AID MEASURES SKIN CONTACT: REMOVE CONTAMINATED CLOTHING. WASH EXPOSED AREA WITH A LARGE QUANTITY OF SOAP SOLUTION OR WATER FOR 15 MINUTES.EYE CONTACT:IMMEDIATELY FLUSH EYES WITH WATER FOR 15 MINUTES. IMMEDIATELY CONTACT A PHYSICIAN FOR ADDITIONAL TREATMENT. INHALATION: REMOVE VICTIM FROM CONTAMINATED AREA TO FRESH AIR. APPLY APPROPRIATE FIRST AID TREATMENT AS NECESSARY. INGESTION: DO NOT FEED ANYTHING BY MOUTH TO AN UNCONSCIOUS OR CONVULSIVE VICTIM.DO NOT INDUCE VOMITING. IMMEDIATELY CONTACT PHYSICIAN. DILUTE CONTENTS OF STOMACH USING 3-4 GLASSES MILK OR WATER.NOTES TO PHYSICIANS: NO SPECIAL INSTRUCTIONS 5 FIRE FIGHTING MEASURES FIRE FIGHTING INSTRUCTIONS: FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE).EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER HAZARDOUS DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES.FLASH POINT:>20OF>93C P-m (CC)6 ACCIDENTAL RELEASE MEASURES PROTECTION AND SPILL CONTAINMENT: VENTILATE AREA. USE SPECIFIED PROTECTIVE EQUIPMENT. CONTAIN AND ABSORB ON ABSORBENT MATERIAL. PLACE IN WASTE DISPOSAL CONTAINER. FLUSH AREA WITH WATER.WET AREA MAY BE SLIPPERY. SPREAD SAND/GRIT. DISPOSAL INSTRUCTIONS: WATER CONTAMINATED WITH THIS PRODUCT MAY BE SENT TO A SANITARY SEWER TREATMENT FACILITY, IN ACCORDANCE WITH ANY LOCAL AGREEMENT, A PERMITTED WASTE TREATMENT FACILITY OR DISCHARGED UNDER A PERMIT. PRODUCT AS IS -INCINERATEOR LAND DISPOSE IN AN APPROVED LANDFILL.7 HANDLING & STORAGE HANDLING: NORMAL CHEMICAL HANDLING, http://fptenergy.complyplus.com/MSDS/print-bare.asp?S= 113&ShowTOC=1&ShowHazardRatings=l&... 6/17/2009 CONTINUUM AEC3l1 0 by BETZ DEARBORN 4 FIRST AID MEASURES SKIN CONTACT: REMOVE CONTAMINATED CLOTHING. WASH EXPOSED AREA WITH A LARGE QUANTITY OF SOAP SOLUTION OR WATER FOR 15 MINUTES. EYE CONTACT: IMMEDIATELY FLUSH EYES WITH WATER FOR 15 MINUTES. IMMEDIATELY CONTACT A PHYSICIAN FOR ADDITIONAL TREATMENT. INHALATION: REMOVE VICTIM FROM CONTAMINATED AREA TO FRESH AIR. APPLY APPROPRIATE FIRST AID TREATMENT AS NECESSARY. INGESTION: DO NOT FEED ANYTHING BY MOUTH TO AN UNCONSCIOUS OR CONVULSIVE VICTIM. DO NOT INDUCE VOMITING. IMMEDIATELY CONTACT PHYSICIAN. DILUTE CONTENTS OF STOMACH USING 3-4 GLASSES MILK OR WATER. NOTES TO PHYSICIANS: NO SPECIAL INSTRUCTIONS 5 FIRE FIGHTING MEASURES FIRE FIGHTING INSTRUCTIONS: FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE) . EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER HAZARDOUS DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES. FLASH POINT: >200F >93C P-M (CC) 6 ACCIDENTAL RELEASE MEASURES PROTECTION AND SPILL CONTAINMENT: VENTILATE AREA. USE SPECIFIED PROTECTIVE EQUIPMENT. CONTAIN AND ABSORB ON ABSORBENT MATERIAL. PLACE IN WASTE DISPOSAL CONTAINER. FLUSH AREA WITH WATER. WET AREA MAY BE SLIPPERY. SPREAD SAND/GRIT. DISPOSAL INSTRUCTIONS: WATER CONTAMINATED WITH THIS PRODUCT MAY BE SENT TO A SANITARY SEWER TREATMENT FACILITY, IN ACCORDANCE WITH ANY LOCAL AGREEMENT, A PERMITTED WASTE TREATMENT FACILITY OR DISCHARGED UNDER A PERMIT. PRODUCT AS IS -INCINERATE OR LAND DISPOSE IN AN APPROVED LANDFILL. 7 HANDLING & STORAGE HANDLING: NORMAL CHEMICAL HANDLING. Page 3 of7 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S= 113&ShowTOC= 1 &ShowHazardRatings= 1 &... 6/17/2009 CONTINUUM AEC31 10 by BETZ DEARBORN Page 4 of 7 STORAGE: KEEP CONTAINERS CLOSED WHEN NOT IN USE. DO NOT FREEZE. IF FROZEN, THAW AND MIX COMPLETELY PRIOR TO USE.8 EXPOSURE CONTROLS / PERSONAL PROTECTION CHEMICAL NAME EXPOSURE LIMITS DISODIUM PHOSPHATE (SODIUM PHOSPHATE, DIBASIC) PEL (OSHA): NOT DETERMINED TLV (ACGIH): NOT DETERMINED ENGINEERING CONTROLS: ADEQUATE VENTILATION PERSONAL PROTECTIVE EQUIPMENT: USE PROTECTIVE EQUIPMENT IN ACCORDANCE WITH 29 CFR 1910 SUBPART 1 RESPIRATORY PROTECTION: A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHAIS 29 CFR 1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE.USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS. IF AIR-PURIFYING RESPIRATOR USE IS APPROPRIATE, USE A RESPIRATOR WITH DUST/MIST FILTERS.SKIN PROTECTION:NEOPRENE GLOVES: WASH OFF AFTER EACH USE. REPLACE AS NECESSARY. EYE PROTECTION: SPLASH PROOF CHEMICAL GOGGLES 9 PHYSICAL & CHEMICAL PROPERTIES SPECIFIC GRAY. (70 F, 21 C): 1.255 VAPOR PRESSURE (MMHg): APPROX. 18.0 FREEZE POINT (F): 18 FREEZE POINT (C): -8 VAPOR DENSITY (AIR = 1): <1.00 VISCOSITY (CPS 70F, 21C): 60% SOLUBILITY (WATER): 100.0 ODOR: MILD APPEARANCE: COLORLESS TO YELLOW PHYSICAL STATE: LIQUID FLASH POINT P-M(CC)':>200F>93C http://fplenergy.complyplus.com/MSDS/print bare.asp?S= 113&ShowTOC= I &ShowHazardRatings= 1 &... 6/17/2009 CONTINUUM AEC3 I 10 by BETZ DEARBORN STORAGE: KEEP CONTAINERS CLOSED WHEN NOT IN USE. DO NOT FREEZE. IF FROZEN; THAW AND MIX COMPLETELY PRIOR TO USE. 8 EXPOSURE CONTROLS / PERSONAL PROTECTION CHEMICAL NAME DISODIUM PHOSPHATE (SODIUM PHOSPHATE, DIBASIC) ENGINEERING CONTROLS: ADEQUATE VENTILATION PERSONAL PROTECTIVE EQUIPMENT: EXPOSURE LIMITS PEL (OSHA): NOT DETERMINED TLV (ACGIH): NOT DETERMINED OSB PROTECTIVE EQUIPMENT IN ACCORDANCE WITH 29 CFR 1910 SUBPART 1 RESPIRATORY PROTECTION: A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CFR 1910.134 AND ANSI Z8B.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE. USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS. IF AIR-PURIFYING RESPIRATOR USE IS APPROPRIATE, USE A RESPIRATOR WITH DUST/MIST FILTERS. SKIN PROTECTION: NEOPRENE GLOVES: WASH OFF AFTER EACH USE. REPLACE AS NECESSARY. EYE PROTECTION: SPLASH PROOF CHEMICAL GOGGLES 9 PHYSICAL & CHEMICAL PROPERTIES SPECIFIC GRAV. (70 F, 21 C): 1. 255 VAPOR PRESSURE (MMHg): APPROX. 18.0 FREEZE POINT (F): IB FREEZE POINT (C): -8 VAPOR DENSITY (AIR = 1): <1.00 VISCOSITY (CPS 70F, 21C): 60 % SOLUBILITY (WATER): 100.0 ODOR: MILD APPEARANCE; COLORLESS TO YELLOW PHYSICAL STATE: LIQUID FLASH POINT P-M(CC) : >200F >93C Page 4 of7 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S= 113&ShowTOC=1 &ShowHazardRatings== 1 &... 6117/2009 CONTINUUM AEC3 110 by BETZ DEARBORN pH AS IS (APPROX.):

4.2 EVAPORATION

RATE (ETHER = 1): <1.00 NA = NOT APPLICABLE ND -NOT DETERMINED Page 5 of 7 10 STABILITY & REACTIVITY STABILITY: STABLE UNDER NORMAL STORAGE CONDITIONS. HAZARDOUS POLYMERIZATION: WILL NOT OCCUR.INCOMPATIBILITIES: MAY REACT WITH STRONG OXIDIZERS. DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES.BETZDEARBORN INTERNAL PUMPOUT/CLEANOUT CATEGORIES: "B" 11 TOXICOLOGICAL INFORMATION ORAL LD50 RAT: >2,000 MG/KGNOTE: ESTIMATED VALUE DERMAL LDS0 RABBIT: >2,000 MG/KG NOTE: ESTIMATED VALUE 12 ECOLOGICAL INFORMATION AQUATIC TOXICOLOGY: FATHEAD MINNOW 96 HOUR ACUTE TOXICITY: PRODUCT TOXICITY DETERMINED FROM BIOASSAYS CONDUCTED ON INDIVIDUAL COMPONENTS. LC50: 1710 MG/L NO EFFECT LEVEL: 450 MG/L DAPHNIA MAGNA 48 HOUR ACUTE TOXICITY: PRODUCT TOXICITY DETERMINED FROM BIOASSAYS CONDUCTED ON INDIVIDUAL COMPONENTS. LC50: 1460 MG/L NO EFFECT LEVEL: 690 MG/L BIODEGRADATION: COD (MG/GM): 253 CALCULATED TOc (MG/GM): 107 CALCULATED BOD-5 (MG/GM): 9 CALCULATED BOD-28 (MG/GM): 21 CALCULATED 13 DISPOSAL CONSIDERATIONS http://fplenergygcomplyplus.comIMSDS/print_bare.asp?S=113&ShowTOC= I &ShowHazardRatings=l &... 6/17/2009 CONTINUUM AEC311 0 by BETZ DEARBORN pH AS IS (APPROX.):

4.2 EVAPORATION

RATE (ETHER c 1): <1.00 NA NOT APPLICASLE ND e NOT DETERMINED 10 STABILITY & REACTIVITY STABILITY: STABLE UNDER NORMAL STORAGE CONDITIONS. HAZARDOUS POLYMERIZATION: WILL NOT OCCUR. INCOMPATIBILITIES: MAY REACT WITH STRONG OXIDIZERS. DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES. BETZDEARBORN INTERNAL PUMPOUT!CLEANOUT CATEGORIES: "B" 11 TOXICOLOGICAL INFORMATION ORAL LDSO RAT: >2,000 MG/KG NOTE: ESTIMATED VALUE DERMAL LDSO RABBIT: >2,000 MG/KG NOTE: ESTIMATED VALUE 12 ECOLOGICAL INFORMATION AQUATIC TOXICOLOGY: FATHEAD MINNOW 96 HOUR ACUTE TOXICITY: PRODUCT TOXICITY DETERMINED FROM BIOASSAYS CONDUCTED ON INDIVIDUAL COMPONENTS. LCSO: 1710 MGIL NO EFFECT LEVEL, 450 MG/L DAPHNIA MAGNA 48 HOUR ACUTE TOXICITY, PRODUCT TOXICITY DETERMINED FROM BIOASSAYS CONDUCTED ON INDIVIDUAL COMPONENTS. Leso: 1460 MG/L NO EFFECT LEVEL: 690 MG/L BIODEGRADATION: COD (MG/GM): 253 CALCULATED TOC (MG!GM): 107 CALCULATED BOD-S (MG!GM): 9 CALCULATED 8OD-28 (MG!GM): 21 CALCULATED 13 DISPOSAL CONSIDERATIONS Page 50f7 http://fplenergy.complYplus.comIMSDS/print_ bare.asp?S= 113&ShowTOC= 1 &ShowHazardRatings= 1&... 6117/2009 CONTINUUM AEC3 110 by BETZ DEARBORN Page 6 of 7 IF THIS UNDILUTED PRODUCT IS DISCARDED AS A WASTE, THE US RCRA HAZARDOUS WASTE IDENTIFICATION NUMBER IS: NOT APPLICABLE. PLEASE BE ADVISED; HOWEVER, THAT STATE AND LOCAL REQUIREMENTS FOR WASTE DISPOSAL MAY BE MORE RESTRICTIVE OR OTHERWISE DIFFERENT FROM FEDERAL REGULATIONS. CONSULT STATE AND LOCAL REGULATIONS REGARDING THE PROPER DISPOSAL OF THIS MATERIAL.14 TRANSPORT INFORMATION DOT HAZARD: NOT APPLICABLE UN / NA NUMBER: NOT APPLICABLE DOT EMERGENCY RESPONSE GUIDE #: NOT APPLICABLE 15 REGULATORY INFORMATION TSCA: ALL COMPONENTS OF THIS PRODUCT ARE LISTED IN THE TSCA INVENTORY. CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ): NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS FOOD AND DRUG ADMINISTRATION: FDA APPROVED FOR MILL SUPPLY WATER USDA FEDERALLY INSPECTED MEAT AND POULTRY PLANTS: SEC, G5, G7 SARA SECTION 312 HAZARD CLASS: IMMEDIATE (ACUTE)SARA SECTION 302 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS SARA SECTION 313 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS CALIFORNIA REGULATORY INFORMATION: CALIFORNIA SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT (PROPOSITION 65)CHEMICALS PRESENT: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS MICHIGAN REGULATORY INFORMATION: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS 16 OTHER INFORMATION NFPA/HMIS CODE TRANSLATION HEALTH 1 SLIGHT HAZARD FIRE 1 SLIGHT HAZARD REACTIVITY 0 MINIMAL HAZARD SPECIAL NONE NO SPECIAL HAZARD (1) PROTECTIVE EQUIPMENT B GOGGLES, GLOVES http://fplenergy.complyplus.com/MSDS/print-bare.asp?S= 113&ShowTOC=I&ShowHazardRatings=l&... 6/17/2009 CONTINUUM AEC311 0 by BETZ DEARBORN IF THIS UNDILUTED PRODUCT IS DISCARDED AS A WASTE, THE US RCRA HAZARDOUS WASTE IDENTIFICATION NUMBER IS, NOT APPLICABLE. PLEASE BE ADVISED; HOWEVER, THAT STATE AND LOCAL REQUIREMENTS FOR WASTE DISPOSAL MAY BE MORE RESTRICTIVE OR OTHERWISE DIFFERENT FROM FEDERAL REGULATIONS. CONSULT STATE AND LOCAL REGULATIONS REGARDING THE PROPER DISPOSAL OF THIS MATERIAL. 14 TRANSPORT INFORMATION DOT HAZARD, NOT APPLICASLE UN / NA NUMBER: NOT APPLICABLE DOT EMERGENCY RESPONSE GUIDE #, NOT APPLICABLE 15 REGULATORY INFORMATION TSCA, ALL COMPONENTS OF THIS PRODUCT ARE LISTED IN THE TSCA INVENTORY. CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ): NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS FOOD AND DRUG ADMINISTRATION: FDA APPROVED FOR MILL SUPPLY WATER USDA FEDERALLY INSPECTED MEAT AND POULTRY PLANTS: SEC. G5, G7 SARA SECTION 312 HAZARD CLASS: IMMEDIATE (ACUTE) SARA SECTION 302 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS SARA SECTION 313 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS CALIFORNIA REGULATORY INFORMATION: CALIFORNIA SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT (PROPOSITION

65) CHEMICALS PRESENT: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS MICHIGAN REGULATORY INFORMATION:

NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS 16 OTHER INFORMATION NFPA/HMIS HEALTH FIRE REACTIVITY SPECIAL CODE TRANSLATION 1 SLIGHT HAZARD 1 SLIGHT HAZARD o MINIMAL HAZARD NONE NO SPECIAL HAZARD (1) PROTECTIVE EQUIPMENT B GOGGLES, GLOVES Page 6 of7 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S= 113&ShowTOC= I&ShowHazardRatings=l &... 6/1712009 CONTINUUM AEC3 110 by BETZ DEARBORN (1) REFER TO SECTION 8 OF MSDS FOR ADDITIONAL PROTECTIVE EQUIPMENT RECOMMENDATIONS.CHANGE LOG

Page 7 of 7 EFFECTIVE DATE MSDS STATUS: 11-FEB-1997 21-JUL-1997 20-JAN-1998 03-JAN-2001 REVISIONS TO SECTION SUPERCEDES NEW 11-FEB-1997 21-JUL- 1997 20-JAN-1998 15 15 15 Copyright© 1999-2009 Dolphin Software, Inc.Comply Plus Web -Hosted FPL Energy http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=I 13&ShowTOC=

&ShowHazardRatings= 1 &... 6/17/2009 CONTINUUM ABC31} 0 by BETZ DEARBORN .( 1} REFER TO SECTION 8 OF MSDS FOR ADDITIONAL PROTECTIVE EQUIPMENT RECOMME:NDATIONS. CHANGE LOG: EFFECTIVE DATE MSDS STATUS: II-FEE-1997 21-JUL-1997 20-JAN-1998 03-JAN-2001 REVISIONS TO SECTION SUPERCEDES 15 15 15 NEW ll-FEE-1997 21-JUL-1997 20-JAN-1998 Copyright© 1999*2009 Dolphin Software, Inc. Comply Plus Web -Hosted FPL Energy Page 7 of7 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S= 113&ShowTOC= 1 &ShowHazardRatings= 1 &... 6/17/2009 SPECTRUS BD1501E by GE BETZ FPL Energy Duane Arnold SPECTRUS BD1501E GE BETZ FileName Language Internal ID Revision Date 014687 1718 2/27/2008 Table Of Contents I1 IDENTIFICATION OF PRODUCT AND COMPANY 2 COMPOSITION / INFORMATION ON INGREDIENTS 3 HAZARDS IDENTIFICATION 4 FIRST AID MEASURES 5 FIRE FIGHTING MEASURES 6 ACCIDENTAL RELEASE MEASURES 7 HANDLING & STORAGE B EXPOSURE CONTROLS / PERSONAL PROTECTION 9 PHYSICAL & CHEMICAL PROPERTIES 10 STABILITY & REACTIVITY 11 TOXICOLOGICAL INFORMATION 12 ECOLOGICAL INFORMATION 13 DISPOSAL CONSIDERATIONS 14 TRANSPORT INFORMATION 15 REGULATORY INFORMATION 116 OTHER INFORMATION Hazards .. MSDS stte NFPA HMIS -1 (Active)Health 2 2 Hazard Ratings are Local Overrides. Flammability 1 1 Reactivity 0 0 Other B GE MATERIAL SAPETY DATA SHEET GE WATER & PROCESS TECHNOLOGIES SPECTRUS BDI501E ISSUE DATE: 27-FEB-2008 SUPERCEDES: 08-FEB-2008 1 IDENTIFICATION OF PRODUCT AND COMPANY Page 1 of 7 IDENTIFICATION OF SUBSTANCE OR PREPARATION: SPECTRUS BDISO1E PRODUCT APPLICATION AREA: BIODISPERSANT COMPANY/UNDERTAKING IDENTIFICATION: GE BETZ, INC.4636 SOMERTON ROAD TREVOSE, PA 19053 http://fplenergy.complyplus.comiMSDS/print-bare.asp?S=3265&ShowTOC= 1&ShowHazardRatings= 1... 6/17/2009 SPECTRUS BD1501E by GE BETZ FPL Energy Duane Arnold SPECTRUS BD1S01E FileName Language Internal 10 014687 1718 Table Of Contents 1 IDENTIFICATION OF PRODUCT AND COMPANY 2 COMPOSmON / INFORMATION ON INGREDIENTS 3 HAZARDS IDENTIFICATION 4 FIRST AID MEASURES 5 FIRE FIGHTING MEASURES 5 ACCIDENTAL RELEASE MEASURES 7 HANDLING & STORAGE 8 EXPOSURE CONTROLS / PERSONAL PROTECTION 9 PHYSICAL & CHEMICAL PROPERTIES 10 STABILITY & REAcrIVIiY 11 TOXICOLOGICAL INFORMATION 12 ECOLOGICAL INFORMATION 13 DISPOSAL CONSIDERATIONS 14 TRANSPORT INFORMATION 15 REGULATORY INFORMATION 15 OTHER INFORMATION Hazards _ ....... --MSDS State-NFPA HMIS GE 8ETZ Revision Date 2/27/2008 -...... (Active) Health 2 2 II Hazard Ratings are Local Overrides. Flammability 1 1 Reactivity 0 0 Other B GE MATERIAL SAFETY DATA SHEET GIS WATER & PROCESS TECHNOLOGIES SPECTRUS BD1501E ISSUE DATE: 27-FEB-2008 SUPERCEDES: OB-FEB-2008 1 IDENTIFICATION OF PRODUCT AND COMPANY IDENTIFICATION OF SUBSTANCE OR PREPARATION: SPECTRUS BD1501E PRODUCT APPLICATION AREA: BIODISPERSANT COMPANY/UNDERTAKING IDENTIFICATION: GE BE'l'Z, INC. 4636 SOMERTON ROAD TREVOSE, PA 19053 Page 1 of7 http://fplenergy.complyplus.comlMSDS/print_ bare.asp?S=3265&ShowTOC= l&ShowHazardRatings= 1... 6117/2009 SPECTRUS BD1501E by GE BETZ Page 2 of 7T: 215 355-3300F: 215 953 5524 EMERGENCY TELEPHONE: (800) 877-1940 PREPARED BY PRODUCT STEWARDSHIP GROUP: 215 355-3300 2 COMPOSITION / INFORMATION ON INGREDIENTS INFORMATION FOR SPECIFIC PRODUCT INGREDIENTS AS REQUIRED BY THE U.S. OSHA HAZARD COMMUNICATION STANDARD IS LISTED. REFER TO ADDITIONAL SECTIONS OF THIS MSDS FOR OUR ASSESSMENT OF THE POTENTIAL HAZARDS OF THIS FORMULATION. HAZARDOUS INGREDIENTS: CAS# CHEMICAL NAME RANGE (W/W%)166736-08-9 OXIRANE,IMETHYL-, POLYMER WITH OXIRANE, 10-20 MONO (2- PROPYLHEPTYL) ETHER EYE AND SKIN IRRITANT 3 HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: WARNING: MAY CAUSE MODERATE IRRITATION TO THE SKIN. SEVERE IRRITANT TO THE EYES.MISTS/AEROSOLS MAY CAUSE IRRITATION TO UPPER RESPIRATORY TRACT.DOT HAZARD IS NOT APPLICABLE ODOR: MILDAPPEARANCE: COLORLESS, LIQUID FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS(FULL FACE-PIECE TYPE).PROPER FIRE-EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER POTENTIAL HEALTH EFFECTS: ACUTE SKIN EFFECTS:PRIMARY ROUTE OF EXPOSURE; MAY CAUSE MODERATE IRRITATION TO THE SKIN.ACUTE EYE EFFECTS: SEVERE IRRITANT TO THE EYES.ACUTE RESPIRATORY EFFECTS: MISTS/AEROSOLS MAY CAUSE IRRITATION TO UPPER RESPIRATORY TRACT.INGESTION EFFECTS: MAY CAUSE GASTROINTESTINAL IRRITATION, TARGET ORGANS: NO EVIDENCE OF POTENTIAL CHRONIC EFFECTS.MEDICAL CONDITIONS AGGRAVATED: NOT KNOWN.http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=3265&ShowTOC= 1 &ShowHazardRatings= 1... 6/17/2009 SPECTRUS BD150lE by GE BETZ T, 215 355-3300 F, 215 953 5524 EMERGENCY TELEPHONE: (800) 877-1940 PREPARED BY PRODUCT STEWARDSHIP GROUP: 215 355-3300 2 COMPOSITION / INFORMATION ON INGREDIENTS INFORMATION FOR SPECIFlC PRODUCT INGREDIENTS AS REQUIRED BY THE U.S. OSHA HAZARD COMMUNICATION STANDARD IS LISTED. REFER TO ADDITIONAL SECTIONS OF THIS MSDS FOR OUR ASSESSMENT OF THE POTENTIAL HAZARDS OF THIS FORMULATION. HAZARDOUS INGREDIENTS: CAS# 166736-08-9 CHEMICAL NAME 6XlRANE;;ME'THYL-, POLYMER WITH OXIRANE, MONO (2-PROPYLHEPTYLl ETHER EYE AND SKIN IRRITANT 3 HAzARDS IDENTIFICATION EMERGENCY OVERVIEW: WARNING: RANGE (W/W%) 10-20 MAY CAUSE MODERATE IRRITATION TO THE SKIN. SEVERE IRRITANT TO THE EYES. MISTS/AEROSOLS MAY CAUSE IRRITATION TO UPPER RESPIRATORY TRACT. DOT HAZARD IS NOT APPLICABLE ODOR: MILD APPEARANCE: COLORLESS, LIQUID FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS(FULL FACE-PIECE TYPE). PROPER FIRE-EXTINGUISHING MEDIA; DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER POTENTIAL HEALTH EFFECTS: ACUTE SKIN EFFECTS: PRIMARY ROUTE OF EXPOSURE; MAY CAUSE MODERATE IRRITATION TO THE SKIN. ACUTE EYE EFFECTS: SEVERE IRRITANT TO THE EYES. ACUTE RESPIRATORY EFFECTS: MISTS/AEROSOLS MAY CAUSE IRRITATION TO UPPER RESPIRATORY TRACT. INGESTION EFFECTs: MAY CAUSE GASTROINTESTINAL IRRITATION. TARGET ORGANS: NO EVIDENCE OF POTENTIAL CHRONIC EFFECTS. MEDICAL CONDITIONS AGGRAVATED: NOT KNOWN. http://fplenergy.complyplus.comIMSDS/print _ bare.asp?S=3 265&ShowTOC= 1 &ShowHazardRatings=: 1 ... Page 2 of7 6/17/2009 SPECTRUS BDI501E by GE BETZ Page 3 of 7 SYMPTOMS OF EXPOSURE: MAY CAUSE REDNESS OR ITCHING OF SKIN, IRRITATION, AND/OR TEARING OF EYES (DIRECT CONTACT).4 FIRST AID MEASURES SKIN CONTACT: WASH THOROUGHLY WITH SOAP AND WATER. REMOVE CONTAMINATED CLOTHING.THOROUGHLY WASH CLOTHING BEFORE REUSE. GET MEDICAL ATTENTION IF IRRITATION DEVELOPS OR PERSISTS.EYE CONTACT: REMOVE CONTACT LENSES. HOLD EYELIDS APART. IMMEDIATELY FLUSH EYES WITH PLENTY OF LOW-PRESSURE WATER FOR AT LEAST 15 MINUTES. GET IMMEDIATE MEDICAL ATTENTION. INHALATION:IF NASAL, THROAT OR LUNG IRRITATION DEVELOPS -REMOVE TO FRESH AIR AND GET MEDICAL ATTENTION. INGESTION: DO NOT FEED ANYTHING BY MOUTH TO AN UNCONSCIOUS OR CONVULSIVE VICTIM. DO NOT INDUCE VOMITING. IMMEDIATELY CONTACT PHYSICIAN. DILUTE CONTENTS OF STOMACH USING 2-8 FLUID OUNCES (60-240 ML) OF MILK OR WATER.NOTES TO PHYSICIANS: NO SPECIAL INSTRUCTIONS 5 FIRE FIGHTING MEASURES FIRE FIGHTING INSTRUCTIONS: FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE).EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER HAZARDOUS DECOMPOSITION PRODUCTS: OXIDES OF CARBON FLASH POINT: >213F >101C P-M(CC)6 ACCIDENTAL RELEASE MEASURES PROTECTION AND SPILL CONTAINMENT: VENTILATE AREA. USE SPECIFIED PROTECTIVE EQUIPMENT. CONTAIN AND ABSORB ON ABSORBENT MATERIAL. PLACE IN WASTE DISPOSAL CONTAINER. FLUSH AREA WITH WATER. WET AREA MAY BE SLIPPERY. SPREAD SAND/GRIT. DISPOSAL INSTRUCTIONS: WATER CONTAMINATED WITH THIS PRODUCT MAY BE SENT TO A SANITARY SEWER TREATMENT FACILITY, IN ACCORDANCE WITH ANY LOCAL AGREEMENT, A PERMITTED WASTE TREATMENT FACILITY OR DISCHARGED UNDER A PERMIT. PRODUCT AS IS -INCINERATE OR LAND DISPOSE IN AN APPROVED LANDFILL.http://fplenergy.complyplus.comIMSDS/print-bare.asp?S=3265&ShowTOC=1&ShowHazardRatings=l .. 6/17/2009 SPECTRUS BD 150 1 E by GE BETZ SYMPTOMS OF EXPOSURE: MAY CAUSE REDNESS OR ITCHING OF SKIN, IRRITATION, AND/OR TEARING OF EYES (DIRECT CONTACT) . 4 FIRST AID MEASURES SKIN CONTACT: WASH THOROUGHLY WITH SOAP AND WATER. REMOVE CONTAMINATED CLOTHING. THOROUGHLY WASH CLOTHING BEFORE REUSE. GET MEDICAL ATTENTION IF IRRITATION DEVELOPS OR PERSISTS. EYE CONTACT: REMOVE CONTACT LENSES. HOLD EYELIDS APART. IMMEDIATELY FLUSH EYES WITH PLENTY OF LOW-PRESSURE WATER FOR AT LEAST 15 MINUTES. GET IMMEDIATE MEDICAL ATTENTION. INHALATION: IF NASAL, THROAT OR LUNG IRRITATION DEVELOPS -REMOVE TO FRESH AIR AND GET MEDICAL ATTENTION. INGESTION: DO NOT FEED ANYTHING BY MOUTH TO AN UNCONSCIOUS OR CONVULSIVE VICTIM. DO NOT INDUCE VOMITING. IMMEDIATELY CONTACT PHYSICIAN. DILUTE CONTENTS OF STOMACH USING 2-8 FLUID OUNCES (60-240 ML) OF MILK OR WATER. NOTES TO PHYSICIANS: NO SPECIAL INSTRUCTIONS 5 FIRE FIGHTING MEASURES FIRE FIGHTING INSTRUCTIONS, FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE). EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER HAZARDOUS DECOMPOSITION PRODUCTS: OXIDES OF CARBON FLASH POINT: >213F >101C P-M(CC) 6 ACCIDENTAL RELEASE MEASURES PROTECTION AND SPILL CONTAINMENT: VENTILATE AREA. USE SPECIFIED PROTECTIVE EQUIPMENT. CONTAIN AND ABSORB ON ABSORBENT MATERIAL. PLACE IN WASTE DISPOSAL CONTAINER. FLUSH AREA WITH WATER. WET AREA MAY BE SLIPPERY. SPREAD SAND/GRIT. DISPOSAL INSTRUCTIONS: WATEa CONTAMINATED WITH THIS PRODUCT MAY BE SENT TO A SANITARY SEWER TREATMENT FAC!LITY, IN ACCORDANCE WITH ANY LOCAL AGREEMENT, A PERMITTED WASTE TREATMENT FAC!LITY OR DISCHARGED UNDER A PERMIT. PRODUCT AS IS -INCINERATE OR LAND DISPOSE IN AN APPROVED LANDFILL. http://fplenergy.complyplus.comIMSDS/print _ bare.asp?S=3 265&ShowTOC= 1 &ShowHazardRatings= 1 ... Page 3 of7 6/1712009 SPECTRUS BDI501E by GE BETZ Page 4 of 7 7 RANDLIqG & STORAGE HANDLING: NORMAL CHEMICAL HANDLING. STORAGE:KEEP CONTAINERS CLOSED WHEN NOT IN USE. STORE IN COOL VENTILATED LOCATION.STORE AWAY FROM OXIDIZERS. 8 EXPOSURE CONTROLS / PERSONAL PROTECTION EXPOSURE LIMITS: CHEMICAL NAME: OXIRANE, METHYL-, POLYMER WITH OXIRANE, MONO(2-PROPYLHEPTYL) ETHER: PEL (OSHA): NOT DETERMINED TLV (ACGIH) : NOT DETERMINED ENGINEERING CONTROLS: ADEQUATE VENTILATION PERSONAL PROTECTIVE EQUIPMENT: USE PROTECTIVE EQUIPMENT IN ACCORDANCE WITH 29CFR 1910 SUBPART I RESPIRATORY PROTECTION: A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CFR 1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE.USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS. IF AIR-PURIFYING RESPIRATOR USE IS APPROPRIATE, USE ANY OF THE FOLLOWING PARTICULATE RESPIRATORS: N95, N99, N100, R95, R99, R100, P95, P99 OR P100.SKIN PROTECTION:RUBBER, BUTYL OR VITON GLOVES -WASH OFF AFTER EACH USE.REPLACE AS NECESSARY. EYE PROTECTION: SPLASH PROOF CHEMICAL GOGGLES 9 PHYSICAL & CHEMICAL PROPERTIES SPECIFIC GRAV. (70F, 21C): 1.019 VAPOR PRESSURE IMMHG).: APPROX. 18.0 FREEZE POINT (F): 31 FREEZE POINT (C): -1 VAPOR DENSITY (AIR-1): <1.00 VISCOSITY(CPS 70F, 21C): 110 k% SOLUBILITY (WATER): 100.0 http://fplenergy.complyplus.com/MSDS/printbare.asp?S=3265&ShowTOC= 1 &ShowHazardRatings=1 ... 6/17/2009 SPECTRUS BDl501E by GE BETZ 7 UANDLING & STORAGE HANDLING: NORMAL CHEMICAL HANDLING. STORAGE; KEEP CONTAINERS CLOSED WHEN NOT IN USE. STORE IN COOL VENTILATED LOCATION. STORE AWAY FROM OXIDIZERS. 8 EXPOSURE CONTROLS / PERSONAL PROTECTION EXPOSURE LIMITS: CHEMICAL NAME: OXIRANE, METHYL-, POLYMER WITH OXIRANE, MONO (2-PROPYLHEPTYL) ETHER: PEL (OSHA): NOT DETERMINED TLV (ACGIH): NOT DETERMINED ENGINEERING CONTROLS: ADEQUATE VENTILATION PERSONAL PROTECTIVE EQUIPMENT: USE PROTECTIVE EQUIPMENT IN ACCORDANCE WITH 29CFR 1910 SUBPART I RESPIRATORY PROTECTION: A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CFR 1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE. USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS. IF AIR-PURIFYING RESPIRATOR USE IS APPROPRIATE, USE ANY OF THE FOLLOWING PARTICULATE RESPlRATORS: N9S, N99, N100, R9S, R99, RI00, P9S, P99 OR PI00. SKIN PROTECTION: RU'BBER, BUTYL OR VlTON GLOVES -WASH OFF AFTER EACH USE. REPLACE AS NECESSARY. EYE PROTECTION: PROOF CHEMICAL GOGGLES 9 PHYSICAL & CHEMICAL PROPERTIES SPECIFIC GRAV. (70F, 21C), 1.019 VAPOR PRESSURB (MMHG), APPROX. 18.0 FREEZE POINT (F): 31 FREEZE POINT (e): -1 VAPOR DENSITY <1.00 VISCOSITY(CPS 70F, 21C): 110 % SOLU'BILITY (WATER): 100.0 http://fplenergy.complyplus.comIMSDS/print _ bare.asp?S=3265&ShowTOC= 1 &ShowHazardRatings::::: 1 ... Page 4 of7 6117/2009 SPECTRUS BD1501E by GE BETZ Page 5 of 7 ODOR: MILD APPEARANCE: COLORLESS PHYSICAL STATE: LIQUID FLASH POINT P-M(CC):>213F>100C pH AS IS (APPROX.):

6.7 EVAPORATION

RATE (ETHER=l): <1.00 PERCENT VOC: 0.0 NA = NOT APPLICABLE ND = NOT DETERMINED 10 STABILITY & REACTIVITY STABILITY: STABLE UNDER NORMAL STORAGE CONDITIONS. HAZARDOUS POLYMERIZATION: WILL NOT OCCUR.INCOMPATIBILITIES: MAY REACT WITH STRONG OXIDIZERS. DECOMPOSITION PRODUCTS: OXIDES OF CARBON INTERNAL PUMPOUT/CLEANOUT CATEGORIES: "B" 11 TOXICOLOGICAL INFORMATION ORAL LDS0 RAT: >200-<2,000 MG/KG DERMAL LDS0 RABBIT: >2,000 MG/KGNOTE: ESTIMATED VALUE SKIN IRRITATION SCORE RABBIT: NONIRRITANT EYE IRRITATION SCORE RABBIT: IRRITANT 12 ECOLOGICAL INFORMATION

• AQUATIC TOXICOLOGY:

DAPHNIA MAGNA 48 HOUR STATIC RENEWAL BIOASSAY: LC50: 38.2 NO EFFECT LEVEL: 12.5 MG/L FATHEAD MINNOW 96 HOUR STATIC RENEWAL BIOASSAY: LC50: 82.5 NO EFFECT LEVEL: 31.3 MG/L RAINBOW TROUT 96 HOUR STATIC RENEWAL BIOASSAY:http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=3265&ShowTOC=1 &ShowHazardRatings=l ... 6/17/2009 SPECTRUS BDl501E by GE BETZ ODOR: MILD APPEARANCE: COLORLESS PHYSICAL STATE: LIQUID FLASH POINT P-M (CC) : >213F >100C pH AS IS (APPROX.):

6.7 EVAPORATION

RATE (ETHER=l): <1.00 PERCENT VOC: 0.0 NA = NOT APPLICABLE ND = NOT DETERMINED 10 STABILITY & REACTIVITY STABILITY: STABLE UNDER NORMAL STORAGE CONDITIONS. HAZARDOUS POLYMERIZATION: WILL NOT OCCUR. INCOMPATIBILITIES: MAY REACT WITH STRONG OXIDIZERS. DECOMPOSITION PRODUCTS: OXIDES OF CARBON INTERNAL PUMPOUT/CLEANOUT CATEGORIES: "B" 11 TOXICOLOGICAL INFORMATION ORAL LDSO RAT: >200-<2,000 MG/KG DERMAL LDSO RABBIT: >2,000 MG/KG NOTE: ESTIMATED VALUE SKIN IRRITATION SCORE RABBIT: NONIRRITANT EYE IRRITATION SCORE RABBIT: IRRITANT 12 ECOLOGICAL INFORMATION AQUATIC TOXICOLOGY: DAPHNIA MAGNA 48 HOUR STATIC RENEWAL BIOASSAY: LeSO: 38.2 NO EFFECT LEVEL: 12.5 MG/L FATHEAD MINNOW 96 HOUR STATIC RENEWAL BIOASSAY: LeSO: 82.5 NO EFFECT LEVEL: 31.3 MG/L RAINBOW TROUT 96 HOUR STATIC RENEWAL BIOASSAY: http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S:::;:3265&ShowTOC== 1 &ShowHazardRatings:::;: 1 ... Page 5 of7 6/17/2009 SPECTRUS BD1501E by GE BETZ Page 6 of 7 LC50: 141.4 NO EFFECT LEVEL: 100 MG/L BIODEGRADATION: NO DATA AVAILABLE.13 DISPOSAL CONSIDERATIONS IF THIS UNDILUTED PRODUCT IS DISCARDED AS A WASTE, THE US RCRA HAZARDOUS WASTE IDENTIFICATION NUMBER IS: NOT APPLICABLE. PLEASE BE ADVISED; HOWEVER, THAT STATE AND LOCAL REQUIREMENTS FOR WASTE DISPOSAL MAY BE MORE RESTRICTIVE OR OTHERWISE DIFFERENT FROM FEDERAL REGULATIONS. CONSULT STATE AND LOCAL REGULATIONS REGARDING THE PROPER DISPOSAL OF THIS MATERIAL.14 TRANSPORT INFORMATIONDOT HAZARD: NOT APPLICABLE PROPER SHIPPING NAME: DOT EMERGENCY RESPONSE GUIDE

1. NOT APPLICABLE NOTE: SOME CONTAINERS MAY BE DOT EXEMPT, PLEASE CHECK BOL FOR EXACT CONTAINER CLASSIFICATION 15 REGULATORY INFORMATION TSCA: ALL COMPONENTS OF THIS PRODUCT ARE INCLUDED ON OR ARE IN COMPLIANCE WITH THE U.S. TSCA REGULATIONS.

CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ): NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS SARA SECTION 312 HAZARD CLASS: IMMEDIATE (ACUTE)SARA SECTION 302 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS SARA SECTION 313 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS CALIFORNIA REGULATORY INFORMATION: CALIFORNIA SAFE DRINKING WATER AND TOXIC: ENFORCEMENT ACT (PROPOSITION 65): THIS PRODUCT CONTAINS ONE OR MORE INGREDIENTS AT TRACE LEVELS KNOWN TO THE STATE OF CALIFORNIA TO CAUSE CANCER AND REPRODUCTIVE TOXICITY.MICHIGAN REGULATORY INFORMATION: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=3265&ShowTOC= I &ShowHazardRatings= l... 6/17/2009 SPECTRUS BD 150 1 E by GE BETZ LC50: 141.4 NO EPPECT LEVEL: 100 MG!L BIODEGRADATION: NO DATA AVAILABLE. 13 DISPOSAL CONSIDERATIONS IF THIS UNDILUTED PRODUCT IS DISCARDED AS A WASTE, THE US RCRA HAZARDOUS WASTE IDENTIFICATION NUMBER IS: NOT APPLICABLE. PLEASE BE ADVISED; HOWEVER, THAT STATE AND LOCAL REQUIREMENTS FOR WASTE DISPOSAL MAY BE MORE RESTRICTIVE OR OTHERWISE DIFFERENT FROM FEDERAL REGULATIONS. CONSULT STATE AND LOCAL REGULATIONS REGARDING THE PROPER DISPOSAL OF THIS MATERIAL. 14 TRANSPORT INFORMATION DOT HAZARD: NOT APPLICABLE PROPER SHIPPING NAME: DOT EMERGENCY RESPONSE GUIDE n: NOT APPLICABLE NOTE: SOME CONTAINERS MAY BE DOT EXEMPT, PLEASE CHEeR BOL FOR EXACT CONTAINER CLASSIFICATION 15 REGULATORY INFORMATION TSCA: ALL COMPONENTS OF THIS PRODUCT ARE INCLUDED ON OR ARB IN COMPLIANCE WITH THE u.s. TSCA REGULATIONS. CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ): NO REGULATSD CONSTITUENT PRESENT AT OSHA THRESHOLDS SARA SECTION 312 HAZARD CLASS: IMMEDIATE (ACUTE) SARA SECTION 302 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS SARA SECTION 313 CHEMICALS: NO REGULATSD CONSTITUENT PRESENT AT OSHA THRESHOLDS CALIFORNIA REGULATORY INFORMATION: CALIPORNIA SAFE DRINKING WATER AND TOXIC: ENPORCEMENT ACT (PROPOSITION

65) : THIS PRODUCT CONTAINS ONE OR MORE INGREDIENTS AT 'l'RACE LEVELS KNOWN TO THE STATE OF CALIFORNIA TO CAUSE CANCER AND REPRODUCTIVE TOXICITY.

MICHIGAN REGULATORY INFORMATION: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=3265&ShowTOC= 1 &ShowHazardRatings== 1 ... Page 6 of7 6117/2009 SPECTRUS BD 1501 E by GE BETZ 16 OTHER INFORMATION Page 7 of 7 NFPA/HMIS HEALTH FIRE REACTIVITY SPECIAL (1) PROTECTIVE EQUIPMENT CODE TRANSLATION 2 MODERATE HAZARD 1 SLIGHT HAZARD 0 MINIMAL HAZARD NONE NO SPECIAL HAZARD B GOGGLES, GLOVES (1) REFER TO SECTION 8 OF MSDS FOR ADDITIONAL RECOMMENDATIONS. PROTECTIVE EQUIPMENTCHANGE LOG: EFFECTIVE DATE MSDS STATUS 31-JAN-2005 15-MAR-2007 28-SEP-2007 08-FEB-2008 27-FEB-2008 REVISIONS TO SECTION 2, 8 12; EDIT: REBRANDING 12; EDIT: REBRANDING 2, 4, 8 SUPERCEDES NEW 31-JAN-2005 15-MAR-2007 28-SEP-2007 08-FEB-2008 Copyright© 1999-2009 Dolphin Software, Inc.Comply Plus Web -Hosted FPL Energyhttp://fplenergy.complyplus.com/MSDS/print bare.asp?S=3265&ShowTOC= 1 &ShowHazardRatings= 1... 6/17/2009 SPECTRUS BD1501E by GE BETZ 16 OTHER INFORMATION NFPA/HMIS HEALTH FIRE 2 1 CODE TRANSLATION MODERATE HAZARD SLIGHT HAZARD REACTIVITY 0 MINIMAL HAZARD SPECIAL NONE NO SPECIAL HAZARD (1) PROTECTIVE EQUIPMENT B GOGGLES, GLOVES (1) REFER TO SECTION B OF MSDS FOR ADDITIONAL PROTECTIVE EQUIPMENT RECOMMENDATIONS. CHANGE LOG: EFFECTIVE DATE MSDS STATUS 31-JAN-200S lS-MAR-2007 28-SEP-2007 OB-FEB-2008 27-FEB-200B REVISIONS TO SECTION SUPERCEDES 2, 12; 12; 2, NEW B 31-JAN-200S EDIT: REBRANDING lS-MAR-2007 EDIT: REBRANDING 2B-SEP-2007 4, 8 OB-FEB-200B Copyright© 1999-2009 Dolphin Software, Ino, Comply Plus Web -Hosted FPL Energy Page 7 of7 http://fplenergy.complypius.comIMSDS/print_ bare.asp?S=3265&ShowTOC= 1 &ShowHazardRatings= 1... 6/17/2009 INM/BITOR AZ8 100 by BETZ DEARBORN FPL Energy Duane Arnold INHIBITOR AZ8100 BETZ DEARBORN FileName Language Internal ID Revision Date 000146 0081 5/3/2000 Table Of Contents 1 PRODUCT IDENTIFICATION 2 COMPOSITION / INFORMATION ON INGREDIENTS 3 HAZARDS IDENTIFICATION 4 FIRST AID MEASURES 5 FIRE FIGHTING MEASURES 6 ACCIDENTAL RELEASE MEASURES 7 HANDLING & STORAGE 8 EXPOSURE CONTROLS/PERSONAL PROTECTION 9 PHYSICAL & CHEMICAL PROPERTIES 10 STABILITY & REACTIVfTY 11 TOXICOLOGICAL INFORMATION 12 ECOLOGICAL INFORMATION 13 DISPOSAL CONSIDERATIONS 14 TRANSPORT INFORMATION 15 REGULATORY INFORMATION 16 OTHER INFORMATION Hazards MSDS State NFPA HMlIS (Active)Health 3 3 Flammability 1 1 Reactivity 0 0 Other CO D BD BETZ DEARBORN ISSUE DATE: 03-MAY-2000 MATERIAL SAFETY DATA SHEET BETZ DEARBORN, DIVISION OF HERCULES INCORPORATED 4636 SOMERTON ROAD, TREVOSE PA 19053 BUSINFS TELEPHONE: (215) -355-3300 EMERGENCY TELEPHONE (REALTH/ACCIDENT): (800)-877-1940 (USA)HMIS RATINGS(SEE SECTION 16 FOR ADDITIONAL INFORMATION) HEALTH: 3 FLAMMABILITY: 1 REACTIVITY: 0 1 PRODUCT IDENTIFICATION Page 1 of 8 PRODUCT NAME: INHIBITOR AZ8100 http://fplenergy.complyplus.com/MSDS/printbare.asp?S= 112&ShowTOC= I &ShowHazardRatings= I &... 6/17/2009 INHIBITOR AZ81 00 by BETZ DEARBORN FPL Energy Duane Arnold INHIBITOR AZ8100 FileName Language InternalID 000146 0081 Table Of Contents 1 PRODUCT IDENTIFICATION 2 COMPOSmON / INFORMATION ON INGREDIENTS 3 HAZARDS IDENTIFICATION 4 FIRST AID MEASURES 5 FIRE FIGHTING MEASURES 6 ACCIDENTAL RELEASE MEASURES 7 HANDLING & STORAGE 8 EXPOSURE CONTROLS/PERSONAL PROTECTION 9 PHYSICAL & CHEMICAL PROPERTIES 10 STABIlITY & REACTIVITY 11 TOXICOLOGICAL INFORMATION 12 ECOLOGICAL INFORMATION 13 DISPOSAL CONSIDERATIONS 14 TRANSPORT INFORMATION 15 REGULATORY INFORMATION 16 OTHER INFORMATION Hazards MSDSState HMIS I Health 3 3 Flammability 1 1 Reactivity 0 0 Other CO D BD BETZ DEARBORN ISSUE DATE: OJ-MAY-20DO MATERIAL SAFETY DATA SHEET BETZ DEARBORN, DIVISION OF HERCULES INCORPORATED 4636 SOMERTON ROAD, TREVOSE PA 19053 TELEPHONE: (215) -355-3300 EMERGENCY TELEPHONE (HEALTH/ACCIDENT): (800)-877-1940 (USA) HMIS RATINGS (SEE SECTION 16 FOR ADDITIONAL INFORMATION) HEALTH: 3 FLAMMABILITY: 1 REACTIVITY: 0 1 PRODUCT IDENTIFICATION PRODUCT NAME: INHIBITOR AZB100' Page 1 of8 BETZ DEARBORN Date 5/3/2000 (Active) I http://fplenergy.complyplus.comIMSDS/print_bare.asp?S=112&ShowTOC=l&ShowHazardRatings=l&... 6117/2009 INHIBITOR AZ8100 by BETZ DEARBORN Page 2 of 8 PRODUCT APPLICATION AREA: WATER-BASED CORROSION INHIBITOR. 2 COMPOSITION / INFORMATION ON INGREDIENTS INFORMATION FOR SPECIFIC PRODUCT INGREDIENTS AS REQUIRED BY THE U.S. OSHA HAZARD COMMUNICATION STANDARD IS LISTED. REFER TO ADDITIONAL SECTIONS OF THIS MSDS FOR OUR ASSESSMENT OF THE POTENTIAL HAZARDS OF THIS FORMULATION. HAZARDOUS INGREDIENTS: CAS# CHEMICAL NAME 64665-57-2 BENZOTRIAZOLE, METHYL, SODIUM SALT (SODIUM TOLYLTRIAZOLE), (TTA)CORROSIVE (EYES AND SKIN); TOXIC (BY INGESTION) NO COMPONENT IS CONSIDERED TO BE A CARCINOGEN BY THE NATIONAL TOXICOLOGY PROGRAM, THE INTERNATIONAL AGENCY FOR RESEARCH ON CANCER, OR THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION AT OSHA THRESHOLDS FOR CARCINOGENS. 3 HAZARDS IDENTIFICATION EMERGENCY OVERVIEW DANGER CORROSIVE TO SKIN. CORROSIVE TO THE EYES. MISTS/AEROSOLS CAUSE IRRITATION TO THE UPPER RESPIRATORY TRACT.DOT HAZARD: CORROSIVE TO SKIN EMERGENCY RESPONSE GUIDE #154 ODOR: MILD APPEARANCE: AMBER, LIQUID FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS(FULL FACE-PIECE TYPE). PROPER FIRE-EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER POTENTIAL HEALTH EFFECTS ACUTE SKIN EFFECTS: PRIMARY ROUTE OF EXPOSURE; CORROSIVE TO SKIN.ACUTE EYE EFFECTS: CORROSIVE TO THE EYES.ACUTE RESPIRATORY EFFECTS: MISTS/AEROSOLS CAUSE IRRITATION TO THE UPPER RESPIRATORY TRACT.INGESTION EFFECTS: MAY CAUSE SEVERE IRRITATION OR BURNING OF THE GASTROINTESTINAL TRACT.TARGET ORGANS: http://fplenergy.complyplus.com/MSDS/printbare.asp?S= 11 2&ShowTOC= 1 &ShowHazardRatings=l &... 6/17/2009 INHIBITOR AZ8100 by BETZ DEARBORN PRODUCT APPLICATION AREA: WATER-BASED CORROSION INHIBITOR. 2 COMPOSITION I INFORMATION ON INGREDIENTS INFORMATION FOR SPECIFIC PRODUCT INGREDIENTS AS REQUIRED BY THE u.S. OSHA HAZARD COMMUNICATION STANDAAD IS LISTED. REFER TO ADDITIONAL SECTIONS OF THIS MSDS FOR OUR ASSBSSMENT OF THE POTENTIAL HAZARDS OF THIS FORMULATION. HAZARDOUS INGREDIENTS: CAS II 64665-57-2 CHEMICAL NAME BENZOTRIAZOLE, METHYL, SODIUM SALT (SODIUM TOLYLTRIAZOLE), (TTA) CORROSIVE (BYES AND SKIN) i TOXIC (BY INGESTION) NO COMPONENT IS CONSIDERED TO BE A CARCINOGEN BY THE NATIONAL TOXICOLOGY PROGRAM, THE INTERNATIONAL AGENCY FOR RESEARCH ON CANCER, OR THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION AT OSHA THRESHOLDS FOR CARCINOGENS. 3 HAZARDS IDENTIFICATION EMERGENCY OVERVIEW DANGER CORROSIVE TO SRIN. CORROSIVE TO THE EYES. MISTS/AEROSOLS CAUSE IRRITATION TO THE UPPER RESPIRATORY TRACT. DOT HAZARD: CORROSIVE TO SKIN EMERGENCY RESPONSE GUIDE #154 ODOR: MILD APPEARANCE: AMBER, LIQUID FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS(FULL FACE-PIECE TYPE). PROPER FIRE-EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER POTENTIAL HEALTH EFFECTS ACUTE SKIN EFFECTS: PRIMARY ROUTE OF EXPOSURE; CORROS IVE TO SKIN. ACUTE EYE EFFECTS: CORROSIVE TO THE EYES. ACUTE RESPIRATORY EFFECTS: MISTS/AEROSOLS CAUSE IRRITATION TO THE UPPER RESPIRATORY TRACT. INGESTION EFFECTS: MAY CAUSE SEVERE IRRITATION OR BURNING OF THE GASTROINTESTINAL TRACT. TARGET ORGANS: Page 2 of8 http://fplenergy.complyplus.comIMSDS/prinC bare.asp?S=112&ShowTOC= 1 &ShowHazardRatings=l &... 6117/2009 INHIBITOR AZ8100 by BETZ DEARBORN Page 3 of 8 PROLONGED OR REPEATED EXPOSURES MAY CAUSE TISSUE NECROSIS.MEDICAL CONDITIONS AGGRAVATED: NOT KNOWN.SYMPTOMS OF EXPOSURE: CAUSES REDNESS OR ITCHING OF SKIN, POSSIBLY LEADING TO BURNS (DEPENDENT ON THE LENGTH OF EXPOSURE). 4 FIRST AID MEASURES SKIN CONTACT: REMOVE CLOTHING. WASH AREA WITH LARGE AMOUNTS OF SOAP SOLUTION OR WATER FOR 15 MIN. IMMEDIATELY CONTACT PHYSICIAN. EYE CONTACT: REMOVE CONTACT LENSES. HOLD EYELIDS APART. IMMEDIATELY FLUSH EYES WITH PLENTY OF LOW-PRESSURE WATER FOR AT LEAST 15 MINUTES. GET IMMEDIATE MEDICAL ATTENTION. INHALATION: REMOVE TO FRESH AIR. APPLY NECESSARY FIRST AID TREATMENT. IMMEDIATELY CONTACT A PHYSICIAN. INGESTION: DO NOT FEED ANYTHING BY MOUTH TO AN UNCONSCIOUS OR CONVULSIVE VICTIM. DO NOT INDUCE VOMITING. IMMEDIATELY CONTACT PHYSICIAN. DILUTE CONTENTS OF STOMACH USING 3-4 GLASSES MILK OR WATER.NOTE TO PHYSICIANS: NO SPECIAL INSTRUCTIONS 5 FIRE FIGHTING MEASURES FIRE FIGHTING INSTRUCTIONS: FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE).EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER HAZARDOUS DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES.FLASH POINT: > 200 F > 93 C SETA (CC)MISCELLANEOUS: CORROSIVE TO SKIN UN1719; EMERGENCY RESPONSE GUIDE #154 6 ACCIDENTAL RELEASE MEASURES PROTECTION AND SPILL CONTAINMENT: VENTILATE AREA. USE SPECIFIED PROTECTIVE EQUIPMENT. CONTAIN AND ABSORB ON ABSORBENT MATERIAL. PLACE IN WASTE DISPOSAL CONTAINER. FLUSH AREA WITH WATER. WET AREA MAY BE SLIPPERY. SPREAD SAND/GRIT. http://fplenergy.complyplus.com/MSDS/print-bare.asp?S= 112&ShowTOC= I &ShowHazardRatings=l &... 6/17/2009 INHIBITOR AZ8t 00 by BETZ DEARBORN PROLONGED OR EXPOSURES MAY CAUSE TISSUE NECROSIS. MEDICAL CONDITIONS AGGRAVATED: NOT KNOWN. SYMPTOMS OF EXPOSURE: CAUSES REDNESS OR ITCHING OF SKIN, POSSIBLY LEADING TO BURNS (DEPENDENT ON THE LENGTH OF EXPOSURE) . 4 FIRST AID MEASURES SKIN CONTACT: REMOVE CLOTHING. WASH AREA WITH LARGE AMOUNTS OF SOAP SOLUTION OR WATER FOR lS MIN. IMMEDIATELY CONTACT PHYSICIAN. EYE CONTACT: CONTACT LENSES. HOLD EYELIDS APART. IMMEDIATELY FLUSH EYES WITH PLENTY OF LOW-PRESSURE WATER FOR AT LEAST 15 MINUTES. GET IMMEDIATE MEDICAL ATTENTION. INHALATION: REMOVE TO FRESH AIR. APPLY NECESSARY AID TREATMENT. IMMEDIATELY CONTACT A PHYSICIAN. INGESTION: DO NOT FEED ANYTfUNG BY MOUTH TO AN UNCONSCIOUS OR CONVULSIVE VICTIM. DO NOT INDUCE VOMITING. IMMEDIATELY CONTACT PHYSICIAN. DILUTE CONTENTS OF STOMACH USING 3-4 GLASSES MILK OR WATER. NOTE TO PHYSICIANS: NO SPECIAL INSTROCTIONS 5 FIRE FIGHTING MEASURES FIRE FIGHTING INSTRUCTIONS: FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE) . EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER HAZARDOUS DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES. FLASH POINT: > 200 F > 93 C SETA (CC) MISCELLANEOUS: CORROSIVE TO SKIN UN1719; BMERGENCY RESPONSE GUIDB #154 6 ACCIDENTAL RELEASE MEASURES PROTECTION AND SPILL CONTAINMENT: VENTILATE AREA. USE SPECIFIED PROTECTIVE EQUIPMENT. CONTAIN AND ABSORB ON ABSORBENT MATERIAL. PLACE IN WASTE DISPOSAL CONTAINER. FLUSH AREA WITH WATER. WET AREA MAY BE SLIPPERY. SPREAD SAND/GRIT. Page 3 of8 http://fplenergy.complyplus.comlMSDS/print_ bare.asp?S= 112&ShowTOC= 1 &ShowHazardRatings=l &... 6117/2009 INHIBITOR AZ8 100 by BETZ DEARBORN DISPOSAL INSTRUCTIONS: WATER CONTAMINATED WITH THIS PRODUCT MAY BE SENT TO A SANITARY SEWER TREATMENT FACILITY, IN ACCORDANCE WITH ANY LOCAL AGREEMENT, A PERMITTED WASTE TREATMENT FACILITY OR DISCHARGED UNDER A PERMIT. PRODUCT AS IS -INCINERATE OR LAND DISPOSE IN AN APPROVED LANDFILL.7 HANDLING & STORAGE HANDLING: ALKALINE. CORROSIVE (SKIN/EYES). DO NOT MIX WITH ACIDIC MATERIAL.STORAGE: KEEP CONTAINERS CLOSED WHEN NOT IN USE. STORE IN COOL VENTILATED LOCATION.STORE AWAY FROM OXIDIZERS. 8 EXPOSURE CONTROLS/PERSONAL PROTECTION EXPOSURE LIMITS CHEMICAL NAME: BENZOTRIAZOLE, METHYL, SODIUM SALT (SODIUM TOLYLTRIAZOLE), (TTA)PEL (OSHA): NOT DETERMINED TLV (ACGIH): NOT DETERMINED ENGINEERING CONTROLS: ADEQUATE VENTILATION PERSONAL PROTECTIVE EQUIPMENT: USE PROTECTIVE EQUIPMENT IN ACCORDANCE WITH 29 CFR 1910 SUBPART I RESPIRATORY PROTECTION: A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CFR 1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE. USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS. IF AIR-PURIFYING RESPIRATOR USE IS APPROPRIATE, USE A RESPIRATOR WITH DUST/MIST FILTERS.SKIN PROTECTION: GAUNTLET-TYPE NEOPRENE GLOVES, CHEMICAL RESISTANT APRON -- WASH OFF AFTER EACH USE. REPLACE AS NECESSARY. EYE PROTECTION: SPLASH PROOF CHEMICAL GOGGLES, PACE SHIELD 9 PHYSICAL & CHEMICAL PROPERTIES Page 4 of 8 SPECIFIC GRAV. (70 F, 22 C): 1,215 VAPOR PRESSURE (MM HG): APPROX. 18.0 FREEZE POINT (F): -25 FREEZE POINT (C): -32 VAPOR DENSITY (AIR=1): < 1.00 http://fplenergy.complyplus.com/MSDS/print-bare.asp?S= 112&ShowTOC= I &ShowHazardRatings= 1 &... 6/17/2009 INHIBITOR AZ81 00 by BETZ DEARBORN DISPOSAL INSTROCTIONS: WATER CONTAMINATED WITH THIS PRODUCT MAY BE SENT TO A SANITARY SEWER TREATMENT FACILITY, IN ACCORDANCE WITH ANY LOCAL AGREEMENT, A PERMITTED WASTE TREATMENT FACILITY OR DISCHARGED UNDER A PERMIT. PRODUCT AS IS -INCINERATE OR LAND DISPOSE IN AN APPROVED LANDFILL. 7 HANDLING & STORAGE HANDLING: ALKALINE. CORROSIVE (SKIN/EYES). DO NOT MIX WITH ACIDIC MATERIAL. STORAGE: KEEP CONTAINERS CLOSED WHEN NOT IN USE. STORE IN COOL VENTILATED LOCATION. STORE AWAY FROM OXIDIZERS. B EXPOSURE CONTROLS/PERSONAL PROTECTION EXPOSURE LIMITS CHEMICAL NAME: BENZOTRIAZOLE, METHYL, SODIUM SALT (SODIUM TOLYLTRIAZOLE), (TTA) PEL (OSHA): NOT DETERMINED TLV (ACGIH): NOT DETERMINED ENGINEERING CONTROLS: ADEQUATE VENTILATION PERSONAL PROTECTIVE EQUIPMENT: USE PROTECTIVE EQUIPMENT IN ACCORDANCE WITH 29 CFR 1910 SUBPART I RESPIRATORY PROTECTION: A RESPIRATORY PROTECTION PROGR.AM THAT MEETS OSHA'S 29 CFR 1910.134 AND ANSI ZBB.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE. USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS. IF AIR-PURIFYING RESPIRATOR USE IS APPROPRIATE, USE A RESPIRATOR WITH DUST/MIST FILTERS. SKIN PROTECTION: GAUNTLET-TYPE NEOPRENE GLOVES, CHEMICAL RESISTANT APRON --WASH OFF AFTER EACH USE. REPLACE AS NECESSARY. EYE PROTECTION: SPLASH PROOF CHEMICAL GOGGLES, FACE SHIELD 9 PHYSICAL & CHEMICAL PROPERTIES SPECIFIC GRAV. (70 F, 21 C): 1.215 VAPOR PRESSURE (MM HG): APPROX. lB.O FREEZE POINT (F): -25 FREEZE POINT (C): -32 VAPOR DENSITY 1.00 Page 4 of8 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S= 112&ShowTOC= l&ShowHazardRatings;;::: 1 &... 6/17/2009 INHIBITOR AZ8 100 by BETZ DEARBORN Page 5 of 8 VISCOSITY (CPS 70 F, 21 C): 190% SOLUBILITY (WATER): 100.0 ODOR: MILD APPEARAHCE: AMBER PHYSICAL STATE: LIQUID FLASH POINT SETA(CC): > 200 F > 93 C PH AS IS (APPROX.)

13.0 EVAPORATION RATE (ETHER=1)

< 1.00 NA = NOT APPLICABLE ND = NOT DETERMINED 10 STABILITY & REACTIVITY STABILITY: STABLE UNDER NORMAL STORAGE CONDITIONS. HAZARDOUS POLYMERIZATION: WILL NOT OCCUR.INCOMPATIBILITIES: MAY REACT WITH ACIDS.DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES.BETZ DEARBORN INTERNAL PUMPOUT/CLEANOUT CATEGORIES: "C" 11 TOXICOLOGICAL INFORMATION ORAL LD50 RAT: 1,150 MG/KG DERMAL LD50 RABBIT: > 2,000 MG/KG NOTE -ESTIMATED VALUE 12 ECOLOGICAL INFORMATION AQUATIC TOXICOLOGY DAPHNIA MAGNA 48 HOUR STATIC RENEWAL BIOASSAY PH OF 'TEST SOLUTIONS WAS ADJUSTED TO A LEVEL OF 6-9, LC50: 243 MG/L NO EFFECT LEVEL: 75 MG/L BLUEGILL SUNFISH 96 HOUR STATIC ACUTE BIOASSAY LC50: 109.3 MG/L http://fplenergy.complyplus.com/MSDS/print-bare.asp?S= 11 2&ShowTOC= I &ShowHazardRatings= I &... 6/17/2009 INHIBITOR AZ8100 by BETZ DEARBORN (CPS 70 F, 21 C): 190 % SOLUBILITY (WATER): 100.0 ODOR: MILD AMBER PHYSICAL STATE,' LIQUID FLASH POINT SETA(CC): > 200 F > 93 C PH AS IS (APPROX.), 13.0 EVAPORATION RATE (ETHERml}: < 1.00 NA = NOT APPLICABLE NO = NOT DETERMINED 10 STABILITY & REACTIVITY STABILITY, STABLE UNDER NORMAL STORAGE CONDITIONS. HAZARDOUS POLYMERIZATION, WILL NOT OCCUR. INCOMPATIBILITIES: MAY REACT WITH ACIDS. DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES. BETZ DEARBORN INTERNAL PUMPOUT/CLEANOUT CATEGORIES:

• C* 11 TOXICOLOGICAL INFORMATION ORAL LDSO RAT: 1,150 MG/KG DERMAL LDSO RABBIT: " 2,000 MG/KG NOTE -ESTIMATED VALUE 12 ECOLOGICAL INFORMATION AQUATIC TOXICOLOGY DAPHNIA MAGNA 48 HOUR STATIC RENEWAL BIOASSAY PH OF TEST SOLUTIONS WAS ADJUSTED TO A LEVEL OF 6-9. LCSO: 243 MG/L NO EFFECT LEVEL, 75 MG/L BLUEGILL SUNFISH 96 HOUR STATIC ACUTE BIOASSAY LCSO, 109.3 MG/L Page 5 of8 http://fplenergy .complyplus.comJMSDS/print_

bare.asp?S= 1 12&ShowTOC= 1 &ShowHazardRatings=l &... 6117/2009 INHIBITOR AZ8100 by BETZ DEARBORN NO EFFECT LEVEL: 42 MG/L MYSID SHRIMP 48 HOUR STATIC ACUTE BIOASSAY LC50: 166 MG/L NO EFFECT LEVEL: 10 MG/L SHEEPSHEAD MINNOW 48 HOUR STATIC ACUTE BIOASSAY LC50: 475 MG/L NO EFFECT LEVEL: 370 MG/L FATHEAD MINNOW 96 HOUR STATIC RENEWAL BIOASSAY PH OF TEST SOLUTIONS WAS ADJUSTED TO A LEVEL OF 6-9.LC50: 105 MG/L NO EFFECT LEVEL: 75 MG/L RAINBOW TROUT 96 HOUR STATIC RENEWAL BIOASSAY LC50: 34 MG/L NO EFFECT LEVEL: 15 MG/L CERIODAPHNIA 48 HOUR STATIC RENEWAL BIOASSAY LC50: 147 MG/L NO EFFECT LEVEL: 37 MG/L BIODEGRADATION:COD (MG/GM)

810 TOC (MG/GM): 280 BOD-5 (MG/GM): 4 BOD-28 (MG/GM) : 22 13 DISPOSAL CONSIDERATIONS IF THIS UNDILUTED PRODUCT IS DISCARDED AS A WASTE, THE US RCRA HAZARDOUS WASTE IDENTIFICATION NUMBER IS: D002=CORROSIVE(PH).

PLEASE BE ADVISED; HOWEVER, THAT STATE AND LOCAL REQUIREMENTS FOR WASTE DISPOSAL MAY BE MORE RESTRICTIVE OR OTHERWISE DIFFERENT FROM FEDERAL REGULATIONS. CONSULT STATE AND LOCAL REGULATIONS REGARDING THE PROPER DISPOSAL OF THIS MATERIAL.14 TRANSPORT INFORMATION Page 6 of 8 DOT HAZARD: CORROSIVE TO SKIN UN / NA NUMBER: UN1719 DOT EMERGENCY RESPONSE GUIDE #: 154 http://fplenergy.complyplus.comi/MSDS/print-bare.asp?S= 112&ShowTOC= 1 &ShowHazardRatings= l&... 6/17/2009 INHIBITOR AZ81 00 by BETZ DEARBORN NO EFFECT LEVEL: 42 MG/L MYSID SHRIMP 48 HOUR STATIC ACUTE BIOASSAY LCSO: 166 MG/L NO EFFECT LEVEL: 10 MG/L SHEEPSHEAD MINNOW 48 HOUR STATIC ACUTE BIOASSAY LCSO: 475 MG/L NO EFFECT LEVEL: 370 MG/L FATHEAD MINNOW 95 HOUR STATIC RENEWAL BIOASSAY PH OF TEST SOLUTIONS WAS ADJUSTED TO A LEVEL OF 6-9. LCSO: 105 MG/L NO EFFECT LEVEL: 75 MG/L RAINBOW TROUT 96 HOUR STATIC RENEWAL BIOASSAY LCSO: 34 MG/L NO EFFECT LEVEL: is MG/L CERIODAPHNIA 48 HOUR STATIC RENEWAL BIOASSAY LCSO: 147 MG/L NO EFFECT LEVEL: 37 MG/L BIODEGRADATION: COD (MG/GM): 810 TOC (MG/GM): 280 BOD-5 (MG/GM): 4 BOD-28 (MG/GM): 22 13 DISPOSAL CONSIDERATIONS IF THIS UNDILUTED PRODUCT IS DISCARDED AS A WASTE, THE US RCRA HAZARDOUS WASTE IDENTIFICATION NUMBER IS: D002=CORROSIVE(PH). PLEASE BE ADVISED; HOWEVER, THAT STATE AND LOCAL REQUIREMENTS FOR WASTE DISPOSAL MAY BE MORE RESTRICTIVE OR OTHERWISE DIFFERENT FROM FEDERAL REGULATIONS. CONSULT STATE AND LOCAL REGULATIONS REGARDING TaB PROPER DISPOSAL OF THIS MATERIAL. 14 TRANSPORT INFORMATION DOT HAZARD: CORROS lVE TO SKIN UN / NA NUMBER: 001719 DOT EMERGENCY RESPONSE GUIDE #: 154 Page 60f8 http://fplenergy.complyplus.com/MSDS/print_ bare. asp ?S= 112&ShowTOC= 1 &ShowHazardRatings= 1 &... 6/17/2009 INHIBITOR AZ8 100 by BETZ DEARBORN 15 REGULATORY INFORMATION Page 7 of 8 TSCA: ALL COMPONENTS OF THIS PRODUCT ARE LISTED IN THE TSCA INVENTORY. CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ): NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS SARA SECTION 312 HAZARD CLASS: IMMEDIATE (ACUTE);DELAYED (CHRONIC)SARA SECTION 302 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS SARA SECTION 313 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS CALIFORNIA REGULATORY INFORMATION CALIFORNIA SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT (PROPOSITION 65)CHEMICALS PRESENT: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS MICHIGAN REGULATORY INFORMATION: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS 16 OTHER INFORMATION NFPA/HMIS CODE TRANSLATION HEALTH FIRE REACTIVITY SPECIAL (1) PROTECTIVE EQUIPMENT (1) REFER TO SECTION 8 OF RECOMMENDATIONS. 3 1 0 CORR D SERIOUS HAZARD SLIGHT HAZARD MINIMAL HAZARD DOT CORROSIVE GOGGLES, FACE SHIELD, GLOVES, APRON MSDS FOR ADDITIONAL PROTECTIVE EQUIPMENT CHANGE LOGEFFECTIVE REVISIONS DATE TO SECTION: MSDS STATUS: 28-JAN-1997

19-FEB-1997 03-OCT-1997 29-MAY-1998 08-FEB-1999 15-JUN -1999 30-AUG-1999 03-MAY-2000 12 8 12 3,5,14 12 4; EDIT: 9 12 SUPERCEDES

• • NEW **28-JAN-1997 19-FEB-1997 03-OCT-1997 29-MAY-1998 08-FEB-1999 15-OTJN-1999 30-AUG-1999 http://fplenergy.complyplus.com/MSDS/printbare.asp?S=

112&ShowTOC= I &ShowHazardRatings= 1 &... 6/17/2009 INHIBITOR AZ8 I 00 by BETZ DEARBORN 15 REGULATORY INFORMATION TSCA: ALL COMPONENTS OF THIS PRODUCT ARE LISTED IN THE TSCA INVENTORY. CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ): NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS SARA SECTION 312 HAZARD CLASS: IMMEDIATE (ACO'TE) ; DELAYED (CHRONIC) SARA SECTION 302 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS SARA SECTION 313 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS CALIFORNIA REGULATORY INFORMATION CALIFORNIA SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT (PROPOSITION

65) CHEMICALS PRESENT: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS MICHIGAN REGULATORY INFORMATION:

NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS 16 OTHER INFORMATION NFPA/HMIS CODE TRANSLATION HEALTH 3 SERIOUS HAZARD FIRE 1 SLIGHT HAZARD REACTIVITY 0 MINIMAL HAZARD SPECIAL CORR DOT CORROS lVE (1) PROTECTIVE EQUIPMENT D GOGGLES, FACE SHIELD, GLOVES, APRON (1) REFER TO SECTION 8 OF MSDS FOR ADDITIONAL PROTECTIVE EQUIPMENT RECOMMENDATIONS. CHANGE LOG EFFECTIVE REVISIONS SUPERCEDES DATE TO SECTION: MSDS STATUS: 28-JAN-1997

• • NEW ** 19-FEB-1997 12 28-JAN-1997 03-0CT-1997 8 19-FEB-1997 29-MAY-1998 12 03-0CT-1997 08-FEB-1999 3,5,14 29-MAY-199B 15-JUN-1999 12 OS-FEB-1999 30-AUG-1999 4; EDIT: 9 15-JUN-1999 03-MAY-2000 12 30-AUG-1999 Page 7of8 http://fplenergy.complyplus.comIMSDS/print_

