ML15328A071

Northwest Medical Isotopes, LLC - Response to the U.S. Nuclear Regulatory Commission Request for Additional Information, Environmental Review of the Construction Permit Application, Including Document No. NWMI-2015-RAI-001. Part 1 of 14

ML15328A071
Person / Time
Site:	Northwest Medical Isotopes
Issue date:	11/20/2015
From:	Northwest Medical Isotopes
To:	Northwest Medical Isotopes, Office of Nuclear Reactor Regulation
Shared Package
ML15328A010	List: ML15328A070 ML15328A071 ML15328A072 ML15328A073 ML15328A075 ML15328A076 ML15328A077 ML15328A078 ML15328A079 ML15328A080 ML15328A081 ML15328A082 ML15328A083 ML15328A084
References
NWMI-LTR-2015-005 EDF-3124-0011, Rev. 1, NWMI-2015-RAI-001, Rev. 0
Download: ML15328A071 (75)

Text

"O " NWM!I

• ,OC. NORTHWEST MEDICALISOTOPES ATTACHMENT 1 Northwest Medical Isotopes, LLC Response to the U.S. Nuclear Regulatory Commission Request for Additional Information Environmental Review of the Northwest Medical Isotopes, LLC Construction Permit Application (Document No. NWMI-201 5-RAI-001, November 2015)

Information is being provided via hard copy

• ,Oo.O

• eOOO

• 0 @00.0 NWMI NORTHWEST MEDICAL ISOTOPES Response to the U.S. Nuclear Regulatory Comm ission Request for Additional Information Environmental Review of the Northwest Medical Isotopes, LLC Construction Permit Application NWMI-2015-RAI-O01, Rev. 0 November 2015 Prepared for:

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

This page intentionally left blank.

I

NWMI-2015-RAI-001

!;: NWM!I Rev. 0 Response to the U.S. Nuclear Regulatory Commission Request for Additional Information Environmental Review of the Northwest Medical Isotopes, LLC Construction Permit Application NWMI-201 5-RAI-OO1, Rev. 0 Date Published:

November 23, 2015

Title:

Response to the USNRC Request for Additional Information - Environmental Review of the NWMI Construction Permit Application Checked by: N/A Approved by: Carolyn Haass Signature: C w['*Yp *-

ii

NWM1-201 5-RAI-001

!:;i!NWM!I

• , ,, OR'STM*IAIOOESc Rev. 0 REVISION HISTORY Rev Date Reason for Revision Revised By 0 11/23/2015 Issued for Submittal to USNRC NA

NWMI-201 5-RAI-001 WMI Rev. 0 TERMS Acronyms and Abbreviations 41Ar argon-41 99 Mo molybdenum-99 1311 iodine-13l

' 33Xe xenon- 133 ALARA as low as reasonably achievable BLM Bureau of Land Management CATSO Columbia Area Transportation Study Organization CFR Code of Federal Regulations CO carbon monoxide CO 2 carbon dioxide CSR Code of State Regulations Discovery Ridge Discovery Ridge Research Park DOT U.S. Department of Transportation EH&S Environmental Health & Safety EPA U.S. Environmental Protection Agency ER Environmental Report FHWA Federal Highway Administration H2 hydrogen gas HAP hazardous air pollutant HEU highly enriched uranium HIC high-integrity container HVAC heating, ventilation, and air conditioning LEU low-enriched uranium LLMW low-level mixed waste MDNR Missouri Department of Natural Resources Mo molybdenum MU University of Missouri MURR University of Missouri Research Reactor N2 0 nitrous oxide NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NHC n-hydrocarbon NO nitric oxide NO 2 nitrogen dioxide NOx nitrogen oxides NPDES National Pollutant Discharge Elimination System NRC U.S. Nuclear Regulatory Commission NWMI Northwest Medical Isotopes, LLC 02 oxygen 03 ozone OAR Oregon Administrative Rule OSHA Occupational Safety and Health Administration OSTR Oregon State University TRIGA Reactor OSU Oregon State University Pb lead PM particulate matter

• ,,o

  "NOESTMEUAIS/IfTlPE5 PM-2.5 particulate matter, 2.5 micron PM- 10 particulate matter, 10 micron PPE personal protective equipment RCRA Resource Conservation and Recovery Act RO Reactor Operator ROI region of influence RPF Radioisotope Production Facility SHPO State Historic Preservation Office SO2 sulfur dioxide SO* sulfur oxides SPA Special Planning Area SPCC spill prevention, control, and countermeasure SRO Senior Reactor Operator TCE trichloroethylene Terracon Terracon Consultants, Inc.

