Environmental Impact 

Statement for the Construction 

Permit for the Northwest 

Medical Isotopes Radioisotope 

Production Facility

Final Report

Office of Nuclear Reactor Regulation

NUREG-2209

Environmental Impact 

Statement for the Construction 

Permit for the Northwest 

Medical Isotopes Radioisotope 

Production Facility

Final Report 

Manuscript Completed: May 2017

Date Published: May 2017 

Office of Nuclear Reactor Regulation

NUREG-2209

iii

COVER SHEET

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

Regulation.

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

Isotopes, LLC (NWMI) Medical Radioisotope Production Facility, Final Report

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

Missouri.

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

Division of License Renewal

U.S. Nuclear Regulatory Commission (NRC)

Office of Nuclear Reactor Regulation

Mail Stop O-11F1

11555 Rockville Pike

Rockville, MD 20852

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

E-mail: David.Drucker@nrc.gov

ABSTRACT

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

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

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

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

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

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

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

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

unless safety issues mandate otherwise, is to issue a construction permit to NWMI. The NRC

staff based its recommendation on the following factors:

• the NRC staff’s review of the NWMI Environmental Report and responses to 

requests for additional information;

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

officials;

• the NRC staff’s independent environmental review; and

• the NRC staff’s consideration of public comments.

v

TABLE OF CONTENTS

ABSTRACT.............................................................................................................................. iii

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

LIST OF FIGURES .................................................................................................................. xv

LIST OF TABLES.................................................................................................................. xvii

EXECUTIVE SUMMARY ........................................................................................................ xxi

ABBREVIATIONS AND ACRONYMS ................................................................................... xxv

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2.7 Production and Processing of Radioactive and Nonradioactive Waste........... 2-15

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

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

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

vi

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

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

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

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

2.8 Storage and Transportation of Radioactive and Nonradioactive 

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

2.8.1 Storage and Transportation ............................................................. 2-20

2.8.1.1 Radioactive Waste and Other Materials ......................... 2-20

2.8.1.2 Nonradioactive Waste and Other Materials .................... 2-21

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

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

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

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

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

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

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

3.1.1.4 Agricultural Resources and Facilities................................ 3-5

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

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

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

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

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

3.3 Geologic Environment.................................................................................... 3-18

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

3.5.4.1 Endangered Species Act................................................ 3-42

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

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

vii

3.5.4.4 Magnuson–Stevens Fishery Conservation and 

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

3.5.4.5 State Parks and Conservation Areas.............................. 3-46

3.6 Historic and Cultural Resources..................................................................... 3-47

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

3.6.1.1 Paleo-Indian Period (11,500 to 9,900 B.P.) .................... 3-48

3.6.1.2 Archaic Period (9,900 to 3,000 B.P.) .............................. 3-48

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

3.6.1.4 Mississippian Period (1,000 to 400 B.P.)........................ 3-49

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

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

3.6.1.6 Recent History – Columbia............................................. 3-50

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

3.6.2 Historic and Cultural Resources ...................................................... 3-51

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

3.7.1 Population Growth Rates and Projections ....................................... 3-52

3.7.2 Race and Ethnicity........................................................................... 3-52

3.7.3 Transient Population........................................................................ 3-54

3.7.4 Labor Force, Employment, and Unemployment............................... 3-54

3.7.5 Income and Wages and Poverty...................................................... 3-55

3.7.6 Housing ........................................................................................... 3-56

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

3.7.8 Taxes .............................................................................................. 3-57

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

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

3.7.11 Public Services................................................................................ 3-59

3.8 Human Health................................................................................................ 3-60

3.8.1 Sensitive Receptors......................................................................... 3-60

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

3.8.2.1 Pathways for Human Exposure to Radiation and 

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

3.8.2.2 Major Sources and Levels of Radiation .......................... 3-62

3.8.2.3 Regulations Governing Dose from Human-Made 

Sources of Radiation...................................................... 3-63

3.8.3 Chemical Hazards ........................................................................... 3-64

3.8.4 Other Hazards ................................................................................. 3-65

3.9 Transportation Environments ......................................................................... 3-65

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

3.9.2 Airports............................................................................................ 3-66

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

3.10 Research Reactors ........................................................................................ 3-67

3.10.1 University of Missouri Research Reactor......................................... 3-67
Table of Contents

viii

3.10.2 Oregon State University Research Reactor..................................... 3-71

3.10.3 Third Research Reactor................................................................... 3-73

4.0 ENVIRONMENTAL IMPACTS OF CONSTRUCTION, OPERATIONS, AND 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

4.2.1.3 Decommissioning............................................................. 4-9

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

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

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

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

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

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

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

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

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

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

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

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

4.4.1.3 Decommissioning........................................................... 4-17

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

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

4.4.2.2 Operations ..................................................................... 4-19

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

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

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

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

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

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

4.6 Historic and Cultural Resources..................................................................... 4-24
Table of Contents

ix

4.6.1 Historic and Cultural Resources ...................................................... 4-24

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

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

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

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

4.6.3.3 Decommissioning........................................................... 4-27

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

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

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

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

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

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

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

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

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

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

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

4.7.2.4 Public and Educational Services .................................... 4-29

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

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

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

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

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

4.7.3.4 Public and Educational Services .................................... 4-30

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

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

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

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

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

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

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

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

4.8.3 Decommissioning ............................................................................ 4-35

4.8.3.1 Radiological ................................................................... 4-35

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

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

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

4.9.2 Nonradioactive Waste ..................................................................... 4-38

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

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

4.10.2 Operations....................................................................................... 4-39
Table of Contents

x

4.10.3 Decommissioning ............................................................................ 4-40

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

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

4.11.2 Hazardous Chemical Accidents....................................................... 4-45

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

4.12.1 Construction .................................................................................... 4-54

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

4.12.3 Decommissioning ............................................................................ 4-55

4.13 Research Reactors ........................................................................................ 4-55

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

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

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

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

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

4.13.2.2 Irradiation Services ........................................................ 4-59

4.13.3 Third Research Reactor................................................................... 4-62

4.13.3.1 Facility Modifications and Equipment Refurbishment...... 4-62

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

4.14 Cumulative Impacts ....................................................................................... 4-65

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

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

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

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

4.14.2.1 Air Quality ...................................................................... 4-72

4.14.2.2 Noise.............................................................................. 4-73

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

4.14.4 Water Resources............................................................................. 4-75

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

4.14.4.2 Groundwater .................................................................. 4-78

4.14.5 Ecological Resources ...................................................................... 4-79

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

4.14.7 Socioeconomics .............................................................................. 4-81

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

4.14.8.1 Radiological Impacts ...................................................... 4-82

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

4.14.9 Waste Management ........................................................................ 4-84

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

4.14.9.2 Nonradioactive Waste .................................................... 4-85

4.14.10 Accidents......................................................................................... 4-86

4.14.10.1 Radiological Accidents ................................................... 4-86

4.14.10.2 Nonradiological Accidents .............................................. 4-87
Table of Contents

xi

4.14.11 Transportation ................................................................................. 4-87

4.14.12 Environmental Justice ..................................................................... 4-88

4.14.13 Summary......................................................................................... 4-89

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

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

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

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

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

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

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

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

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

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

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

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

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

5.2.2.7 Socioeconomics............................................................. 5-26

5.2.2.8 Human Health ................................................................ 5-26

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

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

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

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

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

5.3 Alternative Technologies................................................................................ 5-53

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

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

5.3.1.2 Secondary Screening..................................................... 5-55

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

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

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

5.3.2.3 Geologic Environment.................................................... 5-59

5.3.2.4 Water Resources ........................................................... 5-61

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

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

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

5.3.2.8 Human Health ................................................................ 5-65

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

5.3.2.10 Transportation................................................................ 5-66

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

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

5.3.2.13 Cumulative Impacts........................................................ 5-68
Table of Contents

xii

5.3.3 Subcritical Fission Technology ........................................................ 5-68

5.3.3.1 Land Use and Visual Resources .................................... 5-69

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

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

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

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

5.3.3.6 Historic and Cultural Resources ..................................... 5-78

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

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

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

5.3.3.10 Transportation................................................................ 5-80

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

5.3.3.12 Environmental Justice .................................................... 5-81

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

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

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

5.4.2 Cost-Benefit Conclusions ................................................................ 5-87

5.5 Alternatives Summary.................................................................................... 5-88

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

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

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

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

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

6.3.2 Relationship Between Local Short-Term Uses of the 

Environment and the Maintenance and Enhancement of LongTerm Productivity............................................................................... 6-9

6.3.3 Irreversible and Irretrievable Commitment of Resources ................. 6-10

6.3.4 Unresolved Conflicts........................................................................ 6-11

6.4 Recommendation........................................................................................... 6-11

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

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

9.0 DISTRIBUTION LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS 

TO WHOM COPIES OF THIS ENVIRONMENTAL IMPACT STATEMENT ARE 

SENT........................................................................................................................... 9-1
Table of Contents

xiii

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

xv

LIST OF FIGURES

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Figure 3–14. Location of Sensitive Receptors Near the Proposed Discovery Ridge Site....... 3-61

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

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

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

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

xvii

LIST OF TABLES

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

Construction, Operations, and Decommissioning of the Proposed NWMI 

Facility............................................................................................................... xxiii

Estimated Construction Materials Requirements ................................................ 2-5

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

Water Requirements for NWMI Facility............................................................. 2-12

Gaseous Radioactive Effluents ........................................................................ 2-16

Summary of Chemical Inventory and Quantity at the Proposed NWMI 

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

Summary of Land Use and Land Cover Within the Proposed Discovery 

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

Annual and Seasonal Precipitation and Temperature Data for Columbia, 

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

Ambient Air Quality Standards ......................................................................... 3-13

Boone County Air Emissions Inventory, Tons/Year .......................................... 3-14

Common Noise Sources and Noise Levels ...................................................... 3-16

Summary of Boring Log B-5 Completed in the Vicinity of the Proposed 

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

Groundwater Use in Boone County, 2010 ........................................................ 3-35

Typical Wildlife That May Occur on or near the Proposed Site ......................... 3-41

Federally and State-Listed Species That May Occur on or near the 

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

Migratory Birds of Concern that May Occur near the Proposed Discovery 

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

Boone County Population (1980–2050)............................................................ 3-52

Race and Ethnicity for Columbia and Boone County, Missouri, in 2010............ 3-52

Race and Ethnicity for Columbia and Boone County, Missouri, in 2014............ 3-53

Labor Force, Employment, and Unemployment Rates in Missouri, Boone 

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

Employment by Industry in Boone County for 2014.......................................... 3-55

Median Family Income and Per Capita Income for the City of Columbia, 

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

Housing Unit Characteristics for Boone County and City of Columbia 

in 2014 ............................................................................................................. 3-56

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

Parks within a 5-mi (8-km) Radius of the Proposed NWMI Facility Site ............ 3-58

Public Water Supply Systems in Boone County ............................................... 3-59

Sensitive Receptors from the Discovery Ridge Site.......................................... 3-60

Average Daily Traffic Counts in the Vicinity of the Proposed NWMI 

Facility Site 2013.............................................................................................. 3-66

MURR Ar-41 Effluents...................................................................................... 3-68
List of Tables

xviii

MURR Sanitary Sewer Radioactive Effluents ................................................... 3-69

MURR Solid Low-Level Radioactive Waste Shipments .................................... 3-69

MURR Occupational Doses (Operations Group) .............................................. 3-70

MURR Occupational Doses (Health Physics Group) ........................................ 3-70

MURR Occupational Doses (Shipping Group).................................................. 3-70

OSTR Solid Low-Level Radioactive Waste Shipments ..................................... 3-72

OSTR Occupational Doses .............................................................................. 3-73

Acres of Land Required for Construction of the Proposed NWMI Facility ........... 4-2

Equipment and Activity Parameters During Construction ................................... 4-5

Estimated Emissions During Construction.......................................................... 4-6

Emissions Sources and Estimated Emissions During Operations....................... 4-8

Air Emissions During Decommissioning ............................................................. 4-9

Definition of High- and Intermediate-Consequence Radiological Accidents...... 4-41

Definition of High- and Intermediate-Consequence Chemical Accidents .......... 4-45

NWMI Hazardous Chemical Concentrations .................................................... 4-47

Minority Populations in Census Block Groups Within 5 mi (8 km) of the 

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

Percentage of People and Families in Census Tracts Within 5 mi (8 km) 

of the Discovery Ridge Site Whose Income is Below the Poverty Level ........... 4-53

Past, Present, and Reasonably Foreseeable Future Projects and Other 

Actions Retained for the Cumulative Impacts Analysis – Discovery Ridge ....... 4-66

Cumulative Impacts on Environmental Resources, Including the Impacts 

of the Proposed Project.................................................................................... 4-89

NWMI Site-Selection Scoring Criteria................................................................. 5-6

Average Daily Traffic Counts in the Vicinity of the MURR Site 2013................. 5-28

Minority Populations in Census Block Groups Within 5 mi (8 km) of the 

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

Percentage of People and Families in Census Tracts Within 5 mi (8 km) 

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

Past, Present, and Reasonably Foreseeable Future Projects and Other 

Actions Considered for the Cumulative Impacts Analysis – MURR................... 5-37

Estimated Air Emissions Resulting from Construction of a Linear 

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

Estimated Air Emissions Resulting from Operation of a Linear 

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

Estimated Air Emissions Resulting from Construction of a Subcritical 

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

Estimated Air Emissions Resulting from Operation of a Subcritical 

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

Estimated Air Emissions Resulting from Decommissioning of a 

Subcritical Fission Facility ................................................................................ 5-71

Costs and Benefits of Constructing, Operating, and Decommissioning the 

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

xix

Comparison of Impacts for the Proposed NWMI Facility, Proposed 

Alternative Site, and No-Action......................................................................... 5-86

Comparison of Technologies at the Proposed NWMI Facility in Discovery 

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

Summary of the Environmental Impacts from Construction, Operations, 

and Decommissioning of the Proposed NWMI Facility at the Discovery 

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

Unavoidable Adverse Environmental Impacts .................................................... 6-5

List of Preparers................................................................................................. 8-1

List of Agencies, Organizations, and Persons to Whom Copies of this 

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

Individuals Providing Comments During the Scoping Comment Period..............A-2

Issue Categories ................................................................................................A-2

Table Comments Received Associated with the NWMI Draft EIS.....................A-14

Potentially Applicable Federal Statutes, Regulations, and Orders ......................B-2

Potentially Applicable Missouri State Requirements...........................................B-7

Potentially Applicable City of Columbia and Boone County, Missouri, 

Ordinances and Plans........................................................................................B-8

Permits and Approvals Required for Construction and Operations.....................B-9

Environmental Review Correspondence.............................................................C-1

Section 7 Consultation Correspondence ............................................................D-3

NHPA Correspondence......................................................................................D-4

xxi

EXECUTIVE SUMMARY

BACKGROUND

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

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

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

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

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

construction permit application to include a discussion of connected actions in the

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

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

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

as NEPA). The NRC’s environmental protection regulations that implement NEPA in 

10 CFR Part 51 describe several types of actions that would require an environmental impact 

statement (EIS). The regulation at 10 CFR 51.20 does not specifically identify construction 

permits and operating licenses for medical radioisotope production facilities as an action that 

would require an EIS. However, for the NWMI environmental review, the NRC staff determined 

that an EIS was appropriate to assess the environmental impacts of the proposed action.

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

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

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

this EIS, the NRC staff performed the following:

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

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

September 2015;

• conducted a public meeting on the draft EIS on December 6, 2016, in Columbia,

Missouri;

• reviewed NWMI’s ER and responses to NRC staff requests for additional information; 

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

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

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

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

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

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

Standard Review Plan and Acceptance Criteria”; and

• considered public comments received.

Changes made to the draft EIS in response to comments as well as changes to include updated 

information, minor corrections, and other editorial revisions are marked with a change bar 

(vertical lines) on the side margin of the page.

PROPOSED ACTION

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

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

xxii

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

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

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

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

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

recovery and purification.

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

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

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

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

construction of the facility in accordance with an NRC-issued construction permit, and (3) obtain 

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

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

PURPOSE AND NEED FOR ACTION

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

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

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

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

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

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

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

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

production facility should be constructed and operated.

ENVIRONMENTAL IMPACTS OF CONSTRUCTION, OPERATIONS, AND 

DECOMMISSIONING

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

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

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

interim staff guidance to NUREG–1537, apply: 

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

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

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

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

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

destabilize, important attributes of the resource.

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

important attributes of the resource.

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

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

xxiii

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

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.

ALTERNATIVES

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

to constructing the NWMI facility at the Discovery Ridge site:

• the no-action alternative;

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

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

xxiv

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

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

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

at the Discovery Ridge site (Alternative Technology No.2).

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

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

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

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

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

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

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

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

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

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

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

action.

RECOMMENDATION

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

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

unless safety issues mandate otherwise, is the issuance of a construction permit to NWMI. The 

NRC staff based its recommendation on the following factors:

• the NRC staff’s review of the NWMI ER and responses to requests for additional 

information;

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

officials;

• the NRC staff’s independent environmental review; and

• the NRC staff’s consideration of public comments.
xxv

ABBREVIATIONS AND ACRONYMS

C degree(s) Celsius

F degree(s) Fahrenheit

ac acre(s)

ACHP Advisory Council on Historic Preservation

ADAMS Agencywide Documents Access and Management System

AIHA American Industrial Hygiene Association 

ALOHA Areal Locations of Hazardous Atmospheres 

AEGL Acute Exposure Guideline Level

ALARA as low as is reasonably achievable

APE area of potential effect

AQCR air quality control region

bgs below ground surface

BIA U.S. Bureau of Indian Affairs

BLS U.S. Bureau of Labor Statistics

BMP best management practice

B.P. before present

CAA Clean Air Act

Ci curie

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

cfs cubic feet per second

CH4 methane

cm centimeter

CO carbon monoxide

CO2 carbon dioxide

CO2eq carbon dioxide equivalent

CRMP cultural resource management plan

CWA Clean Water Act

dB decibel(s)

dBA decibels on the A-weighted scale

DBA design-basis accident

DOE U.S. Department of Energy

DOL U.S. Department of Labor
Abbreviations and Acronyms

xxvi

DOT U.S. Department of Transportation

EA environmental assessment

ECHO Enforcement and Compliance History Online 

EIA Energy Information Administration

EIS environmental impact statement

EO Executive Order

EPA U.S. Environmental Protection Agency

ER Environmental Report

ERPG Emergency Response Planning Guideline

ESA Endangered Species Act

FEMA U.S. Federal Emergency Management Agency

FHWA U.S. Federal Highway Administration

FR Federal Register

ft foot (feet)

ft2 square foot (feet)

FWS U.S. Fish and Wildlife Service

gal gallon(s)

GHG greenhouse gas

gpd gallons per day

gpm gallons per minute

GTCC greater than Class C

GWP global warming potential

ha hectare(s)

HAP hazardous air pollutant

HEPA high-efficiency particulate air

HEU highly enriched uranium

HNO3 Nitric Acid

hp horsepower

hr hour(s)

IAEA International Atomic Energy Agency

in. inch

kg kilogram(s)

km kilometer(s)

kph kilometer(s) per hour

km2 square kilometer(s)
Abbreviations and Acronyms

xxvii

L liter(s)

LDN day-night sound intensity level

LEU low enriched uranium

Lpd liter(s) per day

m meter(s)

m2 square meter(s)

m3 cubic meter(s)

m3

/day cubic meter(s) per day

m3

/min cubic meter(s) per minute

mi3

/s cubic mile(s) per second

mg/L milligram(s) per liter

mg/m3 milligram(s) per cubic meter

mgd million gallon(s) per day

m/s meter(s) per second

MAR material at risk

MBTA Migratory Bird Treaty Act

mgd million gallons per day

MHA maximum hypothetical accident

mi mile

min minute

mph mile(s) per hour

mi2 square mile(s)

μg microgram

μm microns

μg/m3 microgram per cubic meter

MDNR Missouri Department of Natural Resources

MMI Modified Mercalli Intensity

MOI maximum offsite individual

mrem milliroentgen equivalent man

MSL mean sea level

mSv millisievert

MT metric ton(s)

MU University of Missouri

MURR University of Missouri Research Reactor

NAAQS National Ambient Air Quality Standards
Abbreviations and Acronyms

xxviii

NaOH Sodium Hydroxide

NCDC National Climatic Data Center

NCES National Center for Education Statistics

NEA Nuclear Energy Agency

NEPA National Environmental Policy Act

NHPA National Historic Preservation Act

NNSA National Nuclear Security Administration

NO2 nitrogen dioxide

NOx nitrogen oxide

NOAA National Oceanic and Atmospheric Administration

NPDES National Pollutant Discharge Elimination System

NPS U.S. National Park Service

NRC U.S. Nuclear Regulatory Commission

NRCS Natural Resources Conservation Service

NRHP National Register of Historic Places

NUREG NRC technical report designation (Nuclear Regulatory 

Commission)

NWMI Northwest Medical Isotopes, LLC

OSHA Occupational Safety and Health Administration

OSTR Oregon State TRIGA Reactor

PAC protective action criterion/criteria

Pb Lead

PGA peak ground acceleration

PM particulate matter

ppb parts per billion

ppm parts per million

PSAR preliminary safety analysis report

PSD prevention of significant deterioration

RCA radiation-controlled area

RCRA Resource Conservation and Recovery Act

ROI region of influence

RM river mile

RPF radioisotope production facility

SER safety evaluation report

SHPO State Historic Preservation Office
Abbreviations and Acronyms

xxix

SIL significant impact level

SNM Society of Nuclear Medicine and Molecular Imaging

SO2 sulfur dioxide

SPCC Spill Prevention, Control, and Countermeasure

SSC species of special concern

TDS total dissolved solids

TEDE total effective dose equivalent

TEEL Temporary Emergency Exposure Limit

TIF Tax Increment Finance

TMDL total maximum daily load

TNM traffic noise model

TPY tons per year

TS technical specification(s)

TSV target solution vessel

μg microgram(s)

μm micron(s)

U.S. United States

U.S.C. United States Code

USCB U.S. Census Bureau

USDA U.S. Department of Agriculture

USDOI U.S. Department of Interior

USGCRP U.S. Global Change Research Program

USGS U.S. Geological Service

VOC volatile organic compound(s)

WWTP Wastewater Treatment Plant

yd3 cubic yard(s)

Y-12 Y-12 National Security Complex

1-1

1.0 INTRODUCTION

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

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

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

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

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

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

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

connected actions in its Environmental Report (ER) in response to a letter from the NRC 

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

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

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

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

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

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

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

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

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

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

(NRC 2012).

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

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

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

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

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

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

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

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

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

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

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

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

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

EIS for the issuance of a license that authorizes possession and use of special nuclear material 

(SNM) for processing and fuel fabrication and for scrap recovery.

1.1 Background

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

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

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

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

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

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

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

Council 2009):

• bone scans,

• lung perfusion imaging,
Introduction

1-2

• kidney scans and functional imaging,

• liver scans,

• cardiac perfusion imaging,

• brain perfusion imaging,

• gall bladder function imaging,

• blood pool imaging, and

• thyroid and salivary gland imaging.

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

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

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

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

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

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

facilities (National Research Council 2009). In addition to issues of production reliability and the 

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

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

Research Council 2009).

1.2 Proposed Federal Action

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

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

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

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

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

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

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

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

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

requirements, (2) substantially complete construction of the facility in accordance with an 

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

submit an application for an operating license, the NRC staff would prepare a supplement to this 

EIS in accordance with 10 CFR 51.95(b).
Introduction

1-3

1.3 Purpose and Need for the Proposed Federal Action

The purpose of and need for this proposed Federal 

action is to provide a medical radioisotope production 

option that could help meet the need for a domestic 

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

United States has relied on imported medical 

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

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

about 50,000 medical procedures daily in the United 

States. Global shortages of medical radioisotopes in 

the last decade have highlighted the need for prompt 

action to ensure a reliable domestic supply. Demand in 

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

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

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

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

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

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

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

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

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

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

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

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 

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

1.4 U.S. Nuclear Regulatory Commission Environmental Review

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

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

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

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

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

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

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

construction permit.

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

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

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

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

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

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

SMALL, MODERATE, and LARGE, as defined below.

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

destabilize nor noticeably alter any important attribute of the resource.

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

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

LARGE: Environmental effects are clearly 

noticeable and are sufficient to destabilize 

important attributes of the resource.

On November 7, 2014, NWMI submitted its ER

with Part 1 of its application for a construction 

permit. By letter dated February 5, 2015, NWMI 

withdrew and resubmitted Part 1 of its

construction permit application to include a 

discussion of connected actions in its ER in 

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

NWMI 2015b). After reviewing Part 1 of the application for sufficiency, on June 8, 2015, the 

NRC staff published a Notice of Acceptance for Docketing in the Federal Register 

(80 FR 32418). On November 18, 2015, the NRC staff published a Federal Register notice 

(80 FR 72115) of its intent to prepare an EIS and conduct a scoping process. This notice began 

the 45-day scoping period. On December 8, 2015, the NRC held a public scoping meeting in 

Columbia, Missouri. The NRC’s report entitled, “Summary of the Public Scoping Meeting 

Conducted Related to the Review of the Proposed Northwest Medical Isotopes, LLC 

Radioisotope Production Facility,” presents the comments received during the scoping process

(NRC 2016a). In September 2015, the NRC staff conducted a site audit at the proposed and 

alternative NWMI facility sites to verify information in NWMI’s ER. During the site audit, the 

NRC staff met with NWMI personnel; reviewed specific documentation; and toured the proposed 

site, the alternative site, and the University of Missouri Research Reactor, one of the reactors 

where NWMI plans to have its targets irradiated (NRC 2015b).

Figure 1–1 shows the major milestones in the public review of an EIS. After the scoping period

and the site audit, the NRC staff compiled its findings in a draft EIS (NRC 2016g). The public 

comment period for the draft EIS was from November 10, 2016, through December 29, 2016

(81 FR 79019). The draft EIS was available for public comment for 49 days. During this time, 

the NRC staff hosted a public meeting and collected public comments (See Appendix A.2 for 

comments received and NRC responses). Based on the information gathered, the NRC staff 

amended the draft EIS as necessary and then published this final EIS. Changes made to the 

draft EIS in response to comments as well as changes to include updated information, and 

minor corrective and other editorial revisions are marked with a change bar (vertical lines) on 

the side margin of the page.

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

Figure 1–1. Environmental Review Process

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

1.5 Scope of the EIS

As described in Section 1.2 of the EIS, the 

proposed Federal action is for the NRC to decide 

whether to issue a construction permit under 

10 CFR Part 50 that would allow construction of 

the NWMI facility. CEQ regulations 

implementing NEPA state that the NEPA 

analysis should also include connected actions 

(40 CFR 1508.25). In determining the scope of 

its environmental review for the proposed action, 

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

will discuss connected actions to the proposed 

action (see how actions are connected in text 

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

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

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

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

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

proposes to fabricate low-enriched uranium

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

Licensing of Special Nuclear Material.” This EIS 

will also evaluate the potential environmental 

impacts from operation of the proposed NWMI 

facility that will consist of both the 

10 CFR Parts 50 and 70 activities. Operation of 

NWMI’s proposed facility will depend on LEU 

targets being transferred to and from, and 

irradiated in, one or more research reactors that would apply to the NRC to be authorized, by an 

operating license amendment, to irradiate the NWMI LEU targets. The NRC staff will conduct a 

separate safety review and environmental review of each operating license amendment 

application submitted by these research reactors. However, because Mo-99 production cannot 

occur until research reactors are licensed to irradiate NWMI’s LEU targets and the 

environmental impacts from LEU target irradiation at research reactors has not been previously 

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

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

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

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

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

research reactors in this EIS.

1.6 Preconstruction Activities

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

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

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

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

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

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

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

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.

Scope of the EIS

• Construction, operations, and 

decommissioning of the proposed NWMI 

facility.

• Transportation and irradiation of LEU 

targets at research reactors.
Introduction

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

See NUREG-2183, Environmental Impact Statement for the Construction Permit for the SHINE 

Medical Radioisotope Production Facility (NRC 2015c, 2015d). Section 4.14, “Cumulative 

Impacts,” of the EIS incorporates the impacts from “preconstruction” to satisfy the NRC’s 

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

to preconstruction activities and NRC-authorized construction.

1.7 Consultation and Correspondence

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

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

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

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

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

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

formal consultation processes and the NWMI environmental review process included the 

following:

• Advisory Council on Historic Preservation,

• Boone County Government Center,

• Mid-Missouri Regional Planning Commission,

• Absentee-Shawnee Tribe of Indians of Oklahoma,

• Caddo Nation of Oklahoma,

• Cherokee Nation,

• Cheyenne and Arapaho Tribes,

• The Chickasaw Nation,

• The Choctaw Nation of Oklahoma,

• Citizen Potawatomi Nation,
Introduction

1-8

• Delaware Nation,

• Eastern Shawnee Tribe of Oklahoma,

• Iowa Tribe of Kansas and Nebraska,

• Iowa Tribe of Oklahoma,

• Miami Tribe of Oklahoma,

• Missouri Department of Conservation,

• Missouri Department of Health and Senior Services,

• Missouri Department of Natural Resources,

• Missouri Department of Public Safety,

• Missouri Department of Transportation,

• The Muscogee (Creek) Nation,

• Omaha Tribe of Nebraska,

• The Osage Nation,

• Otoe-Missouria Tribe of Indians, Oklahoma,

• Pawnee Nation of Oklahoma,

• Peoria Tribe of Indians of Oklahoma,

• Ponca Tribe of Indians of Oklahoma,

• Ponca Tribe of Nebraska,

• Prairie Band Potawatomi Nation,

• The Quapaw Tribe of Indians,

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

• Sac and Fox Nation, Oklahoma,

• Sac and Fox Tribe of the Mississippi in Iowa,

• Shawnee Tribe,

• United Keetoowah Band of Cherokee Indians of Oklahoma,

• Winnebago Tribe of Nebraska,

• Wyandotte Nation,

• Kaw Nation, Oklahoma,

• Yankton Sioux Tribe of South Dakota,

• U.S. Fish and Wildlife Service, and

• U.S. Department of Energy.

Chapter 9 provides a list of those to whom copies of this EIS are sent. Appendix C contains a 

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

1-9

1.8 Status of Compliance

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

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

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

proposed facility.

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2.0 PROPOSED FEDERAL ACTION

2.1 Site Location and Layout

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

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

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

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

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

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

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

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

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

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

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

(Figure 2–3):

Radioisotope Production Facility (RPF) Building,

Waste Management Building,

Diesel Generator Building, and

Administration Building.

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

) 

(6,610 square meters (m2

)) (NWMI 2016b). The largest of the proposed buildings would be the 

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

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

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

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

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

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

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

Source: Modified from NWMI 2015a
Proposed Federal Action

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

(8-km) Radius

Source: Modified from NWMI 2015a
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Figure 2–3. Proposed NWMI Facility Site Boundary and Site Layout

Source: Modified from NWMI 2015a

2.2 Construction Activities

The construction period for the proposed NWMI facility would be approximately 17 months and 

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

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

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

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

steel, miscellaneous steel, steel liner, asphalt, stone granular material, roofing materials, and 
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2-5

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

of these materials.

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 (1,300 m3)

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

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

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

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

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

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

estimates that approximately 6,881 m3 (9,000 yd3

) would be excavated (earthwork) to support 

construction activities and that construction equipment necessary to support these activities 

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

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

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

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

landscaped (NWMI 2015c). In addition, approximately 0.1 ha (0.26 ac) of a lot adjacent to the 

proposed Discovery Ridge site would be temporarily affected to support construction activities 

and will be revegetated once construction activities are completed (NWMI 2015c).

2.3 Facility Operations

If the NRC issues NWMI a construction permit and an operating license, the proposed NWMI 

facility would commence full operations upon completion of construction and preoperational 

startup activities. NWMI expects to request an operating license term of 30 years

(NWMI 2015a). During preoperation startup, the proposed NWMI facility would undergo a 

commissioning phase that would involve a series of test operations designed to ensure that the 

facility is functioning as designed (NWMI 2015a). Preoperation startup activities will be 

completed within 3 months (NWMI 2015a). The NWMI Environmental Report (ER) considered 

the impacts associated with the preoperational phase within the operating phase of the 

proposed NWMI facility. Similarly, for the purposes of this environmental analysis, the U.S. 

Nuclear Regulatory Commission (NRC) staff included the activities and impacts of 

preoperational activities as part of the operations phase in the impacts assessment in 

Chapter 4.
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During operations, NWMI plans to obtain low-enriched 

uranium (LEU) metal from the U.S. Department of 

Energy (DOE) Y-12 National Security Complex 

(Y-12 facility) in Oak Ridge, Tennessee (NWMI 2015a). 

The American Medical Isotopes Production Act of 2012 

(42 U.S.C. 2065(c)(3)(A)(ii)) states that DOE shall 

establish a program (uranium lease and take-back 

program) to make LEU available through lease 

contracts for irradiation for the production of 

molybdenum-99 (Mo-99) for medical uses. The lease 

contracts will also provide for the Mo-99 producer 

(e.g., NWMI) to return eligible leased LEU material to 

DOE (DOE 2016; NWMI 2016c, 2016d). In 

January 2016, the DOE’s National Nuclear Security 

Administration established the Uranium Lease and 

Take-Back Program (DOE 2016). For the purposes of this EIS, the NRC staff assumed that 

contracts and approvals necessary for NWMI to obtain LEU would be in place. LEU that NWMI 

determines is not economically viable for the Mo-99 production process will be returned to 

DOE’s Savannah River Site in Aiken, South Carolina, for storage in accordance with the takeback contract. LEU obtained from DOE will be referred to as fresh LEU, and LEU returned to 

DOE will be referred to as take-back LEU throughout this EIS.

Operational activities would require 98 workers and a total of 486 inbound and outbound 

shipments annually. Table 2–2 shows the estimated annual inbound and outbound shipments

between NWMI and DOE, research reactors, radiopharmaceutical distributors, and waste sites. 

NRC regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 71 contain NRC 

requirements for packaging, preparation for shipment, and transportation of licensed radioactive

material. Regulations at 10 CFR 71.5 require licensees that transport licensed radioactive

material outside the site of use (e.g., the proposed NWMI facility) to comply with applicable 

U.S. Department of Transportation (DOT) regulations in 49 CFR Parts 107, 171 through 180, 

and 390 through 397, as appropriate. NWMI stated it will transport radioactive material, 

radioactive waste, and medical isotopes in shipping containers that meet applicable NRC and 

DOT regulations to protect public health and safety (NWMI 2015a).

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).
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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

2.3.1 Radioisotope Production Process Overview

The NWMI process would involve fabricating LEU 

targets at the proposed NWMI facility, shipping 

unirradiated targets to university research reactors, 

irradiating LEU targets at university research reactors, 

returning irradiated targets to NWMI, LEU target 

dissolution, and Mo-99 recovery and purification. The 

proposed NWMI facility will have the capacity to fabricate and process up to 1,104 LEU targets

annually (NWMI 2015a, 2016b, 2016a). Figure 2–4 presents a flow diagram of the process. 

For descriptive purposes of the EIS, NWMI’s process can be divided into five primary stages:

LEU target fabrication;

LEU target irradiation;

irradiated target disassembly and dissolution; 

Mo-99 production (extraction, purification, and shipping); and

uranium recovery and recycle.

As illustrated in Figure 2–4, several sub-processes would occur within each of the five primary 

stages identified above. The following sections present an overview of the key factors 

associated with these processes. Most of the activities, other than LEU target irradiation, would 

take place within a single building, the RPF Building (NWMI 2015a, 2015d). As described in the 

following sections, target fabrication would be conducted using contact-handled equipment 

within the target fabrication area of the RPF building (Figure 2–5). Target disassembly and 

dissolution, Mo-99 extraction and purification, and uranium recovery would be handled remotely 

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

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Figure 2–4. NWMI Radioisotope Production Facility Process

Source: Modified from NWMI 2015a
Proposed Federal Action

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

Production Facility Building

Source: Modified from NWMI 2015d

2.3.1.1 LEU Target Fabrication

The first stage in the NWMI radioisotope production process is fabrication of the LEU target. 

LEU target fabrication would be conducted within the target fabrication area housed within the 

RPF building (see Figure 2–5). This area would contain the process equipment for preparation 

of targets, including concentrators, dissolvers, furnaces, and hardware. This equipment would 

be contact-handled by the operators (NWMI 2015a).

The target fabrication process would begin with the receipt of fresh LEU (special nuclear 

material) from DOE. Fresh LEU would be dissolved in nitric acid to form a uranyl nitrate product 

that is then evaporated to a desired uranium concentration. The uranyl nitrate product would 

then be chilled, mixed with reagents, and treated with heated silicone oil to form a solid LEU 
Proposed Federal Action

2-10

material (gelation broth). The LEU material would be filtered, washed, and reduced to obtain 

the LEU target material.

The LEU target material would then be encapsulated 

(loaded and welded), possibly with helium gas, in metal 

cladding to contain the LEU target material and to form 

the LEU targets. These LEU targets would then 

undergo inspection and quality assurance (QA) checks, 

be packaged and loaded into shielded shipping 

containers for transport to research reactors. 

Transportation from the proposed NWMI facility to each 

research reactor will be via ground transportation.

After the first batch of LEU targets are fabricated from 

fresh LEU, LEU targets will be fabricated using a 

combination of (1) fresh LEU, (2) recovered scrap LEU 

(scrap recovery), and (3) LEU recycled from the 

processing of irradiated targets (NWMI 2015e). LEU 

targets that fail inspection or QA checks, will be 

identified as off-specification uranium targets, and 

subsequently be disassembled and treated as scrap to recover the LEU target material 

(NWMI 2015e, 2016d). If an LEU target is identified as an off-specification uranium target 

because it does not meet target material parameter requirements (e.g., due to deformities), the 

target material will be dissolved in nitric acid within the Target Fabrication System (step 1 

identified in Figure 2–4), to then be used to fabricate targets. If an LEU target is identified as an 

off-specification uranium target because of the presence of chemical impurities in the target 

material, the material will go to the Uranium Recovery and Recycle system (Step 5 identified in 

Figure 2-4 and as discussed in Section 2.3.1.5 below) for recovery and then be used to 

fabricate targets (NWMI 2015e, 2016d).

2.3.1.2 LEU Target Irradiation

Following shipment to licensed research reactors, the LEU targets would undergo neutron 

irradiation in the reactor. This irradiation causes the uranium-235 in the LEU target to fission

and produce Mo-99 and other fission products. NWMI has identified two research reactors, the 

University of Missouri Research Reactor (MURR) and the Oregon State University TRIGA 

Reactor (OSTR), to provide irradiation services. NWMI is also considering use of a third 

research reactor and is performing an analysis to support that selection (NWMI 2015a, 2015c). 

Irradiating LEU targets at the research reactors is considered a connected action, and this EIS 

evaluates the environmental impacts associated with target irradiation at MURR, OSTR, and a 

potential third research reactor to bound this connected action (See Section 1.5 for a discussion 

on connected actions). The potential third research reactor parameters (e.g., distance from the 

proposed NWMI RPF and modifications anticipated to support LEU target irradiation) are based 

on the licensed operating research reactors being considered by NWMI (NWMI 2015a, 2015c).

Annual irradiation capacity at the research reactors is as follows (NWMI 2015a, 2016a, 2016b):

• MURR: 624 LEU targets,

• OSTR: 240 LEU targets, and

• Third Reactor: 240 LEU targets.

Research reactors that plan to irradiate NWMI LEU targets will require facility modifications and 

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.
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will need to separately request an amended operating license from the NRC to allow target 

irradiation services. The NRC staff will conduct a separate safety review and environmental 

review for each license amendment request submitted to the NRC. Section 3.10 of this EIS 

discusses the affected environment of the research reactors and Section 4.13 identifies and 

discusses facility modifications and the potential impacts from irradiation of the LEU targets at 

the research reactors.

Following irradiation, the irradiated LEU targets would be loaded onto DOT shielded shipping 

containers and returned by ground transport to the proposed NWMI facility.

2.3.1.3 Irradiated Target Disassembly and Dissolution

The NWMI irradiated target receipt bay within the RPF building would be used to receive 

irradiated LEU targets (in shipping containers) from the ground transport trailers. The shipping 

containers would be transferred via a bridge crane onto a transfer cart. The transfer cart would 

then be transferred to the RPF hot cell area for target disassembly and dissolution (see

Figure 2–5). Irradiated target processing will occur in shielded hot cells. The hot cells would 

provide remote operation via shielded windows and through wall manipulators that would be 

remotely operated from outside the hot cell.

Within the target disassembly hot cells, irradiated LEU targets would be disassembled by 

puncturing and severing the target in half, and pouring the irradiated LEU material into a transfer 

container. The metal cladding would be disposed of as solid radioactive waste (see 

Section 2.7.1 for a discussion of radioactive waste that would be produced at the proposed 

NWMI facility). The transfer container holding the irradiated LEU material would then be 

transferred from the target disassembly hot cell to the target dissolution hot cell, where the 

irradiated LEU material would be dissolved in a nitric acid solution. This dissolver solution 

would then be diluted, cooled, filtered, and pumped to a tank. An offgas system would be used 

during this stage to capture fission product gases released from the target dissolution process.

2.3.1.4 Mo-99 Extraction, Purification, and Shipping

Extraction and purification of Mo-99 from the dissolver solution would occur within the hot cell

area and involve a series of three Mo-99 ion exchange columns. The dissolver solution would 

be pumped through the first ion exchanger to extract and separate the Mo-99 from the uranium

and other fission products. The Mo-99 and several other isotopes would be absorbed onto the 

ion exchange column media. The uranium and fission product solution that flows through the 

column would then be sent to the uranium recovery and recycle system (see Section 2.3.1.5 

below). The absorbed Mo-99 would be removed from the ion exchange column media to obtain 

a Mo-99 solution. The Mo-99 solution would then be pumped through a second and third ion 

exchange column to undergo chemical adjustments to remove unwanted isotopes and purify the 

Mo-99 solution. The Mo-99 solution would be transferred to small vials that are placed into 

DOT-approved shipping containers and transferred from the hot cell to a shipping/receiving 

room and loading dock. The Mo-99 product would then be transported by air or ground 

transportation, depending on which radiopharmaceutical distributor will be receiving the 

shipment.

2.3.1.5 Uranium Recovery and Recycle

The uranium and fission product solution that is separated from the Mo-99 after it is pumped 

through the ion exchange columns (see Section 2.3.1.4 discussion above) would be processed 

to recover uranium to be used in LEU target fabrication. Before the uranium and fission product 

solution is processed, it would be held in storage tanks to allow short-lived radionuclides to 

decay. The uranium and fission product solution would then be diluted and pumped through 

additional ion exchange columns to separate the remaining fission products from the uranium. 
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The separated fission product solution would then be sent to liquid waste storage tanks, and 

would be treated and processed as discussed in Section 2.7.1.2. The uranium removed from 

the ion exchange columns would be transferred to the target fabrication area, where it would be 

recycled for fabrication of additional LEU targets.

2.4 Power Requirements

Columbia Water and Light would supply electrical power to the proposed NWMI facility 

(NWMI 2015f). Overall, the proposed NWMI facility would annually consume 

10 megawatt-hours. NWMI would equip the facility with an uninterruptible electrical power 

supply (UPS) system to power safety-related systems and equipment for safe shutdown of the 

facility in the event of a loss of offsite power. NWMI would also maintain and test a 1,000 kW 

standby diesel generator to extend the duration of UPS power. The diesel generator will be 

serviced with a 3,785 L (1,000 gal) diesel tank, stored above ground (NWMI 2015a). NWMI 

would use natural gas to supply five boilers. NWMI estimates that the total annual natural gas 

consumption would be 4.3 x 105 million British thermal units (calculated from NWMI 2015c).

2.5 Water Use, Treatment, and Discharges

2.5.1 Water Use

Public utility infrastructure (i.e., electric power, natural gas, water, and sanitary sewer) would 

serve the proposed NWMI facility. Utility providers would extend service lines to connect the 

proposed NWMI facility to existing service lines, including to public water mains. Utility work 

would be performed as part of site preparation (NWMI 2016a). Table 2–3 lists the projected 

water needs to support NWMI facility construction, operations, and decommissioning activities.

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
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Project Phase and Use Volume Required (gal)

 Total (annualized operations)(f) 1,312,000

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

Water would be required for various purposes, such as dust suppression and soil compaction 

during NWMI facility construction. Activities requiring water would include, but would not be 

limited to, site clearing and grading, facility excavation, support facility construction, roadway 

development, and installation of site drainage and utilities. Water would also be required to 

meet the drinking and sanitary needs of the construction workforce. NWMI proposes to use 

portable restroom facilities, serviced by a commercial vendor (NWMI 2015c).

As proposed, operational water use within the RPF building is divided among four key 

systems: the demineralized water system (serving process and related uses), the wash water 

system, the potable and sanitary system (i.e., serving drinking, showers, and toilets), and the 

firewater system (Table 2–3). During operations, wash water would primarily be required for 

cleaning tractor trailers (NWMI 2015a, 2015c).

Facility decommissioning activities would require water for many of the same purposes as 

construction in association with facility demolition and decontamination (see Table 2–3).

2.5.2 Water Treatment

Potable water would be supplied to the NWMI facility through a public utility system to support 

facility operations. The water would require no additional treatment for most facility uses. 

Nonetheless, the water routed to the process systems must be pretreated by the demineralized 

water system. Demineralization, also known as ion exchange, refers to the exchange of ions 

between a solid substance and an aqueous solution (makeup water). This system would supply 

demineralized water to the RPF building facility processes for water addition, flushing, and 

chemical dilution. The demineralized water system can also potentially provide makeup water 

to the steam boilers (NWMI 2015a, 2015c).
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Once charged, the steam boiler and chilled water (cooling) systems are closed-loop and require 

minimal makeup water inputs during operation (NWMI 2015a).

2.5.3 Water Discharges

As stated in the applicant’s ER, the NWMI RPF building is designed to have zero liquid 

discharge from the radiologically controlled area of the facility. No radioactive liquid effluents 

would be discharged to the site environment. RPF radioactive liquid wastes would be physically 

and chemically treated, as necessary, and shipped to an appropriate disposal facility, as further 

described in Section 2.7 (NWMI 2015a, 2015c).

Nonhazardous, nonradioactive wastewater would be discharged to the municipal sanitary sewer

collection and treatment system. This effluent would be primarily comprised of sanitary 

wastewater (NWMI 2015a). Based on the staff’s review of the ER and applicable regulatory 

information, all wastewater conveyed to the municipal system would have to comply with 

influent acceptance criteria and applicable pretreatment requirements, as prescribed in 

applicable ordinances.

2.6 Cooling and Heating Dissipation Systems

2.6.1 Cooling Systems

The NWMI cooling water systems would control the temperature of process equipment at the 

proposed NWMI RPF building from process activities and heat of radioactive decay of fission

products in the hot cells and target fabrication area. The cooling system consists of a primary 

closed-loop, an intermediate heat exchanger, a secondary loop, and air-cooled chillers. Water 

from the primary loop and secondary loop do not come in direct contact because heat from the 

primary loop to the secondary loop is exchanged through the intermediate heat exchanger. The 

secondary loop circulates chilled water from air-cooled chillers located outside the RPF building 

to a heat exchanger that removes heat from the primary loop (i.e., heat is transferred from the 

primary loop to the secondary loop). The secondary loop water is then circulated to the 

air-cooled chillers and heat is dissipated to the environment. The primary closed-loop circulates 

and distributes chilled water from the heat exchanger to various process areas to remove heat; 

this heated water in the primary loop is then circulated back to the heat exchanger to transfer 

heat to the chilled secondary loop water.

2.6.2 Heating Systems

The RPF building would house five natural gas-fired boilers. One set of three boilers will be 

dedicated for the heating, ventilation, and air conditioning system (HVAC). One set of two 

boilers would be dedicated to steam production necessary for process equipment. NWMI 

anticipates that three boilers will be operational at any one time; the remaining two boilers will

be spare (NWMI 2015c). NWMI estimates that the total annual natural gas consumption would 

be 4.3 x 105 million British thermal units (NWMI 2015c).

The process steam system will consist of a primary loop, secondary loop, and intermediate heat 

exchanger. The steam from the boilers flows to an intermediate heat exchanger in the 

secondary loop. The primary loop then circulates and distributes steam from the heat 

exchanger to the various process loads in a closed loop (NWMI 2015a). 
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2.7 Production and Processing of Radioactive and Nonradioactive Waste

Construction, operations, and decommissioning of the NWMI facility would result in the 

generation of radioactive and nonradioactive wastes. The information below describes the 

generation and treatment of radioactive and nonradioactive wastes at the proposed NWMI 

facility, and the waste minimization and pollution prevention measures.

2.7.1 Radioactive Waste

During construction of the proposed NWMI facility, NWMI would not have radioactive material

associated with the production of medical isotopes on site; therefore, no radioactive waste

would be generated during this phase. During operation of the NWMI facility, processes would 

generate liquid, solid, and gaseous radioactive waste during the following activities:

• target fabrication (i.e., dissolution and washing process);

• target disassembly and dissolution (i.e., spent metal cladding, fission product gases);

• Mo-99 recovery and purification (i.e., exchange resin);

• uranium recovery and recycle (i.e., exchange resin, fission product solution);

• waste management system (i.e., liquid waste collection, concentration, solidification, 

and encapsulation process);

• laboratory facility operation (i.e., laboratory glassware, vials, and containers); and

• facility support operations (i.e., potentially radiologically contaminated waste such as 

failed process equipment, decontamination materials, and personal protective 

equipment) (NWMI 2015a, 2016c).

2.7.1.1 Gaseous Waste

Gaseous radioactive waste from routine operations of the proposed NWMI facility would consist 

of radioactive effluents from hot cell processes, including irradiated LEU target dissolution,

uranium recovery and recycling processes, and waste management processes. The design of 

the RPF ventilation system divides the operating areas into pressure zones that draw air from 

the cleanest part of the facility to the most contaminated area. This design protects workers and 

members of the public by minimizing the potential spread of radioactive contamination within the 

facility. Gaseous effluents from the NWMI facility would be released to the environment through 

one of three vent stacks, each of which would release air from a separate zone or zones of the 

RPF building. The gaseous effluents would be treated using two high-efficiency particulate air 

(HEPA) filters to remove radioactive particulates, and carbon absorbers to remove iodine fission

products, before they are released through a vent stack in the RPF building. In addition, gas 

retention systems would temporarily retain effluents containing radioactive gas for a period of 

time before they are released into the environment, to reduce the level of fission product gases 

such as xenon and krypton by decay (NWMI 2015a, 2015g).

NWMI expects gaseous radioactive effluents released into the environment through the vent 

stacks to contain measureable quantities of noble gases (i.e., xenon and krypton). Table 2–4

lists the quantities of three noble gas radionuclides, krypton-85, metastable xenon-131, and 

xenon-133, that NWMI estimates the facility would release annually. Other radioactive noble 

gases, and radioactive iodine, particulates, and tritium could also be present in the airborne 

effluent exhaust. However, the quantities of other radioactive noble gases, and radioactive 

iodine and particulates, in the exhaust would be comparatively small (NWMI 2015a, 2016a). 

Therefore, the NRC staff expects that the total dose contribution from noble gas radionuclides 
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other than krypton-85, metastable xenon-131, and xenon-133, and from radioactive iodine and 

particulates, would also be small. NWMI also determined that the dose from tritium would be 

negligible relative to the dose from other radionuclides released (NWMI 2016c). Consequently, 

only krypton-85, metastable xenon-131, and xenon-133 releases are listed in Table 2–4. NWMI 

would perform monitoring of airborne radionuclide releases, as described in Section 4.8.

Gaseous Radioactive Effluents

Effluent Rate(a)

Krypton-85 58.4 Ci/yr(b)

Metastable 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 2016a

2.7.1.2 Liquid and Solid Waste

Operation of the NWMI facility would result in the production of liquid and solid radioactive 

waste. Liquid radioactive wastes would be generated by target fabrication, target disassembly 

and dissolution, Mo-99 recovery and purification, uranium recovery and recycle, waste 

management, laboratory facility operation, and facility support operations. Most liquid waste 

would be treated, condensed, and processed, at the proposed NWMI facility, into a solid waste

form suitable for offsite disposal (NWMI 2015a, 2015g). NWMI estimates that 

525,000 kilograms (kg) (1,157,426 pounds (lbs)) of solidified liquid waste would be generated 

per year (NWMI 2015c). NWMI estimates that small quantities (approximately 310 liters 

(81.9 gallons) per year) of specialty liquid radioactive wastes such as silicone oil or solvents 

could also be produced, and these wastes would be packaged and shipped for offsite disposal

(NWMI 2015a, 2015g). No liquid radioactive material would be released to the facility environs

as a result of routine operations of the NWMI facility (NWMI 2015a). Liquid waste from process 

operations would be recycled and reused where practicable and, therefore, would be expected 

to reduce the amount of solidified and liquid waste (NWMI 2015a).

Solid radioactive wastes would be generated during target disassembly and dissolution, Mo-99

recovery and purification, uranium recovery and recycle, waste management, laboratory facility 

operation, and facility support operations. Solid waste will be collected into disposal containers, 

and most solid waste will be encapsulated in cement (NWMI 2015a, 2015c, 2016c). Large 

pieces of equipment that may fail and solid waste from laboratory facility operations and facility 

support operations for which encapsulation on site may be difficult will not be encapsulated 

(NWMI 2016c). NWMI estimates that 15,000 kg (33,069 lbs) of encapsulated solid waste and 

an additional 7,000 kg (15,432 lbs) of solid waste not encapsulated, would be generated per 

year (NWMI 2015c, 2016c). A portion of the solid radioactive waste generated from laboratory 

operations at the proposed NWMI facility would be mixed (i.e., both hazardous and radioactive) 

waste. NWMI estimates that less than 760 kg (1,676 lbs) of solid mixed waste would be 

generated per year (NWMI 2015c, 2016c). This quantity of solid mixed waste is included in the 

estimates above. The NRC staff expects that small quantities of specialty liquid waste that are 

produced could also be mixed waste. Any mixed waste that could be produced is included

in the total hazardous waste generation estimate discussed in Section 2.7.2 

(NWMI 2015c, 2016c).
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The NRC classifies solid low-level waste in 10 CFR 61.55 as Class A, Class B, Class C, or 

greater than Class C (GTCC) waste, depending on the types and concentrations of 

radionuclides in the waste. Class A wastes generally contain short-lived radionuclides at 

relatively low concentrations, whereas the half-lives and concentrations of radionuclides in 

Class B and C wastes are progressively higher. Because of the longer half-lives and higher 

concentrations of radionuclides in Class B wastes, these wastes must meet more rigorous 

requirements with regard to their form to ensure stability after disposal (e.g., by adding chemical

stabilizing agents, such as cement, to the waste, or by placing the waste in a disposal container 

or structure that provides stability after disposal). Class C wastes, in addition to meeting 

Class B requirements, must have additional measures at the disposal facility to protect against 

inadvertent intrusion (e.g., by increasing the thickness and hardness of the cover over the waste 

disposal cell). GTCC wastes contain radionuclides at concentrations that are higher than those 

allowed for Class C wastes. For GTCC wastes, near-surface disposal methods are generally 

not acceptable.

Operation of the NWMI facility would generate NRC Class A, Class B, and Class C radioactive 

waste. Of the 525,000 kg (1,157,426 lbs) of solidified liquid waste that would be generated per 

year, NWMI estimates that 300,000 kg (661,386 lbs) is projected to be Class B and/or Class C

waste, and 225,000 kg (496,040 lbs) will be Class A waste (NWMI 2015c, 2016e). NWMI 

estimates that all of the 15,000 kg/yr (33,069 lbs/yr) of encapsulated solid waste will be Class B 

waste, and 7,000 kg/yr (15,432 lbs/yr) of solid waste not encapsulated will be Class A waste 

(NWMI 2015c, 2016c). NWMI expects that the small quantity of specialty liquid wastes that 

could be generated would be Class A waste (NWMI 2015g). NWMI expects that no GTCC 

wastes will be generated (NWMI 2015c).

2.7.2 Nonradioactive Waste

2.7.2.1 Liquid Waste

Nonradioactive liquid waste would be generated during construction. For example, lubricating 

oil, hydraulic oil, and grease might be necessary to assemble various pieces of equipment and 

systems. Chemicals, hazardous liquids, compressed gases, flammable liquids, and oxidizers 

are expected to be on site during construction (NWMI 2015a). NWMI intends to use best 

management practices and personal protective equipment to minimize waste generation and 

exposure (NWMI 2015a).

During operations, nonradioactive liquid waste would include hazardous waste, such as 

chemicals. Table 2–5 lists some of the expected inventory and quantity of chemicals that would 

be used during operation of the proposed NWMI facility at any given time. Some chemicals 

would be in liquid form and would be controlled and confined in containers, tanks, pipes, and hot 

cells. NWMI anticipates that the proposed NWMI facility would generate up to 1,000 kg 

(2,205 lbs) of hazardous waste per month (NWMI 2015c). However, this estimate includes both 

radiological and nonradiological waste as well as solid and liquid waste. Therefore, the liquid 

nonradiological hazardous waste portion will be less than 1,000 kg/month (2,205 lbs/month).

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
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Chemical Quantity(a)

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

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

NWMI would release nonradiological liquid waste meeting municipal treatment standards to the 

Columbia, Missouri, sewer system as a result of activities conducted outside the 

radiologically-controlled area of the facility during routine facility operations (NWMI 2015a). 

NWMI stated it will have administrative controls in place and sampling and monitoring 

processes to ensure that its nonradioactive effluents meet the requirements pertaining to the 

types, quantity, and concentrations specified as acceptable for processing by the Columbia 

wastewater treatment facility. Liquid wastes that do not meet the local municipal wastewater 

treatment standards would be containerized and shipped to a disposal facility (NWMI 2015a). 

Additionally, sanitary wastewater from the proposed NWMI facility would be sent to the 

Columbia sanitary sewer system (NWMI 2015a). Section 4.9.2 of this document contains more 

information on the liquid nonradioactive waste discharges from the proposed NWMI facility.

2.7.2.2 Solid Waste

During construction, operations, and decommissioning, NWMI expects to generate the following 

nonradioactive solid wastes:

• wood,

• metal,

• plastics,

• piping,

• wires,

• batteries,

• office supply waste,

• expired lights and fixtures,
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• packaging waste, and

• solidified used oil and solvents.

The solid hazardous waste that would be generated would be a portion of the up to 1,000 kg 

(2,205 lbs) total (solid and liquid) hazardous waste produced per month that was described in 

Section 2.7.2.1. The proposed facility would also generate approximately 4,056 kg (8,942 lb) of 

solid nonradiological, nonhazardous waste (i.e., municipal waste) per year during operation 

(NWMI 2015c).

NWMI would temporarily collect and store nonradioactive waste on site. NWMI stated that all 

solid hazardous waste would be managed according to applicable regulations (e.g., the 

Resource Conservation and Recovery Act (42 U.S.C. 6901 et seq.) and the Missouri Hazardous 

Waste Management Law (Missouri Revised Statutes 260.350 to 260.430)) (NWMI 2015a).

2.7.3 Waste Minimization and Pollution Prevention Program

NWMI will implement a program of pollution prevention and waste minimization that includes:

• waste minimization and recycling programs specific to various phases of the project 

(e.g., construction and operations);

• employee training and education;

• recognition of employees for improving environmental conditions; and

• requirements and responsibilities to consider pollution prevention and waste 

minimization in day-to-day activities (NWMI 2015a).

Section 4.9 discusses the impacts associated with waste management activities at the proposed 

NWMI facility.

Another facet of NWMI’s waste minimization program will be its recycling and reclamation 

program. This program manages economic and environmental costs and impacts that result in 

cost savings and reduced waste generation. This program will focus primarily on paper, plastic, 

administrative supplies, solvent (trichloroethylene) recovery, uranium, and process water 

(NWMI 2015a).

2.8 Storage and Transportation of Radioactive and Nonradioactive Materials 

and Waste

Construction, operations, and decommissioning of the NWMI facility would result in the 

accumulation of radioactive and nonradioactive wastes. NWMI does not anticipate any 

long-term storage or disposal of radioactive or nonradioactive materials on site (NWMI 2015a). 

NWMI will treat and temporarily store liquid and solid radioactive and nonradioactive waste 

generated as part of the radioisotope production process within the facility until it can ship the 

waste off site for disposal (NWMI 2015a). Transportation of radioactive material, radioactive 

waste, and medical isotopes will be conducted in accordance with NRC and DOT regulations to 

protect public health and safety during the transportation of these materials (NWMI 2015a). The 

additional information provided below describes, as applicable, the generation, storage, waste 

management activities, waste minimization and pollution prevention measures, and 

transportation of radioactive and nonradioactive waste and materials.
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2.8.1 Storage and Transportation

2.8.1.1 Radioactive Waste and Other Materials

After NWMI treats, processes, and packages radioactive waste, NWMI stated it will temporarily 

store radioactive waste at the proposed NWMI facility to allow for decay before offsite transport 

and disposal. NWMI stated it will store Class B and C wastes (solidified liquid waste and 

encapsulated solid wastes) at the proposed NWMI facility for at least 12 weeks of decay time 

before shipment off site. NWMI also may temporarily store some Class A waste at the NWMI 

facility for approximately 12 weeks (NWMI 2015c). Assembled LEU targets would be stored at 

the NWMI facility until they are shipped to research reactors for irradiation. Because of the 

short half-life of Mo-99, minimal Mo-99 product temporary storage would occur at the NWMI 

facility, and it would be shipped out twice per week (NWMI 2015a). Similarly, irradiated targets 

from research reactors would not be stored at the NWMI facility but would be processed to 

recover Mo-99. Radioactive waste and other radioactive material would be stored in a manner 

that would help ensure that no uncontrolled release of radioactive materials from the NWMI 

facility could occur, and if any release did occur, potential occupational and/or public radiation 

exposures would be within 10 CFR Part 20 limits. Additionally, routine personnel exposures to 

radiation would be as low as is reasonably achievable and within 10 CFR Part 20 limits 

(NWMI 2015g). The NWMI facility would have sufficient space to store all radioactive materials 

(NWMI 2015c). Radioactive waste would be stored in both the RPF and in the external waste 

management building (see Figure 2–3 in Section 2.1) (NWMI 2015a). However, only Class A

(low activity concentration) radioactive waste would be stored in the external waste 

management building, and no processing of waste would be performed in that external building 

(NWMI 2016e, 2017), limiting any activity available for potential release from the external 

building.

Radioactive waste generated at the NWMI facility would be transported off site following 

temporary storage. Solid waste would be transported by commercial carrier, on public 

roadways, to Waste Control Specialists in Andrews, Texas (NWMI 2015a, 2015c, 2016c, 2017). 

The NRC staff expects that any small quantities of liquid radioactive waste (i.e., specialty liquid 

wastes that are not solidified) that are generated would similarly be transported to Waste 

Control Specialists. Other radioactive materials shipped to and from the proposed site would 

include fresh LEU, unirradiated LEU targets, irradiated LEU targets, Mo-99 product solution, and 

take-back LEU. Fresh LEU would be shipped, on public roadways, from DOE Y-12 (Oak Ridge, 

Tennessee) to the proposed NWMI facility. Unirradiated and irradiated LEU targets would be 

shipped to and from the proposed NWMI facility and MURR (Columbia, Missouri), OSTR 

(Corvallis, Oregon), and a third research reactor on public roadways. Mo-99 product solution 

would be shipped, on public roadways, to a distributor in Hazelwood, Missouri, or to the 

Columbia Regional Airport in Columbia, Missouri, and then transported by air from the Columbia 

Regional Airport to Logan International Airport in Boston, Massachusetts. From Logan 

International Airport, the Mo-99 will be transported on public roadways to a distributor in 

Billerica, Massachusetts (NWMI 2015a). Take-back uranium would be shipped, on public 

roadways, to DOE’s Savannah River Site in Aiken, South Carolina.

NWMI stated that, when transporting waste and other radioactive materials on public roads, 

NWMI or commercial carriers must comply with the applicable DOT regulations in 

49 CFR Parts 172, 173, 177, and 397, as well as the NRC packaging requirements for 

radioactive material in 10 CFR Part 71 (NWMI 2015a). These regulations help ensure safety on 

the public roadways. NWMI also stated that for transport of Mo-99 product by air, the air carrier 

NWMI chooses also must comply with additional DOT regulations in 49 CFR Part 175 

(NWMI 2015a).
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In accordance with 10 CFR Part 71, waste and other radioactive material shipped to or from the 

NWMI facility would require packaging meeting one of three DOT packaging classifications: low 

specific activity (LSA), Type A, or Type B. An LSA package contains low levels of radioactive 

material. A Type A package meets additional integrity and shielding requirements, and may 

contain higher radioactivity levels than an LSA package. Type B packages meet the highest 

integrity and shielding requirements, and may contain higher radioactivity levels than a Type A 

package. The lettering system for packaging types is not related to the lettering system for 

waste classification.

2.8.1.2 Nonradioactive Waste and Other Materials

NWMI does not anticipate any long-term storage or disposal of nonradioactive (hazardous or 

nonhazardous) materials on site (NWMI 2015a). NWMI stated it will treat and temporarily store 

liquid and solid nonradioactive waste generated as part of the radioisotope production process 

within the facility until it can ship the waste off site for disposal (NWMI 2015a). Nonradioactive 

liquid wastes that do not meet the municipal treatment standards will be containerized, treated 

(reduced and neutralized), and solidified and shipped to a disposal facility. Solid waste will be 

transported off site to either a landfill, storage facility, or recycling or recovery facility, as 

appropriate. For instance, nonhazardous, nonradioactive solid waste (wiring, packaging waste) 

will be shipped to a landfill (NWMI 2015c). NWMI stated hazardous waste will be handled in 

accordance with applicable regulations (e.g., the Resource Conservation and Recovery Act) 

and would be collected by a hazardous waste disposal company for separation, processing, and 

disposal (NWMI 2015c).

NWMI will develop a chemical management and product handling plan. The storage and 

treatment of wastes will be conducted in accordance with this plan. Additionally, onsite storage 

of chemicals and supplies will be performed in accordance with a chemical management and 

product handling plan to ensure that chemicals are properly stored (e.g., non-compatible 

chemicals are stored in separate areas, flammable chemicals and oxidizers are stored in 

separate areas) (NWMI 2015a).

NWMI would temporarily collect and store solid nonradioactive waste on site and then transport 

waste to a landfill, storage facility, or recycling facility. Transportation will be by ground

transportation. NWMI must package and transport hazardous nonradioactive waste in 

accordance with DOT regulations contained in 49 CFR 171-180.

2.9 Facility Decommissioning

The NWMI facility would be decommissioned 

upon completion of its useful life. In accordance 

with 10 CFR Part 50, a licensed production or 

utilization facility that permanently ceases 

operations submits a decommissioning plan or 

report. Also, 10 CFR 50.33(k) requires that an 

operating license applicant submit a report that

indicates how reasonable assurance will be 

provided that funds will be available to 

decommission the facility.

NWMI anticipates decommissioning of the facility to begin following a 30-year operating period 

(NWMI 2015a). Decommissioning activities would be similar to construction activities, because 

they would involve heavy equipment to dismantle buildings and remove roadway and parking 

facilities (NWMI 2015a). Decommissioning would involve decontamination of the RPF, 

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 license 

(10 CFR 50.2)
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reduction of residual radioactivity to a level that permits release of the property for unrestricted 

use and termination of the license. NWMI estimated that the decommissioning period would 

extend for 18 to 24 months and would require a peak workforce of approximately 81 workers, 

1 truck delivery per week, and 20 offsite waste shipments per week (NWMI 2015c, 2016a). 

Demolition and equipment supporting activities are projected to consume 1,647 L/month 

(435 gal/month) of diesel fuel (NWMI 2015a, 2015c). Estimates of the types and quantity of 

radioactive waste that would be disposed of during decommissioning are not known at this time. 

However, the NRC staff assumes that the types of radioactive waste would be consistent with 

those discussed in Section 2.7.1. NWMI would be required to conduct decommissioning 

activities such that radiation doses to occupational workers and members of the public are 

maintained below 10 CFR Part 20 limits.

NWMI would be required to conduct decommissioning activities in accordance with applicable 

NRC requirements and any additional Federal, State, and local requirements. For example, any 

radioactive equipment and materials will be disposed of according to State and Federal laws 

and regulations. After decommissioning activities are completed, the proposed site could 

remain industrial or could be converted back to agricultural land or open space.
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3.0 AFFECTED ENVIRONMENT

The site proposed by Northwest Medical Isotopes, LLC (NWMI) for the NWMI facility is Lot 15 of 

the Discovery Ridge Research Park located in Boone County, Columbia, Missouri. This chapter 

describes the existing regional and local environmental conditions in the vicinity of the proposed 

site for land use and visual resources, air quality and noise, the geologic environment, water 

resources, ecological resources, historic and cultural resources, socioeconomics, human health, 

and transportation. Unless otherwise specified, the description of the environment includes the 

area within a 5-mi (8-km) radius of the proposed site, which is also referred to as the vicinity. 

This geographic range is consistent with the Final Interim Staff Guidance Augmenting 

NUREG–1537, Part 1 and 2 (NRC 2012), which identifies that the geographic distance to be 

considered for environmental impacts is a 5-mi (8-km) radial distance from the proposed facility.

The following description of the affected environment is based on the U.S. Nuclear Regulatory 

Commission (NRC) staff’s independent review of (1) NWMI’s Environmental Report (ER)

(NWMI 2015a, 2015d); (2) NWMI’s responses to the NRC staff’s requests for additional 

information (NWMI 2015c, 2016a, 2016b); (3) the NRC staff’s environmental site visit and audit 

(NRC 2015b); (4) information provided in public scoping comments (NRC 2016a); (5) comments 

and input provided by other Federal agencies, States, Tribes, and regional and local agencies; 

and (6) the NRC staff’s independent research of the environs surrounding the proposed site.

3.1 Land Use and Visual Resources

This section describes the land use and visual resources at the proposed site and in the vicinity 

of the proposed site. The NRC staff assessed land use and land cover using the National Land 

Cover Database (USGS 2006; Fry et al. 2011). The NRC staff used the U.S. Department of the 

Interior, Bureau of Land Management (USDOI-BLM), Visual Resource Management System, to 

rate the visual resources at the proposed site; this system rates the visual appeal and the 

sensitivity of changes to an area (BLM 1984).

3.1.1 Land Use

3.1.1.1 Site and Immediate Surroundings

The proposed site is Lot 15 of the Discovery Ridge Research Park located approximately 3 mi 

(5 km) southeast of the City of Columbia (NWMI 2015a; Figure 2–1). The Discovery Ridge 

Research Park is 1,250 acres (ac) (505 hectares (ha)) and is owned by the University of 

Missouri (MU 2016a). Two research facilities are currently in operation within the research park, 

and the University of Missouri intends to expand the research park for additional research 

facilities (MU 2016a).

Lot 15 of the Discovery Ridge Research Park is 7.4 ac (3.0 ha) (NWMI 2015a; Figure 2–3). 

Based on a review of the National Land Cover Database, 100 percent of the site is classified as 

pasture/hay (USGS 2006; NWMI 2015a). No structures currently exist on the site (NWMI 

2015a; NRC2015b). The proposed Discovery Ridge site does not contain prime farmland or 

other important farmland soils as defined in the Farmland Protection Policy Act of 1981 

(7 U.S.C. 4201 et seq.) and implementing regulations (7 CFR Parts 657, 658; NWMI 2015a).

The proposed site is zoned A–1 for agricultural activities (City of Columbia 2016a). However, 

Section 172.273.1 of the Missouri Revised Statues states that “the curators of the University of 

Missouri may establish research, development and office park projects, in order to promote 

cooperative relationships and to provide for shared resources between private individuals, 

companies and corporations, and the University of Missouri, for the advancement of the 
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3-2

university in carrying out its educational mission.” In October 2005, the Board of Curators of the 

University of Missouri identified the site to be developed as a research park pursuant to 

Statute 172.273 of the Missouri Revised Statutes (MU 2009). In May 2006, the Board approved 

the Master Plan of the research park, which designated approximately 114 ac (46 ha) as the 

initial phase for development with the expectation that additional phases of the research park 

would be added as needed.

In the most recent land use plan, the City of Columbia identifies the Discovery Ridge Research 

Park, including Lot 15, as “shovel ready” for future industrial development (City of 

Columbia 2013). The research park is also one of three sites that the City of Columbia (2013) 

designated as an industrial certified site. The future development goal for the Discovery Ridge 

Research Park is to increase the number of business and research facilities on site, especially 

for entities that would benefit from the close proximity to the resources available at the 

University of Missouri (City of Columbia 2013). In addition, one of the City of Columbia’s

economic goals is to attract new businesses and increase the number of light industrial and high 

tech jobs within the Columbia Regional Airport-Discovery Ridge-U.S. Highway 63 Corridor

(City of Columbia 2013), which includes Discovery Ridge Research Park.

3.1.1.2 Vicinity

Table 3–1 lists the major land uses and land covers within a 5-mi (8-km) radius of the proposed 

site (USGS 2006; Fry et al. 2011; NWMI 2015a). The major land uses and covers include 

developed areas (25 percent), deciduous forests (31 percent), and hay or pasture (30 percent).

The proposed site is within the limits of the City of Columbia, which had a population of 116,109 

as of July 1, 2014 (USCB 2016a). The University of Missouri is located within the City of 

Columbia and has a student population of 34,748 when in full session (MU 2016b). No other 

major population centers (more than 25,000 residents) exist within the 5-mi (8-km) vicinity of the 

proposed site.

The major transportation corridors in the vicinity include Discovery Parkway, U.S. Highway 63, 

and U.S. Interstate 70 (Figure 3–1). COLT Transload, which is owned by the City of Columbia, 

provides rail transportation to the City of Columbia. The closest airport to the proposed 

Discovery Ridge site is the Columbia Regional Airport, which is located 11 km (7 mi) from the 

proposed site. The Missouri River is the largest river in Boone County and occurs 11.7 km 

(7.3 mi) to the west of the proposed Discovery Ridge site (see Section 3.4). The Missouri River 

is the only river large enough to support commercial traffic in Boone County (NWMI 2015a).
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3-3

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

of the Proposed Discovery Ridge Site

Summary of Land Use and Land Cover Within the 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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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

3.1.1.3 Special Land Uses

Approximately 7 percent (1,427 ha (3,527 ac)) of the 5-mi (8-km) vicinity surrounding the 

proposed Discovery Ridge site is parks or conservation areas, such as Rock Bridge Memorial 

State Park, Three Creeks Conservation Area, and the northwest corner of the Mark Twain 

National Forest (NWMI 2015a). The Missouri Department of Natural Resources (MDNR) 

manages the Rock Bridge Memorial State Park, which is an 858-ha (2,120-ac) park that 

consists of karsts, grasslands, and oak woodlands and forests (MDNR 2016a). This State park 

also contains the Gans Creek Wild Area. The Missouri Department of Conservation (MDC) 

manages the Three Creeks Conservation Area, which is a 607-ha (1,500-ac) natural preserve 

that consists mostly of oak forests and woodlands and provides cave habitat for bats 

(MDC 2016a). A small portion of the Mark Twain National Forest, Cedar Creek Ranger District, 

is also located within the vicinity of the proposed site (USDA 2016a). The Mark Twain National 

Forest consists of tall grass prairies and shortleaf pine-oak woodlands. The City of Columbia 

manages the 320 ac (129 ha) Gans Creek Recreation Area, which includes five multi-purpose 

fields, grassy areas, a cave, and forested areas that run along Gans Creek (City of Columbia, 

undated).

No active mines or quarries, military reservations, Federally designated wild and scenic rivers, 

national parks, or Federal lands held in trust for an American Indian tribe occur within 5 mi 

(8 km) of the proposed site (NWMI 2015a; NRC 2015b; Find the Data 2016). In addition, 

because no Federally designated coastal zone areas occur within 5 mi (8 km) of the proposed 

NWMI site, the proposed action would not affect any land or water use or natural resource 

within a coastal zone (NOAA 2016). Thus, no applicant certification and State concurrence 

(under the Coastal Zone Management Act of 1972, as amended) that the activity is consistent 

with the State’s Coastal Zone Management Plan is needed for the NRC’s review of the 

construction permit for the proposed NWMI facility.
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3.1.1.4 Agricultural Resources and Facilities

Soils that may qualify as prime farmland and farmland of statewide importance are located 

within the 5-mi (8-km) vicinity of the proposed Discovery Ridge site (Figure 3–2). Prime 

farmland is defined in the Farmland Protection Policy Act of 1981 as “land that has the best 

combination of physical and chemical characteristics for producing food, feed, fiber, forage, 

oilseed, and other agricultural crops with minimum inputs of fuel, fertilizer, pesticides, and labor, 

and without intolerable soil erosion, as determined by the Secretary [of Agriculture].” The 

Farmland Protection Policy Act states that farmland of statewide importance includes soils, 

other than those determined as prime farmland, with similar characteristics as prime farmland 

locally within the State. The U.S. Department of Agriculture (USDA), Natural Resources 

Conservation Service (NRCS), in cooperation with State and local agencies, defines and 

delineates the soils to consider as prime farmland and farmland of statewide importance (Title 7 

of the Code of Federal Regulations (CFR) Part 657). However, otherwise qualifying “farmland” 

soils do not include those on land already in, or committed to, urban development or water 

storage, as defined in 7 CFR 658.2.

In Missouri, farmlands of statewide importance include the following soils: Weller silt loam, 

Weller–Urban land complex, Wrengart silty clay loam, and Hatton silt loam (NRCS 2016a, 

2016b). Weller silt loam is the most common soil type that qualifies as both prime farmland and 

farmlands of statewide importance. The proposed Discovery Ridge site does not contain prime 

farmland or other important farmland soils. Within a 5-mi (8-km) radius of the proposed 

Discovery Ridge site, approximately 4,218 ha (10,424 ac), or one-fifth of the 5-mi (8-km) vicinity, 

are prime farmland or statewide important farmland (NRCS 2016a, 2016b; NWMI 2015a).

Principal agricultural products grown in the vicinity include soybeans, sorghum, and oats 

(USDA 2014). Many farms in the vicinity of the proposed Discovery Ridge site are used for 

pasture and grazing (USDA 2014; NWMI 2015a).

3.1.2 Visual Resources

The visual setting of the area that would be affected by the proposed NWMI facility includes 

agricultural, residential, and light industrial viewsheds (NWMI 2015a; NRC 2015b, Figures 3–3 

through 3–10). Deciduous trees are also visible (NWMI 2015a; NRC 2015b). The viewsheds to 

the north and south of the proposed site have slightly rolling cultivated fields, roads, and 

residential buildings. The viewshed to the east is similar, with mostly agricultural fields, and a 

building associated with the University of Missouri Beef Farm. The viewshed to the west 

includes roads and agricultural fields.
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Figure 3–2. September 2013 Visual Reconnaissance Photo Locations

Source: NWMI 2015a
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3-7

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

Intersection of Rolling Hills and Bass Roads, Photo Location #1

Source: NWMI 2015a

Figure 3–4. View of Proposed Radioisotope Production Facility Site from 

Gans Road, approximately 1.6 km (1 mi) North, Photo Location #2

Source: NWMI 2015a
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Figure 3–5. Direct View of Radioisotope Production Facility Site from Discovery Parkway 

near the Overpass, Photo Location #3

Source: NWMI 2015a

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

Phillips Lake, Photo Location #4

Source: NWMI 2015a
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Figure 3–7. View of Proposed Radioisotope Production Facility Site from Boys and Girls 

Town of Missouri, Photo Location #5

Source: NWMI 2015a

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

Roosevelt Avenue, Photo Location #6

Source: NWMI 2015a
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3-10

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

New Haven and Rolling Hills Roads, Photo Location #7

Source: NWMI 2015a

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

Old Hawthorne, Photo Location #8

Source: NWMI 2015a
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The proposed site would be within the viewshed of patrons and employees visiting the nearby 

facilities within the Discovery Ridge Research Park, traveling along nearby roads and highways, 

and potentially from some of the nearby residences (NWMI 2015a; NRC 2015b). Trees and 

other vegetation that border many of the residential neighborhoods and some of the business 

would obstruct the view of the proposed NWMI facility from some of these areas.

The NRC staff rated the visual resources and scenic quality of the existing site using the 

USDOI-BLM Visual Resource Management System (BLM 1984). The scenic quality 

classification is the rating of the visual appeal of the land designated for the proposed site. This 

rating is based on an evaluation of seven key factors—landform, vegetation, water, color, 

adjacent scenery, scarcity, and cultural modifications. Scenic quality is classified as A, B, or C, 

with A as the highest quality visual rating. The NRC staff gave the proposed site a C rating, with 

low scenic quality because of the uniform landform, low vegetation diversity, absence of water, 

subtle variation of color variations and contrast of vegetation, absence of cultural modifications 

to adjacent scenery, commonality within the physiographic province, and lack of notable 

features (NWMI 2015a; NRC 2015b).

The NRC staff also analyzed the sensitivity level, which is a measurement of public concern for 

scenic quality, using six different indicators—types of users, amount of use, public interest, 

adjacent land uses, special areas, and other factors. The sensitivity level of public concern for 

scenic quality is assigned as high, moderate, or low. The NRC staff assigned the proposed site 

a low sensitivity level because it is located in an area with low scenic values, typical users have 

low sensitivity to changes in the area’s visual quality, the amount of viewer use is low, public 

interest in changes to the visual quality of the proposed site is low, and the location has no 

special natural and wilderness areas (NWMI 2015a; NRC 2015b).

3.2 Meteorology, Air Quality, and Noise

3.2.1 Meteorology and Climatology

The State of Missouri is characterized by a humid continental type climate, subject to frequent 

changes in temperatures, and strong seasonality (NCDC undated). The lack of topographic 

barriers allows dry and cool air masses from Canada to reach the region during winter, and 

during summer moist and warm air masses from the Gulf of Mexico reach the region. Summers 

are warm, humid, and rainy and winters are moderately cold and snowfalls are common. 

Climate characteristics vary across the State along a diagonal line trending northwest to 

southeast. The proposed site is located in Missouri’s Northeast Prairie Climate Division 2. The 

nearest National Climatic Data Center (NCDC) station is the Columbia Regional Airport station. 

To characterize the region’s climate, the NRC staff used a 30-year (1981–2010) climatological 

data set from the Columbia Regional Airport (NCDC 2010). The Columbia Regional Airport 

station is 7 mi (11 km) from the proposed Discovery Ridge site.

Table 3–2 summarizes annual and seasonal precipitation and temperature data for the 

1981-2010 record from the Columbia Regional Airport station. Annual average temperature for 

the 30-year record was 54.6 oF (12.6 oC). Average seasonal temperatures for the 30-year 

record ranged from 75.5 oF (24.2 oC) in the summer to 32.1 oF (0.05 oC) in the winter. Annual 

average precipitation was 42.62 in. (1.1 m) and seasonal precipitation ranged from 6.61 in. 

(16.8 cm) in the winter to 13.20 in. (33.5 cm) in the summer. Monthly average wind speeds 

range from 7.4 miles per hour (mph) (11.9 kilometers per hour (kph)) in August to 11.3 mph 

(18.2 kph) in March. Annual mean wind speed is 9.5 mph (15.3 kph). Prevailing wind direction 

is from the south May through November and from the northwest December through April 

(NCDC 2014).
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Annual and Seasonal Precipitation and Temperature Data for

Columbia, 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

NCDC records (NCDC 2016) identify the following extreme weather events in Boone County 

from 1950 to 2015:

• tornadoes: 26 events,

• floods: 11 events,

• blizzard: 1 event, and 

• strong winds: 2 events.

The strongest recorded tornados in the County were classified as F3,1 which occurred in 1990 

and 1998.

3.2.2 Air Quality

Under the Clean Air Act of 1970, as amended (CAA) (42 U.S.C. 7401 et seq.), the 

U.S. Environmental Protection Agency (EPA) has set primary and secondary National Ambient 

Air Quality Standards (NAAQS) (40 CFR Part 50) for six common criteria pollutants considered 

harmful to public health and the environment. Primary standards specify maximum ambient 

concentration levels of the criteria pollutants aimed at providing public health protection 

including protecting the health of “sensitive” populations, such as asthmatics, children, and the 

elderly. Secondary standards specify maximum ambient concentration levels of the criteria 

pollutants aimed at providing public welfare protection including protection against decreased

visibility and damage to animals, crops, vegetation, and buildings. The NAAQS criteria 

pollutants include carbon monoxide (CO), lead (Pb), nitrogen dioxide (NO2), ozone (O3), sulfur 

dioxide (SO2), and particulate matter (PM). Particulate matter is further categorized by size—

particulate matter with aerodynamic diameter of 10 micrometers (μm) or less (PM10) and 

particulate matter with aerodynamic diameter of 2.5 μm or less (PM2.5). 

The CAA allows for states to adopt additional or more stringent air quality standards. Missouri 

has adopted the CAA NAAQS in Title 10 of Missouri’s Code of State Regulations (CSR) and 

has set standards for hydrogen sulfide and sulfuric acid (10 CSR 10-6.010). Table 3–3 presents 

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.
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3-13

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

The EPA designates areas of “attainment” and “nonattainment” with respect to the NAAQS. 

Areas for which there are insufficient data to determine designation status are denoted as 

“unclassifiable.” Areas meeting the standard or expected to be meeting the standard despite a 

lack of monitoring data are designated “unclassifiable/attainment”. Areas that were once in 

nonattainment, but are now in attainment, are called “maintenance” areas; these areas are 

under a 10-year monitoring plan to maintain the attainment designation status. States have 

primary responsibility for ensuring attainment and maintenance of the NAAQS. Under 

Section 110 of the CAA (42 U.S.C. 7410) and related provisions, states are to submit, for EPA 

approval, State Implementation Plans (SIPs) that provide for the timely attainment and 

maintenance of the NAAQS. Air quality designations are generally made at the county level. 

For the purposes of planning and maintaining ambient air quality with respect to the NAAQS, 

EPA has developed Air Quality Control Regions (AQCRs). AQCRs are intrastate or interstate 

areas that share a common airshed (40 CFR Part 81). The proposed facility site, Discovery 

Ridge, is located in Boone County which is part of the Northern Missouri Intrastate Air Quality 

Control Region (40 CFR 81.116). With regard to the NAAQS criteria pollutants, Boone County 

is designated as an unclassifiable/attainment area for all criteria pollutants (40 CFR 81.326). 

The nearest designated nonattainment areas to the proposed site are the following: 

Franklin County, Missouri: approximately 50 mi (80 km) from the proposed site. 

Franklin County is part of the Metropolitan St. Louis Interstate AQCR (40 CFR 81.18) 

and nonattainment for the 8-hr ozone (2008) NAAQS and PM2.5 (1997) NAAQS, and
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3-14

St. Charles County, Missouri: approximately 70 mi (113 km) from the proposed site. 

St. Charles County is part of the Metropolitan St. Louis Interstate AQCR 

(40 CFR 81.18) and nonattainment for PM2.5.

The EPA promulgated the Regional Haze Rule (RHR) to improve and protect visibility in 

national parks and wilderness areas from haze, which is caused by numerous, diverse sources 

located across a broad region (40 CFR 51.308-309). Specifically, 40 CFR Part 81 Subpart D 

lists mandatory Class I Federal Areas where visibility is an important value. The RHR requires 

states to develop SIPs to reduce visibility impairment at Class I Federal Areas. The nearest 

Class I Federal Area to the proposed site is the Hercules-Glades Wilderness Area, 

approximately 138 mi (222 km) away.

Table 3–4 provides annual emissions of criteria pollutants and carbon dioxide for Boone County. 

These emissions include both stationary and mobile sources.

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 

The General Conformity Rule, established under Section 176(c)(4) of the CAA, ensures that 

Federal actions conform to SIPs. The Federal agency must conduct a conformity analysis if the 

proposed action is in a designated nonattainment or maintenance area with respect to NAAQS 

and would result in the generation of air emissions that would exceed conformity threshold 

levels of pollutants (de minimis thresholds). Because the proposed NWMI facility would be 

located in a designated unclassifiable/attainment area, a conformity analysis is not required.

Air Quality Regulations 

New facilities that emit air pollutants could be subject to Federal requirements, depending on 

the location and the type and amount of emitted air pollution. The following discussions 

summarize these requirements. The MDNR is authorized by the EPA to administer air pollutant 

emission permits. NWMI may be required to obtain construction and operation permits in 

accordance with Title 10 of Missouri’s CSR.

New Source Review Program

Construction of a new air pollution source is subject to the New Source Review program. 

Sources classified as major sources (as defined in 40 CFR 51.165, 40 CFR 51.166, and 

40 CFR 52.21) and located in attainment areas are required to obtain a prevention of significant 

deterioration (PSD) permit. The purpose of the program is to prevent degradation of air quality 

in areas where air quality is good. New sources of criteria pollutants that are located in an 

attainment area that exceed 250 tons/year (TPY) emission rate of any criteria pollutant are 

subject to the permit program and are considered a major source. Further, emissions that 

exceed de minimis levels are considered significant (40 CFR 51.166) and for the purposes of 

the NRC staff’s air quality analysis, these thresholds will be considered in determining the 

significance of air quality impacts for construction. The de minimis rates are as follows: 
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3-15

100 TPY of carbon monoxide, 40 TPY of nitrogen oxides, 40 TPY of sulfur dioxide, 40 TPY of 

volatile organic compounds (ozone precursor), 15 TPY of particulate matter less than 

10 microns, and 10 TPY of particulate matter less than 2.5 microns (40 CFR 51.166; 

10 CSR 10-6.020). New Source Review requirements are implemented in Title 10 of Missouri’s 

CSR (10 CSR 10-6.060).

Title V of the Clean Air Act

Title V of the CAA (42 U.S.C. 7661–7661f) requires a Federally enforceable operating permit 

program that applies to large, new, and existing sources of air pollution. Any facility with the 

potential to emit 100 TPY or more of any criteria pollutant, 10 TPY of any hazardous air 

pollutant (HAP), or 25 TPY of all HAPs combined is required to obtain a valid Title V permit and 

is considered a major air source (40 CFR Part 70). For the purpose of the NRC staff’s air 

quality analysis, the 100 TPY of any criteria pollutant threshold for a Title V operation permit will 

be considered in determining the significance of air quality impacts for operation. Title V 

requirements are implemented in Title 10 of Missouri’s CSR (10 CSR 10-6.065).

Greenhouse Gas Tailoring Rule

Gaseous chemicals that trap heat in the atmosphere are known as greenhouse gases (GHGs). 

The most common GHGs are carbon dioxide, methane, and nitrous oxide. These pollutants are 

emitted from natural processes and human activities. 

On September 22, 2009, the EPA issued a final rule for mandatory GHG reporting from large 

GHG emission sources in the United States (74 FR 56260). The purpose of the GHG Tailoring 

Rule is to collect and use comprehensive and accurate data on carbon dioxide and other GHG 

emissions to inform future policy decisions. In general, the threshold for reporting is 

25,000 metric tons carbon dioxide equivalent (CO2eq) emissions per year, excluding 

mobile-source emissions. GHGs are grouped into a single, representative “pollutant” called 

CO2eq. CO2eq is a metric used to compare the emissions of GHG based on their global 

warming potential (GWP). GWP is a measure used to compare how much heat a GHG traps in 

the atmosphere. GWP is the total energy that a gas absorbs over a period of time compared to 

carbon dioxide. CO2eq is obtained by multiplying the amount of the GHG by the associated 

GWP. For example, the GWP of methane is estimated to be 21; therefore, 1 ton of methane 

emission is equivalent to 21 tons of carbon dioxide emissions.

On May 13, 2010, the EPA issued the GHG Tailoring Rule. This rule set the thresholds for a 

phase-in approach to regulating GHG emissions under the PSD and Title V permitting programs 

(75 FR 31514). Beginning on January 2, 2011,2 operating permits issued to major sources of 

GHG under the PSD or Title V Federal permit programs must contain provisions requiring the 

use of best available control technology to limit the emissions of GHGs, if those sources would 

be subject to PSD or Title V permitting requirements because of their non-GHG pollutant 

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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On November 3, 2009, the Commission directed (CLI-09-21)3 NRC staff “to include 

consideration of carbon dioxide and other greenhouse gas emissions in its environmental 

reviews for major licensing actions under the National Environmental Policy Act.” In order to 

comply with the Commission’s direction in CLI–09–21, the staff has considered GHG emissions 

from construction, operations, and decommissioning of the proposed NWMI facility, as well as 

any cumulative impacts caused by the potential climate change upon the affected resources in 

Chapter 4 of this EIS. 

3.2.3 Noise

Noise is often defined as unwanted sound and can be generated by many sources. Sound 

intensity is measured in logarithmic units called decibels (dB). A dB is the ratio of the measured 

sound pressure level to a reference level equal to a normal person’s threshold of hearing. 

Another characteristic of sound is frequency or pitch. Noise may be composed of many 

frequencies, but the human ear does not hear very low or very high frequencies. To represent 

noise as closely as possible to the noise levels people experience, sounds are measured using 

a frequency-weighting scheme known as the A-scale. Sound levels measured on this A-scale 

are given in units of A-weighted decibels (dBA). 

Table 3–5 presents common noise sources and their respective noise levels. A whisper is 

normally 30 dBA and is considered very quiet. Noise levels can become annoying at 80 dBA 

and very annoying at 90 dBA. Noise levels attenuate rapidly with distance. When distance is 

doubled from a point source, noise levels decrease by 6 dBA (FHWA 2011). Generally, a 

3-dBA change over existing noise levels is considered to be a “just noticeable” difference, a 

5-dBA increase is readily perceptible, and a 10-dBA increase is subjectively perceived as a 

doubling in loudness (FHWA 2011).

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

Several different terms are commonly used to describe sounds that vary in intensity over time. 

The equivalent sound intensity level (Leq) represents the average sound intensity level over a 

specified interval, often 1 hr. The day-night sound intensity level (LDN) is a single value 

calculated from hourly Leq over a 24-hr period, with the addition of 10 dBA to sound levels from 

10 p.m. to 7 a.m. This addition accounts for the greater sensitivity of most people to nighttime 

noise. Statistical sound level (Ln) is the sound level that is exceeded “n” percent of the time 

 3 In the matter of Duke Energy Carolinas, LLC (Combined License Application for William States Lee III

Nuclear Station, Units 1 and 2); in the matter of Tennessee Valley Authority (Bellefonte Nuclear

Power Plant, Units 3 and 4), CLI–09–21 (NRC November 3, 2009).
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during a given period. For example, L90, is the sound level exceeded 90 percent of time and is 

considered the background level.

Noise Regulations

There are no Federal regulations4 for public exposures to noise (EPA 2016e). The EPA 

recommends an average LDN of 55 dBA as guidelines or goals for outdoors in residential areas 

(EPA 1974). However, these are not standards. The Federal Housing Administration has 

established noise assessment guidelines for housing projects and finds that an average LDN of 

65 dBA or less is acceptable (HUD 2014). Under the Noise Control Act of 1972 

(42 U.S.C. 4901 et seq.), the Occupational Safety and Health Administration established 

workplace standards for noise. The minimum requirement states that constant noise exposure 

must not exceed 90 dBA over an 8-hr period. The highest allowable sound level to which 

workers can be exposed is 115 dBA. Exposure to this level must not exceed 15 min within an 

8-hr period. If noise levels exceed these standards, employers are required to provide hearing 

protection equipment that reduces sound levels to acceptable limits (29 CFR 1910.95).

The City of Columbia has a noise ordinance that prohibits loud and unnecessary noise. The 

noise ordinance does not establish acceptable noise levels, but it does establish acceptable 

time frames for when activities can be conducted. For instance, site preparation activities 

associated with construction shall be conducted during the hours of 7:00 a.m. and 7:00 p.m. 

(City of Columbia 2016b). Furthermore, the Discovery Ridge Master Plan prohibits “excessive” 

noise in the Discovery Ridge Research Park (MU 2009) but does not define excessive noise or 

establish acceptable noise levels. 

Existing Noise Levels 

Existing noise sources near the proposed site include vehicular traffic along U.S. Highway 63, 

agricultural equipment, and HVAC systems associated with the nearby buildings (NWMI 2015a). 

Noise-sensitive receptors within 1 mi (1.6 km) of the proposed site include:

• a residence, approximately 0.27 mi (0.43 km) south of the proposed site;

• New Haven Elementary School, approximately 1 mi (1.6 km) north of the proposed 

site;

• Analytical Bio-Chemistry (ABC) Laboratories, approximately 0.3 mi (0.48 km) west of 

the proposed site; and

• IDEXX BioResearch facility (formerly known as Research Animal Diagnostic and 

Investigative Laboratory – RADIL), approximately 0.1 mi (0.16 km) northwest of the 

proposed site.

The NRC staff did not identify the existence of any ambient noise surveys for the Discovery 

Ridge Research Park. Surrounding land uses include agricultural activities. Typical noise 

levels from agricultural equipment at a 50 ft (15 m) distance are estimated to be 84 dBA 

(FHWA 2006). However, these noise levels are intermittent, when the equipment is in use. 

NWMI conducted a noise modeling study using the Federal Highway Administrations Traffic 

Noise Model 2.5 (NWMI 2016a, 2016d). Based on this model study, during peak traffic periods 

along U.S. Highway 63, noise levels at the nearest residence to the proposed Discovery Ridge 

site can reach 69 dBA. As discussed in Section 3.1.1.1, the Discovery Ridge Research Park is 

 4 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 of 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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designated as an industrial certified site and it has commercial community features (City of 

Columbia 2016a). During non-peak traffic periods and when equipment noise is not in use, the 

NRC anticipates that Discovery Ridge Research Park ambient background levels are similar to 

that of commercial areas. Commercial area noise levels can range from 60 to 70 dBA 

(Miller 2002). Given that the Discovery Ridge Research Park is an emerging research park that 

currently has two research and laboratory and office facilities in operation, the NRC staff 

anticipates that current ambient background noise levels are 60 to 65 dBA.

3.3 Geologic Environment

The geologic environment of a location encompasses the physiographic or physical setting and 

the associated structural features of the Earth’s crust, geologic strata, and soils that comprise 

the site. Geologic hazards are a condition of the geologic environment and include large-scale 

hazards such as geologic faulting and earthquakes that comprise a site’s seismologic setting as 

well as local hazards associated with the site-specific attributes of the soil and bedrock at a site.

3.3.1 Site Geology

The proposed NWMI facility site within the Discovery Ridge Research Park (Discovery Ridge 

site) is located at the southern edge of the Central Lowland physiographic province and just 

north of its boundary with the adjacent Ozark Plateaus province (NWMI 2015a; NPS 2015; 

Miller and Appel 1997; MDNR 2002a). The Missouri River in central Missouri marks the 

approximate boundary between the two provinces. The Central Lowland province is part of the 

greater Interior Plains physiographic division whereas the Interior Highlands physiographic 

division encompasses the Ozark Plateaus province. Physiographic or geomorphic provinces 

are regions with similar landforms and underlying geology. Provinces are further divided into 

physiographic sections.

More precisely, the Discovery Ridge site lies within the Dissected Till Plains section of the 

Central Lowland province (MDNR 2002a; USGS 2014a). Landforms within this section and of 

the Central Lowland province as a whole are generally flat to gently rolling (NPS 2015). Such 

low-relief landforms relate partly to the presence of mainly flat-lying rocks deposited primarily in 

marine and fluvial environments beginning in the Paleozoic Era, some 500 million years ago 

(Ma). These strata were then eroded during the Mesozoic, which ended about 66 Ma, down to 

the current bedrock surface consisting of Pennsylvanian-age strata (Miller and Appel 1997). 

The land surface was then subjected to glaciation during the early to mid-Pleistocene Epoch 

(i.e., Pre-Illinoian, prior to about 310,000 years before present). Unlike regions to the north and 

east, later glacial advances did not affect the Missouri region (Sharp 1984; Miller and 

Appel 1997). Modern drainage development including stream incision, alluvial deposition, and 

associated erosional processes further shaped the land surface, with these processes 

continuing into the present day.

As a result, the current land surface across undeveloped portions of the Dissected Till Plains of 

south-central Boone County exists as a moderately dissected, flat to rolling glacial plain that 

slopes toward the Missouri River valley (NWMI 2015a). Topography at the Discovery Ridge site 

mirrors this landform, where the site is generally flat to slightly rolling, with a slope generally to

the south and southwest (Terracon 2011a). This observation was confirmed during the NRC 

staff’s environmental site audit in September 2015 (NRC 2015b), when the site predominantly 

existed as an open grassland. Elevations across the site range from approximately 820 ft 

(250 m) mean sea level (MSL) in the northwestern corner to about 800 ft (244 m) in the 

southern corner (Figure 3–11).
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Figure 3–11. Topographic Map of the Discovery Ridge Site and Vicinity

Source: Modified from USGS 2015a

As indicated above, the surficial geology of Boone County is the product of glacial action and 

subsequent weathering and erosion. A mantle of glacial drift covers much of the County. 

Glacial drift consists of undifferentiated sediments deposited either directly by a glacier 

(i.e., glacial till) or by related glaciofluvial processes (e.g., meltwater stream outwash). These 

glacial deposits generally range in thickness from a few inches to more than 100 ft (30 m), 

particularly in areas of the County immediately north and east of the Missouri River. These 

materials generally consist of a yellowish clay till mixed with sand and pebbles. Deposits of 
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loess (windblown glacial sediment) are also widespread throughout the County, but the deposits 

are thickest along the bluffs of the Missouri River to the south of the site (BCC 1996).

Glacial drift generally covers the eastern half of Boone County whereas residuum (weathered 

bedrock material) is the predominant bedrock cover over the western half of the County. This 

generally supports the overburden mapping information provided in the NWMI ER

(NWMI 2015a). Specifically, the surficial geologic unit at the Discovery Ridge site is mapped as 

glacial drift (unit F). This unit is characterized as light tan to dark gray silty clay and clay till. 

The clay is mixed with pebbles of limestone, chert, and quartzite. Sands, cobbles, and boulders 

may occur in pockets, lenses, or as channel deposits. A layer of loess ranging from 1 to 5 ft 

(0.3 to 1.5 m) thick typically covers the drift. A clay-rich paleosol (i.e., a buried soil horizon) 

often occurs at depths ranging from 6 to 8 ft (1.8 to 2.4 m). In total, this unit ranges from 10 to 

300 ft (3-91 m) thick. However, based on bedrock contour mapping data derived from well logs, 

the total thickness of the drift and other overburden material in the vicinity of the Discovery 

Ridge site is approximately 25 ft (7.6 m) (MGS 2016).

Terracon, a consulting engineering firm, performed a preliminary geotechnical investigation of 

the Discovery Ridge Research Park in 2011, which encompassed the proposed site (i.e., Lot 15 

of the research park) (Terracon 2011a). The purpose of the investigation was to provide 

preliminary geotechnical recommendations concerning earthwork and the design and 

construction of foundations, floor slabs, and pavements for Discovery Ridge properties 

(NWMI 2015a).

Terracon drilled nine boreholes (designated B-1 through B-9) across the research park as part 

of the 2011 study. The borings were advanced to depths ranging from 13 to 20 ft (3.9 to 6.1 m) 

below ground surface (bgs). Laboratory tests were also conducted on select samples, including 

soil density, compaction, plasticity and liquid limit tests (NWMI 2015a; Terracon 2011a). All 

boring samples measured were found to have a relatively high water content, generally in the 

range of 18 up to 35 percent (Terracon 2011a). For the surveyed areas as a whole, the boring 

logs indicate the presence of lean to fat clay and fat clay in the upper part and underlain by clay, 

trace sand, gravels, and cobbles representing glacial drift. Clay fill was encountered in the 

upper part of two borings completed at locations to the west of the Discovery Ridge site 

(i.e., borings B-3 and B-4 located west of Discovery Ridge Parkway). A single boring 

(designated B-5 in Terracon 2011a) drilled on the eastern boundary of Lot 15 is most 

representative of the proposed site. Table 3–6 summarizes information on the nature of the 

surficial materials obtained from this boring.

Summary of Boring Log B-5 Completed in the Vicinity of the Proposed NWMI 

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

As shown in Table 3–6, fat clays appear to comprise much of the surficial strata at the 

Discovery Ridge site. Fat clays include inorganic clay minerals of high plasticity. These 

materials characteristically have high compressibility, poor shear strength when wetted, and 

have generally poor workability as a construction material, including for use as structural 

(engineered) backfill (SCS 1990). Moreover, as indicated by Terracon and as referenced by 

NWMI in its ER, fat clays are termed expansive or swelling soils because they expand or swell 

with changes in moisture content (NWMI 2015a; Terracon 2011a). Such soils with a high 

shrink/swell potential can damage concrete and other structures with changes in moisture 

content and soil volume. Terracon determined that some of the soils encountered during drilling 

had moisture levels above their measured plastic limit. Such soils may be prone to rutting and 

pumping (rebound) when a load is applied, which results in unstable subgrade conditions during 

construction (Terracon 2011a). Nevertheless, Terracon made no determination about the 

liquefaction potential of these soil materials (NWMI 2015h).

Weathered bedrock (identified as limestone) was encountered in only two borings (B-6 and B-7) 

at depths of approximately 17 and 13 ft (5.1 and 4.0 m) bgs, respectively. These boring sites 

are located approximately 1,000 ft (300 m) south of the proposed NWMI facility site (Lot 15, 

Discovery Ridge site) and toward the shallow valley traversed by Gans Creek.

While geotechnical investigations conducted to date have not determined the precise depth to 

or nature of bedrock beneath the proposed site, available mapping data indicate that the depth 

to bedrock is approximately 25 ft (7.6 m) (MGS 2016). Geologic mapping (Stoeser et al. 2007) 

reveals that rocks of the Cherokee Group of Pennsylvanian age (i.e., 299 to 318 Ma) 

immediately underlie the site. This is consistent with the geologic mapping provided in the 

NWMI ER (NWMI 2015a) and adapted as Figure 3–12.

Sediments comprising the Cherokee Group were mainly deposited in low-relief continental 

(terrestrial) to tidal environments that included river deltas, coastal plains, and swamps. Across 

central and eastern Missouri, deposition occurred on an eroded karst surface (i.e., atop 

carbonate bedrock subject to dissolution) (Thompson 1979). The geologic units comprising the 

recognized Cherokee Group are further divided into two subgroups, the Cabaniss and Krebs 

Subgroups. The Cabaniss Subgroup includes cyclically-deposited shale, sandstone, siltstone, 

clay, and limestone with seven coal beds. Cyclically-deposited rocks derive from sediments 

deposited in an often-repetitive pattern reflective of changes in the depositional environment 

from marine to continental and then back again. Rocks of the Cabaniss Subgroup attain a 

maximum thickness of 200 ft (60 m). Rocks of the lower Krebs Subgroup also include cyclic 

deposits that predominantly consist of shale and sandstone with limestone, as well as siltstone 

and two coal beds. The Krebs Subgroup attains a maximum thickness of 110 ft (34 m) 

(Stoeser et al. 2007). The bedrock immediately to the south along the Gans Creek valley and to 

the west of the site consists of Osagean Series rocks of Early Mississippian age (345 to 

359 Ma). Rock types are predominantly marine limestone with chert and minor dolostone and 
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shale. Recognized geologic units include the Keokuk and Burlington limestones, Elsey (Grand 

Falls) Formation, Reeds Spring Formation, and Fern Glen Formation (Stoeser et al. 2007; Miller 

and Appel 1997). The total thickness of the series is as much as 600 ft (180 m) 

(Stoeser et al. 2007). More recent (2014) geologic mapping completed by the Missouri 

Geological Survey (MGS) at 1:24000 scale shows that rocks immediately underlying the 

Discovery Ridge site are comprised of the Krebs Subgroup, described above, while bedrock 

immediately bordering and encroaching into the site from the south and farther to the west 

consists of Burlington-Keokuk limestone of Mississippian age (MGS 2016). The former 

observation is consistent with findings from geotechnical borings B-6 and B-7.

Burlington limestone is the principal limestone exposed in quarries, creek banks, and road cuts 

near and around Columbia. As referenced by NWMI (2015a), this limestone unit is relatively 

soluble and contains many caverns and passages indicative of karst terrane. Karst terrane is a 

landform underlain by soluble carbonate bedrock and characterized by the presence of springs, 

caves, and sinkholes.

Based on the results of its preliminary geotechnical report and available geological mapping of 

the area, Terracon (2011a) concluded that there are no known caves or sinkholes within 

approximately 1 mi (1.6 km) of the Discovery Ridge Research Park. MGS mapping coverage 

for the area indicates that karst features are present to the west and southwest of the Discovery 

Ridge site, with the nearest sinkhole features lying approximately 1.3 mi (2.1 km) southwest 

(MGS 2016). However, the nearest documented feature is associated with a sinkhole that

collapsed a roadway in southern Columbia in May 2014 at East Gans Creek Road between 

Ponderosa Street and Discovery Parkway. This location is approximately 0.7 mi (1.1 km) 

southwest of the Discovery Ridge site (MMRPC 2015; NWMI 2016e). Before making repairs, 

the Columbia Public Works Department evaluated the sinkhole and determined it to be naturally 

occurring due to karst processes (MMRPC 2015). Changes in site conditions, such as grading 

and drainage alteration, can result in sinkholes even in areas with no history of sinkhole 

development (Terracon 2011a). NWMI has confirmed that no sinkholes have occurred at the 

proposed RPF site since Terracon issued its preliminary report in 2011 (NWMI 2016e). 

Predominantly northwest-trending faulting and folding (e.g., anticlines, synclines, and similar 

features) across the central and northeast Missouri region are mainly attributable to 

compressional tectonic stress associated with Ouachita belt mountain building and uplift during 

the Mississippian and Pennsylvanian Periods (Clendenin et al. 1989).

In the ER, NWMI identified the presence of one geologic fault structure within a 5-mi (8-km) 

radius of the Discovery Ridge site (NWMI 2015a). This feature was studied as part of siting 

studies by Union Electric Company. The Fox Hollow fault is a normal fault that fades into a 

monoclinal fold at its two ends. The northeast-striking fault terminates approximately 3 mi 

(4.8 km) south of the site. This fault reportedly exhibits a throw (vertical displacement) of 

approximately 120 ft (37 m) to the southwest with Mississippian-aged Chouteau Limestone beds 

faulted against Ordovician-aged Jefferson City Dolomite. No surface expression of this fault 

was noted during field surveys, and there is no evidence of recent activity or displacement of 

overlying strata (NWMI 2015a, 2015h). 
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Figure 3–12. Bedrock Geology of the Discovery Ridge Site and Vicinity 

Source: Modified from NWMI 2015a, 2015h

MGS-maintained mapping data for known structural features identify a set of several features as 

comprising the trace of the Fox Hollow fault and monocline. Traces of this feature run in a 

southerly direction for a total of 8.5 mi (13.6 km) before intersecting with and crossing a 

northwest-striking feature (Sapp monocline) at a point located about 10 mi (16 km) 

south-southwest of the site (MGS 2016).

Available information indicates that there has been no movement on this fault during the 

Holocene (i.e., during the last 11,700 years). Further, the structure is considered to be early 

Paleozoic in age and does not constitute an earthquake hazard (MU 2006). The NRC staff’s 

review of the USGS’s latest release of the Quaternary Fault and Fold Database found no record 
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of Quaternary faults or folds within a 50-mi (80-km) radius of the proposed site (USGS 2015b). 

Based on available information, the NRC staff does not consider the fault to be active at present 

or represent a “capable fault” as defined in Appendix A to 10 CFR Part 100, “Seismic and 

Geologic Siting Criteria for Nuclear Power Plants.”

Nevertheless, liquefaction features in the St. Louis area (St. Louis–Cape Girardeau features), 

located about 100 mi (160-km) east of the site, as well as the Wabash Valley liquefaction 

features further to the east in southern Illinois, indicate the presence of active and recurrent 

faulting and associated earthquake activity in the Holocene. Thus, these features indicate the 

likely presence of capable faults in the St. Louis–Cape Girardeau and Wabash Valley regions. 

More significantly, situated approximately 200 mi (320 km) southeast of the site at its closest 

point is the seismically active region associated with the Reelfoot scarp and New Madrid 

Seismic Zone (USGS 2015b; Crone and Wheeler 2000). Section 3.3.3 further describes the 

seismic setting, including earthquake risk, at the Discovery Ridge site.

Geologic resources, encompassing rock and mineral (fuel and nonfuel) resources, in the vicinity 

of the site have historically included limestone and refractory clay, as well as lead, zinc, and 

coal (Thompson 1979). Exposures of Burlington Limestone have been an important resource 

and serve as the host rock for lead and zinc deposits in the Tri-State mining district of Missouri, 

Kansas, and Oklahoma (NWMI 2015a). Northern Boone County encompasses major coal 

producing strata and southern Boone County has high-calcium limestone resources, as noted 

above. Sand and gravel deposits are also available throughout Boone County and surrounding 

counties in central Missouri from glacial and floodplain materials (MDNR 2001; USGS 2015c).

3.3.2 Soils

A preliminary geotechnical investigation of the Discovery Ridge Research Park found that site 

soils predominantly consist of lean to fat clay and fat clay, as further described in Section 3.3.1. 

Soil unit mapping by the NRCS identifies the majority of the Discovery Ridge site (75 percent) 

as Mexico silt loam, 1 to 4 percent slopes, eroded. This mapping unit generally comprises the 

middle interior of the site while the remaining four corner areas of the site are comprised of 

Armstrong loam, 5 to 9 percent slopes, eroded (NRCS 2016a).

The predominant Mexico soils are silty clay loams and silty clay whereas the Armstrong soils 

are clay loams and clays, with both typically found on hill slopes. Mexico soils are poorly 

drained soils that developed from loess (wind-deposited sediment) overlying pedisediment. 

Pedisediments are alluvial materials transported from upslope areas onto an eroded soil

surface. Armstrong soils are somewhat poorly drained materials that derive from loess deposits 

atop glacial till. Both soils have a low infiltration rate (due to clay) and a very high runoff rate as 

a result. The depth to the water table in these soils generally ranges from 6 to 36 in. (15 to 

91 cm) (NRCS 2016a).

As reflected in the preliminary geotechnical investigation conducted by Terracon (2011a) and as 

indicated in the NRCS characterizations presented above, soil conditions present a number of 

site development challenges. As a building site, the soils are rated as poorly suited for 

excavation work because of the depth to the saturated zone, high clay content, and instability of 

excavation walls. In addition, due to the presence of clays with a high/shrink swell potential, as 

previously discussed in Section 3.3.1, the soils are rated as very limited for constructing 

commercial buildings. Shrink/swell potential and the relatively shallow depth to the zone of 

saturation adversely affect the ability of soils to support structural loads (e.g., building slabs, 

foundations, and pavement structures) without movement and also affect the workability of site 

soils during construction (NRCS 2016a). NWMI will conduct site-specific geotechnical and 
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hydrologic studies of the Discovery Ridge site (NWMI 2015c, 2016e). These studies would help 

to support final facility design and construction planning.

Neither of the onsite soil mapping units are prime farmland or other important farmland soils as 

defined in the Farmland Protection Policy Act of 1981 and implementing regulations 

(7 CFR Parts 657, 658; NWMI 2015a).

3.3.3 Seismic Setting

Northeast Missouri is located within the central stable region of the North American craton. The 

region has had a relatively gentle tectonic history since the beginning of the Paleozoic Era in 

contrast to adjoining regions (NRC 2014; Reed and Bush 2007; NWMI 2015h). More 

tectonically active areas that border northeast Missouri to the east and south include the Ozark 

Uplift, Mississippi Embayment, and the Ouachita Mountain System (Reed and Bush 2007). 

Across the stable continental region of the United States, most locations can go years without 

an earthquake strong enough for people to feel. In the central and eastern United States, 

people can feel earthquakes over a very wide area. For example, people can feel a magnitude 

4.0 earthquake at locations as far as 60 mi (100 km) from its source (epicenter) and it may 

cause damage near its source. An earthquake with a magnitude of 5.5 can be felt as far away 

as 300 mi (500 km) from its source and can cause damage as far as 25 mi (40 km) away. 

Usually, the earthquakes that do occur in the eastern and central United States are not 

traceable to a mapped geologic fault.

Typical of the central United States, the Discovery Ridge site is located within one of the lower 

earthquake hazard areas in the conterminous United States (NWMI 2015a, 2015h). National 

seismic hazard data and mapping products maintained by the U.S. Geological Survey (USGS) 

indicate that earthquake sources in southeast Missouri, associated with the New Madrid 

Seismic Zone, are the primary driver of earthquake hazard in northeast Missouri 

(Petersen et al. 2015).

The New Madrid Seismic Zone is associated with reactivated faults that originally formed when 

North America began to split or rift apart in Cambrian or late pre-Cambrian time (approximately 

500 Ma). While rifting ceased, a zone of structural weakness was created, known as the 

Reelfoot rift (NWMI 2015a, 2015h). The mapped extent of this zone runs for approximately

150 mi (240 km) southward from near Cairo, Illinois, through New Madrid and Caruthersville, 

Missouri, down through Blytheville, Arkansas, to Marked Tree, Arkansas (NWMI 2015a, 2015h; 

USGS 2014b). New Madrid was the center of the largest earthquakes ever recorded in the 

central and eastern United States. A series of earthquakes occurred around New Madrid, 

Missouri, in 1811–1812 and ranged in magnitude from about 7.0 to 7.5 (USGS 2014b, 2015d). 

On the Modified Mercalli Intensity (MMI) scale (USGS 2014c), the intensity of these 

earthquakes ranged from MMI XI to XII (very disastrous to catastrophic shaking) at the 

epicenter and were estimated to have produced shaking of up to MMI VII (capable of causing 

slight to moderate damage to structures) in central Missouri (USGS 2014b).

Consistent with the above characterization, and as delineated in Boone County’s Hazard 

Mitigation plan based on Missouri State Emergency Management Agency projections, Boone 

County lies within the MMI VII shaking intensity zone (“very strong” zone) from postulated 

earthquakes occurring in the New Madrid Seismic Zone. Additionally, projections made by the 

State Emergency Management Agency indicate that for the period 2002 to 2052, there is a 25 to 

40 percent probability of a magnitude 6.7 earthquake and a 7 to 10 percent probability of a 

magnitude 7.6 earthquake within the New Madrid Seismic Zone. These events could be 

expected to result in MMI VI (slight damage) to MMI VII (significant damage to poorly built 
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structures) shaking intensities, respectively, across Boone County (NWMI 2015h; 

MMRPC 2015).

No earthquakes are known to have had epicenters within Boone County (MU 2006). Since 

1976, a total of 104 earthquakes with a magnitude equal to or greater than 2.5 have occurred 

within a radius of 200 mi (322 km) of the Discovery Ridge site. The vast majority of these 

earthquakes had epicenters more than 90 mi (140 km) to the east and south in association with 

the Wabash Valley and New Madrid seismic zones, respectively. The closest of these events 

occurred on July 31, 2005, near Tipton, Missouri, approximately 27 mi (43 km) southwest of the 

Discovery Ridge site. The earthquake had a magnitude of 3.3 and produced MMI III to IV (weak 

to light) shaking near the epicenter, but it was not generally felt north of the Missouri River into 

Boone County. Over the last 40 years, the largest earthquake in the region was a magnitude 

4.7 earthquake on September 26, 1990. This earthquake was centered south of Cape 

Girardeau near Kelso, Missouri, about 165 mi (265 km) southeast of the Discovery Ridge site. It 

produced MMI VI (strong) shaking near the epicenter and caused slight damage in Kelso, 

Chaffee and other nearby communities. This earthquake was widely felt in southeast Missouri 

as well as in parts of Arkansas, southern Indiana, western Kentucky, and into parts of 

Tennessee and Ohio, according to reports to the USGS (USGS 2016a).

USGS national seismic hazard data and mapping products specifically provide risk-informed 

information on probabilistic earthquake ground motions for various return periods. As noted by 

NWMI (NWMI 2015h), the probabilistic ground motion estimates and current state of 

geophysical knowledge used in seismic hazard mapping are applied to the seismic design 

provisions of governing building codes across the Nation, although the ground motions used for 

building design are not identical to those from the USGS seismic hazard maps. Nevertheless, 

the USGS probabilistic seismic hazard maps provide a quantitative assessment of relative 

seismic risk. USGS published its latest seismic hazard data and map updates in 2015 

(Petersen et al. 2015).

Based on the USGS’s latest seismic hazard mapping data (Petersen et al. 2015), the Discovery 

Ridge site lies within the fourth lowest hazard area with predicted peak ground accelerations of 

0.06 to 0.08 g (i.e., the force of acceleration relative to that of Earth’s gravity, g). For the 

corresponding response spectral accelerations (SA), the site falls within the 0.16 to 0.20 g 

contours for the 0.2-second SA and the 0.08 to 0.10 g contours for the 1.0-second SA. SA 

values reflect the response of structures to vibratory ground motion. These values all represent 

shaking from an earthquake with a 2-percent probability of exceedance (PE) in the next 

50 years (i.e., an earthquake with a 2,475-year return period). These values are based on a 

standard reference condition (firm rock), and ground motions on less competent rock or soil

would differ.

