ML16053A205

Northwest Medical Isotopes, LLC - NWMI-2016-RAI-001, Rev. 0, Response to NRC Request for Additional Information, Round 2, Environmental Review of Construction Permit Application

ML16053A205
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Site:	Northwest Medical Isotopes
Issue date:	02/29/2016
From:	Haass C Northwest Medical Isotopes
To:	Office of Nuclear Reactor Regulation
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ML16053A221	List: ML16053A204 ML16053A205 ML16053A206 ML16053A207 ML16053A208 ML16053A209 ML16053A210 ML16053A211 ML16053A212
References
NWMI-LTR-2016-002 NWMI-2016-RAI-001, Rev. 0
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ElCAL SOAOPES

-,..NORTHWEST ME ATTACHMENT 3 Northwest Medical Isotopes, LLC Response to the U.S. Nuclear Regulatory Commission Request for Additional Information, Round 2 Environmental Review of the Northwest Medical Isotopes, LLC Construction Permit Application (Document No. NWMI-2016-RAI-001, February 2016)

Public Version Informnationz is being provided via hard copy

o.0 0 NWM I

00. 0 S0 *O 0 0 0 NORTHWEST MEDICAL iSOTOPES Response to the U.S. Nuclear Regulatory Commission Request for Additional Information, Round 2 Environmental Review of the Northwest Medical Isotopes, LLC Construction Permit Application NWMI-2016-RAI-001, Rev. 0 February 2016 Prepared by:

Northwest Medical Isotopes, LLC 815 NW 9 th Ave, Suite 256 Corvallis, OR 97330

This page intentionally left blank.

Response to the U.S. Nuclear Regulatory Commission Request for Additional Information, Round 2 Environmental Review of the Northwest Medical Isotopes, LLC Construction Permit Application NWMI-201 6-RAI-O01, Rev. 0 Date Published:

February 17, 2016

Title:

Response tO the U.S. Nuclear Regulatory Commission Request for Additional Information, Round 2 - Environmental Review of the Northwest Medical Isotopes, LLC Construction Permit Application Approved by. Carolyn Haass Signature: C M* '4 *- -

NVVMI-2016-RAI-001, Rev. 0

• .".I;NW MI!

REVISION HISTORY Rev Date Reason for Revision Revised By 0 2/17/2015 Issued for Submittal to the NRC N/A

+

• NWMI-2016-RAI-001, Rev. 0 NWMI TERMS Acronyms and Abbreviations

• Mo maflybdenum-99 235UJ uranium-235 ADUN aci,d-deficient uranyl nitrate ALARA as [ow as reasonably achievable CEQA Cal.lifomnia Environmental Quality Act CFR Co,de of Federal Regulations CO car rbon monoxide CO2 car rbon dioxide Discovery Ridge Di~scovery Ridge Research Park EPAU. S.Environmental Protection Agency ER En'.vironmental Review GIS ge( ographic information systems H2 hay drogen gas HEPA hi8 ;h-efficiency particulate air H1N0 3 flit nce acid HVAC he."ating, ventilation, and air conditioning ISG Int erim Staff Guidance LEU loyv¢-enriched uranium MDNR Mi ssouri Department of Natural Resources M1HA ma tximum hypothetical accident MINRC Mc,Clellan Nuclear Research Center MURR Un fiversity of Missouri Research Reactor N2 0 nit rous oxide NO2 nit rogen dioxide NO* nit r'ogen oxides NRC U S.Nuclear Regulatory Commission NWMI No*rthwest Medical Isotopes, LLC 02 ox,ygen 0STR Or,egon State University TRIGA Reactor PSAR preflirninary safety analysis report RAI req tuest for additional information RCRA Re,source Conservation and Recovery Act RPF Ra,,dioisotope Production Facility SNM spc,cial nuclear material SO2 sullfur dioxide TEDE tot al effective dose equivalent Terracon Te:rracon Consultants, Inc.

U.S. Un fited States U.S.C. Unfited States Code UC Unfiversity of Califomnia USGSU. S.Geological Survey

NWMI-2016-RAI-001, Rev. 0 Units bgs below ground surface Ci curie cm centim~ter dBA A-weighted decibel ft feet g gram gal gallon ha hectare hr hour in. inch kg kilogram km kilometer km2 square kilometer L liter m meter m2 square meter m3 cubic meter mi mile mi2 square mile mR milliroentgen mrem millirem mSv millisievert t tonne (metric) wt% weight percent yd 3 cubic yard yr year ii

NWMI-2016-RAI-001, Rev. 0 NWVMI a - a *gg * - a - a The peak workforce identified in Table 19-6 of NWMI-20 13-021, ConstructionPermit Applicationfor Radioisotope ProductionFacility, is assumed to be 82 during construction, with an average workforce assumed to be 38. By estimating the mileage for 100 vehicles (Table 19-56), the calculation bounded any potential emissions, including those by other service providers (e.g.. for routine deliveries).

The current Northwest Medical Isotopes, LLC (NWMI) Radioisotope Production Facility (RPF) production process steps do not produce significant quantities of sulfur dioxide (SO 2) or carbon dioxide (CO 2) that contribute to facility emissions. However, small quantities of nitrogen oxides (NOx) are evolved during the dissolution of low-enriched uranium (LEU) oxide from irradiated targets in the target dissolution process system and dissolution of fresh LEU metal receipts in the target fabrication process system.

Irradiated target material dissolution is based on reaction stoichiometry within the dissolver vessel.

Equation 1

[Proprietary Information]

The dissolver vessel condenser returns water vapor to the dissolver during operation, along with nitric acid from partial absorption of the nitrogen dioxide (NO 2), to produce the overall reaction shown as Equation 2 that defines NOx entering the subsequent dissolver offgas treatment process elements.

Equation 2

[Proprietary Information]

The annual irradiated target process load for describing NOx emissions is bounded by assuming dissolution [Proprietary Information]. This produces a bounding irradiated target dissolution throughput of [Proprietary Information] such that the bounding quantity [Proprietary Information]. The molecular weight of [Proprietary Information] such that the bounding target material is equivalent to [Proprietary Information].

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NW MI IiNM-06RIO1 Rev. 0 Based on Equation 1, the bounding irradiated target dissolution source term is described by Equation 3, where the NO,, is described as equivalent NO2 mass (46.01 g NO2/mole NO 2 ).

Equation 3

[Proprietary Information]

Presence of the dissolver condenser reduces the quantity of NOx, entering the dissolver offgas system based on Equation 2. The bounding quantity of NOx, entering the dissolver offgas system is described by Equation 4.

Equation 4

[Proprietary Information]

Offgas leaving the irradiated target condenser is routed to the dissolver offgas treatment system. Process elements affecting NO,, emissions consist of a caustic scrubber, NOx, oxidizer, and NOx, absorber. The primary purpose of these treatment elements is to reduce non-condensable gas volume and remove NO*,,

water vapor, and nitric acid (I-NO3) vapor such that residual gas leaving the treatment elements is acceptable for downstream fission gas treatment. The treatment element NOx,removal performance is summarized as follows:

• Caustic scrubber - removes 95 percent of the NO,, entering the caustic scrubber

• NOx, oxidizer - removes 50 percent of the NO,, entering the NO,, oxidizer

• NO,, absorber - removes 98 percent of the NOx, entering the NO,, absorber The NO,, leaving the NOx,absorber is routed, via the process vessel vent system, to the Zone I exhaust plenum for emission via the Zone I exhaust stack. Equation 5 indicates the irradiated target dissolution emissions are bounded by 0.14 kg NOx,/yr as NO 2.

Equation 5 NOx leaving caustic scrubber = (270 kg V x. ( -095 1. kgNOx s O

\ yr i yr N Ox leaving N Ox oxidizer =-(13.5 k * '* x -(-1 0.)=67 kgNOx s O

\ yri/ yr NOx leaving NOx absorber = 67

( ___kg yr /x (1 - 0.98t) = 0.14 No

• r as NO02 The target fabrication system includes process elements for dissolution of fresh uranium metal receipts and [Proprietary Information]. [Proprietary Information] dissolution stoichiometry is described by Equation 1. The uranium metal dissolution reaction is described by Equation 6.

Equation 6

[Proprietary Information]

The target fabrication process is based on a nominal production rate that fabricates [Proprietary Information]. Once steady-state operation has been established, fresh uranium metal dissolution is estimated to be required equivalent to [Proprietary Information] as makeup for recycled uranium process losses in the target fabrication system.

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.R W MAIK NWa,-2016-RAI-001. Rev. 0

[Proprietary Information] will be processed by the target fabrication dissolver to address recycling out-of-specification materials generated during target fabrication. For a nominal production load of

[Proprietary Information] if the production process was operated at the bounding throughput described for irradiated target dissolution.

The target fabrication dissolver must also support generation of a fabricated target inventory from fresh uranium metal during the initial year of operation. Table 4-1 ofNWMI-2013-021, Chapter 4, indicates the target fabrication area nominal special nuclear material (SNM) inventory that would be created by fresh metal dissolution in the first year of operation is as follows:

• [Proprietary Information]

• [Proprietary Information]

• [Proprietary Information]

• [Proprietary Information]

The total target fabrication inventory from fresh uranium metal dissolution is [Proprietary Information].

Therefore, the nominal SNM inventory is estimated to create a nominal target inventory of [Proprietary Information]. The bounding target fabrication throughput is capable of producing the targets in approximately [Proprietary Information]. Based on operating 52 weeks/yr, the target fabrication system is available to support steady-state operation in the remaining 50 weeks of the first operating year.

The target fabrication system is not actually capable of supporting the bounding throughput of

[Proprietary Information] used for estimiating bounding NOx emissions from the irradiated target dissolver. Therefore, the target fabrication dissolver is assumed to support uranium recycle at an operating rate of [Proprietary Information]. Therefore, the total uranium dissolved in target fabrication is bounded by [Proprietary Information].

The molecular weight of uranium for LEU containing 20 wt% 235U is [Proprietary Information] such that the first operating year uranium metal dissolved is [Proprietary Information]. Based on Equation 6, the bounding target fabrication dissolver source term from fresh uranium metal dissolution is described by Equation 7.

Equation 7

[Proprietary Information]

Nitrogen oxides generated by dissolution of [Proprietary Information] is difficult to predict prior to obtaining actual operating experience. However, conservatism in the bounding fresh metal dissolution estimate (equivalent to producing [Proprietary Information] is considered sufficient to address the uncertainty associated with [Proprietary Information].

Offgas from the target fabrication dissolver is routed, via the process vessel vent system, to the Zone I exhaust plenum for emission via the Zone I exhaust stack. Offgas treatment for removal of NOx from the target fabrication dissolver is not included in the current design because it represents a relatively small emission source. Inclusion of a target fabrication dissolver condenser may be found to be required for liquid level control in final design activities, along with other process steps that reduce the quantity of NO* emitted from the facility stack.

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BIIAI.BNWMI-2016-RAI-001, Rev. 0 Table 1 provides a summary of the source terms and stack emissions for NOx generated by the RPF process systems.

Table 1. Summary of Radioisotope Production Facility Process System NOx Source Terms and Stack Emissions Irradiated target dissolution 540 kg NOR/yr as NO2 0.14 kg NON/yr as NO 2 Facility total 582.5 kg NOx/yr as NO2 42.64 kg NOx/yr as NO2 NO2 = nitrogen dioxide. N =nitrogen oxides.

Primary process system reactions do not generate quantities of CO 2 or SO 2 as reaction products.

However, actual materials may generate trace quantities of these components due to the presence of impurities or solution radiolysis. As an example, offgas from dissolution of uranium metal is reported to contain nitrous oxide (N2 0), CO 2 , carbon monoxide (CO), and hydrogen gas (1-12) at concentrations that are approximately 0.1 percent of the total NOx (NO + NO 2) generated. Formation of CO 2 and CO is attributed to the dissolution of carbon impurities in the uranium that was dissolved. While H2 and oxygen (02) are the dominant components produced by aqueous solution radiolysis, there is a potential for RPF solutions containing nitrate and sulfate solutes to generated trace quantities on NOx and SO 2 from radiolysis. The trace sources of these potential emissions have not been quantified and are unlikely to be present at measurable concentrations in the stack emissions.

9 -9 - 9 99 9 9 9 The planned inventory is approximately 53 gallons (gal), and depending on nominal versus maximum target production rate, the tumnover rate is estimated at 1 to 2 times per year.

AIR-2 Th. IGaci i esuiz NRE 537, Pat , S~c~n194.2,'i ulZ n ~e ttsta h

• EDFh -31244OOOI, 2015.,Estimat fxwalnfrhe NM Rd1otp*od o Faiy*,Rev.3, Porzage, Inc.,Idh Falls,Idaho, Febrwii2,201...

• I DF -3124-(X).,,42015. Caclto1frteDtemnto of Fgtv hawn ct iesfrom Coiuton&juipem Re.1, PotgIn. dh Falsjd*o F .iwi 321.

• 1 1244)0,04 nRa msin o eade uigCntuto.Rv .Prae Inc,,

Idio.'llIao June6 04

• EDF-314(), 2014, DeterminatIonof Wid-Blw Z*tdrn CowrcincliisRv 0, Portage,lnc., Idaho Falls,Idaho, ue6 2014.  ; "

"EDF-31240X9 2040fRa m;in durngC'ostut *,Re.0, Potg n. *~

al, Idaho, June 26, 2014,...

• EDF-312-04,2014. Ems(nMoeigfor ConsrutinAcivts:U*m A*SRE; 0, Portage,Inc., Idaho Falls,Idaho, June 26.2014.

The most recent revisions of the requested reference documents listed above are attached in Appendix A, B, C, D, E, and F, respectively.

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NVVMI-2016-RAI-001, Rev. 0

~NM

-S * ~** S S - S The selection university of potential research reactorRPFthat sites couldwas initially provide driven by irradiation the requirement services to be co-located near a for the majority of NWMI molybdenum-99 (99Mo) production. In addition, the university reactor needed to have:

• Experience supporting government and commercial industries

• Capability to support commercial irradiation on a regular basis

• Core configuration that could accept the NWMI targets

• Power required to meet the irradiation requirements From a broad list of potential locations, NWMI conducted an informal evaluation process based on the experience and knowledge to down-select to the four sites for a more detailed evaluation.

As stated above, NWMI initially considered sites near a multitude of existing research and test reactors and down-selected based on the knowledge and experience of the team. The initial down-select did not include any specific regional or State-wide factors.

AL2 I0 FR51 4Sb3 n th S nmntn UE-537,Part 1,Scto 1.5 "Atenaivs Asstated inRNM ta sho13021sChapether h1t0, pand192 (pagrocesusedoformuae Thbe rea8)sonabledoth aiig lrternaetiblis.hedcn 19anfteE sn edl valbepbi tts htN/i nomtion osdrd theUniervain rmsiteoviisou its the sites were scored using a scale of 1 to 5 (5 being most favorable, 1 being least). The NWMI team determined that all four of the sites are viable and acceptable, with Discovery Ridge selected as the preferred site of the proposed RPF (see Table 19-88 ["Evaluation of Alternative Sites"]). .... The Discovery Ridge site total weighted score of 82 percent was followed by the MURR location. Given the high weighting of certain criteria (i.e., political and local logistical support, facility operations, and production logistics) and high scores for these criteria, the MURR and Discovery Ridge sites have an advantage over both the proposed McClellan Business Park and OSTR sites.