bare.asp?S= 1 12&ShowTOC= 1 &ShowHazardRatings= 1 &." 6/17/2009 INHIBITOR AZ8 100 by BETZ DEARBORN CopyrghtO 1999-2009 Dolphin Software, Inc.Comply Plus Web -Hosted FPL Energy Page 8 of 8 hptp://fplenergy.complyplus.com/MSDS/printbare.asp?S= 112&ShowTOC= 1 &ShowHazardRatings= 1 &... 6/17/2009 INHIBITOR AZ81 00 by BETZ DEARBORN Copyrigh/@l1999-2009 Dolphin Software, Inc. Comply Plus Web. Hosted FPL Energy Page 8 of8 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S= 112&ShowTOC= 1 &ShowHazardRatings= 1 & .. , 6117/2009 SODIUM HYPOCHLORITE by K.A. STEEL CHEMICALS FPL Energy Duane Arnold SODIUM HYPOCHLORITE K.A. STEEL CHEMICALS FileName Language Internal ID Revision Date 000285 0398 4/1/2002 Table Of Contents SECTION 1: PRODUCT IDENTIFICATION SECTION 2: PHYSICAL DATA & INGREDIENTS SECTION 3: FIRE & EXPLOSION INFORMATION SECTION 4: REACTIVITY DATA SECTION 5: LEAK, SPILL, DISPOSAL SECTION 6: HEALTH HAZARD DATA SECTION 7: EMERGENCY & FIRST AID PROCEDURES SECTION 8: OCCUPATIONAL CONTROL SECTION 9: HANDLING & STORAGE SECTION 10: REGULATORY INFORMATION Hazards 14SDS State NFPA HMIS F (Active)Health 3 3 Flammability 0 0 Reactivity 0 0 Other K.A. STEEL CHEMICALS INC.15185 MAIN STREET LEMONT, IL 60439 630-257-3900 MATERIAL SAFETY DATA SHEET SODIUM HYPOCHLORITE SECTION 1: PRODUCT IDENTIFICATION Page I of 5 PRODUCT NAME: SODIUM HYPOCHLORITE SOLUTION REVISION DATE: APRIL I, 2002 MOLECULAR WEIGHT: 74.44 ID NUMBER: UN 1791 CHEMICAL FORMULA: NaOCL (AQUEOUS SOLUTION)CAS NUMBER: 7681-52-9 CHEMICAL NAME: SODIUM HYPOCHLORITE (AQUEOUS SOLUTION)EMERGENCY NUMBERS: 24 HOUR EMERGENCY: CHEMTREC 1-800-424-9300 PRODUCT INFORMATION: LEMONT, IL 1-630-257-3900 http://fplenergy.complyplus.comr/MSDS/printbare.asp?S=213 &ShowTOC= l&ShowHazardRatings= 1&... 6/17/2009 SODIUM HYPOCHLORITE by K.A. STEEL CHEMICALS FPL Energy Duane Arnold SODIUM HYPOCHLORITE FileName Language Internal1D 000285 0398 Table Of Contents SECTION 1: PRODUCT IDENTIFICATION SECTION 2: PHYSICAL DATA & INGREDIENTS SECTION 3: FIRE & EXPLOSION INFORMATION SECTION 4: REACTIVITY DATA SECTION 5: LEAK, SPILL, DISPOSAL SECTION 6: HEALTH HAZARD DATA SECTION 7: EMERGENCY & FIRST AID PROCEDURES SECTION 8: OCCUPATIONAL CONTROL SECTION 9: HANDUNG &. STORAGE SECTION 10: REGULATORY INFORMATION Hazards NFPA Health 3 Flammability 0 Reactivity 0 Other K.A. STEEL CHEMICALS INC. 15185 MAIN STREET LEMONT, IL 60439 630-257-3900 MATERIAL SAFETY DATA SHEET SODIUM HYPOCHLORITE SECTION 1: PRODUCT IDENTIFICATION HMIS 3 0 0 PRODUCT NAME: SODIUM HYPOCHLORITE SOLUTION REVISION DATE: APRIL 1, 2002 MOLECULAR WEIGHT: 74.44 ID NUMBER: ON 1791 CHEMICAL FORMULA: NaDeL (AQUEOUS SOLUTION) CAS NUMBER: 7681-52-9 MSDSState I CHEMICAL NAME: SODIUM HYPOCHLORITE (AQUEOUS SOLUTION) EMERGENCY NUMBERS: 24 HOUR EMERGENCY: CHEMTREC 1-800-424-9300 PRODUCT INFORMATION: LEMONT, XL 1-630-257-3900 Page 1 ofS K.A. STEEL CHEMICALS RevisiQn Date 4/1/2002 (Active) I http://fplenergy.complyplus.comlMSDS/print_ bare.asp?S=213&ShowTOC=1 &ShowHazardRatings=l &... 6/17/2009 SODIUM HYPOCHLORITE by K.A. STEEL CHEMICALS Page 2 of 5 SECTION 2: PHYSICAL DATA & INGREDIENTS APPEARANCE: CLEAR TO LIGHT YELLOW LIQUIDODOR: PUNGENT, IRRITATING, THAT OF HOUSEHOLD BLEACH.VAPOR PRESSURE: APPROX. THAT OF AIR.BOILING POINT: DECOMPOSES PRIOR TO BOILING.SOLUBILITY: COMPLETELY IN WATER.VAPOR DENSITY (AIR = I): APPROX. THAT OF AIR.PH OF SOLUTIONS: APPROX. 12 SPECIFIC GRAVITY: 1.0690 @ 6.0% BY VOLUME @ 68 DEG. F 1.2180 @ 15.5% BY VOLUME @ 68 DEG. F 1.265 0 20% BY VOLUME @ 68 DEG. F INGREDIENTS MATERIALS: SODIUM HYPOCHLORITE 5 -20%SODIUM HYDROXIDE 0.3 -5% APPROX.WATER BALANCE SECTION 3: FIRE & EXPLOSION INFORMATION FIRE: NOT CONSIDERED TO BE A FIRE HAZARD.EXPLOSION: NOT CONSIDERED AN EXPLOSION HAZARD.FIRE EXTINGUISHING MEDIA: USE ANY MEANS SUITABLE FOR EXTINGUISHING SURROUNDING FIRE.SECTION 4: REACTIVITY DATA STABILITY: STABLE UNDER ORDINARY CONDITIONS OF USE AND STORAGE. SLOWLY DECOMPOSES ON CONTACT WITH AIR. RATE INCREASES WITH THE CONCENTRATION AND TEMPERATURE. HAZARDOUS DECOMPOSITION PRODUCTS: DECOMPOSES UNDER VARIOUS MECHANISMS. MAY GENERATE CHLORINE OR OXYGEN WHICH MAY BE TOXIC AND EXPLOSIVE, RESPECTIVELY. HAZARDOUS POLYMERIZATION: THIS SUBSTANCE DOES NOT POLYMERIZE. INCOMPATIBILITY (MATERIALS TO AVOID): REACTS VIGOROUSLY WITH AMINES, AMMONIUM SALTS, REDUCING AGENTS, METHANOL, ACIDS http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=213 &ShowTOC= I &ShowHazardRatings= 1 &... 6/17/2009 SODIUM HYPOCHLORITE by K.A. STEEL CHEMICALS SECTION 2: PHYSICAL DATA & INGREDIENTS APPEARANCE: CLEAR TO LIGHT YELLOW LIQUID ODOR: PUNGENT, IRRITATING, THAT OF HOUSEHOLD BLEACH. VAPOR PRESSURE: APPROX. THAT OF AIR. BOILING POINT: DECOMPOSES PR!OR TO BOILING. SOLUBILITY: COMPLETELY IN WATER. VAPOR DENSITY (AIR = 1): APPROX. THAT OF AIR. PH OF SOLUTIONS: APPROX. 12 SPECIFIC GRAVITY: 1.0690 @ 6.0% BY VOLUME @ 68 DEG. F 1.2180 @ lS.S% BY VOLUME 68 DEG. F 1.265 @ 20% BY VOLUME @ 68 DEG. F INGREDIENTS MATERIALS: SODIUM HYPOCHLORITE SODIUM HYDROXIDE WATER S -20% 0.3 -S% APPROX. BALANCE SECTION 3: FIRE & EXPLOSION INFORMATION FIRE: NOT CONSIDERED TO BE A FIRE HAZARD. EXPLOSION: NOT CONSIDERED AN EXPLOSION HAZARD. FIRE EXTINGUISHING MEDIA: USE ANY MEANS SUITABLE FOR EXTINGUISHING SURROUNDING FIRE. SECTION 4: REACTIVITY DATA STABILITY: STABLE UNDER ORDINARY CONDITIONS OF USE AND STORAGE. SLOWLY DECOMPOSES ON CONTACT WITH AIR. RATE INCREASES WITH THE CONCENTRATION AND TEMPERATURE. HAZARDOUS DECOMPOSITION PRODUCTS: DECOMPOSES UNDER VARIOUS MECHANISMS. MAY GENERATE CHLORINE OR OXYGEN WHICH MAY BE TOXIC AND EXPLOSIVE, RESPECTIVELY. HAZARDOUS POLYMERIZATION: THIS SUBSTANCE DOES NOT POLYMERIZE. INCOMPATIBILITY (MATERIALS TO AVOID) : REACTS VIGOROUSLY WITH AMlNES, AMMONIUM SALTS, REDUCING AGENTS, METHANOL, ACIDS Page 2 of5 http://fplenergy.complyplus.comlMSDS/print_ bare.asp?S=213&ShowTOC= 1 &ShowHazardRatings::::l &... 6/17/2009 SODIUM HYPOCHLORITE by K.A. STEEL CHEMICALS Page 3 of 5 AND MOST ORGANICS. WILL LIBERATE CHLORINE GAS!SECTION 5: LEAK, SPILL, DISPOSAL STEPS TO BE TAKEN IF MATERIAL IS SPILLED OR RELEASED: KEEP MATERIAL FROM FLOWING TO SEWERS OR AREAS WHERE MIXING OF OTHER LIQUIDS MAY OCCUR. VENTILATE AREA OF LEAK OR SPILL, MOVE UNPROTECTED PERSONNEL UPWIND OUT OF DANGER.WASTE DISPOSAL METHOD: CONTAIN AND RECOVER LIQUID WHEN POSSIBLE. COLLECT LIQUID IN AN APPROPRIATE CONTAINER OR ABSORB WITH AN INERT MATERIAL (E.G., VERMICULITE, DRY SAND, EARTH), AND PLACE IN A CHEMICAL WASTE CONTAINER. DO NOT USE COMBUSTIBLE MATERIALS, SUCH AS SAW DUST. ENSURE COMPLIANCE WITH LOCAL, STATE AND FEDERAL REGULATIONS. SECTION 6: HEALTH HAZARD DATA IS CHEMICAL LISTED AS A CARCINOGEN OR POTENTIAL CARCINOGEN?: NTP: NO IARC: NO OSHA: NO MEDICAL CONDITION GENERALLY AGGRAVATED BY EXPOSURE-PERSONS WITH IMPAIRED RESPIRATORY FUNCTION OR HEART DISORDER (OR DISEASE) MAY BE MORE SUSCEPTIBLE TO THE EFFECTS OF THE SUBSTANCE. PERMISSIBLE EXPOSURE LIMIT: OSHA: SODIUM HYDROXIDE 2 MG/M3 CEILING CHLORINE 0.5 PPM 8 HOUR TWA, 1 PPM 15 MIN STEL ACUTE TOXICITY: DANGER CORROSIVE INGESTION: INGESTION OF A FEW OUNCES CAN CAUSE CORROSION OF MUCOUS MEMBRANES, SWELLING OF THE THROAT, PERFORATION OF THE ESOPHAGUS AND STOMACH, VOMITING, COLIC, ANDCIRCULATORY COLLAPSE. MAY LEAD TO UNCONSCIOUSNESS, COMA OR DEATH.EYE/SKIN: LIQUID CONTACT CAN PRODUCE IRRITATIONS OF THE SKIN WITH BLISTERING. DIRECT CONTACT WITH EYES MAY CAUSE REDNESS, PAIN AND IN THE CASE OF CONCENTRATED HYPOCHLORITE (20% BY VOLUME), PERMANENT DAMAGE.INHALATION: INHALATION OF MIST OR FUMES CAN CAUSE BRONCHIAL IRRITATION, COUGH, DIFFICULT BREATHING, INFLAMMATION OF THE MOUTH, NAUSEA, AND IN SEVERE EXPOSURES, PULMONARY EDEMA. MATERIAL HAS ODOR OF CHLORINE, CHRONIC TOXICITY: NO DATA FOUND SECTION 7: EMERGENCY & FIRST AID PROCEDURES INHALATION: http://fplenergy.conmplyplus.romMSDS/print-bare.asp?S=2 1 3&ShowTOC=I &ShowHazardRatings=l &... 6/17/2009 SODIUM HYPOCHLORlTE by K.A. STEEL CHEMICALS AND MOST ORGANICS. WILL LISERATE CHLORINE GAS! SECTION 5: LEAK, SPILL, DISPOSAL . STEPS TO BE TAKEN IF MATERIAL IS SPILLED OR RELEASED: KEEP MATERIAL FROM FLOWING TO SEWERS OR AREAS WHERE MIXING OF OTHER LIQUIDS MAY OCCUR. VENTILATE AREA OF LEAK OR SPILL. MOVE UNPROTECTED PERSONNEL UPWIND OUT OF DANGER. WASTE DISPOSAL METHOD: CONTAIN AND RECOVER LIQUID WHEN POSSIBLE. COLLECT LIQUID IN AN APPROPRIATE CONTAINER OR ABSORB WITH AN INERT MATERIAL (B.G., VERMICULITE, DRY SAND, EARTH), AND PLACE IN A CHEMICAL WASTE CONTAINER. DO NOT USE COMBUSTIBLE MATERIALS, SUCH AS SAW DUST. ENSURE COMPLIANCE WITH LOCAL, STATE AND FEDERAL REGULATIONS. SECTION 6: HEALTH HAZARD DATA IS CHEMICAL LISTED AS A CARCINOGEN OR POTENTIAL CARCINOGEN?: NTP: NO IARC: NO OSHA: NO MEDICAL CONDITION GENERALLY AGGRAVATED BY EXPOSURE: PERSONS WITH IMPAIRED RESPIRATORY FUNCTION OR HEART ,DISORDER (OR DISEASE) MAY BE MORE SUSCEPTIBLE TO THE EFFECTS OF THE SUBSTANCE. PERMISSIBLE EXPOSURE LIMIT: OSHA: SODIUM HYDROXIDE 2 MG/M3 CEILING CHLORINE 0.5 PPM 8 ,HOUR TWA, 1 PPM 15 MIN STEL ACUTE TOXICITY: DANGER CORROS!VE INGESTION: INGESTION OF A FEW OUNCES CAN CAUSE CORROSION OF MUCOUS MEMBRANES, SWELLING OF THE THROAT, PERFORATION OF THE ESOPHAGUS AND STOMACH, VOMITING, COLIC, AND CIRCULATORY COLLAPSE. MAY LEAD TO UNCONSCIOUSNESS, COMA OR DEATH. EYE/SKIN: LIQUID CONTACT CAN PRODUCE IRRITATIONS OF THE SKIN WITH BLISTERING. DIRECT CONTACT WITH EYES MAy CAUSE REDNESS, PAIN AND IN THE CASE OF CONCENTRATED HYPOCHLORITE (20% By VOLUME), PERMANENT DAMAGE. INHALATION: INHALATION OF MIST OR FUMES CAN CAUSE BRONCHIAL IRRITATION, COUGH, DIFFICULT BREATHING, INFLAMMATION OF THE MOUTH, NAUSEA, AND IN SEVERE EXPOSURES, PULMONARY EDEMA. MATERIAL HAS ODOR OF CHLORINE. CHRONIC TOXICITY: NO DATA FOUND SECTION 7: EMERGENCy & FIRST AID PROCEDURES INHALATION: Page 3 of5 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=213&ShowTOC== 1 &ShowHazardRatings=l &... 6117/2009 SODIUM HYPOCHLORITE by K.A. STEEL CHEMICALS Page 4 of 5 MOVE PERSON TO FRESH AIR. IF BREATHING IS DIFFICULT, ADMINISTER OXYGEN AND CALL A PHYSICIAN. IF NOT BREATHING, GIVE ARTIFICIAL RESPIRATION.EYE CONTACT:IMMEDIATELY FLUSH EYES WITH COPIOUS AMOUNTS OF WATER FOR AT LEAST 15 MINUTES, LIFTING LOWER AND UPPER EYELIDS OCCASIONALLY. SEEK MEDICAL ATTENTION. SKIN CONTACT:IMMEDIATELY FLUSH AFFECTED AREA WITH COPIOUS AMOUNTS OF WATER FOR AT LEAST 15MINUTES WHILE REMOVING ANY CONTAMINATED CLOTHING/SHOES. IF IRRITATION OCCURS, CONSULT A PHYSICIAN. INGESTION: DO NOT INDUCE VOMITING! GIVE LARGE QUANTITIES OF WATER. NEVER GIVE ANYTHING BY MOUTH TO AN UNCONSCIOUS PERSON. TAKE IMMEDIATELY TO A HOSPITAL OR PHYSICIAN. NOTES TO PHYSICIAN: DO NOT ADMINISTER ACIDIC ANTIDOTES OR SODIUM BICARBONATE FOLLOWING SODIUM HYPOCHLORITE OVEREXPOSURE. AN OUNCE OF 12 SODIUM THIOSULFATE OR MILK OF MAGNESIA IS HELPFUL.SECTION 8: OCCUPATIONAL CONTROL VENTILATION REQUIREMENTS: LOCAL EXHAUST.PERSONAL RESPIRATORS: RECOMMENDED FOR ALL PERSONNEL WORKING IN OR ABOUT AN AREA OF POTENTIAL MIST EXPOSURE. USE ONLY NIOSH/MSHA APPROVED RESPIRATOR FOR MISTS AND CHLORINE.SKIN PROTECTION REQUIREMENTS: WEAR IMPERVIOUS PROTECTIVE CLOTHING; INCLUDING BOOTS; GLOVES; LAB COAT; APRON OR COVERALLS TO PREVENT SKIN CONTACT. PREFERRED MATERIALS: NITRILE, NEOPRENE, PVC, RUBBER EYE PROTECTION REQUIREMENTS: USE CHEMICAL SAFETY GOGGLES IMPERVIOUS TO PRODUCT. CONTACT LENSES SHOULD NOT BE WORN WHEN WORKING WITH THIS MATERIAL. MAINTAIN EYE WASH FOUNTAIN AND QUICK-DRENCH FACILITIES IN IMMEDIATE WORK AREA.NOTE: ALL PROTECTIVE EQUIPMENT MUST CONFORM WITH 29 CFR 1910.132.SECTION 9: HANDLING & STORAGE STORE IN A COOL, DRY VENTILATED AREA. PROTECT AGAINST PHYSICAL DAMAGE. KEEP SEPARATE FROM ACIDS AND ORGANICS. LABEL ALL PIPELINES, STORAGE VESSELS, AND OTHER OFFLOAD CONNECTIONS. SECTION 10: REGULATORY INFORMATION DOT HAZARD CLASS: CORROSIVE MATERIAL -8DOT PLACARD REQUIRED: CORROSIVE -UN 1791 http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=2 1 3&ShowTOC=I &ShowHazardRatings= 1 &... 6/17/2009 SODIUM HYPOCHLORITE by K.A. STEEL CHEMICALS MOVE PERSON TO FRESH AIR. IF BREATHING IS DIFFICULT, ADMINISTER OXYGEN AND CALL A PHYSICIAN. IF NOT BREATHING, GIVE ARTIFICIAL RESPIRATION. EYE CONTACT: IMMEDIATELY FLUSH EYES WITH COPIOUS AMOUNTS OF WATER FOR AT LEAST 15 MINUTES, LIFTING LOWER AND UPPER EYELIDS OCCASIONALLY. SEEK MEDICAL ATTENTION. SKIN CONTACT: IMMEDIATELY FLUSH AFFECTED AREA WITH COPIOOS AMOUNTS OF WATER FOR AT LEAST 15 MINUTES WHILE REMOVING ANY CONTAMINATED CLOTHING/SHOES. IF IRRITATION OCCURS, CONSULT A PHYSICIAN. INGESTION: DO NOT INDUCE VOMITINGl GIVE LARGE QUANTITIES OF WATER. NEVER GIVE ANYTHING BY MOUTH TO AN UNCONSCIOUS PERSON. TAKE IMMEDIATELY TO A HOSPITAL OR PHYSICIAN. NOTES TO PHYSICIAN: DO NOT ADMINISTER ACIDIC ANTIDOTES OR SODIUM BICARBONATE FOLLOWING SODIUM HYPOCHLORITE OVEREXPOSURE. AN OUNCE OF 1%' SODIUM THIOSOLFATE OR MILK OF MAGNESIA IS HELPFUL. SECTION 8: OCCUPATIONAL CONTROL VENTILATION REQUIREMENTS: LOCAL EXHAUST. PERSONAL RESPIRATORS: RECOMMENDED FOR ALL PERSONNEL WORKING IN OR ABOUT AN AREA OF POTENTIAL MIST EXPOSURE. USE ONLY NIOSH!MSHA APPROVED RESPIRATOR FOR MISTS AND CHLORINE. SKIN PROTECTION REQUIREMENTS: WEAR IMPERVIOUS PROTECTIVE CLOTHING; INCLUDING BOOTS; GLOVES; LAB COAT; APRON OR COVERALLS TO PREVENT SKIN CONTACT. PREFERRED MATERIALS: NITRILE, NEOPRENE, PVC, RUBBER EYE PROTECTION REQUIREMENTS: USB CHEMICAL SAFETY GOGGLES IMPERVIOUS TO PRODUCT. CONTACT LENSES SHOULD NOT BE WORN WHEN WORKING WITH THIS MATERIAL. MAINTAIN EYE WASH FOUNTAIN AND DRENCH FACILITIES IN IMMEDIATE WORK AREA. NOTE: ALL PROTECTIVE EQUIPMENT MUST CONFORM WITH 29 CFR 1910.13 2 . SECTION 9: HANDLING & STORAGE STORE IN A COOL, DRY VENTILATED AREA. PROTECT AGAINST PHYSICAL DAMAGE. KEEP SEPARATE FROM ACIDS AND ORGANICS. LABEL ALL PIPELINES, STORAGE VESSELS, AND OTHER OFFLOAD CONNECTIONS . . SECTION 10: REGULATORY INFORMATION DOT HAZARD CLASS: CORROSIVE MATERIAL -8 DOT PLACARD REQUIRED: CORROSIVE -UN 1791 Page 4 of5 http://fplenergy.complyplus.comlMSDS/print_ bare.asp?S=213&ShowTOC=1 &ShowHazardRatings= 1 &... 6/17/2009 SODIUM HYPOCHLORITE by K.A. STEEL CHEMICALS Page 5 of 5 DOT LABEL: CORROSIVE REPORTABLE QUANTITY: REPORTABLE QUANTITY -100 LBS.NFPA/HMIS RATINGS: HEALTH -3 FLAMMABILITY -0 REACTIVITY -0 TSCA: ALL INGREDIENTS ARE LISTED ON THE TSCA INVENTORY. SARA TITLE III: SARA 311/312 -HAZARD CLASS: ACUTE HEALTH HAZARD. REACTIVE HAZARD.SARA 313 -NOT LISTED.SARA 302 -NOT LISTED.NSF: MAXIMUM USE FOR DISINFECTION, OXIDATION, ALGICIDE IS (PER ANSI/NSF STANDARD 60)-84 MG/L THE INFORMATION CONTAINED HEREIN IS PROVIDED IN GOOD FAITH AND IS BELIEVED TO BE CORRECT AS OF THE DATE HEREOF. HOWEVER, K.A. STEEL CHEMICALS MAKES NO REPRESENTATION AS TO THE COMPREHENSIVENESS OR ACCURACY OF THE INFORMATION. IT IS EXPECTED THAT INDIVIDUALS RECEIVING INFORMATION WILL EXERCISE THEIR INDEPENDENT JUDGEMENT IN DETERMINING ITS APPROPRIATENESS FOR A PARTICULAR PURPOSE.ACCORDINGLY, K.A. STEEL CHEMICALS WILL NOT BE RESPONSIBLE FOR DAMAGES OF ANY KIND RESULTING FROM THE USE OF OR RELIANCE UPON SUCH INFORMATION. NO REPRESENTATION, OR WARRANTIES, EITHER EXPRESS OR IMPLIED, OF MERCHANTABILITY FITNESS FOR A PARTICULAR PURPOSE OR OF ANY NATURE ARE MADE HEREUNDER WITH RESPECT TO THE INFORMATION SET FORTH HEREIN OR TO THE PRODUCT TO WHICH THE INFORMATION REFERS.Copyright© 1999-2009 Dolphin Software, Inc.Comply Plus Web -Hosted FPL Energy http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=2 1 3&ShowTOC=1&ShowHazardRatings=KL &... 6/17/2009 SODWM HYPOCHLORITE by K.A. STEEL CHEMICALS DOT LABEL: CORROSIVE REPORTABLE QUANTITY: REPORTABLE QUANTITY -100 LBS. NFPA/HMIS RATINGS: H8¥TH -3 FLAMMABILITY -0 REACTIVITY -0 TSCA: ALL INGREDIENTS ARE LISTED ON THE TSCA INVENTORY. SARA TITLE I II : SARA 311/312 -HAZARD CLASS: ACUTE HEALTH HAZARD. REACTIVE HAZARD. SARA 313 SARA 302 NSF: -NOT LISTED. -NOT LISTED. MAXIMUM USE FOR DISINFECTION, OXIDATION, ALGIClDE IS (PER ANSI/NSF STANDARD 60) .. 84 MG/L THE INFORMATION CONTAINED HEREIN IS PROVIDED IN GOOD FAITH AND lS BELIEVED TO BE CORRECT AS OF THE DATE HEREOF. HOWEVER, K.A. STEEL CHEMICALS MAKES NO REPRESENTATION AS TO THE COMPREHENSIVENESS OR ACCURACY OF THE INFORMATION. IT IS EXPECTED THAT INDIVIDUALS RECEIVING INFORMATION WILL EXERCISE THEIR INDEPENDENT JUDGEMENT IN DETERMINING ITS APPROPRIATENESS FOR A PARTICULAR PURPOSE. ACCORDINGLY, K.A. STEEL CHEMICALS WILL NOT BE RESPONSIBLE FOR DAMAGES OF ANY KIND RESULTING FROM THE USE OF OR RELIANCE UPON SUCH INFORMATION. NO REPRESENTATION, OR WARRANTIES, EITHER EXPRESS OR IMPLIED, OF MERCHANTABILITY FITNESS FOR A PARTICULAR PURPOSE OR OF ANY NATURE ARE MADE HEREUNDER WITH RESPECT TO THE INFORMATION SET FORTH HEREIN OR TO THE PRODUCT TO WHICH THE INFORMATION REFERS. Copyr/ght© 1999-2009 Dolphin Software, Inc. Comply Plus Web -Hosted FPL Energy Page 5 of5 http://fplenergy.complyplus.comlMSDS/print_ bare.asp?S=213&ShowTOC= l&ShowHazardRatings=l &... 6/17/2009 SULFURIC ACID by KOCH SULFUR PRODUCTS FPL Energy Duane Arnold SULFURIC ACID KOCH SULFUR PRODUCTS FileName Language Internal ID Revision Date 000412 0405 4/23/2002 Table Of Contents 1 CHEMICAL PRODUCT & COMPANY IDENTIFICATION 2 COMPOSITION / INFORMATION ON INGREDIENTS3 HAZARDS IDENTIFICATION 4 FIRST AID MEASURES 5 FIRE FIGHTING MEASURES 6 ACCIDENTAL RELEASE MEASURES 7 HANDLING & STORAGE 8 EXPOSURE CONTROLS / PERSONAL PROTECTION 9 PHYSICAL & CHEMICAL PROPERTIES 10 STABILITY & REACTIVITY 11 TOXICOLOGICAL INFORMATION 12 ECOLOGICAL INFORMATION 13 DISPOSAL CONSIDERATIONS 14 TRANSPORT INFORMATION 15 REGULATORY INFORMATION 16 OTHER INFORMATION Hazards MSDS State NFPA HMIS (Active)Health 3 3*Flammability 0 0 Reactivity 2 2 Other -W KOCH MATERIAL SAFETY DATA SHEET 1 CHEMICAL PRODUCT & COMPANY IDENTIFICATION Page 1 of 9 TRADE NAME(S): SULFURIC ACID CAS NUMBER: 7664-93-9 MSDS NUMBER: 5371 PRODUCT CODE: ND SYNONYM(S): OIL OF VITRIOL MANUFACTURER/SUPPLIER: KOCH SULFUR PRODUCTS COMPANY P0 BOX 2256 WICHITA, KS 67201 TELEPHONE NUMBERS -24 HOUR ASSISTANCE: CHEMTREC: 800-424-9300 http://fplenergy.complyplus.comvMSDS/print-bare.asp?S=293&ShowTOC= 1 &ShowHazardRatings=1 &... 6/17/2009 SULFURIC ACID by KOCH SULFUR PRODUCTS FPL Energy Duane Arnold SULFURIC ACID FileName Language Internal 10 000412 0405 Table Of Contents 1 CHEMICAL PRODUCT & COMPANY IDENTIFICATION 2 COMPOSITION I INFORMATION ON INGREDIENTS 3 HAZARDS IDENTIFICATION 4 FIRST AID MEASURES 5 FIRE FIGHTING MEASURES 6 ACCIDENTAL RELEASE MEASURES 7 HAN DUNG & STORAGE 8 EXPOSURE CONTROLS 1 PERSONAL PROTECTION 9 PHYSICAL & CHEMICAL PROPERTIES 10 STABILITY & REACTIVITY 11 TOXICOLOGICAL INFORMATION 12 ECOLOGICAL INFORMATION 13 DISPOSAL CONSIDERATIONS 14 TRANSPORT INFORMATION 15 REGULATORY INFORMATION 16 OTHER INFORMATION Hazards NFPA HMIS Health 3 3* Flammability 0 0 Reactivity 2 2 Other -w KOCH MATERIAL SAFETY DATA SHEET 1 CHEMICAL PRODUCT & COMPANY IDENTIF!CATION TRADE NAME(S): SULFURIC AC!D CAS NUMBER: 7664-93-9 MSDS NUMBER: 5371 PRODUCT CODE: ND SYNONYM(S): OIL OF VITRIOL MANUFACTURER/SUPPLIER: KOCH SULFUR PRODUCTS COMPANY PO BOX 2256 WICHITA, KS 67201 TELEPHONE NUMBERS -24 HOUR ASSISTANCE: CHEMTREC: 800-424-9300 MSOSState I Page 1 of9 KOCH SULFUR PRODUCTS Revision Date* 4/23/2002 (Active) I http://fplenergy.complyplus.comlMSDS/print_ bare.asp?S=293&ShowTOC= 1 &ShowHazardRatings= 1 &... 6117/2009 SULFURIC ACID by KOCH SULFUR PRODUCTS REFERENCE KOCH SUBSIDIARY: KOCH SULFUR PRODUCTS COMPANY TELEPHONE NUMBERS -GENERAL ASSISTANCE: 8-5 (M-F, CST): 316-828-3019 8-5 (M-F, CST) MSDS ASSISTANCE: 316-828-8488 2 COMPOSITION / INFORMATION ON INGREDIENTS Page 2 of 9 INGREDIENT NAME CAS NUMBER CONCENTRATION* EXPOSURE LIMITS /HEALTH HAZARDS SULFURIC ACID 7664-93-9 7 -100 ?I MG/M3 6-HOUR TWA (OSHA)1 MG/M3 B-HOUR TWA (ACGIH)3 MG/M3 15-MIN STEL (ACGIH)*VALUES DO NOT REFLECT ABSOLUTE MINIMUMS AND MAXIMUMS, THESE VALUES ARE TYPICAL WHICH MAY VARY FROM TIME TO TIME.3 HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: DANGER I HEALTH HAZARDS MAY BE CORROSIVE TO THE SKIN, EYES AND RESPIRATORY TRACT ASPIRATION HAZARD IF SWALLOWED-CAN ENTER LUNGS AND CAUSE DAMAGE CANCER HAZARD SEE "TOXICOLOGICAL INFORMATION" (SECTION 11) FOR MORE INFORMATION FLAMMABILITY HAZARDS: NON-COMBUSTIBLE REACTIVITY HAZARDS: MAY REACT VIOLENTLY WITH WATER POTENTIAL HEALTH EFFECTS, SKIN: CORROSIVE. CONTACT MAY CAUSE REDDENING, ITCHING, INFLAMMATION, BURNS, BLISTERING AND POSSIBLY SEVERE TISSUE DAMAGE. REPEATED OR PROLONGED CONTACT MAY RESULT IN DRYING, REDDENING, ITCHING, PAIN, INFLAMMATION, CRACKING AND POSSIBLE SECONDARY INFECTION WITH TISSUE DAMAGE.POTENTIAL HEALTH EFFECTS, EYE: CORROSIVE. EXPOSURE MAY CAUSE SEVERE BURNS, DESTRUCTION OF EYE TISSUE AND POSSIBLE PERMANENT INJURY OR BLINDNESS. PROLONGED OR REPEATED EXPOSURE MAY CAUSE IRRITATION AND CONJUNCTIVITIS. POTENTIAL HEALTH EFFECTS, INHALATION: EXTREMELY IRRITATING AND CORROSIVE. MAY CAUSE SEVERE BURNS AND TISSUE DAMAGE TO THE RESPIRATORY TRACT. SYMPTOMS MAY INCLUDE THROAT BURNS, CONSTRICTION OF THE WINDPIPE (BRONCHOSPASMS), SEVERE PULMONARY EDEMA AND DEATH, DEPENDING ON THE CONCENTRATION AND DURATION OF EXPOSURE.OVEREXPOSURE TO THIS MATERIAL MAY CAUSE SYSTEMIC DAMAGE INCLUDING TARGET ORGAN EFFECTS LISTED UNDER "TOXICOLOGICAL INFORMATION" (SECTION 11).OTHER SPECIFIC SYMPTOMS OF EXPOSURE ARE LISTED UNDER "TOXICOLOGICAL http://fplenergy.complyplus.comIMSDS/printbare.asp?S=293&ShowTOC=1&ShowHazardRatings= l&... 6/17/2009 SULFURIC ACID by KOCH SULFUR PRODUCTS REFERENCE KOCH SUBSIDIARY: KOCH SULFUR PRODUCTS COMPANY TELEPHONE NUMBERS -GENERAL ASSISTANCE: 8-5 (M-F, CST): 8-5 (M-F, CST) MSDS ASSISTANCE: 316-828-8488 2 COMPOSITION I INFORMATION ON IUGREOIENTS IUGREDIENT NAME CAS NUMBER CONCENTRATION* SULFURIC ACID 7664-93-9 7 -100 % EXPOSURE LIMITS / HEALTH HAZARDS 1 MG/M3 a-HOUR TWA (OSHA) 1 MG/M3 8-HOUR TWA (ACGIH) 3 MG/M3 IS-MIN STEL (ACGIH) *VALUES DO NOT REFLECT ABSOLUTE MINIMUMS AND MAXIMUMS: THESE VALUES ARE TYPICAL WHICH MAY VARY FROM TIME TO TIME. 3 HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: DANGER! HEALTH HAZARDS MAY BE CORROSIVE TO THE SKIN, EYES AND RESPIRATORY TRACT ASPIRATION HAZARD IF SWALLOWED-CAN ENTER LUNGS AND CAUSE DAMAGE CANCER HAZARD SEE "TOXICOLOGICAL INFORMATION" (SECTION 11) FOR MORE INFORMATION FLAMMABILITY HAZARDS: NON-COMBUSTIBLE REACTIVITY HAZARDS: MAY REACT VIOLENTLY WITH WATER POTENTIAL HEALTH EFFECTS, SKIN: CORROSIVE. CONTACT MAY CAUSE REDDENING, ITCHING, INFLAMMATION, BURNS, BLISTERING AND POSSIBLY SEVERE TISSUE DAMAGE. REPEATED OR PROLONGED CONTACT MAY RESULT IN DRYING, REDDENING, ITCHING, PAIN, INFLAMMATION, CRACKING AND POSSIBLE SECONDARY INFECTION WITH TISSUE DAMAGE. POTENTIAL HEALTH EFFECTS, EYE: CORROSIVE. EXPOSURE MAY CAUSE SEVERE BURNS, DESTRUCTION OF EYE TISSUE AND POSSIBLE INJURY OR BLINDNESS. PROLONGED OR REPEATED EXPOSURE MAY CAUSE IRRITATION AND CONJUNCTIVITIS. POTENTIAL HEALTH EFFECTS, INHALATION: EXTREMELY IRRITATING AND CORROSIVE. MAY CAUSE SEVERE BURNS AND TISSUE DAMAGE TO THE RESPIRATORY TRACT. SYMPTOMS MAY INCLUDE THROAT BURNS, CONSTRICTION OF THE WINDPIPE (BRONCHOSPASMS), SEVERE PULMONARY EDEMA AND DEATH, DEPENDING ON THE CONCENTRATION AND DURATION OF EXPOSURE. OVEREXPOSURE TO THIS MATERIAL MAY CAUSE SYSTEMIC DAMAGE INCLUDING TARGET ORGAN EFFECTS LISTED UNDER "TOXICOLOGICAL INFORMATION" (SECTION 11). OTHER SPECIFIC SYMPTOMS OF EXPOSURE ARE! LISTED UNDER "TOXICOLOGICAL Page 2 of9 http;llfplenergy.complyplus.comIMSDS/print_bare,asp?S=293&ShowTOC= 1 &ShowHazardRatings== 1&... 6/17/2009 SULFURIC ACID by KOCH SULFUR PRODUCTS Page 3 of 9 INFORMATION" (SECTION 11).POTENTIAL HEALTH EFFECTS, INGESTION: CORROSIVE. MAY CAUSE PAINFUL IRRITATION AND BURNING OF THE MOUTH AND THROAT, PAINFUL SWALLOWING, LABORED BREATHING, BURNS OR PERFORATION OF THE3 GASTROINTESTINAL TRACT LEADING TO ULCERATION AND SECONDARY INFECTION. CORROSIVE DAMAGE TO THE STOMACH AND ESOPHAGUS MAY BE DELAYED. ASPIRATION INTO LUNGS MAY CAUSE CHEMICAL PNEUMONIA AND LUNG DAMAGE.OVEREXPOSURE TO THIS MATERIAL MAY CAUSE SYSTEMIC DAMAGE INCLUDING TARGET ORGAN EFFECTS LISTED UNDER "TOXICOLOGICAL INFORMATION" (SECTION 11).OTHER SPECIFIC SYMPTOMS OF EXPOSURE ARE LISTED UNDER "TOXICOLOGICAL INFORMATION" (SECTION 11).4 FIRST AID MEASURES SKIN: IMMEDIATELY FLUSH SKIN WITH PLENTY OF WATER, FOR AT LEAST 15 MINUTES, WHILEREMOVING CONTAMINATED CLOTHING AND SHOES. GET IMMEDIATE MEDICAL ATTENTION. PLACE CONTAMINATED CLOTHING IN CLOSED CONTAINER FOR STORAGE UNTIL LAUNDERED OR DISCARDED. IF CLOTHING IS TO BE LAUNDERED, INFORM PERSON PERFORMING OPERATION OF CONTAMINANT'S HAZARDOUS PROPERTIES. DISCARD CONTAMINATED LEATHER GOODS.EYE: FLUSH IMMEDIATELY WITH LARGE AMOUNTS OF WATER FOR AT LEAST 15 MINUTES. EYELIDS SHOULD BE HELD AWAY FROM THE EYEBALL TO ENSURE THOROUGH RINSING. GET IMMEDIATE MEDICAL ATTENTION. INHALATION:REMOVE TO FRESH AIR. IF NOT BREATHING, INSTITUTE RESCUE BREATHING. IF BREATHING IS DIFFICULT, ENSURE AIRWAY IS CLEAR AND GIVE OXYGEN.KEEP AFFECTED PERSON WARM AND AT REST. GET IMMEDIATE MEDICAL ATTENTION. INGESTION: IF VICTIM IS CONSCIOUS AND ALERT, GIVE 1-3 GLASSES OF WATER TO DILUTE STOMACH CONTENTS. RINSE MOUTH OUT WITH WATER. DO NOT INDUCE VOMITING UNLESS DIRECTED BY MEDICAL PERSONNEL. NEVER GIVE ANYTHING BY MOUTH TO AN UNCONSCIOUS PERSON.IF SPONTANEOUS VOMITING OCCURS KEEP HEAD BELOW HIPS TO PREVENT ASPIRATION AND MONITOR FOR BREATHING DIFFICULTY. KEEP AFFECTED PERSON WARM AND AT REST. GET IMMEDIATE MEDICAL ATTENTION. 5 FIRE FIGHTING MEASURES HAZARDOUS COMBUSTION PRODUCTS: DECOMPOSES TO FORM SULFUR DIOXIDE AND SULFUR TRIOXIDE.EXTINGUISHING MEDIA: USE CARBON DIOXIDE OR DRY CHEMICAL TO EXTINGUISH FIRE.BASIC FIRE FIGHTING PROCEDURES: DO0 NOT ADD WATER TO ACID. WATER APPLIED DIRECTLY RESULTS IN EVOLUTION http ://fplenergy.complyplus.com[MSDS/print-bare.asp?S=293&ShowTOC~= I&Showl-azardRatings=l &... 6/17/2009 SULFURIC ACID by KOCH SULFUR PRODUCTS INFORMATION" (SECTION 11) . POTENTIAL HEALTH EFFECTS, INGESTION: CORROSIVE. MAY CAUSE PAINFUL IRRITATION AND BURNING OF THE MOUTH AND THROAT, PAINFUL SWALLOWING, LABORED BREATHING, BURNS OR PERFORATION OF THE GASTROINTESTINAL TRACT LEADING TO ULCERATION AND SECONDARY INFECTION. CORROSIVE DAMAGE TO THE STOMACH AND ESOPHAGUS MAY BE DELAYED. ASPIRATION INTO LUNGS MAY CAUSE CHEMICAL PNEUMONIA AND LUNG DAMAGE. OVEREXPOSURE TO THIS MATERIAL MAY CAUSE SYSTEMIC DAMAGE INCLUDING TARGET ORGAN EFFECTS LISTED UNDER "TOXICOLOGICAL INFORMATION" (SECTION 11}. OTHER SPECIFIC SYMPTOMS OF EXPOSURE ARE LISTED UNDER "TOXICOLOGICAL INFORMATION" (SECTION ll) . 4 FIRST AID MEASURES SKIN: IMMEDIATELY FLUSH SKIN WITH PLENTY OF WATER, FOR AT LEAST 15 MINUTES, WHILE REMOVING CONTAMINATED CLOTHING AND SHOES. GET IMMEDIATE MEDICAL ATTENTION. PLACE CONTAMINATED CLOTHING IN CLOSED CONTAINER FOR STORAGE UNTIL LAUNDERED OR DISCARDED. IF CLOTHING IS TO BE LAUNDERED, INFORM PERSON PERFORMING OPERATION OF CONTAMINANT'S HAZARDOUS PROPERTIES. DISCARD CONTAMINATED LEATHER GOODS. EYE: FLUSH IMMEDIATELY WITH LARGE AMOUNTS OF WATER FOR AT LEAST 15 MINUTES. EYELIDS SHOULD BE HELD AWAY FROM THE EYEBALL TO ENSURE THOROUGH RINSING. GET IMMEDIATE MEDICAL ATTENTION. INHALATION: REMOVE TO FRESH AIR. IF NOT BREATHING, INSTITUTE RESCUE BREATHING. IF BREATHING IS DIFFICULT, ENSURE AIRWAY IS CLEAR AND GIVE OXYGEN. KEEP AFFECTED PERSON WARM AND AT REST. GET IMMEDIATE MEDICAL ATTENTION. INGESTION: IF VICTIM IS CONSCIOUS AND ALERT, GIVE 1-3 GLASSES OF WATER TO DILUTE STOMACH CONTENTS. RINSE MOUTH OUT WITH WATER. DO NOT INDUCE VOMITING UNLESS DIRECTED BY MEDICAL PERSONNEL. NEVER GIVE ANYTHING BY MOUTH TO AN UNCONSCIOUS PERSON. IF SPONTANEOUS VOMITING OCCURS KEEP HEAD BELOW HIPS TO PREVENT ASPIRATION AND MONITOR FOR BREATHING DIFFICULTY. KEEP AFFECTED PERSON WARM AND AT REST. GBT IMMEDIATE MEDICAL ATTENTION. 5 FIRE FIGHTING MEASURES HAZARDOUS COMBUSTION PRODUCTS: DECOMPOSES TO FORM SULFUR DIOXIDE AND SULFUR TRIOXIDE. EXTINGUISHING MEDIA: USE CARBON DIOXIDE OR DRY CHEMICAL TO EXTINGUISH FIRE. BASIC FIRE FIGHTING PROCEDURES: DO NOT ADD WATER TO ACID. WATER APPLIED DIRECTLY RESULTS IN EVOLUTION Page 3 of9 http://fplenergy.complyplus.comlMSDS/print_ bare.asp?S=293&ShowTOC= 1 &ShowHazardRatings= 1 &... 6117/2009 SULFURIC ACID by KOCH SULFUR PRODUCTS Page 4 of 9 OF HEAT AND SPLATTERING OF ACID. ACID CAN REACT WITH METALS TO LIBERATEFLAMMABLE HYDROGEN GAS, ESPECIALLY WHEN DILUTED WITH WATER. EVACUATE AREA AND FIGHT FIRE FROM A SAFE DISTANCE.USE WATER SPRAY TO COOL ADJACENT STRUCTURES AND TO PROTECT PERSONNEL. DO NOT GET WATER INSIDE SULFURIC ACID CONTAINERS. SHUT OFF SOURCE OF FLOW IF POSSIBLE. STAY AWAY FROM STORAGE TANK ENDS. WITHDRAW IMMEDIATELY IN CASE OF RISING SOUND FROM VENTING SAFETY DEVICE OR ANY DISCOLORATION OF STORAGE TANK DUE TO FIRE.FIREFIGHTERS MUST WEAR MSHA/NIOSH APPROVED POSITIVE PRESSURE BREATHING APPARATUS (SCBA) WITH FULL FACE MASK AND FULL PROTECTIVE EQUIPMENT. UNUSUAL FIRE & EXPLOSION HAZARDS: MATERIAL WILL NOT BURN.REACTS WITH MOST METALS TO PRODUCE HYDROGEN GAS WHICH CAN FORM AN EXPLOSIVE MIXTURE WITH AIR.FLASH POINT: ND AUTOIGNITION TEMPERATURE: ND FLAMMABILITY LIMITS IN AIR, LOWER, % BY VOLUME: ND FLAMMABILITY LIMITS IN AIR, UPPER, % BY VOLUME: ND 6 ACCIDENTAL RELEASE MEASURES EMERGENCY ACTION: KEEP UNNECESSARY PEOPLE AWAY; ISOLATE HAZARD AREA AND DENY ENTRY. STAY UPWIND. ISOLATE FOR 1/2 MILE IN ALL DIRECTIONS IF TANK, RAIL CAR OR TANK TRUCK IS INVOLVED IN FIRE. EVACUATE AREA ENDANGERED BY RELEASE AS REQUIRED. (SEE EXPOSURE CONTROL/PERSONAL PROTECTION -SECTION 8).ENVIRONMENTAL PRECAUTIONS: IF PRODUCT IS RELEASED TO THE ENVIRONMENT, TAKE IMMEDIATE STEPS TO STOP AND CONTAIN RELEASE. CAUTION SHOULD BE EXERCISED REGARDING PERSONNEL SAFETY AND EXPOSURE TO THE RELEASED PRODUCT. NOTIFY LOCAL AUTHORITIES AND THE NATIONAL RESPONSE CENTER, IF REQUIRED.SPILL OR LEAK PROCEDURE: KEEP UNNECESSARY PEOPLE AWAY. ISOLATE AREA FOR AT LEAST 50-100 METERS (160-330 FEET) TO PRESERVE PUBLIC SAFETY. FOR LARGE SPILLS, CONSIDER INITIAL EVACUATION FOR AT LEAST 300 METERS (1000 FEET).LARGE SPILLS MAY BE NEUTRALIZED WITH DILUTE ALKALINE SOLUTIONS OF SODA ASH OR LIME. STOP LEAK WHEN SAFE TO DO SO.SEE EXPOSURE CONTROLS/PERSONAL PROTECTION (SECTION 8).7 HANDLING & STORAGE HANDLING: THIS MATERIAL SHOULD BE STORED AND SHIPPED IN PLASTIC OR PLASTIC LINED CONTAINERS. DO NOT USE WITH MATERIALS OR EQUIPMENT SENSITIVE TO ACIDIC SOLUTIONS. http://fplenergy.complyplus.com/M SDS/print-bare.asp?S=293&ShowTOC=I &ShowHazardRatings=l &... 6/17/2009 SULFURIC ACID by KOCH SULFUR PRODUCTS OF HEAT AND SPLATTERING OF ACID. ACID CAN REACT WITH METALS TO LIBERATE FLAMMABLE HWROGEN GAS, ESPECIALLY WHEN DILUTED WITH WATER. EVACUATE AREA AND FIGHT FIRE FROM A SAFE DISTANCE. USE WATER SPRAY TO COOL ADJACENT STRUCTURES AND TO PROTECT PERSONNEL. DO NOT GET WATER INSIDE SULFURIC ACID CONTAINERS. SHUT OFF SOURCE OF FLOW IF POSSIBLE. STAY AWAY FROM STORAGE TANK ENDS. WITHDRAW IMMEDIATELY IN CASE OF RISING SOUND FROM VENTING SAFETY DEVICE OR ANY DISCOLORATION OF STORAGE TANK DUE TO FIRE. FIREFIGHTERS MUST WEAR MSHA/NIOSH APPROVED POSITIVE PRESSURE BREATHING APPARATUS (SCaA) WITH FULL FACE MASK AND FULL PROTECTIVE EQUIPMENT. UNUSUAL FIRE & EXPLOSION HAZARDS: MATERIAL WILL NOT BURN. REACTS WITH MOST METALS TO PRODUCE HYDROGEN GAS WHICH CAN FORM AN EXPLOSIVE MIXTURE WITH AIR. FLASH POINT: ND AUTO IGNITION TEMPERATURE: NO FLAMMABILITY LIMITS IN AIR, LOWER, % BY VOLUME: ND FLAMMABILITY LIMITS IN AIR, UPPER, % BY VOLUME: NO 6 ACCIDENTAL RELEASE MEASURES EMERGENCY ACTION: KEEP UNNECESSARy PEOPLE AWAY; ISOLATE HAZARD AREA AND DENY ENTRY. STAY UPWIND. ISOLATE FOR 1/2 MILE IN ALL DIRECTIONS IF TANK, RAIL CAR OR TANK TRUCK IS INVOLVED IN FIRE. EVACUATE AREA ENDANGERED BY RELEASE AS REQUIRED. (SEE EXPOSURE CONTROL/PERSONAL PROTECTION -SECTION 8) . ENVIRONMENTAL PRECAUTIONS: IF PRODUCT IS RELEASED TO THE ENVIRONMENT, TAKE IMMEDIATE STEPS TO STOP AND CONTAIN RELEASE. CAUTION SHOULD BE EXERCISED REGARDING PERSONNEL SAFETY AND EXPOSURE TO THE RELEASED PRODUCT. NOTIFY LOCAL AUTHORITIES AND THE NATIONAL RESPONSE CENTER, IF REQUIRED. SPILL OR LEAK PROCEDURE: KEEP UNNECESSARY PEOPLE AWAY. ISOLATE AREA FOR AT LEAST 50-100 METERS (160-330 FEET) TO PRESERVE PUBLIC SAFETY. FOR LARGE SPILLS, CONSIDER INITIAL EVACUATION FOR AT LEAST 300 METERS (1000 FEET). LARGE SPILLS MAY BE NEUTRALIZED WITH DILUTE ALKALINB* SOLUTIONS OF SODA ASH OR LIME. STOP LEAK WHEN SAFE TO DO SO. SEE EXPOSURE CONTROLS/PERSONAL PROTECTION (SECTION 8) . 7 HANDLING & STORAGE HANDLING: THIS MATERIAL SHOULD BE STORED AND SHIPPED IN PLASTIC OR PLASTIC LINED CONTAINERS. DO NOT USE WITH MATERIALS OR EQUIPMENT SENSITIVE TO ACIDIC SOLUTIONS. Page 4 of9 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=293&ShowTOC= 1 &ShowHazardRatings=l &... 6/17/2009 SULFURIC ACID by KOCH SULFUR PRODUCTS Page 5 of' 9 DO NOT EAT, DRINK OR SMOKE IN AREAS OF USE OR STORAGE.STORAGE: AVOID CONTACT WITH COMBUSTIBLE MATERIALS, WATER, METALS AND ALKALIS. STORE IN A VENTED CONTAINER. SULFURIC ACID REACTS WITH MOST METALS TO PRODUCE HYDROGEN GAS WHICH CAN FORM AN EXPLOSIVE MIXTURE WITH AIR.EMPTY CONTAINERS MAY CONTAIN PRODUCT RESIDUE. DO NOT REUSE WITHOUT ADEQUATE PRECAUTIONS. 8 EXPOSURE CONTROLS / PERSONAL PROTECTION ENGINEERING CONTROLS: VENTILATION AND OTHER FORMS OF ENGINEERING CONTROLS ARE THE PREFERRED MEANS FOR CONTROLLING EXPOSURES. EYE PROTECTION: PERSONAL PROTECTION EQUIPMENT (PPE): WEAR CHEMICAL SAFETY GOGGLES AND FACE SHIELD. HAVE EYE WASHING FACILITIESREADILY AVAILABLE WHERE EYE CONTACT CAN OCCUR.SKIN PROTECTION: PERSONAL PROTECTION EQUIPMENT (PPE)., AVOID SKIN CONTACT WITH THIS MATERIAL. USE APPROPRIATE CHEMICAL PROTECTIVE GLOVES WHEN HANDLING.ADDITIONAL PROTECTION MAY BE NECESSARY TO PREVENT SKIN CONTACT INCLUDING USE OF APRON, GAUNTLETS, BOOTS, IMPERVIOUS PROTECTIVE SUIT AND FACE SHIELD OR SPLASH GOGGLES. PROVIDE SAFETY SHOWERS AT ANY LOCATION WHERE SKIN CONTACT CAN OCCUR.USE GOOD PERSDNAL HYGIENE.RESPIRATORY PROTECTION: PERSONAL PROTECTION EQUIPMENT (PPE): A NIOSH/NSHA APPROVED AIR PURIFYING RESPIRATOR WITH AN APPROPRIATE ACID GAS CARTRIDGE OR CANISTER MAY BE APPROPRIATE UNDER CERTAIN CIRCUMSTANCES WHERE AIRBORNE CONCENTRATIONS ARE EXPECTED TO EXCEED EXPOSURE LIMITS. PROTECTION PROVIDED BY AIR PURIFYING RESPIRATORS IS LIMITED. USE A POSITIVE PRESSURE AIR SUPPLIED RESPIRATOR IF THERE IS ANY POTENTIAL FOR AN UNCONTROLLED RELEASE, EXPOSURE LEVELS ARE NDT KNOWN, OR ANY OTHER CIRCUMSTANCES WHERE AIR PURIFYING RESPIRATORS MAY NOT PROVIDE ADEQUATE PROTECTION. 9 PHYSICAL &: CHEMICAL PROPERTIES ODOR AND APPEARANCE: COLORLESS TO CLOUDY OILY LOOKING LIQUID WITH A PUNGENT ODORBOILING POINT: 7-85t -215-440 DEG. F, 93% -541 DEG. F, 96% -586 DEG. F, 99k -625 DEC. F SPECIFIC GRAVITY: 7-85t -1.04-1.79, 93% -1.84, 96% -1.84, 999% -1.84 MELTING POINT: ND http://fpl.energy.comnplyplus.com/MSDS/Print-bare.asp?S=293&ShowTOC=I1&ShowI-azardRatings~'l&... 6/17/2009 SULFURIC ACID by KOCH SULFUR PRODUCTS DO NOT EAT, DRINK OR SMOKE IN AREAS OF USE OR STORAGE. STORAGE: AVOID CONTACT WITH COMBUSTIBLE MATERIALS, WATER, METALS AND ALKALIS. STORE IN A VENTED CONTAINER. SULFURIC ACID REACTS WITH MOST METALS TO PRODUCE HYDROGEN GAS WHICH CAN FORM AN EXPLOSIVE MIXTURE WI'l'H AIR. EMPTY CONTAINERS MAY CONTAIN PRODUCT RESIDUE. DO NOT REUSE WITHOUT ADEQUATE PRECAUTIONS. B EXPOSURE CONTROLS I PERSONAL PROTECTION ENGINEERING CONTROLS: VENTILATION AND OTHER FORMS OF ENGINEERING CONTROLS ARE THE PREFERRED MEANS FOR CONTROLLING EXPOSURES. EYE PROTECTION: PERSONAL PROTECTION EQUIPMENT (PPE): WEAR CHEMICAL SAFETY GOGGLES AND FACE SHIELD. HAVE EYE WASHING FACILITIES READILY AVAILABLE WHERE EYE CONTACT CAN OCCUR. SKIN PROTECTION: PERSONAL PROTECTION EQUIPMENT (PPE): AVOID SKIN CONTACT WITH THIS MATERIAL. USE APPROPRIATE CHEMICAL PROTECTIVE GLOVES WHEN HANDLING. ADDITIONAL PROTECTION MAY BE NECESSARY TO PREVENT SKIN CONTACT INCLUDING USE OF APRON, GAUNTLETS, BOOTS, IMPERVIOUS PROTECTIVE SUIT AND FACE SHIELD OR SPLASH GOGGLES. PROVIDE SAFETY SHOWERS AT ANY LOCATION WHERE SKIN CONTACT CAN OCCUR. USE GOOD PERSONAL HYGIENE. RESPIRATORY PROTECTION: PERSONAL PROTECTION EQUIPMENT (PPE): A NIOSH/MSHA APPROVED AIR PURIFYING RESPIRATOR WITH AN APPROPRIATE ACID GAS CARTRIDGE OR CANISTER MAY BE APPROPRIATE UNDER CERTAIN CIRCUMSTANCES WHERE AIRBORNE CONCENTRATIONS ARE EXPECTED TO EXCEED EXPOSURE LIMITS. PROTECTION PROVIDED BY AIR PURIFYING RESPIRATORS IS LIMITED. USE A POSITIVE PRESSURE AIR SUPPLIED RESPIRATOR IF THERE IS ANY POTENTIAL FOR AN UNCONTROLLED RELEASE. EXPOSURE LEVELS ARE NOT KNOWN, OR ANY OTHER CIRCUMSTANCES WHERE AIR PURIFYING RESPIRATORS MAY NOT PROVIDE ADEQUATE PROTECTION. 9 PHYSICAL & CHEMICAL PROPERTIES ODOR AND APPEARANCE: COLORLESS TO CLOUDY OILY LOOKING LIQUID WITH A PUNGENT ODOR BOILING POINT: 7-85% -215-440 DEG. F, 93% -541 DEG. F, 96% -586 DEG. F, 99% -625 DEG. F SPECIFIC GRAVITY: 7-85% -1.04-1.79, 93% -1.84, 96% -1.84, 99% -1.84 MELTING POINT: NO Page 5 of9 http://fplenergy.complyplus.com/MSDS/print _ bare.asp?S=293&ShowTOC=: 1 &ShowHazardRatings= 1 &... 6/17/2009 SULFURIC ACID by KOCH SULFUR PRODUCTS Page 6 of 9 PERCENT VOLATILE: ND VAPOR PRESSURE: AT 100 DEG. F (7-85% <2, 93%-<l, 96%-<1, 99%-<1)VAPOR DENSITY: ND BULK DENSITY: ND SOLUBILITY IN WATER: 100 %OCTANOL/WATER PARTN: ND VOLATILE ORGANIC: ND POUR POINT: ND pH VALUE: < 1 FREEZING POINT: 7-85% (-40) DEG. F, 85% -(-40) DEG. F, 93% -(-29) DEG. F, 96% -10 DEG. F, 99% -45 DEG. F VISCOSITY: ND EVAPORATION RATE: ND MOLECULAR FORMULA: H2S04 MOLECULAR WEIGHT: 98.07 CHEMICAL FAMILY: MINERAL ACID ODOR THRESHOLD: ND 10 STABILITY & REACTIVITY STABILITY/INCOMPATIBILITY: AVOID CONTACT WITH WATER.INCOMPATIBLE WITH COMBUSTIBLE MATERIALS, WATER, METALS AND ALKALIS. SEE PRECAUTIONS UNDER HANDLING & STORAGE (SECTION 7).HAZARDOUS REACTIONS/DECOMPOSITION PRODUCTS: DECOMPOSES TO FORM SULFUR DIOXIDE AND SULFUR TRIOXIDE.11 TOXICOLOGICAL INFORMATION ROUTES OF EXPOSURE: INHALATION, INGESTION, SKIN AND EYE CONTACT. LD50: LDS0: SULFURIC ACID, RAT, ORAL, 2140 MG/KG.TOXICOLOGICAL DATA: ACUTE OR CHRONIC OVEREXPOSURE TO THIS MATERIAL OR ITS COMPONENTS MAY CAUSE SYSTEMIC TOXICITY, INCLUDING ADVERSE EFFECTS TO THE FOLLOWING: KIDNEY, LIVER, htt)://ftplenergy.complyplus.com/MSDS/print-bare.asp?S=293&ShowTOC= &ShowHazardRatings=1 &... 6/17/2009 SULFURIC ACID by KOCH SULFUR PRODUCTS PERCENT VOLATILE: NO VAPOR PRESSURE: AT 100 DEG. F (7-B5% - 93%-<1, 96%-<1, 99%-<1) VAPOR DENS ITY: NO BULK DENSITY: NO SOLUBILITY IN WATER: 100 % OCTANOL/wATER PARTN: NO VOLATILE ORGANIC: NO POUR POINT: NO pH VALUE: < 1 FREEZING POINT: 7-85% (-40) DEG. F, BSt -(-40) DEG. F, 93% -(-29) DEG. F, 96% -10 DEG. P, 99% -45 DEG. F VISCOSITY, NO EVAPORATION RATE: NO MOLECULAR FORMULA: H2S04 MOLECULAR WEIGHT: 98.07 CHEMICAL FAMILY: MINERAL ACID ODOR THRESHOLD: NO 10 STABILITY & REACTIVITY STABILITY/INCOMPATIBILITY: AVOID CONTACT IHTH WATER. INCOMPATIBLE WITH COMBUSTIBLE MATERIALS, WATER, METALS AND ALKALIS. SEE PRECAUTIONS UNDER HANDLING & STORAGE (SECTION 7). HAZARDOUS REACTIONS/DECOMPOSITION PRODUCTS: DECOMPOSES TO FORM SULFUR DIOXIDE AND SULFUR TRIOXIDE. 11 TOXICOLOGICAL INFORMATION ROUTES OF EXPOSURE: INHALATION, INGESTION, SKIN AND EYE CONTACT. LD50: LOSO: SULFURIC ACID, RAT, ORAL, 2140 Ma/KG. TOXICOLOGICAL DATA: ACUTE OR CHRONIC OVEREXPOSURE TO THIS MATERIAL OR ITS COMPONENTS MAY CAUSE SYSTEMIC TOXICITY, INCLUDING ADVERSE EFFECTS TO THE FOLLOWING: KIDNEY, LIVER, Page 6of9 htto:llfplenergy .complyplus.comIMSDS/print_ bare.asp?S=293&ShowTOC== 1 &ShowHazardRatings= 1 &... 6/1712009 SULFURIC ACID by KOCH SULFUR PRODUCTS Page 7 of 9 TEETH, RESPIRATORY AND CARDIOVASCULAR SYSTEMS.EXPOSURE TO COMPONENTS OF THIS MATERIAL MAY CAUSE THE FOLLOWING SPECIFIC SYMPTOMS, DEPENDING ON THE CONCENTRATION AND DURATION OF EXPOSURE: ATTACKS ENAMEL OF TEETH, VOMITING, CLAMMY SKIN, WEAK AND RAPID PULSE. OTHER SYMPTOMS OF EXPOSURE MAY INCLUDE THE FOLLOWING: SHALLOW RESPIRATION, CHRONIC BRONCHITIS, LUNG FUNCTION CHANGES AND SCANTY URINE.CARCINOGENICITY: IARC HAS DETERMINED THAT THERE IS SUFFICIENT EVIDENCE FOR THE CARCINOGENICITY OF OCCUPATIONAL EXPOSURE TO STRONG INORGANIC ACID MISTS CONTAINING SULFURIC ACID IN HUMANS (IARC CLASS 1).PRE-EXISTING CONDITIONS AGGRAVATED BY EXPOSURE;PRE-EXISTING MEDICAL CONDITIONS WHICH MAY BE AGGRAVATED BY EXPOSURE INCLUDE DISORDERS OF THE SKIN AND RESPIRATORY SYSTEM.12 ECOLOGICAL INFORMATION ECOTOXICOLOGICAL INFORMATION: ND 13 DISPOSAL CONSIDERATIONS WASTE DISPOSAL: THIS PRODUCT AS SUPPLIED, WHEN DISCARDED OR DISPOSED OF, IS A HAZARDOUS WASTE ACCORDING TO FEDERAL REGULATIONS (40 CFR 261) DUE TO ITS CORROSIVITY AND REACTIVITY. UNDER THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA), IT IS THE RESPONSIBILITY OF THE USER OF THE PRODUCT TO DETERMINE, AT THE TIME OF DISPOSAL, WHETHER THE MATERIAL IS A HAZARDOUS WASTE SUBJECT TO RCRA.THE TRANSPORTATION, STORAGE, TREATMENT AND DISPOSAL OF RCRA WASTE MATERIAL MUST BE CONDUCTED IN COMPLIANCE WITH 40 CFR 262, 263, 264, 268 AND 270. DISPOSAL CAN OCCUR ONLY IN PROPERLY PERMITTED FACILITIES. CHECK STATE AND LOCAL REGULATIONS FOR ANY ADDITIONAL REQUIREMENTS AS THESE MAY BE MORE RESTRICTIVE THAN FEDERALLAWS AND REGULATIONS. CHEMICAL ADDITIONS, PROCESSING OR OTHERWISE ALTERING THIS MATERIAL MAY MAKE THE WASTE MANAGEMENT INFORMATION PRESENTED IN THIS MSDS INCOMPLETE, INACCURATE OR OTHERWISE INAPPROPRIATE. DISPOSAL OF THIS MATERIAL MUST BE CONDUCTED IN COMPLIANCE WITH ALL FEDERAL, STATE AND LOCAL REGULATIONS. 14 TRANSPORT INFORMATION BILL OF LADING -BULK (U. S. DOT): RQ, SULFURIC ACID, 8, UN1830, PG II (USE WITH MORE THAN 51% ACID)RQ, SULFURIC ACID, 8, UN2796, PG II (USE WITH NOT MORE THAN 51% ACID)BILL OF LADING -NON-BULK (U. S. DOT): RQ, SULFURIC ACID, 8, UN1830, PG II (USE WITH MORE THAN 51% ACID)RQ, SULFURIC ACID, 8, UN2796, PG II (USE WITH NOT MORE THAN 51% ACID)U. S. DEPARTMENT OF TRANSPORTATION (DOT) REQUIREMENTS: GENERAL TRANSPORTATION INFORMATION FOR BULK SHIPMENTS: PROPER SHIPPING NAME: SULFURIC ACID HAZARD CLASS: 8 httn://fplenergy.complyplus.com/MSDS/print-bare.asp?S=293&ShowTOC= 1 &ShowHazardRatings= I &... 6/17/2009 SULFURIC ACID by KOCH SULFUR PRODUCTS TEETH, RESPIRATORY AND CARDIOVASCULAR SYSTEMS. EXPOSURE TO COMPONENTS OF THIS MATERIAL MAY CAUSE THE FOLLOWING SPECIFIC SYMPTOMS, DEPENDING ON THE CONCENTRATION AND DURATION OF EXpOSURE: ATTACKS BNAMEL OF TEETH, VOMITING, CLAMMY SKIN, WEAK AND RAPID PULSE. OTHER SYMPTOMS OF EXPOSURE MAY INCLUDE THE FOLLOWING: SHALLOW RESPIRATION, CHRONIC BRONCHITIS, LUNG FUNCTION CHANGES AND SCANTY URINE. CARCINOGENICITY: IARC HAS DETERMINED THAT THERE IS SUFFICIENT EVIDENCE FOR THE CARCINOGENICITY OF OCCUPATIONAL EXPOSURE TO STRONG INORGANIC ACID MISTS CONTAINING SULFURIC ACID IN HUMANS (IARC CLASS 1). PRE-EXISTING CONDITIONS AGGRAVATED BY EXPOSURE; PRE-EXISTING MEDICAL CONDITIONS WHICH MAY BE AGGRAVATED BY EXPOSURE INCLUDE DISORDERS OF THE SKIN AND RESPIRATORy SYSTEM. 12 ECOLOGICAL INFORMATION ECOTOXICOLOGICAL INFORMATION: ND 13 DISPOSAL CONSIDERATIONS WASTE DISPOSAL: THIS PRODUCT AS SUPPLIED, WHEN DISCARDED OR DISPOSED OF, IS A HAZARDOUS WASTE ACCORDING TO FEDERAL REGULATIONS (40 CFR 261) DUE TO ITS CORROSIVITY AND REACTIVITY. UNDER THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA), IT IS THE RESPONSIBILITY OF THE USER OF THE PRODUCT TO DETERMINE, AT THE TIME OF DISPOSAL, WHETHER THE MATERIAL IS A HAZARDOUS WASTE SUBJECT TO RCRA. THE TRANSPORTATION, STORAGE, TREATMENT AND DISPOSAL OF RCRA WASTE MATERIAL MUST BE CONDUCTED IN COMPLIANCE WITH 40 CFR 262, 263, 264, 268 AND 270. DISPOSAL CAN OCCUR ONLY IN PROPERLY PERMITTED FACILITIES. CHECK STATE AND LOCAL REGULATIONS FOR ANY ADDITIONAL REQUIREMENTS AS THESE MAY BE MORE RESTRICTIVE THAN FEDERAL LAWS AND REGULATIONS. CHEMICAL ADDITIONS, PROCESSING OR OTHERWISE ALTERING THIS MATERIAL MAY MAKE THE WASTE MANAGEMENT INFORMATION PRESENTED IN THIS MSDS INCOMPLETE, INACCURATE OR OTHERWISE INAPPROPRIATE. DISPOSAL OF THIS MATERIAL MUST BE CONDUCTED IN COMPLIANCE WITH ALL FEDERAL, STATE AND LOCAL REGULATIONS. 14 TRANSPORT INFORMATION BILL OF LADING -BULK (U. S. DOT): RQ, SULFURIC ACID, 8, UN1830, Fa II (USE WITH MORE THAN 51% ACID) RQ, SULFURIC ACID, 8, UN2796, PG II (USE WITH NOT MORE THAN 51% ACID) BILL OF LADING -NON-BULK (U. s. DOT): RQ, SULFURIC ACID, 8, UN1830, PG II (USE WITH MORE THAN 51% ACID) RQ, SULFURIC ACID, B, UN2796, PG II (USE WITH NOT MORE THAN 51% ACID) U. S. DEPARTMENT OF TRANSPORTATION (DOT) REQUIREMENTS: GENERAL TRANSPORTATION INFORMATION FOR BULK SHIPMENTS, PROPER SHIPPING NAME: SULFURIC ACID HAZARD. CLASS: B Page 7 of9 htto;! Ifolenergy .complyplus.comIMSDS/print_ bare.asp?S=293&ShowTOC= 1 &ShowHazardRatings= 1 &... 6117/2009 SULFURIC ACID by KOCH SULFUR PRODUCTS Page 8 of 9 UN/NA CODE: UN1830, UN2796 PACKAGING GROUP: PG II LABELS REQUIRED: CORROSIVE PLACARDS REQUIRED: CORROSIVE, UN1830 (>51%), UN2796 (<=51%)REPORTABLE QUANTITY: SEE REGULATORY INFORMATION (SECTION 15)GENERAL TRANSPORTATION INFORMATION FOR NON-BULK SHIPMENTS: PROPER SHIPPING NAME: SULFURIC ACID HAZARD CLASS: 8 UN/NA CODE: UN1830, UN2796PACKAGING GROUP: PG II LABELS REQUIRED: CORROSIVE PLACARDS REQUIRED: CORROSIVE, UN1830 (>51t), UN2796 (<-51%)REPORTABLE QUANTITY: SEE REGULATORY INFORMATION (SECTION 15)THE ABOVE DESCRIPTION MAY NOT COVER SHIPPING IN ALL CASES, PLEASE CONSULT 49 CFR 172.101 FOR SPECIFIC SHIPPING INFORMATION. 15 REGULATORY INFORMATIONFEDERAL REGULATIONS: ALL INGREDIENTS ARE ON THE TSCA INVENTORY OR ARE NOT REQUIRED TO BE LISTED ON THE TSCA INVENTORY. THIS PRODUCT, AS SUPPLIED, CONTAINS SULFURIC ACID, A HAZARDOUS SUBSTANCE AS PER 40 CPR PART 302.4 AND AN EXTREMELY HAZARDOUS SUBSTANCE AS PER 40 CFR PART 355. THE REPORTABLE QUANTITY FOR SULFURIC ACID IS 1000 POUNDS. ANY RELEASE OF THIS PRODUCT EQUAL TO OR EXCEEDING THE REPORTABLE QUANTITY MUST BE REPORTED TO THE NATIONAL RESPONSE CENTER (800-424-8802) AND APPROPRIATE STATE AND LOCAL REGULATORY AGENCIES AS DESCRIBED IN 40 CFR PART 302.6 AND 40 CFR 355.40, RESPECTIVELY. FAILURE TO REPORT MAY RESULT IN SUBSTANTIAL CIVIL AND CRIMINAL PENALTIES. CHECK STATE AND LOCAL REGULATIONS FOR ANY ADDITIONAL REQUIREMENTS AS THESE MAY BE MORE RESTRICTIVE THAN FEDERAL LAWS AND REGULATIONS. THIS PRODUCT CONTAINS ONE OR MORE COMPONENTS DESIGNATED AS HAZARDOUS SUBSTANCES OR TOXIC POLLUTJANTS PURSUANT TO THE FEDERAL CLEAN WATER ACT (40 CFR 116.4 TABLE A; 40 CFR 401.15). ANY UNPERMITTED INTRODUCTION OF THIS PRODUCT INTO A FACILITY STORM WATER OR WASTEWATER DISCHARGE MAY CONSTITUTE A VIOLATION OF THE CLEAN WATER ACT. FACILITIES MUST NOTIFY THE APPROPRIATE PERMITTING AGENCY PRIOR TO INTRODUCING THIS PRODUCT INTO THE AFOREMENTIONED DISCHARGES. THIS PRODUCT CONTAINS ONE OR MORE SUBSTANCES LISTED AS HAZARDOUS, TOXIC OR FLAMMABLE AIR POLLUTANTS UNDER SECTION 112 OF THE CLEAN AIR ACT.THERE MAY BE SPECIFIC REGULATIONS AT THE LOCAL, REGIONAL OR STATE/PROVINCIAL LEVEL THAT PERTAIN TO THIS PRODUCT.STATE REGULATIONS: BASED ON AVAILABLE INFORMATION THIS PRODUCT DOES NOT CONTAIN ANY COMPONENTS OR CHEMICALS CURRENTLY KNOWN TO THE STATE OF CALIFORNIA TO CAUSE CANCER, BIRTH DEFECTS OR REPRODUCTIVE HARM AT LEVELS WHICH WOULD BE SUBJECT TO PROPOSITION

65. REFORMULATION, USE OR PROCESSING OF THIS PRODUCT MAY AFFECT ITS COMPOSITION AND REQUIRE RE-EVALUATION.

SARA TITLE III RATINGS: IMMEDIATE HAZARD (X)httn://fn~energy.comp~yplus.comJMSDS/printbare.asp?S=293&ShowTOC=4&ShowHazardRatings=1&... 6/17/2009 SULFURIC ACID by KOCH SULFUR PRODUCTS ON/NA COOE: UN1830, UN2796 PACKAGINQ GROUP: PG II LABELS CORROSIVE PLACARDS REQUIRED: CORROSIVE, UN1830 (>51%), UN2796 <<=51%) REPORTABLE QUANTITY: SEE REGULATORY INFORMATION (SECTION 15) GENERAL TRANSPORTATION INFORMATION FOR NON-BULK SHIPMENTS: PROPER SHIPPING NAME: SULFURIC ACID HAZARD CLASS: 8 ON/NA CODE: ON1830, UN2796 PACKAGING GROUP, PG II LABELS REQUIRED: CORROSIVE PLACARDS REQUIRED: CORROSIVE, ON1830 (>51%), UN2796 <<c51%) REPORTABLE QUANTITY: SEE REGULATORY INFORMATION (SECTION 15) THE ABOVE DESCRIPTION MAY NOT COVER SHIPPING IN ALL CASES, PLEASE CONSULT 49 CFR 172.101 FOR SPECIFIC SHIPPING INFORMATION. 15 REGULATORY INFORMATION FEDERAL REGULATIONS: ALL INGREDIENTS ARE ON THE TSCA INVENTORY OR ARE NOT REQUIRED TO BE LISTED ON THE TSCA INVENTORY. THIS PROOUCT, AS SUPPLIED, CONTAINS SULFURIC ACID, A HAZARDOUS SUBSTANCE AS PER 40 CFR PART 302.4 AND AN EXTREMELY HAZARDOUS SUBSTANCE AS PER 40 CFR PART 355. THE REPORTABLE QUANTITY FOR SULFURIC ACID IS 1000 POUNDS. ANY RELEASE OF THIS PRODUCT EQUAL TO OR EXCEEDING THE REPORTABLE QUANTITY MUST BE REPORTED TO THE NATIONAL RESPONSE CENTER (800-424-8802) AND APPROPRIATE STATE AND LOCAL REGULATORY AGENCIES AS DESCRIBED IN 40 CPR PART 302.6 AND 40 CPR 355.40, RESPECTIVELY. FAILURE TO REPORT MAY RESULT IN SUBSTANTIAL CIVIL AND CRIMINAL PENALTIES. CHECK STATE AND LOCAL REGULATIONS FOR ANY ADDITIONAL REQUIREMENTS AS THESE MAY BE MORE RESTRICTIVE THAN FEDERAL LAlv5 AND REGULATIONS. THIS PRODUCT CONTAINS ONE OR MORE COMPONENTS DESICNATED AS HAZARDOUS SOBSTANCES OR TOXIC POLLUTANTS PURSUANT TO THE FEDERAL CLEAN WATER ACT (40 CFR 116.4 TABLE A; 40 CFR 401.15). ANY UNPERMITTED INTRODUCTION OF THIS PRODUCT INTO A FACILITY STORM WATER OR WASTEWATER DISCHARGE MAY CONSTITUTE A VIOLATION OF THE CLEAN WATER ACT. FACILITIES MUST NOTIFY THE APPROPRIATE PERMITTING AGENCY PRIOR TO INTRODOCING THIS PRODUCT INTO THE AFOREMENTIONED DISCHARGES. THIS PRODUCT CONTAINS ONE OR MORE SUBSTANCES LISTED AS HAZARDOUS, TOXIC OR FLAMMABLE AIR POLLUTANTS UNDER SECTION 112 OF THE CLEAN AIR ACT. THERE MAY BE SPECIFIC REGULATIONS AT THE LOCAL, REGIONAL OR STATE/PROVINCIAL LEVEL THAT PERTAIN TO THIS PRODUCT. STATE REGULATIONS: BASED ON AVAILABLE INFORMATION THIS PRODUCT DOES NOT CONTAIN ANY COMPONENTS OR CHEMICALS CURRENTLY KNOWN TO THE STATE OF CALIFORNIA TO CAUSE CANCER, BIRTH DEFECTS OR REPRODUCTIVE HARM AT LEVELS WHICH WOULD BE SUBJECT TO PROPOSITION

65. REFORMULATION, USB OR PROCESSING OF THIS PRODUCT MAY AFFECT ITS COMPOSITION AND REQUIRE RE-EVALUATION.

SARA TITLE III RATINGS: IMMEDIATE HAZARD (X) Page 80f9 httn:/ Ifolenem.Y .complyplus.comIMSDS/princ bare.asp?S=293&ShowTOC= 1 &ShowHazardRatings== 1 &... 6/17/2009 SULFURIC ACID by KOCH SULFUR PRODUCTS Page 9 of 9 DELAYED HAZARD (X)FIRE HAZARD PRESSURE HAZARD REACTIVITY HAZARD (X)NFPA RATINGS: HEALTH 3FLAMMABILITY 0 REACTIVITY 2 SPECIAL HAZARDS W HMIS RATINGS: HEALTH 3*FLAMMABILITY 0 REACTIVITY 2 FOLLOWING INGREDIENTS OF THIS PRODUCT ARE LISTED IN SARA313: SARA LISTED INGREDIENT NAME CAS NUMBER MAXIMUM %SULFURIC ACID 7664-93-9 100.0 16 OTHER INFORMATION DISCLAIMER: NOTICE:THE INFORMATION PRESENTED HEREIN IS BASED ON DATA CONSIDERED TO BE ACCURATE ASOF THE DATE OF PREPARATION OF THIS MATERIAL SAFETY DATA SHEET. HOWEVER, MSDS MAY NOT BE USED AS A COMMERCIAL SPECIFICATION SHEET OF MANUFACTURER OR SELLER, AND NO WARRANTY OR REPRESENTATION, EXPRESSED OR IMPLIED, IS MADE AS TO THE ACCURACY OR COMPREHENSIVENESS OF THE FOREGOING DATA AND SAFETY INFORMATION, NOR IS ANY AUTHORIZATION GIVEN OR IMPLIED TO PRACTICE ANY PATENTED INVENTION WITHOUT A LICENSE. IN ADDITION, NO RESPONSIBILITY CAN BE ASSUMED BY VENDOR FORANY DAMAGE OR INJURY RESULTING FROM ABNORMAL USE, FROM ANY FAILURE TO ADHERE TO RECOMMENDED PRACTICES, OR FROM ANY HAZARDS INHERENT IN THE NATURE OF THE PRODUCT.CURRENT REVISION DATE: 23-APR-2002 REPLACES SHEET DATED: 19-APR-2002 COMPLETED BY SAFETY & EMERGENCY RESPONSE, KOCH INDUSTRIES, INC.ND = NO DATA NA = NOT APPLICABLE PRINTED ON: 4/23/2002 MATERIAL ID 5371 Copyright§ 1999-2009 Dolphin Software, Inc.Comply Plus Web -Hosted FPL Energy httn://fnlenernv.comtpyplus.comIMSDS/print-bare.asp?S=293&ShowTOC=1&ShowHazardRatings=l &... 6/17/2009 SULFURIC ACID by KOCH SULFUR PRODUCTS DEIAYED HAZARD (X) FIRE HAZARD ( ) PRESSURE HAZARD () REACTIVITY HAZARD (X) NFPA RATINGS: HEALTH 3 FLAMMABILITY 0 REACTIVITY 2 SPECIAL HAZARDS W HMIS RATINGS: HEALTH 3* FLAMMABILITY 0 REACTIVITY 2 FOLLOWING INGREDIENTS OF THIS PRODUCT ARE LISTED IN SARA313: SARA LISTED INGREDIENT NAME CAS NUMBER MAXIMUM % SULFURIC ACID 7664-93-9 100.0 16 OTHER INFORMATION DISCIAIMER: NOTICE; THE INFORMATION PRESENTED HEREIN IS BASED ON DATA CONSIDERED TO BE ACCURATE AS OF THE DATE OF PREPARATION OF THIS MATERIAL SAFETY DATA SHEET. HOWEVER, MSDS MAY NOT BE USED AS A COMMERCIAL SPECIFICATION SHEET OF MANUFACTURER OR SELLER, AND NO WARRANTY OR REPRESENTATION, EXPRESSED OR IMPLIED, IS MADE AS TO THE ACCURACY OR COMPREHENSIVENESS OF THE FOREGOING DATA AND SAFETY INFORMATION, NOR IS ANY AUTHORIZATION GIVEN OR IMPLIED TO PRACTICE ANY PATENTED INVENTION WITHOUT A LICENSE. IN ADDITION, NO RESPONSIBILITY CAN BE ASSUMED BY VENDOR FOR ANY DAMAGE OR INJURY RESULTING FROM ABNORMAL USE, FROM ANY FAILURE TO ADHERE TO RECOMMENDED PRACTICES, OR FROM ANY HAZARDS INHERENT IN THE NATURE OF THE PRODUCT. CURRENT REVISION DATE: 23-APR-2002 REPLACES SHEET DATED: 19-APR-2002 COMPLETED BY SAFETY & EMERGENCY RESPONSE, KOCH INDUSTRIES, INC. ND NO DATA NA NOT APPLICABLE PRINTED ON: 4/23/2002 MATERIAL ID 5371 Copyrigh/© 1999*2009 Dolphin Software, Inc. Comply Plus Web* Hosted FPL Energy Page 9 of9 httn:llfulenergY.comp}yplus.comIMSDS/print _ bare.asp?S==293&ShowTOC== 1 &ShowHazardRatings= 1 &... 6/17/2009 SPECTRUS NX 1107 by GE BETZ Page 1 of 7 FPL Energy Duane Arnold SPECTRUS NX1I07 GE BETZ FileName Language Internal ID Revision Date 004150 0938 6/1/2001 Table Of Contents 1 PRODUCT IDENTIFICATION 2 COMPOSITION / INFORMATION ON INGREDIENTS 3 HAZARDS IDENTIFICATION 4 FIRST AID MEASURES 5 FIRE FIGHTING MEASURES 6 ACCIDENTAL RELEASE MEASURES 7 HANDLING & STORAGE 8 EXPOSURE CONTROLS / PERSONAL PROTECTION 9 PHYSICAL & CHEMICAL PROPERTIES 10 STABILITY & REACTIVITY 11 TOXICOLOGICAL INFORMATION 12 ECOLOGICAL INFORMATION 13 DISPOSAL CONSIDERATIONS 14 TRANSPORT INFORMATION 15 REGULATORY INFORMATION 16 OTHER INFORMATION I Hazards MSDS State NFPA HMIS (Active)Health 1 1 Flammability 1 1 Reactivity 0 0 Other B MATERIAL SAFETY DATA SHEET GE BETZ, INC.4636 SOMERTON ROAD TREVOSE, PA 19053 BUSINESS TELEPHONE: (215) 355-3300 ISSUE DATE: O1-JUN-2001 EMERGENCY TELEPHONE (HEALTH/ACCIDENT): (800) 877-1940 1 PRODUCT IDENTIFICATION PRODUCT NAME: SPECTRUS NX1107 PRODUCT APPLICATION AREA: WATER-BASED MICROBIAL CONTROL AGENT.2 COMPOSITION / INFORMATION ON INGREDIENTS INFORMATION FOR SPECIFIC PRODUCT INGREDIENTS AS REQUIRED BY THE U.S. OSHA HAZARD COMMUNICATION STANDARD IS LISTED. REFER TO ADDITIONAL SECTIONS OF http://fplenergy.complyplus.cornMSDS/printbare.asp?S=980&ShowTOC= l &ShowHazardRatings=l &... 6/17/2009 SPECTRUS NXl107 by OE BETZ FPL Energy Duane Arnold SPECTRUS NXll07 FileName Language Internal 10 004150 0938 Table Of Contents 1 PRODUCT IDENTIFICATION 2 COMPOSITION / INFORMATION ON INGREDIENTS 3 HAZARDS IDf:NTIFICATIDN 4 FIRST AID MEASURES 5 FIRE FIGHTING MEASURES 6 ACCIDENTAL RELEASE MEASURES 7 HANDLING & STORAGE 8 EXPOSURE CONTROLS / PERSONAL PROTECTION 9 PHYSICAL & CHEMICAL PROPERTIES 10 STABILITY & REACTIVITY 11 TOXICOLOGICAL INFORMATION 12 ECOLOGICAL INFORMATION 13 DISPOSAL CONSIDERATIONS 14 TRANSPORT INFORMATION lS REGULATORY INFORMATION 15 OTHER INFORMATION Hazards NFPA Health 1 Flammability 1 Reactivity 0 Other MATERIAL SAFETy DATA SHEET GE BE'I'Z, INC. 4636 SOMERTON ROAD TREVOSE, PA 19053 BUSINESS TELEPHONE: (215) 355-3300 ISSUE DATE: 01-JUN-2001 HMIS 1 1 0 B MSDSState I EMERGENCY TELEPHONE (HEALTH/ACCIDENT): (BOO) B77-1940 1 PRODUCT IDENTIFICATION PRODUCT NAME: SPECTRUS NX1107 PRODUCT APPLICATION AREA: WATER-BASED MICROBIAL CONTROL AGENT. 2 COMPOSITION / INFORMATION ON INGREDIENTS (Active) INFORMATION FOR SPECIFIC PRODUCT INGREDIENTS AS REQUIRED BY THE U.S. OSHA HAZARD COMMUNICATION STANDARD IS LISTED. REFER TO ADDITIONAL SECTIONS OF Page 1 of7 GE BETZ Revision Date 6/1/2001 I http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=980&ShowTOC= 1 &ShowHazardRatings=l &... 6/17/2009 SPECTRUS NX 1107 by GE BETZ Page 2 of 7 THIS MSDS FOR OUR ASSESSMENT OF THE POTENTIAL HAZARDS OF THIS FORMULATION. HAZARDOUS INGREDIENTS: CAS# CHEMICAL NAME 5915-41-3 2- (T-BUTYLAMINO) CHLORO-6-ETHYLAMINO-S-TRIAZINE (TERBUTYLAZINE) POTENTIAL IRRITANT 107-21-1 ETHYLENE GLYCOL LIVER, KIDNEY AND BLOOD TOXIN CNS DEPRESSANTANIMAL TERATOGEN (AT HIGH ORAL DOSES)NO COMPONENT IS CONSIDERED TO BE A CARCINOGEN BY THE NATIONAL TOXICOLOGY PROGRAM, THE INTERNATIONAL AGENCY FOR RESEARCH ON CANCER, OR THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION AT OSHA THRESHOLDS FOR CARCINOGENS. 3 HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: WARNING: MAY CAUSE SLIGHT IRRITATION TO THE SKIN. POTENTIAL SKIN SENSITIZER. MAY CAUSE SLIGHT IRRITATION TO THE EYES. VAPORS, GASES, MISTS AND/OR AEROSOLS MAY CAUSE IRRITATION TO UPPER RESPIRATORY TRACT.DOT HAZARD IS NOT APPLICABLE EMERGENCY RESPONSE GUIDE IS NOT APPLICABLE ODOR: MILD APPEARANCE: TAN, DISPERSION FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE).PROPER FIRE-EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER.POTENTIAL HEALTH EFFECTS: ACUTE SKIN EFFECTS: PRIMARY ROUTE OF EXPOSURE; MAY CAUSE SLIGHT IRRITATION TO THE SKIN.POTENTIAL SKIN SENSITIZER.ACUTE EYE EFFECTS: MAY CAUSE SLIGHT IRRITATION TO THE EYES.ACUTE RESPIRATORY EFFECTS: VAPORS, GASES, MISTS AND/OR AEROSOLS MAY CAUSE IRRITATION TO UPPER RESPIRATORY TRACT.INGESTION EFFECTS;MAY CAUSE GASTROINTESTINAL IRRITATION WITH POSSIBLE NAUSEA, VOMITING, HEADACHE, DIZZINESS, UNCONSCIOUSNESS AND INJURY TO THE KIDNEYS AND LIVER.http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=980&ShowTOC=1&ShowHazardRatings=l &... 6/17/2009 SPECTRUS NXI107 by GE BETZ THIS MSDS FOR OUR ASSESSMENT OF THE POTENTIAL HAZARDS OF THIS FORMULATION. HAZARDOUS INGREDIENTS: CAS# 5915-41-3 107-21-1 CHEMICAL NAME 2-(T-BUTYLAMINO) CHLDRO-6-ETHYLAMINO-S-TRIAZlNE (TERBUTYLAZINE) POTENTIAL IRRITANT ETHYLENE GLYCOL LIVER, KIDNEY AND BLOOD TOXIN CNS DEPRESSANT ANIMAL TERATOGEN (AT HIGH ORAL DOSES) NO COMPONENT IS CONSIDERED TO BE A CARCINOGEN BY THE: NATIONAL TOXICOLOGY PROGRAM, THE INTERNATIONAL AGENCY FOR RESEARCH ON CANCER, OR THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION AT OSHA THRESHOLDS FOR CARCINOGENS. 3 HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: WARNING: MAY CAUSE SLIGHT IRRITATION TO THE SKIN. POTElITIAL SKIN SENSITIZER. MAY CAUSE SLIGHT IRRITATION TO THE EYES. VAPORS, GASES, MISTS AND/OR AEROSOLS MAY CAUSE IRRITATION TO UPPER RESPIRATORY TRACT. DOT HAZARD IS NOT APPLICABLE EMERGENCY RESPONSE GUIDE IS NOT APPLICABLE ODOR: MILD APPEARANCE: TAN, DISPERSION FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE). PROPER FIRE-EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER. POTENTIAL HEALTH EFFECTS: ACUTE SKIN EFFECTS, PRIMARY ROUTE OF EXPOSURE; MAY ChUSE SLIGHT IRRITATION TO THE SKIN. POTENTIAL SKIN SENSITIZER. ACUTE EYE EFFECTS: MAY CAUSE SLIGHT IRRITATION TO THE EYES. ACUTE RESPIRATORY EFFECTS: VAPORS, GASES, MISTS AND/OR AEROSOLS MAY CAUSE IRRITATION TO UPPER RESPIRATORY TRACT. INGESTION EFFECTS: MAY CAUSE GASTROINTESTINAL IRRITATION WITH POSSIBLE NAUSEA, VOMITING, HEADACHE, DIZZINESS, UNCONSCIOUSNESS AND INJURY TO THE KIDNEYS AND LIVER. Page 2 of7 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=980&ShowTOC=1 &ShowHazardRatings=l &... 6/17/2009 SPECTRUS NXI 107 by GE BETZ Page 3 of 7 TARGET ORGANS: PROLONGED OR REPEATED EXPOSURES MAY CAUSE CNS DEPRESSION AND/OR TOXICITY TO THE LIVER, KIDNEY, BLOOD SYSTEM, AND REPRODUCTIVE SYSTEM.MEDICAL CONDITIONS AGGRAVATED: NOT KNOWN.SYMPTOMS OF EXPOSURE: MAY CAUSE REDNESS OR ITCHING OF SKIN.4 FIRST AID MEASURES SKIN CONTACT.: REMOVE CONTAMINATED CLOTHING. WASH EXPOSED AREA WITH A LARGE QUANTITY OF SOAP SOLUTION OR WATER FOR 15 MINUTES.EYE CONTACT:IMMEDIATELY FLUSH EYES WITH WATER FOR 15 MINUTES. IMMEDIATELY CONTACT A PHYSICIAN FOR ADDITIONAL TREATMENT. INHALATION: REMOVE VICTIM FROM CONTAMINATED AREA TO FRESH AIR. APPLY APPROPRIATE FIRST AID TREATMENT AS NECESSARY. INGESTION: DO NOT FEED ANYTHING BY MOUTH TO AN UNCONSCIOUS OR CONVULSIVE VICTIM. DO NOT INDUCE VOMITING. IMMEDIATELY CONTACT PHYSICIAN. DILUTE CONTENTS OF STOMACH USING 3-4 GLASSES MILK OR WATER.NOTES TO PHYSICIANS: NO SPECIAL INSTRUCTIONS 5 FIRE FIGHTING MEASURES FIRE FIGHTING INSTRUCTIONS: FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE).EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER.HAZARDOUS DECOMPOSITION PRODUCTS:.THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES.FLASHPOINT: >200F>93C P-M(CC)6 ACCIDENTAL RELEASE MEASURES PROTECTION AND SPILL CONTAINMENT: VENTILATE AREA. USE SPECIFIED PROTECTIVE EQUIPMENT. CONTAIN AND ABSORB ON ABSORBENT MATERIAL, PLACE IN WASTE DISPOSAL CONTAINER. FLUSH AREA WITH WATER. WET AREA MAY BE SLIPPERY. SPREAD SAND/GRIT. DISPOSAL INSTRUCTIONS: WATER CONTAMINATED WITH THIS PRODUCT MAY BE SENT TO A SANITARY SEWER http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=980&ShowTOC=I &ShowHazardRatings= &... 6/17/2009 SPECTRUS NXIlO7 by OE BETZ TARGET ORGANS: PROLONGED OR REPBATSD EXPOSURES MAY CAUSE CNS DEPRESSION AND/OR TOXICITY TO THE LIVER, KIDNEY, SLOOD SYSTEM, AND REPRODUCTIVE SYSTEM. MEDICAL CONDITIONS AGGRAVATED: NOT KNOWN. SYMPTOMS OF EXPOSURE: MAY CAUSE REDNESS OR ITCHING OF SKIN. 4 FIRST AID MEASURES SKIN CONTACT: REMOVE CONTAMINATED CLOTHING. WASH EXPOSED AREA WITH A LARGE QUANTITY OF SOAP SOLUTION OR WATER FOR 15 MINUTES. EYE: CONTACT: IMMEDIATELY FLUSH EYES WITH WATER FOR 15 MINUTES. IMMEDIATELY CONTACT A PHYSICIAN FOR ADDITIONAL TREATMENT. INHALATION: REMOVE VICTIM FROM CONTAMINATED AREA TO FRESH AIR. APPLY APPROPRIATE FIRST AID TREATMENT AS NECESSARY. INGESTION: DO NOT FEED ANYTHING BY MOUTH TO AN UNCONSCIOUS OR CONVULSIVE VICTIM. DO NOT INDUCE VOMITING. IMMEDIATELY CONTACT PHYSICIAN. DILUTE CONTENTS OF STOMACH USING 3-4 GLASSES MILK OR WATER. NOTES TO PHYSICIANS: NO SPECIAL INSTRUCTIONS 5 FIRE FIGHTING MEASURES FIRE FIGHTING FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE). EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER. HAZARDOUS DECOMPOSITION PRODUCTS:

• THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES. FLASHPOINT:

,,200F >93C P-M(CC) 6 ACCIDENTAL RELEASE MEASURES PROTECTION AND SPILL CONTAINMENT: VENTILATE AREA. USE SPECIFIED PROTECTIVE EQUIPMENT. CONTAIN AND ABSORB ON ABSORBENT MATERIAL. PLACE IN WASTE DISPOSAL CONTAINER. FLUSH AREA WITH WATER. WET AREA MAY BE SLIPPERY. SPREAD SAND/GRIT. DISPOSAL INSTRUCTIONS: WATER CONTAMINATED WITH THIS PRODUCT MAY BE SENT TO A SANITARY SEWER Page 3 of7 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=980&ShowTOO= 1 &ShowHazardRatings= 1 &... 6/17/2009 SPECTRUS NXI 107 by GE BETZ Page 4 of 7 TREATMENT FACILITY, IN ACCORDANCE WITH ANY LOCAL AGREEMENT, A PERMITTED WASTE TREATMENT FACILITY OR DISCHARGED UNDER A PERMIT. PRODUCT ASIS -DISPOSE OF IN APPROVED PESTICIDE FACILITY OR ACCORDING TO LABEL INSTRUCTIONS. 7 HANDLING & STORAGE HANDLING: NORMAL CHEMICAL HANDLING. STORAGE-KEEP CONTAINERS CLOSED WHEN NOT IN USE. DO NOT FREEZE. IF FROZEN, THAW AND MIX COMPLETELY PRIOR TO USE.8 EXPOSURE CONTROLS / PERSONAL PROTECTION EXPOSURE LIMITS: CHEMICAL NAME:2- (T-BUTYLAMINO) CHLORO-6-ETHYLAMINO-S-TRIAZINE (TERBUTYLAZINE): PEL (OSHA): NOT DETERMINED TLV (ACGIH)! NOT DETERMINED ETHYLENE GLYCOL: PEL (OSHA): 50 PPM-C TLV (ACGIH): 100 PPM-C ENGINEERING CONTROLS: ADEQUATE VENTILATION TO MAINTAIN AIR CONTAMINANTS BELOW EXPOSURE LIMITS.PERSONAL PROTECTIVE EQUIPMENT: USE PROTECTIVE EQUIPMENT IN ACCORDANCE WITH 29 CFR 1910 SUBPART I RESPIRATORY PROTECTION: A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CFR 1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE.USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS. IF AIR-PURIFYING RESPIRATOR USE IS APPROPRIATE, USE A RESPIRATOR WITH ORGANIC VAPOR CARTRIDGES. SKIN PROTECTION: RUBBER GLOVES -WASH OFF AFTER EACH USE. REPLACE AS NECESSARY. EYE PROTECTION: SPLASH PROOF CHEMICAL GOGGLES 9 PHYSICAL & CHEMICAL PROPERTIES SPECIFIC GRAV. (70F, 21C) 1.117 VAPOR PRESSURE (MMHG) : APPROX. 18.0 FREEZE POINT (FM: 15 FREEZE POINT (C) : -9 http://fplenergy.complyplus.com/MSDS/print-bare.asp?S-980&ShowTOC=l &ShowHazardRatings=l&... 6/17/2009 SPECTRUS NXII07 by GE BETZ TREATMENT FACILITY, IN ACCORDANCE WITH ANY LOCAL AGREEMENT, A PERMITTED WASTE TREATMENT FACILITY OR DISCHARGED UNDER A PERMIT. PRODUCT AS IS -DISPOSE OF IN APPROVED PESTICIDE FACILITY OR ACCORDING TO LABEL INSTRUCTIONS. 7 HANDLING "' STORAGE HANDLING: NORMAL CHEMICAL HANDLING. STORAGE: KEEP CONTAINERS CLOSED WHEN NOT IN USE. DO NOT FREEZE. IF FROZEN, THAW AND MIX COMPLETELY PRIOR TO USE. a EXPOSURE CONTROLS I PERSONAL PROTECTION EXPOSURE LIMITS: CHEMICAL NAME: 2-(T-BUTYLAMINO)-4-CHLORO-6-ETHYLAMINO-S-TRIAZINE (TERBOTYLAZINE): PEL (OSHA): NOT DETERMINED TLV (ACGIH): NOT DETBRMINED ETHYLENE GLYCOL: PEL (OSHA): 50 PPM-C TLV (ACGIH): 100 PPM-C ENGINEERING CONTROLS: ADEQUATE VENTILATION TO MAINTAIN AIR CONTAMINANTS BELOW EXPOSURE LIMITS. PERSONAL PROTECTIVE EQUIPMENT: USE PROTECTIVE EQUIPMENT IN ACCORDANCE WITH 29 CFR 1910 SUBPART I RESPIRATORY PROTECTION: A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CFR 1910.134 AND ANSI 288.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE. USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS. IF AIR-PURIFYING RESPIRATOR USE IS APPROPRIATE, USE A RESPIRATOR WITH ORGANIC VAPOR CARTRIDGES. SKIN PROTECTION: RUBBER GLOVES -WASH OFF AFTER EACH USE. REPLACE AS NECESSARY. EYE PROTECTION: SPLASH PROOF CHEMICAL GOGGLES 9 PHYSICAL "' CHEMICAL PROPERTIES SPECIFIC GRAV. (70F, 21C) 1.117 VAPOR PRESSURE (MMHG): APPROX. 18.0 FREEZE POINT (F); 1S FREEZE POINT (e); -9 Page 4 of7 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=980&ShowTOC= 1 &ShowHazardRatings= 1 &... 6117/2009 SPECTRUS NX 1107 by GE BETZ Page 5 of 7 VAPOR DENSITY (AIR = 1): < 1.00 VISCOSITY (CPS 70F, 21 C): 291% SOLUBILITY (WATER): 0.0 ODOR: MILD APPEARANCE: TAN PHYSICAL STATE: DISPERSION FLASHPOINT: P-M (CC)>200 F>93 C pH AS IS (APPROX.):

7.1 EVAPORATION

RATE (ETHER 1 1): <1.00NA = NOT APPLICABLE ND = NOT DETERMINED 10 STABILITY & REACTIVITY STABILITY: STABLE UNDER NORMAL STORAGE CONDITIONS. HAZARDOUS POLYMERIZATION: WILL NOT OCCUR. INCOMPATIBILITIES: MAY REACT WITH STRONG OXIDIZERS. DECOMPOSITION PRODUCTS;THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES.INTERNAL PUMPOUT/CLEANOUT CATEGORIES: "B" 11 TOXICOLOGICAL INFORMATION ORAL LD50 RAT: 1,350 MG/KG DERMAL LDSO RABBIT: >4,400 MG/KG SKIN IRRITATION SCORE RABBIT: .7 EYE IRRITATION SCORE RABBIT: 0 SKIN SENSITIZATION G. PIG: NEGATIVE 12 ECOLOGICAL INFORMATION AQUATIC TOXICOLOGY:http://fplenergy.complyplus.oom/MSDS/print-bare.asp?S=980&ShowTOC= 1 &ShowHazardRatings=' &... 6/17/2009 SPECTRUS NXII07 by GE BETZ VAPOR DENSITY (AIR = 1): < 1.00 VISCOSrTY (CPS 70F, 21 C), 291 % SOLUBILITY (WATER): 0.0 ODOR: MILD APPEARANCE: TAN PHYSICAL STATE: DISPERSION FLASHPOINT: P-M (CC) >200 F >93 C pH AS IS (APPROX.):

7.1 EVAPORATION

RATE (ETHER" 1): <1. 00 NA = NOT APPLICABLE ND = NOT DETERMINED .. 10 STABILITY & REACTIVITY STABILITY: STABLE UNDER NORMAL STORAGE CONDITIONS. HAZARDOUS POLYMERIZATION: WILL NOT OCCUR. INCOMPATIBILITIES: MAY REACT WITH STRONG OXIDIZERS. DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES. INTERNAL PUMPOUT/CLEANOUT CATEGORIES: "B" 11 TOXICOLOGICAL INFORMATION ORAL LD50 RAT: 1,350 MG/KG DERMAL LDSO RABBIT: >4,400 MG/KG SKIN IRRITATION SCORE RABBIT: .7 EYE IRRITATION SCORE RABBIT: 0 SKIN SENSITIZATION G. PIG: NEGATIVE 12 ECOLOGICAL INFORMATION AQUATIC TOXICOLOGY: Page 5 of7 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=980&ShowTOC== 1 &ShQwHazardRatings== 1 &... 611712009 SPECTRUS NXI 107 by GE BETZ Page 6 of 7 BLUEGILL SUNFISH 96 HOUR STATIC ACUTE BIOASSAY: LC50: 16 MG/L DAPHNIA MAGNA 48 HOUR STATIC ACUTE BIOASSAY: LC50: 86 MG/L FATHEAD MINNOW 96 HOUR STATIC ACUTE BIOASSAY: LC50: 13 MG/L MYSID SHRIMP 96 HOUR STATIC ACUTE BIOASSAY: LC50: .2 MG/L RAINBOW TROUT 96 HOUR STATIC ACUTE BIOASSAY: LC50: 8 MG/L BIODEGRADATION: BOD-28 (MG/G): 103 BOD-5 (MG/G): 38 COD (MG/G): 1300 TOC (MG/G) : 270 13 DISPOSAL CONSIDERATIONS IF THIS UNDILUTED PRODUCT IS DISCARDED AS A WASTE, THE US RCRA HAZARDOUS WASTE IDENTIFICATION NUMBER IS: NOT APPLICABLE. PLEASE BE ADVISED; HOWEVER, THAT STATE AND LOCAL REQUIREMENTS FOR WASTE DISPOSAL MAY BE MORE RESTRICTIVE OR OTHERWISE DIFFERENT FROM FEDERAL REGULATIONS. CONSULT STATE AND LOCAL REGULATIONS REGARDING THE PROPER DISPOSAL OF THIS MATERIAL.14 TRANSPORT INFORMATION DOT HAZARD: NOT APPLICABLE UN / NA NUMBER: NOT APPLICABLE DOT EMERGENCY RESPONSE GUIDE #: NOT APPLICABLE 15 REGULATORY INFORMATION TSCA : THIS IS AN EPA REGISTERED BIOCIDE AND IS EXEMPT FROM TSCA INVENTORY REQUIREMENTS. CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ): NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS. FIFRA REGISTRATION NUMBER: 279-3137-3876 SARA SECTION 312 HAZARD CLASS: IMMEDIATE (ACUTE)DELAYED (CHRONIC)http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=980&ShowTOC=I&ShowHazardRatings=l &... 6/17/2009 SPECTRUS NXI 107 by GE BETZ BLUEGILL SUNFISH 96 HOUR STATIC ACUTE BIOASSAY: LeSO: 16 MG/L DAPHNIA MAGNA 48 HOUR STATIC ACUTE BIOASSAY: Leso: 86 MG/L FATHEAD MINNOW 96 HOUR STATIC ACUTE BIOASSAY: LCSO: 13 MG/L MYSID SHRIMP 96 HOUR STATIC ACUTE BIOASSAY: Leso: .2 MG/L RAINBOW TROUT 96 HOUR STATIC ACUTE BIOASSAY: LeSO: e MG/L BIODEGRADATION: BOD-28 (MG/G): 103 BOD-S (MG/G): 38 COD (MG/G): 1300 TOC (MG/G): 270 13 DISPOSAL CONSIDERATIONS IF THIS UNDILUTED PRODUCT IS DISCARDED AS A WASTE, THE US ReRA HAZARDOUS WASTE IDENTIFICATION NUMBER IS: NOT APPLICABLE. PLEASE BE ADVISED, HOWEVER, THAT STATE AND LOCAL REQUIREMENTS FOR WASTE DISPOSAL MAY BE MORE RESTRICTIVE OR OTHERWISE DIFFERENT FROM FEDERAL REGULATIONS. CONSULT STATE AND LOCAL REGULATIONS REGARDING THE PROPER DISPOSAL OF THIS MATERIAL. 14 TRANSPORT INFORMATION DOT HAZARD: NOT APPLICABLE UN I NA NUMBER: NOT APPLICABLE DOT EMERGENCY RESPONSE GUIDE #: NOT APPLICABLE 15 REGULATORY INFORMATION TSCA: THIS IS AN EPA REGISTERED BIOCIDE AND IS EXEMPT FROM TSCA INVENTORY REQUIREMENTS . CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ): NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS. FIFRA REGISTRATION NUMBER: 279-3137-3876 SARA SECTION 312 HAZARD CLASS: IMMEDIATE (ACUTE) DELAYED (CHRONIC) Page 6 of7 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=980&ShowTOC= 1 &ShowHazardRatings= 1 &... 6117/2009 SPECTRUS NX 1107 by GE BETZ SARA SECTION 302 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS. SARA SECTION 313 CHEMICALS: CAS# CHEMICAL NAME RANGE 107-21-1 ETHYLENE GLYCOL 2.0 -5.0*CALIFORNIA REGULATORY INFORMATION: CALIFORNIA SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT (PROPOSITION 65)CHEMICALS PRESENT: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS MICHIGAN REGULATORY INFORMATION: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS 16 OTHER INFORMATION Page 7 of 7 NFPA/HMIS HEALTH I FIRE 1 REACTIVITY 0 SPECIAL NONE (1) PROTECTIVE EQUIPMENT B (1) REFER TO SECTION 8 OF MSDS RECOMMENDATIONS. CHANGE LOG: CODE TRANSLATION SLIGHT HAZARD SLIGHT HAZARD MINIMAL HAZARD NO SPECIAL HAZARD GOGGLES, GLOVES FOR ADDITIONAL PROTECTIVE EQUIPMENT MSDS STATUS EFFECTIVE DATE 10-OCT-1997 30-JUL-1998 01-0JUN-2001 REVISIONS TO SECTION 2 15 SUPERCEDES NEW 10-OCT-1997 30-JUL-1998 Copyright@ 1999-2009 Dolphih Software, ftc.Comply Plus Web -Hosted FPL Energy http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=980&ShowTOC= &ShowHazardRatings=1 &... 6/17/2009 SPECTRUS NXII07 by GE BETZ SARA SECTION 302 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS. SARA SECTION 313 CHEMICALS: CAS # CHEMICAL NAME RANGE 107-21-1 ETHYLENE GLYCOL 2.0 -5.0t CALIFORNIA RSGULATORY CALIFORNIA SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT (PROPOSITION

65) CHEMICALS PRESENT: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS MICHIGAN REGULATORY INFORMATION:

NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS 16 OTHER INFORMATION NFPA/HMIS HEALTH FIRE REACTIVITY 1 1 o CODE SLIGHT HAZARD SLIGHT HAZAlW MINIMAL HAUJill SPB.:CIAL NONE NO SPECIAL HAZARD (1) PROTECTIVE EQUIPMENT B GOGGLES, GLOVES (1) REFER TO SECTION 8 OF MSDS FOR ADDITIONAL PROTECTIVE EQUIPMENT RECoMMENDATIONS. CHlINGE LOG: EFFECTIVE DATE REVISIONS TO SECTION SUl'ERCEDES MSDS STATUS lO-OCT-1997 30-JUL-1998 01-JUN-2001 2 15 NEW lO-OCT-1997 30-JUL-1998 Copyrighf@ 1999-2009 Dolphin Software, (nc. Comply Plus Web* Hosted FPL Energy Page 70f7 http://fplenergy.complyplus.comlMSDS/print_ bare.asp?S=980&ShowTOC=1 &ShowHazardRatings=l &... 6/1712009 CORRSHIELD MD4100 by BETZ DEARBORN Page 1 of 7 FPL Energy Duane Arnold CORRSHIELD MD4100 BETZ DEARBORN FileName Language Internal ID Revision Date 000516 0088 1/3/2002 Table Of Contents 1 PRODUCT IDENTIFICATION 2 COMPOSITION / INFORMATION ON INGREDIENTS 3 HAZARDS IDENTIFICATION 4 FIRST AID MEASURES 5 FIRE FIGHTING MEASURES 6 ACCIDENTAL RELEASE MEASURES 7 HANDLING & STORAGE 8 EXPOSURE CONTROLS / PERSONAL PROTECTION 9 PHYSICAL & CHEMICAL PROPERTIES 10 STABILITY & REACTIVITY11 TOXICOLOGICAL INFORMATION 12 ECOLOGICAL INFORMATION 13 DISPOSAL CONSIDERATIONS 14 TRANSPORT INFORMATION 15 REGULATORY INFORMATION 16 OTHER INFORMATION Hazards MSDS State NFPA HMIS (Active)Health 2 2 Flammability 0 0 Reactivity 0 0 Other AL B ISSUE DATE: 03-JAN-2002 MATERIAL SAFETY DATA SHEET BETZDEARBORN, DIVISION OF HERCULES INCORPORATED 4636 SOMERTON ROAD TREVOSE, PA 19053 BUSINESS TELEPHONE: (215) 355-3300 EMERGENCY TELEPHONE (HEALTH/ACCIDENT): (800) 877-1940 (USA)HMIS RATINGS: HEALTH 2 FLAMMABILITY 0 REACTIVITY 0(SEE SECTION 16 FOR ADDITIONAL INFORMATION) 1 PRODUCT IDENTIFICATION PRODUCT NAME: CORRSHIELD MD4100 PRODUCT APPLICATION AREA: WATER-BASED CORROSION INHIBITOR. http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=365&ShowTOC=1&ShowHazardRatings=l&... 6/17/2009 CORRSHIELD MD41 00 by BETZ DEARBORN FPL Energy Duane Arnold CORRSHIELD MD4100 FileName Language Internal 10 000516 -0088 Table Of Contents 1 PRODUCT IDENTIFICATION 2 COMPOSITION / INfORMATION ON INGREDIENTS 3 HAZARDS IDENTIfICATION 4 fIRST AID MEASURES 5 FIRE fIGHTING MEASURES 6 ACCIDENTAL RELEASE MEASURES 7 HAN DUNG & STORAGE 8 EXPOSURE CONTROLS f PERSONAL PROTECTION 9 PHYSICAL & CHEMICAL PROPERTIES 10 STABIUTY & REACTIVITY 11 TOXICOLOGICAL INfORMATION 12 ECOLOGICAL INFORMATION 13 DISPOSAL CONSIDERATIONS 14 TRANSPORT INFORMATION 15 REGULATORY INFORMATION 16 OTHER INFORMATION Hazards MSDSState NFPA HMIS I Health 2 2 Flammability 0 0 Reactivity 0 0 Other AL B ISSUE DATE: 03-JAN-2002 MATERIAL SAFETY DATA SHEET BETZDEARBORN, DIVISION OF HERCULES INCORPORATED 4636 SOMERTON ROAD TREVOSE, PA 19053 BUSINESS TELEPHONE: (215) 355-3300 EMERGENCY TELEPHONE (HEALTH/ACCIDENT): (800) 877-1940 (USA) HMIS RATINGS: HEALTH 2 FLAMMABILITY 0 REACTIVITY 0 (SEE SECTION 16 FOR ADDITIONAL INFORMATION) 1 PRODUCT IDENTIFICATION PRODUCT NAME: CORRSHIELD MD4100 PRODUCT APPLICATION ARRA: WATER-BASED CORROSION INHIBITOR. Page 1 of7 BETZ DEARBORN Revision Date 1/3/2002 (Active) I http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=3 65&ShowTOC= 1 &ShowHazardRatings= 1 &... 6/17/2009 CORRSHIELD MD4100 by BETZ DEARBORN Page 2 of 7 2 COMPOSITION / INFORMATION ON INGREDIENTS INFORMATION FOR SPECIFIC PRODUCT INGREDIENTS AS REQUIRED BY THE U.S. OSHA HAZARD COMMUNICATION STANDARD IS LISTED. REFER TO ADDITIONAL SECTIONS OF THIS MSDS FOR OUR ASSESSMENT OF THE POTENTIAL HAZARDS OF THIS FORMULATION. HAZARDOUS INGREDIENTS: CAS # CHEMICAL NAME 7631-95-0 SODIUM MOLYBDATE (MOLYBDIC ACID, DISODIUM SALT)POTENTIAL IRRITANT (RESPIRATORY); POTENTIAL LUNG TOXICITY 7632-00-0 SODIUM NITRITE OXIDIZER; TOXIC (BY INGESTION); POTENTIAL BLOOD TOXIN NO COMPONENT IS CONSIDERED TO BE A CARCINOGEN BY THE NATIONAL TOXICOLOGY PROGRAM, THE INTERNATIONAL AGENCY FOR RESEARCH ON CANCER, OR THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION AT OSHA THRESHOLDS FOR CARCINOGENS. 3 HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: WARNING MAY CAUSE SLIGHT IRRITATION TO THE SKIN. SEVERE IRRITANT TO THE EYES.MISTS/AEROSOLS MAY CAUSE IRRITATION TO UPPER RESPIRATORY TRACT.DOT HAZARD: CORROSIVE TO ALUMINUM, RQ EMERGENCY RESPONSE GUIDE #: 154 ODOR: MILD APPEARANCE: YELLOW, LIQUID FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE).PROPER FIRE-EXTINGUISHING MEDIA: FLOOD WITH WATER. USE OF C02 OR FOAM MAY NOT BE EFFECTIVE. POTENTIAL HEALTH EFFECTS: ACUTE SKIN EFFECTS: PRIMARY ROUTE OF EXPOSURE; MAY CAUSE SLIGHT IRRITATION TO THE SKIN.ACUTE EYE EFFECTS: SEVERE IRRITANT TO THE EYES.ACUTE RESPIRATORY EFFECTS: MISTS/AEROSOLS MAY CAUSE IRRITATION TO UPPER RESPIRATORY TRACT.http ://fplenergy.complyplus.com/MSDS/print-bare.asp?S=365&ShowTOC= 1 &ShowHazardRatings= 1 &... 6/17/2009 CORRSHIELD MD41 00 by BETZ DEARBORN 2 COMPOSITION / INFORMATION ON INGREDIENTS INFORMATION FOR SPECIFIC PRODUCT INGREDIENTS AS REQUIRED BY THE U.S. OSHA .. HAZARD COMMUNICATION STANDARD IS LISTED. REFER TO ADDITIONAL SECTIONS OF THIS MSDS FOR OUR ASSESSMENT OF THE POTENTIAL HAZARDS OF THIS FORMULATION. HAZARDOUS INGREDIENTS: CAS # CHEMICAL NAME 7631-95-0 SODIUM MOLYBDATE (MOLYBDIC ACID, DISODIUM SALT) POTENTIAL IRRITANT (RESPIRATORY); POTENTIAL LUNG TOXICITY 7632-00-0 SODIUM NITRITE OXIDIZER; TOXIC (BY INGESTION); POTENTIAL BLOOD TOXIN NO COMPONENT IS CONSIDERED TO BE A CARCINOGEN BY THE NATIONAL TOXICOLOGY PROGRAM, THE INTERNATIONAL AGENCY FOR RESEARCH ON CANCER, OR THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION AT OSHA THRESHOLDS FOR CARCINOGENS. 3 HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: WARNING MAY CAUSE SLIGHT IRRITATION TO THE SKIN. SEVERE IRRITANT TO THE EYES. MISTS/AEROSOLS MAY CAUSE IRRITATION TO UPPER RESPIRATORY TRACT. DOT HAZARD: CORROSIVE TO ALUMINUM, RQ EMERGENCY RESPONSE GUIDE

1. 154 ODOR: MILD APPEARANCE:

YELLOW, LIQUID FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE) . PROPER FIRE-EXTINGUISHING MEDIA: FLOOD WITH WATER. USE OF C02 OR FOAM MAY NOT BE EFFECTIVE. POTENTIAL HEALTH EFFECTS: ACUTE SKIN EFFECTS: PRIMARY ROUTE OF EXPOSURE; MAY CAUSE SLIGHT IRRITATION TO THE SKIN. ACUTE EYE EFFECTS: SEVERE IRRITANT TO THE EYES. ACUTE RESPIRATORY EFFECTS: MISTS/AEROSOLS MAY CAUSE IRRITATION TO UPPER RESPIRATORY TRACT. Page 2 of7 http://fplenergy.complypius.comIMSDS/print _ bare.asp?S=365&ShowTOC= 1 &ShowHazardRatings= 1 &... 6/17/2009 CORRSHIELD MD4100 by BETZ DEARBORN Page 3 of 7 INGESTION EFFECTS: MAY CAUSE SLIGHT GASTROINTESTINAL IRRITATION. TARGET ORGANS: PROLONGED OR REPEATED EXPOSURES MAY CAUSE TOXICITY TO THE BLOOD AND/OR LUNG.MEDICAL CONDITIONS AGGRAVATED: NOT KNOWN.SYMPTOMS OF EXPOSURE: MAY CAUSE REDNESS OR ITCHING OF SKIN.4 FIRST AID MEASURES SKIN CONTACT: WASH THOROUGHLY WITH SOAP AND WATER. REMOVE CONTAMINATED CLOTHING. GET MEDICAL ATTENTION IF IRRITATION DEVELOPS OR PERSISTS.EYE CONTACT: REMOVE CONTACT LENSES. HOLD EYELIDS APART. IMMEDIATELY FLUSH EYES WITH PLENTY OF LOW-PRESSURE WATER FOR AT LEAST 15 MINUTES. GET IMMEDIATE MEDICAL ATTENTION. INHALATION:IF NASAL, THROAT OR LUNG IRRITATION DEVELOPS -REMOVE TO FRESH AIR AND GET MEDICAL ATTENTION. INGESTION: DO. NOT FEED ANYTHING BY MOUTH TO AN UNCONSCIOUS OR CONVULSIVE VICTIM. DO NOT INDUCE VOMITING. IMMEDIATELY CONTACT PHYSICIAN. DILUTE CONTENTS OF STOMACH USING 3-4 GLASSES MILK OR WATER.NOTES TO PHYSICIANS: NO SPECIAL INSTRUCTIONS 5 FIRE FIGHTING MEASURES FIRE FIGHTING INSTRUCTIONS: FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE).EXTINGUISHING MEDIA:FLOOD WITH WATER. USE OF C02 OR FOAM MAY NOT BE EFFECTIVE. HAZARDOUS DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES.FLASH POINT: 200F 93C SETA(CC)MISCELLANEOUS: CORROSIVE TO ALUMINUM, RQ UN3266; EMERGENCY RESPONSE GUIDE #154 6 ACCIDENTAL RELEASE MEASURES http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=365&ShowTOC= 1 &ShowHazardRatings= 1 &... 6/17/2009 CORRSHIELD MD41 00 by BETZ DEARBORN INGESTION EFFECTS: MAY CAUSE SLIGHT GASTROINTESTINAL IRRITATION. TARGET ORGANS: PROLONGED OR REPEATED EXPOSURES MAY CAOSE TOXICITY TO THE BLOOD AND/OR LUNG. MEDICAL CONDITIONS AGGRAVATED: NOT KNOWN. SYMPTOMS OF EXPOSURE: MAY CAUSE REDNESS OR ITCHING OF SKIN. 4 FIRST AID MEASURES SKIN CONTACT: WASH THOROUGHLY WITH SOAP AND WATER. REMOVE CONTAMINATED CLOTHING. GET MEDICAL ATTENTION IF IRRITATION DEVELOPS OR PERSISTS. EYE CONTACT: REMOVE CONTACT LENSES. HOLD EYELIDS APART. IMMEDIATELY FLUSH EYES WITH PLENTY OF LOW-PRESSURE WATER FOR AT LEAST 15 MINUTES. GET IMMEDIATE MEDICAL ATTENTION. INf!A.LATION: IF NASAL, THROAT OR LUNG IRRITATION DEVELOPS -REMOVE TO FRESH AIR AND GET MEDICAL ATTENTION. INGESTION: DO NOT FEED ANYTHING BY MOUTH TO AN UNCONSCIOUS OR CONVULSIVE VICTIM. DO NOT INDUCE VOMITING. IMMEDIATELY CONTACT PHYSICIAN. DILOTE CONTENTS OF STOMACH USING 3-4 GLASSES MILK OR WATER. NOTES TO PHYSICIANS: NO SPECIAL INSTRUCTIONS 5 FIRE FIGHTING MEASURES FIRE FIGHTING INSTRUCTIONS: FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE) . EXTINGUISHING MEDIA: FLOOD WITH WATER. OSE OF C02 OR FOAM MAY NOT BE EFFECTIVE. HAZARDOUS DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES. FLASH POINT: 200F 93C SETA (CC) MISCELLANEOUS: CORROSIVE TO ALUMINUM, RQ UN3266; EMERGENCY RESPONSE GUIDE #154 6 ACCIDENTAL RELEASE MEASURES Page 3 of7 http://fplenergy.complyplus.comIMSDS/print _ bare.asp?S=365&ShowTOC= 1 &ShowHazardRatings= 1 &... 6/17/2009 CORRSHIELD MD41 00 by BETZ DEARBORN Page 4 of 7 PROTECTION AND SPILL CONTAINMENT: VENTILATE AREA. USE SPECIFIED PROTECTIVE EQUIPMENT. CONTAIN AND ABSORB ON ABSORBENT MATERIAL. PLACE IN WASTE DISPOSAL CONTAINER. FLUSH AREA WITH WATER.WET AREA MAY BE SLIPPERY. SPREAD SAND/GRIT. DISPOSAL INSTRUCTIONS: WATER CONTAMINATED WITH THIS PRODUCT MAY BE SENT TO A SANITARY SEWER TREATMENTFACILITY, IN ACCORDANCE WITH ANY LOCAL AGREEMENT, A PERMITTED WASTE TREATMENT FACILITY OR DISCHARGED UNDER A PERMIT. PRODUCT AS IS -INCINERATE OR LAND DISPOSE IN AN APPROVED LANDFILL.7 HANDLING & STORAGE HANDLING: CONTAINS AN OXIDIZER. AVOID ALL CONTACT WITH REDUCING AGENTS, OILS, GREASES, ORGANICS AND ACIDS. DO NOT ALLOW TO DRY.STORAGE: KEEP CONTAINERS CLOSED WHEN NOT IN USE. DO NOT FREEZE. IF FROZEN, THAW AND MIX COMPLETELY PRIOR TO USE.B EXPOSURE CONTROLS / PERSONAL PROTECTION CHEMICAL NAME EXPOSURE LIMITS SODIUM MOLYBDATE PEL (OSHA): S MG/M3 (AS MO)(MOLYBDIC ACID, DISODIUM SALT) TLV (ACGIH): 0.5 MG/M3 (AS Mo) RESPIRABLE FRACTION SODIUM NITRITE PEL (OSHA): NOT DETERMINED TLV (ACGIH): NOT DETERMINED ENGINEERING CONTROLS: ADEQUATE VENTILATION TO MAINTAIN AIR CONTAMINANTS BELOW EXPOSURE LIMITS.PERSONAL PROTECTIVE EQUIPMENT: USE PROTECTIVE EQUIPMENT IN ACCORDANCE WITH 29CFR 1910 SUBPART I RESPIRATORY PROTECTION: A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CFR 1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE.USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS. IF AIR-PURIFYING RESPIRATOR USE IS APPROPRIATE, USE A RESPIRATOR WITH DUST/MIST FILTERS.SKIN PROTECTION: NEOPRENE GLOVES -WASH OFF AFTER EACH USE. REPLACE AS NECESSARY. EYE PROTECTION: SPLASH PROOF CHEMICAL GOGGLES http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=365&ShowTOC=l &ShowHazardRatings=I &... 6/17/2009 CORRSHIELD MD41 00 by BETZ DEARBORN PROTECTION AND SPILL CONTAINMENT, VENTILATE AREA. USE SPECIFIED PROTECTIVE EQUIPMENT. CONTAIN AND ABSORB ON ABSORBENT MATERIAL. PLACE IN WASTE DISPOSAL CONTAINER. FLUSH AREA WITH WATER. WET AREA MAY BE SLIPPERY. SPREAD SAND/GRIT. DISPOSAL INSTRUCTIONS, WATER CONTAMINATED WITH THIS PRODUCT MAY BE SENT TO A SANITARY SEWER TREATMENT FACILITY, IN ACCORDANCE WITH ANY LOCAL AGRESMENT, A PERMITTED WASTE TREATMENT FACILITY OR DISCHARGED UNDER A PERMIT. PRODUCT AS IS -INCINERATE OR LAND DISPOSE IN AN APPROVED LANDFILL. 7 HANDLING & STORAGE HANDLING, CONTAINS AN OXIDIZER. AVOID ALL CONTACT WITH REDUCING AGENTS, OILS, GREASES, ORGANICS AND ACIDS. DO NOT ALLOW TO DRY. STORAGE, KEEP CONTAINERS CLOSED WHEN NOT IN USE. DO NOT FREEZE. IF FROZEN, THAW AND MIX COMPLETELY PRIOR TO USE. 8 EXPOSURE CONTROLS / PERSONAL PROTECTION CHSMlCAL NAME SODIUM MOLYBDATE (MOLYBDIC ACID, DISODIUM SALT) SODIUM NITRITE ENGINEERING CONTROLS, EXPOSURE LIMITS PEL (OSHA), 5 MG/M3 (AS MO) TLV (ACGIH): 0.5 MG/M3 (AS Mo) RESPIRABLE FRACTION PEL (OSHA): NOT DETERMINED TLV (ACGIH): NOT DETERMINED ADEQUATE VENTILATION TO MAINTAIN AIR CONTAMINANTS BELOW EXPOSURE LIMITS. PERSONAL PROTECTIVE EQUIPMENT: USE PROTECTIVE EQUIPMENT IN ACCORDANCE WITH 29CFR 1910 SUBPART I RESPIRATORY PROTECTION: A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CFR 1910.134 AND ANSI Z88.2 REQUIRSMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE. USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS. IF AIR-PURIFYING RESPIRATOR USE IS APPROPRIATE, USE A RESPIRATOR WITH DUST/MIST FILTERS. SKIN PROTECTION, NEOPRENe GLOVES -WASH OFF AFTER EACH OSE. REPLACE AS NECESSARY. EYE PROTECTION: SPLASH PROOF CHEMICAL GOGGLES Page 4 of? http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=365&ShowTOO= 1 &ShowHazardRatings= 1 &... 6/17/2009 CORRSHIELD MD4 100 by BETZ DEARBORN Page 5 of 7 9 PHYSICAL & CHEMICAL PROPERTIES SPECIFIC GRAV. (70F,22C): 1.184 VAPOR PRESSURE (MMHg): APPROX. 18.0 FREEZE POINT (F): 14 VAPOR DENSITY (AIR = 1): <1.00 FREEZE POINT (C): -10 VISCOSITY (CPS 70F, 21C)- 4%k SOLUBILITY (WATER): 100.0 ODOR: MILD APPEARANCE: YELLOW PHYSICAL STATE: LIQUID FLASH POINT SETA(CC): 200F 93C pH AS IS (APPROX.): 12.8 EVAPORATION RATE (ETHER = 1): <1.00 NA = NOT APPLICABLE ND -NOT DETERMINED 10 STABILITY & REACTIVITY STABILITY: STABLE UNDER NORMAL STORAGE CONDITIONS. HAZARDOUS POLYMERIZATION: WILL NOT OCCUR.INCOMPATIBILITIES: MAY REACT WITH STRONG REDUCING AGENTS.DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES.BETZDEARBORN INTERNAL PUMPOUT/CLEANOUT CATEGORIES: "B" 11 TOXICOLOGICAL INFORMATION ORAL LD50 RAT: 825 MG/KG NOTE: ESTIMATED VALUE DERMAL LD50 RABBIT: 2,000 MG/KG NOTE: ESTIMATED VALUE 12 ECOLOGICAL INFORMATION http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=365&ShowTOC= &ShowHazardRatings= 1 &... 6/17/2009 CORRSHIELD MD4100 by BETZ DEARBORN 9 PHYSICAL & CHEMICAL PROPERTIES SPECIFIC GRAV. (70F,21C): 1.184 VAPOR PRESSURE (MMHg): APPROX. 18.0 FREEZE POINT (F): 14 VAPOR DENSITY (AIR = 1): FREEZE POINT (C): -10 VISCOSITY (CPS 70F, 21C): 4 % SOLUBILITY (WATER): 100.0 OOOR: MILD APPEARANCE: YELLOW PHYSICAL STATE: LIQUID FLASH POINT SETA (CC) : 200F 93C pH AS IS (APPROX.): 12.8 EVAPORATION RATE (ETHER = 1): NA = NOT APPLICABLE ND NOT DETERMINED 10 STABILITY & REACTIVITY STABILITY: STABLE ONDER NORMAL STORAGE CONDITIONS. HAZARDOUS POLYMERIZATION: WILL NOT OCCUR. INCOMPATIBILITIES:* MAY REACT WITH STRONG REDOCING AGENTS. DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES. BETZDEARBORN INTERNAL PUMPOUT/CLEANOUT CATEGORIES: nBn 11 TOXICOLOGICAL INFORMATION ORAL LD50 RAT: 825 MG/KG NOTE: ESTIMATED VALUE DERMAL LD50 RABBIT: 2,000 MG/KG NOTE: ESTIMATED VALUE 12 ECOLOGICAL rNFORMATION Page 5 of7 http://fplenergy.complyplus.comIMSDS/print_ bare.asp7S=365&ShowTOC= 1 &ShowHazardRatings=l &... 6117/2009 CORRSHIELD MD4100 by BETZ DEARBORN Page 6 of 7 AQUATIC TOXICOLOGY: BLUEGILL SUNFISH 96 HOUR STATIC ACUTE BIOASSAY: LC50: 3258 NO EFFECT LEVEL: 1800 MG/L DAPHNIA MAGNA 48 HOUR STATIC ACUTE BIOASSAY: LC50: 5997 NO EFFECT LEVEL: 500 MG/L FATHEAD MINNOW 96 HOUR ACUTE TOXICITY (ESTIMATED): LC50: 2730 NO EFFECT LEVEL: 1850 MG/L RAINBOW TROUT 48 HOUR STATIC SCREEN: 0% MORTALITY: 2000 MG/L BIODEGRADATION: BOD-28 (MG/G): 1 BOD-5 (MG/G).: 0 COD (MG/G) : 39 TOC (MG/G) : 6 13 DISPOSAL CONSIDERATIONS IF THIS UNDILUTED PRODUCT IS DISCARDED AS A WASTE, THE US RCRA HAZARDOUS WASTE IDENTIFICATION NUMBER IS: D002=CORROSIVE(pH). PLEASE BE ADVISED; HOWEVER, THAT STATE AND LOCAL REQUIREMENTS FOR WASTE DISPOSAL MAY BE MORE RESTRICTIVE OR OTHERWISE DIFFERENT FROM FEDERAL REGULATIONS. CONSULT STATE AND LOCAL REGULATIONS REGARDING THE PROPER DISPOSAL OF THIS MATERIAL.14 TRANSPORT INFORMATION DOT HAZARD: CORROSIVE TO ALUMINUM, RQ UN / NA NUMBER: UN3266 DOT EMERGENCY RESPONSE GUIDE #: 154 15 REGULATORY INFORMATION TSCA: ALL COMPONENTS OF THIS PRODUCT ARE LISTED IN THE TSCA INVENTORY. CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ): 101 GALLONS DUE TO SODIUM NITRITE;FOOD AND DRUG ADMINISTRATION: NO FDA APPROVAL FOR PAPER OR PAPERBOARD HAVING FOOD CONTACT.http://fplenergy.complyplus.com/MSDS/printbare.asp?S=365&ShowTOC= 1 &ShowHazardRatings= 1 &... 6/17/2009 CORRSHIELD MD41 00 by BETZ DEARBORN AQUATIC TOXICOLOGY: BLUEGILL SUNFISH 96 HOUR STATIC ACUTE BIOASSAY: LC50: 3258 NO EFFECT LEVEL: 1800 MG/L DAPHNIA MAGNA 48 HOUR STATIC ACUTE BIOASSAY: LC50: 5997 NO EFFECT LEVEL: SOO MG/L FATHEAD MINNOW 96 HOUR ACUTE TOXICITY (ESTIMATED): LC50: 2730 NO EFFECT LEVSL: 1850 MG/L RAINBOW TROUT 48 HOUR STATIC SCREEN: 0% MORTALITY: 2000 MG/L BIODEGRADATION: BOD-28 (MG/G): 1 BOD-5 (MG/G): 0 COD (MG/G): 39 TOC (MG/G): 6 13 DISPOSAL CONSIDERATIONS IF THIS UNDILUTED PRODUCT IS DISCARDED AS A WASTE I THE US RCRA HAZARDOUS WASTE IDENTIFICATION NUMBER IS: D002=CORROSIVE(pH). PLEASE BE ADVISED; HOWEVER, THAT STATE AND LOCAL REQUIREMENTS FOR WASTE DISPOSAL MAY BE MORE RESTRICTIVE OR OTHERWISE DIFFERENT FROM FEDERAL REGULATIONS. CONSULT STATE AND LOCAL REGULATIONS REGARDING THE PROPER DISPOSAL OF THIS MATERIAL. 14 TRANSPORT INFORMATION DOT HAZARD: CORROSIVE TO ALUMINUM, RQ UN / NA NUMBER: UN3266 DOT EMERGENCY RESPONSE GUIDE M: 154 15 REGULATORY INFORMATION TSCA: ALL COMPONENTS OF THIS PRODUCT ARE LISTED IN THE TSCA INVENTORY. CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ): 101 GALLONS DUE TO SODIUM NITRITE; FOOD AND DRUG ADMINISTRATION: NO FDA APPROVAL FOR PAPER OR PAPERBOARD HAVING FOOD CONTACT. Page 6 of7 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=365&ShowTOC=1 &ShowHazardRatings= 1 &... 6/17/2009 CORRSHIELD MD4100 by BETZ DEARBORN USDA FEDERALLY INSPECTED MEAT AND POULTRY PLANTS: SEC. G5 SARA SECTION 312 HAZARD CLASS: IMMEDIATE (ACUTE)DELAYED (CHRONIC)SARA SECTION 302 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS SARA SECTION 313 CHEMICALS: CAS# CHEMICAL NAME RANGE 7632-00-0 SODIUM NITRITE 6.0-10.0%CALIFORNIA REGULATORY INFORMATION: CALIFORNIA SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT (PROPOSITION 65)CHEMICALS PRESENT: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS MICHIGAN REGULATORY INFORMATION: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS Page 7 of 7 16 OTHER INFORMATION NFPA/HMIS CODE TRANSLATION HEALTH 2 MODERATE HAZARD FIRE 0 MINIMAL HAZARD REACTIVITY 0 MINIMAL HAZARD SPECIAL ALK PH ABOVE 12.0 (1) PROTECTIVE EQUIPMENT B GOGGLES, GLOVES (1) REFER TO SECTION 8 OF MSDS FOR ADDITIONAL RECOMMENDATIONS.CHANGE LOG: PROTECTIVE EQUIPMENT MSDS STATUS: EFFECTIVE DATE 28-JAN-1997 12-MAY-1997 27-OCT-1998 08-FEB-2000 06-APR-2001 09-AUG-2001 17-SEP-2001 03-JAN-2002 REVISIONS TO SECTION 15 3,5,14 15 4 4,16 8,10 2,3,8 SUPERCEDES NEW 28-JAN-1997 12-MAY- 1997 27-OCT- 1998 08-FEB-2000 06 -APR-2001 09-AUG-2001 17-SEP-2001 Copyright@ 1999-2009 Dolphin Software, Inc, Comply Plus Web -Hosted FPL Energy http://fplenergy.complyplus.com/MSDS/print bare.asp?S=365&ShowTOC=1 &ShowHazardRatings= &... 6/17/2009 CORRSHIELD MD4100 by BETZ DEARBORN USDA FEDERALLY INSPECTED MEAT AND POULTRY PLANTS: SEC. G5 SARA SECTION 312 HAZARD CLASS: IMMEDIATE (ACUTE) DELAYED (CHRONIC) SARA SECTION 302 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS SARA SECTION 313 CHEMICALS: CAS # CHEMICAL NAME RANGE 7632-00-0 SODIUM NITRITE 6.0-10.0% CALIFORNIA REGULATORY INFORMATION: CALIFORNIA SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT (PROPOSITION