As documented in the preliminary safety analysis report, NWMI performed a preliminary seismic 

design analysis to assess the potential maximum earthquake ground motions for the Discovery 

Ridge site. Derived ground motion SAs were calculated for site-specific conditions (i.e., for a 

stiff soil profile (Site Class D)). For a 2-percent PE in 50 years, the analysis yielded maximum 

earthquake accelerations ranging from 0.341 g (0.2-second period SA) to 0.223 g (1.0-second 

period SA). The NRC staff will further evaluate the potential maximum earthquake and other 

seismic design considerations in the Safety Evaluation Report related to the NWMI construction 

permit application.

3.4 Water Resources

Water resources comprise all forms of surface water and groundwater occurring near a site. 

Surface water encompasses all water bodies that occur above the ground surface, including 
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rivers, streams, lakes, ponds, and other features, such as human-made reservoirs or other 

impoundments. Groundwater is water that is below the ground surface within a zone of 

saturation, with the uppermost groundwater surface comprising the water table. Aquifers are 

subsurface geologic formations capable of yielding a significant amount of groundwater to wells 

or springs. Lesser amounts of groundwater may also occur in areas above the saturated zone 

in the form of relatively small and isolated lenses or pockets of groundwater known as “perched” 

groundwater.

3.4.1 Surface Water

3.4.1.1 Surface Water Hydrology

The Missouri River is the dominant surface water body in Boone County. The Discovery Ridge 

site is located about 8 mi (13 km) northeast of the river at its closest point. A well-developed 

dendritic drainage pattern exists across much of Boone County. Surface waters in central and 

southern Boone County drain into the Missouri River through a number of tributaries, including 

Bonne Femme, Cedar, Little Cedar, Hinkson, Jemerson, and Perche Creeks. Figure 3–13

shows the named tributaries within a 5-mi (8-km) radius of the Discovery Ridge site, including 

Bonne Femme, Clear, Little Bonne Femme, Little Cedar, and Hinkson Creeks. In addition, a 

large lake, Perry Phillips Lake, is located approximately 0.75 mi (1.2 km) west of the site but is 

not in the drainage area of the site (NWMI 2015a).

No natural surface water features (e.g., headwater tributaries to streams) originate on the 

proposed Discovery Ridge site. The Discovery Ridge site currently drains south and southwest 

towards the southwesterly flowing Gans Creek, located approximately 0.35 mi (0.56 km) south 

of the site at its closest point (see Figures 3–11 and 3–13). Based on observations made by the 

NRC staff during the environmental site audit in September 2015, most site drainage occurs as 

overland sheet flow across the site with some drainage conveyed to ditches that border an 

access road associated with the future extension of Discovery Drive that would connect land 

parcels bordering the proposed site to the south. The NRC staff observed that these ditches 

convey runoff further southwest across Lot 9 of the Discovery Ridge Research Park via a 

meandering drainage way and toward an engineered drainage channel that parallels 

U.S. Highway 63.

This channel ultimately discharges to Gans Creek south of the site. Topographic maps 

(USGS 2015a), historical photography, and other records reviewed by Terracon (2011a) 

indicate that at least some of these drainage features may mark the remnants of a headwater 

tributary to Gans Creek. Nevertheless, the engineered drainage channel receives runoff from 

surrounding parcels and drainage and overflow from an existing human-made lake (located to 

the northwest of the Discovery Ridge site and immediately adjacent to the existing IDEXX 

BioResearch facility), which serves as a stormwater management pond and has an associated 

drainage channel.
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Figure 3–13. Major Surface Water Features in the Vicinity of the Discovery Ridge Site

Source: Modified from NWMI 2015a

The lake was created by the University of Missouri R1 Dam. The lake is ultimately destined to 

serve various lots within the Discovery Ridge Research Park, as shown in construction maps for 

the research park (NWMI 2015a; MU 2009). This lake was originally constructed between 1948 

and 1959, as reported by Terracon (2011a) (see Figure 3–11). The lake covers about 20 ac 

(8 ha) (NWMI 2015a).

Additionally, there is another surface water feature just to the northeast of the NWMI facility site, 

a large farm pond (Figure 3–11). This pond was constructed in the headwaters area of a 

south-flowing ephemeral tributary to Gans Creek. The pond is estimated to be about 4 ac 

(0.4 ha) in size. The shallow tributary may receive overflow and seepage from the pond, but it is 

not affected by runoff from the Discovery Ridge site.
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Regardless, Gans Creek is the major surface water body in proximity to the Discovery Ridge 

site. This perennial to intermittent stream is located within the Bonne Femme (Creek) 

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

) (241 square 

kilometers (km2

)). The Discovery Ridge site lies within the northern portion of this 

watershed–Little Bonne Femme sub-watershed (Frueh 2007; NWMI 2015a).

From just south of the site (Figure 3–13), Gans Creek flows beneath U.S. Highway 63 and 

continues west to southwesterly in a winding path for approximately 6 stream mi (9.7 km) before 

joining Clear Creek. At this confluence, the Little Bonne Femme Creek begins. Little Bonne 

Femme Creek continues flowing southwesterly for some 9 mi (14 km) along a winding course 

before entering the Missouri River. Approximately 2 mi (3.2 km) south of the mouth of Little 

Bonne Femme Creek, Bonne Femme Creek discharges to the Missouri River (Frueh 2007; 

NWMI 2015a).

The Bonne Femme watershed is situated on karst terrane, as referenced in Section 3.3.1. 

Surface water hydrology is complex because of the presence of losing (sinking) and gaining 

sections of streams where surface water can easily enter the subsurface, providing flow to other 

streams. Karst streams, and underlying groundwater, are very susceptible to upgradient 

pollutant sources and contaminant transport. Within the watershed, there are two main 

recharge areas tied to these losing and gaining sections of stream, the Devil’s Icebox cave and 

the Hunter’s Cave recharge areas (Frueh 2007; NWMI 2015a). Carlson et al. (2005) states that 

Gans Creek is the first gaining stream due to surface water lost through the Devil’s Icebox cave. 

Thus, the Bonne Femme and Little Bonne Femme creeks are interconnected where surface 

water lost from Bonne Femme Creek is lost through the Devil’s Icebox Cave Branch (across the 

surface water divide) into Gans Creek and is eventually discharged to Little Bonne Femme 

Creek (Figure 3–13) (Frueh 2007; NWMI 2015a). None of the streams within the Bonne 

Femme watershed have active stream gaging stations. In general, streams within the 

watershed exhibit a low base flow with flow rising appreciably in response to precipitation events 

(Frueh 2007).

There are no floodplains on the Discovery Ridge site. The site and adjacent parcels are located 

within areas mapped as outside the 500-year flood elevation. The Federal Emergency 

Management Agency has delineated the floodplain boundary for Gans Creek. The Discovery 

Ridge site is located approximately 1,400 ft (425 m) north of the 100-year floodplain, and the 

base elevation of the site lies some 40 ft (15 m) above the floodplain (FEMA 2011a; 

NWMI 2015h). Therefore, the site is not readily subject to stream flooding.

3.4.1.2 Surface Water Quality and Use

Existing and proposed activities within a watershed are regulated under various provisions of 

the Federal Water Pollution Control Act (i.e., Clean Water Act of 1972, as amended (CWA) 

(33 U.S.C. 1251 et seq.)). Congress enacted the CWA with the goal of restoring and 

maintaining the chemical, physical, and biological integrity of the Nation’s surface waters.

In accordance with Section 303(c) of the CWA, States have the primary responsibility for 

establishing, reviewing, and revising water quality standards for the Nation’s navigable surface 

waters. Such standards include the designated uses of a water body or waterbody segment, 

the water quality criteria necessary to protect those designated uses, and an anti-degradation 

policy with respect to ambient water quality. As set forth under CWA Section 101(a), water 

quality standards are intended in part to provide for the protection and propagation of fish, 

shellfish, and wildlife and recreation in and on the water. The EPA retains a role in reviewing 

state-promulgated water quality standards to ensure that they meet the goals of the CWA and 

Federal water quality standards regulations (40 CFR Part 131).
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The State of Missouri, like other States, has established water quality standards, numeric 

criteria, and associated designated use categories for all waters of the State, including 

jurisdictional wetlands. Water quality standards provide a means by which attainment of water 

quality objectives can be measured. The objective is protection of designated uses through the 

application of narrative or numeric criteria. The level of protection given to a stream, lake, or 

river is dependent on the expected or “designated use(s)” of that water. The State frequently 

derives effluent limits contained in National Pollutant Discharge Elimination System (NPDES)

permits from water quality standards (MDNR 2016b). NPDES permits are issued in accordance 

with CWA Section 402. Streams, lakes, and rivers that have identified beneficial uses and have 

some water year round also have designated hydrologic classifications. Water quality 

standards, designated beneficial uses, and hydrologic classifications of waters of the State are 

specified in Title 10, Division 20, Chapter 7 of the Missouri Code of State Regulations.

Within the State, all perennial rivers and streams, streams with permanent pools, and lakes and 

reservoirs that intersect the flow lines of perennial rivers and streams are designated for the 

following beneficial uses: aquatic habitat protection; human health protection, whole body 

contact recreation, and secondary contact recreation; and livestock and wildlife protection and 

irrigation (10 CSR 20-7.031). These uses apply to Gans Creek and other major streams within 

a 5-mi (8-km) radius of the Discovery Ridge site. Furthermore, a 3 mi (4.8 km) section of Gans 

Creek is classified by the State as an Outstanding State Resource Water (10 CSR 20-7.031) 

and denoted as an environmentally sensitive area by Boone County (Boone County 2016a). 

Outstanding State Resource Waters are high-quality waters with a significant aesthetic, 

recreational, or scientific value and specifically designated as such by the State’s Clean Water 

Commission. Such waters may require exceptionally stringent water quality management 

requirements to assure conformance with the State’s antidegradation policy. This special 

segment of Gans Creek is located within the Rock Bridge Memorial State Park, located 

approximately 3 mi (4.8 km) southwest of the Discovery Ridge site (see Figure 3–13).

From a hydrologic perspective, Little Bonne Femme and Bonne Femme Creeks and Hinkson 

Creek are Class P streams (i.e., streams that maintain permanent flow even in drought periods) 

(Boone County 2016a; MDNR 2015a). Gans Creek is a Class C stream, which is a stream that 

may cease flow in dry periods but maintain permanent pools that support aquatic life 

(MDNR 2015a).

CWA Section 303(d) requires States to identify all “impaired” waters for which effluent limitations 

and pollution control activities are not sufficient to attain water quality standards in such waters. 

Similarly, CWA Section 305(b) requires states to assess and report on the overall quality of 

waters in their state. States prepare a 303(d) “list” that comprises those water quality limited 

stream segments that require the development of total maximum daily loads (TMDLs) of 

pollutants to assure future compliance with water quality standards. The list also identifies the 

pollutant or stressor causing the impairment, and establishes a priority for developing a control 

plan to address the impairment. The TMDLs specify the maximum amount of a pollutant that a 

waterbody can receive and still meet water quality standards. Once established, States typically 

implement TMDLs through watershed-based programs, primarily through the NPDES permit 

program and associated point and nonpoint source water quality improvement plans and best 

management practices. States are required to update and resubmit their impaired waters list 

every 2 years. This process ensures that impaired waters continue to be monitored and 

assessed until applicable water quality standards are met.

Several of the streams within a 5-mi (8-km) radius of the Discovery Ridge site are either 

included in their entirety or have segments included in the State of Missouri’s 303(d) list 

(NWMI 2015a; MDNR 2014a, 2015a). In particular, Gans Creek continues to be listed as 

impaired due to water-borne E. coli bacteria. It was first listed in 2012. The reason for its listing 
Affected Environment

3-31

is impairment of the beneficial use for whole body contact recreation; the identified pollutant 

source is a rural nonpoint source runoff. Similarly, Little Bonne Femme and Bonne Femme 

Creeks are also listed as impaired due solely to E. coli. An extensive study to characterize the 

hydrologic and water quality characteristics of the Bonne Femme watershed, and further 

focusing on the karst areas of the watershed, was conducted between 2003 and 2007. The 

CWA Section 319 grant-funded effort was directed by a steering committee composed of 

members from local, State, and Federal agencies. The effort culminated in the development of 

a watershed plan for use as a tool for use in preventing further watershed degradation and 

maintenance of the long-term quality of water resources within the watershed (Frueh 2007).

Water quality studies conducted as part of the watershed investigation included establishing 

monitoring sites at a number of surface sub-watershed locations. Of particular relevance to the 

Discovery Ridge site, these included monitoring locations on Clear Creek, Gans Creek, Upper 

Bonne Femme Creek, Little Bonne Femme Creek, and at the two karst recharge areas including 

Devil’s Icebox cave. Samples were collected at all sites once per quarter beginning in 2003. In 

addition to measurement of standard physical and water quality parameters, samples were 

analyzed for various herbicides and for the presence of bacterial contamination. In summary, 

general water quality parameters were found to be typical for streams in carbonate bedrock 

areas. Dissolved oxygen levels exceeded the State standard of 5 milligrams per liter (mg/L). 

Nutrient levels were similar to or less than streams in other comparable agricultural watersheds, 

and there was no indication of acute contamination at any site. Although field observations and 

monitoring results revealed nuisance algal growth, no excess nutrient enrichment 

(eutrophication) was found at any site. One or more herbicides was detected at every site but 

generally at low levels. Widespread fecal bacterial contamination was evident, with the highest 

levels found during the spring and summer. The fecal bacteria standard for whole body contact 

was frequently exceeded. The primary cause of bacterial contamination at most sites was 

attributed to cattle grazing (Frueh 2007).

The NPDES permit program, as referenced above, addresses water pollution by regulating point 

sources (i.e., pipes, ditches) that discharge pollutants to waters of the United States 

(40 CFR Part 122; EPA 2016g). Regulated pollutant discharges include, but are not necessarily 

limited to, the discharge of facility wastewater and stormwater associated with construction or 

industrial activity at a site. NPDES permits set forth effluent limits on the discharge and also 

prescribe effluent monitoring, reporting, and other requirements to ensure that permit terms are 

being met. Regulated facilities may either require an individual NPDES permit or qualify for a 

general permit (i.e., a generic permit appropriate for covering a class of dischargers in a 

geographic area with similar characteristics) (EPA 2016g; MDNR 2016c). The State of Missouri 

is among the many states that have been authorized by EPA to perform many of the permitting, 

administrative, and enforcement aspects of the NPDES program, with EPA retaining oversight 

responsibilities (EPA 2016g). The State of Missouri was first authorized by EPA to assume 

NPDES permitting authority in 1974; it received general permit authority in 1985. The State of 

Missouri’s regulations for administering its NPDES permit program are contained in Title 10, 

Division 20, Chapter 6 of the Missouri CSR (10 CSR 20-6.010 and 10 CSR 20-6.200). In 

addition to State-administered NPDES permit requirements, local jurisdictions, including the 

City of Columbia, have additional requirements for site development, wastewater discharge, and 

stormwater management.

The discharge of wastewater to a municipal sanitary sewer system, as proposed by NWMI for 

the disposal of facility-generated wastewater, does not require an NPDES permit. A wastewater 

treatment plant (i.e., publicly owned treatment works (POTW)), where sanitary wastewater is 

ultimately treated, operates under its own NPDES permit. Wastewater collected by the City of 

Columbia’s sanitary sewer system is treated at the Columbia Regional Wastewater Treatment 
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3-32

Plant. The plant has a design treatment capacity of approximately 20 million gallons per day 

(mgd) (75,700 cubic meters/day (m3

/day)) (City of Columbia 2016c).

The introduction of wastewater to a POTW constitutes an “indirect discharge” that is excluded 

from the definition of “discharge of a pollutant” to waters of the United States (40 CFR 122.2). 

However, in accordance with CWA Section 307 and EPA’s pretreatment regulations

(40 CFR Part 403), the discharge of pollutants from non-domestic (e.g., industrial) sources to 

such systems must meet local (municipal) acceptance criteria and other applicable 

requirements. This is to avoid interfering with the POTW in a manner that might result in a 

violation of the POTW’s NPDES permit and/or water quality standards (EPA 2015b). For this 

purpose, the City of Columbia Sanitary Sewer Utility that serves the Discovery Ridge site has 

specific regulations in the City’s Code of Ordinances (Chapter 22, Article VI, “Sewers and 

Sewage Disposal”) to address unlawful discharges, influent limits, and applicable pretreatment 

requirements (NWMI 2015a; City of Columbia 2015).

In addition, CWA Section 401 requires an applicant for a Federal license or permit to conduct 

any activities that may result in any discharge of regulated pollutants into navigable waters to 

provide the licensing agency with a water quality certification from the state in which the 

discharge would occur. This certification indicates that discharges from the project or facility to 

be licensed will comply with CWA requirements and will not cause or contribute to a violation of 

state water quality standards. If the applicant has not received Section 401 certification, the 

NRC cannot issue a license unless that state has otherwise waived the requirement. The State 

of Missouri’s regulations for administering its water quality certification program are contained in 

Title 10, Division 20, Chapter 6 of the Missouri CSR (10 CSR 20-6.060).

3.4.2 Groundwater

3.4.2.1 Site Description and Hydrogeology

The Discovery Ridge site is located within the Northeast Missouri Groundwater Province 

(MDNR 2016d). Groundwater beneath the proposed Discovery Ridge site and across Boone 

County occurs in unconsolidated and consolidated water-bearing deposits (aquifers). The 

following discusses the general hydrostratigraphy and other characteristics of these aquifers.

The USGS has broadly classified and grouped the distinct water-bearing geologic units 

(aquifers) that occur in northeast Missouri. These include the water-bearing sediments 

associated with the surficial aquifer system and two bedrock aquifer systems—the Mississippian 

aquifer system and the deeper Cambrian-Ordovician aquifer system (NWMI 2015a, 2016a; 

Miller and Appel 1997).

Across northeastern Missouri, the surficial aquifer consists mainly of stream-valley fill deposits. 

These deposits include narrow bands of fluvial and alluvial sediments lying within the valleys 

where rivers and streams have eroded shallow channels into glacial deposits. In southern 

Boone County, these materials are essentially limited to the Missouri River valley (Boone 

County Commission 1996; Miller and Appel 1997). Alluvial deposits consisting of sand and 

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

/min)) are 

possible from properly constructed wells (MDNR 2016c).

The shallow glacial drift is not considered a suitable water source due to the limited thickness of 

the water-bearing strata, low storage, and vulnerability to contamination (MDNR 2016d). As 

described in Section 3.3.1, the combined thickness of glacial drift and other overburden at the 

Discovery Ridge site is approximately 25 ft (7.6 m). Groundwater occurring in these materials 

generally moves from areas of higher elevation to discharge points along streams.
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In northern Missouri, the Mississippian aquifer is the uppermost aquifer, with the overlying 

Pennsylvanian age strata not considered a major aquifer. The Mississippian aquifer extends 

over all of Missouri north of the Missouri River, except to the south near the Mississippi and the 

Missouri Rivers where the rocks that compose the aquifer have either been partially or 

completely removed by erosion. This aquifer encompasses Mississippian age carbonate rocks 

(principally limestones), including the Keokuk, Burlington, Fern Glen, Sedalia, and Chouteau 

limestone units (see Section 3.3.1). The Keokuk and the Burlington are the principal 

hydrogeologic units. Both units consist of crystalline limestone and yield water primarily from 

solution cavities (NWMI 2015a, 2016a; Miller and Appel 1997).

Carbonate rocks comprising the Mississippian aquifer in northeastern Missouri are 

stratigraphically equivalent to those of the uppermost aquifer (i.e., Springfield Plateau aquifer) of 

the Ozark Plateaus aquifer system that extends south from Boone County into southern 

Missouri. However, east of Boone County, Missouri, the two aquifers have little or no hydraulic 

connection (Miller and Appel 1997). Pennsylvania-age shale and sandstone generally overlies 

the Mississippian aquifer in most places, acting as a confining unit. A confining unit comprised 

of Mississippian-age shale underlies the aquifer in all locations (NWMI 2015a; Miller and 

Appel 1997). However, the Mississippian aquifer is reported as generally unconfined in the 

region of the Discovery Ridge site (NWMI 2016a).

Across central and northern Boone County, the units of the Mississippian aquifer average about 

200 ft (60 m) thick, but the thickness increases to the northwest and thins to the south as 

discussed above (Miller and Appel 1997; NWMI 2016a). A review conducted by NWMI of well 

logs from four wells within a 1-mi (1.6-km) radius of the site indicates that the total thickness of 

Mississippian age strata is about 240 ft (73 m) (NWMI 2016a).

Recharge of the uppermost aquifer units occurs primarily from precipitation over aquifer outcrop 

areas or infiltration and leakage down through the overburden and from the overlying glacial drift 

aquifers, where present. However, some recharge may also occur through vertical leakage 

from the underlying Cambrian-Ordovician aquifer system. The direction of groundwater flow in 

the uppermost aquifers beneath the County is generally to the south and southwest with 

discharge to major streams (Miller and Appel 1997).

The MDNR maintains extensive geospatial data sources on groundwater resources. This 

includes data extracted from well driller logs submitted to the State. Available MDNR data 

indicate that the static water level in the uppermost aquifer beneath the site ranges between 625 

and 650 ft (190 and 200 m) MSL (NWMI 2015a; 2016a; MGS 2016). For comparison, the 

mapped depth to groundwater (as measured from the land surface) in the area of the Discovery 

Ridge site ranges between 110 to 120 ft (34 to 37 m) bgs (MGS 2016).

The Cambrian-Ordovician aquifer system underlies the Mississippian system across the 

northeastern portion of Missouri north of the Missouri River and encompassing Boone County. 

Like the Mississippian aquifer, units within the Cambrian-Ordovician aquifer are stratigraphically 

equivalent to parts of the Ozark Plateaus aquifer system of southern Missouri. While a major 

water source across the Midwest as a whole, its use in northern Missouri is limited to eight 

counties just north of the Missouri River, including Boone County, where salinity levels are low 

enough to make the water potable (Miller and Appel 1997; Wilson 2012). In this eight-county 

area, this system is the principal water supply source (USGS 1985). In this eight-county area, 

the hydrogeologic flow system has been shown to be independent of the regional saline-water 

flow system in northern Missouri (Wilson 2012).

The hydrostratigraphy of the Cambrian-Ordovician aquifer system is principally comprised of 

carbonate rocks (limestones, dolomites) and sandstones of marine origin with shalely confining 

units. Significant water-bearing strata within the system, in descending order, include the 
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3-34

Roubidoux (sandstone) Formation and Gasconade Dolomite of Ordovician age and the 

Cambrian Eminence and Potosi Dolomites (Miller and Appel 1997). On a broader regional 

basis, the major aquifer zones are the sandstones, which are separated by leaking confining 

units comprised of dolomite, shale, shaley sandstone, or a combination of these types. Across 

northern Missouri, the aquifer is confined by the Ordovician age Maquoketa Shale 

(Wilson 2012).

Within the northeastern Missouri counties, the local aquifer is also referred to as the KimmswickPotosi aquifer. It is named for the Ordovician age Kimmswick Limestone and the Potosi Dolomite, 

which are the geologic units that mark its upper and lowermost extent in the subsurface 

(USGS 1985). These units are part of the recognized Cambrian-Ordovician aquifer system.

In total, the Cambrian-Ordovician aquifer system attains a thickness of up to 1,500 ft (460 m) 

below southern Boone County. Flow within the system is generally south with discharge to the 

Missouri River (Miller and Appel 1997).

NWMI reviewed historical well records for water supply, monitoring, and related well records 

within a 1-mi (1.6-km) radius of the site on file with the MDNR (NWMI 2016a). These records, 

for wells with total completion depths ranging from 505 to 1,250 ft (154 to 380 m), indicate a 

depth to groundwater in the aquifer ranging from about 180 to 325 ft bgs (NWMI 2016a; 

MDNR 2016e). A review of well logs indicates that these wells are completed in and draw water 

from the Cambrian-Ordovician aquifer system. In general, wells completed in the CambrianOrdovician aquifer system yield from 15 up to 1,000 gpm (0.06 to 3.8 m3

/min) of water 

(USGS 1985). Similarly, MDNR (2002b) states that wells developed in the Mississippian 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

/min), with wells 

exceeding 1,000 gpm (3.8 m3

/min) including from the Columbia, Missouri area.

As part of the preliminary geotechnical investigation of the Discovery Ridge site and vicinity, 

Terracon (2011a) installed a number of soil borings in the glacial drift and uppermost bedrock 

(see Section 3.3.1). Terracon only observed groundwater in two of the borings at depths of 

approximately 12 to 18.5 ft (3.7 and 5.6 m) bgs. This included the one boring installed near the 

proposed NWMI facility site within Lot 15, where saturated conditions were encountered at a 

depth of 12 ft (3.7 m) bgs (Terracon 2011a). Nevertheless, Terracon indicated that the borehole 

observations made for the presence of groundwater may have been affected by the low 

permeability of the surficial materials. The low permeability soils may not have allowed water, 

even if present, to flow into all the boreholes during the relatively short period of time they were 

left open for observation. As referenced by Terracon (2011b), pockets and lenses of more 

permeable and water-bearing glacial materials occur in the vicinity of the site, leading to 

“perched” groundwater. NWMI has indicated that given the high water content of the site soils 

at the time the borings were completed, the “groundwater” observed in the boring holes may 

have been the result of water introduced into the holes during drilling operations (NWMI 2016a).

Furthermore, only two of the borings were advanced far enough to bedrock, at depths of 

approximately 17 and 13 ft (5.1 and 4.0 m) bgs. No groundwater monitoring wells have been 

installed on the site to determine the static water table elevation or the depth to groundwater in 

the uppermost bedrock aquifer beneath the Discovery Ridge site. Overall, the NRC staff 

considers Terracon’s observations and assessments reasonable and that the available data 

suggest that any lenses or pockets of perched groundwater underlying the Discovery Ridge site 

are likely to be of limited lateral and horizontal extent. 
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3.4.2.2 Groundwater Quality and Use

Boone County’s groundwater resources are characterized as large in volume and of high quality 

(Boone County Commission 1996). The County’s public water supply systems obtain nearly all 

of its potable water from groundwater via deep wells. Across northern Missouri, water from the 

Cambrian-Ordovician aquifer system ranges from fresh to saline but is generally of good quality 

in a band parallel to and north of the Missouri River from Boone County and east to the 

Mississippi River.

Within Boone County, groundwater is principally supplied from two aquifer units, the Roubidoux 

and the Gunter Member (Boone County Commission 1996). The Roubidoux Formation and 

Gunter Sandstone Member of the Van Buren Formation are aquifer units within the 

Cambrian-Ordovician aquifer system. It should be noted, however, that production wells in 

large aquifer systems typically draw from more than a single hydrostratigraphic unit. Across 

Boone County, the concentration of total dissolved solids from the aquifer is approximately 

500 mg/L (Miller and Appel 1997). Groundwater produced across northeastern Missouri from 

Cambrian-Ordovician strata is generally of the calcium magnesium, bicarbonate-type and hard 

to very hard (USGS 1985). Hardness is generally the result of high concentrations of calcium 

and magnesium.

Five separate water districts produce and distribute potable water to the majority of Boone 

County (Boone County 2013). The districts operate as independent public utilities, regulated by 

the State of Missouri. These districts were originally formed for the purposes of meeting the 

needs of rural populations and of agriculture (Boone County Commission 1996). The Discovery 

Ridge site lies within the service area of Consolidated Public Water Supply District No. 1, and it 

would supply water to the proposed NWMI facility site (NWMI 2015a, 2016a). This district 

serves most of the southern and western portions of the County but has interconnections with 

adjoining districts, including the City of Columbia, for contingency purposes. A system of 

13 deep wells supply the district. The system has a total groundwater production capacity of 

11 mgd (49,200 m3

/day) (NWMI 2015a; CPWSD 2016).

Groundwater is used extensively and almost exclusively across Boone County for a wide range 

of purposes, as summarized in 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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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

/day). Water to meet irrigation and 

thermoelectric power generation needs constitute the next largest water use categories in the 

County.

As previously discussed (Section 3.4.2.1), NWMI compiled a list of water supply and other wells 

within a 1-mi (1.6-km) radius of the Discovery Ridge site based on information sources 

maintained by the MDNR. The NRC staff reviewed the information provided by NWMI 

(NWMI 2016a) and other available information. Based on this review, the closest domestic 

supply well identified (well no. 394516) is located approximately 0.7 mi (1.1 km) northeast of the 

site (MGS 2016). The University of Missouri Thomas Jefferson Agricultural Institute is the 

registered owner (MDNR 2016f). This well was installed in October 2006 to a depth of 766 ft 

(233 m). It has a cased diameter of 6.25 in. (15.9 cm). Well logs for the area indicate that this 

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

/min) 

at installation (MGS 2016; MDNR 2016f). This well is hydraulically upgradient of the Discovery 

Ridge site as the direction of regional groundwater flow is generally from north to south.

A public water supply well (well no. 400126) is located approximately 0.8 mi (1.3 km) south, 

southeast of the Discovery Ridge site (MGS 2016). Consolidated Public Water Supply District 

No. 1 is the registered owner (MDNR 2016f). This well is a reconstruction (i.e., refurbishment 

and/or modification) of a well (well no. 24126) originally drilled in December 1965. 

Reconstruction was completed on September 20, 2008, and involved deepening the well to 

1,475 ft (450 m) further into the Cambrian strata. It has a cased diameter of 12 in. (30.5 cm). 

The completion log indicates a static water level of 280 ft (85 m) bgs and a yield of 600 gpm 

(2.3 m3

/min) at installation (MGS 2016; MDNR 2016f).

The nearest well identified by NWMI is reportedly located approximately 0.3 mi (0.48 km) 

west-northwest of the Discovery Ridge site (NWMI 2016a). The location mapped by NWMI 

places it proximal to Lot 6 of the Discovery Ridge Research Park and near the existing ABC 

Laboratories facility; this approximate location matches other well records that the NRC staff 

reviewed (MGS 2016). This well (well no. 013947) was drilled in 1955 and owned by the 

University of Missouri. It was drilled to a depth of 587 ft (179 m) with a static water level of 

270 ft (82 m) bgs at completion (NWMI 2016a). A well log that the NRC staff reviewed indicates 

that the well was located on the Bradford dairy farm (MGS 2016).

Terracon (2011b) discussed the possible existence of a water well in the above cited area as 

documented in the 2011 Phase I environmental site assessment report that was prepared for

the Discovery Ridge Research Park. In the Phase I report, the location of the well is attributed 

to the USDA Field Research Building, which lies in Lot 4. As described in the ER, the University 

of Missouri’s Bradford Research and Extension Center encompasses a research farm that 

provides land, equipment, and facilities to assist university and USDA scientists and extension 

personnel in performing research (NWMI 2015a). This information collectively suggests that the 

water well in question was associated with the original Bradford farm.

The NRC staff’s opinion is that the well could possibly have been in areas impacted by 

construction of Discovery Drive and Discovery Ridge Parkway, or by construction of the ABC 

Laboratories facility. Terracon reported that it did not locate the well during its site 

reconnaissance as part of the Phase I assessment. However, as stated by Terracon in the 

Phase I report (Terracon 2011b), the well, if still in existence and not used, should be located 

and properly abandoned in accordance with MDNR standards.
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3.5 Ecological Resources

3.5.1 Ecoregion

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

) (Karstensen 2010; USGS 2015e). 

Diverse topography, geologic, soil and hydrological condition have created a wide range of 

habitat types, including woodlands, forests, wetlands, fluvial features, hills, caves, deep valleys, 

and various rocks outcrops. Aquatic habitats include rivers, meandering streams, tributaries, 

seeps, and springs (MDNR 2008). These diverse and unique habitats support a number of 

plant and animal species, including 200 species largely restricted to the Ozark Highlands, of 

which 160 species only occur within the Ozark Highlands (USGS 2009).

Historically, this region primarily consisted of woodlands, forests, prairie grasslands, savannas, 

and wetlands (Epperson 1992; Nigh and Schroeder 2002). Beginning with European 

settlement, the majority of grasslands and wetlands were converted to agricultural lands for 

farming and pastures (Nigh and Schroeder 2002). In the late 1880s through 1960, the amount 

of hickory oak forest decreased as a result of the timber industry. Afterwards, the percent forest 

cover continued to decline as forests were converted to agricultural lands for pasture and row 

crops. Upland grasslands and valley bottoms were also converted to agricultural lands for 

pasture and row crops during this period (Karstensen 2010). From 1973 through 2000, 

2.4 percent of forests in the ecoregion were converted to agricultural lands and approximately 

1 percent was mechanically disturbed (Karstensen 2010). During this same period, 

approximately 1 percent of agricultural lands were converted to grasslands, in part due to the 

Conservation Reserve Program, which offered financial incentives for farmers to suspend 

agricultural activities and convert the land to native grasslands or forests (Johnson and 

Maxwell 2001). Dahl (1990) determined that 87 percent of Missouri’s original 1.9 million ha 

(4.8 million ac) of wetlands have been converted to other land uses, such as agriculture 

(87 percent), urban development (8 percent), and other development (5 percent). The 

conversion of forest and wetlands to agricultural fields has resulted in the decline of many 

biological species that depend on large tracts of undisturbed complex, natural habitats, and 

native species for prey, shelter, and breeding. Species that can survive in low-quality 

human-modified habitats, such as agricultural fields and developed areas, have generally 

increased over the past few centuries.

In 2000, the primary undeveloped land cover that provided habitat within the ecoregion included 

forests (56 percent), agricultural lands (37 percent), open water (1 percent), and wetlands (less 

than 1 percent) (Karstensen 2010). Developed land accounted for 2.1 percent of the ecoregion.

3.5.2 Habitats in the Vicinity of the Proposed Site

Within the vicinity, or a 5-mi (8-km) radius, of the proposed Discovery Ridge site, most of the 

area (39 percent) is used for agricultural purposes (see Table 3-1). Vegetation and wildlife

within agricultural fields surrounding the proposed site are likely to be similar to those found at 

the proposed site (see Section 3.5.3). This section also describes other types of habitats—

forests, grasslands, wetlands, and aquatic—within a 5-mi (8-km) radius of the proposed site. In 

addition, several communities of concern occur within the vicinity of the site (USDA 2016b; 

NWMI 2015a) and are highlighted below. MDC (2016b) defines these areas as high-quality 

ecological communities with intact tracts of habitat containing a diverse assemblage of native 

species. MDC (2016b) classifies each community as critically imperiled, imperiled, or 

vulnerable based on criteria such as total number of occurrences, total acres, number of 
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counties in which the community type occurs, number of protected occurrences, and threats to 

the community, as defined below:

• Critically Imperiled: Extremely rare or some factor(s) such as very steep declines 

making it especially vulnerable to extirpation from the State.

• Imperiled: Rare due to very restricted range, very few populations or occurrences, 

steep declines, or other factors making it very vulnerable to extirpation from the 

State.

• Vulnerable: Restricted range, relatively few populations or occurrences, recent and 

widespread declines, or other factors making it vulnerable to extirpation.

Forested Habitats

Forests cover 33 percent of the area within a 5-mi (8-km) radius of the proposed Discovery 

Ridge site (NWMI 2015a). Typical forests are primarily deciduous forests that include white oak 

(Quercus alba) forests, oak dry woodlands, black oak (Quercus velutina) woodlands, oak 

savannas, and sugar maple (Acer saccharum) mesic forests (Nigh and Schroeder 2002; 

NWMI 2015a). Evergreen forests and mixed forests are less common, but they also occur 

within the vicinity. Historically, forests covered a larger portion of the area; however, many of 

the forests have been converted into agricultural fields (Karstensen 2010). Remaining forested 

tracts, especially in riparian areas, provide important habitat for wildlife and birds. Many 

neotropical migrating birds use forested riparian habitats for resting, foraging, and providing 

refuge from predators. Two forested communities of concern occur within the vicinity:

• White oak forests (imperiled)—White oak forests generally occur on relatively steep 

slopes, from the valley bottoms to ridge tops, above river corridors. Hardwood trees 

comprise a well-developed forest canopy and subcanopy dominated by a mixture of 

white oak, sugar maple, pawpaw (Asimina triloba), and other hardwoods (USDA 2016b). 

Common shrubs and forb species include fragrant sumac (Rhus aromatic), wild blue 

phlox (Phlox divaricata), and woodnettle (Laportea canadensis) (USDA, 2016b). 

Common wildlife species include white-tailed deer (Odocoileus virginianus), great 

crested flycatcher (Myiarchus crinitus), and ringed salamander (Ambystoma annulatum) 

(MDC 2010).

• Mixed oak loess/glacial till woodlands (imperiled)—The mixed oak loess/glacial till 

woodlands generally occur adjacent to the Missouri River floodplains on upland summit 

crests. White, black, and post oak (Quercus stellate) trees comprise a well-developed 

forest canopy. Common shrubs and forbs include American hazelnut (Corylus 

Americana), elm-leafed goldenrod (Solidago ulmifolia), and smooth blue aster (Aster 

laevis). Common wildlife species include wild turkey (Meleagris gallopavo), red-headed 

woodpecker (Melanerpes erythrocephalus), and tiger salamander (Ambystoma tigrinum) 

(MDC 2010; USDA 2016b).

Grasslands

Grasslands cover less than 1 percent of the area within a 5-mi (8-km) radius of the proposed 

site (NWMI 2015a). Since the arrival of European settlers, agricultural activities converted the 

majority of native grasslands into cultivated croplands or pastures. The remaining areas of 

native grasslands are typically small and disconnected from other patches of native grasslands 

(Nigh and Schroeder 2002). These small patches provide lower quality habitat than larger 

connected tracts of grasslands. Predation, for example, is usually higher along the edge of a 

patch of prairie than at the center of a large continuous patch of prairie, which is likely because 

prey are more visible and have fewer places to hide from predators along the edge of a patch. 
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Remaining tracts of native grasslands provide an important habitat for wildlife and birds. For 

example, many birds require grassland habitats for courtship, nesting, foraging, rearing young, 

roosting, or resting.

The NRC staff notes that cultivated grasses, such as corn and wheat, or pastures with 

non-native species are sometimes considered grasslands. Because native grasses are 

relatively rare in the area and native grasses provide substantially higher quality habitat than 

cultivated grasses or pastures, the NRC staff classified cultivated grasses and pastures as 

agricultural lands in this environmental impact statement (EIS).

One grassland community of concern occurs within the vicinity:

• Loess/glacial till prairies (critically imperiled)—These prairie communities generally 

occur in areas of low relief with low slope gradients and narrow drainages. Tall grass 

prairies are primarily comprised of little bluestem (Schizachyrium scoparium), Indian 

grass (Sorghastrum nutans), and sideoats grama (Bouteloua curtipendula). Small 

groves of post oak, American hazelnut (Corylus Americana), and prairie willow (Salix 

humilis) occasionally occur within the prairies. Common shrubs and forbs include 

lead plant (Amorpha canescens) and purple prairie clover (Dalea purpurea). 

Common wildlife species include white-tailed deer (Odocoileus virginianus), upland 

sandpiper (Bartramia longicauda), and western slender glass lizard (Ophisaurus 

attenuates) (USDA 2016b).

Wetlands

Forest/shrub wetlands and freshwater emergent wetlands cover less than 1 percent of the area 

within a 5-mi (8-km) radius of the proposed site (NWMI 2015a). Wetlands provide an important,

high-value habitat for both terrestrial and aquatic resources. Migrating birds often use wetland 

sites for feeding and resting. Areas of open water provide an important nursery ground for 

many developing amphibians (e.g., frogs and salamanders), reptiles (e.g., turtles), and fish. 

One wetland community of concern occurs within the vicinity:

• Emergent wetlands and shrub swamps (Imperiled)—For emergent wetlands, 

common plant species include cattails (Typhaceae latifolia), bulrushes 

(Schoenoplectus spp), and sedges (Cyperaceae spp); and common wildlife species 

include bitterns (Botaurus lentiginosus), pied-billed grebes (podilymbus podiceps), 

and muskrats (Ondatra zibethicus). Shrub swamps are wetland thickets with 

buttonbush (Cephalanthus occidentalis) and willows (Salix spp). Common wildlife 

species include yellow warblers (Dendroica petechia) and green herons (Butorides 

virescens) (Leahy 2010; MDC 2016b, 2016c).

Aquatic Habitats

Areas of open water, or aquatic habitats, cover 1.5 percent of the area within a 5-mi (8-km) 

radius of the proposed site (NWMI 2015a). As described in Section 3.4.1, the proposed 

Discovery Ridge site currently drains south and southwest toward the southwesterly flowing 

Gans Creek, located approximately 0.35 mi (0.56 km) south of the site at its closest point (see 

Figures 3–11 and 3–13). Gans Creek is the major water body that provides aquatic habitat in 

proximity to the Discovery Ridge site. This perennial to intermittent stream is located within the 

Bonne Femme (Creek) watershed, and the proposed site lies within the northern portion of this 

watershed, the Little Bonne Femme sub-watershed (Frueh 2007; NWMI 2015a). From just 

south of the site (Figure 3–13), Gans Creek flows beneath U.S. Highway 63 and continues west 

to southwesterly in a winding path for approximately 6 stream mi (9.7 km) before joining Clear 

Creek. Little Bonne Femme Creek begins at this confluence. Little Bonne Femme Creek 

continues flowing southwesterly for some 9 mi (14 km) along a winding course before entering 
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the Missouri River. Approximately 2 mi (3.2 km) south of the mouth of Little Bonne Femme 

Creek, Bonne Femme Creek discharges to the Missouri River (Frueh 2007; NWMI 2015a).

The Bonne Femme Stakeholder Committee (BFSC 2007) determined that fish communities 

within the Bonne Femme watershed and nearby streams generally range from 11 to 17 species, 

and commonly include shiners, minnows, suckers, redhorse, sunfish, bass, darters and 

stonerollers. NWMI (2015c) observed creek chub (Semotilus atromaculatus) in small pools of 

Gans Creek on September 30 and October 1, 2015. Gans Creek was not flowing at the time of 

the observation. The NRC staff also searched FishNet (2014), which is a collaborative effort by 

the National Science Foundation, National Biological Information Infrastructure, and other 

natural history and biodiversity institutions to compile a database of fish survey results. 

FishNet (2014) contained records for two fish species within the vicinity of the proposed 

Discovery Ridge site. Small mouth bass (Micropterus dolomieu) were collected from Little 

Bonne Femme Creek in October 1978. Smallmouth bass are relatively common within this 

watershed. In March 1960, orangethroat darter (Etheostoma spectabile) were collected from 

the spring branch of Gans Creek. Orangethroat darter is endemic, or solely unique, to the 

Mississippi River basin and the Lake Erie basin. However, given the age of the data, it is not 

certain whether these species still occur within the Bonne Femme watershed.

Portions of Gans Creek are considered Fish Spawning Stream Reaches, which is one of 

138 State-designated fish spawning stream segments (MDC 2015). The State designates

stream reaches as Fish Spawning Stream Reaches if they contain highly diverse fish 

communities, provide habitat for fish species of conservation concern, and if they are important 

to maintaining, restoring, or avoiding future listing of Species of Conservation Concern 

(MDC 2015).

Streams and other waterbodies within the Bonne Femme watershed also contain many 

invertebrates, such as mayflies, stoneflies, caddisflies, dragonflies, beetles, small crustaceans, 

and snails. BFSC (2007) determined that 18 to 27 invertebrate species are estimated to inhabit 

streams within the Bonne Femme Watershed.

3.5.3 Site 

The proposed site consists of 7.4 ac (3.0 ha) of agricultural lands. The proposed site has been 

continuously disturbed from agricultural activities, such as row crops and pasture, during the 

past several decades. Because of these agricultural activities, plant communities located on the 

proposed site are primarily limited to non-native or common grasses reminiscent of open 

pasture land (NWMI 2015c; USDA 2016c; NRC 2016j). Because of the clearing, tilling, and 

other disturbances associated with agricultural activities, the proposed Discovery Ridge site has 

no native forests, woodlands, savannas, wetlands, or intact prairies. In addition, no water 

bodies, aquatic habitats, or riparian zones exist within the boundaries of the proposed Discovery 

Ridge site (NWMI 2015a, 2015c).

To characterize the vegetation on the proposed Discovery Ridge site, NWMI (2015c) performed 

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

) plots at 5-m (16-ft) intervals along each 

transect. In addition, NWMI identified plants observed while walking the perimeter of the 

property. Both the NRC staff and the Missouri Department of Conservation staff reviewed the 

vegetation survey (NRC 2016j). The most common species to occur on the Discovery Ridge 

site include tall fescue (Colium arundinaceum) and yellow foxtail (Setaria pumila), both of which 

are non-native to Boone County (USDA 2016c; MDC 2016d; NRC2016j). Other vegetative 

species on the site include Indian grass (Sorghastrum nutans), ironweed (Vernonia spp.), 

cocklebur (Xanthium spp.), birdsfoot trefoil (Lotus corniculatus), red clover (Trifolium pretense),
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3-41

teasel (Dipsacus spp.), and Queen Anne’s lace (Daucus carota) (NWMI 2015c, NRC 2016j). 

These species are either common, weedy, and/or non-native to Boone County (MDC 2016c, 

2016d; USDA 2016c; NRC 2016j). The vegetative species that occur on the Discovery Ridge

site are indicative of an old field that has been previously disturbed (NWMI 2015c; NRC 2016j).

In addition, the present vegetation provides low quality habitat for wildlife and birds 

(NWMI 2015c; NRC 2016j).

NWMI (2015c) identified one American sycamore (Platanus occidentalis) tree on the Discovery 

Ridge site. During its site audit (NRC 2015b), the NRC staff also identified the American 

sycamore tree and noted that it was in relatively poor health based on multiple physical 

abrasions, or removal of bark, and dead branches that did not produce leaves. 

The proposed Discovery Ridge site provides low-quality habitat for birds, mammals, 

amphibians, reptiles, and other wildlife tolerant of open fields, grasses, and regular disturbance 

associated with cow grazing or other agricultural activities. During its qualitative field survey, 

NWMI (2015c) noted the presence of nine Eurasian collared-doves (Streptopelia decaocto). 

This species is not native to Missouri and tolerant of human-modified habitats, such as old 

fields, pastures, and urbanized areas (Audubon 2016). NWMI (2015c) did not observe any 

other wildlife during its qualitative or quantitative vegetation assessment.

Birds and wildlife may use the proposed site to feed on vegetation, as a temporary resting 

location, or while traveling among other habitats. Table 3–8 provides a representative list of 

species tolerant of human-altered landscapes, such as agricultural fields, which may occur on 

the proposed Discovery Ridge site. Wildlife that requires trees, native plants, shrubs, or 

uncultivated grasses would not use the proposed site because of the lack of forested areas, 

wetlands, and native grasslands. Note that Federally listed species, State-listed species, and 

birds protected under the Migratory Bird Treaty Act of 1918, as amended (MBTA) 

(16 U.S.C. 703–712) are described in Section 3.5.4.

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

Sturnella magna eastern meadowlark

Sturnus vulgaris European starling

Turdus migratorius American robin
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Scientific Name Common Name

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

No natural surface water features (e.g., headwater tributaries to streams) originate on the 

proposed Discovery Ridge site. As described in Section 3.5.2, the closest surface water feature 

is Gans Creek, located approximately 0.35 mi (0.56 km) south of the site (see Figures 3–11 

and 3–13). 

3.5.4 Protected Species and Habitats

The U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS)

jointly administer the Endangered Species Act of 1973, as amended (ESA) (16 U.S.C. 1531 

et seq.). The FWS manages the protection of, and recovery effort for, listed terrestrial and 

freshwater species, and NMFS manages the protection of, and recovery effort for, listed marine 

and anadromous species. In Missouri, the MDC lists species as State-endangered under 

Missouri’s Code of State Regulations (Title 3 of Code of State Regulations, Division 10, 

“Conservation Commission”) and the State Endangered Species Law (252.240). This section 

discusses these species and species protected under the MBTA.

3.5.4.1 Endangered Species Act

Action Area

The implementing regulations for section 7(a)(2) of the ESA define “action area” as “all areas to 

be affected directly or indirectly by the Federal action and not merely the immediate area 
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involved in the action.” (50 CFR 402.02). The action area effectively bounds the analysis of 

ESA-protected species and habitats because only species that occur within the action area may 

be affected by the Federal action.

For the purposes of the ESA analysis in this EIS, the NRC staff considers the action area to 

include the lands within the 7.4 ac (3.0 ha) proposed site, the adjacent offsite area that would be 

used as a temporary construction staging area, and the surrounding area where runoff drains 

and activities would be audible to wildlife. The NRC staff expects all direct and indirect effects 

of the proposed action to be contained within these areas.

The NRC staff recognizes that while the action area is stationary, Federally listed species can 

move in and out of the action area. For instance, a flowering plant known to occur near, but 

outside, of the action area could appear within the action area over time if its seeds are carried 

into the action area by wind, water, or animals. Thus, in its analysis, the NRC staff considers 

not only those species known to occur directly within the action area, but those species that may 

passively or actively move into the action area. The NRC staff then considers whether the life 

history of each species makes the species likely to move into the action area where it could be 

affected by the construction, operations, and decommissioning of the NWMI facility.

Overview of Protected Species

Table 3–9 describes the Federally listed species that have the potential to exist within the action 

area. The NRC staff compiled this table from the FWS’s online database (FWS 2015a), 

correspondence and discussions with the FWS (FWS 2015a; NRC 2015e), and the NWMI ER

(NWMI 2015a).

As described in Section 3.5.3, NWMI conducted ecological surveys in the action area and did 

not observe any Federally protected species on the proposed site (NWMI 2015a). Based on the 

surveys described in Section 3.5.3, the NRC staff did not identify any Federally listed species 

that could exist in the action area. In addition, the NRC staff reviewed the habitat requirements 

for the Federally listed species in Table 3–9. The NRC staff determined that the proposed site 

provides unsuitable habitat for all the Federally listed species in Table 3–9. The NRC staff did 

not identify any candidate species or proposed or designated critical habitats within the action 

area. Given the available information, the NRC staff concludes that Federally listed, proposed, 

or candidate species are unlikely to occur within the action area.

The Gans Creek does not contain marine or anadromous fish species. Therefore, no Federally 

listed species or habitats under NMFS’s jurisdiction occur within the action area.

3.5.4.2 State-listed Species

Table 3–9 includes the State-listed species that have the potential to occur on or near the 

proposed Discovery Ridge site. The NRC staff compiled this table from the MDC’s description 

of State-listed species (MDC 2000a, 2000b, 2016b), MDC’s Natural Heritage Review (2015 and 

2016 [June 2 letter]) reports, and the NWMI ER (NWMI 2015a). As described in Section 3.5.3, 

NWMI conducted vegetation surveys in the action area and did not observe any State-protected 

species on the proposed site (NWMI 2015a). Furthermore, habitat to support State-listed 

species does not occur on site. Based on the surveys described in Section 3.5.3, the NRC staff 

did not identify any State-listed species that are likely to occur in the action area.

The NRC staff reviewed the habitat requirements for the State-endangered species in 

Table 3–9. The NRC staff determined that the proposed site provides unsuitable habitat for all 

the State-endangered species. The Topeka shiner (Anguilla rostrate), which is State

endangered, historically inhabited the watershed, but its occurrence has not been reported 

since 1997 (BFSC 2007). MDC’s (MDC 2016e) natural heritage report did not identify any 
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state-listed endangered species, state-ranked species, nor any natural communities within the 

project area. Because no State-listed species have the potential to exist within the proposed 

Discovery Ridge site, this EIS does not discuss State-listed species in any further detail.

Federally and State-Listed Species 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

Charadrius melodus piping plover T Wide, flat, open, sandy 

beaches with very little 

vegetation; Nesting occurs 

near small creeks or 

wetlands
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Scientific Name Common Name

Federal 

Status(a)

State 

Status(a) Habitat

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

3.5.4.3 Migratory Bird Treaty Act

The FWS administers the MBTA, which prohibits anyone from taking native migratory birds or 

their eggs, feathers, or nests. Regulations under the MBTA define a “take” differently than the 

ESA (16 U.S.C. 1532(19)) and define “take” as “to pursue, hunt, shoot, wound, kill, trap, 

capture, or collect or attempt to” carry out these activities (50 CFR 10.12). Unlike a “take” under 

the ESA regulations (50 CFR 17.3), a “take” under the MBTA does not include significant habitat

modification or degradation that results in death or injury to listed species by significantly 

impairing essential behavioral patterns, such as breeding, feeding, or sheltering.

The MBTA protects a total of 1,007 migratory bird species (75 FR 9282). FWS (2015a) 

indicated that 20 migratory birds of concern may occur on or near the proposed Discovery 

Ridge site (Table 3–10). Near the proposed site, migratory birds rely on riparian, forested, 

grassland, and wetland habitats as important areas for foraging, resting, and avoiding predators 

and for breeding for some species. Although these habitats exist in the vicinity of the proposed 

site, none of them exists on the proposed site. For this reason, the proposed site likely provides 

low-quality habitat for migratory birds.

Migratory Birds of Concern that May Occur near the

Proposed Discovery Ridge Site

Scientific Name Common Name

Bird of 

Conservation 

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

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
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Scientific Name Common Name

Bird of 

Conservation 

Concern

Occurrence in 

Project Area

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

3.5.4.4 Magnuson–Stevens Fishery Conservation and Management Act

Magnuson–Stevens Fishery Conservation and Management Act, as amended (16 U.S.C. 1801 

et seq., herein referred to as MSA), requires Federal agencies to consult with National Marine 

Fisheries Service (NMFS) on actions that may adversely affect essential fish habitat (EFH). The 

NMFS has not designated any EFH under the MSA within affected water bodies in the vicinity of 

the proposed site (NMFS 2016). Because no habitats are designated, no EFH would be 

affected by the proposed action. Therefore, this section does not discuss species with essential 

fish habitat.

3.5.4.5 State Parks and Conservation Areas

Rock Bridge Memorial State Park

As described in Section 3.1.1.3, the Rock Bridge Memorial State Park is within 5 mi (8 km) of 

the Discovery Ridge site. Karsts, caves, grasslands, and oak woodlands and forests within the 

park provide habitat to a variety of vegetation, birds, and wildlife (NRC 2016j; MDNR 2016a). 

Important native grasslands occur within the park, including a 3-acre prairie remnant of big 

bluestem grass. MDNR (2016a) has planted and restored additional native grasses surrounding 

the remnant prairie and in other areas of the park. MDNR continues to support the growth of 

native grasslands within the park by using a variety of management conservation efforts, such 

as prescribed burns.

Caves within the park, including Devil’s Icebox Cave, provide unique habitat for several 

threatened and endangered species, including grey bats (Myotis grisescens) and northern 

long-eared bats (Myotis septentrionalis). Cave-dwelling species, referred to as troglobites, are 

species that have adapted to survive within dark underground caves and cannot survive outside 

caves. Some troglobites are restricted to a single cave. The pink planarian (Macrocotyla 

glandulosa), for example, is a rare 1 in. (2.5 cm) flatworm that is endemic to, or only known to 

exist, within a single stream within Devil’s Icebox Cave (BFSC 2007). Threats to the pink 
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planarian include pollution, siltation, and physical disturbances (BFSC 2007; Wicks et al. 2010). 

Due to the restricted habitat and vulnerability to extinction, MDC (2016a) considers the pink 

planarian a species of conservation concern. 

Devil’s Icebox Cave is the seventh longest cave in Missouri and has the second highest number 

of species among the 6,300 caves in Missouri (BFSC 2007). Elliot (2007) identified 80 species 

that occur within Devil’s Icebox Cave.

Three Creeks Conservation Area 

As described in Section 3.1.1.3, the Three Creeks Conservation Area is a 607-ha (1,500-ac) 

natural preserve that consists mostly of oak forests and woodlands (MDC 2016a). In addition, 

three intermittent streams (Turkey, Bass, and Bonne Femme creeks), native grasslands, and 

caves provide valuable habitat for wildlife, birds, and fish, including rare and endangered 

species. For example the cherrystone snail (Hendersonia occulta), a species considered

“vulnerable” by MDC (undated), and the Federally listed Topeka Shiner occur within the 

watershed within the conservation area (Frueh 2007).

Gans Creek Recreation Area

As described in Section 3.1.1.3, the Gans Creek Recreation Area occurs within the vicinity of 

the proposed Discovery Ridge Site. This area provides important habitats for wildlife, bats, and 

birds, including elbow cave and a forested riparian corridor that runs along Gans Creek (City of 

Columbia, undated). The forested riparian corridor fulfills important ecological services by 

helping to filter out pollutants prior to reaching Gans Creek, lining the creek with a quality 

structural habitat (e.g., roots and tree branches), and forested areas for migratory birds and 

wildlife to find shelter, food, and refuge from predators.

3.6 Historic and Cultural Resources

The National Historic Preservation Act (NHPA) of 1966, as amended (54 U.S.C. 300101 et 

seq.), requires Federal agencies to consider the effects of their undertakings on historic 

properties. The historic preservation review process (Section 106 of the NHPA) is outlined in 

regulations issued by the Advisory Council on Historic Preservation (ACHP) in 36 CFR Part 800. 

This section describes the archaeological history of Columbia, Missouri, and Boone County and 

identifies historic and cultural resources that could potentially be found on or near the Discovery 

Ridge site. The identification of these resources is based on a review of the Phase I survey of 

the Discovery Ridge site, historic literature and archaeological records, and an interview with an 

archaeologist with the MDNR State Historic Preservation Office (SHPO). Additional cultural 

resource information is available at MDNR in Jefferson City, Missouri.

3.6.1 Cultural Background

Human occupation in Missouri is generally characterized according to the following 

chronological sequence (MAS 2015):

• Paleo-Indian Period (11,500 to 9,900 years before present (B.P.)),

• Archaic Period (9,900 to 3,000 B.P.),

• Woodland Period (3,000 to 1,000 B.P.),

• Mississippian Period (1,000 to 400 B.P.), and

• Protohistoric/Historic Period (400 B.P. to present).
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3.6.1.1 Paleo-Indian Period (11,500 to 9,900 B.P.)

The earliest evidence of people living in Missouri dates to the Paleo-Indian Period. Paleo-Indian 

sites are generally found upland or on river terraces and are characterized by specific types of 

projectile points (i.e., fluted Clovis points) and stone tools such as gravers, scrapers, or large 

blades. These artifacts often occur in association with mastodon remains, suggesting a reliance 

on the hunting of large mammals for subsistence, along with plants, small game, birds, and 

amphibians. Most fluted points have been found along major river valleys (e.g., Missouri River), 

although some have been recovered along streams such as the Moreau River. These finds 

suggest that the nomadic hunters and gatherers followed these streams in their movement 

through the Midwest area. Social organization during this period consisted of small, highly 

nomadic bands of hunter-gathers, leaving Paleo-Indian sites with little detailed archaeological 

information (NRC 2014; NWMI 2015a).

In Missouri, a distinct cultural tradition appeared in the transition from the Paleo-Indian to 

Archaic cultural periods: the Dalton Complex. Lasting approximately 1,000 years, from 10,000 

to 9,000 B.P., the overall settlement pattern during this period continued to be nomadic and 

influenced by climatic rather than glacial conditions. Archaeological sites from this period tend 

to be located in areas that crosscut major resource zones, suggesting a change in subsistence 

strategies from primarily hunting large mammals to hunting smaller mammals, gathering plant 

resources, and exploiting marine resources such as mussels. All known Dalton sites in Missouri 

are small camps, and represent short-term utilization. Artifact assemblages from Dalton sites 

are characterized by distinct narrow, oval-shaped, unfluted projectile points (NRC 2014; 

NWMI 2015a).

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

The Archaic Period was a time of major climatic shifts as the environment transitioned from a 

colder to warmer climate similar to modern conditions. In response to this shift, new 

technologies and subsistence strategies were developed. The Archaic Period is often 

subdivided into early, middle, and late periods. The Early Archaic Period is characterized by a 

shift from nomadic to more sedentary settlement patterns, with central base camps located on 

river terraces and smaller hunting camps located in upland areas. These sites are found in a 

variety of environmental settings throughout Missouri, including upland ridges near small 

ephemeral streams, upland bluff edges, rock shelters, and the margins of high bottomland 

terraces. The Early Archaic Period also shows an increased reliance on wild plant foods, small 

game, and aquatic resources.

The Middle Archaic Period is characterized by an increased number of settlement sites on high 

stream terraces, which may reflect population increases. While subsistence and settlement 

patterns remained fairly similar to the Early Archaic Period, artifact assemblages suggest 

increased exploitation of aquatic resources. Also in evidence are new artifacts such as pecked 

and ground stone tools, used for processing nuts; banner stones that signaled the innovation of 

a new projectile technology called the atlatl, or spear-thrower; and grooved axes.

The Late Archaic Period is characterized by an increase in the number and size of settlement 

sites, which indicates a further increase in population and more sedentary lifestyle. New 

features of Late Archaic artifact assemblages, such as crude ceramic vessels, represent a shift 

towards increased reliance on horticulture as a subsistence strategy, although hunting and 

gathering would have continued (NRC 2014; NWMI 2015a).

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

The Woodland Period is also often subdivided into early, middle, and late periods. Early 

Woodland Period sites are not well represented in the Missouri archaeological record; they tend 
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to be large base camps located in major river valleys, with smaller logistical camp sites located 

on terraces of smaller water bodies. This period is identified by the presence of Black Sand 

Incised pottery. In spite of intensive surveys in various areas of the State, only a few 

unquestionable Early Woodland sites have been identified. While Early Woodland Period 

subsistence appears to have relied on hunting and gathering, there is evidence for cultivating 

plants such as sunflowers and cucurbits (i.e., squashes, gourds, melons, etc.) (NRC 2014; 

NWMI 2015a).

During the Middle Woodland Period, the large and complex Hopewell Culture emerged in the 

United States, including Missouri. This culture is characterized by village settlements, increased 

reliance on horticulture, burial mounds, and trade networks. These trade networks facilitated 

the exchange of exotic materials, such as marine shells from the Gulf Coast, obsidian from the 

Rocky Mountains, copper from Lake Superior, and mica from the Appalachian Mountains. 

Middle Woodland artifact assemblages are dominated by ceramics, suggesting an increased 

reliance on cultivated plants (NRC 2014; NWMI 2015a).

The Late Woodland Period is characterized by an increase in the number of settlement sites, 

which suggests a rise in population, a change in settlement patterns from large, centralized 

village sites to smaller, dispersed habitation sites, or both. Late Woodland Period artifact 

assemblages are characterized by an increase in thin-walled plain ceramic types and stemmed 

and side-notched projectile points. The sudden appearance of very small, thin triangular 

projectile points between 1,300 and 1,400 B.P. indicates the invention of bow-and-arrow 

technology and suggests a corresponding change in hunting techniques. Several Late 

Woodland sites have been identified in Boone County, including open habitation sites and burial 

mounds (NRC 2014; NWMI 2015a).

3.6.1.4 Mississippian Period (1,000 to 400 B.P.)

The Mississippian Period is characterized by major changes in settlement, subsistence patterns, 

and social structure. This period is not well-documented in the general area of the proposed 

Discovery Ridge site. Large, highly centralized permanent settlements supported by many 

satellite villages emerged during this period. The archaeological record of these settlements 

suggests they were organized as chiefdoms with considerable social stratification. A new type 

of ceremonial earthen mound, the platform mound, appeared in association with these 

permanent settlements. Mississippian Period subsistence relied heavily on maize agriculture, 

as well as hunting and gathering. Craft specialists appeared in the social structure of the 

Mississippian Period, producing highly specialized lithic and ceramic artifacts, beadwork, and 

shell pendants. In addition to these specialized artifacts, characteristic Mississippian Period 

artifacts include small triangular, side-notched and bi-pointed projectile points and slipped and 

painted pottery (NRC 2014; NWMI 2015a).

Beginning about 1350, the Oneota cultural tradition appeared in the area near the junction of the 

Grand, Chariton, and Missouri Rivers. The Oneota occupation lasted to the end of the 

Mississippian period, when Oneota culture blended into what is recognized as the Historic 

Missouri Indian tribe (NWMI 2015a).

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

The end of the Mississippian Period is characterized by severe social, political, and 

demographic changes that resulted from contact with Europeans. In particular, it is believed 

that the introduction of infectious diseases such as smallpox, yellow fever, typhoid, and 

influenza severely decimated native populations, which had no immunity to these diseases. 

The spread of disease, which was often fatal, resulted in the abandonment of villages and the 
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collapse of trade networks. By the time of European contact and settlement, the Mississippian 

chiefdoms were gone (NRC 2014).

The first major European expedition to Missouri was conducted by French Catholic missionaries 

sometime in the late 17th to early 18th centuries. Missouri (then called Upper Louisiana) was 

seen by the French as a place for new economic opportunity, and St. Louis was established as 

a center for fur trade in the area. By 1719, most of the interior of Missouri had been explored for 

fur trade and exploitation of mineral resources such as silver and lead (NRC 2014).

Beginning about 1730, the Missouri Indian tribe began to suffer losses due to smallpox and 

challenges from its enemies to the north, and in turn became increasingly dependent on their 

allies, the Osage, for protection. By the 1790s the Sac and Fox tribes had conquered and 

dispersed the Missouri Indian tribe, with those who were not killed joining the Osage, Kansas, 

and Oto tribes (NWMI 2015a).

The proposed Discovery Ridge site lies in territory claimed at different times by France and 

Spain until it was sold to the United States in 1803 as part of the Louisiana Purchase. The first 

permanent European settlers to the area soon followed. The U.S. Congress subsequently 

established the Territory of Missouri in 1812, and recognized Missouri as a state in 1821 

(NWMI 2015a).

Most of the settlers who came to mid-Missouri were attracted to the land and cultivated crops 

that reproduced the agricultural patterns of their native states, including the slave-holding States 

of Kentucky, Tennessee, and Virginia. Major crops included hemp and tobacco, which 

demanded intensive labor for productivity (NWMI 2015a).

3.6.1.6 Recent History – Columbia

Columbia was incorporated in 1826, 5 years after Missouri achieved statehood. The city 

benefited from its proximity to stops on the Santa Fe and Oregon Trails, and later the Missouri 

Kansas Texas Railroad. The economy of Columbia has historically centered on education. A 

school for girls was opened in 1833, and an institution called Columbia College was opened in 

1834 (NWMI 2015a).

Missouri University was established in Columbia in 1841. This was followed by the Christian 

Female College in 1851, which later changed its name to Columbia College (although not 

related to the earlier institution). Baptist Female College, now known as Stephens College, was 

established in 1855 (NWMI 2015a). 

The coming of the railroad in the 1850s opened the interior to greater trade and established the 

area as a major source of agricultural products (NWMI 2015a). By the onset of the Civil War, 

slave holding began to drop and agricultural pursuits became almost entirely geared toward 

corn and wheat production. Columbia’s economy also has strong ties to the health care 

industry, with it being among the top cities in the Nation for medical facilities per capita 

(NRC 2014; NWMI 2015a).

3.6.1.7 Recent History – Discovery Ridge

From 1934 to 2006, the Discovery Ridge Research Park was predominantly in crop production, 

livestock pasture, or vacant farmland. Since 2006, the western and northern portion has been 

in development as a research park that includes the Missouri University plant genetic research 

farm, while the eastern portion has remained in agricultural use. Several residential structures 

were removed from the site since the 1980s, including a small log cabin-type structure that was 

located on the central portion of the research park. Two small machine-shed structures dating 

from the 1950s and a Quonset hut used for storage by the USDA remain on site (NWMI 2015a; 

Terracon 2011a).
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3.6.2 Historic and Cultural Resources

Databases that the National Park Service (NPS) maintains show 50 properties listed in the 

National Register of Historic Places in Boone County, with the vast majority of them located in 

and around Columbia under the National Historic Preservation Act (54 U.S.C. 300101 et seq.). 

However, no historic properties are located at the Discovery Ridge site. The nearest property in 

the National Register of Historic Places list is the Maplewood House, which is located about 

1 mi (1.6 km) northwest of the proposed NWMI facility site at Discovery Ridge (NWMI 2015a). 

The view from the Maplewood House of the proposed Discovery Ridge site is obstructed by 

trees and residential and commercial properties.

NWMI conducted a Phase I survey investigation in October 2013 to inventory and evaluate 

cultural resources within the Discovery Ridge site. The Phase I investigation included (1) a 

pre-field evaluation of pertinent literature and records from which the field survey techniques 

and site designation criteria were developed, (2) an intensive pedestrian survey of the project 

area, (3) an attempt to recover sufficient data for site designation and evaluation in terms of 

NRHP eligibility requirements, (4) notation of locational information regarding site provenience 

and physiographic setting, (5) post-field activities involving data analysis, and (6) report 

preparation (NWMI 2015a).

A review of relevant publications and archaeological records provides an understanding of the 

types of historic and cultural resources that could be found at the Discovery Ridge site. Based 

on the review of historical information, no archaeological sites or historic structures have been 

recorded nor have any significant historic events occurred within Lot 15. A review of 19th and 

20th century plat maps and 20th century USGS topographic quadrangles also revealed no 

evidence of historic structures on Lot 15.

A Phase I archeological survey was conducted at the proposed Discovery Ridge site, which 

included shovel tests to interpret the presence of historic and cultural resources. No evidence 

of historic or cultural resources were found within the Lot 15 survey area. As a result, Lot 15 at 

the Discovery Ridge site contains no significant cultural resources (NWMI 2015a).

Cultural Resource Assessment, Section 106 Reviews, were conducted by the MDNR SHPO for 

the proposed Northwest Medical Isotopes, LLC Radioisotope Production Facility, Columbia 

(Lot 15 at Discovery Ridge). The assessments, signed by Toni M. Prawl, Ph.D., Deputy State 

Historic Preservation Officer, state that, “Adequate documentation has been provided 

(26 CFR Section 800.11). There will be ‘no historic properties affected’ by the current project.” 

The assessments also state, the MDNR SHPO has “no objection to the initiation of project 

activities.” (MDNR 2015b, 2016g).

3.7 Socioeconomics

This section describes current socioeconomic factors that have the potential to be directly or 

indirectly affected from construction, operations, and decommissioning of the proposed NWMI 

facility. The NWMI facility and the communities that would support it can be described as a 

dynamic socioeconomic system. The communities provide the people, goods, and services 

required to construct, operate, and decommission the proposed NWMI facility. NWMI facility 

operations, in turn, provide wages and benefits for people and dollar expenditures for goods and 

services. The measure of a community’s ability to support the construction, operations, and 

decommissioning of the proposed NWMI facility depends on its ability to respond to changing 

environmental, social, economic, and demographic conditions.
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The socioeconomic region of influence (ROI) is defined by the area in which NWMI construction, 

operations, and decommissioning employees and their families would likely reside, spend their 

income, and use their benefits—all of which affect economic conditions of the region. For the 

purposes of analysis and because of the relatively small size of the NWMI operations work force 

(approximately 100 workers), this area includes all of Boone County and the City of Columbia, 

Missouri.

3.7.1 Population Growth Rates and Projections

The population for Boone County has grown steadily from 1980 through 2010, with the largest 

increase between 1990 and 2010 (see Table 3–11). Based on population projections from the 

Missouri Department of Administration, Division of Budget and Planning, the population within 

Boone County is projected to continue to increase.

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.

3.7.2 Race and Ethnicity

Table 3–12 presents the demographic profiles for the City of Columbia and Boone County. In 

2010, minorities comprised 23 percent of the total population in the City of Columbia. As shown 

in Table 3–12, the largest minority populations were Black or African American at 11.1 percent 

followed by Asians at 5.2 percent. In Boone County, minorities comprised 19 percent of the 

total population in 2010. The largest minority populations were Black or African American at 

9.2 percent followed by Asians at 3.8 percent.

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
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Columbia Boone County

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

According to the U.S. Census Bureau’s 2014 American Community Survey 1-Year Estimates, 

since 2010 minority populations in the City of Columbia and Boone County were estimated to 

have increased by approximately 3,000 to 4,000 persons and now comprise 24 and 

20.2 percent of the respective populations (see Table 3–13). In the City of Columbia, the 

largest increase occurred in the Asian and Black or African American populations, an increase 

of 10.3 and 6.3 percent, respectively. In Boone County, the largest increase occurred in the 

Hispanic, Latino, or Spanish origin of any race and Asian populations, an increase of 14.2 and 

10.6 percent, respectively.

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

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
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3.7.3 Transient Population

Colleges and recreational opportunities attract daily and seasonal visitors who create a demand 

for temporary housing and services. In 2015, approximately 55,800 students attended colleges 

and universities within 20 mi (32 km) of the proposed NWMI facility at Discovery Ridge 

(NCES 2015a). Based on 2014 American Community Survey 1-Year Estimates, approximately 

2,227 seasonal housing units are located in Boone County (USCB 2016d).

Migrant farm workers are individuals whose employment requires travel to harvest agricultural 

crops. Some migrant workers follow the harvesting of crops, particularly fruit, throughout rural 

areas of the United States. Migrant workers may be members of minority or low-income 

populations. Because migrant workers travel and can spend a significant amount of time in an 

area without being actual residents, they may be unavailable for counting by Census takers. If 

uncounted, these minority and low-income workers would be “underrepresented” in the 

decennial Census population counts.

Information about both migrant and temporary farm labor (working less than 150 days) can be 

found in the 2012 Census of Agriculture. According to the 2012 Census of Agriculture, 

approximately 470 temporary farm workers were hired to work on 196 farms in Boone County, 

Missouri. Only one farm in Boone County reported hiring migrant workers in the 2012 Census 

of Agriculture (NASS 2014).

3.7.4 Labor Force, Employment, and Unemployment

This section provides labor force, employment, and unemployment data for the City of 

Columbia, Boone County, and the State of Missouri. It also presents economic data on 

employment by industry, income, poverty levels, occupations, wages, poverty rates, and 

housing.

Table 3–14 shows that Boone County had an estimated available civilian labor force in 2014 of 

97,498, with a 2.9 percent unemployment rate. The City of Columbia had an available labor 

force of 67,702, with a 2.4 percent unemployment rate.

Labor Force, Employment, and Unemployment Rates in Missouri, 

Boone 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

Table 3–15 shows employment by industry for Boone County for 2014. According to 2014 

American Community Survey estimates, the educational, health, and social services industry 

represented the largest employment sector in Boone County (36.3 percent) followed by retail 

trade (14.5 percent) and arts, entertainment, recreation, accommodation, and food services 

(12.3 percent).
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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

3.7.5 Income and Wages and Poverty

Table 3–16 presents the median family and per capita income figures for Missouri, Boone 

County, and the City of Columbia. According to 2014 American Community Survey 1-Year 

Estimates, Boone County has a higher median household income average than both the State 

of Missouri and the City of Columbia. The City of Columbia had a lower per capita income 

average than Boone County and the State of Missouri.

Median Family Income and Per Capita Income for the City of Columbia, 

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

Table 3–16 also presents the percentages of families and individuals living below the Federal 

poverty threshold in Missouri, Boone County, and the City of Columbia. The poverty levels in 

2014 were $12,071 for an individual and $24,230 for a family of four (USCB 2016d). According 

to 2014 American Community Survey 1-Year Estimates, the City of Columbia had a higher 

percentage of families and people living below the poverty level than Boone County as a whole.
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3.7.6 Housing

Table 3–17 lists the total number of occupied and vacant housing units, vacancy rates, and 

median value in Boone County and the City of Columbia. Based on 2014 American Community 

Survey estimates, there were approximately 73,000 housing units in Boone County, of which 

nearly 67,000 were occupied. The median values of owner-occupied housing units in Boone 

County was $170,700. The vacancy rate for all housing was 8.2 percent and 2.3 percent for 

rental units alone (USCB 2016e).

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

3.7.7 Local Employers

Table 3–18 lists the 10 largest employers in the City of Columbia and Boone County. These 

employers provide a variety of products and services, including educational and medical 

services, local government, financial and insurance services, and wholesale distribution.

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
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3.7.8 Taxes

The Missouri personal income tax rates range from 1.5 to 6 percent, assessed over 10 income 

brackets. The rates start at 1.5 percent on the first $1,000 of taxable income. The rate 

increases 0.5 percent on each additional $1,000 up to $9,000. The tax rate for income above 

$9,000 is 6 percent (MDOR 2016).

Missouri has a State sales tax of 4.225 percent that is levied on the purchase price of tangible 

personal property or taxable services sold at retail. The City of Columbia and Boone County 

have additional sales tax rates of 3.75 and 1.75 percent, respectively. These rates are in 

addition to the State tax rate of 4.225 percent.

The Missouri corporate tax rate is 6.25 percent. Only income earned in Missouri is taxed 

(MDOR 2016). Missouri permits companies to choose the formula that results in the lesser 

corporate income tax liability. Missouri also allows a portion of Federal income tax payments to 

be deducted before computing taxable income.

Missouri local governments rely on real (real estate) and personal property tax revenue to fund 

school districts, public transport, infrastructure, and other municipal government projects. 

Property tax rates are set each year by local taxing jurisdictions within the limits set by the 

Missouri Constitution and laws. Rates are based on the revenues that had been permitted for 

the prior year with an allowance for growth based on the rate of inflation (Boone County 

Collector of Revenue 2016).

Taxes are levied against property based on the rates as permitted by voters, collected by the 

collector and then distributed back to the taxing entities. In other words, Boone County collects 

property taxes on behalf of the taxing entities within the County (Boone County Collector of 

Revenue 2016).

The amount of property taxes imposed on any taxpayer is determined by two separate factors:

The assessed value of the property, as established by the local assessor.

The tax rates set by local taxing jurisdictions plus the $0.03 State tax rate. In 2015, 

Boone County levied a property tax rate of $0.2846, the City of Columbia a tax rate 

of $0.4100, and Columbia Public Schools a tax rate of $5.4656. (Boone County 

Collector of Revenue 2016). 

3.7.9 Education

There are six public school districts located within Boone County. The Columbia Public School 

District services the population within the 5-mi (8-km) radius of the proposed NWMI facility at 

Discovery Ridge. Total enrollment in the Columbia School District was 17,872 during the 

2013-2014 school year (NCES 2015b).

3.7.10 Public Recreation for Boone County

The parks and open spaces within Boone County are listed in Table 3–19, along with their 

approximate distance from the proposed NWMI facility at the Discovery Ridge site.
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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

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

In addition to the parks, several other public facilities are located within a 5-mi (8-km) radius of 

the proposed NWMI facility at Discovery Ridge, including:

Aquatic centers – The Columbia Parks and Recreation Department manages four outdoor and 

two indoor pools. Only two of these facilities, Douglass Family Aquatic Center and Stephens 

Lake Swimming Beach and Spraygrounds are located within a 5-mi (8-km) radius of the 

proposed NWMI facility at Discovery Ridge. The Douglass Family Aquatic Center is an outdoor 

facility that consists of a recreational pool, a slide, and a spray park. The Stephens Lake 

Swimming Beach and Spraygrounds consists of a lake and spraygrounds.

Columbia Area Seniors Center – The Columbia Area Seniors Center offers services and 

activities for seniors, including meals, computers, and meeting places for activities.

Armory Sports & Recreation Center – This indoor facility is used for basketball, volleyball, 

meetings, aerobics, and other programs. The facility includes a gymnasium, classroom, 
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meeting room, aerobics room, a cardio/strength training area, computer room, general 

recreation room, and locker rooms (NWMI 2015a).

3.7.11 Public Services

Medical

The City of Columbia and Boone County have many medical care facilities, including four 

hospitals and one veteran’s hospital. Boone Hospital Center has 321 beds, Landmark Hospital 

of Columbia has 42 beds, the University of Missouri Hospital has 528 beds, and Woman’s and 

Children’s Hospital has 98 beds (American Hospital Directory 2016).

Emergency Services

The Columbia/Boone County Office of Emergency Management is located in the City of 

Columbia. The Public Joint Communications Center coordinates County and City-wide 

responses and supports other local governments during major disasters and emergencies. It 

also prepares other governmental entities, private business, volunteer organizations, and 

citizens to respond and recover from major emergencies and disasters. The Public Joint 

Communications Center has a 24-hr dispatching service for City and County police and law 

enforcement, fire and rescue, and emergency medical services (Boone County).

Public Water

Table 3–20 lists the public water suppliers in Boone County and provides water source and 

population served for those suppliers. The Columbia Water Treatment Plant is owned by the 

City of Columbia and operated by the Water and Light Department. The service territory of the 

Columbia Water Treatment Plant includes the City of Columbia, where the majority of customers 

reside. Public Water Supply District 9 currently provides service to the northeast portion of the 

proposed NWMI facility site.

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
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3.8 Human Health

The proposed NWMI facility is a potential source of radiation and chemical exposure to onsite 

workers and offsite members of the public. Human health can be adversely affected by 

radioactive and chemical materials in the environment. The following sections discuss potential 

receptors in the vicinity of the Discovery Ridge site to radioactive and chemical materials, 

existing conditions at the Discovery Ridge site and surrounding area, and laws and regulations

to protect workers and the public against potential health risks from exposure to radioactive 

materials and hazardous chemicals used, generated, and released from the licensed facility.

3.8.1 Sensitive Receptors

The NRC evaluates the potential human health impacts in a region of interest (ROI) primarily 

within a 5-mi (8-km) radius from the proposed NWMI facility. Figure 3–14 identifies sensitive 

receptors (schools, medical facilities, parks, recreational areas, religious institutions, and 

retirement communities) that are within a 5-mi (8-km) radius of the proposed Discovery Ridge 

site. Table 3–21 identifies the distances to the nearest sensitive receptors from the proposed 

Discovery Ridge site. As discussed in Section 3.4.2, the nearest domestic supply well is located 

approximately 0.7 mi (1.1 km) northeast of the site and a public water supply well is located 

approximately 0.8 mi (1.3 km) south, southeast of the Discovery Ridge site.

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

Retirement/Assisted Living Facility 0.91 Northwest

Source: NWMI 2015a
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Figure 3–14. Location of Sensitive Receptors Near the Proposed Discovery Ridge Site

Source: Modified from NWMI 2015a

3.8.2 Radiation and Nuclear Hazards

3.8.2.1 Pathways for Human Exposure to Radiation and Radioactivity

Radioactive material released into the environment can expose individuals through the following 

pathways:
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• Inhalation exposure pathway: inhaling contaminated airborne emissions;

• Direct radiation: material that is deposited on the ground from passing airborne 

emissions becomes an external exposure source of direct radiation; exposure to 

radioactive waste or other radioactive material.

• Ingestion exposure pathway: Radioactive materials can be transported through a 

variety of routes into the human diet. Drinking milk or eating meat from animals that 

grazed on open pasture on which radioactive material was deposited; eating 

vegetables grown that are contaminated with radioactive material; and direct

consumption of contaminated surface water or groundwater.

3.8.2.2 Major Sources and Levels of Radiation

Naturally Occurring Background Sources

Naturally occurring background radiation is always present and originates from cosmic, 

terrestrial, and internal (within the human body) sources. Cosmic radiation comes from the sun 

and stars, and the dose received varies with weather and elevation. In the City of Columbia, 

where the proposed site is located, the average annual dose from cosmic radiation is 

approximately 28 millirem (mrem) (NWMI 2015a).

Terrestrial radiation comes from naturally occurring radionuclides in soil, water, and air. Areas 

with high natural soil concentrations of radioactive uranium or thorium are typically associated 

with higher terrestrial radiation doses, due to the dose from other radionuclides, particularly 

radon, which are produced by the decay of uranium and thorium. Based on Missouri’s average 

uranium and thorium concentrations, the average annual terrestrial radiation dose at the 

proposed site is approximately 228 mrem (NWMI 2015a).

Internal radiation comes from the radioisotopes potassium-40 and carbon-14, which occur 

naturally in the human body. A person’s average annual internal radiation dose is 

approximately 30-40 mrem (NWMI 2015a; EPA 2016i).

Current Human-Made Sources of Radiation

As discussed in Section 3.8.1, there are numerous medical facilities in the ROI. These facilities 

may use ionizing radiation for medical imaging or treatment (NWMI 2015a). The average 

person receives a dose of about 310 mrem per year from human-made radiation sources; about 

96 percent of this dose comes from medical procedures (NRC 2016e).

The University of Missouri research reactor (MURR) is located approximately 4 mi (6.4 km) from 

the proposed Discovery Ridge site. The radiological environmental monitoring program at 

MURR, and the environmental effects of operation of the MURR, are discussed in detail in 

Section 3.10.1. The regulations at 10 CFR 50.47 require that, in general, nuclear power 

reactors shall have an emergency planning zone (EPZ) that consists of an area about 50 mi

(80 km) in radius. The Callaway Energy Center, a nuclear power plant, is located about 28 mi 

(45 km) southeast of the proposed NWMI facility site; therefore, the proposed site is within the 

EPZ for the Callaway Energy Center.

The Callaway Energy Center has a radiological environmental monitoring program that includes 

collection of water, terrestrial, air, and biological samples. Surface water, groundwater, drinking 

water, and sediment samples are collected on either a monthly, quarterly, or semi-annual basis, 

and are analyzed for gamma-emitting isotopes. The water samples are also analyzed for 

tritium. Soil samples are collected on an annual basis and analyzed for gamma-emitting 

isotopes. Continuous air monitoring is performed to monitor for iodine-131 and other gamma 

isotopes in air; the filters from the continuous air monitor systems are analyzed weekly. 
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Biological sampling includes collection and gamma isotope analysis of milk, fish, and vegetation 

on either a monthly or semi-annual basis. Although radionuclides were detected in water, 

terrestrial, air, and biological samples in 2012, 2013, and 2014, the types and quantities of 

radionuclides were consistent with naturally occurring levels and/or historical data at the

Callaway site. The Callaway Energy Center’s radiological environmental monitoring program 

also measures direct ambient gamma radiation at 40 locations using thermoluminescent 

dosimeters (TLDs). During 2012, 2013, and 2014, the dose levels measured by these TLDs 

were similar to historical results (AMEREN 2013, 2014, 2015).

Analytical Bio-Chemistry Laboratories Inc. (ABC) currently engages in the industrial and 

commercial use of radiation. The ABC Laboratories facilities, located approximately 500 ft 

(152 m) and 5 mi (8 km) from the proposed site, use radiation and radioactive materials for 

various research and analysis purposes. Although occupational dose monitoring is conducted 

for ABC Laboratories personnel, no radiological environmental monitoring program is currently 

required for the ABC Laboratories facilities (NWMI 2015a; NRC 2015h). 

Historical radionuclide releases to the environment have occurred at the ABC Laboratories site 

approximately 5 mi (8 km) northeast of the proposed NWMI facility site. In 1968, two sanitary 

lagoons were constructed for collection of liquid effluents containing radionuclides, primarily 

carbon-14. In 1986, these lagoons were closed, and they were later backfilled. Also in 1986, a 

third lagoon was constructed and placed into use. The third lagoon was closed in 2004, drained 

in 2011, and backfilled in 2012. Low levels of radioactivity continue to be present at the 

lagoons. However, surveys have shown these levels of radioactivity to be very low. In 2011, 

the NRC determined that the portion of the site containing the two older backfilled lagoons met 

the criteria in 10 CFR 20.1402 for unrestricted use, and that area was released for unrestricted 

use. In 2013, the NRC approved a partial site release for unrestricted use for the portion of the 

ABC Laboratories site containing the newer backfilled lagoon (NWMI 2015a; ABC 2010, 2011; 

NRC 2011a, 2013c, 2013d).

In addition, the University of Missouri’s Pickard Hall, which is also within the ROI, contains 

legacy radium contamination from radioactive material separation activities conducted in the 

1900s through 1930s. Although personnel monitoring is conducted for selected Pickard Hall 

faculty and staff, and an internal standard operating procedure is used to help avoid the further 

spread of radioactive contamination within the building or to the environment, no radiological 

environmental monitoring program is associated with the University of Missouri’s Pickard Hall 

(NWMI 2015a; MU 2013). The radioactive material separation activities performed in Pickard 

Hall resulted in some radium contamination of subsurface soil in the immediate vicinity of 

Pickard Hall, in addition to the contamination within the building. The internal standard 

operation procedure used at Pickard Hall helps to avoid any further spread of the subsurface 

soil contamination by limiting disturbance of the subsoil (NWMI 2015a; MU 2013).

3.8.2.3 Regulations Governing Dose from Human-Made Sources of Radiation

The Atomic Energy Act of 1954, as amended (42 U.S.C. 2011 et seq.), gives the NRC authority 

to issue and enforce standards that provide an adequate level of protection for public health and 

safety and that protect the environment. The NRC staff evaluates the latest radiation protection 

recommendations from national and international scientific bodies as a basis for its radiation 

protection standards (10 CFR Part 20). A radioisotope production facility utilizing enriched 

uranium must receive a license from the NRC and comply with NRC regulations and conditions 

specified in the license to operate. A licensee is required to comply with occupational dose

limits for adults (10 CFR Part 20, Subpart C) and radiation dose limits for individual members of 

the public (10 CFR Part 20, Subpart D).
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The NRC staff evaluates the impact to human health from human-made sources of radiation or 

radioactive material by comparing the estimated dose to a person (occupational worker or 

member of the public) from the radiation source to the NRC’s radiation protection dose limits in 

10 CFR Part 20. The dose limits in 10 CFR Part 20 do not apply for radiation doses received by 

patients during medical imaging or treatment. Dose is calculated based on the amount of 

material, and either the amount of time spent in the vicinity of the radioactive material, or the 

amount of time an individual’s body retains radioactive material that has been inhaled or 

ingested.

The NRC regulations at 10 CFR 20.1201 establish occupational dose limits for adults. The 

regulations at 10 CFR 20.1201 specify an annual maximum allowable occupational dose (total 

effective dose equivalent or TEDE) of 5 rem to a radiation worker from exposure to radiation 

and radioactive material at a licensed facility. The regulations at 10 CFR 20.1201 also specify 

limits on occupational doses to individual organs or tissues, including a 50 rem annual 

maximum allowable dose to the skin of the extremities.

Under 10 CFR 20.2206, the NRC requires licensees to submit an annual report of their results 

of individual monitoring for each individual who required monitoring under 10 CFR 20.1502 

during a given year. The NRC regulations at 10 CFR 20.2202 and 20.2203 require licensees to 

submit reports of incidents and occurrences involving personnel radiation exposures that 

exceed regulatory limits. Licensees are required to investigate incidents and occurrences and 

to take corrective actions as necessary.

The NRC regulations at 10 CFR 20.1301 specify an annual maximum allowable dose of 

100 mrem to a member of the public from exposure to radiation and radioactive material at a 

licensed facility. In addition, 10 CFR 20.1101(d) imposes a 10 mrem constraint on dose from 

airborne radioactive material released into the environment. This dose constraint, which is 

applicable to the proposed NWMI facility, implements 10 CFR 20.1101(b), which requires NRC 

licensees to use, to the extent practical, procedures and engineering controls based upon sound 

radiation protection principles to achieve doses to members of the public and occupational 

workers that are as low as is reasonably achievable. The NRC regulations at 

10 CFR 20.1302(a) require licensees to make or cause to be made, as appropriate, surveys of 

radiation levels in unrestricted and controlled areas (both within and outside the site boundary), 

and to measure concentrations of radionuclides in effluents released from the facility, to 

demonstrate compliance with dose limits for individual members of the public. The NRC 

regulations at 10 CFR 20.2203 require licensees to submit reports of incidents and occurrences 

involving radiation exposures to members of the public that exceed regulatory limits.

3.8.3 Chemical Hazards

Chemicals enter the body through the skin, by inhalation, or by ingestion. Chemical exposure 

produces different effects on the body, depending on the chemical and the amount of exposure. 

Chemicals can cause cancer, affect reproductive capability, disrupt the endocrine system, and 

have other health effects. Acute effects from chemical exposure occur immediately (e.g., when 

somebody inhales or ingests a poisonous substance). Chronic or delayed effects result in 

symptoms, such as skin rashes, headaches, breathing difficulties, and nausea (NRC 2013b).

The EPA is responsible for the regulation of most chemicals that can enter the environment. 

The EPA regulates the management, including treatment, storage, and disposal, of hazardous 

chemicals. The EPA administers the following Federal acts related to chemical contamination: 

the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA); Toxic Substances Control Act 

(TSCA); Resource Conservation and Recovery Act (RCRA); Clean Water Act (CWA); Safe 

Drinking Water Act (SDWA); Clean Air Act (CAA); and Comprehensive Environmental 
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Response Compensation and Liability Act (CERCLA) (NRC 2013b). Other Federal acts are 

also implemented in the EPA’s regulations, as applicable.

EPA and MDNR regulations require reporting of environmental releases of certain toxic 

chemicals manufactured, processed, or otherwise used at a facility, if those releases are above 

threshold quantities (EPA 2016b, 2016h; NRC 2013b). Such releases from facilities must be 

reported to the EPA Toxics Release Inventory (TRI) Program in accordance with Section 313 of 

the Emergency Planning and Community Right-to-Know Act. Chemicals covered by the TRI 

program are those that cause cancer or other chronic human health effects, significant adverse 

acute human health effects, or significant adverse environmental effects. The current TRI toxic 

chemical list contains 594 chemicals. Within a 5-mi (8-km) radius of the Discovery Ridge site 

there are 11 facilities that release TRI chemicals to the environment and are required to submit 

annual reports on releases to the EPA (EPA 2016h; EPA 2016b).

EPA and MDNR regulations also require permitting of facilities that generate hazardous wastes 

above threshold quantities. Within the Discovery Ridge Research Park, two facilities, ABC and 

IDEXX BioResearch, are EPA and MDNR permitted hazardous waste generators. These 

facilities conduct analytical testing in biological or pharmaceutical applications. Reagent grade 

organic and inorganic chemicals, some of which are hazardous materials, are used to conduct 

analytical research at these facilities (EPA 2016d). ABC is a large quantity generator and in 

2013 this facility generated 17.8 tons of hazardous waste. IDEXX BioResearch is a small 

quantity generator (EPA 2016d). The University of Missouri South Farm (approximately 1.0 mi 

(1.6 km) from Discovery Ridge) and the Columbia Environmental Research Center (0.9 mi (1.5 

km) from Discovery Ridge) are also permitted small quantity hazardous waste generators 

(EPA 2016d). These facilities are periodically inspected to ensure compliance with applicable 

waste management regulations.

3.8.4 Other Hazards

The proposed NWMI facility will be an industrial facility with many of the typical occupational 

hazards found at other industrial manufacturing or production facilities. Workplace hazards can 

be grouped into physical hazards (e.g., hazards from slips, trips, and falls from a height and 

those from transportation, temperature, humidity, and electricity); physical agents (e.g., noise, 

vibration, and ionizing radiation); chemicals; and psychosocial issues (e.g., work-related stress) 

(NRC 2013b). Occupational hazards are regulated by the Occupational Safety and Health 

Administration (OSHA) regulations in Title 29 of the Code of Federal Regulations Part 1910. 

The NRC has a memorandum of understanding with OSHA regarding the responsibilities of 

each agency with regard to occupational safety and health at NRC-licensed facilities 

(OSHA 2013).

3.9 Transportation Environments

This section describes the local transportation systems, including roadway networks and traffic

volumes near the Discovery Ridge site.

3.9.1 Roads

Figures 2–1 and 2–2 show major roads and transportation features in the vicinity of the 

proposed NWMI facility site at Discovery Ridge. The proposed NWMI facility site is located just 

north of Discovery Ridge Drive within the City of Columbia limits. Discovery Drive and 

Discovery Parkway would provide access to the proposed NWMI facility site.
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Discovery Parkway intersects with U.S. Highway 63, a four-lane divided highway in Boone 

County, about 0.25 mi (0.4 km) to the south. The proposed NWMI facility at the Discovery 

Ridge site would have easy direct access via on- and off-ramps to U.S. Highway 63. 

U.S. Highway 63 proceeds north and intersects U.S. Interstate 70 approximately 5 mi (8 km) to 

the north. U.S. Highway 63 continues to Jefferson City, Missouri, 31 mi (50 km) to the south. 

U.S. Interstate 70 proceeds approximately 125 mi (201 km) east to St. Louis, Missouri, and 

125 mi (201 km) west to Kansas City, Missouri. Current average daily traffic volumes for nearby 

roads are listed in Table 3–22.

Average Daily Traffic Counts in the Vicinity of the Proposed 

NWMI Facility 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

3.9.2 Airports

The nearest airport is the Columbia Regional Airport approximately 7 mi (11 km) south of the 

proposed NWMI facility site at Discovery Ridge. The airport is owned and operated by the City 

of Columbia. It is also the only public use airport in Boone County.

For the 12-month period ending October 31, 2015, the airport had 22,950 aircraft operations or 

approximately 63 per day, 75 percent general aviation, 9 percent military, 11 percent air taxi, 

and 5 percent air carrier. At that time, 34 aircraft were based at the airport that were 50 percent 

single-engine, 26 percent multi-engine, and 24 percent jet (AMR 2016).

Two small private airports are located within 10 mi (16 km) of the proposed NWMI facility site at 

Discovery Ridge. These airports include the Cedar Creek Airport, approximately 6 mi (10 km) 

east and the Sugar Branch Airport, 10 mi (16 km) west of the proposed NWMI facility.

Two helicopter ports are located within 10 mi (16 km) of the proposed NWMI facility site at 

Discovery Ridge. These two heliports support hospital operations and include the University 

Hospitals and Clinics heliport and the Boone Hospital Center heliport, both of which are located 

approximately 4 mi (6 km) northwest.

3.9.3 Rail

The nearest Union Pacific siding is in Jefferson City, approximately 20 mi (32 km) south of the 

proposed NWMI facility site at Discovery Ridge. Union Pacific operates approximately 85 trains 

each day (UP 2015).
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Owned by the City of Columbia and operated by Columbia Water & Light, COLT Railroad 

provides rail service to the City of Columbia from Norfolk Southern Railroad’s main line in 

Centralia, Missouri. COLT Railroad’s two locomotives move over 1,500 cars a year. The rail 

line generally parallels State Highway B to Hallsville and State Highway 124 to Centralia. In the 

City of Columbia, the rail line is located just west of the Highway B industrial area, crosses 

U.S. Highway 63 approximately 3 mi (5 km) north of U.S. Interstate 70, and ends south of 

Rogers Street near the city center, approximately 5 mi (8 km) northwest of the proposed NWMI 

facility site at Discovery Ridge (CTR 2016).

3.10 Research Reactors

This section provides the existing regional and local environmental conditions at the research 

reactors where low-enriched (LEU) targets will be irradiated. This section will discuss in detail 

only the resources and environments that could potentially be affected by irradiation of LEU 

targets. The level of detail varies depending upon the potential for impacts, which is discussed 

in Section 4.13. Some resources are not considered in detail because irradiation of LEU targets 

at the research reactors is not anticipated to impact that resource area as explained in 

Section 4.13. For example, irradiation of LEU targets will not result in land disturbance, external 

building modifications, or additional water use; therefore, there would be no impacts on land 

use, geology, cultural resources, or water resources. Further, as discussed in Section 4.13, the 

irradiation of LEU targets will not require additional workers at MURR and would only add about 

10 additional workers at the Oregon State TRIGA Research Reactor (OSTR) for 8 weeks per 

year; therefore, the irradiation of targets would have no noticeable socioeconomics impact. As 

discussed in Section 4.13, because the consequences of accidents at research reactors would 

continue to be required to be within 10 CFR Part 20 limits, activities related to target irradiation 

at the research reactors are not anticipated to result in a significant change in impacts from

potential research reactor accidents.

3.10.1 University of Missouri Research Reactor 

The University of Missouri Research Reactor (MURR) is located in Boone County, Columbia, 

Missouri. MURR is a pressurized, light-water moderated and cooled reactor. The reactor is 

fueled with high-enriched uranium fuel and has a maximum steady-state power level of 

10 megawatts thermal (MW(t)) (MU 2006). MURR is situated on a 7.5 ac (3 ha) lot in a portion 

of the University Research Park, approximately 1-mi (1.6-km) southwest of the Missouri 

University at Columbia main campus (MU 2006). The staff at MURR consists of approximately 

140 full-time employees (MURR 2006). MURR is 4 mi (6.4 km) from the Discovery Ridge site.

The Missouri River is approximately 8.5 mi (13.6 km) west of MURR and the nearest stream is 

Hinkson Creek, approximately 305 m (1,000 ft.) south of MURR. Makeup secondary coolant 

water as a result of evaporative losses, 50 gpm (28 million gallons per year), is obtained from 

five wells owned and operated by the University of Missouri (MU 2006). The National Register 

of Historic Places (NRHP) lists a number of historical properties within 1.0 mi (1.6 km) from 

MURR, including: Sanborn Field and Soil Erosion Plots, Sanford F. Conley House, and the 

Francis Quadrangle Historic District (NRHP 2015). In 2010, during the MURR operating license 

renewal review, the Missouri SHPO informed the NRC that MURR is eligible for inclusion in the 

NRHP (MDNR 2010). In addition, a review of MDNR archaeological records and the 

Archeology Survey of Missouri found no evidence of archeological sites on the 7.5 ac (3.0 ha) 

MURR site (MU 2010).
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Air Quality and Noise

Boone County, where MURR is located, is designated unclassifiable/attainment for all NAAQS. 

The nearest resident is 0.5 mi (0.8 km) north of MURR. Existing noise sources near MURR 

include vehicular traffic along South Providence Road (Route 63), cooling towers associated 

with MURR, and sports venues (within 0.3 mi (0.48 km) of MURR). The MURR site is located 

within the University Research Park; therefore, the NRC staff estimates background noise levels 

of 65 dBA, which are typical of commercial areas.

Human Health 

The routine operation of MURR results in the release of airborne radioactive effluents to the 

environment. MURR technical specifications (TS) limit the concentration of radionuclides in 

these effluents to help ensure that the public dose limits in 10 CFR 20.1301 will not be 

exceeded (MU 2016c). In addition, MURR is required to comply with 10 CFR 20.1101(d), 

which, as discussed in Section 3.8.2.3, requires licensees to maintain public doses ALARA by 

establishing a 10 mrem constraint on public dose from airborne radioactive material released 

into the environment. Table 3–23 summarizes the average concentration, total activity 

released, and percent of TS limits for airborne argon-41 (Ar-41) releases in each of the years 

2013 through 2015. Other than Ar-41, no other radionuclides were released at average 

concentrations greater than 1 percent of MURR TS limits for any of the years 2013 through 

2015 (MU 2014, 2015a, 2016d).

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

Routine operation of MURR also results in the release of liquid radioactive effluents to the 

environment. These effluents are released to the sanitary sewer. In 2013 through 2015, the 

activity released consisted primarily of tritium (hydrogen-3 or H-3). Table 3–24 summarizes the 

sanitary sewer radioactive effluents for each of the years 2013 through 2015. During these 

years, MURR was in compliance with the sanitary sewer effluent regulations in 10 CFR 20.2003 

(MU 2014, 2015a, 2016d), which require that monthly average liquid effluent radionuclide 

concentrations be below the values listed in 10 CFR Part 20, Appendix B, Table 3 for releases 

to sewers.
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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

No liquid radioactive wastes were reported by MURR as having been packaged and shipped 

offsite during the 2013, 2014, or 2015 reporting periods (MU 2014, 2015a, 2016d).

Solid radioactive wastes produced by operation of the MURR include high-level and low-level 

radioactive wastes. All solid radioactive wastes produced at MURR are packaged and shipped 

off site for disposal. The high-level solid waste consists of used nuclear fuel. The U.S. 

Department of Energy maintains title to all nuclear fuel used at MURR, and is obligated by 

contract to take possession of the fuel after its use at MURR. Used fuel does not leave the 

MURR reactor pool until a predetermined cooling period has elapsed since the element was last 

removed from the reactor core, and the element has been loaded into NRC-approved shipping 

containers for shipment (MU 2006).

The solid, low-level radioactive wastes produced by MURR and shipped off site for disposal 

during 2013 through 2015 are summarized in 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

MURR reports personnel doses by dividing workers into dosimetry groups, each of which 

performs different types of work at MURR. The MURR reactor operations, reactor health 

physics, and shipping groups would be responsible for handling, packaging, and shipping the 

LEU targets at MURR (NWMI 2015a). Tables 3–26, 3–27, and 3–28 summarize the personnel 

doses for the operations, health physics, and shipping groups, respectively, in 2013 through 

2015. These doses are within the occupational dose limits for adults listed in 10 CFR 20.1201 

(MU 2014, 2015a, 2016d).
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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

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

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

MURR has an environmental monitoring program to measure offsite doses resulting from 

MURR facility operations. This program includes the use of 40 environmental monitoring 

stations, each consisting of a three-chip environmental TLD, at various locations within the 

fenced, licensed area and also beyond the fenced area at distances up to 907 m (2,976 ft) from 
Affected Environment

3-71

the facility stack. The total net dose equivalent measured at all 40 locations in 2013 was 

257 mrem, and the total net dose equivalents measured in the years 2009 through 2012 ranged 

from 201 to 371 mrem. Approximately 60 percent of these total doses were received at two 

TLDs located immediately adjacent to two separate loading docks that are part of the MURR 

laboratory building, and well within the fenced area; most other TLDs receive little or no dose 

(NWMI 2015a).

The MURR environmental monitoring program also includes semi-annual collection and 

analysis of environmental samples from eight locations near the MURR facility. Soil and 

vegetation samples are taken at all eight locations, water samples are taken at three of the eight 

locations, and subsurface soil samples are taken at six of the eight locations. Sampling 

performed in 2013 through 2015 has shown minimal environmental impact from MURR 

operation (MU 2014, 2015a, 2016d).

Transportation Environments

MURR is approximately 3.5 mi (5.6 km) southwest of the Interstate-70/U.S. Highway 63

intersection. U.S Highway 63 runs north-south and Interstate-70 east-west. Major access 

roads to MURR include North Providence Road to the east of MURR and E. Stadium Blvd to the 

North. Research Park Drive provides direct access to the site. Table 5–2 provides average 

daily traffic counts in the vicinity of MURR. For instance, in 2013, average daily traffic counts 

along Providence Road (Route 163), south of Route 740 was 29,802.

3.10.2 Oregon State University Research Reactor

The OSTR is located in Benton County, Corvallis, Oregon. OSTR is a water cooled reactor. 

The reactor is fueled with TRIGA (uranium/zirconium hydride) fuel and operates at a 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

) facility. The Williamette River is approximately 1.60 mi (2.6 km) 

east of OSTR. OSTR is 2,000 mi (3,219 km) from the proposed NWMI facility at the Discovery 

Ridge site.

The National Register of Historic Places (NRHP 2015) lists a number of historical sites within 

0.5 mi (0.8 km) from the OSTR site boundary, including the J. Leo Fairbanks House and the 

College Hill West Historic District John Bexell House. Makeup coolant water for the secondary 

coolant system, approximately 1,500 gal (5,700 L) per day as a result of evaporative losses, is 

obtained from the City of Corvallis (OSU 2004, 2006).

Air Quality and Noise

Benton County is designated unclassifiable/attainment with respect to NAAQS (40 CFR 81.338). 

Residential development is concentrated north of the OSTR and the nearest resident is 0.25 mi 

(0.4 km) north of OSTR. Existing noise sources near (within 0.5 mi (0.8 km)) OSTR include 

vehicular traffic and sport venues (Goss Stadium, Reser Stadium). Due to the proximity of the 

residential areas to OSTR, NRC staff estimates background noise levels of 55 dBA, which are 

typical of residential areas.

Human Health and Waste Management

The routine operation of the OSTR results in the release of airborne radioactive Ar-41 effluent to 

the environment. The typical concentration (averaged over a one year reporting period) of 

Ar-41 at the point of release from the OSTR is 1.4x10-7 microcuries per milliliter (μCi/mL), which 

corresponds to a total annual release of approximately 20 curies of Ar-41 (NWMI 2015c). 

OSTR TSs ensure that the public dose from OSTR’s airborne Ar-41 effluent is in compliance 

with the public dose limit in 10 CFR 20.1301 and the 10 mrem constraint in 10 CFR 20.1101(d) 
Affected Environment

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by requiring that the annual average concentration of Ar-41 at the point of discharge from the 

OSTR facility does not exceed 4x10-6 μCi/mL (OSU 2016); OSTR’s annual average Ar-41 

release concentration is well within this limit. No measureable quantities of radionuclides other 

than Ar-41 are released from OSTR (NWMI 2015c).

Routine operation of OSTR also results in the release of liquid radioactive effluents to the 

environment. These effluents are released to the sanitary sewer. In July 2012 through 

June 2015, the activity released consisted primarily of H-3. Sewer radioactive effluents are 

reported for the Oregon State University (OSU) Radiation Center as a whole, rather than for the 

OSTR and Radiation Center laboratories separately; therefore, reported values include liquid 

effluent activity released for both the OSTR and the Radiation Center Laboratories. For the 

OSU Radiation Center, during each of the annual reporting periods July 2012 to June 2013, 

July 2013 to June 2014, and July 2014 to June 2015, the monthly average concentrations of 

H-3 in liquid effluents were less than 10 percent of 10 CFR Part 20, Appendix B, Table 3 limits 

on releases to sewers, and the monthly average concentrations of all other radionuclides were 

less than 1 percent of 10 CFR Part 20, Appendix B, Table 3 limits. Therefore OSTR, and the 

OSU Radiation Center, were in compliance with the sanitary sewer effluent regulations in 

10 CFR 20.2003 (OSU 2013, 2014, 2015a).

OSTR produces other liquid radioactive wastes that are packaged and transferred off site for 

disposal. From July 2012 to June 2015, a total of 13.5 gal (51 L) of liquid waste containing 

3.25x10-3 Ci of total activity was transferred off site (OSU 2013, 2014, 2015a).

Solid radioactive wastes are produced by operation of the OSTR. All solid radioactive wastes 

produced at OSTR are packaged and shipped off site for disposal. During OSTR’s current 

20-year license term, starting in 2008 and continuing through 2028, the OSTR licensee does not 

anticipate the need to ship any high-level radioactive waste (OSU 2008). The solid, low-level 

radioactive wastes produced at OSTR and transferred off site for disposal during each of the 

annual reporting periods of July 2012 to June 2013, July 2013 to June 2014, and July 2014 to 

June 2015, are summarized in 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

OSTR facility operating personnel would be responsible for handling, packaging, and shipping 

the LEU targets at OSTR. Table 3–30 summarizes the personnel doses for OSTR facility 

operating personnel during each of the annual reporting periods of July 2012 to June 2013, 

July 2013 to June 2014, and July 2014 to June 2015. These doses are within the occupational 

dose limits for adults listed in 10 CFR 20.1201.
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3-73

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

OSTR has an environmental monitoring program to measure offsite doses resulting from facility 

operations. This program includes the use of nine environmental monitoring stations, each 

consisting of a three-chip environmental TLD, at locations along the fence that surrounds the 

reactor. Over a 7-year period ending in 2014, the average annual net dose equivalents 

measured at these stations ranged from 7 to 18 mrem (NWMI 2015a).

The OSTR environmental monitoring program also includes annual collection and analysis of 

environmental samples from 22 locations near the OSTR facility. Soil samples are collected at 

four locations, water samples (when available) are collected at four locations, and vegetation 

samples are collected at 14 locations. Sampling performed during each of the annual reporting 

periods of July 2012 to June 2013, July 2013 to June 2014, and July 2014 to June 2015 found 

levels of environmental radioactivity consistent with naturally occurring radioactivity and 

comparable to values reported in previous years (OSU 2013, 2014, 2015a).

Transportation Environments

OSTR is bordered to the west by 35th Street, to the south by South Jefferson Way, to the north 

by South Campus Way, and to the east by the South 30th St. Major roads in the vicinity of 

OSTR include U.S. Route 20 to the south (0.7 mi (1.1 km) away), NW Harrison Boulevard to the 

north (0.5 mi (0.8 km) away), State Highway 99W to the east (1.4 mi (2.3 km) away), and 

Interstate-5 (I-5) to the east (11.4 mi (23.2 km) away). Annual average daily traffic volume 

along these roads are as follows (ODOT 2014a, 2014b):

• Harrison Street/East of State Highway 99W: 11,000-12,900, 

• along State Route 34 (at State Route 99W intersection): 20,001–30,000, 

• along State Route 99W (at State Route 34 intersection): 15,001–2000

• along Interstate 5 (at State Route 34 intersection): 30,001–50,000, and

• along U.S. Route 20 (near 35th street intersection): 16,300–16,900.

3.10.3 Third Research Reactor

NWMI is also considering use of a third research reactor and is performing an analysis to 

support that selection (NWMI 2015a, 2015c). NWMI has stated that the third research reactor 

will be similar to the OSTR and located on a university campus (NWMI 2015a). Therefore, the 

research reactor design and operations will be similar to what is discussed for the OSTR in 
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3-74

Section 3.10.2 above. Distance of the third research reactor to the proposed NWMI facility at 

Discovery Ridge will be bounded by 2,000 mi (3,219 km) since the OSTR is the greatest 

distance between the proposed Discovery Ridge site and any operating research reactor in the 

continental United States. An NRC licensed research reactor is required to comply with 

10 CFR Part 20 dose limits. Further, the operating license includes a TS requiring that an 

annual report be submitted to the NRC that discloses radioactive effluents released, an estimate 

of radionuclides present in effluents, and radiological exposure received by facility personnel.
4-1

4.0 ENVIRONMENTAL IMPACTS OF CONSTRUCTION, 

OPERATIONS, AND DECOMMISSIONING

This chapter addresses potential environmental impacts related to the proposed construction, 

operations, and decommissioning of the Northwest Medical Isotopes, LLC (NWMI) medical 

radioisotope production facility (NWMI facility). The U.S. Nuclear Regulatory Commission 

(NRC) standard of significance for impacts uses the Council on Environmental Quality (CEQ)

terminology for “significantly” (Title 40 of the Code of Federal Regulations (40 CFR) 1508.27).

Because the significance and severity of an impact can vary with the setting of the proposed 

action, both “context” and “intensity,” as defined in CEQ regulation 40 CFR 1508.27, were 

considered. Context is the geographic, biophysical, and social context in which the effects 

would occur. Intensity is the severity of the impact. Based on this, the NRC established three 

levels of significance for potential impacts: SMALL, MODERATE, and LARGE. The definitions 

of these three significance levels, which are presented in the Interim Staff Guidance to 

NUREG-1537 (NRC 2012), follow:

SMALL—environmental effects are not detectable or are so minor that they 

would neither destabilize nor noticeably alter any important attribute of the 

resource. In assessing radiological impacts, the NRC has concluded that those 

impacts that do not exceed permissible levels in the NRC’s regulations are 

considered SMALL.

MODERATE—environmental effects are sufficient to alter noticeably, but not to 

destabilize, important attributes of the resource.

LARGE—environmental effects are clearly noticeable and are sufficient to 

destabilize important attributes of the resource.

For this environmental impact statement (EIS), the NRC staff characterized impact levels using 

the above definitions (NRC 2012). These impacts are grouped and presented according to the 

resource area. Within each resource area, the NRC staff determined the impacts during each of 

the three phases: construction, operations, and decommissioning. As described in Section 1.6, 

preconstruction is related to the building of the proposed NWMI facility and a combined 

construction (preconstruction and NRC-authorized construction) impact level is provided. When 

the combined construction impact category level is SMALL for any resource area (e.g., land 

use, water resources, etc.), no further breakdown of impacts between preconstruction and 

NRC-authorized construction will be provided. When the combined construction impact 

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

NRC-authorized construction activities will be discussed separately. The impacts from 

operations of the proposed medical radioisotope production facility presented in this Chapter 

consider those activities associated with facility operations identified in Section 2.3, including 

preoperation startup activities, transportation of material to and from the proposed facility, and 

processes conducted inside the facility building (target fabrication and scrap recovery, irradiated 

target disassembly and dissolution, Mo-99 recovery and purification, and uranium recovery and 

recycling). 

The NRC staff characterizes the impacts to resources as a single level or as a range of impact 

levels. A range of impacts may be provided if environmental conditions are uncertain or if there 

are multiple circumstances associated with environmental conditions surrounding the proposed 

or alternate sites. For example, a range of impacts may be appropriate to characterize impact 

levels if the environment changes in time or space, such as the impacts may be smaller at 

certain times or in certain places and larger at other times or places.
Environmental Impacts of Construction, Operations, and Decommissioning

4-2

4.1 Land Use and Visual Resources

4.1.1 Land Use

4.1.1.1 Construction

The proposed Discovery Ridge site currently includes 7.4 acres (ac) (3.0 hectares (ha)) of 

agricultural land (NWMI 2015a; NRC 2015b; USGS 2006; Fry et al. 2011). The facility would 

occupy a rectangular area approximately 213 by 91 meters (m) (700 by 300 feet (ft)) at the outer 

perimeter and cover approximately 1.95 ha (4.8 ac) (NWMI 2015a). The restricted area would 

be the area inside the fence surrounding the facility. The unrestricted area would be the area 

outside the fence surrounding the main building (NWMI 2015a).

Construction of the proposed NWMI facility would permanently disturb and convert 7.4 ac 

(3.0 ha) of agricultural land into an industrial area that would include facility buildings, an 

administrative building, an employee parking lot, facility access roads, and other support 

facilities (Table 4–1). In addition, 0.26 ac (0.1 ha) of an offsite adjacent lot (Lot 14) in the 

research park would be temporarily converted from agricultural land to a construction material 

staging area (NWMI 2015a, 2015c). Once construction activities are complete, NWMI would 

restore temporarily affected areas with vegetation that is common to the Discovery Ridge 

Research Park (NWMI 2015c). The remaining portion of the site would likely remain as open or 

landscaped areas in accordance with the Discovery Ridge Research Park covenants (MU 2009, 

NWMI 2015a). Ground vegetation would include grasses, shrubs, trees and/or ornamental 

flowers including native species (NWMI 2015c). The potential temporary and permanent 

conversion of up to 7.66 ac (3.1 ha) of pasture/hay would be minor when compared to the 

15,158 ac (6,134 ha) of pasture/hay remaining within 5 mi (8 km) of the proposed site.

Land use impacts would be confined to 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. Therefore, no coastal 

zones or areas with a special land use or mineral resources (as described in Section 3.1) would 

be affected by the proposed construction of the NWMI facility (NWMI 2015a; NRC 2015b; 

NRCS 2016a, 2016b; Find the Data 2016; NOAA 2016).

Based on the relatively small amount of pasture/hay that would be permanently converted to 

other land uses, the lack of important farmland soils within affected areas, the location of the 

proposed facility within an area designated as an industrial certified site, and the lack of special 

land use or mineral resources on site, land use impacts from construction would be SMALL.

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

4.1.1.2 Operations

Operation of the NWMI facility would not require any new land or require land use changes 

beyond that required for construction. Therefore, land use impacts during operations would be 

SMALL.

4.1.1.3 Decommissioning

Decommissioning activities would be similar to construction activities because they would 

involve heavy equipment to dismantle buildings and remove roadway and parking facilities. 

Land requirements to perform these activities would be the same or less than those required 

during construction (NWMI 2015a). After decommissioning activities are complete, the 

proposed site could remain industrial or could be converted back to agricultural land. Given that 

the site is located within a currently existing research park, it is likely that the site would remain 

for industrial use, assuming the research park is still operating. Given that land requirements 

would be similar to those described during construction and that, after decommissioning is 

complete, land would either be industrial, agricultural, or open space, land use impacts during 

decommissioning would be SMALL.

4.1.2 Visual Resources

4.1.2.1 Construction

As described in Section 3.1.2, the visual setting of the proposed NWMI facility includes 

agricultural, residential, light industrial, and forested viewsheds. The proposed site is currently 

used for agricultural purposes, and no existing structures or natural or built barriers, screens, or 

buffers occur on site. NWMI would build a Radioisotope Production Facility (RPF) building that 

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

(NWMI 2015a). The highest point at the NWMI facility would be the three exhaust stacks that 

extend 75 ft (66 m) from the ground (NWMI 2015a). The high bay, which would be the second 

story above the process area, would be 65 ft (19.8 m) high. NWMI (2015a) estimated that the 

stacks would be visible from 2 mi (3.2 km) away. Figure 4–1 is a conceptual rendering of the 

proposed NWMI facility based on these dimensions.

The activities associated with construction of the NWMI facility (e.g., excavation, earthmoving, 

pile driving, and erection) would require large equipment, would significantly alter onsite 

conditions, and would partially obstruct views of the existing landscape. However, as described 

in Section 3.1.2, the NRC staff determined that the proposed site has low scenic quality 

because of a lack of notable features, uniform landform, low vegetation diversity, an absence of 

water, mute colors, cultural modifications to adjacent scenery, and a commonality within the 

physiographic province. The NRC staff also determined that the proposed site has a low 

sensitivity rating because it is in an area with low scenic values resulting from a low amount of 

use by viewers, low public interest in changes to the visual quality of the proposed site, a low 

sensitivity to changes in visual quality by the type of users in the area, and a lack of special 

natural and wilderness areas. In addition, the viewshed surrounding the proposed site is 

partially aesthetically altered by light industrial buildings, research facilities, residences, and 

roads. Further, once construction activities are complete, NWMI would revegetate open areas 

with grasses, shrubs, trees and/or ornamental flowers including native species (NWMI 2015c). 

Vegetation could partially mitigate impacts to visual resources given that the majority of the 

surrounding viewshed is pasture, hay, or grasses. Based on the low scenic quality and light 

industrial viewshed within the vicinity, construction-related aesthetic impacts would be SMALL.

4.1.2.2 Operations

The appearance of the NWMI facility would not change during operation, other than a small

steam plume that may be visible coming from the exhaust stack. The steam plume from the 

exhaust stack is expected to be minimal because opacity associated with the natural gas-fired 

boilers tends to be low, and, as described in Section 4.2.1.2, emissions will not be significant. 