The proposed site at the McClellan Business Park ranks fourth for the RPF location. The McClellan Business Park score was 34 percentage points lower than the Discovery Ridge site, primarily due to a lack of political and local support, Federal and state taxes and incentives, limited available greenfleld space, and weaker ties to the UC Davis reactor team. However, the site's strengths include an existing building and abundant available space. The OSTR site, which ranked third, had limited available space, transportation routes, and State and local financial incentives.

In consideration of these factors, the Discovery Ridge site was selected as the proposed site for the RPF.

The siting alternatives of the MNRC Business Park and OSTR locations were not further evaluated. The MURR site was considered to be viable and was identified as a reasonable alternative; its evaluation is provided in the following subsections..."

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NWMI-2016-RAI-001, Rev. 0

• NWMI

.. S The factors NWMI considered to make this determination include the following (Table 19-88):

° Political and local logistics support

• Facility operations

• Production logistics

• Transportation

• Radioactive, hazardous, and mixed secondary waste generation (e.g., air, liquids, solids)

• Federal, State, county, and local requirements to construct and operate facility

• Federal and State taxes and incentives

• Available space

• Construction costs

• Natural or human-made disaster potential ea2410CFR5h 5b3 tad th ISGagetn UE 137 at1 eto 95"le stat tha ER sho....ld sumrz th itr n rcs sd of uaeteraoal The "Production Logistics" score for MURR is incorrect. This value should have been a "4," the same as Discovery Ridge site, with a weighted value of 40. In addition, the "Facility Operations" and "Construction costs" for MURR were incorrect and should have been "2" for a weighted value of "20" and "3" for a weighted value of "6," respectively. The "'Facility Operations" rating was due to the ability to operate a RPF in conjunction in a limited space and would be managed by MURR personnel not NWMI. The "Construction Costs" rating was lower than Discovery Ridge due to the limited space available next to the MURR reactor building for initial construction or future expansion and the need for the construction of below-grade connection to the reactor. The total corrected score for MUJRR is 217 with a weighted percentage of 72 percent. A revised Table 19-88 is provided below.

Table 19-88. Evaluation of Alternative Sites (2 pages)

- - * - I Political and local logistics support 4 40 4 40 4 40 1 10 Facilt operaton 4 40 2 20 3 30 3 30 Production logistics Radioactive, hazardous, and mixed secondary 4 32 4 32 4 32 3 24 waste generation (i.e., air, liquids, solids)

Federal and State taxes and incentives 5 15 5 15 3 9 1 3 Availablespe 5 15 3 9 1 3 2 6 6 of 28

NV MINWMI-06RIO, Rev. 0 Table 19-88. Evaluation of Alternative Sites (2 pages)

I---

Construction costs 4 8 3 6 3 6 3 6

.......... diatcpoc ill3 344 Total 245 217 190 145

........... ........... 2%7 %63% 48%

DR =Discovery Ridge. MURR =University of Missouri Research Reactor.

MNRC =McClellan Nuclear Research Center. OSTR = Oregon State University TRIGA Reactor.

Discovery Ridge and MURR were given a score of "4," because with placement of the RPF in either of those locations, the primary university reactor that provides the bulk of irradiation services for NWMI would be near (less than 20 miles from) the RPF. Transport of irradiated targets from either Discovery Ridge or MURR would not require crossing significant mountain ranges (e.g., Rocky Mountains) that could result in potential delays due to inclement weather. Because time is critical to NWMI's business, a site in close proximity to the irradiating reactor is preferable.

The second major bullet and associated second and third sub-bullets in NWMI-2015-RAI-001, Response to the U.S. Nuclear Regulatory Commission Request for Additional Information, EnvironmentalReview of the Northwest MedicalIsotopes, LLC ConstructionPermit Application, Appendix E, Page 21, stating that "all routes require crossing significant mountain ranges" and "If RPF was located at Discovery Ridge/MURR, more Rocky Mountain crossings may increase the probability of delays," was in error for the Discovery Ridge and MURR sites. These statements were intended to be applicable only to the McClellan and OSTR sites. The difference between a score of 2 for OSTR and 3 for McClellan was based on the additional distance and travel time required to ship irradiated targets from their respective site to the RPF (i.e., 200 miles or an additional 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of travel time farther to OSTR than McClellan).

McClellan was given a score of "3" due to the additional regulatory requirements by the state of California for the transport and disposal of any waste generated.

The regulatory requirements associated with storage, transportation, and disposal of waste are more rigorous in the state of California than in the states of Missouri and Oregon. Thus, a lower score was given to McClellan.

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NWMI-2016-RAI-001, Rev. 0 NWMI McClellan was expected to have additional or more significant State and local requirement than the other three sites. For example, the state of California requires a separate State Environmental Policy Act under the Califomnia Environmental Quality Act (CEQA) action for any new processing facility. In addition, the State (e.g., California Code of Regulations) and local requirements are expected to be more stringent and broader in scope in Califomia (e.g., McClellan) than Federal regulations and less so at the other three sites. For example, if and when the waste leaves the state of California, the waste is treated as nonhazardous; for this reason, treating and disposing of hazardous waste in California is preferable in terms of environmental protection because California's protocols are more rigorous in comparison to those in Federal Resource Conservation and Recovery Act (RCRA) regulations and other State regulations.

The state of California, in general, has more stringent regulatory requirements that either the state of Missouri or Oregon. For example, if the RPF was to be sited at the McClellan site, the state of California would require a separate CEQA action for any new processing facility that is comparable to preparing a separate environmental impact statement.

OS Ra score of 3*an icvr*dge an U RasoeofSgvnta reo osnthv The state of Missouri offers several incentives that help provide a score of 5 compared to the other locations. Some of these incentives include the following:

• Statewide works - This program provides significant state incentives for eligible companies creating new jobs in Missouri; the incentives of the program are the retention of the State withholding tax.

• Customized training grant - This program provides customized training to employees that will help meet the specific needs of the employer through classroom skill training.

• Recruitment assistance - The Division of Workforce Development offers personalized recruitment assistance to help businesses meet their labor needs.

• Energy exemption - As of August 28, 2007, the state of Missouri allows manufacturers an exemption on energy purchases. These items may be exempted from State tax (4.225 percent) and local use tax, but not local sales tax.

• Sales/use tax exemption - Machinery and equipment used to establish a new or expand an existing manufacturing facility is tax-exempt, provided such machinery/equipment is used directly to manufacture a product ultimately intended for sale.

T* for*A future.epansion OSTR was given a score of"l" due to the potential site provided by the university to NWMI was less than 1.0 hectares (ha) (2.5 acres) in size and no future expansion would be available.

NWMI-2015-RAI-001, Appendix E, '"NWMI Site Alternative Study," page 25, OSU Bullet 2, was in error. In addition, McClellan was given a score of'"2" due to the limitations on the existing buildings and airport tarmac adjacent to the site (e.g., no construction can occur on the existing tarmac).

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NWMI-2016-RAI-001, Rev. 0 1 1VIHl NJ:;..*

I 9 - 9 6 NWMI-2015-RAI-001 states in RAI ALT-2B that construction costs would be higher at MURR and OSTR than at Discovery Ridge. This statement is based on the land area constraints that were given for both MURR and OSTR. Discovery Ridge is a "greenfield" area that has been broken into three phases for development. Lot 15 of Discovery Ridge is part of the Phase II development, which has over 22.5 ha (60 acres) for development. The MURR score of "4" for construction costs was in error in NWMI-2015-RAI-001, Appendix E, page 26; this score should have been "3," as stated in RAI ALT-2B.

ALT2-3A provides the revised table.

Based on similar work performed in the industry, the refurbishment of the overhead crane will nominally take two days and be performed by two individuals from a qualified mechanical subcontractor.

Management high water table elevations: As described in our response to WAT2-1, NWMI does not anticipate a high water table at the RPF site. There is no historical groundwater data specifically for the RPF site at Discovery Ridge. The nearest United States (U.S.) Geological Survey monitoring well provides an indication of the historical groundwater fluctuation and seasonal trends. The depth to groundwater at that well has varied from a minimum of 22.9 meters (in) (75 feet [if]) to a maximum over 61 m (200 if). Other monitoring wells in the area show a static water level from 55 to 99 m (180 to 325 if) below the surface, while two wells drilled approximately 1.6 kilometer (kin) (1 mile [mi]) east of the site encountered water at 10.97 and 11.89 m (36 and 39 if). The response to WAT2-1 provides plausible explanations as to why water was found in two of the nine boreholes drilled across the Discovery Ridge site (Terracon, 2011).

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NW M!III NWM,-2016-RA,-001, Rev. 0 Additional borings, within the RPF boundary, are planned. If the analysis of these new borings discovers high water tables, the final design will address that issue in detail.

Projected rate and duration of dewatering: NWMI does not anticipate a high water table or to encounter significant groundwater at the site. However, if encountered, as noted in NWMI-20 13-021, Section 19.4.4.1.1, some dewatering due to groundwater and precipitation may be required during construction at the deepest excavation. Any water would be collected in a detention/retention pond. The dewatering rate is anticipated to be controlled by the precipitation for the site during the construction period. Section 19.3.2.1.2 states, on a monthly basis, rainfall amounts range from a high of 12.4 centimeters (cm) (4.89 inches [in.]) in May to a low of 4.62 cm (1.82 in.) in January. The proposed lot for the RPF at Discovery Ridge is approximately 3.0 ha (7.4 acres). Using the maximum rainfall rate and the entire site area, a conservative estimate of less than 1,400 g/hour (hr) is reasonable. The size of the excavation is a small fraction of the entire site area, so this estimate is conservative. The duration of the civil and foundation work is estimated at three to six months. The duration of the dewatering would be a fraction of the total duration (i.e., only when there is precipitation).

Potential impacts on local groundwater sources and direction of flow: NWMI does not anticipate any detrimental impact to local groundwater sources or directions of flow. As described in the response to WAT2-1, the site does not interact directly with local aquifers. Surface run-off would be collected in a detention/retention pond.

Facility design considerations for permanently or seasonally high water tables: The RPF will have design features to minimize the impacts of any seasonal high water tables. Foundations will be protected from water with barrier systems (e.g., sealants) and drainage will be provided to channel water away from the RPF.

Implications for facility operations: NWMI does not anticipate any impact on facility operations due to groundwater issues. . .... . .. . .. .. . . . . .. .

S - . ~.. S - S S The calculations for transportation of materials for the RPF (EDF-3 124-0010, Radiological Dose Consequences Associated with Transportationof Materialsfor the NWMI Radioisotope Production Facility) assumed a dose rate of 10 milliroentgen (mR)/hr at one meter for the transportation cask used to transport the 99Mo product. Using the inverse square law (R1D12 = RiD 22 ), the dose to the public when the plane is at a cruising altitude of 6,200 m (20,000 ft) would be 2.6E-7 mR/hr. This dose is significantly lower than background.

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NWMI lv.l ,

Chaper 1ruTale 11- ofeNaMIonal,-and eoisspoiddon tefoing be 11n2paigtes PnR in Chaptder11tled Te stweek radionulides ed gaueos

[ releaes) genderte norma t peratingmcoditons.aewr upidb doswek to oti thepuelics fromthes inorma operationals iacreleases weeudjsed ind termining va10ely account for one high-efficiency particulate air (HEPA) filter in the Zone I heating, ventilation, and air conditioning (H-VAC) offgas treatment system (Chapter 9, "Auxiliary Systems," Section 9.1.2.2) in accordance with EPA 520/1-89-003, User's Guide for the COMPLY Code, which recommends that radionuclide particulate releases be reduced by an adjustment factor of 0.01. The noble gases and iodine releases were not reduced in the analysis. The following radionuclides were not available in the COMPLY database: l36 tuBa, l37 tuBa, 133mi, 97myb 23 6rmNp, 23 4 mpa, l"2 pd '""'4pr, 10R' 285b' 12SSb, and The following assumptions were used in the development of the analysis:

• Meteorologic~al data - COMPLY meteorological wind rose file for Columbia, Missouri

• Stack data - Stack height 22.9 m (75 ft), diameter of 0.86 m (34 in.)

• Building data - Height 19.8 m (65 ft), width 24.4 m (80 fi), length 76.2 m (250 ft)

• Receptor location - Nearest receptor locations is the RPF fence line at 9.1 m (30 fi) from the stack

• Agricultural data - Food sources (e.g., milk, meat, vegetables) assumed to be home grown at receptor location The maximum dose to the public from the normal operational stack releases was calculated to be 0.036 millisievert (mSv)/yr (3.6 millirem [mrem]/yr) at 9.1 m (30 fi) from the RPF. The results of the COMPLY analysis determine that the requirement of 10 CFR 20.1101, "Radiation Protection Programs,"

item (d) will be met for the RPF, such that air emissions of radioactive material to the environment will not result in a member of the public receiving a total effective dose equivalent (TEDE) in excess of 0.1 mSv/yr (10 mrem/yr) from these emissions.

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NV IVINWMI-06RIO1 Rev. 0 Table 11-2. Radionuclide Stack Release Source Term Input to COMPLY (2 pages)

S*S.... ...5 4Am8.67E-17 237Np 1.63E-12 89 Sr 3.69E-02 91 l37mBa 2.89E'06 Z3Np 3.49E-04 Sr 2.36E-02

'!Ba 1.Q3E)5 *;  ! 4.14 !31-O 2

'*13a 7.99E-04 *Pa 1.59E-12 99Tc 4.04E-08 I43Ce 3.52E-04 " 2pd 7.43E-07 I2StaTe 8.55E-07 9.89. 5 '*P 9.39E06 ' 7 Ti 9.1E 27 3Cs4.92E-10O4p 5.81E-09 l raTe 1.12E-04 16s7.16E-07 49m6.44E-05 2roe9.73E-04

'55Eu 1.03E-07 151 Pm 2.47E-05 I3IraTe 2.39E-03

' 57 Eu 3.28E-07 143 pr 8.15E-04 133Te 1.38E-05

... .. 1.90E-i3 14 P ,~7f4 6...3E6 1317.17E-08 144mpr 1.38E-06 34e1.78E-05

• I5.97E-4 ,]4p L 14E-4 m .34 1132 1.56E-03 23pu 1.31E-12 234U 2.48E-06 8.I65E-0

• u 3.5E0 14E0 24

]331 2.62E-03 °pud 2.58E-12 23U3.82E-08

]*4.36E-07 2 9,31E-13 2',,-~

13I2.69E-05 1O3m~h 2.74E-04 23U7.15E-08 1354 1.36E-03 IRh 6.40EQ5* "L6+0 83 33 m}Qr 3.81E-10 '°6Rh 5.70E-06 ' Xe 4.98E+02 SSKr 5.84E+01 1.O05E,08 1*8 977*

85 1 3 35 mfr 1.92E-03 ° Ru 2.75E-04 1 Xe 9.5 1E-20 aKr 1.80E-23 ,!5y,2.12E.05 I.46 -27 88Kr 1.16E-07 '°*Ru 5.70E-06 89y3.43E'06 "4'La 8.64E0 42S 3 8E-1 2.4F.O l 41La 1.11E-04 24

' Sb 6.56E- 10 9y5.70E-09 9

99M0 3.40E-04 '26Sb 1.10E-07 Imy 1.50E-02 95Nb 1.68E-04 ')S 1.02E4 5 2.Q3,Q2 95m~b 4.64E-06 aSb9.42E-07 9y2.68E-02 Nb3.06E-08 . .. SE4YI i?*!  ::Zr *6.12H9 95 97Nb 3.37E-04 ' *Sb 1.14E-05 Zr 4.29E-02 97Nb, 2.98E0 '5 Sm 6.84E-Q ': Z 3.44O 47d2.8 1E-04 '53Sm 9.44E-06 Total Ci 7.24FE-02 2*sNp 9,02E:15 'SSSm6....... "

I I I I T][ [ ] T Sources: Barrington, C., 2015, "NWMI Release # 11 - Process Vessel Ventilation (PVV) System Estimate," (memorandum to G. Dunford, May 26), AEM Consulting, LLC, Richland, Washington, 2015, and NWMI-2013-CALC-006, Overall Summary MaterialBalance - MURR Target Batch, Rev. D, Northwest Medical Isotopes, LLC, Corvallis, Oregon, 2015.