65) CHEMICALS PRESENT: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS MICHIGAN REGULATORY INFORMATION:

NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS 16 OTHER INFORMATION NFPA/HMIS HEALTH FIRE REACTIVITY CODE TRANSLATION 2 MODERATE HAZARD o MINIMAL HAZARD o MINIMAL HAZARD SPECIAL ALK pH ABOVE 12.0 (1) PROTECTIVE EQUIPMENT B GOGGLES, GLOVES (1) REFER TO SECTION 8 OF MSDS FOR ADDITIONAL PROTECTIVE EQUIPMENT RECOMMENDATIONS. CHANGE LOG: EFFECTIVE DATE MSDS STATUS: 28-JAN-1997 12-MAY-1997 27'OCT-1998 08-FEB-2000 06-APR-2001 09-AUG-2001 17-SEP-2001 03-JAN-2002 REVISIONS TO SECTION SUPERCEDES NEW 15 28-JAN-1997 3,5,14 12-MAY-1997 15 27-0CT-1998 4 08-FEB-2000 4,16 06-APR-2001 8,10 09-AUG-2001 2,3,8 17-SEP-2001 Copyr/ght© 1999-2009 Dolphin Software, Inc, Comply Plus Web -Hosted FPL Energy Page 7 of7 http://fplenergy.complyplus.comIMSDS/print_bare.asp?S=365&ShowTOC=l&ShowHazardRatings=l&... 6/17/2009 SPECTRUS NX 1105 by GE BETZ Page 1 of 8 FPL Energy Duane Arnold SPECTRUS NX1105 GE BETZ FileName Language Internal ID Revision Date 004149 0937 8/22/2001 Table Of Contents I PRODUCT IDENTIFICATION 2 COMPOSITION / INFORMATION ON INGREDIENTS 3 HAZARDS IDENTIFICATION 4 FIRST AID MEASURES 5 FIRE FIGHTING MEASURES 6 ACCIDENTAL RELEASE MEASURES 7 HANDLING & STORAGE8 EXPOSURE CONTROLS / PERSONAL PROTECTION 9 PHYSICAL & CHEMICAL PROPERTIES 10 STABILITY & REACTIVITY 11 TOXICOLOGICAL INFORMATION 12 ECOLOGICAL INFORMATION 13 DISPOSAL CONSIDERATIONS 14 TRANSPORT INFORMATION 15 REGULATORY INFORMATION 16 OTHER INFORMATION Hazards MSDS State NFPA HMIS (Active)Health 3 3 Flammability 1 1 Reactivity 0 0 Other CO X GE BETZ, INC.4636 SOMERTON ROAD TREVOSE, PA 19053 BUSINESS TELEPHONE: (215) 355-3300 EMERGENCY TELEPHONE (HEALTH/ACCIDENT): (800) 877-1940 MATERIAL SAFETY DATA SHEET ISSUE DATE: 22-AUG-2001 1 PRODUCT IDENTIFICATION PRODUCT NAME: SPECTRUS NX1105 PRODUCT APPLICATION AREA: WATER-BASED MICROBIAL CONTROL AGENT.2 COMPOSITION / INFORMATION ON INGREDIENTS INFORMATION FOR SPECIFIC PRODUCT INGREDIENTS AS REQUIRED BY THE U.S. OSHA HAZARD COMMUNICATION STANDARD IS LISTED. REFER TO ADDITIONAL SECTIONS OF http://fplenergy~complyplus-com/MSDS/print-bare-asp?S=979&ShowTOC= 1 &ShowHazardRatings= &... 6/17/2009 SPECTRUS NXl105 by GE BETZ FPL Energy Duane Arnold SPECTRUS NX1105 FileName Language Internal 10 004149 0937 Table Of Contents 1 PRODUCf IDENTIFICATION 2 COMPOSITION / INFORMATION ON INGREDIENTS 3 HAZARDS IDENTIFICATION 4 F1RST A1D MEASURES 5 FIRE FIGHTING MEASURES 6 ACCIDENTAL RELEASE MEASURES 7 HANDLING & STORAGE 8 EXPOSURE CONTROLS / PERSONAL PROTECfION 9 PHYSICAL & CHEMICAL PROPERTIES 10 STABIUTY & REACTIVITY 11 TOXICOLOGICAL INFORMATION 12 ECOLOGICAL INFORMATION 13 DISPOSAL CONSIDERATIONS 14 TRANSPORT INFORMATION 15 REGULATORY INFORMATION 16 OTHER INFORMATION Hazards Health Flammability Reactivity Other GE BETZ, INC. 4636 SOMERTON ROAD TREVOSE, PA 19053 NFPA 3 1 0 CO BUSINESS TELEPHONE: (215) 355-3300 HMIS 3 1 0 X MSOSState I EMERGENCY TELEPHONE (HEALTH/ACCIDENT): (800) 877-1940 MATERIAL SAFETY DATA SHEET ISSUE DATE: 22-AUG-2001 1 PRODUCT IDENTIFICATION PRODUCT NAME: SPECTRDS NXII05 PRODUCT APPLICATION AREA: WATER-BASED MICROBIAL CONTROL AGENT. 2 COMPOSITION / INFORMATION ON INGREDIENTS (Active) INFORMATION FOR SPECIFIC PRODUCT INGREDIENTS AS REQUIRED BY THE U.S. OSHA HAZARD COMMUNl:CATION STANDARD IS LISTED. REFER TO ADDITIONAL SECTIONS OF Page 1 of8 GE BETZ Revision Date 8/22/2001 I http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=979&ShowTOC= 1 &ShowHazardRatings= 1 &... 6/17/2009 SPECTRUS NX 1105 by GE BETZ Page 2 of 8 THIS MSDS FOR OUR ASSESSMENT OF THE POTENTIAL HAZARDS OF THIS FORMULATION. HAZARDOUS INGREDIENTS: CAS #CHEMICAL NAME 111-30-8 GLUTARALDEHYDE TOXIC (BY INGESTION)CORROSIVE (EYES, AND SKIN)POTENTIAL SENSITIZER (SKIN AND RESPIRATORY), ABSORBED BY SKIN NO COMPONENT IS CONSIDERED TO BE A CARCINOGEN BY THE NATIONAL TOXICOLOGY PROGRAM, THE INTERNATIONAL AGENCY FOR RESEARCH ON CANCER, OR THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION AT OSHA THRESHOLDS FOR CARCINOGENS. 3 HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: DANGER: CORROSIVE TO SKIN. ABSORBED BY THE EYES. VAPORS, GASES, MISTS RESPIRATORY TRACT. RESPIRATORY SKIN. POTENTIAL SKIN SENSITIZER. CORROSIVE TO AND/OR AEROSOLS CAUSE IRRITATION TO THE UPPER SENSITIZATION MAY OCCUR.DOT HAZARD: CORROSIVE TO SKIN EMERGENCY RESPONSE GUIDE: #153 ODOR: SLIGHT ACID APPEARANCE: COLORLESS, LIQUID FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE).PROPER FIRE-EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER POTENTIAL HEALTH EFFECTS: ACUTE SKIN EFFECTS: PRIMARY ROUTE OF EXPOSURE; CORROSIVE TO SKIN. ABSORBED BY SKIN. POTENTIAL SKIN SENSITIZER.ACUTE EYE EFFECTS: CORROSIVE TO THE EYES.ACUTE RESPIRATORY EFFECTS:PRIMARY ROUTE OF EXPOSURE; VAPORS, GASES, MISTS AND/OR AEROSOLS CAUSE IRRITATION TO T1HE UPPER RESPIRATORY TRACT. RESPIRATORY SENSITIZATION MAY OCCUR.INGESTION EFFECTS: HIGHLY TOXIC MAY CAUSE SEVERE IRRITATION OR BURNING OF MOUTH, THROAT, AND GASTROINTESTINALTRACT WITH SEVERE CHEST AND ABDOMINAL PAIN, NAUSEA, VOMITING, DIARRHEA, LETHARGY AND COLLAPSE. POSSIBLE DEATH WHEN INGESTED IN VERY LARGE DOSES.TARGET ORGANS: http://fplenergy.complyplus.com/MSDS/print bare.asp?S=979&ShowTOC=I&ShowHazardRatings=l&... 6/17/2009 SPECTRUS NX 1105 by GE BETZ THIS MSDS FOR OUR ASSBSSMENT OF THE POTENTIAL HAZARDS OF THIS FORMULATION. HAZARDOUS INGREDIENTS, CAS # 111-30-8 CHEMICAL NAME GLUTARALDEHYDE TOXIC (BY INGESTION) CORROSIVE (EYES, AND SKIN) POTENTIAL SENSITIZER (SKIN AND RESPIRATORY), ABSORBED BY SKIN NO COMPONENT IS CONSIDERED TO BE A CARCINOGEN BY THE NATIONAL TOXICOLOGY PROGRAM, THE INTERNATIONAL AGENCY FOR RESEARCH ON CANCER, OR THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION AT OSHA THRESHOLDS FOR CARCINOGENS. 3 HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: DANGER: CORROSIVE TO SKIN. ABSORBED BY SKIN. POTENTIAL SKIN SENSITIZER. CORROSIVE TO THE EYES. VAPORS, GASES, MISTS AND/OR AEROSOLS CAUSE IRRITATION TO THE UPPER RESPIRATORY TRACT. RESPIRATORY SENSITIZATION MAY OCCUR. DOT HAZARD: CORROSIVE TO SKIN EMERGENCY RESPONSE GUIDE, #153 ODOR: SLIGHT 'ACID APPEARANCE: COLORLESS, LIQUID FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSORE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE). PROPER FIRE-EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER POTENTIAL HEALTH EFFECTS: ACUTE SKIN EFFECTS: PRIMARY ROUTE OF EXPOSURE; CORROSIVE TO SKIN. ABSORBED BY SKIN. POTENTIAL SKIN SENSITIZER. ACUTE EYE EFFECTS: CORROSIVE TO THE EYES. ACUTE RESPIRATORY EFFECTS: PRIMARY ROUTE OF EXPOSURE; VAPORS, GASES, MISTS AND/OR AEROSOLS CAUSE IRRITATION TO THE UPPER RESPIRATORY TRACT. RESPIRATORY SENSITIZATION MAY OCCUR. INGESTION EFFECTS: HIGHLY TOXIC MAY CAUSE SEVERE IRRITATION OR BURNING OF MOUTH, THROAT, AND GASTROINTESTINAL TRACT WITH SEVERE CHEST AND ABDOMINAL PAIN, NAUSEA, VOMITING, DIARRHEA, LETHARGY AND COLLAPSE. POSSIBLE DEATH WHEN INGESTED IN VERY LARGE DOSES. TARGET ORGANS: Page 2 of8 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=979&ShowTOC= 1 &ShowHazardRatings= 1 &... 6/17/2009 SPECTRUS NX 1105 by GE BETZ Page 3 of 8 PROLONGED OR REPEATED EXPOSURES MAY CAUSE TISSUE NECROSIS, PRIMARY IRRITANT DERMATITIS, SKIN SENSITIZATION, AND/OR ALLERGIC RESPIRATORY REACTIONS. MEDICAL CONDITIONS AGGRAVATED: ASTHMA, ALLERGIES, SKIN DISORDERS, AND CHRONIC RESPIRATORY DISEASE.SYMPTOMS OF EXPOSURE: INHALATION MAY CAUSE EYE, NOSE, THROAT AND LUNG IRRITATION AND POSSIBLE RESPIRATORY SENSITIZATION OR ASTHMA. SKIN CONTACT MAY CAUSE MODERATE IRRITATION TO SEVERE BURNS AND SENSITIZATION. 4 FIRST AID MEASURES SKIN CONTACT: URGENT!WASH THOROUGHLY WITH SOAP AND WATER. REMOVE CONTAMINATED CLOTHING.GET IMMEDIATE MEDICAL ATTENTION. THOROUGHLY WASH CLOTHING BEFORE REUSE. EYE CONTACT: URGENT!IMMEDIATELY FLUSH EYES WITH PLENTY OF LOW-PRESSURE WATER FOR AT LEAST 20 MINUTES WHILE REMOVING CONTACT LENSES. HOLD EYELIDS APART. GET IMMEDIATE MEDICAL ATTENTION. INHALATION: REMOVE TO FRESH AIR. IF BREATHING IS DIFFICULT, GIVE OXYGEN. IF BREATHING HAS STOPPED, GIVE ARTIFICIAL RESPIRATION. GET IMMEDIATE MEDICAL ATTENTION. INGESTION: DO NOT FEED ANYTHING BY MOUTH TO AN UNCONSCIOUS OR CONVULSIVE VICTIM. DO NOT INDUCE VOMITING. IMMEDIATELY CONTACT PHYSICIAN. DILUTE CONTENTS OF STOMACH USING 3-4 GLASSES MILK OR WATER.NOTES TO PHYSICIANS: MATERIAL IS CORROSIVE. IT MAY NOT BE ADVISABLE TO INDUCE VOMITING.POSSIBLE MUCOSAL DAMAGE MAY CONTRAINDICATE THE USE OF GASTRIC LAVAGE.5 FIRE FIGHTING MEASURES FIRE FIGHTING INSTRUCTIONS: FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELP-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE).EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER HAZARDOUS DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES.FLASH POINT:>200F>93C P-M (CC)MISCELLANEOUS: http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=979&ShowTOC=I &ShowHazardRatings=l &... 6/17/2009 SPECTRUS NXII05 by GE BETZ PROLONGED OR REPEATED EXPOSUREs MAY CAUSE TISSUE NECROSIS, PRIMARY IRRITANT DERMATITIS, SKIN SENSITIZATION, AND/OR ALLERGIC RESPIRATORY REACTIONS. MEDICAL CONDITIONs AGGRAVATED: ASTHMA, ALLERGIES, SKIN DISORDERS, AND CHRONIC RESPIRATORY DISEASE. OF EXPOSURE: INHALATION MAY CAUSE EYE, NOSE, THROAT AND LUNG IRRITATION AND POSSIBLE RESPIRATORY SENSITIZATION OR ASTHMA. SKIN CONTACT MAY CAUSE MODERATE IRRITATION TO SEVERE BURNS AND SENSITIZATION. 4 FIRST AID MEASURES SKIN CONTACT: URGENT! WASH THOROUGHLY WITH SOAP AND WATER. REMOVE CONTAMINATED CLOTHING. GET IMMEDIATE MEDICAL ATTENTION. THOROUGHLY WASH CLOTHING BEFORE REUSE. EYE CONTACT: URGENT! IMMEDIATELY FLUSH EYES WITH PLENTY OF LOW-PRESSURE WATER FOR AT LEAST 20 MINUTES WHILE REMoVING CONTACT LENSES. HOLD EYELIDS APART. GET IMMEDIATE MEDICAL ATTENTION. INHALATION: REMOVE TO FRESH AIR. IF BREATHING IS DIFFICULT, GIVE OXYGEN. IF BREATHING HAS STOPPED, GIVE ARTIFICIAL RESPIRATION. GET IMMEDIATE MEDICAL ATTENTION. INGESTION: DO NOT FEED ANYTHING BY MOUTH TO AN UNCONSCIOUS OR CONVULSIVE VICTIM. DO NOT INDUCE VOMITING. IMMEDIATELY CONTACT PHYSICIAN. DILUTE CONTENTS OF STOMACH USING 3-4 GLASSES MILK OR WATER. NOTES TO PHYSICIANS, MATERIAL IS CORROSIVE. IT MAY NOT BE ADVISABLE TO INDUCE VOMITING. POSSIBLE MUCOSAL DAMAGE MAY CONTRAINDICATE THE USE OF GASTRIC LAVAGE. 5 FIRE FIGHTING MEASURES FIRE FIGHTING INSTRUCTIONS: FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELP-CONTAlNED BREATHING APPARATUS (FULL FACE-PIECE TYPE) . EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER HAZARDOUS DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES. FLASH POINT: >200F >93C P-M (CC) MISCELLANEOUS: Page 3 of8 http://fplenergy .complyplus.comJMSDS/print_ bare.asp?S=979&ShowTOC= 1 &ShowHazardRatings= 1&... 6/17/2009 SPECTRUS NXI 105 by GE BETZ Page 4 of 8 CORROSIVE TO SKIN UN3265; EMERGENCY RESPONSE GUIDE #153 6 ACCIDENTAL RELEASE MEASURES PROTECTION AND SPILL CONTAINMENT: VENTILATE AREA. USE SPECIFIED PROTECTIVE EQUIPMENT. CONTAIN AND ABSORB ON ABSORBENT MATERIAL. PLACE IN WASTE DISPOSAL CONTAINER. FLUSH AREA WITH WATER.WET AREA MAY BE SLIPPERY. SPREAD SAND/GRIT. DISPOSAL INSTRUCTIONS: WATER CONTAMINATED WITH THIS PRODUCT MAY BE SENT TO A SANITARY SEWER TREATMENT FACILITY, IN ACCORDANCE WITH ANY LOCAL AGREEMENT, A PERMITTED WASTE TREATMENT FACILITY OR DISCHARGED UNDER A PERMIT. PRODUCT AS IS -DISPOSE OF IN APPROVED PESTICIDE FACILITY OR ACCORDING TO LABEL INSTRUCTIONS. 7 HANDLING & STORAGE HANDLING: ACIDIC. CORROSIVE (SKIN/EYES). DO NOT MIX WITH ALKALINE MATERIAL.STORAGE: KEEP CONTAINERS CLOSED WHEN NOT IN USE. STORE IN COOL VENTILATED LOCATION.STORE AWAY FROM OXIDIZERS. 8 EXPOSURE CONTROLS / PERSONAL PROTECTION EXPOSURE LIMITS: CHEMICAL NAME: GLUTARALDEHYDE: PEL (OSHA): 0.2 PPM (CEILING)TLV (ACGIH): 0.05 PPM (CEILING)MISC: MANUFACTURER'S RECOMMENDED EXPOSURE LIMIT 0.1 PPM (CEILING). ENGINEERING CONTROLS: ADEQUATE VENTILATION TO MAINTAIN AIR CONTAMINANTS BELOW EXPOSURE LIMITS.PERSONAL PROTECTIVE EQUIPMENT:USE PROTECTIVE EQUIPMENT IN ACCORDANCE WITH 29CFR 1920 SUBPART I RESPIRATORY PROTECTION: A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CFR 1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE.USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS. IF AIR-PURIFYING RESPIRATOR USE IS APPROPRIATE, USE A RESPIRATOR WITH ORGANIC VAPOR AND HEPA CARTRIDGES. SKIN PROTECTION: GAUNTLET-TYPE NITRILE GLOVES, CHEMICAL RESISTANT APRON -WASH OFF AFTER EACH USE. REPLACE AS NECESSARY. EYE PROTECTION: SPLASH PROOF CHEMICAL GOGGLES, FACE SHIELD http://fplenergy.complyplus.com/MSDS/printbare.asp?S=979&ShowTOC= I &ShowHazardRatings=l &... 6/17/2009 SPECTRUS NXl105 by GE BETZ CORROSIVE TO SKIN UN3265; EMERGENCY RESPONSE GUIDE #153 6 ACCIDENTAL RELEASE MEASURES PROTECTION AND SPILL CONTAINMENT: VENTILATE AREA. USE SPECIFIED PROTECTIVE EQUIPMENT. CONTAIN AND ABSORB ON ABSORBENT MATERIAL. PLACE IN WASTE DISPOSAL CONTAINER. FLUSH AREA WITH WATER. WET AREA MAY BE SLIPPERY. SPREAD SAND/GRIT. DISPOSAL INSTRUCTIONS: WATER CONTAMINATED WITH THIS PRODUCT MAY BE SENT TO A SANITARY SEWER TREATMENT FACILITY I IN ACCORDANCE WITH ANY LOCAL AGREEMENT, A PERMITTED WASTE TREATMENT FACILITY OR DISCHARGED UNDER A PERMIT. PRODUCT AS IS -DISPOSE OF IN APPROVED PESTICIDE FACILITY OR ACCORDING TO LABEL INSTRUCTIONS. 7 HANDLING & STORAGE HANDLING: ACIDIC. CORROSIVE (SKIN/EYES). DO NOT MIX WITH ALKALINE MATERIAL. STORAGE: KEEP CONTAINERS CLOSED WHEN NOT IN USE. STORE IN COOL VENTILATED LOCATION. STORE AWAY FROM OXIDIZERS. 8 EXPOSURE CONTROLS / PERSONAL PROTECTION EXPOSURE LIMITS: CHEMICAL NAME: GLUTARALDEHYDE: PEL (OSHA): 0.2 PPM (CEILING) TLV (ACGIH): 0.05 PPM (CEILING) MISC: MANUFACTURER'S RECOMMENDED EXPOSURE LIMIT 0.1 PPM (CEILING). ENGINEERING CONTROLS: ADEQUATE VENTILATION TO MAINTAIN AIR CONTAMINANTS BELOW EXPOSURE LIMITS. PERSONAL PROTECTIVE EQUIPMENT: USE PROTECTIVE EQUIPMENT IN ACCORDANCE WITH 29CFR 1910 SUBPART I RESPIRATORY PROTECTION: A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CFR 1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE. USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS. IF AIR-PURIFYING RESPIRATOR USE IS APPROPRIATE, USE A RESPIRATOR WITH ORGANIC VAPOR AND HEPA CARTRIDGES. SKIN PROTECTION: GAUNTLET-TYPE NITRILE GLOVES, CHEMICAL RESISTANT APRON -WASH OFF AFTER EACH USE. REPLACE AS NECESSARY. EYE PROTECTION: SPLASH PROOF CHEMICAL GOGGLES, FACE SHIELD Page 4of8 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S::::979&ShowTOC= 1 &ShowHazardRatings= 1 &... 6117/2009 SPECTRUS NX1105 by GE BETZ Page 5 of 8 9 PHYSICAL & CHEMICAL PROPERTIES SPECIFIC GRAV. (70F, 21C) : 1.116 VAPOR PRESSURE (MMHG): 14.7 FREEZE POINT (F) : 1 VAPOR DENSITY (AIR = 1): >1.00 FREEZE POINT (C): -17 VISCOSITY (CPS 70F, 21C): 28% SOLUBILITY (WATER): 100.0 ODOR: SLIGHT ACID APPEARANCE: COLORLESS PHYSICAL STATE: LIQUID FLASH POINT: P-M (CC)>200F>93C pH AS IS (APPROX.):

3.5 EVAPORATION

RATE (ETHER = I)-: <1.00 NA = NOT APPLICABLE ND = NOT DETERMINED 10 STABILITY & REACTIVITY STABILITY: STABLE UNDER NORMAL STORAGE CONDITIONS. HAZARDOUS POLYMERIZATION: WILL NOT OCCUR.INCOMPATIBILITIES: MAY REACT WITH STRONG OXIDIZERS. DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES.INTERNAL PUMPOUT/CLEANOUT CATEGORIES: "B" 11 TOXICOLOGICAL INFORMATION ORAL LD50 RAT: 1.19 MG/KGNOTE: ESTIMATED VALUE DERMAL LD50 RABBIT: 2,350 MG/KG http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=979&ShowTOC= 1 &ShowHazardRatings= l&... 6/17/2009 SPECTRUS NXI105 by GE BETZ 9 PHYSICAL & CHEMICAL PROPERTIES SPECIFIC GRAV. (70F, 2lC): 1.116 VAPOR PRESSURE (MMHG): 14.7 FREEZE POINT (F): 1 VAPOR DENSITY (AIR" 1): >1.00 FREEZE POINT (C): -17 VISCOSITY (CPS 70F, 21C): 28 % SOLUBILITY (WATER): 100.0 ODOR: SLIGHT ACID APPEARANCE: COLORLESS PHYSICAL STATE: LIQUID FLASH POINT: P-M(CC) >200F >93C pH AS IS (APPROX.):

3.5 EVAPORATION

RATE (ETHER" 1): <1.00 NA = NOT APPLICABLE NO " NOT DETERMINED 10 STABILITY & REACTIVITY STABILITY: STABLE UNDER NORMAL STORAGE CONDITIONS. HAZARDOUS POLYMERIZATION: WILL NOT OCCUR. INCOMPATIBILITIES: MAY REACT WITH STRONG OXIDIZERS. DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES. INTERNAL PUMPOUT/CLEANOUT CATEGORIES: "B" 11 TOXICOLOGICAL INFORMATION ORAL LDSO RAT: 1.19 MG/KG NOTE: ESTIMATED VALUE DERMAL LDSO RABBIT: 2,350 MG/KG Page 5 of8 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=979&ShowTOC= 1 &ShowHazardRatings= 1 &... 6/17/2009 SPECTRUS NX1 105 by GE BETZ Page 6 of 8 NOTE: ESTIMATED VALUE; PROLONGS EXPOSURE MAY CAUSE BURNS.INHALATION LC50 RAT: NOTE: 12.58 MG/L/8HR CAUSED NO LETHALITY SKIN IRRITATION SCORE RABBIT: NONIRRITANT EYE IRRITATION SCORE RABBIT: CORROSIVE SKIN SENSITIZATION G.PIG: POSITIVE NOTE: GUINEA PIG MAXIMIZATION TEST 12 ECOLOGICAL INFORMATION AQUATIC TOXICOLOGY: BLUEGILL SUNFISH 96 HOUR STATIC ACUTE BIOASSAY: LD50: 24.8 NO EFFECT LEVEL: 11 MG/L DAPHNIA MAGNA 21 DAY CHRONIC BIOASSAY: REPRODUCTION NOEL: 9.7 MG/L DAPHNIA MAGNA 48 HOUR STATIC RENEWAL BIOASSAY: LC50: 23.6 NO EFFECT LEVEL: 17 MG/L EASTERN OYSTER LARVAE 96 HOUR FLOW-THRU BIOASSAY: EC50 SHELL DEPOSITION: 1.73 NO EFFECT LEVEL: .35 MG/L FATHEAD MINNOW 32 DAY EARLY LIFE STAGE TEST: LOEC: 6,6 NO EFFECT LEVEL: 3.2 MG/L FATHEAD MINNOW 96 HOUR STATIC ACUTE BIOASSAY: LC50: 13 NO EFFECT LEVEL: 8.6 MG/L MYSID SHRIMP 96 HOUR FLOW-THRU BIOASSAY: LC50: 15.7 NO EFFECT LEVEL: 1.7 MG/L RAINBOW TROUT 96 HOUR STATIC RENEWAL BIOASSAY: LC50: 24 NO EFFECT LEVEL: 17 MG/L SHEEPSHEAD MINNOW 96 HOUR FLOW-THRU BIOASSAY: LC50: 71 NO EFFECT LEVEL: 53 MG/L BIODEGRADATION: BOD-28 (MG/G): 500 BOD-5 (MG/G): 0 COD (MG/G) : 981 TOC (MG/G): 315 http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=979&ShowTOC=I&ShowHazardRatings=l&... 6/17/2009 SPECTRUS NXl105 by GE BETZ NOTB: ESTIMATED VALUE; PROLONGS EXPOSURE MAY CAUSE BURNS. INHALATION LC50 RAT: NOTB, 12.58 MG/L/SHR CAOSED NO LETHALITY SKIN IRRITATION SCORE RABBIT: NONIRRITANT EYE IRRITATION SCORE RABSIT: CORROSIVE SKIN SENSITIZATION G.PIG: POSITIVE NOTE: GOINEA PIG MAXIMIZATION TEST 12 ECOLOGICAL INFORMATION AQUATIC TOXICOLOGY: SLOEGILL SUNFISH 96 HOUR STATIC ACUTE BIOASSAY: LD50: 24.8 NO EFFECT LEVEL: 11 MG/L DAPHNIA MAGNA 21 DAY CHRONIC BIOASSAY: REPRODUCTION NOEL: 9.7 MG/L DAPHNIA MAGNA 48 HOUR STATIC RENEWAL BIOASSAY: LC50: 23.6 NO EFFECT LEVEL: 17 MG/L EASTERN OYSTER LARVAE 96 HOUR FLOW-THRU BIOASSAY: EC50 SHELL DEPOSITION: 1.73 NO EFFECT LEVEL: .35 MG/L FATHEAD MINNOW 32 DAY EARLY LIFE STAGE TEST: LOEC: 6.6 NO EFFECT LEVEL: 3.2 MG/L FATHEAD MINNOW 96 HOUR STATIC ACUTE BIOASSAY: LC50: 13 NO EFFECT LEVEL: 8.6 MG/L MYSID SHRIMP 96 HOUR FLOW-THRU BIOASSAY: LC50: 15.7 NO EFFECT LEVEL: 1.7 MG/L RAINBOW TROUT 96 HOUR STATIC RENEWAL BIOASSAY: LCSO: 24 NO EFFECT LEVEL: 17 MG/L SHEEPSHEAD MINNOW 96 HOUR FLOW-THRU BIOASSAY: LC50: 71 NO EFFECT LEVEL: 53 MG/L BIODEGRADATION: BOD-28 (MG!G): 500 BOD-5 (MG/G): 0 COD (MG/G): 981 TOC (MG/G): 315 Page 6 of8 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=979&ShowTOC= 1 &ShowHazardRatings= 1 &... 6/17/2009 SPECTRUS NX1 105 by GE BETZ Page 7 of 813 DISPOSAL CONSIDERATIONS IF THIS UNDILUTED PRODUCT IS DISCARDED AS A WASTE, THE US RCRA HAZARDOUS WASTE IDENTIFICATION NUMBER IS: NOT APPLICABLE. PLEASE BE ADVISED; HOWEVER, THAT STATE AND LOCAL REQUIREMENTS FOR WASTE DISPOSAL MAY BE MORE RESTRICTIVE OR OTHERWISE DIFFERENT FROM FEDERAL REGULATIONS. CONSULT STATE AND LOCAL REGULATIONS REGARDING THE PROPER DISPOSAL OF THIS MATERIAL.14 TRANSPORT INFORMATION DOT HAZARD: CORROSIVE TO SKIN UN / NA NUMBER: UN3265 DOT EMERGENCY RESPONSE GUIDE #: 153 15 REGULATORY INFORMATION TSCA: THIS IS AN EPA REGISTERED BIOCIDE AND IS EXEMPT FROM TSCA INVENTORY REQUIREMENTS. CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ): NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS FIFRA REGISTRATION NUMBER: 10352-22-3876 FOOD AND DRUG ADMINISTRATION: THE INGREDIENTS IN THIS PRODUCT ARE APPROVED BY FDA UNDER 21 CFR 176.170, 176.300 AND 173.320.USDA FEDERALLY INSPECTED MEAT AND POULTRY PLANTS: SEC. G5, G7 SARA SECTION 312 HAZARD CLASS:IMMEDIATE (ACUTE) DELAYED (CHRONIC)SARA SECTION 302 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS SARA SECTION 313 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS CALIFORNIA REGULATORY INFORMATION: CALIFORNIA SAFE DRINKING WATER AND TOXIC: ENFORCEMENT ACT (PROPOSITION

65) CHEMICALS PRESENT: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS MICHIGAN REGULATORY INFORMATION:

NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=979&ShowTOC= I &ShowHazardRatings= l &... 6/17/2009 SPECTRUS NXII0S by GE BETZ 13 DISPOSAL CONSIDERATIONS IF THIS UNDILUTED PRODUCT IS DISCARDED AS A WASTE, THE US RCRA HAZARDOUS WASTE IDENTIFICATION NUMBER IS: NOT APPLICABLE. PLEASE BE ADVISED; HOWEVER, THAT STATE AND LOCAL REQUIREMENTS FOR WASTE DISPOSAL MAY BE MORE RESTRICTIVE OR OTHERWISE DIFFERENT FROM FEDERAL REGULATIONS. CONSULT STATE AND LOCAL REGULATIONS REGARDING THE PROPER DISPOSAL OF THIS MATERIAL. 14 TRANSPORT INFORMATION DOT HAZARD: CORROSIVE TO SKIN UN / NA NUMBER: UN3265 DOT EMERGENCY RESPONSE GUIDE #: 153 15 REGULATORY INFORMATION TSCA: THIS IS AN EPA REGISTERED BIOCIDE AND IS EXEMPT FROM TSCA INVENTORY REQUIREMENTS. CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ): NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS FIFRA REGISTRATION NUMBER: 10352-22-3876 FOOD AND DRUG ADMINISTRATION: THE INGREDIENTS IN THIS PRODUCT ARE APPROVED BY FDA UNDER 21 CFR 176.170, 176.300 AND 173.320. USDA FEDERALLY INSPECTED MEAT AND POULTRY PLANTS: SEC. GS, G7 SARA SECTION 312 HAZARD CLASS: IMMEDIATE (ACUTE) DELAYED (CHRONIC) SARA SECTION 302 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS SARA SECTION 313 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS CALIFORNIA REGULATORY INFORMATION: CALIFORNIA SAFE DRINKING WATER AND TOXIC: ENFORCEMENT ACT (PROPOSITION

65) CHEMICALS PRESENT: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS MICHIGAN REGULATORY INFORMATION:

NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS Page 7 of8 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=979&ShowTOC=1 &ShowHazardRatings= 1 &... 6/17/2009 SPECTRUS NX 1105 by GE BETZ 16 OTHER INFORMATION Page 8 of 8.NFPA/HMIS HEALTH 3 FIRE 1 REACTIVITY 0 SPECIAL CORR I (1) PROTECTIVE EQUIPMENT X I (1) REFER TO SECTION 8 OF MSDS RECOMMENDATIONS. =ODE TRANSLATION SERIOUS HAZARD LIGHT HAZARD MINIMAL HAZARD DOT CORROSIVE ASK YOUR SUPERVISOR FOR ADDITIONAL PROTECTIVE EQUIPMENT CHANGE LOG: EFFECTIVE DATE REVISIONS TO SECTION MSDS STATUS 09-OCT-1997 20-MAY-1998 06-IJUL-1998 29-JUL-1998 09-IJUL-1999 24-SEP-1999 12-OCT-2000 22-AUG-2001 15 3 12 11 2,3,4; EDIT: 6 3,11 4 SUPERCEDES NEW 09-OCT-1997 20-MAY-1998 06-JUL-1998 29-JTUL-1998 09-ITUL-1999 24-SEP-1999 12-OCT-2000 Copyright@ 1999-2009 Dolphin Software, Inc.Comply Plus Web -Hosted FPL Energy http://fplenergy.complyplus.comiMSDS/print-bare.asp?S=979&ShowTOC= 1 &ShowHazardRatings= 1 &... 6/17/2009 SPECTRUS NXI105 by GE BETZ 16 OTHER INFORMATION .NFPA!HMIS HEALTH FIRE REACTIVITY 3 1 o CODE TRANSLATION SERIOUS HAZARD SLIGHT HAZARD MINlMAL HAZARD SPECIAL CORR DOT CORROSIVE (1) PROTECTIVE EQUIPMENT X ASK YOUR SUPERVISOR (1) REFER TO SECTION 8 OF MSDS FOR ADDITIONAL PROTECTIVE EQUIPMENT RECOMMENDATIONS. CHANGE LOG: EFFECTrVE DATE MSDS STATUS 09-0CT-1997 20-MAY-1998 06-JUL-1998 29-JUL-1998 09-JUL-1999 24-SEP-1999 12-OCT-2000 22-AUG-2001 REVISIONS TO SECTION 15 3 12 11 2,3,4; EDIT: 6 3,11 4 SUPERCEDES NEW 09-0CT-1997 20-MAY-1998 06-JUL-1998 29-JUL-1998 09-JUL-1999 24-SEP-1999 12-OCT-2000 Copyright© 1999-2009 Dolphin Software, Inc. Comply Plus Web -Hosted FPL Energy Page 8 of8 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=979&ShowTOC= 1 &ShowHazardRatings= 1 &... 6/17/2009 SPECTRUS NX 1106 by BETZ DEARBORN Page 1 of 8 FPL Energy Duane Arnold SPECTRUS NX1106 BETZ DEARBORN FileName Language Internal ID Revision Date 000108 0078 5/17/2001 Table Of Contents 1 PRODUCT IDENTIFICATION 2 COMPOSITION/INFORMATION ON INGREDIENTS 3 HAZARDS IDENTIFICATION 4 FIRST AID MEASURES 5 FIRE FIGHTING MEASURES 6 ACCIDENTAL RELEASE MEASURES 7 HANDLING & STORAGE 8 EXPOSURE CONTROLS/PERSONAL PROTECTION 9 PHYSICAL & CHEMICAL PROPERTIES 10 STABILITY & REACTIVITY 11 TOXICOLOGICAL INFORMATION 12 ECOLOGICAL INFORMATION 13 DISPOSAL CONSIDERATIONS 14 TRANSPORT INFORMATION 15 REGULATORY INFORMATION 16 OTHER INFORMATION Hazards MSDS State NFPA HMIS (Active)Health 3 3 Flammability 0 0 Reactivity 0 0 Other CO D HERCULES MSDS -SPECTRUS NX1106 MATERIAL SAFETY DATA SHEET BETZ DEARBORN, DIVISION OF HERCULES INCORPORATED 4636 SOMERTON ROAD TREVOSE, PA 190S3 BUSINESS TELEPHONE: (215) 355-3300 EMERGENCY TELEPHONE (HEALTH/ACCIDENT): (800) 877-1940 (USA)ISSUE DATE: 17-MAY-2001 HMIS RATINGS (SEE SECTION 16 FOR ADDITIONAL INFORMATION) HEALTH: 3 FLAMMABILITY: 0 REACTIVITY: 0 I PRODUCT IDENTIFICATION PRODUCT NAME: SPECTRUS NX1106 PRODUCT APPLICATION AREA: WATER-BASED MICROBIAL CONTROL AGENT.http://fplenergy. complyplus.comIMSDS/print-ba~re.asp?S=87&ShowTOC= 1 &ShowHazardRatings= 1 &S... 6/17/2009 SPECTRUS NXl106 by BETZ DEARBORN FPL Energy Duane Arnold SPECTRUS NX1106 fileName Language InternalID 000108 0078 TabJe Of Contents 1 PRODUCT IDENTIFICATION 2 COMPOSITION/INFORMATION ON INGREDIENTS 3 HAZARDS IDENTIFICATION 4 FIRST AID MEASURES 5 FIRE FIGHTING MEASURES 6 ACCIDENTAL RELEASE MEASURES 7 HANDLING & STORAGE 8 EXPOSURE CONTROLS/PERSONAL PROTECTION 9 PHYSICAL & CHEMICAL PROPERTIES 10 STABILITY & REACTIVITY 11 TOXICOLOGICAL INFORMATION 12 ECOLOGICAL INFORMATION 13 DISPOSAL CONSIDERATIONS 14 TRANSPORT INFORMATION 15 REGULATORY INFORMATION 16 OTHER INFORMATION Hazards MSDSState NFPA HMIS I Health 3 3 Flammability 0 0 Reactivity 0 0 Other CO 0 HERCULES MSDS -SPECTRUS NX1106 MATERIAL SAFETY DATA SHEET BETZ DEARBORN, DIVISION OF HERCULES INCORPORATED 4636 SOMERTON ROAD TREVOSE, PA 19053 BUSINESS TELEPHONE; (215) 355-3300 EMERGENCY TELEPHONE (HEALTH/ACCIDENT); (800) 877-1940 (USA) ISSUE DATE; 17-MAY-2001 HMIS RATINGS (SEE SECTION 16 FOR ADDITIONAL INFORMATION) HEALTH: 3 FLAMMABILITY; 0 REACTIVITY: 0 1 PRODUCT IDENTIFICATION PRODUCT NAME: SPBCTRUS NXII06 PRODUCT APPLICATION AREA: WATER-BASED MICROBIAL CONTROL AGENT. Page 1 of8 BETZ DEARBORN Revision Date 5/17/2001 (Active) I http://fplenergy. complyplus.comIMSDS/print_ bare .asp?S=87 &ShowTOC== 1 &ShowHazardRatings= 1 &S... 6117/2009 SPECTRUS NXI 106 by BETZ DEARBORN Page 2 of 8 2 COMPOSITION/INFORMATION ON INGREDIENTS INFORMATION FOR SPECIFIC PRODUCT INGREDIENTS AS REQUIRED BY THE U.S. OSHA HAZARD COMMUNICATION STANDARD IS LISTED. REFER TO ADDITIONAL SECTIONS OF THIS MSDS FOR OUR ASSESSMENT OF THE POTENTIAL HAZARDS OF THIS FORMULATION. HAZARDOUS INGREDIENTS: CAS#CHEMICAL NAME 10377-60-3 26172-55-4 MAGNESIUM NITRATE OXIDIZER; IRRITANT (EYES AND SKIN)5-CHLORO-2-METHYL-4-ISOTHIAZOLIN-3-ONECORROSIVE; TOXIC (BY INGESTION AND SKIN ABSORPTION); SENSITIZER (SKIN)IS CONSIDERED TO BE A CARCINOGEN BY THE NATIONAL TOXICOLOGY INTERNATIONAL AGENCY FOR RESEARCH ON CANCER, OR THE SAFETY AND HEALTH ADMINISTRATION AT OSHA THRESHOLDS FOR NO COMPONENT PROGRAM, THE OCCUPATIONAL CARCINOGENS. 3 HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: DANGER CORROSIVE TO SKIN. SKIN SENSITIZER WITH DELAYED ONSET OF SYMPTOMS. CORROSIVE TO THE EYES. MISTS/AEROSOLS CAUSE IRRITATION TO THE UPPER RESPIRATORY TRACT.DOT HAZARD: CORROSIVE TO SKIN EMERGENCY RESPONSE GUIDE

1. 153 ODOR: SLIGHT; APPEARANCE:

LIGHT YELLOW TO GREEN, LIQUID FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE).PROPER FIRE-EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER POTENTIAL HEALTH EFFECTS: ACUTE SKIN EFFECTS: PRIMARY ROUTE OF EXPOSURE; CORROSIVE TO SKIN. SKIN SENSITIZER WITH DELAYED ONSET OF SYMPTOMS.ACUTE EYE EFFECTS: CORROSIVE TO THE EYES.ACUTE RESPIRATORY EFFECTS: MISTS/AEROSOLS CAUSE IRRITATION TO THE UPPER RESPIRATORY TRACT.INGESTION EFFECTS: MAY CAUSE SEVERE IRRITATION OR BURNING OF MOUTH, THROAT, AND GASTROINTESTINAL TRACT WITH SEVERE CHEST AND ABDOMINAL PAIN, NAUSEA, VOMITING, DIARRHEA, LETHARGY AND COLLAPSE. POSSIBLE DEATH WHEN INGESTED IN VERY LARGE DOSES.http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=87&ShowTOC=l &ShowHazardRatings=I&S... 6/17/2009 SPECTRUS NXI106 by BETZ DEARBORN 2 COMPOSITION/INFORMATION ON INGREDIENTS INFORMATION FOR SPECIFIC* PRODUCT INGREDIENTS AS REQUIRED BY TaE U.S. OSHA HAZARD COMMUNICATION STANDARD IS LISTED. REFER TO ADDITIONAL SECTIONS OF THIS MSDS FOR OUR ASSESSMENT OF THE POTENTIAL HAZARDS OF THIS FORMULATION. HAZARDOUS INGREDIENTS: CASII 10377-60-3 26172-55-4 CHEMICAL NAME MAGNESIUM NITRATE OXIDIZER; IRRITANT (EYES AND SKIN) 5-CHLORO-2-METHYL-4-ISOTHIAZOLIN-3-0NE CORROSIVE; TOXIC (BY INGESTION AND SKIN ABSORPTION) I SENSITIZER (SKIN) NO COMPONENT IS CONSIDERED TO BE A CARCINOGEN BY THE NATIONAL TOXICOLOGY PROGRAM, THE INTERNATIONAL AGENCY FOR RESEARCH ON CANCER, OR THE OCCUPATIONAL SAFETY AND HEALTa ADMINISTRATION AT OSHA THRESHOLDS FOR CARCINOGENS. 3 HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: DANGER CORROSIVE TO SKIN. SKIN SENSITIZER WITH DELAYED ONSET OF SYMPTOMS. CORROSIVE TO THE EYES. MISTS/AEROSOLS CAUSE IRRITATION TO THE UPPER RESPIRATORY TRACT. DOT HAZARD: CORROSIVE TO SKIN EMERGENCY RESPONSE GUIDE #153 ODOR: SLIGHT; APPEARANCE: LIGHT YELLOW TO GREEN, LIQUID FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE) . PROPER FIRE-EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER POTENTIAL HEALTH EFFECTS: ACUTE SKIN EFFECTS: PRIMARY ROUTE OF EXPOSORE; CORROSIVE TO SKIN. SKIN SENSITIZER WITH DELAYED ONSET OF SYMPTOMS. ACUTE EYE EFFECTS: CORROSIVE TO THE EYES. ACUTE RESPIRATORY EFFECTS: MISTS/AEROSOLS CAUSE IRRITATION TO THE UPPER RESPIRATORY TRACT. INGESTION EFFECTS: MAY CAUSE SEVERE IRRITATION OR BURNING OF MOUTH, THROAT, AND GASTROINTESTINAL TRACT WITH SEVERE CHEST AND ABDOMINAL PAIN, NAUSEA, VOMITING, DIARRHEA, LETHARGY AND COLLAPSE. POSSIBLE DEATH WHEN INGESTED IN VERY LARGE DOSES. Page 2 of8 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=87 &ShowTOC= 1 &ShowHazardRatings= I&S... 6117/2009 SPECTRUS NXI 106 by BETZ DEARBORN Page 3 of 8 TARGET ORGANS: PROLONGED OR REPEATED EXPOSURES MAY CAUSE TISSUE NECROSIS AND/OR SKIN SENSITIZATION. MEDICAL CONDITIONS AGGRAVATED: NOT KNOWN.SYMPTOMS OF EXPOSURE: DIRECT CONTACT WITH SKIN WILL CAUSE SEVERE DELAYED SKIN REACTIONS OR BURNS IF NOT WASHED OFF IMMEDIATELY-FOLLOW FIRST AID INSTRUCTIONS. 4 FIRST AID MEASURES SKIN CONTACT: URGENT! WASH THOROUGHLY WITH SOAP AND WATER. REMOVE CONTAMINATED CLOTHING.GET IMMEDIATE MEDICAL ATTENTION. THOROUGHLY WASH CLOTHING BEFORE REUSE.EYE CONTACT;URGENTI IMMEDIATELY FLUSH EYES WITH PLENTY OF LOW-PRESSURE WATER FOR AT LEAST 20 MINUTES WHILE REMOVING CONTACT LENSES. HOLD EYELIDS APART. GET IMMEDIATE MEDICAL ATTENTION. INHALATION:IF NASAL, THROAT OR LUNG IRRITATION DEVELOPS -REMOVE TO FRESH AIR AND GET MEDICAL ATTENTION. INGESTION: DO NOT FEED ANYTHING BY MOUTH TO AN UNCONSCIOUS OR CONVULSIVE VICTIM. DO NOT INDUCE VOMITING. IMMEDIATELY CONTACT PHYSICIAN. DILUTE CONTENTS OF STOMACH USING 3-4 GLASSES MILK OR WATER.NOTES TO PHYSICIANS: MATERIAL IS CORROSIVE. IT MAY NOT BE ADVISABLE TO INDUCE VOMITING. POSSIBLE MUCOSAL DAMAGE MAY CONTRAINDICATE THE USE OF GASTRIC LAVAGE.5 FIRE FIGHTING MEASURES FIRE FIGHTING INSTRUCTIONS: FIRE FIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE).EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER HAZARDOUS DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES.FLASH POINT: > 200F > 93C P-M(CC)MISCELLANEOUS: CORROSIVE TO SKIN UN3265;EMERGENCY RESPONSE GUIDE #153 6 ACCIDENTAL RELEASE MEASURES PROTECTION AND SPILL CONTAINMENT: VENTILATE AREA. USE SPECIFIED PROTECTIVE EQUIPMENT. CONTAIN AND ABSORB ON http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=87&ShowTOC=1 &ShowHazardRatings= I &S,.. 6/17/2009 SPECTRUS NX1l 06 by BETZ DEARBORN TARGET ORGANS: PROLONGED OR REPEATED EXPOSURES MAY CAUSE TISSUE NECROSIS AND/OR SKIN SENSITIZATION. MEDICAL CONDITIONS AGGRAVATED: NOT KNOWN. SYMPTOMS OF rocPOSURE: DIRECT CONTACT WITH SKIN WILL CAUSE SEVERE DELAYED SKIN REACTIONS OR BURNS IF NOT WASHED OFF IMMEDIATELY-FOLLOW FIRST AID INSTRUCTIONS. 4 FIRST AID MEASURES SKIN CONTACT: URGENT! WASH THOROUGHLY WITH SOAP AND WATER. REMOVE CONTAMINATED CLOTHING. GET IMMEDIATE MEDICAL ATTENTION. THOROUGHLY WASH CLOTHING BEFORE REUSE. EYE CONTACT: URGENT I IMMEDIATELY FLUSH EYES WITH PLENTY OF LOW-PRESSURE WATER FOR AT LEAST 20 MINUTES WHILE REMOVING CONTACT LENSES. HOLD EYELIDS APART. GET IMMEDIATE MEDICAL ATTENTION. INHALATION: IF NASAL, THROAT OR LUNG IRRITATION DEVELOPS -REMOVE TO FRESH AIR AND GET MEDICAL ATI'ENTION. INGESTION: DO NOT FEED ANYTHING BY MOUTH TO AN UNCONSCIOUS OR CONVULSIVE VICTIM. DO NOT INDUCE VOMITING. IMMEDIATELY CONTACT PHYSICIAN. DILUTE CONTENTS OF STOMACH USING 3-4 GLASSES MILK OR WATER. NOTES TO PHYSICIANS: MATERIAL IS CORROSIVE. IT MAY NOT BE ADVISABLE TO INDUCE VOMITING. POSSIBLE MUCOSAL DAMAGE MAY CONTRAINDICATE THE USE OF GASTRIC LAVAGE. 5 FIRE FIGHTING MEASURES FIRE FIGHTING INSTRUCTIONS: FIRE FIGRTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE) . EXTINGUISHING MEDIA: DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER HAZARDOUS DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES. FLASH POINT: > 200F > 93C F-M(CC) MISCELLANEOUS: CORROSIVE TO SKIN UN3265;EMERGENCY RESPONSE GUIDE 6 ACCIDENTAL RELEASE MEASURES PROTECTION AND SPILL CONTAINMENT: VENTILATE AREA. USE SPECIFIED PROTECTIVE EQUIPMENT. CONTAIN AND ABSORB ON Page 3 ofS http://fplenergy.complyplus.comIMSDS/print _ bare.asp?S=87 &ShowTOC= 1 &ShowHazardRatings= 1 &S... 6117/2009 SPECTRUS NX 1106 by BETZ DEARBORN Page 4 of 8 ABSORBENT MATERIAL. PLACE IN WASTE DISPOSAL CONTAINER. DO NOT ADD DECONTAMINANT SOLUTION TO WASTE DRUM CONTAINING BIOCIDE OR ADSORBENT.DECONTAMINATE FLOOR RESIDUAL WITH 10% METABISULFITE SOLUTION. USE 10 VOLUMES OF SOLUTION TO ONE VOLUME OF SPILL.DISPOSAL INSTRUCTIONS: WATER CONTAMINATED WITH THIS PRODUCT MAY BE SENT TO A SANITARY SEWER TREATMENT FACILITY,IN ACCORDANCE WITH ANY LOCAL AGREEMENT,A PERMITTED WASTE TREATMENT FACILITY OR DISCHARGED UNDER A PERMIT. PRODUCT AS IS -DISPOSE OF IN APPROVED PESTICIDE FACILITY OR ACCORDING TO LABEL INSTRUCTIONS. 7 HANDLING & STORAGE HANDLING: CONTAINS AN OXIDIZER. AVOID ALL CONTACT WITH REDUCING AGENTS, OILS, GREASES, ORGANICS AND ACIDS. CORROSIVE TO SKIN AND/OR EYES.STORAGE: KEEP CONTAINERS CLOSED WHEN NOT IN USE. STORE BETWEEN 20-20OF FOR NO MORETHAN 6 MONTHS. STORE UPRIGHT IN ORIGINAL VENTED CONTAINERS. PRODUCT EVOLVES C02 SLOWLY. STORE SAMPLES IN PLASTIC BOTTLES DUE TO PRESSURE BUILD-UP. <1.00 8 EXPOSURE CONTROLS/PERSONAL PROTECTION EXPOSURE LIMITS: CHEMICAL NAME MAGNESIUM NITRATE PEL (OSHA): NOT DETERMINED TLV (ACGIH): NOT DETERMINED 5-CHLORO-2-METHYL-4-ISOTHIAZOLIN-3-ONE PEL (OSHA): NOT DETERMINED TLV (ACGIH): NOT DETERMINED MISC: NOTE-MFG. SUGG. EXP. LIMIT:0.1 MG/M3 TWA;0.3MG/M3 STEL TOTAL ISOTHIAZOLINE). ENGINEERING CONTROLS: ADEQUATE VENTILATION TO MAINTAIN AIR CONTAMINANTS BELOW EXPOSURE LIMITS.PERSONAL PROTECTIVE EQUIPMENT: USE PROTECTIVE EQUIPMENT IN ACCORDANCE WITH 29CFR 1910 SUBPART IRESPIRATORY PROTECTION: A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CFR 1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE.USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS. IF AIR-PURIFYING RESPIRATOR USE IS APPROPRIATE, USE A RESPIRATOR WITH ORGANIC VAPOR/ACID GAS CARTRIDGES AND DUST/MIST PREFILTERS. SKIN PROTECTION: GAUNTLET-TYPE BUTYL GLOVES, CHEMICAL RESISTANT APRON http://fplenergy.complyplus.oom/MSDS/print-bare.asp?S=87&ShowTOC=I &ShowHazardRatings=l &S... 6/17/2009 SPECTRUS NXl106 by BETZ DEARBORN ABSORBENT MATERIAL. PLACE IN WASTE DISPOSAL CONTAINER. DO NOT ADD DECONTAMINANT SOLUTION TO WASTE DRUM CONTAINING BIOCIDE OR ADSORBENT. DECONTAMINATE FLOOR RESIDUAL WITH 10% METABISULFITE SOLUTION. USE 10 VOLUMES OF SOLUTION TO ONE VOLUME OF SPILL. DISPOSAL INSTRUCTIONS: WATER CONTAMINATED WITH THIS PRODUCT MAY BE SENT TO A SANITARY SEWER TREATMENT FACILITY,IN ACCORDANCE WITH ANY LOCAL AGREEMENT,A PERMITTED WASTE TRBATMENT FACILITY OR DISCHARGED UNDER A PERMIT. PRODUCT AS IS -DISPOSE OF IN APPROVED PESTICIDE FACILITY OR ACCORDING TO LABEL INSTRUCTIONS. 7 HANDLING & STORAGE HANDLING: CONTAINS AN OXIDIZER. AVOID ALL CONTACT WITH REDUCING AGENTS, OILS, GRBASES, ORGANICS AND ACIDS. CORROSIVE TO SKIN AND/OR EYES. STORAGE: KEEP CONTAINERS CLOSEO WHEN NOT IN USE. STORE BETWEEN 20-100F FOR NO MORE THAN 6 MONTHS. STORE UPRIGHT IN ORIGINAL VENTED CONTAINERS. PRODUCT EVOLVES C02 SLOWLY. STORE SAMPLES IN PLASTIC BOTTLES DUE TO PRESSURE BUILD-UP. " 1. 00 B EXPOSURE CONTROLS/PERSONAL PROTECTION EXPOSURE LIMITS: CHEMICAL NAME MAGNESIUM NITRATE PEL (OSHA): NOT DETERMINED TLV {ACGIH}: NOT OETERMINED 5-CHLORO-2-METHYL-4-ISOTHIAZOLIN-3-0NE PEL (OSHA): NOT DETERMINED TLV (ACGIH): NOT DETERMINED MISC: NOTE-MFG. SUGG. EXP. LIMIT:O.1 MG/M3 TWA;0.3MG/M3 STEL TOTAL ISOTHIAZOLINE) . ENGINEERING CONTROLS: ADEQUATE VENTILATION TO MAINTAIN AIR CONTAMINANTS BELOW EXPOSURE LIMITS. PERSONAL PROTECTIVE EQUIPMENT: USE PROTECTIVE EQUIPMENT IN ACCORDANCE WITH 29CFR 1910 SUBPART I RESPIRATORY PROTECTION: A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CFR 1910.134 AND ANSI ZBB.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE. USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS. IF AIR-PURIFYING RESPIRATOR USE IS APPROPRIATE, USE A RESPIRATOR WITH ORGANIC VAPOR/ACID GAS CARTRIDGES AND DUST/MIST PREFILTERS. SKIN PROTECTION: GAUNTLET-TYPE BUTYL GLOVES, CHEMICAL RESISTANT APRON Page 4 of8 http://fplenergy .complyplus.comfMSDS/print_ bare.asp?S=87 &ShowTOC= 1 &ShowHazardRatings= 1 &S... 6/17/2009 SPECTRUS NX 1106 by BETZ DEARBORN Page 5 of 8 WASH OFF AFTER EACH USE. REPLACE AS NECESSARY. EYE PROTECTION: SPLASH PROOF CHEMICAL GOGGLES, FACE SHIELD 9 PHYSICAL & CHEMICAL PROPERTIES SPECIFIC GRAV. (70F, 21C): 1.033 FREEZE POINT (F): 28 FREEZE POINT (C): -2 VISCOSITY (CPS 70F, 2"IC): 8 VAPOR PRESSURE (MMHG): APPROX. 18.0 VAPOR DENSITY (AIR=I): < 1.00% SOLUBILITY (WATER): 100.0 ODOR: SLIGHT APPEARANCE: LIGHT YELLOW TO GREEN PHYSICAL STATE: LIQUID FLASH POINT: P-M(CC) > 200F > 93C PH AS IS (APPROX.).:

3.0 EVAPORATION

RATE (ETHER=1): < 1.00 NA = NOT APPLICABLE ND = NOT DETERMINED 10 STABILITY & REACTIVITY STABILITY: STABLE UNDER NORMAL STORAGE CONDITIONS. HAZARDOUS POLYMERIZATION: WILL NOT OCCUR.INCOMPATIBILITIES: MAY REACT WITH STRONG OXIDIZERS. DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES.BETZ DEARBORN INTERNAL PUMPOUT/CLEANOUT CATEGORIES: "B" 11 TOXICOLOGICAL INFORMATION ORAL LD50 RAT: >5,000 MG/KG TERATOLOGY

NEGATIVE http://fplenergy.complyplus.com/MSDS/printbare.asp?S=87&ShowTOC=

&ShowHazardRatings 1&S... 6/17/2009 SPECTRUS NXII06 by BETZ DEARBORN WASH OFF AFTER EACH USE. REPLACE AS NECESSARY. EYE PROTECTION: SPLASH PROOF CHEMICAL GOGGLES, FACE SHIELD 9 PHYSICAL & CHEMICAL PROPERTIES SPECIFIC GRAV. (70F, 21C): 1.033 FREEZE POINT (F): 28 FREEZE POINT (C): -2 VISCOSITY (CPS 70F, 21C): 8 VAPOR PRESSURE (MMHG): APPROX. 18.0 VAPOR DENSITY (AIR=l): < 1.00 % SOLUBILITY (WATER): 100.0 ODOR: SLIGHT APPEARANCE: LIGHT YELLOW TO GREEN PHYSICAL STATE: LIQUID FLASH POINT: P-M(CC) > 200F > 93C PH AS IS (APPROX.):

3.0 EVAPORATION

RATE (ETHER=1): < 1.00 NA = NOT APPLICABLE ND = NOT DETERMINED 10 STABILITY & REACTIVITY STABILITY: STABLE UNDER NORMAL STORAGE CONDITIONS. HAZARDOUS POLYMERIZATION: WILL NOT OCCUR. INCOMPATIBILITIES: MAY REACT WITH STRONG OXIDIZERS . . DECOMPOSITION PRODUCTS: THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES. BETZ DEARBORN INTERNAL PUMPOOT / CLEANOOT CATEGORIES: n B" 11 TOXICOLOGICAL INFORMATION ORAL LDSO RAT: >5,000 MG/KG TERATOLOGY

NEGATIVE Page 5 of8 http://fplenergy.complyplus.comIMSDS/print_

bare.asp?S=87 &ShowTOC=l &ShowHazardRatings== 1 &S... 6117/2009 SPECTRUS NX 1106 by BETZ DEARBORN Page 6 of 8 DERMAL LD50 RABBIT: >2,000 MG/KGNOTE -ESTIMATED VALUE SKIN SENSITIZATION HUMAN: POSITIVE NON-AMES MUTAGENICITY: NEGATIVE 12 ECOLOGICAL INFORMATION AQUATIC TOXICOLOGY: RAINBOW TROUT 96 HOUR STATIC ACUTE BIOASSAY: LC50: 8.7 MG/L NO EFFECT LEVEL: 6.5 MG/L DAPHNIA MAGNA 48 HOUR FLOW-THRU BIOASSAY: MORTALITY WAS OBSERVED IN LOWEST CONCENTRATION TESTED. TEST CONCENTRATIONS WERE ANALYTICALLY VERIFIED.LC50: 2.9 MG/L 10% MORTALITY: .6 MG/L BLUEGILL SUNFISH 96 HOUR STATIC ACUTE BIOASSAY: LC50: 12.1 MG/L NO EFFECT LEVEL: 6.5 MG/L FATHEAD MINNOW 96 HOUR FLOW-THRU BIOASSAY: TEST CONCENTRATIONS WERE ANALYTICALLY VERIFIED.LC50: 6.6 MG/L NO EFFECT LEVEL: 2.5 MG/L RAINBOW TROUT 14 DAY CHRONIC BIOASSAY: LC50: 4.6 MG/L NO EFFECT LEVEL: 3.3 MG/L FATHEAD MINNOW 36 DAY EARLY LIFE STAGE TEST: LOEC: 4 MG/L NO EFFECT LEVEL: 1.3 MG/L SHEEPSHEAD MINNOW 96 HOUR STATIC ACUTE BIOASSAY: LCS0: 20 MG/L NO EFFECT LEVEL: 12 MG/L BIODEGRADATION: COD (MG/GM): 17 CALCULATED TOC (MG/GM): 6 CALCULATED BOD-5 (MG/GM): 0 CALCULATED BOD-28 (MG/GM): 0 CALCULATED13 DISPOSAL CONSIDERATIONS IF THIS UNDILUTED PRODUCT IS DISCARDED AS A WASTE, THE US RCRA HAZARDOUS WASTE IDENTIFICATION NUMBER IS: NOT APPLICABLE. PLEASE BE ADVISED; HOWEVER, THAT STATE AND LOCAL REQUIREMENTS FOR WASTE http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=87&ShowTOC=1&ShowHazardRatings=l&S... 6/17/2009 SPECTRUS NX 11 06 by BETZ DEARBORN DERMAL LDSO RABBIT: >2,000 MG/KG NOTE -ESTIMATED VALUE SKIN SENSITIZATION HUMAN: POSITIVE NON-AMES MUTAGENICITY: NEGATIVE 12 ECOLOGICAL INFORMATION AQUATIC TOXICOLOGY: RAINBOW TROUT 96 HOUR STATIC ACUTE BIOASSAY: LCSO: S.7 MG/L NO EFFECT LEVEL: 6.5 MG/L DAPHNIA MAGNA 4S HOUR FLOIq-THRV BIOASSAY: MORTALITY WAS OBSERVED IN LOWEST CONCENTRATION TESTED. TEST CONCENTRATIONS WERE ANALYTICALLY VERIFIED. LC50: 2.9 MG/L 10% MORTALITY: .6 MG/L BLUEGILL SUNFISH 96 HOUR STATIC ACUTE BIOASSAY: LCSO: 12.1 MG/L NO EFFECT LEVEL: 6.5 MG/L FATHEAD MINNOW 96 HOUR FLOW-THRU BIOASSAY: TEST CONCENTRATIONS WERE ANALYTICALLY VERIFIED. LCSO: 6.6 MG/L NO EFFECT LEVEL: 2.5 MG/L RAINBOW TROUT 14 DAY CHRONIC BIOASSAY: LCSO: 4.6 MG/L NO EFFECT LEVEL: 3.3 MG/L FATHEAD MINNOW 36 DAY EARLY LIFE STAGE TEST: LOEC: 4 MG/L NO EFFECT LEVEL: 1.3 MG/L SHEEPSHEAD MINNOW 96 HOUR STATIC ACUTE BIOASSAY: LCSO: 20 MG/L NO EFFECT LEVEL: 12 MG/L BIODEGRADATION: COD (MG/GM): TOe (MG/GM): BOD-5 (MG/GM): BOD-28 (MG/GM): 17 CALCULATED 6 CALCULATED o CALCULATED o CALCULATED 13 DISPOSAL CONSIDERATIONS IF THIS UNDILUTED PRODUCT IS DISCARDED AS A WASTE, THE US RCAA HAZAADOVS WASTE IDENTIFICATION NUMBER IS: NOT APPLICABLE. PLEASE BE ADVISED; HOWEVER, THAT STATE AND LOCAL REQUIREMENTS FOR WASTE Page 6 of8 http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=87 &ShowTOC= 1 &ShowHazardRatings=l &S... 6/17/2009 SPECTRUS NX1 106 by BETZ DEARBORN DISPOSAL MAY BE MORE RESTRICTIVE OR OTHERWISE DIFFERENT FROM FEDERAL REGULATIONS. CONSULT STATE AND LOCAL REGULATIONS REGARDING THE PROPER DISPOSAL OF THIS MATERIAL.14 TRANSPORT INFORMATION DOT HAZARD: CORROSIVE TO SKIN UN/NA NUMBER: UN3265 DOT EMERGENCY RESPONSE GUIDE #: 153 15 REGULATORY INFORMATION Page 7 of 8 TSCA: THIS IS AN EPA REGISTERED BIOCIDE AND IS EXEMPT FROM TSCA INVENTORY REQUIREMENTS. CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ): NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS FIFRA REGISTRATION NUMBER: 3876-143 FOOD AND DRUG ADMINISTRATION: THE INGREDIENTS IN THIS PRODUCT ARE APPROVED BY FDA UNDER 21 CFR 176.300.USDA FEDERALLY INSPECTED MEAT AND POULTRY PLANTS: SEC. G7 SARA SECTION 312 HAZARD CLASS: IMMEDIATE (ACUTE); DELAYED (CHRONIC)SARA SECTION 302 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS SARA SECTION 313 CHEMICALS: CAS# CHEMICAL NAME 10377-60-3 MAGNESIUM NITRATE RANGE 2.0-5.0-CALIFORNIA REGULATORY INFORMATION: CALIFORNIA SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT (PROPOSITION 65)CHEMICALS PRESENT: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS MICHIGAN REGULATORY INFORMATION: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS 16 OTHER INFORMATION NFPA/HMIS HEALTH FIRE REACTIVITY CODE TRANSLATION 3 SERIOUS HAZARD 0 MINIMAL HAZARD 0 MINIMAL HAZARD http://fplenergy.complyplus.com!MSDS/printbare.asp?S=87&ShowTOC= I &ShowHazardRatings=1 &S... 6/17/2009 SPECTRUS NXl106 by BETZ DEARBORN DISPOSAL MAY BE MORE RESTRICTIVE OR OTHERWISE DIFFERENT FROM FEDERAL REGULATIONS. CONSULT STATE AND LOCAL REGULATIONS REGARDING THE PROPER DISPOSAL OF THIS MATERIAL. 14 TRANSPORT INFORMATION DOT HAZARD: CORROSIVE TO SKIN UN/NA NUMBER: UN3265 DOT EMERGENCY RESPONSE GUIDE #: 153 15 REGULATORY INFORMATION TSCA: THIS IS AN EPA REGISTERED BIOCIDE AND IS EXEMPT FROM TSCA INVENTORY REQUIREMENTS. CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ): NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS FIFRA REGISTRATION NUMBER: 3876-143 FOOD AND DRUG ADMINISTRATION: THE INGREDIENTS IN THIS PROnUCT ARE APPROVED BY FDA UNDER 21 CFR 176.300. USDA FEDERALLY INSPECTED MEAT AND POULTRY PLANTS: SEC. G7 SARA SECTION 312 HAZARD CLASS: IMMEDIATE (ACUTE); DELAYED (CHRONIC) SARA SECTION 302 CHEMICALS: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS SARA SECTION 313 CHEMICALS: CAS# CHEMICAL NAME 10377-60-3 MAGNESIUM NITRATE CALIFORNIA REGULATORY INFORMATION: RANGE :I.0-5.0%- CALIFORNIA SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT (PROPOSITION

65) CHEMICALS PRESENT: NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS MICHIGAN REGULATORY INFORMATION:

NO REGULATED CONSTITUENT PRESENT AT OSHA THRESHOLDS 16 OTHER INFORMATION NFPA/HMIS HEALTH FIRE REACTIVITY 3 o o CODE TRANSLATION SERIOUS HAZARD MINIMAL HAZARD MINIMAL HAZARD Page 7 of8 http;llfplenergy.compiyplus.comlMSDS/print_ bare.asp?S=87 &ShowTOC= 1 &ShowHazardRatings=l &S... 6/17/2009 SPECTRUS NXI 106 by BETZ DEARBORN Page 8 of 8 SPECIAL C((1) PROTECTIVE EQUIPMENT D ORR DOT CORROSIVE GOGGLESFACE SHIELD, GLOVES,APRON (1) REFER TO SECTION 8 OP MSDS FOR ADDITIONAL PROTECTIVE EQUIPMENT RECOMMENDATIONS. CHANGE LOG: EFFECTIVE DATE REVISIONS TO SECTION: MSDS STATUS: 03-OCT-1997 02-DEC-1997 23-DEC-1997 01-MAY-1998 08-APR-1999 17-MAY-2001 is 15 15;EDITz9;EDIT: 9 4,16 SUPERCEDES

• • NEW **03-OCT-1997 02-DEC-1997 23-DEC-1997 01-MAY-1998 08-APR-1999 CopyrightO 1999-2009 Dolphin Software, Inc.Comply Plus Web -Hosted FPL Energy http://fplenergy-complyplus.conmMSDS/print-bare.asp?S=87&ShowTOC=I&ShowHazardRatings=I&S...

6/17/2009 SPECTRUS NXil 06 by BETZ DEARBORN SPECIAL (1) PROTECTIVE EQUIPMENT CORR D DOT CORROS IVE GOGGLES,FACE SHIELD,GLOVES,APRON (1) REFER TO SECTION B OF MSDS FOR ADDITIONAL PROTECTIVE EQUIPMENT RECOMMENDATIONS. CHANGE LOG: EFFECTIVE DATE REVISIONS TO SECTION: SUPERCEDES MSDS STATUS: 03-OCT-1997 02-DEC-1997 15 23-DEC-1997 15 01-MAY-199B 15;EDIT:9 DB-APR-1999

EDIT

9 17-MAY-2001 4,16 .* NEW ** 03-0CT-1997 02-DEC-1997 23-DEC-1997 Ol-MAY-199B 08-APR-1999 Copyright© 1999-2009 Dolphin Software, Inc. Comply Plus Web -Hosted FPL Energy Page 8 of8 http://fplenergy.complyplus.comIMSDS/print_

bare.asp?S=87 &ShowTOC= 1 &ShowHazardRatings=l &S... 6/17/2009 SODA ASH LIGHT by FMC Page 1 of 8 FPL Energy Duane Arnold SODA ASH LIGHT FMC FileName Language Internal ID Revision Date 012802 0928 2/6/2007 Table Of Contents 1. PRODUCT AND COMPANY IDENTIFICATION

2. HAZARDS IDENTIFICATION

3. COMPOSITION/INFORMATION ON INGREDIENTS

4. FIRSTAID MEASURES 5. FIRE FIGHTING MEASURES 6. ACCIDENTAL RELEASE MEASURES 7. HANDLING AND STORAGE 8. EXPOSURE CONTROLS/PERSONAL PROTECTION

9. PHYSICAL AND CHEMICAL PROPERTIES

10. STABILITY AND REACTIVITY

11. TOXICOLOGICAL INFORMATION

12. ECOLOGICAL INFORMATION

13. DISPOSAL CONSIDERATIONS

14. TRANSPORTATION INFORMATION

15. REGULATORY INFORMATION

16. ADDITIONAL INFORMATION Hazards MSDS State NFPA HMIS (Active)Health 2 2 Flammability 0 0 Reactivity 0 0 Other E MATERIAL SAFETY DATA SHEET SODA ASH LIGHT MSDS ID: AL0110 REPLACES:

11-01-2005 REVISED: 02-06-2007

1. PRODUCT AND COMPANY IDENTIFICATION PRODUCT NAME: SODA ASH LIGHT MSDS ID: AL0110 SYNONYMS: SODIUM CARBONATE, ANHYDROUS SODA ASH DISODIUM CARBONATE SODA, CALCINED CAS NUMBER: 497-19-8 http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=3168&ShowTOC=

1 &ShowHazardRatings=1 ... 6/17/2009 SODA ASH LIGHT by FMC FPL Energy Duane Arnold SODA ASH UGHT FileName Language Internal 10 012802 0928 Table Of Contents 1. PRODUCT AND COMPANY IDENTIFICATION

2. HAZARDS IDENTIFICATION

3. COMPOSITION/lNFORMATION ON INGREDIENTS

4. FIRSTAID MEASURES S. FIRE FIGHTING MEASURES 6. ACCIDENTAL RELEASE MEASURES 7. HAN DUNG AND STORAGE 8. EXPOSURE CONTROLS/PERSONAL PROTECTION

9. PHYSICAL AND CHEMICAL PROPERTIES

10. STABIUTY AND REACTIVITY

11. TOXICOLOGICAL INFORMATION

12. ECOLOGICAL INFORMATION

13. DISPOSAL CONSIDERATIONS

14. TRANSPORTATION INFORMATION

15. REGULATORY INFORMATION

16. ADDITIONAL INFORMATION Hazards NFPA HMIS Health 2 2 Flammability 0 0 Reactivity 0 0 Other E MA'l'ERIAL SAFETY DATA SHEET SODA ASH LIGHT MSDS 10: ALOll0 REPLACES:

11-01-2005 REVISED: 02-06-2007

1. PRODUCT AND COMPANY IDENTIFICATION PRODUCT NAME: SODA ASH LIGHT MSDS 10: ALO 11 0 SYNONYMS:

SODIUM CARBONA'l'E, ANHYDROUS SODA ASH DISODIUM CARBONATE SODA, CALCINED CAS NUMBER: 497-19-8 MSDSState I Page lof8 FMC Revision Date 2/6/2007 (Active) I http://fplenergy.complyplus.comlMSDS/print_bare.asp?S=3168&ShowTOC= 1 &ShowHazardRatings=l... 6/17/2009 SODA ASH LIGHT by FMC Page 2 of 8 CHEMICAL FAMILY: ALKALIFORMULA: NA2 CO3 DISTRIBUTED BY: HYDRITE CHEMICAL CO.300 N. PATRICK BLVD.BROOKFIELD, WL 53008-0948 (262) 792-1450 MANUFACTURED BY: FMC EMERGENCY RESPONSE NUMBERS: 24 HOUR EMERGENCY

1. (414) 277-1311 CHEMTREC EMERGENCY

   (800) 424-9300 2. HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: WARNING CAUSES EYE IRRITATION.

MAY CAUSE SKIN AND RESPIRATORY IRRITATION. MAY BE HARMFUL IF SWALLOWED. CORROSIVE TO ALUMINUM.PHYSICAL STATE: GRANULES.COLOR: WHITE. ODOR: NO ODOR.POTENTIAL HEALTH EFFECTS: ROUTES OF EXPOSURE: EYES. SKIN. INHALATION. INGESTION.TARGET ORGANS: NONE KNOWN.EYE CONTACT: CAUSES SEVERE IRRITATION. MAY CAUSE: PERMANENT EYE DAMAGE.SKIN CONTACT: CONTACT MAY CAUSE: IRRITATION, REDNESS, SWELLING. MAY CAUSE A MORE SEVERE RESPONSE IF SKIN IS DAMP.SKIN ABSORPTION: NO DATA AVAILABLE. INHALATION: DUSTS MAY IRRITATE: MUCOUS MEMBRANES. UPPER RESPIRATORY TRACT, LUNGS.INGESTION: MAY BE CORROSIVE TO THE GASTROINTESTINAL TRACT. SEVERE IRRITATION AND BURNS MAY RESULT.MAY CAUSE: http://fplenergy.complyplus.com/MSDS/print.bare.asp?S=3168&ShowTOC= 1 &ShowHazardRatings=l ... 6/17/2009 SODA ASH LIGHT by FMC CHEMICAL FAMILY: ALKALI FORMULA: NA2C03 DISTRIBUTED BY: HYORITE CHEMICAL CO. 300 N. PATRICK BLVD. BROOKFIELD, WL 53008-0948 (262) 792-1450 MANUFACTURED BY: FMC EMERGENCY RESPONSE NUMBERS: 24 HOUR EMERGENCY II: (414) 277-1311 CHEMTREC EMERGENCY II: (BOO) 424-9300 2. HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: WARNINGl CAUSES EYE IRRITATION. MAY CAUSE SKIN AND RESPIRATORY IRRITATION. MAY BE HARMFUL IF SWALLOWED. CORROSIVE TO ALUMINUM. PHYSICAL STATE: GRANULES. COLOR: WHITE. ODOR: NO ODOR. POTENTIAL HEALTH EFFECTS: ROUTES OF EXPOSURE: EYES. SKIN. INHALATION. INGESTION. TARGET ORGANS: NONE KNOWN. EYE CONTACT: CAUSES SEVERE IRRITATION. MAY CAUSE: PERMANENT EYE DAMAGE. SKIN CONTACT: CONTACT MAY CAUSE: IRRITATION, REDNESS, SWELLING. MAY CAUSE A MORE SEVERE RESPONSE IF SKIN IS DAMP. SKIN ABSORPTION: NO DATA AVAILABLE. INHALATION: DUSTS MAY IRRITATE: MUCOUS MEMBRANES. UPPER RESPIRATORY TRACT, LONGS. INGESTION: MAY BE CORROSIVE TO THE GASTROINTESTINAL TRACT. SEVERE' IRRITATION AND BURNS MAY RESULT. MAY CAUSE: http://fplenergy.complyplus.comlMSDS/print_ bare. asp ?S=3168&ShowTOC= 1 &ShowHazardRatings= 1 ... Page 20f8 6117/2009 SODA ASH LIGHT by FMC NAUSEA. VOMITING. DIARRHEA. ABDOMINAL CRAMPS. GASTROINTESTINAL IRRITATION. CORROSION. LOW ACUTE TOXICITY.MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE TO PRODUCT: SKIN DISORDERS. RESPIRATORY SYSTEM DISORDERS. OTHER: NONE KNOWN.CANCER INFORMATION: THIS PRODUCT DOES NOT CONTAIN GREATER THAN 0.1% OF THE KNOWN OR POTENTIAL CARCINOGENS LISTED IN NTP, IARC, OR OSHA.POTENTIAL ENVIRONMENTAL EFFECTS: SEE SECTION 12.3. COMPOSITION/INFORMATION ON INGREDIENTS COMPONENT CAS NUMBER OSHA HAZARD % BY WT.SODIUM CARBONATE 497-19-8 YES >99.8%4. FIRSTAID MEASURES EYE CONTACT: IMMEDIATELY FLUSH EYES WITH PLENTY OF WATER FOR AT LEAST 15 MINUTES WHILE HOLDING EYELIDS OPEN. TILT HEAD TO AVOID CONTAMINATING UNAFFECTED EYE. GET IMMEDIATE MEDICAL ATTENTION. SKIN CONTACT: IMMEDIATELY FLUSH SKIN WITH PLENTY OF WATER WHILE REMOVING CONTAMINATED CLOTHING AND SHOES. DO NOT REUSE CLOTHING OR SHOES UNTIL CLEANED. IF IRRITATION DEVELOPS OR PERSISTS, GET MEDICAL ATTENTION. WASH WITH SOAP AND WATER. DO NOT APPLY OILS OR OINTMENTS UNLESS ORDERED BY THE PHYSICIAN. INHALATION: REMOVE TO FRESH AIR. IF BREATHING IS DIFFICULT, ADMINISTER OXYGEN. IF NOT BREATHING, GIVE ARTIFICIAL RESPIRATION, PREFERABLY MOUTH-TO-MOUTH. GET MEDICAL ATTENTION IMMEDIATELY. INGESTION: IF FULLY CONSCIOUS, DRINK A QUART OF WATER. DO NOT INDUCE VOMITING. CALL A PHYSICIAN IMMEDIATELY. IF UNCONSCIOUS OR IN CONVULSIONS, TAKE IMMEDIATELY TO A HOSPITAL OR A PHYSICIAN. NEVER INDUCE VOMITING OR GIVE ANYTHING BY MOUTH TO AN UNCONSCIOUS VICTIM. IF VOMITING OCCURS SPONTANEOUSLY, KEEP HEAD BELOW HIPS TO PREVENT ASPIRATION OF LIQUID INTO THE LUNGS.NOTE TO PHYSICIANS; THERE IS NO SPECIFIC ANTIDOTE. TREATMENT OF OVEREXPOSURE SHOULD BE DIRECTED AT THE CONTROL OF SYMPTOMS AND THE CLINICAL CONDITION OF THE PATIENT.5. FIRE FIGHTING MEASURES EXTINGUISHING MEDIA: NOT COMBUSTIBLE. FOR FIRES IN AREA USE APPROPRIATE MEDIA.FOR EXAMPLE: WATER SPRAY. DRY CHEMICAL. CARBON DIOXIDE. FOAM.Page 3 of 8 http://fplenergy.cOmpIyp~us.comIMSDS/print-bare.asp?S=3168&ShowTOC=I&ShowHazardRatings=l ... 6/17/2009 SODA ASH LIGHT by FMC NAUSEA. VOMITING. DIARRHEA. ABOOMINAL CRAMPS. GASTROINTESTINAL IRRITATION. CORROSION. LOW ACUTE TOXICITY. MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE TO PRODUCT: SKIN DISORDERS. RESPIRATORY SYSTEM DISORDERS. OTHER: NONE KNOWN. CANCER INFORMATION: THIS PRODUCT OOES NOT CONTAIN GREATER THAN O. 1% OF THE KNOWN OR POTENTIAL CARCINOGENS LISTED IN NTP, IARC, OR OSHA. poTENTIAL ENVIRONMENTAL EFFECTS: SEE SECTION 12. 3. COMPOSITION/INFORMATION ON INGREDIENTS COMPONENT CAS NUMBER OSHA HAZARD % BY WT. SODIUM CARBONATE 497-19-8 YES >99.8% 4. FIRSTAID MEASURES EYE CONTACT: IMMEDIATELY FLUSH EYES WITH PLENTY OF WATER FOR AT LEAST lS MINUTES WHILE HOLDING EYELIDS OPEN. TILT HEAD TO AVOID CONTAMINATING UNAFFECTED EYE. GET IMMEDIATE MEDICAL ATTENTION. SKIN CONTACT: IMMEDIATELY FLUSH SKIN WITH PLENTY OF WATER WHILE REMOVING CONTAMINATED CLOTHING AND SHOES. DO NOT REUSE CLOTHING OR SHOES UNTIL CLEANED. IF IRRITATION DEVELOPS OR PERSISTS, GET MEDICAL WASH WITH SOAP AND WATER. 00 NOT APPLY OILS OR OINTMENTS UNLESS ORDERED BY THE PHYSICIAN. INHALATION; REMOVE TO FRESH AIR. IF BREATHING IS DIFFICULT, ADMINISTER OXYGEN. IF NOT BREATHING, GIVE ARTIFICIAL RESPIRATION, PREFERABLY MOUTH-TO-MOUTH. GET MEDICAL ATTENTION IMMEDIATELY. INGESTION: IF FULLY CONSCIOUS, DRINK A QUART OF WATER. 00 NOT INDUCE VOMITING. CALL A PHYSICIAN IMMEDIATELY. IF UNCONSCIOUS OR IN CONVULSIONS, TAKE IMMEDIATELY TO A HOSPITAL OR A PHYSICIAN. NEVER INDUCE VOMITING OR GIVE ANYTHING BY MOUTH TO AN UNCONSCIOUS VICTIM. IF VOMITING OCCURS SPONTANEOUSLY, KEEP HEAD BELOW HIPS TO PREVENT ASPIRATION OF LIQUID INTO THE LUNGS. NOTE TO PHYSICIANS; THERE IS NO SPECIFIC ANTIDOTE. TREATMENT OF OVEREXPOSURE SHOULD BE DIRECTED AT THE CONTROL OF SYMPTOMS AND THE CLINICAL CONDITION OF THE PATIENT. 5. FIRE FIGHTING MEASURES EXTINGUISHING MEDIA; NOT COMBUSTIBLE. FOR FIRES IN AREA USE APPROPRIATE MEDIA. FOR EXAMPLE; WATER SPRAY. DRY CHEMICAL. CARBON DIOXIDE. FOAM. http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=3168&ShowTOC=1 &ShowHazardRatings= 1 ... Page 30f8 6117/2009 SODA ASH LIGHT by FMC Page 4 of 8 FIRE FIGHTING METHODS: EVACUATE AREA OF UNPROTECTED PERSONNEL. WEAR PROTECTIVE CLOTHING INCLUDING NIOSH-APPROVED SELF-CONTAINED BREATHING APPARATUS. FIRE AND EXPLOSION HAZARDS: NONE KNOWN.HAZARDOUS COMBUSTION PRODUCTS: CARBON DIOXIDE. SODIUM OXIDE.6. ACCIDENTAL RELEASE MEASURES SPILL CLEAN-UP PROCEDURES; EVACUATE UNPROTECTED PERSONNEL FROM AREA. MAINTAIN ADEQUATE VENTILATION. FOLLOW PERSONAL PROTECTIVE EQUIPMENT RECOMMENDATIONS FOUND IN SECTION 8. SWEEP UP MATERIAL INTO CONTAINERS AND DISPOSE OF PROPERLY. AVOID DUST FORMATION. FLUSH REMAINING AREA WITH WATER TO REMOVE TRACE RESIDUE AND DISPOSE OF PROPERLY.AVOID DIRECT DISCHARGE TO SEWERS AND SURFACE WATERS. NOTIFY AUTHORITIES IF ENTRY OCCURS.7. HANDLING AND STORAGE HANDLING: AVOID CONTACT WITH EYES, SKIN, AND CLOTHING. USE WITH ADEQUATE VENTILATION. DO NOT SWALLOW. WASH THOROUGHLY AFTER HANDLING. AVOID DUST OR MIST FORMATION. DO NOT EAT, DRINK, OR SMOKE IN WORK AREA.STORAGE: STORE IN A COOL, WELL VENTILATED AREA, OUT OF DIRECT SUNLIGHT. STORE IN A DRY LOCATION AWAY FROM HEAT. KEEP AWAY FROM INCOMPATIBLE MATERIALS. KEEP CONTAINERS TIGHTLY CLOSED. DO NOT STORE IN UNLABELED OR MISLABELED CONTAINERS. HYGROSCOPIC MATERIAL. AVOID CONTACT WITH MOISTURE. STORE IN CLOSED CONTAINERS. DO NOT USE ALUMINUM EQUIPMENT FOR STORAGE AND/OR TRANSFER. DEADLY CARBON MONOXIDE GAS CAN FORM IN ENCLOSED OR POORLY VENTILATED AREAS OR TANKS WHEN ALKALINE PRODUCTS CONTACT FOOD, BEVERAGE, OR DAIRY PRODUCTS. DO NOT ENTER SUCH AREAS UNTIL THEY HAVE BEEN WELL VENTILATED AND CARBON MONOXIDE AND OXYGEN LEVELS HAVE BEEN DETERMINED TO BE WITHIN OSHA ACCEPTABLE LIMITS. IF CARBON MONOXIDE AND OXYGEN LEVELS CANNOT BE MEASURED, WEAR NIOSH-APPROVED, SELF-CONTAINED BREATHING APPARATUS.

8. EXPOSURE CONTROLS/PERSONAL PROTECTION EXPOSURE GUIDELINES:

COMPONENT OSHA PEL OSHA STEL/C ACGIH TWA ACGIH STEL/C SODIUM CARBONATE NOT ESTAB. NOT ESTAB. NOT ESTAB. NOT ESTAB.NOTE:* RECOMMEND EXPOSURE LIMITS FOR PARTICULATES NOT OTHERWISE REGULATED/PARTICULATES (INSOLUBLE OR POORLY SOLUBLE) NOT OTHERWISE SPECIFIED: 15 MG/M3 (TOTAL DUST)5 MG/M3 (RESPIRABLE FRACTION)(OSHA) 3 MG/M3 (RESPIRABLE PARTICLES) 10 MG/M3 (INHALABLE PARTICLES)(ACGIH). http://fplenergy.complyplus.com/MSDS/printbare.asp?S=3168&ShowTOC= 1 &ShowHazardRatings=1 ... 6/17/2009 SODA ASH LIGHT by FMC FIRE FIGHTING METHODS: EVACUATE AREA OF UNPROTECTED PERSONNEL. WEAR PROTECTIVE CLOTHING INCLUDING NIOSH-APPROVED SELF-CONTAINED BREATHING APPARATUS. FIRE AND EXPLOSION HAZARDS: NONE KNOWN. HAZARDOUS COMBUSTION PRODUCTS: CARBON DlOXIDE. SODIUM OXIDE. 6. ACCIDENTAL RELEASE MEASURES SPILL CLEAN-UP PROCEDURES: EVACUATE UNPROTECTED PERSONNEL FROM AREA. MAINTAIN ADEQUATE VENTILATION. FOLLOW PERSONAL PROTECTIVE EQUIPMENT RECOMMENDATIONS FOUND IN SECTION 8. SWEEP UP MATERIAL INTO CONTAINERS AND DISPOSE OF PROPERLY. AVOID DUST FORMATION. FLUSH REMAINING AREA WITH WATER TO REMOVE TRACE RESIDUE AND DISPOSE OF PROPERLY. AVOID DIRECT DISCHARGE TO SEWERS AND SURFACE WATERS. NOTIFY AUTHORITIES IF ENTRY OCCURS. 7. HANDLING AND STORAGE HANDLING: AVOID CONTACT WITH EYES, SKIN, AND CLOTHING. USE WITH ADEQUATE VENTILATION. DO NOT SWALLOW. WASH THOROUGHLY AFTER HANDLING. AVOID DUST OR MIST FORMATION. DO NOT EAT, DRINK, OR SMOKE IN WORK AREA. STORAGE: STORE IN A COOL, WELL VENTILATED AREA, OUT OF DIRECT SUNLIGHT. STORE IN A DRY LOCATION AWAY FROM HEAT. KEEP AWAY FROM INCOMPATIBLE MATERIALS. KEEP CONTAINERS TlGHTLY CLOSED. DO NOT STORE IN UNLABELED OR MISLABELED CONTAINERS. HYGROSCOPIC MATERIAL. AVOID CONTACT WITH MOISTURE. STORE IN CLOSED CONTAINERS. DO NOT USE ALUMINUM EQUIPMENT FOR STORAGE AND/OR TRANSFER. DEADLY CARBON MONOXIDE GAS CAN FORM IN ENCLOSED OR POORLY VENTILATED AREAS OR TANKS WHEN ALKALINE PRODUCTS CONTACT FOOD, BEVERAGE, OR DAIRY PRODUCTS. DO NOT ENTER SUCH AREAS UNTIL THEY HAVE BEEN WELL VENTILATED AND CARBON MONOXIDE AND OXYGEN LEVELS HAVE BEEN DETERMINED TO BE WITHIN OSHA ACCBPTABLE LIMITS. IF CARBON MONOXIDE AND OXYGEN LEVELS CANNOT BE MEASURED, WEAR NIOSH-APPROVED, SELF-CONTAINED BREATHING APPARATUS.

8. EXPOSURE CONTROLS/PERSONAL PROTECTION EXPOSURE GUIDELINES:

COMPONENT OSHA PEL OSHA STELIC ACGIH TWA ACGIH STELle SODIUM CARBONATE NOT ESTAB. NOT ESTAB. NOT ESTAB. NOT ESTAB. NOTE:

• RECOMMEND EXPOSURE LIMITS FOR PARTICULATES NOT OTHERWISE REGULATED/PARTICULATES (INSOLUBLB OR POORLY SOLUBLE) NOT OTHERWISE SPECIFIED:

l5 MG/M3 (TOTAL DUST) 5 MG/M3 (RESPIRABLE FRACTION) (OSHA) 3 MG/M3 (RESPIRABLE PARTICLES) 10 Ma/M3 (INHALABLE PARTICLES) (ACGIH) . http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=3168&ShowTOC= 1 &ShowHazardRatings= 1 ... Page 4 of8 6/17/2009 SODA ASH LIGHT by FMC Page 5 of 8 ENGINEERING CONTROLS: GENERAL ROOM VENTILATION IS REQUIRED. TO KEEP EXPOSURE BELOW ESTABLISHED LIMITS, LOCAL EXHAUST MAY BE NECESSARY. MAINTAIN ADEQUATE VENTILATION. DO NOT USE IN CLOSED OR CONFINED SPACES. AVOID CREATING DUST OR MIST.EYE/FACE PROTECTION: WEAR SAFETY GLASSES WITH SIDE SHIELDS WHILE HANDLING THIS PRODUCT. WEAR ADDITIONAL EYE PROTECTION SUCH AS CHEMICAL SAFETY GOGGLES WHEN THE POSSIBILITY EXISTS FOR EYE CONTACT WITH SPLASHING OR SPRAYING LIQUID, OR AIRBORNE MATERIAL.DO NOT WEAR CONTACT LENSES.SKIN PROTECTION: PREVENT CONTACT WITH THIS PRODUCT. WEAR GLOVES AND PROTECTIVE CLOTHING DEPENDING ON CONDITION OF USE.PROTECTIVE GLOVES: CHEMICAL-RESISTANT. RESPIRATORY PROTECTION: RESPIRATORY PROTECTION MUST BE WORN IF VENTILATION DOES NOT ELIMINATE SYMPTOMS OR KEEP LEVELS BELOW RECOMMENDED EXPOSURE LIMITS.IF EXPOSURE LIMITS ARE EXCEEDED, WEAR: NIOSH-APPROVED RESPIRATOR FOR DUSTS AND MISTS. DO NOT EXCEED LIMITS ESTABLISHED BY THE RESPIRATOR MANUFACTURER. ALL RESPIRATORY PROTECTION PROGRAMS MUST COMPLY WITH OSHA 29 CFR 1910.134 AND ANSI Z88.2 REQUIREMENTS AND MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS REQUIRE A RESPIRATOR'S USE.OTHER PROTECTIVE EQUIPMENT: EYE-WASH STATION. SAFETY SHOWER. RUBBER APRON. CHEMICAL SAFETY SHOES.PROTECTIVE CLOTHING.GENERAL HYGIENE CONDITIONS: WASH WITH SOAP AND WATER BEFORE MEAL TIMES AND AT THE END OF EACH WORK SHIFT.GOOD MANUFACTURING PRACTICES REQUIRE GROSS AMOUNTS OF ANY CHEMICAL BE REMOVED FROM SKIN AS SOON AS PRACTICAL, ESPECIALLY BEFORE EATING OR SMOKING.9. PHYSICAL AND CHEMICAL PROPERTIES PHYSICAL STATE: GRANULES.COLOR: WHITE. ODOR: NO ODOR.BOILING POINT (DEG. F): 752 (DECOMPOSES) FREEZING POINT (DEG. F): N.D.MELTING POINT (DEG. F): 1564 VAPOR PRESSURE (MMHg): N.A.VAPOR DENSITY (AIR=1): N.A.SOLUBILITY IN WATER: 33.2t MAXIMUM pH: 11.4 (1I SOLUTION)http://fplenergy.complyplus.com/MSDS/print-bare.asp?S=3168&ShowTOC=I&ShowHazardRatings=l... 6/17/2009 SODA ASH LIGHT by FMC ENGINEERING CONTROLS: GENERAL ROOM VENTILATION IS REQUIRED. TO KEEP EXPOSURE BELOW ESTABLISHED LIMITS, LOCAL EXHAUST MAY BE NECESSARY. MAINTAIN ADEQUATE VENTILATION. DO NOT USE IN CLOSED OR CONFINED SPACES. AVOID CREATING DUST OR MIST. EYE/FACE PROTECTION: WEAR SAFETY GLASSES WITH SIDE SHIELDS WHILE HANDLING THIS PRODUCT. WEAR ADDITIONAL EYE PROTECTION SUCH AS CHEMICAL SAFETY GOGGLES WHEN THE POSSIBILITY EXISTS FOR EYE CONTACT WITH SPLASHING OR SPRAYING LIQUID, OR AIRBORNE MATERIAL. DO NOT WEAR CONTACT LENSES. SKIN PROTECTION: PREVENT CONTACT WITH THIS PRODUCT. WEAR GLOVES AND PROTECTIVE CLOTHING DEPENDING ON CONDITION OF USE. PROTECTIVE GLOVES: CHEMICAL-RESISTANT. RESPIRATORY PROTECTION: RESPIRATORY PROTECTION MUST BE WORN IF VENTILATION DOES NOT ELIMINATE SYMPTOMS OR KEEP LEVELS BELOW RECOMMENDED EXPOSURE LIMITS. IF EXPOSURE LIMITS ARE EXCEEDED, WEAR: NIOSH-APPROVED RESPIRATOR FOR DUSTS AND MISTS. DO NOT EXCEED LIMITS ESTABLISHED BY THE RESPIRATOR MANUFACTURER. ALL RESPIRATORY PROTECTION PROGRAMS MOST COMPLY WITH OSHA 29 CFR 1910.134 AND ANSI ZSS.2 REQUIREMENTS AND MOST aE FOLLOWED WHENEVER WORKPLACE CONDITIONS REQUIRE A RESPIRATOR'S USE. OTHER PROTECTIVE EQUIPMENT: EYE-WASH STATION. SAFETY SHOWER. RUSBER APRON. CHEMICAL SAFETY SHOES. PROTECTIVE CLOTHING. GENERAL HYGIENE CONDITIONS: WASH WITH SOAP AND WATER BEFORE MEAL TIMES AND AT THE END OF EACH WORK GOOD MANUFACTURING PRACTICES REQUIRE GROSS AMOUNTS OF ANY CHEMICAL BE REMOVED FROM SKIN AS SOON AS PRACTICAL, ESPECIALLY BEFORE EATING OR SMOKING. 9. PHYSICAL AND CHEMICAL PROPERTIES PHYSICAL STATE: GRANULES. COLOR: WHITE. ODOR: NO ODOR. BOILING POINT (DEG. F): 752 (DECOMPOSES) FREEZING POINT (DEG. F): N.D. MELTING POINT (DEG. F): 1564 VAPOR PRESSORE (MMHg): N .A. VAPOR DENSITY (AIR=l): N.A. SOLUBILITY IN WATER, 33.2% MAXIMUM pM: 11.4 (1% SOLUTION) http://fplenergy.complyplus.comIMSDS/print _ bare.asp ?S=3168&ShowTOC= 1 &ShowHazardRatings::::; 1 ... Page 5 of8 6117/2009 SODA ASH LIGHT by FMC SPECIFIC GRAVITY: 0.70 -0.90 G/ML% VOLATILE (WT %): N.A EVAPORATION RATE (nBuAc = 1): N.A.VOC (WT %)-: 0 VOC (LBS/GAL): 0VISCOSITY: N.D. FLASH POINT: N.A.FLASH POINT METHOD: N.A.LOWER EXPLOSION LIMIT: N.A.UPPER EXPLOSION LIMIT: N.A.AUTOIGNITION TEMPERATURE: N.A.10. STABILITY AND REACTIVITY Page 6 of 8 STABILITY: STABLE UNDER NORMAL CONDITIONS. CONDITIONS TO AVOID: HYGROSCOPIC MATERIAL. AVOID CONTACT WITH MOISTURE.INCOMPATIBLE MATERIALS: ACIDS. FLUORINE. LITHIUM. ALUMINUM. MAGNESIUM. STEEL. PHOSPHOROUS PENTOXIDE. 2,4,6-TRINITROTOLUENE. SULFURIC ACID. SODA ASH AND LIME DUST (CALCIUM OXIDE) IN THE PRESENCE OF MOISTURE MAY FORM CORROSIVE CAUSTIC SODA. FOOD SUGARS.HAZARDOUS DECOMPOSITION PRODUCTS: CARBON DIOXIDE. SODIUM OXIDE. CARBON MONOXIDE.POSSIBILITY OF HAZARDOUS REACTIONS: HAZARDOUS POLYMERIZATION WILL NOT OCCUR UNDER NORMAL CONDITIONS. REACTS WITH.ACIDS AND RELEASES LARGE VOLUMES OF CARBON DIOXIDE GAS AND HEAT. REACTIONS WITH VARIOUS FOOD SUGARS MAY FORM CARBON MONOXIDE.11. TOXICOLOGICAL INFORMATION LD5O ORAL: RAT: 4090 MG/KGLD50 SKIN: RABBIT: >2,000 MG/KG LC50 INHALATION: RAT: 2300 MG/M3/2H RAT: 2.3 MG/L/2H FOR DETAILED TOXICOLOGICAL INFORMATION ON THIS PRODUCT, CONTACT THE ADDRESS IN SECTION 1 OF THIS MSDS.http://fplenergy.complypius.comIMSDS/print-bare.asp?S=3168&ShowTOC=1&ShowHazardRatings=l... 6/17/2009 SODA ASH LIGHT by FMC SPECIFIC GRAVITY: 0.70 -0.90 G/ML % VOLATILE (WT %): N.A EVAPORATION RATE (nBuAc 1): N.A. VOC (W'r %): ° VOC (LBS/GAL): ° VISCOSITY: N.D. FLASH POINT: N.A. FLASH POINT METHOD: N.A. LOWER EXPLOSION LIMIT: N.A. UPPER EXPLOSION LIMIT: N.A. AUTOIGNITION TEMPERATURE: N .A. 10. STABILITY AND REACTIVITY STABILITY: STABLE UNDER NORMAL CONDITIONS. CONDITIONS TO AVOID: HYGROSCOPIC MATERIAL. AVOID CONTACT WITH MOISTURE. INCOMPATIBLE MATERIALS: ACIDS. FLUORINE. LITHIUM. ALUMINUM. MAGNESIUM. STEEL. PHOSPHOROUS PENTOXIDE. 2,4,6-TRINITROTOLUENE. SULFURIC ACID. SODA ASH AND LIME DUST (CALCIUM OXIDE) IN THE PRESENCE OF MOISWRE MAY FORM CORROSIVE CAUSTIC SODA. FOOD SUGARS. HAZARDOUS DECOMPOSITION PRODUCTS: CARBON DIOXIDE. SODIUM OXIDE. CARBON MONOXIDE. POSSIBILITY OF HAZARDOUS REACTIONS: HAZARDOUS POLYMERIZATION WILL NOT OCCUR UNDER NORMAL CONDITIONS. REACTS WITH. ACIDS AND RELEASES LARGE VOLUMES OF CARBON DIOXIDE GAS AND HEAT. REACTIONS WITH VARIOOS POOD SUGARS MAY FORM CARBON MONOXIDE.