The plume would be more visible during periods of cold weather, although the size of the plume 

would still be relatively small. Therefore, visual impacts during operations would be SMALL.

Figure 4–1. Conceptual Rendering of Proposed NWMI Facility

Source: NWMI 2015a
Environmental Impacts of Construction, Operations, and Decommissioning

4-5

4.1.2.3 Impacts from Decommissioning

Decommissioning activities would be similar to construction activities because they would 

involve heavy equipment to dismantle buildings and remove roadway and parking facilities. 

After NWMI completes decommissioning activities, the proposed site could remain industrial or 

could be converted back to agricultural land. Given that the site is located within a currently 

existing research park, it is likely that the site would remain for industrial use, assuming the 

research park is still operating. As the proposed NWMI facility is located in a certified industrial 

site and the viewshed surrounding the proposed site is partially aesthetically altered by light 

industrial buildings, the NRC staff would not expect any changes to the landscape to 

significantly affect any viewsheds. Therefore, visual impacts during decommissioning would be 

SMALL.

4.2 Air Quality and Noise

Air and noise emissions would occur during construction, operations, and decommissioning of 

the proposed NWMI facility. Emission sources, pollutants, and durations would be different for 

each phase and are discussed below. The region of influence (ROI) for this air quality analysis 

is Boone County, which is designated as an unclassifiable/attainment area for all criteria 

pollutants. The ROI for the noise analysis is a 1-mi (1.6-km) radius from the site boundary of 

the proposed NWMI facility.

4.2.1 Air Quality

4.2.1.1 Construction

During construction, earth-moving equipment, non-road vehicles, and worker and delivery 

vehicles will be sources of air emissions. Earth moving activities, including excavation, clearing, 

and compacting, will generate fugitive dust on site. Operation of construction equipment will 

emit criteria pollutants (particulate matter, carbon monoxide, sulfur dioxide, and nitrogen oxides) 

on site from the combustion of fuels in equipment. Table 4–2 identifies construction equipment, 

total activity, and material moved during construction. Employee and delivery and shipment 

vehicular exhaust will emit criteria air pollutants (particulate matter, carbon monoxide, sulfur 

dioxide, and nitrogen oxides) and generate fugitive dust emissions, some of which would occur 

on site and others would occur off site. However, fugitive dust emissions should be minimal for 

vehicles when traveling on paved roads off site. A peak workforce of 82 and a total of 

21 deliveries and shipments per week are anticipated during construction (NWMI 2015c). 

Completion of the proposed NWMI facility is estimated to take up to 17 months. Fugitive dust 

emissions are anticipated to be greatest during the initial site preparation activities and would 

vary depending on the level of activity. Therefore, fugitive dust emissions and equipment 

exhaust emissions will be localized and temporary.

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
Environmental Impacts of Construction, Operations, and Decommissioning

4-6

Equipment Type Total Activity (hours) Material Moved (tons)

Paver 80 N/A

Asphalt Roller 80 N/A

Source: NWMI 2015a

Construction-related emissions from earth-moving activities, equipment, and on-road vehicles 

are presented in Table 4–3. Overall construction-related emissions for criteria pollutants are 

well below the significant de minimis levels under the New Source Review program and the 

250 tons/year (TPY) threshold for a major source as discussed in Section 3.2.2 of this EIS. 

Total greenhouse gas emissions (GHGs) (approximately 750 tons of carbon dioxide equivalents 

(CO2eq) per year) would be well below the 75,000 TPY of CO2eq (68,000 metric TPY) threshold 

for prevention of significant deterioration (PSD) and Title V permits set in the Greenhouse Gas 

(GHG) Tailoring Rule and the U.S. Environmental Protection Agency’s (EPA’s) mandatory GHG 

Tailoring Rule (74 FR 56260). Further, construction-related emissions would be less than 

1 percent of Boone County annual emissions. Therefore, the NRC staff does not expect 

increases in air emissions from construction activities to contribute to concentrations that would 

exceed National Ambient Air Quality Standards (NAAQS) in Boone County.

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

The nearest Class I Federal Area to the proposed site is the Hercules-Glades Wilderness Area, 

approximately 70 mi (113 km) away. EPA recommends that sources located within 62 mi 

(100 km) of a Class I Federal Area be modeled to consider adverse impacts (EPA 1992). Given 

the distance and estimated emissions from construction, the NRC staff does not anticipate that 

activities from construction could adversely affect air quality and air quality-related values 

(e.g., visibility or acid deposition) in the nearest Class I Federal Area. NWMI may need to 

obtain an air construction permit from MDNR prior to commencing construction in accordance 

with 10 CSR 10-6.060. NWMI intends to initiate the permit review and applicability 

determination with MDNR (NWMI 2015c).
Environmental Impacts of Construction, Operations, and Decommissioning

4-7

The emission estimates presented in Table 4–3 do not account for best management practices 

(BMPs) or mitigative measures that can be implemented during construction-related activities to

reduce emissions. For instance, NWMI proposes to control particulate matter by watering 

unpaved and disturbed areas, stabilizing spoil piles, revegetating slopes, and minimizing soil

disturbance via phased grading (NWMI 2015a). Furthermore, to reduce equipment related 

emissions, NWMI proposes to implement the following measures: reduce equipment idle times, 

use ultra-low sulfur diesel fuel, and install pollution control devices on construction equipment.

Given that (1) air emissions during construction would be local and temporary (duration of 

17 months), (2) Boone County is designated as an unclassifiable/attainment area, 

(3) construction emissions are well below major air source thresholds, and (4) construction 

emissions are not expected to contribute to concentrations that would exceed the NAAQS, the 

NRC staff concludes that air quality impacts during construction would be SMALL.

4.2.1.2 Operations

Air emissions sources from operation of the proposed NWMI facility would be predominantly 

from: (1) target fabrication and irradiated target processing; (2) fuel combustion associated with 

processing and facility heating purposes; and (3) vehicular traffic from workers commuting and 

from shipments and deliveries during operations.

As discussed in Section 2.3.1, NWMI facility operations will include target preparation and 

processing for extraction of molybdenum-99 (Mo-99), which involves dissolution of uranium in 

nitric acid. Dissolution will result in gases, which include nitrogen oxides (NWMI 2016a). The 

offgas will pass through a reflux condenser and nitrogen oxide absorbers prior to being filtered 

and discharged into the process exhaust system (NWMI 2015a). Total nitrogen oxide emissions

from the radioisotope production process would be 0.05 TPY (0.04 MT/year) (NWMI 2015c, 

2016a).

Fuel combustion sources housed in the NWMI facility will include five gas-fired boilers and a 

diesel generator. NWMI boilers will be used for the heating, ventilation, and air conditioning 

(HVAC) system and for process steam used to provide heating for process equipment 

(NWMI 2015a, 2015b, 2015c). Three boilers are expected to be operating at any one time (two 

heating and one process steam boiler) (NWMI 2015c). The diesel generator will be used for 

emergency power, if needed, and will be operated for routine testing and maintenance 

(NWMI 2015a). The operation of the gas-fired boilers and diesel generator will emit criteria 

pollutants (carbon monoxide, particulate matter, nitrogen oxides, and sulfur dioxide) and GHGs. 

Annual emissions from these combustion sources are presented in Table 4–4. NWMI may need 

to obtain an air permit from MDNR to install and operate these fuel combustion sources in 

accordance with 10 CSR 10-6.060 or 10 CSR 10-6.065. NWMI intends to initiate the permit 

review and applicability determination with MDNR (NWMI 2015c).

Vehicle exhaust from workers and from shipments and deliveries during operations will emit 

criteria pollutants (carbon monoxide, particulate matter, nitrogen oxides, and sulfur dioxide) and 

GHGs. During operations, 98 workers will be commuting to and from the proposed site. 

Shipments to and from the proposed site will include fresh low-enriched uranium (LEU), 

unirradiated LEU targets, irradiated targets, Mo-99 product, spent LEU, and waste. The total 

projected annual number of shipments is 484 or approximately 10 shipments/week 

(NWMI 2015c, 2016a). Vehicle emissions during operations is presented in Table 4–4.
Environmental Impacts of Construction, Operations, and Decommissioning

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Emissions Sources and Estimated Emissions During Operations

Emissions During Operation (tons/year)

Source CO NOx SO2 PM10 PM2.5 CO2

Target processing - 0.05 - - - -

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

Operation-related emissions from predominant sources are presented in Table 4–4. Total 

operational emissions for criteria pollutants are well below the significant de minimis levels 

discussed under the New Source Review program and Title V major operating source threshold 

(100 TPY) discussed in Section 3.2.2 of this EIS. Total GHGs (approximately 27,000 tons 

CO2eq per year) would be well below the 75,000 TPY of CO2eq (68,000 metric TPY) threshold 

for PSD and Title V permits set in the Greenhouse Gas (GHG) Tailoring Rule. Further, 

operation-related emissions for carbon monoxide, nitrogen oxides, sulfur dioxide, and 

particulate matter are less than 1 percent of Boone County annual emissions and carbon 

dioxide emissions are less than 5 percent. Therefore, the NRC staff does not expect increases 

in air emissions from operations to contribute to concentrations that would interfere with the 

maintenance of NAAQS or degrade Boone County’s unclassifiable/attainment designation.

The nearest Class I Federal Area to the proposed site is the Hercules-Glades Wilderness Area, 

approximately 70 mi (113 km) away. EPA recommends that sources located within 62 mi 

(100 km) of a Class I Federal Area be modeled to consider adverse impacts (EPA 1992). Given 

the distance and estimated emissions from operation, the NRC staff does not anticipate that 

activities from operation could adversely affect air quality and air quality-related values 

(e.g., visibility, acid deposition) in the nearest Class I Federal Area.

NWMI proposes to 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 (NWMI 2015a).

Given that operation-related air emissions are well below the significant de minimis levels and 

Title V major source threshold, operational emissions are not expected to contribute to 

concentrations that would exceed the NAAQS or degrade Boone County’s air quality 

designation (unclassifiable/attainment area) therefore, the NRC staff concludes that air quality 

impacts during operation would be SMALL.
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4.2.1.3 Decommissioning

Decommissioning activities would be similar to construction activities. The decommissioning 

activities would include, for example, vehicular traffic, earth-moving equipment, demolition of 

structures, and dismantlement and decontamination of systems over a period of up to 

24 months (NWMI 2015a, 2016a). Equipment, worker vehicles, and truck shipments will emit 

criteria air pollutants (particulate matter, carbon monoxide, sulfur dioxide, and nitrogen oxides) 

and GHGs. Demolition and dismantlement of structures will emit fugitive dust. A daily peak 

workforce of 81 and a total of 21 deliveries and shipments per week are anticipated during 

decommissioning (NWMI 2015c). Equipment used and diesel fuel consumption for 

decommissioning activities would be similar to those presented in Table 4–2. Emissions from 

decommissioning would be localized and temporary and are presented in Table 4–5. Emissions 

are well below the significant de minimis levels discussed under the New Source Review 

program and the 250 TPY threshold for a major source as discussed Section 3.2.2 of this EIS. 

Therefore, the NRC staff does not expect air emissions from decommissioning activities to 

contribute to concentrations that would exceed the NAAQS or prevent Boone County from 

maintaining its unclassifiable/attainment designation.

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

Given that air emissions during decommissioning would be local and temporary 

(decommissioning phase of up to 24 months) and that decommissioning-related emissions are 

well below major air source thresholds, the NRC staff concludes that the air quality impact 

associated with the decommissioning phase would be SMALL.

4.2.2 Noise

4.2.2.1 Construction

Noise sources associated with building the proposed NWMI facility will include construction 

equipment on site and workforce and shipment/delivery vehicles. Increased traffic volumes 

because of 82 workers and 21 deliveries per week can increase noise emissions along road and 

highways near the proposed Discovery Ridge site. While workers would be able to access the 

site using a combination of routes, it is reasonable to assume that U.S. Highway 63, St. Lenoir 

Street, Discovery Drive, and Discovery Parkway will experience an increase in traffic volumes 

as a result of the construction workforce and deliveries because these are access roads to the 

proposed site. NWMI modeled highway noise to estimate noise levels when an additional 

100 vehicles are added to peak traffic volume along U.S. Highway 63 (NWMI 2015c, 2016a, 
Environmental Impacts of Construction, Operations, and Decommissioning

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2016d). An additional 100 vehicles will increase noise by 1 decibel on the A-weighted scale 

(dBA) at 85 m (280 ft) distance from U.S. Highway 63 and at the nearest residence to the 

proposed Discovery Ridge site. Most people are unable to discern noise level differences less 

than 3 dBA.

Noise emissions will vary with each phase of construction and will depend on the duration and 

mix of equipment used. The types of equipment that would be used on site during construction 

are listed in Table 4–2. Noise emissions from equipment that will be used during construction 

are predicted to be in the 80- to 85-dBA range at a 50-ft (15-m) distance (FHWA 2006); 

however, noise levels attenuate rapidly with distance. As discussed in Section 3.2.3, the 

nearest noise sensitive receptor is the IDEXX BioResearch facility, which is approximately 

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 

NRC staff estimates noise levels from construction equipment to be 59 to 64 dBA (GSU 2016). 

The nearest residence is approximately 0.4 km (0.27 miles; 1,425 ft) from the proposed site. At 

this distance, the NRC staff estimates noise levels from construction equipment to be 50 to 

55 dBA (GSU 2016). Noise levels from construction equipment can further be dampened by the 

existing building walls at the IDEXX BioResearch facility and existing walls of the nearest 

residence. Noise levels from construction equipment to noise sensitive receptors are not 

anticipated to exceed the existing noise levels from traffic on U.S. Highway 63 (69 dBA), 

agricultural equipment (84 dBA), or estimated ambient background noise levels (60 to 65 dBA) 

and, therefore, will not be noticeable. Further, noise from construction equipment would be 

localized, short term, and intermittent during operation of equipment.

Control measures that could be used to minimize noise emissions from construction activities 

include routine maintenance of equipment (e.g., lubrication of moving parts, 

replacement/adjustment of worn or loose parts), industry best practices (e.g., minimizing 

equipment idle time and simultaneous use of equipment), shielding high noise sources, and 

conducting activities during daytime when noise levels are greatest.

Given the minor (1 dBA) increase in noise levels as a result of additional vehicle traffic and 

estimated noise levels from construction equipment not exceeding existing ambient noise levels, 

the NRC staff concludes that offsite noise impacts from construction would be SMALL.

4.2.2.2 Operations

Noise sources during operation would be primarily from workforce and shipment vehicles. 

Noise from operating equipment would be contained inside buildings and is not anticipated to be 

audible outside the proposed NWMI building at the site. Increased traffic volumes because of a 

daily workforce of 98 and 10 deliveries per week can increase noise emissions along nearby 

road and highways. NWMI modeled highway noise to estimate noise levels when an additional 

100 vehicles are added to peak traffic volume along U.S. Highway 63 (NWMI 2015c, 2016a, 

2016d). An additional 100 vehicles will increase noise by 1 dBA at 85 m (280 ft) distance from 

U.S. Highway 63 and at the nearest residence. Most people are unable to discern noise level 

differences less than 3 dBA. Further, increase in noise levels from vehicles will not be 

continuous, but rather intermittent during work shifts.

Given that noise levels from operating equipment are not expected to be audible beyond the 

building facility and additional noise levels from worker and shipment vehicles are minor 

(increase of 1 dBA), the NRC staff concludes that offsite noise impacts during operation would 

be SMALL.

4.2.2.3 Decommissioning

Noise emissions during decommissioning would be similar to those generated during 

construction. Increased noise levels would occur from increased traffic volumes and from the 
Environmental Impacts of Construction, Operations, and Decommissioning

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use of equipment on site. A daily peak workforce of 81 and a total of 21 deliveries and 

shipments a week are anticipated during decommissioning. NWMI modeled highway noise to 

estimate noise levels when an additional 100 vehicles are added to peak traffic volume along 

U.S. Highway 63 (NWMI 2015c, 2016a, 2016c, 2016d). An additional 100 vehicles will increase 

noise by 1 dBA at 85 m (280 ft) distance from U.S. Highway 63 and at the nearest residence. 

Most people are unable to discern noise level differences less than 3 dBA. Further, increase in 

noise levels from vehicles will not be continuous but rather intermittent during work shifts.

Equipment used during decommissioning activities would be similar to those presented in Table 

4–2. Therefore, as discussed above, noise levels from demolition equipment and vehicles to 

noise sensitive receptors are not anticipated to exceed existing noise levels from traffic on 

U.S. Highway 63 (69 dBA), agricultural equipment (84 dBA), or estimated ambient background 

noise levels (60-65 dBA) near the Discovery Ridge site and, therefore, will not be noticeable.

Given the minor (1 dBA) increase in noise levels as a result of additional vehicles and given that 

estimated noise levels from decommissioning activities would be bounded by existing ambient 

noise levels, the NRC staff concludes that offsite noise impacts from decommissioning would be 

SMALL.

4.3 Geologic Environment

4.3.1 Construction

Construction of the proposed NWMI facility at the Discovery Ridge site will temporarily disturb 

the entire site (7.4 ac (3.0 ha)), as detailed in Section 4.1.1.1. Ground-disturbing activity, 

including site clearing, grading, grubbing, surface compaction, excavation work, and 

construction-related vehicle traffic, would expose site soils and sediments to wind and water 

erosion. Site development and associated ground disturbance exceeding 1 ac (0.4 ha) in size 

requires a Land Disturbance Permit from the City of Columbia in accordance with Chapter 12A, 

Article II (Land Preservation) of the City’s Code of Ordinances (City of Columbia 2015). This 

permit is required before any site work can begin, and this authorization is in addition to any 

other required approvals, such as permits from the Missouri Department of Natural Resources

(MDNR). The NWMI Environmental Report (ER) (NWMI 2015a) lists relevant constructionrelated permit requirements, which the NRC has summarized in Appendix B of this EIS.

Further, the City of Columbia requires that the project proponent submit a detailed site 

development plan for City approval. This development application package must include a soil

erosion and sediment control plan and a stormwater management plan (City of Columbia 2015, 

2016d). These plans entail the implementation of construction-related BMPs for soil erosion 

and sediment control and stormwater pollution prevention during site development, facility 

construction, and for post development. For example, BMPs include use of gravel aprons to 

stabilize construction site entrances; sediment traps, sediment fencing, check dams and staked 

hay bales to manage runoff and erosion; use of fugitive dust controls, mulching and geotextile 

matting, stockpile covers, and rapid reseeding of disturbed areas to limit soil loss; and the 

retention of native vegetation and drainage ways, where practicable. These measures would 

serve to minimize soil erosion and loss and help ensure that soil impacts are limited to the 

immediate construction site, while also ensuring that the impacts are temporary in nature. 

NWMI states that dust production and erosional impacts due to site clearing and grading would 

be mitigated by using construction and erosion control BMPs (NWMI 2015a). Section 4.4.1 

presents additional information on relevant stormwater discharge and management 

requirements.
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NWMI would be required to obtain the appropriate permits from the County and City, if not 

already obtained by the developer for the Discovery Ridge Research Park (NWMI 2015a).

Following site grading, trenching and excavation, work for utility routings and emplacement of 

foundation structures (i.e., footings and floor slabs) for the NWMI facility would be conducted. 

Earthwork associated with utility infrastructure should be minimal. Discovery Ridge Research 

Park already has the necessary utility infrastructure (i.e., electric power, natural gas, water, and 

sanitary sewer) required to support the proposed NWMI facility on Lot 15. The utility providers 

will extend service lines to the NWMI facility site from utility connections presently located at the 

southwest corner of the site (MU 2009; NWMI 2015a). Utility routings and other foundation 

slabs and footings typically require excavation to a depth of about 5 ft (1.5 m). Excavation work 

would also be involved for a stormwater detention basin (NWMI 2015a).

Mineral and other geologic resources would be required to support facility construction such as 

granular stone (e.g., typically crushed aggregate (sand and gravel)), as summarized in

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

) 

(3,360 cubic meters (m3

)) of concrete would also be used for facility construction, in addition to 

precast concrete, and would be obtained from offsite commercial vendors 

(NWMI 2015a, 2015c). Consequently, no onsite concrete batch plant would be required. The 

mineral products that comprise concrete (i.e., Portland cement, sand, gravel, and other 

additives) are widely available in the region or are not otherwise limited in commercial 

availability.

With regard to excavation for facility structures, portions of the RPF building would be located at 

a floor elevation of 15 ft (4.6 m) below finished grade, based on preliminary facility designs. 

This below-grade portion would house the process hot cells and waste storage areas 

(i.e., high-integrity container vault) (see Section 2.3.1). The design calls for the subflooring to 

consist of a reinforced concrete mat slab 18 to 24 in. (46 to 61 cm) thick. The maximum depth 

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

) of earthwork material will be 

generated by site construction and excavation activities (see Section 2.2) 

(NWMI 2015a, 2015c). NWMI indicated its desire to limit overexcavation and to reuse 

excavated soils for backfill (NWMI 2015a, 2015c). However, soils at the Discovery Ridge site 

present a number of construction challenges and limitations for workability and stability that in 

turn can affect excavation work and needed material.

The geotechnical study (Terracon 2011a) found that site soils classify as lean to fat clay and fat 

clay, as further described in Section 3.3.1. The soils are rated as poorly drained with low 

permeability. At the time they were evaluated by Terracon (2011a), site soils exhibited a high 

water content with the potential for perched groundwater conditions. Most significantly, the fat 

clays have a high shrink/swell potential. High shrink/swell soils are difficult to work and 

undesirable for backfill. Consequently, these conditions may require additional overexcavation 

and removal of site soils in excavations and foundation cuts so that they can be replaced with 

suitable engineered backfill to properly support and safeguard concrete structures. Terracon 

(2011a) identified the need for the use of engineered backfill to provide a low-volume change 

layer for proper support of concrete surfaces. Therefore, additional excavation may be required 

and some or a substantial proportion of the excavated material may need to be replaced with 

engineered backfill.

As discussed in Sections 3.3.1 and 3.3.2, the depth to bedrock beneath the Discovery Ridge 

site has not been determined with accuracy, and the relative proximity of karst terrane presents 

an additional concern. Available information indicates that the depth to weathered bedrock 
Environmental Impacts of Construction, Operations, and Decommissioning

4-13

ranges between 13 and 25 ft (4 to 7.6 m) below ground surface (bgs), with the true depth likely 

to be on the higher end of the cited range. Depending on the final depth of excavation and 

depth to bedrock, excavation may require techniques such as drilling, ripping, or blasting. The 

integrity of the bedrock surface requires assessment with respect to the possible presence of 

karst features.

In addition, the potential for wet soils at relatively shallow depths and the possibility of a shallow 

water table (see Section 3.3.2) or perched groundwater could require the use of bracing, even in 

shallow trenches, and other measures (e.g., cofferdams) during construction of the below-grade 

portion of the facility that ultimately impacts the final facility design and, therefore, excavation 

work.

NWMI will conduct site-specific geotechnical and hydrological studies of the Discovery Ridge 

site to characterize site conditions in support of final facility design (NWMI 2015c, 2016e). 

These studies would include drilling a suite of boreholes to a maximum depth of 50 ft (12 m) 

bgs, or up to 20 ft (6.1 m) into competent bedrock. Soil and rock profiles would be 

characterized for each boring and engineering, geotechnical, and hydrologic properties would 

be determined. Depth to groundwater and groundwater quality would also be characterized 

during these studies (NWMI 2015c, 2016a).

Construction activities would require the consumption of geologic resources and would have the 

potential to increase soil erosion, but the necessary geologic resources are widely available 

within the region and erosion would be managed with the implementation of BMPs as required 

by permit requirements. Site conditions such as depth to bedrock, high shrink/swell soils, and 

wet, low permeability soils would increase the potential for construction impacts and the 

possible need for construction mitigation. However, completion of detailed site-specific 

geotechnical studies would serve to reduce the cited uncertainties with respect to site geologic 

and soil conditions. As a result, the NRC staff concludes that the impacts on the geologic 

environment from the construction of the proposed NWMI facility would be SMALL.

4.3.2 Operations

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.

NWMI would conduct all facility process activities within enclosed buildings, and vehicle traffic

would be confined to paved surfaces (e.g., roads and parking areas) that service the facility. As 

a result, incremental impacts on geology and soils would be negligible during operations.

The NRC staff does not expect site geologic conditions to affect the operation of the NWMI 

facility. The proposed site is located in a region with a relatively low seismic hazard compared 

with adjoining regions, as described in Section 3.3.3. Final facility design and construction 

would comply with applicable building codes and standards, which provide for the evaluation of 

site geologic and soil conditions, including potential seismic hazards. Completion of 

site-specific geotechnical and hydrological studies, as discussed in Section 4.3.1, would inform 

final design and construction considerations. Therefore, the NRC staff concludes that the 

operational impacts associated with the geologic environment at the proposed site would be 

SMALL.
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4.3.3 Decommissioning

Compacted site soils and underlying sediments would be disturbed by facility demolition and 

decontamination work. The impacts on site geology and soils would be similar in scope to those 

described for construction. Site clearing to restore the proposed site to a reusable condition 

would be subject to applicable permits and approvals (e.g., demolition or clearance permit), and 

the applicable provisions, including Chapter 6, Article II (Building Code) of the City of 

Columbia’s Code of Ordinances (NWMI 2015a; City of Columbia 2015).

Before beginning to dismantle onsite structures, decommissioning contractors would remove 

waste materials and contaminated media from the structures. Materials would be packaged and 

properly disposed of as discussed in Section 4.9. Thus, these materials would not pose a 

contamination threat to site soils or water resources. Soils and other media would be sampled 

to determine the presence of any contamination and associated waste management 

requirements. NWMI would be required to conduct all decommissioning activities in accordance 

with a decommissioning plan submitted to the NRC for approval and applicable regulations, as 

described in Section 2.9.

The NRC staff concludes that impacts on the geologic environment from facility 

decommissioning would be SMALL.

4.4 Water Resources

4.4.1 Surface Water

4.4.1.1 Construction

Surface water resources would not be directly impacted by site construction activities. No 

natural surface water features occur on the Discovery Ridge site. As discussed in 

Section 3.4.1.1, the natural hydrologic regime of the site and immediate vicinity has been 

altered by previous development activities that include pond and stormwater management 

facility construction. The closest natural watercourse is Gans Creek, which is located 

approximately 0.35 mi (0.56 km) south of the site at its closest point.

During construction, however, stormwater runoff from construction areas could potentially affect 

downstream surface water quality if not properly managed. As detailed in Section 4.3.1, NWMI 

would be required to obtain a Land Disturbance Permit from the City of Columbia and submit 

related plans for City approval before any ground-disturbing activities or facility construction 

could begin on the site. The City would require that appropriate soil erosion and sediment 

control BMPs be used to minimize soil erosion and the stormwater transport of suspended 

sediment and other pollutants. These measures must also address construction site pollutants 

that could affect offsite surface water quality.

Construction stormwater runoff is also subject to regulation in accordance with Section 402 of

the Federal Water Pollution Control Act (i.e., Clean Water Act (CWA) of 1972, as amended 

(33 U.S.C. 1251 et seq. )), and the Missouri Clean Water Law. CWA Section 402 establishes 

the National Pollutant Discharge Elimination System (NPDES) (see Section 3.4.1.2). 

Specifically, the State of Missouri has developed an NPDES general permit (i.e., Missouri State 

Operating Permit MO-RA) that must be obtained by owners and operators for the discharge of 

stormwater and certain non-stormwater discharges (e.g., dewatering) from land-disturbance 

sites that disturb 1 ac (0.4 ha) or more, or less than 1 ac (0.4 ha) but are part of a larger 

development. Missouri’s current General Permit MO-RA for construction or land disturbance 

has an effective date of February 2017, and is valid until February 2022 (states typically 

reauthorize general permits every 5 years). Facilities that discharge stormwater to a combined 
Environmental Impacts of Construction, Operations, and Decommissioning

4-15

storm sewer are exempt from stormwater permit requirements (MDNR 2012, 2017). This State 

general permit requires permit holders to develop and implement a stormwater pollution 

prevention plan (SWPP), the purpose of which is in part to ensure the proper design, 

implementation, management, and maintenance of BMPs to prevent the introduction of 

sediment and other pollutants in stormwater discharges (MDNR 2012).

NWMI indicates that it would obtain coverage under a Missouri General Operating Permit, if 

applicable for the site, or would comply with criteria and standards of the Discovery Ridge 

Master Storm Water Management Plan (NWMI 2015a). A separate County approval, a 

Stormwater Discharge Permit, may also be required for the discharge of any stormwater into a 

municipal storm sewer system or other publicly owned storm sewer system. The approval 

ensures that the receiving system has adequate capacity for any increases in peak flow rates 

and volumes (Boone County 2010, 2016b).

Finally, a stormwater management plan must also be prepared and approved by the City of 

Columbia in accordance with Chapter 12A, Article V (Stormwater Management) of the City’s 

Code of Ordinances. As indicated in Section 4.3.1, the City must approve the plan before a 

Land Disturbance Permit can be issued. The stormwater management plan must in part 

address BMPs used to control the peak flow rates of stormwater discharge associated with 

specified design storms and to reduce the generation of stormwater runoff.

No surface water or onsite groundwater would be withdrawn to support facility construction. 

Section 4.4.2 presents the NRC’s analysis of groundwater use impacts.

There would also be no sanitary wastewater discharges during construction. In accordance with 

common construction practices and as stated by NWMI (2015c), portable restroom facilities, 

serviced by a commercial vendor, would be used during site construction. Section 4.9 

describes waste management impacts in detail.

The proposed site is not located in an area susceptible to flooding or in a delineated floodplain, 

as discussed in Section 3.4.1. The NRC staff does not expect that site construction activities 

would have any direct impact on the floodplain of Gans Creek, which is located approximately 

0.35 mi (0.56 km) south of the NWMI facility site at is closest point.

Under CWA Section 401, an applicant for a Federal license or permit to conduct any activities, 

including facility construction or operation, that may cause a discharge into navigable waters is 

required to provide the Federal licensing agency with a certification from the state or agency 

having jurisdiction in which the discharge would originate (see Section 3.4.1.2). This water 

quality certification signifies that discharges from the project or facility to be licensed by the 

Federal agency will comply with CWA requirements and will not cause or contribute to a 

violation of state water quality standards. A Federal agency cannot issue a license or permit to 

an applicant until the required certification is provided, or the responsible state or agency has 

waived the requirement. The NRC recognizes that some NPDES-delegated states explicitly 

integrate their 401 certification process with NPDES permit issuance. The State of Missouri 

regulations for administering its water quality certification process are at 10 CSR 20-6.060.

The only regulated direct discharges from the proposed facility involve stormwater associated 

with construction activity. As previously described, NWMI would obtain coverage under a 

State-issued NPDES general permit (i.e., Missouri State Operating Permit MO-RA) for such 

discharges. Permit provisions are intended to ensure that the State’s water quality standards 

are met. NWMI has stated that no State certification is required under CWA Section 401

(NWMI 2015a). NWMI also has stated that it would seek a waiver from the State 

(NWMI 2015c). However, because the NRC cannot issue a construction permit without the 

required certification, NWMI must provide the NRC with either a 401 certification from the State 
Environmental Impacts of Construction, Operations, and Decommissioning

4-16

of Missouri, a waiver, or other State documentation that a Section 401 certification is not 

necessary.

No natural surface water features occur on the proposed site, and previous activities have 

altered the natural hydrology of the site. NWMI must prepare site-specific plans and implement 

BMPs in accordance with local and MDNR requirements to mitigate the potential impacts on 

surface water quality associated with construction activities. NWMI would not divert or withdraw 

surface water to support facility construction. Based on these considerations, the NRC staff 

concludes that the impacts on surface water hydrology, quality, and use from the construction of 

the proposed NWMI facility would be SMALL.

4.4.1.2 Operations

During operations, there would be no direct impact on surface water features and no direct 

discharge of industrial wastewater to surface water bodies. The NRC staff anticipates that there 

would be no measurable impacts on surface water quality. Stormwater would be collected and 

discharged from the NWMI facility property to lined, engineered stormwater basins. NWMI 

would use BMPs to manage stormwater runoff from paved and compacted surfaces to drainage 

ditches and basins (NWMI 2015a).

The University of Missouri (MU) will require that stormwater discharges from the NWMI facility 

site comply with the master stormwater management plan developed for the Discovery Ridge 

Research Park (MU 2009; NWMI 2015a). This would include compliance with applicable 

provisions of City ordinances. More precisely, the site-specific stormwater management plan 

(see Section 4.4.1.1) required by the City of Columbia must address BMPs used to control the 

peak flow rates of stormwater discharge associated with specified design storms and to reduce 

the generation of stormwater runoff. As a required element of the plan, NWMI will have to 

maintain a written operation and maintenance manual for the facility’s permanent stormwater 

management facilities to ensure that the permanent stormwater facilities, once constructed, 

continue to function as designed.

Additionally, as referenced in Section 4.4.1.1, a separate Stormwater Discharge Permit may 

also be required from Boone County for the discharge of facility stormwater runoff into a 

municipal storm sewer system. However, NWMI may be able to address this requirement as 

part of the discharge approval process under the Discovery Ridge Research Park master 

stormwater management plan.

NWMI states that it would obtain an NPDES general permit for stormwater discharges

associated with industrial activity (NWMI 2015a, 2015c) (see Appendix B). Under Section 402 

of the CWA and MDNR’s regulations for implementing the NPDES permit program for 

stormwater (10 CSR 20-6.200), certain industrial activities require a permit from the MDNR for 

their stormwater discharges. If applicable, MDNR may either issue NWMI a general permit for 

the appropriate industrial category or will require that the facility be covered under an NPDES 

individual permit (MDNR 2014b). Nonetheless, NWMI does not appear to fall into any of the 

industrial classifications requiring permit coverage. It also appears that the nature of NWMI’s 

proposed activities would meet the “no exposure” exemption criteria as no industrial materials, 

products, or wastes will be exposed to stormwater runoff from the NWMI facility. Stormwater 

runoff from the facility site would normally only consist of runoff from landscaped grounds, 

parking lots, roads, and roof drainage. NWMI may still be required to file a “no exposure 

certification” form with MDNR (MDNR 2014b).

The RPF building of the NWMI facility is designed to have zero liquid discharge from the RCA. 

There would be no liquid radioactive effluents released from the facility (NWMI 2015a, 2015c). 
Environmental Impacts of Construction, Operations, and Decommissioning

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Sections 2.7, 2.8, and 4.9 of this EIS separately discuss the treatment and handling of waste 

from the RCA.

Facility discharges would be limited to sanitary effluent. This sanitary wastewater would be 

conveyed to the City of Columbia Sanitary Sewer Utility. NWMI would also obtain a sanitary 

sewer connection approval from the City of Columbia (NWMI 2015a, 2015c). As previously 

described in Section 3.4.1.2, wastewater discharges to a municipal sanitary sewer system do 

not require an NPDES permit, although the discharge would need to comply with the system’s 

influent acceptance and treatment criteria. Influent requirements are prescribed in the City’s 

Code of Ordinances (Chapter 22, Article VI, Sewers and Sewage Disposal) and specifically 

address unlawful discharges, influent limits, and applicable pretreatment requirements 

(NWMI 2015a; City of Columbia 2015). Wastewater would also need to meet the NRC’s release 

criteria under 10 CFR 20.2003.

Wastewater from the NWMI facility would be discharged to the City of Columbia sanitary sewer 

system at an average rate of approximately 4,570 gallons per day (gpd) (17,300 liters per day 

(Lpd)) (NWMI 2015a, 2015c). This is equivalent to approximately 0.0046 million gallons per day 

(mgd/day) (17.4 cubic meters per day (m3

/day)). The Columbia Regional Wastewater 

Treatment Plant (WWTP) would be ultimately the point of treatment because this facility serves 

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/day) (City of Columbia 2016c). 

NWMI’s additional wastewater volume would constitute a very small percentage 

(i.e., 0.12 percent) of the available treatment capacity of the WWTP; therefore, the proposed 

discharge would be unlikely to have any impact on the WWTP.

Finally, 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. NWMI would 

maintain an emergency response plan and operating procedures to address chemical hazards, 

including spill response and mitigation (NWMI 2015a). A sizable volume of diesel fuel would 

also be stored on site. Current plans call for a 1,000-gal (3,780-L) above-ground storage tank 

for use in supplying the RPF backup generator (NWMI 2015a). This storage volume falls below 

the threshold requiring the preparation of a Spill Prevention, Control, and Countermeasure 

(SPCC) Plan under CWA Section 311 and implementing regulations. SPCC plans must be 

prepared by covered facilities to prevent, prepare, and respond to oil discharges potentially 

affecting navigable waters of the United States (40 CFR Part 112). NWMI will evaluate the 

need to prepare an SPCC plan to support facility operations and/or construction before initiating 

site work (NWMI 2015a).

In summary, no hazardous or radiological liquid effluent discharge would occur from the facility. 

NWMI would convey sanitary wastewater to a municipal wastewater treatment plant that has 

adequate treatment capacity. Stormwater discharges from the NWMI facility would be of a 

nonindustrial nature and would be managed by engineered facilities and in accordance with 

local and State regulations. NWMI will maintain appropriate plans and procedures to address 

any inadvertent spills of chemical or petroleum products. Based on these considerations, the 

NRC staff concludes that the impacts on surface water hydrology, quality, and use from NWMI 

facility operations would be SMALL.

4.4.1.3 Decommissioning

No natural surface water features occur on the proposed site, and there would be no direct 

impacts on surface water resources as a consequence of facility decommissioning activities. 

No surface water would be used during decommissioning.
Environmental Impacts of Construction, Operations, and Decommissioning

4-18

As previously referenced in Section 4.3.3, decommissioning contractors would conduct work in 

accordance with a decommissioning plan submitted to the NRC for approval and in accordance 

with permits and approvals from the City of Columbia. During decommissioning, NWMI would 

be responsible for removing waste materials and contaminated media from the facility and 

packaging them for proper disposal. As necessary, contractors would sample soils and other 

media to determine the presence of any contamination and associated waste management 

requirements. Further, appropriate waste handling and stormwater pollution prevention 

practices and spill prevention and response procedures would be observed during 

decommissioning to ensure that no materials or contaminants are released to soils or exposed 

to stormwater.

The NRC staff expects that ground-disturbing activities associated with decommissioning would 

require coverage under a State-issued NPDES general permit for the discharge of stormwater

from land-disturbance sites, as described in Section 4.4.1.1 for construction. BMPs, including 

the use of structural controls, such as sediment fencing and sediment basins, and the use of 

mulching, geotextile matting, and rapid reseeding of disturbed areas, would be used to prevent 

soil erosion and loss and any potential offsite water quality impacts.

As no natural surface water features would be impacted during decommissioning, there would 

be no diversion or withdrawal of surface water, and all work would be accomplished in 

accordance with a decommissioning plan, procedures, and permits to protect surface water 

quality, the NRC staff concludes that the impacts on surface water resources from facility 

decommissioning would be SMALL.

4.4.2 Groundwater

4.4.2.1 Construction

Excavation depths could range from 17 to 23 ft below grade (5.2 to 7 m) for portions of the RPF, 

as described in Section 4.3.1. During the preliminary geotechnical investigation of the 

Discovery Ridge Research Park in 2011, the geotechnical contractor encountered groundwater 

in two soil borings at depths of approximately 12 to 18.5 ft (3.7 and 5.6 m) bgs (see 

Section 3.4.2.1). Therefore, groundwater dewatering may be required during construction. 

NWMI will conduct site-specific geotechnical and hydrologic studies of the Discovery Ridge site 

(NWMI 2015c, 2016e). These studies would help to determine whether a seasonally high water 

table or perched groundwater exists beneath the site, as well as guide any necessary 

construction accommodations and final facility design.

NWMI estimated the maximum potential dewatering rate for site excavations (NWMI 2016a). 

NWMI used very conservative parameters for runoff area and precipitation yielding a maximum 

dewatering rate of 1,400 gal (5,300 L) per hour. Dewatering at this rate would be necessary 

only in the deepest excavation and only during a heavy precipitation event. During dewatering, 

contractors would pump the groundwater to a detention/retention pond (NWMI 2016a). The 

State-issued NPDES general permit for the discharge of stormwater from land-disturbance sites 

(see Section 4.4.1.1) allows for the discharge of uncontaminated groundwater if the discharge is 

properly controlled and addressed under the project-site SWPP (MDNR 2012). The NRC staff 

expects that dewatering could have minor effects on the vertical and horizontal extent of shallow 

groundwater, if present, and on groundwater flow direction, but any effects would be localized 

and temporary.

Site groundwater conditions could potentially affect facility construction and final design. These 

include the potential for wet subsurface conditions, including a seasonally high water table or 

perched groundwater beneath the site. To address these potential issues, site-specific 

geotechnical and hydrologic studies are planned that will characterize site conditions in support 
Environmental Impacts of Construction, Operations, and Decommissioning

4-19

of final facility design. These studies would ensure that the completed facility incorporates any 

necessary design features such as foundations protected with water barrier systems 

(e.g., sealants) and foundation drainage and water diversion systems (NWMI 2016a, 2016e).

NWMI does not plan to install any groundwater wells, and there would be no use of onsite 

groundwater to support construction activities. Consolidated Public Water Supply District No. 1 

would supply water required to support site construction activities (NWMI 2015a, 2015c). As 

noted in Section 4.3.1, water lines and other utilities are already in place at the southwest corner 

of the Discovery Ridge site. During the course of construction and before the establishment of 

permanent utility connections with the NWMI facility, the NRC staff expects that construction 

contractors would truck water to the point of use on the site, or water would be conveyed 

through a temporary water tap.

Water would be required during construction for such uses as dust control and soil compaction. 

For example, NWMI has proposed twice-daily watering of the construction site as a fugitive dust

BMP (NWMI 2015a). Some potable water would also be required to meet the drinking and 

sanitary needs of the construction workforce during the construction period. As stated in 

Section 4.4.1.1, the construction contractor would provide portable restroom facilities for the 

construction workforce. This measure would reduce the quantity of water required for potable 

and sanitary uses. These facilities would be serviced off site by a commercial vendor, 

alleviating any potential surface water or groundwater quality concerns. While water would also 

be used to produce concrete, this water consumption would occur off site as NWMI proposes to 

use ready-mix concrete supplied by commercial vendors instead of operating an onsite concrete 

batch plant (NWMI 2015c).

As presented in Section 2.5 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

/day). 

Total projected water use for the 17-month construction period is approximately 2.1 million gal 

(7.9 million L).

Consolidated Public Water Supply District No. 1, which is the utility that serves the Discovery 

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

/day) and currently supplies 

approximately 1.45 mgd (5,490 m3

/day) to customers (NWMI 2015a). The projected average 

daily water needs for NWMI facility construction would be a very small percentage (less than 

1 percent) of the district’s total production and available supply capacity.

Dewatering may be necessary during construction but site-specific geotechnical and hydrologic 

studies will further characterize subsurface conditions, and dewatering activities would be 

conducted in accordance with regulatory requirements. NWMI would not use groundwater from 

onsite sources during construction, and the estimated water demand to support construction 

activities would be less than 1 percent of the public utility’s total production and available excess 

capacity. As a result, the NRC staff concludes that the impacts on groundwater hydrology, 

quality, and use from construction of the NWMI facility would be SMALL.

4.4.2.2 Operations

The NRC staff expects that there would be no measurable impacts on groundwater hydrology or 

groundwater quality associated with normal operations of the NWMI facility. As discussed in 

Section 4.4.2.1, due to the potential for a seasonally high water table or perched groundwater 

beneath the site, the below-grade portions of the facility may incorporate a foundation drainage 

collection and water diversion system. Any impacts on groundwater elevations and flow 

direction beneath the site associated with the operation of these features would likely be very 

localized.
Environmental Impacts of Construction, Operations, and Decommissioning

4-20

There would be no radioactive liquid effluents released from the facility because the RPF 

building is designed to have zero liquid discharge. NWMI would conduct all material, chemical, 

and waste handling activities within the confines of the NWMI facility, precluding any releases to 

the environment, including soils and groundwater. 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 (see Section 4.4.1.2).

As described in Section 4.4.1.1, the only liquid waste stream discharged from the facility would 

be sanitary wastewater. NWMI would discharge this wastewater to the City of Columbia

Sanitary Sewer Utility, where it would be treated in the Columbia Regional WWTP, which has 

excess treatment capacity available.

No onsite groundwater would be used during operations. A public water utility, Consolidated 

Public Water Supply District No. 1, provides water service to the Discovery Ridge Research 

Park. Water would be required to meet the potable and sanitary needs of the facility staff and to 

provide water for fire protection, wash water, and RPF process makeup needs. Section 2.5 and 

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

/day). Total annual water 

use would be approximately 1.3 million gal (4.9 million L). Based on the process water balance 

for the facility (NWMI 2015c), process losses are projected to average 475 gpd (1,798 Lpd), 

which reflects a consumptive use rate of approximately 9 percent. These in-facility losses 

represent water lost to the atmosphere as water vapor, incorporated into packaged waste 

products, or other miscellaneous losses. Even so, the projected average daily water use of the 

NWMI facility is a negligible percentage of the production capacity of the water district and 

represents a very small increase (about 0.3 percent) in the volume of water the district supplies 

to its customers.

As facility operations would have no offsite impact on groundwater hydrology, there would be no 

discharge of wastewater to groundwater, and water to support facility operations would be a 

very small percentage of the production capacity and current demand of the public water supply 

district, the NRC staff concludes that the impacts on groundwater hydrology, quality, and use 

from the operation of the NWMI facility would be SMALL.

4.4.2.3 Decommissioning

The potential decommissioning impacts on and associated mitigation measures for groundwater 

are similar to those described in Sections 4.3.3 and 4.4.1.3. In summary, contractors would 

perform demolition and site restoration activities in accordance with applicable local and State 

permits and approvals, including a State-issued NPDES general permit for the discharge of 

stormwater from land-disturbance sites, as described in Section 4.4.1.1 for construction. BMPs

would be used to prevent soil erosion and loss and any potential impacts to surface water and 

groundwater incidental to site decommissioning activities. Specifically, waste handling and 

pollution prevention practices and spill prevention and response procedures would be observed 

during decommissioning, so that no materials or contaminants would be released to soils or 

exposed to stormwater, where they could contaminate underlying groundwater.

NWMI would be required to conduct necessary surveys of the soils and subsurface to comply 

with the NRC’s radiological criteria for license termination in 10 CFR Part 20, Subpart E. The 

NRC staff also expects that NWMI would sample soils and other media as necessary in 

accordance with other required local and State permits and approvals to ensure that no

nonradiological contamination remains in excess of action levels.
Environmental Impacts of Construction, Operations, and Decommissioning

4-21

Water would be required to support decommissioning work, as summarized in Section 2.5 and 

Table 2–3. As for facility construction and operations, the NRC staff assumes that Consolidated 

Public Water Supply District No. 1 would supply water to support facility decommissioning. 

NWMI contractors would either truck water to the site or it could be supplied through a 

temporary water line as decommissioning activities progress. 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

/day). Total projected water use for the 24-month 

decommissioning period is approximately 0.96 million gal (3.6 million L). The volume of water 

required would be less than that required for facility construction, with negligible impacts on 

local or regional groundwater supply capacity. It is expected that portable restroom facilities, 

serviced by a commercial vendor, would be used during site decommissioning to meet the 

needs of decommissioning personnel. Thus, there would be no onsite discharge of sanitary 

waste streams. Therefore, based on the stated findings and assumptions, the NRC staff 

concludes that impacts on groundwater resources from decommissioning of the NWMI facility 

would be SMALL.

4.5 Ecological Resources

4.5.1 Construction

As described in Section 4.1, construction of the proposed NWMI facility would permanently 

convert 7.4 ac (3.0 ha) of agricultural land into an industrial area (Table 4–1) (NWMI 2015a, 

2015c). In addition, 0.26 ac (0.1 ha) of agricultural land would be temporarily converted from 

agricultural land to a construction staging area (NWMI 2015a, 2015c). Once construction 

activities are complete, 68 percent of the site will be covered by buildings, roads, or parking lots, 

and 32 percent of the site will be covered with grasses, shrubs, and/or ornamental flowers, 

including native species (NWMI 2015a, 2015c). Directly affected vegetation would be limited to 

common or non-native grasses, which are abundant within the region and provide relatively 

low-quality habitat for birds and wildlife in comparison to forests, grasslands, and wetland 

habitats. In addition to a loss of habitat, noise from construction activities could disturb birds 

and wildlife. In response to such disturbances and loss of habitat, birds and wildlife could move 

out of the immediate area and find adequate, similar habitat (e.g., agricultural fields) within the 

vicinity. Once construction activities are complete, birds and wildlife could return to the area.

Using regionally native species to revegetate disturbed areas should help reduce the risk of 

reintroduction of non-native plants to the watershed (MDC 2016e). 

During construction, bird collisions with construction equipment and the new facility could result 

in increased mortality caused by the presence of tall structures and artificial night lighting. 

NWMI may use tall cranes to build the facility, which, when built, would be at a height of 65 ft 

(20 m) for the high bay roof (NWMI 2015a). In addition, the facility stacks would be 75 ft (23 m) 

(NWMI 2015a). Migratory songbirds would be most likely to collide with artificially lighted 

structures or cranes because of their propensity to migrate at night, their low flight altitudes, and 

their tendency to be trapped and disoriented by artificial light (Ogden 1996; NRC 2013a). 

NWMI (2015a) stated that, during construction at night, BMPs, such as light source shielding

and appropriate directional lighting, would be used to mitigate impacts associated with artificial 

nighttime illumination. NRC (2013b) reviewed bird collisions with plant structures at nuclear 

power plants and determined that collision rates were negligible sources of bird mortality with 

plants that have cooling towers 100 ft (30 m) in height. The NWMI facility and construction 

equipment would be similar or smaller in size and height than an operating nuclear power plant; 

therefore, the impacts from bird collisions at the NWMI site would be bounded by the 
Environmental Impacts of Construction, Operations, and Decommissioning

4-22

conclusions the NRC staff reached in its review of bird collisions at operating nuclear power 

plants with cooling towers 100 ft (30 m) in height.

Construction of the NWMI facility is not expected to result in any direct impacts to aquatic 

resources, such as habitat loss, because no aquatic resources occur on site and no surface 

water or groundwater would be used for construction activities. As described in Section 3.4, 

water drains off the proposed site to the south and southwest toward the southwesterly flowing 

Gans Creek, located approximately 0.35 mi (0.56 km) south of the site at its closest point (see 

Figures 3–11 and 3–13). Converting land from open fields to impermeable surfaces, such as 

rooftops and paved roads, will increase runoff to Gans Creek. Runoff from the proposed site 

could affect offsite aquatic resources by damaging downstream aquatic habitat and functions 

(MDC 2016e). For example, runoff can increase turbidity or introduce various chemicals or 

other pollutants that decrease water quality. However, impacts to Gans Creek and other nearby 

waterbodies are expected to be minimal because of the distance to the waterbodies, 

appropriate soil erosion and sediment control BMPs would be employed to minimize the 

transport of suspended sediment and other pollutants, and NWMI would be required to develop 

a site-specific program to prevent pollution from stormwater runoff (see Sections 4.3 and 4.4).

An inadvertent release of pollutants could flow to nearby surface water or groundwater features, 

including Devil’s Icebox cave located within Rock Bridge Memorial State Park. However, no 

hazardous or radiological liquid effluent discharge would occur from the facility and NWMI would 

convey sanitary wastewater to a municipal wastewater treatment plant that has adequate 

treatment capacity. In addition, NWMI will maintain appropriate plans and procedures to 

address any inadvertent spills of chemical or petroleum products. 

Given that construction would not permanently or temporarily affect any high-quality habitats, 

such as grasslands, forests, or wetlands; permanently and temporarily affected habitats 

(agricultural fields) are abundant within the region; mortality from bird collisions is expected to 

be negligible; and no aquatic features or State-listed species occur on the Discovery Ridge site, 

the NRC staff concludes that impacts to ecological resources during construction would be 

SMALL.

4.5.2 Operations

During operations, impacts to ecological resources could result from bird collisions, herbicide 

applications for landscape maintenance activities, elevated noise levels, and increased turbidity 

or introduction of pollutants from site runoff. As described above, mortality from bird collisions is 

expected to be negligible, given that the tallest structure would be a stack no higher than 75 ft 

(23 m). Disturbance from daily activities, herbicide applications, or elevated noise levels are 

likely to have minimal impacts on wildlife and plant species, given that the species identified at 

the proposed site are generally tolerant of human disturbances because the land has been 

actively farmed for the past several decades. In response to any disturbances, birds and wildlife 

could move out of the immediate area and find adequate, similar habitat (agricultural fields) 

within the vicinity. In addition, NWMI would mitigate impacts from herbicide applications by 

implementing BMP requirements that would limit their use and contain the broad application 

throughout the site.

Operation of the NWMI facility is not expected to result in any direct impacts to aquatic 

resources, because no aquatic resources occur on site and wastewater would be conveyed to a 

municipal wastewater treatment plant (NWMI 2015a). Indirect impacts during operations could 

include runoff that may contain sediments, contaminants from road and parking surfaces, or 

herbicides. Increased runoff could affect offsite aquatic resources by damaging downstream 

aquatic habitat and functions (MDC 2016e). However, as described in Section 4.4, impacts to 
Environmental Impacts of Construction, Operations, and Decommissioning

4-23

aquatic resources are expected to be minimal because of the distance to the nearest waterbody 

and NWMI would be required to develop a site-specific program to prevent pollution from 

stormwater runoff. In addition, NWMI will maintain appropriate plans and procedures to address 

any inadvertent spills of chemical or petroleum products. 

Given that mortality from bird collisions is expected to be negligible, habitat disturbances during 

operations would be minimal, any disturbed wildlife could find similar habitat in the vicinity, and 

no aquatic features or State-listed species occur on the proposed site, the NRC staff concludes 

that impacts to ecological resources during operations would be SMALL.

4.5.3 Decommissioning

Decommissioning activities would have impacts that are similar to the impacts that would occur 

during construction of the proposed facility. For example, NWMI would use construction 

equipment to dismantle large buildings, which could result in disturbances to wildlife and birds 

and potential runoff to nearby waterbodies. In addition, some land on the proposed site could 

be used as staging areas for the equipment and to conduct certain dismantling activities. As 

described above, if noise or other activities disturb birds or wildlife, similar habitat is available in 

nearby offsite areas. Once activities are complete, birds and wildlife could return to the area. 

No surface water would be used during decommissioning and impacts from runoff would be 

minimal, based on the distance to the nearest waterbodies, and because BMPs would be 

required in NWMI’s stormwater permit. Therefore, the NRC staff concludes that impacts to 

ecological resources during decommissioning would be SMALL.

4.5.4 Federally Protected Species

Section 3.5 describes the special status species and habitats that have the potential to be 

affected by the proposed action. The discussion of species and habitats protected under the 

Endangered Species Act of 1973 (ESA) (16 U.S.C. 1531 et seq.) includes a description of the 

action area as defined by the ESA section 7 regulations at 50 CFR 402.02. The action area 

encompasses all areas that would be directly or indirectly affected by the proposed construction, 

operations, and decommissioning of the NWMI facility.

Appendix D contains information on the NRC staff’s ESA section 7 consultation with the 

U.S. Fish and Wildlife Service (FWS) for the proposed action. 

In Section 3.5, the NRC staff concludes that no Federally listed species are likely to occur in the 

action area. The NRC staff also concludes that no candidate species, proposed species, or 

designated critical habitat occur in the action area. Thus, the NRC staff concludes that the 

proposed action would have no effect on Federally listed species or habitats under FWS’s 

jurisdiction. The FWS (2013) is not required to provide its concurrence with “no effect” 

determinations by Federal agencies. Thus, the ESA does not require informal consultation or 

the initiation of formal consultation with the FWS for the proposed NWMI construction permit. 

Nonetheless, FWS (2013) states that an agency may request written concurrence from the 

Services for a “no effect” determination. Following this best practice, the NRC staff submitted a 

copy of the draft EIS to the FWS for its review in a letter dated November 1, 2016. In response, 

the U.S. Department of the Interior (DOI) Office of Environmental Policy and Compliance stated

that the DOI has no comments on the draft EIS. Accordingly, the NRC has fulfilled its 

obligations under ESA section 7 for the review of NWMI’s construction permit.

As discussed in Section 3.5, no species or habitats under NMFS’s jurisdiction occur within the 

action area. Thus, the NRC staff concludes that the proposed action would have no effect on 

Federally listed species or habitats under NMFS’s jurisdiction.
Environmental Impacts of Construction, Operations, and Decommissioning

4-24

As discussed in Section 3.5, NMFS has not designated essential fish habitat (EFH) pursuant to 

the Magnuson–Stevens Fishery Conservation and Management Act, as amended 

(16 U.S.C. 1801 et seq.) within affected water bodies in the vicinity of the proposed site. Thus, 

the NRC staff concludes that the proposed action would have no effect on EFH.

4.6 Historic and Cultural Resources

This section describes the potential impacts from constructing, operating, and decommissioning 

the proposed NWMI facility at Discovery Ridge Research Park on historic and cultural 

resources.

4.6.1 Historic and Cultural Resources

The National Historic Preservation Act (NHPA) of 1966, as amended 

(54 U.S.C. 300101 et seq.), requires Federal agencies to consider the effects of their 

undertakings on historic properties. Construction, operations, and decommissioning of the 

NWMI facility is an undertaking that could potentially affect historic properties. Historic 

properties are defined as resources eligible for listing in the National Register of Historic Places 

(NRHP). The criteria for eligibility are listed in 36 CFR 60.4 and include (1) association with 

significant events in history, (2) association with the lives of persons significant in the past, 

(3) embodiment of distinctive characteristics of type, period, or construction, and (4) sites or 

places that have yielded, or are likely to yield, important information regarding prehistory or 

history.

The historic preservation review process (Section 106 of the NHPA) is outlined in regulations 

issued by the Advisory Council on Historic Preservation (ACHP) in 36 CFR Part 800.

4.6.2 Proposed Action

In accordance with the provisions of the NHPA, the NRC is required to make a reasonable effort 

to identify historic properties included in, or eligible for, inclusion in the NRHP in the area of 

potential effect (APE). The APE for this proposed action is Lot 15 at Discovery Ridge Research 

Park and any other properties that may be affected by the construction, operations, and 

decommissioning of the proposed NWMI facility. The APE may extend beyond Lot 15 in those 

instances where construction, operations, and decommissioning activities may effect an historic 

property. This determination is made irrespective of land ownership or control. Cultural 

resource investigations and surveys conducted on Lot 15 are described in Section 3.6.2.

If historic properties are present within the APE, the NRC is required to contact the State 

Historic Preservation Officer (SHPO), assess the potential impact, and resolve any possible 

adverse effects of the undertaking on historic properties. In addition, the NRC is required to 

notify the SHPO if historic properties would not be affected by the undertaking or if no historic 

properties are present. The SHPO is part of the MDNR.

4.6.3 Consultation

In accordance with 36 CFR 800.8(c), on November 19, 2015, the NRC initiated consultations on 

the proposed action by writing to the ACHP and MDNR (NRC 2015f). In a response dated 

December 9, 2015, MDNR indicated that adequate documentation had been provided 

(as required by 36 CFR Section 800.11), and there will be “no historic properties affected” by 

the proposed NWMI facility (see Appendix D).
Environmental Impacts of Construction, Operations, and Decommissioning

4-25

The NRC staff also initiated consultation with the following Federally recognized tribes on 

November 20, 2015 (see Appendix D for a copy of these letters):

• Absentee-Shawnee Tribe of Indians of Oklahoma,

• Caddo Nation of Oklahoma,

• Cherokee Nation,

• Cheyenne and Arapaho Tribes,

• Chickasaw Nation,

• Choctaw Nation of Oklahoma,

• Citizen Potawatomi Nation,

• Delaware Nation,

• Eastern Shawnee Tribe of Oklahoma,

• Iowa Tribe of Kansas and Nebraska,

• Iowa Tribe of Oklahoma,

• Miami Tribe of Oklahoma,

• Muscogee (Creek) Nation,

• Omaha Tribe of Nebraska,

• Osage Nation,

• Otoe-Missouria Tribe of Indians,

• Pawnee Nation of Oklahoma,

• Peoria Tribe of Indians of Oklahoma,

• Ponca Tribe of Indians of Oklahoma,

• Ponca Tribe of Nebraska,

• Prairie Band Potawatomi Nation,

• Quapaw Tribe of Oklahoma,

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

• Sac and Fox Nation, Oklahoma,

• Sac and Fox Tribe of the Mississippi in Iowa,

• Shawnee Tribe,

• United Keetoowah Band of Cherokee Indians of Oklahoma,

• Winnebago Tribe of Nebraska,

• Wyandotte Nation,
Environmental Impacts of Construction, Operations, and Decommissioning

4-26

• Kaw Nation, Oklahoma, and

• Yankton Sioux Tribe of South Dakota.

In its letters, the NRC provided information about the proposed action, defined the APE, and 

indicated that the NRC intends to comply with Section 106 through the National Environmental 

Policy Act of 1969 (NEPA) (42 U.S.C. 4321 et seq.) process, pursuant to 36 CFR 800.8(c). The 

NRC invited participation in the identification and possible decisions concerning any historic 

properties and also invited participation in the scoping process.

In response, the NRC was contacted by several tribes, including the Miami Tribe of Oklahoma, 

Pawnee Nation of Oklahoma, Quapaw Tribe of Oklahoma, and United Keetoowah Band of 

Cherokee Indians of Oklahoma. The Miami Tribe of Oklahoma indicated that the Tribe is not 

currently aware of any existing documentation directly linking a specific Miami cultural or historic 

site to the project site at Discovery Ridge, and also indicated the project site is within the 

extended homelands of the Miami Tribe. The Pawnee Nation of Oklahoma indicated that the 

proposed project site at Discovery Ridge would have no potential to adversely affect known 

archaeological, historic, or sacred Pawnee sites. The Quapaw Tribe of Oklahoma and the 

United Keetoowah Band of Cherokee Indians of Oklahoma indicated that the project site is 

outside their area of historic interest and deferred consultation to Federally recognized tribes 

with more of a historic interest in the proposed site. The NRC was also contacted by two other 

tribes. One tribe requested consulting party status on the NWMI project; the other indicated that 

the project site is not in their area of historic interest and deferred consultation to other tribes.

Several tribes also contacted the NRC following publication of the draft EIS (DEIS). In a letter to 

the NRC (ADAMS No. ML17054D472), the Osage Nation indicated that NRC’s Section 106 

consultation requirements with respect to their tribe had been fulfilled, and that they do not 

anticipate the proposed project will adversely impact any cultural resources or human remains 

protected under the NHPA, NEPA, or other Federal or Tribal laws. The Caddo Nation of 

Oklahoma indicated that the proposed project would not would not impact sites of interest to 

their tribe. The Muscogee (Creek) Nation indicated that the project site is outside their area of 

historic interest and deferred consultation to other tribes. 

4.6.3.1 Construction

Construction would convert agricultural land and open space to industrial use. Since no historic 

properties (as defined by 36 CFR 800.4(d)(1)) 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 of the proposed NWMI facility at the 

Discovery Ridge site. Construction of the NWMI facility would also have little or no visual 

impact. The nearest NRHP site, the Maplewood House, is about 1 mi (1.6 km) away to the 

northwest, and its view is obstructed by trees and residential and commercial properties. Based 

on these factors, as well as tribal input and cultural resource assessment and consultations, 

construction of the NWMI facility would not impact any known historic and cultural resources at 

the Discovery Ridge site. 

4.6.3.2 Operations

Because no historic properties (as defined by 36 CFR 800.4(d)(1)) would be affected and no 

archaeological sites or evidence of cultural resources were identified during the Phase I survey, 

historic and cultural resources would not likely be impacted during NWMI facility operations at 

the Discovery Ridge site. The completed NWMI facility would also have little or no visual 

impact. The nearest NRHP site, the Maplewood House, is about 1 mi (1.6 km) away to the 

northwest, and its view is obstructed by trees and residential and commercial properties. Based 

on these factors, as well as tribal input and cultural resource assessment and consultations, 
Environmental Impacts of Construction, Operations, and Decommissioning

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operation of the NWMI facility would not impact any known historic and cultural resources at the 

Discovery Ridge site.

4.6.3.3 Decommissioning

Because no historic properties (as defined by 36 CFR 800.4(d)(1)) would be affected and no 

archaeological sites or evidence of cultural resources were identified during the Phase I survey, 

historic and cultural resources would not likely be impacted during the decommissioning of the 

NWMI facility. Decommissioning the NWMI facility would also have little or no visual impact. 

The nearest NRHP site, the Maplewood House, is about 1 mi (1.6 km) away to the northwest, 

and its view is obstructed by trees and residential and commercial properties. Based on these 

factors, as well as tribal input and cultural resource assessment and consultations, 

decommissioning the NWMI facility would not impact any known historic and cultural resources 

at the Discovery Ridge site.

4.7 Socioeconomic Impacts

This section describes the potential socioeconomic impacts from constructing, operating, and 

decommissioning the proposed NWMI facility at Discovery Ridge Research Park. The impact 

analysis considers potential changes in regional employment, housing availability, tax revenues, 

and public services. For the purposes of this analysis, the socioeconomic ROI is the City of 

Columbia and Boone County, Missouri.

4.7.1 Construction

4.7.1.1 Employment

Construction of the proposed NWMI facility would require an average of 38 workers over 

17 months or up to 82 workers during peak construction (NWMI 2015a). At peak, this number 

of workers represents less than a tenth of a percent of the civilian labor force in Boone County 

in 2014 (see Table 3–16). As a result, nearly all construction workers would likely reside within 

the ROI, or adjacent counties and communities, and commute to the work site. Even if 

construction were to generate additional employment in the ROI, two to three times the average 

number of construction workers would represent less than a quarter of a percent of the civilian 

labor force. This would have no noticeable effect on employment levels in the ROI. Given the 

small number of construction workers, employment impacts during construction would be 

SMALL.

4.7.1.2 Housing

Construction workers would likely commute from within the ROI to the proposed work site at 

Discovery Ridge. This would result in little, if any, increased demand for temporary housing. 

As discussed in Section 3.7.6, there is plenty of available rental housing in the City of Columbia

and Boone County. Given the small number of construction workers, housing impacts during 

construction would be SMALL.

4.7.1.3 Tax Revenue

Tax revenue generated during the construction of the proposed NWMI facility would include 

revenue from property taxes paid by NWMI, income and property taxes paid by construction 

workers residing in the ROI, and sales and use taxes received from the purchase and rental of 

equipment, material, and commercial services in the ROI. Increased tax revenue would benefit 

the City of Columbia, Boone County, and Columbia Public Schools.
Environmental Impacts of Construction, Operations, and Decommissioning

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Communities within the ROI could experience a short-term economic benefit from increased tax

revenue and income generated by construction expenditures. After construction, local 

communities could experience a return to preconstruction economic conditions. The increase in 

tax revenue may have a noticeable effect in the ROI. However, given the relative short-duration 

of construction (17 months) and the small number of workers, tax revenue impacts in the ROI 

during construction would be SMALL.

4.7.1.4 Public and Educational Services

Construction workers and their families living within the ROI would continue to use existing 

public and educational services. These services would be able to handle any changes in 

demand from the small number of construction workers. Therefore, impacts on public and 

educational services during construction would be SMALL.

4.7.1.5 Summary of Construction Impacts

Communities within the ROI would benefit from increased employment, tax revenue, and 

income generated during construction. However, the small number of construction workers, the 

availability of rental housing, and the short duration of construction (17 months) would generate 

little if any noticeable socioeconomic impact within the ROI. The creation of 38 to 82 (peak) 

construction jobs would help maintain employment levels in the ROI and increase property and 

sales tax revenue in the ROI, but any changes would be minimal. Therefore, the overall 

socioeconomic impact from the construction of the proposed NWMI facility would be SMALL.

4.7.2 Operations

4.7.2.1 Employment

Approximately 98 jobs would be added to the local economy during NWMI facility operations 

(NWMI 2015a). This number of workers represents approximately one tenth of a percent of the 

civilian labor force in the City of Columbia and Boone County in 2014 (Table 3–16). Even if 

NWMI facility operations were to generate additional employment in the ROI, two to three times 

the number of operations workers would represent approximately one half of a percent of the 

civilian labor force. This would have no noticeable effect on employment levels in the ROI. 

Given the small number of operations workers, employment impacts during operations would be 

SMALL.

4.7.2.2 Housing

NWMI estimates that 98 workers would be needed during operation of the proposed NWMI 

facility (NWMI 2015a). Any operations workers relocating to the ROI would likely purchase 

permanent housing. As discussed in Section 3.7.6, there is plenty of available housing in the 

City of Columbia and Boone County. Given the small number of operations workers, housing 

impacts during operations would be SMALL.

4.7.2.3 Tax Revenue

Tax revenue generated during NWMI facility operations would include revenue from property 

taxes paid by NWMI, income and property taxes paid by workers residing in the ROI, and sales 

and use taxes received from the purchase and rental of equipment, material, and commercial 

services in the ROI. Estimated NWMI total annual tax payments (approximately $2.5 million) 

would comprise less than 1 percent of the City of Columbia’s 2015 fiscal year total revenues 

(approximately $325 million) (City of Columbia 2016e). Regardless, this increased tax revenue 

would benefit the City of Columbia, Boone County, and Columbia Public Schools.
Environmental Impacts of Construction, Operations, and Decommissioning

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Communities within the ROI could experience a minor economic benefit from increased tax

revenue and income generated by any workers and their families relocating to the ROI. This 

increase in tax revenue may have a noticeable effect in the ROI. However, given the small 

number of workers, overall tax revenue impacts in the ROI during operations would be SMALL.

4.7.2.4 Public and Educational Services

Operations workers and their families living in the ROI would continue to use existing public and 

educational services. These services would be able to handle any changes in demand from the 

small number of operations workers. Therefore, impacts on public and educational services 

during operations would be SMALL.

4.7.2.5 Summary of Operations Impacts

Communities within the ROI would benefit from increased employment, tax revenue, and 

income generated during NWMI facility operations. However, the small number of operations 

workers and the availability of housing would generate little if any socioeconomic impact within 

the ROI. The creation of 98 jobs would help maintain employment levels and increase property, 

income, and sales tax revenue in the ROI, but any changes would be minimal. Therefore, the 

overall socioeconomic impact from the operation of the proposed NWMI facility would be 

SMALL.

4.7.3 Decommissioning

4.7.3.1 Employment

Decommissioning the proposed NWMI facility would require an average of 38 workers over 

18 to 24 months or up to 81 workers during peak decommissioning (NWMI 2015a). At peak, 

this number of workers represents less than a tenth of a percent of the civilian labor force in 

Boone County in 2014 (Table 3–16). In addition, some operations workers may be kept on to 

support decommissioning. As a result, nearly all workers would likely reside within the ROI, or 

adjacent counties and communities, and commute to the work site. Even if decommissioning 

were to generate additional employment in the ROI, two to three times the average number of 

decommissioning workers would represent less than a quarter of a percent of the civilian labor 

force. This would have no noticeable effect on employment levels in the ROI. Given the small 

number of decommissioning workers, employment impacts during decommissioning would be 

SMALL.

4.7.3.2 Housing

Decommissioning workers would likely commute from within the ROI to the proposed NWMI 

facility. As previously discussed, some operations workers may be kept on to support 

decommissioning, thereby reducing the need for new hires. This would result in little, if any, 

increased demand for temporary housing. As discussed in Section 3.7.6, there is plenty of 

available rental housing in the City of Columbia and Boone County. Given the small number of 

decommissioning workers, housing impacts during decommissioning would be SMALL.

4.7.3.3 Tax Revenue

NWMI would continue to pay property taxes during decommissioning. The assessed property 

taxes would be based on the property tax rates at the time. Revenue loss would directly affect 

the City of Columbia and Boone County and the communities and other local taxing districts 

closest to, and most reliant on, the revenue from NWMI. However, the loss in tax revenue 

should be small in comparison to the established tax base of the City of Columbia and Boone 

County. Therefore, tax revenue impacts during decommissioning would be SMALL.
Environmental Impacts of Construction, Operations, and Decommissioning

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4.7.3.4 Public and Educational Services

Decommissioning workers and their families living in the ROI would continue to use existing 

public and educational services. Any temporary increase in population during decommissioning 

would be small relative to the projected population of the City of Columbia and Boone County. 

Public and educational services in the City of Columbia and Boone County would be able to 

handle any changes in demand during decommissioning. Therefore, impacts on public and 

educational services during decommissioning would be SMALL.

4.7.3.5 Summary of Decommissioning Impacts

The small number of decommissioning workers, the availability of housing, and the short 

duration of decommissioning (18 to 24 months) would generate little if any socioeconomic 

impact within the ROI. The creation of 38 to 81 (peak) decommissioning jobs would help 

maintain employment levels in the ROI, but any changes would be minimal. NWMI would 

continue to pay property taxes during decommissioning. Therefore, the overall socioeconomic 

impact from decommissioning the proposed NWMI facility would be SMALL.

4.8 Human Health

This section provides the NRC’s assessment of the potential radiological and nonradiological 

effects from the proposed NWMI facility. Radioactive and nonradioactive materials would 

routinely be used at the proposed NWMI facility. The NRC regulations, other Federal 

regulations, State of Missouri regulations, and local regulations would control the use and 

discharge of these materials to protect facility workers and members of the public.

Radiological exposures from the proposed NWMI facility would include offsite doses to 

members of the public and onsite doses to facility workers. The NRC’s radiation safety and 

dose limit requirements, which are found in 10 CFR Part 20, are discussed in detail in 

Section 3.8.2. The NRC has the authority to enforce these requirements to help ensure an 

adequate level of protection for workers, members of the public, and the environment.

Nonradiological exposures from the proposed NWMI facility to workers and members of the 

public would be regulated by applicable Federal (e.g., Clean Air Act, Clean Water Act, and 

Resource Conservation and Recovery Act (RCRA) (42 U.S.C. 6901 et seq.)), State 

(e.g., Missouri Hazardous Waste Management Law, Missouri Air Conservation Law, and 

Missouri Clean Water Law), and local laws and regulations. Occupational hazards would also 

be regulated by the Occupational Safety and Health Administration’s (OSHA’s) regulations in 

Chapter 29 of the Code of Federal Regulations (NWMI 2015a).

4.8.1 Construction

4.8.1.1 Radiological

No radioactive material associated with the application will be present at the proposed site 

during the construction phase of the proposed NWMI facility (NWMI 2015a, 2015c). As a result, 

no radioactive waste associated with the NWMI processes will be produced during construction. 

Therefore, the NRC staff concludes that there will be no impacts from potential radiological 

exposures during construction and impacts would be SMALL.

4.8.1.2 Nonradiological

Members of the public would not have access to the construction site. As discussed in 

Section 4.2.1.1, the NRC expects air pollutants from worker vehicles and fossil-fueled 
Environmental Impacts of Construction, Operations, and Decommissioning

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equipment (e.g., excavation and earth-moving equipment and electric generators), but the 

impact to the public would be SMALL because the effects would not be noticeable.

Construction workers would encounter potential hazards typical of any industrial construction 

site. As discussed in Section 3.8.4, workplace hazards can be grouped into physical hazards 

(e.g., slips and trips; falls from height; and those related to transportation, temperature, 

humidity, and electricity); physical agents (e.g., noise and vibration); chemicals; and 

psychosocial issues (e.g., work-related stress). NWMI would employ normal construction safety 

practices contained in 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 (NWMI 2015a). However, construction accidents could occur. Over the 

period when construction activities would occur, the average number of workers at the site 

would be 38 with a peak of 82 (NWMI 2015a). The NRC staff used data from the U.S. Bureau 

of Labor Statistics (BLS) for nonfatal workplace injuries and illnesses to calculate the potential 

number of reportable cases at the proposed NWMI construction site based on the average 

number of workers. The U.S. Department of Labor (DOL) data for 2014 showed that private 

industry reported an incidence rate of 3.2 cases per 100 equivalent full-time workers 

(DOL 2014). Conservatively assuming the peak workforce of 82 workers during the 

construction period, the BLS rates would result in 2.6 recordable cases per year. With the use 

of normal construction safety practices at the proposed NWMI construction site, the NRC staff 

concludes that recordable cases during construction should be consistent with the DOL data.

During construction, NWMI would store nonradioactive chemical sources on site in liquid; 

gaseous; and solid forms, including fuels, oils, and solvents necessary for site preparation and 

construction. Chemicals, hazardous liquids, and gases may also be encountered during 

construction. Such chemicals may take the form of compressed gases, oxidizers, flammable 

liquids, and other gases. The impact of these chemicals would be mitigated by the use of 

access controls, proper personal protective equipment and other typical construction safety 

practices to ensure safe working conditions and reduced instances of accidents or exposure to 

hazardous materials. If a spill or accident occurs during construction, an emergency response 

plan would be used to reduce the impact to human health and the environment (NWMI 2015a).

Given that access to the site would be restricted, that NWMI would implement normal 

construction safety practices contained in OSHA regulations, and that hazardous chemicals 

stored or used at the construction site would be managed in accordance with applicable Federal 

and State regulations, the NRC staff concludes that nonradiological impacts to human health 

during construction would be SMALL.

4.8.2 Operations

4.8.2.1 Radiological

During operation, LEU targets will be fabricated at the proposed NWMI facility. These will be 

transported offsite, irradiated, transported back to the proposed facility, and processed to 

produce Mo-99. Byproducts of the processing of these targets include some recyclable material 

(take-back LEU) and radioactive waste, which will be managed accordingly. Gaseous effluents 

meeting approved regulatory criteria will be released to the environment. Liquid and solid 

radioactive wastes would be managed as discussed in Sections 2.7.1.2 and 4.9.1 of this EIS 

(NWMI 2015a).

Radioactive material would be located in the facility hot cell area, irradiated target receipt and 

unloading area, target fabrication area, and waste management areas. Radioactive liquid and 

gaseous effluents from activities at the proposed facility would be contained within the process 

waste management or offgas systems (NWMI 2015a).
Environmental Impacts of Construction, Operations, and Decommissioning

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NWMI plans to maintain radiation exposure to facility workers to within the occupational dose

limits in 10 CFR 20.1201. Radiation exposure to personnel within the proposed facility would be 

minimized to as low as is reasonably achievable (ALARA) using shielding, optimized process 

designs, radiological work planning, protective equipment and materials, access controls, and 

contamination control measures. All personnel whose duties require entry into restricted areas 

(areas that are access-controlled due to actual or possible elevated radiation levels) will wear 

individual dosimetry devices, such as thermoluminescent dosimeters, to monitor radiation dose 

from external sources. Selected personnel will also have radiation dose from internal sources 

(i.e., dose from inhaled or ingested radionuclides) monitored by bioassay. NWMI would 

administratively control individual occupational external radiation doses to 500 millirem (mrem) 

per year (10 percent of the 10 CFR 20.1201 limit). Additionally, NWMI would administratively 

control individual occupational total effect dose equivalent (combined dose from external and 

internal sources) to 2,000 mrem per year (40 percent of the 10 CFR 20.1201 limit) 

(NWMI 2015g).

At the site boundary, the combination of shielding within the facility and distance from the facility 

would ensure that the direct radiation dose to members of the public in this area would be 

negligible (NWMI 2015a).

As described in Section 2.7.1.1, radioactive gaseous effluents would be released into the 

environment from the facility stack. The ventilation system is designed to provide confinement 

of hazardous chemical fumes and airborne radiological materials. Each exhaust filter train will 

consist of prefilters, two stages of HEPA filters, carbon adsorbers, and isolation dampers. The 

radionuclides of interest in these gaseous effluents would be krypton-85, metastable xenon-131, 

and xenon-133. Smaller amounts of radioactive iodines, particulates, tritium, and other noble 

gases would also be released. As discussed in Section 2.7.1.1, the NRC staff expects that 

given the small quantities of radioactive iodines, particulates, and other noble gases released, 

the dose contribution from those radionuclides would be small relative to krypton-85, metastable 

xenon-131, and xenon-133. NWMI also determined that the dose from tritium would be 

negligible relative to the dose from other radionuclides released (NWMI 2016c). The exhaust 

stacks will be provided with continuous monitors for noble gases, particulates, and iodine. The 

stack monitoring system is designed to continuously monitor stack releases. 

NWMI estimates that the maximum dose to the public from normal operational stack releases 

would be 3.6 mrem per year (NWMI 2015a, 2016a). The estimated dose is well below the 

annual dose limit of 100 mrem in 10 CFR 20.1301, and is also within the requirements in 

10 CFR 20.1101(d) that impose a constraint of 10 mrem per year on individual dose to a 

member of the public from radioactive gaseous effluents.

The ER states that NWMI will 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. The radiological effluent monitoring program would include gaseous effluent 

monitoring (NWMI 2015a). The program would also include environmental monitoring that 

would comprise:

• waterborne exposure pathway monitoring (sampling and analysis of nearby surface 

water and groundwater);

• direct exposure pathway monitoring (use of thermoluminescent dosimeter monitoring 

stations both on site and at the fence line of the proposed facility); and,

• airborne exposure pathway monitoring (use of continuous air monitoring stations at 

the fence line) (NWMI 2015a, 2016a).
Environmental Impacts of Construction, Operations, and Decommissioning

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Additional environmental monitoring for the ingestion exposure pathway (i.e., sampling and 

analysis of milk for iodine-131 and other gamma-emitting radioisotopes) may also be performed, 

if it is determined to be necessary as a result of radioactive iodine and particulate activity being 

measured during airborne effluent monitoring or air sampling (NWMI 2015a).

As stated in Section 2.7.1.2, no liquid radioactive material would be released to the facility 

environs as a result of routine operations of the proposed NWMI facility. Most liquid radioactive 

waste produced at the proposed facility would be solidified and shipped off site for disposal; 

small quantities of specialty liquid wastes that are not solidified would also be shipped off site for 

disposal. Should any inadvertent liquid release to the environment occur, the waterborne 

exposure pathway monitoring performed as part of NWMI’s effluent monitoring program, along 

with additional ad hoc sampling that would be performed as necessary, would allow the 

inadvertent release to be detected and its environmental and public dose impacts quantified 

(NWMI 2016a).

As described in detail in Section 2.8, transportation of radioactive materials, both on public 

highways and by air, would occur in conjunction with operation of the proposed NWMI facility. 

Radioactive materials transported to and from the NWMI facility site would include fresh LEU, 

unirradiated and irradiated LEU targets, Mo-99 product solution, and take-back LEU. When 

transporting waste and other radioactive materials on public roads, NWMI or commercial 

carriers must comply with the applicable U.S. Department of Transportation (DOT) regulations 

in 49 CFR Parts 172, 173, 177, and 397, as well as the NRC packaging requirements for 

radioactive material in 10 CFR Part 71. For transport of Mo-99 product by air, the air carrier 

chosen by NWMI must also comply with additional DOT regulations in 49 CFR Part 175 

(NWMI 2015a).

Using the RADCAT/RADTRAN code, NWMI estimated that the total incident-free dose to the 

general public from all public highway radioactive material transportation associated with the 

proposed NWMI facility (including transportation of waste, which is discussed in Section 4.9.1) 

would be 47,300 person-mrem per year, and 0.393 mrem per year to the maximally exposed 

individual member of the public located along a highway transportation route. The total 

population dose is approximately 0.6 percent of the approximately 7,740,000 person-mrem 

received annually within a 5-mi (8-km) radius of the proposed NWMI facility from background 

radiation (NWMI 2015a, 2016c). Additionally, the annual dose to a maximally exposed 

individual from highway transportation of radioactive material is small relative the NRC’s 

100 mrem annual public dose limit in 10 CFR 20.1301. For air transport of Mo-99 product, 

NWMI assumed that no commercial airliners carrying members of the public as passengers 

would be used, and it determined that the dose to members of the public on the ground would 

be negligible (NWMI 2015a, 2016c).

The NRC has previously evaluated the environmental impact of the transportation of radioactive 

materials on public roads and by air. The NRC concluded in 1977 that when radioactive 

material transportation is performed in compliance with all Federal regulations, the impact of 

such transportation is small (NRC 1977). The Commission determined that the environmental 

impacts, radiological and nonradiological, of normal (incident-free) transportation of radioactive 

materials and the risks and consequences of accidents involving radioactive material shipments 

in packages for which the NRC has issued design approvals meeting the performance 

standards of 10 CFR Part 71 were small (49 FR 9375). Regulations, shipping practices, and 

cask designs for transporting radioactive material have remained essentially unchanged since 

1977. Although more recent NRC assessments of the safety of radioactive materials 

transportation have focused on nuclear power reactor spent fuel, rather than the types of 

radioactive materials that would be transported in conjunction with the proposed NWMI facility, 

these assessments have shown, through the use of more advanced calculation methodologies, 
Environmental Impacts of Construction, Operations, and Decommissioning

4-34

that the impacts associated with transportation of nuclear power reactor spent fuel are smaller 

than originally thought in 1977 (NRC 2014a). Since transportation performed in conjunction with 

operation of the proposed NWMI facility would be performed in compliance with DOT and NRC 

regulations, the NRC staff concludes that the impacts from transportation of radioactive 

materials during operation would be SMALL.

As described above, NWMI would have facility design features and use procedures to minimize 

radiation exposure to occupational workers and members of the public. 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. In addition, NWMI plans to administratively control doses to occupational 

workers such that these doses would be well below the limits in 10 CFR 20.1201

(NWMI 2015g). The NRC staff is conducting an independent review of the potential dose to 

occupational workers and the public from operation of the proposed NWMI facility. This 

independent evaluation will be documented in the NRC staff’s safety evaluation report (SER). If 

the NRC staff determines in its SER that the maximum doses to workers and the public are 

within the dose limits in 10 CFR Part 20, the NRC staff concludes that the impacts from potential 

radiological exposures during operation would be SMALL.

4.8.2.2 Nonradiological

The proposed NWMI facility would be designed with engineering controls (e.g., shields, 

double-valves, ventilation system, glove boxes, fume hoods, safety switches, and safe-storage 

facilities) to minimize the exposure of workers to chemicals (NWMI 2015a).

NWMI would be expected to incorporate mechanisms for maintaining a safe working 

environment based on OSHA requirements, industry standards, and the experience of the 

managerial staff. General areas within the proposed facility and laboratory spaces would be 

expected to be kept clean and orderly. NWMI would store hazardous material (e.g., acids, 

bases, oxidizers, gases, and pyrophoric metals) in appropriate safety containers and cabinets 

(NWMI 2015a).

In addition to supervision and oversight of facility operations, NWMI would implement a training 

program that would emphasize workplace safety (NWMI 2015a). There would also be 

requirements for protective equipment commensurate with the hazards. These requirements 

would range from a description of appropriate clothing for workers (e.g., no shorts or open-toed 

shoes in the facility or the laboratory) to protective equipment (e.g., gloves, safety glasses, and 

laboratory coats). For more potentially hazardous operations, such as target solution 

preparation, which involves the handling of acids, workers would be required to use face 

shields, aprons, and heavy nitrile gloves. As discussed in Section 2.8.1.2, NWMI will develop a 

chemical management and product handling plan. The storage and treatment of wastes will be 

conducted in accordance with these plans. Additionally, the storage of chemicals and supplies 

on site will be performed in accordance with a chemical management and product handling plan 

to ensure that chemicals are properly stored (e.g., incompatible chemicals are stored in 

separate areas, flammable chemicals and oxidizers are stored in separate areas) 

(NWMI 2015a).

As discussed in Sections 2.7.2.1 and 4.2.1.2, nonradioactive pollutants may be present in 

wastewater and air emissions released into the environment during normal operations. Solid 

nonradioactive wastes would also be generated. After initial use, NWMI expects the majority of 

chemicals to be reused, discharged to the municipal sewer, or shipped off site as waste as 

discussed in Sections 2.7 and 2.8 (NWMI 2015a).

Given that NWMI would manage and minimize worker hazards by complying with OSHA and 

State of Missouri regulations and by using multiple planned features (e.g., facility design, 
Environmental Impacts of Construction, Operations, and Decommissioning

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supervision, training, and protective equipment), the NRC staff concludes that nonradiological 

impacts to workers and members of the public during routine facility operations would be 

SMALL.

4.8.3 Decommissioning

4.8.3.1 Radiological

Following cessation of proposed NWMI facility operations, residual radioactive contamination 

would remain in the hot cell and process areas of the facility. The potential radiological impacts 

from decommissioning would be associated with this contamination. During decommissioning 

operations, contaminated areas and equipment would be decontaminated; proper radiation 

protection procedures would be followed during these activities to keep exposure to 

occupational workers ALARA. Piping and vessels would be decontaminated, rinsed, and 

sampled to ensure that the removal of radioactive material has been achieved. If an area or 

piece of equipment could not be adequately decontaminated, a fixative would be applied to 

prevent the spread of the residual contamination. Materials with residual contamination would 

be disposed of as radioactive waste (see discussion of impacts related to radioactive waste 

disposal in Section 4.9.1) (NWMI 2015a).

With the cessation of proposed facility operations, radioactive gaseous effluents released into 

the environment from operations would effectively stop. However, during decommissioning 

activities, workers and members of the public would continue to be exposed to negligible or low 

levels of radioactive material within the facility and from radioactive gaseous effluents resulting 

from decommissioning activities involving the dismantlement and decontamination of equipment 

and systems and the handling and packaging of radioactive waste. The NRC’s radiation 

protection standards and dose limits for occupational workers and members of the public during 

decommissioning are the same as those for the operating facility.

Before initial operation of the proposed NWMI facility, NWMI would conduct a radiological 

survey of the proposed site to establish a baseline for decommissioning (NWMI 2015c). As 

discussed in Section 2.9, NWMI would be required to conduct decommissioning activities in 

accordance with applicable NRC requirements and any additional Federal, State, and local 

requirements. The NRC would terminate the license if the decommissioning were performed in 

accordance with the facility’s approved decommissioning plan, and if the termination radiation 

survey and associated documentation demonstrated that the facility and site were suitable for 

release in accordance with the criteria in 10 CFR Part 20, Subpart E. After decommissioning 

activities are completed in compliance with regulations, the proposed site could be released for 

unrestricted or restricted use, as determined by 10 CFR Part 20, Subpart E criteria.

Based on the expected reduced levels of radioactive material in the facility, and the radiological 

controls expected to be used to ensure doses to occupational workers and members of the 

public that are in compliance with radiation protection standards, the NRC staff concludes that 

the impacts from potential radiological exposures during decommissioning would be SMALL.

4.8.3.2 Nonradiological

Nonradiological health impacts on the public and workers from decommissioning and demolition 

activities would be similar to construction activities. Decommissioning and demolition activities 

would involve the use of heavy construction and demolition equipment and the transport of new 

and waste materials and personnel to and from the site. The public and workers could be 

exposed to dust and vehicle exhaust and noise. Workers could also experience occupational 

injuries. Nonradiological hazards would also be associated with emissions, discharges, and 

waste from processes within the facility and from accidental spills and releases. NWMI would 
Environmental Impacts of Construction, Operations, and Decommissioning

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manage nonradioactive wastes generated by decommissioning the NWMI facility, including solid 

wastes, liquid wastes, discharges, and air emissions, in accordance with applicable Federal, 

State, and local laws and regulations and with applicable permit requirements. As discussed in 

Section 4.2, the NRC staff determined that air pollutants from worker vehicles and fossil-fueled 

equipment (e.g., demolition, excavation, and earth-moving equipment and electric generators) 

would have a SMALL impact on air quality. In addition, NWMI’s access controls would help 

ensure that only authorized personnel would come on site. Given that NWMI would prohibit 

members of the public from accessing the site during decommissioning and that NWMI would 

manage nonradioactive wastes generated by decommissioning the NWMI facility in accordance 

with applicable Federal, State, and local laws and regulations and with applicable permit 

requirements, the NRC staff expects decommissioning activities to result in minimal human 

health impact to members of the public.

Decommissioning and demolition workers would encounter potential hazards typical of any 

industrial construction and demolition site. As discussed in Section 3.8, workplace hazards can 

be grouped into physical hazards (e.g., slips and trips; falls from height; and those related to 

transportation, temperature, humidity, and electricity); physical agents (e.g., noise and 

vibration); chemicals; and psychosocial issues (e.g., work-related stress). NWMI would 

implement normal construction safety practices contained in 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 decommissioning. However, decommissioning 

accidents could occur. Over the projected decommissioning phase, NWMI estimates a peak 

workforce of approximately 81 workers at the site. The NRC staff used data from the BLS for 

nonfatal workplace injuries and illnesses to calculate the potential number of reportable cases at 

the proposed NWMI decommissioning site based on the average number of workers. The DOL 

data for 2014 showed that private industry reported an incidence rate of 3.2 cases per 

100 equivalent full-time workers (DOL 2014). Conservatively assuming the peak workforce of 

81 workers during the decommissioning period, the BLS rates would result in 2.6 recordable 

cases a year. With the use of normal construction safety practices at the proposed NWMI 

decommissioning site, the NRC staff concludes that recordable cases during decommissioning

should be consistent with the DOL data.

During decommissioning, nonradioactive chemical sources would be managed in the same 

manner as during construction and operation.

Given that access to the site would be restricted, that NWMI would implement normal safety 

practices contained in OSHA regulations, and that chemicals stored or used at the site would be 

managed in the same manner as during construction and operation, the NRC staff concludes 

that nonradiological impacts to human health during decommissioning would be SMALL.

4.9 Waste Management

4.9.1 Radioactive Waste

This section describes potential impacts related to the production, processing, handling, and 

transportation of low-level radioactive wastes during operation and decommissioning of the 

proposed NWMI facility.

As discussed in Sections 2.7.1 and 2.8.1, radioactive waste would be produced during the 

operation and decommissioning phases of the proposed NWMI facility. Radioactive waste 

would include gaseous effluents, which would be released to the facility environs; low-level solid 

waste, including solidified liquid waste, which would be packaged and transported off site for 

disposal; and small quantities of liquid radioactive waste, which would also be transported off 
Environmental Impacts of Construction, Operations, and Decommissioning

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site for disposal. No high-level solid waste would be produced at the proposed facility. No 

liquid radioactive waste would be released into the facility environs. Most liquid radioactive 

wastes would be processed at the proposed NWMI facility to solidify the wastes prior to their

disposal. No radioactive wastes would be disposed of or permanently stored at the proposed 

facility site.

Gaseous effluents are discussed in Section 2.7.1.1, and the impact from the handling of these 

effluents and their release to the environment is discussed in Section 4.8.2.1. The production of 

solid and liquid low-level radioactive waste, a small portion of which could be mixed (both 

radiological and hazardous) waste, at the proposed NWMI facility, is discussed in 

Section 2.7.1.2. Upper-bound estimates of the quantities of waste that would be produced are 

provided in Section 2.7.1.2; when practical, methods including process liquid recycle and reuse 

would be used to reduce the amount of waste produced (NWMI 2015a, 2015c).

As described in Section 2.7.1.2, the solid radioactive waste produced at the proposed NWMI 

facility would include Class A, Class B, and Class C waste. NWMI expects that the small 

quantities of liquid waste that could be produced and shipped off site would be Class A waste 

(NWMI 2015g). No greater than Class C wastes will be generated by facility operations 

(NWMI 2015c).

NWMI plans to ship solid radioactive waste from the proposed facility to Waste Control 

Specialists (WCS) in Andrews, Texas (NWMI 2015a, 2017). The NRC staff expects that any 

small quantity of liquid radioactive waste that is produced and shipped offsite for disposal would 

similarly be shipped to WCS. WCS accepts mixed waste (i.e., waste that is both hazardous and 

radioactive), in addition to nonhazardous radioactive waste, and also accepts both liquid and 

solid waste (WCS 2016). In the event that NWMI loses access to a low-level waste disposal 

facility, the NRC staff expects that any low-level waste would have to be stored either within the 

facility or in a new storage facility that NWMI would construct either on site or at an offsite 

location. The storage of low-level waste would continue until a low-level waste facility is 

available. Radioactive material, regardless of its location, must be stored in accordance with 

Federal and state regulations to ensure the safety of workers and members of the public.

As described in Section 2.8.1.1, transportation of radioactive waste on public highways would 

also occur in conjunction with operation of the proposed NWMI facility. When transporting 

waste, NWMI or commercial carriers must comply with the applicable DOT regulations in 

49 CFR Parts 172, 173, 177, and 397, as well as the NRC packaging requirements for 

radioactive material in 10 CFR Part 71 (NWMI 2015a).

The environmental impact of transporting radioactive waste on public roads was included in the 

discussion of the impacts of transporting radioactive materials in Section 4.8.2.1. The NRC has 

previously evaluated the environmental impact of the transportation of radioactive waste on 

public roads. The NRC concluded that when radioactive waste transportation is performed in 

compliance with all Federal regulations, the impact of such transportation is small (NRC 1977). 

Therefore, since waste transportation performed in conjunction with the operation of the 

proposed NWMI facility would be performed in compliance with DOT and NRC regulations, the 

NRC staff concludes that the impacts from transportation of radioactive waste produced during 

operation and decommissioning of the proposed facility would be SMALL.

The proposed NWMI facility’s waste management systems, engineering design features, and 

contamination control and radiological safety procedures would help ensure that doses to facility 

personnel and members of the public from the production, processing, handling, and packaging 

of radioactive waste are reduced to levels that are ALARA. In addition, all activities at the 

proposed facility, including processing and handling of radioactive waste, would be conducted 

such that radiation doses to occupational workers and members of the public are maintained 
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below 10 CFR Part 20 limits, as discussed in Section 4.8.2.1. Radioactive waste at the 

proposed facility is expected to be managed in accordance with regulatory requirements. The 

NRC staff concludes that the impacts from production, processing, and handling of radioactive 

waste at the proposed NWMI facility during operations and decommissioning would be SMALL.

4.9.2 Nonradioactive Waste

As discussed in Section 2.7.2, NWMI would acquire, use, and store solid and liquid 

nonradioactive waste.

RCRA waste regulations govern the disposal of solid and hazardous waste. RCRA, Subtitle C, 

establishes a system for controlling hazardous waste, and RCRA, Subtitle D, encourages states 

to develop comprehensive plans to manage nonhazardous solid waste and mandates minimum 

technological standards for municipal solid waste landfills. EPA has delegated the primary 

responsibility for implementing RCRA regulations to the State of Missouri (EPA 2015c).

NWMI will implement waste management systems to control, handle, process, store, and 

transport nonradioactive waste generated during construction, operations, and 

decommissioning (NWMI 2015a). As described in Section 2.7.3, NWMI’s nonradioactive waste 

management program is based on a pollution prevention and waste minimization framework. 

The design of the NWMI facility would also incorporate features to minimize the release of 

chemicals or other nonradioactive materials into the environment (NWMI 2015a). Additionally, 

during operations, NWMI would contain chemicals within closed systems and use the chemicals 

in controlled processes (NWMI 2015a). The NRC staff expects that the waste management 

systems would ensure that the nonradioactive wastes generated at the proposed NWMI facility 

would be managed in accordance with applicable Federal and State of Missouri regulations.

As discussed in Section 2.7, the proposed NWMI facility would generate less than 1,000 kg 

(2,205 lb) of hazardous waste per month, making it a small quantity hazardous waste generator 

under EPA regulations. The proposed facility would also generate approximately 4,056 kg 

(8,942 lb) of nonradiological, nonhazardous waste (i.e., municipal waste) per year during 

operation (NWMI 2015c). NWMI expects that nonradiological hazardous wastes from 

construction or operation of the proposed facility would be collected by a hazardous waste 

disposal company such as Veolia or Clean Harbors for separation, processing, and disposal. 

Other solid waste (municipal waste or construction debris) generated by the construction or 

operation of the proposed facility would be picked up and disposed of at the City of Columbia

sanitary landfill (NWMI 2015c).

Nonhazardous waste would be temporarily stored on site before being transported to the local 

disposal or recycling facility (NWMI 2015a). Hazardous nonradioactive waste would be 

temporarily stored on site and then would be collected by the hazardous waste disposal 

company for separation, processing, and disposal. The NRC staff determined that adequate

storage capacity would exist within the facility to accommodate the waste generated and stored 

between shipments to offsite disposal facilities.

Based on NWMI’s proposed waste management systems, processes to minimize chemical

contamination, and because NWMI would operate within applicable Federal and State of 

Missouri regulations, the NRC staff concludes that impacts from nonradioactive waste would be 

SMALL during construction, operations, and decommissioning.

4.10 Transportation

This section describes potential non-radiological transportation impacts during the construction, 

operations, and decommissioning of the proposed NWMI facility at the Discovery Ridge site. 
Environmental Impacts of Construction, Operations, and Decommissioning

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The impact analysis considers changes in traffic volumes on the existing roadway network. The 

radiological impacts of transporting radioactive materials and waste are discussed in Section 4.8 

and 4.9.

4.10.1 Construction

Transportation impacts occurring during the construction of the proposed NWMI facility would 

be caused by an increase in commuter vehicles and construction trucks on local roads. 

Construction workers would arrive via site access roads as discussed in Section 3.9.1 and traffic

volumes on these roads would increase during shift changes. In addition, trucks would deliver 

construction equipment and material to the work site and remove construction waste material, 

thereby adding to traffic volumes on site access roads. The increase in vehicular traffic would 

peak during certain hours of the day (e.g., shift changes), resulting in temporary levels of 

service impacts and possible delays at intersections.

During construction, an average daily workforce of 38 workers would be commuting to and from 

the construction site at Discovery Ridge for approximately 17 months. During peak 

construction, up to 82 workers could be commuting daily to the construction site. In addition, an 

average of 20 trucks per week (4 trucks per day) would deliver construction equipment and 

material to the work site. An additional 1 truck per week would remove construction waste 

(NWMI2015a).

Because of the small size of the average daily workforce, the low number of daily truck 

deliveries and shipments, combined with the short duration of construction (approximately 

17 months), and easy access to U.S. Highway 63, there would be little if any noticeable traffic

volume-related level of service impacts. Therefore, transportation impacts would be SMALL.

4.10.2 Operations

Transportation impacts occurring during preoperations and operation of the proposed NWMI 

facility would be caused by an increase in commuter vehicles and delivery trucks on the local 

roadway network. Operations workers would arrive via site access roads as discussed in 

Section 3.9.1 and traffic volumes on these roads would increase during shift changes. In 

addition, trucks would deliver production material, ship products, and remove waste material, 

thereby adding to the traffic volumes on site access roads. The increase in vehicular traffic 

would peak during certain hours of the day (e.g., shift changes), resulting in temporary levels of 

service impacts and possible delays at intersections.

During operations (30 years), 98 workers would be commuting to and from the proposed NWMI 

facility at Discovery Ridge (NWMI 2015a). In addition, an average of 2 to 4 trucks per week 

would deliver nonradioactive material; an average of 2 to 3 trucks per week would deliver 

irradiated LEU targets; and another 2 trucks per year would deliver fresh LEU (NWMI 2015a).

In addition, outbound truck traffic would include the following:

an average of 1 truck shipment per week of LEU targets to irradiation facilities,

an average of 2 shipments per week of medical isotope product through the 

Columbia Regional Airport,

an average of 3 to 4 shipments per week of waste, and

an average of 2 truck shipments per year of take-back LEU (NWMI 2015c).

Medical isotope product shipments to customers would be transported from the NWMI facility by 

truck to the Columbia Regional Airport, approximately 7 mi (11 km) away. Radioactive and 
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nonradioactive waste would also be transported via common truck carrier from the NWMI facility 

to an offsite storage, treatment, or disposal facility.

The relatively small size of the workforce and low number of daily truck deliveries and 

shipments would generate little if any noticeable traffic volume-related level of service impacts. 

Therefore, given the size of the operations workforce, the number of trucks, and easy access to 

U.S. Highway 63, transportation impacts during NWMI facility operations would be SMALL.

4.10.3 Decommissioning

Transportation impacts occurring during the decommissioning of the proposed NWMI facility 

would be caused by an increase in commuter vehicles and trucks on the local roads. 

Decommissioning workers commuting to the work site would arrive via site access roads and 

traffic volumes on these roads could increase during shift changes. In addition, trucks would 

deliver equipment and material to the work site and remove waste material, thus adding to traffic 

volumes on site access roads. The increase in vehicular traffic would peak during certain hours 

of the day (e.g., shift changes) resulting in temporary levels of service impacts and possible 

delays at intersections.

During decommissioning, an average daily workforce of 38 workers would be commuting to and 

from the work site at Discovery Ridge for 18 to 24 months. During peak decommissioning 

activities, up to 81 workers could be commuting daily. In addition, an average of 1 truck per 

week would deliver equipment and material to the work site. An additional 20 trucks per week 

would remove construction waste (NWMI 2015a).

Because of the small size of the average daily workforce, the low number of daily truck 

deliveries and shipments, combined with the short duration of decommissioning (18 to 

24 months), and easy access to U.S. Highway 63, there would be little if any noticeable traffic

volume-related level of service impacts. Therefore, transportation impacts would be SMALL.

4.11 Accidents

This section discusses the environmental impacts associated with potential radiological and 

hazardous chemical accidents that might occur at the proposed NWMI facility. In addition to this 

EIS, the NRC staff will perform an independent verification of the potential accident scenarios 

and associated consequences at the proposed NWMI facility in its SER. The SER is part of the 

regulatory process that the NRC uses to decide whether to issue a construction permit and 

operating license for the proposed NWMI facility.

The term “accident,” as used in this section, refers to any off-normal event that may affect the 

health or safety of facility workers and/or members of the public due to the release of, or 

exposure to, radioactive material or hazardous chemicals. The accidents described in this 

section are associated with processes and activities that would occur at the proposed NWMI 

facility.

Potential initiating events and credible operational accidents for the proposed NWMI facility 

constitute the design-basis accidents (DBAs). For example, NWMI considered a fire at the 

proposed facility as a credible DBA scenario (NWMI 2015a). The proposed NWMI facility would 

be required to be designed and built to withstand any internal (e.g., caused by a component 

failure) or external (e.g., caused by a weather event) DBA without loss of systems needed to 

ensure safety. 

This EIS considers hypothetical accidents that would be considered to bound any DBA at the 

proposed NWMI facility, and uses the impacts from those hypothetical, bounding accidents as 
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the basis for determining the environmental impacts from potential accidents at the proposed 

facility. Although some types of accidents could involve both radiological and chemical hazards, 

for this EIS, the radiological and chemical hazards of potential accidents are considered 

separately. Radiological consequences of accidents at the proposed NWMI facility are 

discussed in Section 4.11.1, and chemical consequences of accidents are discussed in 

Section 4.11.2.

NWMI evaluated the consequences of accidents at the proposed facility, and the controls it 

would use to prevent or mitigate the consequences of accidents, against the performance 

requirements in 10 CFR 70.61. The NRC performance requirements for accidents in 

10 CFR 70.61 require that NWMI limit the risks of credible high-consequence and 

intermediate-consequence radiological and/or chemical events by applying engineered controls 

and/or administrative controls to reduce the likelihood and consequences of these events, and 

assure that all nuclear processes are subcritical under normal and credible abnormal conditions. 

To comply with 10 CFR 70.61, NWMI must have controls that:

• for any credible high-consequence radiological and/or chemical accident, either 

reduce the likelihood of the accident such that it would be highly unlikely, or reduce 

the consequences such that it would either be intermediate-consequence or 

low-consequence (i.e., less than intermediate-consequence);

• for any credible intermediate-consequence radiological and/or chemical accident, 

either reduce the likelihood of the accident such that it would be unlikely, or reduce 

the consequences such that it would be low-consequence (i.e., less than 

intermediate consequence); and,

• limit the risk of nuclear criticality accidents by assuring that under normal and 

credible abnormal conditions, all nuclear processes are subcritical.

Threshold consequence levels that define high- and intermediate-consequence radiological or 

chemical accidents for the purposes of evaluating compliance with 10 CFR 70.61 are provided 

in Sections 4.11.1 and 4.11.2.

4.11.1 Radiological Accidents

This section discusses the potential onsite and offsite radiological consequences of accidents at 

the proposed NWMI facility, and controls to prevent or mitigate the potential consequences. 

The results of the radiological accident analyses in this section are compared to the threshold 

consequence values in 10 CFR 70.61. The values are intended to be compared to the 

unmitigated consequences of credible accident scenarios. The threshold consequence values 

that define high- and intermediate-consequence radiological accidents for the purposes of 

evaluating compliance with 10 CFR 70.61 are provided in 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
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Receptor High Consequence Intermediate Consequence

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

For evaluation of the radiological consequences for members of the public from potential 

accidents at the proposed NWMI facility, NWMI considered a variety of potential nuclear 

criticality or radioactive material accidents, including:

• liquid spills or sprays with radiological and/or criticality safety consequences;

• target dissolver offgas accidents with radiological consequences;

• leaks into auxiliary services or systems with radiological and/or criticality safety 

consequences;

• loss of electrical power with radiological consequences; and

• natural phenomena (external events) with radiological consequences (NWMI 2015g, 

2015i).

Other events were either determined to be bounded by the events listed above; were 

determined, based on low likelihood and/or consequences, to pose an acceptably low level of 

risk; or they have not yet been fully evaluated by NWMI (NWMI will provide additional 

information for these events in the operating license application that it will submit for future NRC 

review) (NWMI 2015i).

The accidents listed above include one hypothetical radioactive material accident, based on 

events unique to the design of the proposed facility, that the NWMI ER states could result in 

radiological consequences for members of the public that would bound those of any credible 

radiological accident (NWMI 2015a). The NRC staff discusses this hypothetical accident in 

order to bound the worst-case radiological consequences for members of the public from 

potential accidents involving fission product releases at the proposed facility. NWMI identified 

this hypothetical, bounding accident as a fire-related gross failure of the target dissolution offgas 

treatment system. The target dissolution offgas treatment system is essentially a filtration 

system designed to collect the radioactive iodine and noble gases released during routine 

operation of the target dissolution systems. For the bounding radiological accident at the 

proposed NWMI facility, the failure of the target dissolution offgas treatment system would 

release all radioactive iodine and noble gas isotopes retained in that system out of the 75 ft 

(22.9 m) facility stack without mitigation. NWMI performed its analysis based on the assumption 

that 12 irradiated LEU targets per week, for 12 weeks immediately preceding the accident, had 

been processed upstream of the offgas treatment system. NWMI stated that its analysis of this 

accident is based on extremely conservative initial conditions and assumptions, including:

• maximum accumulation of radioactive iodine and noble gases in the offgas treatment 

system based on the assumed target processing history (i.e., all iodine and noble 

gases in the targets are released into the offgas system, and no iodine or noble 

gases are captured by other scrubbing systems or retained in the target dissolution 

system);
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• greater release of material from the offgas treatment system than would be expected 

to occur during an actual offgas treatment system fire; and

• no mitigation (e.g., from filtration or plate-out of iodine) of the release between the 

offgas treatment system and the facility stack (NWMI 2015a, 2015i, 2016a).

In addition, NWMI applied a safety margin of 1.32 to the source term inventory used for the 

analysis (NWMI 2016a) (i.e., the amount of radioactive material that could be released was 

multiplied by 1.32 to account for any uncertainty in the material quantity estimate). Because of 

these conservative initial conditions and assumptions, NWMI’s bounding radiological accident is 

a hypothetical radioactive material release with a maximized source term, and all material in the 

source term is released to the environment (no mitigation). All credible internally or externally 

initiated DBAs that could cause a radiological release from the proposed facility to the 

environment would be bounded by this accident.

NWMI calculated the potential doses to offsite members of the public for its bounding 

unmitigated radiological accident as follows:

• The total effective dose equivalent (TEDE) to a member of the public at the nearest 

fence line, 10 m (32.8 ft) from the facility stack, would be 360 mrem.

• The TEDE at the furthest fence line, 91 m (299 ft) from the facility stack, would be 

700 mrem.

• The TEDE at the nearest residence, 430 m (1,411 ft) from the facility stack, would be 

3,100 mrem.

• The TEDE at the point of maximum offsite dose would be 22,600 mrem, received 

1,100 m (3,609 ft) from the facility stack (NWMI 2016a).

The TEDE increases with increasing distance from the point of release because the release 

point is elevated above ground level (due to the 75 ft (22.9 m) stack), and most of the 

radioactive material will be blown some distance from the release point before it reaches ground 

level, where it could be inhaled by an individual. Beyond 1,100 m (3,609 ft) from the stack, 

however, the doses start to decrease, because beyond that point the radioactive material has 

become more diluted/dispersed in the air and the ground-level concentration is lower.

The NRC staff considered the consequences of the radiological accident that NWMI stated 

would be the bounding radiological accident for the proposed NWMI facility, without regard to 

the likelihood that this accident could actually occur. Based on the maximum offsite dose

calculated by NWMI of 22,600 mrem, and the 10 CFR 70.61 threshold consequence values 

listed in Table 4–6, if the bounding radiological accident for the proposed NWMI facility were to 

occur, it would be intermediate-consequence for members of the public. If, as NWMI stated, the 

consequences of this accident for members of the public bound those of any other credible 

radiological accident, then any other unmitigated, credible accident at the proposed NWMI 

facility would be either intermediate- or low-consequence for radiological consequences to 

members of the public.

NWMI also provided analyses of radiological consequences to facility staff (occupational 

workers) from possible accidents at the proposed NWMI facility. NWMI identified a credible 

type of radioactive material accident involving a spill of liquid Mo-99 product solution, and 

calculated that for this accident, the unshielded direct radiation dose rate to a worker located 

1 m (3.3 ft) from the spill would be 1,500,000 mrem per hour. This dose rate could lead to a 

high-consequence (>100,000 mrem) or intermediate-consequence (>25,000 mrem) dose to a 

worker in a short period of time (NWMI 2015i). NWMI also identified credible scenarios, 

including spills or leaks from process vessels that could result in accidents involving an 
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inadvertent nuclear criticality. Due to the intense levels of radiation that can be produced during 

a nuclear criticality accident, these types of accidents could have very significant dose 

consequences for facility staff, especially any staff located in the immediate vicinity of the 

accident. Therefore, NWMI qualitatively assumed that these accidents could be 

high-consequence for facility staff (NWMI 2015i). Given the types of accidents described by 

NWMI which could have radiological consequences for NWMI facility personnel, the NRC staff 

assumes that unmitigated, credible accidents at the proposed NWMI facility could be high-, 

intermediate-, or low-consequence for radiological consequences to facility staff.

NWMI has proposed in its preliminary safety analysis report to have various controls (including 

engineering design features and administrative controls) that would prevent the initiation of 

nuclear or radioactive material accidents, or mitigate their consequences (NWMI 2015i). These 

would include controls that would mitigate the consequences of radiological accidents, but 

which were not credited in the analyses above, such as:

• use of hot cells, confinement boundaries, and shielding in process areas;

• double-wall piping;

• sumps to capture and remove spilled liquids;

• radiation monitoring; 

• an emergency nitrogen purge system that will limit the likelihood of fires by 

preventing the buildup of flammable hydrogen gas in the process vessels; and,

• design of the facility ventilation system and dissolution offgas treatment system, 

including the use of filters to remove radioactive gases and particulates 

(NWMI 2015a, 2015i).

NWMI has also proposed to have additional preventative controls specific to nuclear criticality 

accidents, including:

• geometry of, and spacing between, process vessels; and

• geometry of liquid collection sumps (NWMI 2015i).

NWMI stated that, for any accident with high radiological consequences for workers, members 

of the public, and/or the environment (as determined by the criteria in 10 CFR 70.61), the 

controls proposed in its preliminary safety analysis report would either reduce the likelihood 

such that it would be highly unlikely or reduce the consequences such that it would be 

intermediate- or low-consequence. Additionally, NWMI stated that for any accident with 

intermediate radiological consequences for workers, members of the public, and/or the 

environment (as determined by the criteria in 10 CFR 70.61), the controls proposed in its 

preliminary safety analysis report would either reduce the likelihood such that it would be 

unlikely or reduce the consequences such that it would be low-consequence (NWMI 2016c, 

2016d). NWMI also stated that nuclear criticality controls proposed in its preliminary safety 

analysis report would be designed such that process systems would remain subcritical under 

normal and credible abnormal operating conditions (NWMI 2015i).

The NRC staff is conducting an independent review of the radiological consequences of 

accidents at the proposed NWMI facility, and of the controls proposed by NWMI. The NRC staff 

will document this review in its SER. The NRC staff will determine whether the controls will be 

designed, implemented, and maintained to ensure they are available and reliable to perform 

their preventative and mitigating functions when needed. The NRC staff will also determine 

whether the controls are sufficient to ensure that the likelihood and/or consequences of any 

credible radiological accidents at the proposed NWMI facility would be reduced such that the 
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proposed facility would be in compliance with the performance requirements in 10 CFR 70.61 

and any other applicable NRC regulations. 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, the NRC staff concludes that the impacts 

from potential nuclear or radioactive material accidents at the proposed facility would be 

SMALL.

4.11.2 Hazardous Chemical Accidents

This section discusses the potential onsite and offsite hazardous chemical exposure 

consequences of accidents at the proposed NWMI facility, and controls to prevent or mitigate 

the potential consequences. The results of the chemical accident analyses in this section are 

compared to the threshold consequences in 10 CFR 70.61, which are intended to be compared 

to the unmitigated consequences of credible accident scenarios. The general threshold 

consequences that define high- and intermediate-consequence hazardous chemical accidents 

for the purposes of evaluating compliance with 10 CFR 70.61 are provided in 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

The accidents that involve hazardous chemicals, and that could result in chemical exposure to 

workers or members of the public, include the following:

• chemical burns from contaminated solutions during sample analysis;

• nitric acid fume release; and

• release of other chemicals, such as hydrogen peroxide, ammonia, or carbon dioxide, 

that would be present at the proposed facility (NWMI 2015a, 2015i).

The chemical accidents evaluated by NWMI are hypothetical severe chemical accidents that 

NWMI considered to bound any other potential chemical accident at the proposed NWMI facility. 

The accidents involve unmitigated releases of chemicals that would be used in conjunction with 

the processing of licensed radioactive material at the proposed facility. NWMI’s analyses used 

the Areal Locations of Hazardous Atmospheres (ALOHA) computer code (NWMI 2015a). 

ALOHA is an atmospheric dispersion model that evaluates releases of hazardous chemical 

vapors. The use of this code for chemical accident analyses is consistent with methodologies 

described in the NRC’s Nuclear Fuel Cycle Facility Accident Analysis Handbook (NRC 1998).

In its analysis, NWMI evaluated the unmitigated release from tank breach or rupture of the 

following chemical materials:

• nitric acid (HNO3, 10.4 M aqueous solution),

• hydrogen peroxide (H2O2, 10.4 M aqueous solution),
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• ammonia (NH3, gas), and

• carbon dioxide (CO2, gas) (NWMI 2015a).

For liquid chemicals (aqueous solutions), the release scenario assumed a breach in a chemical

tank resulting in an unconfined spill and subsequent evaporation. For gases, the release 

scenario assumed a ruptured tank resulting in an immediate release to the atmosphere. The 

chemicals selected for analysis were chosen based on quantity used at the facility and 

availability in the ALOHA code’s library, which includes chemicals that could pose an airborne 

dispersion hazard. For the chemicals analyzed, the material at risk (MAR) was based on the 

estimated maximum inventory of each chemical at the proposed NWMI facility. These inventory 

values are considered to be conservative, bounding conditions. In addition, no credit was taken 

for depletion or plate-out of any chemicals, either within the proposed NWMI facility or during 

transport to receptor locations (NWMI 2015a).

For evaluating possible chemical release exposures to members of the public, NWMI assumed 

that the releases would occur at ground level. NWMI calculated airborne chemical 

concentrations at the location of a maximally exposed offsite individual (MOI) at a point along 

the boundary fence estimated to be 24 m (80 ft) from the release point (based on the general 

layout of the proposed facility and where chemicals would be located), and at the location of the 

nearest resident, 430 m (1,425 ft) from the release point. Concentrations were calculated based 

on 1-hour release/exposure scenarios. NWMI assumed average meteorological conditions for 

these calculations. The results, in units of parts per million (ppm), are listed in Table 4–8 

(NWMI 2015a).

To determine human health impacts associated with the accidental release of hazardous 

chemicals, estimated airborne chemical concentrations are compared against protective action 

criteria (PAC) limits. PAC limits are essential components of planning for the uncontrolled 

release of hazardous chemicals. These limits, combined with estimates of exposure, provide 

the information necessary to identify and evaluate accidents for the purpose of taking 

appropriate protective actions. During an emergency response to an uncontrolled chemical 

release, these limits may be used to evaluate the severity of the event, to identify potential 

outcomes, and to decide what protective actions should be taken. In anticipation of a possible 

uncontrolled release, these limits may also be used to estimate the consequences of the 

possible uncontrolled release and to plan emergency responses (DOE 2008).

U.S. Department of Energy (DOE) guidance states that PAC values equivalent to the 1-hour 

Acute Exposure Guideline Levels (AEGLs), which are developed by EPA and the National 

Academy of Sciences, should be used to assess the potential impacts associated with the 

accidental release of hazardous chemicals. Three levels of AEGL values (AEGL-1, AEGL-2, 

and AEGL-3) are used for each of five exposure periods (10 minutes, 30 minutes, 1 hour, 

4 hours, and 8 hours). The three levels of AEGL values are distinguished by varying degrees of 

severity of toxic effects based on exposure to the chemical concentration values associated with 

each AEGL level over the given exposure period. The three AEGL levels are defined as 

follows:

AEGL-1 is the airborne concentration of a substance above which it is predicted that 

the general population, including susceptible individuals, could experience notable 

discomfort, irritation, or certain asymptomatic nonsensory effects. However, the 

effects are not disabling and are transient and reversible on cessation of exposure.

