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{{#Wiki_filter:1NRR-PMDAPEm Resource From:Moser, Michelle Sent:Tuesday, April 26, 2016 12:16 PM To:brittnie.brauner@mdc.mo.gov
{{#Wiki_filter:1 NRR-PMDAPEm Resource From: Moser, Michelle Sent: Tuesday, April 26, 2016 12:16 PM To: brittnie.brauner@mdc.mo.gov


==Subject:==
==Subject:==
Environmental Review for the Proposed Northwest Medical Isotopes, LLC Facility Attachments:
Environmental Review for the Proposed Northwest Medical Isotopes, LLC Facility Attachments:
MDC 2015. Natural Heritage Review for th e Proposed NWMI Facility ML15355A246.pdf; State-Endangered Species for Northw est Medical Isotopes Project.docx
MDC 2015. Natural Heritage Review for th e Proposed NWMI Facility ML15355A246.pdf; State-Endangered Species for Northw est Medical Isotopes Project.docx Brittnie, It was a pleasure to talk with you the other day on the phone. As I mentioned during our conversation, I am a biologist with the U.S. Nuclear Regulatory Commission (NRC). Northwest Medical Isotopes, LLC (NWMI) submitted an application to the NRC to construct a radi oisotope production facility that, if licensed, would produce medical radioisotopes. NWMI would construct a production facility building, a support facility, a waste staging and shipping building, diesel generator building, administration building, and security stations. The proposed Discovery Ridge site includes 7.4 acres (ac) (3.0 hectares (ha)) of land located about 3 mi (5 km) southeast of the City of Columbia. The proposed site has been used for agricultural purposes for several decades. In its application to the NRC, NWMI did not identify any forests, prairies, riparian zones, or streams on the proposed Discovery Ridge site.  
: Brittnie,  
 
It was a pleasure to talk with you the other day on the phone. As I mentioned during our conversation, I am a biologist with the U.S. Nuclear Regulatory Commission (NRC). Northwest Medical Isotopes, LLC (NWMI) submitted an application to the NRC to construct a radi oisotope production facility that, if licensed, would produce medical radioisotopes. NWMI would construct a production facility building, a support facility, a waste staging and shipping building, diesel generator building, administration building, and security stations. The proposed Discovery Ridge site includes 7.4 acres (ac) (3.0 hectares (ha)) of land located about 3 mi (5 km) southeast of the City of Columbia. The proposed site has been used for agricultural purposes for several decades. In its application to the NRC, NWMI did not identify any forests, prairies, riparian zones, or streams on the proposed Discovery Ridge site.  


Attached is a Natural Heritage Level 3 Report regarding the proposed NMWI project. In addition, I've attached a list of State-endangered species that have the potential to occur on or near the site. The attached list of species also includes Federally-listed species, which is based on information provided by the U.S. Fish and Wildlife Service. Per our conversation, the NRC requests any additional information you may have regarding State-protected species, Natural Communities of Conservation Concern, and any other important ecological resource on or near the proposed Discovery Ridge site.  
Attached is a Natural Heritage Level 3 Report regarding the proposed NMWI project. In addition, I've attached a list of State-endangered species that have the potential to occur on or near the site. The attached list of species also includes Federally-listed species, which is based on information provided by the U.S. Fish and Wildlife Service. Per our conversation, the NRC requests any additional information you may have regarding State-protected species, Natural Communities of Conservation Concern, and any other important ecological resource on or near the proposed Discovery Ridge site.  


Please feel free to contact me if I can provide any additional information. My phone number is 301-415-6509 and my email is Michelle.Moser@nrc.gov
Please feel free to contact me if I can provide any additional information. My phone number is 301-415-6509 and my email is Michelle.Moser@nrc.gov. Regards,  
. Regards,  


Michelle Moser  
Michelle Moser  
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reference that should be used to evaluate potential adverse project impacts. Other types of information, such as wetland and
reference that should be used to evaluate potential adverse project impacts. Other types of information, such as wetland and


soils maps and on-site inspections or surveys, should be considered. Reviewing current landscape and habitat information,
soils maps and on-site inspections or surveys, should be considered. Reviewing current landscape and habitat information, and species' biological characteristics would additionally ensure that Missouri Species of Conservation Concern are
 
and species' biological characteristics would additionally ensure that Missouri Species of Conservation Concern are


appropriately identified and addressed in planning efforts.
appropriately identified and addressed in planning efforts.
Line 114: Line 108:
the U.S. Fish and Wildlife Service (USFWS) for listed species. Direct contact with the USFWS may be necessary to complete
the U.S. Fish and Wildlife Service (USFWS) for listed species. Direct contact with the USFWS may be necessary to complete


consultation and it is required for actions with a federal connection, such as federal funding or a federal permit; direct cont actis also required if ESA concurrence is necessary. Visit the USFWS Information for Planning and Conservation (IPaC)
consultation and it is required for actions with a federal connection, such as federal funding or a federal permit; direct cont act is also required if ESA concurrence is necessary. Visit the USFWS Information for Planning and Conservation (IPaC)


website at https://ecos.fws.gov/ipac/
website at https://ecos.fws.gov/ipac/
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Project Type Recommendations:
Project Type Recommendations:
New construction, maintenance and remodeling, including government, commercial and residential buildings and other structures.
New construction, maintenance and remodeling, including government, commercial and residential buildings and other structures.
Fish, forest, and wildlife impacts can be avoided by siting projects in locations that have already been disturbed or previously developed, where and when feasible, and by avoiding alteration of areas providing existing habitat,
Fish, forest, and wildlife impacts can be avoided by siting projects in locations that have already been disturbed or previously developed, where and when feasible, and by avoiding alteration of areas providing existing habitat, such as wetlands, streams, forest, native grassland, etc. The project should be managed to minimize erosion and
 
such as wetlands, streams, forest, native grassland, etc. The project should be managed to minimize erosion and


sedimentation/runoff to nearby wetlands, streams and lakes, including adherence to any "Clean Water Act Permit"
sedimentation/runoff to nearby wetlands, streams and lakes, including adherence to any "Clean Water Act Permit"
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with native perennials for quicker green-up. Avoid aggressive exotic perennials such as crownvetch and sericea lespedeza.
with native perennials for quicker green-up. Avoid aggressive exotic perennials such as crownvetch and sericea lespedeza.


Pollutants, including sediment, can have significant impacts far downstream. Use silt fences and/or vegetative filter strips t obuffer streams and drainages, and monitor the site after rain events and until a well-rooted ground cover is reestablished.
Pollutants, including sediment, can have significant impacts far downstream. Use silt fences and/or vegetative filter strips t o buffer streams and drainages, and monitor the site after rain events and until a well-rooted ground cover is reestablished.
Project Location and/or Species Recommendations:
Project Location and/or Species Recommendations:
Endangered Species Act Coordination - Indiana bats (Myotis sodalis
Endangered Species Act Coordination - Indiana bats (Myotis sodalis , federal- and state-listed endangered) and Northern long-eared bats (Myotis septentrionalis, federal-listed threatened) hibernate during winter months in caves and mines.
, federal- and state-listed endangered) and Northernlong-eared bats (Myotis septentrionalis, federal-listed threatened) hibernate during winter months in caves and mines.
During the summer months, they roost and raise young under the bark of trees in wooded areas, often riparian forests and
During the summer months, they roost and raise young under the bark of trees in wooded areas, often riparian forests and


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Permit Regional Condition (Number 2) that must be considered if working under a Clean Water Act Section 404 Permit issued
Permit Regional Condition (Number 2) that must be considered if working under a Clean Water Act Section 404 Permit issued


by the U.S. Army Corps of Engineers (
by the U.S. Army Corps of Engineers (http://www.nwk.usace.army.mil/Missions/RegulatoryBranch/NationWidePermit...
http://www.nwk.usace.army.mil/Missions/RegulatoryBranch/NationWidePermit...
). A list of all stream reaches is available at http://www.nwk.usace.army.mil/Portals/29/docs/regulatory/nationwidepermi... . Activities that alter or destabilize stream bottoms or banks should be avoided during the important fish spawning period for that stream, in order to not disrupt fish spawning (i.e., laying and fertilizing fish eggs.) The sensitive spawning period for this stream i s March 15th to June 15th. At all times, avoid habitat destruction or introducing heavy sediment loads, chemical or organic
). A list of all stream reaches is available at http://www.nwk.usace.army.mil/Portals/29/docs/regulatory/nationwidepermi...
. Activities that alter or destabilize stream bottoms or banks should be avoided during the important fish spawning period for that stream,
 
in order to not disrupt fish spawning (i.e., laying and fertilizing fish eggs.) The sensitive spawning period for this stream i sMarch 15th to June 15th. At all times, avoid habitat destruction or introducing heavy sediment loads, chemical or organic


pollutants.
pollutants.
Line 207: Line 194:
activities, and riparian corridor removal, can modify or diminish aquatic habitats. Streams and wetlands may be protected
activities, and riparian corridor removal, can modify or diminish aquatic habitats. Streams and wetlands may be protected


under the Clean Water Act and require a permit for any activities that result in fill or other modifications to the site. Cond itionsprovided within the U.S. Army Corps of Engineers (USACE) Clean Water Act Section 404 permit
under the Clean Water Act and require a permit for any activities that result in fill or other modifications to the site. Cond itions provided within the U.S. Army Corps of Engineers (USACE) Clean Water Act Section 404 permit


(http://www.nwk.usace.army.mil/Missions/RegulatoryBranch.aspx
(http://www.nwk.usace.army.mil/Missions/RegulatoryBranch.aspx ) and the Missouri  Department of Natural Resources (DNR) issued Clean Water Act Section 401 Water Quality Certification (http://dnr.mo.gov/env/wpp/401/index.html
) and the Missouri  Department of Natural Resources (DNR) issued Clean Water Act Section 401 Water Quality Certification (
http://dnr.mo.gov/env/wpp/401/index.html
), if required, should help minimize impacts to the aquatic organisms and aquatic habitat within the area. Depending on your project
), if required, should help minimize impacts to the aquatic organisms and aquatic habitat within the area. Depending on your project


type, additional permits may be required by the Missouri Department of Natural Resources, such as permits for stormwater,
type, additional permits may be required by the Missouri Department of Natural Resources, such as permits for stormwater, wastewater treatment facilities, and confined animal feeding operations. Visit http://dnr.mo.gov/env/wpp/permits/index.html for more information on DNR permits. Visit both the USACE and DNR for more information on Clean Water Act permitting.
 
wastewater treatment facilities, and confined animal feeding operations. Visit http://dnr.mo.gov/env/wpp/permits/index.html for more information on DNR permits. Visit both the USACE and DNR for more information on Clean Water Act permitting.