11. TOXICOLOGICAL INFORMATION LD50 ORAL, RAT: 4090 MG/KG LD50 SKIN: RABBIT: >2,000 MG/KG LCSO INHALATION:

RAT: 2300 MG/M3/2H RAT: 2.3 MG/L/2H FOR DETAILED TOXICOLOGICAL INFORMATION ON THIS PRODUCT, CONTACT THE ADDRESS IN SECTION 1 OF THIS MSDS. http://fplenergy.complyplus.comIMSDS/print_ bare.asp?S=3168&ShowTOC= 1 &ShowHazardRatings= 1 ... Page 60f8 6/17/2009 SODA ASH LIGHT by FMC Page 7 of 8 12. ECOLOGICAL INFORMATION ECOTOXICOLOGICAL INFORMATION; EXTENSIVE DATA, CALL FOR INFORMATION. CHEMICAL FATE INFORMATION: EXTENSIVE DATA, CALL FOR INFORMATION.

13. DISPOSAL CONSIDERATIONSHAZARDOUS WASTE NUMBER: N.A.DISPOSAL METHOD: DISPOSE OF IN ACCORDANCE WITH ALL LOCAL, STATE AND FEDERAL REGULATIONS.

DISPOSE IN CLOSED CONTAINERS AT AN APPROVED LANDFILL. REGULATIONS MAY VARY IN DIFFERENT LOCATIONS. WASTE CHARACTERIZATIONS AND COMPLIANCE WITH APPLICABLE LAWS ARE THE RESPONSIBILITY SOLELY OF THE WASTE GENERATOR.

14. TRANSPORTATION INFORMATION DOT (DEPARTMENT OF TRANSPORTATION):

PROPER SHIPPING NAME: NOT REGULATED BY THE DOT.IDENTIFICATION NUMBER: N.A.PACKING GROUP: N.A.15. REGULATORY INFORMATION U.S. FEDERAL REGULATIONS: TSCA INVENTORY STATUS: THIS PRODUCT OR ALL COMPONENTS OF THIS PRODUCT ARE LISTED ON THE EPA/TSCA INVENTORY OF CHEMICAL SUBSTANCES. SARA TITLE III SECTION 311/312 CATEGORY: IMMEDIATE (ACUTE) HEALTH HAZARD: Y DELAYED (CHRONIC) HEALTH HAZARD: N FIRE HAZARD: N SUDDEN RELEASE OF PRESSURE HAZARD: N REACTIVE HAZARD: N SARA SECTION 302/304/313/HAP: COMPONENT CERCLA RQ SARA RQ SARA TPQ SARA 313 U.S. HAP SODIUM CARBONATE N.A. N.A. N.A. NO NO U.S. STATE REGULATIONS: CALIFORNIA -THE FOLLOWING COMPONENTS ARE LISTED UNDER PROPOSITION 65: LEAD (10 PPM MAX.)ARSENIC (3 PPM MAX.)WISCONSIN -THE FOLLOWING COMPONENTS ARE LISTED AS A WISCONSIN HAP: NONE.http://fplenergy.complyplus.com/MSDS/print-bare.asp?=3 1 68&ShowTOC= I &ShowHazardRatings=1... 6/17/2009 SODA ASH LIGHT by FMC 12. ECOLOGICAL INFORMATION ECOTOX I COLOG I CAL INFORMATION; EXTENSIVE DATA, CALL FOR INFORMATION. CHEMICAL FATE INFORMATION; EXTENSIVE DATA, CALL FOR INFORMATION.

13. DISPOSAL CONSIDERATIONS HAZARDOUS WASTE NUMBER: N.A. DISPOSAL METHOD: DISPOSE OF IN ACCORDANCE WITH ALL LOCAL, STATE AND FEDERAL REGULATIONS.

DISPOSE IN CLOSED CONTAINERS AT AN APPROVED LANDFILL. REGULATIONS MAY VARY IN DIFFERENT LOCATIONS. WASTE CHARACTERIZATIONS AND COMPLIANCE WITH APPLICABLE LAWS ARE THE RESPONSIBILITY SOLELY OF THE WASTE GENERATOR.

14. TRANSPORTATION INFORMATION DOT (DEPARTMENT OF TRANSPORTATION)

PROPER SHIPPING NAME: NOT REGULATED BY THE DOT. IDENTIFICATION NUMBER: N.A. PACKING GROUP: N.A. 15. REGULATORY INFORMATION U.S. FEDERAL REGULATIONS:

TSCA INVENTORY STATUS: THIS PRODUCT OR ALL COMPONENTS OF THIS PRODUCT ARE LISTED ON THE EPA/TSCA INVENTORY OF CHEMICAL SUBSTANCES. SARA TITLE III SECTION 311/312 CATEGORY: IMMEDIATE (ACUTE) HEALTH HAZARD: Y DELAYED (CHRONIC) HEALTH HAZARD: N FIRE HAZARD: N SUDDEN RELEASE OF PRESSURE HAZARD: N REACTIVE HAZARD: N SARA SECTION 302/304/313/HAP: COMPONENT CERCLA RQ SARA RQ SARA TPQ SARA 313 SODIUM CARBONATE N.A. N.A. N.A. NO U.S. STATE REGULATIONS: U.S. HAP NO CALIFORNIA -THE FOLLOW!NG COMPONENTS ARE LISTED UNDER PROPOSITION 65: LEAD (10 PPM MAX.) ARSENIC (3 PPM MAX.) WISCONSIN -THE FOLLOWING COMPONENTS ARE LISTED AS A WISCONSIN HAP, NONB. http://fplenergy.complyplus.com/MSDS/print_ bare.asp?S=3168&ShowTOG= 1 &ShowHazardRatings= 1 ... Page 70f8 6117/2009 SODA ASH LIGHT by FMC Page 8 of 8 16. ADDITIONAL INFORMATION HYDRITE RATING SYSTEM: HEALTH 2 FLAMMABILITY 0 REACTIVITY 0* = CHRONIC HEALTH HAZARDNFPA RATING SYSTEM: HEALTH 2 FLAMMABILITY 0 REACTIVITY 0 SPECIAL HAZARD NONE MSDS ABBREVIATIONS: N.A. = NOT APPLICABLE N.D. = NOT DETERMINED HAP = HAZARDOUS AIR POLLUTANT VOC = VOLATILE ORGANIC COMPOUND C = CEILING LIMIT N.E./NOT ESTAB. = NOT ESTABLISHED MSDS PREPARED BY: NAOREASON FOR REVISION: NEW FORMAT. CHANGES MADE THROUGHOUT THE MSDS.THE DATA IN THIS MATERIAL SAFETY DATA SHEET RELATES TO THE SPECIFIC MATERIAL DESIGNATED AND DOES NOT RELATE TO ITS USE IN COMBINATION WITH ANY OTHER MATERIAL OR PROCESS. THE DATA CONTAINED IS BELIEVED TO BE CORRECT. HOWEVER, SINCE CONDITIONS OF USE ARE OUTSIDE OUR CONTROL IT SHOULD NOT BE TAKEN AS WARRANTY OR REPRESENTATION FOR WHICH HYDRITE CHEMICAL CO. ASSUMES LEGAL RESPONSIBILITY. THIS INFORMATION IS PROVIDED SOLELY FOR YOUR CONSIDERATION, INVESTIGATION, AND VERIFICATION. Copyright@ 1999-2009 Dolphin Software, Inc.Comply Plus Web -Hosted FPL Energyhttp:l/fplenergy.complyplus.comIMSDS/printbare.asp?S=3168&ShowTOC= 1 &ShowHazardRatings=1 ... 6/17/2009 SODA ASH LIGHT by FMC 16. ADDITIONAL INFORMATION HYDRITE RATING SYSTEM: HEALTH 2 FLAMMABILITY 0 REACTIVITY 0 .. = CHRONIC HEALTH HAZARD NFPA RATING SYSTEM: HEALTH 2 FLAMMABILITY 0 REACTIVITY 0 SPECIAL HAZARD NONE MSDS ABBREVIATIONS: N.A. = NOT APPLICABLE N.D. = NOT DETERMINED HAP = HAZARDOUS AIR POLLUTANT VOC c VOLATILE ORGANIC COMPOUND C = CEILING LIMIT N.E./NOT ESTAB. = NOT ESTABLISHED MSDS PREPARED BY: NAO REASON FOR REVISION: NEW FORMAT. CHANGES MADE THROUGHOUT THE MSDS. THE DATA IN THIS MATERIAL SAFETY DATA SHEET RELATES TO THE SPECIFIC MATERIAL DESIGNATED AND DOES NOT RELATE TO ITS USE IN COMBINATION WITH ANY OTHER MATERIAL OR PROCESS. THE DATA CONTAINED IS BELIEVED TO BE CORRECT. HOWEVER, SINCE CONDITIONS OF USE ARE OUTSIDE OUR CONTROL IT SffOOLD NOT BE TAKEN AS WARRANTY OR REPRESENTATION FOR WHICK KYDRITE CHEMICAL CO. ASSUMES LEGAL RESPONSIBILITY. THIS INFORMATION IS PROVIDED SOLELY FOR YOUR CONSIDERATION, INVESTIGATION, AND VERIFICATION. Copyright@1999-2009 Dolphin Software, Inc. Comply Plus Web -Hosted FPL Energy http://fplenergy.complyplus.comlMSDS/print_ bare.asp?S=3168&ShowTOC= 1 &ShowHazardRatings=I ... Page 80f8 6/17/2009 Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D.2 NextEra Energy Resources, 2008, Recovery Phase Plan Outline EPIP 5.2. updated June 18.Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641

0.2 NextEra

Energy Resources, 2008, Recovery Phase Plan Outline EPIP 5.2. updated June 18. Recovery Phase Plan Outline EPIP 5.2 (Updated 6/17/08 1100)1. INTRODUCTION A particularly wet and rainy spring, combined with heavy rain showers throughout the Upper Midwest, resulted in flooding'of the Cedar River valley. When DAEC became aware of forecasted river levels, flood preparations began. AOP 902 Flood was entered on June 8th. River levels continued to rise as DAEC, along with nearby towns, performed sandbagging and other flood preparation activities. The river crested on Friday June 13 th at 751.0 feet MSL (DAEC indication). The crest in Cedar Rapids occurred at 1500 on June 14th, at 31.12 feet (150,000 cfs flow).The rising river level flooded the Palo communication building which caused a loss of several communications methods at DAEC including the commercial telephone system, FTS 2000, data transmission connectivity. When flood waters reached the Alliant Tower in Cedar Rapids and power was lost at the tower, the DAEC microwave phone systembecame inoperable. An Unusual Event SU6.2, major loss of communication capabilities, was declared on June 12 th. The ERO was not activated because the site had been previously staffed with the individuals needed to support flooding preparation andresponse activities. During the initial loss of Communications, the NRC initiated the Incident Response Team and staffed in Region 3. Communications with the region were initiallycontinuous, then went to every 3 hours and ultimately the IRT was secured when communications were restored through Shellsburg Farmer Mutual phone company (06-16-08 at 0100).Site access was challenged, as Blairs Ferry Road, Lewis Access Road (from CenterPoint) Urbana Bridge over the Cedar, Hwy 94, and Palo Marsh Road were all closed.The only access over the Cedar River that remained open during the event was the 1-380 bridge. The plant South Access road also went under water, provisions were set up in advance to have employees park at the Pleasant Creek Park and were shuttled back and forth via rented vans to the North Access road (this occurred for approximately 2 days, at the crest of 751 feet, this road was approx 3 -5" under water). During this time, only essential personnel were told to report, all remaining employees were given the Thursday and Friday off to stay home and be available if needed. At the worst point, Site access was via 1-3 80, the Hwy 30 to Benton-Linn road then gravel to the plant.As the water receded, various access roads were restored. The Blairs Ferry road between the bridges was severely damaged and only remained available in emergency situations while repairs were completed. The Lewis Access road to Center Point was extremely damaged as major sections of the road were washed out.U:\NGDSHARE\Flood 2008\Recovery Plan.doc r 1. INTRODUCTION Recovery Phase Plan Outline EPIP 5.2 (Updated 6/17/08 11 00) A particularly wet and rainy spring, combined with heavy rain showers throughout the Upper Midwest, resulted in flooding 'of the Cedar River valley. When DAEC became aware of forecasted river levels, flood preparations began. AOP 902 Flood was entered on June 8 th. River levels continued to rise as DAEC, along with nearby towns, performed sandbagging and other flood preparat{on activities. The river crested on Friday June 13 th at 751.0 feet MSL (DAEC indication). The crest in Cedar Rapids occurred at 1500 on June 14t\ at 31.12 feet (150,000 cfs flow). The rising river level flooded the Palo communication building which caused a loss of several communications methods at DAEC including the commercial telephone system, FTS 2000, data transmission connectivity. When flood waters reached the Alliant Tower in Cedar Rapids and power was lost at the tower, the DAEC microwave phone system became inoperable. An Unusual Event SU6.2, major loss of communication capabilities, was declared on June lih. The ERO was not activated because the site had been previously staffed with the individuals needed to support flooding preparation and response activities. During the initial loss of Communications, the NRC initiated the Incident Response Team and staffed in Region 3. Communications with the region were initially continuous, then went to every 3 hours and ultimately the IR T was secured when communications were restored through Shellsburg Farmer Mutual phone company (06-16-08 at 0100). Site access was challenged, as Blairs Ferry Road, Lewis Access Road (from Center Point) Urbana Bridge over the Cedar, Hwy 94, and Palo Marsh Road were all closed. The only access over the Cedar River that remained open during the event was the I-380 bridge. The plant South Access road also went under water, provisions were set up in advance to have employees park at the Pleasant Creek Park and were shuttled back and forth via rented vans to the North Access road (this occurred for approximately 2 days, at the crest of 751 feet, this road was approx 3 -5" under water). During this time, only essential personnel were told to report, all remaining employees were given the Thursday and Friday off to stay home and be available if needed. At the worst point, Site access was via I-380, the Hwy 30 to Benton-Linn road then gravel to the plant. As the water receded, various access roads were restored. The Blairs Ferry road between the bridges was severely damaged and only remained available in emergency situations while repairs were completed. The Lewis Access road to Center Point was extremely damaged as major sections of the road were washed out. U :\NGDSHARE\Flood 2008\Recovery Plan.doc The 30 and 60 minute responders were staffed at the station during the event to ensure response times could be met. Once the majority of the roads, and the Blairs Ferry Bridge access was provided in an emergency, the 60 minute responders were let go (6-18-08 at 1900). The 30 Minute responders were maintained until the replacement Pager notification system was working and all phone systems were completed and verified.River levels are lowering at this time and site recovery actions are in progress.2. OBJECTIVES A. Assess damage to the site B. Monitor plant equipment C. Re-gain access to those areas of the plant that became isolated due to flood waters.3. RECOVERY ORGANIZATION A. DAEC (TSC)Staffing PlanCurrent staffing will continue until access to the plant from surrounding areas is such that there are no uncertainties with people being able to get to the plant in the required time (i.e. 30 minute responders, 60 minute responders, etc.). Additional staff will be utilized as necessary to complete recovery actions. B. EOF (Not Staffed)4. FACILITIES INVOLVED IN THE RECOVERY EFFORT A. DAEC -Includes TSC, Juno Beach staff, and various contracted services B. EOF -Not staffed 5. RECOVERY SCHEDULECurrent recovery is dependent on confidence in the current communications capabilities established via Shellsburg. In addition, the ability to meet the 30 minute response positions is of concern due to the limited access routes to the plant. Communications needed to exit the NOUE most likely could be verified in-place as soon as Monday dayshift. However, site access via various roads is still limited, and the timeline to restoration is not fully understood.In addition, there are several DAEC Flood AOP procedure recovery actions, which are described below.U:\NGDSHARE\Flood 2008\Recovery Plan.doc The 30 aild 60 minute responders were staffed at the station during the event to ensure response times could be met. Once the majority of the roads, and the Blairs Ferry Bridge access was provided in an emergency, the 60 minute responders were let go (6-18-08 at 1900). The 30 Minute responders were maintained until the replacement Pager notification system was working and all phone systems were completed and verified. River levels are lowering at this time and site recovery actions are in progress.

2. OBJECTIVES A. Assess damage to the site B. Monitor plant equipment C. Re-gain access to those areas of the plant that became isolated due to flood waters. 3. RECOVERY ORGANIZATION A. DAEC (TSC) Staffing Plan Current staffing will continue until access to the plant from surrounding areas is such that there are no uncertainties with people being able to get to the plant in the required time (i.e. 30 minute responders, 60 minute responders, etc.). Additional staff will be utilized as necessary to complete recovery actions. B. EOF (Not Staffed) 4. FACILITIES INVOLVED IN THE RECOVERY EFFORT A. DAEC -Includes TSC, Juno Beach staff, and various contracted services B. EOF -Not staffed 5. RECOVERY SCHEDULE Current recovery is dependent on confidence in the current communications capabilities established via Shellsburg.

In addition, the ability to meet the 30 minute response positions is of concern due to the limited access routes to the plant. Communications needed to exit the NOUE most likely could be verified in-place as soon as Monday day shift. However, site access via various roads is still limited, and the time line to restoration is not fully understood. In addition, there are several DAEC Flood AOP procedure recovery actions, which are described below. U:\NGDSHARE\Flood 2008\Recovery Plan.doc

6. COST ESTIMATES Currently, no specific dedicated cost reporting structure is set up to track costs associated with the NOUE. There will be certain services and material expenses associated with the efforts to re-establish communications.

7. RECOVERY ACTIONS Communications We have now:Hard Line Satellite Phone with access in the Control Room and TSCHard Line Cell Phone in the Control RoomHard Line Cell Phone in the TSC The NRC ENS/FTS lines (17) Portable Satellite Phones in various locations (8) 800 MHz Phones functionally tested Fiber optic line through Shellsburg (Farmers Mutual)" Long distance capability incoming and outgoing" Local service outgoing and incoming" Internet access and email fully functional" ERDS restored and tested Working on now: 1. Microwave Phone system -Currently working with Alliant to re-establish communications using Kirkwood microwave. (Complete)

2. Sprint Satellite on Wheels

-voice cell phone. Would be more phones, but still all the drawbacks of cell phones, tower loss. Tim Lewis and Manny Cano are coordinating from Juno. (Not pursuing as an option)3. Satellite Van through Sprint -would tap the van into our PBX to allowconnectivity through all phones on site. Tim Lewis and Manny Cano coordinating from Juno. (Not Pursuing as an option)4. Shellsburg Telecommunications -The fiber-optic lines have been installed and connected to Shellsburg service and this has been connected into the plant PBX. Currently all long-distance service in and out are fully functional. Local service full capability to call outbut incoming local calls are not fully functioning. Technicians are still troubleshooting local incoming service and repairs. (Complete-Full Service local/long distance provided).

5. Initial entry into Palo Phone Company has been made to assess damage. Recovery is not a short term solution based on the extent of damage; this includes the ENS communications lines. (Completed

-Internet connection restored, phones re energized. Site phones were not transferred back to Palo Co-op)U:\NGDSHARE\Flood 2008\Recovery Plan.doc 6. COST ESTIMATES Currently, no specific dedicated cost reporting structure is set up to track costs associated with the NOUE. There will be certain services and material expenses associated with the efforts to re-establish communications.

7. RECOVERY ACTIONS Communications We have now: Hard Line Satellite Phone with access in the Control Room and TSC Hard Line Cell Phone in the Control Room Hard Line Cell Phone in the TSC The NRC ENS/FTS lines (17) Portable Satellite Phones in various locations (8) 800 MHz Phones functionally tested Fiber optic line through Shellsburg (Farmers Mutual)

• Long distance capability incoming and outgoing
• Local service outgoing and incoming
• Internet access and email fully functional
• ERDS restored and tested Working on now: 1. Microwave Phone system -Currently working with Alliant to establish communications using Kirkwood microwave. (Complete)

2. Sprint Satellite on Wheels -voice cell phone. Would be more phones, but still all the drawbacks of cell phones, tower loss. Tim Lewis and Manny Cano are coordinating from Juno. (Not pursuing as an option) 3. Satellite Van through Sprint -would tap the van into our PBX to allow connectivity through all phones on site. Tim Lewis and Manny Cano coordinating from Juno. (Not Pursuing as an option) 4. Shellsburg Telecommunications

-The fiber-optic lines have been installed and connected to Shellsburg service and this has been connected into the plant PBX. Currently all long-distance service in and out are fully functional. Local service full capability to call out but incoming local calls are not fully functioning. Technicians are still troubleshooting local incoming service and repairs. (Complete-Full Service local/long distance provided).

5. Initial entry into Palo Phone Company has been made to assess damage. Recovery is not a short term solution based on the extent of damage; this includes the ENS communications lines.

Internet connection restored, phones re energized. Site phones were not transferred back to Palo Co-op) U:\NGDSHARE\Flood 2008\Recovery Plan.doc

6. Private Satellite Phone solution.

Looking for a private company with a satellite phone van we can get. Tom Coates and Manny Cano in Juno are coordinating. (Not being pursued at this time)7. 2 Verizon and 3AT&T wireless card for laptops to try for data connectivity through them. Manny Cano in Juno is coordinating. (Not being pursued at this time)8. Blackberry Tether -tether a blackberry to a laptop to use the blackberry as a modem for data connectivity. Manny Cano in Juno coordinating. (Not being pursued at this time)9. Fax capability from Satellite/Cell Phone systems. Manny Cano coordinating from Juno. (Not being pursued at this time)10. ViaSat has a satellite receiver on site and is available as a back-up system.Plant South Access Recovered (Completed 6/13/08)Transformer (XR1) has been re-energized. Security kiosk is powered. Security has tested their equipment and it is functioning sat. Water initially flowed over the road at an indicated river level of 750.45 feet. The South Access road was restored on June 13th and normal plant access is via that entrance.Area Recovery We have no internal flooding in the power block. Some outbuildings have undergone flooding. People and equipment have been moved to higher areas. The Mechanics and Mechanical Planners are being moved to the second floor of the warehouse. Areas are being recovered. Specific actions are listed under "Other Follow-up Activities". Communication to Employees Site wide communications has been developed and will be handed to each employee as they arrive on site Monday June 16, 2008. During the course of the flooding, several site wide communications were written and communicated, as well as the phone hot line provided STP Coordination STPs that were scheduled for the week of June 7 th, but were delayed due to the flood response are being worked as time and staff resources allow. STPs that are scheduled for the week of June 14 th have been reviewed for possible rescheduling due to staff resources or plant condition restrictions. U:\NGDSHARE\Flood 2008\Recovery Plan.doc 6. Private Satellite Phone solution. Looking for a private company with a satellite phone van we can get. Tom Coates and Manny Cano in Juno are coordinating. (Not being pursued at this time) 7. 2 Verizon and 3AT&T wireless card for laptops to try for data connectivity through them. Manny Cano in Juno is coordinating. (Not being pursued at this time) 8. Blackberry Tether -tether a blackberry to a laptop to use the blackberry as a modem for data connectivity. Manny Cano in Juno coordinating. (Not being pursued at this time) 9. Fax capability from Satellite/Cell Phone systems. Manny Cano coordinating from Juno. (Not being pursued at this time) 10. ViaSat has a satellite receiver on site and is available as a back-up system. Plant South Access Recovered (Completed 6/13/08) Transformer (XR1) has been re-energized. Security kiosk is powered. Security has tested their equipment and it is functioning sat. Water initially flowed over the road at an indicated river level of750.45 feet. The South Access road was restored on June 13 th and normal plant access is via that entrance. Area Recovery We have no internal flooding in the power block. Some outbuildings have undergone flooding. People and equipment have been moved to higher areas. The Mechanics and Mechanical Planners are being moved to the second floor of the warehouse. Areas are being recovered. Specific actions are listed under "Other Follow-up Activities". Communication to Employees Site wide communications has been developed and will be handed to each employee as they arrive on site Monday June 16,2008. During the course of the flooding, several site wide communications were written and communicated, as well as the phone hot line provided STP Coordination STPs that were scheduled for the week of June i\ but were delayed due to the flood response are being worked as time and staff resources allow. STPs that are scheduled for the week of June 14th have been reviewed for possible rescheduling due to staff resources or plant condition restrictions. U:\NGDSHARE\Flood 2008\Recovery Plan.doc A contingency plan has been developed for the performance of STP 3.3.1.1-22 Auto Scram Functional Test. This STP results in half scrams and will need to be carefully controlled while the plant is in a more vulnerable position due to the grid status. Drop dead for this STP is 6/17 0100.Other STPs to be performed from 6/7 week:3.3.1.1-29A1 Rx Lo water level (RPS) response time check -test equipment problems 3.5.1-03A CS sim auto actuation due 11/11 NS 13A002 Fire Supervisory due 6/27 3.5.1-04 LPCI sim auto actuation due 8/7 3.8.1-11 B done for day due to IKIOD inop 3.8.1-11 A SBDG aux. due 7/5 STPs for 6/14 week that should be considered for rescheduling: 3.8.7-01 LPCI swing bus UV trans test due 7/153.5.1-04 LPCI sim auto actuation due 7/25 3.3.6.1-47 HPCI exh diaphragm funct drop dead 7/8 3.5.1-05 HPCI quarterly run 7/2 Equipment Issues* HWC flow was reduced to minimize usage due to access to the H2 trailer during elevated river levels (Normal flow has been restored)* Met Tower -Precipitation Sensor, reconnect (WRC A82561)* Intake recovery when road is accessible (complete 6-17)* Intranet recovery (Complete)

• Temporary cameras at the Intake Structure needs to be removed (Complete)
• MPA and Intake Structure perimeters need repaired and restored (Complete)
• Remove Temp air compressor (Complete)
• Develop RWS Pump start sequence -CAP 58328 (Complete and attached to CAP)* Road Inspections (Site roads) -Complete* Determine deposition of debris and silt in pump pits o Inspect and clean A/B intake pits* Z17786 A intake pit inspection (Divers) PWO1143783
• Z17787 B intake pit inspection (Divers) PWOl 146412* Z19158 Fore bay and B side inlet inspection (Divers)(Will be tasked as part of normal diving activities when river level and flow return to normal so the divers can dive there)* Z17788 Fore bay and A side inlet inspection (Divers)(Will be tasked as part of normal diving activities when U:\NGDSHARE\Flood 2008\Recovery Plan.doc A contingency plan has been developed for the performance of STP 3.3.1.1-22 Auto Scram Functional Test. This STP results in half scrams and will need to be carefully controlled while the plant is in a more vulnerable position due to the grid status. Drop dead for this STP is 61170100.

Other STPs to be performed from 617 week: 3.3.1.1-29Al Rx Lo water level (RPS) response time check -test equipment problems 3.5.1-03A CS sim auto actuation due 11111 NS13A002 Fire Supervisory due 6/27 3.5.1-04 LPCI sim auto actuation due 817 3.8.1-11 B done for day due to lKI0D inop 3.8.1-11 A SBDG aux. due 7/5 STPs for 6114 week that should be considered for rescheduling: 3.8.7-01 LPCI swing bus UV trans test due 7115 3.5.1-04 LPCI sim auto actuation due 7/25 3.3.6.1-47 HPCI exh diaphragm funct drop dead 7/8 3.5.1-05 HPCI quarterly run 7/2 Equipment Issues

• HWC flow was reduced to minimize usage due to access to the H2 trailer during elevated river levels (Normal flow has been restored)
• Met Tower -Precipitation Sensor, reconnect (WRC A82561)
• Intake recovery when road is accessible (complete 6-17)
• Intranet recovery (Complete)
• Temporary cameras at the Intake Structure needs to be removed (Complete)
• MPA and Intake Structure perimeters need repaired and restored (Complete)
• Remove Temp air compressor (Complete)
• Develop RWS Pump start sequence -CAP 58328 (Complete and attached to CAP)
• Road Inspections (Site roads) -Complete
• Determine deposition of debris and silt in pump pits o Inspect and clean AlB intake pits
• Z17786 A intake pit inspection (Divers) PW01143783
• Z17787 B intake pit inspection (Divers) PWOl146412
• Z19158 Fore bay and B side inlet inspection (Divers)(Will be tasked as part of normal diving activities when river level . and flow return to normal so the divers can dive there)
• Z17788 Fore bay and A side inlet inspection (Divers)(Will be tasked as part of normal diving activities when U:\NGDSHARE\F1ood 2008\Recovery Plan.doc river level and flow return to normal so the divers can dive there)o Inspect and clean stilling basin at pump house
• Z17785 Stilling basin inspection (Divers)(Will be performed as part of normal diving ops)o Inspect and clean circ pit (RFO-2 1)o Inspect and clean cooling tower basins (RFO -21)o Inspect and clean RHRSW and ESW pits" Z17783 A RHRSW/ESW pit inspection (Divers)(Will be performed as part of normal diving ops)" Z11784 B RHRSW/ESW pit inspection (Divers)(Will be performed as part of normal diving ops)River channel inspections o Verify river depth in front of intake 0 Z19283 River sounding (MM in boat)o Verify location of river channel to assure silt deposition in front of the intake did not occur E Z19692 Contract a river sediment topographical map Structural Inspections" Intake structural exterior and interior for structural damage o Intake Structure

-Foundation washout (WRC 84506, WRC 84507)o CAP 58332" Integrity of river structures o Wing dam condition(CAP058406) o Riprap on west shore(CAP058406) o Condition of turning vanes(CAP058406)

• Perform inspections of the structural integrity of the MET tower o Z05968 Met Tower Structural Inspection (PWO 1142950)Electrical Equipment Checks* Met tower inspection o Z11143 Met Tower Calibration (cabling check)(PWO 1144754)* Perform inspections of the Cathodic/Freeze protection system to assure proper operation o Z05957 Cathodic Protection System (PWO 1142423)* Security cameras (Done)* Fab shop, Maintenance shop, Lower EM shop (Working)* Intake structure inspection (Done)
• Inspect and clean electrical man ways on duct banks to the intake structure o Z19157 Manhole sump inspection (PWO 1146413)* Lower Electrical Shop Restored (Working)
• Perform inspections of EP sirens (Done)U:\NGDSHARE\Flood 2008\Recovery Plan.doc river level and flow return to normal so the divers can dive there) o Inspect and clean stilling basin at pump house
• ZI7785 Stilling basin inspection (Divers)(Will be performed as part of normal diving ops) o Inspect and clean circ pit (RFO-21) o Inspect and clean cooling tower basins (RFO -21) o Inspect and clean RHRSW and ESW pits
• ZI7783 A RHRSW IESW pit inspection (Divers)(Will be performed as part of normal diving ops)
• ZI1784 B RHRSW IESW pit inspection (Divers)(Will be performed as part of normal diving ops)
• River channel inspections o Verify river depth in front of intake
• Z 19283 River sounding (MM in boat) o Verify location of river channel to assure silt deposition in front of the intake did not occur
• ZI9692 Contract a river sediment topographical map Structural Inspections
• Intake structural exterior and interior for structural damage o Intake Structure

-Foundation washout (WRC 84506, WRC 84507) o CAP 58332

• Integrity of river structures o Wing dam condition(CAP058406) o Riprap on west shore(CAP058406) o Condition oftuming vanes(CAP058406)
• Perform inspections of the structural integrity of the MET tower o Z05968 Met Tower Structural Inspection (PWO 1142950) Electrical Equipment Checks
• Met tower inspection o ZII143 Met Tower Calibration (cabling check)(PWO 1144754)
• Perform inspections of the Cathodic/Freeze protection system to assure proper operation o Z05957 Cathodic Protection System (PWO 1142423)
• Security cameras (Done)
• Fab shop, Maintenance shop, Lower EM shop (Working)
• Intake structure inspection (Done)
• Inspect and clean electrical man ways on duct banks to the intake structure o Z19157 Manhole sump inspection (PWO 1146413)
• Lower Electrical Shop Restored (Working)
• Perform inspections of EP sirens (Done) U:\NGDSHARE\Flood 2008\Recovery Plan.doc External Communications
• Juno Beach updates at 0800, 1300, and 2000* NRC updates every 3 hours by the ENS Communicator (Secured, NRC IRT secured at 0102 on 6/16/08)* Hourly updates to the State EOC by EP (Secured)* IM status updates with Juno every 2 -2 %2 hours NOUE Declassification
• Needed to loose all of these to enter the NOUE: o Loss of commercial phone lines o Loss of the microwave o Loss of FTS Phone System* Any one coming back would allow us to exit* Most likely candidate to come back is commercial lines from Shellsburg
• Due to lack of history with Shellsburg, we would prefer a second line available such as a microwave system.
• NRR has requested that prior to us exiting the NOUE we hold a conference call with DAEC, NRR, and Region 3 to discuss what communication links we have, what we don't have, and how they relate to what is required to exit the EAL.* Lessons Learned/Critique meeting held.

Other Follow-up Activities" Gas tank at South Warehouse -once water level has receded, hose down outside of tank (power wash if possible)* Sewage Treatment Plant -continue to pump down with sump pump as needed (every 30 minutes currently) -once the river level is down below the discharge pipe, we can resume discharging with the normal setup. Update: 6/14/08 -the water level in the discharge ditch is still too high to remove the plug in thedischarge pipe. Currently just above the top of the discharge pipe. We will re-evaluate on 6/15/08 during the dayshift. Update: night shift on 6/14/08 -removed sand bags and discharge pipe plug from discharge line. Water level in discharge sewer is below bottom of discharge pipe. Sewage Treatment Plant discharge back to normal. (Complete)

• Sump pumps at the H2 skid are currently disconnected and need to be removed* XR1/2 plugs need to be removed from the area* Any building that will have normal occupancy, need to sanitizer area effected by the water -examples: o MMD Fab shop and the Lower Electrical shop -need to power wash walls (include sanitizer) in the effected areas from the highest point of the water level to the floor, then mop floor using a sanitizer o MMD shop -remove effected area of the drywall, remove carpet, power wash walls (include sanitizer) then mop floor using a sanitizer o Consider tetanus shots for clean-up crews U:\NGDSHARE\Flood 2008\Recovery Plan.doc External Communications
• Juno Beach updates at 0800, 1300, and 2000
• NRC updates every 3 hours by the ENS Communicator (Secured, NRC IR T secured at 0102 on 6116/08)
• Hourly updates to the State EOC by EP (Secured)
• 1M status updates with Juno every 2 -2 liz hours NOUE Declassification
• Needed to loose all of these to enter the NOUE: o Loss of commercial phone lines o Loss of the microwave o Loss of FTS Phone System
• Anyone coming back would allow us to exit
• Most likely candidate to come back is commercial lines from Shellsburg
• Due to lack of history with Shellsburg, we would prefer a second line available such as a microwave system.
• NRR has requested that prior to us exiting the NOUE we hold a conference call with DAEC, NRR, and Region 3 to discuss what communication links we have, what we don't have, and how they relate to what is required to exit the EAL.
• Lessons Learned/Critique meeting held. Other Follow-up Activities
• Gas tank at South Warehouse

-once water level has receded, hose down outside of tank (power wash if possible)

• Sewage Treatment Plant -continue to pump down with sump pump as needed (every 30 minutes currently)

--{)nce the river level is down below the discharge pipe, we can resume discharging with the normal setup. Update: 6114/08 -the water level in the discharge ditch is still too high to remove the plug in the discharge pipe. Currently just above the top of the discharge pipe. We will evaluate on 6115/08 during the dayshift. Update: night shift on 6/14/08 -removed sand bags and discharge pipe plug from discharge line. Water level in discharge sewer is below bottom of discharge pipe. Sewage Treatment Plant discharge back to normal. (Complete)

• Sump pumps at the H2 skid are currently disconnected and need to be removed
• XR1I2 plugs need to be removed from the area
• Any building that will have normal occupancy, need to sanitizer area effected by the water -examples:

o MMD Fab shop and the Lower Electrical shop -need to power wash walls (include sanitizer) in the effected areas from the highest point of the water level to the floor, then mop floor using a sanitizer o MMD shop -remove effected area of the drywall, remove carpet, power wash walls (include sanitizer) then mop floor using a sanitizer o Consider tetanus shots for clean-up crews U:\NGDSHARE\Flood 2008\Recovery Plan.doc

• Sea lands outside the Protected Area south of the Cooling towers

-once water level has receded, hose down outside of tank (power wash if possible).

• Chemistry is sampling the well water and domestic Water and testing to ensure that the water is safe. Chemistry sampled the Well water and Domestic water on 6/13/08. We can not perform the appropriate analysis for bacteria because our analysis system is not set up for this.

We will ship the samples to an offsite lab on Monday, 6/16/08.* Put all flood prep material back in barn (sand bags, stop logs)* A RWS Traveling Screen -clean out debris, inspect (WRC 54509)Hazardous Wastes Area -no actions needed New Helper storage Building -no actions needed Restoration of access routes o Hwy 94 is closed to public, but access is provided to DAEC personnel. (full access restored)o Blairs Ferry Road is closed, but accessible for emergency response vehicles only o Palo Mash Road is closed (restored 18)o South Access to the site is open o Urbana Bridge is open o Lewis Bottoms bridge to Center Point is closed Hazardous Waste Management Plan Incorporated into the relevant sections of this report.Long-Term Emergency Planning Facilities The EOF, JIC, and ORAA have been moved to the Linn County EOC. The ORAL has been moved to the Iowa Hygenics Lab. The Alliant Tower will not be available for some time due to flood damage. The EOF and JIC will need to use alternate facilities for some time. The flooding at the ORAL has receded and it is available, except power hasn't been restored. Once power is restored we will move the ORAL back to its original location. The Palo School will not be able to be returned to service soon. The backup ORAA will be used, which is the same place as the primary ORAL.U:\NGDSHARE\Flood 2008\Recovery Plan.doc* Sea lands outside the Protected Area south of the Cooling towers -once water level has receded, hose down outside of tank (power wash if possible).

• Chemistry is sampling the well water and domestic water and testing to ensure that the water is safe. Chemistry sampled the Well water and Domestic water on 6/13/08. We can not perform the appropriate analysis for bacteria because our analysis system is not set up for this. We will ship the samples to an offsite lab on Monday, 6/16/08.
• Put all flood prep material back in bam (sand bags, stop logs)
• A R WS Traveling Screen -clean out debris, inspect (WRC 54509) Hazardous Wastes Area -no actions needed New Helper storage Building -no actions needed Restoration of access routes o Hwy 94 is closed to public, but access is provided to DAEC personnel. (full access restored) o Blairs Ferry Road is closed, but accessible for emergency response vehicles only o Palo Mash Road is closed (restored 18) o South Access to the site is open o Urbana Bridge is open o Lewis Bottoms bridge to Center Point is closed Hazardous Waste Management Plan Incorporated into the relevant sections of this report. Long-Term Emergency Planning Facilities The EOF, JIC, and ORAA have been moved to the Linn County EOC. The ORAL has been moved to the Iowa Hygenics Lab. The Alliant Tower will not be available for some time due to flood damage. The EOF and JIC will need to use alternate facilities for some time. The flooding at the ORAL has receded and it is available, except power hasn't been restored.

Once power is restored we will move the ORAL back to its original location. The Palo School will not be able to be returned to service soon. The backup ORAA will be used, which is the same place as the primary ORAL. U:\NGDSHARE\Flood 2008\Recovery Plan.doc Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D.4 Haug P.E. and J.A. Odgaard 2008, Bathymetric and Topographic Survey near Duane Arnold Energy Center: August 2008 Survey. November.Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D.4 Haug P.E. and J.A. Odgaard 2008, Bathymetric and Topographic Survey near Duane Arnold Energy Center: August 2008 Survey. November. BATHYMETRIC AND TOPOGRAPHIC SURVEY NEAR DUANE ARNOLD ENERGY CENTER: AUGUST 2008 SURVEY byPete E. Haug and Jacob A. Odgaard Submitted toFPL Energy Duane Arnold 3277 DAEC Road Palo, Iowa 52324-9785Limited Distribution Report No. 357 Hydroscience & Engineering IIHR -Hydroscience and Engineering College of Engineering The University of Iowa Iowa City, Iowa 52242-1585 November 2008\ ,/ .... ,I ;-...-/ .... > BATHYMETRIC AND TOPOGRAPIDC SURVEY NEAR DUANE ARNOLD ENERGY CENTER: AUGUST 2008 SURVEY by Pete E. Haug and Jacob A. Odgaard Submitted to FPL Energy Duane Arnold 3277 DAEC Road Palo, Iowa 52324-9785 Limited Distribution Report No. 357 IIHR -Hydroscience and Engineering College of Engineering The University of Iowa Iowa City, Iowa 52242-1585 November 2008 fETHE UNIVERSITY OF IOWA .n .E , 1. INTRODUCTION Florida Power and Light's Duane Arnold Energy Center (DAEC) requested IIHR -Hydroscience &Engineering (IIHR) to collect bathymetric and bank line survey data sufficient to create a topographic representation for 6000 feet of the Cedar River near DAEC. The original survey was completed in December 2006 (Limited Distribution Report 346), and a follow-up survey completed in July 2007 (Limited Distribution Report 351). In June 2008 the flood of record (about 150,000 cubic feet per second) passed by DAEC. IIHR was tasked with re-surveying the entire channel from 3000 feet upstream to 600 feet downstream of the intake.The survey was requested to include sufficient grid density to document hydraulically significant structuresand bathymetry. This report was to address Iowa vane maintenance, repair of existing riprap along the west bank, addition riprap placement recommendations, existing spur dike resurvey and protection recommendations, vane maintenance recommendations, and future dredging recommendations upstream and downstream of the intake. The report was also requested to determine if the sand bar located upstream of the intake adjacent to the wing dams and the sand bar downstream of the intake weir should be removed. The last item was to review the regression from the 6/26/1991 plot called CAL-IELPM90-30 rev 0 and compare it to the plant records from 1997 to 2008.2. SURVEY CONDITIONThe bathymetric survey was completed on 05 August 2008 by staff engineer Pete Haug and research scientist Dr. Nathan Young. IMR arrived at the DAEC boat ramp at about 09:30 AM, confirmed operability of the survey equipment, and began surveying shortly thereafter. IIHR collected bathymetric data between 11:00 AM and 3:30 PM.River conditions during the survey were calm with maximum wave heights less than six inches. The river elevation near the DAEC intake was 734.3 feet (surveyed along bank) which corresponded to a flowrate of between 4400+/-20 cfs (Waterloo USGS) and 3690+/-20 cfs (Cedar Rapids USGS).The weather conditions were overcast skies with a slight wind from the south. Surface water temperature was measured as 80.1 degrees Fahrenheit at 11:45 AM. Air temperature was measured at 83.0 degrees at the same time. Figures 1 through II show photographs taken at the survey site. The figures areordered upstream to downstream. November 2008 DAEC Survey Page 2 LDR UNIVERSITY OF low A 1. INTRODUCTION Florida Power and Light's Duane Arnold Energy Center (DAEC) requested IIHR -Hydroscience & Engineering (lIHR) to collect bathymetric and bank line survey data sufficient to create a topographic representation for 6000 feet of the Cedar River near DAEC. The original survey was completed in December 2006 (Limited Distribution Report 346), and a follow-up survey completed in July 2007 (Limited Distribution Report 351). In June 2008 the flood of record (about 150,000 cubic feet per second) passed by DAEC. IIHR was tasked with re-surveying the entire channel from 3000 feet upstream to 600 feet downstream of the intake. The survey was requested to include sufficient grid density to document hydraulically significant structures and bathymetry. This report was to address Iowa vane maintenance, repair of existing riprap along the west bank, addition riprap placement recommendations, existing spur dike resurvey and protection recommendations, vane maintenance recommendations, and future dredging recommendations upstream and downstream of the intake. The report was also requested to determine if the sand bar located upstream of the intake adjacent to the wing dams and the sand bar downstream of the intake weir should be removed. The last item was to review the regression from the 6/2611991 plot called CAL-IELPM90-30 rev 0 and compare it to the plant records from 1997 to 2008. 2. SURVEY CONDITION The bathymetric survey was completed on 05 August 2008 by staff engineer Pete Haug and research scientist Dr. Nathan Young. IIHR arrived at the DAEC boat ramp at about 09:30 AM, continued operability of the survey equipment, and began surveying shortly thereafter. IIHR collected bathymetric data between 11:00 AM and 3:30 PM. River conditions during the survey were calm with maximum wave heights less than six inches. The river elevation near the DAEC intake was 734.3 feet (surveyed along bank) which corresponded to a flowrate of between 4400+/-20 cfs (Waterloo USGS) and 3690+/-20 cfs (Cedar Rapids USGS). The weather conditions were overcast skies with a slight wind from the south. Surface water temperature was measured as 80.1 degrees Fahrenheit at 11 :45 AM. Air temperature was measured at 83.0 degrees at the same time. Figures 1 through I I show photographs taken at the survey site. The figures are ordered upstream to downstream. DAEC Survey LDR November 2008 Page 2 E THE UNIVERSITY OF IOWA Figure 1. Looking upstream from confluence of main and oxbow channels (oxbow channel starts at right)Figure 2. Looking upstream at entrance of oxbow channel Figure 3. Looking northeast at entrance of oxbow channel November 2008 Page 3 DAEC Survey LDR Figure 1. Looking upstream from confluence of main and oxbow channels (oxbow channel starts at right) DAEC Survey LDR Figure 2. Looking upstream at entrance of oxbow channel Figure 3. Looking northeast at entrance of oxbow channel November 2008 Page 3 , i \ I 1 ! 1: ! I i ,. , i 1 f I t j i ; ! ! ,. f ! ffHE UNIVERSITY OF IOWA-- .UE I,---Figure 4. Looking east at bank of island just downstream of oxbow entrance Figure 5. Typical left bank of main channel along islandNovember 2008 Page 4 DAEC Survey LDR DAEC Survey LDR Figure 4. Looking east at bank of island just downstream of oxbow entrance Figure 5. Typicalleftbank of main channel along island November 2008 Page 4 ETHE UNIVERSITY OF IOWA:Lu Rilr*wianca &Figure 6. Vertical face of bank (dark) and five feet of sand deposition (light) on island Figure 7. Exit of slough that enters the main channel upstream of the security ditch Figure 8. Looking west at right bank upstream of spur dikes November 2008 Page 5 DAEC Survey LDR Figure 6. Vertical face of bank (dark) and five feet of sand deposition (light) on island Figure 7. Exit of slough that enters the main channel upstream of the security ditch DAEC Survey LDR Figure 8. Looking west at right bank upstream of spur dikes November 2008 Page 5 IIIIIUBE UNIVERSITY OF IOWA ETH UNVERITYOF OWAfldoý*~rc &Er'Figure 9. Looking upstream at intake structure Figure 10. Looking west at right bank downstream of overhead power line crossing Figure 11. Lookingwest at right bank downstream of overhead power line crossing November 2008 Page 6 DAEC Survey LDR UNIVERSITY OF IOWA Figure 9. Looking upstream at intake structure Figure 10. Looking west at right bank downstream of overhead power line crossing Figure 11. Looking'west at right bank downstream of overhead power line crossing DAEC Survey LDR November 2008 Page 6 FI HE UNIVERSITY OF IOWA ifydoienco & £-- ncor ng 3. BATHYMETRIC SURVEYING EQUIPMENTIIHR surveyed bathymetric features in an 18-foot long tunnel hull boat outfitted with a 60-horsepower outboard motor.3.1.1. Vertical Positioning Bathymetric depths were measured at twenty times per second with a 3-degree survey grade, 200 kHz echosounder supplied by Odom Hydrographic. The echosounder face was submerged 11 centimeters below the mean water surface. This depth was sufficient to prevent air bubbles from the bow from passing beneath the transducer but also shallow enough to be protected from submerged logs and rocks. The boat's draft was approximately 17 centimeters. The manufacturer states the depth measurement accuracy to be 0.01 meters (displayed resolution) +/-0.I percent of distance (measurement accuracy). Given quiescent water, this translates into depth measurement accuracies better than +/-0.5 inches for the entire survey area. The echosounder is powered by an Odom Hydrographic HT100 control box.During the survey, the transducer pitch was between 0.0 and 1.5 degrees above horizontal for boat speeds between zero and four miles per hour. Roll angle was less than one degree since the water surface was calm and survey boat speeds were low. The total uncertainty error attributed to pitch and roll angular bias was less than +/-0.2 inches for the entire survey area.Vertical control was maintained with a Trimble R8 GNSS with TSC2 Survey Controller. The manufacturer states the vertical measurement accuracy to be 0.005 meters (displayed resolution) + 1.0 parts per million of distance (measurement accuracy). Figures 12 and 13 show the Monument D used for vertical datum. The elevation of Monument D was listed as 751.17 feet per "Note A" of Stanley Consultants Inc drawing "Duane Arnold Energy Center Cedar River Spur Dike Project Palo, Iowa -Site Plan and Spur Dike Sections" Revision 1, 24Aug2005. November 2008 DAEC Survey Page 7 LDR UNIVERSITY OF IOWA 3. BATHYMETRIC SURVEYING EQUIPMENT IIHR surveyed bathymetric features in an 18-foot long tunnel hull boat outfitted with a 60-horsepower outboard motor. 3.1.1. Vertical Positioning Bathymetric depths were measured at twenty times per second with a 3-degree survey grade, 200 kHz echosounder supplied by Odom Hydrographic. The echosounder face was submerged 11 centimeters below the mean water surface. This depth was sufficient to prevent air bubbles from the bow from passing beneath the transducer but also shallow enough to be protected from submerged logs and rocks. The boat's draft was approximately 17 centimeters. The manufacturer states the depth measurement accuracy to be 0.01 meters (displayed resolution) +/-o. I percent of distance (measurement accuracy). Given quiescent water, this translates into depth measurement accuracies better than +/-0.5 inches for the entire survey area. The echosounder is powered by an I Odom Hydrographic HTl 00 control box. During the survey, the transducer pitch was between 0.0 and 1.5 degrees above horizontal for boat speeds between zero and four miles per hour. Roll angle was less than one degree since the water surface was calm and survey boat speeds were low. The total uncertainty error attributed to pitch and roll angular bias was less than +/-0.2 inches for the entire survey area. Vertical control was maintained with a Trimble R8 GNSS with TSC2 Survey Controller. The manufacturer states the vertical measurement accuracy to be 0.005 meters (displayed resolution) +/- 1.0 parts per million of distance (measurement accuracy). Figures 12 and 13 show the Monument D used for vertical datum. The elevation of Monument D was listed as 751.17 feet per "Note A" of Stanley Consultants Inc drawing "Duane Arnold Energy Center Cedar River Spur Dike Project Palo, Iowa -Site Plan and Spur Dike Sections" Revision I, 24Aug200S. DAEC Survey LDR November 2008 Page 7 ETHE UNIVERSITY OF IOWA~'Vd ~ ~ once & ~*~I flOUfl4i3 Figure 12. Benchmark disk "Monument D" for local plant datum (4400E, 9500N)Figure 13. Benchmark "Monument D" in southwest gravel parking lot of DAEC November 2008Page 8 DAEC Survey LDR Figure 12. Benchmark disk "Monument D" for local plant datum (4400E, 9500N) Figure 13. Benchmark "Monument D" in southwest gravel parking lot ofDAEC DAEC Survey LDR November 2008 Page 8 II E UNIVERSITY OF IOWA ýHydroscionce , Eiiarg 3.1.2. Horizontal PositioningHorizontal control was maintained with a Trimble R8 GNSS with TSC2 Survey Controller. The manufacturer states the horizontal measurement accuracy to be 0.005 meters (displayed resolution) +/- 0.5 partsper million of distance (measurement accuracy). The Trimble receiver antenna was centered vertically at 1.982 meters above the echosounder. Horizontal position was recorded ten times per second and interpolated temporally to yield coordinates for every depth measurement. After synchronizing the software and hardware clocks, the Trimble "ZDA" time stamp was used to allow temporal accuracies better than ten milliseconds. 3.1.3. Data Processing Depth and GPS coordinates were processed in real-time with HYPACK 2008 software. After the survey was complete, HYPACK Single Beam Max was used to remove erroneous data. About five percent of measurements were removed when the bed elevation could not be correctly determined. All data collected in water less than 1.5 feet deep were removed from the final data set since the bed would have been disturbed by the transducer passing over it.The final plot of corrected data points is shown in Figure 14.4. SURVEY ANALYSIS The following figures illustrate IIHR's interpretation of the bathymetric data collected on 05 August 2008 (data points shown in Figures 14 and 15). Figures 16 and 17 show river channel contours based on bathymetric data interpretation. Figure 18 shows the July 2007 and August 2008 river thalweg (the deepest channel and most likely the main channel), based on the riverbed contour interpretations. Figures 19 and 20 show the difference between the July 2007 and August 2008 bed elevations. Figures 20 and 21 show that remnants of the old river crossing road (used during spur dike construction) have limited the 2008 flood scour upstream of the spur dikes and created a large scour area along the western edges of spur dikes A and B.Figure 22 shows a side scan image of the Iowa vanes near the intake, and according to the image all the vanes were exposed by the 2008 flood. All of the following figures (14 through 22) are available as high resolutionimages on the attached compact disk as well as large size plots attached to this report. November 2008 DAEC Survey Page 9 LDR UNIVERSITY OF IOWA 3.1.2. Horizontal Positioning Horizontal control was maintained with a Trimble R8 GNSS with TSC2 Survey Controller. The manufacturer states the horizontal measurement accuracy to be 0.005 meters (displayed resolution) +/- 0.5 parts per million of distance (measurement accuracy). The Trimble receiver antenna was centered vertically at 1.982 meters above the echosounder. Horizontal position was recorded ten times per second and interpolated temporally to yield coordinates for every depth measurement. After synchronizing the software and hardware clocks, the Trimble "ZDA" time stamp was used to allow temporal accuracies better than ten milliseconds. 3.1.3. Data Processing Depth and GPS coordinates were processed in real-time with HYPACK 2008 software. After the survey was complete, HYP ACK Single Beam Max was used to remove erroneous data. About five percent of measurements were removed when the bed elevation could not be correctly determined. All data collected in water less than 1.5 feet deep were removed from the final data set since the bed would have been disturbed by the transducer passing over it. The final plot of corrected data points is shown in Figure 14. 4. SURVEY ANALYSIS The following figures illustrate UHRIs interpretation of the bathymetric data collected on 05 August 2008 (data points shown in Figures 14 and 15). Figures 16 and 17 show river channel contours based on bathymetric data interpretation. Figure 18 shows the July 2007 and August 2008 river thalweg (the deepest channel and most likely the main channel), based on the riverbed contour interpretations. Figures 19 and 20 show the difference between the July 2007 and August 2008 bed elevations. Figures 20 and 21 show that remnants of the old river crossing road (used during spur dike construction) have limited the 2008 flood scour upstream of the spur dikes and created a large scour area along the western edges of spur dikes A and B. Figure 22 shows a side scan image of the Iowa vanes near the intake, and according to the image all the vanes were exposed by the 2008 flood. All of the following figures (14 through 22) are available as high resolution images on the attached compact disk as well as large size plots attached to this report. DAEC Survey LDR November 2008 Page 9 ETHE UNIVERSITY OF IOWA Fyrsla1n lo~~!~ 1 a'Figure 14. Bathymetric data points collected on 05 August 2008 November 2008 Page 10DAEC Survey LDR DAEC Survey LDR Figure 14. Bathymetric data points collected on 05 August 2008 November 2008 Page 10 B14E UNIVERSITY OF IOWAH NY Wo[cU co & !inparu'g Figure 15. Bathymetric data points collected near the intake on 05 August 2008 November 2008 Page 11 DAEC Survey LDR DAEC Survey LDR Figure 15. Bathymetric data points collected near the intake on 05 August 2008 November 2008 Page 11 W E UNIVERSITY OF IOWA & Figure 16. Bathymetric contours generated from data collected on 05 August 2008 November 2008 DAEC Survey Page 12 LDR DAEC Survey LDR Figme 16. Bathymetric contoms generated from data collected on 05 August 2008 November 2008 Page 12 UNIVERSITY OF IOWA-d scienice a EAEmurhn~.t.Figure 16. Bathymetric contours for 05 August 2008 November 2008 Page 13 DAEC Survey LDR UNIVERSITY OF IOWA DAEC Survey LDR Figure 16. Bathymetric contours for 05 August 2008 November 2008 Page 13 ETHE UNIVERSITY OF IOWA.~v~;o~denc~ & ~no~ii~i Figure 17. Bathymetric contours near the intake for 05 August 2008 November 2008 Page 14 DAEC Survey LDR UNlVERSITY OF IOWA. DAEC Survey LDR Figure 17. Bathymetric contours near the intake for 05 August 2008 November 2008 Page 14 H THE UNIVERSITY OF IOWA~iV~ ~ C arIC*2 & e~j-ne~ "~Figure 18. Thalweg changes between 2007 and 2008 November 2008 Page 15 DAEC Survey LDR DAEC Survey LDR Figure 18. Thalweg changes between 2007 and 2008 November 2008 Page 15

• THE UNIVERSITY OF IOWA I ydroc idenca&EFoi1 J* 2007 MkMrD IM~elý 10 Snw"Yd ExevaIknL A~u~ut-08

,= J,.ly 2i0O7 Suuveyed E~etioM Figure 19. Aggradation / deposition changes between 24 July 2007 and 05 August 2008 DAEC Survey LDR November 2008 Page 16 UNIVERSITY OF IOWA Figure 19. Aggradation / deposition changes between 24 July 2007 and 05 August 2008 DAEC Survey LDR November 2008 Page 16 i ! 1 ! L ! 1 UTHE UNIVERSITY OF IOWA WFWD.~ci~ce ~. ~mea *~j Figure 20. Contour plot showing bed elevation changes between 2007 and 2008 November 2008 Page 17 DAEC Survey LDR DAEC Survey LDR Figure 20. Contour plot showing bed elevation changes between 2007 and 2008 November 2008 Page 17 U HE UNIVERSITY OF IOWA w.Figure 21. Old construction road foundation exposed after 2008 flood (red arrow)November 2008 Page I8 DAEC Survey LDR DAEC Survey LDR Figure 21. Old construction road foundation exposed after 2008 flood (red arrow) November 2008 Page 1.8 BTlm UNIVERSITY OF IOWA idr~cie~ SVC Figure 22. Bed elevation changes between 2007 and 2008 near old construction road foundation (red arrow)November 2008 DAEC Survey LDR Page 19 Figure 22. Bed elevation changes between 2007 and 2008 near old construction road foundation (red arrow) DAEC Survey LDR November 2008 Page 19 RHE UNIVERSITY OF IOWA D THE UNIVERSITY OF IOWA ~ydresc'cncc & t-gtnoerirj Figure 23. Side scan image of all nine Iowa vanes -photo taken on 05 August 2008 5. CHANGE IN STAGE-DISCHARGE RELATIONSHIP The Cedar Rapids USGS' gage calibration was altered during the Flood of 2008. Jon Nania of the USGS says that the Cedar Rapid gage's "stage-discharge relationships have dramatically changed." Since DAEC personnel use the Cedar Rapids gage flowrate forecasts for predicting the river elevations near the DAEC intake, these flowrates should be corrected based on the latest calibration data supplied by the USGS.In other words, the National Weather Service 2 forecast, Corps of Engineers 3 forecast, and any other forecast sites should be checked to see that these sites have implemented the latest USGS 4 rating information. All the sites should yield the same flowrate at the same stage; if not, then the USGS data is assumed to be the most USGS stands for the "United States Geological Survey" 2 http://vww.crh.noaa.gov/ahps2/hydrograph.php?wfo=dvn&gage=cidi4 3 http://www2.mvr.usace.army.milfWaterControl/stationinfo2.cfin?sid=CIDI4&fid=CID14&dt-S 4 http://waterdata.usgs.gov/nwis/uv/?site no=05464500&agency, cd=USGS November 2008 Page 20 DAEC Survey LDR UNIVERSITY OF IOWA Side scan "shadow" Figure 23. Side scan image of all nine Iowa vanes -photo taken on 05 August 2008 5. CHANGE IN STAGE-DISCHARGE RELATIONSHIP The Cedar Rapids USGS I gage calibration was altered during the Flood of 2008. Jon Nania of the USGS says that the Cedar Rapid gage's "stage-discharge relationships have dramatically changed." Since DAEC personnel use the Cedar Rapids gage tlowrate forecasts for predicting the river elevations near the DAEC intake, these tlowrates should be corrected based on the latest calibration data supplied by the USGS. In other words, the National Weather Service 2 forecast, Corps of Engineers3 forecast, and any other forecast sites should be checked to see that these sites have implemented the latest USGS 4 rating information. All the sites should yield the same flowrate at the same stage; if not, then the USGS data is assumed to be the most 1 USGS stands for the "United States Geological Survey" 2 http://www.crh.noaa.gov/ahps2Ihydrograph.php?wfo;dvn&gage=cidi4 3 http://www2.mvLusace.army.millWaterControl/stationinfo2.cfin?sid=CIDI4&fid=CIDI4&dt=S 4 http://waterdata.usgs.gov/nwis/uv/?site no=05464500&agency cd=USGS DAEC Survey LDR November 2008 Page 20 UT HE UNIVERSITY OF IOWA correct Cedar River flowrate. Once a flowrate is determined at the Cedar Rapids gage, the DAEC intake stage should be determined with Figure 27.Prior to presenting the final stage-discharge relationships for DAEC, some observations should be made about the Cedar River. Figure 24 shows that the unregulated Cedar River is subject to changing its stage-discharge curve as the river channel and bed elevation changes over time, so that the USGS is constantly updating the gage's calibration as the river changes over time. Figure 24 shows that the stage-discharge changed between 2002 and 2003 (+0.45 ft), 2006 to 2007 (+0.45 ift), and after the flood of 2008.1000 cfs -- 3000 cfs ----7000 cfs X 15000 c1 737 -736 J: -I I= i." 7 3 6 ... .. ...... .... .... .. .. .. ..... ................... T .... .......... -- ---- -.. .... ... .............. ."" .." -- -----... .. ....0 7 3 4 .5 .. ... -... ................. .. .. ...................................................... i .... .... .. .... ............. > 734 .. ........... 733 -.......,- /.2 732L 4--. .730 4 I -' -. ... -' t ' [1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 Year of record Figure 24. Change-in the stage-discharge relationship over time 1000000 CL u~100000-- ------ .MW -- I---10000 I .100 + i ...... ........ .. .. .. .. .. .... ;" 1000 ........1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 Date of Record Figure 25. April to October flowrates for the last eleven years of record (winter flows are plotted as a straight line average since ice cover could impact the gage's accuracy)November 2008 DAEC Survey Page 21 LDR UNIVERSITY OF IOWA correct Cedar River flowrate. Once a flowrate is determined at the Cedar Rapids gage, the DAEC intake stage should be determined with Figure 27. Prior to presenting the final stage-discharge relationships for DAEC, some observations should be made about the Cedar River. Figure 24 shows that the unregulated Cedar River is subject to changing its stage-discharge curve as the river channel and bed elevation changes over time, so that the USGS is constantly updating the gage's calibration as the river changes over time. Figure 24 shows' that the stage-discharge changed between 2002 and 2003 (+0.45 ft), 2006 to 2007 (+0.45 ft), and after the flood of2008. .... 0 Gi g III fl "'-..t: C CJ 0 .!a .. 1:1"' c: > > 4> 's, .. .2 ell C) .l3 tI) ___ 1000 cfs -. -3000 cfs --Ir -7000 cfs __ 15000 cfs 739 738 737 x' , ! , , , I ' ! , 736 -I ; i ., .... r" -***.-*-**-;-------*.*.*-f-*-- 1 i 735 734 733 732 , 731 --*.. _-_ .*. __ 1 o ! 730 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 Year of record Figure 24. Changein the stage-discharge relationship over time 1000000 __ .. "-I ** 100000 10000 . -' ... ***t "'t" f--t -i -_.[_ . "1"' ". i--.. ::: i:: -f::: -I-. -"j'" ,." :: ._-j ! 1 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 Date of Record Figure 25. April to October flowrates for the last eleven years of record (winter flows are plotted as a straight line average since ice cover could impact the gage's accuracy) DAEC Survey LDR November 2008 Page 21 I THE UNIVERSITY OF IOWA 1Ea, kt &, The vertical shifts in stage-discharge relationships are apparently not correlated with magnitude of flow events since Figure 25 does not show high flow events occurring in between 2002 and 2003 or 2006 and 2007. Instead the shifts in stage-discharge relationships are probably more attributable to changes in the river bed forms due to ice flows, changes in sediment load, or new channel alignments. While vertical shifts are probably not correlated with flood magnitudes, the Flood of 2008 changed the entire shape of the stage discharge curve as seen in Figure 26. Note that the 2008 stage-discharge curve is not parallel to any other year's curve. This is probably due to significant channel realignment and massive changes in bed morphology. -1991 -1998 -2000 .-...2001-----2002 -.-......... 2003 2004 ----.2005 2006 -2007 ---- 2008 742 741 740- --05/__-_70 739 -..... .......~738 ........0)77a .......... .... ...... ..... .... .. .............. .....0)7 3 3. ... ... ........ ...J ..... .. .i --.. ... ................... ; ..... ... ... . .... ..... ....Y : -........ ..... .......--- --- -- -.... ..... .. ...... I ....... ..-- -...........S736 CC730 i }o~~~,,, ;732 J......731 "____ ___-0 5000 10000 15000 20000 25000 30000Flowrate (cfs)Figure 26. The flood of 2008 (dashed line) impact on the stage-discharge relationship (note that the 2008 date is not parallel to the previous stage-discharge relationships) November 2008 DAEC Survey Page 22 LDR UNIVERSITY OF IOWA The vertical shifts in stage-discharge relationships are apparently not correlated with magnitude of flow events since Figure 25 does not show high flow events occurring in between 2002 and 2003 or 2006 and 2007. Instead the shifts in stage-discharge relationships are probably more attributable to changes in the river bed forms due to ice flows, changes in sediment load, or new channel aligrunents. While vertical shifts are probably not. correlated with flood magnitudes, the Flood of 2008 changed the entire shape of the stage discharge curve as seen in Figure 26. Note that the 2008 stage-discharge curve is not parallel to any other year's curve. This is probably due to significant channel realignment and massive changes in bed morphology. --1991 --1998 --2000 -.-.---2001 .-_ .. 2002 ............. 2003 2004 *----2005 --2006 --2007 -* -* 2008 742 , i 741 .. _ .. _ .. __ ....... i ......... _. ____ L_ ......... ___ L._ ..... _. __ L __ .. ___ _._ .. _ ..... _ : I ! 740 ... -.z! .' 739 C-o ___ OW" __ __ __ :_ ... : ! . 738 Q) Qj ... 0 737 Q; g. <II E' 736 OJ .c (,) rtJ '6 c 735 'c, oS! 734 <II Cl .l!! Ul 733 732 731 '1(1. i ; ! I /;lf i : : ! 1 ------l-il ------j-----" "-------!------; -----/ljfi ; . i i Jf/!; :-----:---'-i__ i-,-----+ .... ',t. ! I j ............... , .. -730 0 5000 10000 15000 20000 25000 30000 Flowrate (cfs) Figure 26. The flood of2008 (dashed line) impact on the stage-discharge relationship (note that the 2008 date is not parallel to the previous stage-discharge relationships) DAEC Survey LDR November 2008 Page 22

• TH-IE UNIVERSITY OF IOWA Figure 27 shows the 2008 stage-discharge relationship imposed over the 6/26/1991 CAL-IELPM90-30 rev 0 data, the 2007 relationship proposed in IIHR limited distribution report 351, and the actual daily data collected since 12 June 2008.

The final stage-discharge equation for the DAEC intake after the 2008 flood is: Z = 731+ I +/- 0 a'[Ig(Q)]5 +b.[tog(O)] 4 +c.'log(Q)] 3 +d.[log(Q)] 2 +e.log(Q)+f where Z = the river's average elevation at the DAEC intake, Q = the river's average flowrate at the USGS Cedar Rapids gage number 05464500, a = +0.00433259021800403, b = -0.0636845968796251, c =+0.342057444298689, d= -0.810919088143237, e =+1.25671401561658, andf= -1.301030257479. eo..- 6/26/1991 CAL-IELPM90-30 rev 0 ---1997 to 2007 Rating Curve x 2008 Data After 6-12-2008 765 760- --755 7 Lu 740 735 tMO 73[I745 .......... 7305 .....-Rating Curve After 6-12-2008 100 1000 10000 100000 Fiowrate at Cedar Rapids USGS Gage (cfs)1000000 Figure 27. Change in stage-discharge relationships between 1991, 2007, and 2008 November 2008 Page 23 DAEC Survey LDR UNIVERSITY OF IOWA Figure 27 shows the 2008 stage-discharge relationship imposed over the 6/2611991 CAL-IELPM90-30 rev 0 data, the 2007 relationship proposed in IlllR limited distribution report 351, and the actual daily data collected since 12 June 2008. The final stage-discharge equation for the DAEC intake after the 2008 flood is: Z ::: 731 + 1 oa.[log(Q)]5 +b*[tog(Q)]4 +c.[log(Q)Y +d*[log(Q)]2+ e.1og (Q)+ f , where Z = the river's average elevation at the DAEC intake, Q = the river's average flowrate at the USGS Cedar Rapids gage number 05464500, a = +0.00433259021800403, b = -0.0636845968796251, c = +0.342057444298689, d= e = + 1.25671401561658, andf= -1.301030257479. DAEC Survey LDR til 6/26/1991 CAl-IElPM90-30 rev 0 *** 1997 to 2007 Rating Curve x 2008 Data After 6-12-2008 -Rating Curve After 6-12-2008 100 1000 10000 100000 1000000 Flowrate at Cedar Rapids USGS Gage (cfs) Figure 27. Change in stage-discharge relationships between 1991, 2007, and 2008 November 2008 Page 23 1T HE UNIVERSITY OF IOWA & E o 6. CONCLUSIONS The following conclusions have been made by Dr. Jacob Odgaard and engineer Pete Haug. The conclusions are listed as high priority and low priority to aid in decision making processes. High priorityactions should be completed prior to the spring flood, and low priority actions should be completed within the next year unless otherwise stated.

6.1. Recommendations

for High Priority Actions 6.1.1. Stabilization of the 2004 channel location Between July 2007 and August 2008, the river's deepest channel "thalweg" was straightened (as expected during a high flood event). The 2008 thalweg position indicates that river currents will continue tomaintain a deep channel next to the intake structure, but unfortunately river currents will maintain a deep channel along the western bank upstream of the spur dikes (just upstream of the western riprap bank).The Cedar River must return to the 2004 channel location to correspond with the as-built spur dike alignment. If the west bank failure is not returned to the 2004 channel location prior to another large flood, the river will likely erode behind the existing west bank riprap and flow into the upstream spur dikes perpendicularly. Channel misalignment would increase east bank erosion and potential result in spur dike failure.To stabilize the river at the 2004 channel location, IIHR recommends that DAEC repair the existing west bank riprap (section 6.1.2) and add new riprap to the eroded west bank areas (section 6.1.3).6.1.2. Repair of existing ripran along west bank The riprap along the west bank near DAEC failed in one spot as shown in Figure

28. If not fixed before the water level reaches this level again, the entire bank could be vulnerable to undermining and progressive collapse.Figure 28. Riprap failure along west bank November 2008 Page 24 DAEC Survey LDR UNIVERSITY OF low A 6. CONCLUSIONS The following conclusions have been made by Dr. Jacob Odgaard and engineer Pete Haug. The conclusions are listed as high priority and low priority to aid in decision making processes.

High priority actions should be completed prior to the spring flood, and low priority actions should be completed within the next year unless otherwise stated. 6.1. Recommendations for High Priority Actions 6.1.1. Stabilization of the 2004 channel location Between July 2007 and August 2008, the river's deepest channel "thalweg" was straightened (as expected during a high flood event). The 2008 thalweg position indicates that river currents will continue to maintain a deep channel next to the intake structure, but unfortunately river currents will maintain a deep channel along the western bank upstream of the spur dikes Gust upstream of the western riprap bank). The Cedar River must return to the 2004 channel location to correspond with the as-built spur dike alignment. If the west bank failure is not returned to the 2004 channel location prior to another large flood, the river will likely erode behind the existing west bank riprap and flow into the upstream spur dikes perpendicularly. Channel misalignment would increase east bank erosion and potential result in spur dike failure. To stabilize the river at the 2004 channel location, IIHR recommends that DAEC repair the existing west bank ripiap (section 6.l.2) and add new riprap to the eroded west bank areas (section 6.1.3). 6.1.2. Repair of existing riprap along west bank The riprap along the west bank near DAEC failed in one spot as shown in Figure 28. If not fixed before the water level reaches this level again, the entire bank could be vulnerable to undermining and progresSive collapse. DAEC Survey LDR Figure 28. Riprap failure along west bank November 2008 Page 24 ETHE UNIVERSITY OF IOWA 6.1.3. Additional riprap installation yrcicu,,ca & n~r~As in the previous report, IMHR recommends that DAEC install additional bank-line protection upstream of the upstream-most spur dike to prevent the river's meander pattern from flanking the spur dike and eroding the bank upstream of the spur dike. If the thalweg continues to erode into the west bank, the structural integrity and hydraulic performance of both the upstream spur dike and west bank riprap could be compromised. The recommended action is to add riprap upstream of the existing riprap along the right bank (west channel edge) up to and around the security ditch exit. The riprap along the security ditch should extend intothe ditch sufficiently to anchor this critical bank line from future channel shifts. The riprap should extend from elevation 742 feet down into the riverbed. Figure 29 shows the recommended location for additional riprap protection and how it aligns with the existing riprap (thick red lines). The dashed red line in Figure 29 shows that the riprap should be aligned to direct the flow at the knee of the second spur dike (blue lines).Figure 29. Additional riprap protection needed along west bank upstream of spur dikes (red lines)November 2008 Page 25 DAEC Survey LDR UNIVERSITY OF IOWA 6.1.3. Additional riprap installation As in the previous report, IIHR recommends that DAEC install additional bank-line protection upstream of the upstream-most spur dike to prevent the river's meander pattern from flanking the spur dike and eroding the bank upstream of the spur dike. If the thalweg continues to erode into the west bank, the structural integrity and hydraulic performance of both the upstream spur dike and west bank riprap could be compromised. The recommended action is to add riprap upstream of the existing riprap along the right bank (west channel edge) up to and around the security ditch exit. The riprap along the security ditch should extend into the ditch sufficiently to anchor this critical bank line from future channel shifts. The riprap should extend from elevation 742 feet down into the riverbed. Figure 29 shows the recommended location for additional riprap protection and how it aligns with the existing riprap (thick red lines). The dashed red line in Figure 29 shows that the riprap should be aligned to direct the flow at the knee of the second spur dike (blue lines). Figure 29. Additional riprap protection needed along west bank upstream of spur dikes (red lines) DAEC Survey LDR November 2008 Page 25

• T -IE UNIVERSITY OF IOWA & i..nc'6.1.4. Aerial photograph during high flow events IIHR's survey results indicate that the secondary channel (future oxbow) did not deepen during the flood. In fact, the entrance channel and exit channel are both filled with sediment which indicates that this channel did not pass a significant amount of water during the recent flood. In fact, the sand bar located between spur dike "D" and the DAEC intake is increasing in area and volume. This sand bar is partly composed of material carried from behind spur dike "D" and partly composed of material from the channel's scour hole near spur dikes "B" and "C." The secondary channel is probably not a major contributor of flow and sediment, but any future aerial photographs taken during high flow events should be copied and sent to IIHR so that Jacob Odgaard can determine the impact of the secondary channel on the intake sediment levels.In addition to the secondary channel impacts, an aerial photograph could help determine if the existing spur dikes are too low. If the aerial photograph indicates that the main flow is overtopping the spur dikes and attacking the island's west bank near the spur dikes, then the spur dike crest elevations are too low.6.1.5. Existing spur dike resurvey and protection According to the Stanley Consultant drawings (24AUG2005, C I rev 1), spur dikes were installed with a design crest elevation of 733.0 feet, a crest width of 10 feet, and a minimum aggregate depth of six feet. The side slopes are 2H:IV, and a 3H:IV lateral transition was suggested for the 40 to 50 feet of spur dike extending from the bank.During the December 2006 topographic survey, IIHR staff noticed that some of the spur dikes had low spots near the east bank. During the July 2007 survey, strong flow overtopped the spur dikes but only near the bank, indicating that they are not at uniform elevations.

The 2008 depth readings indicate that scour holes are continuing to develop downstream of each spur dike.The 2008 flood scoured behind each spur dike significantly, and additional scour development could result in spur dike collapse or other structural failure. The scour hole between the southernmost spur dike "D" has reached 714.4 feet (18+ feet below the original crest) and the spur dike's back slope is 39 degrees and at the upper limit for angle of repose. The top of each spur dike was designed to be at elevation 733 feet. The spur dike design (Stanley drawing Cl, detail A, 24Aug2005) calls for each dike to extend into the bed to at least elevation 727 feet. The area downstream of the upstream spur dike "A" has been scoured to 719 feet.The area downstream of the second spur dike "B" has been scoured to 724 feet. The area downstream of the third spur dike "C" has been scoured to 718 feet. The area downstream of the downstream spur dike "D" has been scoured to 714 feet. IIHR was unable to survey the tops of the spur dikes to check for elevation changes but could do so if the water level drops below 732 feet.November 2008 DAEC Survey Page 26 LDR UNIVERSITY OF IOWA 6.1.4. Aerial photograph during high flow events lIHR's survey results indicate that the secondary channel (future oxbow) did not deepen during the flood. In fact, the entrance channel and exit channel are both fIlled with sediment which indicates that this channel did not pass a signifIcant amount of water during the recent flood. In fact, the sand bar located between spur dike "D" and the DAEC intake is increasing in area and volume. This sand bar is partly composed of material carried from behind spur dike "D" and partly composed of material from the channel's scour hole near spur "dikes "B" and "C." The secondary channel is probably not a major contributor of flow and sediment, but any future aerial photographs taken during high flow events should be copied and sent to IIHR so that Jacob Odgaard can determine the impact of the secondary channel on the intake sediment levels. In addition to the secondary channel impacts, an aerial photograph could help determine if the existing spur dikes are too low. If the aerial photograph indicates that the main flow is overtopping the spur dikes and attacking the island's west bank near the spur dikes, then the spur dike crest elevations are too low. 6.1.5. Existing spur dike resurvey and protection According to the Stanley Consultant drawings (24AUG2005, CI rev I), spur dikes were installed with a design crest elevation of733.0 feet, a crest width of 10 feet, and a minimum aggregate depth of six feet. The side slopes are 2H:IV, and a 3H:IV lateral transition was suggested for the 40 to 50 feet of spur dike extending from the bank. During the December 2006 topographic survey, IIHR staff noticed that some of the spur dikes had low spots near the east bank. During the July 2007 survey, strong flow overtopped the spur dikes but only near the bank, indicating that they are not at uniform elevations. The 2008 depth readings indicate that scour holes are continuing to develop downstream of each spur dike. The 2008 flood scoured behind each spur dike signifIcantly, and additional scour development could result in spur dike collapse or other structural failure. The scour hole between the southernmost spur dike "D" has reached 714.4 feet (18+ feet below the original crest) and the spur dike's back slope is 39 degrees and at the upper limit for angle of repose. The top of each spur dike was designed to be at elevation 733 feet. The spur dike design (Stanley drawing C 1, detail A, 24Aug2005) calls for each dike to extend into the bed to at least elevation 727 feet. The area downstream ofthe upstream spur dike "An has been scoured to 719 feet. The area downstream of the second spur dike liB II has been scoured to 724 feet. The area downstream of the third spur dike "C" has been scoured to 718 feet. The area downstream of the downstream spur dike liD" has been scoured to 714 feet. IlHR was unable to survey the tops of the spur dikes to check for elevation changes but could do so lithe water level drops below 732 feet. DAECSurvey LDR November 2008 Page 26 THE UNIVERSITY OF IOWA f3 Given the consistent scour behind each spur dike -in low and high flow years -additional scour is expected in the upcoming years. If the spur dikes settle into or slide along the river bed, they will need to be repaired and possibly strengthened with riprap to prevent their collapse and/or sliding downstream during high flow events. Should the spur dikes settle into or slide along the riverbed, overtopping floodwater may have too much energy to be dissipated in the shallow water downstream of each dike. The high energy creates a scour hole and the spur dikes can slide downstream towards the hole. This can be prevented by raising the spur dike crest elevation. IIHR recommends three actions. First, the dikes must be periodically surveyed to check for settlement and/or downstream movement. Second, if the scour behind the spur dikes continues to increase, the spur dike crest elevations will need to be raised and additional riprap should be placed along each spur dike'sdownstream edges. Third, all future dredging spoil should be relocated behind the nearest spur dike to fill in any scour holes.6.2. Recommendations for Low Priority Actions The following actions are recommended by IIHR but do not need to be completed prior to the spring floods.6.2.1. Vane Condition Check After the recent flood of record, the Iowa vanes are all intact and visible. Seven vanes are protruding above the surface and the two leading vanes are just barely visible above the surrounding sand dunes. A twenty to thirty foot long log is currently caught on the middle vane but this will not negatively affect vane hydraulic performance. During the Flood of 2008, the vanes lowered the bed elevation near the DAEC intake as designed.However, during lesser flow events river sand will continue to pass by the intake and may re-bury the vanes.DAEC should continue to monitor river bed elevations near the intake as described in section 6.2.2 but no other vane field maintenance is necessary at this time. For the record, the minimum elevation found in the vane field in the 2008 survey was 716 feet (closest to the intake) and the maximum elevation was 727 feet (near the eastern vanes). Most of the vane field is at elevation 721 feet.6.2.2. Periodic Monitoring of River Bed Elevations Table 1 lists some points in the vane field and along the intake centerline for comparison between future surveys and the 2007 and 2006 survey data. Figure 30 shows the locations of these spot check points.November 2008 DAEC Survey Page 27 LDR UNIVERSITY OF IOWA Given the consistent scour behind each spur dike -in low and high flow years -additional scour is expected in the upcoming years. If the spur dikes settle into or slide along the river bed, they will need to be repaired and possibly strengthened with riprap to prevent their collapse andlor sliding downstream during high flow events. Should the spur dikes settie into or slide along the riverbed, overtopping floodwater may have too much energy to be dissipated in the shallow water downstream of each dike. The high energy creates a scour hole and the spur dikes can slide downstream towards the hole. This can be prevented by raising the spur dike crest elevation. IIHR recommends three actions. First, the dikes must be periodically surveyed to check for settlement and/or downstream movement. Second, if the scour behind the spur dikes continues to increase, the spur dike crest elevations will need to be raised and additional riprap should be placed along each spur dike's downstream edges. Third, all future dredging spoil should be relocated behind the nearest spur dike to fill in any scour holes. 6.2. Recommendations for Low Priority Actions The following actions are recommended by IIHR but do not need to be completed prior to the spring floods. 6.2.1. Vane Condition Check After the recent flood of record, the Iowa vanes are all intact and visible. Seven vanes are protruding above the surface and the two leading vanes are just barely visible above the surrounding sand dunes. A twenty to thirty foot long log is currently caught on the middle vane but this will not negatively affect vane hydraulic performance. During the Flood of 2008, the vanes lowered the bed elevation near the DAEC intake as designed. However, during lesser flow events river sand will continue to pass by the intake and may re-bury the vanes. DAEC should continue to monitor river bed elevations near the intake as described in section 6.2.2 but no other vane field maintenance is necessary at this time. For the record, the minimum elevation found in the vane field in the 2008 survey was 716 feet (closest to the intake) and the maximum elevation was 727 feet (near the eastern vanes). Most of the vane field is at elevation 721 feet. 6.2.2. Periodic Monitoring of River Bed Elevations Table 1 lists some points in the vane field and along the intake centerline for comparison between future surveys and the 2007 and 2006 survey data. Figure 30 shows the locations of these spot check points. DAEC Survey LDR November 2008 Page 27 trHE UNIVERSITY OF IOWA"drsclenc, os 4~Reference GPS Coordinates UTM15 NADM3 Coordinates Elevation Difference Point Latitude Longitude Easting ] Northing 12/18/2006 7/24/2007 8/5/2008 2007-2006 I 2008-2007 Number Degrees Degrees meters meters ft MSL ft MSL ft MSL ft MSL j ft MSL 1 42.097072 91J772014 601545.0 4661283.7 724.0 ] 726.7 721.8 2.7 -4.9 2 42.097060 391.771981 601547.7 .4661282.4 725.0 726.0 721.3 1.0 4.7 3 42.097137 I 91.771974 601548.2 J 4661290.9 723.0 J 724.0 721.9 1.0 -2.1 4 42.097129 91.771942 601550.9 I 4661290.1 724.0 723.1 721.3 -0.9 -1.8 5 42.097224 91.771939 601550.9 1 4661300.6 723.0 726.4 722.8 3,4 -3.6 6 42.097045 91.771937 601551.4 1 4661280.8 725.0 726.6 722.3 1.6 -4.3 7 42.097214 91.771909 601553.4 1 4661299,6 724.0 725.1 724.0 1.1 -1.1 8 42.097119 F 91.771908 601553.7 1 4661289,0 725.0 725.7 722.2 0.7 -3.5 9 42.097199 91.771868 601556.8 1 4661297.9 725.0 727.0 725.0 2.0 -2.0 10 42,096991 91.771754 601566.6 1 4661275.0 728.0 728.8 728.0 0.8 -0.8 11 42,096947 L 91.771612 601578.4 4661270.2 729.0 729.6 730.2 0.5 0.7 12 42.097104 91.771557 601582.7 4661287.8 729.0 729.0 730.5 0.0 1.5 13 42.096684 91.771403 601595,8 4661263.5 729.0 730.0 728.6 1.0 -1.4 14 42.097030 1 91.771332 601601.4 4661279.9 729.0 730.0 730.2 1.0 0.2AVERAGE 1.1 -2.0 Table 1. Comparison points for future bed elevation spot checks (generally arranged north to south)Figure 30. Location of bed elevation spot checks (red) and vane field (blue)

6.2.3. Dredging

At this time, the river channel does not need dredging to maintain a sufficient water supply to the DAEC intake. As long as the thalweg continues to pass by the intake (as it does in Figure 18) and as long as the river bed elevation near the intake does not exceed elevation 728 ft MSL (currently it is near 716 feetMSL), no channel dredging is necessary. Either of the two aforementioned criteria could change with thespring flood, so IIHR recommends follow-up actions as listed in Section 7.7. FOLLOW-UPACTION RECOMMENDATIONS Since the bank full condition indicates when significant river bathymetry changes can occur, IIHR recommends the following actions every time the river exceeds 29,000 cfs at the Cedar Rapids gage or elevation 741 feet at the DAEC intake. I)DAEC personnel should take a bed elevation measurement outside the intake to insure that a sand bar will not block the intake flow as floodwaters recede (i.e. the bed is sufficiently below the sand gate).November 2008 Page 28 DAEC Survey LDR n UNIVERSITY OF low A 1 . . 1& Reference GPS Coordinates UTM15 NAD83 Coordinates Elevation Difference Point latitude I longitude E.sting Northing 12/18/2006 7/24/2007 8/5/2008 2007*2006 2008*2007 Number Degrees Degrees meters meters ftMSl ItMSl It MSl ftM5L ItMSL 1 42.097072 91.772014 601545.0 4661283.7 724.0 726.7 721.8 2.7 -4.9 2 42.097060 I 91.771981 601547.7 4661282.4 725.0 726.0 721.3 1.0 -4.7 3 42.097137 I 91.771974 601548.2 I 4661290.9 723.0 724.0 721.9 1.0 -2.1 4 42.097129 i 91.771942 601550.9 I 4661290.1 724.0 723.1 721.3 -0.9 -1.8 5 42.097224 I 91.771939 601550.9 4661300.6 723.0 726.4 722.8 3.4 *3.6 6 42.097045 I 91.771937 601551.4 I 4661280.8 725.0 726.6 722.3 1.6 -4.3 7 42.097214 91.771909 601553.4 I 4661299.6 724.0 725.1 724.0 1.1 *1.1 8 42.097119 91.771908 601553.7 4661289.0 725.0 725.7 722.2 0.7 *3.5 9 42.097199 91.771868 601556.8 4661297.9 725.0 727.0 725.0 2.0 *2.0 10 42.096991 91.771754 601566.6 4661275.0 728.0 728.8 728.0 0.8 *0.8 11 42.096947 91.771612 601578.4 4661270.2 729.0 729.6 730.2 0.5 0.7 12 42.097104 91.771557 601582.7 4661287.8 729.0 729.0 730.5 0.0 1.5 13 42.096884 91.771403 601595.8 4661263.5 729.0 730.0 728.6 1.0 -1.4 14 42.097030 91.771332 601601.4 4661279.9 729.0 730.0 730.2 1.0 0.2 AVERAGE 1.1 -2.0 Table 1. Comparison points for future bed elevation spot checks (generally arranged north to south) Figure 30. Location of bed elevation spot checks (red) and vane field (blue) 6.2.3. Dredging At this time, the river channel does not need dredging to maintain a sufficient water supply to the DAEC intake. As long as the thalweg continues to pass by the intake (as it does in Figure 18) and as long as the river bed elevation near the intake does not exceed elevation 728 ft MSL (currently it is near 716 feet MSL), no channel dredging is necessary. Either of the two aforementioned criteria could change with the spring flood, so TIHR recommends follow-up actions as listed in Section 7. 7. FOLLOW-UP ACTION RECOMMENDATIONS Since the bank full condition indicates when significant river bathymetry changes can occur, IIHR recommends the following actions every time the river exceeds 29,000 cfs at the Cedar Rapids gage or elevation 741 feet at the DAEC intake. 1) DAEC personnel should take a bed elevation measurement outside the intake to insure that a sand bar will not block the intake flow as floodwaters recede (i.e. the bed is sufficiently below the sand gate). DAEC Survey LDR November 2008 Page 28 It -E UNIVERSITY OF IOWA kor , &, 2) If the bed elevation near the intake is too high during or immediately after the flood, a new survey and dredging operation should be initiated immediately to remedy the situation.

3) Even if the bed elevation is sufficiently low, a new bathymetric survey should be completed after the floodwaters recede to guide remediation efforts for any new developments related to scour holes near the spur dikes, sediment deposition near the vane field, and to decide whether dredging should occur before the next flood.As long as there are good boat access and safe river conditions, IIHR can complete a bathymetric survey anytime that DAEC requests one. The ideal survey period is when the river elevation is just below the spur dike crests or at about elevation 733 feet MSL (between 2,000 and 3,000 cfs), so that IIHR can check each spur dike's structural condition.

Alternatively, the channel survey can also be completed when the river is above 10,000 cfs because then the IIHR echosounder can travel safely over the spur dikes.IIHR appreciates the opportunity to complete this scope of work for DAEC. Should you have any questions about this report and its contents, please contact us at 319-335-5237. November 2008 Page 29 DAEC Survey LDR UNIVERSITY OF low A 2) If the bed elevation near the intake is too high during or immediately after the flood, a new survey and dredging operation should be initiated immediately to remedy the situation.

3) Even if the bed elevation is sufficiently low, a new bathymetric survey should be completed after the floodwaters recede to guide remediation efforts for any new developments related to scour holes near the spur dikes, sediment deposition near the vane field, and to decide whether dredging should occur before the next flood. As long as there are good boat access and safe river conditions, IIHR can complete a bathymetric survey anytime that DAEC requests one. The ideal survey period is when the river elevation is just below the spur dike crests or at about elevation 733 feet MSL (between 2,000 and 3,000 cfs), so that IlHR can check each spur dike's structural condition.

Alternatively, the channel survey can also be completed when the river is above 10,000 cfs because then the IIHR echosounder can travel safely over the spur dikes. IIHR appreciates the opportunity to complete this scope of work for DAEC. Should you have any questions about this report and its contents, please contact us at 319-335-5237. DAECSurvey LDR November 2008 Page 29 Work Order: 1141951 Priority:3 PM Critical: Y WorkType: MWO Equip ID: SUS10.01 Equip Name: RIVER WATER SUPPLY Location: NOT APPLICABLE Pnl/Rack: Location Comments: Cedar River Bank RIPRAP repair/insta" 141951C'Quality Level: 1 SUS: 10.01 Elev: RWP Number: Milestone: 9843C1 Concern REPAIR EXISTING RIPRAP ALONG WEST BANK OF THE CEDAR RIVER AND ADD ADDITIONAL RIPRAP AS DIRECTED, Scope of Work Install I Repair RIPRAP at Cedar River Bank Summary WBS: W.N-3003-520.540010( Mod: Topic/Task: Account: 531.060 PA#: Project: H1 Planning Flags I Nuclear Risk: L 2 Personal Risk: M 3 Radiological Risk: L 5 Corp-Reg-Gen: L EPIX: Y ISI: Y Parts Required: Y Peer Review: Y RWP Required: Y Reference Documents[-STANLEY CONSULTANTS DVW AR#: Lead Shop: PE 4 Env Chem Risk: L IST: Y Walk Down: Y Plannira Review!Plannina Review Planner: BOWMAN, ROBERT Peer Review: CHAMPION, GEORGE System Engineer: COLLINGSWORTH, PAUL ASME: PRESLER, SCOTT IST Engineer: CHRISTOPHER, ERIC OSS -Planner: BREWER, STEVEN HP Planner: HARRISON, BONNIE Pre-job Brief: Date: 12/06/2007 Date: 01109/2008 Date: 01121/2008 Date: 01125/2008 Date: 01/28/2008 Date: 07J28/2008 Date: 07116/2008 Date:]Effect on Plant'Plant Mode(s): None I F7 Power Operation 2 [] Startup 3 [] Hot Shutdown 4 [] Cold Shutdown 5 IZ Refueling Loop or Side: Risk Significant: N Page l of 3 Work Order: 1141951 A1141951 Prlority:3 WorkType: MWO Equip ID: SUS10.01 Location: NOT APPLICABLE PM Critical: Y Equip Name: RIVER WATER SUPPLY Pnl/Rack: Location Comments: Cedar River Bank RIPRAP repairlinsta Quality Level: 1 SUS: 10.01 Elev: RWPNumber: Milestone: 9843C1 Initiation and Planning Concern REPAIR EXISTING RIPRAP ALONG WEST BANK OF THE CEDAR RIVER AND ADD ADDITIONAL RIPRAP AS DIRECTED. Scope of Work Install ( Repair RIP RAP at Cedar River Bank WBS: W.N-3003-520.540010( Mod: ToplclTask: AR#: Account: 531.060 PAt: Project H1 Lead Shop: PE ------------ Planning Flags ---------1 Nuclear Risk: L 5 Corp-Reg-Gen: L Parts Required: Y 2 Personal Risk: M 3 Radiologlcal Risk: L EPIX: Y lSI: Y Peer Review: Y RWP Required: Y 4 Env Chem Risk: L IST:Y Walk Down: Y -------Reference Documents

---

OSTANLEY CONSULTANTS DW Planner: BOWMAN, ROBERT Peer Review: CHAMPION, GEORGE System Engineer:

COLLINGSWORTH, PAUL ASME: PRESLER, scon 1ST Engineer: CHRISTOPHER, ERIC OSS -Planner: BREWER, STEVEN HP Planner: HARRISON, BONNIE Planning Review Pre-job Brief: ______________________ _ Plant Mode(s): 1 0 Power Operation 20 Startup 3 0 Hot Shutdown 4 0 Cold Shutdown 5 0 Refueling* Loop or Side: _ Risk Significant N Effect on Plant None Date: 1210612007 Date: 01/0912008 Date: 01121/2008 Date: 01125/2008 Date: 01/28/2008 Date: 07/28/2008 Date: 07/16/2008 Date: ______ _ Page 10f3 Work Order: 1141951'1 141 951CE I i OSS Authorization Section(s) Conditional Release Boundary: Temp Mod(s) Removed? FPIR_Conditional Release: OSS: Date: Released for Work: OSS:SCHUSSLER, DAVID (6587) Date: 10/13/2008 Step I Work Step Instructions Craft lnit/Date Test I Pre Operations sign on task FIELD SUPV El Notify Iowa One Call for area utility survey_ Notification Number 2 Verify this work order has been approved and signed on for field work to commence IELD SUPV 3 Verify contractor liason brief has been performed and a copy attached to this MWO FIELD SUPV 4 Perform Prejob brief and JHA -=IELD SUPV 5 Ensure excavation permits have been completed and approved. IELD SUPV D 6 Nate: If rigging Is required during the performance of this work, contact Tom Rowan at ext 7456. FIELD SUPV"All rigging evolutions will be performed by a DAEC qualified rigger" 7 Repair riprap failure area, approximately 100 ft. length utilizing typical section B-B as depicted S:-SCHMIDT)n Stanley Consultants drawing C1.8 'lear trees etc for new 700 ft. installation and grade embankment per Stanley Consultants C-SCHMiDT specification sections 2230 & 2310, Stanley Consultants print C1 9 Notify Stanley Consultants field engineer prior to grading completion to perform grading FIELD ENG inspection.. 10 install geotextile per typical bank section, per Stanley Consultants specification sections 2371, 3-SCHMIDTStanley Consultants print C1 11 Notify Stanley Consultants field engineer prior to completion to perform inspection.. IELD SUPV 12 Install aggregate bedding per Stanley Consultants specification sections 2374, Stanley C-SCHMIDT LI Consultants print C1 13 Notify Stanley Consultants field engineer prior to completion to perform aggregate bedding FIELD SUPV nspection..14 nstall Riprap per Stanley Consultants specification sections 2733, Stanley Consultants print C1 C-SCHMIDT 15 Nolify Stanley Consultants field engineer prior to completion to perform inspection.. FIELD SUPV 16 Perform finish grading and install appropriate errosion control for all disturbed areas. 1-SCHMIDT'Revision I adds steps 16A & 16B for Design engineering walk down and EMA operational release.(G.N.C -10/30/2008) 17 Verify all work completed satisfactorily and all work order steps signed off. FIELD SUPV 18 No turn over activities associated with this MWO OPS-P Page 2 of 3 Work Order: 1141951 OSS Authorization I Section(s) Temp Mod(s) Removed? FPIR Conditional Release Boundary; o Conditional Release: 055: __________________________ ___ Date: _______ _ Released for Work: OSS;SCHUSSLER, DAVID (6587) Date: 10/1312008 Step Work Step Instructions Craft 1 Pre Operations sign on task FIELDSUPV Notify Iowa One Call for area utility survey Notification Number 2 Verify this work order has been approved and signed on for field work to commence IELDSUPV 3 Verify contractor Iiason brief has been performed and a copy attached to this MWO IELDSUPV 4 Perform Prejob brief and JHA IELDSUPV 5 Ensure excavation permits have been completed and approved. IELDSUPV 6 If rigging Is required during the performance of this work. contact Tom Rowan at ext 7456. , All rigging evolutions wiD be performed by a DAEC qualified rigger" IELDSUPV 7 riprap failure area, approximately 100 ft. length utilizing typical section B-B as depicted C-SCHMIDT pn Stanley Consultants drawing C1. a Clear trees etc for new 700 fl. installation and grade embankment per Stanley Consultants C-SCHMIDT sections 2230 & 2310, Stanley Consultants print C1 9 Notify Stanley Consultants field engineer prior to grading completion to perform grading FIELD ENG nspection .. 10 nstall geotextile per typical bank section, per Stanley Consultants specification sections 2371, P-SCHMIDT Stanley Consultants print C1 11 Notify Stanley Consultants field engineer prior to completion to perform inspection .. FIELDSUPV 12 nstall sggregate bedding per Stanley Consultants specification sections 2374, Stanley f:;onsultants print C1 ,SCHMIDT 13 Notify Stanley Consultants field engineer prior to completion to perform aggregate bedding flELDSUPV nspectian .. I 14 nstall Riprap per Stanley Consultants specification sections 2733, Stanley Consultants print C1 C-SCHMIDT 15 Notify Stanley ConSUltants field engineer prior to completion to perform inspection .. FIELDSUPV 16 Perform finish grading and install appropriate errosion control for alf disturbed areas. C-SCHMIDT

• Revislon 1 adds steps 16A & 168 for Design engineering walk down and EMA operational elease.(G.N.C

-10/3012008) 17 Verify all work completed satisfactorily and all work order steps signed off. FIELDSUPV 18 No tum over activities associated with this MWO OPS InitlDate Page 2 0(3 Test 0 p JJ P p P p p gJ 0 gJ 0 0 0 0 0 0 0 ::J Work Order: 1141951 CE.Initials Name (print)Initials Name (prnt)-i Worker Comments i As FoundlProbable Cause/Action Taken: M&TE Used: Actual Man Hours Craft Code: C-SCHMIDT Duration: Craft Code: SECURITY Duration: Craft Code: Duration: Craft Code: Duration: I Job Duration: I# of Craft:# of Craft:# of Craft:# of Craft: I[]Tags Cleared Work Closure LuTemp Mod Cleared EjFPIR Cleared Post Remarks: Job Supervisor; OSS: Post Work Planner Review Required: YES/NO Date: Date:.Post Work Review ASME Review: EPIX Engineer.IST Engineer Review: Date: Date: Date: Page 3of3 Work Order: 1141951 Initials Name (print) InItials Name (print) As Found/Probable Cause/Action Taken: M&TE Used: Actual Man Hours Craft Code: C-SCHMIOT Craft Code: SECURITY Craft Code: ___ _ Craft Code: ___ _ Duration: ___ _ Duration: ___ _ Duratkln: ___ _ Duration: ___ _ OTags Cleared Post Remarks: Worker Comments # of Craft: ___ _ # of Craft: __ _ # of Craft: __ _ # of Craft: __ _ Work Closure DTemp Mod Cleared Job Supervisor; ____________________ _ OS5: ________________________ _ Post Work Planner Review Required: YES/NO Post Work Review ASME Review; _____________________ _ EPIX Engineer. _____________________ _ 1ST Engineer Review: _____________________ _ Job Duration: DFPIR Cleared Date: _____ _ Date: _____ _ Date: _____ _ Date: _____ _ Date: _____ _ Page 30'3 Document Included in Enclosure I of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D.5 FPL Energy Letter, D. Curtland, Plant Manager-Nuclear, to M. Anderson, Water Supply Engineering, IDNR, "Annual Water Use Report Form for Water Use Permits #3046-MR5 and 3533-R3" dated January 27, 2009, NG-09-0078. Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 0.5 FPL Energy Letter, O. Curtland, Plant Manager-Nuclear, to M. Anderson, Water Supply Engineering, 10NR, "Annual Water Use Report Form for Water Use Permits #3046-MR5 and 3533-R3" dated January 27,2009, NG-09-0078. 0 FPLEnergy .Duane Arnold Energy Center January 27, 2009 NG-09-0078 Michael Anderson Iowa Department of Natural Resources (IDNR)Water Supply Engineering (WSE)401 SW 7 th Street, Suite M Des Moines, Iowa 50309-4611 FPL Energy Duane Arnold, LLC 3277 DAEC RoadPalo, Iowa 52324 Re:

Subject:

Reference:

File: Duane Arnold Energy Center Annual Water Use Report Form Water Use Permits # 3046-MR5 and 3533-R3 ST-2, A-85h

Dear Mr. Anderson,

Please find enclosed the completed "Annual Water Use Report" for calendar year 2008, for FPL Energy Duane Arnold as required by DAEC Water Use Permits # 3046-MR5 and 3533-R3.Should you have any questions about these reports, please feel free to contact Jerald Hogan at (319) 851-7606.Sincerely, Dean Curtland Plant Manager-Nuclear

Enclosures:

DNR FORM # 542-3115 for permit# 3046-MR5 (Cedar River)DNR FORM A 542-3115 for permit# 3046-MR5 (Silurian Wells A + B + C + D)DNR FORM # 542-3115 for permit# 3533-R3 (Pleasant Creek)CC: Neal McKenney Jerald.Hogan Aaron LaGrange IRMS FPLlEnergy. DUlana Energv Cell1lter January 27, 2009 NG-09-0078 Michael Anderson Iowa Department of Natural Resources (lDNR) Water Supply Engineering (WSE) 401 SW ih Street, Suite M Des Moines, Iowa 50309-4611 Re:

Subject:

Reference:

File: Duane Arnold Energy Center Annual Water Use Report Form Water Use Permits # 3046-MR5 and 3533-R3 ST-2, A-a5h

Dear Mr. Anderson,

FPL Energy Duane Arnold, LLC 3277 DAEC Road Palo, Iowa 52324 Please find enclosed the completed "Annual Water Use Report" for calendar year 2008, for FPL Energy Duane Arnold as required by DAEC Water Use Permits # 3046-MR5 and 3533-R3. Should you have any questions about these reports, please feel free to contact Jerald Hogan at (319) 851-7606. -Sincerely, Dean Curtland Plant Manager-Nuclear

Enclosures:

DNR FORM # 542-3115 for permit# 3046-MR5 (Cedar River) DNR FORM # 542-3115 for permit# 3046-MR5 (Silurian Wells A + B + C + D) DNR FORM # 542-3115 for permit# 3533-R3 (Pleasant Creek) cc: Neal McKenney Aaron LaGrange IRMS FTiedF of Opportuit W A-4ESTER J. CULVER, GOVERNOR DEPARTMENT OF NATURAL RESOURCES ,ATTY JUDGE. LT. GOVERNOR RICHARD A. LEOPOLD, DIRECTOR Please print permittee's name and address below if different from that shown at left.FPL Energy Duane Arnold, LLC Duane Arnold Enery Center 3277 DAEC Road, Palo IA 52324

Dear Permittee:

Phone # (3.19) 851-7606Iowa water use permit holders are required to report the amounts of water used each year. Report the water use as "0" if no water was used during the year. Complete and return the water use form to the Department of Natural Resources by January 31 of each year. The Department's mailing address is found on the bottom of this page.INSTRUCTIONS TO COMPLETE TIE REPORT FORM: Each number in the instructions corresponds to a number on the water use report form shown on the reverse side, Do not complete the report form until the end of a water use period.1. PERMIT NUMBER: This refers to the number that appears on the mailing label above and/or on your water use permit. (Public water supplies: Please note that this number is not your PWSID number.)2. PERMIT HOLDER: This refers to the person whose name is officially recorded on the water use permit, 3. UNITS WATER USE REPORTED IN: Indicate the units in which you are reporting your water use (i.e.gallons, acre-ft, etc.). If you are using units other than those given, please specify in the space provided.TYPE OF SOURCE USED: If a permit allows withdrawals from more than one source (e.g., from a stream and a well, a pond and a well, etc.) separate water use reports are required for each source, including standby sources. If a permit includes more than one well and they are all in the same aquifer, they are considered one source; therefore, one water use report can be used. If they are in different aquifers, they are considered separate sources and separate reports must be filed.5. STATIC WATER LEVEL: Static water level must be measured annually for each well. Measurement should be taken prior to the first spring use for seasonally used wells, or prior to March 31 for wells used throughout the year.6. DETERMINATION OF WATER USE: METERING: If a flow meter was used to determine water use, check this box.CALCULATIONS: If your system is not equipped with a flow meter, use one of the following methods: GALLONS: Multiply the system's operating capacity (in gallons per minute) by the number of hoursthe system is run and multiply that result by 60 to obtain gallons.Example: During July, an irrigation system using 700 gallons per minute is run for 170 hours.700 gal/min x 170 hrs x 60 mrinrhr = 7,140,000 gallons ACRE-FEET: Multiply the number of acres irrigated by the number of inches of water applied and divide by 12 to obtain acre-feet. (To convert to gallons, multiply acre-feet by 326,000)Example: During August, 4.5 inches of water is applied to 31 acres of land.4.5 inches x 31 acres/12 inches/foot = 11.63 acre-feet (or 3,790,000 gallons)

7. YEAR: This refers to the calendar year for which you are reporting your water usage 8.-41. WATER USE APPLICATIONS:

Complete only the section or sections that apply to you.1 2. TOTAL: Add up the values in each column and enter the totals in this row.,ease contact Michael Anderson at (515) 725-0336 if you have any questions or need further information. Water Supply Engineering Section, 401 SW 7 t1 St. Suite M, Des Moines, IA 50309-4611 Phone 515/725-0282 Fax 515/725-0348 wwwiowadnr.gov

• sM j; "..,.. lUll '-,p::::-, .... Fields of Opportunities CULVER, GOVERNOR ,'ATTY ..JUDGE, LT. C;;;OVERNOR

Dear Permittee:

STAT.E OF IOVVA DEpARTMENT OF NATURAL RESOt)RCES R1CHARD A. LEOPOLD, DIRECTOR Please print pennittee's narne and address below if different from that shown at left. FPL Energy Duane Arnold, LLC Duane Arnold Energy Center 3277 DAEC Road, Palo IA 52324 Phone __ ..."(3=1,,,-9),-,8=S-",-l-...!-7=60=6 Iowa water use permit holders are required to report the amounts of water used each year. Report the water use as "0" if no water was used during the year. Complete and return the water use form to the Department of Natural Resources by January 31 of each year. The Department's mailing address is found on the bottom of this page. INSTRUCTIONS TO COMPLETE THE REPORT FORM: Each number in the instructions corresponds to a number on the water use report form shown on the reverse side. Do not complete the report form until the end of a water use period. 1. PERMIT NUMBER: This refers to the number that appears on the mailing label above and/or on your water use permit. (Public water supplies: Please note that this number is not your PWSID number.) 2. PERMIT HOLDER: This refers to the person whose name is officially recorded on the water use permit. 3. UNITS WATER USE REPORTED IN: Indicate the units in which you are reporting your water use (i.e. gallons, acre-ft, etc.). If you are using units other than those given, please specify in the space provided. TYPE OF SOURCE USED: If a permit allows withdrawals from more than one source (e.g., from a stream and a well, a pond and a well, etc.) separate water use reports are required for each source, including standby sources. If a permit includes more than one well and they are all in the same aquifer, they are considered one source; therefore, one water use report can be used. If they are in different aquifers, they are considered separate sources and separate reports must be filed. 5. STATIC WATER LEVEL: Static water level must be measured annually for each well. Measurement should be taken prior to the first spring use for seasonally used wells, or prior to March 31 for wells used throughout the year. 6. DETERMINATION OF WATER USE: METERING: If a flow meter was used to determine water use, check this box. CALCULATIONS: If your system is not equipped with a flow meter, use one of the following methods: GALLONS: Multiply the system's operating capacity (in gallons per minute) by the number of hours the system is run and multiply that result by 60 to obtain gallons. Example: During July, an irrigation system using 700 gallons per minute is run for 170 hours. 700 gal/min x 170 hrs x 60 minlhr = 7,140,000 gallons ACRE-FEET: Multiply the number of acres irrigated by the number of inches of water applied and divide by 12 to obtain acre-feet. (To convert to gallons, multiply acre-feet by 326,000) Example: During August, 4.5 inches of water is applied to 31 acres ofland. 4.5 inches x 31 acresll2 inches/foot = 11.63 acre-feet (or 3,790,000 gallons) 7. YEAR: This refers to the calendar year for which you are reporting your water usage 8.-11. WATER USE APPLICATIONS: Complete only the sectionor sections that apply to you. 1 TOTAL: Add up the values in each column and enter the totals in this row. ,ease contact Michael Anderson at (515) 725-0336 if you have any questions or need further information. Water Supply Engineering Section, 401 SW 7 tb St. Suite M, Des Moines, IA 50309-4611 Phone 515/725-0282 Fax 515/725-0348 www.iowadnr.gov ANNUAL WATER REPORT FORM (Read instructions on reverse side before completing.)