TNM Traffic Noise Model TRIGA Training, Research, Isotopes, General Atomics U.S. United States U.S.C. United States Code USFWS United States Fish and Wildlife Service USGS U.S. Geological Survey VOC volatile organic compound Units

[tCi microcurie gg microgram A ampere Bq becquerel Ci curie dBA A-weighted decibel ft feet ft2 square feet ft3 cubic feet g gram gal gallon ha hectare hr hour in. inch kg kilogram km kilometer kVA kilovolt-amp L liter lb pound m meter m2 square meter m3 cubic meter Mgal million gallons mi mile mL milliliter ML megaliter mm millimeter ii

NWMI-201 5-RAI-001 NV IVI Rev. 0 mrem milifrem MW megawatt ppb parts per billion ppm parts per million t tonne (metric)

VAC volts alternating current wt% weight percent yd 3 cubic yard yr year iii

K E~M NE 53 NWMI-201 5-RAI-001 Rev. 0

• . EUVI

• ORCAWESTMED CA SCIAPA This page intentionally left blank.

iv

NWM I-201 5-RAI-001 I~I1JV lvi I Rev. 0 iAIR-1A 'Clarif if Table 19-58 of the Environmental Reportpresents emission factors or

( emissionsfor off-road construction equipment. if Table 19-58 does present

emissionsfor off-road construction equipment, verify~the emissions presented for p...*art!iculate matterless_ than 2.5 microns. 2 ... _ * ..

Table 19-58 provides emissions for off-road construction. The emissions in Table 19-58 have been verified. Changes to the table include removing "Factors" from the table title and correcting the mislabeled column headings. Table 19-58 has been revised and is presented below.

Table 19-58. Air Pollutant Emissions for Off-Road Construction Equipment U

Bulldozer

)Compactor (1

1

[100 120 m*ml/m***l*ln 11401...3.10 160 340

_..19 I_41 _.1.*

21 46' 6.3 7.0 -I14 1

!4:7]10 1*'5 :5.3

!13,000j29,000i 12 -15,000 32,000 23 26 51 157j Excavators 2.4 9i54i' 1.8 4.0 4,500 110,0001 8.1 18 tFront loaders 1 120 68 150 10 23 3.4 7.4 2.5 5.6 6,200 14,000 11 25 1 Graders 1 80 i661150 !10 i22j  : . . ) . 6,0001 13,000o 11r24 3.2 iPaver 1 80 =64 1.40 10 22 7.0 2.4 ,5.3 5,900 13,000 11 23]!

Asphalt

......... roller 1 8-*%0---1-iO--230-! 14 ... 31 i 4.7

.......T-otal -647 1i430 9"1.5 ....202- 30.2- 66;.0 22.6 50.0oo 60,300' 132,000 107.1 2-361 Source: EDF-3124-0009, Off-Road Emissions During Construction, Rev. I, Portage, Inc., Idaho Falls, Idaho, July 31, 2015.

PM-2.5 =particulate matter, 2.5 g+/-. PM- 10 =particulate matter, 10 i.

1 of 58

NWMI-201 5-RAI-001 Rev. 0 IAIR-1B Section 19.4.2.1.2.5 of the ER states." "Emissions data shown in Table 19-63 ,/

,provide an estimate of vehicle emissions. Calculationsused to obtain the estimates are based on an average workforce of 25-5 0 vehicles/day using a specific vehicle ratio (60 percent light-duty autos, 30 percent light-duty gas, ftrwckg, andk2percen//igh/-dziy diese/trudi) andaroz/ndlripof 40 rni/day..."

.However, Table 19-6 lists that during operation the average workforce andpeak workforce will be 98. Explain why 25-5 0 vehicles/day were assumed during the The stated estimate assumed that employees will carpool, with two to three people per vehicle. To provide a more bounding evaluation, the calculation has been reanalyzed assuming that each individual will drive their own vehicle and that 100 vehicles are used. Table 19-63 has been revised and is presented below.