For further coordination with the Missouri Department of Conservation and the U.S. Fish and Wildlife Services, please see the
For further coordination with the Missouri Department of Conservation and the U.S. Fish and Wildlife Services, please see the
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Provisions of the Wildlife Code.   
Provisions of the Wildlife Code.   


Additional information on Missouri's sensitive species may be found at http://mdc.mo.gov/discover-nature/field-guide/endangered-species
Additional information on Missouri's sensitive species may be found at http://mdc.mo.gov/discover-nature/field-guide/endangered-species . Detailed information about the animals and some plants mentioned may be accessed at http://mdc4.mdc.mo.gov/applications/mofwis/mofwis_search1.aspx . If you would like printed copies of best management practices cited as internet URLs, please contact the Missouri Department of Conservation.Missouri Department of ConservationPage 6 of 6Report Created: 12/18/2015 03:35:06 PM Table 1. Federally and State-Listed Species  that may occur on or near the Proposed Discovery Ridge Site for the Proposed Northwest Medical Isotope, LLC Project Scientific Name Common Name Federal Status (a) State Status (a) Habitat Fish Anguilla rostrate Topeka shiner E E Pools of small prairie streams with good water  
. Detailed information about the animals and some plants mentioned may be accessed at http://mdc4.mdc.mo.gov/applications/mofwis/mofwis_search1.aspx
. If you would like printed copies of best management practices cited as internet URLs, please contact the Missouri Department of Conservation.Missouri Department of ConservationPage 6 of 6Report Created: 12/18/2015 03:35:06 PM Table 1. Federally and State-Listed Species  that may occur on or near the Proposed Discovery Ridge Site for the Proposed Northwest Medical Isotope, LLC Project Scientific Name Common Name Federal Status(a) State Status(a) Habitat Fish Anguilla rostrate Topeka shiner E E Pools of small prairie streams with good water  


quality and gravel streambeds Scaphirhynchus albus pallid sturgeon E E Missouri River and lower portions of the Mississippi River; Currently extirpated from Missouri Mammals    Myotis grisescens gray bat E E Caves year-long Myotis septentrionalis northern long-eared bat T  Caves or mines during the winter and trees with loose bark or caves in the summer Myotis sodalist Indiana bat E E Caves during the winter and large diameter trees with loose bark in summer Spilogale putorius interrupta plains spotted skunk E Tallgrass prairies, forests, brushy areas, and cultivated lands with brushy cover Birds    Botaurus lentiginosus American bittern  E Freshwater marshes with dense stands of reeds and cattails Calidris canutus rufa red knot T  Migrate from the artic to South America. Stopover habitat in Missouri most often includes muddy or sandy areas near the Missouri River Charadrius melodus piping plover T  Wide, flat, open, sandy beaches with very little vegetation; Nesting occurs near small creeks or wetlands Sterna antillarum least tern E E Sand islands along the lower Mississippi River; Historically nested on sand islands along the Missouri River Plants Scientific Name Common Name Federal Status(a) State Status(a) Habitat Trifolium stoloniferum running buffalo clover E E Moist, partially shaded woodlands and to a lesser extent, along stream or river terraces (a,b) T = threatened, E = endangered Sources:  NWMI 2015a; Niles et al. 2008; FWS 2015a, 2015b, 2015c; MDC 2000a, 2000b, 2016; NRC 2015   
quality and gravel streambeds Scaphirhynchus albus pallid sturgeon E E Missouri River and lower portions of the Mississippi River; Currently extirpated from Missouri Mammals    Myotis grisescens gray bat E E Caves year-long Myotis septentrionalis northern long-eared bat T  Caves or mines during the winter and trees with loose bark or caves in the summer Myotis sodalist Indiana bat E E Caves during the winter and large diameter trees with loose bark in summer Spilogale putorius interrupta plains spotted skunk E Tallgrass prairies, forests, brushy areas, and cultivated lands with brushy cover Birds    Botaurus lentiginosus American bittern  E Freshwater marshes with dense stands of reeds and cattails Calidris canutus rufa red knot T  Migrate from the artic to South America. Stopover habitat in Missouri most often includes muddy or sandy areas near the Missouri River Charadrius melodus piping plover T  Wide, flat, open, sandy beaches with very little vegetation; Nesting occurs near small creeks or wetlands Sterna antillarum least tern E E Sand islands along the lower Mississippi River; Historically nested on sand islands along the Missouri River Plants Scientific Name Common Name Federal Status (a) State Status (a) Habitat Trifolium stoloniferum running buffalo clover E E Moist, partially shaded woodlands and to a lesser extent, along stream or river terraces (a,b) T = threatened, E = endangered Sources:  NWMI 2015a; Niles et al. 2008; FWS 2015a, 2015b, 2015c; MDC 2000a, 2000b, 2016; NRC 2015   


==References:==
==References:==
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==Subject:==
==Subject:==
List of threatened and endangered species that may occur in your proposed project location, and/or may be affected by your proposed project. Consultation Code: 03E14000-2016-SLI-0314.
List of threatened and endangered species that may occur in your proposed project location, and/or may be affected by your proposed project. Consultation Code: 03E14000-2016-SLI-0314.
November 20, 2015. ML15335A002. [FWS] Fish and Wildlife Service. 2015b. Northern Long-Eared Bat, Myotis septentrionalis
November 20, 2015. ML15335A002. [FWS] Fish and Wildlife Service. 2015b. Northern Long-Eared Bat, Myotis septentrionalis. Fort Snelling, Minnesota. April 2015. Available at: http://www.fws.gov/Midwest/endangered/mammals/nleb/nlebFactSheet.html (accessed 13 April 2016). [FWS] Fish and Wildlife Service. 2015c. Endangered Species Fact Sheet: Piping Plover. Fort Snelling, Minnesota. Last updated 23 April 2015. Available at:
. Fort Snelling, Minnesota. April 2015. Available at: http://www.fws.gov/Midwest/endangered/mammals/nleb/nlebFactSheet.html (accessed 13 April 2016). [FWS] Fish and Wildlife Service. 2015c. Endangered Species Fact Sheet: Piping Plover. Fort Snelling, Minnesota. Last updated 23 April 2015. Available at:
http://www.fws.gov/midwest/endangered/pipingplover/pipingpl.html (accessed 13 April 2016). [MDC] Missouri Department of Conservation. 2000a. Missouri Animals of Conservation Concern. Jefferson City, Missouri. Available at:
http://www.fws.gov/midwest/endangered/pipingplover/pipingpl.html (accessed 13 April 2016). [MDC] Missouri Department of Conservation. 2000a. Missouri Animals of Conservation Concern. Jefferson City, Missouri. Available at:
http://mdc.mo.gov/sites/default/files/resources/2010/04/4068_1693.pdf (accessed 13 April 2016). [MDC] Missouri Department of Conservation 2000b. Missouri Plants of Conservation Concern.
http://mdc.mo.gov/sites/default/files/resources/2010/04/4068_1693.pdf (accessed 13 April 2016). [MDC] Missouri Department of Conservation 2000b. Missouri Plants of Conservation Concern.
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Scoping Comments Regarding the Environmental Review for the Northwest Medical Isotopes, LLC (NWMI) Construction Permit Application. December 3, 2015. ADAMS No. ML15362A225.   
Scoping Comments Regarding the Environmental Review for the Northwest Medical Isotopes, LLC (NWMI) Construction Permit Application. December 3, 2015. ADAMS No. ML15362A225.   