12 of 28

NWMI-2016-RAI-001, Rev. 0

~NWNH NWMI programwill willestablish a liquid enviromnmental include baseline sampling program for the area around the RPF. The sampling and routine sampling. The program will also include ad hoc sampling to be performed in the event of a liquid radiological release to determine the environmental impact and associated dose to the public.

NWMI programwill willestablish a liquid environmental sampling program for the area around the RPF. The include baseline sampling and routine sampling to determine and quantify the impacts of normal effluents from the vent stack emissions. The sampling program will include sampling of nearby surface water and the groundwater monitoring wells.

The TEDE nearest to line fence the public located outside at the controlled area would be from 3.6 mSv (0.36 rem) at the 10 m (30 fi) to 7 mSv (0.70 rem) at the furthest fence line 91 m (300 ft). The TEDE to the nearest resident located 430 m away was calculated to be 31 mSv (3.1 rem). The highest TEDE to the licensee staff outside the building would be 7 mSv (0.70 rem) for a person located 91 m (300 ft) from the location of the stack. The calculations are provided in EDF-3 124-0003, PreliminaryMaximum Hypothetical Accident to Support the Northwest Medical Isotope Facility EnvironmentalReport. The TEDE doses are greater than the limits of 10 CFR 20, "Standards for Protection Against Radiation."

However, 10 CRF 20 limits are for normal operations not accident situations. The TEDE indicates that the maximum hypothetical accident (MHA) is the intermediate consequence event per 10 CFR 70.61, "Performance Requirements."

13 of 28

NWMI-2016-RAI-001, Rev. 0

• • ,*!,'*. Nt^tKnl 111 If V IWll

. ~.. S S

• S The requested reference document is attached in Appendix G. EDF-3 124-0003 has been updated to Revision 2, which is the version attached in Appendix G. There are three minor differences between NWMI-2013-021 and this appendix, including:

• Stack height is 75 ft. In EDF-3 124-0003, 22.86 and 22.9 m are both used in the text. The actual calculations use the non-rounded stack height of 22.86 m (75 fi).

• Density of air in the actual calculation of the EDF was 1,240 g/m 3; however, the text in NWMI-2013-021, Chapters 3 and 19, was in error and stated 1,250 g/m3 .

• EDF-3 124-0003 (Rev. 2) was updated to reflect a 1.32 safety margin in the inventory (consistent with Chapter 13). As part of the updated calculations, the model results were truncated at 1,500 m (4,921 fI) away versus the 1,700 m (5,577 ft) results presented in EDF-3124-0003 (Rev. 1) and NWMI-2013-021, Chapters 13 and 19.

Baseline noise levels were modeled using peak traffic counts for U.S. Highway 63 in Missouri for traffic traveling at 112.7 km/hr (70 mi/hr). Using these traffic counts, the modeled baseline noise level is 68.8 dBA (A-weighted decibel) at the nearest residence.

Peak traffic counts used in the baseline noise modeling were 818 in the southbound lane and 1,002 in the northbound lane. Peak traffic counts used to assess facility impact were 918 in the southbound lane and 1,102 in the northbound lane (an increase of 100 vehicles traveling on U.S. Highway 63).

The nearest resident used in noise modeling is nearest to both U.S. Highway 63 and to the proposed RPF.

Approximate distance to the residence from U.S. Highway 63 is 85.3 m (280 ft), and the distance to the proposed RPF site is 792.5 m (2,600 fI).

14 of 28

a a. a am a.

.tuu.u..u*..

NWMI-2016-RAI-001, Rev. 0

• V. *~~~*~*V S - S .55 5 - V S Preconstruction activities are those that are not considered construction activities under the definition of construction currently provided in 10 CFR 51.4, "Definitions." Based on this definition, NWMI considers the following activities as preconstruction:

• Site exploration, including boring to determine foundation conditions and other preconstruction monitoring

• Site preparation, including clearing and grubbing, grading, installation of drainage, erosion and other environmental mitigation measures, and construction of temporary roads and borrow areas

• Erection of fences and other access control measures that are not safety- or security-related or pertain to radiological controls

• Facility excavation

• Construction of support buildings for use in connection with the construction of the proposed RPF, including construction equipment storage sheds, warehouse and shop facilities, utilities, concrete mixing plants, docking and unloading facilities, and office buildings

• Construction of service facilities, including paved roads, parking lots, exterior utility and lighting systems, potable water systems, sanitary sewerage treatment facilities, and electrical systems

• Procurement or fabrication of components or portions of the proposed RPF occurring at other than the final, in-place location at the facility

• Erection of buildings that wvill be used for activities other than operation of the proposed RPF and that may also be used to house a training or laboratory facility The total duration of preconstruction activities is estimated to be approximately 60 days immediately prior to the start of construction except for site exploration and long-lead procurements. Site exploration will be completed in the second quarter of 2016 to support the completion of the RPF final design and construction drawings. In addition, long-lead procurements of components for the proposed RPF that occur at other than the final, in-place location will be initiated prior to construction. The impacts of these preconstruction activities are included in our construction activity analysis.

The average and peak-workforce required during preconstruction activities is estimated to be 40 percent of the peak and average workforce required for all RPF installations or a peak of 33 and average of 15.

The average number of delivery trucks during preconstruction is estimated at an average of 20 vehicles per week. Offsite shipments of waste and debris is estimated at an average of one per week during preconstruction activities.

15 of 28

NWMI-2016-RAI-001, Rev. 0 As stated in Table 19-6 of NWMI-2013-021, the majority of the diesel fuel consumed during the RiPF installation would be during the first three months of construction. These three months coincide with the preconstruction phase. Based on the average rate of 1,647 liters (L)/month (435 gal/month), the total fuel consumption is estimated at 28,000 L (7,395 gal) of diesel. Approximately 70 percent of the total 19,600 L (5,180 gal) are estimated to be used during preconstruction.

The majority of the water consumed during the RPF installation would be used during preconstruction activities. The volume of water required during preconstruction activities is estimated at less than 7,571 L/day (2,000 gal/day). The source of the water would be the Consolidated Public Water Supply District # 1.

100 percent of Discovery Ridge Lot 15 (2.99 ha [7.4 acres]) will be cleared and grubbed during preconstruction activities.

Tabl 19-7 of the E Table 2 provides an estimate of the percentage of material presented in Table 19-7 of NWMI-2013-021 that is assumed to be consumed during the preconstruction portion of activities.

Table 2. Percentage of Materials Consumed During Preconstruction Phase Concrete 5% 3,257 m3 4,260 yd3 Asphalt 95% 245 m3 320 yd3 Miscellaneou 2% 45 t 50 tons Roofing 8% 4,645 m2 50,000 ft2 s steel Ste ie %17t 100) rc~ %435 t 40' u

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

The number of hours and material moved for the preconstruction portion of RPF installation activities for the equipment identified in Table 19-51 of NWMI-20 13-021 are identified in Table 3.

16 of 28

NWMmUIKI NWI21-A-ORev. 0 Table 3. Number of Hours and Material Moved for the Preconstruction Portion of the Radioisotope Production Facility Installation Bulldozing 100 N/A N/A 10,886 12,000 Loading of earth haulers from front loaders 30 100 2I;772 24,000 Compacting 64 N/A N/A Moto p'~n 64 N/A N/A N/A =not applicable. . . . . ii I I i¸ i I i i S a .. 5r5 5 The duration of RiPF decommissioning activities is estimated to take 18 to 24 months.

The values in Table 19-6 and Table 19-14 are effectively the same. The Table 19-6 number of offsite shipments was rounded up from 9.4 to 10 (for bounding purposes) when converted to shipments per week. Thus, 486 shipments per year divided by 52 weeks was rounded up to 10 shipments per week.

17 of 28

NWMI-2016-RAI-001, Rev. 0

..'.,i, NWM I I .

PA2-3 During the pre-operations phase, the RPF will receive chemicals and process supplies needed to complete construction and operability testing. A small quantity of natural or depleted uranium will also be received for equipment testing and process testing. The natural uranium will have to be flushed from the system and disposed of before LEU operations. No irradiated material will be handled in this phase; therefore, no corresponding data is shown in Table 19-14 of NWMI-2013-021.

S -S - S .55 5 - S - S 18 of 28

NWMI-2016-RAI-001, Rev. 0 N*-9.*11WNHIW There is no historical groundwater datakm specifically RPF site. (Latitude monitoring well (USGS, 2016) is 11.9 (7.4 mi) toforthethenorthwest The nearest U.S. Geological Survey 38057'1811, Longitude 92023142 NAD83) of the RPF site. This well provides an indication of the historical groundwater fluctuation and seasonal trends. Figure 1 shows the water level over the past seven years. The depth to groundwater at that well has varied from a minimum of 22.9 m (75 fi) to a maximum over 60.96 m (200 ft). As shown in Figure 1, the groundwater level normally peaks in July, dropping from 7.6 to 15.2 m (25 to 50 fi) in October.

Depth to water level, feet below land surface Most recent instantaneous value: 155.83 01-20-2016 13:0O0 CST USGS 395718892234201. Coluwbia 50 0 199

.0 550 ==

I 150

.g.

'I. 4588 299 250 2181_ 2911 2912 2913 2914 2915 2916

-Depth to seater level mmPeriod of provisional data

-m Period of approved data Source: USGS, 2016, "'USGS National Water Information System: Web Interface," http://waterdata.usgs.gov/nwis?progrmm

--uv&site_no=385718092234201 &agency cd=USGS, U.S. Geological Survey, Reston, Virginia, accessed January 20, 2016.

Figure i. U.S. Geological Survey Well 385718092234201 Depth to Water (WAT2-1lA-1)

S .55 5 . S . S There are no current Piezometric contour maps of the area. Figure 19-37 of NWMiI-20 13-02 1 provides the current water table contour map of the site. Figure 2 (on the following page) provides a map of the hydraulic gradient and groundwater flow direction map near and around Discovery Ridge.

19 of 28

NWMI-2016-RAI-001, Rev. 0 NWM!

v Groundwater Elevation and Flow Direction (1 ft Contours)

.. RPF Site O* 8 km (5 mile) Radius from RLPF Site

• Interstate Highways

+ Q

-Highways City Limits o 0.5 1 2 3 4 m

• Miles Figure 2. Hydraulic Gradient and Groundwater Flow Direction Map (WAT2-IB-I) 20 of 28

NWMI-201 6-RAI-001, Rev. 0 NWMI 0 - 0 .00 0 0

• The Mississippian aquifer is unconfmned in the Boone County area and underlies Discovery Ridge. The site has an estimated depth from 22.9 to 67.1 m (75 to 220 if) below the ground surface.

Figure 3 (on the following page) shows the location of the wells within 1.6 km (1-mi) radius of the RPF site (MDNR, 2006 and MDNR, 2014). Table 4 provides the historical data associated with each well recorded when the well was drilled. These wells primarily show a static water level from 55 to 99 m (180 to 325 ft) below the surface. Two monitoring wells drilled approximately 1.6 km (1 mi) east of the RPF site encountered water at 10.97 and 11.89 m (36 and 39 ft). No additional information is available on these boreholes or the water encountered.

Table 4. Historical Data For Wells Within A 1-Mile Radius of the Radioisotope Production Facility Site a - 0 -.

13947 Conmmunity public well University of Missouri- 9/13/55 587 60 270 810 Columbia 525 40 17896 Private well Phillips Angus Farm 11/20/58 505 300 792 1961 600 50 20980 Community public well Edwin Gose Trailer Park 797 70 24126 Community public well Boone Co Cons PWSD #1 12/1/65 1,190 60 300 820 192112 Water Not identified 7/8/97 720 - 180 394516 Domestic Not identified 10/20/06 766 - 200 807:i 408872 Heat pump Not idenltifed 4/1/10 187 10118/113 487832 Soil boring Not identified 104 10/18/13 487834 Monitoring Not identified 40 - 36 Sources: MDNR, 2014, "MIO 2014 Wells (SHP) Geospatial Data," ftp://mnsdis.missouri.edu/pub/

GeologicalCGeophysical/MO_2014_Wells_shp.zip, Missouri Department of Natural Resources, Jefferson City, Missouri, 2014.

MDNR, 2006, "MO 2006 Well Logs (SHP) Geospatial Data," ftp://msdis.rnissouri.edu/pub/

GeologicalGeophysical/MO_2006_Well_Logs shp.zip, Missouri Department of Natural Resources, Jefferson City, Missouri, 2014.

21 of 28

NVVMI-2016-RAI-001, Rev. 0 NWYM I

?.'::,

Groundwater Wells I NWMI Site

-Highways

+ *.** City Limits 0 0.125 0.25 0.5 0.75 1 Miles Figure 3. Wells Located within 1.6 Kilometer (1-Mile) Radius of the Radioisotope Production Facility Site (WAT2-1D-1) 22 of 28

NWMI-2016-RAI-001, Rev. 0 NWI~ffl Figure 4 provides a qualitative description of the groundwater aquifers (i.e., hydrostratigraphy) in the Columbia, Missouri area.

Fonndton wefltC,3fli 2ep*t Columbia Observation Well Water Level Hydrograph Geologic Well Log 1C00 -------------- O-------------2---0 !U~/2O1O !2/2/2012 Massissipp~an Aquifer 10 Burlington/Keokuk Ls

' OSedalia Fm Compton Ls Deoia yse 300 --- - - - 1 Cambnan-Or'dovician Con fining Unto ..... ....................