1. PERMIT NO: 3046---MR5

2. PERMIT HOLDER (Please print): FPL Energy Duane Arnold, I 3. WATER USE REPORTED IN: 4.LLC TYPE OF SOURCE USED: (Follow instructions carefully.)[ ] Well[X ] Stream[ ] Gravel PitlQuarry Reservoir/Lake/Pond

[I[X]ACRE-FEET GALLONS OTHER (Specify): million gallons Name of water source: Cedar River

5. STATIC WATER LEVEL (Well #, Depth to water surface, prior to withdrawal, in ft)Well # __, _ ft Well# , _ft Well # __,___ ft (If more wells are included in permit, list static water levels on a separate attached sheet.)6. DETERMINATION OF WATER USE: [ I Metering [ X ] Calculation T 7. YEAR 8. IRRIGATIONCORN / BEANS Specialty Crop: GOLF COURSE I (fruits & vegetables)

SOD FARM 9. Municipal, Industrial, Commercial

10. AGGREGATE PRODUCTION/

MINING 11. OTHER (wetland development, recreational, etc.)2008 DEWATERING WASHING__________ 4 4 288 4 4 4 270 1 +323 368 MAY 440 JUN 448 JUL 569 AUG 514 456 451 396 319 4,842 NAME (Prin("nrt'l wnA SIGNATURE & DATE REPORT PREPARED BY: [X]Permit Holder]Agent [ ]Tenant [ ]Consultant [ ]New Owner [ ]Other (Specify)WATER SUPPLY SECTION -DNR FORM NO. 542 -3115 (R-12/04)1. PERMIT NO: 3046---MRS ANNUAL WATER REPORT FORM (Read instructions on reverse side before completing.)

4. TYPE OF SOURCE USED: (Follow instructions carefully.) [ ] Well [] Gravel Pit/Quarry

[X] Stream . [ ] ReservoirlLakelPond

2. PERlmT HOLDER (please print): FPL Energy Duane Arnold, LLC 3. WATER USE REPORTED IN: [ ] ACRE-FEET [ ] GALLONS [X] OTHER (Specify):

million gallons Name of water

5. STATIC WATER LEVEL (Well #, Depth to water surface, prior to withdrawal, in ft) Well#_, __ ft Well#_, __ ft Well#_, __ ft (If more wells are included in permit, list static water levels on a separate attached sheet.) 6. DETERMINATION OF WATER USE: [] Metering [X] Calculation

7. YEAR 8. IRRIGATION

9. Municipal, 10. AGGREGATE PRODUCTION/

11. OTHER B=-=E=-A-N-S--'-S-p-ec-i-:Cal-ty-:CC'-ro-p-:

Industrial, (fruits & vegetables) SOD FARM Commercial NUNrnNG (wetland 2008 JAN FEB r./1 MAR APR MAY < JUN JUL AUG SEP Z OCT 0 ::E NOV DEC 12. TOTAL NAME (Print . .L) ______ _ 288 270 323 368 440 448 569 514 456 451 396 319 4,842 DEWATERING WASHING development, recreational, etc.) SIGNATURE & DATE ___ _ REPORT PREPARED BY: [X]Permit Holder []Agent []Tenant []Consultant []New Owner []Other (Specify) ____ _ WATER SUPPLY SECTION -DNR FORM NO. 542 -3115 (R-12/04) ANNUAL WATER USý REPORT FORM (Read instructions on reverse side before completing.)

1. PERMIT NO: 3046---IMR5 4, 2. PERMIT HOLDER (Please print): FPL Energy Duane Arnold, LLC 3. WATER USE REPORTED IN: 5, ACRE-FEET[ ] GALLONS[X] OTHER (Specify):

Million Gallons 6, I* TYPE OF SOURCE USED: [ X] Well [ ] Gravel Pit/Quarry (Follow instructions carefully.) [ ] Stream [ ] Reservoir/Lake/Pond Name of water source: "A" "B"132 "C" "D" -Devonian/Silurian wells* STATIC WATER LEVEL (Well #, Depth to water surface, prior to withdrawal, in ft)Well # "A", 77 ft Well # "B", 55 ft. Well # "C", 166 ft, Well # "D", 211 ft (If more wells are included in permit, list static water levels on a separate attached sheet.)* DETERMINATION OF WATER USE: [ X ] Metering [ ] Calculation

7. YEAR 8. IRRIGATION J 9. Municipal, Industrial, Commercial

10. AGGREGATE PRODUCTION/

MINING Specialty Crop: GOLF COURSE /(fruits & vegetables) SOD FARM 11. OTHER (wetland development, recreational, etc.)DEWATERING WASHING JAN FEB MAR APR 48.0 49.0 58.2 54.1 MAY 59.7 JUN 55.4 JUL 56.9 AUG 56.9 SEP 4 OCT NOV DEC 12. TOTAL 52.4 54.6+ * +53.6 54.9I I I I 653.8 NAME (Print) Dean Curtland SIGNATURE & DATE 1{e o--(4-> ,,4O9 REPORT PREPARED BY: [X]Permit Holder [ ]Agent [ ]Tenant [ ]Consultant [ ]New Owner [ ]Other (Specify)WATER SUPPLY SECTION -DNR FORM NO. 542 -3115 (R-12/04)ANNUAL WATER REPORT FORM (Read instructions on reverse side before completing.)

1.

__ ____ __ 4. TYPE OF SOURCE USED: (Follow instructions carefully.) [X] Well [, ] Stream [ ] Gravel Pit/Quarry [ ] ReservoirlLakelPond

2. PERMIT HOLDER (please print): FPL Energy Duane Arnold, LLC 3. WATER USE REPORTED IN: [ ] ACRE-FEET [ ] GALLONS (X] OTHER (Specify):

Million Gallons Name of water source,.:..: __ ",!.2A,-"_"B!=!-" '....ol'D::::,.'_' 5, STATIC WATER LEVEL (Well #, Depth to water surface, prior to withdrawal, in ft) Well # "A" , 77 ft Well # "B" , 55 ft, Well # "C", 166 ft, Well # "D", 211 ft (If more wells are included in permit, list static water levels on a separate attached sheet.) 6. DETERMINATION OF WATER USE: [X] Metering [] Calculation

7. YEAR 8. IRRIGATION

9. Municipal, 10. AGGREGATE PRODUCTION/

MINING 11. OTHER 2008 I------+-C-=-O-:-RN-:-:-:--:--,; B-:-:E-:-AN-S---'-S"--p-ec-:-ia-:-lty--':C'-ro-p-: ---'--G-:::-O=-OL'--'F'-C"-O::--"U""'R=-=S=E,--,/-l Industrial, (fruits & vegetables) SOD FARM Commercial JAN 48.0 FEB 49.0 C/1 MAR ;:J 58.2 APR 54.1 p;,:j MAY 59.7 < JUN JUL 55.4 56.9 AUG 56.9 SEP 52.4 Z OCT 0 54.6 NOV 53.6 DEC 54.9 12. TOTAL 653.8 NA1\1E (print) Dean Curtland DEWATERING WASHING (wetland development, recreational, etc.) REPORT PREPARED BY: [X]Permit Holder []Agent []Tenant ]Consultant ]New Owner []Other (Specify) _____ _ WATER SUPPLY SECTION -DNR FORM NO. 542 -3115 (R-12/04) ANNUAL WATER Uz, REPORT FORM (Read instructions on reverse side before completing.)

1. PERMIT NO: 3533--R3 4, 2. PERMIT HOLDER (Please print): FPL Energy Duane Arnold. LLC 3. WATER USE REPORTED IN: 5[ ] ACRE-FEET[X] GALLONS[ ] OTHER (Specify):

6.* TYPE OF SOURCE USED: (Follow instructions carefully.) [ ] Well [ ] Gravel Pit/Quarry[ ] Stream [X ] Reservoir/Lake/Pond Name of water source: Pleasant Creek Reservoir* STATIC WATER LEVEL (Well #, Depth to water surface, prior to withdrawal, in ft)Well # __ , _ ft Well# _, ft Well # _ , ft (If more wells are included in permit, list static water levels on a separate attached sheet.)DETERMINATION OF WATER USE: [ ] Metering [X ] Calculation

7. YEAR I 8. IRRIGATION

9. Municipal, Industrial, Commercial

10. AGGREGATE PRODUCTION/

MINING 2008 CORN / BEANS I Specialty Crop: I (fruits & vegetables) I A- Arrc GOLF COURSE /SOD FARM DEWATERING WASHING 11. OTHER (wetland development, recreational, etc.)I 0 0 0 0 MAY 0 JUN 0 JUL 0 AUG 0 0 I +

• 1 1-0 0 0 NAME (Print)Dean Curtland SIGNATURE

& DATE REPORT PREPARED BY: [X]Perinit Holder]Agent [ )Tenant 1 ]Consultant [ ]New Owner, [ ]Other (Specify)WATER SUPPLY SECTION --- DNR FORM NO. 542 -3115 (R-12/04)1. PERMIT NO: 3533--R3 ANNUAL WATER UL,"", REPORT FORM (Read instructions on reverse side before completing.)

4. TYPE OF SOURCE USED: (Follow instructions carefully.) [ ] Well [ ] Gravel Pit/Quarry [ ] Stream [X ] Reservoir/LakeIPond

2. PERMIT HOLDER (Please print): FPL Energy Duane Arnold, LLC 3. WATER USE REPORTED IN: [ ] ACRE-FEET

[X] GALLONS [ ] OTHER (Specify): _____ _ Name of water source: Pleasant Creek Reservoir

5. STATIC WATER LEVEL (Well #, Depth to water surface, prior to withdrawal, in ft) WeIl#_, __ ft Well#_, __ ft Well # ___ ft (If more wells are included in pemrit, list static water levels on a separate attached sheet.) 6. DETERMINATION OF WATER USE: [] Metering [X] Calculation

7. YEAR 8. IRRIGATION

9. Municipal, 10. AGGREGATE PRODUCTION/

MINING 11. OTHER B-E-A-N-S---'-S""'p-ec-ial-ty-C-ro-p-: ---'--G-O-LF-C-O-UR-S=E-/,....-I Industrial, (fruits & vegetables) SOD FARM Commercial 2008 JAN o FEB o VJ. MAR ::> o APR o MAY JUN JUL o o o AUG o ::c SEP o Z OCT 0 o ;;E NOV o DEC o 12. TOTAL o NAME (Print) _____ _ DEWATERING WASHING (wetland development, etc.) REPORT PREPARED BY: [X]Pennit Holder []Agent []Tenant ] Consultant ]New Owner. [ ]Other (Specify) _____ _ WATER SUPPLY SECTION ---DNR FORM NO. 542 -3115 (R-12104) Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D.6 Iowa Department of Natural Resources Letter, C.M. Schwake, Environmental Specialist, to J. Hogan, Duane Arnold Energy Center, "401 Water Quality Certification" dated August 26, 2005.Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D.6 Iowa Department of Natural Resources Letter, C.M. Schwake, Environmental Specialist, to J. Hogan, Duane Arnold Energy Center, "401 Water Quality Certification" dated August 26,2005. Fields of Opportunities STATE OF IOWA THOMAS J. VILSACK, GOVERNOR SALLY J. PEDERSON, LT. GOVERNOR DEPARTMENT OF NATURAL RESOURCES.JEFFREY R VONK, DIRECTOR August 26, 2005 Duane Arnold Energy Center Mr. Jerald Hogan 3277 DAEC Road Palo, IA 52324

Dear Mr. Hogan:

After reviewing your request for State 401 Water Quality Certification, the Iowa Department of Natural.Resources has issued the enclosed Certification. Please read the attached conditions carefully before beginning work on the project.A .copy of this Certification has been forwarded to the office of the Army Corps of Engineers as indicated below.. You are advised to contact that office upon receipt of this certification. if you have any questions or comments about the certification or any conditions contained therein, please contact me at the address shown below or call (515) 281-6615.i Sincerely,-Christine M. Schwake.* Environmental Specialist cc. Mr. John Betker, Department of the Army Corps of Engineers, Rock Island District, Clock Tower Building, P.O. Box 2004, Rock Island, IL 61204-2004. WALLACE STATE OFFICE BUILDING / DES MOINES,. IOWA 50319 515-281-5918 TDD 515-242-5967 FAX 515-281-6794 WWW.STATE.IA.US/DNR .':" , " THOMAS J. VIL5ACK, GOVERNOR SALLY J. PEDERSON, LT. GOVERNOR August 26,2005 Duane Arnold Energy Center Mr. Jerald Hogan 3277 DAEC Road Palo, IA 52324

Dear .i\1r. Hogan:

. STATE OF IOWA DEPARTMENT OF NATURAL RESOURCES JEFFREY R. VONK, DIRECTOR . *After reviewing your request for State 401 Water Quality Certification, the Iowa Department of Natural* Resources has issued the enclosed Certification.

Please read the attached conditions' carefully before* beginning work on the project. . . . A .copy of this Certification been* forwarded to the office of the Army Corps of Engineers as indicated below .. You are advised to contact that office upon receipt of this certification. . If you have any questions or comments about the certification or any conditions contained therein, please contact me at the address shown below or call (515) 281-6615. \) Srncerely, . Christine M. Schwake . . . Enyironmental Specialist CC: . Mr. John Betker, Department of the Anny Corps of Engineers, Rock Island District, Clock Tower Building, P.O. Box 2004, Rock Island, IL ,.," : *... :. WALLACE STATE OFFiCE BUiLDING IDES MOINES,. IOWA 50319 515-281-5918 TDD 515-242-5967 FAX 515*281-6794 WWW.STATEJA.us/oNR* IOWA DEPARTMENT OF NATURAL RESOURCES SECTION 401 WATER QUALITY CERTIFICATION Certification issued to: Effective: August 26, 2005 Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 Project certified: US Army Corps of Engineers, Joint Public Notice No. CEMVR-OD-P-2005-1016 State 401 Water Quality Certification, Application Log No.: 05-I- 1 13-08-02-S Proposal to construct 4 spur dikes and perform dredging operations on the Cedar River in S10, T84N, R8W, in Linn County. A 1250'-long and 50'-wide channel will be mechanically dredged.The sand type material will be loaded onto trucks and hauled to an upland disposal site on the applicant's property. Maintenance dredging will occur on an as needed basis and disposed of in the same location as stated above.Water quality use designation: The Cedar River is designated as a Class A. Primary contact recreational use. These are waters in which recreational or other uses may result in prolonged and direct contact with the water, involving considerable risk of ingesting water in quantities sufficient to pose a health hazard. Such activities would include, but not be limited to, swimming, diving, water skiing, and water contact recreational canoeing. The Cedar River is'also designated as a Class B(WW) Significant resource warm water. These are waters in which temperature, flow and other habitat characteristics are suitable fdr the maintenance of a wide variety of reproducing populations of warm water fish and.associated aquatic communities, including sensitive species.The Iowa Department of Natural Resources (IDNR) has issued this State 401 Water Quality Certification pursuant to Section 401 of the Clean Water Act. The Army Corps of Engineers (Corps) requires state Certification before a Section 404 permit can be issued. Section 401 Certification represents the IDNR's concurrence that the project. certified is consistent with the Water Quality Standards of the state-of Iowa as set forth in Chapter 61 , Iowa Administrative Code.Subject to the attached conditions, incorporated by reference herein, .the IDNR has determined that there is reasonable assurance the proposed activities will be conducted in a manner that will not violate water quality standards of the state.of Iowa.P repar~ed By: Prepared By: Date Executed: August 26,2005 Date Executed: August 26, 2005 IOWA DEPARTMENT OF NATURAL RESOURCES SECTION 401 WATER QUALITY CERTIFICATION Certification issued to: Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 Effective: August 26, 2005 Project certified: US Army Corps of Engineers,]oii1.t Public Notice No. CEMVR-OD-P-2005-1016 State 401 Water Quality Certification, Application Log No.: 05-1-113-08-02-S Proposal to 4 spur dikes and perform dredging operations on the Cedar River in S 1 0, T84N, R8W, in Linn County. A 1250'-long and 50'-wide channel will be mechanically dredged. The sand* type material will be loaded onto trucks and hauled to an upland disposal .site on the applicant's property.* Maintenance dredging will occur on an as needed basis and disposed of in the* . same location as stated above. Water quality use designation: The Cedar River is designated as a Class A 1 Primary contact recreational use. These are waters in which recreational or other usesniay result in prolonged and direct contact with the water, involving considerable risk of ingesting water in quantities sufficient to pose a health hazard. Such activities would include, but not be limited to, swimming, diving, water skiing, and water contact recreational canoeing. The Cedar River is' also designated as a Class B(WW) Significant resource warm water. These are waters in which temperature, flow and other habitat characteristics are suitable for the maintenance of a wide variety of reproducing populations of warm water fish and aqUatic communities, including sensitive species . . The Iowa Department of Natural Resources (IDNR) has issued this State 401 Water Quality Certification* pursuant to Section 401 of the Clean Water' Act. The Army Corps of Engineers (Corps) requires state Certification before a Section 404 permit can be issued. Section 401 Certification represents the IDNR's concUfl'ence-that the project certified is consistent with the Water Quality Standards of the stateoOowa as set forth in Chapter 61, Iowa Administrative Code. Subject to the attached conditions, incorporated by reference herein, the IDNR has determined that there. is .. reasonable assurance the proposed activities will be conducted in a manner that will not violate water quality standards of the state.of Iowa. . Prepared By: Date Executed: August 26, 2005 Duane Arnold Energy Center CEMVR-OD-P-2005-1016 Page 3 GENERAL CONDITIONS

1. Fermittee is responsible for securing and for compliance with such other permits or approvals as may be required by the IDNR, federal, state, or local governmental agencies for the project activities described.

2. The spur dikes may not be constructed until the applicant receives authorization from the Iowa Department of Natural Resources Floodplain Section. For more information regarding the status of this project's floodplain permit, contact Kelly Stone at 515-281-4312.

3. You are encouraged to conduct your construction activities during a period of low flow.4. Clearing of vegetation, including trees located in or immediately adjacent to waters of the state, shall be limited to that which is absolutely necessary for construction of the project. All vegetative clearing material shall be removed to an upland, non-wetland disposal site.5. All construction debris shall be disposed of on land in such a manner that it cannot enter a waterway or wetland. Construction equipment, activities, and materials shall be kept out of the water to the maximum extent possible.

Equipment for handling and conveying materials during construction. shall be operated to prevent dumping or spilling the material into waterbodies, streams or wetlands except as approved herein. Care shall be taken to prevent any petroleum products, chemicals, or other deleterious materials from entering waterbodies, streams or wetlands.6. Erosion control features (i.e., silt fences, silt ditches, silt dikes, silt basins, etc.) must be installed to provide continuous erosion -control throughout the construction and post construction period as well as the revegetation of all disturbed areas upon project completion. Where siltation control features have been reduced in capacity by 50% or more, the features shall be restored to their original condition with a minimum of delay.7. Should the dredged materials be deposited on the shore before being hauled away, a silt. fence, staked bales of straw, or low berms shall be required to limit the reentry of sediments into the lake or river. Erosion control must be in place around the dredged material disposal site.8. All disturbed areas not covered with riprap shall be seeded with native grasses consistent with those included in the NRCS Critical Areas Seeding Mixture, excluding Reed Canarygrass (Phalaris arnznnacea), during an optimal seeding period. If excavation and construction are completed outside an optimal seeding period,' temporary erosion control protection shall be implemented immediately upon completion of excavation'and construction and shall be maintained until such time as seeding can be completed during an optimal period. The applicant shall monitor revegetated areas continuously to assure success of revegetation. If rye is initially planted to stabilize the soil then native warm season grasses shall be planted during the following growing season.9. Riprap shall consist of clean native fieldstone, clean quarry run rock or clean broken concrete. If broken concrete is used all reinforcement material shall be completely removed from it; if removal is not possible, said reinforcement material shall be cut flush with the flat surface of the concrete. It shall be the applicant's responsibility to maintain the riprap suchf that any reinforcement material"that becomes exposed in the future is removed. The concrete-pieces shall be appropriately graded and no piece shall be larger than 3 feet across the longest flat surface. No asphalt or petroleum based material shall be used as or included in riprap material.10. All excavated materials shall be removed to an upland, non-wetland site.'" " GENERAL CONDmONS Duane Arnold Energy Center CEMVR-OD-P-2005-1016 Page 3 1. Permittee* is responsible for securing and for compliance with such other pennits or approvals as may be required by the IDNR, federal, state, or local governmental agencies for the project activities described.

2. The spur dikes may not be constructed until the applicant receives authorization from the .Iowa Department of Natural Resources Floodplain Section. For more information regarding the status of this project's floodplain permit, contact Kelly Stone at 615-281-4312.

3. You are encouraged to conduct your construction activities during a period of low flow. 4. Clearing of vegetation, including trees located in or immediately adjacent to waters of the state, shall be limited to. that which is absolutely necessary for construction of the project. All vegetative clearing material shall be removed to an upland, non-wetland disposal site. . .5. All construction debris shall be disposed of on land in such a manner that it cannot enter a . waterway or wetland. Construction equipment, activities, and materials shall be kept out of the water to the maximum extent possible.

Equipment for handling and conveying materials during construction shall be operated to prevent dumping or spilling the material into waterbodies, streams or wetlands except as approved herein. care shall be taken to prevent any petroleum products, chemicals, or other deleterious materials from entering waterbodies, streams or wetlands.

6. Erosion control features (i.e., silt fences, silt ditches, silt dikes, silt basins, etc.) must be installed to provide continuous erosion control throughout the construction and post construction period as well as the revegetation of all disturbed areas upon project completion.

Where siltation control features have been reduced in capacity by 60% or more, the features shall be restored to their original condition with a minimum of delay. 7. Should the dredged materials be deposited on the shore before being hauled away, a silt fence, staked bales of straw, or low berms shall be required to limit the reentry of sediments into the lake .or river. Erosion control be in place around the dredged material disposal site. 8. All disturbed areas not covered with riprap shall be seected with native grasses co:t:lsistentwith*those included in the NRCS critical Areas Seeding Mixture, excluding Reed Canarygrass (Phalnris arundina.cea.>>) during an optimal seeding period. If excavation and construction are completed outside an optimal seeding period,* temporary erosion control protection shalibe implemented inunediately upon completion of excavation* and construction and shall be rpaintained until such time as seeding can be completed during an optimal period. The applicant shall monitor revegetated areas continuously to assure success of revegetation. If rye is initially planted to stabilize the soil then native warm season grasses shall beplante4 during the following growing season. . . . 9. Riprap shall consist of clean native fieldstone, clean quarry run rock or clean broken concrete. If *broken concrete is Used all reinforcement material shall be completely removed from it; if removal is not possible, said reinforcement material shall be cut flush with the flat surface of the concrete. It *shall be the a,pplicant's responsibility to maintain the rip rap such that any reinforcement material *that becomes exposed in the future is removed. The concrete . pieces shall be appropriately graded and no piece shall be larger than 3 feet across the longest flat surface. No asphalt or petroleum material shall be used as or included in riprap material. .l 10. All excavated materials shall be removed to an upland) non-wetland site. Duane Arnold Energy Center CEMVR-OD-P-2005-1016 Page 4 11. The use of dredging equipment in the river shall be kept to a minimum to cut down on the resuspension of solids.12. If dredging will be performed by hydraulic means, the applicant shall perform a modified elutriate test procedure to predict the effluent quality or the total concentration of contaminants in the effluent. This test simulates the processes occurring during confined disposal and provides information on the dissolved and particulate contaminant concentrations. Results of the elutriatetest shall be forwarded to the Department when available. Should test results prove unsatisfactory,the Department may amend this Certification to assure that effluent water quality requirements are met. The hydraulically dredged material shall have a retention time in the confined disposal site long enough for the return water to meet state water quality standards. Water quality shall be monitored to assure that Iowa's water quality standards are met.Duane Arnold Energy Center CEMVR-OD-P-2005-10 16 Page 4 11. The use of dredging equipment in the river shall be kept to a minimum to cut down* on the resuspension of solids. . 12. If dredging will be performed by hydraulic means, the applicant shall perform a modlfied elutriate test. procedure to predict the effluent quality or the total concentration of contaminants in the effluent. This test simulates the processes occurring during confined disposal and provides. information on the dissolved and particulate contaminant concentrations. Results of the elutriate test shall be forwarded to the Department when available. Should test results prove unSatisfactory, the Department may amend this Certification to assure that effluent water quality requirements are met. The hydraulically dredged material shall have a retention time in the confined disposal site long enough for the return water to meet state water qUality standards. Water quality shall be monitored to assure that Iowa's water quality standards are met. Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D.7 Funk, S. 2007, Ground Water Protection Initiative Site Conceptual Mode.December 19, 2007. 1 Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 0.7 Funk, S. 2007, Ground Water Protection Initiative Site Conceptual Mode. December 19,2007. I Ground Water Protection Initiative Site Conceptual Model December 19 th, 2007 By Steve Funk Table of Contents Developing the Initial Site Conceptual Model 2 Aerial Photos and Engineering Drawings 2 Previous Hydrogeologic Reports 4Potential On-Site and Off-Site Receptors of Groundwater Contamination 7 State and Local Regulations 8 Preliminary Estimates of Groundwater Flow Characteristics 9 Site-Specific Groundwater Flow Profile 15 Measurement of Physical Parameters 18 Attachments 19 Table of Figures Figure 1 -Aerial Photograph 2 Figure 2- Site Drawing: BECH-C101 3 Figure 3 -Regional Groundwater Elevations 9 Figure 4 -Bedrock Elevations 10 Figure 5 -SW -NE Geologic Cross Section 11Figure 6 -NW -SE Geologic Cross Section 11 Figure 7 -Site Boring Plan 12 Figure 8 -Geologic Cross Section N -S 13 Figure 9 -Geologic Cross Section W -E 14 Figure 10 -.Geologic Cross Section W -E 14 Figure 11 -Regional Potentiometric Map of Devonian\Silurian Water Table 15 Figure 12 -Shallow Monitoring Well Flow Directions 16 Figure 13 -Deep Monitoring Well Flow Direction 17 Ground Water Protection Initiative Site Conceptual Model December 19 th , 2007 By Steve Funk Table of Contents Developing the Initial Site Conceptual Model 2 Aerial Photos and Engineering Drawings 2 Previous Hydrogeologic Reports 4 Potential On-Site and Off-Site Receptors of Groundwater Contamination 7 State and Local Regulations 8 Preliminary Estimates of Groundwater Flow Characteristics 9 Site-Specific Groundwater Flow Profile 15 Measurement of Physical Parameters 18 Attachments 19 Table of Figures Figure 1 -Aerial Photograph 2 Figure 2 -Site Drawing: BECH-C101 3 Figure 3 -Regional Groundwater Elevations 9 Figure 4 -Bedrock Elevations 10 Figure 5 -SW* NE Geologic Cross Section 11 Figure 6 -NW -SE Geologic Cross Section 11 Figure 7 -Site Boring Plan 12 Figure 8 -Geologic Cross Section N -S 13 Figure 9 -Geologic Cross Section W* E 14 Figure 10 -Geologic Cross Section W -E 14 Figure 11 -Regional Potentiometric Map of Devonian\Silurian Water Table 15 Figure 12

• Shallow Monitoring Well Flow Directions 16 Figure 13 -Deep Monitoring Well Flow Direction 17 Developing the Initial Site Conceptual ModelThis information provided in this document includes the site operating history, potential contaminant sources, plant layout, and site hydrogeology.- This Site Conceptual Model is a non-numerical, site hydrogeological model, which when used in conjunction with other data, attempts to form a preliminary hypothesis of how and where the releases of contaminants occurred or may occur, how they have moved or may move through the environment, and what impact they may have on human health and the environment.

Aerial Photos and Engineering DrawingsAerial photos and engineering drawings and the site FSAR were reviewed. Topography on site has ageneral slope towards the river in the direction to the South-South-East. Information presented in section two of the UFSAR indicates that the groundwater flow gradient across the site ranges in directions of North-to-South and West-to-East. Figure 1 -Aerial Photograph DAEC Ground Water Protection Initiative: Site Conceptual Model Page 2 of 19 Developing the Initial Site Conceptual Model This information provided in this document includes the site operating history, potential contaminant sources, plant layout, and site hydrogeology.- This Site Conceptual Model is a non-numerical, site hydrogeological model, which when used in conjunction with other data, attempts to form a preliminary hypothesis of how and where the releases of contaminants occurred or may occur, how they have moved or may move through the environment, and what impact they may have on human health and the environment. Aerial Photos and Engineering Drawings Aerial photos and engineering drawings and the site FSAR were reviewed. Topography on site has a general slope towards the river in the direction to the South-South-East. Information presented in section two ofthe UFSAR indicates that the groundwater flow gradient across the site ranges in directions of North-to-South and West-to-East. Figure 1 -Aerial Photograph DAEC Ground Water Protection Initiative: Site Conceptual Model Page 2 of 19 The Site Drawing BECH-C101 illustrates the general topography of the site. Also presented on this drawing are the site groundwater monitoring wells and three of the four site production wells. Site Drawings BECH-C 109 and BECH-C 110 also display the locations of the groundwater monitoring wells.DAEC Ground Water Protection Initiative: Site Conceptual Model Page 3 of 19 The Site Drawing BECH -C 1 0 1 illustrates the general topography of the site. Also presented on this drawing are the site groundwater monitoring wells and three of the four site production wells. Site Drawings BECH -C 1 09alld BECH-C 11 0 also display the locations of the groundwater monitoring wells. DAEC Ground Water Protection Initiative: Site Conceptual Model \ I c ) J I .. /1 " .. J .. / .. I I J / ' I Page 3 of19 Previous Hydrogeologic ReportsThe UFSAR description of the geologic and hydrologic characteristics of the site was reviewed.

• The UFSAR describes two aquifers.

An upper water table aquifer separated from a lower artesian type aquifer. The two aquifers are separated by a impervious clay rich material* The flow gradient in the shallower ground water aquifer is towards the southeast." Artesian pressure in the deeper aquifer will result in an upward transfer of water into theshallower aquifer. It is noted that this condition may be reversed by the extended operation of deep production wells.Relevant sections of UFSAR Section 2.4 are presented here: UFSAR Section 2.4 HYDROLOGIC ENGINEERING 2.4.13 GROUND WATER 2.4.13.1 Description of Onsite Use In the Cedar River basin of Iowa, ground water is obtained from two main sources: shallow wells in unconsolidated glacial and surficial deposits, and deep wells into any of three underlying bedrock aquifers. Wells in glacial deposits usually range between 70 and 200 ft deep depending on location. Wells in rock range between 300 and 1700 ft deep depending on location and on whether the upper, middle, or lower aquifer is tapped.1.) Jordan Aquifer The lower rock aquifer is estimated to lie within the depth range of 1000 to 1700 ft below ground at the plant site. This aquifer is composed of Ordovician and Cambrian rocks, which include St. Peter Sandstone, Prairie du Chien dolomite and sandstone, Jordan sandstone and St. Lawrence dolomite. The Jordan sandstone is the most prolific source of ground water.Water is under high artesian pressure. Well production is about 10 gpm/ft of pumping drawdown. Many wells in this region produce in excess of 1000 gpm of good quality water. There are no plans to develop the Jordan aquifer as a primary water supply for the plant since the Jordan aquifer is a sandstone aquifer which cannot tolerate excessive pumping; alternate wet and dry conditions would lead to ultimate crumbling and collapse.2.) Shallow Aquifers Many adequate supplies of good water are obtained from sand and gravel aquifers in the surficial deposits that overlie the bedrock. These are replenished by direct precipitation, periodic flooding, and, where adequate underground hydraulic connections with streambeds exist, by river recharge.Borings indicate that two aquifers underlie most of the site area, an upper water table aquifer composed of fine to medium sand, and a lower artesian-type aquifer in weathered rock. The two aquifers are separated by 10 to 60 ft of relatively impervious clayey material. Boring logs and water-level measurements indicate that this clay aquiclude is probably continuous over most of the site area.This clay extends above and below river bottom elevation at most boring locations. Ground-water measurements indicate that flows in the upper aquifer are toward the river in a general southeasterly direction across the site. Pressure surface contours indicate that flows in the lower aquifer are also in this same general direction. Since the aquifer below the clay is under considerable pressure in the natural state, any ground-watertransfer between the two aquifers would be from the lower into the upper aquifer. With the production wells operating, the lower aquifer pressure could be lower than the surface water table in the immediate vicinity of these wells. Under this circumstance, ground-water transfer could possibly be reversed over a long period of time.During production well tests and subsequent production well operation, no interference of the upper aquifer has been noted.Gradients causing flow are quite steep in both aquifers. Information collected on domestic wells within a 1 -mile radius of the plant indicates that all domestic wells west and north of the plant are up the ground-water slope from the plant; that is, ground water flows past these wells toward theplant or along some other path directly toward the river. Domestic wells southwest and south of the plant are approximately 1 mile away and are not in the line of ground-water flow past the plant.DAEC Ground Water Protection Initiative: Site Conceptual Model Page 4 of 19 Previous Hydrogeologic Reports The UFSAR description of the geologic and hydrologic characteristics of the site was reviewed.

• The UFSAR describes two aquifers.

An upper water table aquifer separated from a lower artesian type aquifer. The two aquifers are separated by a impervious clay rich material

• The flow gradient in the shallower ground water aquifer is towards the southeast.
• Artesian pressure in the deeper aquifer will result in an upward transfer of water into the shallower aquifer. It is noted that this condition may be reversed by the extended operation of deep production wells. Relevant sections ofUFSAR Section 2.4 are presented here: UFSAR Section 2.4 HYDROLOGIC ENGINEERING 2.4.13 GROUNDWATER 2.4.13.1 Description of On site Use In the Cedar River basin of Iowa, ground water is obtained from two main sources: shallow wells in unconsolidated glacial and surficial deposits, and deep wells into any of three underlying bedrock aquifers.

Wells in glacial deposits usually range between 70 and 200 ft deep depending on location. Wells in rock range between 300 and 1700 ft deep depending on location and on whether the upper, middle, or lower aquifer is tapped. 1.) Jordan Aquifer The lower rock aqu ifer is estimated to I ie with in the depth range of 1000 to 1700 ft below ground at the plant site. This aquifer is composed of Ordovician and Cambrian rocks, which include St. Peter Sandstone, Prairie du Chien dolomite and sandstone, Jordan sandstone and st. Lawrence dolomite. The Jordan sandstone is the most prolific source of ground water. Water is under high artesian pressure. Well production is about 10 gpmlft of pumping drawdown. Many wells in this region produce in excess of 1000 gpm of good quality water. There are no plans to develop the Jordan aquifer as a primary water supply for the plant since the Jordan aquifer is a sandstone aquifer which cannot tolerate excessive pumping; alternate wet and dry conditions would lead to ultimate crumbling and collapse. 2.) Shallow Aquifers Many adequate supplies of good water are obtained from sand and gravel aquifers in the surficial deposits that overlie the bedrock. These are replenished by direct precipitation, periodic flooding, and, where adequate underground hydraulic connections with streambeds exist, by river recharge. Borings indicate that two aquifers underlie most of the site area, an upper water table aquifer composed of fine to medium sand, and a lower artesian-type aquifer in weathered rock. The two aquifers are separated by 10 to 60 ft of relatively impervious clayey material. Boring logs and level measurements indicate that this clay aquiclude is probably continuous over most of the site area. This clay extends above and below river bottom elevation at most boring locations. Ground-water measurements indicate that flows in the upper aquifer are toward the river in a general southeasterly direction across the site. Pressure surface contours indicate that flows in the lower aquifer are also in this same general direction. Since the aquifer below the clay is under considerable pressure in the natural state, any ground-water transfer between the two aquifers would be from the lower into the upper aquifer. With the production wells operating, the lower aquifer pressure could be lower than the surface water table in the immediate vicinity of these wells. Under this circumstance, ground-water transfer could possibly be reversed over a long period of time. During production well tests and subsequent production well operation, no interference of the upper aquifer has been noted. Gradients causing flow are quite steep in both aquifers. Information collected on domestic wells within a 1 -mile radius of the plant indicates that all domestic wells west and north of the plant are up the ground-water slope from the plant; that is, ground water flows past these wells toward the plant or along some other path directly toward the river. Domestic wells southwest and south of the plant are approximately 1 mile away and are not in the line of ground-water flow past the plant. DAEC Ground Water Protection fuitiative: Site Conceptual Model Page 4 of 19 Should the area be inundated by a Cedar River flood, infiltration would temporarily raise the general ground-water table. Some domestic wells south of the plant would be flooded. Those onhigher ground would maintain their same relative positions on the general water table slope.UFSAR/DAEC-1 In the Village of Palo, 2.5 miles south-southwest of the plant, the water table stands approximately 12 ft below average ground-surface elevation 745, or at elevation 733'. Ground-water flow is in an easterly direction toward the river.A comprehensive subsurface exploration program was performed to establish the adequacy and quality of water available for plant use. Two production wells were drilled into the lower artesian aquifer in weathered rock, and a yield of 750 gpm for each well, pumping concurrently, was established. Test reports of water analysis indicated a good mineral quality.2.4.13.2 Sources There are no potable water supplies taken from the Cedar River surface water downstream of the DAEC. Irrigation uses are presented in Section 2.4.1. No permit is required nor is there any restriction on the withdrawal of water from the river for livestock watering, and no records are available. The primary user of water that could originate from the river is the City of Cedar Rapids.Some of the recharge for the city wells comes from the river at normal withdrawal, and under periods of no or low withdrawal no recharge comes from the river.In 1981, the average city water consumption was about 22.6 million gal per day (mgd) with a peak day consumption of approximately 33.8 million gal. It has been estimated that this will increase 2% to 5% per year. This system is expected to have an ultimate capacity of 42 mgd. Total storage capacity within the city system is approximately 16.3 million gal. All of the city water was supplied by wells located adjacent to the Cedar River. Because of this location, a large portion of the water withdrawn from these wells was recharged from the river. In addition, the city has an emergency standby system capable of withdrawing 24 mgd directly from the river.Within a 1.5-mile radius of the plant, there were 14 property owners having I or more wells. The use of these wells extended beyond potable supply to such items as swimming pools, livestock watering, and irrigation. Major industrial water use, within 50 miles downstream of the plant, is concentrated in the Cedar Rapids area. Primary uses of river water include condenser cooling and process water.Agricultural withdrawals are made at a few locations for irrigation purposes. In addition, limited recreational use is made of the river, particularly above the power plant dams in Cedar Rapids, and in the headwater area recreational lakes. The operation of the plant does not affect these activities. Figure 2.4-12 is a generalized map of the piezometric surface of the Silurian-Devonian aquifer within Linn County. This lower aquifer also flows toward the rivers. The production wells tap this lower aquifer. Extensive pumping in the Cedar Rapids area has depressed the piezometric level about 105 ft in 70 years in the center of the area.A piezometric level map for the site area has not been developed. Information available fromborings indicates that the flow in the lower aquifer is toward the river. Test results from production well tests indicate that the recharge comes from a northerly direction in the site vicinity. Observation wells into this aquifer are highly localized making it difficult to state the direction of flow other than toward the river. Any spill at the site would seep into the ground and into the upper aquifer. This worst-case spill is considered in Section 11.2.3.2006 Howard R. Green (Consultants) Report: In 2006 an assessment was performed for the feasibility of Horizontal Collector Wells on site. Theanalysis was performed by the consulting firm Howard R. Green. The HR Green assessment confirmed the hydrogeologic description presented in the UFSAR, the report described Quaternary Deposits of Alluvium overlying glacial till. The HR Green report is included as Attachment 1.DAEC Ground Water Protection Initiative: Site Conceptual Model Page 5 of 19 Should the area be inundated by a Cedar River flood, infiltration would temporarily raise the general ground-water table. Some domestic wells south of the plant would be flooded. Those on higher ground would maintain their same relative positions on the general water table slope. UFSARfDAEC-1 In the Village of Palo, 2.5 miles south-southwest of the plant, the water table stands approximately 12 ft below average ground-surface elevation 745, or at elevation 733'. Ground-water flow is in an easterly direction toward the river. A comprehensive subsurface exploration program was performed to establish the adequacy and quality of water available for plant use. Two production wells were drilled into the lower artesian aquifer in weathered rock, and a yield of 750 gpm for each well, pumping concurrently, was established. Test reports of water analysis indicated a good mineral quality. 2.4.13.2 Sources There are no potable water supplies taken from the Cedar River surface water downstream of the DAEC. Irrigation uses are presented in Section 2.4.1. No permit is required nor is there any restriction on the withdrawal of water from the river for livestock watering, and no records are available. The primary user of water that could originate from the river is the City of Cedar Rapids. Some of the recharge for th.e city wells comes from the river at normal withdrawal, and under periods of no or low withdrawal no recharge comes from the river. In 1981, the average city water consumption was about 22.6 million gal per day (mgd) with a peak day consumption of approximately 33.8 million gal. It has been estimated that this will increase 2% to 5% per year. This system is expected to have an ultimate capacity of 42 mgd. Total storage capacity within the city system is approximately 16.3 million gal. All of the city water was supplied by wells located adjacent to the Cedar River. Because of this location, a large portion of the water withdrawn from these wells was recharged from the river. In addition, the city has an emergency standby system capable of withdrawing 24 mgd directly from the river. Within a 1.5-mile radius of the plant, there were 14 property owners having I or more wells. The use of these wells extended beyond potable supply to such items as swimming pools, livestock watering, and irrigation. Major industrial water use, within 50 miles downstream of the plant, is concentrated in the Cedar Rapids area. Primary uses of river water include condenser cooling and process water. Agricultural withdrawals are made at a few locations for irrigation purposes. In addition, limited recreational use is made of the river, particularly above the power plant dams in Cedar Rapids, and in the headwater area recreational lakes. The operation of the plant does not affect these activities. Figure 2.4-12 is a generalized map of the piezometric surface of the Silurian-Devonian aquifer within linn County. This lower aquifer also flows toward the rivers. The production wells tap this lower aquifer. Extensive pumping in the Cedar Rapids area has depressed the piezometric level about 105 ft in 70 years in the center of the area. A piezometric level map for the site area has not been developed. Information available from borings indicates that the flow in the lower aquifer is toward the river. Test results from production well tests indicate that the recharge comes from a northerly direction in the site vicinity. Observation wells into this aquifer are highly localized making it difficult to state the direction of flow other than toward the river. Any spill at the site would seep into the ground and into the upper aquifer. This worst-case spill is considered in Section 11.2.3. 2006 Howard R. Green (Consultants) Report: In 2006 an assessment was performed for the feasibility of Horizontal Collector Wells on site. The analysis was performed by the consulting firm Howard R. Green. The HR Green assessment confinned the hydrogeologic description presented in the UFSAR, the report described Quaternary Deposits of Alluvium overlying glacial till. The HR Green report is included as Attachment

1. DAEC Ground Water Protection Initiative:

Site Conceptual Model Page 5 of 19 2006 Stanley Consultants Evaluation: In 2006, Stanley Consultants analyzed Site records and well logs from the Iowa Geological Survey Bureau and concluded: "...the subsurface in the area includes two water bearing layers separated by a lower permeability layer of glacial till. These consist of a shallow water bearing surficial sand and gravel layer, and a deeper confined or partially confined sand and gravel and/or limestone layer." and: "The presence of two potential contaminant migration pathways suggests that two sets of wells, one shallow and one deep, may be necessary. Also nearby production wells may influence the direction of groundwater flow in the area so that flow direction in the two aquifers may be different. Accordingly we are recommending that two sets of three wells beconstructed initially, and that these be evaluated for flow direction, and contaminant concentration. Three wells are the minimum necessary to evaluate groundwater flow direction in an aquifer. After initial evaluation additional wells may be constructed if appropriate. The evaluation by Stanley Consultants validated assumptions and conclusions of the hydrogeologic discussions described in the UFSAR.2006 Baseline Assessment of the Risk of Radiological Impacts to Groundwater As part of a FPL Nuclear Plant Fleet initiative, an evaluation of the existing conditions that could affect groundwater quality was performed. A copy of that document is included as Attachment 3.2006 Monitoring Wells: Drilling Standards Monitoring Wells installed in 2006were installed in compliance with the requirements of Iowa Code Sections 567.38. The work was overseen by a Well Contractor Certified by the state of Iowa in accordance with Iowa Code 567.82.DAEC Ground Water Protection Initiative: Site Conceptual Model Page 6 of 19 2006 Stanley Consultants Evaluation: In 2006, Stanley Consultants analyzed Site records and well logs from the Iowa Geological Survey Bureau and concluded: " ... the subsurface in the area includes two water bearing layers separated by a lower permeability layer of glacial till. These consist of a shallow water bearing surficial sand and gravel layer, and a deeper confined or partially confined sand and gravel and/or limestone layer." and: "The presence of two potential contaminant migration pathways suggests that two sets of wells, one shallow and one deep, may be necessary. Also nearby production wells may influence the direction of groundwater flow in the area so that flow direction in the two aquifers may be different. Accordingly we are recommending that two sets of three wells be constructed initially, and that these be evaluated for flow direction, and contaminant concentration. Three wells are the minimum necessary to evaluate groundwater flow direction in an aquifer. After initial evaluation additional wells may be constructed if appropriate. The evaluation by Stanley Consultants validated assumptions and conclusions of the hydrogeologic discussions described in the UFSAR. 2006 Baseline Assessment of the Risk of Radiological Impacts to Groundwater As part of a FPL Nuclear Plant Fleet initiative, an evaluation of the existing conditions that could affect groundwater quality was performed. A copy of that document is included as Attachment

3. 2006 Monitoring Wells: Drilling Standards Monitoring Wells installed in 2006were installed in compliance with the requirements ofIowa Code Sections 567.38. The work was overseen by a Well Contractor Certified by the state ofIowa in accordance with Iowa Code 567.82. DAEC Ground Water Protection Initiative:

Site Conceptual Model Page 6 of19 Potential On-Site and Off-Site Receptors of Groundwater Contamination From the 2007 Land Use Census, the list of closest Residences is presented in Table 1. All residences use well water for drinking water. The two farms located on Power Plant Road participate in the Site's REMP program by providing well water samples on a quarterly basis.No commercial or municipal wells are located within 2 miles of the site. Four deep wells located on site supply both the industrial needs and drinking water for the site.Sector Distance in Meters Distance in Miles Address E 2,230 1.4 3942 Wickiup Hill Road ENE 2,010 1.2 3985 Minnie Lane ESE 2,450 1.5 3221 Lake View Drive N 2,414 1.5 4295 Mather Lane NE 2,510 1.6 4005 Ponds Lane NNE 3,660 2.3 4109 Greens Grove Road NNW 1,620 1.0 4261 McClintock Road NW 2,120 1.3 4394 McClintock Road S 2,200 1.4 10452 Morris Hills Road SE 2,670 1.4 9807 Morris Hills Road SSE 2,380 1.5 10450 Morris Hills Road SSW 1,720 1.1 4370 Comp Road 4318 Power Plant Road SW 974 0.6 REMP Sample Point D-58 4325 Power Plant Road W 805 0.5 REMP Sample Point D-57 WNW 1,560 1.0 3318 Palo Marsh Road WSW 2340 1.5 3200 Lewis Bottoms Road Table I -Nearest Receptors DAEC Ground Water Protection Initiative: Site Conceptual Model Page 7 of 19 Potential On-Site and Off-Site Receptors of Groundwater Contamination From the 2007 Land Use Census, the list of closest Residences is presented in Table 1. All residences use well water for drinking water. The two farms located on Power Plant Road participate in the Site's REMP program by providing well water samples on a quarterly basis. No commercial or municipal wells are located within 2 miles of the site. Four deep wells located on site supply both the industrial needs and drinking water for the site. Sector Distance in Meters Distance in Miles Address E 2,230 1.4 3942 Wickiup Hill Road ENE 2,010 1.2 3985 Minnie Lane ESE 2,450 1.5 3221 Lake View Drive N 2,414 1.5 4295 Mather Lane NE 2,510 1.6 4005 Ponds Lane NNE 3,660 2.3 4109 Greens Grove Road NNW 1,620 1.0 4261 McClintock Road NW 2,120 1.3 4394 McClintock Road S 2,200 1.4 10452 Morris Hills Road SE 2,670 1.4 9807 Morris Hills Road SSE 2,380 1.5 10450 Morris Hills Road SSW 1,720 1.1 4370 Comp Road 4318 Power Plant Road SW 974 0.6 REMP Sample Point 0-58 4325 Power Plant Road W 805 0.5 REMP Sample Point D-57 WNW 1,560 1.0 3318 Palo Marsh Road WSW 2340 1.5 3200 Lewis Bottoms Road Table 1 -Nearest Receptors DAEC Ground Water Protection Initiative: Site Conceptual Model Page 7 of 19 Documentation of Nearby Wells UFSAR Figure 2.4-8 is a map of wells within 3 miles of the DAEC. Well details are presented in UFSAR Table 2.4-2.Action Request PCR24704 was initiated to add guidance to Environmental Sampling Procedure ESP 4.4, Land Use Census for the survey of new wells on an annual basis.Documentation of Nearby Wetlands and Estuaries One mile south of the site, on the west side of the river is the location of the Chain of Lakes Wildlife Management this area is a subset of the Cedar River Greenbelt Project and is composed of land owned by the Linn County Conservation Board and the State of Iowa.The Linn County Park: Chain Lakes Area" is located 3.5 miles south of the site on the Cedar River.This 373-acre park is a part of the Cedar River Greenbelt Project.The Linn County Park, "Palo Marsh", is located 1 mile south of the site on the Cedar River. This 144 acre site is also a part of the extensive Cedar River Greenbelt Project.The Greenbelt project is a corridor of public land along the Cedar River.To the North West and North of the site are Pleasant Creek Park and the Lewis Preserve County Park State and Local RegulationsThe State of Iowa Code was searched:The State of Iowa Code, Section 567-62.1(455B) prohibits the release of high-level radioactive waste into navigable waters.The State of Iowa Code, 567-113 prohibits the disposal, in sanitary landfills, of Radioactive waste, excluding luminous timepieces and other items using very small amounts of tritium.No other State or Local Regulations describe requirements related to the release of radioactive material into the environment. DAEC Ground Water Protection Initiative: Site Conceptual Model Page 8 of 19 Documentation of Nearby Wells UFSAR Figure 2.4-8 is a map of wells within 3 miles of the DAEC. Well details are presented in UFSAR Table 2.4-2. Action Request PCR24704 was initiated to add guidance to Environmental Sampling Procedure ESP 4.4, Land Use Census for the survey of new wells on an annual basis. Documentation of Nearby Wetlands and Estuaries One mile south of the site, on the west side of the river is the location of the Chain of Lakes Wildlife Management this area is a subset of the Cedar River Greenbelt Project and is composed ofland owned by the Linn County Conservation Board and the State of Iowa. The Linn County Park: Chain Lakes Area" is located 3.5 miles south ofthe site on the Cedar River. This 373-acre park is a part of the Cedar River Greenbelt Project. The Linn County Park, "Palo Marsh", is located 1 mile south of the site on the Cedar River. This 144 acre site is also a part of the extensive Cedar River Greenbelt Project. The Greenbelt project is a corridor of public land along the Cedar River. To the North West and North of the site are Pleasant Creek Park and the Lewis Preserve County Park State and Local Regulations The State ofIowa Code was searched: The State onawa Code, Section 567-62.1(455B) prohibits the release of high-level radioactive waste into navigable waters. The State ofIowa Code, 567-113 prohibits the disposal, in sanitary landfills, of Radioactive waste, excluding luminous timepieces and other items using very small amounts of tritium. No other State or Local Regulations describe requirements related to the release of radioactive material into the environment. DAEC Ground Water Protection Initiative: Site Conceptual Model Page 8 of 19 Preliminary Estimates of Groundwater Flow Characteristics Groundwater Elevation UFSAR Figure 2.4.9 is a map that illustrates the regional groundwater elevation. The map demonstrates that groundwater flow direction in the area is towards the south-southeast: 'p.- .*- J r; --i -, w .-6 .'" ".-fr...II S. I +7? Tr-t Page 9 oflI_9 DAEC Ground Water Protection Initiative: Site Conceptual Model Preliminary Estimates of Groundwater Flow Characteristics Groundwater Elevation UFSAR Figure 2.4.9 is a map that illustrates the regional groundwater elevation. The map demonstrates that flow direction in the area is towards the south-southeast: Figure 3 -Regional Groundwater Elevations DAEC Ground Water Protection Initiative: Site Conceptual Model Page 9 of 19 Pre-Operational Groundwater and Geologic Data For the purpose of siting the plant, Seismic Refraction Studies were performed. The results of those studies are summarized in UFSAR Figures 2.5-6. Information from the Seismic Refraction study was used as input to UFSAR figure 2.5-7. Those diagrams are presented here as figures 4, 5 and 6: Figure 4 -Bedrock Elevations DAEC Ground Water Protection Initiative: Site Conceptual Model Page 10 of 19 Pre-Operational Groundwater and Geologic Data For the purpose of siting the plant, Seismic Refraction Studies were performed. The results of those studies are summarized in UFSAR Figures 2.5-6. Information from the Seismic Refraction study was used as input to UFSAR figure 2.5-7. Those diagrams are presented here as figures 4, 5 and 6: i . , ... I . ...... .... . ... . ... . . . .. Figure 4 -Bedrock Elevations DAEC Ground Water Protection Initiative: Site Conceptual Model Page 10 ofl9 'iS(South West). 9-21 B-I? (North East)P-4.r -* -*- -~ a* .-~ ..* --nýkLLUVIU04 710 OIL ) : ..j goo 7-_;.7 L Pon:..7: PR G. 'GRIAM 12 KENWOOD.'.1

Qo~gprFGRNIATI0N. (SILURIAN) 61 -r C JL SECTION A-A I igure 5 -SW -NE Geologic Cross Section North West B~4 * .. .* 8-~6* North

.-53 ,8 South East 750~m HALLUVIUM

• ~ow 7-ý ýOLACIAL, , TILL AVENPOR m SPRING.AIROVE E -ATHERED.KENW06D R1'r N-6w.l Figure 6 -NW -SE Geologic Cross Section DAEC Ground Water Protection Initiative:

Site Conceptual Model Page 11 of 19 H6(South West) B-21 . . . ""'-:...-.... ---... . . .... .... . * * .* ","" P. ," 17 (North East) .... ,. K£HWOOD* GOWER FORMATlON ISIL.URIAN I 610-.-' . Figure 5 -SW -NE Geologic Cross Section *J\JorthWe.st '. .' . . : 830.' .* * ::z!:: '.110 Figure 6 -NW -SE Geologic Cross Section . .*... *. :;::Z: WEATHERED r-I(£NWOOO' H6' . soUth East. = (jOWt:R' -FORMATION .lsl).l.lRIAN) !§:§ . SECTIONB-B-t= DAEC Ground Water Protection Initiative: Site Conceptual Model Page 11 of 19 Based on site Borings, the UFSAR presents additional information about the site geology in UFSAR Figures 2.5-11, 2.5-12, 2.5-13 and 2.5-15. Those figures are presented here as Figures 7-11: Figure 7 -Site Boring Plan DAEC Ground Water Protection Initiative: Site Conceptual Model Page 12 of 19 1*Based on site Borings, the UFSAR presents additional infonnation about the site geology in UFSAR Figures 2.5-11, 2.5-12, 2.5-13 and 2.5-15. Those figures are presented here as Figures 7-11: A3.? ..... . y", Figure 7 -Site Boring Plan CONTROl.. . .. ROOM* DAEC Ground Water Protection Initiative: Site Conceptual Model Page 12 of19

• .. .£X7S1716 6400/0 SURMCZ Noflh.....S.Duth RiPNG ID 730-... So-- -_ _ _ _ _ _EVrN 6WiA4 SUR.A. t North, rx-740 14..,k, i,-14 In 00--00 600"Sction A -.A 4.Figure 8 -Geologic Cross Section N -S DAEC Ground Water Protection Initiative:

Site Conceptual Model Page 13 of 19 A-A Figure 8 -Geologic Cross Section N -S .to .. o* :' I!!! DAEC Ground Water Protection Initiative: Site Conceptual Model Page 13 of19 West_BORI1*ALLUVIAL DEPOSITS 10te1 ST~If CLAYEY 6UJ. SANS?sAW;KTO O~AN itgMiD WHICH ?OAND A 10'""I AMOJ(T ~OAAAC ATERAL J~iFRAGM99ATU OFDVEiD NAT 680-SADJ IE7 O5ARSE Sao GRAVE Wke SCVASVECSSE 31.CrossSection

B-B'igure 9 -Geologic Cross Section W -E 7-0 ,74 800-V4 (East)21 ?w UVJXý DE-OSEItýMAW`

STIFF VERY 4=-W 4RAVEL L-D' ON L11EXII, ITIC .-M.)--am zl, kA-6w IN..........COWER:. FORMAT N p R 0--4-Gro~ss:SeCtion C-C..U IA fl *te Wi S. Wi Figure 10 -Geologic Cross Section W -EDAEC Ground Water Protection Initiative: Site Conceptual Model Page 14 of 19.___-£.I(JS1'lN6 (JIOUHD $I.IRI'ACC CrossSectiori.B-B. Figure 9 -Geologic Cross Section W -E .CrossSQction ¢-¢ .. ****taI !t'o Figure 10 -Geologic Cross Section W -E DAEC Ground Water Protection Initiative: Site Conceptual Model Page 14 of19 Regional Hydrogeologic Characteristics From the Iowa Department of Natural Resources, a Potentiometric Map of the Region was reviewed and is presented here:-.R,$4R 1 ... 1. ..... ~ ~

• SL .. t .... ..... ............

-7MA ýh....Ft--- 5 E benefit of ore data gathered r ov r th yas, H-t hemp rm h '- hsmoedeal.nth.egoa bai.Teupae a does n ttpresn -at tht*nvaidaes the datepres ntdinnn thet -FAWl In stallation H ti~w2;..- AN -j 2l.......ti..t-~j -V -. -. t Figure 11 Regional Potentiometric Map of Devonian\Silurian Water Table The information provided in Figure I11 was compared to UPSAIR Figures 2.4-9 and 2.4-11. With the benefit of more data gathered over the years, the map from the I"DNR has more detail on the regional basis. The updated map does not present data that invalidates the date presented in the UFSARt Site-Specific Groundwater Flow Profile Well Installation As per the 2006 recommendation of Stanley Consultant, 3 pair of monitoring wells were drilled on site; one to the southeast, one to the east-southeast and one "up-gradient" to the northwest. Each pair of wells consisted of a (relatively) shallow well and an intermediate depth well.Analysis of the water levels from the monitoring wells by a Stanley Consultants indicates that shallow groundwater (the "A" monitoring wells) flow is to the south-west, and intermediate depth groundwater (the "B" monitoring wells) flow is to the northeast. It was believed that the intermediate depth wells may be influenced by the DAEC water supply well ("D" well) north of the plant.The hydrological consultant recommends two additional wells be installed, a shallow one to the southwest, and a deep one to the northeast. Following further discussions with Stanley Consultants, a decision to sink 3 more pairs of monitoring wells was reached. See Figures 1 and 2 for the final placement of the 6 pairs of monitoring wells.DAEC Ground Water Protection Initiative: Site Conceptual Model Page 15 of 19 Regional Hydrogeologic Characteristics From the Iowa Department of Natural Resources, a Potentiometric Map of the Region was reviewed and is here: Figure 11 -Regional Potentiometric Map of Devonian\Silurian Water Table The information provided in Figure 11 was compared to UFSAR Figures 2.4-9 and 2.4-11. With the benefit of more data gathered over the years, the map from the IDNR has more detail on the regional basis. The updated map does not present data that invalidates the date presented in the UFSAR. Site-Specific Groundwater Flow Profile WeI/Installation As per the 2006 recommendation of Stanley Consultant, 3 pair of monitoring wells were drilled on site; one to the southeast, one to the east-southeast and one "up-gradient" to the northwest. Each pair of wells consisted of a (relatively) shallow well and an intennediate depth well. Analysis of the water levels from the monitoring wells by a Stanley Consultants indicates that shallow groundwater (the "A" monitoring wells) flow is to the south-west, and intennediate depth groundwater (the "B" monitoring wells) flow is to the northeast. It was believed that the intennediate depth wells may be influenced by the DAEC water supply well ("D" well) north of the plant. The hydrological consultant recommends two additional wells be installed, a shallow one to the southwest, and a deep one to the northeast. Following further discussions with Stanley Consultants, a decision to sink 3 more pairs of monitoring wells was reached. See Figures 1 and 2 for the final placement of the 6 pairs of monitoring wells. DAEC Ground Water Protection fuitiative: Site Conceptual Model Page 15 of19 Horizontal Groundwater Flow Direction Following well measurements performed on 11/29/2007, flow direction the alluvial aquifer groundwater and in the glacial till aquifer from the previous 4 quarters were plotted.Groundwater flow in the shallow alluvium was found to be variable. "Direction To" bearings rangefrom the SW to the SE./I (Fi alloWNionitoring Well Flow Directions DAEC Ground Water Protection Initiative: Site Conceptual Model Page 16 of 19 ( Horizontal Groundwater Flow Direction Following well measurements perfonned on 11129/2007, flow direction the alluvial aquifer groundwater and in the glacial till aquifer from the previous 4 quarters were plotted. Groundwater flow in the shallow alluvium was found to be variable. "Direction To" bearings range from the SW to the SE. DAEC Ground Water Protection Initiative: Site Conceptual Model Page 160f19 Groundwater flow direction in the glacial till aquifer was also highly variable. "Direction To" bearings ranged from the SE to the NE. It is believed that the operation of the D well located towards the Northeast of the monitoring wells has an impact on the water level in the glacial till. When the D well is operated for extended periods of time, a "cone of depression" is created in the water levels of the glacial till.Maps used to determine ground water flow direction from monitoring well data is included as Attachment 2.Plume Distribution and Movement Following the installation of the first three pair of monitoring wells, three more monitoring well weredrilled. Low concentrations of Tritium are occasionally identified in samples from these monitoring wells. The concentration of tritium in the water from these wells was consistent with tritium concentrations in rainwater collected on site. Data does not indicate a plume of contaminated water emanating from a leak of radioactive liquid from plant systems. The need for additional wells for the use of bounding a plume of radioactive body at the DAEC was evaluated and determined to be not justified at this time.See the Annual Radiological Environmental Operating Report for details on tritium contamination in the monitoring wells.DAEC Ground Water Protection Initiative: Site Conceptual Model Page 17 of 19 Groundwater flow direction in the glacial till aquifer was also highly variable. "Direction To" bearings ranged from the SE to the NE. It is believed that the operation of the D well located towards the Northeast of the monitoring wells has an impact on the water level in the glacial till. When the D well is operated for extended periods of time, a "cone of depression" is created in the water levels of the glacial till. Figure 13 -Deep Monitoring Well Flow Direction Maps used to determine ground water flow direction from monitoring well data is included as Attachment

2. Plume Distribution and Movement Following the installation ofthe first three pair of monitoring wells, three more monitoring well were drilled. Low concentrations of Tritium are occasionally identified in samples from these monitoring wells. The concentration of tritium in the water from these wells was consistent with tritium concentrations in rainwater collected on site. Data does not indicate a plume of contaminated water emanating from a leak of radioactive liquid from plant systems .. The need for additional wells for the use of bounding a plume of radioactive body at the DAEC was evaluated and determined to be not justified at this time. . See the Annual Radiological Environmental Operating Report for details on tritium contamination in the monitoring wells. DAEC Ground Water Protection Initiative:

Site Conceptual Model Page 17 of19 Flow Regimes, Connectivity, and Hydraulic Conductivity When radiological contamination of multiple water-bearing zones is confirmed, aquifer tests will help to identify hydraulic connection between zones. The need for such testing at the DAEC was evaluated and determined to be not justified at this time.Measurement of Physical Parameters Water-Level Transducers Water levels in wells and surface water bodies are an indicator of flow potential and direction. Water levels fluctuate continuously in response to several processes, including recharge by precipitation, groundwater recession, tidal flow, and pumping of nearby wells. Data logging pressure transducers can be used gather a extensive amount of water level change data in water levels in monitoring wells.The resulting data provide a measure of the hydraulic gradient within an aquifer, between aquifers, or between an aquifer and a surface water body. .The need for such testing at the DAEC was evaluated and determined to be not justified at this time.Geophysical Testing Geophysical testing techniques such as Down-hole resistivity, heat-pulse flow meters, and hydrophysical logging can be used to identify discrete water-bearing zones and flow direction within fractured consolidated rock aquifers. Additionally, electrical resistivity and seismic methods are useful surface methods for identifying aquifer boundaries such as the interface between the overburden and bedrock. There are also several bedrock borehole imaging techniques that are useful in identifying bedrock features and structure within and between boreholes. The need for such testing at the DAEC was evaluated and determined to be not justified at this time.Hydraulic Conductivity Testing Aquifer testing can be used to determine various aquifer parameters. Hydraulic conductivity is typically of greatest interest because it is used to calculate the rate of groundwater flow. Hydraulic conductivity can be determined by aquifer testing, but it also can.be estimated using porosity and grain size data.The need for such testing at the DAEC was evaluated and determined to be not justified at this time.Hydrophysical TestingAt those plants where contamination has been confirmed in a fractured bedrock aquifer, detailed characterization of the flow domain will be required. Hydrophysical testing is one technique that has been used successfully to achieve that detailed characterization. The need for such testing at the DAEC was evaluated and determined to be not justified at this time.Fate and Transport Numerical Modeling Although a contaminantfate and transport numerical model might provide an important tool for understanding and predicting the spatial and temporal variations of contaminant concentrations in groundwater. The need for such a model was evaluated and determined to be not justified at this time.DAEC Ground Water Protection Initiative: Site Conceptual Model Page 18 of 19 Flow Regimes, Connectivity, and Hydraulic Conductivity When radiological contamination of multiple water-bearing zones is confirmed, aquifer tests will help to identify hydraulic connection between zones. The need for such testing at the DAEC was evaluated and determined to be not justified at this time. Measurement of Physical Parameters Water-Level Transducers ' Water levels in wells and surface water bodies are an indicator of flow potential and direction. Water levels fluctuate continuously in response to several processes, including recharge by precipitation, groundwater recession, tidal flow, and pumping of nearby wells. Data logging pressure transducers can be used gather a extensive amount of water level change data in water levels in monitoring wells. The resulting data provide a measure of the hydraulic gradient within an aquifer, between aquifers, or between an aquifer and a surface water body .. The need for such testing at the DAEC was evaluated and determined to be not justified at this time. Geophysical Testing Geophysical testing techniques such as Down-hole resistivity, heat-pulse flow meters, and hydro physical logging can be used to identify discrete water-bearing zones and flow direction within fractured consolidated rock aquifers. Additionally, electrical resistivity and seismic methods are useful surface methods for identifying aquifer boundaries such as the ,interface between the overburden and bedrock. There are also several bedrock borehole imaging techniques that are useful in identifying bedrock features and structure within and between boreholes. The need for such testing at the DAEC was evaluated and determined to be not justified at this time. Hydraulic Conductivity Testing Aquifer testing can be used to determine various aquifer parameters. Hydraulic conductivity is typically of greatest interest because it is used to calculate the rate of groundwater flow. Hydraulic conductivity can be determined by aquifer testing, but it also can.be estimated using porosity and grain size data. The need for such testing at the DAEC was evaluated and determined to be not justified at this time. HydrophysicaJ Testing At those plants where contamination has been confirmed in a fractured bedrock aquifer, detailed characterization of the flow domain will be required. Hydrophysical testing is one technique that has been used successfully to achieve that detailed characterization. The need for such testing at the DAEC was evaluated and determined to be not justified at this time. Fate and Transport Numerical Modeling Although a contaminant/ate and transport numerical model might provide an important tool for understanding and predicting the spatial and temporal variations of contaminant concentrations in groundwater. The need for such a model was evaluated and determined to be not justified at this time. DAEC Ground Water Protection Initiative: Site Conceptual Model Page 18 of19 Attachments

1. Howard R. Green Report on feasibility of horizontal collector wells 2. Maps used to determine groundwater flow direction.

3. Baseline Assessment of the Risk of Radiological Impacts to Groundwater

-8/30/2006. DAEC Ground Water Protection Initiative: Site Conceptual Model Page 19 of 19 Attachments

1. Howard R. Green Report on feasibility of horizontal collector wells 2. Maps used to determine groundwater flow direction.

3. Baseline Assessment of the Risk of Radiological Impacts to Groundwater

-8/30/2006. DAEC Ground Water Protection Initiative: SHe Conceptual Model Page 19 of19 Attachment 1 Howard R. Green Report on Feasibility of Horizontal Collector Wells DAEC Ground Water Protection Initiative: Site Conceptual Model Attachments Attachment 1 Howard R. Green Report on Feasibility of Horizontal Collector Wells DAEC Ground Water Protection Initiative: Site Conceptual Model Attachments Howard R. Green Company February 21, 2006 Mr. Frank George Nuclear Management Company, LLC Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 Re: Phase I Assessment, Radial Collector Well

Dear Frank:

This letter summarizes the results and conclusions of the Phase I exploratory drilling completed in January 2006 and presents a recommendation to pursue other nearby favorable locations. The Phase I program was designed as an exploration effort to assess the feasibility of a 6 MGD radial collector well(s) along the west bank of the Cedar River on DAEC property. Phase I was recommended for completion prior to committing to larger-scale and more expensive hydrogeologic testing. The Phase I study indicates development along the west bank of the river is not geologically feasible. However more promising areas are located nearby and apparently on DAEC property east of the river, including across from the intake (Area #1), one mile upstream from the intake (Area

1. 2), and on non-DAEC property less than two miles north of the plant (Area #3) (Figure 1). The Phase I study and basis for recommendations are discussed below.Phase I Study The Phase I project consisted of two parts, including (1) desktop study and compilation of existing subsurface data, including from the Iowa Geological Survey, the Soil Conservation Service, the U.S. Geological Survey, and boring logs presented by DAEC at the kickoff meeting held on January 5, 2006, and (2) exploratory drilling to characterize the subsurface along the west bank of the Cedar River.1. Desktop Study. Compilation of existing state and federal information shows alluvial deposits along the Cedar River. This is observed locally through examination of on-site Silurian well logs, the river's configuration, and the areas considered as potentially containing sand material (see Figure 1). The Silurian well logs which are located closeto glacial till uplands indicate the presence of sand. It was hoped the sand deposits would thicken toward the river and be conducive to well development by providing a capacity similar to that realized downstream by the City of Cedar Rapid's Water Department (CRWD). The main objective of.the Phase I borings was to characterize the alluvium.Conceptually, the areas most conducive to collector well development

-that is where the potential for sand is greatest -are those where the main river channel exists or where the river cuts into and is forced around glacial till uplands (ridges). Where the 8710 Earhart Lane SW

• Cedar Rapids, IA 52404 , PO Box 9009 , Cedar Rapids, IA 52409-9009 319.841.4000 fax 319.841.4012 toll free 800.728.7805 www.hrgreen.com

---

'--'-'

Howard R. Green Company February 21, 2006 Mr. Frank George Nuclear Management Company, LLC Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 Re: Phase I Assessment, Radial Collector Well

Dear Frank:

This letter summarizes the results and conclusions of the Phase J exploratory drilfjng completed in January 2006 and presents a recommendation to pursue other nearby favorable locations. The Phase I program was designed as an exploration effort to assess the feasibility of a 6 MGD radial collector well(s) along the west bank of the Cedar River on DAEC property. Phase I was recommended for completion prior to committing to larger-scale and more expensive hydrogeologic testing. The Phase I study indicates development along the west bank of the river is not geologically feasible. However more promising areas are located nearby and apparently on DAEC property east of the river, including across from the intake (Area #1). one mile upstream from the intake (Area #2), and on non-DAEC property less than two miles north of the plant (Area #3) (Figure 1). The Phase I study and basis for recommendations are discussed below. Phase I Study The Phase I project consisted of two parts, including (1) desktop study and compilation of existing subsurface data, including from the Iowa Geological Survey, the Soil Conservation Service, the U.S. Geological Survey, and boring logs presented by DAEC at the kickoff meeting held on January 5, 2006, and (2) exploratory drilling to characterize the subsurface along the west bank of the Cedar River. 1. Desktop Study. Compilation of existing state and federal information shows alluvial deposits along the Cedar River. This is observed locally through examination of on-site Silurian well logs, the river's configuration, and the areas considered as potentially containing sand material (see Figure 1). The Silurian well logs which are located close to glacial till uplands indicate the presence of sand. It was hoped the sand deposits would thicken toward the river and be conducive to well development by providing a capacity similar to that realized downstream by the City of Cedar Rapid's Water Department (CRWD). The main objective of the Phase I borings was to characterize the alluvium. Conceptually, the areas most conducive to collector well development -that is where the potential for sand is greatest -are those where the main river channel exists or where the river cuts into and is forced around glacial till uplands (ridges). Where the 8710 Earhart Lane SW* Cedar Rapids, fA 52404* PO Box 9009

• Cedar Rapids, IA 52409-9009 319.841.4000 fax 319.841.4012 toll free 800.728.7805 www.hrgreen.com Howard R. Green Company flow direction changes quickly the river loses energy and coarser material (sand &gravel) is more likely to fall out in deposition.

Such favorable areas are observed in Areas #1, #2, and #3 because thicker deposits of coarse sand are more likely in thisgeologic setting, which is similar to CRWD. Downstream along the trailing edge of riverbank cutting the energy is lower and fine sand, silt, and clay deposits characteristic of floodplain overburden are more likely.In Area #1 anecdotal reports are that periodic dredging of the river bed in the vicinity ofthe intake produces good concrete sand (> 90% silica). As an early indicator these factors were viewed favorably with respect to the potential presence of sand and good hydraulic interconnection between the river and groundwater system (which is needed for a collector well).What was not known coming into the Phase I drilling was whether or not the main river channel extended west beneath DAEC property along the west river bank. Discussion of the more favorable areas identified above was not a factor and the Phase I drilling was concentrated along the west river bank on DAEC property where logistics and economic considerations were most promising. Boring logs presented by DAEC at the January 5, 2006 kickoff meeting were reviewed (Iowa Electric Light & Power Co., Drawing C-F1219, 1970). The logs are concentratedaround the main plant with 3 extending toward the river (B-I, B-8, and B-9). The boringsshow the river terrace deposits generally as a thin soil horizon (< 6 feet) over loose to medium dense fine to medium sand with trace coarse sand and gravel (up to 34 feet)over sandy silt (up to 25 feet) or directly over silty clay interpreted as glacial till. Bedrock was not noted in any boring and seismic refraction profiles showing the bedrock profile extending to the river were not available for review (Bechtel, Drawing C-1 04, 1969). The logs generally were not viewed optimistically in that it was hoped that a thicker, coarser material more indicative of river channel deposits was present.A portion of an Options Report (Stanley, 2004) was also presented at the kickoff meeting. That report, citing boring (D500 and D501) results along the river, concluded the collector well option appears infeasible due to the thin nature of the aquifer.Given the geotechnical objectives of the noted site borings -in contrast to a water supply perspective -the Phase I effort proceeded to exploratory drilling to fully define the nature of the alluvial sediment along the west river bank.2. Exploratory Drilling. The Phase I boring plan was designed to explore the west bank of the river, including both the lower and upper river terraces (Figures 1 and 2). The floodway was not explored because the permit requirements for a structure are more involved, including a Federal 404 Permit from ACOE, a State 401 Certification from IDNR, and possibly a wetland mitigation plan and NEPA cultural resources and archeology reviews/surveys. In addition based on a comparison of recent and historical (1930s and 1990s) aerial photos, and as noted in the Options Report, the river's course is subject to change over time at this particular location. This does not rule out such locations but detailed assessment will be needed to fully evaluate those opportunities. 8710 Earhart Lane SW -Cedar Rapids, IA 52404 -PO Box 9009 -Cedar Rapids, IA 52409-9009 319.841.4000 fax 319.841.4012 tofl free 800.728.7805. www.hrgreen.com '-""'-----' Howard R.Green Company flow direction changes quickly the river loses energy and coarser material (sand & gravel) is more likely to fall out in deposition. Such favorable areas are observed in Areas #1. #2, and #3 because thicker deposits of coarse sand are more likely in this geologic setting, which is similar to CRWD. Downstream along the trailing edge of riverbank cutting the energy is lower and fine sand, silt, and clay deposits characteristic of floodplain overburden are more likely. In Area #1 anecdotal reports are that periodic dredging of the river bed in the vicinity of the intake produces good concrete sand (> 90% silica). As an early indicator these factors were viewed favorably with respect to the potential presence of sand and good hydraulic interconnection between the river and groundwater system (which is needed for a collector well). What was not known coming into the Phase I drilling was whether or not the main river channel extended west beneath DAEC property along the west river bank. Discussion of the more favorable areas identified above was not a factor and the Phase I drilling was concentrated along the west river bank on DAEC property where logistics and economic considerations were most promising. Boring logs presented by DAEC at the January 5, 2006 kickoff meeting were reviewed (Iowa Electric Light & Power Co., Drawing 1970). The logs are concentrated around the main plant with 3 extending toward the river (B-1, B-8, and B-9). The borings show the river terrace deposits generally as a thin soil horizon << 6 feet) over loose to medium dense fine to medium sand with trace coarse sand and gravel (up to 34 feet) over sandy silt (up to 25 feet) or directly over silty clay interpreted as glacial till. Bedrock was not noted in any boring and seismic refraction profiles showing the bedrock profile extending to the river were not available for review (Bechtel, Drawing C-104, 1969). The logs generally were not viewed optimistically in that it was hoped that a thicker, coarser material more indicative of river channel deposits was present. A portion of an Options Report (Stanley, 2004) was also presented at the kickoff meeting. That report, citing boring (0500 and D501) results along the river, concluded the collector well option appears infeasible due to the thin nature of the aquifer. Given the geotechnical objectives of the noted site borings -in contrast to a water supply perspective -the Phase I effort proceeded to exploratory drilling to fully define the nature of the alluvial sediment along the west river bank. 2. Exploratory Drilling. The Phase I boring plan was designed to explore the west bank of the river, including both the lower and upper river terraces (Figures 1 and 2). The floodway was not explored because the permit requirements for a structure are more involved, including a Federal 404 Permit from ACOE, a State 401 Certification from IDNR, and possibly a wetland mitigation plan and NEPA cultural resources and archeology reviews/surveys. In addition based on a comparison of recent and historical {1930s and 1990s)aerial photos, and as noted in the Options Report, the river's course is subject to change over time at this particular location. This does not rule out such locations but detailed assessment will be needed to fully evaluate those opportunities. 8710 Earhart Lane SW* Cedar Rapids, IA 52404

• PO Box 9009' Cedar Rapids, IA 52409-9009 319.841.4000 fax 319.841.4012 toll free 800.728.7805.

www.hrgreen.com Howard R, Green Company Drilling results show the river valley axis is beneath the floodway and that the riverterrace deposits along the west bank are comprised mainly of thin silty sand over shallow glacial till, which are not conducive to well development. Specifically, six borings located on the river terrace upstream of the intake were drilled.The sand encountered varied from none at boring SB7 to 13.5 feet at SB5, and all locations were dominantly silty fine to medium sand. The underlying glacial clay confining unit was encountered at less than 18 feet deep in each boring. Based on the Options Report logs which did encounter bedrock directly beneath the glacial till, the Phase I borings were not extended to rock once glacial till was encountered in order to limit costs. For a collector well a thicker deposit (aquifer) of medium to coarse sand with gravel and good hydraulic connection with the river is needed.Although the areas explored on DAEC property were found not favorable for a collector well, conditions still appear conducive in the areas shown in Figure 1, including Area #1 located across from the intake in Section 10 and apparently on DAEC property, Area #2 located a mile upstream from the intake and across the river also apparently on DAEC property, and Area #3 located 1% mile upstream from the intake in the southwest corner of Section 3. It is recommended 2 to 3 test borings and a pumping test be completed in at least two of the three areas to assess their groundwater supply potential. A preliminary estimate for a pipeline to carry 4,200 GPM from each of the three areas is given in Table 1. Given the anticipated collector well cost of $3.2M (plus additional cost for building in the floodway) the pipeline, especially for Area #1, is a relatively small percentage of the project.To obtain 6 MGD from another source would require significantly more water main.Table 1. Estimated Pipeline -Length and Cost Area #1 Area #2 Area #3 Length of Pipeline 2,700' 8,700' 10,500 River Crossing 400' 500' 500'Estimated Cost $362,000 $772,000 $880,000 8710 Earhart Lane SW -Cedar Rapids, IA 52404 -PO Box 9009 -Cedar Rapids, IA 52409-9009 319.841.4000 fax 319.841.4012 toll free 800.728.7805 www.hrgreen.com =----> Howard R. Green Company Drilling results show the river valley axis is beneath the floodway and that the river terrace deposits along the west bank are comprised mainly of thin silty sand over shallow glacial till, which are not conducive to well development. Specifically, six borings located on the river terrace upstream of the intake were drilled. The sand encountered varied from none at boring S87 to 13.5 feet at SB5, and all locations were dominantly silty fine to medium sand. The underlying 'glacial clay confining unit was encountered at less than 18 feet deep in each boring. Based on the Options Report logs which did encounter bedrock directly beneath the glacial till, the Phase I borings were not extended to rock once glacial tiJ1 was encountered in order to limit costs. For a collector well a thicker deposit (aquifer) of medium to coarse sand with gravel and good hydraulic connection with the river is needed. Although the areas explored on DAEC property were found not favorable for a collector well, conditions still appear conducive in the areas shown in Figure 1, including Area #1 located across from the intake in Section 10 and apparently on DAEC property, Area #2 located a mile upstream from the intake and across the river also apparently on DAEC property, and Area #3 located 1% mile upstream from the intake in the southwest corner of Section 3. It is recommended 2 to 3 test borings and a pumping test be completed in at least two of the three areas to assess their groundwater supply potential. { A preliminary estimate for a pipeline to carry 4,200 GPM from each of the three areas is given in Table 1. Given the anticipated collector well cost of $3.2M (prus additional cost for building in the floodway) the pipeline, especially for Area #1, is a relatively small percentage of the project. To obtain 6 MGD from another source would require significantly more water main. Table 1. Estimated Pipeline -Length and Cost Area #1 Area #2 Area #3 Length of Pipeline 2,700' 8,700' 10,500 River Crossing 400' 500' 500' Estimated Cost $362,000 $772,000 $880,000 8710 Earhart Lane SW* Cedar Rapids, IA 52404' PO Box 9009* Cedar Rapids, IA 52409-9009 319.841.4000 fax 319.841.4012 toll free 800.728.7805 W'NW.hrgreen.com Howard R, Green Company One final comment, it was mentioned during the Phase I drilling that Silurian Well 4 exhibits excellent specific yield -about 10 feet of drawdown when test pumping at about 1,000 GPM. If so, this yield is in the upper-end for the Silurian aquifer in this area. Though it could never provide the high capacity of a collector well it still might be a valuable supplemental source. A close examination and/or testing of the well and its construction are recommended to assess the feasibility of upgrading the pump and water main to this well.Thank you for your selecting Howard R. Green Company to participate in this project and don't hesitate to contact me at 841-4393 if you have any questions. Sincerely, Howard R. Green CompanyGreg Brennan, PHG.Attachments cc: Jim Swales, NMCAndrew Marsh, Howard R. Green Company O:\PROJ\186960\Reportrpt-022106-DAEC-Phasel.doc 8710 Earhart Lane SW

• Cedar Rapids, IA 52404
• P0 Box 9009
• Cedar Rapids, IA 52409-9009 319.841.4000 fax 319.841.4012 toll free 800.728.7805 www.hrgreen.com Howard Ri Green Company One final comment, it was mentioned during the Phase I drilling that Silurian Well 4 exhibits excellent specific yield-about 10 feet of drawdown when test pumping at about 1,000 GPM. If so, this yield is in the upper-end for the Silurian aquifer in this area. Though it could never provide the high capacity of a collector well it still might be a valuable supplemental source. A close examination and/or testing of the well and its construction are recommended to assess the feasibility of upgrading the pump and water main to this well. Thank you for your selecting Howard R. Green Company to participate in this project and don't hesitate to contact me at 841-4393 if you have any questions.

Sincerely, Howard R. Green Company ;"--7) b*,A.-Lj-l> """-Greg Brennan, P.HG. Attachments cc: Jim Swales, NMC Andrew Marsh, Howard R. Green Company O:\PROJ\ 186960\Report\rpt*0221 06-0AEC-Phasel.doc 8710 Earhart Lane SW' Cedar Rapids, IA 52404* PO Box 9009' Cedar Rapids, IA 52409-9009 319.841.4000 fax 319.841.4012 toll free 800.728.7805 www.hrgreen.com Howard R. Green Company FIGURES 8710 Earhart Lane SW -Cedar Rapids, IA 52404 -PO Box 9009 -Cedar Rapids, JA 52409-9009 319.841.4000 fax 319.841.4012 toll free 800.728.7805 www.hrgreen.comHoward R. Green Company FIGURES 8710 Earhart Lane SW

• Cedar Rapids, IA 52404
• PO Box 9009
• Cedar Rapids, JA 52409-9009 319.841.4000 fax 319.841.4012 toll free 800.728.7805 www.hrgreen.com I~hA -AEA #3" ,-: -i.i, -, , -',.-At.:A -.rad -I- -....- /. , I I Legend Figure 1 SITE LOCATION MAP DUANE ARNOLD ENERGY CENTER JANUARY 2006 I Possible Pipeline Routes... s Glacial Till -River Terrace Boundary+/----. Upper -Lower River Terrace Boundary Floodway (approx.):: .... Property Boundary (approx.)[nrr 0 1,000 2,000 Feet'" .. ",'1"",<," .. -: ... '

ii'

.,.",' .: j' "', ." Figure 1 SITE LOCATION MAP DUANE ARNOLD ENERGY CENTER JANUARY 2006 '. ...* , ,: ., = Possible Pipeline Routes .' .* -. -.:.: ' -..... -Glacial Till

• River Terrace Boundary Upper* Lower River Terrace Boundary Ffoodway (approx.)

Property Boundary (approx.) I ° N + I 1,000 2,000 Feet Figure 2 PHASE I -BORINGS DUANE ARNOLD ENERGY CENTER JANUARY 2006 Legend@ Phase I Borings-Possible Pipeline Routes.-- -Glacial Till -Upper River Terrace Boundary.--- Upper -Lower River Terrace Boundary Floodway (approx.)" Property Boundary (approx.) 0 40-1-- .I)0 800 Feet 9 Figure 2 Legend PHASE I -BORINGS Phase f Borings DUANE ARNOLD ENERGY CENTER Possible Pipeline Routes N JANUARY 2006 --.. -Glacial Till -Upper River Terrace Boundary + .... = Upper* Lower River Terrace Boundary lEIS"'WlUl!!I Floodway (approx.) p.II_III-" ",_"" ... j Property Boundary (approx.) I o I 400 800 Feet Howard R. Green Company WELL LOGS 8710 Earhart Lane SW -Cedar Rapids, IA 52404

• PO Box 9009 -Cedar Rapids, IA 52409-9009 319.841.4000 fax 319.841.4012 toll free 800.728.7805 www.hrgreen.com
• , Howard R. Green Company WELL LOGS 8710 Earhart Lane SW
• Cedar Rapids, IA 52404
• PO Box 9009' Cedar Rapids, IA 52409-9009 319.841.4000 fax 319.841.4012 toll free 800.728.7805 www.hrgreen.com

!b 10 06 02:42p p.5 field boring log JobNOb-0 Nooject Name kC ( PW '4_ ___Boring No -Date Started i/ Date Completed DrIled By Logged By Rig6 subsurface stratigraphy Flight Auger" 4"' H.S. Auger R Size Size SFrom To Description ___ ____~ S\L~f, C)__ _Ck{otary ize water levels While Drilling 0 Hours A.B.Hours A.B..\.weI' details Stick-up Cover .. -.Flush Mount Cover __~riCO grade-Bottom of Boring sample data Depth LV> 15S'.v 20.0 --25D 35.0' 4-0 MO.0 ~Thr--7-,/-Depth 4O-9,9. 0 Numnb r/T e AS (auger sample) C CS (continuous sample) ARS (air rotary sample)SS (split spoon sample) ST {shelby tube sample) NQ2 (wireline rock coring)aquadrill b 1000 02:42p p.5 field. boring log 00-00 \ Job No _ . ____ . ___ ._. oje9tName DA-tc e PAW .-:r:tf. , Boring No .:;;..& -.\ Date (g8 ZCD to . a J& Date Completed . 0 !"'V 'Y 1 I 20fip Drilled By ' Logged By STPlf--Rig O\LV --&--57 subsurface stratigraphy -...L " Flight Auger/-2_ Size ___ .. _ ..

• From D.D Co.D t3:0 To 0.D \3.D H.S.Auger_

Size __ _ Description Bottom of Boring ____ . .. S'D. 0 sample data Size __ _ J"-:*ODe.POth _ c_D Depth Number'!)'pe .. J-,f'J..? 450 -5tJ.o \ 0 50---JO.t) 2-.As (O.D-I5'.o * -A \5.0-20.0 = ---As. 20.0 -*5" 2'2f)---6D.D. -s :-OI[ ]-5 35.0-.0 .0# .. ' water levels .. --... : ...... --.. _-_.::,j::. . Wh11e Drilling 0 __ _ o Hours AB. _ HoursA.R II, details Flush Mount Cover __ N,Q,. VJ:8I-t)(){j oquodrill AS (auger sample). OS (continuous sample) ARS (air rotary sample) SS (split spoon sample) ST {shelby tube san1"pfe} NQ2 (wirefine rock coring) ?b 10 06 02:42p field boring log Job oject Neme -VRETC- 'PU Q _q c Boring No ~4Date Started 1P1 "Date Completed agt10 L Drilled By Logged By Rig r-subsurface stratigraphy Flight Auger H.S. Auger___Size _ -_ Size Rotary Size water levels While Drilling71'.0 Hours A.B. ..Hours A.B.From i).5-TO Description I AT ' -"-'well details Stick-up Cover _ -.. .Flush Mount Cover.grade-2 5OC Bottom of Boring 1P -d sample Depth 30-20-O 2.o --.o 20.V -2TO Noi~NumberfType I-As,'_ -fl , 4--I-7 Depth Number/Type AS (auger sample) CS (continuous sample) ARS (air rotary sample)SS (split spoon sample) ST (shelby tube sample) NQ2 (wireline rock coring)aqu.odri -I,1 0 02:42p field boring log Name 1A1EL @> '{)ifW :rI+. No .--6[3-2-. Date Started ')l*! 1 '11ll tro& Drilled By Logged By Ii. subsurface stratigraphy . /i.."lf Fright Auger H.S. Auger __ Rotary __ _ Size .. ___ .. Size __ _ Size __ _ From D,D To Description {O.ODK.l'ba.\)vl'l cLA1 }O,1) BlkGcJLJ 5/11& ( )4.5-14. §' F"Y'Je.. - '5!WD Bottom of Boring . __ . sample data Depth D.D* S.O S.Q-)o .. D iO.O )5,0 -2Q.O 20.D-25'.0 lJILl:Jle( 'GILTI nih:' Numberrrype 2-11> 3-11s 4-AS (p. A> . I . Depth Numberrrype .. AS (auger sample) CS (continuous sample) ARS {air rotary sample) SS [split spoon sample) ST (shelby tube sample) NQ2 {wireline rock coring) pA Job No DD { water levels .. ' ... ... -... -S .. V+/--. WhIte DrillIng .. * "' .. I o Hours A.B ..... __ _ Hours A.s. ...... __ ._ . welf details $trek-up Cover . ____ __ Flush Mount Cover .. __ . __ . NO . W\zLl -----------_--.: __ --oOIIIIb._. aqUadri II 10b 0.6 02:42p p.7 field boring log Job No -oj"-t Name_ ___ _ _Boring No .GDate Started ~Y~>~?L Date CompletedTY?\ '2C(Drilled By ýj LoggedBy Rig LANJ L5;7 ___subsurface stratigraphy Fright Auger .. H.S. Auger Size Size Rotary Size From 17.ýTo Description water levels While Drilling :7-5 0 Hours A.B.Hours A.B......well details Stick-up Cover.Flush Mount Cover ...--'DIL bt-n"1:11 5W,ýj ýj Lýt IV., L-rwill 20Deo Boltom of Boring sample dat Depth* -7_0.Number/Type 4- -;¢.~. c Depth Number/Type Vo~l ZA.AS (auger sample) CS (continuous sample) ARS (air rotary sample)SS (split spoon sample) ST (shelby tube sample) NQ2 (wireline rock coring)aquodrill 910 09 02:42p p.? boring log JobNo_O{u-OO) ojeC?t Name -1)f1\-:::=:C='

---

,rr----------.

-L.. 7 . ,.-.-)'\ .. Vi H; --t', . -:-\"i Boring No .-.:!.C.:>* 2 Date Started ) h J V ! C .? eel.. Date Completed ) 'bN \ , 2. <1.6 Drliled By Logged By c.;'E"vS Rig o(LV *, ___ _ subsurfaqe stratigraphy 4\\ Flight Auger __ . . . H.S. Auger _ Size Slze __ _ From (), b -"'). , To 0,0 .'2 t? \ ,. Rotary ___ _ Size __ _ LV,O Bottom of Borin9* __________________ sample data Depth o* S . NumberfType \ - Depth Numberrrype ll-j*20 AS (auger sample) CS (continuous sample) ARS (air rotary sample) . SS (split spoon sample) ST (shelby tube sample) NQ2 (wireline rock coring) water levels . . . ... --........ _ .. -. While Drilling _J....J...:.-". J=---_ . 0 Hours AB ... ___ _ Hours AS .. ____ _ wen details Stick-up Cover. __ _ Flush Mount Cover ... __ . grade -aquodrill tb 10 0Q 02:42p p, 6 field boring log Job.oI,-cc ý)ject N ame LAIWC ~P~ _Boring No IDate Started JIi ~ ~~DateCompleted 3 A Drilled By RLogge By E Rg _____--_subsurface stratigraphy water levels I Flight Auger H.S. Auger -Rotary While Drilling _ ......Size_ ___ Size Size 0 Hours AB.Hours A.B.rom oTh-To.0, Descriptiop 4AtJy c%well details Stick-up Cover Ffush Mounf Cover-_grade -Botfom of Boring 7c~o _________Nu ber/Type sample data NO Depth 0,,.-5\%5 -IO~L Nu~be 2- R6-Re.Depth Number/Type AS (auger sample) CS (continuous sample) ARS (air rotary sample)SS (split spoon sample) ST (shelby tube sample) NQ2 (wireline rock coring)aquodrilIJ10 00 02:42p p.6 field. boring log Job NO.£:tz. ( )ject Name DftE.C @ PALO Boring No Date Started :rAJi ioTIfl)W --{;ffi= Date Completed --.l i!N \ 0 ! ZO'oto Drilled By Logged By SI(z)) E-Rig aL\f G:_*57_---;-I __ subsurface stratigraphy LI-,I Flight Auger l* H.S, Auger_ Rotary __ _ 81ze. __ _ FOrom 5:0 \/.'1 1:0 17*5" Boltom of Bori ng _. sample data: Depth C\O**S.D \bD "\5.D . \S.O * ... '10.0 Siz;e __ _ $jz9 __ _ l)V--g, l-J ;;Icr( aA Y 70.0 ----------------- Depth NumberfType r;s {auger sampie) CS (continuous sample) ARS (air rotary sample) S8 {split spoon sample) ST (shelby tube sample) NQ2 (wireline rock coring) o Hours A.B. ____ _ Hours A.B. __ _ well details . Stick-up Cover . .:..... __ _ Frush Mount Cover ... _. aquodrill .,3)b IO 06 02:41p Field boring log Job No_0tb -0)Boject Name9A.C (C a Sta Boring No ________Date Started +/-2§li Date ComnpletedJ1?2Q Drilled By -Logged By Rig -7IC2IA__subsurface stratigraphy Flight Auger H.S. Auger Size _ -_ Size Rotary Size water levels While Drilling 0 Hours A.B.Hours A.B, From 0.0 To-DesX cAJ i4p (fiMR!_ý WO L-a t(Al W well details Stick-up Cover..-, Flush Mounf Cover__-, grade -Bottom of Boring'9 sample date Depth 5,zb -ý.6_2,--D ilý 0ýQIEU_Depth Number/Type -,S (auger sample) CS (continuous sample) ARS (air rotary sample)SS (spilt spoon sample) ST (shelby tube sample) NQ2 (wireline rock coring)aqubd rill--L Pb lb 10 O§ 02:41p p.3 Job No _QIP -00) fieJd boring log @ .QA-lo " -':\\\ Boring No 66 -Date Started 29 1f!>'5 Date Completed 1"0 2 0o tc, Drilled By Logged By Rig , (6-5] subsurface stratigraphy .1 \1 Flight Auger H.S. Auger_ Size __ :.....-. From 0.0 \b .0 To -4,\j Size __ _ Rotal)' __ _ Size __ _ '?D .. D Botfom of Boring _, .. ____ =--£)-"-___________ _ sample data Depth J3D 5D \0.0 -'S.D B,O-2DD ;e.D.-S Depth M.S sample) CS (continuous sample) ARS (air rotary sam>>le) SS (split spoon sample) ST (shelby tube sample) NQ2 (wireline rock coring) water levels '" . --.... . __ .. ".--_ .. -. While Drilling ___ _ o Hours A.B. ____ _ Hours AB. __ .. well details Stick-up Cover .. _._ Flush Mount Cover .... __ . aquadrill i I I i l ( t p.2 3b 1u ub 02:41p field .boring log Job No .4OO _-ojectName o DAGIC @1- PAtoo =oeD7 Boring No -7Date Started 'i 'I~Date Completed i~~/)7X~Bvled~ Logged By Rig ?I7021 subsurface stratigraphy Flight Auger .4-" H.S. Auger Size .Size Rotary Size __ .water levels While Drilling J.0 Hours A.B.Hours A.B...From_0.0 TO ,,)5 Description.wr7c~well details Stick-up Cover.- -Flush Mount Cover -.......grade Bottom oF Borin.q sample data Depth 60- 2D.0Z UOS -2 6.o 36o.- 40-2 qu o- 4-, 0o ND lVAf!E(h Number/Type Depth A-50 4-S8,0 NumberiType .. S (auger sample) CS (continuous sample) ARS (air rotary sample)SS (split spoon sample) ST (shelby tube sample) NQ2 (wireline rock codng)oquadri IID 3b 10.06 02:41p , fierd .boring fog *oject Name . VA r£C @ PAt. 0 J$ Boring No.. S B -7 Date Started \ 4' ( "200 f::; .----, ,.-"71+ Date Completed irt-N b:' C 7Vik. Drilled By Logged By S1ft: V t. Rig (3*:.57 0 (l,V ! subsurface stratigrflphy H.S. Auger_ . Size ... __ _ From O.D t7"5 'S.S-Size __ _ Rotary __ Siz* ____ . Boltom of Boring _. ____ __________ _ sample data. Number/Type '-As 2-115 -Ai7 Depth.. A-5JJ (0 -f-.\ S .* S {auger sample) CS (continuous sample) ARS (air rotary sample) S8 (split spoon sample) ST (shelby tube sample) NQ2 (wireline rock coling) wate-r levels " ... ---... --_ .. __ .--.-+/- While Drilling _ ... ..lQ .. Q_. __ o Hours A.B. ______ .. Hours A.B .. 00. __ _ well details Stick-up Cover .* __ FlUSh Mount Cover ..... _ .. 00. grade -NO \/JlElL oquodrill Attachment 2 Maps Used to Determine Groundwater Flow Direction.DAEC Ground Water Protection Initiative: Site Conceptual Model Attachments Attachment 2 Maps Used to Determine Groundwater Flow Direction. DAEC Ground Water Protection Initiative: Site Conceptual Model Attachments I -_ KM xk y' /Mir 9~f W0 Pn*ttý1>~-/ ~s r-1.~ li M w 41 %c= --M. m; V Ar ark_j L... .. .. ..... .. ..Q9 rw 035 V, ~ _7 17, 1.11 L L____ 4~N>E~MO--p- 44i-N L ~ --- M 0 15 1&/ý"2~ TJ%~~ K.. L.!` r " "_____~ ~ ~ ~ A 461 & f)' 'iS~lb i~MWO5 n%\)y\%z; -2e -I'\ y!I' ye wi,2 Alc W+4r F I~2 --~a a- \% L4 mg2 jw/r/ w7 CIO'rR Lo 21r i'1~-~~~~~ W' 05 23Y ~fC-/?9 c -~z c ,Z go Ii -d I 94_ S_ ?fI-t.z, qssI4a~-171 47 P -t1T R AF~.W #k <W03,~I 4x"Jil Jj'f IlaeI 2 P/2cc?-j(cco Q&JIL.t f' I. ,I f " C;/2&!;:oor IY { b * .r .. 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'I,_ :,... WO't,mi' 73<-f* ( r J I Ns.-I j* ,kj 1!MWO 3>re25A p 4 C ý -- Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D.8 Bechtel Corporation Letter, R.W. Cote, Supervising Startup Engineer, toG.G. Hunt, Chief Engineer, Iowa Electric Light & Power Company, "Duane Arnold Energy Center Unit #1, Results of Well Water Drawdown Test" dated December 14, 1972.Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641

0.8 Bechtel

Corporation Letter, R.W. Cote, Supervising Startup Engineer, to G.G. Hunt, Chief Engineer, Iowa Electric Light & Power Company, "Duane Arnold Energy Center Unit #1, Results of Well Water Drawdown Test" dated December 14, 1972. vi Bechtel Corporation Engineers-Construclors Fifty Beale Street San Francisco, California 94119 Pl/aW reply o. lag: 369 P. 0. Box 209, Palo, Iowa 52324 File: SUS #8 14 December 1972 Mr. G. G. Hunt Chief Engineer Iowa Electric Light & Power CompanyP. 0. Box 351 Cedar Rapids, Iowa-52406 .Jýsg-k

Subject:

Iowa Electric Light & Power Company Job 7884 Duane Arnold Energy Center Unit #1 Results of Well Water Drawdown Test

Dear Mr. Hunt:

Presented are the results of the well water drawdown test conducted 19 November 1972.