1NRR-PMDAPEm Resource From:Moser, Michelle Sent:Tuesday, April 26, 2016 12:16 PM To:brittnie.brauner@mdc.mo.gov
1 NRR-PMDAPEm Resource From: Moser, Michelle Sent: Tuesday, April 26, 2016 12:16 PM To: brittnie.brauner@mdc.mo.gov


==Subject:==
==Subject:==
Environmental Review for the Proposed Northwest Medical Isotopes, LLC Facility Attachments:
Environmental Review for the Proposed Northwest Medical Isotopes, LLC Facility Attachments:
MDC 2015. Natural Heritage Review for th e Proposed NWMI Facility ML15355A246.pdf; State-Endangered Species for Northw est Medical Isotopes Project.docx
MDC 2015. Natural Heritage Review for th e Proposed NWMI Facility ML15355A246.pdf; State-Endangered Species for Northw est Medical Isotopes Project.docx Brittnie, It was a pleasure to talk with you the other day on the phone. As I mentioned during our conversation, I am a biologist with the U.S. Nuclear Regulatory Commission (NRC). Northwest Medical Isotopes, LLC (NWMI) submitted an application to the NRC to construct a radi oisotope production facility that, if licensed, would produce medical radioisotopes. NWMI would construct a production facility building, a support facility, a waste staging and shipping building, diesel generator building, administration building, and security stations. The proposed Discovery Ridge site includes 7.4 acres (ac) (3.0 hectares (ha)) of land located about 3 mi (5 km) southeast of the City of Columbia. The proposed site has been used for agricultural purposes for several decades. In its application to the NRC, NWMI did not identify any forests, prairies, riparian zones, or streams on the proposed Discovery Ridge site.  
: Brittnie,  
 
It was a pleasure to talk with you the other day on the phone. As I mentioned during our conversation, I am a biologist with the U.S. Nuclear Regulatory Commission (NRC). Northwest Medical Isotopes, LLC (NWMI) submitted an application to the NRC to construct a radi oisotope production facility that, if licensed, would produce medical radioisotopes. NWMI would construct a production facility building, a support facility, a waste staging and shipping building, diesel generator building, administration building, and security stations. The proposed Discovery Ridge site includes 7.4 acres (ac) (3.0 hectares (ha)) of land located about 3 mi (5 km) southeast of the City of Columbia. The proposed site has been used for agricultural purposes for several decades. In its application to the NRC, NWMI did not identify any forests, prairies, riparian zones, or streams on the proposed Discovery Ridge site.  


Attached is a Natural Heritage Level 3 Report regarding the proposed NMWI project. In addition, I've attached a list of State-endangered species that have the potential to occur on or near the site. The attached list of species also includes Federally-listed species, which is based on information provided by the U.S. Fish and Wildlife Service. Per our conversation, the NRC requests any additional information you may have regarding State-protected species, Natural Communities of Conservation Concern, and any other important ecological resource on or near the proposed Discovery Ridge site.  
Attached is a Natural Heritage Level 3 Report regarding the proposed NMWI project. In addition, I've attached a list of State-endangered species that have the potential to occur on or near the site. The attached list of species also includes Federally-listed species, which is based on information provided by the U.S. Fish and Wildlife Service. Per our conversation, the NRC requests any additional information you may have regarding State-protected species, Natural Communities of Conservation Concern, and any other important ecological resource on or near the proposed Discovery Ridge site.  


Please feel free to contact me if I can provide any additional information. My phone number is 301-415-6509 and my email is Michelle.Moser@nrc.gov
Please feel free to contact me if I can provide any additional information. My phone number is 301-415-6509 and my email is Michelle.Moser@nrc.gov. Regards,  
. Regards,  


Michelle Moser  
Michelle Moser  
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reference that should be used to evaluate potential adverse project impacts. Other types of information, such as wetland and
reference that should be used to evaluate potential adverse project impacts. Other types of information, such as wetland and


soils maps and on-site inspections or surveys, should be considered. Reviewing current landscape and habitat information,
soils maps and on-site inspections or surveys, should be considered. Reviewing current landscape and habitat information, and species' biological characteristics would additionally ensure that Missouri Species of Conservation Concern are
 
and species' biological characteristics would additionally ensure that Missouri Species of Conservation Concern are


appropriately identified and addressed in planning efforts.
appropriately identified and addressed in planning efforts.
Line 381: Line 355:
the U.S. Fish and Wildlife Service (USFWS) for listed species. Direct contact with the USFWS may be necessary to complete
the U.S. Fish and Wildlife Service (USFWS) for listed species. Direct contact with the USFWS may be necessary to complete


consultation and it is required for actions with a federal connection, such as federal funding or a federal permit; direct cont actis also required if ESA concurrence is necessary. Visit the USFWS Information for Planning and Conservation (IPaC)
consultation and it is required for actions with a federal connection, such as federal funding or a federal permit; direct cont act is also required if ESA concurrence is necessary. Visit the USFWS Information for Planning and Conservation (IPaC)


website at https://ecos.fws.gov/ipac/
website at https://ecos.fws.gov/ipac/
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Project Type Recommendations:
Project Type Recommendations:
New construction, maintenance and remodeling, including government, commercial and residential buildings and other structures.
New construction, maintenance and remodeling, including government, commercial and residential buildings and other structures.
Fish, forest, and wildlife impacts can be avoided by siting projects in locations that have already been disturbed or previously developed, where and when feasible, and by avoiding alteration of areas providing existing habitat,
Fish, forest, and wildlife impacts can be avoided by siting projects in locations that have already been disturbed or previously developed, where and when feasible, and by avoiding alteration of areas providing existing habitat, such as wetlands, streams, forest, native grassland, etc. The project should be managed to minimize erosion and
 
such as wetlands, streams, forest, native grassland, etc. The project should be managed to minimize erosion and


sedimentation/runoff to nearby wetlands, streams and lakes, including adherence to any "Clean Water Act Permit"
sedimentation/runoff to nearby wetlands, streams and lakes, including adherence to any "Clean Water Act Permit"
Line 434: Line 406:
with native perennials for quicker green-up. Avoid aggressive exotic perennials such as crownvetch and sericea lespedeza.
with native perennials for quicker green-up. Avoid aggressive exotic perennials such as crownvetch and sericea lespedeza.


Pollutants, including sediment, can have significant impacts far downstream. Use silt fences and/or vegetative filter strips t obuffer streams and drainages, and monitor the site after rain events and until a well-rooted ground cover is reestablished.
Pollutants, including sediment, can have significant impacts far downstream. Use silt fences and/or vegetative filter strips t o buffer streams and drainages, and monitor the site after rain events and until a well-rooted ground cover is reestablished.
Project Location and/or Species Recommendations:
Project Location and/or Species Recommendations:
Endangered Species Act Coordination - Indiana bats (Myotis sodalis
Endangered Species Act Coordination - Indiana bats (Myotis sodalis , federal- and state-listed endangered) and Northern long-eared bats (Myotis septentrionalis, federal-listed threatened) hibernate during winter months in caves and mines.
, federal- and state-listed endangered) and Northernlong-eared bats (Myotis septentrionalis, federal-listed threatened) hibernate during winter months in caves and mines.
During the summer months, they roost and raise young under the bark of trees in wooded areas, often riparian forests and
During the summer months, they roost and raise young under the bark of trees in wooded areas, often riparian forests and


Line 453: Line 424:
Permit Regional Condition (Number 2) that must be considered if working under a Clean Water Act Section 404 Permit issued
Permit Regional Condition (Number 2) that must be considered if working under a Clean Water Act Section 404 Permit issued


by the U.S. Army Corps of Engineers (
by the U.S. Army Corps of Engineers (http://www.nwk.usace.army.mil/Missions/RegulatoryBranch/NationWidePermit...
http://www.nwk.usace.army.mil/Missions/RegulatoryBranch/NationWidePermit...
). A list of all stream reaches is available at http://www.nwk.usace.army.mil/Portals/29/docs/regulatory/nationwidepermi... . Activities that alter or destabilize stream bottoms or banks should be avoided during the important fish spawning period for that stream, in order to not disrupt fish spawning (i.e., laying and fertilizing fish eggs.) The sensitive spawning period for this stream i s March 15th to June 15th. At all times, avoid habitat destruction or introducing heavy sediment loads, chemical or organic
). A list of all stream reaches is available at http://www.nwk.usace.army.mil/Portals/29/docs/regulatory/nationwidepermi...
. Activities that alter or destabilize stream bottoms or banks should be avoided during the important fish spawning period for that stream,
 
in order to not disrupt fish spawning (i.e., laying and fertilizing fish eggs.) The sensitive spawning period for this stream i sMarch 15th to June 15th. At all times, avoid habitat destruction or introducing heavy sediment loads, chemical or organic


pollutants.
pollutants.
Line 474: Line 441:
activities, and riparian corridor removal, can modify or diminish aquatic habitats. Streams and wetlands may be protected
activities, and riparian corridor removal, can modify or diminish aquatic habitats. Streams and wetlands may be protected


under the Clean Water Act and require a permit for any activities that result in fill or other modifications to the site. Cond itionsprovided within the U.S. Army Corps of Engineers (USACE) Clean Water Act Section 404 permit
under the Clean Water Act and require a permit for any activities that result in fill or other modifications to the site. Cond itions provided within the U.S. Army Corps of Engineers (USACE) Clean Water Act Section 404 permit


(http://www.nwk.usace.army.mil/Missions/RegulatoryBranch.aspx
(http://www.nwk.usace.army.mil/Missions/RegulatoryBranch.aspx ) and the Missouri  Department of Natural Resources (DNR) issued Clean Water Act Section 401 Water Quality Certification (http://dnr.mo.gov/env/wpp/401/index.html
) and the Missouri  Department of Natural Resources (DNR) issued Clean Water Act Section 401 Water Quality Certification (
http://dnr.mo.gov/env/wpp/401/index.html
), if required, should help minimize impacts to the aquatic organisms and aquatic habitat within the area. Depending on your project
), if required, should help minimize impacts to the aquatic organisms and aquatic habitat within the area. Depending on your project


type, additional permits may be required by the Missouri Department of Natural Resources, such as permits for stormwater,
type, additional permits may be required by the Missouri Department of Natural Resources, such as permits for stormwater, wastewater treatment facilities, and confined animal feeding operations. Visit http://dnr.mo.gov/env/wpp/permits/index.html for more information on DNR permits. Visit both the USACE and DNR for more information on Clean Water Act permitting.
 
wastewater treatment facilities, and confined animal feeding operations. Visit http://dnr.mo.gov/env/wpp/permits/index.html for more information on DNR permits. Visit both the USACE and DNR for more information on Clean Water Act permitting.