AEGL-2 is the airborne concentration of a substance above which it is predicted that 

the general population, including susceptible individuals, could experience 
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irreversible or other serious, long-lasting adverse health effects or an impaired ability 

to escape.

AEGL-3 is the airborne concentration of a substance above which it is predicted that 

the general population, including susceptible individuals, could experience 

life-threatening health effects or death (DOE 2008).

In addition to the estimated chemical concentrations calculated by NWMI, Table 4–8 lists, for 

comparison, the PAC-1, PAC-2, and PAC-3 values (for nitric acid and ammonia, these are 

equivalent to 1-hour AEGL-1, AEGL-2, and AEGL-3 values, respectively) for each chemical 

evaluated by NWMI in its accident analysis. For hydrogen peroxide and carbon dioxide, AEGL 

values are not available. DOE guidance states that if AEGL values do not exist for a given 

chemical, Emergency Response Planning Guideline (ERPG) values, or in the absence of ERPG 

values, Temporary Emergency Exposure Limit (TEEL) values, should be used in place of AEGL 

values to determine PACs. ERPG and TEEL values are similar to AEGL values, but they are 

developed by the American Industrial Hygiene Association (AIHA), and by DOE, respectively. 

Additionally, ERPG values are always based on 1-hour exposures, and TEEL values are based 

on 15-min exposures, in contrast to the range of exposure times for which AEGL values are 

available (DOE 2008). The PACs in Table 4–8 for hydrogen peroxide are based on ERPGs for 

that chemical, and the PACs for carbon dioxide are based on TEELs.

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

Comparison of the concentrations to the corresponding PACs in Table 4–8 indicates that 

possible chemical accidents involving releases of nitric acid and/or ammonia would pose a 

much greater risk to human health than accidents involving hydrogen peroxide or carbon 

dioxide. For nitric acid and ammonia, the MOI could be exposed to concentrations that are 

significantly greater than PAC-3 values. At these concentrations, it is predicted that individuals 
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could experience life-threatening health effects or death. Additionally, the individuals at the 

nearest residence could be exposed to concentrations that are above PAC-1 values but below 

PAC-2 values, and these individuals could experience transient, non-disabling health effects 

including notable discomfort or irritation. However, since the effects on individuals at the 

nearest residence would be non-disabling, the effects would likely not impair the individuals’ 

ability to take protective action (i.e., seek shelter or evacuate to a location further away from the 

proposed NWMI facility).

NWMI additionally stated that another liquid-form chemical, sodium hydroxide (NaOH, 19 M 

aqueous solution), that would be used at the proposed facility would have an MAR of 1,900 L 

(502 gal). NWMI did not provide an analysis (calculation of estimated concentrations at the MOI 

and/or nearest residence) of a chemical accident involving a sodium hydroxide release, but 

NWMI stated that it assumed, based on the large MAR quantity and the low PACs for sodium 

hydroxide, that a sodium hydroxide release could cause PAC-2 limits to be exceeded at 

locations occupied by members of the public (NWMI 2015a).

The NRC staff considered the consequences of the chemical accidents that NWMI stated would 

be bounding chemical accidents for the proposed NWMI facility, without regard to the likelihood 

that these accidents could actually occur. Based on the analysis provided by NWMI and the 

threshold consequences listed in Table 4-7, if a bounding severe chemical accident for the 

proposed NWMI facility were to occur, it could be high-consequence for members of the public 

(for nitric acid, ammonia, or sodium hydroxide release). The NRC staff assumes that smaller, 

less severe releases of nitric acid, ammonia, or sodium hydroxide could be intermediate- or 

low-consequence for members of the public. NWMI’s analysis shows that bounding hydrogen 

peroxide or carbon dioxide release accidents would be low-consequence for members of the 

public. NWMI did not provide an analysis of possible chemical exposures to workers at the 

proposed NWMI facility, but stated that for a bounding chemical accident involving a nitric acid 

release, chemical exposures to workers would be much higher than the exposure to the MOI 

(NWMI 2015i). Therefore bounding severe chemical accidents at the proposed NWMI facility 

could also be high-consequence for the facility staff. Given the bounding analyses provided by 

NWMI, the NRC staff assumes that unmitigated, credible accidents at the proposed NWMI 

facility could be high-, intermediate-, or low-consequence for chemical exposure to members of 

the public or facility staff, depending on the type and quantity of chemicals involved.

NWMI has proposed in its preliminary safety analysis report to have various controls (including 

engineering design features and administrative controls) that would prevent the initiation of 

hazardous chemical accidents, or mitigate their consequences. These would include controls 

that would mitigate the consequences of chemical accidents, but which were not credited in the 

analyses above, such as:

• use of procedures for handling chemicals;

• design and construction of chemical preparation and storage areas; and

• use of confinement boundaries and barriers in process areas, to confine spills or

releases and protect workers from liquid sprays (NWMI 2015i).

NWMI stated that, for any chemical release accident with high consequences for workers or 

members of the public (as determined by the criteria in 10 CFR 70.61), the controls proposed in 

its preliminary safety analysis report would either reduce the likelihood such that it would be 

highly unlikely or reduce the consequences such that it would be intermediate- or 

low-consequence. Additionally, NWMI stated that for any chemical release accident with 

intermediate consequences for workers or members of the public (as determined by the criteria 

in 10 CFR 70.61), the controls proposed in its preliminary safety analysis report would either 
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reduce the likelihood such that it would be unlikely or reduce the consequences such that it 

would be low-consequence (NWMI 2016c, 2016d).

The NRC staff is conducting an independent review of the consequences of hazardous 

chemical accidents at the proposed NWMI facility, and of the controls proposed by NWMI. 

The NRC staff will document this review in its SER. The NRC staff will determine whether the 

controls will be designed, implemented, and maintained to ensure they are available and 

reliable to perform their preventative and mitigating functions when needed. The NRC staff will 

also determine whether the controls are sufficient to ensure that the likelihood and/or 

consequences of any credible hazardous accidents at the proposed NWMI facility would be 

reduced such that the proposed facility would be in compliance with the performance 

requirements in 10 CFR 70.61 and any other applicable NRC regulations. 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 hazardous chemical accident consequences, the NRC staff 

concludes that the impacts from potential hazardous chemical accidents at the proposed facility 

would be SMALL.

4.12 Environmental Justice

This section describes the potential human health and environmental effects from the 

construction, operations, and decommissioning of the proposed NWMI facility on minority and 

low-income populations living near the proposed Discovery Ridge site. The NRC strives to 

identify and consider environmental justice issues in agency licensing and regulatory actions 

primarily by fulfilling its NEPA responsibilities for these actions.

Under Executive Order (EO) 12898 (59 FR 7629), Federal agencies are responsible for 

identifying and addressing, as appropriate, potential disproportionately high and adverse human 

health and environmental impacts on minority and low-income populations. In 2004, the 

Commission issued a Policy Statement on the Treatment of Environmental Justice Matters in 

NRC Regulatory and Licensing Actions (69 FR 52040), which states that “[t]he Commission is 

committed to the general goals set forth in EO 12898, and strives to meet those goals as part of 

its NEPA review process.”

The CEQ provides the following definitions to consider when conducting environmental justice 

reviews within the framework of NEPA in Environmental Justice: Guidance under the National 

Environmental Policy Act (CEQ 1997):

Disproportionately High and Adverse Human Health Effects. Adverse health 

effects are measured in risks and rates that could result in latent cancer fatalities, as 

well as other fatal or nonfatal adverse impacts on human health. Adverse health 

effects may include bodily impairment, infirmity, illness, or death. Disproportionately 

high and adverse human health effects occur when the risk or rate of exposure to an 

environmental hazard for a minority or low-income population is significant 

(as employed by NEPA) and appreciably exceeds the risk or exposure rate for the 

general population or for another appropriate comparison group.

Disproportionately High and Adverse Environmental Effects. A disproportionately 

high environmental impact that is significant (as employed by NEPA) refers to an 

impact or risk of an impact on the natural or physical environment in a low-income or 

minority community that appreciably exceeds the environmental impact on the larger 

community. Such effects may include ecological, cultural, human health, economic, or 

social impacts. An adverse environmental impact is an impact that is determined to be 

both harmful and significant (as employed by NEPA). In assessing cultural and 
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aesthetic environmental impacts, impacts that uniquely affect geographically dislocated 

or dispersed minority or low-income populations or American Indian tribes are 

considered.

The environmental justice analysis assesses the potential for disproportionately high and 

adverse human health or environmental effects on minority populations and low-income 

populations that could result from the construction, operations, and decommissioning of the 

proposed NWMI facility. In assessing the impacts, the following definitions of minority 

individuals and populations and low-income population were used (CEQ 1997):

Minority individuals. Individuals who identify themselves as members of the following 

population groups: Hispanic, Latino or Spanish origin, American Indian or Alaskan

Native, Asian, Black or African American, Native Hawaiian or Other Pacific Islander, or 

two or more races—meaning individuals who identified themselves on a Census form 

as being a member of two or more races (e.g., Hispanic and Asian).

Minority populations. Minority populations are identified when the minority population

of an affected area exceeds 50 percent or the minority population percentage of the 

affected area is meaningfully greater than the minority population percentage in the 

general population or other appropriate unit of geographic analysis.

Low-income population. Low-income populations in an affected area are identified 

with the annual statistical poverty thresholds from the U.S. Census Bureau’s Current 

Population Reports, Series P-60, on Income and Poverty.

Methodology for Assessing Environmental Justice Impacts

The NRC addresses environmental justice issues and concerns by first identifying potentially 

affected minority and low-income populations and then determining whether there would be any 

potential human health or environmental effects and whether any of these effects would be 

disproportionately high and adverse. Adverse health effects are measured in terms of the risk 

and rate of fatal or nonfatal impacts on human health. Disproportionately high and adverse 

human health effects may occur when the risk or rate of exposure to an environmental hazard 

would be significant for a minority or low-income population and exceed the risk or rate of 

exposure for the general population or some other comparable population. Disproportionately 

high environmental effects refer to impacts or risks of impacts on the natural or physical 

environment in a minority or low-income community that are significant and that appreciably 

exceed the environmental impact on the larger community. Such effects may include biological, 

cultural, economic, or social impacts.

Consistent with the Commission’s Policy Statement (69 FR 52040), affected populations are 

defined as minority and low-income populations who reside within a 5-mi (8-km) radius of the 

proposed NWMI facility site. Data on minority and low-income populations are usually collected 

and analyzed at the Census tract or Census block group level.

The U.S. Census Bureau (USCB) compiles demographic information at the Census tract and 

block group levels in small geographic areas. A Census tract is a small area that is a statistical 

subdivision of a county or statistically equivalent entity. A block group is a statistical subdivision 

of a Census tract. A Census block is the smallest geographic entity for which the USCB collects 

and tabulates demographic data.

Minority population data are available for Census block groups within a 5-mi (8-km) radius of the 

proposed NWMI facility site. Low-income population data are only available at the Census tract 

level because of the limited availability of poverty and income data at the block group level. To 

protect confidentiality, USCB does not publish information about small geographic areas if the 
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population size is too small. Race and ethnicity and poverty and income data were used to 

determine the presence of minority and low-income populations. If the center point of the 

Census tract and block group is within the 5-mi (8-km) radius boundary, data from the entire 

Census tract or Census block group was used.

Minority Population

According to the 2010 Census, approximately 23 percent of the City of Columbia population

(which includes more than one Census tract and block group) identified themselves as minority. 

In Boone County, approximately 19 percent of the population identified themselves as minority. 

According to the U.S. Census Bureau’s 2014 American Community Survey 1-Year Estimates, 

since 2010 minority populations in the City of Columbia and Boone County were estimated to 

have increased by approximately 3,000 to 4,000 persons and now comprise 24 and 

20.2 percent of the respective populations (see Table 3–15). (UCSB 2016b).

Approximately 22 percent of the population identified themselves as minority individuals (Table 

4–9) within the 5-mi (8-km) radius of the proposed Discovery Ridge site (MCDC 2016a). The 

largest minority group was Black or African American at 10.3 percent, followed by Asian at 

5.4 percent (MCDC 2016a).

Census block groups were considered minority population block groups if the percentage of the 

minority population within any block group exceeded 22 percent. Eleven of the 30 Census block 

groups were found to have meaningfully greater minority populations. These block groups are 

concentrated northwest and west of the proposed NWMI facility site near the City of Columbia. 

The Discovery Ridge site is located in Census Tract 10.02, Block Group 3, with a minority 

population of 12.5 percent.

Minority Populations in Census Block Groups Within 5 mi (8 km)

of the 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
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Census Tract Block Group Total Population

Minority 

Population(a) Percent Minority

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

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)

Low-Income Population

According to 2010–2014 American Community Survey estimates, an average of 11.3 percent of 

families and 20.7 percent of all people residing in Boone County were identified as living below 

the Federal poverty threshold. In addition, the City of Columbia had an average of 13.2 percent 

of families and 24.9 percent of all people identified as living below the Federal poverty threshold

(level). The Federal poverty threshold for a family of four was $22,314 in 2010 and $24,230 in 

2014 (USCB 2016d).

Table 4–10 lists low-income population Census tracts within a 5-mi (8-km) radius of the 

Discovery Ridge site and the estimated average number of people living below the poverty 

level. According to the USCB’s American Community Survey 5-Year Estimates for 2010–2014, 

40.6 percent of the total population within that radius was identified as living below the Federal 

poverty level (MCDC 2016a).

Census tracts were considered low-income population Census tracts if the percentage of 

individuals living below the Federal poverty threshold exceeded 40.6 percent. Five of the nine 

Census tracts were found to have meaningfully greater low-income populations. These Census 

tracts are concentrated northwest and west of the proposed NWMI facility site. The existing

research park and proposed Discovery Ridge site are located in Census Tract 10.02 with an 

estimated 16.7 percent of its population living below the poverty level (USCB 2016d).
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Percentage of People and Families in Census Tracts Within 5 mi (8 km) of the 

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).

Impact Analysis

Chapter 4 presents an assessment of the environmental effects from constructing, operating, 

and decommissioning the proposed NWMI facility at Discovery Ridge for all affected resource 

areas. The NRC uses this information to determine if there would be any human health or 

environmental effects that could disproportionately affect minority and low-income populations 

and whether any of these effects would be high and adverse.

The following sections in Chapter 4 describe the potential human health and environmental 

effects from constructing, operating, and decommissioning the proposed NWMI facility that 

could impact minority and low-income populations:

• radiological human health impacts (Sections 4.8.1.1, 4.8.2.1, and 4.8.3.1);

• nonradiological human health impacts (Sections 4.8.1.2, 4.8.2.2, and 4.8.3.3);

• noise impacts (Section 4.2.2); and

• traffic impacts (Section 4.10).

The NRC also considered whether there would be any environmental impacts that would affect 

a specific minority and low-income population and whether there would be any unique effects 

that could appreciably exceed or are likely to appreciably exceed those for the general 

population.

Subsistence Consumption of Fish and Wildlife

The special pathway receptors analysis is an important part of the environmental justice 

analysis because consumption patterns may reflect the traditional or cultural practices of 

minority and low-income populations in the area, such as migrant workers or Native Americans.

Section 4–4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and 

appropriate, to collect and analyze information about the consumption patterns of populations 

that rely principally on fish and/or wildlife for subsistence and to communicate the risks of these 
Environmental Impacts of Construction, Operations, and Decommissioning

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consumption patterns to the public. In this EIS, the NRC considered whether there were any 

means for minority or low-income populations to be disproportionately affected by examining 

impacts on American Indians, Hispanics, migrant workers, and other traditional lifestyle special 

pathway receptors.

Based on the description of air and water quality impacts and the discussion of human health 

effects in this EIS, it is unlikely that there would be any disproportionately high and adverse 

human health impacts in special pathway receptor populations in the region as a result of 

subsistence consumption of water, local food, fish, and wildlife. Thus, constructing, operating, 

and decommissioning the proposed NWMI facility at the Discovery Ridge site would not have 

disproportionately high and adverse human health and environmental effects on these 

populations.

4.12.1 Construction

Potential impacts to minority and low-income populations from the construction of the proposed 

NWMI facility at the Discovery Ridge site would mostly consist of environmental effects 

(e.g., noise, dust, and traffic). Noise and dust impacts during construction would be short term 

and primarily limited to onsite activities (Section 4.2.2.1). Minority and low-income populations 

residing along site access roads could be affected by an increase in the number of commuter 

vehicle and truck traffic traveling to and from the proposed work site. However, these effects 

are not likely to be different than what was previously experienced during the construction of 

other research facilities at Discovery Ridge Research Park (e.g., Missouri University plant 

genetic research farm, IDEXX BioResearch). Given the short duration of construction, the small 

size of the average daily workforce, the small number of trucks, and the easy access to 

U.S. Highway 63, it is not likely that the construction of the proposed NWMI facility would have 

disproportionately high and adverse human health and environmental effects on minority and 

low-income populations living near Discovery Ridge.

4.12.2 Operations

Potential impacts to minority and low-income populations during NWMI facility operations would 

mostly consist of radiological and nonradiological human health and environmental (e.g., noise 

and traffic) effects. Everyone living near Discovery Ridge and the proposed NWMI facility could 

be affected by operations activities, including minority and low-income populations. Any human 

health and environmental effect would depend on the magnitude of the change from current 

environmental conditions. Minority and low-income populations residing along site access 

roads could be affected by the increased commuter vehicle and truck traffic during certain hours 

of the day.

As discussed in Section 4.8.2.1 of this EIS, the potential radiological dose to the public from 

NWMI facility operations would be well within NRC and applicable Federal, State, and local 

regulatory limits. As a result, everyone living near the proposed NWMI facility site, including 

minority and low-income populations, would not be adversely affected by radiation exposure 

during facility operations. Permitted nonradiological air emissions would also be required to 

remain within regulatory limits (Section 4.2.1.2).

As discussed in Section 4.2.2.2 of this EIS, noise levels may increase along U.S. Highway 63

because of increased commuter vehicle and truck traffic during NWMI facility operations. This 

may not be noticeable, however, given the relatively small size of the daily workforce and the 

limited number of truck deliveries and shipments. Based on this information, operation of the 

proposed NWMI facility would not likely have disproportionately high and adverse human health 

and environmental effects on minority and low-income populations living near Discovery Ridge.
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4.12.3 Decommissioning

Similar to construction, potential impacts to minority and low-income populations during the 

decommissioning of the proposed NWMI facility at the Discovery Ridge site would mostly 

consist of environmental and socioeconomic effects (e.g., noise, dust, and traffic). Noise and 

dust impacts during decommissioning would be short term and primarily limited to onsite 

activities (Section 4.2.2.3). Minority and low-income populations residing along site access 

roads could be affected by an increase in the number of commuter vehicle and truck traffic 

traveling to and from the proposed work site. However, because of the temporary nature of 

decommissioning, these effects are not likely to be high and adverse and would be intermittent, 

only occurring when trucks and vehicles pass by during certain hours of the day. Given the 

short duration, the small size of the average daily workforce, the small number of trucks, and the 

easy access to U.S. Highway 63, it is not likely that decommissioning the proposed NWMI 

facility would have disproportionately high and adverse human health and environmental effects 

on minority and low-income populations living near Discovery Ridge.

4.13 Research Reactors

As discussed in Section 2.3.1.3, once the LEU targets are fabricated at the proposed NWMI 

RPF, the LEU targets will be transported to research reactors for irradiation. Research reactors 

that irradiate NWMI’s LEU targets will need to submit an application for a separate license 

amendment to provide irradiation services to NWMI. The NRC must issue each reactor facility a

license amendment before NWMI’s LEU targets can be irradiated at each reactor. The NRC will 

conduct a separate safety and environmental review of each license amendment application 

submitted to the NRC. However, since irradiation of LEU targets is a connected action to the 

proposed action, the NRC will assess the environmental impact associated with irradiating LEU 

targets at the research reactors in this EIS.

On January 31, 2016, the NRC issued the Oregon State University TRIGA Research Reactor 

(OSTR) a license amendment that consisted of changes to the facility operating license and 

technical specifications (TS) that would allow the irradiation of up to three medical isotope 

production targets containing fissionable material in the OSTR to demonstrate the production of 

Mo-99 (NRC 2016d; OSU 2012). Oregon State University (OSU) has submitted to the NRC a 

letter stating OSU’s intent to submit a license amendment application in 2017 pertaining to the 

irradiation of LEU targets in the OSTR that would be fabricated by the proposed NWMI facility 

(OSU 2015b). In 2016, the University of Missouri Research Reactor (MURR) submitted a letter 

of intent to submit a license amendment pertaining to the irradiation of LEU targets (MU 2016e).

4.13.1 University of Missouri Research Reactor Site

4.13.1.1 Facility Modifications and Equipment Refurbishment

Facility modifications and equipment refurbishment at MURR are anticipated to be conducted 

prior to supporting the handling and irradiation of LEU targets. Facility modifications and 

equipment refurbishment activities will be completed inside the existing MURR building and will 

consist of (NWMI 2015a, 2015c):

• installation of 3 graphite reflector elements in the reactor,

• fabrication of a target transfer cask,

• construction of an airlock on the beamport floor of the reactor containment,
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• installation of storage areas for irradiated targets, and

• refurbishment of the overhead crane and freight elevator.

Facility modifications and equipment refurbishment activities are anticipated to be completed 

within 2 months and will require up to 6 temporary construction workers (NWMI 2015c). No 

excavation or ground-disturbing activities are anticipated to occur in connection with facility 

modifications and equipment refurbishment activities (NWMI 2015c). Additional traffic and 

vehicle-related emissions will be minimal in connection with the construction workers and single 

delivery of transfer cask and storage racks (NWMI 2015c). No additional water use to complete 

modifications is anticipated (NWMI 2015c).

The NRC staff does not expect any impacts to ecological resources given that modification 

activities would be internal and limited to the existing MURR facility. The NRC staff has 

identified no foreseeable land and visual impacts, given that modifications would not change 

any land use on or off site and external changes to the MURR facility would not occur. The 

NRC staff has identified no foreseeable air quality and offsite noise impacts given that additional 

air and noise emissions from the additional 6 worker vehicles and single deliveries would be 

minimal and additional noise levels from facility modification activities would be contained inside 

the MURR building. No impacts to water resources are expected, because there would be no 

changes in water use from facility modifications and refurbishment. There would be no 

socioeconomic, environmental justice, or cultural impacts associated with facility modifications 

given the short duration of facility modifications (2 months), minimal additional workers needed, 

and that modifications would be internal and limited to the existing MURR facility. In addition, 

facility modification and refurbishment activities will not change the types or quantities of 

effluents that may be released, nor are these activities expected to result in a significant

increase in individual or cumulative public or occupational radiation exposure (NWMI 2016c).

4.13.1.2 Irradiation Services

Irradiation services provided by MURR will result in an additional 26 deliveries per year to 

MURR and 104 offsite shipments per year to the proposed NWMI facility, target handling of up 

to 624 LEU unirradiated targets, and irradiation of up to 624 LEU targets at MURR 

(NWMI 2015a, 2016a, 2016b). Irradiation services at MURR will not change land use, will not 

require additional employees, and no additional water use will be required to support operation 

activities (NWMI 2015c). Additionally, no anticipated changes in the sources, types, and 

quantities of nonradiological effluent releases and waste streams are expected from irradiation 

of LEU targets (NWMI 2015c). Therefore, the NRC staff does not expect impacts to ecological 

resources, land use, visual, geological resources, water resources, historic or cultural 

resources, or socioeconomics from LEU target handling and irradiation at MURR. The potential 

impacts from additional deliveries, target handling, and target irradiation to air quality and noise, 

human health, and transportation environments are discussed below.

Air Quality and Noise

Deliveries and offsite shipments associated with MURR irradiation services will result in air 

criteria pollutant and GHG emissions as a result of vehicle exhaust. Target deliveries and 

shipments will result in an additional 130 vehicles per year and an additional annual 780 mi 

(1,255 km) (each vehicle would travel 6 mi (10 km), which is the distance between MURR and 

the proposed NWMI facility). The NRC staff estimates that an addition 780 mi (1,255 km) will 

emit less than 1 ton of criteria pollutants and GHGs. No additional workforce vehicle emissions 

would result from irradiation services; therefore, workforce vehicle emissions are anticipated to 

remain the same. Boone County is designated an unclassifiable/attainment area with respect to 

all NAAQS. The additional emissions associated with vehicle deliveries and shipments would 
Environmental Impacts of Construction, Operations, and Decommissioning

4-57

be less than 1 ton of criteria pollutants and GHGs and the NRC staff does not anticipate that 

these additional emissions would deteriorate air quality in Boone County. Therefore, the NRC 

staff concludes that air quality impacts from irradiation services at MURR are SMALL.

Additional noise associated from irradiation services at MURR will result from additional vehicle 

shipments and deliveries along the main roads, North Providence Road and Stadium Road, 

which provide access to MURR. Sound levels would increase at a rate of 3 dBA per doubling of 

traffic volumes. An increase in noise levels from an additional 130 vehicles per year as a result 

of LEU target deliveries and offsite shipments along the access roads to MURR will not be 

noticeable (see discussion below). Furthermore, noise from the additional vehicles will be 

intermittent and for short periods of time. Therefore, the NRC staff concludes that offsite noise 

impacts from irradiation services at MURR would be SMALL.

Human Health 

Activities performed at MURR in conjunction with providing irradiation services would include:

• handling of unirradiated LEU targets;

• operating the reactor to irradiate targets; and

• handling, packaging, and shipping of irradiated LEU targets (NWMI 2015a).

These activities could result in additional radiation dose to occupational workers and/or 

members of the public. MURR has extensive experience in handling irradiated reactor fuel, 

fueled experiments, and other materials that have high direct dose rates. For example, MURR 

staff perform a minimum of 16 fuel-handling evolutions for each week of operation. All high 

direct dose rate materials are handled using shielding, radiation safety procedures, and other 

measures to keep doses to MURR staff ALARA. Because these measures are used, the 

additional occupational dose associated with handling irradiated LEU targets is anticipated to be 

minimal relative to historical occupational doses received at MURR (see Section 3.10.1). Since 

unirradiated LEU targets or fuel produce only very low levels of radiation, the additional 

occupational dose from handling unirradiated LEU targets would also be very small. 

Additionally, given the similarity of the proposed activities to the fuel-handling evolutions 

currently performed at MURR, a measureable increase in the direct dose to the public (which is 

currently very low as discussed in Section 3.10.1) is unlikely to occur (NWMI 2015a).

No radiological gaseous emissions are expected from the targets, although gaseous releases 

from the operation of the reactor can change based on how often and at what power level the 

reactor is operated. At MURR, no change in radiological gaseous effluents would be expected 

because the operating tempo of the reactor would not change (NWMI 2015c). Therefore, there 

would be no increase in radiation doses to the public from gaseous effluents. Additionally, no 

changes in the sources, types, or quantities of nonradiological gaseous effluents are anticipated 

at MURR, and no changes in any radiological or nonradiological liquid waste streams are 

expected (NWMI 2015c).

As discussed in Section 4.13, the MURR licensee would have to apply to the NRC for, and be 

issued, a license amendment before target irradiation could occur at MURR. The NRC staff 

would perform a detailed review of the request to ensure that the irradiation would comply with 

all applicable NRC regulations. The dose consequences of any potential accident associated 

with target irradiation must be within the limits in 10 CFR Part 20. If the consequences of each 

accident remain below 10 CFR Part 20 limits, then no significant additional public dose or 

environmental impact is expected from accidents associated with target irradiation at MURR.

The University of Missouri Department of Environmental Health and Safety requires MURR to 

implement health and safety policies and procedures that require the identification of industrial 
Environmental Impacts of Construction, Operations, and Decommissioning

4-58

hazards before performance of jobs (NWMI 2015c). Procedures for ensuring occupational 

health and safety at MURR are not expected to change. In addition, MURR maintains an 

emergency response plan for handling any emergencies or accidents at the facility 

(NWMI 2015c). The regulations at 10 CFR 50.54(q) require that any changes to this emergency 

plan that could reduce its effectiveness must be approved by the NRC.

No significant change in radiation doses to the public, and only a minimal increase in 

occupational radiation doses to MURR staff, is expected to occur as a result of the irradiation

services that would be performed at MURR. In addition, no changes in nonradiological 

(chemical or occupational) hazards to MURR staff or members of the public are anticipated. 

Therefore, the NRC staff concludes that human health impacts from irradiation services 

provided by MURR would be SMALL.

NWMI stated that the nonradiological waste streams at MURR are not expected to increase as 

a result of the irradiation services provided by MURR. In addition, NWMI stated that the liquid 

radioactive waste stream is not expected to increase (NWMI 2015c). The NRC staff expects 

that the types of irradiation services performed at MURR would not cause any significant 

additional nonradiological waste, or liquid radioactive waste, to be generated because these 

types of services do not generate these wastes. The solid low-level radioactive waste stream at 

MURR is expected to increase by 4 to 6 cubic feet annually; however, this volume of waste 

would be small (about 1 percent increase by volume) relative to the amount of low-level 

radioactive waste currently generated at MURR (see Section 3.10.1), and all of this additional 

waste would be expected to be Class A, the lowest (least radioactive) level of radioactive waste 

(NWMI 2015a, 2016c). Because only minimal additional radioactive or nonradioactive waste 

would be produced, the NRC staff concludes that waste management impacts from irradiation 

services provided by MURR would be SMALL.

Transportation

Major roads in the vicinity of MURR include South Providence Road to the east of MURR and 

E. Stadium Boulevard to the north of MURR. Access to MURR is by South Providence Road. 

MURR is approximately 2.5 miles (5.6 km) south of U.S. Interstate 70. Irradiation services 

provided by MURR will add an estimated 130 vehicles per year as a result of LEU target 

deliveries and shipments. The addition of 130 truck deliveries and shipments per year (less 

than one per day) would result in little if any noticeable traffic volume-related level of service 

impacts in the vicinity of MURR. Therefore, traffic volume-related transportation impacts from 

irradiation services provided by MURR would be SMALL.

4.13.2 Oregon State University TRIGA Reactor Site

4.13.2.1 Facility Modifications and Equipment Refurbishment

Facility modifications and equipment refurbishment at OSTR are anticipated to be conducted 

prior to supporting the handling and irradiation of LEU targets. Facility modifications and 

equipment refurbishment will be completed inside the existing OSTR building and will consist of 

(NWMI 2015a, 2015c):

• refurbishment or replacement of overhead crane,

• fabrication of a target transfer cask, and

• installation of target storage containers.

Facility modifications and equipment refurbishment activities are anticipated to be completed 

within 2 months and they will require up to two temporary construction workers (NWMI 2015c). 

No excavation or ground-disturbing activities are anticipated to occur in connection with facility 
Environmental Impacts of Construction, Operations, and Decommissioning

4-59

modifications and equipment refurbishment activities (NWMI 2015c). Additional traffic and 

vehicle-related emissions will be minimal in connection with two construction workers and a 

single delivery of transfer cask and storage racks. No additional water use to complete 

modifications is anticipated (NWMI 2015c).

The NRC staff does not expect any impacts to ecological resources, given that modification 

activities would be internal and limited to the existing OSTR building. The NRC staff has 

identified no foreseeable land and visual impacts because modifications would not change any 

land use on or off site and external changes to the OSTR building would not occur. The NRC 

staff has identified no foreseeable air quality or offsite noise impacts, given that additional air 

and noise emissions from an additional 2 worker vehicles and single deliveries would be 

minimal and additional noise levels from facility modification activities will be contained inside 

the OSTR building. No impacts to water resources are expected because there would be no 

changes in water use from facility modifications and refurbishment. There would be no 

socioeconomic, environmental justice, or cultural impacts associated with facility modifications, 

given the short duration of facility modifications (2 months), minimal additional workers needed, 

and that modifications would be internal and limited to the existing OSTR facility. In addition, 

facility modification and refurbishment activities will not change the types or quantities of 

effluents that may be released, nor are these activities expected to result in a significant

increase in individual or cumulative public or occupational radiation exposure (NWMI 2016c).

4.13.2.2 Irradiation Services

Irradiation services provided by OSTR will result in an increase in workload (NWMI 2015c). For 

the weeks that OSTR provides irradiation services (8 weeks out of the year), facility operations 

are anticipated to increase from a 40-hour work week irradiation schedule to a 24 hour per day, 

7 day per week schedule. This will also require an additional 10 staff to support the increase in 

operations for irradiation services; the additional employees are anticipated to be drawn from 

the existing university population (NWMI 2015c). Irradiation services will add the following 

activities at OSTR: 8 deliveries per year to OSTR; 16 offsite shipments per year to the 

proposed NWMI facility; handling of up to 240 LEU unirradiated targets; and irradiation of up to 

240 LEU targets (NWMI 2015a, 2015c, 2016b). Irradiation services at OSTR will not change 

land use and no additional water use will be required to support operation activities 

(NWMI 2015c). Additionally, no anticipated changes in the sources, types, and quantities of 

nonradiological effluent releases and waste streams are expected from irradiation of LEU 

targets (NWMI 2015c). Therefore, the NRC staff does not expect impacts to ecological 

resources, land use, visual, geological resources, water resources, historic or cultural resources 

from LEU target handling and irradiation at the OSTR. Further, the 10 additional employees 

drawn from the university population would not have an appreciable impact on socioeconomic 

conditions; therefore, no socioeconomic impacts would be expected as a result of irradiation 

services provided by OSTR. The potential impacts from additional deliveries, additional 

workforce, LEU target handling, and LEU target irradiation to air quality and noise, human 

health, and transportation are discussed below.

Air Quality and Noise

Vehicles would be the source of air emissions from irradiation services provided by OSTR. 

Target deliveries and shipments will result in an additional 24 vehicles per year, and the 

additional staff will result in 10 additional vehicles daily for up to 8 weeks. The additional staff is 

anticipated to be drawn from the existing university population; therefore, it is reasonable to 

assume that the workforce will commute up to 100 mi/day (161 km/day) and, therefore, an 

additional total 56,000 mi/year (90,160 km/year). Applying passenger vehicle exhaust emission 

factors (EPA 2008), the NRC staff estimates that worker vehicle emissions will emit less than 
Environmental Impacts of Construction, Operations, and Decommissioning

4-60

1 TPY of each criteria air pollutant and 22 TPY of GHGs. The offsite shipments and deliveries 

will be sent to and from the proposed NWMI facility in Columbia, Missouri (approximately 

2,000 mi (3,218 km)). Applying truck exhaust emission factors (EPA 2008), the NRC staff 

estimates that delivery and shipment vehicle emissions will emit less than 1 TPY of each criteria 

air pollutant and 28 TPY of GHGs. Emissions from vehicle sources to support irradiation 

services are not significant. Benton County, where OSTR is located, is designated in 

unclassifiable/attainment area for all NAAQS. Given the estimated emissions from vehicle 

exhaust, the NRC staff does not anticipate that these additional emissions would deteriorate air 

quality in Benton County. Therefore, the NRC staff concludes that air quality impacts from 

irradiation services at the OSTR would be SMALL.

Sources of noise from irradiation services provided by OSTR will be from the additional 

workforce and delivery/shipment vehicles along the main roads that provide access to OSTR. 

Additional workforce travel will be temporary (8 weeks out of the year) and will consist of 

10 vehicles. Sound levels increase at a rate of 3 dBA per doubling of traffic volumes. An 

increase in noise levels from an additional 10 worker vehicles per year and 

24 delivery/shipments per year along the access roads to OSTR relative to current traffic levels 

(see discussion below) near the roads in the vicinity of OSTR are not anticipated to be 

noticeable. Further, noise from the additional worker vehicles and delivery/shipment vehicles 

will be intermittent and for short periods of time. Therefore, the NRC staff concludes that offsite 

noise impacts from irradiation services at the OSTR would be SMALL.

Human Health

Activities performed at OSTR in conjunction with providing irradiation services would include:

• handling of unirradiated LEU targets;

• operating the reactor to irradiate targets; and

• handling, packaging, and shipping of irradiated LEU targets (NWMI 2015a).

These activities could result in additional radiation dose to occupational workers and/or 

members of the public. OSTR has experience in handling irradiated reactor fuel, specifically 

TRIGA fuel, which also has high direct dose rates. All high direct dose rate materials are 

handled using shielding, radiation safety procedures, and other measures to keep doses to 

OSTR staff ALARA. Historically, occupational doses at OSTR have not significantly increased 

due to increased handling or movement of irradiated TRIGA elements. Although irradiated LEU 

targets at OSTR are expected to have an associated dose rate approximately three times that of 

irradiated TRIGA fuel elements handled previously, the dose rate to personnel would be 

reduced by the use of an irradiated LEU target transfer cask with better radiation shielding than 

the cask routinely used for moving the TRIGA elements. Therefore, routine handling of 

irradiated LEU targets at OSTR is not expected to significantly increase occupational doses. 

Since unirradiated LEU targets or fuel produce only very low levels of radiation, the additional 

occupational dose from handling unirradiated LEU targets would also be very small. 

Additionally, given the similarity of the proposed activities to the fuel-handling activities 

previously performed at OSTR, a measureable increase in the direct dose to the public (which is 

currently very low as discussed in Section 3.10.2) is unlikely to occur (NWMI 2015a).

No radiological gaseous emissions are expected from the targets themselves, although gaseous 

releases from the operation of the reactor can change based on how often and at what power 

level it is operated. At OSTR, the average annualized concentration of gaseous radioactive 

effluents, particularly Ar-41, would increase because of the reactor’s increased operating tempo. 

Conservatively, the average annualized concentration of Ar-41 released at OSTR could 

increase by a factor of 4.8 if OSTR switched to 24 hours per day, 7 days per week, and 
Environmental Impacts of Construction, Operations, and Decommissioning

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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 1.4x10-7 microcuries per milliliter, 

compared to a TS limit of 4x10-6 microcuries per milliliter. If OSTR’s current average annualized 

effluent concentration increased by a factor of 4.8, it would still be well below the TS limit, 

ensuring that radioactive effluents from OSTR would continue to not cause the public dose limit 

in 10 CFR 20.1301 and the 10 mrem dose constraint in 10 CFR 20.1101(d) to be exceeded.

As discussed in Section 4.13, the OSTR licensee would have to apply to the NRC for, and be 

issued, a license amendment before target irradiation could occur at OSTR. The NRC staff 

would perform a detailed review of the request to ensure that the irradiation would comply with 

all applicable NRC regulations. The dose consequences of any potential accident associated 

with target irradiation must be within the limits in 10 CFR Part 20. If the consequences of each 

accident remain below 10 CFR Part 20 limits, then no significant additional public dose or 

environmental impact is expected from accidents associated with target irradiation at OSTR.

No changes in the sources, types, or quantities of nonradiological gaseous effluents are 

anticipated at OSTR, and no changes in any radiological or nonradiological liquid waste streams 

are expected (NWMI 2015c).

Oregon State University Enterprise Risk Services requires individuals working at OSTR to 

implement health and safety policies and procedures that require the identification of industrial 

hazards prior to the performance of jobs (NWMI 2015c). Procedures for ensuring occupational 

health and safety at OSTR are not expected to change. In addition, OSTR maintains an 

emergency response plan for handling any emergencies or accidents at the facility 

(NWMI 2015c). The regulations at 10 CFR 50.54(q) require that any changes to this emergency 

plan that could reduce its effectiveness must be approved by the NRC.

Only minimal increases in radiation doses to OSTR staff and members of the public are 

expected to occur as a result of the irradiation services that would be performed at OSTR, and 

these doses are expected to remain in compliance with regulatory limits. In addition, no 

changes in nonradiological (chemical or occupational) hazards to OSTR staff or members of the 

public are anticipated. Therefore, the NRC staff concludes that human health impacts from 

irradiation services provided by OSTR would be SMALL.

NWMI stated that the nonradiological waste streams at OSTR are not expected to increase as a 

result of the irradiation services provided by OSTR. In addition, NWMI stated that the liquid 

radioactive waste stream is not expected to increase (NWMI 2015c). The NRC staff expects 

that the types of irradiation services performed at OSTR would not cause any significant 

additional nonradiological waste, or liquid radioactive waste, to be generated because these 

types of services do not generate these wastes. The solid low-level radioactive waste stream at 

OSTR is expected to increase by 4 to 6 cubic feet annually; however, this volume of waste 

would be small (about a 15 to 25 percent increase by volume) relative to the amount of low-level 

radioactive waste currently generated at OSTR (see Section 3.10.2). Further, all this additional 

waste would be expected to be Class A, the lowest (least radioactive) level of radioactive waste 

(NWMI 2015c; NRC 2016c). Because only minimal additional radioactive or nonradioactive 

waste would be produced, the NRC staff concludes that waste management impacts from 

irradiation services provided by OSTR would be SMALL.

Transportation

Given an additional 10 workers commuting daily to the OSTR during 8 weeks of facility 

operations and 24 truck deliveries and shipments per year during irradiation services, there 

would be little if any noticeable traffic volume-related level of service impacts in the vicinity of 
Environmental Impacts of Construction, Operations, and Decommissioning

4-62

OSTR. Therefore, traffic volume-related transportation impacts from irradiation services 

provided by OSTR would be SMALL.

4.13.3 Third Research Reactor

4.13.3.1 Facility Modifications and Equipment Refurbishment

Facility modifications and equipment refurbishment at a yet to be identified third research 

reactor are anticipated to be conducted before the handling and irradiation of LEU targets. 

Facility modifications and equipment refurbishment activities will be completed inside the 

existing research reactor building and will consist of (NWMI 2015c):

• refurbishment of an existing overhead crane,

• fabrication of a target transfer cask, and

• installation of target storage containers.

Facility modifications and equipment refurbishment activities are anticipated to be completed 

within 2 months and will require up to 2 temporary construction workers (NWMI 2015c). No 

excavation or ground-disturbing activities are anticipated to occur in connection with facility 

modifications and equipment refurbishment activities (NWMI 2015c). Additional traffic and 

vehicle-related emissions will be minimal in connection with two construction workers and single 

delivery of the transfer cask, storage racks, and equipment for crane refurbishment. No 

additional water use to complete modifications is anticipated (NWMI 2015c).

The NRC staff does not expect any impacts to ecological resources given that modification 

activities would be internal and limited to the existing research reactor building. The NRC staff 

has identified no foreseeable land and visual impacts because the modifications would not 

change any land use on or off site and external changes to the research reactor building would 

not occur. The NRC staff has identified no foreseeable air quality and offsite noise impacts 

because additional air and noise emissions from the additional two worker vehicles and single 

deliveries would be minimal and additional noise levels from facility modification activities will be 

contained inside the research reactor building. No impacts to water resources are expected, 

because there would be no changes in water use from facility modifications and refurbishment. 

Similar to the MURR and OSTR, there would likely be no noticeable socioeconomic, 

environmental justice, or cultural resource impacts associated with facility modifications, given 

the short duration of facility modifications (2 months), and the few (2) additional workers

needed. Modifications would be completed inside buildings and limited to the existing research 

reactor facility. In addition, facility modification and refurbishment activities will not change the 

types or quantities of effluents that may be released, nor would these activities be expected to 

result in a significant increase in individual or cumulative public or occupational radiation 

exposure (NWMI 2016c).

4.13.3.2 Irradiation Services

Irradiation services provided by a third research reactor will result in an increase in workload 

(NWMI 2015c). For the weeks that a third research reactor provides irradiation services 

(8 weeks out of the year), facility operations are anticipated to increase from a 40-hour work 

week irradiation schedule to a 24 hours a day, 7 days a week schedule. This will also require 

an addition of up to 10 staff to support the increase in operations for irradiation services, which 

is anticipated to be drawn from the local population. Irradiation services will add the following 

activities at a third research reactor: 8 deliveries per year to a third research reactor; 16 offsite 

shipments per year to the proposed NWMI facility; handling of up to 240 LEU unirradiated 

targets; and irradiation of up to 240 LEU targets (NWMI 2015a, 2015c, 2016b). Irradiation 
Environmental Impacts of Construction, Operations, and Decommissioning

4-63

services at a third research reactor will not change land use and no additional water use will be 

required to support operation activities (NWMI 2015c). Additionally, no anticipated changes in 

the sources, types, and quantities of nonradiological effluent releases and waste streams are 

expected from irradiation of LEU targets (NWMI 2015c). Therefore, the NRC staff does not 

expect any impacts to ecological resources, land use, visual, geological resources, water 

resources, and historic or cultural resources at the third research reactor from LEU target 

handling and irradiation. Further, the up to 10 additional workers drawn from the local 

population would not have an appreciable impact on socioeconomic conditions; therefore, no 

socioeconomic impacts would be expected as a result of irradiation services provided by a third

research reactor. The potential impacts from additional deliveries, additional workforce, LEU 

target handling, and LEU target irradiation to air quality and noise, human health, and 

transportation are discussed below.

Air Quality and Noise

Vehicles would be the source of air emissions from irradiation services provided by a third

research reactor. Target deliveries and shipments will result in an additional 24 vehicles per 

year and the additional staff will result in up to 10 additional vehicles daily for up to 8 weeks. 

The additional staff is anticipated to be drawn from the local population (NWMI 2015c); 

therefore, it is reasonable to assume that the workforce will commute up to 100 mi/day 

(161 km/day) and therefore an additional total 56,000 mi/year (91,160 km/day). Applying 

passenger vehicle exhaust emission factors (EPA 2008), the NRC staff estimates that worker 

vehicle emissions will emit less than 1 TPY of each criteria air pollutant and 22 TPY of GHGs. 

The offsite shipments and deliveries will be sent to and from the proposed NWMI facility in 

Columbia, Missouri. The distance travelled from offsite shipment and deliveries would be no 

greater than the distance travelled between the proposed NWMI facility and OSTR because this 

is the greatest distance between the proposed NWMI facility and any operating research 

reactor. Therefore, up to 2,000 mi (3,218 km) will be traveled by each delivery or off-shipment, 

resulting in a total of less than 1 TPY of each criteria air pollutant and 28 TPY of GHGs. 

Emissions from vehicle sources to support irradiation services are not significant. Given the 

estimated emissions from vehicle exhaust, the NRC staff does not anticipate that these 

additional emissions would deteriorate air quality in the county where a third research reactor is 

located. Therefore, the NRC staff concludes that air quality impacts from irradiation services at 

a third research reactor would be SMALL.

Sources of noise from irradiation services provided by a third research reactor will be from the 

additional workforce and delivery/shipment vehicles along the main roads that provide access to 

a third research reactor. Additional workforce travel will be temporary (8 weeks out of the year) 

and will consist of up to 10 vehicles. The 24 additional delivery/shipment vehicles a year will not 

occur at the same time. An increase in noise levels from an additional 10 worker vehicles per 

year and 24 delivery/shipments per year along the access roads to a third research reactor are 

not anticipated to be noticeable because they will be intermittent, for short periods of time, and 

the increase in additional vehicles is not significant. Therefore, the NRC staff concludes that 

offsite noise impacts from irradiation services at a third research reactor would be SMALL.

Human Health

Activities performed at a third research reactor in conjunction with providing irradiation services 

would include:

• handling of unirradiated LEU targets;

• operating the reactor to irradiate targets; and

• handling, packaging, and shipping of irradiated LEU targets (NWMI 2015a, 2015c).
Environmental Impacts of Construction, Operations, and Decommissioning

4-64

These activities could result in additional radiation dose to occupational workers and/or 

members of the public. A third research reactor would use shielding, radiation safety 

procedures, and other measures to keep doses to staff ALARA. While some increase in 

occupational dose would be observed, the dose increase would not be significant because of 

the established radiation protection measures and radioactive material handling experience at a 

third research reactor (NWMI 2015c). Additionally, similarly to MURR and OSTR, a 

measureable increase in the direct dose to the public is unlikely to occur, because the current 

direct offsite dose at a third research reactor is presumably very low, and new activities 

performed at a third research reactor would be similar to fuel handling activities currently 

performed at that reactor (NWMI 2016c).

No radiological gaseous emissions would be expected from the LEU targets, although gaseous 

releases from the operation of the reactor could change based on how often and at what power 

level the reactor is operated. At a third research reactor, the average annualized concentration 

of gaseous radioactive effluents, particularly Ar-41, would be expected to increase due to the 

reactor’s increased operating tempo. However, a third research reactor would have a TS that 

would limit any increases in Ar-41 effluents such that the public dose limits in 10 CFR 20.1301 

would not be exceeded (NWMI 2015c).

As discussed in Section 4.13, the licensee for the third research reactor would have to apply to 

the NRC for, and be issued, a license amendment before target irradiation could occur at the 

third research reactor. The NRC staff would perform a detailed review of the request to ensure 

that the irradiation would comply with all applicable NRC regulations. The dose consequences 

of any potential accident associated with target irradiation must be within the limits in 

10 CFR Part 20. If the consequences of each accident remain below 10 CFR Part 20 limits, 

then no significant additional public dose or environmental impact is expected from accidents 

associated with target irradiation at the third research reactor.

No changes in the sources, types, or quantities of nonradiological gaseous effluents are 

anticipated at a third research reactor, and no changes in any radiological or nonradiological 

liquid waste streams are expected (NWMI 2015c).

Similar to MURR and OSTR, a third research reactor would be expected to implement 

occupational health and safety policies and procedures that would require compliance with 

Federal, State, and local regulations. A third research reactor would also be expected to 

maintain an emergency response plan for handling any emergencies or accidents at the facility. 

This plan would follow NRC guidance for emergency plans found in NUREG–1537 and the 

associated Interim Staff Guidance (NWMI 2015c). The regulations at 10 CFR 50.54(q) would 

require that any changes to this emergency plan that could reduce its effectiveness must be 

approved by the NRC.

Only minimal increases in radiation doses to a third research reactor staff and members of the 

public are expected to occur as a result of the irradiation services that would be performed at a 

third research reactor, and these doses are expected to remain in compliance with regulatory 

limits. Additionally, no changes in nonradiological (chemical or occupational) hazards to staff at 

a third research reactor or members of the public are anticipated. Therefore, the NRC staff 

concludes that human health impacts from irradiation services provided by a third research 

reactor would be SMALL.

NWMI stated that the nonradiological waste streams at a third research reactor would not be 

expected to change as a result of the irradiation services provided by a third research reactor. 

In addition, NWMI stated that the liquid radioactive waste stream is not expected to change 

(NWMI 2015c). The NRC staff expects that the types of irradiation services performed at a third 

research reactor would not cause any significant additional nonradiological waste, or liquid 
Environmental Impacts of Construction, Operations, and Decommissioning

4-65

radioactive waste, to be generated because these types of services do not generate these 

wastes. The solid low-level radioactive waste stream at a third research reactor would be 

expected to increase by 4 to 6 cubic feet annually; however, this volume of waste is small 

relative to the amount of low-level radioactive waste currently generated at other research and 

test reactors such as OSTR (see Section 3.10.2), and all of this additional waste would be 

expected to be Class A, the lowest (least radioactive) level of radioactive waste (NWMI 2015a, 

2016c). Since only minimal additional radioactive or nonradioactive waste would be produced, 

the NRC staff concludes that waste management impacts from irradiation services provided by 

a third research reactor would be SMALL.

Transportation

Given an additional 10 workers commuting daily to a third research reactor during 8 weeks of 

target irradiation and 24 truck deliveries and shipments per year during irradiation services, 

there would be little if any noticeable traffic volume-related level of service impacts in the vicinity 

of a third research reactor. Therefore, traffic volume-related transportation impacts from 

irradiation services provided by a third research reactor would be SMALL.

4.14 Cumulative Impacts

The NRC staff considered potential cumulative impacts in the environmental analysis of the 

construction, operations, and decommissioning of the proposed NWMI facility. Cumulative 

impacts may result when the environmental effects associated with the proposed action are 

overlaid or added to temporary or permanent effects associated with other past, present, and 

reasonably foreseeable future actions. Cumulative impacts can result from individually minor, 

but collectively significant, actions taking place over a period of time. An impact that may be 

SMALL by itself could result in a MODERATE or LARGE cumulative impact when considered in 

combination with the impacts of other actions on the affected resource. Likewise, if a resource 

is regionally declining or imperiled, even a SMALL individual impact could be important if it 

contributes to, or accelerates, the overall resource decline.

For the purposes of this cumulative impacts analysis, past actions are those before the receipt 

of the NWMI construction permit application. Present actions are those related to the resources 

at the time of construction of the NWMI facility, and future actions are those that are reasonably 

foreseeable through the end of operation and decommissioning. The geographic area over 

which past, present, and reasonably foreseeable future actions would occur depends on the 

type of action considered and is described below for each resource area.

To evaluate cumulative impacts, the incremental impacts of the proposed action, as described 

in Sections 4.1 to 4.12, are combined with other past, present, and reasonably foreseeable 

future actions regardless of what agency (Federal or non-Federal) or person undertakes such 

actions. The NRC staff used the information provided in the ER; responses to RAIs; information 

from other Federal, State, and local agencies; scoping comments; and information gathered 

during the visits to the proposed NWMI facility site to identify other past, present, and 

reasonably foreseeable future actions.

Table 4–11 identifies recent past, present, and reasonably foreseeable future actions within the 

geographic extent of analysis. To be considered in the cumulative impacts analysis, the NRC 

staff determined whether the project would occur within the noted geographic areas of interest 

and within the noted timeframes, whether it was reasonably foreseeable, and whether there 

would be potential overlapping effects with the proposed project. For past actions, 

consideration within the cumulative impacts assessment is resource- and project-specific. In 

general, the effects of past actions are included in the description of the affected environment in 
Environmental Impacts of Construction, Operations, and Decommissioning

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Chapter 3, which serves as the baseline for the cumulative impacts analysis. However, past 

actions that continue to have an overlapping effect on a resource potentially affected by the 

proposed action are considered in the cumulative impacts analysis.

Further, the NRC staff considers the potential cumulative, or overlapping, impacts from climate 

change on environmental resources that could be impacted by the proposed NWMI facility. 

Changes in climate have broad implications on water resources, land use and development, 

and ecosystems. In accordance with 10 CFR Part 51 Appendix A, the level of detail provided 

within the cumulative discussions below will be commensurate with the potential for adverse or 

significant impacts to a specific resource area. However, climate change impacts on

construction and operation of the proposed NWMI facility, are considered outside the scope of 

the EIS; this EIS documents the potential impacts from construction, operations, and 

decommissioning of the proposed NWMI facility on the environment. External events and 

extreme weather event impacts on the proposed NWMI facility will be assessed in the NRC 

staff’s SER.

Past, Present, and Reasonably Foreseeable Future Projects and 

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)

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 (EAG [formerly 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)

EAG Laboratories

(formerly ABC 

Laboratories)

Analytical biochemical 

testing services

0.3 mi (0.5 km) 

west of site

Operational (ABC 2016; EAG 2017)

IDEXX 

BioResearch

Animal bioresearch 

health monitoring and 

diagnostic testing 

laboratory

0.1 mi (0.16 km) 

northwest of site

Operational (IDEXX 2015; 

MU 2016g)
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Project Name Summary of Project Location Status

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 connector

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)

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)
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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

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 Recreation

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 

Recreation 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)

Rock Bridge 

Memorial 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)
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Project Name Summary of Project Location Status

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.

Climate Change

Climate change is the decades or longer change in climate measurements (e.g., temperature, 

precipitation) that has been observed on a global, national, and regional level (EPA 2014; 

IPCC 2007a; USGCRP 2014). Climate change can vary regionally, spatially, and seasonally 

depending on local, regional, and global factors. Just as the regional climate differs throughout 

the world, the impacts of climate change can vary between locations. Climate change research 

indicates that the cause of the Earth’s warming over the last 50 years is due to the buildup of 

GHGs in the atmosphere resulting from human activities (USGCRP 2014).

In the United States, the U.S. Global Change Research Program (USGCRP) reports that, 

from 1895 to 2012, average surface temperature has increased from 1.3 °F to 1.9 °F (0.72 °C to 

1.06 °C), and since 1900, average annual precipitation has increased by 5 percent 

(USGCRP 2014). On a seasonal basis, warming has been the greatest in winter and spring. 

From 1895 to 2011, an increase in the length of the freeze-free season, the period between the 

last occurrence of 32 °F (0 °C) in the spring and first occurrence of 32 °F (0 °C) in the fall, has 

been observed for the contiguous United States; between 1991 and 2011, the average 

freeze-free season was 10 days longer than that between 1901 and 1960 (USGCRP 2014). 

Since the 1970s, the United States has warmed at a faster rate as the surface temperature rose 

at an average rate of 0.17 to 0.25 °C (0.31 to 0.45°F) per decade. Observed climate-related 

changes in the United States include increases in the frequency and intensity of heavy 

precipitation, earlier onset of spring snowmelt and runoff, rise of sea level in coastal areas of the 

United States, increase in occurrence of heat waves, and a decrease in occurrence of cold 

waves (EPA 2014; NOAA 2013a; USGCRP 2009, 2014).

Temperature data indicate that the Midwest region, where the proposed Discovery Ridge site is 

located, experienced a 0.06 °C (0.11 °F) per decade increase in annual mean temperature 

during the 1900 to 2010 period (NOAA 2013b). Temperature data for the recent past indicate 

an increased rate of warming for the Midwest: 0.12 °C (0.22 °F) per decade for the 1950 to 

2010 time period and a 0.26 °C (0.47 °F) temperature increase for the 1979 to 2010 time period. 

Average annual precipitation data for the Midwest exhibit an increasing trend of 0.31 in. 

(0.79 cm) per decade for the long-term period (1895 to 2011) (NOAA 2013b). Precipitation data 

over the 1958 to 2007 period exhibit clear trends toward more very heavy precipitation events 

(defined as the heaviest 1 percent of all daily events) for the Nation as a whole and particularly 

in the Northeast and Midwest.
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Future GHG emission concentration and climate models are commonly used to project possible 

climate change. Climate models indicate that over the next few decades, temperature 

increases will continue due to current GHG concentrations in the atmosphere (USGCRP 2014). 

Over the longer term, the magnitude of temperature increases and climate change effects will 

depend on both past and future GHG emissions (IPCC 2007a; USGCRP 2009, 2014). For the 

2021–2050 time period (relative to 1971–1999), climate model simulations indicate an increase 

in annual mean temperature of 2.5 to 3.5 °F (1.4 to 1.9 °C) for the entire Midwest region for both 

a low- and high-GHG emission modeled scenario. For mid-century (2041–2070) annual mean 

temperatures are projected to increase even greater; climate model simulations indicate an 

increase in annual mean temperature of 3.5 to 4.5 °F (1.9 to 2.5 °C) for a low-GHG emission 

modeled scenario and an increase in annual mean temperature of 4.5 to 5.5 °F (2.5 to 3.0 °C) 

for a high-GHG emission modeled scenario for the Midwest. Further, by mid-century the annual 

number of days above 95 °F (35 °C) are projected to increase by up to 25 days for Missouri. In 

addition, the length of the average frost-free season (the period between the last occurrence of 

32 °F (0 °C) in the spring and first occurrence of 32 °F (0 °C) in the fall is projected to increase 

by up to 23 days (USGRP 2014).

Climate model simulations indicate spatial differences in annual mean precipitation changes for 

the Midwest. For the 2021–2050 time period (relative to 1971–1999), models indicate an 

increase of 0 to 3 percent in annual mean precipitation for the northeast region of Missouri, 

while the southeastern region would experience a decrease of 0 to 3 percent. However, these 

changes in precipitation were not significant as the models indicate changes that are less than 

normal year-to-year variations and, therefore, less certain than annual mean temperature 

changes (NOAA 2013b; USGCR 2014). However, by mid-century increases in the frequency 

and intensity of extreme precipitation are projected to increase, while at the same time the 

average maximum number of consecutive days with less than 0.01 in of precipitation will 

increase (indicative of drought conditions) throughout the entire Midwest region 

(USGCRP 2014).

Changes in climate have broad implications for air quality, water resources, land use and 

development, and ecosystems. For instance, changes in precipitation patterns and increase in 

air temperature can affect water availability and quality, distribution of plant and animal species, 

land-use patterns, and land-cover, which can in turn affect terrestrial and aquatic habitats. 

Although the future effects of climate change are uncertain, the cumulative impact sections 

below discuss how future climate change may affect environmental resource areas that could 

be impacted by the proposed NWMI facility. 

4.14.1 Land Use and Visual Resources

This section addresses the direct and indirect effects of the construction, operations, and 

decommissioning of the proposed NWMI facility on land use and visual resources when added 

to the aggregate effects of other past, present, and reasonably foreseeable future actions. The 

description of the affected environment in Section 3.1 (5-mi (8-km) radius for land use and the 

viewshed for visual resources) serves as baseline conditions for the land use and visual 

resources cumulative impact assessment. The incremental impacts from construction, 

operations, and decommissioning of the proposed NWMI facility on land use and visual 

resources would be SMALL, as described in Section 4.1.

4.14.1.1 Land Use

The projects and activities described in Table 4–11 would result in minimal changes to existing 

land uses because new construction would occur either within or adjacent to existing facilities or 

within areas currently certified for industrial or commercial use. For example, most reasonably 
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foreseeable projects would occur within the Discovery Ridge Research Park. In the most recent 

land use plan, the City of Columbia (2013) identifies the Discovery Ridge Research Park as 

“shovel ready” for future industrial development. The research park is also one of three sites 

that the City of Columbia (2013) designated as an industrial certified site. The future 

development goal for the Discovery Ridge Research Park is to increase the number of business 

and research facilities on site, especially for entities that would benefit from the close proximity 

to the resources available at the University of Missouri (City of Columbia 2013). In addition, one 

of the City of Columbia’s (2013) economic goals is to attract new businesses and increase the 

number of light industrial and high tech jobs within the Columbia Regional Airport-Discovery 

Ridge–U.S. Highway 63 Corridor, which would include the proposed Discovery Ridge site. 

Given that Discovery Ridge Research Park is currently certified for industrial use, any new 

development within this area would be compatible with current land use plans.

Future urbanization and global climate change could contribute to additional decreases in 

agricultural lands, forests, grasslands, and wetlands. Urbanization in the vicinity of the 

proposed site would alter important attributes of land use.

Urbanization would reduce natural vegetation and agricultural fields, resulting in an overall 

decline in the extent and connectivity of wetlands, forests, grasslands, and wildlife habitat. 

Global climate change could reduce crop yields and livestock productivity (USGCRP 2014), 

which may change portions of agricultural land uses. However, existing parks, reserves, and 

managed areas would help preserve wetlands and forested areas. In addition, zoning laws and 

comprehensive land use plans would help ensure a proper balance of development (City of 

Columbia 2013, 2016a).

Given that reasonably foreseeable new construction activities would occur within or adjacent to 

existing facilities or within areas certified for industrial use, cumulative land use impacts would 

be SMALL.

4.14.1.2 Visual Resources

The projects and activities described in Table 4–11 would result in minimal changes to the 

existing viewshed because most new construction would occur either within or adjacent to 

existing facilities or within areas that are currently certified for industrial use. Furthermore, the 

viewshed within the vicinity of the proposed site includes agricultural, light industrial, residential, 

and forested views. Within nondeveloped areas, where a new structure would change qualities 

of the existing landscape, the viewshed directly surrounding the proposed Discovery Ridge site 

is generally of low scenic quality because of a lack of notable features, uniform landform, low 

vegetation diversity, an absence of water, and mute colors.

Given that 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, cumulative 

visual impacts would be SMALL.

4.14.2 Air Quality and Noise

This section addresses the direct and indirect effects of the construction, operations, and 

decommissioning of the proposed NWMI facility on air quality and noise at the Discovery Ridge 

site when added to the aggregate effects of other past, present, and reasonably foreseeable 

future actions. The description of the affected environment in Section 3.2 provides baseline 

conditions for the assessment of cumulative impacts on air quality and noise. The incremental 

impacts from construction, operations, and decommissioning of the proposed NWMI facility on 

air quality and noise would be SMALL, as described in Section 4.2.
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4.14.2.1 Air Quality

As described in Section 3.2.2, the ROI considered for the air quality analysis of the proposed 

NWMI facility is defined as Boone County. The ROI considered in the cumulative air quality 

analysis is also Boone County because air quality designations for criteria air pollutants are 

generally made at the county level.

Present-day activities in Boone County that could potentially result in cumulative impacts 

include seven major sources of air emissions identified on EPA’s Enforcement and Compliance 

History Online (ECHO) air data search tool (EPA 2016c). Minor sources of air emissions are 

also present in Boone County; however, a minor source classification typically indicates that the 

facility has little to no potential for significantly affecting air quality or interfering with plans to 

achieve compliance with NAAQS (IEPA 2015). Sources of air pollutants classified as a major 

source require a permit that will include provisions on how much and what is allowed to be

emitted, which serves to minimize cumulative impacts on air quality. Table 4–11, provides a list 

of current projects and reasonably foreseeable future actions that could contribute to cumulative 

impacts to air quality. Air emissions sources that contribute to air quality identified in

Table 4–11 (e.g., fossil fuel projects and manufacturing facilities) that are currently operating 

have not contributed to a violation of the NAAQS given Boone County’s designated 

unclassifiable/attainment status. These past and current emissions are included in the air 

quality baseline for Boone County. Therefore, cumulative impacts to air quality would be the 

result of changes to present-day emissions and future actions within Boone County.

Development and construction activities, as identified in Table 4–11, associated with regional 

growth in housing, business, and industry, as well as associated vehicular traffic, can increase 

air emissions. The population of Columbia, Missouri, is projected to increase between 22 and 

35 percent by 2030 (relative to 2010), and construction of new housing and associated 

infrastructure will be needed to accommodate the increase in population (City of 

Columbia 2013). The population in Boone County is projected to increase by 51.6 percent by 

2050 (relative to 2010), see Table 3-11. Annual job growth projection for Columbia is 1.3 to 

1.4 percent (City of Columbia 2013). Regional air quality conditions could deteriorate from the 

effects of the growth in the County as growth gives rise to dust, exhaust from increased traffic, 

and other emissions. While air emissions from construction activities would be temporary and 

localized, the resulting regional growth in residential, commercial, and industrial uses across 

Boone County can result in overall long-term air emission sources. These new stationary and 

mobile (e.g., vehicle) emission sources could further overlap with operation and 

decommissioning of the proposed NWMI facility and could noticeably alter air quality conditions 

in Boone County. If degradation in air quality is observed, MDNR can develop air quality control 

programs to mitigate the effects of development. However, mitigation will depend on the control 

strategies implemented and adherence to these strategies.

Climate change can affect air quality as a result of changes in meteorological conditions. The 

formation, transport, dispersion, and deposition of air pollutants depend, in part, on weather 

conditions (IPCC 2007a). Air pollutant concentrations are sensitive to winds, temperature, 

humidity, and precipitation (EPA 2009a). Ozone levels have been found to be particularly 

sensitive to climate change influences (IPCC 2007a; EPA 2009b). Ozone is formed, in part, as 

a result of the chemical reaction of nitrogen oxides and volatile organic compounds (VOCs) in 

the presence of heat and sunlight. Nitrogen oxides and VOC sources include both natural 

emissions (e.g., biogenic emissions from vegetation or soils) and anthropogenic emissions 

(e.g., motor vehicles, power plants). Nitrogen oxide, biogenic VOCs, and ozone concentrations 

are expected to be higher in a warmer climate (EPA 2009b). Although surface temperatures are 

expected to increase in the Midwest, this may not necessarily result in an increase in ozone 

concentrations. The observed correlation between increased ozone concentrations and 
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temperature has been found to occur in polluted and urban regions (those areas where ozone 

concentration are greater than 60 ppb). Additionally, increases in ozone concentrations 

correlated with temperature increases occur in combination with cloud-free regions and air 

stagnation episodes (Jacob and Winner 2009; IPCC 2013). Furthermore, climate model 

simulations do not agree on the ozone response to climate change. For instance, some models 

indicate increases in ozone concentrations with climate change for the Midwest 

(e.g., Wu et al. 2008), and others (e.g., Tagaris et al. 2007) project decreases in ozone 

concentrations with climate change for the Midwest.

Overall, the potential cumulative air quality impact 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.

4.14.2.2 Noise

The ROI considered for noise is a 1-mi (1.6-km) radius from the site boundary of the proposed 

NWMI facility. Noise levels attenuate rapidly with distance. When distance is doubled from a 

point source, noise levels decrease by 6 dBA (FHWA 2011). Generally, a 3-dBA change over 

existing noise levels is considered to be a “just noticeable” difference, a 5-dBA increase is 

readily perceptible, and a 10-dBA increase is subjectively perceived as a doubling in loudness 

(FHWA 2011).

Present-day activities within the ROI are identified in Table 4–11 and contribute to current 

background noise levels near the Discovery Ridge site. Potential cumulative noise impacts 

could occur during the construction, operations, and decommissioning phases in conjunction 

with other reasonably foreseeable activities occurring within the noise ROI of the proposed 

NWMI facility. Primarily, these would be construction-related activities from transportation 

projects as well as residential and commercial project construction identified in Table 4–11. 

Noise levels associated with construction equipment will be temporary and background levels 

would return once construction is completed. However, the potential expansion of the 

Discovery Ridge Research Park (MU 2009) and new roads adjacent to the proposed NWMI 

facility would result in an increase in noise levels from traffic and business growth after 

construction activities are complete. There is the potential for future expansion at the Discovery 

Ridge Research Park. Should this expansion occur coupled with additional noise from vehicle 

traffic from new roads adjacent to the proposed facility, the NRC staff concludes that 

background noise levels could increase similar to that of a thriving commercial area with noise 

levels reaching 70 dBA, resulting in an increase of 5 dBA from estimated background levels. 

This increase in noise levels would be noticeable to noise-sensitive receptors in the vicinity of 

the Research Park and would overlap with operation and decommissioning of the proposed 

NWMI facility. Therefore, the NRC staff concludes that cumulative noise impacts would be 

SMALL to MODERATE.

4.14.3 Geologic Environment

This section addresses the direct and indirect effects of the construction, operations, and 

decommissioning of the proposed NWMI facility at the Discovery Ridge site on the geologic 

environment when added to the aggregate effects of other past, present, and reasonably 

foreseeable future actions. The cumulative impacts on the geologic environment primarily relate 

to land disturbance, the potential for soil erosion and loss, and the consumption of geologic 

resources. The descriptions of the affected environment in Sections 3.3.1 and 3.3.2 
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(Site Geology and Soils, respectively) of this EIS serve as the baseline for the geologic 

environment cumulative impacts assessment.

The ROI for evaluating cumulative impacts on soil resources encompasses the Discovery Ridge 

site and a 5-mi (8-km) radius around the site. For geologic resources, the NRC staff further 

extended the ROI to include all of Boone County to encompass potential commercial sources of 

rock and mineral resources to support construction activities at the proposed site and vicinity. 

Because the aspects of land disturbance and conversion are addressed separately in 

Section 4.14.1.1, the cumulative impacts analysis here will focus on soil loss, including the loss 

of any prime farmland soils and other important farmland soils, and the consumption of geologic 

resources. The incremental impacts from construction, operations, and decommissioning of the 

proposed NWMI facility on the geologic environment, including geologic and soil resources, 

would be SMALL, as described in Section 4.3.

Soil Resources

New construction projects identified in Table 4–11 within the immediate 5-mi (8-km) radius of 

the Discovery Ridge site would result in the conversion and loss of soils. There would be no 

incremental loss of prime farmland or other important farmland soils because soils at the 

Discovery Ridge site do not meet the relevant criteria defined by the Natural Resources 

Conservation Service, as referenced in Section 3.3.2 of this EIS. Regardless, in accordance 

with local and State permits and approvals, as referenced in Sections 4.3 and 4.4 relative to the 

NWMI facility, all development activities in the ROI and beyond would be subject to BMPs for 

soil erosion and sediment control, which would serve to minimize soil erosion and loss. 

Developers would be likely to reclaim usable topsoil removed by ground-disturbing activities for 

use elsewhere within the impacted development sites. Alternatively, developers can stockpile 

usable topsoil or backfill and then sell or otherwise transfer it for reuse elsewhere at other 

development sites. 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. This would be the case, for example, at the NWMI facility site and at other 

pad sites within the Discovery Ridge Research Park. Although developed land areas could be 

reclaimed and sufficiently restored to support certain agricultural and nondeveloped uses at 

some point in the future, such lands and associated soils would not be restorable to their 

predeveloped state. Cumulative soil loss would largely occur in or adjacent to developed areas 

and soil loss would be mitigated by the use of BMPs. Based on these considerations, the NRC 

staff concludes that cumulative impacts on soil resources would be SMALL.

Geologic Resources

New facility construction and expansion (Table 4–11) would require the use and consumption of 

geologic resources, including rock and mineral assets such as construction aggregate materials 

(e.g., sand and gravel). Construction of the NWMI facility at the Discovery Ridge site would use 

many of the same materials, including concrete, gravel, and sand required for the other 

identified projects in Table 4–11. For example, construction of the NWMI facility would require 

about 1,700 yd3 (1,300 m3

) of crushed aggregate (limestone) (see Sections 2.2 and 4.3.1). By 

comparison, the 11-county rock and mineral district of central Missouri that includes Boone 

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

) of material (USGS 2015c).

As noted in Section 3.3.1, rock and mineral products including construction aggregate are 

widely available throughout Boone County and the surrounding region. Likewise, products 

derived from geologic materials, including concrete and asphaltic materials used in construction, 

are widely available on a regional basis. It is not likely that the geologic resource requirements 
Environmental Impacts of Construction, Operations, and Decommissioning

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to construct the NWMI facility or the resource requirements of other identified projects are of 

such a volume as to affect local and regional sources and supplies of the identified resources. 

In addition, there are no developed geologic assets (mines or quarries) at or near the Discovery 

Ridge site that would be rendered inaccessible for future use. Therefore, the NRC staff 

concludes that cumulative impacts on geologic resources would be SMALL.

4.14.4 Water Resources

This section addresses the direct and indirect effects of the construction, operations, and 

decommissioning of the proposed NWMI facility at the Discovery Ridge site on water resources 

when added to the aggregate effects of other past, present, and reasonably foreseeable future 

actions. This cumulative impacts analysis for surface water and groundwater resources 

considers such issues as water quality, water use, and potential climate change. It further 

considers relevant project actions, activities, and specific implications for surface water or 

groundwater withdrawal, effluent discharges, stormwater drainage and runoff, and accidental 

spills and releases. The description of the affected environment in Sections 3.4.1 and 3.4.2 

(Surface Water Resources and Groundwater Resources, respectively) serves as the baseline 

for the water resources cumulative impacts assessment.

The ROI for the surface water resources component of the cumulative impacts analysis is 

comprised of the Discovery Ridge site and the Bonne Femme Creek watershed downstream of 

the site, as described in Section 3.4.1. For groundwater resources, the area of analysis 

includes the Discovery Ridge site and the local groundwater basin in which groundwater is 

recharged and flows to discharge points within the watershed. The area comprises those 

aquifers from which groundwater is withdrawn through wells to supply potable, industrial, 

agricultural, and other uses within a 5-mi (8-km) radius of the Discovery Ridge site. Thus, this 

analysis focuses on those projects that, when combined with those under the proposed action, 

would: (1) withdraw water from or discharge effluents to Gans Creek and other tributaries within 

the Bonne Femme Creek watershed downstream of the site, or (2) would use groundwater or 

could otherwise affect the same aquifers that would supply water to the Discovery Ridge site. 

For surface water, the ROI further encompasses Perche Creek from its confluence with Hinkson 

Creek and including the segment of Perche Creek that receives effluent discharges from the 

Columbia Regional WWTP. The Columbia Regional WWTP would receive sanitary effluent 

from the proposed NWMI facility. The incremental impacts from construction, operations, and 

decommissioning of the proposed NWMI facility on surface water and groundwater resources 

would be SMALL, as described in Sections 4.4.1 and 4.4.2, respectively.

The proposed NWMI facility site is located within the Discovery Ridge Research Park. Site 

drainage flows generally south and southwest toward the southwesterly flowing Gans Creek, 

located approximately 0.35 mi (0.56 km) south of the site at is closest point. Gans Creek is 

located within the Bonne Femme Creek watershed that contributes drainage to the Missouri 

River, as described in Section 3.4.1. The State of Missouri has established water quality 

standards for Gans Creek and other tributaries within the Bonne Femme Creek watershed. 

Surface water is a minor source of water supply in Boone County. The predominant source of 

water for municipal water supply and for individual property owners in Boone County is 

groundwater pumped from deep bedrock aquifers, principally the Mississippian and the deeper, 

more extensive Cambrian-Ordovician aquifer system, described in Section 3.4.2.

4.14.4.1 Surface Water

Downstream of the Discovery Ridge site, the surface water hydrology is rather complex as the 

watershed is founded on karst terrane. Due to the occurrence of soluble carbonate bedrock, 

karst features include the presence of losing (sinking) and gaining sections of streams where 
Environmental Impacts of Construction, Operations, and Decommissioning

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surface water can easily enter the subsurface, providing flow to other streams. These features 

make surface waters and underlying groundwater particular vulnerable to contamination.

Gans Creek and other streams within the Bonne Femme Creek watershed have been 

designated by the State for the following beneficial uses: aquatic habitat protection; human 

health protection, whole body contact recreation, and secondary contact recreation; as well as 

livestock and wildlife protection and irrigation. In addition, the State of Missouri has classified a 

3 mi (4.8 km) section of Gans Creek as an Outstanding State Resource Water. Boone County 

has also designated this section of stream and adjoining areas as an environmentally sensitive 

area and includes karst features such as Devil’s Icebox Cave within Rock Bridge Memorial 

State Park (see Section 3.4.1.2).

An intensive study of the watershed conducted by Federal, State, and local stakeholder 

agencies (Frueh 2007) found water quality parameters to be typical for streams in carbonate 

bedrock areas and not seriously degraded from a hydrologic and water quality perspective. 

Nevertheless, Gans Creek as well as several of the stream segments within the Bonne Femme 

Creek watershed are included in the State’s list of “impaired” waters, pursuant to Section 303(d) 

of the Federal Water Pollution Control Act (i.e., Clean Water Act (CWA)) of 1972. The pollutant 

of concern is water-borne E. coli bacteria stemming from rural nonpoint source runoff. As 

further described in Section 3.4.1.2, the State is required to evaluate pollutant loadings within 

such watersheds and implement a watershed-based program to assure future compliance with 

water quality standards. On an individual project or facility basis, the State typically addresses 

watershed improvement through existing and new NPDES permits. The Federal NPDES permit 

program, under CWA Section 402, addresses water pollution by regulating point sources 

(i.e., pipes, ditches) that discharge pollutants to waters of the United States. The State of 

Missouri has been delegated NPDES permitting authority by EPA.

Within the context of the local watersheds of the Missouri River, such as Bonne Femme Creek, 

climate change is an important consideration. Prospects for continued increases in temperature 

and changes in precipitation patterns, including longer periods of drought, would be likely to 

reduce the overall amount of water available for surface runoff. Over the period 1988 to 2010, a 

decrease in soil moisture has been documented during most seasons in the central Midwest 

(USGCRP 2014). As temperatures are projected to continue to increase across the Midwest, 

this trend would be expected to continue. Meanwhile, by mid-century, the scientific community 

projects increases in the frequency and intensity of extreme precipitation, while at same time the 

average maximum number of consecutive days with less than 0.01 in. of precipitation will 

increase (indicative of drought conditions) throughout the entire Midwest region 

(USGCRP 2014). An increased frequency of extreme rainfall events can cause erosion and 

lead to a decline in water quality (USGCRP 2014). This is particularly true where soils are dry 

and less able to retain precipitation that falls during heavier precipitation events. The 

implications for a sensitive karst watershed, such as the Bonne Femme Creek watershed, are 

that climatic changes can bring with them increases in runoff laden with nutrients, sediment, and 

other contaminants, and associated changes in near-surface groundwater. Increases in 

impervious surface due to development can further exacerbate these changes in water quality.

The proposed NWMI facility is part of a larger development, the Discovery Ridge Research Park 

(Table 4–11). As described in Sections 3.4.1, 4.4.1 and 4.4.2, the NWMI facility would have no 

direct impact on surface water features and no direct discharge of industrial wastewater to 

surface water bodies. No surface water would be used for the construction, operations, or 

decommissioning of the proposed NWMI facility; therefore, there would be no incremental 

contribution to cumulative impacts due to surface water use. Stormwater runoff would occur 

from the facility site during construction, operations, and decommissioning. Groundwater 

removed from excavations during facility construction may also be discharged from the site. 
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During operations, NWMI would discharge sanitary wastewater to the City of Columbia sanitary 

sewer system. There would be no radioactive liquid effluents released from the facility during 

operations, as the RPF portion of the facility is designed to have zero liquid discharge.

Projects and activities occurring within the ROI would be subject to applicable local, State, and 

Federal regulatory requirements and associated permits and approvals. Accordingly, the 

University of Missouri will require that stormwater discharges from all tenants within the 

Discovery Ridge Research Park comply with the master stormwater management plan 

developed for the park. Construction projects are required to obtain a Land Disturbance Permit 

from the City of Columbia and submit related plans for city approval before any 

ground-disturbing activities or facility construction could begin on the site (Section 4.3.1). 

For projects outside the municipal boundary of the City, Boone County also requires a Land 

Disturbance Permit. These plans entail the implementation of construction-related BMPs for soil

erosion and sediment control and stormwater pollution prevention during site development, 

facility construction, and for post development.

The MDNR has developed an NPDES general permit that must be obtained by owners and 

operators for the discharge of stormwater and certain non-stormwater discharges

(e.g., dewatering) from land-disturbance sites that disturb 1 ac (0.4 ha) or more, or less than 

1 ac (0.4) but part of a larger development. This State general permit requires permit holders to 

develop and implement an SWPP, the purpose of which is in part to ensure the proper design, 

implementation, management, and maintenance of BMPs in order to prevent the introduction of 

sediment and other pollutants in stormwater discharges. MDNR also requires certain industrial 

facilities to obtain an NPDES permit for stormwater discharges during facility operations.

The WWTP serves the whole City of Columbia. During the projected 30-year period of 

operations, the only liquid waste discharged from the NWMI facility would be sanitary in nature. 

This effluent would be discharged to the City of Columbia sanitary sewer system at an average 

rate of approximately 4,570 gpd (17,300 Lpd). This is equivalent to approximately 0.0046 mgd 

(17.4 m3

/day). The Columbia Regional WWTP would be the ultimate point of 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

/day). NWMI’s additional wastewater volume would 

constitute a very small percentage (i.e., 0.12 percent) of the available treatment capacity of the 

WWTP. Sanitary wastewater discharges from the NWMI facility would be unlikely to have any 

impact on the facility or have any impact on ambient water quality downstream of the WWTP.

Nevertheless, the potential exists for substantial population growth in the County and City of 

about 40 percent between 2016 and 2050 (Section 3.7.1). The corresponding increase in 

sanitary effluent generated by the larger population would approach or exceed the capacity of 

the WWTP. This would necessitate that the City invest in additional wastewater treatment 

infrastructure. Given the planning timeframe, the NRC staff anticipates that the City of 

Columbia would be able to accommodate the increased treatment demand with timely 

expansions of treatment infrastructure, as it becomes needed.

In summary, construction, operations, and decommissioning of the proposed NWMI facility 

would have a minimal incremental contribution to cumulative impacts on surface water 

resources, including surface water and groundwater quality. Ongoing and future development 

projects within the Bonne Femme Creek watershed would be subject to County and City site 

development approvals, including Land Disturbance Permits. NPDES permits required for all 

new stormwater and industrial wastewater dischargers would include provisions to comply with 

applicable wasteload allocations established for downstream receiving waters. At present, there 

are few industrial facilities within the Bonne Femme Creek watershed or upstream of the 

watershed, as identified in Table 4–11. Within this context, however, climate change including 
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changes in runoff rate and quality would be expected to have as big or a bigger role in affecting 

surface water hydrology and water quality as growth and development alone in the watershed, 

as described above. In consideration of this information, the NRC staff concludes that the 

cumulative impacts on surface water resources would be SMALL to MODERATE, primarily due 

to regional growth and climate change.

4.14.4.2 Groundwater

Groundwater is the source of water supply for municipal water suppliers and individual users in 

Boone County. Total groundwater use in Boone County is approximately 18.2 mgd 

(68,890 m3

/day). While groundwater is withdrawn from the more productive zones of the 

Mississippian aquifer and from the upper units of the Ordovician age units for agricultural and 

domestic uses in Boone County, public water supply utilities primarily rely upon deep wells 

completed in the Cambrian-Ordovician aquifer system. The shallow glacial drift that occurs 

primarily over the eastern part of the County including the Discovery Ridge site is not generally 

used as a source of water supply, as discussed in Section 3.4.2.

Public utilities, including water and sewer, already exist at the Discovery Ridge site. The 

Discovery Ridge site lies within the service area of Consolidated Public Water Supply District 

No. 1, and it would supply water to the proposed NWMI facility site. The district is one of five 

water districts that supply water to the majority of users across Boone County, in addition to the 

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

/day) with water supply demands of approximately 

1.45 mgd (5,490 m3

/day) (Sections 3.4.2.2 and 4.4.2). In contrast, NWMI facility operations 

would require an average of 5,045 gpd (19,100 Lpd) of water, equivalent to 0.005 mgd 

(18.9 m3

/day).

The population of Boone County is projected to increase by about 40 percent by 2050, as 

referenced in Section 4.14.4.1. Assuming that this projected population growth has a direct and 

equal correlation on groundwater demand, total groundwater demand within the service area of 

Consolidated Public Water Supply District No. 1 could grow to approximately 2 mgd 

(7,600 m3

/day).

Given the groundwater production capacity of the water supply district and the availability of 

groundwater within Boone County, the forecasted water demands alone would not be expected 

to affect the water district’s ability to provide adequate water supplies over the next 30 years.

Nevertheless, based on the assessment presented below, the NRC staff assumes that climate 

change could have as great or a greater impact on surface water and groundwater resources, 

including overall water availability, as any other reasonably foreseeable future actions. Locally 

within the Bonne Femme Creek watershed, this is particularly relevant given the sensitivity of 

karst watersheds. The loss of moisture from soils because of higher temperatures, along with 

increased evapotranspiration from vegetation and the increased average number of days 

without precipitation is likely to intensify short-term (seasonal or shorter) droughts across the 

Midwest region into the future (USGCRP 2009, 2014). Such conditions can reduce the amount 

of water available for surface runoff, streamflow, and groundwater recharge. Specifically, 

climate change is projected to increase water demand across most of the United States. When 

accounting for regional changes in population coupled with predicted climate change impacts, 

current projections indicate that northeast Missouri (where the Discovery Ridge site is located) 

could experience climate-change induced increases in water demand of up to 10 to 25 percent 

(USGCRP 2014). This increase would still not challenge the current production capacity of 

Consolidated Public Water Supply District No. 1. In order to manage any increases in water 

demands across Boone County where the water supply is heavily reliant on deep groundwater, 

coupled with the potential for reduced groundwater recharge due to climate change, the 
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County’s water supply districts and other municipalities could take action to increase the 

efficiency and extent of their production and water distribution infrastructure. This could include 

redeveloping existing production wells or drilling new ones to manage water supply conflicts. 

Alternatively, public water suppliers could also seek out new water supply sources such as the 

abundant resources of the Missouri River, although this approach would entail investments in 

new infrastructure and increased operating costs. Suppliers could also pursue a combination of 

approaches such as conservation measures and new sources.

It remains that the projected average daily water needs for NWMI facility construction, 

operations, and decommissioning would be a very small percentage (less than 1 percent) of the 

public water district’s total production and current available supply capacity. In total, the NRC 

staff concludes that the cumulative impacts on groundwater resources, including water 

availability, would be SMALL.

4.14.5 Ecological Resources

This section addresses the direct and indirect effects of the construction, operations, and 

decommissioning of the proposed NWMI facility on ecological resources when added to the 

aggregate effects of other past, present, and reasonably foreseeable future actions. The 

description of the affected environment in Section 3.5 serves as a baseline for the ecological 

cumulative impact assessment. The ROI for evaluating cumulative impacts on ecological 

resources includes the Bonne Femme (Creek) watershed in the vicinity of the proposed site. 

The incremental impacts from construction, operations, and decommissioning of the proposed 

NWMI facility would be SMALL, as described in Section 4.5.

Before European settlement, the main land cover types within the Bonne Femme watershed 

included prairies, forests, and wetlands. Since that time, these habitats have been greatly 

reduced and converted into agricultural fields, and residential and commercial areas, as 

described in Section 3.5. The remaining tracts of grasslands, forests, and wetlands tend to be 

relatively small and isolated, which provides lower quality habitats than large tracts of habitat

because of the different biological and physical characteristics along the edge of a habitat patch.

Environmental management practices over the past few decades have slightly increased the 

quality and extent of terrestrial and aquatic habitats. For example, the amount of forested 

habitats has increased because of changes in land management and forestry laws 

(Karstensen 2010).

Current threats to terrestrial and aquatic habitats include increased soil, nutrients, and other 

pollutants washing into streams and lakes from urban and agricultural stormwater runoff, 

continued conversion and fragmentation of wildlife habitat from development, and the 

introduction of invasive species (BFSC 2007; USGS 2009). These activities will likely decrease 

the overall availability and quality of forested, grassland, and wetland habitats. Species with 

threatened, endangered, or declining populations are likely to be more sensitive to declines in 

habitat availability and quality and the introduction of invasive species.

New development projects identified in Table 4–11 are likely to have minimal impacts on 

ecological resources because all the projects are sited within areas that are currently 

agricultural land, open space, or developed. These types of land covers provide low-quality 

habitats for wildlife, birds, and aquatic resources.

State parks and wildlife refuges located near the proposed site, such as Rock Bridge Memorial 

State Park, Gans Creek Recreation Area, Three Creeks Conservation Area, and the northwest 

corner of the Mark Twain National Forest, provide valuable habitat to native wildlife and 

migratory birds. For example, these parks contain complex, natural habitats that are relatively 
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rare within the watershed, such as woodlands, oak forests, and tall grass prairies. As 

agricultural activities, development, and urbanization increase habitat conversion and 

fragmentation, these protected areas will become ecologically more important because they 

provide continuous areas of minimally disturbed habitat.

Climate change in the midwestern United States is likely to include an increase in the annual 

mean temperature combined with an increase in the intensity of rainfall events (USGCRP 2014). 

As the climate changes, ecological resources will either need to be able to tolerate the new 

physical conditions, such as less water availability, or to shift their population range to new 

areas with a more suitable climate. Some species may be more prone to changes in climate. 

For example, migratory birds that travel long distances may not be able to detect environmental 

clues that a warmer, earlier spring is occurring in the United States, while the birds are still 

overwintering in the tropics. Fraser et al. (2013) found that songbirds overwintering in the 

Amazon basin did not leave their winter sites earlier, even when spring sites in the eastern 

United States experienced a warmer spring. As a result, the song birds missed periods of “peak 

food” availability. Climate changes could also favor non-native invasive species and promote 

population increases of insect pests and plant pathogens, which may be more tolerant to a 

wider range of climate conditions (USGCRP 2014). Physiological stressors associated with 

climate change may also exacerbate the effects of existing stresses in the natural environment, 

such as those caused by habitat fragmentation, invasive species, nitrogen deposition and runoff

from agriculture, and air emissions.

Section 4.5 of this EIS concludes that the impact from the proposed facility construction, 

operations, and decommissioning would not noticeably alter the terrestrial and aquatic 

environment and, thus, would be SMALL. However, as environmental stressors, such as runoff

from agricultural fields and urban areas and climate change, continue over the proposed 

construction, operational, and decommissioning periods, certain attributes of the terrestrial and 

aquatic environment (such as habitat quality) are likely to noticeably change. The staff does not 

expect these impacts to destabilize any important attributes of the terrestrial and aquatic 

environment because such impacts will cause gradual change, which should allow many 

aspects of the terrestrial and aquatic environment to appropriately adapt. The NRC staff 

concludes that the cumulative impacts of the proposed construction, operations, and 

decommissioning of the NWMI facility plus other past, present, and reasonably foreseeable 

future projects or actions would result in MODERATE impacts to terrestrial and aquatic

resources. This MODERATE impact is primarily driven by environmental stressors, such as 

runoff from agricultural fields and urban areas and climate change, which are likely to noticeably 

alter important attributes of the terrestrial and aquatic environments. 

4.14.6 Historic and Cultural Resources

This section addresses the direct and indirect contributory effects from constructing, operating, 

and decommissioning the proposed NWMI facility at the Discovery Ridge site when added to 

the aggregate effects of other past, present, and reasonably foreseeable future actions on 

historic and cultural resources. The ROI in this analysis is the Discovery Ridge site and its 

immediate vicinity. As discussed in Section 4.6, constructing, operating, and decommissioning 

the proposed NWMI facility would not impact any known historic and cultural resources at the 

Discovery Ridge site.

The archaeological record for the region indicates prehistoric and historic occupation; the APE 

appears to have been traditionally used as agricultural fields from the protohistoric period 

onward. Historic land development and prolonged agricultural use may have resulted in 

impacts on, and the loss of, cultural resources. As described in Section 3.6.2, no evidence of 
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historic or cultural resources were found within the Lot 15 survey area, and the closest historic 

property is approximately 1 mi (1.6 km) to the northwest of the Discovery Ridge site. The only 

reasonably foreseeable project within the APE is the proposed NWMI facility. Therefore, 

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.

4.14.7 Socioeconomics

This section addresses the direct and indirect contributory effects from constructing, operating, 

and decommissioning the proposed NWMI facility at Discovery Ridge when added to the effects 

from other past, present, and reasonably foreseeable future actions on current socioeconomic 

conditions within the ROI. The description of the affected environment in Section 3.7 serves as 

a baseline for the cumulative socioeconomic impact assessment. The socioeconomic ROI is 

Boone County. Section 4.7 found that socioeconomic impacts from the construction, 

operations, and decommissioning of the proposed NWMI facility would be SMALL.

Table 4–11 identifies past, present, and reasonably foreseeable future actions within the ROI 

that could contribute to cumulative socioeconomic impacts. Relevant “other actions” that are 

considered in this cumulative impacts analysis are the potential for future construction within the 

Discovery Ridge site and the construction and operation of the Discovery Park, involving 

residential and commercial development, on the west side of U.S. Highway 63 opposite the 

Discovery Ridge site.

The proposed NWMI facility is located in Lot 15 of the Discovery Ridge Research Park, an area 

designated for research, development, and office park and is currently zoned for commercial 

use. The Discovery Ridge Research Park is large enough for the construction and operation of 

several research laboratory and office facilities. Since no other research or office facilities are 

currently planned for the Discovery Ridge Research Park, there would be no labor shortages 

because the City of Columbia and Boone County have a sufficient workforce to meet the needs 

for new research facilities (Section 3.7.4).

The Discovery Park development is being constructed 0.4 mi (0.6 km) southwest of the 

proposed NWMI facility. Demand for labor would not create a shortage because the City of 

Columbia and Boone County have a sufficient workforce to meet the needs for both 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. Therefore, with no other research or office facilities currently planned for the Discovery 

Ridge Research Park, the cumulative impact of the proposed NWMI facility, combined with the 

Discovery Park development, would be SMALL.

4.14.8 Human Health

The geographic ROI for the evaluation of cumulative effects on human health is a 5-mi (8-km) 

radius around the proposed NWMI facility. This evaluation will consider radiological and 

nonradiological impacts of other activities (in the recent past, present, and reasonably 

foreseeable future) within this ROI. Within this ROI, there are no nuclear power plants that 

would contribute to radioactive or nonradioactive exposure. However, the Callaway Energy 

Center nuclear power plant is located approximately 28 mi (45 km) away. Given that the 

proposed Discovery Ridge site is within the 50 mi (80 km) radiological emergency planning zone 

for the Callaway plant, radiological human health impacts associated with the Callaway plant will 

also be considered in this evaluation.
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As discussed in Section 4.8.2, the NRC staff reviewed the information provided by NWMI 

regarding the proposed radiological and nonradiological safety programs that would be 

implemented to protect occupational workers and members of the public from any detrimental 

human health effects that could be associated with operation of the proposed NWMI facility. 

The NRC staff concluded that both radiological and nonradiological human health impacts to 

workers and members of the public from operation of the proposed facility would be SMALL.

4.14.8.1 Radiological Impacts

Projects and facilities considered for this evaluation that could have potential radiological human 

health impacts within the ROI include:

• MURR (currently operating);

• Callaway nuclear power plant (currently operating);

• two ABC Laboratories facilities (currently operating);

• University Hospital and Boone Hospital Center (two currently operating medical 

facilities that perform procedures using radiation); and

• two sites with legacy radioactive contamination: the site of one of the two ABC 

Laboratories facilities listed above, and the University of Missouri’s Pickard Hall site.

As discussed in Section 3.10.1, MURR, which is located approximately 4 mi (6.4 km) from the 

proposed NWMI facility site, produces gaseous and liquid radiological effluents during routine 

operation. However, these effluents are monitored to ensure any public radiation dose that 

could result from the effluents is below NRC regulatory limits in 10 CFR Part 20. Additionally, 

environmental monitoring performed by MURR has shown minimal or no environmental impact 

from MURR operation. Given that MURR and the proposed NWMI facility would both be 

required to comply with NRC regulatory dose limits; current radiological environmental impacts 

from MURR are very low; and the distance between the two facilities (which would minimize 

potential cumulative radiation exposure), the NRC staff does not expect that the combined 

operation of these facilities would result in a cumulative radiological dose impact in excess of 

NRC regulatory limits.

The Callaway nuclear plant, which is discussed in Section 3.8.2, is located approximately 28 mi 

(45 km) from the proposed NWMI site. Environmental monitoring performed at the Callaway 

plant has shown minimal or no environmental impact from operation of the plant. Given that the 

Callaway plant and the proposed NWMI facility would both be required to comply with NRC 

regulatory dose limits; current radiological environmental impacts from the Callaway plant are 

very low; and the distance between the two facilities, the NRC staff does not expect that the 

combined operation of these facilities would result in a cumulative radiological dose impact in 

excess of NRC regulatory limits.

The two ABC Laboratories facilities, discussed in Section 3.8.2, are located approximately 

0.3 mi (0.5 km) and 5 mi (8 km) from the proposed NWMI site. ABC Laboratories is licensed by 

NRC to use radioactive materials at these facilities (NWMI 2015a). Although worker doses are 

monitored at these facilities to ensure compliance with NRC occupational dose limits, no 

environmental monitoring is required because no radioactive material releases, and 

consequently no radiation dose to the public, is anticipated from the continued operation of 

these facilities. Given that ABC Laboratories and the proposed NWMI facility would both be 

required to comply with NRC dose limits, and also given that no radiological environmental 

impacts are anticipated from ABC Laboratories operation, the NRC staff does not expect that 

the combined operation of these facilities would result in a cumulative radiological dose impact 

in excess of NRC regulatory limits.
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Two currently operating medical facilities, University Hospital and Boone Hospital Center, are 

each located approximately 4 mi (6.4 km) from the proposed NWMI site and each perform 

medical procedures using radiation. Although patients receiving these medical procedures are 

exposed to radiation, radiation doses to patients from medical procedures are not subject to 

NRC regulatory dose limits. The radiation exposure to members of the public outside of medical 

facilities is negligible; therefore, the NRC staff does not expect that the combined operation of 

University Hospital, Boone Hospital Center, and the proposed NWMI facility would result in a 

cumulative radiological dose impact in excess of NRC regulatory limits.

As discussed in Section 3.8.2, two sites in the ROI, an ABC Laboratories site and the University 

of Missouri’s Pickard Hall, which are located approximately 5 mi (8 km) and 1.2 mi (1.9 km) from 

the proposed NWMI facility site, respectively, contain legacy radiological contamination. The 

ABC Laboratories site contains three backfilled former liquid radiological waste disposal 

lagoons. However, surveys have shown the levels of residual radioactive contamination at this 

site to be very low. Since minimal or no continuing dose from radioactive material in these 

lagoons is expected, the NRC has approved the release of the land containing the backfilled 

lagoons for unrestricted use. The University of Missouri’s Pickard Hall, and some subsurface 

soil in the immediate vicinity of that building, contain legacy radioactive radium contamination 

from historical activities performed in the building. An internal standard operating procedure is 

used at Pickard Hall to help avoid any further spread of this contamination, minimizing any dose 

to the public. Since only minimal public radiation exposure occurs from either of these 

contaminated sites, and given the distance between these sites and the proposed NWMI facility, 

the NRC staff does not expect that the cumulative impacts of these sites and the proposed 

NWMI facility would result in a cumulative radiological dose impact in excess of NRC regulatory 

limits.

The NRC staff is currently conducting an independent evaluation of doses from the proposed 

NWMI facility to verify that the radiological exposure to occupational workers and members of 

the public from operation of the proposed NWMI facility would be below the regulatory limits in 

10 CFR Part 20. The NRC staff will document the results of its evaluation in its SER. If the 

NRC staff determines that the doses would be within the regulatory limits, the NRC staff 

concludes that the cumulative radiological human health impacts would be SMALL.

4.14.8.2 Nonradiological Impacts

Construction activities included in Table 4–11, as well as construction of the proposed NWMI 

facility, would involve potential hazards to workers typical of any construction site 

(NWMI 2015a). In addition, the proposed NWMI facility and some other facilities listed in Table 

4–11 are industrial sites with many typical occupational hazards. These construction and 

industrial activities would be required to be performed subject to OSHA and State of Missouri 

safety regulations. Additionally, as the proposed NWMI facility would not be accessible to the 

general public during construction or operation (NWMI 2015a), and other construction and 

industrial sites are also generally not publicly accessible, these hazards are not anticipated to 

affect members of the public.

Hazardous chemical releases from the proposed NWMI facility, and from other activities or 

facilities within the ROI, would be required to be within EPA and State of Missouri regulatory 

limits. In addition, certain toxic chemical releases must be reported to the EPA as part of EPA’s 

Toxics Release Inventory (TRI) program, as discussed in Section 3.8.3.

Other than the Discovery Ridge Research Park (which currently includes ABC Laboratories and 

IDEXX BioResearch as tenants), all other currently operating facilities in Table 4–11 for which 

possible chemical releases would be expected (Callaway nuclear power plant, MURR, Boone 

Quarries, University of Missouri’s Combined Heat and Power Plant, Columbia Municipal Power 
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Plant, and Columbia Energy Center) are approximately 4 mi (6.4 km) or more from the proposed 

NWMI facility site. ABC Laboratories and IDEXX BioResearch are 0.3 mi (0.5 km) and 0.1 mi 

(0.16 km) from the proposed site, respectively. Neither ABC Laboratories nor IDEXX 

BioResearch meet the thresholds that would make them subject to reporting for EPA’s TRI 

program (EPA 2016d).

In summary, given the distances between the proposed NWMI facility site and other facilities 

listed in Table 4–11 and that ongoing and future facilities that would release chemicals would be 

subject to applicable regulations, the NRC staff does not expect that the cumulative impacts of 

other facilities in Table 4–11 and the proposed NWMI facility would result in a cumulative 

chemical exposure impact in excess of Federal or State regulatory limits. The NRC staff 

therefore concludes that the cumulative nonradiological human health impacts would be 

SMALL.

4.14.9 Waste Management

The ROI for the evaluation of cumulative impacts from the disposal of radioactive and 

nonradioactive waste is that area within a 5 mi (8 km) radius of the proposed NWMI facility. 

Table 4–11 lists the facilities and activities considered within this ROI.

This evaluation considers the cumulative impacts within the ROI associated with the waste 

management activities of other facilities using radioactive and nonradioactive material in the 

recent past, present, and reasonably foreseeable future.

In Section 4.9., the NRC staff reviewed the information provided by NWMI regarding its 

radioactive and nonradioactive waste management plans. The NRC staff found that the 

procedures, controls, and engineering design features that would be used at the proposed 

NWMI facility would minimize impacts to workers and the public from the processing, handling, 

storage, transportation, and disposal of radioactive and nonradioactive wastes. The NRC staff 

therefore concludes that the human health impacts from both radioactive and nonradioactive 

wastes would be SMALL.

4.14.9.1 Radioactive Waste

Activities identified within the ROI that could generate radioactive waste include the operation 

of:

• MURR;

• ABC Laboratories; and,

• University Hospital and Boone Hospital Center, which use radiation for medical 

treatment.

Disposal of radioactive waste from any of these facilities would be required to be conducted in 

accordance with all Federal and State of Missouri regulations. Some or all radioactive wastes 

from these facilities would likely go to the same waste disposal sites. There are no radioactive 

waste disposal sites within the State of Missouri. Two facilities are available for the disposal of 

low-level radioactive waste produced within the State of Missouri: Energy Solutions Clive 

Operations in Clive, Utah, and WCS in Andrews, Texas. Energy Solutions accepts only Class A 

low-level radioactive waste, while WCS accepts Class A, B, and C low-level waste 

(NRC 2016e). As discussed in Section 4.9.1, NWMI plans to ship radioactive waste from the 

proposed facility to WCS (NWMI 2015a). WCS accepts mixed waste (i.e., waste that is both 

hazardous and radioactive), in addition to nonhazardous radioactive waste (WCS 2016).
Environmental Impacts of Construction, Operations, and Decommissioning

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As discussed in Section 4.9.1, if NWMI loses access to a low-level waste disposal facility, any 

low-level waste would have to be stored, either within the NWMI facility or in a new storage 

facility constructed either on site or at an offsite location, until a low-level waste facility is 

available. Low-level waste, regardless of its location, must be stored in accordance with 

Federal and state regulations to ensure the safety of workers and members of the public. As 

discussed in Sections 2.7.1, 2.8.1, and 4.9.1, NWMI would have controls and engineering 

design features at the proposed facility to ensure that processing, handling, and storage of 

radioactive waste would be conducted such that radiation doses to workers and members of the 

public are maintained ALARA. The NRC staff expects that similar facility design and 

management programs would be used to ensure safety during the temporary storage of lowlevel radioactive waste at other facilities within the ROI.

Based on the information on radioactive waste disposal for waste produced in Missouri and the 

United States, the NRC staff expects that there would be adequate disposal space for the 

cumulative quantities of radioactive waste that would be produced by the proposed NWMI 

facility and other facilities within the ROI. In addition, radioactive waste from all sources would 

be required to be handled, transported, and disposed of in accordance with Federal and state 

regulations. The NRC staff therefore concludes that the cumulative impact from radioactive 

waste disposal would be SMALL.

4.14.9.2 Nonradioactive Waste

Many activities within the ROI, including those listed in Table 4–11 and the proposed NWMI 

facility, could or would produce nonhazardous, nonradioactive wastes. Activities within the ROI 

that currently produce, or could produce, hazardous nonradioactive wastes include industrial, 

production, medical, and/or research facilities such as MURR, ABC Laboratories, IDEXX 

BioResearch, University of Missouri’s Combined Heat and Power Plant, Columbia Municipal 

Power Plant, University Hospital, and Boone Hospital Center.

As discussed in Sections 2.7.3 and 4.9.2, NWMI would implement a waste minimization and 

pollution prevention program that would help to minimize the production of hazardous and 

nonhazardous wastes at the proposed facility. As discussed in Sections 2.7.2 and 4.9.2, the 

proposed NWMI facility would generate less than 1,000 kg (2,205 lb) of hazardous waste per 

month, and approximately 4,056 kg (8,942 lb) of nonradiological, nonhazardous waste 

(i.e., municipal waste) per year during operation (NWMI 2015c). NWMI expects that 

nonradiological hazardous wastes from construction or operation of the proposed facility would 

be collected by a hazardous waste disposal company such as Veolia or Clean Harbors for 

separation, processing, and disposal. Other solid waste (municipal waste or construction 

debris) generated by the construction or operation of the proposed facility would be picked up 

and disposed of at the City of Columbia sanitary landfill (NWMI 2015c).

The NRC staff expects that nonradiological hazardous or nonhazardous wastes produced by 

activities in the ROI other than NWMI would be disposed of similarly to the waste from the 

proposed NWMI facility. As discussed in Section 3.8.3, ABC Laboratories and IDEXX 

BioResearch are hazardous quantity generators that are periodically inspected to ensure and 

enforce compliance with applicable waste management regulations. All hazardous waste would 

be managed according to applicable regulations (e.g., RCRA and the Missouri Hazardous 

Waste Management Law (Missouri Revised Statutes 2015b)). Given the population density and 

level of activity in the ROI, and given that the ROI includes other large and small quantity 

hazardous waste generators as discussed in Section 3.8.3, the NRC staff also expects that the 

incremental quantity of waste produced by the proposed facility would be comparatively small 

and that there would be adequate infrastructure and capacity for disposal of the additional 

waste.
Environmental Impacts of Construction, Operations, and Decommissioning

4-86

As discussed in Section 2.7.2, NWMI would release sanitary wastewater and nonradioactive 

liquid waste, meeting municipal treatment standards, to the Columbia sewer system. The NRC 

staff expects that wastewater from other activities within the ROI would be disposed of similarly 

to the wastewater from the proposed NWMI facility. The NRC staff also expects that the 

incremental quantity of wastewater produced by the proposed facility would be comparatively 

small, and that the Columbia sewer system would have adequate capacity to handle the 

additional wastewater.

Given that waste disposal infrastructure exists for nonradiological wastes generated within the 

ROI, that the incremental quantities of waste produced by the proposed NWMI facility would be 

comparatively small, and that all waste produced within the ROI would be handled and disposed 

of subject to Federal, State, and local regulations and standards, the NRC staff concludes that 

the cumulative impact from nonradiological waste disposal would be SMALL.

4.14.10 Accidents

The geographic ROI for the evaluation of cumulative effects of accidents is that within a 5 mi 

(8 km) radius of the proposed NWMI facility. This evaluation will consider cumulative impacts of 

radiological and chemical accidents that could occur within this ROI. Within this ROI, there are 

no nuclear power plants. However, the Callaway Energy Center nuclear power plant is located 

approximately 28 mi (45 km) away. Since the proposed site is within the 50 mi (80 km) 

radiological emergency planning zone for the Callaway plant, hypothetical radiological accidents 

associated with the Callaway plant will also be considered in this evaluation.

4.14.10.1 Radiological Accidents

As discussed in Section 4.11.1, the NRC staff reviewed the information provided by NWMI 

regarding radiological consequences of potential accidents at the proposed NWMI facility. The 

analyses provided by NWMI showed that hypothetical, unmitigated radiological accidents at the 

proposed facility could be intermediate-consequence for members of the public, and could be 

high- or intermediate-consequence for NWMI facility staff. However, NWMI stated that it would 

use engineered and administrative controls to reduce the likelihood and consequences of 

radiological accidents at the proposed facility, such that the proposed facility would comply with 

the performance requirements in 10 CFR 70.61. The NRC staff concluded that if the NRC 

safety review determined that the proposed NWMI facility would comply with 10 CFR 70.61 and 

any other applicable NRC regulations regarding radiological accident consequences, the 

impacts from potential radiological accidents would be SMALL.

Existing facilities included in this evaluation that could have potential radiological accidents are 

facilities that are nuclear reactors or that otherwise use radiation or radioactive materials, 

including Callaway nuclear power plant, MURR, ABC Laboratories, University Hospital, and 

Boone Medical Center. These facilities are licensed by NRC. To be licensed by NRC, facility 

licensees must show that the facilities are in compliance with NRC regulations, including dose

limits for accidents. Therefore accidents at these facilities are expected to have minimal 

environmental impact. For example, the generic EIS for license renewal of nuclear power plants 

in the United States (NUREG-1437) determined that the environmental impacts of both 

design-basis accidents (i.e., credible accidents) and beyond design-basis accidents 

(i.e., severe, unlikely accidents) would be SMALL (NRC 2013b). The plant-specific supplement 

to the generic EIS for license renewal that was developed for the Callaway nuclear power plant 

found no accident-related impacts for the Callaway plant beyond those discussed in the generic 

EIS (NRC 2014). 

The possible radiological accident impacts from other activities near the proposed NWMI facility 

would be minimal, and if the proposed NWMI facility were in compliance with NRC regulations 
Environmental Impacts of Construction, Operations, and Decommissioning

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regarding accident consequences, the incremental environmental effects of potential 

radiological accidents from the NWMI facility would also be minimal, as discussed in 

Section 4.11.1. Additionally, with the exception of the ABC Laboratories facility located 

approximately 0.3 mi (0.5 km) from the proposed facility site, for which no radiological releases 

are expected as discussed in Section 4.14.8.1, no other facilities currently licensed to use 

radiation or radioactive materials are located within approximately 4 mi (6.4 km) of the proposed 

facility site. Therefore, 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 accident consequences, the NRC staff concludes that the cumulative impact from 

potential radiological accidents would be SMALL.

4.14.10.2 Nonradiological Accidents

As discussed in Section 4.11.2, the NRC staff reviewed the information provided by NWMI 

regarding chemical exposure consequences of potential accidents at the proposed NWMI 

facility. The analyses provided by NWMI showed that hypothetical, unmitigated chemical 

accidents at the proposed facility could be high- or intermediate-consequence for members of 

the public and NWMI facility staff. However, NWMI stated that it would use engineered and 

administrative controls to reduce the likelihood and consequences of hazardous chemical 

accidents at the proposed facility, such that the proposed facility would comply with the 

performance requirements in 10 CFR 70.61. The NRC staff concluded that if the NRC safety 

review determined that the proposed NWMI facility would comply with 10 CFR 70.61 and any 

other applicable NRC regulations regarding chemical accident consequences, the impacts from 

potential hazardous chemical accidents would be SMALL.

Existing facilities or activities included in this evaluation that could have potential chemical

accidents include those listed in Table 4–11. These facilities or activities are required to comply 

with EPA and State of Missouri regulations to ensure the safe handling of chemicals and 

hazardous materials. The possible chemical accident impacts from other activities near the 

proposed NWMI facility would be minimal, and if the proposed NWMI facility were in compliance 

with NRC regulations regarding accident consequences, the incremental environmental effects 

of potential hazardous chemical accidents from the NWMI facility would also be minimal, as 

discussed in Section 4.11.2. Additionally, as discussed in Section 4.14.8.2, none of the facilities 

or activities listed in Table 4–11 that are located within approximately 4 mi (6.4 km) of the 

proposed NWMI facility site use hazardous chemicals in quantities that would make them 

subject to the EPA’s TRI reporting requirements, further reducing the likelihood that any 

significant chemical release accident could occur in close proximity to the proposed NWMI 

facility site. Therefore, 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 

hazardous chemical accident consequences, the NRC staff concludes that the cumulative 

impact from potential hazardous chemical accidents would be SMALL.

4.14.11 Transportation

This section addresses the direct and indirect contributory effects from constructing, operating, 

and decommissioning the proposed NWMI facility when added to the effects from other past, 

present, and reasonably foreseeable future actions on transportation infrastructure. The ROI is 

the 5-mi (8-km) region surrounding the proposed NWMI facility. However, the roads for routes 

that could be used for delivery of medical isotopes (if air transport is not possible) or disposal of 

wastes were also considered. Transportation infrastructure includes roadways, rail lines, 

airports, and traffic control devices. As discussed in Section 4.10, transportation impacts during 

construction, operations, and decommissioning would be SMALL.
Environmental Impacts of Construction, Operations, and Decommissioning

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Construction projects in Table 4–11 could produce an increase in vehicle traffic on roads within 

the 5-mi (8-km) radius of the proposed NWMI site. For example, Discovery Park, a residential 

and commercial development being constructed on the west side of U.S. Highway 63 opposite 

the Discovery Ridge Research Park, could add additional commuting vehicles and commercial 

trucks on local roads near the proposed NWMI facility. In addition, new construction projects 

could occur within the Discovery Ridge Research Park. However, existing roads are sufficient 

to handle the increased traffic. 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. Therefore, the cumulative effect of traffic-related 

transportation impacts of the proposed action combined with the Discovery Ridge Research 

Park and Discovery Park development would be SMALL.

4.14.12 Environmental Justice

The environmental justice cumulative impact analysis evaluates the potential contributory 

human health and environmental effects from the construction, operations, and 

decommissioning of the proposed NWMI facility when added to the effects from other past, 

present, and reasonably foreseeable future actions on minority and low-income populations and

whether these effects might be disproportionately high and adverse. Everyone living near 

Discovery Ridge Research Park and the proposed NWMI facility could be affected by 

construction, operations, and decommissioning activities, including minority and low-income 

populations.

The ROI is the 5-mi (8-km) region surrounding the proposed NWMI facility at the Discovery 

Ridge site. As discussed in Section 4.12, the proposed NWMI facility is not located in a minority 

population block group. Minority and low-income populations residing along site access roads 

could be affected by noise, dust, and increased commuter vehicle and truck traffic during 

construction, operations, and decommissioning. However, during construction and 

decommissioning, these would be short term and primarily limited to onsite activities. In 

addition, NWMI facility operations would not have high and adverse human health and 

environmental effects on minority and low-income populations. As a result, minority and 

low-income populations residing near the proposed NWMI facility at Discovery Ridge would not 

experience disproportionately high and adverse human health and environmental effects from 

the proposed action.

Table 4–11 identifies past, present, and reasonably foreseeable future actions within the ROI 

that could contribute cumulative human health and environmental effects. Potential impacts to 

minority and low-income populations from other past, present, and reasonably foreseeable 

future actions would mostly consist of environmental effects caused by construction and 

operation of new residential, commercial, and industrial developments (e.g., noise, dust, traffic, 

employment, and housing impacts). However, noise and dust impacts would be short term 

during construction and primarily limited to onsite activities. Minority and low-income 

populations residing along site access roads could be directly affected by commuter vehicle and 

truck traffic. However, these effects are not likely to be high and adverse and would be 

contained within a limited time period during certain hours of the day. Increased demand for 

housing could cause housing costs to rise. Increasing rental costs could disproportionately 

affect low-income populations who rely on inexpensive housing. However, given the availability 

of local labor and the likelihood that construction workers would commute to the work site, rental 

housing costs may be unaffected.

Emissions from new commercial or industrial facilities could also disproportionately affect 

minority and low-income populations. However, any impacts would depend on the magnitude of 
Environmental Impacts of Construction, Operations, and Decommissioning

4-89

the change from current environmental conditions. Permitted air emissions from all commercial 

and industrial facilities, including the contributory effects from the proposed NWMI facility, would 

be expected to remain within regulatory standards.

Based on this information and the analysis of human health and other environmental impacts 

presented in this EIS, the contributory effects of constructing, operating, and decommissioning 

the proposed NWMI facility are not likely to create high and adverse cumulative human health 

and environmental effects on minority and low-income populations living near Discovery Ridge

Research Park.

4.14.13 Summary

Table 4–12 summarizes the cumulative impacts for all resources areas.

Cumulative Impacts on Environmental Resources, Including the Impacts

of 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.

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.
Environmental Impacts of Construction, Operations, and Decommissioning

4-90

Resource Category Cumulative Impact Level Description of Impacts

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.

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.
Environmental Impacts of Construction, Operations, and Decommissioning

4-91

Resource Category Cumulative Impact Level Description of Impacts

Socioeconomics SMALL Cumulative socioeconomic impacts associated 

with the construction, operations, and 

decommissioning of the proposed 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 the 

proposed NWMI facility could temporarily 

increase the size of the local population as well 

as employment and tax revenue and create an 

increased demand for public services in the 

ROI. However, this effect would not likely be 

noticeable and 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.

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.
Environmental Impacts of Construction, Operations, and Decommissioning

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Resource Category Cumulative Impact Level Description of Impacts

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, 

because 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.
5-1

5.0 ALTERNATIVES

This chapter describes alternatives to granting a construction permit for the proposed Northwest 

Medical Isotopes, LLC (NWMI), medical radioisotope production facility (NWMI facility) and the 

environmental impacts of those alternatives. The need to compare the proposed action with 

alternatives arises from the requirement in Section 102(2)(C)(iii) of the National Environmental 

Policy Act of 1969 (NEPA), as amended (42 U.S.C. 4321 et seq.). NEPA states that an 

environmental impact statement (EIS) shall include an analysis of alternatives to the proposed 

action. The U.S. Nuclear Regulatory Commission (NRC) implements this requirement through 

regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 51 and its Interim Staff 

Guidance in NUREG–1537 (NRC 2012), which state that the EIS will include an analysis that 

considers and weighs the environmental effects of the proposed action, the environmental 

impacts of alternatives to the proposed action, and alternatives available for reducing or 

avoiding adverse environmental effects.

The NRC standard of significance for impacts uses the Council on Environmental Quality (CEQ)

terminology for “significantly” (40 CFR 1508.27). Since the significance and severity of an 

impact can vary with the setting of the proposed action, the NRC considered both “context” and 

“intensity,” as defined in the CEQ regulations in 40 CFR 1508.27. Context is the geographic, 

biophysical, and social context in which the effects would occur. Intensity is the severity of the 

impact. Based on this, the NRC established three levels of significance for potential impacts: 

SMALL, MODERATE, and LARGE. For this EIS, the NRC staff characterized impact levels for 

each resource area using the following three definitions of significance levels, which are 

presented in the Interim Staff Guidance to NUREG–1537 (NRC 2012):

SMALL—environmental effects are not detectable or are so minor that 

they will neither destabilize nor noticeably alter any important attribute of 

the resource. In assessing radiological impacts, the NRC has concluded 

that those impacts that do not exceed permissible levels in the NRC’s 

regulations are considered small.

MODERATE—environmental effects are sufficient to alter noticeably, but 

not to destabilize, important attributes of the resource.

LARGE—environmental effects are clearly noticeable and are sufficient to 

destabilize important attributes of the resource.