Table 19-63. Vehicle Emissions During Operations

-- I ll/

Light duty autos i Gas, 1,085 ;2,392

• 95 210 225,239 496,569 11 1 i 3 ,, 2 3is SLight duty trucks Gas 1,323 2,917 122 268 129,506 !285,513 2 i4 1 3 . 1 Light duty trucks Diesel 177 701 -6 -6 !13 Al T~otal... .. ... . .... 2,443 5,385 286 631 391,748 863,662 9 '21 9 ,19 4 9 Source: EDF-3 124-0013, On-Road Emissions for Vehicles During Operation, Rev. 1, Portage, Inc., Idaho Falls, Idaho, July 31, 2015.

PM-2.5 = particulate matter, 2.5 p.. PM-10 particulate matter, 10 p..

Table 19-64 has been revised and is presented to the right. Table 19-64 Expected Green House Gas Emissions from Radioisotope Production Facility Project SC.onstru)c.t ion p h ase on sit e ....... .. 44 ,000... i 97,000 Construction phase offsite i610,000 1,330,000i Normal plant operations (per year) I23,000,000 51d0*00 00 Operations on-road vehicle travel I 392,000 864,000i l(per year)I Source: EDF-3124-0011, Greenhouse Gas Emissions, Rev. 1, Portage, Inc., Idaho Falls, Idaho, July 31, 2015.

2 of 58

SNW MI NWMI-2015-~-0Rv

-. WUE . . . IPE IAIR-I1C Scin19.4.2.1.2.5 of the ER states "During the operationsphase, vehicular air .

• emissions would resultfrom the commuting workforce andfrom routine deliveries

to andfrom the proposedRPF." Table 19-6 of the ER provides an estimate of ,!

vehicle emissions. Clarify if Table 19-6 emissions accountfor both commuting *t

_workforee andjfrom routine deliveries to/from the RPF....

Table 19-63 has been revised to reflect 100 vehicles a day. This number includes both workforce commuters and routine deliveries to the Northwest Medical Isotopes, LLC (NWMI) Radioisotope Production Faction (RPF). The revised Table 19-63 is provided in the AIR-lB response.

AIR-1D "Table 19-56 of the ER identifies 100 for workforce travel du~ing thee cons truction ;-*

S phase. However, Table 19-6 identifies a peak workforce o,/82 aduriingcorns/ruc//on¢.

C/r, h I2 wr, wervl a sdnTable 19-6. ... . _

The peak workforce is assumed to be 82 during construction, with an average workforce assumed to be

38. By estimating the mileage for 100 vehicles, the calculation bounded any potential emissions, including those by other service providers such as for routine deliveries. Table 19-63 accounts for the commutinlg workforce and routine deliveries to/from the RPF. The revised Table 19-63 is provided in the AIR-lB response.

AIR-I1E Table 19-59 of the ER consideredfugitiv~e dust, windblown dust, and emissions  ; VZ? "

from off-road construction equipment from constructiOnpresented in Tables 19-5 5 <

'and 19-58. However, the total amountpresented in Table 19-59 does not equate * .

=to the sum fromTables 19-55 and 19-58. Clarify the differences in these values. *_

The values in Tables 19-55 and 19-58 represent the results of the calculations documented in each referenced engineering design file and are rounded to the appropriate number of significant figures.

Table 19-59 has been revised to the summation of values presented in Table 19-55 and 19-58 and is presented below.

3 of 58

NWMI-201 5-RAI-001

":=,..%=:" No*mwes'raeocat soToP*

Rev. 0 Table 19-59. Anticipated Gaseous Effluents and Their Associated Air Quality Parameters for Construction PM-10 1,503 3,226 2.91 g.g/m , 1.20 j*tglm a150 gig/m 3 r iM_2.5 304.* " *674 61 gtg/mn33.. 25 . gtg/m 3 ' b3 5 jig/mn3 NOx j 647.1 ,430 68ppb i 28ppb clO100ppb S CO- 9P'5 2 20* 0.Olppm .. 006 P~ 35 ppm '

SOx i 107 236 0.008 ppm 0.003 ppm e0.075 ppm Source: EDF-3124-0014 rev-01, Emission Modelingfor ConstructionActivities using AERSCREEN, Rev. 0, Portage, Inc.,

Idaho Falls, Idaho, July 30, 2015.

a24-hr, not to be exceeded more than once per year on average over three years.

b 24-hr, 9 8 th percentile, averaged over three years.

e1-hr, 9 8th percentile, averaged over three years.

d 8-hr, not to be exceeded more than once per year.

l -hr, 99th percentile of 1-hr daily maximum concentrations, averaged over three years.

