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The paper presents a new rigorous model for high-frequency analysis of grounding systems in non-uniform two-layer soil based on the electromagnetic field theory approach. It is formulated by mixed potential integral equation for arbitrary thin-wire horizontal structures. The corresponding set of Green's functions for the vector and scalar potentials due to elementary electric source embedded in two-layer soil is used. The Sommerfeld-type integrals are solved by direct numerical integration. To enable grounding system analysis, shunt current source is introduced in the moment method solution. Appropriate set of basis and testing functions are used for solution of the integral equation.