SUMMARY

Approximately 204,000 gallons of water were pumped from well No. 1 in 4-1/2 hours and 153,000 gallons from well No. 2 in-3-3/4 hours.Flow rate from well.No. 1 was 730 GPM at a discharge pressure of 140 psig; well No. 2 flow was 650 GPM at a discharge pressure of 145-148 psig.Drawdown measurements for the production wells and observation wells D-1, P-I 'and OW-SA were taken at approximately one hour intervals.The drawdown and flow rate data verses elapsed time are shown on enclosure 7.DISCUSSION Test operations were witnessed by Iowa Electric Light & Power Company personnel and Mr. James Sampson of Howard Green Engineering Company.Water from well No. 1 and 2 was pumped through the fire main system to the pumphouse circulating water system pit. Flow measurements were taken at each pump discharge line and at the pumphouse firewater flow orifice FE-3300. The sum flow of wells 1 and 2 was within 6% of the indicated flow in the punphouse. For example, at steady state flow, the pumphouse orifice FE-3300 indicated 1300 GPM flow; corresponding flow from wells 1 and 2 was 730 GPM and 650 GPM respectively; a total flow of 1380 OPM., SANDFORD FRINK %0G. HUNT WALLACE NOSSARDI VECHTEL ROOT VKULLANoER I.E. SITE HEROLD WARD COOK ZUHNRECEIVED DEC 15 1972 I. E L P. Co.ENGR. DEPT.b"hi.PPPF1 V;Mr. G. G. Hunt Chief Engineer Iowa Electri<<;: Light & Power Company P. O. Bolt 351' Cedar RapidS, Iowa'52406' Bechtel Corporation Engineers-Constructors Fifty Beale Street San Francisco, California 94119 P/6/J$I1 reply rot LoS: 369 P. o. 80)( 209, Palo, Iowa 52324 File: SUS fi8 14 December 1972 Sub-ject: Iowa Electric Light & Power Company Job 7884 DUane Arnold Energy Center Unit #1 Results of Well Water Drawdown Test

Dear Mr. Hunt:

are the results of the well water drawdown test conducted 19"November 1972.

SUMMARY

Approximately 204,000 gallons of water were pumped from well No. 1 in 4-1/2 hours and 153.000 gallons from well No. 2 in-3-3/4 hoUrs. Flow rate from well. No. 1 was 730 GPM at a diseharge pressure of 140 psig; well No. 2 flow was 650 GPM at a discharge pressure of 145-148 psig. Drawdown measurements for the production wells and observation wells D-1, P-10 'and OW-SA were taken at approximately one hour intervals. The drawdown and flow rate verses elapsed time are shown on enclosure

7. ' DIS CUSS I-Pl:! Test operations were witnessed by Iowa Electric Light & Power Company personnel and Mr. James Sampson of Howard Green Engineering Company. Water from well No. 1 and 2 was pUl'llped through the fire main system to the pumphouse circulating water system pit. Flow measurements were taken at each p,ump discharge line ,and at the pumphouse firewater flow orifice FE-3300. The sum flow of wells 1 and 2 was Wi thin 6% of the indicated flow in the pumphouse.

For example, at steady state flow, the pumphouse orifice FE-3300 indicated 1300 GPM flow; corresponding flow from wells I and 2 was 730 GPoM and 650 GPM respectively; a total flow of 1380 GPM ** , , SANDFORD FRINK HUNT

• WALLACe: NOSSARDI
• ROOT ,. KUL.L.ANDEA
• HEROl.D WARD COOK ZUHN

Subject:

Iowa Electric Light & Power Company Job 7884 Duane Arnold Energy Center Unit #1 Results of Well Water Drawdown Test Page 2 Shown in enclosure I is the test procedure and -tabulated test data.Enclosure 2 presents the drawdown and flow rate data versus time.Water samples were taken from production wells.:1 and 2 at. approximately 1400 hours on November 19, 1972. The analysis results of these samples is shown in enclosure 3.Shown on enclosure 4 are the operating points of wells 1 and 2 relative to the pumping characteristic curves. The discharge pressure gages are presently located downstream of the flow measuring orifices. Assuming no. pressure recovery downstream of the orifices; the calculated total pump :discharge head-forvell 1-and 2 is 376.8 feet and 383.4 feet respectively. These% valves correspond to flows of 730 GPM :and 650 GPM from wells 14nd 2 respectively. Well No. 1 had been in continuous operation prior to the drawdown test at a discharge flow of 525 GPM and continued to operate following the test, at a discharge flow of 480 GPE.Yours very truly, BEHTEL CORP TON.R. W. Cote Supervising Startup Engineer RWC :JPM/ks Attachments CC, V. E- Balodis, w/attach.S. W. Cott, v/attach.0. L. Fouts, w/attach.X. V. Harrington, w/ attach.0. A. Nossardi, w/attach.L. D. Root, w/attach..-

Subject:

Iowa Electric Light & Power Compauy Job 7884 Duane Arnold Energy Center Unit 11 Results of Well Water Drawdown Test Page 2 Shown in enclosure 1 is the test procedure and *tabulated test data. Enclosure 2 presents the drawdown and flow rate data versus time. t.later samples were taken from production wells.1 and 2 at. approximately 1400 hours on November 19, 1912. !he analysis results* of these . samples is shown in enelosure

3. Shown on 4 are the operating points of wells 1 arid 2 relative to the pumping characteristic curves. The discharge gages are presently located downstreamo£ the £low Assuming no. pressure recoyery downstream of . the orifices; the calculated total pump ,discharge head-for"* well ;1 .. '-:: and 2 .is 376.8 feet and 383.4 feet

'lllese. valves .. , :>. correspond* to flows of 730 GPMand 650 GPM from. wells 1 . and 2 .. --. respectively. . . .. -. Well No. 1 had been in continuous operation prior to the drawdown test at a discharge flow of 525 GPM: andcont1nued to operate following the test, at a discharge flow of 480 GPM. . Yours very truly, R. W. Cc>te aWC:JPM/ks Attachments ec: v. E.-Baloci1s. w/attach. S. H. Cott. w/attach. G. L. Fouts, w/attach. K. V. Harrington, wI attach. O. A. NOssardi, w/attach. L. D. Root,

• . ....*.. ----._"-----

StartUp Engineer . "'. &NCLL&LE I Pex 3 VF7 Sheet No.'WELL PRODUCTION TEST DATA SHEET"Job 7&S4 Location WE LL-!t I Diameter of Well.. Depth of .Well:_, A! PROSE. USEO Static W. L.DateTes.ted I?.fg-7z.__Tested fm#/fl_Purip Usedmav tAIEL#IPrP -Dr'iver___* _ *Col. &Shaft-Bowls___________________ Migr., II Orifice Size-,4"4 TIME ORIFICE-.: GPM PUMPING. STATIC DRAW- '401SREMARKS "" READING .LEVEL L W.. DO.WN I -o2 i .1 P S/s 1SS mz.s .r o- f... 7 f.t or ST.r~ 6Fs~ nn-.01/5 24OS/ 52S 42?.8W~ Ti 1_05_6__N// _ _S 1r- 0 X' ' -....._____. 48 -. oo 8L0o .1. *__ /5o"r)

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PUMP PT7"Vf T M0 W 7 m FE!UW!MWo*Af 11AM MR ro~ , oO, rig .a ***.1fa T.m ., Wpm M AL*7 i..VU AP CYGE ° .E-.... ........-----.....-. -. ENrLOSU£E I PU:E 3 OF7 Sheet No. ---WELL PRODUCTION TEST DATA SHEET ,' . .Tob* iSi4 Tes.ted ,,;'r9*7Z " . . .... . , Location WELL -:it , by,fAmPJON I m,/fIJI£WJ .. ' ; Diameter of Well ______ _ Pump Used WEll'll{ PlJmp , , Depth. of *:WeilL.,: ____ __ MoiS1VRE PROBE, USED ': ' ____ '. 1 ... _'_.' _. ____ . +"_' ...;... ___ ---:_ , '-.. Col * .-&. ____ * '_' --. a ** * . " Static \V" L. _--:-____ ._'_0:-- 4*436,'* gOl£ ___ ' _. _. __ " .-.;... __ ' ._. :_ *. _-... , , TIME ORIFICE': ' ,GPM PUMPING, STATIC* DRAW-.* ,"-' :: READING .. LEVEL W.L. Do.WN OBio . *Z*OPSIO S25 fT' ': O* . f.eA71#1it ' .. . ' .,: . '. r. 5TIIK, OF 1 £s'T* .:;, tJ915 'liO 525 . , lk T( ) iJifJfl "11*8 O* ; .. . . . " .6.,; . 4f3 . , 8Gn. l!JiO, . 181.: 15Ii;** .. .. ' .. :jJ:SO.' 4.(J .. 140.,". S1*'O . ,4*a : ,.,0 81J111 U ,(US,POIIP* '. . J3:0S' . .. .. '3-.,9.-730 sa .. I ... .,." . Pt3 ,!I{r;,. ': . , . , , . .., -. -, . .. -V 4 (J 14{){) ,3*9 730 /.'J.. .. . " . :-. . . -." .. ,lsi.o : 3*!t . : 130 GO,,} -, 0*8" '.-: -. . .. ' . ... " , -1554 ' -, f FlOW FllJ:; 3.9.' . 730 lIit} H.rlJl£l iJli. .. , io'DS 1,.7, " 480: ' " , " .. ,-l!JJfj 71JlJf'1J ¥iRJiT£ tu lTJI r.riL* .. pump 70'0 :ro*1J1. liEN. .' '. . ,. , -. . -.. . . , , -," " -, . .. " . . . . '* m£AJ{)1l. wo Ffl{)fJ1 pump BAlE . , ** !ENT PE,RIOD i SlVllLlI{J/6 PI< QmDJfIIL 6EN . .f0lJl.1. V& . TOP t, IJfJ. -:_'E-DOIJ8Z lJL, ,ll.¥ 70 IFIIVuY'-tiME. P£ ')BUM. {OtC, "au tIJ: FlMf 0AT.A. . .. '

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.... - ,--.' .' ... ...... PNtiE'J OF Sheet NoD...-*WELL PRODUCTION TEST DATA SHEET Job ____4.Date Tested li q-ia-.* Locationf WfLLV2 Diameter of Well_ _ _.Depth of W-eI l* AIJW~tPRO& EDUt Static W.. L.Orifice Size A-436' i -Tested by_ SjM8fiPSO W/d..fOA, Pump Used WELZ PLJP.Driver C,.. -Shaf 7TIME; ORIFICE-.: -GPM PUMPING.. STATIC DRAW- jMSCH REMARKS READING LEVEL W.L. DOWN I -6 7 7 1145-. i3.3 .-37 '{ .I¢I PO31 P5T5.,4T8__ _ _ _ _ .S"__ _ _ _____7 __ _ __(8 .... __"1245 > 3. 1"65S ""___ 5*j If .... .__" 1S40' 3- 50 -Se6s -_2 -, I. --." ...* s .-.. V. M ON. .E.--._._._ .. , 1 _ _ _ __,_ _ _ _ _ _ :: I _ _: _ _z ..- * -_ _,ow__

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• f* Col * .-&. Sh:dt:.-'*

______ _., -.. .. Bowls ____ !:. '.' ., ... ' ,',-. Mfgr. ___________ , TIME ORIFICE -: .. GPM READING* ' PUMPING.. STATIC . DRAW -IlJSCJl/RE:MARKS ' , .' LEVEL W. L. 'DOWN .. " '()B3S p , , " " .. , .. ,' ',.' .. -, ,.' .i-.:, rl* '//45 " '37,'7, " puli);.* 11/8 .' . : "'. . ,._-' .. ' . , 1245', : d*/ '" -:.' .. ** ". t .... . 3*1, " .. ' .165*s.-: . , IfB ' . Isocr: .. **' :. 3.p :. . . list) 5/;*.0' , 1{5 "i540 3*0 . '. > II.,s ** " " " e"* ,. . . : -

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Sheet No._'WELL PRODUCTION TEST DATA SHEET* , .S;,ARFlFVATIBA WEI t Dl-1*Date Tested-II- 1Q-~I7~<,,,,r ....Te~sted ..by W1 Ll AL Diamneter Denth of of wen Pum nlp Used-L~elgth~.of. Airlinn'Static W. Ls." Col- '& Shaft Bowls Orifice Size IvMfgr.STIME oRWICE.K GPM PUMPING. STATIC DRAW- SC EMZ RlS READING .LEVEL W. L. PD. ._m .!" OSSS _____14.F ___ _LZIN Nb OUN11 130 -. 2692S .L.: 2...U.-. IP.iiiii * -m. .. .29 I 4 S _ IUTI) N 2 z7- S .- -ss____I-...°..._ -._,- --"m_4SS _I'__.--,-) E .ic F °.n ."~ o .1 S ..' ..-___

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'. .. . . :. Static W. L. _-----:-_________ _ ',-* * :. * * ". ..'! Bowls_"*_* _____ ____ .. * " .. . '. Orifice 5ize _._.....;... __ -.:. ___ ...;...._ .' .. . .. ' ... .. ":"'" : .. M£gr. ____________ ..;.._ . -...... . , TIME ORiFicE ':". CiPM READING PUMPING, LEVEL . STATIC

• w. -. , DtjSO " .. 1 .

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• • __ ,-:_. a..>

.... (' .. . _." -.... ': , ,. , . 'WELL PRODUCTION

• T MUMM~~A~tVINIA.

WF1f td P-1fl Diameter of Well Depth of,Len qgth of , Static W.Airline__'_______________ L.l Orifice SizeIJ m I I I I I ,I TIME ORIFICE..GPM PUMPI READING ... LEYE oq3s < __j:S -_ _---:.1.445... ._ _ _ ..,.,.-__znn 4--_ , -I u_ ,,m:gLrmfME I4F~OR4 tit F TAEL_ _ _ _ _ _ _ _ __ " I _ _ _"_ _.*,-., PAU~ 6 0F 7 Sheet No.TEST DATA SHEET Date Tcsted il-iqn.Tested by " " Pump Used'ailne n Col. &f shaft___________,Bowls IG_ STATIC DRAW- IMSCO !MARIC W. L. DO-WN o *-__.35.D .. * ......-- -.. ' " *°ITO~~~~ [-ý UMA--T .. .,* .. ..,: .,L , .SHU-DOWN____ ATM 1% 5Noff..;- -if __- -_ _ _II-, 4 * .t: ..-.. , ..." ENatlJU£EI b fJF7 Sheet No. --'WELL PRODUCTION TEST DATA SHEET ... :'. _________ _ lI-;Q-ll. ' . ' . .' '. Tested by: W'UOU . :". .' . Diar.neter of Well ______ _ Pump ___ ... _ " .- ____ ....... -_ '. .. . .... Depth of .Yf.el ..... l* _________ ,;.-. . " " .... ',' " _ . . . .-:.:

.

.*Shaft':-*

______ _---:--.. -'-'-. ....,. ... ' .. . ',' :.;t Bowls __

• ______

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RAW~ 7 OF 7 (Sheet No.WELL PRODUCTION TEST DATA SHEET*Job -73&4*Locantion OW -SA Diameter of Well Depth- of ,W-I Length.of Airline____-_'_...... Static W. IL.Orifice Size Date Testedj -!Tested by WILSON Pump Used -Driver" Co. .Shat 41 -_ _Mfu-wj TIME ORIFICE GPM PUMPING, STATIC DRAW- WIRM P.EMARKI READING LEVEL W: L. DOWN 'PFM A ; :w Ol 1 12-5__ _ __ I_ __ _l i,_*_.l.: i z o0 _ _ _ _ -.Is*o ..~ -.. -1300. ..57. _-.___ _ _tSO- -. ,-InIS. __....f~ _ _ __ _-1 o -o.IsisI ,. -* -. -._. . ENaaur.e , fAGe 70F7 Sheet No. --WELL PRODUCTION TEST DATA SHEET Job' ,884 Diameter of Well _______ _ of.*Y/:e.i,'1.. ________ _ " . Static W. __ ----__ Orifice Size __ ..;...-__ Date Tea,ted. n -., -lZ, Tested by' W'lSO .... Pump Used_-___ ...... _-. _____ .. Col. &: Shaft:...- _____ --:. __ Bow15 _______ , Mtgr. __________ -.... ______ _ TIME 'ORIFICE: GPM READING PUMl'lNG, ST",TIC LEVEL L. '2*5 , "'lIl0 , 15*0 : .... , IZOO " 1300, 1,5-i, ISIS ,11* I , 'U;OS , , , ' , .. . ": zo -50 L) v mAV ))tJt IULN 111 Ul,-'LTS&- ---* * *o-~WATEE LEVEL WLIL# I-M WE1 LEVEL WELL'2..*-WATER LEVEL -I E*1 WATEE ffVEL P-If-r.4.i410z 00 0 ..-WATER LEVEL OW-SA 800 -MOUwf ~OTAI P:rl (T" Ft=~LW WEUAI1 i cFLOWR WELL41Z..I -LU No& -Soo-400 I.I 1.I.I I I N 1b0 too-I i Ii I U.OPM PICO iDO0 1300 OF DAY.~14DOL Isoo"I", 11-1_1 ........... ..Z 0 ',(t-_ ___ IJ I, U'J HOW IJ 1:'1:'.\ j ---+:-$. . ** t:J,.S ....... " .. -.J . ...... i\O . ---** ----. !.u . * " ,,' ! 0---0&----4> " ... m ...... 1;\ **** 1!l' . :.... *** * .I!l" * ; .: SO' ..... . c:c6 . ; f.O , >q;z U,.) :': ' . 10 .' .. WAlf£ LEVa WtlL"#,1 *. ,' .'--tc. WilER. LElIEL WELLll '2... II--WAnR IPI£L 0 .. 1 a**.a l£VEL P_',t.1 e i' Q a e -c ...... WMfR LEVEL OW-SA 800 . '. . .;i: 'If.{) S* \.L: 3l1() lJJO I I I I . ;'. ". . I G-4' FlClW WElL lJ I II--If FLOW WfLl#Z-r

• __ +-__ +-__ __

__ __ ______ __ . . OW Q100 .". ", \000 uoo rzoo gOO .'. 1400 T\W\E Or: lSOD Iboo .... --_*********1 .. **** .... -..... -.-.. , ....... -.. -.,-.-." .. ,--... ,., .. , .... .. ..*. . ......... , ,,","-.' ,,-.. ... .. ; .. ....... ....... -..... "., ..*.. " .w',* *. , .... , ... * ....... *.*, .*..* ***** ***. ** ........ * ..... * .... * ..... ** .. 1 ........... * ... *'w* ........ *.*******.**** ......... " ............................................. !, .... , ............... "........................... .. ....... " .. -" ................................. _.......... . ........ .............................................. . ................................... . Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D.9 Northway Well and Pump Co. data sheets from aquifer test performed November 13, 2001 at Well A.Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0S41

0.9 Northway

Well and Pump Co. data sheets from aquifer test performed November 13, 2001 at Well A. .,Northway Well and Pump Co.4895 8th Avenue I I Marion, Iowa 5230 'NDX, ITEM .Q.p- -1.I UOR Duane Arnold Energy Center LOCATEI.') AT Palo, Iowa"1 I:.MI'.Well A STATIC DATE 11-13-01 TIME 9: 20 PlUMP WATER SEITING LEVEL 248' 78'1PUMPING GALLONS LEVEL PER MIN.80' 750 D)ISCHIARGE DU~SCRIII'ION 9: 30 9:35 9:45 10:00 10:15 81'82'83'84'85.5'930 930 930. __930 930 10:30 86' 930_ 10 :_4_5 86'9 _930 ...232. 5gpf SAND I.I.M.VOI.UMEi 11:00-11:15 87'5 88'3 930 930 11:30 88'6 930 11:45 89' 930 12:00pm 12: 30 I: 00 89'7 90'3 91 '2 930.93Q0 930.1: 30 91 8.1 I 1 2: 00 2: 30 92' 5 91 '2 750 ---. -...~j.j. .I ---.------- i t I F- -(Phone 319-377-6339 1-800-747-6339 FAX 319-377-81,18 .... , . ( { '. . I . ( *Northway Well and Pump Co. , 4895 8th Avenue Marion Iowa 52302 INDEX ITEM :], 10 , . PI "'Llll ..==-1 FOR Duane Arnold Energy Center LOCATED AT Palo, Iowa ----------

---

.-.....

...... -......... -... --Well A DATE TIME 11-13-01 STATIC I'UMI' WATER I'UMPING GALLONS SETI'ING LEVEL LEVEL PElt t-.IIN. ., EMP. DISCHARGE VESCHII'TION SAN() P.I'.M. VOI.Uf\IE 9:20 248' 78' 80' 750 ---.----.. ----. -----.--9:30 81' 930 -------------f*---I----

---

.-.-------.---

.. -. -"-'-.. -.-. --.-. 9:35 _________ 8_2_' __ .. _ .. __ ... ____ 2.lQ ..... _____ .... ____ ._. __ .. _._. ___ . __ 930 ---1-------....... ' .-.... -....... -._.-....... . 10:00 84' --._--------1--- 10:15 85.5' 930 ---------1---*-f----II----I-----*-- -.... --.-----.-.-- -'" "-"-'-'--.---_--1 10: 30 86' _______ . ___ -,-__ ... _ .. _ .... _ ... _ ... 10:45 86'9 930 ---- -....... --.. -----......... -. ______ _. ________ 1-8_7-' 5 __ ___ .. ____ :._1_5 -l. ____ I-___ .. ---.-._..:_ .. ___ .... _. ____ . 11:30 88'6 930 ---*--I------I----I----t------*-* .. --.--.------ -.. -.... '-' ... -.. --.. -11:45 89' 930 -----t--------I-----f-----f----*f--=:...;:...;.-----

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• U ..,' rR%,b Marion, lo1 FOR Duane Arnold Energy Center STATIC PUMP WATER SUE'ITNG LEVEL wa~13U INDEX ITEM T1 LOCATED AT Palo, Iowa TE~MP."ING GALLONS DISCIIARGE SAND I.I.M.EL PER MIN. DESCRIPTION VOLUME DATE TIME RECOVERY PIUMI LEV.11-13-01 4:03 88' 8 4 -I 4-4:05 88'4:07 87'8 4-. I- --I I 4:09 87'6---4----------4 I + F 4:11 4:15 87'86'9 4:20 86'4 4 4:25 86'3 .... ...4:30 86'2 4:45 85'7 5:00 85'5 5:15 85'2 5:30 84'7-..- # --- ---- ---5:45 6:00 84'5 84'4--, t r-_________

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....... ___ -L.. ___ ___ _L.., __ ... -------....... -----... -. Phone 1-800-747-6339 Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D.10 NMC 2004, Storm Water Pollution Prevention Plan (SWPPP). Nuclear Management Company, Duane Arnold Energy Center, Revision 5.3, December.Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 0.10 NMC 2004, Storm Water Pollution Prevention Plan (SWPPP). Nuclear Management Company, Duane Arnold Energy Center, Revision 5.3, December.

Revision No. 5.3 STORM WATER POLLUTION PREVENTION PLAN (SWPPP)NUCLEAR MANAGEMENT COMPANY DUANE ARNOLD ENERGY CENTER Revision No. 5.3 Prepared By: 0 Jei d MH --S enio Evironmental Analyst Reviewed By: e /t K thee Furm --Facilities Supervisor Reviewed 6Snhld Chur p-- py ham Manager Reviewed By: avi@Reviewed By: David Olsen--Chemistry General Supervisor Date:/4 2Q/- OLf Date: 64-Date:/ Date: !Date: I?-21-Y-I[Swppp5 -3. doc]Page 1 Revision No. 5.3 STORM WATER POLLUTION PREVENTION PLAN (SWPPP) NUCLEAR MANAGEMENT COMPANY DUANE ARNOLD ENERGY CENTER Revision No.5. 3 Prepared By: _-j1f--'-__ Date:! :z ;t 1-0 Lf Date: Reviewed By: ___ _ Date: 1:2. -,;? 2: of Reviewed By: 'Date:) d/ , Sehwertfeger-S eu ity Supervisor Reviewed By: -DaViOiSel1=Chemistry General Supervisor Date: /2-2/-d-/ [Swppp5 -3. doc] Page 1 Revision No. 5.3 TABLE OF CONTENTS HEADINGS INTRODUCTION PAGE 3 SECTION AORGANIZATION, PLANNING AND RECORDKEEPING

1.0 STORM

WATER POLLUTION PREVENTION TEAM 2.0 COORDINATION WITH OTHER PROCEDURES, RECORDS AND PLANS 3.0 PLAN REVIEW AND REVISION REQUIREMENTS4.0 SPILL AND MAINTENANCE RECORDS

5.0 RECORD

KEEPING 4 5 5 6 6 SECTION B ASSESSMENT OF POTENTIAL POLLUTION SOURCES 1.0 2.0 3.0 4.0 5.0 FACILITY SITE PLANS SITE ASSESSMENT FINDINGS SIGNIFICANT MATERIALS ON-SITE SITE DRAINAGE PATTERNS AND OUTFALL DESCRIPTIONS NON-STORM WATER DISCHARGE ASSESSMENT & CERTIFICATION 7 7 8 9-11 11-12 SECTION CBEST MANAGEMENT PRACTICES (BMPs)1.0 POLLUTANT SOURCE IDENTIFICATION AND BMPs 2.0 REVIEWS AND SELECTIONS OF CURRENT BMPs 3.0 SPILL RESPONSE AND REPORTING 4.0 INSPECTIONS

5.0 STORM

WATER MONITORING REQUIREMENTS

6.0 EMPLOYEE

TRAINING PROGRAM ATTACHMENTS ATTACHMENT 1 -INVENTORY OF POTENTIALLY EXPOSED MATERIALS ATTACHMENT 2 -REPORTABLE QUANTITY RELEASE REPORT 13-19 19 20 21 22 22 23 25[Swppp5-.3. doc]Page 2 Revision No. 5.3 TABLE OF CONTENTS HEADINGS PAGE INTRODUCTION 3 SECTION A ORGANIZATION, PLANNING AND RECORDKEEPING

1.0 STORM

WATER POLLUTION PREVENTION TEAM 4 2.0 COORDINATION WITH OTHER PROCEDURES, RECORDS AND PLANS 5 3.0 PLAN REVIEW AND REVISION REQUIREMENTS 5 4.0 SPILL AND MAINTENANCE RECORDS 6 5.0 RECORD KEEPING 6 SECTION B ASSESSMENT OF POTENTIAL POLLUTION SOURCES 1.0 FACILITY SITE PLANS 7 2.0 SITE ASSESSMENT FINDINGS 7 3.0 SIGNIFICANT MATERIALS ON-SITE 8 4.0 SITE DRAINAGE PATTERNS AND OUTFALL DESCRIPTIONS 9-11 5.0 NON-STORM WATER DISCHARGE ASSESSMENT & CERTIFICATION 11-12 SECTION C BEST MANAGEMENT PRACTICES (BMPs) 1.0 POLLUTANT SOURCE IDENTIFICATION AND BMPs 2.0 REVIEWS AND SELECTIONS OF CURRENT BMPs 3.0 SPILL RESPONSE AND REPORTING

4.0 INSPECTIONS

5.0 STORM

WATER MONITORING REQUIREMENTS

6.0 EMPLOYEE

TRAINING PROGRAM ATTACHMENTS 13-19 19 20 21 22 22 ATTACHMENT 1 -INVENTORY OF POTENTIALLY EXPOSED MATERIALS 23 ATTACHMENT 2 -REPORTABLE QUANTITY RELEASE REPORT 25 [SwpppS -3. doc] Page 2 Revision No.

5.3 INTRODUCTION

Facility: Duane Arnold Energy Center (DAEC)3277 DAEC Road Palo, Iowa Location: Section 9, T 84N, R 8W This facility is a Nuclear Power Steam Electric Generating Station This facility maintains an Iowa Department of Natural Resources (IDNR)Permit # 5700104 for Storm Water Discharge Requirements. This Storm Water Pollution Prevention Plan (SWPPP) has been prepared in accordance with good engineering practices consistent with the requirements of 40 CFR Part 122 and Iowa Administrative Code (IAC) 567-64. This plan identifies potential sources of pollution that may reasonably be expected to affect the quality of storm water discharges associated with industrial activity from this facility. In the storm water regulations, the United States Environmental Protection Agency (EPA) encourages the development and implementation of SWPPP that are designed to reduce (or eliminate) storm water pollution at its source in order to mitigate (or prevent entirely) potential adverse environmental impacts on receiving streams.Implementation of the DAEC SWPPP assures compliance with the terms and conditions of the IDNR National Pollution Discharge Elimination System (NPDES) Permit for "Storm Water Discharge Requirements". This plan describes and ensures the implementation of practices, which will be used to reduce pollutants in storm water discharges associated with industrial activities at the DAEC. A condition of the IDNR NPDES Permit is that the provisions of this SWPPP must be implemented. Any NPDES permit noncompliance constitutes a violations of the Clean Water Act and is grounds for enforcement action: permit termination, revocation and reissuance, modification, or denial of a permit renewal.The DAEC is not subjected to the NPDES additional requirements for storm water discharges associated with industrial activity from facilities subject to SARA Title III Section 313 Requirements. Because the DAEC is a Nuclear Power Steam Electric Generating Station and does not use oil or coal for the purpose of generating power for distribution in commerce istherefore exempt from the SARA Title I1 Section 313 Requirements. This exemption is referenced in 40 CFR 372.22.[Swppp5 -3.doc]Page 3 Revision No.

5.3 INTRODUCTION

Facility: Location: Duane Arnold Energy Center (DAEC) 3277 DAEC Road Palo, Iowa Section 9, T 84N, R 8W This facility is a Nuclear Power Steam Electric Generating Station This facility maintains an Iowa Department of Natural Resources (IDNR) Permit # 5700104 for Storm Water Discharge Requirements. This Storm Water Pollution Prevention Plan (SWPPP) has been prepared in accordance with good engineering practices consistent with the requirements of 40 CFR Part 122 and Iowa Administrative Code (lAC) 567-64. This plan identifies potential sources of pollution that may reasonably be expected to affect the quality of storm water discharges associated with industrial activity from this facility. In the storm water regulations, the United States Environmental Protection Agency (EPA) encourages the development and implementation of SWPPP that are designed to reduce (or eliminate) storm water pollution at its source in order to mitigate (or prevent entirely) potential adverse environmental impacts on receiving streams. Implementation of the DAEC SWPPP assures compliance with the terms and conditions of the IDNR National Pollution Discharge Elimination System (NPDES) Permit for "Storm Water Discharge Requirements". This plan describes and ensures the implementation of practices, which will be used to reduce pollutants in storm water discharges associated with industrial activities at the DAEC. A condition of the IDNR NPDES Permit is that the provisions of this SWPPP must be implemented. Any NPDES permit noncompliance constitutes a violations of the Clean Water Act and is grounds for enforcement action: permit termination, revocation and reissuance, modification, or denial of a permit renewal. The DAEC is not subjected to the NPDES additional requirements for storm water discharges associated with industrial activity from facilities subject to SARA Title ill Section 313 Requirements. Because the DAEC is a Nuclear Power Steam Electric Generating Station and does not use oil or coal for the purpose of generating power for distribution in commerce is therefore exempt from the SARA Title ill Section 313 Requirements. This exemption is referenced in 40 CFR 372.22. [SwpppS -3. doc] Page 3 Revision No. 5.3 SECTION A ORGANIZATION, PLANNING AND RECORDKEEPING

1.0 STORM

WATER POLLUTION PREVENTION TEAM 1) DAEC has established a Storm Water Pollution Prevention (SWPP) Team to assist in the development and implementation of the storm water pollutionprevention planning effort. The SWPP Team members will provide technical oversight and management for the storm water management program.2) The SWPP Team members are responsible for the following activities: a) Ensure all NPDES permit and SWPPP requirements are Implemented. Each team member shall be aware that the provisions Of the SWPPP must be implemented as a condition of the IDNR NPDES Permit compliance. b) Defining and establishing an appropriate set of objectives for the Facilities storm water management program. Also, to determine When the SWPPP needs to be revised to meet these objectives. c) Monitoring changes in plant operations or facilities, which mayrequire updates to the SWPPP.d) Maintaining a clear line of communication with plant personnel And management to ensure a cooperative partnership and effective Dissemination of information.

3) Members of the DAEC's SWPP Team will be available to assist DAEC personnel in resolving SWPPP concerns.a) Rosters will be posted at strategic locations at the DAEC so that Other plant personnel will be aware of contacts for concerns for SWPPP problems.b) The Rosters will be updated within 30 days after a change in Personnel or responsibility in the DAEC Organization, which will Effect the SWPPP.c) The SWPP Team will also periodically provide SWPPP information to plant personnel.

This is to ensure that all personnel (at all levels Of responsibility) are aware of the SWPPP and compliance with NPDES Storm Water Discharge Requirements. [Swppp5-3. doc]Page 4 Revision No. 5.3 SECTION A ORGANIZATION, PLANNING AND RECORDKEEPING

1.0 STORM

WATER POLLUTION PREVENTION TEAM [Swppp5 -3. doc] 1) DAEC has established a Stonn Water Pollution Prevention (SWPP) Team to assist in the development and implementation of the stonn water pollution prevention planning effort. The SWPP Team members will provide technical oversight and management for the stonnwater management program. 2) The SWPP Team members are responsible for the following activities: a) Ensure all NPDES pennit and SWPPP requirements are hnplemented. Each team member shall be aware that the provisions Of the SWPPP must be implemented as a condition of the IDNR NPDES Pennit compliance. b) Defining and establishing an appropriate set of obj ectives for the Facilities stonn water management program. Also, to detennine When the SWPPP needs to be revised to meet these objectives. c) Monitoring changes in plant operations or facilities, which may require updates to the SWPPP. d) Maintaining a clear line of communication with plant personnel And management to ensure a cooperative partnership and effective Dissemination of infonnation.

3) Members of the DAEC's SWPP Team will be available to assist DAEC personnel in resolving SWPPP concerns.

a) Rosters will be posted at strategic locations at the DAEC so that Other plant personnel will be aware of contacts for concerns for SWPPP problems. b) The Rosters will be updated within 30 days after a change in Personnel or responsibility in the DAEC Organization, which will Effect the SWPPP. c) The SWPP Team will also periodically provide SWPPP infonnation to plant personnel. This is to ensure that all personnel (at all levels Of responsibility) are aware of the SWPPP and compliance with NPDES Stonn Water Discharge Requirements. Page 4 Revision No. 5.3 2.0 COORDINATION WITH OTHER PROCEDURES, REPORTS AND PLANS 1) The primary overlap is with the DAEC Spill Prevention Control and Countermeasures (SPCC) Plan that is required under 40 CFR Part 112. The goals of the SPCC Plan are to prevent and control the discharges of oil to Receiving waters (i.e., Cedar River).

2) DAEC's SWPPP will complement and be interactive with other departmental (Radwaste, Chemistry, Maintenance, Operations...)

and Administrative Control Procedures (ACPs) that are already in place at the facility.3) The DAEC is required to have a RCRA contingency plan which describes spill prevention and proper handling of hazardous wastes generated at the facility.4) DAEC also performs SARA Tier II and EPCRA 311 reporting requirements which list the presence of all Hazardous and Extremely Hazardous Substances on site in excess of the Threshold Planning Quantity.3.0 PLAN REVIEW AND REVISION REQUIREMENTS

1) The SWPP Team will periodically review this plan. The SWPP Team members should maintain this plan to current status. An update will be designated as a 0.1 addition to the revision number (ex. 4.3 will follow the 4.2-update number). The SWPPP should be updated whenever: a) There is a change in operation, maintenance, construction, or design, which has a significant effect on the potential for the discharge of pollutants to waters of the state.b) This plan will be updated within 14 calendar days of the knowledge of a "Hazardous Condition" release event at the facility.2) Editorial corrections and updates to the SWPPP can be made by any SWPP Team member and does not constitute a revision to this plan. A revision will be designated as the next whole number addition to the revision number (ex. 5.0 will follow the 4.X revision number).

However, a revision to the SWPPP must be approved by a corporate officer for the following: a) If the IDNR or EPA identify items of the SWPPP that are not in accordance with NPDES Storm Water Discharge Requirements, the plan must be revised. Any necessary changes to the SWPPP[Swppp5-3. doc Page 5 Revision No. 5.3 2.0 COORDINATION WITH OTHER PROCEDURES, REPORTS AND PLANS 1) The primary overlap is with the DAEC Spill Prevention Control and Countermeasures (SPCC) Plan that is required under 40 CFR Part 112. The goals of the SPCC Plan are to prevent and control the discharges of oil to Receiving waters (i.e., Cedar River) . . 2) DAEC's SWPPP will complement and be interactive with other departmental (Radwaste, Chemistry, Maintenance, Operations ... ) and Administrative Control Procedures (ACPs) that are already in place at the facility.

3) The DAEC is required to have a RCRA contingency plan which describes spill prevention and proper handling of hazardous wastes generated at the facility.

4) DAEC also performs SARA Tier II and EPCRA 311 reporting requirements which list the presence of all Hazardous and Extremely Hazardous Substances on site in excess of the Threshold Planning Quantity.

3.0 PLAN REVIEW AND REVISION REQUIREMENTS [Swppp5 -3. doc] 1) The SWPP Team will periodically review this plan. The SWPP Team members should maintain this plan to current status. An update will be designated as a 0.1 addition to the revision number (ex. 4.3 will follow the 4.2-update number). The SWPPP should be updated whenever: a) There is a change in operation, maintenance, construction, or design, which has a significant effect on the potential for the discharge of pollutants to waters of the state. b) This plan will be updated within 14 calendar days of the knowledge of a "Hazardous Condition" release event at the facility.

2) Editorial corrections and updates to the SWPPP can be made by any SWPP Team member and does not constitute a revision to this plan. A revision will be designated as the next whole number addition to the revision number (ex. 5.0 will follow the 4.X revision number). However, a revision to the SWPPP must be approved by a corporate officer for the following:

a) If the IDNR or EPA identify items of the SWPPP that are not in accordance with NPDES Storm Water Discharge Requirements, the plan must be revised. Any necessary changes to the SWPPP Page 5 Revision No. 5.3 must be made within 30 days and IDNR must be provided with certification of the changes.b) A revision is required because the SWPP Team determines that the SWPPP proves to be ineffective in achieving the general objectives of controlling pollutants in storm water discharges. c) Any changes that the SWPP Team determines is a major modification to the original objectives, a change in commitment of resources, or basic operating philosophy to the SWPPP.4.0 SPILL AND MAINTENANCE RECORDS 1) All reportable spills (as defined in ACP 1411.14) and their corrective actions or maintenance records will be updated in the DAEC Chemical and Oil Spill Log Notebook. The Chemistry Department maintains this logbook.2) Good work practices and engineering controls, which are designed to reduce storm water runoff pollutants, are known as Best Management Practices (BMPs). These BMP's are identified and inspected quarterly during the storm water runoff examination form.5.0 RECORDKEEPING

1) Records are kept of all significant storm water pollution events (i.e., spills, failure of BMPs, etc.), in-house SWPPP visual examinations and follow-up responses, and any changes in SWPPP on-site activities.

These records are maintained on-site for a period of at least 3 years in the SWPPP and Inspection Log Notebooks.

2) A current up-to-date copy of the SWPPP, including all revisions and updates made within the last 3 years, shall be maintained on-site in theSWPPP Notebooks.

[Swppp5-3 .doc]Page 6 Revision No. 5.3 must be made within 30 days and IDNR must be provided with certification of the changes. b) A revision is required because the SWPP Team determines that the SWPPP proves to be ineffective in achieving the general objectives of controlling pollutants in storm water discharges. c) Any changes that the SWPP Team determines is a major modification to the original objectives, a change in commitment of resources, or basic operating philosophy to the SWPPP. 4.0 SPILL AND MAINTENANCE RECORDS 1) All reportable spills (as defined in ACP 1411.14) and their corrective actions or maintenance records will be updated in the DAEC Chemical and Oil Spill Log Notebook. The Chemistry Department maintains this logbook. 2) Good work practices and engineering controls, which are designed to reduce storm water runoff pollutants, are known as Best Management Practices (BMPs). These BMP's are identified and inspected quarterly during the storm water runoff examination form. 5.0 RECORDKEEPING [Swppp5 -3. doc] 1) Records are kept of all significant storm water pollution events (i.e., spills, failure ofBMPs, etc.), in-house SWPPP visual examinations and up responses, and any changes in SWPPP on-site activities. These records are maintained on-site for a period of at least 3 years in the SWPPP and Inspection Log Notebooks.

2) A current up-to-date copy of the SWPPP, including all revisions and updates made within the last 3 years, shall be maintained on-site in the SWPPP Notebooks.

Page 6 Revision No. 5.3 SECTION B ASSESSMENT OF POTENTIAL POLLUTION SOURCES 1.0 FACILITY SITE PLANS 1) A site map was developed in 1993 to meet the EPA's requirements. This map will be updated as necessary to meet the EPA's and NPDESrequirements. The map was updated in 1996 and 2004 to reflect changes in DAEC's facility plans.2) The Site map depicting various features of the DAEC facility is provided in Appendix B of the SWPPP Notebook. a) Locations of storm sewers, exposed materials, and high-risk areas are illustrated on the map.b) Best Management Practices (BMPs) that are employed to improve storm water management at the DAEC facility is illustrated on the Site map.c) This map is updated whenever site BMPs modifications occur or BMPs improvements are made at the DAEC facility. Refer to this map when reviewing narrative descriptions of storm water pollutant sources and recommended BMPs presented in the following sections of this plan.3) Site drainage features and outfall locations are shown on Bechtel drawing BECH-ClOl. 2.0 SITE ASSESSMENT FINDINGS 1) In February 1993, a site assessment was performed at the DAEC facility in order to collect information for the SWPPP efforts. Site assessment activities included: a) Determining the inventory of significant materials used or stored at the DAEC.b) Inspections of material storage/handling areas, outfalls, storm watercontrol structures, and other areas of concern.c) A review of plant operations relative to storm water management.

2) Photographs of key areas of interest are provided in the Inspection Photolog (Appendix C) in the SWPPP Notebook.[Swppp5-3

.doc]Page 7'/ Revision No. 5.3 SECTION B ASSESSMENT OF POTENTIAL POLLUTION SOURCES 1.0 FACILITY SITE PLANS 1) A site map was developed in 1993 to meet the EPA's requirements. This map will be updated as necessary to meet the EPA's and NPDES requirements. The map was updated in 1996 and 2004 to reflect changes in DAEC's facility plans. 2) The Site map depicting various features ofthe DAEC facility is provided in Appendix B ofthe SWPPP Notebook. a) Locations of storm sewers, exposed materials, and high-risk areas are illustrated on the map. b) Best Management Practices (BMPs) that are employed to improve storm water management at the DAEC facility is illustrated on the Site map. c) This map is updated whenever site BMPs modifications occur or BMPs improvements are made at the DAEC facility. Refer to this map when reviewing narrative descriptions of storm water pollutant sources and recommended BMPs presented in the following sections ofthis plan. 3) Site drainage features and outfall locations are shown on Bechtel drawing BECR-CIOl. 2.0 SITE ASSESSMENT FINDINGS [Swppp5 -3. doc] 1) In February 1993, a site assessment was performed at the DAEC facility in order to collect information for the SWPPP efforts. Site assessment activities included: a) Determining the inventory of significant materials used or stored at theDAEC. b) . Inspections of material storagelhandling areas, outfalls, storm water control structures, and other areas of concern. c) A review of plant operations relative to storm water management.

2) Photographs of key areas of interest are provided in the Inspection Photo log (Appendix C) in the SWPPP Notebook. . Page 7 Revision No. 5.3 3.0 SIGNIFICANT MATERIALS ON-SITE 1) An initial inventory of significant materials used or stored at the DAEC was generated in 1993 (Material Inventory Worksheet

1. 3 of SWPPP Notebook).

This inventory was updated on Attachment-I, Inventory of Exposed Materials, and this Attachment will be updated as the inventory of significant material on-site changes. These materials are evaluated for their potential to contribute pollutants to storm water run-off.2) For the purposes of this plan the following definitions are used: a) "Significant Materials," as defined: in 40 CFR 122.26(b)(12),"include but are not limited to: raw materials; fuels; materials such as solvents, detergents and plastic pellets; finished materials such as metallic products; raw materials used in food processing or production. b) "Hazardous Substances" designated under Section 101(14) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); any chemical the facility is required to report pursuant to Section 313 of Title III of the Superfund Amendments and Reauthorization Act (SARA); fertilizers; pesticides; and waste products such as ashes, slag, and sludge that have a potential to be released with storm water discharges." 3) As shown on Attachment-i, Inventory of Exposed Materials, most of the chemicals used at the DAEC fall into three main categories: a) Petroleum products such as fuels (diesel and gasoline), transformer oils (electrical insulating fluids), and hydraulic oils. SPCC requirements (40 CFR Part 112) apply to petroleum bulk storage tanks and materials handling areas.b) Water treatment chemicals which have been tested, certified by a vendor, or confirmed by process knowledge to containno detectable concentrations of the 126 priority pollutants listed in Appendix "A" of 40 CFR Part 423, except as specifically authorized by the NPDES permit.c) Antifreeze (ethylene and propylene glycol) used in air conditioning units or cooling coils. The locations for these chemicals are visited and observed frequently throughout each shift by the DAEC Operations department, any leak of antifreeze would be recognized readily and corrected. [Swppp5-3.doc] Page 8 Revision No. 5.3 3.0 SIGNIFICANT MATERIALS ON-SITE [Swppp5 -3. doc} 1) An initial inventory of significant materials used or stored at the DAEC was generated in 1993 (Material Inventory Worksheet

1. 3 of SWPPP Notebook).

This inventory was updated on Attachment-I, Inventory of Exposed Materials, and this Attachment will be updated as the inventory of significant material on-site changes. These materials are evaluated for their potential to contribute pollutants to storm water run-off. 2) For the purposes ofthis plan the following definitions are used: a) "Significant Materials," as defined: in 40 CFR 122.26(b)(12), "include but are not limited to: raw materials; fuels; materials such as solvents, detergents and plastic pellets; finished materials such as metallic products; raw materials used in food processing or production. b) "Hazardous Substances" designated under Section 101(14) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); any chemical the facility is required to report pursuant to Section 313 of Title ill ofthe Superfund Amendments and Reauthorization Act (SARA); fertilizers; pesticides; and waste products such as ashes, slag, and sludge that have a potential to be released with storm water discharges." 3) As shown on Attachment-I, Inventory of Exposed Materials, most of the chemicals used at the DAEC fall into three main categories: a) Petroleum products such as fuels (diesel and gasoline), transformer oils (electrical insulating fluids), and hydraulic oils. SPCC requirements (40 CFR Part 112) apply to petroleum bulk storage tanks and materials handling areas. b) Water treatment chemicals which have been tested, certified by a vendor, or confirmed by process knowledge to contain no detectable concentrations of the 126 priority pollutants listed in Appendix "A" of 40 CFR Part 423, except as specifically authorized by the NPDES permit. c) Antifreeze (ethylene and propylene glycol) used in air conditioning units or cooling coils. The locations for these chemicals are visited and observed frequently throughout each shift by the DAEC Operations department, any leak of antifreeze would be recognized readily and corrected. Page 8 Revision No. 5.3 4) The likelihood of storm water contact with the chemicals stored in bulk tanks at the DAEC is relatively low since all aboveground bulk storage tanks are located inside containment structures.

5) Containers (55-gallon drums) of used solvents, used oil, and used glycol are located in containment structures or buildings, which minimize the potential for exposure to storm water run-off.4.0 SITE DRAINAGE PATTERNS AND OUTFALL DESCRIPTIONS

1) As shown on the site plans provided in Appendix B of the SWPPP Notebook, surface run-off is conveyed in storm sewers and drainage ditches at the DAEC facility.a) Surface water flow across the site trends in an easterly orsoutheasterly direction in two main canals toward the Cedar River, the receiving stream.b) Primary sources of storm water include road and parking lot run-off, building downspouts, and yard drains.c) Several of the yard drains and storm sewers receive run-off associated with "industrial activity" as defined in the storm water regulations.

d) Security upgrades surrounding the facility include a series of ditches, which are designed for security purposes only and not for directing storm water runoff. The ditches are typically several feet deep with the removed soil piled next to the ditch on one side. The ditches were made with sediment traps in the ditch to reduce the amount of erosion. The ditches and soil piles are planned to be completelyseeded during the next growing season.2) Sources in the northern portion of the site, include the following: a) The Independent Spent Fuel Storage Installation (ISFSI) constructed just north of the DAEC Training Center consists of dry fuel storage modules installed on a concrete base pad. Approximately

5.5 acres

has been graded level with the removed material placed in a spoils pile stretching from the south. Riprap was installed in the drainage area leading away from the ISFSI. Runoff from this area flows on the east side of the north-south road and travels south and meets up withthe flow from the training center.[Swppp5-3 .doc]Page 9 I Revision No. 5.3 4) The likelihood of stonn water contact with the chemicals stored in bulk tanks at the DAEC is relatively low since all aboveground bulk storage tanks are located inside containment structures.

5) Containers (55":gallon drums) of used solvents, used oil, and used glycol are located in containment structures or buildings, which minimize the potential for exposure to stonn water run-off. 4.0 SITE DRAINAGE PATTERNS AND OUTFALL DESCRIPTIONS

[Swppp5 -3. doc] 1) As shown on the site plans provided in Appendix B of the SWPPP Notebook, surface run-off is conveyed in stonn sewers and drainage ditches at the DAEC facility. a) Surface water* flow across the site trends in an easterly or southeasterly direction in two main canals toward the Cedar River, the receiving stream. b) Primary sources of stonn water include road arid parking lot off, building downspouts, and yard drains. c) Several of the yard drains and stonn sewers receive run-off associated with "industrial activity" as defined in the stonn water regulations. d) Security upgrades surrounding the facility include a series of ditches, which are designed for security purposes only and not for directing stonn water runoff. The ditches are typically several feet deep with the removed soil piled next to the ditch on one side. The ditches were made with sediment traps in the ditch to reduce the amount of erosion. The ditches and soil piles are planned to be completely seeded during the next growing season. 2) Sources in the northern portion of the site, include the following: a) The Independent Spent Fuel Storage Installation (ISFSI) constructed just north of the DAEC Training Center consists of dry fuel storage modules installed on a concrete base pad. Approximately

5.5 acres

has been graded level with the removed material placed in a spoils pile stretching from the south. Riprap was installed in the drainage area leading away from the ISFSI. Runoff from this area flows on the east side of the north-south road and travels south and meets up with the flow from the training center. Page 9 Revision No. 5.3 a) Runoff from the DAEC Training Center, which intercepts a northern drainage ditch on the eastern side of the road travels approximately 100 yards south where it then traverses the site in an east direction towards the Cedar River. Some of the travel path for this runoff is underground in culverts. This storm water run-off flows into NPDES Outfall No. 002 b) NPDES Outfall No. 002 from the Sewage plant enters this ditch from the north through a 10-inch diameter sewer pipe; this outfall receives approximately 12,000 gpd of treated effluent from the sanitary wastewater treatment plant (in about 1,500-gallon batch discharges). c) The northern ditch also receives inputs from various yard drains and culverts (including the drainage-way adjacent to the west of the petroleum pad containment structure) and the overflow from the Cooling Towers, which enters via a drainage channel, located between the towers.d) For the purposes of the SWPPP, the terminal culvert pipe that extends under the plant road in the northeast portion of the site (at the entrance of the channel past the cooling towers that extends from the road to the river) has been identified as SWPPP Outfall No.002. It is comprised of a mixed discharge from both storm water runoff and non-storm water discharges.

3) Sources in the southern portion of the site, include the following:

a) Surface run-off from the southern portion of the site and the switchyard drain to ditches that parallel the DAEC Road on both sides and then flow east to the discharge canal. The discharge canal is conveyed with cooling tower blowdown from the circulating water system (approximately 1,600 gpm during typical plant operations) to the Cedar River. NPDES Outfall No. 001 enters this canal through a 48-inch diameter reinforced concrete pipe.b) A Retention Pond, which accumulates the stormwater from Low Level Radwaste Processing and Storage Facility (LLRPSF) yard storm water drains, is located on the south portion of the site. This retention pond is manually drained and inspected prior to drainage to the drainage ditch that -flows east to the discharge canal.c) The overflow parking area on the south side of the site is gravel and recently has had storm water drainage culverts installed to improve theoverall drainage. These culverts are directed to the south, where they[SwpppS-3. doe]Page 10 Revision No.5. 3 a) . Runoff from the DAEC Training Center, which intercepts a northern drainage ditch on the eastern side of the road travels approximately 100 yards south where it then traverses the site in an east direction towards the Cedar River. Some of the travel path for this runoff is underground in culverts. This storm water run-off flows into NPDES Outfall No. 002 b) NPDES Outfall No. 002 from the Sewage plant enters this ditch from the north through a lO-inch diameter sewer pipe; this outfall receives approximately 12,000 gpd of treated effluent from the sanitary wastewater treatment plant (in about I,SOO-gallon batch discharges). c) The northern ditch also receives inputs from various yard drains and culverts (including the drainage-way adjacent to the west ofthe petroleum pad containment structure) and the overflow from the Cooling Towers, which enters via a drainage channel, located between the towers. d) For the purposes of the SWPPP, the terminal culvert pipe that . extends under the plant road in the northeast portion ofthe site (at the entrance of the channel past the cooling towers that extends from the road to the river) has been identified as SWPPP Outfall No. 002. It is comprised of a mixed discharge from both storm water runoff and non-storm water discharges.

3) Sources in the southern portion of the site, include the following:

[Swppp5 -3. doc] a) Surface run-off from the southern portion of the site and the switchyard drain to ditches that parallel the DAEC Road on both sides and then flow east to the discharge canal. The discharge canal is conveyed with cooling tower blowdown from the circulating water system (approximately 1,600 gpm during typical plant operations) to the Cedar River. NPDES Outfall No. 001 enters this canal through a 48-inch diameter reinforced concrete pipe. b) A Retention Pond, which accumulates the stormwater from Low Level Radwaste Processing and Storage Facility (LLRPSF) yard storm water drains, is located on the south portion of the site. This retention pond is manually drained and inspected prior to drainage to the drainage ditch that .flows east to the discharge canal. c) The overflow parking area on the south side of the site is gravel and recently has had storm water drainage culverts installed to improve the overall drainage. These culverts :ire directed to the south, where they Page 10 Revision No. 5.3 flow into the easterly drainage ditch and eventually mix with NPDES Outfall 001.d) The site has a Transformer Deluge Pit, which accumulates the stormwater from the transformers, Instrument Air Building airconditioning unit containment areas, and some floor drains from the pump .house. This pit is manually drained and inspected prior to drainage into NPDES Outfall No. 001.e) A new south warehouse was fabricated on the southwest quadrant of the site. The new warehouse is designed to receive all shipments(including chemicals and petroleum products) and hold them for a temporary period until they are inspected and accepted. The buildingwas designed with a closed floor drain trough system. The containment pit runs through the center of the building and a second trough and containment pit in the southeast quadrant of the building. Any spilled material will be contained within the building where it can be readily cleaned up. The storm water runoff from the roof drains and loading dock, runs into an east-west drainage ditch on the southern boundary of the property. The ditch flows into the Cedar River.5.0 NON-STORM WATER DISCHARGE ASSESSMENT & CERTIFICATION

1) Initial evaluations of the DAEC outfalls for the presence of non-storm water discharges were conducted on February 17 and February 19, 1993.a) Methods used to evaluate these outfalls included a review of plant schematics and visual inspection during dry weather conditions.

b) Documentation of the inspections is in the SWPPP Notebook.Also, included are the results of the non-storm water discharge assessment and certification.

2) NPDES Outfall No.

001 receives cooling tower blowdown from the circulating water system.a) On February 17, 1993, cooling tower blowdown was being diverted to the intake screens for de-icing purposes and flow from this system was not observed in the discharge canal.b) A follow-up inspection on February 19,1993, when the de-icing flow was not being diverted to the intake structure confirmed a non-storm water discharge on the order of 12,000 gpm; this is about 10 times the normal blowdown flow from the circulating water system and filled the cross-sectional area of the 48-inch reinforced concrete pipe at the entrance to the discharge canal approximately one-half of capacity.[Swppp5-3.doc] Page 11 Revision No. 5.3 flow into the easterly drainage ditch and eventually mix with NPDES Outfall 001. d) The site has a Transformer Deluge Pit, which accumulates the stormwater from the transformers, mstrument Air Building air conditioning unit containment areas, and some floor drains from the pump .house. This pit is manually drained and inspected prior to drainage into NPDES Outfall No. 001. e) A new south warehouse was fabricated on the southwest quadrant of the site. The new warehouse is designed to receive all shipments (including chemicals and petroleum products) and hold them for a temporary period until they are inspected and accepted. The building was designed with a closed floor drain trough system. The containment pit runs through the center of the building and a second trough and containment pit in the southeast quadrant of the building. Any spilled material will be contained within the building where it can be readily cleaned up. The storm water runoff from the roof drains and loading dock, runs into an east-west drainage ditch on the southern boundary of the property. The ditch flows into the Cedar River. 5.0 NON-STORM WATER DISCHARGE ASSESSMENT & CERTIFICATION {Swppp5 -3. doc] 1) mitial evaluations ofthe DAEC outfalls for the presence of non-storm water discharges were conducted on February 17 and February 19, 1993. a) Methods used to evaluate these outfalls included a review of plant schematics and visual inspection during dry weather conditions. b) Documentation of the inspections is in the SWPPP Notebook. Also, included are the results of the non-storm water discharge assessment and certification.

2) NPDES Outfall No. 001 receives cooling tower blowdown from the circulating water system. a) On February 17, 1993, cooling tower blowdown was being diverted to the intake screens for de-icing purposes and flow from this system was not observed in the discharge canal. b) A follow-up inspection on February 19,1993, when the de-icing flow was not being diverted to the intake structure confirmed a non-storm water discharge on the order of 12,000 gpm; this is about 10 times the normal blowdown flow from the circulating water system and filled the cross-sectional area of the 48-inch reinforced concrete pipe at the entrance to the discharge canal approximately one-half of capacity.

Page 11 Revision No. 5.3 c) During both inspections, flow (estimated 5 to 10 gpm) from a General Service Water (GSW) source in the Pumphouse was observed entering a small drainage channel upstream (and north of)the discharge canal. This non-storm water discharge flow is generated from a sampling station and backwash strainerblowdown on the GSW system 3) NPDES Outfall No. 002 is the second NPDES outfall at the DAEC facilityand conveys treated effluent from the sanitary wastewater treatment system to the northern ditch.a) Batch discharges of treated effluent from the sanitary wastewater treatment system totaling approximately 12,000 gallons per day enter this drainage ditch.b) The channel immediately downstream of the outfall was observed to contain pond water from the prior discharge cycles.c) SWPPP Outfall No. 002 is located at the termination of the north drainage ditch (upstream of the Cedar River) and receives non-storm water discharges from two sources: NPDES Outfall No. 002 and the overflow from the two cooling towers, which enters the ditch via a drainage channel in the northeast portion of the site (see site plan BECH-C101 for approximate location). [Swppp5-3.doc] Page 12 Revision No. 5.3 [Swppp5 -3. doc] c) During both inspections, flow (estimated 5 to 10 gpm) from a General Service Water (GSW) source in the Pumphouse was observed entering a small drainage channel upstream (and north of) the discharge canal. This non-storm water discharge flow is generated from a sampling station and backwash strainer blowdown on the GSW system 3) NPDES Outfall No. 002 is the second NPDES outfall at the DAEC facility and conveys treated effluent from the sanitary wastewater treatment system to the northern ditch. a) Batch discharges of treated effluent from the sanitary wastewater treatment system totaling approximately 12,000 gallons per day enter this drainage ditch. b) The channel immediately downstream of the outfall was observed to contain pond water from the prior discharge cycles. c) SWPPP Outfall No. 002 is located at the termination ofthe north drainage ditch (upstream of the Cedar River) and receives storm water discharges from two sources: NPDES Outfall No. 002 and the overflow from the two cooling towers, which enters the ditch via a drainage channel in the northeast portion of the site (see site plan BECR-ClOl for approximate location). Page 12 Revision No. 5.3 SECTION C BEST MANAGEMENT PRACTICES (BMPs)1.0 POLLUTANT SOURCE IDENTIFICATION AND BMPs During the February 1993 site assessment activities, several potential sources of storm water contamination were identified at the DAEC facility. The 1993 site assessment was very thorough in identifying potential pollution sources. These same sources continue to be the highest potential sources of storm water contamination at the DAEC facility today. A brief description of each of the potential pollutant sources is provided below with an update tothe BMPs suggested for each source. As a minimum a monthly inspection is performed to ensure the BMPs are effectively being used.

1) The petroleum pad containment structure houses two bulk tanks (a 250 gal.above ground tank for diesel fuel and a 500 gal. above ground tank for gasoline) and at times may store 55-gallon drums containing used oil, used glycol, and used non-hazardous solvents in this location.

At the time of thisrevision plans are to relocate the bulk tanks of diesel fuel and gasoline to thesouth warehouse. a) Storm water collected in the containment structure is retained and visually examined for the presence of an oily sheen prior to discharge (through a normally-closed valve) to the drainage channel immediately west of the structure (east side of the Electrical Shop).b) Accidental release of impounded contaminated water or spilled product materials is a potential source of storm water contamination. c) A metal enclosure for this containment structure was not built due to security requirements at this facility. However, a canopy was constructed over the pad to minimize rain from entering the containment. The canopy was damaged in 2003 and was removed.Currently, there are no plans to replace it.2) DAEC vehicles are periodically re-fueled on a concrete pad adjacent to the petroleum pad containment structure. Overfilling of the vehicle fill tube or leaks from the dispensing nozzle are potential sources of storm water pollutants. a) These re-fueling activities could impact storm water quality in the drainage-way that extends north from the containment structure on the east side of the Electrical Shop.[Swppp5-3 .doe]Page 13 Revision No. 5.3 SECTION C BEST MANAGEMENT PRACTICES (BMPs) 1.0 POLLUTANT SOURCE IDENTIFICATION AND BMPs During the February 1993 site assessment activities, several potential sources of storm water contamination were identified at the DAEC facility. The 1993 site assessment was very thorough in identifying potential pollution sources. These same sources continue to be the highest potential sources of storm water contamination at the DAEC facility today. A brief description of each of the potential pollutant sources is provided below. with an update to the BMPs suggested for each source. As a minimum a monthly inspection is performed to ensure the BMPs are effectively being used. [Swppp5 -3. doc] 1) The petroleum pad containment structure houses two bulk tanks (a 250 gal. above ground tank for diesel fuel and a 500 gal. above ground tank for gasoline) and at times may store 55-gallon drums containing used oil, used glycol, and used non-hazardous solvents in this location. At the time of this revision plans are to relocate the bulk tanks of diesel fuel and gasoline to the south warehouse. a) Storm water collected in the containment structure is retained and visually examined for the presence of an oily sheen prior to discharge (through a normally-closed valve) to the drainage channel immediately west of the structure (east side of the Electrical Shop). b) Accidental release of impounded contaminated water or spilled product materials is a potential source of storm water contamination. c) A metal enclosure for this containment structure was not built due to security requirements at this facility. However, a canopy was constructed over the pad to minimize rain from entering the containment. The canopy was damaged in 2003 and was removed. Currently, there are no plans to replace it. 2) DAEC vehicles are periodically re-fueled on a concrete pad adjacent to the petroleum pad containment structure. Overfilling of the vehicle fill tube or leaks from the dispensing nozzle are potential sources of storm water pollutants. a) These re-fueling activities could impact storm water quality in the drainage-way that extends north from the containment structure on the east side ofthe Electrical Shop. Page 13 Revision No. 5.3 3) The warehouse loading dock is uncovered and storm water that collects at the base of the north end of the vehicle drive-up area could become contaminated by vehicle leaks (e.g., oily chassis) or spills that could occur during vehicle unloading or material handling operations. a) The concrete bulkhead on the north side of the north drainage ditch has an 8-inch hole cast in place to allow water accumulating at the base to drain directly into the ditch. Any contaminants present in the collected water could run-off into the ditch via this drain.b) A normally closed valve was not installed, it was determined a drain plug would provide the same protection. A drain plug is available on the bulkhead drain at the loading dock area.c) Spill response equipment from the Warehouse spill kit can be used as needed when spills or residues accumulate behind the bulkhead drain.4) The fill line on the 20,000-gallon sulfuric acid tank located on the east side of the Pump house is inside of the vehicle off-loading drive through containment. The vehicle off-loading drive through containment area was constructed in October of 1993.a) Prior to 1993, in the event of a vehicular accident, faulty valve, or other related problem, the released product could enter a nearby yard drain and flow into the discharge channel. b) The vehicle off-loading drive through containment has a drain plug that is required to be installed during off-loading activities. A dry break coupler is used to prevent inadvertent leakage during disconnection. c) Spill response equipment from the Pumphouse spill kits can be used when spills or residues accumulate inside and outside the containment. d) Drainage from the vehicle off-loading containment is underground to the east, above ground to the north, where it flows into a storm drain. The storm drain goes underground to the south until it meets the discharge canal, NPDES Outfall #001.5) Two underground storage tanks (UST's; one 50,000 gallon and one 40,000gallon) used to store diesel fuel for an auxiliary boiler and emergency diesel generators are located immediately south of the Turbine Building.[Swppp5-3 .doc]Page 14 Revision No. 5.3 [Swppp5 -3. doc] 3) The warehouse loading dock is uncovered and storm water that collects at the base of the north end of the vehicle drive-up area could become contaminated by vehicle leaks (e.g., oily chassis) or spills that could occur during vehicle unloading or material handling operations. a) The concrete bulkhead on the north side of the north drainage ditch has an 8-inch hole cast in place to allow water accumulating at the base to drain directly into the ditch. Any contaminants present in the collected water could run-off into the ditch via this drain. b) A normally closed valve was not installed, it was determined a drain plug would provide the same protection. A drain plug is available on the bulkhead drain at the loading dock area. c) Spill response equipment from the Warehouse spill kit can be used as needed when spills or residues accumulate behind the bulkhead drain. 4) The fill line on the 20,000-gallon sulfuric acid tank located on the east side of the Pump house is inside of the vehicle off-loading drive through containment. The vehicle off-loading drive through containment area was constructed in October of 1993. a) Prior to 1993, in the event of a vehicular accident, faulty valve, or other related problem, the released product could enter a nearby yard drain and flow into the discharge channel. b) The vehicle off-loading drive through containment has a drain plug that is required to be installed during off-loading activities. A dry break coupler is used to prevent inadvertent leakage during disconnection. c) Spill response equipment from the Pumphouse spill kits can be used when spills or residues accumulate inside and outside the containment. d) Drainage from the vehicle off-loading containment is underground to the east, above ground to the north, where it flows into a storm drain. The storm drain goes underground to the south until it meets the discharge canal, NPDES Outfall #001. 5) Two underground storage tanks (UST's; one 50,000 gallon and one 40,000 gallon) used to store diesel fuel for an auxiliary boiler and emergency diesel generators are located immediately south of the Turbine Building. Page 14 Revision No. 5.3 a) Prior to 1993, releases occurring as a result of faulty valves on delivery lines or leaking fittings could enter yard drains and were potential sources of storm water contamination. b) Two Vehicle off-loading drive through containments were constructed in 1993 at these locations. The containments have drainplugs that are required to be installed during off-loading activities. Dry break couplers are also used to prevent inadvertent leakageduring disconnection. c) Signs are posted requiring the driver to properly disconnect prior to driving away and inserting containment drain plug prior to off-loading. The vehicle wheels are chocked.6) Impounded water released from the Transformer Deluge Pit impoundment structure may contain oils or an oily sheen from transformer leaks.a) An Operations Department procedure requires an observer to be stationed at the canal to monitor for any oil sheen during discharges. Also, an Operator is stationed at the isolation valve and communicates using two-way radios with the observer to quickly secure the discharge in case of an oil sheen. These controls decrease the risk of an accidental release of impounded oil contaminated water as a potential source of storm water contamination. b) If oil is visible on the water surface (oily sheen, floating oil), it isremoved (skimmed) from the surface using absorbents prior to discharge into the canal. Oil booms are positioned at NPDES Outfall No. 001 downstream of the mixing with the discharged Transformer Deluge water. Prior to each discharge from the Transformer Deluge Pit the oil booms are inspected and replaced if necessary.

7) Fires are ignited and extinguished in a metal pan on a concrete pad in the fire training area as part of the DAEC fire training activities.

a) Debris and fire extinguisher residues (non-hazardous) may remainon the pad following a training exercise and could contaminate surface run-off that enters the north drainage ditch.b) A berm area surrounding the concrete pad was determined not necessary since employees are required to cleanup residues and debris following each training exercise. [Swppp5-3 .docc Page 15 Revision No. 5.3 [Swppp5 -3. doc] a) Prior to 1993, releases occurring as a result of faulty valves on delivery lines or leaking fittings could enter yard drains and were potential sources of storm water contamination. b) Two Vehicle off-loading drive through containments were constructed in 1993 at these locations. The containments have drain plugs that are required to be installed during off-loading activities. Dry break: couplers are also used to prevent inadvertent leakage during disconnection. c) Signs are posted requiring the driver to properly disconnect prior to driving away and inserting containment drain plug prior to off-loading. The vehicle wheels are chocked. 6) hnpounded water released from the Transformer Deluge Pit impoundment structure may contain oils or an oily sheen from transformer leaks. a) An Operations Department procedure requires an observer to be stationed at the canal to monitor for any oil sheen during discharges. Also, an Operator is stationed at the isolation valve and communicates using two-way radios with the observer to quickly secure the discharge in case of an oil sheen. These controls decrease the risk of an accidental release of impounded oil contaminated water as a potential source of storm water contamination. b) If oil is visible on the water surface (oily sheen, floating oil), it is removed (skimmed) from the surface using absorbents prior to discharge into the canaL Oil booms are positioned at NPDES Outfall No. 001 downstream of the mixing with the discharged Transformer Deluge water. Prior to each discharge from the Transformer Deluge Pit the oil booms are inspected and replaced if necessary.

7) Fires are ignited and extinguished in a metal pan on a concrete pad in the fire training area as part ofthe DAEC fire training activities.

a) Debris and fire extinguisher residues (non-hazardous) may remain on the pad following a training exercise and could contaminate surface run-off that enters the north drainage ditch . . b) A berm area surrounding the concrete pad was determined not necessary since employees are required to cleanup residues and debris following each training exercise. Page 15 Revision No. 5.3 c) Spill response equipment from the Warehouse or Sewage Plant spill kits can be used as needed when spills or residues accumulate.

8) Bulk deliveries of water treatment chemicals to the containment structure located on the north end of the Pumphouse could result in storm water contamination.

a) Prior to 1993, potential sources of storm water pollutants includeleaks from valves on vehicles and fill lines (located outside the containment structure), equipment malfunctions, tank overfilling, and vehicle accidents. b) A vehicle off-loading drive through containment was constructed in 1993. The containment has a drain plugs that is required to be installed during off-loading activities. Dry break couplers are used to prevent inadvertent leakage during disconnection. c) Spill response equipment from the Pumphouse spill kits can be used when spills or residues accumulate inside and outside the containment.

9) The concrete pad located on the north end of the Pipe Fab Shop is used for storing miscellaneous vehicles, equipment items andheavy machinery.

a) Pollutant sources include incidental leaks and spills from vehicle and equipment maintenance activities. Such leaks could contribute pollutants to the storm water run-off that accumulates in the north-south drainage ditch located on the east side of the Electrical Shop.b) The spills and leaks from the vehicles and equipment or maintenance activities at the pad did not warrant a canopy of the area. The requirements for general housekeeping and the uses of drip pans andabsorbent material during vehicle maintenance adequately prevent pollutants from reaching the storm water run-off c) A drainage channel located to the north and east of the storage pad area is inspected periodically to facilitate more effective conveyance of storm water flow.10) Discharge of oily water from a-moisture separator in the Breathing air Compressor building (south of the Reactor Building) is a potential source of[Swppp5-3 .doc]Page 16 Revision No. 5.3 [Swppp5 -3. doc] c) Spill response equipment from the Warehouse or Sewage Plant spill kits can be used as needed when spills or residues accumulate.

8) Bulk deliveries of water treatment chemicals to the containment structure located on the north end ofthe Pumphouse could result in storm water contamination.

a) Prior to 1993, potential sources of storm water pollutants include leaks from valves on vehicles and fill lines (located outside the containment structure), equipment malfunctions, tank overfilling, and vehicle accidents. b) A vehicle off-loading drive through containment was constructed in 1993. The containment has a drain plugs that is required to be installed during off-loading activities. Dry break couplers are used to prevent inadvertent leakage during disconnection. c) Spill response equipment from the Pumphouse spill kits can be used when spills or residues accumulate inside and outside the containment.

9) The concrete pad located on the north end of the Pipe Fab Shop is used for storing miscellaneous vehicles, equipment items and heavy machinery.

a) Pollutant sources include incidental leaks and spills from vehicle and equipment maintenance activities. Such leaks could contribute pollutants to the storm water run-off that accumulates in the south drainage ditch located on the east side of the Electrical Shop. b) The spills and leaks from the vehicles and equipment or maintenance activities at the pad did not warrant .a canopy of the area. The requirements for general housekeeping imd the uses of drip pans and absorbent material during vehicle maintenance adequately prevent pollutants from reaching the storm water run-off c) A drainage channellbcated to the north and east ofthe storage pad area is inspected periodically to facilitate more effective conveyance of storm water flow. 10) Discharge of oily water from a*moisture separator in the Breathing air Compressor building (south of the Reactor Building) is a potential source of Page 16 Revision No. 5.3 contaminants in storm water entering a yard drain located at the southeast comer of the building.a) A 55-gallon drum is used to collect the oily water from the moisture separator. The double-contained sump considered in 1993 in the building was determined not necessary. b) This drum is routinely checked by Radwaste Group and transferred if the container is greater than 3/4 full.11) Releases during the transfer of drummed products from the main warehouse to the petroleum product container storage (lube) building located adjacent to the warehouse could contribute contaminants to a nearby yard drain.a) Good housekeeping practices are used to minimize any accidentsfrom occurring during product transfer. Personnel are trained toimmediately report spills. Good housekeeping and spill cleanup requirements are the BMPs used at this location to prevent pollutants from reaching a nearby yard drain.b) Spill response equipment from the Warehouse spill kit can be used as needed when spills occur in this area.

13) The 1,000-gallon sulfuric acid bulk storage tank at the southeast comer of the Turbine Building is abandoned in place and has not been used since 1994.14) Vehicular accidents are a potential source of storm water contamination atvarious loading and unloading locations at the DAEC facility.a) Security personnel inspect each vehicle for leaking fluids prior to entering and escort all contract vehicles during loading and unloading evolutions in the Protected Area.b) Any vehicle attempting to enter the facility with leaky equipment is refused entry or the spill is treated with spill absorbant material prior to entering.15) Oil releases from transformers in the electrical switchyard located to the west of the main parking lot and on the west side of the main DAEC Road could contribute storm water pollutants during precipitation events.a) Spill prevention and inspection of this area is covered by the SPCC Plan.[Swppp5-3

.doci Page 17 Revision No. 5.3 [Swppp5 -3. doc] contaminants in stOIDl water entering a yard drain located at the southeast comer of the building. a) A 55-gallon drum is used to collect the oily water from the moisture separator. The double-contained sump considered in 1993 in the building was deteIDlined not necessary. b) This drum is routinely checked by Radwaste Group and transferred if the container is greater than 3/4 full. 11) Releases during the transfer of drummed products from the main warehouse to the petroleum product container storage (lube) building located adjacent to the warehouse could contribute contaminants to a nearby yard drain. a) Good housekeeping practices are used to minimize any accidents from occurring during product transfer. Personnel are trained to immediately report spills. Good housekeeping and spill cleanup requirements are the BMPs used at this location to prevent pollutants from reaching a nearby yard drain. b) Spill response equipment from the Warehouse spill kit can be used as needed when spills occur in this area. 13) The 1,OOO-gallon sulfuric acid bulk storage tank at the southeast comer of the Turbine Building is abandoned in place and has not been used since 1994. 14) Vehicular accidents are a potential source of stOIDl water contamination at various loading and unloading locations at the DAEC facility. a) Security personnel inspect each vehicle for leaking fluids prior to entering and escort all contract vehicles during loading and unloading evolutions in the Protected Area. b) Any vehicle attempting to enter the facility with leaky equipment is refused entry or the spill is treated with spill absorbant material prior to entering.

15) Oil releases from transfoIDlers in the electrical switchyard located to the west ofthe main parking lot and on the west side of the main DAEC Road could contribute stOIDl water pollutants during precipitation events. a) Spill prevention and inspection of this area is covered by the SPCC Plan. Page 17 Revision No. 5.3 b) If oil is observed in the drainage channel, spill booms will be strategically located in the drainage channel.16) Paved and graveled vehicle parking lot areas and unpaved areas around plant structures contribute solids to storm water run-off. Parking lot areas are also a potential source of oily contaminants.

a) Sweeping of parking lots to remove solids and oily residues has been occasionally performed but is not a BMP used at this facility. b) Periodic inspections and educating employees to minimize vehiclefluid leakage and reporting spills are BMPs used to prevent contamination of storm water run-off from parking lots. Spills and leaks from vehicles are treated similar to spills from plant equipment and are required to be reported. Vehicle owners are often asked to remove their leaking vehicle from site until it has been repaired.17) Soil erosion caused by overland surface water flow and by scouring ofdrainage channels is a potential source of increased solids and sediment loading in storm water run-off, especially during periods of heavy rainfall.The presence of debris obstruct/restrict flow in some drainage channels may cause excessive siltation or other drainage problems.a) Placements of ripraps have been incorporated at strategic locations at the site to prevent banks from washing out. Also, periodic inspection of the site prevents debris from obstructing or restricting flow in drainage channels.18) General housekeeping practices if not used, could result in trash blocking culverts, used products, not properly stored equipment, and oily residues from equipment contaminating storm water runoff, and increases potential for accidents that mayrelease pollutants to the storm drains.a)- Periodic inspections and educating the employees to the importance of good housekeeping practices are the BMPs used to prevent contamination of storm water run-off from this site.19) The new South Warehouse loading dock is uncovered and storm water from this area flows a short distance north to a culvert. The loading dock andwarehouse delivery area could become contaminated by vehicle leaks (e.g., oily chassis) or spills that could occur during vehicle unloading or material handling operations. a) Personnel are planning to assemble a spill kit for controlling the spread of spilled material in or around the outside of the warehouse, this would decrease the risk of material being released to the river.[Swppp5-3 .doc]Page 18 Revision No. 5.3 [Swppp5 -3. doc] b) If oil is observed in the drainage channel, spill booms will be strategically located in the drainage channel. 16) Paved and graveled vehicle parking lot areas and unpaved areas around plant structures contribute solids to storm water run-off. Parking lot areas are also a potential source of oily contaminants. a) Sweeping of parking lots to remove solids and oily residues has been occasionally performed but is not a BMP used at this facility. b) Periodic inspections and educating employees to minimize vehicle fluid leakage and reporting spills are BMPs used to prevent contamination of storm water run-off from parking lots. Spills and leaks from vehicles are treated similar to spills from plant equipment and are required to be reported. Vehicle owners are often asked to remove their leaking vehicle from site until it has been repaired.

17) Soil erosion caused by overland surface water flow and by scouring of drainage channels is a potential source of increased solids and sediment loading in storm water run-off, especially during periods of heavy rainfall.

The presence of debris obstruct/restrict flow in some drainage channels may cause excessive siltation or other drainage problems. a) Placements of rip raps have been incorporated at strategic locations at the site to prevent banks from washing out. Also, periodic inspection of the site prevents debris from obstructing or restricting flow in drainage channels.

18) General housekeeping practices if not used, could result in trash blocking culverts, used products, not properly stored equipment, and oily residues from equipment contaminating storm water runoff, and increases potential for accidents that may release pollutants to the storm drains. a)-Periodic inspections and educating the employees to the importance of good housekeeping practices are the BMPs used to prevent contamination of storm water run-off from this site. 19) The new South Warehouse loading dock is uncovered and storm water from this area flows a short distance north to a culvert. The loading dock and warehouse delivery area could become contaminated by vehicle leaks (e.g., oily chassis) or spills that could occur during vehicle unloading or material handling operations, a) Personnel are planning to assemble a spill kit for controlling the spread of spilled material in or around the outside of the warehouse, this would decrease the risk of material being released to the river. Page 18 Revision No. 5.3 b) An area outside of the warehouse is being prepared for bulk diesel and gasoline tanks. These tanks will be used for filling site vehicles with all loading and unloading activities being performed on concrete surfaces.The spill kit for this area will contain several types of petroleum absorbent materials such as booms, socks, pads, and diatomaceous earth.20) Training Center Cooling Tower Chiller and Instrument Air Conditioning Units are potential source for glycol.a) The Training Center Cooling Tower Chiller Glycol loop vent lines are plugged with threaded pipe plugs and vent valve handles have been removed.

Instructions are provided to off-site contractors to immediately notify DAEC personnel of any hazardous chemical spills so that appropriate spill response action can be taken.b) A drain plug is normally installed during Instrument Air Conditioning Unit operations. The collected rainwater is checked to ensure the absence of glycol prior to discharge to the transformer pit.2.0 REVIEWS AND SELECTIONS OF CURRENT BMPs 1) Best Management Practices (BMPs) are measures employed to prevent or mitigate storm water pollution from facility-specific or activity-specific sources. BMPs are a broad class of measures that may include processes, procedures, schedules of activities, prohibitions on practices, and othermanagement practices used to prevent or reduce pollution.

2) Following the 1993 DAEC site assessment, various storm water management practices were evaluated as alternatives to existing practices which may contribute pollutants to storm water run-off.3) The BMPs at this facility will continually be evaluated and updated as necessary to ensure the best practices are used to control potential pollutants and minimize or completely eliminate the potential release ofcontaminants from entering the storm water system.3.0 SPILL RESPONSE AND REPORTING 1) The DAEC has a Chemical/Oil Spill Response (ACP 1411.14) procedure to provide guidance and reporting requirements to employees when a chemical or oil spill occurs.2) Each employee is trained to immediately report a spill that they cannot[Swppp5-3

.doc]Page 19 Revision No. 5.3 20) b) An area outside of the warehouse is being prepared for bulk diesel and gasoline tanks. These tanks will be used for filling site vehicles with all loading and unloading activities being performed on concrete surfaces. The spill kit for this area will contain several types of petroleum absorbent materials such as booms, socks, pads, and diatomaceous earth. Training Center Cooling Tower Chiller and Instrument Air Conditioning Units are potential source for glycol. a) The Training Center Cooling Tower Chiller Glycol loop vent lines are plugged with threaded pipe plugs and vent valve handles have been removed. Instructions are provided to off-site contractors to immediately notify DAEC personnel of any hazardous chemical spills so that appropriate spill response action can be taken. b) A drain plug is normally installed during Instrument Air Conditioning Unit operations. The collected rainwater is checked to ensure the absence of glycol prior to discharge to the transformer pit. 2.0 REVIEWS AND SELECTIONS OF CURRENT BMPs 1) Best Management Practices (BMPs) are measures employed to prevent or mitigate storm water pollution from facility-specific or activity-specific . sources. BMPs are a broad class of measures that may include processes, procedures, schedules of activities, prohibitions on practices, and other management practices used to prevent or reduce pollution.

2) Following the 1993 DAEC site assessment, various storm water management practices were evaluated as alternatives to existing practices which may contribute pollutants to storm water run-off. 3) The BMPs at this facility will continually be evaluated and updated as necessary to ensure the best practices are used to control potential pollutants and minimize or completely eliminate the potential release of contaminants from entering the storm water system. 3.0 SPILL RESPONSE AND REPORTING

[Swppp5 -3. doc] 1) The DAEC has a Chemical/Oil Spill Response (ACP 1411.14) procedure to provide guidance and reporting requirements to employees when a chemical or oil spill occurs. 2) Each employee is trained to immediately report a spill that they cannot Page 19 Revision No. 5.3 cleanup by themselves or are not trained to cleanup. The spill is reported to the Control Room Supervisor (CRS) who then requests a ChemistryTechnician response to the spill area for an initial evaluation.

3) A trained DAEC HAZMAT spill response team is available 24 hours a day to provide technical advice and support the cleanup of non-incidental spills.4) If offsite assistance in containing or cleaning up a spill is needed, DAEC will solicit the support of the Palo Fire department and/or Linn CountyHazmat Team.

5) As soon as possible but less than six hours after an onset of a "Hazardous Condition", a representative of the DAEC will notify the IDNR and Linn County Sheriff and Nuclear Regulatory Commission.

a) "Hazardous condition" means any situation involving the actual,imminent, or probable spillage, leakage, or release of a hazardous substance on the land, into a water of the state, or into theatmosphere, which creates an immediate or potential danger to the public health or safety or to the environment. [Swppp5-3.doc] Page 20 Revision No. 5.3 [Swppp5 -3. doc] cleanup by themselves or are not trained to cleanup. The spill is reported to the Control Room Supervisor (CRS) who then requests a Chemistry Technician response to the spill area for an initial evaluation.

3) A trained DAEC HAZMAT spill response team is available 24 hours a day to provide technical advice and support the cleanup of non-incidental spills. 4) If offsite assistance in containing or cleaning up a spill is needed, DAEC will solicit the support of the Palo Fire department and/or Linn County Hazmat Team. 5) As soon as possible but less than six hours after an onset of a "Hazardous Condition", a representative of the DAEC will notify the IDNR and Linn County Sheriff and Nuclear Regulatory Commission.

a) "Hazardous condition" means any situation involving the actual, imminent, or probable spillage, leakage, or release of a hazardous substance on the land, into a water of the state, or into the atmosphere, which creates an immediate or potential danger to the public health or safety or to the environment. Page 20 Revision No. 5.3 4.0 INSPECTIONS

1) A SWPP Team member will at a minimum conduct a quarterly visual examination of storm water discharge associated with industrial activity from outfalls 001 and 002. The examination must be made: a) At least once during in each of the following periods: January though March, April through June, July through September, and October through December.b) During daylight hours.c) At a minimum of 30 days from the last examination.

d) Within the first 30 minutes (or soon thereafter as practical but not to exceed 1 hour) of when runoff or snowmelt begins discharging. e) Document observations of color, odor, clarity, floating solids, settledsolids, suspended solids, foam, oil sheen, and other obvious indicators ofstorm water pollution. f) During a storm event that is greater than 0.1 inches in magnitude and that occurs at least 72 hours from the previously measurable storm event of greater than 0.1 inches.g) Where practicable, the same individual should carry out the examination of discharges for the entire permit term.2) The visual examination reports must be maintained on-site in the pollutionprevention plan and not sent into the Iowa DNR unless requested. a) The results of these inspections and descriptions of any follow-up actions (e.g., maintenance or construction activities) will be recorded in the SWPPP logbook.b) Any discrepancies or problems noted in the inspection reports will be corrected in a prompt and appropriate fashion.[Swppp5-3 .dc]Page 21 Revision No. 5.3 4.0 INSPECTIONS [Swppp5 -3. doc] 1) A SWPP Team member will at a mInImum conduct a quarterly visual examination of storm water discharge associated with industrial activity from outfalls 001 and 002. The examination must be made: a) At least once during in each of the following periods: January though March, April through June, July through September, and October through December. b) During daylight hours. c) Ata minimum of30 days from the last examination. d) Within the first 30 minutes (or soon thereafter as practical but not to exceed 1 hour) of when runoff or snowmelt begins discharging. e) Document observations of color, odor, clarity, floating solids, settled solids, suspended solids, foam, oil sheen, and other obvious indicators of storm water pollution. f) During a storm event that is greater than 0.1 inches in magnitude and that occurs at least 72 hours from the previously measurable storm event of greater than 0.1 inches. g) Where practicable, the same individual should carry out the examination of discharges for the entire permit term. 2) The visual examination reports must be maintained on-site in the pollution prevention plan and not sent into the Iowa DNR unless requested. a) The results of these inspections and descriptions of any follow-up actions (e.g., maintenance or construction activities) will be recorded in the SWPPP logbook. b) Any discrepancies or problems noted in the inspection reports will be corrected in a prompt and appropriate fashion. Page 21 Revision No. 5.3 5.0 STORM WATER MONITORING REQUIREMENTS HISTORY 1) On October 1, 1992 the DAEC was issued IDNR Storm Water GeneralPermit No. 1 which authorized storm water discharges from the DAEC.2) On November 30, 1993 the DAEC submitted a request to combine the General Permit No. 1 Storm Water NPDES with the industrial activitydischarge off-site NPDES Permit 5700104. Storm water applicationmonitoring parameters on Form 2F included: Biological Toxicity Testing, oil and grease, BOD5, COD, TSS, Total Kjeldahl Nitrogen, nitrate-nitrite nitrogen, total phosphorus, pH, total residual chlorine, Hexavalent Chromium, Total Chromium, Total Zinc, temperature, sulfate, and surfactants.

3) On January 24, 1994, the IDNR approved the request and included the"Storm Water Discharge Requirements" with Permit Amendment to NPDES Permit Number 5700104.4) The IDNR NPDES Permit issued from April 17,1997 to April 15, 2002, had"No Monitoring Required" for storm water monitoring on the monthly NPDES report form.5) The current NPDES permit issued on July 6, 2004 requires the above-mentioned examinations with no reports being sent to the department.

6.0 EMPLOYEE

TRAINING PROGRAM 1) Initial Hazardous Material Handling Training is provided, which is required prior to allowing any worker to handle hazardous material during their job function.2) Advanced Hazmat Training is provided to DAEC Radwaste, Health Physics, Chemistry, Helper, and Environmental personnel so that they may respond to a spill of hazardous material or waste as part of a recognized spillcleanup crew.

3) An annual Advanced Hazmat Requal Training for the spill responders, which is a refresher course to handle spills and preventing pollutants from reaching the Cedar River. This course includes the training requirements for SWPPP and SPCC.4) All site personnel are provided with training on the SWPPP and SPCC programs annually..[Swppp5-.3.

doc]Page 22 Revision No.5. 3 5.0 STORM WATER MONITORING REQUIREMENTS HISTORY 1) On October 1, 1992 the DAEC was issued IDNR Stonn Water General Pennit No. 1 which authorized stonn water discharges from the DAEC. 2) On November 30, 1993 the DAEC submitted a request to combine the General Pennit No.1 Stonn Water NPDES with the industrial activity discharge off-site NPDES Pennit 5700104. Stonn water application monitoring parameters on Fonn 2F included: Biological Toxicity Testing, oil and grease, BOD5, COD, TSS, Total Kjeldahl Nitrogen, nitrate-nitrite nitrogen, total phosphorus, pH, total residual chlorine, Hexavalent Chromium, Total Chromiuni, Total Zinc, temperature, sulfate, and surfactants.

3) On January 24, 1994, the IDNR approved the request and included the "Stonn Water Discharge Requirements" with Pennit Amendment to NPDES Pennit Number 5700104. 4) The IDNR NPDES Pennit issued from April 17,1997 to April 15, 2002, had "No Monitoring Required" for stonn water monitoring on the monthly NPDES report fonn. 5) The current NPDES pennit issued on July 6, 2004 requires the above-mentioned examinations with no reports being sent to the department.

6.0 EMPLOYEE

TRAINING PROGRAM .[Swppp5 -3. doc] 1) Initial Hazardous Material Handling Training is provided, which is required prior to allowing any worker to handle hazardous material during their job function.

2) Advanced Hazmat Training is provided to DAEC Radwaste, Health Physics, Chemistry, Helper, and Environmental personnel so that they may respond to a spill of hazardous material or waste as part of a recognized spill cleanup crew. 3) An annual Advanced Hazmat Requal Training for the spill responders, which is a refresher course to handle spills and preventing pollutants from reaching . the Cedar River. This course includes the training requirements for SWPPP and SPCC. 4) All site personnel are provided with training on the SWPPP and SPCC programs annually . Page 22 Revision No. 5.3 ATTACHMENT 1 PAGE 1 of 2 INVENTORY OF POTENTIALLY EXPOSED MATERIALS Sodium Dechlorination of cooling tower Thiosulfateblowdown water

/ Pumphouse and warehouse 26,000 lbs.used per year No. Pumphouse and warehouse are no fully enclosed.Sulfuric Acid Cooling water treatment / 20,000 gal No.Tank is in a containment and no Outside tank Southeast of tank trucks are in a drive Pumphouse through containment during filling.Cooling water treatment / tank 6,000 gal No.Tank is in a containment and no Sodium inside the Pumphouse tank trucks are in a drive Hypochlorite through containment during filling.Drinking water treatment / 1,000 gal Yes. Tank is in a containment but no Sodium outside tank South of D well tank filling operations have potential for Hypochlorite spills, leaks from tanker or hose.waste water treatment / 55 gal No.Drums are kept inside sewage no Sodium drums in sewage plant drums plant, Domestic water room, and Hypochlorite and warehouse warehouse.Diesel Fuel Fuel for Emergency DG / 40,000 gal Yes. Tank is a UST and trucks are no Underground storage tank tank in a drive through containment Southeast of Turbine Building during filling but overfill vent has potential to spill on the ground.Diesel Fuel Fuel for Aux. Boiler / 50,000 gal Yes. Tank is a UST and trucks are no Underground storage tank tank in a drive through containment South of Turbine Building during filling but overfill vent has potential to spill on the ground.Diesel Fuel Fuel for Diesel Fire Pump / 500 gal Yes. Tank inside building but filling no inside tank at Pumphouse tank operations has potential for spills, leaks from tanker or hose.Diesel Fuel Fuel for TSC Diesel / outside 250 gal Yes. Tank is in a containment but no tank North of Turbine Building tank filling operations have potential for spills, leaks from tanker or hose.Diesel Fuel Fuel for vehicle / outside tank 250 gal Yes. Tank is in a containment but no at petroleum pad tank filling operations have potential for spills, leaks from tanker or hose.Propane Fuel for Aux. Boiler startup / 500 gal Yes. Tank not in a containment but no outsidestorage tank South of tank trucks are in a driveTurbine Building through containment during filling. [Swppp5-3 .doc)Page 23 Revision No. 5.3 ATTACHMENT 1 PAGE 1 of 2 INVENTORY OF POTENTIALLY EXPOSED MATERIALS Dechlorination of cooling tower No. Pumphouse and warehouse are Thiosulfate blowdown water / Pumphouse fully enclosed. and warehouse Sulfuric Acid Cooling water treatment / 20,000 gal No.Tank is in a containment and no Outside tank Southeast of tank trucks are in a drive Cooling water treatment! tank 6,000 gal no Sodium inside the Pump house tank containment Drinking water treatment! 1,000 gal no outside tank South of Dwell tank waste water treatment! 55 gal No. Drums are kept inside sewage no drums in sewage plant drums plant, Domestic water room, and and warehouse warehouse. Diesel Fuel Fuel for Emergency DG ! 40,000 gal Yes. Tank is a UST and trucks are no Underground storage tank tank in a drive through containment Southeast of Turbine Building during filling but overfill vent has on the Diesel Fuel Fuel for Aux. Boiler / 50,000 gal Yes. Tank is a UST and trucks are no Underground storage tank tank in a drive through containment South of Turbine Building during filling but overfill vent has on the Diesel Fuel Fuel for Diesel Fire Pump / 500 gal Yes. Tank inside building but filling no inside tank at Pumphouse tank operations has potential for spills, leaks from tanker or hose. Diesel Fuel Fuel for TSC Diesel! outside 250 gal Yes. Tank is in a containment but no tank North of Turbine Building tank filling operations have potential for leaks from tanker or hose. Diesel Fuel Fuel for vehicle! outside tank 250 gal no at petroleum pad tank Propane Fuel for Aux. Boiler startup / 500 gal Yes. Tank not in a containment but no outside* storage tank South of tank trucks are in a drive Turbine Building through containment during filling. [Swppp5 -3. doc} Page 23 Revision No. 5.3 ATTACHMENT 1 PAGE 2 of 2 INVENTORY OF POTENTIALLY EXPOSED MATERIALS Gasoline Fuel for vehicle / outside tank at petroleum pad boo gal tank Yes. lank is in a containment but filling operations have potential for spills, leaks from tanker or hose.no Transformer Oil Electric insulating fluid in approx. Yes. Possible exposure from no electrical transformers and 120,000 gal transformer and circuit breaker circuit breakers/ Switch Yard stored leaks. Filling and draining and substations operations have potential for spills, leaks from tanker or hose.Equipment Lubrication / 55 gal No. Drums are kept inside no Oil drums in Petroleum Product drums building.Storage Building and warehouse Used Oil Used oil / Petroleum Pads 55 gal No. Drums are kept inside a no drums containment. Used Oil Used oil / Breathing Air one 55 gal No. Drum is kept inside a no Building drum building.Used Oil Used oil / Machine Shop one 55 gal No. Drum is kept in inside a no drum building.Used Solvent Used Solvent / Machine Shop one 55 gal No. Drum is kept in inside a no drum building.Glycol/Antifreeze Antifreeze / Rx Building 3rd 1700 gal No. Cooling coils are in a no Floor building and drain goes to Transformer Pit.Glycol/Antifreeze Antifreeze / West of Training 550 gal Yes. Air conditioning units are in yes Center. concrete enclosures with fenced 4/03/95 entrance but equipment failure see Att-2 may result in spills or leakage.Glycol/Antifreeze Antifreeze / North of 300 gal No. Air conditioning units are in a no Instrument Air Compressor containment. Building Glycol/Antifreeze Antifreeze / South of Rx 30'gal Yes. Air condition unit is outside no Building and equipment failure may result in spills or leakage. -Glycol/Antifreeze Antifreeze / inside Pumphouse 20 gal No. Cooling coils are in a no in 1P-49 Diesel Fire Pump building and drain goes to Room Transformer Pit.[Swppp5 -3. doc Page 24 Revision No. 5.3 ATTACHMENT 1 PAGE 2 of 2 INVENTORY OF POTENTIALLY EXPOSED MATERIALS Gasoline Fuel for vehicle / outside tank 500 gal Yes. Tank is in a containment but no at petroleum pad tank filling operations have potential for spills, leaks from tanker or hose. Transformer Oil Electric insulating fluid in approx. Yes. Possible exposure from no electrical transformers and 120,000 gal transformer and circuit breaker circuit breakers/ Switch Yard stored leaks. Filling and draining and substations operations have potential for leaks from tanker or hose. Equipment Lubrication / 55 gal No. Drums are kept inside no Oil drums in Petroleum Product drums building. Storage Building and warehouse Used Oil Used oil/Petroleum Pads 55 gal No. Drums are kept inside a no drums containment. Used Oil Used oil/Breathing Air one 55 gal No. Drum is kept inside a no drum Used Oil Used oil/Machine Shop one 55 gal no drum Used Solvent Used Solvent / Machine Shop one 55 gal no drum Glycol! Antifreeze Antifreeze / Rx Building 3rd 1700 gal No. Cooling coils are in a no Floor building and drain goes to Transformer Pit. Glycol! Antifreeze Antifreeze / West of Training 550 gal Yes. Air conditioning units are in yes Center* concrete enclosures with fenced 4/03/95 entrance but equipment failure see Att-2 result in or Glycol! Antifreeze Antifreeze / North of 300 gal No. Air conditioning units are in a no Instrument Air Compressor containment. Glycol! Antifreeze Antifreeze / South of Rx . 30 gal Yes. Air condition unit is outside no Building and equipment failure may result in or G lyco l! Antifreeze Antifreeze / inside Pumphouse 20 gal No. Cooling coils are in a no in 1P-49 Diesel Fire Pump building and drain goes to Room Transformer Pit. [Swppp5 -3. doc] Page 24 Revision No. 5.3 ATTACHMENT 2 PAGE 1 of 2 REPORTABLE QUANTITY RELEASE REPORT 1) On Monday, April 3, 1995, at 0930 hours, a release of approximately 50 gallons of ethylene glycol and water was discovered by JES Duane Arnold Energy Center (DAEC)personnel. Subsequent analysis identified the concentration as 43% ethylene glycol and 57%water. The weather at the time of discovery was dry, partly sunny, windy and between 40 to 50 degrees F.It is believed that a small animal (raccoon) manipulated a glycol loop line vent valve (as observed by small teeth and scratch marks on the valve rubber handle) and caused a small release to occur over several days. Discovery occurred as a contractor hired to maintain the system noticed a loss of glycol/water mixture from the system and had to replenish level (see the written follow-up report to the Iowa Department of Natural Resources "Report of Hazardous Condition"). The release location was at the DAEC Training Center, 3363 DAEC Road, 3 miles north of Palo,Iowa. The release was contained entirely on the facility site and did not result in an immediate or potential danger to the public health or safety. It is believed that no storm water runoff occurred from this event-as all released mixture was collected in an adjacentfrench drain gravel bed.The following Corrective Actions have been implemented to prevent reoccurrence:

• Glycol loop vent lines fitted with plugs, and* Glycol loop vent line valve handles removed.2) On Saturday, February 19th, 2000, at 11:30 hours, Duane Arnold Energy Center personnelcreated sheen of gasoline on the Cedar River. The release occurred when personnel were retrieving a gasoline-powered snowblower, which had fallen into the river. The sheen was created when the primer cover came off the primer bowl which houses approximately 10 cc's of gasoline.

The gasoline was quickly carried downstream before the personnel could get any spill and clean-up material to absorb the spill. The snowblower was recovered a short time later with no further releases occurring. The location of the spill was between the DAEC intake structure and the NPDES discharge canal, along the Red Cedar River. Personnel were removing heavy snow build-up for the security department when the incident happened. Reports were made to theappropriate authorities. To prevent any recurrences of this nature personnel will no longer use snowblowers on the edge of the embankment and will shovel the snow by hand.[Swppp5 -3. doc]Page 25 Revision No. 5.3 ATTACHMENT 2 PAGE 1 of2 REPORTABLE QUANTITY RELEASE REPORT 1) On Monday, April 3, 1995, at 0930 hours, a release of approximately 50 gallons of ethylene glycol and water was discovered by IES Duane Arnold Energy Center (DAEC) personnel. Subsequent analysis identified the concentration as 43% ethylene glycol and 57% water. The weather at the time of discovery was dry, partly sunny, windy and between 40 to 50 degrees F. It is believed that a small animal (raccoon) manipulated a glycol loop line vent valve (as observed by small teeth and scratch marks on the valve rubber handle) and caused a small release to occur over several days. Discovery occurred as a contractor hired to maintain the system noticed a loss of glycol/water mixture from the system and had to replenish level (see the written follow-up report to the Iowa Department of Natural Resources "Report of Hazardous Condition"). The release location was at the DAEC Training Center, 3363 DAEC Road, 3 miles north of Palo, Iowa. The release was contained entirely on the facility site and did not result in an immediate or potential danger to the public health or safety. It is believed that no storm water runoff occurred from this event-as all released mixture was collected in an adjacentfrench drain gravel bed. The following Corrective Actions have been implemented to prevent reoccurrence:

• Glycol loop vent lines fitted with plugs, and
• Glycol loop vent line valve handles removed. 2) On Saturday, February 19 th , 2000, at 11 :30 hours, Duane Arnold Energy Center personnel created sheen of gasoline on the Cedar River. The release occurred when personnel were retrieving a gasoline-powered snowblower, which had fallen into the river. The sheen was created when the primer cover came off the primer bowl which houses approximately 10 cc's of gasoline.