For further coordination with the Missouri Department of Conservation and the U.S. Fish and Wildlife Services, please see the
For further coordination with the Missouri Department of Conservation and the U.S. Fish and Wildlife Services, please see the
Line 527: Line 490:
Provisions of the Wildlife Code.   
Provisions of the Wildlife Code.   


Additional information on Missouri's sensitive species may be found at http://mdc.mo.gov/discover-nature/field-guide/endangered-species
Additional information on Missouri's sensitive species may be found at http://mdc.mo.gov/discover-nature/field-guide/endangered-species . Detailed information about the animals and some plants mentioned may be accessed at http://mdc4.mdc.mo.gov/applications/mofwis/mofwis_search1.aspx . If you would like printed copies of best management practices cited as internet URLs, please contact the Missouri Department of Conservation.Missouri Department of ConservationPage 6 of 6Report Created: 12/18/2015 03:35:06 PM Table 1. Federally and State-Listed Species  that may occur on or near the Proposed Discovery Ridge Site for the Proposed Northwest Medical Isotope, LLC Project Scientific Name Common Name Federal Status (a) State Status (a) Habitat Fish Anguilla rostrate Topeka shiner E E Pools of small prairie streams with good water  
. Detailed information about the animals and some plants mentioned may be accessed at http://mdc4.mdc.mo.gov/applications/mofwis/mofwis_search1.aspx
. If you would like printed copies of best management practices cited as internet URLs, please contact the Missouri Department of Conservation.Missouri Department of ConservationPage 6 of 6Report Created: 12/18/2015 03:35:06 PM Table 1. Federally and State-Listed Species  that may occur on or near the Proposed Discovery Ridge Site for the Proposed Northwest Medical Isotope, LLC Project Scientific Name Common Name Federal Status(a) State Status(a) Habitat Fish Anguilla rostrate Topeka shiner E E Pools of small prairie streams with good water  


quality and gravel streambeds Scaphirhynchus albus pallid sturgeon E E Missouri River and lower portions of the Mississippi River; Currently extirpated from Missouri Mammals    Myotis grisescens gray bat E E Caves year-long Myotis septentrionalis northern long-eared bat T  Caves or mines during the winter and trees with loose bark or caves in the summer Myotis sodalist Indiana bat E E Caves during the winter and large diameter trees with loose bark in summer Spilogale putorius interrupta plains spotted skunk E Tallgrass prairies, forests, brushy areas, and cultivated lands with brushy cover Birds    Botaurus lentiginosus American bittern  E Freshwater marshes with dense stands of reeds and cattails Calidris canutus rufa red knot T  Migrate from the artic to South America. Stopover habitat in Missouri most often includes muddy or sandy areas near the Missouri River Charadrius melodus piping plover T  Wide, flat, open, sandy beaches with very little vegetation; Nesting occurs near small creeks or wetlands Sterna antillarum least tern E E Sand islands along the lower Mississippi River; Historically nested on sand islands along the Missouri River Plants Scientific Name Common Name Federal Status(a) State Status(a) Habitat Trifolium stoloniferum running buffalo clover E E Moist, partially shaded woodlands and to a lesser extent, along stream or river terraces (a,b) T = threatened, E = endangered Sources:  NWMI 2015a; Niles et al. 2008; FWS 2015a, 2015b, 2015c; MDC 2000a, 2000b, 2016; NRC 2015   
quality and gravel streambeds Scaphirhynchus albus pallid sturgeon E E Missouri River and lower portions of the Mississippi River; Currently extirpated from Missouri Mammals    Myotis grisescens gray bat E E Caves year-long Myotis septentrionalis northern long-eared bat T  Caves or mines during the winter and trees with loose bark or caves in the summer Myotis sodalist Indiana bat E E Caves during the winter and large diameter trees with loose bark in summer Spilogale putorius interrupta plains spotted skunk E Tallgrass prairies, forests, brushy areas, and cultivated lands with brushy cover Birds    Botaurus lentiginosus American bittern  E Freshwater marshes with dense stands of reeds and cattails Calidris canutus rufa red knot T  Migrate from the artic to South America. Stopover habitat in Missouri most often includes muddy or sandy areas near the Missouri River Charadrius melodus piping plover T  Wide, flat, open, sandy beaches with very little vegetation; Nesting occurs near small creeks or wetlands Sterna antillarum least tern E E Sand islands along the lower Mississippi River; Historically nested on sand islands along the Missouri River Plants Scientific Name Common Name Federal Status (a) State Status (a) Habitat Trifolium stoloniferum running buffalo clover E E Moist, partially shaded woodlands and to a lesser extent, along stream or river terraces (a,b) T = threatened, E = endangered Sources:  NWMI 2015a; Niles et al. 2008; FWS 2015a, 2015b, 2015c; MDC 2000a, 2000b, 2016; NRC 2015   


==References:==
==References:==
Line 538: Line 499:
==Subject:==
==Subject:==
List of threatened and endangered species that may occur in your proposed project location, and/or may be affected by your proposed project. Consultation Code: 03E14000-2016-SLI-0314.
List of threatened and endangered species that may occur in your proposed project location, and/or may be affected by your proposed project. Consultation Code: 03E14000-2016-SLI-0314.
November 20, 2015. ML15335A002. [FWS] Fish and Wildlife Service. 2015b. Northern Long-Eared Bat, Myotis septentrionalis
November 20, 2015. ML15335A002. [FWS] Fish and Wildlife Service. 2015b. Northern Long-Eared Bat, Myotis septentrionalis. Fort Snelling, Minnesota. April 2015. Available at: http://www.fws.gov/Midwest/endangered/mammals/nleb/nlebFactSheet.html (accessed 13 April 2016). [FWS] Fish and Wildlife Service. 2015c. Endangered Species Fact Sheet: Piping Plover. Fort Snelling, Minnesota. Last updated 23 April 2015. Available at:
. Fort Snelling, Minnesota. April 2015. Available at: http://www.fws.gov/Midwest/endangered/mammals/nleb/nlebFactSheet.html (accessed 13 April 2016). [FWS] Fish and Wildlife Service. 2015c. Endangered Species Fact Sheet: Piping Plover. Fort Snelling, Minnesota. Last updated 23 April 2015. Available at:
http://www.fws.gov/midwest/endangered/pipingplover/pipingpl.html (accessed 13 April 2016). [MDC] Missouri Department of Conservation. 2000a. Missouri Animals of Conservation Concern. Jefferson City, Missouri. Available at:
http://www.fws.gov/midwest/endangered/pipingplover/pipingpl.html (accessed 13 April 2016). [MDC] Missouri Department of Conservation. 2000a. Missouri Animals of Conservation Concern. Jefferson City, Missouri. Available at:
http://mdc.mo.gov/sites/default/files/resources/2010/04/4068_1693.pdf (accessed 13 April 2016). [MDC] Missouri Department of Conservation 2000b. Missouri Plants of Conservation Concern.
http://mdc.mo.gov/sites/default/files/resources/2010/04/4068_1693.pdf (accessed 13 April 2016). [MDC] Missouri Department of Conservation 2000b. Missouri Plants of Conservation Concern.

Revision as of 12:44, 8 July 2018

2016/04/26 NRR E-mail Capture - Environmental Review for the Proposed Northwest Medical Isotopes, LLC Facility
ML16117A430
Person / Time
Site: Northwest Medical Isotopes
Issue date: 04/26/2016
From: Michelle Moser
Division of License Renewal
To: Brauner B
State of MO, Dept of Conservation
References
Download: ML16117A430 (11)


Text

1 NRR-PMDAPEm Resource From: Moser, Michelle Sent: Tuesday, April 26, 2016 12:16 PM To: brittnie.brauner@mdc.mo.gov

Subject:

Environmental Review for the Proposed Northwest Medical Isotopes, LLC Facility Attachments:

MDC 2015. Natural Heritage Review for th e Proposed NWMI Facility ML15355A246.pdf; State-Endangered Species for Northw est Medical Isotopes Project.docx Brittnie, It was a pleasure to talk with you the other day on the phone. As I mentioned during our conversation, I am a biologist with the U.S. Nuclear Regulatory Commission (NRC). Northwest Medical Isotopes, LLC (NWMI) submitted an application to the NRC to construct a radi oisotope production facility that, if licensed, would produce medical radioisotopes. NWMI would construct a production facility building, a support facility, a waste staging and shipping building, diesel generator building, administration building, and security stations. The proposed Discovery Ridge site includes 7.4 acres (ac) (3.0 hectares (ha)) of land located about 3 mi (5 km) southeast of the City of Columbia. The proposed site has been used for agricultural purposes for several decades. In its application to the NRC, NWMI did not identify any forests, prairies, riparian zones, or streams on the proposed Discovery Ridge site.

Attached is a Natural Heritage Level 3 Report regarding the proposed NMWI project. In addition, I've attached a list of State-endangered species that have the potential to occur on or near the site. The attached list of species also includes Federally-listed species, which is based on information provided by the U.S. Fish and Wildlife Service. Per our conversation, the NRC requests any additional information you may have regarding State-protected species, Natural Communities of Conservation Concern, and any other important ecological resource on or near the proposed Discovery Ridge site.

