Environmental Impact 

Statement for Construction 

Permit for the Northwest 

Medical Isotopes Radioisotope 

Production Facility

Draft Report for Comment

Office of Nuclear Reactor Regulation

NUREG-2209

Environmental Impact 

Statement for Construction 

Permit for the Northwest 

Medical Isotopes Radioisotope 

Production Facility

Draft Report for Comment

Manuscript Completed: October 2016

Date Published: October 2016

Office of Nuclear Reactor Regulation

NUREG-2209
COMMENTS ON DRAFT REPORT

Any interested party may submit comments on this report for consideration by the NRC staff. 

Comments may be accompanied by additional relevant information or supporting data. Please 

specify the report number NUREG-2209 in your comments, and send them by the end of the 

comment period specified in the Federal Register notice announcing the availability of this 

report. 

Addresses: You may submit comments by any one of the following methods. Please include 

Docket ID NRC-2013-0235 in the subject line of your comments. Comments submitted in 

writing or in electronic form will be posted on the NRC website and on the Federal rulemaking 

website http://www.regulations.gov. 

Federal Rulemaking Website: Go to http://www.regulations.gov and search for documents 

filed under Docket ID NRC-2013-0235. Address questions about NRC dockets to Carol 

Gallagher at 301-415-3463 or by e-mail at Carol.Gallagher@nrc.gov. 

Mail comments to: Cindy Bladey, Chief, Rules, Announcements, and Directives Branch

(RADB), Division of Administrative Services, Office of Administration, Mail Stop: 

OWFN-12-H08, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. 

For any questions about the material in this report, please contact: David Drucker, Senior 

Project Manager, 301-415-6223 or by e-mail at david.drucker@nrc.gov. 

Please be aware that any comments that you submit to the NRC will be considered a public 

record and entered into the Agencywide Documents Access and Management System 

(ADAMS). Do not provide information you would not want to be publicly available.
iii

1 COVER SHEET

2 Responsible Agency: U.S. Nuclear Regulatory Commission (NRC), Office of Nuclear Reactor

3 Regulation.

4 Title: Environmental Impact Statement for the Construction Permit for the Northwest Medical 

5 Isotopes, LLC (NWMI) Medical Radioisotope Production Facility, Draft Report for Comment

6 The proposed Northwest Medical Isotopes, LLC (NWMI), facility would be located in Columbia, 

7 Missouri.

8 Additional information or copies of this document are available through the following:

9 Division of License Renewal

10 U.S. Nuclear Regulatory Commission (NRC)

11 Office of Nuclear Reactor Regulation

12 Mail Stop O-11F1

13 11555 Rockville Pike

14 Rockville, MD 20852

15 Phone: 1-800-368-5642, extension 6223

16 E-mail: David.Drucker@nrc.gov

17 ABSTRACT

18 The U.S Nuclear Regulatory Commission (NRC) has prepared this environmental impact

19 statement (EIS) in response to an application submitted by Northwest Medical Isotopes, LLC 

20 (NWMI), for a construction permit for the NWMI medical radioisotope production facility. The

21 EIS includes the analysis that evaluates the environmental impacts of the proposed action and

22 considers the following alternatives to the proposed action: (1) the no-action alternative (i.e., the 

23 construction permit is denied), (2) one alternative site, and (3) two alternative technologies.

24 After weighing the environmental, economic, technical, and other benefits against environmental

25 and other costs, and considering reasonable alternatives, the NRC staff’s preliminary 

26 recommendation, unless safety issues mandate otherwise, is to issue a construction permit to 

27 NWMI. The NRC staff based its recommendation on the following factors:

28 • the NRC staff’s review of the NWMI Environmental Report;

29 • the NRC staff’s consultation with Federal, State, and local agencies and Tribal 

30 officials;

31 • the NRC staff’s independent environmental review; and

32 • the NRC staff’s consideration of public comments received.

v

1 TABLE OF CONTENTS

2 ABSTRACT.............................................................................................................................. iii

3 TABLE OF CONTENTS ............................................................................................................ v

4 LIST OF FIGURES ................................................................................................................. xiii

5 LIST OF TABLES.................................................................................................................... xv

6 EXECUTIVE SUMMARY .........................................................................................................xix

7 ABBREVIATIONS AND ACRONYMS ...................................................................................xxiii

8 1.0 INTRODUCTION......................................................................................................... 1-1

9 1.1 Background...................................................................................................... 1-1

10 1.2 Proposed Federal Action.................................................................................. 1-2

11 1.3 Purpose and Need for the Proposed Federal Action ........................................ 1-3

12 1.4 U.S. Nuclear Regulatory Commission Environmental Review.......................... 1-3

13 1.5 Scope of the EIS.............................................................................................. 1-6

14 1.6 Preconstruction Activities ................................................................................. 1-6

15 1.7 Consultation and Correspondence................................................................... 1-7

16 1.8 Status of Compliance....................................................................................... 1-9

17 2.0 PROPOSED FEDERAL ACTION................................................................................ 2-1

18 2.1 Site Location and Layout.................................................................................. 2-1

19 2.2 Construction Activities...................................................................................... 2-4

20 2.3 Facility Operations ........................................................................................... 2-5

21 2.3.1 Radioisotope Production Process Overview ...................................... 2-7

22 2.3.1.1 LEU Target Fabrication ....................................................... 2-9

23 2.3.1.2 LEU Target Irradiation....................................................... 2-10

24 2.3.1.3 Irradiated Target Disassembly and Dissolution ................. 2-11

25 2.3.1.4 Mo-99 Extraction, Purification, and Shipping..................... 2-11

26 2.3.1.5 Uranium Recovery and Recycle........................................ 2-11

27 2.4 Power Requirements ..................................................................................... 2-12

28 2.5 Water Use, Treatment, and Discharges ......................................................... 2-12

29 2.5.1 Water Use ....................................................................................... 2-12

30 2.5.2 Water Treatment ............................................................................. 2-13

31 2.5.3 Water Discharges............................................................................ 2-14

32 2.6 Cooling and Heating Dissipation Systems...................................................... 2-14

33 2.6.1 Cooling Systems ............................................................................. 2-14

34 2.6.2 Heating Systems ............................................................................. 2-14

35 2.7 Radioactive and Nonradioactive Waste.......................................................... 2-14

36 2.7.1 Radioactive Waste........................................................................... 2-15

37 2.7.1.1 Gaseous Waste ................................................................ 2-15

38 2.7.1.2 Liquid and Solid Waste ..................................................... 2-16
Table of Contents

vi

1 2.7.2 Nonradioactive Waste ..................................................................... 2-17

2 2.7.2.1 Liquid Waste ..................................................................... 2-17

3 2.7.2.2 Solid Waste....................................................................... 2-18

4 2.7.3 Waste Minimization and Pollution Prevention Program.................... 2-19

5 2.8 Storage and Transportation of Radioactive and Nonradioactive 

6 Materials and Waste ...................................................................................... 2-19

7 2.8.1 Storage and Transportation ............................................................. 2-19

8 2.8.1.1 Radioactive Waste and Other Materials ............................ 2-19

9 2.8.1.2 Nonradioactive Waste and Other Materials ....................... 2-20

10 2.9 Facility Decommissioning............................................................................... 2-21

11 3.0 AFFECTED ENVIRONMENT ...................................................................................... 3-1

12 3.1 Land Use and Visual Resources...................................................................... 3-1

13 3.1.1 Land Use........................................................................................... 3-1

14 3.1.1.1 Site and Immediate Surroundings ....................................... 3-1

15 3.1.1.2 Vicinity ................................................................................ 3-2

16 3.1.1.3 Special Land Uses .............................................................. 3-4

17 3.1.1.4 Agricultural Resources and Facilities .................................. 3-4

18 3.1.2 Visual Resources............................................................................... 3-5

19 3.2 Meteorology, Air Quality, and Noise............................................................... 3-11

20 3.2.1 Meteorology and Climatology .......................................................... 3-11

21 3.2.2 Air Quality........................................................................................ 3-12

22 3.2.3 Noise............................................................................................... 3-16

23 3.3 Geologic Environment.................................................................................... 3-17

24 3.3.1 Site Geology.................................................................................... 3-18

25 3.3.2 Soils ................................................................................................ 3-24

26 3.3.3 Seismic Setting................................................................................ 3-25

27 3.4 Water Resources ........................................................................................... 3-26

28 3.4.1 Surface Water ................................................................................. 3-27

29 3.4.1.1 Surface Water Hydrology .................................................. 3-27

30 3.4.1.2 Surface Water Quality and Use......................................... 3-29

31 3.4.2 Groundwater.................................................................................... 3-32

32 3.4.2.1 Site Description and Hydrogeology ................................... 3-32

33 3.4.2.2 Groundwater Quality and Use ........................................... 3-35

34 3.5 Ecological Resources .................................................................................... 3-37

35 3.5.1 Ecoregion ........................................................................................ 3-37

36 3.5.2 Habitats in the Vicinity of the Proposed Site .................................... 3-37

37 3.5.3 Site.................................................................................................. 3-40

38 3.5.4 Protected Species and Habitats....................................................... 3-42

39 3.5.4.1 Endangered Species Act................................................... 3-43

40 3.5.4.2 State-listed Species .......................................................... 3-43

41 3.5.4.3 Migratory Bird Treaty Act................................................... 3-45
Table of Contents

vii

1 3.5.4.4 Magnuson–Stevens Fishery Conservation and 

2 Management Act............................................................... 3-46

3 3.6 Historic and Cultural Resources..................................................................... 3-46

4 3.6.1 Cultural Background........................................................................ 3-47

5 3.6.1.1 Paleo-Indian Period (11,500 to 9,900 B.P.)....................... 3-47

6 3.6.1.2 Archaic Period (9,900 to 3,000 B.P.)................................. 3-47

7 3.6.1.3 Woodland Period (3,000 to 1,000 B.P.)............................. 3-48

8 3.6.1.4 Mississippian Period (1,000 to 400 B.P.)........................... 3-48

9 3.6.1.5 Protohistoric/Historic Period (400 B.P. to Recent 

10 History) ............................................................................. 3-49

11 3.6.1.6 Recent History – Columbia................................................ 3-49

12 3.6.1.7 Recent History – Discovery Ridge..................................... 3-50

13 3.6.2 Historic and Cultural Resources ...................................................... 3-50

14 3.7 Socioeconomics............................................................................................. 3-51

15 3.7.1 Population Growth Rates and Projections ....................................... 3-51

16 3.7.2 Race and Ethnicity........................................................................... 3-51

17 3.7.3 Transient Population........................................................................ 3-53

18 3.7.4 Labor Force, Employment, and Unemployment............................... 3-53

19 3.7.5 Income and Wages and Poverty...................................................... 3-54

20 3.7.6 Housing ........................................................................................... 3-55

21 3.7.7 Local Employers.............................................................................. 3-56

22 3.7.8 Taxes .............................................................................................. 3-56

23 3.7.9 Education ........................................................................................ 3-57

24 3.7.10 Public Recreation for Boone County................................................ 3-57

25 3.7.11 Public Services................................................................................ 3-58

26 3.8 Human Health................................................................................................ 3-59

27 3.8.1 Sensitive Receptors......................................................................... 3-59

28 3.8.2 Radiation and Nuclear Hazards....................................................... 3-61

29 3.8.2.1 Pathways for Human Exposure to Radiation and 

30 Radioactivity...................................................................... 3-61

31 3.8.2.2 Major Sources and Levels of Radiation............................. 3-61

32 3.8.2.3 Regulations Governing Dose from Human-Made 

33 Sources of Radiation......................................................... 3-62

34 3.8.3 Chemical Hazards ........................................................................... 3-63

35 3.8.4 Other Hazards ................................................................................. 3-64

36 3.9 Transportation Environments ......................................................................... 3-64

37 3.9.1 Roads.............................................................................................. 3-65

38 3.9.2 Airports............................................................................................ 3-65

39 3.9.3 Rail.................................................................................................. 3-66

40 3.10 Research Reactors ........................................................................................ 3-66

41 3.10.1 University of Missouri Research Reactor......................................... 3-66

42 3.10.2 Oregon State University Research Reactor..................................... 3-70
Table of Contents

viii

1 3.10.3 Third Research Reactor................................................................... 3-72

2 4.0 ENVIRONMENTAL IMPACTS OF CONSTRUCTION, OPERATIONS, AND 

3 DECOMMISSIONING.................................................................................................. 4-1

4 4.1 Land Use and Visual Resources...................................................................... 4-2

5 4.1.1 Land Use........................................................................................... 4-2

6 4.1.1.1 Construction........................................................................ 4-2

7 4.1.1.2 Operations .......................................................................... 4-3

8 4.1.1.3 Decommissioning................................................................ 4-3

9 4.1.2 Visual Resources............................................................................... 4-3

10 4.1.2.1 Construction........................................................................ 4-3

11 4.1.2.2 Operations .......................................................................... 4-4

12 4.1.2.3 Impacts from Decommissioning .......................................... 4-5

13 4.2 Air Quality and Noise ....................................................................................... 4-5

14 4.2.1 Air Quality.......................................................................................... 4-5

15 4.2.1.1 Construction........................................................................ 4-5

16 4.2.1.2 Operations .......................................................................... 4-7

17 4.2.1.3 Decommissioning................................................................ 4-8

18 4.2.2 Noise................................................................................................. 4-9

19 4.2.2.1 Construction........................................................................ 4-9

20 4.2.2.2 Operations ........................................................................ 4-10

21 4.2.2.3 Decommissioning.............................................................. 4-10

22 4.3 Geologic Environment.................................................................................... 4-11

23 4.3.1 Construction .................................................................................... 4-11

24 4.3.2 Operations....................................................................................... 4-13

25 4.3.3 Decommissioning ............................................................................ 4-14

26 4.4 Water Resources ........................................................................................... 4-14

27 4.4.1 Surface Water ................................................................................. 4-14

28 4.4.1.1 Construction...................................................................... 4-14

29 4.4.1.2 Operations ........................................................................ 4-16

30 4.4.1.3 Decommissioning.............................................................. 4-18

31 4.4.2 Groundwater.................................................................................... 4-18

32 4.4.2.1 Construction...................................................................... 4-18

33 4.4.2.2 Operations ........................................................................ 4-20

34 4.4.2.3 Decommissioning.............................................................. 4-20

35 4.5 Ecological Resources .................................................................................... 4-21

36 4.5.1 Construction .................................................................................... 4-21

37 4.5.2 Operations....................................................................................... 4-22

38 4.5.3 Decommissioning ............................................................................ 4-23

39 4.5.4 Federally Protected Species............................................................ 4-23

40 4.6 Historic and Cultural Resources..................................................................... 4-24

41 4.6.1 Historic and Cultural Resources ...................................................... 4-24
Table of Contents

ix

1 4.6.2 Proposed Action .............................................................................. 4-24

2 4.6.3 Consultation .................................................................................... 4-24

3 4.6.3.1 Construction...................................................................... 4-26

4 4.6.3.2 Operations ........................................................................ 4-26

5 4.6.3.3 Decommissioning.............................................................. 4-26

6 4.7 Socioeconomic Impacts ................................................................................. 4-27

7 4.7.1 Construction .................................................................................... 4-27

8 4.7.1.1 Employment...................................................................... 4-27

9 4.7.1.2 Housing............................................................................. 4-27

10 4.7.1.3 Tax Revenue..................................................................... 4-27

11 4.7.1.4 Public and Educational Services ....................................... 4-28

12 4.7.1.5 Summary of Construction Impacts .................................... 4-28

13 4.7.2 Operations....................................................................................... 4-28

14 4.7.2.1 Employment...................................................................... 4-28

15 4.7.2.2 Housing............................................................................. 4-28

16 4.7.2.3 Tax Revenue..................................................................... 4-28

17 4.7.2.4 Public and Educational Services ....................................... 4-28

18 4.7.2.5 Summary of Operations Impacts....................................... 4-29

19 4.7.3 Decommissioning ............................................................................ 4-29

20 4.7.3.1 Employment...................................................................... 4-29

21 4.7.3.2 Housing............................................................................. 4-29

22 4.7.3.3 Tax Revenue..................................................................... 4-29

23 4.7.3.4 Public and Educational Services ....................................... 4-29

24 4.7.3.5 Summary of Decommissioning Impacts ............................ 4-30

25 4.8 Human Health................................................................................................ 4-30

26 4.8.1 Construction .................................................................................... 4-30

27 4.8.1.1 Radiological ...................................................................... 4-30

28 4.8.1.2 Nonradiological ................................................................. 4-30

29 4.8.2 Operations....................................................................................... 4-31

30 4.8.2.1 Radiological ...................................................................... 4-31

31 4.8.2.2 Nonradiological ................................................................. 4-34

32 4.8.3 Decommissioning ............................................................................ 4-34

33 4.8.3.1 Radiological ...................................................................... 4-34

34 4.8.3.2 Nonradiological ................................................................. 4-35

35 4.9 Waste Management....................................................................................... 4-36

36 4.9.1 Radioactive Waste........................................................................... 4-36

37 4.9.2 Nonradioactive Waste ..................................................................... 4-37

38 4.10 Transportation................................................................................................ 4-38

39 4.10.1 Construction .................................................................................... 4-38

40 4.10.2 Operations....................................................................................... 4-39

41 4.10.3 Decommissioning ............................................................................ 4-39
Table of Contents

x

1 4.11 Accidents ....................................................................................................... 4-40

2 4.11.1 Radiological Accidents .................................................................... 4-41

3 4.11.2 Hazardous Chemical Accidents....................................................... 4-44

4 4.12 Environmental Justice.................................................................................... 4-49

5 4.12.1 Construction .................................................................................... 4-53

6 4.12.2 Operations....................................................................................... 4-54

7 4.12.3 Decommissioning ............................................................................ 4-54

8 4.13 Research Reactors ........................................................................................ 4-54

9 4.13.1 University of Missouri Research Reactor Site.................................. 4-55

10 4.13.1.1 Facility Modifications and Equipment Refurbishment ........ 4-55

11 4.13.1.2 Irradiation Services ........................................................... 4-56

12 4.13.2 Oregon State University TRIGA Reactor Site .................................. 4-58

13 4.13.2.1 Facility Modifications and Equipment Refurbishment ........ 4-58

14 4.13.2.2 Irradiation Services ........................................................... 4-58

15 4.13.3 Third Research Reactor................................................................... 4-61

16 4.13.3.1 Facility Modifications and Equipment Refurbishment ........ 4-61

17 4.13.3.2 Irradiation Services ........................................................... 4-62

18 4.14 Cumulative Impacts ....................................................................................... 4-64

19 4.14.1 Land Use and Visual Resources...................................................... 4-70

20 4.14.1.1 Land Use .......................................................................... 4-70

21 4.14.1.2 Visual Resources .............................................................. 4-71

22 4.14.2 Air Quality and Noise....................................................................... 4-71

23 4.14.2.1 Air Quality ......................................................................... 4-71

24 4.14.2.2 Noise................................................................................. 4-72

25 4.14.3 Geologic Environment ..................................................................... 4-73

26 4.14.4 Water Resources............................................................................. 4-74

27 4.14.4.1 Surface Water................................................................... 4-75

28 4.14.4.2 Groundwater ..................................................................... 4-77

29 4.14.5 Ecological Resources ...................................................................... 4-78

30 4.14.6 Historic and Cultural Resources ...................................................... 4-80

31 4.14.7 Socioeconomics .............................................................................. 4-80

32 4.14.8 Human Health ................................................................................. 4-81

33 4.14.8.1 Radiological Impacts......................................................... 4-81

34 4.14.8.2 Nonradiological Impacts.................................................... 4-83

35 4.14.9 Waste Management ........................................................................ 4-83

36 4.14.9.1 Radioactive Waste ............................................................ 4-84

37 4.14.9.2 Nonradioactive Waste....................................................... 4-84

38 4.14.10 Accidents......................................................................................... 4-85

39 4.14.10.1 Radiological Accidents ...................................................... 4-85

40 4.14.10.2 Nonradiological Accidents................................................. 4-86

41 4.14.11 Transportation ................................................................................. 4-87
Table of Contents

xi

1 4.14.12 Environmental Justice ..................................................................... 4-87

2 4.14.13 Summary......................................................................................... 4-88

3 5.0 ALTERNATIVES......................................................................................................... 5-1

4 5.1 No-Action Alternative ....................................................................................... 5-2

5 5.2 Alternative Sites............................................................................................... 5-2

6 5.2.1 Description of Alternative Site-Selection Process .............................. 5-2

7 5.2.1.1 Initial Site Screening ........................................................... 5-2

8 5.2.1.2 Secondary Screening.......................................................... 5-3

9 5.2.2 University of Missouri Research Reactor Alternative Site .................. 5-7

10 5.2.2.1 Land Use and Visual Resources ......................................... 5-8

11 5.2.2.2 Air Quality and Noise ........................................................ 5-10

12 5.2.2.3 Geologic Environment....................................................... 5-13

13 5.2.2.4 Water Resources .............................................................. 5-17

14 5.2.2.5 Ecological Resources........................................................ 5-22

15 5.2.2.6 Historic and Cultural Resources........................................ 5-24

16 5.2.2.7 Socioeconomics................................................................ 5-25

17 5.2.2.8 Human Health................................................................... 5-25

18 5.2.2.9 Waste Management.......................................................... 5-27

19 5.2.2.10 Transportation................................................................... 5-28

20 5.2.2.11 Accidents .......................................................................... 5-30

21 5.2.2.12 Environmental Justice ....................................................... 5-31

22 5.2.2.13 Cumulative Impacts........................................................... 5-36

23 5.3 Alternative Technologies................................................................................ 5-52

24 5.3.1 Description of Alternative Technology Screening Process............... 5-53

25 5.3.1.1 Initial Screening ................................................................ 5-53

26 5.3.1.2 Secondary Screening........................................................ 5-54

27 5.3.2 Linear Accelerator-Based Technology............................................. 5-55

28 5.3.2.1 Land Use and Visual Resources ....................................... 5-56

29 5.3.2.2 Air Quality and Noise ........................................................ 5-56

30 5.3.2.3 Geologic Environment....................................................... 5-58

31 5.3.2.4 Water Resources .............................................................. 5-60

32 5.3.2.5 Ecological Resources........................................................ 5-64

33 5.3.2.6 Historic and Cultural Resources........................................ 5-64

34 5.3.2.7 Socioeconomics................................................................ 5-64

35 5.3.2.8 Human Health................................................................... 5-64

36 5.3.2.9 Waste Management.......................................................... 5-65

37 5.3.2.10 Transportation................................................................... 5-65

38 5.3.2.11 Accidents .......................................................................... 5-66

39 5.3.2.12 Environmental Justice....................................................... 5-67

40 5.3.2.13 Cumulative Impacts........................................................... 5-67

41 5.3.3 Subcritical Fission Technology ........................................................ 5-67
Table of Contents

xii

1 5.3.3.1 Land Use and Visual Resources ....................................... 5-68

2 5.3.3.2 Air Quality and Noise ........................................................ 5-69

3 5.3.3.3 Geologic Environment....................................................... 5-72

4 5.3.3.4 Water Resources .............................................................. 5-74

5 5.3.3.5 Ecological Resources........................................................ 5-77

6 5.3.3.6 Historic and Cultural Resources........................................ 5-77

7 5.3.3.7 Socioeconomics................................................................ 5-78

8 5.3.3.8 Human Health................................................................... 5-78

9 5.3.3.9 Waste Management.......................................................... 5-79

10 5.3.3.10 Transportation................................................................... 5-79

11 5.3.3.11 Accidents .......................................................................... 5-80

12 5.3.3.12 Environmental Justice....................................................... 5-80

13 5.3.3.13 Cumulative Impacts........................................................... 5-81

14 5.4 Cost-Benefit Comparison............................................................................... 5-81

15 5.4.1 Benefit and Costs of Alternatives..................................................... 5-85

16 5.4.2 Cost-Benefit Conclusions ................................................................ 5-86

17 5.5 Alternatives Summary.................................................................................... 5-87

18 6.0 CONCLUSIONS.......................................................................................................... 6-1

19 6.1 Environmental Impacts of the Proposed Action................................................ 6-1

20 6.2 Comparison of Alternatives .............................................................................. 6-4

21 6.3 Resource Commitments................................................................................... 6-5

22 6.3.1 Unavoidable Adverse Impacts ........................................................... 6-5

23 6.3.2 Relationship Between Local Short-Term Uses of the 

24 Environment and the Maintenance and Enhancement of 

25 Long-Term Productivity ................................................................... 6-10

26 6.3.3 Irreversible and Irretrievable Commitment of Resources ................. 6-11

27 6.3.4 Unresolved Conflicts........................................................................ 6-12

28 6.4 Preliminary Recommendation ........................................................................ 6-12

29 7.0 REFERENCES............................................................................................................ 7-1

30 8.0 LIST OF PREPARERS ............................................................................................... 8-1

31 9.0 DISTRIBUTION LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS 

32 TO WHOM COPIES OF THIS ENVIRONMENTAL IMPACT STATEMENT ARE 

33 SENT........................................................................................................................... 9-1

34 10.0 INDEX ....................................................................................................................... 10-1

35 COMMENTS RECEIVED ON THE NORTHWEST MEDICAL ISOTOPES,

36 LLC, RADIOISOTOPE PRODUCTION FACILITY ENVIRONMENTAL 

37 REVIEW ..........................................................................................................A-1

38 APPLICABLE LAWS, REGULATIONS, AND OTHER REQUIREMENTS .......B-1

39 CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE.......C-1

40 CONSULTATION CORRESPONDENCE.........................................................D-1
xiii

1 LIST OF FIGURES

2 Figure 1–1. Environmental Review Process.......................................................................... 1-5

3 Figure 2–1. Discovery Ridge Research Park and Proposed NWMI Site (Discovery 

4 Ridge) ................................................................................................................ 2-2

5 Figure 2–2. Proposed NWMI Site (Discovery Ridge) and Surrounding Area Within 

6 5-mi (8-km) Radius............................................................................................. 2-3

7 Figure 2–3. Proposed NWMI Facility Site Boundary and Site Layout .................................... 2-4

8 Figure 2–4. NWMI Radioisotope Production Facility Process................................................ 2-8

9 Figure 2–5. General Layout of the Proposed NWMI Radioisotope Production Facility 

10 Building .............................................................................................................. 2-9

11 Figure 3–1. Cities and Major Roadways Within 5 mi (8 km) of the Proposed 

12 Discovery Ridge Site.......................................................................................... 3-3

13 Figure 3–2. September 2013 Visual Reconnaissance Photo Locations................................. 3-6

14 Figure 3–3. View of Proposed Radioisotope Production Facility Site from Intersection 

15 of Rolling Hills and Bass Roads, Photo Location #1 ........................................... 3-7

16 Figure 3–4. View of Proposed Radioisotope Production Facility Site from Gans Road, 

17 approximately 1.6 km (1 mi) North Photo Location #2 ........................................ 3-7

18 Figure 3–5. Direct View of Radioisotope Production Facility Site from Discovery 

19 Parkway near the Overpass, Photo Location #3................................................. 3-8

20 Figure 3–6. View of Radioisotope Production Facility Site from the North Edge of 

21 Perry Phillips Lake, Photo Location #4 ............................................................... 3-8

22 Figure 3–7. View of Proposed Radioisotope Production Facility Site from Boys and 

23 Girls Town of Missouri, Photo Location #5 ......................................................... 3-9

24 Figure 3–8. View of Proposed Radioisotope Production Facility Site from S. Lenoir 

25 and Roosevelt Avenue, Photo Location #6......................................................... 3-9

26 Figure 3–9. View of Proposed Radioisotope Production Facility Site from Intersection 

27 of New Haven and Rolling Hills Roads, Photo Location #7............................... 3-10

28 Figure 3–10. View of Proposed Radioisotope Production Facility Site from Route WW 

29 at Old Hawthorne, Photo Location #8............................................................... 3-10

30 Figure 3–11. Topographic Map of the Discovery Ridge Site and Vicinity............................... 3-19

31 Figure 3–12. Bedrock Geology of the Discovery Ridge Site and Vicinity ............................... 3-23

32 Figure 3–13. Major Surface Water Features in the Vicinity of the Discovery Ridge Site ........ 3-28

33 Figure 3–14. Location of Sensitive Receptors Near the Proposed Discovery Ridge Site....... 3-60

34 Figure 4–1. Conceptual Rendering of Proposed NWMI Facility.............................................. 4-4

35 Figure 5–1. Cities and Major Roadways Transportation near the University of 

36 Missouri Research Reactor Alternative Site ....................................................... 5-8

37 Figure 5–2. Topographic Map of the MURR Site and Vicinity.............................................. 5-15

xv

1 LIST OF TABLES

2 Table ES–1. Summary of NRC Conclusions on the Environmental Impacts of 

3 Construction, Operations, and Decommissioning of the Proposed NWMI 

4 Facility................................................................................................................. xxi

5 Table 2–1. Estimated Construction Materials Requirements ................................................ 2-5

6 Table 2–2. Estimated Annual Shipments to and from the Proposed NWMI Facility.............. 2-6

7 Table 2–3. Water Requirements for NWMI Facility............................................................. 2-12

8 Table 2–4. Gaseous Radioactive Effluents ........................................................................ 2-16

9 Table 2–5. Summary of Chemical Inventory and Quantity at the Proposed NWMI 

10 Facility.............................................................................................................. 2-17

11 Table 3–1. Summary of Land Use and Land Cover Within the Proposed Discovery 

12 Ridge Site and Vicinity ....................................................................................... 3-3

13 Table 3–2. Annual and Seasonal Precipitation and Temperature Data for Columbia, 

14 Missouri............................................................................................................ 3-12

15 Table 3–3. Ambient Air Quality Standards ......................................................................... 3-13

16 Table 3–4. Boone County Air Emissions Inventory, Tons/Year .......................................... 3-14

17 Table 3–5. Common Noise Sources and Noise Levels ...................................................... 3-16

18 Table 3–6. Summary of Boring Log B-5 Completed in the Vicinity of the Proposed 

19 NWMI Facility Site, Discovery Ridge Research Park........................................ 3-20

20 Table 3–7. Groundwater Use in Boone County, 2010 ........................................................ 3-35

21 Table 3–8. Typical Wildlife That May Occur on or near the Proposed Site ......................... 3-41

22 Table 3–9. Federally and State-Listed Species That May Occur on or near the 

23 Proposed Discovery Ridge Site........................................................................ 3-44

24 Table 3–10. Migratory Birds of Concern that May Occur near the Proposed Discovery 

25 Ridge Site. ....................................................................................................... 3-45

26 Table 3–11. Boone County Population (1980–2050)............................................................ 3-51

27 Table 3–12. Race and Ethnicity for Columbia and Boone County, Missouri, in 2010............ 3-52

28 Table 3–13. Race and Ethnicity for Columbia and Boone County, Missouri, in 2014............ 3-52

29 Table 3–14. Labor Force, Employment, and Unemployment Rates in Missouri, Boone 

30 County, and the City of Columbia (2014).......................................................... 3-54

31 Table 3–15. Employment by Industry in Boone County for 2014.......................................... 3-54

32 Table 3–16. Median Family Income and Per Capita Income for the City of Columbia, 

33 Boone County, and State of Missouri in 2014................................................... 3-55

34 Table 3–17. Housing Unit Characteristics for Boone County and City of Columbia

35 in 2014 ............................................................................................................. 3-55

36 Table 3–18. Ten Largest Employers in the City of Columbia and Boone County (2014) ...... 3-56

37 Table 3–19. Parks within a 5-mi (8-km) Radius of the Proposed NWMI Facility Site ............ 3-57

38 Table 3–20. Public Water Supply Systems in Boone County ............................................... 3-59

39 Table 3–21. Sensitive Receptors from the Discovery Ridge Site.......................................... 3-59

40 Table 3–22. Average Daily Traffic Counts in the Vicinity of the Proposed NWMI 

41 Facility Site 2013.............................................................................................. 3-65

42 Table 3–23. MURR Ar-41 Effluents...................................................................................... 3-67
List of Tables

xvi

1 Table 3–24. MURR Sanitary Sewer Radioactive Effluents ................................................... 3-68

2 Table 3–25. MURR Solid Low-Level Radioactive Waste Shipments .................................... 3-68

3 Table 3–26. MURR Occupational Doses (Operations Group) .............................................. 3-69

4 Table 3–27. MURR Occupational Doses (Health Physics Group) ........................................ 3-69

5 Table 3–28. MURR Occupational Doses (Shipping Group).................................................. 3-69

6 Table 3–29. OSTR Solid Low-Level Radioactive Waste Shipments ..................................... 3-71

7 Table 3–30. OSTR Occupational Doses .............................................................................. 3-72

8 Table 4–1. Acres of Land Required for Construction of the Proposed NWMI Facility ........... 4-2

9 Table 4–2. Equipment and Activity Parameters During Construction ................................... 4-5

10 Table 4–3. Estimated Emissions During Construction.......................................................... 4-6

11 Table 4–4. Emissions Sources and Estimated Emissions During Operations....................... 4-7

12 Table 4–5. Air Emissions During Decommissioning ............................................................. 4-9

13 Table 4–6. Definition of High- and Intermediate-Consequence Radiological Accidents...... 4-41

14 Table 4–7. Definition of High- and Intermediate-Consequence Chemical Accidents .......... 4-45

15 Table 4–8. NWMI Hazardous Chemical Concentrations .................................................... 4-47

16 Table 4–9. Minority Populations in Census Block Groups Within 5 mi (8 km) of the 

17 Discovery Ridge Site........................................................................................ 4-51

18 Table 4–10. Percentage of People and Families in Census Tracts Within 5 mi (8 km) 

19 of the Discovery Ridge Site Whose Income is Below the Poverty Level ........... 4-52

20 Table 4–11. Past, Present, and Reasonably Foreseeable Projects and Other Actions 

21 Retained for the Cumulative Impacts Analysis – Discovery Ridge.................... 4-65

22 Table 4–12. Cumulative Impacts on Environmental Resources, Including the Impacts 

23 of the Proposed Project.................................................................................... 4-88

24 Table 5–1. NWMI Site-Selection Scoring Criteria................................................................. 5-6

25 Table 5–2. Average Daily Traffic Counts in the Vicinity of the MURR Site 2013................. 5-28

26 Table 5–3. Minority Populations in Census Block Groups Within 5 mi (8 km) of the 

27 MURR Site ....................................................................................................... 5-32

28 Table 5–4. Percentage of People and Families in Census Tracts Within 5 mi (8 km) 

29 of the MURR Site Whose Income is Below the Poverty Level .......................... 5-34

30 Table 5–5. Past, Present, and Reasonably Foreseeable Projects and Other Actions 

31 Considered for the Cumulative Impacts Analysis – MURR ............................... 5-36

32 Table 5–6. Estimated Air Emissions Resulting from Construction of a Linear

33 Accelerator-Based Facility................................................................................ 5-56

34 Table 5–7. Estimated Air Emissions Resulting from Operation of a Linear 

35 Accelerator-Based Facility................................................................................ 5-57

36 Table 5–8. Estimated Air Emissions Resulting from Construction of a Subcritical 

37 Fission Facility.................................................................................................. 5-69

38 Table 5–9. Estimated Air Emissions Resulting from Operation of a Subcritical Fission 

39 Facility.............................................................................................................. 5-70

40 Table 5–10. Estimated Air Emissions Resulting from Decommissioning of a Subcritical 

41 Fission Facility.................................................................................................. 5-70

42 Table 5–11. Costs and Benefits of Constructing, Operating, and Decommissioning the 

43 Proposed NWMI Facility at the Discovery Ridge Site ....................................... 5-82
List of Tables

xvii

1 Table 5–12. Comparison of Impacts for the Proposed NWMI Facility, Proposed 

2 Alternative Site, and No-Action......................................................................... 5-85

3 Table 5–13. Comparison of Technologies at the Proposed NWMI Facility in Discovery 

4 Ridge ............................................................................................................... 5-86

5 Table 6–1. Summary of the Environmental Impacts from Construction, Operations, 

6 and Decommissioning of the Proposed NWMI Facility at the Discovery 

7 Ridge site........................................................................................................... 6-1

8 Table 6–2. Unavoidable Adverse Environmental Impacts .................................................... 6-5

9 Table 8–1. List of Preparers................................................................................................. 8-1

10 Table 9–1. List of Agencies, Organizations, and Persons to Whom Copies of This 

11 Environmental Impact Statement Are Sent......................................................... 9-1

12 Table A–1. Individuals Providing Comments During the Scoping Comment Period.............. A-2

13 Table A–2. Issue Categories ................................................................................................ A-2

14 Table B–1. Potentially Applicable Federal Statutes, Regulations, and Orders ...................... B-2

15 Table B–2. Potentially Applicable Missouri State Requirements........................................... B-7

16 Table B–3. City of Columbia and Boone County, Missouri, Ordinances and Plans............... B-8

17 Table B–4. Permits and Approvals Required for Construction and Operations..................... B-9

18 Table C–1. Environmental Review Correspondence............................................................. C-1

19 Table D–1. Section 7 Consultation Correspondence ............................................................ D-2

20 Table D–2. NHPA Correspondence...................................................................................... D-3

Executive Summary

xix

1 EXECUTIVE SUMMARY

2 BACKGROUND

3 By letter dated November 7, 2014, Northwest Medical Isotopes, LLC (NWMI) submitted Part 1 

4 of a two-part application to the U.S. Nuclear Regulatory Commission (NRC) for a construction 

5 permit under Title 10 of the Code of Federal Regulations (10 CFR) Part 50 that would allow 

6 construction of the NWMI medical radioisotope production facility (NWMI facility) in Columbia, 

7 Missouri. By letter dated February 5, 2015, NWMI withdrew and resubmitted this portion of its 

8 construction permit application to include a discussion of connected actions in their 

9 environmental report (ER) in response to a letter from the NRC (NWMI 2015a, 2015b). To issue 

10 a permit, the NRC is required to consider the environmental impacts of the proposed action 

11 under the National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq., herein referred to 

12 as NEPA). The NRC’s environmental protection regulations that implement NEPA in Title 10 of 

13 the Code of Federal Regulations (10 CFR) Part 51 describe several types of actions that would 

14 require an environmental impact statement (EIS). The regulation at 10 CFR 51.20 does not 

15 specifically identify construction permits and operating licenses for production and utilization 

16 facilities as an action that would require an EIS. However, for the NWMI environmental review, 

17 the NRC staff determined that an EIS was appropriate to assess the environmental impacts of 

18 the proposed action.

19 Upon acceptance of Part 1 of NWMI’s application, the NRC staff began the environmental 

20 review process described in 10 CFR Part 51 by publishing a Notice of Intent in the Federal 

21 Register (80 FR 72115) to prepare an EIS and to conduct scoping activities. In preparation of

22 this EIS, the NRC staff performed the following:

23 • conducted a public scoping meeting on December 8, 2015, in Columbia, Missouri;

24 • conducted a site audit at the proposed NWMI site and an alternative site in

25 September 2015;

26 • reviewed NWMI’s ER;

27 • consulted with Federal, State, and local agencies, as well as Tribal officials;

28 • conducted a review of the guidance in Final Interim Staff Guidance Augmenting

29 NUREG-1537, Part 1, “Guidelines for Preparing and Reviewing Applications for the

30 Licensing of Non-Power Reactors: Format and Content,” for Licensing Radioisotope

31 Production Facilities and Aqueous Homogeneous Reactors; and Part 2, “Guidelines

32 for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors:

33 Standard Review Plan and Acceptance Criteria”; and

34 • considered public comments received during the EIS scoping process.

35 PROPOSED ACTION

36 The proposed Federal action is for the NRC to decide whether to issue a construction permit 

37 under 10 CFR Part 50 that would allow construction of the NWMI medical radioisotope

38 production facility. If the NRC were to issue a construction permit, NWMI could build the 

39 proposed facility at the 7.4-acre (3-hectare) Discovery Ridge site, in Boone County, Columbia, 

40 Missouri. The NWMI process would involve fabricating low-enriched uranium (LEU) targets, 

41 shipping targets to university research reactors, irradiating LEU targets at university research 

42 reactors, returning targets to NWMI, LEU target dissolution, and molybdenum-99 (Mo-99) 

43 recovery and purification.
Executive Summary

xx 

1 The issuance of a construction permit is a separate licensing action from the issuance of an 

2 operating license. Before NWMI can operate the proposed production facility, NWMI must 

3 (1) submit an application for an operating license and a license to receive and possess special 

4 nuclear material for its processes, pursuant to the NRC requirements, (2) must substantially 

5 complete construction in accordance with an NRC-issued construction permit, and (3) obtain an 

6 NRC operating license. If NWMI were to submit an application for an operating license, the 

7 NRC staff would prepare a supplement to this EIS in accordance with 10 CFR 51.95(b).

8 PURPOSE AND NEED FOR ACTION

9 The purpose and need of this proposed Federal action is to provide a medical radioisotope

10 production option that could help meet the need for a domestic source of Mo-99. The 

11 determination of need and the decision to produce radioisotopes are at the discretion of 

12 applicants or other medical radioisotope production decisionmakers. This definition of purpose 

13 and need reflects the NRC’s recognition that, unless there are findings in the safety review 

14 required by the Atomic Energy Act of 1954, as amended, or findings in the environmental 

15 analysis under NEPA that would lead the NRC to reject a construction permit application, the 

16 agency does not have a role in the planning decisions as to whether a particular radioisotope 

17 production facility should be constructed and operated.

18 ENVIRONMENTAL IMPACTS OF CONSTRUCTION, OPERATIONS, AND 

19 DECOMMISSIONING

20 This EIS evaluates the potential environmental impacts of the proposed action. The 

21 environmental impacts from the proposed action are designated as SMALL, MODERATE, or 

22 LARGE. The following definitions of these three significance levels, as presented in the final 

23 interim staff guidance to NUREG–1537, apply: 

24 SMALL: Environmental effects are not detectable or are so minor that they would 

25 neither destabilize nor noticeably alter any important attribute of the resource. In 

26 assessing radiological impacts, the NRC has concluded that those impacts that do not 

27 exceed permissible levels in the agency’s regulations are considered SMALL. 

28 MODERATE: Environmental effects are sufficient to alter noticeably, but not to 

29 destabilize, important attributes of the resource.

30 LARGE: Environmental effects are clearly noticeable and are sufficient to destabilize 

31 important attributes of the resource.

32 Table ES–1 summarizes the NRC staff’s findings on the level of impacts on environmental 

33 resources from the construction, operations, and decommissioning of the NWMI facility. 
Executive Summary

xxi

1 Table ES–1. Summary of NRC Conclusions on the Environmental Impacts of 

2 Construction, Operations, and Decommissioning of the Proposed NWMI Facility

Resource Area Impacts

Land Use and Visual Resources SMALL

Air Quality and Noise SMALL

Geologic Environment SMALL

Water Resources SMALL

Ecological Resources SMALL(a)

Historic and Cultural Resources No historic properties affected

Socioeconomic Impacts SMALL

Human Health SMALL

Waste Management SMALL

Transportation SMALL

Accidents SMALL

Environmental Justice See note below(b)

Cumulative Impacts (Including Regional Growth and Climate Change)

Land Use and Visual Resources SMALL

Air Quality and Noise SMALL to MODERATE

Geologic Environment SMALL

Water Resources SMALL

Ecological Resources MODERATE

Historic and Cultural Resources No historic properties affected

Socioeconomics Impacts SMALL

Human Health SMALL

Waste Management SMALL

Transportation SMALL

Environmental Justice See note below(b)

(a) The NRC determined that the proposed action would result in no effect to species and habitats protected under 

the Endangered Species Act of 1973, as amended or to essential fish habitat designated under the Magnuson–

Stevens Fishery Conservation and Management Act, as amended. 

(b) There would be no disproportionately high and adverse impacts to minority and low-income populations and 

subsistence consumption from the proposed action and from cumulative impacts.

3 ALTERNATIVES

4 The NRC staff considered the environmental impacts associated with the following alternatives

5 to constructing the NWMI facility at the Discovery Ridge site:

6 • the no-action alternative;

7 • construction, operations, and decommissioning of the NWMI facility at the University

8 of Missouri Research Reactor site (alternative site);
Executive Summary

xxii

1 • construction, operations, and decommissioning of a linear accelerator-based facility 

2 at the Discovery Ridge site (Alternative technology No.1); and

3 • construction, operations, and decommissioning of a subcritical fission-based facility

4 at the Discovery Ridge site (Alternative technology No.2).

5 The NRC staff evaluated each alternative using the same resource areas that were used in 

6 evaluating impacts from the proposed action. The NRC staff determined that the no-action 

7 alternative would result in SMALL impacts to all resource areas. However, the no-action 

8 alternative does not fulfill the purpose and need of the project. The environmentally preferred 

9 alternatives are the construction, operations, and decommissioning of the NWMI facility at the 

10 Discovery Ridge site (proposed action), the linear accelerator-based facility at the Discovery 

11 Ridge site (Alternative Technology No. 1), and the subcritical fission-based facility at the 

12 Discovery Ridge site (Alternative Technology No. 2). The direct and indirect impacts associated 

13 with the proposed action and the two alternative technologies would be SMALL for all resource 

14 areas. The NRC staff determined that the construction, operations, and decommissioning of 

15 building the NWMI facility at the alternative site would likely result in greater impacts than the 

16 proposed action. 

17 PRELIMINARY RECOMMENDATION

18 After weighing the environmental, economic, technical, and other benefits against environmental 

19 and other costs, and considering reasonable alternatives, the NRC staff’s preliminary 

20 recommendation, unless safety issues mandate otherwise, is the issuance of a construction 

21 permit to NWMI. The NRC staff based its preliminary recommendation on the following factors: 

22 • NWMI’s ER;

23 • the NRC staff’s consultation with Federal, State, and local agencies, as well as Tribal

24 officials;

25 • the NRC staff’s independent environmental review; and

26 • the NRC staff’s consideration of public comments received during the scoping

27 process.
xxiii

1 ABBREVIATIONS AND ACRONYMS

2 C degree(s) Celsius

3 F degree(s) Fahrenheit

4 ac acre(s)

5 ACHP Advisory Council on Historic Preservation

6 ADAMS Agencywide Documents Access and Management System

7 AIHA American Industrial Hygiene Association 

8 ALOHA Areal Locations of Hazardous Atmospheres 

9 AEGL Acute Exposure Guideline Level

10 ALARA as low as is reasonably achievable

11 APE area of potential effect

12 AQCR air quality control region

13 bgs below ground surface

14 BIA U.S. Bureau of Indian Affairs

15 BLS U.S. Bureau of Labor Statistics

16 BMP best management practice

17 B.P. before present

18 CAA Clean Air Act

19 Ci curie

20 CEQ Council on Environmental Quality

21 CFR Code of Federal Regulations

22 cfs cubic feet per second

23 CH4 methane

24 cm centimeter

25 CO carbon monoxide

26 CO2 carbon dioxide

27 CO2eq carbon dioxide equivalent

28 CRMP cultural resource management plan

29 CWA Clean Water Act

30 dB decibel(s)

31 dBA decibels on the A-weighted scale

32 DBA design-basis accident

33 DOE U.S. Department of Energy

34 DOL U.S. Department of Labor
Abbreviations and Acronyms

xxiv

1 DOT U.S. Department of Transportation

2 EA environmental assessment

3 ECHO Enforcement and Compliance History Online 

4 EIA Energy Information Administration

5 EIS environmental impact statement

6 EO Executive Order

7 EPA U.S. Environmental Protection Agency

8 ER Environmental Report

9 ERPG Emergency Response Planning Guideline

10 ESA Endangered Species Act

11 FEMA U.S. Federal Emergency Management Agency

12 FHWA U.S. Federal Highway Administration

13 FR Federal Register

14 ft foot (feet)

ft2 15 square foot (feet)

16 FWS U.S. Fish and Wildlife Service

17 gal gallon(s)

18 GHG greenhouse gas

19 gpd gallons per day

20 gpm gallons per minute

21 GTCC greater than Class C

22 GWP global warming potential

23 ha hectare(s)

24 HAP hazardous air pollutant

25 HEPA high-efficiency particulate air

26 HEU highly enriched uranium

27 HNO3 Nitric Acid

28 hp horsepower

29 hr hour(s)

30 IAEA International Atomic Energy Agency

31 in. inch

32 kg kilogram(s)

33 km kilometer(s)

34 kph kilometer(s) per hour

km2 35 square kilometer(s)
Abbreviations and Acronyms

xxv 

1 L liter(s)

2 LDN day-night sound intensity level

3 LEU low enriched uranium

4 Lpd liter(s) per day

5 m meter(s)

m2 6 square meter(s)

m3 7 cubic meter(s)

m3 8 /day cubic meter(s) per day

m3 9 /min cubic meter(s) per minute

mi3 10 /s cubic mile(s) per second

11 mg/L milligram(s) per liter

12 mg/m3 milligram(s) per cubic meter

13 mgd million gallon(s) per day

14 m/s meter(s) per second

15 MAR material at risk

16 MBTA Migratory Bird Treaty Act

17 mgd million gallons per day

18 MHA maximum hypothetical accident

19 mi mile

20 min minute

21 mph mile(s) per hour

mi2 22 square mile(s)

23 μg microgram

24 μm microns

25 μg/m3 microgram per cubic meter

26 MDNR Missouri Department of Natural Resources

27 MMI Modified Mercalli Intensity

28 MOI maximum offsite individual

29 mrem milliroentgen equivalent man

30 MSL mean sea level

31 mSv millisievert

32 MT metric ton(s)

33 MU University of Missouri

34 MURR University of Missouri Research Reactor

35 NAAQS National Ambient Air Quality Standards
Abbreviations and Acronyms

xxvi

1 NaOH Sodium Hydroxide

2 NCDC National Climatic Data Center

3 NCES National Center for Education Statistics

4 NEA Nuclear Energy Agency

5 NEPA National Environmental Policy Act

6 NHPA National Historic Preservation Act

7 NNSA National Nuclear Security Administration

8 NO2 nitrogen dioxide

9 NOx nitrogen oxide

10 NOAA National Oceanic and Atmospheric Administration

11 NPDES National Pollutant Discharge Elimination System

12 NPS U.S. National Park Service

13 NRC U.S. Nuclear Regulatory Commission

14 NRCS Natural Resources Conservation Service

15 NRHP National Register of Historic Places

16 NUREG NRC technical report designation (Nuclear Regulatory 

17 Commission)

18 NWMI Northwest Medical Isotopes, LLC

19 OSHA Occupational Safety and Health Administration

20 OSTR Oregon State TRIGA Reactor

21 PAC protective action criterion/criteria

22 Pb Lead

23 PGA peak ground acceleration

24 PM particulate matter

25 ppb parts per billion

26 ppm parts per million

27 PSAR preliminary safety analysis report

28 PSD prevention of significant deterioration

29 RCA radiation-controlled area

30 RCRA Resource Conservation and Recovery Act

31 ROI region of influence

32 RM river mile

33 RPF radioisotope production facility

34 SER safety evaluation report

35 SHPO State Historic Preservation Office
Abbreviations and Acronyms

xxvii 

1 SIL significant impact level

2 SNM Society of Nuclear Medicine and Molecular Imaging

3 SO2 sulfur dioxide

4 SPCC Spill Prevention, Control, and Countermeasure

5 SSC species of special concern

6 TDS total dissolved solids

7 TEDE total effective dose equivalent

8 TEEL Temporary Emergency Exposure Limit

9 TIF Tax Increment Finance

10 TMDL total maximum daily load

11 TNM traffic noise model

12 TPY tons per year

13 TSV target solution vessel

14 μg microgram(s)

15 μm micron(s)

16 U.S. United States

17 U.S.C. United States Code

18 USCB U.S. Census Bureau

19 USDA U.S. Department of Agriculture

20 USDOI U.S. Department of Interior

21 USGCRP U.S. Global Change Research Program

22 USGS U.S. Geological Service

23 VOC volatile organic compound(s)

24 WWTP Wastewater Treatment Plant

yd3 25 cubic yard(s)

26 Y-12 Y-12 National Security Complex

1-1 

1 1.0 INTRODUCTION

2 By letter dated November 7, 2014, Northwest Medical Isotopes, LLC (NWMI) submitted Part 1 

3 of a two-part application to the U.S. Nuclear Regulatory Commission (NRC) for a construction 

4 permit under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, “Domestic

5 Licensing of Production and Utilization Facilities,” that would allow construction of the NWMI 

6 medical radioisotope production facility (NWMI facility) in Columbia, Missouri. The NWMI facility 

7 is a production facility as defined in 10 CFR 50.2. By letter dated February 5, 2015, NWMI 

8 withdrew and resubmitted Part 1 of its construction permit application to include a discussion of 

9 connected actions in its Environmental Report in response to a letter from the NRC 

10 (NWMI 2015a, 2015b). The Atomic Energy Act of 1954 (42 U.S.C. 2011 et seq.) authorizes the 

11 NRC to issue construction permits and operating licenses for production and utilization facilities. 

12 To issue a construction permit, the NRC is required to consider the environmental impacts of 

13 the proposed action under the National Environmental Policy Act of 1969 (NEPA) 

14 (42 U.S.C. 4321 et seq.). The NRC’s environmental protection regulations that implement 

15 NEPA in 10 CFR Part 51 describe several types of actions that would require an environmental 

16 impact statement (EIS). Construction permits and operating licenses for a medical isotope 

17 production facility are not specifically identified in 10 CFR 51.20 as an action that would require 

18 an EIS. Such activities may require an environmental assessment (EA) or an EIS, depending 

19 on their potential for significant impacts that may affect the quality of the human environment 

20 (NRC 2012).

21 An EA is used to determine whether the impacts from the proposed action may be significant 

22 and whether a finding of no significant impact can be made. If, based on the EA, the NRC 

23 concludes that the proposed action could result in significant impacts to the human 

24 environment, the agency would prepare an EIS. In some cases, the NRC may decide to 

25 prepare an EIS without first preparing an EA if there is the potential for significant impacts to the 

26 human environment or the proposed action involves a matter that the Commission, in the 

27 exercise of its discretion, has determined should be covered by an EIS. For the NWMI 

28 environmental review, the NRC staff determined that pursuant to 10 CFR 51.20(a)(2), the 

29 proposed action should be covered by an EIS as a matter of discretion. The NRC staff made 

30 this determination because (1) of the potential that an EA might not support a finding of no 

31 significant impact and (2) operation of the proposed NWMI facility, a connected action to the 

32 issuance of a construction permit, will include target fabrication and scrap recovery, processes 

33 similar to the processes that fuel fabrication facilities use and 10 CFR 51.20(b)(7) requires an 

34 EIS for a license that authorizes possession and use of special nuclear material (SNM) for 

35 processing and fuel fabrication and for scrap recovery.

36 1.1 Background

37 Nuclear medicine practitioners frequently use a variety of radioisotopes to diagnose and treat 

38 illnesses in patients. Molybdenum-99 (Mo-99) is the radioisotope currently in highest demand 

39 (NRC 2012) for medical use. Mo-99 decays with a 66-hour half-life to technetium-99m, which in 

40 turn decays with a 6-hour half-life to technetium-99. Technetium-99m is the most commonly 

41 used medical radioisotope in the world. It is used in about 20 to 25 million medical diagnostic 

42 procedures annually, or about 80 percent of all diagnostic nuclear medicine procedures 

43 (IAEA 2013a). Uses for technetium-99m include the following (National Research 

44 Council 2009):

45 • bone scans,

46 • lung perfusion imaging,
Introduction

1-2 

1 • kidney scans and functional imaging,

2 • liver scans,

3 • cardiac perfusion imaging,

4 • brain perfusion imaging,

5 • gall bladder function imaging,

6 • blood pool imaging, and

7 • thyroid and salivary gland imaging.

8 Mo-99 is commonly produced through the neutron activation of naturally occurring molybdenum 

9 or as a by-product of uranium-235 fission. No U.S. domestic producers of Mo-99 exist. A

10 majority of the U.S. supply of Mo-99 is produced at the High Flux Reactor in Petten, 

11 Netherlands. The only other international producers are located in South Africa, Australia, 

12 Belgium, Poland, Czech Republic, and France. Serious domestic and international shortages 

13 over the last decade resulted from planned and unplanned maintenance shutdowns at these 

14 facilities (National Research Council 2009). In addition to issues of production reliability, global 

15 demand for the radioisotope is increasing, proliferation of highly enriched uranium, and 

16 transporting the radioisotope across international borders is becoming more difficult (National 

17 Research Council 2009).

18 1.2 Proposed Federal Action

19 The proposed Federal action is for the NRC to decide whether to issue a construction permit 

20 under 10 CFR Part 50 that would allow construction of the NWMI facility, a medical radioisotope

21 production facility (Chapter 2 provides a description of the facility and isotope production 

22 process). If the NRC were to issue a construction permit, NWMI could build the proposed 

23 facility on a 3.0-hectare (ha) (7.4-acre (ac)) site, Lot 15 of the Discovery Ridge Research Park, 

24 in Boone County, Columbia, Missouri. The issuance of a construction permit is a separate 

25 licensing action from the issuance of an operating license. Before NWMI can operate the 

26 proposed production facility, NWMI must (1) submit an application for an operating license and 

27 a license to receive and possess special nuclear material for its processes, pursuant to the NRC 

28 requirements, (2) substantially complete construction in accordance with an NRC issued 

29 construction permit, and (3) obtain an NRC operating license. If NWMI were to submit an 

30 application for an operating license, the NRC staff would prepare a supplement to this EIS in 

31 accordance with 10 CFR 51.95(b).
Introduction

1-3 

1 1.3 Purpose and Need for the Proposed Federal Action

2 The purpose of and need for this proposed Federal 

3 action is to provide a medical radioisotope production 

4 option that could help meet the need for a domestic 

5 source of Mo-99. For the past 2 decades, the 

6 United States has relied on imported medical 

7 radioisotopes, such as Mo-99, iodine-131, and 

8 xenon-133. Mo-99, for example, is used to perform 

9 about 50,000 medical procedures daily in the United 

10 States. Global shortages of medical radioisotopes in 

11 the last decade have highlighted the need for prompt 

12 action to ensure a reliable domestic supply. Demand in 

13 the United States for Mo-99 is approximately 5,000 

6-day curies (Ci) (2x1014 14 6-day becquerels (Bq)) per 

15 week. This demand is expected to increase about 0.5 percent per year (OECD 2014). In recent 

16 years, U.S. policy as established by the American Medical Isotopes Production Act

17 (42 U.S.C. 2065 et seq.) is to ensure a reliable supply of medical radioisotopes while minimizing 

18 the use of highly enriched uranium for civilian purposes through, among other things, supporting 

19 commercial projects that produce medical radioisotopes domestically without the use of highly 

20 enriched uranium (AMIPA 2012; NNSA 2011; White House 2012).

21 The proposed action for the NRC is to decide whether to issue a construction permit, which 

22 would allow NWMI to construct a facility that uses low-enriched uranium to produce Mo-99. 

23 NWMI could not operate its facility until it applies for and is issued an operating license. The 

24 NRC would review that application and separately decide whether to issue an operating license. 

If the facility is licensed to operate, NWMI expects to produce up to 2,500 6-day Ci (9.3x1013 25

26 6-day Bq) of Mo-99 per week (NWMI 2015a, 2015c).

27 1.4 U.S. Nuclear Regulatory Commission Environmental Review

28 The NRC’s process to review applications for construction permits consists of two separate, 

29 parallel reviews. The safety review evaluates the applicant’s ability to meet the NRC regulatory 

30 safety requirements. The NRC staff documents the findings of the safety review in a Safety 

31 Evaluation Report. The environmental review, governed by the requirements in 

32 10 CFR Part 51, evaluates the environmental impacts of, and alternatives to, the proposed 

33 action. This draft EIS presents the results of this evaluation. The NRC considers the findings in 

34 both the EIS and the Safety Evaluation Report in its decision to grant or deny the issuance of a 

35 construction permit.

36 To guide its assessment of the environmental impacts of the proposed action or alternative 

37 actions, the NRC established a standard of significance for impacts using the Council on 

38 Environmental Quality (CEQ) terminology for “significantly” (40 CFR 1508.27). Because the 

39 significance and severity of an impact can vary with the setting of the proposed action, both 

40 “context” and “intensity,” as defined in CEQ regulation 40 CFR 1508.27, were considered (see 

41 text box). Based on this, the NRC established three levels of significance for potential impacts: 

42 SMALL, MODERATE, and LARGE, as defined below.

43 SMALL: Environmental effects are not detectable or are so minor that they will neither 

44 destabilize nor noticeably alter any important attribute of the resource. 

45 MODERATE: Environmental effects are sufficient to alter noticeably, but not to destabilize, 

46 important attributes of the resource.

A curie (Ci) is a unit of measurement 

describing the radioactive 

disintegration rate of a substance; 

1 Ci is 3.700x1010 disintegrations 

per second (Institute of Medicine 

(IOM) 1995).

The term “6-day Ci” comes from 

producers to determine the number 

of curies present in a shipment 

6 days after it leaves the production 

facility (National Research 

Council 2009).
Introduction

1-4

1 LARGE: Environmental effects are clearly 

2 noticeable and are sufficient to destabilize 

3 important attributes of the resource.

4 On November 7, 2014, NWMI submitted its ER

5 with Part 1 of its application for a construction 

6 permit. By letter dated February 5, 2015, NWMI 

7 withdrew and resubmitted Part 1 of its

8 construction permit application to include a 

9 discussion of connected actions in its ER in 

10 response to a letter from the NRC (NRC 2015a; 

11 NWMI 2015b). After reviewing Part 1 of the 

12 application for sufficiency, on June 8, 2015, the NRC staff published a Notice of Acceptance for 

13 Docketing in the Federal Register (80 FR 32418). On November 18, 2015, the NRC staff 

14 published a Federal Register notice (80 FR 72115) of its intent to prepare an EIS and conduct a 

15 scoping process. This notice began the 45-day scoping period. On December 8, 2015, the 

16 NRC held a public scoping meeting in Columbia, Missouri. The NRC’s report entitled,

17 “Summary of the Public Scoping Meeting Conducted Related to the Review of the Proposed 

18 Northwest Medical Isotopes, LLC Radioisotope Production Facility,” presents the comments 

19 received during the scoping process (NRC 2016a). In September 2015, the NRC staff 

20 conducted a site audit at the proposed and alternative NWMI facility sites to verify information in 

21 NWMI’s Environmental Report. During the site audit, the NRC staff met with NWMI personnel; 

22 reviewed specific documentation; and toured the proposed site, the alternative site, and the 

23 University of Missouri Research Reactor, one of the reactors where NWMI plans to have its 

24 targets irradiated (NRC 2015b).

25 Figure 1–1 shows the major milestones in the public review of an EIS. After the site audit and 

26 the scoping period, the NRC staff compiles its findings in a draft EIS. The draft EIS is available 

27 for public comment for 45 days. During this time, the NRC staff hosts a public meeting and 

28 collects public comments. Based on the information gathered, the NRC staff will amend the 

29 draft EIS as necessary and then publish a final EIS.

Significance indicates the importance of likely 

environmental impacts and is determined by 

considering two variables: context and 

intensity.

Context is the geographic, biophysical, and 

social context in which the effects will occur.

Intensity refers to the severity of the impact, in 

whatever context it occurs.
Introduction

1-5 

1 Figure 1–1. Environmental Review Process

2 

NRC staff 

reviews 

application

Staff conducts 

site 

environmental

audit

NRC issues 

draft EIS

Application 

submitted to NRC

*Scoping

process

*Draft EIS

process

NRC issues 

final EIS

NRC makes decision on 

whether to issue a 

construction permit or 

license

*Opportunities

for public

involvement
Introduction

1-6

1 1.5 Scope of the EIS

2 As described in Section 1.2 of the EIS, the 

3 proposed Federal action is for the NRC to decide 

4 whether to issue a construction permit under 

5 10 CFR Part 50 that would allow construction of 

6 the NWMI facility. CEQ regulations 

7 implementing NEPA state that the NEPA 

8 analysis should also include connected actions 

9 (40 CFR 1508.25). In determining the scope of 

10 its environmental review for the proposed action, 

11 the NRC staff, consistent with 10 CFR 51.14(b), 

12 will discuss connected actions to the proposed 

13 action (see how actions are connected in text 

14 box) in implementing Section 102(2) of NEPA.

15 The NRC staff has determined that it is appropriate to evaluate the potential impacts from 

16 operations and decommissioning given that such activities are connected to construction and 

17 cannot proceed unless other actions (e.g., issuance of a construction permit) are taken 

18 previously. In order to operate and produce radioisotopes in the proposed NWMI facility, NWMI 

19 proposes to fabricate low-enriched uranium

20 (LEU) targets under 10 CFR Part 70, “Domestic 

21 Licensing of Special Nuclear Material.” This EIS 

22 will also evaluate the potential environmental 

23 impacts from operation of the proposed NWMI 

24 facility that will consist of both the 

25 10 CFR Parts 50 and 70 activities. Operation of 

26 NWMI’s proposed facility will depend on LEU 

27 targets being transferred to and from, and irradiated in, one or more research reactors that are 

28 authorized, by an operating license amendment, to irradiate the NWMI LEU targets. The NRC 

29 staff will conduct a separate safety review and environmental review of each operating license 

30 amendment application submitted by these research reactors. However, because Mo-99

31 production cannot occur until research reactors are licensed to irradiate NWMI’s LEU targets 

32 and the environmental impacts from LEU target irradiation at research reactors has not been 

33 previously assessed, the NRC staff concluded that LEU irradiation at research reactors is an 

34 interdependent part of the proposed NWMI facility operation. The NRC staff also determined 

35 that transportation of LEU targets and irradiation of LEU targets at research reactors are actions 

36 connected to operation of the proposed NWMI facility. Therefore, the NRC will assess the 

37 environmental impacts associated with transporting and irradiating LEU targets at the identified 

38 research reactors in this EIS.

39 1.6 Preconstruction Activities

40 In a final rule dated October 9, 2007 (72 FR 57416), the Commission limited the definition of

41 “construction” to those activities that fall within its regulatory authority in 10 CFR 51.4. Many of

42 the activities required to build a radioisotope production facility are not part of the NRC action to 

43 license the proposed NWMI facility because they do not have a reasonable nexus to radiological

44 health and safety and/or common defense and security; therefore, they are not within the NRC’s

45 authority to regulate. Activities associated with building the proposed NWMI facility that are not 

46 within the purview of the NRC action are grouped under the term “preconstruction.”

47 Preconstruction activities include clearing and grading, excavating, building of service facilities 

Scope of the EIS

• Construction, operations, and 

decommissioning of the proposed NWMI 

facility.

• Transportation and irradiation of LEU 

targets at research reactors.

Actions are connected if they:

• Automatically trigger other actions that

may require environmental impact 

statements.

• Cannot or will not proceed unless other 

actions are taken previously or 

simultaneously.

• Are interdependent parts of a larger action 

and depend on the larger action for their 

justification.
Introduction

1-7 

1 (e.g., paved roads, parking lots), erection of support buildings, and other associated activities. 

2 These preconstruction activities may take place before the application for a construction permit

3 is submitted, during the staff’s review of a construction permit application, or after a construction 

4 permit is granted. Consequently, the NRC evaluates preconstruction impacts as cumulative 

5 impacts and not as direct impacts resulting from the NRC’s Federal action. Although 

6 preconstruction activities are outside the NRC’s regulatory authority, many are within the 

7 regulatory authority of local, State, or other Federal agencies.

8 Preconstruction activities could occur whether or not the construction permit is granted. 

9 However, because preconstruction is related to the building of the proposed NWMI facility, 

10 Chapter 4 of the EIS presents a single combined impact level to increase the readability of the 

11 document. When the combined preconstruction and NRC-authorized construction activity 

12 impact category level is SMALL for any resource area (e.g., land use, water resources), no 

13 further breakdown of impacts between preconstruction and NRC-authorized construction will be 

14 provided. When the combined preconstruction and NRC-authorized construction activity impact 

15 category level is greater than SMALL for any resource area, the impact from solely 

16 NRC-authorized construction activities will be discussed separately. This is consistent with 

17 NRC Staff Guidance (NRC 2011, 2013a) and the NRC’s analysis of similar licensing actions. 

18 See Environmental Impact Statement for the Construction Permit for the SHINE Medical 

19 Radioisotope Production Facility EIS (NRC 2015c, 2015d). Section 4.14, “Cumulative Impacts,”

20 of the EIS incorporates the impacts from “preconstruction” to satisfy NRC’s regulatory 

21 requirements in 10 CFR 51.71(d). In addition, throughout the EIS, construction refers to

22 preconstruction activities and NRC-authorized construction.

23 1.7 Consultation and Correspondence

24 The Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.), and the National 

25 Historic Preservation Act of 1966 (54 U.S.C. 300101 et seq.) require Federal agencies to 

26 consult with applicable State and Federal agencies and groups before taking actions that may 

27 affect endangered species, fisheries, and historic and archaeological resources. The NRC staff 

28 contacted Federal, State, regional, local, and Tribal agencies with environmental expertise in 

29 the areas that the proposed project could potentially affect. Agencies contacted during the 

30 formal consultation processes and the NWMI environmental review process included the 

31 following:

32 • Advisory Council on Historic Preservation,

33 • Boone County Government Center,

34 • Mid-Missouri Regional Planning Commission,

35 • Absentee-Shawnee Tribe of Indians of Oklahoma,

36 • Caddo Nation of Oklahoma,

37 • Cherokee Nation,

38 • Cheyenne and Arapaho Tribes,

39 • The Chickasaw Nation,

40 • The Choctaw Nation of Oklahoma,

41 • Citizen Potawatomi Nation,

42 • Delaware Nation,
Introduction

1-8 

1 • Eastern Shawnee Tribe of Oklahoma,

2 • Iowa Tribe of Kansas and Nebraska,

3 • Iowa Tribe of Oklahoma,

4 • Miami Tribe of Oklahoma,

5 • Missouri Department of Conservation,

6 • Missouri Department of Health and Senior Services,

7 • Missouri Department of Natural Resources,

8 • Missouri Department of Public Safety,

9 • Missouri Department of Transportation,

10 • The Muscogee (Creek) Nation,

11 • Omaha Tribe of Nebraska,

12 • The Osage Nation,

13 • Otoe-Missouria Tribe of Indians, Oklahoma,

14 • Pawnee Nation of Oklahoma,

15 • Peoria Tribe of Indians of Oklahoma,

16 • Ponca Tribe of Indians of Oklahoma,

17 • Ponca Tribe of Nebraska,

18 • Prairie Band Potawatomi Nation,

19 • The Quapaw Tribe of Indians,

20 • Sac and Fox Nation of Missouri in Kansas and Nebraska,

21 • Sac and Fox Nation, Oklahoma,

22 • Sac and Fox Tribe of the Mississippi in Iowa,

23 • Shawnee Tribe,

24 • United Keetoowah Band of Cherokee Indians of Oklahoma,

25 • Winnebago Tribe of Nebraska,

26 • Wyandotte Nation,

27 • Kaw Nation, Oklahoma,

28 • Yankton Sioux Tribe of South Dakota,

29 • U.S. Fish and Wildlife Service, and

30 • U.S. Department of Energy.

31 Chapter 9 provides a list of those who received a copy of this EIS. Appendix C contains a 

32 chronological list of all correspondence sent and received during the environmental review. 
Introduction

1-9 

1 1.8 Status of Compliance

2 NWMI is responsible for complying with applicable NRC regulations and other Federal, State, 

3 and local requirements. Appendix B to this EIS includes a list of the permits and licenses that 

4 Federal, State, and local authorities must issue to NWMI before construction or operation of the 

5 proposed facility.

2-1 

1 2.0 PROPOSED FEDERAL ACTION

2 2.1 Site Location and Layout

3 Northwest Medical Isotopes, LLC (NWMI) would construct and operate the proposed NWMI 

4 medical radioisotope production facility (NWMI facility) in Columbia, Missouri, within the 

5 University of Missouri Discovery Ridge Research Park. Discovery Ridge Research Park has 

6 been established as a research, development, and office park pursuant to Section 172.273 of 

7 Chapter 172 of the Missouri Revised Statutes. The proposed Discovery Ridge site, Lot 15 of 

8 the Discovery Ridge Research Park, encompasses 3.0 hectares (ha) (7.4 acres (ac)) of land 

9 (Figure 2–1) that is owned by the University of Missouri. The proposed Discovery Ridge site is 

10 bordered by U.S Highway 63 to the south, a mixture of cultivated crops and pasture to the north 

11 and east, and a research and laboratory facility to the northwest (Figure 2–1, Figure 2–2, and 

12 Figure 2–3) (NWMI 2015a). Access to the proposed Discovery Ridge site is from Discovery 

13 Drive and Discovery Parkway. The NWMI facility would comprise four main buildings 

14 (Figure 2–3):

15 Radioisotope Production Facility (RPF) Building,

16 Waste Management Building,

17 Diesel Generator Building, and

18 Administration Building.

These four main buildings would collectively cover approximately 71,150 square feet (ft2 19 ) 

(6,610 square meters (m2 20 )) (NWMI 2016b). The largest of the proposed buildings would be the 

21 RPF Building, which would extend 106.7 m (350 ft) in length and 56.4 m (185 ft) in width and 

22 would have an estimated height of 19.8 m (65 ft) above grade (NWMI 2015a). The tallest 

23 exhaust vent stack would be higher, extending 22.9 m (75 ft) above grade (NWMI 2015a).

24 Other features associated with the proposed NWMI facility include support structures, such as 

25 storage tanks and fuel tanks, and engineered features, such as parking lots, fences, a paved 

26 entrance road, and berms. The proposed NWMI facility would occupy a rectangular area that 

would result in a total estimated footprint of approximately 210,000 ft2 (19,383 m2 27 ).
Proposed Federal Action

2-2

1 Figure 2–1. Discovery Ridge Research Park and Proposed NWMI Site (Discovery Ridge)

2

3 Source: Modified from NWMI 2015a
Proposed Federal Action

2-3 

1 Figure 2–2. Proposed NWMI Site (Discovery Ridge) and Surrounding Area Within 5-mi 

2 (8-km) Radius

3 

4 Source: Modified from NWMI 2015a
Proposed Federal Action

2-4 

1 Figure 2–3. Proposed NWMI Facility Site Boundary and Site Layout

2 

3 Source: Modified from NWMI 2015a

4 2.2 Construction Activities

5 The construction period for the proposed NWMI facility would extend for 17 months and would 

6 require a peak construction workforce of 82 workers (NWMI 2015a, 2015c).

7 Construction activities would include earthmoving (clearing, grading) excavation, pile driving, 

8 facility build-out, installation of parking areas, and delivery of construction-related materials and 

9 components. Materials needed to construct the NWMI facility would include concrete, structural 

10 steel, miscellaneous steel, steel liner, asphalt, stone granular material, roofing materials, and 
Proposed Federal Action

2-5

1 precast concrete (NWMI 2015a). Table 2–1 presents the estimated amounts needed for each 

2 of these materials.

3 Table 2–1. Estimated Construction Materials Requirements

Material Amount

Concrete 4,260 yd3(3,257 m3) 

Structural Steel (400 t) (363 MT) 

Miscellaneous Steel 50 t (45 MT) 

Steel Liner 140 t (127 MT) 

Asphalt 320 yd3 (245 m3)

Stone Granular Material 1,700 yd3

Roofing 50,000 ft2 (4,645 m2)

Precast Concrete 480 t (435 MT) 

(a) yd3 = cubic yard(s), m3 = cubic meter(s), and MT = metric ton(s).

Source: NWMI 2015a

4 NWMI estimates that the proposed facility would require, on average, approximately 20 truck 

5 deliveries and 1 offsite waste shipment each month during construction (NWMI 2015a). Rather 

6 than operating an onsite batch plant, ready-mix concrete supplied by commercial vendors would 

7 be delivered to the site (NWMI 2015c). The maximum depth of excavation would be 7.0 m 

8 (23 ft) below grade to account for potential overexcavation (NWMI 2015a, 2015c). NWMI 

estimates that approximately 6,881 m3 (9,000 yd3 9 ) would be excavated (earthwork) to support 

10 construction activities and that construction equipment necessary to support these activities 

11 would consume 28,000 liters (L) (7,395 gallons (gal)) of diesel fuel (NWMI 2015a).

12 Overall, construction activities would disturb the entire 3.0 ha (7.4 ac) of the proposed Discovery 

13 Ridge site. Of this total, NWMI projects that approximately 2 ha (5 ac) will be permanently 

14 affected (i.e., occupied by buildings, paved areas, etc.) and the remaining will be revegetated or 

15 landscaped (NWMI 2015c). In addition, approximately 0.1 ha (0.26 ac) of a lot adjacent to the 

16 proposed Discovery Ridge site would be temporarily affected to support construction activities 

17 and will be revegetated once construction activities are completed (NWMI 2015c).

18 2.3 Facility Operations

19 If the NRC issues NWMI a construction permit and an operating license, the proposed NWMI 

20 facility would commence full operations upon completion of construction and preoperational 

21 startup activities. NWMI expects to request an operating license term of 30 years

22 (NWMI 2015a). During preoperation startup, the proposed NWMI facility would undergo a 

23 commissioning phase that would involve a series of test operations designed to ensure that the 

24 facility is functioning as designed (NWMI 2015a). Preoperation startup activities will be 

25 completed within 3 months (NWMI 2015a). The NWMI Environmental Report considered the 

26 impacts associated with the preoperational phase within the operating phase of the proposed 

27 NWMI facility. Similarly, for the purposes of this environmental analysis, the U.S. Nuclear 

28 Regulatory Commission (NRC) staff included the activities and impacts of preoperational 

29 activities as part of the operations phase in the impacts assessment in Chapter 4.
Proposed Federal Action

2-6 

1 During operations, NWMI plans to obtain low-enriched 

2 uranium (LEU) metal from the U.S. Department of 

3 Energy (DOE) Y-12 National Security Complex 

4 (Y-12 facility) in Oak Ridge, Tennessee (NWMI 2015a). 

5 The American Medical Isotopes Production Act of 2012 

6 (42 U.S.C. 2065(c)(3)(A)(ii)) states that DOE shall 

7 establish a program (uranium lease and take-back 

8 program) to make LEU available through lease 

9 contracts for irradiation for the production of 

10 molybdenum-99 (Mo-99) for medical uses. The lease 

11 contracts will also provide for the Mo-99 producer 

12 (e.g., NWMI) to return eligible leased LEU material to 

13 DOE (DOE 2016; NWMI 2016c, 2016d). In 

14 January 2016, the DOE’s National Nuclear Security 

15 Administration established the Uranium Lease and 

16 Take-Back Program (DOE 2016). For the purposes of this EIS, the NRC staff assumed that 

17 contracts and approvals necessary for NWMI to obtain LEU would be in place. LEU that NWMI 

18 determines is not economically viable for the Mo-99 production process will be returned to 

19 DOE’s Savannah River Site in Aiken, South Carolina, for storage in accordance with the take20 back contract. LEU obtained from DOE will be referred to as fresh LEU, and LEU returned to 

21 DOE will be referred to as take-back LEU throughout this EIS.

22 Operational activities would require 98 workers and a total of 486 inbound and outbound 

23 shipments annually. Table 2–2 shows the estimated annual inbound and outbound shipments

24 between NWMI and DOE, research reactors, radiopharmaceutical distributors, and waste sites. 

25 NRC regulations in 10 CFR Part 71 contain NRC requirements for packaging, preparation for 

26 shipment, and transportation of licensed radioactive material. Regulations at 10 CFR 71.5 

27 require licensees that transport licensed radioactive material outside the site of use (e.g., the 

28 proposed NWMI facility) to comply with applicable U.S. Department of Transportation (DOT)

29 regulations in 49 CFR Parts 107, 171 through 180, and 390 through 397, as appropriate. NWMI

30 stated it will transport radioactive material, radioactive waste, and medical isotopes in shipping 

31 containers that meet applicable NRC and DOT regulations to protect public health and safety 

32 (NWMI 2015a).

33 Table 2–2. Estimated Annual Shipments to and from the Proposed NWMI Facility

Type of Shipments Annual Shipments

Inbound Shipments (to NWMI facility)

Fresh LEU from DOE Y-12 facility(a) 2

Irradiated LEU targets from research reactors

 From University of Missouri Research Reactor (MURR) to NWMI facility(b) 104

 From Oregon State University TRIGA Reactor (OSTR) to NWMI facility(c) 16

 From Third Research Reactor to NWMI facility(d) 16

Outbound Shipments (from NWMI facility)

Medical radioisotope product(e) 104

Radioactive waste shipments to Waste Control Specialists(f) 200

LEU targets to research reactors

 From NWMI facility to MURR 26

Low-enriched uranium (LEU) means 

uranium enriched below 20 percent in 

the isotope uranium-235.

Highly enriched uranium (HEU) 

means uranium enriched to 

20 percent or greater in the isotope 

uranium-235.

The United States encourages the

use of LEU or other non-HEU-based 

technologies to produce medical 

radioisotopes because of the 

additional proliferation concerns 

associated with HEU (White 

House 2012).
Proposed Federal Action

2-7

Type of Shipments Annual Shipments

 From NWMI facility to OSTR 8

 From NWMI facility to Third Research Reactor 8

Take-back LEU to DOE Y-12 facility(g) 2

(a) Shipments from Oak Ridge, Tennessee, 950 km (590 mi) from the proposed NWMI facility.

(b) Shipments from Columbia, Missouri, 10 km (6.2 mi) from the proposed NWMI facility.

(c) Shipments from Corvallis, Oregon, 3,320 km (2063 mi) from the proposed NWMI facility.

(d) Shipments will travel up to 3,320 km (2,063 mi) to the proposed NWMI facility.

(e) Shipments to distributors in Hazelwood, Missouri, and Billerica, Massachusetts, 180 km (111 mi) and 2,080 km 

(1300 mi), respectively, from the proposed NWMI facility. Mo-99 product would be transported by air carrier to 

Boston Logan International Airport and to Billerica via commercial ground carrier. 

(f) Shipments to Andrews, Texas, 1,470 km (913 mi) from the proposed NWMI facility.

(g) Shipments will travel 950 km (590 mi) from the proposed NWMI facility.

Sources: NWMI 2015a, 2016a, 2016c

1 2.3.1 Radioisotope Production Process Overview

2 The NWMI process would involve fabricating LEU 

3 targets at the proposed NWMI facility, shipping 

4 unirradiated targets to university research reactors, 

5 irradiating LEU targets at university research reactors, 

6 returning irradiated targets to NWMI, LEU target 

7 dissolution, and Mo-99 recovery and purification. The 

8 proposed NWMI facility will have the capacity to fabricate and process up to 1,104 LEU targets

9 annually (NWMI 2015a, 2016b, 2016a). Figure 2–4 presents a flow diagram of the process. 

10 For descriptive purposes of the EIS, NWMI’s process can be divided into five primary stages:

11 LEU target fabrication;

12 LEU target irradiation;

13 irradiated target disassembly and dissolution; 

14 Mo-99 production (extraction, purification, and shipping); and

15 uranium recovery and recycle.

16 As illustrated in Figure 2–4, several sub-processes would occur within each of the five primary 

17 stages identified above. The following sections present an overview of the key factors 

18 associated with these processes. Most of the activities, other than LEU target irradiation, would 

19 take place within a single building, the RPF Building (NWMI 2015a, 2015d). As described in the 

20 following sections, target fabrication would be conducted using contact-handled equipment 

21 within the target fabrication area of the RPF building (Figure 2–5). Target disassembly and 

22 dissolution, Mo-99 extraction and purification, and uranium recovery would be handled remotely 

23 within the RPF hot cell (shielded nuclear radiation confinement chamber) area.

Target means material subjected to 

irradiation in an accelerator or nuclear 

reactor to induce a reaction or 

produce nuclear material 

(10 CFR 110.2).
Proposed Federal Action

2-8

1 Figure 2–4. NWMI Radioisotope Production Facility Process

2

3 Source: Modified from NWMI 2015a
Proposed Federal Action

2-9 

1 Figure 2–5. General Layout of the Proposed NWMI Radioisotope Production Facility 

2 Building

3 

4 Source: Modified from NWMI 2015d

5 2.3.1.1 LEU Target Fabrication

6 The first stage in the NWMI radioisotope production process is fabrication of the LEU target. 

7 LEU target fabrication would be conducted within the target fabrication area housed within the 

8 RPF building (see Figure 2–5). This area would contain the process equipment for preparation 

9 of targets, including concentrators, dissolvers, furnaces, and hardware. This equipment would 

10 be contact-handled by the operators (NWMI 2015a).

11 The target fabrication process would begin with the receipt of fresh LEU (special nuclear 

12 material) from DOE. Fresh LEU would be dissolved in nitric acid to form a uranyl nitrate product 

13 that is then evaporated to a desired uranium concentration. The uranyl nitrate product would 

14 then be chilled, mixed with reagents, and treated with heated silicone oil to form a solid LEU 
Proposed Federal Action

2-10

1 material (gelation broth). The LEU material would be filtered, washed, and reduced to obtain 

2 the LEU target material.

3 The LEU target material would then be encapsulated 

4 (loaded and welded), possibly with helium gas, in metal 

5 cladding to contain the LEU target material and to form 

6 the LEU targets. These LEU targets would then 

7 undergo inspection and quality assurance (QA) checks, 

8 be packaged and loaded into shielded shipping 

9 containers for transport to research reactors. 

10 Transportation from the proposed NWMI facility to each 

11 research reactor will be via ground transportation.

12 After the first batch of LEU targets are fabricated from 

13 fresh LEU, LEU targets will be fabricated using a 

14 combination of (1) fresh LEU, (2) recovered scrap LEU 

15 (scrap recovery), and (3) LEU recycled from the 

16 processing of irradiated targets (NWMI 2015e). LEU 

17 targets that fail inspection or QA checks, will be 

18 identified as off-specification uranium targets, and 

19 subsequently be disassembled and treated as scrap to recover the LEU target material 

20 (NWMI 2015e, 2016d). If an LEU target is identified as an off-specification uranium target 

21 because it does not meet target material parameter requirements (e.g., due to deformities), the 

22 target material will be dissolved in nitric acid within the Target Fabrication System (step 1 

23 identified in Figure 2–4), to then be used to fabricate targets. If an LEU target is identified as an 

24 off-specification uranium target because of the presence of chemical impurities in the target 

25 material, the material will go to the Uranium Recovery and Recycle system (Step 5 identified in 

26 Figure 2-4 and as discussed in Section 2.3.1.5 below) for recovery and then be used to 

27 fabricate targets (NWMI 2015e, 2016d).

28 2.3.1.2 LEU Target Irradiation

29 Following shipment to licensed research reactors, the LEU targets would undergo neutron 

30 irradiation in the reactor. This irradiation causes the uranium-235 in the LEU target to fission

31 and produce Mo-99 and other fission products. NWMI has identified two research reactors, the 

32 University of Missouri Research Reactor (MURR) and the Oregon State University TRIGA 

33 Reactor (OSTR), to provide irradiation services. NWMI is also considering use of a third 

34 research reactor and is performing an analysis to support that selection (NWMI 2015a, 2015c). 

35 Irradiating LEU targets at the research reactors is considered a connected action, and this EIS 

36 evaluates the environmental impacts associated with target irradiation at MURR, OSTR, and a 

37 potential third research reactor to bound this connected action (See Section 1.5 for a discussion 

38 on connected actions). The potential third research reactor parameters (e.g., distance from the 

39 proposed NWMI RPF and modifications anticipated to support LEU target irradiation) are based 

40 on the licensed operating research reactors being considered by NWMI (NWMI 2015a, 2015c).

41 Annual irradiation capacity at the research reactors is as follows (NWMI 2015a, 2016a, 2016b):

42 • MURR: 624 LEU targets,

43 • OSTR: 240 LEU targets, and

44 • Third Reactor: 240 LEU targets.

45 Research reactors that plan to irradiate NWMI LEU targets will require facility modifications and 

46 equipment refurbishment. Each research reactor that plans to irradiate the NWMI LEU targets 

10 CFR 70.4, “Definitions,” states:

Special nuclear material means 

plutonium, uranium 233, uranium 

enriched in the isotope 233 or in the 

isotope 235, and any other material 

which the Commission determines to 

be special nuclear material.

Special nuclear material scrap

means the various forms of special 

nuclear material generated during 

chemical and mechanical processing, 

other than recycle material and 

normal process intermediates, which 

are unsuitable for use in their present 

form, but all or part of which will be 

used after further processing.
Proposed Federal Action

2-11

1 will need to separately request an amended operating license from the NRC to allow target 

2 irradiation services. The NRC staff will conduct a separate safety review and environmental 

3 review for each license amendment request submitted to the NRC. Section 3.10 of this EIS 

4 discusses the affected environment of the research reactors and Section 4.13 identifies and 

5 discusses facility modifications and the potential impacts from irradiation of the LEU targets at 

6 the research reactors.

7 Following irradiation, the irradiated LEU targets would be loaded onto DOT shielded shipping 

8 containers and returned by ground transport to the proposed NWMI facility.

9 2.3.1.3 Irradiated Target Disassembly and Dissolution

10 The NWMI irradiated target receipt bay within the RPF building would be used to receive 

11 irradiated LEU targets (in shipping containers) from the ground transport trailers. The shipping 

12 containers would be transferred via a bridge crane onto a transfer cart. The transfer cart would 

13 then be transferred to the RPF hot cell area for target disassembly and dissolution (see

14 Figure 2–5). Irradiated target processing will occur in shielded hot cells. The hot cells would 

15 provide remote operation via shielded windows and through wall manipulators that would be 

16 remotely operated from outside the hot cell.

17 Within the target disassembly hot cells, irradiated LEU targets would be disassembled by 

18 puncturing and severing the target in half, and pouring the irradiated LEU material into a transfer 

19 container. The metal cladding would be disposed of as solid radioactive waste (see 

20 Section 2.7.1 for a discussion of radioactive waste that would be produced at the proposed 

21 NWMI facility). The transfer container holding the irradiated LEU material would then be 

22 transferred from the target disassembly hot cell to the target dissolution hot cell, where the 

23 irradiated LEU material would be dissolved in a nitric acid solution. This dissolver solution 

24 would then be diluted, cooled, filtered, and pumped to a tank. An offgas system would be used 

25 during this stage to capture fission product gases released from the target dissolution process.

26 2.3.1.4 Mo-99 Extraction, Purification, and Shipping

27 Extraction and purification of Mo-99 from the dissolver solution would occur within the hot cell

28 area and involve a series of three Mo-99 ion exchange columns. The dissolver solution would 

29 be pumped through the first ion exchanger to extract and separate the Mo-99 from the uranium

30 and other fission products. The Mo-99 and several other isotopes would be absorbed onto the 

31 ion exchange column media. The uranium and fission product solution that flows through the 

32 column would then be sent to the uranium recovery and recycle system (see Section 2.3.1.5 

33 below). The absorbed Mo-99 would be removed from the ion exchange column media to obtain 

34 a Mo-99 solution. The Mo-99 solution would then be pumped through a second and third ion 

35 exchange column to undergo chemical adjustments to remove unwanted isotopes and purify the 

36 Mo-99 solution. The Mo-99 solution would be transferred to small vials that are placed into 

37 DOT-approved shipping containers and transferred from the hot cell to a shipping/receiving 

38 room and loading dock. The Mo-99 product would then be transported by air or ground 

39 transportation, depending on which radiopharmaceutical distributor will be receiving the 

40 shipment.

41 2.3.1.5 Uranium Recovery and Recycle

42 The uranium and fission product solution that is separated from the Mo-99 after it is pumped 

43 through the ion exchange columns (see Section 2.3.1.4 discussion above) would be processed 

44 to recover uranium to be used in LEU target fabrication. Before the uranium and fission product 

45 solution is processed, it would be held in storage tanks to allow short-lived radionuclides to 

46 decay. The uranium and fission product solution would then be diluted and pumped through 

47 additional ion exchange columns to separate the remaining fission products from the uranium. 
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1 The separated fission product solution would then be sent to liquid waste storage tanks. The 

2 uranium removed from the ion exchange columns would be transferred to the target fabrication 

3 area, where it would be recycled for fabrication of additional LEU targets.

4 2.4 Power Requirements

5 Columbia Water and Light would supply electrical power to the proposed NWMI facility 

6 (NWMI 2015f). Overall, the proposed NWMI facility would annually consume 

7 10 megawatt-hours. NWMI would equip the facility with an uninterruptible electrical power 

8 supply (UPS) system to power safety-related systems and equipment for safe shutdown of the 

9 facility in the event of a loss of offsite power. NWMI would also maintain and test a 1,000 kW 

10 standby diesel generator to extend the duration of UPS power. The diesel generator will be 

11 serviced with a 3,785 L (1,000 gal) diesel tank, stored above ground (NWMI 2015a). NWMI 

12 would use natural gas to supply five boilers. NWMI estimates that the total annual natural gas 

consumption would be 4.3 x 10 13 5 million British thermal units (calculated from NWMI 2015c).

14 2.5 Water Use, Treatment, and Discharges

15 2.5.1 Water Use

16 Public utility infrastructure (i.e., electric power, natural gas, water, and sanitary sewer) would 

17 serve the proposed NWMI facility. Utility providers would extend service lines to connect the 

18 proposed NWMI facility to existing service lines, including to public water mains. Utility work 

19 would be performed as part of site preparation (NWMI 2016a). Table 2–3 lists the projected 

20 water needs to support NWMI facility construction, operations, and decommissioning activities.

21 Table 2–3. Water Requirements for NWMI Facility

Project Phase and Use Volume Required (gal)

Construction

Dust control/soil compaction –

Workforce potable and sanitary use(a) –

Washing and miscellaneous uses –

 Subtotal (average daily)(b) 6,140

 Total (construction phase)(c) 2,088,000

Operations

Target fabrication (average daily)(d) 25

Target disassembly and dissolution (average daily)(d) 1.5

Mo-99 recovery and purification system(d) –

Uranium recovery and recycle system (average daily)(d) 508

Laboratory facilities (average daily)(d) 2

Facility support (average daily)(d, e) 2

Wash water (average daily) 366

Potable and sanitary (average daily) 4,140

 Subtotal (average daily) 5,045

 Total (annualized operations)(f) 1,312,000
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Project Phase and Use Volume Required (gal)

Decommissioning

Dust control/soil compaction –

Workforce potable and sanitary use(a) –

Washing and miscellaneous uses –

 Subtotal (average daily) 2,000

 Total (decommissioning phase)(g) 960,000

(a) Portable sanitary facilities would be used to minimize water use by workforce.

(b) Total is inclusive of the listed uses during the projected 17-month construction period.

(c) Total demand for 17-month construction phase, assuming 20 workdays per month.

(d) Facility uses served by the demineralized water system with raw water supplied by public water system.

(e) Periodic/intermittent needs to fill/top off the NWMI facility’s 180,000-gallon firewater storage tank and to provide 

cooling system makeup are not included.

(f) Total annual water demand assumes 260 days of operation per year.

(g) Total demand for assumed decommissioning phase of up to 24 months, assuming 20 workdays per month.

Note: Some values are rounded. To convert gallons (gal) to liters, multiply by 3.7854. To convert gal to cubic 

meters (m3), divide by 264.2.

Source: Based on values derived or scaled from NWMI 2015a, 2015c, 2016a

1 Water would be required for various purposes, such as dust suppression and soil compaction 

2 during NWMI facility construction. Activities requiring water would include, but would not be 

3 limited to, site clearing and grading, facility excavation, support facility construction, roadway 

4 development, and installation of site drainage and utilities. Water would also be required to 

5 meet the drinking and sanitary needs of the construction workforce. NWMI proposes to use 

6 portable restroom facilities, serviced by a commercial vendor (NWMI 2015c).

7 As proposed, operational water use within the RPF building is divided among four key systems: 

8 (1) the demineralized water system (serving process and related uses), the wash water system, 

9 the potable and sanitary system (i.e., serving drinking, showers, and toilets), and the firewater 

10 system (Table 2–3). During operations, wash water would primarily be required for cleaning 

11 tractor trailers (NWMI 2015a, 2015c).

12 Facility decommissioning activities would require water for many of the same purposes as 

13 construction in association with facility demolition and decontamination (see Table 2–3).

14 2.5.2 Water Treatment

15 Potable water would be supplied to the NWMI facility through a public utility system to support 

16 facility operations. The water would require no additional treatment for most facility uses. 

17 Nonetheless, the water routed to the process systems must be pretreated by the demineralized 

18 water system. Demineralization, also known as ion exchange, refers to the exchange of ions 

19 between a solid substance and an aqueous solution (makeup water). This system would supply 

20 demineralized water to the RPF building facility processes for water addition, flushing, and 

21 chemical dilution. The demineralized water system can also potentially provide makeup water 

22 to the steam boilers (NWMI 2015a, 2015c).

23 Once charged, the steam boiler and chilled water (cooling) systems are closed-loop and require 

24 minimal makeup water inputs during operation (NWMI 2015a).
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1 2.5.3 Water Discharges

2 As stated in the applicant’s ER, the NWMI RPF building is designed to have zero liquid 

3 discharge from the radiologically controlled area of the facility. No radioactive liquid effluents 

4 would be discharged to the site environment. RPF processed radioactive liquid wastes would 

5 be physically and chemically treated, as necessary, and shipped to an appropriate disposal 

6 facility, as further described in Section 2.9 (NWMI 2015a, 2015c).

7 Nonhazardous, nonradioactive wastewater would be discharged to the municipal sanitary sewer

8 collection and treatment system. This effluent would be primarily comprised of sanitary 

9 wastewater (NWMI 2015a). Based on the staff’s review of the ER and applicable regulatory 

10 information, all wastewater conveyed to the municipal system would have to comply with 

11 influent acceptance criteria and applicable pretreatment requirements, as prescribed in 

12 applicable ordinances.

13 2.6 Cooling and Heating Dissipation Systems

14 2.6.1 Cooling Systems

15 The NWMI cooling water systems would control the temperature of process equipment at the 

16 proposed NWMI RPF building from process activities and heat of radioactive decay of fission

17 products in the hot cells and target fabrication area. The cooling system consists of a primary 

18 closed-loop, an intermediate heat exchanger, a secondary loop, and air-cooled chillers. Water 

19 from the primary loop and secondary loop do not come in direct contact because heat from the 

20 primary loop to the secondary loop is exchanged through the intermediate heat exchanger. The 

21 secondary loop circulates chilled water from air-cooled chillers located outside the RPF building 

22 to a heat exchanger that removes heat from the primary loop (i.e., heat is transferred from the 

23 primary loop to the secondary loop). The secondary loop water is then circulated to the 

24 air-cooled chillers and heat is dissipated to the environment. The primary closed-loop circulates 

25 and distributes chilled water from the heat exchanger to various process areas to remove heat; 

26 this heated water in the primary loop is then circulated back to the heat exchanger to transfer 

27 heat to the chilled secondary loop water.

28 2.6.2 Heating Systems

29 The RPF building would house five natural gas-fired boilers. One set of three boilers will be 

30 dedicated for the heating, ventilation, and air conditioning system (HVAC). One set of two 

31 boilers would be dedicated to steam production necessary for process equipment. NWMI 

32 anticipates that three boilers will be operational at any one time; the remaining two boilers will 

33 be spare (NWMI 2015c). NWMI estimates that the total annual natural gas consumption would 

be 4.3 x 10 34 5 million British thermal units (NWMI 2015c).

35 The process steam system will consist of a primary loop, secondary loop, and intermediate heat 

36 exchanger. The steam from the boilers flows to an intermediate heat exchanger in the 

37 secondary loop. The primary loop then circulates and distributes steam from the heat 

38 exchanger to the various process loads in a closed loop (NWMI 2015a). 

39 2.7 Radioactive and Nonradioactive Waste

40 Construction, operations, and decommissioning of the NWMI facility would result in the 

41 generation of radioactive and nonradioactive wastes. The information below describes the 
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1 generation and treatment of radioactive and nonradioactive wastes at the proposed NWMI 

2 facility, and the waste minimization and pollution prevention measures.

3 2.7.1 Radioactive Waste

4 During construction of the proposed NWMI facility, NWMI would not have radioactive material

5 associated with the production of medical isotopes on site; therefore, no radioactive waste

6 would be generated during this phase. During operation of the NWMI facility, processes would 

7 generate liquid, solid, and gaseous radioactive waste during the following activities:

8 • target fabrication (i.e., dissolution and washing process);

9 • target disassembly and dissolution (i.e., spent metal cladding, fission product gases);

10 • Mo-99 recovery and purification (i.e., exchange resin);

11 • uranium recovery and recycle (i.e., exchange resin, fission product solution);

12 • waste management system (i.e., liquid waste collection, concentration, solidification, 

13 and encapsulation process);

14 • laboratory facility operation (i.e., laboratory glassware, vials, and containers); and

15 • facility support operations (i.e., potentially radiologically contaminated waste such as 

16 failed process equipment, decontamination materials, and personal protective 

17 equipment) (NWMI 2015a, 2016c).

18 2.7.1.1 Gaseous Waste

19 Gaseous radioactive waste from routine operations of the proposed NWMI facility would consist 

20 of radioactive effluents from hot cell processes, including irradiated LEU target dissolution and 

21 uranium recovery and recycling processes. The design of the RPF ventilation system divides 

22 the operating areas into pressure zones that draw air from the cleanest part of the facility to the 

23 most contaminated area. This design protects workers and members of the public by 

24 minimizing the potential spread of radioactive contamination within the facility. Gaseous 

25 effluents from the NWMI facility would be released to the environment through one of three vent 

26 stacks, each of which would release air from a separate zone or zones of the RPF building. The 

27 gaseous effluents would be treated using two high-efficiency particulate air (HEPA) filters to 

28 remove radioactive particulates, and carbon absorbers to remove iodine fission products, before 

29 they are released through a vent stack in the RPF building. In addition, gas retention systems 

30 would temporarily retain effluents containing radioactive gas for a period of time before they are

31 released into the environment, to reduce the level of fission product gasses such as xenon and 

32 krypton by decay (NWMI 2015a, 2015g).

33 NWMI expects gaseous radioactive effluents released into the environment through the vent 

34 stacks to contain measureable quantities of noble gases (i.e., xenon and krypton). Table 2–4

35 lists the quantities of radionuclides that NWMI estimates the facility would release annually. 

36 Radioactive iodine, particulates, and tritium could also be present in the airborne effluent 

37 exhaust (NWMI 2015a). NWMI would perform monitoring of these releases, as described in 

38 Section 4.8.
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1 Table 2–4. Gaseous Radioactive Effluents

Effluent Rate(a)

Krypton-85 58.4 Ci/yr(b)

Xenon-131 166 Ci/yr

Xenon-133 498 Ci/yr

(a) The rate is based on 52 weeks of operation

(b) Ci/yr = curie(s) per year

Source: NWMI 2015a

2 2.7.1.2 Liquid and Solid Waste

3 Operation of the NWMI facility would result in the production of liquid and solid radioactive 

4 waste. Liquid radioactive wastes would be generated by target fabrication, target disassembly 

5 and dissolution, Mo-99 recovery and purification, uranium recovery and recycle, laboratory 

6 facility operation, and facility support operations. Liquid waste would be treated and solidified 

7 into a solid waste form suitable for offsite disposal (NWMI 2015a). NWMI estimates that 

8 525,000 kilograms (kg) (1,157,426 pounds (lbs)) of solidified liquid waste would be generated 

9 per year. No liquid radioactive material would be released to the environment as a result of 

10 routine operations of the NWMI facility (NWMI 2015a). Liquid waste from process operations 

11 would be recycled and reused where practicable and, therefore, would be expected to reduce 

12 the amount of solidified waste (NWMI 2015a).

13 Solid radioactive wastes would be generated during target disassembly and dissolution, Mo-99

14 recovery and purification, uranium recovery and recycle, waste management, laboratory facility 

15 operation, and facility support operations. Solid waste will be collected into disposal containers, 

16 and most solid waste will be encapsulated in cement (NWMI 2015a, 2015c, 2016c). Large 

17 pieces of equipment that may fail and solid waste from laboratory facility operations and facility 

18 support operations for which encapsulation on site may be difficult will not be encapsulated 

19 (NWMI 2016c). NWMI estimates that 15,000 kg (33,069 lbs) of encapsulated solid waste and 

20 an additional 7,000 kg (15,432 lbs) of solid waste not encapsulated, would be generated per 

21 year (NWMI 2015c, 2016c). A portion of the solid radioactive waste generated from laboratory 

22 operations at the proposed NWMI facility would be mixed (i.e., both hazardous and radioactive) 

23 waste. NWMI estimates that less than 760 kg (1,676 lbs) of mixed waste would be generated 

24 per year. This quantity of mixed waste is included in the estimates above and in the total 

25 hazardous waste generation estimate discussed in Section 2.7.2 (NWMI 2016c).

26 The NRC classifies solid low-level waste in 10 CFR 61.55 as Class A, Class B, Class C, or 

27 greater than Class C (GTCC) waste, depending on the types and concentrations of 

28 radionuclides in the waste. Class A wastes generally contain short-lived radionuclides at 

29 relatively low concentrations, whereas the half-lives and concentrations of radionuclides in 

30 Class B and C wastes are progressively higher. Because of the longer half-lives and higher 

31 concentrations of radionuclides in Class B wastes, these wastes must meet more rigorous 

32 requirements with regard to their form to ensure stability after disposal (e.g., by adding chemical

33 stabilizing agents, such as cement, to the waste, or by placing the waste in a disposal container 

34 or structure that provides stability after disposal). Class C wastes, in addition to meeting 

35 Class B requirements, must have additional measures at the disposal facility to protect against 

36 inadvertent intrusion (e.g., by increasing the thickness and hardness of the cover over the waste 

37 disposal cell). GTCC wastes contain radionuclides at concentrations that are higher than those 
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1 allowed for Class C wastes. For GTCC wastes, near-surface disposal methods are generally 

2 not acceptable.

3 Operation of the NWMI facility would generate NRC Class A and Class B radioactive waste. Of 

4 the 525,000 kg (1,157,426 lbs) of solidified liquid waste that would be generated per year, 

5 NWMI estimates that 300,000 kg (661,386 lbs) is projected to be Class B waste and 225,000 kg 

6 (496,040 lbs) will be Class A waste (NWMI 2015c). NWMI estimates that all of the 15,000 kg/yr 

7 (33,069 lbs/yr) of encapsulated solid waste will be Class B waste, and 7,000 kg/yr 

8 (15,432 lbs/yr) of solid waste not encapsulated will be Class A waste (NWMI 2015c, 2016c). 

9 Possible volume reduction and optimization activities have the potential to change some 

10 Class B waste into Class C; if NWMI anticipates that Class C waste will be produced, NWMI 

11 would provide this information in its operating license application and the NRC would review this 

12 information and document its review in the supplemented EIS. NWMI expects that no GTCC 

13 wastes will be generated (NWMI 2015c).

14 2.7.2 Nonradioactive Waste

15 2.7.2.1 Liquid Waste

16 Nonradioactive liquid waste would be generated during construction. For example, lubricating 

17 oil, hydraulic oil, and grease might be necessary to assemble various pieces of equipment and 

18 systems. Chemicals, hazardous liquids, compressed gases, flammable liquids, and oxidizers 

19 are expected to be on site during construction (NWMI 2015a). NWMI intends to use best 

20 management practices and personal protective equipment to minimize waste generation and 

21 exposure (NWMI 2015a).

22 During operations, nonradioactive liquid waste would include hazardous waste, such as 

23 chemicals. Table 2–5 lists some of the expected inventory and quantity of chemicals that would 

24 be used during operation of the proposed NWMI facility at any given time. Some chemicals 

25 would be in liquid form and would be controlled and confined in containers, tanks, pipes, and hot 

26 cells. NWMI anticipates that the proposed NWMI facility would generate up to 1,000 kg 

27 (2,205 lbs) of hazardous waste per month (NWMI 2015c). However, this estimate includes both 

28 radiological and nonradiological waste as well as solid and liquid waste. Therefore, the liquid 

29 nonradiological hazardous waste portion will be less than 1,000 kg/month (2,205 lbs/month).

30 Table 2–5. Summary of Chemical Inventory and Quantity at the Proposed NWMI Facility

Chemical Quantity(a)

Nitric Acid 100,000 L/yr

Hydrogen Peroxide 500 L

Ammonium Hydroxide, 100 L

Ammonia 100 kg

Carbon Dioxide 200 kg

Oxygen 100 kg

Nitrogen 1,800 kg

Sulfamic Acid 20.8 kg/yr

Sodium Hydroxide 70,000 L/yr

Reductant 230 L/yr

Sodium Hypochlorite 1 L

Amberlite LA-2 25 kg
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Chemical Quantity(a)

Diethylbenzene 50 kg

Sorbent 10,000 kg

Solvent 200 L

Hexamethylenetetramine 200 kg

Urea 100 kg

Silicone Oil 100 L

(a) L = liters; kg = kilograms; yr = year.

Source: NWMI 2015a

1 NWMI would release nonradiological liquid waste meeting municipal treatment standards to the 

2 Columbia, Missouri, sewer system as a result of chemical processes conducted during routine 

3 facility operations (NWMI 2015a). NWMI stated it will have administrative controls in place and 

4 sampling and monitoring processes to ensure that its nonradioactive effluents meet the 

5 requirements pertaining to the types, quantity, and concentrations specified as acceptable for 

6 processing by the Columbia wastewater treatment facility. Liquid wastes that do not meet the 

7 local municipal wastewater treatment standards would be containerized and shipped to a 

8 disposal facility (NWMI 2015a). Additionally, sanitary wastewater from the proposed NWMI 

9 facility would be sent to the Columbia sanitary sewer system (NWMI 2015a). Section 4.9.2 of 

10 this document contains more information on the liquid nonradioactive waste discharges from the 

11 proposed NWMI facility.

12 2.7.2.2 Solid Waste

13 During construction, operations, and decommissioning, NWMI expects to generate the following 

14 nonradioactive solid wastes: 

15 • wood,

16 • metal,

17 • plastics,

18 • piping,

19 • wires,

20 • batteries,

21 • office supply waste,

22 • expired lights and fixtures,

23 • packaging waste, and

24 • solidified used oil and solvents.

25 The solid hazardous waste that would be generated would be a portion of the up to 1,000 kg 

26 (2,205 lbs) total (solid and liquid) hazardous waste produced per month that was described in 

27 Section 2.7.2.1. The proposed facility would also generate approximately 4,056 kg (8,942 lb) of 

28 solid nonradiological, nonhazardous waste (i.e., municipal waste) per year during operation 

29 (NWMI 2015c).
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1 NWMI would temporarily collect and store nonradioactive waste on site. NWMI stated that all 

2 solid hazardous waste would be managed according to applicable regulations (e.g., the 

3 Resource Conservation and Recovery Act (42 USC 6901et seq.) and the Missouri Hazardous 

4 Waste Management Law (Missouri Revised Statutes 260.350 to 260.430)) (NWMI 2015a).

5 2.7.3 Waste Minimization and Pollution Prevention Program

6 NWMI will implement a program of pollution prevention and waste minimization that includes:

7 • waste minimization and recycling programs specific to various phases of the project

8 (e.g., construction and operations);

9 • employee training and education;

10 • recognition of employees for improving environmental conditions; and

11 • requirements and responsibilities to consider pollution prevention and waste

12 minimization in day-to-day activities (NWMI 2015a).

13 Section 4.9 discusses the impacts associated with waste management activities at the proposed 

14 NWMI facility.

15 Another facet of NWMI’s waste minimization program will be its recycling and reclamation 

16 program. This program manages economic and environmental costs and impacts that result in 

17 cost savings and reduced waste generation. This program will focus primarily on paper, plastic, 

18 administrative supplies, solvent (trichloroethylene) recovery, uranium, and process water 

19 (NWMI 2015a).

20 2.8 Storage and Transportation of Radioactive and Nonradioactive Materials 

21 and Waste

22 Construction, operations, and decommissioning of the NWMI facility would result in the 

23 accumulation of radioactive and nonradioactive wastes. NWMI does not anticipate any 

24 long-term storage or disposal of radioactive or nonradioactive materials on site (NWMI 2015a). 

25 NWMI will treat and temporarily store liquid and solid radioactive and nonradioactive waste 

26 generated as part of the radioisotope production process within the facility until it can ship the 

27 waste off site for disposal (NWMI 2015a). Transportation of radioactive material, radioactive 

28 waste, and medical isotopes will be conducted in accordance with NRC and DOT regulations to 

29 protect public health and safety during the transportation of these materials (NWMI 2015a). The 

30 additional information provided below describes, as applicable, the generation, storage, waste 

31 management activities, waste minimization and pollution prevention measures, and 

32 transportation of radioactive and nonradioactive waste and materials. 

33 2.8.1 Storage and Transportation

34 2.8.1.1 Radioactive Waste and Other Materials

35 After NWMI treats and packages radioactive waste, NWMI stated it will temporarily store 

36 radioactive waste at the proposed NWMI facility to allow for decay before offsite transport and 

37 disposal. NWMI stated it will store Class B wastes (solidified liquid waste and encapsulated 

38 solid wastes) at the proposed NWMI facility for at least 12 to 15 weeks of decay time before 

39 shipment off site. NWMI also may temporarily store some Class A waste at the NWMI facility 

40 for approximately 12 weeks (NWMI 2015c). Assembled LEU targets would be stored at the 

41 NWMI facility until they are shipped to research reactors for irradiation. Because of the short 

42 half-life of Mo-99, minimal Mo-99 product temporary storage would occur at the NWMI facility, 
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1 and it would be shipped out twice per week (NWMI 2015a). Similarly, irradiated targets from 

2 research reactors would not be stored at the NWMI facility but would be processed to recover 

3 Mo-99. Radioactive waste and other radioactive material would be stored in a manner that 

4 would ensure that no uncontrolled release of radioactive materials from the NWMI facility could 

5 occur, and that personnel exposures to radiation would be as low as is reasonably achievable 

6 and within 10 CFR Part 20 limits (NWMI 2015g). The NWMI facility would have sufficient space 

7 to store all radioactive materials (NWMI 2015c).

8 Class A and Class B wastes generated at the NWMI facility would be transported off site 

9 following temporary storage. This waste would be transported by commercial carrier, on public 

10 roadways, to Waste Control Specialists in Andrews, Texas (NWMI 2015a, 2015c, 2016c). Other 

11 radioactive materials shipped to and from the proposed site would include fresh LEU, 

12 unirradiated LEU targets, irradiated LEU targets, Mo-99 product solution, and take-back LEU. 

13 Fresh LEU would be shipped, on public roadways, from DOE Y-12 (Oak Ridge, Tennessee) to 

14 the proposed NWMI facility. Unirradiated and irradiated LEU targets would be shipped to and 

15 from the proposed NWMI facility and MURR (Columbia, Missouri), OSTR (Corvallis, Oregon), 

16 and a third research reactor on public roadways. Mo-99 product solution would be shipped, on 

17 public roadways, to a distributor in Hazelwood, Missouri, or to the Columbia Regional Airport in 

18 Columbia, Missouri, and then transported by air from the Columbia Regional Airport to Logan 

19 International Airport in Boston, Massachusetts. From Logan International Airport, the Mo-99 will 

20 be transported on public roadways to a distributor in Billerica, Massachusetts (NWMI 2015a). 

21 Take-back uranium would be shipped, on public roadways, to DOE’s Savannah River Site in 

22 Aiken, South Carolina.

23 NWMI stated that, when transporting waste and other radioactive materials on public roads, 

24 NWMI or commercial carriers must comply with the applicable DOT regulations in 

25 49 CFR Parts 172, 173, 177, and 397, as well as the NRC packaging requirements for 

26 radioactive material in 10 CFR Part 71 (NWMI 2015a). These regulations help ensure safety on 

27 the public roadways. NWMI also stated that for transport of Mo-99 product by air, the air carrier 

28 NWMI chooses also must comply with additional DOT regulations in 49 CFR Part 175 

29 (NWMI 2015a).

30 In accordance with 10 CFR Part 71, waste and other radioactive material shipped to or from the 

31 NWMI facility would require packaging meeting one of three DOT packaging classifications: low 

32 specific activity (LSA), Type A, or Type B. An LSA package contains low levels of radioactive 

33 material. A Type A package meets additional integrity and shielding requirements, and may 

34 contain higher radioactivity levels than an LSA package. Type B packages meet the highest 

35 integrity and shielding requirements, and may contain higher radioactivity levels than a Type A 

36 package. The lettering system for packaging types is not related to the lettering system for 

37 waste classification.

38 2.8.1.2 Nonradioactive Waste and Other Materials

39 NWMI does not anticipate any long-term storage or disposal of nonradioactive (hazardous or 

40 nonhazardous) materials on site (NWMI 2015a). NWMI stated it will treat and temporarily store 

41 liquid and solid nonradioactive waste generated as part of the radioisotope production process 

42 within the facility until it can ship the waste off site for disposal (NWMI 2015a). Nonradioactive 

43 liquid wastes that do not meet the municipal treatment standards will be containerized, treated 

44 (reduced and neutralized), and solidified and shipped to a disposal facility. Solid waste will be 

45 transported off site to either a landfill, storage facility, or recycling or recovery facility, as 

46 appropriate. For instance, nonhazardous, nonradioactive solid waste (wiring, packaging waste) 

47 will be shipped to a landfill (NWMI 2015c). NWMI stated hazardous waste will be handled in 

48 accordance with applicable regulations (e.g., the Resource Conservation and Recovery Act) 
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1 and would be collected by a hazardous waste disposal company for separation, processing, and 

2 disposal (NWMI 2015c).

3 NWMI will develop a chemical management and product handling plan. The storage and 

4 treatment of wastes will be conducted in accordance with this plan. Additionally, onsite storage 

5 of chemicals and supplies will be performed in accordance with a chemical management and 

6 product handling plan to ensure that chemicals are properly stored (e.g., non-compatible 

7 chemicals are stored in separate areas, flammable chemicals and oxidizers are stored in 

8 separate areas) (NWMI 2015a).

9 NWMI would temporarily collect and store solid nonradioactive waste on site and then transport 

10 waste to a landfill, storage facility, or recycling facility. Transportation will be by ground 

11 transportation. NWMI must package and transport hazardous nonradioactive waste in 

12 accordance with DOT regulations contained in 49 CFR 171-180.

13 2.9 Facility Decommissioning

14 The NWMI facility would be decommissioned 

15 upon completion of its useful life. In accordance 

16 with 10 CFR Part 50, a licensed production or 

17 utilization facility that permanently ceases 

18 operations submits a decommissioning plan or 

19 report. Also, 10 CFR 50.33(k) requires that an 

20 operating license applicant submit a report that

21 indicates how reasonable assurance will be 

22 provided that funds will be available to 

23 decommission the facility.

24 NWMI anticipates decommissioning of the facility to begin following a 30-year operating period 

25 (NWMI 2015a). Decommissioning activities would be similar to construction activities, because 

26 they would involve heavy equipment to dismantle buildings and remove roadway and parking 

27 facilities (NWMI 2015a). Decommissioning would involve decontamination of the RPF, 

28 reduction of residual radioactivity to a level that permits release of the property for unrestricted 

29 use and termination of the license. NWMI estimated that the decommissioning period would 

30 extend for 18 to 24 months and would require a peak workforce of approximately 81 workers, 

31 1 truck delivery per week, and 20 offsite waste shipments per week (NWMI 2015c, 2016a). 

32 Demolition and equipment supporting activities are projected to consume 1,647 L/month 

33 (435 gal/month) of diesel fuel (NWMI 2015a, 2015c). Estimates of the types and quantity of 

34 radioactive waste that would be disposed of during decommissioning are not known at this time. 

35 However, the NRC staff assumes that the types of radioactive waste would be consistent with 

36 those discussed in Section 2.7.1. NWMI would be required to conduct decommissioning 

37 activities such that radiation doses to occupational workers and members of the public are 

38 maintained below 10 CFR Part 20 limits. 

39 NWMI would be required to conduct decommissioning activities in accordance with applicable 

40 NRC requirements and any additional Federal, State, and local requirements. For example, any 

41 radioactive equipment and materials will be disposed of according to State and Federal laws 

42 and regulations. After decommissioning activities are completed, the proposed site could 

43 remain industrial or could be converted back to agricultural land or open space.

Decommission means to remove a facility or 

site safely from service and reduce residual 

radioactivity to a level that permits:

• Release of the property for unrestricted

use and termination of the license or

• Release of the property under restricted

conditions and termination of the

property (10 CFR 50.2)

3-1 

1 3.0 AFFECTED ENVIRONMENT

2 The site proposed by Northwest Medical Isotopes, LLC (NWMI) for the NWMI facility is Lot 15 of 

3 the Discovery Ridge Research Park located in Boone County, Columbia, Missouri. This chapter 

4 describes the existing regional and local environmental conditions in the vicinity of the proposed 

5 site for land use and visual resources, air quality and noise, the geologic environment, water 

6 resources, ecological resources, historic and cultural resources, socioeconomics, human health, 

7 and transportation. Unless otherwise specified, the description of the environment includes the 

8 area within a 5-mi (8-km) radius of the proposed site, which is also referred to as the vicinity. 

9 This geographic range is consistent with the Final Interim Staff Guidance Augmenting 

10 NUREG–1537, Part 1 and 2 (NRC 2012), which identifies that the geographic distance to be 

11 considered for environmental impacts is a 5-mi (8-km) radial distance from the proposed facility. 

12 The following description of the affected environment is based on the U.S. Nuclear Regulatory 

13 Commission (NRC) staff’s independent review of (1) NWMI’s Environmental Report (ER)

14 (NWMI 2015a, 2015d); (2) NWMI’s responses to the NRC staff’s requests for additional 

15 information (NWMI 2015c, 2016a, 2016b); (3) the NRC staff’s environmental site visit and audit 

16 (NRC 2015b); (4) information provided in public scoping comments (NRC 2016a); (5) comments 

17 and input provided by other Federal agencies, States, Tribes, and regional and local agencies; 

18 and (6) the NRC staff’s independent research of the environs surrounding the proposed site.

19 3.1 Land Use and Visual Resources

20 This section describes the land use and visual resources at the proposed site and in the vicinity 

21 of the proposed site. The NRC staff assessed land use and land cover using the National Land 

22 Cover Database (USGS 2006; Fry et al. 2011). The NRC staff used the U.S. Department of the 

23 Interior, Bureau of Land Management (USDOI-BLM), Visual Resource Management System, to 

24 rate the visual resources at the proposed site; this system rates the visual appeal and the 

25 sensitivity of changes to an area (BLM 1984).

26 3.1.1 Land Use

27 3.1.1.1 Site and Immediate Surroundings

28 The proposed site is Lot 15 of the Discovery Ridge Research Park located approximately 3 mi 

29 (5 km) southeast of the City of Columbia (NWMI 2015a; Figure 2–1). The Discovery Ridge 

30 Research Park is 505-ha (1,250-ac) and is owned by the University of Missouri (MU 2016a). 

31 Two research facilities are currently in operation within the research park, and the University of 

32 Missouri intends to expand the research park for additional research facilities (MU 2016a).

33 Lot 15 of the Discovery Ridge Research Park is 7.4 acres (ac) (3.0 hectares (ha)) 

34 (NWMI 2015a; Figure 2–3). Based on a review of the National Land Cover Database, 

35 100 percent of the site is classified as pasture/hay (USGS 2006; NWMI 2015a). No structures 

36 currently exist on the site (NWMI 2015a; NRC2015b). The proposed Discovery Ridge site does 

37 not contain prime farmland or other important farmland soils as defined in the Farmland 

38 Protection Policy Act of 1981 (7 U.S.C. 4201 et seq.) and implementing regulations 

39 (7 CFR Parts 657, 658; NWMI 2015a).

40 The proposed site is zoned A–1 for agricultural activities (City of Columbia 2016a). However, 

41 Section 172.273.1 of the Missouri Revised Statues states that “the curators of the University of 

42 Missouri may establish research, development and office park projects, in order to promote 

43 cooperative relationships and to provide for shared resources between private individuals, 

44 companies and corporations, and the University of Missouri, for the advancement of the 
Affected Environment

3-2

1 university in carrying out its educational mission.” In October 2005, the Board of Curators of the 

2 University of Missouri identified the site to be developed as a research park pursuant to 

3 Statute 172.273 of the Missouri Revised Statutes (MU 2009). In May 2006, the Board approved 

4 the Master Plan of the research park, which designated approximately 114 ac (46 ha) as the 

5 initial phase for development with the expectation that additional phases of the research park 

6 would be added as needed.

7 In the most recent land use plan, the City of Columbia identifies the Discovery Ridge Research 

8 Park, including Lot 15, as “shovel ready” for future industrial development (City of 

9 Columbia 2013). The research park is also one of three sites that the City of Columbia (2013) 

10 designated as an industrial certified site. The future development goal for the Discovery Ridge 

11 Research Park is to increase the number of business and research facilities on site, especially 

12 for entities that would benefit from the close proximity to the resources available at the 

13 University of Missouri (City of Columbia 2013). In addition, one of the City of Columbia’s

14 economic goals is to attract new businesses and increase the number of light industrial and high 

15 tech jobs within the Columbia Regional Airport-Discovery Ridge-U.S. Highway 63 Corridor

16 (City of Columbia 2013), which includes Discovery Ridge Research Park.

17 3.1.1.2 Vicinity

18 Table 3–1 lists the major land uses and land covers within a 5-mi (8-km) radius of the proposed 

19 site (USGS 2006; Fry et al. 2011; NWMI 2015a). The major land uses and covers include 

20 developed areas (25 percent), deciduous forests (31 percent), and hay or pasture (30 percent).

21 The proposed site is within the limits of the City of Columbia, which had a population of 116,109 

22 as of July 1, 2014 (USCB 2016a). The University of Missouri is located within the City of 

23 Columbia and has a student population of 34,748 when in full session (MU 2016b). No other 

24 major population centers (more than 25,000 residents) exist within the 5-mi (8-km) vicinity of the 

25 proposed site.

26 The major transportation corridors in the vicinity include Discovery Parkway, U.S. Highway 63, 

27 and U.S. Interstate 70 (Figure 3–1). COLT Transload, which is owned by the City of Columbia, 

28 provides rail transportation to the City of Columbia. The closest airport to the proposed 

29 Discovery Ridge site is the Columbia Regional Airport, which is located 11 km (7 mi) from the 

30 proposed site. The Missouri River is the largest river in Boone County and occurs 11.7 km 

31 (7.3 mi) to the west of the proposed Discovery Ridge site (see Section 3.4). The Missouri River 

32 is the only river large enough to support commercial traffic in Boone County (NWMI 2015a).
Affected Environment

3-3

1 Figure 3–1. Cities and Major Roadways Within 5 mi (8 km) 

2 of the Proposed Discovery Ridge Site

3

4 Table 3–1. Summary of Land Use and Land Cover Within the 

5 Proposed Discovery Ridge Site and Vicinity

Land Cover Type

NWMI Site Vicinity (5 mi)

ac ha percent ac ha percent

Open Water 346 140 <1

Developed, Open Space 4,119 1,667 8

Developed, Low Intensity 4,677 1,893 9

Developed, Medium Intensity 2,770 1,121 6

Developed, High Intensity 911 369 2

Barren 94 38 <1
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3-4

Land Cover Type

NWMI Site Vicinity (5 mi)

ac ha percent ac ha percent

Deciduous Forest 15,730 6,366 31

Evergreen Forest 534 216 1

Mixed Forest 469 190 <1

Shrub/Scrub 107 43 <1

Grassland 345 140 <1

Pasture/Hay 7.4 3.0 100 15,158 6,134 30

Cultivated Crops 4,639 1,877 9

Woody Wetlands 363 147 <1

Emergent Herbaceous Wetland 2 1 <1

Total(a) 7.4 3.0 100 50,262 20,339 100

Key: ac = acre, ha = hectare.

(a) Total may add up to more or less than 100 percent due to rounding.

Sources: USGS 2006; Fry et al. 2011; NWMI 2015a

1 3.1.1.3 Special Land Uses

2 Approximately 7 percent (1,427 ha (3,527 ac)) of the 5-mi (8-km) vicinity surrounding the 

3 proposed Discovery Ridge site is parks or conservation areas, such as Rock Bridge State Park, 

4 Three River Conservation Area, and the northwest corner of the Mark Twain National Forest 

5 (NWMI 2015a). The Missouri Department of Natural Resources (MDNR) manages the Rock 

6 Bridge State Memorial Park, which is an 858-ha (2,120-ac) park that consists of karsts, 

7 grasslands, and oak woodlands and forests (MDNR 2016a). This State park also contains the 

8 Gans Creek Wild Area. The Missouri Department of Conservation (MDC) manages the Three

9 River Conservation Area, which is a 607-ha (1,500-ac) natural preserve that consists mostly of 

10 oak forests and woodlands and provides cave habitat for bats (MDC 2016a). A small portion of 

11 the Mark Twain National Forest, Cedar Creek Ranger District, is also located within the vicinity 

12 of the proposed site (USDA 2016a). The Mark Twain National Forest consists of tall grass 

13 prairies and shortleaf pine-oak woodlands.

14 No active mines or quarries, military reservations, Federally designated wild and scenic rivers, 

15 national parks, or Federal lands held in trust for an American Indian tribe occur within 5 mi 

16 (8 km) of the proposed site (NWMI 2015a; NRC 2015b; Find the Data 2016). In addition, 

17 because no Federally designated coastal zone areas occur within 5 mi (8 km) of the proposed 

18 NWMI site the proposed action would not affect any land or water use or natural resource within 

19 a coastal zone (NOAA 2016). Thus, no applicant certification and State concurrence (under the 

20 Coastal Zone Management Act of 1972, as amended) that the activity is consistent with the 

21 State’s Coastal Zone Management Plan is needed for the NRC’s review of the construction 

22 permit for the proposed NWMI facility.

23 3.1.1.4 Agricultural Resources and Facilities

24 Soils that may qualify as prime farmland and farmland of statewide importance are located 

25 within the 5-mi (8-km) vicinity of the proposed Discovery Ridge site (Figure 3–2). Prime 

26 farmland is defined in the Farmland Protection Policy Act of 1981 as “land that has the best 

27 combination of physical and chemical characteristics for producing food, feed, fiber, forage, 
Affected Environment

3-5

1 oilseed, and other agricultural crops with minimum inputs of fuel, fertilizer, pesticides, and labor, 

2 and without intolerable soil erosion, as determined by the Secretary [of Agriculture].” The 

3 Farmland Protection Policy Act states that farmland of statewide importance includes soils, 

4 other than those determined as prime farmland, with similar characteristics as prime farmland 

5 locally within the State. The U.S. Department of Agriculture (USDA), Natural Resources 

6 Conservation Service (NRCS), in cooperation with State and local agencies, defines and 

7 delineates the soils to consider as prime farmland and farmland of statewide importance (Title 7 

8 of the Code of Federal Regulations (CFR) Part 657). However, otherwise qualifying “farmland” 

9 soils do not include those on land already in, or committed to, urban development or water 

10 storage, as defined in 7 CFR 658.2.