In this EIS, the NRC staff analyzed four alternatives to the proposed action. In Section 5.1, the 

NRC staff analyzed the no-action alternative or the environmental consequences if the NRC 

denies the construction permit. In Section 5.2, the NRC staff examined the environmental 

consequences if the NWMI facility were constructed, operated, and decommissioned at an 

alternative location. Based on an in-depth site selection process, the NRC staff examined in 

depth one alternative site, the University of Missouri Research Reactor (MURR). Section 5.3 

examines the environmental impacts of construction, operating, and decommissioning a medical 

radioisotope production facility at the proposed Discovery Ridge site but using alternative 

technologies. The NRC initially considered a wide-range of potential alternative technologies 

and narrowed down the potential technologies to examine two alternative technologies in depth: 

uranium fission technology and linear accelerator-based technology. Section 5.4 describes the 

benefits and costs of the various alternatives.
Alternatives

5-2

5.1 No-Action Alternative

Under the no-action alternative, the NRC would deny the construction permit, and the NWMI 

facility would not be constructed. The no-action alternative does not involve the determination 

of whether radioisotopes are needed or should be generated. The decision to produce 

radioisotopes is at the discretion of applicants (NRC 2012).

Under the no-action alternative, no changes would occur to the proposed Discovery Ridge site 

from NRC-authorized construction. The site would remain designated as an industrial certified 

site. If the NRC were to deny the construction permit, a private entity could construct a facility 

on Lot 15. Given that such a facility would also need to construct and operate in compliance 

with applicable local, State, or Federal requirements, and that the facility would also likely be a 

light industrial facility because it would occur within the Discovery Ridge Research Park, the 

impacts would likely be similar to those described in Chapter 4. Therefore, impacts on all 

resource areas would be SMALL.

The no-action alternative is the only alternative considered by the NRC that does not satisfy the 

purpose and need for this EIS, because this alternative does not satisfy the need for a 

U.S. supplier of molybdenum-99 (Mo-99). Assuming that the need for a U.S. supplier of Mo-99 

continues to exist, another private company would likely construct and operate a medical 

radioisotope production facility.

5.2 Alternative Sites

NWMI identified and selected reasonable alternative sites, using the site-selection process 

described in Section 5.2.1 (NWMI 2015a). The NRC staff reviewed NWMI’s site selection 

process and considered the environmental impacts of locating the proposed NWMI facility at an 

alternative site. Unless indicated otherwise, the following discussion is a summary of 

information presented in NWMI’s Environmental Report (ER) (NWMI 2015a) and responses to 

requests for additional information (RAI) (NWMI 2015c, 2016a).

5.2.1 Description of Alternative Site-Selection Process

5.2.1.1 Initial Site Screening

NWMI’s site-selection process assessed a variety of economic and environmental factors to 

determine reasonable sites to construct and operate the proposed NWMI facility. NWMI 

determined that proximity to an existing university research reactor was the most important 

factor in determining site location because the production process relies upon one or more 

research reactors to irradiate targets (NWMI 2016a). From this broad list of potential locations, 

NWMI (2016a) further narrowed the range of reasonable alternatives to four potential sites 

based on the following requirements for the co-located university research reactor:

• experience supporting government and commercial industries,

• capability to support commercial irradiation on a regular basis,

• core configuration that could accept the NWMI targets, and

• sufficient power to meet NWMI’s irradiation requirements.

Based on these criteria, NWMI identified four potential sites:
Alternatives

5-3

Discovery Ridge Site

The Discovery Ridge site is located in Columbia, Missouri, approximately 125 miles (mi)

(201 kilometers (km)) west of St. Louis, Missouri. The site is located 3.7 mi (6 km) southeast of 

the University of Missouri Research Reactor. The 7.4-acre (ac) (3.0-hectare (ha)) site is located 

on a parcel of land that is part of a larger, developing technology research park (the Discovery 

Ridge Research Park). The site has been previously disturbed due to decades of agricultural 

activities. No utilities or roadways currently exist on site, but they could be made available.

University of Missouri Research Reactor Site 

The University of Missouri Research Reactor (MURR) alternative site is located in Columbia, 

Missouri, approximately 125 mi (201 km) west of St. Louis, Missouri. The MURR alternative site 

is located within the MURR Center; the MURR Center occupies a 7.5-ac (3.0-ha) lot in a portion 

of the University Research Park, which is part of the University of Missouri (MU) campus and 

encompasses the existing research reactor. The production facility would be constructed 

immediately south of the MURR Center laboratory building, which houses the research reactor, 

on a partially paved parking lot. The paved parking lot within the MURR Center where the 

proposed NWMI facility would be constructed is 2.5 ac (1 ha) (NWMI 2016c). The land is 

currently zoned for industrial use and utilities are available. Under this alternative, NWMI would 

construct a below-ground direct connection between the existing MURR Center and the 

proposed NWMI facility (NWMI 2016c).

Oregon State University Training, Research, Isotopes, General Atomics (TRIGA) Reactor Site

The Oregon State University TRIGA Reactor (OSTR) alternative site is located in Corvallis, 

Oregon, approximately 80 mi (129 km) south of Portland, Oregon. The 3-ac (1.2-ha) site is 

located adjacent to the Oregon State University (OSU) Radiation Center, immediately to the 

east of the OSU TRIGA reactor (NWMI 2016c). Developing the site for the proposed facility 

would require relocation of two existing laboratory buildings and rerouting transportation access 

to the reactor bay. Utilities are currently available on site.

McClellan Business Park Site

The McClellan Business Park (McClellan) alternative site is located in McClellan, California, 

approximately 10 mi (16 km) north of Sacramento, California. The site includes an existing 

45,000 square feet (ft2

) (4,181 square meters (m2)) building approximately 61 m (200 ft) from 

the McClellan Nuclear Research Center, which houses a TRIGA reactor. The site is located 

within the McClellan Business Park. The land is currently zoned for industrial use and utilities 

are available.

5.2.1.2 Secondary Screening

To further narrow the range of possible alternatives, NWMI (2015a) conducted a decision 

analysis by using a Simple Multi-Attribute Rating Technique, which is based on the U.S. 

Department of Energy’s (DOE’s) Guidebook to Decision-Making Methods (DOE 2001). As part 

of this process, NWMI developed a set of 10 criteria to score the four potential sites and to 

ultimately identify the preferred site (Table 5–1). NWMI evaluated each site for each criteria and 

assigned it a score of 1 through 5 depending upon the site’s ability to meet the criteria. NWMI 

also weighted each criteria based on its relative importance in terms of NWMI’s business plan. 

As part of the business plan, NWMI assumed that no matter the alternative site, NWMI would 

transport targets to three RTRs for irradiation, and then transport the irradiated targets back to 

the production facility for processing. In addition, NWMI assumed that the majority of irradiation 

would occur at MURR (NWMI 2016a and 2016c).
Alternatives

5-4

Political and Local Logistic Support

NWMI determined that political and local logistical support are important factors in its 

site-selection process because local support depends on regional politics, and the importance to 

local economic development will likely play a large role in the financial success of the company. 

Therefore, NWMI assigned this criteria the highest weight of 10 points. NWMI assigned three 

sites, Discovery Ridge, MURR, and OSTR, a score of 4 (weighted score of 40), based on the 

high level of State, county, and local support for the proposed project and connections among 

NWMI and university reactor staff. McClellan scored the lowest (1, weighted score of 10) 

because of the limited State and local support for the proposed project.

Facility Operations

NWMI assigned facility operations the highest weight (10 points) based on the importance of 

NWMI having sole responsibility for operations and for the building design to prevent logistical 

complications. NWMI assigned Discovery Ridge a score of 4 (weighted score of 40) because 

NWMI would operate the proposed production facility. NWMI assigned MURR a score of 2 

(weighted score of 20), based on logistical complications to operate within a smaller space and 

because the University of Missouri would require that MURR personnel, rather than NWMI 

personnel, manage the facility. NWMI assigned both OSTR and McClellan a score of 3 

(weighted score of 30) because NWMI staff would solely manage the facility, although some 

land or building design constraints would make operations more constrained.

Production Logistics

NWMI assigned production logistics the highest weight (10 points) based on the critical role in 

minimizing transport time, and the associated (Mo-99) decay, to ensure NWMI delivers the 

maximum amount of product to the distributor. NWMI assigned Discovery Ridge and MURR a 

score of 4 (weighted score of 40), because target irradiation would primarily occur at MURR, 

which would be adjacent to or less than 20 mi (32 km) from the production facility. Thus, for 

these two sites, travel time would be minimized between the irradiation facility and the 

production facility. For OSTR and McClellan, NWMI assigned a score of 3 (weighted score 

of 30) given the longer distance between these two sites and MURR. NWMI assumed that all 

sites would have similar processing and product conditioning timeframes.

Transportation

NWMI assigned transportation a high weight (8 points) because longer transportation routes 

would likely be more costly because of the longer transportation time, especially with inclement 

weather delays. NWMI assigned MURR and Discovery Ridge a score of 4 (weighted score 

of 32), because target irradiation would primarily occur at MURR, which would be adjacent to or 

less than 20 mi (32 km) from either site. NWMI assigned OSTR and McClellan a score of 2 

(weighted score of 16) and 3 (weighted score of 24), respectively, based on the additional 

distance from these two sites to MURR, in which NWMI assumed the majority of irradiation 

would occur. Transportation to and from MURR from these sites would also require crossing 

significant mountain ranges, which may increase the probability of delays. OSTR is an 

additional 200 mi (322 km), or 5 hours of travel time, from MURR than McClellan, which 

influenced the lower score for OSTR.

Radioactive, Hazardous, and Mixed Secondary Waste Generation

NWMI assigned radioactive, hazardous, and mixed secondary waste generation a high weight 

(8 points) because the proposed facility must comply with Federal, State, and local radioactive 

and hazardous waste requirements, which may vary by State and/or locality. NWMI assigned 

McClellan a score of 3 (weighted score of 24) based on the additional State regulatory 
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requirements in California for the storage, transportation, and disposal of generated waste. 

Disposal costs may also be greater in California. Given the fewer regulatory requirements and 

lower disposal costs at the other three sites, NWMI assigned Discovery Ridge, MURR, and 

OSTR a score of 4 (weighted score of 32).

Federal, State, County, and Local Requirements

NWMI assigned Federal, State, county, and local requirements a weight of 5 because NWMI 

determined that differences in State, county, and local environmental permitting requirements 

could influence the initial start date for operations. NWMI assigned McClellan a score of 3 

(weighted score of 15) based on the additional State and local regulatory requirements in 

California, such as a State environmental analysis required under the California Environmental 

Quality Act. Given the fewer regulatory requirements at the other three sites, NWMI assigned 

Discovery Ridge, MURR, and OSTR a score of 4 (weighted score of 20).

Federal and State Taxes and Incentives

NWMI assigned Federal and State tax and incentives a low weight (3 points) because State and 

local taxes, employment hiring credits, and incentives may slightly differ among locations, which 

could affect the cost of construction, equipment, and operations. NWMI assigned Discovery 

Ridge and MURR a score of 5 (weighted score of 15), based on the low sales and corporate 

income taxes (4.225 and 6.25 percent, respectively) and the number of financial incentives 

offered in Missouri, such as State-wide programs to reduce taxes for companies creating new 

jobs and purchases of new equipment within certain manufacturing facilities, training programs 

for new employees, and recruitment assistance. NWMI assigned OSTR a score of 3 (weighted 

score of 9) based on the lack of sales tax, moderate corporate income tax (7.6 percent), and 

reduced property taxes for the proposed project. NWMI assigned McClellan a score of 1 

(weighted score of 3) based on the high sales and corporate income tax (7.75 and 8.84 percent, 

respectively), and the lack of reduced property taxes.

Available Space

NWMI assigned available space a low weight (3 points) because all four sites have the 

minimum amount of space required for the production facility, but differences in the available 

space could influence NWMI’s ability for future expansion and the complexity of construction 

activities. NWMI assigned Discovery Ridge a score of 5 (weighted score of 15) because no 

buildings currently occur on the site and space is available for future expansion. NWMI 

assigned MURR a score of 3 (weighted score of 9) because future expansion would be limited. 

NWMI assigned OSTR a score of 1 (weighted score of 3) because the site is less than 1.0 ha 

(2.5 ac) and no future expansion would be available. NWMI assigned McClellan a score of 2 

(weighted score of 6) because of limited construction possibilities within the existing building, 

although future expansion could occur.

Construction Costs

NWMI assigned construction costs a low weight (2 points) because local labor rates, materials 

costs, and the current site condition could have a small influence on the total construction cost. 

NWMI assigned Discovery Ridge a score of 4 (weighted score of 8) because few restrictions 

would impede building design and construction. NWMI assigned MURR a score of 3 (weighted 

score of 6), based on the higher costs to conduct construction activities within a limited space 

and to construct a below-grade connection to the MURR reactor. NWMI assigned OSTR and 

McClelland a score of 3 (weighted score of 6) because OSTR has few construction restrictions, 

but it may require demolition and reconstruction of existing buildings and also because 

McClellan would require structural and mechanical modifications to meet the code within the 

existing building.
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Natural or Human-Made Disaster Potential

NWMI assessed the natural or human-made disaster potential based on Federal Emergency 

Management Agency (FEMA) disaster declarations and U.S. Geological Survey (USGS) 

seismic activity predictions. NWMI assigned this criterion a low weight (1 point) because each 

site is adjacent or close to an existing reactor, which was likely sited in an area with low 

potential for natural or human-made disasters. NWMI assigned Discovery Ridge and MURR a 

score of 3 (weighted score of 3) because both sites have the most storm, flooding, and tornado 

declarations but low-to-no earthquake risk. OSTR received a score of 4 (weighted score of 4) 

because the associated county (Benton) had the fewest disaster declarations and 

moderate-to-low earthquake risk. McClellan received a score of 2 (weighted score of 2) 

because the associated county (Sacramento) had more disaster declarations than OSTR, but 

less than Discovery Ridge and MURR, and a higher earthquake risk.

Summary

NWMI (2015a, 2015c, 2016a) developed 10 site-selection criteria and weighted each criteria 1 

through 10, depending upon the relative importance to NWMI’s business plan. Next, NWMI 

assigned each site a score of 1 to 5, based on the criteria discussed above. Table 5–1 

summarizes these scores.

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

Based on these scores, NWMI selected the Discovery Ridge site, with a total weighted score of 

245 out of 300 (82 percent), as the proposed location for the NWMI facility. The three 

alternative sites scored lower: MURR (217 total weighted score; 72 percent), OSTR (190 total 
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weighted score; 63 percent), and McClellan (145 total weighted score, 48 percent) 

(NWMI 2016a). OSTR and McClellan scored lower than Discovery Ridge and MURR primarily 

based on the longer transportation routes and more complex production logistics, the lower 

State tax and financial incentives, and the lack of available space for future expansion. The 

NRC staff evaluated the site-selection methodology described above and concluded that the 

process for selecting and evaluating alternative sites, including the proposed site at Discovery 

Ridge, is reasonable and consistent with guidelines presented in NUREG–1537 and the 

associated Interim Staff Guidance (NRC 2012).

NEPA requires that an agency analyze a reasonable number of examples, covering the full 

spectrum of alternatives, in the EIS (46 FR 18026). Further, Appendix A to 10 CFR Part 51 

states that the level of information for each alternative considered will reflect the depth of 

analysis required for sound decisionmaking. The NRC staff analyzed one alternative site in 

detail given that the proposed site and alternative site likely cover the full spectrum of 

alternatives and provide sufficient information for sound decisionmaking based on the relatively 

small size of the proposed facility, the limited footprint and excavation required, the use of 

county water rather than surface or groundwater for withdrawal or discharge, and the ability to 

site the facility within a previously disturbed area. Thus, the NRC staff analyzed the MURR 

alternative site in detail below.

5.2.2 University of Missouri Research Reactor Alternative Site

The NRC staff evaluated the MURR site in detail as a reasonable alternative. The MURR site is 

a 3.0 ha (7.5 ac) lot located in Columbia, Missouri, within Boone County, approximately 125 mi 

(201 km) west of St. Louis, Missouri (Figure 5–1; NWMI 2016c). Specifically, the site is located 

on the University of Missouri Campus, within the MURR Center. NWMI would construct a new 

production facility immediately south of the existing research reactor on a partially paved 

parking lot. An external waste management building, a diesel generator building, and the 

Radioisotope Production Facility (RPF) building would be constructed on the 2.5-ac (1-ha) 

paved parking lot within the MURR Center (NWMI 2016c) and would collectively cover 

approximately 66,150 ft2 (6,145 m2

). There would be one offsite location at an existing building 

(the University of Missouri Life Science Incubator Building) across the street from the MURR 

Center that would house the administrative building, including offices and conference rooms, but 

no new construction would be required (NWMI 2016c). Research Park Drive and South 

Providence Road provide access to the site. Irradiation of low-enriched uranium (LEU) targets 

would be carried out at MURR, OSTR, and a third reactor. The impacts as a result of irradiation

of LEU targets at these three research reactors is discussed in Section 4.13 of the EIS.
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Figure 5–1. Cities and Major Roadways Transportation 

near the University of Missouri Research Reactor Alternative Site

5.2.2.1 Land Use and Visual Resources 

Land Use

The MURR site includes 7.5 ac (3.0 ha) of land within the southwestern portion of the City of 

Columbia (Figure 5–1; NWMI 2016c). The site is currently zoned for light industrial use and is 

part of the University Research Park (City of Columbia 2012, 2016i; NWMI 2015c). The 

University Research Park includes several industrial buildings used for research or commercial 

purposes (NWMI 2015a). A few deciduous trees occur on site, although most appear to have 

been planted for ornamental purposes (NRC 2015c). No prime farmland or farmland of 

Statewide importance, active mines or quarries, military reservations, Federally designated wild 

and scenic rivers, national parks, national forests, Federally designated coastal zone areas, or 

Federal lands held in trust for an American Indian tribe occur on the MURR site (NWMI 2015a; 

Find the Data 2016; NRCS 2016a, 2016b; NOAA 2016).
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Immediately surrounding the MURR site (within a 0.6-mi (1-km) radius), the majority of the land 

is owned by the University of Missouri, including three sporting venues: Memorial 

Stadium/Faurot Field (62,000 seats), Mizzou Arena (15,061 seats), and Hearnes Center 

(13,300 seats). The A.L. Gustin Golf Course is west of the MURR site and Epple Field, which 

includes the University of Missouri tennis facilities, is south of the MURR site.

Within a 5-mi (8-km) radius of the MURR site, a variety of land uses occur, including residential, 

light industrial, commercial, and forested areas. Several City and State parks occur within the 

vicinity, including multiple recreational trails (NWMI 2015a; NRC 2015b).

Construction

Construction at the MURR site would occur within an existing parking lot (NWMI 2015a, 2015c). 

Because the site is already zoned for industrial use and existing building have supported 

research for several decades, no change in zoning or land use would occur.

Impacts on land use from construction would be SMALL, given that no change in land use or 

zoning would occur, and no special land uses or mineral resources occur within the MURR site.

Operations

Operation of the NWMI facility would not require any new land or require land use changes 

beyond those required for construction. Therefore, impacts on land use during operations 

would be SMALL.

Decommissioning

Decommissioning activities would be similar to construction activities because they would 

involve heavy equipment to dismantle buildings and remove roadway and parking facilities. 

Land requirements to perform these activities would be similar to those required during

construction. After decommissioning activities are complete, the MURR site would likely remain 

industrial because it is part of the University Research Park. Given that land requirements 

would be similar to those described during construction, and that after decommissioning is 

complete the land would likely remain industrial, the NRC staff determined that the impacts on 

land use during decommissioning would be SMALL.

Visual Resources

The visual setting of the area that would be affected by the proposed NWMI facility at the MURR 

site is primarily a light industrial viewshed (NWMI 2015a; NRC 2015b). In addition, trees are 

visible in many directions (NWMI 2015a; NRC 2015b).

Construction

The activities associated with constructing the proposed NWMI facility (e.g., excavation, 

earthmoving, pile driving, and erecting the facility) would require large pieces of construction 

equipment, which may alter the appearance of the existing landscape because construction 

equipment is not typically visible on the MURR site. However, the MURR site has low scenic 

quality caused by a lack of notable features, uniform landform, low vegetation diversity, an 

absence of water, mute colors, cultural modifications to adjacent scenery, and a commonality 

within the physiographic province. The MURR site also has a low-to-moderate sensitivity rating 

because it is in an area with low scenic values and a lack of special natural and wilderness 

areas. In addition, the viewshed surrounding the MURR site is aesthetically altered by light 

industrial buildings, such as research facilities. In addition, NWMI (2015a) stated that the RPF 

building would be designed to blend in with the architecture of the existing facilities on the 

MURR site. Based on the light industrial viewshed, the low scenic quality and sensitivity ratings, 
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construction-related aesthetic impacts of the proposed NWMI facility at the MURR site would be 

SMALL during construction.

Operations

After the facility is constructed, the appearance of the NWMI facility at the MURR site would not 

change during operations, other than a small steam plume that may be visible from the exhaust 

stack. The steam plume from the exhaust stack is expected to be minimal, because opacity 

associated with the natural-gas-fired boiler tends to be low, as a result of emissions described in 

Section 4.2.1.1. The steam plume would be more visible during periods of cold weather, 

although the size of the steam plume would still be relatively small. Therefore, visual impacts 

during operations of the proposed NWMI facility at the MURR site would be SMALL.

Decommissioning

Decommissioning activities would be similar to construction activities because they would 

require heavy equipment to dismantle buildings and remove roadway and parking facilities. 

After decommissioning activities are complete, the MURR site would likely remain industrial 

because it is part of the University Research Park. Given that the facility would be located in a 

district zoned for light industrial use and the viewshed surrounding the MURR site is 

aesthetically altered by light industrial buildings, the NRC staff would not expect any changes to 

the landscape during decommissioning to significantly affect any viewsheds. Therefore, visual 

impacts during decommissioning of the proposed NWMI facility at the MURR site would be 

SMALL.

5.2.2.2 Air Quality and Noise

Air Quality

The MURR site is located in Boone County, Missouri. The climate at the MURR site is similar to 

what was described in Section 3.2.1 for the Discovery Ridge site. Boone County is part of the 

Northern Missouri Intrastate Air Quality Control Region (40 CFR 81.116). With regard to the 

National Ambient Air Quality Standards (NAAQS) criteria pollutants, Boone County is 

designated unclassifiable/attainment for all criteria pollutants (40 CFR 81.326). Therefore, 

criteria air pollutant concentrations in the County are lower than NAAQS or there is insufficient 

data to determine if the NAAQS are met. The nearest Class I Federal area to the proposed site 

is the Hercules-Glades Wilderness Area in Bradleyville, Missouri, approximately 140 mi 

(225 km) away. The region of influence (ROI) for the air quality analysis discussed below is 

Boone County, because air quality designations are made at the county level.

Construction

Sources of air pollutant emissions during construction at the MURR site would include fugitive 

dust from earth-moving equipment, non-road vehicles, and worker and delivery vehicles. 

Earth-moving activities, including excavation, clearing, and compacting, will generate fugitive 

dust on site. Operation of construction equipment will emit criteria pollutants (particulate matter, 

carbon monoxide, sulfur dioxide, and nitrogen oxides) on site from the combustion of fuels in 

equipment. Employee and delivery and shipment vehicular exhaust will emit criteria air 

pollutants (particulate matter, carbon monoxide, sulfur dioxide, and nitrogen oxides). Air 

emissions would be similar to those estimated and presented in Table 4–3 for the Discovery 

Ridge site, because construction activities and parameters would be similar (i.e., construction 

duration, and number of worker vehicles, land disturbance and excavation, and building 

footprint). Since the MURR site is centered on an existing paved parking lot, additional 

equipment (e.g., track drill, cold planer) to remove existing paved surfaces may be needed to 

prepare the site for construction. However, use of this equipment will be short term during the 
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beginning of site preparation. Therefore, construction air emissions at the MURR site would be 

similar to estimated emissions presented in Table 4–3. Overall construction-related emissions 

for criteria pollutants are well below the significant de minimis levels discussed under the New 

Source Review program and major source threshold emissions (see Section 3.2.2). Total 

greenhouse gas emissions (GHGs) (approximately 27,000 tons of carbon dioxide equivalent 

(CO2eq) per year) would be well below the 75,000 tons/year (TPY) of CO2eq (68,000 metric 

TPY) threshold for prevention of significant deterioration (PSD) and Title V permits set in the 

Greenhouse Gas (GHG) Tailoring Rule and EPA’s mandatory GHG Tailoring Rule 

(74 FR 56260). Therefore, the NRC staff does not expect increases in air emissions from 

construction activities at the MURR site to contribute to concentrations that would exceed 

NAAQS in Boone County. Given that air emissions during construction would be local and 

temporary (17 months), that Boone County is designated as an unclassifiable/attainment area, 

that construction emissions are well below the significant de minimis levels, and that 

construction emissions are not expected to contribute to concentrations that would exceed the 

NAAQS, the NRC staff concludes that air quality impacts during construction at the MURR site 

would be SMALL.

Operations

Air emissions sources from operation of the proposed NWMI facility would be predominantly 

from: (1) target preparation and irradiated target processing, (2) fuel combustion associated 

with processing and facility heating, and (3) vehicular traffic from commuting workers and from 

transportation of shipments and deliveries during operations. Air emissions would be similar to 

those estimated for the proposed Discovery Ridge site, because the operational activities and 

the number and type of sources would be similar (number of worker vehicles, fuel combustion 

sources, and target preparation and processing activities). Therefore, air emissions would 

include nitrogen oxides, sulfur dioxide, particulate matter, carbon monoxide, and carbon dioxide 

and would be similar to what is presented in Table 4–4. Based on these estimated emissions, 

the NRC staff does not expect emissions from operation of the NWMI facility at the MURR site 

to contribute to concentrations that would exceed NAAQS or that would deteriorate Boone 

County’s unclassifiable/attainment designation. Given that NAAQS are not expected to be 

exceeded and that Boone County is designated unclassifiable/attainment, the NRC staff 

concludes that air quality impacts during operation at the MURR site would be SMALL.

Decommissioning

Decommissioning activities would include earth-moving equipment, demolition of structures, and 

dismantlement and decontamination of systems over a period of up to 24 months 

(NWMI 2015a, 2016a). Equipment, worker vehicles, and truck shipments will emit criteria air 

pollutants (particulate matter, carbon monoxide, sulfur dioxide, and nitrogen oxides) and GHGs. 

Demolition and dismantlement of structures will emit fugitive dust. Air emissions would be 

similar to those estimated for the proposed Discovery Ridge site, because the decommissioning 

activities would be similar. Therefore, air emissions would include nitrogen oxides, sulfur 

dioxide, particulate matter, carbon monoxide, and carbon dioxide and would be similar to what 

is presented in Table 4–5. Projected emissions are well below the significant de minimis levels 

discussed under the New Source Review program in Section 3.2.2 of this EIS. Therefore, the 

NRC staff does not expect increases in air emissions from decommissioning activities to 

contribute to concentrations that would exceed NAAQS or prevent Boone County from 

maintaining attainment designation. The NRC staff concludes that air quality impacts from 

decommissioning at the MURR site would be SMALL.
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Noise 

Existing noise sources near the MURR site include vehicular traffic along South Providence 

Road (Route 63), cooling towers associated with MURR, and sports venues (within 0.3 mi 

(0.48 km) of MURR). Noise-sensitive receptors within 1 mi (1.6 km) of the MURR site include:

• residence, approximately 0.47 mi (0.76 km) north of the MURR site;

• golf course, approximately 0.09 mi (0.14 km) west of the MURR site;

• hospital, approximately 0.80 mi (1.3 km ) northeast of the MURR site;

• University of Missouri research buildings, 0.1 mi (0.16 km ) northeast of MURR site; 

and

• MURR, immediately adjacent to MURR site.

The NRC staff did not identify the existence of any ambient noise surveys for the MURR site 

and vicinity. At 5-ft (1.5-m) distance from MURR’s cooling towers noise levels can reach 

71 A-weighted decibels (dBA) (Lenntech undated). Typical noise levels at 15 m (50 ft) from a 

highway such as Route 63 can reach 70 dBA (FHWA 2003). The MURR site is located within 

the University Research Park; therefore, the NRC staff estimates background noise levels of 65 

to 70 dBA, which are typical of commercial areas. The ROI for the noise analysis discussed 

below is 1 mi (1.6 km) from the MURR site.

Construction

Noise sources associated with building the proposed NWMI facility will include construction 

equipment on site and workforce and shipment/delivery vehicles. Increased traffic volumes 

because of 82 workers and 21 deliveries per week can increase noise emissions along nearby 

access roads to the MURR site and will depend on the increase in traffic from current 

conditions. Access to the MURR site is from South Providence Road (Route 63) and Research 

Park Drive. In 2013, the annual average daily traffic volume traffic count along South 

Providence Road (at the Stadium Boulevard intersection) was 29,940 (1,247 vehicles per hour) 

(MODOT 2013). Sound levels increase at a rate of 3 dBA per doubling of traffic volumes and an 

increase of 3 dBA is barely noticeable. Conservatively assuming that all worker vehicles and 

deliveries travel on South Providence Road at the same time, a traffic volume of 

1,350 vehicles/hr will result. This increase in traffic will not result in any noticeable increased 

noise levels.

The types of equipment that would be used on the MURR site during construction would include 

those listed in Table 4–2 and additional equipment (e.g., track drill) to remove the existing paved 

surfaces. Noise emissions from equipment that will be used during construction are predicted to 

be in the 80- to 85-dBA range at a 50 ft (80 km) distance (FHWA 2006). At 0.14 km (0.09 mi), 

noise will attenuate to 61 to 65 dBA and at 0.76 km (0.47 mi), distance to the nearest residence, 

noise will attenuate to 46 to 51 dBA. However, because of the proximity to the existing MURR 

building from the construction site, noise levels at MURR can reach 80-85 dBA, which would be 

noticeable. Background noise levels are assumed to be 65 to 70 dBA. A 10-dBA increase is 

subjectively perceived as a doubling in loudness and almost always causes an adverse 

community response (FHWA 2011). Although building walls of the MURR laboratory building 

may dampen the construction equipment noise levels, the increase in noise levels would be 

noticeable. Given noise levels from construction equipment and distance to noise-sensitive 

receptors, the NRC staff estimates that noise impacts from construction at the MURR site would 

be SMALL to MODERATE.
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Operations

Noise sources during operation would be primarily from workforce and shipment vehicles. 

Noise from operating equipment would be contained inside buildings and is not anticipated to be 

audible outside the proposed NWMI building at the MURR site. Increased traffic volumes 

because of a daily workforce of 98 and 16 deliveries per week can increase noise emissions

along South Providence Road and will depend on the relative increase in traffic volume. 

Conservatively assuming that all worker vehicles and deliveries travel on South Providence 

Road at the same time, this will result in a traffic volume of 1,361 vehicles/hr. Sound levels 

increase at a rate of 3 dBA per doubling of traffic volumes and an increase of 3 dBA is barely 

noticeable. This increase in traffic from 1,246 vehicles per hour to 1,361 vehicles/hr will not 

result in noticeable noise levels.

Given that noise levels from operating equipment are not expected to be audible beyond the 

building facility and additional noise levels from worker and shipment vehicles are not 

anticipated to be noticeable, the NRC staff concludes that noise impacts during operation would 

be SMALL.

Decommissioning

Noise emissions during decommissioning would be similar to those generated during 

construction. Increased noise levels would occur from increased traffic volumes and from the 

use of equipment on site. A daily peak workforce of 81 and a total of 21 deliveries and 

shipments per week are anticipated during decommissioning. Sound levels increase at a rate of 

3 dBA per doubling of traffic volumes and an increase of 3 dBA is barely noticeable. 

Conservatively assuming that all worker vehicles and deliveries travel on South Providence 

Road at the same time, the additional traffic along South Providence Road should not be 

noticeable.

As discussed above, under construction, noise levels from construction equipment at MURR 

can reach 80 to 85 dBA, which would be noticeable. During decommissioning, equipment 

similar to construction activities would be used and similar noise levels are assumed during 

decommissioning activities. Therefore, given the expected noise levels during decommissioning 

and the distance to noise sensitive receptors, the NRC staff estimates that noise impacts from 

decommissioning at the MURR site would be SMALL to MODERATE.

5.2.2.3 Geologic Environment

Site Geology, Soils, and Seismic Setting

The alternative site for the proposed NWMI facility is in the University Research Park within the

existing MURR Center (NWMI 2016c). The MURR Center, and alternate site, are located within 

the Dissected Till Plains section of the Central Lowland province (MDNR 2002a). Landforms 

within this physiographic section are the product of glacial action as modified by post-glacial 

geomorphological processes, as further described in Section 3.3.1 of this EIS.

MURR and the University of Missouri campus are located in an area known locally as the 

Columbia dissected uplands (MU 2006). The MURR site is located on a relatively flat plain 

adjacent to a stream valley that was incised into the glacial strata. The MURR site lies at an 

elevation of approximately 615 ft (187 m) above mean sea level (MSL) (Figure 5–2).

While glacial drift deposits are prevalent in the eastern half of Boone County, residuum 

(weathered bedrock material) is the predominant bedrock cover over the western half of the 

County. The MURR site is mapped as residuum (unit J). This unit is a tan to reddish-brown 

gravelly clay and silty clay, which developed from limestone and shale bedrock. The total 

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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covered by a layer of loess and/or glacial drift. Across the University Research Park, mapping 

shows that the total depth of this cover is as much as 25 ft (7.6 m) deep (MGS 2016). Specific 

to the MURR site, these surficial deposits also likely include alluvium of Holocene age 

associated with Hinkson Creek (MU 2006).

The uppermost bedrock units underlying the site belong to the Osagean series of Mississippian 

age (345 to 359 million years ago). These rocks are characterized as very cherty, crystalline, 

and fossiliferous limestones (MU 2006). Geologic mapping shows that the specific bedrock unit 

beneath the site is Burlington-Keokuk limestone (MGS 2016). The Burlington Limestone is as 

much as 160 ft (49 m) thick in the Columbia area. This bedrock unit is relatively soluble and, 

where it outcrops at the surface, it is susceptible to karst development, as further described in 

Section 3.3.1 for the Discovery Ridge site (MU 2006). However, geologic mapping shows that 

the nearest karst features are approximately 3.5 mi (5.6 km) south of the MURR site 

(MGS 2016).

Older Devonian age limestones and sandstones are relatively thin or absent in the Columbia 

area; nevertheless, Ordovician age carbonate strata are well represented, including the 

Jefferson City Dolomite and the Rubidoux Formation. Cambrian age carbonates underlie the 

Ordovician strata and include the Eminence and Potosi Dolomites (MU 2006; Miller and 

Appel 1997).

The horizontal sedimentary strata underlying the MURR site exhibit little deformation, and the 

Columbia area is relatively free of faults, folds, and other major structural features (MU 2006). 

There are no mapped geologic faults or other significant geologic features within 5 mi (8 km) of 

the site. The closest geologic fault structure is the Fox Hollow fault, as further described in 

Section 3.3.1. The northern end of this fault is located approximately 6.5 mi (10.5 km) 

southeast of the MURR site. There has been no movement on this fault since the Paleozoic Era 

and it does not constitute an earthquake hazard. Evidence for active and recurrent faulting, 

along with associated seismic activity, can be found in eastern and southeastern Missouri and in 

southern Illinois, as further described in Section 3.3.1 of this EIS and referenced below. The 

most significant seismologic features are associated with the New Madrid Seismic Zone 

(MU 2006).

Geologic resources, encompassing rock and mineral (fuel and nonfuel) resources, from 

geologic strata in the Columbia area have historically included limestone and coal, as well as 

sand and gravel deposits, which are widely available, from glacial and floodplain materials 

throughout Boone County (MDNR 2001; USGS 2015c). A former limestone quarry is located 

about 0.4 mi (6 km) south of the MURR site and a former coal mining operation is located 

approximately 0.6 mi (1 km) southwest of the site (MGS 2016).

Soil unit mapping by the Natural Resources Conservation Service (NRCS) identifies the natural 

soils across the MURR site as predominantly Weller silt loam, bench, 2 to 5 slopes 

(NRCS 2016c). Where not otherwise mixed or replaced with fill material that may have been

placed in conjunction with the construction of MURR, soils in this mapping unit are mainly silt 

loams occupying stream terraces. They are moderately well-drained, deep soils that developed 

from parent materials consisting of loess deposits over stream alluvium. The depth to the water 

table in these soils generally ranges from 24 to 48 in. (61 to 122 cm) (NRCS 2016c).
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Figure 5–2. Topographic Map of the MURR Site and Vicinity

Source: Modified from USGS 2015a

Natural soils across the MURR site are rated as somewhat limited for building site development 

and excavation work primarily due to the depth to the saturated zone and clay shrink/swell 

potential. The soils have slight limitations due to instability of excavation walls (caving). The 

soils meet the classification criteria of prime farmland soils as defined in the Farmland 
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Protection Policy Act of 1981 (7 U.S.C. 4201 et seq.) and implementing regulations 

(7 CFR Parts 657, 658). However, because the site and vicinity is developed and otherwise 

committed to urban development, the site is exempt from Farmland Protection Policy Act 

provisions (7 CFR 658.2 and 658.3).

Northeast Missouri and the MURR site are located within a relatively stable region of the 

continent, as further described in Section 3.3.3. While the area is not immune to seismic 

activity, the intensities of Midcontinent earthquakes are generally mild, although they are usually 

felt over wide areas (MU 2006). Earthquake sources in southeast Missouri, associated with the 

New Madrid Seismic Zone, are the primary driver of earthquake hazard in northeast Missouri. 

The New Madrid Seismic Zone and the earthquake history for northeast Missouri, 

representative of the MURR site, are described in Section 3.3.3 of this EIS.

Over the last 40 years, a total of 99 earthquakes with a magnitude equal to or greater than 2.5 

have occurred within a radius of 200 mi (322 km) of the MURR site. The vast majority of these 

earthquakes had epicenters more than 90 mi (140 km) to the east and south in association with 

the Wabash Valley and New Madrid seismic zones, respectively. The closest of these events 

occurred on July 31, 2005 near Tipton, Missouri, approximately 25 mi (40 km) southwest of the 

MURR site. The earthquake had a magnitude of 3.3 and produced MMI III to IV (weak to light) 

shaking near the epicenter, but it was not generally felt north of the Missouri River into Boone 

County (USGS 2016c).

Section 3.3.3 of this EIS presents information on predicted earthquake ground motions across 

central Boone County based on the USGS’s latest seismic hazard mapping data. NWMI 

performed a preliminary seismic design analysis to assess the potential maximum earthquake 

ground motions in consideration of site-specific soil conditions (i.e., for a stiff soil profile (Site 

Class D)) (see Section 3.3.3). The NRC staff will further evaluate the potential maximum 

earthquake and other seismic design considerations in the safety evaluation report (SER)

related to the NWMI construction permit application.

Construction

Ground-disturbing activities associated with facility construction would have impacts on geologic 

and soil resources similar to those discussed for the Discovery Ridge site (Section 4.3.1). 

Earthwork requirements and the ease of excavation would generally be similar, with a few 

exceptions. To prepare the site for facility construction, NWMI would first need to remove 

existing hardscape including asphalt and concrete associated with a parking lot, walkways, and 

curb and gutter. It is also likely that some existing utility lines would need to be relocated. 

These activities would entail additional earthwork and could possibly lengthen the construction 

timeframe at this site. The site’s loamy, alluvial soils are typically suitable to build on and 

engineer (e.g., grade and compact). The shrink/swell potential of site soils is moderately 

favorable for site development purposes with only slight limitations and risk for impacting 

building foundations and concrete surfaces.

Excavations at the site could be prone to slumping because of the potential for saturated soils 

and seasonally high water table conditions, as similarly discussed for the Discovery Ridge site. 

These conditions could require the use of bracing in trenches and other measures 

(e.g., cofferdams) during construction of the below-grade portion of the facility. The potential for 

soil erosion and loss would be similar to the Discovery Ridge site. However, as described in 

Section 4.3.1, adherence to standard best management practices (BMPs) for soil erosion and 

sediment control and stormwater runoff management, and compliance with the provisions of a 

Land Disturbance Permit from the City of Columbia, would serve to minimize soil erosion and 

loss. In consideration of these points, the NRC staff finds that the impacts on the geologic 

environment from the construction of the NWMI facility at the MURR site would be SMALL.
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Operations

There would be no incremental impact on the geologic environment from facility operations at 

the MURR site. Following construction, exposed soils would no longer be subject to erosion

because they would lie beneath buildings or other impervious surfaces, with areas outside those 

areas restored to a vegetated or landscaped condition.

Regardless of the site location, the final design and construction of the NWMI facility would have 

to comply with all applicable building codes and standards, which provide for the evaluation of 

site geologic and soil conditions, including potential seismic hazards. Thus, the NRC staff 

concludes that the operational impacts associated with the geologic environment at the MURR 

site would be SMALL.

Decommissioning

Facility demolition and other ground-disturbing activities associated with decommissioning 

would have impacts on soils and underlying sediments and geologic strata similar to those 

described in Section 4.3.3 for the Discovery Ridge site. Site decommissioning activities would 

be conducted in accordance with a decommissioning plan submitted to the NRC and in 

compliance with applicable local, State, and Federal regulations and permits. Therefore, the 

NRC staff finds that the impacts on the geologic environment from facility decommissioning at 

the MURR site would be SMALL.

5.2.2.4 Water Resources

Surface Water Hydrology, Quality, and Use

The MURR site is located within the Hinkson Creek watershed. Hinkson Creek is a major 

tributary to Perche Creek, which flows to the Missouri River. The MURR site is located slightly 

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

) and roughly bisects the City of Columbia in a 

northeast to southwest direction, and it serves as the major stormwater drainage basin for the 

City of Columbia. Together with the MURR site, all the properties belonging to the University of 

Missouri drain either directly or indirectly to Hinkson Creek and ultimately to the Missouri River 

(MU 2006).

While no natural surface water drainages exist on the MURR site, a stormwater drainage 

system serves the MURR site and adjoining university properties. This system generally 

consists of an open system of swales and culverts (MU 2006). The MURR property drains 

generally south toward Hinkson Creek, which is located approximately 0.2 mi (0.3 km) south of 

the site.

From just south of the site (Figure 5–2), Hinkson Creek flows generally in a west to southwest 

direction over a sinuous course for approximately 7.6 stream mi (12.1 km) (4 linear mi (6.4 km)) 

from the MURR site to its confluence with the southward-flowing Perche Creek near the 

Columbia Regional Wastewater Treatment Plant (WWTP). Perche Creek continues flowing 

southwest before turning south and then southeast, paralleling the Missouri River, for a total of 

about 11 stream mi (17.7 km) before entering the river at a point approximately 8 mi (12.9 km) 

southwest of the MURR site.

The USGS maintains a gaging station on Hinkson Creek just downstream from the Highway 163 

bridge (Station 06910230) at South Providence Road, approximately 0.25 mi (0.4 km) southeast 

of the MURR site. The mean annual discharge measured at this site for the period of record 

(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/s) on April 30, 2009. For water 

year 2015, the mean discharge was 112.7 cfs (3.18 m3

/s). The mean 90-percent exceedance 
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flow is 0.4 cfs (0.011 m3

/s) for the period of record. The 90 percent exceedance flow is an 

indicator value of hydrologic drought. It signifies a rate of streamflow that is equaled or 

exceeded 90 percent of the time, as compared to the average flow for the period of record. 

Based on average monthly flow over the period of record at the station, August is the low-flow 

month, and April is the high-flow month for Hinkson Creek (USGS 2016d).

The Federal Emergency Management Agency has delineated the floodplain boundary for 

Hinkson Creek, which runs south of the site. The MURR site is mapped as outside the 500-year 

flood elevation. However, the location of the proposed NWMI facility site on the MURR site is 

located less than 500 ft (152 m) north of the delineated 100-year floodplain (base flood elevation 

605 ft (184 m)) (FEMA 2011b). The University of Missouri (MU 2006) states that the existing 

MURR laboratory building is about 200 ft north of the 100-year floodplain at its closest point.

In accordance with Section 303(c) of the Federal Water Pollution Control Act (i.e., Clean Water 

Act (CWA)) of 1972, as amended, states have the primary responsibility for establishing, 

reviewing, and revising water quality standards for the Nation’s navigable waters. As further 

discussed in Section 3.4.1.2, the State of Missouri, like other states, has established water 

quality standards, numeric criteria, and associated designated use categories for all waters of 

the State, including jurisdictional wetlands. In summary, all perennial rivers and streams, 

streams with permanent pools, and lakes and reservoirs that intersect the flow lines of perennial 

rivers and streams are designated for the following beneficial uses: aquatic habitat protection, 

human health protection, whole body contact recreation, and secondary contact and livestock 

and wildlife protection and irrigation (10 CSR 20-7.031). These uses apply to Hinkson Creek 

and other major streams within a 5-mi (8-km) radius of the MURR site, including Perche Creek.

CWA Section 303(d) requires states to identify all “impaired” waters for which effluent limitations 

and pollution control activities are not sufficient to attain water quality standards in such waters. 

As more fully described in Section 3.4.1.2 of this EIS, states prepare a 303(d) “list” that 

comprises those water quality limited stream segments that require the development of total 

maximum daily loads (TMDLs) to assure future compliance with water quality standards. Once 

established, states implement TMDLs through watershed-based programs, primarily through the 

National Pollutant Discharge Elimination System (NPDES) permit program in accordance with 

CWA Section 402.

The lower reaches of Hinkson Creek downstream of the MURR site are included in the State of 

Missouri’s 303(d) list (MDNR 2014a, 2015a). The Missouri Department of Natural Resources

(MDNR) continues to list Hinkson Creek as impaired for whole body contact recreation due to 

water-borne E. coli bacteria. The reason for listing is impairment of the beneficial use due to 

nonpoint source runoff.

Groundwater Hydrology, Quality, and Use

Groundwater beneath the MURR site and the south Columbia area of Boone County occurs in 

unconsolidated and consolidated water-bearing deposits (aquifers). USGS broadly recognizes 

a surficial aquifer system and two bedrock aquifer systems in northeast Missouri, as described 

in Section 3.4.2.1. In general, the hydrogeology of the south Columbia area and the MURR site 

is similar to the Discovery Ridge site.

The overlying glacial drift, where present, produces only limited quantities of water in the 

Columbia area. Still, both the Mississippian and the underlying Cambrian-Ordovician aquifer 

systems are present beneath the site. Within the Mississippian system, the Burlington 

Limestone yields mainly hard water through shallow wells that is adequate to support rural 

domestic uses. Within the upper Ordovician age strata, the Jefferson City Formation is the 

principal water-bearing unit in the Columbia area. This formation averages 400 ft (122 m) thick 
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and produces moderate quantities of water. It has been the most widely used unit for rural 

domestic supply (MU 2006).

Most notably, the Ordovician and Cambrian bedrock units, particularly the sandstone and 

dolomitic units, yield considerable water to deep wells in the Columbia area. These units are 

part of the Cambrian-Ordovician aquifer system (see Section 3.4.2.1). This system is about 

1,300 ft (400 m) thick in the Columbia area, at depths ranging from approximately 150 to 400 ft 

(46 to 122 m) below ground surface (bgs). Two of the deepest formations of significance are 

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

/min)) (MU 2006). The 

NRC staff’s review of available MDNR well logs for the area within a 2-mi (3.2-km) radius of the 

MURR site indicate that the depth to the Ordovician strata is marked by the Cotter Dolomite at 

depths of approximately 200 to 300 ft (60 to 90 m) bgs (MGS 2016; MDNR 2016e).

The MDNR maintains extensive geospatial data, including data extracted from well driller logs 

submitted to the State. Available MDNR data indicate that the static water level in the 

uppermost aquifer across the south Columbia area ranges between 600 and 625 ft (183 and 

190 m) MSL. The approximate depth to groundwater (as measured from the land surface) in 

the area ranges between 90 and 100 ft (27 to 30 m) bgs (MGS 2016). Depth to groundwater 

would be less within the incised stream valleys, such as Hinkson Creek. In addition, the NRC 

staff expects that shallow groundwater also occurs within the stream alluvium and other 

unconsolidated sediments in proximity to Hinkson Creek, which runs just to the south and 

southwest of the site.

Groundwater is used extensively and almost exclusively across Boone County, as summarized 

in Section 3.4.2.2. Historically, the City of Columbia relied on a system of deep wells for public 

water supply. Declines in well production and other factors prompted the City to install a new 

well field in 1972 within the alluvial aquifer of the Missouri River floodplain (known as the 

McBaine Bottoms) (MU 2006; City of Columbia and MDNR 2013). The well field is located 

approximately 7 mi (11 km) southwest of the MURR site (MGS 2016). This production system 

consists of 15 alluvial wells installed to a depth of about 110 ft (33 m) in the bottom alluvium. 

The system has a total groundwater production capacity of 30 million gallons per day (mgd) 

(113,560 cubic meters per day (m3

/day)). Groundwater is pumped to the City’s nearby McBaine 

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

/day) 

(City of Columbia 2016c).

The City maintains four deep wells as emergency backup water sources (MU 2006; City of 

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

/min) from the 

Eminence and Potosi Dolomites. The closest of these wells is approximately 2.3 mi (3.7 km) 

northwest of the existing MURR laboratory building (MU 2006).

The University of Missouri, through its Campus Facilities Department, maintains its own system 

of deep wells to supply potable water across the university, including providing water supply to 

the existing MURR Center. Five supply wells comprise the production system. These wells 

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

/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/day) 

(MU 2015).
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Construction

Facility construction activities at the MURR site would not have any direct impact on surface 

water resources because no natural watercourses originate within the boundaries of the site. 

Stormwater drainage ditches deliver stormwater from the site south toward Hinkson Creek, 

which is located approximately 0.2 mi (0.3 km) south of the site. As at the Discovery Ridge site, 

the potential does exist for shallow groundwater to occur south of the existing MURR main 

building and beneath the proposed NWMI facility site. This would require groundwater 

dewatering during construction, as further described and evaluated in Section 4.4.2.1. If NWMI 

were to select this alternative site, it would commission site-specific geotechnical and hydrologic 

studies to assess shallow groundwater conditions and to guide any necessary construction 

accommodations and final facility design.

As discussed above in Section 5.2.2.3 for construction and detailed in Section 4.3.1.1 for the 

Discovery Ridge site, ground-disturbing activities would be subject to a Land Disturbance Permit 

from the City of Columbia as well as a State of Missouri NPDES general permit (i.e., Missouri 

State Operating Permit MO-RA) for the discharge of stormwater from land-disturbance sites. 

The development application package for the Land Disturbance Permit would require NWMI to 

develop and implement a soil erosion and sediment control plan and a stormwater management 

plan. These plans entail the implementation of construction-related BMPs for soil erosion and 

sediment control and stormwater pollution prevention during site development, facility 

construction, and for post development. Further, the NPDES general permit similarly requires 

the development and implementation of a stormwater pollution prevention plan (SWPP) to 

prevent the introduction of sediment and other pollutants in stormwater discharges.

Under CWA Section 401, an applicant for a Federal license or permit to conduct any activities, 

including facility construction or operation, that may cause a discharge into navigable waters is 

required to provide the Federal licensing agency with a certification from the state or agency 

having jurisdiction in which the discharge would originate. This water quality certification 

signifies that discharges from the project or facility to be licensed by the Federal agency will 

comply with CWA requirements and will not cause or contribute to a violation of state water 

quality standards. A Federal agency cannot issue a license or permit to an applicant until the 

required certification is provided, or the responsible state or agency has waived the 

requirement. The NRC recognizes that some NPDES-delegated states explicitly integrate their 

401 certification process with NPDES permit issuance. The State of Missouri regulations for 

administering its water quality certification process are at 10 CSR 20-6.060.

The only regulated direct discharges from the proposed facility involve stormwater associated 

with construction activity. As referenced above, NWMI would obtain coverage under a 

State-issued NPDES general permit for such discharges. Permit provisions are intended to 

ensure that the State’s water quality standards are met. NWMI has stated that no State 

certification is required under CWA Section 401 (NWMI 2015a). NWMI also has stated that it 

would seek a waiver from the State (NWMI 2015c). However, because the NRC cannot issue a 

construction permit without the required certification, NWMI must provide the NRC with either a 

401 certification from the State of Missouri, a waiver, or other State documentation that a 

Section 401 certification is not necessary. During construction, water would be required for 

such uses as dust control, soil compaction, as well as to meet the drinking and sanitary needs 

of the construction workforce during the construction period. NWMI would not use surface 

water or onsite groundwater to support facility construction at the site. Instead, the NRC staff 

expects that the University of Missouri campus water utility (Campus Facilities Department) that 

currently provides water to the existing MURR Center would supply water to the NWMI facility 

site. Water could be supplied during construction by trucking it to the point of use or through a 

portable water tap from a nearby service line or hydrant, until a permanent water service line is 
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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

/day). This projected daily 

demand is a very small percentage (i.e., about 0.34 and 0.12 percent) of the University’s 

existing demand and available production capacity, respectively. Wastewater generation would 

be limited to sanitary waste from the construction workforce and would likely be accommodated 

using portable restroom facilities.

No natural surface water features occur on the site, and NWMI would not divert or withdraw 

surface water or onsite groundwater during construction. NWMI would also be subject to 

compliance with City and State permits, including an NPDES general permit for the discharge of 

stormwater from a land-disturbance site. Therefore, the NRC staff concludes that the impacts 

on surface water and groundwater hydrology, water quality, and water use from the construction 

of the NWMI facility at the MURR site would be SMALL.

Operations

Normal facility operations would not have any direct impact on surface water or groundwater 

hydrology or quality. Stormwater runoff from the proposed NWMI facility at the MURR site 

would also be managed by an engineered stormwater management system, including 

necessary detention/retention structures, constructed and operated in compliance with 

applicable local, State, and Federal stormwater management permits, plans, procedures, and 

practices, as discussed in Sections 4.4.1.2 and 4.4.2.2 for the Discovery Ridge site.

There would be no radioactive liquid effluents released from the facility because the RPF portion 

of the facility is designed to have zero liquid discharge. NWMI would conduct all material, 

chemical, and waste handling activities within the confines of the NWMI facility, precluding any 

releases to the environment, including soils and groundwater. The only liquid waste stream 

discharged from the facility would be sanitary wastewater at an average rate of approximately 

4,570 gpd (17,300 Lpd). NWMI would discharge this wastewater to the City of Columbia

Sanitary Sewer Utility, which also receives effluent from the existing MURR Center (MU 2006). 

The Columbia Regional WWTP provides treatment of the sanitary wastewater discharged into 

the sewer system, and the WWTP has excess treatment capacity available. The effluent would 

be required to meet the system’s influent acceptance and treatment criteria, as well as NRC’s 

regulations at 10 CFR 20.2003 (see Section 4.4.1.2).

Facility operations would require an average of 5,045 gpd (19,100 Lpd) of water, equivalent to 

0.005 mgd (18.9 m3

/day), as previously described in Section 4.4.2.2 for the Discovery Ridge 

site. A service connection from the University of Missouri campus water utility would provide 

water to the NWMI facility. Similar to the projected water needs for construction, the NWMI 

facility’s projected operational water needs are a small percentage (i.e., about 0.29 and 

0.1 percent) of the University’s existing water supply demand and available production capacity, 

respectively.

The proposed NWMI facility would not divert or withdraw surface water or onsite groundwater to 

support facility operation at the MURR site because the University of Missouri’s campus utility 

would provide water supply. There would be no discharge of industrial or radiological effluents 

to surface water or groundwater, and the NWMI facility operations would need to comply with 

local, State, and Federal stormwater management permits, plans, procedures, and practices. 

Accordingly, the NRC staff concludes that the impacts on surface and groundwater hydrology, 

water quality, and water use from the operation of the NWMI facility at the MURR site would be 

SMALL.
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Decommissioning

Facility decontamination, demolition, and site-restoration activities would be similar, regardless 

of the site, with the potential magnitude of the impacts on surface water and groundwater similar 

to those discussed for construction. The NRC staff expects that a State-issued NPDES general 

permit would be required for the discharge of stormwater from land-disturbance sites. NWMI 

would conduct site activities in accordance with appropriate BMPs and would observe waste 

handling and pollution prevention practices and response procedures during decommissioning, 

such that no materials or contaminants are released to soils, surface water, or underlying 

groundwater.

As previously referenced for the Discovery Ridge site (see Section 4.4.2.3), NWMI would 

conduct decommissioning work and activities in accordance with a decommissioning plan 

submitted to the NRC. NWMI would be required to conduct necessary surveys of the soils and 

subsurface to comply with the NRC’s radiological criteria for license termination in 

10 CFR Part 20, Subpart E. The NRC staff also expects that NWMI would sample soils and 

other media as necessary in accordance with other required local and State permits and 

approvals to ensure that no nonradiological contamination remains in excess of action levels.

Some water would be required for dust control and soil compaction during decommissioning 

(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

/day) during the 24-month 

decommissioning period. The NRC staff assumes that the University of Missouri campus water 

utility would also supply water for decommissioning. The projected water volume is less than 

the volume required for facility construction, as discussed above, and the impacts on supply 

capacity would similarly be negligible.

Given that no natural surface water features occur on the MURR site, that water requirements 

would be minimal, and that NWMI would develop and implement stormwater pollution 

prevention and spill response procedures as part of local and State permit requirements for 

ground-disturbing activities, the NRC staff concludes that the impacts on water resources from 

facility decommissioning would be SMALL.

5.2.2.5 Ecological Resources

The MURR facility complex consists of 7.5 ac (3.0 ha) of existing buildings, parking lots, a few 

deciduous trees, and some ornamental grasses and shrubs (NWMI 2015a and NWMI 2016c; 

NRC 2015b). The MURR site provides habitat for birds, mammals, amphibians, reptiles, and 

other wildlife tolerant of human-modified landscapes, and frequent disturbances from human 

activity. Birds and wildlife may use the MURR site to feed on vegetation, as a temporary resting 

location, or while traveling among other habitats. Therefore, species would likely be similar to 

those described in Section 3.5.3 for the proposed Discovery Ridge site. Wildlife that require 

dense stands of trees, native plants, shrubs, or uncultivated grasses would not use the 

proposed site because of the lack of forested areas, wetlands, and native grasslands.

No water bodies or aquatic habitats exist within the boundaries of the MURR site. The MURR 

site drains generally south toward Hinkson Creek, which is located approximately 0.2 mi 

(0.3 km) south of the site.

The NRC staff determined that the Federal and State-listed species that have the potential to 

exist within the MURR site are the same as those that have the potential to occur on the 

proposed Discovery Ridge site. The NRC staff made this determination based on FWS’s online 

database (FWS 2016), the Missouri Department of Conservation’s (MDC’s) description of 

State-listed species (MDC 2000a, 2000b, 2016b), and the NWMI ER (NWMI 2015a). The NRC 

staff reviewed the habitat requirements for these species and determined that no suitable 
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habitat for any of the State endangered or Federally listed species occur on the MURR site 

(see Table 3–11). The NRC staff did not observe any Federally listed or State-endangered 

species on the MURR site during the site audit (NRC 2015b).

The FWS also administers the Migratory Bird Treaty Act (16 U.S.C. 703–712), which prohibits 

anyone from taking native migratory birds or their eggs, feathers, or nests. FWS (2015a, 2016) 

determined that the same migratory birds likely use the proposed Discovery Ridge site and the 

MURR site given their proximity to one another and because both sites have been heavily 

modified by human activities. In the vicinity of the site, migratory birds rely on riparian, forested, 

grassland, and wetland habitats as important areas for foraging, resting, avoiding predators, 

and, for some species, breeding. On the MURR site, migratory birds likely use trees for resting 

and possibly for limited foraging.

Construction

Construction of the NWMI facility would occur within a paved parking lot that provides minimal, if 

any, habitat to species highly tolerant of human activity (NWMI 2015a). Noise from construction 

activities could disturb birds and wildlife. In response to such disturbances, birds and wildlife 

could move out of the immediate area and find adequate, similar habitat within the vicinity.

During construction, bird collisions with construction equipment and the new facility could result 

in mortality from the presence of tall structures (e.g., stacks or cranes) and artificial night lighting 

during nighttime construction. The size of structures and the likelihood of mortality from bird 

collisions would be similar to that described in Section 4.5 for the proposed Discovery Ridge 

site. In that analysis, the NRC staff determined that impacts from bird collisions would be 

negligible and unlikely to affect local or migratory populations, based on previous reviews of bird 

collisions at nuclear power plants that are similar or larger in height and size than the proposed 

NWMI facility.

Construction at the MURR site is not expected to result in any direct impacts on aquatic 

resources, such as habitat loss, because no aquatic resources would be within the footprint of 

the proposed facility or the construction laydown areas. Runoff from the site could affect offsite 

aquatic resources by increasing turbidity or introducing various chemicals or other pollutants. 

However, impacts on aquatic resources are expected to be minimal because of the distance to 

Hinkson Creek, and NWMI would be required, in its stormwater permit, to use appropriate soil

erosion and sediment control BMPs.

Given that construction would not permanently or temporarily affect any high-quality habitats, 

such as grasslands, undisturbed forests, or wetlands; that permanently and temporarily affected 

habitats are abundant within the region; that mortality from bird collisions is expected to be 

negligible; and that no State-endangered or Federally listed species are likely to occur on the 

site, the NRC staff concludes that impacts on ecological resources during construction of the 

proposed NWMI facility at the MURR site would be SMALL.

Operations

During operations, impacts on ecological resources could result from bird collisions, herbicide 

applications for landscape maintenance activities, elevated noise levels, and increased turbidity 

or introduction of pollutants from runoff. As described in Section 4.5, mortality from bird 

collisions is expected to be negligible, given that the tallest structure would be a stack 

approximately 75 ft (23 m) tall. Disturbance from daily activities, herbicide applications, or 

elevated noise levels is likely to have minimal impacts on wildlife and plant species, given that 

the species identified at the MURR site are tolerant of disturbance, because of current 

operations at the existing research reactor and other nearby educational facilities. In response 
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to any disturbances during operations, birds and wildlife could move out of the immediate area 

and find adequate, similar habitat within the vicinity.

Operation of the facility is not expected to result in any direct impacts on aquatic resources, 

because wastewater would be not be discharged to any waterbody (NWMI 2015a). Indirect 

impacts during operations could include runoff that may contain sediments, contaminants from 

road and parking surfaces, or herbicides. However, as described above, impacts on aquatic 

resources are expected to be minimal because of the distance to Hinkson Creek, and NWMI 

would be required, in its stormwater permit, to use appropriate soil erosion and sediment control 

BMPs.

Given that mortality from bird collisions is expected to be negligible, that habitat disturbances 

during operations would be minimal, that any disturbed wildlife could find similar habitat in the 

vicinity, that BMPs would be required in the NWMI stormwater permit, and that no Federally or 

State-listed species occur on the MURR site, impacts on ecological resources during operations 

of the proposed NWMI facility at the MURR site would be SMALL.

Decommissioning

Decommissioning activities would have similar impacts on those that occur during construction. 

For example, NWMI would use construction equipment to dismantle large buildings, which could 

result in disturbances to wildlife and birds and potential runoff to nearby water bodies. In 

addition, some land on the site could be used as staging areas for the equipment and to 

conduct certain dismantling activities. As described above, if noise or other activities disturb 

birds or wildlife, similar habitat is available in nearby offsite areas. No surface water would be 

used during decommissioning, and NWMI would develop and implement spill prevention and 

response procedures as part of State permit requirements for ground-disturbing activities. 

Therefore, impacts during decommissioning of the proposed NWMI facility at the MURR site are

expected to be SMALL.

5.2.2.6 Historic and Cultural Resources

The general cultural background and chronological sequence of human occupation at the 

MURR site and vicinity would be the same as that described for the Discovery Ridge Research 

Park site in Section 3.6.1. The NWMI facility would be located on previously disturbed land 

adjacent to the south side of the existing University of Missouri Laboratory and Reactor 

Containment Buildings, colloquially known as the “Laboratory Building” (MU 2010; 

NWMI 2015c). The Laboratory Building was originally constructed in 1964 and is located on a 

7.5 ac (3 ha) plot of land within the larger University Research Park, an 84 ac (34 ha) tract 

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

) of fill 

was deposited on the south and central portions of the site. Several additions and a new 

building have subsequently been constructed at this location (MU 2006, 2010).

A review of databases maintained by the National Park Service indicates that there are 

50 properties listed on the National Register of Historic Places (NRHP) in Boone County, with 

the vast majority of them located in and around Columbia. The nearest property on the NRHP 

list is the Sanford F. Conley House, which is located on the University of Missouri main campus 

about 1 mi (1.6 km) north-northeast of the existing MURR Center (MU 2006, 2010). The view 

from the Sanford F. Conley House of the MURR site is obstructed by trees and campus 

properties. In 2010, during the MURR operating license renewal review, the Missouri SHPO 

informed the NRC that MURR is also eligible for inclusion in the NRHP (MDNR 2010).

No archeological survey was commissioned by NWMI for the MURR site. However, a review of 

state archaeological records conducted by the University of Missouri in 2010 found no evidence 
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of other archaeological sites on the 7.5 ac (3 ha) MURR site. The nearest recorded 

archaeological site was identified approximately 1,000 ft (300 m) northeast of the existing 

MURR Center (MU 2010).

Construction

Because the Missouri SHPO has determined that MURR is eligible for listing on the NRHP, it is 

considered a historic property as defined under 36 CFR 800.16(l). Construction of the proposed 

NWMI facility at the MURR site would occur on previously disturbed, paved and open space 

land currently in industrial use. The proposed NWMI facility would be designed to blend in with 

the architecture of the existing MURR facilities (see Section 5.2.2.1). Nonetheless, construction 

could result in an adverse effect if it is found to alter the historic characteristics that qualify 

MURR for inclusion on the NRHP (36 CFR 800.5(a)(1)). However, any adverse effects could be 

minimized or mitigated because NWMI has indicated that the proposed new facility would be 

located and designed to blend in with the historic fabric of the MURR site.

Because no other archaeological sites or evidence of cultural resources have been identified 

during previous archaeological reviews at the MURR site, cultural resources are not likely to be 

impacted by the construction of the proposed NWMI facility. Construction of the NWMI facility 

would also have little or no visual impact on other historic properties. The nearest NRHP-listed

property, the Sanford F. Conley House, is about 1 mi (1.6 km) away to the north-northeast, and 

its view is obstructed by trees and campus properties. 

Operations

As previously discussed, MURR is considered a historic property as defined under 

36 CFR 800.16(l) and is eligible for listing on the NRHP. However, operation of the proposed 

NWMI facility at the MURR would not result in additional adverse impacts to the historic property 

beyond those incurred from construction. Because no other archaeological sites or evidence of 

cultural resources have been identified during previous archaeological reviews, cultural 

resources would not likely be impacted during NWMI facility operations at the MURR site. The 

completed NWMI facility would also have little or no visual impact. The nearest NRHP-listed

property, the Sanford F. Conley House, is about 1 mi (1.6 km) away to the north-northeast, and 

its view is obstructed by trees and campus properties. 

Decommissioning

Decommissioning activities would be similar to construction activities because they would 

involve heavy equipment to dismantle buildings and remove roadway and parking facilities. As 

previously discussed, MURR is considered a historic property as defined under 

36 CFR 800.16(l) and is eligible for listing on the NRHP. Decommissioning of the proposed 

NWMI facility at the MURR could therefore result in an adverse effect if it is found to alter the 

historic characteristics that qualify MURR for inclusion on the NRHP (36 CFR 800.5(a)(1)). 

However, such adverse effects would likely be temporary in nature and would diminish once

decommissioning is complete.

Because no other archaeological sites or evidence of cultural resources have been identified 

during previous archaeological reviews at the MURR site, cultural resources would not likely be 

impacted during the decommissioning of the NWMI facility. Decommissioning of the NWMI 

facility would also have little or no visual impact on other historic properties. The nearest 

NRHP-listed property, the Sanford F. Conley House, is about 1 mi (1.6 km) away to the 

north-northeast, and its view is obstructed by trees and campus properties.
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5.2.2.7 Socioeconomics

The MURR site and the Discovery Ridge site share the same socioeconomic ROI. Both are 

located in the City of Columbia, Boone County, Missouri. The number of workers needed to 

construct, operate, and decommission the proposed NWMI facility at the MURR site would be 

the same or similar. The description of the affected environment and the socioeconomic 

impacts of constructing, operating, and decommissioning the proposed NWMI facility at the 

MURR site would be the same as described for the Discovery Ridge site in Sections 3.7 

and 4.7. Therefore, the socioeconomic impacts from constructing, operating, and 

decommissioning the proposed NWMI facility at the MURR site would be SMALL.

5.2.2.8 Human Health

Construction

Construction of the proposed NWMI facility at the MURR site would be essentially the same as 

construction at the Discovery Ridge site. There would be no significant differences in the design 

of the RPF building of the facility, with the exception of a below-grade corridor constructed 

between the RPF building of the facility and the existing MURR basement (NWMI 2015a,

2016c). The MURR basement is an area is which construction workers could potentially be 

exposed to radiation. Construction workers working in this area would be considered 

occupational radiation workers, and radiological controls and monitoring would be put into place 

to protect construction workers and to ensure that construction workers’ occupational worker 

dose would be maintained within 10 CFR Part 20 limits; however, NWMI expects that, due to 

the controls used, no measureable radiation dose would be received by the construction 

workers (NWMI 2016c). Construction workers for a facility at the MURR site would be exposed 

to similar physical occupational hazards as construction workers at the Discovery Ridge site, 

and any chemical exposure to workers or members of the public would also be similar. All 

occupational or material hazards would be controlled to ensure compliance with all applicable 

Federal and State regulations (NWMI 2015a). In Section 4.8.1 of this EIS, the NRC staff 

concluded that the radiological and nonradiological human health impacts from construction of 

the proposed NWMI facility at the Discovery Ridge site would be SMALL. Because there are no 

significant differences in construction or facility design except for the below-grade corridor, and 

because any potential hazards associated with construction would continue to be subject to 

Federal and State of Missouri regulations, the NRC staff concludes that the human health 

impacts from construction of the proposed NWMI facility at the MURR site would also be 

SMALL.

Operations

The operation of the proposed NWMI facility at the MURR site would also be essentially the 

same as operation at the Discovery Ridge site.

Radiological human health factors associated with an NWMI facility at the MURR site, including 

radiation sources, radioactive effluents, worker doses, and dose mitigation measures, would be 

the same as they would be for an NWMI facility at the Discovery Ridge site (NWMI 2015a). As 

stated in Section 4.8.2.1, NWMI estimated that the dose to the maximally exposed offsite 

member of the public from radioactive effluents emitted during operation of the proposed facility 

at the Discovery Ridge site would be 3.6 millirem (mrem) per year. This dose would be received 

by an individual located at the site boundary, 30 ft (9.1 m) from the facility stack at the Discovery 

Ridge site (NWMI 2016a). NWMI expects that the nearest distance to the site boundary from 

the facility stack would not vary by more than a few meters compared with the Discovery Ridge 

site, and that the dose to a member of the public at the site boundary for routine radioactive 

effluent releases would not change significantly for the MURR alternative site relative to the 
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Discovery Ridge site (NWMI 2016c). A facility at the MURR site would continue to be subject to 

the NRC’s dose limits in 10 CFR Part 20.

Due to the proximity of an NWMI facility at the MURR site to MURR, the NRC staff assumes 

that no public highway transportation of unirradiated or irradiated LEU targets between the 

NWMI facility and MURR would be needed. However, the NRC staff assumes that doses from 

transportation of targets between the NWMI facility and the other two research reactors (OSTR 

and a third reactor) would be very similar for an NWMI facility located at either site due to the 

proximity of the MURR site to the Discovery Ridge site.

Nonradiological human health factors associated with an NWMI facility at the MURR site, 

including chemicals and hazardous materials present at the site, nonradioactive effluents, 

potential chemical exposures to workers and/or the public, physical occupational hazards, and 

mitigation measures for nonradiological human health impacts, would also essentially be the 

same as they would be for an NWMI facility at the Discovery Ridge site. All occupational or 

material hazards would be controlled to ensure compliance with all applicable Federal and State 

regulations (NWMI 2015a).

In Section 4.8.2 of this EIS, the NRC staff concluded that the radiological and nonradiological 

human health impacts from operation of the proposed NWMI facility at the Discovery Ridge site 

would be SMALL. Because there are no significant differences in facility design or operation, 

and because any potential radiological or nonradiological hazards associated with operation 

would continue to be subject to Federal and State of Missouri regulations, the NRC staff 

concludes that the human health impacts from operation of the proposed NWMI facility at the 

MURR site would also be SMALL.

Decommissioning

Since the design and operation of the proposed NWMI facility at the MURR site would be similar 

to that at the Discovery Ridge site, and the general characteristics of the two sites are also 

similar, the NRC staff expects that the decommissioning of the proposed facility at the MURR 

site would also be similar to that at the Discovery Ridge site. Any occupational, chemical, or 

radiological hazards to workers and/or the public would be similar, and would be required to be 

in compliance with all applicable Federal and State of Missouri regulations. In Section 4.8.3 of 

this EIS, the NRC staff concluded that the radiological and nonradiological human health 

impacts from decommissioning of the proposed NWMI facility at the Discovery Ridge site would 

be SMALL. Because there would be no significant differences in facility decommissioning, and 

because any potential radiological or nonradiological hazards associated with decommissioning 

would continue to be subject to Federal and State of Missouri regulations, the NRC staff 

concludes that the human health impacts from decommissioning of the proposed NWMI facility 

at the MURR site would also be SMALL.

5.2.2.9 Waste Management

Construction, operations, and decommissioning of the proposed NWMI facility at the MURR site 

would be essentially the same as at the Discovery Ridge site. The NRC staff expects that there 

would be no physical differences between the design of the facilities that would change the 

types or volumes of radiological or nonradiological wastes generated during construction, 

operations, or decommissioning of the proposed facility at the MURR site. The disposal 

pathways for radioactive waste produced by an NWMI facility at the MURR site would be the 

same as for a facility at the Discovery Ridge site (NWMI 2016a). The distance that radioactive 

waste produced during operations or decommissioning would need to be transported to reach a 

disposal site would be effectively the same for either site. In addition, because of the proximity 

of the MURR site to the Discovery Ridge site and the similar waste disposal infrastructure, the 
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NRC staff expects disposal pathways for nonradioactive waste (including hazardous waste) at 

the MURR site to be similar to the Discovery Ridge site. All waste management activities at an 

NWMI facility at the MURR site would be required to comply with all applicable Federal, State, 

and local regulations.

In Section 4.9 of this EIS, the NRC staff concluded that impacts from radioactive and 

nonradioactive waste management during construction, operations, and decommissioning of the 

proposed NWMI facility at the Discovery Ridge site would be SMALL. Because there would be 

no significant differences in waste management, and because waste management would 

continue to be subject to Federal, State, and local regulations, the NRC staff concludes that the 

impacts from waste management of the proposed NWMI facility at the MURR site during 

construction, operations, and decommissioning would also be SMALL.

5.2.2.10 Transportation

Affected Environment

Figure 5–1 shows major roads and transportation features in the vicinity of the MURR site. The 

MURR site is located within the City of Columbia limits. Research Park Drive provides direct 

access to the site.

Research Park Drive intersects with old Route K and South Providence Road (Missouri 

Route 163), a four-lane roadway in Boone County, about 0.15 mi (0.25 km) to the east. 

The MURR site has direct easy access to Route 163. Route 163’s northern terminus is at 

U.S. Interstate 70/U.S. Route 40 (I-70/US 40) in Columbia; its southern terminus is at 

U.S. Highway 63 south of Columbia. Route 163 also intersects with Stadium Boulevard 

(Missouri Route 740) approximately 0.6 mi (1 km) to the north. Route 740 intersects with 

U.S. Highway 63, 2.3 mi (3.7 km), to the east. U.S. Highway 63 continues to Jefferson City, 

Missouri, 31 mi (50 km) to the south. U.S. Interstate 70 proceeds approximately 125 mi 

(201 km) east to St. Louis, Missouri, and 125 mi (201 km) west to Kansas City, Missouri. 

Current average daily traffic volumes for nearby roads is listed in 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
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Impact Analysis

This section describes potential transportation impacts during the construction, operations, and 

decommissioning of the proposed NWMI facility at the MURR site. The impact analysis 

considers changes in traffic volumes on the existing roadway network. The number of workers

and truck deliveries and shipments needed to construct, operate, and decommission the NWMI 

facility at the MURR site would be the same or similar as the Discovery Ridge site.

Construction

Similar to construction at Discovery Ridge, transportation impacts would be caused by an 

increase in commuter vehicles and construction trucks on local roads. Construction workers

would arrive via site access roads and traffic volumes on these roads would increase during 

shift changes. In addition, trucks would deliver construction equipment and material to the work 

site and remove construction waste material, thus adding to traffic volumes on site access 

roads. The increase in vehicular traffic would peak during certain hours of the day (e.g., shift 

changes), resulting in temporary levels of service impacts and possible delays at intersections.

During construction, an average daily workforce of 38 workers would be commuting to and from 

the work site for 17 months. During peak construction, up to 82 workers could be commuting 

daily to the construction site. In addition, an average of 20 trucks per week (4 trucks per day) 

would deliver construction equipment and material to the work site. An additional 1 truck per 

week would remove construction waste (NWMI 2015a, 2015c).

Due to the small size of the average daily workforce, the low number of daily truck deliveries 

and shipments combined with the short duration of construction (17 months) and easy access to 

Route 163, there would be little if any noticeable traffic volume-related level of service impacts. 

Therefore, transportation impacts during the construction of the proposed NWMI facility at the 

MURR site would be SMALL.

Operations

Transportation impacts occurring during operation of the proposed NWMI facility would be 

caused by an increase in commuter vehicles and delivery trucks on local roads. Operations 

workers would arrive via site access roads and traffic volumes on these roads would increase 

during shift changes. In addition, trucks would deliver production material, ship products, and 

remove waste material, thus adding to the traffic volumes on site access roads. The increase in 

vehicular traffic would peak during certain hours of the day (e.g., shift changes), resulting in 

temporary levels of service impacts and possible delays at intersections.

During operations, 98 workers would be commuting to and from the MURR site (NWMI 2015a). 

In addition, an average of 2 to 4 trucks per week would deliver nonradioactive material; an 

average of 2 to 3 trucks per week would deliver irradiated LEU targets; and another two trucks 

per year would deliver fresh LEU (NWMI 2015a, 2016a).

In addition, outbound truck traffic would include the following:

an average of 1 truck shipment per week of LEU targets to irradiation facilities,

an average of 2 shipments per week of medical isotope product through the 

Columbia Regional Airport,

an average of 3 to 4 shipments per week of waste, and

an average of 2 truck shipments per year of take back LEU (NWMI 2015c, 2016a).

Medical isotope product shipments to customers would be transported from the NWMI facility by 

truck to the Columbia Regional Airport, over 13 mi (21 km) away. Radioactive and 
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nonradioactive waste would also be transported by common truck carrier from the NWMI facility 

to an offsite storage, treatment, or disposal facility.

The relatively small size of the workforce and low number of daily truck deliveries and 

shipments would generate little if any noticeable traffic volume-related level of service impacts. 

Therefore, given the size of the operations workforce, the number of trucks, and easy access to 

Route 163, transportation impacts during NWMI facility operations at the MURR site would be 

SMALL.

Decommissioning

Transportation impacts occurring during decommissioning would be caused by an increase in

commuter vehicles and trucks on local roads. Decommissioning workers commuting to the 

work site would arrive via site access roads and traffic volumes on these roads could increase 

during shift changes. In addition, trucks would deliver equipment and material to the work site 

and remove waste material, thus adding to traffic volumes on site access roads. The increase 

in vehicular traffic would peak during certain hours of the day (e.g., shift changes), resulting in 

temporary levels of service impacts and possible delays at intersections.

During construction, an average daily workforce of 38 workers would be commuting to and from 

the work site for 18 to 24 months. During peak decommissioning activities, up to 81 workers 

could be commuting daily. In addition, an average of 1 truck per week would deliver equipment 

and material to the work site. An additional 20 trucks per week would remove construction 

waste (NWMI 2015a).

Due to the small size of the average daily workforce, the low number of daily truck deliveries 

and shipments combined with the short duration of decommissioning (18 to 24 months) and 

easy access to Route 163, there would be little if any noticeable traffic volume-related level of 

service impacts. Therefore, transportation impacts during the decommissioning of the proposed 

NWMI facility at the MURR site would be SMALL.

5.2.2.11 Accidents

The design and operation of the proposed NWMI facility constructed at the MURR site would be 

essentially the same as it would be for a facility constructed at the Discovery Ridge site 

(NWMI 2015a). Therefore the NRC staff expects that the quantities of radionuclides and 

hazardous chemicals that could be released during a possible radiological or chemical accident, 

as well as any safety features to prevent or mitigate chemical or radioactive material releases

during any accident, would also be the same. The distances from the nearest publicly 

accessible locations (along the facility fence line) to the radiological and chemical accident 

release points would also be similar for the MURR alternative site and the Discovery Ridge site 

(NWMI 2016c). For a proposed NWMI facility at the Discovery Ridge site, the nearest 

permanent residence would be approximately 430 m (0.27 mi) away; for a facility constructed at 

the MURR site, the nearest resident would be approximately 762 m (0.47 mi) away 

(NWMI 2015a).

In Section 4.11.1 of this EIS, the NRC staff concluded that the impacts from potential 

radiological accidents for the proposed NWMI facility constructed at the Discovery Ridge site 

would be SMALL. For a proposed NWMI facility at the MURR site, the location of the nearest 

resident would change, but the NRC staff expects that the maximum offsite accident dose to 

any member of the public, and the point where the maximum offsite dose would be received 

relative to the location of the facility, would not change significantly (as the quantity of 

radiological material released would be the same, and weather or other factors that could affect 

dispersion of radioactive materials would be very similar). The population density of individuals 

living and working around both sites would also be similar (NWMI 2015a). Therefore the 
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unmitigated consequences of radiological accidents for members of the public would be very 

similar for a proposed NWMI facility at either site. The unmitigated consequences for NWMI 

facility staff would also be very similar or identical. The NRC staff expects that a proposed 

NWMI facility at the MURR site would use similar engineering and administrative controls to 

reduce the consequences and likelihood of accidents that an NWMI facility at the Discovery 

Ridge site would. Given the similarity of potential radiological accidents for a proposed NWMI 

facility at the MURR site to radiological accidents for a facility at Discovery Ridge, and given the 

similar number and distribution of members of the public near either site, if the NRC staff 

determines in its SER that the proposed NWMI facility at Discovery Ridge would comply with 

10 CFR 70.61 and any other NRC regulations applicable to radiological accident consequences, 

then the NRC staff concludes that the impacts from potential radiological accidents for a 

proposed NWMI facility located at the MURR site would also be SMALL.

In Section 4.11.2 of this EIS, the NRC staff concluded that the impacts from potential hazardous 

chemical accidents for the proposed NWMI facility constructed at the Discovery Ridge site 

would be SMALL. For potential chemical accidents at the proposed NWMI facility at Discovery 

Ridge, NWMI determined that the highest chemical exposures would occur along the facility 

fence line, which is the nearest location to the facility accessible by members of the public. 

Given that the nearest location accessible to the public would be similar for a facility at the 

MURR site, and that the quantity of hazardous chemicals released would be the same, the 

unmitigated consequences of chemical accidents for members of the public would be very 

similar for an NWMI facility at either site. The unmitigated consequences for NWMI facility staff 

would also be very similar or identical. The NRC staff expects that a proposed NWMI facility at 

the MURR site would use similar engineering and administrative controls to reduce the 

consequences and likelihood of accidents compared to an NWMI facility at the Discovery Ridge 

site. Given the similarity of potential hazardous chemical accidents for a proposed NWMI facility 

at the MURR site to hazardous chemical accidents for a facility at Discovery Ridge, if the NRC 

staff determines in its SER that the proposed NWMI facility at Discovery Ridge would comply 

with 10 CFR 70.61 and any other NRC regulations applicable to chemical accident 

consequences, then the NRC staff concludes that the impacts from potential hazardous 

chemical accidents for a proposed NWMI facility located at the MURR site would also be 

SMALL.

5.2.2.12 Environmental Justice

This section describes the potential human health and environmental effects from the 

construction, operations, and decommissioning of the proposed NWMI facility on minority and 

low-income populations living near the MURR site. As previously discussed in Section 4.12, the 

NRC addresses environmental justice issues and concerns by first identifying potentially 

affected minority and low-income populations and then determining whether there would be any 

potential human health or environmental effects and whether any of these effects would be 

disproportionately high and adverse.

Minority population data are available for Census block groups within a 5-mi (8-km) radius of the 

MURR site. Low-income population data are only available at the Census tract level because of 

the limited availability of poverty and income data at the block group level. To protect 

confidentiality, the United States Census Bureau (USCB) does not publish information about 

small geographic areas if the population size is too small. Race and ethnicity, and poverty and 

income data were used to determine the presence of minority and low-income populations. If 

the center point of the Census tract and block group is within the 5-mi (8-km) radius boundary, 

data from the entire Census tract or Census block group was used.
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Minority Population

According to the 2010 Census, approximately 23 percent of the City of Columbia population

(which includes more than one Census tract and block group) identified themselves as minority. 

According to the USCB’s 2014 American Community Survey 1-Year Estimates, since 2010 

minority population in the City of Columbia was estimated to have increased by approximately 

3,000 persons and now comprises 24 percent of the population (see Table 3–15). 

(UCSB 2016c)

Approximately 23 percent of the population identified themselves as minority individuals 

(Table 5–3) within the 5-mi (8-km) radius of the MURR site and the existing industrial park 

(MCDC 2016b). The largest minority group was Black or African American at 10.8 percent, 

followed by Asian at 5.2 percent (MCDC 2016b).

Census block groups were considered minority population block groups if the percentage of the 

minority population within any block group exceeded 23 percent. Twenty-five of the 58 Census 

block groups were found to have meaningfully greater minority populations. These block groups

are concentrated predominantly north and east of the MURR site within the City of Columbia. 

The MURR site is located in Census Tract 11.03, Block Group 4, with a minority population of 

18.5 percent.

Minority Populations in Census Block Groups Within 5 mi (8 km) 

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
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Census Tract Block Group Total Population

Minority 

Population(a) Percent Minority

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

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)
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Low-Income Population

According to 2010–2014 American Community Survey estimates, an average of 11.3 percent of 

families and 20.7 percent of all people residing in Boone County were identified as living below 

the Federal poverty threshold. In addition, the City of Columbia had an average of 13.2 percent 

of families and 24.9 percent of all people identified as living below the Federal poverty level. 

The Federal poverty threshold for a family of four was $22,314 in 2010 and $24,230 in 2014 

(USCB 2016d).

Table 5–4 lists low-income population Census tracts within a 5-mi (8-km) radius of the MURR 

site and the estimated average number of people living below the poverty level. According to 

the USCB’s American Community Survey 5-Year Estimates for 2010–2014, 25.9 percent of the 

total population within that radius was identified as living below the Federal poverty level 

(MCDC 2016b).

Census tracts were considered low-income population Census tracts if the percentage of 

individuals living below the Federal poverty threshold exceeded 25.9 percent. Ten of the 

18 Census tracts were found to have meaningfully greater low-income populations. These 

Census tracts are concentrated mainly northeast of the MURR site within the City of Columbia. 

The MURR site is located in Census Tract 11.03 with an estimated 16.5 percent of its 

population living below the poverty level (USCB 2016d).

Percentage of People and Families in Census Tracts Within 5 mi (8 km) of the 

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)
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Impact Analysis

Section 5.2 of this EIS presents an assessment of the environmental effects from constructing, 

operating, and decommissioning the proposed NWMI facility at MURR for all affected resource 

areas. The NRC uses this information to determine if there would be any human health or 

environmental effects that could disproportionately affect minority and low-income populations 

and whether any of these effects would be high and adverse.

The following subsections of Section 5.2 describe the potential human health and environmental 

effects from constructing, operating, and decommissioning the proposed NWMI facility that 

could impact minority and low-income populations:

• radiological and nonradiological human health impacts (Section 5.2.2.8),

• noise impacts (Section 5.2.2.2), and

• traffic impacts (Section 5.2.2.10).

The NRC also considered whether there would be any environmental impacts that would affect 

a specific minority and low-income population and whether there would be any unique effects 

that could appreciably exceed or are likely to appreciably exceed those for the general 

population.

Subsistence Consumption of Fish and Wildlife

The special pathway receptors analysis is an important part of the environmental justice 

analysis because consumption patterns may reflect the traditional or cultural practices of 

minority and low-income populations in the area, such as migrant workers or Native Americans.

Section 4–4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and 

appropriate, to collect and analyze information about the consumption patterns of populations 

that rely principally on fish and/or wildlife for subsistence and to communicate the risks of these 

consumption patterns to the public. In this EIS, the NRC staff considered whether there were 

any means for minority or low-income populations to be disproportionately affected by 

examining impacts on American Indians, Hispanics, migrant workers, and other traditional 

lifestyle special pathway receptors.

Based on the description of air and water quality impacts and the discussion of human health 

effects in this EIS, human health impacts in special pathway receptor populations in the region 

as a result of subsistence consumption of water, local food, fish, and wildlife are not likely to be 

high or adverse. Thus, constructing, operating, and decommissioning the proposed NWMI 

facility at the MURR site would not have disproportionately high and adverse human health and 

environmental effects on these populations.

Construction

Similar to construction at Discovery Ridge, potential impacts to minority and low-income 

populations from the construction of the proposed NWMI facility at the MURR site would mostly 

consist of environmental effects (e.g., noise, dust, and traffic). Noise and dust impacts during 

construction would be short term and primarily 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. 

However, given the short duration of construction, the small size of the average daily workforce, 

and the small number of trucks, construction of the proposed NWMI facility would not have 

disproportionately high and adverse human health and environmental effects on minority and 

low-income populations living near the MURR site.
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Operations

Potential impacts to minority and low-income populations during NWMI facility operations would 

mostly consist of radiological and nonradiological human health and environmental (e.g., noise 

and traffic) effects. Everyone living near the MURR site and the proposed NWMI facility could 

be affected by operations activities, including minority and low-income populations. Any human 

health and environmental effect would depend on the magnitude of the change from current 

environmental conditions. Minority and low-income populations residing along site access 

roads could be affected by the increased commuter vehicle and truck traffic during certain hours 

of the day.

As discussed in Section 5.2.2.8 of this EIS, the potential radiological dose to the public from 

NWMI facility operations would be well within NRC and applicable Federal, State, and local 

regulatory limits. As a result, everyone living near the proposed NWMI facility site, including 

minority and low-income populations, would not be adversely affected by radiation exposure 

during facility operations. Permitted nonradiological air emissions would also be required to 

remain within regulatory standards.

As discussed in Section 5.2.2.2 of this EIS, noise levels may increase along site access roads 

due to increased commuter vehicle and truck traffic during NWMI facility operations. This may 

not be noticeable, however, given the relatively small size of the workforce and the limited 

number of daily truck deliveries and shipments. Based on this information, operation of the 

proposed NWMI facility would not have disproportionately high and adverse human health and 

environmental effects on minority and low-income populations living near the MURR site.

Decommissioning

Similar to construction impacts, potential impacts to minority and low-income populations during 

the decommissioning of the proposed NWMI facility at the MURR site would mostly consist of 

environmental and socioeconomic effects (e.g., noise, dust, and traffic). Noise and dust impacts 

during decommissioning would be short term and primarily 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 travelling to and from the proposed work 

site. However, because of the temporary nature of decommissioning, these effects are not 

likely to be high and adverse and would be contained within a limited time period during certain 

hours of the day. Given the short duration, the small size of the average daily workforce, and 

the small number of trucks, decommissioning the proposed NWMI facility would not have 

disproportionately high and adverse human health and environmental effects on minority and 

low-income populations living near the MURR site.

5.2.2.13 Cumulative Impacts

Available information about the past, present, and reasonably foreseeable future projects and 

other activities near the MURR site is provided in Table 5–5.
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Past, Present, and Reasonably Foreseeable Future Projects and 

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)

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

EAG Laboratories

(formerly ABC 

Laboratories)

Analytical biochemical 

testing services

3.8 mi (6.1 km)

southeast of site

Operational (ABC 2016;

EAG 2017)

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)
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Project Name Summary of Project Location Status

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)

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 

Recreation 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)
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Project Name Summary of Project Location Status

Gans Creek Recreation

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 

Memorial 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)

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.

Land Use and Visual Resources

This section addresses the direct and indirect effects of the construction, operations, and 

decommissioning of the NWMI facility at the MURR site on land use and visual resources, when 

added to the aggregate effects of other past, present, and reasonably foreseeable future 

actions. The description of the affected environment in Section 5.2.2.1 serves as baseline 

conditions for the cumulative impact assessment of land use and visual resources. The 

incremental impacts from construction, operations, and decommissioning of the proposed 

NWMI facility on land use and visual resources would be SMALL, as described in 

Section 5.2.2.1.
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Land Use

The projects and activities described in Table 5–5 would result in minimal changes to existing 

land uses, because new construction would occur either within or adjacent to existing facilities, 

or within areas currently zoned for industrial or residential use. Future urbanization and global 

climate change could contribute to additional decreases in agricultural lands, forests, 

grasslands, and wetlands. Urbanization in the vicinity of the MURR site would alter important 

attributes of land use. Urbanization would reduce natural vegetation and agricultural fields, 

resulting in an overall decline in the extent and connectivity of wetlands, forests, grasslands, 

and wildlife habitat. Global climate change could reduce crop yields and livestock productivity 

(USGCRP 2014), which may change portions of agricultural land uses. However, existing 

parks, reserves, and managed areas would help preserve wetlands and forested areas. In 

addition, zoning laws and comprehensive land use plans would help ensure a proper balance of 

development (City of Columbia 2013).

Given that reasonably foreseeable new construction activities would occur within or adjacent to 

existing facilities or within areas zoned for industrial or residential use, cumulative impacts of the 

proposed NWMI facility on land use resources would be SMALL.

Visual Resources

The projects and activities described in Table 5–5 would result in minimal changes to the 

existing viewshed, because new construction would occur either within or adjacent to existing 

facilities, or within areas currently zoned for industrial or residential use. Furthermore, the 

viewshed within the vicinity of the MURR site is agricultural, light industrial, forested or 

residential. Within undeveloped areas, where a new structure would change qualities of the 

existing landscape, the viewshed is generally of low scenic quality because of a lack of notable 

features, uniform landform, low vegetation diversity, an absence of water, mute colors, and a 

commonality within the physiographic province.

Given that reasonably foreseeable new construction activities would occur within or adjacent to 

existing facilities or within areas zoned for industrial or residential use and of low scenic quality, 

the NRC staff determined that cumulative impacts of the proposed NWMI facility on visual 

resources would be SMALL.

Air Quality and Noise

This section addresses the direct and indirect effects of the construction, operations, and 

decommissioning of the NWMI facility at the MURR site on air quality and noise, when added to 

the aggregate effects of other past, present, and reasonably foreseeable future actions. The 

incremental impacts from construction, operations, and decommissioning of the proposed 

NWMI facility on air quality would be SMALL, as described in Section 5.2.2.2. The incremental 

impacts from construction, operations, and decommissioning of the proposed NWMI facility on 

noise would be SMALL to MODERATE.

Air Quality 

The ROI considered for the air quality analysis for the NWMI facility located at the MURR site is 

Boone County, because air quality designations for criteria air pollutants are generally made at 

the county level (Section 5.2.2.2). Table 5–5, provides a list of current projects and reasonably 

foreseeable future actions that could contribute to cumulative impacts to air quality. Air 

emissions sources that contribute to air quality identified in Table 5–5 (e.g., fossil fuel projects 

and manufacturing facilities) that are currently operating have not contributed to a violation of 

the NAAQS given Boone County’s designated unclassifiable/attainment status. Consequently, 
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cumulative impacts to air quality would be the result of changes to present-day emissions and 

future actions within Boone County.

Development and construction activities, as identified in Table 5–5, associated with regional 

growth in housing, business, and industry, as well as associated vehicular traffic can increase 

air emissions. The population for the City of Columbia is projected to increase between 22 and 

35 percent by 2030 (related to 2010) and construction of new housing and associated 

infrastructure will be needed to accommodate the increase in population (City of 

Columbia 2013). Annual job growth projection for the City of Columbia is 1.3 to 1.4 percent 

(City of Columbia 2013). Regional air quality conditions could deteriorate from the effects of 

growth in Boone County, because growth gives rise to dust, vehicle exhaust from increased 

traffic, and other emissions. Although air emissions from construction activities would be 

temporary and localized, the resulting regional growth in residential, commercial, and industrial 

uses across Boone County could result in overall long-term air emission sources. These new 

stationary and mobile (e.g., vehicle) emission sources could further overlap with operations and 

decommissioning of the proposed NWMI facility and could noticeably alter air quality conditions 

in Boone County. If degradation in air quality is observed, MDNR can develop air quality control 

programs to mitigate the effects of development. However, mitigation will depend on the control 

strategies implemented and adherence to these strategies. Climate change impacts, as 

discussed in Section 4.14, can affect air quality as a result of changes in meteorological 

conditions. However, the combination of conditions that can change air pollutant concentrations 

are still being investigated by the scientific community.

The NRC staff determined that the potential cumulative air quality impact associated with 

construction, operations, and decommissioning of the NWMI facility, in conjunction with other 

reasonably foreseeable projects, would be SMALL to MODERATE, because future economic 

and population growth in Boone County could lead to long-term air emission sources and 

increases in air pollutants that can noticeably alter air quality.

Noise

The ROI considered for the noise impact analysis is a 1-mi (1.6-km) radius from the proposed 

NWMI facility at the MURR site. Noise levels attenuate rapidly with distance. When distance is 

doubled from a point source, noise levels decrease by 6 dBA (FHWA 2011). Generally, a 

3-dBA change over existing noise levels is considered to be a “just noticeable” difference, a 

5-dBA increase is readily perceptible, and a 10-dBA increase is subjectively perceived as a 

doubling in loudness (FHWA 2011). As discussed in Section 5.2.2.2, the impact to noise would 

be SMALL to MODERATE during construction and decommissioning.

Those projects identified in Table 5–5 that involve construction activities could result in 

increases in noise levels. Because these projects are beyond the noise analysis ROI for the 

MURR site, these projects would not be expected to have significant noise impacts or increase 

ambient noise levels within the ROI. Therefore, the NRC staff determined that the potential 

cumulative noise impact associated with construction, operations, and decommissioning of the 

NWMI facility, in conjunction with other reasonably foreseeable projects, would remain SMALL 

to MODERATE.

Geologic Environment

This section addresses the direct and indirect effects of the construction, operations, and 

decommissioning of the proposed NWMI facility at the MURR site on the geologic environment 

when added to the aggregate effects of other past, present, and reasonably foreseeable future 

actions. The cumulative impacts on the geologic environment primarily relate to land 

disturbance, the potential for soil erosion and loss, and the consumption of geologic resources. 
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The description of the affected environment in Section 5.2.2.3 of this EIS serves as the baseline 

for the geologic environment cumulative impacts assessment.

The ROI for evaluating cumulative impacts on soil resources encompasses the MURR site and 

a 5-mi (8-km) radius around the site. For geologic resources, the NRC staff further extended 

the ROI to include all of Boone County to encompass potential commercial sources of rock and 

mineral resources to support construction activities at the proposed site and vicinity. Because 

the aspects of land disturbance and conversion are addressed separately under Land Use and 

Visual Resources above, the cumulative impacts analysis here will focus on soil loss, including 

the loss of any prime farmland soils and other important farmland soils, and the consumption of 

geologic resources. The incremental impacts from construction, operations, and 

decommissioning of the proposed NWMI facility on the geologic environment, including geologic 

and soil resources, would be SMALL, as described in Section 5.2.2.3.

Soil Resources

New construction projects identified in Table 5–5 within the immediate 5-mi (8-km) radius of the 

MURR site would result in the conversion and loss of soils. There would be no incremental loss 

of prime farmland or other important farmland soils because although soils at the MURR site do 

meet the relevant criteria as prime farmland soils, they are already in and otherwise committed 

to development uses. Regardless, in accordance with local and State permits and approvals, 

as referenced in Section 5.2.2.3 relative to the NWMI facility, all development activities in the 

ROI would be subject to BMPs for soil erosion and sediment control, which would serve to 

minimize soil erosion and loss. Developers would be likely to reclaim usable topsoil removed by 

ground-disturbing activities for use elsewhere at the impacted development sites. Alternatively, 

developers can stockpile usable topsoil or backfill and then sell or otherwise transfer it for reuse 

elsewhere at other development sites. 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. This would be the case, for example, at the 

NWMI facility site and at other sites across the University of Missouri campus and across south 

Columbia. Although developed land areas could be reclaimed and sufficiently restored to 

support certain agricultural and non-developed uses at some point in the future, such lands and 

associated soils would not be restorable to prime or other important farmland status. 

Cumulative soil loss would largely occur in or adjacent to developed areas and soil loss would 

be mitigated by the use of BMPs. As a result, the NRC staff concludes that cumulative impacts 

on soil resources would be SMALL. 

Geologic Resources

New facility construction and expansion (Table 5–5) would require the use and consumption of 

geologic resources, including rock and mineral assets such as construction aggregate materials 

(e.g., sand and gravel). Construction of the NWMI facility at the MURR site would use many of 

the same materials, including concrete, gravel, and sand required for the other identified 

projects. For example, construction of the NWMI facility would require about 1,700 cubic yards 

(yd3

) (1,300 cubic meters (m3)) of crushed aggregate (limestone) (see Section 2.2). By 

comparison, the 11-county rock and mineral district of central Missouri that includes Boone 

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

) of material (USGS 2015c).

As noted in Section 5.2.2.3, rock and mineral products, including construction aggregate, are 

widely available throughout Boone County and the surrounding region. Likewise, products 

derived from geologic materials, including concrete and asphaltic materials used in construction, 

are widely available on a regional basis. It is not likely that the geologic resource requirements 
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to construct the NWMI facility or the resource requirements of other identified projects are of 

such a volume as to affect local and regional sources and supplies of the identified resources. 

In addition, there are no active geologic assets (mines or quarries) at or near the MURR site 

that would be rendered inaccessible for future use. Therefore, the NRC staff concludes that 

cumulative impacts on geologic resources would be SMALL.

Water Resources

This section addresses the direct and indirect effects of the construction, operations, and 

decommissioning of the proposed NWMI facility on water resources when added to the 

aggregate effects of other past, present, and reasonably foreseeable future actions. This 

cumulative impacts analysis for surface water and groundwater resources considers such 

issues as water quality, water use, and potential climate change. It further considers relevant 

project actions, activities, and specific implications for surface water or groundwater withdrawal, 

effluent discharges, stormwater drainage and runoff, and accidental spills and releases. The 

description of the affected environment in Section 5.2.2.4 serves as the baseline for the water 

resources cumulative impacts assessment.

The ROI for the surface water resources component of the cumulative impacts analysis is 

comprised of the MURR site and the Hinkson Creek watershed downstream of the site and 

including Perche Creek, as described in Section 5.2.2.4, Surface Water Hydrology, Quality, and 

Use. For groundwater resources, the ROI includes the MURR site and the local groundwater 

basin in which groundwater is recharged and flows to discharge points within the watershed. 

The area further comprises those aquifers from which groundwater is withdrawn through wells 

to supply potable, industrial, agricultural, and other uses within a 5-mi (8-km) radius of the site. 

Thus, this analysis focuses on those projects that, when combined with those under the 

proposed action, would: (1) withdraw water from or discharge effluents to Hinkson Creek and 

other tributaries within the watershed downstream of the site, or (2) would use groundwater or 

could otherwise affect the same aquifers that would supply water to the MURR site. For surface 

water, the ROI further encompasses Perche Creek from its confluence with Hinkson Creek and 

including the segment of Perche Creek that receives effluent discharges from the Columbia 

Regional WWTP. The Columbia Regional WWTP would also receive sanitary effluent from the 

proposed NWMI facility. The incremental impacts from construction, operations, and 

decommissioning of the proposed NWMI facility on surface water and groundwater resources 

would be SMALL, as described in Sections 5.2.2.4.

The MURR site is located adjacent to the existing MURR laboratory building, within the 

University of Missouri campus. Site drainage flows generally south through stormwater

drainage channels toward Hinkson Creek, which is located approximately 0.2 mi (0.3 km) south 

of the site. Hinkson Creek is a tributary to Perche Creek and, ultimately, to the Missouri River, 

as further discussed in Section 5.2.2.4.

The State of Missouri has established water quality standards for Hinkson Creek and other 

tributaries within the watershed that ultimately flow to the Missouri River. Surface water is a 

minor source of water supply in Boone County. The predominant source of water for municipal 

water supply and for individual property owners in Boone County, and particularly within the City 

of Columbia, is groundwater pumped from deep bedrock aquifers (Section 5.2.2.4, Groundwater 

Hydrology, Quality, and Use).

Surface Water Resources

Hinkson Creek, which passes south of the MURR site, bisects the City of Columbia and serves 

as the major stormwater drainage basin for the City of Columbia. Like other perennial rivers 

and streams of the State, Hinkson Creek is designated for the following beneficial uses: aquatic 
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habitat protection, human health protection, whole body contact recreation, and secondary 

contact as well as livestock and wildlife protection and irrigation. These uses apply to Hinkson 

Creek and other major streams within a 5-mi (8-km) radius of the MURR site, including Perche 

Creek. Hinkson Creek is included in the State’s list of “impaired” waters, pursuant to 

Section 303(d) of the Federal Water Pollution Control Act (i.e., Clean Water Act (CWA)) of 1972. 

Hinkson Creek is impaired for whole body contact recreation because of water-borne E. coli 

bacteria. The reason for listing is impairment of the beneficial use due to nonpoint source 

runoff.

As further described in Section 5.2.2.4, the State is required to evaluate pollutant loadings within 

such watersheds and implement a watershed-based program to assure future compliance with 

water quality standards. On an individual project or facility basis, the State typically addresses 

watershed improvement through existing and new permits. The NPDES permit program, under 

CWA Section 402, addresses water pollution by regulating point sources (i.e., pipes and 

ditches) that discharge pollutants to waters of the United States. The State of Missouri has 

been delegated NPDES permitting authority by EPA.

Within the context of the local watersheds of the Missouri River, such as Hinkson Creek, climate 

change is an important consideration. Projections for continued increases in temperature and 

changes in precipitation patterns, including longer periods of drought, would be likely to reduce 

the overall amount of water available for surface runoff, with an effect on the beneficial uses of 

affected surface waters. Over the period 1988 to 2010, a decrease in soil moisture has been 

documented during most seasons in the central Midwest (USGCRP 2014). As temperatures 

are projected to continue to increase across the Midwest, this trend would be expected to 

continue. Meanwhile, by mid-century, the scientific community projects increases in the 

frequency and intensity of extreme precipitation, while at same time, an increase in the average 

maximum number of consecutive days with less than 0.01 in (0.025 cm) of precipitation 

(indicative of drought conditions) throughout the entire Midwest region (USGCRP 2014). An 

increased frequency of extreme rainfall events can cause erosion and lead to a decline in water 

quality (USGCRP 2014). This is particularly true where soils are dry and less able to retain 

precipitation that falls during heavier precipitation events. The implications for an urbanized 

watershed, such as Hinkson Creek, are that climatic changes can bring with them increases in 

runoff laden with nutrients, sediment, and other contaminants. Increases in impervious surface 

due to existing and future development can further exacerbate these changes in water quality.

Current and proposed future projects and facilities that adjoin the MURR site include 

institutional, residential, commercial, and industrial uses (Table 5–5) within the urbanized 

University of Missouri campus. Projects and activities occurring within the ROI would be subject 

to applicable local, State, and Federal regulatory requirements and associated permits and 

approvals. Construction projects must obtain a Land Disturbance Permit from the City of 

Columbia and submit related plans for city approval before any ground-disturbing activities or 

facility construction could begin on the site (Section 4.3.1). For projects outside the municipal 

boundary of the City of Columbia, Boone County also requires a Land Disturbance Permit, 

including the development and implementation of a soil erosion and sediment control plan and a 

stormwater management plan. These plans entail the implementation of construction-related 

BMPs for soil erosion and sediment control and stormwater pollution prevention during site 

development, facility construction, and for post development.

The MDNR has developed an NPDES general permit that must be obtained by owners and 

operators for the discharge of stormwater and certain non-stormwater discharges

(e.g., dewatering) from land-disturbance sites that disturb 1 ac (0.4 ha) or more, or less than 

1 ac (0.4) but part of a larger development. This State general permit requires permit holders to 

develop and implement an SWPP, the purpose of which is in part to ensure the proper design, 
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implementation, management, and maintenance of BMPs to prevent the introduction of 

sediment and other pollutants in stormwater discharges. MDNR also requires certain industrial 

facilities to obtain an NPDES permit for stormwater discharges during facility operations.

The Columbia Regional WWTP serves all of the City of Columbia. During the projected 30-year 

period of operations, the only liquid waste discharged from the NWMI facility would be sanitary 

in nature. This effluent would be discharged to the City of Columbia sanitary sewer system at 

an average rate of approximately 4,570 gpd (17,300 Lpd). This is equivalent to approximately 

0.0046 mgd (17.4 m3

/day). The Columbia Regional WWTP would be the ultimate point of 

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/day). NWMI’s additional 

wastewater volume would constitute a very small percentage (i.e., 0.12 percent) of the available 

treatment capacity of the WWTP. Sanitary wastewater discharges from the NWMI facility would 

be unlikely to have any impact on the facility or have any impact on ambient water quality 

downstream of the WWTP.

Nevertheless, the potential exists for substantial population growth in the County and City of 

Columbia of about 40 percent between 2016 and 2050 (Section 3.7.1). The corresponding 

increase in sanitary effluent generated by the larger population would approach or exceed the 

capacity of the WWTP. This would require the City of Columbia to invest in additional 

wastewater treatment infrastructure. Given the planning timeframe, the NRC staff expects that 

the City of Columbia would be able to accommodate the increased treatment demand with 

timely expansions of treatment infrastructure, as it becomes needed.

In summary, construction, operations, and decommissioning of the proposed NWMI facility 

would have a minimal incremental contribution to cumulative impacts on surface water 

resources, including surface water and groundwater quality. Ongoing and future development 

projects within the Hinkson Creek watershed would be subject to City and Boone County site 

development approvals, including Land Disturbance Permits. NPDES permits required for all 

new stormwater and industrial wastewater dischargers would include provisions to comply with 

applicable wasteload allocations established for downstream receiving waters. Within this 

context, climate change including changes in runoff rate and quality would be expected to have 

as big or a bigger role in affecting surface hydrology and water quality as growth and 

development alone in the watershed, as described above. In consideration of this information, 

the NRC staff concludes that the cumulative impacts on surface water resources would be 

SMALL to MODERATE overall, primarily because of urbanization, regional growth, and climate 

change.

Groundwater Resources

The City of Columbia’s water supply primarily comes from a well field withdrawing from the 

alluvial aquifer adjacent to the Missouri River floodplain and located about 7 mi (11 km) 

southwest of the MURR site. This well field has a total groundwater production capacity of 

30 mgd (113,560 m3

/day). The City of Columbia’s average groundwater use is 12.6 mgd 

(47,700 m3

/day) (City of Columbia 2016j). Meanwhile, the University of Missouri maintains its 

own system of five deep wells to supply potable water across the university, including providing 

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/day). 

In 2014, university water use averaged 1.74 mgd (6,590 m3

/day) (MU 2015b). In contrast, 

NWMI facility operations would require an average of 5,045 gpd (19,100 Lpd) of water, 

equivalent to 0.005 mgd (18.9 m3

/day).

The population of Boone County is projected to increase by about 40 percent by 2050. 

Assuming that this projected population growth has a direct and equal correlation on 
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groundwater demand, total groundwater demand within the water supply service areas of the 

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/day), respectively. In reality, population growth in the 

student body, faculty, and other tenant entities located on the university campus would not be 

expected to grow proportionally. Given the groundwater production capacity of the two 

systems, the forecasted water demands alone would not be expected to affect the ability of the 

City of Columbia and University of Missouri water systems to meet the water supply demands of 

expected growth over the next 30 years.

However, the NRC staff assumes that climate change could have as great or a greater impact 

on surface water and groundwater resources, including overall water availability, as any other 

reasonably foreseeable future actions. The loss of moisture from soils because of higher 

temperatures, as discussed in Section 4.14, along with increased evapotranspiration from 

vegetation and the increased average number of days without precipitation is likely to intensify 

short-term (seasonal or shorter) droughts across the Midwest region into the future 

(USGCRP 2009, 2014). Such conditions can reduce the amount of water available for surface 

runoff, streamflow, and groundwater recharge. Specifically, climate change is projected to 

increase water demand across most of the United States. When accounting for regional 

changes in population coupled with predicted climate change impacts, current projections 

indicate that northeast Missouri (where the MURR site is located) could experience 

climate-change induced increases in water demand of up to 10 to 25 percent (USGCRP 2014). 

This increase would not seriously challenge the current production capacity of either the City of 

Columbia or the University of Missouri as the respective supply systems have large excess 

capacity margins. In order to manage any increases in water demands across Boone County 

where the water supply is heavily reliant on deep groundwater coupled with reduced 

groundwater recharge due to climate change, the County’s water supply districts, municipalities, 

and other interests that rely upon deep groundwater could take action to increase the efficiency 

and extent of their production and water distribution infrastructure. This could include 

redeveloping existing production wells or drilling new wells to better manage water supply 

conflicts. However, it is noteworthy that the City of Columbia’s well field would be well insulated 

from any drawdown in the region’s bedrock aquifers due to any increased production, owing to 

the presence of the Missouri River that can serve as a source of induced recharge to the alluvial 

aquifer.

Alternatively, public water suppliers could seek out new water supply sources, such as the 

Missouri River, although this approach would entail investments in new infrastructure and 

increased operating costs. Suppliers could also pursue a combination of approaches such as 

conservation measures and new sources.

It remains that the projected average daily water needs for NWMI facility construction, 

operations, and decommissioning would be a very small percentage (less than 0.3 percent) of 

the University of Missouri’s total production and current available supply capacity. In total, the 

NRC staff concludes that the cumulative impacts on groundwater resources, including water 

availability, would be SMALL.

Ecological Resources

This section addresses the direct and indirect effects of the construction, operations, and 

decommissioning of the NWMI facility at the MURR site on ecological resources, when added to 

the aggregate effects of other past, present, and reasonably foreseeable future actions. The 

description of the affected environment in Section 5.2.2.5 serves as a baseline for the 

cumulative impact assessment of ecological resources. The ROI for evaluating cumulative 

impacts on ecological resources includes the area surrounding the MURR site that is 
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ecologically connected to the onsite ecological resources (e.g., the watershed surrounding the 

MURR site). The incremental impacts from construction, operations, and decommissioning the 

proposed NWMI facility would be SMALL, as described in Section 5.2.2.5.

Since European settlement, prairies, forests, and wetlands have been greatly reduced and 

converted into agricultural fields, industrial uses, and residential and commercial areas. 

Remaining tracts of grasslands, forests, and wetlands tend to be relatively small and isolated, 

which results in lower quality habitat than large tracts of habitat, because of the different 

biological and physical characteristics along the edge of a habitat patch.

Current threats to terrestrial and aquatic habitats include increased soil, nutrients, and other 

pollutants washing into streams and lakes from urban and agricultural stormwater runoff; 

continued conversion and fragmentation of wildlife habitat from development; introduction of 

invasive species; and climate change (BFSC 2007; USGCRP 2014). These activities will likely 

decrease the overall availability and quality of forested, grassland, and wetland habitats. 

Species with threatened, endangered, or declining populations are likely to be more sensitive to 

declines in habitat availability and quality and the introduction of invasive species.

New development projects identified in Table 5–5 are likely to have minimal impacts on 

ecological resources because all the projects are sited within areas that are currently 

agricultural land, open space, or developed. These types of land covers provide low-quality 

habitat for wildlife, birds, and aquatic resources. However, as environmental stressors, such as 

runoff from agricultural fields and urban areas and climate change, continue over the next few 

decades, certain attributes of the terrestrial and aquatic environment (e.g., habitat quality) are 

likely to noticeably change. The NRC staff does not expect these impacts to destabilize any 

important attributes of the terrestrial and aquatic environment, because such impacts will cause 

gradual change, which should allow some aspects of the terrestrial and aquatic environment to 

appropriately adapt. The NRC staff concludes that the cumulative impacts of the proposed 

construction and operation of the NWMI facility, plus other past, present, and reasonably 

foreseeable future projects or actions would result in MODERATE impacts on terrestrial and 

aquatic resources.

Historic and Cultural Resources

This section addresses the direct and indirect contributory effects from constructing, operating, 

and decommissioning the proposed NWMI facility at the MURR site when added to the 

aggregate effects of other past, present, and reasonably foreseeable future actions on historic 

and cultural resources. The geographic area considered in this analysis is the area of potential 

effect (APE) associated with the MURR facility, the MURR site, and its immediate vicinity. As 

discussed in Section 5.2.2.6, constructing, operating, and decommissioning the proposed NWMI 

facility could result in an adverse effect if it is found to alter the historic characteristics that 

qualify MURR for inclusion on the NRHP (36 CFR 800.5(a)(1)). 

The archaeological record for the region indicates prehistoric and historic occupation; the APE 

appears to have been traditionally used as agricultural fields from the protohistoric period 

onward. Historic land development may have resulted in impacts on, and the loss of, cultural 

resources. As described in Section 5.2.2.6, the closest historic property is approximately 1 mi 

(1.6 km) to the north-northeast of the MURR site. The only foreseeable project within the APE

is the proposed NWMI facility at the MURR site. Therefore, historic and cultural resources are 

not likely to be subject to cumulative effects beyond those associated with constructing, 

operating, and decommissioning the proposed NWMI facility at the MURR site.
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Socioeconomics

This section addresses the direct and indirect contributory effects from the construction, 

operations, and decommissioning of the proposed NWMI facility at the MURR site when added 

to the effects from other past, present, and reasonably foreseeable future actions on current 

socioeconomic conditions within the ROI. Since the MURR site and the Discovery Ridge site 

share the same socioeconomic ROI, the description of the affected environment in Section 3.7 

serves as a baseline for the cumulative socioeconomic impact assessment. The geographic 

area of analysis is the ROI, the City of Columbia and Boone County. In either location, the 

socioeconomic impacts from constructing, operating, and decommissioning the proposed NWMI 

facility in the ROI would be SMALL. Since no other research or office facilities are currently 

planned for the Discovery Ridge Research Park, there would be no labor shortages because the 

City of Columbia and Boone County have a sufficient workforce to meet the needs for new 

research facilities (Section 3.7.4).

Table 5–5 identifies past, present, and reasonably foreseeable future actions within the ROI that 

could contribute to cumulative socioeconomic impacts. Relevant “other actions” considered in 

this cumulative impacts analysis is Discovery Park, a residential and commercial development 

being constructed 3.5 mi (5.6 km) southeast of the MURR site. Construction of Discovery Park 

could increase the size of the local population as well as employment and tax revenue and 

increase the demand for public services in the ROI. However, the overall socioeconomic effect 

of this construction project would be small. Therefore, the cumulative socioeconomic impact of 

the proposed action combined with the Discovery Park development would be SMALL.

Human Health

This section addresses the cumulative radiological and nonradiological effects on human health 

for a proposed NWMI facility located at the MURR site. The geographic ROI for this evaluation 

of cumulative effects on human health is that area within a 5-mi (8-km) radius of the proposed 

NWMI facility at the MURR site. This evaluation will consider radiological and nonradiological 

impacts of other activities (in the recent past, present, and reasonably foreseeable future) within 

this ROI. Within this ROI, there are no nuclear power plants that would contribute to radioactive 

or nonradioactive exposure. However, the Callaway Energy Center nuclear power plant is 

located approximately 32 mi (51 km) away. Since the MURR site is within the 50 mi (80 km) 

radiological emergency planning zone for the Callaway plant, radiological human health impacts 

associated with the Callaway plant will also be considered in this evaluation.

As discussed in Section 5.2.2.8, the NRC staff reviewed the possible human health effects that 

could be associated with construction, operations, and decommissioning of the proposed NWMI 

facility at the MURR site. The NRC staff concludes that both radiological and nonradiological 

human health impacts to workers and members of the public from construction, operations, and 

decommissioning of the proposed facility at the MURR site would be SMALL.