Please feel free to contact me if I can provide any additional information. My phone number is 301-415-6509 and my email is Michelle.Moser@nrc.gov. Regards,

Michelle Moser


Michelle Rome Moser Biologist U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation

Division of License Renewal Phone: 301-415-6509 Email: Michelle.Moser@nrc.gov

Hearing Identifier: NRR_PMDA Email Number: 2801 Mail Envelope Properties (Michelle.Moser@nrc.gov20160426121600)

Subject:

Environmental Review for the Proposed No rthwest Medical Isotopes, LLC Facility Sent Date: 4/26/2016 12:16:22 PM Received Date: 4/26/2016 12:16:00 PM From: Moser, Michelle Created By: Michelle.Moser@nrc.gov Recipients: "brittnie.brauner@mdc.mo.gov" <brittnie.brauner@mdc.mo.gov>

Tracking Status: None Post Office: Files Size Date & Time MESSAGE 2056 4/26/2016 12:16:00 PM MDC 2015. Natural Heritage Review for the Proposed NWMI Facility ML15355A246.pdf 809215 State-Endangered Species for Northwest Medical Isotopes Project.docx 24449 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

Missouri Department of Conservation Missouri Department of Conservation's Mission is to protect and manage the forest, fish, and wildlife resources of the state and to facilitate and provide opportunities for all citizens to use, enjoy and learn about these resources.

Natural Heritage Review Level Three Report: Species Listed Under the Federal Endangered Species Act There are records for species listed under the Federal Endangered Species Act, and possibly also records for species listed Endangered by the state, or Missouri Species and/or Natural Communities of Conservation Concern within or near the the

defined Project Area. Please contact the U.S. Fish and Wildlife Service and the Missouri Department of Conservation for further coordination.

Foreword:

Thank you for accessing the Missouri Natural Heritage Review Website developed by the Missouri Department of Conservation with assistance from the U.S. Fish and Wildlife Service, the U.S. Army Corps of Engineers, Missouri

Department of Transportation and NatureServe. The purpose of this website is to provide information to federal, state and

local agencies, organizations, municipalities, corporations and consultants regarding sensitive fish, wildlife, plants, natural

communities and habitats to assist in planning, designing and permitting stages of projects.

PROJECT INFORMATION Project Name and ID Number:

NWMI Proposed Facility #155 Project

Description:

Northwest Medical Isotopes, LLC (NWMI) submitted an application to the U.S. Nuclear Regulatory Commission to construct a radioisotope production facility that, if licensed, would produce radioisotopes. The proposed site

would cover approximately 7.4 acres (3.0 ha), which would include a production facility building, a support facility, a waste

staging and shipping building, diesel generator building, administration building and security stations. The site has been used

for agricultural purposes. In its application, NWMI did not identify any forests, prairies, riparian zones, or streams on the

proposed site.

Project Type:

Residential, Commercial and Governmental Building Development Contact Person:

Michelle Moser Contact Information:

Michelle.Moser@nrc.gov or 301-415-6509Missouri Department of ConservationPage 1 of 6Report Created: 12/18/2015 03:35:06 PM Disclaimer:

The NATURAL HERITAGE REVIEW REPORT produced by this website identifies if a species tracked by the Natural Heritage Program is known to occur within or near the area submitted for your project, and shares suggested

recommendations on ways to avoid or minimize project impacts to sensitive species or special habitats. If an occurrence

record is present, or the proposed project might affect federally listed species, the user must contact the Department of

Conservation or U.S. Fish and Wildlife Service for more information. The Natural Heritage Program tracks occurrences of

sensitive species and natural communities where the species or natural community has been found. Lack of an occurrence

record does not mean that a sensitive plant, animal or natural community is not present on or near the project

area. Depending on the project, current habitat conditions, and geographic location in the state, surveys may be

necessary. Additionally, because land use conditions change and animals move, the existence of an occurrence record does

not mean the species/habitat is still present. Therefore, Reports include information about records near but not necessarily

on the project site.

The Natural Heritage Report is not a site clearance letter for the project.

It provides an indication of whether or not public lands and sensitive resources are known to be (or are likely to be) located close to the proposed project. Incorporating

information from the Natural Heritage Program into project plans is an important step that can help reduce unnecessary

impacts to Missouri's sensitive fish, forest and wildlife resources. However, the Natural Heritage Program is only one

reference that should be used to evaluate potential adverse project impacts. Other types of information, such as wetland and

soils maps and on-site inspections or surveys, should be considered. Reviewing current landscape and habitat information, and species' biological characteristics would additionally ensure that Missouri Species of Conservation Concern are

appropriately identified and addressed in planning efforts.

U.S. Fish and Wildlife Service - Endangered Species Act (ESA) Coordination:

Lack of a Natural Heritage Program occurrence record for federally listed species in your project area does not mean the species is not present, as the area may

never have been surveyed. Presence of a Natural Heritage Program occurrence record does not mean the project will result

in negative impacts. The information within this report is not intended to replace Endangered Species Act consultation with

the U.S. Fish and Wildlife Service (USFWS) for listed species. Direct contact with the USFWS may be necessary to complete

consultation and it is required for actions with a federal connection, such as federal funding or a federal permit; direct cont act is also required if ESA concurrence is necessary. Visit the USFWS Information for Planning and Conservation (IPaC)

website at https://ecos.fws.gov/ipac/

for further information. This site was developed to help streamline the USFWS environmental review process and is a first step in ESA coordination. The Columbia Missouri Ecological Field Services Office

may be reached at 573-234-2132, or by mail at 101 Park Deville Drive, Suite A, Columbia, MO 65203.

Transportation Projects:

If the project involves the use of Federal Highway Administration transportation funds, these recommendations may not fulfill all contract requirements. Please contact the Missouri Department of Transportation at

573-526-4778 or www.modot.mo.gov/ehp/index.htm for additional information on recommendations.Missouri Department of ConservationPage 2 of 6Report Created: 12/18/2015 03:35:06 PM Missouri Department of ConservationPage 3 of 6Report Created: 12/18/2015 03:35:06 PM Species or Communities of Conservation Concern within the Area:

There are records for species listed under the Federal Endangered Species Act, and possibly also records for species listed Endangered by the state, or Missouri Species and/or Natural Communities of Conservation Concern within or near the the

defined Project Area. Please contact the U.S. Fish and Wildlife Service and the Missouri Department of Conservation for further coordination.

MDC Natural Heritage Review

Resource Science Division

P.O. Box 180

Jefferson City, MO

65102-0180

Phone: 573-522-4115 ext. 3182

NaturalHeritageReview@mdc.mo.gov U.S. Fish and Wildlife Service Ecological Service

101 Park Deville Drive

Suite A Columbia, MO

65203-0007

Phone: 573-234-2132 Other Special Search Results:

The project occurs on public land, CENTRAL REGIONAL OFFICE, COLUMBIA (A PERRY PHILIPS PARK LAKE), UNIV OF MO (SOUTH FARM R-1 LAKE), please contact MDC.

Project Type Recommendations:

New construction, maintenance and remodeling, including government, commercial and residential buildings and other structures.

Fish, forest, and wildlife impacts can be avoided by siting projects in locations that have already been disturbed or previously developed, where and when feasible, and by avoiding alteration of areas providing existing habitat, such as wetlands, streams, forest, native grassland, etc. The project should be managed to minimize erosion and

sedimentation/runoff to nearby wetlands, streams and lakes, including adherence to any "Clean Water Act Permit"

conditions. Project design should include stormwater management elements that assure storm discharge rates to streams for

heavy rain events will not increase from present levels. Revegetate areas in which the natural cover is disturbed to minimize

erosion using native plant species compatible with the local landscape and wildlife needs. Annual ryegrass may be combined

with native perennials for quicker green-up. Avoid aggressive exotic perennials such as crownvetch and sericea lespedeza.

Pollutants, including sediment, can have significant impacts far downstream. Use silt fences and/or vegetative filter strips t o buffer streams and drainages, and monitor the site after rain events and until a well-rooted ground cover is reestablished.

Project Location and/or Species Recommendations:

Endangered Species Act Coordination - Indiana bats (Myotis sodalis , federal- and state-listed endangered) and Northern long-eared bats (Myotis septentrionalis, federal-listed threatened) hibernate during winter months in caves and mines.

During the summer months, they roost and raise young under the bark of trees in wooded areas, often riparian forests and

upland forests near perennial streams. During project activities, avoid degrading stream quality and where possible leave

snags standing and preserve mature forest canopy. Do not enter caves known to harbor Indiana bats, especially from September to April.

If any trees need to be removed for your project, please contact the U.S. Fish and Wildlife Service (Ecological Services, 101 Park Deville Drive, Suite A, Columbia, Missouri 65203-0007; Phone 573-234-2132) for

further coordination.Missouri Department of ConservationPage 4 of 6Report Created: 12/18/2015 03:35:06 PM The project site submitted and evaluated is on or near Fish Spawning Stream Reaches Gans River, one of 138 state-designated fish spawning stream segments. These stream reaches were so designated because they have highly diverse fish

communities, fish Species of Conservation Concern present, and because they are important to maintaining, restoring, or

avoiding future listing of Species of Conservation Concern. These stream reaches also are included as a Missouri Nationwide

Permit Regional Condition (Number 2) that must be considered if working under a Clean Water Act Section 404 Permit issued

by the U.S. Army Corps of Engineers (http://www.nwk.usace.army.mil/Missions/RegulatoryBranch/NationWidePermit...