11 In Missouri, farmlands of statewide importance include the following soils: Weller silt loam, 

12 Weller–Urban land complex, Wrengart silty clay loam, and Hatton silt loam (NRCS 2016a, 

13 2016b). Weller silt loam is the most common soil type that qualifies as both prime farmland and 

14 farmlands of statewide importance. The proposed Discovery Ridge site does not contain prime 

15 farmland or other important farmland soils. Within a 5-mi (8-km) radius of the proposed 

16 Discovery Ridge site, approximately 4,218 ha (10,424 ac), or one-fifth of the 5-mi (8-km) vicinity, 

17 are prime farmland or statewide important farmland (NRCS 2016a, 2016b; NWMI 2015a).

18 Principal agricultural products grown in the vicinity include soybeans, sorghum, and oats 

19 (USDA 2014). Many farms in the vicinity of the proposed Discovery Ridge site are used for 

20 pasture and grazing (USDA 2014; NWMI 2015a).

21 3.1.2 Visual Resources

22 The visual setting of the area that would be affected by the proposed NWMI facility includes 

23 agricultural, residential, and light industrial viewsheds (NWMI 2015a; NRC 2015b, Figures 3–3 

24 through 3–10). Deciduous trees are also visible (NWMI 2015a; NRC 2015b). The viewsheds to 

25 the north and south of the proposed site have slightly rolling cultivated fields, roads, and 

26 residential buildings. The viewshed to the east is similar, with mostly agricultural fields, and a 

27 building associated with the University of Missouri Beef Farm. The viewshed to the west 

28 includes roads and agricultural fields.
Affected Environment

3-6

1 Figure 3–2. September 2013 Visual Reconnaissance Photo Locations

2

3 Source: NWMI 2015a
Affected Environment

3-7

1 Figure 3–3. View of Proposed Radioisotope Production Facility Site from Intersection of 

2 Rolling Hills and Bass Roads, Photo Location #1

3

4 Source: NWMI 2015a

5 Figure 3–4. View of Proposed Radioisotope Production Facility Site from Gans Road, 

6 approximately 1.6 km (1 mi) North Photo Location #2

7

8 Source: NWMI 2015a
Affected Environment

3-8

1 Figure 3–5. Direct View of Radioisotope Production Facility Site from Discovery Parkway 

2 near the Overpass, Photo Location #3

3

4 Source: NWMI 2015a

5 Figure 3–6. View of Radioisotope Production Facility Site from the North Edge of Perry 

6 Phillips Lake, Photo Location #4

7

8 Source: NWMI 2015a
Affected Environment

3-9

1 Figure 3–7. View of Proposed Radioisotope Production Facility Site from Boys and Girls 

2 Town of Missouri, Photo Location #5

3

4 Source: NWMI 2015a

5 Figure 3–8. View of Proposed Radioisotope Production Facility Site from S. Lenoir and 

6 Roosevelt Avenue, Photo Location #6

7

8 Source: NWMI 2015a
Affected Environment

3-10

1 Figure 3–9. View of Proposed Radioisotope Production Facility Site from Intersection of 

2 New Haven and Rolling Hills Roads, Photo Location #7

3

4 Source: NWMI 2015a

5 Figure 3–10. View of Proposed Radioisotope Production Facility Site from Route WW at 

6 Old Hawthorne, Photo Location #8

7

8 Source: NWMI 2015a
Affected Environment

3-11

1 The proposed site would be within the viewshed of patrons and employees visiting the nearby 

2 facilities within the Discovery Ridge Research Park, traveling along nearby roads and highways, 

3 and potentially from some of the nearby residences (NWMI 2015a; NRC 2015b). Trees and 

4 other vegetation that border many of the residential neighborhoods and some of the business 

5 would obstruct the view of the proposed NWMI facility from some of these areas.

6 The NRC staff rated the visual resources and scenic quality of the existing site using the 

7 USDOI-BLM Visual Resource Management System (BLM 1984). The scenic quality 

8 classification is the rating of the visual appeal of the land designated for the proposed site. This 

9 rating is based on an evaluation of seven key factors—landform, vegetation, water, color, 

10 adjacent scenery, scarcity, and cultural modifications. Scenic quality is classified as A, B, or C, 

11 with A as the highest quality visual rating. The NRC staff gave the proposed site a C rating, with 

12 low scenic quality because of the uniform landform, low vegetation diversity, absence of water, 

13 subtle variation of color variations and contrast of vegetation, absence of cultural modifications 

14 to adjacent scenery, commonality within the physiographic province, and lack of notable 

15 features (NWMI 2015a; NRC 2015b).

16 The NRC staff also analyzed the sensitivity level, which is a measurement of public concern for 

17 scenic quality, using six different indicators—types of users, amount of use, public interest, 

18 adjacent land uses, special areas, and other factors. The sensitivity level of public concern for 

19 scenic quality is assigned as high, moderate, or low. The NRC staff assigned the proposed site 

20 a low sensitivity level because it is located in an area with low scenic values, typical users have 

21 low sensitivity to changes in the area’s visual quality, the amount of viewer use is low, public 

22 interest in changes to the visual quality of the proposed site is low, and the location has no 

23 special natural and wilderness areas (NWMI 2015a; NRC 2015b).

24 3.2 Meteorology, Air Quality, and Noise

25 3.2.1 Meteorology and Climatology

26 The State of Missouri is characterized by a humid continental type climate, subject to frequent 

27 changes in temperatures, and strong seasonality (NCDC undated). The lack of topographic 

28 barriers allows dry and cool air masses from Canada to reach the region during winter, and 

29 during summer moist and warm air masses from the Gulf of Mexico reach the region. Summers 

30 are warm, humid, and rainy and winters are moderately cold and snowfalls are common. 

31 Climate characteristics vary across the State along a diagonal line trending northwest to 

32 southeast. The proposed site is located in Missouri’s Northeast Prairie Climate Division 2. The 

33 nearest National Climatic Data Center (NCDC) station is the Columbia Regional Airport station. 

34 To characterize the region’s climate, the NRC staff used a 30-year (1981–2010) climatological 

35 data set from the Columbia Regional Airport (NCDC 2010). The Columbia Regional Airport 

36 station is 7 mi (11 km) from the proposed Discovery Ridge site.

37 Figure 3–2 summarizes annual and seasonal precipitation and temperature data for the 

38 1981-2010 record from the Columbia Regional Airport station. Annual average temperature for 

39 the 30-year record was 54.6 oF (12.6 oC). Average seasonal temperatures for the 30-year 

40 record ranged from 75.5 oF (24.2 oC) in the summer to 32.1 oF (0.05 oC) in the winter. Annual 

41 average precipitation was 42.62 in. (1.1 m) and seasonal precipitation ranged from 6.61 in. 

42 (16.8 cm) in the winter to 13.20 in. (33.5 cm) in the summer. Monthly average wind speeds 

43 range from 7.4 miles per hour (mph) (11.9 kilometers per hour (kph)) in August to 11.3 mph 

44 (18.2 kph) in March. Annual mean wind speed is 9.5 mph (15.3 kph). Prevailing wind direction 

45 is from the south May through November and from the northwest December through April 

46 (NCDC 2014).
Affected Environment

3-12

1 Table 3–2. Annual and Seasonal Precipitation and Temperature Data for Columbia, 

2 Missouri

Annual Winter Spring Summer Fall 

Average Temperature (oF) 54.6 32.1 54.5 75.5 56.0

Average Precipitation (in.) 42.62 6.61 12.38 13.20 10.43

Source: NCDC 2010

3 NCDC records (NCDC 2016) identify the following extreme weather events in Boone County 

4 from 1950 to 2015:

5 • tornadoes: 26 events,

6 • floods: 11 events,

7 • blizzard: 1 event, and 

8 • strong winds: 2 events.

The strongest recorded tornados in the County were classified as F3, 9 1 which occurred in 1990 

10 and 1998.

11 3.2.2 Air Quality

12 Under the Clean Air Act of 1970, as amended (CAA) (42 U.S.C. 7401 et seq.), the 

13 U.S. Environmental Protection Agency (EPA) has set primary and secondary National Ambient 

14 Air Quality Standards (NAAQS) (40 CFR Part 50) for six common criteria pollutants considered 

15 harmful to public health and the environment. Primary standards specify maximum ambient 

16 concentration levels of the criteria pollutants aimed at providing public health protection 

17 including protecting the health of “sensitive” populations, such as asthmatics, children, and the 

18 elderly. Secondary standards specify maximum ambient concentration levels of the criteria 

19 pollutants aimed at providing public welfare protection including protection against decreased 

20 visibility and damage to animals, crops, vegetation, and buildings. The NAAQS criteria 

21 pollutants include carbon monoxide (CO), lead (Pb), nitrogen dioxide (NO2), ozone (O3), sulfur 

22 dioxide (SO2), and particulate matter (PM). Particulate matter is further categorized by size—

23 particulate matter with aerodynamic diameter of 10 micrometers (μm) or less (PM10) and 

24 particulate matter with aerodynamic diameter of 2.5 μm or less (PM2.5). 

25 The CAA allows for states to adopt additional or more stringent air quality standards. Missouri 

26 has adopted the CAA NAAQS in Title 10 of Missouri’s Code of State Regulations (CSR) and 

27 has set standards for hydrogen sulfide and sulfuric acid (10 CSR 10-6.010). Table 3–3 presents 

28 the NAAQS for the six criteria pollutants and two State standards.

 1 There are five tornado classifications: F0 to F5. F0 tornadoes cause the least damage, and F5 tornadoes are the 

most dangerous and cause the most damage. Estimated wind speeds for an F3 tornado are 158 to 206 mph and 

can cause severe damage.
Affected Environment

3-13

1 Table 3–3. Ambient Air Quality Standards

Pollutant

Primary/Secondary 

Standard Averaging Time Level

Carbon Monoxide (CO) Primary 8-hr 9 ppm

1-hr 35 ppm

Lead (Pb) Primary and Secondary Rolling 3-month 

average

0.15 μg/m3

Nitrogen Dioxide (NO2) Primary 1-hr 100 ppb

Primary and Secondary Annual 53 ppb

Ozone (O3) Primary and Secondary 8-hr 0.075 ppm

Particulate matter less than 2.5 

μm (PM2.5)

Primary Annual 12 μg/m3

Secondary Annual 15 μg/m3

Primary and Secondary 24-hr 35 μg/m3

Particulate matter less than 

10 μm (PM10)

Primary and Secondary 24-hr 150 μg/m3

Sulfur Dioxide (SO2) Primary 1-hr 75 ppb

Secondary 3-hr 0.5 ppm

Hydrogen Sulfide (H2S) State Standard 1⁄2-hr 0.03 ppm

1⁄2-hr 0.05 ppm

Sulfuric Acid State Standard 1-hr 30 μg/m3

24-hr 10 μg/m3

Key: ppb = parts per billion; ppm = parts per million; μg/m3 = micrograms per cubic meter.

Sources: EPA 2016f; 10 CSR 10-6.010

2 The EPA designates areas of “attainment” and “nonattainment” with respect to the NAAQS. 

3 Areas for which there are insufficient data to determine designation status are denoted as 

4 “unclassifiable.” Areas meeting the standard or expected to be meeting the standard despite a 

5 lack of monitoring data are designated “unclassifiable/attainment”. Areas that were once in 

6 nonattainment, but are now in attainment, are called “maintenance” areas; these areas are 

7 under a 10-year monitoring plan to maintain the attainment designation status. States have 

8 primary responsibility for ensuring attainment and maintenance of the NAAQS. Under 

9 Section 110 of the CAA (42 U.S.C. 7410) and related provisions, states are to submit, for EPA 

10 approval, State Implementation Plans (SIPs) that provide for the timely attainment and 

11 maintenance of the NAAQS. Air quality designations are generally made at the county level. 

12 For the purposes of planning and maintaining ambient air quality with respect to the NAAQS, 

13 EPA has developed Air Quality Control Regions (AQCRs). AQCRs are intrastate or interstate 

14 areas that share a common airshed (40 CFR Part 81). The proposed facility site, Discovery 

15 Ridge, is located in Boone County which is part of the Northern Missouri Intrastate Air Quality 

16 Control Region (40 CFR 81.116). With regard to the NAAQS criteria pollutants, Boone County 

17 is designated as an unclassifiable/attainment area for all criteria pollutants (40 CFR 81.326). 

18 The nearest designated nonattainment areas to the proposed site are the following: 

19 Franklin County, Missouri: approximately 50 mi (80 km) from the proposed site. 

20 Franklin County is part of the Metropolitan St. Louis Interstate AQCR (40 CFR 81.18) 

21 and nonattainment for the 8-hr ozone (2008) NAAQS and PM2.5 (1997) NAAQS, and
Affected Environment

3-14

1 St. Charles County, Missouri: approximately 70 mi (113 km) from the proposed site. 

2 St. Charles County is part of the Metropolitan St. Louis Interstate AQCR 

3 (40 CFR 81.18) and nonattainment for PM2.5.

4 The EPA promulgated the Regional Haze Rule (RHR) to improve and protect visibility in 

5 national parks and wilderness areas from haze, which is caused by numerous, diverse sources 

6 located across a broad region (40 CFR 51.308-309). Specifically, 40 CFR Part 81 Subpart D 

7 lists mandatory Class I Federal Areas where visibility is an important value. The RHR requires 

8 states to develop SIPs to reduce visibility impairment at Class I Federal Areas. The nearest 

9 Class I Federal Area to the proposed site is the Hercules-Glades Wilderness Area, 

10 approximately 138 mi (222 km) away.

11 Table 3–4 provides annual emissions of criteria pollutants and carbon dioxide for Boone County. 

12 These emissions include both stationary and mobile sources.

13 Table 3–4. Boone County Air Emissions Inventory, Tons/Year

CO NOx SO2 PM10 PM2.5 CO2

26,638 7,702 7,024 12,699 2,260 1,128,841

Key: CO = carbon monoxide; NOx = nitrous oxide; SO2 = sulfur dioxide; PM10 = particulate matter of 10 μm or 

less; PM2.5 = particulate matter 2.5 μm or less; CO2 = carbon dioxide.

Note: to convert tons/year to metric tons/year, multiply by 0.90718

Source: EPA 2011 

14 The General Conformity Rule, established under Section 176(c)(4) of the CAA, ensures that 

15 Federal actions conform to SIPs. The Federal agency must conduct a conformity analysis if the 

16 proposed action is in a designated nonattainment or maintenance area with respect to NAAQS 

17 and would result in the generation of air emissions that would exceed conformity threshold 

18 levels of pollutants (de minimis thresholds). Because the proposed NWMI facility would be 

19 located in a designated unclassifiable/attainment area, a conformity analysis is not required.

20 Regulations 

21 New facilities that emit air pollutants could be subject to Federal requirements, depending on 

22 the location and the type and amount of emitted air pollution. The following discussions 

23 summarize these requirements. The MDNR is authorized by the EPA to administer air pollutant 

24 emission permits. NWMI may be required to obtain construction and operation permits in 

25 accordance with in Title 10 of Missouri’s CSR.

26 New Source Review Program

27 Construction of a new air pollution source is subject to the New Source Review program. 

28 Sources classified as major sources (as defined in 40 CFR 51.165, 40 CFR 51.166, and 

29 40 CFR 52.21) and located in attainment areas are required to obtain a prevention of significant 

30 deterioration (PSD) permit. The purpose of the program is to prevent degradation of air quality 

31 in areas where air quality is good. New sources of criteria pollutants that are located in an 

32 attainment area that exceed 250 tons/year (TPY) emission rate of any criteria pollutant are 

33 subject to the permit program and are considered a major source. Further, emissions that 

34 exceed de minimis levels are considered significant (40 CFR 51.166) and for the purposes of 

35 the NRC staff’s air quality analysis, these thresholds will be considered in determining the 

36 significance of air quality impacts for construction. The de minimis rates are as follows: 
Affected Environment

3-15

1 100 TPY of carbon monoxide, 40 TPY of nitrogen oxides, 40 TPY of sulfur dioxide, 40 TPY of 

2 volatile organic compounds (ozone precursor), 15 TPY of particulate matter less than 

3 10 microns, and 10 TPY of particulate matter less than 2.5 microns (40 CFR 51.166; 

4 10 CSR 10-6.020). New Source Review requirements are implemented in Title 10 of Missouri’s 

5 CSR (10 CSR 10-6.060).

6 Title V of the Clean Air Act

7 Title V of the CAA (42 U.S.C. 7661–7661f) requires a Federally enforceable operating permit 

8 program that applies to large, new, and existing sources of air pollution. Any facility with the 

9 potential to emit 100 TPY or more of any criteria pollutant, 10 TPY of any hazardous air 

10 pollutant (HAP), or 25 TPY of all HAPs combined is required to obtain a valid Title V permit and 

11 is considered a major air source (40 CFR Part 70). For purposes of the NRC staff’s air quality 

12 analysis, the 100 TPY of any criteria pollutant threshold for a Title V operation permit will be 

13 considered in determining the significance of air quality impacts for operation. Title V 

14 requirements are implemented in Title 10 of Missouri’s CSR (10 CSR 10-6.065).

15 Greenhouse Gas Tailoring Rule

16 Gaseous chemicals that trap heat in the atmosphere are known as greenhouse gases (GHGs). 

17 The most common GHGs are carbon dioxide, methane, and nitrous oxide. These pollutants are 

18 emitted from natural processes and human activities. 

19 On September 22, 2009, the EPA issued a final rule for mandatory GHG reporting from large 

20 GHG emission sources in the United States (74 FR 56260). The purpose of the GHG Tailoring 

21 Rule is to collect and use comprehensive and accurate data on carbon dioxide and other GHG 

22 emissions to inform future policy decisions. In general, the threshold for reporting is 

23 25,000 metric tons carbon dioxide equivalent (CO2eq) emissions per year, excluding 

24 mobile-source emissions. GHGs are grouped into a single, representative “pollutant” called 

25 CO2eq. CO2eq is a metric used to compare the emissions of GHG based on their global 

26 warming potential (GWP). GWP is a measure used to compare how much heat a GHG traps in 

27 the atmosphere. GWP is the total energy that a gas absorbs over a period of time compared to 

28 carbon dioxide. CO2eq is obtained by multiplying the amount of the GHG by the associated 

29 GWP. For example, the GWP of methane is estimated to be 21; therefore, 1 ton of methane 

30 emission is equivalent to 21 tons of carbon dioxide emissions.

31 On May 13, 2010, the EPA issued the GHG Tailoring Rule. This rule set the thresholds for a 

32 phase-in approach to regulating GHG emissions under the PSD and Title V permitting programs 

(75 FR 31514). Beginning on January 2, 2011,2 33 operating permits issued to major sources of 

34 GHG under the PSD or Title V Federal permit programs must contain provisions requiring the 

35 use of best available control technology to limit the emissions of GHGs, if those sources would 

36 be subject to PSD or Title V permitting requirements because of their non-GHG pollutant 

37 emission potentials and if their estimated GHG emissions are at least 75,000 TPY of CO2eq.

 2 On June 23, 2014, the U.S. Supreme Court issued a decision that EPA may not treat GHGs as an air pollutant for 

determining whether a source is a major source required to obtain a PSD or Title V permit but could continue to 

require PSD and Title V permits, which are otherwise required based on emissions of conventional pollutants. In 

July 2014, the EPA issued a memorandum in response to the Supreme Court’s decision and acknowledged that, 

although the decision is pending judicial action, the EPA will no longer require PSD or Title V permits for 

GHG-emitting sources that are not sources subject to PSD or Title V permits based on emissions of conventional 

pollutants (e.g., nitrogen oxides and, carbon monoxide) (EPA 2014a).
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1 3.2.3 Noise

2 Noise is often defined as unwanted sound and can be generated by many sources. Sound 

3 intensity is measured in logarithmic units called decibels (dB). A dB is the ratio of the measured 

4 sound pressure level to a reference level equal to a normal person’s threshold of hearing. 

5 Another characteristic of sound is frequency or pitch. Noise may be composed of many 

6 frequencies, but the human ear does not hear very low or very high frequencies. To represent 

7 noise as closely as possible to the noise levels people experience, sounds are measured using 

8 a frequency-weighting scheme known as the A-scale. Sound levels measured on this A-scale 

9 are given in units of A-weighted decibels (dBA). 

10 Table 3–5 presents common noise sources and their respective noise levels. A whisper is 

11 normally 30 dBA and is considered very quiet. Noise levels can become annoying at 80 dBA 

12 and very annoying at 90 dBA. Noise levels attenuate rapidly with distance. When distance is 

13 doubled from a point source, noise levels decrease by 6 dBA (FHWA 2011). Generally, a 

14 3-dBA change over existing noise levels is considered to be a “just noticeable” difference, a 

15 5-dBA increase is readily perceptible, and a 10-dBA increase is subjectively perceived as a 

16 doubling in loudness (FHWA 2011).

17 Table 3–5. Common Noise Sources and Noise Levels

Noise Source Noise Level (dBA)

Human hearing threshold 0

Soft whisper 30

Quiet residential area 40

Dishwasher 55–70

Lawn mower 65–95

Blender 80–90

Ambulance siren, jet plane 120

Source: CHC undated

18 Several different terms are commonly used to describe sounds that vary in intensity over time. 

19 The equivalent sound intensity level (Leq) represents the average sound intensity level over a 

20 specified interval, often 1 hr. The day-night sound intensity level (LDN) is a single value 

21 calculated from hourly Leq over a 24-hr period, with the addition of 10 dBA to sound levels from 

22 10 p.m. to 7 a.m. This addition accounts for the greater sensitivity of most people to nighttime 

23 noise. Statistical sound level (Ln) is the sound level that is exceeded “n” percent of the time 

24 during a given period. For example, L90, is the sound level exceeded 90 percent of time and is 

25 considered the background level.

26 Noise Regulations

There are no Federal regulations3 27 for public exposures to noise (EPA 2016e). The EPA 

28 recommends an average LDN of 55 dBA as guidelines or goals for outdoors in residential areas 

29 (EPA 1974). However, these are not standards. The Federal Housing Administration has 

 3 In 1972 Congress passed the Noise Control Act of 1972 establishing a national policy to promote an environment 

free of noise that impacts the health and welfare of the public. However, in 1982 there was a shift in Federal noise 

control policy to transfer the responsibility of regulation noise to state and local governments. The Noise Control 

Act of 1972 was never rescinded by Congress but remains unfunded (EPA 2016e).
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1 established noise assessment guidelines for housing projects and finds that an average LDN of 

2 65 dBA or less is acceptable (HUD 2014). Under the Noise Control Act of 1972 

3 (42 U.S.C. 4901 et seq.), the Occupational Safety and Health Administration established 

4 workplace standards for noise. The minimum requirement states that constant noise exposure 

5 must not exceed 90 dBA over an 8-hr period. The highest allowable sound level to which 

6 workers can be exposed is 115 dBA. Exposure to this level must not exceed 15 min within an 

7 8-hr period. If noise levels exceed these standards, employers are required to provide hearing 

8 protection equipment that reduces sound levels to acceptable limits (29 CFR 1910.95).

9 The City of Columbia has a noise ordinance that prohibits loud and unnecessary noise. The 

10 noise ordinance does not establish acceptable noise levels, but it does establish acceptable 

11 time frames for when activities can be conducted. For instance, site preparation activities 

12 associated with construction shall be conducted during the hours of 7:00 a.m. and 7:00 p.m. 

13 (City of Columbia 2016b). Furthermore, the Discovery Ridge Master Plan prohibits “excessive” 

14 noise in the Discovery Ridge Research Park (MU 2009) but does not define excessive noise or 

15 establish acceptable noise levels. 

16 Existing Noise Levels 

17 Existing noise sources near the proposed site include vehicular traffic along U.S. Highway 63, 

18 agricultural equipment, and HVAC systems associated with the nearby buildings (NWMI 2015a). 

19 Noise-sensitive receptors within 1 mi (1.6 km) of the proposed site include:

20 • a residence, approximately 0.27 mi (0.43 km) south of the proposed site;

21 • New Haven Elementary School, approximately 1 mi (1.6 km) north of the proposed 

22 site;

23 • Analytical Bio-Chemistry (ABC) Laboratories, approximately 0.3 mi (0.48 km) west of 

24 the proposed site; and

25 • IDEXX BioResearch facility (formerly known as Research Animal Diagnostic and 

26 Investigative Laboratory – RADIL), approximately 0.1 mi (0.16 km) northwest of the 

27 proposed site.

28 The NRC staff did not identify the existence of any ambient noise surveys for the Discovery 

29 Ridge Research Park. Surrounding land uses include agricultural activities. Typical noise 

30 levels from agricultural equipment at a 50 ft (15 m) distance are estimated to be 84 dBA 

31 (FHWA 2006). However, these noise levels are intermittent, when the equipment is in use. 

32 NWMI conducted a noise modeling study using the Federal Highway Administrations Traffic 

33 Noise Model 2.5 (NWMI 2016a, 2016d). Based on this model study, during peak traffic periods 

34 along U.S. Highway 63, noise levels at the nearest residence to the proposed Discovery Ridge 

35 site can reach 69 dBA. As discussed in Section 3.1.1.1, the Discovery Ridge Research Park is 

36 designated as an industrial certified site and it has commercial community features (City of 

37 Columbia 2016a). During non-peak traffic periods and when equipment noise is not in use, the 

38 NRC anticipates that Discovery Ridge Research Park ambient background levels are similar to 

39 that of commercial areas. Commercial area noise levels can range from 60 to 70 dBA 

40 (Miller 2002). Given that the Discovery Ridge Research Park is an emerging research park that 

41 currently has two research and laboratory and office facilities in operation, the NRC staff 

42 anticipates that current ambient background noise levels are 60 to 65 dBA.

43 3.3 Geologic Environment

44 The geologic environment of a location encompasses the physiographic or physical setting and 

45 the associated structural features of the Earth’s crust, geologic strata, and soils that comprise 
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1 the site. Geologic hazards are a condition of the geologic environment and include large-scale 

2 hazards such as geologic faulting and earthquakes that comprise a site’s seismologic setting as 

3 well as local hazards associated with the site-specific attributes of the soil and bedrock at a site.

4 3.3.1 Site Geology

5 The proposed NWMI facility site within the Discovery Ridge Research Park (Discovery Ridge 

6 site) is located at the southern edge of the Central Lowland physiographic province and just 

7 north of its boundary with the adjacent Ozark Plateaus province (NWMI 2015a; NPS 2015; 

8 Miller and Appel 1997; MDNR 2002a). The Missouri River in central Missouri marks the 

9 approximate boundary between the two provinces. The Central Lowland province is part of the 

10 greater Interior Plains physiographic division whereas the Interior Highlands physiographic 

11 division encompasses the Ozark Plateaus province. Physiographic or geomorphic provinces 

12 are regions with similar landforms and underlying geology. Provinces are further divided into 

13 physiographic sections.

14 More precisely, the Discovery Ridge site lies within the Dissected Till Plains section of the 

15 Central Lowland province (MDNR 2002a; USGS 2014a). Landforms within this section and of 

16 the Central Lowland province as a whole are generally flat to gently rolling (NPS 2015). Such 

17 low-relief landforms relate partly to the presence of mainly flat-lying rocks deposited primarily in 

18 marine and fluvial environments beginning in the Paleozoic Era, some 500 million years ago 

19 (Ma). These strata were then eroded during the Mesozoic, which ended about 66 Ma, down to 

20 the current bedrock surface consisting of Pennsylvanian-age strata (Miller and Appel 1997). 

21 The land surface was then subjected to glaciation during the early to mid-Pleistocene Epoch 

22 (i.e., Pre-Illinoian, prior to about 310,000 years before present). Unlike regions to the north and 

23 east, later glacial advances did not affect the Missouri region (Sharp 1984; Miller and 

24 Appel 1997). Modern drainage development including stream incision, alluvial deposition, and 

25 associated erosional processes further shaped the land surface, with these processes 

26 continuing into the present day.

27 As a result, the current land surface across undeveloped portions of the Dissected Till Plains of 

28 south-central Boone County exists as a moderately dissected, flat to rolling glacial plain that 

29 slopes toward the Missouri River valley (NWMI 2015a). Topography at the Discovery Ridge site 

30 mirrors this landform, where the site is generally flat to slightly rolling, with a slope generally to

31 the south and southwest (Terracon 2011a). This observation was confirmed during the NRC 

32 staff’s environmental site audit in September 2015 (NRC 2015b), when the site predominantly 

33 existed as an open grassland. Elevations across the site range from approximately 820 ft 

34 (250 m) mean sea level (MSL) in the northwestern corner to about 800 ft (244 m) in the 

35 southern corner (Figure 3–11).
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1 Figure 3–11. Topographic Map of the Discovery Ridge Site and Vicinity

2

3 Source: Modified from USGS 2015a

4 As indicated above, the surficial geology of Boone County is the product of glacial action and 

5 subsequent weathering and erosion. A mantle of glacial drift covers much of the County. 

6 Glacial drift consists of undifferentiated sediments deposited either directly by a glacier 

7 (i.e., glacial till) or by related glaciofluvial processes (e.g., meltwater stream outwash). These 

8 glacial deposits generally range in thickness from a few inches to more than 100 ft (30 m), 

9 particularly in areas of the County immediately north and east of the Missouri River. These 

10 materials generally consist of a yellowish clay till mixed with sand and pebbles. Deposits of 
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1 loess (windblown glacial sediment) are also widespread throughout the County, but the deposits 

2 are thickest along the bluffs of the Missouri River to the south of the site (BCC 1996).

3 Glacial drift generally covers the eastern half of Boone County whereas residuum (weathered 

4 bedrock material) is the predominant bedrock cover over the western half of the County. This 

5 generally supports the overburden mapping information provided in the NWMI ER

6 (NWMI 2015a). Specifically, the surficial geologic unit at the Discovery Ridge site is mapped as 

7 glacial drift (unit F). This unit is characterized as light tan to dark gray silty clay and clay till. 

8 The clay is mixed with pebbles of limestone, chert, and quartzite. Sands, cobbles, and boulders 

9 may occur in pockets, lenses, or as channel deposits. A layer of loess ranging from 1 to 5 ft 

10 (0.3 to 1.5 m) thick typically covers the drift. A clay-rich paleosol (i.e., a buried soil horizon) 

11 often occurs at depths ranging from 6 to 8 ft (1.8 to 2.4 m). In total, this unit ranges from 10 to 

12 300 ft (3-91 m) thick. However, based on bedrock contour mapping data derived from well logs, 

13 the total thickness of the drift and other overburden material in the vicinity of the Discovery 

14 Ridge site is approximately 25 ft (7.6 m) (MGS 2016).

15 Terracon, a consulting engineering firm, performed a preliminary geotechnical investigation of 

16 the Discovery Ridge Research Park in 2011, which encompassed the proposed site (i.e., Lot 15 

17 of the research park) (Terracon 2011a). The purpose of the investigation was to provide 

18 preliminary geotechnical recommendations concerning earthwork and the design and 

19 construction of foundations, floor slabs, and pavements for Discovery Ridge properties 

20 (NWMI 2015a).

21 Terracon drilled nine boreholes (designated B-1 through B-9) across the research park as part 

22 of the 2011 study. The borings were advanced to depths ranging from 13 to 20 ft (3.9 to 6.1 m) 

23 below ground surface (bgs). Laboratory tests were also conducted on select samples, including 

24 soil density, compaction, plasticity and liquid limit tests (NWMI 2015a; Terracon 2011a). All 

25 boring samples measured were found to have a relatively high water content, generally in the

26 range of 18 up to 35 percent (Terracon 2011a). For the surveyed areas as a whole, the boring 

27 logs indicate the presence of lean to fat clay and fat clay in the upper part and underlain by clay, 

28 trace sand, gravels, and cobbles representing glacial drift. Clay fill was encountered in the 

29 upper part of two borings completed at locations to the west of the Discovery Ridge site 

30 (i.e., borings B-3 and B-4 located west of Discovery Ridge Parkway). A single boring 

31 (designated B-5 in Terracon 2011a) drilled on the eastern boundary of Lot 15 is most 

32 representative of the proposed site. Table 3–6 summarizes information on the nature of the 

33 surficial materials obtained from this boring.

34 Table 3–6. Summary of Boring Log B-5 Completed in the Vicinity of the Proposed NWMI 

35 Facility Site, Discovery Ridge Research Park

Interval Depth, 

ft. (bgs)

USCS Class 

Symbol and 

Name Interval Description/Interpretation of Surficial Materials

0.3 – Topsoil

0.3 to 3 CL–Lean Clay Lean Clay: brown, trace gray, stiff

3 to 8 CH-Fat Clay Fat Clay: gray with red, stiff

8 to 12 CH–Fat Clay Fat Clay: reddish brown and light gray, trace sand and gravel, 

possible cobbles, very stiff (Glacial Drift)

Water level at 12 ft. bgs after boring completion

12 to 17 CL–Lean Clay, 

CH–Fat Clay

Sandy Lean to Fat Clay: reddish brown and light gray, trace gravel, 

possible cobbles, stiff (Glacial drift);

Water level at 16.5 ft. bgs while sampling
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Interval Depth, 

ft. (bgs)

USCS Class 

Symbol and 

Name Interval Description/Interpretation of Surficial Materials

17 to 20 

(bottom of 

boring)

CH–Fat Clay Fat Clay; reddish brown and light gray, trace sand and gravel, 

possible cobbles, very stiff (Glacial Drift)

Key: bgs = below ground surface; USCS = Unified Soil Classification System. 

Source: NRC staff interpretation of information in Terracon 2011a

1 As shown in Table 3–6, fat clays appear to comprise much of the surficial strata at the 

2 Discovery Ridge site. Fat clays include inorganic clay minerals of high plasticity. These 

3 materials characteristically have high compressibility, poor shear strength when wetted, and 

4 have generally poor workability as a construction material, including for use as structural 

5 (engineered) backfill (SCS 1990). Moreover, as indicated by Terracon and as referenced by 

6 NWMI in its ER, fat clays are termed expansive or swelling soils because they expand or swell 

7 with changes in moisture content (NWMI 2015a; Terracon 2011a). Such soils with a high 

8 shrink/swell potential can damage concrete and other structures with changes in moisture 

9 content and soil volume. Terracon determined that some of the soils encountered during drilling 

10 had moisture levels above their measured plastic limit. Such soils may be prone to rutting and 

11 pumping (rebound) when a load is applied, which results in unstable subgrade conditions during 

12 construction (Terracon 2011a). Nevertheless, Terracon made no determination about the 

13 liquefaction potential of these soil materials (NWMI 2015h).

14 Weathered bedrock (identified as limestone) was encountered in only two borings (B-6 and B-7) 

15 at depths of approximately 17 and 13 ft bgs (5.1 and 4.0 m) bgs, respectively. These boring 

16 sites are located approximately 1,000 ft (300 m) south of the proposed NWMI facility site 

17 (Lot 15, Discovery Ridge site) and toward the shallow valley traversed by Gans Creek.

18 While geotechnical investigations conducted to date have not determined the precise depth to 

19 or nature of bedrock beneath the proposed site, available mapping data indicate that the depth 

20 to bedrock is approximately 25 ft (7.6 m) (MGS 2016). Geologic mapping (Stoeser et al. 2007) 

21 reveals that rocks of the Cherokee Group of Pennsylvanian age (i.e., 299 to 318 Ma) 

22 immediately underlie the site. This is consistent with the geologic mapping provided in the 

23 NWMI ER (NWMI 2015a) and adapted as Figure 3–12.

24 Sediments comprising the Cherokee Group were mainly deposited in low-relief continental 

25 (terrestrial) to tidal environments that included river deltas, coastal plains, and swamps. Across 

26 central and eastern Missouri, deposition occurred on an eroded karst surface (i.e., atop 

27 carbonate bedrock subject to dissolution) (Thompson 1979). The geologic units comprising the 

28 recognized Cherokee Group are further divided into two subgroups, the Cabaniss and Krebs 

29 Subgroups. The Cabaniss Subgroup includes cyclically-deposited shale, sandstone, siltstone, 

30 clay, and limestone with seven coal beds. Cyclically-deposited rocks derive from sediments 

31 deposited in an often-repetitive pattern reflective of changes in the depositional environment 

32 from marine to continental and then back again. Rocks of the Cabaniss Subgroup attain a 

33 maximum thickness of 200 ft (60 m). Rocks of the lower Krebs Subgroup also include cyclic 

34 deposits that predominantly consist of shale and sandstone with limestone, as well as siltstone 

35 and two coal beds. The Krebs Subgroup attains a maximum thickness of 110 ft (34 m) 

36 (Stoeser et al. 2007). The bedrock immediately to the south along the Gans Creek valley and to 

37 the west of the site consists of Osagean Series rocks of Early Mississippian age (345 to 

38 359 Ma). Rock types are predominantly marine limestone with chert and minor dolostone and 
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3-22

1 shale. Recognized geologic units include the Keokuk and Burlington limestones, Elsey (Grand 

2 Falls) Formation, Reeds Spring Formation, and Fern Glen Formation (Stoeser et al. 2007; Miller 

3 and Appel 1997). The total thickness of the series is as much as 600 ft (180 m) 

4 (Stoeser et al. 2007). More recent (2014) geologic mapping completed by the Missouri 

5 Geological Survey (MGS) at 1:24000 scale shows that rocks immediately underlying the 

6 Discovery Ridge site are comprised of the Krebs Subgroup, described above, while bedrock 

7 immediately bordering and encroaching into the site from the south and farther to the west 

8 consists of Burlington-Keokuk limestone of Mississippian age (MGS 2016). The former 

9 observation is consistent with findings from geotechnical borings B-6 and B-7.

10 Burlington limestone is the principal limestone exposed in quarries, creek banks, and road cuts 

11 near and around Columbia. As referenced by NWMI (2015a), this limestone unit is relatively 

12 soluble and contains many caverns and passages indicative of karst terrane. Karst terrane is a 

13 landform underlain by soluble carbonate bedrock and characterized by the presence of springs, 

14 caves, and sinkholes.

15 Based on the results of its preliminary geotechnical report and available geological mapping of 

16 the area, Terracon concluded that there are no known caves or sinkholes within approximately 

17 1 mi (1.6 km) of the Discovery Ridge Research Park. Karst features are present to the west and 

18 southwest of the Discovery Ridge site, with the nearest sinkhole features lying approximately 

19 1.3 mi (2.1 km) southwest (MGS 2016). However, changes in site conditions, such as grading 

20 and drainage alteration, can result in sinkholes even in areas with no history of sinkhole 

21 development (Terracon 2011a).

22 Predominantly northwest-trending faulting and folding (e.g., anticlines, synclines and similar 

23 features) across the central and northeast Missouri region are mainly attributable to 

24 compressional tectonic stress associated with Ouachita belt mountain building and uplift during 

25 the Mississippian and Pennsylvanian Periods (Clendenin et al. 1989).

26 In the ER, NWMI identified the presence of one geologic fault structure within a 5-mi (8-km) 

27 radius of the Discovery Ridge site (NWMI 2015a). The Fox Hollow fault is a normal fault that 

28 fades into a monoclinal fold at its two ends. The northeast-striking fault terminates 

29 approximately 3 mi (4.8 km) south of the site. This fault reportedly exhibits a throw (vertical 

30 displacement) of approximately 120 ft (37 m) to the southwest with Mississippian-aged 

31 Chouteau Limestone beds faulted against Ordovician-aged Jefferson City Dolomite. No surface 

32 expression of this fault was noted during field surveys, and there is no evidence of recent 

33 activity or displacement of overlying strata. 
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1 Figure 3–12. Bedrock Geology of the Discovery Ridge Site and Vicinity 

2

3 Source: Modified from NWMI 2015a, 2015h

4 MGS-maintained mapping data for known structural features identify a set of several features as 

5 comprising the trace of the Fox Hollow fault and monocline. Traces of this feature run in a 

6 southerly direction for a total of 8.5 mi (13.6 km) before intersecting with and crossing a 

7 northwest-striking feature (Sapp monocline) at a point located about 10 mi (16 km) 

8 south-southwest of the site (MGS 2016).

9 Available information indicates that there has been no movement on this fault during the 

10 Holocene (i.e., during the last 11,700 years). Further, the structure is considered to be early 

11 Paleozoic in age and does not constitute an earthquake hazard (MU 2006). The NRC staff’s 

12 review of the USGS’s latest release of the Quaternary Fault and Fold Database found no record 
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1 of Quaternary faults or folds within a 50-mi (80-km) radius of the proposed site (USGS 2015b). 

2 Based on available information, the NRC staff does not consider the fault to be active at present 

3 or represent a “capable fault” as defined in Appendix A to 10 CFR Part 100, “Seismic and 

4 Geologic Siting Criteria for Nuclear Power Plants”.

5 Nevertheless, liquefaction features in the St. Louis area (St. Louis–Cape Girardeau features), 

6 located about 100 mi (160-km) east of the site, as well as the Wabash Valley liquefaction 

7 features further to the east in southern Illinois, indicate the presence of active and recurrent 

8 faulting and associated earthquake activity in the Holocene. Thus, these features indicate the 

9 likely presence of capable faults in the St. Louis–Cape Girardeau and Wabash Valley regions. 

10 More significantly, situated approximately 200 mi (320 km) southeast of the site at its closest 

11 point is the seismically active region associated with the Reelfoot scarp and New Madrid 

12 Seismic Zone (USGS 2015b; Crone and Wheeler 2000). Section 3.3.3 further describes the 

13 seismic setting, including earthquake risk, at the Discovery Ridge site.

14 Geologic resources, encompassing rock and mineral (fuel and nonfuel) resources, in the vicinity 

15 of the site have historically included limestone and refractory clay, as well as lead, zinc, and 

16 coal (Thompson 1979). Exposures of Burlington Limestone have been an important resource 

17 and serve as the host rock for lead and zinc deposits in the Tri-State mining district of Missouri, 

18 Kansas, and Oklahoma (NWMI 2015a). Northern Boone County encompasses major coal 

19 producing strata and southern Boone County has high-calcium limestone resources, as noted 

20 above. Sand and gravel deposits are also available throughout Boone County and surrounding 

21 counties in central Missouri from glacial and floodplain materials (MDNR 2001; USGS 2015c).

22 3.3.2 Soils

23 A preliminary geotechnical investigation of the Discovery Ridge Research Park found that site 

24 soils predominantly consist of lean to fat clay and fat clay, as further described in Section 3.3.1. 

25 Soil unit mapping by the NRCS identifies the majority of the Discovery Ridge site (75 percent) 

26 as Mexico silt loam, 1 to 4 percent slopes, eroded. This mapping unit generally comprises the 

27 middle interior of the site while the remaining four corner areas of the site are comprised of 

28 Armstrong loam, 5 to 9 percent slopes, eroded (NRCS 2016a).

29 The predominant Mexico soils are silty clay loams and silty clay whereas the Armstrong soils 

30 are clay loams and clays, with both typically found on hill slopes. Mexico soils are poorly 

31 drained soils that developed from loess (wind-deposited sediment) overlying pedisediment. 

32 Pedisediments are alluvial materials transported from upslope areas onto an eroded soil

33 surface. Armstrong soils are somewhat poorly drained materials that derive from loess deposits 

34 atop glacial till. Both soils have a low infiltration rate (due to clay) and a very high runoff rate as 

35 a result. The depth to the water table in these soils generally ranges from 6 to 36 in. (15 to 

36 91 cm) (NRCS 2016a).

37 As reflected in the preliminary geotechnical investigation conducted by Terracon (2011a) and as 

38 indicated in the NRCS characterizations presented above, soil conditions present a number of 

39 site development challenges. As a building site, the soils are rated as poorly suited for 

40 excavation work because of the depth to the saturated zone, high clay content, and instability of 

41 excavation walls. In addition, due to the presence of clays with a high/shrink swell potential, as 

42 previously discussed in Section 3.3.1, the soils are rated as very limited for constructing 

43 commercial buildings. Shrink/well potential and the relatively shallow depth to the zone of 

44 saturation adversely affect the ability of soils to support structural loads (e.g., building slabs, 

45 foundations, and pavement structures) without movement and also affect the workability of site 

46 soils during construction (NRCS 2016a). NWMI will conduct site-specific geotechnical and 
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1 hydrologic studies of the Discovery Ridge site (NWMI 2015c). These studies would help to 

2 support final facility design and construction planning.

3 Neither of the onsite soil mapping units are prime farmland or other important farmland soils as 

4 defined in the Farmland Protection Policy Act of 1981 and implementing regulations 

5 (7 CFR Parts 657, 658; NWMI 2015a).

6 3.3.3 Seismic Setting

7 As noted in Section 3.3.1, Northeast Missouri is located within the central stable region of the 

8 North American craton. The region has had a relatively gentle tectonic history since the 

9 beginning of the Paleozoic Era in contrast to adjoining regions (NRC 2014; Reed and 

10 Bush 2007; NWMI 2015h). More tectonically active areas that border northeast Missouri to the 

11 east and south include the Ozark Uplift, Mississippi Embayment, and the Ouachita Mountain 

12 System (Reed and Bush 2007). Across the stable continental region of the United States, most 

13 locations can go years without an earthquake strong enough for people to feel. In the central 

14 and eastern United States, people can feel earthquakes over a very wide area. For example, 

15 people can feel a magnitude 4.0 earthquake at locations as far as 60 mi (100 km) from its 

16 source (epicenter) and it may cause damage near its source. An earthquake with a magnitude 

17 of 5.5 can be felt as far away as 300 mi (500 km) from its source and can cause damage as far 

18 as 25 mi (40 km) away. Usually, the earthquakes that do occur in the eastern and central 

19 United States are not traceable to a mapped geologic fault.

20 Typical of the central United States, the Discovery Ridge site is located within one of the lower 

21 earthquake hazard areas in the conterminous United States (NWMI 2015a, 2015h). National 

22 seismic hazard data and mapping products maintained by the U.S. Geological Survey (USGS) 

23 indicate that earthquake sources in southeast Missouri, associated with the New Madrid 

24 Seismic Zone, are the primary driver of earthquake hazard in northeast Missouri 

25 (Petersen et al. 2015).

26 The New Madrid Seismic Zone is associated with reactivated faults that originally formed when 

27 North America began to split or rift apart in Cambrian or late pre-Cambrian time (approximately 

28 500 Ma). While rifting ceased, a zone of structural weakness was created, known as the 

29 Reelfoot rift (NWMI 2015a, 2015h). The mapped extent of this zone runs for approximately 

30 150 mi (240 km) southward from near Cairo, Illinois, through New Madrid and Caruthersville, 

31 Missouri, down through Blytheville, Arkansas, to Marked Tree, Arkansas (NWMI 2015a, 2015h; 

32 USGS 2014b). New Madrid was the center of the largest earthquakes ever recorded in the 

33 central and eastern United States. A series of earthquakes occurred around New Madrid, 

34 Missouri, in 1811–1812 and ranged in magnitude from about 7.0 to 7.5 (USGS 2014b, 2015d). 

35 On the Modified Mercalli Intensity (MMI) scale (USGS 2014c), the intensity of these 

36 earthquakes ranged from MMI XI to XII (very disastrous to catastrophic shaking) at the 

37 epicenter and were estimated to have produced shaking of up to MMI VII (capable of causing 

38 slight to moderate damage to structures) in central Missouri (USGS 2014b).

39 Consistent with the above characterization, and as delineated in Boone County’s Hazard 

40 Mitigation plan based on Missouri State Emergency Management Agency projections, Boone 

41 County lies within the MMI VII shaking intensity zone (“very strong” zone) from postulated 

42 earthquakes occurring in the New Madrid Seismic Zone. Additionally, projections made by the 

43 State Emergency Management Agency indicate that for the period 2002 to 2052, there is a 25 to 

44 40 percent probability of a magnitude 6.7 earthquake and a 7 to 10 percent probability of a 

45 magnitude 7.6 earthquake within the New Madrid Seismic Zone. These events could be 

46 expected to result in MMI VI (slight damage) to MMI VII (significant damage to poorly built 
Affected Environment

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1 structures) shaking intensities, respectively, across Boone County (NWMI 2015h; 

2 MMRPC 2015).

3 No earthquakes are known to have had epicenters within Boone County (MU 2006). Since 

4 1976, a total of 104 earthquakes with a magnitude equal to or greater than 2.5 have occurred 

5 within a radius of 200 mi (322 km) of the Discovery Ridge site. The vast majority of these 

6 earthquakes had epicenters more than 90 mi (140 km) to the east and south in association with 

7 the Wabash Valley and New Madrid seismic zones, respectively. The closest of these events 

8 occurred on July 31, 2005, near Tipton, Missouri, approximately 27 mi (43 km) southwest of the 

9 Discovery Ridge site. The earthquake had a magnitude of 3.3 and produced MMI III to IV (weak 

10 to light) shaking near the epicenter, but it was not generally felt north of the Missouri River into 

11 Boone County. Over the last 40 years, the largest earthquake in the region was a magnitude 

12 4.7 earthquake on September 26, 1990. This earthquake was centered south of Cape 

13 Girardeau near Kelso, Missouri, about 165 mi (265 km) southeast of the Discovery Ridge site. It 

14 produced MMI VI (strong) shaking near the epicenter and caused slight damage in Kelso, 

15 Chaffee and other nearby communities. This earthquake was widely felt in southeast Missouri 

16 as well as in parts of Arkansas, southern Indiana, western Kentucky, and into parts of 

17 Tennessee and Ohio, according to reports to the USGS (USGS 2016a).

18 USGS national seismic hazard data and mapping products specifically provide risk-informed 

19 information on probabilistic earthquake ground motions for various return periods. As noted by 

20 NWMI (NWMI 2015h), the probabilistic ground motion estimates and current state of 

21 geophysical knowledge used in seismic hazard mapping are applied to the seismic design 

22 provisions of governing building codes across the Nation, although the ground motions used for 

23 building design are not identical to those from the USGS seismic hazard maps. Nevertheless, 

24 the USGS probabilistic seismic hazard maps provide a quantitative assessment of relative 

25 seismic risk. USGS published its latest seismic hazard data and map updates in 2015 

26 (Petersen et al. 2015).

27 Based on the USGS’s latest seismic hazard mapping data (Petersen et al. 2015), the Discovery 

28 Ridge site lies within the fourth lowest hazard area with predicted peak ground accelerations of 

29 0.06 to 0.08 g (i.e., the force of acceleration relative to that of Earth’s gravity, g). For the 

30 corresponding response spectral accelerations (SA), the site falls within the 0.16 to 0.20 g 

31 contours for the 0.2-second SA and the 0.08 to 0.10 g contours for the 1.0-second SA. SA 

32 values reflect the response of structures to vibratory ground motion. These values all represent 

33 shaking from an earthquake with a 2-percent probability of exceedance (PE) in the next 

34 50 years (i.e., an earthquake with a 2,475-year return period). These values are based on a 

35 standard reference condition (firm rock), and ground motions on less competent rock or soil

36 would differ.

37 As documented in the preliminary safety analysis report, NWMI performed a preliminary seismic 

38 design analysis to assess the potential maximum earthquake ground motions for the Discovery 

39 Ridge site. Derived ground motion SAs were calculated for site-specific conditions (i.e., for a 

40 stiff soil profile (Site Class D)). For a 2-percent PE in 50 years, the analysis yielded maximum 

41 earthquake accelerations ranging from 0.341 g (0.2-second period SA) to 0.223 g (1.0-second 

42 period SA). The NRC staff will further evaluate the potential maximum earthquake and other 

43 seismic design considerations in the Safety Evaluation Report related to the NWMI construction 

44 permit application.

45 3.4 Water Resources

46 Water resources comprise all forms of surface water and groundwater occurring near a site. 

47 Surface water encompasses all water bodies that occur above the ground surface, including 
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1 rivers, streams, lakes, ponds, and other features, such as human-made reservoirs or other 

2 impoundments. Groundwater is water that is below the ground surface within a zone of 

3 saturation, with the uppermost groundwater surface comprising the water table. Aquifers are 

4 subsurface geologic formations capable of yielding a significant amount of groundwater to wells 

5 or springs. Lesser amounts of groundwater may also occur in areas above the saturated zone 

6 in the form of relatively small and isolated lenses or pockets of groundwater known as “perched” 

7 groundwater.

8 3.4.1 Surface Water

9 3.4.1.1 Surface Water Hydrology

10 The Missouri River is the dominant surface water body in Boone County. The Discovery Ridge 

11 site is located about 8 mi (13 km) northeast of the river at its closest point. A well-developed 

12 dendritic drainage pattern exists across much of Boone County. Surface waters in central and 

13 southern Boone County drain into the Missouri River through a number of tributaries, including

14 Bonne Femme, Cedar, Little Cedar, Hinkson, Jemerson, and Perche Creeks. Figure 3–13

15 shows the named tributaries within a 5-mi (8-km) radius of the Discovery Ridge site, including 

16 Bonne Femme, Clear, Little Bonne Femme, Little Cedar, and Hinkson Creeks. In addition, a 

17 large lake, Perry Phillips Lake, is located approximately 0.75 mi (1.2 km) west of the site but is 

18 not in the drainage area of the site (NWMI 2015a).

19 No natural surface water features (e.g., headwater tributaries to streams) originate on the 

20 proposed Discovery Ridge site. The Discovery Ridge site currently drains south and southwest 

21 towards the southwesterly flowing Gans Creek, located approximately 0.35 mi (0.56 km) south 

22 of the site at its closest point (see Figures 3–11 and 3–13). Based on observations made by the 

23 NRC staff during the environmental site audit in September 2015, most site drainage occurs as 

24 overland sheet flow across the site with some drainage conveyed to ditches that border an

25 access road associated with the future extension of Discovery Drive that would connect land 

26 parcels bordering the proposed site to the south. The NRC staff observed that these ditches 

27 convey runoff further southwest across Lot 9 of the Discovery Ridge Research Park via a 

28 meandering drainage way and toward an engineered drainage channel that parallels 

29 U.S. Highway 63.

30 This channel ultimately discharges to Gans Creek south of the site. Topographic maps 

31 (USGS 2015a), historical photography, and other records reviewed by Terracon (2011a) 

32 indicate that at least some of these drainage features may mark the remnants of a headwater 

33 tributary to Gans Creek. Nevertheless, the engineered drainage channel receives runoff from 

34 surrounding parcels and drainage and overflow from an existing human-made lake (located to 

35 the northwest of the Discovery Ridge site and immediately adjacent to the existing IDEXX 

36 BioResearch facility), which serves as a stormwater management pond and has an associated 

37 drainage channel.
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1 Figure 3–13. Major Surface Water Features in the Vicinity of the Discovery Ridge Site

2

3 Source: Modified from NWMI 2015a

4 The lake was created by the University of Missouri R1 Dam. The lake is ultimately destined to 

5 serve various lots within the Discovery Ridge Research Park, as shown in construction maps for 

6 the research park (NWMI 2015a; MU 2009). This lake was originally constructed between 1948 

7 and 1959, as reported by Terracon (2011a) (see Figure 3–11). The lake covers about 20 ac 

8 (8 ha) (NWMI 2015a).

9 Additionally, there is another surface water feature just to the northeast of the NWMI facility site, 

10 a large farm pond (Figure 3–11). This pond was constructed in the headwaters area of a 

11 south-flowing ephemeral tributary to Gans Creek. The pond is estimated to be about 4 ac 

12 (0.4 ha) in size. The shallow tributary may receive overflow and seepage from the pond, but it is 

13 not affected by runoff from the Discovery Ridge site.
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1 Regardless, Gans Creek is the major surface water body in proximity to the Discovery Ridge 

2 site. This perennial to intermittent stream is located within the Bonne Femme (Creek) 

3 watershed, which is comprised of two major sub-watersheds: the Bonne Femme and the Little 

Bonne Femme. In total, the watershed drains approximately 93 square miles (mi2 4 ) (241 square 

kilometers (km2 5 )). The Discovery Ridge site lies within the northern portion of this 

6 watershed–Little Bonne Femme sub-watershed (Frueh 2007; NWMI 2015a).

7 From just south of the site (Figure 3–13), Gans Creek flows beneath U.S. Highway 63 and 

8 continues west to southwesterly in a winding path for approximately 6 stream mi (9.7 km) before 

9 joining Clear Creek. At this confluence, the Little Bonne Femme Creek begins. Little Bonne 

10 Femme Creek continues flowing southwesterly for some 9 mi (14 km) along a winding course 

11 before entering the Missouri River. Approximately 2 mi (3.2 km) south of the mouth of Little 

12 Bonne Femme Creek, Bonne Femme Creek discharges to the Missouri River (Frueh 2007; 

13 NWMI 2015a).

14 The Bonne Femme watershed is situated on karst terrane, as referenced in Section 3.3.1. 

15 Surface water hydrology is complex because of the presence of losing (sinking) and gaining 

16 sections of streams where surface water can easily enter the subsurface, providing flow to other 

17 streams. Karst streams, and underlying groundwater, are very susceptible to upgradient 

18 pollutant sources and contaminant transport. Within the watershed, there are two main 

19 recharge areas tied to these losing and gaining sections of stream, the Devil’s Icebox cave and 

20 the Hunter’s Cave recharge areas (Frueh 2007; NWMI 2015a). Carlson et al. (2005) states that 

21 Gans Creek is the first gaining stream due to surface water lost through the Devil’s Icebox cave. 

22 Thus, the Bonne Femme and Little Bonne Femme creeks are interconnected where surface 

23 water lost from Bonne Femme Creek is lost through the Devil’s Icebox Cave Branch (across the 

24 surface water divide) into Gans Creek and is eventually discharged to Little Bonne Femme 

25 Creek (Figure 3–13) (Frueh 2007; NWMI 2015a). None of the streams within the Bonne 

26 Femme watershed have active stream gaging stations. In general, streams within the 

27 watershed exhibit a low base flow with flow rising appreciably in response to precipitation events 

28 (Frueh 2007).

29 There are no floodplains on the Discovery Ridge site. The site and adjacent parcels are located 

30 within areas mapped as outside the 500-year flood elevation. The Federal Emergency 

31 Management Agency has delineated the floodplain boundary for Gans Creek. The Discovery 

32 Ridge site is located approximately 1,400 ft (425 m) north of the 100-year floodplain, and the 

33 base elevation of the site lies some 40 ft (15 m) above the floodplain (FEMA 2011a; 

34 NWMI 2015h). Therefore, the site is not readily subject to stream flooding.

35 3.4.1.2 Surface Water Quality and Use

36 Existing and proposed activities within a watershed are regulated under various provisions of 

37 the Federal Water Pollution Control Act (i.e., Clean Water Act of 1972, as amended (CWA) 

38 (42 U.S.C. 6901 et seq.)). Congress enacted the CWA with the goal of restoring and 

39 maintaining the chemical, physical, and biological integrity of the Nation’s surface waters.

40 In accordance with Section 303(c) of the CWA, States have the primary responsibility for 

41 establishing, reviewing, and revising water quality standards for the Nation’s navigable surface 

42 waters. Such standards include the designated uses of a water body or waterbody segment, 

43 the water quality criteria necessary to protect those designated uses, and an anti-degradation 

44 policy with respect to ambient water quality. As set forth under CWA Section 101(a), water 

45 quality standards are intended in part to provide for the protection and propagation of fish, 

46 shellfish, and wildlife and recreation in and on the water. The EPA retains a role in reviewing 

47 state-promulgated water quality standards to ensure that they meet the goals of the CWA and 

48 Federal water quality standards regulations (40 CFR Part 131).
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1 The State of Missouri, like other States, has established water quality standards, numeric 

2 criteria, and associated designated use categories for all waters of the State, including 

3 jurisdictional wetlands. Water quality standards provide a means by which attainment of water 

4 quality objectives can be measured. The objective is protection of designated uses through the 

5 application of narrative or numeric criteria. The level of protection given to a stream, lake, or 

6 river is dependent on the expected or “designated use(s)” of that water. The State frequently 

7 derives effluent limits contained in National Pollutant Discharge Elimination System (NPDES)

8 permits from water quality standards (MDNR 2016b). NPDES permits are issued in accordance 

9 with CWA Section 402. Streams, lakes, and rivers that have identified beneficial uses and have 

10 some water year round also have designated hydrologic classifications. Water quality 

11 standards, designated beneficial uses, and hydrologic classifications of waters of the State are 

12 specified in Title 10, Division 20, Chapter 7 of the Missouri Code of State Regulations.

13 Within the State, all perennial rivers and streams, streams with permanent pools, and lakes and 

14 reservoirs that intersect the flow lines of perennial rivers and streams are designated for the 

15 following beneficial uses: aquatic habitat protection; human health protection, whole body 

16 contact recreation, and secondary contact recreation; and livestock and wildlife protection and 

17 irrigation (10 CSR 20-7.031). These uses apply to Gans Creek and other major streams within 

18 a 5-mi (8-km) radius of the Discovery Ridge site. Furthermore, a 3 mi (4.8 km) section of Gans 

19 Creek is classified by the State as an Outstanding State Resource Water (10 CSR 20-7.031) 

20 and denoted as an environmentally sensitive area by Boone County (Boone County 2016a). 

21 Outstanding State resource waters are high-quality waters with a significant aesthetic, 

22 recreational, or scientific value and specifically designated as such by the State’s Clean Water 

23 Commission. Such waters may require exceptionally stringent water quality management 

24 requirements to assure conformance with the State’s antidegradation policy. This special 

25 segment of Gans Creek is located within the Rock Bridge State Park, located approximately 

26 3 mi (4.8 km) southwest of the Discovery Ridge site (see Figure 3–13).

27 From a hydrologic perspective, Little Bonne Femme and Bonne Femme Creeks and Hinkson 

28 Creek are Class P streams (i.e., streams that maintain permanent flow even in drought periods) 

29 (Boone County 2016a; MDNR 2015a). Gans Creek is a Class C stream, which is a stream that 

30 may cease flow in dry periods but maintain permanent pools that support aquatic life 

31 (MDNR 2015a).

32 CWA Section 303(d) requires States to identify all “impaired” waters for which effluent limitations 

33 and pollution control activities are not sufficient to attain water quality standards in such waters. 

34 Similarly, CWA Section 305(b) requires states to assess and report on the overall quality of 

35 waters in their state. States prepare a 303(d) “list” that comprises those water quality limited 

36 stream segments that require the development of total maximum daily loads (TMDLs) of 

37 pollutants to assure future compliance with water quality standards. The list also identifies the 

38 pollutant or stressor causing the impairment, and establishes a priority for developing a control 

39 plan to address the impairment. The TMDLs specify the maximum amount of a pollutant that a 

40 waterbody can receive and still meet water quality standards. Once established, States typically 

41 implement TMDLs through watershed-based programs, primarily through the NPDES permit 

42 program and associated point and nonpoint source water quality improvement plans and best 

43 management practices. States are required to update and resubmit their impaired waters list 

44 every 2 years. This process ensures that impaired waters continue to be monitored and 

45 assessed until applicable water quality standards are met.

46 Several of the streams within a 5-mi (8-km) radius of the Discovery Ridge site are either 

47 included in their entirety or have segments included in the State of Missouri’s 303(d) list 

48 (NWMI 2015a; MDNR 2014a, 2015a). In particular, Gans Creek continues to be listed as 

49 impaired due to water-borne E. coli bacteria. It was first listed in 2012. The reason for its listing 
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1 is impairment of the beneficial use for whole body contact recreation; the identified pollutant 

2 source is a rural nonpoint source runoff. Similarly, Little Bonne Femme and Bonne Femme 

3 Creeks are also listed as impaired due solely to E. coli. An extensive study to characterize the 

4 hydrologic and water quality characteristics of the Bonne Femme watershed, and further 

5 focusing on the karst areas of the watershed, was conducted between 2003 and 2007. The 

6 CWA Section 319 grant-funded effort was directed by a steering committee composed of 

7 members from local, State, and Federal agencies. The effort culminated in the development of 

8 a watershed plan for use as a tool for use in preventing further watershed degradation and 

9 maintenance of the long-term quality of water resources within the watershed (Frueh 2007).

10 Water quality studies conducted as part of the watershed investigation included establishing 

11 monitoring sites at a number of surface sub-watershed locations. Of particular relevance to the 

12 Discovery Ridge site, these included monitoring locations on Clear Creek, Gans Creek, Upper 

13 Bonne Femme Creek, Little Bonne Femme Creek, and at the two karst recharge areas including 

14 Devil’s Icebox cave. Samples were collected at all sites once per quarter beginning in 2003. In 

15 addition to measurement of standard physical and water quality parameters, samples were 

16 analyzed for various herbicides and for the presence of bacterial contamination. In summary, 

17 general water quality parameters were found to be typical for streams in carbonate bedrock 

18 areas. Dissolved oxygen levels exceeded the State standard of 5 milligrams per liter (mg/L). 

19 Nutrient levels were similar to or less than streams in other comparable agricultural watersheds, 

20 and there was no indication of acute contamination at any site. Although field observations and 

21 monitoring results revealed nuisance algal growth, no excess nutrient enrichment 

22 (eutrophication) was found at any site. One or more herbicides was detected at every site but 

23 generally at low levels. Widespread fecal bacterial contamination was evident, with the highest 

24 levels found during the spring and summer. The fecal bacteria standard for whole body contact 

25 was frequently exceeded. The primary cause of bacterial contamination at most sites was 

26 attributed to cattle grazing (Frueh 2007).

27 The NPDES permit program, as referenced above, addresses water pollution by regulating point 

28 sources (i.e., pipes, ditches) that discharge pollutants to waters of the United States 

29 (40 CFR Part 122; EPA 2016g). Regulated pollutant discharges include, but are not necessarily 

30 limited to, the discharge of facility wastewater and stormwater associated with construction or 

31 industrial activity at a site. NPDES permits set forth effluent limits on the discharge and also 

32 prescribe effluent monitoring, reporting, and other requirements to ensure that permit terms are 

33 being met. Regulated facilities may either require an individual NPDES permit or qualify for a 

34 general permit (i.e., a generic permit appropriate for covering a class of dischargers in a 

35 geographic area with similar characteristics) (EPA 2016g; MDNR 2016c). The State of Missouri 

36 is among the many states that have been authorized by EPA to perform many of the permitting, 

37 administrative, and enforcement aspects of the NPDES program, with EPA retaining oversight 

38 responsibilities (EPA 2016g). The State of Missouri was first authorized by EPA to assume 

39 NPDES permitting authority in 1974; it received general permit authority in 1985. The State of 

40 Missouri’s regulations for administering its NPDES permit program are contained in Title 10, 

41 Division 20, Chapter 6 of the Missouri CSR (10 CSR 20-6.010 and 10 CSR 20-6.200). In 

42 addition to State-administered NPDES permit requirements, local jurisdictions, including the 

43 City of Columbia, have additional requirements for site development, wastewater discharge, and 

44 stormwater management.

45 The discharge of wastewater to a municipal sanitary sewer system, as proposed by NWMI for 

46 the disposal of facility-generated wastewater, does not require an NPDES permit. A wastewater 

47 treatment plant (i.e., publicly owned treatment works (POTW)), where sanitary wastewater is 

48 ultimately treated, operates under its own NPDES permit. Wastewater collected by the City of 

49 Columbia’s sanitary sewer system is treated at the Columbia Regional Wastewater Treatment 
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1 Plant. The plant has a design treatment capacity of approximately 20 million gallons per day 

(mgd) (75,700 cubic meters/day (m3 2 /day)) (City of Columbia 2016c).

3 The introduction of wastewater to a POTW constitutes an “indirect discharge” that is excluded 

4 from the definition of “discharge of a pollutant” to waters of the United States (40 CFR 122.2). 

5 However, in accordance with CWA Section 307 and EPA’s pretreatment regulations 

6 (40 CFR Part 403), the discharge of pollutants from non-domestic (e.g., industrial) sources to 

7 such systems must meet local (municipal) acceptance criteria and other applicable 

8 requirements. This is to avoid interfering with the POTW in a manner that might result in a 

9 violation of the POTW’s NPDES permit and/or water quality standards (EPA 2015b). For this 

10 purpose, the City of Columbia Sanitary Sewer Utility that serves the Discovery Ridge site has 

11 specific regulations in the City’s Code of Ordinances (Chapter 22, Article VI, “Sewers and 

12 Sewage Disposal”) to address unlawful discharges, influent limits, and applicable pretreatment 

13 requirements (NWMI 2015a; City of Columbia 2015).

14 In addition, CWA Section 401 requires an applicant for a Federal license or permit to conduct 

15 any activities that may result in any discharge of regulated pollutants into navigable waters to 

16 provide the licensing agency with a water quality certification from the state in which the 

17 discharge would occur. This certification indicates that discharges from the project or facility to 

18 be licensed will comply with CWA requirements and will not cause or contribute to a violation of 

19 state water quality standards. If the applicant has not received Section 401 certification, the 

20 NRC cannot issue a license unless that state has otherwise waived the requirement. The State 

21 of Missouri’s regulations for administering its water quality certification program are contained in 

22 Title 10, Division 20, Chapter 6 of the Missouri CSR (10 CSR 20-6.060).

23 3.4.2 Groundwater

24 3.4.2.1 Site Description and Hydrogeology

25 The Discovery Ridge site is located within the Northeast Missouri Groundwater Province 

26 (MDNR 2016d). Groundwater beneath the proposed Discovery Ridge site and across Boone 

27 County occurs in unconsolidated and consolidated water-bearing deposits (aquifers). The 

28 following discusses the general hydrostratigraphy and other characteristics of these aquifers.

29 The USGS has broadly classified and grouped the distinct water-bearing geologic units 

30 (aquifers) that occur in northeast Missouri. These include the water-bearing sediments 

31 associated with the surficial aquifer system and two bedrock aquifer systems—the Mississippian 

32 aquifer system and the deeper Cambrian-Ordovician aquifer system (NWMI 2015a, 2016a; 

33 Miller and Appel 1997).

34 Across northeastern Missouri, the surficial aquifer consists mainly of stream-valley fill deposits. 

35 These deposits include narrow bands of fluvial and alluvial sediments lying within the valleys 

36 where rivers and streams have eroded shallow channels into glacial deposits. In southern 

37 Boone County, these materials are essentially limited to the Missouri River valley (Boone 

38 County Commission 1996; Miller and Appel 1997). Alluvial deposits consisting of sand and 

39 gravel underlying the floodplains of major rivers can yield large quantities of good-quality water. 

Yields as high as 2,000 gallons per minute (gpm) (7.6 cubic meters per minute (m3 40 /min)) are 

41 possible from properly constructed wells (MDNR 2016c).

42 The shallow glacial drift is not considered a suitable water source due to the limited thickness of 

43 the water-bearing strata, low storage, and vulnerability to contamination (MDNR 2016d). As 

44 described in Section 3.3.1, the combined thickness of glacial drift and other overburden at the 

45 Discovery Ridge site is approximately 25 ft (7.6 m). Groundwater occurring in these materials 

46 generally moves from areas of higher elevation to discharge points along streams.
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1 In northern Missouri, the Mississippian aquifer is the uppermost aquifer, with the overlying 

2 Pennsylvanian age strata not considered a major aquifer. The Mississippian aquifer extends 

3 over all of Missouri north of the Missouri River, except to the south near the Mississippi and the 

4 Missouri Rivers where the rocks that compose the aquifer have either been partially or 

5 completely removed by erosion. This aquifer encompasses Mississippian age carbonate rocks 

6 (principally limestones), including the Keokuk, Burlington, Fern Glen, Sedalia, and Chouteau 

7 limestone units (see Section 3.3.1). The Keokuk and the Burlington are the principal 

8 hydrogeologic units. Both units consist of crystalline limestone and yield water primarily from 

9 solution cavities (NWMI 2015a, 2016a; Miller and Appel 1997).

10 Carbonate rocks comprising the Mississippian aquifer in northeastern Missouri are 

11 stratigraphically equivalent to those of the uppermost aquifer (i.e., Springfield Plateau aquifer) of 

12 the Ozark Plateaus aquifer system that extends south from Boone County into southern 

13 Missouri. However, east of Boone County, Missouri, the two aquifers have little or no hydraulic 

14 connection (Miller and Appel 1997). Pennsylvania-age shale and sandstone generally overlies 

15 the Mississippian aquifer in most places, acting as a confining unit. A confining unit comprised 

16 of Mississippian-age shale underlies the aquifer in all locations (NWMI 2015a; Miller and 

17 Appel 1997). However, the Mississippian aquifer is reported as generally unconfined in the 

18 region of the Discovery Ridge site (NWMI 2016a).

19 Across central and northern Boone County, the units of the Mississippian aquifer average about 

20 200 ft (60 m) thick, but the thickness increases to the northwest and thins to the south as 

21 discussed above (Miller and Appel 1997; NWMI 2016a). A review conducted by NWMI of well 

22 logs from four wells within a 1-mi (1.6-km) radius of the site indicates that the total thickness of 

23 Mississippian age strata is about 240 ft (73 m) (NWMI 2016a).

24 Recharge of the uppermost aquifer units occurs primarily from precipitation over aquifer outcrop 

25 areas or infiltration and leakage down through the overburden and from the overlying glacial drift 

26 aquifers, where present. However, some recharge may also occur through vertical leakage 

27 from the underlying Cambrian-Ordovician aquifer system. The direction of groundwater flow in 

28 the uppermost aquifers beneath the County is generally to the south and southwest with 

29 discharge to major streams (Miller and Appel 1997).

30 The MDNR maintains extensive geospatial data sources on groundwater resources. This 

31 includes data extracted from well driller logs submitted to the State. Available MDNR data 

32 indicate that the static water level in the uppermost aquifer beneath the site ranges between 625 

33 and 650 ft (190 and 200 m) MSL (NWMI 2015a; 2016a; MGS 2016). For comparison, the 

34 mapped depth to groundwater (as measured from the land surface) in the area of the Discovery 

35 Ridge site ranges between 110 to 120 ft (34 to 37 m) bgs (MGS 2016).

36 The Cambrian-Ordovician aquifer system underlies the Mississippian system across the 

37 northeastern portion of Missouri north of the Missouri River and encompassing Boone County. 

38 Like the Mississippian aquifer, units within the Cambrian-Ordovician aquifer are stratigraphically 

39 equivalent to parts of the Ozark Plateaus aquifer system of southern Missouri. While a major 

40 water source across the Midwest as a whole, its use in northern Missouri is limited to eight 

41 counties just north of the Missouri River, including Boone County, where salinity levels are low 

42 enough to make the water potable (Miller and Appel 1997; Wilson 2012). In this eight-county 

43 area, this system is the principal water supply source (USGS 1985). In this eight-county area, 

44 the hydrogeologic flow system has been shown to be independent of the regional saline-water 

45 flow system in northern Missouri (Wilson 2012).

46 The hydrostratigraphy of the Cambrian-Ordovician aquifer system is principally comprised of 

47 carbonate rocks (limestones, dolomites) and sandstones of marine origin with shalely confining 

48 units. Significant water-bearing strata within the system, in descending order, include the 
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1 Roubidoux (sandstone) Formation and Gasconade Dolomite of Ordovician age and the 

2 Cambrian Eminence and Potosi Dolomites (Miller and Appel 1997). On a broader regional 

3 basis, the major aquifer zones are the sandstones, which are separated by leaking confining 

4 units comprised of dolomite, shale, shaley sandstone, or a combination of these types. Across 

5 northern Missouri, the aquifer is confined by the Ordovician age Maquoketa Shale 

6 (Wilson 2012).

7 Within the northeastern Missouri counties, the local aquifer is also referred to as the 

8 Kimmswick-Potosi aquifer. It is named for the Ordovician age Kimmswick Limestone and the 

9 Potosi Dolomite, which are the geologic units that mark its upper and lowermost extent in the 

10 subsurface (USGS 1985). These units are part of the recognized Cambrian-Ordovician aquifer 

11 system.

12 In total, the Cambrian-Ordovician aquifer system attains a thickness of up to 1,500 ft (460 m) 

13 below southern Boone County. Flow within the system is generally south with discharge to the 

14 Missouri River (Miller and Appel 1997).

15 NWMI reviewed historical well records for water supply, monitoring, and related well records 

16 within a 1-mi (1.6-km) radius of the site on file with the MDNR (NWMI 2016a). These records, 

17 for wells with total completion depths ranging from 505 to 1,250 ft (154 to 380 m), indicate a 

18 depth to groundwater in the aquifer ranging from about 180 to 325 ft bgs (NWMI 2016a; 

19 MDNR 2016e). Review of select well logs indicate that these wells are completed in and draw 

20 water from the Cambrian-Ordovician aquifer system. In general, wells completed in the 

Cambrian-Ordovician aquifer system yield from 15 up to 1,000 gpm (0.06 to 3.8 m3 21 /min) of 

22 water (USGS 1985). Similarly, MDNR (2002b) states that wells developed in the Mississippian 

23 age limestones and Ordovician and Cambrian age dolomites and sandstones of the 

Cambrian-Ordovician aquifer system can yield 15 to 500 gpm (0.06 to 1.9 m3 24 /min), with wells 

exceeding 1,000 gpm (3.8 m3 25 /min) including from the Columbia, Missouri area.

26 As part of the preliminary geotechnical investigation of the Discovery Ridge site and vicinity, 

27 Terracon (2011a) installed a number of soil borings in the glacial drift and uppermost bedrock 

28 (see Section 3.3.1). Terracon only observed groundwater in two of the borings at depths of 

29 approximately 12 to 18.5 ft (3.7 and 5.6 m) bgs. This included the one boring installed near the 

30 proposed NWMI facility site within Lot 15, where saturated conditions were encountered at a 

31 depth of 12 ft (3.7 m) bgs (Terracon 2011a). Nevertheless, Terracon indicated that the borehole 

32 observations made for the presence of groundwater may have been affected by the low 

33 permeability of the surficial materials. The low permeability soils may not have allowed water, 

34 even if present, to flow into all the boreholes during the relatively short period of time they were 

35 left open for observation. As referenced by Terracon (2011b), pockets and lenses of more 

36 permeable and water-bearing glacial materials occur in the vicinity of the site, leading to 

37 “perched” groundwater. NWMI has indicated that given the high water content of the site soils 

38 at the time the borings were completed, the “groundwater” observed in the boring holes may 

39 have been the result of water introduced into the holes during drilling operations (NWMI 2016a).

40 Furthermore, only two of the borings were advanced far enough to bedrock, at depths of 

41 approximately 17 and 13 ft (5.1 and 4.0 m) bgs. No groundwater monitoring wells have been 

42 installed on the site to determine the static water table elevation or the depth to groundwater in 

43 the uppermost bedrock aquifer beneath the Discovery Ridge site. Overall, the NRC staff 

44 considers Terracon’s observations and assessments reasonable and that the available data 

45 suggest that any lenses or pockets of perched groundwater underlying the Discovery Ridge site 

46 are likely to be of limited lateral and horizontal extent. 
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1 3.4.2.2 Groundwater Quality and Use

2 Boone County’s groundwater resources are characterized as large in volume and of high quality 

3 (Boone County Commission 1996). The County’s public water supply systems obtain nearly all 

4 of its potable water from groundwater via deep wells. Across northern Missouri, water from the 

5 Cambrian-Ordovician aquifer system ranges from fresh to saline but is generally of good quality 

6 in a band parallel to and north of the Missouri River from Boone County and east to the 

7 Mississippi River.

8 Within Boone County, groundwater is principally supplied from two aquifer units, the Roubidoux 

9 and the Gunter Member (Boone County Commission 1996). The Roubidoux Formation and 

10 Gunter Sandstone Member of the Van Buren Formation are aquifer units within the 

11 Cambrian-Ordovician aquifer system. It should be noted, however, that production wells in 

12 large aquifer systems typically draw from more than a single hydrostratigraphic unit. Across 

13 Boone County, the concentration of total dissolved solids from the aquifer is approximately 

14 500 mg/L (Miller and Appel 1997). Groundwater produced across northeastern Missouri from 

15 Cambrian-Ordovician strata is generally of the calcium magnesium, bicarbonate-type and hard 

16 to very hard (USGS 1985). Hardness is generally the result of high concentrations of calcium 

17 and magnesium.

18 Five separate water districts produce and distribute potable water to the majority of Boone 

19 County (Boone County 2013). The districts operate as independent public utilities, regulated by 

20 the State of Missouri. These districts were originally formed for the purposes of meeting the 

21 needs of rural populations and of agriculture (Boone County Commission 1996). The Discovery 

22 Ridge site lies within the service area of Consolidated Public Water Supply District No. 1, and it 

23 would supply water to the proposed NWMI facility site (NWMI 2015a, 2016a). This district 

24 serves most of the southern and western portions of the County but has interconnections with 

25 adjoining districts, including the City of Columbia, for contingency purposes. A system of 

26 13 deep wells supply the district. The system has a total groundwater production capacity of 

11 mgd (49,200 m3 27 /day) (NWMI 2015a; CPWSD 2016).

28 Groundwater is used extensively and almost exclusively across Boone County for a wide range 

29 of purposes, as summarized in Table 3–7.

30 Table 3–7. Groundwater Use in Boone County, 2010

Category Volume (mgd)

Public supply 15.89

Domestic, self-supplied 0.11

Industrial, self-supplied 0.02

Thermoelectric power, self-supplied 0.88

Mining, self-supplied 0.21

Livestock, self-supplied 0.11

Irrigation, self-supplied 0.99

Total 18.21

Note: To convert from million gallons per day to cubic meters per day, multiply by 3785.4.

Source: USGS 2016b.
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1 In summary, for 2010, groundwater production for public water supply accounted for the largest 

use by volume in Boone County at 15.89 mgd (60,150 m3 2 /day). Water to meet irrigation and 

3 thermoelectric power generation needs constitute the next largest water use categories in the 

4 County.

5 As previously discussed (Section 3.4.2.1), NWMI compiled a list of water supply and other wells 

6 within a 1-mi (1.6-km) radius of the Discovery Ridge site based on information sources 

7 maintained by the MDNR. The NRC staff reviewed the information provided by NWMI 

8 (NWMI 2016a) and other available information. Based on this review, the closest domestic 

9 supply well identified (well no. 394516) is located approximately 0.7 mi (1.1 km) northeast of the 

10 site (MGS 2016). The University of Missouri Thomas Jefferson Agricultural Institute is the 

11 registered owner (MDNR 2016f). This well was installed in October 2006 to a depth of 766 ft 

12 (233 m). It has a cased diameter of 6.25 in. (15.9 cm). Well logs for the area indicate that this 

13 depth corresponds to the Ordovician age Jefferson City Dolomite and Roubidoux Formations. 

The log indicates a static water level of 200 ft (60 m) bgs and a yield of 120 gpm (0.45 m3 14 /min) 

15 at installation (MGS 2016; MDNR 2016f). This well is hydraulically upgradient of the Discovery 

16 Ridge site as the direction of regional groundwater flow is generally from north to south.

17 A public water supply well (well no. 400126) is located approximately 0.8 mi (1.3 km) south, 

18 southeast of the Discovery Ridge site (MGS 2016). Consolidated Public Water Supply District 

19 No. 1 is the registered owner (MDNR 2016f). This well is a reconstruction (i.e., refurbishment 

20 and/or modification) of a well (well no. 24126) originally drilled in December 1965. 

21 Reconstruction was completed on September 20, 2008, and involved deepening the well to 

22 1,475 ft (450 m) further into the Cambrian strata. It has a cased diameter of 12 in. (30.5 cm). 

23 The completion log indicates a static water level of 280 ft (85 m) bgs and a yield of 600 gpm 

(2.3 m3 24 /min) at installation (MGS 2016; MDNR 2016f).

25 The nearest well identified by NWMI is reportedly located approximately 0.3 mi (0.48 km) 

26 west-northwest of the Discovery Ridge site (NWMI 2016a). The location mapped by NWMI 

27 places it proximal to Lot 6 of the Discovery Ridge Research Park and near the existing ABC 

28 Laboratories facility; this approximate location matches other well records that the NRC staff 

29 reviewed (MGS 2016). This well (well no. 013947) was drilled in 1955 and owned by the 

30 University of Missouri. It was drilled to a depth of 587 ft (179 m) with a static water level of 

31 270 ft (82 m) bgs at completion (NWMI 2016a). A well log that the NRC staff reviewed indicates 

32 that the well was located on the Bradford dairy farm (MGS 2016).

33 Terracon (2011b) discussed the possible existence of a water well in the above cited area as 

34 documented in the 2011 Phase I environmental site assessment report that was prepared for

35 the Discovery Ridge Research Park. In the Phase I report, the location of the well is attributed 

36 to the USDA Field Research Building, which lies in Lot 4. As described in the ER, the University 

37 of Missouri’s Bradford Research and Extension Center encompasses a research farm that 

38 provides land, equipment, and facilities to assist university and USDA scientists and extension 

39 personnel in performing research (NWMI 2015a). This information collectively suggests that the 

40 water well in question was associated with the original Bradford farm.

41 The NRC staff’s opinion is that the well could possibly have been in areas impacted by 

42 construction of Discovery Drive and Discovery Ridge Parkway, or by construction of the ABC 

43 Laboratories facility. Terracon reported that it did not locate the well during its site 

44 reconnaissance as part of the Phase I assessment. However, as stated by Terracon in the 

45 Phase I report (Terracon 2011b), the well, if still in existence and not used, should be located 

46 and properly abandoned in accordance with MDNR standards.
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1 3.5 Ecological Resources

2 3.5.1 Ecoregion

3 The proposed Discovery Ridge site is located within the north-central portion of the Ozark 

Highlands ecoregion, which is 108,322 km2 (41,823 mi2 4 ) (Karstensen 2010; USGS 2015e). 

5 Diverse topography, geologic, soil and hydrological condition have created a wide range of 

6 habitat types, including woodlands, forests, wetlands, fluvial features, hills, caves, deep valleys, 

7 and various rocks outcrops. Aquatic habitats include rivers, meandering streams, tributaries, 

8 seeps, and springs (MDNR 2008). These diverse and unique habitats support a number of 

9 plant and animal species, including 200 species largely restricted to the Ozark Highlands, of 

10 which 160 species only occur within the Ozark Highlands (USGS 2009).

11 Historically, this region primarily consisted of woodlands, forests, prairie grasslands, savannas, 

12 and wetlands (Epperson 1992; Nigh and Schroeder 2002). Beginning with European 

13 settlement, the majority of grasslands and wetlands were converted to agricultural lands for 

14 farming and pastures (Nigh and Schroeder 2002). In the late 1880s through 1960, the amount 

15 of hickory oak forest decreased as a result of the timber industry. Afterwards, the percent forest 

16 cover continued to decline as forests were converted to agricultural lands for pasture and row 

17 crops. Upland grasslands and valley bottoms were also converted to agricultural lands for 

18 pasture and row crops during this period (Karstensen 2010). From 1973 through 2000, 

19 2.4 percent of forests in the ecoregion were converted to agricultural lands and approximately 

20 1 percent was mechanically disturbed (Karstensen 2010). During this same period, 

21 approximately 1 percent of agricultural lands were converted to grasslands, in part due to the 

22 Conservation Reserve Program, which offered financial incentives for farmers to suspend 

23 agricultural activities and convert the land to native grasslands or forests (Johnson and 

24 Maxwell 2001). Dahl (1990) determined that 87 percent of Missouri’s original 1.9 million ha 

25 (4.8 million ac) of wetlands have been converted to other land uses, such as agriculture 

26 (87 percent), urban development (8 percent) and other development (5 percent). The 

27 conversion of forest and wetlands to agricultural fields has resulted in the decline of many 

28 biological species that depend on large tracts of undisturbed complex, natural habitats, and 

29 native species for prey, shelter, and breeding. Species that can survive in low-quality 

30 human-modified habitats, such as agricultural fields and developed areas, have generally 

31 increased over the past few centuries.

32 In 2000, the primary undeveloped land cover that provided habitat within the ecoregion included 

33 forests (56 percent), agricultural lands (37 percent), open water (1 percent), and wetlands (less 

34 than 1 percent) (Karstensen 2010). Developed land accounted for 2.1 percent of the ecoregion.

35 3.5.2 Habitats in the Vicinity of the Proposed Site

36 Within the vicinity, or a 5-mi (8-km) radius, of the proposed Discovery Ridge site, most of the 

37 area (39 percent) is used for agricultural purposes (see Table 3-1). Vegetation and wildlife

38 within agricultural fields surrounding the proposed site are likely to be similar to those found at 

39 the proposed site (see Section 3.5.3). This section also describes other types of habitats—

40 forests, grasslands, wetlands, and aquatic—within a 5-mi (8-km) radius of the proposed site. In 

41 addition, several communities of concern occur within the vicinity of the site (USDA 2016b; 

42 NWMI 2015a) and are highlighted below. MDC (2016b) defines these areas as high-quality 

43 ecological communities with intact tracts of habitat containing a diverse assemblage of native 

44 species. MDC (2016b) classifies each community as critically imperiled, imperiled, or 

45 vulnerable based on criteria such as total number of occurrences, total acres, number of 
Affected Environment

3-38

1 counties in which the community type occurs, number of protected occurrences, and threats to 

2 the community, as defined below:

3 • Critically Imperiled: Extremely rare or some factor(s) such as very steep declines 

4 making it especially vulnerable to extirpation from the State.

5 • Imperiled: Rare due to very restricted range, very few populations or occurrences, 

6 steep declines, or other factors making it very vulnerable to extirpation from the 

7 State.

8 • Vulnerable: Restricted range, relatively few populations or occurrences, recent and 

9 widespread declines, or other factors making it vulnerable to extirpation.

10 Forested Habitats

11 Forests cover 33 percent of the area within a 5-mi (8-km) radius of the proposed Discovery 

12 Ridge site (NWMI 2015a). Typical forests are primarily deciduous forests that include white oak 

13 (Quercus alba) forests, oak dry woodlands, black oak (Quercus velutina) woodlands, oak 

14 savannas, and sugar maple (Acer saccharum) mesic forests (Nigh and Schroeder 2002; 

15 NWMI 2015a). Evergreen forests and mixed forests are less common, but they also occur 

16 within the vicinity. Historically, forests covered a larger portion of the area; however, many of 

17 the forests have been converted into agricultural fields (Karstensen 2010). Remaining forested 

18 tracts, especially in riparian areas, provide important habitat for wildlife and birds. Many 

19 neotropical migrating birds use forested riparian habitats for resting, foraging, and providing 

20 refuge from predators. Two forested communities of concern occur within the vicinity:

21 • White oak forests (imperiled)—White oak forests generally occur on relatively steep 

22 slopes, from the valley bottoms to ridge tops, above river corridors. Hardwood trees 

23 comprise a well-developed forest canopy and subcanopy dominated by a mixture of 

24 white oak, sugar maple, pawpaw (Asimina triloba), and other hardwoods (USDA 2016b). 

25 Common shrubs and forb species include fragrant sumac (Rhus aromatic), wild blue 

26 phlox (Phlox divaricata), and woodnettle (Laportea canadensis) (USDA, 2016b). 

27 Common wildlife species include white-tailed deer (Odocoileus virginianus), great 

28 crested flycatcher (Myiarchus crinitus), and ringed salamander (Ambystoma annulatum) 

29 (MDC 2010).

30 • Mixed oak loess/glacial till woodlands (imperiled)—The mixed oak loess/glacial till 

31 woodlands generally occur adjacent to the Missouri River floodplains on upland summit 

32 crests. White, black, and post oak (Quercus stellate) trees comprise a well-developed 

33 forest canopy. Common shrubs and forbs include American hazelnut (Corylus 

34 Americana), elm-leafed goldenrod (Solidago ulmifolia), and smooth blue aster (Aster 

35 laevis). Common wildlife species include wild turkey (Meleagris gallopavo), red-headed 

36 woodpecker (Melanerpes erythrocephalus), and tiger salamander (Ambystoma tigrinum) 

37 (MDC 2010; USDA 2016b).

38 As described in Section 3.1.1.3, the Rock Bridge State Memorial Park is within 5 mi (8 km) of 

39 the Discovery Ridge site. This park consists of karsts, grasslands, and oak woodlands and 

40 forests and also contains the Gans Creek Wild Area (MDNR 2016a). The park provides habitat

41 to a variety of vegetation, birds, and wildlife, including bats that may occur within the Devil’s 

42 Icebox cave (NRC 2016j). 

43 Grasslands

44 Grasslands cover less than 1 percent of the area within a 5-mi (8-km) radius of the proposed 

45 site (NWMI 2015a). Since the arrival of European settlers, agricultural activities converted the 

46 majority of native grasslands into cultivated croplands or pastures. The remaining areas of 
Affected Environment

3-39

1 native grasslands are typically small and disconnected from other patches of native grasslands 

2 (Nigh and Schroeder 2002). These small patches provide lower quality habitat than larger 

3 connected tracts of grasslands. Predation, for example, is usually higher along the edge of a 

4 patch of prairie than at the center of a large continuous patch of prairie, which is likely because 

5 prey are more visible and have fewer places to hide from predators along the edge of a patch. 

6 Remaining tracts of native grasslands provide an important habitat for wildlife and birds. For 

7 example, many birds require grassland habitats for courtship, nesting, foraging, rearing young, 

8 roosting, or resting.

9 The NRC staff notes that cultivated grasses, such as corn and wheat, or pastures with 

10 non-native species are sometimes considered grasslands. Because native grasses are 

11 relatively rare in the area and native grasses provide substantially higher quality habitat than 

12 cultivated grasses or pastures, the NRC staff classified cultivated grasses and pastures as 

13 agricultural lands in this environmental impact statement (EIS).

14 One grassland community of concern occurs within the vicinity:

15 • Loess/glacial till prairies (critically imperiled)—These prairie communities generally 

16 occur in areas of low relief with low slope gradients and narrow drainages. Tall grass 

17 prairies are primarily comprised of little bluestem (Schizachyrium scoparium), Indian 

18 grass (Sorghastrum nutans), and sideoats grama (Bouteloua curtipendula). Small 

19 groves of post oak, American hazelnut (Corylus Americana), and prairie willow (Salix 

20 humilis) occasionally occur within the prairies. Common shrubs and forbs include 

21 lead plant (Amorpha canescens) and purple prairie clover (Dalea purpurea). 

22 Common wildlife species include white-tailed deer (Odocoileus virginianus), upland 

23 sandpiper (Bartramia longicauda), and western slender glass lizard (Ophisaurus 

24 attenuates) (USDA 2016b).

25 Wetlands

26 Forest/shrub wetlands and freshwater emergent wetlands cover less than 1 percent of the area 

27 within a 5-mi (8-km) radius of the proposed site (NWMI 2015a). Wetlands provide an important, 

28 high-value habitat for both terrestrial and aquatic resources. Migrating birds often use wetland 

29 sites for feeding and resting. Areas of open water provide an important nursery ground for 

30 many developing amphibians (e.g., frogs and salamanders), reptiles (e.g., turtles), and fish. 

31 One wetland community of concern occurs within the vicinity:

32 • Emergent wetlands and shrub swamps (Imperiled)—For emergent wetlands, 

33 common plant species include cattails (Typhaceae latifolia), bulrushes 

34 (Schoenoplectus spp), and sedges (Cyperaceae spp); and common wildlife species 

35 include bitterns (Botaurus lentiginosus), pied-billed grebes (podilymbus podiceps), 

36 and muskrats (Ondatra zibethicus). Shrub swamps are wetland thickets with 

37 buttonbush (Cephalanthus occidentalis) and willows (Salix spp). Common wildlife 

38 species include yellow warblers (Dendroica petechia) and green herons (Butorides 

39 virescens) (Leahy 2010; MDC 2016b, 2016c).

40 Aquatic Habitats

41 Areas of open water, or aquatic habitats, cover 1.5 percent of the area within a 5-mi (8-km) 

42 radius of the proposed site (NWMI 2015a). As described in Section 3.4.1, the proposed 

43 Discovery Ridge site currently drains south and southwest toward the southwesterly flowing 

44 Gans Creek, located approximately 0.35 mi (0.56 km) south of the site at its closest point (see 

45 Figures 3–11 and 3–13). Gans Creek is the major water body that provides aquatic habitat in 

46 proximity to the Discovery Ridge site. This perennial to intermittent stream is located within the 

47 Bonne Femme (Creek) watershed, and the proposed site lies within the northern portion of this 
Affected Environment

3-40

1 watershed, the Little Bonne Femme sub-watershed (Frueh 2007; NWMI 2015a). From just 

2 south of the site (Figure 3–13), Gans Creek flows beneath U.S. Highway 63 and continues west 

3 to southwesterly in a winding path for approximately 6 stream mi (9.7 km) before joining Clear 

4 Creek. Little Bonne Femme Creek begins at this confluence. Little Bonne Femme Creek 

5 continues flowing southwesterly for some 9 mi (14 km) along a winding course before entering 

6 the Missouri River. Approximately 2 mi (3.2 km) south of the mouth of Little Bonne Femme 

7 Creek, Bonne Femme Creek discharges to the Missouri River (Frueh 2007; NWMI 2015a).

8 The Bonne Femme Stakeholder Committee (BFSC 2007) determined that fish communities 

9 within the Bonne Femme watershed and nearby streams generally range from 11 to 17 species, 

10 and commonly include shiners, minnows, suckers, redhorse, sunfish, bass, darters and 

11 stonerollers. NWMI (2015c) observed creek chub (Semotilus atromaculatus) in small pools of 

12 Gans Creek on September 30 and October 1, 2015. Gans Creek was not flowing at the time of 

13 the observation. The NRC staff also searched FishNet (2014), which is a collaborative effort by 

14 the National Science Foundation, National Biological Information Infrastructure, and other 

15 natural history and biodiversity institutions to compile a database of fish survey results. 

16 FishNet (2014) contained records for two fish species within the vicinity of the proposed 

17 Discovery Ridge site. Small mouth bass (Micropterus dolomieu) were collected from Little 

18 Bonne Femme Creek in October 1978. Smallmouth bass are relatively common within this 

19 watershed. In March 1960, orangethroat darter (Etheostoma spectabile) were collected from 

20 the spring branch of Gans Creek. Orangethroat darter is endemic, or solely unique, to the 

21 Mississippi River basin and the Lake Erie basin. However, given the age of the data, it is not 

22 certain whether these species still occur within the Bonne Femme watershed.

23 Portions of Gans Creek are considered Fish Spawning Stream Reaches, which is one of 

24 138 State-designated fish spawning stream segments (MDC 2015). The State designates 

25 stream reaches as Fish Spawning Stream Reaches if they contain highly diverse fish 

26 communities, provide habitat for fish species of conservation concern, and if they are important

27 to maintaining, restoring, or avoiding future listing of Species of Conservation Concern 

28 (MDC 2015).

29 Streams and other waterbodies within the Bonne Femme watershed also contain many 

30 invertebrates, such as mayflies, stoneflies, caddisflies, dragonflies, beetles, small crustaceans, 

31 and snails. BFSC (2007) determined that 18 to 27 invertebrate species are estimated to inhabit 

32 streams within the Bonne Femme Watershed.

33 3.5.3 Site 

34 The proposed site consists of 7.4 ac (3.0 ha) of agricultural lands. The proposed site has been 

35 continuously disturbed from agricultural activities, such as row crops and pasture, during the 

36 past several decades. Because of these agricultural activities, plant communities located on the 

37 proposed site are primarily limited to non-native or common grasses reminiscent of open 

38 pasture land (NWMI 2015c; USDA 2016c; NRC 2016j). Because of the clearing, tilling, and 

39 other disturbances associated with agricultural activities, the proposed Discovery Ridge site has 

40 no native forests, woodlands, savannas, wetlands, or intact prairies. In addition, no water 

41 bodies, aquatic habitats, or riparian zones exist within the boundaries of the proposed Discovery 

42 Ridge site (NWMI 2015a, 2015c).

43 To characterize the vegetation on the proposed Discovery Ridge site, NWMI (2015c) performed 

44 a site survey on September 30, and October 1, 2015. NWMI randomly selected two 50-m 

(164-ft) long transects and established 1 m2 (11 ft2 45 ) plots at 5-m (16-ft) intervals along each 

46 transect. In addition, NWMI identified plants observed while walking the perimeter of the 

47 property. Both the NRC staff and the Missouri Department of Conservation staff reviewed the 
Affected Environment

3-41

1 vegetation survey (NRC 2016j). The most common species to occur on the Discovery Ridge 

2 site include tall fescue (Colium arundinaceum) and yellow foxtail (Setaria pumila), both of which 

3 are non-native to Boone County (USDA 2016c; MDC 2016d; NRC2016j). Other vegetative 

4 species on the site include Indian grass (Sorghastrum nutans), ironweed (Vernonia spp.), 

5 cocklebur (Xanthium spp.), birdsfoot trefoil (Lotus corniculatus), red clover (Trifolium pretense),

6 teasel (Dipsacus spp.), and Queen Anne’s lace (Daucus carota) (NWMI 2015c, NRC 2016j). 

7 These species are either common, weedy, and/or non-native to Boone County (MDC 2016c, 

8 2016d; USDA 2016c; NRC 2016j). The vegetative species that occur on the Discovery Ridge

9 site are indicative of an old field that has been previously disturbed (NWMI 2015c; NRC 2016j).

10 In addition, the present vegetation provides low quality habitat for wildlife and birds 

11 (NWMI 2015c; NRC 2016j).

12 NWMI (2015c) identified one American sycamore (Platanus occidentalis) tree on the Discovery 

13 Ridge site. During its site audit (NRC 2015b), the NRC staff also identified the American 

14 sycamore tree and noted that it was in relatively poor health based on multiple physical 

15 abrasions, or removal of bark, and dead branches that did not produce leaves. 

16 The proposed Discovery Ridge site provides low-quality habitat for birds, mammals, 

17 amphibians, reptiles, and other wildlife tolerant of open fields, grasses, and regular disturbance 

18 associated with cow grazing or other agricultural activities. During its qualitative field survey, 

19 NWMI (2015c) noted the presence of nine Eurasian collared-doves (Streptopelia decaocto). 

20 This species is not native to Missouri and tolerant of human-modified habitats, such as old 

21 fields, pastures, and urbanized areas (Audubon 2016). NWMI (2015c) did not observe any 

22 other wildlife during its qualitative or quantitative vegetation assessment.

23 Birds and wildlife may use the proposed site to feed on vegetation, as a temporary resting 

24 location, or while traveling among other habitats. Table 3–8 provides a representative list of 

25 species tolerant of human-altered landscapes, such as agricultural fields, which may occur on 

26 the proposed Discovery Ridge site. Wildlife that requires trees, native plants, shrubs, or 

27 uncultivated grasses would not use the proposed site because of the lack of forested areas, 

28 wetlands, and native grasslands. Note that Federally-listed species, State-listed species, and 

29 birds protected under the Migratory Bird Treaty Act of 1918, as amended (MBTA) 

30 (16 U.S.C. 703–712) are described in Section 3.5.4.

31 Table 3–8. Typical Wildlife That May Occur on or near the Proposed Site

Scientific Name Common Name

Birds

Branta canadensis Canadian goose

Cardinalis cardinalis northern cardinal

Carduelis tristis American goldfinch

Carpodacus mexicanus house finch

Charadrius vociferus killdeer

Corvus brachyrhynchos American crow

Eremophila alpestris horned lark

Passer domesticus house sparrow

Quiscalus quiscula common grackle

Spizella pusilla field sparrow

Streptopelia decaocto Eurasian collared-doves
Affected Environment

3-42

Scientific Name Common Name

Sturnella magna eastern meadowlark

Sturnus vulgaris European starling

Turdus migratorius American robin

Mammals

Marmota monax groundhog

Mephitis mephitis striped skunk

Odocoileus virginianus white tailed deer

Procyon lotor raccoon

Sciurus carolinensis grey squirrel

Sylvilagus floridanus eastern cottontail

Tamias striatus eastern chipmunk

Vulpes vulpes red fox

Reptiles and Amphibians

Anaxyrus americanus (formerly 

Bufo americanus)

Eastern American toad

Chelydra serpentina common snapping turtle

Lithobates catesbeianus (formerly 

Rana catesbiana)

American bullfrog

Lithobates clamitans (formerly 

Rana clanitans)

green frog

Lithobates pipiens (formerly Rana 

pipiens)

northern leopard frog

Ophisaurus attenuatus attenuatus western slender glass lizard

Terrapene ornata ornata ornate box turtle

Thamnophis sirtalis eastern garter snake

Sources: NWMI 2015a, 2015c; MDC 2016c

1 No natural surface water features (e.g., headwater tributaries to streams) originate on the 

2 proposed Discovery Ridge site. As described in Section 3.5.2, the closest surface water feature 

3 is Gans Creek, located approximately 0.35 mi (0.56 km) south of the site (see Figures 3–11

4 and 3–13). 

5 3.5.4 Protected Species and Habitats

6 The U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS)

7 jointly administer the Endangered Species Act of 1973, as amended (ESA) (16 U.S.C. 1531 

8 et seq.). The FWS manages the protection of, and recovery effort for, listed terrestrial and 

9 freshwater species, and NMFS manages the protection of and recovery effort for listed marine 

10 and anadromous species. In Missouri, the MDC lists species as State-endangered under 

11 Missouri’s Code of State Regulations (Title 3 of Code of State Regulations, Division 10, 

12 “Conservation Commission”) and the State Endangered Species Law (252.240). This section 

13 discusses these species and species protected under the MBTA.
Affected Environment

3-43

1 3.5.4.1 Endangered Species Act

2 Action Area

3 The implementing regulations for section 7(a)(2) of the ESA define “action area” as “all areas to 

4 be affected directly or indirectly by the Federal action and not merely the immediate area 

5 involved in the action.” (50 CFR 402.02). The action area effectively bounds the analysis of 

6 ESA-protected species and habitats because only species that occur within the action area may 

7 be affected by the Federal action.

8 For the purposes of the ESA analysis in this EIS, the NRC staff considers the action area to 

9 include the lands within the 7.4 ac (3.0 ha) proposed site, the adjacent offsite area that would be 

10 used as a temporary construction staging area, and the surrounding area where runoff drains 

11 and activities would be audible to wildlife. The NRC staff expects all direct and indirect effects 

12 of the proposed action to be contained within these areas.

13 The NRC staff recognizes that while the action area is stationary, Federally listed species can 

14 move in and out of the action area. For instance, a flowering plant known to occur near, but 

15 outside, of the action area could appear within the action area over time if its seeds are carried 

16 into the action area by wind, water, or animals. Thus, in its analysis, the NRC staff considers 

17 not only those species known to occur directly within the action area, but those species that may 

18 passively or actively move into the action area. The staff then considers whether the life history 

19 of each species makes the species likely to move into the action area where it could be affected 

20 by the construction, operations, and decommissioning of the NWMI facility.

21 Overview of Protected Species

22 Table 3–9 describes the Federally listed species that have the potential to exist within the action 

23 area. The NRC staff compiled this table from the FWS’s online database (FWS 2015a), 

24 correspondence and discussions with the FWS (FWS 2015a; NRC 2015e), and the NWMI ER

25 (NWMI 2015a).

26 As described in Section 3.5.3, NWMI conducted ecological surveys in the action area and did 

27 not observe any Federally protected species on the proposed site (NWMI 2015a). Based on the 

28 surveys described in Section 3.5.3, the NRC staff did not identify any Federally listed species 

29 that could exist in the action area. In addition, the NRC staff reviewed the habitat requirements 

30 for the Federally-listed species in Table 3–9. The NRC staff determined that the proposed site 

31 provides unsuitable habitat for all the Federally-listed species in Table 3–9. The NRC staff did 

32 not identify any candidate species or proposed or designated critical habitats within the action 

33 area. Given the available information, the NRC staff concludes that Federally listed, proposed, 

34 or candidate species are unlikely to occur within the action area.

35 The Gans Creek does not contain marine or anadromous fish species. Therefore, no Federally 

36 listed species or habitats under NMFS’s jurisdiction occur within the action area.

37 3.5.4.2 State-listed Species

38 Table 3–9 includes the State-listed species that have the potential to occur on or near the 

39 proposed Discovery Ridge site. The NRC staff compiled this table from the MDC’s description 

40 of State-listed species (MDC 2000a, 2000b, 2016b), MDC’s Natural Heritage Review (2015 and 

41 2016 [June 2 letter]) reports, and the NWMI ER (NWMI 2015a). As described in Section 3.5.3, 

42 NWMI conducted vegetation surveys in the action area and did not observe any State-protected 

43 species on the proposed site (NWMI 2015a). Furthermore, habitat to support State-listed 

44 species does not occur on site. Based on the surveys described in Section 3.5.3, the NRC staff 

45 did not identify any State-listed species that are likely to occur in the action area.
Affected Environment

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1 The NRC staff reviewed the habitat requirements for the State-endangered species in 

2 Table 3–9. The NRC staff determined that the proposed site provides unsuitable habitat for all 

3 the State-endangered species. The Topeka shiner (Anguilla rostrate), which is State

4 endangered, historically inhabited the watershed, but its occurrence has not been reported 

5 since 1997 (BFSC 2007). MDC’s (MDC 2016e) natural heritage report did not identify any 

6 state-listed endangered species, state-ranked species, nor any natural communities within the 

7 project area. Because no State-listed species have the potential to exist within the proposed 

8 Discovery Ridge site, this EIS does not discuss State-listed species in any further detail.

9 Table 3–9. Federally and State-Listed Species 

10 That May Occur on or near the Proposed Discovery Ridge Site

Scientific Name Common Name

Federal 

Status(a)

State 

Status(a) Habitat

Fish

Anguilla rostrate Topeka shiner E E Pools of small prairie 

streams with good water 

quality and gravel 

streambeds

Scaphirhynchus albus pallid sturgeon E E Missouri River and lower 

portions of the Mississippi 

River; Currently extirpated 

from Missouri

Mammals

Myotis grisescens gray bat E E Caves year-long

Myotis septentrionalis northern long-eared 

bat

T Caves or mines during the 

winter and trees with loose 

bark or caves in the 

summer

Myotis sodalist Indiana bat E E Caves during the winter 

and large diameter trees 

with loose bark in summer

Spilogale putorius 

interrupta

plains spotted skunk E Tallgrass prairies, forests, 

brushy areas, and 

cultivated lands with brushy 

cover

Birds

Botaurus lentiginosus American bittern E Freshwater marshes with 

dense stands of reeds and 

cattails

Calidris canutus rufa red knot T Migrate from the artic to 

South America. Stopover 

habitat in Missouri most 

often includes muddy or 

sandy areas near the 

Missouri River
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Scientific Name Common Name

Federal 

Status(a)

State 

Status(a) Habitat

Charadrius melodus piping plover T Wide, flat, open, sandy 

beaches with very little 

vegetation; Nesting occurs 

near small creeks or 

wetlands

Sterna antillarum least tern E E Sand islands along the 

lower Mississippi River; 

Historically nested on sand 

islands along the Missouri 

River

Plants

Trifolium stoloniferum running buffalo clover E E Moist, partially shaded 

woodlands and to a lesser 

extent, along stream or 

river terraces

(a,b) T = threatened, E = endangered

Sources: MDC 2016e; NWMI 2015a; Niles et al. 2008; FWS 2015a, 2015b, 2015c; MDC 2000a, 2000b, 2016b, 

2016c; NRC 2015e

1 3.5.4.3 Migratory Bird Treaty Act

2 The FWS administers the MBTA, which prohibits anyone from taking native migratory birds or 

3 their eggs, feathers, or nests. Regulations under the MBTA define a “take” differently than the 

4 ESA (16 U.S.C. 1532(19)) and define “take” as “to pursue, hunt, shoot, wound, kill, trap, 

5 capture, or collect or attempt to” carry out these activities (50 CFR 10.12). Unlike a “take” under 

6 the ESA regulations (50 CFR 17.3), a “take” under the MBTA does not include significant habitat

7 alteration or degradation that results in death or injury to listed species by significantly impairing 

8 essential behavioral patterns, such as breeding, feeding, or sheltering.

9 The MBTA protects a total of 1,007 migratory bird species (75 FR 9282). FWS (2015a) 

10 indicated that 20 migratory birds of concern may occur on or near the proposed Discovery 

11 Ridge site (Table 3–10). Near the proposed site, migratory birds rely on riparian, forested, 

12 grassland, and wetland habitats as important areas for foraging, resting, and avoiding predators 

13 and for breeding for some species. Although these habitats exist in the vicinity of the proposed 

14 site, none of them exists on the proposed site. For this reason, the proposed site likely provides 

15 low-quality habitat for migratory birds.

16 Table 3–10. Migratory Birds of Concern that May Occur near the Proposed Discovery 

17 Ridge Site

Scientific Name Common Name

Bird of 

Conservati

on Concern

Occurrence in 

Project Area

Birds

Haliaeetus leucocephalus bald eagle Yes Year-round

Vireo bellii bell's vireo Yes Breeding

Thryomanes bewickii ssp. bewickii Benwick’s wren Yes Year-round
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Scientific Name Common Name

Bird of 

Conservati

on Concern

Occurrence in 

Project Area

Coccyzus erythropthalmus black-billed cuckoo Yes Breeding

Vermivora pinus blue-winged warbler Yes Breeding

Dendroica cerulea cerulean warbler Yes Breeding

Spiza americana dickcissel Yes Wintering

Passerella liaca fox sparrow Yes Wintering

Ammodramus henslowii Henslow’s sparrow Yes Breeding

Oporornis formosus Kentucky Warbler Yes Breeding

Ixobrychus exilis least bittern Yes Breeding

Lanius ludovicianus loggerhead shrike Yes Year-round

Podilymbus podiceps pied-billed grebe Yes Breeding

Protonotaria citrea prothonotary warbler Yes Breeding

Melanerpes erythrocephalus red-headed woodpecker Yes Year-round

Euphagus carolinus rusty blackbird Yes Wintering

Cistothorus platensis sedge wren Yes Breeding

Asio flammeus short-eared owl Yes Wintering

Hylocichla mustelina wood thrush Yes Breeding

Helmitheros vermivorum worm eating warbler Yes Breeding

Source: FWS 2015a

1 3.5.4.4 Magnuson–Stevens Fishery Conservation and Management Act

2 Magnuson–Stevens Fishery Conservation and Management Act, as amended (16 U.S.C. 1801 

3 et seq., herein referred to as MSA), requires Federal agencies to consult with National Marine 

4 Fisheries Service (NMFS) on actions that may adversely affect essential fish habitat (EFH). The 

5 NMFS has not designated any EFH under the MSA within affected water bodies in the vicinity of 

6 the proposed site (NMFS 2016). Because no habitats are designated, no EFH would be 

7 affected by the proposed action. Therefore, this section does not discuss species with essential 

8 fish habitat.

9 3.6 Historic and Cultural Resources

10 The National Historic Preservation Act (NHPA) of 1966, as amended (54 U.S.C. 300101 et 

11 seq.), requires Federal agencies to consider the effects of their undertakings on historic 

12 properties. The historic preservation review process (Section 106 of the NHPA) is outlined in 

13 regulations issued by the Advisory Council on Historic Preservation (ACHP) in 36 CFR Part 800. 

14 This section describes the archaeological history of Columbia, Missouri, and Boone County and 

15 identifies historic and cultural resources that could potentially be found on or near the Discovery 

16 Ridge site. The identification of these resources is based on a review of the Phase I survey of 

17 the Discovery Ridge site, historic literature and archaeological records, and an interview with an 

18 archaeologist with the MDNR State Historic Preservation Office (SHPO). Additional cultural 

19 resource information is available at MDNR in Jefferson City, Missouri.
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1 3.6.1 Cultural Background

2 Human occupation in Missouri is generally characterized according to the following 

3 chronological sequence (MAS 2015):

4 • Paleo-Indian Period (11,500 to 9,900 years before present (B.P.)),

5 • Archaic Period (9,900 to 3,000 B.P.),

6 • Woodland Period (3,000 to 1,000 B.P.),

7 • Mississippian Period (1,000 to 400 B.P.), and

8 • Protohistoric/Historic Period (400 B.P. to present).

9 3.6.1.1 Paleo-Indian Period (11,500 to 9,900 B.P.)

10 The earliest evidence of people living in Missouri dates to the Paleo-Indian Period. Paleo-Indian 

11 sites are generally found upland or on river terraces and are characterized by specific types of 

12 projectile points (i.e., fluted Clovis points) and stone tools such as gravers, scrapers, or large 

13 blades. These artifacts often occur in association with mastodon remains, suggesting a reliance 

14 on the hunting of large mammals for subsistence, along with plants, small game, birds, and 

15 amphibians. Most fluted points have been found along major river valleys (e.g., Missouri River), 

16 although some have been recovered along streams such as the Moreau River. These finds 

17 suggest that the nomadic hunters and gatherers followed these streams in their movement 

18 through the Midwest area. Social organization during this period consisted of small, highly 

19 nomadic bands of hunter-gathers, leaving Paleo-Indian sites with little detailed archaeological 

20 information (NRC 2014; NWMI 2015a).

21 In Missouri, a distinct cultural tradition appeared in the transition from the Paleo-Indian to 

22 Archaic cultural periods: the Dalton Complex. Lasting approximately 1,000 years, from 10,000 

23 to 9,000 B.P., the overall settlement pattern during this period continued to be nomadic and 

24 influenced by climatic rather than glacial conditions. Archaeological sites from this period tend 

25 to be located in areas that crosscut major resource zones, suggesting a change in subsistence 

26 strategies from primarily hunting large mammals to hunting smaller mammals, gathering plant 

27 resources, and exploiting marine resources such as mussels. All known Dalton sites in Missouri 

28 are small camps, and represent short-term utilization. Artifact assemblages from Dalton sites 

29 are characterized by distinct narrow, oval-shaped, unfluted projectile points (NRC 2014; 

30 NWMI 2015a).

31 3.6.1.2 Archaic Period (9,900 to 3,000 B.P.) 

32 The Archaic Period was a time of major climatic shifts as the environment transitioned from a 

33 colder to warmer climate similar to modern conditions. In response to this shift, new 

34 technologies and subsistence strategies were developed. The Archaic Period is often 

35 subdivided into early, middle, and late periods. The Early Archaic Period is characterized by a 

36 shift from nomadic to more sedentary settlement patterns, with central base camps located on 

37 river terraces and smaller hunting camps located in upland areas. These sites are found in a 

38 variety of environmental settings throughout Missouri, including upland ridges near small 

39 ephemeral streams, upland bluff edges, rock shelters, and the margins of high bottomland 

40 terraces. The Early Archaic Period also shows an increased reliance on wild plant foods, small 

41 game, and aquatic resources.

42 The Middle Archaic Period is characterized by an increased number of settlement sites on high 

43 stream terraces, which may reflect population increases. While subsistence and settlement 

44 patterns remained fairly similar to the Early Archaic Period, artifact assemblages suggest 
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1 increased exploitation of aquatic resources. Also in evidence are new artifacts such as pecked 

2 and ground stone tools, used for processing nuts; banner stones that signaled the innovation of 

3 a new projectile technology called the atlatl, or spear-thrower; and grooved axes.

4 The Late Archaic Period is characterized by an increase in the number and size of settlement 

5 sites, which indicates a further increase in population and more sedentary lifestyle. New 

6 features of Late Archaic artifact assemblages, such as crude ceramic vessels, represent a shift 

7 towards increased reliance on horticulture as a subsistence strategy, although hunting and 

8 gathering would have continued (NRC 2014; NWMI 2015a).

9 3.6.1.3 Woodland Period (3,000 to 1,000 B.P.)

10 The Woodland Period is also often subdivided into early, middle, and late periods. Early 

11 Woodland Period sites are not well represented in the Missouri archaeological record; they tend 

12 to be large base camps located in major river valleys, with smaller logistical camp sites located 

13 on terraces of smaller water bodies. This period is identified by the presence of Black Sand 

14 Incised pottery. In spite of intensive surveys in various areas of the State, only a few 

15 unquestionable Early Woodland sites have been identified. While Early Woodland Period 

16 subsistence appears to have relied on hunting and gathering, there is evidence for cultivating 

17 plants such as sunflowers and cucurbits (i.e., squashes, gourds, melons, etc.) (NRC 2014; 

18 NWMI 2015a).

19 During the Middle Woodland Period, the large and complex Hopewell Culture emerged in the 

20 United States, including Missouri. This culture is characterized by village settlements, increased 

21 reliance on horticulture, burial mounds, and trade networks. These trade networks facilitated 

22 the exchange of exotic materials, such as marine shells from the Gulf Coast, obsidian from the 

23 Rocky Mountains, copper from Lake Superior, and mica from the Appalachian Mountains. 

24 Middle Woodland artifact assemblages are dominated by ceramics, suggesting an increased 

25 reliance on cultivated plants (NRC 2014; NWMI 2015a).

26 The Late Woodland Period is characterized by an increase in the number of settlement sites, 

27 which suggests a rise in population, a change in settlement patterns from large, centralized 

28 village sites to smaller, dispersed habitation sites, or both. Late Woodland Period artifact 

29 assemblages are characterized by an increase in thin-walled plain ceramic types and stemmed 

30 and side-notched projectile points. The sudden appearance of very small, thin triangular 

31 projectile points between 1,300 and 1,400 B.P. indicates the invention of bow-and-arrow 

32 technology and suggests a corresponding change in hunting techniques. Several Late 

33 Woodland sites have been identified in Boone County, including open habitation sites and burial 

34 mounds (NRC 2014; NWMI 2015a).

35 3.6.1.4 Mississippian Period (1,000 to 400 B.P.)

36 The Mississippian Period is characterized by major changes in settlement, subsistence patterns, 

37 and social structure. This period is not well-documented in the general area of the proposed 

38 Discovery Ridge site. Large, highly centralized permanent settlements supported by many 

39 satellite villages emerged during this period. The archaeological record of these settlements 

40 suggests they were organized as chiefdoms with considerable social stratification. A new type 

41 of ceremonial earthen mound, the platform mound, appeared in association with these 

42 permanent settlements. Mississippian Period subsistence relied heavily on maize agriculture, 

43 as well as hunting and gathering. Craft specialists appeared in the social structure of the 

44 Mississippian Period, producing highly specialized lithic and ceramic artifacts, beadwork, and 

45 shell pendants. In addition to these specialized artifacts, characteristic Mississippian Period 

46 artifacts include small triangular, side-notched and bi-pointed projectile points and slipped and 

47 painted pottery (NRC 2014; NWMI 2015a).
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1 Beginning about 1350, the Oneota cultural tradition appeared in the area near the junction of the 

2 Grand, Chariton, and Missouri Rivers. The Oneota occupation lasted to the end of the 

3 Mississippian period, when Oneota culture blended into what is recognized as the Historic 

4 Missouri Indian tribe (NWMI 2015a).

5 3.6.1.5 Protohistoric/Historic Period (400 B.P. to Recent History)

6 The end of the Mississippian Period is characterized by severe social, political, and 

7 demographic changes that resulted from contact with Europeans. In particular, it is believed 

8 that the introduction of infectious diseases such as smallpox, yellow fever, typhoid, and 

9 influenza severely decimated native populations, which had no immunity to these diseases. 

10 The spread of disease, which was often fatal, resulted in the abandonment of villages and the 

11 collapse of trade networks. By the time of European contact and settlement, the Mississippian 

12 chiefdoms were gone (NRC 2014).

13 The first major European expedition to Missouri was conducted by French Catholic missionaries 

14 sometime in the late 17th to early 18th centuries. Missouri (then called Upper Louisiana) was 

15 seen by the French as a place for new economic opportunity, and St. Louis was established as 

16 a center for fur trade in the area. By 1719, most of the interior of Missouri had been explored for 

17 fur trade and exploitation of mineral resources such as silver and lead (NRC 2014).

18 Beginning about 1730, the Missouri Indian tribe began to suffer losses due to smallpox and 

19 challenges from its enemies to the north, and in turn became increasingly dependent on their 

20 allies, the Osage, for protection. By the 1790s the Sac and Fox tribes had conquered and 

21 dispersed the Missouri Indian tribe, with those who were not killed joining the Osage, Kansas, 

22 and Oto tribes (NWMI 2015a).

23 The proposed Discovery Ridge site lies in territory claimed at different times by France and 

24 Spain until it was sold to the United States in 1803 as part of the Louisiana Purchase. The first 

25 permanent European settlers to the area soon followed. The U.S. Congress subsequently 

26 established the Territory of Missouri in 1812, and recognized Missouri as a state in 1821 

27 (NWMI 2015a).

28 Most of the settlers who came to mid-Missouri were attracted to the land and cultivated crops 

29 that reproduced the agricultural patterns of their native states, including the slave-holding States 

30 of Kentucky, Tennessee, and Virginia. Major crops included hemp and tobacco, which 

31 demanded intensive labor for productivity (NWMI 2015a).

32 3.6.1.6 Recent History – Columbia

33 Columbia was incorporated in 1826, 5 years after Missouri achieved statehood. The city 

34 benefited from its proximity to stops on the Santa Fe and Oregon Trails, and later the Missouri 

35 Kansas Texas Railroad. The economy of Columbia has historically centered on education. A 

36 school for girls was opened in 1833, and an institution called Columbia College was opened in 

37 1834 (NWMI 2015a).

38 Missouri University was established in Columbia in 1841. This was followed by the Christian 

39 Female College in 1851, which later changed its name to Columbia College (although not 

40 related to the earlier institution). Baptist Female College, now known as Stephens College, was 

41 established in 1855 (NWMI 2015a). 

42 The coming of the railroad in the 1850s opened the interior to greater trade and established the 

43 area as a major source of agricultural products (NWMI 2015a). By the onset of the Civil War, 

44 slave holding began to drop and agricultural pursuits became almost entirely geared toward 

45 corn and wheat production. Columbia’s economy also has strong ties to the health care 
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1 industry, with it being among the top cities in the Nation for medical facilities per capita 

2 (NRC 2014; NWMI 2015a).

3 3.6.1.7 Recent History – Discovery Ridge

4 From 1934 to 2006, the Discovery Ridge Research Park was predominantly in crop production, 

5 livestock pasture, or vacant farmland. Since 2006, the western and northern portion has been 

6 in development as a research park that includes the Missouri University plant genetic research 

7 farm, while the eastern portion has remained in agricultural use. Several residential structures 

8 were removed from the site since the 1980s, including a small log cabin-type structure that was 

9 located on the central portion of the research park. Two small machine-shed structures dating 

10 from the 1950s and a Quonset hut used for storage by the USDA remain on site (NWMI 2015a; 

11 Terracon 2011a).

12 3.6.2 Historic and Cultural Resources

13 Databases that the National Park Service (NPS) maintains show 50 properties listed in the 

14 National Register of Historic Places in Boone County, with the vast majority of them located in 

15 and around Columbia under the National Historic Preservation Act (54 U.S.C. 300101 et seq.). 

16 However, no historic properties are located at the Discovery Ridge site. The nearest property in 

17 the National Register of Historic Places list is the Maplewood House, which is located about 

18 1 mi (1.6 km) northwest of the proposed NWMI facility site at Discovery Ridge (NWMI 2015a). 

19 The view from the Maplewood House of the proposed Discovery Ridge site is obstructed by 

20 trees and residential and commercial properties.

21 NWMI conducted a Phase I survey investigation in October 2013 to inventory and evaluate 

22 cultural resources within the Discovery Ridge site. The Phase I investigation included (1) a 

23 pre-field evaluation of pertinent literature and records from which the field survey techniques 

24 and site designation criteria were developed, (2) an intensive pedestrian survey of the project 

25 area, (3) an attempt to recover sufficient data for site designation and evaluation in terms of 

26 NRHP eligibility requirements, (4) notation of locational information regarding site provenience 

27 and physiographic setting, (5) post-field activities involving data analysis, and (6) report 

28 preparation (NWMI 2015a).

29 A review of relevant publications and archaeological records provides an understanding of the 

30 types of historic and cultural resources that could be found at the Discovery Ridge site. Based 

31 on the review of historical information, no archaeological sites or historic structures have been 

32 recorded nor have any significant historic events occurred within Lot 15. A review of 19th and 

33 20th century plat maps and 20th century USGS topographic quadrangles also revealed no 

34 evidence of historic structures on Lot 15.

35 A Phase I archeological survey was conducted at the proposed Discovery Ridge site, which 

36 included shovel tests to interpret the presence of historic and cultural resources. No evidence 

37 of historic or cultural resources were found within the Lot 15 survey area. As a result, Lot 15 at 

38 the Discovery Ridge site contains no significant cultural resources (NWMI 2015a).

39 A Cultural Resource Assessment, Section 106 Review, was conducted by the MDNR SHPO for 

40 the proposed Northwest Medical Isotopes, LLC Radioisotope Production Facility, Columbia 

41 (Lot 15 at Discovery Ridge). The assessment, signed by Toni M. Prawl, Ph.D., Deputy State 

42 Historic Preservation Officer, states that, “Adequate documentation has been provided 

43 (26 CFR Section 800.11). There will be ‘no historic properties affected’ by the current project.” 

44 The assessment also states, the MDNR SHPO has “no objection to the initiation of project 

45 activities.” (MDNR 2015b).
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1 3.7 Socioeconomics

2 This section describes current socioeconomic factors that have the potential to be directly or 

3 indirectly affected from construction, operations, and decommissioning of the proposed NWMI 

4 facility. The NWMI facility and the communities that would support it can be described as a 

5 dynamic socioeconomic system. The communities provide the people, goods, and services 

6 required to construct, operate, and decommission the proposed NWMI facility. NWMI facility 

7 operations, in turn, provide wages and benefits for people and dollar expenditures for goods and 

8 services. The measure of a community’s ability to support the construction, operations, and 

9 decommissioning of the proposed NWMI facility depends on its ability to respond to changing 

10 environmental, social, economic, and demographic conditions.