AIR-IF Tablethe S from 19-61 fourand Table natural 19-62 gas of the boilers. ER present Hourly total annual and annual and hourly emissiions, however, emissions from *V thesetwo tables do not match. Clarify. andprovide the correct annual and hourly "* ,'

t~otal emissionsfrom the gas-firedboilers. ..... J Table 19-6 1 contained several errors on conversion of pounds (lb)/hour (hr) to Tables 19-61. Natural Gas-Fired Boiler Total Annual Emissions kilogram (kg)/hr. The second and third column headers were mislabeled in Table 19-62. Table 19-6 1 and 19-62 have been revised and are presented below.

4.2

.... ..... . ...

• 16 i 18 1.9 1

!NOX 10 11 o1.13 PM (total) {0.36 1.6 0.18 0.39 jNHC(voo) 1.1 12 0.23 So 2 * -- 01..

A2- 0.13 0.0....O 15--*

• I c0 2 ..24,000-- 26,000 2722 2, 6,000 Source: EDF-3 124-0008, Emissionsfrom Natural Gas-FiredJBoiler Operation, Rev. 0A, Portage, Inc., Idaho Falls, Idaho, June 26, 2014.

NHC = n-hydrocarbon.

PM = particulate matter.

VOC = volatile organic compound.

4 of 58

NWMI NWM[-201 5-RAI-00Re.i Tables 19-62. AERSCREEN Model Total Annual Emissions CO I 4"2E+00 __ 18  ! 72E+01 !4.6E+01 i4.0E+04 NO 25E001 4.E0 2.7E+01 1.9E+02]

PM-10 (total)c , 3.9E-01 1.6 . 6..... +/-00 4.E00g 5 jPM-10 (filterable)d9.8E-02 0.40 1.6E+/-00 ,1.0E+00 g3 5 VOCe 2.8E-01J 1.2  ! -  ! -

. SO2 3.0E-02 0.13 - 4.7+01 E +00 +0 197E+021 CO2 -- 6"0E+03 " 26,000 i 5. 1E-01i! 3.3E-01 NA Source

EDF-3 124-0012, Emission Modelingfor Process and HVAC Boilers Using AERSCREEN, Rev. 1, Portage, Inc.,

Idaho Falls, Idaho, February 4, 2015.

aThe stack effluent maximum concentration was determined to be at 136 meters (in) (446 feet [ft]).

b Based on 50 weeks/year.

SUsed as PM-10 values.

d Assumed to represent PM-2.5.

No NAAQS for volatile organic compounds.

rNo NAAQS for carbon dioxide.

g 24-hr standard for PM-10 and PM-2.5 NA =not applicable. PM-10 = particulate matter, 10 I..

NAAQS = National Ambient Air Quality Standards. VOC = volatile organic compound.

PM-2.5 = particulate matter, 2.5 ft.

'*AIR-1 G Section 19.4.2.1.1l of the ER identifies batch plant operations as a source of 1$"

S fugitive dust. Clarify ifa batch plant will be onsite and if emissionsfrom batch  :

plant operations are accountedfor in Section 19.4.2.1.1 of the ER.

The batch plant in assumed to be offsite. The two references to the batch plant being onsite were removed from Section 19.4.2.1.1. Emissions from the batch plant are not included in Section 19.4.2.1.1.

The closest batch plant from the RPF is Columbia Ready Mix located at 2600 N. Stadium Drive, Columbia, Missouri. Columbia Ready Mix is 7.6 kilometer (kin) (4.7 mile [mil) from the RPF. The delivery of the concrete to the RPF site is included in our emission estimates in Table 19-57.

5 of 58

NW iNWM, -20 5-RAI00OevI AIR-2A Section 19.2.3.1.2 of the ER states: "The offgas containing the fission product gases goes through a series of cleanup columns. The nitrogen oxides (NOx) is fI'l v" removed by a reflux condenser and several NOx absorbers, the fission product gases (noble and iodine) are captured on absorbers, and the remaininggas is filtered and discharged into the process ventilation header." Table 19-86 of the ER states "The RPF would emit minor emissions of NOx and CO2 along with levels of radionuclides below 10 CFR 20 levels. "Furthermore, Section 19.4.2.1.2.3 of the ER, states. "Gaseous effluents resultingfrom the production process are based on a 50-week/year operatingschedule. There are no emissions of CO, Pb, 03, or particulatematterfrom the process exhaust system. " However, Section 19.4.2.1.2.3 does not discuss NON, S02, or CO2 emissions or quantify the amount of NOx, SO2, or CO2 emitted resultingfrom the RPF production process. Clarify ifNOx, 502, or CO2 would be emitted during the production process. If so, provide NO., SO 2, and CO2 emissions resulting from... .. ..

o m.the.production.process........ ....... ....... .... ....... ... ... . ...