). A list of all stream reaches is available at http://www.nwk.usace.army.mil/Portals/29/docs/regulatory/nationwidepermi... . Activities that alter or destabilize stream bottoms or banks should be avoided during the important fish spawning period for that stream, in order to not disrupt fish spawning (i.e., laying and fertilizing fish eggs.) The sensitive spawning period for this stream i s March 15th to June 15th. At all times, avoid habitat destruction or introducing heavy sediment loads, chemical or organic

pollutants.

Invasive exotic species are a significant issue for fish, wildlife and agriculture in Missouri. Seeds, eggs, and larvae may be moved to new sites on boats or construction equipment. Please inspect and clean equipment thoroughly before moving

between project sites. See http://mdc.mo.gov//9633 for more information.

Remove any mud, soil, trash, plants or animals from equipment before leaving any water body or work area.

Drain water from boats and machinery that have operated in water, checking motor cavities, live-well, bilge and transom wells, tracks, buckets, and any other water reservoirs.

When possible, wash and rinse equipment thoroughly with hard spray or HOT water (?140° F, typically available at

do-it-yourself car wash sites), and dry in the hot sun before using again.

Streams and Wetlands - Clean Water Act Permits:

Streams and wetlands in the project area should be protected from activities that degrade habitat conditions. For example, soil erosion, water pollution, placement of fill, dredging, in-stream

activities, and riparian corridor removal, can modify or diminish aquatic habitats. Streams and wetlands may be protected

under the Clean Water Act and require a permit for any activities that result in fill or other modifications to the site. Cond itions provided within the U.S. Army Corps of Engineers (USACE) Clean Water Act Section 404 permit

(http://www.nwk.usace.army.mil/Missions/RegulatoryBranch.aspx ) and the Missouri Department of Natural Resources (DNR) issued Clean Water Act Section 401 Water Quality Certification (http://dnr.mo.gov/env/wpp/401/index.html

), if required, should help minimize impacts to the aquatic organisms and aquatic habitat within the area. Depending on your project

type, additional permits may be required by the Missouri Department of Natural Resources, such as permits for stormwater, wastewater treatment facilities, and confined animal feeding operations. Visit http://dnr.mo.gov/env/wpp/permits/index.html for more information on DNR permits. Visit both the USACE and DNR for more information on Clean Water Act permitting.

For further coordination with the Missouri Department of Conservation and the U.S. Fish and Wildlife Services, please see the

contact information below.

MDC Natural Heritage Review

Resource Science Division

P.O. Box 180

Jefferson City, MO

65102-0180

Phone: 573-522-4115 ext. 3182

NaturalHeritageReview@mdc.mo.gov U.S. Fish and Wildlife Service Ecological Service

101 Park Deville Drive

Suite A Columbia, MO

65203-0007

Phone: 573-234-2132Missouri Department of ConservationPage 5 of 6Report Created: 12/18/2015 03:35:06 PM Miscellaneous Information FEDERAL Concerns are species/habitats protected under the Federal Endangered Species Act and that have been known near enough to the project site to warrant consideration. For these, project managers must contact the U.S. Fish and Wildlife

Service Ecological Services (101 Park Deville Drive Suite A, Columbia, Missouri 65203-0007; Phone 573-234-2132; Fax

573-234-2181) for consultation.

STATE Concerns are species/habitats known to exist near enough to the project site to warrant concern and that are

protected under the Wildlife Code of Missouri (RSMo 3 CSR 1 0). "State Endangered Status" is determined by the Missouri

Conservation Commission under constitutional authority, with requirements expressed in the Missouri Wildlife Code, rule

3CSR 1 0-4.111. Species tracked by the Natural Heritage Program have a "State Rank" which is a numeric rank of relative

rarity. Species tracked by this program and all native Missouri wildlife are protected under rule 3CSR 10-4.110 General

Provisions of the Wildlife Code.

Additional information on Missouri's sensitive species may be found at http://mdc.mo.gov/discover-nature/field-guide/endangered-species . Detailed information about the animals and some plants mentioned may be accessed at http://mdc4.mdc.mo.gov/applications/mofwis/mofwis_search1.aspx . If you would like printed copies of best management practices cited as internet URLs, please contact the Missouri Department of Conservation.Missouri Department of ConservationPage 6 of 6Report Created: 12/18/2015 03:35:06 PM Table 1. Federally and State-Listed Species that may occur on or near the Proposed Discovery Ridge Site for the Proposed Northwest Medical Isotope, LLC Project Scientific Name Common Name Federal Status (a) State Status (a) Habitat Fish Anguilla rostrate Topeka shiner E E Pools of small prairie streams with good water

quality and gravel streambeds Scaphirhynchus albus pallid sturgeon E E Missouri River and lower portions of the Mississippi River; Currently extirpated from Missouri Mammals Myotis grisescens gray bat E E Caves year-long Myotis septentrionalis northern long-eared bat T Caves or mines during the winter and trees with loose bark or caves in the summer Myotis sodalist Indiana bat E E Caves during the winter and large diameter trees with loose bark in summer Spilogale putorius interrupta plains spotted skunk E Tallgrass prairies, forests, brushy areas, and cultivated lands with brushy cover Birds Botaurus lentiginosus American bittern E Freshwater marshes with dense stands of reeds and cattails Calidris canutus rufa red knot T Migrate from the artic to South America. Stopover habitat in Missouri most often includes muddy or sandy areas near the Missouri River Charadrius melodus piping plover T Wide, flat, open, sandy beaches with very little vegetation; Nesting occurs near small creeks or wetlands Sterna antillarum least tern E E Sand islands along the lower Mississippi River; Historically nested on sand islands along the Missouri River Plants Scientific Name Common Name Federal Status (a) State Status (a) Habitat Trifolium stoloniferum running buffalo clover E E Moist, partially shaded woodlands and to a lesser extent, along stream or river terraces (a,b) T = threatened, E = endangered Sources: NWMI 2015a; Niles et al. 2008; FWS 2015a, 2015b, 2015c; MDC 2000a, 2000b, 2016; NRC 2015

References:

[FWS] Fish and Wildlife Service. 2015a. Letter from Amy Salveter, FWS, to NRC,

Subject:

List of threatened and endangered species that may occur in your proposed project location, and/or may be affected by your proposed project. Consultation Code: 03E14000-2016-SLI-0314.

November 20, 2015. ML15335A002. [FWS] Fish and Wildlife Service. 2015b. Northern Long-Eared Bat, Myotis septentrionalis. Fort Snelling, Minnesota. April 2015. Available at: http://www.fws.gov/Midwest/endangered/mammals/nleb/nlebFactSheet.html (accessed 13 April 2016). [FWS] Fish and Wildlife Service. 2015c. Endangered Species Fact Sheet: Piping Plover. Fort Snelling, Minnesota. Last updated 23 April 2015. Available at:

http://www.fws.gov/midwest/endangered/pipingplover/pipingpl.html (accessed 13 April 2016). [MDC] Missouri Department of Conservation. 2000a. Missouri Animals of Conservation Concern. Jefferson City, Missouri. Available at:

http://mdc.mo.gov/sites/default/files/resources/2010/04/4068_1693.pdf (accessed 13 April 2016). [MDC] Missouri Department of Conservation 2000b. Missouri Plants of Conservation Concern.

Jefferson City, Missouri. Available at: http://mdc.mo.gov/sites/default/files/resources/2010/04/4069_1692.pdf (accessed 13 April 2016). [MDC] Missouri Department of Conservation. 2016a. Missouri Species and Communities of Conservation Concern Checklist. January 2016. Available at:

http://nature.mdc.mo.gov/sites/default/files/downloads/2016_SOCC.pdf (accessed 13 April 2016). Niles LJ, Sitters HP, Dey AD, Atkinson PW, Baker AJ, Bennet KA, Carmoa R, Clark KE, Clark NA, Espoza C. 2008. Status of the red knot (Calidris canutus rufa) in the Western Hemisphere. Studies in Avian Biology 36:1-185. [NWMI] Northwest Medical Isotopes, LLC. 2015. Preliminary Safety Analysis Report (PSAR), Chapter 19, "Environmental Report." Corvallis, OR: NWMI. January 2015. ADAMS No. ML15086A261.

[NRC] U.S. Nuclear Regulatory Commission. 2015. Teleconference Summary with Michelle Moser, NRC and Amy Salveter, FWS.

Subject:

Scoping Comments Regarding the Environmental Review for the Northwest Medical Isotopes, LLC (NWMI) Construction Permit Application. December 3, 2015. ADAMS No. ML15362A225.

1 NRR-PMDAPEm Resource From: Moser, Michelle Sent: Tuesday, April 26, 2016 12:16 PM To: brittnie.brauner@mdc.mo.gov

Subject:

Environmental Review for the Proposed Northwest Medical Isotopes, LLC Facility Attachments:

MDC 2015. Natural Heritage Review for th e Proposed NWMI Facility ML15355A246.pdf; State-Endangered Species for Northw est Medical Isotopes Project.docx Brittnie, It was a pleasure to talk with you the other day on the phone. As I mentioned during our conversation, I am a biologist with the U.S. Nuclear Regulatory Commission (NRC). Northwest Medical Isotopes, LLC (NWMI) submitted an application to the NRC to construct a radi oisotope production facility that, if licensed, would produce medical radioisotopes. NWMI would construct a production facility building, a support facility, a waste staging and shipping building, diesel generator building, administration building, and security stations. The proposed Discovery Ridge site includes 7.4 acres (ac) (3.0 hectares (ha)) of land located about 3 mi (5 km) southeast of the City of Columbia. The proposed site has been used for agricultural purposes for several decades. In its application to the NRC, NWMI did not identify any forests, prairies, riparian zones, or streams on the proposed Discovery Ridge site.