-- Cotter Dot ito-- - - ----- =-_______l '-Jefferson City Dot

-S

• ' i-Roubidoux Fm

,-Upper Gasconade Co170 Cambrian-Ordfovcian Aquifer

-Lower Gasconade Dot 9 00sGUnter Ss ita-'

-Eminence Dot

-Potosi Dol Water level data 12129/2000 - 226/2014 E~pth=ia53f~t St. Francois Cornfirnng Unit D*erby-Doerun Dol 1400 Source: MDNR, 2016, "Well Log No. 23501, Strathydrograph," http://dntr.mo.gov/geology/wrc/groundwvaterf strathydrographs/columbia.pdf, Missouri Department of Natural Resources, Jefferson City, Missouri, accessed January 25, 2016.

Figure 4. Columbia Observation Well (WAT2-1E-1) 23 of 28

NVVMI-2016-RAI-001, Rev. 0 NWI

- . ... .

• S S There are two significant aquifers that underlie the RPF site: the Mississippian and Cambrian-Ordovician aquifers. The Mississippian aquifer is the uppermost aquifer in Paleozoic rocks in northern Missouri. The Mississippian aquifer underlies all of Missouri north of the Missouri River except for small areas near the Mississippi and Missouri Rivers where rocks composing the aquifer have been removed by erosion. The name "Mississippian" was given to this aquifer because it consists of limestone of Mississippian age. The geologic units that compose this aquifer include the Keokuk, Burlington, Fern Glen, Sedalia, and Chouteau Limestones. Of these formations, the Keokuk and the Burlington Limestones are the principal water-yielding units. Both formations consist of crystalline limestone and yield water primarily from solution cavities. In most places, the Mississippian aquifer is overlain by a confining unit of Pennsylvanian shale and sandstone and regionally the entire aquifer is underlain by a confining unit of Mississippian shale (USGS, 1997). However, based on the review of nearby well log data obtained from the Missouri Department of Natural Resources (MDNR) geographic information systems (GIS) database for wells located within a 1.6 km (1-mi) radius of the subject property, no Pennsylvanian shale or sandstone was noted. Only the eastern one-third of the Mississippian aquifer contains freshwater; the remaining two-thirds contain slightly saline to very saline water. Therefore, the chemical quality of the Mississippian aquifer varies extensively throughout the aquifer (USGS, 1997). Additional detail on water quality is provided in Section 19.3.4.2.2 ofNWMI-2013-021.

The Mississippian aquifer averages about 60.96 m (200 if) thick in Boone County but exceeds 121.9 m (400 if) in northwestern Missouri. The thinnest portion of the aquifer is near the Mississippi and Missouri Rivers, where the aquifer has been dissected or partially removed by erosion.

The Cambrian-Ordovician aquifer system underlies the Mississippian aquifer in Columbia, Missouri north of the Missouri River. The Cambrian-Ordovician aquifer system contains very productive aquifers throughout an area of approximately 416,988 km 2 (161,000 mi 2) in Minnesota, Wisconsin, Iowa, northern Missouri, and northern Illinois. Many metropolitan areas depend on this aquifer system for municipal and industrial water supplies. The aquifer system is also used extensively for self-supplied industrial, rural, and domestic water supplies (USGS, 1992).

The Cambrian-Ordovician aquifer system is designated as one of 16 sandstone principal aquifers that underlies the U.S. The aquifer system includes several carbonate (limestone and dolomite) rock units with shale layers. Some of the sandstones are interbedded with carbonate units or, in places, contain secondary carbonate mineralization as cementation between grains. The Missouri River forms a natural boundary on the southern edge in Missouri and the southwestern edge in western Iowa. South of the Missouri River, the Cambrian and Ordovician rocks are included in the Ozark Plateau aquifer system, which is designated as one of the carbonate principal aquifers (USGS, 2012).

Freshwater is found in the Cambrian-Ordovician aquifer along a band approximately 80.5 km (50 mi) wide, which is parallel to and north of the Missouri River from Boone County eastward to the Mississippi River (USGS, 2012).

To better define the strathydrograph underlying the RPF site, two sources were evaluated. These sources include the MDNR strathydrograph for groundwater observation well (Well ID No. 23501, USGS well number 385718092234201 Columbia) located approximately 11.9 km (7.4 mi) to the northwest of the RPF site and well driller logs for wells located near the RPF site.

24 of 28

~.NW MvI NWM,-2016-RAI-001, Rev. 0 Figure 5 provides a strathydrograph for Groundwater Observation Well No. 23501 and provides geologic detail and the observed depths of both the Mississippian and Cambrian-Ordovician aquifers. Though located several miles from the RPF site, this strathydrograph provides an information on the hydrogeology in the region near the RPF site. The Mississippian aquifer is unconfined in this region and has historical daily average water levels that have ranged from a minimum depth of 22.9 m (75 ft) below the ground surface (bgs) to as deep as 67.1 m-bgs (220 ft-bgs).

Geologic well data from four driller's well logs (Well ID Nos. 013947, 017581, 017896, and 020722) located within 1.6 km (1-mi) of the RPF site were also evaluated to estimate the approximate depth to static groundwater level, depth to water-bearing geologic formations, and depth to aquifer systems underlying the RPF site (Figure 3). The GIS well data file reviewed (MDNR, 2006) provides the geologic stratigraphy within these wells as the following:

• Glacial Drift - Ranging from 0-18.3 m-bgs (0-60 ft-bgs), composed of topsoil, sand, clay, residuum, and/or gravel.

• Mississippian System - Ranging from 12.192-18.3 m-bgs (40-60 ft-bgs) and extending to depths of 85.3 m-bgs (280 ft-bgs) (Well ID Nos. 013974 and 017581).

• Ordovician System - Beginning at depths of 85.3 m-bgs (280 ft-bgs) (Well ID Nos. 013974 and 017581) and extending depths up to 182.9 m-bgs (600 ft-bgs) in Well ID)No. 020722.

Static water levels are listed for these four wells at depths ranging from 70.1 to 99 m-bgs (230 to 325 ft-bgs) within the Mississippian and Cambrian-Ordovician aquifers. The MDNR well located nearest the subject property is Well ID No. 013947. This well is located approximately 0.48 km (0.3 mi) west-northwest of the subject property. The static water level measured in this well at the time of drilling (1958) was 82.3 m-bgs (270 ft-bgs).

There are no sole source aquifers in Missouri (EPA, 2016).

Based on the information detailed in RAI WAT2-1A through WAT2-1F, the groundwater identified in Boreholes B-S and B-6 is not a surficial water-table aquifer and not a local water supply source. The source of the water encountered in Borehole B-6 could be from two other sources: (1) perched water from surface infiltration, or (2) potentially brought down the borehole during drilling.

Of the nine boreholes drilled by Terracon (Terracon, 2011) across the Discovery Ridge site, water was only identified in two, Boreholes B-S and B-6. Borehole B-6 was located approximately one-third of a mile to the south of the Borehole B-S and with a surface elevation 7.6 m (25 fi) lower. Borehole B-6 encountered weathered limestone at 5.2 m (17 fi) and refusal at 5.8 m (18.9 ft). Water was identified at a depth of 5.8 m (18.9 ft) for Borehole B-5, located on the eastern edge of the RPF site, and was drilled to 6.1 m (20 ft). According to the drill log, water was encountered at 5.2 m (17 ft) near the interface between sandy lean and fat clay. The water content of fat clay sample collected was 19 percent. This water content was similar to or less than the fat clay sample collected from the other boreholes where no water was encountered.

With the high water content of the soil and clay near the surface (24 and 34 percent, respectively), water could have seeped into the hole during the drilling process and was not noticed by the well logger.

Figure 5 provides a cross-section stratigraphic unit description of Discovery Ridge interpreted from the four Terracon bore holes that line up from east to west across the RPF site. This cross-section supports the potential that the water is not perched. The site-specific geotechnical and hydrological studies will better resolve this question.

25 of 28

NVVMI-2016-RAI-OO1, Rev, 0 S!NWMID 3)5L 3)4 O3) 3)2 801 799~

798.

-J 795' (I)

C, 794.

C 793, z

0 792; C 791

-J w

788 '

787 Ak RFP Bonring LOC atkon

/ /Cross Section Line L]Lot 15

• yr Water Level Figure 5. Discovery Ridge Stratigraphic Unit Description (WATZ-1iD-i) 26 of 28

NW M! NM-06RI 1Rev..0 REFERENCES 10 CFR 20, "Standards for Protection Against Radiation," Code of FederalRegulations, Office of the Federal Register, as amended.

10 CFR 51.4, "Definitions," Code of FederalRegulations, Office of the Federal Register, as amended.

10 CFR 51.45, "Environmental Reports--General Requirements," Code of FederalRegulations, Office of the Federal Register, as amended.

10 CFR 70.61, "Performance Requirements," Code of FederalRegulations, Office of the Federal Register, as amended.

42 U.S.C. § 6901 et seq., "Resource Conservation and Recovery Act of 1976," United States Code, as amended.

Barrington, C., 2015, "NWMI Release # 11 - Process Vessel Ventilation (PVV) System Estimate,"

(memorandum to G. Dunford, May 26), AEM Consulting, LLC, Richland, Washington, 2015.

EDF-3 124-0001, Estimate of Excavationfor the NWMI Radioisotope ProductionFacility, Rev. 3, Portage, Inc., Idaho Falls, Idaho, February 2, 2015.

EDF-3 124-0003, PreliminaryMaximum HypotheticalAccident to Support the Northwest Medical Isotope Facility EnvironmentalReport, Rev. 2, Portage, Inc., Idaho Falls, Idaho, January 21, 2016.

EDF-3 124-00 04, Calculationfor the Determination of Fugitive Dust During ConstructionActivities from ConstructionEquipment, Rev. 1, Portage, Inc., Idaho Falls, Idaho, February 3, 2015.

EDF-3 124-0005, On-Road Emissionsfor Vehicles During Construction, Rev. 1, Portage, Inc., Idaho Falls, Idaho, July 31, 2015.

EDF-3 124-0006, Determinationof Wind-Blown Dust During ConstructionActivities, Rev. 1, Portage, Inc., Idaho Falls, Idaho, July 21, 2015.

EDF-3 124-0009, Off-Road Emissions During Construction,Rev. 1, Portage, Inc., Idaho Falls, Idaho, July 31, 2015.

EDF-3 124-00 10, RadiologicalDose Consequences Associated with Transportationof Materialsfor the NWMJIRadioisotope ProductionFacility, Rev. 2, Portage, Inc., Idaho Falls, Idaho, January 5, 2015.

EDF-3 124-0014, Emission Modeling for ConstructionActivities using AERSCREEN, Rev. 1, Portage, Inc., Idaho Falls, Idaho, July 31, 2015.

EPA, 2016, "Map of Sole Source Aquifer Locations," http://www.epa.gov/dwssa/map-sole-source-aquifer-locations, U.S. Environmental Protection Agency, Washington, D.C., accessed January 20, 2016.

EPA 520/1-89-003, User's Guide for the COMPLY Code, Rev. 2, U.S. Environmental Protection Agency, Washington, D.C., October 1989.

MIDNR, 2006, "MIO 2006 Well Logs (SHIP) Geospatial Data," ftp://msdis.missouri.edu/pub/

GeologicalGeophysical/MO_2006_Well Logs shp.zip, Missouri Department of Natural Resources, Jefferson City, Missouri, 2014.

MDNR, 2014, "MO 2014 Wells (SHIP) Geospatial Data," ftp://msdis.missouri.edu/pub/

GeologicalGeophysical/MO_2014_Wells shp.zip, Missouri Department of Natural Resources, Jefferson City, Missouri, 2014.

27 of 28

MDNR, 2016, 'WVell Log No. 23501, Strathydrograph," http://dnr.mo.gov/geology/wrc/groundwater/

strathydrographs/columbia.pdf, Missouri Department of Natural Resources, Jefferson City, Missouri, accessed January 25, 2016.

NUJREG- 1537, Guidelinesfor PreparingandReviewing Applicationsfor the Licensing of Non-Power Reactors - Formatand Content, Part 1, U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Washington, D.C., February 1996.

NWMI-2013-021, ConstructionPermit Applicationfor RadioisotopeProductionFacility, Rev. 0, Northwest Medical Isotopes, LLC, Corvallis, Oregon, June 29, 2015.

NWMVI-2013-CALC-006, Overall Summary MaterialBalance - MURR Target Batch, Rev. D, Northwest Medical Isotopes, LLC, Corvallis, Oregon January 29, 2015.

NWMI-2015-RAI-001, Response to the U.S. Nuclear Regulatory Commission Request for Additional Information, EnvironmentalReview of the Northwest Medical Isotopes, LLC ConstructionPermit Application, Rev. 0, Northwest Medical Isotopes, LLC, Corvallis, Oregon, November 23, 2015.

Terracon, 2011, Preliminary GeotechnicalEngineeringReport Discovery Ridge-CertifiedSite Program Lots 2, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, and 18, Terracon Consultants, Inc., prepared for University of Missouri and Trabue, Hansen & Hinshaw, Inc., Terracon Project No. 09105094.1, February 11, 2011.

USGS, 1992, "'Summary of Ground-Water Hydrology of the Cambrian-Ordovician Aquifer System in the Northern Midwest, United States," U.S. Geological Survey Professional Paper 1405-A, United States Government Printing Office, Washington, 1992.

USGS, 1997, "Ground Water Atlas of the United States, Segment 3 Kansas Missouri Nebraska, Hydrologic Investigations Atlas 730O-D," U.S. Geological Survey, Reston, Virginia, 1997.

USGS, 2012, "WVater-Quality Assessment of the Cambrian-Ordovician Aquifer System in the Northern Midwest," United States, Scientific Investigations Report 2011-5229, U.S. Geological Survey, Virginia, 2012.

USGS, 2016, "UISGS National Water Information System: Web Interface,"

http://waterdata.usgs.gov/nwis ?program=uv&site_no=3 8571809223420 1&agencycd=USGS, U.S. Geological Survey, Reston, Virginia, accessed January 20, 2016.