11 The socioeconomic region of influence (ROI) is defined by the area in which NWMI construction, 

12 operations, and decommissioning employees and their families would likely reside, spend their 

13 income, and use their benefits—all of which affect economic conditions of the region. For the 

14 purposes of analysis and because of the relatively small size of the NWMI operations work force 

15 (approximately 100 workers), this area includes all of Boone County and the City of Columbia, 

16 Missouri.

17 3.7.1 Population Growth Rates and Projections

18 The population for Boone County has grown steadily from 1980 through 2010, with the largest 

19 increase between 1990 and 2010 (see Table 3–11). Based on population projections from the 

20 Missouri Department of Administration, Division of Budget and Planning, the population within 

21 Boone County is projected to continue to increase.

22 Table 3–11. Boone County Population (1980–2050)

Year Population Percent Change

1980 100,376 –

1990 112,379 12.0

2000 135,454 20.5

2010 162,642 20.1

2014 172,717 5.8

2020 183,101 12.2

2030 204,264 11.6

2040 225,427 10.4

2050 246,590 9.4

Sources: Decennial population data for 1970-2010, and estimated 

2014 (USCB 2016b); projections for 2020-2030 by State of Missouri, 

Office of Administration, Division of Budget and Planning (Missouri 

Office of Administration 2016); 2040-2050 calculated.

23 3.7.2 Race and Ethnicity

24 Table 3–12 presents the demographic profiles for the City of Columbia and Boone County. In 

25 2010, minorities comprised 23 percent of the total population in the City of Columbia. As shown 

26 in Table 3–12, the largest minority populations were Black or African American at 11.1 percent 
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1 followed by Asians at 5.2 percent. In Boone County, minorities comprised 19 percent of the 

2 total population in 2010. The largest minority populations were Black or African American at 

3 9.2 percent followed by Asians at 3.8 percent.

4 Table 3–12. Race and Ethnicity for Columbia and Boone County, Missouri, in 2010

Columbia Boone County

Total Population 108,500 162,642

Race (percent of total population, Not-Hispanic, Latino, or Spanish ethnicity)

White 77.0 81.0

Black or African American 11.1 9.2

American Indian and Alaska Native 0.3 0.3

Asian 5.2 3.8

Native Hawaiian and Other Pacific Islander 0.1 0.1

Some other race 0.2 0.2

Two or more races 2.7 2.5

Ethnicity

Hispanic or Latino (population) 3,729 4,895

Percent of total population 3.4 3.0

Minority population (including people of Hispanic, Latino, or Spanish ethnicity)

Total minority population 24,958 30,965

Percent minority 23.0 19.0

Source: USCB 2016c

5 According to the U.S. Census Bureau’s 2014 American Community Survey 1-Year Estimates, 

6 since 2010 minority populations in the City of Columbia and Boone County were estimated to 

7 have increased by approximately 3,000 to 4,000 persons and now comprise 24 and 

8 20.2 percent of the respective populations (see Table 3–13). In the City of Columbia, the 

9 largest increase occurred in the Asian and Black or African American populations, an increase 

10 of 10.3 and 6.3 percent, respectively. In Boone County, the largest increase occurred in the 

11 Hispanic, Latino, or Spanish origin of any race and Asian populations, an increase of 14.2 and 

12 10.6 percent, respectively.

13 Table 3–13. Race and Ethnicity for Columbia and Boone County, Missouri, in 2014

Columbia Boone County

Total Population 116,892 172,717

Race (percent of total population, Not-Hispanic, Latino, or Spanish ethnicity)

White 76.0 79.8

Black or African American 11.1 8.8

American Indian and Alaska Native 0.0 0.0

Asian 5.3 3.9

Native Hawaiian and Other Pacific Islander 0.0 0.0

Some other race 0.1 0.2
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Columbia Boone County

Two or more races 4.4 4.1

Ethnicity

Hispanic or Latino (population) 3,620 5,588

Percent of total population 3.1 3.2

Minority population (including people of Hispanic, Latino, or Spanish ethnicity)

Total minority population 28,082 34,941

Percent minority 24.0 20.2

Source: USCB 2016c

1 3.7.3 Transient Population

2 Colleges and recreational opportunities attract daily and seasonal visitors who create a demand 

3 for temporary housing and services. In 2015, approximately 55,800 students attended colleges 

4 and universities within 20 mi (32 km) of the proposed NWMI facility at Discovery Ridge 

5 (NCES 2015a). Based on 2014 American Community Survey 1-Year Estimates, approximately 

6 2,227 seasonal housing units are located in Boone County (USCB 2016d).

7 Migrant farm workers are individuals whose employment requires travel to harvest agricultural 

8 crops. Some migrant workers follow the harvesting of crops, particularly fruit, throughout rural 

9 areas of the United States. Migrant workers may be members of minority or low-income 

10 populations. Because migrant workers travel and can spend a significant amount of time in an 

11 area without being actual residents, they may be unavailable for counting by Census takers. If 

12 uncounted, these minority and low-income workers would be “underrepresented” in the 

13 decennial Census population counts.

14 Information about both migrant and temporary farm labor (working less than 150 days) can be 

15 found in the 2012 Census of Agriculture. According to the 2012 Census of Agriculture, 

16 approximately 470 temporary farm workers were hired to work on 196 farms in Boone County, 

17 Missouri. Only one farm in Boone County reported hiring migrant workers in the 2012 Census 

18 of Agriculture (NASS 2014).

19 3.7.4 Labor Force, Employment, and Unemployment

20 This section provides labor force, employment, and unemployment data for the City of 

21 Columbia, Boone County, and the State of Missouri. It also presents economic data on 

22 employment by industry, income, poverty levels, occupations, wages, poverty rates, and 

23 housing.

24 Table 3–14 shows that Boone County had an estimated available civilian labor force in 2014 of 

25 97,498, with a 2.9 percent unemployment rate. The City of Columbia had an available labor 

26 force of 67,702, with a 2.4 percent unemployment rate.
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1 Table 3–14. Labor Force, Employment, and Unemployment Rates in Missouri, Boone 

2 County, and the City of Columbia (2014)

Missouri Boone County Columbia

Civilian Labor Force 3,009,857 97,498 67,702

Employed 2,805,646 93,405 65,355

Unemployed 204,211 4,093 2,347

Unemployment rate 4.2 2.9 2.4

Source: USCB 2016d

3 Table 3–15 shows employment by industry for Boone County for 2014. According to 2014 

4 American Community Survey estimates, the educational, health, and social services industry 

5 represented the largest employment sector in Boone County (36.3 percent) followed by retail 

6 trade (14.5 percent) and arts, entertainment, recreation, accommodation, and food services 

7 (12.3 percent).

8 Table 3–15. Employment by Industry in Boone County for 2014

Industry Employment Percent

Total employed civilian workers 93,405 –

Agriculture, forestry, fishing, hunting, and mining 800 0.9

Construction 3,151 3.4

Manufacturing 4,153 4.4

Wholesale Trade 1,727 1.8

Retail Trade 13,583 14.5

Transportation, warehousing, and utilities 3,032 3.2

Information 2,209 2.4

Finance, insurance, real estate, rental, and leasing 7,543 8.1

Professional, scientific, management, administrative, 

and waste management services

5,308 5.7

Educational, health, and social services 33,943 36.3

Arts, entertainment, recreation, accommodation, and 

food services

11,501 12.3

Other services (except public administration) 3,402 3.6

Public administration 3,053 3.3

Source: USCB 2016d

9 3.7.5 Income and Wages and Poverty

10 Table 3–16 presents the median family and per capita income figures for Missouri, Boone 

11 County, and the City of Columbia. According to 2014 American Community Survey 1-Year 

12 Estimates, Boone County has a higher median household income average than both the State 

13 of Missouri and the City of Columbia. The City of Columbia had a lower per capita income 

14 average than Boone County and the State of Missouri.
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1 Table 3–16. Median Family Income and Per Capita Income for the City of Columbia, 

2 Boone County, and State of Missouri in 2014

Missouri Boone County Columbia 

Median household income (dollars)(a) 48,363 50,085 46,624

Per capita income (dollars)(a) 26,126 25,928 24,656

Families living below the poverty level (percent) 10.7 11.3 13.2

Individuals living below the poverty level (percent) 15.5 20.7 24.9

(a) In 2014 inflation adjusted dollars.

Source: USCB 2016d

3 Table 3–16 also presents the percentages of families and individuals living below the Federal 

4 poverty threshold in Missouri, Boone County, and the City of Columbia. The poverty levels in 

5 2014 were $12,071 for an individual and $24,230 for a family of four (USCB 2016d). According 

6 to 2014 American Community Survey 1-Year Estimates, the City of Columbia had a higher 

7 percentage of families and people living below the poverty level than Boone County as a whole.

8 3.7.6 Housing

9 Table 3–17 lists the total number of occupied and vacant housing units, vacancy rates, and 

10 median value in Boone County and the City of Columbia. Based on 2014 American Community 

11 Survey estimates, there were approximately 73,000 housing units in Boone County, of which 

12 nearly 67,000 were occupied. The median values of owner-occupied housing units in Boone 

13 County was $170,700. The vacancy rate for all housing was 8.2 percent and 2.3 percent for 

14 rental units alone (USCB 2016e).

15 Table 3–17. Housing Unit Characteristics for Boone County and City of Columbia in 2014 

Boone County Columbia

Total housing units 73,173 49,842

Occupied housing units 67,198 45,405

Total vacant housing units 5,975 4,437

 Percent total vacant 8.2 8.9

Owner occupied units 37,296 21,561

Median value (dollars) 170,700 185,600

 Owner vacancy rate (percent) 0.0 0.0

Renter occupied units 29,902 23,844

Median rent (dollars/month) 802 814

 Rental vacancy rate (percent) 2.3 1.7

Source: USCB 2016e
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1 3.7.7 Local Employers

2 Table 3–18 lists the 10 largest employers in the City of Columbia and Boone County. These 

3 employers provide a variety of products and services, including educational and medical 

4 services, local government, financial and insurance services, and wholesale distribution.

5 Table 3–18. Ten Largest Employers in the City of Columbia and Boone County (2014)

Employer Number of Employees Product/Service

University of Missouri 8,750 Educational services

University Hospitals and Clinics 5,575 Medical services

Columbia Public Schools 2,417 Educational services

Boone Hospital Center 1,750 Medical services

City of Columbia 1,416 City government

Truman Memorial Veteran’s Hospital 1,276 Medical services

Veterans United Home Loans 1,400 Financial services

Shelter Insurance Companies 1,109 Insurance services

MBS Textbook Exchange 863 College textbook wholesaler

State Farm Insurance 850 Insurance services

Source: Columbia Daily Tribune 2015a

6 3.7.8 Taxes

7 The Missouri personal income tax rates range from 1.5 to 6 percent, assessed over 10 income 

8 brackets. The rates start at 1.5 percent on the first $1,000 of taxable income. The rate 

9 increases 0.5 percent on each additional $1,000 up to $9,000. The tax rate for income above 

10 $9,000 is 6 percent (MDOR 2016).

11 Missouri has a State sales tax of 4.225 percent that is levied on the purchase price of tangible 

12 personal property or taxable services sold at retail. The City of Columbia and Boone County 

13 have additional sales tax rates of 3.75 and 1.75 percent, respectively. These rates are in 

14 addition to the State tax rate of 4.225 percent.

15 The Missouri corporate tax rate is 6.25 percent. Only income earned in Missouri is taxed 

16 (MDOR 2016). Missouri permits companies to choose the formula that results in the lesser 

17 corporate income tax liability. Missouri also allows a portion of Federal income tax payments to 

18 be deducted before computing taxable income.

19 Missouri local governments rely on real (real estate) and personal property tax revenue to fund 

20 school districts, public transport, infrastructure, and other municipal government projects. 

21 Property tax rates are set each year by local taxing jurisdictions within the limits set by the 

22 Missouri Constitution and laws. Rates are based on the revenues that had been permitted for 

23 the prior year with an allowance for growth based on the rate of inflation (Boone County 

24 Collector of Revenue 2016).

25 Taxes are levied against property based on the rates as permitted by voters, collected by the 

26 collector and then distributed back to the taxing entities. In other words, Boone County collects 

27 property taxes on behalf of the taxing entities within the County (Boone County Collector of 

28 Revenue 2016).
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1 The amount of property taxes imposed on any taxpayer is determined by two separate factors:

2 The assessed value of the property, as established by the local assessor.

3 The tax rates set by local taxing jurisdictions plus the $0.03 State tax rate. In 2015, 

4 Boone County levied a property tax rate of $0.2846, the City of Columbia a tax rate 

5 of $0.4100, and Columbia Public Schools a tax rate of $5.4656. (Boone County 

6 Collector of Revenue 2016). 

7 3.7.9 Education

8 There are six public school districts located within Boone County. The Columbia Public School 

9 District services the population within the 5-mi (8-km) radius of the proposed NWMI facility at 

10 Discovery Ridge. Total enrollment in the Columbia School District was 17,872 during the 

11 2013-2014 school year (NCES 2015b).

12 3.7.10 Public Recreation for Boone County

13 The parks and open spaces within Boone County are listed in Table 3–19, along with their 

14 approximate distance from the proposed NWMI facility at the Discovery Ridge site.

15 Table 3–19. Parks within a 5-mi (8-km) Radius of the Proposed NWMI Facility Site

Park/Open space

Approximate 

distance from 

proposed site 

(mi/km)

General 

direction Park/Open space

Approximate

distance from 

proposed site 

(mi/km)

General 

direction

A. Perry Philips Park 0.7/1.1 West Eastport Park 3.6/5.8 Northeast

Nifong Park 1.1/1.8 Northwest Stephens Lake Park 3.6/5.8 North

Gans Creek 

Recreation Area

1.3/2.1 Southwest Cliff Drive Park 3.7/5.9 Northwest

Rock Bridge 

Memorial State Park

2/3.2 Southwest Rock Bridge Park 3.7/5.9 Northwest

Rock Quarry Park 2/3.2 Northwest Woodridge Park 3.8/6.1 North

Waters-Moss 

Memorial Wildlife 

Area

2.2/3.5 Northwest Columbia Country 

Club

4/6.4 North

Old Hawthorne Gold 

Club

2.6/4.5 Northwest A.L. Gustin Golf 

Course

4.1/6.6 Northwest

Grindstone Nature 

Area

2.8/4.5 Northwest Paquin Park 4.2/6.8 Northwest

Shepard Park 2.8/4.5 North Willis Quad 4.2/6.8 Northwest

American Legion 

Park

2.9/4.6 North Peace Park 4.3/6.9 Northwest

Old 63 Roadside 

Park

3.0/4.8 Northwest Grasslands Park 4.5/7.2 Northwest

Capen Park 3.1/4.9 Northwest Oakwood Hills Park 4.5/7.2 Northwest

Highpointe Park 3.2/5.1 Northwest Flat Branch Park 4.6/7.4 Northwest
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Park/Open space

Approximate 

distance from 

proposed site 

(mi/km)

General 

direction Park/Open space

Approximate

distance from 

proposed site 

(mi/km)

General 

direction

Three Creeks 

Conservation Area

3.2/5.1 South McKee Street Park 4.8/7.7 North

Cosmo-Bethel Park 3.6/5.8 West Forum nature Area 5/8 Northwest

Source: NWMI 2015a

1 In addition to the parks, several other public facilities are located within a 5-mi (8-km) radius of 

2 the proposed NWMI facility at Discovery Ridge, including:

3 Aquatic centers – The Columbia Parks and Recreation Department manages four outdoor and 

4 two indoor pools. Only two of these facilities, Douglass Family Aquatic Center and Stephens 

5 Lake Swimming Beach and Spraygrounds are located within a 5-mi (8-km) radius of the 

6 proposed NWMI facility at Discovery Ridge. The Douglass Family Aquatic Center is an outdoor 

7 facility that consists of a recreational pool, a slide, and a spray park. The Stephens Lake 

8 Swimming Beach and Spraygrounds consists of a lake and spraygrounds.

9 Columbia Area Seniors Center – The Columbia Area Seniors Center offers services and 

10 activities for seniors, including meals, computers, and meeting places for activities.

11 Armory Sports & Recreation Center – This indoor facility is used for basketball, volleyball, 

12 meetings, aerobics, and other programs. The facility includes a gymnasium, classroom, 

13 meeting room, aerobics room, a cardio/strength training area, computer room, general 

14 recreation room, and locker rooms (NWMI 2015a).

15 3.7.11 Public Services

16 Medical

17 The City of Columbia and Boone County have many medical care facilities, including four 

18 hospitals and one veteran’s hospital. Boone Hospital Center has 321 beds, Landmark Hospital 

19 of Columbia has 42 beds, the University of Missouri Hospital has 528 beds, and Woman’s and 

20 Children’s Hospital has 98 beds (American Hospital Directory 2016).

21 Emergency Services

22 The Columbia/Boone County Office of Emergency Management is located in the City of

23 Columbia. The Public Joint Communications Center coordinates County and City-wide 

24 responses and supports other local governments during major disasters and emergencies. It 

25 also prepares other governmental entities, private business, volunteer organizations, and 

26 citizens to respond and recover from major emergencies and disasters. The Public Joint 

27 Communications Center has a 24-hr dispatching service for City and County police and law 

28 enforcement, fire and rescue, and emergency medical services (Boone County).

29 Public Water

30 Table 3–20 lists the public water suppliers in Boone County and provides water source and 

31 population served for those suppliers. The Columbia Water Treatment Plant is owned by the 

32 City of Columbia and operated by the Water and Light Department. The service territory of the 

33 Columbia Water Treatment Plant includes the City of Columbia, where the majority of customers 
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1 reside. Public Water Supply District 9 currently provides service to the northeast portion of the 

2 proposed NWMI facility site.

3 Table 3–20. Public Water Supply Systems in Boone County

Public Water System Source

Population

Served(a)

Ashland Groundwater 3,707

Boone County Consolidated Public Water Supply District 1 Groundwater 21,500

Boone County Public Water Supply District 10 Groundwater 4,625

Boone County Public Water Supply District 4 Groundwater 6,455

Boone County Public Water Supply District 9 Groundwater 12,200

Centralia Groundwater 4,027

Columbia Groundwater 100,733

University of Missouri Columbia Groundwater 40,319

(a) Safe Drinking Water Search for the State of Missouri.

Source: EPA 2016g

4 3.8 Human Health

5 The proposed NWMI facility is a potential source of radiation and chemical exposure to onsite 

6 workers and offsite members of the public. Human health can be adversely affected by 

7 radioactive and chemical materials in the environment. The following sections discuss potential 

8 receptors in the vicinity of the Discovery Ridge site to radioactive and chemical materials, 

9 existing conditions at the Discovery Ridge site and surrounding area, and laws and regulations

10 to protect workers and the public against potential health risks from exposure to radioactive 

11 materials and hazardous chemicals used, generated, and released from the licensed facility.

12 3.8.1 Sensitive Receptors

13 The NRC evaluates the potential human health impacts in a region of interest (ROI) primarily 

14 within a 5-mi (8-km) radius from the proposed NWMI facility. Figure 3–14 identifies sensitive 

15 receptors (schools, medical facilities, parks, recreational areas, religious institutions, and 

16 retirement communities) that are within a 5-mi (8-km) radius of the proposed Discovery Ridge 

17 site. Table 3–21 identifies the distances to the nearest sensitive receptors from the proposed 

18 Discovery Ridge site. As discussed in Section 3.4.2, the nearest domestic supply well is located 

19 approximately 0.7 mi (1.1 km) northeast of the site and a public water supply well is located 

20 approximately 0.8 mi (1.3 km) south, southeast of the Discovery Ridge site.

21 Table 3–21. Sensitive Receptors from the Discovery Ridge Site

Distance (mi) General Direction

Resident 0.27 South

Elementary School 1.0 Northwest

Child Care/Preschool 1.7 North

Hospital 3.3 West
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Distance (mi) General Direction

Retirement/Assisted Living 

Facility

0.91 Northwest

Source: NWMI 2015a

1 Figure 3–14. Location of Sensitive Receptors Near the Proposed Discovery Ridge Site

2

3 Source: Modified from NWMI 2015a
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1 3.8.2 Radiation and Nuclear Hazards

2 3.8.2.1 Pathways for Human Exposure to Radiation and Radioactivity

3 Radioactive material released into the environment can expose individuals through the following 

4 pathways:

5 • Inhalation exposure pathway: inhaling contaminated airborne emissions;

6 • Direct radiation: material that is deposited on the ground from passing airborne 

7 emissions becomes an external exposure source of direct radiation; exposure to 

8 radioactive waste or other radioactive material.

9 • Ingestion exposure pathway: Radioactive materials can be transported through a 

10 variety of routes into the human diet. Drinking milk or eating meat from animals that 

11 grazed on open pasture on which radioactive material was deposited; eating 

12 vegetables grown that are contaminated with radioactive material; and direct 

13 consumption of contaminated surface water or groundwater.

14 3.8.2.2 Major Sources and Levels of Radiation

15 Naturally Occurring Background Sources

16 Naturally occurring background radiation is always present and originates from cosmic, 

17 terrestrial, and internal (within the human body) sources. Cosmic radiation comes from the sun 

18 and stars, and the dose received varies with weather and elevation. In the City of Columbia, 

19 where the proposed site is located, the average annual dose from cosmic radiation is 

20 approximately 28 millirem (mrem) (NWMI 2015a).

21 Terrestrial radiation comes from naturally occurring radionuclides in soil, water, and air. Areas 

22 with high natural soil concentrations of radioactive uranium or thorium are typically associated 

23 with higher terrestrial radiation doses, due to the dose from other radionuclides, particularly 

24 radon, which are produced by the decay of uranium and thorium. Based on Missouri’s average 

25 uranium and thorium concentrations, the average annual terrestrial radiation dose at the 

26 proposed site is approximately 228 mrem (NWMI 2015a).

27 Internal radiation comes from the radioisotopes potassium-40 and carbon-14, which occur 

28 naturally in the human body. A person’s average annual internal radiation dose is 

29 approximately 30-40 mrem (NWMI 2015a; EPA 2016i).

30 Current Human-Made Sources of Radiation:

31 As discussed in Section 3.8.1, there are numerous medical facilities in the ROI. These facilities

32 may use ionizing radiation for medical imaging or treatment (NWMI 2015a). The average 

33 person receives a dose of about 310 mrem per year from human-made radiation sources; about 

34 96 percent of this dose comes from medical procedures (NRC 2016e).

35 The University of Missouri research reactor (MURR) is located approximately 4 mi (6.4 km) from 

36 the proposed Discovery Ridge site. The radiological environmental monitoring program at 

37 MURR, and the environmental effects of operation of the MURR, are discussed in detail in 

38 Section 3.10.1. The regulations at 10 CFR 50.47 require that, in general, nuclear power 

39 reactors shall have an emergency planning zone (EPZ) that consists of an area about 50 mi

40 (80 km) in radius. The Callaway Energy Center, a nuclear power plant, is located about 28 mi 

41 (45 km) southeast of the proposed NWMI facility site; therefore, the proposed site is within the 

42 EPZ for the Callaway Energy Center.

43 The Callaway Energy Center has a radiological environmental monitoring program that includes 

44 collection of water, terrestrial, air, and biological samples. Surface water, groundwater, drinking 
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1 water, and sediment samples are collected on either a monthly, quarterly, or semi-annual basis, 

2 and are analyzed for gamma-emitting isotopes. The water samples are also analyzed for 

3 tritium. Soil samples are collected on an annual basis and analyzed for gamma-emitting 

4 isotopes. Continuous air monitoring is performed to monitor for iodine-131 and other gamma 

5 isotopes in air; the filters from the continuous air monitor systems are analyzed weekly. 

6 Biological sampling includes collection and gamma isotope analysis of milk, fish, and vegetation 

7 on either a monthly or semi-annual basis. Although radionuclides were detected in water, 

8 terrestrial, air, and biological samples in 2012, 2013, and 2014, the types and quantities of 

9 radionuclides were consistent with naturally occurring levels and/or historical data at the

10 Callaway site. The Callaway Energy Center’s radiological environmental monitoring program 

11 also measures direct ambient gamma radiation at 40 locations using thermoluminescent 

12 dosimeters (TLDs). During 2012, 2013, and 2014, the dose levels measured by these TLDs 

13 were similar to historical results (AMEREN 2013, 2014, 2015).

14 Analytical Bio-Chemistry Laboratories Inc. (ABC) currently engages in the industrial and 

15 commercial use of radiation. The ABC Laboratories facilities, located approximately 500 ft 

16 (152 m) and 5 mi (8 km) from the proposed site, use radiation and radioactive materials for 

17 various research and analysis purposes. Although occupational dose monitoring is conducted 

18 for ABC Laboratories personnel, no radiological environmental monitoring program is currently 

19 required for the ABC Laboratories facilities (NWMI 2015a; NRC 2015h). 

20 Historical radionuclide releases to the environment have occurred at the ABC Laboratories site 

21 approximately 5 mi (8 km) northeast of the proposed NWMI facility site. In 1968, two sanitary 

22 lagoons were constructed for collection of liquid effluents containing radionuclides, primarily 

23 carbon-14. In 1986, these lagoons were closed, and they were later backfilled. Also in 1986, a 

24 third lagoon was constructed and placed into use. The third lagoon was closed in 2004, drained 

25 in 2011, and backfilled in 2012. Low levels of radioactivity continue to be present at the 

26 lagoons. However, surveys have shown these levels of radioactivity to be very low. In 2011, 

27 the NRC determined that the portion of the site containing the two older backfilled lagoons met 

28 the criteria in 10 CFR 20.1402 for unrestricted use, and that area was released for unrestricted 

29 use. In 2013, the NRC approved a partial site release for unrestricted use for the portion of the 

30 ABC Laboratories site containing the newer backfilled lagoon (NWMI 2015a; ABC 2010, 2011; 

31 NRC 2011a, 2013c, 2013d).

32 In addition, the University of Missouri’s Pickard Hall, which is also within the ROI, contains 

33 legacy radium contamination from radioactive material separation activities conducted in the 

34 1900s through 1930s. Although personnel monitoring is conducted for selected Pickard Hall 

35 faculty and staff, and an internal standard operating procedure is used to help avoid the further 

36 spread of radioactive contamination within the building or to the environment, no radiological 

37 environmental monitoring program is associated with the University of Missouri’s Pickard Hall 

38 (NWMI 2015a; MU 2013). The radioactive material separation activities performed in Pickard 

39 Hall resulted in some radium contamination of subsurface soil in the immediate vicinity of 

40 Pickard Hall, in addition to the contamination within the building. The internal standard 

41 operation procedure used at Pickard Hall helps to avoid any further spread of the subsurface 

42 soil contamination by limiting disturbance of the subsoil (NWMI 2015a; MU 2013).

43 3.8.2.3 Regulations Governing Dose from Human-Made Sources of Radiation

44 The Atomic Energy Act of 1954, as amended (42 U.S.C. 2011 et seq.), gives the NRC authority 

45 to issue and enforce standards that provide an adequate level of protection for public health and 

46 safety and that protect the environment. The NRC staff evaluates the latest radiation protection 

47 recommendations from national and international scientific bodies as a basis for its radiation 

48 protection standards (10 CFR Part 20). A radioisotope production facility utilizing enriched 
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1 uranium must receive a license from the NRC and comply with NRC regulations and conditions 

2 specified in the license to operate. A licensee is required to comply with occupational dose

3 limits for adults (10 CFR Part 20, Subpart C) and radiation dose limits for individual members of 

4 the public (10 CFR Part 20, Subpart D).

5 The NRC staff evaluates the impact to human health from human-made sources of radiation or 

6 radioactive material by comparing the estimated dose to a person (occupational worker or 

7 member of the public) from the radiation source to the NRC’s radiation protection dose limits in 

8 10 CFR Part 20. The dose limits in 10 CFR Part 20 do not apply for radiation doses received by 

9 patients during medical imaging or treatment. Dose is calculated based on the amount of 

10 material, and either the amount of time spent in the vicinity of the radioactive material, or the 

11 amount of time an individual’s body retains radioactive material that has been inhaled or 

12 ingested.

13 The NRC regulations at 10 CFR 20.1201 establish occupational dose limits for adults. The 

14 regulations at 10 CFR 20.1201 specify an annual maximum allowable occupational dose (total 

15 effective dose equivalent or TEDE) of 5 rem to a radiation worker from exposure to radiation 

16 and radioactive material at a licensed facility. The regulations at 10 CFR 20.1201 also specify 

17 limits on occupational doses to individual organs or tissues, including a 50 rem annual 

18 maximum allowable dose to the skin of the extremities.

19 Under 10 CFR 20.2206, the NRC requires licensees to submit an annual report of their results 

20 of individual monitoring for each individual who required monitoring under 10 CFR 20.1502 

21 during a given year. The NRC regulations at 10 CFR 20.2202 and 20.2203 require licensees to 

22 submit reports of incidents and occurrences involving personnel radiation exposures that 

23 exceed regulatory limits. Licensees are required to investigate incidents and occurrences and 

24 to take corrective actions as necessary.

25 The NRC regulations at 10 CFR 20.1301 specify an annual maximum allowable dose of 

26 100 mrem to a member of the public from exposure to radiation and radioactive material at a 

27 licensed facility. In addition, 10 CFR 20.1101(d) imposes a 10 mrem constraint on dose from 

28 airborne radioactive material released into the environment. This dose constraint, which is 

29 applicable to the proposed NWMI facility, implements 10 CFR 20.1101(b), which requires NRC 

30 licensees to use, to the extent practical, procedures and engineering controls based upon sound 

31 radiation protection principles to achieve doses to members of the public and occupational 

32 workers that are as low as is reasonably achievable. The NRC regulations at 

33 10 CFR 20.1302(a) require licensees to make or cause to be made, as appropriate, surveys of 

34 radiation levels in unrestricted and controlled areas (both within and outside the site boundary), 

35 and to measure concentrations of radionuclides in effluents released from the facility, to 

36 demonstrate compliance with dose limits for individual members of the public. The NRC 

37 regulations at 10 CFR 20.2203 require licensees to submit reports of incidents and occurrences 

38 involving radiation exposures to members of the public that exceed regulatory limits.

39 3.8.3 Chemical Hazards

40 Chemicals enter the body through the skin, by inhalation, or by ingestion. Chemical exposure 

41 produces different effects on the body, depending on the chemical and the amount of exposure. 

42 Chemicals can cause cancer, affect reproductive capability, disrupt the endocrine system, and 

43 have other health effects. Acute effects from chemical exposure occur immediately (e.g., when 

44 somebody inhales or ingests a poisonous substance). Chronic or delayed effects result in 

45 symptoms, such as skin rashes, headaches, breathing difficulties, and nausea (NRC 2013b).

46 The EPA is responsible for the regulation of most chemicals that can enter the environment. 

47 The EPA regulates the management, including treatment, storage, and disposal, of hazardous 
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1 chemicals. The EPA administers the following Federal acts related to chemical contamination: 

2 the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA); Toxic Substances Control Act 

3 (TSCA); Resource Conservation and Recovery Act (RCRA); Clean Water Act (CWA); Safe 

4 Drinking Water Act (SDWA); Clean Air Act (CAA); and Comprehensive Environmental 

5 Response Compensation and Liability Act (CERCLA) (NRC 2013b). Other Federal acts are 

6 also implemented in the EPA’s regulations, as applicable.

7 EPA and MDNR regulations require reporting of environmental releases of certain toxic 

8 chemicals manufactured, processed, or otherwise used at a facility, if those releases are above 

9 threshold quantities (EPA 2016b, 2016h; NRC 2013b). Such releases from facilities must be 

10 reported to the EPA Toxics Release Inventory (TRI) Program in accordance with Section 313 of 

11 the Emergency Planning and Community Right-to-Know Act. Chemicals covered by the TRI 

12 program are those that cause cancer or other chronic human health effects, significant adverse 

13 acute human health effects, or significant adverse environmental effects. The current TRI toxic 

14 chemical list contains 594 chemicals. Within a 5-mi (8-km) radius of the Discovery Ridge site 

15 there are 11 facilities that release TRI chemicals to the environment and are required to submit 

16 annual reports on releases to the EPA (EPA 2016h; EPA 2016b).

17 EPA and MDNR regulations also require permitting of facilities that generate hazardous wastes 

18 above threshold quantities. Within the Discovery Ridge Research Park, two facilities, ABC and 

19 IDEXX Bioresearch, are EPA and MDNR permitted hazardous waste generators. These 

20 facilities conduct analytical testing in biological or pharmaceutical applications. Reagent grade 

21 organic and inorganic chemicals, some of which are hazardous materials, are used to conduct 

22 analytical research at these facilities (EPA 2016d). ABC is a large quantity generator and in 

23 2013 this facility generated 17.8 tons of hazardous waste. IDEXX is a small quantity generator 

24 (EPA 2016d). The University of Missouri South Farm (approximately 1.0 mi (1.6 km) from 

25 Discovery Ridge) and the Columbia Environmental Research Center (0.9 mi (1.5 km) from 

26 Discovery Ridge) are also permitted small quantity hazardous waste generators (EPA 2016d). 

27 These facilities are periodically inspected to ensure compliance with applicable waste

28 management regulations.

29 3.8.4 Other Hazards

30 The proposed NWMI facility will be an industrial facility with many of the typical occupational 

31 hazards found at other industrial manufacturing or production facilities. Workplace hazards can 

32 be grouped into physical hazards (e.g., hazards from slips, trips, and falls from a height and 

33 those from transportation, temperature, humidity, and electricity); physical agents (e.g., noise, 

34 vibration, and ionizing radiation); chemicals; and psychosocial issues (e.g., work-related stress) 

35 (NRC 2013b). Occupational hazards are regulated by the Occupational Safety and Health 

36 Administration (OSHA) regulations in Title 29 of the Code of Federal Regulations Part 1910. 

37 The NRC has a memorandum of understanding with OSHA regarding the responsibilities of 

38 each agency with regard to occupational safety and health at NRC-licensed facilities 

39 (OSHA 2013).

40 3.9 Transportation Environments

41 This section describes the local transportation systems, including roadway networks and traffic

42 volumes near the Discovery Ridge site.
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1 3.9.1 Roads

2 Figures 2–1 and 2–2 show major roads and transportation features in the vicinity of the 

3 proposed NWMI facility site at Discovery Ridge. The proposed NWMI facility site is located just 

4 north of Discovery Ridge Drive within the City of Columbia limits. Discovery Drive and 

5 Discovery Parkway would provide access to the proposed NWMI facility site.

6 Discovery Parkway intersects with U.S. Highway 63, a four-lane divided highway in Boone 

7 County, about 0.25 mi (0.4 km) to the south. The proposed NWMI facility at the Discovery 

8 Ridge site would have easy direct access via on- and off-ramps to U.S. Highway 63. 

9 U.S. Highway 63 proceeds north and intersects U.S. Interstate 70 approximately 5 mi (8 km) to 

10 the north. U.S. Highway 63 continues to Jefferson City, Missouri, 31 mi (50 km) to the south. 

11 U.S. Interstate 70 proceeds approximately 125 mi (201 km) east to St. Louis, Missouri, and 

12 125 mi (201 km) west to Kansas City, Missouri. Current average daily traffic volumes for nearby 

13 roads are listed in Table 3–22.

14 Table 3–22. Average Daily Traffic Counts in the Vicinity of the Proposed NWMI Facility 

15 Site 2013

Road Section Average Daily Traffic

Discovery Parkway South of Discovery Lane 644

Discovery Parkway South of U.S. Highway 63 (traffic heading north) 498

Discovery Parkway South of U.S. Highway 63 (traffic heading south) 1,379

Gans Road East of Bearfield Road 1,035

Ponderosa Street South of Nifong Boulevard 1,017

U.S. Highway 63 North of Route 740 47,234

U.S. Highway 63 South of Route 740 26,288

U.S. Highway 63 South of Grindstone Parkway 28,944

U.S. Highway 63 South of Discovery Parkway 26,288

Source: MODOT 2013

16 3.9.2 Airports

17 The nearest airport is the Columbia Regional Airport approximately 7 mi (11 km) south of the 

18 proposed NWMI facility site at Discovery Ridge. The airport is owned and operated by the City 

19 of Columbia. It is also the only public use airport in Boone County.

20 For the 12-month period ending October 31, 2015, the airport had 22,950 aircraft operations or 

21 approximately 63 per day, 75 percent general aviation, 9 percent military, 11 percent air taxi, 

22 and 5 percent air carrier. At that time, 34 aircraft were based at the airport that were 50 percent 

23 single-engine, 26 percent multi-engine, and 24 percent jet (AMR 2016).

24 Two small private airports are located within 10 mi (16 km) of the proposed NWMI facility site at 

25 Discovery Ridge. These airports include the Cedar Creek Airport, approximately 6 mi (10 km) 

26 east and the Sugar Branch Airport, 10 mi (16 km) west of the proposed NWMI facility.

27 Two helicopter ports are located within 10 mi (16 km) of the proposed NWMI facility site at 

28 Discovery Ridge. These two heliports support hospital operations and include the University 
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1 Hospitals and Clinics heliport and the Boone Hospital Center heliport, both of which are located 

2 approximately 4 mi (6 km) northwest.

3 3.9.3 Rail

4 The nearest Union Pacific siding is in Jefferson City, approximately 20 mi (32 km) south of the 

5 proposed NWMI facility site at Discovery Ridge. Union Pacific operates approximately 85 trains 

6 each day (UP 2015).

7 Owned by the City of Columbia and operated by Columbia Water & Light, COLT Railroad 

8 provides rail service to the City of Columbia from Norfolk Southern Railroad’s main line in 

9 Centralia, Missouri. COLT Railroad’s two locomotives move over 1,500 cars a year. The rail 

10 line generally parallels State Highway B to Hallsville and State Highway 124 to Centralia. In the 

11 City of Columbia, the rail line is located just west of the Highway B industrial area, crosses 

12 U.S. Highway 63 approximately 3 mi (5 km) north of U.S. Interstate 70, and ends south of 

13 Rogers Street near the city center, approximately 5 mi (8 km) northwest of the proposed NWMI 

14 facility site at Discovery Ridge (CTR 2016).

15 3.10 Research Reactors

16 This section provides the existing regional and local environmental conditions at the research 

17 reactors where low-enriched (LEU) targets will be irradiated. This section will discuss in detail 

18 only the resources and environments that could potentially be affected by irradiation of LEU 

19 targets. The level of detail varies depending upon the potential for impacts, which is discussed 

20 in Section 4.13. Some resources are not considered in detail because irradiation of LEU targets 

21 at the research reactors are not anticipated to impact that resource area as explained in 

22 Section 4.13. For example, irradiation of LEU targets will not result in land disturbance, external 

23 building modifications, or additional water use; therefore, there would be no impacts on land 

24 use, geology, cultural resources, or water resources. Further, as discussed in Section 4.13, the 

25 irradiation of LEU targets will not require additional workers at MURR and would only add about 

26 10 additional workers at the Oregon State TRIGA Research Reactor (OSTR) for 8 weeks per 

27 year; therefore, the irradiation of targets would have no noticeable socioeconomics impact.

28 3.10.1 University of Missouri Research Reactor 

29 The University of Missouri Research Reactor (MURR) is located in Boone County, Columbia, 

30 Missouri. MURR is a pressurized, light-water moderated and cooled reactor. The reactor is 

31 fueled with high-enriched uranium fuel and has a maximum steady-state power level of 

32 10 megawatts thermal (MW(t)) (MU 2006). MURR is situated on a 7.5 ac (3 ha) lot in a portion 

33 of the University Research Park, approximately 1-mi (1.6-km) southwest of the Missouri 

34 University at Columbia main campus (MU 2006). The staff at MURR consists of approximately 

35 140 full-time employees (MURR 2006). MURR is 4 mi (6.4 km) from the Discovery Ridge site.

36 The Missouri River is approximately 8.5 mi (13.6 km) west of MURR and the nearest stream is 

37 Hinkson Creek, approximately 305 m (1,000 ft.) south of MURR. Makeup secondary coolant 

38 water as a result of evaporative losses, 50 gpm (28 million gallons per year), is obtained from 

39 five wells owned and operated by the University of Missouri (MU 2006). The National Register 

40 of Historic Places (NRHP 2015) lists a number of historical sites within 1.0 mi (1.6 km) from 

41 MURR, including: Sanborn Field and Soil Erosion Plots, Sanford F. Conley House, and the 

42 Francis Quadrangle Historic District. A review of archaeological records of the MDNR and 

43 Archeology Survey of Missouri found no evidence of archeological sites on the 7.5 ac (3.0 ha) 

44 MURR site (MU 2010).
Affected Environment

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1 Air Quality and Noise

2 Boone County, where MURR is located, is designated unclassifiable/attainment for all NAAQS. 

3 The nearest resident is 0.5 mi (0.8 km) north of MURR. Existing noise sources near MURR 

4 include vehicular traffic along South Providence Road (Route 63), cooling towers associated 

5 with MURR, and sports venues (within 0.3 mi (0.48 km) of MURR). The MURR site is located 

6 within the University Research Park; therefore, the NRC staff estimates background noise levels 

7 of 65 dBA, which are typical of commercial areas.

8 Human Health 

9 The routine operation of MURR results in the release of airborne radioactive effluents to the 

10 environment. MURR technical specifications (TS) limit the concentration of radionuclides in 

11 these effluents to help ensure that the public dose limits in 10 CFR 20.1301 will not be 

12 exceeded (MU 2016c). In addition, MURR is required to comply with 10 CFR 20.1101(d), 

13 which, as discussed in Section 3.8.2.3, requires licensees to maintain public doses ALARA by 

14 establishing a 10 mrem constraint on public dose from airborne radioactive material released 

15 into the environment. Table 3–23 summarizes the average concentration, total activity 

16 released, and percent of TS limits for airborne argon-41 (Ar-41) releases in each of the years 

17 2013 through 2015. Other than Ar-41, no other radionuclides were released at average 

18 concentrations greater than 1 percent of MURR TS limits for any of the years 2013 through 

19 2015 (MU 2014, 2015a, 2016d).

20 Table 3–23. MURR Ar-41 Effluents

Reporting Period(a) Average Concentration(b) Total Release % of TS Limit

2015 1.64E-6 μCi/mL(c) 7.35E2 Ci(d) 48.9%

2014 2.59E-6 μCi/mL 1.16E3 Ci 74.3%

2013 2.73E-6 μCi/mL 1.22E3 Ci 78.1%

(a) January 1 through December 31

(b) Averaged over the 1-year reporting period

(c) μCi/mL = microcurie(s) per milliliter

(d) Ci = curies

Sources: MU 2014, 2015a, 2016d

21 Routine operation of MURR also results in the release of liquid radioactive effluents to the 

22 environment. These effluents are released to the sanitary sewer. In 2013 through 2015, the 

23 activity released consisted primarily of tritium (hydrogen-3 or H-3). Table 3–24 summarizes the 

24 sanitary sewer radioactive effluents for each of the years 2013 through 2015. During these 

25 years, MURR was in compliance with the sanitary sewer effluent regulations in 10 CFR 20.2003 

26 (MU 2014, 2015a, 2016d), which require that monthly average liquid effluent radionuclide 

27 concentrations be below the values listed in 10 CFR Part 20, Appendix B, Table 3 for releases 

28 to sewers.
Affected Environment

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1 Table 3–24. MURR Sanitary Sewer Radioactive Effluents

Reporting Period(a) Total H-3 Release Total Other Radionuclide Release

2015 1.04x10-1 Ci(b) 1.78x10-2 Ci

2014 2.60x10-1 Ci 2.43x10-2 Ci

2013 9.82x10-1 Ci 2.13x10-2 Ci

(a) January 1 through December 31

(b) Ci = curies

Sources: MU 2014, 2015a, 2016d

2 No liquid radioactive wastes were reported by MURR as having been packaged and shipped 

3 offsite during the 2013, 2014, or 2015 reporting periods (MU 2014, 2015a, 2016d).

4 Solid radioactive wastes produced by operation of the MURR include high-level and low-level 

5 radioactive wastes. All solid radioactive wastes produced at MURR are packaged and shipped 

6 off site for disposal. The high-level solid waste consists of used nuclear fuel. The U.S. 

7 Department of Energy maintains title to all nuclear fuel used at MURR, and is obligated by 

8 contract to take possession of the fuel after its use at MURR. Used fuel does not leave the 

9 MURR reactor pool until a predetermined cooling period has elapsed since the element was last 

10 removed from the reactor core, and the element has been loaded into NRC-approved shipping 

11 containers for shipment (MU 2006).

12 The solid, low-level radioactive wastes produced by MURR and shipped off site for disposal 

13 during 2013 through 2015 are summarized in Table 3–25.

14 Table 3–25. MURR Solid Low-Level Radioactive Waste Shipments

Reporting Period(a) Total Volume Total Activity

2015 629 ft3(b) 657 mCi(c)

2014 850 ft3 508 mCi

2013 554 ft3 1,205 mCi

(a) January 1 through December 31

(b) ft3 = cubic feet

(c) mCi = millicuries

Sources: MU 2014, 2015a, 2016d

15 MURR reports personnel doses by dividing workers into dosimetry groups, each of which 

16 performs different types of work at MURR. The MURR reactor operations, reactor health 

17 physics, and shipping groups would be responsible for handling, packaging, and shipping the 

18 LEU targets at MURR (NWMI 2015a). Tables 3–26, 3–27, and 3–28 summarize the personnel 

19 doses for the operations, health physics, and shipping groups, respectively, in 2013 through 

20 2015. These doses are within the occupational dose limits for adults listed in 10 CFR 20.1201 

21 (MU 2014, 2015a, 2016d).
Affected Environment

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1 Table 3–26. MURR Occupational Doses (Operations Group)

Reporting 

Period(a) Total TEDE(b,c) Highest Individual TEDE

Highest Individual Extremity 

Dose

2015 17,406 mrem(d) 975 mrem 3,060 mrem

2014 26,527 mrem 1,460 mrem 2,223 mrem

2013 19,489 mrem 1,236 mrem 1,556 mrem

(a) January 1 through December 31

(b) Total TEDE = Collective TEDE to all individuals in dosimetry group

(c) TEDE = total effective dose equivalent

(d) mrem = millirem

Sources: MU 2014, 2015a, 2016d

2 Table 3–27. MURR Occupational Doses (Health Physics Group)

Reporting 

Period(a) Total TEDE(b,c) Highest Individual TEDE

Highest Individual Extremity 

Dose

2015 2,930 mrem(d) 1,115 mrem 2,269 mrem

2014 2,530 mrem 776 mrem 1,312 mrem

2013 1,621 mrem 425 mrem 866 mrem

(a) January 1 through December 31

(b) Total TEDE = Collective TEDE to all individuals in dosimetry group

(c) TEDE = total effective dose equivalent

(d) mrem = millirem

Sources: MU 2014, 2015a, 2016d

3 Table 3–28. MURR Occupational Doses (Shipping Group)

Reporting 

Period(a) Total TEDE(b,c) Highest Individual TEDE

Highest Individual Extremity 

Dose

2015 5,683 mrem(d) 2,098 mrem 4,283 mrem

2014 5,558 mrem 1,441 mrem 3,805 mrem

2013 4,623 mrem 1,565 mrem 3,397 mrem

(a) January 1 through December 31

(b) Total TEDE = Collective TEDE to all individuals in dosimetry group

(c) TEDE = total effective dose equivalent

(d) mrem = millirem

Sources: MU 2014, 2015a, 2016d

4 MURR has an environmental monitoring program to measure offsite doses resulting from 

5 MURR facility operations. This program includes the use of 40 environmental monitoring 

6 stations, each consisting of a three-chip environmental TLD, at various locations within the 

7 fenced, licensed area and also beyond the fenced area at distances up to 907 m (2,976 ft) from 

8 the facility stack. The total net dose equivalent measured at all 40 locations in 2013 was 
Affected Environment

3-70

1 257 mrem, and the total net dose equivalents measured in the years 2009 through 2012 ranged 

2 from 201 to 371 mrem. Approximately 60 percent of these total doses were received at two 

3 TLDs located immediately adjacent to two separate loading docks that are part of the MURR 

4 laboratory building, and well within the fenced area; most other TLDs receive little or no dose 

5 (NWMI 2015a).

6 The MURR environmental monitoring program also includes semi-annual collection and 

7 analysis of environmental samples from eight locations near the MURR facility. Soil and 

8 vegetation samples are taken at all eight locations, water samples are taken at three of the eight 

9 locations, and subsurface soil samples are taken at six of the eight locations. Sampling 

10 performed in 2013 through 2015 has shown minimal environmental impact from MURR 

11 operation (MU 2014, 2015a, 2016d).

12 Transportation Environments

13 MURR is approximately 3.5 mi (5.6 km) southwest of the Interstate-70/U.S. Highway 63

14 intersection. U.S Highway 63 runs north-south and Interstate-70 east-west. Major access 

15 roads to MURR include North Providence Road to the east of MURR and E. Stadium Blvd to the 

16 North. Research Park Drive provides direct access to the site. Table 5–2 provides average 

17 daily traffic counts in the vicinity of MURR. For instance, in 2013, average daily traffic counts 

18 along Providence Road (Route 163), south of Route 740 was 29,802.

19 3.10.2 Oregon State University Research Reactor

20 The OSTR is located in Benton County, Corvallis, Oregon. OSTR is a water cooled reactor. 

21 The reactor is fueled with TRIGA (uranium/zirconium hydride) fuel and operates at a maximum 

22 power level of 1.1 MW(t). OSTR is located within the Oregon State University Radiation Center 

Complex, which is a 47,000 ft2 (4,366 m2 23 ) facility. The Williamette River is approximately 

24 1.60 mi (2.6 km) east of OSTR. OSTR is 2,000 mi (3,219 km) from the proposed NWMI facility 

25 at the Discovery Ridge site.

26 The National Register of Historic Places (NRHP 2015) lists a number of historical sites within 

27 0.5 mi (0.8 km) from the OSTR site boundary, including the J. Leo Fairbanks House and the 

28 College Hill West Historic District John Bexell House. Makeup coolant water for the secondary 

29 coolant system, approximately 1,500 gal (5,700 L) per day as result of evaporative losses, is 

30 obtained from the City of Corvallis (OSU 2004, 2006).

31 Air Quality and Noise

32 Benton County is designated unclassifiable/attainment with respect to NAAQS (40 CFR 81.338). 

33 Residential development is concentrated north of the OSTR and the nearest resident is 0.25 mi 

34 (0.4 km) north of OSTR. Existing noise sources near (within 0.5 mi (0.8 km)) OSTR include 

35 vehicular traffic and sport venues (Goss Stadium, Reser Stadium). Due to the proximity of the 

36 residential areas to OSTR, NRC staff estimates background noise levels of 55 dBA, which are 

37 typical of residential areas.

38 Human Health and Waste Management

39 The routine operation of the OSTR results in the release of airborne radioactive Ar-41 effluent to 

40 the environment. The typical concentration (averaged over a one year reporting period) of 

Ar-41 at the point of release from the OSTR is 1.4x10 41 -7 microcuries per milliliter (μCi/mL), which 

42 corresponds to a total annual release of approximately 20 curies of Ar-41 (NWMI 2015c). 

43 OSTR technical specifications ensure that the public dose from OSTR’s airborne Ar-41 effluent 

44 is in compliance with the public dose limit in 10 CFR 20.1301 and the 10 mrem constraint in 

45 10 CFR 20.1101(d) by requiring that annual average concentration of Ar-41 at the point of 
Affected Environment

3-71

discharge from the OSTR facility not exceed 4x10-6 1 μCi/mL (OSU 2016); OSTR’s annual 

2 average Ar-41 release concentration is well within this limit. No measureable quantities of 

3 radionuclides other than Ar-41 are released from OSTR (NWMI 2015c).

4 Routine operation of OSTR also results in the release of liquid radioactive effluents to the 

5 environment. These effluents are released to the sanitary sewer. In July 2012 through 

6 June 2015, the activity released consisted primarily of H-3. Sewer radioactive effluents are 

7 reported for the Oregon State University (OSU) Radiation Center as a whole, rather than for the 

8 OSTR and Radiation Center laboratories separately; therefore, reported values include liquid 

9 effluent activity released for both the OSTR and the Radiation Center Laboratories. For the 

10 OSU Radiation Center, during each of the annual reporting periods July 2012 to June 2013, 

11 July 2013 to June 2014, and July 2014 to June 2015, the monthly average concentrations of 

12 H-3 in liquid effluents were less than 10 percent of 10 CFR Part 20, Appendix B, Table 3 limits 

13 on releases to sewers, and the monthly average concentrations of all other radionuclides were 

14 less than 1 percent of 10 CFR Part 20, Appendix B, Table 3 limits. Therefore OSTR, and the 

15 OSU Radiation Center, were in compliance with the sanitary sewer effluent regulations in 

16 10 CFR 20.2003 (OSU 2013, 2014, 2015a).

17 OSTR produces other liquid radioactive wastes that are packaged and transferred off site for 

18 disposal. From July 2012 to June 2015, a total of 13.5 gal (51 L) of liquid waste containing 

3.25x10 19 -3 Ci of total activity was transferred off site (OSU 2013, 2014, 2015a).

20 Solid radioactive wastes are produced by operation of the OSTR. All solid radioactive wastes 

21 produced at OSTR are packaged and shipped off site for disposal. During OSTR’s current 

22 20-year license term, starting in 2008 and continuing through 2028, the OSTR licensee does not 

23 anticipate the need to ship any high-level radioactive waste (OSU 2008). The solid, low-level 

24 radioactive wastes produced at OSTR and transferred off site for disposal during each of the 

25 annual reporting periods of July 2012 to June 2013, July 2013 to June 2014, and July 2014 to 

26 June 2015, are summarized in Table 3–29.

27 Table 3–29. OSTR Solid Low-Level Radioactive Waste Shipments

Reporting Period(a) Total Volume Total Activity

2014-2015 23 ft3(b) 5.19x10-3 Ci(c)

2013-2014 38 ft3 1.25x10-4 Ci

2012-2013 34 ft

3 4.62x10-3 Ci

(a) July 1 through June 30

(b) ft3 = cubic feet

(c) Ci = curies

Sources: OSU 2013, 2014, 2015a

28 OSTR facility operating personnel would be responsible for handling, packaging, and shipping 

29 the LEU targets at OSTR. Table 3–30 summarizes the personnel doses for OSTR facility 

30 operating personnel during each of the annual reporting periods of July 2012 to June 2013, 

31 July 2013 to June 2014, and July 2014 to June 2015. These doses are within the occupational 

32 dose limits for adults listed in 10 CFR 20.1201.
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1 Table 3–30. OSTR Occupational Doses

Reporting 

Period(a) Total TEDE(b,c) Highest Individual TEDE

Highest Individual Extremity 

Dose

2014-2015 749 mrem(d) 210 mrem 942 mrem

2013-2014 2,229 mrem 639 mrem 914 mrem

2012-2013 867 mrem 203 mrem 778 mrem

(a) July 1 through June 30

(b) Total TEDE = Collective TEDE to all facility operating personnel

(c) TEDE = total effective dose equivalent

(d) mrem = millirem

Sources: OSU 2013, 2014, 2015a

2 OSTR has an environmental monitoring program to measure offsite doses resulting from facility 

3 operations. This program includes the use of nine environmental monitoring stations, each 

4 consisting of a three-chip environmental TLD, at locations along the fence that surrounds the 

5 reactor. Over a 7-year period ending in 2014, the average annual net dose equivalents 

6 measured at these stations ranged from 7 to 18 mrem (NWMI 2015a).

7 The OSTR environmental monitoring program also includes annual collection and analysis of 

8 environmental samples from 22 locations near the OSTR facility. Soil samples are collected at 

9 four locations, water samples (when available) are collected at four locations, and vegetation 

10 samples are collected at 14 locations. Sampling performed during each of the annual reporting 

11 periods of July 2012 to June 2013, July 2013 to June 2014, and July 2014 to June 2015 found 

12 levels of environmental radioactivity consistent with naturally occurring radioactivity and 

13 comparable to values reported in previous years (OSU 2013, 2014, 2015a).

14 Transportation Environments

15 OSTR is bordered to the west by 35th Street, to the south by South Jefferson Way, to the north 

16 by South Campus Way, and to the east by the South 30th St. Major roads in the vicinity of 

17 OSTR include U.S. Route 20 to the south (0.7 mi (1.1 km) away), NW Harrison Boulevard to the 

18 north (0.5 mi (0.8 km) away), State Highway 99W to the east (1.4 mi (2.3 km) away), and 

19 Interstate-5 (I-5) to the east (11.4 mi (23.2 km) away). Annual average daily traffic volume 

20 along these roads are as follows (ODOT 2014a, 2014b):

21 • Harrison Street/East of State Highway 99W: 11,000-12,900,

22 • along State Route 34 (at State Route 99W intersection): 20,001–30,000,

23 • along State Route 99W (at State Route 34 intersection): 15,001–2000

24 • along Interstate 5 (at State Route 34 intersection): 30,001–50,000, and

25 • along U.S. Route 20 (near 35th street intersection): 16,300–16,900.

26 3.10.3 Third Research Reactor

27 NWMI is also considering use of a third research reactor and is performing an analysis to 

28 support that selection (NWMI 2015a, 2015c). NWMI has stated that the third research reactor 

29 will be similar to the OSTR and located on a university campus (NWMI 2015a). Therefore, the 

30 research reactor design and operations will be similar to what is discussed for the OSTR in 
Affected Environment

3-73

1 Section 3.10.2 above. Distance of the third research reactor to the proposed NWMI facility at 

2 Discovery Ridge will be bounded by 2,000 mi (3,219 km) since the OSTR is the greatest 

3 distance between the proposed Discovery Ridge site and any operating research reactor in the 

4 continental United States. An NRC licensed research reactor is required to comply with 

5 10 CFR Part 20 dose limits. Further, the operating license includes a TS requiring that an 

6 annual report be submitted to the NRC that discloses radioactive effluents released, an estimate 

7 of radionuclides present in effluents, and radiological exposure received by facility personnel.

4-1 

1 4.0 ENVIRONMENTAL IMPACTS OF CONSTRUCTION, 

2 OPERATIONS, AND DECOMMISSIONING

3 This chapter addresses potential environmental impacts related to the proposed construction, 

4 operations, and decommissioning of the Northwest Medical Isotopes, LLC (NWMI), medical 

5 radioisotope production facility (NWMI facility). The U.S. Nuclear Regulatory Commission 

6 (NRC) standard of significance for impacts uses the Council on Environmental Quality (CEQ)

7 terminology for “significantly” (Title 40 of the Code of Federal Regulations (40 CFR 1508.27)). 

8 Because the significance and severity of an impact can vary with the setting of the proposed 

9 action, both “context” and “intensity,” as defined in CEQ regulation 40 CFR 1508.27, were 

10 considered. Context is the geographic, biophysical, and social context in which the effects 

11 would occur. Intensity is the severity of the impact. Based on this, the NRC established three 

12 levels of significance for potential impacts: SMALL, MODERATE, and LARGE. The definitions 

13 of these three significance levels, which are presented in the Interim Staff Guidance to 

14 NUREG-1537 (NRC 2012), follow:

15 SMALL—environmental effects are not detectable or are so minor that they 

16 would neither destabilize nor noticeably alter any important attribute of the 

17 resource. In assessing radiological impacts, the NRC has concluded that those 

18 impacts that do not exceed permissible levels in the NRC’s regulations are 

19 considered SMALL.

20 MODERATE—environmental effects are sufficient to alter noticeably, but not to 

21 destabilize, important attributes of the resource.

22 LARGE—environmental effects are clearly noticeable and are sufficient to 

23 destabilize important attributes of the resource.

24 For this environmental impact statement (EIS), the NRC staff characterized impact levels using 

25 the above definitions (NRC 2012). These impacts are grouped and presented according to the 

26 resource area. Within each resource area, the NRC staff determined the impacts during each of 

27 the three phases: construction, operations, and decommissioning. As described in Section 1.6, 

28 preconstruction is related to the building of the proposed NWMI facility and a combined 

29 construction (preconstruction and NRC-authorized construction) impact level is provided. When 

30 the combined construction impact category level is SMALL for any resource area (land use, 

31 water resources, etc.), no further breakdown of impacts between preconstruction and 

32 NRC-authorized construction will be provided. When the combined construction impact 

33 category level is greater than SMALL for any resource area, the impact from solely 

34 NRC-authorized construction activities will be discussed separately. The impacts from 

35 operations of the proposed medical radioisotope production facility presented in this Chapter 

36 considers those activities associated with facility operations identified in Section 2.3, including 

37 preoperation startup activities, transportation of material to and from the proposed facility, and 

38 processes conducted inside the facility building (target fabrication and scrap recovery, irradiated 

39 target disassembly and dissolution, Mo-99 recovery and purification, and uranium recovery and 

40 recycling). 

41 The NRC staff characterizes the impacts to resources as a single level or as a range of impact 

42 levels. A range of impacts may be provided if environmental conditions are uncertain or if there 

43 are multiple circumstances associated with environmental conditions surrounding the proposed 

44 or alternate sites. For example, a range of impacts may be appropriate to characterize impact 

45 levels if the environment changes in time or space, such as the impacts may be smaller at 

46 certain times or in certain places and larger at other times or places.
Environmental Impacts of Construction, Operations, and Decommissioning

4-2 

1 4.1 Land Use and Visual Resources

2 4.1.1 Land Use

3 4.1.1.1 Construction

4 The proposed Discovery Ridge site currently includes 7.4 acres (ac) (3.0 hectares (ha)) of 

5 pastoral land (NWMI 2015a; NRC 2015b, USGS 2006; Fry et al. 2011). The facility would 

6 occupy a rectangular area approximately 213 by 91 meters (m) (700 by 300 feet (ft)) at the outer 

7 perimeter and cover approximately 1.95 ha (4.8 ac) (NWMI 2015a). The restricted area would 

8 be the area inside the fence surrounding the facility. The unrestricted area would be the area 

9 outside the fence surrounding the main building (NWMI 2015a).

10 Construction of the proposed NWMI facility would permanently disturb and convert 7.4 ac 

11 (3.0 ha) of agricultural land into an industrial area that would include facility buildings, an 

12 administrative building, an employee parking lot, facility access roads, and other support 

13 facilities (Table 4–1). In addition, 0.26 ac (0.1 ha) of an offsite adjacent lot (Lot 14) in the 

14 research park would be temporarily converted from agricultural land to a construction material 

15 staging area (NWMI 2015a, 2015c). Once construction activities are complete, NWMI would 

16 restore temporarily affected areas with vegetation that is common to the Discovery Ridge 

17 Research Park (NWMI 2015c). The remaining portion of the site would likely remain as open or 

18 landscaped areas in accordance with the Discovery Ridge Research Park covenants (MU 2009, 

19 NWMI 2015a). Ground vegetation would include grasses, shrubs, trees and/or ornamental 

20 flowers including native species (NWMI 2015c). The potential temporary and permanent 

21 conversion of up to 7.66 ac (3.1 ha) of pasture/hay would be minor when compared to the 

22 15,158 ac (6,134 ha) of pasture/hay remaining within 5 mi (8 km) of the proposed site.

23 Land use impacts would be confined to the proposed 7.4 ac (3.0 ha) site and 0.26 ac. (0.1 ha) 

24 of offsite agricultural lands immediately adjacent to the proposed site. Therefore, no coastal 

25 zones or areas with a special land use or mineral resources (as described in Section 3.1) would 

26 be affected by the proposed construction of the NWMI facility (NWMI 2015a; NRC 2015b; 

27 NRCS 2016a, 2016b; Find the Data 2016; NOAA 2016).

28 Based on the relatively small amount of pasture/hay that would be permanently converted to 

29 other land uses, the lack of important farmland soils within affected areas, the location of the 

30 proposed facility within an area designated as an industrial certified site, and the lack of special 

31 land use or mineral resources on site, land use impacts from construction would be SMALL.

32 Table 4–1. Acres of Land Required for Construction of the Proposed NWMI Facility

Land Cover Type

Permanent 

Disturbance

Temporary 

Disturbance

Total Land 

Cover Within 

5 mi (8 km)

ac ha ac ha ac ha Percent

Open Water 346 140 <1

Developed, Open Space 4,119 1,667 8

Developed, Low Intensity 4,677 1,893 9

Developed, Medium Intensity 2,770 1,121 6

Developed, High Intensity 911 369 2

Barren 94 38 <1
Environmental Impacts of Construction, Operations, and Decommissioning

4-3

Land Cover Type

Permanent 

Disturbance

Temporary 

Disturbance

Total Land 

Cover Within 

5 mi (8 km)

ac ha ac ha ac ha Percent

Deciduous Forest 15,730 6,366 31

Evergreen Forest 534 216 1

Mixed Forest 469 190 <1

Shrub/Scrub 107 43 <1

Grassland 345 140 <1

Pasture/Hay 7.4 3.0 0.3 0.1 15,158 6,134 30

Cultivated Crops 4,639 1,877 9

Woody Wetlands 363 147 <1

Emergent Herbaceous 

Wetland

2 1 <1

Total(a) 7.4 3.0 0.3 0.1 50,262 20,339 100

(a) Total may add up to more or less than 100 percent due to rounding.

Sources: USGS 2006; Fry et al. 2011; NWMI 2015a

1 4.1.1.2 Operations

2 Operation of the NWMI facility would not require any new land or require land use changes 

3 beyond that required for construction. Therefore, land use impacts during operations would be 

4 SMALL.

5 4.1.1.3 Decommissioning

6 Decommissioning activities would be similar to construction activities because they would 

7 involve heavy equipment to dismantle buildings and remove roadway and parking facilities. 

8 Land requirements to perform these activities would be the same or less than those required 

9 during construction (NWMI 2015a). After decommissioning activities are complete, the 

10 proposed site could remain industrial or could be converted back to agricultural land. Given that 

11 the site is located within a currently existing research park, it is likely that the site would remain 

12 for industrial use, assuming the research park is still operating. Given that land requirements 

13 would be similar to those described during construction and that, after decommissioning is 

14 complete, land would either be industrial, agricultural, or open space, land use impacts during 

15 decommissioning would be SMALL.

16 4.1.2 Visual Resources

17 4.1.2.1 Construction

18 As described in Section 3.1.2, the visual setting of the proposed NWMI facility includes 

19 agricultural, residential, light industrial, and forested viewsheds. The proposed site is currently 

20 used for agricultural purposes, and no existing structures or natural or built barriers, screens, or 

21 buffers occur on site. NWMI would build a Radioisotope Production Facility (RPF) building that 

22 would be approximately 65 ft (20 m) high, 350 ft (107 m) long, and 185 ft (56 m) wide 
Environmental Impacts of Construction, Operations, and Decommissioning

4-4 

1 (NWMI 2015a). The highest point at the NWMI facility would be the three exhaust stacks that 

2 extend 75 ft (66 m) from the ground (NWMI 2015a). The high bay, which would be the second 

3 story above the process area, would be 65 ft (19.8 m) high. NWMI (2015a) estimated that the 

4 stacks would be visible from 2 mi (3.2 km) away. Figure 4–1 is a conceptual rendering of the 

5 proposed NWMI facility based on these dimensions.

6 The activities associated with construction of the NWMI facility (e.g., excavation, earthmoving, 

7 pile driving, and erection) would require large equipment, would significantly alter onsite 

8 conditions, and would partially obstruct views of the existing landscape. However, as described 

9 in Section 3.1.2, the NRC staff determined that the proposed site has low scenic quality 

10 because of a lack of notable features, uniform landform, low vegetation diversity, an absence of 

11 water, mute colors, cultural modifications to adjacent scenery, and a commonality within the 

12 physiographic province. The NRC staff also determined that the proposed site has a low 

13 sensitivity rating because it is in an area with low scenic values resulting from a low amount of 

14 use by viewers, low public interest in changes to the visual quality of the proposed site, a low 

15 sensitivity to changes in visual quality by the type of users in the area, and a lack of special 

16 natural and wilderness areas. In addition, the viewshed surrounding the proposed site is 

17 partially aesthetically altered by light industrial buildings, research facilities, residences, and 

18 roads. Further, once construction activities are complete, NWMI would revegetate open areas 

19 with grasses, shrubs, trees and/or ornamental flowers including native species (NWMI 2015c). 

20 Vegetation could partially mitigate impacts to visual resources given that the majority of the 

21 surrounding viewshed is pasture, hay, or grasses. Based on the low scenic quality and light 

22 industrial viewshed within the vicinity, construction-related aesthetic impacts would be SMALL.

23 4.1.2.2 Operations

24 The appearance of the NWMI facility would not change during operation, other than a small 

25 steam plume that may be visible coming from the exhaust stack. The steam plume from the 

26 exhaust stack is expected to be minimal because opacity associated with the natural gas-fired 

27 boilers tends to be low, and, as described in Section 4.2.1.2, emissions will not be significant. 

28 The plume would be more visible during periods of cold weather, although the size of the plume 

29 would still be relatively small. Therefore, visual impacts during operations would be SMALL.

30 Figure 4–1. Conceptual Rendering of Proposed NWMI Facility

31

32 Source: NWMI 2015a
Environmental Impacts of Construction, Operations, and Decommissioning

4-5

1 4.1.2.3 Impacts from Decommissioning

2 Decommissioning activities would be similar to construction activities because they would 

3 involve heavy equipment to dismantle buildings and remove roadway and parking facilities. 

4 After NWMI completes decommissioning activities, the proposed site could remain industrial or 

5 could be converted back to agricultural land. Given that the site is located within a currently 

6 existing research park, it is likely that the site would remain for industrial use, assuming the 

7 research park is still operating. As the proposed NWMI facility is located in a certified industrial 

8 site and the viewshed surrounding the proposed site is partially aesthetically altered by light 

9 industrial buildings, the NRC staff would not expect any changes to the landscape to 

10 significantly affect any viewsheds. Therefore, visual impacts during decommissioning would be 

11 SMALL.

12 4.2 Air Quality and Noise

13 Air and noise emissions would occur during construction, operations, and decommissioning of 

14 the proposed NWMI facility. Emission sources, pollutants, and durations would be different for 

15 each phase and are discussed below. The region of influence (ROI) for this air quality analysis 

16 is Boone County, which is designated as an attainment/unclassifiable area for all criteria 

17 pollutants. The ROI for the noise analysis is a 1-mi (1.6-km) radius from the site boundary of 

18 the proposed NWMI facility.

19 4.2.1 Air Quality

20 4.2.1.1 Construction

21 During construction, earth-moving equipment, non-road vehicles, and worker and delivery 

22 vehicles will be sources of air emissions. Earth moving activities, including excavation, clearing, 

23 and compacting, will generate fugitive dust on site. Operation of construction equipment will 

24 emit criteria pollutants (particulate matter, carbon monoxide, sulfur dioxide, and nitrogen oxides) 

25 on site from the combustion of fuels in equipment. Table 4–2 identifies construction equipment, 

26 total activity, and material moved during construction. Employee and delivery and shipment 

27 vehicular exhaust will emit criteria air pollutants (particulate matter, carbon monoxide, sulfur 

28 dioxide, and nitrogen oxides) and generate fugitive dust emissions, some of which would occur 

29 on site and others would occur off site. However, fugitive dust emissions should be minimal for

30 vehicles when traveling on paved roads off site. A peak workforce of 82 and a total of 

31 21 deliveries and shipments per week are anticipated during construction (NWMI 2015c). 

32 Completion of the proposed NWMI facility is estimated to take up to 17 months. Fugitive dust 

33 emissions are anticipated to be greatest during the initial site preparation activities and would 

34 vary depending on the level of activity. Therefore, fugitive dust emissions and equipment 

35 exhaust emissions will be localized and temporary.

36 Table 4–2. Equipment and Activity Parameters During Construction

Equipment Type Total Activity (hours) Material Moved (tons)

Bulldozer 100 12,000

Excavator 120 12,000

Front Loader 60 24,000

Compactor 120 N/A

Grader 80 N/A

Paver 80 N/A
Environmental Impacts of Construction, Operations, and Decommissioning

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Equipment Type Total Activity (hours) Material Moved (tons)

Asphalt Roller 80 N/A

Source: NWMI 2015a

1 Construction-related emissions from earth-moving activities, equipment, and on-road vehicles 

2 are presented in Table 4–3. Overall construction-related emissions for criteria pollutants are 

3 well below the significant de minimis levels under the New Source Review program and the 

4 250 tons/year (TPY) threshold for a major source as discussed in Section 3.2.2 of this EIS. 

5 Total greenhouse gas emissions (GHGs) (approximately 750 tons of carbon dioxide equivalents 

6 (CO2eq) per year) would be well below the 75,000 TPY of CO2eq (68,000 metric TPY) threshold 

7 for prevention of significant deterioration (PSD) and Title V permits set in the Greenhouse Gas 

8 (GHG) Tailoring Rule and the U.S. Environmental Protection Agency’s (EPA’s) mandatory GHG 

9 Tailoring Rule (74 FR 56260). Further, construction-related emissions would be less than 

10 1 percent of Boone County annual emissions. Therefore, the NRC staff does not expect 

11 increases in air emissions from construction activities to contribute to concentrations that would 

12 exceed National Ambient Air Quality Standards (NAAQS) in Boone County.

13 Table 4–3. Estimated Emissions During Construction

Emissions(a) (tons)

Source CO NOx SO2 PM10 PM2.5 CO2

Construction Equipment Exhaust 0.10 0.71 0.12 0.03 0.02 66

On-road vehicles Exhaust(b) 3.9 0.8 0.006 0.02 0.02 659

Fugitive dust(c) - - - 1.6 0.28 -

Total 4.0 1.5 0.13 1.7 0.3 725

(a) Total emissions during the 17-month construction phase.

(b) On-road vehicle exhaust emissions account for worker vehicles and delivery vehicles (concrete trucks, 

asphalt trucks, earth haulers, and miscellaneous material deliveries).

(c) Fugitive dust emissions account for earth moving activities and wind erosion of bare ground areas.

Key: CO = carbon monoxide; NOx = nitrogen oxides; SO2 = sulfur dioxide; PM10 = particulate matter of 

10 microns (μm) or less; PM2.5 = particulate matter of 2.5 μm or less; CO2 = carbon dioxide.

Source: NWMI 2015a, 2015c. 2016a

14 The nearest Class I Federal Area to the proposed site is the Hercules-Glades Wilderness Area, 

15 approximately 70 mi (113 km) away. EPA recommends that sources located within 62 mi 

16 (100 km) of a Class I Federal Area be modeled to consider adverse impacts (EPA 1992). Given 

17 the distance and estimated emissions from construction, the NRC staff does not anticipate that 

18 activities from construction could adversely affect air quality and air quality-related values 

19 (e.g., visibility or acid deposition) in the nearest Class I Federal Area. NWMI may need to 

20 obtain an air construction permit from MDNR prior to commencing construction in accordance 

21 with 10 CSR 10-6.060. NWMI intends to initiate the permit review and applicability 

22 determination with MDNR (NWMI 2015c).

23 The emission estimates presented in Table 4–3 do not account for best management practices 

24 (BMPs) or mitigative measures that can be implemented during construction-related activities to
Environmental Impacts of Construction, Operations, and Decommissioning

4-7

1 reduce emissions. For instance, NWMI proposes to control particulate matter by watering 

2 unpaved and disturbed areas, stabilizing spoil piles, revegetating slopes, and minimizing soil

3 disturbance via phased grading (NWMI 2015a). Furthermore, to reduce equipment related 

4 emissions, NWMI proposes to implement the following measures: reduce equipment idle times, 

5 use ultra-low sulfur diesel fuel, and install pollution control devices on construction equipment.

6 Given that (1) air emissions during construction would be local and temporary (duration of 

7 17 months), (2) Boone County is designated as an attainment/unclassifiable area, 

8 (3) construction emissions are well below major air source thresholds, and (4) construction 

9 emissions are not expected to contribute to concentrations that would exceed the NAAQS, the 

10 NRC staff concludes that air quality impacts during construction would be SMALL.

11 4.2.1.2 Operations

12 Air emissions sources from operation of the proposed NWMI facility would be predominantly 

13 from: (1) target fabrication and irradiated target processing; (2) fuel combustion associated with 

14 processing and facility heating purposes; and, (3) vehicular traffic from workers commuting and 

15 from shipments and deliveries during operations.

16 As discussed in Section 2.3.1, NWMI facility operations will include target preparation and 

17 processing for extraction of molybdenum-99 (Mo-99), which involves dissolution of uranium in 

18 nitric acid. Dissolution will result in gases, which include nitrogen oxides (NWMI 2016a). The 

19 offgas will pass through a reflux condenser and nitrogen oxide absorbers prior to being filtered 

20 and discharged into the process exhaust system (NWMI 2015a). Total nitrogen oxide emissions

21 from the radioisotope production process would be 0.05 TPY (0.04 MT/year) (NWMI 2015c, 

22 2016a).

23 Fuel combustion sources housed in the NWMI facility will include five gas-fired boilers and a 

24 diesel generator. NWMI boilers will be used for the heating, ventilation, and air conditioning 

25 (HVAC) system and for process steam used to provide heating for process equipment 

26 (NWMI 2015a, 2015b, 2015c). Three boilers are expected to be operating at any one time (two 

27 heating and one process steam boiler) (NWMI 2015c). The diesel generator will be used for 

28 emergency power, if needed, and will be operated for routine testing and maintenance 

29 (NWMI 2015a). The operation of the gas-fired boilers and diesel generator will emit criteria 

30 pollutants (carbon monoxide, particulate matter, nitrogen oxides, and sulfur dioxide) and GHGs. 

31 Annual emissions from these combustion sources are presented in Table 4–4. NWMI may need 

32 to obtain an air permit from MDNR to install and operate these fuel combustion sources 

33 accordance with 10 CSR 10-6.060 or 10 CSR 10-6.065. NWMI intends to initiate the permit 

34 review and applicability determination with MDNR (NWMI 2015c).

35 Vehicle exhaust from workers and from shipments and deliveries during operations will emit 

36 criteria pollutants (carbon monoxide, particulate matter, nitrogen oxides, and sulfur dioxide) and 

37 GHGs. During operations, 98 workers will be commuting to and from the proposed site. 

38 Shipments to and from the proposed site will include fresh low-enriched uranium (LEU), 

39 unirradiated LEU targets, irradiated targets, Mo-99 product, spent LEU, and waste. The total 

40 projected annual number of shipments is 484 or approximately 10 shipments/week 

41 (NWMI 2015c, 2016a). Vehicle emissions during operations is presented in Table 4–4.

42 Table 4–4. Emissions Sources and Estimated Emissions During Operations

Emissions During Operation (tons/year)

Source CO NOx SO2 PM10 PM2.5 CO2

Target processing - 0.05 - - - -
Environmental Impacts of Construction, Operations, and Decommissioning

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Emissions During Operation (tons/year)

Diesel Generator(a) 0.23 0.5 0.17 0.03 0.03 48.5

Gas-Fired Boilers(b) 18 11 0.13 0.40 0.40 26,000

Vehicles exhaust(c) 2.7 0.3 0.004 0.010 0.009 432

Total 21 12 0.3 0.44 0.44 26,500

(a) Diesel generator emissions are based on emission factors from EPA 2010 and assumes generator 

operated 24 hours per year.

(b) Gas-fired boilers emissions account for operation of 4 boilers as a bounding condition, each operated for 

50 weeks per year, 7 days/week, and 24 hours a day. Emissions are based on emission factors from 

EPA. 

(c) Vehicle exhaust emissions include worker vehicle emissions and shipment and delivery vehicles.

Source: NWMI 2015a, 2015c

1 Operation-related emissions from predominant sources are presented in Table 4–4. Total 

2 operational emissions for criteria pollutants are well below the significant de minimis levels 

3 discussed under the New Source Review program and Title V major operating source threshold 

4 (100 TPY) discussed in Section 3.2.2 of this EIS. Total GHGs (approximately 27,000 tons 

5 CO2eq) per year) would be well below the 75,000 TPY of CO2eq (68,000 metric TPY) threshold 

6 for PSD and Title V permits set in the Greenhouse Gas (GHG) Tailoring Rule. Further, 

7 operation-related emissions for carbon monoxide, nitrogen oxides, sulfur dioxide, and 

8 particulate matter are less than 1 percent of Boone County annual emissions and carbon 

9 dioxide emissions are less than 5 percent. Therefore, the NRC staff does not expect increases 

10 in air emissions from operations to contribute to concentrations that would interfere with the 

11 maintenance of NAAQS or degrade Boone County’s attainment/unclassifiable designation.

12 The nearest Class I Federal Area to the proposed site is the Hercules-Glades Wilderness Area, 

13 approximately 70 mi (113 km) away. EPA recommends that sources located within 62 mi 

14 (100 km) of a Class I Federal Area be modeled to consider adverse impacts (EPA 1992). Given 

15 the distance and estimated emissions from operation, the NRC staff does not anticipate that 

16 activities from operation could adversely affect air quality and air quality-related values 

17 (e.g., visibility, acid deposition) in the nearest Class I Federal Area.

18 NWMI proposes to develop a comprehensive program for controlling GHG emissions

19 associated with operation of the NWMI facility. This will include developing a GHG emission 

20 inventory, implementing methods for avoiding or minimizing GHG emissions identified in the 

21 inventory and encouraging carpooling and other measures to minimize GHG emissions due to 

22 vehicle traffic during operation (NWMI 2015a).

23 Given that operation-related air emissions are well below the significant de minimis levels and 

24 Title V major source threshold, operational emissions are not expected to contribute to 

25 concentrations that would exceed NAAQS or degrade Boone County’s air quality designation 

26 (attainment/unclassifiable area) therefore, the NRC staff concludes that air quality impacts 

27 during operation would be SMALL.

28 4.2.1.3 Decommissioning

29 Decommissioning activities would be similar to construction activities. The decommissioning 

30 activities would include, for example, vehicular traffic, earth-moving equipment, demolition of 

31 structures, and dismantlement and decontamination of systems over a period of up to 

32 24 months (NWMI 2015a, 2016a). Equipment, worker vehicles and truck shipments will emit 

33 criteria air pollutants (particulate matter, carbon monoxide, sulfur dioxide, and nitrogen oxides) 
Environmental Impacts of Construction, Operations, and Decommissioning

4-9

1 and GHGs. Demolition and dismantlement of structures will emit fugitive dust. A daily peak 

2 workforce of 81 and a total of 21 deliveries and shipments per week are anticipated during 

3 decommissioning (NWMI 2015c). Equipment used and diesel fuel consumption for 

4 decommissioning activities would be similar to those presented in Table 4–2. Emissions from 

5 decommissioning would be localized and temporary and are presented in Table 4–5. Emissions 

6 are well below the significant de minimis levels discussed under the New Source Review

7 program and the 250 TPY threshold for a major source as discussed Section 3.2.2 of this EIS. 

8 Therefore, the NRC staff does not expect increases in air emissions from decommissioning 

9 activities to contribute to concentrations that would exceed the NAAQS or prevent Boone 

10 County from maintaining its attainment designation.

11 Table 4–5. Air Emissions During Decommissioning

Emissions(a) (tons)

Source CO NOx SO2 PM10 PM2.5 CO2

Construction Equipment Exhaust 0.10 0.71 0.12 0.03 0.02 66

On-road vehicles Exhaust(b) 5.5 1.0 0.009 0.1 0.1 920

Fugitive dust - - - 1.6 0.28 -

Total 5.6 1.7 0.13 1.7 0.4 986

(a) Total emissions during 24-month decommissioning phase.

(b) On road emissions calculated from EDF-3124-0005 (NWMI 2016a) and based on a 24-month 

decommissioning duration.

Source: NWMI 2015a, 2015c, 2016a

12 Given that air emissions during decommissioning would be local and temporary 

13 (decommissioning phase of up to 24 months) and that decommissioning-related emissions are 

14 well below major air source thresholds, the NRC staff concludes that the air quality impact 

15 associated with the decommissioning phase would be SMALL.

16 4.2.2 Noise

17 4.2.2.1 Construction

18 Noise sources associated with building the proposed NWMI facility will include construction 

19 equipment on site and workforce and shipment/delivery vehicles. Increased traffic volumes 

20 because of 82 workers and 21 deliveries per week can increase noise emissions along road and 

21 highways near the proposed Discovery Ridge site. While workers would be able to access the 

22 site using a combination of routes, it is reasonable to assume that U.S. Highway 63, St. Lenoir 

23 Street, Discovery Drive, and Discovery Parkway will experience an increase in traffic volumes 

24 as a result of the construction workforce and deliveries because these are access roads to the 

25 proposed site. NWMI modeled highway noise to estimate noise levels when an additional 

26 100 vehicles are added to peak traffic volume along U.S. Highway 63 (NWMI 2015c, 2016a, 

27 2016d). An additional 100 vehicles will increase noise by 1 decibel on the A-weighted scale 

28 (dBA) at 85 m (280 ft) distance from U.S. Highway 63 and at the nearest residence to the 

29 proposed Discovery Ridge site. Most people are unable to discern noise level differences less 

30 than 3 dBA.

31 Noise emissions will vary with each phase of construction and will depend on the duration and 

32 mix of equipment used. The types of equipment that would be used on site during construction 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 are listed in Table 4–2. Noise emissions from equipment that will be used during construction 

2 are predicted to be in the 80- to 85-dBA range at a 50-ft (15-m) distance (FHWA 2006); 

3 however, noise levels attenuate rapidly with distance. As discussed in Section 3.2.3, the 

4 nearest noise sensitive receptor is the IDEXX BioResearch facility, which is approximately 

5 0.16 km (0.1 mi; 528 ft) from the proposed site. At a distance of 0.16 km (0.1 mi; 528 ft), the 

6 NRC staff estimates noise levels from construction equipment to be 59 to 64 dBA (GSU 2016). 

7 The nearest residence is approximately 0.4 km (0.27 miles; 1,425 ft) from the proposed site. At 

8 this distance, the NRC staff estimates noise levels from construction equipment to be 50 to 

9 55 dBA (GSU 2016). Noise levels from construction equipment can further be dampened by the 

10 existing building walls at the IDEXX BioResearch facility and existing walls of the nearest 

11 residence. Noise levels from construction equipment to noise sensitive receptors are not 

12 anticipated to exceed the existing noise levels from traffic on U.S. Highway 63 (69 dBA), 

13 agricultural equipment (84 dBA), or estimated ambient background noise levels (60 to 65 dBA) 

14 and, therefore, will not be noticeable. Further, noise from construction equipment would be 

15 localized, short term, and intermittent during operation of equipment.

16 Control measures that could be used to minimize noise emissions from construction activities 

17 include routine maintenance of equipment (e.g., lubrication of moving parts, 

18 replacement/adjustment of worn or loose parts), industry best practices (e.g., minimizing 

19 equipment idle time and simultaneous use of equipment), shielding high noise sources, and 

20 conducting activities during daytime when noise levels are greatest.

21 Given the minor (1 dBA) increase in noise levels as a result of additional vehicle traffic and 

22 estimated noise levels from construction equipment not exceeding existing ambient noise levels, 

23 the NRC staff concludes that offsite noise impacts from construction would be SMALL.

24 4.2.2.2 Operations

25 Noise sources during operation would be primarily from workforce and shipment vehicles. 

26 Noise from operating equipment would be contained inside buildings and is not anticipated to be 

27 audible outside the proposed NWMI building at the site. Increased traffic volumes because of a 

28 daily workforce of 98 and 10 deliveries per week can increase noise emissions along nearby 

29 road and highways. NWMI modeled highway noise to estimate noise levels when an additional 

30 100 vehicles are added to peak traffic volume along U.S. Highway 63 (NWMI 2015c, 2016a, 

31 2016d). An additional 100 vehicles will increase noise by 1 dBA at 85 m (280 ft) distance from 

32 U.S. Highway 63 and at the nearest residence. Most people are unable to discern noise level 

33 differences less than 3 dBA. Further, increase in noise levels from vehicles will not be 

34 continuous, but rather intermittent during work shifts.

35 Given that noise levels from operating equipment are not expected to be audible beyond the 

36 building facility and additional noise levels from worker and shipment vehicles are minor 

37 (increase of 1 dBA), the NRC staff concludes that offsite noise impacts during operation would 

38 be SMALL.

39 4.2.2.3 Decommissioning

40 Noise emissions during decommissioning would be similar to those generated during 

41 construction. Increased noise levels would occur from increased traffic volumes and from the 

42 use of equipment on site. A daily peak workforce of 81 and a total of 21 deliveries and 

43 shipments a week are anticipated during decommissioning. NWMI modeled highway noise to 

44 estimate noise levels when an additional 100 vehicles are added to peak traffic volume along 

45 U.S. Highway 63 (NWMI 2015c, 2016a, 2016c, 2016d). An additional 100 vehicles will increase 

46 noise by 1 dBA at 85 m (280 ft) distance from U.S. Highway 63 and at the nearest residence. 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 Most people are unable to discern noise level differences less than 3 dBA. Further, increase in 

2 noise levels from vehicles will not be continuous but rather intermittent during work shifts.

3 Equipment used during decommissioning activities would be similar to those presented in Table 

4 4–2. Therefore, as discussed above, noise levels from demolition equipment and vehicles to 

5 noise sensitive receptors are not anticipated to exceed existing noise levels from traffic on 

6 U.S. Highway 63 (69 dBA), agricultural equipment (84 dBA), or estimated ambient background 

7 noise levels (60-65 dBA) near the Discovery Ridge site and, therefore, will not be noticeable.

8 Given the minor (1 dBA) increase in noise levels as a result of additional vehicles and given that 

9 estimated noise levels from decommissioning activities would be bounded by existing ambient 

10 noise levels, the NRC staff concludes that offsite noise impacts from decommissioning would be 

11 SMALL.

12 4.3 Geologic Environment

13 4.3.1 Construction

14 Construction of the proposed NWMI facility at the Discovery Ridge site will temporarily disturb 

15 the entire site (7.4 ac (3.0 ha)), as detailed in Section 4.1.1.1. Ground-disturbing activity, 

16 including site clearing, grading, grubbing, surface compaction, excavation work, and 

17 construction-related vehicle traffic, would expose site soils and sediments to wind and water 

18 erosion. Site development and associated ground disturbance exceeding 1 ac (0.4 ha) in size 

19 requires a permit from the City of Columbia in accordance with Chapter 12A, Article II (Land 

20 Preservation) of the City’s Code of Ordinances (City of Columbia 2015). This permit is required 

21 before any site work can begin, and this authorization is in addition to any other required 

22 approvals, such as permits from the Missouri Department of Natural Resources (MDNR). The 

23 NWMI Environmental Report (ER) (NWMI 2015a) lists relevant construction-related permit 

24 requirements, which the NRC has summarized in Appendix B of this EIS.

25 Further, the City of Columbia requires that the project proponent submit a detailed site 

26 development plan for City approval. This development application package must include a soil

27 erosion and sediment control plan and a stormwater management plan (City of Columbia 2015, 

28 2016d). These plans entail the implementation of construction-related BMPs for soil erosion 

29 and sediment control and stormwater pollution prevention during site development, facility 

30 construction, and for post development. For example, BMPs include use of gravel aprons to 

31 stabilize construction site entrances; sediment traps, sediment fencing, check dams and staked 

32 hay bales to manage runoff and erosion; use of fugitive dust controls, mulching and geotextile 

33 matting, stockpile covers, and rapid reseeding of disturbed areas to limit soil loss; and the 

34 retention of native vegetation and drainage ways, where practicable. These measures would 

35 serve to minimize soil erosion and loss and ensure that soil impacts are limited to the immediate 

36 construction site, while also ensuring that the impacts are temporary in nature. NWMI states 

37 that dust production and erosional impacts due to site clearing and grading would be mitigated 

38 by using construction and erosion control BMPs (NWMI 2015a). Section 4.4.1 presents 

39 additional information on relevant stormwater discharge and management requirements.

40 NWMI would be required to obtain the appropriate permits from the County and City, if not 

41 already obtained by the developer for the Discovery Ridge Research Park (NWMI 2015a).

42 Following site grading, trenching and excavation, work for utility routings and emplacement of 

43 foundation structures (i.e., footings and floor slabs) for the NWMI facility would be conducted. 

44 Earthwork associated with utility infrastructure should be minimal. Discovery Ridge Research 

45 Park already has the necessary utility infrastructure (i.e., electric power, natural gas, water, and 
Environmental Impacts of Construction, Operations, and Decommissioning

4-12

1 sanitary sewer) required to support the proposed NWMI facility on Lot 15. The utility providers 

2 will extend service lines to the NWMI facility site from utility connections presently located at the 

3 southwest corner of the site (MU 2009; NWMI 2015a). Utility routings and other foundation 

4 slabs and footings typically require excavation to a depth of about 5 ft (1.5 m). Excavation work 

5 would also be involved for a stormwater detention basin (NWMI 2015a).

6 Mineral and other geologic resources would be required to support facility construction such as 

7 granular stone (e.g., typically crushed aggregate (sand and gravel)), as summarized in 

8 Section 2.2, Table 2–1. As noted in Section 3.3.1, construction aggregate is widely available 

throughout Boone County and northeast Missouri. NWMI estimates that 4,260 cubic yards (yd3 9 ) 

(3,360 cubic meters (m3 10 )) of concrete would also be used for facility construction, in addition to 

11 precast concrete, and would be obtained from offsite commercial vendors 

12 (NWMI 2015a, 2015c). Consequently, no onsite concrete batch plant would be required. The 

13 mineral products that comprise concrete (i.e., Portland cement, sand, gravel, and other 

14 additives) are widely available in the region or are not otherwise limited in commercial 

15 availability.

16 With regard to excavation for facility structures, portions of the RPF building would be located at 

17 a floor elevation of 15 ft (4.6 m) below finished grade, based on preliminary facility designs. 

18 This below-grade portion would house the process hot cells and waste storage areas 

19 (i.e., high-integrity container vault) (see Section 2.3.1). The design calls for the subflooring to 

20 consist of a reinforced concrete mat slab 18 to 24 in. (46 to 61 cm) thick. The maximum depth 

21 of excavation could range from 17 to 23 ft below grade (5.2 to 7 m) (NWMI 2015a, 2015c). 

NWMI estimates that approximately 9,000 yd3 (6,900 m3 22 ) of earthwork material will be 

23 generated by site construction and excavation activities (see Section 2.2) 

24 (NWMI 2015a, 2015c). NWMI indicated its desire to limit overexcavation and to reuse 

25 excavated soils for backfill (NWMI 2015a, 2015c). However, soils at the Discovery Ridge site 

26 present a number of construction challenges and limitations for workability and stability that in 

27 turn can affect excavation work and needed material.

28 The geotechnical study (Terracon 2011a) found that site soils classify as lean to fat clay and fat 

29 clay, as further described in Section 3.3.1. The soils are rated as poorly drained with low 

30 permeability. At the time they were evaluated by Terracon (2011a), site soils exhibited a high 

31 water content with the potential for perched groundwater conditions. Most significantly, the fat 

32 clays have a high/shrink swell potential. High shrink/swell soils are difficult to work and 

33 undesirable for backfill. Consequently, these conditions may require additional overexcavation 

34 and removal of site soils in excavations and foundation cuts so that they can be replaced with 

35 suitable engineered backfill to properly support and safeguard concrete structures. Terracon 

36 (2011a) identified the need for the use of engineered backfill to provide a low-volume change 

37 layer for proper support of concrete surfaces. Therefore, additional excavation may be required 

38 and some or a substantial proportion of the excavated material may need to be replaced with 

39 engineered backfill.

40 As discussed in Sections 3.3.1 and 3.3.2, the depth to bedrock beneath the Discovery Ridge 

41 site has not been determined with accuracy, and the relative proximity of karst terrane presents 

42 an additional concern. Available information indicates that the depth to weathered bedrock 

43 ranges between 13 and 25 ft (4 to 7.6 m) below ground surface (bgs), with the true depth likely 

44 to be on the higher end of the cited range. Depending on the final depth of excavation and 

45 depth to bedrock, excavation may require techniques such as drilling, ripping, or blasting. The 

46 integrity of the bedrock surface requires assessment with respect to the possible presence of 

47 karst features.
Environmental Impacts of Construction, Operations, and Decommissioning

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1 In addition, the potential for wet soils at relatively shallow depths and the possibility of a shallow 

2 water table (see Section 3.3.1) or perched groundwater could require the use of bracing, even in 

3 shallow trenches, and other measures (e.g., cofferdams) during construction of the below-grade 

4 portion of the facility that ultimately impacts the final facility design and, therefore, excavation 

work. 5 

6 NWMI will conduct site-specific geotechnical and hydrological studies of the Discovery Ridge 

7 site to characterize site conditions in support of final facility design (NWMI 2015c). These 

8 studies would include drilling a suite of boreholes to a maximum depth of 50 ft (12 m) bgs, or up 

9 to 20 ft (6.1 m) into competent bedrock. Soil and rock profiles would be characterized for each 

10 boring and engineering, geotechnical, and hydrologic properties would be determined. Depth to 

11 groundwater and groundwater quality would also be characterized during these studies 

12 (NWMI 2015c, 2016a).

13 Mineral and other geologic resources, such as granular stone (e.g., typically crushed aggregate 

14 (sand and gravel)), would be required to support facility construction, as summarized in 

15 Section 2.2, Table 2–1. As noted in Section 3.3.1, construction aggregate is widely available 

16 throughout Boone County and northeast Missouri.

NWMI estimates that 4,260 yd3 (3,360 m3 17 ) of concrete would also be used for facility 

18 construction, in addition to precast concrete, which would be obtained from offsite commercial 

19 vendors (NWMI 2015a, 2015c). Consequently, no onsite concrete batch plant would be 

20 required. The mineral products that comprise concrete (i.e., Portland cement, sand, gravel, and 

21 other additives) are widely available in the region or are not otherwise limited in commercial 

22 availability.

NWMI estimates that approximately 9,000 yd3 (6,900 m3 23 ) of earthwork material will be 

24 generated by site construction and excavation activities (see Section 2.2). As stated in the ER, 

25 NWMI assumes that these excavated soils and sediments would be used as backfill. As 

26 referenced above, some or a substantial proportion of this excavated material may need to be 

27 replaced with engineered backfill, although soils with the necessary engineering properties are 

28 readily obtainable throughout the Columbia area.

29 Construction activities would require the consumption of geologic resources and would have the 

30 potential to increase soil erosion, but the necessary geologic resources are widely available 

31 within the region and erosion would be managed with the implementation of BMPs as required 

32 by permit requirements. Site conditions such as depth to bedrock, high shrink/swell soils, and 

33 wet, low permeability soils would increase the potential for construction impacts and the 

34 possible need for construction mitigation. However, completion of detailed site-specific 

35 geotechnical studies would serve to reduce the cited uncertainties with respect to site geologic 

36 and soil conditions. As a result, the NRC staff concludes that the impacts on the geologic 

37 environment from the construction of the proposed NWMI facility would be SMALL overall.

38 4.3.2 Operations 

39 During facility operations, previously disturbed areas would not be subject to long-term soil

40 erosion. Areas disturbed during construction would be within the footprint of the completed 

41 facility or overlain by other impervious surfaces (e.g., roadways and parking lots), or 

42 revegetated.

43 NWMI would conduct all facility process activities within enclosed buildings, and vehicle traffic

44 would be confined to paved surfaces (e.g., roads and parking areas) that service the facility. As 

45 a result, incremental impacts on geology and soils would be negligible during operations.
Environmental Impacts of Construction, Operations, and Decommissioning

4-14

1 The NRC staff does not expect site geologic conditions to affect the operation of the NWMI 

2 facility. The proposed site is located in a region with a relatively low seismic hazard compared 

3 with adjoining regions, as described in Section 3.3.3. Final facility design and construction 

4 would comply with applicable building codes and standards, which provide for the evaluation of 

5 site geologic and soil conditions, including potential seismic hazards. Completion of 

6 site-specific geotechnical and hydrological studies, as discussed in Section 4.3.1, would inform 

7 final design and construction considerations. Therefore, the NRC staff concludes that the 

8 operational impacts associated with the geologic environment at the proposed site would be 

9 SMALL.

10 4.3.3 Decommissioning

11 Compacted site soils and underlying sediments would be disturbed by facility demolition and 

12 decontamination work. The impacts on site geology and soils would be similar in scope to those 

13 described for construction. Site clearing to restore the proposed site to a reusable condition 

14 would be subject to applicable permits and approvals (e.g., demolition or clearance permit), and 

15 the applicable provisions, including Chapter 6, Article II (Building Code) of the City of 

16 Columbia’s Code of Ordinances (NWMI 2015a; City of Columbia 2015).

17 Before beginning to dismantle onsite structures, decommissioning contractors would remove 

18 waste materials and contaminated media from the structures. Materials would be packaged and 

19 properly disposed of as discussed in Section 4.9. Thus, these materials would not pose a 

20 contamination threat to site soils or water resources. Soils and other media would be sampled 

21 to determine the presence of any contamination and associated waste management 

22 requirements. NWMI would be required to conduct all decommissioning activities in accordance 

23 with a decommissioning plan submitted to the NRC for approval and applicable regulations, as 

24 described in Section 2.9.

25 The NRC staff concludes that impacts on the geologic environment from facility 

26 decommissioning would be SMALL.

27 4.4 Water Resources

28 4.4.1 Surface Water

29 4.4.1.1 Construction

30 Surface water resources would not be directly impacted by site construction activities. No 

31 natural surface water features occur on the Discovery Ridge site. As discussed in 

32 Section 3.4.1.1, the natural hydrologic regime of the site and immediate vicinity has been 

33 altered by previous development activities that include pond and stormwater management 

34 facility construction. The closest natural watercourse is Gans Creek, which is located 

35 approximately 0.35 mi (0.56 km) south of the site at its closest point.

36 During construction, however, stormwater runoff from construction areas could potentially affect 

37 downstream surface water quality if not properly managed. As detailed in Section 4.3.1, NWMI 

38 would be required to obtain a Land Disturbance Permit from the City of Columbia and submit 

39 related plans for City approval before any ground-disturbing activities or facility construction 

40 could begin on the site. The City would require that appropriate soil erosion and sediment 

41 control BMPs be used to minimize soil erosion and the stormwater transport of suspended 

42 sediment and other pollutants. These measures must also address construction site pollutants 

43 that could affect offsite surface water quality.
Environmental Impacts of Construction, Operations, and Decommissioning

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1 Construction stormwater runoff is also subject to regulation in accordance with Section 402 of 

2 the Federal Water Pollution Control Act (i.e., Clean Water Act (CWA) of 1972, as amended 

3 (33 U.S.C. 1251 et seq. )), and the Missouri Clean Water Law. CWA Section 402 establishes 

4 the National Pollutant Discharge Elimination System (NPDES) (see Section 3.4.1.2). 

5 Specifically, the State of Missouri has developed an NPDES general permit (i.e., Missouri State 

6 Operating Permit MO-RA) that must be obtained by owners and operators for the discharge of 

7 stormwater and certain non-stormwater discharges (e.g., dewatering) from land-disturbance 

8 sites that disturb 1 ac (0.4 ha) or more, or less than 1 ac (0.4 ha) but are part of a larger 

9 development. General permit MO-RA has an effective date of February 2012, and is valid until 

10 February 2017 (states typically reauthorize general permits every 5 years). Facilities that 

11 discharge stormwater to a combined storm sewer are exempt from stormwater permit 

12 requirements (MDNR 2012, 2016g). This State general permit requires permit holders to 

13 develop and implement a stormwater pollution prevention plan (SWPP), the purpose of which is 

14 in part to ensure the proper design, implementation, management, and maintenance of BMPs to 

15 prevent the introduction of sediment and other pollutants in stormwater discharges 

16 (MDNR 2012).

17 NWMI indicates that it would obtain coverage under a Missouri General Operating Permit, if 

18 applicable for the site, or would comply with criteria and standards of the Discovery Ridge 

19 Master Storm Water Management Plan (NWMI 2015a). A separate County approval, a 

20 Stormwater Discharge Permit, may also be required for the discharge of any stormwater into a 

21 municipal storm sewer system or other publicly owned storm sewer system. The approval 

22 ensures that the receiving system has adequate capacity for any increases in peak flow rates 

23 and volumes (Boone County 2010, 2016b).

24 Finally, a stormwater management plan must also be prepared and approved by the City of 

25 Columbia in accordance with Chapter 12A, Article V (Stormwater Management) of the City’s 

26 Code of Ordinances. As indicated in Section 4.3.1, the City must approve the plan before a 

27 Land Disturbance Permit can be issued. The stormwater management plan must in part 

28 address BMPs used to control the peak flow rates of stormwater discharge associated with 

29 specified design storms and to reduce the generation of stormwater runoff.

30 No surface water or onsite groundwater would be withdrawn to support facility construction. 

31 Section 4.4.2 presents the NRC’s analysis of groundwater use impacts.

32 There would also be no sanitary wastewater discharges during construction. In accordance with 

33 common construction practices and as stated by NWMI (2015c), portable restroom facilities, 

34 serviced by a commercial vendor, would be used during site construction. Section 4.9 

35 describes waste management impacts in detail.

36 The proposed site is not located in an area susceptible to flooding or in a delineated floodplain, 

37 as discussed in Section 3.4.1. The NRC staff does not expect that site construction activities 

38 would have any direct impact on the floodplain of Gans Creek, which is located approximately 

39 0.35 mi (0.56 km) south of the NWMI facility site at is closest point.

40 Under CWA Section 401, an applicant for a Federal license or permit to conduct any activities, 

41 including facility construction or operation, that may cause a discharge into navigable waters is 

42 required to provide the Federal licensing agency with a certification from the state or agency 

43 having jurisdiction in which the discharge would originate (see Section 3.4.1.2). This water 

44 quality certification signifies that discharges from the project or facility to be licensed by the 

45 Federal agency will comply with CWA requirements and will not cause or contribute to a 

46 violation of state water quality standards. A Federal agency cannot issue a license or permit to 

47 an applicant until the required certification is provided, or the responsible state or agency has 

48 waived the requirement. The NRC recognizes that some NPDES-delegated states explicitly 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 integrate their 401 certification process with NPDES permit issuance. The State of Missouri 

2 regulations for administering its water quality certification process are at 10 CSR 20-6.060.

3 The only regulated direct discharges from the proposed facility involve stormwater associated 

4 with construction activity. As previously described, NWMI would obtain coverage under a 

5 State-issued NPDES general permit (i.e., Missouri State Operating Permit MO-RA) for such 

6 discharges. Permit provisions are intended to ensure that the State’s water quality standards 

7 are met. NWMI has stated that no State certification is required under CWA Section 401

8 (NWMI 2015a). NWMI also has stated that it would seek a waiver from the State 

9 (NWMI 2015c). However, because the NRC cannot issue a construction permit without the 

10 required certification, NWMI must provide the NRC with either a 401 certification from the State 

11 of Missouri, a waiver, or other State documentation that a Section 401 certification is not 

12 necessary.

13 No natural surface water features occur on the proposed site, and previous activities have 

14 altered the natural hydrology of the site. NWMI must prepare site-specific plans and implement 

15 BMPs in accordance with local and MDNR requirements to mitigate the potential impacts on 

16 surface water quality associated with construction activities. NWMI would not divert or withdraw 

17 surface water to support facility construction. Based on these considerations, the NRC staff 

18 concludes that the impacts on surface water hydrology, quality, and use from the construction of 

19 the proposed NWMI facility would be SMALL.

20 4.4.1.2 Operations

21 During operations, there would be no direct impact on surface water features and no direct 

22 discharge of industrial wastewater to surface water bodies. The NRC staff anticipates that there 

23 would be no measurable impacts on surface water quality. Stormwater would be collected and 

24 discharged from the NWMI facility property to lined, engineered stormwater basins. NWMI 

25 would use BMPs to manage stormwater runoff from paved and compacted surfaces to drainage 

26 ditches and basins (NWMI 2015a).

27 The University of Missouri (MU) will require that stormwater discharges from the NWMI facility 

28 site comply with the master stormwater management plan developed for the Discovery Ridge 

29 Research Park (MU 2009; NWMI 2015a). This would include compliance with applicable 

30 provisions of City ordinances. More precisely, the site-specific stormwater management plan 

31 (see Section 4.4.1.1) required by the City of Columbia must address BMPs used to control the 

32 peak flow rates of stormwater discharge associated with specified design storms and to reduce 

33 the generation of stormwater runoff. As a required element of the plan, NWMI will have to 

34 maintain a written operation and maintenance manual for the facility’s permanent stormwater 

35 management facilities to ensure that the permanent stormwater facilities, once constructed, 

36 continue to function as designed.

37 Additionally, as referenced in Section 4.4.1.1, a separate Stormwater Discharge Permit may 

38 also be required from Boone County for the discharge of facility stormwater runoff into a 

39 municipal storm sewer system. However, NWMI may be able to address this requirement as 

40 part of the discharge approval process under the Discovery Ridge Research Park master 

41 stormwater management plan.

42 NWMI states that it would obtain an NPDES general permit for stormwater discharges

43 associated with industrial activity (NWMI 2015a, 2015c) (see Appendix B). Under Section 402 

44 of the CWA and MDNR’s regulations for implementing the NPDES permit program for 

45 stormwater (10 CSR 20-6.200), certain industrial activities require a permit from the MDNR for 

46 their stormwater discharges. If applicable, MDNR may either issue NWMI a general permit for 

47 the appropriate industrial category or will require that the facility be covered under an NPDES 
Environmental Impacts of Construction, Operations, and Decommissioning

4-17

1 individual permit (MDNR 2014b). Nonetheless, NWMI does not appear to fall into any of the 

2 industrial classifications requiring permit coverage. It also appears that the nature of NWMI’s 

3 proposed activities would meet the “no exposure” exemption criteria as no industrial materials, 

4 products, or wastes will be exposed to stormwater runoff from the NWMI facility. Stormwater 

5 runoff from the facility site would normally only consist of runoff from landscaped grounds, 

6 parking lots, roads, and roof drainage. NWMI may still be required to file a “no exposure 

7 certification” form with MDNR (MDNR 2014b).

8 The RPF building of the NWMI facility is designed to have zero liquid discharge from the RCA. 

9 There would be no liquid radioactive effluents released from the facility (NWMI 2015a, 2015c). 

10 Sections 2.7, 2.8, and 4.9 of this EIS separately discuss the treatment and handling of waste 

11 from the RCA.

12 Facility discharges would be limited to sanitary effluent. This sanitary wastewater would be 

13 conveyed to the City of Columbia Sanitary Sewer Utility. NWMI would also obtain a sanitary 

14 sewer connection approval from the City of Columbia (NWMI 2015a, 2015c). As previously 

15 described in Section 3.4.1.2, wastewater discharges to a municipal sanitary sewer system do 

16 not require an NPDES permit, although the discharge would need to comply with the system’s 

17 influent acceptance and treatment criteria. Influent requirements are prescribed in the City’s 

18 Code of Ordinances (Chapter 22, Article VI, Sewers and Sewage Disposal) and specifically 

19 address unlawful discharges, influent limits, and applicable pretreatment requirements 

20 (NWMI 2015a; City of Columbia 2015). Wastewater would also need to meet the NRC’s release 

21 criteria under 10 CFR 20.2003.

22 Wastewater from the NWMI facility would be discharged to the City of Columbia sanitary sewer 

23 system at an average rate of approximately 4,570 gallons per day (gpd) (17,300 liters per day 

24 (Lpd)) (NWMI 2015a, 2015c). This is equivalent to approximately 0.0046 million gallons per day 

(mgd/day) (17.4 cubic meters per day (m3 25 /day)). The Columbia Regional Wastewater 

26 Treatment Plant (WWTP) would be ultimately the point of treatment because this facility serves 

27 the entire City of Columbia. The Columbia WWTP has a design treatment capacity of 20 mgd 

(75,700 m3

/day) with an average demand of 16 mgd (60,600 m3 28 /day) (City of Columbia 2016c). 

29 NWMI’s additional wastewater volume would constitute a very small percentage 

30 (i.e., 0.12 percent) of the available treatment capacity of the WWTP; the proposed discharge 

31 would be unlikely to have any impact on the WWTP.

32 Finally, fuels and chemicals stored on the NWMI facility site could have substantial, localized 

33 water quality impacts if such materials were to be released to the environment. NWMI would 

34 maintain an emergency response plan and operating procedures to address chemical hazards, 

35 including spill response and mitigation (NWMI 2015a). A sizable volume of diesel fuel would 

36 also be stored on site. Current plans call for a 1,000-gal (3,780-L) aboveground storage tank for 

37 use in supplying the RPF backup generator (NWMI 2015a). This storage volume falls below the 

38 threshold requiring the preparation of a Spill Prevention, Control, and Countermeasure (SPCC) 

39 Plan under CWA Section 311 and implementing regulations. SPCC plans must be prepared by 

40 covered facilities to prevent, prepare, and respond to oil discharges potentially affecting 

41 navigable waters of the United States (40 CFR Part 112). NWMI will evaluate the need to 

42 prepare an SPCC plan to support facility operations and/or construction before initiating site 

43 work (NWMI 2015a).

44 In summary, no hazardous or radiological liquid effluent discharge would occur from the facility. 

45 NWMI would convey sanitary wastewater to a municipal wastewater treatment plant that has 

46 adequate treatment capacity. Stormwater discharges from the NWMI facility would be of a 

47 nonindustrial nature and would be managed by engineered facilities and in accordance with 

48 local and State regulations. NWMI will maintain appropriate plans and procedures to address 
Environmental Impacts of Construction, Operations, and Decommissioning

4-18

1 any inadvertent spills of chemical or petroleum products. Based on these considerations, the 

2 NRC staff concludes that the impacts on surface water hydrology, quality, and use from the 

3 NWMI facility operations would be SMALL.

4 4.4.1.3 Decommissioning

5 No natural surface water features occur on the proposed site, and there would be no direct 

6 impacts on surface water resources as a consequence of facility decommissioning activities. 

7 No surface water would be used during decommissioning.

8 As previously referenced in Section 4.3.3, decommissioning contractors would conduct work in 

9 accordance with a decommissioning plan submitted to the NRC for approval and in accordance 

10 with permits and approvals from the City of Columbia. During decommissioning, NWMI would 

11 be responsible for removing waste materials and contaminated media from the facility and 

12 packaging them for proper disposal. As necessary, contractors would sample soils and other 

13 media to determine the presence of any contamination and associated waste management 

14 requirements. Further, appropriate waste handling and stormwater pollution prevention 

15 practices and spill prevention and response procedures would be observed during 

16 decommissioning to ensure that no materials or contaminants are released to soils or exposed 

17 to stormwater.

18 The NRC staff expects that ground-disturbing activities associated with decommissioning would 

19 require coverage under a State-issued NPDES general permit for the discharge of stormwater

20 from land-disturbance sites, as described in Section 4.4.1.1 for construction. BMPs, including 

21 the use of structural controls, such as sediment fencing and sediment basins, and the use of 

22 mulching, geotextile matting, and rapid reseeding of disturbed areas, would be used to prevent 

23 soil erosion and loss and any potential offsite water quality impacts.

24 As no natural surface water features would be impacted during decommissioning, there would 

25 be no diversion or withdrawal of surface water, and all work would be accomplished in 

26 accordance with a decommissioning plan, procedures, and permits to protect surface water 

27 quality, the NRC staff concludes that the impacts on surface water resources from facility 

28 decommissioning would be SMALL.

29 4.4.2 Groundwater

30 4.4.2.1 Construction

31 Excavation depths could range from 17 to 23 ft below grade (5.2 to 7 m) for portions of the RPF, 

32 as described in Section 4.3.1. During the preliminary geotechnical investigation of the 

33 Discovery Ridge Research Park in 2011, the geotechnical contractor encountered groundwater 

34 in two soil borings at depths of approximately 12 to 18.5 ft (3.7 and 5.6 m) bgs (see 

35 Section 3.4.2.1). Therefore, groundwater dewatering may be required during construction. 

36 NWMI will conduct site-specific geotechnical and hydrologic studies of the Discovery Ridge site 

37 (NWMI 2015c). These studies would help to determine whether a seasonally high water table 

38 or perched groundwater exists beneath the site, as well as guide any necessary construction 

39 accommodations and final facility design.

40 NWMI estimated the maximum potential dewatering rate for site excavations (NWMI 2016a). 

41 NWMI used very conservative parameters for runoff area and precipitation yielding a maximum 

42 dewatering rate of 1,400 gal (5,300 L) per hour. Dewatering at this rate would be necessary 

43 only in the deepest excavation and only during a heavy precipitation event. During dewatering, 

44 contractors would pump the groundwater to a detention/retention pond (NWMI 2016a). The 

45 State-issued NPDES general permit for the discharge of stormwater from land-disturbance sites 

46 (see Section 4.4.1.1) allows for the discharge of uncontaminated groundwater if the discharge is 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 properly controlled and addressed under the project-site SWPP (MDNR 2012). The NRC staff 

2 expects that dewatering could have minor effects on the vertical and horizontal extent of shallow 

3 groundwater, if present, and on groundwater flow direction, but any effects would be localized 

4 and temporary.

5 Site groundwater conditions could potentially affect facility construction and final design. These 

6 include the potential for wet subsurface conditions, including a seasonally high water table or 

7 perched groundwater beneath the site. To address these potential issues, site-specific 

8 geotechnical and hydrologic studies are planned that will characterize site conditions in support 

9 of final facility design. These studies would ensure that the completed facility incorporates any

10 necessary design features such as foundations protected with water barrier systems 

11 (e.g., sealants) and foundation drainage and water diversion systems (NWMI 2016a).

12 NWMI does not plan to install any groundwater wells, and there would be no use of onsite 

13 groundwater to support construction activities. Consolidated Public Water Supply District No. 1 

14 would supply water required to support site construction activities (NWMI 2015a, 2015c). As 

15 noted in Section 4.3.1, water lines and other utilities are already in place at the southwest corner 

16 of the Discovery Ridge site. During the course of construction and before the establishment of 

17 permanent utility connections with the NWMI facility, the NRC staff expects that construction 

18 contractors would truck water to the point of use on the site, or water would be conveyed 

19 through a temporary water tap.

20 Water would be required during construction for such uses as dust control and soil compaction. 

21 For example, NWMI has proposed twice-daily watering of the construction site as a fugitive dust

22 BMP (NWMI 2015a). Some potable water would also be required to meet the drinking and 

23 sanitary needs of the construction workforce during the construction period. As stated in 

24 Section 4.4.1.1, the construction contractor would provide portable restroom facilities for the 

25 construction workforce. This measure would reduce the quantity of water required for potable 

26 and sanitary uses. These facilities would be serviced off site by a commercial vendor, 

27 alleviating any potential surface water or groundwater quality concerns. While water would also 

28 be used to produce concrete, this water consumption would occur off site as NWMI proposes to 

29 use ready-mix concrete supplied by commercial vendors instead of operating an onsite concrete 

30 batch plant (NWMI 2015c).

31 As presented in Section 2.6 and summarized in Table 2–3, construction activities would require 

an average of 6,140 gpd (23,200 Lpd) of water. This is equivalent to 0.0061 mgd (23.1 m3 32 /day). 

33 Total projected water use for the 17-month construction period is approximately 2.1 million gal 

34 (7.9 million L).

35 Consolidated Public Water Supply District No. 1, which is the utility that serves the Discovery 

36 Ridge site, uses groundwater as its supply source (Section 3.4.2.2). The system has a total 

groundwater production capacity of 11 mgd (49,200 m3 37 /day) and currently supplies 

approximately 1.45 mgd (5,490 m3 38 /day) to customers (NWMI 2015a). The projected average 

39 daily water needs for NWMI facility construction would be a very small percentage (less than 

40 1 percent) of the district’s total production and available supply capacity.

41 Dewatering may be necessary during construction but site-specific geotechnical and hydrologic 

42 studies will further characterize subsurface conditions, and dewatering activities would be 

43 conducted in accordance with regulatory requirements. NWMI would not use groundwater from 

44 onsite sources during construction, and the estimated water demand to support construction 

45 activities would be less than 1 percent of the public utility’s total production and available excess 

46 capacity. As a result, the NRC staff concludes that the impacts on groundwater hydrology, 

47 quality, and use from construction of the NWMI facility would be SMALL.
Environmental Impacts of Construction, Operations, and Decommissioning

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1 4.4.2.2 Operations

2 The NRC staff expects that there would be no measurable impacts on groundwater hydrology or 

3 groundwater quality associated with normal operations of the NWMI facility. As discussed in 

4 Section 4.4.2.1, due to the potential for a seasonally high water table or perched groundwater 

5 beneath the site, the below-grade portions of the facility may incorporate a foundation drainage 

6 collection and water diversion system. Any impacts on groundwater elevations and flow 

7 direction beneath the site associated with the operation of these features would likely be very 

8 localized.

9 There would be no radioactive liquid effluents released from the facility because the RPF 

10 building is designed to have zero liquid discharge. NWMI would conduct all material, chemical, 

11 and waste handling activities within the confines of the NWMI facility, precluding any releases to 

12 the environment, including soils and groundwater. Stormwater runoff from the NWMI facility site 

13 would be managed by an engineered stormwater management system, including necessary 

14 detention/retention structures, constructed and operated in compliance with State and municipal 

15 stormwater management plans, procedures, and practices (see Section 4.4.1.2).

16 As described in Section 4.4.1.1, the only liquid waste stream discharged from the facility would 

17 be sanitary wastewater. NWMI would discharge this wastewater to the City of Columbia

18 Sanitary Sewer Utility, where it would be treated in the Columbia Regional WWTP, which has 

19 excess treatment capacity available.

20 No onsite groundwater would be used during operations. A public water utility, Consolidated 

21 Public Water Supply District No. 1, provides water service to the Discovery Ridge Research 

22 Park. Water would be required to meet the potable and sanitary needs of the facility staff and to 

23 provide water for fire protection, wash water, and RPF process makeup needs. Section 2.5 and 

24 Table 2–3 further describes these requirements. Facility operations would require an average 

of 5,045 gpd (19,100 Lpd) of water, equivalent to 0.005 mgd (18.9 m3 25 /day). Total annual water 

26 use would be approximately 1.3 million gal (4.9 million L). Based on the process water balance 

27 for the facility (NWMI 2015c), process losses are projected to average 475 gpd (1,798 Lpd), 

28 which reflects a consumptive use rate of approximately 9 percent. These in-facility losses 

29 represent water lost to the atmosphere as water vapor, incorporated into packaged waste 

30 products, or other miscellaneous losses. Even so, the projected average daily water use of the 

31 NWMI facility is a negligible percentage of the production capacity of the water district and 

32 represents a very small increase (about 0.3 percent) in the volume of water the district supplies 

33 to its customers.

34 As facility operations would have no offsite impact on groundwater hydrology, there would be no 

35 discharge of wastewater to groundwater, and water to support facility operations would be a 

36 very small percentage of the production capacity and current demand of the public water supply 

37 district, the NRC staff concludes that the impacts on groundwater hydrology, quality, and use 

38 from the operation of the NWMI facility would be SMALL.

39 4.4.2.3 Decommissioning

40 The potential decommissioning impacts on and associated mitigation measures for groundwater 

41 are similar to those described in Sections 4.3.3 and 4.4.1.3. In summary, contractors would 

42 perform demolition and site restoration activities in accordance with applicable local and State 

43 permits and approvals, including a State-issued NPDES general permit for the discharge of 

44 stormwater from land-disturbance sites, as described in Section 4.4.1.1 for construction. BMPs

45 would be used to prevent soil erosion and loss and any potential impacts to surface water and 

46 groundwater incidental to site decommissioning activities. Specifically, waste handling and 

47 pollution prevention practices and spill prevention and response procedures would be observed 
Environmental Impacts of Construction, Operations, and Decommissioning

4-21

1 during decommissioning, so that no materials or contaminants would be released to soils or 

2 exposed to stormwater, where they could contaminate underlying groundwater.

3 NWMI would be required to conduct necessary surveys of the soils and subsurface to comply 

4 with the NRC’s radiological criteria for license termination in 10 CFR Part 20, Subpart E. The 

5 NRC staff also expects that NWMI would sample soils and other media as necessary in 

6 accordance with other required local and State permits and approvals to ensure that no

7 nonradiological contamination remains in excess of action levels.

8 Water would be required to support decommissioning work, as summarized in Section 2.5 and 

9 Table 2–3. As for facility construction and operations, the NRC staff assumes that Consolidated 

10 Public Water Supply District No. 1 would supply water to support facility decommissioning. 

11 NWMI contractors would either truck water to the site or it could be supplied through a 

12 temporary water line as decommissioning activities progress. NWMI estimates that 

13 decommissioning activities would require an average of 2,000 gpd (7,600 Lpd) of water, 

equivalent to 0.002 mgd (7.6 m3 14 /day). Total projected water use for the 24-month 

15 decommissioning period is approximately 0.96 million gal (3.6 million L). The volume of water 

16 required would be less than that required for facility construction, with negligible impacts on 

17 local or regional groundwater supply capacity. It is expected that portable restroom facilities, 

18 serviced by a commercial vendor, would be used during site decommissioning to meet the 

19 needs of decommissioning personnel. Thus, there would be no onsite discharge of sanitary 

20 waste streams. Therefore, based on the stated findings and assumptions, the NRC staff 

21 concludes that impacts on groundwater resources from decommissioning of the NWMI facility 

22 would be SMALL.

23 4.5 Ecological Resources

24 4.5.1 Construction

25 As described in Section 4.1, construction of the proposed NWMI facility would permanently 

26 convert 7.4 ac (3.0 ha) of agricultural land into an industrial area (Table 4–1) (NWMI 2015a, 

27 2015c). In addition, 0.26 ac (0.1 ha) of agricultural land would be temporarily converted from 

28 agricultural land to a construction staging area (NWMI 2015a, 2015c). Once construction 

29 activities are complete, 68 percent of the site will be covered by buildings, roads, or parking lots, 

30 and 32 percent of the site will be covered with grasses, shrubs, and/or ornamental flowers, 

31 including native species (NWMI 2015a, 2015c). Directly affected vegetation would be limited to 

32 common or non-native grasses, which are abundant within the region and provide relatively 

33 low-quality habitat for birds and wildlife in comparison to forests, grasslands, and wetland 

34 habitats. In addition to a loss of habitat, noise from construction activities could disturb birds 

35 and wildlife. In response to such disturbances and loss of habitat, birds and wildlife could move 

36 out of the immediate area and find adequate, similar habitat (e.g., agricultural fields) within the 

37 vicinity. Once construction activities are complete, birds and wildlife could return to the area.

38 Using regionally native species to revegetate disturbed areas should help reduce the risk of 

39 reintroduction of non-native plants to the watershed (MDC 2016e). 

40 During construction, bird collisions with construction equipment and the new facility could result 

41 in increased mortality caused by the presence of tall structures and artificial night lighting. 

42 NWMI may use tall cranes to build the facility, which, when built, would be at a height of 65 ft 

43 (20 m) for the high bay roof (NWMI 2015a). In addition, the facility stacks would be 75 ft (23 m) 

44 (NWMI 2015a). Migratory songbirds would be most likely to collide with artificially lighted 

45 structures or cranes because of their propensity to migrate at night, their low flight altitudes, and 

46 their tendency to be trapped and disoriented by artificial light (Ogden 1996; NRC 2013a). 
Environmental Impacts of Construction, Operations, and Decommissioning

4-22

1 NWMI (2015a) stated that, during construction at night, BMPs, such as light source shielding

2 and appropriate directional lighting, would be used to mitigate impacts associated with artificial 

3 nighttime illumination. NRC (2013b) reviewed bird collisions with plant structures at nuclear 

4 power plants and determined that collision rates were negligible sources of bird mortality with 

5 plants that have cooling towers 100 ft (30 m) in height. The NWMI facility and construction 

6 equipment would be similar or smaller in size and height than an operating nuclear power plant; 

7 therefore, the impacts from bird collisions at the NWMI site would be bounded by the 

8 conclusions the NRC staff reached in its review of bird collisions at operating nuclear power 

9 plants with cooling towers 100 ft (30 m) in height.

10 Construction of the NWMI facility is not expected to result in any direct impacts to aquatic 

11 resources, such as habitat loss, because no aquatic resources occur on site and no surface 

12 water or groundwater would be used for construction activities. As described in Section 3.4, 

13 water drains off the proposed site to the south and southwest toward the southwesterly flowing 

14 Gans Creek, located approximately 0.35 mi (0.56 km) south of the site at its closest point (see 

15 Figures 3–11 and 3–13). Converting land from open fields to impermeable surfaces, such as 

16 rooftops and paved roads, will increase runoff to Gans Creek. Runoff from the proposed site 

17 could affect offsite aquatic resources by damaging downstream aquatic habitat and functions

18 (MDC 2016e). For example, runoff can increase turbidity or introduce various chemicals or 

19 other pollutants that decrease water quality. However, impacts to Gans Creek and other nearby 

20 waterbodies are expected to be minimal because of the distance to the waterbodies, 

21 appropriate soil erosion and sediment control BMPs would be employed to minimize the 

22 transport of suspended sediment and other pollutants, and NWMI would be required to develop 

23 a site-specific program to prevent pollution from stormwater runoff (see Sections 4.3 and 4.4).

24 An inadvertent release of pollutants could flow to nearby surface water or groundwater features, 

25 including Devil’s Icebox cave located within Rock Bridge Memorial State Park. However, no 

26 hazardous or radiological liquid effluent discharge would occur from the facility and NWMI would 

27 convey sanitary wastewater to a municipal wastewater treatment plant that has adequate

28 treatment capacity. In addition, NWMI will maintain appropriate plans and procedures to 

29 address any inadvertent spills of chemical or petroleum products. 

30 Given that construction would not permanently or temporarily affect any high-quality habitats, 

31 such as grasslands, forests, or wetlands; permanently and temporarily affected habitats 

32 (agricultural fields) are abundant within the region; mortality from bird collisions is expected to 

33 be negligible; and no aquatic features or State-listed species occur on the Discovery Ridge site, 

34 the NRC staff concludes that impacts to ecological resources during construction would be 

35 SMALL.

36 4.5.2 Operations

37 During operations, impacts to ecological resources could result from bird collisions, herbicide 

38 applications for landscape maintenance activities, elevated noise levels, and increased turbidity 

39 or introduction of pollutants from site runoff. As described above, mortality from bird collisions is 

40 expected to be negligible, given that the tallest structure would be a stack no higher than 75 ft 

41 (23 m). Disturbance from daily activities, herbicide applications, or elevated noise levels are 

42 likely to have minimal impacts on wildlife and plant species, given that the species identified at 

43 the proposed site are generally tolerant of human disturbances because the land has been 

44 actively farmed for the past several decades. In response to any disturbances, birds and wildlife 

45 could move out of the immediate area and find adequate, similar habitat (agricultural fields) 

46 within the vicinity. In addition, NWMI would mitigate impacts from herbicide applications by 

47 implementing BMP requirements that would limit their use and contain the broad application 

48 throughout the site.
Environmental Impacts of Construction, Operations, and Decommissioning

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1 Operation of the NWMI facility is not expected to result in any direct impacts to aquatic 

2 resources, because no aquatic resources occur on site and wastewater would be conveyed to a 

3 municipal wastewater treatment plant (NWMI 2015a). Indirect impacts during operations could 

4 include runoff that may contain sediments, contaminants from road and parking surfaces, or 

5 herbicides. Increased runoff could affect offsite aquatic resources by damaging downstream 

6 aquatic habitat and functions (MDC 2016e). However, as described in Section 4.4, impacts to 

7 aquatic resources are expected to be minimal because of the distance to the nearest waterbody 

8 and NWMI would be required to develop a site-specific program to prevent pollution from 

9 stormwater runoff. In addition, NWMI will maintain appropriate plans and procedures to address 

10 any inadvertent spills of chemical or petroleum products. 