Attached is a Natural Heritage Level 3 Report regarding the proposed NMWI project. In addition, I've attached a list of State-endangered species that have the potential to occur on or near the site. The attached list of species also includes Federally-listed species, which is based on information provided by the U.S. Fish and Wildlife Service. Per our conversation, the NRC requests any additional information you may have regarding State-protected species, Natural Communities of Conservation Concern, and any other important ecological resource on or near the proposed Discovery Ridge site.

Please feel free to contact me if I can provide any additional information. My phone number is 301-415-6509 and my email is Michelle.Moser@nrc.gov. Regards,

Michelle Moser


Michelle Rome Moser Biologist U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation

Division of License Renewal Phone: 301-415-6509 Email: Michelle.Moser@nrc.gov

Hearing Identifier: NRR_PMDA Email Number: 2801 Mail Envelope Properties (Michelle.Moser@nrc.gov20160426121600)

Subject:

Environmental Review for the Proposed No rthwest Medical Isotopes, LLC Facility Sent Date: 4/26/2016 12:16:22 PM Received Date: 4/26/2016 12:16:00 PM From: Moser, Michelle Created By: Michelle.Moser@nrc.gov Recipients: "brittnie.brauner@mdc.mo.gov" <brittnie.brauner@mdc.mo.gov>

Tracking Status: None Post Office: Files Size Date & Time MESSAGE 2056 4/26/2016 12:16:00 PM MDC 2015. Natural Heritage Review for the Proposed NWMI Facility ML15355A246.pdf 809215 State-Endangered Species for Northwest Medical Isotopes Project.docx 24449 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

Missouri Department of Conservation Missouri Department of Conservation's Mission is to protect and manage the forest, fish, and wildlife resources of the state and to facilitate and provide opportunities for all citizens to use, enjoy and learn about these resources.

Natural Heritage Review Level Three Report: Species Listed Under the Federal Endangered Species Act There are records for species listed under the Federal Endangered Species Act, and possibly also records for species listed Endangered by the state, or Missouri Species and/or Natural Communities of Conservation Concern within or near the the

defined Project Area. Please contact the U.S. Fish and Wildlife Service and the Missouri Department of Conservation for further coordination.

Foreword:

Thank you for accessing the Missouri Natural Heritage Review Website developed by the Missouri Department of Conservation with assistance from the U.S. Fish and Wildlife Service, the U.S. Army Corps of Engineers, Missouri

Department of Transportation and NatureServe. The purpose of this website is to provide information to federal, state and

local agencies, organizations, municipalities, corporations and consultants regarding sensitive fish, wildlife, plants, natural

communities and habitats to assist in planning, designing and permitting stages of projects.

PROJECT INFORMATION Project Name and ID Number:

NWMI Proposed Facility #155 Project

Description:

Northwest Medical Isotopes, LLC (NWMI) submitted an application to the U.S. Nuclear Regulatory Commission to construct a radioisotope production facility that, if licensed, would produce radioisotopes. The proposed site

would cover approximately 7.4 acres (3.0 ha), which would include a production facility building, a support facility, a waste

staging and shipping building, diesel generator building, administration building and security stations. The site has been used

for agricultural purposes. In its application, NWMI did not identify any forests, prairies, riparian zones, or streams on the

proposed site.

Project Type:

Residential, Commercial and Governmental Building Development Contact Person:

Michelle Moser Contact Information:

Michelle.Moser@nrc.gov or 301-415-6509Missouri Department of ConservationPage 1 of 6Report Created: 12/18/2015 03:35:06 PM Disclaimer:

The NATURAL HERITAGE REVIEW REPORT produced by this website identifies if a species tracked by the Natural Heritage Program is known to occur within or near the area submitted for your project, and shares suggested

recommendations on ways to avoid or minimize project impacts to sensitive species or special habitats. If an occurrence

record is present, or the proposed project might affect federally listed species, the user must contact the Department of

Conservation or U.S. Fish and Wildlife Service for more information. The Natural Heritage Program tracks occurrences of

sensitive species and natural communities where the species or natural community has been found. Lack of an occurrence

record does not mean that a sensitive plant, animal or natural community is not present on or near the project

area. Depending on the project, current habitat conditions, and geographic location in the state, surveys may be

necessary. Additionally, because land use conditions change and animals move, the existence of an occurrence record does

not mean the species/habitat is still present. Therefore, Reports include information about records near but not necessarily

on the project site.

The Natural Heritage Report is not a site clearance letter for the project.

It provides an indication of whether or not public lands and sensitive resources are known to be (or are likely to be) located close to the proposed project. Incorporating

information from the Natural Heritage Program into project plans is an important step that can help reduce unnecessary

impacts to Missouri's sensitive fish, forest and wildlife resources. However, the Natural Heritage Program is only one

reference that should be used to evaluate potential adverse project impacts. Other types of information, such as wetland and

soils maps and on-site inspections or surveys, should be considered. Reviewing current landscape and habitat information, and species' biological characteristics would additionally ensure that Missouri Species of Conservation Concern are

appropriately identified and addressed in planning efforts.

U.S. Fish and Wildlife Service - Endangered Species Act (ESA) Coordination:

Lack of a Natural Heritage Program occurrence record for federally listed species in your project area does not mean the species is not present, as the area may

never have been surveyed. Presence of a Natural Heritage Program occurrence record does not mean the project will result

in negative impacts. The information within this report is not intended to replace Endangered Species Act consultation with

the U.S. Fish and Wildlife Service (USFWS) for listed species. Direct contact with the USFWS may be necessary to complete

consultation and it is required for actions with a federal connection, such as federal funding or a federal permit; direct cont act is also required if ESA concurrence is necessary. Visit the USFWS Information for Planning and Conservation (IPaC)

website at https://ecos.fws.gov/ipac/

for further information. This site was developed to help streamline the USFWS environmental review process and is a first step in ESA coordination. The Columbia Missouri Ecological Field Services Office

may be reached at 573-234-2132, or by mail at 101 Park Deville Drive, Suite A, Columbia, MO 65203.

Transportation Projects:

If the project involves the use of Federal Highway Administration transportation funds, these recommendations may not fulfill all contract requirements. Please contact the Missouri Department of Transportation at

573-526-4778 or www.modot.mo.gov/ehp/index.htm for additional information on recommendations.Missouri Department of ConservationPage 2 of 6Report Created: 12/18/2015 03:35:06 PM Missouri Department of ConservationPage 3 of 6Report Created: 12/18/2015 03:35:06 PM Species or Communities of Conservation Concern within the Area:

There are records for species listed under the Federal Endangered Species Act, and possibly also records for species listed Endangered by the state, or Missouri Species and/or Natural Communities of Conservation Concern within or near the the

defined Project Area. Please contact the U.S. Fish and Wildlife Service and the Missouri Department of Conservation for further coordination.

MDC Natural Heritage Review

Resource Science Division

P.O. Box 180

Jefferson City, MO

65102-0180

Phone: 573-522-4115 ext. 3182

NaturalHeritageReview@mdc.mo.gov U.S. Fish and Wildlife Service Ecological Service

101 Park Deville Drive

Suite A Columbia, MO

65203-0007

Phone: 573-234-2132 Other Special Search Results:

The project occurs on public land, CENTRAL REGIONAL OFFICE, COLUMBIA (A PERRY PHILIPS PARK LAKE), UNIV OF MO (SOUTH FARM R-1 LAKE), please contact MDC.

Project Type Recommendations:

New construction, maintenance and remodeling, including government, commercial and residential buildings and other structures.

Fish, forest, and wildlife impacts can be avoided by siting projects in locations that have already been disturbed or previously developed, where and when feasible, and by avoiding alteration of areas providing existing habitat, such as wetlands, streams, forest, native grassland, etc. The project should be managed to minimize erosion and

sedimentation/runoff to nearby wetlands, streams and lakes, including adherence to any "Clean Water Act Permit"

conditions. Project design should include stormwater management elements that assure storm discharge rates to streams for

heavy rain events will not increase from present levels. Revegetate areas in which the natural cover is disturbed to minimize

erosion using native plant species compatible with the local landscape and wildlife needs. Annual ryegrass may be combined

with native perennials for quicker green-up. Avoid aggressive exotic perennials such as crownvetch and sericea lespedeza.

Pollutants, including sediment, can have significant impacts far downstream. Use silt fences and/or vegetative filter strips t o buffer streams and drainages, and monitor the site after rain events and until a well-rooted ground cover is reestablished.

Project Location and/or Species Recommendations:

Endangered Species Act Coordination - Indiana bats (Myotis sodalis , federal- and state-listed endangered) and Northern long-eared bats (Myotis septentrionalis, federal-listed threatened) hibernate during winter months in caves and mines.

During the summer months, they roost and raise young under the bark of trees in wooded areas, often riparian forests and

upland forests near perennial streams. During project activities, avoid degrading stream quality and where possible leave

snags standing and preserve mature forest canopy. Do not enter caves known to harbor Indiana bats, especially from September to April.