Items considered for this evaluation that could have potential radiological health impacts within 

the ROI include the Callaway nuclear power plant, ABC Laboratories, University Hospital, and 

Boone Hospital Center, and the existing MURR Center (all listed in Table 5–5). As discussed in 

Section 4.14.8.1, these facilities are all required to comply with NRC regulations, including limits 

on doses to members of the public. Therefore the NRC staff expects minimal or no 

environmental impacts for each of these facilities considered individually. For Callaway, ABC 

Laboratories, University Hospital and Boone Hospital Center, given the distances between 

those facilities and the MURR site (see Table 5–5) and the very limited individual impacts from 

each of those facilities, the NRC staff does not expect that the cumulative impacts of those 

facilities and the proposed NWMI facility at the MURR site would result in a cumulative 

radiological dose impact in excess of NRC regulatory limits. 
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The existing MURR laboratory building, however, as stated above, would be located 

immediately adjacent to a proposed NWMI facility at the MURR site. As discussed in 

Section 3.10.1, the existing MURR Center has a technical specification (TS) that requires

airborne radiological effluents be limited to levels that ensure that the NRC dose limits in 

10 CFR Part 20 will not be exceeded. MURR’s annual reports for 2013, 2014, and 2015, show 

that MURR’s airborne Ar-41 effluents ranged from 48.9 to 78.1 percent of the TS limit when 

averaged on an annualized basis, and that no other radionuclides were released at average 

concentrations greater than 1 percent of the TS limits (MU 2014, 2015a, 2016d). Also as 

discussed in Section 3.10.1, the MURR Center is required to comply with 10 CFR 20.1101(d), 

which requires licensees to maintain public doses ALARA by establishing a 10 mrem constraint 

on public dose from airborne radioactive material released into the environment. Although 

MURR remained within TS limits and in compliance with 10 CFR Part 20 during the years 2013 

through 2015, a proposed NWMI facility constructed at the MURR site would release additional 

airborne radiological effluents, as discussed in Sections 2.7.1.1 and 4.8.2.1. For a proposed 

NWMI facility at the MURR site, these releases would occur in very close proximity to the 

existing MURR Center. As discussed in Sections 4.8.2 and 5.2.2.8, NWMI estimated that the 

maximum public dose from routine airborne effluents from the proposed NWMI facility at the 

Discovery Ridge site would be approximately 3.6 mrem per year, below both the 100 mrem 

annual limit in 10 CFR 20.1301 and the 10 mrem ALARA constraint of 10 CFR 20.1101(d), and 

this dose would not change significantly for a proposed NWMI facility at the MURR site. 

Although cumulative effluents from a proposed NWMI facility at the MURR site and the existing 

MURR Center could, potentially, result in cumulative public doses that are greater than doses 

from either facility individually, both facilities would be required to comply with 

10 CFR 20.1101(d) by implementing the 10 mrem ALARA constraint. The NRC staff expects 

that since the public dose from airborne radioactive effluents from each facility individually would 

be maintained within this constraint, the cumulative dose from effluents from both facilities 

would remain well below the 100 mrem annual regulatory public dose limit in 10 CFR 20.1301. 

Therefore, if the NRC staff determines in its SER that the doses for the proposed NWMI facility 

located at Discovery Ridge would be in compliance with 10 CFR Part 20, the NRC staff 

concludes that the cumulative radiological human health impacts for a proposed NWMI facility at 

the MURR site would be SMALL.

Activities considered for this evaluation that could have potential nonradiological human health 

impacts within the ROI include all items listed in Table 5–5 as well as the existing MURR 

Center. Construction activities included in Table 5–5, as well as construction of the proposed 

NWMI facility at the MURR site (which would be very similar to construction at the Discovery 

Ridge site), would involve potential hazards to workers typical of any construction site 

(NWMI 2015a). In addition, the proposed NWMI facility at the MURR site and some other 

facilities listed in Table 5–5 are industrial sites with many typical occupational hazards. These 

construction and industrial activities would be required to be performed subject to Occupational 

Safety and Health Administration (OSHA) and State of Missouri safety regulations.

As discussed in Section 4.14.8.2, hazardous chemical releases from the proposed NWMI facility 

and from other activities or facilities within the ROI, would be required to be within EPA and 

State of Missouri regulatory limits. All currently operating facilities in Table 5–5 for which 

possible chemical releases could be expected, except for the existing MURR facility, would be 

approximately 1.1 mi (1.8 km) or more from the proposed NWMI facility at the MURR site. The 

existing MURR could also generate possible chemical releases, and the existing MURR 

laboratory building would be located adjacent to a proposed NWMI facility at the MURR site. 

However, the existing MURR Center is below chemical emissions thresholds that would make it 

subject to reporting for EPA’s Toxics Release Inventory (TRI) program (see Section 4.14.8.2) 

(EPA 2016g).
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All construction, industrial, and other work activities at a proposed NWMI facility at the MURR 

site, and elsewhere in the ROI, would be conducted in accordance with Federal and State 

regulations. In addition, since chemical releases from a proposed NWMI facility at the MURR 

site and other facilities in the ROI would be within EPA and State regulatory limits, and also 

given the distances between the MURR site and facilities listed in Table 5–5 that may have 

significant chemical emissions and be subject to TRI reporting, the NRC staff does not expect 

that the cumulative impacts of other facilities in the ROI and the proposed NWMI facility would 

result in a cumulative chemical exposure impact in excess of Federal or State regulatory limits. 

The NRC staff therefore concludes that the cumulative nonradiological human health impacts of 

the proposed NWMI facility located at the MURR site would be SMALL.

Waste Management

This section addresses the cumulative impacts within the ROI associated with the waste 

management activities of other facilities using radioactive and nonradioactive material in the 

recent past, present, and reasonably foreseeable future. The geographic ROI for the evaluation 

of cumulative impacts from the disposal of radioactive and nonradioactive waste is that area 

within a 5 mi (8 km) radius of the proposed NWMI facility at the MURR site. Table 5–5 lists 

facilities and activities considered within this ROI (Table 5–5 also lists some facilities outside the 

5 mi (8 km) radius, which are not considered in this evaluation).

As stated in Section 5.2.2.9, the types and quantities of radiological and nonradiological waste 

generated, and the disposal pathways for that waste, for a proposed NWMI facility at the MURR 

site would be essentially identical to those for the proposed NWMI facility at the Discovery 

Ridge site. The NRC staff therefore concludes that the human health impacts from both 

radioactive and nonradioactive wastes for a proposed NWMI facility at the MURR site would be

SMALL.

The ROI for a proposed NWMI facility at the MURR site (which includes activities listed in 

Table 5–5) is within the general City of Columbia, Boone County, Missouri area. As discussed 

in Section 4.14.9, the NRC staff assumes that sufficient infrastructure currently exists for proper 

disposal of all radioactive waste generated within the State of Missouri, and all nonradioactive 

waste generated in the Columbia, Missouri area, including radioactive and nonradioactive 

wastes that would be generated by a proposed NWMI facility at the Discovery Ridge site. 

Therefore, given the similar ROIs for a proposed NWMI facility at either site, and given that all 

radioactive or nonradioactive waste generated at a proposed NWMI facility at either site or by 

any other activity within either ROI would be required to be handled in accordance with Federal, 

State, and local regulations, the NRC staff concludes that the cumulative impacts from 

radiological and nonradiological waste management for a proposed NWMI facility at the MURR 

site would be SMALL.

Transportation

This section addresses the direct and indirect contributory effects from constructing, operating, 

and decommissioning the proposed NWMI facility when added to the effects from other past, 

present, and reasonably foreseeable future actions on transportation infrastructure. The ROI is 

the 5-mi (8-km) region surrounding the proposed NWMI facility at the MURR site. However, the 

roads for routes that could be used for delivery of medical isotopes (if air transport is not 

possible) or disposal of wastes were also considered. Transportation infrastructure includes 

roadways, rail lines, airports, and traffic control devices. As discussed in Section 5.2.2.10, 

transportation impacts during construction, operations, and decommissioning would be SMALL.

Construction projects in Table 5–5 could produce an increase in vehicle traffic on roads within 

the 5-mi (8-km) radius of the proposed NWMI site. For example, Discovery Park, a residential 
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and commercial development being constructed 3.5 mi (5.6 km) southeast of the MURR site, 

could add additional commuting vehicles and commercial trucks on local roads near the

proposed NWMI facility. In addition, new construction could occur within the Discovery Ridge 

Research Park. However, existing roads are sufficient to handle the increased traffic. An 

increase in the number of commuter vehicles and commercial trucks on roads near the MURR 

site would not likely have a noticeable impact on overall traffic volumes. Therefore, the 

cumulative effect of traffic-related transportation impacts of the proposed action combined with 

the Discovery Ridge Research Park and Discovery Park development would be SMALL.

Accidents

This section addresses the cumulative impacts within the ROI associated with possible 

accidents at other facilities using radioactive and/or non-radioactive hazardous chemicals. The 

ROI for the evaluation of cumulative effects of accidents is that within a 5-mi (8-km) radius of a 

proposed NWMI facility at the MURR site. Within this ROI, there are no nuclear power plants. 

However, the Callaway nuclear power plant is located approximately 32 mi (51 km) away. 

Since the proposed site is within the 50 mi (80 km) radiological emergency planning zone for the 

Callaway plant, hypothetical radiological accidents associated with the Callaway plant are also 

considered in this evaluation.

In Section 5.2.2.11, the NRC staff concluded that the impacts from both possible radiological 

accidents and possible non-radiological (hazardous chemical) accidents for a proposed NWMI 

facility at the MURR site would be SMALL.

As discussed in Section 4.14.10.1, nuclear reactors and nuclear materials facilities in the United 

States must comply with NRC regulations, including accident dose limits. The nuclear reactors 

and other facilities within the ROI that use radiation or radioactive materials are Callaway, 

ABC Laboratories, University Hospital, Boone Hospital Center, and the existing MURR center. 

These facilities are licensed by the NRC and have demonstrated compliance with NRC’s dose 

limits for accident conditions, as applicable. Therefore, the NRC staff expects possible 

radiological accidents at these facilities to have minimal environmental impact. With the 

exception of the existing MURR center, the facilities within 5 mi (8 km) of the MURR site 

(ABC Laboratories, University Hospital, and Boone Hospital Center) are facilities for which no 

radiological material releases are expected (see Section 4.14.8.1). The existing MURR center 

would be located adjacent to a proposed NWMI facility at the MURR site. Accidents at the 

existing MURR center and a proposed NWMI facility at the MURR site would individually be 

expected to have minimal environmental impact because NRC-licensed facilities must comply 

with NRC regulations related to radiological accident consequences. However, due to the very 

close proximity of these two facilities, there is increased likelihood of a single scenario (such as 

an external event) that could cause accidents to occur at both facilities, creating the possibility 

for cumulative dose impacts greater than those for an accident at either facility individually. 

Therefore, if the NRC staff determines in its SER that the proposed NWMI facility at the 

Discovery Ridge site would comply with 10 CFR 70.61 and any other applicable NRC 

regulations regarding radiological accident consequences, the NRC staff concludes that the 

cumulative impact from potential radiological accidents for a proposed NWMI facility at the 

MURR site would be SMALL to MODERATE.

As discussed in Section 4.14.10.2, industrial, production, or other facilities in Missouri (including 

those in the ROIs for a proposed NWMI facility located at either the MURR or Discovery Ridge 

sites) are required to comply with EPA and State of Missouri regulations to ensure the safe 

handling of chemicals and hazardous materials. With the exception of the existing MURR 

center, all facilities or activities in Table 5–5 for which hazardous chemical releases could be 

expected would be located approximately 1.1 mi (1.8 km) or more from a proposed NWMI 
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facility at the MURR site. The existing MURR center would be located adjacent to a proposed 

NWMI facility at the MURR site; however, as discussed previously in this section, the existing 

MURR center does not use hazardous chemicals in quantities that would make it subject to the 

EPA’s TRI reporting requirements, reducing the likelihood that any significant chemical release 

accident could occur in close proximity to a proposed NWMI facility at the MURR site. 

Therefore, if the NRC staff determines in its SER that the proposed NWMI facility would comply 

with 10 CFR 70.61 and any other applicable NRC regulations regarding hazardous chemical 

accident consequences, the NRC staff concludes that the cumulative impact from potential 

hazardous chemical accidents for a proposed NWMI facility at the MURR site would be SMALL.

Environmental Justice

The environmental justice cumulative impact analysis evaluates the potential contributory 

human health and environmental effects from the construction, operations, and 

decommissioning of the proposed NWMI facility when added to the effects from other past, 

present, and reasonably foreseeable future actions on minority and low-income populations and 

whether these effects might be disproportionately high and adverse. Everyone living near the 

proposed NWMI facility at the MURR site could be affected by construction, operations, and 

decommissioning activities, including minority and low-income populations.

The ROI is the 5-mi (8-km) region surrounding the proposed NWMI facility at the MURR site. 

As discussed in Section 5.2.2.12, the proposed NWMI facility is not located in a minority 

population block group. Minority and low-income populations residing along site access roads 

could be affected by noise, dust, and increased commuter vehicle and truck traffic during 

construction, operations, and decommissioning. However, during construction and 

decommissioning, these would be short term and primarily limited to onsite activities. In 

addition, NWMI facility operations would not have high and adverse human health and 

environmental effects on minority and low-income populations. As a result, minority and 

low-income populations residing near the proposed NWMI facility at MURR would not 

experience disproportionately high and adverse human health and environmental effects from 

the proposed action.

Table 5–5 identifies past, present, and reasonably foreseeable future actions within the 

geographic area of analysis that could contribute to cumulative human health and environmental 

effects. Potential impacts to minority and low-income populations from other past, present, and 

reasonably foreseeable future actions would mostly consist of environmental effects caused by 

construction and operation of new residential, commercial, and industrial developments 

(e.g., noise, dust, traffic, employment, and housing impacts). However, noise and dust impacts 

would be short term during construction and primarily limited to onsite activities. Minority and 

low-income populations residing along site access roads could be directly affected by an 

increase in commuter vehicle and truck traffic. However, these effects are not likely to be high 

and adverse and would be intermittent, only occurring when construction trucks and other 

vehicles pass by during certain hours of the day. Increased demand for housing could cause 

housing costs to rise. Increasing rental costs could disproportionately affect low-income 

populations that rely on inexpensive housing. However, given the availability of local labor and 

the likelihood that construction workers would commute to the work site, rental housing costs 

may be unaffected.

Emissions from new commercial or industrial facilities could also disproportionately affect 

minority and low-income populations. However, any impacts would depend on the magnitude of 

the change from current environmental conditions. Permitted air emissions from all commercial 

and industrial facilities, including the contributory effects from the proposed NWMI facility, would 

be expected to remain within regulatory standards.
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Based on this information and the analysis of human health and other environmental impacts 

presented in this EIS, the contributory effects of constructing, operating, and decommissioning 

the proposed NWMI facility would not create disproportionately high and adverse cumulative 

human health and environmental effects on minority and low-income populations living near 

MURR.

5.3 Alternative Technologies

The purpose of the NWMI facility is to use LEU to domestically produce molybdenum-99 

(Mo-99) (Section 2.0). Other alternative medical radioisotope production technologies currently 

exist and have been proposed that could be used to create these isotopes (e.g., “Making 

Medical Isotopes: Report of the Task Force on Alternatives for Medical-Isotope Production 

(TRIUMF 2008) and Homogeneous Aqueous Solution Nuclear Reactors for the Production of 

Mo-99 [Molybdenum-99] and other Short Lived Radioisotopes” (IAEA 2008)).

In this analysis of the alternative technologies, the NRC staff evaluated the potential 

environmental impacts if a commercial entity were to construct and operate a facility on the 

proposed Discovery Ridge site using an alternative technology. The NRC staff notes that no 

commercial entity (other than NWMI) has proposed building or operating a medical radioisotope

production facility at the proposed Discovery Ridge site.

5.3.1 Description of Alternative Technology Screening Process

5.3.1.1 Initial Screening

To begin the alternative technology evaluation, the NRC staff initially considered the range of 

possible alternatives, or various methods to produce Mo-99, including international commercial 

entities currently producing Mo-99 and several commercial entities proposing new methods to 

produce Mo-99 within the United States. The Council on Environmental Quality’s regulations 

implementing NEPA provide guidance when a large number of potential alternatives exist. In 

such situations, NEPA only requires that an agency analyze a reasonable number of examples, 

covering the full spectrum of alternatives, in the EIS (46 FR 18026).

For the purposes of this EIS, the NRC staff initially limited the alternative technologies analysis 

to the five technologies that the DOE’s National Nuclear Security Administration (NNSA), 

through the Office of Nuclear Nonproliferation’s Global Threat Reduction Initiative, awarded 

cooperative agreements (as of July 2016) for three main reasons. First, these technologies 

appear to be technically feasible. In awarding the cooperative agreements, NNSA based its 

decision, in part, on an evaluation of technical feasibility. Second, the NRC is not aware of 

entities proposing to construct a new facility in the United States using technology currently 

being used in other countries. Therefore, based on the technology that has been proposed to 

create a domestic source of Mo-99, as of July 2016, the alternative technologies examined in 

the EIS include the types of technologies most likely to be constructed and operated within the 

United States. Third, the NRC staff concluded that the five entities awarded cooperative 

agreements used technologies that covered the spectrum of potential alternatives based on 

general land use requirements, power levels, and other environmental and engineering 

parameters.

The five alternative technologies are:

neutron capture technology,

aqueous homogenous reactor technology,

selective gas extraction technology, 
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uranium fission technology, and

linear accelerator-based technology.

Neutron Capture Technology

The neutron capture technology produces Mo-99 by neutron irradiation of natural molybdenum 

in a boiling water reactor (GE-Hitachi 2011). Given that the proposed Discovery Ridge site does 

not contain a boiling water reactor, the NRC staff does not consider construction of a new power 

reactor to be reasonable, because the currently proposed site has insufficient space and other 

resources to support a power reactor. Alternatively, a research reactor could be used to 

produce Mo-99 using neutron capture technology. Sufficient space likely exists on the proposed 

Discovery Ridge site to construct a new research reactor as part of the neutron capture 

alternative.

Aqueous Homogenous Reactor Technology

The LEU aqueous homogenous reactor technology produces Mo-99 using an aqueous 

homogenous reactor fueled by a uranium salt solution, followed by a series of chemical

processes to extract the Mo-99 (IAEA 2008; B&W 2012). The size of each reactor would be 

approximately 200 to 240 kilowatts, and it would be capable of producing about 1,100 6-day Ci 

on a weekly basis (IAEA 2008). The reactor fuel solution would contain LEU salt dissolved in 

water and acid. This solution would also be the target material for Mo-99 production, as 

fissioning uranium-235 would produce Mo-99 and other fission products. The reactor would be 

operated until a sufficient amount of Mo-99 occurred in the fuel solution. The fuel solution would 

then be removed and processed using chemical purification to extract the Mo-99 (IAEA 2013b).

Selective Gas Extraction Technology

The selective gas extraction technology produces Mo-99 by irradiating porous uranium oxide 

targets and then using a selective gas extraction process to extract the Mo-99 (Bertch 2014;

Grozelle 2016). For this technology, uranium targets would initially be placed within a tube and 

then irradiated within a research reactor. After irradiation, the target tube would be heated and 

gas would flow through the porous target to extract the Mo-99 in hot cells (Bertch 2014; 

Grozelle 2016). The target tube includes separate areas for gas delivery and collection. The 

target would be re-irradiated following the selective gas extraction process.

Uranium Fission Technology

The uranium fission technology would produce Mo-99 using a subcritical fission process 

followed by chemical extraction of Mo-99 (SHINE 2015). The process would use an accelerator 

and neutron multiplier to produce neutrons that would enter a tank containing a target solution 

with the fissile uranium-235 isotope. As neutrons collide with the uranium-235, the uranium 

would split and form other radioisotopes, including Mo-99, xenon-133, and iodine-131. 

Extraction and purification would occur within hot cells. During this process, Mo-99 extraction 

would occur as a batch process in which the irradiated uranyl sulfate target solution would be 

passed through an adsorption column to extract the isotopes. The extracted isotopes would 

then undergo dissolution and evaporation processes to yield a crude Mo-99 product. The 

purification process would remove impurities through small-scale additions of reagents and 

through precipitation, filtration, and boiling. LEU remaining in the target solution would be 

reused and would undergo cleanup for use as the target solution for subsequent cycles because 

only a small amount of uranium-235 is used up during each production run.

Linear Accelerator-Based Technology

The linear accelerator-based technology produces Mo-99 by utilizing an accelerator to irradiate 

natural molybdenum that has been enriched in the radioisotope molybdenum-100 (Mo-100) 
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(DOE 2012). Targets made of molybdenum would be enriched in the radioisotope Mo-100 and 

would be irradiated (or bombarded) using a pair of accelerators. After bombardment, the 

targets would be removed and be shipped from the facility to an end user medical facility

(NorthStar 2015). After further processing at the end user medical facility, the spent or 

unusable portion of the radiochemical from the end user facility would be returned and reused.

5.3.1.2 Secondary Screening

For the next level of screening, the NRC staff searched for engineering and environmental data 

to describe the impacts from the construction and operations of the alternative technology within 

topical papers, white papers, environmental assessments, environmental reports, and other 

sources of information. Based on this review, the NRC staff did not find sufficient data to 

describe the potential environmental impacts from the construction and operations of the 

neutron capture technology, aqueous homogenous reactor technology, or the selective gas 

extraction technology due to the lack of environmental documents describing potential 

environmental impacts to the natural and human environmental from these technologies. 

Therefore, the NRC staff determined that insufficient environmental information exists to 

meaningfully analyze the environmental impacts of these technologies in detail. For these 

reasons, the NRC staff does not consider these technologies reasonable alternatives and has 

excluded them from further consideration.

The NRC staff determined that sufficient environmental data exist regarding the potential 

impacts of construction, operations, and decommissioning for the uranium fission alternative 

(NRC 2015c) and the linear accelerator-based alternative (DOE 2012). Therefore, in the 

following sections, the NRC staff evaluated in depth the potential environmental impacts if a 

commercial entity were to construct, operate, and decommission a uranium fission facility or a 

linear accelerator-based facility on the proposed Discovery Ridge site.

5.3.2 Linear Accelerator-Based Technology

The linear accelerator-based technology produces Mo-99 by using an accelerator to irradiate 

natural molybdenum that has been enriched in the radioisotope Mo-100. For the purpose of this 

analysis, the NRC staff assumed the facility would be similar to the facility described in NNSA’s 

“Environmental Assessment for NorthStar Medical Technologies LLC Commercial Domestic 

Production of the Medical Isotope Molybdenum-99” (DOE 2012). The NRC staff acknowledges 

that other commercial entities have proposed methods of producing Mo-99 using linear 

accelerator-based technology, such as Niowave, Inc. (Niowave 2015). However, for the 

purpose of this analysis, the NRC staff used the environmental parameters included in NNSA’s 

environmental assessment for the NorthStar Medical Radioisotope facility because this 

commercial entity was awarded a cooperative agreement by NNSA and sufficient environmental 

data exist regarding this proposed technology to conduct a meaningful analysis.

The facility for the linear accelerator-based alternative would have the capacity to produce 

approximately 3,000 6-day Ci per week. To produce Mo-99, the operator would use a target 

made of molybdenum enriched in the radioisotope Mo-100 and would irradiate (or bombard) the 

targets using a pair of accelerators. Up to 16 accelerators would be constructed and used 

during operations (DOE 2012). After bombardment, the operator would then ship Mo-99 from 

the facility to an end user medical facility (NorthStar 2015). After further processing at the end

user medical facility, the spent or unusable portion of the radiochemical from the end user 

facility would be returned.

During operations, the facility would produce radiolytic and other offgases such as nitrogen 

oxides (DOE 2012). The production process would also generate radioactive and 

nonradioactive liquid waste (DOE 2012).
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The NRC staff assumed that the operator would construct a containment building for the 

accelerators and radioactive waste facility (DOE 2012). In addition, a separate building or parts 

of the building would contain the processing facility (e.g., hot cells and chemical laboratories), 

areas for shipping and receiving, and a waste management center. Support facilities, such as 

administration buildings, parking lots, and access roads, would be similar to those for the NWMI 

facility. Construction of a linear accelerator-based facility would take up to 18 months and 

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) of soil

and rock material (DOE 2012). Operation of a linear accelerator-based facility would require up 

to 150 workers (DOE 2012).

A description of the affected environment for the Discovery Ridge site is provided in Chapter 3 

of the EIS. The following sections describe the impacts of constructing, operating, and 

decommissioning the proposed NWMI facility utilizing the linear accelerator-based technology.

5.3.2.1 Land Use and Visual Resources

Land use impacts of a linear accelerator-based alternative at the Discovery Ridge site would be 

confined to the 7.4 ac (3.0 ha) site. The linear accelerator-based alternative would disturb a 

similar amount of land as the proposed NWMI facility (DOE 2012). The highest structure would 

be the emissions stack for chemical processing, which would extend approximately 18 m (60 ft) 

in height, with a diameter of 0.6 m (2 ft) (DOE 2012). Therefore, the height of the buildings for 

the accelerator-based alternative would be bounded by the parameters analyzed for the NWMI 

facility in Section 4.1. As described in Section 4.1, land use impacts during construction, 

operations, and decommissioning would be SMALL, because the entire site is currently certified 

for industrial use, and the permanently converted agricultural land would be a small portion of 

available agricultural land within the vicinity. As described in Section 4.1, aesthetic impacts 

during construction, operations, and decommissioning would be SMALL at the proposed 

Discovery Ridge site, given that a light industrial development landscape surrounds part of the 

site and the visual setting is generally flat and has a uniform landform with low vegetation 

diversity and a low visual-quality rating. Based on a similar land disturbance and building height 

for the linear accelerator-based alternative, land use and visual impacts would be SMALL during 

construction, operations, and decommissioning of a linear accelerator-based facility on the 

Discovery Ridge site.

5.3.2.2 Air Quality and Noise

Air Quality

Construction

Construction activities associated with building a linear accelerator-based facility would 

generate air pollutant emissions from site-disturbing activities (e.g., grading, compacting), 

operation of construction equipment, and worker and shipment vehicles. Emissions from 

construction are presented in Table 5–6.

Estimated Air Emissions Resulting from Construction of a Linear

Accelerator-Based Facility

Total Emissions 

(ton/year)(a)

Nitrogen Oxides (NOx) 8

Carbon Monoxide (CO) 6

Sulfur Dioxide (SO2) 0.5
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Total Emissions 

(ton/year)(a)

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.

While emissions would be greater than construction of the proposed NWMI facility, emissions 

would be below the significant de minimis levels under the New Source Review program 

discussed in Section 3.2.2 of this EIS. Therefore, the NRC staff does not expect increases in air 

emissions from construction activities of a linear accelerator-based technology at the Discovery 

Ridge site to contribute to concentrations that would exceed NAAQS in Boone County. The 

NRC staff concludes that air quality impacts during construction of a linear accelerator-based 

technology at the Discovery Ridge site would be SMALL.

Operations

Operation of a linear accelerator-based facility would produce air emissions from operation of 

the building heating system, emergency generator, chemical processing, and worker vehicles. 

Total emissions from operations of a linear accelerator-based facility are presented in 

Table 5–7.

Estimated Air Emissions Resulting from Operation of a Linear

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.

Total operation-related emissions for criteria pollutants are well below the significant de minimis 

levels under the New Source Review program and major source under Title V operating source 

threshold (100 TPY) discussed Section 3.2.2 of this EIS. Therefore, the NRC staff does not 

expect increases in air emissions from operations of a linear accelerator-based facility at the 

Discovery Ridge site to contribute to concentrations that would interfere with the maintenance of 

NAAQS or degrade Boone County’s unclassifiable/attainment designation. Therefore, the NRC 

staff concludes that the air quality impacts during operations of a linear accelerator-based 

facility would be SMALL.
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Decommissioning

Decommissioning activities would be similar to construction activities. The decommissioning 

activities would include, for example, vehicular traffic, earth-moving equipment, demolition of 

structures, and dismantlement and decontamination of systems. Emissions would be similar to 

what is presented in Table 5–6, above. Similarly, the NRC staff concludes that air quality 

impacts during decommissioning of a linear accelerator-based technology at the Discovery 

Ridge site would be SMALL.

Noise

Construction

Noise emissions during construction would occur because of increased traffic volumes from 

worker vehicles and because of the use of construction equipment on site. Noise from 

construction equipment would be localized, short term, and intermittent during machinery 

operations. Noise levels from construction equipment is predicted to be 65 dBA at 210 m 

(0.13 mi) distance from the equipment (DOE 2012). Noise levels from construction equipment 

therefore would not exceed existing noise levels at the sensitive receptors to the Discovery 

Ridge site. The number of worker vehicles expected during construction is 50 (DOE 2012), all 

of which, for purposes of this analysis, are assumed to travel along U.S. Highway 63 during 

hours when work starts and stops. Sound levels increase at a rate of 3 dBA per doubling of 

traffic volumes. Conservatively assuming that all worker vehicles and deliveries travel on 

U.S. Highway 63 at the same time, this will result in a traffic volume of 868 vehicles/hr. This 

increase in traffic will not result in noise levels that will be noticeable from a traffic volume of 

818 vehicles/hr.

Given that increases in noise levels as a result of additional vehicle traffic will not be noticeable 

and noise levels from construction equipment are not anticipated to exceed existing ambient

noise levels, the NRC staff concludes that offsite noise impacts from construction would be 

SMALL.

Operations

Noise emissions during operation would occur because of increased traffic and the cooling 

tower. Noise from most operating equipment would be contained inside buildings and is not 

anticipated to be audible outside the linear accelerator-based facility (DOE 2012). Cooling 

tower noise levels are estimated to reach 60 dBA at a distance of 9 m (30 ft) from the cooling 

towers, which would not be noticeable given existing ambient noise levels at the Discovery 

Ridge site. The number of worker vehicles expected during operation is 150 (DOE 2012). 

Adding this traffic volume to existing traffic levels along U.S. Highway 63 will not result in noise 

levels that would be noticeable (i.e., less than 3 dBA increase). Therefore, the NRC staff 

concludes that noise impacts from operation of a linear accelerator-based facility at the 

Discovery Ridge site would be SMALL.

Decommissioning

Noise emissions during decommissioning would occur because of increased traffic volumes 

from worker vehicles and the use of equipment on site. Equipment during decommissioning 

would be similar to that used during the construction phase. As discussed above, noise levels 

from construction equipment for a linear accelerator-based facility are not expected to exceed 

existing noise levels. Similarly, noise levels from additional worker vehicles are not anticipated 

to be noticeable. Therefore, given that increases in noise levels as a result of additional vehicle 

traffic will not be noticeable and noise levels from equipment are not anticipated to exceed
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existing ambient noise levels, the NRC staff concludes that noise impacts from 

decommissioning a linear accelerator-based facility at the Discovery Ridge site would be 

SMALL.

5.3.2.3 Geologic Environment

Geology and Soils

Construction

Impacts on geology and soils associated with construction of a linear accelerator-based facility 

at the Discovery Ridge site would likely be similar to but somewhat greater than the impacts 

described for the proposed technology alternative, as presented in Section 4.3.1. The potential 

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

)) and the greater depth of excavation 

required (i.e., up to 30 ft (9 m)) in order to construct the below-grade portions of the facility 

(DOE 2012). As the depth to bedrock beneath the site is on the order of 25 ft (7.6 m) or less 

(Section 3.3.1), it is possible that blasting and other construction methods may be required 

during foundation excavation, depending on such factors as the depth of bedrock weathering. 

As for the proposed technology, the NRC staff assumes that the entire 7.4 ac (3.0 ha) site would 

be disturbed during construction of the linear accelerator-based facility.

The larger footprint that would be cleared, graded, and compacted along with the greater 

excavation depth would increase the potential for soil erosion and loss. Nevertheless, 

construction activities would be subject to the same site development permitting and associated 

regulatory requirements previously described in Section 4.3.1. For instance, NWMI would need 

to conduct site work in accordance with a Land Disturbance Permit from the City of Columbia in 

accordance with Chapter 12A, Article II (Land Preservation) of the City’s Code of Ordinances 

(City of Columbia 2015). NWMI would need to prepare a soil erosion and sediment control plan 

and a stormwater management plan. These plans entail the implementation of 

construction-related BMPs for soil erosion and sediment control and stormwater pollution 

prevention during site development, facility construction, and for post development.

As described in Sections 3.3.1 and 3.3.2 and evaluated as for potential impacts in Section 4.3.1 

for the proposed alternative, the site presents construction challenges that will need to be

addressed during facility construction, along with possible mitigative features incorporated into 

the facility design. These challenges include the depth to bedrock, the potential for a seasonally 

high water table or perched groundwater, and the occurrence of soils with construction 

limitations (e.g., fat clays with a high shrink/swell potential). NWMI will conduct a site-specific 

geotechnical and hydrological studies of the Discovery Ridge site to characterize site conditions 

in support of final facility design.

As summarized in Section 2.2, Table 2–1 for the proposed alternative, geologic resources would 

also be required to support construction of a linear accelerator-based facility; these resources 

include granular stone (e.g., typically crushed aggregate (sand and gravel)) and aggregate to 

produce ready-mix concrete. Nevertheless, as noted in Section 3.3.1, construction aggregate is 

widely available throughout Boone County and northeast Missouri; therefore, their consumption 

to support facility construction under this alternative would not likely deplete local or regional 

stockpiles of such geologic resources.

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

) of soil, 

sediments, and rock material, as compared to 9,000 yd3 (6,900 m3

) for the proposed alternative. 

DOE (2012) indicates that the excavated material would be used on site for grading purposes, 

and presumably for backfill, or transported off site for disposal or reuse. Soils at the Discovery 
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Ridge site, particularly the fat clays, have poor shear strength when wetted and have generally 

poor workability as a construction material, including for use as structural (engineered) backfill 

(Section 3.3.1). Consequently, the NRC staff expects that at least some proportion of this 

excavated material may need to be replaced with engineered backfill from offsite sources, thus 

adding to the volume of onsite earthwork required and geologic materials consumed. Still, the 

NRC staff expects that soils and other materials with the necessary engineering properties are 

readily obtainable from sources throughout the City of Columbia area and across Boone 

County.

Potential impacts on the geologic environment from construction of a linear accelerator-based 

facility at the Discovery Ridge site, to include soil loss and geologic resource consumption, 

would be similar to but somewhat greater than those associated with the proposed technology 

alternative. Site conditions also present somewhat greater constraints on site development and 

linear accelerator-based facility construction because of the larger facility footprint and greater 

excavation depth required. However, as for the proposed technology, the completion of detailed 

site-specific geotechnical studies would serve to reduce the cited uncertainties with respect to 

site geologic and soil conditions. Overall, the NRC staff concludes that the impacts on the 

geologic environment from the construction of a linear accelerator-based facility would also be 

SMALL.

Operations

Operational impacts on the geologic environment would be negligible under this technology 

alternative. 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 (such as roadways and parking lots), 

or revegetated.

Regardless of the technology, final facility design and construction would comply with applicable 

building codes and standards, which provide for the evaluation of site geologic and soil

conditions, including potential seismic hazards. Completion of site-specific geotechnical and 

hydrological studies, as discussed in Section 4.3.1, would inform final facility design for the 

linear accelerator-based technology and construction considerations. The NRC staff concludes 

that linear accelerator-based facility operational impacts associated with the geologic 

environment at the proposed site would be SMALL.

Decommissioning

Compacted site soils and underlying sediments would be disturbed by facility demolition and 

decontamination work. The impacts on site geology and soils would be similar in scope to those 

described for construction. For the linear accelerator-based facility, the potential for soil erosion

and loss would be somewhat greater than for the proposed NWMI technology primarily because 

of the larger facility footprint. Regardless, all site clearing to restore the proposed site to a 

reusable condition would be subject to applicable permits and approvals (e.g., demolition or 

clearance permit) and the applicable provisions, including Chapter 6, Article II (Building Code) of 

the City of Columbia’s Code of Ordinances (City of Columbia 2015).

Before beginning to dismantle onsite structures, NWMI would remove waste materials and 

contaminated media from the structures. Materials would be packaged and properly disposed 

of as discussed in Section 5.3.2.9. Thus, these materials would not pose a contamination threat 

to site soils or water resources. NWMI would be required to conduct all decommissioning 

activities in accordance with a decommissioning plan submitted to the NRC and applicable 

regulations, as described in Section 2.9. As a result, the NRC staff concludes that impacts on 

the geologic environment from facility decommissioning would be SMALL.
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5.3.2.4 Water Resources

Surface Water and Groundwater Resources

Construction

Impacts on surface water and groundwater resources from construction activities associated 

with the linear accelerator-based technology alternative would be similar to but somewhat 

greater than those under the proposed technology alternative (see Sections 4.4.1.1 

and 4.4.2.1). The potential for greater impacts is attributable to the additional land affected 

because of the larger footprint of the facility and the greater depth of excavation, as referenced 

in Section 5.3.2.3. Otherwise, the same general assumptions, impact considerations, and 

regulatory parameters discussed for the proposed alternative apply to this alternative.

Site construction activities would have no direct impact on surface water resources. No natural 

surface water features occur on the Discovery Ridge site, and the site is not located in an area 

susceptible to flooding or in a delineated floodplain, as discussed in Section 3.4.1. During 

construction, however, stormwater runoff from construction areas could potentially affect 

downstream surface water quality if not properly managed. NWMI would be required to obtain a 

Land Disturbance Permit from the City of Columbia and submit related plans for City approval 

before any ground-disturbing activities or facility construction could begin on the site, as 

referenced in Section 5.3.2.3. The City would require that appropriate soil erosion and sediment 

control BMPs be used to minimize soil erosion and the stormwater transport of suspended 

sediment and other pollutants.

Construction stormwater runoff from the site would also be subject to regulation in accordance 

with CWA Section 402. Under the State of Missouri’s delegated authority for administering the 

NPDES permit program pursuant to Section 402, the State has developed an NPDES general 

permit for construction stormwater. Permit coverage must be obtained by facility owners and 

operators for the discharge of stormwater and certain non-stormwater discharges

(e.g., dewatering flows) from land-disturbance sites that disturb 1 ac (0.4 ha) or more, as further 

described in Section 4.4.1.1. NWMI’s construction activities would be subject to NPDES permit 

and other local regulations for soil erosion and sediment control and construction stormwater 

management.

In addition, under CWA Section 401, an applicant for a Federal license or permit to conduct any 

activities, including facility construction or operation, that may cause a discharge into navigable 

waters is required to provide the Federal licensing agency with a certification from the state or 

agency having jurisdiction in which the discharge would originate. As discussed in 

Section 4.4.1.1 for the Discovery Ridge site, NWMI has stated that no State certification is 

required under CWA Section 401 (NWMI 2015a). NWMI also has stated that it would seek a 

waiver from the State (NWMI 2015c). However, because the NRC cannot issue a license or 

permit until the required certification is submitted, NWMI must provide the NRC with either a 

401 certification from the State of Missouri, a waiver, or other State documentation that a 

Section 401 certification is not necessary.

The need for groundwater dewatering would be more likely under this alternative. This is due to 

the greater depth of excavation (i.e., up to 30 ft (7 m)) expected for the below-grade portion of 

the linear accelerator-based facility. The volume of groundwater requiring removal could be 

greater than the maximum volume projected by NWMI for the proposed technology, as 

described in Section 4.4.2.1.

As such, the NRC staff expects that dewatering could have minor effects on the vertical and 

horizontal extent of shallow groundwater, if present, and on groundwater flow direction, but any 

effects would be localized and temporary. Notwithstanding, NWMI would conduct site-specific 
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geotechnical and hydrologic studies of the Discovery Ridge site that would characterize 

groundwater conditions beneath the site (NWMI 2015c). These results would guide any 

necessary construction accommodations and final facility design.

Other than the need for construction dewatering, no surface water or onsite groundwater would 

be withdrawn to support construction for this technology alternative. Water would be required 

during facility construction for such uses as dust control and soil compaction as well as to meet 

the drinking and sanitary needs of the construction workforce during the construction period.

Water lines and other utilities are already in place at the southwest corner of the Discovery 

Ridge site, with public water provided by Consolidated Public Water Supply District No. 1 

(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

/day) and currently supplies 

approximately 1.45 mgd (5,490 m3

/day) to customers.

The NRC staff estimates that onsite water needs to support linear accelerator-based facility 

construction would be similar to but greater than those for the proposed technology alternative, 

with the difference attributable primarily to the larger footprint of the facility. The NRC staff 

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

/day). Total projected water use for the slightly 

longer construction period (18 months) as compared to the NWMI proposed technology 

alternative would be about 2.6 million gal (9.8 million L). The projected average daily water 

needs for facility construction under this alternative is a very small percentage (i.e., about 

0.50 and 0.07 percent) of the public water district’s existing demand and available production 

capacity, respectively.

As stated in Section 4.4.1.1, the construction contractor would provide portable restroom 

facilities for the construction workforce. This measure would reduce the quantity of water 

required for potable and sanitary uses. These facilities would be serviced off site by a 

commercial vendor, alleviating any potential surface water or groundwater quality concerns.

Construction activities would not disturb any surface water features under this technology 

alternative, and NWMI would be required to prepare site-specific plans and implement BMPs in 

accordance with local and MDNR requirements to mitigate the potential impacts on surface 

water quality associated with construction activities. No surface water or onsite groundwater 

would be used to support facility construction. Construction dewatering would be likely during 

construction, but site-specific geotechnical and hydrologic studies will further characterize 

subsurface conditions, and dewatering activities would be conducted in accordance with 

regulatory requirements. The volume of water required to support onsite construction activities 

would be a very small percentage of the public utility’s existing demand and available production 

capacity. The NRC staff concludes that the impacts on surface water and groundwater 

hydrology, quality, and use from the construction of a linear accelerator-based facility would be 

SMALL.

Operations

Under the linear accelerator-based technology alternative, normal facility operations would not 

have any direct impact on surface water or groundwater hydrology or quality. As described in 

Sections 4.4.1.2 and 4.4.2.2 for the proposed alternative at the Discovery Ridge site, 

stormwater runoff from the facility site would also be managed by an engineered stormwater 

management system, including necessary detention/retention structures, constructed and 

operated in compliance with applicable local, State, and Federal stormwater management 

permits, plans, procedures, and practices.
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The NRC staff estimates that operation of the linear accelerator-based facility would normally 

require less water than the proposed technology alternative. This is because the volume of 

water necessary to meet workforce potable and sanitary needs is the primary component of 

total facility use. A closed-loop cooling system would normally operate to service the 

accelerators. Initial cooling system makeup requirements would total about 3,000 gal 

(11,400 L). This water would circulate internally and would need to be replenished only 

periodically. However, the use of a hybrid, evaporative cooling system may be necessary 

during the summer. This would require additional makeup water totaling 2,800 gpd 

(11,000 Lpd) during the summer months (DOE 2012).

The NRC staff estimates that an average of 4,000 gpd (15,100 Lpd) of water, equivalent to 

0.004 mgd (15.1 m3

/day), would be required to support facility operations under this alternative. 

Consolidated Public Water Supply District No. 1 would also provide water service to the site and 

facility under this alternative. The projected average daily water use for this technology 

alternative is a negligible percentage of the production capacity of the water district and 

represents a very small increase (about 0.3 percent) in the volume of water that the district 

supplies to its customers.

There would be no radioactive liquid effluents released from the facility. Liquid waste generated 

during operations would be collected and stored by NWMI, and there would be no release of 

radioactive material through wastewater. All facility operations would be contained inside 

properly constructed buildings with proper material- and waste-handling facilities and spill 

prevention/cleanup capabilities (DOE 2012). As designed, only sanitary wastewater would be 

discharged to the sanitary sewer system serving the site (DOE 2012). The NRC staff estimates 

that sanitary effluent flow would average 3,300 gpd (12,500 Lpd). This is equivalent to 

approximately 0.0033 mgd (12.5 m3

/day). This effluent would be treated at the Columbia 

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/day). The sanitary effluent flow 

under this technology alternative would be a very small percentage (i.e., 0.08 percent) of the 

available treatment capacity of the WWTP. The effluent would be required to meet the sewer 

system’s influent acceptance and treatment criteria, as well as NRC’s regulations at 

10 CFR 20.2003.

Under this technology alternative, there would be no radiological or nonradiological impacts on 

surface water or groundwater during normal operations. Facility operations would need to 

comply with local, State, and Federal stormwater management permits, plans, procedures, and 

practices. Water requirements and sanitary effluent treatment needs would be met by public 

facilities, which have adequate capacity. As a result, the NRC staff concludes that the impacts 

on surface and groundwater hydrology, water quality, and water use from the operation of a 

linear accelerator-based facility would be SMALL.

Decommissioning

Facility decontamination, demolition, and site-restoration activities would be similar to those 

under the proposed technology alternative, with the potential magnitude of the impacts on 

surface water and groundwater similar to those discussed above for construction. NWMI would 

perform demolition and site-restoration activities in accordance with applicable local and State 

permits and approvals, including a State-issued NPDES general permit for the discharge of 

stormwater from land-disturbance sites, as described in Section 4.4.1.1 for construction. NWMI 

would use appropriate construction BMPs, including waste handling and pollution prevention 

practices and response procedures during decommissioning, so that no materials or 

contaminants are released to soils, surface water, or underlying groundwater.
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NWMI would conduct work in accordance with a decommissioning plan submitted to the NRC. 

NWMI would be required to conduct necessary surveys of the soils and subsurface to comply 

with the NRC’s radiological criteria for license termination in 10 CFR Part 20, Subpart E. The 

NRC staff also expects that NWMI would sample soils and other media as necessary in 

accordance with other required local and State permits and approvals to ensure that no 

nonradiological contamination remains in excess of action levels.

Water would be required for dust control and soil compaction during decommissioning. Based 

on facility size and dimensions as compared to the proposed technology alternative, the NRC 

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

/day) during the decommissioning period. 

The NRC staff assumes that Consolidated Public Water Supply District No. 1 would also supply 

water needed for decommissioning. The projected water volume needed is less than the 

volume required for facility construction, as discussed above, and the impacts on supply 

capacity would similarly be negligible.

Since decommissioning activities would be conducted in accordance with pollution prevention 

and spill response procedures as part of local and State permit requirements for 

ground-disturbing activities and water needs would be minimal, the NRC staff concludes that the 

impacts on surface water and groundwater resources from facility decommissioning would be 

SMALL.

5.3.2.5 Ecological Resources

The linear accelerator-based alternative would disturb a similar amount of land as the proposed 

NWMI facility. Directly affected vegetation would be limited to non-native, common, or weedy 

species, which are abundant within the region and provide relatively low-quality habitat for birds 

and wildlife in comparison to forests, grasslands, and wetland habitats. In addition to a loss of 

habitat, noise from construction activities could disturb birds and wildlife. In response to such 

disturbances and loss of habitat, birds and wildlife could move out of the immediate area and 

find adequate, similar habitat (agricultural fields) within the vicinity. All other impacts on 

ecological resources, such as bird collisions, disturbance during maintenance activities, and 

potential runoff to offsite aquatic resources, are expected to be similar to those described for the 

proposed NWMI facility in Section 4.5 because of similar construction methods, similar amount 

of land disturbed, and similar operating and decommissioning activities. Therefore, the NRC 

staff concludes that the impacts on ecological resources from a linear accelerator-based facility 

at the Discovery Ridge site would be SMALL during construction, operations, and 

decommissioning.

5.3.2.6 Historic and Cultural Resources

Impacts to historic and cultural resources from the linear accelerator-based alternative would be 

similar to those described for the proposed NWMI facility in Section 4.6. With no historic 

properties affected, no archaeological sites or evidence of cultural resources identified during 

the Phase I survey (NWMI 2015a), tribal input, and the cultural resource assessment and 

consultations performed by the NRC staff, constructing, operating, and decommissioning the 

NWMI facility using this alternative technology would not impact any known historic and cultural 

resources at the Discovery Ridge site.

5.3.2.7 Socioeconomics

Socioeconomic impacts from the linear accelerator-based alternative would be similar to those 

described for the proposed NWMI facility in Section 4.7. This technology alternative would 

require up to 50 construction workers and up to 150 workers during facility operations. The 

number of construction workers for the linear accelerator-based alternative would be fewer than 
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the subcritical fission process alternative and the proposed NWMI facility. The number of 

operation workers for the linear accelerator-based alternative and the subcritical fission process 

alternative would be the same but higher than the proposed NWMI facility. These are peak

estimates of workers, and the average daily number of operations workers would be much less. 

Most, if not all, workers would likely reside within the ROI or adjacent counties and communities 

and commute to the work site. Even if the estimated number of operations workers (150) were 

to generate two to three times additional employment in the ROI, the combined total number of 

workers would represent less than three-quarters of a percent of the current civilian labor force 

in Boone County. This would have little to no noticeable effect on employment levels or public 

services demands in the ROI. Given the size of the workforce, socioeconomic impacts for 

constructing, operating, and decommissioning the linear accelerator-based technology 

alternative at the Discovery Ridge site would be SMALL.

5.3.2.8 Human Health

The NRC staff expects human health impacts from the linear accelerator-based alternative to be 

similar to those described in Section 4.8 for the proposed NWMI facility. Like the proposed 

NWMI facility, the linear accelerator-based facility would be required to comply with all Federal 

and State regulations, protecting workers and members of the public during construction, 

operations, and decommissioning. For example, OSHA regulations would protect workers from 

physical occupational hazards; OSHA and EPA regulations would protect workers and the 

public from hazardous material and chemical hazards; and NRC regulations would protect 

workers and the public from radiological hazards. Additionally, the NRC staff expects that for 

both radiological and nonradiological hazards, the linear accelerator-based alternative would 

incorporate engineered design features and procedural controls to minimize any impacts to 

workers or the public (DOE 2012).

Operation of the linear accelerator-based facility would require transportation of nonradioactive 

natural molybdenum target material to the facility. Radioactive materials transportation 

associated with the linear accelerator-based facility would include transportation of Mo-99

product from the facility to an end user medical facility, and transportation of the spent or 

unusable portion of Mo-99 product back to the linear accelerator-based facility for reuse. 

However, since the linear accelerator-based facility would not use or handle LEU, no 

transportation of irradiated or unirradiated LEU targets would occur in conjunction with operation 

of the facility (DOE 2012). All transportation would be in compliance with NRC and DOT

regulations.

Given the safety-oriented design and procedures at a facility using the linear accelerator-based 

alternative, and given that this facility would be required to comply with all Federal and State of 

Missouri regulations, ensuring that public health and safety are protected, the NRC staff 

concludes that the human health impacts from construction, operations, and decommissioning 

of the linear accelerator-based alternative would be SMALL.

5.3.2.9 Waste Management

The NRC staff assumes that waste management impacts from the linear accelerator-based 

alternative would be similar to those described in Section 4.9 for the proposed NWMI facility. 

Based on comparisons with similar proposed linear accelerator-based facilities, the NRC staff 

expects that the linear accelerator-based alternative would generate approximately 160 metric 

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

) of low-level 

radioactive waste, 2.4 m3 (3.1 yd3

) of hazardous waste, and 45 m3 (59 yd3) of nonradioactive, 

nonhazardous waste annually (DOE 2012). Compared to the volumes of waste that would be 

produced by the proposed NWMI facility (NWMI 2015c), these volumes of hazardous and 
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nonradioactive, nonhazardous waste generated by the linear accelerator-based alternative 

would be similar, and the volume of radioactive waste would be significantly smaller. As 

discussed in Section 4.14.9, the NRC staff assumes that sufficient infrastructure exists in the 

City of Columbia, Missouri, area for proper management of wastes from the proposed NWMI 

facility; therefore, the infrastructure would also be sufficient to handle waste from the linear 

accelerator-based alternative. In addition, the operator of the linear accelerator-based 

alternative would be required to comply with NRC, DOT, State of Missouri, and local 

requirements, as applicable, regarding disposal, handling, and transportation of waste. Since 

adequate infrastructure exists for waste disposal in the City of Columbia, Missouri, area, and 

since waste disposal would be required to be conducted in accordance with all applicable 

regulations, the NRC staff concludes that the impacts from waste management during 

construction, operations, and decommissioning of the linear accelerator-based alternative would 

be SMALL.

5.3.2.10 Transportation

Transportation impacts from the linear accelerator-based alternative would be similar to those 

described for the proposed NWMI facility in Section 4.10. Construction, operations, and 

decommissioning activities would be very similar and over same time span. Transportation 

impacts would consist of commuting workers and truck deliveries and shipments of equipment 

and materials. During periods of peak construction up to 50 workers and during operations up 

to 150 workers could be commuting daily to the work site. Workers would arrive via site access 

roads and the volume of traffic on nearby roads could increase during shift changes. In addition 

to commuting workers, trucks would be transporting equipment and materials to and from the 

work site, thus increasing the amount of traffic on local roads. Up to 10 to 20 truck shipments 

per day would occur during operations (DOE 2012). The increase in vehicular traffic would 

peak during shift changes, resulting in temporary levels of service impacts and delays at 

intersections. However, given the size of the average daily workforce, the number of daily truck 

deliveries and shipments combined with the easy access to U.S. Highway 63, there would be 

little if any noticeable traffic volume-related level of service impacts. Therefore, transportation 

impacts during the construction, operations, and decommissioning of the NWMI facility using the 

linear accelerator-based technology at the Discovery Ridge site would be SMALL.

5.3.2.11 Accidents

DOE previously assessed a range of accidents involving either radioactive Mo-99, or chemicals 

that would be used during Mo-99 production, for a potential linear accelerator-based facility 

(DOE 2012). The accident scenarios were chosen such that the accidents considered would 

represent the range of possible accident consequences given the design, operating parameters, 

and types of materials that would be present at the facility. Possible internal accidents 

(e.g., fire), external accidents (e.g., tornado), and sabotage events were all considered. For 

evaluation of impacts of accidents to members of the public, DOE’s assessment considered the 

nearest member of the public to the facility to be located at a site boundary 20 m (65.6 ft) from 

the facility (DOE 2012).

This assessment determined that, for an extremely unlikely severe chemical accident involving 

an explosion-, fire-, earthquake-, or tornado-induced release of helium from the facility (the 

highest-consequence chemical accident considered), assuming average meteorological 

conditions, PAC-1, PAC-2, and PAC-3 limits would not be exceeded at the location of the 

maximally exposed member of the public. This means that no significant health effects would 

be expected for members of the public as a result of this accident for average meteorological 

conditions (PAC-1, PAC-2, and PAC-3 limits are defined in Section 4.11.2). However, DOE’s 

assessment also determined that, for 95th percentile meteorological conditions 
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(i.e., meteorological conditions that would result in greater exposure than the conditions that 

occur 95 percent of the time), the helium concentration at the location of the maximally exposed 

member of the public would exceed the PAC-3 limits; concentrations above PAC-3 limits could 

result in life-threatening health effects or death. (DOE 2012).

DOE’s assessment considered two broad types of radiological accidents: accidents or events 

that could result in an airborne release of radioactive material, and accidents that could result in 

direct radiation exposure. The assessment determined that, for a sabotage event (i.e., an 

intentional action by a person inside or outside of the facility intending to cause harm to workers

or members of the public) resulting in an airborne release of Mo-99, the dose to a maximally 

exposed member of the public would be 130 mrem for average meteorological conditions, and 

560 mrem for 95th percentile meteorological conditions. This was the highest consequence 

airborne release of radioactive material accident or event considered. The assessment also 

determined that, for an earthquake-, tornado-, or aircraft impact-induced accident that damages 

the facility, exposing an irradiated target and causing direct radiation exposure (the highest 

consequence direct radiation exposure accident considered), the dose to a maximally exposed 

member of the public from 1 hour of exposure would be 1,100 mrem (DOE 2012).

For the bounding chemical and radiological accidents discussed above, PAC-1/2/3 limits, and 

10 CFR Part 20 public dose limits, respectively, would be exceeded. However, the NRC staff 

expects that a linear accelerator-based facility would include additional engineered designed 

features and procedural controls that would mitigate the consequences of these accidents. 

Before construction or operation of a linear accelerator-based facility, the NRC staff would 

perform a safety review of the proposed facility that would include a thorough evaluation of 

possible radiological or chemical accidents at the facility, including the consequences of those 

accidents and any features or controls that would mitigate those consequences. To receive a 

construction permit or operating license from the NRC, the applicant would have to demonstrate 

that the facility would be in compliance with all NRC regulations, including 10 CFR Part 20 dose 

limits and accident performance requirements in 10 CFR 70.61, as applicable. If the NRC staff 

determines in its SER for the linear accelerator-based facility that the facility would be operated 

in compliance with all applicable regulations governing the consequences of accidents, then the 

NRC staff concludes that the impacts from accidents at the linear accelerator-based facility 

would be SMALL.

5.3.2.12 Environmental Justice

The environmental justice impacts from a linear accelerator-based alternative would be similar 

as those discussed for the proposed NWMI facility in Section 4.12. Minority and low-income 

populations residing along site access roads could be affected by noise and dust and increased 

commuter vehicle and truck traffic during construction, operations, and decommissioning. 

However, these effects are not likely to be high and adverse and would be short term and within 

a limited time period during certain hours of the day. Noise and dust impacts from onsite 

activities during construction and decommissioning would similarly be short term. Everyone 

living near Discovery Ridge could be affected by operation activities, including minority and 

low-income populations. Any human health and environmental effect would depend on the 

magnitude of the change from current environmental conditions.

As discussed in Section 5.3.2.8 of this EIS, the potential radiological dose to the public from 

facility operations would be well within NRC and applicable Federal, State, and local regulatory 

limits. As a result, everyone living near the Discovery Ridge site, including minority and 

low-income populations, would not be adversely affected by radiation exposure during facility 

operations. Permitted nonradiological air emissions would also be required to remain within 

regulatory standards. Noise levels may increase along U.S. Highway 63 because of increased 
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commuter vehicle and truck traffic during NWMI facility operations. This may not be noticeable, 

however, given the relatively small size of the workforce and the limited number of daily truck 

deliveries and shipments. Based on this information, construction, operations, and 

decommissioning of the proposed NWMI facility using the linear accelerator-based technology 

would not likely have disproportionately high and adverse human health and environmental 

effects on minority and low-income populations living near Discovery Ridge.

5.3.2.13 Cumulative Impacts

Cumulative impacts for the linear accelerator-based alternative would be similar to those 

described in Chapter 4 for the NWMI RPF facility at the Discovery Ridge site, because direct 

contributory effects from construction, operations, and decommissioning for this technology 

would be similar.

5.3.3 Subcritical Fission Technology

The uranium fission technology alternative would produce Mo-99 using a subcritical fission 

process followed by chemical extraction of Mo-99. For the purpose of this analysis, the NRC 

staff assumed the facility would be similar to the facility described in NRC’s Environmental 

Impact Statement for the Construction Permit for the SHINE Medical Radioisotope Production 

Facility, Final Report, NUREG–2183 (NRC 2015c), which considered the environment impacts 

of the facility proposed in the SHINE Medical Technologies, Inc.’s Construction Permit 

Application (SHINE 2015).

The first stage in the radioisotope production process for this alternative is the production of 

neutrons, which induce the fission of uranium, resulting in the formation of radioisotopes. 

During the irradiation stage, a neutron driver (accelerator) affixed above a subcritical operating 

assembly would accelerate deuterium ions into a chamber filled with tritium gas. This chamber 

would be centered within the subcritical operating assembly which contains a vessel containing 

LEU target solution in the form of uranyl sulfate. The resulting ion beam would strike the tritium 

gas and produce helium nuclei and neutrons. These additional neutrons would pass through a 

neutron multiplier, which would produce additional neutrons (SHINE 2015).

The neutrons would then pass into the LEU target solution within one of several irradiation units, 

causing the uranium-235 in the solution to fission (split) and produce byproduct materials, 

including Mo-99. The target solution in each irradiation unit would be maintained at a subcritical 

level (i.e., a level at which the uranium-235 fission and the consequent neutron production in the 

target solution vessel would not be self-sustaining). Mo-99, xenon-133, and iodine-131

production would occur within the target solution from fission during the irradiation cycle. An 

offgas system would be used during this stage to handle and contain radiolytic and fission 

product gases released from the target solution. The target solution vessel would be 

surrounded by a light-water pool. This pool would be used to control the temperature of the 

target solution vessel, reflect neutrons back into the vessel, shield radiation, and absorb heat 

resulting from the fission process (SHINE 2015).

At the end of the irradiation cycle in each irradiation unit, the target solution would be removed 

from the target solution vessel and transferred through piping to one of three hot cells (shielded 

nuclear radiation confinement chambers) where the Mo-99 would be selectively extracted and 

purified using a chemical process (SHINE 2015; NRC 2015c). Following extraction and 

purification, the separated radioisotopes would be packaged and distributed.

At full operational capacity, the facility could produce up to 8,200 6-day curies (Ci 6-day) per 

week of the medical radioisotope Mo-99 (SHINE 2015). To meet this production schedule, each 
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irradiation unit would need to operate continuously for about 5.5 days. Radioisotope production 

functions would operate close to 7 days per week (SHINE 2015).

A description of the affected environment for the Discovery Ridge site is provided in Chapter 3 

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 

(213,000 m3) (SHINE 2015; NRC 2015c). Construction of a subcritical fission-based alternative 

would take 18 months and require a peak workforce of 451 workers (SHINE 2015; NRC 2015c). 

Operation of a subcritical fission-based alternative would require a peak workforce of 

150 workers for 30 years (SHINE 2015; NRC 2015c). The decommissioning phase would be 

6 months and require a peak workforce of 261 workers (SHINE 2015; NRC 2015c). The 

following sections describe the impacts of constructing, operating, and decommissioning the 

proposed NWMI facility using the subcritical fission-based technology.

5.3.3.1 Land Use and Visual Resources

Land use impacts of a subcritical fission-based alternative at the Discovery Ridge site would be 

confined to the 7.4 ac (3.0 ha) site. The fission-based alternative would disturb a similar amount 

of land as the proposed NWMI facility (NRC 2015c). The highest structure would be the 

emissions stack, which would extend approximately 66 ft (20 m) in height (NRC 2015c). 

Therefore, the height of the buildings for the fission-based alternative would be bounded by the 

parameters analyzed for the NWMI facility in Section 4.1. As described in Section 4.1, land use 

impacts during construction, operations, and decommissioning would be SMALL, because the 

entire site is currently certified for industrial use, and the permanently converted agricultural land

would be a small portion of available agricultural land within the vicinity. As described in 

Section 4.1, aesthetic impacts during construction, operations, and decommissioning would be 

SMALL at the proposed Discovery Ridge site, given that a light industrial development 

landscape surrounds part of the site and the visual setting is generally flat and has a uniform 

landform with low vegetation diversity and a low visual-quality rating. Based on a similar 

amount of land disturbed and building height for the subcritical fission facility alternative, land 

use and visual impacts would be SMALL during construction, operations, and decommissioning 

of a subcritical fission facility on the Discovery Ridge site.

5.3.3.2 Air Quality and Noise

A description of the air quality and noise affected environment for the Discovery Ridge site is 

provided in Section 3.2 of the EIS.

Air Quality

Construction

Construction activities associated with building a subcritical fission facility would generate air 

pollutant emissions from site-disturbing activities (e.g., grading, compacting), operation of 

construction equipment, and worker and shipment vehicles. Construction-related emissions are 

presented in Table 5–8.

Estimated Air Emissions Resulting from Construction of a

Subcritical Fission Facility

Total Emissions (tons/year)(a)

Nitrogen Oxides (NOx) 278

Carbon Monoxide (CO) 184

Sulfur Dioxide (SO2) 18
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Total Emissions (tons/year)(a)

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.

Emissions would be greater than construction of the proposed NWMI facility because the 

subcritical fission facility would be a larger facility that would require a larger workforce and 

additional equipment. Emissions would exceed the significant de minimis levels under the New 

Source Review program discussed in Section 3.2.2. However, total construction emissions

would be 4 percent or less of the Boone County annual emissions for each criteria pollutant and 

carbon dioxide. Further, these emissions are bounding conditions that assume conservative 

equipment activities and conservative workforce commute distances (NRC 2015c). Additionally, 

the facility may be required to obtain and abide by applicable construction air permits to prevent 

degradation of air quality in Boone County. Therefore, the NRC staff concludes that the air 

quality impacts during construction would be SMALL.

Operations

Operation of a subcritical fission facility would produce air emissions from fuel combustion 

associated with processing and facility heating purposes (boilers and heaters), an emergency 

generator, target solution preparation, and worker vehicles. Total emissions from these sources 

are presented in Table 5–9.

Estimated Air Emissions Resulting from Operation of a 

Subcritical Fission 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.

Total operation-related emissions for criteria pollutants are well below the significant de minimis 

levels under the New Source Review program and major sources under Title V operating 

sources threshold (100 TPY) discussed in Section 3.2.2 of this EIS. Therefore, the NRC staff 

does not expect increases in air emissions from operation to contribute to concentrations that 

would interfere with the maintenance of NAAQS or degrade Boone County’s 

unclassifiable/attainment designation. Therefore, the NRC staff concludes that the air quality 

impacts during operation of a subcritical fission facility would be SMALL.
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Decommissioning

Activities associated with decommissioning of a subcritical fission facility would generate air 

pollutant emissions from site-disturbing activities, operation of equipment, worker vehicles, and 

demolition of structures, and dismantlement and decontamination of systems. Total emissions 

from these sources are presented in Table 5–10.

Estimated Air Emissions Resulting from Decommissioning of a 

Subcritical 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.

Emissions would be greater than decommissioning of the proposed NWMI facility as a result of 

the subcritical fission facility being a larger facility that would require a larger workforce and 

additional equipment. Emissions would exceed the significant de minimis levels under the New 

Source Review program discussed in Section 3.2.2. However, decommissioning emissions

would be 2 percent or less of the Boone County annual emissions for each criteria pollutant and 

carbon dioxide. Further, these emissions are based upon bounding conditions. For instance, a 

100-mi (160-km) roundtrip worker commute for each employee and simultaneous continuous 

use of construction equipment were assumed (NRC 2015c). Additionally, the facility may be 

required to obtain and abide by applicable air permits to prevent degradation of air quality in 

Boone County. Therefore, the NRC staff concludes that the air quality impacts during 

decommissioning would be SMALL.

Noise

Construction

Noise emissions during construction would occur because of increased traffic volumes from 

worker vehicles and because of the use of construction equipment on site. The maximum 

number of worker vehicles expected on site during construction is 451, all of which, for purposes 

of this analysis, are assumed to travel along U.S. Highway 63 during hours when work starts 

and stops. Sound levels increase at a rate of 3 dBA per doubling of traffic volumes. Traffic 

volume along U.S. Highway 63 is 818 vehicles/hr (NWMI 2016a; NWMI 2016c). Conservatively 

assuming that all worker vehicles and deliveries travel on U.S. Highway 63 at the same time, 

this will result in a traffic volume of 1,259 vehicles/hr. This increase in traffic will not result in 

noise levels that will be noticeable.

Construction equipment for a subcritical fission facility would be similar to construction 

equipment for the proposed NWMI facility. However, because the subcritical fission facility 

would be a larger facility, multiple numbers of similar equipment are assumed to be used 

simultaneously (NRC 2015c). Simultaneous use of multiple equipment may result in greater 
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noise levels than single-use equipment. For example, simultaneous use of three pieces of 

equipment, each with noise levels of 85 dBA, results in a combined noise level of 90 dBA. 

However, accounting for attenuation of noise levels from construction equipment to nearby 

noise sensitive receptors at the Discovery Ridge, site noise emissions from construction 

equipment are not expected to be noticeable or exceed existing noise levels at the sensitive 

receptors. Further, noise from construction equipment would be localized, short term, and 

intermittent during machinery operations.

Given that increases in noise levels as a result of additional vehicle traffic will not be noticeable 

and noise levels from construction equipment are not anticipated to exceed existing ambient 

noise levels, the NRC staff concludes that offsite noise impacts from construction would be 

SMALL.

Operations

Noise emissions during operation would occur because of increased traffic. Noise from 

operating equipment would be contained inside buildings and is not anticipated to be audible 

outside the subcritical fission facility (NRC 2015c). The number of worker vehicles expected 

during operation is 150. Adding this traffic volume to existing traffic levels along 

U.S. Highway 63 will not result in noise levels that would be noticeable (i.e., less than 3-dBA 

increase). Therefore, the NRC staff concludes that noise impacts from operation of a subcritical 

fission facility at the Discovery Ridge site would be SMALL.

Decommissioning

Noise emissions during decommissioning would occur because of increased traffic volumes 

from worker vehicles and the use of equipment on site. The maximum number of worker 

vehicles expected on site during decommissioning is 261, all of which, for purposes of this 

analysis, are assumed to travel along U.S. Highway 63 during hours when work starts and 

stops. Sound levels increase at a rate of 3 dBA per doubling of traffic volumes. Conservatively 

assuming that all worker vehicles and deliveries travel on U.S. Highway 63 at the same time, 

this will result in a traffic volume of 1,079 vehicles/hr. This increase in traffic will not result in 

noise levels that will be noticeable from a traffic volume of 818 vehicles/hr.

Equipment during decommissioning would be similar to that used during the construction phase. 

As discussed above, noise levels from construction equipment for a subcritical fission facility are 

not expected to exceed existing noise levels. Therefore, given that increases in noise levels as 

a result of additional vehicle traffic will not be noticeable and that noise levels from equipment 

are not anticipated to exceed existing ambient noise levels, the NRC staff concludes that noise 

impacts from decommissioning a subcritical fission facility at the Discovery Ridge site would be 

SMALL.

5.3.3.3 Geologic Environment

Geology and Soils

Construction

Impacts on geology and soils associated with construction of a subcritical fission process facility 

at the Discovery Ridge site would be similar to but somewhat greater than the impacts 

described for the proposed technology, as presented in Section 4.3.1. The potential for greater 

impacts under this technology alternative is attributable to the larger footprint of the subcritical 

fission process facility (91,000 ft2 (8,500 m2

)) and the greater depth of excavation required 

(i.e., up to 39 ft (12 m)) to construct the below-grade portions of the facility (NRC 2015c). 

Because the depth to bedrock beneath the site is on the order of 25 ft (7.6 m) or less 

(Section 3.3.1), it is probable that blasting and other construction methods may be required 
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during foundation excavation. The NRC staff further assumes that the entire 7.4 ac (3.0 ha) site 

would be disturbed during construction of the subcritical fission process facility.

The larger footprint that would be cleared, graded, and compacted along with the greater 

excavation depth would increase the potential for soil erosion and loss. Nevertheless, 

construction activities would be subject to the same site development permitting and associated 

regulatory requirements previously described in Section 4.3.1. For instance, NWMI would need 

to conduct site work in accordance with a Land Disturbance Permit from the City of Columbia in 

accordance with Chapter 12A, Article II (Land Preservation) of the City’s Code of Ordinances 

(City of Columbia 2015). NWMI would need to prepare a soil erosion and sediment control plan 

and a stormwater management plan. These plans entail the implementation of 

construction-related BMPs for soil erosion and sediment control and stormwater pollution 

prevention during site development, facility construction, and for post development.

As described in Sections 3.3.1 and 3.3.2 and evaluated for potential impacts in Sections 4.3.1 

and 5.3.2.3, the Discovery Ridge site presents construction challenges that will need to be 

addressed during facility construction, along with mitigative features incorporated into the 

facility. These challenges include the depth to bedrock, the potential for a seasonally high water 

table or perched groundwater, and the occurrence of soils with construction limitations (e.g., fat 

clays with a high shrink/swell potential). NWMI would conduct site-specific geotechnical and 

hydrological studies of the Discovery Ridge site to characterize site conditions in support of final 

subcritical fission facility design.

As summarized in Section 2.2, Table 2–1, for the proposed alternative, geologic resources 

would also be required to support construction of a subcritical fission process facility; these 

resources include granular stone (e.g., typically crushed aggregate (sand and gravel)) and 

aggregates to produce ready-mix concrete. The volumes required would be proportionally 

greater for this technology alternative as compared to either the proposed technology or the 

linear accelerator-based facility alternatives. Specifically, projected geologic resource 

requirements to construct the subcritical fission process facility include, but are not limited to, 

16,000 yd3 (12,233 m3

) of crushed stone material (NRC 2015c). Nevertheless, as noted in 

Section 3.3.1, construction aggregate is widely available throughout Boone County and 

northeast Missouri and so their consumption to support facility construction under this 

alternative would not likely deplete local or regional stockpiles of such geologic resources.

Because of the larger facility footprint and, especially, the greater depth of excavation required 

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

) of soil, sediments, and 

rock material. This is considerable in comparison to the excavation volumes of 28,000 yd3 

(21,000 m3) and 9,000 yd3 (6,900 m3) associated with the linear accelerator-based facility and 

proposed technology alternative, respectively. For construction of a subcritical fission process 

facility, NRC (2015) indicated that materials needed for backfill around structures and topsoil for 

use in miscellaneous earthwork and final surface preparation would be reclaimed from onsite, 

excavated material and prepared as necessary to meet structural requirements. Nonetheless, 

soils at the Discovery Ridge site, particularly the fat clays, have poor shear strength when 

wetted and have generally poor workability as a construction material, including for use as 

structural (engineered) backfill (Section 3.3.1). Thus, the NRC staff assumes that at least some 

proportion of this excavated material would need to be replaced with engineered backfill from 

offsite sources, thus adding to the volume of onsite earthwork required and geologic materials 

consumed. Due to the diversity of soil types in the region, the NRC staff concludes that soils 

with the necessary engineering properties are readily obtainable from sources throughout the 

City of Columbia area and across Boone County or from sources elsewhere in central and 

eastern Missouri.
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Under this alternative, the potential impact on the geologic environment from deep excavation 

work, potential soil loss, and geologic resource consumption would be greater than under both 

the linear accelerator-based facility and proposed technology alternatives. Because of the 

larger facility size and the need for deep excavation, site conditions would present greater 

constraints on site development and facility construction. Completion of detailed site-specific 

geotechnical studies would serve to inform construction planning and final facility design. In 

consideration of the above factors, the NRC staff concludes that the impacts on the geologic 

environment from the construction of a subcritical fission process facility at the Discovery Ridge 

site would also be SMALL.

Operations

Operational impacts on the geologic environment would be negligible under this technology 

alternative. 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 (such as roadways and parking lots), 

or revegetated.

Regardless of the technology, final facility design and construction would comply with applicable 

building codes and standards, which provide for the evaluation of site geologic and soil

conditions, including potential seismic hazards. Completion of site-specific geotechnical and 

hydrological studies, as discussed in Section 4.3.1, would inform final facility design and 

construction considerations. The NRC staff concludes that subcritical fission process facility 

operational impacts associated with the geologic environment at the proposed site would be 

SMALL.

Decommissioning

Compacted site soils and underlying sediments would be disturbed by facility demolition and 

decontamination work. The impacts on site geology and soils would be similar in scope to those 

described for construction. For the subcritical fission process facility, the potential for soil

erosion and loss during decommissioning would be greater than for either the linear 

accelerator-based facility or proposed technology primarily because of the larger facility footprint 

and extensive below-grade portions of the facility. Nonetheless, all site clearing to restore the 

proposed site to a reusable condition would be subject to applicable permits and approvals 

(e.g., demolition or clearance permit), and the applicable provisions including Chapter 6, Article 

II (Building Code) of the City of Columbia’s Code of Ordinances (City of Columbia 2015).

Before beginning to dismantle onsite structures, NWMI would remove waste materials and 

contaminated media from the structures. Materials would be packaged and properly disposed 

of as discussed in Section 5.3.3.9. Thus, these materials would not pose a contamination threat 

to site soils or water resources. NWMI would be required to conduct all decommissioning 

activities in accordance with a decommissioning plan submitted to the NRC and applicable 

regulations, as described in Section 2.9. The NRC staff concludes that impacts on the geologic 

environment from facility decommissioning under this technology alternative would be SMALL.

5.3.3.4 Water Resources

Surface Water and Groundwater Resources

Construction

Impacts on surface water and groundwater resources from construction activities associated 

with the subcritical fission process alternative would be similar to but greater than those under 

both the linear accelerator-based and proposed technology alternatives (see 

Sections 4.4.1.1, 4.4.2.1, and 5.3.2.4). The potential for greater impacts is attributable to the 
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additional land affected because of the larger footprint of the facility and the greater depth of 

excavation, as referenced in Section 5.3.3.3. Otherwise, the same general assumptions, impact 

considerations, and regulatory parameters discussed for the linear accelerator-based and 

proposed technology alternatives apply to this alternative discussion.

During construction, stormwater runoff from construction areas could potentially affect 

downstream surface water quality if not properly managed. NWMI would be required to obtain a 

Land Disturbance Permit from the City of Columbia and submit related plans for city approval 

before any ground-disturbing activities or facility construction could commence on the site, as 

referenced in Section 5.3.3.3. The City would require that appropriate soil erosion and sediment 

control BMPs be used to minimize soil erosion and the stormwater transport of suspended 

sediment and other pollutants.

Construction stormwater runoff from the construction would also be subject to regulations in 

accordance with CWA Section 402. Under the State of Missouri’s delegated authority for 

administering the NPDES permit program pursuant to Section 402, the State has developed an 

NPDES general permit for construction stormwater. Permit coverage must be obtained by 

owners and operators for the discharge of stormwater and certain non-stormwater discharges

(e.g., dewatering flows) from land-disturbance sites that disturb 1 ac (0.4 ha) or more, as further 

described in Section 4.4.1.1. NWMI’s construction activities would be subject to NPDES permit 

and other local regulations for soil erosion and sediment control and construction stormwater 

management.

In addition, under CWA Section 401, an applicant for a Federal license or permit to conduct any 

activities, including facility construction or operation, that may cause a discharge of regulated 

pollutants into navigable waters is required to provide the Federal licensing agency with a 

certification from the state or agency having jurisdiction in which the discharge would originate. 

As discussed in Section 4.4.1.1 for the Discovery Ridge site, NWMI has stated that no State 

certification is required under CWA Section 401 (NWMI 2015a). NWMI also has stated that it 

would seek a waiver from the State (NWMI 2015c). However, because the NRC cannot issue a 

construction permit until the required certification is submitted, NWMI must provide the NRC 

with either a 401 certification from the State of Missouri, a waiver, or State documentation that a 

Section 401 certification is not necessary.

The need for groundwater dewatering would be very likely under this alternative. This is 

because of the greater depth of excavation (i.e., up to 39 ft (12 m)) expected for the 

below-grade portion of the subcritical fission process facility. The volume of groundwater 

requiring removal could be much greater, depending on the depth and extent of groundwater, 

than the maximum volume projected by NWMI for the proposed technology, as described in 

Section 4.4.2.1. Consequently, the NRC staff expects that dewatering could have localized 

effects on the vertical and horizontal extent of shallow groundwater and on groundwater flow 

direction, although the impacts would likely be temporary. NWMI has committed to 

commissioning site-specific geotechnical and hydrologic studies of the Discovery Ridge site. 

These studies would characterize groundwater conditions beneath the site and would guide any 

necessary construction accommodations and final facility design.

As previously discussed, the Discovery Ridge site is served by public water, with service 

provided by Consolidated Public Water Supply District No. 1 (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

/day) and currently supplies approximately 1.45 mgd (5,490 m3/day) to customers.

Under this technology alternative, onsite water needs to support facility construction would be 

greater than under both the linear accelerator-based and proposed technology alternatives. 

The NRC staff estimates that construction activities would require an average of 12,000 gpd 
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(45,400 Lpd) of water. This is equivalent to 0.012 mgd (45.4 m3

/day). Total projected water use 

for the construction period (18 months) is about 4.3 million gal (16.3 million L), excluding water 

required for concrete production and preoperational testing (NRC 2015c). The projected 

average daily water needs for construction under this technology alternative would still be a 

small percentage (i.e., about 0.8 and 0.11 percent) of the public water district’s existing demand 

and available production capacity, respectively.

For construction under this technology alternative, NWMI would be required to prepare 

site-specific plans and implement BMPs in accordance with local and MDNR requirements to 

mitigate the potential impacts on surface water quality. No surface water features would be 

disturbed and no surface water or onsite groundwater would be used to support facility 

construction. Construction dewatering would be very likely during construction, but site-specific 

geotechnical and hydrologic studies will further characterize subsurface conditions, and 

dewatering activities would be conducted in accordance with regulatory requirements. The 

volume of water required to support onsite construction activities would be a small percentage 

of the public utility’s existing demand and available production capacity. The NRC staff 

concludes that the impacts on surface water and groundwater hydrology, quality, and use from 

the construction of a subcritical fission process facility would be SMALL.

Operations

Normal facility operations would not have any direct impact on surface water or groundwater 

hydrology or quality under this technology alternative. Consistent with the previously described 

alternatives, stormwater runoff from the facility site would be managed by an engineered 

stormwater management system, constructed and operated in compliance with applicable local, 

State, and Federal stormwater management permits, plans, procedures, and practices.

Projected water demands for operation of a subcritical fission process facility under this 

alternative are higher than for either the linear accelerator-based technology or proposed 

technology alternatives. Water would be required for potable and sanitary uses, fire protection, 

heating and cooling system makeup, and makeup for the radioisotope production process, with 

the largest use attributable to potable and sanitary water use by the facility workforce 

(NRC 2015c).

Total water use is projected to be 6,073 gpd (22,990 Lpd), equivalent to 0.0061 mgd 

(23 m3

/day), to support facility operations under this alternative (NRC 2015). Consolidated 

Public Water Supply District No. 1 would also provide water service under this alternative. 

While higher when compared to the other technology alternatives, the projected average daily 

water use is a negligible percentage of the production capacity of the water district and 

represents a very small increase (about 0.4 percent) in the volume of water the district supplies 

to its customers.

Consistent with the other technologies, no radiological liquid effluents would be discharged to 

the environment under this technology alternative. All facility operations would be contained 

inside properly constructed buildings with waste management systems and programs in place to 

control, handle, process, store, and transport the types and quantities generated by the medical 

radioisotope production process (NRC 2015c).

Facility wastewater would normally consist of sanitary wastewater and boiler blowdown from the 

facility’s heated water system. In addition, facility personnel may periodically convey small 

quantities of maintenance and laboratory chemicals to the facility’s sanitary sewer drains. As for 

water use, wastewater generation would be higher under this technology alternative when 

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

/day) (NRC 2015c). This effluent would 
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be discharged to the City of Columbia sanitary sewer system for treatment at the Columbia 

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/day). The effluent flow under 

this technology alternative would be a very small percentage (i.e., 0.15 percent) of the available 

treatment capacity of the WWTP. The effluent would be required to meet the sewer system’s 

influent acceptance and treatment criteria, as well as NRC’s regulations at 10 CFR 20.2003.

There would be no radiological or nonradiological impacts on surface water or groundwater 

during normal operations under this technology alternative. Facility operations would need to 

comply with applicable regulatory requirements and would be conducted in accordance with 

appropriate practices. Water requirements and sanitary effluent treatment needs would be met 

by public facilities, which have adequate capacity. Therefore, the NRC staff concludes that the 

impacts on surface and groundwater hydrology, water quality, and water use from the operation 

of a subcritical fission process facility would be SMALL.

Decommissioning

Facility decontamination, demolition, and site-restoration activities would be similar to those 

under the other technology alternatives, with the potential magnitude of the impacts on surface 

water and groundwater similar to those discussed above for construction. NWMI would perform 

demolition and site-restoration activities in accordance with applicable local and State permits 

and approvals, including a State-issued NPDES general permit for the discharge of stormwater

from land-disturbance sites. NWMI would use appropriate construction BMPs, including waste 

handling and pollution prevention practices and response procedures during decommissioning, 

so that no materials or contaminants are released to soils, surface water, or underlying 

groundwater.

NWMI would conduct work in accordance with a decommissioning plan submitted to the NRC. 

NWMI would be required to conduct necessary surveys of the soils and subsurface to comply 

with the NRC’s radiological criteria for license termination in 10 CFR Part 20, Subpart E. The 

NRC staff also expects that NWMI would sample soils and other media as necessary in 

accordance with other required local and State permits and approvals to ensure that no 

nonradiological contamination remains in excess of action levels.

Water would be required for dust control and soil compaction during decommissioning. Based 

on relative facility size and dimensions as compared to the other technology alternatives, the 

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

/day) during the decommissioning 

period. The NRC staff assumes that Consolidated Public Water Supply District No. 1 would 

supply water needed for decommissioning. The projected water volume needed is less than the 

volume required for facility construction, as discussed above, and the impacts on supply 

capacity would similarly be very small.

Considering the above, the NRC staff concludes that the impacts on surface water and 

groundwater resources from decommissioning of a subcritical fission process facility under this 

alternative would be SMALL.

5.3.3.5 Ecological Resources

The subcritical fission-based alternative would disturb a similar amount of land as the proposed 

NWMI facility. Directly affected vegetation would be limited to non-native, common, or weedy 

species, which are abundant within the region and provide relatively low-quality habitat for birds 

and wildlife in comparison to forests, grasslands, and wetland habitats. In addition to a loss of 

habitat, noise from construction activities could disturb birds and wildlife. In response to such 

disturbances and loss of habitat, birds and wildlife could move out of the immediate area and 
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find adequate, similar habitat (agricultural fields) within the vicinity. All other impacts on 

ecological resources, such as bird collisions, disturbance during maintenance activities, and 

potential runoff to offsite aquatic resources, are expected to be similar to those described for the 

proposed NWMI facility in Section 4.5 because of similar construction methods, similar amount 

of land disturbed, and similar operating and decommissioning activities. Therefore, the NRC 

staff concludes that the impacts on ecological resources would be SMALL during construction, 

operations, and decommissioning of a subcritical fission facility on the Discovery Ridge site.

5.3.3.6 Historic and Cultural Resources

Impacts to historic and cultural resources from the subcritical fission process alternative would 

be similar to those described for the proposed NWMI facility in Section 4.6. With no historic 

properties affected, no archaeological sites or evidence of cultural resources identified during 

the Phase I survey (NWMI 2015a), tribal input, and the cultural resource assessment and 

consultations performed by the NRC staff, constructing, operating, and decommissioning the 

NWMI facility using the subcritical fission technology would not impact any known historic and 

cultural resources at the Discovery Ridge site. 

5.3.3.7 Socioeconomics

Socioeconomic impacts from the subcritical fission process alternative would be similar to those 

described for the proposed NWMI facility in Section 4.7. Although this technology alternative 

would require a higher number of workers to construct (up to 450), operate (up to 150), and 

decommission (up to 260) than for the proposed NWMI facility, these are peak estimates of 

workers, and the average daily number of construction and decommissioning workers would be 

much less. Most, if not all, workers would likely reside within the ROI or adjacent counties and 

communities and commute to the work site. Even if the estimated number of operations 

workers (150) were to generate two to three times additional employment in the ROI, the 

combined total number of workers would represent less than three-quarters of a percent of the 

current civilian labor force in Boone County. This would have little to no noticeable effect on 

employment levels or public service demand in the ROI. Given the size of the workforce, 

socioeconomic impacts from the construction, operations, and decommissioning of the 

proposed NWMI facility using the subcritical fission process technology at the Discovery Ridge 

site would be SMALL.

5.3.3.8 Human Health

The NRC staff expects that human health impacts from the subcritical fission process alternative 

would be similar to those described in Section 4.8 for the proposed NWMI facility. Like the 

proposed NWMI facility, the subcritical fission process facility would be required to comply with 

all Federal, State of Missouri, and local regulations, protecting workers and members of the 

public during construction, operations, and decommissioning. For example, OSHA regulations 

would protect workers from physical occupational hazards; OSHA and EPA regulations would 

protect workers and the public from hazardous material and chemical hazards; and NRC 

regulations would protect workers and the public from radiological hazards.

The NRC evaluated the human health impacts of a subcritical fission technology facility. A 

subcritical fission technology facility would have incorporated engineered design features and 

procedural controls to minimize any impacts to workers or the public from both radiological and 

nonradiological hazards. The maximum dose to a member of the public from radioactive 

gaseous emissions would be approximately 9.0 mrem, which is within 10 CFR Part 20 dose 

limits (SHINE 2015; NRC 2015c). Operation of the subcritical fission technology facility would 

require transportation of fresh LEU to the facility and Mo-99 product from the facility to an end

user medical facility. However, no transportation of irradiated LEU would occur in conjunction 
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with operation of the facility. All transportation would be in compliance with NRC and DOT

regulations.

The NRC staff concluded that, if the facility was constructed, operated, and decommissioned in 

compliance with all applicable regulations, the radiological and nonradiological human health 

impacts from construction, operations, and decommissioning of the subcritical fission process 

facility would be SMALL (NRC 2015c). The NRC staff expects that similar features and controls 

to minimize impacts to workers and the public would be used at other facilities using the 

subcritical fission process. Given the safety-oriented design and procedures at a facility using 

the subcritical fission process alternative, and given that this facility would be required to comply 

with all Federal and State of Missouri regulations, ensuring that public health and safety are 

protected, the NRC staff concludes that the human health impacts from construction, 

operations, and decommissioning of the subcritical fission process alternative would be SMALL.

5.3.3.9 Waste Management

The NRC staff assumes that waste management impacts from the subcritical fission process 

alternative would be similar to those described in Section 4.9 for the proposed NWMI facility. 

Like the proposed NWMI facility, the subcritical fission process alternative facility would be 

required to comply with all applicable Federal, State of Missouri, and local regulations regarding 

waste handling, transportation, and disposal.

The NRC staff evaluated the waste management impacts of a subcritical fission technology 

facility. The facility would produce low-level radioactive waste ranging from Class A through 

greater than Class C (GTCC). The facility would also produce hazardous and nonhazardous 

nonradioactive wastes. The facility would use waste minimization practices, and handling,

storage, and disposal of all wastes would be conducted in compliance with all applicable 

regulations. The NRC staff concluded that, since waste management must be performed in 

compliance with regulations, and since disposal pathways would exist for the types and 

quantities of wastes generated, the impacts from waste management during construction, 

operations, and decommissioning at the subcritical fission process facility would be SMALL 

(NRC 2015c).

The NRC staff expects that similar waste minimization practices would be used at the subcritical 

fission process facility, and that the types and quantities of waste generated would also be 

similar. As discussed in Section 4.14.9, the NRC staff assumes that sufficient infrastructure and 

disposal pathways exist in the Columbia, Missouri, area for proper management of wastes from 

the proposed NWMI facility therefore, the infrastructure would also be sufficient to handle waste 

from the subcritical fission process alternative. For GTCC waste that would be generated at the 

subcritical fission process facility, a provision of the American Medical Isotopes Production 

Act of 2012 (42 U.S.C. 2065(c)(3)(A)(ii)) states that DOE would take title to, and be responsible 

for, the final disposition of radioactive waste created by the irradiation, processing, or 

purification of uranium leased from DOE if it determines that the producer does not have access 

to a disposal path. Therefore, if a disposal pathway for GTCC waste did not exist, DOE would 

be responsible for its disposal.

Because disposal pathways exist for waste that would be generated by the subcritical fission

process facility, and because all handling, storage, transportation, and disposal of wastes would 

be conducted in accordance with all applicable regulations, the NRC staff concludes that the 

impacts from waste management during construction, operations, and decommissioning of the 

subcritical fission process alternative would be SMALL.
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5.3.3.10 Transportation

Transportation impacts from the subcritical fission process alternative would be similar to those 

described for the NWMI facility in Section 4.10. Construction, operations, and decommissioning 

activities would be very similar and over the same time span. Transportation impacts would 

consist of commuting workers and truck deliveries and shipments of equipment and materials. 

During periods of peak construction up to 451 workers, during operations up to 150 workers, 

and during decommissioning up to 261 workers could be commuting daily to the work site. 

These are peak estimates of workers, and the average daily number of construction and 

decommissioning workers would be much less. Workers would arrive via site access roads and 

the volume of traffic on nearby roads could increase during shift changes. In addition to 

commuting workers, trucks would be transporting equipment and materials to and from the work 

site, thus increasing the amount of traffic on local roads. During construction up to 14 trucks, 

during operations an average of 3 trucks, and during decommissioning up to 9 trucks would 

travel to and from the site (NRC 2015c). The increase in vehicular traffic would peak during 

shift changes, resulting in temporary levels of service impacts and delays at intersections. 

However, given the small size of the average daily workforce and the number of daily truck 

deliveries and shipments combined with the easy access to U.S. Highway 63, there would be 

little if any noticeable traffic volume-related level of service impacts. Therefore, transportation 

impacts during the construction, operations, and decommissioning of the proposed NWMI 

facility using the subcritical fission process technology at the Discovery Ridge site would be 

SMALL.

5.3.3.11 Accidents

The NRC staff previously evaluated the environmental impacts from radiological and chemical

accidents at a proposed facility based on the subcritical fission process. This facility would use 

engineered design features and controls to mitigate the consequences of accidents. The 

evaluation showed that public doses from possible radiological accidents would be within 

10 CFR Part 20 limits. The evaluation also showed that, for possible chemical accidents, 

chemical concentrations at the location of the maximally exposed member of the public would 

either be below PAC-1 limits, or above PAC-1 limits but below PAC-2 limits (PAC-1, PAC-2, and 

PAC-3 limits are defined in Section 4.11.2), meaning that chemical accidents could cause mild 

transient adverse health effects but would not cause serious irreversible health effects. The 

NRC staff’s environmental evaluation stated that if the subsequent NRC staff safety evaluation 

determined that radiological and chemical accident exposures would be in compliance with NRC 

regulatory limits (including 10 CFR Part 20 dose limits and chemical accident performance 

requirements in 10 CFR 70.61, as applicable), then the impacts from accidents at the subcritical 

fission process facility would be SMALL (NRC 2015c).

The NRC staff expects that other subcritical fission process facilities would have similar 

engineered design features and controls to mitigate the consequences of accidents, and it also 

expects that the consequences of accidents at other subcritical fission process facilities would 

be similar. Before construction or operation of a subcritical fission process facility, the NRC staff 

would perform a safety review of the proposed facility that would include a thorough evaluation 

of possible radiological or chemical accidents at the facility, including the consequences of 

those accidents and any features or controls that would mitigate those consequences. To 

receive a construction permit or operating license from the NRC, the applicant would have to 

demonstrate that the facility would be in compliance with all NRC regulations, including 

10 CFR Part 20 dose limits and the accident performance requirements in 10 CFR 70.61, as 

applicable. If the NRC staff determines in its SER that the subcritical fission process facility 

would be operated in compliance with all applicable regulations governing the consequences of 
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accidents, then the NRC staff concludes that the impacts from accidents at the subcritical fission 

process facility would be SMALL.

5.3.3.12 Environmental Justice

The environmental justice impacts from the subcritical fission process alternative would be 

similar to those discussed for the NWMI facility in Section 4.12. Minority and low-income 

populations residing along site access roads could be affected by noise and dust and increased 

commuter vehicle and truck traffic during construction, operations, and decommissioning. 

However, these effects are not likely to be high and adverse and would be short term and within 

a limited time period during certain hours of the day. Noise and dust impacts from onsite 

activities during construction and decommissioning would similarly be short term. Everyone 

living near Discovery Ridge could be affected by operation activities, including minority and 

low-income populations. Any human health and environmental effects would depend on the 

magnitude of the change from current environmental conditions.

As discussed in Section 5.3.3.8 of this EIS, the potential radiological dose to the public from 

facility operations would be well within NRC and applicable Federal, State, and local regulatory 

limits. As a result, everyone living near the Discovery Ridge site, including minority and 

low-income populations, would not be adversely affected by radiation exposure during facility 

operations. Permitted nonradiological air emissions would also be required to remain within 

regulatory standards. Noise levels may increase along U.S. Highway 63 because of increased 

commuter vehicle and truck traffic during NWMI facility operations. This may not be noticeable, 

however, given the relatively small size of the workforce and the limited number of daily truck 

deliveries and shipments. Based on this information, construction, operations, and 

decommissioning of the proposed NWMI facility using the subcritical fission process technology 

would not likely have disproportionately high and adverse human health and environmental 

effects on minority and low-income populations living near the Discovery Ridge site.

5.3.3.13 Cumulative Impacts

Cumulative impacts for the subcritical fission-based alternative would be similar to those 

described in Chapter 4 for the NWMI RPF facility at the Discovery Ridge site, because direct 

contributory effects from construction, operations, and decommissioning for this technology 

would be similar.

5.4 Cost-Benefit Comparison

NEPA and CEQ require that all agencies of the Federal government prepare detailed 

environmental statements on proposed major Federal actions significantly affecting the quality 

of the human environment. One of NEPA’s principal objectives is to require each Federal 

agency to consider, in its decisionmaking process, the environmental impacts of each proposed 

major action. In particular, as stated below, Section 102 of NEPA requires all Federal agencies 

to the fullest extent possible to: 

(B) identify and develop methods and procedures, in consultation with the 

Council on Environmental Quality established by Title II of this Act, which will 

insure that presently unquantified environmental amenities and values may be 

given appropriate consideration in decisionmaking along with economic and 

technical considerations. (42 U.S.C. 4321).

However, neither NEPA nor CEQ requires the benefits and costs of a proposed action to be 

quantified in dollars or any other common metric. The intent of this section is not to identify and 

quantify all potential societal benefits of the proposed action and compare them to potential 
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costs. Instead, it focuses only on those benefits and costs of such magnitude or importance 

that including them in this analysis can inform the decisionmaking process.

This section compiles the expected impacts from operations of the proposed NWMI facility and 

aggregates them into two final categories: (1) the expected costs and (2) the expected benefits 

derived from approving the proposed action. Table 5–11 describes the following information on 

major environmental costs and benefits, including:

• average annual production of commercial products;

• expected increase in tax payments to State and local tax jurisdictions during 

construction and operations;

• other benefits;

• environmental degradation, which includes impacts on: land use and visual 

resources, air quality, noise, geologic environment, water resources, ecological 

resources, historic and cultural resources, socioeconomics, human health, waste 

management, transportation, environmental justice, and increased demand for public 

services;

• effects on human health; and

• other costs, which include lost tax revenues, decreased recreational value, and 

transportation (as appropriate).

Costs and Benefits of Constructing, Operating, and Decommissioning the 

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, sales taxes of $830,000, 

and income taxes of $465,000 (NWMI 2015a).

_

Local Economy Increased jobs would benefit the area economically. 

(Section 4.7)

_
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Cost-Benefit Category Description

Impact 

Assessment

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 of NAAQS or 

degrade Boone County’s unclassifiable/attainment

designation. (Section 4.2)

SMALL

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
Alternatives

5-84

Cost-Benefit Category Description

Impact 

Assessment

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

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
Alternatives

5-85

Cost-Benefit Category Description

Impact 

Assessment

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

The financial costs related to the construction, operations, and decommissioning of the 

proposed NWMI facility are described below. NRC regulations at 10 CFR 50.33(f)(1) state that 

an applicant for a construction permit shall demonstrate that it possesses or has reasonable 

assurance of obtaining the funds necessary to cover estimated construction costs and related 

fuel cycle costs. Further, the applicant shall indicate the source(s) of funds to cover these costs. 

In Chapter 15 of the preliminary safety analysis report (PSAR), NWMI stated that it has obtained 

financing for its development and construction project using various sources of financing, 

including equity and debt, and listed financial commitments. These specific financial 

commitments are considered business sensitive and proprietary, and as such have been 

withheld from public disclosure per 10 CFR 2.390.

NWMI’s operational cost estimates provided in Chapter 15 of the PSAR include the total annual 

operating costs for the first 5 years (NWMI 2015j). NWMI expects that revenue from the sale of 

Mo-99 and other radioisotopes will exceed operating costs, and provided a preliminary cost 

estimate (NWMI 2015j).

5.4.1 Benefit and Costs of Alternatives

This section compares the environmental impacts of the proposed NWMI facility with those that 

would be associated with using an alternative site or alternative technologies. Table 5–12 

provides a tabular comparison of the potential environmental impacts of constructing, operating, 

and decommissioning the proposed NWMI facility at Discovery Ridge with the alternative site 

(MURR) and the no-action alternative. In nearly all cases, impacts associated with using the 

alternative site would be similar to the impacts associated with the proposed action, and remain 

SMALL. The only exception would be noise associated with the MURR site, which would result 

in SMALL to MODERATE impacts, as well as an adverse effect to historic properties if it is 

found to alter the characteristics that qualify MURR for inclusion on the NRHP. The financial 

costs of construction, operations, and decommissioning of the proposed NWMI facility at the 

alternative site would likely be similar to the financial costs at the proposed NWMI site because 

of the facility’s design and operational plan. The no-action alternative would have SMALL 

impacts for every resource area.
Alternatives

5-86

Table 5–13 provides a tabular comparison of the potential environmental impacts of 

constructing, operating, and decommissioning the proposed NWMI facility at the Discovery 

Ridge site with the potential environmental impacts of using an alternative technology 

(linear accelerator-based or subcritical fission). The NRC staff determined that impacts across 

all resources and areas of evaluation would be SMALL, regardless of which radioisotope

production technology is employed.

Construction and operation of the proposed facility at an alternative site or using an alternative 

technology would not reduce or avoid adverse effects, compared with constructing and 

operating the proposed NWMI facility at the Discovery Ridge site. The adverse environmental 

impacts from the no-action alternative would be SMALL. However, the no-action alternative 

would not fulfill the purpose and need for the proposed action.

Comparison of Impacts for the Proposed 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

Potential 

adverse effect 

to historic 

property

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

Comparison of Technologies at the 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
Alternatives

5-87

Impacts on Resource or Other 

Area Evaluation

Proposed NWMI 

Technology

Linear AcceleratorBased Technology Subcritical

Fission Technology

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

5.4.2 Cost-Benefit Conclusions

In Chapter 4 and the preceding sections of Chapter 5, the NRC staff described the costs and 

benefits of the proposed action as well as alternatives to the proposed action. In weighing the 

costs and benefits, the NRC staff concludes that the overall benefits of constructing, operating, 

and decommissioning the proposed NWMI facility at the Discovery Ridge site outweigh the 

environmental and other costs based upon the following considerations:

• U.S. policy is to ensure a reliable supply of medical radioisotopes while minimizing 

the use of highly enriched uranium for civilian purposes (NNSA 2011; 

White House 2012);

• the small environmental impact, including radiological impacts and risk to human 

health, which would be caused by constructing, operating, and decommissioning the 

proposed NWMI facility at the Discovery Ridge site;

• the economic benefit of constructing and operating the proposed NWMI facility to 

communities located near the Discovery Ridge site; and

• the increased availability of medical radioisotopes for U.S. public health needs.

Constructing, operating, and decommissioning the NWMI facility at the Discovery Ridge site 

would have slightly less environmental costs than at the alternative site because impacts from 

noise would be SMALL to MODERATE at the MURR site, due to the close proximity of the 

exiting MURR workforce to heavy equipment noise that would be associated with construction 

and decommissioning of an NWMI facility within the MURR Center. In addition, constructing, 

operating, and decommissioning the NWMI facility at the MURR site could result in an adverse 

effect to historic properties if it alters the characteristics that qualify MURR for inclusion on the 

NRHP. However, the overall benefits of constructing and operating the proposed NWMI facility 

at either site would outweigh the environmental or other costs for the reasons outlined above.

Installation of alternative technologies (e.g., linear accelerator-based or subcritical 

fission-based) would not result in any greater economic advantages or disadvantages over the 
Alternatives

5-88

proposed NWMI technology, and the environmental costs and benefits would be similar to those 

described for the proposed NWMI facility at the Discovery Ridge site. Therefore, the overall 

benefits and costs of utilizing an alternative technology at the Discovery Ridge site would be the 

same and would outweigh the environmental and other costs for the reasons outlined above.

5.5 Alternatives Summary

In this Chapter the NRC staff considered the following alternatives to constructing, operating, 

and decommissioning the NWMI facility at the proposed Discovery Ridge site in Columbia, 

Missouri:

• the no-action alternative;

• construction, operations, and decommissioning of the NWMI facility at the MURR site 

(alternative site);

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

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

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

at the Discovery Ridge site (Alternative Technology No. 2).

The impacts for the proposed action, the no-action alternative, alternative site, and alternative 

technologies are summarized in Tables 5–12 and 5–13.

In conclusion, the NRC staff notes that the no-action alternative would result in SMALL impacts 

to all resource areas. The no-action alternative, however, does not fulfill the purpose and need 

of the project. The environmentally preferred alternatives are the construction, operations, and 

decommissioning of the NWMI facility at the Discovery Ridge site (proposed action), the linear 

accelerator-based facility at the Discovery Ridge site (Alternative Technology No. 1), and the 

subcritical fission-based facility at the Discovery Ridge site (Alternative Technology No. 2). The 

impacts associated with the proposed action and the two alternative technologies would be 

SMALL for all resource areas. The other alternative capable of meeting the purpose and need 

of the project is locating the NWMI facility at the MURR site. However, this alternative would 

entail potentially greater impacts than the proposed action of constructing the NWMI facility at 

the Discovery Ridge site (i.e., impacts from noise for constructing the NWMI facility at the 

MURR site would be SMALL to MODERATE, and adverse effects to historic properties could 

also occur).
6-1

6.0 CONCLUSIONS

This environmental impact statement (EIS) contains the environmental review of the Northwest 

Medical Isotopes, LLC (NWMI), application for a construction permit under Title 10 of the Code 

of Federal Regulations (10 CFR) Part 50 that would allow construction of the NWMI medical 

radioisotope production facility (NWMI facility) at the Discovery Ridge site in Columbia, Missouri. 

This EIS follows the requirements in 10 CFR Part 51, which are the U.S. Nuclear Regulatory 

Commission’s (NRC’s) regulations that implement the National Environmental Policy 

Act of 1969, as amended (42 U.S.C. 4321 et seq.). This chapter presents conclusions and 

recommendations from the environmental review of the NWMI facility. Section 6.1 summarizes 

the environmental impacts of construction, operations, and decommissioning. Section 6.2 

compares the environmental impacts of the proposed action, the construction of the NWMI 

facility at one alternative site, and the construction of two alternative technologies at the 

Discovery Ridge site in Columbia, Missouri. Section 6.3 discusses unavoidable impacts of the 

proposed action and alternatives to the proposed action and identifies resource commitments. 

Section 6.4 presents the NRC staff’s conclusions and recommendations.

6.1 Environmental Impacts of the Proposed Action

The NRC staff concludes that issuing a construction permit for the NWMI facility would have 

SMALL impacts for all resource areas. Table 6–1 summarizes the environmental impacts from 

construction, operations, and decommissioning of the proposed NWMI facility at the Discovery 

Ridge site.

The NRC staff also considered cumulative impacts of past, present, and reasonably foreseeable 

future actions regardless of which agency (Federal or non-Federal) or person undertakes them. 

In Section 4.14, the NRC staff concluded that the cumulative impacts would be SMALL for all 

resource areas with the exception of air quality, noise, water resources, and ecological 

resources. For air quality, noise and water resources, the NRC staff concluded that the 

cumulative impacts would be SMALL to MODERATE. For ecological resources, the NRC staff 

concluded that the cumulative impacts would be MODERATE.

Summary of the Environmental Impacts from Construction, Operations, and 

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 

unclassifiable/attainment 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

6.2 Comparison of Alternatives

In Chapter 5, the NRC staff considered the following alternatives to construction, operations, 

and decommissioning of the proposed NWMI facility at the Discovery Ridge site in Columbia, 

Missouri:

• the no action-alternative;

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

of Missouri Research Reactor (MURR) site in Columbia, Missouri (alternative site);

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

at the proposed Discovery Ridge site (Alternative Technology No. 1)

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

at the proposed Discovery Ridge site (Alternative Technology No. 2).

Tables 5–12 and 5–13 summarize the impacts for the proposed action, the no-action alternative, 

alternative site, and two alternative technologies. In conclusion, the NRC staff notes that the 

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

no-action alternative does not fulfill the purpose and need of the project. The environmentally 

preferred alternatives are the construction, operations, and decommissioning of the NWMI 

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

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

6-5

the Discovery Ridge site (Alternative Technology No. 2). Like the impacts associated with the 

proposed action, the impacts associated with the two alternative technologies would be SMALL 

for all resource areas. The other alternative capable of meeting the purpose and need of the 

project is locating the NWMI facility at the MURR site. However, this alternative would entail 

potentially greater impacts than the proposed action of constructing the NWMI facility at the 

Discovery Ridge site (i.e., impacts from noise for constructing the NWMI facility at the MURR 

site would be SMALL to MODERATE, and adverse effects to historic properties could also 

occur).

6.3 Resource Commitments

6.3.1 Unavoidable Adverse Impacts 

Section 102(2)(C)(ii) of the National Environmental Policy Act of 1969 requires that an EIS 

include information on any adverse environmental effects that cannot be avoided should the 

proposal be implemented. Unavoidable adverse impacts are predicted adverse environmental 

impacts that cannot be avoided.

As described in this EIS and summarized above, the impacts to all resource areas from the 

proposed action would be SMALL: the environmental effects would not be detectable or would 

be so minor that they would neither destabilize nor noticeably alter any important attribute of the 

resource. However, even though SMALL, there may be unavoidable adverse impacts from 

construction, operations, and decommissioning of the proposed NWMI facility at the Discovery 

Ridge site. Table 6–2 presents the unavoidable adverse impacts from construction, operations, 

and decommissioning of the proposed NWMI facility and presents mitigation and control

measures intended to lessen the adverse impact. Unless noted otherwise, mitigation measures 

were taken from NWMI’s Environmental Report (NWMI 2015a, 2015d) or from responses to 

NRC requests for additional information (NWMI 2015c, 2016a, 2016b).

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.

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 

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 
Conclusions

6-6

Resource Area Unavoidable Adverse Impact Mitigation Measures

would result from worker vehicle 

commuting, delivery and shipment 

vehicles.

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.

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 
Conclusions

6-7

Resource Area Unavoidable Adverse Impact Mitigation Measures

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.

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 
Conclusions

6-8

Resource Area Unavoidable Adverse Impact Mitigation Measures

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.

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;

7,000 kg (15,432 lbs) of 

unencapsulated solid low-level 

radioactive waste annually; 

310 liters (81.9 gallons) of liquid 

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. 
Conclusions

6-9

Resource Area Unavoidable Adverse Impact Mitigation Measures

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

In addition, the Missouri Department of Conservation (MDC) submitted a letter to the NRC dated 

June 2, 2016 (ADAMS No. ML16155A148), in which MDC recommended certain mitigation

measures be considered to avoid, minimize, and where necessary mitigate impacts to fish, 

forest, and wildlife resources (MDC 2016f). The NRC staff provided a copy of these 

recommended mitigation measures to NWMI for its consideration (NRC 2016f). These 

mitigation measures are summarized below:

• If site development or construction will result in tree removal, the applicant is 

encouraged to coordinate with the U.S. Fish and Wildlife Service.

• Regionally native plants should be used to revegetate areas where soils are disturbed 

for the project. Exercise caution to avoid introduction of non-native plants to the 

watershed, such as through a Hazard Analysis Critical Control Plan described by the 

American Society for Testing and Materials (ASTM E2592-80).

The NRC staff did not consider these mitigation measures when determining the potential

impacts from the proposed action because NWMI has not committed to incorporating the

suggested mitigation measures. NWMI is not required to implement the suggested mitigation

measures because they are recommendations, and not requirements, from MDC.

6.3.2 Relationship Between Local Short-Term Uses of the Environment and the 

Maintenance and Enhancement of Long-Term Productivity

The construction, operations, and decommissioning of the NWMI facility and alternatives to the 

proposed action would result in short-term uses of the environment, as described in Chapters 4 

and 5. “Short-term” is the period of time during which construction, operations, and 

decommissioning activities would take place.
Conclusions

6-10

The construction, operations, and decommissioning of the NWMI facility would require 

short-term use of the environment and commitment of resources and would commit certain 

resources (e.g., land and energy) indefinitely or permanently. Short-term resource

commitments would be similar at the alternative site and for the two alternative technologies if 

they were to be developed at the proposed Discovery Ridge site. These alternatives and the 

proposed action would result in similar relationships between local short-term uses of the 

environment and the maintenance and enhancement of long-term productivity.

Construction, operations, and decommissioning would require up to 7.4 ac (3.0 ha) of 

agricultural land that would be committed to industrial land use during the short term. In 

addition, during construction 0.26 ac (0.1 ha) of agricultural land would temporarily be used as a 

construction material staging area. The facility would partially obstruct views of the existing 

landscape. Construction, operations, and decommissioning could also displace wildlife through 

destruction of habitat or noise. Wildlife may return to the site once construction or 

decommissioning is completed if it is restored to suitable habitat. Mineral and other geologic 

resources would be consumed for facility construction. Water would be required for various 

purposes during NWMI facility construction, operations, and decommissioning as identified in 

Table 2–3.

Air emissions from construction, operations, and decommissioning would introduce small 

amounts of radiological and nonradiological constituents at the facility site. However, such 

emissions are not expected to affect air quality or radiation exposure to the extent that they 

would impair public health and long-term productivity of the environment. Noise emitted by 

construction, operations, and decommissioning activities would increase the ambient noise 

levels on site and in adjacent offsite areas. However, increases in noise levels are not expected 

to be noticeable, and noise levels would return to background levels once construction and 

decommissioning activities are complete.

Increased employment, expenditures, and tax revenues generated during construction, 

operations, and decommissioning activities directly benefit local, regional, and State economies 

over the short term. Worker vehicles and the delivery and shipment of materials would increase 

the volume of traffic on local roads. Worker and delivery vehicles-related traffic would be short 

term during peak construction and decommissioning activities and work shifts and, therefore, 

would not affect long-term productivity.

The management and disposal of low-level radioactive waste, hazardous waste, and 

nonhazardous waste requires an increase in energy and consumes space at treatment, storage, 

or disposal facilities. Regardless of the location, the use of land to meet waste disposal needs 

would reduce the long-term productivity of the land.

Extension installation of service lines (e.g., electric power, water) during construction of the 

proposed NWMI facility would connect the facility to utility providers. This additional 

infrastructure would be available and beneficial for any future use of the proposed NWMI facility 

after its decommissioning.

6.3.3 Irreversible and Irretrievable Commitment of Resources

This section describes the irreversible and irretrievable commitment of resources that have 

been noted in this EIS. Resources are irreversible when primary or secondary impacts limit 

future options for a resource. An irretrievable commitment refers to the use or consumption of 

resources that are neither renewable nor recoverable for future use. Irreversible and 

irretrievable commitments of resources for construction, operations, and decommissioning of a 

medical radioisotope facility include the commitment of water, energy, raw materials, and other 
Conclusions

6-11

natural and man-made resources. In general, the commitment of capital, energy, labor, and 

material resources are also irreversible.

The implementation of the proposed site, alternative site, or the alternative technologies

considered in this EIS would entail the irreversible and irretrievable commitment of energy, 

water, chemicals, fossil fuels, and other natural and man-made resources. These resources 

would be unrecoverable. For example, NWMI would consume materials during construction, as 

described in Chapter 2. These materials would be irretrievable unless NWMI recycles them 

during decommissioning (e.g., finds another facility to use such materials). During operations, 

uranium used as the source for the molybdenum isotope would be the main resource that would 

be irreversibly and irretrievably committed.

Mineral and other geologic resources, such as concrete, granular material, steel, and asphalt 

necessary for construction of the facility, would be irreversibly committed for construction of the 

NWMI facility. In addition, a small amount of soils and sediments would be lost to wind and 

water erosion during construction, operations, and decommissioning.

A negligible increase in the mortality of birds could occur because of their collisions with facility 

structures. The loss of these birds would be irreversible and irretrievable. 

Nonradiological irreversible commitments to occupational human health resources may occur. 

Such impacts would be similar to potential hazards that occur at any industrial construction site.

Energy expended would be in the form of fuel for equipment, vehicles, and facility operations 

and electricity for equipment and facility operations. Electricity and fuel would be acquired from 

offsite commercial sources. Water would be obtained from existing water supply systems. 

These resources are readily available, and the amounts required are not expected to deplete 

available supplies or exceed available system capacities.

6.3.4 Unresolved Conflicts

Section 102(2)(E) of the National Environmental Policy Act of 1969 requires that the NRC staff 

study, develop, and describe appropriate alternatives to recommended courses of action in any 

proposal which involves unresolved conflicts concerning alternative uses of available resources. 

In reviewing the potential impacts associated with the proposed action, the NRC staff did not 

identify any unresolved conflicts. 

6.4 Recommendation

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

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

unless safety issues mandate otherwise, is the issuance of the construction permit to NWMI. 

The NRC staff based its recommendation on the following factors:

• the NRC staff’s review of NWMI’s Environmental Report and responses to requests 

for additional information;

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

officials;

• the NRC staff’s independent environmental review; and

• the NRC staff’s consideration of public comments.

7-1

7.0 REFERENCES

7 CFR Part 657. Code of Federal Regulations, Title 7, Agriculture, Part 657, “Important 

farmlands inventory.”

7 CFR Part 658. Code of Federal Regulations, Title 7, Agriculture, Part 658, “Farmland and 

protection policy act.

10 CFR Part 2. Code of Federal Regulations, Title 10, Energy, Part 2, “Agency rules of practice 

and procedures.”

10 CFR Part 10. Code of Federal Regulations, Title 10, Energy, Part 10, “Criteria and 

procedures for determining eligibility for access to restricted data or national security information 

or an employment clearance.”

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

protection against radiation.”

10 CFR Part 30. Code of Federal Regulations, Title 10, Energy, Part 30, “Rules of general 

applicability to domestic licensing of byproduct material.”

10 CFR Part 40. Code of Federal Regulations, Title 10, Energy, Part 40, “Domestic licensing of 

source material.”

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

production and utilization facilities.”

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

protection regulations for domestic licensing and related regulatory functions.”

10 CFR Part 70. Code of Federal Regulations, Title 10, Energy, Part 70, “Domestic licensing of 

special nuclear material.”

10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and 

transportation of radioactive material.”

10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, “Reactor site 

criteria.”

10 CFR 110.2. Code of Federal Regulations, Title 10, Energy, Section 110.2, “Definitions.”

29 CFR Part 1910. Code of Federal Regulations, Title 29, Labor, Part 1910, “Occupational 

safety and health standards.”

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

Part 800, “Protection of historic properties.”

40 CFR Part 50. Code of Federal Regulations, Title 40, Protection of the Environment, Part 50, 

“National primary and secondary ambient air quality standards.” 

40 CFR Part 51. Code of Federal Regulations, Title 40, Protection of the Environment, Part 51, 

“Requirements for preparation, adoptions, and submittal of implementation plans.” Washington, 

D.C.

40 CFR Part 52. Code of Federal Regulations, Title 40, Protection of the Environment, Part 52, 

“Approval and promulgation of implementation plans.”

40 CFR Part 70. Code of Federal Regulations, Title 40, Protection of the Environment, Part 70,

“State operating permit programs.”
References

7-2

40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81, 

“Designation of areas for air quality planning purposes.”

40 CFR Part 112. Code of Federal Regulations, Title 40, Protection of Environment, Part 112,

”Oil pollution prevention.”

40 CFR Part 122. Code of Federal Regulations, Title 40, Protection of Environment, Part 122, 

“EPA administered permit programs: the National Pollutant Discharge Elimination System.”

40 CFR Part 131. Code of Federal Regulations, Title 40, Protection of Environment, Part 131, 

“Water quality standards.”

40 CFR Part 403. Code of Federal Regulations, Title 40, Protection of Environment, Part 403, 

“General pretreatment regulations for existing and new sources of pollution.”

40 CFR 1508. Code of Federal Regulations, Title 40, Protection of Environment, Part 1508, 

“Terminology and index.”

49 CFR Parts 107. Code of Federal Regulations, Title 49, Transportation, Part 107, “Hazardous 

materials program procedures.”

49 CFR Parts 171. Code of Federal Regulations, Title 49, Transportation, Part 171, “General 

information, regulations, and definitions.

49 CFR Parts 172. Code of Federal Regulations, Title 49, Transportation, Part 172, “Hazardous 

materials table, special provisions, hazardous materials communications, emergency responses 

information, training requirements, and security plans.

49 CFR Parts 173. Code of Federal Regulations, Title 49, Transportation, Part 173, “Shippers, 

general requirements for shipments and packagings.”

49 CFR Part 174. Code of Federal Regulations, Title 49, Transportation, Part 174, “Carriage by 

rail.”

49 CFR Part 175. Code of Federal Regulations, Title 49, Transportation, Part 175, “Carriage by 

aircraft.”

49 CFR Part 176. Code of Federal Regulations, Title 49, Transportation, Part 176, “Carriage by 

vessel.”

49 CFR Part 177. Code of Federal Regulations, Title 49, Transportation, Part 177, “Carriage by 

public highway.”

49 CFR Part 178. Code of Federal Regulations, Title 49, Transportation, Part 178, 

“Specifications for packagings.”

49 CFR Part 179. Code of Federal Regulations, Title 49, Transportation, Part 179, 

“Specifications for tank cars.”

49 CFR Part 180. Code of Federal Regulations, Title 49, Transportation, Part 180, “Continuing 

qualification and maintenance of packagings.”

49 CFR Part 390. Code of Federal Regulations, Title 49, Transportation, Part 390, “Federal 

motor carrier safety regulations.”

49 CFR Part 391. Code of Federal Regulations, Title 49, Transportation, Part 391, 

“Qualifications of drivers and longer combination vehicle driver instructors.”

49 CFR Part 392. Code of Federal Regulations, Title 49, Transportation, Part 392, “Driving of 

commercial motor vehicles.”
References

7-3

49 CFR Part 393. Code of Federal Regulations, Title 49, Transportation, Part 393, “Parts and 

accessories necessary for safe operation.”

49 CFR Part 395. Code of Federal Regulations, Title 49, Transportation, Part 395, “Hours of 

service of drivers.”

49 CFR Part 396. Code of Federal Regulations, Title 49, Transportation, Part 396, “Inspection, 

repair, and maintenance.

49 CFR Part 397. Code of Federal Regulations, Title 49, Transportation, Part 397, 

“Transportation of hazardous materials; driving and parking rules.

50 CFR Part 10. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 10, 

“General provisions.”

50 CFR Part 17. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 17, 

“Endangered and threatened wildlife and plants.”

50 CFR Part 402. Code of Federal Regulations, Title 50, Wildlife and Fisheries, “Interagency 

cooperation—Endangered Species Act of 1973,” Part 402, Subchapter A.