11 Given that mortality from bird collisions is expected to be negligible, habitat disturbances during 

12 operations would be minimal, any disturbed wildlife could find similar habitat in the vicinity, and 

13 no aquatic features or State-listed species occur on the proposed site, the NRC staff concludes 

14 that impacts to ecological resources during operations would be SMALL.

15 4.5.3 Decommissioning

16 Decommissioning activities would have impacts that are similar to the impacts that would occur 

17 during construction of the proposed facility. For example, NWMI would use construction 

18 equipment to dismantle large buildings, which could result in disturbances to wildlife and birds 

19 and potential runoff to nearby waterbodies. In addition, some land on the proposed site could 

20 be used as staging areas for the equipment and to conduct certain dismantling activities. As 

21 described above, if noise or other activities disturb birds or wildlife, similar habitat is available in 

22 nearby offsite areas. Once activities are complete, birds and wildlife could return to the area. 

23 No surface water would be used during decommissioning and impacts from runoff would be 

24 minimal, based on the distance to the nearest waterbodies, and because BMPs would be 

25 required in NWMI’s stormwater permit. Therefore, impacts during decommissioning are 

26 expected to be SMALL.

27 4.5.4 Federally Protected Species

28 Section 3.5 describes the special status species and habitats that have the potential to be 

29 affected by the proposed action. The discussion of species and habitats protected under the 

30 Endangered Species Act of 1973 (ESA) (16 U.S.C. 1531 et seq.) includes a description of the 

31 action area as defined by the ESA section 7 regulations at 50 CFR 402.02. The action area 

32 encompasses all areas that would be directly or indirectly affected by the proposed construction, 

33 operations, and decommissioning of the NWMI facility.

34 Appendix D contains information on the NRC staff’s section 7 consultation with the U.S. Fish 

35 and Wildlife Service (FWS) for the proposed action. The NRC did not consult with the National 

36 Marine Fisheries Service (NMFS) as part of the construction permit review because 

37 (as described in Section 3.5) no species or habitats under NMFS’s jurisdiction occur within the 

38 action area.

39 In Section 3.5, the NRC staff concludes that no Federally listed species are likely to occur in the 

40 action area. The NRC staff also concludes that no candidate species, proposed species, or 

41 designated critical habitat occur in the action area. Thus, the NRC staff concludes that the 

42 proposed action would have no effect on Federally listed species or habitats under FWS’s 

43 jurisdiction.
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1 As discussed in Section 3.5, no species or habitats under NMFS’s jurisdiction occur within the 

2 action area. Thus, the NRC staff concludes that the proposed action would have no effect on 

3 Federally listed species or habitats under NMFS’s jurisdiction.

4 As discussed in Section 3.5, NMFS has not designated essential fish habitat (EFH) pursuant to 

5 the Magnuson–Stevens Fishery Conservation and Management Act, as amended 

6 (16 U.S.C. 1801 et seq.) within affected water bodies in the vicinity of the proposed site. Thus, 

7 the NRC staff concludes that the proposed action would have no effect on EFH.

8 4.6 Historic and Cultural Resources

9 This section describes the potential impacts from constructing, operating, and decommissioning 

10 the proposed NWMI facility at Discovery Ridge Research Park on historic and cultural 

11 resources.

12 4.6.1 Historic and Cultural Resources

13 The National Historic Preservation Act (NHPA) of 1966, as amended 

14 (54 U.S.C. 300101 et seq.), requires Federal agencies to consider the effects of their 

15 undertakings on historic properties. Construction, operations, and decommissioning of the 

16 NWMI facility is an undertaking that could potentially affect historic properties. Historic 

17 properties are defined as resources eligible for listing in the National Register of Historic Places 

18 (NRHP). The criteria for eligibility are listed in 36 CFR 60.4 and include (1) association with 

19 significant events in history, (2) association with the lives of persons significant in the past, 

20 (3) embodiment of distinctive characteristics of type, period, or construction, and (4) sites or 

21 places that have yielded, or are likely to yield, important information.

22 The historic preservation review process (Section 106 of the NHPA) is outlined in regulations 

23 issued by the Advisory Council on Historic Preservation (ACHP) in 36 CFR Part 800.

24 4.6.2 Proposed Action

25 In accordance with the provisions of the NHPA, the NRC is required to make a reasonable effort 

26 to identify historic properties included in, or eligible for, inclusion in the NRHP in the area of 

27 potential effect (APE). The APE for this proposed action is Lot 15 at Discovery Ridge Research 

28 Park and any other properties that may be affected by the construction, operations, and 

29 decommissioning of the proposed NWMI facility. The APE may extend beyond Lot 15 in those 

30 instances where construction, operations, and decommissioning activities may effect an historic 

31 property. This determination is made irrespective of land ownership or control. Cultural 

32 resource investigations and surveys conducted on Lot 15 are described in Section 3.6.2.

33 If historic properties are present within the APE, the NRC is required to contact the State 

34 Historic Preservation Officer (SHPO), assess the potential impact, and resolve any possible 

35 adverse effects of the undertaking on historic properties. In addition, the NRC is required to 

36 notify the SHPO if historic properties would not be affected by the undertaking or if no historic 

37 properties are present. The SHPO is part of the MDNR.

38 4.6.3 Consultation

39 In accordance with 36 CFR 800.8(c), on November 19, 2015, the NRC initiated consultations on 

40 the proposed action by writing to the ACHP and MDNR (NRC 2015f). In a response dated 

41 December 9, 2015, MDNR indicated that adequate documentation had been provided 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 (as required by 36 CFR Section 800.11), and there will be “no historic properties affected” by 

2 the proposed NWMI facility (see Appendix D).

3 The NRC staff also initiated consultation with the following Federally recognized tribes on 

4 November 20, 2015 (see Appendix D for a copy of these letters):

5 • Absentee-Shawnee Tribe of Indians of Oklahoma,

6 • Caddo Nation of Oklahoma,

7 • Cherokee Nation,

8 • Cheyenne and Arapaho Tribes,

9 • Chickasaw Nation,

10 • Choctaw Nation of Oklahoma,

11 • Citizen Potawatomi Nation,

12 • Delaware Nation,

13 • Eastern Shawnee Tribe of Oklahoma,

14 • Iowa Tribe of Kansas and Nebraska,

15 • Iowa Tribe of Oklahoma,

16 • Miami Tribe of Oklahoma,

17 • Muscogee (Creek) Nation,

18 • Omaha Tribe of Nebraska,

19 • Osage Nation,

20 • Otoe-Missouria Tribe of Indians,

21 • Pawnee Nation of Oklahoma,

22 • Peoria Tribe of Indians of Oklahoma,

23 • Ponca Tribe of Indians of Oklahoma,

24 • Ponca Tribe of Nebraska,

25 • Prairie Band Potawatomi Nation,

26 • Quapaw Tribe of Oklahoma,

27 • Sac and Fox Nation of Missouri in Kansas and Nebraska,

28 • Sac and Fox Nation, Oklahoma,

29 • Sac and Fox Tribe of the Mississippi in Iowa,

30 • Shawnee Tribe,

31 • United Keetoowah Band of Cherokee Indians of Oklahoma,

32 • Winnebago Tribe of Nebraska,

33 • Wyandotte Nation,
Environmental Impacts of Construction, Operations, and Decommissioning

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1 • Kaw Nation, Oklahoma, and

2 • Yankton Sioux Tribe of South Dakota.

3 In its letters, the NRC provided information about the proposed action, defined the APE, and 

4 indicated that the NRC intends to comply with Section 106 through the National Environmental 

5 Policy Act of 1969 (NEPA) (42 U.S.C. 4321 et seq.) process, pursuant to 36 CFR 800.8(c). The 

6 NRC invited participation in the identification and possible decisions concerning any historic 

7 properties and also invited participation in the scoping process.

8 In response, the NRC was contacted by several tribes, including the Miami Tribe of Oklahoma, 

9 Pawnee Nation of Oklahoma, Quapaw Tribe of Oklahoma, and United Keetoowah Band of 

10 Cherokee Indians of Oklahoma. The Miami Tribe of Oklahoma indicated that the Tribe is not 

11 currently aware of any existing documentation directly linking a specific Miami cultural or historic 

12 site to the project site at Discovery Ridge, and also indicated the project site is within the 

13 extended homelands of the Miami Tribe. The Pawnee Nation of Oklahoma indicated that the 

14 proposed project site at Discovery Ridge would have no potential to adversely affect known 

15 archaeological, historic, or sacred Pawnee sites. The Quapaw Tribe of Oklahoma and the 

16 United Keetoowah Band of Cherokee Indians of Oklahoma indicated that the project site is 

17 outside their area of historic interest and deferred consultation to Federally recognized tribes 

18 with more of a historic interest in the proposed site. The NRC was also contacted by two other 

19 tribes. One tribe requested consulting party status on the NWMI project; the other indicated that 

20 the project site is not in their area of historic interest and deferred consultation to other tribes.

21 4.6.3.1 Construction

22 Construction would convert agricultural land and open space to industrial use. Since no historic 

23 properties (as defined by 36 CFR 800.4(d)(1)) would be affected and no archaeological sites or 

24 evidence of cultural resources were identified during the Phase I survey, historic and cultural 

25 resources are not likely to be impacted by the construction of the proposed NWMI facility at the 

26 Discovery Ridge site. Construction of the NWMI facility would also have little or no visual 

27 impact. The nearest NRHP site, the Maplewood House, is about 1 mi (1.6 km) away to the 

28 northwest, and its view is obstructed by trees and residential and commercial properties. Based 

29 on these factors, as well as tribal input and cultural resource assessment and consultations, 

30 construction of the NWMI facility would not impact any known historic and cultural resources at 

31 the Discovery Ridge site. 

32 4.6.3.2 Operations

33 Because no historic properties (as defined by 36 CFR 800.4(d)(1)) would be affected and no 

34 archaeological sites or evidence of cultural resources were identified during the Phase I survey, 

35 historic and cultural resources would not likely be impacted during NWMI facility operations at 

36 the Discovery Ridge site. The completed NWMI facility would also have little or no visual 

37 impact. The nearest NRHP site, the Maplewood House, is about 1 mi (1.6 km) away to the 

38 northwest, and its view is obstructed by trees and residential and commercial properties. Based 

39 on these factors, as well as tribal input and cultural resource assessment and consultations, 

40 operation of the NWMI facility would not impact any known historic and cultural resources at the 

41 Discovery Ridge site.

42 4.6.3.3 Decommissioning

43 Because no historic properties (as defined by 36 CFR 800.4(d)(1)) would be affected and no 

44 archaeological sites or evidence of cultural resources were identified during the Phase I survey, 

45 historic and cultural resources would not likely be impacted during the decommissioning of the 

46 NWMI facility. Decommissioning the NWMI facility would also have little or no visual impact. 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 The nearest NRHP site, the Maplewood House, is about 1 mi (1.6 km) away to the northwest, 

2 and its view is obstructed by trees and residential and commercial properties. Based on these 

3 factors, as well as tribal input and cultural resource assessment and consultations, 

4 decommissioning the NWMI facility would not impact any known historic and cultural resources 

5 at the Discovery Ridge site.

6 4.7 Socioeconomic Impacts

7 This section describes the potential socioeconomic impacts from constructing, operating, and 

8 decommissioning the proposed NWMI facility at Discovery Ridge Research Park. The impact 

9 analysis considers potential changes in regional employment, housing availability, tax revenues, 

10 and public services. For the purposes of this analysis, the socioeconomic ROI is the City of 

11 Columbia and Boone County, Missouri.

12 4.7.1 Construction

13 4.7.1.1 Employment

14 Construction of the proposed NWMI facility would require an average of 38 workers over 

15 17 months or up to 82 workers during peak construction (NWMI 2015a). At peak, this number 

16 of workers represents less than a tenth of a percent of the civilian labor force in Boone County 

17 in 2014 (see Table 3–16). As a result, nearly all construction workers would likely reside within 

18 the ROI, or adjacent counties and communities, and commute to the work site. Even if 

19 construction were to generate additional employment in the ROI, two to three times the average 

20 number of construction workers would represent less than a quarter of a percent of the civilian 

21 labor force. This would have no noticeable effect on employment levels in the ROI. Given the 

22 small number of construction workers, employment impacts during construction would be 

23 SMALL.

24 4.7.1.2 Housing

25 Construction workers would likely commute from within the ROI to the proposed work site at 

26 Discovery Ridge. This would result in little, if any, increased demand for temporary housing. 

27 As discussed in Section 3.7.6, there is plenty of available rental housing in the City of Columbia

28 and Boone County. Given the small number of construction workers, housing impacts during 

29 construction would be SMALL.

30 4.7.1.3 Tax Revenue

31 Tax revenue generated during the construction of the proposed NWMI facility would include 

32 revenue from property taxes paid by NWMI, income and property taxes paid by construction 

33 workers residing in the ROI, and sales and use taxes received from the purchase and rental of 

34 equipment, material, and commercial services in the ROI. Increased tax revenue would benefit 

35 the City of Columbia, Boone County, and Columbia Public Schools.

36 Communities within the ROI could experience a short-term economic benefit from increased tax

37 revenue and income generated by construction expenditures. After construction, local 

38 communities could experience a return to preconstruction economic conditions. The increase in 

39 tax revenue may have a noticeable effect in the ROI. However, given the relative short-duration 

40 of construction (17 months) and the small number of workers, tax revenue impacts in the ROI 

41 during construction would be SMALL.
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1 4.7.1.4 Public and Educational Services

2 Construction workers and their families living within the ROI would continue to use existing 

3 public and educational services. These services would be able to handle any changes in 

4 demand from the small number of construction workers. Therefore, impacts on public and 

5 educational services during construction would be SMALL.

6 4.7.1.5 Summary of Construction Impacts

7 Communities within the ROI would benefit from increased employment, tax revenue, and 

8 income generated during construction. However, the small number of construction workers, the 

9 availability of rental housing, and the short duration of construction (17 months) would generate 

10 little if any noticeable socioeconomic impact within the ROI. The creation of 38 to 82 (peak) 

11 construction jobs would help maintain employment levels in the ROI and increase property and 

12 sales tax revenue in the ROI, but any changes would be minimal. Therefore, the overall 

13 socioeconomic impact from the construction of the proposed NWMI facility would be SMALL.

14 4.7.2 Operations

15 4.7.2.1 Employment

16 Approximately 98 jobs would be added to the local economy during NWMI facility operations 

17 (NWMI 2015a). This number of workers represents approximately one tenth of a percent of the 

18 civilian labor force in the City of Columbia and Boone County in 2014 (Table 3–16). Even if 

19 NWMI facility operations were to generate additional employment in the ROI, two to three times 

20 the number of operations workers would represent approximately one half of a percent of the 

21 civilian labor force. This would have no noticeable effect on employment levels in the ROI. 

22 Given the small number of operations workers, employment impacts during operations would be 

23 SMALL.

24 4.7.2.2 Housing

25 NWMI estimates that 98 workers would be needed during operation of the proposed NWMI 

26 facility (NWMI 2015a). Any operations workers relocating to the ROI would likely purchase 

27 permanent housing. As discussed in Section 3.7.6, there is plenty of available housing in the 

28 City of Columbia and Boone County. Given the small number of operations workers, housing 

29 impacts during operations would be SMALL.

30 4.7.2.3 Tax Revenue

31 Tax revenue generated during NWMI facility operations would include revenue from property 

32 taxes paid by NWMI, income and property taxes paid by workers residing in the ROI, and sales 

33 and use taxes received from the purchase and rental of equipment, material, and commercial 

34 services in the ROI. Estimated NWMI total annual tax payments (approximately $2.5 million) 

35 would comprise less than 1 percent of the City of Columbia’s 2015 fiscal year total revenues 

36 (approximately $325 million) (City of Columbia 2016e). Regardless, this increased tax revenue 

37 would benefit the City of Columbia, Boone County, and Columbia Public Schools.

38 Communities within the ROI could experience a minor economic benefit from increased tax

39 revenue and income generated by any workers and their families relocating to the ROI. This 

40 increase in tax revenue may have a noticeable effect in the ROI. However, given the small 

41 number of workers, overall tax revenue impacts in the ROI during operations would be SMALL.

42 4.7.2.4 Public and Educational Services

43 Operations workers and their families living in the ROI would continue to use existing public and 

44 educational services. These services would be able to handle any changes in demand from the 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 small number of operations workers. Therefore, impacts on public and educational services 

2 during operations would be SMALL.

3 4.7.2.5 Summary of Operations Impacts

4 Communities within the ROI would benefit from increased employment, tax revenue, and 

5 income generated during NWMI facility operations. However, the small number of operations 

6 workers and the availability of housing would generate little if any socioeconomic impact within 

7 the ROI. The creation of 98 jobs would help maintain employment levels and increase property, 

8 income, and sales tax revenue in the ROI, but any changes would be minimal. Therefore, the 

9 overall socioeconomic impact from the operation of the proposed NWMI facility would be 

10 SMALL.

11 4.7.3 Decommissioning

12 4.7.3.1 Employment

13 Decommissioning the proposed NWMI facility would require an average of 38 workers over 

14 18 to 24 months or up to 81 workers during peak decommissioning (NWMI 2015a). At peak, 

15 this number of workers represents less than a tenth of a percent of the civilian labor force in 

16 Boone County in 2014 (Table 3–16). In addition, some operations workers may be kept on to 

17 support decommissioning. As a result, nearly all workers would likely reside within the ROI, or 

18 adjacent counties and communities, and commute to the work site. Even if decommissioning 

19 were to generate additional employment in the ROI, two to three times the average number of 

20 decommissioning workers would represent less than a quarter of a percent of the civilian labor 

21 force. This would have no noticeable effect on employment levels in the ROI. Given the small 

22 number of decommissioning workers, employment impacts during decommissioning would be 

23 SMALL.

24 4.7.3.2 Housing

25 Decommissioning workers would likely commute from within the ROI to the proposed NWMI 

26 facility. As previously discussed, some operations workers may be kept on to support 

27 decommissioning, thereby reducing the need for new hires. This would result in little, if any, 

28 increased demand for temporary housing. As discussed in Section 3.7.6, there is plenty of 

29 available rental housing in the City of Columbia and Boone County. Given the small number of 

30 decommissioning workers, housing impacts during decommissioning would be SMALL.

31 4.7.3.3 Tax Revenue

32 NWMI would continue to pay property taxes during decommissioning. The assessed property 

33 taxes would be based on the property tax rates at the time. Revenue loss would directly affect 

34 the City of Columbia and Boone County and the communities and other local taxing districts 

35 closest to, and most reliant on, the revenue from NWMI. However, the loss in tax revenue 

36 should be small in comparison to the established tax base of the City of Columbia and Boone 

37 County. Therefore, tax revenue impacts during decommissioning would be SMALL.

38 4.7.3.4 Public and Educational Services

39 Decommissioning workers and their families living in the ROI would continue to use existing 

40 public and educational services. Any temporary increase in population during decommissioning 

41 would be small relative to the projected population of the City of Columbia and Boone County. 

42 Public and educational services in the City of Columbia and Boone County would be able to 

43 handle any changes in demand during decommissioning. Therefore, impacts on public and 

44 educational services during decommissioning would be SMALL.
Environmental Impacts of Construction, Operations, and Decommissioning

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1 4.7.3.5 Summary of Decommissioning Impacts

2 The small number of decommissioning workers, the availability of housing, and the short 

3 duration of decommissioning (18 to 24 months) would generate little if any socioeconomic 

4 impact within the ROI. The creation of 38 to 81 (peak) decommissioning jobs would help 

5 maintain employment levels in the ROI, but any changes would be minimal. NWMI would 

6 continue to pay property taxes during decommissioning. Therefore, the overall socioeconomic 

7 impact from decommissioning the proposed NWMI facility would be SMALL.

8 4.8 Human Health

9 This section provides the NRC’s assessment of the potential radiological and nonradiological 

10 effects from the proposed NWMI facility. Radioactive and nonradioactive materials would 

11 routinely be used at the proposed NWMI facility. The NRC regulations, other Federal 

12 regulations, State of Missouri regulations, and local regulations would control the use and 

13 discharge of these materials to protect facility workers and members of the public.

14 Radiological exposures from the proposed NWMI facility would include offsite doses to 

15 members of the public and onsite doses to facility workers. The NRC’s radiation safety and 

16 dose limit requirements, which are found in 10 CFR Part 20, are discussed in detail in 

17 Section 3.8.2. The NRC has the authority to enforce these requirements to help ensure an 

18 adequate level of protection for workers, members of the public, and the environment.

19 Nonradiological exposures from the proposed NWMI facility to workers and members of the 

20 public would be regulated by applicable Federal (e.g., Clean Air Act, Clean Water Act, and 

21 Resource Conservation and Recovery Act (RCRA) (42 USC 6901 et seq.)), State (e.g., Missouri 

22 Hazardous Waste Management Law, Missouri Air Conservation Law, and Missouri Clean Water 

23 Law), and local laws and regulations. Occupational hazards would also be regulated by the 

24 Occupational Safety and Health Administration’s (OSHA’s) regulations in Chapter 29 of the 

25 Code of Federal Regulations (NWMI 2015a).

26 4.8.1 Construction

27 4.8.1.1 Radiological

28 No radioactive material associated with the application will be present at the proposed site 

29 during the construction phase of the proposed NWMI facility (NWMI 2015a, 2015c). As a result, 

30 no radioactive waste associated with the NWMI processes will be produced during construction. 

31 Therefore, the NRC staff concludes that there will be no impacts from potential radiological 

32 exposures during construction and impacts would be SMALL.

33 4.8.1.2 Nonradiological

34 Members of the public would not have access to the construction site. As discussed in 

35 Section 4.2.1.1, the NRC expects air pollutants from worker vehicles and fossil-fueled 

36 equipment (e.g., excavation and earth-moving equipment and electric generators), but the 

37 impact to the public would be SMALL because the effects would not be noticeable.

38 Construction workers would encounter potential hazards typical of any industrial construction 

39 site. As discussed in Section 3.8.4, workplace hazards can be grouped into physical hazards 

40 (e.g., slips and trips; falls from height; and those related to transportation, temperature, 

41 humidity, and electricity); physical agents (e.g., noise and vibration); chemicals; and 

42 psychosocial issues (e.g., work-related stress). NWMI would employ normal construction safety 

43 practices contained in OSHA regulations, such as safety training, safety equipment, and 

44 supervision of the work force to promote worker safety and reduce the likelihood of worker injury 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 during construction (NWMI 2015a). However, construction accidents could occur. Over the 

2 projected 12-month period when construction activities would occur, the average number of 

3 workers at the site would be 38 with a peak of 82 (NWMI 2015a). The NRC staff used data from 

4 the U.S. Bureau of Labor Statistics (BLS) for nonfatal workplace injuries and illnesses to 

5 calculate the potential number of reportable cases at the proposed NWMI construction site 

6 based on the average number of workers. The U.S. Department of Labor (DOL) data for 2014 

7 showed that private industry reported an incidence rate of 3.2 cases per 100 equivalent full-time 

8 workers (DOL 2014). Conservatively assuming the peak workforce of 82 workers during the 

9 construction period, the BLS rates would result in 2.6 recordable cases during the 12 months of 

10 construction. With the use of normal construction safety practices at the proposed NWMI 

11 construction site, the NRC staff concludes that recordable cases during construction should be 

12 consistent with the DOL data.

13 During construction, NWMI would store nonradioactive chemical sources on site in liquid; 

14 gaseous; and solid forms, including fuels, oils, and solvents necessary for site preparation and 

15 construction. Chemicals, hazardous liquids, and gases may also be encountered during 

16 construction. Such chemicals may take the form of compressed gases, oxidizers, flammable 

17 liquids, and other gases. The impact of these chemicals would be mitigated by the use of 

18 access controls, proper personal protective equipment and other typical construction safety 

19 practices to ensure safe working conditions and reduced instances of accidents or exposure to 

20 hazardous materials. If a spill or accident occurs during construction, an emergency response 

21 plan would be used to reduce the impact to human health and the environment (NWMI 2015a).

22 Given that access to the site would be restricted, that NWMI would implement normal 

23 construction safety practices contained in OSHA regulations, and that hazardous chemicals 

24 stored or used at the construction site would be managed in accordance with applicable Federal 

25 and State regulations, the NRC staff concludes that nonradiological impacts to human health 

26 during construction would be SMALL.

27 4.8.2 Operations

28 4.8.2.1 Radiological

29 During operation, LEU targets will be fabricated at the proposed NWMI facility. These will be 

30 transported offsite, irradiated, transported back to the proposed facility, and processed to 

31 produce Mo-99. Byproducts of the processing of these targets include some recyclable material 

32 (take-back LEU) and radioactive waste, which will be managed accordingly. Gaseous effluents 

33 meeting approved regulatory criteria will be released to the environment. Liquid and solid 

34 radioactive wastes would be managed as discussed in Sections 2.7.1.2 and 4.9.1 of this EIS 

35 (NWMI 2015a).

36 Radioactive material would be located in the facility hot cell area, irradiated target receipt and 

37 unloading area, target fabrication area, and waste management areas. Radioactive liquid and 

38 gaseous effluents from activities at the proposed facility would be contained within the process 

39 waste management or offgas systems (NWMI 2015a).

40 NWMI plans to maintain radiation exposure to facility workers to within the occupational dose

41 limits in 10 CFR 20.1201. Radiation exposure to personnel within the proposed facility would be 

42 minimized to as low as is reasonably achievable (ALARA) using shielding, optimized process 

43 designs, radiological work planning, protective equipment and materials, access controls, and 

44 contamination control measures. All personnel whose duties require entry into restricted areas 

45 (areas that are access-controlled due to actual or possible elevated radiation levels) will wear 

46 individual dosimetry devices, such as thermoluminescent dosimeters, to monitor radiation dose 

47 from external sources. Selected personnel will also have radiation dose from internal sources 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 (i.e., dose from inhaled or ingested radionuclides) monitored by bioassay. NWMI would 

2 administratively control individual occupational external radiation doses to 500 millirem (mrem) 

3 per year (10 percent of the 10 CFR 20.1201 limit). Additionally, NWMI would administratively 

4 control individual occupational total effect dose equivalent (combined dose from external and 

5 internal sources) to 2,000 mrem per year (40 percent of the 10 CFR 20.1201 limit) 

6 (NWMI 2015g).

7 At the site boundary, the combination of shielding within the facility and distance from the facility 

8 would ensure that the direct radiation dose to members of the public in this area would be 

9 negligible (NWMI 2015a).

10 As described in Section 2.7.1.1, radioactive gaseous effluents would be released into the 

11 environment from the facility stack. The ventilation system is designed to provide confinement 

12 of hazardous chemical fumes and airborne radiological materials. Each exhaust filter train will 

13 consist of prefilters, two stages of HEPA filters, carbon adsorbers, and isolation dampers. The 

14 radionuclides of interest in these gaseous effluents would be krypton-85, metastable xenon-131, 

15 and xenon-133. Smaller amounts of radioactive iodines, particulates, tritium, and other noble 

16 gasses would also be released. NWMI determined that the dose from tritium would be 

17 negligible relative to the dose from other radionuclides released (NWMI 2016c). The exhaust 

18 stacks will be provided with continuous monitors for noble gases, particulates, and iodine. The 

19 stack monitoring system is designed to continuously monitor stack releases. 

20 NWMI estimates that the maximum dose to the public from normal operational stack releases 

21 would be 3.6 mrem per year (NWMI 2015a, 2016a). The estimated dose is well below the 

22 annual dose limit of 100 mrem in 10 CFR 20.1301, and is also within the requirements in 

23 10 CFR 20.1101(d) that impose a constraint of 10 mrem per year on individual dose to a 

24 member of the public from radioactive gaseous effluents.

25 The ER states that NWMI will have a radiological effluent monitoring program to ensure that the 

26 types and quantities of radioactive material released from the proposed facility are within 

27 expected parameters, such that the limits in 10 CFR 20.1301 and 10 CFR 20.1101(d) would not 

28 be exceeded. The radiological effluent monitoring program would include gaseous effluent 

29 monitoring (NWMI 2015a). The program would also include environmental monitoring that 

30 would comprise:

31 • waterborne exposure pathway monitoring (sampling and analysis of nearby surface 

32 water and groundwater);

33 • direct exposure pathway monitoring (use of thermoluminescent dosimeter monitoring 

34 stations both on site and at the fence line of the proposed facility); and,

35 • airborne exposure pathway monitoring (use of continuous air monitoring stations at 

36 the fence line) (NWMI 2015a, 2016a).

37 Additional environmental monitoring for the ingestion exposure pathway (i.e., sampling and 

38 analysis of milk for iodine-131 and other gamma-emitting radioisotopes) may also be performed, 

39 if it is determined to be necessary as a result of radioactive iodine and particulate activity being 

40 measured during airborne effluent monitoring or air sampling (NWMI 2015a).

41 As stated in Section 2.7.1.2, no liquid radioactive material would be released to the environment 

42 as a result of routine operations of the proposed NWMI facility. All liquid radioactive waste

43 produced at the proposed facility would be solidified for disposal. Should any inadvertent liquid 

44 release to the environment occur, the waterborne exposure pathway monitoring performed as 

45 part of NWMI’s effluent monitoring program, along with additional ad hoc sampling that would be 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 performed as necessary, would allow the inadvertent release to be detected and its 

2 environmental and public dose impacts quantified (NWMI 2016a).

3 As described in detail in Section 2.8, transportation of radioactive materials, both on public 

4 highways and by air, would occur in conjunction with operation of the proposed NWMI facility. 

5 Radioactive materials transported to and from the NWMI facility site would include fresh LEU, 

6 unirradiated and irradiated LEU targets, Mo-99 product solution, and take-back LEU. When 

7 transporting waste and other radioactive materials on public roads, NWMI or commercial 

8 carriers must comply with the applicable U.S. Department of Transportation (DOT) regulations 

9 in 49 CFR Parts 172, 173, 177, and 397, as well as the NRC packaging requirements for 

10 radioactive material in 10 CFR Part 71. For transport of Mo-99 product by air, the air carrier 

11 chosen by NWMI must also comply with additional DOT regulations in 49 CFR Part 175 

12 (NWMI 2015a).

13 Using the RADCAT/RADTRAN code, NWMI estimated that the total incident-free dose to the 

14 general public from all public highway radioactive material transportation associated with the 

15 proposed NWMI facility (including transportation of waste, which is discussed in Section 4.9.1) 

16 would be 47,300 person-mrem per year, and 0.393 mrem per year to the maximally exposed 

17 individual member of the public located along a highway transportation route. The total 

18 population dose is approximately 0.6 percent of the approximately 7,740,000 person-mrem 

19 received annually within a 5-mi (8-km) radius of the proposed NWMI facility from background 

20 radiation (NWMI 2015a, 2016c). Additionally, the annual dose to a maximally exposed 

21 individual from highway transportation of radioactive material is small relative the NRC’s 

22 100 mrem annual public dose limit in 10 CFR 20.1301. For air transport of Mo-99 product, 

23 NWMI assumed that no commercial airliners carrying members of the public as passengers 

24 would be used, and it determined that the dose to members of the public on the ground would 

25 be negligible (NWMI 2015a, 2016c).

26 The NRC has previously evaluated the environmental impact of the transportation of radioactive 

27 materials on public roads and by air. The NRC concluded in 1977 that when radioactive 

28 material transportation is performed in compliance with all Federal regulations, the impact of 

29 such transportation is small (NRC 1977). The Commission determined that the environmental 

30 impacts, radiological and nonradiological, of normal (incident-free) transportation of radioactive 

31 materials and the risks and consequences of accidents involving radioactive material shipments 

32 in packages for which the NRC has issued design approvals meeting the performance 

33 standards of 10 CFR Part 71 were small (49 FR 9375). Regulations, shipping practices, and 

34 cask designs for transporting radioactive material have remained essentially unchanged since 

35 1977. Although more recent NRC assessments of the safety of radioactive materials 

36 transportation have focused on nuclear power reactor spent fuel, rather than the types of 

37 radioactive materials that would be transported in conjunction with the proposed NWMI facility, 

38 these assessments have shown, through the use of more advanced calculation methodologies, 

39 that the impacts associated with transportation of nuclear power reactor spent fuel are smaller 

40 than originally thought in 1977 (NRC 2014a). Since transportation performed in conjunction with 

41 operation of the proposed NWMI facility would be performed in compliance with DOT and NRC 

42 regulations, the NRC staff concludes that the impacts from transportation of radioactive 

43 materials during operation would be SMALL.

44 As described above, NWMI would have facility design features and use procedures to minimize 

45 radiation exposure to occupational workers and members of the public. The maximum dose to 

46 a member of the public would be well within the annual dose limit of 100 mrem in 

47 10 CFR 20.1301. In addition, NWMI plans to administratively control doses to occupational 

48 workers such that these doses would be well below the limits in 10 CFR 20.1201

49 (NWMI 2015g). The NRC staff is conducting an independent review of the potential dose to 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 occupational workers and the public from operation of the proposed NWMI facility. This 

2 independent evaluation will be documented in the NRC staff’s safety evaluation report (SER). If 

3 the NRC staff determines in its SER that the maximum doses to workers and the public are 

4 within the dose limits in 10 CFR Part 20, the NRC staff concludes that the impacts from potential 

5 radiological exposures during operation would be SMALL.

6 4.8.2.2 Nonradiological

7 The proposed NWMI facility would be designed with engineering controls (e.g., shields, 

8 double-valves, ventilation system, glove boxes, fume hoods, safety switches, and safe-storage 

9 facilities) to minimize the exposure of workers to chemicals (NWMI 2015a).

10 NWMI would be expected to incorporate mechanisms for maintaining a safe working 

11 environment based on OSHA requirements, industry standards, and the experience of the 

12 managerial staff. General areas within the proposed facility and laboratory spaces would be 

13 expected to be kept clean and orderly. NWMI would store hazardous material (e.g., acids, 

14 bases, oxidizers, gases, and pyrophoric metals) in appropriate safety containers and cabinets 

15 (NWMI 2015a).

16 In addition to supervision and oversight of facility operations, NWMI would implement a training 

17 program that would emphasize workplace safety (NWMI 2015a). There would also be 

18 requirements for protective equipment commensurate with the hazards. These requirements 

19 would range from a description of appropriate clothing for workers (e.g., no shorts or open-toed 

20 shoes in the facility or the laboratory) to protective equipment (e.g., gloves, safety glasses, and 

21 laboratory coats). For more potentially hazardous operations, such as target solution 

22 preparation, which involves the handling of acids, workers would be required to use face 

23 shields, aprons, and heavy nitrile gloves. As discussed in Section 2.8.1.2, NWMI will develop a 

24 chemical management and product handling plan. The storage and treatment of wastes will be 

25 conducted in accordance with these plans. Additionally, the storage of chemicals and supplies 

26 on site will be performed in accordance with a chemical management and product handling plan 

27 to ensure that chemicals are properly stored (e.g., incompatible chemicals are stored in 

28 separate areas, flammable chemicals and oxidizers are stored in separate areas) 

29 (NWMI 2015a).

30 As discussed in Sections 2.7.2.1 and 4.2.1.2, nonradioactive pollutants may be present in 

31 wastewater and air emissions released into the environment during normal operations. Solid 

32 nonradioactive wastes would also be generated. After initial use, NWMI expects the majority of 

33 chemicals to be reused, discharged to the municipal sewer, or shipped off site as waste as 

34 discussed in Sections 2.7 and 2.8 (NWMI 2015a).

35 Given that NWMI would manage and minimize worker hazards by complying with OSHA and 

36 State of Missouri regulations and by using multiple planned features (e.g., facility design, 

37 supervision, training, and protective equipment), the NRC staff concludes that nonradiological 

38 impacts to workers and members of the public during routine facility operations would be 

39 SMALL.

40 4.8.3 Decommissioning

41 4.8.3.1 Radiological

42 Following cessation of proposed NWMI facility operations, residual radioactive contamination 

43 would remain in the hot cell and process areas of the facility. The potential radiological impacts 

44 from decommissioning would be associated with this contamination. During decommissioning 

45 operations, contaminated areas and equipment would be decontaminated; proper radiation 

46 protection procedures would be followed during these activities to keep exposure to 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 occupational workers ALARA. Piping and vessels would be decontaminated, rinsed, and 

2 sampled to ensure that the removal of radioactive material has been achieved. If an area or 

3 piece of equipment could not be adequately decontaminated, a fixative would be applied to 

4 prevent the spread of the residual contamination. Materials with residual contamination would 

5 be disposed of as radioactive waste (see discussion of impacts related to radioactive waste 

6 disposal in Section 4.9.1) (NWMI 2015a).

7 With the cessation of proposed facility operations, radioactive gaseous effluents released into 

8 the environment from operations would effectively stop. However, during decommissioning 

9 activities, workers and members of the public would continue to be exposed to negligible or low 

10 levels of radioactive material within the facility and from radioactive gaseous effluents resulting 

11 from decommissioning activities involving the dismantlement and decontamination of equipment 

12 and systems and the handling and packaging of radioactive waste. The NRC’s radiation 

13 protection standards and dose limits for occupational workers and members of the public during 

14 decommissioning are the same as those for the operating facility.

15 Before initial operation of the proposed NWMI facility, NWMI would conduct a radiological 

16 survey of the proposed site to establish a baseline for decommissioning (NWMI 2015c). As 

17 discussed in Section 2.9, NWMI would be required to conduct decommissioning activities in 

18 accordance with applicable NRC requirements and any additional Federal, State, and local 

19 requirements. The NRC would terminate the license if the decommissioning were performed in 

20 accordance with the facility’s approved decommissioning plan, and if the termination radiation 

21 survey and associated documentation demonstrated that the facility and site were suitable for 

22 release in accordance with the criteria in 10 CFR Part 20, Subpart E. After decommissioning 

23 activities are completed in compliance with regulations, the proposed site could be released for 

24 unrestricted or restricted use, as determined by 10 CFR Part 20, Subpart E criteria.

25 Based on the expected reduced levels of radioactive material in the facility, and the radiological 

26 controls expected to be used to ensure doses to occupational workers and members of the 

27 public that are in compliance with radiation protection standards, the NRC staff concludes that 

28 the impacts from potential radiological exposures during decommissioning would be SMALL.

29 4.8.3.2 Nonradiological

30 Nonradiological health impacts on the public and workers from decommissioning and demolition 

31 activities would be similar to construction activities. Decommissioning and demolition activities 

32 would involve the use of heavy construction and demolition equipment and the transport of new 

33 and waste materials and personnel to and from the site. The public and workers could be 

34 exposed to dust and vehicle exhaust and noise. Workers could also experience occupational 

35 injuries. Nonradiological hazards would also be associated with emissions, discharges, and 

36 waste from processes within the facility and from accidental spills and releases. NWMI would 

37 manage nonradioactive wastes generated by decommissioning the NWMI facility, including solid 

38 wastes, liquid wastes, discharges, and air emissions, in accordance with applicable Federal, 

39 State, and local laws and regulations and with applicable permit requirements. As discussed in 

40 Section 4.2, the NRC staff determined that air pollutants from worker vehicles and fossil-fueled 

41 equipment (e.g., demolition, excavation, and earth-moving equipment and electric generators) 

42 would have a SMALL impact on air quality. In addition, NWMI’s access controls would help 

43 ensure that only authorized personnel would come on site. Given that NWMI would prohibit 

44 members of the public from accessing the site during decommissioning and that NWMI would 

45 manage nonradioactive wastes generated by decommissioning the NWMI facility in accordance 

46 with applicable Federal, State, and local laws and regulations and with applicable permit 

47 requirements, the NRC staff expects decommissioning activities to result in minimal human 

48 health impact to members of the public.
Environmental Impacts of Construction, Operations, and Decommissioning

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1 Decommissioning and demolition workers would encounter potential hazards typical of any 

2 industrial construction and demolition site. As discussed in Section 3.8, workplace hazards can 

3 be grouped into physical hazards (e.g., slips and trips; falls from height; and those related to 

4 transportation, temperature, humidity, and electricity); physical agents (e.g., noise and 

5 vibration); chemicals; and psychosocial issues (e.g., work-related stress). NWMI would 

6 implement normal construction safety practices contained in OSHA regulations, such as safety 

7 training, safety equipment, and supervision of the work force, to promote worker safety and 

8 reduce the likelihood of worker injury during decommissioning. However, decommissioning 

9 accidents could occur. Over the projected decommissioning phase, NWMI estimates a peak 

10 workforce of 81 workers at the site. The NRC staff used data from the BLS for nonfatal 

11 workplace injuries and illnesses to calculate the potential number of reportable cases at the 

12 proposed NWMI construction site based on the average number of workers. The DOL data for 

13 2014 showed that private industry reported an incidence rate of 3.2 cases per 100 equivalent 

14 full-time workers (DOL 2014). Conservatively assuming the peak workforce of 81 workers 

15 during the construction period, the BLS rates would result in 2.6 recordable cases a year. With 

16 the use of normal construction safety practices at the proposed NWMI decommissioning site, 

17 the NRC staff concludes that recordable cases during construction should be consistent with the 

18 DOL data.

19 During decommissioning, nonradioactive chemical sources would be managed in the same 

20 manner as during construction and operation.

21 Inasmuch as access to the site would be restricted, that NWMI would implement normal safety 

22 practices contained in OSHA regulations, and that chemicals stored or used at the site would be 

23 managed in the same manner as during construction and operation, the NRC staff concludes 

24 that nonradiological impacts to human health during decommissioning would be SMALL.

25 4.9 Waste Management

26 4.9.1 Radioactive Waste

27 This section describes potential impacts related to the production and transportation of solid 

28 low-level radioactive wastes during operation and decommissioning of the proposed NWMI 

29 facility.

30 As discussed in Sections 2.7.1 and 2.8.1, radioactive waste would be produced during the 

31 operation and decommissioning phases of the proposed NWMI facility. Radioactive waste 

32 would include gaseous effluents, which would be released to the environment; and low-level 

33 solid waste, including solidified liquid waste, which would be packaged and transported off site 

34 for disposal. No high-level solid waste would be produced at the proposed facility. No liquid 

35 radioactive waste would be released into the environment or shipped off site; all liquid 

36 radioactive wastes would be solidified before disposal. No radioactive wastes would be 

37 disposed of or permanently stored at the proposed facility site.

38 Gaseous effluents are discussed in Section 2.7.1.1, and the impact from handling of these 

39 effluents and their release to the environment is discussed in Section 4.8.2.1. The production of 

40 solid low-level radioactive waste, a small portion of which could be mixed (both radiological and 

41 hazardous) waste, at the proposed NWMI facility, is discussed in Section 2.7.1.2. Upper-bound 

42 estimates of the quantities of solid waste that would be produced are provided in 

43 Section 2.7.1.2; when practical, methods including process liquid recycle and reuse would be 

44 used to reduce the amount of waste produced (NWMI 2015a, 2015c).
Environmental Impacts of Construction, Operations, and Decommissioning

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1 The solid radioactive waste produced at the proposed NWMI facility would include both Class A 

2 and Class B waste. As described in Section 2.7.1.2, possible volume reduction and 

3 optimization activities have the potential to change some Class B waste into Class C; if NWMI 

4 anticipates that Class C waste will be produced, NWMI would provide this information in its 

5 operating license application and the NRC would review this information and document its 

6 review in the supplemented EIS. No greater than Class C wastes will be generated by facility 

7 operations (NWMI 2015c).

8 NWMI plans to ship radioactive waste from the proposed facility to Waste Control Specialists 

9 (WCS) in Andrews, Texas (NWMI 2015a). WCS accepts mixed waste (i.e., waste that is both 

10 hazardous and radioactive), in addition to nonhazardous radioactive waste (WCS 2016). In the 

11 event that NWMI loses access to a low-level waste disposal facility, the NRC staff expects that 

12 any low-level waste would have to be stored either within the facility or in a new storage facility 

13 that NWMI would construct either on site or at an offsite location. The storage of low-level 

14 waste would continue until a low-level waste facility is available. Low-level waste, regardless of 

15 its location, must be stored in accordance with Federal and state regulations to ensure the 

16 safety of workers and members of the public.

17 As described in Section 2.8.1.1, transportation of radioactive waste on public highways would 

18 also occur in conjunction with operation of the proposed NWMI facility. When transporting 

19 waste, NWMI or commercial carriers must comply with the applicable DOT regulations in 

20 49 CFR Parts 172, 173, 177, and 397, as well as the NRC packaging requirements for 

21 radioactive material in 10 CFR Part 71 (NWMI 2015a).

22 The environmental impact of transporting radioactive waste on public roads was included in the 

23 discussion of the impacts of transporting radioactive materials in Section 4.8.2.1. The NRC has 

24 previously evaluated the environmental impact of the transportation of radioactive waste on 

25 public roads. The NRC concluded that when radioactive waste transportation is performed in 

26 compliance with all Federal regulations, the impact of such transportation is small (NRC 1977). 

27 Therefore, since waste transportation performed in conjunction with the operation of the 

28 proposed NWMI facility would be performed in compliance with DOT and NRC regulations, the 

29 NRC staff concludes that the impacts from transportation of radioactive waste produced during 

30 operation and decommissioning of the proposed facility would be SMALL.

31 The proposed NWMI facility’s waste management systems, engineering design features, and 

32 contamination control and radiological safety procedures would help ensure that doses to facility 

33 personnel and members of the public from the production, handling, and packaging of 

34 radioactive waste are reduced to levels that are ALARA. In addition, all activities at the 

35 proposed facility, including handling of radioactive waste, would be conducted such that 

36 radiation doses to occupational workers and members of the public are maintained below 

37 10 CFR Part 20 limits, as discussed in Section 4.8.2.1. Radioactive waste at the proposed 

38 facility is expected to be managed in accordance with regulatory requirements. The NRC staff 

39 concludes that the impacts from production and handling of radioactive waste at the proposed 

40 NWMI facility during operations and decommissioning would be SMALL.

41 4.9.2 Nonradioactive Waste

42 As discussed in Section 2.7.2, NWMI would acquire, use, and store solid and liquid 

43 nonradioactive waste.

44 RCRA waste regulations govern the disposal of solid and hazardous waste. RCRA, Subtitle C, 

45 establishes a system for controlling hazardous waste, and RCRA, Subtitle D, encourages states 

46 to develop comprehensive plans to manage nonhazardous solid waste and mandates minimum 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 technological standards for municipal solid waste landfills. EPA has delegated the primary 

2 responsibility for implementing RCRA regulations to the State of Missouri (EPA 2015c).

3 NWMI will implement waste management systems to control, handle, process, store, and 

4 transport nonradioactive waste generated during construction, operations, and 

5 decommissioning (NWMI 2015a). As described in Section 2.7.3, NWMI’s nonradioactive waste 

6 management program is based on a pollution prevention and waste minimization framework. 

7 The design of the NWMI facility would also incorporate features to minimize the release of 

8 chemicals or other nonradioactive materials into the environment (NWMI 2015a). Additionally, 

9 during operations, NWMI would contain chemicals within closed systems and use the chemicals 

10 in controlled processes (NWMI 2015a). The NRC staff expects that the waste management 

11 systems would ensure that the nonradioactive wastes generated at the proposed NWMI facility 

12 would be managed in accordance with applicable Federal and State of Missouri regulations.

13 As discussed in Section 2.7, the proposed NWMI facility would generate less than 1,000 kg 

14 (2,205 lb) of hazardous waste per month, making it a small quantity hazardous waste generator 

15 under EPA regulations. The proposed facility would also generate approximately 4,056 kg 

16 (8,942 lb) of nonradiological, nonhazardous waste (i.e., municipal waste) per year during 

17 operation (NWMI 2015c). NWMI expects that nonradiological hazardous wastes from 

18 construction or operation of the proposed facility would be collected by a hazardous waste 

19 disposal company such as Veolia or Clean Harbors for separation, processing, and disposal. 

20 Other solid waste (municipal waste or construction debris) generated by the construction or 

21 operation of the proposed facility would be picked up and disposed of at the City of Columbia

22 sanitary landfill (NWMI 2015c).

23 Nonhazardous waste would be temporarily stored on site before being transported to the local 

24 disposal or recycling facility (NWMI 2015a). Hazardous nonradioactive waste will be temporarily 

25 stored on site and then would be collected by the hazardous waste disposal company for 

26 separation, processing, and disposal. The NRC staff determined that adequate storage 

27 capacity occurs within the facility to accommodate the waste generated and stored between 

28 shipments to offsite disposal facilities.

29 Based on NWMI’s proposed waste management systems, processes to minimize chemical

30 contamination, and because NWMI would operate within applicable Federal and State of 

31 Missouri regulations, the NRC staff concludes impacts from nonradioactive waste would be 

32 SMALL during construction, operations, and decommissioning.

33 4.10 Transportation

34 This section describes potential non-radiological transportation impacts during the construction, 

35 operations, and decommissioning of the proposed NWMI facility at the Discovery Ridge site. 

36 The impact analysis considers changes in traffic volumes on the existing roadway network. The 

37 radiological impacts of transporting radioactive materials and waste are discussed in Section 4.8 

38 and 4.9.

39 4.10.1 Construction

40 Transportation impacts occurring during the construction of the proposed NWMI facility would 

41 be caused by an increase in commuter vehicles and construction trucks on local roads. 

42 Construction workers would arrive via site access roads as discussed in Section 3.9.1 and traffic

43 volumes on these roads would increase during shift changes. In addition, trucks would deliver 

44 construction equipment and material to the work site and remove construction waste material, 

45 thereby adding to traffic volumes on site access roads. The increase in vehicular traffic would 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 peak during certain hours of the day (e.g., shift changes), resulting in temporary levels of 

2 service impacts and possible delays at intersections.

3 During construction, an average daily workforce of 38 workers would be commuting to and from 

4 the construction site at Discovery Ridge for 17 months. During peak construction, up to 

5 82 workers could be commuting daily to the construction site. In addition, an average of 

6 20 trucks per week (4 trucks per day) would deliver construction equipment and material to the 

7 work site. An additional 1 truck per week would remove construction waste (NWMI2015a).

8 Because of the small size of the average daily workforce, the low number of daily truck 

9 deliveries and shipments, combined with the short duration of construction (17 months), and 

10 easy access to U.S. Highway 63, there would be little if any noticeable traffic volume-related 

11 level of service impacts. Therefore, transportation impacts would be SMALL.

12 4.10.2 Operations

13 Transportation impacts occurring during preoperations and operation of the proposed NWMI 

14 facility would be caused by an increase in commuter vehicles and delivery trucks on the local 

15 roadway network. Operations workers would arrive via site access roads as discussed in 

16 Section 3.9.1 and traffic volumes on these roads would increase during shift changes. In 

17 addition, trucks would deliver production material, ship products, and remove waste material, 

18 thereby adding to the traffic volumes on site access roads. The increase in vehicular traffic 

19 would peak during certain hours of the day (e.g., shift changes), resulting in temporary levels of 

20 service impacts and possible delays at intersections.

21 During operations (30 years), 98 workers would be commuting to and from the proposed NWMI 

22 facility at Discovery Ridge (NWMI 2015a). In addition, an average of 2 to 4 trucks per week 

23 would deliver nonradioactive material; an average of 2 to 3 trucks per week would deliver 

24 irradiated LEU targets; and another 2 trucks per year would deliver fresh LEU (NWMI 2015a).

25 In addition, outbound truck traffic would include the following:

26 an average of 1 truck shipment per week of LEU targets to irradiation facilities,

27 an average of 2 shipments per week of medical isotope product through the 

28 Columbia Regional Airport,

29 an average of 3 to 4 shipments per week of waste, and

30 an average of 2 truck shipments per year of take-back LEU (NWMI 2015c).

31 Medical isotope product shipments to customers would be transported from the NWMI facility by 

32 truck to the Columbia Regional Airport, approximately 7 mi (11 km) away. Radioactive and 

33 nonradioactive waste would also be transported via common truck carrier from the NWMI facility 

34 to an offsite storage, treatment, or disposal facility.

35 The relatively small size of the workforce and low number of daily truck deliveries and 

36 shipments would generate little if any noticeable traffic volume-related level of service impacts. 

37 Therefore, given the size of the operations workforce, the number of trucks, and easy access to 

38 U.S. Highway 63, transportation impacts during NWMI facility operations would be SMALL.

39 4.10.3 Decommissioning

40 Transportation impacts occurring during the decommissioning would be caused by an increase 

41 in commuter vehicles and trucks on the local roads. Decommissioning workers commuting to 

42 the work site would arrive via site access roads and traffic volumes on these roads could 

43 increase during shift changes. In addition, trucks would deliver equipment and material to the 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 work site and remove waste material, thus adding to traffic volumes on site access roads. The 

2 increase in vehicular traffic would peak during certain hours of the day (e.g., shift changes) 

3 resulting in temporary levels of service impacts and possible delays at intersections.

4 During construction, an average daily workforce of 38 workers would be commuting to and from 

5 the work site at Discovery Ridge for 18 to 24 months. During peak decommissioning activities, 

6 up to 81 workers could be commuting daily. In addition, an average of 1 truck per week would 

7 deliver equipment and material to the work site. An additional 20 trucks per week would remove 

8 construction waste (NWMI 2015a).

9 Because of the small size of the average daily workforce, the low number of daily truck 

10 deliveries and shipments, combined with the short duration of decommissioning (18 to 

11 24 months), and easy access to U.S. Highway 63, there would be little if any noticeable traffic

12 volume-related level of service impacts. Therefore, transportation impacts would be SMALL.

13 4.11 Accidents

14 This section discusses the environmental impacts associated with potential radiological and 

15 hazardous chemical accidents that might occur at the proposed NWMI facility. In addition to this 

16 EIS, the NRC staff will perform an independent verification of the potential accident scenarios 

17 and associated consequences at the proposed NWMI facility in its SER. The SER is part of the 

18 regulatory process that the NRC uses to decide whether to issue a construction permit and 

19 operating license for the proposed NWMI facility.

20 The term “accident,” as used in this section, refers to any off-normal event that may affect the 

21 health or safety of facility workers and/or members of the public due to the release of, or 

22 exposure to, radioactive material or hazardous chemicals. The accidents described in this 

23 section are associated with processes and activities that would occur at the proposed NWMI 

24 facility.

25 Potential initiating events and credible operational accidents for the proposed NWMI facility 

26 constitute the design-basis accidents (DBAs). For example, NWMI considered a fire at the 

27 proposed facility as a credible DBA scenario (NWMI 2015a). The proposed NWMI facility would 

28 be required to be designed and built to withstand any internal (e.g., caused by a component 

29 failure) or external (e.g., caused by a weather event) DBA without loss of systems needed to 

30 ensure safety. 

31 This EIS considers hypothetical accidents that would be considered to bound any DBA at the 

32 proposed NWMI facility, and uses the impacts from those hypothetical, bounding accidents as 

33 the basis for determining the environmental impacts from potential accidents at the proposed 

34 facility. Although some types of accidents could involve both radiological and chemical hazards, 

35 for this EIS, the radiological and chemical hazards of potential accidents are considered 

36 separately. Radiological consequences of accidents at the proposed NWMI facility are 

37 discussed in Section 4.11.1, and chemical consequences of accidents are discussed in 

38 Section 4.11.2.

39 NWMI evaluated the consequences of accidents at the proposed facility, and the controls it 

40 would use to prevent or mitigate the consequences of accidents, against the performance 

41 requirements in 10 CFR 70.61. The NRC performance requirements for accidents in 

42 10 CFR 70.61 require that NWMI limit the risks of credible high-consequence and 

43 intermediate-consequence radiological and/or chemical events by applying engineered controls 

44 and/or administrative controls to reduce the likelihood and consequences of these events, and 

45 assure that all nuclear processes are subcritical under normal and credible abnormal conditions. 

46 To comply with 10 CFR 70.61, NWMI must have controls that:
Environmental Impacts of Construction, Operations, and Decommissioning

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1 • for any credible high-consequence radiological and/or chemical accident, either 

2 reduce the likelihood of the accident such that it would be highly unlikely, or reduce 

3 the consequences such that it would either be intermediate-consequence or 

4 low-consequence (i.e., less than intermediate-consequence);

5 • for any credible intermediate-consequence radiological and/or chemical accident, 

6 either reduce the likelihood of the accident such that it would be unlikely, or reduce 

7 the consequences such that it would be low-consequence (i.e., less than 

8 intermediate consequence); and,

9 • limit the risk of nuclear criticality accidents by assuring that under normal and 

10 credible abnormal conditions, all nuclear processes are subcritical.

11 Threshold consequence levels that define high- and intermediate-consequence radiological or 

12 chemical accidents for the purposes of evaluating compliance with 10 CFR 70.61 are provided 

13 in Sections 4.11.1 and 4.11.2.

14 4.11.1 Radiological Accidents

15 This section discusses the potential onsite and offsite radiological consequences of accidents at 

16 the proposed NWMI facility, and controls to prevent or mitigate the potential consequences. 

17 The results of the radiological accident analyses in this section are compared to the threshold 

18 consequence values in 10 CFR 70.61. The values are intended to be compared to the 

19 unmitigated consequences of credible accident scenarios. The threshold consequence values 

20 that define high- and intermediate-consequence radiological accidents for the purposes of 

21 evaluating compliance with 10 CFR 70.61 are provided in Table 4–6.

22 Table 4–6. Definition of High- and Intermediate-Consequence Radiological Accidents

Receptor High Consequence Intermediate Consequence

Worker Dose >100,000 mrem(a) Dose >25,000 mrem, and <100,000 

mrem

Member of the Public Dose >25,000 mrem, or 

>30 mg(b) soluble uranium

uptake

Dose >5,000 mrem, and <25,000 mrem

Environment outside of the 

Restricted Area Boundary

(Accidents are not defined as 

high-consequence based on the 

environment outside of the 

restricted area boundary)

24-hour-averaged release of radioactive 

material outside the restricted area in 

concentrations >5,000 times the values 

in 10 CFR Part 20, Appendix B, Table 2, 

“Effluent Concentrations”

(a) mrem = millirem

(b) mg = milligram

23 For evaluation of the radiological consequences for members of the public from potential 

24 accidents at the proposed NWMI facility, NWMI considered a variety of potential nuclear 

25 criticality or radioactive material accidents, including:

26 • liquid spills or sprays with radiological and/or criticality safety consequences;

27 • target dissolver offgas accidents with radiological consequences;
Environmental Impacts of Construction, Operations, and Decommissioning

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1 • leaks into auxiliary services or systems with radiological and/or criticality safety 

2 consequences;

3 • loss of electrical power with radiological consequences; and

4 • natural phenomena (external events) with radiological consequences (NWMI 2015g, 

5 2015i).

6 Other events were either determined to be bounded by the events listed above; were 

7 determined, based on low likelihood and/or consequences, to pose an acceptably low level of 

8 risk; or, they have not yet been fully evaluated by NWMI (NWMI will provide additional 

9 information for these events in the operating license application that it will submit for future NRC 

10 review) (NWMI 2015i).

11 The accidents listed above include one hypothetical radioactive material accident, based on 

12 events unique to the design of the proposed facility, that NWMI stated would result in 

13 radiological consequences for members of the public that would bound those of any credible 

14 radiological accident. NWMI identified this accident as a fire-related gross failure of the target 

15 dissolution offgas treatment system. The target dissolution offgas treatment system is 

16 essentially a filtration system designed to collect the radioactive iodine and noble gasses 

17 released during routine operation of the target dissolution systems. For the bounding 

18 radiological accident at the proposed NWMI facility, the failure of the target dissolution offgas 

19 treatment system would release all radioactive iodine and noble gas isotopes retained in that 

20 system out of the 75 ft (22.9 m) facility stack without mitigation. NWMI performed its analysis 

21 based on the assumption that 12 irradiated LEU targets per week, for 12 weeks immediately 

22 preceding the accident, had been processed upstream of the offgas treatment system. NWMI 

23 stated that its analysis of this accident is based on extremely conservative initial conditions and 

24 assumptions, including:

25 • maximum accumulation of radioactive iodine and noble gasses in the offgas 

26 treatment system based on the assumed target processing history (i.e., all iodine and 

27 noble gases in the targets are released into the offgas system, and no iodine or 

28 noble gases are captured by other scrubbing systems or retained in the target 

29 dissolution system);

30 • greater release of material from the offgas treatment system than would be expected 

31 to occur during an actual offgas treatment system fire; and

32 • no mitigation (e.g., from filtration or plate-out of iodine) of the release between the 

33 offgas treatment system and the facility stack (NWMI 2015a, 2015i, 2016a).

34 In addition, NWMI applied a safety margin of 1.32 to the source term inventory used for the 

35 analysis (NWMI 2016a) (i.e., the amount of radioactive material that could be released was 

36 multiplied by 1.32 to account for any uncertainty in the material quantity estimate). Because of 

37 these conservative initial conditions and assumptions, NWMI’s bounding radiological accident is 

38 a hypothetical radioactive material release with a maximized source term, and all material in the 

39 source term is released to the environment (no mitigation). All credible internally or externally 

40 initiated DBAs that could cause a radiological release from the proposed facility to the 

41 environment would be bounded by this accident.

42 NWMI calculated the potential doses to offsite members of the public for its bounding 

43 unmitigated radiological accident as follows:

44 • The total effective dose equivalent (TEDE) to a member of the public at the nearest 

45 fence line, 10 m (32.8 ft) from the facility stack, would be 360 mrem.
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1 • The TEDE at the furthest fence line, 91 m (299 ft) from the facility stack, would be 

2 700 mrem.

3 • The TEDE at the nearest residence, 430 m (1,411 ft) from the facility stack, would be 

4 3,100 mrem.

5 • The TEDE at the point of maximum offsite dose would be 22,600 mrem, received 

6 1,100 m (3,609 ft) from the facility stack (NWMI 2016a).

7 The TEDE increases with increasing distance from the point of release because the release 

8 point is elevated above ground level (due to the 75 ft (22.9 m) stack), and most of the 

9 radioactive material will be blown some distance from the release point before it reaches ground 

10 level, where it could be inhaled by an individual. Beyond 1,100 m (3,609 ft) from the stack, 

11 however, the doses start to decrease, because beyond that point the radioactive material has 

12 become more diluted/dispersed in the air and the ground-level concentration is lower.

13 The NRC staff considered the consequences of the radiological accident that NWMI stated 

14 would be the bounding radiological accident for the proposed NWMI facility, without regard to 

15 the likelihood that this accident could actually occur. Based on the maximum offsite dose

16 calculated by NWMI of 22,600 mrem, and the 10 CFR 70.61 threshold consequence values 

17 listed in Table 4–6, if the bounding radiological accident for the proposed NWMI facility were to 

18 occur, it would be intermediate-consequence for members of the public. If, as NWMI stated, the 

19 consequences of this accident for members of the public bound those of any other credible 

20 radiological accident, then any other unmitigated, credible accident at the proposed NWMI 

21 facility would be either intermediate- or low-consequence for radiological consequences to 

22 members of the public.

23 NWMI also provided analyses of radiological consequences to facility staff (occupational 

24 workers) from possible accidents at the proposed NWMI facility. NWMI identified a credible 

25 type of radioactive material accident involving a spill of liquid Mo-99 product solution, and 

26 calculated that for this accident, the unshielded direct radiation dose rate to a worker located 

27 1 m (3.3 ft) from the spill would be 1,500,000 mrem per hour. This dose rate could lead to a 

28 high-consequence (>100,000 mrem) or intermediate-consequence (>25,000 mrem) dose to a 

29 worker in a short period of time (NWMI 2015i). NWMI also identified credible scenarios, 

30 including spills or leaks from process vessels that could result in accidents involving an 

31 inadvertent nuclear criticality. Due to the intense levels of radiation that can be produced during

32 a nuclear criticality accident, these types of accidents could have very significant dose 

33 consequences for facility staff, especially any staff located in the immediate vicinity of the 

34 accident. Therefore, NWMI qualitatively assumed that these accidents could be 

35 high-consequence for facility staff (NWMI 2015i). Given the types of accidents described by 

36 NWMI which could have radiological consequences for NWMI facility personnel, the NRC staff 

37 assumes that unmitigated, credible accidents at the proposed NWMI facility could be high-, 

38 intermediate-, or low-consequence for radiological consequences to facility staff.

39 NWMI has proposed in its preliminary safety analysis report to have various controls (including 

40 engineering design features and administrative controls) that would prevent the initiation of 

41 nuclear or radioactive material accidents, or mitigate their consequences (NWMI 2015i). These 

42 would include controls that would mitigate the consequences of radiological accidents, but 

43 which were not credited in the analyses above, such as:

44 • use of hot cells, confinement boundaries, and shielding in process areas;

45 • double-wall piping;

46 • sumps to capture and remove spilled liquids;
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1 • radiation monitoring; 

2 • an emergency nitrogen purge system that will limit the likelihood of fires by 

3 preventing the buildup of flammable hydrogen gas in the process vessels; and,

4 • design of the facility ventilation system and dissolution offgas treatment system, 

5 including the use of filters to remove radioactive gasses and particulates 

6 (NWMI 2015a, 2015i).

7 NWMI has also proposed to have additional preventative controls specific to nuclear criticality 

8 accidents, including:

9 • geometry of, and spacing between, process vessels; and,

10 • geometry of liquid collection sumps (NWMI 2015i).

11 NWMI stated that, for any accident with high radiological consequences for workers, members 

12 of the public, and/or the environment (as determined by the criteria in 10 CFR 70.61), the 

13 controls proposed in its preliminary safety analysis report would either reduce the likelihood 

14 such that it would be highly unlikely; or, reduce the consequences such that it would be 

15 intermediate- or low-consequence. Additionally, NWMI stated that for any accident with 

16 intermediate radiological consequences for workers, members of the public, and/or the 

17 environment (as determined by the criteria in 10 CFR 70.61), the controls proposed in its 

18 preliminary safety analysis report would either reduce the likelihood such that it would be 

19 unlikely; or, reduce the consequences such that it would be low-consequence (NWMI 2016c, 

20 2016d). NWMI also stated that nuclear criticality controls proposed in its preliminary safety 

21 analysis report would be designed such that process systems would remain subcritical under 

22 normal and credible abnormal operating conditions (NWMI 2015i).

23 The NRC staff is conducting an independent review of the radiological consequences of 

24 accidents at the proposed NWMI facility, and of the controls proposed by NWMI. The NRC staff 

25 will document this review in its SER. The NRC staff will determine whether the controls will be 

26 designed, implemented, and maintained to ensure they are available and reliable to perform 

27 their preventative and mitigating functions when needed. The NRC staff will also determine 

28 whether the controls are sufficient to ensure that the likelihood and/or consequences of any 

29 credible radiological accidents at the proposed NWMI facility would be reduced such that the 

30 proposed facility would be in compliance with the performance requirements in 10 CFR 70.61 

31 and any other applicable NRC regulations. If the NRC staff determines in its SER that the 

32 proposed NWMI facility would comply with 10 CFR 70.61 and any other NRC regulations 

33 applicable to radiological accident consequences, the NRC staff concludes that the impacts 

34 from potential nuclear or radioactive material accidents at the proposed facility would be 

35 SMALL.

36 4.11.2 Hazardous Chemical Accidents

37 This section discusses the potential onsite and offsite hazardous chemical exposure 

38 consequences of accidents at the proposed NWMI facility, and controls to prevent or mitigate 

39 the potential consequences. The results of the chemical accident analyses in this section are 

40 compared to the threshold consequences in 10 CFR 70.61, which are intended to be compared 

41 to the unmitigated consequences of credible accident scenarios. The general threshold 

42 consequences that define high- and intermediate-consequence hazardous chemical accidents 

43 for the purposes of evaluating compliance with 10 CFR 70.61 are provided in Table 4–7.
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1 Table 4–7. Definition of High- and Intermediate-Consequence Chemical Accidents

Receptor High Consequence Intermediate Consequence

Worker Could endanger the life of a worker Could lead to irreversible or other 

serious, long-lasting health effects to a 

worker

Member of the Public Could lead to irreversible or other 

serious, long-lasting health effects to 

any individual located outside the 

controlled area

Could cause mild transient health 

effects to any individual located 

outside the controlled area

2 The accidents that involve hazardous chemicals, and that could result in chemical exposure to 

3 workers or members of the public, include the following:

4 • chemical burns from contaminated solutions during sample analysis;

5 • nitric acid fume release; and,

6 • release of other chemicals, such as hydrogen peroxide, ammonia, or carbon dioxide, 

7 that would be present at the proposed facility (NWMI 2015a, 2015i).

8 The chemical accidents evaluated by NWMI are hypothetical severe chemical accidents that 

9 NWMI considered to bound any other potential chemical accident at the proposed NWMI facility. 

10 The accidents involve unmitigated releases of chemicals that would be used in conjunction with 

11 the processing of licensed radioactive material at the proposed facility. NWMI’s analyses used 

12 the Areal Locations of Hazardous Atmospheres (ALOHA) computer code (NWMI 2015a). 

13 ALOHA is an atmospheric dispersion model that evaluates releases of hazardous chemical 

14 vapors. The use of this code for chemical accident analyses is consistent with methodologies 

15 described in the NRC’s Nuclear Fuel Cycle Facility Accident Analysis Handbook (NRC 1998).

16 In its analysis, NWMI evaluated the unmitigated release from tank breach or rupture of the 

17 following chemical materials:

18 • nitric acid (HNO3, 10.4 M aqueous solution),

19 • hydrogen peroxide (H2O2, 10.4 M aqueous solution),

20 • ammonia (NH3, gas), and

21 • carbon dioxide (CO2, gas) (NWMI 2015a).

22 For liquid chemicals (aqueous solutions), the release scenario assumed a breach in a chemical

23 tank resulting in an unconfined spill and subsequent evaporation. For gases, the release 

24 scenario assumed a ruptured tank resulting in an immediate release to the atmosphere. The 

25 chemicals selected for analysis were chosen based on quantity used at the facility and 

26 availability in the ALOHA code’s library, which includes chemicals that could pose an airborne 

27 dispersion hazard. For the chemicals analyzed, the material at risk (MAR) was based on the 

28 estimated maximum inventory of each chemical at the proposed NWMI facility. These inventory 

29 values are considered to be conservative, bounding conditions. In addition, no credit was taken 

30 for depletion or plate-out of any chemicals, either within the proposed NWMI facility or during 

31 transport to receptor locations (NWMI 2015a).

32 For evaluating possible chemical release exposures to members of the public, NWMI assumed 

33 that the releases would occur at ground level. NWMI calculated airborne chemical 

34 concentrations at the location of a maximally exposed offsite individual (MOI) at a point along 
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1 the boundary fence estimated to be 24 m (80 ft) from the release point (based on the general 

2 layout of the proposed facility and where chemicals would be located), and at the location of the 

3 nearest resident, 430 m (1,425 ft) from the release point. Concentrations were calculated based 

4 on 1-hour release/exposure scenarios. NWMI assumed average meteorological conditions for 

5 these calculations. The results, in units of parts per million (ppm), are listed in Table 4–8 

6 (NWMI 2015a).

7 To determine human health impacts associated with the accidental release of hazardous 

8 chemicals, estimated airborne chemical concentrations are compared against protective action 

9 criteria (PAC) limits. PAC limits are essential components of planning for the uncontrolled 

10 release of hazardous chemicals. These limits, combined with estimates of exposure, provide 

11 the information necessary to identify and evaluate accidents for the purpose of taking 

12 appropriate protective actions. During an emergency response to an uncontrolled chemical 

13 release, these limits may be used to evaluate the severity of the event, to identify potential 

14 outcomes, and to decide what protective actions should be taken. In anticipation of a possible 

15 uncontrolled release, these limits may also be used to estimate the consequences of the 

16 possible uncontrolled release and to plan emergency responses (DOE 2008).

17 U.S. Department of Energy (DOE) guidance states that PAC values equivalent to the 1-hour 

18 Acute Exposure Guideline Levels (AEGLs), which are developed by EPA and the National 

19 Academy of Sciences, should be used to assess the potential impacts associated with the 

20 accidental release of hazardous chemicals. Three levels of AEGL values (AEGL-1, AEGL-2, 

21 and AEGL-3) are used for each of five exposure periods (10 minutes, 30 minutes, 1 hour, 

22 4 hours, and 8 hours). The three levels of AEGL values are distinguished by varying degrees of 

23 severity of toxic effects based on exposure to the chemical concentration values associated with 

24 each AEGL level over the given exposure period. The three AEGL levels are defined as 

25 follows:

26 AEGL-1 is the airborne concentration of a substance above which it is predicted that 

27 the general population, including susceptible individuals, could experience notable 

28 discomfort, irritation, or certain asymptomatic nonsensory effects. However, the 

29 effects are not disabling and are transient and reversible on cessation of exposure.

30 AEGL-2 is the airborne concentration of a substance above which it is predicted that 

31 the general population, including susceptible individuals, could experience 

32 irreversible or other serious, long-lasting adverse health effects or an impaired ability 

33 to escape.

34 AEGL-3 is the airborne concentration of a substance above which it is predicted that 

35 the general population, including susceptible individuals, could experience 

36 life-threatening health effects or death (DOE 2008).

37 In addition to the estimated chemical concentrations calculated by NWMI, Table 4–8 lists, for 

38 comparison, the PAC-1, PAC-2, and PAC-3 values (for nitric acid and ammonia, these are 

39 equivalent to 1-hour AEGL-1, AEGL-2, and AEGL-3 values, respectively) for each chemical 

40 evaluated by NWMI in its accident analysis. For hydrogen peroxide and carbon dioxide, AEGL 

41 values are not available. DOE guidance states that if AEGL values do not exist for a given 

42 chemical, Emergency Response Planning Guideline (ERPG) values, or in the absence of ERPG 

43 values, Temporary Emergency Exposure Limit (TEEL) values, should be used in place of AEGL 

44 values to determine PACs. ERPG and TEEL values are similar to AEGL values, but they are 

45 developed by the American Industrial Hygiene Association (AIHA), and by DOE, respectively. 

46 Additionally, ERPG values are always based on 1-hour exposures, and TEEL values are based 

47 on 15-min exposures, in contrast to the range of exposure times for which AEGL values are 
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1 available (DOE 2008). The PACs in Table 4–8 for hydrogen peroxide are based on ERPGs for 

2 that chemical, and the PACs for carbon dioxide are based on TEELs.

3 Table 4–8. NWMI Hazardous Chemical Concentrations

Chemical MAR(d)

Concentration 

at MOI(g)

Concentration at 

Nearest Resident PAC(i)-1 PAC-2 PAC-3

Nitric acid(a) 5,000 L(e) 1,200 ppm(h) 19.1 ppm 0.16 ppm 24 ppm 92 ppm

Hydrogen(b)

peroxide

500 L 1.74 ppm 0.963 ppm 10 ppm 50 ppm 100 ppm

Ammonia(a) 100 kg(f) 36,800 ppm 123 ppm 30 ppm 160 ppm 1,100 ppm

Carbon 

dioxide(c)

200 kg 28,500 ppm 95.1 ppm 30,000 ppm 40,000 ppm 50,000 ppm

(a) PACs for nitric acid and ammonia are based on 1-hour AEGLs. Source for AEGLs: EPA 2016a.

(b) PACs for hydrogen peroxide are based on ERPGs. Source for ERPGs: AIHA 2013.

(c) PACs for carbon dioxide are based on TEELs. Source for TEELs: ATL International 2016.

(d) MAR = material at risk

(e) L = liters

(f) kg = kilograms

(g) MOI = maximally exposed offsite individual

(h) ppm = parts per million

(i) PAC = protective action criteria

Source for MARs and concentrations: NWMI 2015a

4 Comparison of the concentrations to the corresponding PACs in Table 4–8 indicates that 

5 possible chemical accidents involving releases of nitric acid and/or ammonia would pose a 

6 much greater risk to human health than accidents involving hydrogen peroxide or carbon 

7 dioxide. For nitric acid and ammonia, the MOI could be exposed to concentrations that are 

8 significantly greater than PAC-3 values. At these concentrations, it is predicted that individuals 

9 could experience life-threatening health effects or death. Additionally, the individuals at the 

10 nearest residence could be exposed to concentrations that are above PAC-1 values but below 

11 PAC-2 values, and these individuals could experience transient, non-disabling health effects 

12 including notable discomfort or irritation. However, since the effects on individuals at the 

13 nearest residence would be non-disabling, the effects would likely not impair the individuals’ 

14 ability to take protective action (i.e., seek shelter or evacuate to a location further away from the 

15 proposed NWMI facility).

16 NWMI additionally stated that another liquid-form chemical, sodium hydroxide (NaOH, 19 M 

17 aqueous solution), that would be used at the proposed facility would have an MAR of 1,900 L 

18 (502 gal). NWMI did not provide an analysis (calculation of estimated concentrations at the MOI 

19 and/or nearest residence) of a chemical accident involving a sodium hydroxide release, but 

20 NWMI stated that it assumed, based on the large MAR quantity and the low PACs for sodium 

21 hydroxide, that a sodium hydroxide release could cause PAC-2 limits to be exceeded at 

22 locations occupied by members of the public (NWMI 2015a).

23 The NRC staff considered the consequences of the chemical accidents that NWMI stated would 

24 be bounding chemical accidents for the proposed NWMI facility, without regard to the likelihood 
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1 that these accidents could actually occur. Based on the analysis provided by NWMI and the 

2 threshold consequences listed in Table 4-7, if a bounding severe chemical accident for the 

3 proposed NWMI facility were to occur, it could be high-consequence for members of the public 

4 (for nitric acid, ammonia, or sodium hydroxide release). The NRC staff assumes that smaller, 

5 less severe releases of nitric acid, ammonia, or sodium hydroxide could be intermediate- or

6 low-consequence for members of the public. NWMI’s analysis shows that bounding hydrogen 

7 peroxide or carbon dioxide release accidents would be low-consequence for members of the 

8 public. NWMI did not provide an analysis of possible chemical exposures to workers at the 

9 proposed NWMI facility, but stated that for a bounding chemical accident involving a nitric acid 

10 release, chemical exposures to workers would be much higher than the exposure to the MOI 

11 (NWMI 2015i). Therefore bounding severe chemical accidents at the proposed NWMI facility 

12 could also be high-consequence for the facility staff. Given the bounding analyses provided by 

13 NWMI, the NRC staff assumes that unmitigated, credible accidents at the proposed NWMI 

14 facility could be high-, intermediate-, or low-consequence for chemical exposure to members of 

15 the public or facility staff, depending on the type and quantity of chemicals involved.

16 NWMI has proposed in its preliminary safety analysis report to have various controls (including 

17 engineering design features and administrative controls) that would prevent the initiation of 

18 hazardous chemical accidents, or mitigate their consequences. These would include controls 

19 that would mitigate the consequences of chemical accidents, but which were not credited in the 

20 analyses above, such as:

21 • use of procedures for handling chemicals;

22 • design and construction of chemical preparation and storage areas; and,

23 • use of confinement boundaries and barriers in process areas, to confine spills or 

24 releases and protect workers from liquid sprays (NWMI 2015i).

25 NWMI stated that, for any chemical release accident with high consequences for workers or 

26 members of the public (as determined by the criteria in 10 CFR 70.61), the controls proposed in 

27 its preliminary safety analysis report would either reduce the likelihood such that it would be 

28 highly unlikely; or, reduce the consequences such that it would be intermediate- or 

29 low-consequence. Additionally, NWMI stated that for any chemical release accident with 

30 intermediate consequences for workers or members of the public (as determined by the criteria 

31 in 10 CFR 70.61), the controls proposed in its preliminary safety analysis report would either 

32 reduce the likelihood such that it would be unlikely; or, reduce the consequences such that it 

33 would be low-consequence (NWMI 2016c, 2016d).

34 The NRC staff is conducting an independent review of the consequences of hazardous 

35 chemical accidents at the proposed NWMI facility, and of the controls proposed by NWMI. 

36 The NRC staff will document this review in its SER. The NRC staff will determine whether the 

37 controls will be designed, implemented, and maintained to ensure they are available and 

38 reliable to perform their preventative and mitigating functions when needed. The NRC staff will 

39 also determine whether the controls are sufficient to ensure that the likelihood and/or 

40 consequences of any credible hazardous accidents at the proposed NWMI facility would be 

41 reduced such that the proposed facility would be in compliance with the performance 

42 requirements in 10 CFR 70.61 and any other applicable NRC regulations. If the NRC staff 

43 determines in its SER that the proposed NWMI facility would comply with 10 CFR 70.61 and any 

44 other applicable NRC regulations to hazardous chemical accident consequences, the NRC staff 

45 concludes that the impacts from potential hazardous chemical accidents at the proposed facility 

46 would be SMALL.
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1 4.12 Environmental Justice

2 This section describes the potential human health and environmental effects from the 

3 construction, operations, and decommissioning of the proposed NWMI facility on minority and 

4 low-income populations living near the proposed Discovery Ridge site. The NRC strives to 

5 identify and consider environmental justice issues in agency licensing and regulatory actions 

6 primarily by fulfilling its NEPA responsibilities for these actions.

7 Under Executive Order (EO) 12898 (59 FR 7629), Federal agencies are responsible for 

8 identifying and addressing, as appropriate, potential disproportionately high and adverse human 

9 health and environmental impacts on minority and low-income populations. In 2004, the 

10 Commission issued a Policy Statement on the Treatment of Environmental Justice Matters in 

11 NRC Regulatory and Licensing Actions (69 FR 52040), which states that “[t]he Commission is 

12 committed to the general goals set forth in EO 12898, and strives to meet those goals as part of 

13 its NEPA review process.”

14 The CEQ provides the following definitions to consider when conducting environmental justice 

15 reviews within the framework of NEPA in Environmental Justice: Guidance under the National 

16 Environmental Policy Act (CEQ 1997):

17 Disproportionately High and Adverse Human Health Effects. Adverse health 

18 effects are measured in risks and rates that could result in latent cancer fatalities, as 

19 well as other fatal or nonfatal adverse impacts on human health. Adverse health 

20 effects may include bodily impairment, infirmity, illness, or death. Disproportionately 

21 high and adverse human health effects occur when the risk or rate of exposure to an 

22 environmental hazard for a minority or low-income population is significant 

23 (as employed by NEPA) and appreciably exceeds the risk or exposure rate for the 

24 general population or for another appropriate comparison group.

25 Disproportionately High and Adverse Environmental Effects. A disproportionately 

26 high environmental impact that is significant (as employed by NEPA) refers to an 

27 impact or risk of an impact on the natural or physical environment in a low-income or 

28 minority community that appreciably exceeds the environmental impact on the larger 

29 community. Such effects may include ecological, cultural, human health, economic, or 

30 social impacts. An adverse environmental impact is an impact that is determined to be 

31 both harmful and significant (as employed by NEPA). In assessing cultural and 

32 aesthetic environmental impacts, impacts that uniquely affect geographically dislocated 

33 or dispersed minority or low-income populations or American Indian tribes are 

34 considered.

35 The environmental justice analysis assesses the potential for disproportionately high and 

36 adverse human health or environmental effects on minority populations and low-income 

37 populations that could result from the construction, operations, and decommissioning of the 

38 NWMI facility. In assessing the impacts, the following definitions of minority individuals and 

39 populations and low-income population were used (CEQ 1997):

40 Minority individuals. Individuals who identify themselves as members of the following 

41 population groups: Hispanic, Latino or Spanish origin, American Indian or Alaska 

42 Native, Asian, Black or African American, Native Hawaiian or Other Pacific Islander, or 

43 two or more races—meaning individuals who identified themselves on a Census form 

44 as being a member of two or more races (e.g., Hispanic and Asian).

45 Minority populations. Minority populations are identified when the minority population

46 of an affected area exceeds 50 percent or the minority population percentage of the 
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1 affected area is meaningfully greater than the minority population percentage in the 

2 general population or other appropriate unit of geographic analysis.

3 Low-income population. Low-income populations in an affected area are identified 

4 with the annual statistical poverty thresholds from the [U.S.] Census Bureau’s Current 

5 Population Reports, Series P60, on Income and Poverty.

6 Methodology for Assessing Environmental Justice Impacts

7 The NRC addresses environmental justice issues and concerns by first identifying potentially 

8 affected minority and low-income populations and then determining whether there would be any 

9 potential human health or environmental effects and whether any of these effects would be 

10 disproportionately high and adverse. Adverse health effects are measured in terms of the risk 

11 and rate of fatal or nonfatal impacts on human health. Disproportionately high and adverse 

12 human health effects may occur when the risk or rate of exposure to an environmental hazard 

13 would be significant for a minority or low-income population and exceed the risk or rate of 

14 exposure for the general population or some other comparable population. Disproportionately 

15 high environmental effects refer to impacts or risks of impacts on the natural or physical 

16 environment in a minority or low-income community that are significant and that appreciably 

17 exceed the environmental impact on the larger community. Such effects may include biological, 

18 cultural, economic, or social impacts.

19 Consistent with the Commission’s Policy Statement (69 FR 52040), affected populations are 

20 defined as minority and low-income populations who reside within a 5-mi (8-km) radius of the 

21 proposed NWMI facility site. Data on minority and low-income populations are usually collected 

22 and analyzed at the Census tract or Census block group level.

23 The U.S. Census Bureau (USCB) compiles demographic information at the Census tract and 

24 block group levels in small geographic areas. A Census tract is a small area that is a statistical 

25 subdivision of a county or statistically equivalent entity. A block group is a statistical subdivision 

26 of a Census tract. A Census block is the smallest geographic entity for which the USCB collects 

27 and tabulates demographic data.

28 Minority population data are available for Census block groups within a 5-mi (8-km) radius of the 

29 proposed NWMI facility site. Low-income population data are only available at the Census tract 

30 level because of the limited availability of poverty and income data at the block group level. To 

31 protect confidentiality, USCB does not publish information about small geographic areas if the 

32 population size is too small. Race and ethnicity and poverty and income data were used to 

33 determine the presence of minority and low-income populations. If the center point of the 

34 Census tract and block group is within the 5-mi (8-km) radius boundary, data from the entire 

35 Census tract or Census block group was used.

36 Minority Population

37 According to the 2010 Census, approximately 23 percent of the City of Columbia population

38 (which includes more than one Census tract and block group) identified themselves as minority. 

39 In Boone County, approximately 19 percent of the population identified themselves as minority. 

40 According to the U.S. Census Bureau’s 2014 American Community Survey 1-Year Estimates, 

41 since 2010 minority populations in the City of Columbia and Boone County were estimated to 

42 have increased by approximately 3,000 to 4,000 persons and now comprise 24 and 

43 20.2 percent of the respective populations (see Table 3–15). (UCSB 2016b).

44 Approximately 22 percent of the population identified themselves as minority individuals (Table 

45 4–9) within the 5-mi (8-km) radius of the proposed Discovery Ridge site (MCDC 2016a). The 
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1 largest minority group was Black or African American at 10.3 percent, followed by Asian at 

2 5.4 percent (MCDC 2016a).

3 Census block groups were considered minority population block groups if the percentage of the 

4 minority population within any block group exceeded 22 percent. Eleven of the 30 Census block 

5 groups were found to have meaningfully greater minority populations. These block groups are 

6 concentrated northwest and west of the proposed NWMI facility site near the City of Columbia. 

7 The Discovery Ridge site is located in Census Tract 10.02, Block Group 3, with a minority 

8 population of 12.5 percent.

9 Table 4–9. Minority Populations in Census Block Groups Within 5 mi (8 km) of the 

10 Discovery Ridge Site

Census Tract Block Group Total Population

Minority 

Population(a) Percent Minority

2 1 665 139 20.9

2 2 1,065 171 16.1

3 1 641 66 10.3

3 2 1,151 81 7.0

3 3 1,218 229 18.8

5 1 1,441 536 37.2

5 2 1,353 258 19.1

6 1 1,151 82 7.1

10.01 1 1,316 373 28.3

10.01 2 864 222 25.7

10.01 3 2,476 446 18.0

10.02 1 2,979 462 15.5

10.02 2 2,194 529 24.1

10.02 3 777 97 12.5

11.01 1 2,815 522 18.5

11.01 2 3,304 666 20.2

11.01 3 2,509 501 20.0

11.03 1 1,421 136 9.6

11.03 3 1,281 312 24.4

11.03 4 1,537 284 18.5

11.04 1 3,444 508 14.8

11.04 3 3,265 796 24.4

15.02 2 2,172 822 37.8

15.02 3 712 396 55.6

16.01 3 3,498 969 27.7

21 2 1,472 858 58.3

21 3 832 264 31.7

22 1 3,230 674 20.9

22 2 2,203 389 17.7
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Census Tract Block Group Total Population

Minority 

Population(a) Percent Minority

22 3 1,320 62 4.7

(a) Includes people of Hispanic, Latino, or Spanish origin.

Census block groups with minority population percentages greater than 22 percent are in bold.

Source: USCB 2010 Census Summary File 1, Table P9, Hispanic or Latino or Not Hispanic or Latino by Race 

(USCB 2016b)

1 Low-Income Population

2 According to 2010–2014 American Community Survey estimates, an average of 11.3 percent of 

3 families and 20.7 percent of all people residing in Boone County were identified as living below 

4 the Federal poverty threshold. In addition, the City of Columbia had an average of 13.2 percent 

5 of families and 24.9 percent of all people identified as living below the Federal poverty level. 

6 The Federal poverty threshold for a family of four was $22,314 in 2010 and $24,230 in 2014 

7 (USCB 2016d).

8 Table 4–10 lists low-income population Census tracts within a 5-mi (8-km) radius of the 

9 Discovery Ridge site and the estimated average number of people living below the poverty 

10 level. According to the USCB’s American Community Survey 5-Year Estimates for 2010–2014, 

11 40.6 percent of the total population within that radius was identified as living below the Federal 

12 poverty level (MCDC 2016a).

13 Census tracts were considered low-income population Census tracts if the percentage of 

14 individuals living below the Federal poverty threshold exceeded 40.6 percent. Five of the nine 

15 Census tracts were found to have meaningfully greater low-income populations. These Census 

16 tracts are concentrated northwest and west of the proposed NWMI facility site.. The existing 

17 research park and proposed Discovery Ridge site are located in Census Tract 10.02 with an 

18 estimated 16.7 percent of its population living below the poverty level (USCB 2016d).

19 Table 4–10. Percentage of People and Families in Census Tracts Within 5 mi (8 km) of the 

20 Discovery Ridge Site Whose Income is Below the Poverty Level

Census Tract Total Population Percentage of People 

Below Poverty Level 

Percentage of Families 

Below Poverty Level

2 1,749 29.5 25.9

3 3,097 66.8 10.3

5 2,760 70.5 77.1

10.01 4,644 40.2 11.7

10.02 6,052 16.7 15.8

11.01 8,824 56.2 14.6

11.03 6,989 16.5 4.4

21 3,649 49.4 45.8

22 7,223 72.8 67.3

Census tracts with percentages of people below the poverty level is greater than 40.6 percent are in bold.

Source: USCB American Community Survey 5-Year Estimates, 2010–2014, Table DP03, Selected Economic 

Characteristics (USCB 2016d).
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1 Impact Analysis

2 Chapter 4 presents an assessment of the environmental effects from constructing, operating, 

3 and decommissioning the proposed NWMI facility at Discovery Ridge for all affected resource 

4 areas. The NRC uses this information to determine if there would be any human health or 

5 environmental effects that could disproportionately affect minority and low-income populations 

6 and whether any of these effects would be high and adverse.

7 The following sections in Chapter 4 describe the potential human health and environmental 

8 effects from constructing, operating, and decommissioning the proposed NWMI facility that 

9 could impact minority and low-income populations:

10 • radiological human health impacts (Sections 4.8.1.1, 4.8.2.1, and 4.8.3.1);

11 • nonradiological human health impacts (Sections 4.8.1.2, 4.8.2.2, and 4.8.3.3);

12 • noise impacts (Section 4.2.2); and

13 • traffic impacts (Section 4.10).

14 The NRC also considered whether there would be any environmental impacts that would affect 

15 a specific minority and low-income population and whether there would be any unique effects 

16 that could appreciably exceed or (are) likely to appreciably exceed those for the general 

17 population.

18 Subsistence Consumption of Fish and Wildlife

19 The special pathway receptors analysis is an important part of the environmental justice 

20 analysis because consumption patterns may reflect the traditional or cultural practices of 

21 minority and low-income populations in the area, such as migrant workers or Native Americans.

22 Section 4–4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and 

23 appropriate, to collect and analyze information about the consumption patterns of populations

24 that rely principally on fish and/or wildlife for subsistence and to communicate the risks of these 

25 consumption patterns to the public. In this EIS, the NRC considered whether there were any 

26 means for minority or low-income populations to be disproportionately affected by examining 

27 impacts on American Indians, Hispanics, migrant workers, and other traditional lifestyle special 

28 pathway receptors.

29 Based on the description of air- and water quality impacts and the discussion of human health 

30 effects in this EIS, it is unlikely that there would be any disproportionately high and adverse 

31 human health impacts in special pathway receptor populations in the region as a result of 

32 subsistence consumption of water, local food, fish, and wildlife. Thus, constructing, operating, 

33 and decommissioning the proposed NWMI facility at the Discovery Ridge site would not have 

34 disproportionately high and adverse human health and environmental effects on these 

35 populations.

36 4.12.1 Construction

37 Potential impacts to minority and low-income populations from the construction of the proposed 

38 NWMI facility at the Discovery Ridge site would mostly consist of environmental effects 

39 (e.g., noise, dust, and traffic). Noise and dust impacts during construction would be short term 

40 and primarily limited to onsite activities (Section 4.2.2.1). Minority and low-income populations 

41 residing along site access roads could be affected by an increase in the number of commuter 

42 vehicle and truck traffic traveling to and from the proposed work site. However, these effects 

43 are not likely to be different than what was previously experienced during the construction of 

44 other research facilities at Discovery Ridge Research Park (e.g., Missouri University plant 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 genetic research farm, IDEXX BioResearch). Given the short duration of construction, the small 

2 size of the average daily workforce, the small number of trucks, and the easy access to 

3 U.S. Highway 63, it is not likely that the construction of the proposed NWMI facility would have 

4 disproportionately high and adverse human health and environmental effects on minority and 

5 low-income populations living near Discovery Ridge.

6 4.12.2 Operations

7 Potential impacts to minority and low-income populations during NWMI facility operations would 

8 mostly consist of radiological and nonradiological human health and environmental (e.g., noise 

9 and traffic) effects. Everyone living near Discovery Ridge and the proposed NWMI facility could 

10 be affected by operations activities, including minority and low-income populations. Any human 

11 health and environmental effect would depend on the magnitude of the change from current 

12 environmental conditions. Minority and low-income populations residing along site access 

13 roads could be affected by the increased commuter vehicle and truck traffic during certain hours 

14 of the day.

15 As discussed in Section 4.8.2.1 of this EIS, the potential radiological dose to the public from 

16 NWMI facility operations would be well within NRC and applicable Federal, State, and local 

17 regulatory limits. As a result, everyone living near the proposed NWMI facility site, including 

18 minority and low-income populations, would not be adversely affected by radiation exposure 

19 during facility operations. Permitted nonradiological air emissions would also be required to 

20 remain within regulatory limits (Section 4.2.1.2).

21 As discussed in Section 4.2.2.2 of this EIS, noise levels may increase along U.S. Highway 63

22 because of increased commuter vehicle and truck traffic during NWMI facility operations. This 

23 may not be noticeable, however, given the relatively small size of the daily workforce and the 

24 limited number of truck deliveries and shipments. Based on this information, operation of the 

25 proposed NWMI facility would not likely have disproportionately high and adverse human health 

26 and environmental effects on minority and low-income populations living near Discovery Ridge.

27 4.12.3 Decommissioning

28 Similar to construction, potential impacts to minority and low-income populations during the 

29 decommissioning of the proposed NWMI facility at the Discovery Ridge site would mostly 

30 consist of environmental and socioeconomic effects (e.g., noise, dust, and traffic). Noise and 

31 dust impacts during decommissioning would be short term and primarily limited to onsite 

32 activities (Section 4.2.2.3). Minority and low-income populations residing along site access 

33 roads could be affected by an increase in the number of commuter vehicle and truck traffic 

34 traveling to and from the proposed work site. However, because of the temporary nature of 

35 decommissioning, these effects are not likely to be high and adverse and would be intermittent, 

36 only occurring when trucks and vehicles pass by during certain hours of the day. Given the 

37 short duration, the small size of the average daily workforce, the small number of trucks, and the 

38 easy access to U.S. Highway 63, it is not likely that decommissioning the proposed NWMI 

39 facility would have disproportionately high and adverse human health and environmental effects 

40 on minority and low-income populations living near Discovery Ridge.

41 4.13 Research Reactors

42 As discussed in Section 2.3.1.3, once the LEU targets are fabricated at the proposed NWMI 

43 RPF, the LEU targets will be transported to research reactors for irradiation. Research reactors 

44 that irradiate NWMI’s LEU targets will need to submit an application for a separate license 
Environmental Impacts of Construction, Operations, and Decommissioning

4-55

1 amendment to provide irradiation services to NWMI. The NRC must issue each reactor facility a

2 license amendment before NWMI’s LEU targets can be irradiated at each reactor. The NRC will 

3 conduct a separate safety and environmental review of each license amendment application 

4 submitted to the NRC. However, since irradiation of LEU targets is a connected action to the 

5 proposed action, the NRC will assess the environmental impact associated with irradiating LEU 

6 targets at the research reactors in this EIS.

7 On January 31, 2016, the NRC issued the Oregon State University TRIGA Research Reactor 

8 (OSTR) a license amendment that consisted of changes to the facility operating license and 

9 technical specifications (TS) that would allow the irradiation of up to three medical isotope 

10 production targets containing fissionable material in the OSTR to demonstrate the production of 

11 Mo-99 (NRC 2016d; OSU 2012). Oregon State University (OSU) has submitted to the NRC a 

12 letter stating OSU’s intent to submit a license amendment application in 2017 pertaining to the 

13 irradiation of LEU targets in the OSTR that would be fabricated by the proposed NWMI facility 

14 (OSU 2015b). The University of Missouri Research Reactor (MURR) has submitted a letter 

15 intent to submit a license amendment in 2016 pertaining to the irradiation of LEU targets 

16 (MU 2016e).

17 4.13.1 University of Missouri Research Reactor Site

18 4.13.1.1 Facility Modifications and Equipment Refurbishment

19 Facility modifications and equipment refurbishment at MURR are anticipated to be conducted 

20 prior to supporting the handling and irradiation of LEU targets. Facility modifications and 

21 equipment refurbishment activities will be completed inside the existing MURR building and will 

22 consist of (NWMI 2015a, 2015c):

23 • installation of 3 graphite reflector elements in the reactor,

24 • fabrication of a target transfer cask,

25 • construction of an airlock on the beamport floor of the reactor containment,

26 • installation of storage areas for irradiated targets, and

27 • refurbishment of the overhead crane and freight elevator.

28 Facility modifications and equipment refurbishment activities are anticipated to be completed 

29 within 2 months and will require up to 6 temporary construction workers (NWMI 2015c). No 

30 excavation or ground-disturbing activities are anticipated to occur in connection with facility 

31 modifications and equipment refurbishment activities (NWMI 2015c). Additional traffic and 

32 vehicle-related emissions will be minimal in connection with the construction workers and single 

33 delivery of transfer cask and storage racks (NWMI 2015c). No additional water use to complete 

34 modifications is anticipated (NWMI 2015c).

35 The NRC staff does not expect any impacts to ecological resources given that modification 

36 activities would be internal and limited to the existing MURR facility. The NRC staff has 

37 identified no foreseeable land and visual impacts, given that modifications would not change

38 any land use on or off site and external changes to the MURR facility would not occur. The 

39 NRC staff has identified no foreseeable air quality and offsite noise impacts given that additional 

40 air and noise emissions from the additional 6 worker vehicles and single deliveries would be 

41 minimal and additional noise levels from facility modification activities would be contained inside 

42 the MURR building. No impacts to water resources are expected, because there would be no 

43 changes in water use from facility modifications and refurbishment. There would be no 

44 socioeconomic, environmental justice, or cultural impacts associated with facility modifications 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 given the short duration of facility modifications (2 months), minimal additional workers needed, 

2 and modifications would be internal and limited to the existing MURR facility. In addition, facility 

3 modification and refurbishment activities will not change the types or quantities of effluents that 

4 may be released, nor are these activities expected to result in a significant increase in individual 

5 or cumulative public or occupational radiation exposure (NWMI 2016c).

6 4.13.1.2 Irradiation Services

7 Irradiation services provided by MURR will result in an additional 26 deliveries per year to 

8 MURR and 104 offsite shipments per year to the proposed NWMI facility, target handling of up 

9 to 624 LEU unirradiated targets, and irradiation of up to 624 LEU targets at MURR 

10 (NWMI 2015a, 2016a, 2016b). Irradiation services at MURR will not change land use, will not 

11 require additional employees, and no additional water use will be required to support operation 

12 activities (NWMI 2015c). Additionally, no anticipated changes in the sources, types, and 

13 quantities of nonradiological effluent releases and waste streams are expected from irradiation 

14 of LEU targets (NWMI 2015c). Therefore, the NRC staff does not expect impacts to ecological 

15 resources, land use, visual, geological resources, water resources, historic or cultural 

16 resources, or socioeconomics from LEU target handling and irradiation at MURR. The potential 

17 impacts from additional deliveries, target handling, and target irradiation to air quality and noise, 

18 human health, and transportation environments are discussed below.

19 Air Quality and Noise

20 Deliveries and offsite shipments associated with MURR irradiation services will result in air 

21 criteria pollutant and GHG emissions as a result of vehicle exhaust. Target deliveries and 

22 shipments will result in an additional 130 vehicles per year and an additional annual 780 mi 

23 (1,255 km) (each vehicle would travel 6 mi (10 km), which is the distance between MURR and 

24 the proposed NWMI facility). The NRC staff estimates that an addition 780 mi (1,255 km) will 

25 emit less than 1 ton of criteria pollutants and GHGs. No additional workforce vehicle emissions 

26 would result from irradiation services; therefore, workforce vehicle emissions are anticipated to 

27 remain the same. Boone County is designated an attainment/unclassifiable area with respect to 

28 all NAAQS. The additional emissions associated with vehicle deliveries and shipments would 

29 be less than 1 ton of criteria pollutants and GHGs and the NRC staff does not anticipate that 

30 these additional emissions would deteriorate air quality in Boone County. Therefore, the NRC 

31 staff concludes that air quality impacts from irradiation services at MURR are SMALL.

32 Additional noise associated from irradiation services at MURR will result from additional vehicle 

33 shipments and deliveries along the main roads, North Providence Road and Stadium Road, 

34 which provide access to MURR. Sound levels would increase at a rate of 3 dBA per doubling of 

35 traffic volumes. An increase in noise levels from an additional 130 vehicles per year as a result 

36 of LEU target deliveries and offsite shipments along the access roads to MURR will not be 

37 noticeable (see discussion below). Furthermore, noise from the additional vehicles will be 

38 intermittent and for short periods of time. Therefore, the NRC staff concludes that offsite noise 

39 impacts from irradiation services at MURR would be SMALL.

40 Human Health 

41 Activities performed at MURR in conjunction with providing irradiation services would include:

42 • handling of unirradiated LEU targets;

43 • operating the reactor to irradiate targets; and

44 • handling, packaging, and shipping of irradiated LEU targets (NWMI 2015a).
Environmental Impacts of Construction, Operations, and Decommissioning

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1 These activities could result in additional radiation dose to occupational workers and/or 

2 members of the public. MURR has extensive experience in handling irradiated reactor fuel, 

3 fueled experiments, and other materials that have high direct dose rates. For example, MURR 

4 staff perform a minimum of 16 fuel-handling evolutions for each week of operation. All high 

5 direct dose rate materials are handled using shielding, radiation safety procedures, and other 

6 measures to keep doses to MURR staff ALARA. Because these measures are used, the 

7 additional occupational dose associated with handling irradiated LEU targets is anticipated to be 

8 minimal relative to historical occupational doses received at MURR (see Section 3.10.1). Since 

9 unirradiated LEU targets or fuel produce only very low levels of radiation, the additional 

10 occupational dose from handling unirradiated LEU targets would also be very small. 

11 Additionally, given the similarity of the proposed activities to the fuel-handling evolutions 

12 currently performed at MURR, a measureable increase in the direct dose to the public (which is 

13 currently very low as discussed in Section 3.10.1) is unlikely to occur (NWMI 2015a).

14 No radiological gaseous emissions are expected from the targets, although gaseous releases 

15 from the operation of the reactor can change based on how often and at what power level the 

16 reactor is operated. At MURR, no change in radiological gaseous effluents would be expected 

17 because the operating tempo of the reactor would not change (NWMI 2015c). Therefore, there 

18 would be no increase in radiation doses to the public from gaseous effluents. Additionally, no 

19 changes in the sources, types, or quantities of nonradiological gaseous effluents are anticipated 

20 at MURR, and no changes in any radiological or nonradiological liquid waste streams are 

21 expected (NWMI 2015c).

22 The University of Missouri Department of Environmental Health and Safety requires MURR to 

23 implement health and safety policies and procedures that require the identification of industrial 

24 hazards before performance of jobs (NWMI 2015c). Procedures for ensuring occupational 

25 health and safety at MURR are not expected to change. In addition, MURR maintains an 

26 emergency response plan for handling any emergencies or accidents at the facility 

27 (NWMI 2015c). The regulations at 10 CFR 50.54(q) require that any changes to this emergency 

28 plan that could reduce its effectiveness must be approved by the NRC.

29 No significant change in radiation doses to the public, and only a minimal increase in 

30 occupational radiation doses to MURR staff, is expected to occur as a result of the irradiation

31 services that would be performed at MURR. In addition, no changes in nonradiological 

32 (chemical or occupational) hazards to MURR staff or members of the public are anticipated. 

33 Therefore, the NRC staff concludes that human health impacts from irradiation services 

34 provided by MURR would be SMALL.

35 NWMI stated that the nonradiological waste streams at MURR are not expected to increase as 

36 a result of the irradiation services provided by MURR. In addition, NWMI stated that the liquid 

37 radioactive waste stream is not expected to increase (NWMI 2015c). The NRC staff expects 

38 that the types of irradiation services performed at MURR would not cause any significant 

39 additional nonradiological waste, or liquid radioactive waste, to be generated because these 

40 types of services do not generate these wastes. The solid low-level radioactive waste stream at 

41 MURR is expected to increase by 4 to 6 cubic feet annually; however, this volume of waste 

42 would be small (about 1 percent increase by volume) relative to the amount of low-level 

43 radioactive waste currently generated at MURR (see Section 3.10.1), and all of this additional 

44 waste would be expected to be Class A, the lowest (least radioactive) level of radioactive waste 

45 (NWMI 2015a, 2016c). Because only minimal additional radioactive or nonradioactive waste 

46 would be produced, the NRC staff concludes that waste management impacts from irradiation 

47 services provided by MURR would be SMALL.
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1 Transportation

2 Major roads in the vicinity of MURR include South Providence Road to the east of MURR and 

3 E. Stadium Boulevard to the north of MURR. Access to MURR is by South Providence Road. 

4 MURR is approximately 2.5 miles (5.6 km) south of U.S. Interstate 70. Irradiation services 

5 provided by MURR will add an estimated 130 vehicles per year as a result of LEU target 

6 deliveries and shipments. The addition of 130 truck deliveries and shipments per year (less 

7 than one per day) would result in little if any noticeable traffic volume-related level of service 

8 impacts in the vicinity of MURR. Therefore, traffic volume-related transportation impacts from 

9 irradiation services provided by MURR would be SMALL.

10 4.13.2 Oregon State University TRIGA Reactor Site

11 4.13.2.1 Facility Modifications and Equipment Refurbishment

12 Facility modifications and equipment refurbishment at OSTR are anticipated to be conducted 

13 prior to supporting the handling and irradiation of LEU targets. Facility modifications and 

14 equipment refurbishment will be completed inside the existing OSTR building and will consist of 

15 (NWMI 2015a, 2015c):

16 • refurbishment or replacement of overhead crane,

17 • fabrication of a target transfer cask, and

18 • installation of target storage containers.

19 Facility modifications and equipment refurbishment activities are anticipated to be completed 

20 within 2 months and they will require up to two temporary construction workers (NWMI 2015c). 

21 No excavation or ground-disturbing activities are anticipated to occur in connection with facility 

22 modifications and equipment refurbishment activities (NWMI 2015c). Additional traffic and 

23 vehicle-related emissions will be minimal in connection with two construction workers and a 

24 single delivery of transfer cask and storage racks. No additional water use to complete 

25 modifications is anticipated (NWMI 2015c).

26 The NRC staff does not expect any impacts to ecological resources, given that modification 

27 activities would be internal and limited to the existing OSTR building. The NRC staff has 

28 identified no foreseeable land and visual impacts because modifications would not change any 

29 land use on or off site and external changes to the OSTR building would not occur. The NRC 

30 staff has identified no foreseeable air quality or offsite noise impacts, given that additional air 

31 and noise emissions from an additional 2 worker vehicles and single deliveries would be 

32 minimal and additional noise levels from facility modification activities will be contained inside 

33 the OSTR building. No impacts to water resources are expected because there would be no 

34 changes in water use from facility modifications and refurbishment. There would be no 

35 socioeconomic, environmental justice, or cultural impacts associated with facility modifications, 

36 given the short duration of facility modifications (2 months), minimal additional workers needed, 

37 and modifications would be internal and limited to the existing OSTR facility. In addition, facility 

38 modification and refurbishment activities will not change the types or quantities of effluents that 

39 may be released, nor are these activities expected to result in a significant increase in individual 

40 or cumulative public or occupational radiation exposure (NWMI 2016c).

41 4.13.2.2 Irradiation Services

42 Irradiation services provided by OSTR will result in an increase in workload (NWMI 2015c). For 

43 the weeks that OSTR provides irradiation services (8 weeks out of the year), facility operations 

44 are anticipated to increase from a 40-hour work week irradiation schedule to a 24 hour per day, 

45 7 day per week schedule. This will also require an additional 10 staff to support the increase in 
Environmental Impacts of Construction, Operations, and Decommissioning

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1 operations for irradiation services; the additional employees are anticipated to be drawn from 

2 the existing university population (NWMI 2015c). Irradiation services will add the following 

3 activities at OSTR: 8 deliveries per year to OSTR; 16 offsite shipments per year to the 

4 proposed NWMI facility; handling of up to 240 LEU unirradiated targets; and, irradiation of up to 

5 240 LEU (NWMI 2015a, 2015c, 2016b). Irradiation services at OSTR will not change land use 

6 and no additional water use will be required to support operation activities (NWMI 2015c). 

7 Additionally, no anticipated changes in the sources, types, and quantities of nonradiological 

8 effluent releases and waste streams are expected from irradiation of LEU targets 

9 (NWMI 2015c). Therefore, the NRC staff does not expect impacts to ecological resources, land 

10 use, visual, geological resources, water resources, historic or cultural resources from LEU target 

11 handling and irradiation at the OSTR. Further, the 10 additional employees drawn from the 

12 university population would not have an appreciable impact on socioeconomic conditions; 

13 therefore, no socioeconomic impacts would be expected as a result of irradiation services 

14 provided by OSTR. The potential impacts from additional deliveries, additional workforce, LEU 

15 target handling, and LEU target irradiation to air quality and noise, human health, and 

16 transportation are discussed below.

17 Air Quality and Noise

18 Vehicles would be the source of air emissions from irradiation services provided by OSTR. 

19 Target deliveries and shipments will result in an additional 24 vehicles per year, and the 

20 additional staff will result in 10 additional vehicles daily for up to 8 weeks. The additional staff is 

21 anticipated to be drawn from the existing university population; therefore, it is reasonable to 

22 assume that the workforce will commute up to 100 mi/day (161 km/day) and, therefore, an 

23 additional total 56,000 mi/year (90,160 km/year). Applying passenger vehicle exhaust emission 

24 factors (EPA 2008), the NRC staff estimates that worker vehicle emissions will emit less than 

25 1 TPY of each criteria air pollutant and 22 TPY of GHGs. The offsite shipments and deliveries 

26 will be sent to and from the proposed NWMI facility in Columbia, Missouri (approximately 

27 2,000 mi (3,218 km)). Applying truck exhaust emission factors (EPA 2008), the NRC staff 

28 estimates that delivery and shipment vehicle emissions will emit less than 1 TPY of each criteria 

29 air pollutant and 28 TPY of GHGs. Emissions from vehicle sources to support irradiation 

30 services are not significant. Benton County, where OSTR is located, is designated in 

31 attainment/unclassifiable area for all NAAQS. Given the estimated emissions from vehicle 

32 exhaust, the NRC staff does not anticipate that these additional emissions would deteriorate air 

33 quality in Benton County. Therefore, the NRC staff concludes that air quality impacts from 

34 irradiation services at the OSTR would be SMALL.

35 Sources of noise from irradiation services provided by OSTR will be from the additional 

36 workforce and delivery/shipment vehicles along the main roads that provide access to OSTR. 

37 Additional workforce travel will be temporary (8 weeks out of the year) and will consist of 

38 10 vehicles. Sound levels increase at a rate of 3 dBA per doubling of traffic volumes. An 

39 increase in noise levels from an additional 10 worker vehicles per year and 

40 24 delivery/shipments per year along the access roads to OSTR relative to current traffic levels 

41 (see discussion below) near the roads in the vicinity of OSTR are not anticipated to be 

42 noticeable. Further, noise from the additional worker vehicles and delivery/shipment vehicles 

43 will be intermittent and for short periods of time. Therefore, the NRC staff concludes that offsite 

44 noise impacts from irradiation services at the OSTR would be SMALL.

45 Human Health

46 Activities performed at OSTR in conjunction with providing irradiation services would include:

47 • handling of unirradiated LEU targets;
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1 • operating the reactor to irradiate targets; and

2 • handling, packaging, and shipping of irradiated LEU targets (NWMI 2015a).

3 These activities could result in additional radiation dose to occupational workers and/or 

4 members of the public. OSTR has experience in handling irradiated reactor fuel, specifically 

5 TRIGA fuel, which also has high direct dose rates. All high direct dose rate materials are 

6 handled using shielding, radiation safety procedures, and other measures to keep doses to 

7 OSTR staff ALARA. Historically, occupational doses at OSTR have not significantly increased 

8 due to increased handling or movement of irradiated TRIGA elements. Although irradiated LEU 

9 targets at OSTR are expected to have an associated dose rate approximately three times that of 

10 irradiated TRIGA fuel elements handled previously, the dose rate to personnel would be 

11 reduced by the use of an irradiated LEU target transfer cask with better radiation shielding than 

12 the cask routinely used for moving the TRIGA elements. Therefore, routine handling of 

13 irradiated LEU targets at OSTR is not expected to significantly increase occupational doses. 

14 Since unirradiated LEU targets or fuel produce only very low levels of radiation, the additional 

15 occupational dose from handling unirradiated LEU targets would also be very small. 

16 Additionally, given the similarity of the proposed activities to the fuel-handling activities 

17 previously performed at OSTR, a measureable increase in the direct dose to the public (which is 

18 currently very low as discussed in Section 3.10.2) is unlikely to occur (NWMI 2015a).

19 No radiological gaseous emissions are expected from the targets themselves, although gaseous 

20 releases from the operation of the reactor can change based on how often and at what power 

21 level it is operated. At OSTR, the average annualized concentration of gaseous radioactive 

22 effluents, particularly Ar-41, would increase because of the reactor’s increased operating tempo. 

23 Conservatively, the average annualized concentration of Ar-41 released at OSTR could 

24 increase by a factor of 4.8 if OSTR switched to 24 hours per day, 7 days per week, and 

25 365 days per year operation (NWMI 2015c). As discussed in Section 3.10.2, OSTR’s current 

typical average annualized effluent concentration of Ar-41 is 1.4x10 26 -7 microcuries per milliliter, 

compared to a TS limit of 4x10 27 -6 microcuries per milliliter. If OSTR’s current average annualized 

28 effluent concentration increased by a factor of 4.8, it would still be well below the TS limit, 

29 ensuring that radioactive effluents from OSTR would continue to not cause the public dose limit 

30 in 10 CFR 20.1301 and the 10 mrem dose constraint in 10 CFR 20.1101(d) to be exceeded.

31 No changes in the sources, types, or quantities of nonradiological gaseous effluents are

32 anticipated at OSTR, and no changes in any radiological or nonradiological liquid waste streams 

33 are expected (NWMI 2015c).

34 Oregon State University Enterprise Risk Services requires individuals working at OSTR to 

35 implement health and safety policies and procedures that require the identification of industrial 

36 hazards prior to the performance of jobs (NWMI 2015c). Procedures for ensuring occupational 

37 health and safety at OSTR are not expected to change. In addition, OSTR maintains an 

38 emergency response plan for handling any emergencies or accidents at the facility 

39 (NWMI 2015c). The regulations at 10 CFR 50.54(q) require that any changes to this emergency 

40 plan that could reduce its effectiveness must be approved by the NRC.

41 Only minimal increases in radiation doses to OSTR staff and members of the public are 

42 expected to occur as a result of the irradiation services that would be performed at OSTR, and 

43 these doses are expected to remain in compliance with regulatory limits. In addition, no 

44 changes in nonradiological (chemical or occupational) hazards to OSTR staff or members of the 

45 public are anticipated. Therefore, the NRC staff concludes that human health impacts from 

46 irradiation services provided by OSTR would be SMALL.
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1 NWMI stated that the nonradiological waste streams at OSTR are not expected to increase as a 

2 result of the irradiation services provided by OSTR. In addition, NWMI stated that the liquid 

3 radioactive waste stream is not expected to increase (NWMI 2015c). The NRC staff expects 

4 that the types of irradiation services performed at OSTR would not cause any significant 

5 additional nonradiological waste, or liquid radioactive waste, to be generated because these 

6 types of services do not generate these wastes. The solid low-level radioactive waste stream at 

7 OSTR is expected to increase by 4 to 6 cubic feet annually; however, this volume of waste 

8 would be small (about a 15 to 25 percent increase by volume) relative to the amount of low-level 

9 radioactive waste currently generated at OSTR (see Section 3.10.2). Further, all this additional 

10 waste would be expected to be Class A, the lowest (least radioactive) level of radioactive waste 

11 (NWMI 2015c, NRC 2016c). Because only minimal additional radioactive or nonradioactive 

12 waste would be produced, the NRC staff concludes that waste management impacts from 

13 irradiation services provided by OSTR would be SMALL.

14 Transportation

15 Given an additional 10 workers commuting daily to the OSTR during 8 weeks of facility 

16 operations and 24 truck deliveries and shipments per year during irradiation services, there 

17 would be little if any noticeable traffic volume-related level of service impacts in the vicinity of 

18 OSTR. Therefore, traffic volume-related transportation impacts from irradiation services 

19 provided by OSTR would be SMALL.

20 4.13.3 Third Research Reactor

21 4.13.3.1 Facility Modifications and Equipment Refurbishment

22 Facility modifications and equipment refurbishment at a yet to be identified third research 

23 reactor are anticipated to be conducted before the handling and irradiation of LEU targets. 

24 Facility modifications and equipment refurbishment activities will be completed inside the 

25 existing research reactor building and will consist of (NWMI 2015c):

26 • refurbishment of an existing overhead crane,

27 • fabrication of a target transfer cask, and

28 • installation of target storage containers.

29 Facility modifications and equipment refurbishment activities are anticipated to be completed 

30 within 2 months and will require up to 2 temporary construction workers (NWMI 2015c). No 

31 excavation or ground-disturbing activities are anticipated to occur in connection with facility 

32 modifications and equipment refurbishment activities (NWMI 2015c). Additional traffic and 

33 vehicle-related emissions will be minimal in connection with two construction workers and single 

34 delivery of the transfer cask, storage racks, and equipment for crane refurbishment. No 

35 additional water use to complete modifications is anticipated (NWMI 2015c).

36 The NRC staff does not expect any impacts to ecological resources given that modification 

37 activities would be internal and limited to the existing research reactor building. The NRC staff 

38 has identified no foreseeable land and visual impacts because the modifications would not 

39 change any land use on or off site and external changes to the research reactor building would 

40 not occur. The NRC staff has identified no foreseeable air quality and offsite noise impacts 

41 because additional air and noise emissions from the additional two worker vehicles and single 

42 deliveries would be minimal and additional noise levels from facility modification activities will be 

43 contained inside the research reactor building. No impacts to water resources are expected, 

44 because there would be no changes in water use from facility modifications and refurbishment. 

45 Similar to the MURR and OSU research reactor, there would likely be no noticeable 
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1 socioeconomic, environmental justice, or cultural resource impacts associated with facility 

2 modifications, given the short duration of facility modifications (2 months), and the few (2)

3 additional workers needed. Modifications would be completed inside buildings and limited to the 

4 existing research reactor facility. In addition, facility modification and refurbishment activities will 

5 not change the types or quantities of effluents that may be released, nor would these activities 

6 be expected to result in a significant increase in individual or cumulative public or occupational 

7 radiation exposure (NWMI 2016c).

8 4.13.3.2 Irradiation Services

9 Irradiation services provided by a third research reactor will result in an increase in workload 

10 (NWMI 2015c). For the weeks that a third research reactor provides irradiation services 

11 (8 weeks out of the year), facility operations are anticipated to increase from a 40-hour work 

12 week irradiation schedule to a 24 hours a day, 7 days a week schedule. This will also require 

13 an additional 10 staff to support the increase in operations for irradiation services, which is 

14 anticipated to be drawn from the university population. Irradiation services will add the following 

15 activities at a third research reactor: 8 deliveries per year to a third research reactor; 16 offsite 

16 shipments per year to the proposed NWMI facility; handling of up to 240 LEU unirradiated 

17 targets; and, irradiation of up to 240 LEU targets (NWMI 2015a, 2015c, 2016b). Irradiation 

18 services at a third research reactor will not change land use and no additional water use will be 

19 required to support operation activities (NWMI 2015c). Additionally, no anticipated changes in 

20 the sources, types, and quantities of nonradiological effluent releases and waste streams are 

21 expected from irradiation of LEU targets (NWMI 2015c). Therefore, the NRC staff does not 

22 expect any impacts to ecological resources, land use, visual, geological resources, water 

23 resources, and historic or cultural resources at the third research reactor from LEU target 

24 handling and irradiation. Further, the 10 additional workers drawn from the existing university 

25 population would have no socioeconomic impact; therefore, LEU target irradiation at an existing 

26 research reactor would result in no socioeconomic impacts. The potential impacts from 

27 additional deliveries, the additional workforce, LEU target handling, and LEU target irradiation to 

28 air quality and noise, human health, socioeconomics, and transportation environments are 

29 discussed below.

30 Air Quality and Noise

31 Vehicles would be the source of air emissions from irradiation services provided by a third

32 research reactor. Target deliveries and shipments will result in an additional 24 vehicles per 

33 year and the additional staff will result in 10 additional vehicles daily for up to 8 weeks. The 

34 additional staff is anticipated to be drawn from the existing university population (NWMI 2015c); 

35 therefore, it is reasonable to assume that the workforce will commute up to 100 mi/day 

36 (161 km/day) and therefore an additional total 56,000 mi/year (91,160 km/day). Applying 

37 passenger vehicle exhaust emission factors (EPA 2008), the NRC staff estimates that worker 

38 vehicle emissions will emit less than 1 TPY of each criteria air pollutant and 22 TPY of GHGs. 

39 The offsite shipments and deliveries will be sent to and from the proposed NWMI facility in 

40 Columbia, Missouri. The distance travelled from offsite shipment and deliveries would be no 

41 greater than the distance travelled between the proposed NWMI facility and OSTR because this 

42 is the greatest distance between the proposed NWMI facility and any operating research 

43 reactor. Therefore, up to 2,000 mi (3,218 km) will be traveled by each delivery or off-shipment, 

44 resulting in a total of less than 1 TPY of each criteria air pollutant and 28 TPY of GHGs. 

45 Emissions from vehicle sources to support irradiation services are not significant. Given the 

46 estimated emissions from vehicle exhaust, the NRC staff does not anticipate that these 

47 additional emissions would deteriorate air quality in the county where a third research reactor is 

48 located. Therefore, the NRC staff concludes that air quality impacts from irradiation services at 

49 a third research reactor would be SMALL.
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1 Sources of noise from irradiation services provided by a third research reactor will be from the 

2 additional workforce and delivery/shipment vehicles along the main roads that provide access to 

3 a third research reactor. Additional workforce travel will be temporary (8 weeks out of the year) 

4 and will consist of 10 vehicles. The 24 additional delivery/shipment vehicles a year will not 

5 occur at the same time. An increase in noise levels from an additional 10 worker vehicles per 

6 year and 24 delivery/shipments per year along the access roads to a third research reactor are 

7 not anticipated to be noticeable because they will be intermittent, for short periods of time, and 

8 the increase in additional vehicles is not significant. Therefore, the NRC staff concludes that 

9 offsite noise impacts from irradiation services at a third research reactor would be SMALL.

10 Human Health

11 Activities performed at a third research reactor in conjunction with providing irradiation services 

12 would include:

13 • handling of unirradiated LEU targets;

14 • operating the reactor to irradiate targets; and

15 • handling, packaging, and shipping of irradiated LEU targets (NWMI 2015a, 2015c).

16 These activities could result in additional radiation dose to occupational workers and/or 

17 members of the public. A third research reactor would use shielding, radiation safety 

18 procedures, and other measures to keep doses to staff ALARA. While some increase in 

19 occupational dose would be observed, the dose increase would not be significant because of 

20 the established radiation protection measures and radioactive material handling experience at a 

21 third research reactor (NWMI 2015c). Additionally, similarly to MURR and OSTR, a 

22 measureable increase in the direct dose to the public is unlikely to occur, because the current 

23 direct offsite dose at a third research reactor is presumably very low, and new activities 

24 performed at a third research reactor would be similar to fuel handling activities currently 

25 performed at that reactor (NWMI 2016c).

26 No radiological gaseous emissions would be expected from the LEU targets, although gaseous 

27 releases from the operation of the reactor could change based on how often and at what power 

28 level the reactor is operated. At a third research reactor, the average annualized concentration 

29 of gaseous radioactive effluents, particularly Ar-41, would be expected to increase due to the 

30 reactor’s increased operating tempo. However, a third research reactor would have a TS that 

31 would limit any increases in Ar-41 effluents such that the public dose limits in 10 CFR 20.1301 

32 would not be exceeded (NWMI 2015c).

33 No changes in the sources, types, or quantities of nonradiological gaseous effluents are 

34 anticipated at a third research reactor, and no changes in any radiological or nonradiological 

35 liquid waste streams are expected (NWMI 2015c).

36 Similar to MURR and OSTR, a third research reactor would be expected to implement 

37 occupational health and safety policies and procedures that would require compliance with 

38 Federal, State, and local regulations. A third research reactor would also be expected to 

39 maintain an emergency response plan for handling any emergencies or accidents at the facility. 

40 This plan would follow NRC guidance for emergency plans found in NUREG–1537 and the 

41 associated Interim Staff Guidance (NWMI 2015c). The regulations at 10 CFR 50.54(q) would 

42 require that any changes to this emergency plan that could reduce its effectiveness must be 

43 approved by the NRC.

44 Only minimal increases in radiation doses to a third research reactor staff and members of the 

45 public are expected to occur as a result of the irradiation services that would be performed at a 

46 third research reactor, and these doses are expected to remain in compliance with regulatory 
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1 limits. Additionally, no changes in nonradiological (chemical or occupational) hazards to staff at 

2 a third research reactor or members of the public are anticipated. Therefore, the NRC staff 

3 concludes that human health impacts from irradiation services provided by a third research 

4 reactor would be SMALL.

5 NWMI stated that the nonradiological waste streams at a third research reactor would not be 

6 expected to change as a result of the irradiation services provided by a third research reactor. 

7 In addition, NWMI stated that the liquid radioactive waste stream is not expected to change 

8 (NWMI 2015c). The NRC staff expects that the types of irradiation services performed at a third 

9 research reactor would not cause any significant additional nonradiological waste, or liquid 

10 radioactive waste, to be generated because these types of services do not generate these 

11 wastes. The solid low-level radioactive waste stream at a third research reactor would be 

12 expected to increase by 4 to 6 cubic feet annually; however, this volume of waste is small 

13 relative to the amount of low-level radioactive waste currently generated at other research and 

14 test reactors such as OSTR (see Section 3.10.2), and all of this additional waste would be 

15 expected to be Class A, the lowest (least radioactive) level of radioactive waste (NWMI 2015a, 

16 2016c). Since only minimal additional radioactive or nonradioactive waste would be produced, 

17 the NRC staff concludes that waste management impacts from irradiation services provided by 

18 a third research reactor would be SMALL.

19 Transportation

20 Given an additional 10 workers commuting daily to a third research reactor during 8 weeks of 

21 target irradiation and 24 truck deliveries and shipments per year during irradiation services, 

22 there would be little if any noticeable traffic volume-related level of service impacts in the vicinity 

23 of a third research reactor. Therefore, traffic volume-related transportation impacts from 

24 irradiation services provided by a third research reactor would be SMALL.

25 4.14 Cumulative Impacts

26 The NRC staff considered potential cumulative impacts in the environmental analysis of the 

27 construction, operations, and decommissioning of the proposed NWMI facility. Cumulative 

28 impacts may result when the environmental effects associated with the proposed action are 

29 overlaid or added to temporary or permanent effects associated with other past, present, and 

30 reasonably foreseeable actions. Cumulative impacts can result from individually minor, but 

31 collectively significant, actions taking place over a period of time. An impact that may be 

32 SMALL by itself could result in a MODERATE or LARGE cumulative impact when considered in 

33 combination with the impacts of other actions on the affected resource. Likewise, if a resource 

34 is regionally declining or imperiled, even a SMALL individual impact could be important if it 

35 contributes to, or accelerates, the overall resource decline.