If any trees need to be removed for your project, please contact the U.S. Fish and Wildlife Service (Ecological Services, 101 Park Deville Drive, Suite A, Columbia, Missouri 65203-0007; Phone 573-234-2132) for

further coordination.Missouri Department of ConservationPage 4 of 6Report Created: 12/18/2015 03:35:06 PM The project site submitted and evaluated is on or near Fish Spawning Stream Reaches Gans River, one of 138 state-designated fish spawning stream segments. These stream reaches were so designated because they have highly diverse fish

communities, fish Species of Conservation Concern present, and because they are important to maintaining, restoring, or

avoiding future listing of Species of Conservation Concern. These stream reaches also are included as a Missouri Nationwide

Permit Regional Condition (Number 2) that must be considered if working under a Clean Water Act Section 404 Permit issued

by the U.S. Army Corps of Engineers (http://www.nwk.usace.army.mil/Missions/RegulatoryBranch/NationWidePermit...

). A list of all stream reaches is available at http://www.nwk.usace.army.mil/Portals/29/docs/regulatory/nationwidepermi... . Activities that alter or destabilize stream bottoms or banks should be avoided during the important fish spawning period for that stream, in order to not disrupt fish spawning (i.e., laying and fertilizing fish eggs.) The sensitive spawning period for this stream i s March 15th to June 15th. At all times, avoid habitat destruction or introducing heavy sediment loads, chemical or organic

pollutants.

Invasive exotic species are a significant issue for fish, wildlife and agriculture in Missouri. Seeds, eggs, and larvae may be moved to new sites on boats or construction equipment. Please inspect and clean equipment thoroughly before moving

between project sites. See http://mdc.mo.gov//9633 for more information.

Remove any mud, soil, trash, plants or animals from equipment before leaving any water body or work area.

Drain water from boats and machinery that have operated in water, checking motor cavities, live-well, bilge and transom wells, tracks, buckets, and any other water reservoirs.

When possible, wash and rinse equipment thoroughly with hard spray or HOT water (?140° F, typically available at

do-it-yourself car wash sites), and dry in the hot sun before using again.

Streams and Wetlands - Clean Water Act Permits:

Streams and wetlands in the project area should be protected from activities that degrade habitat conditions. For example, soil erosion, water pollution, placement of fill, dredging, in-stream

activities, and riparian corridor removal, can modify or diminish aquatic habitats. Streams and wetlands may be protected

under the Clean Water Act and require a permit for any activities that result in fill or other modifications to the site. Cond itions provided within the U.S. Army Corps of Engineers (USACE) Clean Water Act Section 404 permit

(http://www.nwk.usace.army.mil/Missions/RegulatoryBranch.aspx ) and the Missouri Department of Natural Resources (DNR) issued Clean Water Act Section 401 Water Quality Certification (http://dnr.mo.gov/env/wpp/401/index.html

), if required, should help minimize impacts to the aquatic organisms and aquatic habitat within the area. Depending on your project

type, additional permits may be required by the Missouri Department of Natural Resources, such as permits for stormwater, wastewater treatment facilities, and confined animal feeding operations. Visit http://dnr.mo.gov/env/wpp/permits/index.html for more information on DNR permits. Visit both the USACE and DNR for more information on Clean Water Act permitting.

For further coordination with the Missouri Department of Conservation and the U.S. Fish and Wildlife Services, please see the

contact information below.

MDC Natural Heritage Review

Resource Science Division

P.O. Box 180

Jefferson City, MO

65102-0180

Phone: 573-522-4115 ext. 3182

NaturalHeritageReview@mdc.mo.gov U.S. Fish and Wildlife Service Ecological Service

101 Park Deville Drive

Suite A Columbia, MO

65203-0007

Phone: 573-234-2132Missouri Department of ConservationPage 5 of 6Report Created: 12/18/2015 03:35:06 PM Miscellaneous Information FEDERAL Concerns are species/habitats protected under the Federal Endangered Species Act and that have been known near enough to the project site to warrant consideration. For these, project managers must contact the U.S. Fish and Wildlife

Service Ecological Services (101 Park Deville Drive Suite A, Columbia, Missouri 65203-0007; Phone 573-234-2132; Fax

573-234-2181) for consultation.

STATE Concerns are species/habitats known to exist near enough to the project site to warrant concern and that are

protected under the Wildlife Code of Missouri (RSMo 3 CSR 1 0). "State Endangered Status" is determined by the Missouri

Conservation Commission under constitutional authority, with requirements expressed in the Missouri Wildlife Code, rule

3CSR 1 0-4.111. Species tracked by the Natural Heritage Program have a "State Rank" which is a numeric rank of relative

rarity. Species tracked by this program and all native Missouri wildlife are protected under rule 3CSR 10-4.110 General

Provisions of the Wildlife Code.

Additional information on Missouri's sensitive species may be found at http://mdc.mo.gov/discover-nature/field-guide/endangered-species . Detailed information about the animals and some plants mentioned may be accessed at http://mdc4.mdc.mo.gov/applications/mofwis/mofwis_search1.aspx . If you would like printed copies of best management practices cited as internet URLs, please contact the Missouri Department of Conservation.Missouri Department of ConservationPage 6 of 6Report Created: 12/18/2015 03:35:06 PM Table 1. Federally and State-Listed Species that may occur on or near the Proposed Discovery Ridge Site for the Proposed Northwest Medical Isotope, LLC Project Scientific Name Common Name Federal Status (a) State Status (a) Habitat Fish Anguilla rostrate Topeka shiner E E Pools of small prairie streams with good water

quality and gravel streambeds Scaphirhynchus albus pallid sturgeon E E Missouri River and lower portions of the Mississippi River; Currently extirpated from Missouri Mammals Myotis grisescens gray bat E E Caves year-long Myotis septentrionalis northern long-eared bat T Caves or mines during the winter and trees with loose bark or caves in the summer Myotis sodalist Indiana bat E E Caves during the winter and large diameter trees with loose bark in summer Spilogale putorius interrupta plains spotted skunk E Tallgrass prairies, forests, brushy areas, and cultivated lands with brushy cover Birds Botaurus lentiginosus American bittern E Freshwater marshes with dense stands of reeds and cattails Calidris canutus rufa red knot T Migrate from the artic to South America. Stopover habitat in Missouri most often includes muddy or sandy areas near the Missouri River Charadrius melodus piping plover T Wide, flat, open, sandy beaches with very little vegetation; Nesting occurs near small creeks or wetlands Sterna antillarum least tern E E Sand islands along the lower Mississippi River; Historically nested on sand islands along the Missouri River Plants Scientific Name Common Name Federal Status (a) State Status (a) Habitat Trifolium stoloniferum running buffalo clover E E Moist, partially shaded woodlands and to a lesser extent, along stream or river terraces (a,b) T = threatened, E = endangered Sources: NWMI 2015a; Niles et al. 2008; FWS 2015a, 2015b, 2015c; MDC 2000a, 2000b, 2016; NRC 2015

References:

[FWS] Fish and Wildlife Service. 2015a. Letter from Amy Salveter, FWS, to NRC,

Subject:

List of threatened and endangered species that may occur in your proposed project location, and/or may be affected by your proposed project. Consultation Code: 03E14000-2016-SLI-0314.

November 20, 2015. ML15335A002. [FWS] Fish and Wildlife Service. 2015b. Northern Long-Eared Bat, Myotis septentrionalis. Fort Snelling, Minnesota. April 2015. Available at: http://www.fws.gov/Midwest/endangered/mammals/nleb/nlebFactSheet.html (accessed 13 April 2016). [FWS] Fish and Wildlife Service. 2015c. Endangered Species Fact Sheet: Piping Plover. Fort Snelling, Minnesota. Last updated 23 April 2015. Available at:

http://www.fws.gov/midwest/endangered/pipingplover/pipingpl.html (accessed 13 April 2016). [MDC] Missouri Department of Conservation. 2000a. Missouri Animals of Conservation Concern. Jefferson City, Missouri. Available at:

http://mdc.mo.gov/sites/default/files/resources/2010/04/4068_1693.pdf (accessed 13 April 2016). [MDC] Missouri Department of Conservation 2000b. Missouri Plants of Conservation Concern.

Jefferson City, Missouri. Available at: http://mdc.mo.gov/sites/default/files/resources/2010/04/4069_1692.pdf (accessed 13 April 2016). [MDC] Missouri Department of Conservation. 2016a. Missouri Species and Communities of Conservation Concern Checklist. January 2016. Available at:

http://nature.mdc.mo.gov/sites/default/files/downloads/2016_SOCC.pdf (accessed 13 April 2016). Niles LJ, Sitters HP, Dey AD, Atkinson PW, Baker AJ, Bennet KA, Carmoa R, Clark KE, Clark NA, Espoza C. 2008. Status of the red knot (Calidris canutus rufa) in the Western Hemisphere. Studies in Avian Biology 36:1-185. [NWMI] Northwest Medical Isotopes, LLC. 2015. Preliminary Safety Analysis Report (PSAR), Chapter 19, "Environmental Report." Corvallis, OR: NWMI. January 2015. ADAMS No. ML15086A261.

[NRC] U.S. Nuclear Regulatory Commission. 2015. Teleconference Summary with Michelle Moser, NRC and Amy Salveter, FWS.

Subject:

Scoping Comments Regarding the Environmental Review for the Northwest Medical Isotopes, LLC (NWMI) Construction Permit Application. December 3, 2015. ADAMS No. ML15362A225.