10 CSR 10-6.010. Missouri Code of State Regulations, Title 10, Department of Natural 

Resources, Division 10, Air Conservation Commissions, Chapter 6, Air Quality Standards, 

Rule 6.010, Ambient Air Quality Standards.

10 CSR 10-6. Missouri Code of State Regulations, Title 10, Department of Natural Resources, 

Division 10, Air Conservation Commission, Chapter 6, Air Quality Standards, Definitions, 

Sampling and Reference Methods and Air Pollution Control Regulations for the Entire State of 

Missouri. Available at <http://www.sos.mo.gov/adrules/csr/current/10csr/10csr.asp#10-20> 

(accessed 3 March 2016).

10 CSR 10-6.020. Missouri Code of State Regulations, Title 10, Department of Natural 

Resources, Division 10, Air Conservation Commission, Chapter 6, Air Quality Standards, 

Rule 6.020, Definitions and Common Reference Tables.

10 CSR 10-6.060. Missouri Code of State Regulations, Title 10, Department of Natural 

Resources, Division 10, Air Conservation Commission, Chapter 6, Air Quality Standards, 

Rule 6.060, Construction Permits Required.

10 CSR 20-6.010. Missouri Code of State Regulations, Title 10, Department of Natural 

Resources, Division 20, Clean Water Commission, Chapter 6, Permits, Rule 6.010, 

Construction and Operating Permits. Available at 

<http://www.sos.mo.gov/adrules/csr/current/10csr/10csr.asp#10-20> (accessed 3 March 2016).

10 CSR 20-6.060. Missouri Code of State Regulations, Title 10, Department of Natural 

Resources, Division 20, Clean Water Commission, Chapter 6, Permits, Rule 6.060, Water 

Quality Certification. Available at 

<http://www.sos.mo.gov/adrules/csr/current/10csr/10csr.asp#10-20> (accessed 3 March 2016).

10 CSR 10-6.065. Missouri Code of State Regulations, Title 10, Department of Natural 

Resources, Division 10, Air Conservation Commission, Chapter 6, Air Quality Standards, 

Rule 6.065, Operating Permits.

10 CSR 20-6.200. Missouri Code of State Regulations, Title 10, Department of Natural 

Resources, Division 20, Clean Water Commission, Chapter 6, Permits, Rule 6.200, Storm 

Water Regulations. Available at 

<http://www.sos.mo.gov/adrules/csr/current/10csr/10csr.asp#10-20> (accessed 3 March 2016).
References

7-4

10 CSR 20-7.031. Missouri Code of State Regulations, Title 10, Department of Natural 

Resources, Division 20, Clean Water Commission, Chapter 7, Water Quality, Rule 7.031, Water 

Quality Standards. Available at 

<http://www.sos.mo.gov/adrules/csr/current/10csr/10csr.asp#10-20> (accessed 

6 February 2016).

46 FR 18026. Council on Environmental Quality. Forty Most Asked Questions Concerning the 

CEQ’s [Council on Environmental Quality’s] National Environmental Policy Act Regulations. 

Federal Register 46(55): 18026–18028. March 23, 1981.

49 FR 9375. U.S. Nuclear Regulatory Commission. “Environmental Protection Regulations for 

Domestic Licensing and Related Regulatory Functions and Related Conforming Amendments.” 

Federal Register Notice 49(49): 9163–9406. March 12, 1984.

56 FR 23360. U.S. Nuclear Regulatory Commission. Federal Register Notice 56(98): 

23360–23474. May 21, 1991.

59 FR 7629. Executive Order No. 12898. “Federal Actions to Address Environmental Justice in 

Minority Populations and Low-Income Populations.” Federal Register 59(32): 7629–7633. 

February 16, 1994.

69 FR 52040. U.S. Nuclear Regulatory Commission. “Policy Statement on the Treatment of 

Environmental Justice Matters in NRC Regulatory and Licensing Actions.” 

Federal Register 69(163): 52040–52048. August 24, 2004.

72 FR 57416. U.S. Nuclear Regulatory Commission. “Limited Work Authorizations for Nuclear 

Power Plants.” Federal Register 72(194): 57416–57447. October 9, 2007.

74 FR 56260. Environmental Protection Agency. “Mandatory Reporting of Greenhouse 

Gases.” Federal Register 74(209): 56260–56519. October 30, 2009.

75 FR 9282. U.S. Fish and Wildlife Service. “General Provisions; Revised List of Migratory 

Birds [Final rule].” Federal Register 75(39): 9282–9314. March 1, 2010.

75 FR 31514. Environmental Protection Agency. “Prevention of Significant Deterioration and 

Title V Greenhouse Gas Tailoring Rule.” Federal Register 75(106): 31514–31608. 

June 3, 2010.

80 FR 32418. U.S. Nuclear Regulatory Commission. “Northwest Medical Isotopes, LLC; 

Construction Permit Application.” Federal Register 80(109): 32418–32419. June 8, 2015.

80 FR 72115. U.S. Nuclear Regulatory Commission. “Northwest Medical Isotopes, LLC –

Intent to Conduct Scoping Process and Prepare an Environmental Impact Statement; Public 

Meeting and Request for Comment.” Federal Register 80(222): 72115-72117. 

November 18, 2015.

[ABC] Analytical Bio-Chemistry Laboratories, Inc. 2010. “ABC Laboratories, Inc., Request to 

Amend License No. 24-13365-01.” June 2010. ADAMS No. ML101550106.

[ABC] Analytical Bio-Chemistry Laboratories, Inc. 2011. “ABC Laboratories, Request for Partial 

Site Release of Sanitary Ponds.” October 2011. ADAMS No. ML112900307.

[ABC] Analytical Bio-Chemistry Laboratories, Inc. 2016. Available at 

<http://www.abclabs.com/> (accessed 20 February 2016).

[AIHA] American Industrial Hygiene Association. 2013. Current ERPG Values (2013). 

Available at <https://www.aiha.org/getinvolved/AIHAGuidelineFoundation/EmergencyResponsePlanningGuidelines/Documents/2013E

RPGValues.pdf> (accessed 1 May 2016).
References

7-5

[AMEREN] Ameren Missouri, Callaway Energy Center. 2013. “Annual Report to the United 

States Nuclear Regulatory Commission, Radiation Environmental Operating Report, January 1 

to December 31, 2012.” April 2013. ADAMS No. ML13119A142.

[AMEREN] Ameren Missouri, Callaway Energy Center. 2014. “Annual Report to the United 

States Nuclear Regulatory Commission, Radiation Environmental Operating Report, January 1 

to December 31, 2013.” April 2014. ADAMS No. ML14115A324.

[AMEREN] Ameren Missouri, Callaway Energy Center. 2015. “Annual Report to the United 

States Nuclear Regulatory Commission, Radiation Environmental Operating Report, January 1 

to December 31, 2014.” April 2015. ADAMS No. ML15120A492.

American Hospital Directory. 2016. “Individual Hospital Statistics for Missouri.” Last updated 

February 17, 2016. Available at <https://www.ahd.com/states/hospital_MO.html> (accessed 

March 2016).

American Medical Isotopes Production Act of 2012. 42 U.S.C. §2065 et seq.

[AMR] Airport Master Records and Reports. 2016. “Columbia Regional Airport Master Records 

and Report,” FAA Site 1165 1.1*A, Federal Aviation Administration. Operations for 12 months 

ending: October 31, 2015. Data Effective Date: February 4, 2016. Available at 

<http://www.gcr1.com/5010Web/airport.cfm?Site=cou&AptSecNum=0> (accessed March 2016).

[ATL International] Advanced Technologies and Laboratories International. 2016. PAC 

Database, Revision 28A (February 2016). Available at 

<http://www.atlintl.com/DOE/teels/teel.html> (accessed 18 April 2016).

Atomic Energy Act of 1954, as amended. 42 U.S.C. §2011 et seq.

[Audubon] Eastside Audubon. 2016. “Eurasian Collared-Dove (Streptopelia decaocto)” 

Available at <http://eastsideaudubon.org/birding/birding_resources/gallery/doves/band-tailedpigeon-columba-fasciata> (accessed 13 April 2016).

[B&W] Babcock and Wilcox Technical Services Group. 2012. “B&W Medical Isotope 

Production System (MIPS).” May 11, 2012. Available at <http://www.nrc.gov/reading-rm/doccollections/commission/slides/2012/20120511/spickard-20120511.pdf> (accessed 

11 April 2016).

[BCC] Boone County Commission. 1996. Boone County Master Plan. Prepared by Booker 

Associates, Inc. October 1996. Available at 

<https://www.showmeboone.com/resourcemanagement/Regulations.asp> (accessed 

6 February 2016).

Bertch, TC. 2014. Selective Gaseous Extraction: Research, Development and Training for 

Isotope Production, Final Technical Report for the Period April 1, 2012 through April 31, 2014, 

GA-A27770, General Atomics. March 2014. Available at 

<http://www.osti.gov/scitech/servlets/purl/1127320> (accessed 11 April 2016).

[BFSC] Bonne Femme Stakeholder Committee. 2007. Bonne Femme Watershed Plan. 

Columbia, Missouri. February 2007. Available at 

<http://www.showmeboone.com/resourcemanagement/watershed/plan.asp> (accessed 

12 April 2016).

[BLM] Bureau of Land Management. 1984. Visual Resource Inventory Manual H-8410-1. 

U.S. Department of the Interior, BLM. H-8410-1. January 17, 1986. Available at 

<http://www.blm.gov/style/medialib/blm/wo/Information_Resources_Management/policy/blm_ha

ndbook.Par.31679.File.dat/H-8410.pdf> (accessed 25 April 2016).
References

7-6

Boone County. 2010. Boone County Stormwater Ordinance, Final. Columbia, MO: Boone 

County Stormwater Management. Approved 2/1/10, Effective 4/15/10. Available at 

<https://www.showmeboone.com/stormwater/common/PDF/

Approved%20SW%20Ordinance.pdf> (accessed 3 March 2016).

Boone County. 2013. Boone County Water Districts. Updated June 2013. Columbia, MO: 

Boone County Public Works. Available at 

<https://www.showmeboone.com/PublicWorks/common/pdf/Water_District_Map_2013.pdf> 

(accessed 6 February 2016).

Boone County. 2016a. “Protection of Environmentally Sensitive Areas in Boone County.” 

Columbia, MO: Boone County Stormwater Management. No page date. Available at 

<https://www.showmeboone.com/stormwater/EnvSensitiveArea.asp> (accessed 

6 February 2016).

Boone County. 2016b. “Permits and Inspections.” Columbia, MO: Boone County Stormwater 

Management. No page date. Available at 

<https://www.showmeboone.com/stormwater/PermitsAndInspections.asp> (accessed 

3 March 2016).

Boone County. 2016c. Boone Hospital Center. Available at <http://www.boone.org/OurServices> (accessed 22 February 2016).

Boone County Collector of Revenue. 2016. Boone County Tax Entities and Rates, 2011 –

2015. Available at <http://www.showmeboone.com/collector/taxrates.asp> (accessed 

March 2016).

Carlson J, McCafferey K, O’Leary M, Thomast N. 2005. Geographical Information System and 

Subwatershed Sensitivity Analysis for the Bonne Femme Watershed. Columbia, MO: Applied 

Ecological Services, Inc. August 19, 2005. Available at 

<http://www.showmeboone.com/resourcemanagement/watershed/SWSA.asp> (accessed 

6 February 2016).

[CATSO] Columbia Area Transportation Study Organization. 2014. 2040 Long-Range 

Transportation Plan. Appendix Q: CATSO 2040 Roadway Plan by Segment/Project Status. 

Available at <http://www.gocolumbiamo.com/community-development/planning/columbia-areatransportation-study-organization-catso/2040-long-range-transportation-plan-update/2040-longrange-transportation-plan/> (accessed 20 February 2016).

[CHC] Center for Hearing and Communication. Undated. “Common Environmental Noise 

Levels Factsheet.” Available at <http://www.chchearing.org/noise-center-home/factsnoise/common-environmental-noise-levels> (accessed 21 December 2015).

City of Columbia. 2012. Zoning District Map, City of Columbia, Department of Community 

Development, Columbia, Missouri. August 17, 2012. Available at 

<https://www.como.gov/Maps/documents/ZoningMapBook_08_17_2012.pdf> (accessed 

25 April 2016).

City of Columbia. 2013. Columbia Imagined: The plan for how we live and grow. 

October 7, 2013. Available at 

<https://www.como.gov/community_development/comprehensive_plan/documents/ColumbiaIm

agined-FINAL.pdf> (accessed 18 April 2016).

City of Columbia. 2015. Columbia, Missouri - Code of Ordinances. Columbia, MO. Codified 

through Ordinance No. 22664, enacted December 7, 2015. Supplement 100. Available at 

<https://www.municode.com/library/mo/columbia/codes/code_of_ordinances> (accessed 

3 March 2016).
References

7-7

City of Columbia. 2016a. Columbia City View Zoning Map, Geospatial Information Office, 

Discovery Ridge Site. Available at <https://gis.gocolumbiamo.com/CityView/> (accessed 

18 April 2016).

City of Columbia. 2016b. Code of Ordinances, Chapter 16, “Offenses and Miscellaneous 

Provisions.” Available at 

<https://www.municode.com/library/mo/columbia/codes/code_of_ordinances?nodeId=PTIICOO

R_CH16OFMIPR_ARTIIINO> (accessed 25 February 2016).

City of Columbia. 2016c. “Columbia Regional Wastewater Treatment Plant.” Public Works 

Department. Page dated 2016. Available at 

<http://www.gocolumbiamo.com/PublicWorks/Sewer/wwtppg_4.php> (accessed 18 April 2016).

City of Columbia. 2016d. “Site Development.” [Site Plan Checklist.] Available at 

<http://www.gocolumbiamo.com/community-development/bsd/land-disturbance/> (accessed 

3 March 2016).

City of Columbia. 2016e. Comprehensive Annual Financial Report for the Fiscal Year 

October 1, 2014 – September 30, 2015. January 29. Available at 

<https://www.como.gov/finance/wp-content/uploads/sites/21/2015/11/City-of-ColumbiaMissouri-CAFR-FY15.pdf> (accessed April 2106).

City of Columbia. 2016f. “Columbia Parks and Recreation – Frank G. Nifong Memorial Park.” 

Available at <https://www.gocolumbiamo.com/ParksandRec/Parks/Philips/philips_history.php> 

(accessed 22 February 2016).

City of Columbia. 2016g. “Columbia Parks and Recreation – Philips Park.” Available at 

<https://www.gocolumbiamo.com/ParksandRec/Parks/Philips/philips_history.php> (accessed 

22 February 2016).

City of Columbia. 2016h. “Columbia Parks and Recreation – Gans Creek Recreation Area.” 

Available at <https://www.gocolumbiamo.com/ParksandRec/Parks/Crane/index.php> (accessed 

22 February 2016).

City of Columbia. 2016i. Columbia City View Zoning Map, Geospatial Information Office, 

MURR site. Available at <https://gis.gocolumbiamo.com/CityView/> (accessed 25 April 2016).

City of Columbia. 2016j. “Columbia Missouri Water System.” Columbia, MO. Page updated 

2016. Available at <https://www.gocolumbiamo.com/WaterandLight/Water/watersystem.php> 

(accessed 3 March 2016).

City of Columbia. 2017. Gans Creek Recreation Area. Available at 

<https://www.como.gov/ParksandRec/Parks/Gans_Creek_Recreation_Area/documents/gcra8x1

1.pdf> (accessed 8 February 2017)

City of Columbia and Missouri Department of Natural Resources (MDNR). 2013. Source Water 

Protection Plan, City of Columbia Missouri. Columbia, MO: Prepared by Columbia Source 

Water Protection Task Force with assistance from Missouri Department of Natural Resources. 

February 2013. Available at 

<https://www.gocolumbiamo.com/WaterandLight/Documents/SourceWaterProtectionPlan.pdf> 

(accessed 3 March 2016).

Clean Air Act of 1970, as amended. 42 U.S.C. §7401 et seq.

Clean Water Act of 1977, as amended. 33 U.S.C. §1251 et seq.
References

7-8

Clendenin, CW, Niewendorp CA, Lowell GR. 1989. Reinterpretation of faulting in southeast 

Missouri. Geology(17): 217–220. Available at 

<http://geology.gsapubs.org/content/17/3/217.full.pdf> (accessed 6 February 2016).

Coastal Zone Management Act of 1972, as amended. 16 U.S.C. §1451 et seq.

Columbia Daily Tribune. 2015a. “2015 Our Town: Top Employers.” Sunday, June 14, 2015. 

Available at <http://www.columbiatribune.com/special_sections/ourtown/our-town-topemployers/article_c6d2d1e6-c0b1-5a45-a31a-417713780aa6.html> (accessed March 2016).

Columbia Daily Tribune. 2015b. “Discovery Park developers plan hotel, restaurants.” 

April 15, 2015. Available at <http://www.columbiatribune.com/news/local/discovery-parkdevelopers-plan-hotel-restaurants/article_5820dce5-6656-558a-add0-74d34e1e1eb1.html> 

(accessed 22 February 2016).

[Con-Agg] Con-Agg of MO, LLC. Undated. Con-Agg of MO, LLC Companies – Boone 

Quarries. Available at <http://www.conagg-mo.com/boone-quarries/> (accessed 

22 February 2016).

[CPWSD] Consolidated Public Water Supply District No. 1 of Boone County Missouri. 2016. 

“Water District History/Info.” Page updated 2016. Available at 

<http://consolidatedwater.com/about-us/our-history/> (accessed 6 February 2016).

[CRA] Columbia Regional Airport. 2012. Draft Environmental Assessment– Airside, Landside, 

and Surface Transportation Developments. January. Available at 

<http://www.flycou.com/?page_id=342> (accessed 21 February 2016).

Crone AJ, Wheeler RL. 2000. Data for Quaternary Faults, Liquefaction Features, and Possible 

Tectonic Features in the Central and Eastern United States, East of the Rocky Mountain Front. 

Reston, VA: U.S. Geological Survey. Open-File Report 00–260. 2000. 332 p. Available at 

<http://pubs.usgs.gov/of/2000/ofr-00-0260> (accessed 6 February 2016).

[CTR] Columbia Terminal Railroad. 2016. “Columbia Terminal Railroad, About Us.” City of 

Columbia, Missouri, Columbia Power & Light. Available at 

<www.gocolumbiamo.com/WaterandLight/About_Us/COLT> (accessed March 2016).

Dahl, T.E. 1990. Wetland Losses in the United States 1780s To 1980s. U.S. Department of 

the Interior. Fish and Wildlife Service, Washington, D.C. Available at 

<http://www.fws.gov/wetlands/Documents/Wetlands-Losses-in-the-United-States-1780s-to1980s.pdf> (accessed 2 May 2016).

[DOE] U.S. Department of Energy. 2001. Guidebook to Decision-Making Methods, 

WS-IM-2002-00002, U.S. Department of Energy, Washington, D.C., December 2001. Available 

at <http://kscddms.ksc.nasa.gov/Reliability/Documents/

Decision_Making_Guidebook_2002_Dept_of_Energy.pdf> (accessed 11 April 2016)

[DOE] U.S. Department of Energy. 2008. DOE Handbook: Temporary Emergency Exposure 

Limits for Chemicals: Methods and Practice. DOE-HDBK-1046-2008. Available at 

<http://energy.gov/sites/prod/files/2013/06/f1/DOE-HDBK-1046-2008.pdf> (accessed 

1 May 2016).

[DOE] U.S. Department of Energy. 2012. Environmental Assessment for NorthStar Medical 

Technologies LLC Commercial Domestic Production of the Medical Isotope Molybdenum-99 

(DOE/EA–1929). July 2012. Available at <http://energy.gov/sites/prod/files/EA-1929-DEA2012.pdf> (accessed 11 April 2016).
References

7-9

[DOE] U.S. Department of Energy. 2016. Supplement Analysis for the Uranium Lease and 

Take-Back Program for Irradiation for Production of Molybdenum-99 for Medical Use. Available 

at <http://nnsa.energy.gov/sites/default/files/nnsa/inlinefiles/ULTB%20SA%20%28EIS-0279-SA05_EIS-0387-SA-02%29.pdf> (accessed 27 April 2016).

[DOL] Department of Labor. 2014. Table 1, Incidence Rates of Nonfatal Occupational Injuries 

and Illnesses by Industry and Case Types, 2014. Available at 

<http://www.bls.gov/iif/oshwc/osh/os/ostb4343.pdf> (accessed April 8, 2016).

[EAG] EAG Laboratories. 2017. Available at < http://www.eag.com/locations/northamerica/columbia-mo/> (accessed 21 March 2017).

[EIA] U.S. Energy Information Administration. 2015a. “Missouri State Profile and Energy 

Estimates, Profile Overview Interactive Map – MU Combined Heat and Power Plant.” Available 

at <http://www.eia.gov/state/?sid=MO> (accessed 22 February 2016).

[EIA] U.S. Energy Information Administration. 2015b. “Missouri State Profile and Energy 

Estimates, Profile Overview Interactive Map – City of Columbia (MO) Municipal Power Plant.” 

Available at <http://www.eia.gov/state/?sid=MO> (accessed 22 February 2016).

[EIA] U.S. Energy Information Administration. 2015c. “Missouri State Profile and Energy 

Estimates, Profile Overview Interactive Map – Columbia Energy Center.” Available at 

<http://www.eia.gov/state/?sid=MO> (accessed 22 February 2016).

Elliott WR. 2007. Zoogeography and Biodiversity of Missouri Caves and Karst. Journal of Cave 

and Karst Studies, v. 69, no. 1, p. 135–162.

Endangered Species Act of 1973, as amended. 16 U.S.C. §1531 et seq.

Energy Reorganization Act of 1974, as amended. 42 U.S.C. §5801 et seq.

[EPA] U.S. Environmental Protection Agency. 1974. Information on Levels of Environmental 

Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety. 

Available at <http://www.nonoise.org/library/levels74/levels74.htm> (accessed 10 May 2016).

[EPA] U.S. Environmental Protection Agency. 1992. Clarification of Prevention of Significance 

Deterioration (PSD) Guidance for Modelling Class I Area Impacts. Available at 

<http://www.epa.gov/sites/production/files/2015-07/documents/class1.pdf> (accessed 

9 February 2016).

[EPA] U.S. Environmental Protection Agency. 2008. Average Annual Emissions and Fuel 

Consumption for Gasoline-Fueled Passenger Cars and Light Trucks. Available at 

<https://www3.epa.gov/otaq/consumer/420f08024.pdf> (accessed 29 February 2016).

[EPA] U.S. Environmental Protection Agency. 2009a. “Endangerment and Cause or Contribute 

Finding for Greenhouse Gases under Section 202(a) of the Clean Air Act.” Available at 

<http://www.epa.gov/climatechange/endangerment/> (accessed 1 March 2016).

[EPA] U.S. Environmental Protection Agency. 2009b. Assessment of the Impacts of Global 

Change on Regional U.S. Air Quality: A synthesis of Climate Change Impacts on Ground-Level 

Ozone. EPA/600/R–07/094F. April 2009. Available at 

<http://ofmpub.epa.gov/eims/eimscomm.getfile?p_download_id=491176> (accessed 

1 March 2106).

[EPA] U.S. Environmental Protection Agency. 2011. 2011 National Inventory (NEI) Data. 

Available at <http://www.epa.gov/air-emissions-inventories/2011-national-emissions-inventorynei-data> (accessed 12 January 2016).
References

7-10

[EPA] U.S. Environmental Protection Agency. 2014a. Next Steps and Preliminary View on the 

Application of Clean Air Act Permitting Programs to Greenhouse Gases Following the Supreme 

Court’s Decision in Utility Air Regulatory Group V. Environmental Protection Agency. Available 

at <https://www.epa.gov/nsr/clean-air-act-permitting-greenhouse-gases> (accessed 8 August 

2016). 

[EPA] U.S. Environmental Protection Agency. 2014b. Climate Change Indicators in the 

United States, 2014. EPA-430-R-14-004. Available at 

<http://www.epa.gov/climatechange/pdfs/climateindicators-full-2014.pdf> (accessed 

8 November 2015).

[EPA] U.S. Environmental Protection Agency. 2015a. Clean Air Act Permitting for Greenhouse 

Gases. Available at <http://www.epa.gov/nsr/clean-air-act-permitting-greenhouse-gases> 

(accessed 9 February 2016).

[EPA] U.S. Environmental Protection Agency. 2015b. “About NPDES.” Page updated 

November 16, 2015. Available at <https://www.epa.gov/npdes/pretreatment-standards-andrequirements#local> (accessed 3 March 2016).

[EPA] U.S. Environmental Protection Agency. 2015c. State Reports, StATS Data as of 

June 2015. Available at <https://www3.epa.gov/epawaste/laws-regs/state/stats/mo.pdf> 

(accessed 8 April 2016).

[EPA] U.S. Environmental Protection Agency. 2016a. Acute Exposure Guideline Levels for 

Airborne Chemicals. Available at< https://www.epa.gov/aegl> (accessed 18 April 2016).

[EPA] U.S. Environmental Protection Agency. 2016b. Basics of TRI Reporting. Available at 

<https://www.epa.gov/toxics-release-inventory-tri-program/basics-tri-reporting> (accessed 

March 8, 2016).

[EPA] U.S. Environmental Protection Agency. 2016c. Enforcement and Compliance Online. 

Available at <https://echo.epa.gov/?redirect=echo> (accessed 1 March 2016).

[EPA] U.S. Environmental Protection Agency. 2016d. EPA Envirofacts. Available at 

<https://www3.epa.gov/enviro/> (accessed April 19, 2016).

[EPA] U.S. Environmental Protection Agency. 2016e. EPA History: Noise and the Noise 

Control Act. Available at <http://www.epa.gov/aboutepa/epa-history-noise-and-noise-controlact> (accessed 9 February 2016).

[EPA] U.S. Environmental Protection Agency. 2016f. National Ambient Air Quality Standards 

(NAAQS). Available at <http://www3.epa.gov/ttn/naaqs/criteria.html> (accessed 

9 February 2016).

[EPA] U.S. Environmental Protection Agency. 2016g. “National Pollutant Discharge Elimination 

System (NPDES), Pretreatment Standards and Requirements.” Page updated 

February 4, 2016. Available at <https://www.epa.gov/npdes/about-npdes> (accessed 

3 March 2016).

[EPA] U.S. Environmental Protection Agency. 2016h. NEPAssist. Available at 

<https://www.epa.gov/nepa/nepassist> (accessed 5 July 2016).

[EPA] U.S. Environmental Protection Agency. 2016i. Radiation Sources and Doses. Available 

at <https://www.epa.gov/radiation/radiation-sources-and-doses#tab-2> (accessed 

29 March 2016).
References

7-11

[EPA] U.S. Environmental Protection Agency. 2016j. “Safe Drinking Water Information System 

(SDWIS),” County Search—Boone County, Missouri. February 24, 2016 data extraction. 

Available at <http://www.epa.gov/enviro/facts/sdwis/search.html> (accessed March 2016).

Epperson JE. 1992. Missouri Wetlands: A Vanishing Resources. Water Resources Report 

No. 39. Missouri Department of Natural Resources. Rolla, Missouri. Available at 

<http://dnr.mo.gov/pubs/WR39.pdf> (accessed 12 April 2016).

Farmland Protection Policy Act of 1981. 7 U.S.C. §4201 et seq.

Federal Water Pollution Control Act (Clean Water Act) of 1972, as amended. 

33 U.S.C. §1251 et seq.

[FEMA] Federal Emergency Management Agency. 2011. Flood Insurance Rate Map, Boone 

County, Missouri, and Incorporated Areas. Oakton, VA: FEMA Map Service Center. Map 

Number 29019C0295D. Effective date March 17, 2011. Available at 

<https://msc.fema.gov/portal/> (accessed 6 February 2016).

[FHWA] Federal Highway Administration. 2003. Living with Noise. Available at 

<https://www.fhwa.dot.gov/publications/publicroads/03jul/06.cfm> (accessed 29 February 2016).

[FHWA] Federal Highway Administration. 2006. Construction Noise Handbook. Available at 

<https://www.fhwa.dot.gov/environment/noise/construction_noise/handbook/handbook07.cfm> 

(accessed 7 January 2016).

[FHWA] Federal Highway Administration. 2011. Highway Traffic Noise Analysis and 

Abatement Policy. Available at <https://www.fhwa.dot.gov/environment/

noise/regulations_and_guidance/polguide/polguide02.cfm> (accessed 29 February 2016).

Find the Data 2016. Active Mines. Available at <http://active-mines.findthedata.com/>

(accessed 21 April 2016).

FishNet. 2014. FishNet2, Search FishNet. Updated June 16, 2014. Available at 

<http://www.fishnet2.net/search.aspx> (accessed 15 April 2016).

Fraser J, Silverio C, Kramer P, Mickle N, Aeppli R, Stutchbury BJM. 2013. A trans-hemispheric 

migratory songbird does not advance spring schedules or increase migration rate in response to 

record-setting temperatures at breeding sites. PLoS ONE 8(5): e64587.

Frueh WT. 2007. Bonne Femme Watershed Plan. Columbia, MO: Bonne Femme Stakeholder 

Committee. February 2007. Available at 

<http://www.showmeboone.com/resourcemanagement/watershed/plan.asp> (accessed 

6 February 2016).

Fry J, Xian G, Jin S, Dewitz J, Homer C, Yang L, Barnes C, Herold N, Wickham J. 2011.

“Completion of the 2006 National Land Cover Database for the Conterminous United States,” 

Photogrammetric Engineering & Remote Sensing Journal 77(9): 858–864, Bethesda, MD, 

2011.

[FWS] Fish and Wildlife Service. 2015a. Letter from A. Salveter, FWS, to NRC, Subject: List of 

threatened and endangered species that may occur in your proposed project location, and/or 

may be affected by your proposed project. Consultation Code: 03E14000-2016-SLI-0314. 

November 20, 2015. ADAMS No. ML15335A002.

[FWS] Fish and Wildlife Service. 2015b. Northern Long-Eared Bat, Myotis septentrionalis. Fort 

Snelling, Minnesota. April 2015. Available at 

<http://www.fws.gov/Midwest/endangered/mammals/nleb/nlebFactSheet.html> (accessed 

13 April 2016).
References

7-12

[FWS] Fish and Wildlife Service. 2015c. Endangered Species Fact Sheet: Piping Plover. Fort 

Snelling, Minnesota. Last updated 23 April 2015. Available at 

<http://www.fws.gov/midwest/endangered/pipingplover/pipingpl.html> (accessed 13 April 2016).

[FWS] Fish and Wildlife Service. 2016. Information for Planning and Conservation (IPaC) 

Report for Boone County, Missouri Project. ADAMS No. ML16117A529.

[GE Hitachi]. 2011. GE Hitachi Production of Molybdenum-99 Using Neutron Capture. NNSA

Mo-99 Topical Meeting Presentation. Presented by John Berger. December 6, 2011. Available 

at <http://mo99.ne.anl.gov/2011/pdfs/Mo99%202011%20Web%20Presentations/S7-

P2_Berger.pdf> (accessed 11 April 2016).

Grozelle J. 2016. “Selective Gas Extraction: A Transformational Production Technology being 

Implemented by General Atomics, the University of Missouri Research Reactor Center and 

Nordion,” June 2016. Available at 

<http://cns2016conference.org/abstracts/grozelle_CNS2016AbstractNordion.pdf> (accessed 

16 February 2017).

[GSU] Georgia State University. 2016. HyperPhysics, Estimating Sound Levels with the 

Inverse Square Law. Available at <http://hyperphysics.phyastr.gsu.edu/hbase/acoustic/isprob2.html> (accessed 26 January 2016).

[Hawthorne] The Club at Old Hawthorne. 2016. Available at <http://www.oldhawthorne.com/> 

(accessed 20 February 2016).

Hazardous Material Transportation Act of 1975, as amended. 49 U.S.C. §5101 et seq.

[HUD] U.S. Department of Housing and Urban Development. 2014. Noise and Abatement 

Control. Available at <https://www.hudexchange.info/environmental-review/noise-abatementand-control/> (accessed 15 July 2015).

[IAEA] International Atomic Energy Agency. 2008. “Making Medical Isotopes: Report of the 

Task Force on Alternatives for Medical-Isotope Production (TRIUMF 2008) and Homogeneous 

Aqueous Solution Nuclear Reactors for the Production of Mo-99 [Molybdenum-99] and other 

Short Lived Radioisotopes,” September 2008. Available at <http://www-pub.iaea.org/

MTCD/publications/PDF/te_1601_web.pdf> (accessed 20 March 2017).

[IAEA] International Atomic Energy Agency. 2013a. Coordinated Research Projects (CRP) on 

Production of Mo-99 from LEU or Neutron Activation. Available at 

<http://www.iaea.org/OurWork/ST/NE/NEFW/Technical_Areas/RRS/mo99.html> (accessed 

29 February 2016).

[IAEA] International Atomic Energy Agency. 2013b. Non-HEU Production Technologies for 

Molybdenum-99 and Technetium-99m. IAEA Nuclear Energy Series No. NF-T-5.4. 

February 2013. Available at <http://www-pub.iaea.org/books/IAEABooks/10386/Non-HEUProduction-Technologies-for-Molybdenum-99-and-Technetium-99m> (accessed 11 April 2016).

[ICRP] International Commission on Radiological Protection. 1987. Recommendations of the 

International Commission on Radiological Protection. ICRP Publication 26 (adopted 

January 17, 1977), revised to 1987.

[IDEXX] IDEXX RADIL Bioresearch. 2015. Available at <http://www.idexxbioresearch.com/> 

(accessed 20 February 2016).

[IEPA] Illinois Environmental Protection Agency. 2015. Answers to Frequently Asked 

Questions Regarding NSR and PSD. Available at <http://www.epa.illinois.gov/topics/forms/airpermits/new-source-review/faq/index> (accessed 10 May 2016).
References

7-13

[IPCC] Intergovernmental Panel on Climate Change. 2007a. Climate Change 2007: The 

Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of 

the Intergovernmental Panel on Climate Change. Solomon S, Qin D, Manning M, Chen Z, 

Marquis M, Averyt KB, Tignor M, Miller HL, eds. Cambridge University Press, Cambridge, 

United Kingdom, and New York, New York, United States.

[IPCC] Intergovermental Panel of Climate Change. 2013. Climate Change 2013: The Physical 

Science Basis. Contribution of Working Group I to the Fifth Assessment Report of the 

Intergovernmental Panel on Climate Change. Stocker TF, Qin D, Plattner G-K, Tignor M, 

Allen SK, Boschung J, Nauels A, Xia Y, Bex V, and Midgley PM, eds.

Jacob DJ, Winner DA. 2009. Effect of climate change on air quality. Atmospheric 

Environment 43(51–63).

Johnson J, Maxwell B. 2001. The role of the Conservation Reserve Program in controlling rural 

residential development: Journal of Rural Studies, v. 17, p. 323–332. Available at: 

http://pubs.usgs.gov/of/2010/1198/pdf/OFR2010-1198.pdf (accessed on 12 April 2016). 

Karstensen KA. 2010. Land-cover change in the Ozark Highlands, 1973–2000: 

U.S. Geological Survey Open-File Report 2010–1198, 13 p. Available at 

<http://pubs.usgs.gov/of/2010/1198/pdf/OFR2010-1198.pdf> (accessed 12 April 2016).

[KOMU] KOMU-TV8. 2016. Available at <http://www.komu.com/home/> (accessed 

21 February 2016).

Leahy M. 2010. The Wetlands of Missouri, Missouri Conservationist Magazine. Jefferson City, 

MO. Available at 

<http://www.jeffcomo.org/uploads/stormwater/brochures/missouri%20wetlands.pdf>.

Lenntech. Undated. NC 8400 steel cooking tower, engineering data. Available at 

<http://www.lenntech.com/Data-sheets/Marley-TECH-NC-12-L.pdf> (accessed 

29 February 2016).

Magnuson–Stevens Fishery Conservation and Management Act, as amended. 

16 U.S.C. §1801 et seq.

[MAS] Missouri Archaeological Society. 2015. “Archaeology in Missouri, Missouri 

Archaeological Chronology and History.” Last updated January 2015. Available at 

<http://associations.missouristate.edu/mas/archaeologyinmo.html> (accessed March 2016).

[MCDC] Missouri Census Data Center, Circular Area Profiles (CAPS). 2016a. 2010 Census 

Summary File 1, “Aggregated Census Block Group Data on Hispanic, Latino or Spanish Origin 

and Race,” and 2010–2014 American Community Survey (ACS) data, “Summary of aggregated 

Census Tract data on Poverty within a 5-mile (8-kilometer) radius around the proposed NWMI 

Facility at Discovery Ridge (38.90023214512947 Lat., -92.27653980255128 Long.)” Available 

at <http://mcdc.missouri.edu/websas/caps10c.html> (accessed March 2016).

[MCDC] Missouri Census Data Center, Circular Area Profiles (CAPS). 2016b. 2010 Census 

Summary File 1, “Aggregated Census Block Group Data on Hispanic, Latino or Spanish Origin 

and Race,” and 2010–2014 American Community Survey (ACS) data, “Summary of aggregated 

Census Tract data on Poverty within a 5-mile (8-kilometer) radius around the proposed NWMI 

Facility at MURR (38.931010504851905 Lat., -92.3415940999849 Long.).” Available at 

<http://mcdc.missouri.edu/websas/caps10c.html> (accessed March 2016).

[MDC] Missouri Department of Conservation. Undated. Missouri Natural Heritage Program, 

Heritage Results for Boone County. Available at <https://mdc.mo.gov/property/greenercommunities/heritage-program/results/county/Boone> (accessed 25 January 2017)
References

7-14

[MDC] Missouri Department of Conservation. 2000a. Missouri Animals of Conservation 

Concern. Jefferson City, Missouri. Available at 

<http://mdc.mo.gov/sites/default/files/resources/2010/04/4068_1693.pdf> (accessed 

13 April 2016).

[MDC] Missouri Department of Conservation. 2000b. Missouri Plants of Conservation Concern. 

Jefferson City, Missouri. Available at 

<http://mdc.mo.gov/sites/default/files/resources/2010/04/4069_1692.pdf> (accessed 

13 April 2016).

[MDC] Missouri Department of Conservation. 2010. Missouri Forest and Woodland Community 

Profiles, Missouri Department of Conservation, Jefferson City, Missouri, 2010.

[MDC] Missouri Department of Conservation. 2015. Natural Heritage Review: Level Three 

Report. December 18, 2015. ADAMS No. ML15355A246.

[MDC] Missouri Department of Conservation. 2016a. Three Creeks Conservation Area. 

Available at 

<http://mdc7.mdc.mo.gov/applications/moatlas/AreaSummaryPage.aspx?txtAreaID=8315>

(accessed 22 April 2016).

[MDC] Missouri Department of Conservation. 2016b. Missouri Species and Communities of 

Conservation Concern Checklist. January 2016. Available at 

<http://nature.mdc.mo.gov/sites/default/files/downloads/2016_SOCC.pdf> (accessed 

13 April 2016).

[MDC] Missouri Department of Conservation. 2016c. MDC Discover Nature, Field Guide. 

Available at <http://nature.mdc.mo.gov/discover-nature/field-guide/search> (accessed 

13 April 2016).

[MDC] Missouri Department of Conservation. 2016d. Invasive Plants. Available at 

<http://mdc.mo.gov/your-property/problem-plants-and-animals/invasive-plants> (accessed 

18 April 2016).

[MDC] Missouri Department of Conservation. 2016e. Email dated June 2, 2016: RE: 

Environmental Review for the Proposed Northwest Medical Isotopes, LLC Facility ADAMS 

No. ML16155A148.

[MDOR] Missouri Department of Revenue. Tax Rate Information. Jefferson City, Missouri. 

Available at <http://dor.mo.gov/> (accessed March 2016).

[MDNR] Missouri Department of Natural Resources. Undated. “Missouri State Parks - Rock 

Bridge Memorial State Park.” Available at <https://mostateparks.com/park/rock-bridgememorial-state-park> (accessed 22 February 2016).

[MDNR] Missouri Department of Natural Resources. 2001. Mineral Resources in Missouri, 

Mineral Industries in Missouri. DNR/DGLS Fact Sheet No. 3. Rolla, MO: Division of Geology 

and Land Survey. Available at <http://dnr.mo.gov/geology/adm/publications/docs/mapMinRes.pdf> (accessed 6 February 2016).

[MDNR] Missouri Department of Natural Resources. 2002a. Physiographic Regions of 

Missouri. DNR/DGLS Fact Sheet No. 2. Rolla, MO: Division of Geology and Land Survey. 

Available at <http://dnr.mo.gov/geology/adm/publications/docs/map-ShdRelief.pdf> (accessed 

6 February 2016).

[MDNR] Missouri Department of Natural Resources. 2002b. Missouri Groundwater. 

DNR/DGLS Fact Sheet No. 4. Rolla, MO: Division of Geology and Land Survey. Available at 

<http://dnr.mo.gov/geology/wrc/docs/MoGrndH2O.pdf> (accessed 6 February 2016).
References

7-15

[MDNR] Missouri Department of Natural Resources. 2008. Missouri Ozarks, Division of 

Geology and Land Survey Fact Sheet 20. June 2008. Available at 

<http://dnr.mo.gov/pubs/pub655.pdf> (accessed 13 April 2016).

[MDNR] Missouri Department of Natural Resources, State Historic Preservation Office. 2010. 

Determination that University of Missouri–Columbia Research Reactor is Eligible for Inclusion in 

the National Register of Historic Places. Signed by Mark A. Miles, Director and Deputy State 

Historic Preservation Officer. July 2, 2010. ADAMS No. ML101950104.

[MDNR] Missouri Department of Natural Resources. 2012. Missouri State Operating Permit, 

General Operating Permit. MORA00000. Clean Water Commission. Effective date 

February 8, 2012; Expiration date February 7, 2017. Available at 

<http://dnr.mo.gov/env/wpp/permits/issued/docs/RA00000.pdf> (accessed 3 March 2016).

[MDNR] Missouri Department of Natural Resources. 2014a. Missouri Department of Natural 

Resources 2014 EPA Approved Section 303(d) Listed Waters. Columbia, MO: Water 

Protection Program. 1/6/2014. Available at 

<http://dnr.mo.gov/env/wpp/waterquality/303d/303d.htm> (accessed 6 February 2016).

[MDNR] Missouri Department of Natural Resources. 2014b. “The Stormwater Issue.” Water 

Protection Program Fact Sheet. July 2014. Available at <http://dnr.mo.gov/pubs/pub223.htm> 

(accessed 3 March 2016).

[MDNR] Missouri Department of Natural Resources. 2015a. Missouri Department of Natural 

Resources 2016 Draft Section 303(d) Listed Waters. Columbia, MO: Water Protection 

Program. 9/17/2015. Available at <http://dnr.mo.gov/env/wpp/waterquality/303d/303d.htm> 

(accessed 6 February 2016).

[MDNR] Missouri Department of Natural Resources, State Historic Preservation Office. 2015b. 

“Cultural Resource Assessment, Section 106 Review,” for Northwest Medical Isotopes, LLC 

Radioisotope Production Facility, Columbia (Project Number 017-BO-16). Jefferson City, MO: 

MDNR SHPO. Signed by T.M. Prawl, Ph.D., Deputy State Historic Preservation Officer. 

December 9, 2015. ADAMS No. ML16020A340.

[MDNR] Missouri Department of Natural Resources. 2016a. General Information at Rock 

Bridge Memorial State Park. Available at <https://mostateparks.com/page/54996/generalinformation> (accessed 22 April 2016).

[MDNR] Missouri Department of Natural Resources. 2016b. “Water Quality Standards.” No 

page date. Available at <http://dnr.mo.gov/env/wpp/wqstandards/> (accessed 

6 February 2016).

[MDNR] Missouri Department of Natural Resources. 2016c. “Permits.” Water Protection 

Program. No page date. Available at <http://dnr.mo.gov/env/wpp/permits/index.html> 

(accessed 22 February 2016).

[MDNR] Missouri Department of Natural Resources. 2016d. “Northeast Missouri Groundwater 

Province.” Available at 

<http://dnr.mo.gov/geology/wrc/groundwater/education/provinces/nemissouriprovince.htm> 

(accessed 6 February 2016).

[MDNR] Missouri Department of Natural Resources. 2016e. “Geologic Well Logs of Missouri.” 

[Search/Review of “Well Log Reports by County” for Boone County; Boone County reference 

map dated February 2007.] Missouri Geological Survey. No page date. Available at 

<http://dnr.mo.gov/geology/wrc/logmain/> (accessed 22 February 2016).
References

7-16

[MDNR] Missouri Department of Natural Resources. 2016f. “Wellhead Online Services.” 

[Search of Well Information Management System (WIMS).] No page date. Available at 

<https://www.dnr.mo.gov/mowells/publicLanding.do> (accessed 22 February 2016).

[MDNR] Missouri Department of Natural Resources, State Historic Preservation Office. 2016g. 

“Cultural Resource Assessment, Section 106 Review,” for Northwest Medical Isotopes, LLC 

Radioisotope Production Facility, Columbia (Project Number 017-BO-16). Jefferson City, MO: 

MDNR SHPO. Signed by T.M. Prawl, Ph.D., Deputy State Historic Preservation Officer. 

November 23, 2016. ADAMS No. ML16356A320.

[MDNR] Missouri Department of Natural Resources. 2017. “Stormwater Permits.” No page 

date. Available at <http://dnr.mo.gov/env/wpp/permits/issued/wpcpermits-stormwater.htm> 

(accessed 21 March 2017).

[MGS] Missouri Geological Survey. 2016. “Missouri Geosciences Technical Resource 

Assessment Tool.” [Data layers and metadata: Bedrock Geology Bedrock (1:24,000 scale); 

Bedrock (1:500,000 scale); Depth to Bedrock; Geologic Structures; Groundwater Depth; 

Groundwater Elevation; TDS-Cherokee Group Aquifer; TDS-Mississippian Aquifer; Karst Losing 

and Gaining Streams; Springs; Sinkhole Areas; Mines Inventory of Mines, Occurrences and 

Prospects; Abandoned Mine Lands Projects; Surficial Geology Alluvium; Surficial Geology; 

Wells.] Missouri Department of Natural Resources, Missouri Geological Survey. No page date. 

Available at <http://dnr.mo.gov/geostrat/> (accessed 6 February 2016).

Migratory Bird Treaty Act of 1918. 16 U.S.C. §703–712.

Miller JA, Appel CL. 1997. Ground Water Atlas of the United States, Segment 3, Kansas, 

Missouri, Nebraska. Reston, VA: U.S. Geological Survey. HA-730-D. Available at 

<http://water.usgs.gov/ogw/aquifer/atlas.html> (accessed 2 February 2016).

Miller NP. 2002. Transportation Noise and Recreational Lands. The 2002 International 

Congress and Exposition and Noise Control Engineering, Dearborn, MI. August 19–21, 2002.

Missouri Office of Administration. 2016. Division of Budget and Planning, State of Missouri. 

“Population Projections – Total Population Missouri Counties: 2000 through 2030.” Available at 

<https://oa.mo.gov/budget-planning/demographic-information/population-projections/2000-2030-

projections> (accessed March 2016).

Missouri Revised Statutes. 2015a. Missouri Revised Statutes Chapter 172, State University—

University of Missouri. August 28, 2015. Available at 

<http://www.moga.mo.gov/mostatutes/stathtml/17200002731.html> (accessed 18 April 2016).

Missouri Revised Statutes. 2015b. Missouri Revised Statutes Chapter 260, Environmental 

Control. August 28, 2015. Available at 

<http://www.moga.mo.gov/mostatutes/stathtml/26000003501.html> (accessed 29 June 2016).

[MMRPC] Mid-Missouri Regional Planning Commission. 2015. Boone County Hazard 

Mitigation Plan, 2015. Ashland, MO: Mid-Missouri Regional Planning Commission. 

October 2010. Available at <http://www.mmrpc.org/reports-library/hazard-mitigation-reports/> 

(accessed 15 February 2016).

[MODOT] Missouri Department of Transportation. 2013. 2013 Traffic Counts Map. Available at 

<http://www.gocolumbiamo.com/community-development/planning/traffic-counts/> (accessed 

14 March 2016).
References

7-17

[MU] University of Missouri. 2006. University of Missouri, Columbia, Missouri University 

Research Reactor (MURR), License Renewal Application Safety Analysis Report. Columbia, 

MO: Curators of the University of Missouri. August 18, 2006. ADAMS Nos. ML092110573 and 

ML092110597.

[MU] University of Missouri-Columbia. 2009. Revised Master Plan: Discovery Ridge, 

University of Missouri, Where Science goes to Work. Columbia, MO. January 6, 2009. 

Available at <https://uminfopoint.umsystem.edu/media/ed/Discoveryridge/DRMaster%20Plan%20and%20Convenants.pdf> (accessed 18 April 2016).

[MU] University of Missouri Research Reactor. 2010. University of Missouri-Columbia 

Research Reactor’s Responses to the NRC RAI dated April 20, 2010. ADAMS 

No. ML101440148.

[MU] University of Missouri. 2013. Pickard Hall Radiological Operations and Restrictions. 

ADAMS No. ML13135A616

[MU] University of Missouri. 2014. University of Missouri Research Reactor 2013 Reactor 

Operations Annual Report. ADAMS No. ML14063A044.

[MU] University of Missouri. 2015a. University of Missouri Research Reactor 2014 Reactor 

Operations Annual Report. ADAMS No. ML15061A293

[MU] University of Missouri. 2015b. 2014 Annual Water Quality Report. Columbia, MO: 

University of Missouri. Available at <http://www.cf.missouri.edu/energy/em_pp/ccr.pdf> 

(accessed 3 March 2016).

[MU] University of Missouri. 2016a. About Discovery Ridge. Available at 

<https://www.umsystem.edu/ums/aa/umrpi/discoveryridge/about> (accessed 21 April 2016).

[MU] University of Missouri. 2016b. Fast Facts. Available at 

<http://admissions.missouri.edu/mizzou-life/fast-facts.php> (accessed 21 April 2016).

[MU] University of Missouri. 2016c. The Curators of the University of Missouri, Amended 

Facility License. ADAMS No. ML14136A088.

[MU] University of Missouri. 2016d. University of Missouri Research Reactor 2015 Reactor 

Operations Annual Report. ADAMS No. ML16060A211.

[MU] University of Missouri. 2016e. Notice that the University of Missouri Research Reactor 

Intends to Submit a License Amendment in Support of Northwest Medical Isotopes, Inc.’s 

Molybdenum 99 Project. ADAMS No. ML16039A162.

[MU] University of Missouri. 2016f. “About MURR – Operations and General.” Available at 

<http://www.murr.missouri.edu/operations.php> (accessed 22 February 2016).

[MU] University of Missouri Research Reactor Center. 2016g. Discovery Ridge – Current 

Tenants. Available at <https://www.umsystem.edu/ums/aa/umrpi/discoveryridge/tenants> 

(accessed 21 February 2016).

[MU] University of Missouri. 2016h. University of Missouri Health System. Available at 

<http://www.muhealth.org/> (accessed 22 February 2016).

[MU] University of Missouri. 2016i. “A.L. Gustin Golf Course.” Available at 

<http://www.gustingolfcourse.com/> (accessed 22 February 2016).

[MU] University of Missouri. 2016j. “Utility Production.” Columbia, MO: University of Missouri, 

Campus Facilities-Energy Management. Page updated 2016. Available at 

<http://www.cf.missouri.edu/energy/em_pp/> (accessed 3 March 2016).
References

7-18

National Environmental Policy Act of 1969, as amended (NEPA). 42 U.S.C. §4321 et seq.

National Historic Preservation Act of 1966. 54 U.S.C. §300101 et seq.

National Research Council. 2009. Medical Isotope Production Without Highly Enriched 

Uranium. Washington, DC: The National Academies Press. Available at 

<http://www.nap.edu/catalog.php?record_id=12569> (accessed 29 February 2016).

[NASS] National Agricultural Statistics Service, U.S. Department of Agriculture. 2014. “2012 

Census of Agriculture,” Volume 1, Chapter 2, County Level, Table 7. “Hired Farm Labor –

Workers and Payroll: 2012.” 2012 Census of Agriculture, Volume 1 Chapter 2, County Level 

Data for Missouri. Last modified: April 15, 2014. Available at 

<http://www.agcensus.usda.gov/Publications/2012/Full_Report/Census_by_State/> (accessed 

March 2016).

[NCDC] National Climatic Data Center. 2010. Data Tools: 1981–2010 Normals, Columbia 

Regional Airport, MO. Available at <https://www.ncdc.noaa.gov/data-access/land-basedstation-data/land-based-datasets/climate-normals> (accessed 16 February 2016).

[NCDC] National Climatic Data Center. 2014. 2014 Local Climatological Data Annual Summary 

with Comparative Data, Columbia, MO (KCOU). Available at 

<http://www.weather.gov/lsx/cli_archive> (accessed 16 February 2016).

[NCDC] National Climatic Data Center. 2016. Storm Events Database. Available at 

<https://www.ncdc.noaa.gov/stormevents/> (accessed 16 February 2016).

[NCES] National Center for Education Statistics. 2015a. “College Navigator.” U.S. Department 

of Education, Washington, D.C. College and university student population within 20 miles of 

ZIP code 65201. Released July 2015. Available at 

<http://nces.ed.gov/collegenavigator/default.aspx> (accessed March 2016).

[NCES] National Center for Education Statistics. 2015b. Public School Districts in Boone 

County, Missouri. 2013-2014, 2014-2015 school years. Available at 

<http://nces.ed.gov/ccd/districtsearch/> (accessed March 2016).

Nigh TA, Schroeder WA. 2002. Atlas of Missouri Ecoregions, Missouri Department of 

Conservation, Jefferson City, Missouri, 2002.

Niles LJ, Sitters HP, Dey AD, Atkinson PW, Baker AJ, Bennet KA, Carmoa R, Clark KE, Clark 

NA, Espoza C. 2008. Status of the red knot (Calidris canutus rufa) in the Western Hemisphere. 

Studies in Avian Biology(36): 1–185.

[Niowave] Niowave, Inc. 2015. Letter from T.L. Grimm, Niowave, President and Senior 

Scientist to Region III, NRC. Subject: Combined Application for a License to Produce and 

Possess Accelerator Produced Radionuclides for Research and Development (NRC Control 

No. 584728). February 11, 2015. ADAMS No. ML15043A755.

[NMFS] National Marine Fisheries Service. 2016. Essential Fish Habitat Mapper v3.0. 

Available at <http://www.habitat.noaa.gov/protection/efh/habitatmapper.html> (accessed 

13 April 2016).

[NNSA] National Nuclear Security Administration. 2011. NNSA Works to Minimize the Use of 

HEU in Medical Isotope Production. NNSA Fact Sheet 20100125. November 1, 2011. 

Available at <http://www.nnsa.energy.gov/mediaroom/factsheets/factsheet20100125> 

(accessed 27 April 2016).
References

7-19

[NOAA] National Oceanic and Atmospheric Administration. 2013a. Regional Climate Trends 

and Scenarios for the U.S. National Climate Assessment, Part 9. Climate of the Contiguous 

United States. NOAA Technical Report NESDID 142–9.

[NOAA] National Oceanic and Atmospheric Administration. 2013b. Regional Climate Trends 

and Scenarios for the U.S. National Climate Assessment, Part 3. Climate of the Midwest. 

NOAA Technical Report NESDID 142–3.

[NOAA] National Oceanographic and Atmospheric Administration. 2016. Coastal Zone 

Management Programs. Available at < https://coast.noaa.gov/czm/mystate/> (accessed 

25 April 2016).

Noise Control Act of 1972. 42 U.S.C. §4901 et seq.

[NPS] National Park Service. 2015. “Earth Science Concepts, Geology by Region, 

Physiographic Provinces, Province Maps.” Page updated 11/05/15. U.S. Department of the 

Interior. Available at 

<https://www.nature.nps.gov/geology/education/concepts/concepts_regional_geology.cfm> 

(accessed 2 February 2016).

[NRC] U.S. Nuclear Regulatory Commission. 1977. NUREG–0170, Final Environmental Impact 

Statement on the Transportation of Radioactive Materials by Air and Other Modes. ADAMS 

No. ML12192A283.

[NRC] U.S. Nuclear Regulatory Commission. 1998. NUREG/CR–6410, Nuclear Fuel Cycle 

Facility Accident Analysis Handbook. ADAMS No. ML072000468.

[NRC] U.S. Nuclear Regulatory Commission. 2008. Oregon State University TRIGA Reactor 

Environmental Assessment Regarding Renewal of Facility License No. R-106 

(TAC No. MC5155). ADAMS No. ML061650197. 

[NRC] U.S. Nuclear Regulatory Commission. 2011a. Approval for Release of Analytical BioChemistry Laboratories Sanitary Ponds for Unrestricted Use. October 17, 2011. ADAMS 

No. ML113000281.

[NRC] U.S. Nuclear Regulatory Commission. 2011b. Memorandum from B. Clayton to 

S. Flanders. Subject: “Revision 1—Addressing the Construction and Preconstruction Activities, 

Greenhouse Gas Issues, General Conformity Determinations, Environmental Justice, the Need 

for Power, Cumulative Impact Analysis and Cultural/Historical Resources Analysis Issues in 

Environmental Impact Statements.” March 4, 2011. ADAMS No. ML110380369.

[NRC] U.S. Nuclear Regulatory Commission. 2012. Final Interim Staff Guidance Augmenting 

NUREG–1537, Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of 

Non-Power Reactors: Format and Content, for Licensing Radioisotope Production Facilities and 

Aqueous Homogeneous Reactors; and Part 2, Guidelines for Preparing and Reviewing 

Applications for the Licensing of Non-Power Reactors: Standard Review Plan and Acceptance 

Criteria,” for Licensing Radioisotope Production Facilities and Aqueous Homogeneous 

Reactors. Washington, DC: NRC. NUREG–1537. October 17, 2012. ADAMS 

Nos. ML12156A069 and ML12156A075.

[NRC] U.S. Nuclear Regulatory Commission. 2013a. “Environmental Issues Associated with 

New Reactors, Interim Staff Guidance.” August 2013. ADAMS No. ML12326A742.

[NRC] U.S. Nuclear Regulatory Commission. 2013b. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants. Revision 1, Volume 1, 2, and 3. Washington, DC: 

NRC. NUREG–1437. June 19, 2013. ADAMS No. ML13107A023.
References

7-20

[NRC] U.S. Nuclear Regulatory Commission. 2013c. Environmental Assessment and Finding 

of No Significant Impact for License Amendment Request for Analytical Bio-Chemistry 

Laboratories, Inc. January 2013. ADAMS No. ML13009A030

[NRC] U.S. Nuclear Regulatory Commission. 2013d. Approval for Release of Sanitary Lagoon 

and Surrounding Effluent Discharge Area for Unrestricted Use. January 18, 2013. ADAMS 

No. ML13035A034.

[NRC] U.S. Nuclear Regulatory Commission. 2014. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants Regarding Callaway Plant, Unit 1, Final Report. 

Washington, DC: NRC. NUREG–1437, Supplement 51. October 2014. ADAMS 

No. ML14289A140.

[NRC] U.S. Nuclear Regulatory Commission. 2014a. Spent Fuel Transportation Risk 

Assessment, Final Report. Washington, DC: NRC. NUREG–2125. January 2014. ADAMS 

No. ML14031A323.

[NRC] U.S. Nuclear Regulatory Commission. 2015a. “Northwest Medical Isotopes, LLC–Status 

of the Acceptance Review of Part One of the Application for Construction Permit. 

January 23, 2015. ADAMS No. ML14349A501.

[NRC] U.S. Nuclear Regulatory Commission. 2015b. “Summary of the Environmental Site 

Audit Related to the Review of Construction Permit Application.” Washington, DC: NRC. 

October 13, 2015. ADAMS Package No. ML15266A139.

[NRC] U.S. Nuclear Regulatory Commission. 2015c. Environmental Impact Statement for the 

Construction Permit for the SHINE Medical Radioisotope Production Facility, Final Report. 

NUREG–2183. Rockville, MD. October 2015. ADAMS No. ML15288A046.

[NRC] U.S. Nuclear Regulatory Commission. 2015d. NRC Staff Responses to Commission 

Pre-Hearing Questions. ADAMS No. ML15328A546

[NRC] U.S. Nuclear Regulatory Commission. 2015e. Teleconference Summary with M. Moser, 

NRC and A. Salveter, FWS. Subject: Scoping Comments Regarding the Environmental Review 

for the Northwest Medical Isotopes, LLC (NWMI) Construction Permit Application. 

December 3, 2015. ADAMS No. ML15362A225.

[NRC] U.S. Nuclear Regulatory Commission. 2015f. Request for Scoping Comments 

Concerning the Northwest Medical Isotopes, LLC Radioisotope Production Facility Application 

Review. ADAMS Nos. ML15314A363 and ML15314A686.

[NRC] U.S. Nuclear Regulatory Commission. 2015g. “Callaway Plant, Unit 1.” 

December 1, 2015. Available at <http://www.nrc.gov/info-finder/reactors/call.html> (accessed 

22 February 2016).

[NRC] U.S. Nuclear Regulatory Commission. 2015h. Materials License for ABC Laboratories, 

amended through Amendment No. 47. ADAMS No. ML15259A250.

[NRC] U.S. Nuclear Regulatory Commission. 2016a. “Summary of the Public Scoping Meeting 

Conducted Related to the Review of the Proposed Northwest Medical Isotopes, LLC 

Radioisotope Production Facility.” Washington, DC: NRC. January 20, 2015. ADAMS 

Package No. ML15356A096.

[NRC] U.S. Nuclear Regulatory Commission. 2016b. Summary of the Telephone Conference 

Call Held on July 7, 2016, Between the U.S. Nuclear Regulatory Commission and Missouri 

Department of Conservation Concerning the Northwest Medical Isotopes, LLC Radioisotope 

Production Facility Vegetation Assessment. ADAMS No. ML16214A373.
References

7-21

[NRC] U.S. Nuclear Regulatory Commission. 2016c. Doses in our Daily Lives. Available at 

<http://www.nrc.gov/about-nrc/radiation/around-us/doses-daily-lives.html> (accessed 

29 March 2016).

[NRC] U.S. Nuclear Regulatory Commission. 2016d. Oregon State University-Issuance of 

Amendment No. 23 to Renewed Facility Operating License No. R-106 to Allow the Irradiation of 

Up to Three Medical Isotopes Production Targets Containing Fissionable Material 

(TAC No. ME8443). ADAMS No. ML15310A126.

[NRC] U.S. Nuclear Regulatory Commission. 2016e. Locations of Low-Level Waste Disposal 

Facilities. Available at<http://www.nrc.gov/waste/llw-disposal/licensing/locations.html> 

(accessed 20 April 2016).

[NRC] U.S. Nuclear Regulatory Commission. 2016f. Email: D. Drucker, NRC, to C. Haass, 

NWMI, transmitting letter from Missouri Department of Conservation to NRC dated June 2, 2016 

regarding mitigation measures for consideration at proposed NWMI facility Discovery Ridge site. 

ADAMS No. ML16190A427.

[NRC] U.S. Nuclear Regulatory Commission. 2016g. Environmental Impact Statement for 

Construction Permit for the Northwest Medical Isotopes Radioisotope Production Facility, Final 

Report. NUREG–2209. Rockville, MD. October 2016. ADAMS No. ML16305A029.

[NRCS] Natural Resources Conservation Service. 2016a. Web Soil Survey, Soil Map—Boone 

County, Missouri. [Discovery Drive (Discovery Ridge site), Columbia, MO; search parameters: 

soil map; soil data explorer: soil reports; map unit description; suitabilities and limitations 

ratings, building site development]. Updated December 6, 2013. U.S. Department of 

Agriculture, National Cooperative Soil Survey. Available at 

<http://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm> (accessed 5 February 2016).

[NRCS] Natural Resources Conservation Service. 2016b. “National Soil Survey Handbook,” 

U.S. Department of Agriculture, Natural Resources Conservation Service, Washington, D.C. 

March 2016 Available at 

<http://www.nrcs.usda.gov/wps/portal/nrcs/detail/soils/ref/?cid=nrcs142p2_054241>

(accessed 22 April 2016).

[NRCS] Natural Resources Conservation Service. 2016c. Web Soil Survey, Soil Map—Boone 

County, Missouri. [Research Park Drive (MURR site), Columbia, MO; search parameters: soil

map; soil data explorer: soil reports; map unit description; suitabilities and limitations ratings, 

building site development]. Updated December 6, 2013. U.S. Department of Agriculture, 

National Cooperative Soil Survey. Available at 

<http://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm> (accessed 16 February 2016).

[NRHP] National Register of Historic Places. 2015. Spreadsheet of NHLs. Available at 

<http://www.nps.gov/nr/research/index.htm> (accessed 22 February 2015).

[NWMI] Northwest Medical Isotopes, LLC. 2015a. Preliminary Safety Analysis Report (PSAR), 

Chapter 19, “Environmental Report.” Corvallis, OR: NWMI. January 2015. ADAMS 

Nos. ML15086A263, ML150864264, ML15086A265, ML15086A268, ML15086A269, 

ML15086A270, and ML15086A271.

[NWMI] Northwest Medical Isotopes, LLC. 2015b. NRC Project No. 0803 Northwest Medical 

Isotopes, LLC, Submittal Part 1 Construction Permit Application for a Radioisotope Production 

Facility- Withdrawal of Part 1 Application Submitted on November 7, 2014 and Resubmittal of 

Application. ADAMS No. ML15086A262
References

7-22

[NWMI] Northwest Medical Isotopes, LLC. 2015c. Northwest Medical Isotopes, LLC. 

Application for Construction Permit, Response to the U.S. Nuclear Regulatory Commission 

Request for Additional Information, Environmental Review of the Northwest Medical Isotopes, 

LLC Construction Permit Application. ADAMS No. ML15328A010.

[NWMI] Northwest Medical Isotopes, LLC. 2015d. Preliminary Safety Analysis Report (PSAR), 

Chapter 19, “Environmental Report.” Corvallis, OR: NWMI. June 2015. ADAMS 

No. ML15210A182.

[NWMI] Northwest Medical Isotopes, LLC. 2015e. Preliminary Safety Analysis Report (PSAR), 

Chapter 3, “Design of Structures, Systems, and Components” ”and Chapter 4, “Radioisotope 

Production Facility Description.” June 2015. ADAMS No. ML15210A117.

[NWMI] Northwest Medical Isotopes, LLC. 2015f. Preliminary Safety Analysis Report (PSAR), 

Chapter 8, “Electrical Power Systems.” June 2015. ADAMS No. ML15210A120.

[NWMI] Northwest Medical Isotopes, LLC. 2015g. Preliminary Safety Analysis Report (PSAR), 

Chapter 9 “Auxiliary Systems,” Chapter 10, “Experimental Facilities” Chapter 11, “Radiation 

Protection and Waste Management ” and Chapter 12, “Conduct of Operations .” June 2015. 

ADAMS No. ML15210A118.

[NWMI] Northwest Medical Isotopes, LLC. 2015h. Chapter 2.0 – Site Characteristics, 

Construction Permit Application for Radioisotope Production Facility. NWMI-2013-021, Rev. 0. 

Corvallis, OR: Northwest Medical Isotopes, LLC. January 2015. ADAMS No. ML15086A263, 

ML15086A24, and ML15086A265.

[NWMI] Northwest Medical Isotopes, LLC. 2015i. Preliminary Safety Analysis Report (PSAR), 

Chapter 13, “Accident Analysis.” June 2015. ADAMS Nos. ML15210A124 and ML15210A122.

[NWMI] Northwest Medical Isotopes, LLC. 2015j. Preliminary Safety Analysis Report (PSAR), 

Chapter 15 “Financial Qualifications.” June 2015 ADAMS No. ML15210A182.

[NWMI] Northwest Medical Isotopes, LLC. 2016a. Northwest Medical Isotopes, LLC Response 

to the U.S. Nuclear Regulatory Commission Request for Additional Information–Letter Dated 

January 19, 2016. ADAMS No. ML16053A221.

[NWMI] Northwest Medical Isotopes, LLC. 2016b. Northwest Medical Isotopes, LLC 

Responses to the U.S. Nuclear Regulatory Commission Environmental Request for Additional 

Information-Letter Dated March 28, 2016. ADAMS No. ML16123A119.

[NWMI] Northwest Medical Isotopes, LLC. 2016c. Northwest Medical Isotopes, LLC Response 

to the U.S. Nuclear Regulatory Commission Request for Additional Information–Letter Dated 

June 16, 2016. ADAMS No. ML16210A305.

[NWMI] Northwest Medical Isotopes, LLC. 2016d. Northwest Medical Isotopes, LLC

Responses to the U.S. Nuclear Regulatory Commission Environmental Request for Additional 

information (Letter dated June 16, 2016) – Additional Clarification on POSA3-1A, POSA3-1B, 

POSA3-2A, POSA3-3A, NOI3-1B, and PA3-1 Dated September 1, 2016. ADAMS 

No. ML16270A377.

[NWMI] Northwest Medical Isotopes, LLC. 2016e. Northwest Medical Isotopes, LLC 

Responses to the U.S. Nuclear Regulatory Commission Regarding the Preliminary Safety 

Analysis Report Request for Additional Information (Letter dated September 29, 2016). ADAMS 

No. ML16344A049.

[NWMI] Northwest Medical Isotopes, LLC. 2017. Electronic Mail to the U.S. Nuclear Regulatory 

Commission Providing Clarification Regarding Radioactive Waste Storage and Disposal. 

February 1, 2017. ADAMS No. ML17032A126.
References

7-23

Occupational Safety and Health Act of 1970. 29 U.S.C. §651.

[ODOT] Oregon Department of Transportation. 2014a. Traffic Flow Map 2014. Available at 

<http://www.oregon.gov/ODOT/TD/TDATA/tsm/docs/Flow_Map_2014.pdf> (accessed 

16 February 2016).

[ODOT] Oregon Department of Transportation. 2014b. Section II, 2014 Traffic Volumes on 

State Highways. Available at 

<http://www.oregon.gov/ODOT/TD/TDATA/tsm/docs/TVT_2014.pdf> (accessed 

16 February 2016).

[OECD] Organisation for Economic Co-operation and Development–Nuclear Energy Agency. 

2014. The Supply of Medical Radioisotopes—Medical Isotope Supply in the Future: Production 

Capacity and Demand Forecast for the 99Mo/99mTc Market, 2015-2020. Organization for 

Economic Co-operation and Development. Available at <http://www.oecd-nea.org/medradio/reports/sen-hlgmr2014-2.pdf> (accessed 27 April 2016).

Ogden LJ. 1996. Collision Course: The Hazards of Lighted Structures and Windows to 

Migrating Birds. Fatal Light Awareness Program (FLAP). Paper 3. Available at 

<http://digitalcommons.unl.edu/flap/3?utm_source=digitalcommons.unl.edu%2Fflap%2F3&utm_

medium=PDF&utm_campaign=PDFCoverPages> (accessed 12 April 2016).

[OSHA] Occupational Safety and Health Administration. 2013. Memorandum of Understanding 

Between the U.S. Nuclear Regulatory Commission and the Occupational Safety and Health 

Administration. Available at <https://www.osha.gov/pls/oshaweb/owadisp.show_document? 

p_table=MOU&p_id=1245> (accessed 16 September 2016).

[OSU] Oregon State University. 2004. Environmental Report, In Support of Application for 

Renewal of Operating License. ADAMS No. ML043270077. October 5, 2004.

[OSU] Oregon State University. 2006. Oregon State University TRIGA Reactor (OSTR), 

Response to RAI. ADAMS No. ML061510355. May 24, 2006.

[OSU] Oregon State University. 2012. License Amendment Application for the Purpose of 

Demonstrating Mo-99 production Capability in the OSTR. ADAMS No. ML12124A265.

[OSU] Oregon State University. 2013. Oregon State University TRIGA Reactor, 2012 Annual 

Report. ADAMS No. ML13304A799.

[OSU] Oregon State University. 2014. Oregon State University TRIGA Reactor, 2013 Annual 

Report. ADAMS No. ML14303A305.

[OSU] Oregon State University. 2015a. Oregon State University TRIGA Reactor, 2014 Annual 

Report. ADAMS Nos. ML15289A436 and ML15289A437.

[OSU] Oregon State University. 2015b. License Amendment Application for the Purpose of 

Demonstrating Mo-99 production Capability in the OSTR. ADAMS No. ML15134A015.

[OSU] Oregon State University. 2016. Appendix A to Facility License No. R-106, Amendment 

No. 23, Technical Specifications. ADAMS No. ML15329A197.

Petersen MD, Moschetti MP, Powers PM, Mueller CS, Haller KM, Frankel AD, Zeng Y, 

Rezaeian S, Harmsen SC, Boyd OS, Field EH, Chen R, Luco N, Wheeler RL, Williams RA, 

Olsen AH, Rukstales KS. 2015. Seismic-Hazard Maps for the Conterminous United States, 

2014. Denver, CO: U.S. Geological Survey. Scientific Investigations Map 3325, 6 sheets. 

Available at <http://pubs.usgs.gov/sim/3325/> (accessed 6 February 2016).
References

7-24

Reed JC, Bush CA. 2007. About the Geologic Map in the National Atlas of the United States of 

America. Reston, VA: U.S. Geological Survey. Circular 1300. Available at 

<http://pubs.usgs.gov/circ/1300/pdf/Cir1300_508.pdf> (accessed 6 February 2016).

Resource Conservation and Recovery Act. 42 U.S.C. §6901 et seq.

[SCS] Soil Conservation Service. 1990. Part 650 – Engineering Field Handbook, Chapter 4. 

Elementary Soil Engineering. Washington, DC: U.S. Department of Agriculture. Available at 

<http://directives.sc.egov.usda.gov/viewerFS.aspx?hid=21429> (accessed 6 February 2016).

Sharp JM. 1984. Hydrogeologic characteristics of shallow glacial drift aquifers in Dissected Till 

Plains (north-central Missouri). Ground Water 22(6): 683–689. Available at 

<https://info.ngwa.org/GWOL/pdf/842932483.PDF> (accessed 6 February 2016).

[SHINE] SHINE Medical Technologies, Inc. 2015. Preliminary Safety Analysis Report (PSAR), 

Chapter 19, “Environmental Report.” Monona, WI: SHINE. June 16, 2015. ADAMS 

No. ML15175A274.

Stoeser DB, Green GN, Morath, LC, Heran, WD, Wilson, AB, Moore, DW, Van Gosen, BS. 

2007. Preliminary integrated geologic map databases for the United States: Central States: 

Montana, Wyoming, Colorado, New Mexico, North Dakota, South Dakota, Nebraska, Kansas, 

Oklahoma, Texas, Iowa, Missouri, Arkansas, and Louisiana. [Missouri geologic map data.] 

U.S. Geological Survey Open-File Report (2005–1351). Version 1.2, Updated December 2007. 

Available at <https://mrdata.usgs.gov/geology/state/state.php?state=MO> (accessed 

6 February 2016).

Tagaris E, Manomaiphiboon K, Liao KJ, Leung LR, Woo JH, He S, Amar P, Russell 

AG. 2007. Impacts of Global Climate Change and Emissions on Regional Ozone and Fine 

Particulate Matter Concentrations over the United States. Journal of Geophysical Research, 

112, D14312.

Tagaris E, Manomaiphiboon K, Liao K, Leung LR, Woo J, He S, Amar P, Russell AG. 2009. 

Impacts of Global Climate Change and Emissions on Regional Ozone and Fine particulate 

Matter Concentrations over the United States. Journal of Geophysical Research(112): D14312.

[Terracon] Terracon Consultants, Inc. 2011a. Preliminary Geotechnical Engineering Report, 

Discovery Ridge – Certified Site Program Lots 2, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17 

and 18, Columbia, Missouri. Columbia, MO: Terracon Consultants. Prepared for Trabue 

Hansen & Hinshaw, Inc. February 17, 2011.

[Terracon] Terracon Consultants, Inc. 2011b. Phase I Environmental Site Assessment, 

Discovery Ridge, Lots 2, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17 and 18, Columbia, Boone 

County, Missouri. Columbia, MO: Terracon Consultants. Terracon Project No. 09117701. 

Prepared for Trabue Hansen & Hinshaw, Inc. March 23, 2011.

The Columbia Missourian. 2015. “Evicted: Ed’s and Sunset mobile home park residents leave 

homes behind.” Available at <http://www.columbiamissourian.com/news/local/evicted-ed-s-andsunset-mobile-home-park-residents-leave/article_997b0a2c-6798-11e5-b213-

4b373df4900b.html> (accessed 12 December 2015).

Thompson TL. 1979. The Mississippian and Pennsylvanian (Carboniferous) Systems in the 

United States, Missouri. Washington, DC: U.S. Geological Survey. Professional 

Paper 1110–N. Available at <http://pubs.usgs.gov/pp/1110m-dd/report.pdf> (accessed 

6 February 2016).
References

7-25

TRIUMF. 2008. Making Medical Isotopes: Report of the Task Force on Alternatives for 

Medical-Isotope Production. Vancouver, BC: University of British Columbia. Available at 

<http://www.triumf.ca/report-medical-isotope-production> (accessed 11 April 2016).

[UP] Union Pacific Railroad. 2015. “Union Pacific in Missouri,” Omaha, Nebraska. Available at 

<www.up.com/cs/groups/public/documents/up_pdf_nativedocs/pdf_missouri_usguide.pdf>, 

(accessed March 2016).

USA Parks. 2015. “Rock Bridge Memorial State Park.” Available at 

<http://www.stateparks.com/rock_bridge_memorial_state_park_in_missouri.html> (accessed 

22 February 2016).

[USCB] United States Census Bureau. 2016a. Quick Facts: Columbia City, Missouri. 

Available at <http://www.census.gov/quickfacts/table/PST045214/29019> (accessed 

21 April 2016).

[USCB] U.S. Census Bureau. 2016b. 1970–2010 Decennial Census: 1900 to 1990; 

“Table DP–1 – Profile of General Demographic Characteristics: 2000”, and American 

FactFinder, Table DP–1, “Profile of General Population and Housing Characteristics: 2010, 

2010 Demographic Profile Data,” and Table P9, “Hispanic or Latino or Not Hispanic or Latino by 

Race” for Boone County, Missouri. Available at 

<http://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t> (accessed 

March 2016).

[USCB] U.S. Census Bureau. 2016c. American FactFinder, Table DP–1, “Profile of General 

Population and Housing Characteristics: 2010, 2010 Demographic Profile Data,” and American 

FactFinder, “2014 American Community Survey 1-Year Estimates,” Table DP05 – “ACS 

Demographic and Housing Estimates” for Columbia and Boone County, Missouri. Available at 

<http://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t> (accessed 

March 2016).

[USCB] U.S. Census Bureau. 2016d. American FactFinder, Table DP03 – “Selected Economic 

Characteristics,” 2014, 1-Year Estimates for Missouri, Boone County and Columbia. Available 

at <http://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t> and for 

Poverty Thresholds by size of family and number of children. Available at 

<http://www.census.gov/hhes/www/poverty/data/threshld/index.html> (accessed March 2016).

[USCB] U.S. Census Bureau. 2016e. “American FactFinder, “2014 American Community 

Survey 1-Year Estimates,” Table DP04 – Selected Housing Characteristics” for Columbia and 

Boone County. Available at 

<http://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t> (accessed 

March 2016).Population Growth Rates and Projections.

[USDA] U.S. Department of Agriculture. 2014. 2012 Census of Agriculture, Volume 1, 

Chapter 2: County Level Data: Missouri. May 2, 2014. Available at 

<https://www.agcensus.usda.gov/Publications/2012/Full_Report/Volume_1,_Chapter_2_County

_Level/Missouri/st29_2_001_001.pdf> (accessed 22 April 2016).

[USDA] U.S. Department of Agriculture. 2016a. Welcome to the Mark Twain National Forest. 

Available at <http://www.fs.usda.gov/mtnf> (accessed 22 April 2016).

[USDA] U.S. Department of Agriculture. 2016b. Missouri Electronic Field Office Technical 

Guide, U.S. Department of Agriculture, Washington, D.C. Available at 

<https://efotg.sc.egov.usda.gov/treemenuFS.aspx> (accessed 18 April 2016).
References

7-26

[USDA] U.S. Department of Agriculture. 2016c. PLANTS Database, U.S. Department of 

Agriculture, Washington, D.C. Available at <http://plants.usda.gov/java/> (accessed 

18 April 2016).

[USGCRP] U.S. Global Change Research Program. 2009. Global Climate Change Impacts in 

the United States. Karl TR, Melillo JM, Peterson TC, eds. ADAMS No. ML100580077.

[USGCRP] U.S. Global Change Research Program. 2014. Climate Change Impacts in the 

United States: The Third National Climate Assessment. Melillo JM, Richmond TC, Yohe GW, 

eds. May 9, 2014. ADAMS No. ML14129A233.

[USGS] U.S. Geological Survey. 1985. National water summary 1984; hydrologic events, 

selected water-quality trends, and ground-water resources. Washington, DC: U.S. Department 

of the Interior, U.S. Geological Survey. Water Supply Paper 2275. Available at 

<https://pubs.er.usgs.gov/publication/wsp2275> (accessed 6 February 2016).

[USGS] U.S. Geological Survey. 2006. National Land Cover Database. ESRI ArcGIS 9.3.1 

software. Available at <http://viewer.nationalmap.gov/viewer> (accessed 24 April 2016).

[USGS] U.S. Geological Survey. 2009. The Ozark Highlands, A distinctive Landscape. Fact 

Sheet 2009–3065. August 2009. Available at< http://pubs.usgs.gov/fs/2009/3065/pdf/FS2009-

3065.pdf> (accessed 12 April 2016).

[USGS] U.S. Geological Survey. 2014a. “Geologic Provinces of the United States: Interior 

Plain Province, Subprovince Index Map.” Page Last Modified October 2, 2014. Available at 

<http://geomaps.wr.usgs.gov/parks/province/intplain.html> (accessed 9 January 2016).

[USGS] U.S. Geological Survey. 2014b. “Historic Earthquakes, New Madrid 1811–1812 

Earthquakes, Isoseismal Map.” Page updated April 18, 2014. Available at 

<http://earthquake.usgs.gov/earthquakes/states/events/1811-1812.php> (accessed 

6 February 2016).

[USGS] U.S. Geological Survey. 2014c. “Magnitude/Intensity Comparison.” U.S. Department 

of the Interior, U.S. Geological Survey, Earthquake Hazards Program. Page updated 

September 29, 2014. Available at <http://earthquake.usgs.gov/learn/topics/mag_vs_int.php> 

(accessed 6 February 2016).

[USGS] U.S. Geological Survey. 2015a. Columbia Quadrangle, Missouri-Boone County, 

7.5 Minute Series. U.S. Department of the Interior, U.S. Geological Survey. Available at 

<http://viewer.nationalmap.gov/basic/#productSearch> (accessed 6 February 2016).

[USGS] U.S. Geological Survey. 2015b. Quaternary Fault and Fold Database of the 

United States. U.S. Department of the Interior, U.S. Geological Survey, Earthquake Hazards 

Program. Page updated February 13, 2015. Available at 

<http://earthquake.usgs.gov/hazards/qfaults> (accessed 6 February 2016).

[USGS] U.S. Geological Survey. 2015c. 2010–2011 Minerals Yearbook, Missouri [Advance 

Release]. Reston, VA: U.S. Department of the Interior, U.S. Geological Survey. April 2015. 

Available at <http://minerals.usgs.gov/minerals/pubs/state/> (accessed 6 February 2016).

[USGS] U.S. Geological Survey. 2015d. “Missouri Earthquake History.” U.S. Department of 

the Interior, U.S. Geological Survey, Earthquake Hazards Program. Page updated 

January 14, 2005. Available at 

<http://earthquake.usgs.gov/earthquakes/states/missouri/history.php> (accessed 

6 February 2016).
References

7-27

[USGS] U.S. Geological Survey. 2015e. Land Cover Trends Project, Land Cover Trends. Last 

modified October 28, 2015. Available at <http://landcovertrends.usgs.gov/map.html> (accessed 

12 April 2016).

[USGS] U.S. Geological Survey. 2016a. “Search Earthquake Archive.” [Radius search 

parameters: center latitude 38.900516 N, center longitude -92.277174 W, and outside radius 

322 km; National Earthquake Information Center PDE catalog]. U.S. Department of the Interior, 

U.S. Geological Survey, Earthquake Hazards Program. Available at 

<http://earthquake.usgs.gov/earthquakes/search/> (accessed 24 February 2016).

[USGS] U.S. Geological Survey. 2016b. “Water Use Data for Missouri.” [Search Results, 

2010, Boone County, National Water Information System: Web Interface.] Page updated 

March 4, 2016. Available at <http://waterdata.usgs.gov/mo/nwis/water_use/> (accessed 

4 March 2016).

[USGS] U.S. Geological Survey. 2016c. “Search Earthquake Archive.” [Radius search 

parameters: center latitude 38.93127912 N, center longitude -92.34190095 W, and outside 

radius 322 km; National Earthquake Information Center PDE catalog]. U.S. Department of the 

Interior, U.S. Geological Survey, Earthquake Hazards Program. Available at 

<http://earthquake.usgs.gov/earthquakes/search/> (accessed 24 February 2016) 

[WCS] Waste Control Specialist. 2016. Waste Control Specialist, Disposal Capabilities. 

Available at <http://www.wcstexas.com/facilities/site-capabilities> (accessed 20 April 2016).

White House. 2012. Fact Sheet: Encouraging Reliable Supplies of Molybdenum-99 Produced 

without Highly Enriched Uranium. Office of the Press Secretary. June 7, 2012. Available at 

<http://www.whitehouse.gov/the-press-office/2012/06/07/fact-sheet-encouraging-reliablesupplies-molybdenum-99-produced-without-> (accessed 27 April 2016).

Wicks C, Noltie DB, Peterson EW, and Dogwiler T. 2010. Disturbances in the Habitat of 

Macrocotyla glandulosa (Kenk). Ecohydrology 3(1)116–125.

Wilson T. 2012. Water-Quality Assessment of the Cambrian-Ordovician Aquifer System in the 

Northern Midwest, United States. Reston, VA: U.S. Department of the Interior, U.S. Geological 

Survey, National Water-Quality Assessment Program. Scientific Investigations 

Report 2011–5229. Available at < http://pubs.usgs.gov/sir/2011/5229/> (accessed 

6 February 2016).

Wu S, Mickley LJ, Leibensperger EM, Jacob DJ, Rind D, Streets DG. 2008. Effects of

2000–2050 global change on ozone air quality in the United States. Journal of Geophysical 

Research, Volume 113.

8-1

8.0 LIST OF PREPARERS

Members of the U.S. Nuclear Regulatory Commission’s (NRC’s) Office of Nuclear Reactor 

Regulation (NRR) prepared this environmental impact statement. Idoneous, Inc. provided 

technical editing support. Table 8–1 identifies each contributor’s name, affiliation, 

education/experience, and function or expertise.

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 Jr.

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, and management 

oversight

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 and waste management

(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

Michael Balazik

NRC/NRR

B.S., Mechanical Engineering;

27 years combined nuclear industry

and government experience including

13 years non-power reactor operation

Safety project manager

Susan Anastasi

Idoneous

Technical editing
9-1

9.0 DISTRIBUTION LIST OF AGENCIES, ORGANIZATIONS, AND 

PERSONS TO WHOM COPIES OF THIS ENVIRONMENTAL 

IMPACT STATEMENT ARE SENT

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

Tahlequah, OK 74465

John A. Barrett, Jr.

Chairman 

Citizen Potawatomi Nation 

1601 South Gordon Cooper Drive 

Shawnee, OK 74801

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

Jonathan Garoutte 

Chief

Bureau of Environmental Epidemiology

Missouri Department of Health and Senior Services 

912 Wildwood 

P.O. Box 570 

Jefferson City, Missouri 65102
Distribution List of Agencies, Organizations, and Persons

9-2

Name and Title Affiliation and Address

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

Douglas G. Lankford, 

Chief

Miami Tribe of Oklahoma 

P.O. Box 1326 

202 South Eight Tribes Trail 

Miami, OK 74355

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
Distribution List of Agencies, Organizations, and Persons

9-3

Name and Title Affiliation and Address

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

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

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
Distribution List of Agencies, Organizations, and Persons

9-4

Name and Title Affiliation and Address

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, xxi, 4-41, 4-42, 4-45, 4-46, 

4-87, 4-88, 4-93, 5-31, 5-52, 5-67, 5-81, 

5-86, 5-87, 5-88, 6-4, 6-9, A-2, A-3

Advisory Council on Historic 

Preservation (ACHP) .......xxiii, 1-7, 3-47, 

4-24, 4-25, B-4, C-3, C-7, D-3, D-4, D-7

agricultural land. 2-22, 3-37, 3-39, 3-40, 4-

2, 4-3, 4-5, 4-21, 4-27, 4-72, 4-80, 5-41, 

5-48, 5-57, 5-70, 5-84, 6-1, 6-5, 6-10

alternatives....iii, xxi, xxii, 1-3, 5-1, 5-2, 5-3, 

5-7, 5-54, 5-56, 5-74, 5-75, 5-76, 5-77, 

5-78, 5-88, 5-89, 6-1, 6-4, 6-9, 6-11, 8-2, 

A-1, A-4, A-5, B-2, D-2

American Medical Isotopes Production 

Act ..................... 1-3, 2-6, 5-80, 7-5, A-38

B

best management practice(s) (BMPs).4-7, 

4-11, 4-13, 4-15, 4-16, 4-18, 4-21, 4-22, 

4-23, 4-75, 4-78, 5-16, 5-20, 5-22, 5-23, 

5-24, 5-43, 5-45, 5-46, 5-60, 5-62, 5-63, 

5-64, 5-74, 5-76, 5-77, 5-78, 5-84, 6-2, 

6-6, 6-7

bird ...3-45, 4-21, 4-22, 4-23, 5-23, 5-24, 5-

65, 5-79, 6-2, 6-7

C

chemical ..2-10, 2-11, 2-13, 2-17, 2-21, 3-5, 

3-29, 3-60, 3-64, 3-65, 4-17, 4-18, 4-20, 

4-22, 4-23, 4-31, 4-32, 4-35, 4-37, 4-39, 

4-41, 4-42, 4-45, 4-46, 4-47, 4-48, 4-49, 

4-58, 4-62, 4-65, 4-73, 4-84, 4-85, 4-87, 

4-88, 4-93, 5-21, 5-26, 5-27, 5-28, 5-31, 

5-50, 5-51, 5-52, 5-53, 5-55, 5-57, 5-58, 

5-66, 5-67, 5-68, 5-69, 5-70, 5-80, 5-81, 

5-82, 5-86, 6-4, 6-7, 6-9, A-37, B-6

City of Columbia ..... xv, xvii, 3-1, 3-2, 3-17, 

3-18, 3-31, 3-32, 3-35, 3-52, 3-53, 3-54, 

3-55, 3-56, 3-57, 3-58, 3-59, 3-62, 3-65, 

3-66, 3-67, 4-11, 4-14, 4-15, 4-16, 4-17, 

4-18, 4-20, 4-27, 4-28, 4-29, 4-30, 4-39, 

4-51, 4-52, 4-53, 4-69, 4-72, 4-73, 4-78, 

4-79, 4-82, 4-86, 4-92, 5-8, 5-16, 5-17, 

5-19, 5-20, 5-21, 5-26, 5-28, 5-32, 5-35, 

5-39, 5-40, 5-41, 5-42, 5-44, 5-45, 5-46, 

5-47, 5-49, 5-51, 5-60, 5-61, 5-62, 5-67, 

5-74, 5-75, 5-76, 5-78, 5-84, 6-6, 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-14

Columbia, Missouri.....iii, xv, xix, xx, 1-1, 

1-2, 1-4, 2-1, 2-7, 2-18, 2-20, 3-1, 3-12, 

3-34, 3-47, 3-67, 4-60, 4-64, 4-73, 5-3, 

5-7, 5-51, 5-67, 5-80, 5-89, 6-1, 6-4, 7-5, 

7-6, 7-17, 7-25, A-1, A-5, A-7, A-12

Council on Environmental Quality 

(CEQ)....xxiii, 1-3, 1-6, 4-1, 4-50, 5-1, 

5-54, 5-82, 5-83, 7-4, A-3

critical habitat......3-43, 4-24, B-5, D-1, D-2

D

demographic............ 3-50, 3-52, 4-51, 7-16

discharges ..... 2-18, 3-27, 3-29, 3-31, 3-32, 

3-40, 4-15, 4-16, 4-17, 4-18, 4-36, 4-76, 

4-78, 5-20, 5-44, 5-45, 5-46, 5-62, 5-76, 

A-9

dose .......xxvii, 2-16, 3-62, 3-63, 3-64, 3-68, 

3-69, 3-70, 3-71, 3-72, 3-73, 3-74, 4-30, 

4-32, 4-33, 4-34, 4-35, 4-43, 4-44, 4-55, 

4-58, 4-61, 4-64, 4-65, 4-83, 4-84, 4-87, 

5-26, 5-27, 5-31, 5-37, 5-50, 5-52, 5-68, 

5-69, 5-80, 5-81, 5-82, 5-86, 6-3, 6-7, A-3, 

A-8, B-2, B-4

E

education.......... 2-19, 3-50, 7-16, 7-19, 8-1

emissions ... 3-14, 3-15, 3-62, 4-4, 4-5, 4-6, 

4-7, 4-8, 4-9, 4-10, 4-35, 4-36, 4-55, 4-56, 

4-57, 4-58, 4-59, 4-60, 4-61, 4-63, 4-64, 

4-65, 4-71, 4-73, 4-81, 4-90, 5-10, 5-11, 

5-12, 5-13, 5-37, 5-41, 5-42, 5-51, 5-54, 

5-57, 5-58, 5-59, 5-69, 5-70, 5-71, 5-72, 

5-73, 5-80, 5-82, 5-84, 5-86, 6-2, 6-4, 6-5, 

6-6, 6-10, 7-9, A-3, A-4, A-6, B-3

employment... 3-54, 3-55, 4-27, 4-28, 4-29, 

4-30, 4-82, 4-89, 4-92, 5-5, 5-49, 5-53, 

5-66, 5-79, 6-10, 7-1, A-11, A-12

endangered species. 1-7, 3-44, 5-23, 7-11, 

B-1, D-7
Index

10-2

Endangered Species Act (ESA)...xxiv, 1-7, 

3-42, 3-43, 3-45, 4-23, 7-3, 7-9, B-5, 

B-14, C-5, C-6, D-1, D-2, D-3, D-7

Environmental Report (ER) ...... iii, xix, xxii, 

xxiv, 1-1, 1-4, 2-5, 2-14, 3-1, 3-20, 3-21, 

3-22, 3-36, 3-43, 4-11, 4-33, 4-66, 5-2, 5-

22, 6-5, 6-11, 7-22, 7-23, 7-24, B-14

erosion...... 3-5, 3-19, 3-33, 4-6, 4-11, 4-13, 

4-15, 4-18, 4-21, 4-22, 4-74, 4-75, 4-77, 

4-78, 5-16, 5-17, 5-20, 5-23, 5-24, 5-42, 

5-43, 5-45, 5-60, 5-61, 5-62, 5-74, 5-75, 

5-76, 5-84, 6-2, 6-6, 6-11, B-8

essential fish habitat (EFH) .......3-46, 4-24

F

farmland of statewide importance .......3-5

fission.....xxii, 1-2, 2-10, 2-11, 2-14, 2-15, 

5-1, 5-55, 5-56, 5-66, 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, 5-82, 5-87, 5-89, 6-4, 

A-12

fugitive dust ...... 4-5, 4-9, 4-11, 4-19, 5-10, 

5-11, 5-58, 5-71, 5-72, 6-5

G

greenhouse gas .. xxiv, 3-15, 4-6, 5-11, A-3

H

habitat...xxi, 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, 4-72, 4-77, 4-80, 4-81, 

4-91, 5-18, 5-22, 5-23, 5-24, 5-41, 5-45, 

5-48, 5-65, 5-79, 6-2, 6-7, 6-10, 7-19, B-5, 

D-1, D-2, D-3

hazardous waste.....2-17, 2-19, 2-21, 3-65, 

4-38, 4-39, 4-86, 5-4, 5-28, 5-67, 6-10, 

B-5, B-10, B-11

hot cell .....2-7, 2-11, 2-14, 2-15, 2-17, 4-12, 

4-32, 4-35, 4-44, 5-55, 5-57, 5-69

I

iodine-131..........1-3, 3-62, 4-33, 5-55, 5-69

irradiation ... 1-6, 2-6, 2-7, 2-10, 2-11, 2-20, 

3-67, 4-40, 4-55, 4-56, 4-57, 4-58, 4-59, 

4-60, 4-61, 4-62, 4-63, 4-64, 4-65, 4-66, 

5-2, 5-3, 5-4, 5-7, 5-30, 5-55, 5-69, 5-70, 

5-81

J

jobs....3-2, 4-28, 4-29, 4-30, 4-58, 4-62, 

4-72, 5-5, 5-84, 6-8, A-10, A-11

L

low-enriched uranium......xx, 1-3, 1-6, 2-6, 

4-7, 5-7, A-12

low-level radioactive waste ..... 3-69, 3-72, 

4-37, 4-58, 4-62, 4-65, 4-85, 4-86, 5-67, 

5-80, 6-8, 6-10

M

Magnuson–Stevens Fishery 

Conservation and Management Act 

(MSA)..... xxi, 3-46, 4-24, 7-13, B-5, B-14, 

D-3, D-8

mineral resources ...... 3-50, 4-2, 4-75, 5-9, 

5-43

Missouri Department of Administration

3-52

Missouri Department of Conservation.....

1-8, 3-4, 3-41, 5-22, 6-9, 7-14, 7-18, 7-21, 

9-1, 9-4, B-7, C-2

Missouri Department of Natural 

Resources. ....... xxv, 1-8, 3-4, 4-11, 4-69, 

5-18, 5-40, 7-7, 7-11, 7-14, 7-15, 7-16, 

9-3, A-2, A-4, B-6, C-2, C-3, C-6, C-7, 

D-4, D-6, D-7

mitigation....... 4-13, 4-17, 4-20, 4-43, 4-73, 

5-27, 5-42, 6-5, 6-9, 7-17, 7-21

mixed waste......2-16, 4-37, 4-86, 6-8, B-11

molybdenum-99 (Mo-99) ..xx, 1-1, 1-2, 1-3, 

1-6, 2-6, 2-7, 2-10, 2-11, 2-12, 2-15, 2-16, 

2-20, 2-21, 4-1, 4-7, 4-32, 4-33, 4-34, 

4-44, 4-56, 5-2, 5-4, 5-54, 5-55, 5-56, 

5-66, 5-67, 5-68, 5-69, 5-70, 5-80, 5-83, 

5-86, 7-12, 7-23, 7-24, 7-27, A-9, A-12

N

National Environmental Policy Act 

(NEPA)... ...... xix, xx, xxvi, 1-1, 1-6, 4-26, 

4-50, 5-1, 5-7, 5-54, 5-82, 5-83, 6-1, 6-5, 

6-11, 7-4, 7-18, 8-1, 8-2, 9-4, A-9, A-38, 

B-2, B-4, B-14, D-1, D-3, D-8

National Marine Fisheries Service 

(NMFS)....3-42, 3-43, 3-46, 4-24, 7-19, 

B-5, D-1, D-2, D-3, D-7

National Nuclear Security Administration 

(NNSA).... xxvi, 1-3, 2-6, 5-54, 5-56, 5-88, 

7-12, 7-19

National Pollutant Discharge Elimination 

System (NPDES) .. xxvi, 3-30, 3-31, 3-32, 

4-15, 4-16, 4-17, 4-18, 4-19, 4-20, 4-77, 

4-78, 5-18, 5-20, 5-21, 5-22, 5-45, 5-46, 
Index

10-3

5-62, 5-64, 5-76, 5-78, 7-2, 7-10, B-1, 

B-6, B-14

National Register of Historic Places 

(NRHP)..xxvi, 3-51, 3-67, 3-71, 4-24, 

4-27, 5-24, 5-25, 5-26, 7-22, B-4, D-3

no-action alternative...iii, xxi, xxii, 5-1, 5-2, 

5-86, 5-87, 5-89, 6-4, A-4, A-6

nonattainment ............................3-13, 3-14

O

Occupational Safety and Health 

Administration (OSHA)...xxvi, 3-17, 

3-65, 4-31, 4-34, 4-35, 4-36, 4-37, 4-84, 

5-50, 5-66, 5-80, 5-85, 6-3, 6-8, 7-23, B-4

P

personal protective equipment...2-15, 

2-17, 4-31, 6-8

population...3-2, 3-48, 3-49, 3-52, 3-53, 

3-54, 3-58, 3-59, 4-30, 4-33, 4-47, 4-50, 

4-51, 4-52, 4-53, 4-54, 4-60, 4-63, 4-64, 

4-73, 4-74, 4-78, 4-79, 4-81, 4-82, 4-86, 

4-89, 4-90, 4-92, 5-31, 5-32, 5-34, 5-35, 

5-36, 5-42, 5-46, 5-47, 5-49, 5-53, 7-16, 

7-18, B-3, B-8

population centers................................3-2

prime farmland.... 3-1, 3-5, 3-25, 4-75, 5-8, 

5-15, 5-43, A-5, B-5

production facility iii, xix, xx, xxvi, 1-1, 1-2, 

1-6, 2-1, 3-63, 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-2, 

C-1, D-1

public health.....2-6, 2-20, 3-12, 3-63, 5-66, 

5-80, 5-88, 6-10, A-8, B-1, B-3, B-4, B-9

public services........4-27, 4-82, 4-92, 5-49, 

5-66, 5-83, A-12

R

radioactive waste ......2-6, 2-11, 2-15, 2-16, 

2-17, 2-19, 2-20, 2-22, 3-62, 3-69, 3-72, 

4-31, 4-32, 4-33, 4-35, 4-37, 4-38, 4-58, 

4-62, 4-65, 4-85, 4-86, 5-28, 5-51, 5-57, 

5-67, 5-81, 6-8, 8-2

radioisotope .. iii, xix, xx, xxvi, 1-1, 1-2, 1-3, 

1-6, 2-1, 2-6, 2-9, 2-19, 2-21, 3-63, 4-1, 

4-7, 5-1, 5-2, 5-54, 5-56, 5-69, 5-70, 5-77, 

5-78, 5-83, 5-87, 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, 4-70, 4-76, 4-77, 4-79, 4-80, 4-81, 

4-91, 5-16, 5-18, 5-21, 5-23, 5-24, 5-44, 

5-45, 5-46, 5-47, 5-48, 5-62, 5-63, 5-65, 

5-76, 5-77, 5-79, 6-6, A-9, B-6, B-11

S

safety evaluation report (SER) . xxvi, 4-34, 

4-41, 4-45, 4-49, 4-67, 5-16, 5-31, 5-50, 

5-52, 5-53, 5-68, 5-82, 5-86, 6-4, A-8

schools ................................ 3-60, A-8, B-8

scoping .. xix, 1-4, 3-1, 4-26, 4-66, A-1, A-2, 

A-4, A-38

shielding...2-21, 4-10, 4-22, 4-32, 4-44, 

4-58, 4-61, 4-64, 6-7

soil.. 2-12, 2-13, 3-5, 3-18, 3-20, 3-21, 3-24, 

3-25, 3-26, 3-34, 3-37, 3-62, 3-63, 3-71, 

4-7, 4-11, 4-13, 4-14, 4-15, 4-18, 4-19, 

4-21, 4-22, 4-74, 4-75, 4-77, 4-78, 4-80, 

4-84, 4-91, 5-16, 5-17, 5-20, 5-22, 5-23, 

5-24, 5-42, 5-43, 5-45, 5-48, 5-57, 5-60, 

5-61, 5-62, 5-63, 5-65, 5-74, 5-75, 5-76, 

5-78, 5-84, 6-2, 6-5, 6-6, 7-21, 7-22

solid waste..... 2-16, 2-17, 2-18, 2-20, 2-21, 

3-69, 4-36, 4-37, 4-38, 4-39, 4-86, 5-67, 

B-1, B-7

State Historic Preservation Office 

(SHPO).. xxvi, 3-47, 3-51, 4-25, 6-7, 7-15, 

9-3, A-4, A-5, A-7, C-3, C-6, C-7, D-4, 

D-6, D-7

stormwater..... 3-27, 3-31, 4-11, 4-12, 4-14, 

4-15, 4-16, 4-17, 4-18, 4-19, 4-20, 4-21, 

4-22, 4-23, 4-76, 4-78, 4-80, 5-16, 5-17, 

5-20, 5-21, 5-22, 5-23, 5-24, 5-44, 5-45, 

5-46, 5-48, 5-60, 5-62, 5-63, 5-64, 5-74, 

5-76, 5-77, 5-78, 5-84, 6-2, 6-6, 7-6, 7-13, 

7-16, A-9, B-6, B-8, B-9, B-11

T

tax......3-57, 3-58, 4-27, 4-28, 4-29, 4-30, 

4-82, 4-92, 5-5, 5-6, 5-7, 5-49, 5-83, 5-84, 

6-10, A-10, A-11, A-12

technetium-99m.................................... 1-1

traffic....... xxvii, 3-2, 3-17, 3-65, 3-66, 3-68, 

3-71, 3-73, 4-7, 4-8, 4-9, 4-10, 4-11, 4-14, 

4-39, 4-40, 4-41, 4-54, 4-55, 4-56, 4-57, 

4-59, 4-60, 4-62, 4-63, 4-66, 4-73, 4-74, 

4-89, 4-91, 4-93, 5-11, 5-12, 5-13, 5-29, 

5-30, 5-36, 5-37, 5-42, 5-52, 5-53, 5-59, 

5-67, 5-68, 5-69, 5-72, 5-73, 5-81, 5-82, 

5-85, 5-86, 6-3, 6-4, 6-6, 6-8, 6-9, 6-10, 

7-17, A-12

tritium....... 2-15, 3-62, 3-68, 4-32, 5-69, 6-7
Index

10-4

U

U.S. Department of Energy (DOE)......xxiii, 

1-8, 2-6, 2-7, 2-9, 2-20, 3-69, 4-47, 5-3, 

5-54, 5-56, 5-57, 5-58, 5-59, 5-60, 5-61, 

5-64, 5-66, 5-67, 5-68, 5-80, 7-5, 7-8, 7-9, 

9-2, C-2

U.S. Department of Transportation (DOT)

xxiv, 2-6, 2-11, 2-19, 2-20, 2-21, 4-33, 

4-34, 4-38, 5-66, 5-67, 5-80, 5-85, 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, 3-17, 

3-29, 3-31, 3-32, 3-60, 3-62, 3-64, 3-65, 

4-6, 4-8, 4-38, 4-39, 4-47, 4-48, 4-60, 

4-64, 4-70, 4-73, 4-77, 4-84, 4-85, 4-88, 

5-11, 5-45, 5-50, 5-51, 5-53, 5-66, 5-80, 

7-2, 7-9, 7-10, 7-11, 7-15, 9-3, 9-4, A-2, 

A-4, A-5, B-1, B-3, B-5, B-6, B-9, B-14, 

C-2, C-6

U.S. Fish and Wildlife Service (FWS)

xxiv, 1-8, 3-42, 3-43, 3-45, 3-46, 4-23, 

4-24, 5-22, 5-23, 6-9, 7-4, 7-11, 7-12, 7-

20, 9-4, A-6, B-5, C-6, D-1, D-2, D-3, D-7, 

D-8

U.S. Highway 63 ........3-2, 3-17, 3-27, 3-29, 

3-40, 3-66, 3-67, 3-71, 4-9, 4-10, 4-11, 

4-39, 4-40, 4-41, 4-55, 4-72, 4-82, 4-89, 

5-28, 5-29, 5-59, 5-67, 5-69, 5-72, 5-73, 

5-81, 5-82, 5-85, 6-3, A-11

U.S. Nuclear Regulatory Commission 

(NRC)......................................... C-7, D-3

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, 3-62, 

3-63, 3-67, 3-71, 4-1, 4-7, 4-42, 5-1, 5-55, 

5-56, 5-69, 5-81, 5-83, 5-88, 6-11, A-4, 

A-5

utilization facility................................ 2-21

V

viewshed.....3-5, 3-11, 4-4, 4-5, 4-71, 4-72, 

5-9, 5-10, 5-41, 5-84, 6-1

W

wastewater....2-14, 2-18, 3-31, 3-32, 4-15, 

4-16, 4-17, 4-18, 4-20, 4-22, 4-23, 4-35, 

4-70, 4-77, 4-78, 4-87, 5-21, 5-24, 5-40, 

5-46, 5-64, 5-78, 8-2, B-9, B-13

wildlife... 3-29, 3-30, 3-37, 3-38, 3-39, 3-41, 

3-43, 4-21, 4-22, 4-23, 4-54, 4-72, 4-77, 

4-80, 5-18, 5-22, 5-23, 5-24, 5-36, 5-41, 

5-45, 5-48, 5-65, 5-79, 6-7, 6-9, 6-10, 7-3, 

B-5, B-6, B-7

workers ..... 2-4, 2-6, 2-15, 2-22, 3-17, 3-52, 

3-54, 3-55, 3-60, 3-64, 3-67, 3-69, 4-7, 

4-9, 4-27, 4-28, 4-29, 4-30, 4-31, 4-32, 

4-34, 4-35, 4-36, 4-38, 4-39, 4-40, 4-41, 

4-44, 4-45, 4-46, 4-49, 4-54, 4-56, 4-57, 

4-58, 4-59, 4-61, 4-62, 4-63, 4-64, 4-66, 

4-83, 4-84, 4-85, 4-86, 4-89, 5-11, 5-12, 

5-26, 5-27, 5-28, 5-29, 5-30, 5-36, 5-49, 

5-50, 5-53, 5-57, 5-66, 5-67, 5-68, 5-70, 

5-79, 5-80, 5-81, 6-3, 6-7, A-10, B-1, B-2
COMMENTS RECEIVED ON THE NORTHWEST MEDICAL ISOTOPES, 

LLC, RADIOISOTOPE PRODUCTION FACILITY ENVIRONMENTAL 

REVIEW

A-1

A. COMMENTS RECEIVED ON THE NORTHWEST MEDICAL 

ISOTOPES, LLC, RADIOISOTOPE PRODUCTION FACILITY 

ENVIRONMENTAL REVIEW

A.1 Comments Received During the Scoping Period

The scoping process for the environmental review of the construction permit application for the 

Northwest Medical Isotopes, LLC (NWMI), radioisotope production facility (NWMI facility) began 

on November 18, 2015, with the publication of the U.S. Nuclear Regulatory Commission’s 

(NRC’s) Notice of Intent to conduct scoping in the Federal Register (80 FR 72115). The 

scoping process included a public meeting held in Columbia, Missouri, on December 8, 2015. 

Approximately 43 people attended the meeting. After the NRC presented its prepared 

statements on the construction permit review process, the meeting was open for public 

comments. Attendees provided oral statements that were recorded and transcribed by a 

certified court reporter. A summary and transcript of the scoping meeting are available through 

the NRC’s Agencywide Documents Access and Management System (ADAMS). The ADAMS 

Public Electronic Reading Room is accessible at http://www.nrc.gov/reading-rm/adams.html. 

The scoping meeting summary and meeting transcript (NRC 2016a) can be found at ADAMS 

No. ML15356A096. In addition to comments that the NRC received during the public meeting, 

the agency also received comments electronically and through the mail.

Each commenter was given a unique identifier to allow every comment to be traced back to its 

author. Table A–1 identifies the individuals who provided comments and an ADAMS No. to 

identify the source document of the comments.

Specific comments were categorized and consolidated by topic. Comments with similar specific 

objectives were combined to capture the common essential issues raised by commenters. 

Comments have been grouped into the following general categories:

• Specific comments that address environmental issues within the purview of the NRC 

environmental regulations related to a construction permit. These comments 

address issues related to the construction, operations, and decommissioning of the 

NWMI facility. The comments also address alternatives to the proposed action and 

related Federal actions.

• General comments in support of, or opposed to, the NWMI facility or comments 

regarding the construction permit process, the NRC’s regulations, and the regulatory 

process.

• Comments that address issues that do not fall within, or are specifically excluded 

from, the purview of NRC environmental regulations related to the construction 

permit process. These comments may address issues such as emergency 

preparedness, security, and safety.
Appendix A

A-2

Individuals Providing Comments During the Scoping Comment Period

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

Comments that are outside the scope of the NWMI facility environmental review are not 

included here but appear in and are responded to in the Scoping Summary Report (ADAMS 

No. ML16056A628). To maintain consistency with the Scoping Summary Report, Appendix A 

retains the unique identifiers used in that report for each comment. 

The NRC staff placed comments received during the scoping comment period applicable to this 

environmental review into categories based on topics in the environmental impact statement 

(EIS). These categories are listed in 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 

The following pages contain the comments, identified by the commenter’s identification and 

comment number, and the NRC staff’s response. Comments are presented in the same order 

as listed in Table A–2.

Accidents

Comments:

12-03: The increased likelihood of a transportation accident involving molybdenum- 99 [...] can 

increase the risk of harm to sensitive populations.

Response:

This comment recommends that the NRC consider the increased likelihood of transportation 

accidents. Section 4.8.2.1 of the EIS discusses the impacts to the public from highway 

transportation of radioactive material associated with the proposed NWMI facility. As discussed 

in Section 4.8.2.1, when transporting radioactive material, both NWMI and commercial carriers 

used by NWMI must comply with applicable U.S. Department of Transportation (DOT)

regulations and NRC packaging requirements for radioactive material in 10 CFR Part 71. The 

annual dose to a maximally exposed individual from highway transportation of radioactive 

material associated with the proposed NWMI facility is small relative to the NRC’s 100 mrem 

annual public dose limit in 10 CFR 20.1301. The NRC’s public dose limit is set at a level that 

helps to ensure that any risk to members of the public, including sensitive populations, from 

radiation exposure that occurs due to the operation of a nuclear facility is no greater than the 

risk from any other hazard to which individuals are routinely exposed (ICRP 1987; 

56 FR 23360). In addition, as noted in Section 4.8.2.1, the Commission has determined that the 

radiological and nonradiological environmental impacts of normal (incident-free) transportation 

of radioactive materials done in accordance with NRC and DOT regulations, and the risks and 

consequences of accidents involving radioactive material shipments in packages for which the 

NRC has issued design approvals meeting the performance standards of 10 CFR Part 71, are 

small (49 FR 9375).

Air Quality

Comment:

12-20: The document should also consider greenhouse gas emissions and how the preferred 

alternative might improve or degrade air quality based on the construction of the facility and how 

this facility could improve transportation GHG emissions based on reduction of imports from 

Canada or overseas. Information on how to comply with the President and CEQ can be found 

here: https://www.whitehouse.gov/administration/eop/ceq/initiatives/nepa/ghgguidance.

Response:

This comment recommends that the EIS assess the greenhouse gas emission (GHG) and air 

quality impacts of the proposed NWMI facility. Section 4.2 of the EIS addresses the impacts on 
Appendix A

A-4

air quality that result from construction, operations, and decommissioning of the proposed 

NWMI facility. Section 4.2 quantifies annual GHG emissions resulting from construction, 

operations, and decommissioning of the proposed NWMI facility at the Discovery Ridge site. 

Section 5.4.1 of the EIS compares the environmental impacts of the proposed NWMI facility with 

the environmental impacts associated with using an alternative site or alternative technologies.

Alternatives

Comments:

12-01: Although the proposed action is only the licensing of a new low enriched uranium

Medical Isotope [facility], EPA strongly encourages NRC to consider all the significant 

environmental impacts that would be caused by licensing this facility, both the beneficial and 

harmful, to human health and the environment. For example, alternatives one might consider 

are: 1) no-action, 2) licensing of this facility, or 3) denial of this facility to license with approval 

for licensing a different facility at another location.

Response:

This comment suggests that the NRC consider all the significant environmental impacts as a 

result of the no-action alternative (i.e., denial of the construction permit application), the 

proposed action, and an alternative site and facility. Chapter 4 of the EIS evaluates the 

potential environmental impacts from the proposed action. Chapter 5 of the EIS evaluates the 

potential impacts from the no-action alternative, an alternative site, and two alternative 

technologies. Section 5.4.1 of the EIS compares the environmental impacts of the proposed 

NWMI facility with those that would be associated with using an alternative site or alternative 

technologies. Specifically, Table 5–12 provides a tabular comparison of the potential 

environmental impacts of constructing, operating, and decommissioning the proposed NWMI 

facility at the Discovery Ridge site with the alternative site and the no-action alternative. 

Table 5–13 provides a tabular comparison of the potential environmental impacts of 

constructing, operating, and decommissioning the proposed NWMI facility at the Discovery 

Ridge site with the potential environmental impacts of using alternative technologies.

Coordination

Comment:

12-12: Has coordination between Missouri Department of Natural Resources and NRC 

occurred?

Response:

This comment asks whether coordination has occurred between the NRC and the Missouri 

Department of Natural Resources (MDNR). In a letter dated November 19, 2015, the NRC 

invited the MDNR’s Division of Environmental Quality, Chief of Policy, and State Historic 

Preservation Office to participate in the scoping process for the environmental review related to 

the proposed NWMI facility (NRC 2015b). On December 9, 2015, MDNR’s State Historic 

Preservation Officer responded to the NRC (see response to Comment 12-15 below). However, 

MDNR’s Division of Environmental Quality and Chief of Policy did not submit comments to the 

NRC during the scoping period. Section 1.7 of the EIS identifies agencies contacted during the 

formal consultation processes and Appendix D discusses agencies with which the NRC 

consulted. The MDNR was on distribution for the NRC’s draft EIS and was invited to the NRC’s 

public meeting discussing the draft EIS.

Comment:

12-14: Will there need to be coordination for farmland conversion?
Appendix A

A-5

Response:

This comment asks whether the NRC will need to coordinate with the U.S. Department of 

Agriculture regarding the conversion of prime farmland to nonagricultural uses. As discussed in 

Section 3.1.1.1 of the EIS, the proposed site (Discovery Ridge) and alternative site (University 

of Missouri Research Reactor) do not contain prime farmland or other important farmland soils 

as defined in the Farmland Protection Policy Act of 1981 (7 U.S.C. 4201 et seq.) and 

implementing regulations (7 CFR Parts 657 and 658). Given that the Discovery Ridge site is 

already committed to use as a research, development, and office park, the site is not subject to 

the Farmland Protection Policy Act (7 CFR 658.2). Section 3.1.1 of the EIS describes land use 

on and around the proposed site in Columbia, Missouri, and Section 4.1.1 addresses the 

impacts to land use from construction, operations, and decommissioning of the proposed NWMI 

facility there. Section 5.2.2.1 of the EIS describes land use on and around the alternative site in 

Columbia, Missouri and the impacts to land use from construction, operations, and 

decommissioning of the proposed NWMI facility there.

12-15: Has coordination occurred with the Missouri State Historic Preservation Officer?

Response:

This comment asks whether coordination has occurred between the NRC and the Missouri 

State Historic Preservation Officer (SHPO). Section 4.6.3 of the EIS explains that the NRC 

initiated NHPA Section 106 consultation with the Missouri SHPO on November 19, 2015. A 

Cultural Resource Assessment, Section 106 Review, was conducted by the SHPO for the 

proposed Northwest Medical Isotopes, LLC Radioisotope Production Facility, in Columbia, 

Missouri (Lot 15 at Discovery Ridge). The assessment signed by Toni M. Prawl, Ph.D., Deputy 

State Historic Preservation Officer, on December 9, 2015, states that, “Adequate documentation 

has been provided (26 CFR Section 800.11). There will be ‘no historic properties affected’ by 

the current project.” The assessment also states, the Missouri SHPO has “no objection to the 

initiation of project activities.” The Missouri SHPO was on distribution for the NRC’s draft EIS 

and was invited to the NRC’s public meeting discussing the draft EIS. Following its review of 

the draft EIS, the Missouri SHPO issued an assessment on December 23, 2016 that confirmed 

its earlier findings.

Cost Benefit Analysis

Comment:

12-02: Although the proposed action is only the licensing of a new low enriched uranium

Medical Isotope [facility], EPA strongly encourages NRC to consider all the significant 

environmental impacts that would be caused by licensing this facility, both the beneficial and 

harmful, to human health and the environment. [...] The direct effects of such facilities can be 

both beneficial and harmful and we encourage NRC to expand the discussion in this area.

Comment:

12-05: In contrast, if such medical supplies have a pronounced effect on human health and are 

in short supply or are not otherwise readily available, then such considerations should also be 

taken into account. EPA recommends objectively analyzing both positive and negative aspects 

so that the decision maker can easily choose the preferred alternative.

Response:

The above comments suggest that the NRC staff consider the costs and benefits of the 

proposed action and alternatives. Section 5.4 of the EIS evaluates the costs and benefits for 

the proposed action and compares the environmental impacts of the proposed action, no-action 
Appendix A

A-6

alternative, alternative sites, and two alternative technologies. Specifically, Table 5–12 provides 

a tabular comparison of the potential environmental impacts of constructing, operating, and 

decommissioning the proposed NWMI facility at the Discovery Ridge site with the alternative 

site and the no-action alternative. Table 5–13 provides a tabular comparison of the potential 

environmental impacts of constructing, operating, and decommissioning the proposed NWMI 

facility at the Discovery Ridge site with the potential environmental impacts of using alternative 

technologies.