36 For the purposes of this cumulative impacts analysis, past actions are those before the receipt 

37 of the NWMI construction permit application. Present actions are those related to the resources 

38 at the time of construction of the NWMI facility, and future actions are those that are reasonably 

39 foreseeable through the end of operation and decommissioning. The geographic area over 

40 which past, present, and reasonably foreseeable actions would occur depends on the type of 

41 action considered and is described below for each resource area.

42 To evaluate cumulative impacts, the incremental impacts of the proposed action, as described 

43 in Sections 4.1 to 4.12, are combined with other past, present, and reasonably foreseeable 

44 future actions regardless of what agency (Federal or non-Federal) or person undertakes such 

45 actions. The NRC staff used the information provided in the ER; responses to RAIs; information 

46 from other Federal, State, and local agencies; scoping comments; and information gathered 
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1 during the visits to the potential NWMI facility site to identify other past, present, and reasonably 

2 foreseeable actions.

3 Table 4–11 identifies recent past, present, and reasonably foreseeable future actions within the 

4 geographic extent of analysis. To be considered in the cumulative impacts analysis, the NRC 

5 staff determined whether the project would occur within the noted geographic areas of interest 

6 and within the noted timeframes, whether it was reasonably foreseeable, and whether there 

7 would be potential overlapping effects with the proposed project. For past actions, 

8 consideration within the cumulative impacts assessment is resource- and project-specific. In 

9 general, the effects of past actions are included in the description of the affected environment in 

10 Chapter 3, which serves as the baseline for the cumulative impacts analysis. However, past 

11 actions that continue to have an overlapping effect on a resource potentially affected by the 

12 proposed action are considered in the cumulative impacts analysis.

13 Further, the NRC staff considers the potential cumulative, or overlapping, impacts from climate 

14 change on environmental resources that could be impacted by the proposed NWMI facility. 

15 Changes in climate have broad implications on water resources, land use and development, 

16 and ecosystems. In accordance with 10 CFR Part 51 Appendix A, the level of detail provided 

17 within the cumulative discussions below will be commensurate with the potential for adverse or 

18 significant impacts to a specific resource area. However, climate change impacts on

19 construction and operation of the proposed NWMI facility, are considered outside the scope of 

20 the EIS; this EIS documents the potential impacts from construction, operations, and 

21 decommissioning of the proposed NWMI facility on the environment. External events and 

22 extreme weather event impacts on the proposed NWMI facility will be assessed in the NRC 

23 staff’s SER.

24 Table 4–11. Past, Present, and Reasonably Foreseeable Projects and 

25 Other Actions Retained for the Cumulative Impacts Analysis – Discovery Ridge

Project Name Summary of Project Location Status

Nuclear Projects

Callaway Plant Nuclear power plant, 

one 1,236 MWe 

Westinghouse 4-loop 

pressurized water 

reactor 

28 mi (46 km) 

southeast of site

Operational 

(NRC 2015j)

University of 

Missouri Research 

Reactor

Research reactor, one 

10 MWt open pool 

pressurized water 

reactor

4 miles (6.6 km) 

northwest of site

Operational (MU 2016f)
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Project Name Summary of Project Location Status

Research and Manufacturing Facilities 

Discovery Ridge 

Research Park

Research Park being 

developed on 

University of Missouri 

lands with potential 

expansion to 550 ac 

(220 ha)

Proposed site 

would be within 

research park

Research park currently has two 

tenants (ABC Laboratories and 

IDEXX BioResearch) occupying two 

of 14 lots comprising Phase I 

(139 ac (56 ha)) of the park’s 

development. Proposed NWMI 

facility would occupy one of four lots 

comprising Phase II (additional 

55 ac (22 ha)). Potential total future 

build out of 550 ac (220 ha). No 

other proposed tenants identified at 

this time. (MU 2009, 2016g)

ABC Laboratories Analytical biochemical 

testing serves

0.3 mi (0.5 km) 

west of site

Operational (ABC 2016)

IDEXX 

BioResearch

Animal bioresearch 

health monitoring and 

diagnostic testing 

laboratory

0.1 mi (0.16 km) 

northwest of site

Operational (IDEXX 2015; 

MU 2016g)

Boone Quarries Crushed Limestone 

Quarry 

8 mi (12.9 km) 

northwest of site

Operational (Con-Ag undated)

Fossil Fuel Projects 

University of 

Missouri Combined 

Heat and Power 

Plant

Conventional Steam 

Coal (50.7 MW); 

Natural Gas-Fired 

Combustion Turbine 

(22.8 MW); Petroleum 

3.5 MW)

4.4 mi (7 km) 

northwest of site

Operational (EIA 2015a)

Columbia Municipal 

Power Plant

Natural Gas-Fired 

Combustion Turbine 

(47.5 MW); 

Conventional Steam 

Coal (38.5 MW); 

Petroleum (12.6 MW); 

Landfill Gas (3 MW)

5 mi (8km) 

north-northwest of 

site

Operational (EIA 2015b)

Columbia Energy 

Center

Natural Gas-Fired 

Combustion Turbine 

(140 MW)

8.2 mi (13.2 km) 

north of site

Operational (EIA 2015c)

Transportation Projects 

Discovery Parkway Proposed construction 

of major collector from 

Gans Road to New 

Haven Road

Adjacent to 

northwestern 

portion of site at 

nearest location

Initial segment to completed 

intersection with Discovery Drive. 

Construction planned through 

FY 2017 (CATSO 2014)
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Project Name Summary of Project Location Status

Gans Road Proposed new 

extension, level of 

service upgrades, and 

interchange 

improvements to Gans 

Road between U.S. 63 

Interchange and 

Providence Road 

0.4 mi (0.6 km) 

south of site at 

nearest location

Construction proposed to continue 

through 2023 (CATSO 2014; 

NWMI 2015a) 

Columbia Regional 

Airport

Public airport 6.4 mi (10 km) 

southeast of site

Operational. Proposed runway 

expansion and improvements under 

consideration (CRA 2012)

Medical Facilities

University Hospital Hospital that performs 

radiological procedures

4 mi (6.5 km) 

northwest of site

Operational (MU 2016h)

Boone Hospital 

Center 

Hospital that performs 

radiological procedures

4 mi (6.5 km) 

north-northwest of 

site

Operational (Boone County 2016c)

Parks/Recreation Sites

Nifong Park 58 ac (23 ha) park 

offering picnicking, 

fishing, and hiking. 

Other amenities 

include Walters-Boone 

County Historical 

Museum, historic 

Maplewood home and 

grounds, and Boone 

Junction Historical 

Village

1 mi (1.6 km) west 

of site

Operational. Minor park 

improvements planned though 

2017. Managed by the City of 

Columbia (City of Columbia 2016f; 

NWMI 2015a)

A. Perry Phillips 

Park

140 ac (57 ha) park 

offering picnicking, 

fishing, boating, and 

hiking. 

0.7 mi (1.1 km) 

west of site

Operational. Park dedicated in 

2011 and being developed over 

several years in conjunction with 

adjacent Gans Creek Recreational 

Area. Planned improvements 

through 2018 include an ice skating 

center and an indoor sports center. 

Managed by the City of Columbia

(City of Columbia 2016g; 

NWMI 2015a)

Gans Creek 

Recreational Area

320 ac (130 ha) park 

offering five 

multipurpose athletic 

fields

0.8 mi (1.3 km) 

southwest of site

Operational. Two additional athletic 

fields under construction, with 

planned future construction of 

playground, restroom, and 

concession facilities. Managed by 

the City of Columbia (City of 

Columbia 2016h)
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Project Name Summary of Project Location Status

Rock Bridge State 

Park

2,273 ac (920 ha) park 

containing unique 

geological features and 

offering picnicking, 

hiking, cycling, and 

horseback riding.

1.8 mi (2.9 km) 

southwest of site

Operational. Managed by Missouri 

Department of Natural Resources

(MDNR undated; USA Parks 2015)

Other Recreational 

Areas

Various parks, 

campgrounds, and 

natural areas

Within 10 mi 

(16 km)

Operational

Other Projects/Actions

Discovery Park 105 ac (42 ha) 

residential and 

commercial 

development center

0.4 mi (0.6 km) 

southwest of site

Under construction.

(Columbia Daily Tribune 2015b)

Ed’s Mobile Home 

Park/Sunset Mobile 

Home Park

Residential 

Development

0.6 mi (1 km) 

northwest of site

Shut down October 1, 2015.

(The Columbian Missourian 2015)

Old Hawthorne Golf 

Club

Private country club 

and residential 

community

2.5 mi (4 km) 

northeast of site

Operational. Golf course opened in 

2007 and construction of associated 

residential community is ongoing 

(Hawthorne 2016)

KOMU TV Network television 

station

1.1 mi (1.7 km) 

southeast of site

Operational (KOMU 2016)

Other Future 

Development

Construction of 

housing units and 

associated commercial 

buildings; roads, 

bridges, and rail; water 

and/or wastewater

treatment and 

distribution facilities, 

and associated 

pipelines as described 

in local land use 

planning documents.

Throughout region Construction would occur in the 

future as described in State and 

local land use planning documents.

1 Climate Change

2 Climate change is the decades or longer change in climate measurements (e.g., temperature, 

3 precipitation) that has been observed on a global, national, and regional level (EPA 2014; 

4 IPCC 2007a; USGCRP 2014). Climate change can vary regionally, spatially, and seasonally 

5 depending on local, regional, and global factors. Just as the regional climate differs throughout 

6 the world, the impacts of climate change can vary between locations. Climate change research 

7 indicates that the cause of the Earth’s warming over the last 50 years is due to the buildup of 

8 GHGs in the atmosphere resulting from human activities (USGCRP 2014).

9 In the United States, the U.S. Global Change Research Program (USGCRP) reports that, 

10 from 1895 to 2012, average surface temperature has increased from 1.3 °F to 1.9 °F (0.72 C to 

11 1.06 °C), and since 1900, average annual precipitation has increased by 5 percent 
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1 (USGCRP 2014). On a seasonal basis, warming has been the greatest in winter and spring. 

2 From 1895 to 2011, an increase in the length of the freeze-free season, the period between the 

3 last occurrence of 32 °F (0 °C) in the spring and first occurrence of 32 °F (0 °C) in the fall, has 

4 been observed for the contiguous United States; between 1991 and 2011, the average 

5 freeze-free season was 10 days longer than that between 1901 and 1960 (USGCRP 2014). 

6 Since the 1970s, the United States has warmed at a faster rate as the surface temperature rose 

7 at an average rate of 0.17 to 0.25 °C (0.31 to 0.45°F) per decade. Observed climate-related 

8 changes in the United States include increases in the frequency and intensity of heavy 

9 precipitation, earlier onset of spring snowmelt and runoff, rise of sea level in coastal areas of the 

10 United States, increase in occurrence of heat waves, and a decrease in occurrence of cold 

11 waves (EPA 2014; NOAA 2013a; USGCRP 2009, 2014).

12 Temperature data indicate that the Midwest region, where the proposed Discovery Ridge site is 

13 located, experienced a 0.06 °C (0.11 °F) per decade increase in annual mean temperature 

14 during the 1900 to 2010 period (NOAA 2013b). Temperature data for the recent past indicate 

15 an increased rate of warming for the Midwest: 0.12 °C (0.22 °F) per decade for the 1950 to 

16 2010 time period and a 0.26 °C (0.47 °F) temperature increase for the 1979 to 2010 time period. 

17 Average annual precipitation data for the Midwest exhibit an increasing trend of 0.31 in. 

18 (0.79 cm) per decade for the long-term period (1895 to 2011) (NOAA 2013b). Precipitation 

19 data over the 1958 to 2007 period exhibit clear trends toward more very heavy precipitation 

20 events (defined as the heaviest 1 percent of all daily events) for the Nation as a whole and 

21 particularly in the Northeast and Midwest.

22 Future GHG emission concentration and climate models are commonly used to project possible 

23 climate change. Climate models indicate that over the next few decades, temperature 

24 increases will continue due to current GHG concentrations in the atmosphere (USGCRP 2014). 

25 Over the longer term, the magnitude of temperature increases and climate change effects will 

26 depend on both past and future GHG emissions (IPCC 2007a; USGCRP 2009, 2014). For the 

27 2021–2050 time period (relative to 1971–1999), climate model simulations indicate an increase 

28 in annual mean temperature of 2.5 to 3.5 °F (1.4 to 1.9 °C) for the entire Midwest region for both 

29 a low- and high-GHG emission modeled scenario. For mid-century (2041–2070) annual mean 

30 temperatures are projected to increase even greater; climate model simulations indicate an 

31 increase in annual mean temperature of 3.5 to 4.5 °F (1.9 to 2.5 °C) for a low-GHG emission 

32 modeled scenario and an increase in annual mean temperature of 4.5 to 5.5 °F (2.5 to 3.0 °C) 

33 for a high-GHG emission modeled scenario for the Midwest. Further, by mid-century the annual 

34 number of days above 95 °F (35 °C) are projected to increase by up to 25 days for Missouri. In 

35 addition, the length of the average frost-free season (the period between the last occurrence of 

36 32 °F (0 °C) in the spring and first occurrence of 32 °F (0 °C) in the fall is projected to increase 

37 by up to 23 days (USGRP 2014).

38 Climate model simulations indicate spatial differences in annual mean precipitation changes for 

39 the Midwest. For the 2021–2050 time period (relative to 1971–1999), models indicate an 

40 increase of 0 to 3 percent in annual mean precipitation for the northeast region of Missouri,

41 while the southeastern region would experience a decrease of 0 to 3 percent. However, these 

42 changes in precipitation were not significant as the models indicate changes that are less than 

43 normal year-to-year variations and, therefore, less certain than annual mean temperature 

44 changes (NOAA 2013b; USGCR 2014). However, by mid-century increases in the frequency 

45 and intensity of extreme precipitation are projected to increase, while at the same time the 

46 average maximum number of consecutive days with less than 0.01 in of precipitation will 

47 increase (indicative of drought conditions) throughout the entire Midwest region 

48 (USGCRP 2014).
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1 Changes in climate have broad implications for air quality, water resources, land use and 

2 development, and ecosystems. For instance, changes in precipitation patterns and increase in 

3 air temperature can affect water availability and quality, distribution of plant and animal species, 

4 land-use patterns, and land-cover, which can in turn affect terrestrial and aquatic habitats. 

5 Although the future effects of climate change are uncertain, the cumulative impact sections 

6 below discuss how future climate change may affect environmental resource areas that could 

7 be impacted by the proposed NWMI facility. 

8 4.14.1 Land Use and Visual Resources

9 This section addresses the direct and indirect effects of the construction, operations, and 

10 decommissioning of the proposed NWMI facility on land use and visual resources when added 

11 to the aggregate effects of other past, present, and reasonably foreseeable future actions. The 

12 description of the affected environment in Section 3.1 (5-mi (8-km)) radius for land use and the 

13 viewshed for visual resources) serves as baseline conditions for the land use and visual 

14 resources cumulative impact assessment. The incremental impacts from construction, 

15 operations, and decommissioning of the proposed NWMI facility on land use and visual 

16 resources would be SMALL, as described in Section 4.1.

17 4.14.1.1 Land Use

18 The projects and activities described in Table 4–11 would result in minimal changes to existing 

19 land uses because new construction would occur either within or adjacent to existing facilities or 

20 within areas currently certified for industrial or commercial use. For example, most reasonably 

21 foreseeable projects would occur within the Discovery Ridge Research Park. In the most recent 

22 land use plan, the City of Columbia (2013) identifies the Discovery Ridge Research Park as 

23 “shovel ready” for future industrial development. The research park is also one of three sites 

24 that the City of Columbia (2013) designated as an industrial certified site. The future 

25 development goal for the Discovery Ridge Research Park is to increase the number of business 

26 and research facilities on site, especially for entities that would benefit from the close proximity 

27 to the resources available at the University of Missouri (City of Columbia 2013). In addition, one 

28 of the City of Columbia’s (2013) economic goals is to attract new businesses and increase the 

29 number of light industrial and high tech jobs within the Columbia Regional Airport-Discovery 

30 Ridge–U.S. Highway 63 Corridor, which would include the proposed Discovery Ridge site. 

31 Given that Discovery Ridge Research Park is currently certified for industrial use, any new 

32 development within this area would be compatible with current land use plans.

33 Future urbanization and global climate change could contribute to additional decreases in 

34 agricultural lands, forests, grasslands, and wetlands. Urbanization in the vicinity of the 

35 proposed site would alter important attributes of land use.

36 Urbanization would reduce natural vegetation and agricultural fields, resulting in an overall 

37 decline in the extent and connectivity of wetlands, forests, grasslands, and wildlife habitat. 

38 Global climate change could reduce crop yields and livestock productivity (USGCRP 2014), 

39 which may change portions of agricultural land uses. However, existing parks, reserves, and 

40 managed areas would help preserve wetlands and forested areas. In addition, zoning laws and 

41 comprehensive land use plans would help ensure a proper balance of development (City of 

42 Columbia 2013, 2016a).

43 Given that reasonably foreseeable new construction activities would occur within or adjacent to 

44 existing facilities or within areas certified for industrial use, cumulative land use impacts would 

45 be SMALL.
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1 4.14.1.2 Visual Resources

2 The projects and activities described in Table 4–11 would result in minimal changes to the 

3 existing viewshed because most new construction would occur either within or adjacent to 

4 existing facilities or within areas that are currently certified for industrial use. Furthermore, the 

5 viewshed within the vicinity of the proposed site includes agricultural, light industrial, residential, 

6 and forested views. Within nondeveloped areas, where a new structure would change qualities 

7 of the existing landscape, the viewshed directly surrounding the proposed Discovery Ridge site 

8 is generally of low scenic quality because of a lack of notable features, uniform landform, low 

9 vegetation diversity, an absence of water, and mute colors.

10 Given that reasonably foreseeable new construction activities would occur within or adjacent to 

11 existing facilities or within areas certified for industrial use and of low scenic quality, cumulative 

12 visual impacts would be SMALL.

13 4.14.2 Air Quality and Noise

14 This section addresses the direct and indirect effects of the construction, operations, and 

15 decommissioning of the proposed NWMI facility on air quality and noise at the Discovery Ridge 

16 site when added to the aggregate effects of other past, present, and reasonably foreseeable 

17 future actions. The description of the affected environment in Section 3.2 provides baseline 

18 conditions for the assessment of cumulative impacts on air quality and noise. The incremental 

19 impacts from construction, operations, and decommissioning of the proposed NWMI facility on 

20 air quality and noise would be SMALL, as described in Section 4.2.

21 4.14.2.1 Air Quality

22 As described in Section 3.2.2, the ROI considered for the air quality analysis of the proposed 

23 NWMI facility is defined as Boone County. The ROI considered in the cumulative air quality 

24 analysis is also Boone County because air quality designations for criteria air pollutants are 

25 generally made at the county level.

26 Present-day activities in Boone County that could potentially result in cumulative impacts 

27 include seven major sources of air emissions identified on EPA’s Enforcement and Compliance 

28 History Online (ECHO) air data search tool (EPA 2016c). Minor sources of air emissions are 

29 also present in Boone County; however, a minor source classification typically indicates that the 

30 facility has little to no potential for significantly affecting air quality or interfering with plans to 

31 achieve compliance with NAAQS (IEPA 2015). Sources of air pollutants classified as a major 

32 source require a permit that will include provisions on how much and what is allowed to be 

33 emitted, which serves to minimize cumulative impacts on air quality. Table 4–11, provides a list 

34 of current projects and reasonably foreseeable future actions that could contribute to cumulative 

35 impacts to air quality. Air emissions sources that contribute to air quality identified in 

36 Table 4–11 (e.g., fossil fuel projects and manufacturing facilities) that are currently operating 

37 have not contributed to a violation of the NAAQS given Boone County’s designated 

38 attainment/unclassifiable status. These past and current emissions are included in the air 

39 quality baseline for Boone County. Therefore, cumulative impacts to air quality would be the 

40 result of changes to present-day emissions and future actions within Boone County.

41 Development and construction activities, as identified in Table 4–11, associated with regional 

42 growth in housing, business, and industry, as well as associated vehicular traffic, can increase 

43 air emissions. The population of Columbia, Missouri, is projected to increase between 22 and 

44 35 percent by 2030 (relative to 2010), and construction of new housing and associated 

45 infrastructure will be needed to accommodate the increase in population (City of 

46 Columbia 2013). The population in Boone County is projected to increase by 51.6 percent by 
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1 2050 (relative to 2010), see Table 3-11. Annual job growth projection for Columbia is 1.3 to 

2 1.4 percent (City of Columbia 2013). Regional air quality conditions could deteriorate from the 

3 effects of the growth in the County as growth gives rise to dust, exhaust from increased traffic, 

4 and other emissions. While air emissions from construction activities would be temporary and 

5 localized, the resulting regional growth in residential, commercial, and industrial uses across 

6 Boone County can result in overall long-term air emission sources. These new stationary and 

7 mobile (e.g., vehicle) emission sources could further overlap with operation and 

8 decommissioning of the proposed NWMI facility and could noticeably alter air quality conditions 

9 in Boone County. If degradation in air quality is observed, MDNR can develop air quality control 

10 programs to mitigate the effects of development. However, mitigation will depend on the control 

11 strategies implemented and adherence to these strategies.

12 Climate change can affect air quality as a result of changes in meteorological conditions. The 

13 formation, transport, dispersion, and deposition of air pollutants depend, in part, on weather 

14 conditions (IPCC 2007a). Air pollutant concentrations are sensitive to winds, temperature, 

15 humidity, and precipitation (EPA 2009a). Ozone levels have been found to be particularly 

16 sensitive to climate change influences (IPCC 2007a; EPA 2009b). Ozone is formed, in part, as 

17 a result of the chemical reaction of nitrogen oxides and volatile organic compounds (VOCs) in 

18 the presence of heat and sunlight. Nitrogen oxides and VOC sources include both natural 

19 emissions (e.g., biogenic emissions from vegetation or soils) and anthropogenic emissions 

20 (e.g., motor vehicles, power plants). Nitrogen oxide, biogenic VOCs, and ozone concentrations 

21 are expected to be higher in a warmer climate (EPA 2009b). Although surface temperatures are 

22 expected to increase in the Midwest, this may not necessarily result in an increase in ozone 

23 concentrations. The observed correlation between increased ozone concentrations and 

24 temperature has been found to occur in polluted and urban regions (those areas where ozone 

25 concentration are greater than 60 ppb). Additionally, increases in ozone concentrations 

26 correlated with temperature increases occur in combination with cloud-free regions and air 

27 stagnation episodes (Jacob and Winner 2009; IPCC 2013). Furthermore, climate model 

28 simulations do not agree on the ozone response to climate change. For instance, some models 

29 indicate increases in ozone concentrations with climate change for the Midwest 

30 (e.g., Wu et al. 2008), and others (e.g., Tagaris et al. 2007) project decreases in ozone 

31 concentrations with climate change for the Midwest.

32 Overall, the potential cumulative air quality impact associated with the construction, operations, 

33 and decommissioning of the NWMI facility in conjunction with other reasonably foreseeable 

34 projects is considered SMALL to MODERATE, primarily due to future economic and population

35 growth in Boone County that can lead to long-term air emission sources and increases in air 

36 pollutants that can noticeably alter air quality.

37 4.14.2.2 Noise

38 The ROI considered for noise is a 1-mi (1.6-km) radius from the site boundary of the proposed 

39 NWMI facility. Noise levels attenuate rapidly with distance. When distance is doubled from a 

40 point source, noise levels decrease by 6 dBA (FHWA 2011). Generally, a 3-dBA change over 

41 existing noise levels is considered to be a “just noticeable” difference, a 5-dBA increase is 

42 readily perceptible, and a 10-dBA increase is subjectively perceived as a doubling in loudness 

43 (FHWA 2011).

44 Present-day activities within the ROI are identified in Table 4–11 and contribute to current 

45 background noise levels near the Discovery Ridge site. Potential cumulative noise impacts 

46 could occur during the construction, operations, and decommissioning phases in conjunction 

47 with other reasonably foreseeable activities occurring within the noise ROI of the proposed 

48 NWMI facility. Primarily, these would be construction-related activities from transportation 
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1 projects as well as residential and commercial project construction identified in Table 4–11. 

2 Noise levels associated with construction equipment will be temporary and background levels 

3 would return once construction is completed. However, the potential expansion of the 

4 Discovery Ridge Research Park (MU 2009) and new roads adjacent to the proposed NWMI 

5 facility would result in an increase in noise levels from traffic and business growth after 

6 construction activities are complete. Given the potential for expansion at the Discovery Ridge 

7 Research Parkway and additional noise from vehicle traffic from new roads adjacent to the 

8 proposed facility, the NRC staff concludes that background noise levels could increase similar to 

9 that of a thriving commercial area with noise levels reaching 70 dBA, resulting in an increase of 

10 5 dBA from estimated background levels. This increase in noise levels would be noticeable to 

11 noise-sensitive receptors in the vicinity of the Research Park and would overlap with operation 

12 and decommissioning of the proposed NWMI facility. Therefore, the NRC staff concludes that 

13 cumulative noise impacts would be SMALL to MODERATE.

14 4.14.3 Geologic Environment

15 This section addresses the direct and indirect effects of the construction, operations, and 

16 decommissioning of the proposed NWMI facility at the Discovery Ridge site on the geologic 

17 environment when added to the aggregate effects of other past, present, and reasonably 

18 foreseeable future actions. The cumulative impacts on the geologic environment primarily relate 

19 to land disturbance, the potential for soil erosion and loss, and the consumption of geologic 

20 resources. The descriptions of the affected environment in Sections 3.3.1 and 3.3.2 

21 (Site Geology and Soils, respectively) of this EIS serve as the baseline for the geologic 

22 environment cumulative impacts assessment.

23 The ROI for evaluating cumulative impacts on soil resources encompasses the Discovery Ridge 

24 site and further encompassing a 5-mi (8-km) radius of the site. For geologic resources, the 

25 NRC staff further extended the ROI to include all of Boone County to encompass potential 

26 commercial sources of rock and mineral resources to support construction activities at the 

27 proposed site and vicinity. Because the aspects of land disturbance and conversion are 

28 addressed separately in Section 4.14.1.1, the cumulative impacts analysis here will focus on soil 

29 loss, including the loss of any prime farmland soils and other important farmland soils, and the 

30 consumption of geologic resources. The incremental impacts from construction, operations, 

31 and decommissioning of the proposed NWMI facility on the geologic environment, including 

32 geologic and soil resources, would be SMALL, as described in Section 4.3.

33 Soil Resources

34 New construction projects identified in Table 4–11 within the immediate 5-mi (8-km) radius of 

35 the Discovery Ridge site would result in the conversion and loss of soils. There would be no 

36 incremental loss of prime farmland or other important farmland soils because soils at the 

37 Discovery Ridge site do not meet the relevant criteria defined by the Natural Resources 

38 Conservation Service, as referenced in Section 3.3.2 of this EIS. Regardless, in accordance 

39 with local and State permits and approvals, as referenced in Sections 4.3 and 4.4 relative to the 

40 NWMI facility, all development activities in the ROI and beyond would be subject to BMPs for 

41 soil erosion and sediment control, which would serve to minimize soil erosion and loss. 

42 Developers would be likely to reclaim usable topsoil removed by ground-disturbing activities for 

43 use elsewhere within the impacted development sites. Alternatively, developers can stockpile 

44 usable topsoil or backfill and then sell or otherwise transfer it for reuse elsewhere at other 

45 development sites. Following the completion of construction activities, continued soil loss would 

46 be minimal as the remaining soils would lie beneath impervious surfaces such as buildings or 

47 the impacted area would have been revegetated or incorporated into facility landscaping or 

48 hardscaped areas. This would be the case, for example, at the NWMI facility site and at other 
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1 pad sites within the Discovery Ridge Research Park. Although developed land areas could be 

2 reclaimed and sufficiently restored to support certain agricultural and nondeveloped uses at 

3 some point in the future, such lands and associated soils would not be restorable to their 

4 predeveloped state. Cumulative soil loss would largely occur in or adjacent to developed areas 

5 and soil loss would be mitigated by the use of BMPs. Based on these considerations, the NRC 

6 staff concludes that cumulative impacts on soil resources would be SMALL.

7 Geologic Resources

8 New facility construction and expansion (Table 4–11) would require the use and consumption of 

9 geologic resources, including rock and mineral assets such as construction aggregate materials 

10 (e.g., sand and gravel). Construction of the NWMI facility at the Discovery Ridge site would use 

11 many of the same materials, including concrete, gravel, and sand required for the other 

12 identified projects in Table 4–11. For example, construction of the NWMI facility would require 

about 1,700 yd3 (1,300 m3 13 ) of crushed aggregate (limestone) (see Sections 2.2 and 4.3.1). By 

14 comparison, the 11-county rock and mineral district of central Missouri that includes Boone 

15 County produces or uses approximately 5.95 million tons (5.4 million metric tons) of crushed 

stone annually. This is equivalent to 4.5 million yd3 (3.4 million m3 16 ) of material (USGS 2015c).

17 As noted in Section 3.3.1, rock and mineral products including construction aggregate are 

18 widely available throughout Boone County and the surrounding region. Likewise, products 

19 derived from geologic materials, including concrete and asphaltic materials used in construction, 

20 are widely available on a regional basis. It is not likely that the geologic resource requirements 

21 to construct the NWMI facility or the resource requirements of other identified projects are of 

22 such a volume as to affect local and regional sources and supplies of the identified resources. 

23 In addition, there are no developed geologic assets (mines or quarries) at or near the Discovery 

24 Ridge site that would be rendered inaccessible for future use. Therefore, the NRC staff 

25 concludes that cumulative impacts on geologic resources would be SMALL.

26 4.14.4 Water Resources

27 This section addresses the direct and indirect effects of the construction, operations, and 

28 decommissioning of the proposed NWMI facility at the Discovery Ridge site on water resources 

29 when added to the aggregate effects of other past, present, and reasonably foreseeable future 

30 actions. This cumulative impacts analysis for surface water and groundwater resources 

31 considers such issues as water quality, water use, and potential climate change. It further 

32 considers relevant project actions, activities, and specific implications for surface water or 

33 groundwater withdrawal, effluent discharges, stormwater drainage and runoff, and accidental 

34 spills and releases. The description of the affected environment in Sections 3.4.1 and 3.4.2 

35 (Surface Water Resources and Groundwater Resources, respectively) serves as the baseline 

36 for the water resources cumulative impacts assessment.

37 The ROI for the surface water resources component of the cumulative impacts analysis is 

38 comprised of the Discovery Ridge site and the Bonne Femme Creek watershed downstream of 

39 the site, as described in Section 3.4.1. For groundwater resources, the area of analysis 

40 includes the Discovery Ridge site and the local groundwater basin in which groundwater is 

41 recharged and flows to discharge points within the watershed. The area comprises those 

42 aquifers from which groundwater is withdrawn through wells to supply potable, industrial, 

43 agricultural, and other uses within a 5-mi (8-km) radius of the Discovery Ridge site. Thus, this 

44 analysis focuses on those projects that, when combined with those under the proposed action, 

45 would: (1) withdraw water from or discharge effluents to Gans Creek and other tributaries within 

46 the Bonne Femme Creek watershed downstream of the site, or (2) would use groundwater or 

47 could otherwise affect the same aquifers that would supply water to the Discovery Ridge site. 
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1 For surface water, the ROI further encompasses Perche Creek from its confluence with Hinkson 

2 Creek and including the segment of Perche Creek that receives effluent discharges from the 

3 Columbia Regional WWTP. The Columbia Regional WWTP would receive sanitary effluent 

4 from the proposed NWMI facility. The incremental impacts from construction, operations, and 

5 decommissioning of the proposed NWMI facility on surface water and groundwater resources 

6 would be SMALL, as described in Sections 4.4.1 and 4.4.2, respectively.

7 The proposed NWMI facility site is located within the Discovery Ridge Research Park. Site 

8 drainage flows generally south and southwest toward the southwesterly flowing Gans Creek, 

9 located approximately 0.35 mi (0.56 km) south of the site at is closest point. Gans Creek is 

10 located within the Bonne Femme Creek watershed that contributes drainage to the Missouri 

11 River, as described in Section 3.4.1. The State of Missouri has established water quality 

12 standards for Gans Creek and other tributaries within the Bonne Femme Creek watershed. 

13 Surface water is a minor source of water supply in Boone County. The predominant source of 

14 water for municipal water supply and for individual property owners in Boone County is 

15 groundwater pumped from deep bedrock aquifers, principally the Mississippian and the deeper, 

16 more extensive Cambrian-Ordovician aquifer system, described in Section 3.4.2.

17 4.14.4.1 Surface Water

18 Downstream of the Discovery Ridge site, the surface water hydrology is rather complex as the 

19 watershed is founded on karst terrane. Due to the occurrence of soluble carbonate bedrock, 

20 karst features include the presence of losing (sinking) and gaining sections of streams where 

21 surface water can easily enter the subsurface, providing flow to other streams. These features

22 make surface waters and underlying groundwater particular vulnerable to contamination.

23 Gans Creek and other streams within the Bonne Femme Creek watershed have been 

24 designated by the State for the following beneficial uses: aquatic habitat protection; human 

25 health protection, whole body contact recreation, and secondary contact recreation; as well as 

26 livestock and wildlife protection and irrigation. In addition, the State of Missouri has classified a 

27 3 mi (4.8 km) section of Gans Creek as an Outstanding State Resource Water. Boone County 

28 has also designated this section of stream and adjoining areas as an environmentally sensitive 

29 area and includes karst features such as Devil’s Icebox Cave within Rock Bridge State Park 

30 (see Section 3.4.1.2). 

31 An intensive study of the watershed conducted by Federal, State, and local stakeholder 

32 agencies (Frueh 2007) found water quality parameters to be typical for streams in carbonate 

33 bedrock areas and not seriously degraded from a hydrologic and water quality perspective. 

34 Nevertheless, Gans Creek as well as several of the stream segments within the Bonne Femme 

35 Creek watershed are included in the State’s list of “impaired” waters, pursuant to Section 303(d) 

36 of the Federal Water Pollution Control Act (i.e., Clean Water Act (CWA)) of 1972. The pollutant 

37 of concern is water-borne E. coli bacteria stemming from rural nonpoint source runoff. As 

38 further described in Section 3.4.1.2, the State is required to evaluate pollutant loadings within 

39 such watersheds and implement a watershed-based program to assure future compliance with 

40 water quality standards. On an individual project or facility basis, the State typically addresses 

41 watershed improvement through existing and new NPDES permits. The Federal NPDES permit 

42 program, under CWA Section 402, addresses water pollution by regulating point sources 

43 (i.e., pipes, ditches) that discharge pollutants to waters of the United States. The State of 

44 Missouri has been delegated NPDES permitting authority by EPA. 

45 Within the context of the local watersheds of the Missouri River, such as Bonne Femme Creek, 

46 climate change is an important consideration. Prospects for continued increases in temperature 

47 and changes in precipitation patterns, including longer periods of drought, would be likely to 

48 reduce the overall amount of water available for surface runoff. Over the period 1988 to 2010, a 
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1 decrease in soil moisture has been documented during most seasons in the central Midwest 

2 (USGCRP 2014). As temperatures are projected to continue to increase across the Midwest, 

3 this trend would be expected to continue. Meanwhile, by mid-century, the scientific community 

4 projects increases in the frequency and intensity of extreme precipitation, while at same time the 

5 average maximum number of consecutive days with less than 0.01 in. of precipitation will 

6 increase (indicative of drought conditions) throughout the entire Midwest region 

7 (USGCRP 2014). An increased frequency of extreme rainfall events can cause erosion and 

8 lead to a decline in water quality (USGCRP 2014). This is particularly true where soils are dry 

9 and less able to retain precipitation that falls during heavier precipitation events. The 

10 implications are clear for a sensitive karst watershed, such as the Bonne Femme Creek 

11 watershed, where climatic changes can bring with them increases in runoff laden with nutrients, 

12 sediment, and other contaminants, and associated changes in near-surface groundwater. 

13 Increases in impervious surface due to development can further exacerbate these changes in 

14 water quality.

15 The proposed NWMI facility is part of a larger development, the Discovery Ridge Research Park 

16 (Table 4–11). As described in Sections 3.4.1, 4.4.1 and 4.4.2, the NWMI facility would have no 

17 direct impact on surface water features and no direct discharge of industrial wastewater to 

18 surface water bodies. No surface water would be used for the construction, operations, or 

19 decommissioning of the proposed NWMI facility; therefore, there would be no incremental 

20 contribution to cumulative impacts due to surface water use. Stormwater runoff would occur 

21 from the facility site during construction, operations, and decommissioning. Groundwater 

22 removed from excavations during facility construction may also be discharged from the site. 

23 During operations, NWMI would discharge sanitary wastewater to the City of Columbia sanitary 

24 sewer system. There would be no radioactive liquid effluents released from the facility during 

25 operations, as the RPF portion of the facility is designed to have zero liquid discharge.

26 Projects and activities occurring within the ROI would be subject to applicable local, State, and 

27 Federal regulatory requirements and associated permits and approvals. Accordingly, the 

28 University of Missouri will require that stormwater discharges from all tenants within the 

29 Discovery Ridge Research Park comply with the master stormwater management plan 

30 developed for the park. Construction projects are required to obtain a Land Disturbance Permit 

31 from the City of Columbia and submit related plans for city approval before any 

32 ground-disturbing activities or facility construction could begin on the site (Section 4.3.1). 

33 For projects outside the municipal boundary of the City, Boone County also requires a Land 

34 Disturbance Permit. These plans entail the implementation of construction-related BMPs for soil

35 erosion and sediment control and stormwater pollution prevention during site development, 

36 facility construction, and for post development.

37 The MDNR has developed an NPDES general permit that must be obtained by owners and 

38 operators for the discharge of stormwater and certain non-stormwater discharges

39 (e.g., dewatering) from land-disturbance sites that disturb 1 ac (0.4 ha) or more, or less than 

40 1 ac (0.4) but part of a larger development. This State general permit requires permit holders to 

41 develop and implement an SWPP, the purpose of which is in part to ensure the proper design, 

42 implementation, management, and maintenance of BMPs in order to prevent the introduction of 

43 sediment and other pollutants in stormwater discharges. MDNR also requires certain industrial 

44 facilities to obtain an NPDES permit for stormwater discharges during facility operations.

45 The WWTP serves the whole City of Columbia. During the projected 30-year period of 

46 operations, the only liquid waste discharged from the NWMI facility would be sanitary in nature. 

47 This effluent would be discharged to the City of Columbia sanitary sewer system at an average 

48 rate of approximately 4,570 gpd (17,300 Lpd). This is equivalent to approximately 0.0046 mgd 

(17.4 m3 49 /day). The Columbia Regional WWTP would be the ultimate point of treatment. The 
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Columbia Regional WWTP has a design treatment capacity of 20 mgd (75,700 m3 1 /day) with 

average demand of 16 mgd (60,600 m3 2 /day). NWMI’s additional wastewater volume would 

3 constitute a very small percentage (i.e., 0.12 percent) of the available treatment capacity of the 

4 WWTP. Sanitary wastewater discharges from the NWMI facility would be unlikely to have any 

5 impact on the facility or have any impact on ambient water quality downstream of the WWTP.

6 Nevertheless, the potential exists for substantial population growth in the County and City of 

7 about 40 percent between 2016 and 2050 (Section 3.7.1). The corresponding increase in 

8 sanitary effluent generated by the larger population would approach or exceed the capacity of 

9 the WWTP. This would necessitate that the City invest in additional wastewater treatment 

10 infrastructure. Given the planning timeframe, the NRC staff anticipates that the City of 

11 Columbia would be able to accommodate the increased treatment demand with timely 

12 expansions of treatment infrastructure, as it becomes needed.

13 In summary, construction, operations, and decommissioning of the proposed NWMI facility 

14 would have a minimal incremental contribution to cumulative impacts on surface water 

15 resources, including surface water and groundwater quality. Ongoing and future development 

16 projects within the Bonne Femme Creek watershed would be subject to County and City site 

17 development approvals, including Land Disturbance Permits. NPDES permits required for all 

18 new stormwater and industrial wastewater dischargers would include provisions to comply with 

19 applicable wasteload allocations established for downstream receiving waters. At present, there 

20 are few industrial facilities within the Bonne Femme Creek watershed or upstream of the 

21 watershed, as identified in Table 4–11. Within this context, however, climate change including 

22 changes in runoff rate and quality would be expected to have as big or a bigger role in affecting 

23 surface water hydrology and water quality as growth and development alone in the watershed, 

24 as described above. In consideration of this information, the NRC staff concludes that the 

25 cumulative impacts on surface water resources would be SMALL to MODERATE, primarily due 

26 to regional growth and climate change.

27 4.14.4.2 Groundwater

28 Groundwater is the source of water supply for municipal water suppliers and individual users in 

29 Boone County. Total groundwater use in Boone County is approximately 18.2 mgd 

(68,890 m3 30 /day). While groundwater is withdrawn from the more productive zones of the 

31 Mississippian aquifer and from the upper units of the Ordovician age units for agricultural and 

32 domestic uses in Boone County, public water supply utilities primarily rely upon deep wells 

33 completed in the Cambrian-Ordovician aquifer system. The shallow glacial drift that occurs 

34 primarily over the eastern part of the County including the Discovery Ridge site is not generally 

35 used as a source of water supply, as discussed in Section 3.4.2.

36 Public utilities, including water and sewer, already exist at the Discovery Ridge site. The 

37 Discovery Ridge site lies within the service area of Consolidated Public Water Supply District 

38 No. 1, and it would supply water to the proposed NWMI facility site. The district is one of five 

39 water districts that supply water to the majority of users across Boone County, in addition to the 

40 City of Columbia. The district relies on a system of deep wells and has a total groundwater 

production capacity of 11 mgd (49,200 m3 41 /day) with water supply demands of approximately 

1.45 mgd (5,490 m3 42 /day) (Sections 3.4.2.2 and 4.4.2). In contrast, NWMI facility operations 

43 would require an average of 5,045 gpd (19,100 Lpd) of water, equivalent to 0.005 mgd 

(18.9 m3 44 /day).

45 The population of Boone County is projected to increase by about 40 percent by 2050, as 

46 referenced in Section 4.14.4.1. Assuming that this projected population growth has a direct and 

47 equal correlation on groundwater demand, total groundwater demand within the service area of 
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1 Consolidated Public Water Supply District No. 1 could grow to approximately 2 mgd 

(7,600 m3 2 /day).

3 Given the groundwater production capacity of the water supply district and the availability of 

4 groundwater within Boone County, the forecasted water demands alone would not be expected 

5 to affect the water district’s ability to provide adequate water supplies over the next 30 years.

6 Nevertheless, based on the assessment presented below, the NRC staff assumes that climate 

7 change could have as great or a greater impact on surface water and groundwater resources, 

8 including overall water availability, as any other reasonably foreseeable future actions. Locally 

9 within the Bonne Femme Creek watershed, this is particularly relevant given the sensitivity of 

10 karst watersheds. The loss of moisture from soils because of higher temperatures, along with 

11 increased evapotranspiration from vegetation and the increased average number of days 

12 without precipitation is likely to intensify short-term (seasonal or shorter) droughts across the 

13 Midwest region into the future (USGCRP 2009, 2014). Such conditions can reduce the amount 

14 of water available for surface runoff, streamflow, and groundwater recharge. Specifically, 

15 climate change is projected to increase water demand across most of the United States. When 

16 accounting for regional changes in population coupled with predicted climate change impacts, 

17 current projections indicate that northeast Missouri (where the Discovery Ridge site is located) 

18 could experience climate-change induced increases in water demand of up to 10 to 25 percent 

19 (USGCRP 2014). This increase would still not challenge the current production capacity of 

20 Consolidated Public Water Supply District No. 1. In order to manage any increases in water 

21 demands across Boone County where the water supply is heavily reliant on deep groundwater, 

22 coupled with the potential for reduced groundwater recharge due to climate change, the 

23 County’s water supply districts and other municipalities could take action to increase the 

24 efficiency and extent of their production and water distribution infrastructure. This could include 

25 redeveloping existing production wells or drilling new ones to manage water supply conflicts. 

26 Alternatively, public water suppliers could also seek out new water supply sources such as the 

27 abundant resources of the Missouri River, although this approach would entail investments in 

28 new infrastructure and increased operating costs. Suppliers could also pursue a combination of 

29 approaches such as conservation measures and new sources.

30 It remains that the projected average daily water needs for NWMI facility construction, 

31 operations, and decommissioning would be a very small percentage (less than 1 percent) of the 

32 public water district’s total production and current available supply capacity. In total, the NRC 

33 staff concludes that the cumulative impacts on groundwater resources, including water 

34 availability, would be SMALL.

35 4.14.5 Ecological Resources

36 This section addresses the direct and indirect effects of the construction, operations, and 

37 decommissioning of the proposed NWMI facility on ecological resources when added to the 

38 aggregate effects of other past, present, and reasonably foreseeable future actions. The 

39 description of the affected environment in Section 3.5 serves as a baseline for the ecological 

40 cumulative impact assessment. The ROI for evaluating cumulative impacts on ecological 

41 resources includes the Bonne Femme (Creek) watershed in the vicinity of the proposed site. 

42 The incremental impacts from construction, operations, and decommissioning of the proposed 

43 NWMI facility would be SMALL, as described in Section 4.5.

44 Before European settlement, the main land cover types within the Bonne Femme watershed 

45 included prairies, forests, and wetlands. Since that time, these habitats have been greatly 

46 reduced and converted into agricultural fields, and residential and commercial areas, as 

47 described in Section 3.5. The remaining tracts of grasslands, forests, and wetlands tend to be 
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1 relatively small and isolated, which provides lower quality habitats than large tracts of habitat

2 because of the different biological and physical characteristics along the edge of a habitat patch.

3 Environmental management practices over the past few decades have slightly increased the 

4 quality and extent of terrestrial and aquatic habitats. For example, the amount of forested 

5 habitats has increased because of changes in land management and forestry laws 

6 (Karstensen 2010). 

7 Current threats to terrestrial and aquatic habitats include increased soil, nutrients, and other 

8 pollutants washing into streams and lakes from urban and agricultural stormwater runoff, 

9 continued conversion and fragmentation of wildlife habitat from development, and the 

10 introduction of invasive species (BFSC 2007; USGS 2009). These activities will likely decrease 

11 the overall availability and quality of forested, grassland, and wetland habitats. Species with 

12 threatened, endangered, or declining populations are likely to be more sensitive to declines in 

13 habitat availability and quality and the introduction of invasive species.

14 New development projects identified in Table 4–11 are likely to have minimal impacts on 

15 ecological resources because all the projects are sited within areas that are currently 

16 agricultural land, open space, or developed. These types of land covers provide low-quality 

17 habitats for wildlife, birds, and aquatic resources.

18 State parks and wildlife refuges located near the proposed site, such as Rock Bridge State 

19 Park, Three River Conservation Area, and the northwest corner of the Mark Twain National 

20 Forest, provide valuable habitat to native wildlife and migratory birds. For example, these parks 

21 contain complex, natural habitats that are relatively rare within the watershed, such as 

22 woodlands, oak forests, and tall grass prairies. As agricultural activities, development, and 

23 urbanization increase habitat conversion and fragmentation, these protected areas will become 

24 ecologically more important because they provide continuous areas of minimally disturbed 

25 habitat.

26 Climate change in the midwestern United States is likely to include an increase in the annual 

27 mean temperature combined with an increase in the intensity of rainfall events (USGCRP 2014). 

28 As the climate changes, ecological resources will either need to be able to tolerate the new 

29 physical conditions, such as less water availability, or to shift their population range to new 

30 areas with a more suitable climate. Some species may be more prone to changes in climate. 

31 For example, migratory birds that travel long distances may not be able to detect environmental 

32 clues that a warmer, earlier spring is occurring in the United States, while the birds are still 

33 overwintering in the tropics. Fraser et al. (2013) found that songbirds overwintering in the 

34 Amazon basin did not leave their winter sites earlier, even when spring sites in the eastern 

35 United States experienced a warmer spring. As a result, the song birds missed periods of “peak 

36 food” availability. Climate changes could also favor non-native invasive species and promote 

37 population increases of insect pests and plant pathogens, which may be more tolerant to a 

38 wider range of climate conditions (USGCRP 2014). Physiological stressors associated with 

39 climate change may also exacerbate the effects of existing stresses in the natural environment, 

40 such as those caused by habitat fragmentation, invasive species, nitrogen deposition and runoff

41 from agriculture, and air emissions. 

42 Section 4.5 of this EIS concludes that the impact from the proposed facility construction, 

43 operations, and decommissioning would not noticeably alter the terrestrial and aquatic 

44 environment and, thus, would be SMALL. However, as environmental stressors, such as runoff

45 from agricultural fields and urban areas and climate change, continue over the proposed 

46 construction, operational, and decommissioning periods, certain attributes of the terrestrial and 

47 aquatic environment (such as habitat quality) are likely to noticeably change. The staff does not 

48 expect these impacts to destabilize any important attributes of the terrestrial and aquatic 
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1 environment because such impacts will cause gradual change, which should allow many 

2 aspects of the terrestrial and aquatic environment to appropriately adapt. The NRC staff 

3 concludes that the cumulative impacts of the proposed construction, operations, and 

4 decommissioning of the NWMI facility plus other past, present, and reasonably foreseeable 

5 future projects or actions would result in MODERATE impacts to terrestrial and aquatic 

6 resources. This MODERATE impact is primarily driven by environmental stressors, such as 

7 runoff from agricultural fields and urban areas and climate change, which are likely to noticeably 

8 alter important attributes of the terrestrial and aquatic environments. 

9 4.14.6 Historic and Cultural Resources

10 This section addresses the direct and indirect contributory effects from constructing, operating, 

11 and decommissioning the proposed NWMI facility at the Discovery Ridge site when added to 

12 the aggregate effects of other past, present, and reasonably foreseeable future actions on 

13 historic and cultural resources. The ROI in this analysis is the Discovery Ridge site and its 

14 immediate vicinity. As discussed in Section 4.6, constructing, operating, and decommissioning 

15 the proposed NWMI facility would not impact any known historic and cultural resources at the 

16 Discovery Ridge site.

17 The archaeological record for the region indicates prehistoric and historic occupation; the APE 

18 appears to have been traditionally used as agricultural fields from the protohistoric period 

19 onward. Historic land development and prolonged agricultural use may have resulted in 

20 impacts on, and the loss of, cultural resources. As described in Section 3.6.2, no evidence of 

21 historic or cultural resources were found within the Lot 15 survey area, and the closest historic 

22 property is approximately 1 mi (1.6 km) to the northwest of the Discovery Ridge site. The only 

23 foreseeable project within the APE is the proposed NWMI facility. Therefore, historic and 

24 cultural resources are not likely to be affected by the cumulative effects of constructing, 

25 operating, and decommissioning the proposed NWMI facility combined with other past, present, 

26 and reasonable foreseeable future activities at the Discovery Ridge site.

27 4.14.7 Socioeconomics

28 This section addresses the direct and indirect contributory effects from constructing, operating, 

29 and decommissioning the proposed NWMI facility at Discovery Ridge when added to the effects 

30 from other past, present, and reasonably foreseeable future actions on current socioeconomic 

31 conditions within the ROI. The description of the affected environment in Section 3.7 serves as 

32 a baseline for the cumulative socioeconomic impact assessment. The socioeconomic ROI is 

33 Boone County. Section 4.7 found that socioeconomic impacts from the construction, 

34 operations, and decommissioning of the proposed NWMI facility would be SMALL.

35 Table 4–11 identifies past, present, and reasonably foreseeable future actions within the ROI 

36 that could contribute to cumulative socioeconomic impacts. Relevant “other actions” that are 

37 considered in this cumulative impacts analysis is the potential for future construction within the 

38 Discovery Ridge site and the construction and operation of the Discovery Park, involving 

39 residential and commercial development, on the west side of U.S. Highway 63 opposite the 

40 Discovery Ridge site.

41 The proposed NWMI facility is located in Lot 15 of the Discovery Ridge Research Park, an area 

42 designated for research, development, and office park and is currently zoned for commercial 

43 use. The Discovery Ridge Research Park is large enough for the construction and operation of 

44 several research laboratory and office facilities. Since no other research or office facilities are 

45 currently planned for the Discovery Ridge Research Park, there would be no labor shortages 
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1 because the City of Columbia and Boone County have a sufficient workforce to meet the needs 

2 for new research facilities (Section 3.7.4).

3 The Discovery Park development is being constructed 0.4 mi (0.6 km) southwest of the 

4 proposed NWMI facility. Demand for labor would not create a shortage because the City of 

5 Columbia and Boone County have a sufficient workforce to meet the needs for both facilities. 

6 Construction of Discovery Park could increase the size of the local population as well as 

7 employment and tax revenue and an increased demand for public services in the ROI. 

8 However, the overall contributory socioeconomic effect of this construction project would be 

9 small. Therefore, with no other research or office facilities currently planned for the Discovery 

10 Ridge Research Park, the cumulative impact of the proposed NWMI facility, combined with the 

11 Discovery Park development, would be SMALL.

12 4.14.8 Human Health

13 The geographic ROI for the evaluation of cumulative effects on human health is a 5-mi (8-km) 

14 radius of the proposed NWMI facility. This evaluation will consider radiological and 

15 nonradiological impacts of other activities (in the recent past, present, and reasonably 

16 foreseeable future) within this ROI. Within this ROI, there are no nuclear power plants that 

17 would contribute to radioactive or nonradioactive exposure. However, the Callaway Energy 

18 Center nuclear power plant is located approximately 28 mi (45 km) away. Given that the 

19 proposed Discovery Ridge site is within the 50 mi (80 km) radiological emergency planning zone 

20 for the Callaway plant, radiological human health impacts associated with the Callaway plant will 

21 also be considered in this evaluation.

22 As discussed in Section 4.8.2, the NRC staff reviewed the information provided by NWMI 

23 regarding the proposed radiological and nonradiological safety programs that would be 

24 implemented to protect occupational workers and members of the public from any detrimental 

25 human health effects that could be associated with operation of the proposed NWMI facility. 

26 The NRC staff concluded that both radiological and nonradiological human health impacts to 

27 workers and members of the public from operation of the proposed facility would be SMALL.

28 4.14.8.1 Radiological Impacts

29 Projects and facilities considered for this evaluation that could have potential radiological human 

30 health impacts within the ROI include:

31 • MURR (currently operating);

32 • Callaway nuclear power plant (currently operating);

33 • two ABC Laboratories facilities (currently operating);

34 • University Hospital and Boone Hospital Center (two currently operating medical 

35 facilities that perform procedures using radiation); and

36 • two sites with legacy radioactive contamination: the site of one of the two ABC 

37 Laboratories facilities listed above, and the University of Missouri’s Pickard Hall site.

38 As discussed in Section 3.10.1, MURR, which is located approximately 4 mi (6.4 km) from the 

39 proposed NWMI facility site, produces gaseous and liquid radiological effluents during routine 

40 operation. However, these effluents are monitored to ensure any public radiation dose that 

41 could result from the effluents is below NRC regulatory limits in 10 CFR Part 20. Additionally, 

42 environmental monitoring performed by MURR has shown minimal or no environmental impact 

43 from MURR operation. Given that MURR and the proposed NWMI facility would both be 

44 required to comply with NRC regulatory dose limits; current radiological environmental impacts 
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1 from MURR are very low; and the distance between the two facilities (which would minimize 

2 potential cumulative radiation exposure), the NRC staff does not expect that the combined 

3 operation of these facilities would result in a cumulative radiological dose impact in excess of 

4 NRC regulatory limits.

5 The Callaway nuclear plant, which is discussed in Section 3.8.2, is located approximately 28 mi 

6 (45 km) from the proposed NWMI site. Environmental monitoring performed at the Callaway 

7 plant has shown minimal or no environmental impact from operation of the plant. Given that the 

8 Callaway plant and the proposed NWMI facility would both be required to comply with NRC 

9 regulatory dose limits; current radiological environmental impacts from the Callaway plant are 

10 very low; and the distance between the two facilities, the NRC staff does not expect that the 

11 combined operation of these facilities would result in a cumulative radiological dose impact in 

12 excess of NRC regulatory limits.

13 The two ABC Laboratories facilities, discussed in Section 3.8.2, are located approximately

14 0.3 mi (0.5 km) and 5 mi (8 km) from the proposed NWMI site. ABC Laboratories is licensed by 

15 NRC to use radioactive materials at these facilities (NWMI 2015a). Although worker doses are 

16 monitored at these facilities to ensure compliance with NRC occupational dose limits, no 

17 environmental monitoring is required because no radioactive material releases, and 

18 consequently no radiation dose to the public, is anticipated from the continued operation of 

19 these facilities. Given that ABC Laboratories and the proposed NWMI facility would both be 

20 required to comply with NRC dose limits, and also given that no radiological environmental 

21 impacts are anticipated from ABC Laboratories operation, the NRC staff does not expect that 

22 the combined operation of these facilities would result in a cumulative radiological dose impact 

23 in excess of NRC regulatory limits.

24 Two currently operating medical facilities, University Hospital and Boone Hospital Center, are 

25 each located approximately 4 mi (6.4 km) from the proposed NWMI site and each perform 

26 medical procedures using radiation. Although patients receiving these medical procedures are 

27 exposed to radiation, radiation doses to patients from medical procedures are not subject to 

28 NRC regulatory dose limits. The radiation exposure to members of the public outside of medical 

29 facilities is negligible; therefore, the NRC staff does not expect that the combined operation of 

30 University Hospital, Boone Hospital Center, and the proposed NWMI facility would result in a 

31 cumulative radiological dose impact in excess of NRC regulatory limits.

32 As discussed in Section 3.8.2, two sites in the ROI, an ABC Laboratories site and the University 

33 of Missouri’s Pickard Hall, which are located approximately 5 mi (8 km) and 1.2 mi (1.9 km) from 

34 the proposed NWMI facility site, respectively, contain legacy radiological contamination. The 

35 ABC Laboratories site contains three backfilled former liquid radiological waste disposal 

36 lagoons. However, surveys have shown the levels of residual radioactive contamination at this 

37 site to be very low. Since minimal or no continuing dose from radioactive material in these 

38 lagoons is expected, the NRC has approved the release of the land containing the backfilled 

39 lagoons for unrestricted use. The University of Missouri’s Pickard Hall, and some subsurface 

40 soil in the immediate vicinity of that building, contain legacy radioactive radium contamination 

41 from historical activities performed in the building. An internal standard operating procedure is 

42 used at Pickard Hall to help avoid any further spread of this contamination, minimizing any dose 

43 to the public. Since only minimal public radiation exposure occurs from either of these 

44 contaminated sites, and given the distance between these sites and the proposed NWMI facility, 

45 the NRC staff does not expect that the cumulative impacts of these sites and the proposed 

46 NWMI facility would result in a cumulative radiological dose impact in excess of NRC regulatory 

47 limits.
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1 The NRC staff is currently conducting an independent safety evaluation to verify that the 

2 radiological exposure to occupational workers and members of the public from operation of the 

3 proposed NWMI facility would be below the regulatory limits in 10 CFR Part 20. If the NRC staff 

4 determines that the doses would be within the regulatory limits, the NRC staff concludes that the 

5 cumulative radiological human health impacts would be SMALL.

6 4.14.8.2 Nonradiological Impacts

7 Construction activities included in Table 4–11, as well as construction of the proposed NWMI 

8 facility, would involve potential hazards to workers typical of any construction site 

9 (NWMI 2015a). In addition, the proposed NWMI facility and some other facilities listed in Table 

10 4–11 are industrial sites with many typical occupational hazards. These construction and 

11 industrial activities would be required to be performed subject to OSHA and State of Missouri 

12 safety regulations. Additionally, as the proposed NWMI facility would not be accessible to the 

13 general public during construction or operation (NWMI 2015a), and other construction and 

14 industrial sites are also generally not publicly accessible, these hazards are not anticipated to 

15 affect members of the public.

16 Hazardous chemical releases from the proposed NWMI facility, and from other activities or 

17 facilities within the ROI, would be required to be within EPA and State of Missouri regulatory 

18 limits. In addition, certain toxic chemical releases must be reported to the EPA as part of EPA’s 

19 Toxics Release Inventory (TRI) program, as discussed in Section 3.8.3.

20 Other than the Discovery Ridge Research Park (which currently includes ABC Laboratories and 

21 IDEXX BioResearch as tenants), all other currently operating facilities in Table 4–11 for which 

22 possible chemical releases would be expected (Callaway nuclear power plant, MURR, Boone 

23 Quarries, University of Missouri’s Combined Heat and Power Plant, Columbia Municipal Power 

24 Plant, and Columbia Energy Center) are approximately 4 mi (6.4 km) or more from the proposed 

25 NWMI facility site. ABC Laboratories and IDEXX BioResearch are 0.3 mi (0.5 km) and 0.1 mi 

26 (0.16 km) from the proposed site, respectively. Neither ABC Laboratories nor IDEXX 

27 BioResearch meet the thresholds that would make them subject to reporting for EPA’s TRI 

28 program (EPA 2016d).

29 In summary, given the distances between the proposed NWMI facility site and other facilities 

30 listed in Table 4–11 and that ongoing and future facilities that would release chemicals would be 

31 subject to applicable regulations, the NRC staff does not expect that the cumulative impacts of 

32 other facilities in Table 4–11 and the proposed NWMI facility would result in a cumulative 

33 chemical exposure impact in excess of Federal or State regulatory limits. The NRC staff 

34 therefore concludes that the cumulative nonradiological human health impacts would be 

35 SMALL.

36 4.14.9 Waste Management

37 The ROI for the evaluation of cumulative impacts from the disposal of radioactive and 

38 nonradioactive waste is that area within a 5 mi (8 km) radius of the proposed NWMI facility. 

39 Table 4–11 lists the facilities and activities considered within this ROI.

40 This evaluation considers the cumulative impacts within the ROI associated with the waste 

41 management activities of other facilities using radioactive and nonradioactive material in the 

42 recent past, present, and reasonably foreseeable future.

43 In Section 4.9., the NRC staff reviewed the information provided by NWMI regarding its 

44 radioactive and nonradioactive waste management plans. The NRC staff found that the 

45 procedures, controls, and engineering design features that would be used at the proposed 

46 NWMI facility would minimize impacts to workers and the public from the handling, storage, 
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1 transportation, and disposal of radioactive and nonradioactive wastes. The NRC staff therefore 

2 concludes that the human health impacts from both radioactive and nonradioactive wastes 

3 would be SMALL.

4 4.14.9.1 Radioactive Waste

5 Activities identified within the ROI that could generate radioactive waste include the operation 

6 of:

7 • MURR;

8 • ABC Laboratories; and,

9 • University Hospital and Boone Hospital Center, which use radiation for medical 

10 treatment.

11 Disposal of radioactive waste from any of these facilities would be required to be conducted in 

12 accordance with all Federal and State of Missouri regulations. Some or all radioactive wastes 

13 from these facilities would likely go to the same waste disposal sites. There are no radioactive 

14 waste disposal sites within the State of Missouri. Two facilities are available for the disposal of 

15 low-level radioactive waste produced within the State of Missouri: Energy Solutions Clive 

16 Operations in Clive, Utah, and WCS in Andrews, Texas. Energy Solutions accepts only Class A 

17 low-level radioactive waste, while WCS accepts Class A, B, and C low-level waste 

18 (NRC 2016e). As discussed in Section 4.9.1, NWMI plans to ship radioactive waste from the 

19 proposed facility to WCS (NWMI 2015a). WCS accepts mixed waste (i.e., waste that is both 

20 hazardous and radioactive), in addition to nonhazardous radioactive waste (WCS 2016).

21 As discussed in Section 4.9.1, if NWMI loses access to a low-level waste disposal facility, any 

22 low-level waste would have to be stored, either within the NWMI facility or in a new storage 

23 facility constructed either on site or at an offsite location, until a low-level waste facility is 

24 available. Low-level waste, regardless of its location, must be stored in accordance with 

25 Federal and state regulations to ensure the safety of workers and members of the public. As 

26 discussed in Sections 2.7.1, 2.8.1 and 4.9.1, NWMI would have controls and engineering design 

27 features at the proposed facility to ensure that handling and storage of radioactive waste would 

28 be conducted such that radiation doses to workers and members of the public are maintained 

29 ALARA. The NRC staff expects that similar facility design and management programs would be 

30 used to ensure safety during the temporary storage of low-level radioactive waste at other 

31 facilities within the ROI.

32 Based on the information on radioactive waste disposal for waste produced in Missouri and the 

33 United States, the NRC staff expects that there would be adequate disposal space for the 

34 cumulative quantities of radioactive waste that would be produced by the proposed NWMI 

35 facility and other facilities within the ROI. In addition, radioactive waste from all sources would 

36 be required to be handled, transported, and disposed of in accordance with Federal and state 

37 regulations. The NRC staff therefore concludes that the cumulative impact from radioactive 

38 waste disposal would be SMALL.

39 4.14.9.2 Nonradioactive Waste

40 Many activities within the ROI, including those listed in Table 4–11 and the proposed NWMI 

41 facility, could or would produce nonhazardous, nonradioactive wastes. Activities within the ROI 

42 that currently produce, or could produce, hazardous nonradioactive wastes include industrial, 

43 production, medical, and/or research facilities such as MURR, ABC Laboratories, IDEXX 

44 BioResearch, University of Missouri’s Combined Heat and Power Plant, Columbia Municipal 

45 Power Plant, University Hospital, and Boone Hospital Center.
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1 As discussed in Sections 2.7.3 and 4.9.2, NWMI would implement a waste minimization and 

2 pollution prevention program that would help to minimize the production of hazardous and 

3 nonhazardous wastes at the proposed facility. As discussed in Sections 2.7.2 and 4.9.2, the 

4 proposed NWMI facility would generate less than 1,000 kg (2,205 lb) of hazardous waste per 

5 month, and approximately 4,056 kg (8,942 lb) of nonradiological, nonhazardous waste 

6 (i.e., municipal waste) per year during operation (NWMI 2015c). NWMI expects that 

7 nonradiological hazardous wastes from construction or operation of the proposed facility would 

8 be collected by a hazardous waste disposal company such as Veolia or Clean Harbors for 

9 separation, processing, and disposal. Other solid waste (municipal waste or construction 

10 debris) generated by the construction or operation of the proposed facility would be picked up 

11 and disposed of at the City of Columbia sanitary landfill (NWMI 2015c).

12 The NRC staff expects that nonradiological hazardous or nonhazardous wastes produced by 

13 activities in the ROI other than NWMI would be disposed of similarly to the waste from the 

14 proposed NWMI facility. As discussed in Section 3.8.3 ABC Laboratories and IDEXX 

15 BioResearch are hazardous quantity generators that are periodically inspected to ensure and 

16 enforce compliance with applicable waste management regulations. All hazardous waste would 

17 be managed according to applicable regulations (e.g., RCRA and the Missouri Hazardous 

18 Waste Management Law (Missouri Revised Statutes 2015b)). Given the population density and 

19 level of activity in the ROI, and given that the ROI includes other large and small quantity 

20 hazardous waste generators as discussed in Section 3.8.3, the NRC staff also expects that the 

21 incremental quantity of waste produced by the proposed facility would be comparatively small 

22 and that there would be adequate infrastructure and capacity for disposal of the additional 

23 waste.

24 As discussed in Section 2.7.2, NWMI would release sanitary wastewater and nonradioactive 

25 liquid waste, meeting municipal treatment standards, to the Columbia sewer system. The NRC 

26 staff expects that wastewater from other activities within the ROI would be disposed of similarly 

27 to the wastewater from the proposed NWMI facility. The NRC staff also expects that the 

28 incremental quantity of wastewater produced by the proposed facility would be comparatively 

29 small, and that the Columbia sewer system would have adequate capacity to handle the 

30 additional wastewater.

31 Given that waste disposal infrastructure exists for nonradiological wastes generated within the 

32 ROI, that the incremental quantities of waste produced by the proposed NWMI facility would be 

33 comparatively small, and that all waste produced within the ROI would be handled and disposed 

34 of subject to Federal, State, and local regulations and standards, the NRC staff concludes that 

35 the cumulative impact from nonradiological waste disposal would be SMALL.

36 4.14.10 Accidents

37 The geographic ROI for the evaluation of cumulative effects of accidents is that within a 5 mi 

38 (8 km) radius of the proposed NWMI facility. This evaluation will consider cumulative impacts of 

39 radiological and chemical accidents that could occur within this ROI. Within this ROI, there are 

40 no nuclear power plants. However, the Callaway Energy Center nuclear power plant is located 

41 approximately 28 mi (45 km) away. Since the proposed site is within the 50 mi (80 km) 

42 radiological emergency planning zone for the Callaway plant, hypothetical radiological accidents 

43 associated with the Callaway plant will also be considered in this evaluation.

44 4.14.10.1 Radiological Accidents

45 As discussed in Section 4.11.1, the NRC staff reviewed the information provided by NWMI 

46 regarding radiological consequences of potential accidents at the proposed NWMI facility. The 

47 analyses provided by NWMI showed that hypothetical, unmitigated radiological accidents at the 
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1 proposed facility could be intermediate-consequence for members of the public, and could be 

2 high- or intermediate-consequence for NWMI facility staff. However, NWMI stated that it would 

3 use engineered and administrative controls to reduce the likelihood and consequences of 

4 radiological accidents at the proposed facility, such that the proposed facility would comply with 

5 the performance requirements in 10 CFR 70.61. The NRC staff concluded that if the NRC 

6 safety review determined that the proposed NWMI facility would comply with 10 CFR 70.61 and 

7 any other applicable NRC regulations regarding radiological accident consequences, the 

8 impacts from potential radiological accidents would be SMALL.

9 Existing facilities included in this evaluation that could have potential radiological accidents are 

10 facilities that are nuclear reactors or that otherwise use radiation or radioactive materials, 

11 including Callaway nuclear power plant, MURR, ABC Laboratories, University Hospital, and 

12 Boone Medical Center. These facilities are licensed by NRC. To be licensed by NRC, facility 

13 licensees must show that the facilities are in compliance with NRC regulations, including dose

14 limits for accidents. Therefore accidents at these facilities are expected to have minimal 

15 environmental impact. For example, the generic EIS for license renewal of nuclear power plants 

16 in the United States (NUREG-1437) determined that the environmental impacts of both 

17 design-basis accidents (i.e., credible accidents) and beyond design-basis accidents 

18 (i.e., severe, unlikely accidents) would be SMALL (NRC 2013b). The plant-specific supplement 

19 to the generic EIS for license renewal that was developed for the Callaway nuclear power plant 

20 found no accident-related impacts for the Callaway plant beyond those discussed in the generic 

21 EIS (NRC 2014). 

22 The possible radiological accident impacts from other activities near the proposed NWMI facility 

23 would be minimal, and if the proposed NWMI facility were in compliance with NRC regulations 

24 regarding accident consequences, the incremental environmental effects of potential 

25 radiological accidents from the NWMI facility would also be minimal, as discussed in 

26 Section 4.11.1. Additionally, with the exception of the ABC Laboratories facility located 

27 approximately 0.3 mi (0.5 km) from the proposed facility site, for which no radiological releases 

28 are expected as discussed in Section 4.14.8.1, no other facilities currently licensed to use 

29 radiation or radioactive materials are located within approximately 4 mi (6.4 km) of the proposed 

30 facility site. Therefore, if the NRC safety review determines that the proposed NWMI facility 

31 would comply with 10 CFR 70.61 and any other applicable NRC regulations regarding 

32 radiological accident consequences, the NRC staff concludes that the cumulative impact from 

33 potential radiological accidents would be SMALL.

34 4.14.10.2 Nonradiological Accidents

35 As discussed in Section 4.11.2, the NRC staff reviewed the information provided by NWMI 

36 regarding chemical exposure consequences of potential accidents at the proposed NWMI 

37 facility. The analyses provided by NWMI showed that hypothetical, unmitigated chemical 

38 accidents at the proposed facility could be high- or intermediate-consequence for members of 

39 the public and NWMI facility staff. However, NWMI stated that it would use engineered and 

40 administrative controls to reduce the likelihood and consequences of hazardous chemical 

41 accidents at the proposed facility, such that the proposed facility would comply with the 

42 performance requirements in 10 CFR 70.61. The NRC staff concluded that if the NRC safety 

43 review determined that the proposed NWMI facility would comply with 10 CFR 70.61 and any 

44 other applicable NRC regulations regarding chemical accident consequences, the impacts from 

45 potential hazardous chemical accidents would be SMALL.

46 Existing facilities or activities included in this evaluation that could have potential chemical

47 accidents include those listed in Table 4–11. These facilities or activities are required to comply 

48 with EPA and State of Missouri regulations to ensure the safe handling of chemicals and 
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1 hazardous materials. The possible chemical accident impacts from other activities near the 

2 proposed NWMI facility would be minimal, and if the proposed NWMI facility were in compliance 

3 with NRC regulations regarding accident consequences, the incremental environmental effects 

4 of potential hazardous chemical accidents from the NWMI facility would also be minimal, as 

5 discussed in Section 4.11.2. Additionally, as discussed in Section 4.14.8.2, none of the facilities 

6 or activities listed in Table 4–11 that are located within approximately 4 mi (6.4 km) of the 

7 proposed NWMI facility site use hazardous chemicals in quantities that would make them 

8 subject to the EPA’s TRI reporting requirements, further reducing the likelihood that any 

9 significant chemical release accident could occur in close proximity to the proposed NWMI 

10 facility site. Therefore, if the NRC safety review determines that the proposed NWMI facility 

11 would comply with 10 CFR 70.61 and any other applicable NRC regulations regarding 

12 hazardous chemical accident consequences, the NRC staff concludes that the cumulative 

13 impact from potential hazardous chemical accidents would be SMALL.

14 4.14.11 Transportation

15 This section addresses the direct and indirect contributory effects from constructing, operating, 

16 and decommissioning the proposed NWMI facility when added to the effects from other past, 

17 present, and reasonably foreseeable future actions on transportation infrastructure. The ROI is 

18 the 5-mi (8-km) region surrounding the proposed NWMI facility. However, the roads for routes 

19 that could be used for delivery of medical isotopes (if air transport is not possible) or disposal of 

20 wastes were also considered. Transportation infrastructure includes roadways, rail lines, 

21 airports, and traffic control devices. As discussed in Section 4.10, transportation impacts during 

22 construction, operations, and decommissioning would be SMALL.

23 Construction projects in Table 4–11 could produce an increase in vehicle traffic on roads within 

24 the 5-mi (8-km) radius of the proposed NWMI site. For example, Discovery Park, a residential 

25 and commercial development being constructed on the west side of U.S. Highway 63 opposite 

26 the Discovery Ridge Research Park, could add additional commuting vehicles and commercial 

27 trucks on local roads near the proposed NWMI facility. In addition, new construction projects 

28 could occur within the Discovery Ridge Research Park. However, existing roads are sufficient 

29 to handle the increased traffic. An increase in the number of commuter vehicles and 

30 commercial trucks on roads near the proposed NWMI site would not likely have a noticeable 

31 impact on overall traffic volumes. Therefore, the cumulative effect of traffic-related 

32 transportation impacts of the proposed action combined with the Discovery Ridge Research 

33 Park and Discovery Park development would be SMALL.

34 4.14.12 Environmental Justice

35 The environmental justice cumulative impact analysis evaluates the potential contributory 

36 human health and environmental effects from the construction, operations, and 

37 decommissioning of the proposed NWMI facility when added to the effects from other past, 

38 present, and reasonably foreseeable future actions on minority and low-income populations and 

39 whether these effects might be disproportionately high and adverse. Everyone living near 

40 Discovery Ridge Research Park and the proposed NWMI facility could be affected by 

41 construction, operations, and decommissioning activities, including minority and low-income 

42 populations.

43 The ROI is the 5-mi (8-km) region surrounding the proposed NWMI facility at the Discovery 

44 Ridge site. As discussed in Section 4.12, the proposed NWMI facility is not located in a minority 

45 population block group. Minority and low-income populations residing along site access roads 

46 could be affected by noise, dust, and increased commuter vehicle and truck traffic during 
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1 construction, operations, and decommissioning. However, during construction and 

2 decommissioning, these would be short term and primarily limited to onsite activities. In 

3 addition, NWMI facility operations would not have high and adverse human health and 

4 environmental effects on minority and low-income populations. As a result, minority and 

5 low-income populations residing near the proposed NWMI facility at Discovery Ridge would not 

6 experience disproportionately high and adverse human health and environmental effects from 

7 the proposed action.

8 Table 4–11 identifies past, present, and reasonably foreseeable future actions within the ROI 

9 that could contribute cumulative human health and environmental effects. Potential impacts to 

10 minority and low-income populations from other past, present, and reasonably foreseeable 

11 future actions would mostly consist of environmental effects caused by construction and 

12 operation of new residential, commercial, and industrial developments (e.g., noise, dust, traffic, 

13 employment, and housing impacts). However, noise and dust impacts would be short term 

14 during construction and primarily limited to onsite activities. Minority and low-income 

15 populations residing along site access roads could be directly affected by commuter vehicle and 

16 truck traffic. However, these effects are not likely to be high and adverse and would be 

17 contained within a limited time period during certain hours of the day. Increased demand for 

18 housing could cause housing costs to rise. Increasing rental costs could disproportionately 

19 affect low-income populations who rely on inexpensive housing. However, given the availability 

20 of local labor and the likelihood that construction workers would commute to the work site, rental 

21 housing costs may be unaffected.

22 Emissions from new commercial or industrial facilities could also disproportionately affect 

23 minority and low-income populations. However, any impacts would depend on the magnitude of 

24 the change from current environmental conditions. Permitted air emissions from all commercial 

25 and industrial facilities, including the contributory effects from the proposed NWMI facility, would 

26 be expected to remain within regulatory standards.

27 Based on this information and the analysis of human health and other environmental impacts 

28 presented in this EIS, the contributory effects of constructing, operating, and decommissioning 

29 the proposed NWMI facility are not likely to create high and adverse cumulative human health 

30 and environmental effects on minority and low-income populations living near Discovery Ridge

31 Research Park. 

32 4.14.13 Summary

33 Table 4–12 summarizes the cumulative impacts for all resources areas.

34 Table 4–12. Cumulative Impacts on Environmental Resources, Including the Impacts of 

35 the Proposed Project

Resource Category Cumulative Impact Level Description of Impacts

Land Use and Visual Resources

Land Use SMALL Cumulative land use impacts associated with 

the construction, operations, and 

decommissioning of the NWMI facility in 

conjunction with other reasonably foreseeable 

projects is considered SMALL. Discovery 

Ridge Research Park is currently certified for 

industrial use; any new development within this 

area would be compatible with current land use 

plans.
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Resource Category Cumulative Impact Level Description of Impacts

Visual Resources SMALL Cumulative visual impacts associated with the 

construction, operations, and decommissioning 

of the NWMI facility in conjunction with other 

reasonably foreseeable projects is considered 

SMALL. Reasonably foreseeable new 

construction activities would occur within or 

adjacent to existing facilities or within areas 

certified for industrial use and of low scenic 

quality.

Air Quality and Noise

Air Quality SMALL to MODERATE Cumulative air quality impacts associated with 

the construction, operations, and 

decommissioning of the NWMI facility in 

conjunction with other reasonably foreseeable 

projects is considered SMALL to MODERATE 

primarily due to future economic and 

population growth in Boone County that can 

lead to long-term air emission sources and 

increases in air pollutants that can noticeably 

alter air quality.

Noise SMALL to MODERATE Cumulative noise impacts associated with the 

construction, operations, and decommissioning 

of the NWMI facility in conjunction with other 

reasonably foreseeable projects is considered 

SMALL to MODERATE primarily due to the 

potential expansion of the Discovery Ridge 

Research Park and construction and operation 

of new roads adjacent to the proposed NWMI 

facility that would result in an increase in noise 

levels from traffic and business growth.

Geologic Environment SMALL Cumulative geologic resource impacts 

associated with the construction, operations, 

and decommissioning of the NWMI facility in 

conjunction with other reasonably foreseeable 

projects is considered SMALL. Following the 

completion of construction activities, continued 

soil loss would be minimal as the remaining 

soils would lie beneath impervious surfaces, 

such as buildings, or the impacted area would 

have been revegetated or incorporated into 

facility landscaping or hardscaped areas. 

Rock and mineral products including 

construction aggregate are widely available 

throughout Boone County and the surrounding 

region.
Environmental Impacts of Construction, Operations, and Decommissioning

4-90

Resource Category Cumulative Impact Level Description of Impacts

Water Resources SMALL to MODERATE Cumulative surface water resource impacts 

associated with the construction, operations, 

and decommissioning of the NWMI facility in 

conjunction with other reasonably foreseeable 

projects is considered SMALL to MODERATE, 

primarily due to regional growth and climate 

change. Cumulative groundwater resource 

impacts associated with the construction, 

operations, and decommissioning of the NWMI 

facility in conjunction with other reasonably 

foreseeable projects is considered SMALL.

Ecological Resources MODERATE Cumulative terrestrial and aquatic resource 

impacts associated with the construction, 

operations, and decommissioning of the NWMI 

facility in conjunction with other reasonably 

foreseeable projects is considered 

MODERATE, primarily due to certain attributes 

of the terrestrial and aquatic environment (such 

as habitat quality) that are likely to noticeably 

change as a result of environmental stressors, 

such as runoff from agricultural fields and 

urban areas and climate change, and that will 

continue over the proposed construction, 

operational, and decommissioning periods.

Socioeconomics SMALL Cumulative socioeconomic impacts associated 

with the construction, operations, and 

decommissioning of the NWMI facility in 

conjunction with other reasonably foreseeable 

projects is considered SMALL. Demand for 

labor would not create a shortage because the 

City of Columbia and Boone County have a 

sufficient workforce to meet the needs of 

facilities. Construction of Discovery Park could 

increase the size of the local population as well 

as employment and tax revenue and an 

increased demand for public services in the 

ROI. However, the overall contributory 

socioeconomic effect of this construction 

project would be SMALL.

Historic and Cultural 

Resources

See next column No evidence of historic or cultural resources 

were found within the Lot 15 (the proposed 

Discovery Ridge site) survey area, and the 

closest historic property is approximately 1 mi 

(1.6 km) to the northwest of the Discovery 

Ridge site. Historic and cultural resources are 

not likely to be affected by the cumulative 

effects of constructing, operating, and 

decommissioning the proposed NWMI facility 

combined with other past, present, and 

reasonable foreseeable future activities at the 

Discovery Ridge site.
Environmental Impacts of Construction, Operations, and Decommissioning

4-91

Resource Category Cumulative Impact Level Description of Impacts

Human Health SMALL Cumulative human health impacts associated 

with the construction, operations, and 

decommissioning of the NWMI facility in 

conjunction with other reasonably foreseeable 

projects is considered SMALL. Radiological 

doses would be within NRC regulatory limits 

and nonradiological exposures would be within 

Federal and State regulatory limits.

Waste Management SMALL Cumulative waste management impacts 

associated with the construction, operations, 

and decommissioning of the NWMI facility in 

conjunction with other reasonably foreseeable 

projects is considered SMALL. Adequate 

disposal space for the cumulative quantities of 

radioactive and nonradioactive waste that 

would be produced by the proposed NWMI 

facility and other facilities within the ROI exists. 

Radioactive and nonradioactive waste from all 

sources would be required to be handled, 

transported, and disposed of in accordance 

with Federal and State regulations.

Accidents SMALL Given that other existing facilities within the 

ROI are required to comply with Federal and 

State regulations that limit the consequences 

of accidents at those facilities, and given the 

proximity of those facilities to the proposed 

NWMI facility, if the NRC safety review 

determines that the proposed NWMI facility 

would comply with 10 CFR 70.61 and any 

other applicable NRC regulations regarding 

radiological and chemical accident 

consequences, then the cumulative impacts 

from potential radiological and chemical 

accidents would be SMALL. 

Transportation SMALL Cumulative traffic-related transportation 

impacts of the proposed action combined with 

the Discovery Ridge Research Park and 

Discovery Park development would be SMALL, 

an increase in the number of commuter 

vehicles and commercial trucks on roads near 

the proposed NWMI site would not likely have 

a noticeable impact on overall traffic volumes.

Environmental Justice See next column Cumulative human health and environmental 

effects on minority and low-income populations 

are not expected to be disproportionately high 

and adverse.

1 

5-1 

1 5.0 ALTERNATIVES

2 This chapter describes alternatives to granting a construction permit for the proposed Northwest 

3 Medical Isotopes, LLC (NWMI), medical radioisotope production facility (NWMI facility) and the 

4 environmental impacts of those alternatives. The need to compare the proposed action with 

5 alternatives arises from the requirement in Section 102(2)(C)(iii) of the National Environmental 

6 Policy Act of 1969 (NEPA), as amended (42 U.S.C. 4321 et seq.). NEPA states that an 

7 environmental impact statement (EIS) shall include an analysis of alternatives to the proposed 

8 action. The U.S. Nuclear Regulatory Commission (NRC) implements this requirement through 

9 regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 51 and its Interim Staff 

10 Guidance in NUREG–1537 (NRC 2012), which state that the EIS will include an analysis that 

11 considers and weighs the environmental effects of the proposed action, the environmental 

12 impacts of alternatives to the proposed action, and alternatives available for reducing or 

13 avoiding adverse environmental effects.

14 The NRC standard of significance for impacts uses the Council on Environmental Quality (CEQ)

15 terminology for “significantly” (40 CFR 1508.27). Since the significance and severity of an 

16 impact can vary with the setting of the proposed action, the NRC considered both “context” and 

17 “intensity,” as defined in the CEQ regulations in 40 CFR 1508.27. Context is the geographic, 

18 biophysical, and social context in which the effects would occur. Intensity is the severity of the 

19 impact. Based on this, the NRC established three levels of significance for potential impacts: 

20 SMALL, MODERATE, and LARGE. For this EIS, the NRC staff characterized impact levels for 

21 each resource area using the following three definitions of significance levels, which are 

22 presented in the Interim Staff Guidance to NUREG–1537 (NRC 2012): 

23 SMALL—environmental effects are not detectable or are so minor that 

24 they will neither destabilize nor noticeably alter any important attribute of 

25 the resource. In assessing radiological impacts, the NRC has concluded 

26 that those impacts that do not exceed permissible levels in the NRC’s 

27 regulations are considered small.

28 MODERATE—environmental effects are sufficient to alter noticeably, but 

29 not to destabilize, important attributes of the resource.

30 LARGE—environmental effects are clearly noticeable and are sufficient to 

31 destabilize important attributes of the resource.

32 In this EIS, the NRC staff analyzed four alternatives to the proposed action. In Section 5.1, the 

33 NRC staff analyzed the no-action alternative or the environmental consequences if the NRC 

34 denies the construction permit. In Section 5.2, the NRC staff examined the environmental 

35 consequences if the NWMI facility were constructed, operated, and decommissioned at an 

36 alternative location. Based on an in-depth site selection process, the NRC staff examined in 

37 depth one alternative site, the University of Missouri Research Reactor (MURR). Section 5.3 

38 examines the environmental impacts of construction, operating, and decommissioning a medical 

39 radioisotope production facility at the proposed Discovery Ridge site but using alternative 

40 technologies. The NRC initially considered a wide-range of potential alternative technologies 

41 and narrowed down the potential technologies to examine two alternative technologies in depth: 

42 uranium fission technology and linear accelerator-based technology. Section 5.4 describes the 

43 benefits and costs of the various alternatives.
Alternatives

5-2

1 5.1 No-Action Alternative

2 Under the no-action alternative, the NRC would deny the construction permit, and the NWMI 

3 facility would not be constructed. The no-action alternative does not involve the determination 

4 of whether radioisotopes are needed or should be generated. The decision to produce 

5 radioisotopes is at the discretion of applicants (NRC 2012).

6 Under the no-action alternative, no changes would occur to the proposed Discovery Ridge site 

7 from NRC-authorized construction. The site would remain designated as an industrial certified 

8 site. If the NRC denies the construction permit, a private entity could construct a facility on 

9 Lot 15. Given that such a facility would also need to construct and operate in compliance with

10 applicable local, State, or Federal requirements, and that the facility would also likely be a light 

11 industrial facility because it would occur within the Discovery Ridge Research Park, the impacts 

12 would likely be similar to those described in Chapter 4. Therefore, impacts on all resource 

13 areas would be SMALL.

14 The no-action alternative is the only alternative considered by the NRC that does not satisfy the 

15 purpose and need for this EIS, because this alternative does not satisfy the need for a 

16 U.S. supplier of molybdenum-99 (Mo-99). Assuming that the need for a U.S. supplier of Mo-99 

17 continues to exist, another private company would likely construct and operate a medical 

18 radioisotope production facility.

19 5.2 Alternative Sites

20 NWMI identified and selected reasonable alternative sites, using the site-selection process 

21 described in Section 5.2.1 (NWMI 2015a). The NRC staff reviewed NWMI’s site selection 

22 process and considered the environmental impacts of locating the proposed NWMI facility at an 

23 alternative site. Unless indicated otherwise, the following discussion is a summary of 

24 information presented in NWMI’s Environmental Report (ER) (NWMI 2015a) and responses to 

25 requests for additional information (RAI) (NWMI 2015c, 2016a).

26 5.2.1 Description of Alternative Site-Selection Process

27 5.2.1.1 Initial Site Screening

28 NWMI’s site-selection process assessed a variety of economic and environmental factors to 

29 determine reasonable sites to construct and operate the proposed NWMI facility. NWMI 

30 determined that proximity to an existing university research reactor was the most important 

31 factor in determining site location because the production process relies upon one or more 

32 research reactors to irradiate targets (NWMI 2016a). From this broad list of potential locations, 

33 NWMI (2016a) further narrowed the range of reasonable alternatives to four potential sites 

34 based on the following requirements for the co-located university research reactor:

35 • experience supporting government and commercial industries,

36 • capability to support commercial irradiation on a regular basis,

37 • core configuration that could accept the NWMI targets, and

38 • sufficient power to meet NWMI’s irradiation requirements.

39 Based on these criteria, NWMI identified four potential sites:
Alternatives

5-3

1 Discovery Ridge Site

2 The Discovery Ridge site is located in Columbia, Missouri, approximately 125 mi (201 km) west 

3 of St. Louis, Missouri. The site is located 3.7 miles (mi) (6 kilometers (km)) southeast of the 

4 University of Missouri Research Reactor. The 7.4-acre (ac) (3.0-hectare (ha)) site is located on 

5 a parcel of land that is part of a larger, developing technology research park (the Discovery 

6 Ridge Research Park). The site has been previously disturbed due to decades of agricultural 

7 activities. No utilities or roadways currently exist on site, but they could be made available.

8 University of Missouri Research Reactor Site 

9 The University of Missouri Research Reactor (MURR) alternative site is located in Columbia, 

10 Missouri, approximately 125 mi (201 km) west of St. Louis, Missouri. The MURR alternative site 

11 is located within the MURR Center; the MURR Center occupies a 7.5-ac (3.0-ha) lot in a portion 

12 of the University Research Park, which is part of the University of Missouri (MU) campus and 

13 encompasses the existing research reactor. The production facility would be constructed 

14 immediately south of the MURR Center laboratory building, which houses the research reactor, 

15 on a partially paved parking lot. The paved parking lot within the MURR Center where the 

16 proposed NWMI facility would be constructed is 2.5 ac (1 ha) (NWMI 2016c). The land is 

17 currently zoned for industrial use and utilities are available. Under this alternative, NWMI would 

18 construct a below-ground direct connection between the existing MURR Center and the 

19 proposed NWMI facility (NWMI 2016c).

20 Oregon State University Training, Research, Isotopes, General Atomics (TRIGA) Reactor Site

21 The Oregon State University TRIGA Reactor (OSTR) alternative site is located in Corvallis, 

22 Oregon, approximately 80 mi (129 km) south of Portland, Oregon. The 3-ac (1.2-ha) site is 

23 located adjacent to the Oregon State University (OSU) Radiation Center, immediately to the 

24 east of the OSU TRIGA reactor (NWMI 2016c). Developing the site for the proposed facility 

25 would require relocation of two existing laboratory buildings and rerouting transportation access 

26 to the reactor bay. Utilities are currently available on site.

27 McClellan Business Park Site

28 The McClellan Business Park (McClellan) alternative site is located in McClellan, California, 

29 approximately 10 mi (16 km) north of Sacramento, California. The site includes an existing 

45,000 square feet (ft2

) (4,181 square meters (m2 30 )) building approximately 61 m (200 ft) from 

31 the McClellan Nuclear Research Center, which houses a TRIGA reactor. The site is located 

32 within the McClellan Business Park. The land is currently zoned for industrial use and utilities 

33 are available.

34 5.2.1.2 Secondary Screening

35 To further narrow the range of possible alternatives, NWMI (2015a) conducted a decision 

36 analysis by using a Simple Multi-Attribute Rating Technique, which is based on the U.S. 

37 Department of Energy’s (DOE’s) Guidebook to Decision-Making Methods (DOE 2001). As part 

38 of this process, NWMI developed a set of 10 criteria to score the four potential sites and to 

39 ultimately identify the preferred site (Table 5–1). NWMI evaluated each site for each criteria and 

40 assigned it a score of 1 through 5 depending upon the site’s ability to meet the criteria. NWMI 

41 also weighted each criteria based on its relative importance in terms of NWMI’s business plan. 

42 As part of the business plan, NWMI assumed that no matter the alternative site, NWMI would 

43 transport targets to three RTRs for irradiation, and then transport the irradiated targets back to 

44 the production facility for processing. In addition, NWMI assumed that the majority of irradiation 

45 would occur at MURR (NWMI 2016a and 2016c).
Alternatives

5-4

1 Political and Local Logistic Support

2 NWMI determined that political and local logistical support are important factors in its 

3 site-selection process because local support depends on regional politics, and the importance to 

4 local economic development will likely play a large role in the financial success of the company. 

5 Therefore, NWMI assigned this criteria the highest weight of 10 points. NWMI assigned three 

6 sites, Discovery Ridge, MURR, and OSTR, a score of 4 (weighted score of 40), based on the 

7 high level of State, county, and local support for the proposed project and connections among 

8 NWMI and university reactor staff. McClellan scored the lowest (1, weighted score of 10) 

9 because of the limited State and local support for the proposed project.

10 Facility Operations

11 NWMI assigned facility operations the highest weight (10 points) based on the importance of 

12 NWMI having sole responsibility for operations and for the building design to prevent logistical 

13 complications. NWMI assigned Discovery Ridge a score of 4 (weighted score of 40) because 

14 NWMI would operate the proposed production facility. NWMI assigned MURR a score of 2 

15 (weighted score of 20), based on logistical complications to operate within a smaller space and 

16 because the University of Missouri would require that MURR personnel, rather than NWMI 

17 personnel, manage the facility. NWMI assigned both OSTR and McClellan a score of 3 

18 (weighted score of 30) because NWMI staff would solely manage the facility, although some 

19 land or building design constraints would make operations more constrained.

20 Production Logistics

21 NWMI assigned production logistics the highest weight (10 points) based on the critical role in 

22 minimizing transport time, and the associated (Mo-99) decay, to ensure NWMI delivers the 

23 maximum amount of product to the distributor. NWMI assigned Discovery Ridge and MURR a 

24 score of 4 (weighted score of 40), because target irradiation would primarily occur at MURR, 

25 which would be adjacent to or less than 20 mi (32 km) from the production facility. Thus, for 

26 these two sites, travel time would be minimized between the irradiation facility and the 

27 production facility. For OSTR and McClellan, NWMI assigned a score of 3 (weighted score 

28 of 30) given the longer distance between these two sites and MURR. NWMI assumed that all 

29 sites would have similar processing and product conditioning timeframes.

30 Transportation

31 NWMI assigned transportation a high weight (8 points) because longer transportation routes 

32 would likely be more costly because of the longer transportation time, especially with inclement 

33 weather delays. NWMI assigned MURR and Discovery Ridge a score of 4 (weighted score 

34 of 32), because target irradiation would primarily occur at MURR, which would be adjacent to or 

35 less than 20 mi (32 km) from either site. NWMI assigned OSTR and McClellan a score of 2 

36 (weighted score of 16) and 3 (weighted score of 24), respectively, based on the additional 

37 distance from these two sites to MURR, in which NWMI assumed the majority of irradiation 

38 would occur. Transportation to and from MURR from these sites would also require crossing 

39 significant mountain ranges, which may increase the probability of delays. OSTR is an 

40 additional 200 mi (322 km), or 5 hours of travel time, from MURR than McClellan, which 

41 influenced the lower score for OSTR.

42 Radioactive, Hazardous, and Mixed Secondary Waste Generation

43 NWMI assigned radioactive, hazardous, and mixed secondary waste generation a high weight 

44 (8 points) because the proposed facility must comply with Federal, State, and local radioactive 

45 and hazardous waste requirements, which may vary by State and/or locality. NWMI assigned 

46 McClellan a score of 3 (weighted score of 24) based on the additional State regulatory 
Alternatives

5-5

1 requirements in California for the storage, transportation, and disposal of generated waste. 

2 Disposal costs may also be greater in California. Given the fewer regulatory requirements and 

3 lower disposal costs at the other three sites, NWMI assigned Discovery Ridge, MURR, and 

4 OSTR a score of 4 (weighted score of 32).

5 Federal, State, County, and Local Requirements

6 NWMI assigned Federal, State, county, and local requirements a weight of 5 because NWMI 

7 determined that differences in State, county, and local environmental permitting requirements 

8 could influence the initial start date for operations. NWMI assigned McClellan a score of 3 

9 (weighted score of 15) based on the additional State and local regulatory requirements in 

10 California, such as a State environmental analysis required under the California Environmental 

11 Quality Act. Given the fewer regulatory requirements at the other three sites, NWMI assigned 

12 Discovery Ridge, MURR, and OSTR a score of 4 (weighted score of 20).

13 Federal and State Taxes and Incentives

14 NWMI assigned Federal and State tax and incentives a low weight (3 points) because State and 

15 local taxes, employment hiring credits, and incentives may slightly differ among locations, which 

16 could affect the cost of construction, equipment, and operations. NWMI assigned Discovery 

17 Ridge and MURR a score of 5 (weighted score of 15), based on the low sales and corporate 

18 income taxes (4.225 and 6.25 percent, respectively) and the number of financial incentives 

19 offered in Missouri, such as State-wide programs to reduce taxes for companies creating new 

20 jobs and purchases of new equipment within certain manufacturing facilities, training programs 

21 for new employees, and recruitment assistance. NWMI assigned OSTR a score of 3 (weighted 

22 score of 9) based on the lack of sales tax, moderate corporate income tax (7.6 percent), and 

23 reduced property taxes for the proposed project. NWMI assigned McClellan a score of 1 

24 (weighted score of 3) based on the high sales and corporate income tax (7.75 and 8.84 percent, 

25 respectively), and the lack of reduced property taxes.

26 Available Space

27 NWMI assigned available space a low weight (3 points) because all four sites have the 

28 minimum amount of space required for the production facility, but differences in the available 

29 space could influence NWMI’s ability for future expansion and the complexity of construction 

30 activities. NWMI assigned Discovery Ridge a score of 5 (weighted score of 15) because no 

31 buildings currently occur on the site and space is available for future expansion. NWMI 

32 assigned MURR a score of 3 (weighted score of 9) because future expansion would be limited. 

33 NWMI assigned OSTR a score of 1 (weighted score of 3) because the site is less than 1.0 ha 

34 (2.5 ac) and no future expansion would be available. NWMI assigned McClellan a score of 2 

35 (weighted score of 6) because of limited construction possibilities within the existing building, 

36 although future expansion could occur.

37 Construction Costs

38 NWMI assigned construction costs a low weight (2 points) because local labor rates, materials 

39 costs, and the current site condition could have a small influence on the total construction cost. 

40 NWMI assigned Discovery Ridge a score of 4 (weighted score of 8) because few restrictions 

41 would impede building design and construction. NWMI assigned MURR a score of 3 (weighted 

42 score of 6), based on the higher costs to conduct construction activities within a limited space 

43 and to construct a below-grade connection to the MURR reactor. NWMI assigned OSTR and 

44 McClelland a score of 3 (weighted score of 6) because OSTR has few construction restrictions, 

45 but it may require demolition and reconstruction of existing buildings and also because 

46 McClellan would require structural and mechanical modifications to meet the code within the 

47 existing building.
Alternatives

5-6

1 Natural or Human-Made Disaster Potential

2 NWMI assessed the natural or human-made disaster potential based on Federal Emergency 

3 Management Agency (FEMA) disaster declarations and U.S. Geological Survey (USGS) 

4 seismic activity predictions. NWMI assigned this criterion a low weight (1 point) because each 

5 site is adjacent or close to an existing reactor, which was likely sited in an area with low 

6 potential for natural or human-made disasters. NWMI assigned Discovery Ridge and MURR a 

7 score of 3 (weighted score of 3) because both sites have the most storm, flooding, and tornado 

8 declarations but low-to-no earthquake risk. OSTR received a score of 4 (weighted score of 4) 

9 because the associated county (Benton) had the fewest disaster declarations and 

10 moderate-to-low earthquake risk. McClellan received a score of 2 (weighted score of 2) 

11 because the associated county (Sacramento) had more disaster declarations than OSTR, but 

12 less than Discovery Ridge and MURR, and a higher earthquake risk.

13 Summary

14 NWMI (2015a, 2015c, 2016a) developed 10 site-selection criteria and weighted each criteria 1 

15 through 10, depending upon the relative importance to NWMI’s business plan. Next, NWMI 

16 assigned each site a score of 1 to 5, based on the criteria discussed above. Table 5–1 

17 summarizes these scores.

18 Table 5–1. NWMI Site-Selection Scoring Criteria

(Weight) Discovery 

Ridge

MURR OSTR McClellan

Political and local logistics support (10) 4 4 4 1

Facility operations (10) 4 2 3 3

Production logistics (10) 4 4 3 3

Transportation (8) 4 4 2 3

Radioactive, hazardous, and mixed 

secondary waste generation 

(8) 4 4 4 3

Federal, State, county, and local 

requirements to construct and operate facility

(5) 4 4 4 2

Federal and State tax incentives (3) 5 5 3 1

Available space (3) 5 3 1 2

Construction costs (2) 4 3 3 3

Natural or human-made disaster potential (1) 3 3 4 2

Weighted Total Score1 245 217 190 145

Weighted Percentage2 82% 72% 63% 48%

Notes:

1The weighted total score is the sum of each criteria weight multiplied by each site-specific criteria score.

2The weighted percentage is the site-specific weighted total score divided by the total possible weighted score 

(300).

Source: NWMI 2016a

19 Based on these scores, NWMI selected the Discovery Ridge site, with a total weighted score of 

20 245 out of 300 (82 percent), as the proposed location for the NWMI facility. The three 

21 alternative sites scored lower: MURR (217 total weighted score; 72 percent), OSTR (190 total 
Alternatives

5-7

1 weighted score; 63 percent), and McClellan (145 total weighted score, 48 percent) 

2 (NWMI 2016a). OSTR and McClellan scored lower than Discovery Ridge and MURR primarily 

3 based on the longer transportation routes and more complex production logistics, the lower 

4 State tax and financial incentives and the lack of available space for future expansion. The 

5 NRC staff evaluated the site-selection methodology described above and concluded that the 

6 process for selecting and evaluating alternative sites, including the proposed site at Discovery 

7 Ridge, is reasonable and consistent with guidelines presented in NUREG–1537 and the 

8 associated Interim Staff Guidance (NRC 2012).

9 NEPA requires that an agency analyze a reasonable number of examples, covering the full 

10 spectrum of alternatives, in the EIS (46 FR 18026). Further, Appendix A to 10 CFR Part 51 

11 states that the level of information for each alternative considered will reflect the depth of 

12 analysis required for sound decisionmaking. The NRC staff analyzed one alternative site in 

13 detail given that the proposed site and alternative site likely cover the full spectrum of 

14 alternatives and provide sufficient information for sound decisionmaking based on the relatively 

15 small size of the proposed facility, the limited footprint and excavation required, the use of 

16 county water rather than surface or groundwater for withdrawal or discharge, and the ability to 

17 site the facility within a previously disturbed area. Thus, the NRC staff analyzed the MURR 

18 alternative site in detail below.

19 5.2.2 University of Missouri Research Reactor Alternative Site

20 The NRC staff evaluated the MURR site in detail as a reasonable alternative. The MURR site is 

21 a 3.0 ha (7.5 ac) lot located in Columbia, Missouri, within Boone County, approximately 125 mi 

22 (201 km) west of St. Louis, Missouri (Figure 5–1; NWMI 2016c). Specifically, the site is located 

23 on the University of Missouri Campus, within the MURR Center. NWMI would construct a new 

24 production facility immediately south of the existing research reactor on a partially paved 

25 parking lot. An external waste management building, a diesel generator building, and the 

26 Radioisotope Production Facility (RPF) building would be constructed on the 2.5-ac (1-ha) 

27 paved parking lot within the MURR Center (NWMI 2016c) and would collectively cover 

approximately 66,150 ft2 (6,145 m2 28 ). There would be one offsite location at an existing building 

29 (the University of Missouri Life Science Incubator Building) across the street from the MURR 

30 Center that would house the administrative building, including offices and conference rooms, but 

31 no new construction would be required (NWMI 2016c). Research Park Drive and South 

32 Providence Road provide access to the site. Irradiation of low-enriched uranium (LEU) targets 

33 would be carried out at MURR, OSTR, and a third reactor. The impacts as a result of irradiation

34 of LEU targets at these three research reactors is discussed in Section 4.13 of the EIS.
Alternatives

5-8

1 Figure 5–1. Cities and Major Roadways Transportation 

2 near the University of Missouri Research Reactor Alternative Site

3

4 5.2.2.1 Land Use and Visual Resources 

5 Land Use

6 The MURR site includes 7.5 ac (3.0 ha) of land within the southwestern portion of the City of 

7 Columbia (Figure 5–1; NWMI 2016c). The site is currently zoned for light industrial use and is 

8 part of the University Research Park (City of Columbia 2012, 2016i; NWMI 2015c). The 

9 University Research Park includes several industrial buildings used for research or commercial 

10 purposes (NWMI 2015a). A few deciduous trees occur on site, although most appear to have 

11 been planted for ornamental purposes (NRC 2015c). No prime farmland or farmland of 

12 Statewide importance, active mines or quarries, military reservations, Federally designated wild 

13 and scenic rivers, national parks, national forests, Federally designated coastal zone areas, or 

14 Federal lands held in trust for an American Indian tribe occur on the MURR site (NWMI 2015a; 

15 Find the Data 2016; NRCS 2016a, 2016b; NOAA 2016).
Alternatives

5-9

1 Immediately surrounding the MURR site (within a 0.6-mi (1-km) radius), the majority of the land 

2 is owned by the University of Missouri, including three sporting venues: Memorial 

3 Stadium/Faurot Field (62,000 seats), Mizzou Arena (15,061 seats), and Hearnes Center 

4 (13,300 seats). The A.L. Gustin Golf Course is west of the MURR site and Epple Field, which 

5 includes the University of Missouri tennis facilities, is south of the MURR site.

6 Within a 5-mi (8-km) radius of the MURR site, a variety of land uses occur, including residential, 

7 light industrial, commercial, and forested areas. Several City and State parks occur within the 

8 vicinity, including multiple recreational trails (NWMI 2015a; NRC 2015b).

9 Construction

10 Construction at the MURR site would occur within an existing parking lot (NWMI 2015a, 2015c). 

11 Because the site is already zoned for industrial use and existing building have supported 

12 research for several decades, no change in zoning or land use would occur.

13 Impacts on land use from construction would be SMALL, given that no change in land use or 

14 zoning would occur, and no special land uses or mineral resources occur within the MURR site.

15 Operations

16 Operation of the NWMI facility would not require any new land or require land use changes 

17 beyond those required for construction. Therefore, impacts on land use during operations 

18 would be SMALL.

19 Decommissioning

20 Decommissioning activities would be similar to construction activities because they would 

21 involve heavy equipment to dismantle buildings and remove roadway and parking facilities. 

22 Land requirements to perform these activities would be similar to those required during 

23 construction. After decommissioning activities are complete, the MURR site would likely remain 

24 industrial because it is part of the University Research Park. Given that land requirements 

25 would be similar to those described during construction, and that after decommissioning is 

26 complete the land would likely remain industrial, the NRC staff determined that the impacts on 

27 land use during decommissioning would be SMALL.

28 Visual Resources

29 The visual setting of the area that would be affected by the proposed NWMI facility at the MURR 

30 site is primarily a light industrial viewshed (NWMI 2015a; NRC 2015b). In addition, trees are 

31 visible in many directions (NWMI 2015a; NRC 2015b).

32 Construction

33 The activities associated with constructing the proposed NWMI facility (e.g., excavation, 

34 earthmoving, pile driving, and erecting the facility) would require large pieces of construction 

35 equipment, which may alter the appearance of the existing landscape because construction 

36 equipment is not typically visible on the MURR site. However, the MURR site has low scenic 

37 quality caused by a lack of notable features, uniform landform, low vegetation diversity, an 

38 absence of water, mute colors, cultural modifications to adjacent scenery, and a commonality 

39 within the physiographic province. The MURR site also has a low-to-moderate sensitivity rating 

40 because it is in an area with low scenic values and a lack of special natural and wilderness 

41 areas. In addition, the viewshed surrounding the MURR site is aesthetically altered by light 

42 industrial buildings, such as research facilities. In addition, NWMI (2015a) stated that the RPF 

43 building would be designed to blend in with the architecture of the existing facilities on the 

44 MURR site. Based on the light industrial viewshed, the low scenic quality and sensitivity ratings, 
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1 construction-related aesthetic impacts of the proposed NWMI facility at the MURR site would be 

2 SMALL during construction.

3 Operations

4 After the facility is constructed, the appearance of the NWMI facility at the MURR site would not 

5 change during operations, other than a small steam plume that may be visible from the exhaust 

6 stack. The steam plume from the exhaust stack is expected to be minimal, because opacity 

7 associated with the natural-gas-fired boiler tends to be low, as a result of emissions described in 

8 Section 4.2.1.1. The steam plume would be more visible during periods of cold weather, 

9 although the size of the steam plume would still be relatively small. Therefore, visual impacts 

10 during operations of the proposed NWMI facility at the MURR site would be SMALL.

11 Decommissioning

12 Decommissioning activities would be similar to construction activities because they would 

13 require heavy equipment to dismantle buildings and remove roadway and parking facilities. 

14 After decommissioning activities are complete, the MURR site would likely remain industrial 

15 because it is part of the University Research Park. Given that the facility would be located in a 

16 district zoned for light industrial use and the viewshed surrounding the MURR site is 

17 aesthetically altered by light industrial buildings, the NRC staff would not expect any changes to 

18 the landscape during decommissioning to significantly affect any viewsheds. Therefore, visual 

19 impacts during decommissioning of the proposed NWMI facility at the MURR site would be 

20 SMALL.

21 5.2.2.2 Air Quality and Noise

22 Air Quality

23 The MURR site is located in Boone County, Missouri. The climate at this MURR site is similar 

24 to what was described in Section 3.2.1 for the Discovery Ridge site. Boone County is part of the 

25 Northern Missouri Intrastate Air Quality Control Region (40 CFR 81.116). With regard to the 

26 National Ambient Air Quality Standards (NAAQS) criteria pollutants, Boone County is 

27 designated unclassifiable/attainment for all criteria pollutants (40 CFR 81.326). Therefore, 

28 criteria air pollutant concentrations in the County are lower than NAAQS or there is insufficient 

29 data to determine if the NAAQS are met. The nearest Class I Federal area to the proposed site 

30 is the Hercules-Glades Wilderness Area in Bradleyville, Missouri, approximately 140 mi 

31 (225 km) away. The region of influence (ROI) for the air quality analysis discussed below is 

32 Boone County, because air quality designations are made at the county level.

33 Construction

34 Sources of air pollutant emissions during construction at the MURR site would include fugitive 

35 dust from earth-moving equipment, non-road vehicles, and worker and delivery vehicles. 

36 Earth-moving activities, including excavation, clearing, and compacting, will generate fugitive 

37 dust on site. Operation of construction equipment will emit criteria pollutants (particulate matter, 

38 carbon monoxide, sulfur dioxide, and nitrogen oxides) on site from the combustion of fuels in 

39 equipment. Employee and delivery and shipment vehicular exhaust will emit criteria air 

40 pollutants (particulate matter, carbon monoxide, sulfur dioxide, and nitrogen oxides). Air 

41 emissions would be similar to those estimated and presented in Table 4–3 for the Discovery 

42 Ridge site, because construction activities and parameters would be similar (i.e., construction 

43 duration, and number of worker vehicles, land disturbance and excavation, and building 

44 footprint). Since the MURR site is centered on an existing paved parking lot, additional 

45 equipment (e.g., track drill, cold planer) to remove existing paved surfaces may be needed to 

46 prepare the site for construction. However, use of this equipment will be short term during the 
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1 beginning of site preparation. Therefore, construction air emissions at the MURR site would be 

2 similar to estimated emissions presented in Table 4–3. Overall construction-related emissions 

3 for criteria pollutants are well below the significant de minimis levels discussed under the New 

4 Source Review program and major source threshold emissions (see Section 3.2.2). Total 

5 greenhouse gas emissions (GHGs) (approximately 27,000 tons of carbon dioxide equivalent 

6 (CO2eq) per year) would be well below the 75,000 tons/year (TPY) of CO2eq (68,000 metric 

7 TPY) threshold for prevention of significant deterioration (PSD) and Title V permits set in the 

8 Greenhouse Gas (GHG) Tailoring Rule and EPA’s mandatory GHG Tailoring Rule 

9 (74 FR 56260). Therefore, the NRC staff does not expect increases in air emissions from 

10 construction activities at the MURR site to contribute to concentrations that would exceed 

11 NAAQS in Boone County. Given that air emissions during construction would be local and 

12 temporary (17 months), that Boone County is designated as an attainment/unclassifiable area, 

13 that construction emissions are well below the significant de minimis levels, and that 

14 construction emissions are not expected to contribute to concentrations that would exceed the 

15 NAAQS, the NRC staff concludes that air quality impacts during construction at the MURR site 

16 would be SMALL.

17 Operations

18 Air emissions sources from operation of the proposed NWMI facility would be predominantly 

19 from: (1) target preparation and irradiated target processing, (2) fuel combustion associated 

20 with processing and facility heating, and (3) vehicular traffic from commuting workers and from 

21 transportation of shipments and deliveries during operations. Air emissions would be similar to 

22 those estimated for the proposed Discovery Ridge site, because the operational activities and 

23 the number and type of sources would be similar (number of worker vehicles, fuel combustion 

24 sources, and target preparation and processing activities). Therefore, air emissions would 

25 include nitrogen oxides, sulfur dioxide, particulate matter, carbon monoxide, and carbon dioxide 

26 and would be similar to what is presented in Table 4–4. Based on these estimated emissions, 

27 the NRC staff does not expect emissions from operation of the NWMI facility at the MURR site 

28 to contribute to concentrations that would exceed NAAQS or that would deteriorate Boone 

29 County’s unclassifiable/attainment designation. Given that NAAQS are not expected to be 

30 exceeded and that Boone County is designated unclassifiable/attainment, the NRC staff 

31 concludes that air quality impacts during operation at the MURR site would be SMALL.

32 Decommissioning

33 Decommissioning activities would include earth-moving equipment, demolition of structures, and 

34 dismantlement and decontamination of systems over a period of up to 24 months 

35 (NWMI 2015a, 2016a). Equipment, worker vehicles, and truck shipments will emit criteria air 

36 pollutants (particulate matter, carbon monoxide, sulfur dioxide, and nitrogen oxides) and GHGs. 

37 Demolition and dismantlement of structures will emit fugitive dust. Air emissions would be 

38 similar to those estimated for the proposed Discovery Ridge site, because the decommissioning 

39 activities would be similar. Therefore, air emissions would include nitrogen oxides, sulfur 

40 dioxide, particulate matter, carbon monoxide, and carbon dioxide and would be similar to what 

41 is presented in Table 4–5. Projected emissions are well below the significant de minimis levels 

42 discussed under the New Source Review program in Section 3.2.2 of this EIS. Therefore, the 

43 NRC staff does not expect increases in air emissions from decommissioning activities to 

44 contribute to concentrations that would exceed NAAQS or prevent Boone County from 

45 maintaining attainment designation. The NRC staff concludes that air quality impacts from 

46 decommissioning at the MURR site would be SMALL.
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1 Noise 

2 Existing noise sources near the MURR site include vehicular traffic along South Providence 

3 Road (Route 63), cooling towers associated with MURR, and sports venues (within 0.3 mi 

4 (0.48 km) of MURR). Noise-sensitive receptors within 1 mi (1.6 km) of the MURR site include:

5 • residence, approximately 0.47 mi (0.76 km) north of the MURR site;

6 • golf course, approximately 0.09 mi (0.14 km) west of the MURR site;

7 • hospital, approximately 0.80 mi (1.3 km ) northeast of the MURR site;

8 • University of Missouri research buildings, 0.1 mi (0.16 km ) northeast of MURR site; 

9 and

10 • MURR, immediately adjacent to MURR site.

11 The NRC staff did not identify the existence of any ambient noise surveys for the MURR site 

12 and vicinity. At 5-ft (1.5-m) distance from MURR’s cooling towers noise levels can reach 

13 71 A-weighted decibels (dBA) (Lenntech undated). Typical noise levels at 15 m (50 ft) from a 

14 highway such as Route 63 can reach 70 dBA (FHWA 2003). The MURR site is located within 

15 the University Research Park; therefore, the NRC staff estimates background noise levels of 65 

16 to 70 dBA, which are typical of commercial areas. The ROI for the noise analysis discussed 

17 below is 1 mi (1.6 km) from the MURR site.

18 Construction

19 Noise sources associated with building the proposed NWMI facility will include construction 

20 equipment on site and workforce and shipment/delivery vehicles. Increased traffic volumes 

21 because of 82 workers and 21 deliveries per week can increase noise emissions along nearby 

22 access roads to the MURR site and will depend on the increase in traffic from current 

23 conditions. Access to the MURR site is from South Providence Road (Route 63) and Research 

24 Park Drive. In 2013, the annual average daily traffic volume traffic count along South 

25 Providence Road (at the Stadium Boulevard intersection) was 29,940 (1,247 vehicles per hour) 

26 (MODOT 2013). Sound levels increase at a rate of 3 dBA per doubling of traffic volumes and an 

27 increase of 3 dBA is barely noticeable. Conservatively assuming that all worker vehicles and 

28 deliveries travel on South Providence Road at the same time, a traffic volume of 

29 1,350 vehicles/hr will result. This increase in traffic will not result in any noticeable increased 

30 noise levels.

31 The types of equipment that would be used on the MURR site during construction would include 

32 those listed in Table 4–2 and additional equipment (e.g., track drill) to remove the existing paved 

33 surfaces. Noise emissions from equipment that will be used during construction are predicted to

34 be in the 80- to 85-dBA range at a 50 ft (80 km) distance (FHWA 2006). At 0.14 km (0.09 mi), 

35 noise will attenuate to 61 to 65 dBA and at 0.76 km (0.47 mi), distance to the nearest residence, 

36 noise will attenuate to 46 to 51 dBA. However, because of the proximity to the existing MURR 

37 building from the construction site, noise levels at MURR can reach 80-85 dBA, which would be 

38 noticeable. Background noise levels are assumed to be 65 to 70 dBA. A 10-dBA increase is 

39 subjectively perceived as a doubling in loudness and almost always causes an adverse 

40 community response (FHWA 2011). Although building walls of the MURR laboratory building 

41 may dampen the construction equipment noise levels, the increase in noise levels would be 

42 noticeable. Given noise levels from construction equipment and distance to noise-sensitive 

43 receptors, the NRC staff estimate that noise impacts from construction at the MURR site would 

44 be SMALL to MODERATE.
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1 Operations

2 Noise sources during operation would be primarily from workforce and shipment vehicles. 

3 Noise from operating equipment would be contained inside buildings and is not anticipated to be 

4 audible outside the proposed NWMI building at the MURR site. Increased traffic volumes 

5 because of a daily workforce of 98 and 16 deliveries per week can increase noise emissions

6 along South Providence Road and will depend on the relative increase in traffic volume. 

7 Conservatively assuming that all worker vehicles and deliveries travel on South Providence 

8 Road at the same time, this will result in a traffic volume of 1,361 vehicles/hr. Sound levels 

9 increase at a rate of 3 dBA per doubling of traffic volumes and an increase of 3 dBA is barely 

10 noticeable. This increase in traffic from 1,246 vehicles per hour to 1,361 vehicles/hr will not 

11 result in noticeable noise levels.

12 Given that noise levels from operating equipment are not expected to be audible beyond the 

13 building facility and additional noise levels from worker and shipment vehicles are not 

14 anticipated to be noticeable, the NRC staff concludes that noise impacts during operation would 

15 be SMALL.

16 Decommissioning

17 Noise emissions during decommissioning would be similar to those generated during 

18 construction. Increased noise levels would occur from increased traffic volumes and from the 

19 use of equipment on site. A daily peak workforce of 81 and a total of 21 deliveries and 

20 shipments per week are anticipated during decommissioning. Sound levels increase at a rate of 

21 3 dBA per doubling of traffic volumes and an increase of 3 dBA is barely noticeable. 

22 Conservatively assuming that all worker vehicles and deliveries travel on South Providence 

23 Road at the same time, the additional traffic along South Providence Road should not be 

24 noticeable.

25 As discussed above, under construction, noise levels from construction equipment at MURR 

26 can reach 80 to 85 dBA, which would be noticeable. During decommissioning, equipment 

27 similar to construction activities would be used and similar noise levels are assumed during 

28 decommissioning activities. Therefore, given the expected noise levels during decommissioning 

29 and the distance to noise sensitive receptors, the NRC staff estimate that noise impacts from 

30 decommissioning at the MURR site would be SMALL to MODERATE.

31 5.2.2.3 Geologic Environment

32 Site Geology, Soils, and Seismic Setting

33 The alternative site for the proposed NWMI facility is in the University Research Park within the

34 existing MURR Center (NWMI 2016c). The MURR Center, and alternate site, are located within 

35 the Dissected Till Plains section of the Central Lowland province (MDNR 2002a). Landforms 

36 within this physiographic section are the product of glacial action as modified by post-glacial 

37 geomorphological processes, as further described in Section 3.3.1 of this EIS.

38 MURR and the University of Missouri campus are located in an area known locally as the 

39 Columbia dissected uplands (MU 2006). The MURR site is located on a relatively flat plain 

40 adjacent to a stream valley that was incised into the glacial strata. The MURR site lies at an 

41 elevation of approximately 615 ft (187 m) above mean sea level (MSL) (Figure 5–2).

42 While glacial drift deposits are prevalent in the eastern half of Boone County, residuum 

43 (weathered bedrock material) is the predominant bedrock cover over the western half of the 

44 County. The MURR site is mapped as residuum (unit J). This unit is a tan to reddish-brown 

45 gravelly clay and silty clay, which developed from limestone and shale bedrock. The total 

46 thickness of this bedrock cover normally ranges from 1 to 20 ft (0.3 to 6 m) thick and is typically 
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1 covered by a layer of loess and/or glacial drift. Across the University Research Park, mapping 

2 shows that the total depth of this cover is as much as 25 ft (7.6 m) deep (MGS 2016). Specific 

3 to the MURR site, these surficial deposits also likely include alluvium of Holocene age 

4 associated with Hinkson Creek (MU 2006).

5 The uppermost bedrock units underlying the site belong to the Osagean series of Mississippian 

6 age (345 to 359 million years ago). These rocks are characterized as very cherty, crystalline, 

7 and fossiliferous limestones (MU 2006). Geologic mapping shows that the specific bedrock unit 

8 beneath the site is Burlington-Keokuk limestone (MGS 2016). The Burlington Limestone is as 

9 much as 160 ft (49 m) thick in the Columbia area. This bedrock unit is relatively soluble and, 

10 where it outcrops at the surface, it is susceptible to karst development, as further described in 

11 Section 3.3.1 for the Discovery Ridge site (MU 2006). However, geologic mapping shows that 

12 the nearest karst features are approximately 3.5 mi (5.6 km) south of the MURR site 

13 (MGS 2016).

14 Older Devonian age limestones and sandstones are relatively thin or absent in the Columbia 

15 area; nevertheless, Ordovician age carbonate strata are well represented, including the 

16 Jefferson City Dolomite and the Rubidoux Formation. Cambrian age carbonates underlie the 

17 Ordovician strata and include the Eminence and Potosi Dolomites (MU 2006; Miller and 

18 Appel 1997).

19 The horizontal sedimentary strata underlying the MURR site exhibit little deformation, and the 

20 Columbia area is relatively free of faults, folds, and other major structural features (MU 2006). 

21 There are no mapped geologic faults or other significant geologic features within 5 mi (8 km) of 

22 the site. The closest geologic fault structure is the Fox Hollow fault, as further described in 

23 Section 3.3.1. The northern end of this fault is located approximately 6.5 mi (10.5 km) 

24 southeast of the MURR site. There has been no movement on this fault since the Paleozoic Era 

25 and it does not constitute an earthquake hazard. Evidence for active and recurrent faulting, 

26 along with associated seismic activity, can be found in eastern and southeastern Missouri and in 

27 southern Illinois, as further described in Section 3.3.1 of this EIS and referenced below. The 

28 most significant seismologic features are associated with the New Madrid Seismic Zone 

29 (MU 2006).

30 Geologic resources, encompassing rock and mineral (fuel and nonfuel) resources, from 

31 geologic strata in the Columbia area have historically included limestone and coal, as well as 

32 sand and gravel deposits, which are widely available, from glacial and floodplain materials 

33 throughout Boone County (MDNR 2001; USGS 2015c). A former limestone quarry is located 

34 about 0.4 mi (6 km) south of the MURR site and a former coal mining operation is located 

35 approximately 0.6 mi (1 km) southwest of the site (MGS 2016).

36 Soil unit mapping by the Natural Resources Conservation Service (NRCS) identifies the natural 

37 soils across the MURR site as predominantly Weller silt loam, bench, 2 to 5 slopes 

38 (NRCS 2016c). Where not otherwise mixed or replaced with fill material that may have been 

39 placed in conjunction with the construction of MURR, soils in this mapping unit are mainly silt 

40 loams occupying stream terraces. They are moderately well-drained, deep soils that developed 

41 from parent materials consisting of loess deposits over stream alluvium. The depth to the water 

42 table in these soils generally ranges from 24 to 48 in. (61 to 122 cm) (NRCS 2016c).
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1 Figure 5–2. Topographic Map of the MURR Site and Vicinity

2

3 Source: Modified from USGS 2015a

4 Natural soils across the MURR site are rated as somewhat limited for building site development 

5 and excavation work primarily due to the depth to the saturated zone and clay shrink/swell 

6 potential. The soils have slight limitations due to instability of excavation walls (caving). The 

7 soils meet the classification criteria of prime farmland soils as defined in the Farmland 
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1 Protection Policy Act of 1981 (7 U.S.C. 4201 et seq.) and implementing regulations 

2 (7 CFR Parts 657, 658). However, because the site and vicinity is developed and otherwise 

3 committed to urban development, the site is exempt from Farmland Protection Policy Act 

4 provisions (7 CFR 658.2 and 658.3).

5 Northeast Missouri and the MURR site are located within a relatively stable region of the 

6 continent, as further described in Section 3.3.3. While the area is not immune to seismic 

7 activity, the intensities of Midcontinent earthquakes are generally mild, although they are usually 

8 felt over wide areas (MU 2006). Earthquake sources in southeast Missouri, associated with the 

9 New Madrid Seismic Zone, are the primary driver of earthquake hazard in northeast Missouri. 

10 The New Madrid Seismic Zone and the earthquake history for northeast Missouri, 

11 representative of the MURR site, are described in Section 3.3.3 of this EIS.

12 Over the last 40 years, a total of 99 earthquakes with a magnitude equal to or greater than 2.5 

13 have occurred within a radius of 200 mi (322 km) of the MURR site. The vast majority of these 

14 earthquakes had epicenters more than 90 mi (140 km) to the east and south in association with 

15 the Wabash Valley and New Madrid seismic zones, respectively. The closest of these events 

16 occurred on July 31, 2005 near Tipton, Missouri, approximately 25 mi (40 km) southwest of the 

17 MURR site. The earthquake had a magnitude of 3.3 and produced MMI III to IV (weak to light) 

18 shaking near the epicenter, but it was not generally felt north of the Missouri River into Boone 

19 County (USGS 2016c).

20 Section 3.3.3 of this EIS presents information on predicted earthquake ground motions across 

21 central Boone County based on the USGS’s latest seismic hazard mapping data. NWMI 

22 performed a preliminary seismic design analysis to assess the potential maximum earthquake 

23 ground motions in consideration of site-specific soil conditions (i.e., for a stiff soil profile (Site 

24 Class D)) (see Section 3.3.3). The NRC staff will further evaluate the potential maximum 

25 earthquake and other seismic design considerations in the safety evaluation report (SER)

26 related to the NWMI construction permit application.

27 Construction

28 Ground-disturbing activities associated with facility construction would have impacts on geologic 

29 and soil resources similar to those discussed for the Discovery Ridge site (Section 4.3.1). 

30 Earthwork requirements and the ease of excavation would generally be similar, with a few 

31 exceptions. To prepare the site for facility construction, NWMI would first need to remove 

32 existing hardscape including asphalt and concrete associated with a parking lot, walkways, and 

33 curb and gutter. It is also likely that some existing utilities lines would need to be relocated. 

34 These activities would entail additional earthwork and could possibly lengthen the construction 

35 timeframe at this site. The site’s loamy, alluvial soils are typically suitable to build on and 

36 engineer (e.g., grade and compact). The shrink/swell potential of site soils is moderately 

37 favorable for site development purposes with only slight limitations and risk for impacting 

38 building foundations and concrete surfaces.

39 Excavations at the site could be prone to slumping because of the potential for saturated soils 

40 and seasonally high water table conditions, as similarly discussed for the Discovery Ridge site. 