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o . 00 0 o.0@O@Oe 0 0 NWM I NORTHWEST MEDICAL ISOTOPES U.S. Nuclear Response Regulatoryto the Commission Request for Additional Information, Round 2 Environmental Review of the Northwest Medical Isotopes, LLC Construction Permit Application NWMI-2016-RAI-OO1, Rev. 0 February 2016 Prepared by:

Northwest Medical Isotopes, LLC 815 NW9th Ave, Suite 256 Corvallis, OR 97330 1

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I

:NWJMI

~EOCIIOCPSRev. NWMi-2Ol 6-RAI-0010 APPENDICES Appendix A - EDF-3124-0001, Estimate of Excavation for the NWMl Radioisotope Production Facility............................................................................................ A-i Appendix B - EDF-3 124-0004, Calculationfor the Determination of Fugitive Dust During ConstructionActivities from ConstructionEquipment........................................ B-i Appendix C - EDF-3124-0005, On-RoadEmissionsfor Vehicles During Construction ................... C-i Appendix D - EDF-3124-0006, Determinationof Wind-Blown Dust During Construction Activities .......................................................................................... D-i Appendix E - EDF-3 124-0009, Off-Road Emissions During Construction.................................. E-i Appendix F - EDF-3 124-0014, EmissionModeling for ConstructionActivities Using AERSCREEN...................................................................................... F-i Appendix G - EDF-3124-0003, PreliminaryMaximum HypotheticalAccident to Support the Northw est Medical Isotope FacilityEnvironmental Report.................................. G-i

ElCAL SOAOPES

-,..NORTHWEST ME ATTACHMENT 3 Northwest Medical Isotopes, LLC Response to the U.S. Nuclear Regulatory Commission Request for Additional Information, Round 2 Environmental Review of the Northwest Medical Isotopes, LLC Construction Permit Application (Document No. NWMI-2016-RAI-001, February 2016)

Public Version Informnationz is being provided via hard copy

o.0 0 NWM I

00. 0 S0 *O 0 0 0 NORTHWEST MEDICAL iSOTOPES Response to the U.S. Nuclear Regulatory Commission Request for Additional Information, Round 2 Environmental Review of the Northwest Medical Isotopes, LLC Construction Permit Application NWMI-2016-RAI-001, Rev. 0 February 2016 Prepared by:

Northwest Medical Isotopes, LLC 815 NW 9 th Ave, Suite 256 Corvallis, OR 97330

This page intentionally left blank.

Response to the U.S. Nuclear Regulatory Commission Request for Additional Information, Round 2 Environmental Review of the Northwest Medical Isotopes, LLC Construction Permit Application NWMI-201 6-RAI-O01, Rev. 0 Date Published:

February 17, 2016

Title:

Response tO the U.S. Nuclear Regulatory Commission Request for Additional Information, Round 2 - Environmental Review of the Northwest Medical Isotopes, LLC Construction Permit Application Approved by. Carolyn Haass Signature: C M* '4 *- -

NVVMI-2016-RAI-001, Rev. 0

• .".I;NW MI!

REVISION HISTORY Rev Date Reason for Revision Revised By 0 2/17/2015 Issued for Submittal to the NRC N/A

+

• NWMI-2016-RAI-001, Rev. 0 NWMI TERMS Acronyms and Abbreviations

• Mo maflybdenum-99 235UJ uranium-235 ADUN aci,d-deficient uranyl nitrate ALARA as [ow as reasonably achievable CEQA Cal.lifomnia Environmental Quality Act CFR Co,de of Federal Regulations CO car rbon monoxide CO2 car rbon dioxide Discovery Ridge Di~scovery Ridge Research Park EPAU. S.Environmental Protection Agency ER En'.vironmental Review GIS ge( ographic information systems H2 hay drogen gas HEPA hi8 ;h-efficiency particulate air H1N0 3 flit nce acid HVAC he."ating, ventilation, and air conditioning ISG Int erim Staff Guidance LEU loyv¢-enriched uranium MDNR Mi ssouri Department of Natural Resources M1HA ma tximum hypothetical accident MINRC Mc,Clellan Nuclear Research Center MURR Un fiversity of Missouri Research Reactor N2 0 nit rous oxide NO2 nit rogen dioxide NO* nit r'ogen oxides NRC U S.Nuclear Regulatory Commission NWMI No*rthwest Medical Isotopes, LLC 02 ox,ygen 0STR Or,egon State University TRIGA Reactor PSAR preflirninary safety analysis report RAI req tuest for additional information RCRA Re,source Conservation and Recovery Act RPF Ra,,dioisotope Production Facility SNM spc,cial nuclear material SO2 sullfur dioxide TEDE tot al effective dose equivalent Terracon Te:rracon Consultants, Inc.

U.S. Un fited States U.S.C. Unfited States Code UC Unfiversity of Califomnia USGSU. S.Geological Survey

NWMI-2016-RAI-001, Rev. 0 Units bgs below ground surface Ci curie cm centim~ter dBA A-weighted decibel ft feet g gram gal gallon ha hectare hr hour in. inch kg kilogram km kilometer km2 square kilometer L liter m meter m2 square meter m3 cubic meter mi mile mi2 square mile mR milliroentgen mrem millirem mSv millisievert t tonne (metric) wt% weight percent yd 3 cubic yard yr year ii

NWMI-2016-RAI-001, Rev. 0 NWVMI a - a *gg * - a - a The peak workforce identified in Table 19-6 of NWMI-20 13-021, ConstructionPermit Applicationfor Radioisotope ProductionFacility, is assumed to be 82 during construction, with an average workforce assumed to be 38. By estimating the mileage for 100 vehicles (Table 19-56), the calculation bounded any potential emissions, including those by other service providers (e.g.. for routine deliveries).

The current Northwest Medical Isotopes, LLC (NWMI) Radioisotope Production Facility (RPF) production process steps do not produce significant quantities of sulfur dioxide (SO 2) or carbon dioxide (CO 2) that contribute to facility emissions. However, small quantities of nitrogen oxides (NOx) are evolved during the dissolution of low-enriched uranium (LEU) oxide from irradiated targets in the target dissolution process system and dissolution of fresh LEU metal receipts in the target fabrication process system.

Irradiated target material dissolution is based on reaction stoichiometry within the dissolver vessel.

Equation 1

[Proprietary Information]

The dissolver vessel condenser returns water vapor to the dissolver during operation, along with nitric acid from partial absorption of the nitrogen dioxide (NO 2), to produce the overall reaction shown as Equation 2 that defines NOx entering the subsequent dissolver offgas treatment process elements.

Equation 2

[Proprietary Information]

The annual irradiated target process load for describing NOx emissions is bounded by assuming dissolution [Proprietary Information]. This produces a bounding irradiated target dissolution throughput of [Proprietary Information] such that the bounding quantity [Proprietary Information]. The molecular weight of [Proprietary Information] such that the bounding target material is equivalent to [Proprietary Information].

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NW MI IiNM-06RIO1 Rev. 0 Based on Equation 1, the bounding irradiated target dissolution source term is described by Equation 3, where the NO,, is described as equivalent NO2 mass (46.01 g NO2/mole NO 2 ).

Equation 3

[Proprietary Information]

Presence of the dissolver condenser reduces the quantity of NOx, entering the dissolver offgas system based on Equation 2. The bounding quantity of NOx, entering the dissolver offgas system is described by Equation 4.

Equation 4

[Proprietary Information]

Offgas leaving the irradiated target condenser is routed to the dissolver offgas treatment system. Process elements affecting NO,, emissions consist of a caustic scrubber, NOx, oxidizer, and NOx, absorber. The primary purpose of these treatment elements is to reduce non-condensable gas volume and remove NO*,,

water vapor, and nitric acid (I-NO3) vapor such that residual gas leaving the treatment elements is acceptable for downstream fission gas treatment. The treatment element NOx,removal performance is summarized as follows:

• Caustic scrubber - removes 95 percent of the NO,, entering the caustic scrubber

• NOx, oxidizer - removes 50 percent of the NO,, entering the NO,, oxidizer

• NO,, absorber - removes 98 percent of the NOx, entering the NO,, absorber The NO,, leaving the NOx,absorber is routed, via the process vessel vent system, to the Zone I exhaust plenum for emission via the Zone I exhaust stack. Equation 5 indicates the irradiated target dissolution emissions are bounded by 0.14 kg NOx,/yr as NO 2.

Equation 5 NOx leaving caustic scrubber = (270 kg V x. ( -095 1. kgNOx s O

\ yr i yr N Ox leaving N Ox oxidizer =-(13.5 k * '* x -(-1 0.)=67 kgNOx s O

\ yri/ yr NOx leaving NOx absorber = 67

( ___kg yr /x (1 - 0.98t) = 0.14 No

• r as NO02 The target fabrication system includes process elements for dissolution of fresh uranium metal receipts and [Proprietary Information]. [Proprietary Information] dissolution stoichiometry is described by Equation 1. The uranium metal dissolution reaction is described by Equation 6.

Equation 6

[Proprietary Information]

The target fabrication process is based on a nominal production rate that fabricates [Proprietary Information]. Once steady-state operation has been established, fresh uranium metal dissolution is estimated to be required equivalent to [Proprietary Information] as makeup for recycled uranium process losses in the target fabrication system.

2 of 28

.R W MAIK NWa,-2016-RAI-001. Rev. 0

[Proprietary Information] will be processed by the target fabrication dissolver to address recycling out-of-specification materials generated during target fabrication. For a nominal production load of

[Proprietary Information] if the production process was operated at the bounding throughput described for irradiated target dissolution.

The target fabrication dissolver must also support generation of a fabricated target inventory from fresh uranium metal during the initial year of operation. Table 4-1 ofNWMI-2013-021, Chapter 4, indicates the target fabrication area nominal special nuclear material (SNM) inventory that would be created by fresh metal dissolution in the first year of operation is as follows:

• [Proprietary Information]

• [Proprietary Information]

• [Proprietary Information]

• [Proprietary Information]

The total target fabrication inventory from fresh uranium metal dissolution is [Proprietary Information].

Therefore, the nominal SNM inventory is estimated to create a nominal target inventory of [Proprietary Information]. The bounding target fabrication throughput is capable of producing the targets in approximately [Proprietary Information]. Based on operating 52 weeks/yr, the target fabrication system is available to support steady-state operation in the remaining 50 weeks of the first operating year.

The target fabrication system is not actually capable of supporting the bounding throughput of

[Proprietary Information] used for estimiating bounding NOx emissions from the irradiated target dissolver. Therefore, the target fabrication dissolver is assumed to support uranium recycle at an operating rate of [Proprietary Information]. Therefore, the total uranium dissolved in target fabrication is bounded by [Proprietary Information].

The molecular weight of uranium for LEU containing 20 wt% 235U is [Proprietary Information] such that the first operating year uranium metal dissolved is [Proprietary Information]. Based on Equation 6, the bounding target fabrication dissolver source term from fresh uranium metal dissolution is described by Equation 7.

Equation 7

[Proprietary Information]

Nitrogen oxides generated by dissolution of [Proprietary Information] is difficult to predict prior to obtaining actual operating experience. However, conservatism in the bounding fresh metal dissolution estimate (equivalent to producing [Proprietary Information] is considered sufficient to address the uncertainty associated with [Proprietary Information].

Offgas from the target fabrication dissolver is routed, via the process vessel vent system, to the Zone I exhaust plenum for emission via the Zone I exhaust stack. Offgas treatment for removal of NOx from the target fabrication dissolver is not included in the current design because it represents a relatively small emission source. Inclusion of a target fabrication dissolver condenser may be found to be required for liquid level control in final design activities, along with other process steps that reduce the quantity of NO* emitted from the facility stack.

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BIIAI.BNWMI-2016-RAI-001, Rev. 0 Table 1 provides a summary of the source terms and stack emissions for NOx generated by the RPF process systems.

Table 1. Summary of Radioisotope Production Facility Process System NOx Source Terms and Stack Emissions Irradiated target dissolution 540 kg NOR/yr as NO2 0.14 kg NON/yr as NO 2 Facility total 582.5 kg NOx/yr as NO2 42.64 kg NOx/yr as NO2 NO2 = nitrogen dioxide. N =nitrogen oxides.

Primary process system reactions do not generate quantities of CO 2 or SO 2 as reaction products.

However, actual materials may generate trace quantities of these components due to the presence of impurities or solution radiolysis. As an example, offgas from dissolution of uranium metal is reported to contain nitrous oxide (N2 0), CO 2 , carbon monoxide (CO), and hydrogen gas (1-12) at concentrations that are approximately 0.1 percent of the total NOx (NO + NO 2) generated. Formation of CO 2 and CO is attributed to the dissolution of carbon impurities in the uranium that was dissolved. While H2 and oxygen (02) are the dominant components produced by aqueous solution radiolysis, there is a potential for RPF solutions containing nitrate and sulfate solutes to generated trace quantities on NOx and SO 2 from radiolysis. The trace sources of these potential emissions have not been quantified and are unlikely to be present at measurable concentrations in the stack emissions.

9 -9 - 9 99 9 9 9 The planned inventory is approximately 53 gallons (gal), and depending on nominal versus maximum target production rate, the tumnover rate is estimated at 1 to 2 times per year.

AIR-2 Th. IGaci i esuiz NRE 537, Pat , S~c~n194.2,'i ulZ n ~e ttsta h

• EDFh -31244OOOI, 2015.,Estimat fxwalnfrhe NM Rd1otp*od o Faiy*,Rev.3, Porzage, Inc.,Idh Falls,Idaho, Febrwii2,201...

• I DF -3124-(X).,,42015. Caclto1frteDtemnto of Fgtv hawn ct iesfrom Coiuton&juipem Re.1, PotgIn. dh Falsjd*o F .iwi 321.

• 1 1244)0,04 nRa msin o eade uigCntuto.Rv .Prae Inc,,

Idio.'llIao June6 04

• EDF-314(), 2014, DeterminatIonof Wid-Blw Z*tdrn CowrcincliisRv 0, Portage,lnc., Idaho Falls,Idaho, ue6 2014.  ; "

"EDF-31240X9 2040fRa m;in durngC'ostut *,Re.0, Potg n. *~

al, Idaho, June 26, 2014,...

• EDF-312-04,2014. Ems(nMoeigfor ConsrutinAcivts:U*m A*SRE; 0, Portage,Inc., Idaho Falls,Idaho, June 26.2014.

The most recent revisions of the requested reference documents listed above are attached in Appendix A, B, C, D, E, and F, respectively.

4 of 28

NVVMI-2016-RAI-001, Rev. 0

~NM

-S * ~** S S - S The selection university of potential research reactorRPFthat sites couldwas initially provide driven by irradiation the requirement services to be co-located near a for the majority of NWMI molybdenum-99 (99Mo) production. In addition, the university reactor needed to have:

• Experience supporting government and commercial industries

• Capability to support commercial irradiation on a regular basis

• Core configuration that could accept the NWMI targets

• Power required to meet the irradiation requirements From a broad list of potential locations, NWMI conducted an informal evaluation process based on the experience and knowledge to down-select to the four sites for a more detailed evaluation.

As stated above, NWMI initially considered sites near a multitude of existing research and test reactors and down-selected based on the knowledge and experience of the team. The initial down-select did not include any specific regional or State-wide factors.

AL2 I0 FR51 4Sb3 n th S nmntn UE-537,Part 1,Scto 1.5 "Atenaivs Asstated inRNM ta sho13021sChapether h1t0, pand192 (pagrocesusedoformuae Thbe rea8)sonabledoth aiig lrternaetiblis.hedcn 19anfteE sn edl valbepbi tts htN/i nomtion osdrd theUniervain rmsiteoviisou its the sites were scored using a scale of 1 to 5 (5 being most favorable, 1 being least). The NWMI team determined that all four of the sites are viable and acceptable, with Discovery Ridge selected as the preferred site of the proposed RPF (see Table 19-88 ["Evaluation of Alternative Sites"]). .... The Discovery Ridge site total weighted score of 82 percent was followed by the MURR location. Given the high weighting of certain criteria (i.e., political and local logistical support, facility operations, and production logistics) and high scores for these criteria, the MURR and Discovery Ridge sites have an advantage over both the proposed McClellan Business Park and OSTR sites.