Cumulative Impacts

Comment:

12-06: Cumulative impact discussions may also include transport of hazardous materials, 

storage of materials, national health benefits, induced development due to job creation, and 

reduction of GHGs due to proximity of the new facility.

Response:

The comment recommends that the EIS include a cumulative impact discussion that considers 

transportation, waste management, human health, socioeconomics, and GHG emissions. 

Section 4.14 of the EIS considers the potential cumulative impacts of the construction, 

operations, and decommissioning of the proposed NWMI facility when overlaid or added to 

temporary or permanent effects associated with other past, present, and reasonably 

foreseeable future actions on the affected resource areas. Table 4–12 of the EIS summarizes 

the cumulative impacts for all resource areas. The cumulative impacts for (1) transportation are 

SMALL; (2) Human Health are SMALL; (3) socioeconomics are SMALL; (4) air quality are 

SMALL to MODERATE; and (5) waste management are SMALL.

Ecological Resources

Comment:

12-07: When developing Threatened and Endangered species, one might consider not only 

animal species, but also plant species if construction will occur on undisturbed land.

Response:

This comment recommends that the NRC consider the potential impacts to threatened and 

endangered animal and plant species from construction of the proposed NWMI facility. 

Section 3.5.4 of the EIS describes the Federally listed species (both plants and animals) that 

have the potential to exist within the action area. As discussed in Section 3.5.4, the NRC staff 

concludes that Federally listed, proposed, or candidate species (both plants and animals) are 

unlikely to occur within the action area. In Section 4.5.4 of the EIS, the NRC staff concludes 

that there would be no effect on Federally listed species or habitats.

Environmental Justice

Comments:

12-11: Would EJ communities be disproportionately affected by the proposed locations?

Response:

The comment asks whether the proposed action would disproportionately affect Environmental 

Justice (EJ) communities. In the EIS, the NRC staff concludes that it is not likely that the 

construction, operations, and decommissioning of the proposed NWMI facility would have 

disproportionately high and adverse human health and environmental effects on minority and 

low-income populations if located at the Discovery Ridge site (Section 4.12) or at the University 

of Missouri Research Reactor site (Section 5.2.2.12).
Appendix A

A-7

Historical and Cultural Resources

Comments:

06-01: In reference to the above-mentioned project, the Miami Tribe is not currently aware of 

existing documentation directly linking a specific Miami cultural or historic site to the project site. 

However, as this site is within the extended homelands of the Miami Tribe, should any human 

remains or Native American cultural items falling under the Native American Graves Protection 

and Repatriation Act (NAGPRA) or archaeological evidence be discovered during any phase of 

this project, the Miami Tribe requests immediate consultation with the entity of jurisdiction for the 

location of discovery. The Miami Tribe offers no objection to the proposed project at this time. 

However, should human remains and/or cultural objects be discovered, regardless of initial 

determination as to site dating or cultural affiliation, please contact me [...] to initiate 

consultation.

01-01: Thank you for contacting us as a potential consulting party on this project. The UKB 

[United Keetoowah Band] defers consultation on this project to federally recognized tribes with 

more of a historic interest in this site.

02-01: This project is outside of the current area of interest for the Quapaw Tribe [of 

Oklahoma], therefore, the Quapaw Tribe does not desire to comment on this project at this time.

07-01: The Pawnee Nation Office of Historic Preservation has received the information and 

materials requested for our Section 106 Review and Consultation. Consultation with the 

Pawnee Nation is required by Section 106 of the National Historic Preservation Act of 1966 

(NHPA), and 36 CFR Part 800. Given the information provided, you are hereby notified that the 

proposal project location should have no potential to adversely affect any known Archaeological, 

Historical, or Sacred Pawnee sites. Therefore, in accordance with 36 CFR 800.4(d)(1), you may 

proceed with the proposed project. However, please be advised that undiscovered properties 

may be encountered and must be immediately reported to us under both the NHPA and 

NAGPRA regulations.

11-01: The [Missouri] State Historic Preservation Office has reviewed the information submitted 

on the above referenced project. Based on this review, we have made the following 

determination: Adequate documentation has been provided (36 CFR Section 800.11). There 

will be "no historic properties affected" by the current project. For the above checked reason, 

the State Historic Preservation Office has no objection to the initiation of project activities. 

PLEASE BE ADVISED THAT, IF THE CURRENT PROJECT AREA OR SCOPE OF WORK 

ARE CHANGED, A BORROW AREA IS INCLUDED IN THE PROJECT, OR CULTURAL 

MATERIALS ARE ENCOUNTERED DURING CONSTRUCTION, APPROPRIATE 

INFORMATION MUST BE PROVIDED TO THIS OFFICE FOR FURTHER REVIEW AND 

COMMENT. Please retain this documentation as evidence of compliance with Section 106 of 

the National Historic Preservation Act, as amended.

Response:

The above commenters generally indicate there are no known cultural or historic resources that 

could be affected by the proposed action, but express concerns that they be contacted 

consistent with the NHPA Section 106 process if such resources are identified in the future. 

Section 3.6 of the EIS describes the archaeological history of Columbia, Missouri, and Boone 

County and identifies historic and cultural resources that could potentially be found in the vicinity 

of the proposed NWMI facility at the Discovery Ridge Research Park. Section 4.6 of the EIS 

concludes that construction, operations and decommissioning of the proposed NWMI facility 

would not impact any known historic and cultural resources at the Discovery Ridge Research 

Park site.
Appendix A

A-8

Human Health

Comments:

12-09: What is the safe distance to the nearest residence?

Response:

The above comment recommends that the NRC consider impacts to an offsite member of the 

public. Section 3.8.1 identifies the location of the nearest residence, as well as the locations of 

sensitive receptors (schools, medical facilities, parks, recreational areas, religious institutions, 

and retirement communities within the 5-mi (8-km) region of influence) relative to the proposed 

Discovery Ridge site. The nearest residence is located 0.27 mi (435 m) from the proposed 

Discovery Ridge site. Section 4.8 addresses the human health impacts to members of the 

public from construction, operations, and decommissioning of the proposed NWMI facility. 

Section 4.11 addresses the impacts to members of the public, including individuals located at 

the nearest residence, from potential accidents at the proposed NWMI facility. In Sections 4.8 

and 4.11, the NRC staff concluded that if the proposed facility is constructed, operated, and 

decommissioned in compliance with all applicable regulations, then the impacts to offsite 

members of the public (including those at the nearest residence) from both routine operation of 

the proposed facility and potential accidents at the proposed facility would be small. 

Comment:

12-18: Will the facility be required to conduct an annual environmental and public health

radiation dose assessment similar to commercial nuclear reactors?

Response:

The comment recommends that the EIS consider annual environmental monitoring and public 

dose assessment requirements for the proposed facility. Section 3.8.2 of the EIS discusses 

NRC’s radiation protection dose limits contained in 10 CFR Part 20. If licensed to operate, the 

licensee for the radioisotope production facility would need to perform environmental and public 

radiation dose assessments to show compliance with the annual radiation dose limits for 

individual members of the public. The NRC regulations at 10 CFR 20.1301 specify an annual 

maximum allowable dose of 100 mrem to a member of the public from exposure to radiation and 

radioactive material at a licensed facility. In addition, 10 CFR 20.1302 requires licensees to 

make or cause to be made, as appropriate, surveys of radiation levels in unrestricted and 

controlled areas (both within and outside the site boundary), and to measure annual average 

concentrations of radionuclides in effluent releases from the facility, as needed to demonstrate 

compliance with the annual dose limits for individual members of the public. The NRC 

regulations at 10 CFR 20.2203 require licensees to submit reports of incidents and occurrences 

involving radiation exposures to members of the public that exceed regulatory limits. 

Section 4.8.2.1 of the EIS discusses the applicant’s proposed radiological effluent and 

environmental monitoring programs. The applicant’s proposed radiological effluent and 

environmental monitoring programs will be evaluated in a separate safety evaluation report

related to the construction permit application based on the information in the NWMI preliminary 

safety analysis report.

Purpose and Need

Comment:

12-08: In reviewing the background on these type of facilities, it appears that ten letters of 

intent have been made recently, with one construction application already submitted in 

Wisconsin. If the facility in Wisconsin were to be built, would this facility and the others be 

necessary and viable?
Appendix A

A-9

Response:

This comment recommends that the environmental review consider whether construction of the 

proposed NWMI facility is necessary if another radioisotope production facility is constructed. 

Section 1.3 of the EIS describes the purpose and need for the proposed action. The purpose of 

the NRC’s Federal action is to evaluate NWMI’s proposal to construct a facility that would 

ultimately produce medical radioisotopes. This definition of purpose and need reflects the 

NRC’s recognition that, unless there are findings in the safety review required by the Atomic 

Energy Act of 1954, as amended, or findings in the environmental analysis under NEPA that 

would lead the NRC to reject a construction permit application, the agency does not have a role 

in decisions as to whether a particular medical radioisotope production facility should be 

constructed and operated. Section 1.3 of the EIS identifies the demand in the United States for 

molybdenum-99 (Mo-99) and production capacity of the proposed NWMI facility.

Water Resources

Comment:

12-04: [...]the possibility of groundwater contamination near private wells can increase the risk 

of harm to sensitive populations.

Response:

The comment recommends that the EIS assess the groundwater impacts from the proposed 

facility and consider the effects on sensitive populations. Section 3.4.2 of the EIS describes the 

groundwater resources at and around the proposed Discovery Ridge site. Section 3.4.2.2 of the 

EIS discusses water supply wells and other wells within a 1-mi (1.6-km) radius of the proposed 

Discovery Ridge site. Sections 4.4.1 and 4.4.2 of the EIS evaluate the impacts from 

construction, operations, and decommissioning of the proposed NWMI facility on surface water 

and groundwater quality and use, respectively. As discussed in Sections 4.4.1.2 and 4.4.2.2, 

the proposed facility is designed to have zero liquid discharge of radioactive or hazardous 

liquids; therefore, there would be no such liquid effluents released from the facility to the 

environment during operation. Facility discharges would be limited to sanitary effluent, which 

would be conveyed to the City of Columbia Sanitary Sewer Utility as discussed in 

Section 4.4.1.2. Further, 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. Consequently, because no radioactive or 

hazardous liquid effluent discharge would occur from the facility during normal operations, the 

impact on surface water or groundwater quality would be negligible or SMALL and no impact on 

human health would be expected.

Support for the NWMI Facility

Comments:

10-01: I am here to testify in support of Northwest Medical Isotopes, LLC’s proposed project. 

Because of our wide array of community assets, we believe that Boone County is an excellent 

location for the proposed facility. One of our community’s premier assets is the University of 

Missouri’s nuclear reactor. The physical proximity of the reactor, as well as its history of 

excellence in performance, combine to make this a perfect partnership between the University 

of Missouri and Northwest Medical Isotopes.

Through this partnership we will be -- which will produce 99-Mo, cancer patients throughout the 

United States will have more opportunities for a better outcome. The proposed location of the 

facility at University of Missouri’s Discovery Ridge Park will provide access to Mid-Missouri 
Appendix A

A-10

Regional Airport. This too is an enormous benefit to the project, since reducing the time 

between production of the drug and delivery to healthcare professionals will effectively increase 

the efficacy of the drug needed by the patients and doctors throughout the United States. 

Another asset that our community brings to the table is Boone County’s ability to utilize our 

economic development tool, as Chap -- known as Chapter 100 Bond. With this tool, in 

cooperation with our taxing entities, we can make this project successful. This is a 

community-wide partnership, which has the potential to grow ever stronger through the 

collaboration created by effectively utilizing our community assets, the University’s research 

reactor, Mid-Missouri Regional Airport, and our ability to utilize the economic tool Chapter 100 

Bond. Our community directly benefits from this partnership because this project will bring 

good-paying jobs and capital investment, and it creates the possibility of pharmaceutical 

companies joining the research hub of Discovery Ridge, with that enhanced tax base benefiting 

all citizens. Please accept this testimony made on behalf of the Boone County Commission in 

support of the Northwest Medical Isotopes, LLC facility location.

09-01: I appreciate the opportunity to testify before the NRC in support of the Northwest 

Medical Isotopes proposal. This is an important initiative for obviously several different reasons. 

One is that we have a highly-skilled workforce in Boone County and can easily support the 

80-plus jobs that will be required in the production of technetium.

Secondly, obviously for Boone County, the 1,600 workers that will be required to construct the 

building is very important to the economy here in Mid-Missouri and in the whole state of 

Missouri.

Second -- next, you know, I have -- in my former life I was a physician and have been on staff of 

both the University of Missouri Hospital and Boone Hospital; and I know how important, you 

know how important the use of radioisotopes is to the healthcare community, to the men and 

women who do diagnostic and therapeutic intervention, and you know how important this tool is 

to continue. And it’s – it’s -- I know there are a lot of healthcare providers that are 

uncomfortable with the prospect that Technetium may be in short supply in the pending near 

future. And, last, and really most important in my opinion is the fact that so many of us may be 

requiring this tool. You know, whether there’s -- of the 18 million doses of Technetium a year, 

which, obviously, do the math, is 50,000 a day, many of us will need this diagnostic tool for 

heart disease, bone, skin, and other emerging technologies. And it means so much if we’re 

able to bring the production of this very essential radioisotope back into the United States where 

we can produce it here and deliver it to the 300-plus citizens of the United States who continue 

to need this and will need this in the future.

04-01: I wanted to put on record the Columbia Chamber of Commerce’s support of the 

Northwest Medical Isotopes application. I wanted to highlight a couple of items that we are 

supportive of Missouri and Columbia is the home to world-class medical research resources, 

and Columbia is at the strategic central location of that access point, and it accesses to other 

critical markets across the country. So we’re supportive of that effort. Also, the Discovery 

Ridge site utilizes the proximity nourished Missouri and its proximity to transport access at the 

intersections of two major highways and our access to a regional airport. Also, we have an 

ample workforce available for the construction phase through the decommissioning phase of 

this facility. So, once again, the Columbia Chamber of Commerce wants to be on record in 

support of the Northwest Medical Isotopes application.

05-01: I mention that simply to reinforce the point that this project, Northwest Medical Isotopes, 

has from the start been the perfect example of a private-public or a public-private partnership. 

Much like REDI, which is also a public-private partnership, this project is a prime example of a 
Appendix A

A-11

company in the city of Columbia, county of Boone, state of Missouri, and our great native 

University working together to do whatever’s necessary to bring a great project to fruition.

You will hear some more and have heard from several folks tonight about more specific 

information relating to this project. My role is to discuss the overall economic pro-- economic 

impact of the project and how it will impact our community and state.

REDI’s worked with Northwest for over two years by assisting Northwest and bringing together 

the right organizational leadership to help move this project to this point. I mentioned many of 

them just a second ago, but must stress the critical role of the University and the University 

team at the research reactor. This is simply an amazing opportunity for Columbia, the 

University, Missouri and, in fact, the United States and our citizens.

There are approximately 50,000 doses of this drug that will be produced at this proposed facility 

administered every day in North America. There’s no other producer in the United States for 

this credible diagnostic medical pharmaceutical. Our research reactor, in collaboration between 

Northwest and the University, are the critical components for this project.

It’s estimated that construction of this $70 million radioisotope production facility in fully 

operational state will require over 180 full-time skilled construction personnel from Central 

Missouri and take longer than a year. When the facility’s in operation, it’s estimated to employ 

98 full-time employees. I will tell you those positions will range from extremely highly-skilled 

technical jobs to those tasked with maintenance of equipment in the facilities. I make that point 

to note the variety of employment opportunities this project brings to our community. Not 

included in these construction and operational employment and cost estimates are the ancillary 

jobs this project will create. Obviously these radiopharmaceuticals require very rapid delivery to 

the medical facilities that administer them around the country.

This project will be located at University’s Discovery Ridge Research Park on 7.4 acres. 

Discovery Ridge is another great example of great public-private partnerships, as it houses ABC 

Laboratories, which is an environmental testing organization serving the pharmaceutical 

industry, and other clients like IDEXX, a bioscience company serving veterinary and the animal 

health research industry. This site is critically located within a few miles of Interstate 

Highway 70, sets immediately adjacent to U.S. Highway 63. This location provides critical 

north, south, east, west transportation assets from the center of the United States and is only 

about six miles from Columbia Regional Airport.

All necessary utilities and street infrastructures, including an adjacent overpass providing 

access to Highway 63, is already in place at the lot line for a fast timeline for this project. That 

fact simply demonstrates our community’s long-term commitment to support this very type of 

development at Discovery Ridge. In addition to the investment and employment opportunities 

I’ve mentioned, it’s also anticipated over the life of this project this project will produce over 

$76 million in tax revenues to support our school, our city, our county, and our state. In closing, 

on behalf of REDI and myself, our community, our county, our state, and the thousands of U.S. 

citizens whose lives will be positively impacted by this project on a daily basis, I give our support 

and approval.

08-01: The opportunities that we look forward to are those that allow for the growth of 

employment as well as investment. We’re very, very pleased to have provided an assistance 

proposal to Northwest Isotopes approximately a year and a half ago that does just that; creates 

a number of great jobs, a great deal of investment in one of our targeted industries of life 

sciences. It also does something that I consider very important; it creates an opportunity to 

save lives.
Appendix A

A-12

03-01: Large-scale production of moly-99 is currently only completed at five facilities worldwide. 

Moly-99 has not been produced domestically since 1991. These five facilities rely on aging 

research reactors, which are periodically subject to planned and unplanned maintenance. 

Some of these unplanned maintenance outages have led to shortages of moly-99, frequently 

impacting patient access to technetium for these important diagnostic procedures.

Mallinckrodt is also a major producer of moly-99 at our facility in the Netherlands, so we are 

very familiar with what is needed to produce commercial quantities of this isotope. As the 

world’s largest consumer of moly-99, Mallinckrodt closely follows new efforts to produce this 

critical isotope and supports construction of new facilities for its production. We are very familiar 

with Northwest Medical Isotopes’ plan to license and construct a facility in Columbia, Missouri

for the production of moly-99 and the recycling of their target material. As we understand it, 

they intend to utilize a network of two to three university research reactors and build a new 

moly-99 production facility, all of which should provide additional moly-99 capacity.

We believe their technology offers distinct advantages because it is based on the well-proven 

fission method of moly-99 production and uses existing reactors. Their operation will, 

importantly, also be based upon low-enriched uranium, which meets the objectives of the 

U.S. Government's nonproliferation policy, as stated at the 2012 Nuclear Security Summit in 

Seoul, South Korea and in 2014 in the Netherlands.

Nuclear medicine procedures performed in the U.S. consume half of the world’s supplies of 

moly-99. A domestic moly-99 production facility will reduce radioactive decay losses in transit 

from the current suppliers in Europe, South Africa, and Australia. A U.S. supply, if robust 

enough to supply the entire market, will also eliminate or reduce transport problems we’ve had 

in the past relying on shipments from Europe, incidents including volcanic activity in Iceland and 

flood destructions due to terrorist concerns. Discussions leading up to the passage of the 

American Medical Isotope Production Act of 2012 cited all of these issues as a reason to 

encourage domestic production of moly-99.

Mallinckrodt applauds Northwest Medical Isotopes’ efforts to build its facility in Columbia and 

encourages the NRC to provide the necessary resources for an expedient review of their 

construction permit and operating license applications.

Response:

These comments generally support the application and note the medical and socioeconomic 

benefits of constructing and operating the proposed NWMI facility at the University of Missouri’s 

Discovery Ridge Park in Columbia, Missouri. The commenters cite the use of a proven 

technology, the benefit of providing a domestic supply of Mo-99 for medical use, public–private 

partnership, and the proximity of the proposed NWMI facility site to transportation infrastructure.

Section 3.7 of the EIS describes the current socioeconomic factors, including labor force, 

employment, and unemployment data for the City of Columbia and Boone County, which have 

the potential to be directly or indirectly affected from construction, operations, and 

decommissioning of the proposed NWMI facility. Section 4.7 of the EIS describes the potential 

socioeconomic impacts from constructing, operating, and decommissioning the proposed NWMI 

facility at the Discovery Ridge site. The impact analysis considered potential changes in 

regional employment, housing availability, tax revenues, and public services.

Section 3.9 of the EIS describes the local transportation systems, including roadway networks 

and traffic volumes near the proposed Discovery Ridge site. Section 4.10 of the EIS describes 

the potential transportation impacts during the construction operations, and decommissioning of 

the proposed NWMI facility at the Discovery Ridge site.
Appendix A

A-13

Section 5.4 of the EIS evaluates the costs and benefits of the proposed action and compares 

the environmental impacts of the proposed NWMI facility with those that would be associated 

with using alternative technologies. Table 5–13 provides a tabular comparison of the potential 

environmental impacts of constructing, operating, and decommissioning the proposed NWMI 

facility at the Discovery Ridge site with the potential environmental impacts of using alternative 

technologies.

A.2 Comments Received on the Draft EIS

On October 31, 2016, the NRC issued the Environmental Impact Statement for Construction 

Permit for the Northwest Medical Isotopes Radioisotope Facility, Draft Report for Comment

(NUREG-2209, referred to as the draft EIS or DEIS) to Federal, Tribal, State, and local 

government agencies and interested members of the public. The U.S. Environmental Protection 

Agency (EPA) issued its Notice of Availability regarding the draft EIS on November 10, 2016

(81 FR 79019). The public comment period ended on December 29, 2016. As part of the 

process to solicit public comments on the draft EIS, the NRC did the following:

• placed a copy of the draft EIS at the Daniel Boone Regional Library in 

Columbia, Missouri;

• made the draft EIS available in the NRC’s Public Document Room in 

Rockville, Maryland;

• placed a copy of the draft EIS on the NRC Web site at https://www.nrc.gov/infofinder/nonpower/nw-medical-isotopes.html and https://www.nrc.gov/reading-rm/doccollections/nuregs/;

• provided a copy of the draft EIS to members of the public that requested one;

• sent copies of the draft EIS to Federal, Tribal, State, and local government 

agencies;

• published a notice of availability of the draft EIS in the Federal Register on 

November 9, 2016 (81 FR 78865);

• filed the draft EIS with the EPA; and 

• conducted a public meeting in Columbia, Missouri, on December 6, 2016, to 

describe the preliminary results of the environmental review and receive

public comments.

Approximately 34 people attended the public meeting on the draft EIS and a certified court 

reporter prepared a transcript of the meeting (ADAMS No. ML16364A281). A meeting summary 

is also available in ADAMS (ADAMS No. ML17003A149).

A total of seven commenters provided comments during the public meeting. These comments 

are available in the public meeting transcript (ADAMS No. ML16364A281). Comments from six 

of the seven commenters supported the NRC issuing a permit to construct the proposed NWMI 

facility. Because these comments are general in nature and did not provide substantive 

information related to the NRC’s environmental review, they do not warrant further response. 

Accordingly, no changes were made to the EIS as a result of these comments. Comments from 

one commenter, Tom Lata, Vice President of the Osage Group of the Sierra Club, resulted in 

revisions to the EIS. Responses to his comments are provided in Section A.2.1.

The following commenters provided written comments during the public comment period:
Appendix A

A-14

• Steve Mattmuller (ADAMS No. ML16364A011) and George Deatz (ADAMS 

No. ML16351A189) provided comments in support of the proposed NWMI 

facility. These comments did not provide substantive information related to 

the environmental review and no changes were made to the EIS as a result 

of these comments.

• Jon Hendricks (ADAMS No. ML17003A271) provided a comment not in 

support of the NRC issuing a construction permit for the proposed NWMI 

facility. This comment did not provide substantive information related to the 

environmental review and no changes were made to the EIS as a result of 

this comment.

• EPA Region 7 (ADAMS No. ML17005A276) and Tom Lata, Vice President of 

the Osage Group of the Sierra Club (ADAMS No. ML16364A012).

Responses to these comments are provided in Section A.2.1. Comments 

from both of these commenters resulted in changes to the EIS.

The following section presents the comments from the two commenters identified above 

(EPA and Tom Lata) and the responses to their comments. The comments are presented in the 

same order as they appear in the documents submitted by the commenters. Changes made to 

the draft EIS are marked with a change bar (vertical lines) on the side margin of the page.

A listing of all commenters, their affiliation, and the ADAMS number of the document containing 

their comments is provided in Table A–3 below.

Table Comments Received Associated with the NWMI Draft EIS

Commenter Affiliation (If Stated) Comment Type ADAMS No.

Joe Summerlin EPA Region 7 Letter ML17005A276

Tom Lata Vice President of the Osage Group 

of the Sierra Club

Letter and

oral comment

ML16364A012

ML16364A281

Steve Mattmuller Kettering Medical Center Letter ML16364A011

George Deatz Member of public Email ML16351A189

Jon Hendricks Member of public Email ML17003A271

Brian Treece Mayor of Columbia, Missouri Oral comment ML16364A281

Stacey Button Director of Economic Development 

for Columbia, Missouri

Oral comment ML16364A281

Matt McCormick President and CEO of City of 

Columbia Chamber of Commerce

Oral comment ML16364A281

Dave Griggs Former Boone County 

Commissioner

Oral comment ML16364A281

Terry Maglich Missouri Department of Economic 

Development

Oral comment ML16364A281

Karen Miller Boone County Associate 

Commissioner

Oral comment ML16364A281
Appendix A

A-15

Comments and NRC Staff Responses

Comments from the U.S. EPA Region 7 (ADAMS No. ML17005A276)

COMMENT: 1 Regarding gaseous radioactive waste from routine operations, Section 2.7.1.1 

Gaseous Waste: This section identifies and provides estimated annual activity of noble gas 

effluent expected during normal operation (See Table 2-4), but the text in this section also 

notes, "Radioactive iodine, particulates, and tritium could also be present in the airborne effluent 

exhaust." However, the draft environmental impact statement does not provide an estimation of 

these non-noble gas emissions, nor does it provide an estimated filtration percentage from the 

ventilation system.

Recommendations for the Final Environmental Impact Statement:

Please provide additional detail on the approximate total inventory, prior to and after, the 

gaseous waste exhaust system, including description of noble gas retention time, system 

efficiency with regards to iodine and particulates, and the final filtration system on radioiodines, 

particulates, and tritium.

RESPONSE: The comment asks that the EIS include additional detail on the inventories of 

radioactive noble gases, iodines, particulates, and tritium that could be present in the airborne 

effluent exhaust from the NWMI facility, both prior to and after the effluent passes through the 

gaseous waste exhaust and filtration systems (offgas treatment systems). The comment also 

asks that the EIS indicate how long noble gases are retained for decay prior to their release to 

the environment, and the offgas treatment system efficiencies for removal of radioactive iodines 

and particulates.

NWMI has not provided information regarding efficiencies for removal of radioactive iodines and 

particulates. NWMI has not provided non-proprietary information regarding either how long 

noble gases are retained for decay, or regarding inventories of gaseous radioactive material 

generated during facility processes. However, NWMI has provided non-proprietary information 

regarding the quantities of radioactive noble gases, iodines, and particulates that are actually 

released to the environment (i.e., that pass through the offgas treatment systems). 

As noted in the comment, Table 2–4 in Section 2.7.1.1 of the EIS provides the estimated annual 

activity releases for three radioactive noble gases (krypton-85, metastable xenon-131, and 

xenon-133). As discussed in Section 2.7.1.1 of the EIS, radioactive iodines, particulates, and 

tritium could also be present in the airborne effluent exhaust. As a result of this comment, 

Section 2.7.1.1 of the EIS has been revised to additionally clarify that noble gases other than 

krypton-85, metastable xenon-131, and xenon-133 could also be present in the airborne effluent 

exhaust. However, Section 2.7.1.1 of the EIS has also been revised to clarify that of all the 

radionuclides that could be present in the exhaust, krypton-85, metastable xenon-131, and 

xenon-133, are the primary radionuclides of interest in the gaseous effluent from a public dose 

standpoint. Section 2.7.1.1 of the EIS has been revised to clarify that, although smaller 

amounts of other radionuclides besides krypton-85, metastable xenon-131, and xenon-133

(radioactive iodines, particulates, tritium, and noble gases other than krypton-85, metastable 

xenon-131, and xenon-133) would also be released, because the quantities released for these 

other radionuclides would be small, the public dose contribution from these radionuclides would 

also be small. A reference to the NWMI RAI response (NWMI 2016a), which lists quantities of 

radioactive noble gases, iodines, and particulates released to the environment, and shows that 

except for krypton-85, metastable xenon-131, and xenon-133, the quantities are small, has also 

been added to Section 2.7.1.1 of the EIS. The quantities of radioactive iodines, particulates, 

and noble gases other than krypton-85, metastable xenon-131, and xenon-133 are provided in 

the NWMI RAI response (NWMI 2016a), but are not discussed in detail in the EIS because they 
Appendix A

A-16

are not expected to contribute significantly to the public dose. (NWMI has not provided a 

non-proprietary estimate of the quantity of tritium released to the environment, but, as stated in 

Section 4.8.2.1 of the EIS, and also added to Section 2.7.1.1 of the EIS, NWMI determined that 

the dose from tritium would be negligible relative to the dose from other radionuclides released.)

As discussed in Section 1.2 of the EIS, the NRC staff is conducting a safety review of NWMI’s 

construction permit application that is separate from the environmental review that has resulted 

in this EIS. Additionally, NWMI cannot operate its facility unless it submits, and the NRC 

approves, an application for an operating license as well as a license to receive and possess 

special nuclear material for processing. The issuance of a construction permit is a separate 

licensing action from the issuance of an operating license for a facility, and both include

environmental and safety reviews. The NRC staff safety reviews will further evaluate the 

radionuclide source terms for the proposed facility, as well as facility design features used to 

minimize radiation exposures. The safety reviews will include the information discussed in the 

comment, including proprietary information, as appropriate, and will determine whether radiation 

exposures associated with operation meet NRC requirements. The environmental review for 

the operating license application will also consider additional information provided by NWMI in 

its operating license application, as appropriate. The results of the safety reviews for the 

construction permit application and the operating license application will be documented in the 

NRC staff Safety Evaluation Reports, and the environmental review for the operating license 

application will be documented in an EIS supplement prepared by the NRC staff.

As a result of this comment, the NRC staff revised Section 2.7.1.1 of the EIS as discussed 

above.

COMMENT: 2. Regarding the Waste Management Building, Section 2.1 Site Location and 

Layout, Section 2.7.1.2 Liquid and Solid Waste, and Section 19.2.8.1.2 Treatment and 

Temporary Storage of Waste Onsite of the Construction Permit Application for Radioisotope 

Production Facility (ML15086A265): These sections refer to a "Waste Management Building" 

and certain waste that will be collected prior to shipment off-site, but it is unclear in the draft 

environmental impact statement what radionuclides and activities will be stored in the detached 

waste building? Is it anticipated that routine operational exposures from these wastes will 

occur? Are fire protection safety systems considered? Is there any special filtration considered 

as part of the ventilation system, and is shielding from direct gamma exposure in this building 

and wastes considered for occupational and public exposures?

Recommendation for the Final Environmental Impact Statement:

Please provide additional information on these items in the final environmental impact 

statement, as well as, whether an accidental release of these wastes was considered as part of 

the design basis accident assessment.

RESPONSE: The comment asks what types and activities of radioactive waste will be stored in 

the detached waste management building, whether routine occupational exposures from wastes 

in this building will occur, and whether fire protection, filtration, or shielding are considered in the 

design of this building. The comment also asks whether an accidental release of radioactive 

waste in this building was considered as part of the accident assessment for the NWMI facility.

As a result of this comment and Comment 3 below, the NRC staff revised Section 2.8.1.1 of the 

EIS to clarify that only Class A radioactive wastes (which generally contain mostly short-lived 

radionuclides at relatively low activity concentrations) would be handled and stored in the 

detached waste management building, and no processing of waste would be performed in that 

building. As discussed in Section 2.7.1.2 of the EIS, a total of about 232,000 kg (511,472 lbs) of 

Class A waste would be generated at the proposed facility per year, and as discussed in 
Appendix A

A-17

Section 2.8.1.1 of the EIS, Class A waste could be stored at the facility for approximately 

12 weeks before shipment offsite for disposal. The type (Class A) of the waste stored in the 

detached waste management building, along with the rate of Class A waste generation and the 

storage duration for Class A waste, bound the total activities of radioactive waste that could be 

present in the building. Additionally, NWMI estimated in its construction permit application 

(NWMI 2015) that the total activity in Class A solidified process waste (which, by mass,

comprises most of the Class A waste produced) that would be produced at the proposed facility

would be approximately 0.14 curies per week.

Routine occupational exposures, including exposures from wastes stored in this building, would 

occur during operation of the NWMI facility. However, as discussed in Section 2.8.1.1 of the 

EIS, radioactive waste, including wastes stored in the detached waste management building, 

would be stored in a manner that would ensure that personnel exposures to radiation would be 

as low as is reasonably achievable and within 10 CFR Part 20 limits. As discussed in 

Section 4.8.2.1 of the EIS, the combination of shielding within the NWMI facility (including the 

detached waste management building) and the distance from the NWMI facility buildings to the 

site boundary would ensure that the direct radiation dose to members of the public at the site 

boundary would be negligible. The NRC staff expects that shielding provided by the detached 

waste management building structure would also help reduce occupational doses.

NWMI has not identified any specific fire protection and filtration systems for the detached waste 

management building. However, as discussed in Section 2.8.1.1 of the EIS, radioactive waste, 

including wastes stored in the detached waste management building, would be stored in a 

manner that would help ensure that no uncontrolled release of radioactive materials from the 

waste would occur, and if any release did occur, resulting doses would be within 

10 CFR Part 20 limits. As a result of this comment, the NRC staff revised Section 2.8.1.1 of the 

EIS to clarify this discussion. Additionally, as a result of this comment and Comment 3 below, 

the NRC staff revised Section 2.8.1.1 of the EIS to state that because only Class A (low activity 

concentration) wastes would be stored and no waste would be processed in the detached 

building, any activity available for release would be limited.

As discussed in Section 4.11.1 of the EIS, NWMI considered a variety of potential nuclear 

criticality or radioactive material accidents for evaluation of the radiological consequences for 

members of the public from potential accidents at the proposed NWMI facility. NWMI did not 

specifically consider a fire in the detached waste management building in the construction 

permit application. However, as discussed in Section 4.11.1 of the EIS, events that were not 

specifically considered in NWMI’s construction permit application were either determined by 

NWMI to be bounded by the accidents considered; were determined by NWMI to pose an 

acceptably low level of risk, based on low likelihood and/or consequences; or they have not yet 

been fully evaluated by NWMI.

As discussed in Section 4.11.1 of the EIS, the NRC staff is conducting an independent review of 

the radiological consequences of accidents at the proposed NWMI facility as part of its separate 

safety review of the construction permit application for the facility. If NWMI submits an 

operating license application for the proposed facility, the NRC staff will conduct an additional 

and separate safety review, which will further evaluate accident consequences. These reviews 

will evaluate NWMI’s analyses of the full range of accidents that could occur at the facility, 

including the assumptions used for the analyses, to ensure that the proposed NWMI facility 

would comply with 10 CFR 70.61 and any other NRC regulations applicable to radiological 

accident consequences. Additionally, a separate environmental review will be conducted if an 

operating license application is submitted and docketed, and that review will also consider any 

additional information submitted by NWMI in its operating license application. The results of the 

safety reviews for the construction permit application and the operating license application 
Appendix A

A-18

(if submitted) will be documented in separate NRC staff Safety Evaluation Reports. The 

environmental review for the operating license application will be documented in an EIS 

supplement prepared by the NRC staff.

As a result of this comment, the NRC staff revised Section 2.8.1.1 of the EIS as discussed 

above.

COMMENT: 3. Regarding accident assessment, Section 4.11.1 Radiological Accidents: This 

section refers to an accident scenario evaluation within the radioisotope production facility with 

effluents vented out the elevated ventilation stack. An elevated release would cause additional 

dispersal of a plume, as noted by the maximum projected dose to a member of the public 

calculated at nearly a mile downwind. The draft environmental impact statement does not 

indicate if other accident scenarios were evaluated. For example, a situation where a fire 

involving lesser amounts of activity but released at ground level may have a comparable dose 

impact to nearby off-site receptors. What was the basis for the accident assessment to assume 

all radionuclide effluents would be entrained through the ventilation system and out the elevated 

release point? Did other accident scenarios postulate varying conditions where a fire would 

lead to a radionuclide release at ground level as a comparison to the noted design-basis 

accident? Does the design-basis accident represent the highest plausible public dose accident, 

and did an accident scenario consider a fire in the detached waste management building 

(assuming this building as noted in Figure 2-3, Proposed NWMI Facility Site Boundary and Site 

Layout, stores radioactive waste material)?

Recommendation for the Final Environmental Impact Statement:

The reference, NWMI, 2016a, includes an accession number, ML16053A212, with source term 

information and updated accident assessment modeling that does not appear to be fully 

explained in the draft environmental impact statement. Please provide an additional summary 

of this reference in the final document.

RESPONSE: The comment asks whether other accidents, such as those that could result in 

radioactive material being released at ground level rather than from the elevated ventilation 

stack (for example, a fire in the detached waste management building), could result in 

consequences that exceed the hypothetical radioactive material accident (a fire-related gross 

failure of the target dissolution offgas treatment system) discussed in EIS Section 4.11.1. The 

comment also recommends that the EIS include additional detail regarding the source term 

information and accident assessment modeling for the accident discussed in EIS 

Section 4.11.1.

As discussed in Section 4.11.1 of the EIS, NWMI stated that it determined that a fire-related 

gross failure of the target dissolution offgas treatment system accident resulting in a release of 

radioactive material from the stack could result in radiological consequences for members of the 

public that would bound those of any credible radiological accident at the NWMI facility. 

As also discussed in Section 4.11.1 of the EIS, NWMI considered a variety of different potential 

nuclear criticality or radioactive material accidents, including offgas treatment system accidents

and other accidents, for evaluation of the radiological consequences for members of the public 

from potential accidents at the proposed NWMI facility. At this time, NWMI has not provided 

information regarding whether any of the accident scenarios it evaluated specifically considered

the maximum public doses resulting from a ground release of radioactive material. However, as 

discussed in Section 2.7.1.1 of the EIS, the ventilation system of the NWMI Radioisotope 

Production Facility building (in which target processing is performed, and which contains the 

target dissolution offgas treatment system) is designed such that air leaving the facility is 

exhausted through an elevated vent stack. Therefore, the ventilation system would help ensure 
Appendix A

A-19

that any radioactive material released into the Radioisotope Production Facility building from a 

fire, spill, or other event would be released to the environment at an elevated release point. 

NWMI did not specifically consider a fire in the detached waste management building in the 

construction permit application. However, as discussed in Section 4.11.1 of the EIS, events that 

were not specifically considered in NWMI’s construction permit application were either 

determined by NWMI to be bounded by the accidents considered; were determined by NWMI to 

pose an acceptably low level of risk, based on low likelihood and/or consequences; or they have 

not yet been fully evaluated by NWMI. NWMI may provide additional postulated accident 

information in its operating license application that will be submitted separately for NRC review. 

As a result of this comment and Comment 2 above, the NRC staff revised Section 2.8.1.1 of the 

EIS to state that only Class A (low activity concentration) waste would be stored in the detached 

waste management building, and no processing of waste would be performed in that building, 

so any activity available for a potential release from the building would be limited. The NRC 

staff also notes that, as discussed in Section 2.8.1.1 of the EIS, all radioactive waste at the 

NWMI facility, including waste in the detached waste management building, would be stored in 

a manner that would help ensure that no uncontrolled release of radioactive materials from the 

NWMI facility could occur. If any release did occur, any resulting public or occupational dose 

would be within 10 CFR Part 20 limits. 

Section 4.11.1 of the EIS summarizes the source term basis and other assumptions used in 

NWMI’s analysis of the hypothetical radioactive material accident involving a fire-related gross 

failure of the target dissolution offgas treatment system. The summary provided in 

Section 4.11.1 is consistent with the information in the NWMI RAI response referenced in the 

comment (NWMI 2016a). As discussed in Section 4.11.1, the source term for NWMI’s analysis 

is based on the assumption that all radioactive iodine and noble gas isotopes retained in the 

target dissolution offgas treatment system (following 12 weeks of facility operation, with 

12 targets processed per week, and all targets processed directly upstream of the offgas 

treatment system) are released, without mitigation, from the facility stack. NWMI also applied a 

safety margin of 1.32 to account for uncertainty in its source term. Although the RAI response 

referenced in the comment (NWMI 2016a) provides some additional information regarding the 

source term and assumptions for NWMI’s accident analysis, this information is beyond the 

scope of the discussion in Section 4.11.1 of the EIS, which provides a basic summary of the 

accident analysis.

As discussed in Section 4.11.1 of the EIS, the NRC staff is conducting an independent review of 

the radiological consequences of accidents at the proposed NWMI facility as part of its separate 

safety review of the construction permit application for the facility. If NWMI submits an 

operating license application for the proposed facility, the NRC staff will conduct an additional 

and separate safety review, which will further evaluate accident consequences. These reviews

will evaluate NWMI’s analyses of the full range of accidents that could occur at the facility, 

including the assumptions used for the analyses, to ensure that the proposed NWMI facility 

would comply with 10 CFR 70.61 and any other NRC regulations applicable to radiological 

accident consequences. Additionally, a separate environmental review will be conducted if an 

operating license application is submitted and docketed, and that review will also consider any 

additional information submitted by NWMI in its operating license application. The results of the 

safety reviews for the construction permit application and the operating license application

(if submitted) will be documented in separate NRC staff Safety Evaluation Reports. The 

environmental review for the operating license application will be documented in an EIS 

supplement prepared by the NRC staff.
Appendix A

A-20

As a result of this comment, the NRC staff revised Section 2.8.1.1 of the EIS as discussed 

above.

COMMENT: 4. Regarding public dose limits, Section 3.8.2.3 Regulations Governing Dose from 

Human-Made Sources of Radiation: This section references the 10 millirem per year public 

dose standard for airborne releases under 10 CFR 20.1101(d). Does the U.S. Nuclear 

Regulatory Commission anticipate additional "As Low As Reasonably Achievable" objectives for 

gaseous effluent control below 10 millirem? Does Appendix I of 10 CFR 50, which includes 

numerical guides for these objectives, stipulate any additional considerations to the Northwest 

Medical Isotopes facility in regards to iodine or other air effluents?

Recommendations for the Final Environmental Impact Statement:

If additional objectives or concerns are anticipated, please include them in the final 

environmental impact statement.

RESPONSE: The comment asks whether the NRC anticipates that NWMI would use additional 

“as low as is reasonably achievable” (ALARA) objectives for public doses from gaseous 

effluents other than the 10 millirem constraint of 10 CFR 20.1101(d), for example, objectives 

based on 10 CFR Part 50, Appendix I. The comment also recommends that any additional 

ALARA objectives or Appendix I based concerns be included in the EIS. 

For public doses from gaseous effluents, NWMI has not committed to additional ALARA

objectives beyond the 10 millirem constraint of 10 CFR 20.1101(d). Additionally, the NRC staff 

notes that the proposed facility would not be subject to 10 CFR Part 50, Appendix I, because 

that regulation is only applicable to light-water-cooled nuclear power reactors. Therefore, the 

NRC staff does not currently expect that NWMI would use any additional ALARA objectives for 

public doses from gaseous effluents. As discussed in Section 4.8.2.1 of the EIS, NWMI 

estimates that the maximum dose to the public from gaseous effluents would be 3.6 millirem per 

year. This estimated dose is well below the annual public dose limit of 100 millirem in 

10 CFR 20.1301, and is also within the 10 millirem constraint of 10 CFR 20.1101(d).

The NRC staff did not revise the EIS as a result of this comment.

COMMENT: 5. Does the U.S. Nuclear Regulatory Commission anticipate the University of 

Missouri Research Reactor to increase radionuclide emissions due to the Northwest Medical 

Isotopes target irradiation? And if so, what is the estimated increase in effluent and anticipated 

changes to both the annual projected dose under normal operating conditions as well as 

accident conditions?

Recommendation for the Final Environmental Impact Statement:

Include any additional emissions from the University of Missouri Research Reactor, as well as,

accident conditions. A reference to the University of Missouri Research Reactor's accident plan

would be sufficient.

RESPONSE: The comment asks whether the target irradiation at the University of Missouri 

Research Reactor (MURR) would result in possible increases in public doses from routine 

operation of, or potential accidents at, the research reactor; and, if so, what amount of increases 

would occur.

As discussed in Section 4.13.1.2 of the EIS, no radiological gaseous emissions are expected 

from the targets themselves during routine target irradiation. Routine gaseous releases from 

the operation of the reactor (which would occur regardless of whether targets are being 

irradiated) can change based on how often and at what power level the reactor is operated. At 

MURR, however, no change in radiological gaseous effluents would be expected because the 
Appendix A

A-21

operating tempo (frequency and power level) of the reactor would not change. Therefore, there 

would be no increase in radiation doses to the public from routine gaseous effluents. 

Additionally, no changes in the source, types, or quantities of routine radiological liquid effluents 

from MURR are expected. Gaseous and liquid radiological effluents from MURR would 

continue to be required to remain within NRC regulatory limits.

The consequences of potential accidents at research reactors must comply with NRC

regulations, including the public dose limits in 10 CFR Part 20. When research reactors are 

licensed by the NRC, applicants must evaluate the consequences of potential accidents at the 

research reactor facility. Research reactor license applicants must provide analyses that 

demonstrate that the consequences of accidents are within 10 CFR Part 20 dose limits. If the 

accident doses are within 10 CFR Part 20 limits, then the environmental impacts of accidents at 

the research reactor are small. As discussed in Section 4.13 of the EIS, research reactors that 

irradiate NWMI’s targets will need to submit a request for a separate NRC license amendment 

to provide irradiation services to NWMI. The NRC must issue each reactor facility a license 

amendment before NWMI’s targets can be irradiated at the reactor. The license amendment 

requests will need to include an analysis of potential accidents that could occur at the research 

reactors in conjunction with target irradiation, and address whether research reactor accidents 

associated with target irradiation could potentially have dose consequences that exceed those 

of accidents previously evaluated for each research reactor facility. The NRC will conduct a 

separate review of each license amendment request submitted to the NRC to ensure that the 

consequences of any potential accident associated with target irradiation are within 

10 CFR Part 20 dose limits. If the consequences of any new, credible accident that could occur 

at MURR, OSTR, or the third research reactor site in conjunction with target irradiation remain 

within 10 CFR Part 20 dose limits, then there would be no significant additional environmental 

impact from accidents at the facilities, because the environmental impact would still be small.

Sections 4.13.1.2, 4.13.2.2, and 4.13.3.2 of the EIS do not include a discussion of possible 

increases in doses from potential accidents related to target irradiation at research reactors,

because these accidents have not yet been evaluated, and also because no significant change 

in impacts from research reactor accidents is anticipated as discussed above. As a result of this

comment, the NRC staff revised Sections 4.13.1.2, 4.13.2.2, and 4.13.3.2 of the EIS to clarify

that the NRC staff will perform a detailed review of potential accidents related to target 

irradiation at the research reactor facilities as part of its review of the research reactor license 

amendment requests, and that if the consequences of potential accidents remain below 

10 CFR Part 20 dose limits, then no significant additional environmental impact is expected from 

accidents at the MURR, OSTR, and third research reactor. Additionally, as a result of this

comment, the NRC staff revised Section 3.10 of the EIS to clarify that existing research reactor 

accident dose analyses (for previously evaluated accidents, not related to target irradiation) are 

not discussed in Section 3.10 of the EIS because activities related to target irradiation at the 

research reactors are not anticipated to result in a significant change in impacts of potential 

research reactor accidents. The NRC staff will perform an additional, separate environmental 

review and safety review for each research reactor license amendment and it will also prepare a 

supplemental EIS in conjunction with its safety review of NWMI’s operating license application. 

These additional environmental reviews for each license amendment, and the supplemental EIS 

for the NWMI operating license application, would provide additional details as appropriate

regarding impacts from research reactor accidents.

As a result of this comment, the NRC staff revised Sections 3.10, 4.13.1.2, 4.13.2.2, and 

4.13.3.2 of the EIS as discussed above.
Appendix A

A-22

Written Comments from Mr. Tom Lata, Osage Group of the Sierra Club (ADAMS 

No. ML16364A012)

COMMENT: The proposed Federal action is for the NRC to decide whether to issue a 

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

radioisotope production facility. Due to the unique environmental attributes of this site, and 

based on items that were either not reviewed or are understated in the report, we believe the 

location of the site, particularly the construction activities, will have a significant impact on the 

environment.

Areas that have more than a small impact include the following:

Water Resources, Ecological Resources, Cumulative Impacts, and Endangered Species. We 

agree with the report concerning the cumulative impact having a moderate impact on the 

environment, and believe that this should translate into more than a low impact for this particular 

project; based upon the fact that its location is in one of the environmental sensitive areas of the 

County, if not of the State; within the Gans Creek Watershed; and it should be sited elsewhere.

We take issue with the determination that the proposed action would result in no effect to 

species and habitats protected under Federal or State laws, including the Endangered Species 

Act of 1973, as amended. We have comments on the following different areas:

RESPONSE: The preceding comments summarize and introduce the commenter’s detailed 

written comments in 11 areas. Each concern raised is stated again in the written comments

included and responded to below.

COMMENT: Area 1 - Too many unknown geological factors for a Nuclear Facility: The project 

concerns the construction of a major manufacturing facility handling hazardous and radioactive 

waste. This requires deep footings placed into an area that has karst topography and an 

uncertain water table. I personally own a house in a subdivision near the State Park. Many of 

the homeowners there have experienced first floor water problems that are not always related to 

surface run-off, but are related to water table problems that vary by location due to sub surface 

Karsts Topography in the Area. The project should not be approved without further exploration 

of Karst features that may exist on the site.

RESPONSE: The comment expresses concern regarding siting the NWMI facility at the 

proposed Discovery Ridge site due to unknown site geologic conditions, and the karst 

topography in the area and water table issues. The comment also states that the project should 

not be approved without further exploration of Karst features that may exist on the site.

Section 3.3.1 of the EIS describes the geology of the proposed Discovery Ridge site including 

bedrock conditions, and Section 3.4.2.1 describes the hydrogeology of the site including the 

occurrence of groundwater. Section 4.3 of this EIS describes the potential impacts on geologic 

and soil conditions from constructing and operating the proposed NWMI facility. Section 4.4.2 

describes the potential impacts of facility construction and operations on groundwater, including 

the implications of a seasonally high water table or perched groundwater beneath the site. The 

impacts on geology and soils and on site groundwater from constructing, operating, and 

decommissioning the proposed NWMI facility would be SMALL. 

As described in Section 3.3.1 and depicted in Figure 3–12, the site lies near a geologic contact 

between bedrock predominantly consisting of shales and sandstones to the east and limestone 

to the west and south, although the precise composition of the bedrock surface and depth 

beneath the Discovery Ridge site remains uncharacterized at present. Section 3.3.1 also 

describes identified karst features associated with the limestone bedrock to the west and south 

of the Discovery Ridge site. In the final EIS, Section 3.3.1 has been revised to reflect the latest 
Appendix A

A-23

available information on karst features based on NWMI’s latest responses to requests for 

additional information. Further, Sections 3.3.1 and 4.4.2.1 discuss the occurrence of shallow, 

wet soils at the site and the possibility of a shallow water table or perched groundwater 

conditions based on available, although limited, geotechnical information for the site and vicinity.

The NRC staff acknowledges that site conditions could potentially affect facility final design. 

Accordingly, as stated in Sections 4.3.1 and 4.4.2.1, NWMI plans to conduct site-specific 

geotechnical and hydrological studies of the Discovery Ridge site to characterize site conditions 

in support of final facility design. In addition, as stated in NWMI’s latest responses to requests 

for additional information on NWMI’s Construction Permit Application (NWMI 2016b), the sitespecific studies will determine the final facility design. NWMI plans to conduct these studies 

in 2017. 

The NRC staff conducts an environmental and safety review regarding each application that is

received. This EIS presents the results of the environmental review. A safety evaluation report 

will be issued to document the results of the NRC’s safety review. No construction permit will 

be issued unless the NRC determines that all applicable regulatory and statutory requirements 

have been met.

In addition, the issuance of a construction permit is a separate licensing action from the 

issuance of an operating license. Before NWMI can operate the proposed production facility, 

NWMI must (1) submit an application for an operating license and a license to receive and 

possess special nuclear material for its processes, pursuant to the NRC requirements, 

(2) substantially complete construction of the facility in accordance with an NRC-issued 

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

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

accordance with 10 CFR 51.95(b), and prepare a safety evaluation report. The NRC staff 

environmental and safety review of a NWMI operating license application would consider the 

results of any site-specific geotechnical and hydrological studies of the Discovery Ridge site that 

become available.

No changes were made to the EIS in response to this comment.

COMMENT: Area 2: "Large Water Requirements for constructing the NWMI Facility is

needed for: Dust control/soil compaction, workforce potable and sanitary use, washing and 

miscellaneous uses, will amount to a total of (construction phase) 2,088,000 " gallons. This 

is potentially a lot of water and silt that would be running down the creeks during the 

construction period. In our opinion, the City has a spotty record of enforcing stormwater 

regulations, and in many cases, there is no enforcement of stormwater regulations. Who

will enforce the standards for construction run-off into a sensitive stream? Given the

location of the projects, standards for this project should be much higher than the normal

residential subdivision.

RESPONSE: The comment expresses concern regarding the volume of water required for 

construction of the NWMI facility, the magnitude of stormwater runoff, and the transport of silt 

and possible impacts to stream water quality. The comment also asks who would enforce

stormwater management regulations and states that stormwater management standards should 

be higher for the project. 

As for the volume of water required, Section 2.5 of the EIS summarizes the volume of water 

projected for construction, operations, and decommissioning of the proposed NWMI facility, and 

EIS Section 4.4.2.1 further describes the use of this water. Consolidated Public Water Supply 

District No. 1 would supply water to the site. Section 4.4.2.1 also states that the volume of 

water required (averaging 6,140 gallons per day (gpd); equivalent to 0.0061 million gallons per 
Appendix A

A-24

day (mgd)) would have a negligible impact on the utility which has an available supply capacity 

of 9.6 mgd. Most of the construction water would be needed for soil compaction and dust 

control. This volume of water would not directly result in runoff as water needed to compact and 

stabilize soils for structures is normally incorporated into the soil column. Further, watering to 

control fugitive dust is normally only performed when needed and in a manner and at an 

application rate so as to not cause the ponding of water or runoff.

As indicated by the commenter, stormwater runoff from disturbed and denuded ground can 

carry sediment and other substances to nearby surface water bodies. This is why, as discussed 

in Sections 4.3.1 and 4.4.1.1 of this EIS, construction projects are subject to Federal, State, and 

local requirements governing soil erosion and sediment transport and stormwater runoff control. 

NWMI would require a Land Disturbance Permit from the City of Columbia for site construction. 

This permit, in part, requires that management plans be developed and implemented including 

the use of appropriate soil erosion and sediment control best management practices (BMPs) to 

minimize soil erosion and the transport of suspended sediment and other pollutants. Further, 

construction stormwater runoff is regulated under Section 402 of the Federal Clean Water Act 

and Missouri Clean Water Law. As detailed in Section 4.4.1.1 of the EIS, the State of Missouri 

has developed a National Pollutant Discharge Elimination System (NPDES) general permit 

(i.e., Missouri State Operating Permit MO-RA) for the discharge of stormwater and certain 

non-stormwater discharges from construction sites of 1 acre or more. This permit would require 

NWMI to develop and implement a stormwater pollution prevention plan to include appropriate 

BMPs to prevent the discharge of sediment and other pollutants in stormwater runoff.

As for the concern about enforcement of permit provisions for stormwater discharges and 

imposing stricter standards, the City of Columbia and the State of Missouri would be responsible 

for oversight and enforcement, as appropriate. Concerns about a need to impose higher 

stormwater management standards for the project should be directed to them. 

No changes were made to the EIS as a result of this comment. 

COMMENT: Area 3: Length of the construction period will create major and accumulating 

problems with drainage at the site. The construction period would last 17 months, resulting in a 

substantial impact on the environment and a decrease in quality of surface water in Gans Creek 

and associated aquifers. Water would be required for various purposes, such as dust 

suppression and soil compaction during NWMI facility construction. "Activities requiring water 

would include, but would not be limited to, site clearing and grading, facility excavation, support 

facility construction, roadway development, and installation of site drainage and utilities. Facility 

decommissioning activities would require water for many of the same purposes as construction 

in association with facility demolition and decontamination."

"Excavation depths could range from 17 to 23 ft below grade (5.2 to 7 m) for portions of the 

RPF, as described in Section 4.3.1. During the preliminary geotechnical investigation of the

Discovery Ridge Research Park in 2011, the geotechnical contractor encountered groundwater

in two soil borings at depths of approximately 12 to 18.5 ft (3.7 and 5.6 m) bgs (see

Section 3.4.2.1). Therefore, groundwater dewatering will be required during construction."

In response, the report goes on to say, "NWMI will conduct site-specific geotechnical and 

hydrologic studies of the Discovery Ridge site (NWMI 2015c). These studies would help to 

determine whether a seasonally high water table or perched groundwater exists beneath the 

site, as well as guide any necessary construction accommodations and final facility design. 

NWMI estimated the maximum potential dewatering rate for site excavations (NWMI 2016a). 

NWMI used very conservative parameters for runoff area and precipitation yielding a maximum 

dewatering rate of 1,400 gal (5,300 L) per hour." "The NRC staff expects that dewatering could 
Appendix A

A-25

have minor effects on the vertical and horizontal extent of shallow groundwater, if present, and 

on groundwater flow direction, but any effects would be localized and temporary. Site 

groundwater conditions could potentially affect facility construction and final design. These 

include the potential for wet subsurface conditions, including a seasonally high water table or 

perched groundwater beneath the site. To address these potential issues, site-specific 

geotechnical and hydrologic studies are planned that will characterize site conditions in support 

of final facility design. These studies would ensure that the completed facility incorporates any

necessary design features such as foundations protected with water barrier systems (e.g., 

sealants) and foundation drainage and water diversion systems (NWMI 2016a)." "Total 

projected water use for the 17-month construction period is approximately 2.1 million gal (7.9 

million L).”

In other words, thorough investigations have not been completed to determine the extent of the

groundwater on the site. We note that there have been no conclusive investigations to 

determine if the high water table found was due to Karst Topography or to standing water from 

storm water. This would be a huge difference in both cost and impact on the environment. We 

can conclude that the permit should not be considered, until the source of the high water table it 

found is identified. Changes in a permanent waterway, could affect the feasibility of the project 

and the impact on surrounding properties.

RESPONSE: The comment quotes Sections 2.5.1 and 4.4.2.1 of the EIS and expresses 

concern about siting the NWMI facility at the proposed Discovery Ridge site due to the potential 

for drainage problems, including standing water and high water table conditions, and the 

potential for such conditions to impact water quality in Gans Creek and groundwater aquifers. 

The comment also indicates that no construction permit should be considered for the project 

until completion of site groundwater investigations to assess the feasibility of the project and the 

impact on surrounding properties. The comment also expresses concern about unknown

project cost and impacts. 

Section 3.4.2 of the EIS describes groundwater conditions beneath the Discovery Ridge site 

based on currently available information, and Section 4.4.2 of the EIS describes the potential 

impacts of groundwater dewatering at the site and the potential impacts of facility construction 

and operations on groundwater hydrology and quality. As explained in the previous response, 

facility construction would be subject to Federal, State, and local requirements governing soil 

erosion, sediment transport, and stormwater runoff control. For instance, a Land Disturbance 

Permit would be required from the City of Columbia for site construction and an NPDES general 

permit for the discharge of stormwater and certain non-stormwater discharges would be 

required from the State. Both approvals would require that NWMI use appropriate soil erosion 

and sediment control best management practices to minimize soil erosion and the transport of 

suspended sediment and other pollutants and potential water quality impacts. 

As explained in Section 4.4.1.1 of the EIS, the State NPDES general permit would also address 

the discharge of flows from construction dewatering to prevent offsite impacts. As a result of 

these permits, the NRC staff concludes that the impacts on surface water hydrology, quality, 

and use from the construction of the proposed facility would be SMALL. Further, based on the 

analysis presented in Section 4.4.2.1, the impacts on groundwater hydrology, quality, and use 

from construction of the NWMI facility would also be SMALL.

The NRC acknowledges that site conditions could potentially affect facility construction and final 

design. Accordingly, as stated in Sections 4.3.1 and 4.4.2.1, NWMI plans to conduct

site-specific geotechnical and hydrological studies of the Discovery Ridge site to characterize 

site conditions in support of final facility design. In addition, as stated in NWMI’s latest 

responses to requests for additional information on NWMI’s Construction Permit Application 
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A-26

(NWMI 2016b), site-specific studies will determine the final facility design. NWMI plans to 

conduct these studies in 2017. NRC regulations require that NWMI submit its final facility 

design for NRC review and approval as part of a separate application seeking permission to 

operate the facility. 

Concerns about the overall economic feasibility of the project and the associated facility 

construction costs are a matter for the applicant and outside the scope of the NRC’s 

environmental review. 

No changes were made to the EIS as a result of this comment.

COMMENT: Area 4: There are several natural areas in the vicinity of the site that will be 

impacted by the project; these impacts are minimized in the report. According to the report, 

"approximately 7 percent (1,427 ha (3,527 ac)) of the 5-mi (8-km) vicinity surrounding the 

proposed Discovery Ridge site is parks or conservation areas, such as Rock Bridge State Park, 

Three River (should be "Creeks) Conservation Area, and the northwest corner of the Mark 

Twain National Forest." The report failed to mention the City's Gans Creek Recreation Area, 

which is closest to the site and includes large tracts of forested and old farm land on "both" 

sides of Gans Creek. The Gans Creek Recreation Area is adjacent to Rock Bridge State Park 

and provides continuous wildlife corridors, both above and below ground on both sides of the 

creek. Most of this area is available for hunting. The area contains an additional 325 acres not 

included in the 7% report and the regional office of the Department of Missouri Department of 

Conservation. The area also includes "Elbow Cave" and a spring that falls over a high bluff. 

Less than half of the site is used for active recreational activities such as soccer fields etc. The 

Gans Creek Recreation Area is located less than one mile away from the site, while major 

natural features typical of Karst Topography, such as caves and springs are located within 

1.2 miles of the site; with associated flora and fauna that may be impacted by the project. 

Finally, there is a seasonal Blue Heron rookery observed, located in the action area in the Gans 

Creek Recreation Area, which is also likely in the Action Area.

RESPONSE: This comment describes the recreational and ecological resources within the 

Gans Creek Recreation Area and states that this area was not described in the EIS. The NRC 

staff described the Gans Creek Recreation Area in Section 4.14 of the draft EIS, but not in the 

description of the affected environment in Chapter 3. As a result of this comment, the NRC staff 

added a description of the Gans Creek Recreation Area to Sections 3.1.1.3 and 3.5.4.5 in the 

final EIS.

COMMENT: Area 5: The project could have an impact on the "Wild Area" in Rock Bridge State 

Park: Similar to the Gans Creek Recreation Area, and much larger, Rock Bridge State 

Memorial Park, which is an 858-ha (2,120-ac) park that consists of karsts, grasslands, and oak 

woodlands and forests (MDNR 2016a). This State park also contains the Gans Creek Wild 

Area. The Gans Creek Wild Area is managed as a wilderness Area. A large portion Rock 

Bridge State Park has large areas of native grasses, which are not mentioned in the report and 

are downplayed by the authors of the report. In fact, the State Park has gone to great lengths to 

restore most of the fields in the park to native grasses. This has not been recognized in the 

report. Our conclusion is that the project should be located as far away from these recreational 

and natural areas as possible; this one is not.

RESPONSE: This comment states that the EIS does not describe the native grasses within 

Rock Bridge Memorial State Park and the impacts to those grasses. A description of the land 

use and ecological features within Rock Bridge Memorial State Park is provided in Sections 

3.1.1.3 and 3.5.2 and a discussion of potential impacts to these protected areas and habitats is 

provided in Sections 4.1.1 and 4.5.1 of the draft EIS. In addition, as a result of this comment, a 
Appendix A

A-27

discussion of native grasses within Rock Bridge Memorial State Park has been added to 

Section 3.5.4 in the final EIS. As stated in Sections 4.1.1 and 4.5.1, no direct impacts to native 

grasses within Rock Bridge Memorial State Park are expected due to the distance between the 

proposed project and Rock Bridge Memorial State Park (1.8 mi [2.9 km]).

The comment also states that the proposed project should be located as far away from 

recreational and natural areas as possible. The NRC is not involved in an applicant’s planning 

and business decisions regarding where to locate a proposed medical radioisotope production 

facility or any other facility. Rather, the NRC staff evaluates the environmental impacts of the 

proposed action and alternatives to the proposed action. In Section 5.5, the NRC staff 

determined that the proposed action is one of the preferred alternatives because the impacts to 

all resource areas, including special land uses and ecological resources, would be SMALL. 

Thus, no EIS revisions were made as a result of this portion of the comment.

COMMENT: Area 6: The report indicates that "The Missouri Department of Conservation 

(MDC) manages the Three Creeks Conservation Area, which is a 607-ha (1,500-ac) natural 

preserve that consists mostly of oak forests and woodlands and provides cave habitat for bats 

(MDC 2016a). A small portion of the Mark Twain National Forest, Cedar Creek Ranger District, 

is also located within the vicinity of the proposed site (USDA 2016a). The Mark Twain National 

Forest consists of tall grass prairies and shortleaf pine-oak woodlands". Three Creeks also has 

many caves, including two major caves, "Hunters Cave" and "Tomlin Cave". As is in the name, 

there are three creeks all lined with high cliffs and have plenty of habitat to support native 

species, including rare and endangered species not accounted for in the report. These would 

include, the Topeka Shiner (that may or may not still be there, but should be considered there 

for protection), and the Cherrystone snail, found at only one other location in the U.S. (not listed 

in this report). [emphasis in original]

RESPONSE: This comment states that the draft EIS does not provide a complete description of 

land use features and ecological resources within the Three Creeks Conservation Area. A 

description of the land use features and ecological resources within the Three Creeks 

Conservation Area is provided in Section 3.1.1.3. As a result of this comment, the NRC staff 

added a discussion of ecological features within the Three Creeks Conservation Area, including 

the cherrystone snail and the Topeka shiner, to Section 3.5.4 in the final EIS. 

COMMENT: Area 7: Soils in the Area make construction difficult, particularly at lower 

elevations where water is held: The report says that "Soils in the area generally consist of a 

yellowish clay till mixed with sand and pebbles. Deposits of loess (windblown glacial sediment) 

are also widespread throughout the County, but the deposits are thickest along the bluffs of the 

Missouri River to the south of the site (BCC 1996).

Glacial drift generally covers the eastern half of Boone County whereas residuum (weathered 

bedrock material) is the predominant bedrock cover over the western half of the County. This 

generally supports the overburden mapping information provided in the NWMI ER 

(NWMI 2015a). Specifically, the surficial geologic unit at the Discovery Ridge site is mapped as 

glacial drift (unit F). This unit is characterized as light tan to dark gray silty clay and clay till. 

The clay is mixed with pebbles of limestone, chert, and quartzite. Sands, cobbles, and boulders 

may occur in pockets, lenses, or as channel deposits. A layer of loess ranging from 1 to 5 ft. 

(0.3 to 1.5 m) thick typically covers the drift. A Clay-rich paleosol (i.e., a buried soil horizon) 

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, the total thickness of the drift and other overburden material in the vicinity of the Discovery 

Ridge site is approximately 25 ft (7.6 m) (MGS 2016).
Appendix A

A-28

Terracon, a consulting engineering firm, performed a preliminary geotechnical investigation of 

the Discovery Ridge Research Park in 2011, which encompassed the proposed site (i.e., Lot 15 

of the research park) (Terracon 2011a). The purpose of the investigation was to provide 

preliminary geotechnical recommendations concerning earthwork and the design and 

construction of foundations, floor slabs, and pavements for Discovery Ridge properties 

(NWMI 2015a). Terracon drilled nine boreholes (designated B-1through B-9) across the 

research park as part of the 2011 study. The borings were advanced to depths ranging from 13 

to 20 ft (3.9 to 6.1 m) below ground surface (bgs). Laboratory tests were also conducted on 

select samples, including soil density, compaction, plasticity, and liquid limit tests (NWMI 2015a; 

Terracon 2011a). All 25 boring samples measured were found to have relatively high water 

content, generally in the range of 18 up to 35 percent (Terracon 2011a). For the surveyed 

areas as a whole, the boring logs indicate the presence of lean to fat clay and fat clay in the

upper part and underlain by clay, trace sand, gravels, and cobbles representing glacial drift. 

Clay fill was encountered in the upper part of two borings completed at locations to the west of 

the Discovery Ridge site (i.e., borings B-3 and B-4 located west of Discovery Ridge Parkway). 

A single boring (designated B-5 in Terracon 2011a) drilled on the eastern boundary of Lot 15 is 

most representative of the proposed site. Table 3-6 summarizes information on the nature of 

the surficial materials obtained from this boring. 

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

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

As shown in Table 3–6, clays appear to comprise much of the surficial strata at the Discovery 

Ridge site. Fat clays include inorganic clay minerals of high plasticity. These materials 

characteristically have high compressibility, poor shear strength when wetted, and have 

generally poor workability as a construction material, including for use as structural (engineered) 

backfill (SCS 1990). Moreover, as indicated by Terracon and as referenced by NWMI in its ER, 

fat clays are termed expansive or swelling soils because they expand or swell with changes in 

moisture content (NWMI 2015a; Terracon 2011a). Such soils with a high shrink/swell potential 

can damage concrete and other structures with changes in moisture content and soil volume. 

Terracon determined that some of the soils encountered during drilling had moisture levels 
Appendix A

A-29

above their measured plastic limit. Such soils may be prone to rutting and pumping (rebound) 

when a load is applied, which results in unstable subgrade conditions during construction 

(Terracon 2011a). Nevertheless, Terracon made no determination about the liquefaction 

potential of these soil materials (NWMI 2015h). Weathered bedrock (identified as limestone) 

was encountered in only two borings (B-6 and B-7) at depths of approximately 17 and 13 ft bgs 

(5.1and 4.0 m) bgs, respectively. These boring sites are located approximately 1,000 ft (300 m)

south of the proposed NWMI facility site (Lot 15, Discovery Ridge site) and toward the shallow 

valley traversed by Gans Creek. While geotechnical investigations conducted to date have not 

determined the precise depth to or nature of bedrock beneath the proposed site, available 

mapping data indicate that the depth to bedrock is approximately 25 ft (7.6 m) (MGS 2016). 

Geologic mapping (Stoeser et al. 2007) reveals that rocks of the Cherokee Group of 

Pennsylvanian age (i.e., 299 to 318 Ma) immediately underlie the site. This is consistent with 

the geologic mapping provided in the NWMI ER (NWMI 2015a) and adapted as Figure 3-12"

The report indicates that "Burlington limestone is the principal limestone exposed in quarries, 

creek banks, and road cuts near and around Columbia. As referenced by NWMI (2015a), this 

limestone unit is relatively soluble and contains many caverns and passages indicative of karst 

terrane. Karst terrane is a landform underlain by soluble carbonate bedrock and characterized 

by the presence of springs, caves, and sinkholes."

We can conclude, as a building site, the soils are rated as poorly suited for excavation work 

because of the depth to the saturated zone, high clay content, and instability of excavation 

walls. In addition, due to the presence of clays with a high/shrink swell potential, as previously 

discussed in Section 3.3.1, the soils are rated as very limited for constructing commercial 

buildings. Shrink/well potential and the relatively shallow depth to the zone of saturation 

adversely affect the ability of soils to support structural loads (e.g., building slabs, foundations, 

and pavement structures) without movement and also affect the workability of site soils during 

construction (NRCS 2016a).

RESPONSE: The comment quotes portions of the EIS and expresses concern about the 

suitability of site soils for construction of the proposed NWMI facility. 

Sections 3.3.1 and 3.3.2 of this EIS describe the geologic and soil conditions, respectively, of 

the Discovery Ridge site. Section 4.3.1 describes the potential impacts of facility construction 

and operations on the geologic environment, including the implications of site soil conditions. 

As further discussed in Section 4.3.1, preliminary investigations of the site indicate that some 

site soils exhibit a high water content as well as possible expansive soils (high shrink/swell 

potential). During site development and facility construction, such soils may need to be 

excavated and replaced with suitable backfill to properly support site structures. 

As stated in Sections 4.3.1 and 4.4.2.1, NWMI plans to conduct site-specific geotechnical and 

hydrological studies of the Discovery Ridge site to characterize site conditions in support of its 

final facility design. In addition, as stated in NWMI’s latest responses to requests for additional 

information on NWMI’s Construction Permit Application (NWMI 2016b), site-specific studies will 

determine the final facility design. NWMI plans to conduct these studies in 2017. NWMI will 

need to submit this final facility design to the NRC for review and approval as part of a separate 

application for a license to operate the proposed NWMI facility. The results of the site-specific 

studies will be considered by the NRC staff as part of its environmental review of NWMI’s 

operating license application. 

No changes were made to the EIS as a result of this comment.

COMMENT: Area 8, Surface Drainage not Favorable for the Project: It is our opinion that the 

project and associated development in this portion of Discovery Park will have a negative 
Appendix A

A-30

impact on the environment, and will pollute not only Gans Creek, but other creeks and caves in 

the area. The report says that "The Discovery Ridge site currently drains south and southwest 

towards the southwesterly flowing Gans Creek, located approximately 0.35 mi (0.56 km) south 

of the site at its closest point (see Figures 3-11 and 3-13). Based on observations made by the 

NRC staff during the environmental site audit in September 2015, most site drainage occurs as 

overland sheet flow across the site with some drainage conveyed to ditches that border an 

access road associated with the future extension of Discovery Drive that would connect land 

parcels bordering the proposed site to the south. The NRC staff observed that these ditches 

convey runoff further southwest across Lot 9 of the Discovery Ridge Research Park via a 

meandering drainage way and toward an engineered drainage channel that parallels U.S. 

Highway 63. This channel ultimately discharges to Gans Creek south of the site. Topographic 

maps (USGS 2015a), historical photography, and other records reviewed by Terracon (2011a) 

indicate that at least some of these drainage features may mark the remnants of a headwater 

tributary to Gans Creek. Nevertheless, the engineered drainage channel receives runoff from 

surrounding parcels and drainage and overflow from an existing human-made lake (located to 

the northwest of the Discovery Ridge site and immediately adjacent to the existing IDEXX 

BioResearch facility), which serves as a stormwater management pond and has an associated 

drainage channel."

"Affected Environment - From just south of the site (Figure 3-13), Gans Creek flows beneath 

U.S. Highway 63 and continues west to southwesterly in a winding path for approximately 6 

stream mi (9.7 km) before joining Clear Creek. At this confluence, the Little Bonne Femme 

Creek begins. Little Bonne Femme Creek continues flowing southwesterly for some 9 mi 

(14 km) along a winding course before entering the Missouri River....The Bonne Femme 

watershed is situated on karst terrane as referenced in Section 3.3.1. Surface water hydrology 

is complex because of the presence of losing (sinking) and gaining sections of streams where 

surface water can easily enter the subsurface, providing flow to other streams. Karst streams, 

and underlying groundwater, are very susceptible to upgradient pollutant sources and 

contaminant transport. Within the watershed, there are two main recharge areas tied to these 

losing and gaining sections of stream, the Devil's Icebox cave and the Hunter's Cave recharge 

areas (Frueh 2007; NWMI 2015a). Carlson et al. (2005) states that Gans Creek is the first 

gaining stream due to surface water lost through the Devil's Icebox cave. Thus, the Bonne 

Femme and Little Bonne Femme creeks are interconnected where surface water lost from 

Bonne Femme Creek is lost through the Devil's Icebox Cave Branch (across the surface water 

divide) into Gans Creek and is eventually discharged to Little Bonne Femme Creek 

(Figure 3-13) (Frueh 2007; NWMI 2015a)."

Conclusion is that the project will have at least a moderate if not high impact on the environment 

when taking together with other projects planned for the watershed. All of the waterways are 

somewhat connected due to the Karst Topography.

Despite a clear indication to the contrary, "Based on the results of its preliminary geotechnical 

report and available geological mapping of the area, Terracon concluded that there are no 

known caves or sinkholes within approximately 1 mi (1.6 km) of the Discovery Ridge Research 

Park. Karst features are present to the west and southwest of the Discovery Ridge site, with the 

nearest sinkhole features lying approximately 1.3 mi (2.1 km) southwest (MGS 2016). However, 

changes in site conditions, such as grading and drainage alteration, can result in sinkholes even 

in areas with no history of sinkhole development (Terracon 2011a)".

COMMENT: Area 9, Effect on Water Quality: Within the State, all perennial rivers and streams, 

streams with permanent pools, and lakes and reservoirs that intersect the flow lines of perennial

rivers and streams are designated for the following beneficial uses: aquatic habitat protection; 

human health protection, whole body contact recreation, and secondary contact recreation; and 
Appendix A

A-31

livestock and wildlife protection and irrigation (10 CSR 20-7.031). These uses apply to Gans 

Creek and other major streams within a 5-mi (8-km) radius of the Discovery Ridge site. 

Furthermore, a 3 mi (4.8 km) section of Gans Creek is classified by the State as an Outstanding 

State Resource Water (10 CSR 20-7.031) and denoted as an environmentally sensitive area by 

Boone County (Boone County 2016a). Outstanding State resource waters are high-quality 

waters with a significant aesthetic, recreational, or scientific value and specifically designated as 

such by the State's Clean Water Commission. Such waters may require exceptionally stringent 

water quality management requirements to assure conformance with the State's antidegradation 

policy. This special segment of Gans Creek is located within the Rock Bridge State Park, 

located approximately 3 mi (4.8 km) southwest of the Discovery Ridge site (see Figure 3-13)....."

".....Of particular relevance to the 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 Devil's Icebox cave. Samples were collected at all sites 

once per quarter beginning in 2003. In addition to measurement of standard physical and water 

quality parameters, samples were analyzed for various herbicides and for the presence of 

bacterial contamination. In summary, general water quality parameters were found to be typical 

for streams in carbonate bedrock areas. Dissolved oxygen levels exceeded the State standard 

of 5 milligrams per liter (mg/L).

Nutrient levels were similar to or less than streams in other comparable agricultural watersheds, 

and there was no indication of acute contamination at any site. Although field observations and 

monitoring results revealed nuisance algal growth, no excess nutrient enrichment 

(eutrophication) was found at any site. One or more herbicides was detected at every site but 

generally at low levels. Widespread fecal bacterial contamination was evident, with the highest 

levels found during the spring and summer. The fecal bacteria standard for whole body contact 

was frequently exceeded. The primary cause of bacterial contamination at most sites was 

attributed to cattle grazing (Frueh 2007)."

"Downstream of the Discovery Ridge site, the surface water hydrology is rather complex as the 

watershed is founded on karst terrane. Due to the occurrence of soluble carbonate bedrock, 

karst features include the presence of losing (sinking) and gaining sections of streams where 

surface water can easily enter the subsurface, providing flow to other streams. These features 

make surface waters and underlying groundwater particular vulnerable to contamination.

Gans Creek and other streams within the Bonne Femme Creek watershed have been 

designated by the State for the following beneficial uses: aquatic habitat protection; human 

health protection, whole body contact recreation, and secondary contact recreation; as well as 

livestock and wildlife protection and irrigation. In addition, the State of Missouri has classified a 

3 mi (4.8 km) section of Gans Creek as an Outstanding State Resource Water. Boone County 

has also designated this section of stream and adjoining areas as an environmentally sensitive 

area and includes karst features such as Devil's Icebox Cave within Rock Bridge State Park

(see Section 3.4.1.2). An intensive study of the watershed conducted by Federal, State, and 

local stakeholder agencies (Frueh 2007) found water quality parameters to be typical for 

streams in carbonate bedrock areas and not seriously degraded from a hydrologic and water 

quality perspective."

Our position is to site projects as far from Gans Creek as possible to keep it as an outstanding 

water resource.

RESPONSE: The comments identified as Area 8 and Area 9 above, express concern about the 

favorability of the NWMI facility site within the watershed of Gans Creek including the potential 

for impacts on water quality within the watershed from site drainage and due to the location of 

karst features.
Appendix A

A-32

Regarding site selection, the NRC does not have a role in the planning decisions as to where a 

particular medical radioisotope production facility is proposed to be located (NRC 2012). In 

accordance with the National Environmental Policy Act of 1969 (NEPA), as amended 

(42 U.S.C. 4321 et seq.) and the NRC regulations implementing NEPA (10 CFR Part 51), the 

purpose of the EIS is to provide the public and the Commission with a description of potential 

environmental impacts associated with issuing a construction permit for the proposed facility, as 

well as to consider a range of reasonable alternatives to the proposed action. 

As first referenced in the comment in Area 8 and as described in Section 3.4.1 of the EIS, the 

proposed site within the Discovery Ridge Research Park is located within a portion of the Bonne 

Femme watershed that includes Gans Creek. The watershed is situated on karst terrane that 

includes characteristic features such as springs, caves, and sinkholes. As noted in the 

comments, one such feature is the Devil’s Icebox cave. This cave is located within Rock Bridge 

Memorial State Parkand approximately 3 mi (4.8 km) southwest of the Discovery Ridge site. 

The State of Missouri has designated the segment of Gans Creek that traverses the park as an 

Outstanding State Resource Water. 

However, and as previously referenced and shown in Figure 3–12 of the EIS, the proposed 

NWMI facility site lies near a geologic contact between bedrock predominantly consisting of 

shales and sandstones to the east and the limestone that comprises the karst terrane to the 

west and south. Further, no natural surface water features originate on the proposed Discovery 

Ridge site, and the site is located approximately 0.35 mi (0.56 km) north of Gans Creek at its 

closest point. No karst features have been identified on the proposed site; however, the NRC 

staff revised Section 3.3.1 of this final EIS to reflect the latest available information on karst 

features based on NWMI’s responses to the NRC staff requests for additional information. In 

addition, NWMI plans to conduct site-specific geotechnical and hydrological studies of the 

Discovery Ridge site to characterize site conditions in support of final facility design, to include 

an evaluation of the potential for sinkholes and any needed construction mitigation and facility 

design changes (NWMI 2016b). 

As detailed in Sections 4.4.1.1 and 4.4.1.2 of this EIS, surface water resources would not be 

directly impacted by site construction activities, and construction activities would be subject to 

Federal, State, and local requirements governing soil erosion and sediment transport and 

stormwater runoff control, as noted previously and detailed in Sections 4.3.1 and 4.4.1.1. 

During operations, there would be no discharge of wastewater other than sanitary wastewater 

from the proposed NWMI facility. There would be no liquid radioactive effluents released from 

the facility, and no uncontrolled stormwater runoff. Sanitary wastewater would be conveyed to 

the City of Columbia Sanitary Sewer Utility in accordance with an approval from the City of 

Columbia. Stormwater discharges would need to comply with the master stormwater 

management plan governing the Discovery Ridge Research Park and with City ordinances. 

Facility stormwater discharges may also be subject to State NPDES permit provisions for 

stormwater discharges associated with industrial activity.

As a result, the impacts on surface water hydrology, quality, and use from the construction of 

the proposed facility would be SMALL. No revisions were made to the EIS based on this 

comment.

COMMENT: Area 10: Affected Species: "The Bonne Femme Stakeholder Committee 

(BFSC 2007) determined that fish communities within the Bonne Femme watershed and nearby 

streams generally range from 11 to 17 species, and commonly include shiners, minnows, 

suckers, redhorse, sunfish, bass, darters and stonerollers. NWMI (2015c) observed creek chub 

{Semotilus atromaculatus) in small pools of Gans Creek on September 30 and October 1, 2015. 

Gans Creek was not flowing at the time of the observation. The NRC staff also searched 
Appendix A

A-33

FishNet (2014), which is a collaborative effort by the National Science Foundation, National 

Biological Information Infrastructure, and other natural history and biodiversity institutions to 

compile a database of fish survey results. FishNet (2014) contained records for two fish species 

within the vicinity of the proposed Discovery Ridge site. Small mouth bass (Micropterus

dolomieu) were collected from Little Bonne Femme Creek in October 1978. Smallmouth bass 

are relatively common within this watershed.

In March 1960, orangethroat darter (Etheostoma spectabile) were collected from the spring 

branch of Gans Creek. Orangethroat darter is endemic, or solely unique, to the Mississippi 

River basin and the Lake Erie basin: However, given the age of the data, it is not certain 

whether these species still occur within the Bonne Femme watershed.

Portions of Gans Creek are considered Fish Spawning Stream Reaches, which is one of 138 

State-designated fish spawning stream segments (MDC 2015). The State designates stream 

reaches as Fish Spawning Stream Reaches if they contain highly diverse fish communities, 

provide habitat for fish species of conservation concern, and if they are important to maintaining, 

restoring, or avoiding future listing of Species of Conservation Concern (MDC 2015).

Streams and other waterbodies within the Bonne Femme watershed also contain many 

invertebrates, such as mayflies, stoneflies, caddisflies, dragonflies, beetles, small crustaceans, 

and snails. BFSC (2007) determined that 18 to 27 invertebrate species are estimated to inhabit 

32 streams within the Bonne Femme Watershed."

COMMENT: Area 11: Endangered Species clearly located in the Action Area are not identified 

in the Report. The report says that "The implementing regulations for section 7(a)(2) of the ESA 

define "action area" as "all areas to be affected directly or indirectly by the Federal action and 

not merely the immediate area involved in the action." (50 CFR 402.02). The action area 

effectively bounds the analysis of ESA-protected species and habitats because only species 

that occur within the action area may be affected by the Federal action. For the purposes of the 

ESA analysis in this EIS, the NRC staff considers the action area to include the lands within the 

7.4 ac (3.0 ha) proposed site, the adjacent offsite area that would be used as a temporary

construction staging area, and the surrounding area where runoff drains and activities would be 

audible to wildlife. The NRC staff expects all direct and indirect effects of the proposed action to 

be contained within these areas. The NRC staff recognizes that while the action area is 

stationary, Federally listed species can move in and out of the action area. For instance, a 

flowering plant known to occur near, but outside, of the action area could appear within the 

action area over time if its seeds are carried into the action area by wind, water, or animals. 

Thus, in its analysis, the NRC staff considers not only those species known to occur directly 

within the action area, but those species that may passively or actively move into the action 

area. The staff then considers whether the life history of each species makes the species likely 

to move into the action area where it could be affected by the construction, operations, and 

decommissioning of the NWMI facility."

The report says that "The NRC staff compiled this table from the FWS's online database 

(FWS 2015a), correspondence and discussions with the FWS (FWS 2015a; NRC 2015e), and 

the NWMI ER (NWMI 2015a). As described in Section 3.5.3, NWMI conducted ecological 

surveys in the action area and did not observe any Federally protected species on the proposed 

site (NWMI 2015a). Based on the surveys described in Section 3.5.3, the NRC staff did not 

identify any Federally listed species that could exist in the action area. In addition, the NRC 

staff reviewed the habitat requirements for the Federally-listed species in Table 3-9. The NRC 

staff determined that the proposed site provides unsuitable habitat for all the Federally-listed 

species in Table 3-9. The NRC staff did not identify any candidate species or proposed or 

designated critical habitats within the action area. Given the available information, the NRC 
Appendix A

A-34

staff concludes that Federally listed, proposed, or candidate species are unlikely to occur within 

the action area."

State-listed Species: Table 3-9 includes the State-listed species that have the potential to occur 

on or near the proposed Discovery Ridge site. The NRC staff compiled this table from the 

MDC's description of State-listed species (MDC 2000a, 2000b, 2016b), MDC's Natural Heritage 

Review (2015 and 2016 [June 2 letter]) reports, and the NWMI ER (NWMI 2015a). As 

described in Section 3.5.3, NWMI conducted vegetation surveys in the action area and did not 

observe any State-protected species on the proposed site (NWMI 2015a). Furthermore, habitat 

to support State-listed species does not occur on site. Based on the surveys described in 

Section 3.5.3, the NRC staff did not identify any State-listed species that are likely to occur in 

the action area."

"In Section 3.5, the NRC staff concludes that no Federally listed species are likely to occur in 

the action area. The NRC staff also concludes that no candidate species, proposed species, or 

designated critical habitat occur in the action area. Thus, the NRC staff concludes that the 

proposed action would have no effect on Federally listed species or habitats under FWS's 

jurisdiction."

"The NRC staff reviewed the habitat requirements for the State-endangered species in 

Table 3-9. The NRC staff determined that the proposed site provides unsuitable habitat for all 

the State-endangered species. The Topeka shiner (Anguilla rostrate), which is State 

endangered, historically inhabited the watershed, but its occurrence has not been reported 

since 1997 (BFSC 2007). MDC's (MDC 2016e) natural heritage report did not identify any statelisted endangered species, state-ranked species, nor any natural communities within the project 

area. Because no State-listed species have the potential to exist within the proposed Discovery 

Ridge site, this EIS does not discuss State-listed species in any further detail."

We believe there are a number of rare and endangered species that are not discussed in the 

report or are not given any benefit of doubt; and therefore we believe there appeared to be no 

credible search for endangered species in this report. The topic appeared to be dismissed out 

of habit rather than truly reviewing the impacts on endangered species that frequent the Area. 

Our research and previous observations indicate that there is a high likelihood of the presence 

of endangered species in the Action area and that the project could have an impact on rare and 

endangered species in the area.

According to Rock Bridge State Park Officials, the "Devil's Icebox Cave has a total mapped 

passage distance of more than seven miles. Over the years, these spacious cave passages 

have become the home to especially adapted animals. The cave is the only known habitat for 

the pink planarian, a species of flatworm. The cave's watershed of several thousand acres 

contains hundreds of sinkholes as well as losing streams, which allow water to drain down 

cracks in the limestone rock and flow into the cave." The water's quality affects the pink 

planarian and other cave animals. There is a good chance that portions of the cave are in the 

action area. In the absence of checking all of the sinkholes, we must assume they are there. 

Species to mention include: Gray Bats frequent the devils ice-box cave on a seasonal basis.

There is a very high probability that this bat inhabits the caves clearly located in the action area 

of this project. Suggest referral to information on grey bats provided by Rock Bridge State Park. 

Note that the Devils Icebox Cave ranks in the top three of the largest caves in the state ("the 

Cave State") and maybe the world. There are a large number of unexplored passageways; that 

sometimes do not correspond to the presence of streams on the surface.

In season, I have observed a huge number of grey bats exiting Devils Icebox cave at dusk. 

Endangered gray bats use the cave as a summer roosting site to give birth to and raise their 
Appendix A

A-35

young. Each gray bat eats several hundred insects each night above ground and then deposits 

guano in the cave during the day and so plays an important role in two ecosystems.

Indiana Bats frequent the Area on a seasonal basis. Again, they could possibly be found on 

trees or caves in the action area affected by the project.

The Pink Planarian, a small worm found only in Devils Icebox cave was not mentioned in the 

report. There is a complete description of this endangered species found on the marque next to 

the Devils icebox cave.

The Cherry Stone Snail, located nearby at Three Creeks Conservation Area, and located only 

two places in the U.S., were also not mentioned in this report. Although it is likely not found in 

the action area.

The possible existence of the Topeka Shiner should not be dismissed off hand in the absence of 

legitimate studies. Topeka shiner thrives in pools of small prairies, and streams with good 

water, quality, and gravel. Streambeds. No true study was cited to determine that the species 

does not exist. They have most recently been found at Three Creeks Conservation Area. 

Therefore, we do not make a claim that the project will impact the Shiners; however, given the 

karst topography of the area and cross connections in various watersheds, some impacts 

cannot be dismissed.

RESPONSE: The preceding two comments identified by the commenter as Area 10 and 

Area 11 state that the EIS did not discuss the presence and potential impacts to ecological 

resources within nearby parks, including several rare, threatened, or endangered species in 

Rock Bridge Memorial State Park and in the Three Creeks Conservation Area. A description of 

the land use features and ecological resources within Rock Bridge Memorial State Park and 

Three Creeks Conservation Area is provided in Sections 3.1.1.3 and 3.5.2. In response to 

these comments, a discussion of ecological features within Rock Bridge Memorial State Park 

and Three Creeks Conservation Area, including Devil’s Icebox Cave, bats, the pink planarian 

(Macrocotyla glandulosa), the cherrystone snail (Hendersonia occulta), and the Topeka shiner 

(Anguilla rostrate) has been added to the final EIS.

The commenter also suggests that the proposed action could impact Rock Bridge Memorial 

State Park and the species that occur within the park. A discussion of potential impacts to Rock 

Bridge Memorial State Park, including Devil’s Icebox Cave, is provided in Sections 4.1.1 and 

4.5.1. As discussed in the EIS, an inadvertent release of pollutants could flow to nearby surface 

water or groundwater features, including Devil’s Icebox cave located within Rock Bridge 

Memorial State Park or other local parks and conservation areas. However, during operations, 

there would be no discharge of hazardous or radiological liquid effluent into any surface water or 

groundwater features from the proposed NWMI facility. In addition, as part of the permitting 

process with MDNR, NWMI would be required to have plans and procedures to address any 

inadvertent spills of chemical or petroleum products. Also, no ground disturbing activities would 

occur beyond the Discovery Ridge site. Therefore, impacts to ecological resources, including 

resources within Rock Bridge Memorial State Park and Three Creeks Conservation Area, would 

be SMALL.

No revisions were made to Chapter 4 based on this comment. 

Comment at public meeting from Tom Lata, Osage Group of the Sierra Club (ADAMS No.

ML16364A281)

COMMENT: I'm Tom Lata. I'm the vice chair of the Osage group of the Sierra Club, and I just 

want to voice a few concerns that we had. Basically, concerns that are involved in the 

development of -- at Discovery Ridge in general. And one thing that we're concerned about is 
Appendix A

A-36

the soils in the area are basically clay soil, so there's rapid runoff on the development of any 

building at the site. The cumulative impacts of runoff from the various buildings that are being 

constructed on the site run into Gans Creek watershed, which is a losing stream, and -- into the 

cave system of the Rock Bridge State Park. The cave is approximately -- as far as we know, it's 

almost a mile long, so it's -- there's a lot of different passageways, so there's a number of places 

where runoff and -- could get into the system. There are two or three endangered species, the 

Indiana bat the gray bat. There's a pink planarian, which is found only in Devil's Icebox, 

nowhere else in the world, so this could be a real problem. So, basically, we have no objection 

to the facility itself, but how it's being built could become problematic, particularly when that's 

accumulated with the other construction activities that are going on. I might also mention 

there's other caves that are much closer to the Devil's Icebox in this area. There's a cave called 

Elbow Cave, which is maybe a mile, mile and a half from the site, so it's -- which is -- it's actually 

in the city's new Gans Creek Recreation area. I think those are our main concerns. Also, we're 

concerned -- it's mostly clay soil in the area, so runoff is rapid and makes it into the cave quickly.

RESPONSE: This comment expresses two concerns which are more thoroughly discussed in 

the commenter’s written comments provided and addressed earlier in this Section A.2.1. The 

first concern expressed in this comment is the potential impact from runoff from the proposed 

construction site. This concern is more thoroughly discussed in the comments labelled by the 

commenter as Area 8 and Area 9. These comments and the NRC staff responses to them are 

found on pages A-28 through A-31. The second concern expressed in this comment focuses on 

ecological resources and is more thoroughly discussed in the comments labelled by the 

commenter as Area 10 and Area 11. These comments and the NRC staff responses to them 

are found on pages A-31 through A-32.

A.3 References

80 FR 72115. U.S. Nuclear Regulatory Commission. “Northwest Medical Isotopes, LLC- intent 

to conduct scoping process and prepare an environmental impact statement; public meeting 

and request for comment.” Federal Register 80(222): 72115–72117. November 18, 2015.

7 CFR Part 657. Code of Federal Regulations, Title 7, Agriculture, Part 657, “Important 

farmlands inventory.”

7 CFR Part 658. Code of Federal Regulations, Title 7, Agriculture, Part 658, “Farmland 

protection policy act.

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

protection against radiation.”

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

production and utilization facilities.”

10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and 

transportation of radioactive material.”

49 FR 9375. U.S. Nuclear Regulatory Commission. “Environmental Protection Regulations for 

Domestic Licensing and Related Regulatory Functions and Related Conforming Amendments.” 

Federal Register Notice 49(49): 99352–9406. March 12, 1984.

American Medical Isotopes Production Act of 2012. 42 U.S.C. §2065 et seq.

Atomic Energy Act of 1954, as amended. 42 U.S.C. §2011 et seq.

Farmland Protection Policy Act of 1981. 7 U.S.C. §4201 et seq.

National Environmental Policy Act of 1969, as amended. 42 U.S.C. §4321 et seq.
Appendix A

A-37

National Historic Preservation Act of 1966. 54 U.S.C. §300101 et seq.

Resource Conservation and Recovery Act of 1976. 42 U.S.C. §6901 et seq.

[NRC] U.S. Nuclear Regulatory Commission. 2012. Final Interim Staff Guidance Augmenting 

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

Non-Power Reactors: Format and Content,” and Part 2, “Guidelines for Preparing and 

Reviewing Applications for the Licensing of Non-Power Reactors: Standard Review Plan and 

Acceptance Criteria,” for Licensing Radioisotope Production Facilities and Aqueous 

Homogeneous Reactors. Washington, DC: NRC. October 17, 2012. ADAMS

Nos. ML12156A069 and ML12156A075.

[NRC] U.S. Nuclear Regulatory Commission. 2015a. Official Transcript Proceedings, Public 

Scoping Meeting for Northwest Medical Isotopes, LLC. December 8, 2015. ADAMS 

No. ML15356A133.

[NRC] U.S. Nuclear Regulatory Commission. 2015b. Request for Scoping Comments 

Concerning the Northwest Medical Isotopes, LLC Radioisotope Production Facility Application 

Review. ADAMS No. ML15308A362.

[NRC] U.S. Nuclear Regulatory Commission. 2016. “Summary of the Public Scoping Meeting 

Conducted Related to the Review of the Proposed Northwest Medical Isotopes, LLC 

Radioisotope Production Facility.” Washington, DC: NRC. January 20, 2015. ADAMS 

No. ML15356A096.

[NWMI] Northwest Medical Isotopes, LLC. 2015. Preliminary Safety Analysis Report (PSAR), 

Chapter 9 “Auxiliary Systems,” Chapter 10, “Experimental Facilities” Chapter 11, “Radiation 

Protection and Waste Management ” and Chapter 12, “Conduct of Operations .” June 2015. 

ADAMS No. ML15210A118.

[NWMI] Northwest Medical Isotopes, LLC. 2016a. Northwest Medical Isotopes, LLC Response 

to the U.S. Nuclear Regulatory Commission Request for Additional Information–Letter Dated 

January 19, 2016. ADAMS No. ML16053A221.

[NWMI] Northwest Medical Isotopes, LLC. 2016b. Northwest Medical Isotopes, LLC 

Responses to the U.S. Nuclear Regulatory Commission Regarding the Preliminary Safety 

Analysis Report Request for Additional Information (Letter dated September 29, 2016). ADAMS 

No. ML16344A049.

APPLICABLE LAWS, REGULATIONS, AND OTHER REQUIREMENTS

B-1

B. APPLICABLE LAWS, REGULATIONS, AND OTHER

REQUIREMENTS

A number of Federal laws and regulations affect environmental protection, health, safety, 

compliance, and consultation at U.S. Nuclear Regulatory Commission (NRC)-licensed facilities. 

Certain Federal environmental requirements have been delegated to State authorities for 

enforcement and implementation. Furthermore, States have enacted laws to protect public 

health and safety and the environment. It is the NRC’s policy to ensure that NRC-licensed 

facilities are operated in a manner that provides adequate protection of the public health and 

safety and of the environment through compliance with applicable Federal and State laws, 

regulations, and other requirements.

The requirements that may be applicable to the operation of NRC-licensed facilities encompass 

a broad range of Federal and State laws and regulations that address environmental, historical 

and cultural, health and safety, transportation, and other concerns. Generally, these laws and 

regulations relate to how a facility would conduct the work involved in performing a proposed 

action to protect workers, the public, and environmental resources. Some of these laws and 

regulations require permits or consultation with other Federal agencies or State, Tribal, or local 

governments.

The Atomic Energy Act of 1954, as amended (AEA) (42 U.S.C. 2011 et seq.), authorizes any 

State to enter into agreement with the NRC to assume regulatory authority for certain activities 

(42 U.S.C. 2021). Missouri is a non-agreement state; thus, the NRC has regulatory 

responsibility over the byproduct, source, and special nuclear materials in the State.

State legislatures develop their own laws. State statutes supplement, as well as implement, 

Federal laws for the protection of air, water quality, and groundwater. State legislation may 

address solid waste management programs, locally rare or endangered species, and historical 

and cultural resources.

The Federal Water Pollution Control Act (i.e., Clean Water Act of 1972, as amended (CWA) 

(33 U.S.C. 1251 et seq.)) allows for primary enforcement and administration through State 

agencies, as long as the State program is at least as stringent as the Federal program. The 

State program must conform to the CWA and to the delegation of authority for the Federal 

National Pollutant Discharge Elimination System (NPDES) program from the 

U.S. Environmental Protection Agency (EPA) to the State. The primary mechanism to control 

water pollution is the requirement for direct dischargers to obtain an NPDES permit or a State 

Pollutant Discharge Elimination System permit, when the authority has been delegated from the 

EPA to the State, under the CWA, as is the case for Missouri. 

One important difference between Federal regulations and certain State regulations is the 

definition of waters regulated by the State. Certain State regulations may include underground 

waters, whereas the CWA only regulates surface waters. 

B.1 Federal, State, and Local Requirements

Construction and operation of the Northwest Medical Isotopes, LLC (NWMI) radioisotope

production facility (NWMI facility) would be subject to Federal, State, and local requirements. 

Tables B–1, B–2, and B–3 identify the principal Federal, State, County, and city environmental 

regulatory requirements that may be applicable to the proposed NWMI facility. Along with each 

regulatory requirement is a brief description. The requirements are organized into categories, 

such as general requirements, water resources, and pollution prevention.
Appendix B

B-2

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, as amended, 

42 U.S.C. 5801 et seq.

The Atomic Energy Act of 1954, as amended (AEA), and the Energy 

Reorganization Act of 1974, as amended, give the NRC the licensing and 

regulatory authority for nuclear technology 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 Acts 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 requirements 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 may 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.
Appendix B

B-4

Statute/Regulation/Order Description

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.

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 Commission is committed to the general goals of E.O. [Executive 

Order] 12898, and strives to meet those goals as part of its NEPA review 

process.”

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.
Appendix B

B-5

Statute/Regulation/Order Description

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 agency actions that 

may affect listed species or designated critical habitats.

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 agency 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 

each Federal agency with jurisdiction over properties or facilities engaged 

in any activity that may result in the discharge or runoff of pollutants to 

surface waters to comply with all 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 waters of the United States. 

The NPDES program requires all facilities that discharge pollutants from 

any point source into waters of the United States 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 waters of the United States. 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 may

result in a discharge to waters of the State, 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 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 Rivers 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.

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.

Potentially Applicable 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. 

B.2 Operating Permits and Other Requirements

Table B–4 lists the permits and licenses that NWMI plans to obtain from Federal, State, and 

local authorities to construct and operate the NWMI facility.

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

Byproduct 

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 

application for a license 

to receive and possess

and the operating 

license application

EPA CWA, 40 CFR Part 112, 

Subpart D, Appendix F

Spill Prevention, 

Control, and 

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.

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

B.3 References

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

protection against radiation.”

10 CFR Part 30. Code of Federal Regulations, Title 10, Energy, Part 30, “Rules of general 

applicability to domestic licensing of byproduct material.”

10 CFR Part 40. Code of Federal Regulations, Title 10, Energy, Part 40, “Domestic licensing of 

source material.”

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

production and utilization facilities.”
Appendix B

B-13

10 CFR Part 70. Code of Federal Regulations, Title 10, Energy, Part 70, “Domestic licensing of 

special nuclear material.”

14 CFR Part 77. Code of Federal Regulations, Title 14, Aeronautics and Space, Part 77, “Safe, 

efficient use, and preservation of the navigable airspace.”

29 CFR Part 1910. Code of Federal Regulations, Title 29, Labor, Part 1910, “Occupational 

safety and health standards.”

29 CFR Part 1960. Code of Federal Regulations, Title 29, Labor, Part 1960, “Basic program 

elements for federal employee occupational safety and health programs and related matters.”

33 CFR Part 320. Code of Federal Regulations, Title 33, Navigation and Navigable Waters, 

Part 320, “General regulatory policies.”

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

Part 800, “Protection of historic properties.”

40 CFR Part 50. Code of Federal Regulations, Title 40, Protection of Environment, Part 50, 

“National primary and secondary ambient air quality standards.”

40 CFR Part 112. Code of Federal Regulations, Title 40, Protection of Environment, Part 112, 

“Oil pollution prevention.”

40 CFR Part 122. Code of Federal Regulations, Title 40, Protection of Environment, Part 122, 

“EPA administered permit programs: The National Pollutant Discharge Elimination System.”

40 CFR Part 260. Code of Federal Regulations, Title 40, Protection of Environment, Part 260, 

“Hazardous Waste Management System: General.”

49 CFR Part 107. Code of Federal Regulations, Title 49, Transportation, Part 107, “Hazardous 

materials program procedures.”

59 FR 7629. Executive Order No. 12898. “Federal Actions to Address Environmental Justice in 

Minority Populations and Low-Income Populations.” Federal Register 59(32): 7629–7633. 

February 16, 1994.

60 FR 6381. Executive Order No. 12948. “Amendment to Executive Order No. 12898.” 

Federal Register 60(21):6381. February 1, 1995.

62 FR 19885. Executive Order No. 13045. “Protection of Children from Environmental Health 

Risks and Safety Risks.” Federal Register 62(78):19885–19888. April 21, 1997.

69 FR 52040. U.S. Nuclear Regulatory Commission. “Policy Statement on the Treatment of 

Environmental Justice Matters in NRC Regulatory and Licensing Actions.” Federal 

Register 69(163):52040–52048. August 24, 2004.

Atomic Energy Act of 1954, as amended. 42 U.S.C. §2011 et seq.

Clean Air Act of 1970, as amended. 42 U.S.C. §7401 et seq.

Clean Water Act of 1972, as amended. 33 U.S.C. §1251 et seq.

Coastal Zone Management Act of 1972, as amended. 16 U.S.C. §1451 et seq.

Endangered Species Act of 1973, as amended. 16 U.S.C. §1531 et seq.

Energy Reorganization Act of 1974, as amended. 42 U.S.C. §5801 et seq.

Farmland Protection Policy Act of 1981. 7 U.S.C. §4201 et seq.

Fish and Wildlife Coordination Act of 1934, as amended. 16 U.S.C. §661 et seq.
Appendix B

B-14

Hazardous Material Transportation Act of 1975, as amended. 49 U.S.C. §5101 et seq.

Magnuson–Stevens Fishery Conservation and Management Act, as amended. 

16 U.S.C. §1801 et seq.

National Environmental Policy Act of 1969, as amended. 42 U.S.C. §4321 et seq.

National Historic Preservation Act of 1966, as amended. 54 U.S.C. §300101 et seq.

Noise Control Act of 1972, as amended. 42 U.S.C. §4901 et seq.

[NWMI] Northwest Medical Isotopes, LLC. 2015. Preliminary Safety Analysis Report (PSAR), 

Chapter 19, “Environmental Report.” Corvallis, OR: NWMI. January 2015. ADAMS 

Nos. ML15210A123, ML15210A128, ML15210A129, and ML15210A131.

Occupational Safety and Health Act of 1970, as amended. 29 U.S.C. §651 et seq.

Pollution Prevention Act of 1990. 42 U.S.C. §13101 et seq.

Resource Conservation and Recovery Act of 1976, as amended. 42 U.S.C. §6901 et seq.

Wild and Scenic Rivers Act, as amended. 16 U.S.C. §1271 et seq.
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 submitter.

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.

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

November 1, 2016 Availability of the Draft Environmental Impact Statement 

for the Construction Permit for the Proposed NWMI 

Medical Radioisotope Production Facility, and the U.S. 

Nuclear Regulatory Commission’s Determination that the 

Proposed Action Would Have No Effect on Federally 

Listed or Proposed Species or Critical Habitats

ML16272A294

November 4, 2016 NRC Letter to Tribal Nations, Request for DEIS 

Comments

ML16295A129

November 7, 2016 NRC Letter State to Historic Preservation Office,

Missouri Department of Natural Resources, Request for 

DEIS Comments

ML16293A881

November 7, 2016 NRC Letter to Advisory Council on Historic Preservation,

Request for DEIS Comments

ML16294A135

November 9, 2016 Email from Jon Hendricks providing comments on the 

draft EIS

ML17003A271

November 9, 2016 Email from George Deatz providing comments on the 

draft EIS

ML16351A189

November 20, 2016 Caddo Nation of Oklahoma email to NRC ML16327A556

November 23, 2016 State Historic Preservation Office, Missouri Department 

of Natural Resources Letter to NRC

ML16356A320

December 1, 2016 DOI Comments of the Draft EIS ML17003A270

December 8, 2016 Muscogee (Creek) Nation email to NRC ML16347A317

December 22, 2016 U.S. EPA Region 7 Letter to NRC transmitting EPA 

comments on NWMI DEIS

ML17005A276

December 23, 2016 Letter providing comments on the draft EIS from Mr. 

Steve Mattmuller, Kettering Medical Center

ML16364A011

December 27, 2016 Letter providing comments on the draft EIS from Mr. Tom 

Lata, Vice President of the Osage Group of the Sierra 

Club

ML16364A012

January 12, 2017 Osage Nation Letter to NRC ML17054D472

January 17, 2017 Tribal correspondence to NRC* ML17025A214

CONSULTATION CORRESPONDENCE

D-1

D. CONSULTATION CORRESPONDENCE

D.1 ESA Section 7 Consultation

Federal Agency Obligations Under ESA Section 7

As a Federal agency, the U.S. Nuclear Regulatory Commission (NRC) must comply with the 

Endangered Species Act of 1973 (ESA), as amended (16 U.S.C. 1531 et seq.), as part of any 

action authorized, funded, or carried out by the agency, such as the proposed agency action 

that this environmental impact statement (EIS) evaluates: whether to issue a construction 

permit under 10 CFR Part 50 that would allow construction of a medical radioisotope production 

facility. Under section 7 of the ESA, the NRC must consult with the U.S. Fish and Wildlife 

Service (FWS) and the National Marine Fisheries Service (NMFS) (referred to jointly as “the 

Services” and individually as “Service”), as appropriate, to ensure that the proposed agency 

action is not likely to jeopardize the continued existence of any endangered or threatened 

species or result in the destruction or adverse modification of designated critical habitat.

The ESA and the regulations that implement ESA section 7, 50 CFR Part 402, “Interagency 

cooperation—Endangered Species Act of 1973, as amended,” describe the consultation 

process that Federal agencies must follow in support of agency actions. As part of this process, 

the Federal agency shall either request that the Services provide a list of any listed or proposed 

species or designated or proposed critical habitats that may be present in the action area or 

request that the Services concur with a list of species and critical habitats that the Federal 

agency has created (50 CFR 402.12(c)). If it is determined that any such species or critical 

habitats may be present, the Federal agency is to prepare a biological assessment to evaluate 

the potential effects of the action and determine whether the species or critical habitat are likely 

to be adversely affected by the action (50 CFR 402.12(a); 16 U.S.C. 1536(c)). Furthermore, 

biological assessments are required for any agency action that is a “major construction activity” 

(50 CFR 402.12(b)), which the ESA regulations define to include major Federal actions 

significantly affecting the quality of the human environment under the National Environmental 

Policy Act of 1969, as amended (42 U.S.C. 4321 et seq.; herein referred to as NEPA)

(50 CFR 402.02).

Federal agencies may fulfill their obligations to consult with the Services under ESA section 7 

and to prepare a biological assessment in conjunction with the interagency cooperation 

procedures required by other statutes, including NEPA (50 CFR 402.06(a)). In such cases, the 

Federal agency should include the results of the ESA section 7 consultation in the NEPA 

document (50 CFR 402.06(b)). Accordingly, Section D.1.2 describes the biological assessment 

prepared for the proposed agency action evaluated in this EIS, and Section D.1.3 describes the 

chronology and results of the ESA section 7 consultation.

Biological Assessment

The NRC considers this EIS to fulfill its obligation to prepare a biological assessment under ESA

section 7. Accordingly, the NRC did not prepare a separate biological assessment for the 

proposed NWMI facility construction permit.

Although the contents of a biological assessment are at the discretion of the Federal agency 

(50 CFR 402.12(f)), the ESA regulations suggest information that agencies may consider for 

inclusion. The NRC has considered this information in the following EIS sections.
Appendix D

D-2

Section 3.5 describes the action area and the Federally listed and proposed species and 

designated and proposed critical habitat that have the potential to be present in the action area. 

This section includes information pursuant to 50 CFR 402.12(f)(1), (2), and (3).

Section 4.5 provides an assessment of the potential effects of the proposed construction, 

operations, and decommissioning of the NWMI facility on the species and critical habitat present 

and the NRC’s effect determinations, which are consistent with those identified in Section 3.5 of 

the Endangered Species Consultation Handbook (FWS and NMFS 1998). The NRC also 

addresses cumulative effects and alternatives to the proposed action. This section includes 

information under 50 CFR 402.12(f)(4) and (5).

Chronology of ESA Section 7 Consultation

Upon receipt of NWMI’s construction permit application, the NRC staff considered whether any 

Federally listed, proposed, or candidate species or designated or proposed critical habitats may 

be present in the action area (as defined at 50 CFR 402.02) for the proposed construction, 

operations, and decommissioning of the NWMI facility. No species under the NMFS’s 

jurisdiction occur within the action area. Therefore, the NRC staff did not consult with the 

NMFS. With respect to species under the FWS’s jurisdiction, the NRC staff requested 

information from FWS on Federally listed, proposed, and candidate species and critical habitat

that may be in the vicinity of the NWMI site and the one alternative site, in accordance with the 

ESA section 7 regulations at 50 CFR 402.12(c). The NRC staff requested this information 

through the FWS’s Information for Planning and Conservation (IPaC) database system 

(FWS 2015a, 2016). Based on this inquiry, the FWS provided a letter dated 

November 20, 2015, which identified threatened, endangered, proposed, and candidate 

species, as well as proposed and final designated critical habitat, that may occur within the 

proposed Discovery Ridge site and/or may be affected by the proposed NWMI facility. In 

addition, the NRC staff called FWS to confirm the accuracy of the species list, as suggested in 

the November 20, 2015, letter (NRC 2015e). During that call, FWS stated that it did not have 

any additional comments regarding the project other than those stated in its November 20, 2015 

letter (NRC 2015e). In Section 3.5, the NRC staff concludes that no ESA-listed, proposed, or 

candidate species or designated or proposed critical habitats are likely to occur in the action 

area; and Section 4.5 concludes that the proposed action would have no effect on any 

ESA-listed, proposed, or candidate species or designated or proposed critical habitats. The 

FWS (2013) is not required to provide its concurrence with “no effect” determinations by Federal 

agencies. Thus, the ESA does not require further informal consultation or the initiation of formal 

consultation with the FWS for the proposed NWMI construction permit. Nonetheless, FWS 

(2013) states that an agency may request written concurrence from the Services for a “no 

effect” determination. Following this best practice, the NRC staff submitted a copy of the draft

EIS to the FWS for its review in a letter dated November 1, 2016. In response, the 

U.S. Department of the Interior (DOI) Office of Environmental Policy and Compliance stated that 

the DOI has no comments on the draft EIS. Accordingly, the NRC has fulfilled its obligations 

under ESA section 7 for the review of NWMI’s construction permit.

Table D–1 lists the letters, e-mails, and other correspondence related to the NRC’s ESA

obligations with respect to its review of the NWMI construction permit application. 
Appendix D

D-3

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

April 15, 2016 List of ESA-protected species that may occur within the 

University of Missouri Research Reactor alternative site

ML16117A529

November 1, 2016 Availability of the Draft Environmental Impact Statement 

for the Construction Permit for the Proposed NWMI 

Medical Radioisotope Production Facility, and the U.S. 

Nuclear Regulatory Commission’s Determination that the 

Proposed Action Would Have No Effect on Federally 

Listed or Proposed Species or Critical Habitats

ML16272A294

December 1, 2016 DOI Comments of the Draft EIS ML17003A270

(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/.

D.2 Essential Fish Habitat Consultation

The NRC must comply with the Magnuson–Stevens Fishery Conservation and Management 

Act, as amended (MSA) (16 U.S.C. 1801 et seq.), for any actions authorized, funded, or 

undertaken, or proposed to be authorized, funded, or undertaken that may adversely affect any 

essential fish habitat identified under the MSA.

In Section 3.5 of this EIS, the NRC staff concludes that NMFS has not designated essential fish 

habitat under the MSA within the vicinity of the proposed Discovery Ridge site and that the 

proposed NWMI construction permit would have no effect on essential fish habitat. Thus, the 

MSA does not require the NRC to consult with NMFS regarding essential fish habitat for the 

NWMI construction permit.

D.3 NHPA Section 106 Consultation

National Historic Preservation Act of 1966 Consultation

The National Historic Preservation Act of 1966, as amended (NHPA) (54 U.S.C. 300101 

et seq.), requires Federal agencies to consider the effects of their undertakings on historic 

properties and consult with applicable State and Federal agencies, Tribal groups, and 

individuals and organizations with a demonstrated interest in the undertaking before taking 

action. Historic properties are defined as resources eligible for listing on the National Register 

of Historic Places. The historic preservation review process (Section 106 of the NHPA) is 

outlined in regulations issued by the Advisory Council on Historic Preservation (ACHP) in 

36 CFR Part 800. In accordance with 36 CFR 800.8(c), the NRC has indicated its intent to 

comply with Section 106 through the NEPA process.

Table D–2 lists the chronology of consultations and consultation documents related to the NRC 

Section 106 review.
Appendix D

D-4

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

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
Appendix D

D-5

Date Description ADAMS No.(a)

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

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
Appendix D

D-6

Date Description ADAMS No.(a)

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

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
Appendix D

D-7 

Date Description ADAMS No.(a)

November 4, 2016 NRC Letter to Tribal Nations, Request for DEIS 

Comments

ML16295A129

November 7, 2016 NRC Letter to State Historic Preservation Office, Missouri 

Department of Natural Resources, Request for DEIS 

Comments

ML16293A881

November 7, 2016 NRC Letter to Advisory Council on Historic Preservation,

Request for DEIS Comments

ML16294A135

November 20, 2016 Caddo Nation of Oklahoma email to NRC ML16327A556

November 23, 2016 State Historic Preservation Office, Missouri Department of 

Natural Resources Letter to NRC

ML16356A320

December 8, 2016 Muscogee (Creek) Nation email to NRC ML16347A317

January 12, 2017 Osage Nation Letter to NRC ML17054D472

January 17, 2017 Tribal correspondence to NRC* ML17025A214

(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.

D.4 References

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

production and utilization facilities.”

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

Part 800, “Protection of historic properties.”

50 CFR Part 402. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 402, 

“Interagency cooperation—Endangered Species Act of 1973, as amended.”

[ESA] Endangered Species Act of 1973, as amended. 16 U.S.C. §1531 et seq. 

[FWS] U.S. Fish and Wildlife Service. 2013. “Endangered Species Program: What We Do: 

Consultations: Frequently Asked Questions.” July 15, 2013. Available at 

<http://www.fws.gov/endangered/what-we-do/faq.html#8> (accessed 24 April 2016).

[FWS] Fish and Wildlife Service. 2015. Letter from A. Salveter, FWS, to NRC, Subject: List of 

threatened and endangered species that may occur in your proposed project location, and/or 

may be affected by your proposed project. Consultation Code: 03E14000-2016-SLI-0314. 

November 20, 2015. ADAMS No. ML15335A002.

[FWS] Fish and Wildlife Service. 2016. Information for Planning and Conservation (IPaC) 

Report for Boone County, Missouri Project. ADAMS No. ML16117A529. 

[FWS and NMFS] U.S. Fish and Wildlife Service and National Marine Fisheries Service. 1998. 

Endangered Species Consultation Handbook: Procedures for Conducting Consultation and 

Conference Activities Under Section 7 of the Endangered Species Ac. March 1998. 315 p. 

Available at <http://www.fws.gov/endangered/esa-library/pdf/esa_section7_handbook.pdf>

(accessed 24 April 2016).
Appendix D

D-8

[MSA] Magnuson–Stevens Fishery Conservation and Management Act, as amended. 

16 U.S.C. §1801 et seq.

[NEPA] National Environmental Policy Act of 1969, as amended. 42 U.S.C. §4321 et seq.

[NRC] U.S. Nuclear Regulatory Commission. 2015. Teleconference Summary with M. Moser, 

NRC, and A. Salveter, FWS. Subject: Scoping Comments Regarding the Environmental 

Review for the Northwest Medical Isotopes, LLC (NWMI) Construction Permit Application. 

December 3, 2015. ADAMS No. ML15362A225. 

[NHPA] National Historic Preservation Act of 1966, as amended. 54 U.S.C. §300101 et seq.




NUREG-2209

Final

Environmental Impact Statement for the Construction Permit for the Northwest 

Medical Isotopes Radioisotope Production Facility