41 These conditions could require the use of bracing in trenches and other measures 

42 (e.g., cofferdams) during construction of the below-grade portion of the facility. The potential for 

43 soil erosion and loss would be similar to the Discovery Ridge site. However, as described in 

44 Section 4.3.1, adherence to standard best management practices (BMPs) for soil erosion and 

45 sediment control and stormwater runoff management, and compliance with the provisions of a 

46 Land Disturbance Permit from the City of Columbia, would serve to minimize soil erosion and 

47 loss. In consideration of these points, the NRC staff finds that the impacts on the geologic 

48 environment from the construction of the NWMI facility at the MURR site would be SMALL.
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1 Operations

2 There would be no incremental impact on the geologic environment from facility operations at 

3 the MURR site. Following construction, exposed soils would no longer be subject to erosion

4 because they would lie beneath buildings or other impervious surfaces, with areas outside those 

5 areas restored to a vegetated or landscaped condition.

6 Regardless of the site location, the final design and construction of the NWMI facility would have 

7 to comply with all applicable building codes and standards, which provide for the evaluation of 

8 site geologic and soil conditions, including potential seismic hazards. Thus, the NRC staff 

9 concludes that the operational impacts associated with the geologic environment at the MURR 

10 site would be SMALL.

11 Decommissioning

12 Facility demolition and other ground-disturbing activities associated with decommissioning 

13 would have impacts on soils and underlying sediments and geologic strata similar to those 

14 described in Section 4.3.3 for the Discovery Ridge site. Site decommissioning activities would 

15 be conducted in accordance with a decommissioning plan submitted to the NRC and in 

16 compliance with applicable local, State, and Federal regulations and permits. Therefore, the 

17 NRC staff finds that the impacts on the geologic environment from facility decommissioning at 

18 the MURR site would be SMALL.

19 5.2.2.4 Water Resources

20 Surface Water Hydrology, Quality, and Use

21 The MURR site is located within the Hinkson Creek watershed. Hinkson Creek is a major 

22 tributary to Perche Creek, which flows to the Missouri River. The MURR site is located slightly 

23 less than 8 mi (13 km) northeast of the Missouri River at its closest point. In total, the Hinkson 

Creek watershed drains 81 mi2 (210 km2 24 ) and roughly bisects the City of Columbia in a 

25 northeast to southwest direction, and it serves as the major stormwater drainage basin for the 

26 City of Columbia. Together with the MURR site, all the properties belonging to the University of 

27 Missouri drain either directly or indirectly to Hinkson Creek and ultimately to the Missouri River 

28 (MU 2006).

29 While no natural surface water drainages exist on the MURR site, a stormwater drainage 

30 system serves the MURR site and adjoining university properties. This system generally 

31 consists of an open system of swales and culverts (MU 2006). The MURR property drains 

32 generally south toward Hinkson Creek, which is located approximately 0.2 mi (0.3 km) south of 

33 the site.

34 From just south of the site (Figure 5–2), Hinkson Creek flows generally in a west to southwest 

35 direction over a sinuous course for approximately 7.6 stream mi (12.1 km) (4 linear mi (6.4 km)) 

36 from the MURR site to its confluence with the southward-flowing Perche Creek near the 

37 Columbia Regional Wastewater Treatment Plant (WWTP). Perche Creek continues flowing 

38 southwest before turning south and then southeast, paralleling the Missouri River, for a total of 

39 about 11 stream mi (17.7 km) before entering the river at a point approximately 8 mi (12.9 km) 

40 southwest of the MURR site.

41 The USGS maintains a gaging station on Hinkson Creek just downstream from the Highway 163 

42 bridge (Station 06910230) at South Providence Road, approximately 0.25 mi (0.4 km) southeast 

43 of the MURR site. The mean annual discharge measured at this site for the period of record 

44 (water years 1967 through 2015) is 62.3 cubic feet per second (cfs) (1.76 cubic meters per 

second (m3

/s)). The highest peak flow was 14,200 cfs (401 m3 45 /s) on April 30, 2009. For water 

year 2015, the mean discharge was 112.7 cfs (3.18 m3 46 /s). The mean 90-percent exceedance 
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flow is 0.4 cfs (0.011 m3 1 /s) for the period of record. The 90 percent exceedance flow is an 

2 indicator value of hydrologic drought. It signifies a rate of streamflow that is equaled or

3 exceeded 90 percent of the time, as compared to the average flow for the period of record. 

4 Based on average monthly flow over the period of record at the station, August is the low-flow 

5 month, and April is the high-flow month for Hinkson Creek (USGS 2016d).

6 The Federal Emergency Management Agency has delineated the floodplain boundary for 

7 Hinkson Creek, which runs south of the site. The MURR site is mapped as outside the 500-year 

8 flood elevation. However, the location of the proposed NWMI facility site on the MURR site is 

9 located less than 500 ft (152 m) north of the delineated 100-year floodplain (base flood elevation 

10 605 ft (184 m)) (FEMA 2011b). The University of Missouri (MU 2006) states that the existing 

11 MURR laboratory building is about 200 ft north of the 100-year floodplain at its closest point.

12 In accordance with Section 303(c) of the Federal Water Pollution Control Act (i.e., Clean Water 

13 Act (CWA)) of 1972, as amended), states have the primary responsibility for establishing, 

14 reviewing, and revising water quality standards for the Nation’s navigable waters. As further 

15 discussed in Section 3.4.1.2, the State of Missouri, like other states, has established water 

16 quality standards, numeric criteria, and associated designated use categories for all waters of 

17 the State, including jurisdictional wetlands. In summary, all perennial rivers and streams, 

18 streams with permanent pools, and lakes and reservoirs that intersect the flow lines of perennial 

19 rivers and streams are designated for the following beneficial uses: aquatic habitat protection, 

20 human health protection, whole body contact recreation, and secondary contact and livestock 

21 and wildlife protection and irrigation (10 CSR 20-7.031). These uses apply to Hinkson Creek 

22 and other major streams within a 5-mi (8-km) radius of the MURR site, including Perche Creek.

23 CWA Section 303(d) requires states to identify all “impaired” waters for which effluent limitations 

24 and pollution control activities are not sufficient to attain water quality standards in such waters. 

25 As more fully described in Section 3.4.1.2 of this EIS, states prepare a 303(d) “list” that 

26 comprises those water quality limited stream segments that require the development of total 

27 maximum daily loads (TMDLs) to assure future compliance with water quality standards. Once 

28 established, states implement TMDLs through watershed-based programs, primarily through the 

29 National Pollutant Discharge Elimination System (NPDES permit program in accordance with 

30 CWA Section 402.

31 The lower reaches of Hinkson Creek downstream of the MURR site are included in the State of 

32 Missouri’s 303(d) list (MDNR 2014a, 2015a). The Missouri Department of Natural Resources

33 (MDNR) continues to list Hinkson Creek as impaired for whole body contact recreation due to 

34 water-borne E. coli bacteria. The reason for listing is impairment of the beneficial use due to 

35 nonpoint source runoff.

36 Groundwater Hydrology, Quality, and Use

37 Groundwater beneath the MURR site and the south Columbia area of Boone County occurs in 

38 unconsolidated and consolidated water-bearing deposits (aquifers). USGS broadly recognizes 

39 a surficial aquifer system and two bedrock aquifer systems in northeast Missouri, as described 

40 in Section 3.4.2.1. In general, the hydrogeology of the south Columbia area and the MURR site 

41 is similar to the Discovery Ridge site.

42 The overlying glacial drift, where present, produces only limited quantities of water in the 

43 Columbia area. Still, both the Mississippian and the underlying Cambrian-Ordovician aquifer 

44 systems are present beneath the site. Within the Mississippian system, the Burlington 

45 Limestone yields mainly hard water through shallow wells that is adequate to support rural 

46 domestic uses. Within the upper Ordovician age strata, the Jefferson City Formation is the 

47 principal water-bearing unit in the Columbia area. This formation averages 400 ft (122 m) thick 
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1 and produces moderate quantities of water. It has been the most widely used unit for rural 

2 domestic supply (MU 2006).

3 Most notably, the Ordovician and Cambrian bedrock units, particularly the sandstone and 

4 dolomitic units, yield considerable water to deep wells in the Columbia area. These units are 

5 part of the Cambrian-Ordovician aquifer system (see Section 3.4.2.1). This system is about 

6 1,300 ft (400 m) thick in the Columbia area, at depths ranging from approximately 150 to 400 ft 

7 (46 to 122 m) below ground surface (bgs). Two of the deepest formations of significance are 

8 the Eminence and Potosi Dolomites, which can produce well yields ranging from 400 to 

1,100 gallons per minute (gpm) (1.5 to 4.2 cubic meters per minute (m3 9 /min)) (MU 2006). The 

10 NRC staff’s review of available MDNR well logs for the area within a 2-mi (3.2-km) radius of the 

11 MURR site indicate that the depth to the Ordovician strata is marked by the Cotter Dolomite at 

12 depths of approximately 200 to 300 ft (60 to 90 m) bgs (MGS 2016; MDNR 2016e).

13 The MDNR maintains extensive geospatial data, including data extracted from well driller logs 

14 submitted to the State. Available MDNR data indicate that the static water level in the 

15 uppermost aquifer across the south Columbia area ranges between 600 and 625 ft (183 and 

16 190 m) MSL. The approximate depth to groundwater (as measured from the land surface) in 

17 the area ranges between 90 and 100 ft (27 to 30 m) bgs (MGS 2016). Depth to groundwater 

18 would be less within the incised stream valleys, such as Hinkson Creek. In addition, the NRC 

19 staff expects that shallow groundwater also occurs within the stream alluvium and other 

20 unconsolidated sediments in proximity to Hinkson Creek, which runs just to the south and 

21 southwest of the site.

22 Groundwater is used extensively and almost exclusively across Boone County, as summarized 

23 in Section 3.4.2.2. Historically, the City of Columbia relied on a system of deep wells for public 

24 water supply. Declines in well production and other factors prompted the City to install a new 

25 well field in 1972 within the alluvial aquifer of the Missouri River floodplain (known as the 

26 McBaine Bottoms) (MU 2006; City of Columbia and MDNR 2013). The well field is located 

27 approximately 7 mi (11 km) southwest of the MURR site (MGS 2016). This production system 

28 consists of 15 alluvial wells installed to a depth of about 110 ft (33 m) in the bottom alluvium. 

29 The system has a total groundwater production capacity of 30 million gallons per day (mgd) 

(113,560 cubic meters per day (m3 30 /day)). Groundwater is pumped to the City’s nearby McBaine 

31 water plant, where it is treated by aeration, softening, filtration, and finally by disinfection before 

distribution. The City of Columbia’s average groundwater use is 12.6 mgd (47,700 m3 32 /day) 

33 (City of Columbia 2016c).

34 The City maintains four deep wells as emergency backup water sources (MU 2006; City of 

35 Columbia and MDNR 2013). These wells average 1,320 ft (402 m) in depth. They have 

produced groundwater yields ranging from 700 to 1,200 gpm (2.6 to 4.5 m3 36 /min) from the 

37 Eminence and Potosi Dolomites. The closest of these wells is approximately 2.3 mi (3.7 km) 

38 northwest of the existing MURR laboratory building (MU 2006).

39 The University of Missouri, through its Campus Facilities Department, maintains its own system 

40 of deep wells to supply potable water across the university, including providing water supply to 

41 the existing MURR Center. Five supply wells comprise the production system. These wells 

42 have depths ranging from 1,200 to 1,415 ft (366 to 431 m). The combined rated production 

capacity of the wells is 4,700 gpm (17.8 m3 43 /min) (MU 2006, 2016a). This is equivalent to 

6.77 mgd (25,630 m3

/day). In 2014, university water use averaged 1.74 mgd (6,590 m3 44 /day) 

45 (MU 2015).
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1 Construction

2 Facility construction activities at the MURR site would not have any direct impact on surface 

3 water resources because no natural watercourses originate within the boundaries of the site. 

4 Stormwater drainage ditches deliver stormwater from the site south toward Hinkson Creek, 

5 which is located approximately 0.2 mi (0.3 km) south of the site. As at the Discovery Ridge site, 

6 the potential does exist for shallow groundwater to occur south of the existing MURR main 

7 building and beneath the proposed NWMI facility site. This would require groundwater 

8 dewatering during construction, as further described and evaluated in Section 4.4.2.1. If NWMI 

9 were to select this alternative site, it would commission site-specific geotechnical and hydrologic 

10 studies to assess shallow groundwater conditions and to guide any necessary construction 

11 accommodations and final facility design.

12 As discussed above in Section 5.2.2.3 for construction and detailed in Section 4.3.1.1 for the 

13 Discovery Ridge site, ground-disturbing activities would be subject to a Land Disturbance Permit 

14 from the City of Columbia as well as a State of Missouri NPDES general permit (i.e., Missouri 

15 State Operating Permit MO-RA) for the discharge of stormwater from land-disturbance sites. 

16 The development application package for the Land Disturbance Permit would require NWMI to 

17 develop and implement a soil erosion and sediment control plan and a stormwater management 

18 plan. These plans entail the implementation of construction-related BMPs for soil erosion and 

19 sediment control and stormwater pollution prevention during site development, facility 

20 construction, and for post development. Further, the NPDES general permit similarly requires 

21 the development and implementation of a stormwater pollution prevention plan (SWPP) to 

22 prevent the introduction of sediment and other pollutants in stormwater discharges.

23 Under CWA Section 401, an applicant for a Federal license or permit to conduct any activities, 

24 including facility construction or operation, that may cause a discharge into navigable waters is 

25 required to provide the Federal licensing agency with a certification from the state or agency 

26 having jurisdiction in which the discharge would originate. This water quality certification 

27 signifies that discharges from the project or facility to be licensed by the Federal agency will 

28 comply with CWA requirements and will not cause or contribute to a violation of state water 

29 quality standards. A Federal agency cannot issue a license or permit to an applicant until the 

30 required certification is provided, or the responsible state or agency has waived the 

31 requirement. The NRC recognizes that some NPDES-delegated states explicitly integrate their 

32 401 certification process with NPDES permit issuance. The State of Missouri regulations for 

33 administering its water quality certification process are at 10 CSR 20-6.060.

34 The only regulated direct discharges from the proposed facility involve stormwater associated 

35 with construction activity. As referenced above, NWMI would obtain coverage under a 

36 State-issued NPDES general permit for such discharges. Permit provisions are intended to 

37 ensure that the State’s water quality standards are met. NWMI has stated that no State 

38 certification is required under CWA Section 401 (NWMI 2015a). NWMI also has stated that it 

39 would seek a waiver from the State (NWMI 2015c). However, because the NRC cannot issue a 

40 construction permit without the required certification, NWMI must provide the NRC with either a 

41 401 certification from the State of Missouri, a waiver, or other State documentation that a 

42 Section 401 certification is not necessary. During construction, water would be required for 

43 such uses as dust control, soil compaction, as well as to meet the drinking and sanitary needs 

44 of the construction workforce during the construction period. NWMI would not use surface 

45 water or onsite groundwater to support facility construction at the site. Instead, the NRC staff 

46 expects that the University of Missouri campus water utility (Campus Facilities Department) that 

47 currently provides water to the existing MURR Center would supply water to the NWMI facility 

48 site. Water could be supplied during construction by trucking it to the point of use or through a 

49 portable water tap from a nearby service line or hydrant, until a permanent water service line is 
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1 constructed. Construction activities would require an average of 6,140 gallons per day (gpd) 

(23,200 liters per day (Lpd)) of water, equivalent to 0.006 mgd (23 m3 2 /day). This projected daily 

3 demand is a very small percentage (i.e., about 0.34 and 0.12 percent) of the University’s 

4 existing demand and available production capacity, respectively. Wastewater generation would 

5 be limited to sanitary waste from the construction workforce and would likely be accommodated 

6 using portable restroom facilities.

7 No natural surface water features occur on the site, and NWMI would not divert or withdraw 

8 surface water or onsite groundwater during construction. NWMI would also be subject to 

9 compliance with City and State permits, including an NPDES general permit for the discharge of 

10 stormwater from a land-disturbance site. Therefore, the NRC staff concludes that the impacts 

11 on surface water and groundwater hydrology, water quality, and water use from the construction 

12 of the NWMI facility at the MURR site would be SMALL.

13 Operations

14 Normal facility operations would not have any direct impact on surface water or groundwater 

15 hydrology or quality. Stormwater runoff from the proposed NWMI facility at the MURR site 

16 would also be managed by an engineered stormwater management system, including 

17 necessary detention/retention structures, constructed and operated in compliance with 

18 applicable local, State, and Federal stormwater management permits, plans, procedures, and 

19 practices, as discussed in Sections 4.4.1.2 and 4.4.2.2 for the Discovery Ridge site.

20 There would be no radioactive liquid effluents released from the facility because the RPF portion 

21 of the facility is designed to have zero liquid discharge. NWMI would conduct all material, 

22 chemical, and waste handling activities within the confines of the NWMI facility, precluding any 

23 releases to the environment, including soils and groundwater. The only liquid waste stream 

24 discharged from the facility would be sanitary wastewater at an average rate of approximately 

25 4,570 gpd (17,300 Lpd). NWMI would discharge this wastewater to the City of Columbia

26 Sanitary Sewer Utility, which also receives effluent from the existing MURR Center (MU 2006). 

27 The Columbia Regional WWTP provides treatment of the sanitary wastewater discharged into 

28 the sewer system, and the WWTP has excess treatment capacity available. The effluent would 

29 be required to meet the system’s influent acceptance and treatment criteria, as well as NRC’s 

30 regulations at 10 CFR 20.2003 (see Section 4.4.1.2).

31 Water use for facility operations would require an average of 5,045 gpd (19,100 Lpd) of water, 

equivalent to 0.005 mgd (18.9 m3 32 /day), as previously described in Section 4.4.2.2 for the 

33 Discovery Ridge site. A service connection from the University of Missouri campus water utility 

34 would provide water to the NWMI facility. Similar to the projected water needs for construction, 

35 the NWMI facility’s projected operational water needs are a small percentage (i.e., about 0.29 

36 and 0.1 percent) of the University’s existing water supply demand and available production 

37 capacity, respectively.

38 The proposed NWMI facility would not divert or withdraw surface water or onsite groundwater to 

39 support facility operation at the MURR site because the University of Missouri’s campus utility 

40 would provide water supply. There would be no discharge of industrial or radiological effluents 

41 to surface water or groundwater, and the NWMI facility operations would need to comply with 

42 local, State, and Federal stormwater management permits, plans, procedures, and practices. 

43 Accordingly, the NRC staff concludes that the impacts on surface and groundwater hydrology, 

44 water quality, and water use from the operation of the NWMI facility at the MURR site would be 

45 SMALL.
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1 Decommissioning

2 Facility decontamination, demolition, and site-restoration activities would be similar, regardless 

3 of the site, with the potential magnitude of the impacts on surface water and groundwater similar 

4 to those discussed for construction. The NRC staff expects that a State-issued NPDES general 

5 permit would be required for the discharge of stormwater from land-disturbance sites. NWMI 

6 would conduct site activities in accordance with appropriate BMPs and would observe waste 

7 handling and pollution prevention practices and response procedures during decommissioning, 

8 such that no materials or contaminants are released to soils, surface water, or underlying 

9 groundwater.

10 As previously referenced for the Discovery Ridge site (see Section 4.4.2.3), NWMI would 

11 conduct decommissioning work and activities in accordance with a decommissioning plan 

12 submitted to the NRC. NWMI would be required to conduct necessary surveys of the soils and 

13 subsurface to comply with the NRC’s radiological criteria for license termination in 

14 10 CFR Part 20, Subpart E. The NRC staff also expects that NWMI would sample soils and 

15 other media as necessary in accordance with other required local and State permits and 

16 approvals to ensure that no nonradiological contamination remains in excess of action levels.

17 Some water would be required for dust control and soil compaction during decommissioning 

18 (Section 4.4.2.3). NWMI estimates that decommissioning activities would require an average of 

2,000 gpd (7,600 Lpd) of water, equivalent to 0.002 mgd (7.6 m3 19 /day) during the 24-month 

20 decommissioning period. The NRC staff assumes that the University of Missouri campus water 

21 utility would also supply water for decommissioning. The projected water volume is less than 

22 the volume required for facility construction, as discussed above, and the impacts on supply 

23 capacity would similarly be negligible.

24 Given that no natural surface water features occur on the MURR site, that water requirements 

25 would be minimal, and that NWMI would develop and implement stormwater pollution 

26 prevention and spill response procedures as part of local and State permit requirements for 

27 ground-disturbing activities, the NRC staff concludes that the impacts on water resources from 

28 facility decommissioning would be SMALL.

29 5.2.2.5 Ecological Resources

30 The MURR facility complex consists of 7.5 ac (3.0 ha) of existing buildings, parking lots, a few 

31 deciduous trees, and some ornamental grasses and shrubs (NWMI 2015a and NWMI 2016c; 

32 NRC 2015b). The MURR site provides habitat for birds, mammals, amphibians, reptiles, and 

33 other wildlife tolerant of human-modified landscapes, and frequent disturbances from human 

34 activity. Birds and wildlife may use the MURR site to feed on vegetation, as a temporary resting 

35 location, or while traveling among other habitats. Therefore, species would likely be similar to 

36 those described in Section 3.5.3 for the proposed Discovery Ridge site. Wildlife that require 

37 dense stands of trees, native plants, shrubs, or uncultivated grasses would not use the 

38 proposed site because of the lack of forested areas, wetlands, and native grasslands.

39 No water bodies or aquatic habitats exist within the boundaries of the MURR site. The MURR 

40 site drains generally south toward Hinkson Creek, which is located approximately 0.2 mi 

41 (0.3 km) south of the site.

42 The NRC staff determined that the Federal and State-listed species that have the potential to 

43 exist within the MURR site are the same as those that have the potential to occur on the 

44 proposed Discovery Ridge site. The NRC staff made this determination based on FWS’s online 

45 database (FWS 2016), the Missouri Department of Conservation’s (MDC’s) description of 

46 State-listed species (MDC 2000a, 2000b, 2016b), and the NWMI ER (NWMI 2015a). The NRC 

47 staff reviewed the habitat requirements for these species and determined that no suitable 
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1 habitat for any of the State endangered or Federally listed species occur on the MURR site 

2 (see Table 3–11). The NRC staff did not observe any Federally listed or State-endangered 

3 species on the MURR site during the site audit (NRC 2015b).

4 The FWS also administers the Migratory Bird Treaty Act (16 U.S.C. 703–712), which prohibits 

5 anyone from taking native migratory birds or their eggs, feathers, or nests. FWS (2015a, 2016) 

6 determined that the same migratory birds likely use the proposed Discovery Ridge site and the 

7 MURR site given their proximity to one another and because both sites have been heavily 

8 modified by human activities. In the vicinity of the site, migratory birds rely on riparian, forested, 

9 grassland, and wetland habitats as important areas for foraging, resting, avoiding predators, 

10 and, for some species, breeding. On the MURR site, migratory birds likely use trees for resting 

11 and possibly for limited foraging.

12 Construction

13 Construction of the NWMI facility would occur within a paved parking lot that provides minimal, if 

14 any, habitat to species highly tolerant of human activity (NWMI 2015a). Noise from construction 

15 activities could disturb birds and wildlife. In response to such disturbances, birds and wildlife 

16 could move out of the immediate area and find adequate, similar habitat within the vicinity.

17 During construction, bird collisions with construction equipment and the new facility could result 

18 in mortality from the presence of tall structures (e.g., stacks or cranes) and artificial night lighting 

19 during nighttime construction. The size of structures and the likelihood of mortality from bird 

20 collisions would be similar to that described in Section 4.5 for the proposed Discovery Ridge 

21 site. In that analysis, the NRC staff determined that impacts from bird collisions would be 

22 negligible and unlikely to affect local or migratory populations, based on previous reviews of bird 

23 collisions at nuclear power plants that are similar or larger in height and size than the proposed 

24 NWMI facility.

25 Construction at the MURR site is not expected to result in any direct impacts on aquatic 

26 resources, such as habitat loss, because no aquatic resources would be within the footprint of 

27 the proposed facility or the construction laydown areas. Runoff from the site could affect offsite 

28 aquatic resources by increasing turbidity or introducing various chemicals or other pollutants. 

29 However, impacts on aquatic resources are expected to be minimal because of the distance to 

30 Hinkson Creek, and NWMI would be required, in its stormwater permit, to use appropriate soil

31 erosion and sediment control BMPs.

32 Given that construction would not permanently or temporarily affect any high-quality habitats, 

33 such as grasslands, undisturbed forests, or wetlands; that permanently and temporarily affected 

34 habitats are abundant within the region; that mortality from bird collisions is expected to be 

35 negligible; and that no State-endangered or Federally listed species are likely to occur on the 

36 site, the NRC staff concludes that impacts on ecological resources during construction of the 

37 proposed NWMI facility at the MURR site would be SMALL.

38 Operations

39 During operations, impacts on ecological resources could result from bird collisions, herbicide 

40 applications for landscape maintenance activities, elevated noise levels, and increased turbidity 

41 or introduction of pollutants from runoff. As described in Section 4.5, mortality from bird 

42 collisions is expected to be negligible, given that the tallest structure would be a stack 

43 approximately 75 ft (23 m) tall. Disturbance from daily activities, herbicide applications, or 

44 elevated noise levels is likely to have minimal impacts on wildlife and plant species, given that 

45 the species identified at the MURR site are tolerant of disturbance, because of current 

46 operations at the existing research reactor and other nearby educational facilities. In response 
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1 to any disturbances during operations, birds and wildlife could move out of the immediate area 

2 and find adequate, similar habitat within the vicinity.

3 Operation of the facility is not expected to result in any direct impacts on aquatic resources, 

4 because wastewater would be not be discharged to any waterbody (NWMI 2015a). Indirect 

5 impacts during operations could include runoff that may contain sediments, contaminants from 

6 road and parking surfaces, or herbicides. However, as described above, impacts on aquatic 

7 resources are expected to be minimal because of the distance to Hinkson Creek, and NWMI 

8 would be required, in its stormwater permit, to use appropriate soil erosion and sediment control 

9 BMPs.

10 Given that mortality from bird collisions is expected to be negligible, that habitat disturbances 

11 during operations would be minimal, that any disturbed wildlife could find similar habitat in the 

12 vicinity, that BMPs would be required in the NWMI stormwater permit, and that no Federally or 

13 State-listed species occur on the MURR site, impacts on ecological resources during operations 

14 of the proposed NWMI facility at the MURR site would be SMALL.

15 Decommissioning

16 Decommissioning activities would have similar impacts on those that occur during construction. 

17 For example, NWMI would use construction equipment to dismantle large buildings, which could 

18 result in disturbances to wildlife and birds and potential runoff to nearby water bodies. In 

19 addition, some land on the site could be used as staging areas for the equipment and to 

20 conduct certain dismantling activities. As described above, if noise or other activities disturb 

21 birds or wildlife, similar habitat is available in nearby offsite areas. No surface water would be 

22 used during decommissioning, and NWMI would develop and implement spill prevention and 

23 response procedures as part of State permit requirements for ground-disturbing activities. 

24 Therefore, impacts during decommissioning of the proposed NWMI facility at the MURR site are 

25 expected to be SMALL.

26 5.2.2.6 Historic and Cultural Resources

27 The general cultural background and chronological sequence of human occupation at the 

28 MURR site and vicinity would be the same as that described for the Discovery Ridge Research 

29 Park site in Section 3.6.1. The NWMI facility would be located on previously disturbed land 

30 adjacent to the south side of the existing University of Missouri Laboratory and Reactor 

31 Containment Buildings, colloquially known as the “Laboratory Building” (MU 2010; 

32 NWMI 2015c). The Laboratory Building was originally constructed in 1964 and is located on a 

33 7.5 ac (3 ha) plot of land within the larger University Research Park, an 84 ac (34 ha) tract 

34 approximately 1 mi (1.6 km) southwest of the main campus. During MURR Center’s original 

construction, trees were removed from the site and approximately 15,000 yd3 (11,500 m3 35 ) of fill 

36 was deposited on the south and central portions of the site. Several additions and a new 

37 building have subsequently been constructed at this location (MU 2006, 2010).

38 A review of databases maintained by the National Park Service indicates that there are 

39 50 properties listed in the National Register of Historic Places (NHRP) in Boone County, with 

40 the vast majority of them located in and around Columbia. However, no historic properties are 

41 located on the 7.5 ac (3 ha) MURR Center (NWMI 2015a). The nearest property on the NRHP 

42 list is the Sanford F. Conley House, which is located on the University of Missouri main campus 

43 about 1 mi (1.6 km) north-northeast of the existing MURR Center (MU 2006, 2010). The view 

44 from the Sanford F. Conley House of the MURR site is obstructed by trees and campus 

45 properties.

46 No archeological survey was commissioned by NWMI for the MURR site. However, a review of 

47 state archaeological records conducted by the University of Missouri in 2010 found no evidence 
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1 of archaeological sites on the 7.5 ac (3 ha) MURR site. The nearest recorded archaeological 

2 site was identified approximately 1,000 ft (300 m) northeast of the existing MURR Center 

3 (MU 2010).

4 Construction

5 Construction would maintain previously disturbed paved and open space in industrial use. 

6 Since no historic properties (36 CFR 800.4(d)(1)) would be affected and no archaeological sites 

7 or evidence of cultural resources have been identified during previous archaeological reviews, 

8 historic and cultural resources are not likely to be impacted by the construction of the proposed 

9 NWMI facility at the MURR site. Construction of the NWMI facility would also have little or no 

10 visual impact as discussed in Section 5.2.2.1. The nearest NRHP site, the Sanford F. Conley 

11 House, is about 1 mi (1.6 km) away to the north-northeast, and its view is obstructed by trees 

12 and campus properties. Based on these factors, construction of the NWMI facility would not 

13 impact any known historic and cultural resources at the MURR site.

14 Operations

15 Because no historic properties (as defined by 36 CFR 800.4(d)(1)) would be affected and no 

16 archaeological sites or evidence of cultural resources have been identified during previous 

17 archaeological reviews, historic and cultural resources would not likely be impacted during 

18 NWMI facility operations at the MURR site. The completed NWMI facility would also have little 

19 or no visual impact. The nearest NRHP site, the Sanford F. Conley House, is about 1 mi 

20 (1.6 km) away to the north-northeast, and its view is obstructed by trees and campus properties. 

21 Based on these factors, operation of the NWMI facility would not impact any known historic and 

22 cultural resources at the MURR site.

23 Decommissioning

24 Because no historic properties (as defined by 36 CFR 800.4(d)(1)) would be affected and no 

25 archaeological sites or evidence of cultural resources have been identified during previous

26 archaeological reviews, historic and cultural resources would not likely be impacted during the 

27 decommissioning of the NWMI facility operations at the MURR site. Decommissioning of the 

28 NWMI facility would also have little or no visual impact. The nearest NRHP site, the Sanford F. 

29 Conley House, is about 1 mi (1.6 km) away to the north-northeast, and its view is obstructed by 

30 trees and campus properties. Based on these factors, decommissioning of the NWMI facility 

31 would not impact any known historic and cultural resources at the MURR site. 

32 5.2.2.7 Socioeconomics

33 The MURR site and the Discovery Ridge site share the same socioeconomic ROI. Both are 

34 located in the City of Columbia, Boone County, Missouri. The number of workers needed to 

35 construct, operate, and decommission the proposed NWMI facility at the MURR site would be 

36 the same or similar. The description of the affected environment and the socioeconomic 

37 impacts of constructing, operating, and decommissioning the proposed NWMI facility at the 

38 MURR site would be the same as described for the Discovery Ridge site in Sections 3.7 

39 and 4.7. Therefore, the socioeconomic impacts from constructing, operating, and 

40 decommissioning the proposed NWMI facility at the MURR site would be SMALL.

41 5.2.2.8 Human Health

42 Construction

43 Construction of the proposed NWMI facility at the MURR site would be essentially the same as 

44 construction at the Discovery Ridge site. There would be no significant differences in the design 

45 of the RPF building of the facility, with the exception of a below-grade corridor constructed 

46 between the RPF building of the facility and the existing MURR basement (NWMI 2015a, 
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1 2016c). The MURR basement is an area is which construction workers could potentially be 

2 exposed to radiation. Construction workers working in this area would be considered 

3 occupational radiation workers, and radiological controls and monitoring would be put into place 

4 to protect construction workers and to ensure that construction workers’ occupational worker 

5 dose would be maintained within 10 CFR Part 20 limits; however, NWMI expects that, due to 

6 the controls used, no measureable radiation dose would be received by the construction 

7 workers (NWMI 2016c). Construction workers for a facility at the MURR site would be exposed 

8 to similar physical occupational hazards as construction workers at the Discovery Ridge site, 

9 and any chemical exposure to workers or members of the public would also be similar. All 

10 occupational or material hazards would be controlled to ensure compliance with all applicable 

11 Federal and State regulations (NWMI 2015a). In Section 4.8.1 of this EIS, the NRC staff 

12 concluded that the radiological and nonradiological human health impacts from construction of 

13 the proposed NWMI facility at the Discovery Ridge site would be SMALL. Because there are no 

14 significant differences in construction or facility design except for the below-grade corridor, and 

15 because any potential hazards associated with construction would continue to be subject to 

16 Federal and State of Missouri regulations, the NRC staff concludes that the human health 

17 impacts from construction of the proposed NWMI facility at the MURR site would also be 

18 SMALL.

19 Operations

20 The operation of the proposed NWMI facility at the MURR site would also be essentially the 

21 same as operation at the Discovery Ridge site.

22 Radiological human health factors associated with an NWMI facility at the MURR site, including 

23 radiation sources, radioactive effluents, worker doses, and dose mitigation measures, would be 

24 the same as they would be for an NWMI facility at the Discovery Ridge site (NWMI 2015a). As 

25 stated in Section 4.8.2.1, NWMI estimated that the dose to the maximally exposed offsite 

26 member of the public from radioactive effluents emitted during operation of the proposed facility 

27 at the Discovery Ridge site would be 3.6 millirem (mrem) per year. This dose would be received 

28 by an individual located at the site boundary, 30 ft (9.1 m) from the facility stack at the Discovery 

29 Ridge site (NWMI 2016a). NWMI expects that the nearest distance to the site boundary from 

30 the facility stack would not vary by more than a few meters compared with the Discovery Ridge 

31 site, and that the dose to a member of the public at the site boundary for routine radioactive 

32 effluent releases would not change significantly for the MURR alternative site relative to the 

33 Discovery Ridge site (NWMI 2016c). A facility at the MURR site would continue to be subject to 

34 the NRC’s dose limits in 10 CFR Part 20.

35 Due to the proximity of an NWMI facility at the MURR site to MURR, the NRC staff assumes 

36 that no public highway transportation of unirradiated or irradiated LEU targets between the 

37 NWMI facility and MURR would be needed. However, the NRC staff assumes that doses from 

38 transportation of targets between the NWMI facility and the other two research reactors (OSTR 

39 and a third reactor) would be very similar for an NWMI facility located at either site due to the 

40 proximity of the MURR site and Discovery Ridge site.

41 Nonradiological human health factors associated with an NWMI facility at the MURR site, 

42 including chemicals and hazardous materials present at the site, nonradioactive effluents, 

43 potential chemical exposures to workers and/or the public, physical occupational hazards, and 

44 mitigation measures for nonradiological human health impacts, would also essentially be the 

45 same as they would be for an NWMI facility at the Discovery Ridge site. All occupational or 

46 material hazards would be controlled to ensure compliance with all applicable Federal and State 

47 regulations (NWMI 2015a).
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1 In Section 4.8.2 of this EIS, the NRC staff concluded that the radiological and nonradiological 

2 human health impacts from operation of the proposed NWMI facility at the Discovery Ridge site 

3 would be SMALL. Because there are no significant differences in facility design or operation, 

4 and because any potential radiological or nonradiological hazards associated with operation 

5 would continue to be subject to Federal and State of Missouri regulations, the NRC staff 

6 concludes that the human health impacts from operation of the proposed NWMI facility at the 

7 MURR site would also be SMALL.

8 Decommissioning

9 Since the design and operation of the proposed NWMI facility at the MURR site would be similar 

10 to that at the Discovery Ridge site, and the general characteristics of the two sites are also 

11 similar, the NRC staff expects that the decommissioning of the proposed facility at the MURR 

12 site would also be similar to that at the Discovery Ridge site. Any occupational, chemical, or 

13 radiological hazards to workers and/or the public would be similar, and would be required to be 

14 in compliance with all applicable Federal and State of Missouri regulations. In Section 4.8.3 of 

15 this EIS, the NRC staff concluded that the radiological and nonradiological human health 

16 impacts from decommissioning of the proposed NWMI facility at the Discovery Ridge site would 

17 be SMALL. Because there would be no significant differences in facility decommissioning, and 

18 because any potential radiological or nonradiological hazards associated with decommissioning 

19 would continue to be subject to Federal and State of Missouri regulations, the NRC staff 

20 concludes that the human health impacts from decommissioning of the proposed NWMI facility 

21 at the MURR site would also be SMALL.

22 5.2.2.9 Waste Management

23 Construction, operations, and decommissioning of the proposed NWMI facility at the MURR site 

24 would be essentially the same as at the Discovery Ridge site. The NRC staff expects that there 

25 would be no physical differences between the design of the facilities that would change the 

26 types or volumes of radiological or nonradiological wastes generated during construction, 

27 operations, or decommissioning of the proposed facility at the MURR site. The disposal 

28 pathways for radioactive waste produced by an NWMI facility at the MURR site would be the 

29 same as for a facility at the Discovery Ridge site (NWMI 2016a). The distance that radioactive 

30 waste produced during operations or decommissioning would need to be transported to reach a 

31 disposal site would be effectively the same for either site. In addition, because of the proximity 

32 of the MURR site to the Discovery Ridge site and the similar waste disposal infrastructure, the 

33 NRC staff expects disposal pathways for nonradioactive waste (including hazardous waste) at 

34 the MURR site to be similar to the Discovery Ridge site. All waste management activities at an 

35 NWMI facility at the MURR site would be required to comply with all applicable Federal, State, 

36 and local regulations.

37 In Section 4.9 of this EIS, the NRC staff concluded that impacts from radioactive and 

38 nonradioactive waste management during construction, operations, and decommissioning of the 

39 proposed NWMI facility at the Discovery Ridge site would be SMALL. Because there would be 

40 no significant differences in waste management, and because waste management would 

41 continue to be subject to Federal, State, and local regulations, the NRC staff concludes that the 

42 impacts from waste management of the proposed NWMI facility at the MURR site during 

43 construction, operations, and decommissioning would also be SMALL.
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1 5.2.2.10 Transportation

2 Affected Environment

3 Figure 5–1 shows major roads and transportation features in the vicinity of the MURR site. The 

4 MURR site is located within the City of Columbia limits. Research Park Drive provides direct 

5 access to the site.

6 Research Park Drive intersects with old Route K and South Providence Road (Missouri 

7 Route 163), a four-lane roadway in Boone County, about 0.15 mi (0.25 km) to the east. 

8 The MURR site has direct easy access to Route 163. Route 163’s northern terminus is at 

9 U.S. Interstate 70/U.S. Route 40 (I-70/US 40) in Columbia; its southern terminus is at 

10 U.S. Highway 63 south of Columbia. Route 163 also intersects with Stadium Boulevard 

11 (Missouri Route 740) approximately 0.6 mi (1 km) to the north. Route 740 intersects with 

12 U.S. Highway 63, 2.3 mi (3.7 km), to the east. U.S. Highway 63 continues to Jefferson City, 

13 Missouri, 31 mi (50 km) to the south. U.S. Interstate 70 proceeds approximately 125 mi 

14 (201 km) east to St. Louis, Missouri, and 125 mi (201 km) west to Kansas City, Missouri. 

15 Current average daily traffic volumes for nearby roads is listed in Table 5–2.

16 Table 5–2. Average Daily Traffic Counts in the Vicinity of the MURR Site 2013

Road Section Average Daily Traffic

Route 163 South of I-70 21,114

I-70 East of Route 163 66,297

I-70 West of Route 163 73,758

Route 163 South of Route 740 29,802

Route 740 East of Route 163 31,151

Route 740 At U.S. Highway 63 21,965

U.S. Highway 63 North of Route 740 47,234

U.S. Highway 63 South of Route 740 45,006

Route 163 North of Grindstone Parkway 26,900

Grindstone Parkway East of Route 163 to U.S. Highway 63 35,142

Source: MODOT 2013

17 Impact Analysis

18 This section describes potential transportation impacts during the construction, operations, and 

19 decommissioning of the proposed NWMI facility at the MURR site. The impact analysis 

20 considers changes in traffic volumes on the existing roadway network. The number of workers

21 and truck deliveries and shipments needed to construct, operate, and decommission the NWMI 

22 facility at the MURR site would be the same or similar as the Discovery Ridge site.

23 Construction

24 Similar to construction at Discovery Ridge, transportation impacts would be caused by an 

25 increase in commuter vehicles and construction trucks on local roads. Construction workers

26 would arrive via site access roads and traffic volumes on these roads would increase during 

27 shift changes. In addition, trucks would deliver construction equipment and material to the work 

28 site and remove construction waste material, thus adding to traffic volumes on site access 
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1 roads. The increase in vehicular traffic would peak during certain hours of the day (e.g., shift 

2 changes), resulting in temporary levels of service impacts and possible delays at intersections.

3 During construction, an average daily workforce of 38 workers would be commuting to and from 

4 the work site for 17 months. During peak construction, up to 82 workers could be commuting 

5 daily to the construction site. In addition, an average of 20 trucks per week (4 trucks per day) 

6 would deliver construction equipment and material to the work site. An additional 1 truck per 

7 week would remove construction waste (NWMI 2015a, 2015c).

8 Due to the small size of the average daily workforce, the low number of daily truck deliveries 

9 and shipments combined with the short duration of construction (17 months) and easy access to 

10 Route 163, there would be little if any noticeable traffic volume-related level of service impacts. 

11 Therefore, transportation impacts during the construction of the proposed NWMI facility at the 

12 MURR site would be SMALL.

13 Operations

14 Transportation impacts occurring during operation of the proposed NWMI facility would be 

15 caused by an increase in commuter vehicles and delivery trucks on local roads. Operations 

16 workers would arrive via site access roads and traffic volumes on these roads would increase 

17 during shift changes. In addition, trucks would deliver production material, ship products, and 

18 remove waste material, thus adding to the traffic volumes on site access roads. The increase in 

19 vehicular traffic would peak during certain hours of the day (e.g., shift changes), resulting in 

20 temporary levels of service impacts and possible delays at intersections.

21 During operations, 98 workers would be commuting to and from the MURR site (NWMI 2015a). 

22 In addition, an average of 2 to 4 trucks per week would deliver nonradioactive material; an 

23 average of 2 to 3 trucks per week would deliver irradiated LEU targets; and another two trucks 

24 per year would deliver fresh LEU (NWMI 2015a, 2016a).

25 In addition, outbound truck traffic would include the following:

26 an average of 1 truck shipment per week of LEU targets to irradiation facilities,

27 an average of 2 shipments per week of medical isotope product through the 

28 Columbia Regional Airport,

29 an average of 3 to 4 shipments per week of waste, and

30 an average of 2 truck shipments per year of take back LEU (NWMI 2015c, 2016a).

31 Medical isotope product shipments to customers would be transported from the NWMI facility by 

32 truck to the Columbia Regional Airport, over 13 mi (21 km) away. Radioactive and 

33 nonradioactive waste would also be transported by common truck carrier from the NWMI facility 

34 to an offsite storage, treatment, or disposal facility.

35 The relatively small size of the workforce and low number of daily truck deliveries and 

36 shipments would generate little if any noticeable traffic volume-related level of service impacts. 

37 Therefore, given the size of the operations workforce, the number of trucks, and easy access to 

38 Route 163, transportation impacts during NWMI facility operations at the MURR site would be 

39 SMALL.

40 Decommissioning

41 Transportation impacts occurring during decommissioning would be caused by an increase in 

42 commuter vehicles and trucks on local roads. Decommissioning workers commuting to the 

43 work site would arrive via site access roads and traffic volumes on these roads could increase 

44 during shift changes. In addition, trucks would deliver equipment and material to the work site 
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1 and remove waste material, thus adding to traffic volumes on site access roads. The increase 

2 in vehicular traffic would peak during certain hours of the day (e.g., shift changes), resulting in 

3 temporary levels of service impacts and possible delays at intersections.

4 During construction, an average daily workforce of 38 workers would be commuting to and from 

5 the work site for 18 to 24 months. During peak decommissioning activities, up to 81 workers 

6 could be commuting daily. In addition, an average of 1 truck per week would deliver equipment 

7 and material to the work site. An additional 20 trucks per week would remove construction 

8 waste (NWMI 2015a).

9 The small size of the average daily workforce, the low number of daily truck deliveries and 

10 shipments combined with the short duration of decommissioning (18 to 24 months) and easy 

11 access to Route 163, there would be little if any noticeable traffic volume-related level of service 

12 impacts. Therefore, transportation impacts during the decommissioning of the proposed NWMI 

13 facility at the MURR site would be SMALL.

14 5.2.2.11 Accidents

15 The design and operation of the proposed NWMI facility constructed at the MURR site would be 

16 essentially the same as it would be for a facility constructed at the Discovery Ridge site 

17 (NWMI 2015a). Therefore the NRC staff expects that the quantities of radionuclides and 

18 hazardous chemicals that could be released during a possible radiological or chemical accident, 

19 as well as any safety features to prevent or mitigate chemical or radioactive material releases 

20 during any accident, would also be the same. The distances from the nearest publicly 

21 accessible locations (along the facility fence line) to the radiological and chemical accident 

22 release points would also be similar for the MURR alternative site and the Discovery Ridge site 

23 (NWMI 2016c). For a proposed NWMI facility at the Discovery Ridge site, the nearest 

24 permanent residence would be approximately 430 m (0.27 mi) away; for a facility constructed at 

25 the MURR site, the nearest resident would be approximately 762 m (0.47 mi) away 

26 (NWMI 2015a).

27 In Section 4.11.1 of this EIS, the NRC staff concluded that the impacts from potential 

28 radiological accidents for the proposed NWMI facility constructed at the Discovery Ridge site 

29 would be SMALL. For a proposed NWMI facility at the MURR site, the location of the nearest 

30 resident would change, but the NRC staff expects that the maximum offsite accident dose to 

31 any member of the public, and the point where the maximum offsite dose would be received 

32 relative to the location of the facility, would not change significantly (as the quantity of 

33 radiological material released would be the same, and weather or other factors that could affect 

34 dispersion of radioactive materials would be very similar). The population density of individuals 

35 living and working around both sites would also be similar (NWMI 2015a). Therefore the 

36 unmitigated consequences of radiological accidents for members of the public would be very 

37 similar for a proposed NWMI facility at either site. The unmitigated consequences for NWMI 

38 facility staff would also be very similar or identical. The NRC staff expects that a proposed 

39 NWMI facility at the MURR site would use similar engineering and administrative controls to 

40 reduce the consequences and likelihood of accidents that an NWMI facility at the Discovery 

41 Ridge site would. Given the similarity of potential radiological accidents for a proposed NWMI 

42 facility at the MURR site to radiological accidents for a facility at Discovery Ridge, and given the 

43 similar number and distribution of members of the public near either site, if the NRC staff 

44 determines in its SER that the proposed NWMI facility at Discovery Ridge would comply with 

45 10 CFR 70.61 and any other NRC regulations applicable to radiological accident consequences, 

46 then the NRC staff concludes that the impacts from potential radiological accidents for a 

47 proposed NWMI facility located at the MURR site would also be SMALL.
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1 In Section 4.11.2 of this EIS, the NRC staff concluded that the impacts from potential hazardous 

2 chemical accidents for the proposed NWMI facility constructed at the Discovery Ridge site 

3 would be SMALL. For potential chemical accidents at the proposed NWMI facility at Discovery 

4 Ridge, NWMI determined that the highest chemical exposures would occur along the facility 

5 fence line, which is the nearest location to the facility accessible by members of the public. 

6 Given that the nearest location accessible to the public would be similar for a facility at the 

7 MURR site, and that the quantity of hazardous chemicals released would be the same, the 

8 unmitigated consequences of chemical accidents for members of the public would be very 

9 similar for an NWMI facility at either site. The unmitigated consequences for NWMI facility staff 

10 would also be very similar or identical. The NRC staff expects that a proposed NWMI facility at 

11 the MURR site would use similar engineering and administrative controls to reduce the 

12 consequences and likelihood of accidents compared to an NWMI facility at the Discovery Ridge 

13 site. Given the similarity of potential hazardous chemical accidents for a proposed NWMI facility 

14 at the MURR site to hazardous chemical accidents for a facility at Discovery Ridge, if the NRC 

15 staff determines in its SER that the proposed NWMI facility at Discovery Ridge would comply 

16 with 10 CFR 70.61 and any other NRC regulations applicable to chemical accident 

17 consequences, then the NRC staff concludes that the impacts from potential hazardous 

18 chemical accidents for a proposed NWMI facility located at the MURR site would also be 

19 SMALL.

20 5.2.2.12 Environmental Justice

21 This section describes the potential human health and environmental effects from the 

22 construction, operations, and decommissioning of the proposed NWMI facility on minority and 

23 low-income populations living near the MURR site. As previously discussed in Section 4.12, the 

24 NRC addresses environmental justice issues and concerns by first identifying potentially 

25 affected minority and low-income populations and then determining whether there would be any 

26 potential human health or environmental effects and whether any of these effects would be 

27 disproportionately high and adverse.

28 Minority population data are available for Census block groups within a 5-mi (8-km) radius of the 

29 MURR site. Low-income population data are only available at the Census tract level because of 

30 the limited availability of poverty and income data at the block group level. To protect 

31 confidentiality, the United States Census Bureau (USCB) does not publish information about 

32 small geographic areas if the population size is too small. Race and ethnicity, and poverty and 

33 income data were used to determine the presence of minority and low-income populations. If 

34 the center point of the Census tract and block group is within the 5-mi (8-km) radius boundary, 

35 data from the entire Census tract or Census block group was used.

36 Minority Population

37 According to the 2010 Census, approximately 23 percent of the City of Columbia population

38 (which includes more than one Census tract and block group) identified themselves as minority. 

39 According to the USCB’s 2014 American Community Survey 1-Year Estimates, since 2010 

40 minority population in the City of Columbia was estimated to have increased by approximately 

41 3,000 persons and now comprise 24 percent of the population (see Table 3–15). (UCSB 2016c)

42 Approximately 23 percent of the population identified themselves as minority individuals 

43 (Table 5–3) within the 5-mi (8-km) radius of the MURR site and the existing industrial park 

44 (MCDC 2016b). The largest minority group was Black or African American at 10.8 percent, 

45 followed by Asian at 5.2 percent (MCDC 2016b).

46 Census block groups were considered minority population block groups if the percentage of the 

47 minority population within any block group exceeded 23 percent. Twenty-five of the 58 Census 
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1 block groups were found to have meaningfully greater minority populations. These block groups 

2 are concentrated predominantly north and east of the MURR site within the City of Columbia. 

3 The MURR site is located in Census Tract 11.03, Block Group 4, with a minority population of 

4 18.5 percent.

5 Table 5–3. Minority Populations in Census Block Groups Within 5 mi (8 km) 

6 of the MURR Site

Census Tract Block Group Total Population

Minority 

Population(a) Percent Minority

2 1 665 139 20.9

2 2 1,065 171 16.1

3 1 641 66 10.3

3 2 1,151 81 7.0

3 3 1,218 229 18.8

5 1 1,441 536 37.2

5 2 1,353 258 19.1

6 1 1,151 82 7.1

6 2 930 53 5.7

6 3 1,237 98 7.9

6 4 1,284 193 15.0

7 1 734 263 35.8

7 2 1,543 433 28.1

7 3 1,265 309 24.4

9 1 798 263 33.0

9 2 713 390 54.7

10.01 1 1,316 373 28.3

10.01 2 864 222 25.7

10.01 3 2,476 446 18.0

10.02 1 2,979 462 15.5

10.02 2 2,194 529 24.1

10.02 3 777 97 12.5

11.01 1 2,815 522 18.5

11.01 2 3,304 666 20.2

11.01 3 2,509 501 20.0

11.03 1 1,421 136 9.6

11.03 2 2,475 286 11.6

11.03 3 1,281 312 24.4

11.03 4 1,537 284 18.5

11.04 1 3,444 508 14.8

11.04 2 3,920 491 12.5

11.04 3 3,265 796 24.4

12.01 1 1,079 155 14.4
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Census Tract Block Group Total Population

Minority 

Population(a) Percent Minority

12.01 2 1,042 114 10.9

12.01 3 3,055 571 18.7

12.01 4 644 65 10.1

12.02 1 2,341 369 15.8

12.02 2 2,882 418 14.5

13 1 1,218 622 51.1

13 2 2,618 728 27.8

14 1 5,724 1,299 22.7

14 2 1,807 389 21.5

14 3 1,191 295 24.8

14 4 2,711 729 26.9

15.02 2 2,172 822 37.8

15.02 3 712 396 55.6

15.04 1 1,959 550 28.1

15.04 2 2,077 721 34.7

15.04 3 3,975 1,130 28.4

15.04 4 1,095 642 58.6

18.05 1 4,628 1,154 24.9

18.05 2 3,264 643 19.7

21 1 816 492 60.3

21 2 1,472 858 58.3

21 3 832 264 31.7

22 1 3,230 674 20.9

22 2 2,203 389 17.7

22 3 1,320 62 4.7

(a) Includes people of Hispanic, Latino, or Spanish ethnicity.

Census block groups with minority population percentages greater than 23 percent are in bold.

Sources: USCB 2010 Census Summary File 1, Table P9, Hispanic or Latino or Not Hispanic or Latino by Race 

(USCB 2016b)

1 Low-Income Population

2 According to 2010–2014 American Community Survey estimates, an average of 11.3 percent of 

3 families and 20.7 percent of all people residing in Boone County were identified as living below 

4 the Federal poverty threshold. In addition, the City of Columbia had an average of 13.2 percent 

5 of families and 24.9 percent of all people identified as living below the Federal poverty level. 

6 The Federal poverty threshold for a family of four was $22,314 in 2010 and $24,230 in 2014

7 (USCB 2016d).

8 Table 5–4 lists low-income population Census tracts within a 5-mi (8-km) radius of the MURR 

9 site and the estimated average number of people living below the poverty level. According to 
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1 the USCB’s American Community Survey 5-Year Estimates for 2010–2014, 25.9 percent of the 

2 total population within that radius was identified as living below the Federal poverty level 

3 (MCDC 2016b).

4 Census tracts were considered low-income population Census tracts if the percentage of 

5 individuals living below the Federal poverty threshold exceeded 25.9 percent. Ten of the 

6 18 Census tracts were found to have meaningfully greater low-income populations. These 

7 Census tracts are concentrated mainly northeast of the MURR site within the City of Columbia. 

8 The MURR site is located in Census Tract 11.03 with an estimated 16.5 percent of its 

9 population living below the poverty level (USCB 2016d).

10 Table 5–4. Percentage of People and Families in Census Tracts Within 5 mi (8 km) of the 

11 MURR Site Whose Income is Below the Poverty Level

Census Tract Total Population

Percentage of People 

Below Poverty Level

Percentage of Families 

Below Poverty Level

2 1,749 29.5 25.9

3 3,097 66.8 10.3

5 2,760 70.5 77.1

6 4,917 7.2 0.7

7 3,877 29.1 20.8

9 1,618 29.0 15.3

10.01 4,644 40.2 11.7

10.02 6,052 16.7 15.8

11.01 8,824 56.2 14.6

11.03 6,989 16.5 4.4

11.04 10,778 17.7 5.1

12.01 6,169 8.2 6.8

12.02 5,620 8.2 5.2

13 3,603 27.8 17.9

14 11,394 12.1 7.8

15.04 9,161 23.8 15.8

21 3,649 49.4 45.8

22 7,223 72.8 67.3

Census tracts with percentages of people below the poverty level is greater than 25.9 percent are in bold.

Source: USCB American Community Survey 5-Year Estimates, 2010–2014, Table DP03, Selected Economic 

Characteristics (USCB 2016c)

12 Impact Analysis

13 Section 5.2 of this EIS presents an assessment of the environmental effects from constructing, 

14 operating, and decommissioning the proposed NWMI facility at MURR for all affected resource 

15 areas. The NRC uses this information to determine if there would be any human health or 

16 environmental effects that could disproportionately affect minority and low-income populations 

17 and whether any of these effects would be high and adverse.
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1 The following subsections of Section 5.2 describe the potential human health and environmental 

2 effects from constructing, operating, and decommissioning the proposed NWMI facility that 

3 could impact minority and low-income populations:

4 • radiological and nonradiological human health impacts (Section 5.2.2.8),

5 • noise impacts (Section 5.2.2.2), and

6 • traffic impacts (Section 5.2.2.10).

7 The NRC also considered whether there would be any environmental impacts that would affect 

8 a specific minority and low-income population and whether there would be any unique effects 

9 that could appreciably exceed or (are) likely to appreciably exceed those for the general 

10 population.

11 Subsistence Consumption of Fish and Wildlife

12 The special pathway receptors analysis is an important part of the environmental justice 

13 analysis because consumption patterns may reflect the traditional or cultural practices of 

14 minority and low-income populations in the area, such as migrant workers or Native Americans.

15 Section 4–4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and 

16 appropriate, to collect and analyze information about the consumption patterns of populations 

17 that rely principally on fish and/or wildlife for subsistence and to communicate the risks of these 

18 consumption patterns to the public. In this EIS, the NRC staff considered whether there were 

19 any means for minority or low-income populations to be disproportionately affected by 

20 examining impacts on American Indians, Hispanics, migrant workers, and other traditional 

21 lifestyle special pathway receptors.

22 Based on the description of air and water quality impacts and the discussion of human health 

23 effects in this EIS, human health impacts in special pathway receptor populations in the region 

24 as a result of subsistence consumption of water, local food, fish, and wildlife are not likely to be 

25 high or adverse. Thus, constructing, operating, and decommissioning the proposed NWMI 

26 facility at the MURR site would not have disproportionately high and adverse human health and 

27 environmental effects on these populations.

28 Construction

29 Similar to construction at Discovery Ridge, potential impacts to minority and low-income 

30 populations from the construction of the proposed NWMI facility at the MURR site would mostly 

31 consist of environmental effects (e.g., noise, dust, and traffic). Noise and dust impacts during 

32 construction would be short term and primarily limited to onsite activities. Minority and 

33 low-income populations residing along site access roads could be affected by an increase in the 

34 number of commuter vehicles and truck traffic traveling to and from the proposed work site. 

35 However, given the short duration of construction, the small size of the average daily workforce, 

36 and the small number of trucks, construction of the proposed NWMI facility would not have 

37 disproportionately high and adverse human health and environmental effects on minority and 

38 low-income populations living near MURR.

39 Operations

40 Potential impacts to minority and low-income populations during NWMI facility operations would 

41 mostly consist of radiological and nonradiological human health and environmental (e.g., noise 

42 and traffic) effects. Everyone living near MURR and the proposed NWMI facility could be 

43 affected by operations activities, including minority and low-income populations. Any human 

44 health and environmental effect would depend on the magnitude of the change from current 
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1 environmental conditions. Minority and low-income populations residing along site access 

2 roads could be affected by the increased commuter vehicle and truck traffic during certain hours 

3 of the day.

4 As discussed in Section 5.2.2.8 of this EIS, the potential radiological dose to the public from 

5 NWMI facility operations would be well within NRC and applicable Federal, State, and local 

6 regulatory limits. As a result, everyone living near the proposed NWMI facility site, including 

7 minority and low-income populations, would not be adversely affected by radiation exposure 

8 during facility operations. Permitted nonradiological air emissions would also be required to 

9 remain within regulatory standards.

10 As discussed in Section 5.2.2.2 of this EIS, noise levels may increase along site access roads 

11 due to increased commuter vehicle and truck traffic during NWMI facility operations. This may 

12 not be noticeable, however, given the relatively small size of the workforce and the limited 

13 number of daily truck deliveries and shipments. Based on this information, operation of the 

14 proposed NWMI facility would not have disproportionately high and adverse human health and 

15 environmental effects on minority and low-income populations living near MURR.

16 Decommissioning

17 Similar to construction impacts, potential impacts to minority and low-income populations during 

18 the decommissioning of the proposed NWMI facility at the MURR site would mostly consist of 

19 environmental and socioeconomic effects (e.g., noise, dust, and traffic). Noise and dust impacts 

20 during decommissioning would be short term and primarily limited to onsite activities. Minority 

21 and low-income populations residing along site access roads could be affected by an increase 

22 in the number of commuter vehicles and truck traffic travelling to and from the proposed work 

23 site. However, because of the temporary nature of decommissioning, these effects are not 

24 likely to be high and adverse and would be contained within a limited time period during certain 

25 hours of the day. Given the short duration, the small size of the average daily workforce, and 

26 the small number of trucks, decommissioning the proposed NWMI facility would not have 

27 disproportionately high and adverse human health and environmental effects on minority and 

28 low-income populations living near MURR.

29 5.2.2.13 Cumulative Impacts

30 Available information about the past, present, and reasonably foreseeable projects and other 

31 activities near the MURR site is provided in Table 5–5.

32 Table 5–5. Past, Present, and Reasonably Foreseeable Projects and 

33 Other Actions Considered for the Cumulative Impacts Analysis – MURR

Project Name Summary of Project Location Status

Nuclear Projects

Callaway Plant Nuclear power plant,

one 1,236 MWe

Westinghouse 4-loop 

pressurized water 

reactor 

32 mi (51 km) southeast 

of site

Operational (NRC 2015j)

Research and Manufacturing Facilities 

Boone Quarries Crushed Limestone

Quarry 

3.3 mi (5.3 km) north of 

site

Operational (Con-Agg 

undated)
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Project Name Summary of Project Location Status

Discovery Ridge 

Research Park

Research Park being 

developed on University 

of Missouri lands with 

potential expansion to 

550 ac (220 ha)

3.7 mi (6 km)

southeast of site

Research park currently 

has two tenants (ABC 

Laboratories and IDEXX 

BioResearch) occupying 

two of 14 lots comprising 

Phase I (139 ac (56 ha)) 

of the park’s 

development. Potential 

total future build out 

would be 550 ac 

(220 ha). No other 

proposed tenants were 

identified at this time. 

(MU 2009, 2016g)

University of Missouri 

Research Reactor 

10 MWt research reactor Immediately adjacent to 

the site

Operational

ABC Laboratories Analytical biochemical 

testing serves

3.8 mi (6.1 km)

southeast of site

Operational (ABC 2016)

IDEXX BioResearch Animal bioresearch 

health monitoring and 

diagnostic testing 

laboratory

4 mi (6.5 km)

southeast of site

Operational 

(IDEXX 2015, 

MU 2016g)

Fossil Fuel Projects 

University of Missouri 

Combined Heat and 

Power Plant

Conventional Steam 

Coal (50.7 MW); Natural 

Gas-Fired Combustion 

Turbine (22.8 MW); 

Petroleum 3.5 MW)

1.1 mi (1.8 km) 

north-northeast of site

Operational (EIA 2015a)

Columbia Municipal 

Power Plant

Natural Gas-Fired 

Combustion Turbine 

47.5 MW; Conventional 

Steam Coal (38.5 MW); 

Petroleum (12.6 MW); 

Landfill Gas (3 MW)

2.6 mi (4.2 km) 

north-northeast of site

Operational (EIA 2015b)

Columbia Energy Center Natural Gas Fired 

Combustion Turbine 

(140 MW)

7.4 mi (12 km)

northeast of site

Operational (EIA 2015c)

Transportation Projects 

Columbia

Regional Airport

Public airport 10 mi (16 km)

southeast of site

Operational. Proposed 

runway expansion and 

improvements under 

consideration. 

(CRA 2012)

Medical Facilities

University Hospital Hospital that performs 

radiological procedures

0.9 mi (1.5 km)

northeast of site

Operational (MU 2016h)

Boone Hospital Center Hospital that performs 

radiological procedures

1.9 mi (3.1 km) northeast 

of site

Operational (Boone 

County 2016c)
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Project Name Summary of Project Location Status

Parks/Recreation Sites

Nifong Park 58 ac (23 ha) park 

offering picnicking, 

fishing, and hiking. 

Other amenities include 

Walters-Boone County 

Historical Museum, 

historic Maplewood 

home and grounds, and 

Boone Junction 

Historical Village

3 mi (4.8 km) southeast 

of site

Operational. Minor park 

improvements planned 

though 2017. Managed 

by the City of Columbia.

(City of Columbia 2016f; 

NWMI 2015a)

A. Perry Phillips Park 140 ac (57 ha) park 

offering picnicking, 

fishing, boating, and 

hiking. 

5.3 mi (5.3 km) 

southeast of site

Operational. Park 

dedicated in 2011 and 

being developed over 

several years in 

conjunction with 

adjacent Gans Creek 

Recreational Area. 

Planned improvements 

through 2018 include an 

ice skating center and an 

indoor sports center. 

Managed by the City of 

Columbia. (City of 

Columbia 2016g; 

NWMI 2015a)

Gans Creek 

Recreational Area

320 ac (130 ha) park 

offering five 

multipurpose athletic 

fields

4 mi (6.4 km) southeast 

of site

Operational. Two 

additional athletic fields 

under construction, with 

planned future 

construction of 

playground, restroom, 

and concession facilities. 

Managed by the City of 

Columbia. (City of 

Columbia 2016h)

Rock Bridge 

State Park

2,273 ac (920 ha) park 

containing unique 

geological features and 

offering picnicking, 

hiking, cycling, and 

horseback riding.

3.3 mi (5.3 km) south of 

site

Operational. Managed 

by Missouri Department 

of Natural Resources

(MDNR undated; USA 

Parks 2015)

Other Recreational 

Areas

Various parks, 

campgrounds, and 

natural areas

Within 10 mi (16 km) Operational

Other Projects/Actions

Discovery Park 105 ac (42 ha) 

residential and 

commercial development 

center

3.5 mi (5.6 km)

southeast of site

Under construction.

(Columbia Daily 

Tribune 2015b)
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Project Name Summary of Project Location Status

A.L. Gustin Golf Course 6,500-yd (5,944-m) 

university-owned public 

golf course

0.1 mi (0.2 km)

west of site

Operational (MU 2016i)

Other Future 

Development

Construction of housing 

units and associated 

commercial buildings; 

roads, bridges, and rail; 

water and/or wastewater

treatment and 

distribution facilities, and 

associated pipelines as 

described in local land 

use planning documents.

Throughout region Construction would 

occur in the future as 

described in State and 

local land use planning 

documents.

1 Land Use and Visual Resources

2 This section addresses the direct and indirect effects of the construction, operations, and 

3 decommissioning of the NWMI facility at the MURR site on land use and visual resources, when 

4 added to the aggregate effects of other past, present, and reasonably foreseeable future 

5 actions. The description of the affected environment in Section 5.2.2.1 serves as baseline 

6 conditions for the cumulative impact assessment of land use and visual resources. The 

7 incremental impacts from construction, operations, and decommissioning of the proposed 

8 NWMI facility on land use and visual resources would be SMALL, as described in 

9 Section 5.2.2.1.

10 Land Use

11 The projects and activities described in Table 5–5 would result in minimal changes to existing 

12 land uses, because new construction would occur either within or adjacent to existing facilities, 

13 or within areas currently zoned for industrial or residential use. Future urbanization and global 

14 climate change could contribute to additional decreases in agricultural lands, forests, 

15 grasslands, and wetlands. Urbanization in the vicinity of the MURR site would alter important 

16 attributes of land use. Urbanization would reduce natural vegetation and agricultural fields, 

17 resulting in an overall decline in the extent and connectivity of wetlands, forests, grasslands, 

18 and wildlife habitat. Global climate change could reduce crop yields and livestock productivity 

19 (USGCRP 2014), which may change portions of agricultural land uses. However, existing 

20 parks, reserves, and managed areas would help preserve wetlands and forested areas. In 

21 addition, zoning laws and comprehensive land use plans would help ensure a proper balance of 

22 development (City of Columbia 2013).

23 Given that reasonably foreseeable new construction activities would occur within or adjacent to 

24 existing facilities or within areas zoned for industrial or residential use, cumulative impacts of the 

25 proposed NWMI facility on land use resources would be SMALL.

26 Visual Resources

27 The projects and activities described in Table 5–5 would result in minimal changes to the 

28 existing viewshed, because new construction would occur either within or adjacent to existing 

29 facilities, or within areas currently zoned for industrial or residential use. Furthermore, the 

30 viewshed within the vicinity of the MURR site is agricultural, light industrial, forested or 

31 residential. Within undeveloped areas, where a new structure would change qualities of the 

32 existing landscape, the viewshed is generally of low scenic quality because of a lack of notable 
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1 features, uniform landform, low vegetation diversity, an absence of water, mute colors, and a 

2 commonality within the physiographic province.

3 Given that reasonably foreseeable new construction activities would occur within or adjacent to 

4 existing facilities or within areas zoned for industrial or residential use and of low scenic quality, 

5 the NRC staff determined that cumulative impacts of the proposed NWMI facility on visual 

6 resources would be SMALL.

7 Air Quality and Noise

8 This section addresses the direct and indirect effects of the construction, operations, and 

9 decommissioning of the NWMI facility at the MURR site on air quality and noise, when added to 

10 the aggregate effects of other past, present, and reasonably foreseeable future actions. The 

11 incremental impacts from construction, operations, and decommissioning of the proposed 

12 NWMI facility on air quality would be SMALL, as described in Section 5.2.2.2. The incremental 

13 impacts from construction, operations, and decommissioning of the proposed NWMI facility on 

14 noise would be SMALL to MODERATE.

15 Air Quality 

16 The ROI considered for the air quality analysis for the NWMI facility located at the MURR site is 

17 Boone County, because air quality designations for criteria air pollutants are generally made at 

18 the county level (Section 5.2.2.2). Table 5–5, provides a list of current projects and reasonably 

19 foreseeable future actions that could contribute to cumulative impacts to air quality. Air 

20 emissions sources that contribute to air quality identified in Table 5–5 (e.g., fossil fuel projects 

21 and manufacturing facilities) that are currently operating have not contributed to a violation of 

22 the NAAQS given Boone County’s designated attainment/unclassifiable status. Consequently, 

23 cumulative impacts to air quality would be the result of changes to present-day emissions and 

24 future actions within Boone County.

25 Development and construction activities, as identified in Table 5–5, associated with regional 

26 growth in housing, business, and industry, as well as associated vehicular traffic can increase 

27 air emissions. The population for the City of Columbia is projected to increase between 22 and 

28 35 percent by 2030 (related to 2010) and construction of new housing and associated 

29 infrastructure will be needed to accommodate the increase in population (City of 

30 Columbia 2013). Annual job growth projection for the City of Columbia is 1.3 to 1.4 percent 

31 (City of Columbia 2013). Regional air quality conditions could deteriorate from the effects of 

32 growth in Boone County, because growth gives rise to dust, vehicle exhaust from increased 

33 traffic, and other emissions. Although air emissions from construction activities would be 

34 temporary and localized, the resulting regional growth in residential, commercial, and industrial 

35 uses across Boone County could result in overall long-term air emission sources. These new 

36 stationary and mobile (e.g., vehicle) emission sources could further overlap with operations and 

37 decommissioning of the proposed NWMI facility and could noticeably alter air quality conditions 

38 in Boone County. If degradation in air quality is observed, MDNR can develop air quality control 

39 programs to mitigate the effects of development. However, mitigation will depend on the control 

40 strategies implemented and adherence to these strategies. Climate change impacts, as 

41 discussed in Section 4.14, can affect air quality as a result of changes in meteorological 

42 conditions. However, the combination of conditions that can change air pollutant concentrations 

43 are still being investigated by the scientific community.

44 The NRC staff determined that the potential cumulative air quality impact associated with 

45 construction, operations, and decommissioning of the NWMI facility, in conjunction with other 

46 reasonably foreseeable projects, would be SMALL to MODERATE, because future economic 
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1 and population growth in Boone County could lead to long-term air emission sources and 

2 increases in air pollutants that can noticeably alter air quality.

3 Noise

4 The ROI considered for the noise impact analysis is a 1-mi (1.6-km) radius from the proposed 

5 NWMI facility at the MURR site. Noise levels attenuate rapidly with distance. When distance is 

6 doubled from a point source, noise levels decrease by 6 dBA (FHWA 2011). Generally, a 

7 3-dBA change over existing noise levels is considered to be a “just noticeable” difference, a 

8 5-dBA increase is readily perceptible, and a 10-dBA increase is subjectively perceived as a 

9 doubling in loudness (FHWA 2011). As discussed in Section 5.2.2.2, the impact to noise would 

10 be SMALL to MODERATE during construction and decommissioning.

11 Those projects identified in Table 5–5 that involve construction activities could result in 

12 increases in noise levels. Because these projects are beyond the noise analysis ROI for the 

13 MURR site, these projects would not be expected to have significant noise impacts or increase 

14 ambient noise levels within the ROI. Therefore, the NRC staff determined that the potential 

15 cumulative noise impact associated with construction, operations, and decommissioning of the 

16 NWMI facility, in conjunction with other reasonably foreseeable projects, would remain SMALL 

17 to MODERATE.

18 Geologic Environment

19 This section addresses the direct and indirect effects of the construction, operations, and 

20 decommissioning of the proposed NWMI facility at the MURR site on the geologic environment 

21 when added to the aggregate effects of other past, present, and reasonably foreseeable future 

22 actions. The cumulative impacts on the geologic environment primarily relate to land 

23 disturbance, the potential for soil erosion and loss, and the consumption of geologic resources. 

24 The description of the affected environment in Section 5.2.2.3 of this EIS serves as the baseline 

25 for the geologic environment cumulative impacts assessment.

26 The ROI for evaluating cumulative impacts on soil resources encompasses the MURR site and 

27 further encompassing a 5-mi (8-km) radius of the site. For geologic resources, the NRC staff 

28 further extended the ROI to include all of Boone County to encompass potential commercial 

29 sources of rock and mineral resources to support construction activities at the proposed site and 

30 vicinity. Because the aspects of land disturbance and conversion are addressed separately 

31 under Land Use and Visual Resources above, the cumulative impacts analysis here will focus 

32 on soil loss, including the loss of any prime farmland soils and other important farmland soils, 

33 and the consumption of geologic resources. The incremental impacts from construction, 

34 operations, and decommissioning of the proposed NWMI facility on the geologic environment, 

35 including geologic and soil resources, would be SMALL, as described in Section 5.2.2.3.

36 Soil Resources

37 New construction projects identified in Table 5–5 within the immediate 5-mi (8-km) radius of the 

38 MURR site would result in the conversion and loss of soils. There would be no incremental loss 

39 of prime farmland or other important farmland soils because although soils at the MURR site do 

40 meet the relevant criteria as prime farmland soils, they are already in and otherwise committed 

41 to development uses. Regardless, in accordance with local and State permits and approvals, 

42 as referenced in Section 5.2.2.3 relative to the NWMI facility, all development activities in the 

43 ROI would be subject to BMPs for soil erosion and sediment control, which would serve to 

44 minimize soil erosion and loss. Developers would be likely to reclaim usable topsoil removed by 

45 ground-disturbing activities for use elsewhere at the impacted development sites. Alternatively, 

46 developers can stockpile usable topsoil or backfill and then sell or otherwise transfer it for reuse 

47 elsewhere at other development sites. Following the completion of construction activities, 
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1 continued soil loss would be minimal as the remaining soils would lie beneath impervious 

2 surfaces, such as buildings, or the impacted area would have been revegetated or incorporated 

3 into facility landscaping or hardscaped areas. This would be the case, for example, at the 

4 NWMI facility site and at other sites across the University of Missouri campus and across south 

5 Columbia. Although developed land areas could be reclaimed and sufficiently restored to 

6 support certain agricultural and non-developed uses at some point in the future, such lands and 

7 associated soils would not be restorable to prime or other important farmland status. 

8 Cumulative soil loss would largely occur in or adjacent to developed areas and soil loss would 

9 be mitigated by the use of BMPs. As a result, the NRC staff concludes that cumulative impacts 

10 on soil resources would be SMALL. 

11 Geologic Resources

12 New facility construction and expansion (Table 5–5) would require the use and consumption of 

13 geologic resources, including rock and mineral assets such as construction aggregate materials 

14 (e.g., sand and gravel). Construction of the NWMI facility at the MURR site would use many of 

15 the same materials, including concrete, gravel, and sand required for the other identified 

16 projects. For example, construction of the NWMI facility would require about 1,700 cubic yards 

(yd3

) (1,300 cubic meters (m3 17 )) of crushed aggregate (limestone) (see Section 2.2). By 

18 comparison, the 11-county rock and mineral district of central Missouri that includes Boone 

19 County produces or uses approximately 5.95 million tons (5.4 million metric tons) of crushed 

stone annually. This is equivalent to 4.5 million yd3 (3.4 million m3 20 ) of material (USGS 2015c).

21 As noted in Section 5.2.2.3, rock and mineral products, including construction aggregate, are 

22 widely available throughout Boone County and the surrounding region. Likewise, products 

23 derived from geologic materials, including concrete and asphaltic materials used in construction, 

24 are widely available on a regional basis. It is not likely that the geologic resource requirements 

25 to construct the NWMI facility or the resource requirements of other identified projects are of 

26 such a volume as to affect local and regional sources and supplies of the identified resources. 

27 In addition, there are no active geologic assets (mines or quarries) at or near the MURR site 

28 that would be rendered inaccessible for future use. Therefore, the NRC staff concludes that 

29 cumulative impacts on geologic resources would be SMALL.

30 Water Resources

31 This section addresses the direct and indirect effects of the construction, operations, and 

32 decommissioning of the proposed NWMI facility on water resources when added to the 

33 aggregate effects of other past, present, and reasonably foreseeable future actions. This 

34 cumulative impacts analysis for surface water and groundwater resources considers such 

35 issues as water quality, water use, and potential climate change. It further considers relevant 

36 project actions, activities, and specific implications for surface water or groundwater withdrawal, 

37 effluent discharges, stormwater drainage and runoff, and accidental spills and releases. The 

38 description of the affected environment in Section 5.2.2.4 serves as the baseline for the water 

39 resources cumulative impacts assessment.

40 The ROI for the surface water resources component of the cumulative impacts analysis is 

41 comprised of the MURR site and the Hinkson Creek watershed downstream of the site and 

42 including Perche Creek, as described in Section 5.2.2.4, Surface Water Hydrology, Quality, and 

43 Use. For groundwater resources, the ROI includes the MURR site and the local groundwater 

44 basin in which groundwater is recharged and flows to discharge points within the watershed. 

45 The area further comprises those aquifers from which groundwater is withdrawn through wells 

46 to supply potable, industrial, agricultural, and other uses within a 5-mi (8-km) radius of the site. 

47 Thus, this analysis focuses on those projects that, when combined with those under the 

48 proposed action, would: (1) withdraw water from or discharge effluents to Hinkson Creek and 
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1 other tributaries within the watershed downstream of the site, or (2) would use groundwater or 

2 could otherwise affect the same aquifers that would supply water to the MURR site. For surface 

3 water, the ROI further encompasses Perche Creek from its confluence with Hinkson Creek and 

4 including the segment of Perche Creek that receives effluent discharges from the Columbia 

5 Regional WWTP. The Columbia Regional WWTP would also receive sanitary effluent from the 

6 proposed NWMI facility. The incremental impacts from construction, operations, and 

7 decommissioning of the proposed NWMI facility on surface water and groundwater resources 

8 would be SMALL, as described in Sections 5.2.2.4.

9 The MURR site is located adjacent to the existing MURR laboratory building, within the 

10 University of Missouri campus. Site drainage flows generally south through stormwater

11 drainage channels toward Hinkson Creek, which located approximately 0.2 mi (0.3 km) south of 

12 the site. Hinkson Creek is a tributary to Perche Creek and, ultimately, to the Missouri River, as 

13 further discussed in Section 5.2.2.4.

14 The State of Missouri has established water quality standards for Hinkson Creek and other 

15 tributaries within the watershed that ultimately flow to the Missouri River. Surface water is a 

16 minor source of water supply in Boone County. The predominant source of water for municipal 

17 water supply and for individual property owners in Boone County, and particularly within the City 

18 of Columbia, is groundwater pumped from deep bedrock aquifers (Section 5.2.2.4, Groundwater 

19 Hydrology, Quality, and Use).

20 Surface Water Resources

21 Hinkson Creek, which passes south of the MURR site, bisects the City of Columbia and it 

22 serves as the major stormwater drainage basin for the City of Columbia. Like other perennial 

23 rivers and streams of the State, Hinkson Creek is designated for the following beneficial uses: 

24 aquatic habitat protection, human health protection, whole body contact recreation, and 

25 secondary contact as well as livestock and wildlife protection and irrigation. These uses apply 

26 to Hinkson Creek and other major streams within a 5-mi (8-km) radius of the MURR site, 

27 including Perche Creek. Hinkson Creek is included in the State’s list of “impaired” waters, 

28 pursuant to Section 303(d) of the Federal Water Pollution Control Act (i.e., Clean Water Act 

29 (CWA)) of 1972. Hinkson Creek is impaired for whole body contact recreation because of 

30 water-borne E. coli bacteria. The reason for listing is impairment of the beneficial use due to 

31 nonpoint source runoff.

32 As further described in Section 5.2.2.4, the State is required to evaluate pollutant loadings within 

33 such watersheds and implement a watershed-based program to assure future compliance with 

34 water quality standards. On an individual project or facility basis, the State typically addresses 

35 watershed improvement through existing and new permits. The NPDES permit program, under 

36 CWA Section 402, addresses water pollution by regulating point sources (i.e., pipes and 

37 ditches) that discharge pollutants to waters of the United States. The State of Missouri has 

38 been delegated NPDES permitting authority by EPA.

39 Within the context of the local watersheds of the Missouri River, such as Hinkson Creek, climate 

40 change is an important consideration. Projections for continued increases in temperature and 

41 changes in precipitation patterns, including longer periods of drought, would be likely to reduce 

42 the overall amount of water available for surface runoff, with an effect on the beneficial uses of 

43 affected surface waters. Over the period 1988 to 2010, a decrease in soil moisture has been 

44 documented during most seasons in the central Midwest (USGCRP 2014). As temperatures 

45 are projected to continue to increase across the Midwest, this trend would be expected to 

46 continue. Meanwhile, by mid-century, the scientific community projects increases in the 

47 frequency and intensity of extreme precipitation, while at same time, an increase in the average 

48 maximum number of consecutive days with less than 0.01 in (0.025 cm) of precipitation 
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1 (indicative of drought conditions) throughout the entire Midwest region (USGCRP 2014). An 

2 increased frequency of extreme rainfall events can cause erosion and lead to a decline in water 

3 quality (USGCRP 2014). This is particularly true where soils are dry and less able to retain 

4 precipitation that falls during heavier precipitation events. The implications are clear for an 

5 urbanized watershed, such as Hinkson Creek, where climatic changes can bring with them 

6 increases in runoff laden with nutrients, sediment, and other contaminants. Increases in 

7 impervious surface due to existing and future development can further exacerbate these 

8 changes in water quality.

9 Current and proposed future projects and facilities that adjoin the MURR site include 

10 institutional, residential, commercial, and industrial uses (Table 5–5) within the urbanized 

11 University of Missouri campus. Projects and activities occurring within the ROI would be subject 

12 to applicable local, State, and Federal regulatory requirements and associated permits and 

13 approvals. Construction projects must obtain a Land Disturbance Permit from the City of 

14 Columbia and submit related plans for city approval before any ground-disturbing activities or 

15 facility construction could begin on the site (Section 4.3.1). For projects outside the municipal 

16 boundary of the City of Columbia, Boone County also requires a Land Disturbance Permit, 

17 including the development and implementation of a soil erosion and sediment control plan and a 

18 stormwater management plan. These plans entail the implementation of construction-related 

19 BMPs for soil erosion and sediment control and stormwater pollution prevention during site 

20 development, facility construction, and for post development.

21 The MDNR has developed an NPDES general permit that must be obtained by owners and 

22 operators for the discharge of stormwater and certain non-stormwater discharges

23 (e.g., dewatering) from land-disturbance sites that disturb 1 ac (0.4 ha) or more, or less than 

24 1 ac (0.4) but part of a larger development. This State general permit requires permit holders to 

25 develop and implement an SWPP, the purpose of which is in part to ensure the proper design, 

26 implementation, management, and maintenance of BMPs to prevent the introduction of 

27 sediment and other pollutants in stormwater discharges. MDNR also requires certain industrial 

28 facilities to obtain an NPDES permit for stormwater discharges during facility operations.

29 The Columbia Regional WWTP serves all of the City of Columbia. During the projected 30-year 

30 period of operations, the only liquid waste discharged from the NWMI facility would be sanitary 

31 in nature. This effluent would be discharged to the City of Columbia sanitary sewer system at 

32 an average rate of approximately 4,570 gpd (17,300 Lpd). This is equivalent to approximately 

0.0046 mgd (17.4 m3 33 /day). The Columbia Regional WWTP would be the ultimate point of 

34 treatment. The Columbia Regional WWTP has a design treatment capacity of 20 mgd 

(75,700 m3

/day) with average demand of 16 mgd (60,600 m3 35 /day). NWMI’s additional 

36 wastewater volume would constitute a very small percentage (i.e., 0.12 percent) of the available 

37 treatment capacity of the WWTP. Sanitary wastewater discharges from the NWMI facility would 

38 be unlikely to have any impact on the facility or have any impact on ambient water quality 

39 downstream of the WWTP.

40 Nevertheless, the potential exists for substantial population growth in the County and City of 

41 Columbia of about 40 percent between 2016 and 2050 (Section 3.7.1). The corresponding 

42 increase in sanitary effluent generated by the larger population would approach or exceed the 

43 capacity of the WWTP. This would require the City of Columbia to invest in additional 

44 wastewater treatment infrastructure. Given the planning timeframe, the NRC staff expects that 

45 the City of Columbia would be able to accommodate the increased treatment demand with 

46 timely expansions of treatment infrastructure, as it becomes needed.

47 In summary, construction, operations, and decommissioning of the proposed NWMI facility 

48 would have a minimal incremental contribution to cumulative impacts on surface water 
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1 resources, including surface water and groundwater quality. Ongoing and future development 

2 projects within the Hinkson Creek watershed would be subject to City and Boone County site 

3 development approvals, including Land Disturbance Permits. NPDES permits required for all 

4 new stormwater and industrial wastewater dischargers would include provisions to comply with 

5 applicable wasteload allocations established for downstream receiving waters. Within this 

6 context, climate change including changes in runoff rate and quality would be expected to have 

7 as big or a bigger role in affecting surface hydrology and water quality as growth and 

8 development alone in the watershed, as described above. In consideration of this information, 

9 the NRC staff concludes that the cumulative impacts on surface water resources would be 

10 SMALL to MODERATE overall, primarily because of urbanization, regional growth, and climate 

11 change.

12 Groundwater Resources

13 The City of Columbia’s water supply primarily comes from a well field withdrawing from the 

14 alluvial aquifer adjacent to the Missouri River floodplain and located about 7 mi (11 km) 

15 southwest of the MURR site. This well field has a total groundwater production capacity of 

30 mgd (113,560 m3 16 /day). The City of Columbia’s average groundwater use is 12.6 mgd 

(47,700 m3 17 /day) (City of Columbia 2016j). Meanwhile, the University of Missouri maintains its 

18 own system of five deep wells to supply potable water across the university, including providing 

19 water supply to the existing MURR Center. The combined rated production capacity of the wells 

is 4,700 gpm (17.8 m3

/min) (MU 2006, 2016j). This is equivalent to 6.77 mgd (25,630 m3 20 /day). 

In 2014, university water use averaged 1.74 mgd (6,590 m3 21 /day) (MU 2015b). In contrast, 

22 NWMI facility operations would require an average of 5,045 gpd (19,100 Lpd) of water, 

equivalent to 0.005 mgd (18.9 m3 23 /day).

24 The population of Boone County is projected to increase by about 40 percent by 2050. 

25 Assuming that this projected population growth has a direct and equal correlation on 

26 groundwater demand, total groundwater demand within the water supply service areas of the 

27 City of Columbia and the University of Missouri could grow to approximately 17.6 mgd 

(66,600 m3

/day) and 2.4 mgd (9,100 m3 28 /day), respectively. In reality, population growth in the 

29 student body, faculty, and other tenant entities located on the university campus would not be 

30 expected to grow proportionally. Given the groundwater production capacity of the two 

31 systems, the forecasted water demands alone would not be expected to affect the ability of the 

32 City of Columbia and University of Missouri water systems to meet the water supply demands of 

33 expected growth over the next 30 years.

34 However, the NRC staff assumes that climate change could have as great or a greater impact 

35 on surface water and groundwater resources, including overall water availability, as any other 

36 reasonably foreseeable future actions. The loss of moisture from soils because of higher 

37 temperatures, as discussed in Section 4.14, along with increased evapotranspiration from 

38 vegetation and the increased average number of days without precipitation is likely to intensify 

39 short-term (seasonal or shorter) droughts across the Midwest region into the future 

40 (USGCRP 2009, 2014). Such conditions can reduce the amount of water available for surface 

41 runoff, streamflow, and groundwater recharge. Specifically, climate change is projected to 

42 increase water demand across most of the United States. When accounting for regional 

43 changes in population coupled with predicted climate change impacts, current projections 

44 indicate that northeast Missouri (where the MURR site is located) could experience 

45 climate-change induced increases in water demand of up to 10 to 25 percent (USGCRP 2014). 

46 This increase would not seriously challenge the current production capacity of either the City of 

47 Columbia or the University of Missouri as the respective supply systems have large excess 

48 capacity margins. In order to manage any increases in water demands across Boone County 

49 where the water supply is heavily reliant on deep groundwater coupled with reduced 
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1 groundwater recharge due to climate change, the County’s water supply districts, municipalities, 

2 and other interests that rely upon deep groundwater could take action to increase the efficiency 

3 and extent of their production and water distribution infrastructure. This could include 

4 redeveloping existing production wells or drilling new wells to better manage water supply 

5 conflicts. However, it is noteworthy that the City of Columbia’s well field would be well insulated 

6 from any drawdown in the region’s bedrock aquifers due to any increased production, owing to 

7 the presence of the Missouri River that can serve as a source of induced recharge to the alluvial 

8 aquifer.

9 Alternatively, public water suppliers could seek out new water supply sources, such as the 

10 Missouri River, although this approach would entail investments in new infrastructure and 

11 increased operating costs. Suppliers could also pursue a combination of approaches such as 

12 conservation measures and new sources.

13 It remains that the projected average daily water needs for NWMI facility construction, 

14 operations, and decommissioning would be a very small percentage (less than 0.3 percent) of 

15 the University of Missouri’s total production and current available supply capacity. In total, the 

16 NRC staff concludes that the cumulative impacts on groundwater resources, including water 

17 availability, would be SMALL.

18 Ecological Resources

19 This section addresses the direct and indirect effects of the construction, operations, and 

20 decommissioning of the NWMI facility at the MURR site on ecological resources, when added to 

21 the aggregate effects of other past, present, and reasonably foreseeable future actions. The 

22 description of the affected environment in Section 5.2.2.5 serves as a baseline for the 

23 cumulative impact assessment of ecological resources. The ROI for evaluating cumulative 

24 impacts on ecological resources includes the area surrounding the MURR site that is ecological, 

25 connected to the onsite ecological resources (e.g., the watershed surrounding the MURR site). 

26 The incremental impacts from construction, operations, and decommissioning the proposed 

27 NWMI facility would be SMALL, as described in Section 5.2.2.5.

28 Since European settlement, prairies, forests, and wetlands have been greatly reduced and 

29 converted into agricultural fields, industrial uses, and residential and commercial areas. 

30 Remaining tracts of grasslands, forests, and wetlands tend to be relatively small and isolated, 

31 which results in lower quality habitat than large tracts of habitat, because of the different 

32 biological and physical characteristics along the edge of a habitat patch.

33 Current threats to terrestrial and aquatic habitats include increased soil, nutrients, and other 

34 pollutants washing into streams and lakes from urban and agricultural stormwater runoff; 

35 continued conversion and fragmentation of wildlife habitat from development; introduction of 

36 invasive species; and climate change (BFSC 2007; USGCRP 2014). These activities will likely 

37 decrease the overall availability and quality of forested, grassland, and wetland habitats. 

38 Species with threatened, endangered, or declining populations are likely to be more sensitive to 

39 declines in habitat availability and quality and the introduction of invasive species.

40 New development projects identified in Table 5–5 are likely to have minimal impacts on 

41 ecological resources because all the projects are sited within areas that are currently 

42 agricultural land, open space, or developed. These types of land covers provide low-quality 

43 habitat for wildlife, birds, and aquatic resources. However, as environmental stressors, such as 

44 runoff from agricultural fields and urban areas and climate change, continue over the next few 

45 decades, certain attributes of the terrestrial and aquatic environment (e.g., habitat quality) are 

46 likely to noticeably change. The NRC staff does not expect these impacts to destabilize any 

47 important attributes of the terrestrial and aquatic environment, because such impacts will cause 
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1 gradual change, which should allow some aspects of the terrestrial and aquatic environment to 

2 appropriately adapt. The NRC staff concludes that the cumulative impacts of the proposed 

3 construction and operation of the NWMI facility, plus other past, present, and reasonably 

4 foreseeable future projects or actions would result in MODERATE impacts on terrestrial and 

5 aquatic resources.

6 Historic and Cultural Resources

7 This section addresses the direct and indirect contributory effects from constructing, operating, 

8 and decommissioning the proposed NWMI facility at the MURR site when added to the 

9 aggregate effects of other past, present, and reasonably foreseeable future actions on historic 

10 and cultural resources. The geographic area considered in this analysis is the area of potential 

11 effect (APE) associated with the proposed MURR facility, the MURR site, and its immediate 

12 vicinity. As discussed in Section 5.2.2.6, constructing, operating, and decommissioning the 

13 proposed NWMI facility would not impact any known historic and cultural resources at the 

14 MURR site.

15 The archaeological record for the region indicates prehistoric and historic occupation; the APE 

16 appears to have been traditionally used as agricultural fields from the protohistoric period 

17 onward. Historic land development may have resulted in impacts on, and the loss of, cultural 

18 resources. As described in Section 5.2.2.6, no evidence of historic or cultural resources were 

19 found within the area, and the closest historic property is approximately 1 mi (1.6 km) to the 

20 north-northeast of the MURR site. The only foreseeable project within the APE is the proposed 

21 NWMI facility at the MURR site. Therefore, historic and cultural resources are not likely to be 

22 affected by the cumulative effects of constructing, operating, and decommissioning the 

23 proposed NWMI facility combined with other past, present, and reasonably foreseeable future 

24 activities at the MURR site.

25 Socioeconomics

26 This section addresses the direct and indirect contributory effects from the construction, 

27 operations, and decommissioning of the proposed NWMI facility at the MURR site when added 

28 to the effects from other past, present, and reasonably foreseeable future actions on current 

29 socioeconomic conditions within the ROI. Since the MURR site and the Discovery Ridge site 

30 share the same socioeconomic ROI, the description of the affected environment in Section 3.7 

31 serves as a baseline for the cumulative socioeconomic impact assessment. The geographic 

32 area of analysis is the ROI, the City of Columbia and Boone County. In either location, the 

33 socioeconomic impacts from constructing, operating, and decommissioning the proposed NWMI 

34 facility in the ROI would be SMALL. Since no other research or office facilities are currently 

35 planned for the Discovery Ridge Research Park, there would be no labor shortages because the 

36 City of Columbia and Boone County have a sufficient workforce to meet the needs for new 

37 research facilities (Section 3.7.4).

38 Table 5–5 identifies past, present, and reasonably foreseeable future actions within the ROI that 

39 could contribute to cumulative socioeconomic impacts. Relevant “other actions” considered in 

40 this cumulative impacts analysis is Discovery Park, a residential and commercial development 

41 being constructed 3.5 mi (5.6 km) southeast of the MURR site. Construction of Discovery Park 

42 could increase the size of the local population as well as employment and tax revenue and 

43 increase the demand for public services in the ROI. However, the overall socioeconomic effect 

44 of this construction project would be small. Therefore, the cumulative socioeconomic impact of 

45 the proposed action combined with the Discovery Park development would be SMALL.
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1 Human Health

2 This section addresses the cumulative radiological and nonradiological effects on human health 

3 for a proposed NWMI facility located at the MURR site. The geographic ROI for this evaluation 

4 of cumulative effects on human health is that area within a 5-mi (8-km) radius of the proposed 

5 NWMI facility at the MURR site. This evaluation will consider radiological and nonradiological 

6 impacts of other activities (in the recent past, present, and reasonably foreseeable future) within 

7 this ROI. Within this ROI, there are no nuclear power plants that would contribute to radioactive 

8 or nonradioactive exposure. However, the Callaway Energy Center nuclear power plant is 

9 located approximately 32 mi (51 km) away. Since the MURR site is within the 50 mi (80 km) 

10 radiological emergency planning zone for the Callaway plant, radiological human health impacts 

11 associated with the Callaway plant will also be considered in this evaluation.

12 As discussed in Section 5.2.2.8, the NRC staff reviewed the possible human health effects that 

13 could be associated with construction, operations, and decommissioning of the proposed NWMI 

14 facility at the MURR site. The NRC staff concludes that both radiological and nonradiological 

15 human health impacts to workers and members of the public from construction, operations, and 

16 decommissioning of the proposed facility at the MURR site would be SMALL.

17 Items considered for this evaluation that could have potential radiological health impacts within 

18 the ROI include the Callaway nuclear power plant, ABC Laboratories, University Hospital, and 

19 Boone Hospital Center, and the existing MURR Center (all listed in Table 5–5). As discussed in 

20 Section 4.14.8.1, these facilities are all required to comply with NRC regulations, including limits 

21 on doses to members of the public. Therefore the NRC staff expects minimal or no 

22 environmental impacts for each of these facilities considered individually. For Callaway, ABC 

23 Laboratories, University Hospital and Boone Hospital Center, given the distances between 

24 those facilities and the MURR site (see Table 5–5) and the very limited individual impacts from 

25 each of those facilities, the NRC staff does not expect that the cumulative impacts of those 

26 facilities and the proposed NWMI facility at the MURR site would result in a cumulative 

27 radiological dose impact in excess of NRC regulatory limits. The existing MURR laboratory 

28 building, however, as stated above, would be located immediately adjacent to a proposed 

29 NWMI facility at the MURR site. As discussed in Section 3.10.1, the existing MURR Center has 

30 a technical specification (TS) that requires airborne radiological effluents be limited to levels that 

31 ensure that the NRC dose limits in 10 CFR Part 20 will not be exceeded. MURR’s annual 

32 reports for 2013, 2014, and 2015, show that MURR’s airborne Ar-41 effluents ranged from 48.9 

33 to 78.1 percent of the TS limit when averaged on an annualized basis, and that no other 

34 radionuclides were released at average concentrations greater than 1 percent of the TS limits

35 (MU 2014, 2015a, 2016d). Also as discussed in Section 3.10.1, the MURR Center is required to 

36 comply with 10 CFR 20.1101(d), which requires licensees to maintain public doses ALARA by 

37 establishing a 10 mrem constraint on public dose from airborne radioactive material released 

38 into the environment. Although MURR remained within TS limits and in compliance with 

39 10 CFR Part 20 during the years 2013 through 2015, a proposed NWMI facility constructed at 

40 the MURR site would release additional airborne radiological effluents, as discussed in 

41 Sections 2.7.1.1 and 4.8.2.1. For a proposed NWMI facility at the MURR site, these releases 

42 would occur in very close proximity to the existing MURR Center. As discussed in 

43 Sections 4.8.2 and 5.2.2.8, NWMI estimated that the maximum public dose from routine 

44 airborne effluents from the proposed NWMI facility at the Discovery Ridge site would be 

45 approximately 3.6 mrem per year, below both the 100 mrem annual limit in 10 CFR 20.1301 and 

46 the 10 mrem ALARA constraint of 10 CFR 20.1101(d), and this dose would not change 

47 significantly for a proposed NWMI facility at the MURR site. Although cumulative effluents from 

48 a proposed NWMI facility at the MURR site and the existing MURR Center could, potentially, 

49 result in cumulative public doses that are greater than doses from either facility individually, both 
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1 facilities would be required to comply with 10 CFR 20.1101(d) by implementing the 10 mrem 

2 ALARA constraint. The NRC staff expects that since the public dose from airborne radioactive 

3 effluents from each facility individually would be maintained within this constraint, the cumulative 

4 dose from effluents from both facilities would remain well below the 100 mrem annual regulatory 

5 public dose limit in 10 CFR 20.1301. Therefore, if the NRC staff determines in its SER that the 

6 doses for the proposed NWMI facility located at Discovery Ridge would be in compliance with 

7 10 CFR Part 20, the NRC staff concludes that the cumulative radiological human health impacts 

8 for a proposed NWMI facility at the MURR site would be SMALL.

9 Activities considered for this evaluation that could have potential nonradiological human health 

10 impacts within the ROI include all items listed in Table 5–5 as well as the existing MURR 

11 Center. Construction activities included in Table 5–5, as well as construction of the proposed 

12 NWMI facility at the MURR site (which would be very similar to construction at the Discovery 

13 Ridge site), would involve potential hazards to workers typical of any construction site 

14 (NWMI 2015a). In addition, the proposed NWMI facility at the MURR site and some other 

15 facilities listed in Table 5–5 are industrial sites with many typical occupational hazards. These 

16 construction and industrial activities would be required to be performed subject to Occupational 

17 Safety and Health Administration (OSHA) and State of Missouri safety regulations.

18 As discussed in Section 4.14.8.2, hazardous chemical releases from the proposed NWMI facility 

19 and from other activities or facilities within the ROI, would be required to be within EPA and 

20 State of Missouri regulatory limits. All currently operating facilities in Table 5–5 for which 

21 possible chemical releases could be expected, except for the existing MURR facility, would be 

22 approximately 1.1 mi (1.8 km) or more from the proposed NWMI facility at the MURR site. The 

23 existing MURR could also generate possible chemical releases, and the existing MURR 

24 laboratory building would be located adjacent to a proposed NWMI facility at the MURR site. 

25 However, the existing MURR Center is below chemical emissions thresholds that would make it 

26 subject to reporting for EPA’s Toxics Release Inventory (TRI) program (see Section 4.14.8.2) 

27 (EPA 2016g).

28 All construction, industrial, and other work activities at a proposed NWMI facility at the MURR 

29 site, and elsewhere in the ROI, would be conducted in accordance with Federal and State 

30 regulations. In addition, since chemical releases from a proposed NWMI facility at the MURR 

31 site and other facilities in the ROI would be within EPA and State regulatory limits, and also 

32 given the distances between the MURR site and facilities listed in Table 5–5 that may have 

33 significant chemical emissions and be subject to TRI reporting, the NRC staff does not expect 

34 that the cumulative impacts of other facilities in the ROI and the proposed NWMI facility would 

35 result in a cumulative chemical exposure impact in excess of Federal or State regulatory limits. 

36 The NRC staff therefore concludes that the cumulative nonradiological human health impacts of 

37 the proposed NWMI facility located at the MURR site would be SMALL.

38 Waste Management

39 This section addresses the cumulative impacts within the ROI associated with the waste 

40 management activities of other facilities using radioactive and nonradioactive material in the 

41 recent past, present, and reasonably foreseeable future. The geographic ROI for the evaluation 

42 of cumulative impacts from the disposal of radioactive and nonradioactive waste is that area 

43 within a 5 mi (8 km) radius of the proposed NWMI facility at the MURR site. Table 5–5 lists 

44 facilities and activities considered within this ROI (Table 5–5 also lists some facilities outside the 

45 5 mi (8 km) radius, which are not considered in this evaluation).

46 As stated in Section 5.2.2.9, the types and quantities of radiological and nonradiological waste 

47 generated, and the disposal pathways for that waste, for a proposed NWMI facility at the MURR 

48 site would be essentially identical to those for the proposed NWMI facility at the Discovery 
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1 Ridge site. The NRC staff therefore concludes that the human health impacts from both 

2 radioactive and nonradioactive wastes for a proposed NWMI facility at the MURR site would be 

3 SMALL.

4 The ROI for a proposed NWMI facility at the MURR site (which includes activities listed in 

5 Table 5–5) is within the general City of Columbia, Boone County, Missouri area. As discussed 

6 in Section 4.14.9, the NRC staff assumes that sufficient infrastructure currently exists for proper 

7 disposal of all radioactive waste generated within the State of Missouri, and all nonradioactive 

8 waste generated in the Columbia, Missouri area, including radioactive and nonradioactive 

9 wastes that would be generated by a proposed NWMI facility at the Discovery Ridge site. 

10 Therefore, given the similar ROIs for a proposed NWMI facility at either site, and given that all 

11 radioactive or nonradioactive waste generated at a proposed NWMI facility at either site or by 

12 any other activity within either ROI would be required to be handled in accordance with Federal, 

13 State, and local regulations, the NRC staff concludes that the cumulative impacts from 

14 radiological and nonradiological waste management for a proposed NWMI facility at the MURR 

15 site would be SMALL.

16 Transportation

17 This section addresses the direct and indirect contributory effects from constructing, operating, 

18 and decommissioning the proposed NWMI facility when added to the effects from other past, 

19 present, and reasonably foreseeable future actions on transportation infrastructure. The ROI is 

20 the 5-mi (8-km) region surrounding the proposed NWMI facility at the MURR site. However, the 

21 roads for routes that could be used for delivery of medical isotopes (if air transport is not 

22 possible) or disposal of wastes were also considered. Transportation infrastructure includes 

23 roadways, rail lines, airports, and traffic control devices. As discussed in Section 5.2.2.10, 

24 transportation impacts during construction, operations, and decommissioning would be SMALL.

25 Construction projects in Table 5–5 could produce an increase in vehicle traffic on roads within 

26 the 5-mi (8-km) radius of the proposed NWMI site. For example, Discovery Park, a residential 

27 and commercial development being constructed 3.5 mi (5.6 km) southeast of the MURR site, 

28 could add additional commuting vehicles and commercial trucks on local roads near the 

29 proposed NWMI facility. In addition, new construction could occur within the Discovery Ridge 

30 Research Park. However, existing roads are sufficient to handle the increased traffic. An 

31 increase in the number of commuter vehicles and commercial trucks on roads near the MURR 

32 site would not likely have a noticeable impact on overall traffic volumes. Therefore, the 

33 cumulative effect of traffic-related transportation impacts of the proposed action combined with 

34 the Discovery Ridge Research Park and Discovery Park development would be SMALL.

35 Accidents

36 This section addresses the cumulative impacts within the ROI associated with possible 

37 accidents at other facilities using radioactive and/or non-radioactive hazardous chemicals. The 

38 ROI for the evaluation of cumulative effects of accidents is that within a 5-mi (8-km) radius of a 

39 proposed NWMI facility at the MURR site. Within this ROI, there are no nuclear power plants. 

40 However, the Callaway nuclear power plant is located approximately 32 mi (51 km) away. 

41 Since the proposed site is within the 50 mi (80 km) radiological emergency planning zone for the 

42 Callaway plant, hypothetical radiological accidents associated with the Callaway plant are also 

43 considered in this evaluation.

44 In Section 5.2.2.11, the NRC staff concluded that the impacts from both possible radiological 

45 accidents and possible non-radiological (hazardous chemical) accidents for a proposed NWMI 

46 facility at the MURR site would be SMALL.
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1 As discussed in Section 4.14.10.1, nuclear reactors and nuclear materials facilities in the United 

2 States must comply with NRC regulations, including accident dose limits. The nuclear reactors 

3 and other facilities within the ROI that use radiation or radioactive materials are Callaway, 

4 ABC Laboratories, University Hospital, Boone Hospital Center, and the existing MURR center. 

5 These facilities are licensed by the NRC and have demonstrated compliance with NRC’s dose 

6 limits for accident conditions, as applicable. Therefore, the NRC staff expects possible 

7 radiological accidents at these facilities to have minimal environmental impact. With the 

8 exception of the existing MURR center, the facilities within 5 mi (8 km) of the MURR site 

9 (ABC Laboratories, University Hospital, and Boone Hospital Center) are facilities for which no 

10 radiological material releases are expected (see Section 4.14.8.1). The existing MURR center 

11 would be located adjacent to a proposed NWMI facility at the MURR site. Accidents at the 

12 existing MURR center and a proposed NWMI facility at the MURR site would individually be 

13 expected to have minimal environmental impact because NRC-licensed facilities must comply 

14 with NRC regulations related to radiological accident consequences. However, due to the very 

15 close proximity of these two facilities, there is increased likelihood of a single scenario (such as 

16 an external event) that could cause accidents to occur at both facilities, creating the possibility 

17 for cumulative dose impacts greater than those for an accident at either facility individually. 

18 Therefore, if the NRC staff determines in its SER that the proposed NWMI facility at the 

19 Discovery Ridge site would comply with 10 CFR 70.61 and any other applicable NRC 

20 regulations regarding radiological accident consequences, the NRC staff concludes that the 

21 cumulative impact from potential radiological accidents for a proposed NWMI facility at the 

22 MURR site would be SMALL to MODERATE.

23 As discussed in Section 4.14.10.2, industrial, production, or other facilities in Missouri (including 

24 those in the ROIs for a proposed NWMI facility located at either the MURR or Discovery Ridge 

25 sites) are required to comply with EPA and State of Missouri regulations to ensure the safe 

26 handling of chemicals and hazardous materials. With the exception of the existing MURR 

27 center, all facilities or activities in Table 5–5 for which hazardous chemical releases could be 

28 expected would be located approximately 1.1 mi (1.8 km) or more from a proposed NWMI 

29 facility at the MURR site. The existing MURR center would be located adjacent to a proposed 

30 NWMI facility at the MURR site; however, as discussed previously in this section, the existing 

31 MURR center does not use hazardous chemicals in quantities that would make it subject to the 

32 EPA’s TRI reporting requirements, reducing the likelihood that any significant chemical release 

33 accident could occur in close proximity to a proposed NWMI facility at the MURR site. 

34 Therefore, if the NRC staff determines in its SER that the proposed NWMI facility would comply 

35 with 10 CFR 70.61 and any other applicable NRC regulations regarding hazardous chemical 

36 accident consequences, the NRC staff concludes that the cumulative impact from potential 

37 hazardous chemical accidents for a proposed NWMI facility at the MURR site would be SMALL.

38 Environmental Justice

39 The environmental justice cumulative impact analysis evaluates the potential contributory 

40 human health and environmental effects from the construction, operations, and 

41 decommissioning of the proposed NWMI facility when added to the effects from other past, 

42 present, and reasonably foreseeable future actions on minority and low-income populations and 

43 whether these effects might be disproportionately high and adverse. Everyone living near the 

44 proposed NWMI facility at the MURR site could be affected by construction, operations, and 

45 decommissioning activities, including minority and low-income populations.

46 The ROI is the 5-mi (8-km) region surrounding the proposed NWMI facility at the MURR site. 

47 As discussed in Section 5.2.2.12, the proposed NWMI facility is not located in a minority 

48 population block group. Minority and low-income populations residing along site access roads 

49 could be affected by noise, dust, and increased commuter vehicle and truck traffic during 
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1 construction, operations, and decommissioning. However, during construction and 

2 decommissioning, these would be short term and primarily limited to onsite activities. In 

3 addition, NWMI facility operations would not have high and adverse human health and 

4 environmental effects on minority and low-income populations. As a result, minority and 

5 low-income populations residing near the proposed NWMI facility at MURR would not 

6 experience disproportionately high and adverse human health and environmental effects from 

7 the proposed action.

8 Table 5–5 identifies past, present, and reasonably foreseeable future actions within the 

9 geographic area of analysis that could contribute cumulative human health and environmental 

10 effects. Potential impacts to minority and low-income populations from other past, present, and 

11 reasonably foreseeable future actions would mostly consist of environmental effects caused by 

12 construction and operation of new residential, commercial, and industrial developments 

13 (e.g., noise, dust, traffic, employment, and housing impacts). However, noise and dust impacts 

14 would be short term during construction and primarily limited to onsite activities. Minority and 

15 low-income populations residing along site access roads could be directly affected by an 

16 increase in commuter vehicle and truck traffic. However, these effects are not likely to be high 

17 and adverse and would be intermittent, only occurring when construction trucks and other 

18 vehicles pass by during certain hours of the day. Increased demand for housing could cause 

19 housing costs to rise. Increasing rental costs could disproportionately affect low-income 

20 populations that rely on inexpensive housing. However, given the availability of local labor and 

21 the likelihood that construction workers would commute to the work site, rental housing costs 

22 may be unaffected.

23 Emissions from new commercial or industrial facilities could also disproportionately affect 

24 minority and low-income populations. However, any impacts would depend on the magnitude of 

25 the change from current environmental conditions. Permitted air emissions from all commercial 

26 and industrial facilities, including the contributory effects from the proposed NWMI facility, would 

27 be expected to remain within regulatory standards.

28 Based on this information and the analysis of human health and other environmental impacts 

29 presented in this EIS, the contributory effects of constructing, operating, and decommissioning 

30 the proposed NWMI facility would not create disproportionately high and adverse cumulative 

31 human health and environmental effects on minority and low-income populations living near 

32 MURR.

33 5.3 Alternative Technologies

34 The purpose of the NWMI facility is to use LEU to domestically produce molybdenum-99 

35 (Mo-99) (Section 2.0). Other alternative medical radioisotope production technologies currently 

36 exist and have been proposed that could be used to create these isotopes (e.g., “Making 

37 Medical Isotopes: Report of the Task Force on Alternatives for Medical-Isotope Production 

38 (TRIUMF 2008) and Homogeneous Aqueous Solution Nuclear Reactors for the Production of 

39 Mo-99 [molybdenum-99] and other Short Lived Radioisotopes” (IAEA 2008)).

40 In this analysis of the alternative technologies, the NRC staff evaluated the potential 

41 environmental impacts if a commercial entity were to construct and operate a facility on the 

42 proposed Discovery Ridge site using an alternative technology. The NRC staff notes that no 

43 commercial entity (other than NWMI) has proposed building or operating a facility at the 

44 proposed Discovery Ridge site.
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1 5.3.1 Description of Alternative Technology Screening Process

2 5.3.1.1 Initial Screening

3 To begin the alternative technology evaluation, the NRC staff initially considered the range of 

4 possible alternatives, or various methods to produce Mo-99, including international commercial 

5 entities currently producing Mo-99 and several commercial entities proposing new methods to 

6 produce Mo-99 within the United States. The Council on Environmental Quality’s regulations 

7 implementing NEPA provide guidance when a large number of potential alternatives exist. In 

8 such situations, NEPA only requires that an agency analyze a reasonable number of examples, 

9 covering the full spectrum of alternatives, in the EIS (46 FR 18026).

10 For the purposes of this EIS, the NRC staff initially limited the alternative technologies analysis 

11 to the five technologies that the DOE’s National Nuclear Security Administration (NNSA), 

12 through the Office of Nuclear Nonproliferation’s Global Threat Reduction Initiative, awarded 

13 cooperative agreements (as of July 2016) for three main reasons. First of all, these 

14 technologies appear to be technically feasible. In awarding the cooperative agreements, NNSA 

15 based its decision, in part, on an evaluation of the technical feasibility. Secondly, the NRC is 

16 not aware of entities proposing to construct a new facility in the United States using technology 

17 currently being used in other countries. Therefore, based on the technology that has been 

18 proposed to create a domestic source of Mo-99, as of July 2016, the alternative technologies 

19 examined in the EIS include the type of technologies most likely to be constructed and operated 

20 within the United States. Lastly, the NRC staff concluded that the five entities awarded 

21 cooperative agreements used technologies that covered the spectrum of potential alternatives

22 based on the general land use requirements, power levels, and other environmental and 

23 engineering parameters.

24 The five alternative technologies include the following:

25 neutron capture technology,

26 aqueous homogenous reactor technology,

27 selective gas extraction technology, 

28 uranium fission technology, and

29 linear accelerator-based technology.

30 Neutron Capture Technology

31 The neutron capture technology produces Mo-99 by neutron irradiation of natural molybdenum 

32 in a boiling water reactor (GE-Hitachi 2011). Given that the proposed Discovery Ridge site does 

33 not contain a boiling water reactor, the NRC staff does not consider construction of a new power 

34 reactor to be reasonable, because the currently proposed site has insufficient space and other 

35 resources to support a power reactor. Alternatively, a research reactor could be used to 

36 produce Mo-99 using neutron capture technology. Sufficient space likely occurs on the 

37 proposed Discovery Ridge site to construct a new research reactor as part of the neutron 

38 capture alternative.

39 Aqueous Homogenous Reactor Technology

40 The LEU aqueous homogenous reactor technology produces Mo-99 using an aqueous 

41 homogenous reactor fueled by a uranium salt solution, followed by a series of chemical

42 processes to extract the Mo-99 (IAEA 2008; B&W 2012). The size of each reactor would be 

43 approximately 200 to 240 kilowatts, and it would be capable of producing about 1,100 6-day Ci 

44 on a weekly basis (IAEA 2008). The reactor fuel solution would contain LEU salt dissolved in 
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1 water and acid. This solution would also be the target material for Mo-99 production, as 

2 fissioning the uranium-235 would produce Mo-99 and other isotopes. The reactor would be 

3 operated until a sufficient amount of Mo-99 occurred in the fuel solution. The fuel solution would 

4 be removed and processed using chemical purification to extract the Mo-99 (IAEA 2013b).

5 Selective Gas Extraction Technology

6 The selective gas extraction technology produces Mo-99 by irradiating porous uranium oxide 

7 targets and then using a selective gas extraction process to extract the Mo-99 (Bertch 2014;

8 Grozelle 2016). For this technology, uranium targets would initially be placed within a tube and 

9 then irradiated within a research reactor. After irradiation, the target tube would be heated and 

10 gas would flow through the porous target to extract the Mo-99 in hot cells (Bertch 2014; 

11 Grozelle 2016). The target tube includes separate areas for gas delivery and collection. The 

12 target would be re-irradiated following the selective gas extraction process.

13 Uranium Fission Technology

14 The uranium fission technology would produce Mo-99 using a subcritical fission process 

15 followed by chemical extraction of Mo-99 (SHINE 2015). The process would use an accelerator 

16 and neutron multiplier to produce neutrons that would enter a tank containing a target solution 

17 with the fissile uranium-235 isotope. As neutrons collide with the uranium-235, the uranium 

18 would split and form other radioisotopes, including Mo-99, xenon-133, and iodine-131. 

19 Extraction and purification would occur within hot cells. During this process, Mo-99 extraction 

20 would occur as a batch process in which the irradiated uranyl sulfate target solution would be 

21 passed through an adsorption column to extract the isotopes. The extracted isotopes would 

22 then undergo dissolution and evaporation processes to yield a crude Mo-99 product. The 

23 purification process would remove impurities through small-scale additions of reagents and 

24 through precipitation, filtration, and boiling. LEU remaining in the target solution would be 

25 reused and would undergo cleanup for use as the target solution for subsequent cycles because 

26 only a small amount of uranium-235 is used up during each production run.

27 Linear Accelerator-Based Technology

28 The linear accelerator-based technology produces Mo-99 by utilizing an accelerator to irradiate 

29 natural molybdenum that has been enriched in the radioisotope molybdenum-100 (Mo-100) 

30 (DOE 2012). Targets made of molybdenum would be enriched in the radioisotope Mo-100 and 

31 would be irradiated (or bombarded) using a pair of accelerators. After bombardment, the 

32 targets would be removed and be shipped from the facility to an end user medical facility

33 (NorthStar 2015). After further processing at the end user medical facility, the spent or 

34 unusable portion of the radiochemical from the end user facility would be returned and reused.

35 5.3.1.2 Secondary Screening

36 For the next level of screening, the NRC staff searched for engineering and 

37 environmental data to describe the impacts from construction and operations for 

38 alternative technology within topical papers, white papers, environmental 

39 assessments, environmental reports, and other sources of information. Based on 

40 this review, the NRC staff did not find sufficient data to describe the potential 

41 environmental impacts from construction and operations of the neutron capture 

42 technology, aqueous homogenous reactor technology, nor the selective gas 

43 extraction technology due to the lack of environmental documents describing 

44 potential environmental impacts to the natural and human environmental from these 

45 technologies. Therefore, the NRC staff determined that insufficient environmental 

46 information exists to meaningfully analyze the environmental impacts of these 

47 technologies in detail. For these reasons, the NRC staff does not consider these 
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1 technologies reasonable alternatives and has excluded them from further 

2 consideration.

3 The NRC staff determined that sufficient environmental data exist regarding the 

4 potential impacts of construction, operations, and decommissioning for the uranium

5 fission alternative (SHINE 2015; NRC 2015c) and the linear accelerator-based 

6 alternative (DOE 2012). Therefore, in the following sections, the NRC staff 

7 evaluated in depth the potential environmental impacts if a commercial entity were to 

8 construct, operate, and decommission a uranium fission facility or a linear 

9 accelerator-based facility on the proposed Discovery Ridge site.

10 5.3.2 Linear Accelerator-Based Technology

11 The linear accelerator-based technology produces Mo-99 by using an accelerator to irradiate 

12 natural molybdenum that has been enriched in the radioisotope Mo-100. For the purpose of this 

13 analysis, the NRC staff assumed the facility would be similar to the facility described in NNSA’s 

14 “Environmental Assessment for NorthStar Medical Technologies LLC Commercial Domestic 

15 Production of the Medical Isotope Molybdenum-99” (DOE 2012). The NRC staff acknowledges 

16 that other commercial entities have proposed methods of producing Mo-99 using linear 

17 accelerator-based technology, such as Niowave, Inc. (Niowave 2015). However, for the 

18 purpose of this analysis, the NRC staff used the environmental parameters included in NNSA’s 

19 environmental assessment for the NorthStar Medical Radioisotope facility because this 

20 commercial entity was awarded a cooperative agreement by NNSA and sufficient environmental 

21 data exist regarding this proposed technology to conduct a meaningful analysis.

22 The facility for the linear accelerator-based alternative would have the capacity to produce 

23 approximately 3,000 6-day Ci per week. To produce Mo-99, the operator would use a target 

24 made of molybdenum enriched in the radioisotope Mo-100 and would irradiate (or bombard) the 

25 targets using a pair of accelerators. Up to 16 accelerators would be constructed and used 

26 during operations (DOE 2012). After bombardment, the operator would then ship Mo-99 from 

27 the facility to an end user medical facility (NorthStar 2015). After further processing at the end

28 user medical facility, the spent or unusable portion of the radiochemical from the end user 

29 facility would be returned.

30 During operations, the facility would produce radiolytic and other offgases such as nitrogen 

31 oxides (DOE 2012). The production process would also generate radioactive and 

32 nonradioactive liquid waste (DOE 2012).

33 The NRC staff assumed that the operator would construct a containment building for the 

34 accelerators and radioactive waste facility (DOE 2012). In addition, a separate building or parts 

35 of the building would contain the processing facility (e.g., hot cells and chemical laboratories), 

36 areas for shipping and receiving, and a waste management center. Support facilities, such as 

37 administration buildings, parking lots, and access roads, would be similar to those for the NWMI 

38 facility. Construction of a linear accelerator-based facility would take up to 18 months and 

39 require up to 50 workers (DOE 2012). The linear accelerator-based facility would have a 

combined building footprint of 77,000 ft2 (7,200 m2

) and excavate 21,000 m3 (28,000 yd3 40 ) of soil

41 and rock material (DOE 2012). Operation of a linear accelerator-based facility would require up 

42 to 150 workers (DOE 2012).

43 A description of the affected environment for the Discovery Ridge site is provided in Chapter 3 

44 of the EIS. The following sections describe the impacts of constructing, operating, and 

45 decommissioning the proposed NWMI facility utilizing the linear accelerator-based technology.
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1 5.3.2.1 Land Use and Visual Resources

2 Land use impacts of a linear accelerator-based alternative at the Discovery Ridge site would be 

3 confined to the 7.4 ac (3.0 ha) site. The linear accelerator-based alternative would disturb a 

4 similar amount of land as the proposed NWMI facility (DOE 2012). The highest structure would 

5 be the emissions stack for chemical processing, which would extend approximately 18 m (60 ft) 

6 in height, with a diameter of 0.6 m (2 ft) (DOE 2012). Therefore, the height of the buildings for 

7 the accelerator-based alternative would be bounded by the parameters analyzed for the NWMI 

8 facility in Section 4.1. As described in Section 4.1, land use impacts during construction, 

9 operations, and decommissioning would be SMALL, because the entire site is currently certified 

10 for industrial use, and the permanently converted agricultural land would be a small portion of 

11 available agricultural land within the vicinity. As described in Section 4.1, aesthetic impacts 

12 during construction, operations, and decommissioning would be SMALL at the proposed 

13 Discovery Ridge site, given that a light industrial development landscape surrounds part of the 

14 site and the visual setting is generally flat and has a uniform landform with low vegetation 

15 diversity and a low visual-quality rating. Based on a similar land disturbance and building height 

16 for the linear accelerator-based alternative, land use and visual impacts would be SMALL during 

17 construction, operations, and decommissioning of a linear accelerator-based facility on the 

18 Discovery Ridge site.

19 5.3.2.2 Air Quality and Noise

20 Air Quality

21 Construction

22 Construction activities associated with building a linear accelerator-based facility would 

23 generate air pollutant emissions from site-disturbing activities (e.g., grading, compacting), 

24 operation of construction equipment, and worker and shipment vehicles. Emissions from 

25 construction are presented in Table 5–6.

26 Table 5–6. Estimated Air Emissions Resulting from Construction of a Linear

27 Accelerator-Based Facility

Total Emissions 

(ton/year)(a)

Nitrogen Oxides (NOx) 8

Carbon Monoxide (CO) 6

Sulfur Dioxide (SO2) 0.5

Particulate Matter less than 10 microns (μm) (PM10) 17

Particulate Matter less than 2.5 μm (PM2.5) 3

Carbon Dioxide (CO2) 1,500

(a) Accounts for emission from construction equipment, fugitive dust, and worker and delivery vehicle 

emissions. Estimates obtained from DOE 2012.

28 While emissions would be greater than construction of the proposed NWMI facility, emissions 

29 would be below the significant de minimis levels under the New Source Review program 

30 discussed in Section 3.2.2 of this EIS. Therefore, the NRC staff does not expect increases in air 

31 emissions from construction activities of a linear accelerator-based technology at the Discovery 

32 Ridge site to contribute to concentrations that would exceed NAAQS in Boone County. The 
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1 NRC staff concludes that air quality impacts during construction of a linear accelerator-based 

2 technology at the Discovery Ridge site would be SMALL.

3 Operations

4 Operation of a linear accelerator-based facility would produce air emissions from operation of 

5 the building heating system, emergency generator, chemical processing, and worker vehicles. 

6 Total emissions from operations of a linear accelerator-based facility are presented in 

7 Table 5–7.

8 Table 5–7. Estimated Air Emissions Resulting from Operation of a Linear

9 Accelerator-Based Facility 

Total Emissions (ton/year)(a)

Nitrogen Oxides (NOx) 9

Carbon Monoxide (CO) 6.5

Sulfur Dioxide (SO2) 0.01

Particulate Matter less than 10 microns (μm) (PM10) 0.3

Particulate Matter less than 2.5 μm (PM2.5) 0.03

Carbon Dioxide (CO2) 40,000

(a) Accounts for emission from emergency generators, building heating system, process operations, 

and worker vehicles. Estimates obtained from DOE 2012 and rounded up.

10 Total operation-related emissions for criteria pollutants are well below the significant de minimis 

11 levels under the New Source Review program and major source under Title V operating source 

12 threshold (100 TPY) discussed Section 3.2.2 of this EIS. Therefore, the NRC staff does not 

13 expect increases in air emissions from operation activities of a linear facility at the Discovery 

14 Ridge site to contribute to concentrations that would interfere with the maintenance NAAQS or 

15 degrade Boone County’s attainment/unclassifiable designation.

16 Decommissioning

17 Decommissioning activities would be similar to construction activities. The decommissioning 

18 activities would include, for example, vehicular traffic, earth-moving equipment, demolition of 

19 structures, and dismantlement and decontamination of systems. Emissions would be similar to 

20 what is presented in Table 5–6, above. Similarly, the NRC staff concludes that air quality 

21 impacts during decommissioning of a linear accelerator-based technology at the Discovery 

22 Ridge site would be SMALL.

23 Noise

24 Construction

25 Noise emissions during construction would occur because of increased traffic volumes from 

26 worker vehicles and because of the use of construction equipment on site. Noise from 

27 construction equipment would be localized, short term, and intermittent during machinery 

28 operations. Noise levels from construction equipment is predicted to be 65 dBA at 210 m 

29 (0.13 mi) distance from the equipment (DOE 2012). Noise levels from construction equipment 

30 therefore would not exceed existing noise levels at the sensitive receptors to the Discovery 

31 Ridge Site. The number of worker vehicles expected during construction is 50 (DOE 2012), all 

32 of which, for purposes of this analysis, are assumed to travel along U.S. Highway 63 during 

33 hours when work starts and stops. Sound levels increase at a rate of 3 dBA per doubling of 
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1 traffic volumes. Conservatively assuming that all worker vehicles and deliveries travel on 

2 U.S. Highway 63 at the same time, this will result in a traffic volume of 868 vehicles/hr. This 

3 increase in traffic will not result in noise levels that will be noticeable from a traffic volume of 

4 818 vehicles/hr.

5 Given that increases in noise levels as a result of additional vehicle traffic will not be noticeable 

6 and noise levels from construction equipment are not anticipated to exceed existing ambient 

7 noise levels, the NRC staff concludes that offsite noise impacts from construction would be 

8 SMALL.

9 Operations

10 Noise emissions during operation would occur because of increased traffic and the cooling 

11 tower. Noise from most operating equipment would be contained inside buildings and are not 

12 anticipated to be audible outside the linear accelerator-based facility (DOE 2012). Cooling 

13 tower noise levels are estimated to reach 60 dBA at a distance of 9 m (30 ft) from the cooling 

14 towers, which would not be noticeable given existing ambient noise levels at the Discovery 

15 Ridge site. The number of worker vehicles expected during operation is 150 (DOE 2012). 

16 Adding this traffic volume to existing traffic levels along U.S. Highway 63 will not result in noise 

17 levels that would be noticeable (less than 3 dBA increase). Therefore, the NRC staff concludes 

18 that noise impacts from operation of a linear accelerator-based facility at the Discovery Ridge 

19 site would be SMALL.