The proposed site at the McClellan Business Park ranks fourth for the RPF location. The McClellan Business Park score was 34 percentage points lower than the Discovery Ridge site, primarily due to a lack of political and local support, Federal and state taxes and incentives, limited available greenfleld space, and weaker ties to the UC Davis reactor team. However, the site's strengths include an existing building and abundant available space. The OSTR site, which ranked third, had limited available space, transportation routes, and State and local financial incentives.

In consideration of these factors, the Discovery Ridge site was selected as the proposed site for the RPF.

The siting alternatives of the MNRC Business Park and OSTR locations were not further evaluated. The MURR site was considered to be viable and was identified as a reasonable alternative; its evaluation is provided in the following subsections..."

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NWMI-2016-RAI-001, Rev. 0

• NWMI

.. S The factors NWMI considered to make this determination include the following (Table 19-88):

° Political and local logistics support

• Facility operations

• Production logistics

• Transportation

• Radioactive, hazardous, and mixed secondary waste generation (e.g., air, liquids, solids)

• Federal, State, county, and local requirements to construct and operate facility

• Federal and State taxes and incentives

• Available space

• Construction costs

• Natural or human-made disaster potential ea2410CFR5h 5b3 tad th ISGagetn UE 137 at1 eto 95"le stat tha ER sho....ld sumrz th itr n rcs sd of uaeteraoal The "Production Logistics" score for MURR is incorrect. This value should have been a "4," the same as Discovery Ridge site, with a weighted value of 40. In addition, the "Facility Operations" and "Construction costs" for MURR were incorrect and should have been "2" for a weighted value of "20" and "3" for a weighted value of "6," respectively. The "'Facility Operations" rating was due to the ability to operate a RPF in conjunction in a limited space and would be managed by MURR personnel not NWMI. The "Construction Costs" rating was lower than Discovery Ridge due to the limited space available next to the MURR reactor building for initial construction or future expansion and the need for the construction of below-grade connection to the reactor. The total corrected score for MUJRR is 217 with a weighted percentage of 72 percent. A revised Table 19-88 is provided below.

Table 19-88. Evaluation of Alternative Sites (2 pages)

- - * - I Political and local logistics support 4 40 4 40 4 40 1 10 Facilt operaton 4 40 2 20 3 30 3 30 Production logistics Radioactive, hazardous, and mixed secondary 4 32 4 32 4 32 3 24 waste generation (i.e., air, liquids, solids)

Federal and State taxes and incentives 5 15 5 15 3 9 1 3 Availablespe 5 15 3 9 1 3 2 6 6 of 28

NV MINWMI-06RIO, Rev. 0 Table 19-88. Evaluation of Alternative Sites (2 pages)

I---

Construction costs 4 8 3 6 3 6 3 6

.......... diatcpoc ill3 344 Total 245 217 190 145

........... ........... 2%7 %63% 48%

DR =Discovery Ridge. MURR =University of Missouri Research Reactor.

MNRC =McClellan Nuclear Research Center. OSTR = Oregon State University TRIGA Reactor.

Discovery Ridge and MURR were given a score of "4," because with placement of the RPF in either of those locations, the primary university reactor that provides the bulk of irradiation services for NWMI would be near (less than 20 miles from) the RPF. Transport of irradiated targets from either Discovery Ridge or MURR would not require crossing significant mountain ranges (e.g., Rocky Mountains) that could result in potential delays due to inclement weather. Because time is critical to NWMI's business, a site in close proximity to the irradiating reactor is preferable.

The second major bullet and associated second and third sub-bullets in NWMI-2015-RAI-001, Response to the U.S. Nuclear Regulatory Commission Request for Additional Information, EnvironmentalReview of the Northwest MedicalIsotopes, LLC ConstructionPermit Application, Appendix E, Page 21, stating that "all routes require crossing significant mountain ranges" and "If RPF was located at Discovery Ridge/MURR, more Rocky Mountain crossings may increase the probability of delays," was in error for the Discovery Ridge and MURR sites. These statements were intended to be applicable only to the McClellan and OSTR sites. The difference between a score of 2 for OSTR and 3 for McClellan was based on the additional distance and travel time required to ship irradiated targets from their respective site to the RPF (i.e., 200 miles or an additional 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of travel time farther to OSTR than McClellan).

McClellan was given a score of "3" due to the additional regulatory requirements by the state of California for the transport and disposal of any waste generated.

The regulatory requirements associated with storage, transportation, and disposal of waste are more rigorous in the state of California than in the states of Missouri and Oregon. Thus, a lower score was given to McClellan.

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NWMI-2016-RAI-001, Rev. 0 NWMI McClellan was expected to have additional or more significant State and local requirement than the other three sites. For example, the state of California requires a separate State Environmental Policy Act under the Califomnia Environmental Quality Act (CEQA) action for any new processing facility. In addition, the State (e.g., California Code of Regulations) and local requirements are expected to be more stringent and broader in scope in Califomia (e.g., McClellan) than Federal regulations and less so at the other three sites. For example, if and when the waste leaves the state of California, the waste is treated as nonhazardous; for this reason, treating and disposing of hazardous waste in California is preferable in terms of environmental protection because California's protocols are more rigorous in comparison to those in Federal Resource Conservation and Recovery Act (RCRA) regulations and other State regulations.

The state of California, in general, has more stringent regulatory requirements that either the state of Missouri or Oregon. For example, if the RPF was to be sited at the McClellan site, the state of California would require a separate CEQA action for any new processing facility that is comparable to preparing a separate environmental impact statement.

OS Ra score of 3*an icvr*dge an U RasoeofSgvnta reo osnthv The state of Missouri offers several incentives that help provide a score of 5 compared to the other locations. Some of these incentives include the following:

• Statewide works - This program provides significant state incentives for eligible companies creating new jobs in Missouri; the incentives of the program are the retention of the State withholding tax.

• Customized training grant - This program provides customized training to employees that will help meet the specific needs of the employer through classroom skill training.

• Recruitment assistance - The Division of Workforce Development offers personalized recruitment assistance to help businesses meet their labor needs.

• Energy exemption - As of August 28, 2007, the state of Missouri allows manufacturers an exemption on energy purchases. These items may be exempted from State tax (4.225 percent) and local use tax, but not local sales tax.

• Sales/use tax exemption - Machinery and equipment used to establish a new or expand an existing manufacturing facility is tax-exempt, provided such machinery/equipment is used directly to manufacture a product ultimately intended for sale.

T* for*A future.epansion OSTR was given a score of"l" due to the potential site provided by the university to NWMI was less than 1.0 hectares (ha) (2.5 acres) in size and no future expansion would be available.

NWMI-2015-RAI-001, Appendix E, '"NWMI Site Alternative Study," page 25, OSU Bullet 2, was in error. In addition, McClellan was given a score of'"2" due to the limitations on the existing buildings and airport tarmac adjacent to the site (e.g., no construction can occur on the existing tarmac).

8 of 28

NWMI-2016-RAI-001, Rev. 0 1 1VIHl NJ:;..*

I 9 - 9 6 NWMI-2015-RAI-001 states in RAI ALT-2B that construction costs would be higher at MURR and OSTR than at Discovery Ridge. This statement is based on the land area constraints that were given for both MURR and OSTR. Discovery Ridge is a "greenfield" area that has been broken into three phases for development. Lot 15 of Discovery Ridge is part of the Phase II development, which has over 22.5 ha (60 acres) for development. The MURR score of "4" for construction costs was in error in NWMI-2015-RAI-001, Appendix E, page 26; this score should have been "3," as stated in RAI ALT-2B.

ALT2-3A provides the revised table.

Based on similar work performed in the industry, the refurbishment of the overhead crane will nominally take two days and be performed by two individuals from a qualified mechanical subcontractor.

Management high water table elevations: As described in our response to WAT2-1, NWMI does not anticipate a high water table at the RPF site. There is no historical groundwater data specifically for the RPF site at Discovery Ridge. The nearest United States (U.S.) Geological Survey monitoring well provides an indication of the historical groundwater fluctuation and seasonal trends. The depth to groundwater at that well has varied from a minimum of 22.9 meters (in) (75 feet [if]) to a maximum over 61 m (200 if). Other monitoring wells in the area show a static water level from 55 to 99 m (180 to 325 if) below the surface, while two wells drilled approximately 1.6 kilometer (kin) (1 mile [mi]) east of the site encountered water at 10.97 and 11.89 m (36 and 39 if). The response to WAT2-1 provides plausible explanations as to why water was found in two of the nine boreholes drilled across the Discovery Ridge site (Terracon, 2011).

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NW M!III NWM,-2016-RA,-001, Rev. 0 Additional borings, within the RPF boundary, are planned. If the analysis of these new borings discovers high water tables, the final design will address that issue in detail.

Projected rate and duration of dewatering: NWMI does not anticipate a high water table or to encounter significant groundwater at the site. However, if encountered, as noted in NWMI-20 13-021, Section 19.4.4.1.1, some dewatering due to groundwater and precipitation may be required during construction at the deepest excavation. Any water would be collected in a detention/retention pond. The dewatering rate is anticipated to be controlled by the precipitation for the site during the construction period. Section 19.3.2.1.2 states, on a monthly basis, rainfall amounts range from a high of 12.4 centimeters (cm) (4.89 inches [in.]) in May to a low of 4.62 cm (1.82 in.) in January. The proposed lot for the RPF at Discovery Ridge is approximately 3.0 ha (7.4 acres). Using the maximum rainfall rate and the entire site area, a conservative estimate of less than 1,400 g/hour (hr) is reasonable. The size of the excavation is a small fraction of the entire site area, so this estimate is conservative. The duration of the civil and foundation work is estimated at three to six months. The duration of the dewatering would be a fraction of the total duration (i.e., only when there is precipitation).

Potential impacts on local groundwater sources and direction of flow: NWMI does not anticipate any detrimental impact to local groundwater sources or directions of flow. As described in the response to WAT2-1, the site does not interact directly with local aquifers. Surface run-off would be collected in a detention/retention pond.

Facility design considerations for permanently or seasonally high water tables: The RPF will have design features to minimize the impacts of any seasonal high water tables. Foundations will be protected from water with barrier systems (e.g., sealants) and drainage will be provided to channel water away from the RPF.

Implications for facility operations: NWMI does not anticipate any impact on facility operations due to groundwater issues. . .... . .. . .. .. . . . . .. .

S - . ~.. S - S S The calculations for transportation of materials for the RPF (EDF-3 124-0010, Radiological Dose Consequences Associated with Transportationof Materialsfor the NWMI Radioisotope Production Facility) assumed a dose rate of 10 milliroentgen (mR)/hr at one meter for the transportation cask used to transport the 99Mo product. Using the inverse square law (R1D12 = RiD 22 ), the dose to the public when the plane is at a cruising altitude of 6,200 m (20,000 ft) would be 2.6E-7 mR/hr. This dose is significantly lower than background.

10 of 28

NWMI lv.l ,

Chaper 1ruTale 11- ofeNaMIonal,-and eoisspoiddon tefoing be 11n2paigtes PnR in Chaptder11tled Te stweek radionulides ed gaueos

[ releaes) genderte norma t peratingmcoditons.aewr upidb doswek to oti thepuelics fromthes inorma operationals iacreleases weeudjsed ind termining va10ely account for one high-efficiency particulate air (HEPA) filter in the Zone I heating, ventilation, and air conditioning (H-VAC) offgas treatment system (Chapter 9, "Auxiliary Systems," Section 9.1.2.2) in accordance with EPA 520/1-89-003, User's Guide for the COMPLY Code, which recommends that radionuclide particulate releases be reduced by an adjustment factor of 0.01. The noble gases and iodine releases were not reduced in the analysis. The following radionuclides were not available in the COMPLY database: l36 tuBa, l37 tuBa, 133mi, 97myb 23 6rmNp, 23 4 mpa, l"2 pd '""'4pr, 10R' 285b' 12SSb, and The following assumptions were used in the development of the analysis:

• Meteorologic~al data - COMPLY meteorological wind rose file for Columbia, Missouri

• Stack data - Stack height 22.9 m (75 ft), diameter of 0.86 m (34 in.)

• Building data - Height 19.8 m (65 ft), width 24.4 m (80 fi), length 76.2 m (250 ft)

• Receptor location - Nearest receptor locations is the RPF fence line at 9.1 m (30 fi) from the stack

• Agricultural data - Food sources (e.g., milk, meat, vegetables) assumed to be home grown at receptor location The maximum dose to the public from the normal operational stack releases was calculated to be 0.036 millisievert (mSv)/yr (3.6 millirem [mrem]/yr) at 9.1 m (30 fi) from the RPF. The results of the COMPLY analysis determine that the requirement of 10 CFR 20.1101, "Radiation Protection Programs,"

item (d) will be met for the RPF, such that air emissions of radioactive material to the environment will not result in a member of the public receiving a total effective dose equivalent (TEDE) in excess of 0.1 mSv/yr (10 mrem/yr) from these emissions.

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NV IVINWMI-06RIO1 Rev. 0 Table 11-2. Radionuclide Stack Release Source Term Input to COMPLY (2 pages)

S*S.... ...5 4Am8.67E-17 237Np 1.63E-12 89 Sr 3.69E-02 91 l37mBa 2.89E'06 Z3Np 3.49E-04 Sr 2.36E-02

'!Ba 1.Q3E)5 *;  ! 4.14 !31-O 2

'*13a 7.99E-04 *Pa 1.59E-12 99Tc 4.04E-08 I43Ce 3.52E-04 " 2pd 7.43E-07 I2StaTe 8.55E-07 9.89. 5 '*P 9.39E06 ' 7 Ti 9.1E 27 3Cs4.92E-10O4p 5.81E-09 l raTe 1.12E-04 16s7.16E-07 49m6.44E-05 2roe9.73E-04

'55Eu 1.03E-07 151 Pm 2.47E-05 I3IraTe 2.39E-03

' 57 Eu 3.28E-07 143 pr 8.15E-04 133Te 1.38E-05

... .. 1.90E-i3 14 P ,~7f4 6...3E6 1317.17E-08 144mpr 1.38E-06 34e1.78E-05

• I5.97E-4 ,]4p L 14E-4 m .34 1132 1.56E-03 23pu 1.31E-12 234U 2.48E-06 8.I65E-0

• u 3.5E0 14E0 24

]331 2.62E-03 °pud 2.58E-12 23U3.82E-08

]*4.36E-07 2 9,31E-13 2',,-~

13I2.69E-05 1O3m~h 2.74E-04 23U7.15E-08 1354 1.36E-03 IRh 6.40EQ5* "L6+0 83 33 m}Qr 3.81E-10 '°6Rh 5.70E-06 ' Xe 4.98E+02 SSKr 5.84E+01 1.O05E,08 1*8 977*

85 1 3 35 mfr 1.92E-03 ° Ru 2.75E-04 1 Xe 9.5 1E-20 aKr 1.80E-23 ,!5y,2.12E.05 I.46 -27 88Kr 1.16E-07 '°*Ru 5.70E-06 89y3.43E'06 "4'La 8.64E0 42S 3 8E-1 2.4F.O l 41La 1.11E-04 24

' Sb 6.56E- 10 9y5.70E-09 9

99M0 3.40E-04 '26Sb 1.10E-07 Imy 1.50E-02 95Nb 1.68E-04 ')S 1.02E4 5 2.Q3,Q2 95m~b 4.64E-06 aSb9.42E-07 9y2.68E-02 Nb3.06E-08 . .. SE4YI i?*!  ::Zr *6.12H9 95 97Nb 3.37E-04 ' *Sb 1.14E-05 Zr 4.29E-02 97Nb, 2.98E0 '5 Sm 6.84E-Q ': Z 3.44O 47d2.8 1E-04 '53Sm 9.44E-06 Total Ci 7.24FE-02 2*sNp 9,02E:15 'SSSm6....... "

I I I I T][ [ ] T Sources: Barrington, C., 2015, "NWMI Release # 11 - Process Vessel Ventilation (PVV) System Estimate," (memorandum to G. Dunford, May 26), AEM Consulting, LLC, Richland, Washington, 2015, and NWMI-2013-CALC-006, Overall Summary MaterialBalance - MURR Target Batch, Rev. D, Northwest Medical Isotopes, LLC, Corvallis, Oregon, 2015.