The gasoline was quickly carried downstream before the personnel could get any spill and clean-up material to absorb the spill. The snowblower was recovered a short time later with no further releases occurring .. The location of the spill was between the DAEC intake structure and the NPDES discharge canal, along the Red Cedar River. Personnel were removing heavy snow up for the security department when the incident happened. Reports were made to the appropriate authorities. To prevent any recurrences of this nature personnel wili no longer use snowblowers on the edge of the embankment and will shovel the snow by hand. [Swppp5 -3. doc] Page 25 Revision No. 5.3 ATTACHMENT 2 PAGE 2 Of 2 3) On June 12, 2002 at 10:15 hours, a release of less than 1 pint of vegetable oil created asheen on the Cedar River at Duane Arnold Energy Centers intake structure. The release occurred when contracted employees were using a hydraulic driven pump to clean out the weir area of the intake structure. The sheen was created when a set of fittings/seals on thepump failed and developed a leak. The sheen was quickly carried downstream before personnel could implement spill clean-up procedures. The pump was quickly shut off and removed from service in the Cedar River. The spill was reported to the EPA, Iowa DNR, and Linn County Sheriffs office at 11:30.A 1-hour delay in making the report was due to the involved personnel determining if the hydraulic oil used in the pump Was petroleum based or a vegetable oil. The site could not make a determination so it was reported. As a follow-up conversation with the EPA it has been directed to DAEC the oil type does not matter. Both types of oil create a sheen and require a spill notification. To prevent any recurrences of this nature DAEC will no longer use hydraulic driven pumps for this activity, electric pumps will be required for future intake structure work.4) On September 19, 2003 at 1555 hours, a release of less than 1 gallon of diesel fuel created a sheen on the Cedar River at Duane Arnold Energy Center. The release occurred when a contracted employee was using a dredging unit to remove sand/sedimentation upstream from the Intake Structure. The sheen was created when the dredging operator was overfilled his fuel tank with diesel fuel. The majority of the fuel spilled was cleaned up onthe dredging decking but some of it made it's way down the side into the river. The incident occurred in a no-flow area of the river, due to the configuration of an exposed sandbar. The upstream sandbar extended from the riverbank on the west side to the center of the river and downstream two hundred feet, thus surrounding the dredging unit and fuel spill. DAEC's spill responseteam quickly positioned a roll of absorbent material enclosing the sheen, preventing it from being released downstream. Clean-up efforts continued on September 20, 2003 until the sheen was completely removed from the river.The spill was reported to the EPA, Iowa DNR, and Linn County Emergency Planning Commission. To prevent recurrences of this nature the contracted employee will not allow any other activities to take place while he is filling the dredging unit's fuel tank. The operator's attention will be focused on the refueling evolution. [Swppp5-3 .doc]Page 26 Revision No. 5.3 ATTACHMENT 2 PAGE 2 Of2 3) On June 12,2002 at 10:15 hours, a release ofless than 1 pint of vegetable oil created a sheen on the Cedar River at Duane Arnold Energy Centers intake structure. The release occurred when contracted employees were using a hydraulic driven pump to clean out the weir area of the intake structure. The sheen was created when a set of fittings/seals on the pump failed and developed a leak. The sheen was quickly carried downstream before personnel could implement spill clean-up procedures. The pump was quickly shut off and removed from service in the Cedar River. The spill was reported to the EPA, Iowa DNR, and Linn County Sheriffs office at 11 :30. A I-hour delay in making the report was due to the involved personnel determining if the hydraulic oil used in the pump was petroleum based or a vegetable oil. The site could not make a determination so it was reported. As a follow-up conversation with the EPA it has been directed to DAEC the oil type does not matter. Both types of oil create a sheen and require a spill notification. To prevent any recurrences ofthis nature DAEC will no longer use hydraulic driven pumps for this activity, electric pumps will be required for future intake structure work. 4) On September 19, 2003 at 1555 hours, a release ofless than 1 gallon of diesel fuel created a sheen on the Cedar River at Duane Arnold Energy Center. The release occurred when a contracted employee was using a dredging unit to remove sand/sedimentation upstream from the Intake Structure. The sheen was created when the dredging operator was overfilled his fuel tank with diesel fuel. The majority of the fuel spilled was cleaned up on the dredging decking but some of it made it's way down the side into the river. The incident occurred in a no-flow area of the river, due to the configuration of an exposed sandbar. The upstream sandbar extended from the riverbank on the west side to the center of the river and downstream two hundred feet, thus surrounding the dredging unit and fuel spill. DAEC's spill response-team quickly positioned a roll of absorbent material enclosing the sheen, preventing it from being released downstream. Clean-up efforts continued on September 20, 2003 until the sheen was completely removed from the river. .. The spill was reported to the EPA, Iowa DNR, and Linn County Emergency Planning Commission. To prevent recurrences of this nature the contracted employee will not allow any other activities to take place while he is filling the dredging unit's fuel tank. The operator's attention will be focused on the refueling evolution. [Swppp5 -3. doc] Page 26 Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D. 11 a DAEC 2006, System

Description:

Cooling Towers and Circulating Water System. SD-442. Revision 5. October.Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 0.11 a OAEC 2006, System

Description:

Cooling Towers and Circulating Water System. SO-442. Revision 5. October. DUANE ARNOLD ENERGY CENTER SYSTEM DESCRIPTION Cooling Towers and Circulating Water System SD-442 Rev. 5 Reviewed by: Reviewed by: Reviewed by: System Enginer.Operations OperationO raining -M Date Date Date Rev. 5 SD_442.doc -" "' " ... ). -Cooling Towers and Circ Water SEE REV. -i-DATED-.DUANE ARNOLD ENERGY CENTER SYSTEM DESCRIPTION Cooling Towers and Circulating Water System SD N 442 Rev.S . System Engine <::: Reviewed by: Reviewed by: Rev.S SD_442.doc Operations , 10-09 -200.(;. Date Date /lJJ/Ob Date J TABLE OF CONTENTS P U R P O S E ............................................ ............................ .................................................... 5D E S IG N B A S E S ............................................................................ ........................................... 5 SYSTEM DESCRIPTION .... .............. .......................... 5 M A JO R C O M P O N E N T S ............................................................... ............ ................. .... ....... 6 C irc W ater P um p P it ...................................................................................... ..6 C irculating W ater Pum ps ................................................................................ 7 Circulating Water Pump Vent Valves ............................................................... 9 Circulating Water Pump Discharge Valves ............ -............................. 9 Main Condenser Circ Water Inlet isolation Valves ......................................... 10 Main Condenser Circ Water Outlet Isolation Valves...................................... 11 C irculating W ater Drain Pum p ........................................................................ 12 Cooling Tower Inlet and Sparging Valves ......................... .12 Cooling Towers and Fans ......................................... 13 C ooling Tow er Basin ...................................................................................... 14 N O R M A L O P ER A TIO N .................................................................................................... ..15 Starting And Stopping A Circ Water Pump ................................................... 16 A BNO R M AL O PERA TIO N ................................................................................................. 17 Isolating a Circulating Water Loop -Inner or Outer ........................ 17 SYSTEM INTERRELATIO NS ............................................................................................ 18 M ain C ondenser ......................... .. ............................................................. ..18 Residual Heat Removal Service Water ............................ 18 Em ergency Service W ater ............................................................................. 19 General Service Water ...................................... 19 Liquid Radwaste System .......................................... -9 River Water Supply System .......................................................................... 19 W ell W ater S ystem ...................................................................................... ..20 Cooling Water Treatment System ................................................................. 20 Instrument and Service Air System ......................................... 20 Makeup Demineralizer System...................................................................... 20 A cid Feed S ystem ........................................................................................ ..2 1 Rev. 5 Cooling Towers and Circ Water SD_442.doc ./ TABLE OF CONTENTS PURPOSE ................................................................................................................................... 5 DESlGN BASES ......................................................................................................................... 5 SYSTEM DESCRIPTION ..................................................

....... * ...................................................

5 MAJOR COMPONENTS ..........................................................................

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

6 eire Water Pump Pit ................................................................................................ 6 Circulating Water Pumps ...................................................................................... 7 Circulating Water Pump Vent Valves .................................................................... 9 Circulating Water Pump Discharge Valves ........................................................... 9 Main Condenser eire Water Inlet Isolation Valves .............................................. 10 Main Condenser eirc Water Outlet Isolation Valves ........................................... 11 Circulating Water Drain Pump ............................................................................ 12 Cooling Tower Inlet and Sparging Valves ........................................................... 12 Cooling Towers and Fans ................................................................................... 13 Cooling Tower Basin ........................................................................................... 14 NORMAL OPERATION ............................................................................................................ 15 Starting And Stopping A eire Water Pump ....................

.... , ...............................

16 ABNORMAL OPERATION ...............................

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

17 Isolating a Circulating Water Loop -Inner or Outer ............................................ 17 SYSTEM INTERRELATtONS ................................................................................................... 18 Main Condenser....................... ..... . ................................................................... 18 Residual Heat Removal Service Water ...............................

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

18 Emergency Service Water .................................................................................. 19 General Service Water ......................................................................................... 19 Liquid Radwaste System ..................................................................................... 19 River Water Supply System ................................................................................ 19 Well Water System ............................................................................................. 20 Cooling Water Treatment System ....................................

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

20 Instrument and Service Air System ...........................................................

.........

20 Makeup Oemirleralizer System ...........................

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

20 Acid Feed System ............................................................................................... 21 Rev. 5 SD_442.0DC

• 2 .Cooling Towers and Cire Wawl' R E F E R E N C E S .........................................................................................................................

2 2 RS _,ev. 5 3D-,42.doc .3*Cooling Towers and Circ Water REFERENCES ......................................................................................................................... 22 He\*.5 SD_*142.doc .Cooling Towers nntl eire Water LIST OF ILLUSTRATIONS FIGURE 1: Basic Circ Water Flowpath ......................................................................... 24 FIGURE 2: Circ Water Pump, Discharge Valve, Vent Valve ........................ 25 FIGURE 3: Inlet and Outlet Isolation Valves ................................................................ 26 FIGURE 4: Inlet Valve Cam Lock ............................................................................. 26 FIGURE 5: Drain Pump Loop ...................................................................................... 28 FIGURE 6: Circ Water System Makeup ...................................................................... 29 FIGURE 7: System Inter-Connections ......................................................................... 30 R e 4 .C lnr, Towers an,d (i,,' W , SD_,142,doc I UST OF ILLUSTRA TraNS FIGURE 1: Basic eire Water Flowpath .......................................................................... , .. 24 FIGURE 2: Cire Water Pump, Discharge Valve, Vent Valve ............................................ 25 FIGURE 3: Inlet and Outlet Isolation Valves ..................................................................... 26 FIGURE 4: Inlet Valve Cam Lock ..................................................................................... 26 FIGURE 5: Drain Pump Loop ........................................................................................... 28 FIGURE 6: Circ Water System Makeup ........................................................................... 29 FIGURE 7: System Inter-Connections .......... , ................................................................... 30 Re\-*. ;) SD_'H2.doc

• 4 .Cooling Towers and eire Water Cooling Towers and Circulating Water System PURPOSE The principal function of the Cooling Towers and Circulating Water System is to: rn Provide a continuous supply of cooling water to remove the heat rejected to the main condenser.

0 Remove the heat energy rejected from the plant cycle through the action of the cooling towers.DESIGN BASES Circulating Water System is designed to circulate the flow required to remove the design heat load from the Main Condenser. 0 Circulating Water System is designed to operate on a closed cycle using induced-draft Cooling Towers, H Cooling Towers are designed to remove the heat load of the circulated flow under all predicted weather conditions. SYSTEM DESCRIPTION The Circulating Water System provides water from the Circ Water Pump pit to the Main Condenser (High and Low Pressure) to absorb heat from the Main Turbine exhaust. The CIrculating Water flowpaths through the Low "ressure and High Pressure Condensers are designated the Inner Loop and the Outer Loop. The heated water leaves the condenser and moves to the Cooling Towers to transfer the heat to the environment. The tower-cooled water returns to the Circ Water Pump pit by gravity and the cycle begins again. During normal plant operation both Circulating Water pumps and both Cooling Towers are in service.R55 -Cooling Towers and Circ Water.SD4,,12.doc / Cooling Towers and Circulating Water System PURPOSE Thp, principal function of the Cooling Towers and Circulating Water System Is to: n Provide a continuous supply of cooling water to remove the heat rejected to the main condenser. [) Remove the heat energy rejected from the plant cycle through the action of the COOling towers. DESIGN BASES Circulating Water System is designed to circulate the flow required to remove the design heat load from the Main Condenser. o Circulating Water System is designed to operate on a closed cycle using induced-draft Cooling Towers. r1 I I Cooling Towers are designed to remove the heat load of the circulated flow under all predicted weather conditions. SYSTEM DESCRIPTION The Circulating Water System provides water from the Cire Water Pump pit to the Main Condenser {High and Low Pressure) to absorb heat from the Main Turbine exhaust. The Water flowpaths through the Low ressure and High Pressure Condensers are (jesignated the Inner Loop and the Outer Loop. The heated water leaves the condenser and moves to the Cooling Towers to transfer the heat to the environment The lower-cooled water returns to the Cire Water Pump pit by gravity and the cycle begins again. During normal plant operation both Circulating Water pumps and both Cooling Towers are in service. Rev. 5 SD_<l4!.!.doc

• 5 *Cooling Towers and eire Water MAJOR COMPONENTS The major components of the Cooling Towers and Clrc Water System are: El Circ Water Pump Pit O Circulating Water Pumps n Circulating Water Pump Vent Valve 0 Circulating Water Pump Discharge Valve Low Pressure Condenser Inlet Isolation Valves High Pressure Condenser Outlet Isolation Valves E Circulating Water Drain Pump nI Cooling Towers and Fans El Cooling Tower Inlet Valves 9 Cooling Tower Basin Circ Water Pump Pit The Circ Water Pump Pit provides the source of water circulated in the Cooling Tower and Circulating Water System. The Cooling Tower basin supplies water to the Circ Water Pump pit by gravity. Makeup for cooling tower evaporation is supplied to the Circ Water Pumphouse Stilling Basin by the River Water System and/or the Well Water System based on the water level in the cooling tower basin. Water in the Circ Water Pumphouse Stilling Basin enters the Circ Water Pump Pit through a standpipe that connects the two compartments, During full power operation, the level in Circ Water Pump Pit is normally 22 feet. During pump starts, Circ Water Pump Pit level may sustain a temporary drop of up to 6 feet. A low water levetl in the Circ Water Pump Pit is alarmed at 18 feet (Panel 1C06A-D11).

The low water level condition prevents starting either Circ Water Pump, but does not trip any running Circ Water Pump. The start interlock prevents pump cavitation following startup.Rei. 5 *Cocting Towers and Cire Water S1L442.doc MAJOR COMPONENTS The major components of the Cooling Towers and Glre Water System are: D CiTe Water Pump Pit o Circulating Water Pumps [J Circulating Water Pump Vent Valve o Circulating Water Pump Discharge Valve , Low Pressure Condenser Inlet Isolation Valves i High Pressure Condenser Outret Isolation Valves -C Circulating Waler Drain Pump n Cooling Towers and Fans [) Cooling Tower Inlet Valves o Cooling Tower Basin Cire Water Pump Pit The Cire Water Pump Pit provides the source of water circulated in the Cooling Tower and Circulattng Water System. The Cooling Tower basin supplies water to the Cire Water Pump pit by gravity. Makeup for cooling tower evaporation is supplied to the eire Water Pumphouse Stilling 8asin by the River Water System and/or the Well Water System based lev.el in the cooling tower basin. Water in the Cire Water Pumphouse Stilling Basin enters the Cire Water Pump Pit through a standpipe that connects the two compartments. During full power operation, the level in Cire Water Pump Pit is normally 22 feet Outing pump starts, eire Water Pump Pi! Jevel may sustain a temporary drop of up to 6 feet. A low water levet! in the Cire Water Pump Pit is alarmed at 18 feet (Panel 1 COBA-D11). The low water level condition prevents starting either Cire Water Pump. but does not trip any running Cire Water Pump. The start interlock prevents pump cavitation following startup . Rf.v.5 SD_-l<12.doc . Cooling Towers and eire Water CWP CWP Vent Discharge CWP START CWP TRIP'Jnlve Valve Vatw W42-01 OpnM~.... I r "°°........T.."f0-4201 o .............. ~* pumW r~ecwt O lO,, tt'eVn j.:' VaNY I V Z" 5-42O8C0tflen .i. i{O-423-L"I Gre pef tPut F1 T u S:ndnna.r( .T Closed Trip Cod.e ............... Ck C , 'der P. W .Pit .Ca r Pumps ................ Co"Po /S Start.... ....Tw 0 aaiyJhsnvrtcl ie lw e-i cetiua pup,1P4Aad1P4 Breaker.T.O....... ....... -I S V-4201 KY.I'3 "Cv' HS Wfat Closd #A, :. :: Gon Eneue o TcP.ua STARTeand NORMAFToSiART Shad Watr Fsste T c to Ced ............. pproxima.ely ........... g,,. ......... :.......... , ............... .....,, ...-: ! , .............. .l ct " l c Vaner 1ump A P04 oCic-

prC 1 e v Ptaker Cmospr todprevent condensationr

it wi..dins.when.he pumpis.idl.

Th.08..spc.e.es .r.owrdfrmlih.g.ae Circulating WaterrPumps Two 50% capacity Johnson vertical, mixed flow, wet-pit centrifugal pumps, rP-4A and 1ePr.4 are used to circulate water in the Cooling Tower and Circulating Water system. The pumps are located approximately 250 feet east of the Turbine Building and provide 150,000 gpm at 88 ft.totap head. and 356 rpm. The 3800 horsepower GE pump motors are powered from 4160 VAC load centers 1A1 and 1A2. Circ Water Pump breaker control power is from 125 VDC 1D11 and 1 D2.1 respectively. Pump motor space heaters -energize 'to prevent condensation in the motor wi-dings when the pump is idle. The 208 VAk, space heaters are powered from lighting panel 11iL10.Circulating Water pump 1P..4A (B) is controlled by STOP-NORMAL-START, spring return to NORMAL, handswitch HS-4201 (HS-4202) on Control Room Panel 1CG06, Pump breaker status for (green), running (red) and spring charged (white) is available at Panel. 1C06. The purnip start sequence starts the pump and then opens the pump discharge valve. The pump stop sequence shuts the pump discharge valve and then trips the pump.in order to start a Circ Water Pump, the LP Condenser Inlet Isolation valves (MO-4257 and MO-4258) must be verified open at the local control panel and the following electrical interlocks satisfied: Rev.7 ,Cooling Towers and Cite Water SD_442.doc CWP Vent P\r.1 p v.,.... Opet\ CWP Discharge Valve CWP START p..mp Br!2.cr .. \ .. .. :

Eno,;

. ; ;; TDPu : ST.Mfl and NO'lMAFT START tOCh1'iC" ;: \ ................. . : .. ---... -...... r

.. &taker Cloged ; .............................. Circulating Water Pumps CWPTRIP .... t ..... ,. ...... ... t, : """'P : ;= :: .

............. ........ = ****1 .... r': Ii r ! r . . ...............

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"' ....... Two 50% capacity Johnson vertical. mixed flow, wet-pit centrifugal pumps, 1 P-4A and 1 P4B are used to circulate water in the Cooling Tower and Circulating Water system. The pumps are located approximately 250 feet east of the "Turbine Building and provide 150,000 gpm at 88 ft. total head. and 356 rpm. The 3800 horsepower GE pump motors are powered from 4160 VAC load centers 1A1 and 1A2. CircWaterPump breaker control power is from 125VDC 1011 and 1 D21 respectively. Pump motor space healers energize to prevent condensatibnih the' niotor' wit1dings when the pump is idle. The 208 VA'v space heaters are powered from lighting panel t'L 10. Circulating Water pump 1 P-4A (8) is controUed by STOP-NORMAL-START, spring return to NORMAL, handswitch HS*4201 (HS-4202) on Control Room Panel 1 C06. Pump breaker status for s:topped (green), running (red) and spring charged (white) is available at Pane11C06. The pump start sequence starts the pump and then opens the pump discharge valve. The pump stop sequence shuts the pump discharge valve and then trips the pump. In order to start a Circ Water Pump, the LP Condenser Inlet Isolation valves (M0-4257 and MO-42S8) must be verified open at the local control panel and the following electrical interlocks satisfied:

, SD_4iJ2.doc "

• I *Cooling Towers and eire Water Dl The CW pump discharge valve closed (HO-4201 or HO-4202)D The CW pump vent valve open (CV-4201 -or CV-4202)EL Both HP Condenser Outlet Isolation valves open (MO-4208 and MO-4209)f7 Circ Water Pump pit level above 18 feet If a Condenser Circ Water Loop is isolated, then any non-running Circ Water Pump is prevented from starting by the HP Condenser Outlet Isolation valve interlock.

Isolating , Condenser Circ Water Loop will not trip any running Circ Water Pumps.A circulating water pump breaker will trip on any of the following: Fj Overcurrent 0 Ground Fault D Phase differential overcurrent n Non-essential bus load shedding @ 65% of rated bus voltage[1 Discharge valve full closed anytime after 3 minutes of pump operation (normal shutdown method)Annunciators, on Panel 1C06-A, associated with Circ Water Pumps are: 0 "A" CIRC WATER PUMP IP-4A TRIP OR MOTOR OVERLOAD (A-10)[3 "B" CIRC WATER PUMP 1P-4B TRIP OF MOTOR OVERLOAD (A-11)0 "A" CIRC WATER PUMP 1P-4A HI VIBRATION (B-10)D_ "B" CIRC WATER PUMP 1P-41 HI VIBRATION (B-11)Roy. 5

• 8 -Cooling Towers and Circ Water SD j42.doc o The CW pump discharge valve c10sed (HO*4201 or HO-4202) o The CW pump vent valve open (CV*4201-or CV-4202) D 80th HP Condenser Outlet Isolation valves open (MO-42GB and MO*4209) (1 eire Water Pump pit level above 18 feet If a Condenser Cire Water Loop is isolated, then any non-running Cire Water Pump is prevented from starting by the HP Condenser Outlet Isolation valve interlock.

Isolating ..... Condenser Circ Water Loop will not trip any running eire Water Pumps. A circulating water pump breaker will trip on any of the following: rJ Overcurrent o Ground Fault o Phase differential over current n Non-essential bus load shedding @ 65% of rated bus voltage o Discharge valve full closed anytime after 3 minutes ot pump operation (normal shutdown method) Annunciators, on Panel 1 C06-A, assoclated with eire Water Pumps are: o UN CIRC WATER PUMP 1P-4A TRIP OR MOTOR OVERLOAD (A-10) o "8" eIRe WATER PUMP 1P-4B TRIP Ok MOTOR OVERLOAD (A-11) o "An CIRC WATER PUMP 1P-4A HI VIBRATION (8-10) !J "B" elRC WATER PUMP 1P-4B HI VIBRATION (8-11) Rev.5. SD_'142.ooc

• 8 ,Cooling Towers nnd eire Water Circulatinq Water Pump Vent Valves A 4-inch air operated butterfly valve Is at the discharge vent of each pump, The solenoid valve thal controls motive air, for the vent valve Is controlled by the discharge valve open position limit swiftch. The vent valve solenoid receives power from Instrument AC Control Power 1Yl 1 and 1Y21. Instrument and Service Air are required for the vent valve to remain in the closed position.Circulating Water Pump Dischargqe Valves A 78-inch electro-hydraulically operated butterfly valve, H0-4201 and HO-4202 is at the discharge of each pump. The 78-inch discharge valves are operated using 2100 psig hydraulic oil from hydraulic power unit IS-92A and 1S-92B. The valves are designed to open within 175 sK"conds and close in 20 seconds. Timers used by the discharge valve control circuit receive power from Instrument AC Control Power IY11 A and IY21B.Heeren Co. hydraulic power unit consist of a 2 horsepower 480 VAC, 3 phase, 60 cycle motor powered from 480 VAC MCC 1813 (1B23) operating at 1800 rpm. The pumps start at 2000 psig Pressure lowering.

Annunciator on Panel IC07A (C-8). CIRO WATER VALVE HO-42011H0-4202 HYDRAULIC OIL LO PRESSURE, alarms at 1800 psig (lowering) to alert personnel. Each system accumulator has the capacity to stroke the valve at least twice. System relief valves protect the components from damage with a setting of 2250 psig. Hydraulic pressure is required for the discharge valve to remain open.Rev, 5 -9 Cootiiig Towers and Circ Water SD-4,2.doc Circulating Water Pump Vent Valves A 4-inch air operated butterfly valve Is at the discharge vent of each pump. The solenoid valve tha1 controls motive air for the vent valve is controlled by the discharge valve open position limit The vent valve solenoid receives power from Instrument AC Control Power .1Y11 and 1 Y21. Instrument and Service Air are required for the vent valve to remain in the closed position. Circulating Water Pump Discharge Valves A l8-inch operated butterfly valve, H0-4201 and H0-4202 is at the discharge of each pump. The 78-inch discharge valves are operated using 2100 pSig hydraulic oil from hydraulic power unit 1S*92A and 1S-92B. The valves are designed to open within 175 SJccnds and dose in 20 seconds. Timers used by the discharge valve control circuit receive power from Instrument AC Control Power 1Y11A and 1Y21B. Heeien Co. hydraulic power unit consist of a 2 horsepower 480 VAC, 3 phase, 60 cycle motor powered from 480 VAC MCC 1613 (1823) operating at 1800 rpm. The pumps start at 2000 psig pressure lowering. Annunciator on Panel 1 C07 A eiRe WATER VALVE HO-4201fHO-4202 HYDRAULIC OIL La PRESSURE, alarms at 1800 psig (lowering) to alert personnel. Each system accumulator has the capacity to stroke the valve at least twice. System relief valves protect the components from damage with a setting of 2250 psig. Hydrau!ic pressure is required for the discharge valve to remain open. Rev. 5 SD_442.doc -!) .Cooling Towers lind Cire Water Inlet Isolation Valve ,.OC A .EMoTEJ_H$ S, LOCAL -r Outlet Isolation Valve CWP A Off C WP B Off HS in CLOSE 42-0 HS in OPEN LS -'-t-LS HS in CLOSE Intet Valve Intet Valve Close Coil Open Coil Outlet Valve Outlet Valve Close Coil Open Coil Main Condenser Circ Water Inlet Isolation Valves Two 90 inch motor operated butterfly valves (MO-4257 Outer Loop and MO-4258 Inner Loop)are located at the low pressure condenser inlet for isolation purposes. Each condenser inlet.solation valve is controlled by a local OPEN -NORMAL-CLOSE, spring return to NORMAL handswitch (HS-4257 and HS-4258) in the TB 734' Condenser Bay. The control circuit for each'Jow pressure Condenser inlet isolation valve is isolated by a local LOCAL-OFF-REMOTE keylock switch (HS-4257A and HS-4258A) at the same panel as HS-4257 and HS-4258. Valve position is only available locally. The power st'uply for MO-4257 and MO-4258 is 480 VAC MCC 11B62.Rev. 5 SD) 442.duc-10.Cooling Towers and Circ Water Inlet Isolation Valve lOCAL.REMOTU= .1 :,5 II, LOCAL T..--J HS in CLOSE p 'q HS in OPEN 42-0 42-C In!et Valve Close Coil 42-0 Inlet Valve Open Coil Outlet Isolation Valve C'NP A Ott CWP B ott , ** *** , * ******* t,. ................

Pump . : PGrmlSwIJ HS .42*C

..... HSinClOSE p q 42*0 LS ' LS Outlet Valve Crose Coif lS , 42-C 42-0 Outlet Valve Open Coil Main Condenser eire Water Inlet Isolation Valves Two 90 inch motor operated butterfly valves (MO-4257 Outer Loop and MO-4258 Inner Loop) are located at the low pressure condenser inlet for isolation purposes. Each condenser inlet ;solation valve is controlled by a local OPEN -NORMAL*CLOSE. spring retum to NORMAL handswitch (HS-4257 and HS-42S8) in the TB 734' Condenser Bay. The control circuit for each 'low pressure condenser inlet isolation valve is isolated by a local LOCAL-OFF-REMOTE keylock switch (HS-4257 A and HS-4258A) at the same panel as HSA257 and HS*4258. Valve position is only available locally, The power for MO-4257 and MO*4258 is 480 VAC MeC 1862. R(w.5

• 10 *Cooling Towers and Cire Water SD_ 4-l2.uoc XCh Each Inlet isolation valve has a manually actuated cam head locking mechanism.

Normally the c7m head sits in a recession in the valve body and is disconnected from the operating shaft. To lock the valve disk in the closed position, the cam lock is extended by rotating the operating handwheel until the cam head lock and shaft are fully extended. When the cam lock and shaft are fully extended, the key is inserted through the handwheel and shaft to connect the cam lock to the handwheel. The cam lock head is then rotated to the valve disk strike plate in order to lock the isolation valve in the closed position. The cam head lock is pointing at the valve disk strike plate when the arrow on the end of the shaft is pointing to the valve disk. The cam lock can be restrained by either a set screw in the handwheel or a chain-lock arrangement. Removing the cam head lock is basically a reversal of the actions taken to lock the valve.Main Condenser Circ Water Outlet Isolation Valves Two 78 inch motor operated butterfly valves (MO-4208 Outer Loop and MO-4209 Inner Loop)are located at the high pressure condenser OL,;et for isolation purposes. The condenser outlet isolation valves are controlled by CLOSE-NORMAL-OPEN, spring return to NORMAL, hand switches at Panel 1 C06. Power supply for MO-4208 and MO-4209 is 480 VAC MCC I B62. The closing circuit for each motor operated valve (MO4208 and MO-4209) is normally interlocked such that the Circ Water Outlet valve can only be closed when both Circulating Water pump breaers are open. This interlock can be bypassed using Circ Pump Permissive Override handswitch HS-4208A (HS-4209A) when it is necessary to isolate a Circulating Water Loop (Inner or Outer) for maintenance during power operation. Rev. 5 C11 -ooling Towers and Cire Water SD_,142.doc v:w .. o;.,. I !'i1fl\(tPi."\te

• RCHltdltd Each Inlet isolation valve has a manually actuated cam head locking mechanism.

Normally the Cdm head sits in a recession in the valve body and is disconnected from the operating shaft. To lock the valve disk in the closed position. the cam lock is extended by rotating the operating handwheel until the cam head lock and shaft are fully extended. When the cam lock and shaft are fully extended. the key is inserted through the handwheel and shaft to connect the cam lock to the handwheel. The cam lock head is then rotated to the valve disk strike plate in order to lock the isolation valve in the closed position. The cam head lock is pointing at the valve disk strike plate when the arrow on the end of the 'shaft is pointing to the valve disk. The cam lock can be restrained by either a set screw in the handwheel or a chain-lock arrangement. Removing the cam head lOCK is basically a reversal of the actions taken to lock the valve. Main Condenser eire Water Outlet Isolation Valves T'N!O 78 inch motor operated butterfly valves (MOA208 Outer Loop and MO-4209 Inner Loop) are located at the high pressure condenser OL .i8t for isolation purposes. The condenser outlet isolation valves are controlled by CLOSE-NORMAL-OPEN, spring return to NORMAL, hand sWitches at Pane11C06. Power supply for MO-4208 and M0-4209 is 480 VAC MCC 1B62. The closing Circuit for each motor operated valve (M0-4208 and MO*4209) is normally interlocked such! that the Cire Water Outlet valve can only be closed when both Circulating Water pump breail<ers are open. This interlock can be bypassed using eirc Pump Permissive Override hancswitch HS-420BA (HS-4209A) when it is necessary to isolate a Circulating Water Loop (Inner or Ouler) for maintenance during power operation. 5 SD_'142.doc

• 11 *Cooling Towers and Cite Wnter 0.ter Low Circulating Water Drain Pump A Gould horizontal centrifugal pump with the capacity of 650 gpm at an 80 ft head at 1750 rpm is provided to drain the condenser water boxes for servicing.

The drain pump, 1 P-7, is a 20 horsepower 48OVAC, 3 phase 60 Hz powered from MCC 1B33. The drain pump is controlled by local STOP-START pushbuttons, HS-4210, and provided with indicating lights, pump stopped (green) and pump running (red). During partial Condenser Circ Water Loop isolation conditions, pump down capability is provided by connections from each inlet and outlet water box to the 1P-7 Suction. 3-inch drain lines on the West 'E,'F, 'G', and 'H' water boxes provide enhanced drain capacity.Cooling Tower Inlet and Sparcqinq Valves Four motor operated 60 inch butterfly valves (MO-4249, MO-4250, MO-4251 and MO-4252)control the distribution of Circulating Water within the Cooling Towers. These valves can be opened, throttled or closed to send water to the cooling tower fans or in conjunction with the sparger bypass valve to the cooling tower basin. The tower inlet valves are controlled by key operated CLOSE-NORMAL-OPEN, spring return to NORMALhand switches in the vicinity of the Cooling Tower switchgear. Keys are removable only in the NORMAL position.Rev, 5 .12 -Cooling Towers and Cite Water SD_442.doc Ol.ler LO()!) 1",,41r Loop _ ...... '"

• High COndenser 1E*76 -.. i M:J.-D1 4208 4200 t--T C.c 'Mller Drain To Cooling "lIer O;ain Basin Circulating Water Drain Pump 1 "' r--0; _ .. 01 Low P,,,'1V1 Concfe",ff IE*7A ...........('

... ... !\lO-Ci. r, H0-4202 Oi rom F C 'Nater Pumps MO-4257 HO-420 A Gould horizontal centrifugal pump with the capacity of 650 gpm at an 80 ft head at 1750 rpm is provided 10 drain the condenser water boxes for servicing. The drain pump, 1 P.7, is a 20 horsepower 480VAC , 3 phase 60 Hz powered from MeC 1833. The drain pump is controlled by local STOP-START push buttons, HS-421 0, and provided with indicating lights, pump stopped (green) and pump running (red). During partial Condenser Cire Water Loop isolation conditions. pump down capability is provided by connections from each inlet and outlet wa1er box to the 1P-7 Suction. 3-inch drain lines on the West 'E', 'F', 'G', and 'H' water boxes provide enhanced drain capacity. Cooling Tower Inlet and Sparging Valves Four motor operated 60 inch butterfly valves (MO-4249, M04250, MO-42S1 and MO-4252) control the distribution of Circulating Water within the Cooling Towers. These valves can be opened, throttled or closed to send water to the cooling tower fans or in conjunction with the sparger bypass valve to the cooling tower basin. The tower inlet valves are controlled by key operated CLOSE-NORMAL-OPEN, spring return to NORMAL,hand switches in the vicinity of the Cooling Tower switchgear. Keys are removable only in the NORMAL position . Re\,. !i

• 12 . Cooling Towers and Circ Water Cooling Tower Inlet Valve MO-4250 for Cooling Tower IE-69A and MO-4251 for Cooling Tower 1E-691, are each interlocked with the respective manually operated 16 inch sparging bypass valv.e such that the tower inlet valve can only be closed electrically when the sparging bypass valve is opened beyond the limit switch setting. Raising sparging flow will result in rising clrc water temperature in the water returning to the Circ Water pit. 480 VAC MCC 1871 provides power for Cooling Tower IE-69A inlet valves and MCC 1881 provides power for Cooling Tower 1E-69B inlet valves.Cooling Towers and Fans Each Cooling Tower is a twelve cell, cross-flow, forced draft heat sink capable of transferring 1.82 x 103 MBtulhr at 155,000 gpm with a design inlet temperature of 112 0 F and outlet temperature of 87 0 F. The Cooling Towers are sized to reject heat from the Circulating Water, General Service Water, Residual Heat Removal Service Water, Emergency Service Water and Well Water Systems.Each Cooling Tower cell contains a 28 foot diameter, motor driven, single speed, reversible, 137 rpm gear reduced fan. The fan motors are rated at 200 horsepower at 1785 rpm. The fan blades are pitched at 12.75 degrees and have the capacity to move 1.47 x 10" scfm. Each Cooling Tower fan is individually controlled using a REVERSE-OFF-FORWARD handswitch on Panel 1 C06 with green (fan stopped) and red (fan running) indicating lights. The fans for Oooling Tower 1 E-69A and 1E-698 are powered from 480 VAC load centers 167 and 188 respectively.

To start a fan in FORWARD or REVERSE, the fan has to have been stopped for at least three minutes. The following conditions will trip a Cooling Tower Fan: ci High vibration. o Cooling tower fire protection deluge (4-8 psig downstream of the cell deluge valve)-E Overload condition Fan riotor space heaters energize to prevent condensation in the motor windings when the fan is idle. 120 VAC power for winding heaters is supplied from 1 L71 and 1 L81.Annunciators on Panel 1C06-A associated with the fans are: Rev. 5 Cooling Towers and Cire Water SD_442.doc Coaling Tower Inlet Valve MO-4250 for Cooling Tower 1E-69A and M0-4251 for Cooling Tower 1 E-69B, are each interlocked with the respective manually operated 16 inch sparglng bypass valve such that the tower inlet valve can only be closed electrically when the sparging bypass valvre is opened beyond the limit switch setting. Raising sparging flow will result in rising eire . water temperature in the water returning to the eire Water pit. 480 VAC MCC 1871 provides power for Cooling Tower 1E-69A inlet valves and MeC 1881 provides power for Cooling Tower 1 E-69B inlet valves. Cooling Towers and Fans Each Cooling Tower is a welve cell, cross-flow, forced draft heat sink capable of transferring 1.82. x 10 3 MBtufhr at 155,000 gpm with a design inlet temperature of 112°F and outlet temperature of 87°F. The Cooltng Towers are sized to reject heat from the Circulating Water, General Service Water, Residual Heat Removal Service Water, Emergency Service Water and Well Water Systems. Each Cooling Tower cell contains a 28 foot diameter, motor driven. single speed, reversible, 137 rpm gear reQuced fan. The fan motors are rated at 200 horsepower at 1785 rpm. The fan blades are pitched at 12.75 degrees and have (he capacity to move 1.47 x 10 6 scfm. Each Cooling Tower fan is indiVidually controlled using a REVERSE-OFF-FORWARD handswitch on Panel 1 coe with green (fan stopped) and red (fan running) indicating lights. The fans for Cooling Tower 1 E-69A and 1E-698 are powered from 480 VAC load centers 167 and 188 To start a fan in FORWARD or REVERSE, the fan has to have been stopped for at least three minutes. The following conditions will trip a Cooling Tower Fan: o vibration. o Cooling tower fire protection deluge (4-8 psig downstream of the cell deluge valve) [ Overload condition Fan rmotor space heaters energize to prevent condensation in the motor windings when the fan is idle. 120 VAC power for winding heaters is supplied from 1 L 71 and 1 L81. Annunciators on Panel 1 C06-A associated with the fsns are: Rev. 5 *13 -Cooling Towers and eire Water 5lJ_ 442.noc Q1 "A" COOLING TOWER 1 E-69A FAN TROUBLE (A-5)13 "B" COOLING TOWER 1E-69B FAN TROUBLE (A-6)...-.............--------.----- HS--------------------- River Water System Cooling Towers C o. TBasijn Basin -4 LC L Y>~ Circ Wazar M~ T. PLrnp Pit Coolinci Tower Basin The basin is the collection point of either the gravity drains from the tower or the bypassed sparger flow. The basin water level is monitored and transmitted by level transmitter LT-4231 (LT-4232) for Tower 1E-69A (1E-69B) to indicators LIC-4231 and LIC-4232 on Control Room Panel 1C06. A selector switch, HSS-4919, determines which controller regulates river water supply flow to the stilling basin.The Controlling Cooling Tower basin will signal for makeup water when the level is down to 3 inches below the normal level and will continue to signal for makeup water until the water level in the Cooling Tower basin rises 6 inches above the normal level.Eacli Cooling Tower basin level indicator is equipped with a level switch, LS-4229 (LS-4230), for Tower 1E-69A (1E-69B) respectfully, which activates an annunciator on Panel 1C06 A (B-5&6) ("A/B" COOLING TOWER BASIN H11/1.0 LEVEL). These level alarms are 4 inches above and 18 inches below the normal operating level. This physically equates to 8 inches and 30 inches below the top of the basin lip respectfully. The basin overflows at 53" on LI-4231.Rev. 5 *14 -Cooling Towers and Circ Water SD_442.doc o "A" COOLING TOWER 1 E*69A FAN TROUBLE (A-S) (J "S" COOLING TOWER iE*69B FAN TROUBLE (A-e) " --_ *** -M _ M *** --_ -*** -**** --_. -fHs1-_ **** -M' -** -**** -* -***** -***** : I , I * * ! * , Willer System Cooling .--_---.Towcrsr-------.. c::::::x:::> .

• I Basin LC

.. ' Basin L--"-T---'-' LC Stillillg Basin ------r-------, , ",> :"'c >:t) :roa :m;ii : Tower Basin eire Waiar PUIJl!} Pit The basin is the collection point of either the gravity drains from the tower or the bypassed sparger flow. The basin water level is monitored and transmitted by level transmitter LT -4231 (LT-4232) for Tower 1E-69A (1E*69B) to indicators L1C-4231 and lIC-4232 on Control Room P8nel1 C06. A selector switch. HSS-4919, determines which controller regulates river water supply flow to the stilling basin. . The controlling Cooling Tower basin will signal for makeup water when the level is down to 3 inches below the normal level and will continue to signal for makeup water until the water level in the Cooling Tower basin rises 6 inches above the normal Jevel. Eac/"ll Cooling Tower basin level indicator is equipped with a level switch. LS-4229 for TqJwer 1 E-69A (1 E-69B) respectfully, which activates an annunciator on Panel 1 C06 A (8-5&6) ("AlB" COOLING TOWER BASIN HI/1.0 LEVEL). These level alarms are 4 inches above and 18 inches below the norma I operating level. This physically equates to 8 inches and 30 inches below the top of the basin lip respectfully. The basin overflows at 53" on L1-4231. Rev. I) SD_442.doc

• 14 -Cooling Towers and eire Water The basin drain for each Cooling Tower is equipped with concrete slab isolation stop logs for use during maintenance on the respective tower.NORMAL OPERATION Both Circulating Water pumps take suction on the Circ Water Pit and discharge to the Low Pressure Condenser inlet via individual discharge valves and lines. Chemicals are added to the Circulating Water prior to the Main Condenser to control slime, algae growth and scale formation.

Circulating Water flows through the low pressure condenser tubes, crosses over and flows through the high pressure condenser tubes from west to east, Isolation valves MO-4257 or MO-4258 at the LP Condenser inlet water boxes in conjunction with HP Condenser outlet MO-4208 or MO-4209 provide for partial Main Condenser Outer or Inner Loop Circ Water isolation and pump down for maintenance at reduced Reactor Power. A return line from the General Service Water System and from the Circulating Water Drain Pump feeds into one of the HP Condenser lines before the two lines combine into a single header heading toward the Cooling Towers. The Residual Heat Removal Service Water, Emergency Service Water and Well Water systems inject into the combined Circulating Water discharge line from the Main Condenser. The Circulating Water header splits into two lines near the Cooling Towers and flows through Iwo risers with motor operated butterfly valves to the top of the tower. Each tower is equipped with a sparging bypass line with a manually operated valve that can be set to allow part of the Circulating Water to discharge directly to the tower basin. The temperature of the water in the tower basins should be maintained between 60°F and 70°F. Several schemes are available to regulate the temperature as the heat load chaf jes. Some fans can be turned off, or some cells can be completely taken out of service by manually closing the distribution valves at the top of the tower. The Cooling Towers fans may be operated in the reverse direction for winter operation to eliminate icing and for drying out the cell. The sparging bypass lines may be used for temperature control by diverting part of the Circulating Water to the tower basins. Normally open motor operated inlet valves are throttled to prevent pump runout as the sparging bypass valves are opened. Annunciator on Panel 1C06-B, TURBINE INSTRUMENT PANEL 1C20 TROUBLE, alerts personnel to an increasing temperature of 120 degrees in the system.After cooling, the Circulating Water collects in the Cooling Tower basin and drains back to the Circulating Water pit by gravity. Water required to replace evaporation and blowdown losses is Rev. 5 Cooling Towers and Circ Water SD,442.doc The basin drain for each Cooling Tower is equipped with concrete slab isolation stop logs for use during maintenance on the respective tower. NORMAL OPERATION Both Circulating Water pumps take suction on the eire Water Pit and discharge to the Low Pressure Condenser inlet via individual discharge valves and lines. Chemicals are added to the Circulating Water prior to the Main Condenser to control slime, algae growth and scale formation. Circulating Water flows through the low pressure condenser tubes, crosses over and flows through the high pressure condenser tubes from west to east. Isolation valves MO*4257 or M0-4258 at the LP Condenser inlet water boxes in conjunction with HP Condenser outlet MO-4208 or MO*4209 provide for partial Main Condenser Outer or Inner Loop Cire Water isolation and pump down for maintenance at reduced Reactor Power. A return line from the General Service Water System and from the Circulating Water Drain Pump feeds into one of the HP Condenser lines before the two lines combine into a single header heading toward the Cooling Towers. The Residuat Heat Removal Service Water, Emergency Service Water and Well Water systems inject into the combined Circulating Water discharge line from the Main Condenser. The Circulating Wa(er header splils info two Jines near the Cooling Towers and flows through two risers with motor operated butterfly valves to the top of the tower. Each tower is equipped with a sparging bypass line with a manually operated valve that can be set to allow part of the Circulating Water to discharge directly to the tower basin. The temperature of the water in the tower basins should be maintained between 60"F and 70°F. Several schemes are available to regulate the temperature as the heat load char .:;/8S. Some fans can be turned off, or some cells can be completely taken out of service by manually closing the distribution valves at the top of the tower. The Cooling Towers fans may be operated in the reverse direction for winter operation to eliminate icing and for drying out the cell. The sparging bypass lines may be used for temperature control by diverting part of the Circulating Water to the tower basins. Normally open motor operated inlet valves are throttled to prevent pump runout as the sparging bypass valves 3re opened. Annunciator on Panel 1 TURBINE INSTRUMENT PANEL 1C20 TROUBLE, alerts personner to an temperature of 120 degrees in the system. After cooling, the Circurating Water col/ects in the Coaling Tower basin and drains back to the Circulating Water pit by gravity. Water required to replace evaporation and blowdown losses is Rev. 5 SD_442.doc -I:') *Cooling Tow!!(s and eire Water supplied by the River Water Supply System. River Water is pumped to the RHRSW/ESW stillimg basin to overflow to the circulating water pump wet pit through a standpipe. The rate of makeup water delivery is proportional to the level in the Cooling Tower basins. At full power, appqoximately 6000 -8000 gpm (with a nominal 1500 gpm supplied by well water) will be required to make up for Cooling Tower evaporation and blowdown.A line from the discharge of Circulating Water Pump 1P-4A directs water from the Circulating Water System through the Radwaste Dilution Structure to the Cedar River to remove impurities. A separate line to the Cedar River may be utilized for RWS Intake deicing.Starting And Stopping A Cire Water Pump Circ Water Pump handswitch HS-4201 (HS-4202), on Control Room Panel I C06, also controls hydraulic power unit 1S-92A (IS-92B). When the Circ Water Pump handswitch is placed in START, the Circ Water Pump and the respective Pump Discharge Valve hydraulic power unit start. The Pump Discharge Valve HO-4201 (HO-4202) starts to open 30 seconds after the respective pump breaker closes. The hydraulically operated discharge valve takes 145 to 175 seconds to stroke open. When Pump Discharge Valve, HO-4201 (HO-4202), is full open, a solenoid energizes to pressurize and close air operated vent valve CV-4201 (CV-4202). When the Circ Water Pump handswitch HS-4201 (HS-4202), is turned to STOP, the h(ydraulically operated discharge valve moves from full open to 60% in 5 seconds and continues from 60% open to full closed in another 15 seconds. The associated vent valve opens when the discharge valve leaves the full open position. The Circ Water Pump breaker trips when the discharge valve reaches its fully closed position, 120VAC Uninterruptible Power is utilized for the following instrumentation: o TRS-4200, Circ Water/Condenser Temp Recorder o £T-4212, Circ Water Pump Pit Level CD FT-4247, Circ Water Blowdown Flow 0 PT-4205, Circ Water Discharge Pressure.Rev. 5 Cooling Towers and Circ Water SD_4,2 .doc supplied by the River Water Supply System. River Water is pumped to the RHRSW/ESW stillilng basin ,to overflow to the circulating water pump wet pit through a standpipe. The rate of makeup water delivery is proportional to the level in the Cooling Tower basins. At full power, app.roximately 6000 -8000 gpm (with a nominal 1500 gpm supplied by well water) will be required to make up for Cooling Tower evaporation and blowdown. A line from the discharge of Circulating Water Pump 1 P-4A directs water from the Circulating Water System through the Radwaste Dilution Structure to the Cedar River to remove impurities. A separate line to me Cedar River may be utilized for RWS Intake deicing. Starting And Stopping A eire Water Pump Circ Water Pump handswitch HS-4201 (HS-4202), on Control Room Pane11C06. also controls hydraulic power unit 1 S-92A (1 S-928). When the Cire Water Pump handswitch is placed in START. the eirc Water Pump and the respective Pump Discharge Valve hydraulic power unit start. The Pump Discharge Valve H0-4201 (HOA202) starts to open 30 seconds after the respective pump breaker closes. The hydraulically operated discharge valve takes 145 to 175 seconds to stroke open. When Pump Discharge Valve, (HO-4202). is fun open, a solenoid energizes to pressurize and close air operated vent valve CV-4201 (CV-4202). When the Cire Water Pump handswitch HS-4201 (HS-4202). is turned to STOP. the operated discharge valve moves from full open to 60% in 5 seconds and continues from 6.0% open to full closed in another 15 seconds. The associated vent valve opens when the discharge valve leaves the full open position. The Circ Water Pump breaker trips when 'he discharge valve reaches ils fully closed position, 120VAC Uninterruptibre Power is utilized for the following instrumentation: o TRS-4200, eire Water/Condenser Temp Recorder o l T -4212, eirc Water Pump Pit Level OfT-4247. eire Water Slowdown Flow o PT-4205. Circ Water Discharge Pressure. Rev. 5 SD_442.doc .16 .Cooling Towers and eire \'-later ABNORMAL OPERATION During a plant shutdown to cold conditions, both Circulating Water pumps are shutdown.Valves MO-4208 and MO-4209 are closed and one Cooling Tower is left in operation to cool General Service Water, RHR Service Water, Emergency Service Water and Well WaterSystem heat loads. RHR Service Water System, Emergency Water System, GSW and Well Water System can be discharged directly to the river via the dilution structure and discharge canal when no cooling towers are available. During plant shutdown, the Main Condenser water boxes may be drained. This is accomplished by closing the HP Condenser discharge valves MO-4208 and MO-4209, manually opening the inlet valves to the Circulating Water Drain Pump IP-7, and starting the pump. The hand operated gate valve on the discharge side of the pump is then opened, and subsequently closed as soon as the drainage is complete. Additional drainage may be provided via hoses routed to the MUD Chem Waste Sump.Isolating a Circulatin Water Loop -Inner or Outer Reduce Reactor Power to allow taking one Cooling Tower and Circ Water Pump out of service.In the Condenser Bay, open the Outerllnner Loop 1 P-7 suction isolation valves to provide overpressure protection while isolating a Main Condenser Circ Water Loop. For the loop 3elected to be isolated for maintenance, energize and close the LP Condenser Circ Water Inlet (MO-4257 Outer Loop or MO-4258 Inner Loop) isolation valve. Manually engage both Tedundant disc-locking devices. In the Condenser Bay, at local Panel 1C498, place HS-4209A or HS-4208A Circ Pump Permissive Override Handswitch to OVERRIDE. In the Control Room at Panel IC06 Close MO-4209 Outer Loop or 1O-4208 Inner Loop Outlet isolation valve.LP Turbine exhaust steam will continuously add heat to the isolated loop. The only pressure indication of the isolated Condenser Loop will be the 1P-7 Pump Suction Pressure PI-4238A.Control the isolated loop pressure by throttling OPEN the associated loop Water Box East and West vent valves.Rev. 5 .17 -Cooling Towers and Circ Water SD_,442.doc ABNORMAL OPERATION During a plant shutdown to cold conditions, both Circulating Water pumps are shutdown. Valves MOA208 and MO-4209 are closed and one Cooling Tower is left in operation to cool General Service Water. RHR Service Water, Emergency Service Water and Well Water System heat loads. RHR Service Water System, Emergency Water System, GSW and Well Water System can be discharged directly to the river via the dilution structure and discharge canal when no cooling towers are available. During plant shutdown, the Main Condenser water boxes may be drained. This is accomplished by closing the HP Condenser discharge valves MO-42GB and MO-4209, manually opening the inlet valves to the Circulating Water Drain Pump 1P-7, and starting the pump. The operated gate valve on the discharge side of the pump is then opened, and subsequently closed as soon as the drainage is complete. Additional drainage may be provided via hoses routed to the MUD Chem Waste Sump. Isolating a Circulating Water Loop -Inner or Outer Reduce Reactor Power to allow taking one Cooling Tower and eirc Water Pump out of service. In the Condenser Bay, open the OuterlJnner loop 1 P-7 suction isolation valves to provide overpressure protection while isolating a Main Condenser Cire Water Loop. For the loop to be isolated for maintenance, energize and close the LP Condenser eirc Water Inlet (MO-42S7 Outer Loop or MO*4258 Inner Loop) isolation valve. Manually engage both redundant disc-locking devices. In the Condenser Bay, at local Panel 1 C498, place HS-4209A or HS-420BA Cire Pump Permissive Override Handswitch to OVERRIDE. In the Control Room at Panel 1 C06 Close M0-4209 Outer Loop or Inner Loop Outlet isolation valve. LP Turbine exhaust steam will continuously add heat to the isolated loop. The only pressure indication of the isolated Condenser Loop wi!! be the 1 P-7 Pump Suction Pressure PJ-4238A. Control the isolated loop pressure by throttling OPEN the associated loop Water Box East and Wes'J. vent valves. Rev. 5 SD_442.doc . 17 'Towers and eire Water SYSTEM INTERRELATIONS 0.LI.0.Main Condenser The Circulating Water travels through the low pressure section of the condenser first, then the high pressure section of the condenser, providing a heat sink to condense steam exhausted 7rom the turbine.For additional information, refer to SD-691, Main Condenser and Main Condenser Air Removal Sy&,em.Residual Heat Removal Service Water The Cooling Towers receive the Residual Heat Removal Service Water when the Residual Heat Removal System is operating in the shutdown cooling, containment spray, or Torus Cooling or spray modes.For additional information, refer to SD-416, RHR Service Water System Rev. 5 SD.A 42.doc* 18.Cooling Towers and Circ Water SYSTEM INTERRELATIONS ;n HP L P C",J ;Ij"t , I' .... 'Nil -.... ,. 5 '" M-tlI >-!G 1 ',P-117O\ I V,11: ':'.1"':;'1--:-." tL Sl1J'=:ur'Q foE-,Xm 1 (') III I a. (:) b'a ..., ;u ) :::' (1) ..., 1:).:11_ ,f*::!!C Pump House Circulating Water Pit V IP f'rc:O;JI<:R I .6'_ ( , Main Condenser l"he Circulating Water travels through the low pressure section of the condenser first, then the high pressure section of the condenser, providing a heat sink to condense steam exhausted 1rom the turbine. For additional information, refer to SO-691, Main Condenser and Main Condenser Air Removal SY$.\em. Residual Heat Removal Service Water The Cooling Towers receive the Residual Heat Removal Service Water when the Residual Heat RemG)val System is operating in the shutdown cooling. containment spray, or Torus Cooling or spray modes. For additional information. refer to SO-416. RHR Service Water System Hcv.5 SD_.J42.doc . 18 .Cooling Towers and eire Water Emergency Service Water The Cooling Towers provide a discharge path for the Emergency Service Water System.For additional information, refer to SD-454, Emergency Service Water General Service Water The General Service Water pumps take suction from the Circulating Water pump pit and supply its various loads before returning to the Circulating Water System just downstream of the high pressure condenser. The General Service Water System also provides cooling water for the Circulating Water Pump bearing lube oil and motor windings.For additional information, refer to SD-41 1, General Service Water System. LiUuid Radwaste System Processed liquid radioactive wastes can be diluted with water from the River Water Supply System and then combined with the blowdown from the Circulating Water System in the dilution structure. This water can then be discharged to the river via the discharge canal, Note: Radwaste policy is to process all liquids and return to the Condensate Storage Tanks.The discharge path to the river has not and will continue to not be normally used.For additional information, refer to SD-969.1, Liquid Radwaste System.River Water Supply System The River Water Supply System pumps water to the stilling basin, which overflows through a stardpipe to maintain water level in the Circulating Water pump pit. The flow of river water for makeup is controlled by Cooling Tower basin level.Loss of River Water System will result in decreasing level in the Circ Water Pump Pit level.For additional information, refer to SD-410, River Water Supply and Intake Structure, Rev. 5 Cooling Towers and Circ Water SD_4,12,doc Emergency Service Water The Cooling Towers provide a discharge path for the Emergency Service Water System. For additional information. refer to SO-454, Emergency Service Water General Service The General Service Water pumps take suction from the Circulating Water pump pit and supply its various loads before returning to the Circulating Water System just downstream of the high pressure condenser. The General Service Water System also provides cooling water for the Circulating Water Pump bearing lube oil and motor windings. For additional information, refer to 80-411, General SeNice Water System. Liquid Radwaste System liquid radioactive wastes can be diluted with water from the River Water Supply System and then combined with the blowdown from the Circulating Water System in the dilution structure. This water can then be discharged to the river via the discharge canal. Note: Radwc;ste policy is to process all liquids and return to the Condensate Tanks. The discharge path to the river has not and will continue to not be normally used. For additional information, refer to SO-969.1, Liquid Radwaste System. River Water Supply System The River Water Supply System pumps water to the stilling basin, which overflows through a stalldpipe to maintain water level in the Circulating Water pump pit. The flow of river water for makeup is controlled by Cooling Tower basin level. Loss of River Water System will result in decreasing level in the Cire Water Pump Pit level. For additional information, refer to SO-410. River Water Supply and Intake Structure. Rev. 5 *19 -Cooling Towers and eire SD_ 4,t2.doc Well Water System The Circulating Water pump seals are supplied from the Well Water System. The Well Water System discharges to the Circulating Water System downstream of the High Pressure Condenser. Loss of Well Water System results in loss of seal water supply.For additional information, refer to SD-408, Well Water System. Cooling Water Treatment System Sodium Hypochlorite biocide is added to the discharge of the Circulating Water Pumps to control slime and biological growth in the circulating water and condenser systems. A corrosion inhibitor, surfactant, and dispersant are added to the GSW system, which returns to the circulating water pit to treat the circulating water system and main condenser. The Acid System functions to maintain the pH of the Circulating Water and GSW Systems by injecting sulfuric acid into the circ. pit For additional information, refer to SD-442.t, Circ Water Chemical Feed System.Instrument and Service Air System Operating air for the air operated vent valves CV4201 and CV-4202 is supplied from the Instrument and Service Air System. Also, Instrument Air is-utilized for pit level indication. Loss of Instrument and Service Air results in vent valve failing open and low level in the Circ Water Pump Pit. This loss of instrument air causes River Water System Makeup Valves, CV-4914 and 4915 to fail open. These valves also fail open on loss of 120 VAC Instrument Control Power.For additional information, refer to SD-518, Instrument and Service Air and Breathing Air Systems.Makeup Demineralizer System Connecting hoses to the isolated Outer/Inner Loop west side water box 3 inch drain valves facilittes drain down flowrate. Hoses are routed through wall penetrations to the Chemical Waste Sump. Maintain continuous monitoring at the Chemical Waste Sump in coordination with drain valve operation. Throttle the drain flowrate to within the capacity of the Chemical Waste Sump Pumps IP-103A/B. Rev. 5 Cooling Towers and Girt Water SD_442.doc Well Water System The Circulating Water pump seals are supplied from the Well Water System. The Well Water System discharges to the Circulating Water System downstream of the High Pressure Condenser. loss of Well Water System results in loss of seal water supply. For additional information, refer to SO-408, Wen Water System. Cooling Water Treatment System Sodium Hypochlorite biocide is added to the discharge of the Circulating Water Pumps to control slime and biological growth in the Circulating water and condenser systems. A corrosion inhibitor, surfactant. and dispersant are added to the GSW system, which returns to the Circulating water pit to treat the circulating water system and main condenser. The Acid System functions to maintain the pH of the Circulating Water and GSW Systems by injecting sulfuric acid into the eire. pit For addItional information, refer to SO-442.1, Circ Water Chemical Feed System. Instrument and Service Air Operating air for the air operated vent valves CV-4201 and CV-4202 is supplied from the Instrument and Service Air System. Also, Instrument Air is utilized for pit level indication. Loss of Instrument and Service Air results in vent valve failing open and low level in the Circ Water Pump Pit. This ross of instrument air causes River Water System Makeup Valves, CV-4914 and 4915 to fan open. These valves also fail open on loss of 120 VAC Instrument Control Power. F;nr additional information, refer to SD*518, Instrument and Service Air and Breathing Air Systems. Makeup DemineraJizer System Connecting hoses to the isolated Outerllnner Loop west side water box 3 inch drain valves facilitates drain down flowrate. Hoses are routed through wall penetrations to the Chemical Waste Sump. Maintain continuous monitoring at the Chemical Waste Sump in coordination with drain valve operation. Throttle the drain flowrate to within the capacity of the Chemical Waste Sump PUmps 1P-103A1B. Rev. 5 SD_1!42.ooc .20 . Cooling Towers and Cire Water &cjd Feed System The acid feed system functions to maintain the pH of the Circ Water and GSW Systems by injecting sulfuric acid and olher chemicals into the circ pit. This is discussed in SD 515, Circ Water Chemical Feed System. For additional information, refer to SD-515, Circulating Water Chemical Feed System.ReL-V. 5 SDA 42.doc-21.C3aoing Towers and Cite NV ter Acid Feed S,(ste..m The acid feed system functions to maintain the pH of the Cire Water and GSW Systems by injecting sulfuric acid and other chemicals into the eirc pit. This is discussed in SO 515, Cire Water Chemical Feed System. For additional information, refer to SD-515, Circulating Water Chemical Feed System . SD_, 142.doc *21

• Cooling Towel'S unO. Cire Water-REFERENCES A. USFARIDAEC-1, Section 10.4.5 B. DBD-N71-001, Design Basis Document Circulating Water System C, Instructor Guide 32.0, Cooling Towers and Circulating Water System D. Bechtel Specification 7884-M-128, Technical Specification for Butterfly Valves for Circulating Water Pumps E. P&ID, Circulating Water System, Bechtel Drawing 7884-M-142 F. P&ID, Chlorination

& Acid Feed Systems Bechtel Drawing 7884-M-180 G. P&ID, Service Water System Pumphouse Bechtel Drawing 7884-M-146 H. P&ID, River Water Supply System Intake Structure Bechtel Drawing 7884-M-129 I. P&ID, Instrument Air System, Turbine Building, Heater Bay Area, Pump House Area, Bechtel Drawing 7884-M-1 30 (6)J. P&ID, Chlorination and Acid Feed System Bechtel Drawing 7884-M-180 K. Circulating Water System Electrical Dwgs, Bechtel Drawing 7884-E1l10 (2-11)L. Logic Diagram Discharge & Vent Valve Control of Circulating Water Punmps, Drawing 7884-M-407-22 M. Logic Diagram Cooling Tower Fans, Drawing 7884-M-407-50 N. Generai Arrangement of Switch on Operators, Drawing 7884-M-12B-003

0. Schematic Diagram Acid Feed 7884-E-85 (4,5)P. Drawing M128-019, Electrical Sch. Circ Water Hydraulic Valve Control Q. Drawing M128-020, Circ Water Pump Discharge Valve Hydraulic Schematic R. AOP 301, Loss of Essential Electricai Power S. AOP 302.1, Loss of 125 VDC Power T. AOP 304.1, Loss of 4160V Non-Essential Electrical Power U. AOP 317, Loss of 120 VAC Instrument Control Power V. AOP 357, Loss of 120 VAC Uninterruptible Power W. AOP 408, Loss of Well Water System X, AOP 410, Total Loss of River Water Supply Y. AOP 411, GSW Abnormal Operation Z. AOP 518, Failure of Instrument and Service Air AA. Annunciator Panel 1C06-B, TURBINE INSTRUMENT PANEL 1C20 TROUBLE BB. Annunciator Panel 1C07-A, CIRC WATER VALVE HO-4201/HO-4202 HYDRAULIC OIL LO PRESSURE CC. Annunciator Panel 1C07-B, ACID/CHLORINATION PANEL 1C-417 TROUBLE Rev. 5 Cooling Towers and Circ Water SD_442.doc

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REFERENCES A USFARJDAEC-1, Section 10.4.5 B. DBD-N71-001, Design Basis Document Circulating Water System C. Instructor Guide 32.0, Cooling Towers and Circulating Water System D. Bechtel SpecifiCBtion 7884-M-128, Technical Specification for Butterfly Valves for Girculating Water Pumps E. P&ID, Circulating Water System, Bechtel Drawing 7884-M-142 F. P&ID, Chlorination

& Acid Feed Systems Bechtel Drawing 7884-M-180 G. P&\D. Service Water System Pumphouse Bechtel Drawing 7884-M-146 H. P&ID, River Water Supply System Intake Structure Bechtel Drawing 7884*M-129 I. P&ID, Instrument Air System, Turbine Building, Heater Bay Area, Pump House Area, Bechtel Drawing 7 884-M-130 (6) J. P&ID, Chlorination and Acid Feed System Bechtel Drawing 7884-M-180 K. Circulating Water System Electrical Dwgs, Bechtel Drawing 7884*E*110 (2-11) L. Logic Diagram Discharge & Vent Valve Control of Circulating Water Pumps, Drawing 7884-M-407 -22 M. Logic Diagram Cooling Tower Fans, Drawing N. Generai Arrangement of Switch on Operators, Drawing 7884-M-128-003 O. Schematic Diagram Acid Feed 7884-E-85 (4,5) P. Drawing M128-019, Electrical Sch. eire Water Hydraulic Valve Control Q. Drawing M128-020, eire Water Pump Discharge Valve Hydraulic Schematic R. . AOP 301, loss of Essential Electrical Power S. AOP 302.1, Loss of 125 VDC Power T. AOP 304.1, loss of 4160V Non-Essential Electrical Power U. AOP 317, Loss of 120 VAC Instrument Control Power V. AOP 357, Loss of 120 VAC Uninterruptible Power W. AOP 408, loss of Well Water System X. AOP 410, Total Loss of River Water Supply y, AOP 411, GSW Abnormal Operation Z. AOP 518, Failure of Instrument and Service Air AA. Annunciator Panel 1 TURB!NE INSTRUMENT PANEL 1 C20 TROUBLE BB. Annunciator Pane11C07-A, eIRe WATER VALVE HO-4201/HO-4202 HYDRAULIC OIL LO PRESSURE ce. Annunciator Panel1C07-B, ACIO/CHLGRINATION PANEL 1C-417 TROUBLE Hev. 5 SD_,142.doc

• 22 .Cooling Towers and Cire Wator DD. Annunciator Panel 1C06-A: LI "A" COOLING TOWER 1 E-69A FAN TROUBLE U "B" COOLING TOWER 1E-69B FAN TROUBLE a "A" CIRC WATER PUMP 1 P-4A TRIP MOTOR OVERLOAD C "B" CIRC WATER PUMP IP-4B TRIP MOTOR OVERLOAD 1i "A" COOLING TOWER BASIN HI/LO LEVEL El "B" COOLING TOWER BASIN HI/LO LEVEL U "A" CIRC WATER PUMP 1P-4A HI VIBRATION 0 "B" CIRC WATER PUMP 1P-4B HI VIBRATION 0 CIRC WATER PIT LO LEVEL EE. ECP 1640, Replacement of the Circulation Water Pumps FF. ECP 1674, Partial Main Condenser Circ Water Isolation and Pumpdown Rev. 5 .23 SD_442.doc-Cooling Towers and Circ Water DO. Annunciator Panel 1 C06-A: 0 "A n COOLING TOWER 1 E-69A FAN TROUBLE [J "B" COOLING TOWER 1 E-69B FAN TROUBLE 0 "An elRC WATER PUMP 1p*4A TRIP MOTOR OVERLOAD 0 liB" eIRe WATER PUMP 1P-48 TRIP MOTOR OVERLOAD n "A" COOLING TOWER BASIN HIlLa LEVEL 0 liB" COOLING TOWER BASIN HI/LO LEVEL u "A" eiRe WATER PUMP 1P-4A HI VIBRATION 0 "B" elRC WATER PUMP 1P-4B HI VIBRATION fJ CIRe WATER PIT LO LEVEL EE. ECP 1640, Replacement of the Circulation Water Pumps FF. ECP 1674, Partial Main Condenser eire Water Isolation and Pumpdown Rev. :; *23 .Cooling Towers and eire . SD_ 442.doc FIGURE 1: Basic Circ Water Flowpath OEAfr Lo~p RHRSW ESW,¢Rev. 5 SD_442.4oc C~oolng TowerS and Circ Water FIGURE 1: Basic eire Water Flowpath High Pressure Condenser 1E*78 Inner Loop RHRSW ESV'.j GSW'>-...---------------

I I I I I I 6 Circulating Water Pump Pit Low Pressu re Condenser 1E-7P. *24 .Cooling Towers nnel eire \Valer FIGURE 2: Circ Water Pump, Discharge Valve, Vent Valve CWP CWP Vent Disch Valve Valve CWP START CWP TRIP Pump Discharge_ Valve, -HO-4201 Open--,-A------- Pump Discharge Valve,-HO-4201 Closed Pump Discharge VentT Valve, SV-4201 Open -Condenser Outlet Valvel MO-4208 Open Condenser Outlet ValveL MO-4209 Open -CW Pit Level Greater than 18 ft. --Circ W ater Pump ------------- 1P-4, Control HS -Startp Pump TD Breaker TDDO Close r ,Pump Disch Vlv G, Closed------------ Pump Breaker Closed 4 -........4_ ..4 Pump Breaker TripI .... p ........---4 OV-3+/-U I -energize to close-------------

" KY-4201 ,CWP HS TDPU START -I.-----------------

4 ------------------- -:Ciro Water Pump, 1 P4.reakeT Closed( ---------------contact closed in d NORM AFT START oround Fault-------------- Differential Ovormurrent L -------------Over-current...........- -Rev. 5 SD_442-4oc Cooling Towers a;d Circ Water FIGURE 2: eire Water Pump, Discharge Valve, Vent Valve CWP *cwp Vent Valve Disch Valve CWPSTART #-----Pump Discharge Valve, I H0-4201 Closed -Pump Discharge Vent T Valve, SV-4201 Open -Condenser Outlet varvel M0-4208 Open T Condenser Outlet M0-4209 Open I cw Pit Level Greater Pump Discharge Valve. H0-4201 Open : than 18 ft. I

• _______ eirc Water Pump ___________________

_ * * * , , * , * , * , , , * , * , * , 1 P--4, Control HS -Start Pump Breaker Close TOOO 3--4 f .. _____________ , J : .----..... -------'--: SV4201 -::.: KY-4201, :

• CWP HS contact closed in : energize ;:: TOPU : START and NORM AFT START
• I r l ___________

...... : to dose : ' e .. _ ............. _ ... _ ..........

4--...............

-... _ ............. ----... _ ...... -...... , * : eirc Water Pump. 1 P4 : .! Breaker Closed : ,--------------------------

• 25 CWP.TRIP .--_ .. _---------. * : Pump : I, :: Disch Vlv , :: Closp.ci : L _____________

_ I . I ! Pump : : :: Breaker : :: Closed t Pump Breaker Trip : : 4 ...... _ ........... __ ........... t , I , :---£1 -------1 -... ----" -------. , ,--______

• I : Load:' , , : Shed: l __ ...... _ ... _ ... f ,-----------

Ground : : Faull : f __ .. _______ _ " ... _-------_

.... , ' '0 " : ! . : cu rre::1t : 1-_. ________ 1 ,-.. _-----------_ ... , : Differential * , I * : Qverourrent

L _______________ , -Cooling and Cire WaleT FIGURE 3: Inlet and Outlet Isolation Valves Inlet Isolation Valve Outlet Isolation Valve LOCAL-REMOT I-HS in LOCAL ~--r-CWP A Off CWP 6 Off' -,_ .........

.[ u -: -------Pump Permissive HS in Override 42-C --------------------. HS in OPEN 42-0 HS in CLO 4z c: I-I01 in OPEN HS in CLOSEýj42-6L LS LS LS ~ LS LS LS 42-0 LS 42-C 42-0 Inlet Valve Close Coil Inlet Valve Open Coil Outlet Valve Close Coil Outlet Valve Open Coil Rev. 5 SDA_42.4ac -,26* --Cooling Towers and Circ Water FIGURE 3: Inlet and Outlet Isolation Valves Inlet Isolation Valve l HSinLOCAL

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42-C l HS in CLOSE T T q HS in OPEN r 42-0 Rev. 5 SD_4f42.doc LS --c-LS LS =1=.1 LS 42-C In[etVa!ve C\ose Coil 42-0 Inlet Valve Open Coil Outlet Isolation Valve , .. -... -........... CWPAOff CWP 8 Off . ----------. -

_. .: Pump ; : Permissive H S : : in Override : 42-C .... -... -.. -.. -... -.... HS in CLOSE T T q HS in OPEN r 42-0 LS LS LS 42-0 42-C Outlet Valve Close Coil ,': 26' ", '",':. .,,' " .' LS 42-C 42-0 Outlet Valve Open Coil *Cooling Towers and eire Water FIGURE 4: Inlet Valve Cam Lock Key Inlet Valve Disk z Valve DiskStrike Plate Cam Lock Head Retracted r Rev. 55$D..A42joc Cooling Towers and Circ Water Rev. ;; Inlet Valve Disk Valve Disk Strike Plate Cam Lock Head Retracted SD_ 4.42.(foc FIGURE 4: Inlet Valve Cam Lock Key o Cooling Towers and Cire Water FIGURE 5: Drain Pump Loop Outer Loop To Cooling Water From Circ Drain Basin Water Pumps Rev. 5 SEL442.4oc Coohing Towers and Circ Water Rev.S SD_442.&c r High Pressure Condenser 1E-7B To Cooling Water Drain Basin MO-4209 FIGURE 5: Drain Pump Loop Outer Loop Inner Loop eire Water Drain Pump *23 low Pressure Condenser 1E-7A HO-4202 From eire Water Pumps MD-4257 HO-4201 .Cooling Towers and eire Water FIGURE 6: Circ Water System Makeup River Water System-- ---------------- ---- ---- ---- --Cooling Towers I I I kmi RnIi Ciro Water Pump Pit..29-Cooling Towers and Circ Water.Rev. 5 SDA44Ldoc FIGURE 6: eire Water System Makeup :-------------------------------i ------. ----------------------- -: River Water System Cooling Rev. 5 SD_442.doc stilling Basin eire Water Pump Pit "*29 . Towers r-----------, c:::x:::;::,. Basin Basin *Cooling Towers :Jnd eire Water FIGURE 7: System Inter-Connections 0, Intake Structure C-)Rev. 5 SDQ44!.doc Cooling Towers and Circ Water Intake Structure o (i) 0.. ru .., < ro .., Rev. 5 Storm Sewer Edg Coolers 14"--- 1P-'17D OillJtion Structure CV-4f!09 CV-491()A FIGURE 7: System Inter-Connections

u ::r ';0 Ul i'4:-i><J---

'AtJlI VVuter V4:'-1:? Slowdown CV-491G8 CV-4914 CV-4915 stilling Basin 1'PO:; b P 02; lP*:UC lP*229 lP*220 Pump House 1P-48 1P-4A Circul ating Water Pit -3{) H.P. Condo 1P-89C L.P. Condo Cooling Towers GSW *Cooling Towers and eire Water Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D. 11 b DAEC 2009, System

Description:

Cooling Towers and Circulating Water System. SD-442. Revision 7. April 2009.Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 0.11 b OAEC 2009, System

Description:

Cooling Towers and Circulating Water System. SO-442. Revision 7. April 2009. DUANE ARNOLD ENERGY CENTER SYSTEM DESCRIPTION Cooling T owerss and Circulating Water System SD-442 Rev. 7 Reviewed b)Reviewed by Reviewed by Syste Engineer r-Date Date Da -Date Operations Opera Tra ng Rev. 7 SD_442.doc-1-Coolinc DUANE ARNOLD ENERGY CENTER Reviewed by: Reviewed by: Rev. 7 SD_442.doc SYSTEM DESCRIPTION Rev. 7 Operations Date Date 3'-13 -0'7 Date Coolin£ v" TABLE OF CONTENTS Do not manually fill in TOC entries below. Entries will automatically update.After completing the body of the document, right mouse click in the grayed area below and select update fields -entire table/ LIST O F ILLUSTRATIO NS .......................................................................................... 4 V SYSTEM OVERVIEW ................................................................................................. 5 In tro d u c tio n ..................................................................................................................... 5 P u rp o s e ........................................ ............................ ...................................................... 5 Design Bases ........................................................................................................... 5 1' MAJO R CO M PO NENTS ............................................................................................ 6" SYSTEM O PERATIO N .............................................................................................. 6 Circ W ater Pum p Pit .................................................................................................... 6 Circulating W ater Pum ps ............................................................................................ 7 Circulating W ater Pum p Vent Valves .......................................................................... 9 Circulating W ater. Pum p Discharge Valves .................................................................. 9 M ain Condenser Circ W ater Inlet Isolation Valves ..................................................... 10 M ain Condenser Circ W ater O utlet Isolation Valves .................................................. 11 Circulating W ater Drain Pum p ................................................................................... 12 Cooling Tower Inlet and Sparging Valves .................................................................. 12 Cooling Towers and Fans .......................................................................................... 13 Cooling Tower Basin ................................................................................................ 14 Norm al O peration .............................. 1........................................................................... 15 Starting And Stopping A Circ W ater Pum p ................................................................ 16 Abnorm al O peration ................................................................................................... 16 Isolating a Circulating W ater Loop -Inner or Outer ..................................................... 17/ SYSTEM INTERRELATIO NS .................................................................................... 18 M ain Condenser ........................................................................................................ 18 Residual Heat Rem oval Service W ater .................................................................... 18 Em ergency Service W ater ........................................................................................ 19 General Service W ater ............................................................................................... 19 Rev. 7 SD-442 SD_442.doc Cooling Towers and Circulating Water System./ TABLE OF CONTENTS Do not manually fill in TOC entries below. Entries wi" automatically update. After completing the body of the document, right mouse click in the grayed area below and select update fields -entire table LIST OF ILLUSTRATIONS ............................................................................................. .4 SYSTEM OVERVIEW ............................................................................... '" ................... 5 Introduction ..................................................................................................................... 5 Purpose ....................................................................

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5 Design Bases ..... : ............................................................................................................ 5 ./ MAJOR COMPONENTS ................................................................................................. 6 SYSTEM OPERATION ................................................................................................... 6 Circ Water Pump Pit. ....................................................................................................... 6 Circulating .Water Pumps : ............................................................................................... 7 Circulating Water Pump Vent Valves .............................................................................. 9 Circulating Pump Discharge Valves ...................................................................... 9 Main Condenser Circ Water Inlet Isolation Valves ......................................................... 10 Main Condenser Circ Water Outlet Isolation Valves ...................................................... 11 Circulating Water Drain Pump ....................................................................................... 12 Cooling Tower Inlet and Sparging Valves ...................................................................... 12 Cooling Towers and Fans ............................................................................................. 13 Cooling Tower Basin ..................................................................................................... 14 Normal Operation ........................................................................................................... 15 Starting And Stopping A Circ Water Pump .................................................................... 16 Abnormal Operation ...................................................................................................... 16 . Isolating a Circulating Water Loop -Inner or Outer ...................................................... 17 SYSTEM INTERRELATIONS ........................................................................................ 18 Main Condenser ............................................................................................................ 18 Residual Heat Removal Service Water ......................................................................... 18 Emergency Service Water. ............................................................................................ 19 General Service Water .................................................................................................. 19 Rev. 7 SO_442.doc S0-442 Cooling Towers and Circulating Water System Liquid Radwaste System ............................................................................................ 19River W ater Supply System ..................................................................................... 19 W ell W ater System .................................................................................................. 20 Cooling W ater Treatm ent System ............................................................................ 20 Instrum ent and Service Air System .......................................................................... 20 Makeup Dem ineralizer System ................................................................................. 20 Acid Feed System ......................................................................................................... 21/ REFERENCES .............................................................................................................. 22 Rev. 7 SD-442 SD_442.doc Cooling Towers and Circulating Water System Liquid Radwaste System ............................................................................................... 19 River Water Supply System .......................................................................................... 19 Well Water System ....................................................................................................... 20 Cooling Water Treatment System ................................................................................. 20 Instrument and Service Air System ............................................................................... 20 Makeup Demineralizer System ...................................................................................... 20 Acid Feed System ......................................................................................................... 21 REFERENCES .............................................................................................................. 22 Rev. 7 SO_442.doc SO-442 Cooling Towers and Circulating Water System v LIST OF ILLUSTRATIONS Do not manually fill in Figures below. Entries will automatically update.After completing the body of the document, right mouse click in the grayed area below and select update fields -entire table FIGURE 1: Basic Circ Water Flowpath ................................................................................... 24 FIGURE 2: Circ Water Pump, Discharge Valve, Vent ............................................................. 25 FIGURE 3: Inlet and Outlet Isolation Valves .......................................................................... 26 F IG U R E 4 : Inlet V alve C am ................................................................................................... ..27 FIGURE 5: Drain Pump Loop ............................................................................................... 28 FIGURE 6: Circ Water System Makeup ................................................................................. 29 FIGURE 7: System Inter-Connections ..................................................................................... 30 Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System-4-../ LIST OF ILLUSTRATIONS Do not manually fill in Figures below. Entries will automatically update. After completing the body of the document, right mouse click in the grayed area below and select update fields -entire table FIGURE 1: Basic Circ Water Flowpath ........................................................................................ 24 FIGURE 2: Circ Water Pump, Discharge Valve, Vent.. ................................................................ 25 FIGURE 3: Inlet and Outlet Isolation Valves ................................................................................ 26 FIGURE 4: Inlet Valve Cam ......................................................................................................... 27 FIGURE 5: Drain Pump Loop ...................................................................................................... 28 FIGURE 6: Circ Water System Makeup ....................................................................................... 29 FIGURE 7: System Inter-Connections .............................................................................

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30 Rev. 7 SO_442.doc SO-442 Cooling Towers and Circulating Water System COOLING TOWERS AND CIRCULATING WATER SYSTEM Main headings (i.e., System Overview) must be formatted using toolbar button heading-1 Secondary headings (i.e., Introduction) must be formatted using toolbar button heading-2v/ SYSTEM OVERVIEW Introduction The Circulating Water System provides water from the Circ Water Pump pit to the Main Condenser (High and Low Pressure) to absorb heat from the Main Turbine exhaust. The Circulating Water flowpaths through the Low Pressure and High Pressure Condensers are designated the Inner Loop and the Outer Loop. The heated water leaves the condenser and moves to the Cooling Towers to transfer the heat to the environment. The tower-cooled water returns to the Circ Water Pump pit by gravity and the cycle begins again. During normal plant operation both Circulating Water pumps and both Cooling Towers are in service.Purpose The principal function of the Cooling Towers and Circulating Water System is to: " Provide a continuous supply of cooling water to remove the heat rejected to the main condenser." Remove the heat energy rejected from the plant cycle through the action of the cooling towers.Design Bases" Circulating Water System is designed to circulate the flow required to remove the design heat load from the Main Condenser." Circulating Water System is designed to operate on a closed cycle using induced-draft Cooling Towers." Cooling Towers are designed to remove the heat load of the circulated flow under all predicted weather conditions. Rev. 7 SD-442 SD_442.doc Cooling Towers and Circulating Water System COOLING TOWERS AND CIRCULATING WATER SYSTEM Main headings (i.e., System Overview) must be formatted using toolbar button heading-1 Secondary headings (i.e., Introduction) must be formatted using toolbar button heading-2 SYSTEM OVERVIEW Introduction The Circulating Water System provides water from the Circ Water Pump pit to the Main Condenser (High and Low Pressure) to absorb heat from the Main Turbine exhaust. The Circulating Water flowpaths through the Low Pressure and High Pressure Condensers are designated the Inner Loop and the Outer Loop. The heated water leaves the condenser and moves to the Cooling Towers to transfer the heat to the environment. The tower-cooled water returns to the Circ Water Pump pit by gravity and the cycle begins again. During normal plant operation both Circulating Water pumps and both Cooling Towers are in service. Purpose The principal function of the Cooling Towers and Circulating Water System is to:

• Provide a continuous supply of cooling water to remove the heat rejected to the main condenser.
• Remove the heat energy rejected from the plant cycle through the action of the cooling towers. Design Bases
• Circulating Water System is designed to circulate the flow required to remove the design heat load from the Main Condenser.
• Circulating Water System is designed to operate on a closed cycle using induced-draft Cooling Towers.
• Cooling Towers are designed to remove the heat load of the circulated flow under all predicted weather conditions.

Rev. 7 SO_442.doc SO-442 Cooling Towers and Circulating Water System V MAJOR COMPONENTS The major components of the Cooling Towers and Circulating Water System are: List components below" Circ Water Pump Pit" Circulating Water Pumps" Circulating Water Pump Vent Valve E Circulating Water Pump Discharge Valve" Low Pressure Condenser Inlet Isolation Valves" High Pressure Condenser Outlet Isolation Valves* Circulating Water Drain Pump" Cooling Towers and Fans" Cooling Tower Inlet Valves* Cooling Tower Basin SYSTEM OPERATION Circ Water Pump Pit The Circ Water Pump Pit provides the source of water circulated in the Cooling Tower and Circulating Water System. The Cooling Tower basin supplies water to the Circ Water Pump pit by gravity. Makeup for cooling tower evaporation is supplied to the Circ Water Pumphouse Stilling Basin by the River Water System and/or the Well Water System bated on the water level in the cooling tower basin. Water in the Circ Water Pumphouse Stilling Basin enters the Circ Water Pump Pit through a standpipe that connects the two compartments.Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System./ MAJOR COMPONENTS The major components of the Cooling Towers and Circulating Water System are: List components below I!I Circ Water Pump Pit II Circulating Water Pumps

• Circulating Water Pump Vent Valve
• Circulating Water Pump Discharge Valve III Low Pressure Condenser Inlet Isolation Valves III High Pressure Condenser Outlet Isolation Valves
• Circulating Water Drain Pump II Cooling Towers and Fans III Cooling Tower Inlet Valves III Cooling Tower Basin ./ SYSTEM OPERATION eire Water Pump Pit The Circ Water Pump Pit provides the source of water circulated in the Cooling Tower and Circulating Water System. The Cooling Tower basin supplies water to the Circ Water Pump pit by gravity. Makeup for cooling tower evaporation is supplied to the Circ Water Pumphouse Stilling Basin by the River Water System and/or the Well Water System based on the water level in the cooling tower basin. Water in the Circ Water Pumphouse Stilling Basin enters the Circ Water Pump Pit through a standpipe that connects the two compartments.

Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System During full power operation, the level in Circ Water Pump Pit is normally 22 feet. During pump starts, Circ Water Pump Pit level may sustain a temporary drop of up to 6 feet. A low water level in the Circ Water Pump Pit is alarmed at 18 feet (Panel 1 C06A-D1 1). The low water level condition prevents starting either Circ Water Pump, but does not trip any running Circ WaterPump. The start interlock prevents pump cavitation following startup.CWP CWP Vent Discharge CWP START Valve Valve Pump Discharge Valve HO4-4201 ClosedPump Discharge Vent Valve SV-4201 Open Condenser Outlet Valve I MO-4208 Open Condenser Outlet Valve Pump MO-4209 Open Valve, Circ Water Pump Pit Valve. Level Greater than 18 ft Open ...r.... CircnWater Pump 1P04 ...................... .Control HS Start..Pump TDDO Breaker 34Ms --Close Coill -i..... .... .... --............ SV-4201 ' KY-4201 CWP HS contact closed in Energize TDPU START and NORM AFT START to Close --.---------- ,.............. ............................. , Circ Water Pump 1P04 Breaker Closed............................ CWP TRIPPump Discharge Valve Closed Pump Pump Breaker Closed Breaker Trip Coil............ -- -- -- -- -Load Ground .: Shed FaultS. ........ .. * -... .. .. .. ....Over- Differential current .Overcurrent Circulating Water Pumps Two 50% capacity Johnson vertical, mixed flow, wet-pit centrifugal pumps, 1 P-4A and 1 P-4B are used to circulate water in the Cooling Tower and Circulating Water system. The pumps are located approximately 250 feet east of the Turbine Building and provide 150,000 gpm at 88 ft.total head and 356 rpm. The 3800 horsepower GE pump motors are powered from 4160 VAC load centers 1A1 and 1A2. Circ Water Pump breaker control power is from 125 VDC 1D1 1 and 1 D21 respectively. Pump motor space heaters energize to prevent condensation in the motor windings when the pump is idle. The 208 VAC space heaters are powered from lighting panel 1Ll0.Circulating Water pump 1 P-4A (B) is controlled by STOP-NORMAL-START, spring return to NORMAL, handswitch HS-4201 (HS-4202) on Control Room Panel 1 C06. Pump breaker status for stopped (green), running (red) and spring charged (white) is available at Panel 1C06. The Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System-7-During full power operation, the level in Circ Water Pump Pit is normally 22 feet. During pump starts, Circ Water Pump Pit level may sustain a temporary drop of up to 6 feet. A low water level in the Circ Water Pump Pit is alarmed at 18 feet (Panel 1 C06A-D11). The low water level condition prevents starting either Circ Water Pump, but does not trip any running Circ Water Pump. The start interlock prevents pump cavitation following startup. CWP CWP Vent Discharge CWP START Valve Valve Pump Discharge Valve, H0-4201 Open --: SV-4201 : Energize : to Close Pump Discharge Valve H0-4201 Closed Pump Discharge Vent I Valve SV-4201 Open Condenser Outlet Valve I MO-4208 Open I Condenser Outlet Valve MO-4209 Open I , _____ . Cire Water Pump Pit i I Level Greater than 181\ I : * ------.. ClrcWaterPump 1P04-------------------------- .. : Control H S Start , ' , ' Pump Breaker Close Coil i 'CVvP HS contact closed in .:: TDPU : START and NORM AFT START : -------.......... . . t*----***----**---- .. * .. * .......... ". '--: Cire Water Pump 1P04 : : Breal<er Closed .-.0. _. _______ . _____ .. _ .. ____ .. _ Circulating Water Pumps CWPTRIP ..... ___ 0 .................. . . J Pump Discharge: 1 __ ] rl Pump Breaker Trip Coil Ii II f: r ,_. -_ .. _ .. _. _ .. : : Load :_: : Shed : !..----------, . . , , : ........ -.... --... ';: :: Ground :..: : :

: .. ---.-----' . ......................

---

.. : Over-: .... :

• Differential ... : : current : ... _---------, : Overcurrent

----_ .. -_ ............ " Two 50% capacity Johnson vertical, mixed flow, wet-pit centrifugal pumps, 1 P-4A and 1 P-4B are used to circulate water in the Cooling Tower and Circulating Water system. The pumps are located approximately 250 feet east of the Turbine Building and provide 150,000 gpm at 88 ft. total head and 356 rpm. The 3800 horsepower GE pump motors are powered from 4160 VAC load centers 1 A 1 and 1 A2. Circ Water Pump breaker control power is from 125 VDC 1 D11 and 1 D21 respectively.

Pump motor space heaters energize to prevent condensation in the motor windings when the pump is idle. The 208 VAC space heaters are powered from lighting panel 1L 10. Circulating Water pump 1 P-4A (B) is controlled by STOP-NORMAL-START, spring return to NORMAL, handswitch HS-4201 (HS-4202) on Control Room Panel 1 C06. Pump breaker status for stopped (green), running (red) and spring charged (white) is available at Panel 1 C06. The Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System pump start sequence starts the pump and then opens the pump discharge valve. The pump stop sequence shuts the pump discharge valve and then trips the pump.In order to start a Circ Water Pump, the LP Condenser Inlet Isolation valves (MO-4257 and MO-4258) must be verified open at the local control panel and the following electrical interlocks satisfied: " The CW pump discharge valve closed (HO-4201 or HO-4202)" The CW pump vent valve open (CV-4201 or CV-4202)" Both HP Condenser Outlet Isolation valves open (MO-4208 and MO-4209)* Circ Water Pump pit level above 18 feet If a Condenser Circ Water Loop is isolated, then any non-running Circ Water Pump is prevented from starting by the HP Condenser Outlet Isolation valve interlock. Isolating a Condenser Circ Water Loop will not trip any running Circ Water Pumps.A circulating water pump breaker will trip on any of the following:

• Overcurrent
• Ground Fault* Phase differential overcurrent
• Non-essential bus load shedding @ 65% of rated bus voltage* Discharge valve full closed anytime after 3 minutes of pump operation (normal shutdown method)Annunciators, on Panel 1C06-A, associated with Circ Water Pumps are: " "A" CIRC WATER PUMP 1 P-4A TRIP OR MOTOR OVERLOAD (A-1 0)* "B" CIRC WATER PUMP 1P-4B TRIP OR MOTOR OVERLOAD (A-11)" "A" CIRC WATER PUMP 1P-4A HI VIBRATION (B-10)" "B" CIRC WATER PUMP 1 P-4B HI VIBRATION (B-1 1)Rev. 7 SD-442 SD_442.doc Cooling Towers and Circulating Water System pump start sequence starts the pump and then opens the pump discharge valve. The pump stop sequence shuts the pump discharge valve and then trips the pump. In order to start a Circ Water Pump, the LP Condenser Inlet Isolation valves (MO-4257 and MO-4258) must be verified open at the local control panel and the following electrical interlocks satisfied:

II The CW pump discharge valve closed (HO-4201 or HO-4202) III The CW pump vent valve open (CV-4201 or CV-4202)

• Both HP Condenser Outlet Isolation valves open (MO-4208 and MO-4209) II Circ Water Pump pit level above 18 feet If a Condenser Circ Water Loop is isolated, then any non-running Circ Water Pump is prevented from starting by the HP Condenser Outlet Isolation valve interlock.

Isolating a Condenser Circ Water Loop will not trip any running Circ Water Pumps. A circulating water pump breaker will trip on any of the following: III Overcurrent

• Ground Fault
• Phase differential overcurrent
• Non-essential bus load shedding @ 65% of rated bus voltage II Discharge valve full closed anytime after 3 minutes of pump operation (normal shutdown method) Annunciators, on Panel 1 C06-A, associated with eirc Water Pumps are: I!I "A" CIRC WATER PUMP 1P-4A TRIP OR MOTOR OVERLOAD (A-10) * "B" CIRC WATER PUMP 1P-4B TRIP OR MOTOR OVERLOAD (A-11) * "A" CIRC WATER PUMP 1P-4A HI VIBRATION (B-10) * "B" CIRC WATER PUMP 1P-4B HI VIBRATION (B-11) Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System Circulating Water Pump Vent Valves A 4-inch air operated butterfly valve is at the discharge vent of each pump. The solenoid valve that controls motive air for the vent valve is controlled by the discharge valve open position limit switch. The vent valve solenoid receives power from Instrument AC Control Power 1Y1 1 and 1Y21. Instrument and Service Air are required for the vent valve to remain in the closed position.Circulating Water Pump Discharge Valves A 78-inch electro-hydraulically operated butterfly valve, HO-4201 and HO-4202 is at the discharge of each pump. The 78-inch discharge valves are operated using 2100 psig hydraulic oil from hydraulic power unit 1S-92A and 1S-92B. The valves are designed to open within 175 seconds and close in 20 seconds. Timers used by the discharge valve control circuit receive power from Instrument AC Control Power 1Y11A and 1Y21B.AOP 317 Loss of 120 VAC Instrument Control Power 1Y11 ckt 13 Circ. Water Pump HO-4201 control relay KY-4201 control power (HO-4201 fails closed and trips 1P-004A, Circ. Water Pump)1Y21 ckt 01 Circ. Water Pump HO-4202 control relay KY-4202 control power (H04202 fails closed and trips 1 P-004B, Circ. Water Pump)Heeren Co. hydraulic power unit consist of a 2 horsepower 480 VAC, 3 phase, 60 cycle motor powered from 480 VAC MCC 1B13 (1B23) operating at 1800 rpm. The pumps start at 2000 psig pressure lowering.

Annunciator on Panel 1C07A (C-8), CIRC WATER VALVE HO-4201/HO-4202 HYDRAULIC OIL LO PRESSURE, alarms at 1800 psig (lowering) to alert personnel. Each system accumulator has the capacity to stroke the valve at least twice. System reliefvalves protect the components from damage with a setting of 2250 psig. Due to the possibility of the discharge valve position drifting over time upon the loss of hydraulic pressure, this pressure is maintained to ensure that the discharge valve remains open during operation. Rev. 7 SD-442 SD_442.doc Cooling Towers and Circulating Water System Circulating Water Pump Vent Valves A 4-inch air operated butterfly valve is at the discharge vent of each pump. The solenoid valve that controls motive air for the vent valve is controlled by the discharge valve open position limit switch. The vent valve solenoid receives power from Instrument AC Control Power 1Y11 and 1 Y21. Instrument and Service Air are required for the vent valve to remain in the closed position. Circulating Water Pump Discharge Valves A 78-inch electro-hydraulically operated butterfly valve, HO-4201 and HO-4202 is at the discharge of each pump. The 78-inch discharge valves are operated using 2100 psig hydraulic oil from hydraulic power unit 1 S-92A and 1 S-928. The valves are designed to open within 175 seconds and close in 20 seconds. Timers used by the discharge valve control circuit receive power from Instrument AC Control Power 1Y11A and 1Y218. AOP 317 Loss of 120 VAC Instrument Control Power 1 Y11 ckt 13 Circ. Water Pump HO-4201 control relay KY-4201 control power (HO-4201 fails closed and trips 1 P-004A, Circ. Water Pump) 1Y21 ckt 01 Circ. Water Pump HO-4202 control relay KY-4202 control power (H04202 fails closed and trips 1 P-0048, Circ. Water Pump) Heeren Co. hydraulic power unit consist of a 2 horsepower 480 VAC, 3 phase, 60 cycle motor powered from 480 VAC MCC 1813 (1823) operating at 1800 rpm. The pumps start at 2000 psig pressure lowering. Annunciator on Panel1C07A (C-8), CIRC WATER VALVE HO-4201/HO-4202 HYDRAULIC OIL LO PRESSURE, alarms at 1800 psig (lowering) to alert personnel. Each system accumulator has the capacity to stroke the valve at least twice. System relief valves protect the components from damage with a setting of 2250 psig. Due to the possibility of the discharge valve position drifting over time upon the loss of hydraulic pressure, this pressure is maintained to ensure that the discharge valve remains open during operation. Rev. 7 SO_442.doc SO-442 Cooling Towers and Circulating Water System Inlet Isolation Valve LOCAL-REMOTE --HS in LOCAL -'-Outlet Isolation Valve CWP A Off CWP B Off HS in CLOSE HS in OPEN HS in CLOSE Inlet Valve Close Coil Inlet Valve Open Coil Outlet Valve Outlet Valve Close Coil Open Coil Main Condenser Circ Water Inlet Isolation Valves Two 90 inch motor operated butterfly valves (MO-4257 Outer Loop and MO-4258 Inner Loop)are located at the low pressure condenser inlet for isolation purposes. Each condenser inlet isolation valve is controlled by a local OPEN -NORMAL-CLOSE, spring return to NORMAL handswitch (HS-4257 and HS-4258) in the TB 734' Condenser Bay. The control circuit for each low pressure condenser inlet isolation valve is isolated by a local LOCAL-OFF-REMOTE keylock switch (HS-4257A and HS-4258A) at the same panel as HS-4257 and HS-4258. Valve position is only available locally. The power supply for MO-4257 and MO-4258 is 480 VAC MCC 1 B62.Rev. 7 SD-442 SD_442.doc Cooling Towers and Circulating Water System Inlet Isolation Valve HS in LOCAL T HS in CLOSE T T f T HS in OPEN r 42-0"-l 42-0 42-C 42-C Inlet Valve Close Coil 42-0 Inlet Valve Open Coil Outlet Isolation Valve CWP A Off CWP B Off ................ Pu*rri p*********** Permissive HS in Override 42-C HS in CLOSE T T q HS in OPEN r 42-0 Outlet Valve Close Coil LS LS 42-C 42-0 Outlet Valve Open Coil Main Condenser eire Water Inlet Isolation Valves Two 90 inch motor operated butterfly valves (MO-4257 Outer Loop and MO-4258 Inner Loop) are located at the low pressure condenser inlet for isolation purposes. Each condenser inlet isolation valve is controlled by a local OPEN -NORMAL-CLOSE, spring return to NORMAL handswitch (HS-4257 and HS-4258) in the TB 734' Condenser Bay. The control circuit for each low pressure condenser inlet isolation valve is isolated by a local LOCAL-OFF-REMOTE keylock switch (HS-4257 A and HS-4258A) at the same panel as HS-4257 and HS-4258 .. Valve position is only available locally. The power supply for MO-4257 and MO-4258 is 480 VAG MCC 1B62. Rev. 7 SO_442.doc 80-442 Cooling Towers and Circulating Water System Each Inlet isolation valve has a manually actuated cam head locking mechanism. Normally the cam head sits in a recession in the valve body and is disconnected from the operating shaft. To lock the valve disk in the closed position, the cam lock is extended by rotating the operating handwheel until the cam head lock and shaft are fully extended. When the cam lock and shaft are fully extended, the key is inserted through the handwheel and shaft to connect the cam lock to the handwheel. The cam lock head is then rotated to the valve disk strike plate in order to lock the isolation valve in the closed position. The cam head lock is pointing at the valve disk strike plate when the arrow on the end of the shaft is pointing to the valve disk. The cam lock can be restrained by either a set screw in the handwheel or a chain-lock arrangement. Removing the cam head lock is basically a reversal of the actions taken to lock the valve.Main Condenser Circ Water Outlet Isolation Valves Two 78 inch motor operated butterfly valves (MO-4208 Outer Loop and MO-4209 Inner Loop)are located at the high pressure condenser outlet for isolation purposes. The condenser outlet isolation valves are controlled by CLOSE-NORMAL-OPEN, spring return to NORMAL, hand switches at Panel 1006. Power supply for MO-4208 and MO-4209 is 480 VAC MOO 1 B62. The closing circuit for each motor operated valve (MO-4208 and MO-4209) is normally interlocked such that the Circ Water Outlet valve can only be closed when both Circulating Water pump breakers are open. This interlock can be bypassed using Circ Pump Permissive Override handswitch HS-4208A (HS-4209A) when it is necessary to isolate a Circulating Water Loop (Inner or Outer) for maintenance during power operation. Rev. 7 SD-442 SD_442.doc Cooling Towers and Circulating Water System Inlet Valve Disk valve Disk Sir ike Plale C::tm Lock H""d Retruded Each Inlet isolation valve has a manually actuated cam head locking mechanism. Normally the cam head sits in a recession in the valve body and is disconnected from the operating shaft. To lock the valve disk in the closed position, the cam lock is extended by rotating the operating handwheel until the cam head lock and shaft are fully extended. When the cam lock and shaft are fully extended, the key is inserted through the handwheel and shaft to connect the cam lock to the handwheel. The cam lock head is then rotated to the valve disk strike plate in order to lock the isolation valve in the closed position. The cam head lock is pointing at the valve disk strike plate when the arrow on the end of the shaft is pointing to the valve disk. The cam lock can be restrained by either a set screw in the handwheel or a chain-lock arrangement. Removing the cam head lock is basically a reversal of the actions taken to lock the valve. Main Condenser Cire Water Outlet Isolation Valves Two 78 inch motor operated butterfly valves (MO-4208 Outer Loop and MO-4209 Inner Loop) are located at the high pressure condenser outlet for isolation purposes. The condenser outlet isolation valves are controlled by CLOSE-NORMAL-OPEN, spring return to NORMAL, hand switches at Panel 1 COS. Power supply for MO-4208 and MO-4209 is 480 VAC MCC 18S2. The closing circuit for each motor operated valve (MO-4208 and MO-4209) is normally interlocked such that the Circ Water Outlet valve can only be closed when both Circulating Water pump breakers are open. This interlock can be bypassed using Circ Pump Permissive Override handswitch HS-4208A (HS-4209A) when it is necessary to isolate a Circulating Water Loop (Inner or Outer) for maintenance during power operation. Rev. 7 SO_442.doc SO-442 Cooling Towers and Circulating Water System Outer Loop To Cooling Water Drain Basin Water Pumps Circulatinq Water Drain Pump A Gould horizontal centrifugal pump with the capacity of 650 gpm at an 80 ft head at 1750 rpm is provided to drain the condenser water boxes for servicing. The drain pump, 1 P7, is a 20 horsepower 480VAC, 3 phase 60 Hz powered from MCC 11B33. The drain pump is controlled by local STOP-START pushbuttons, HS-4210, and provided with indicating lights, pump stopped (green) and pump running (red). During partial Condenser Circ Water Loop isolation conditions, pump down capability is provided by connections from each inlet and outlet water box to the 1 P-7 Suction. 3-inch drain lines on the West 'E', 'F', 'G', and 'H' water boxes provide enhanced drain capacity.Cooling Tower Inlet and Sparging ValvesFour motor operated 60 inch butterfly valves (MO-4249, MO-4250, MO-4251 and MO-4252)control the distribution of Circulating Water within the Cooling Towers. These valves can be opened, throttled or closed to send water to the cooling tower fans or in conjunction with the sparger bypass valve to the cooling tower basin. The tower inlet valves are controlled by key operated CLOSE-NORMAL-OPEN, spring return to NORMAL hand switches in the vicinity of the Cooling Tower switchgear. Keys are removable only in the NORMAL position.Rev. 7 SD-442 SD_442.doc Cooling Towers and Circulating Water System Outer Loop r Inner Loop

• I High Pressure Condenser Low Pressure 1 E-7B Condenser 1E-7A -, t . MO-MO-

< 4208 . 4209 4258 ,. 4257 AB T " CircWater Drain Pump 0: j>.HQ-4202 0: j>.HO-4201 To Cooling Water From Cire Drain Basin Water Pum ps Circulating Water Drain Pump A Gould horizontal centrifugal pump with the capacity of 650 gpm at an 80 ft head at 1750 rpm is provided to drain the condenser water boxes for servicing. The drain pump, 1 P7, is a 20 horsepower 480VAC, 3 phase 60 Hz powered from MCC 1833. The drain pump is controlled by local STOP-START push buttons, HS-4210, and provided with indicating lights, pump stopped (green) and pump running (red). During partial Condenser Circ Water Loop isolation conditions, pump down capability is provided by connections from each inlet and outlet water box to the 1P-7 Suction. 3-inch drain lines on the West 'E', 'F', 'G', and 'H' water boxes provide enhanced drain capacity. Cooling Tower Inlet and Sparging Valves Four motor operated 60 inch butterfly valves (MO-4249, MO-4250, MO-4251 and MO-4252) control the distribution of Circulating Water within the Cooling Towers. These valves can be ( opened, throttled or closed to send water to the cooling tower fans or in conjunction with the sparger bypass valve to the cooling tower basin. The tower inlet valves are controlled by key operated CLOSE-NORMAL-OPEN,spring return to NORMAL hand switches in the vicinity of the Cooling Tower switchgear. Keys are removable only in the NORMAL position. Rev. 7 SD_ 442.doc SD-442 Cooling Towers and Circulating Water System Cooling Tower Inlet Valve; MO-4250 for Cooling Tower 1 E-69A and MO-4251 for Cooling Tower 1E-69B, is interlocked with the respective manually operated 16 inch sparging bypass valve such that the tower inlet valve can only be closed electrically when the sparging bypass valve is opened beyond the limit switch setting. Raising sparging flow will result in rising circ water temperature in the water returning to the Circ Water pit. 480 VAC MCC 1 B71 provides power for Cooling Tower 1 E-69A inlet valves and MCC 1 B81 provides power for Cooling Tower 1 E-69B inlet valves.Cooling Towers and Fans Each Cooling Tower is a twelve cell, cross-flow, forced draft heat sink capable of transferring 1.82 x 103 MBtu/hr at 155,000 gpm with a design inlet temperature of 11 2 0 F and outlet temperature of 87 0 F. The Cooling Towers are sized to reject heat from the Circulating Water, General Service Water, Residual Heat Removal Service Water, Emergency Service Water and Well Water Systems. Each Cooling Tower cell contains a 28 foot diameter, motor driven, single speed, reversible,137 rpm gear reduced fan. The fan motors are rated at 200 horsepower at 1785 rpm. The fan blades are pitched at 12.75 degrees and have the capacity to move 1.47 x 106 scfm. Each Cooling Tower fan is individually controlled using a REVERSE-OFF-FORWARD handswitch on Panel 1 C06 with green (fan stopped) and red (fan running) indicating lights. The fans for Cooling Tower 1 E-69A and 1 E-69B are powered from 480 VAC load centers 1 B7 and 1 B8 respectively. To start a fan in FORWARD or REVERSE, the fan has to have been stopped for at least three minutes. The following conditions will trip a Cooling Tower Fan: N High vibration. E Cooling tower fire protection deluge (4-8 psig downstream of the cell deluge valve)E Overload condition Fan motor space heaters energize to prevent condensation in the motor windings when the fan is idle. 120 VAC power for winding heaters is supplied from 1 L71 and 1 L81.Rev. 7 SD-442 SD_442.doc Cooling Towers and Circulating Water System Cooling Tower Inlet Valve; MO-4250 for Cooling Tower 1 E-69A and MO-4251 for Cooling Tower 1 E-698, is interlocked with the respective manually operated 16 inch sparging bypass valve such that the tower inlet valve can only be closed electrically when the sparging bypass valve is opened beyond the limit switch setting. Raising sparging flow will result in rising circ water temperature in the water returning to the Circ Water pit. 480 VAC MCC 1871 provides power for Cooling Tower 1 E-69A inlet valves and MCC 1881 provides power for Cooling Tower 1 E-698 inlet valves. Cooling Towers and Fans Each Cooling Tower is a twelve cell, cross-flow, forced draft heat sink capable of transferring 1.82 x 10 3 M8tu/hr at 155,000 gpm with a design inlet temperature of 112°F and outlet temperature of 87°F. The Cooling Towers are sized to reject heat from the Circulating Water, General Service Water, Residual Heat Removal Service Water, Emergency Service Water and Well Water Systems. Each Cooling Tower cell contains a 28 foot diameter, motor driven, single speed, reversible, 137 rpm gear reduced fan. The fan motors are rated at 200 horsepower at 1785 rpm. The fan blades are pitched at 12.75 degrees and have the capacity to move 1.47 x 10 6 scfm. Each Cooling Tower fan is individually controlled using a REVERSE-OFF-FORWARD handswitch on Panel 1 C06 with green (fan stopped) and red (fan running) indicating lights. The fans for Cooling Tower 1 E-69A and 1 E-698 are powered from 480 VAC load centers 187 and 188 respectively. To start a fan in FORWARD or REVERSE, the fan has to have been stopped for at least three minutes. The following conditions will trip a Cooling Tower Fan:

• High vibration.
• Cooling tower fire protection deluge (4-8 psig downstream of the cell deluge valve)
• Overload condition Fan motor space heaters energize to prevent condensation in the motor windings when the fan is idle. 120 VAC power for winding heaters is supplied from 1 L71 and 1 L81. Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System Annunciators on Panel 1C06-A associated with the fans are: M "A" COOLING TOWER 1E-69A FAN TROUBLE (A-5)I "B" COOLING TOWER 1 E-69B FAN TROUBLE (A-6)---------------------

f ------------------------------- , River Water System Towers Circ Water Pump Pit Coolinq Tower Basin The basin is the collection point of either the gravity drains from the tower and the bypassed sparger flow. The basin water level is monitored and transmitted by level transmitter LT-4231(LT-4232) for Tower 1 E-69A (1 E-69B) to indicators LIC-4231 and LIC-4232 on Control Room Panel 1C06. A selector switch, HSS-4919, determine which controller regulates river water supply flow to the stilling basin.The controlling Cooling Tower basin will signal for makeup water when the level is down to 3 inches below the normal level and will continue to signal for makeup water until the water level in the Cooling Tower basin rises 6 inches above the normal level.Each Cooling Tower basin level indicator is equipped with a level switch, LS-4229 (LS-4230), for Tower 1 E-69A (1 E-69B) respectfully, which activates an annunciator on Panel 1C06 A (B-5&6) ("A/B" COOLING TOWER BASIN HI/LO LEVEL). These level alarms are 4 inches above and 18 inches below the normal operating level. This physically equates to 8 inches and 30 inches below the top of the basin lip respectfully. The basin overflows at 53" on LI-4231.Rev. 7 SD-442 SD_442.doc Cooling Towers and Circulating Water System Annunciators on Panel 1 C06-A associated with the fans are: III "A" COOLING TOWER 1 E-69A FAN TROUBLE (A-5) 12 "B" COOLING TOWER 1 E-69B FAN TROUBLE (A-6) River Water System Cooling , , , OlO Stilling Basin ------T-------, , Qo>> : ""Ol ,,;0 : co;o mJ: I mJ:

: I I Cooling Tower Basin CircWater Pump Pit Towers ,------, ,------, Basiri Basin The basin is the collection point of either the gravity drains from the tower and the bypassed sparger flow. The basin water level is monitored and transmitted by level transmitter L T-4231 (L T-4232) for Tower 1 E-69A (1 E-69B) to indicators LlC-4231 and LlC-4232 on Control Room Panel 1 C06. A selector switch, HSS-4919, determine which controller regulates river water supply flow to the stilling basin. The controlling Cooling.Tower basin will signal for makeup water when the level is down to 3 inches below the normal level and will continue to signal for makeup water until the water level in the Cooling Tower basin rises 6 inches above the normal level. Each Cooling Tower basin level indicator is equipped with a level switch, LS-4229 (LS-4230), for Tower 1 E-69A (1 E-69B) respectfully, which activates an annunciator on Panel 1 C06 A (B-5&6) ("NB" COOLING TOWER BASIN HIILO LEVEL). These level alarms are 4 inches above and 18 inches below the normal operating level. This physically equates to 8 inches and 30 inches below the top of the basin lip respectfully.