20 Decommissioning

21 Noise emissions during decommissioning would occur because of increased traffic volumes 

22 from worker vehicles and the use of equipment on site. Equipment during decommissioning 

23 would be similar to that used during the construction phase. As discussed above, noise levels 

24 from construction equipment for a linear accelerator-based facility are not expected to exceed 

25 existing noise levels. Similarly, noise levels from additional worker vehicles are not anticipated 

26 to be noticeable. Therefore, given that increases in noise levels as a result of additional vehicle 

27 traffic will not be noticeable and noise levels from equipment are not anticipated to exceed 

28 existing ambient noise levels, the NRC staff concludes that noise impacts from 

29 decommissioning a linear accelerator-based facility at the Discovery Ridge site would be 

30 SMALL.

31 5.3.2.3 Geologic Environment

32 Geology and Soils

33 Construction

34 Impacts on geology and soils associated with construction of a linear accelerator-based facility 

35 at the Discovery Ridge site would likely be similar to but somewhat greater than the impacts 

36 described for the proposed technology alternative, as presented in Section 4.3.1. The potential 

37 for greater impacts under this technology alternative is attributable to the larger footprint of the 

linear accelerator-based facility (77,000 ft2 (7,200 m2 38 )) and the greater depth of excavation 

39 required (i.e., up to 30 ft (9 m)) in order to construct the below-grade portions of the facility 

40 (DOE 2012). As the depth to bedrock beneath the site is on the order of 25 ft (7.6 m) or less 

41 (Section 3.3.1), it is possible that blasting and other construction methods may be required 

42 during foundation excavation, depending on such factors as the depth of bedrock weathering. 

43 As for the proposed technology, the NRC staff assumes that the entire 7.4 ac (3.0 ha) site would 

44 be disturbed during construction of the linear accelerator-based facility.

45 The larger footprint that would be cleared, graded, and compacted along with the greater 

46 excavation depth would increase the potential for soil erosion and loss. Nevertheless, 
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1 construction activities would be subject to the same site development permitting and associated 

2 regulatory requirements previously described in Section 4.3.1. For instance, NWMI would need 

3 to conduct site work in accordance with a Land Disturbance Permit from the City of Columbia in 

4 accordance with Chapter 12A, Article II (Land Preservation) of the City’s Code of Ordinances 

5 (City of Columbia 2015). NWMI would need to prepare a soil erosion and sediment control plan 

6 and a stormwater management plan. These plans entail the implementation of 

7 construction-related BMPs for soil erosion and sediment control and stormwater pollution 

8 prevention during site development, facility construction, and for post development.

9 As described in Sections 3.3.1 and 3.3.2 and evaluated as for potential impacts in Section 4.3.1 

10 for the proposed alternative, the site presents construction challenges that will need to be 

11 addressed during facility construction, along with possible mitigative features incorporated into 

12 the facility design. These challenges include the depth to bedrock, the potential for a seasonally 

13 high water table or perched groundwater, and the occurrence of soils with construction 

14 limitations (e.g., fat clays with a high shrink/swell potential). NWMI will conduct a site-specific 

15 geotechnical and hydrological studies of the Discovery Ridge site to characterize site conditions 

16 in support of final facility design.

17 As summarized in Section 2.2, Table 2–1 for the proposed alternative, geologic resources would 

18 also be required to support construction of a linear accelerator-based facility; these resources 

19 include granular stone (e.g., typically crushed aggregate (sand and gravel)) and aggregate to 

20 produce ready-mix concrete. Nevertheless, as noted in Section 3.3.1, construction aggregate is 

21 widely available throughout Boone County and northeast Missouri; therefore, their consumption 

22 to support facility construction under this alternative would not likely deplete local or regional 

23 stockpiles of such geologic resources.

24 Excavation of the below-grade portion of a linear accelerator-based facility to a depth of up to 

30 ft (9.1 m) would result in the removal of up to approximately 28,000 yd3 (21,000 m3 25 ) of soil, 

sediments, and rock material, as compared to 9,000 yd3 (6,900 m3 26 ) for the proposed alternative. 

27 DOE (2012) indicates that the excavated material would be used on site for grading purposes, 

28 and presumably for backfill, or transported off site for disposal or reuse. Soils at the Discovery 

29 Ridge site, particularly the fat clays, have poor shear strength when wetted and have generally 

30 poor workability as a construction material, including for use as structural (engineered) backfill 

31 (Section 3.3.1). Consequently, the NRC staff expects that at least some proportion of this 

32 excavated material may need to be replaced with engineered backfill from offsite sources, thus 

33 adding to the volume of onsite earthwork required and geologic materials consumed. Still, the 

34 NRC staff expects that soils and other materials with the necessary engineering properties are 

35 readily obtainable from sources throughout the City of Columbia area and across Boone 

36 County.

37 Potential impacts on the geologic environment from construction of a linear accelerator-based 

38 facility at the Discovery Ridge site, to include soil loss and geologic resource consumption, 

39 would be similar to but somewhat greater than those associated with the proposed technology 

40 alternative. Site conditions also present somewhat greater constraints on site development and 

41 linear accelerator-based facility construction because of the larger facility footprint and greater 

42 excavation depth required. However, as for the proposed technology, the completion of detailed 

43 site-specific geotechnical studies would serve to reduce the cited uncertainties with respect to 

44 site geologic and soil conditions. Overall, the NRC staff concludes that the impacts on the 

45 geologic environment from the construction of a linear accelerator-based facility would also be 

46 SMALL.
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1 Operations

2 Operational impacts on the geologic environment would be negligible under this technology 

3 alternative. During facility operations, previously disturbed areas would not be subject to 

4 long-term soil erosion. Areas disturbed during construction would be within the footprint of the 

5 completed facility or overlain by other impervious surfaces (such as roadways and parking lots), 

6 or revegetated.

7 Regardless of the technology, final facility design and construction would comply with applicable 

8 building codes and standards, which provide for the evaluation of site geologic and soil

9 conditions, including potential seismic hazards. Completion of site-specific geotechnical and 

10 hydrological studies, as discussed in Section 4.3.1, would inform final facility design for the 

11 linear accelerator-based technology and construction considerations. The NRC staff concludes 

12 that linear accelerator-based facility operational impacts associated with the geologic 

13 environment at the proposed site would be SMALL.

14 Decommissioning

15 Compacted site soils and underlying sediments would be disturbed by facility demolition and 

16 decontamination work. The impacts on site geology and soils would be similar in scope to those 

17 described for construction. For the linear accelerator-based facility, the potential for soil erosion

18 and loss would be somewhat greater than for the proposed NWMI technology primarily because 

19 of the larger facility footprint. Regardless, all site clearing to restore the proposed site to a 

20 reusable condition would be subject to applicable permits and approvals (e.g., demolition or 

21 clearance permit) and the applicable provisions, including Chapter 6, Article II (Building Code) of 

22 the City of Columbia’s Code of Ordinances (City of Columbia 2015).

23 Before beginning to dismantle onsite structures, NWMI would remove waste materials and 

24 contaminated media from the structures. Materials would be packaged and properly disposed 

25 of as discussed in Section 5.3.2.9. Thus, these materials would not pose a contamination threat 

26 to site soils or water resources. NWMI would be required to conduct all decommissioning 

27 activities in accordance with a decommissioning plan submitted to the NRC and applicable 

28 regulations, as described in Section 2.9. As a result, the NRC staff concludes that impacts on 

29 the geologic environment from facility decommissioning would be SMALL.

30 5.3.2.4 Water Resources

31 Surface Water and Groundwater Resources

32 Construction

33 Impacts on surface water and groundwater resources from construction activities associated 

34 with the linear accelerator-based technology alternative would be similar to but somewhat 

35 greater than those under the proposed technology alternative (see Sections 4.4.1.1 

36 and 4.4.2.1). The potential for greater impacts is attributable to the additional land affected 

37 because of the larger footprint of the facility and the greater depth of excavation, as referenced 

38 in Section 5.3.2.3. Otherwise, the same general assumptions, impact considerations, and 

39 regulatory parameters discussed for the proposed alternative apply to this alternative.

40 Site construction activities would have no direct impact on surface water resources. No natural 

41 surface water features occur on the Discovery Ridge site, and the site is not located in an area 

42 susceptible to flooding or in a delineated floodplain, as discussed in Section 3.4.1. During 

43 construction, however, stormwater runoff from construction areas could potentially affect 

44 downstream surface water quality if not properly managed. NWMI would be required to obtain a 

45 Land Disturbance Permit from the City of Columbia and submit related plans for City approval 

46 before any ground-disturbing activities or facility construction could begin on the site, as 
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1 referenced in Section 5.3.2.3. The City would require that appropriate soil erosion and sediment 

2 control BMPs be used to minimize soil erosion and the stormwater transport of suspended 

3 sediment and other pollutants.

4 Construction stormwater runoff from the site would also be subject to regulation in accordance 

5 with CWA Section 402. Under the State of Missouri’s delegated authority for administering the 

6 NPDES permit program pursuant to Section 402, the State has developed an NPDES general 

7 permit for construction stormwater. Permit coverage must be obtained by facility owners and 

8 operators for the discharge of stormwater and certain non-stormwater discharges

9 (e.g., dewatering flows) from land-disturbance sites that disturb 1 ac (0.4 ha) or more, as further 

10 described in Section 4.4.1.1. NWMI’s construction activities would be subject to NPDES permit 

11 and other local regulations for soil erosion and sediment control and construction stormwater 

12 management.

13 In addition, under CWA Section 401, an applicant for a Federal license or permit to conduct any 

14 activities, including facility construction or operation, that may cause a discharge into navigable 

15 waters is required to provide the Federal licensing agency with a certification from the state or 

16 agency having jurisdiction in which the discharge would originate. As discussed in 

17 Section 4.4.1.1 for the Discovery Ridge site, NWMI has stated that no State certification is 

18 required under CWA Section 401 (NWMI 2015a). NWMI also has stated that it would seek a 

19 waiver from the State (NWMI 2015c). However, because the NRC cannot issue a license or 

20 permit until the required certification is submitted, NWMI must provide the NRC with either a 

21 401 certification from the State of Missouri, a waiver, or other State documentation that a 

22 Section 401 certification is not necessary.

23 The need for groundwater dewatering would be more likely under this alternative. This is due to 

24 the greater depth of excavation (i.e., up to 30 ft (7 m)) expected for the below-grade portion of 

25 the linear accelerator-based facility. The volume of groundwater requiring removal could be 

26 greater than the maximum volume projected by NWMI for the proposed technology, as 

27 described in Section 4.4.2.1.

28 As such, the NRC staff expects that dewatering could have minor effects on the vertical and 

29 horizontal extent of shallow groundwater, if present, and on groundwater flow direction, but any 

30 effects would be localized and temporary. Notwithstanding, NWMI would conduct site-specific 

31 geotechnical and hydrologic studies of the Discovery Ridge site that would characterize 

32 groundwater conditions beneath the site (NWMI 2015c). These results would guide any 

33 necessary construction accommodations and final facility design.

34 Other than the need for construction dewatering, no surface water or onsite groundwater would 

35 be withdrawn to support construction for this technology alternative. Water would be required 

36 during facility construction for such uses as dust control and soil compaction as well as to meet 

37 the drinking and sanitary needs of the construction workforce during the construction period.

38 Water lines and other utilities are already in place at the southwest corner of the Discovery 

39 Ridge site, with public water provided by Consolidated Public Water Supply District No. 1 

40 (Section 4.4.2.1). The district uses groundwater as its supply source, and it has a total 

groundwater production capacity of 11 mgd (49,200 m3 41 /day) and currently supplies 

approximately 1.45 mgd (5,490 m3 42 /day) to customers.

43 The NRC staff estimates that onsite water needs to support linear accelerator-based facility 

44 construction would be similar to but greater than those for the proposed technology alternative, 

45 with the difference attributable primarily to the larger footprint of the facility. The NRC staff 

46 estimates that construction activities would require an average of 7,200 gpd (27,300 Lpd) of 

water. This is equivalent to 0.0072 mgd (27.2 m3 47 /day). Total projected water use for the slightly 
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1 longer construction period (18 months) as compared to the NWMI proposed technology 

2 alternative would be about 2.6 million gal (9.8 million L). The projected average daily water 

3 needs for facility construction under this alternative is a very small percentage (i.e., about 

4 0.50 and 0.07 percent) of the public water district’s existing demand and available production 

5 capacity, respectively.

6 As stated in Section 4.4.1.1, the construction contractor would provide portable restroom 

7 facilities for the construction workforce. This measure would reduce the quantity of water 

8 required for potable and sanitary uses. These facilities would be serviced off site by a 

9 commercial vendor, alleviating any potential surface water or groundwater quality concerns.

10 Construction activities would not disturb any surface water features under this technology 

11 alternative, and NWMI would be required to prepare site-specific plans and implement BMPs in 

12 accordance with local and MDNR requirements to mitigate the potential impacts on surface 

13 water quality associated with construction activities. No surface water or onsite groundwater 

14 would be used to support facility construction. Construction dewatering would be likely during 

15 construction, but site-specific geotechnical and hydrologic studies will further characterize 

16 subsurface conditions, and dewatering activities would be conducted in accordance with 

17 regulatory requirements. The volume of water required to support onsite construction activities 

18 would be a very small percentage of the public utility’s existing demand and available production 

19 capacity. The NRC staff concludes that the impacts on surface water and groundwater 

20 hydrology, quality, and use from the construction of a linear accelerator-based facility would be 

21 SMALL.

22 Operations

23 Under the linear accelerator-based technology alternative, normal facility operations would not 

24 have any direct impact on surface water or groundwater hydrology or quality. As described in 

25 Sections 4.4.1.2 and 4.4.2.2 for the proposed alternative at the Discovery Ridge site, 

26 stormwater runoff from the facility site would also be managed by an engineered stormwater 

27 management system, including necessary detention/retention structures, constructed and 

28 operated in compliance with applicable local, State, and Federal stormwater management 

29 permits, plans, procedures, and practices.

30 The NRC staff estimates that operation of the linear accelerator-based technology facility would 

31 normally require less water than the proposed technology alternative. This is because the 

32 volume of water necessary to meet workforce potable and sanitary needs is the primary

33 component of total facility use. A closed-loop cooling system would normally operate to service 

34 the accelerators. Initial cooling system makeup requirements would total about 3,000 gal 

35 (11,400 L). This water would circulate internally and would need to be replenished only 

36 periodically. However, the use of a hybrid, evaporative cooling system may be necessary 

37 during the summer. This would require additional makeup water totaling 2,800 gpd 

38 (11,000 Lpd) during the summer months (DOE 2012).

39 The NRC staff estimates that an average of 4,000 gpd (15,100 Lpd) of water, equivalent to 

0.004 mgd (15.1 m3 40 /day), would be required to support facility operations under this alternative. 

41 Consolidated Public Water Supply District No. 1 would also provide water service to the site and 

42 facility under this alternative. The projected average daily water use for this technology 

43 alternative is a negligible percentage of the production capacity of the water district and 

44 represents a very small increase (about 0.3 percent) in the volume of water that the district 

45 supplies to its customers.

46 There would be no radioactive liquid effluents released from the facility. Liquid waste generated 

47 during operations would be collected and stored by NWMI, and there would be no release of 
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1 radioactive material through wastewater. All facility operations would be contained inside 

2 properly constructed buildings with proper material- and waste-handling facilities and spill 

3 prevention/cleanup capabilities (DOE 2012). As designed, only sanitary wastewater would be 

4 discharged to the sanitary sewer system serving the site (DOE 2012). The NRC staff estimates 

5 that sanitary effluent flow would average 3,300 gpd (12,500 Lpd). This is equivalent to 

approximately 0.0033 mgd (12.5 m3 6 /day). This effluent would be treated at the Columbia 

7 Regional WWTP. The Columbia Regional WWTP has a design treatment capacity of 20 mgd 

(75,700 m3

/day) with average demand of 16 mgd (60,600 m3 8 /day). The sanitary effluent flow 

9 under this technology alternative would be a very small percentage (i.e., 0.08 percent) of the 

10 available treatment capacity of the WWTP. The effluent would be required to meet the sewer 

11 system’s influent acceptance and treatment criteria, as well as NRC’s regulations at 

12 10 CFR 20.2003.

13 Under this technology alternative, there would be no radiological or nonradiological impacts on 

14 surface water or groundwater during normal operations. Facility operations would need to 

15 comply with local, State, and Federal stormwater management permits, plans, procedures, and 

16 practices. Water requirements and sanitary effluent treatment needs would be met by public 

17 facilities, which have adequate capacity. As a result, the NRC staff concludes that the impacts 

18 on surface and groundwater hydrology, water quality, and water use from the operation of a 

19 linear accelerator-based facility would be SMALL.

20 Decommissioning

21 Facility decontamination, demolition, and site-restoration activities would be similar to those 

22 under the proposed technology alternative, with the potential magnitude of the impacts on 

23 surface water and groundwater similar to those discussed above for construction. NWMI would 

24 perform demolition and site-restoration activities in accordance with applicable local and State 

25 permits and approvals, including a State-issued NPDES general permit for the discharge of 

26 stormwater from land-disturbance sites, as described in Section 4.4.1.1 for construction. NWMI 

27 would use appropriate construction BMPs, including waste handling and pollution prevention 

28 practices and response procedures during decommissioning, so that no materials or 

29 contaminants are released to soils, surface water, or underlying groundwater.

30 NWMI would conduct work in accordance with a decommissioning plan submitted to the NRC. 

31 NWMI would be required to conduct necessary surveys of the soils and subsurface to comply 

32 with the NRC’s radiological criteria for license termination in 10 CFR Part 20, Subpart E. The 

33 NRC staff also expects that NWMI would sample soils and other media as necessary in 

34 accordance with other required local and State permits and approvals to ensure that no 

35 nonradiological contamination remains in excess of action levels.

36 Water would be required for dust control and soil compaction during decommissioning. Based 

37 on facility size and dimensions as compared to the proposed technology alternative, the NRC 

38 staff estimates that decommissioning activities would require an average of 2,300 gpd 

(8,700 Lpd) of water, equivalent to 0.0023 mgd (8.7 m3 39 /day) during the decommissioning period. 

40 The NRC staff assumes that Consolidated Public Water Supply District No. 1 would also supply 

41 water needed for decommissioning. The projected water volume needed is less than the 

42 volume required for facility construction, as discussed above, and the impacts on supply 

43 capacity would similarly be negligible.

44 Since decommissioning activities would be conducted in accordance with pollution prevention 

45 and spill response procedures as part of local and State permit requirements for 

46 ground-disturbing activities and water needs would be minimal, the NRC staff concludes that the 

47 impacts on surface water and groundwater resources from facility decommissioning would be 

48 SMALL.
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1 5.3.2.5 Ecological Resources

2 The linear accelerator-based alternative would disturb a similar amount of land as the proposed 

3 NWMI facility. Directly affected vegetation would be limited to non-native, common, or weedy 

4 species, which are abundant within the region and provide relatively low-quality habitat for birds 

5 and wildlife in comparison to forests, grasslands, and wetland habitats. In addition to a loss of 

6 habitat, noise from construction activities could disturb birds and wildlife. In response to such 

7 disturbances and loss of habitat, birds and wildlife could move out of the immediate area and 

8 find adequate, similar habitat (agricultural fields) within the vicinity. All other impacts on 

9 ecological resources, such as bird collisions, disturbance during maintenance activities, and 

10 potential runoff to offsite aquatic resources, are expected to be similar to those described for the 

11 proposed NWMI facility in Section 4.5 because of similar construction methods, similar amount 

12 of land disturbed, and similar operating and decommissioning activities. Therefore, the NRC 

13 staff concludes that the impacts on ecological resources from a linear accelerator-based facility 

14 at the Discovery Ridge site would be SMALL during construction, operations, and 

15 decommissioning.

16 5.3.2.6 Historic and Cultural Resources

17 Impacts to historic and cultural resources from the linear accelerator-based alternative would be 

18 similar to those described for the proposed NWMI facility in Section 4.6. With no historic 

19 properties affected, no archaeological sites or evidence of cultural resources identified during 

20 the Phase I survey (NWMI 2015a), tribal input, and the cultural resource assessment and 

21 consultations performed by the NRC staff, constructing, operating, and decommissioning the 

22 NWMI facility using this alternative technology would not impact any known historic and cultural 

23 resources at the Discovery Ridge site.

24 5.3.2.7 Socioeconomics

25 Socioeconomic impacts from the linear accelerator-based alternative would be similar to those 

26 described for the proposed NWMI facility in Section 4.7. This technology alternative would 

27 require up to 50 construction workers and up to 150 workers during facility operations. The 

28 number of construction workers for the linear accelerator-based alternative would be fewer than 

29 the subcritical fission process alternative and the proposed NWMI facility. The number of 

30 operation workers for the linear accelerator-based alternative and the subcritical fission process 

31 alternative would be the same but higher than the proposed NWMI facility. These are peak 

32 estimates of workers, and the average daily number of operations workers would be much less. 

33 Most, if not all, workers would likely reside within the ROI or adjacent counties and communities 

34 and commute to the work site. Even if the estimated number of operations workers (150) were 

35 to generate two to three times additional employment in the ROI, the combined total number of 

36 workers would represent less than three-quarters of a percent of the current civilian labor force 

37 in Boone County. This would have little to no noticeable effect on employment levels or public 

38 services demands in the ROI. Given the size of the workforce, socioeconomic impacts for 

39 constructing, operating, and decommissioning the linear accelerator-based technology 

40 alternative at the Discovery Ridge site would be SMALL.

41 5.3.2.8 Human Health

42 The NRC staff expects human health impacts from the linear accelerator-based alternative to be 

43 similar to those described in Section 4.8 for the proposed NWMI facility. Like the proposed 

44 NWMI facility, the linear accelerator-based facility would be required to comply with all Federal 

45 and State regulations, protecting workers and members of the public during construction, 

46 operations, and decommissioning. For example, OSHA regulations would protect workers from 

47 physical occupational hazards; OSHA and EPA regulations would protect workers and the 
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1 public from hazardous material and chemical hazards; and NRC regulations would protect 

2 workers and the public from radiological hazards. Additionally, the NRC staff expects that for 

3 both radiological and nonradiological hazards, the linear accelerator-based alternative would 

4 incorporate engineered design features and procedural controls to minimize any impacts to 

5 workers or the public (DOE 2012).

6 Operation of the linear accelerator-based facility would require transportation of nonradioactive 

7 natural molybdenum target material to the facility. Radioactive materials transportation 

8 associated with the linear accelerator-based facility would include transportation of Mo-99

9 product from the facility to an end user medical facility, and transportation of the spent or 

10 unusable portion of Mo-99 product back to the linear accelerator-based facility for reuse. 

11 However, since the linear accelerator-based facility would not use or handle LEU, no 

12 transportation of irradiated or unirradiated LEU targets would occur in conjunction with operation 

13 of the facility (DOE 2012). All transportation would be in compliance with NRC and DOT

14 regulations.

15 Given the safety-oriented design and procedures at a facility using the linear accelerator-based 

16 alternative, and given that this facility would be required to comply with all Federal and State of 

17 Missouri regulations, ensuring that public health and safety are protected, the NRC staff 

18 concludes that the human health impacts from construction, operations, and decommissioning 

19 of the linear accelerator-based alternative would be SMALL.

20 5.3.2.9 Waste Management

21 The NRC staff assumes that waste management impacts from the linear accelerator-based 

22 alternative would be similar to those described in Section 4.9 for the proposed NWMI facility. 

23 Based on comparisons with similar proposed linear accelerator-based facilities, the NRC staff 

24 expects that the linear accelerator-based alternative would generate approximately 160 metric 

25 tons (175 tons) of solid waste (construction debris) during construction, and operation of the 

linear accelerator-based alternative would generate about 10.4 m3 (14 yd3 26 ) of low-level 

radioactive waste, 2.4 m3 (3.1 yd3

) of hazardous waste, and 45 m3 (59 yd3 27 ) of nonradioactive, 

28 nonhazardous waste annually (DOE 2012). Compared to the volumes of waste that would be 

29 produced by the proposed NWMI facility (NWMI 2015c), these volumes of hazardous and 

30 nonradioactive, nonhazardous waste generated by the linear accelerator-based alternative 

31 would be similar, and the volume of radioactive waste would be significantly smaller. As 

32 discussed in Section 4.14.9, the NRC staff assumes that sufficient infrastructure exists in the 

33 City of Columbia, Missouri, area for proper management of wastes from the proposed NWMI 

34 facility; therefore, the infrastructure would also be sufficient to handle waste from the linear 

35 accelerator-based alternative. In addition, the operator of the linear accelerator-based 

36 alternative would be required to comply with NRC, DOT, State of Missouri, and local 

37 requirements, as applicable, regarding disposal, handling, and transportation of waste. Since 

38 adequate infrastructure exists for waste disposal in the City of Columbia, Missouri, area, and 

39 since waste disposal would be required to be conducted in accordance with all applicable 

40 regulations, the NRC staff concludes that the impacts from waste management during 

41 construction, operations, and decommissioning of the linear accelerator-based alternative would 

42 be SMALL.

43 5.3.2.10 Transportation

44 Transportation impacts from the linear accelerator-based alternative would be similar to those 

45 described for the proposed NWMI facility in Section 4.10. Construction, operations, and 

46 decommissioning activities would be very similar and over same time span. Transportation 

47 impacts would consist of commuting workers and truck deliveries and shipments of equipment 

48 and materials. During periods of peak construction up to 50 workers and operations up to 
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1 150 workers could be commuting daily to the work site. Workers would arrive via site access 

2 roads and the volume of traffic on nearby roads could increase during shift changes. In addition 

3 to commuting workers, trucks would be transporting equipment and materials to and from the 

4 work site, thus increasing the amount of traffic on local roads. Up to 10 to 20 truck shipments 

5 per day would occur during operations (DOE 2012). The increase in vehicular traffic would 

6 peak during shift changes, resulting in temporary levels of service impacts and delays at 

7 intersections. However, given the size of the average daily workforce, the number of daily truck 

8 deliveries and shipments combined with the easy access to U.S. Highway 63, there would be 

9 little if any noticeable traffic volume-related level of service impacts. Therefore, transportation 

10 impacts during the construction, operations, and decommissioning of the NWMI facility using the 

11 linear accelerator-based technology at the Discovery Ridge site would be SMALL.

12 5.3.2.11 Accidents

13 DOE previously assessed a range of accidents involving either radioactive Mo-99, or chemicals 

14 that would be used during Mo-99 production, for a potential linear accelerator-based facility 

15 (DOE 2012). The accident scenarios were chosen such that the accidents considered would 

16 represent the range of possible accident consequences given the design, operating parameters, 

17 and types of materials that would be present at the facility. Possible internal accidents 

18 (e.g., fire), external accidents (e.g., tornado), and sabotage events were all considered. For 

19 evaluation of impacts of accidents to members of the public, DOE’s assessment considered the 

20 nearest member of the public to the facility to be located at a site boundary 20 m (65.6 ft) from 

21 the facility (DOE 2012).

22 This assessment determined that, for an extremely unlikely severe chemical accident involving 

23 an explosion-, fire-, earthquake-, or tornado-induced release of helium from the facility (the 

24 highest-consequence chemical accident considered), assuming average meteorological 

25 conditions, PAC-1, PAC-2, and PAC-3 limits would not be exceeded at the location of the 

26 maximally exposed member of the public. This means that no significant health effects would 

27 be expected for members of the public as a result of this accident for average meteorological 

28 conditions (PAC-1, PAC-2, and PAC-3 limits are defined in Section 4.11.2). However, DOE’s 

29 assessment also determined that, for 95th percentile meteorological conditions 

30 (i.e., meteorological conditions that would result in greater exposure than the conditions that 

31 occur 95 percent of the time), the helium concentration at the location of the maximally exposed 

32 member of the public would exceed the PAC-3 limits; concentrations above PAC-3 limits could 

33 result in life-threatening health effects or death. (DOE 2012).

34 DOE’s assessment considered two broad types of radiological accidents: accidents or events 

35 that could result in an airborne release of radioactive material, and accidents that could result in 

36 direct radiation exposure. The assessment determined that, for a sabotage event (i.e., an 

37 intentional action by a person inside or outside of the facility intending to cause harm to workers

38 or members of the public) resulting in an airborne release of Mo-99, the dose to a maximally 

39 exposed member of the public would be 130 mrem for average meteorological conditions, and 

40 560 mrem for 95th percentile meteorological conditions. This was the highest consequence 

41 airborne release of radioactive material accident or event considered. The assessment also 

42 determined that, for an earthquake-, tornado-, or aircraft impact-induced accident that damages 

43 the facility, exposing an irradiated target and causing direct radiation exposure (the highest 

44 consequence direct radiation exposure accident considered), the dose to a maximally exposed 

45 member of the public from 1 hour of exposure would be 1,100 mrem (DOE 2012).

46 For the bounding chemical and radiological accidents discussed above, PAC-1/2/3 limits, and 

47 10 CFR Part 20 public dose limits, respectively, would be exceeded. However, the NRC staff 

48 expects that a linear accelerator-based facility would include additional engineered designed 
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1 features and procedural controls that would mitigate the consequences of these accidents. 

2 Before construction or operation of a linear accelerator-based facility, the NRC staff would 

3 perform a safety review of the proposed facility that would include a thorough evaluation of 

4 possible radiological or chemical accidents at the facility, including the consequences of those 

5 accidents and any features or controls that would mitigate those consequences. To receive a 

6 construction permit or operating license from the NRC, the applicant would have to demonstrate 

7 that the facility would be in compliance with all NRC regulations, including 10 CFR Part 20 dose 

8 limits and accident performance requirements in 10 CFR 70.61, as applicable. If the NRC staff 

9 determines in its SER for the linear accelerator-based facility that the facility would be operated 

10 in compliance with all applicable regulations governing the consequences of accidents, then the 

11 NRC staff concludes that the impacts from accidents at the linear accelerator-based facility 

12 would be SMALL.

13 5.3.2.12 Environmental Justice

14 The environmental justice impacts from a linear accelerator-based alternative would be similar 

15 as those discussed for the proposed NWMI facility in Section 4.12. Minority and low-income 

16 populations residing along site access roads could be affected by noise and dust and increased 

17 commuter vehicle and truck traffic during construction, operations, and decommissioning. 

18 However, these effects are not likely to be high and adverse and would be short term and within 

19 a limited time period during certain hours of the day. Noise and dust impacts from onsite 

20 activities during construction and decommissioning would similarly be short term. Everyone 

21 living near Discovery Ridge could be affected by operation activities, including minority and 

22 low-income populations. Any human health and environmental effect would depend on the 

23 magnitude of the change from current environmental conditions.

24 As discussed in Section 5.3.2.8 of this EIS, the potential radiological dose to the public from 

25 facility operations would be well within NRC and applicable Federal, State, and local regulatory 

26 limits. As a result, everyone living near the Discovery Ridge site, including minority and 

27 low-income populations, would not be adversely affected by radiation exposure during facility 

28 operations. Permitted nonradiological air emissions would also be required to remain within 

29 regulatory standards. Noise levels may increase along U.S. Highway 63 because of increased 

30 commuter vehicle and truck traffic during NWMI facility operations. This may not be noticeable, 

31 however, given the relatively small size of the workforce and the limited number of daily truck 

32 deliveries and shipments. Based on this information, construction, operations, and 

33 decommissioning of the proposed NWMI facility using the linear accelerator-based technology 

34 would not likely have disproportionately high and adverse human health and environmental 

35 effects on minority and low-income populations living near Discovery Ridge.

36 5.3.2.13 Cumulative Impacts

37 Cumulative impacts for the linear accelerator-based alternative would be similar to those 

38 described in Chapter 4 for the NWMI RPF facility at the Discovery Ridge site, because direct 

39 contributory effects from construction, operations, and decommissioning for this technology 

40 would be similar.

41 5.3.3 Subcritical Fission Technology

42 The uranium fission technology would produce Mo-99 using a subcritical fission process 

43 followed by chemical extraction of Mo-99. For the purpose of this analysis, the NRC staff 

44 assumed the facility would be similar to the facility described in NRC’s Environmental Impact 

45 Statement for the Construction Permit for the SHINE Medical Radioisotope Production Facility, 

46 Final Report, NUREG–2183 (NRC 2015c), which considered the environment impacts of the 
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1 facility proposed in the SHINE Medical Technologies, Inc.’s Construction Permit Application 

2 (SHINE 2015).

3 The first stage in the radioisotope production process for this alternative is the production of 

4 neutrons, which induce the fission of uranium, resulting in the formation of radioisotopes. 

5 During the irradiation stage, a neutron driver (accelerator) affixed above a subcritical operating 

6 assembly would accelerate deuterium ions into a chamber filled with tritium gas. This chamber 

7 would be centered within the subcritical operating assembly which contains a vessel containing 

8 LEU target solution in the form of uranyl sulfate. The resulting ion beam would strike the tritium 

9 gas and produce helium nuclei and neutrons. These additional neutrons would pass through a 

10 neutron multiplier, which would produce additional neutrons (SHINE 2015).

11 The neutrons would then pass into the LEU target solution within one of several irradiation units, 

12 causing the uranium-235 in the solution to fission (split) and produce byproduct materials, 

13 including Mo-99. The target solution in each irradiation unit would be maintained at a subcritical 

14 level (i.e., a level at which the uranium-235 fission and the consequent neutron production in the 

15 target solution vessel would not be self-sustaining). Mo-99, xenon-133, and iodine-131

16 production would occur within the target solution from fission during the irradiation cycle. An 

17 offgas system would be used during this stage to handle and contain radiolytic and fission 

18 product gases released from the target solution. The target solution vessel would be 

19 surrounded by a light-water pool. This pool would be used to control the temperature of the 

20 target solution vessel, reflect neutrons back into the vessel, shield radiation, and absorb heat 

21 resulting from the fission process (SHINE 2015).

22 At the end of the irradiation cycle in each irradiation unit, the target solution would be removed 

23 from the target solution vessel and transferred through piping to one of three hot cells (shielded 

24 nuclear radiation confinement chambers) where the Mo-99 would be selectively extracted and 

25 purified using a chemical process (SHINE 2015; NRC 2015c). Following extraction and 

26 purification, the separated radioisotopes would be packaged and distributed.

27 At full operational capacity, the facility could produce up to 8,200 6-day curies (Ci 6-day) per 

28 week of the medical radioisotope Mo-99 (SHINE 2015). To meet this production schedule, each 

29 irradiation unit would need to operate continuously for about 5.5 days. Radioisotope production 

30 functions would operate close to 7 days per week (SHINE 2015).

31 A description of the affected environment for the Discovery Ridge site is provided in Chapter 3 

32 of the EIS. Construction of a subcritical fission-based facility will include five main buildings that 

would cover 91,000 ft2 (8,500 m2

) and total excavated material would be 278,000 yd3 33

(213,000 m3 34 ) (SHINE 2015; NRC 2015c). Construction of a subcritical fission-based alternative 

35 would take 18 months and require a peak workforce of 451 workers (SHINE 2015; NRC 2015c). 

36 Operation of a subcritical fission-based alternative would require a peak workforce of 

37 150 workers for 30 years (SHINE 2015; NRC 2015c). The decommissioning phase would be 

38 6 months and require a peak workforce of 261 workers (SHINE 2015; NRC 2015c). The 

39 following sections describe the impacts of constructing, operating, and decommissioning the 

40 proposed NWMI facility using the subcritical fission-based technology.

41 5.3.3.1 Land Use and Visual Resources

42 Land use impacts of a subcritical fission-based alternative at the Discovery Ridge site would be 

43 confined to the 7.4 ac (3.0 ha) site. The fission-based alternative would disturb a similar amount 

44 of land as the proposed NWMI facility (SHINE 2015; NRC 2015c). The highest structure would 

45 be the emissions stack, which would extend approximately 66 ft (20 m) in height (SHINE 2015; 

46 NRC 2015c). Therefore, the height of the buildings for the fission-based alternative would be 

47 bounded by the parameters analyzed for the NWMI facility in Section 4.1. As described in 
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1 Section 4.1, land use impacts during construction, operations, and decommissioning would be 

2 SMALL, because the entire site is currently certified for industrial use, and the permanently 

3 converted agricultural land would be a small portion of available agricultural land within the 

4 vicinity. As described in Section 4.1, aesthetic impacts during construction, operations, and 

5 decommissioning would be SMALL at the proposed Discovery Ridge site, given that a light 

6 industrial development landscape surrounds part of the site and the visual setting is generally 

7 flat and has a uniform landform with low vegetation diversity and a low visual-quality rating. 

8 Based on a similar amount of land disturbed and building height for the subcritical fission facility

9 alternative, land use and visual impacts would be SMALL during construction, operations, and 

10 decommissioning of a subcritical fission facility on the Discovery Ridge site.

11 5.3.3.2 Air Quality and Noise

12 A description of the air quality and noise affected environment for the Discovery Ridge site is 

13 provided in Section 3.2 of the EIS.

14 Air Quality

15 Construction

16 Construction activities associated with building a subcritical fission facility would generate air 

17 pollutant emissions from site-disturbing activities (e.g., grading, compacting), operation of 

18 construction equipment, and worker and shipment vehicles. Construction-related emissions are 

19 presented in Table 5–8.

20 Table 5–8. Estimated Air Emissions Resulting from Construction of a Subcritical Fission 

21 Facility

Total Emissions (tons/year)(a)

Nitrogen Oxides (NOx) 278

Carbon Monoxide (CO) 184

Sulfur Dioxide (SO2) 18

Particulate Matter less than 10 microns (μm) (PM10) 26

Particulate Matter less than 2.5 μm (PM2.5) 20

Carbon Dioxide (CO2) 14,920

(a) Accounts for emission from construction equipment, fugitive dust, and worker and delivery vehicle 

emissions. Construction phase would be 18 months. Emissions based on NRC 2015c.

22 Emissions would be greater than construction of the proposed NWMI facility because the 

23 subcritical fission facility would be a larger facility that would require a larger workforce and 

24 additional equipment. Emissions would exceed the significant de minimis levels under the New 

25 Source Review program discussed in Section 3.2.2. However, total construction emissions

26 would be 4 percent or less of the Boone County annual emissions for each criteria pollutant and 

27 carbon dioxide. Further, these emissions are bounding conditions that assume conservative 

28 equipment activities and conservative workforce commute distances (NRC 2015c). Additionally, 

29 the facility may be required to obtain and abide by applicable construction air permits to prevent 

30 degradation of air quality in Boone County. Therefore, the NRC staff concludes that the air 

31 quality impacts during construction would be SMALL.
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1 Operations

2 Operation of a subcritical fission facility would produce air emissions from fuel combustion 

3 associated with processing and facility heating purposes (boilers and heaters), an emergency 

4 generator, target solution preparation, and worker vehicles. Total emissions from these sources 

5 are presented in Table 5–9.

6 Table 5–9. Estimated Air Emissions Resulting from Operation of a Subcritical Fission 

7 Facility

Total Emissions (tons/year)(a)

Nitrogen Oxides (NOx) 13

Carbon Monoxide (CO) 53

Sulfur Dioxide (SO2) 0.2

Particulate Matter less than 10 μm (PM10) 1.0

Particulate Matter less than 2.5 μm (PM2.5) 1.0

Carbon Dioxide (CO2) 17,250

(a) Accounts for emissions from construction equipment, fugitive dust, and worker and delivery vehicle 

emissions. Emissions based on NRC 2015c.

8 Total operation-related emissions for criteria pollutants are well below the significant de minimis 

9 levels under the New Source Review program and major sources under Title V operating 

10 sources threshold (100 TPY) discussed in Section 3.2.2 of this EIS. Therefore, the NRC staff 

11 does not expect increases in air emissions from construction activities to contribute to 

12 concentrations that would interfere with the maintenance of NAAQS or degrade Boone County’s 

13 attainment/unclassifiable designation. Therefore, the NRC staff concludes that the air quality 

14 impacts during operation of a subcritical fission facility would be SMALL.

15 Decommissioning

16 Activities associated with decommissioning of a subcritical fission facility would generate air 

17 pollutant emissions from site-disturbing activities, operation of equipment, worker vehicles, and 

18 demolition of structures, and dismantlement and decontamination of systems. Total emissions 

19 from these sources are presented in Table 5–10.

20 Table 5–10. Estimated Air Emissions Resulting from Decommissioning of a Subcritical 

21 Fission Facility

Total Emissions (ton/year)(a)

Nitrogen Oxides (NOx) 173

Carbon Monoxide (CO) 89

Sulfur Dioxide (SO2) 11

Particulate Matter less than 10 μm (PM10) 14

Particulate Matter less than 2.5 μm (PM2.5) 12

Carbon Dioxide (CO2) 8,000

(a) Accounts for emission from construction equipment, fugitive dust, and worker and delivery vehicle 

emissions. Total emissions during 6-month decommissioning phase. Emissions based on 

NRC 2015.
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1 Emissions would be greater than decommissioning of the proposed NWMI facility as a result of 

2 the subcritical fission facility being a larger facility that would require a larger workforce and 

3 additional equipment. Emissions would exceed the significant de minimis levels under the New 

4 Source Review program discussed in Section 3.2.2. However, decommissioning emissions

5 would be 2 percent or less of the Boone County annual emissions for each criteria pollutant and 

6 carbon dioxide. Further, these emissions are based upon bounding conditions. For instance, a 

7 100-mi (160-km) roundtrip worker commute for each employee and simultaneous continuous 

8 use of construction equipment were assumed (NRC 2015c). Additionally, the facility may be 

9 required to obtain and abide by applicable air permits to prevent degradation of air quality in 

10 Boone County. Therefore, the NRC staff concludes that the air quality impacts during 

11 decommissioning would be SMALL.

12 Noise

13 Construction

14 Noise emissions during construction would occur because of increased traffic volumes from 

15 worker vehicles and because of the use of construction equipment on site. The maximum 

16 number of worker vehicles expected on site during construction is 451, all of which, for purposes 

17 of this analysis, are assumed to travel along U.S. Highway 63 during hours when work starts 

18 and stops. Sound levels increase at a rate of 3 dBA per doubling of traffic volumes. Traffic 

19 volume along U.S. Highway 63 is 818 vehicles/hr (NWMI 2016a; NWMI 2016c). Conservatively 

20 assuming that all worker vehicles and deliveries travel on U.S. Highway 63 at the same time, 

21 this will result in a traffic volume of 1,259 vehicles/hr. This increase in traffic will not result in 

22 noise levels that will be noticeable.

23 Construction equipment for a subcritical fission facility would be similar to construction 

24 equipment of the proposed NWMI facility. However, because the subcritical fission facility 

25 would be a larger facility, multiple numbers of similar equipment are assumed to be used 

26 simultaneously (NRC 2015c). Simultaneous use of multiple equipment may result in greater 

27 noise levels than single-use equipment. For example, simultaneous use of three pieces of 

28 equipment, each with noise levels of 85 dBA, results in a combined noise level of 90 dBA. 

29 However, accounting for attenuation of noise levels from construction equipment to nearby 

30 noise sensitive receptors at the Discovery Ridge, site noise emissions from construction 

31 equipment are not expected to noticeable or exceed existing noise levels at the sensitive 

32 receptors. Further, noise from construction equipment would be localized, short term, and 

33 intermittent during machinery operations.

34 Given that increases in noise levels as a result of additional vehicle traffic will not be noticeable 

35 and noise levels from construction equipment are not anticipated to exceed existing ambient 

36 noise levels, the NRC staff concludes that offsite noise impacts from construction would be 

37 SMALL.

38 Operations

39 Noise emissions during operation would occur because of increased traffic. Noise from 

40 operating equipment would be contained inside buildings and are not anticipated to be audible 

41 outside the subcritical fission facility (NRC 2015c). The number of worker vehicles expected 

42 during operation is 150. Adding this traffic volume to existing traffic levels along 

43 U.S. Highway 63 will not result in noise levels that would be noticeable (less than 3-dBA 

44 increase). Therefore, the NRC staff concludes that noise impacts from operation of a subcritical 

45 fission facility at the Discovery Ridge site would be SMALL.
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1 Decommissioning

2 Noise emissions during decommissioning would occur because of increased traffic volumes 

3 from worker vehicles and the use of equipment on site. The maximum number of worker 

4 vehicles expected on site during decommissioning is 261, all of which, for purposes of this 

5 analysis, are assumed to travel along U.S. Highway 63 during hours when work starts and 

6 stops. Sound levels increase at a rate of 3 dBA per doubling of traffic volumes. Conservatively 

7 assuming that all worker vehicles and deliveries travel on U.S. Highway 63 at the same time, 

8 this will result in a traffic volume of 1,079 vehicles/hr. This increase in traffic will not result in 

9 noise levels that will be noticeable from a traffic volume of 818 vehicles/hr.

10 Equipment during decommissioning would be similar to that used during the construction phase. 

11 As discussed above, noise levels from construction equipment for a subcritical fission facility are 

12 not expected to exceed existing noise levels. Therefore, given that increases in noise levels as 

13 a result of additional vehicle traffic will not be noticeable and that noise levels from equipment 

14 are not anticipated to exceed existing ambient noise levels, the NRC staff concludes that noise 

15 impacts from decommissioning a subcritical fission facility at the Discovery Ridge site would be 

16 SMALL.

17 5.3.3.3 Geologic Environment

18 Geology and Soils

19 Construction

20 Impacts on geology and soils associated with construction of a subcritical fission process facility 

21 at the Discovery Ridge site would be similar to but somewhat greater than the impacts 

22 described for the proposed technology, as presented in Section 4.3.1. The potential for greater 

23 impacts under this technology alternative is attributable to the larger footprint of the subcritical 

fission process facility (91,000 ft2 (8,500 m2 24 )) and the greater depth of excavation required 

25 (i.e., up to 39 ft (12 m)) to construct the below-grade portions of the facility (NRC 2015c). 

26 Because the depth to bedrock beneath the site is on the order of 25 ft (7.6 m) or less 

27 (Section 3.3.1), it is probable that blasting and other construction methods may be required 

28 during foundation excavation. The NRC staff further assumes that the entire 7.4 ac (3.0 ha) site 

29 would be disturbed during construction of the subcritical fission process facility.

30 The larger footprint that would be cleared, graded, and compacted along with the greater 

31 excavation depth would increase the potential for soil erosion and loss. Nevertheless, 

32 construction activities would be subject to the same site development permitting and associated 

33 regulatory requirements previously described in Section 4.3.1. For instance, NWMI would need 

34 to conduct site work in accordance with a Land Disturbance Permit from the City of Columbia in 

35 accordance with Chapter 12A, Article II (Land Preservation) of the City’s Code of Ordinances 

36 (City of Columbia 2015). NWMI would need to prepare a soil erosion and sediment control plan 

37 and a stormwater management plan. These plans entail the implementation of 

38 construction-related BMPs for soil erosion and sediment control and stormwater pollution 

39 prevention during site development, facility construction, and for post development.

40 As described in Sections 3.3.1 and 3.3.2 and evaluated for potential impacts in Sections 4.3.1 

41 and 5.3.2.3, the Discovery Ridge site presents construction challenges that will need to be 

42 addressed during facility construction, along with mitigative features incorporated into the 

43 facility. These challenges include the depth to bedrock, the potential for a seasonally high water 

44 table or perched groundwater, and the occurrence of soils with construction limitations (e.g., fat 

45 clays with a high shrink/swell potential). NWMI would conduct site-specific geotechnical and 

46 hydrological studies of the Discovery Ridge site to characterize site conditions in support of final 

47 subcritical fission facility design.
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1 As summarized in Section 2.2, Table 2–1, for the proposed alternative, geologic resources 

2 would also be required to support construction of a subcritical fission process facility; these 

3 resources include granular stone (e.g., typically crushed aggregate (sand and gravel)) and 

4 aggregates to produce ready-mix concrete. The volumes required would be proportionally 

5 greater for this technology alternative as compared to either the proposed technology or the 

6 linear accelerator-based facility alternatives. Specifically, projected geologic resource 

7 requirements to construct the subcritical fission process facility include, but are not limited to, 

16,000 yd3 (12,233 m3 8 ) of crushed stone material (NRC 2015c). Nevertheless, as noted in 

9 Section 3.3.1, construction aggregate is widely available throughout Boone County and 

10 northeast Missouri and so their consumption to support facility construction under this 

11 alternative would not likely deplete local or regional stockpiles of such geologic resources.

12 Because of the larger facility footprint and, especially, the greater depth of excavation required 

13 to construct the below-grade portion of the facility, excavation activities under this technology 

alternative would result in removal of up to 278,000 yd3 (213,000 m3 14 ) of soil, sediments, and 

rock material. This is considerable in comparison to the excavation volumes of 28,000 yd3 15

(21,000 m3

) and 9,000 yd3 (6,900 m3 16 ) associated with the linear accelerator-based facility and 

17 proposed technology alternative, respectively. For construction of a subcritical fission process 

18 facility, NRC (2015) indicated that materials needed for backfill around structures and topsoil for 

19 use in miscellaneous earthwork and final surface preparation would be reclaimed from onsite, 

20 excavated material and prepared as necessary to meet structural requirements. Nonetheless, 

21 soils at the Discovery Ridge site, particularly the fat clays, have poor shear strength when 

22 wetted and have generally poor workability as a construction material, including for use as 

23 structural (engineered) backfill (Section 3.3.1). Thus, the NRC staff assumes that at least some 

24 proportion of this excavated material would need to be replaced with engineered backfill from 

25 offsite sources, thus adding to the volume of onsite earthwork required and geologic materials 

26 consumed. Due to the diversity of soil types in the region, the NRC staff concludes that soils 

27 with the necessary engineering properties are readily obtainable from sources throughout the 

28 City of Columbia area and across Boone County or from sources elsewhere in central and 

29 eastern Missouri.

30 Under this alternative, the potential impact on the geologic environment from deep excavation 

31 work, potential soil loss, and geologic resource consumption would be greater than under both 

32 the linear accelerator-based facility and proposed technology alternatives. Because of the 

33 larger facility size and the need for deep excavation, site conditions would present greater 

34 constraints on site development and facility construction. Completion of detailed site-specific 

35 geotechnical studies would serve to inform construction planning and final facility design. In 

36 consideration of the above factors, the NRC staff concludes that the impacts on the geologic 

37 environment from the construction of a subcritical fission process facility at the Discovery Ridge 

38 site would also be SMALL.

39 Operations

40 Operational impacts on the geologic environment would be negligible under this technology 

41 alternative. During facility operations, previously disturbed areas would not be subject to 

42 long-term soil erosion. Areas disturbed during construction would be within the footprint of the 

43 completed facility or overlain by other impervious surfaces (such as roadways and parking lots), 

44 or revegetated.

45 Regardless of the technology, final facility design and construction would comply with applicable 

46 building codes and standards, which provide for the evaluation of site geologic and soil

47 conditions, including potential seismic hazards. Completion of site-specific geotechnical and 

48 hydrological studies, as discussed in Section 4.3.1, would inform final facility design and 
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1 construction considerations. The NRC staff concludes that subcritical fission process facility 

2 operational impacts associated with the geologic environment at the proposed site would be 

3 SMALL.

4 Decommissioning

5 Compacted site soils and underlying sediments would be disturbed by facility demolition and 

6 decontamination work. The impacts on site geology and soils would be similar in scope to those 

7 described for construction. For the subcritical fission process facility, the potential for soil

8 erosion and loss during decommissioning would be greater than for either the linear 

9 accelerator-based facility or proposed technology primarily because of the larger facility footprint 

10 and extensive below-grade portions of the facility. Nonetheless, all site clearing to restore the 

11 proposed site to a reusable condition would be subject to applicable permits and approvals 

12 (e.g., demolition or clearance permit), and the applicable provisions including Chapter 6, Article 

13 II (Building Code) of the City of Columbia’s Code of Ordinances (City of Columbia 2015).

14 Before beginning to dismantle onsite structures, NWMI would remove waste materials and 

15 contaminated media from the structures. Materials would be packaged and properly disposed 

16 of as discussed in Section 5.3.3.9. Thus, these materials would not pose a contamination threat 

17 to site soils or water resources. NWMI would be required to conduct all decommissioning 

18 activities in accordance with a decommissioning plan submitted to the NRC and applicable 

19 regulations, as described in Section 2.9. The NRC staff concludes that impacts on the geologic 

20 environment from facility decommissioning under this technology alternative would be SMALL.

21 5.3.3.4 Water Resources

22 Surface Water and Groundwater Resources

23 Construction

24 Impacts on surface water and groundwater resources from construction activities associated 

25 with the subcritical fission process alternative would be similar to but greater than those under 

26 both the linear accelerator-based and proposed technology alternatives (see 

27 Sections 4.4.1.1, 4.4.2.1, and 5.3.2.4). The potential for greater impacts is attributable to the 

28 additional land affected because of the larger footprint of the facility and the greater depth of 

29 excavation, as referenced in Section 5.3.3.3. Otherwise, the same general assumptions, impact 

30 considerations, and regulatory parameters discussed for the linear accelerator-based and 

31 proposed technology alternatives apply to this alternative discussion.

32 During construction, stormwater runoff from construction areas could potentially affect 

33 downstream surface water quality if not properly managed. NWMI would be required to obtain a 

34 Land Disturbance Permit from the City of Columbia and submit related plans for city approval 

35 before any ground-disturbing activities or facility construction could commence on the site, as 

36 referenced in Section 5.3.3.3. The City would require that appropriate soil erosion and sediment 

37 control BMPs be used to minimize soil erosion and the stormwater transport of suspended 

38 sediment and other pollutants.

39 Construction stormwater runoff from the construction would also be subject to regulations in 

40 accordance with CWA Section 402. Under the State of Missouri’s delegated authority for 

41 administering the NPDES permit program pursuant to Section 402, the State has developed an 

42 NPDES general permit for construction stormwater. Permit coverage must be obtained by 

43 owners and operators for the discharge of stormwater and certain non-stormwater discharges

44 (e.g., dewatering flows) from land-disturbance sites that disturb 1 ac (0.4 ha) or more, as further 

45 described in Section 4.4.1.1. NWMI’s construction activities would be subject to NPDES permit 
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1 and other local regulations for soil erosion and sediment control and construction stormwater 

2 management.

3 In addition, under CWA Section 401, an applicant for a Federal license or permit to conduct any 

4 activities, including facility construction or operation, that may cause a discharge of regulated 

5 pollutants into navigable waters is required to provide the Federal licensing agency with a 

6 certification from the state or agency having jurisdiction in which the discharge would originate. 

7 As discussed in Section 4.4.1.1 for the Discovery Ridge site, NWMI has stated that no State 

8 certification is required under CWA Section 401 (NWMI 2015a). NWMI also has stated that it 

9 would seek a waiver from the State (NWMI 2015c). However, because the NRC cannot issue a 

10 construction permit until the required certification is submitted, NWMI must provide the NRC 

11 with either a 401 certification from the State of Missouri, a waiver, or State documentation that a 

12 Section 401 certification is not necessary.

13 The need for groundwater dewatering would be very likely under this alternative. This is 

14 because of the greater depth of excavation (i.e., up to 39 ft (12 m)) expected for the 

15 below-grade portion of the subcritical fission process facility. The volume of groundwater 

16 requiring removal could be much greater, depending on the depth and extent of groundwater, 

17 than the maximum volume projected by NWMI for the proposed technology, as described in 

18 Section 4.4.2.1. Consequently, the NRC staff expects that dewatering could have localized 

19 effects on the vertical and horizontal extent of shallow groundwater and on groundwater flow 

20 direction, although the impacts would likely be temporary. NWMI has committed to 

21 commissioning site-specific geotechnical and hydrologic studies of the Discovery Ridge site. 

22 These studies would characterize groundwater conditions beneath the site and would guide any 

23 necessary construction accommodations and final facility design.

24 As previously discussed, the Discovery Ridge site is served by public water, with service 

25 provided by Consolidated Public Water Supply District No. 1 (Section 4.4.2.1). The district uses 

26 groundwater as its supply source, and it has a total groundwater production capacity of 11 mgd 

(49,200 m3

/day) and currently supplies approximately 1.45 mgd (5,490 m3 27 /day) to customers.

28 Under this technology alternative, onsite water needs to support facility construction would be 

29 greater than under both the linear accelerator-based and proposed technology alternatives. 

30 The NRC staff estimates that construction activities would require an average of 12,000 gpd 

(45,400 Lpd) of water. This is equivalent to 0.012 mgd (45.4 m3 31 /day). Total projected water use 

32 for the construction period (18 months) is about 4.3 million gal (16.3 million L), excluding water 

33 required for concrete production and preoperational testing (NRC 2015c). The projected 

34 average daily water needs for construction under this technology alternative would still be a 

35 small percentage (i.e., about 0.8 and 0.11 percent) of the public water district’s existing demand

36 and available production capacity, respectively.

37 For construction under this technology alternative, NWMI would be required to prepare 

38 site-specific plans and implement BMPs in accordance with local and MDNR requirements to 

39 mitigate the potential impacts on surface water quality. No surface water features would be 

40 disturbed and no surface water or onsite groundwater would be used to support facility 

41 construction. Construction dewatering would be very likely during construction, but site-specific 

42 geotechnical and hydrologic studies will further characterize subsurface conditions, and 

43 dewatering activities would be conducted in accordance with regulatory requirements. The 

44 volume of water required to support onsite construction activities would be a small percentage 

45 of the public utility’s existing demand and available production capacity. The NRC staff 

46 concludes that the impacts on surface water and groundwater hydrology, quality, and use from 

47 the construction of a subcritical fission process facility would be SMALL.
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1 Operations

2 Normal facility operations would not have any direct impact on surface water or groundwater 

3 hydrology or quality under this technology alternative. Consistent with the previously described 

4 alternatives, stormwater runoff from the facility site would be managed by an engineered 

5 stormwater management system, constructed and operated in compliance with applicable local, 

6 State, and Federal stormwater management permits, plans, procedures, and practices.

7 Projected water demands for operation of a subcritical fission process facility under this 

8 alternative are higher than for either the linear accelerator-based technology or proposed 

9 technology alternatives. Water would be required for potable and sanitary uses, fire protection, 

10 heating and cooling system makeup, and makeup for the radioisotope production process, with 

11 the largest use attributable to potable and sanitary water use by the facility workforce 

12 (NRC 2015c).

13 Total water use is projected to be 6,073 gpd (22,990 Lpd), equivalent to 0.0061 mgd 

(23 m3 14 /day), to support facility operations under this alternative (NRC 2015). Consolidated 

15 Public Water Supply District No. 1 would also provide water service under this alternative. 

16 While higher when compared to the other technology alternatives, the projected average daily 

17 water use is a negligible percentage of the production capacity of the water district and 

18 represents a very small increase (about 0.4 percent) in the volume of water the district supplies 

19 to its customers.

20 Consistent with the other technologies, no radiological liquid effluents would be discharged to 

21 the environment under this technology alternative. All facility operations would be contained 

22 inside properly constructed buildings with waste management systems and programs in place to 

23 control, handle, process, store, and transport the types and quantities generated by the medical 

24 radioisotope production process (NRC 2015c).

25 Facility wastewater would normally consist of sanitary wastewater and boiler blowdown from the 

26 facility’s heated water system. In addition, facility personnel may periodically convey small 

27 quantities of maintenance and laboratory chemicals to the facility’s sanitary sewer drains. As for 

28 water use, wastewater generation would be higher under this technology alternative when 

29 compared to the other technology alternatives. Wastewater flow would average 5,850 gpd 

(22,145 Lpd), equivalent to about 0.0059 mgd (22.3 m3 30 /day) (NRC 2015c). This effluent would 

31 be discharged to the City of Columbia sanitary sewer system for treatment at the Columbia 

32 Regional WWTP. The Columbia Regional WWTP has a design treatment capacity of 20 mgd 

(75,700 m3

/day) with an average demand of 16 mgd (60,600 m3 33 /day). The effluent flow under 

34 this technology alternative would be a very small percentage (i.e., 0.15 percent) of the available 

35 treatment capacity of the WWTP. The effluent would be required to meet the sewer system’s 

36 influent acceptance and treatment criteria, as well as NRC’s regulations at 10 CFR 20.2003.

37 There would be no radiological or nonradiological impacts on surface water or groundwater 

38 during normal operations under this technology alternative. Facility operations would need to 

39 comply with applicable regulatory requirements and would be conducted in accordance with 

40 appropriate practices. Water requirements and sanitary effluent treatment needs would be met 

41 by public facilities, which have adequate capacity. Therefore, the NRC staff concludes that the 

42 impacts on surface and groundwater hydrology, water quality, and water use from the operation 

43 of a subcritical fission process facility would be SMALL.

44 Decommissioning

45 Facility decontamination, demolition, and site-restoration activities would be similar to those 

46 under the other technology alternatives, with the potential magnitude of the impacts on surface 

47 water and groundwater similar to those discussed above for construction. NWMI would perform 
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1 demolition and site-restoration activities in accordance with applicable local and State permits 

2 and approvals, including a State-issued NPDES general permit for the discharge of stormwater

3 from land-disturbance sites. NWMI would use appropriate construction BMPs, including waste 

4 handling and pollution prevention practices and response procedures during decommissioning, 

5 so that no materials or contaminants are released to soils, surface water, or underlying 

6 groundwater.

7 NWMI would conduct work in accordance with a decommissioning plan submitted to the NRC. 

8 NWMI would be required to conduct necessary surveys of the soils and subsurface to comply 

9 with the NRC’s radiological criteria for license termination in 10 CFR Part 20, Subpart E. The 

10 NRC staff also expects that NWMI would sample soils and other media as necessary in 

11 accordance with other required local and State permits and approvals to ensure that no 

12 nonradiological contamination remains in excess of action levels.

13 Water would be required for dust control and soil compaction during decommissioning. Based 

14 on relative facility size and dimensions as compared to the other technology alternatives, the 

15 NRC staff estimates that decommissioning activities would require up to about 4,000 gpd 

(15,100 Lpd) of water, equivalent to 0.004 mgd (15.1 m3 16 /day) during the decommissioning 

17 period. The NRC staff assumes that Consolidated Public Water Supply District No. 1 would

18 supply water needed for decommissioning. The projected water volume needed is less than the 

19 volume required for facility construction, as discussed above, and the impacts on supply 

20 capacity would similarly be very small.

21 Considering the above, the NRC staff concludes that the impacts on surface water and 

22 groundwater resources from decommissioning of a subcritical fission process facility under this 

23 alternative would be SMALL.

24 5.3.3.5 Ecological Resources

25 The subcritical fission-based alternative would disturb a similar amount of land as the proposed 

26 NWMI facility. Directly affected vegetation would be limited to non-native, common, or weedy 

27 species, which are abundant within the region and provide relatively low-quality habitat for birds 

28 and wildlife in comparison to forests, grasslands, and wetland habitats. In addition to a loss of 

29 habitat, noise from construction activities could disturb birds and wildlife. In response to such 

30 disturbances and loss of habitat, birds and wildlife could move out of the immediate area and 

31 find adequate, similar habitat (agricultural fields) within the vicinity. All other impacts on 

32 ecological resources, such as bird collisions, disturbance during maintenance activities, and 

33 potential runoff to offsite aquatic resources, are expected to be similar to those described for the 

34 proposed NWMI facility in Section 4.5 because of similar construction methods, similar or 

35 smaller building size and footprint, and similar operating and decommissioning activities. 

36 Therefore, the NRC staff concludes that the impacts on ecological resources would be SMALL 

37 during construction, operations, and decommissioning of a subcritical fission facility on the 

38 Discovery Ridge site.

39 5.3.3.6 Historic and Cultural Resources

40 Impacts to historic and cultural resources from the subcritical fission process alternative would 

41 be similar to those described for the proposed NWMI facility in Section 4.6. With no historic

42 properties affected, no archaeological sites or evidence of cultural resources identified during 

43 the Phase I survey (NWMI 2015a), tribal input, and the cultural resource assessment and 

44 consultations performed by the NRC staff, constructing, operating, and decommissioning the 

45 NWMI facility using the subcritical fission technology would not impact any known historic and 

46 cultural resources at the Discovery Ridge site. 
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1 5.3.3.7 Socioeconomics

2 Socioeconomic impacts from the subcritical fission process alternative would be similar to those 

3 described for the proposed NWMI facility in Section 4.7. Although this technology alternative 

4 would require a higher number of workers to construct (up to 450), operate (up to 150), and 

5 decommission (up to 260) than for the proposed NWMI facility, these are peak estimates of 

6 workers, and the average daily number of construction and decommissioning workers would be 

7 much less. Most, if not all, workers would likely reside within the ROI or adjacent counties and 

8 communities and commute to the work site. Even if the estimated number of operations 

9 workers (150) were to generate two to three times additional employment in the ROI, the 

10 combined total number of workers would represent less than three-quarters of a percent of the 

11 current civilian labor force in Boone County. This would have little to no noticeable effect on 

12 employment levels or public service demand in the ROI. Given the size of the workforce, 

13 socioeconomic impacts from the construction, operations, and decommissioning of the 

14 proposed NWMI facility using the subcritical fission process technology at the Discovery Ridge 

15 site would be SMALL.

16 5.3.3.8 Human Health

17 The NRC staff expects that human health impacts from the subcritical fission process alternative 

18 would be similar to those described in Section 4.8 for the proposed NWMI facility. Like the 

19 proposed NWMI facility, the subcritical fission process alternative facility would be required to 

20 comply with all Federal, State of Missouri, and local regulations, protecting workers and 

21 members of the public during construction, operations, and decommissioning. For example, 

22 OSHA regulations would protect workers from physical occupational hazards; OSHA and EPA

23 regulations would protect workers and the public from hazardous material and chemical

24 hazards; and NRC regulations would protect workers and the public from radiological hazards.

25 The NRC evaluated the human health impacts of a subcritical fission technology facility. A 

26 subcritical fission technology facility would have incorporated engineered design features and

27 procedural controls to minimize any impacts to workers or the public from both radiological and 

28 nonradiological hazards. The maximum dose to a member of the public from radioactive 

29 gaseous emissions would be approximately 9.0 mrem, which is within 10 CFR Part 20 dose 

30 limits (SHINE 2015; NRC 2015c). Operation of the subcritical fission technology facility would 

31 require transportation of fresh LEU to the facility and Mo-99 product from the facility to an end

32 user medical facility. However, no transportation of irradiated LEU would occur in conjunction 

33 with operation of the facility. All transportation would be in compliance with NRC and DOT

34 regulations.

35 The NRC staff concluded that, if the facility was constructed, operated, and decommissioned in 

36 compliance with all applicable regulations, the radiological and nonradiological human health 

37 impacts from construction, operations, and decommissioning of the subcritical fission process 

38 alternative facility would be SMALL (NRC 2015c; SHINE 2015). The NRC staff expects that 

39 similar features and controls to minimize impacts to workers and the public would be used at 

40 other facilities using the subcritical fission process. Given the safety-oriented design and 

41 procedures at a facility using the subcritical fission process alternative, and given that this 

42 facility would be required to comply with all Federal and State of Missouri regulations, ensuring 

43 that public health and safety are protected, the NRC staff concludes that the human health 

44 impacts from construction, operations, and decommissioning of the subcritical fission process 

45 alternative would be SMALL.
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1 5.3.3.9 Waste Management

2 The NRC staff assumes that waste management impacts from the subcritical fission process 

3 alternative would be similar to those described in Section 4.9 for the proposed NWMI facility. 

4 Like the proposed NWMI facility, the subcritical fission process alternative facility would be 

5 required to comply with all applicable Federal, State of Missouri, and local regulations regarding 

6 waste handling, transportation, and disposal.

7 The NRC staff evaluated the waste management impacts of a subcritical fission technology 

8 facility. The facility would produce low-level radioactive waste ranging from Class A through 

9 greater than Class C (GTCC). The facility would also produce hazardous and nonhazardous 

10 nonradioactive wastes. The facility would use waste minimization practices, and handling, 

11 storage, and disposal of all wastes would be conducted in compliance with all applicable 

12 regulations. The NRC staff concluded that, since waste management must be performed in 

13 compliance with regulations, and since disposal pathways would exist for the types and 

14 quantities of wastes generated, the impacts from waste management during construction, 

15 operations, and decommissioning at the subcritical fission process facility would be SMALL 

16 (NRC 2015c; SHINE 2015).

17 The NRC staff expects that similar waste minimization practices would be used at the subcritical 

18 fission process alternative facility, and that the types and quantities of waste generated would 

19 also be similar. As discussed in Section 4.14.9, the NRC staff assumes that sufficient 

20 infrastructure and disposal pathways exist in the Columbia, Missouri, area for proper 

21 management of wastes from the proposed NWMI facility therefore, the infrastructure would also 

22 be sufficient to handle waste from the subcritical fission process alternative. For GTCC waste 

23 that would be generated at the subcritical fission process facility, a provision of the American 

24 Medical Isotopes Production Act of 2012 (42 U.S.C. 2065(c)(3)(A)(ii)) states that DOE would 

25 take title to, and be responsible for, the final disposition of radioactive waste created by the 

26 irradiation, processing, or purification of uranium leased from DOE if it determines that the 

27 producer does not have access to a disposal path. Therefore, if a disposal pathway for GTCC 

28 waste did not exist, DOE would be responsible for its disposal.

29 Because disposal pathways exist for waste that would be generated by the subcritical fission

30 process facility, and because all handling, storage, transportation, and disposal of wastes would 

31 be conducted in accordance with all applicable regulations, the NRC staff concludes that the 

32 impacts from waste management during construction, operations, and decommissioning of the 

33 subcritical fission process alternative would be SMALL.

34 5.3.3.10 Transportation

35 Transportation impacts from the subcritical fission process alternative would be similar to those 

36 described for the NWMI facility in Section 4.10. Construction, operations, and decommissioning 

37 activities would be very similar and over the same time span. Transportation impacts would 

38 consist of commuting workers and truck deliveries and shipments of equipment and materials. 

39 During periods of peak construction up to 451 workers, operations up to 150 workers, and 

40 decommissioning up to 261 workers could be commuting daily to the work site. These are peak 

41 estimates of workers, and the average daily number of construction and decommissioning 

42 workers would be much less. Workers would arrive via site access roads and the volume of 

43 traffic on nearby roads could increase during shift changes. In addition to commuting workers, 

44 trucks would be transporting equipment and materials to and from the work site, thus increasing 

45 the amount of traffic on local roads. During construction up to 14 trucks, during operations an 

46 average of 3 trucks, and during decommissioning up to 9 trucks would travel to and from the site 

47 (NRC 2015c). The increase in vehicular traffic would peak during shift changes, resulting in 

48 temporary levels of service impacts and delays at intersections. However, given the small size 
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1 of the average daily workforce and the number of daily truck deliveries and shipments combined 

2 with the easy access to U.S. Highway 63, there would be little if any noticeable traffic 

3 volume-related level of service impacts. Therefore, transportation impacts during the 

4 construction, operations, and decommissioning of the proposed NWMI facility using the 

5 subcritical fission process technology at the Discovery Ridge site would be SMALL.

6 5.3.3.11 Accidents

7 The NRC staff previously evaluated the environmental impacts from radiological and chemical

8 accidents at a proposed facility based on the subcritical fission process. This facility would use 

9 engineered design features and controls to mitigate the consequences of accidents. The 

10 evaluation showed that public doses from possible radiological accidents would be within 

11 10 CFR Part 20 limits. The evaluation also showed that, for possible chemical accidents, 

12 chemical concentrations at the location of the maximally exposed member of the public would 

13 either be below PAC-1 limits, or above PAC-1 limits but below PAC-2 limits (PAC-1, PAC-2, and 

14 PAC-3 limits are defined in Section 4.11.2), meaning that chemical accidents could cause mild 

15 transient adverse health effects but would not cause serious irreversible health effects. The 

16 NRC staff’s environmental evaluation stated that if the subsequent NRC staff safety evaluation 

17 determined that radiological and chemical accident exposures would be in compliance with NRC 

18 regulatory limits (10 CFR Part 20 dose limits and chemical accident performance requirements 

19 in 10 CFR 70.61), then the impacts from accidents at the subcritical fission process facility 

20 would be SMALL (NRC 2015c; SHINE 2015).

21 The NRC staff expects that other subcritical fission process facilities would have similar 

22 engineered design features and controls to mitigate the consequences of accidents, and it also 

23 expects that the consequences of accidents at other subcritical fission process facilities would 

24 be similar. Before construction or operation of a subcritical fission process facility, the NRC staff 

25 would perform a safety review of the proposed facility that would include a thorough evaluation 

26 of possible radiological or chemical accidents at the facility, including the consequences of 

27 those accidents and any features or controls that would mitigate those consequences. To 

28 receive a construction permit or operating license from the NRC, the applicant would have to 

29 demonstrate that the facility would be in compliance with all NRC regulations, including 

30 10 CFR Part 20 dose limits and the accident performance requirements in 10 CFR 70.61, as 

31 applicable. If the NRC staff determines in its SER that the subcritical fission process facility 

32 would be operated in compliance with all applicable regulations governing the consequences of 

33 accidents, then the NRC staff concludes that the impacts from accidents at the subcritical fission 

34 process facility would be SMALL.

35 5.3.3.12 Environmental Justice

36 The environmental justice impacts from a subcritical fission process alternative would be the 

37 similar as those discussed for the NWMI facility in Section 4.12. Minority and low-income 

38 populations residing along site access roads could be affected by noise and dust and increased 

39 commuter vehicle and truck traffic during construction, operations, and decommissioning. 

40 However, these effects are not likely to be high and adverse and would be short term and within 

41 a limited time period during certain hours of the day. Noise and dust impacts from onsite 

42 activities during construction and decommissioning would similarly be short term. Everyone 

43 living near Discovery Ridge could be affected by operation activities, including minority and 

44 low-income populations. Any human health and environmental effects would depend on the 

45 magnitude of the change from current environmental conditions.

46 As discussed in Section 5.3.3.8 of this EIS, the potential radiological dose to the public from 

47 facility operations would be well within NRC and applicable Federal, State, and local regulatory 

48 limits. As a result, everyone living near the Discovery Ridge site, including minority and 
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1 low-income populations, would not be adversely affected by radiation exposure during facility 

2 operations. Permitted nonradiological air emissions would also be required to remain within 

3 regulatory standards. Noise levels may increase along U.S. Highway 63 because of increased 

4 commuter vehicle and truck traffic during NWMI facility operations. This may not be noticeable, 

5 however, given the relatively small size of the workforce and the limited number of daily truck 

6 deliveries and shipments. Based on this information, construction, operations, and 

7 decommissioning of the proposed NWMI facility using the subcritical fission process technology 

8 would not likely have disproportionately high and adverse human health and environmental 

9 effects on minority and low-income populations living near the Discovery Ridge site.

10 5.3.3.13 Cumulative Impacts

11 Cumulative impacts for the subcritical fission-based alternative would be similar to those 

12 described in Chapter 4 for the NWMI RPF facility at the Discovery Ridge site, because direct 

13 contributory effects from construction, operations, and decommissioning for this technology 

14 would be similar.

15 5.4 Cost-Benefit Comparison

16 NEPA and CEQ require that all agencies of the Federal government prepare detailed 

17 environmental statements on proposed major Federal actions significantly affecting the quality 

18 of the human environment. One of NEPA’s principal objectives is to require each Federal 

19 agency to consider, in its decisionmaking process, the environmental impacts of each proposed 

20 major action. In particular, as stated below, Section 102 of NEPA requires all Federal agencies 

21 to the fullest extent possible to: 

22 (B) identify and develop methods and procedures, in consultation with the 

23 Council on Environmental Quality established by Title II of this Act, which will 

24 insure that presently unquantified environmental amenities and values may be 

25 given appropriate consideration in decision-making along with economic and 

26 technical considerations. (42 U.S.C. 4321).

27 However, neither NEPA nor CEQ requires the benefits and costs of a proposed action to be 

28 quantified in dollars or any other common metric. The intent of this section is not to identify and 

29 quantify all potential societal benefits of the proposed action and compare them to potential 

30 costs. Instead, it focuses only on those benefits and costs of such magnitude or importance 

31 that including them in this analysis can inform the decisionmaking process.

32 This section compiles the expected impacts from operations of the proposed NWMI facility and 

33 aggregates them into two final categories: (1) the expected costs and (2) the expected benefits 

34 derived from approving the proposed action. Table 5–11 describes the following information on 

35 major environmental costs and benefits, including:

36 • average annual production of commercial products;

37 • expected increase in tax payments to State and local tax jurisdictions during 

38 construction and operations;

39 • other benefits;

40 • environmental degradation, which includes impacts on: land use and visual 

41 resources, air quality, noise, geologic environment, water resources, ecological 

42 resources, historic and cultural resources, socioeconomics, human health, waste 

43 management, transportation, environmental justice, and increased demand for public 

44 services;
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1 • effects on human health; and

2 • other costs, which include lost tax revenues, decreased recreational value, and

3 transportation (as appropriate).

4 Table 5–11. Costs and Benefits of Constructing, Operating, and Decommissioning the 

5 Proposed NWMI Facility at the Discovery Ridge Site

Cost-Benefit Category Description

Impact 

Assessment

Benefits

Domestic Production of 

Mo-99

NWMI would produce a domestic supply of Mo-99;

no domestic producers of this widely used medical 

radioisotope currently exist in the United States and 

the United States currently imports all of its supply.

_

Use of LEU Targets NWMI would use LEU targets for production of 

medical radioisotopes, contributing to the Federal 

nonproliferation objective to phase out U.S. exports 

of highly enriched uranium, as identified in the 

Energy Policy Act of 1992.

_

Tax Revenues Construction of the proposed NWMI facility would 

result in estimated total additional tax revenues of 

approximately $2.5 million for the City of Columbia,

Boone County, and the State of Missouri. During 

the 30-year operational period, NWMI would 

annually pay estimated property taxes of 

approximately $1.2 million, sale taxes of $830,000, 

and income taxes of $465,000 (NWMI 2015a).

_

Local Economy Increased jobs would benefit the area economically. 

(Section 4.7)

_

Costs

Land Use Land use impacts would be confined to agricultural 

land comprising the proposed 7.4 ac (3.0 ha) site, 

and 0.26 ac. (0.1 ha) of offsite agricultural lands 

immediately adjacent to the proposed site, which is 

a small portion of the agricultural land within a 5-mi 

(8-km) radius of the site (Section 4.1.1). The 

location of the proposed facility is within an area 

designated as an industrial certified site. No 

additional land would be disturbed during operations 

or decommissioning.

SMALL

Visual Resources The proposed NWMI facility would not noticeably 

alter visual resources, based on the low scenic 

quality and light industrial viewshed within the 

vicinity of the proposed site. (Section 4.1.2)

SMALL

Air Quality Air quality impacts during construction, operations, 

and decommissioning, would be negligible, given 

the relatively low emissions and the unlikelihood that 

they would contribute to concentrations that would 

interfere with the maintenance NAAQS or degrade 

Boone County’s attainment/unclassifiable 

designation. (Section 4.2)

SMALL
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Cost-Benefit Category Description

Impact 

Assessment

Noise During construction, operations, and 

decommissioning, noise would be minimal, given 

the minor (1 dBA) expected increases in noise 

levels. (Section 4.2)

SMALL

Geologic Environment Construction of the proposed NWMI facility would 

consume geologic resources and have the potential 

to increase soil erosion, but the overall impact would 

be minor, given that the geologic resources are 

widely available within the region and erosion would 

be managed with the implementation of BMPs. 

(Section 4.3)

SMALL

Water Resources Water resource impacts during construction, 

operations, and decommissioning would be 

negligible, because of the lack of natural surface 

water features on site, implementation of 

appropriate stormwater management practices, and 

the use of municipal water. (Section 4.4)

SMALL

Ecological Resources Terrestrial and aquatic ecology impacts are 

expected to be SMALL, because the proposed 

action would not affect any high quality habitats; the 

entire site has been previously disturbed; and 

because no aquatic features or Federally or 

State-listed species occur on the site. (Section 4.5) 

SMALL

Historic and Cultural 

Resources

Because no historic properties would be affected 

and no archaeological sites or evidence of cultural 

resources were identified during the Phase I survey, 

historic and cultural resources are not likely to be 

impacted by the construction, operations, or 

decommissioning of the proposed NWMI facility at 

the Discovery Ridge site. The NWMI facility would 

also have little or no visual impact. Based on these 

factors, as well as tribal input and the cultural 

resource assessments and consultations performed 

by the NRC staff, the proposed facility would not 

impact any known historic and cultural resources at 

the Discovery Ridge site. (Section 4.6)

No historic 

properties affected

Socioeconomics Socioeconomic impacts are expected to be SMALL, 

based on the size of the workforce required to 

construct, operate, and decommission the NWMI 

facility. (Section 4.7) 

SMALL

Human Health Human health impacts would be minimized because 

access to the site would be restricted, NWMI would 

implement normal safety practices contained in 

OSHA regulations, and NWMI would operate the 

proposed NWMI facility in accordance with all 

applicable Federal and State of Missouri regulatory 

requirements. (Section 4.8)

SMALL
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Cost-Benefit Category Description

Impact 

Assessment

Waste Management Based on the availability of waste disposal pathways 

for radiological and nonradiological waste; NWMI’s 

proposed waste management systems; engineered 

design features to minimize radioactive and 

nonradioactive contamination; and NRC, DOT, and 

State of Missouri radiation protection requirements, 

the NRC staff concludes that radioactive and 

nonradioactive waste is expected to be managed in 

accordance with applicable regulatory requirements. 

(Section 4.9)

SMALL

Transportation Due to the small size of the average daily workforce, 

the low number of daily truck deliveries and 

shipments, and easy access to U.S. Highway 63,

there would be little if any noticeable traffic

volume-related level of service impacts. 

(Section 4.10)

SMALL

Accidents The NRC staff is conducting an independent review 

of the potential dose to the public from chemical and 

radiological accidents in the NRC staff’s SER. If the 

NRC staff determines in its SER that the proposed 

NWMI facility would comply with NRC regulations 

applicable to chemical and radiological accident 

consequences, the NRC staff concludes that the 

impacts from potential chemical and radiological 

accidents would be SMALL.

SMALL

Environmental Justice Minority and low-income populations residing along 

site access roads or near the proposed site could be 

affected by noise and dust and increased commuter 

and other vehicular traffic during construction and 

decommissioning. However, these would be short 

term and primarily limited to onsite activities. 

Operation of the proposed NWMI facility is not 

expected to disproportionately affect minority and 

low-income populations, as everyone living near the 

proposed NWMI facility and the existing research 

park would be exposed to the same potential effects 

from operations, and any impacts would depend on 

the magnitude of the change in ambient conditions. 

Permitted nonradiological air emissions are 

expected to remain within regulatory limits. 

(Section 4.12)

Minority and 

low-income 

populations would 

not be expected to 

experience any 

disproportionately 

high and adverse 

effects

1 The financial costs related to the construction, operations, and decommissioning of the 

2 proposed NWMI facility are described below. Regulations at 10 CFR 50.33(f)(1) state that an 

3 applicant for a construction permit shall demonstrate that it possesses or has reasonable 

4 assurance of obtaining the necessary funding needed to cover estimated construction and 

5 related fuel cycle costs. Further, the applicant shall indicate the source(s) of funds to cover 

6 these costs. In Chapter 15 of the preliminary safety analysis report (PSAR), NWMI stated that it 

7 has obtained financing for its development and construction project using various sources of 

8 financing, including equity and debt, and listed financial commitments. These specific financial 
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1 commitments are considered business sensitive and proprietary, and as such have been 

2 withheld from public disclosure per 10 CFR 2.390.

3 NWMI’s operational cost estimates provided in Chapter 15 of the PSAR include the total annual 

4 operating costs for the first 5 years (NWMI 2015j). NWMI expects that revenue from the sale of 

5 Mo-99 and other radioisotopes will exceed operating costs, and provided a preliminary cost 

6 estimate (NWMI 2015j).

7 5.4.1 Benefit and Costs of Alternatives

8 This section compares the environmental impacts of the proposed NWMI facility with those that 

9 would be associated with using an alternative site or alternative technologies. Table 5–12 

10 provides a tabular comparison of the potential environmental impacts of constructing, operating, 

11 and decommissioning the proposed NWMI facility at Discovery Ridge with the alternative site 

12 (MURR) and the no-action alternative. In nearly all cases, impacts associated with using the 

13 alternative site would be similar to the impacts associated with the proposed action, and remain

14 SMALL. The only exception would be noise associated with the MURR site, which would result 

15 in SMALL to MODERATE impacts. The financial costs of construction, operations, and 

16 decommissioning of the proposed NWMI facility at the alternative site would likely be similar to 

17 the financial costs at the proposed NWMI site because of the facility’s design and operational 

18 plan. The no-action alternative would have SMALL impacts for every resource area.

19 Table 5–13 provides a tabular comparison of the potential environmental impacts of 

20 constructing, operating, and decommissioning the proposed NWMI facility at the Discovery 

21 Ridge site with the potential environmental impacts of using an alternative technology 

22 (linear accelerator-based or subcritical fission). The NRC staff determined that impacts across 

23 all resources and areas of evaluation would be SMALL, regardless of which radioisotope

24 production technology is employed.

25 Construction and operation of the proposed facility at an alternative site or using an alternative 

26 technology would not reduce or avoid adverse effects, compared with constructing and 

27 operating the proposed NWMI facility at the Discovery Ridge site. The adverse environmental 

28 impacts from the no-action alternative would be SMALL. However, the no-action alternative 

29 would not fulfill the purpose and need for the proposed action.

30 Table 5–12. Comparison of Impacts for the Proposed 

31 NWMI Facility, Proposed Alternative Site, and No-Action

Impacts on Resource or Other 

Area Evaluation

Proposed

Discovery Ridge Site

MURR 

Alternative Site No-Action

Land Use SMALL SMALL SMALL

Visual Resources SMALL SMALL SMALL

Air Quality SMALL SMALL SMALL

Noise SMALL SMALL to SMALL

MODERATE

Geologic Environment SMALL SMALL SMALL

Water Resources SMALL SMALL SMALL

Ecological Resources SMALL SMALL SMALL

Historic and Cultural Resources No historic properties affected
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Impacts on Resource or Other 

Area Evaluation

Proposed

Discovery Ridge Site

MURR 

Alternative Site No-Action

Socioeconomics SMALL SMALL SMALL

Human Health SMALL SMALL SMALL

Waste Management SMALL SMALL SMALL

Transportation SMALL SMALL SMALL

Accidents SMALL SMALL SMALL

Environmental Justice No disproportionately high and adverse human health and 

environmental effects on minority and low-income populations

1 Table 5–13. Comparison of Technologies at the 

2 Proposed NWMI Facility in Discovery Ridge

Impacts on Resource or Other 

Area Evaluation

Proposed NWMI 

Technology

Linear AcceleratorBased Technology Subcritical

Fission Technology

Land Use SMALL SMALL SMALL

Visual Resources SMALL SMALL SMALL

Air Quality SMALL SMALL SMALL

Noise SMALL SMALL SMALL

Geologic Environment SMALL SMALL SMALL

Water Resources SMALL SMALL SMALL

Ecological Resources SMALL SMALL SMALL

Historic and Cultural Resources No historic properties affected

Socioeconomics SMALL SMALL SMALL

Human Health SMALL SMALL SMALL

Waste Management SMALL SMALL SMALL

Transportation SMALL SMALL SMALL

Accidents SMALL SMALL SMALL

Environmental Justice No disproportionately high and adverse human health and 

environmental effects on minority and low-Income populations

3 5.4.2 Cost-Benefit Conclusions

4 In Chapter 4 and the preceding sections of Chapter 5, the NRC staff described the costs and 

5 benefits of the proposed action as well as alternatives to the proposed action. In weighing the 

6 costs and benefits, the NRC staff concludes that the overall benefits of constructing, operating, 

7 and decommissioning the proposed NWMI facility at the Discovery Ridge site outweigh the 

8 environmental and other costs based upon the following considerations:

9 • U.S. policy is to ensure a reliable supply of medical radioisotopes while minimizing 

10 the use of highly enriched uranium for civilian purposes (NNSA 2011; 

11 White House 2012);
Alternatives

5-87

1 • the small environmental impact, including radiological impacts and risk to human

2 health, which would be caused by constructing, operating, and decommissioning the

3 proposed NWMI facility at the Discovery Ridge site;

4 • the economic benefit of constructing and operating the proposed NWMI facility to

5 communities located near the Discovery Ridge site; and

6 • the increased availability of medical isotopes for U.S. public health needs.

7 Constructing, operating, and decommissioning the NWMI facility at the Discovery Ridge site 

8 would have slightly less environmental costs than at the alternative site because impacts from 

9 noise would be SMALL to MODERATE at the MURR site, due to the close proximity of the 

10 exiting MURR workforce to heavy equipment noise that would be associated with construction 

11 and decommissioning an NWMI facility within the MURR Center. However, the overall benefits 

12 of constructing and operating the proposed NWMI facility at either site would outweigh the 

13 environmental or other costs for the reasons outlined above.

14 Installation of alternative technologies (e.g., linear accelerator-based or subcritical 

15 fission-based) would not result in any greater economic advantages or disadvantages over the 

16 proposed NWMI technology, and the environmental costs and benefits would be similar to those 

17 described for the proposed NWMI facility at the Discovery Ridge site. Therefore, the overall 

18 benefits and costs of utilizing an alternative technology at the Discovery Ridge site would be the 

19 same and would outweigh the environmental and other costs for the reasons outlined above.

20 5.5 Alternatives Summary

21 In this Chapter the NRC staff considered the following alternatives to constructing, operating, 

22 and decommissioning of the NWMI facility at the proposed Discovery Ridge site in Columbia, 

23 Missouri: 

24 • the no-action alternative;

25 • construction, operations, and decommissioning of the NWMI facility at the MURR site

26 (alternative site);

27 • construction, operations, and decommissioning of a linear accelerator-based facility

28 at the Discovery Ridge site (Alternative Technology No. 1); and

29 • construction, operations, and decommissioning of a subcritical fission-based facility

30 at the Discovery Ridge site (Alternative Technology No. 2).

31 The impacts for the proposed action, the no-action alternative, alternative site, and alternative 

32 technologies are summarized in Tables 5–12 and 5–13.

33 In conclusion, the NRC staff notes that the no-action alternative would result in SMALL impacts 

34 to all resource areas. The no-action alternative, however, does not fulfill the purpose and need 

35 of the project. The environmentally preferred alternatives are the construction, operations, and 

36 decommissioning of the NWMI facility at the Discovery Ridge site (proposed action), the linear 

37 accelerator-based facility at the Discovery Ridge site (Alternative Technology No. 1), and the 

38 subcritical fission-based facility at the Discovery Ridge site (Alternative Technology No. 2). The 

39 impacts associated with the proposed action and the two alternative technologies would be 

40 SMALL for all resource areas. The other alternative capable of meeting the purpose and need 

41 of the project is locating the NWMI facility at the MURR site. However, this alternative would 

42 entail potentially greater impacts than the proposed action of constructing the NWMI facility at 

43 the Discovery Ridge site (i.e., impacts from noise for constructing the NWMI facility at the 

44 MURR site would be SMALL to MODERATE). 

6-1 

1 6.0 CONCLUSIONS

2 This environmental impact statement (EIS) contains the environmental review of the Northwest 

3 Medical Isotopes, LLC (NWMI), application for a construction permit under Title 10 of the Code 

4 of Federal Regulations (10 CFR) Part 50 that would allow construction of the NWMI medical 

5 radioisotope production facility (NWMI facility) at the Discovery Ridge site in Columbia, Missouri. 

6 This EIS follows the requirements in 10 CFR Part 51, which are the U.S. Nuclear Regulatory 

7 Commission’s (NRC’s) regulations that implement the National Environmental Policy 

8 Act of 1969, as amended (42 U.S.C. 4321 et seq.). This chapter presents preliminary 

9 conclusions and recommendations from the environmental review of the NWMI facility. 

10 Section 6.1 summarizes the environmental impacts of construction, operations, and 

11 decommissioning. Section 6.2 compares the environmental impacts of the proposed action, the 

12 construction of the NWMI facility at one alternative site, and the construction of two alternative 

13 technologies at the Discovery Ridge site in Columbia, Missouri. Section 6.3 discusses 

14 unavoidable impacts of the proposed action and alternatives to the proposed action and 

15 identifies resource commitments. Section 6.4 presents the NRC staff’s preliminary conclusions 

16 and recommendations.

17 6.1 Environmental Impacts of the Proposed Action

18 The NRC staff concludes that issuing a construction permit for the NWMI facility would have 

19 SMALL impacts for all resource areas. Table 6–1 summarizes the environmental impacts from 

20 construction, operations, and decommissioning of the proposed NWMI facility.

21 The NRC staff also considered cumulative impacts of past, present, and reasonably foreseeable 

22 future actions regardless of which agency (Federal or non-Federal) or person undertakes them. 

23 In Section 4.14, the NRC staff concluded that the cumulative impacts would be SMALL for all 

24 resource areas with the exception of air quality, noise, water resources, and ecological 

25 resources. For air quality, noise and water resources, the NRC staff concluded that the 

26 cumulative impacts would be SMALL to MODERATE. For ecological resources, the NRC staff 

27 concluded that the cumulative impacts would be MODERATE.

28 Table 6–1. Summary of the Environmental Impacts from Construction, Operations, and 

29 Decommissioning of the Proposed NWMI Facility at the Discovery Ridge site

Resource Area Summary of Impact Impact Level

Land Use Land use impacts would be confined to 

agricultural land comprising the proposed 7.4 ac 

(3.0 ha) site, and 0.26 ac. (0.1 ha) of offsite 

agricultural lands immediately adjacent to the 

proposed site, which is a small portion of the 

agricultural land within a 5-mi (8-km) radius of the 

site. The location of the proposed facility is within 

an area designated as an industrial-certified site 

(Section 4.1.1).

SMALL

Visual Resources The proposed NWMI facility would not noticeably 

alter visual resources, based on the low scenic 

quality and light industrial viewshed within the 

vicinity of the proposed site (Section 4.1.2).

SMALL
Conclusions

6-2 

Resource Area Summary of Impact Impact Level

Air Quality Air quality impacts during construction, 

operations, and decommissioning, would be 

negligible, given the relatively low emissions and 

the unlikelihood that they would contribute to 

concentrations that would interfere with NAAQS 

or degrade Boone County’s 

attainment/unclassifiable designation 

(Section 4.2.1).

SMALL

Noise During construction, operations, and 

decommissioning, an increase in noise levels 

beyond 1 dBA is not expected and therefore 

would not be noticeable (Section 4.2.2).

SMALL

Geologic Environment Construction and decommissioning of the 

proposed NWMI facility would consume geologic 

resources and have the potential to increase soil

erosion, but the overall impact would be minor, 

given that the geologic resources are widely 

available within the region and erosion would be 

managed with the implementation of best 

management practices (BMPs) (Section 4.3). 

During facility operations, previously disturbed 

areas would not be subject to long-term soil 

erosion. Areas disturbed during construction 

would be within the footprint of the completed 

facility or overlain by other impervious surfaces 

(e.g., roadways and parking lots), or revegetated. 

As a result, incremental impacts on geology and 

soils would be negligible during operations.

SMALL

Water Resources Water resource impacts during construction, 

operations, and decommissioning would be 

negligible, because of the lack of natural surface 

water features on site, implementation of 

appropriate stormwater management practices, 

and the use of municipal water (Section 4.4).

SMALL

Ecological Resources No aquatic features or Federally or State-listed 

species occur on the Discovery Ridge site; the 

site is a previously disturbed habitat; 

construction, operations, and decommissioning 

would not permanently or temporarily affect any 

high-quality habitats, such as grasslands, forests, 

or wetlands. Operations could result in bird

collisions with the facility; however, mortality from 

bird collisions is expected to be negligible

(Section 4.5). 

SMALL
Conclusions

6-3

Resource Area Summary of Impact Impact Level

Historic and Cultural Resources No historic properties would be affected and no 

archaeological sites or evidence of cultural 

resources were identified during the Phase I 

survey. Therefore, historic and cultural resources 

are not likely to be impacted by the construction, 

operations, or decommissioning of the proposed 

NWMI facility at the Discovery Ridge site. The 

NWMI facility would also have little or no visual 

impact. Based on these factors, as well as tribal 

input and a cultural resource assessment and 

consultations, the proposed facility would not 

affect any historic and cultural resources at the 

Discovery Ridge site (Section 4.6).

No historic 

properties 

affected

Socioeconomics Given the small number of workers during 

construction, operations, and decommissioning, 

the overall socioeconomic impacts would be 

SMALL (Section 4.7).

SMALL

Human Health NWMI would implement normal safety practices 

contained in OSHA regulations, and NWMI would 

operate the proposed NWMI facility in 

accordance with all applicable Federal and State 

of Missouri regulatory requirements. The 

maximum dose to a member of the public would 

be well within the annual dose limit of 100 mrem 

in 10 CFR 20.1301. Access to the site would be 

restricted and NWMI would administratively 

control doses to occupational workers, such that 

these doses would be well below the limits in 

10 CFR 20.1201 (Section 4.8).

SMALL

Waste Management Based on the availability of waste disposal 

pathways for radiological and nonradiological 

waste; NWMI’s proposed waste management 

systems; engineered design features to minimize 

radioactive and nonradioactive contamination; 

and NRC, DOT, and State of Missouri radiation 

protection requirements, radioactive and 

nonradioactive waste can be managed in 

accordance with applicable regulatory 

requirements (Section 4.9).

SMALL

Transportation Due to the small size of the average daily 

workforce, the low number of daily truck 

deliveries and shipments, and easy access to 

U.S. Highway 63, there would be little if any 

noticeable traffic volume-related level of service 

impacts during construction, operations, and 

decommissioning (Section 4.10).

SMALL
Conclusions

6-4

Resource Area Summary of Impact Impact Level

Accidents The NRC staff is conducting an independent 

review of the consequences of accidents, and will 

document this review in its SER. If the NRC staff 

determines in its SER that the proposed NWMI 

facility would comply with 10 CFR 70.61 and any 

other NRC regulations applicable to radiological 

accident consequences and hazardous chemical

accident consequences, the impacts from these 

accidents at the proposed facility would be 

SMALL.

SMALL

Environmental Justice Minority and low-income populations residing 

along site access roads or near the proposed site 

could be affected by noise and dust and 

increased commuter and other vehicular traffic

during construction and decommissioning. 

However, these would be short term and primarily 

limited to onsite activities. Operation of the 

proposed NWMI facility is not expected to 

disproportionately affect minority and low-income 

populations because everyone living near the 

proposed NWMI facility and the existing research 

park would be exposed to the same potential 

effects from operations, and any impacts would 

depend on the magnitude of the change in 

ambient conditions. Permitted nonradiological air 

emissions are expected to remain within 

regulatory limits (Section 4.12).

Minority and 

low-income 

populations would 

not be expected 

to experience any 

disproportionately 

high and adverse 

effects

1 6.2 Comparison of Alternatives

2 In Chapter 5, the NRC staff considered the following alternatives to construction, operations, 

3 and decommissioning of the proposed NWMI facility at the Discovery Ridge site in Columbia, 

4 Missouri:

5 • the no action-alternative;

6 • construction, operations, and decommissioning of the NWMI facility at the University 

7 of Missouri Research Reactor (MURR) site in Columbia, Missouri;

8 • construction, operations, and decommissioning of a linear accelerator-based facility 

9 at the proposed Discovery Ridge site (Alternative Technology No. 1)

10 • construction, operations, and decommissioning of a subcritical fission-based facility 

11 at the proposed Discovery Ridge site (Alternative Technology No. 2).

12 Tables 5–12 and 5–13 summarize the impacts for the proposed action, the no-action alternative, 

13 alternative site, and two alternative technologies. In conclusion, the NRC staff notes that the 

14 no-action alternative would result in SMALL impacts to all resource areas. However, the 

15 no-action alternative does not fulfill the purpose and need of the project. The environmentally 

16 preferred alternatives are the construction, operations, and decommissioning of the NWMI 

17 facility at the Discovery Ridge site (proposed action), the linear accelerator-based facility at the 

18 Discovery Ridge site (Alternative Technology No. 1), and the subcritical fission-based facility at 
Conclusions

6-5

1 the Discovery Ridge site (Alternative Technology No. 2). Like the impacts associated with the 

2 proposed action, the impacts associated with the two alternative technologies would be SMALL 

3 for all resource areas. The other alternative capable of meeting the purpose and need of the 

4 project is locating the NWMI facility at the MURR site. However, this alternative would entail 

5 potentially greater impacts than the proposed action of constructing the NWMI facility at the 

6 Discovery Ridge site (i.e., impacts from noise for constructing the NWMI facility at the MURR 

7 site would be SMALL to MODERATE).

8 6.3 Resource Commitments

9 6.3.1 Unavoidable Adverse Impacts 

10 Section 102(2)(C)(ii) of the National Environmental Policy Act of 1969 requires that an EIS 

11 include information on any adverse environmental effect that cannot be avoided should the 

12 proposal be implemented. Unavoidable adverse impacts are predicted adverse environmental 

13 impacts that cannot be avoided.

14 As described in this EIS and summarized above, the impacts to all resource areas from the 

15 proposed action would be SMALL: the environmental effects would not be detectable or would 

16 be so minor that they would neither destabilize nor noticeably alter any important attribute of the 

17 resource. However, even though SMALL, there may be unavoidable adverse impacts from 

18 construction, operations, and decommissioning of the proposed NWMI facility. Table 6–2 

19 presents the unavoidable adverse impacts from construction, operations, and decommissioning 

20 of the proposed NWMI facility and presents mitigations and controls intended to lessen the 

21 adverse impact. Unless noted otherwise, mitigation measures were taken from NWMI’s 

22 Environmental Report (NWMI 2015a, 2015d) or from responses to requests for additional 

23 information (NWMI 2015c, 2016a, 2016b).

24 Table 6–2. Unavoidable Adverse Environmental Impacts

Resource Area Unavoidable Adverse Impact Mitigation Measures

Land Use 7.4 ac (3.0 ha) of agricultural land

would be disturbed and converted 

into an industrial area. An 

additional 0.26 ac (0.1 ha) would 

be temporarily converted from 

agricultural land to a construction 

material staging area.

NWMI would restore temporarily 

affected areas with vegetation that is 

common to the Discovery Ridge 

Research Park. Ground vegetation 

would include grasses, shrubs, trees 

and/or ornamental flowers including 

native species. The facility would be 

built and operated with all local zoning 

requirements.

Visual Resources Partial obstruction of views of the 

existing landscape as a result of 

the new facility and a small steam 

plume from exhaust stack.

NWMI would revegetate open areas 

with grasses, shrubs, trees and/or 

ornamental flowers including native 

species.
Conclusions

6-6

Resource Area Unavoidable Adverse Impact Mitigation Measures

Air Quality During construction and 

decommissioning, increases in 

fugitive dust and air emissions

would result from earth-moving 

activities, construction equipment, 

worker vehicle commuting, 

delivery and shipment vehicles. 

During facility operations, air 

emissions would result from 

worker vehicle commuting, 

delivery and shipment vehicles.

NWMI would control fugitive dust by 

watering unpaved and disturbed areas, 

stabilizing spoil piles, revegetating 

slopes, and minimizing soil disturbance 

through phased grading. NWMI would 

reduce equipment idle times, use 

ultra-low sulfur diesel fuel, and install 

pollution control devices on 

construction equipment to minimize 

construction equipment related 

emissions. NWMI would develop a 

comprehensive program for controlling 

GHG emissions associated with 

operation of the NWMI facility. This will 

include developing a GHG emission 

inventory, implementing methods for 

avoiding or minimizing GHG emissions 

identified in the inventory, and 

encouraging carpooling and other 

measures to minimize GHG emissions 

due to vehicle traffic during operation.

Noise Short-term localized noise from 

construction equipment and 

workforce and shipment/delivery 

vehicles. 

Distance to sensitive receptors would 

limit offsite noise levels. Facility design 

(e.g., wall thickness and physical 

barriers) would limit noise of operating 

equipment inside buildings.

Geologic Resources Construction would consume 

geologic resources and have the 

potential to increase soil erosion.

NWMI would conduct construction 

activities in accordance with the 

provisions of a Land Disturbance 

Permit and City of Columbia approved 

site development plan, which would 

require implementation of 

construction-related BMPs for soil

erosion and sediment control and 

stormwater pollution prevention during 

site development, facility construction, 

and for post development.
Conclusions

6-7

Resource Area Unavoidable Adverse Impact Mitigation Measures

Water Resources Stormwater runoff could potentially 

affect downstream surface water 

quality. Fuels and chemicals 

stored on the NWMI facility site 

could have substantial, localized 

water quality impacts if such 

materials were to be released to 

the environment.

Stormwater runoff from the NWMI 

facility site would be managed by an 

engineered stormwater management 

system, including necessary 

detention/retention structures, 

constructed and operated in 

compliance with State and municipal 

stormwater management plans, 

procedures, and practices. NWMI 

would be required to obtain a Land 

Disturbance Permit from the City of 

Columbia, which would require 

appropriate soil erosion and sediment 

control BMPs to be used to minimize 

soil erosion and the stormwater 

transport of suspended sediment and 

other pollutants.

NWMI would be required to adhere to a 

City-approved stormwater management 

plan to control the peak flow rates of 

stormwater discharge associated with 

specified design storms. Wastewater 

must meet the acceptance criteria of 

the Columbia Regional Wastewater 

Treatment Plan. Waste handling and 

pollution prevention practices and spill 

prevention and response procedures 

would be observed so that no materials 

or contaminants would be released to 

soils or exposed to stormwater, where 

they could contaminate underlying 

groundwater.

Ecological Resources Construction could result in a loss 

of low-quality habitat, the potential 

for wildlife avoidance and 

displacement caused by noise or 

herbicide applications, and 

increased risk of bird collisions 

with construction equipment and

artificially lighted structures. 

Operations could result in bird 

collisions with the facility. 

Decommissioning could result in 

the potential for wildlife avoidance 

and displacement caused by noise 

or herbicide applications and 

increased risk of bird collisions 

with construction equipment and 

artificially lighted structures.

NWMI would mitigate impacts from 

herbicide applications by implementing 

BMP requirements that would limit their 

use and contain the broad application 

throughout the site. During 

construction at night, NWMI would use 

BMPs, such as light source shielding

and appropriate directional lighting, to 

mitigate impacts associated with 

artificial nighttime illumination.

Historic and Cultural 

Resources

Construction could result in 

inadvertent discovery of historic or 

cultural resources.

If cultural or historical resources are 

identified during construction, NWMI 

will contact the SHPO immediately.
Conclusions

6-8

Resource Area Unavoidable Adverse Impact Mitigation Measures

Socioeconomics

Human Health Radiological: Workers and 

members of the public could be 

exposed to radiation, such as 

gaseous radioactive effluents that 

contain krypton, xenon, and 

tritium.

Nonradiological: Potential for 

chemical exposures and hazards 

to workers typical of any industrial 

facility.

NWMI would have facility design 

features and use procedures to 

minimize radiation exposure to 

occupational workers and members of 

the public. NWMI would maintain 

radiation exposure to facility workers to 

within the occupational dose limits in 

10 CFR 20.1201. Radiation exposure 

within the proposed facility would be 

minimized using shielding, optimized 

process designs, radiological work 

planning, protective equipment and 

materials, access controls, and 

contamination control measures that 

will all be used to keep doses to 

personnel as low as is reasonably 

achievable (ALARA). NWMI would 

have a radiological effluent monitoring 

program to ensure that the types and 

quantities of radioactive material 

released from the proposed facility are 

within expected parameters, such that 

the limits in 10 CFR 20.1301 and 

10 CFR 20.1101(d) would not be 

exceeded.

Transportation of radioactive materials, 

both on public highways and by air, 

must comply with the applicable DOT

regulations in 49 CFR Parts 172, 173, 

175, 177, and 397, as well as the NRC 

packaging requirements for radioactive 

material in 10 CFR Part 71.

NWMI would employ normal 

construction safety practices contained 

in Occupational Safety and Health 

Administration (OSHA) regulations, 

such as safety training, safety 

equipment, and supervision of the work 

force to promote worker safety and 

reduce the likelihood of worker injury 

during construction. Use of access 

controls, proper personal protective 

equipment, and safety practices would 

reduce instances of accidents or 

exposure to hazardous materials. An 

emergency response plan would be 

used to reduce the impact to human 

health and the environment.
Conclusions

6-9

Resource Area Unavoidable Adverse Impact Mitigation Measures

Waste Management Radioactive Waste: Generation of 

radiological waste and mixed 

waste, including 525,000 kg 

(1,157,427 lbs) of solidified liquid 

low-level radioactive waste

annually; 15,000 kg (33,069 lbs) 

encapsulated solid low-level 

radioactive waste annually; and 

7,000 kg (15,432 lbs) of 

unencapsulated solid low-level 

radioactive waste annually; and 

760 kg (1,676 lbs) of mixed waste 

annually.

Nonradioactive Waste: 

Generation of nonradiological 

hazardous (up to 1,000 kg 

(2,205 lbs) per month) and 

nonhazardous waste.

NWMI would implement a waste 

minimization and pollution prevention 

program that would include a recycling 

and reclamation program, and require 

employees to consider waste 

minimization and pollution prevention 

during performance of their jobs.

Transportation Increase in vehicular traffic would 

peak during shift changes or 

during peak construction and 

decommissioning activities, 

resulting in temporary levels of 

service impacts and possible 

delays at intersections. 

NWMI would encourage carpooling. 

Accidents If the NRC staff determines that 

the consequences and/or 

likelihood of possible accidents at 

the proposed NWMI facility would 

be low, such that the facility would 

be in compliance with the

performance requirements in 

10 CFR 70.61 and any other 

applicable NRC regulations, then 

only minor environmental impacts 

are anticipated.

The potential radiological and chemical

accident consequences must comply 

with applicable NRC regulations. 

NWMI would incorporate engineering 

design features and administrative 

controls to ensure that exposure from 

accidents would be within regulatory 

limits.

Environmental Justice Construction and 

decommissioning noise and dust 

impacts are expected to be short 

term and limited to onsite 

activities; minority and low-income 

populations residing along site 

access roads could be affected by 

an increase in the number of 

commuter vehicles and truck traffic

traveling to and from the proposed 

work site; human health and 

environmental impacts would not 

be high or adverse.

See discussions above on mitigation

measures for human health and 

environmental effects, such as noise, 

traffic, and air quality

1 In addition, the Missouri Department of Conservation (MDC) submitted a letter to the NRC dated 

2 June 2, 2016 (ADAMS No. ML16155A148), in which MDC recommended certain mitigation
Conclusions

6-10

1 measures be considered to avoid, minimize, and where necessary mitigate impacts to fish, 

2 forest, and wildlife resources (MDC 2016f). The NRC staff provided a copy of these 

3 recommended mitigation measures to NWMI for its consideration (NRC 2016f). These 

4 mitigation measures are summarized below:

5 • If site development or construction will result in tree removal, the applicant is 

6 encouraged to coordinate with the U.S. Fish and Wildlife Service.

7 • Regionally native plants should be used to revegetate areas where soils are disturbed 

8 for the project. Exercise caution to avoid introduction of non-native plants to the 

9 watershed, such as through a Hazard Analysis Critical Control Plan described by the 

10 American Society for Testing and Materials (ASTM E2592-80).

11 The NRC staff did not consider these mitigation measures when determining the potential

12 impacts from the proposed action because NWMI has not committed to incorporating the

13 suggested mitigation measures. NWMI is not required to implement the suggested mitigation

14 measures because they are recommendations, and not requirements, from MDC.

15 6.3.2 Relationship Between Local Short-Term Uses of the Environment and the 

16 Maintenance and Enhancement of Long-Term Productivity

17 The construction, operations, and decommissioning of the NWMI facility and alternatives to the 

18 proposed actions would result in short-term uses of the environment, as described in Chapters 4 

19 and 5. “Short-term” is the period of time during which construction, operations, and 

20 decommissioning activities would take place.

21 The construction, operations, and decommissioning of the NWMI facility would require 

22 short-term use of the environment and commitment of resources and would commit certain 

23 resources (e.g., land and energy), indefinitely or permanently. Short-term resource 

24 commitments would be similar at the alternative site and for the two alternative technologies if 

25 they were to be developed at the proposed Discovery Ridge site. These alternatives and the 

26 proposed action would result in similar relationships between local short-term uses of the 

27 environment and the maintenance and enhancement of long-term productivity.

28 Construction, operations, and decommissioning would require up to 7.4 ac (3.0 ha) of 

29 agricultural land that would be committed to industrial land use during the short term. In 

30 addition, during construction 0.26 ac (0.1 ha) of agricultural land would temporarily be used as a 

31 construction material staging area. The facility would partially obstruct views of the existing 

32 landscape. Construction, operations, and decommissioning could also displace wildlife through 

33 destruction of habitat or noise. Wildlife may return to the site once construction or 

34 decommissioning is completed if it is restored to suitable habitat. Mineral and other geologic 

35 resources would be consumed for facility construction. Water would be required for various 

36 purposes during NWMI facility construction, operations, and decommissioning as identified in 

37 Table 2–3.

38 Air emissions from construction, operations, and decommissioning would introduce small 

39 amounts of radiological and nonradiological constituents at the facility site. However, such 

40 emissions are not expected to affect air quality or radiation exposure to the extent that they 

41 would impair public health and long-term productivity of the environment. Noise emitted by 

42 construction, operations, and decommissioning activities would increase the ambient noise 

43 levels on site and in adjacent offsite areas. However, increases in noise levels are not expected 

44 to be noticeable, and noise levels would return to background levels once construction and 

45 decommissioning activities are complete.
Conclusions

6-11

1 Increased employment, expenditures, and tax revenues generated during construction, 

2 operations, and decommissioning activities directly benefit local, regional, and State economies 

3 over the short term. Worker vehicles and the delivery and shipment of materials would increase 

4 the volume of traffic on local roads. Worker and delivery vehicles-related traffic would be short 

5 term during peak construction and decommissioning activities and work shifts and, therefore, 

6 would not affect long-term productivity.

7 The management and disposal of low-level radioactive waste, hazardous waste, and 

8 nonhazardous waste requires an increase in energy and consumes space at treatment, storage, 

9 or disposal facilities. Regardless of the location, the use of land to meet waste disposal needs 

10 would reduce the long-term productivity of the land.

11 Extension installation of service lines (e.g., electric power, water) during construction of the 

12 proposed NWMI facility would connect the facility to utility providers. This additional 

13 infrastructure would be available and beneficial for any future use of the proposed NWMI facility 

14 after its decommissioning.

15 6.3.3 Irreversible and Irretrievable Commitment of Resources

16 This section describes the irreversible and irretrievable commitment of resources that have 

17 been noted in this EIS. Resources are irreversible when primary or secondary impacts limit 

18 future options for a resource. An irretrievable commitment refers to the use or consumption of 

19 resources that are neither renewable nor recoverable for future use. Irreversible and 

20 irretrievable commitments of resources for construction, operations, and decommissioning of a

21 medical isotope facility include the commitment of water, energy, raw materials, and other 

22 natural and man-made resources. In general, the commitment of capital, energy, labor, and 

23 material resources are also irreversible.

24 The implementation of the proposed site, alternative site, or the alternative technology 

25 considered in this EIS would entail the irreversible and irretrievable commitment of energy, 

26 water, chemicals, fossil fuels, and other natural and man-made resources. These resources 

27 would be unrecoverable. For example, NWMI would consume materials during construction, as 

28 described in Chapter 2. These materials would be irretrievable unless NWMI recycles them 

29 during decommissioning (e.g., finds another facility to use such materials). During operations, 

30 uranium used as the source for the molybdenum isotope would be the main resource that would 

31 be irreversibly and irretrievably committed.

32 Mineral and other geologic resources, such as concrete, granular material, steel, and asphalt 

33 necessary for construction of the facility, would be irreversibly committed for construction of the 

34 NWMI facility. In addition, a small amount of soils and sediments would be lost to wind and 

35 water erosion during construction, operations, and decommissioning.

36 A negligible increase in the mortality of birds could occur because of their collisions with facility 

37 structures. The loss of these birds would be irreversible and irretrievable. 

38 Nonradiological irreversible commitments to occupational human health resources may occur. 

39 Such impacts would be similar to potential hazards that occur at any industrial construction site.

40 Energy expended would be in the form of fuel for equipment, vehicles, and facility operations 

41 and electricity for equipment and facility operations. Electricity and fuel would be acquired from 

42 offsite commercial sources. Water would be obtained from existing water supply systems. 

43 These resources are readily available, and the amounts required are not expected to deplete

44 available supplies or exceed available system capacities.
Conclusions

6-12

1 6.3.4 Unresolved Conflicts

2 Section 102(2)(E) of the National Environmental Policy Act of 1969 requires that the NRC staff 

3 study, develop, and describe appropriate alternatives to recommended courses of action in any 

4 proposal which involves unresolved conflicts concerning alternative uses of available resources. 

5 In reviewing the potential impacts associated with the proposed action, the NRC staff did not 

6 identify any unresolved conflicts. 

7 6.4 Preliminary Recommendation

8 After weighing the environmental, economic, technical, and other benefits against environmental 

9 and other costs, and considering reasonable alternatives, the NRC staff’s preliminary 

10 recommendation, unless safety issues mandate otherwise, is the issuance of the construction 

11 permit to NWMI. The NRC staff based its preliminary recommendation on the following factors:

12 • NWMI’s Environmental Report;

13 • the NRC staff’s consultation with Federal, State, and local agencies, as well as Tribal 

14 officials;

15 • the NRC staff’s independent environmental review; and

16 • the NRC staff’s consideration of public comments received during the scoping

17 process.
7-1 

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34 [USGS] U.S. Geological Survey. 2014c. “Magnitude/Intensity Comparison.” U.S. Department 

35 of the Interior, U.S. Geological Survey, Earthquake Hazards Program. Page updated

36 September 29, 2014. Available at <http://earthquake.usgs.gov/learn/topics/mag_vs_int.php> 

37 (accessed 6 February 2016).

38 [USGS] U.S. Geological Survey. 2015a. Columbia Quadrangle, Missouri-Boone County, 

39 7.5 Minute Series. U.S. Department of the Interior, U.S. Geological Survey. Available at 

40 <http://viewer.nationalmap.gov/basic/#productSearch > (accessed 6 February 2016).

41 [USGS] U.S. Geological Survey. 2015b. Quaternary Fault and Fold Database of the 

42 United States. U.S. Department of the Interior, U.S. Geological Survey, Earthquake Hazards 

43 Program. Page updated February 13, 2015. Available at 

44 <http://earthquake.usgs.gov/hazards/qfaults> (accessed 6 February 2016).
References

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1 [USGS] U.S. Geological Survey. 2015c. 2010–2011 Minerals Yearbook, Missouri [Advance 

2 Release]. Reston, VA: U.S. Department of the Interior, U.S. Geological Survey. April 2015. 

3 Available at <http://minerals.usgs.gov/minerals/pubs/state/> (accessed 6 February 2016).

4 [USGS] U.S. Geological Survey. 2015d. “Missouri Earthquake History.” U.S. Department of 

5 the Interior, U.S. Geological Survey, Earthquake Hazards Program. Page updated 

6 January 14, 2005. Available at 

7 <http://earthquake.usgs.gov/earthquakes/states/missouri/history.php> (accessed 

8 6 February 2016).

9 [USGS] U.S. Geological Survey. 2015e. Land Cover Trends Project, Land Cover Trends. Last 

10 modified October 28, 2015. Available at <http://landcovertrends.usgs.gov/map.html> (accessed 

11 12 April 2016).

12 [USGS] U.S. Geological Survey. 2016a. “Search Earthquake Archive.” [Radius search 

13 parameters: center latitude 38.900516 N, center longitude -92.277174 W, and outside radius 

14 322 km; National Earthquake Information Center PDE catalog]. U.S. Department of the Interior, 

15 U.S. Geological Survey, Earthquake Hazards Program. Available at 

16 <http://earthquake.usgs.gov/earthquakes/search/> (accessed 24 February 2016).

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18 2010, Boone County, National Water Information System: Web Interface.] Page updated 

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20 4 March 2016).

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22 parameters: center latitude 38.93127912 N, center longitude -92.34190095 W, and outside 

23 radius 322 km; National Earthquake Information Center PDE catalog]. U.S. Department of the 

24 Interior, U.S. Geological Survey, Earthquake Hazards Program. Available at 

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27 Available at <http://www.wcstexas.com/facilities/site-capabilities> (accessed 20 April 2016).

28 White House. 2012. Fact Sheet: Encouraging Reliable Supplies of Molybdenum-99 Produced 

29 without Highly Enriched Uranium. Office of the Press Secretary. June 7, 2012. Available at 

30 <http://www.whitehouse.gov/the-press-office/2012/06/07/fact-sheet-encouraging-reliable31 supplies-molybdenum-99-produced-without-> (accessed 27 April 2016).

32 Wilson T. 2012. Water-Quality Assessment of the Cambrian-Ordovician Aquifer System in the 

33 Northern Midwest, United States. Reston, VA: U.S. Department of the Interior, U.S. Geological 

34 Survey, National Water-Quality Assessment Program. Scientific Investigations 

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36 6 February 2016).

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38 2000–2050 global change on ozone air quality in the United States. Journal of Geophysical 

39 Research, Volume 113.
8-1 

1 8.0 LIST OF PREPARERS

2 Members of the U.S. Nuclear Regulatory Commission’s (NRC’s) Office of Nuclear Reactor 

3 Regulation (NRR) prepared this environmental impact statement. Idoneous, Inc. provided 

4 technical editing support. Table 8–1 identifies each contributors name, affiliation, 

5 education/experience and function or expertise.

6 Table 8–1. List of Preparers

Name & Affiliation Education/Experience Function or Expertise

Jim Danna

NRC/NRR

M.S., Civil Engineering/Geology

29 years of experience in engineering 

and project management including 

16 years at NRC, including as an NRC

technical and projects branch manager

Management oversight

Alexander Adams

NRC/NRR

B.S. Nuclear Engineering; MBA 

Management Science and Accounting;

42 years of combined industry and 

government experience including 12 

years reactor operations, engineering, 

and management and 30 years NRC 

project and branch management

Management oversight

David Drucker

NRC/NRR

B.S., General Engineering; 

M.S., Engineering Management; 

34 years of project and program 

management experience

Environmental project manager

Jeffrey Rikhoff

NRC/NRR

M.R.P., Regional Planning; 

M.S., Economic Development and 

Appropriate Technology; B.A., English; 

36 years of combined industry and 

government experience including 

29 years in NEPA compliance, 

environmental impact analysis, 

socioeconomics and environmental 

justice impact analysis, cultural 

resource impacts, and comprehensive 

land-use and development planning

Socioeconomics, environmental justice, 

transportation

Ed Helvenston

NRC/NRR

M.S., Environmental Engineering with 

Health Physics focus; B.S., Nuclear 

Science and Engineering; 4 years of 

combined industry and government 

experience, including 1 year in nonpower reactor licensing, environmental 

impact assessment, and health 

physics, and 3 years in non-power 

reactor operations

Human health (radiological and 

nonradiological); accidents
List of Preparers

8-2 

Name & Affiliation Education/Experience Function or Expertise

Kevin Folk

NRC/NRR

B.A., Geoenvironmental Studies; 

M.S., Environmental Biology; 27 years 

of experience in NEPA compliance; 

geologic, hydrologic, and water quality 

impacts analysis; utility infrastructure 

analysis; and environmental regulatory 

compliance and water supply and 

wastewater discharge permitting

Geologic environment, surface water 

resources, groundwater resources, and 

management oversight 

Michelle Moser

NRC/NRR

M.S., Biological Sciences; 

B.S., Environmental Sciences; 

13 years of experience in ecological 

studies, environmental impact 

assessment, and protected resource 

management

Terrestrial and aquatic resources,

protected species and habitats, land 

use, visual resources, and alternatives

Nancy Martinez

NRC/NRR

A.M., Earth and Planetary Science; 

B.S., Earth and 

Environmental Science; 9 years of 

combined industry and government 

experience, including 5 years 

of experience in environmental 

impact analysis

Air quality, noise, climate change, 

connected actions, and environmental 

project manager

Russell Chazell

NRC/NRR

B.S., Liberal Studies; J.D, Law; 

M.S., Nuclear Engineering; Certificate 

in Project Management; Certificate in 

NEPA; 27 years of combined industry 

and government experience including

analytical and environmental laboratory 

science, laboratory project 

management, technical business 

development, engineering project 

management, and NEPA compliance

Historic and cultural resources,

non-radioactive waste management

non-radioactive human health

Robert Hoffman

NRC/NRR

B.S., Environmental Resource 

Management; 30 years of experience 

in NEPA compliance, environmental 

impact assessment, alternatives

identification and development, and 

facility siting

Historic and cultural resources, and 

cumulative effects

Susan Anastasi

Idoneous

Technical editing

1 
9-1 

9.0 DISTRIBUTION LIST OF AGENCIES, ORGANIZATIONS, AND 

PERSONS TO WHOM COPIES OF THIS ENVIRONMENTAL IMPACT 

STATEMENT ARE SENT

Table 9–1. List of Agencies, Organizations, and Persons to Whom Copies of This 

Environmental Impact Statement Are Sent

Name and Title Affiliation and Address

Bill Anoatubby

Governor 

The Chickasaw Nation 

P.O. Box 1548 

520 East Arlington 

Ada, OK 74821

Bill John Baker 

Principal Chief 

Cherokee Nation 

P.O. Box 948 

17675 South Muskogee Avenue 

Tahlequah, OK 74465

Everett Bandy

Tribal Historic Preservation Officer

Quapaw Tribe of Oklahoma 

P.O. Box 765 

Quapaw, OK 74363

John A. Barrett, Jr.

Chairman 

Citizen Potawatomi Nation 

1601 South Gordon Cooper Drive 

Shawnee, OK 74801

John Berrey

Chairman 

The Quapaw Tribe of Indians 

P.O. Box 765 

5681 South 630 Road 

Quapaw, OK 74363

Dan Brague Private Residence

Edwina Butler-Wolfe

Governor

Absentee-Shawnee Tribe of Indians of Oklahoma 

2025 South Gordon Cooper Drive 

Shawnee, OK 74801

Jennifer K. Campbell

Policy Coordinator

Missouri Department of Conservation

2901 West Truman Boulevard

P.O. Box 180

Jefferson City, MO 65102

Jerry Dowell

Director of Government Affairs

Columbia Chamber of Commerce

300 South Providence Road 

P.O. Box 1016 

Columbia, MO 65205

Bill Florea Boone County Government Center 

801 East Walnut, Room 315 

Columbia, MO 65201

Tamara Michele Francis

Chairperson 

Caddo Nation of Oklahoma 

P.O. Box 487, 507 NE 1 or 5 Miles West of City 

Binger, OK 73009

Nicholas F. Fowler

Chief Executive Officer

Northwest Medical Isotopes, LLC 

815 Northwest 9th Street, Suite 256 

Corvallis, OR 97330

Billy Friend 

Chief 

Wyandotte Nation 

64700 East Highway 60 

Wyandotte, OK 74370

John P. Froman

Chief 

Peoria Tribe of Indians of Oklahoma 

P.O. Box 1527 

Miami, OK 74355
Distribution List of Agencies, Organizations, and Persons

9-2 

Name and Title Affiliation and Address

Jonathan Garoutte 

Chief

Bureau of Environmental Epidemiology

Missouri Department of Health and Senior Services 

912 Wildwood 

P.O. Box 570 

Jefferson City, Missouri 65102

John Glascock

Deputy City Manager

City of Columbia

701 East Broadway

P.O. Box 6015 

Columbia, MO 65205

Edmore Green

Chairperson 

Sac and Fox Nation of Missouri in Kansas and 

Nebraska 

305 North Main Street 

Reserve, KS 66434

David Griggs Private Residence

Eddie Hamilton, 

Governor 

Cheyenne and Arapaho Tribes 

P.O. Box 38, 100 Red Moon Circle 

Concho, OK 73022

Carolyn Haass

Vice President

Northwest Medical Isotopes, LLC

815 Northwest 9th Street, Suite 256 

Corvallis, OR 97330

Robert Flying Hawk

Chairman 

Yankton Sioux Tribe of South Dakota 

P.O. Box 1153 

800 Main, S.W.

Wagner, SD 57361

Kerry Holton

President

Delaware Nation 

3 Miles North Anadarko on Highway 281 

Main Office Building 100 

P.O. Box 825 

Anadarko, OK 73005

Earl S. Howe III 

Chairman 

Ponca Tribe of Indians of Oklahoma 

20 White Eagle Drive 

Ponca City, OK 74601

Elaine Huch 

Chairwoman 

Kaw Nation, Oklahoma

Drawer 50, 698 Grandview Drive 

Kaw City, OK 74641

Diane Hunter 

Acting Tribal Historic Preservation Officer

Miami Tribe of Oklahoma

P.O. Box 1326

Miami, OK 74355

Peter J. Karcz U.S. Department of Energy

1000 Independence Avenue, S.W. 

Washington, DC 20585

Theresa J. Kliczewski U.S. Department of Energy

1000 Independence Avenue, S.W. 

Washington, DC 20585

Andrew Knife Chief 

Executive Officer

Pawnee Nation of Oklahoma 

P.O. Box 470 

Pawnee, OK 74058

Douglas G. Lankford, 

Chief

Miami Tribe of Oklahoma 

P.O. Box 1326 

202 South Eight Tribes Trail 

Miami, OK 74355
Distribution List of Agencies, Organizations, and Persons

9-3 

Name and Title Affiliation and Address

Darla LaPointe

Tribal Chair 

Winnebago Tribe of Nebraska 

P.O. Box 687 

100 Bluff Street 

Winnebago, NE 68071

Terry Maglich Department of Economic Development 

301 West High Street #720 

Jefferson City, MO 65101

Vernon Miller

Chairman 

Omaha Tribe of Nebraska 

P.O. Box 368 

100 Main Street

Macy, NE 68039

Brian Treese

Mayor

701 East Broadway 

P.O. Box 6015 

Columbia, MO 65205

Karen Miller 

Commissioner

Boone County Government Center

801 East Walnut, Room 333 

Columbia, MO 65201

Misty M. Nuttle 

President 

Pawnee Nation of Oklahoma 

P.O. Box 470 881 

Little Dee Drive

Pawnee, OK 74058

Liana Onnen

Tribal Chairperson 

Prairie Band Potawatomi Nation 

16281 Q Road 

Mayetta, KS 66509

Kay Rhoads

Principal Chief 

Sac and Fox Nation

920883 South Highway 99, Building A 

Stroud, OK 74079

Dr. Toni Prawl

Deputy State Historic Preservation Officer

Missouri Department of Natural Resources

P.O. Box 176 

Jefferson City, MO 65102

Edward Siegmund 

Executive Director

Mid-Missouri Regional Planning Commission 

206 East Broadway 

P.O. Box 140 

Ashland MO 65010

Ron Sparkman

Chief 

Shawnee Tribe 

P.O. Box 189, 29 South Highway 69A 

Miami, OK 74354

Geoffrey Standingbear

Principal Chief

and 

John Fox, archaeologist

The Osage Nation 

627 Grandview 

P.O. Box 779 

Pawhuska, OK 74056

John R Shotton 

Chairman 

Otoe-Missouria Tribe of Indians Oklahoma 

8151 Highway 177 

Red Rock, OK 74651

Joshua Tapp

Deputy Director

U.S. Environmental Protection Agency

Region 7 

P.O. Box 1326

11201 Renner Boulevard 

Lenexa, KS 66219

George Tiger

Principal Chief 

The Muscogee (Creek) Nation 

P.O. Box 580 

1007 East Eufaula Street 

Okmulgee, OK 74447
Distribution List of Agencies, Organizations, and Persons

9-4 

Name and Title Affiliation and Address

Timothy Rhodd 

Chairman 

Iowa Tribe of Kansas and Nebraska

3345 B. Thrasher Road 

White Cloud, KS 66094

Leanne Tippet Mosby

Director

Division of Environmental Quality 

Missouri Department of Natural Resources

P.O. Box 176 

Jefferson City, MO 65102

Gayle Unruh

Manager

Missouri Department of Transportation 

P.O. Box 270 

Jefferson City, MO 65102

Greg Voss 

Manager

Radiological Emergency Preparedness Program 

Missouri Department of Public Safety 

2302 Militia Drive 

P.O. Box 116 

Jefferson City, MO 65101

Bobby Walkup

Chairman 

Iowa Tribe of Oklahoma 

Route 1, Box 721 

335588 East 750 Road 

Perkins, OK 74059

Glenna J. Wallace

Chief 

Eastern Shawnee Tribe of Oklahoma 

P.O. Box 350 

127 West Oneida 

Seneca, MO 64865

Larry Wright Jr

Chairman 

Ponca Tribe of Nebraska 

2521 Spruce Avenue 

P.O. Box 288 

Niobrara, NE 68760

Judith Youngbear-Bender

Chairwoman 

Sac and Fox Tribe of the Mississippi in Iowa 

349 Meskwaki Road 

Tama, IA 52339

Bob McDavid

former Mayor of City of Columbia

Private residence

Stacey Button, REDI No postal address provided. 