12 of 28

NWMI-2016-RAI-001, Rev. 0

~NWNH NWMI programwill willestablish a liquid enviromnmental include baseline sampling program for the area around the RPF. The sampling and routine sampling. The program will also include ad hoc sampling to be performed in the event of a liquid radiological release to determine the environmental impact and associated dose to the public.

NWMI programwill willestablish a liquid environmental sampling program for the area around the RPF. The include baseline sampling and routine sampling to determine and quantify the impacts of normal effluents from the vent stack emissions. The sampling program will include sampling of nearby surface water and the groundwater monitoring wells.

The TEDE nearest to line fence the public located outside at the controlled area would be from 3.6 mSv (0.36 rem) at the 10 m (30 fi) to 7 mSv (0.70 rem) at the furthest fence line 91 m (300 ft). The TEDE to the nearest resident located 430 m away was calculated to be 31 mSv (3.1 rem). The highest TEDE to the licensee staff outside the building would be 7 mSv (0.70 rem) for a person located 91 m (300 ft) from the location of the stack. The calculations are provided in EDF-3 124-0003, PreliminaryMaximum Hypothetical Accident to Support the Northwest Medical Isotope Facility EnvironmentalReport. The TEDE doses are greater than the limits of 10 CFR 20, "Standards for Protection Against Radiation."

However, 10 CRF 20 limits are for normal operations not accident situations. The TEDE indicates that the maximum hypothetical accident (MHA) is the intermediate consequence event per 10 CFR 70.61, "Performance Requirements."

13 of 28

NWMI-2016-RAI-001, Rev. 0

• • ,*!,'*. Nt^tKnl 111 If V IWll

. ~.. S S

• S The requested reference document is attached in Appendix G. EDF-3 124-0003 has been updated to Revision 2, which is the version attached in Appendix G. There are three minor differences between NWMI-2013-021 and this appendix, including:

• Stack height is 75 ft. In EDF-3 124-0003, 22.86 and 22.9 m are both used in the text. The actual calculations use the non-rounded stack height of 22.86 m (75 fi).

• Density of air in the actual calculation of the EDF was 1,240 g/m 3; however, the text in NWMI-2013-021, Chapters 3 and 19, was in error and stated 1,250 g/m3 .

• EDF-3 124-0003 (Rev. 2) was updated to reflect a 1.32 safety margin in the inventory (consistent with Chapter 13). As part of the updated calculations, the model results were truncated at 1,500 m (4,921 fI) away versus the 1,700 m (5,577 ft) results presented in EDF-3124-0003 (Rev. 1) and NWMI-2013-021, Chapters 13 and 19.

Baseline noise levels were modeled using peak traffic counts for U.S. Highway 63 in Missouri for traffic traveling at 112.7 km/hr (70 mi/hr). Using these traffic counts, the modeled baseline noise level is 68.8 dBA (A-weighted decibel) at the nearest residence.

Peak traffic counts used in the baseline noise modeling were 818 in the southbound lane and 1,002 in the northbound lane. Peak traffic counts used to assess facility impact were 918 in the southbound lane and 1,102 in the northbound lane (an increase of 100 vehicles traveling on U.S. Highway 63).

The nearest resident used in noise modeling is nearest to both U.S. Highway 63 and to the proposed RPF.

Approximate distance to the residence from U.S. Highway 63 is 85.3 m (280 ft), and the distance to the proposed RPF site is 792.5 m (2,600 fI).

14 of 28

a a. a am a.

.tuu.u..u*..

NWMI-2016-RAI-001, Rev. 0

• V. *~~~*~*V S - S .55 5 - V S Preconstruction activities are those that are not considered construction activities under the definition of construction currently provided in 10 CFR 51.4, "Definitions." Based on this definition, NWMI considers the following activities as preconstruction:

• Site exploration, including boring to determine foundation conditions and other preconstruction monitoring

• Site preparation, including clearing and grubbing, grading, installation of drainage, erosion and other environmental mitigation measures, and construction of temporary roads and borrow areas

• Erection of fences and other access control measures that are not safety- or security-related or pertain to radiological controls

• Facility excavation

• Construction of support buildings for use in connection with the construction of the proposed RPF, including construction equipment storage sheds, warehouse and shop facilities, utilities, concrete mixing plants, docking and unloading facilities, and office buildings

• Construction of service facilities, including paved roads, parking lots, exterior utility and lighting systems, potable water systems, sanitary sewerage treatment facilities, and electrical systems

• Procurement or fabrication of components or portions of the proposed RPF occurring at other than the final, in-place location at the facility

• Erection of buildings that wvill be used for activities other than operation of the proposed RPF and that may also be used to house a training or laboratory facility The total duration of preconstruction activities is estimated to be approximately 60 days immediately prior to the start of construction except for site exploration and long-lead procurements. Site exploration will be completed in the second quarter of 2016 to support the completion of the RPF final design and construction drawings. In addition, long-lead procurements of components for the proposed RPF that occur at other than the final, in-place location will be initiated prior to construction. The impacts of these preconstruction activities are included in our construction activity analysis.

The average and peak-workforce required during preconstruction activities is estimated to be 40 percent of the peak and average workforce required for all RPF installations or a peak of 33 and average of 15.

The average number of delivery trucks during preconstruction is estimated at an average of 20 vehicles per week. Offsite shipments of waste and debris is estimated at an average of one per week during preconstruction activities.

15 of 28

NWMI-2016-RAI-001, Rev. 0 As stated in Table 19-6 of NWMI-2013-021, the majority of the diesel fuel consumed during the RiPF installation would be during the first three months of construction. These three months coincide with the preconstruction phase. Based on the average rate of 1,647 liters (L)/month (435 gal/month), the total fuel consumption is estimated at 28,000 L (7,395 gal) of diesel. Approximately 70 percent of the total 19,600 L (5,180 gal) are estimated to be used during preconstruction.

The majority of the water consumed during the RPF installation would be used during preconstruction activities. The volume of water required during preconstruction activities is estimated at less than 7,571 L/day (2,000 gal/day). The source of the water would be the Consolidated Public Water Supply District # 1.

100 percent of Discovery Ridge Lot 15 (2.99 ha [7.4 acres]) will be cleared and grubbed during preconstruction activities.

Tabl 19-7 of the E Table 2 provides an estimate of the percentage of material presented in Table 19-7 of NWMI-2013-021 that is assumed to be consumed during the preconstruction portion of activities.

Table 2. Percentage of Materials Consumed During Preconstruction Phase Concrete 5% 3,257 m3 4,260 yd3 Asphalt 95% 245 m3 320 yd3 Miscellaneou 2% 45 t 50 tons Roofing 8% 4,645 m2 50,000 ft2 s steel Ste ie %17t 100) rc~ %435 t 40' u

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

The number of hours and material moved for the preconstruction portion of RPF installation activities for the equipment identified in Table 19-51 of NWMI-20 13-021 are identified in Table 3.

16 of 28

NWMmUIKI NWI21-A-ORev. 0 Table 3. Number of Hours and Material Moved for the Preconstruction Portion of the Radioisotope Production Facility Installation Bulldozing 100 N/A N/A 10,886 12,000 Loading of earth haulers from front loaders 30 100 2I;772 24,000 Compacting 64 N/A N/A Moto p'~n 64 N/A N/A N/A =not applicable. . . . . ii I I i¸ i I i i S a .. 5r5 5 The duration of RiPF decommissioning activities is estimated to take 18 to 24 months.

The values in Table 19-6 and Table 19-14 are effectively the same. The Table 19-6 number of offsite shipments was rounded up from 9.4 to 10 (for bounding purposes) when converted to shipments per week. Thus, 486 shipments per year divided by 52 weeks was rounded up to 10 shipments per week.

17 of 28

NWMI-2016-RAI-001, Rev. 0

..'.,i, NWM I I .

PA2-3 During the pre-operations phase, the RPF will receive chemicals and process supplies needed to complete construction and operability testing. A small quantity of natural or depleted uranium will also be received for equipment testing and process testing. The natural uranium will have to be flushed from the system and disposed of before LEU operations. No irradiated material will be handled in this phase; therefore, no corresponding data is shown in Table 19-14 of NWMI-2013-021.

S -S - S .55 5 - S - S 18 of 28

NWMI-2016-RAI-001, Rev. 0 N*-9.*11WNHIW There is no historical groundwater datakm specifically RPF site. (Latitude monitoring well (USGS, 2016) is 11.9 (7.4 mi) toforthethenorthwest The nearest U.S. Geological Survey 38057'1811, Longitude 92023142 NAD83) of the RPF site. This well provides an indication of the historical groundwater fluctuation and seasonal trends. Figure 1 shows the water level over the past seven years. The depth to groundwater at that well has varied from a minimum of 22.9 m (75 fi) to a maximum over 60.96 m (200 ft). As shown in Figure 1, the groundwater level normally peaks in July, dropping from 7.6 to 15.2 m (25 to 50 fi) in October.

Depth to water level, feet below land surface Most recent instantaneous value: 155.83 01-20-2016 13:0O0 CST USGS 395718892234201. Coluwbia 50 0 199

.0 550 ==

I 150

.g.

'I. 4588 299 250 2181_ 2911 2912 2913 2914 2915 2916

-Depth to seater level mmPeriod of provisional data

-m Period of approved data Source: USGS, 2016, "'USGS National Water Information System: Web Interface," http://waterdata.usgs.gov/nwis?progrmm

--uv&site_no=385718092234201 &agency cd=USGS, U.S. Geological Survey, Reston, Virginia, accessed January 20, 2016.

Figure i. U.S. Geological Survey Well 385718092234201 Depth to Water (WAT2-1lA-1)

S .55 5 . S . S There are no current Piezometric contour maps of the area. Figure 19-37 of NWMiI-20 13-02 1 provides the current water table contour map of the site. Figure 2 (on the following page) provides a map of the hydraulic gradient and groundwater flow direction map near and around Discovery Ridge.

19 of 28

NWMI-2016-RAI-001, Rev. 0 NWM!

v Groundwater Elevation and Flow Direction (1 ft Contours)

.. RPF Site O* 8 km (5 mile) Radius from RLPF Site

• Interstate Highways

+ Q

-Highways City Limits o 0.5 1 2 3 4 m

• Miles Figure 2. Hydraulic Gradient and Groundwater Flow Direction Map (WAT2-IB-I) 20 of 28

NWMI-201 6-RAI-001, Rev. 0 NWMI 0 - 0 .00 0 0

• The Mississippian aquifer is unconfmned in the Boone County area and underlies Discovery Ridge. The site has an estimated depth from 22.9 to 67.1 m (75 to 220 if) below the ground surface.

Figure 3 (on the following page) shows the location of the wells within 1.6 km (1-mi) radius of the RPF site (MDNR, 2006 and MDNR, 2014). Table 4 provides the historical data associated with each well recorded when the well was drilled. These wells primarily show a static water level from 55 to 99 m (180 to 325 ft) below the surface. Two monitoring wells drilled approximately 1.6 km (1 mi) east of the RPF site encountered water at 10.97 and 11.89 m (36 and 39 ft). No additional information is available on these boreholes or the water encountered.

Table 4. Historical Data For Wells Within A 1-Mile Radius of the Radioisotope Production Facility Site a - 0 -.

13947 Conmmunity public well University of Missouri- 9/13/55 587 60 270 810 Columbia 525 40 17896 Private well Phillips Angus Farm 11/20/58 505 300 792 1961 600 50 20980 Community public well Edwin Gose Trailer Park 797 70 24126 Community public well Boone Co Cons PWSD #1 12/1/65 1,190 60 300 820 192112 Water Not identified 7/8/97 720 - 180 394516 Domestic Not identified 10/20/06 766 - 200 807:i 408872 Heat pump Not idenltifed 4/1/10 187 10118/113 487832 Soil boring Not identified 104 10/18/13 487834 Monitoring Not identified 40 - 36 Sources: MDNR, 2014, "MIO 2014 Wells (SHP) Geospatial Data," ftp://mnsdis.missouri.edu/pub/

GeologicalCGeophysical/MO_2014_Wells_shp.zip, Missouri Department of Natural Resources, Jefferson City, Missouri, 2014.

MDNR, 2006, "MO 2006 Well Logs (SHP) Geospatial Data," ftp://msdis.rnissouri.edu/pub/

GeologicalGeophysical/MO_2006_Well_Logs shp.zip, Missouri Department of Natural Resources, Jefferson City, Missouri, 2014.

21 of 28

NVVMI-2016-RAI-001, Rev. 0 NWYM I

?.'::,

Groundwater Wells I NWMI Site

-Highways

+ *.** City Limits 0 0.125 0.25 0.5 0.75 1 Miles Figure 3. Wells Located within 1.6 Kilometer (1-Mile) Radius of the Radioisotope Production Facility Site (WAT2-1D-1) 22 of 28

NWMI-2016-RAI-001, Rev. 0 NWI~ffl Figure 4 provides a qualitative description of the groundwater aquifers (i.e., hydrostratigraphy) in the Columbia, Missouri area.

Fonndton wefltC,3fli 2ep*t Columbia Observation Well Water Level Hydrograph Geologic Well Log 1C00 -------------- O-------------2---0 !U~/2O1O !2/2/2012 Massissipp~an Aquifer 10 Burlington/Keokuk Ls

' OSedalia Fm Compton Ls Deoia yse 300 --- - - - 1 Cambnan-Or'dovician Con fining Unto ..... ....................

-- Cotter Dot ito-- - - ----- =-_______l '-Jefferson City Dot

-S

• ' i-Roubidoux Fm

,-Upper Gasconade Co170 Cambrian-Ordfovcian Aquifer

-Lower Gasconade Dot 9 00sGUnter Ss ita-'

-Eminence Dot

-Potosi Dol Water level data 12129/2000 - 226/2014 E~pth=ia53f~t St. Francois Cornfirnng Unit D*erby-Doerun Dol 1400 Source: MDNR, 2016, "Well Log No. 23501, Strathydrograph," http://dntr.mo.gov/geology/wrc/groundwvaterf strathydrographs/columbia.pdf, Missouri Department of Natural Resources, Jefferson City, Missouri, accessed January 25, 2016.