The basin overflows at 53" on LI-4231. Rev. 7 SO_442.doc S0-442 Cooling Towers and Circulating Water System The basin drain for each Cooling Tower is equipped with concrete slab isolation stop logs for use during maintenance on the respective tower.Normal Operation Both Circulating Water pumps take suction on the Circ Water Pit and discharge to the Low Pressure Condenser inlet via individual discharge valves and lines. Chemicals are added to the Circulating Water prior to the Main Condenser to control slime, algae growth and scale formation. Circulating Water flows through the low pressure condenser tubes crosses over and flows through the high pressure condenser tubes from west to east. Isolation valves MO-4257 or MO-4258 at the LP Condenser inlet water boxes in conjunction with HP Condenser outlet MO-4208 or MO-4209 provide for partial Main Condenser Outer or Inner Loop Circ Water isolation and pump down for maintenance at reduced Reactor Power. A return line from the General Service Water System and from the Circulating Water Drain Pump feeds into one of the HP Condenser lines before the two lines combine into a single header heading toward the Cooling Towers. The Residual Heat Removal Service Water, Emergency Service Water and Well Water systems inject into the combined Circulating Water discharge line from the Main Condenser. The Circulating Water header splits into two lines near the Cooling Towers and flows through two risers with motor operated butterfly valves to the top of the tower. Each tower is equipped with a sparging bypass line with a manually operated valve that can be set to allow part of the Circulating Water to discharge directly to the tower basin. The temperature of the water in the tower basins should be maintained between 60°F and 70 0 F. Several schemes are available to regulate the temperature as the heat load changes. Some fans can be turned off, or some cells can be completely taken out of service by manually closing the distribution valves at the top of the tower. The Cooling Towers fans may be operated in the reverse direction for winter operation to eliminate icing, and for drying out the cell. The sparging bypass lines may be used for temperature control by diverting part of the Circulating Water to the tower basins. Normally open motor operated inlet valves are throttled to prevent pump runout as the sparging bypass valves are opened. Annunciator on Panel 1C06-B, TURBINE INSTRUMENT PANEL 1C20 TROUBLE, alerts personnel to an increasing temperature of 120 degrees in the system.After cooling, the Circulating Water collects in the Cooling Tower basin and drains back to the Circulating Water pit by gravity. Water required to replace evaporation and blowdown losses is Rev. 7 SD-442 SD_442.doc Cooling Towers and Circulating Water System The basin drain for each Cooling Tower is equipped with concrete slab isolation stop logs for use during maintenance on the respective tower. Normal Operation Both Circulating Water pumps take suction on the Circ Water Pit and discharge to the Low Pressure Condenser inlet via individual discharge valves and lines. Chemicals are added to the Circulating Water prior to the Main Condenser to control slime, algae growth and scale formation. Circulating Water flows through the low pressure condenser tubes crosses over and flows through the high pressure condenser tubes from west to east. Isolation valves MO-42S7 or MO-42S8 at the LP Condenser inlet water boxes in conjunction with HP Condenser outlet MO-4208 or MO-4209 provide for partial Main Condenser Outer or Inner Loop Circ Water isolation and pump down for maintenance at reduced Reactor Power. A return line from the General Service Water System and from the Circulating Water Drain Pump feeds into one of the HP Condenser lines before the two lines combine into a single header heading toward the Cooling Towers. The Residual Heat Removal Service Water, Emergency Service Water and Well Water systems inject into the combined Circulating Water discharge line from the Main Condenser. The Circulating Water header splits into two lines near the Cooling Towers and flows through two risers with motor operated butterfly valves to the top of the tower. Each tower is equipped with a sparging bypass line with a manually operated valve that can be set to allow part of the Circulating Water to discharge directly to the tower basin. The temperature of the water in the tower basins should be maintained between 60°F and 70°F. Several schemes are available to regulate the temperature as the heat load changes. Some fans can be turned off, or some cells can be completely taken out of service by manually closing the distribution valves at the top of the tower. The Cooling Towers fans may be operated in the reverse direction for winter operation to eliminate icing, and for drying out the cell. The sparging bypass lines may be used for temperature control by diverting part of the Circulating Water to the tower basins. Normally open motor operated inlet valves are throttled to prevent pump runout as the sparging bypass valves are opened. Annunciator on Pane11C06-B, TURBINE INSTRUMENT PANEL 1C20 TROUBLE, alerts personnel to an increasing temperature of 120 degrees in the system. After cooling, the Circulating Water collects in the Cooling Tower basin and drains back to the Circulating Water pit by gravity. Water required to replace evaporation and blowdown losses is Rev. 7 SO_442.doc SO-442 Cooling Towers and Circulating Water System supplied by the River Water Supply System. River Water is pumped to the RHRSW/ESW stilling basin to overflow to the circulating water pump wet pit through a standpipe. The rate of makeup water delivery is proportional to the level in the Cooling Tower basins. At full power, approximately 6000 -8000 gpm (with a nominal 1500 gpm supplied by well water) will be required to make up for Cooling Tower evaporation and blowdown.A line from the discharge of Circulating Water Pump 1 P-4A directs water from the Circulating Water System through the Radwaste Dilution Structure to the Cedar River to remove impurities. line to the Cedar River may be utilized for RWS Intake deicing.Starting And Stopping A Circ Water Pump Circ Water Pump handswitch HS-4201 (HS-4202), on Control Room Panel 1C06, also controls hydraulic power unit 1 S92A (1 S92B). When the Circ Water Pump handswitch is placed in START, the Circ Water Pump and the respective Pump Discharge Valve hydraulic power unit start. The Pump Discharge Valve HO-4201 (HO-4202) starts to open 30 seconds after the respective pump breaker closes. The hydraulically operated discharge valve takes 145 to 175 seconds to stroke open. When Pump Discharge Valve, HO-4201 (HO-4202), is full open, a solenoid energizes to pressurize and close air operated vent valve CV-4201 (CV-4202). When the Circ Water Pump handswitch HS-4201 (HS-4202), is turned to STOP, the hydraulically operated discharge valve moves from full open to 60% in 5 seconds and continues from 60% open to full closed in another 15 seconds. The associated vent valve opens whenthe discharge valve leaves the full open position. The Circ Water Pump breaker trips when the discharge valve reaches its fully closed position, 120VAC Uninterruptible Power is utilized for the following instrumentation: " TRS-4200, Circ Water/Condenser Temp Recorder" LT-4212, Circ Water Pump Pit Level* FT-4247, Circ Water Blowdown Flow" PT-4205, Circ Water Discharge Pressure.Abnormal Operation During a plant shutdown to cold conditions, both Circulating Water pumps are shutdown.Valves MO-4208 and MO-4209 are closed and one Cooling Tower is left in operation to cool General Service Water, RHR Service Water, Emergency Service Water and Well Water Rev. 7 SD-442 SD_442.doc - CoolingTowers and Circulating Water System supplied by the Water Supply System. River Water is pumped to the RHRSW/ESW stilling basin to overflow to the circulating water pump wet pit through a standpipe. The rate of makeup water delivery is proportional to the level in the Cooling Tower basins. At full power, approximately 6000 -8000 gpm (with a nominal 1500 gpm supplied by well water) will be required to make up for Cooling Tower evaporation and blowdown. A line from the discharge of Circulating Water Pump 1 P-4A directs water from the Circulating Water System through the Radwaste Dilution Structure to the Cedar River to remove impurities. line to the Cedar River may be utilized for RWS Intake deicing. Starting And Stopping A eire Water Pump Circ Water Pump handswitch HS-4201 (HS-4202), on Control Room Panel 1 C06, also controls hydraulic power unit 1 S92A (1 S92B). When the Circ Water Pump handswitch is placed in START, the Circ Water Pump and the respective Pump Discharge Valve hydraulic power unit start. The Pump Discharge Valve HO-4201 (HO-4202) starts to open 30 seconds after the respective pump breaker closes. The hydraulically operated discharge valve takes 145 to 175 seconds to stroke open. When Pump Discharge Valve, HO-4201 (HO-4202), is full open, a solenoid energizes to pressurize and close air operated vent valve CV-4201 (CV-4202). When the Circ Water Pump handswitch HS-4201 (HS-4202), is turned to STOP, the hydraulically operated discharge valve moves from full open to 60% in 5 seconds and continues from 60% open to full closed in another 15 seconds. The associated vent valve opens when the discharge valve leaves the full open position. The Circ Water Pump breaker trips when the discharge valve reaches its fully closed position, 120VAC Uninterruptible Power is utilized for the following instrumentation:

• TRS-4200, Circ Water/Condenser Temp Recorder
• LT-4212, Circ Water Pump Pit Level
• FT-4247, Circ Water Blowdown Flow
• PT -4205, Circ Water Discharge Pressure.

Abnormal Operation During a plant shutdown to cold conditions, both Circulating Water pumps are shutdown. Valves MO-4208 and MO-4209 are closed and one Cooling Tower is left in operation to cool General Service Water, RHR Service Water, Emergency Service Water and Well Water Rev. 7 SO_442.doc -*16 -S0-442 Cooling Towers and Circulating Water System System heat loads. RHR Service Water System, Emergency Water System, GSW and Well Water System can be discharged directly to the river via the dilution structure and dischargecanal when no cooling towers are available. During plant shutdown, the Main Condenser water boxes may be drained. This is accomplished by closing the HP Condenser discharge valves MO-4208 and MO-4209, manually opening the inlet valves to the Circulating Water Drain Pump 1 P-7, and starting the pump. The hand operated gate valve on the discharge side of the pump is then opened, and subsequently closed as soon as the drainage is complete. Additional drainage may be provided via hoses routed to the MUD Chem Waste Sump.Isolating a Circulating Water Loop -Inner or Outer Reduce Reactor Power to allow taking one Cooling Tower and Circ Water Pump out of service.In the Condenser Bay, Open the Outer/Inner Loop 1 P-7 suction isolation valves to provide overpressure protection while isolating a Main Condenser Circ Water Loop. For the loop selected to be isolated for maintenance, energize and close the LP Condenser Circ Water Inlet (MO-4257 Outer Loop or MO-4258 Inner Loop) isolation valve. Manually engage both redundant disc-locking devices. In the Condenser Bay, at local Panel 1C498, place HS-4209A or HS-4208A Circ Pump Permissive Override Handswitch to OVERRIDE. In the Control Room at Panel 1C06 Close MO-4209 Outer Loop or MO-4208 Inner Loop Outlet isolation valve.LP Turbine exhaust steam will continuously add heat to the isolated loop. The only pressure indication of the isolated Condenser Loop will be the 1 P-7 Pump Suction Pressure PI-4238A.Control.the isolated loop pressure by throttling OPEN the associated loop Water Box East and West vent valves. Rev. 7 SD-442 SD_442.doc Cooling Towers and Circulating Water System System heat loads. RHR Service Water System, Emergency Water System, GSW and Well Water System can be discharged directly to the river via the dilution structure and discharge canal when no cooling towers are available. During plant shutdown, the Main Condenser water boxes may be drained. This is accomplished by closing the HP Condenser discharge valves MO-4208 and MO-4209, manually opening the inlet valves to the Circulating Water Drain Pump 1 P-7, and starting the pump. The hand operated gate valve on the discharge side of the pump is then opened, and subsequently closed as soon as the drainage is complete. Additional drainage may be provided via hoses routed to the MUD Chem Waste Sump. Isolating a Circulating Water Loop -Inner or Outer Reduce Reactor Power to allow taking one Cooling Tower and Circ Water Pump out of service. In the Condenser Bay, Open the Outer/Inner Loop 1 P-7 suction isolation valves to provide overpressure protection while isolating a Main Condenser Circ Water Loop. For the loop selected to be isolated for maintenance, energize and close the LP Circ Water Inlet (MO-4257 Outer Loop or MO-4258 Inner Loop) isolation valve. Manually engage both redundant disc-locking devices. In the Condenser Bay, at local Panel 1 C498, place HS-4209A . or HS-4208A Circ Pump Permissive Override Handswitch to OVERRIDE. In the Control Room at Panel 1 C06 Close MO-4209 Outer Loop or MO-4208 Inner Loop Outlet isolation valve. LP Turbine exhaust steam will continuously add heat to the isolated loop. The only pressure indication of the isolated Condenser Loop will be the 1 P-7 Pump Suction Pressure PI-4238A. Controlthe isolated loop pressure by throttling OPEN the associated loop Water Box East and West vent valves. Rev. 7 SO_442.doc SO-442 Cooling Towers and Circulating Water System V' SYSTEM INTERRELATIONS SD-heading-2 should be used below for the headings Storm Sewer x U)co1 E-153B ESW ESW SH.P. L.P.EDG Coolers Cond. Cond.1 E-53A o. MO-4208 MO-4209-- Well Water MO-42 MO-4257 Ot DilutionnDischarge Canal Struture GSW V42-11 V42-09 V42-120 De-icing Blowdown Intake 910-C14975 CV- AW Structure -f: 1 B 1P-4B c a G-K- " 1ae Pit9 M C dCirculating1 P-1 17CT-I Water Pit Main Condenser The Circulating Water travels through the low pressure section of the condenser first, then the high pressure section of the condenser, providing a heat sink to condense steam exhausted from the turbine.For additional information, refer to SD-691, Main Condenser and Main Condenser Air Removal System.Residual Heat Removal Service Water The Cooling Towers receive the Residual Heat Removal Service Water when the Residual Heat Removal System is operating in the shutdown cooling, containment spray, or Torus Cooling or spray modes.For additional information, refer to SD-416, RHR Service Water System Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System../ SYSTEM INTERRELATIONS SO-heading-2 should be used below for the headings o (1) 0. '" ;u <' Disch , Storm :.J Sewer I :.J (fJ :i! 1E-53B EDG Coolers 1E-53A I I

• I argo Canal Dilution , I > II' V42-11 ,I::: -I--I-<I-c

> V42-09 V42-12 t De-icing '---Slowdown r V42-10 CV-4909 CV-491DB -CV-4914 1P-117B I CV-4915 CV-491OA ::0 I ::0 (fJ Well Water .. cJ MO-42OB ... c: Intake $tructure JBaSin 1P-48 1P-4A , 1 " I Circulating Water Pit lP-22D lP-22B 1P-nc lP-22A A Pump House I Main Condenser H.P. L.P. Condo Condo MO-4209 MO-4258 MO-4257 --g;A-l Cooling Towers }G," V 1P-89A ,if if }Fire Protection .I The Circulating Water travels through the low pressure section of the condenser first, then the high pressure section of the condenser, providing a heat sink to condense steam exhausted from the turbine. For additional information, refer to SO-691, Main Condenser and Main Condenser Air Removal System. Residual Heat Removal Service Water The Cooling Towers receive the Residual Heat Removal Service Water when the Residual Heat Removal System is operating in the shutdown cooling, containment spray, or Torus Cooling or spray modes_ For additional information, refer to SO-416, RHR Service Water System Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System Emerqencv Service Water The Cooling Towers provide a discharge path for the Emergency Service Water System.For additional information, refer to SD-454, Emergency Service Water General Service Water The General Service Water pumps take suction from the Circulating Water pump pit and supply its various loads before returning to the Circulating Water System just downstream of the highpressure condenser. The General Service Water System also provides cooling water for the Circulating Water Pump bearing lube oil and motor windings.For additional information, refer to SD-41 1, General Service Water System.Liquid Radwaste System Processed liquid radioactive wastes can be diluted with water from the River Water Supply System and then combined with the blowdown from the Circulating Water System in the dilution structure. This water can then be discharged to the river via the discharge canal.Note: Radwaste policy is to process all liquids and return to the Condensate Storage Tanks.The discharge path to the river has not and will continue to not be normally used.For additional information, refer to SD-969.1, Liquid Radwaste System.River Water Supply System The River Water Supply System pumps water to the stilling basin, which overflows through a standpipe to maintain water level in the Circulating Water pump pit. The flow of river water for makeup is controlled by Cooling Tower basin level.Loss of River Water System will result in decreasing level in the Circ Water Pump Pit level.For additional information, refer to SD-410, River Water Supply and Intake Structure. Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System Emergency Service Water The Cooling Towers provide a discharge path for the Emergency Service Water System. For additional information, refer to SO-454, Emergency Service Water General Service Water The General Service Water pumps take suction from the Circulating Water pump pit and supply its various loads before returning to the Circulating Water System just downstream of the high pressure condenser. The General Service Water System also provides cooling water for the Circulating Water Pump bearing lube oil and motor windings. For additional information, refer to SO-411, General Service Water System. Liquid Radwaste System Processed liquid radioactive wastes can be diluted with water from the River Water Supply System and then combined with the blowdown from the Circulating Water System in the dilution structure. This water can then be discharged to the river via the discharge canal. Note: Radwaste policy is to process all liquids and return to the Condensate Storage Tanks. The discharge path to the river has not and will continue to not be normally used. For additional information, refer to SO-969.1, Liquid Radwaste System. River Water Supply System The River Water Supply System pumps water to the stilling basin, which overflows through a standpipe to maintain water level in the Circulating Water pump pit. The flow of river water for makeup is controlled by Cooling Tower basin level. Loss of River Water System will result in decreasing level in the Circ Water Pump Pit level. For additional information, refer to SO-41 0, River Water Supply and Intake Structure. Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System Well Water System The Circulating Water pump seals are supplied from the Well Water System. The Well Water System discharges to the Circulating Water System downstream of the High Pressure Condenser. Loss of Well Water System results in loss of seal water supply.For additional information, refer to SD-408, Well Water System.Cooling Water Treatment System Sodium Hypochlorite biocide is added to the discharge of the Circulating Water Pumps to control slime and biological growth in the circulating water and condenser systems. A corrosion inhibitor, surfactant, and dispersant are added to the GSW system, which returns to the circulating water pit to treat the circulating water system and main condenser. The Acid System functions to maintain the pH of the Circulating Water and GSW Systems by injecting sulfuric acid into the circ. pit For additional information, refer to SD-442.1, Circ Water Chemical Feed System.Instrument and Service Air System Operating air for the air operated vent valves CV-4201 and CV-4202 is supplied from the Instrument and Service Air System. Also, Instrument Air is utilized for pit level indication. Loss of Instrument and Service Air results in vent valve failing open and low level in the Circ Water Pump Pit. This loss of instrument air causes River Water System Makeup Valves, CV-4914and 4915 to fail open. These valves also fail open on loss of 120 VAC Instrument Control Power.For additional information, refer to SD-518, Instrument and Service Air and Breathing Air Systems.Makeup Demineralizer System Connecting hoses to the isolated Outer/Inner Loop west side water box 3 inch drain valves facilitates drain down flowrate. Hoses are routed through wall penetrations to the Chemical Waste Sump. Maintain continuous monitoring at the Chemical Waste Sump in coordination with drain valve operation. Throttle the drain flowrate to within the capacity of the Chemical Waste Sump Pumps 1P-103A/B. Rev. 7 SD-442 SD_442.doc Cooling Towers and Circulating Water System Well Water System The Circulating Water pump seals are supplied from the Well Water System. The Well Water System discharges to the Circulating Water System downstream of the High Pressure Condenser. Loss of Well Water System results in loss of seal water supply. For additional information, refer to SO-408, Well Water System. Cooling Water Treatment System Sodium Hypochlorite biocide is added to the discharge of the Circulating Water Pumps to control slime and biological growth in the circulating water and condenser systems. A corrosion inhibitor, surfactant, and dispersant are added to the GSW system, which returns to the circulating water pit to treat the circulating water system and main condenser. The Acid System functions to maintain the pH of the Circulating Water and GSW Systems by injecting sulfuric acid into the circ. pit For additional information, refer to SO-442.1, Circ Water Chemical Feed System. Instrument and Service Air System Operating air for the air operated vent valves CV-4201 and CV-4202 is supplied from the Instrument and Service Air System. Also, Instrument Air is utilized for pit level indication. Loss of Instrument and Service Air results in vent valve failing open and low level in the Circ Water Pump Pit. This loss of instrument air causes River Water System Makeup Valves, CV-4914 and 4915 to fail open. These valves also fail open on loss of 120 VAC Instrument Control Power. For additional information, refer to SO-518, Instrument and Service Air and Breathing Air Systems. Makeup Demineralizer System Connecting hoses to the isolated Outer/lnner Loop west side water box 3 inch drain valves facilitates drain down flowrate. Hoses are routed through wall penetrations to the Chemical Waste Sump. Maintain continuous monitoring at the Chemical Waste Sump in coordination with drain valve operation. Throttle the drain flowrate to within the capacity of the Chemical Waste Sump Pumps 1P-103A1B. Rev. 7 SO_442.doc S0-442 Cooling Towers and Circulating Water System Acid Feed System The acid feed system functions to maintain the pH of the Circ Water and GSW Systems by injecting sulfuric acid and other chemicals into the circ pit. This is discussed in SD 515, Circ Water Chemical Feed System.For additional information, refer to SD-515, Circulating Water Chemical Feed System.Rev. 7 SD-442 SD_442.doc Cooling Towers and Circulating Water System Acid Feed System The aCid feed system functions to maintain the pH of the Circ Water and GSW Systems by injecting sulfuric acid and other chemicals into the eirc pit. This is discussed in SO 515, Circ Water Chemical Feed System. For additional information, refer to SO-515, Circulating Water Chemical Feed System. Rev. 7 SO_442.doc SO-442 Cooling Towers and Circulating Water System / REFERENCES List references below A. USFAR/DAEC-1, Section 10.4.5 B. DBD-N71-001, Design Basis Document Circulating Water System C. Instructor Guide 32.0, Cooling Towers and Circulating Water System D. Bechtel Specification 7884-M-128, Technical Specification for Butterfly Valves for Circulating Water Pumps E. P&ID, Circulating Water System, Bechtel Drawing 7884-M-142 F. P&ID, Chlorination & Acid Feed Systems Bechtel Drawing 7884-M-180 G. P&ID, Service Water System Pumphouse Bechtel Drawing 7884-M-146 H. P&ID, River Water Supply System Intake Structure Bechtel Drawing 7884-M-129 I. P&ID, Instrument Air System, Turbine Building, Heater Bay Area, Pump House Area, Bechtel Drawing 7884-M-130 (6)J. P&ID, Chlorination and Acid Feed System Bechtel Drawing 7884-M-180 K. Circulating Water System Electrical Dwgs, Bechtel Drawing 7884-E-1 10 (2-11)L. Logic Diagram Discharge & Vent Valve Control of Circulating Water Pumps, Drawing 7884-M-407-22 M. Logic Diagram Cooling Tower Fans, Drawing 7884-M-407-50 N. General Arrangement of Switch on Operators, Drawing 7884-M-128-003

0. Schematic Diagram Acid Feed 7884-E-85 (4,5)P. Drawing M128-019, Electrical Sch. Circ Water Hydraulic Valve Control Q. Drawing M128-020, Circ Water Pump Discharge Valve Hydraulic Schematic R. AOP 301, Loss of Essential Electrical Power S. AOP 302.1, Loss of 125 VDC Power T. AOP 304.1, Loss of 4160V Non-Essential Electrical Power U. AOP 317, Loss of 120 VAC Instrument Control Power V. AOP 357, Loss of 120 VAC Uninterruptible PowerW. AOP 408, Loss of Well Water System X. AOP 410, Total Loss of River Water Supply Y. AOP 411, GSW Abnormal Operation Z. AOP 518, Failure of Instrument and Service Air AA. Annunciator Panel 1C06-B, TURBINE INSTRUMENT PANEL 1C20 TROUBLE BB. Annunciator Panel 1C07-A, CIRC WATER VALVE HO-4201/HO-4202 HYDRAULIC OIL LO PRESSURE Rev. 7 SD-442 SD_442.doc Cooling Towers and Circulating Water System../ REFERENCES List references below A. USFAR/DAEC-1, Section 10.4.5 B. DBD-N71-001, Design Basis Document Circulating Water System C. Instructor Guide 32.0, Cooling Towers and Circulating Water System D. Bechtel Specification 7884-M-128, Technical Specification for Butterfly Valves for Circulating Water Pumps E. P&ID, Circulating Water System, Bechtel Drawing 7884-M-142 F. P&ID, Chlorination

& Acid Feed Systems Bechtel Drawing 7884-M-180 G. P&ID, Service Water System Pumphouse Bechtel Drawing 7884-M-146 H. P&ID, River Water Supply System Intake Structure Bechtel Drawing 7884-M-129 I. P&ID, Instrument Air System, Turbine Building, Heater Bay Area, Pump House Area, Bechtel Drawing 7884-M-130 (6) J. P&ID, Chlorination and Acid Feed System Bechtel Drawing 7884-M-180 K. Circulating Water System Electrical Dwgs, Bechtel Drawing 7884-E-11 0 (2-11) L. Logic Diagram Discharge & Vent Valve Control of Circulating Water Pumps, Drawing 7884-M-407 -22 M. Logic Diagram Cooling Tower Fans, Drawing 7884-M-407-50 N. General Arrangement of Swi!ch on Operators, Drawing 7884-M-128-003 O. Schematic Diagram Acid Feed 7884-E-85 (4,5) P. Drawing M128-019, Electrical Sch. Circ Water Hydraulic Valve Control Q. Drawing M128-020, Circ Water Pump Discharge Valve Hydraulic Schematic R. AOP 301, Loss of Essential Electrical Power S. AOP 302.1, Loss of 125 VDC Power T. AOP 304.1, Loss of 4160V Non-Essential Electrical Power U. AOP 317, Loss of 120 VAC Instrument Control Power V. AOP 357, Loss of 120 VAC Uninterruptible Power W. AOP 408, Loss of Well Water System X. AOP 410, Total Loss of River Water Supply Y. AOP 411, GSW Abnormal Operation Z. AOP 518, Failure of Instrument and Service Air AA. Annunciator Panel 1 C06-B, TURBINE INSTRUMENT PANEL 1 C20 TROUBLE BB. Annunciator PaneI1C07-A, CIRC WATER VALVE HO-4201/HO-4202 HYDRAULIC OIL LO PRESSURE Rev. 7 SO_442.doc SO-442 Cooling Towers and Circulating Water System CC. Annunciator Panel 1C07-B, ACID/CHLORINATION PANEL 1C-417 TROUBLE DD. Annunciator Panel 1C06-A: " "A" COOLING TOWER 1 E-69A FAN TROUBLE* "B" COOLING TOWER 1 E-69B FAN TROUBLE" "A" CIRC WATER PUMP 1P-4A TRIP MOTOR OVERLOAD" "B" CIRC WATER PUMP 1P-4B TRIP MOTOR OVERLOAD" "A" COOLING TOWER BASIN HI/LO LEVEL* "B" COOLING TOWER BASIN HI/LO LEVEL" "A" CIRC WATER PUMP 1P-4A HI VIBRATION" "B" CIRC WATER PUMP 1P-4B HI VIBRATION" CIRC WATER PIT LO LEVEL EE. ECP 1640, Replacement of the Circulation Water Pumps FF. ECP 1674, Partial Main Condenser Circ Water Isolation and Pumpdown Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System-23 -CC. Annunciator PaneI1C07-B, ACID/CHLORINATION PANEL 1C-417 TROUBLE DO. Annunciator Panel 1 C06-A: * "A" COOLING TOWER 1 E-69A FAN TROUBLE * "8" COOLING TOWER 1 E-69B FAN TROUBLE * "A" CIRC WATER PUMP 1P-4A TRIP MOTOR OVERLOAD * "8" CIRC WATER PUMP 1 P-4B TRIP MOTOR OVERLOAD * "A" COOLING TOWER BASIN HI/LO LEVEL * "8" COOLING TOWER BASIN HIILO LEVEL * "A" CIRC WATER PUMP 1P-4A HI VIBRATION

• "8" CIRC WATER PUMP 1 P-4B HI VIBRATION
• CIRC WATER PIT LO LEVEL EE. ECP 1640, Replacement of the Circulation Water Pumps FF. ECP 1674, Partial Main Condenser Circ Water Isolation and Pumpdown Rev. 7 SO_442.doc 80-442 Cooling Towers and Circulating Water System Use figure button on toolbar for additional figure titles.FIGURE 1: Basic Circ Water Flowpath Outer -ooa RHRSWRev. 7 SD_442.doc 4 SD-442 Cooling Towers and Circulating Water System Use figure button on toolbar for additional figure titles. FIGURE 1: Basic eire Water Flowpath High Pressure Condenser 1E-7B RHRSW ES\V' Rev. 7 SO_ 442.doc . GS,A': hr-------------------------

SHld :.>ipe Overflow 6 Circulating Water Pump Pit --Low Pressure Condenser 1E-7A Ct'lorine Injection Typ cal of 12 SO-442 Cooling Towers and Circulating Water System FIGURE 2: Circ Water Pump, Discharge Valve, Vent CWP CWP Vent Discharge Valve Valve CWP START CWP TRIP Pump Discharge Valve, HO-4201 Open*. -" SV-4201 Energize to Close Pump Discharge Valve HO-4201 Closed Pump Discharge Vent Valve SV-4201 Open Condenser Outlet Valve -MO-4208 Open Condenser Outlet Valve MO-4209 Open Circ Water Pump Pit Level Greater than 18 ft*------ CircWater Pump 1P04 ------ ------------------ Control HS Start Pump TD Breaker TDD.O Close Coil 3-4 Min KY-4201 *CVWP HS contact closed in TDPU START and NORM AFT START Circ Water Pump 1P04 Breaker Closed-... .......-- -. ......=_1 Pump Discharge , Valve Closed S............, Pump Breaker , Closed---IS 1* 3-'Pump Breaker Trip Coil Load Shed Over- :.current.. .... .Ground Fault Differential Overcurrent

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.

..- .--.--Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System FIGURE 2; eirc Water Pump, Discharge Valve, Vent CWP Vent Valve Pump Discharge Valve, HO-4201 Open CWP Discharge Valve CWP START Pump Discharge Valve HO-4201 Closed Pump Discharge Vent I Valve SV*4201 Open Condenser Outlet Valve I MO-42G8 Open I Condenser Outlet Valve MO-4209 Open I .______ CireWater Pump Pit I Level Greater than 18 ft I , * -.-----. CircWaterPump 1P04---**-***------**-****-----* Control HS Start , _ .. Pump Breaker Close Coil TDDO 3-4 Min * . * . * . * . * . * . * . * . * . . .. . _ ... _ .. OM ............. .. _. I' -______ .. _ .. _ .... , I It

• I Rev. 7 SO_ 442.doc SV-4201 Energize to Close * * * :"-; KY-4201 : .' TDPU "CWP HS contact closed in START and NORM AFT START

....... ""' .... , ,-_ ....................

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* . _ .. . . Cire Water Pump 1 P04 Breaker Closed *25 -CWP TRIP ........ -.--.... _j Pump Discharge:

Valve Closed '

• I :
• L. ............

__ ... _ ............ .. * : .............. . : Pump 1-: Breaker : : Closed * .' . I .... _ .. __ .. ______ I , ...... I .............. , . , , ............. _---_. Load Shed " .. : .. ' . . Pump Breaker Trip Coil '"' ...... "', ........ -------, Ground Fault , . .. :-' .......... , . ....... -** -** I Over-! .... : Differential --' current : .................... -Overcurrent , ......... --.......... '" ........... ",I SO-442 Cooling Towers and Circulating Water System FIGURE 3: Inlet and Outlet Isolation Valves Inlet Isolation Valve Outlet Isolation Valve LOCAL-REMOTEI_ _ __HS in LOCAL -r-CwP A off CWP B Off.............. .m .. .............. ~~Pump:Permissive HS in Override 42-C -- ----------.......... HS in OPEN LT 42-0D -HS in CLO SE 2--- HS in OPENLS LS LS U HS in CLOSE LS LS&+ 4~- ký42-0 LS 42-C 42-0 Inlet Valve Close Coil Inlet Valve Open Coil Outlet Valve Close Coil Outlet Valve Open Coil Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System-26-FIGURE 3: Inlet and Outlet Isolation Valves Inlet Isolation Valve LOCAL-REMOTU= l HSinLOCAL

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42-C l HS in CLOSE p q HS in OPEN 42-0 Rev. 7 SO_442.doc 42-C Inlet Valve Close Coil 42-0 Inlet Valve Open Coil Outlet Isolation Valve CWP A Off CWP B Off t' *********** " ***** " ", ................

Pump : : Permissive HS : : in Override : . 42-0 HS in CLOSE p q HS in OPEN LS LS LS 42-0 42-C Outlet Valve Close Coil LS 42-C 42-0 Outlet Valve Open Coil SO-442 Cooling Towers and Circulating Water System FIGURE 4: Inlet Valve Cam Inlet Valve Disk z Valve Disk Strike Plate Cam Lock Head Retracted Key Lock Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System-27 -Lock Rev. 7 SO_442.doc Inlet Valve Disk Valve Disk Strike Pla1e Cam Lock Head Retrac1ed FIGURE 4: Inlet Valve Cam Key o SO-442 Cooling Towers and Circulating Water System FIGURE 5: Drain Pump Loop Outer Loop To Cooling Water From Circ Drain Basin Water Pumps Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System-28 -Rev. 7 SO_442.doc r High Pressure Condenser 1E-7B To Cooling Water Drain Basin FIGURE 5: Drain Pump Loop ,

• 4209 Outer Loop Inner Loop Cire VVater Drain Pump Low Pressure Condenser 1E-7A rooI ,,,, " M 0-J'i.'1' " 4257 HO-4202 From Cire Water Pumps HO-4201 SO-442 Cooling Towers and Circulating Water System FIGURE 6: Circ Water System Makeup River Water System-----------------IS- ---------------~~Towers Ci rc Water Pump Pit Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System-29 -River Water System Rev. 7 SO_442.doc FIGURE 6: eire Water System Makeup :-------------------------------i 1------------------------------

-: I I I I I I I I I I I I I I I -I I I I Stilling Basin ------T------- I I !<O >-:!<O OJ >-;U : m;U I I Cire Water Pump Pit Cooling Towers Basin Basin SO-442 Cooling Towers and Circulating Water System FIGURE 7: System Inter-Connections 0 CD 0-W (D T Intake Structure C-)0.CD C-L (D Rev. 7 SD_442.doc SD-442 Cooling Towers and Circulating Water System-30 -Rev. 7 SD_ 442.doc o CD 0. W -. ;0 <' Disch Intake Structure o CD 0. W -. FIGURE 7: System Inter-Connections ( Storm ::u Sewer ::c ::u (j) t -" 1E-53B ESW ...... , EDG Coolers " 'f -...... 1E-53A " " ...... "A .... ....... -...... 'V I ,It' " Dilution arge Canal Structure ( I r ) I' ) I'V42-11 ,----1-{.K1-V42-12 ) V42-09 De-icing .-Blowdown t ...... V42-10 r-CV-4909,l. CV;:.43!1DB I-.... I 10 1 ... 1 P-117B I , 10 CV-4915 CV-4910A Ct." lP-117D J ,II k-V, ... I ,. lX17C > lp*22D lp*22B 1 P*22C 1 P*22A Pump House ::u r l :c ::u (j) J ESW " H.P. L.P. Condo Condo ,It' '7 MO-4208,l A Well Water ,l. 7 MO-4258;l ,lMO-4257 M Y GSW, f----" ,. " , .. ""-G cJ CJ lP-89A 1P-4B lP-4A 1P-89B G 1P-89C Circulating Water Pit lP-48 U 1 P-49 I J ....... .--<n<<n o <D N Cooling Towers L...r-'-.-GSW ,It ,It } Fire Protection "" SD-442 Cooling Towers and Circulating Water System Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D.12 Iowa Department of Natural Resources Letter, M.T. Moeller, Water Supply Engineering, to D. Siegfried, Duane Arnold Energy Center, "Water Use Permits 3533-R3 and 3046-MR5" dated October 31, 2005.Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 0.12 Iowa Department of Natural Resources Letter, M.T. Moeller, Water Supply Engineering, to D. Siegfried, Duane Arnold Energy Center, "Water Use Permits 3533-R3 and 3046-MR5" dated October 31,2005. fields oOpportunities0 STATE OF IOWA THOMAS J. VI:LSACK, GOVERNOR SALLY J. PEDER5ON, LT. GOVERNOR DEPARTMENT OF: NATURAL RESOURCES JEFFREY R.t VONK, DIRECTOR October 31, 2005 FPL Energy Duane Arnold, LLC Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 RE: Water Use Permit Numbers 3533-R3 and 3046-MR5 transfer of ownership

Dear Mr. Daniel Siegfried:

The Department received your notice of change of ownership on October 17, 2005. I've attached new permits with the new permit holder listed. I have removed the General PermitCondition #1 on water use permit no. 3533-R3, but please be advised that any change of ownership still needs to be reported to the Department. If you have any questions, feel free to contact me at 515-725-0292 or at mark.moeller(o2dnir.state.ia.us. Sincerely, Mark T. Moeller Water Supply Engineering Cc: File: Water Use Permit 3533 File: Water Use Pernmit 3046 Field Office #1, Manchester Iowa Department of Natural Resources, Water Supply Section, 401 SW 7 1h St. Suite M, Des Moines, IA 50309-4611 Phone 515/725-0282 Fax 515/725-0348 Email www.state.ia.us/dnr THOMAS J .VIL13AC\:<:, GOVERNOR SALLY J. PEDERSON, LT. GOVERNOR October 31, 2005 FPL Energy Duane Arnold, LLC Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 \' \ STAT.E OF IOWA DEPARTMENT OFNAlURAL RESOURCES JEFFREY R;, VONK, DIRECTOR RE: Water Use Perinit Numbers 3533-R3 and 3046-MR5 transfer of ownership .

Dear Mr. Daniel Siegfried:

The Department received your notice of change of ownership on October 17, 2005. I've attached new permits with the new pernlit holder listed. I have removed the General Permit Condition

1. 1 on water use permit no. 3533-R3, bilt please be advised that any change of ownership still needs to be reported to the Department.

If you have any questions, feel free to contact me at 515-725-0292 or at mark.moeller@dnr.state.ia.us. Sincerely, Mark T. Moeller Water Supply Engineering Cc: File: Water Use Pernlit 3533 File: Water Use Pe!mit 3046 Field Office #1, Manchester Iowa Department of Natural Resources, Water Supply Section, 401 SW ih St. Suite M, Des Moines, IA 50309-4611 Phone 515/725-0282 Fax 515/725-0348 Email www.state.ia.us/dnr IOWA DEPARTMENT OF NATURAL RESOURCES WATER USE PERMIT Permit issued to: Permit Number: 3533-R3 FPL Energy Duane Arnold, LLC Duane Arnold Energy Center Effective: March 14, 2004 3277 DAEC Road Palo, IA 52324 Expires: March 13, 2014 The permittee is authorized to: store water in permanent storage in the maximum quantity of 7,100 acre-feet at the maximum rate of natural runoff from the contributing 2,480-acre watershed throughout each year in a reservoir (Pleasant Creek Reservoir) on land owned by State of Iowa comprising approximately 1900 acres in Section 31 and 32, T85N, R8W, and Sections 5 and 6, T84N, R8W, Linn County, and Section 1, T84N, R9W, Benton County, Iowa; and to withdraw water from the Cedar River in the maximum quantity of 16,000 acre-feet per year at a maximum rate of 15,000 gallons per minute (33.4 cubic feet per second), in the land generally described as the NE 1/4 of the NE 1/4 of Section 4 and the NE 1/4 of Section 5, T84N, R8W, Linn County, Iowa, throughout each year for storage in said reservoir. This authorization to store water has been granted pursuant to the provisions of Part 4 of Division III of Chapter 455B, Code of Iowa, and Chapters 50, 51, and 52 of Part 567, Iowa Administrative Code, and is further subject to the general permit conditions on page 2 of this permit.Conditions of this permit may be appealed as provided in rule 567--50.9, Iowa AdministrativeCode. Appeal must be in writing and must be received at the Department of Natural Resources; Henry A. Wallace Building; 900 East Grand; Des Moines, Iowa 50319-0034 within thirty days of the date of the certification of the mailing of the permit.FOR THE DIRECTOR: By: Date Executed: October 31, 2005 (mtm)cc: Field Office No. 1, Manchester CON 3-9, #3533. -':" .. ", IOWA DEPARTMENT OF NATURAL RESOURCES WATER USE PERMIT Permit issued to: Permit Number: FPL Energy Duane Arnold, LLC Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 Effective: March 14,2004 Expires: March 13,2014 The permittee is authorized to: store water in pennanent storage in the maximum quantity of 7,100 acre-feet at the maximum rate of natural runoff from the contributing 2,480-acre watershed throughout each year in a reservoir (Pleasant Creek Reservoir) on land owned by State of Iowa comprising approximately 1900 acres in Section 31 and 32, T85N, R8W, and Sections 5 and 6, T84N, R8W, Linn County, and Section 1, T84N, R9W, Benton County, Iowa; and to withdraw water from the Cedar River in the maximUm quantity of 16,000 feet per year at a maximum rate of 15,000 gallons per minute (33.4 cubic feet per second), in the land generally described as the NE *114 of the NE 1/4 of Section 4 and the NE 114 of Section 5, T84N, R8W, Linn County, Iowa, throughout each year for storage in said reservoir. This authorization to store water has been granted pursuant to the provisions of Part. 4 of Division III of Chapter 455B, Code of Iowa, and Chapters 50, 51, and 52 of Part 567, Iowa Administrative Code, and is further subject to the general permit conditions on page 2 of this permit. Conditions of this permit may be appealed as provided in rule 567--50.9, Iowa Administrative Code. Appeal must be in writing and must be received at the Department of Natural Resources; Henry A. Wallace Building; 900 East Grand; Des Moines, Iowa 50319-0034 within thirty days of the date of the certification of the mailing of the pem1it. FOR THE DIRECTOR: (mtm) cc: Field Office No.1, Manchester CON 3-9, #3533 Date Executed: October 31, 2005 Permit No.: 3533-R3 Page 2 of 3 CERTIFICATE OF MAILINGOn the date shown below, a copy of the foregoing permit was mailed to the permittee and to each person entitled to receive a copy as provided by rule 567--50.8(2), Iowa Administrative Code. ; } -Q) 6 GENERAL PERMIT CONDITIONS

1. The permittee shall permit inspections of the dam in accordance with 567--Chapter 74, Iowa"Administrative Code.2. Permittee shall be responsible for securing such other permits or approvals as may be required by this department, federal, or local governmental agencies for the operation of the reservoir and in discharge of water or other materials due tothis operation.

3. Permittee is responsible for compliance with all applicable provisions of state law and the rules and regulations of this department and of federal and local health and water pollution control agencies in the operation of the reservoir and in the discharge of water or other material due to this operation

4. Permittee may withdraw water at all times that the flow of the Cedar River remains greater than 937 cubic feet per second (cfs) at the official gage at Cedar Rapids, Iowa.Permittee may withdraw water during the period April 1 to September 30 when the flow at the official gauge at Cedar Rapids is between 500 cfs and 937 cfs only if the flow of the river is increasing on a 24-hour basis. Permittee may withdraw water during the period October' 1 to March 31 when the flow at the Cedar Rapids gauge is greater than 500 cfs.5. Water may be withdrawn from the Cedar River pursuant to this permit for use in maintaining a maximum reserve of water in Pleasant Creek Reservoir for power generation purposes and may be released from Pleasant Creek Reservoir for low-flow augmentation purposes at a rate equal to the consumptive use at the Duane Arnold Energy Center and for recreational management purposes.6. Permittee shall maintain accurate and up-to-date records of water use from said sources and submit them annually to the department.

Additional records on pumping rates from said sources, and other data related to the regulation of this use of water shall be maintained and submitted as directed by the department

7. Permittee shall provide for the downstream discharge of that portion of the natural flow in said river that is required to prevent material damage to downstream users.2 CERTIFICATE OF MAILING Permit No.: 3533-R3 Page 2 of3 On the date shown below, a copy of the foregoing permit was mailed to the permittee and to each person entitled to receive a copy as provided by rule 567--50.8(2), Iowa AdministTative Code. I) -0 J -0 5 GENERAL PERMIT CONDITIONS

1. The permittee shall permit inspections of the dam in accordance with 567--Chapter 74, ',.. Iowa'Administrative Code. 2. Permittee shall be responsible for securing such other permits or approvals as may be required by this department, federal, or local governmental agencies for the operation of the reservoir and iIi discharge of water or other materials due to 'this operation.

3. Permittee is responsible for compliance with all applicable provisions of state law and the rules and regulations of this department and of federal and local health and water pollution control agencies in the operation of the reservoir and in the discharge of water or other material due to this operation

4. Permittee may withdraw water at all times that the flow of the Cedar River remains greater than 937 cubic feet per second (cfs) at the official gage at Cedar Rapids, Iowa. Permittee may withdraw water during the period April 1 to September 30 when the flow at the official gauge at Cedar Rapids is between 500 cfs and 937 cfs only if the flow of the river is increasing on a 24-hour basis. Permittee may withdraw water during the period October 1 to March 31 when the flow at the Cedar Rapids gauge is greater than 500 cfs. 5. Water may be withdrawn from the Cedar River pursuant to this permit for use in maintaining a maximuin reserve of water in Pleasant Creek Reservoir for power generation purposes and may be released from Pleasant Creek Reservoir for low-flow.

augmentation purposes at a rate equal to the consumptive use at the Duane Arnold Energy Center and for recreational management purposes. . . 6. Permittee shall maintain accurate and up-to-date records of water use from said sources and submit them annually to the department. Additional records on pumping rates from said sources, and other data related to the regulation of this use of water shall be maintained and submitted as directed by the department

7. Permittee shall provide for the downstream discharge of that portion of the natural flow in said river that is required to prevent material damage to downstream users. 2 Permit No.: 3533-113 Page 3 of 3 8. Permittee shall provide screening on water intakes as required in Section 109.14, Code of Iowa, to protect fish and other aquatic life.9. Permittee shall cooperate with representatives of the department to determine that the authorized withdrawals do not violate the flow restriction imposed herein.10. Permittee shall submit to the department within 90 days of being notified by thedepartment, or no later than the expiration date of this permit, whichever first occurs, a plan for implementing routine day-to-day water conservation measures and for implementing emergency water conservation measures during periods of water shortage.Until such a plan has been submitted to and approved by the department, permittee shall implement those emergency water conservation measures determined to be necessary by the department pursuant to Iowa Code Sections 455B.265 and 455B.266.11. Permittee shall obtain written permission, easement, or any other legal means from the adjoining landowners to construct access underground pipe to the river.CAVEAT Permittee is advised that pursuant to Section 455B.271, Code of Iowa, the authority to store water provided by this permit may be modified, canceled or suspended in case of any breach ofthe terms or conditions herein, in case of any violation of state law pertaining to the permit, or if found necessary to prevent substantial injury to private or public interests.

SUMMARY

REPORT Permittee has applied to renew an existing permit that presently authorizes the requested storage and withdrawal of water. The requested use of water conforms to the relevant criteria in Part 4 of Division III of Chapter 455B, Code of Iowa, and Chapter 52 of Part 567, Iowa Administrative Code. The department has received no allegations of public or private-damage resulting from the storage of water authorized under the predecessors to this permit since the original permit was granted.3 Permit No.: 3533-R3 Page 3 of3 8. Permittee shall provide screening on water intakes as required in Section 109.14, Code of . Iowa, to protect fish and other aquatic life. 9. shall cooperate with representatives of the department to determine that the authorized withdrawals do not violate the flow restriction imposed herein. 10. Permittee shall submit to the department within 90 days of being notified by the department, or no later than the expiration date of this permit, whichever first occurs, a plan for implementing routine day-to-day water conservation measures and for implementing emergency water conservation measures during periods of water shortage. Until such a plan has been submitted to and approved by the department, permittee shall implement those emergency water conservation measures determined to be necessary by the department pursuant to Iowa Code Sections 455B.265 and 455B.266.

11. Permittee shall obtain written permission, easement, or any other legal means from the adjoining landowners to construct access underground pipe to the river. CAVEAT Permittee is advised that pursuant to Section 455B.271, Code of Iowa, the authority to store water provided by this permit may be modified, canceled or suspended in case of any breach of the terms or conditions herein, in case of any violation of state law pertaining to the permit, or if found necessary to prevent substantial injury to private or public interests.

SUMMARY

REPORT Permittee has applied to renew an existing permit that presently authorizes the requested storage and withdrawal of water. The requested use of water conforms to the relevant criteria in Part 4 of Division III of Chapter 455B, Code ofIowa, and Chapter 52 of Part 567, Iowa Administrative Code. The department has received no allegations of public or private damage resulting from the storage of water authorized under the predecessors to this permit since the original permit was granted. 3 IOWA DEPARTMENT OF NATURAL RESOURCES WATER USE PERMIT Permit issued to: Permit Number: 3046-MR5 FPL Energy Duane Arnold, LLC Duane Arnold Energy Center Effective: July 1, 2002 3277 DAEC Road Palo, IA 52324 Expires: June 30, 2012 The permittee is authorized to: withdraw water from 4 Silurian-Devonian wells, 285 to 380 feet deep, and the Cedar River on land generally described as the SE 1/4 and the E 1/2/ of the NE 1/4 of Section 9; and that part of Section 10 west of the Cedar River; all in T84N, R8W, Linn County, Iowa, in the combined maximum quantity of 43,400 acre-feet per year (14150 MGY) [maximum quantity of 1575 MGYfrom the wells and 12,575 MGYfrom the Cedar River] at a maximum rate of 27,000 gallons per minute, not to exceed a combined maximum rate from the four 3,000 gallons per minute, throughout each year for cooling, construction, potable and sanitary purposes at permittee's nuclear power plant on said land. This authorization to withdraw water has been granted pursuant to the provisions of Part 4 of Division mI of Chapter 455B, Code of Iowa, and Chapters 50, 51, and 52 of Part 567, Iowa Administrative Code, and is further subject to the general permit conditions within this permit.Conditions of this permit may be appealed as provided in rule 567--50.9, Iowa Administrative Code. Appeal must be in writing and must be received at the Department of Natural Resources; Water Supply Section; 401 SW 7'h St., Suite M; Des Moines, Iowa 50309-4611 within thirty days of the date of the certification of the mailing of the permit.FOR THE DIRECTO1]0 By: / f' ' Date Executed: October 31, 2005 (mtm)c: Field Office No. 1 File CON 3-9, #3 046 CERTIFICATE OF MAILINGOn the date shown below, a copy of the foregoing permit was mailed to the permittee and to each person entitled to receive a copy as provided byrule 567--50.8(2), Iowa Administrative Code. / / _ , , --_IOWA DEPARTMENT OF NATURAL RESOURCES WATER USE PERMIT Permit issued to: Permit Number: 3046-MR5 FPL Energy Duane Arnold, LLC Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 The permittee is authorized to: Effective: July 1, 2002 Expires: June 30, 2012 withdraw water from 4 Silurian-Devonian wells, 285 to 380 feet deep, and the Cedar River on land generally described as the SE 14 and the E Y2 of the NE 14 of Section 9; and that part of Section 10 west of the Cedar River; all in T84N, R8W, Linn County, Iowa, in the combined maximum quantity of 43,400 acre-feet per year (14150 MGY) [maximum quantity of 1575 MGY from the wells and 12,575 MGY from the Cedar River] at a maximum rate of 27,000 gallons per minute, not to exceed a combined maximum rate from the four 3,000 gallons per minute, throughout each year for cooling, construction, potable and sanitary purposes at permittee's nuclear power plant on said land. . This authorization to withdraw water has been granted pursuant to the provisions of Part 4 of Division ill of Chapter 455B, Code of Iowa, and Chapters 50, 51, and 52 of Part 567, Iowa Administrative Code, and is further subject to the general permit conditions within this permit. Conditions of this permit may be appealed as provided in rule 567--50.9, Iowa Administrative Code. Appeal must be in writing and must be received at the Department of Natural Resources; Water Supply Section; 401 SW i h St., Suite M; Des Moines, Iowa 50309-4611 within thirty days of the date of the certification of the mailing of the permit. By: ('IF (mtm) ? c: Field Office No. 1 File CON 3-9, #3046 Date Executed: CERTIFICATE OF MAILING October 31, 2005 On the date shown below, a copy of the foregoing permit was mailed to the permittee and to each person entitled to receive a copy as provided by rule 567--50.8(2), Iowa Administrative Code. / ____ __ Permit No.: 3046-MR5 Page 2 of 3 GENERAL PERMIT CONDITIONS

1. Permittee shall maintain accurate and up-to-date records of water use from said sources and submit them annually to the department.

Additional records on pumping rates from said sources, water levels in said wells and other data related to the regulation of this use of watershall be maintained and submitted as directed by the department.

2. Permittee shall be responsible for securing such other permits or approvals as may be required by this department, federal, or local governmental agencies for the operation of said meat processing plant or the discharge of water or other materials due to this operation.

3. Permittee is responsible for compliance with all applicable provisions of state law and the rules and regulations of this department and of federal and local health and water pollutioncontrol agencies in the operation of the said plant and in the disposal of its wastes.4. Permittee shall construct, maintain, and monitor observation wells, as directed by the department to define the effects of permittee's water withdrawals on groundwater resources or on other water users who might be affected by the withdrawals authorized herein.5. Once each spring prior to March 31, the permittee shall be responsible for accurately measuring the distance(s) to water (static water level) from the access port in all permitted wells. The distance to water shall be submitted to the department annually as part of the records of water use.6. With respect to each proposed or replacement well authorized as a source of water in this permit, withdrawals of water may be made only after the permittee has made the following information available to the Geological Survey Bureau: well location, well log, casing and grouting schedule, results of yield tests, and cutting samples.7. Each, proposed or replacement well authorized as a source of water in this permit, withdrawals of water may be made only after the permittee has made the following information available to the Geological Survey Bureau: well location, well log, casing andgrouting schedule, results of yield tests, and cutting samples.8. Existing wells shall not be replaced without notifying the Iowa Department of Natural Resources.

Changes to the location, depth, source aquifer, or other physical features of said wells may require that this permit be modified to accommodate the changes.9. Permittee shall submit to the department within 90 days of being notified by the department, or no later than the expiration date of this permit, whichever first occurs, a plan for implementing routine day-to-day water conservation measures and for implementing emergency water conservation measures during periods of water shortage. Until such a plan has been submitted to and approved by the department, permittee shall implement those emergency water conservation measures determined to be necessary by the department pursuant to Iowa Code Sections 455B.265 and 455B.266.GENERAL PERMIT CONDITIONS Permit No.: 3046-MR5 Page 2 of3 1. Permittee shall maintain accurate and up-to-date records of water use from said sources and submit them annually to the department. Additional records on pumping rates from said sources, water levels in said wells and other data related to the regulation of this use of water shall be maintained and submitted as directed by the department.

2. Permittee shall be responsible for securing such other permits or approvals as may be required by this department, federal, or local governmental agencies for the operation of said meat processing plant or the discharge of water or other materials due to this operation.

3. Permittee is responsible for compliance with all applicable provisions of state law and the rules and regulations of this department and of federal and local health and water pollution control agencies in the operation of the said plant and in the disposal of its wastes. 4. Permittee shall construct, maintain, and monitor observation wells, as directed by the department to define the effects of permittee's water withdrawals on groundwater resources or on other water users who might be affected by the withdrawals authorized herein. 5. Once each spring prior to March 31, the permittee shall be responsible for accurately measuring the distance(s) to water (static water level) from the access port in all permitted wells. The distance to water shall be submitted to the department annually as part of the records of water use. 6. With respect to each proposed or replacement well authorized as a source of water in this permit, withdrawals of water may be made only after the permittee has made the following information available to the Geological Survey Bureau: well location, well log, casing and grouting schedule, results of yield tests, and cutting samples. 7. Each, proposed or replacement well authorized as a source of water in this permit, withdrawals of water may be made only after the permittee has made the following information available to the Geological Survey Bureau: well location, well log, casing and grouting schedule, results of yield tests, and cutting samples. 8. Existing wells shall not be replaced without notifying the Iowa Department of Natural Resources.

Changes to the location, depth, source aquifer, or other physical features of said wells may require that this permit be modified to accommodate the changes. 9. Permittee shall submit to the department within 90 days of being notified by the department, or no later than the expiration date of this permit, whichever first occurs, a plan for implementing routine day-to-day water conservation measures and for implementing emergency water conservation measures during periods of water shortage. Until such a plan has been submitted to and approved by the department, permittee shall implement those emergency water conservation measures determined to be necessary by the department pursuant to Iowa Code Sections 455B.265 and 455B.266. Permit No.: 3046-MR5 Page 3 of 3 10. This permit supersedes Water Use Permit No. 3046-MR4.CAVEAT Permittee is advised that pursuant to Section 455B.271, Code of Iowa, the authority to withdraw water provided by this permit may be modified, canceled or suspended in case of any breach of the terms or conditions herein, in case of any violation of state law pertaining to the permit, or if found necessary to prevent substantial injury to private or public interests.

10. This permit supersedes Water Use Permit No. 3046-MR4.

CAVEAT Permit No;: 3046-MRS Page 3 of3 Permittee is advised that pursuant to Section 455R271, Code of Iowa, the authority to withdraw water provided by this pennit may be modified, canceled or suspended in case of any breach of the terms or conditions herein, in case of any violation of state law pertaining to the pennit, or if found necessary to prevent substantial injury to private or public interests. IOWA DEPARTMENT OF NATURAL RESOURCES WATER USE REGISTRATION Registration issued to: Registration Number: 57-06-51 Duane Arnold Energy Center Attn: Jerald Hogan, Sr. Envr. Analyst 3277 DAEC RdPalo, IA 52324 In addition to the use of water authorized in Water Use Permit No. 3046-MR5, registrant is authorized to: withdraw water in the maximum quantity of approximately 600,000 gallons at a maximum rate of approximately 1,650 gallons per minute from Well "D", a Silurian/Devonian aquifer well, approximately 285 feet deep, located at the Duane Arnold Energy Center, in the SW 4 of the NW 1/ of Section 10, T84N, R8W, LinnCounty, Iowa, to test pump said well.Registrant is responsible for securing such other permits or approvals as may be required by this department, federal, or local government agencies regarding this use of water.Water withdrawn pursuant to this registration shall be discharged in accordance with the requirements of the department and so as to preclude flooding, erosion, or other adverse effects.This authorization to withdraw water has been granted pursuant to Iowa Code Section 455B.268 and rule 567--51.6(5), Iowa Administrative Code.This registration expires one year from the date executed as shown below.FOR THE DIRECTOR: cc: / ld Office No. I1 anchesterWater Use Permit File #3046Reg. File Date Executed: 10/4/2006 IOWA DEPARTMENT OF NATURAL RESOURCES WATER USE REGISTRATION Registration issued to: Registration Number: 57-06-51 Duane Arnold Energy Center Attn: Jerald Hogan, Sr. Envr. Analyst 3277DAECRd Palo, IA 52324 In addition to the use of water authorized in Water Use Permit No. 3046-MR5, registrant is authorized to: withdraw water in the maximum quantity of approximately 600,000 gallons at a maximum rate of approximately 1,650 gallons per minute from Well "D", a SilurianlDevonian aquifer well, approximately 285 feet deep, located at the Duane Arnold Energy Center, in the SW Y4 of the NW Y4 of Section 10, T84N, R8W, Linn County, Iowa, to test pump said well. Registrant is responsible' for securing such other permits or approvals as may be required by this department, federal, or local govenunent agencies regarding this use of water. Water withdrawn pursuant to this registration shall be discharged in accordance with the requirements Dfthe department and so as to preclude flooding, erosion, or other adverse effects. This authorization to withdraw water has been granted pUrsuant to Iowa Code Section 455B.268 and rule 567--51.6(5), Iowa Administrative Code. This registration expires one year from the date executed as shown below. FOR THE DIRECTOR: By: cc: 'eld Office No.1 -anchester Water Use Permit File #3046 Reg.File* Date Executed: 10/412006 IOWA DEPARTMENT OF NATURAL RESOURCES WATER USE REGISTRATION Registration issued to: Registration Number: 57-05-32 Duane Arnold Energy Center Attn: Jerald Hogan 3277 DAEC Rd Palo, IA 5.2324 In addition to the use of water authorized in Water Use Permit No. 3046-MR5, registrant isauthorized to: withdraw water in the maximum quantity of approximately 90,000 gallons at a maximum rate of approximately 1,500 gallons .per minute from Well "D", a Silurian/Devonian aquifer well, approximately 285 feet deep, located at the Duane Arnold Energy Center, in the SW 1/4 of the NW 1/4 of Section 10, T84N, R8W, Linn County, Iowa, to test pump said well.Registrant is responsible for securing such other permits or approvals as may be required by this department, federal, or local government agencies regarding this use of water.Water withdrawn pursuant to this registration shall be discharged in accordance with the requirements of the department and so as to preclude flooding, erosion, or other adverse effects.This authorization to withdraw water has been granted pursuant to Iowa Code Section 455B.268 and rule 567--51.6(5), Iowa Administrative Code.This registration expires one year from the date executed as shown below.FOR THE DIRECTOR: By: cc: Office No. 1 -Manchester /ater Use Permit File #3046 Reg. File Date Executed: 7/18/2005 IOWA DEPARTMENT OF NATURAL RESOURCES WATER USE REGISTRATION Registration issued to: Registration Number: 57-05-32 Duane Arnold Energy Center Attn: Jerald Hogan 3277DAECRd Palo, IA 52324 In addition to the use of water authorized in Water Use Permit No. 3046-MR5, registrant is authorized to: withdraw water in the maximum quantity of approximately 90,000' gallons at a maximum rate of approximately 1,500 gallons. per minute from Well "D", a SilurianlDevonian aquifer well, approximately 285 feet deep, located at the Duane Arnold Energy Center, in the SW Y4 of the NW Y4 of Section 10, T84N, R8W, Linn County, Iowa, to test pump said well. Registrant is responsible for secming such other permits ot approvals as may be required by this department, federal, or local govennnent agencies regarding this use of water. Water withdrawn pursuant to this registration shall be discharged in accordance with the requirements of the department and so as to preclude flooding, erosion, or other adverse effects. . . '!' : .. This authorization to withdraw water has been granted pursuant to Iowa Code Section 455B.268 and rule 567--51.6(5), Iowa Administrative Code. This registration expires one year from the date executed as shown below. FOR THE DIRECTOR: By: cc: Office No. 1 -Manchester ater Use Permit File #3046 Reg. File .) :"i} .. <.::',:',.; <' '" Xi' Date Executed: 7/18/2005 Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D.13 Department of the Army Letter, J.G. Betker, Project Manager, Regulatory Branch, Corps of Engineers, to J. Hogan Duane Arnold Energy Center,"CEMVR-OD-P-2005-1016" dated September 20, 2005.Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D.13 Department of the Army Letter, J.G. Betker, Project Manager, Regulatory Branch, Corps of Engineers, to J. Hogan Duane Arnold Energy Center, "CEMVR-OD-P-2005-1016" dated September 20,2005. DEPARTMENT OF THE ARMY ROCK ISLAND DISTRICT, CORPS OF ENGINEERS CLOCK TOWER BUILDING -P.O. BOX 2004 ROCK ISLAND, ILLINOIS 61204-2004 PALY MMON ' http://www.nrr.usacc.arny.nil September 20, 2005 Operations Division

SUBJECT:

CEMVR-OD-P-2005-1016 Mr. Jerald Hogan Duane Arnold Energy Center 3277 DAEC Road Palo, Iowa 52324

Dear Mr. Hogan:

We are enclosing a Department of the Army permit authorizing work in conjunction with the construction of spur dikes and dredging operations, on the Cedar River near Palo, in Limn County, Iowa.If you find it necessary to make changes in this authorization, you must submit revised plans to this office for approval before beginning work. You should also have all required Federal, state, and local approvals prior to commencing work.' Please notify this office prior to starting and completion of work. You are required to.complete and return the enclosed "Completed Work Certification" upon completion of your project. A representative of this office will make periodic inspections of the work.We appreciate your cooperation. Should you have any questions pertaining to your permit, please contact our Regulatory Branch by letter, or telephone Mr. Gene Wassenhove, 309/794-5368. Sincerely, qJohn G. Betker Project Manager Regulatory Branch Enclosures Copies Furnished:Ms. Chris SchwakeýIowa Department of Natural Resources Wallace State Office BuildingDes Moines, Iowa 50319 DEPARTMENT OF THE ARMY ROCK ISLAND DISTRICT, CORPS OF ENGINEERS CLOCK TOWER BmLDING -P.O. BOX 2004 ROCK ISLAND, ILLINOIS 61204-2004 IUiPLYTO AT11!lI110NOF Operations Division bt1p:/Iwww.mvr.usace.army.mil September 20, 200S

SUBJECT:

CEMVR-OD-P-2005-1016 Mr. Jerald Hogan Duane Arnold Energy Center 3277 DAEC Road Palo, Iowa 52324

Dear Mr. Hogan:

} We are enclosing a Department of the Army" pennit authorizing work in conjunction with the construction of spur dikes and dredging operations.

on the Cedar River near Palo, in Linn County, Iowa. If you fmd it necessary to make changes in this authorization, you must submit revised plans to this office for approval before beginning work. You should also have all required Federal, state, and local approvals prior to commencing work. ') Please notify this office prior to starting and completi?n You are to / complete and return the enclosed "Completed Work Certification" upon completIOn of your project. A representative ofthis office will make periodic inspections of the work. We appreciate your cooperation. Should you have any questions perttlining to your pennit, please contact our Regulatory Branch by letter, or telephone Mr. Gene WasseIihove, 309/794-5368. Enclosures Copies Furnished: Ms. Chris Schwake ,Iowa Department pfNatural Resources

Wallace State Office Building Des Moines, Iowa 50319 Project Manager Regulatory Branch DEPARTMENT OF THE ARMY PERMIT Permit Number

CEMVR-OD-P-2005-1016 Permittee:

Duane Arnold energy Center 3277 DAEC Road Palo, Iowa 52324 Section 404 POC: Mr. Jerald HoganTel: (319) 851-7606 Effective Date: 20 September 2005 Expiration Date: 31 December 2010 Issuing Office: U.S. Army Corps of Engineers, Rock Island District Clock Tower Building -P.O. Box 2004 Rock Island, Illinois 61204-2004 You are authorized to perform work in accordance with the terms and conditions specified below. NOTE: The term "you" and its derivatives, as used in this permit, means the permittee or any futuretransferee. The term "this office" refers to the appropriate district or division office of the Corps of Engineers having jurisdiction over the permitted activity or the appropriate official of that office'icting under the authority of the commanding officer.Project

Description:

The permittee will construct 4 spur dikes and perform dredging operations. The 4 rock spur dikes will vary in length from 81 feet to 142 feet. The spur dikes will be constructed by accessing theisland from the west river bank during low Water levels. A 1250-foot-long and 50-foot-wide channel will be mechanically dredged. The sand type material will be loaded onto trucks and hauled to an upland disposal site on the permitee's property. Maintenance dredging will occur on an as needed basis. The material will be disposed of as stated above.

• Project Location:

Cedar River, in Section 10, Township 84 North, Range 8 West, near Palo,Linn County, Iowa. In accordance with the plans and drawings attached hereto which are incorporated in and made a part of this permit.Drawing(s) No. CEMVR-OD-P-2005-1016 Sheet 1 of 4, Location Map Sheet 2 of 4, Location Map Sheet 3 of 4, Plan View Sheet 4 of 4, Cross Sections-.... . DEPARTMENT OF THE ARMY PERMIT '" Pennit Number: CEMVR-OD-P-20Q5-1016 ,Pennittee: Duane Arnold energy Center 3277 DAEC Road Palo, Iowa 52324 Effective Date: 20 September 2005 Expiration 31 December 2010 Section 404 POC:'Mr. Jerald Hogan Tel: (319) Issuing Office: U.S. Anny Corps of Engineers, Rock Island District Clock Tower Building -P.O. Box 2004 Rock Island, Illinois 61204-2004 You are authorized to perform work in accordance with the tenns and specified below. NOTE: The term "you" and its derivatives, as used in this pennit, means the pennittee or any future transferee. The tenn "this office" refers to the appropriate district Qr division office of the Corps of Engineers having jurisdiction over the pennitted activity or the appropriate official of that office )cting under the authority of the commanding officer. 'Project

Description:

The permittee will construct 4 spur dikes and perform dredging operations. The 4 rock spur dikes will vary in length from 81 feet to 142 feet. The spur dikes will be constructed by accessing the island from the west river bank during low water levels. A long and 50-foot-wide channel will be mechanically dredged. The sand type material will be loaded onto trucks and hauled to an upland disposal site on the permitee's property. Maintenance dredging will occur on an as needed basis. The material will be disposed of as stated above. , Project Location: Cedar River, iri Section 10, Township 84 North, Range 8 West, near Palo, Linn County, Iowa. In accordance with the plans and drawings attached hereto which are incorporated in and made a part of this permit. Drawing(s) No. CEMVR-OD-P-2005-1016 Sheet 1 of 4, LocationMap Sheet 2 of 4, Location Map Sheet 3 of 4, Plan. View Sheet 4 of 4, Cross Sections Permit Conditions: General Conditions:

1. The time limit for completing the work authorized ends on the date specified on page 1. If you find that you need more time to complete the authorized activity, submit your request for a time extension to this office for consideration at least one month before that date is reached.2. You must maintain the activity authorized by this permit in good condition and in conformance with the terms and conditions of this permit.

You are not relieved of this requirement if you abandon the permittedactivity, although you may make a good faith transfer to a third party, in compliance with General Condition 4 below. Should you wish to cease to maintain the authorized activity or should you desire to abandon it without a good faith transfer, you must obtain a modification of this permit from this office, which may require restoration of the area.3. If you discover any previously unknown historic or archaeological remains while accomplishing the activity authorized by this permit, you must immediately notify this office of what you have found. We will initiate the Federal and state coordination required to determine if the remains warrant a recovery effort or if the site is eligible for listing in the National Register of Historic Places.4. If you sell the property associated with this permit, you must obtain the signature of the new owner in the space provided and forward a copy of the permit to this office to validate the transfer of this authorization. i 5. If a conditioned water quality certification has been issued for your project, you must comply with the conditions specified in the certification as special conditions to this permit. For your convenience, a copy of the certification is attached if it contains such conditions. (Condition is not applicable for Section 10 Permits.)6. You must allow representatives from this office to inspect the authorized activity at any time deemed necessary to ensure that it is being or has been accomplished in accordance with the terms and conditions of your permit.Special Condition: That the 12 general conditions listed in the attached state Section 401 Water Quality Certification letter from the Iowa Department of Natural Resources, dated August 26, 2005, are considered to be part of this permit.2 Permit Conditions: General Conditions: . 1. The time limit for completing the work authorized ends on the date specified on page 1. If you find that you need more time to complete the authorized activity, submit your request for a time* extension to this office for consideration at least one month before that date is reached. 2. You must maintain the activity authorized by this permit in good condition and in . conformance with the terms and conditions of this permit. You are not relieved of this requirement if you abandon the permitted-activity, although you may make a good faith transfer to a third party, in compliance with General Condition 4 below. Should you wish to cease to maintain the authorized activity or should you desire to abandon it without a good faith transfer, you must obtain a modification ofthis permit from this office, which may require restoration of the area. 3. If you discover any previously unknown historic or archaeological remains while accomplishing the activity authorized by this permit, you must immediately notify this office of what you have found. We will initiate the Federal and state coordination required to determine if the remains warrant a recovery effort or if the site is eligible for listing in the National Register of Historic Places. 4. If you sell the property associated with this permit, you must obtain the signature of the new owner in the space provided and forward a copy of the pennit to this office to validate the transfer of this authorization. ) 5. If a conditioned water quality certification has been issued for your project, you must comply with the conditions specified in the certification as special conditions to this permit. For your convenience, a copy of the certification is attached ifit contains such conditions. (Condition is not applicable for Section 10 Permits.)

6. You must allow representatives from this office to inspect the authorized aCtivity at any time deemed necessary to ensure that it is being or has been accomplished in accordance with the terms and conditions of your permit. Special Condition:

That the 12 general conditions listed in the attached state Section 401 Water Quality Certification letter from the Iowa Department of Natural dated August 26, 2005, are considered to be part of this permit. 2 Further Information:

1. Congressional Authorities:

You have been authorized to undertake the activity described above pursuant to:( ) Section 10 of the Rivers and Harbors Act of 1899 (33 U.S.C. 403).(X ) Section 404 of the Clean Water Act (33 U.S.C. 1344).( ) Section 103 of the Marine Protection, Research and Sanctuaries Act of 1972 (33 U.S.C. 1413).2. Limits of this authorization.

a. This permit does not obviate the need to obtain other Federal, state, or local authorizations required by law.b. This permit does not grant any property rights or exclusive privileges.

c. This permit does not authorize any injury to the property or rights of others.d. This permit does not authorize interference with any existing or proposed Federal project.3. Limits of Federal Liability. In issuing this permit, the Federal Government does not assumeany liability for the following:

a. Damages to the permitted project or uses thereof as a result of other permitted or unpermitted activities or from natural causes.b. Damages to the permitted project or uses thereof as a result of current or future activities undertaken by or on behalf of the United States in the public interest.c. Damages to persons, property,.

or to other permitted or unpermitted activities or structures caused by the activity authorized by this permit.d. Design or construction deficiencies associated with the permitted work.e. Damage claims associated with any future modification, suspension, or revocation of this permit.4. Reliance on Applicant's Data: The determination of this office that issuance of this permit isnot contrary to the public interest was made in reliance on the information you provided.5. Reevaluation of Permit Decision. This office may reevaluate its decision on this permit at any time the circumstances warrant. Circumstances that could require a reevaluation include, but are not limited to, the following:

a. You fail to comply with the terms and conditions of this permit.b. The information provided by you in support of your permit application proves to have been false, incomplete, or inaccurate (See 4 above).3 Further Information:

1. Congressional Authorities:

You have been authorized to undertake the activity described above pursuant to: ( ) Section 10 of the Rivers and Harbors Act of 1899 (33 U.S.C. 403). (X) 404 ofthe Clean Water Act (33 U.S.C. 1344). ( ) Section 103 of the Marine Protection, Research and Sanctuaries Act of 1972 (33 U.S.C. 1413). . 2. Limits of this authorization.

a. This permit does not obviate the need to obtain other Federal, state, or local authorizations required by law. b. This permit does not grant any property rights or exclusive privileges.

c. This permit does not authorize any injury to the property or rights of others. d. This permit does not authorize interference with any existing or proposed Federal project. 3. Limits of Federal Liability.

In issuing this permit, the Federal Government does not assume any liability for the following: ! a. Damages to the permitted project or uses thereof as a result of other permitted or unpermitted activities or from natural causes. b. Damages to the permitted project or uses thereof as a result of current or future activities undertaken by or on behalf of the United States in the public interest.

c. Damages to persons, property,or to other permitted or unpermitted activities or structure-s caused by the activity authorized by this permit. d. Design or construction deficiencies associated with the permitted work. e. Damage claims associated with any future modification, suspension, 9r revocation of this permit. 4. Reliance on Applicant's Data: The determination of this office that issuance of this permit is . not contrary to the public interest was made in reliance on the information you provided.

5. Reevaluation of Permit Decision.

This office may reevaluate its decision on this permit at any time the circumstances warrant. Circumstances that could require a reevaluation include, but are not limited to, the following:

a. You fail to comply with the terms and conditions of this permit. b. The information provided by you in support of your permit application proves to have been false, incomplete, or inaccurate (See 4 above). 3

c. Significant new information surfaces which this office did not consider in reaching theoriginal public interest decision.Such a reevaluation may result in a determination that it is appropriate to use the suspension, modification, and revocation procedures contained in 33 CFR 325.7 or enforcement procedures such as those contained in 33 CFR 326.4 and 326.5. The referenced enforcement procedures provide for the issuance of an administrative order requiring you to comply with the terms and conditions of your permit and for the initiation of legal action where appropriate.

Youwill be required to pay for any corrective measures ordered by this office, and if you fail to comply with such directive, this office may in certain situations (such as those specified in 33 CFR 209.170)accomplish the corrective measures by contract or otherwise and bill you for the cost.6. Extensions. General condition 1 establishes a time limit for the completion of the activity authorized by this permit. Unless there are circumstances requiring either a prompt completion of the authorized activity or a reevaluation of the public interest decision, the Corps will normally give favorable consideration to a request for an extension of this time limit.Your signature below, as permittee, indicates that you accept and agree to comply with the terms and conditions of this permit.SPermittee- "U /Date This issuing officer for this permit is Duane P. Gapinski, Colonel, U.S. Army, District Engineer,Rock Island District.This permit becomes effective when the Federal official, designated to act for the Secretary of the Army, and in accordance with CEMVR-OD-P appointment order 28 March 2000 has signed below.Date When the structures or work authorized by this permit are still in existence at the time the property is transferred, the terms and conditions of this permit will continue to be binding on the new owner(s) of the property. To validate the transfer of this permit and the associated liabilities associated with compliance with its terms and conditions, have the transferee sign and date below. Transferee Date 4 c. Significant new infonnation surfaces which this office did not consider in reaching the 9riginal public interest decision. Such a reevaluation may result in a detennination that it is appropriate to use the suspension, modification, and revocation procedures contained in 33 CFR 325.7 or enforcement procedures such as those contained in 33CFR 326.4 and 326.5. The referenced enforcement procedures provide for the issuance of an administrative order requiring you to comply with the tenns and conditions of your pennit and for the initiation of legal action where appropriate. You will be required to pay for any corrective measures ordered by this office, and if you fail to comply with such directive, this office may in certain situations (such as those specified in 33 CFR 209.170) accomplish the corrective measures by contract or otherwise and bill you for the cost. 6. Extensions. General condition 1 establishes a time limit for the completion of the activity authorized by this pennit. Unless there are requiring either a prompt completion of the' authorized activity or a reevaluation of the public interest decision, the Corps will nonnally give favorable consideration to a request for an extension of this time limit. ,Your signature below, as permittee, indicates that you accept and agree to comply with the tenns and conditions of this pennit. I Date ", This issuing officer for this pennit is Duane P. Gapinski, Colonel, u.s. Army, District Engineer, Island District. This pennit becomes effective when the Federal official, designated to act for the Secretary of the Army, and in accordance with CEMVR-OD-P appointment order 28 March 2000 has signed below. cz.-20 --os Date When the structures or work authorized by this pennit are still in existence at the time the property is transferred, the tenns and conditions of this permit will continue to be binding on the new owner(s) of the property. To validate the transfer of this penn it and the associated liabilities associated with compliance with its tenns and conditions, have the transferee sign and date below. Transferee Date 4 ý C(-9 c Jr Ia'>1~AI~,~ '2:~' ~j cI 6 0.'EMVR-OD-P-2005-1016 heet 1 of 4 ocation Map I I ! I pnn Co., r:19292 I I 743 :EMVR-OD-P-2005-1016 heet 1 of 4 ocation Map

.

(Page 2 of the Applicatioo Form for Maps or Sketches)CEM IvR-OD-P-2005-1016 Sheet 2 of 4 Location Map A teA-+-0u Place a Vicinity Map in box above..Area to be dredged-Dredged material storage LIST OF ADJACENT.PROPIRTY.OWNERS No. Name Address I. Mr. D on* Mather 4261 McClintock Road 2! Ms. Ruby Franz 4318 Power Plant Road 1 'inn County Conservation PROJECT DESCRIPTION: River Dredging & Spur Dike LOCATION: Cedar River, near Palo, Iowa CENCR FORM 427 I OCT87 (Revised) SHEET ___OF.___CENCR FORM 427 I OCT 87 (Revised)SHEET OF.__,1/(§:. (Page 2 of the Application Forni for Maps or Sketches) CE1vl v'R-OD-P-2005-1016 Sheet 2 of 4 Location Map No. Name 1. Mr. Don'Mather 2 .. Ms. Ruby Franz Address 4261 McClintock Road 4318 Power Plant Road (jnn County Conservation CENCR FORM 427 I ocr 87 (Revised) . Place a Vicinity Map in box above . . Area to be dredged Dredged material storage PROJEct DESCRIPTION: River Dredging & Spur Dike LOCATION: Cedar River, near Palo, Iowa SHEET OF / Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 D.14 Iowa Natural Resources Council Letter, O.R. McMurry, Director, to Duane Arnold, "Control Weir, Wall and Intake Structure" dated August 9, 1971.Document Included in Enclosure 1 of NextEra Energy Duane Arnold's Response to NRC Request re: NG-09-0641 0.14 Iowa Natural Resources Council Letter, O.R. McMurry, Director, to Duane Arnold, "Control Weir, Wall and Intake Structure" dated August 9, 1971. August 9,. 1971 Mr. Duane Arnold Iowa Eiectric Light and Power Company, P.O. Box 351 Cedar Rapids, Iowa 52406 Re: Cona&tweitr, wall and -intake structure Dear Mr. Arnold-Raefreace is made to your for approval of certain. works on the ftoodway, or flood plains. The constructionof your proposed works to accordance with the material submitted was approved by the low Natural Hesources Council at its meeting held on August -. 1971.The materil applicable to the works approved Is enclosed. The copy of Iowa Natural Resources Coumclt Form No. 2 enclosed should be returned within 30 days after the date of completion. Please note the coadittons under which Council orders are granted.If you have any questios regarding the action taken, please feel tree to contact us.Vary truly yours, Director

Enclosures:

Council Order No. 71-1O Approved Application and Pltans INRC Form No. 2 cc, Mr. Louis Nuehring, Conservation Commission Mr. George 1.am.ilton Mr. Ted Lewis Mr. Herb fierold. August fJ. 1911 All". Duane A "oold loTIa E1Mtrlc l ... i,ght and Power P. O. 80x sit ... Rapids, Iowa S24tS IlslCoa., ** ir. walt and atate stl'tlctQ,re . . ': \ ";,. . i$ mat,le to ,.1' ap'pIleaU. for tHt&1U,ti1lcttoaapproval of eertala works OD.the fteJOcJway or flOOd plabla.. eoastrlleti."* 19ur PJ'oposedwOf'ks m aceol'daace with them.terial

• • bmltted was Qpr<IWedb, tbe il!)Jft Nat"ta.:' . Reeour¢es COtlflCU at it. t11Httng held OIl ;AUf.st 3:. 1911. Thf!:ma'ertal appU ** le to the works .,pl"OVtl4 18 flAClo$ed.

Tbe (lOPY of !QR Nat.rat Bo..-mth). Jeaolosed should 1M ** tul'll" wnbla 30 da,. after the date $feotnpletlon. Please GGte the eoadUtona under whieh Cowten are Il'utM .. If you have any questiotl8 "if.FelDe tn. acttOQ taken, pleas. , ** 1 tree to COfttact ue. OltMlrtml jrd Bl'lclolllurest Council Order No. fl .. 19, App,roved .;,'\ppUoatlon ud f"lus mRC :Forln No.2, Mr. Loul$ Nuehrtng, Conservation COBlmissicm 1\11". George Hamilton 1\Ir. Ted Lil1'l1s Itt.... STATE OF IOWA BEFORE THE 10WA RES-OURCES COUNCIL lN THE MATTER OF THE A P6PLICATION OF'IOWA ELECTRIC LIGWT AND POWER f OQRDER NO. ?1-192 COMFANY This matter havlag coms on for final consideration by the Iowa Natural Rlesources Council at a meeting on the 3rd day of 1971.WHEREAS, the lowva Natural Reaources Council, acting under the authority of C~tapters 469 and 455: .Code of Iowa, 1971. as amended, finds that We construction, operatlon. and maintenance of a low-head dlverstom dam acrosh the Cedar Itiver In Section 10, T84N, fR8W. Lian Cmmty, Iowa. In accor-dance with the .pp!catF~i, plans, and vpecffieallaus submit-ed by the lawa Electric Light ead 'Power Company, Coedar Rapids, Iowa, will aot matertally obstruct existing navigation, or materially affect other public rights, wil not endanger Ut. or public health, and any water taken from the stream in coan unction with ithe prOject ehall be In compllancD with the provisloas of 0mapter.469A, Iowa Code, 1971, an amended.IT IS TUE REFORE ORDER)ED by the Iowa Natural F;esources Counecl that -th aforementioned application, plans, and specilleations whch are made a part of this order be and are hereby approved subject to the followva con-(1) no material change in the construction shall be W,4ertaken or made. unleea first authorized by the Iowa Natural Resources Council: Q) this order may be revoked by the Iowa Natural Resoarces Council if construction is not completed within three 03 years of the date of issue;43) notificatioa of completion of construction shall be made to the- Iwa Natural ft'sourees Council within thirty days after completiom; / STA TJ: OF IOWA BEFOHE THE lOW A TURA L tu:Sc:mnCES COL"N elL IN THE MA TTEH OF THE It ?PLtCA TtON OF IOWA EU1:CTRIC UGHT AND POWER. ) OfU)ER NO. 11 .. 192 COMPANY ) This matter havlq come on tor fEnal oODaid&ratiotl by the Iowa 'Natuni fieaourcos CQuncil at a m@oti11g on the 3rd da, of 1911. \\flUJ;REAS, the row. Natural fteaoerCillllCI!)WilCU. acting under the anlthlerUy 01 .. s 469 and Code of 1911, as I1meE.t400. finds thae abe Cl1:mstnaotloa# operation. aDd of a low*head dam aC('OS$ lbe Cll!!dar IUV8l1" in. SfIleUoft 10, T84N, RaW', Wan Cooty, twa. 1a dU¢$ wUh tbeapp!iclI1t!f!)a.. and erp(j}oifteaUQAs by tm,lowa Et8ctl'ie i.* lsbt and F'ow.,. <':t:tmpaay II Cedar llap1ds, iowa.. wUl act materlaU,.* obelrue' eltlsUng nav.setlon. or materially affect ptibUc rights ... 11a not ewiug4!r Wtto,r pubUc health, aM ara.y water takeo from stream tQ eOfll* WlcUoa wUb ttle prQject mbaU be io oompHaactil wUh tile provlsloBtlJ of Chapt&',. 4i1A, Iowa Code" lag amended. IT IS TUEREFOIUC OODltREO by the Iowa Natural HE?80urCOll CO\\DeU that thtl alorem.$aUoned appUoaUoA. plMS, udspectficaUOlls arc made e. rla,.& of tnts order be ud are hereby approved subject to tl:le foUowtae COD'" 4Ulcfts: (!) no material etlanle 1.0 the CODslnotto!! shall be tmdertakec Ol' made uole'$m lil"6! autbol"Azed by tbe Nahll"al Co_en; (2} this order ma), be I'evok$d by tbe Iowa Hesou.l"CEHIl Council it coustruction i8 not completed wUhin qn ot the date of . . notlticaUoD of completion of ooastructiOil shall be made to the l .... wll Natural CouDcil within thil'"ty days alter compleUeni COUNCIL ORDER NO. 71-192 (4) the applicant shall be responsible for proper maintenance; (5) no legal or financial responsibility arising from the con-struction or maintenance of the approved works shall attach to the State of Iowa or the Iowa Natural Resources Council due to the issuance of this order;*.6,) the applicant shaLl be responsible for obtaintag such other governmental licenses, permiLts or approvals and such lands, easements and rights-of-way as are required for the coetruction, operation, and maintenance of the approved works;(7) this order Is ,subject to the apfllcazat securing all required appro"ls from the State Conservatiom for that porlion dealing with State owned property;(6) the applicant shall coordt We 'with the State (Caservation (ommAssion and Lion County Conservation Board relative to the and of an adequMae warning amd marking system to protect the publte's inteest in puablic uSe of this reach of the river.BE IT FURTHER ORDlERED that the Director of the Iowa Natural Resources Council be and is hereby authorized and directed to provide and deliver to the applicant a true and correct exhibit ofthis determination, duly certified. by him to be a trueand correct exhibit of the proceedings of the Iowa Natural Resources Council in respect to this application at a meeting of the Iowa Natural Resources Council held on the date hereinabove indicated. CERTIFICATION I, OTHIE R. MC MURRY, do hereby certify that I am the.duly appointed and acting Director of the Iowa Natural Resources Council and that the foregoing is a true and correct exhibit of the proceedings of the Iowa Natural Resources Council in respect to this application at a meeting held on the 3rd day of August, 1971..Augtit 6 , 191I E C MU D-R o-6978.COUNCIL ORDER NO. 'l1-192 (4) the applicant shaH be responsible for proper maintenance; (5) no legal or financial responsibility arising from the struction or maintenance of the approved works shaH attach to the State of Iowa or the Iowa Natural Resources Council due to the issuance of this order; \6) tns applicant shall be responsible for obtalo.lq $UCh. (Jtber governmental licenses, pe1l"tnlts or approvals and lands, . eaS!2m@nt8J and !'lghts-of*way as are requlred for tbe COftstr:uction. opera:tioE1; and me.latet!l!lftce oi' the apprcved works; (7) U\!s order is subject to the ap!>Ucut tl(!tC!\U'!QS aU required approvals from tha State COBSt'U"VtltiOll Commlsslon t@r that ,orUec deaUng wUb QWaed property; (6) the appUeaot shall eoordlMtewtth tbe State (:cruu:rve.UoQ Cemm!ss!oo aruS Lion County CO!lservaUQQ Board relative to the de.a!gn8 eOQstnscUOftjl aad malrateaanc0' r4 an adequte waninl ",ad tnaridng syatem to protect tne \etenst in "lihUe of this reach of tbe-river. BE IT FURTHER ORnERED that the Director of the Iowa Natural Resources Council be and is hereby authorized and directed to provide and deliver to the applicant a true and correct exhibit of* .*. this determination, duly certified by him to be a true and correct . exhibitof the proceedings of the Iowa Natural Resources Council in . respect to this application ata meeting of the Iowa Natural Resources Council held on the date hereinabove indicated. CE R TIFICA TION I, OTHIE R. MC MURRY, do hereby certify that I am the. duly appointed and acting Director of the Iowa Natural Resources Council and that the foregoing is a true and correct exhibit of the proceedings of the Iowa Natural Resources Council in respect to this application at a meeting held on the 3N day t4 AUlUst. 19?1. Au.tlat £I 19 71 .. INRC Form No. 1 APPLICATION FOR APPROVAL OF CONSTRUCTION IN OR ON ANY FLOODWAY (Submit Application and all Attachments in Duplicate)(Please Print in Ink or use Typewriter) TO: IOWA NATURAL RESOURCES COUNCIL STATE OFFICE BUILDING DES MOINES, IOWA 50319 DATE May25,.1971 Application is hereby made,. under the provisions of Chapter 455A, Code of Iowa, 1966, for approval. of the construction, operation, and maintenance of the works described herein and on the attached plans and specifications: (1) Name and Address of Each Applicant (include all persons having legal responsibility for construction, .operation, and maintenance) Iowa Electric Light and Power Comp___ny- -- ..--,CQgd a_ Rkixdpoa 5240-6 (2) Title or Designation of Plans and Specifications Control weir. wall and intake structure Prepared by: (name and address)* , _ _ ---------__. , _ _ _ _- ---_, In 7<17~~r gC (.(3) Brief Description of Works. and Benefits Expected" We sir emm flLo~ Qo 1nQk+/-e sLuc+/-re_ '-.m-- ---.(4)(5)Location (name of watercourse and land description) Cedar RiverS, Souhwest,'jugarter of Section 10, Town-ship. 84 North. Ran e 8 West_, Linn Cot ---unty.Anticipated Dates of Construction Initiation 15th of August' '71 CompletionovSember__lj._9J71 (6) All lands required for the construction, operation, and main-tenance of the.described works are owned by the (are) (are not)applicant(s) as titleholders of record.. (If not, attach informa-tion indicating the nature and extent of easements and, rights-of-way which have been or will be obtained.) 6/22/67 CPS2970. 6/67 Page 1 of 2.. _. . c:;:). = :;=.. -I INRC Form No. 1 APPLICATION FOR APPROVAL OF CONSTRUCTION IN OR ON ANY FLOODWA Y (Submit Application and all Attachments in Duplicate) TO: (Please Print in Ink or use Typewriter) IOWA NATURAL RESOURCES COUNCIL STA TE OFFICE BUILDING DES MOINES, IOWA 50319 DATE May2S,. 1971 Application is hereby made, under the provisions* of Chapter 455A,Code of Iowa, 1966, for a,pproval of the construction, operation, and maintenance of the v.rorks described herein and on the attached plans and specifications: . ;;0. (1) Name and Address of Each Applicant (include all perSOrishaving legalresponsipility forconstru.ction, . operation, and maintenance) __________ __________________________ ____ __ ____________ __ "-_____ ...,._ (2) Title or Designation of Plans and Specifications __________ _ _____ (3) Brief Description of Works. and Benefits Expected* ___ ____ _____________ _ . . . . . . . .. ' .

s: m =. ::t:> (4) Location (name of watercourse and land description)

.... = :::>> -< n r-= 00 rri. c::. -= <: '= C"':> <.0 ,.,.., rru en. -....J --' 0:-:.. C = = a: C":> ;::: 6/22/67 CP321170.6/07 (5) (6) __ __ __ _____ ____ _ --------------'-0:----...;...-----------------------;---- Anticipated Dates of Construction. . Initiation __ All lands required for the construction, operation, and main-tenance of described works _____ ______ ..:..._ owned by the . . (are) (are not) ... applicant(s)as titleholders of record. (If tion indicating the nature and extent of easements and. way which have been or will be obtained. ) Page 1 of 2 INRC Form No. 1 I (We), being first placed under oath, certify that this application and the plans, specifications, and any other attachments, which are made a part hereof, have been reviewed and approved by the applicant(s) and are true and correct to the best of my (our) knowledge and belief.Signature by or for Each Applicant Indicated in Item No. 1 Official Capacity if Other than Named Applicant_oLqa Electric Li dPw pany 1Y--ArSi T C , BHFC President Stevsn B. S Secretary STATE. OF IOWA COUNTY OF. Linn)I hereby certify that the foregoing application was signed in my presence: and.sworn to before me by this 25th day of__ , 19 -My Commission Expires: S stote w MJly 4,.19/2 -(Notary P~ublic)I hereby certify. that this Application is an accurate and correct copy of the Application made a part of Iowa Natural Resources Council Order No. 71- II.".Z Approved m q %A-ý3)( 7T?1 Director CP.32970!NRC Form No.1 I (We). being first placed under oath. certify that this application and the plans, specifications, and any other attachments, which are made a part hereof. have been reviewed and approved by the applicant(s) and are true and correct to the best of my (our) knowledge and beli.ef. Signature by or for Each Applicant Indicated in Item 1 , secretary------- STATE, OF IOWA , COUNTY OF Linn ) ) Official Capacity if Other than Named Applicant

---

I hereby certify that the foregoing application was signed in my presence and sworn to before me by ____ D.a....ArDQ.J:..d_.an.d...s.te.'lrul-B..-.8mitiL ________ _ this--'----,--25th-------"""""7------dayof-'--,--;;-:;:,-;------------:-19-:;, -----------------------, My COll'lmissi<mExpires: , , " " , " ,

• lilly 4, 1972 -'" . . .:. . I hereby certify, that t}:1is Application is an accurate and correct copy of the" Application made a part of IoWa Natural Resources Courrcil Order No. 71-192 Page20f 2 , , "

MEMORANDUM TO FILE:

SUBJECT:

SUMMARY

REPORT: DUANE ARNOLD ENERGY CENTER LOW-HEAD DIVERSION DAM ACROSS CEDAR RIVER, LINN COUNTY, IOWA DATE: July 23, 1971 BY: STAFF Summary of Information Received Plans and applications have been received from Iowa Electric Light and Power Company for a low-head diversion dam across the Cedar River in Section 10, T84N, R8W, LLnn County, Iowa. The dam will be used to divert water during low flows on the Cedar River to the inlet of the cooling system at Palo Nuclear Power Plant, otherwise Imown as the Duane Arnold Energy Center. The project is being reviewed under the provisions of Chapter 469,as well as Chapter 455A.Report of Field Inspection The area has been Inspected several times in the past and will be observed again prior to the Council meeting.Eggineerig Analysis It has been determined that at discharges in the Cedar River greater than 1000 cfs. no visible sign of the structure's presence will be detectable. At this discharge the flow over the crest of the structure will be 3.5 feet deep. Velocities at this discharge are very low.Other. Considerations A hearing relative to the construction of the dam was held at 11:15 A., M,ýj on July 14, 1971, at the Civii Defense Center, City Haill Cedar Rapids, Iowa.No opponents to the project were present. It was pointed out that little use is being made of this section of stream for boating. An adequate warning.system for boaters is, however, being coordinated with the Conservation Commission. MEMORANDUM TO FILE: Sti13JEC1': DA1"'E: BY: Summary of Information Received

SUMMARY

REPORT: DUANE ARNOLD ENERGY CEN TER LOW-HEAD DIVERSION DAM ACROSS LINN COUNTY. IOWA July 1971 STAFF Plans and applications have been received from Iowa Electrac Light and Power Company fol" a diversion dam across the Cedar River in Secticml()# RaW. Linn County, Iowa. The dam will be used to divert loW' fl,ows on the Cedar River to the inlet of the cooling system at Palo Nv,lclear Power Plant. otherwise knOWfl a.s the Duane Arnold Energy Center. The is being revi.ewed under the provisions of Chapter 469;9.s weH as Chapter 455A. The area has been inspected several times in the past and win be observed. again prior to the Council meeting. Analysis It bas been determined that at discharges in the Cedar River greater than 1000 cf's. no irisible sign of structureOs presence will be detectable .. . At this discharge the flow over the crest of the structuxoe win be 3.5 feet deep. Velocities at this discharge are very low. Other Considerations A hearing relative to the construction of the dam was held at 11:15 A. M.,; .on July 14b 1971>> at the Civil Defense Center D City Hall. Cedar fowa. No opponents to the project v/ere present. It. was pointed out that little USe is being made of this section of stream. for boating. An adequa.te warning. system for boaters is, however. being coordinated with the Conservation Commission. Conclusions and Recommendations-c. is recommended that Council.approval be granted on the basis of a finding that the construction, operation, and mainten.ance of a low-head diversion dam across the Cedar River in Section 10, T84N, R8W, Linn County, lowa, in accordance with the application, plans, and specifications submitted by Iowa Electric Light and Power Company, Cedar Rapids- Iowa, will not materially obstruct existing navigation, or materially affect other public rights, will not endanger life or public health, and any water taken from the stream in con-nection with the project, excepting water taken by a municipality for distri-bution .in its watermains, is*returned thereto at the nearest practicable place without bei4g materially diminished in quantity or polluted or rendered deleterious to fish life. It is further recommended that the Director. be authorized and directed to issue the appropriate order subject to all appli-cable standard conditions.. Order No. 71- Date Approved: / /71 Yrs. for Comp.: ,Std. Cond's: Conclusions and Recommendations It is tha.t Council.a.pproval be granted on the basis ora. fin.di!'1g that the construction. operation, and maintenance of a low-head diversion dam. across the Cedai" Hivel' in Section 10, T84N# RaW. Linn County> Iowa. in accordance with the plans, and specifications submittetd bylaws, Electric Li.ght and !='ow6r Company. Cedar Rapids# Iowa. will not materially obstruct exist{ng navigatiOl'lb or materially affect other public rights. win not endanger tife or public health. and any water taken from the stream in nection with the proje'ct 6 excepting water taken by a municipality for bution .in its is:;:,eturned thereto at the nea.rest practic,ablle . without beir>..g ma.te:d.ally diminished in quantity or polluted or rendered* to fish life. It is further recom.mended the Director be authorized and directed to issue the appropriate order subject to aU cable sta.ndard Order.No. 'H= ___ Date Approved.:_' Yrs. for Comp:-;-:_ . Cond's: ______ .....,;.. ...... _ /71}}