Joe Summerlin

NEPA Reviewer, Envr Services Div

U.S. Environmental Protection Agency

Region 7, P.O. Box 1326

11201 Renner Boulevard 

Lenexa, KS 66219

Will Brantley, Missouri Department of Health No postal address provided. 

Ryan T. Kinney, Kiewit Construction No postal address provided. 

Robert Schwartz, University of Missouri No postal address provided. 

Ryan Euliss, Boone Electric Coop No postal address provided. 

Chris Newbold

Natural History Biologist

Missouri Department of Conservation

3500 E. Gans Road

Columbia, MO 65201

Brittnie Brauner Missouri Department of Conservation

2901 West Truman Boulevard

P.O. Box 180

Jefferson City, MO 65102

Amy Salveter U.S. Fish and Wildlife Service

Columbia Ecological Services Field Office

101 Park Deville Drive, Suite A

Columbia, MO 65203
10-1 

10.0 INDEX

A

Accidents................................xvi, xx, 4-40, 

4-41, 4-44, 4-45, 4-85, 4-86, 4-91, 5-30, 

5-50, 5-51, 5-66, 5-80, 5-84, 5-86, 6-4, 

6-9, A-2, A-3 

Advisory Council on Historic 

Preservation (ACHP) .......xxiii, 1-7, 3-46, 

4-24, B-4, C-3, D-3 

agricultural land........................ 2-21, 3-37,

 3-39, 3-40, 4-2, 4-3, 4-5, 4-21, 4-26, 

4-70, 4-79, 5-39, 5-46, 5-56, 5-69, 5-82, 

6-1, 6-5, 6-10

alternatives................... iii, xx, xxi, 1-3, 5-1, 

5-2, 5-3, 5-7, 5-53, 5-55, 5-73, 5-74, 5-75, 

5-76, 5-77, 5-86, 5-87, 6-1, 6-4, 6-10, 

6-12, 8-2, A-1, A-4, A-5, B-2, D-2 

American Medical Isotopes Production

Act ..................... 1-3, 2-6, 5-79, 7-5, A-13

B

best management practice(s) 

(BMPs)............................. 4-6, 4-11, 4-13,

 4-14, 4-15, 4-16, 4-18, 4-20, 4-22, 4-23, 

4-73, 4-76, 5-16, 5-20, 5-22, 5-23, 5-24, 

5-41, 5-44, 5-59, 5-61, 5-62, 5-63, 5-72, 

5-74, 5-75, 5-77, 5-83, 6-2, 6-6, 6-7 

bird.................................... 3-45, 4-21, 4-22, 

4-23, 5-23, 5-24, 5-64, 5-77, 6-2, 6-7 

C

chemical ........................... 2-10, 2-11, 2-13, 

2-16, 2-18, 2-21, 3-4, 3-29, 3-59, 3-63, 

3-64, 4-17, 4-18, 4-20, 4-22, 4-23, 4-31, 

4-32, 4-34, 4-36, 4-38, 4-40, 4-41, 4-44, 

4-45, 4-46, 4-47, 4-48, 4-57, 4-61, 4-64, 

4-72, 4-83, 4-85, 4-86, 4-91, 5-21, 5-26, 

5-27, 5-30, 5-31, 5-49, 5-50, 5-51, 5-53, 

5-54, 5-55, 5-56, 5-57, 5-65, 5-66, 5-67, 

5-68, 5-78, 5-80, 5-84, 6-4, 6-8, 6-9, B-6 

City of Columbia ............................ xv, xvii, 

3-1, 3-2, 3-17, 3-31, 3-32, 3-35, 3-51, 

3-52, 3-53, 3-54, 3-55, 3-56, 3-57, 3-58, 

3-61, 3-65, 3-66, 4-11, 4-14, 4-15, 4-16, 

4-17, 4-18, 4-20, 4-27, 4-28, 4-29, 4-38, 

4-50, 4-51, 4-52, 4-67, 4-70, 4-71, 4-76, 

4-77, 4-81, 4-85, 4-90, 5-8, 5-16, 5-17, 

5-19, 5-20, 5-21, 5-25, 5-28, 5-31, 5-32, 

5-33, 5-34, 5-38, 5-39, 5-40, 5-43, 5-44, 

5-45, 5-47, 5-50, 5-59, 5-60, 5-65, 5-72, 

5-73, 5-74, 5-76, 5-82, 6-6, 6-7, 7-6, 7-7, 

7-8, 7-9, 9-2, 9-4, A-2, A-9, A-12, B-8, 

B-9, B-11, B-12, C-2 

Clean Air Act (CAA)....................xxiii, 3-12,

 3-13, 3-14, 3-15, 3-64, 4-30, 7-7, 7-9, 

7-10, B-3, B-10, B-13

Columbia, Missouri ...................iii, xv, xviii, 

1-1, 1-2, 1-4, 2-1, 2-7, 2-18, 2-20, 3-1, 

3-12, 3-34, 3-46, 3-66, 4-59, 4-63, 4-71, 

5-3, 5-7, 5-50, 5-65, 5-79, 5-87, 6-1, 6-4, 

7-5, 7-6, 7-16, 7-23, A-1, A-5, A-7, A-12

Council on Environmental Quality 

(CEQ) ................................. xxiii, 1-3, 1-6, 

4-1, 4-49, 5-1, 5-53, 5-81, 7-4, A-3 

critical habitat...... 3-43, 4-23, B-4, D-1, D-2 

D

demographic............ 3-49, 3-51, 4-50, 7-16

discharges ................................ 2-18, 3-27, 

3-29, 3-31, 3-32, 3-40, 4-15, 4-16, 4-17, 

4-35, 4-74, 4-75, 4-76, 4-77, 5-20, 5-42, 

5-43, 5-44, 5-61, 5-74, A-9 

dose ...........................................xxvii, 3-61, 

3-62, 3-63, 3-67, 3-68, 3-69, 3-70, 3-71, 

3-72, 3-73, 4-30, 4-31, 4-32, 4-33, 4-35, 

4-43, 4-54, 4-57, 4-60, 4-63, 4-81, 4-82, 

4-86, 5-26, 5-30, 5-36, 5-48, 5-51, 5-66, 

5-67, 5-78, 5-80, 5-84, 6-3, 6-8, A-3, A-8, 

B-2, B-3 

E

education.......... 2-19, 3-49, 7-15, 7-18, 8-1 

emissions ........................ 3-14, 3-15, 3-61, 

4-4, 4-5, 4-6, 4-7, 4-8, 4-9, 4-10, 4-34, 

4-35, 4-54, 4-55, 4-56, 4-57, 4-58, 4-59, 

4-60, 4-61, 4-62, 4-63, 4-69, 4-71, 4-72, 

4-79, 4-88, 5-10, 5-11, 5-12, 5-13, 5-36, 

5-40, 5-49, 5-52, 5-56, 5-57, 5-58, 5-67, 

5-68, 5-69, 5-70, 5-71, 5-72, 5-78, 5-81, 

5-82, 5-84, 6-2, 6-4, 6-6, 6-10, 7-9, A-3, 

A-4, A-6, B-3 
Index

10-2 

employment............................... 3-53, 3-54, 

4-27, 4-28, 4-29, 4-30, 4-81, 4-88, 4-90, 

5-5, 5-47, 5-52, 5-64, 5-78, 6-11, 7-1, 

A-11, A-12

endangered species.................... 1-7, 3-44, 

5-23, 7-11, B-1, D-7 

Endangered Species Act (ESA)..........xxiv, 

1-7, 3-42, 3-43, 3-45, 4-23, 7-3, 7-9, B-4, 

B-13, C-5, C-6, D-1, D-2, D-7 

Environmental Report (ER) ................... iii, 

xviii, xxi, xxiv, 1-1, 1-4, 2-5, 2-14, 3-1, 

3-20, 3-21, 3-22, 3-36, 3-43, 4-11, 4-13, 

4-32, 4-65, 5-2, 5-22, 6-5, 6-12, 7-21, 

7-22, 7-23, B-14

erosion................................ 3-5, 3-19, 3-33, 

4-6, 4-11, 4-13, 4-14, 4-18, 4-20, 4-22, 

4-73, 4-76, 5-16, 5-17, 5-20, 5-23, 5-24, 

5-41, 5-44, 5-58, 5-60, 5-61, 5-72, 5-73, 

5-74, 5-75, 5-83, 6-2, 6-6, 6-7, 6-11, B-8 

Essential fish habitat (EFH)....... 3-46, 4-24

F

farmland of statewide importance ....... 3-4 

fission.......................................xx, xxi, 1-2, 

2-10, 2-11, 2-14, 2-15, 5-1, 5-53, 5-54, 

5-55, 5-64, 5-67, 5-68, 5-69, 5-70, 5-71, 

5-72, 5-73, 5-74, 5-75, 5-76, 5-77, 5-78, 

5-79, 5-80, 5-81, 5-85, 5-87, 6-4, A-12

fugitive dust .........................4-5, 4-9, 4-11, 

4-19, 5-10, 5-11, 5-56, 5-69, 5-70, 6-6 

G

greenhouse gas .. xxiv, 3-15, 4-6, 5-11, A-3 

H

habitat................................. 3-4, 3-30, 3-37, 

3-38, 3-39, 3-40, 3-41, 3-43, 3-44, 3-45, 

3-46, 4-21, 4-22, 4-23, 4-24, 4-70, 4-75, 

4-79, 4-90, 5-18, 5-22, 5-23, 5-24, 5-39, 

5-43, 5-46, 5-64, 5-77, 6-2, 6-7, 6-10, 

7-18, B-5, D-1, D-2, D-3 

hazardous waste....................... 2-16, 2-17, 

2-18, 2-19, 2-20, 3-64, 4-37, 4-38, 4-85, 

5-4, 5-27, 5-65, 6-11, B-5, B-10, B-11

hot cell ......................................... 2-7, 2-11, 

2-14, 2-15, 2-17, 4-12, 4-31, 4-34, 4-44, 

5-54, 5-55, 5-68

I

iodine-131 ......... 1-3, 3-62, 4-32, 5-54, 5-68

irradiation .............................. 1-6, 2-6, 2-7, 

2-10, 2-11, 2-19, 3-66, 4-39, 4-55, 4-56, 

4-57, 4-58, 4-59, 4-60, 4-61, 4-62, 4-63, 

4-64, 5-2, 5-3, 5-4, 5-7, 5-29, 5-53, 5-54, 

5-68, 5-79

J

jobs .................................... 3-2, 4-28, 4-29, 

4-30, 4-57, 4-60, 4-70, 5-5, 5-82, 6-9, 

A-10, A-11

L

low-enriched uranium.........................xviii, 

1-3, 1-6, 2-6, 4-7, 5-7, A-12

low-level radioactive waste .............. 3-68, 

3-71, 4-36, 4-58, 4-61, 4-64, 4-84, 5-65, 

5-79, 6-9, 6-11

M

Magnuson–Stevens Fishery 

Conservation and Management Act 

(MSA).............................................. 3-46, 

4-24, 7-13, B-5, B-14, D-3, D-7 

mineral resources ...................... 3-49, 4-2, 

4-73, 5-9, 5-41

Missouri Department of 

Administration ................................ 3-51

Missouri Department of 

Conservation............................. 1-8, 3-4, 

3-40, 5-22, 6-10, 7-13, 7-14, 7-18, 7-20, 

9-1, 9-4, B-7, C-2 

Missouri Department of Natural 

Resources .......................... xxv, 1-8, 3-4,

4-11, 4-68, 5-18, 5-38, 7-7, 7-10, 7-14, 

7-15, 9-3, 9-4, A-2, A-4, B-6, C-2, C-3, 

C-6, D-3, D-6 

mitigation.................................. 4-13, 4-17, 

4-20, 4-42, 4-72, 5-26, 5-40, 6-5, 6-9, 

6-10, 7-16, 7-20

mixed waste.............................. 2-16, 4-37, 

4-84, 6-9, B-11

molybdenum-99 (Mo-99) ............... xix, 1-1, 

1-2, 1-3, 1-6, 2-6, 2-7, 2-10, 2-11, 2-12, 

2-15, 2-16, 2-19, 2-20, 4-1, 4-7, 4-31, 

4-33, 4-43, 4-55, 5-2, 5-4, 5-52, 5-53, 

5-54, 5-55, 5-65, 5-66, 5-67, 5-68, 5-78, 

5-82, 5-85, 7-11, 7-12, 7-22, 7-26, A-9, 

A-12
Index

10-3 

N

National Environmental Policy Act 

(NEPA)................................xviii, xix, xxvi, 

1-1, 1-6, 4-26, 4-49, 5-1, 5-7, 5-53, 5-81, 

6-1, 6-5, 6-12, 7-4, 7-17, 8-1, 8-2, 9-4, 

A-9, A-13, B-2, B-4, B-14, D-1, D-3, D-7 

National Marine Fisheries Service 

(NMFS).................................... 3-42, 3-43, 

3-46, 4-23, 4-24, 7-18, B-4, B-5, D-1, D-2, 

D-3, D-7 

National Nuclear Security Administration 

(NNSA)................................xxvi, 1-3, 2-6,

5-53, 5-55, 5-86, 7-11, 7-18

National Pollutant Discharge Elimination 

System (NPDES).....................xxvi, 3-30, 

3-31, 3-32, 4-15, 4-16, 4-17, 4-18, 4-20, 

4-75, 4-76, 4-77, 5-18, 5-20, 5-21, 5-22, 

5-43, 5-44, 5-45, 5-61, 5-63, 5-74, 5-77, 

7-2, 7-10, B-1, B-6, B-13

National Register of Historic Places 

(NRHP).....................................xxvi, 3-50, 

3-66, 3-70, 4-24, 4-26, 5-24, 5-25, 7-21, 

B-4, D-3 

no-action alternative.........................iii, xx, 

5-1, 5-2, 5-85, 5-87, 6-4, A-4, A-5 

nonattainment ............................ 3-13, 3-14

O

Occupational Safety and Health 

Administration (OSHA).................... xxvi, 

3-17, 3-64, 4-30, 4-31, 4-34, 4-36, 4-83, 

5-49, 5-64, 5-78, 5-83, 6-3, 6-8, 7-22, B-4 

P

personal protective equipment ......... 2-15, 

2-17, 4-31, 6-8 

population ................................... 3-2, 3-47, 

3-48, 3-51, 3-52, 3-53, 3-57, 3-58, 4-29, 

4-33, 4-46, 4-49, 4-50, 4-51, 4-52, 4-53, 

4-59, 4-62, 4-71, 4-72, 4-77, 4-78, 4-79, 

4-81, 4-85, 4-87, 4-89, 4-90, 5-30, 5-31, 

5-33, 5-34, 5-35, 5-40, 5-41, 5-44, 5-45, 

5-47, 5-51, 7-16, 7-17, B-3, B-8 

population centers................................ 3-2 

prime farmland...................... 3-1, 3-4, 3-5, 

3-25, 4-73, 5-8, 5-15, 5-41, A-5, B-4 

production facility...........................iii, xviii, 

xix, xxvi, 1-1, 1-2, 1-6, 2-1, 3-62, 4-1, 5-1, 

5-2, 5-3, 5-4, 5-5, 5-7, 6-1, A-1, A-8, A-9, 

A-11, A-12, B-1, C-1, D-1 

public health............................... 2-6, 2-19, 

3-12, 3-62, 5-65, 5-78, 5-87, 6-10, A-8, 

B-1, B-3, B-4, B-9 

public services ......................... 4-27, 4-81,

4-90, 5-47, 5-64, 5-81, A-12

R

radioactive waste ....................... 2-6, 2-11, 

2-15, 2-16, 2-17, 2-19, 2-21, 3-61, 3-68, 

3-71, 4-30, 4-31, 4-32, 4-35, 4-36, 4-37, 

4-57, 4-61, 4-64, 4-84, 5-27, 5-50, 5-55, 

5-65, 5-79, 6-9, 8-2 

radioisotope.................................... iii, xviii, 

xix, xxvi, 1-1, 1-2, 1-3, 1-6, 2-1, 2-6, 2-9, 

2-19, 2-20, 3-62, 4-1, 4-7, 5-1, 5-2, 5-52, 

5-54, 5-55, 5-68, 5-76, 5-82, 5-85, 6-1, 

A-1, A-8, A-9, A-10, A-11, B-1, C-1, D-1 

runoff ........................................ 3-24, 3-27, 

3-28, 3-31, 3-43, 4-11, 4-14, 4-15, 4-16, 

4-17, 4-18, 4-20, 4-22, 4-23, 4-69, 4-74, 

4-75, 4-76, 4-77, 4-78, 4-79, 4-90, 5-16, 

5-18, 5-21, 5-23, 5-24, 5-42, 5-43, 5-45, 

5-46, 5-60, 5-61, 5-62, 5-64, 5-74, 5-76, 

5-77, 6-7, A-9, B-6, B-10

S

safety evaluation report (SER) .......... xxvi, 

4-34, 4-40, 4-44, 4-48, 4-65, 5-16, 5-30, 

5-31, 5-49, 5-51, 5-67, 5-80, 5-84, 6-4, 

A-8 

schools ................................ 3-59, A-8, B-8 

scoping .................................. xviii, xxi, 1-4, 

3-1, 4-26, 4-65, 6-12, A-1, A-2, A-4, A-13

shielding ................................... 2-20, 4-10, 

4-22, 4-31, 4-32, 4-44, 4-57, 4-60, 4-63, 

6-7, 6-8 

soil...................................... 2-12, 2-13, 3-5, 

3-18, 3-20, 3-21, 3-24, 3-25, 3-26, 3-34, 

3-37, 3-61, 3-62, 3-70, 4-7, 4-11, 4-13, 

4-14, 4-18, 4-19, 4-20, 4-22, 4-73, 4-76, 

4-79, 4-82, 4-89, 5-16, 5-17, 5-20, 5-22, 

5-23, 5-24, 5-41, 5-43, 5-44, 5-46, 5-55, 

5-58, 5-59, 5-60, 5-61, 5-63, 5-72, 5-73, 

5-74, 5-75, 5-77, 5-83, 6-2, 6-6, 6-7, 7-20, 

7-21

solid waste................................ 2-16, 2-17, 

2-18, 2-19, 2-20, 3-68, 4-35, 4-36, 4-37, 

4-38, 4-85, 5-65, B-1, B-7 
Index

10-4 

State Historic Preservation Office 

(SHPO).....................................xxvi, 3-46, 

3-50, 4-24, 6-7, 7-15, 9-3, A-4, A-5, A-7, 

C-3, C-6, D-3, D-6 

stormwater ................................ 3-27, 3-31, 

4-11, 4-12, 4-14, 4-15, 4-16, 4-18, 4-20, 

4-22, 4-23, 4-74, 4-76, 4-77, 4-79, 5-16, 

5-17, 5-20, 5-21, 5-22, 5-23, 5-24, 5-42, 

5-43, 5-44, 5-45, 5-46, 5-59, 5-60, 5-61, 

5-62, 5-63, 5-72, 5-74, 5-76, 5-77, 5-83, 

6-2, 6-6, 6-7, 7-6, 7-13, 7-15, A-9, B-6, 

B-8, B-9, B-10

T

tax ..................................... 3-56, 3-57, 4-27,

4-28, 4-29, 4-81, 4-90, 5-5, 5-6, 5-7, 5-47, 

5-81, 5-82, 6-11, A-10, A-11, A-12

technetium-99m .................................... 1-1 

traffic...................................xxvii, 3-2, 3-17, 

3-64, 3-65, 3-67, 3-70, 3-72, 4-7, 4-8, 4-9, 

4-10, 4-11, 4-13, 4-38, 4-39, 4-40, 4-53, 

4-54, 4-55, 4-56, 4-58, 4-59, 4-61, 4-64, 

4-71, 4-73, 4-87, 4-88, 4-89, 4-91, 5-11, 

5-12, 5-13, 5-28, 5-29, 5-30, 5-35, 5-36, 

5-40, 5-50, 5-51, 5-52, 5-57, 5-58, 5-66, 

5-67, 5-71, 5-72, 5-79, 5-80, 5-81, 5-84, 

6-3, 6-4, 6-6, 6-9, 6-11, 7-16, A-12

tritium .......2-15, 3-62, 3-67, 4-32, 5-68, 6-8 

U

U.S. Department of Energy (DOE)......xxiii, 

1-8, 2-6, 2-7, 2-9, 2-20, 3-68, 4-46, 5-3, 

5-53, 5-54, 5-55, 5-56, 5-57, 5-58, 5-59, 

5-62, 5-63, 5-65, 5-66, 5-79, 7-5, 7-8, 9-2, 

C-2 

U.S. Department of Transportation 

(DOT) .........................................xxiv, 2-6, 

2-11, 2-19, 2-20, 2-21, 4-33, 4-37, 5-65, 

5-78, 5-84, 6-3, 6-8, A-3, B-7, B-10

U.S. Environmental Protection Agency 

(EPA) .......................................xxiv, 3-12, 

3-13, 3-14, 3-15, 3-16, 3-29, 3-31, 3-32, 

3-59, 3-61, 3-63, 3-64, 4-6, 4-8, 4-38, 

4-46, 4-47, 4-59, 4-62, 4-68, 4-69, 4-71, 

4-72, 4-75, 4-83, 4-86, 5-11, 5-43, 5-49, 

5-51, 5-64, 5-78, 7-2, 7-9, 7-10, 7-14, 9-3, 

9-4, A-2, A-4, A-5, B-1, B-3, B-5, B-6, B-9, 

B-13, C-2, C-6 

U.S. Fish and Wildlife Service 

(FWS).... xxiv, 1-8, 3-42, 3-43, 3-45, 3-46, 

4-23, 5-22, 5-23, 6-10, 7-4, 7-11, 7-20, 

9-5, A-6, B-4, B-5, C-5, D-1, D-2, D-7 

U.S. Highway 63 ......................... 3-2, 3-17,

3-27, 3-29, 3-40, 3-65, 3-66, 3-70, 4-9, 

4-10, 4-11, 4-39, 4-40, 4-54, 4-55, 4-70, 

4-80, 4-87, 5-28, 5-57, 5-58, 5-66, 5-67, 

5-71, 5-72, 5-80, 5-81, 5-84, 6-3, A-11

uranium........................................ xxiv, xxv, 

1-2, 1-3, 2-6, 2-7, 2-9, 2-10, 2-11, 2-15, 

2-16, 2-19, 2-20, 3-61, 3-63, 3-66, 3-70, 

4-1, 4-7, 4-41, 5-1, 5-53, 5-54, 5-55, 5-67, 

5-68, 5-79, 5-82, 5-86, 6-11, A-4, A-5 

utilization facility ................................ 2-21

V

viewshed.............................. 3-5, 3-11, 4-4, 

4-5, 4-70, 4-71, 5-9, 5-10, 5-39, 5-82, 6-1 

W

wastewater................................ 2-14, 2-18, 

3-31, 3-32, 4-15, 4-16, 4-17, 4-20, 4-22, 

4-23, 4-34, 4-68, 4-76, 4-77, 4-85, 5-21, 

5-24, 5-39, 5-44, 5-45, 5-63, 5-76, 8-2, 

B-9, B-12

wildlife....................................... 3-29, 3-30, 

3-37, 3-38, 3-39, 3-41, 3-43, 4-21, 4-22, 

4-23, 4-53, 4-70, 4-75, 4-79, 5-18, 5-22, 

5-23, 5-24, 5-35, 5-39, 5-43, 5-46, 5-64, 

5-77, 6-7, 6-10, 7-3, B-5, B-6, B-7 

workers ................................ 2-4, 2-6, 2-15, 

2-21, 3-17, 3-51, 3-53, 3-54, 3-59, 3-63, 

3-66, 3-68, 4-7, 4-9, 4-27, 4-28, 4-29, 

4-30, 4-31, 4-33, 4-34, 4-35, 4-36, 4-37, 

4-38, 4-39, 4-40, 4-43, 4-44, 4-45, 4-48, 

4-53, 4-55, 4-56, 4-57, 4-58, 4-60, 4-61, 

4-62, 4-63, 4-64, 4-81, 4-83, 4-84, 4-88, 

5-11, 5-12, 5-25, 5-26, 5-27, 5-28, 5-29, 

5-30, 5-35, 5-48, 5-49, 5-52, 5-55, 5-64, 

5-65, 5-66, 5-68, 5-78, 5-79, 6-3, 6-8, 

A-10, B-1, B-2 
COMMENTS RECEIVED ON THE NORTHWEST MEDICAL ISOTOPES, 

LLC, RADIOISOTOPE PRODUCTION FACILITY ENVIRONMENTAL 

REVIEW 

A-1 

1 A. COMMENTS RECEIVED ON THE NORTHWEST MEDICAL 

2 ISOTOPES, LLC, RADIOISOTOPE PRODUCTION FACILITY 

3 ENVIRONMENTAL REVIEW

4 A.1 Comments Received During the Scoping Period

5 The scoping process for the environmental review of the construction permit application for the 

6 Northwest Medical Isotopes, LLC (NWMI), radioisotope production facility (NWMI facility) began 

7 on November 18, 2015, with the publication of the U.S. Nuclear Regulatory Commission’s 

8 (NRC’s) Notice of Intent to conduct scoping in the Federal Register (80 FR 72115). The 

9 scoping process included a public meeting held in Columbia, Missouri, on December 8, 2015. 

10 Approximately 43 people attended the meeting. After the NRC presented its prepared 

11 statements on the construction permit review process, the meeting was open for public 

12 comments. Attendees provided oral statements that were recorded and transcribed by a 

13 certified court reporter. A summary and transcript of the scoping meeting are available through 

14 the NRC’s Agencywide Documents Access and Management System (ADAMS). The ADAMS 

15 Public Electronic Reading Room is accessible at http://www.nrc.gov/reading-rm/adams.html. 

16 The scoping meeting summary and meeting transcript (NRC 2016a) can be found at ADAMS 

17 No. ML15356A096. In addition to comments that the NRC received during the public meeting, 

18 the agency also received comments electronically and through the mail.

19 Each commenter was given a unique identifier to allow every comment to be traced back to its 

20 author. Table A–1 identifies the individuals who provided comments and an ADAMS No. to 

21 identify the source document of the comments.

22 Specific comments were categorized and consolidated by topic. Comments with similar specific 

23 objectives were combined to capture the common essential issues raised by commenters. 

24 Comments have been grouped into the following general categories:

25 • Specific comments that address environmental issues within the purview of the NRC

26 environmental regulations related to a construction permit. These comments

27 address issues related to the construction, operations, and decommissioning of the

28 NWMI facility. The comments also address alternatives to the proposed action and

29 related Federal actions.

30 • General comments in support of, or opposed to, the NWMI facility or comments

31 regarding the construction permit process, the NRC’s regulations, and the regulatory

32 process.

33 • Comments that address issues that do not fall within, or are specifically excluded

34 from, the purview of NRC environmental regulations related to the construction

35 permit process. These comments may address issues, such as emergency

36 preparedness, security, and safety.
Appendix A

A-2 

1 Table A–1. Individuals Providing Comments During the Scoping Comment Period

2 Each commenter is identified, along with an affiliation, if any, and the source of the comment.

Commenter Affiliation (if stated) ID Comment Source ADAMS No.

Lisa C. Baker United Keetoowah Band of 

Cherokee Indians in 

Oklahoma

01 E-mail ML16049A297

Everett Bandy Quapaw Tribe of Oklahoma 02 Letter ML16020A339

Dan Brague Mallinckrodt

Pharmaceuticals

03 Transcript ML15356A133

Jerry Dowell Columbia Chamber of 

Commerce

04 Transcript ML15356A133

David Griggs Regional Economic 

Development

05 Transcript ML15356A133

Diane Hunter Miami Tribe of Oklahoma 06 E-mail ML16056A421

Andrew Knife Chief Pawnee Nation of Oklahoma 07 Letter ML16020A338

Terry Maglich Missouri Department of 

Economic Development

08 Transcript ML15356A133

Bob McDavid Mayor, City of Columbia 09 Transcript ML15356A133

Karen Miller Boone County Commission, 

Commissioner

10 Transcript ML15356A133

Toni M. Prawl Missouri Department of 

Natural Resources

11 Letter ML16020A340

Joshua Tapp U.S. Environmental 

Protection Agency

12 Letter ML16007A004

3 Comments that are outside the scope of the NWMI facility environmental review are not 

4 included here but appear in and are responded to in the Scoping Summary Report (ADAMS 

5 No. ML16056A628). To maintain consistency with the Scoping Summary Report, Appendix A 

6 retains the unique identifiers used in that report for each comment. 

7 The NRC staff placed comments received during the scoping comment period applicable to this 

8 environmental review into categories based on topics in the environmental impact statement 

9 (EIS). These categories are listed in Table A–2. 

10 Table A–2. Issue Categories

Technical Issues

Accidents

Air Quality

Alternatives

Coordination

Cost-Benefit Comparison

Cumulative Impacts

Ecological Resources

Environmental Justice
Appendix A

A-3 

Technical Issues

Historic and Cultural Resources

Human Health

Land Use 

Purpose and Need

Water Resources

Support for the NWMI Facility 

1 The following pages contain the comments, identified by the commenter’s identification and 

2 comment number, and the NRC staff’s response. Comments are presented in the same order 

3 as listed in Table A–2. 

4 A.1.2 Accidents

5 Comments:

6 12-03: The increased likelihood of a transportation accident involving molybdenum- 99 [...] can 

7 increase the risk of harm to sensitive populations.

8 Response: 

9 This comment recommends that the NRC consider the increased likelihood of transportation 

10 accidents. Section 4.8.2.1 of the EIS discusses the impacts to the public from highway 

11 transportation of radioactive material associated with the proposed NWMI facility. As discussed 

12 in Section 4.8.2.1, when transporting radioactive material, both NWMI and commercial carriers 

13 used by NWMI must comply with applicable U.S. Department of Transportation (DOT)

14 regulations and NRC packaging requirements for radioactive material in 10 CFR Part 71. The 

15 annual dose to a maximally exposed individual from highway transportation of radioactive 

16 material associated with the proposed NWMI facility is small relative to the NRC’s 100 mrem 

17 annual public dose limit in 10 CFR 20.1301. The NRC’s public dose limit is set at a level that 

18 helps to ensure that any risk to members of the public, including sensitive populations, from 

19 radiation exposure that occurs due to the operation of a nuclear facility is no greater than the 

20 risk from any other hazard to which individuals are routinely exposed (ICRP 1987; 

21 56 FR 23360). In addition, as noted in Section 4.8.2.1, the Commission has determined that the 

22 radiological and nonradiological environmental impacts of normal (incident-free) transportation 

23 of radioactive materials done in accordance with NRC and DOT regulations, and the risks and 

24 consequences of accidents involving radioactive material shipments in packages for which the 

25 NRC has issued design approvals meeting the performance standards of 10 CFR Part 71, are 

26 small (49 FR 9375).

27 A.1.3 Air Quality

28 Comment:

29 12-20: The document should also consider greenhouse gas emissions and how the preferred 

30 alternative might improve or degrade air quality based on the construction of the facility and how 

31 this facility could improve transportation GHG emissions based on reduction of imports from 

32 Canada or overseas. Information on how to comply with the President and CEQ can be found 

33 here: https://www.whitehouse.gov/administration/eop/ceq/initiatives/nepa/ghgguidance.

34 Response:

35 This comment recommends that the EIS assess the greenhouse gas emission (GHG) and air 

36 quality impacts of the proposed NWMI facility. Section 4.2 of the EIS addresses the impacts on 
Appendix A

A-4

1 air quality that results from construction, operations, and decommissioning of the proposed 

2 NWMI facility. Section 4.2 quantifies annual GHG emissions resulting from construction, 

3 operations, and decommissioning of the proposed NWMI facility at the Discovery Ridge site. 

4 Section 5.4.1 of the EIS compares the environmental impacts of the proposed NWMI facility with 

5 the environmental impacts associated with using an alternative site or alternative technologies.

6 A.1.4 Alternatives

7 Comments:

8 12-01: Although the proposed action is only the licensing of a new low enriched uranium

9 Medical Isotope [facility], EPA strongly encourages NRC to consider all the significant 

10 environmental impacts that would be caused by licensing this facility, both the beneficial and 

11 harmful, to human health and the environment. For example, alternatives one might consider 

12 are: 1) no-action, 2) licensing of this facility, or 3) denial of this facility to license with approval 

13 for licensing a different facility at another location.

14 Response:

15 This comment suggests that the NRC consider all the significant environmental impacts as a 

16 result of the no-action alternative (e.g., denial of the construction permit application), the 

17 proposed action, and an alternative site and facility. Chapter 4 of the EIS evaluates the 

18 potential environmental impacts from the proposed action. Chapter 5 of the EIS evaluates the 

19 potential impacts from the no-action alternative, an alternative site, and two alternative 

20 technologies. Section 5.4.1 of the EIS compares the environmental impacts of the proposed 

21 NWMI facility with those that would be associated with using an alternative site or alternative 

22 technologies. Specifically, Table 5–12 provides a tabular comparison of the potential 

23 environmental impacts of constructing, operating, and decommissioning the proposed NWMI 

24 facility at the Discovery Ridge site with the alternative site and the no-action alternative. 

25 Table 5–13 provides a tabular comparison of the potential environmental impacts of 

26 constructing, operating, and decommissioning the proposed NWMI facility at the Discovery 

27 Ridge site with the potential environmental impacts of using alternative technologies.

28 A.1.5 Coordination

29 Comment:

30 12-12: Has coordination between Missouri Department of Natural Resources and NRC 

31 occurred?

32 Response:

33 This comment asks whether coordination has occurred between the NRC and the Missouri 

34 Department of Natural Resources. In a letter dated November 19, 2015, the NRC invited the 

35 Missouri Department of Natural Resources’ (MDNR) Division of Environmental Quality, Chief of 

36 Policy, and State Historic Preservation Office to participate in the scoping process for the 

37 environmental review related to the proposed NWMI facility (NRC 2015b). On 

38 December 9, 2015, MDNR’s State Historic Preservation Officer responded to the NRC (see 

39 response to Comment 12-15 below). However, MDNR’s Division of Environmental Quality and 

40 Chief of Policy did not submit comments to the NRC during the scoping period. Section 1.7 of 

41 the EIS identifies agencies contacted during the formal consultation processes and Appendix D 

42 discusses agencies with which the NRC consulted. The MDNR will be on distribution for the 

43 NRC’s draft EIS and will be invited to the NRC’s public meeting discussing the draft EIS.

44 Comment:

45 12-14: Will there need to be coordination for farmland conversion?
Appendix A

A-5

1 Response:

2 This comment asks whether the NRC will need to coordinate with the U.S. Department of 

3 Agricultural regarding the conversion of prime farmland to nonagricultural uses. As discussed in 

4 Section 3.1.1.1 of the EIS, the proposed site (Discovery Ridge) and alternative site (University 

5 of Missouri Research Reactor) do not contain prime farmland or other important farmland soils 

6 as defined in the Farmland Protection Policy Act of 1981 (7 U.S.C. 4201 et seq.) and 

7 implementing regulations (7 CFR Parts 657 and 658). Given that the Discovery Ridge site is 

8 already committed to use as a research, development, and office park, the site is not subject to 

9 the Farmland Protection Policy Act (7 CFR 658.2). Section 3.1.1 of the EIS describes land use

10 on and around the proposed site in Columbia, Missouri, and Section 4.1.1 addresses the 

11 impacts to land use from construction, operations, and decommissioning of the proposed NWMI 

12 facility. Section 5.2.2.1 of the EIS describes land use on and around the alternative site in 

13 Columbia, Missouri and the impacts to land use from construction, operations, and 

14 decommissioning of the proposed NWMI facility.

15 12-15: Has coordination occurred with the Missouri State Historic Preservation Officer?

16 Response:

17 This comment asks whether coordination has occurred between the NRC and the Missouri 

18 State Historic Preservation Officer (SHPO). Section 4.6.3 of the EIS explains that the NRC 

19 initiated NHPA Section 106 consultation with the Missouri SHPO on November 19, 2015. A 

20 Cultural Resource Assessment, Section 106 Review, was conducted by the SHPO for the 

21 proposed Northwest Medical Isotopes, LLC Radioisotope Production Facility, in Columbia, 

22 Missouri (Lot 15 at Discovery Ridge). The assessment signed by Toni M. Prawl, Ph.D., Deputy 

23 State Historic Preservation Officer, on December 9, 2015, states that, “Adequate documentation 

24 has been provided (26 CFR Section 800.11). There will be ‘no historic properties affected’ by 

25 the current project.” The assessment also states, the Missouri SHPO has “no objection to the 

26 initiation of project activities.” The Missouri SHPO will be on distribution for the NRC’s draft EIS 

27 and will be invited to the NRC’s public meeting discussing the draft EIS.

28 A.1.6 Cost Benefit Analysis

29 Comment:

30 12-02: Although the proposed action is only the licensing of a new low enriched uranium

31 Medical Isotope [facility], EPA strongly encourages NRC to consider all the significant 

32 environmental impacts that would be caused by licensing this facility, both the beneficial and 

33 harmful, to human health and the environment. [...] The direct effects of such facilities can be 

34 both beneficial and harmful and we encourage NRC to expand the discussion in this area.

35 Comment:

36 12-05: In contrast, if such medical supplies have a pronounced effect on human health and are

37 in short supply or are not otherwise readily available, then such considerations should also be 

38 taken into account. EPA recommends objectively analyzing both positive and negative aspects 

39 so that the decision maker can easily choose the preferred alternative.

40 Response:

41 The above comments suggest that the NRC staff consider the costs and benefits of the 

42 proposed action and alternatives. Section 5.4 of the EIS evaluates the costs and benefits for 

43 the proposed action and compares the environmental impacts of the proposed action, no-action 

44 alternative, alternative sites, and two alternative technologies. Specifically, Table 5–12 provides 

45 a tabular comparison of the potential environmental impacts of constructing, operating, and 
Appendix A

A-6

1 decommissioning the proposed NWMI facility at the Discovery Ridge site with the alternative 

2 site and the no-action alternative. Table 5–13 provides a tabular comparison of the potential 

3 environmental impacts of constructing, operating, and decommissioning the proposed NWMI 

4 facility at the Discovery Ridge site with the potential environmental impacts of using alternative 

5 technologies.

6 A.1.7 Cumulative Impacts

7 Comment:

8 12-06: Cumulative impact discussions may also include transport of hazardous materials, 

9 storage of materials, national health benefits, induced development due to job creation, and 

10 reduction of GHGs due to proximity of the new facility.

11 Response:

12 The comment recommends that the EIS include a cumulative impact discussion that considers 

13 transportation, waste management, human health, socioeconomics, and GHG emissions. 

14 Section 4.14 of the EIS considers the potential cumulative impacts of the construction, 

15 operations, and decommissioning of the proposed NWMI facility when overlaid or added to 

16 temporary or permanent effects associated with other past, present, and reasonably 

17 foreseeable actions on the affected resource areas. Table 4–12 of the EIS summarizes the 

18 cumulative impacts for all resource areas. The cumulative impacts for (1) socioeconomics are 

19 SMALL; (2) air quality are SMALL to MODERATE; and (3) waste management are SMALL.

20 A.1.8 Ecological Resources

21 Comment:

22 12-07: When developing Threatened and Endangered species, one might consider not only 

23 animal species, but also plant species if construction will occur on undisturbed land.

24 Response:

25 This comment recommends that the NRC consider the potential impacts to threatened and 

26 endangered animal and plant species from construction of the proposed NWMI facility. 

27 Section 3.5.4 of the EIS describes the Federally listed species (both plants and animals) that 

28 have the potential to exist within the action area. As discussed in Section 3.5.4, the NRC staff 

29 concludes that Federally listed, proposed, or candidate species are unlikely to occur within the 

30 action area. In Section 4.5.4 of the EIS, the NRC staff concludes that there would be no effect 

31 on Federally listed species or habitats under FWS’s jurisdiction.

32 A.1.9 Environmental Justice

33 Comments:

34 12-11: Would EJ communities be disproportionately affected by the proposed locations?

35 Response:

36 The comment asks whether the proposed action would disproportionately affect Environmental 

37 Justice (EJ) communities. In the EIS, the NRC staff concludes that it is not likely that the 

38 construction, operations, and decommissioning of the proposed NWMI facility would have 

39 disproportionately high and adverse human health and environmental effects on minority and 

40 low-income populations if located at the Discovery Ridge site (Section 4.12) or at the University 

41 of Missouri Research Reactor location (Section 5.2.2.12).

42 A.1.10 Historical and Cultural Resources
Appendix A

A-7

1 Comments:

2 06-01: In reference to the above-mentioned project, the Miami Tribe is not currently aware of 

3 existing documentation directly linking a specific Miami cultural or historic site to the project site. 

4 However, as this site is within the extended homelands of the Miami Tribe, should any human 

5 remains or Native American cultural items falling under the Native American Graves Protection 

6 and Repatriation Act (NAGPRA) or archaeological evidence be discovered during any phase of 

7 this project, the Miami Tribe requests immediate consultation with the entity of jurisdiction for the 

8 location of discovery. The Miami Tribe offers no objection to the proposed project at this time. 

9 However, should human remains and/or cultural objects be discovered, regardless of initial 

10 determination as to site dating or cultural affiliation, please contact me [...] to initiate 

11 consultation.

12 01-01: Thank you for contacting us as a potential consulting party on this project. The UKB 

13 [United Keetoowah Band] defers consultation on this project to federally recognized tribes with 

14 more of a historic interest in this site.

15 02-01: This project is outside of the current area of interest for the Quapaw Tribe [of 

16 Oklahoma], therefore, the Quapaw Tribe does not desire to comment on this project at this time.

17 07-01: The Pawnee Nation Office of Historic Preservation has received the information and 

18 materials requested for our Section 106 Review and Consultation. Consultation with the 

19 Pawnee Nation is required by Section 106 of the National Historic Preservation Act of 1966 

20 (NHPA), and 36 CFR Part 800. Given the information provided, you are hereby notified that the 

21 proposal project location should have no potential to adversely affect any known Archaeological, 

22 Historical, or Sacred Pawnee sites. Therefore, in accordance with 36 CFR 800.4(d)(1), you may 

23 proceed with the proposed project. However, please be advised that undiscovered properties 

24 may be encountered and must be immediately reported to us under both the NHPA and 

25 NAGPRA regulations.

26 11-01: The [Missouri] State Historic Preservation Office has reviewed the information submitted 

27 on the above referenced project. Based on this review, we have made the following 

28 determination: Adequate documentation has been provided (36 CFR Section 800.11). There 

29 will be "no historic properties affected" by the current project. For the above checked reason, 

30 the State Historic Preservation Office has no objection to the initiation of project activities. 

31 PLEASE BE ADVISED THAT, IF THE CURRENT PROJECT AREA OR SCOPE OF WORK 

32 ARE CHANGED, A BORROW AREA IS INCLUDED IN THE PROJECT, OR CULTURAL 

33 MATERIALS ARE ENCOUNTERED DURING CONSTRUCTION, APPROPRIATE 

34 INFORMATION MUST BE PROVIDED TO THIS OFFICE FOR FURTHER REVIEW AND 

35 COMMENT. Please retain this documentation as evidence of compliance with Section 106 of 

36 the National Historic Preservation Act, as amended.

37 Response:

38 The above commenters generally indicate there are no known cultural or historic resources that 

39 could be affected by the proposed action, but express concerns that they be contacted 

40 consistent with the Section 106 process if such resources are identified in the future. 

41 Section 3.6 of the EIS describes the archaeological history of Columbia, Missouri, and Boone 

42 County and identifies historic and cultural resources that could potentially be found in the vicinity 

43 of the proposed NWMI facility at the Discovery Ridge Research Park. Section 4.6 of the EIS 

44 concludes that construction, operations and decommissioning of the proposed NWMI facility 

45 would not impact any known historic and cultural resources at the Discovery Ridge Research 

46 Park site.

47 A.1.11 Human Health
Appendix A

A-8

1 Comments:

2 12-09: What is the safe distance to the nearest residence?

3 Response:

4 The above comment recommends that the NRC consider impacts to an offsite member of the 

5 public. Section 3.8.1 identifies the location of the nearest residence, as well as the locations of 

6 sensitive receptors (schools, medical facilities, parks, recreational areas, religious institutions, 

7 and retirement communities within the 5-mi (8-km) region of influence) relative to the proposed 

8 Discovery Ridge site. The nearest residence is located 0.27 mi (435 m) from the proposed 

9 Discovery Ridge site. Section 4.8 addresses the human health impacts to members of the 

10 public from construction, operations, and decommissioning of the proposed NWMI facility. 

11 Section 4.11 addresses the impacts to members of the public, including individuals located at 

12 the nearest residence, from potential accidents at the proposed NWMI facility. In Sections 4.8 

13 and 4.11, the NRC staff concluded that if the proposed facility is constructed, operated, and 

14 decommissioned in compliance with all applicable regulations, then the impacts to offsite 

15 members of the public (including those at the nearest residence) from both routine operation of 

16 the proposed facility and potential accidents at the proposed facility would be small. 

17 Comment:

18 12-18: Will the facility be required to conduct an annual environmental and public health

19 radiation dose assessment similar to commercial nuclear reactors?

20 Response:

21 The comment recommends that the EIS consider annual environmental monitoring 

22 requirements and public dose assessment for the proposed facility. Section 3.8.2 of the EIS 

23 discusses NRC’s radiation protection dose limits contained in 10 CFR Part 20. If licensed to 

24 operate, the licensee for the radioisotope production facility would need to perform 

25 environmental and public radiation dose assessments to show compliance with the annual 

26 radiation dose limits for individual members of the public. The NRC regulations at 

27 10 CFR 20.1301 specify an annual maximum allowable dose of 100 mrem to a member of the 

28 public from exposure to radiation and radioactive material at a licensed facility. In addition, 

29 10 CFR 20.1302 requires licensees to make or cause to be made, as appropriate, surveys of 

30 radiation levels in unrestricted and controlled areas (both within and outside the site boundary), 

31 and to measure annual average concentrations of radionuclides in effluent releases from the 

32 facility, as needed to demonstrate compliance with the annual dose limits for individual 

33 members of the public. The NRC regulations at 10 CFR 20.2203 require licensees to submit 

34 reports of incidents and occurrences involving radiation exposures to members of the public that 

35 exceed regulatory limits. Section 4.8.2.1 of the EIS discusses the applicant’s proposed 

36 radiological effluent and environmental monitoring programs. The applicant’s proposed 

37 radiological effluent and environmental monitoring programs will be evaluated in a separate 

38 safety evaluation report related to the construction permit application based on the information 

39 in the NWMI preliminary safety analysis report.

40 A.1.12 Purpose and Need

41 Comment:

42 12-08: In reviewing the background on these type of facilities, it appears that ten letters of 

43 intent have been made recently, with one construction application already submitted in 

44 Wisconsin. If the facility in Wisconsin were to be built, would this facility and the others be 

45 necessary and viable?
Appendix A

A-9

1 Response:

2 This comment recommends that the environmental review consider whether construction of the 

3 proposed NWMI facility is necessary if another radioisotope production facility is constructed. 

4 Section 1.3 of the EIS describes the purpose and need for the proposed action. The purpose of 

5 the NRC’s Federal action is to evaluate NWMI’s proposal to construct a facility that would 

6 ultimately produce medical radioisotopes. This definition of purpose and need reflects the 

7 NRC’s recognition that, unless there are findings in the safety review required by the Atomic 

8 Energy Act of 1954, as amended, or findings in the environmental analysis under NEPA that 

9 would lead the NRC to reject a construction permit application, the agency does not have a role 

10 in decisions as to whether a particular medical radioisotope production facility should be 

11 constructed and operated. Section 1.3 of the SEIS identifies the demand in the United States 

12 for molybdenum-99 (Mo-99) and production capacity of the proposed NWMI facility.

13 A.1.13 Water Resources

14 Comment:

15 12-04: [...]the possibility of groundwater contamination near private wells can increase the risk 

16 of harm to sensitive populations.

17 Response:

18 The comment recommends that the EIS assess the groundwater impacts from the proposed 

19 facility and consider the effects on sensitive populations. Section 3.4.2 of the EIS describes the 

20 groundwater resources at and around the proposed Discovery Ridge site. Section 3.4.2.2 of the 

21 EIS discusses water supply wells and other wells within a 1-mi (1.6-km) radius of the proposed 

22 Discovery Ridge site. Sections 4.4.1 and 4.4.2 of the EIS evaluate the impacts from 

23 construction, operations, and decommissioning of the proposed NWMI facility on surface water 

24 and groundwater quality and use, respectively. As discussed in Sections 4.4.1.2 and 4.4.2.2, 

25 the proposed facility is designed to have zero liquid discharge of radioactive or hazardous 

26 liquids; therefore, there would be no such liquid effluents released from the facility to the 

27 environment during operation. Facility discharges would be limited to sanitary effluent, which 

28 would be conveyed to the City of Columbia Sanitary Sewer Utility as discussed in 

29 Section 4.4.1.2. Further, stormwater runoff from the NWMI facility site would be managed by an 

30 engineered stormwater management system, including necessary detention/retention 

31 structures, constructed and operated in compliance with State and municipal stormwater 

32 management plans, procedures, and practices. Consequently, because no radioactive or 

33 hazardous liquid effluent discharge would occur from the facility during normal operations, the 

34 impact on surface water or groundwater quality would be negligible or SMALL and no impact on 

35 human health would be expected.

36 A.1.14 Support for the NWMI Facility

37 Comments:

38 10-01: I am here to testify in support of Northwest Medical Isotopes, LLC’s proposed project. 

39 Because of our wide array of community assets, we believe that Boone County is an excellent 

40 location for the proposed facility. One of our community’s premier assets is the University of 

41 Missouri’s nuclear reactor. The physical proximity of the reactor, as well as its history of 

42 excellence in performance, combine to make this a perfect partnership between the University 

43 of Missouri and Northwest Medical Isotopes.

44 Through this partnership we will be -- which will produce 99-Mo, cancer patients throughout the 

45 United States will have more opportunities for a better outcome. The proposed location of the 

46 facility at University of Missouri’s Discovery Ridge Park will provide access to Mid-Missouri 
Appendix A

A-10

1 Regional Airport. This too is an enormous benefit to the project, since reducing the time 

2 between production of the drug and delivery to healthcare professionals will effectively increase 

3 the efficacy of the drug needed by the patients and doctors throughout the United States. 

4 Another asset that our community brings to the table is Boone County’s ability to utilize our 

5 economic development tool, as Chap -- known as Chapter 100 Bond. With this tool, in 

6 cooperation with our taxing entities, we can make this project successful. This is a 

7 community-wide partnership, which has the potential to grow ever stronger through the 

8 collaboration created by effectively utilizing our community assets, the University’s research 

9 reactor, Mid-Missouri Regional Airport, and our ability to utilize the economic tool Chapter 100 

10 Bond. Our community directly benefits from this partnership because this project will bring 

11 good-paying jobs and capital investment, and it creates the possibility of pharmaceutical 

12 companies joining the research hub of Discovery Ridge, with that enhanced tax base benefiting 

13 all citizens. Please accept this testimony made on behalf of the Boone County Commission in 

14 support of the Northwest Medical Isotopes, LLC facility location.

15 09-01: I appreciate the opportunity to testify before the NRC in support of the Northwest 

16 Medical Isotopes proposal. This is an important initiative for obviously several different reasons. 

17 One is that we have a highly-skilled workforce in Boone County and can easily support the 

18 80-plus jobs that will be required in the production of technetium.

19 Secondly, obviously for Boone County, the 1,600 workers that will be required to construct the 

20 building is very important to the economy here in Mid-Missouri and in the whole state of 

21 Missouri.

22 Second -- next, you know, I have -- in my former life I was a physician and have been on staff of 

23 both the University of Missouri Hospital and Boone Hospital; and I know how important, you 

24 know how important the use of radioisotopes is to the healthcare community, to the men and 

25 women who do diagnostic and therapeutic intervention, and you know how important this tool is 

26 to continue. And it’s – it’s -- I know there are a lot of healthcare providers that are 

27 uncomfortable with the prospect that Technetium may be in short supply in the pending near 

28 future. And, last, and really most important in my opinion is the fact that so many of us may be 

29 requiring this tool. You know, whether there’s -- of the 18 million doses of Technetium a year, 

30 which, obviously, do the math, is 50,000 a day, many of us will need this diagnostic tool for 

31 heart disease, bone, skin, and other emerging technologies. And it means so much if we’re 

32 able to bring the production of this very essential radioisotope back into the United States where 

33 we can produce it here and deliver it to the 300-plus citizens of the United States who continue 

34 to need this and will need this in the future.

35 04-01: I wanted to put on record the Columbia Chamber of Commerce’s support of the 

36 Northwest Medical Isotopes application. I wanted to highlight a couple of items that we are 

37 supportive of Missouri and Columbia is the home to world-class medical research resources, 

38 and Columbia is at the strategic central location of that access point, and it accesses to other 

39 critical markets across the country. So we’re supportive of that effort. Also, the Discovery 

40 Ridge site utilizes the proximity nourished Missouri and its proximity to transport access at the 

41 intersections of two major highways and our access to a regional airport. Also, we have an 

42 ample workforce available for the construction phase through the decommissioning phase of 

43 this facility. So, once again, the Columbia Chamber of Commerce wants to be on record in 

44 support of the Northwest Medical Isotopes application.

45 05-01: I mention that simply to reinforce the point that this project, Northwest Medical Isotopes, 

46 has from the start been the perfect example of a private-public or a public-private partnership. 

47 Much like REDI, which is also a public-private partnership, this project is a prime example of a 
Appendix A

A-11

1 company in the city of Columbia, county of Boone, state of Missouri, and our great native 

2 University working together to do whatever’s necessary to bring a great project to fruition.

3 You will hear some more and have heard from several folks tonight about more specific 

4 information relating to this project. My role is to discuss the overall economic pro-- economic 

5 impact of the project and how it will impact our community and state.

6 REDI’s worked with Northwest for over two years by assisting Northwest and bringing together 

7 the right organizational leadership to help move this project to this point. I mentioned many of 

8 them just a second ago, but must stress the critical role of the University and the University 

9 team at the research reactor. This is simply an amazing opportunity for Columbia, the 

10 University, Missouri and, in fact, the United States and our citizens.

11 There are approximately 50,000 doses of this drug that will be produced at this proposed facility 

12 administered every day in North America. There’s no other producer in the United States for 

13 this credible diagnostic medical pharmaceutical. Our research reactor, in collaboration between 

14 Northwest and the University, are the critical components for this project.

15 It’s estimated that construction of this $70 million radioisotope production facility in fully 

16 operational state will require over 180 full-time skilled construction personnel from Central 

17 Missouri and take longer than a year. When the facility’s in operation, it’s estimated to employ 

18 98 full-time employees. I will tell you those positions will range from extremely highly-skilled 

19 technical jobs to those tasked with maintenance of equipment in the facilities. I make that point 

20 to note the variety of employment opportunities this project brings to our community. Not 

21 included in these construction and operational employment and cost estimates are the ancillary 

22 jobs this project will create. Obviously these radiopharmaceuticals require very rapid delivery to 

23 the medical facilities that administer them around the country.

24 This project will be located at University’s Discovery Ridge Research Park on 7.4 acres. 

25 Discovery Ridge is another great example of great public-private partnerships, as it houses ABC 

26 Laboratories, which is an environmental testing organization serving the pharmaceutical 

27 industry, and other clients like IDEXX, a bioscience company serving veterinary and the animal 

28 health research industry. This site is critically located within a few miles of Interstate 

29 Highway 70, sets immediately adjacent to U.S. Highway 63. This location provides critical 

30 north, south, east, west transportation assets from the center of the United States and is only 

31 about six miles from Columbia Regional Airport.

32 All necessary utilities and street infrastructures, including an adjacent overpass providing 

33 access to Highway 63, is already in place at the lot line for a fast timeline for this project. That 

34 fact simply demonstrates our community’s long-term commitment to support this very type of 

35 development at Discovery Ridge. In addition to the investment and employment opportunities 

36 I’ve mentioned, it’s also anticipated over the life of this project this project will produce over 

37 $76 million in tax revenues to support our school, our city, our county, and our state. In closing, 

38 on behalf of REDI and myself, our community, our county, our state, and the thousands of U.S. 

39 citizens whose lives will be positively impacted by this project on a daily basis, I give our support 

40 and approval.

41 08-01: The opportunities that we look forward to are those that allow for the growth of 

42 employment as well as investment. We’re very, very pleased to have provided an assistance 

43 proposal to Northwest Isotopes approximately a year and a half ago that does just that; creates 

44 a number of great jobs, a great deal of investment in one of our targeted industries of life 

45 sciences. It also does something that I consider very important; it creates an opportunity to 

46 save lives.
Appendix A

A-12

1 03-01: Large-scale production of moly-99 is currently only completed at five facilities worldwide. 

2 Moly-99 has not been produced domestically since 1991. These five facilities rely on aging 

3 research reactors, which are periodically subject to planned and unplanned maintenance. 

4 Some of these unplanned maintenance outages have led to shortages of moly-99, frequently 

5 impacting patient access to technetium for these important diagnostic procedures.

6 Mallinckrodt is also a major producer of moly-99 at our facility in the Netherlands, so we are 

7 very familiar with what is needed to produce commercial quantities of this isotope. As the 

8 world’s largest consumer of moly-99, Mallinckrodt closely follows new efforts to produce this 

9 critical isotope and supports construction of new facilities for its production. We are very familiar 

10 with Northwest Medical Isotopes’ plan to license and construct a facility in Columbia, Missouri

11 for the production of moly-99 and the recycling of their target material. As we understand it, 

12 they intend to utilize a network of two to three university research reactors and build a new 

13 moly-99 production facility, all of which should provide additional moly-99 capacity.

14 We believe their technology offers distinct advantages because it is based on the well-proven 

15 fission method of moly-99 production and uses existing reactors. Their operation will, 

16 importantly, also be based upon low-enriched uranium, which meets the objectives of the 

17 U.S. Government's nonproliferation policy, as stated at the 2012 Nuclear Security Summit in 

18 Seoul, South Korea and in 2014 in the Netherlands.

19 Nuclear medicine procedures performed in the U.S. consume half of the world’s supplies of 

20 moly-99. A domestic moly-99 production facility will reduce radioactive decay losses in transit 

21 from the current suppliers in Europe, South Africa, and Australia. A U.S. supply, if robust 

22 enough to supply the entire market, will also eliminate or reduce transport problems we’ve had 

23 in the past relying on shipments from Europe, incidents including volcanic activity in Iceland and 

24 flood destructions due to terrorist concerns. Discussions leading up to the passage of the 

25 American Medical Isotope Production Act of 2012 cited all of these issues as a reason to 

26 encourage domestic production of moly-99.

27 Mallinckrodt applauds Northwest Medical Isotopes’ efforts to build its facility in Columbia and 

28 encourages the NRC to provide the necessary resources for an expedient review of their 

29 construction permit and operating license applications.

30 Response:

31 These comments generally support the application and note the medical and socioeconomic 

32 benefits of constructing and operating the proposed NWMI facility at the University of Missouri’s 

33 Discovery Ridge Park in Columbia, Missouri. The commenters cite the use of a proven 

34 technology, the benefit of providing a domestic supply of Mo-99 for medical use, public–private 

35 partnership, and the proximity of the proposed NWMI facility site to transportation infrastructure.

36 Section 3.7 of the EIS describes the current socioeconomic factors, including labor force, 

37 employment, and unemployment data for the City of Columbia and Boone County, which have 

38 the potential to be directly or indirectly affected from construction, operations, and 

39 decommissioning of the proposed NWMI facility. Section 4.7 of the EIS describes the potential 

40 socioeconomic impacts from constructing, operating, and decommissioning the proposed NWMI 

41 facility at the Discovery Ridge site. The impact analysis considered potential changes in 

42 regional employment, housing availability, tax revenues, and public services.

43 Section 3.9 of the EIS describes the local transportation systems, including roadway networks 

44 and traffic volumes near the proposed Discovery Ridge site. Section 4.10 of the EIS describes 

45 the potential transportation impacts during the construction operations, and decommissioning of 

46 the proposed NWMI facility at the Discovery Ridge site.
Appendix A

A-13

1 Section 5.4 of the EIS evaluates the costs and benefits of the proposed action and compares 

2 the environmental impacts of the proposed NWMI facility with those that would be associated 

3 with using alternative technologies. Table 5–13 provides a tabular comparison of the potential 

4 environmental impacts of constructing, operating, and decommissioning the proposed NWMI 

5 facility at the Discovery Ridge site with the potential environmental impacts of using alternative 

6 technologies.

7 A.2 References

8 80 FR 72115. U.S. Nuclear Regulatory Commission. “Northwest Medical Isotopes, LLC- intent 

9 to conduct scoping process and prepare an environmental impact statement; public meeting 

10 and request for comment.” Federal Register 80(222): 72115–72117. November 18, 2015.

11 7 CFR Part 657. Code of Federal Regulations, Title 7, Agriculture, Part 657, “Important 

12 farmlands inventory.”

13 7 CFR Part 658. Code of Federal Regulations, Title 7, Agriculture, Part 658, “Farmland 

14 protection policy act.

15 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

16 protection against radiation.”

17 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

18 production and utilization facilities.”

19 10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and 

20 transportation of radioactive material.”

21 49 FR 9375. U.S. Nuclear Regulatory Commission. “Environmental Protection Regulations for

22 Domestic Licensing and Related Regulatory Functions and Related Conforming Amendments.” 

23 Federal Register Notice 49(49): 99352–9406. March 12, 1984.

24 American Medical Isotopes Production Act of 2012. 42 U.S.C. §2065 et seq.

25 Atomic Energy Act of 1954, as amended. 42 U.S.C. §2011 et seq.

26 Farmland Protection Policy Act of 1981. 7 U.S.C. §4201 et seq.

27 National Environmental Policy Act of 1969, as amended. 42 U.S.C. §4321 et seq.

28 National Historic Preservation Act of 1966. 54 U.S.C. §300101 et seq.

29 Resource Conservation and Recovery Act of 1976. 42 U.S.C. §6901 et seq.

30 [NRC] U.S. Nuclear Regulatory Commission. 2015a. Official Transcript Proceedings, Public 

31 Scoping Meeting for Northwest Medical Isotopes, LLC. December 8, 2015. ADAMS 

32 No. ML15356A133.

33 [NRC] U.S. Nuclear Regulatory Commission. 2015b. Request for Scoping Comments 

34 Concerning the Northwest Medical Isotopes, LLC Radioisotope Production Facility Application 

35 Review. ADAMS No. ML15308A362.

36 [NRC] U.S. Nuclear Regulatory Commission. 2016. “Summary of the Public Scoping Meeting 

37 Conducted Related to the Review of the Proposed Northwest Medical Isotopes, LLC 

38 Radioisotope Production Facility.” Washington, DC: NRC. January 20, 2015. ADAMS 

39 No. ML15356A096.

1 

2 APPLICABLE LAWS, REGULATIONS, AND OTHER REQUIREMENTS

B-1 

1 B. APPLICABLE LAWS, REGULATIONS, AND OTHER

2 REQUIREMENTS

3 A number of Federal laws and regulations affect environmental protection, health, safety, 

4 compliance, and consultation at U.S. Nuclear Regulatory Commission (NRC)-licensed facilities. 

5 Certain Federal environmental requirements have been delegated to State authorities for 

6 enforcement and implementation. Furthermore, States have enacted laws to protect public 

7 health and safety and the environment. It is the agency’s policy to ensure that NRC-licensed 

8 facilities are operated in a manner that provides adequate protection of public health and safety 

9 and of the environment through compliance with applicable Federal and State laws, regulations, 

10 and other requirements.

11 The requirements that may be applicable to the operation of NRC-licensed facilities encompass 

12 a broad range of Federal laws and regulations that address environmental, historical and 

13 cultural, health and safety, transportation, and other concerns. Generally, these laws and 

14 regulations relate to how a facility would conduct the work involved in performing a proposed 

15 action to protect workers, the public, and environmental resources. Some of these laws and 

16 regulations require permits or consultation with other Federal agencies or State, Tribal, or local 

17 governments.

18 The Atomic Energy Act of 1954, as amended (AEA) (42 U.S.C. 2011 et seq.), authorizes the 

19 NRC to enter into agreement with any State to assume regulatory authority for certain activities 

20 (42 U.S.C. 2021). Missouri is a non-agreement state; thus, the NRC has regulatory 

21 responsibility over byproducts, sources, and quantities of special nuclear materials.

22 State legislatures develop their own laws. State statutes supplement, as well as implement, 

23 Federal laws for the protection of air, water quality, and groundwater. State legislation may 

24 address solid waste management programs, locally rare or endangered species, and historical 

25 and cultural resources.

26 The Clean Water Act of 1977 (CWA), as amended (33 U.S.C. 1251 et seq.), allows for primary 

27 enforcement and administration through State agencies, as long as the State program is at least 

28 as stringent as the Federal program. The State program must conform to the CWA and to the 

29 delegation of authority for the Federal National Pollutant Discharge Elimination System 

30 (NPDES) program from the U.S. Environmental Protection Agency (EPA) to the State. The 

31 primary mechanism to control water pollution is the requirement for direct dischargers to obtain 

32 an NPDES permit or a State Pollutant Discharge Elimination System permit, when the authority 

33 has been delegated from the EPA, under the CWA, as is the case for Missouri. 

34 One important difference between Federal regulations and certain State regulations is the 

35 definition of waters regulated by the State. Certain State regulations may include underground 

36 waters, whereas the CWA only regulates surface waters. 

37 B.1 Federal, State, and Local Requirements

38 Construction and operation of the Northwest Medical Isotopes, LLC (NWMI) facility would be 

39 subject to Federal, State, and local requirements. Tables B–1, B–2, and B–3 identify the

40 principal Federal, State, County, and city environmental regulatory requirements that may be 

41 applicable to the proposed, NWMI medical radioisotope production facility (NWMI facility). 

42 Along with each regulatory requirement is a brief description. The requirements are organized 

43 into categories, such as general requirements, water resources, and pollution prevention.
Appendix B

B-2

1 Table B–1. Potentially Applicable Federal Statutes, Regulations, and Orders

Statute/Regulation/Order Description

General Requirements

Atomic Energy Act of 1954, 

as amended, 

42 U.S.C. 2011 et seq.;

Energy Reorganization Act 

of 1974, 42 U.S.C. 5801 et 

seq.

The 1954 Atomic Energy Act, as amended (AEA), and the Energy 

Reorganization Act of 1974, give the NRC the licensing and regulatory 

authority for nuclear energy uses within the commercial sector. The Acts

give the NRC responsibility for licensing and regulating commercial uses of 

atomic energy and research and test reactors, and allow the agency to

protect workers and the public by establishing dose and concentration 

limits for activities under NRC jurisdiction. The NRC implements its 

responsibilities under the AEA through regulations established in Title 10 of 

the Code of Federal Regulations (CFR).

National Environmental 

Policy Act of 1969, as 

amended, 42 U.S.C. 4321 

et seq.

The National Environmental Policy Act, as amended (NEPA), requires 

Federal agencies to integrate environmental values into their 

decisionmaking process by considering the environmental impacts of 

proposed Federal actions and reasonable alternatives to those actions. 

NEPA establishes policy, sets goals (in Section 101), and provides means 

(in Section 102) for carrying out the policy. Section 102(2) contains 

action-forcing provisions to ensure that Federal agencies follow the letter 

and spirit of the Act. For major Federal actions significantly affecting the 

quality of the human environment, Section 102(2)(C) of NEPA requires 

Federal agencies to prepare a detailed statement that includes the 

environmental impacts of the proposed action and other specified 

information.

10 CFR Part 30 10 CFR Part 30, “Rules of general applicability to domestic licensing of 

byproduct material,” contains NRC regulations issued under the AEA, as 

amended (68 Stat. 919), and Title II of the Energy Reorganization Act of 

1974 (88 Stat. 1242) to provide for the domestic licensing of byproduct 

material. This part also gives notice to certain persons who knowingly 

provide—to any licensee, applicant, certificate holder, contractor, or 

subcontractor—any components, equipment, materials, or other goods or 

services that relate to a licensee’s, certificate holder’s or applicant’s 

activities subject to this part, that they may be individually subject to NRC 

enforcement action for violation of 10 CFR 30.10.

10 CFR Part 50 10 CFR Part 50, “Domestic licensing of production and utilization facilities,” 

contains NRC regulations issued under the AEA, as amended 

(68 Stat. 919), and Title II of the Energy Reorganization Act of 1974 

(88 Stat. 1242) to provide for the licensing of production and utilization 

facilities. This part also gives notice to certain persons who knowingly 

provide—to any licensee, applicant, contractor, or subcontractor—any

components, equipment, materials, or other goods or services that relate to 

a licensee’s or applicant’s activities subject to this part, that they may be 

individually subject to NRC enforcement action for violation of 

10 CFR 50.5.
Appendix B

B-3

Statute/Regulation/Order Description

10 CFR Part 70 10 CFR Part 70, “Domestic licensing of special nuclear material,” contains

NRC regulations issued under the AEA, as amended (68 Stat. 919), and 

Title II of the Energy Reorganization Act of 1974 (88 Stat. 1242), that 

establish procedures and criteria for the issuance of licenses to receive title 

to, own, acquire, deliver, receive, possess, use, and transfer special 

nuclear material. This part also gives notice to certain persons who 

knowingly provide—to any licensee, applicant for a license, employee of a 

licensee or applicant, contractor (including a supplier or consultant), 

subcontractor, or employee of a contractor or subcontractor of any licensee 

of applicant for a license—any components, equipment, materials, or other 

goods or services that relate to a licensee’s or applicant’s activities in this 

part, that they may be individually subject to NRC enforcement action for 

violation of 10 CFR 70.10.

Air Quality Protection

Clean Air Act of 1970, as 

amended,

42 U.S.C. 7401 et seq.

The Clean Air Act, as amended (CAA), is intended to “protect and enhance 

the quality of the nation’s air resources so as to promote the public health

and welfare and the productive capacity of its population.” The CAA 

establishes regulations to ensure maintenance of air quality standards and 

authorizes individual States to manage permits. Section 118 of the CAA 

requires each Federal agency, with jurisdiction over properties or facilities 

engaged in any activity that might result in the discharge of air pollutants, 

to comply with all Federal, State, inter-State, and local requirements with 

regard to the control and abatement of air pollution. Section 109 of the 

CAA directs the U.S. Environmental Protection Agency (EPA) to set 

National Ambient Air Quality Standards for criteria pollutants. EPA has 

identified these standards and set them for the following criteria pollutants: 

particulate matter, sulfur dioxide, carbon monoxide, ozone, nitrogen 

dioxide, and lead. Section 111 of the CAA requires the establishment of 

national performance standards for new or modified stationary sources of 

atmospheric pollutants. Section 160 of the CAA requires the evaluation of 

specific emission increases before permit approval to prevent significant 

deterioration of air quality. Section 112 requires specific standards for the 

release of hazardous air pollutants (including radionuclides). These 

standards are implemented through plans developed by each State and 

approved by the EPA. The CAA requires sources to meet standards and 

to obtain permits to satisfy those standards. Nuclear facilities may be 

required to comply with CAA Title V, Sections 501–507, for sources subject 

to new source performance standards or sources subject to National 

Emission Standards for Hazardous Air Pollutants. EPA regulates 

emissions of air pollutants in 40 CFR Parts 50 to 99.

Environmental Justice and Public Health Protection 

10 CFR Part 20 10 CFR Part 20, “Standards for protection against radiation,” contains NRC 

regulations that establish standards for protection against ionizing radiation 

resulting from activities conducted under licenses issued by the NRC. The

NRC issued these regulations under the AEA, as amended, and the 

Energy Reorganization Act of 1974, as amended. The purpose of these

regulations is to control the receipt, possession, use, transfer, and disposal 

of licensed material by any licensee in such a manner that the total dose to 

an individual (including doses resulting from licensed and unlicensed 

radioactive material and from radiation sources other than background 

radiation) does not exceed the standards for protection against radiation 

prescribed in the regulations in this part.
Appendix B

B-4

Statute/Regulation/Order Description

Executive Order 12898 Executive Order 12898, “Federal Actions to Address Environmental Justice 

in Minority Populations and Low-Income Populations,” requires Federal 

agencies to identify and address, as appropriate, disproportionately high 

and adverse human health or environmental effects of its programs, 

policies, and activities on minority and low-income populations. Amended 

by Executive Order 12948.

Executive Order 13045 Executive Order 13045, “Protection of Children from Environmental Health 

Risks and Safety Risks,” prioritizes the identification and assessment of 

environmental health and safety risks that may disproportionately affect 

children and ensures that those risks are addressed.

Noise Control Act of 1972, 

as amended, 

42 U.S.C. 4901 et seq.

The Noise Control Act of 1972, as amended, requires facilities to maintain 

noise levels that do not jeopardize public health or safety.

Occupational Safety and 

Health Administration

occupational noise 

exposure regulations, 

29 CFR 1910.95

Occupational Safety and Health Administration (OSHA) regulations 

establish workplace standards for noise.

Occupational Safety and 

Health Act of 1970, as 

amended, 29 U.S.C. 651 et 

seq.

The Occupational Safety and Health Act of 1970 requires compliance with 

all applicable worker safety and health legislation (including guidelines in

29 CFR Part 1960).

Policy Statement on the 

Treatment of 

Environmental Justice 

Matters in NRC Regulatory 

and Licensing Actions,

69 FR 52040 (2004)

The NRC is committed to the general goals of Executive Order 12898 and 

to full compliance with the NEPA requirements.

Historic Preservation and Cultural Resources

National Historic 

Preservation Act of 1966, 

as amended, 

54 U.S.C. 300101 et seq.

The National Historic Preservation Act, as amended (NHPA), was enacted 

to create a national historic preservation program, including the National 

Register of Historic Places and the Advisory Council on Historic 

Preservation. Section 106 of the Act requires Federal agencies to take 

into account the effects of their undertakings on historic properties. The 

Advisory Council on Historic Preservation regulations implementing 

Section 106 of the Act are found in 36 CFR Part 800. The regulations call 

for public involvement in the Section 106 consultation process, including 

Indian Tribes and other interested members of the public, as applicable.

Land Use Protection

Farmland Protection Policy 

Act of 1981, 

7 U.S.C. 4201 et seq.

The Farmland Protection Policy Act sets guidelines that require all 

agencies to identify prime farmland proposed to be converted to 

nonagricultural land use and to evaluate the impact of the conversion.

Protected Species

Endangered Species Act of 

1973, as amended,

16 U.S.C. 1531 et seq.

The Endangered Species Act of 1973, as amended (ESA), was enacted to 

prevent the further decline of endangered and threatened species and to 

restore those species and their critical habitats. Section 7 of the Act 

requires Federal agencies to consult with the U.S. Fish and Wildlife 

Service or the National Marine Fisheries Service on Federal actions that 

may affect listed species or designated critical habitats.
Appendix B

B-5

Statute/Regulation/Order Description

Magnuson–Stevens Fishery 

Conservation and 

Management Act, as 

amended,

16 U.S.C. 1801–1884 

The Magnuson-Stevens Fishery Conservation and Management Act, as 

amended (MSA), governs marine fisheries management in U.S. Federal 

waters. The Act created eight regional fishery management councils and 

includes measures to rebuild overfished fisheries, protect essential fish 

habitat, and reduce bycatch. Under Section 305 of the Act, Federal 

agencies are required to consult with National Marine Fisheries Service for 

any Federal actions that may adversely affect essential fish habitat.

Fish and Wildlife 

Coordination Act of 1934, 

as amended 16 U.S.C. 661 

et seq.

The Fish and Wildlife Coordination Act requires Federal agencies that 

construct, license, or permit water resource development projects to 

consult with USFWS (or NMFS, when applicable) and State wildlife

resource agencies for any project that involves an impoundment of more 

than 10 acres (4 hectares), diversion, channel deepening, or other water

modification regarding the impacts of that action to fish and wildlife and 

any mitigative measures to reduce adverse impacts.

Migratory Bird Treaty Act of

1918, as amended, 

16 U.S.C. 703 et seq.

The Migratory Bird Treaty Act of 1918, as amended, prohibits the pursuit, 

hunt, kill, take, capture, possession, delivery for shipment, shipment, 

import, export, transport, sale, purchase, barter, or offer for sale, purchase, 

or barter of any native migratory birds or their eggs, feathers, or nests. 

The Act is intended to protect birds that have common migration patterns 

between the United States, Canada, Mexico, Japan, and Russia. The 

U.S. Fish and Wildlife Service has statutory authority and responsibility for 

enforcing the Migratory Bird Treaty Act. 

Waste Management and Pollution Prevention

Resource Conservation 

and Recovery Act, 

42 U.S.C. 6901 et seq.

The Resource Conservation and Recovery Act (RCRA) requires the EPA

to define and identify hazardous waste; establish standards for its 

transportation, treatment, storage, and disposal; and require permits for 

persons engaged in hazardous waste activities. Section 3006 

(42 U.S.C. 6926) allows States to establish and administer these permit 

programs with EPA approval. EPA regulations implementing the Act are 

found in 40 CFR Parts 260 to 299. Regulations imposed on a generator or 

on a treatment, storage, or disposal facility vary according to the type and 

quantity of material or waste generated, treated, stored, or disposed of. 

The method of treatment, storage, and disposal also affects the extent and 

complexity of the requirements.

Pollution Prevention Act of 

1990,

42 U.S.C. 13101 et seq.

The Pollution Prevention Act of 1990 establishes a national policy for waste 

management and pollution control that focuses first on source prevention 

or reduction and then on environmental issues, safe recycling, treatment, 

and disposal.
Appendix B

B-6

Statute/Regulation/Order Description

Water Resources Protection

Federal Water Pollution 

Control Act of 1972 

(amended by the Clean 

Water Act of 1977),

33 U.S.C. 1251 et seq. and 

the National Pollutant 

Discharge Elimination 

System (NPDES),

40 CFR Part 122

The Federal Water Pollution Control Act (aka Clean Water Act) of 1972, as 

amended (CWA), was enacted to “restore and maintain the chemical, 

physical, and biological integrity of the Nation’s water.” The Act requires all 

branches of the Federal Government that have jurisdiction over properties 

or facilities engaged in any activity that might result in a discharge or runoff

of pollutants to surface waters to comply with Federal, State, inter-State, 

and local requirements. Under Section 303(c) of the CWA, states have the 

primary responsibility for reviewing, establishing, and revising water quality 

standards, which consist of the designated uses of a waterbody, or 

waterbody segment, the water quality criteria necessary to protect those 

designated uses, and an antidegradation policy. As authorized by Section 

402 of the CWA, the National Pollutant Discharge Elimination System 

(NPDES) permit program controls water pollution by regulating point 

sources that discharge pollutants into U.S. waters. The NPDES program 

requires all facilities that discharge pollutants from any point source into 

U.S. waters to obtain an NPDES permit. A facility may also require an

NPDES General Permit for Industrial Stormwater due to stormwater runoff 

from industrial or commercial facilities to U.S. waters. EPA is authorized 

under the CWA to directly implement the NPDES program; however, EPA 

has authorized many States to implement all or parts of the national 

program. The Missouri Department of Natural Resources (MDNR) is the 

responsible State agency for NPDES permitting. Section 401 of the CWA 

requires States to certify that the permitted discharge would comply with all 

limitations necessary to meet established State water quality standards, 

treatment standards, or schedule of compliance. 

The U.S. Army Corps of Engineers is the lead agency for enforcement of 

CWA wetland requirements (33 CFR Part 320). Under Section 401 of the 

CWA, EPA or a delegated State agency has the authority to review and 

approve, impose a condition, or deny Federal permits or licenses that 

might result in a discharge to State waters, including wetlands. 

Coastal Zone Management 

Act of 1972, as amended, 

16 U.S.C. 1451 et seq.

The Coastal Zone Management Act, as amended (CZMA), was enacted by 

Congress in 1972 to address the increasing pressures of overdevelopment 

upon the Nation’s coastal resources. The National Oceanic and 

Atmospheric Administration (NOAA) administers the CZMA. The CZMA 

encourages States to preserve; protect; develop; and, where possible, 

restore or enhance valuable natural coastal resources, such as wetlands, 

floodplains, estuaries, beaches, dunes, barrier islands, and coral reefs, as 

well as the fish and wildlife using those habitats. Participation by States is 

voluntary. To encourage States to participate, the CZMA makes Federal 

financial assistance available to any coastal State or territory, including 

those on the Great Lakes, which is willing to develop and implement a 

comprehensive coastal management program.

Wild and Scenic Rivers Act, 

16 U.S.C. 1271 et seq.

The Wild and Scenic River Act created the National Wild and Scenic Rivers 

System, which was established to protect the environmental values of 

free-flowing streams from degradation by impacting activities, including 

water resources projects.
Appendix B

B-7 

Statute/Regulation/Order Description

Transportation

Federal Aviation 

Regulations, (FARs). 

14 CFR Part 77—Safe, 

Efficient Use, and 

Preservation of the 

Navigable Airspace and 49 

CFR Part 291— Cargo 

Operations in Interstate Air 

Transportation

These Federal Aviation Administration (FAA) regulations set standards 

used to determine if any object, including the permanent or temporary 

construction or alteration of a structure, is an obstruction to air navigation, 

navigation aids, or navigational facilities and could affect their safe and 

efficient use. Regulations also apply to cargo operations in interstate air 

transportation by air carriers. The FAA is part of the U.S Department of 

Transportation (USDOT). 

Hazardous Materials

Transportation Act of 1975, 

as amended,

49 U.S.C. 5101 et seq., 

49 CFR Part 173, 

Subpart I—Class 7 

(Radioactive) Materials

The Hazardous Materials Transportation Act of 1975, as amended, 

regulates the transportation of hazardous materials (including radioactive 

material) in and between States. States may regulate the transport of 

hazardous materials if consistent with USDOT regulations in 

49 CFR Parts 171 through 177. USDOT requirements for shipping and 

packaging radioactive materials are in 49 CFR Part 173, Subpart I. 

U.S. Department of 

Transportation, Federal 

Aviation Administration 

Advisory Circular, 

AC 150/5200-33B 

The Federal Aviation Administration (FAA) Advisory Circular, 

AC 150/5200-33B, “Hazardous wildlife attractants on or near airports,” 

provides guidance on certain land uses that have the potential to attract 

hazardous wildlife on or near public-use airports. It also discusses airport 

development projects that could affect aircraft movement near hazardous 

wildlife attractants.

1 Table B–2. Potentially Applicable Missouri State Requirements

Statute/Regulation/Order Citation Responsible Agency Description

Air Quality Protection

Missouri Air Conservation 

Law

Missouri Revised 

Statutes, Chapter 643

MDNR, Air 

Conservation 

Commission of the 

State of Missouri

Describes the prevention, 

abatement, and control of 

air pollution

Protected Species

Endangered Species Law Missouri Revised 

Statutes, Chapter 252

Missouri Department of 

Conservation 

Describes the protection 

of endangered wildlife

and lists those species 

considered to be 

threatened with 

extinction.

Waste Management and Pollution Prevention

Missouri Statute on 

Environmental Control

Missouri Revised 

Statutes, Chapter 260

MDNR, Environmental 

Improvement and 

Energy Resources 

Authority

Conserves the air, land,

and water resources of 

the State by requiring the 

prevention or reduction of 

the pollution and proper 

methods of disposal of 

solid waste or sewage.
Appendix B 

B-8 

Statute/Regulation/Order Citation Responsible Agency Description

Water Resources Protection

Missouri Clean Water Law Missouri Revised 

Statutes, Chapter 644

MDNR, Clean Water 

Commission

Describes water pollution 

control programs to 

conserve the waters of 

the State and to protect, 

maintain, and improve the 

quality thereof for public 

water supplies.

1 Table B–3. City of Columbia and Boone County, Missouri, Ordinances and Plans

Ordinance or Plan Responsible Agency Description

Land Use Protection

Boone County Zoning 

Regulations

Boone County Resource 

Management Department

Promotes the health and safety and 

conserves the values of property throughout 

Boone County; lessens or avoids undue 

congestion in the public streets or highways; 

prevents overcrowding of land; avoids undue 

concentration of population; facilitates the 

adequate provision of transportation, water, 

sewerage, schools, parks, and other public 

requirements. 

Code of Ordinances, 

City of Columbia,

Missouri Chapter 6, 

Buildings and Building 

Regulations

City of Columbia Includes ordinances regarding construction 

of buildings; installation of heating, 

ventilation, and air conditioning (HVAC) 

systems; installation of plumbing systems; 

and installation of electrical wiring. 

Code of Ordinances, 

City of Columbia,

Missouri Chapter 12A, 

Article II, Land 

Disturbance Permit 

Requirements

City of Columbia Protects the health, safety, and property of 

Columbia by regulating the disturbance of 

land surface areas by preserving trees, 

preventing erosion on disturbed areas, and 

controlling stormwater drainage. A land 

disturbance permit is required for any land 

disturbance activity, including streets and 

utility construction on any site that results in 

a disturbed area of 1 acre (0.4 ha) or more in 

size.

Code of Ordinances, 

City of Columbia,

Missouri Chapter 9, 

Article II, Fire Code

City of Columbia Establishes requirements to provide safety 

and property protection from fires and 

explosions from building and structures. 

Water Resources Protection

Boone County Storm 

Water Ordinance

Boone County Resource 

Management Department

Establishes stormwater management 

requirements and controls to protect and 

safeguard the general health, safety, and 

welfare of the public residing in watersheds 

within Boone County.
Appendix B

B-9 

Ordinance or Plan Responsible Agency Description

Boone County Sanitary 

Sewer Use Regulations

Boone County Regional Sewer 

District

Protects and promotes the public health and 

ensures the safe and efficient delivery of 

wastewater collection and centralized 

treatment services within the areas of Boone 

County, Missouri.

Code of Ordinances, 

City of Columbia,

Missouri Chapter 27, 

Article II

City of Columbia Application process for utility service and 

billing and fees for utility services. 

Code of Ordinances, 

City of Columbia,

Missouri Chapter 12A, 

Article V

City of Columbia Establishes minimum stormwater

management requirements and controls to 

protect and safeguard the general health, 

safety, and welfare of the public. Requires a 

stormwater management plan to be prepared 

and certified. 

1 B.2 Operating Permits and Other Requirements

2 Table B–4 lists the permits and licenses that NWMI plans to obtain from Federal, State, and 

3 local authorities to construct and operate the NWMI facility.

4 Table B–4. Permits and Approvals Required for Construction and Operations 

Agency Regulatory Authority

Permit or 

Approval

Summary of 

Activities Status

NRC Atomic Energy Act 

10 CFR 50.35 and 

50.50 

Construction 

Permit

Construction of 

the NWMI 

facility

Preliminary safety 

analysis report for the 

construction permit was 

submitted in 2015

Atomic Energy Act 

10 CFR 50.50 and 

50.57

Operating 

License

Operation of the 

NWMI facility

Application under 

development

Atomic Energy Act 

10 CFR Part 30

By-Product 

Material License

Possession, 

use, and 

transfer of 

radioactive byproduct material

To be addressed in 

operating license 

application

Atomic Energy Act 

10 CFR Part 70

Special Nuclear 

Material License

Receipt, 

possession, use, 

and transfer of 

special nuclear 

material

To be addressed in 

operating license 

application

EPA CWA, 40 CFR Part 112, 

Subpart D, Appendix F

Spill Prevention, 

Control and 

Control 

Countermeasure 

(SPCC) Plan for 

construction and 

operation

Storage of oil 

during 

construction and 

operation

NWMI plans to submit 

the SPCC plan 30 days 

prior to construction
Appendix B 

B-10

Agency Regulatory Authority

Permit or 

Approval

Summary of 

Activities Status

Resource Conservation 

and Recovery Act 

(RCRA), 

40 CFR Part 262

Notification of 

RCRA Subtitle C 

activity

Generation of 

hazardous 

waste

NWMI plans to submit 

the notification 60 days 

prior to construction

DOT Hazardous Material 

Transportation Act, 

49 CFR Part 173, 

Subpart I 

Certificate of 

Registration

Transportation 

of radioactive 

materials

NWMI plans to obtain 

certificate before 

transporting radioactive 

and other hazardous 

materials.

MDNR Federal CAA; Missouri 

Revised Statute 

Chapter 643; Missouri 

Code of State 

Regulations, 10 CSR 

Division 10

Construction 

permit; Operating 

Permit

Construction of 

an air emission 

source that is 

not exempted; 

Operation of an 

air emission 

source

NWMI plans to contact 

MDNR to determine if 

permits are required.

MDNR Federal CWA; Missouri 

Revised Statute 

Chapters 640 and 644; 

Missouri Code of State 

Regulations, 10 CSR 

Division 20

Construction 

Stormwater 

Permit

Industrial 

Stormwater 

Permit

Section 401 

Water Quality 

Certification

Discharge of 

stormwater

runoff from the 

site during 

construction

Discharge of 

stormwater from 

the site during 

operations

Activities, 

including facility 

construction or 

operations, 

which may 

cause a 

discharge into 

navigable 

waters

NWMI plans to submit 

application 30 days 

prior to starting 

construction

NWMI plans to submit 

application 1 year prior 

to starting operations

NWMI plans to request 

a waiver from the State 

from the Section 401 

Water Quality 

Certification 

requirement.

Resources 

Conservation and 

Recovery Act; Missouri 

Revised Statute 

Chapter 260; Missouri 

Code of State 

Regulations, 10 CSR 

Division 25-5.262

Notification of 

Regulated 

Activity 

Missouri 

identification 

number for 

generation of 

hazardous 

waste

NWMI plans to submit 

notification 90 days 

prior to generating 

hazardous waste 
Appendix B

B-11

Agency Regulatory Authority

Permit or 

Approval

Summary of 

Activities Status

Certified 

Resource 

Recovery Facility 

Reuse, 

reclamation, or 

recycling 

1,000 kg 

(2,204 lb) or 

more of 

site-generated 

hazardous 

waste

NWMI plans to register 

facility 90 days prior to 

generating hazardous 

waste

Notification to 

MDNR of 

Conditional 

Exemption

Notify MDNR in 

writing and by 

certified delivery 

of the claim of 

conditional 

exemption for 

low-level mixed 

waste stored 

and treated in 

the facility

NWMI plans to submit 

notification 90 days 

prior to operations

City of Columbia Clean Water Act;

Code of Ordinances, 

City of Columbia,

Missouri, Chapter 27

Application for 

utility service

Allows the 

facility to 

connect to 

Columbia Water 

Treatment Plant

NWMI plans to submit 

application 30 days 

prior to construction

Code of Ordinances, 

City of Columbia,

Missouri Chapter 6, 

Article II

Building Permit Approval of 

building code 

and standards, 

including site 

plan

NWMI plans to submit 

application 60 days 

prior to construction

Code of Ordinances, 

City of Columbia,

Missouri Chapter 6, 

Article III

Electrical Plan 

Approval

Electrical Code NWMI plans to submit 

application 60 days 

prior to construction

Code of Ordinances, 

City of Columbia,

Missouri Chapter 6, 

Article IV

Plumbing Plan 

Approval

Plumbing Code NWMI plans to submit 

application 60 days 

prior to construction

Code of Ordinances, 

City of Columbia,

Missouri Chapter 6, 

Article V

HVAC Plan 

approval

Mechanical 

Code

NWMI plans to submit 

application 60 days 

prior to construction

Code of Ordinances, 

City of Columbia,

Missouri Chapter 6

Certificate of 

Occupancy

Facilities 

Meeting Building 

Code

NWMI plans to submit 

upon completion of 

construction

Code of Ordinances, 

City of Columbia,

Missouri Chapter 9, 

Article II

Fire Prevention 

Plan Approval

Fire Code NWMI plans to submit 

application 60 days 

prior to construction
Appendix B 

B-12

Agency Regulatory Authority

Permit or 

Approval

Summary of 

Activities Status

Code of Ordinances, 

City of Columbia,

Missouri Chapter 12A, 

Article II

Land 

Disturbances 

Permit

Land 

disturbance 

activity, 

including 

construction on 

any site that 

results in a 

disturbed area 

of 1 acre 

(0.4 ha) or more

NWMI plans to submit 

application 30 days 

prior to construction

Code of Ordinances, 

City of Columbia,

Missouri Chapter 12A, 

Article V 

Stormwater 

Management 

Plan Approval

Approval 

required prior to 

approval for land 

disturbance 

permit

NWMI plans to submit 

information 45 days 

prior to construction

Boone County 

Resource 

Management 

Department

Boone County Storm 

Water Ordinance

Stormwater 

Discharge Permit

Stormwater 

management

NWMI plans to submit 

application 30 days 

prior to construction

Land 

Disturbance 

Permit

Activity 

disturbing 0.4 ha 

(1 acre) or more 

of land or 

disturbing 

278.7 m3

(3,000 ft2) in 

environmentally 

sensitive areas

NWMI plans to submit 

application 30 days 

prior to construction

Boone County Zoning 

Ordinance

Application for 

Commercial 

Building Permit

Construction of 

a commercial 

building

NWMI plans to submit 

application 30 days 

prior to construction

Boone County 

Regional Sewer 

District

Boone County Sanitary 

Sewer Use Regulations

Sanitary Sewer 

Connection 

Approval

Building 

connection to 

District 

wastewater

treatment works

NWMI plans to submit 

information 30 days 

prior to construction

Source: NWMI 2015

1 B.3 References

2 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

3 protection against radiation.”

4 10 CFR Part 30. Code of Federal Regulations, Title 10, Energy, Part 30, “Rules of general 

5 applicability to domestic licensing of byproduct material.”

6 10 CFR Part 40. Code of Federal Regulations, Title 10, Energy, Part 40, “Domestic licensing of 

7 source material.”

8 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

9 production and utilization facilities.”
Appendix B

B-13

1 10 CFR Part 70. Code of Federal Regulations, Title 10, Energy, Part 70, “Domestic licensing of 

2 special nuclear material.”

3 14 CFR Part 77. Code of Federal Regulations, Title 14, Aeronautics and Space, Part 77, “Safe, 

4 efficient use, and preservation of the navigable airspace.”

5 29 CFR Part 1910. Code of Federal Regulations, Title 29, Labor, Part 1910, “Occupational 

6 safety and health standards.”

7 29 CFR Part 1960. Code of Federal Regulations, Title 29, Labor, Part 1960, “Basic program 

8 elements for federal employee occupational safety and health programs and related matters.”

9 33 CFR Part 320. Code of Federal Regulations, Title 33, Navigation and Navigable Waters, 

10 Part 320, “General regulatory policies.”

11 36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

12 Part 800, “Protection of historic properties.”

13 40 CFR Part 50. Code of Federal Regulations, Title 40, Protection of Environment, Part 50, 

14 “National primary and secondary ambient air quality standards.”

15 40 CFR Part 112. Code of Federal Regulations, Title 40, Protection of Environment, Part 112, 

16 “Oil pollution prevention.”

17 40 CFR Part 122. Code of Federal Regulations, Title 40, Protection of Environment, Part 122, 

18 “EPA administered permit programs: The National Pollutant Discharge Elimination System.”

19 40 CFR Part 260. Code of Federal Regulations, Title 40, Protection of Environment, Part 260, 

20 “Hazardous Waste Management System: General.” 

21 49 CFR Part 107. Code of Federal Regulations, Title 49, Transportation, Part 107, “Hazardous 

22 materials program procedures.”

23 59 FR 7629. Executive Order No. 12898. “Federal Actions to Address Environmental Justice in 

24 Minority Populations and Low-Income Populations.” Federal Register 59(32): 7629–7633. 

25 February 16, 1994.

26 60 FR 6381. Executive Order No. 12948. “Amendment to Executive Order No. 12898.” 

27 Federal Register 60(21):6381. February 1, 1995.

28 62 FR 19885. Executive Order No. 13045. “Protection of Children from Environmental Health 

29 Risks and Safety Risks.” Federal Register 62(78):19885–19888. April 21, 1997.

30 69 FR 52040. U.S. Nuclear Regulatory Commission. “Policy Statement on the Treatment of 

31 Environmental Justice Matters in NRC Regulatory and Licensing Actions.” Federal 

32 Register 69(163):52040–52048. August 24, 2004.

33 Atomic Energy Act of 1954, as amended. 42 U.S.C. §2011 et seq.

34 Clean Air Act of 1970, as amended. 42 U.S.C. §7401 et seq.

35 Clean Water Act of 1972, as amended. 33 U.S.C. §1251 et seq.

36 Coastal Zone Management Act of 1972, as amended. 16 U.S.C. §1451 et seq.

37 Endangered Species Act of 1973, as amended. 16 U.S.C. §1531 et seq.

38 Energy Reorganization Act of 1974, as amended. 42 U.S.C. §5801 et seq.

39 Farmland Protection Policy Act of 1981. 7 U.S.C. §4201 et seq.

40 Fish and Wildlife Coordination Act of 1934, as amended. 16 U.S.C. §661 et seq.
Appendix B

B-14

1 Hazardous Material Transportation Act of 1975, as amended. 49 U.S.C. §5101 et seq.

2 Magnuson–Stevens Fishery Conservation and Management Act, as amended. 

3 16 U.S.C. §1801 et seq.

4 National Environmental Policy Act of 1969, as amended. 42 U.S.C. §4321 et seq.

5 National Historic Preservation Act of 1966, as amended. 54 U.S.C. §300101 et seq.

6 Noise Control Act of 1972, as amended. 42 U.S.C. §4901 et seq.

7 [NWMI] Northwest Medical Isotopes, LLC. 2015. Preliminary Safety Analysis Report (PSAR), 

8 Chapter 19, “Environmental Report.” Corvallis, OR: NWMI. January 2015. ADAMS 

9 Nos. ML15210A123, ML15210A128, ML15210A129, and ML15210A131.

10 Occupational Safety and Health Act of 1970, as amended. 29 U.S.C. §651 et seq.

11 Pollution Prevention Act of 1990. 42 U.S.C. §13101 et seq.

12 Resource Conservation and Recovery Act of 1976, as amended. 42 U.S.C. §6901 et seq.

13 Wild and Scenic Rivers Act, as amended. 16 U.S.C. §1271 et seq.
1 

2 CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE

C-1 

C. CHRONOLOGY OF ENVIRONMENTAL REVIEW 

CORRESPONDENCE

This appendix contains a chronological listing of correspondence between the U.S. Nuclear 

Regulatory Commission (NRC) and external parties as part of its environmental review for the 

Northwest Medical Isotopes, LLC (NWMI), medical radioisotope production facility (NWMI 

facility). 

Documents listed in Table C–1 below are available electronically on the NRC’s website at: 

http://www.nrc.gov/reading-rm.html. From this website, the public can gain access to the NRC’s 

Agencywide Documents Access and Management System (ADAMS), which provides text and 

image files of the agency’s public documents. The table below includes the ADAMS accession 

number for each document. If you need assistance in accessing or searching in ADAMS, 

contact the Public Document Room Staff at 1-800-397-4209. Some of the ADAMS accession 

numbers below lead to a folder containing several documents. Some of the documents within 

these folders contain proprietary information and are not publicly available. Documents marked 

with an asterisk are not publicly available at the request of the sender.

C.1 Environmental Review Correspondence

Table C–1 lists the environmental review correspondence in date order, beginning with the 

request by NWMI to construct the NWMI facility.

Table C–1. Environmental Review Correspondence

Date Correspondence Description ADAMS No.

January 23, 2015 NRC Letter to NWMI, Status of the Acceptance Review 

of Part One of the Application for Construction Permit 

(TAC No. MF2288). 

ML14349A501

February 5, 2015 NWMI Construction Permit Application, Part 1 ML15086A261

April 30, 2015 NRC Federal Register Notice (FRN) of Receipt of Part 1 

of the NWMI Construction Permit Application

ML15070A329

June 8, 2015 NRC FRN of Acceptance for Docketing Part 1 of the 

NWMI Construction Permit Application

ML15125A082

July 20, 2015 Construction Permit Application, Part 2 ML15210A182

August 5, 2015 NRC Letter to NWMI, Environmental Site Audit 

Regarding the Northwest Medical Isotopes, LLC 

Radioisotope Production Facility

ML15202A643

October 13, 2015 Summary of the Environmental Site Audit Related to the 

Review of the Construction Permit Application for 

Northwest Medical Isotopes, LLC 

ML15266A139

November 2, 2015 Request for Additional Information for the Environmental 

Review of the Northwest Medical Isotopes, LLC 

Construction Permit Application

ML15288A102

November 6, 2015 NRC Federal Register Notice (FRN) of Receipt of Part 2

of the NWMI Construction Permit Application

ML15348A021

November 18, 2015 NRC FRN of Intent to Conduct Scoping Process and 

Prepare an Environmental Impact Statement

ML15300A468
Appendix C

C-2

Date Correspondence Description ADAMS No.

November 12, 2015 NRC Letter to NWMI, Notice of Intent to Prepare an 

Environmental Impact Statement and Conduct Scoping

ML15300A456

November 17, 2015 NRC Letter to Missouri Department of Natural 

Resources, Division of Environmental Quality, Request 

for Scoping Comments Concerning the Northwest 

Medical Isotopes, LLC Radioisotope Production Facility 

Application Environmental Review

ML15308A362

November 17, 2015 NRC Letter to U.S. Environmental Protection Agency –

Region 7, Request for Scoping Comments Concerning 

the Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Environmental Review

ML15308A362

November 17, 2015 NRC Letter to Missouri Department of Natural 

Resources, Request for Scoping Comments Concerning 

the Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Environmental Review 

ML15308A362

November 17, 2015 NRC Letter to U.S. Department of Energy, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility 

Application Environmental Review

ML15308A362

November 17, 2015 NRC Letter to Missouri Department of Transportation, 

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Environmental Review

ML15308A362

November 17, 2015 NRC Letter to Missouri Department of Health and Senior 

Services, Request for Scoping Comments Concerning 

the Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Environmental Review

ML15308A362

November 17, 2015 NRC Letter to Missouri Department of Health and Senior 

Services, Request for Scoping Comments Concerning 

the Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Environmental Review

ML15308A362

November 17, 2015 NRC Letter to Missouri Department of Public Safety, 

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Environmental Review

ML15308A362

November 17, 2015 NRC Letter to Missouri Department of Conservation,

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Environmental Review

ML15308A362

November 17, 2015 NRC Letter to Boone County Government Center, 

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Environmental Review

ML15308A362

November 17, 2015 NRC Letter to City of Columbia, Request for Scoping 

Comments Concerning the Northwest Medical Isotopes, 

LLC Radioisotope Production Facility Application 

Environmental Review

ML15308A362
Appendix C

C-3 

Date Correspondence Description ADAMS No.

November 17, 2015 NRC Letter to Mid-Missouri Regional Planning 

Commission, Request for Scoping Comments 

Concerning the Northwest Medical Isotopes, LLC 

Radioisotope Production Facility Application 

Environmental Review

ML15308A362

November 19, 2015 NRC Letter to Daniel Boone Regional Library, 

Maintenance of Reference Materials at the Daniel Boone 

Regional Library for the Environmental Review of 

Northwest Medical Isotopes, LLC Construction Permit 

Application

ML15321A069

November 19, 2015 NRC Letter to State Historic Preservation Office,

Missouri Department of Natural Resources, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility 

Application Environmental Review

ML15314A686

November 19, 2015 NRC Letter to Advisory Council on Historic Preservation,

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Review

ML15314A363

November 20, 2015 NRC Letter to Absentee-Shawnee Tribe of Indians of 

Oklahoma, Request for Scoping Comments Concerning 

the Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Caddo Nation of Oklahoma, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility 

Application Review

ML15316A036

November 20, 2015 NRC Letter to Cherokee Nation, Request for Scoping 

Comments Concerning the Northwest Medical Isotopes, 

LLC Radioisotope Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Cheyenne and Arapaho Tribes, Request 

for Scoping Comments Concerning the Northwest 

Medical Isotopes, LLC Radioisotope Production Facility 

Application Review

ML15316A036

November 20, 2015 NRC Letter to The Chickasaw Nation, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility 

Application Review

ML15316A036

November 20, 2015 NRC Letter to The Choctaw Nation of Oklahoma, 

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Citizen Potawatomi Nation, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility 

Application Review

ML15316A036

November 20, 2015 NRC Letter to Delaware Nation, Request for Scoping 

Comments Concerning the Northwest Medical Isotopes, 

LLC Radioisotope Production Facility Application Review

ML15316A036
Appendix C

C-4

Date Correspondence Description ADAMS No.

November 20, 2015 NRC Letter to Eastern Shawnee Tribe of Oklahoma, 

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Iowa Tribe of Kansas and Nebraska, 

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Iowa Tribe of Oklahoma, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility 

Application Review

ML15316A036

November 20, 2015 NRC Letter to Miami Tribe of Oklahoma, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility 

Application Review

ML15316A036

November 20, 2015 NRC Letter to The Muscogee (Creek) Nation, Request 

for Scoping Comments Concerning the Northwest 

Medical Isotopes, LLC Radioisotope Production Facility 

Application Review

ML15316A036

November 20, 2015 NRC Letter to Omaha Tribe of Nebraska, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility 

Application Review

ML15316A036

November 20, 2015 NRC Letter to The Osage Nation, Request for Scoping 

Comments Concerning the Northwest Medical Isotopes, 

LLC Radioisotope Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Otoe-Missouria Tribe of Indians, 

Oklahoma, Request for Scoping Comments Concerning 

the Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Pawnee Nation of Oklahoma, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility 

Application Review

ML15316A036

November 20, 2015 NRC Letter to Peoria Tribe of Indians of Oklahoma, 

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Ponca Tribe of Indians of Oklahoma, 

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Ponca Tribe of Nebraska, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility 

Application Review

ML15316A036
Appendix C

C-5

Date Correspondence Description ADAMS No.

November 20, 2015 NRC Letter to Prairie Band Potawatomi Nation, Request 

for Scoping Comments Concerning the Northwest 

Medical Isotopes, LLC Radioisotope Production Facility 

Application Review

ML15316A036

November 20, 2015 NRC Letter to The Quapaw Tribe of Indians, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility 

Application Review

ML15316A036

November 20, 2015 NRC Letter to Sac and Fox Nation of Missouri in Kansas 

and Nebraska, Request for Scoping Comments 

Concerning the Northwest Medical Isotopes, LLC 

Radioisotope Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Sac and Fox Nation, Oklahoma, Request 

for Scoping Comments Concerning the Northwest 

Medical Isotopes, LLC Radioisotope Production Facility 

Application Review

ML15316A036

November 20, 2015 NRC Letter to Sac and Fox Tribe of the Mississippi in 

Iowa, Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Shawnee Tribe, Request for Scoping 

Comments Concerning the Northwest Medical Isotopes, 

LLC Radioisotope Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to United Keetoowah Band of Cherokee 

Indians of Oklahoma, Request for Scoping Comments 

Concerning the Northwest Medical Isotopes, LLC 

Radioisotope Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Winnebago Tribe of Nebraska, Request 

for Scoping Comments Concerning the Northwest 

Medical Isotopes, LLC Radioisotope Production Facility 

Application Review

ML15316A036

November 20, 2015 NRC Letter to Wyandotte Nation, Request for Scoping 

Comments Concerning the Northwest Medical Isotopes, 

LLC Radioisotope Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Kaw Nation, Oklahoma, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility 

Application Review

ML15316A036

November 20, 2015 NRC Letter to Yankton Sioux Tribe of South Dakota, 

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Review

ML15316A036

November 20, 2015 NWMI Letter to NRC, Response to Environmental 

Request for Additional Information 

ML15328A070

November 29, 2015 List of ESA-protected species that may occur within the 

proposed Discovery Ridge site

ML15335A002
Appendix C

C-6

Date Correspondence Description ADAMS No.

December 1, 2015 Pawnee Nation of Oklahoma, Request for Section 106 

Consultation and Review for Proposed Construction 

located Discovery Ridge Park, Columbia, Boone County, 

MO

ML16020A338

December 3, 2015 Conference call with NRC and FWS to confirm list of 

ESA-protected species that may occur within the 

proposed Discovery Ridge site

ML15362A225

December 7, 2015 Quapaw Tribe of Oklahoma Letter to NRC, Scoping 

Comments Concerning the Northwest Medical Isotopes, 

LLC Radioisotope Production Facility Review

ML16020A339

December 9, 2015 State Historic Preservation Office, Missouri Department 

of Natural Resources Letter to NRC

ML16020A340

December 9, 2015 United Keetoowah Band of Cherokee Indians in 

Oklahoma email to NRC

ML16049A297

December 10, 2015 Miami Tribe of Oklahoma email to NRC ML16056A421

December 24, 2015 NRC Letter to Northwest Medical Isotopes, LCC, 

Acceptance for Docketing of Part Two of the Application 

for A Production Facility Construction Permit

ML15341A112

December 28, 2015 Tribal correspondence to NRC* ML16210A477

December 29, 2016 Tribal correspondence to NRC* ML16077A324

January 4, 2016 NRC FRN of Acceptance for Docketing Part 2 of the 

NWMI Construction Permit Application

ML15348A021

January 4, 2016 U.S. Environmental Protection Agency Letter to NRC, 

Scoping Comments

ML16007A004

January 19, 2016 NRC Letter to NWMI, Request for Additional Information 

for the Environmental Review of the Northwest Medical 

Isotopes, LCC, Construction Permit Application

ML15364A376

February 12, 2016 NWMI Letter to NRC, Responses to the U.S. Nuclear 

Regulatory Commission Request for Additional 

Information, Letter dated January 19, 2016

ML16053A221

March 28, 2016 NRC Letter to NWMI, Request for Additional Information 

Regarding Application for Construction Permit and NRC 

Staff Review Schedule 

ML16056A122

April 6, 2016 NRC Letter to NWMI, Issuance of Environmental 

Scoping Summary Report Associated with the Staff’s 

Review of the Application by Northwest Medical 

Isotopes, LLC, for a Construction Permit for a 

Radioisotope Production Facility

ML16056A628

April 15, 2016 List of ESA-protected species that may occur within the 

University of Missouri Research Reactor alternative site

ML16117A529

April 25, 2016 NWMI Letter to NRC, Responses to the NRC 

Environmental Request for Additional Information –

Letter dated March 28, 2016

ML16123A119

June 16, 2016 NRC Letter to NWMI, Request for Additional Information 

for the Environmental Review of the Application for 

Construction Permit (TAC Nos. MF6134 AND MF6135)

ML16152A019
Appendix C

C-7 

Date Correspondence Description ADAMS No.

July 18, 2016 NWMI Letter to NRC, Responses to the NRC 

Environmental Request for Additional Information – 

Letter dated June 16, 2016

ML16210A305

September 1, 2016 NWMI Letter to NRC, Additional Clarification on RAIs 

POSA3-1A, POSA3-1B, POSA3-2A, POSA3-3A, NOI3-

1B, and PA3-1

ML16270A377

1 

2 CONSULTATION CORRESPONDENCE

D-1 

1 D. CONSULTATION CORRESPONDENCE

2 D.1 Section 7 Consultation

3 D.1.1 Federal Agency Obligations Under ESA Section 7 

4 As a Federal agency, the U.S. Nuclear Regulatory Commission (NRC) must comply with the 

5 Endangered Species Act of 1973 (ESA), as amended (16 U.S.C. 1531 et seq.), as part of any 

6 action authorized, funded, or carried out by the agency, such as the proposed agency action 

7 that this environmental impact statement (EIS) evaluates: whether to issue a construction 

8 permit under 10 CFR Part 50 that would allow construction of a medical radioisotope production 

9 facility. Under section 7 of the ESA, the NRC must consult with the U.S. Fish and Wildlife 

10 Service (FWS) and the National Marine Fisheries Service (NMFS) (referred to jointly as “the 

11 Services” and individually as “Service”), as appropriate, to ensure that the proposed agency 

12 action is not likely to jeopardize the continued existence of any endangered or threatened 

13 species or result in the destruction or adverse modification of designated critical habitat. 

14 The ESA and the regulations that implement ESA section 7, 50 CFR Part 402, “Interagency 

15 cooperation—Endangered Species Act of 1973, as amended,” describe the consultation 

16 process that Federal agencies must follow in support of agency actions. As part of this process, 

17 the Federal agency shall either request that the Services provide a list of any listed or proposed 

18 species or designated or proposed critical habitats that may be present in the action area or 

19 request that the Services concur with a list of species and critical habitats that the Federal 

20 agency has created (50 CFR 402.12(c)). If it is determined that any such species or critical 

21 habitats may be present, the Federal agency is to prepare a biological assessment to evaluate 

22 the potential effects of the action and determine whether the species or critical habitat are likely 

23 to be adversely affected by the action (50 CFR 402.12(a); 16 U.S.C. 1536(c)). Furthermore, 

24 biological assessments are required for any agency action that is a “major construction activity” 

25 (50 CFR 402.12(b)), which the ESA regulations define to include major Federal actions 

26 significantly affecting the quality of the human environment under the National Environmental 

27 Policy Act of 1969, as amended (42 U.S.C. 4321 et seq.; herein referred to as NEPA) 

28 (50 CFR 402.02).

29 Federal agencies may fulfill their obligations to consult with the Services under ESA section 7 

30 and to prepare a biological assessment in conjunction with the interagency cooperation 

31 procedures required by other statutes, including NEPA (50 CFR 402.06(a)). In such cases, the 

32 Federal agency should include the results of the ESA section 7 consultation in the NEPA 

33 document (50 CFR 402.06(b)). Accordingly, Section D.1.2 describes the biological assessment 

34 prepared for the proposed agency action evaluated in this EIS, and Section D.1.3 describes the 

35 chronology and results of the ESA section 7 consultation.

36 D.1.2 Biological Assessment

37 The NRC considers this EIS to fulfill its obligation to prepare a biological assessment under ESA

38 section 7. Accordingly, the NRC did not prepare a separate biological assessment for the 

39 proposed NWMI facility construction permit.

40 Although the contents of a biological assessment are at the discretion of the Federal agency 

41 (50 CFR 402.12(f)), the ESA regulations suggest information that agencies may consider for 

42 inclusion. The NRC has considered this information in the following EIS sections.
Appendix D

D-2

1 Section 3.5 describes the action area and the Federally listed and proposed species and 

2 designated and proposed critical habitat that have the potential to be present in the action area. 

3 This section includes information pursuant to 50 CFR 402.12(f)(1), (2), and (3).

4 Section 4.5 provides an assessment of the potential effects of the proposed construction, 

5 operations, and decommissioning of the NWMI facility on the species and critical habitat present 

6 and the NRC’s effect determinations, which are consistent with those identified in Section 3.5 of 

7 the Endangered Species Consultation Handbook (FWS and NMFS 1998). The NRC also 

8 addresses cumulative effects and alternatives to the proposed action. This section includes 

9 information under 50 CFR 402.12(f)(4) and (5).

10 D.1.3 Chronology of ESA Section 7 Consultation

11 Upon receipt of NWMI’s construction permit application, the NRC staff considered whether any 

12 Federally listed, proposed, or candidate species or designated or proposed critical habitats may 

13 be present in the action area (as defined at 50 CFR 402.02) for the proposed construction, 

14 operations, and decommissioning of the NWMI facility. No species under the NMFS’s 

15 jurisdiction occur within the action area. Therefore, the NRC staff did not consult with the 

16 NMFS. With respect to species under the FWS’s jurisdiction, the NRC staff requested 

17 information from FWS on Federally listed, proposed, and candidate species and critical habitat

18 that may be in the vicinity of the NWMI site and the one alternative site, in accordance with the 

19 ESA section 7 regulations at 50 CFR 402.12(c). The NRC staff requested this information 

20 through the FWS’s Information for Planning and Conservation (IPaC) database system 

21 (FWS 2015a, 2016). Based on this inquiry, the FWS provided a letter dated 

22 November 20, 2015, which identified threatened, endangered, proposed, and candidate 

23 species, as well as proposed and final designated critical habitat, that may occur within the 

24 proposed Discovery Ridge site and/or may be affected by the proposed NWMI facility. In 

25 addition, the NRC staff called FWS to confirm the accuracy of the species list, as suggested in 

26 the November 20, 2015, letter (NRC 2015e). During that call, FWS stated that it did not have 

27 any additional comments regarding the project other than those stated in its November 20, 2015 

28 letter (NRC 2015e). In Section 3.5, the NRC staff concludes that no ESA-protected, proposed, 

29 or candidate species or designated or proposed critical habitats are likely to occur in the action 

30 area; and Section 4.5 concludes that the proposed action would have no effect on any 

31 ESA-protected, proposed, or candidate species or designated or proposed critical habitats. The 

32 FWS (2013) does not typically provide its concurrence with “no effect” determinations by 

33 Federal agencies. Thus, the ESA does not require further informal consultation or the initiation 

34 of formal consultation with the FWS for the proposed NWMI construction permit. Nonetheless, 

35 because this EIS constitutes the NRC’s biological assessment, the NRC staff will submit a copy 

36 of this EIS, upon its issuance, to the FWS for review in accordance with 50 CFR 402.12(j).

37 Table D–1 lists the letters, e-mails, and other correspondence related to the NRC’s ESA

38 obligations with respect to its review of the NWMI construction permit application. 

39 Table D–1. Section 7 Consultation Correspondence

Date Description ADAMS No.(a)

November 20, 2015 List of ESA-protected species that may occur within the 

proposed Discovery Ridge site

ML15335A002

December 3, 2015 Conference call with NRC and FWS to confirm list of 

ESA-protected species that may occur within the 

proposed Discovery Ridge site

ML15362A225
Appendix D

D-3

Date Description ADAMS No.(a)

April 15, 2016 List of ESA-protected species that may occur within the 

University of Missouri Research Reactor alternative site

ML16117A529

(a) These documents can be accessed through the NRC’s Agencywide Documents Access and Management 

System (ADAMS) at the following URL: http://adams.nrc.gov/wba/.

1 D.2 Essential Fish Habitat Consultation

2 The NRC must comply with the Magnuson–Stevens Fishery Conservation and Management 

3 Act, as amended (MSA) (16 U.S.C. 1801 et seq.), for any actions authorized, funded, or 

4 undertaken, or proposed to be authorized, funded, or undertaken that may adversely affect any 

5 essential fish habitat identified under the MSA.

6 In Section 3.5 of this EIS, the NRC staff concludes that NMFS has not designated essential fish 

7 habitat under the MSA within the vicinity of the proposed Discovery Ridge site and that the 

8 proposed NWMI construction permit would have no effect on essential fish habitat. Thus, the 

9 MSA does not require the NRC to consult with NMFS for the NWMI construction permit.

10 D.3 Section 106 Consultation

11 National Historic Preservation Act of 1966 Consultation

12 The National Historic Preservation Act of 1966, as amended (NHPA) (54 U.S.C. 300101 

13 et seq.), requires Federal agencies to consider the effects of their undertakings on historic 

14 properties and consult with applicable State and Federal agencies, Tribal groups, and 

15 individuals and organizations with a demonstrated interest in the undertaking before taking 

16 action. Historic properties are defined as resources eligible for listing on the National Register 

17 of Historic Places. The historic preservation review process (Section 106 of the NHPA) is 

18 outlined in regulations issued by the Advisory Council on Historic Preservation (ACHP) in 

19 36 CFR Part 800. In accordance with 36 CFR 800.8(c), the NRC has indicated its intent to 

20 comply with Section 106 through the NEPA process.

21 Table D–2 lists the chronology of consultations and consultation documents related to the NRC 

22 Section 106 review.

23 Table D–2. NHPA Correspondence

Date Description ADAMS No.(a)

November 19, 2015 NRC Letter to State Historic Preservation Office, Missouri 

Department of Natural Resources, Request for Scoping 

Comments Concerning the Northwest Medical Isotopes, 

LLC Radioisotope Production Facility Application 

Environmental Review

ML15314A686

November 19, 2015 NRC Letter to Advisory Council on Historic Preservation,

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope Production 

Facility Application Review

ML15314A363
Appendix D

D-4

Date Description ADAMS No.(a)

November 20, 2015 NRC Letter to Absentee-Shawnee Tribe of Indians of 

Oklahoma, Request for Scoping Comments Concerning 

the Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Caddo Nation of Oklahoma, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility Application 

Review

ML15316A036

November 20, 2015 NRC Letter to Cherokee Nation, Request for Scoping 

Comments Concerning the Northwest Medical Isotopes, 

LLC Radioisotope Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Cheyenne and Arapaho Tribes, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility Application 

Review

ML15316A036

November 20, 2015 NRC Letter to The Chickasaw Nation, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility Application 

Review

ML15316A036

November 20, 2015 NRC Letter to The Choctaw Nation of Oklahoma, Request 

for Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility Application 

Review

ML15316A036

November 20, 2015 NRC Letter to Citizen Potawatomi Nation, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility Application 

Review

ML15316A036

November 20, 2015 NRC Letter to Delaware Nation, Request for Scoping 

Comments Concerning the Northwest Medical Isotopes, 

LLC Radioisotope Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Eastern Shawnee Tribe of Oklahoma, 

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope Production 

Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Iowa Tribe of Kansas and Nebraska, 

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope Production 

Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Iowa Tribe of Oklahoma, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility Application 

Review

ML15316A036

November 20, 2015 NRC Letter to Miami Tribe of Oklahoma, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility Application 

Review

ML15316A036
Appendix D

D-5

Date Description ADAMS No.(a)

November 20, 2015 NRC Letter to The Muscogee (Creek) Nation, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility Application 

Review

ML15316A036

November 20, 2015 NRC Letter to Omaha Tribe of Nebraska, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility Application 

Review

ML15316A036

November 20, 2015 NRC Letter to The Osage Nation, Request for Scoping 

Comments Concerning the Northwest Medical Isotopes, 

LLC Radioisotope Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Otoe-Missouria Tribe of Indians, Oklahoma, 

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope Production 

Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Pawnee Nation of Oklahoma, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility Application 

Review

ML15316A036

November 20, 2015 NRC Letter to Peoria Tribe of Indians of Oklahoma, 

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope Production 

Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Ponca Tribe of Indians of Oklahoma, 

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope Production 

Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Ponca Tribe of Nebraska, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility Application 

Review

ML15316A036

November 20, 2015 NRC Letter to Prairie Band Potawatomi Nation, Request 

for Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility Application 

Review

ML15316A036

November 20, 2015 NRC Letter to The Quapaw Tribe of Indians, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility Application 

Review

ML15316A036

November 20, 2015 NRC Letter to Sac and Fox Nation of Missouri in Kansas 

and Nebraska, Request for Scoping Comments 

Concerning the Northwest Medical Isotopes, LLC 

Radioisotope Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Sac and Fox Nation, Oklahoma, Request 

for Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility Application 

Review

ML15316A036
Appendix D

D-6

Date Description ADAMS No.(a)

November 20, 2015 NRC Letter to Sac and Fox Tribe of the Mississippi in 

Iowa, Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope Production 

Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Shawnee Tribe, Request for Scoping 

Comments Concerning the Northwest Medical Isotopes, 

LLC Radioisotope Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to United Keetoowah Band of Cherokee 

Indians of Oklahoma, Request for Scoping Comments 

Concerning the Northwest Medical Isotopes, LLC 

Radioisotope Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Winnebago Tribe of Nebraska, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility Application 

Review

ML15316A036

November 20, 2015 NRC Letter to Wyandotte Nation, Request for Scoping 

Comments Concerning the Northwest Medical Isotopes, 

LLC Radioisotope Production Facility Application Review

ML15316A036

November 20, 2015 NRC Letter to Kaw Nation, Oklahoma, Request for 

Scoping Comments Concerning the Northwest Medical 

Isotopes, LLC Radioisotope Production Facility Application 

Review

ML15316A036

November 20, 2015 NRC Letter to Yankton Sioux Tribe of South Dakota, 

Request for Scoping Comments Concerning the 

Northwest Medical Isotopes, LLC Radioisotope Production 

Facility Application Review

ML15316A036

December 1, 2015 Pawnee Nation of Oklahoma, Request for Section 106 

Consultation and Review for Proposed Construction 

located Discovery Ridge Park, Columbia, Boone County, 

MO

ML16020A338

December 7, 2015 Quapaw Tribe of Oklahoma Letter to NRC, Scoping 

Comments Concerning the Northwest Medical Isotopes, 

LLC Radioisotope Production Facility Review

ML16020A339

December 9, 2015 State Historic Preservation Office, Missouri Department of 

Natural Resources Letter to NRC

ML16020A340

December 9, 2015 United Keetoowah Band of Cherokee Indians in Oklahoma 

email to NRC

ML16049A297

December 10, 2015 Miami Tribe of Oklahoma email to NRC ML16056A421

December 28, 2015 Tribal correspondence to NRC* ML16210A477

December 29, 2015 Tribal correspondence to NRC* ML16077A324

(a) These documents, with the exception of those marked with an asterisk, are publicly available and can be 

accessed through the NRC’s Agencywide Documents Access and Management System (ADAMS) at the 

following URL: http://adams.nrc.gov/wba/. Documents marked with an asterisk are not publicly available at the 

request of the sender.
Appendix D

D-7 

1 D.4 References

2 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

3 production and utilization facilities.”

4 36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

5 Part 800, “Protection of historic properties.”

6 50 CFR Part 402. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 402, 

7 “Interagency cooperation—Endangered Species Act of 1973, as amended.”

8 [ESA] Endangered Species Act of 1973, as amended. 16 U.S.C. §1531 et seq. 

9 [FWS] U.S. Fish and Wildlife Service. 2013. “Endangered Species Program: What We Do: 

10 Consultations: Frequently Asked Questions.” July 15, 2013. Available at 

11 <http://www.fws.gov/endangered/what-we-do/faq.html#8> (accessed 24 April 2016).

12 [FWS] Fish and Wildlife Service. 2015. Letter from A. Salveter, FWS, to NRC, Subject: List of 

13 threatened and endangered species that may occur in your proposed project location, and/or 

14 may be affected by your proposed project. Consultation Code: 03E14000-2016-SLI-0314. 

15 November 20, 2015. ADAMS No. ML15335A002.

16 [FWS] Fish and Wildlife Service. 2016. Information for Planning and Conservation (IPaC) 

17 Report for Boone County, Missouri Project. ADAMS No. ML16117A529. 

18 [FWS and NMFS] U.S. Fish and Wildlife Service and National Marine Fisheries Service. 1998. 

19 Endangered Species Consultation Handbook: Procedures for Conducting Consultation and 

20 Conference Activities Under Section 7 of the Endangered Species Ac. March 1998. 315 p. 

21 Available at <http://www.fws.gov/endangered/esa-library/pdf/esa_section7_handbook.pdf>

22 (accessed 24 April 2016).

23 [MSA] Magnuson–Stevens Fishery Conservation and Management Act, as amended. 

24 16 U.S.C. §1801 et seq. 

25 [NEPA] National Environmental Policy Act of 1969, as amended. 42 U.S.C. §4321 et seq. 

26 [NRC] U.S. Nuclear Regulatory Commission. 2015. Teleconference Summary with M. Moser, 

27 NRC, and A. Salveter, FWS. Subject: Scoping Comments Regarding the Environmental 

28 Review for the Northwest Medical Isotopes, LLC (NWMI) Construction Permit Application. 

29 December 3, 2015. ADAMS No. ML15362A225. 

30 [NHPA] National Historic Preservation Act of 1966, as amended. 54 U.S.C. §300101 et seq.





NUREG-2209

Draft

Environmental Impact Statement for the Construction Permit for the Northwest 

Medical Isotopes Radioisotope Production Facility