Figure 4. Columbia Observation Well (WAT2-1E-1) 23 of 28

NVVMI-2016-RAI-001, Rev. 0 NWI

- . ... .

• S S There are two significant aquifers that underlie the RPF site: the Mississippian and Cambrian-Ordovician aquifers. The Mississippian aquifer is the uppermost aquifer in Paleozoic rocks in northern Missouri. The Mississippian aquifer underlies all of Missouri north of the Missouri River except for small areas near the Mississippi and Missouri Rivers where rocks composing the aquifer have been removed by erosion. The name "Mississippian" was given to this aquifer because it consists of limestone of Mississippian age. The geologic units that compose this aquifer include the Keokuk, Burlington, Fern Glen, Sedalia, and Chouteau Limestones. Of these formations, the Keokuk and the Burlington Limestones are the principal water-yielding units. Both formations consist of crystalline limestone and yield water primarily from solution cavities. In most places, the Mississippian aquifer is overlain by a confining unit of Pennsylvanian shale and sandstone and regionally the entire aquifer is underlain by a confining unit of Mississippian shale (USGS, 1997). However, based on the review of nearby well log data obtained from the Missouri Department of Natural Resources (MDNR) geographic information systems (GIS) database for wells located within a 1.6 km (1-mi) radius of the subject property, no Pennsylvanian shale or sandstone was noted. Only the eastern one-third of the Mississippian aquifer contains freshwater; the remaining two-thirds contain slightly saline to very saline water. Therefore, the chemical quality of the Mississippian aquifer varies extensively throughout the aquifer (USGS, 1997). Additional detail on water quality is provided in Section 19.3.4.2.2 ofNWMI-2013-021.

The Mississippian aquifer averages about 60.96 m (200 if) thick in Boone County but exceeds 121.9 m (400 if) in northwestern Missouri. The thinnest portion of the aquifer is near the Mississippi and Missouri Rivers, where the aquifer has been dissected or partially removed by erosion.

The Cambrian-Ordovician aquifer system underlies the Mississippian aquifer in Columbia, Missouri north of the Missouri River. The Cambrian-Ordovician aquifer system contains very productive aquifers throughout an area of approximately 416,988 km 2 (161,000 mi 2) in Minnesota, Wisconsin, Iowa, northern Missouri, and northern Illinois. Many metropolitan areas depend on this aquifer system for municipal and industrial water supplies. The aquifer system is also used extensively for self-supplied industrial, rural, and domestic water supplies (USGS, 1992).

The Cambrian-Ordovician aquifer system is designated as one of 16 sandstone principal aquifers that underlies the U.S. The aquifer system includes several carbonate (limestone and dolomite) rock units with shale layers. Some of the sandstones are interbedded with carbonate units or, in places, contain secondary carbonate mineralization as cementation between grains. The Missouri River forms a natural boundary on the southern edge in Missouri and the southwestern edge in western Iowa. South of the Missouri River, the Cambrian and Ordovician rocks are included in the Ozark Plateau aquifer system, which is designated as one of the carbonate principal aquifers (USGS, 2012).

Freshwater is found in the Cambrian-Ordovician aquifer along a band approximately 80.5 km (50 mi) wide, which is parallel to and north of the Missouri River from Boone County eastward to the Mississippi River (USGS, 2012).

To better define the strathydrograph underlying the RPF site, two sources were evaluated. These sources include the MDNR strathydrograph for groundwater observation well (Well ID No. 23501, USGS well number 385718092234201 Columbia) located approximately 11.9 km (7.4 mi) to the northwest of the RPF site and well driller logs for wells located near the RPF site.

24 of 28

~.NW MvI NWM,-2016-RAI-001, Rev. 0 Figure 5 provides a strathydrograph for Groundwater Observation Well No. 23501 and provides geologic detail and the observed depths of both the Mississippian and Cambrian-Ordovician aquifers. Though located several miles from the RPF site, this strathydrograph provides an information on the hydrogeology in the region near the RPF site. The Mississippian aquifer is unconfined in this region and has historical daily average water levels that have ranged from a minimum depth of 22.9 m (75 ft) below the ground surface (bgs) to as deep as 67.1 m-bgs (220 ft-bgs).

Geologic well data from four driller's well logs (Well ID Nos. 013947, 017581, 017896, and 020722) located within 1.6 km (1-mi) of the RPF site were also evaluated to estimate the approximate depth to static groundwater level, depth to water-bearing geologic formations, and depth to aquifer systems underlying the RPF site (Figure 3). The GIS well data file reviewed (MDNR, 2006) provides the geologic stratigraphy within these wells as the following:

• Glacial Drift - Ranging from 0-18.3 m-bgs (0-60 ft-bgs), composed of topsoil, sand, clay, residuum, and/or gravel.

• Mississippian System - Ranging from 12.192-18.3 m-bgs (40-60 ft-bgs) and extending to depths of 85.3 m-bgs (280 ft-bgs) (Well ID Nos. 013974 and 017581).

• Ordovician System - Beginning at depths of 85.3 m-bgs (280 ft-bgs) (Well ID Nos. 013974 and 017581) and extending depths up to 182.9 m-bgs (600 ft-bgs) in Well ID)No. 020722.

Static water levels are listed for these four wells at depths ranging from 70.1 to 99 m-bgs (230 to 325 ft-bgs) within the Mississippian and Cambrian-Ordovician aquifers. The MDNR well located nearest the subject property is Well ID No. 013947. This well is located approximately 0.48 km (0.3 mi) west-northwest of the subject property. The static water level measured in this well at the time of drilling (1958) was 82.3 m-bgs (270 ft-bgs).

There are no sole source aquifers in Missouri (EPA, 2016).

Based on the information detailed in RAI WAT2-1A through WAT2-1F, the groundwater identified in Boreholes B-S and B-6 is not a surficial water-table aquifer and not a local water supply source. The source of the water encountered in Borehole B-6 could be from two other sources: (1) perched water from surface infiltration, or (2) potentially brought down the borehole during drilling.

Of the nine boreholes drilled by Terracon (Terracon, 2011) across the Discovery Ridge site, water was only identified in two, Boreholes B-S and B-6. Borehole B-6 was located approximately one-third of a mile to the south of the Borehole B-S and with a surface elevation 7.6 m (25 fi) lower. Borehole B-6 encountered weathered limestone at 5.2 m (17 fi) and refusal at 5.8 m (18.9 ft). Water was identified at a depth of 5.8 m (18.9 ft) for Borehole B-5, located on the eastern edge of the RPF site, and was drilled to 6.1 m (20 ft). According to the drill log, water was encountered at 5.2 m (17 ft) near the interface between sandy lean and fat clay. The water content of fat clay sample collected was 19 percent. This water content was similar to or less than the fat clay sample collected from the other boreholes where no water was encountered.

With the high water content of the soil and clay near the surface (24 and 34 percent, respectively), water could have seeped into the hole during the drilling process and was not noticed by the well logger.

Figure 5 provides a cross-section stratigraphic unit description of Discovery Ridge interpreted from the four Terracon bore holes that line up from east to west across the RPF site. This cross-section supports the potential that the water is not perched. The site-specific geotechnical and hydrological studies will better resolve this question.

25 of 28

NVVMI-2016-RAI-OO1, Rev, 0 S!NWMID 3)5L 3)4 O3) 3)2 801 799~

798.

-J 795' (I)

C, 794.

C 793, z

0 792; C 791

-J w

788 '

787 Ak RFP Bonring LOC atkon

/ /Cross Section Line L]Lot 15

• yr Water Level Figure 5. Discovery Ridge Stratigraphic Unit Description (WATZ-1iD-i) 26 of 28

NW M! NM-06RI 1Rev..0 REFERENCES 10 CFR 20, "Standards for Protection Against Radiation," Code of FederalRegulations, Office of the Federal Register, as amended.

10 CFR 51.4, "Definitions," Code of FederalRegulations, Office of the Federal Register, as amended.

10 CFR 51.45, "Environmental Reports--General Requirements," Code of FederalRegulations, Office of the Federal Register, as amended.

10 CFR 70.61, "Performance Requirements," Code of FederalRegulations, Office of the Federal Register, as amended.

42 U.S.C. § 6901 et seq., "Resource Conservation and Recovery Act of 1976," United States Code, as amended.

Barrington, C., 2015, "NWMI Release # 11 - Process Vessel Ventilation (PVV) System Estimate,"

(memorandum to G. Dunford, May 26), AEM Consulting, LLC, Richland, Washington, 2015.

EDF-3 124-0001, Estimate of Excavationfor the NWMI Radioisotope ProductionFacility, Rev. 3, Portage, Inc., Idaho Falls, Idaho, February 2, 2015.

EDF-3 124-0003, PreliminaryMaximum HypotheticalAccident to Support the Northwest Medical Isotope Facility EnvironmentalReport, Rev. 2, Portage, Inc., Idaho Falls, Idaho, January 21, 2016.

EDF-3 124-00 04, Calculationfor the Determination of Fugitive Dust During ConstructionActivities from ConstructionEquipment, Rev. 1, Portage, Inc., Idaho Falls, Idaho, February 3, 2015.

EDF-3 124-0005, On-Road Emissionsfor Vehicles During Construction, Rev. 1, Portage, Inc., Idaho Falls, Idaho, July 31, 2015.

EDF-3 124-0006, Determinationof Wind-Blown Dust During ConstructionActivities, Rev. 1, Portage, Inc., Idaho Falls, Idaho, July 21, 2015.

EDF-3 124-0009, Off-Road Emissions During Construction,Rev. 1, Portage, Inc., Idaho Falls, Idaho, July 31, 2015.

EDF-3 124-00 10, RadiologicalDose Consequences Associated with Transportationof Materialsfor the NWMJIRadioisotope ProductionFacility, Rev. 2, Portage, Inc., Idaho Falls, Idaho, January 5, 2015.

EDF-3 124-0014, Emission Modeling for ConstructionActivities using AERSCREEN, Rev. 1, Portage, Inc., Idaho Falls, Idaho, July 31, 2015.

EPA, 2016, "Map of Sole Source Aquifer Locations," http://www.epa.gov/dwssa/map-sole-source-aquifer-locations, U.S. Environmental Protection Agency, Washington, D.C., accessed January 20, 2016.

EPA 520/1-89-003, User's Guide for the COMPLY Code, Rev. 2, U.S. Environmental Protection Agency, Washington, D.C., October 1989.

MIDNR, 2006, "MIO 2006 Well Logs (SHIP) Geospatial Data," ftp://msdis.missouri.edu/pub/

GeologicalGeophysical/MO_2006_Well Logs shp.zip, Missouri Department of Natural Resources, Jefferson City, Missouri, 2014.

MDNR, 2014, "MO 2014 Wells (SHIP) Geospatial Data," ftp://msdis.missouri.edu/pub/

GeologicalGeophysical/MO_2014_Wells shp.zip, Missouri Department of Natural Resources, Jefferson City, Missouri, 2014.

27 of 28

MDNR, 2016, 'WVell Log No. 23501, Strathydrograph," http://dnr.mo.gov/geology/wrc/groundwater/

strathydrographs/columbia.pdf, Missouri Department of Natural Resources, Jefferson City, Missouri, accessed January 25, 2016.

NUJREG- 1537, Guidelinesfor PreparingandReviewing Applicationsfor the Licensing of Non-Power Reactors - Formatand Content, Part 1, U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Washington, D.C., February 1996.

NWMI-2013-021, ConstructionPermit Applicationfor RadioisotopeProductionFacility, Rev. 0, Northwest Medical Isotopes, LLC, Corvallis, Oregon, June 29, 2015.

NWMVI-2013-CALC-006, Overall Summary MaterialBalance - MURR Target Batch, Rev. D, Northwest Medical Isotopes, LLC, Corvallis, Oregon January 29, 2015.

NWMI-2015-RAI-001, Response to the U.S. Nuclear Regulatory Commission Request for Additional Information, EnvironmentalReview of the Northwest Medical Isotopes, LLC ConstructionPermit Application, Rev. 0, Northwest Medical Isotopes, LLC, Corvallis, Oregon, November 23, 2015.

Terracon, 2011, Preliminary GeotechnicalEngineeringReport Discovery Ridge-CertifiedSite Program Lots 2, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, and 18, Terracon Consultants, Inc., prepared for University of Missouri and Trabue, Hansen & Hinshaw, Inc., Terracon Project No. 09105094.1, February 11, 2011.

USGS, 1992, "'Summary of Ground-Water Hydrology of the Cambrian-Ordovician Aquifer System in the Northern Midwest, United States," U.S. Geological Survey Professional Paper 1405-A, United States Government Printing Office, Washington, 1992.

USGS, 1997, "Ground Water Atlas of the United States, Segment 3 Kansas Missouri Nebraska, Hydrologic Investigations Atlas 730O-D," U.S. Geological Survey, Reston, Virginia, 1997.

USGS, 2012, "WVater-Quality Assessment of the Cambrian-Ordovician Aquifer System in the Northern Midwest," United States, Scientific Investigations Report 2011-5229, U.S. Geological Survey, Virginia, 2012.

USGS, 2016, "UISGS National Water Information System: Web Interface,"

http://waterdata.usgs.gov/nwis ?program=uv&site_no=3 8571809223420 1&agencycd=USGS, U.S. Geological Survey, Reston, Virginia, accessed January 20, 2016.

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o . 00 0 o.0@O@Oe 0 0 NWM I NORTHWEST MEDICAL ISOTOPES U.S. Nuclear Response Regulatoryto the Commission Request for Additional Information, Round 2 Environmental Review of the Northwest Medical Isotopes, LLC Construction Permit Application NWMI-2016-RAI-OO1, Rev. 0 February 2016 Prepared by:

Northwest Medical Isotopes, LLC 815 NW9th Ave, Suite 256 Corvallis, OR 97330 1

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:NWJMI

~EOCIIOCPSRev. NWMi-2Ol 6-RAI-0010 APPENDICES Appendix A - EDF-3124-0001, Estimate of Excavation for the NWMl Radioisotope Production Facility............................................................................................ A-i Appendix B - EDF-3 124-0004, Calculationfor the Determination of Fugitive Dust During ConstructionActivities from ConstructionEquipment........................................ B-i Appendix C - EDF-3124-0005, On-RoadEmissionsfor Vehicles During Construction ................... C-i Appendix D - EDF-3124-0006, Determinationof Wind-Blown Dust During Construction Activities .......................................................................................... D-i Appendix E - EDF-3 124-0009, Off-Road Emissions During Construction.................................. E-i Appendix F - EDF-3 124-0014, EmissionModeling for ConstructionActivities Using AERSCREEN...................................................................................... F-i Appendix G - EDF-3124-0003, PreliminaryMaximum HypotheticalAccident to Support the Northw est Medical Isotope FacilityEnvironmental Report.................................. G-i