Primary process system reactions do not generate quantities of carbon dioxide (CO2) or sulfur dioxide (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 (N 2 0), C0 2 , carbon monoxide (CO), and hydrogen gas (H2) at concentrations that are approximately 0.1 percent of the total nitrogen oxides (NOx) (NO + NO 2) generated. The 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 SO2 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. The estimate of NOx, generation from dissolution is 582.5 kg NOx,/year (yr) as nitrogen dioxide (NO2), and the bounding stack emission is 42.64 kg NOx,/yr as NO 2 .

The third paragraph in Chapter 19.0, Section 19.4.2.1.2.3 has been revised and is provided below.

Each process offgas subsystem would treat the process offgas components separately to prevent mixing of waste constituents (additional information is provided in Section 19.2.3.2.12). Gaseous effluents resulting from the production process are based on a 50-week/yr operating schedule. There are no emissions of CO, lead (Pb), ozone (03), or particulate matter (PM) from the process exhaust system. The bounding stack emission estimate of NOx, is 42.64 kg NO,,yr as NO2 . Iodine fission products would be removed using absorption methods. Fission product gases such as xenon and krypton would be removed using decay beds.

6 of 58

NWMI-201 5-RAI-001 NWMI amwesrEDICA]. PEE Rev. 0 IAIR-2B Section 19.4.2.2.4 of the ER states that emission-specific strategies would be developed and implemented to ensure compliance with NAAQS andNESHAP ill' v standards. However, the ER does not quantify the hazardous airpollutants emitted resultingfrom operations. Identijfy sources of hazardous airpollutants (HAPs), quantify HAP emissionsfrom these sources during construction, operation, and decommissioning, andprovide supporting calculations.

The RPF will mitigate any hazardous air pollutants (HAP) to meet standards/release limits. The oniy source of HAPs identified is trichloroethylene (TCE), which is used in the target fabrication system during low-enriched uranium (LEU) target material washing. Spent TCE recovery is described in Chapter 4.0, Section 4.4.2.8.1, and Table 4-75 estimates the RPF inventory at 53 gallons (gal). The TCE systems will be designed to meet Title 40, Code of FederalRegulations, Part 61 (40 CFR 61), "National Emission Standards for Hazardous Air Pollutants" (NESHAP) standards and be significantly less than the Missouri de minimis level for total volatile organic compounds (VOC) of 40 tons/year.

AIR-2C Provide the following ER referencesfor review:" V

• EDF-3124-O011, Greenhouse Gas Emissions, Rev. 0, Portage, Inc., Idaho Falls, Idaho, June 26, 2014.

• EDF-3124-O008, Emissionsfrom Natural Gas Boiler Operation, Rev. 0, Portage,Inc., Idaho Falls, Idaho, June 26, 2014

• EDF-3124-O012, Emission Modelingfor Process andHVA C Boilers Using AERSCREEN, Rev. 1, Portage,Inc., Idaho Falls, Idaho, February 4, 2015.

• EDF-3124-O013, On-Road Emissionsfor Vehicles During Operation, Rev. 0, Portage,Inc., Idaho Falls, Idaho, June 26, 2014.

The reference documents listed above (or most current revisions of those documents) are aftached in Appendix A, B, C, and D, respectively.

AIR-3 The ISG augmenting NUREG-1537, Part]1,Section 19.1.2, "Regulatory V"

• Provisions,Permits, andRequired Consultations,"'and10 CFR 51.45(d) state that an applicantshould list and summarize the status of all applicable Federal, State, local, and other regulatory requirements,permits, and consultations that would be requiredfor the proposedfacility to be constructed and operated

• Table 19-4 in the ER identifies that construction and operatingairperm its from the Missouri Departnent of NaturalResources (MDNR) are not required Has NWMI contacted MDNR regarding the determination that air emission sources will be exempt from permitting requirements and has MDNR confirmed that air permits will not be required? If so, provide documents (e.g., letters) of such communication. Otherwise, indicate the applicant'~splans and associated ti..

.. .e..

.e.. .. . ... .. .. . . .. . . . . . . .. . . .. .. .. . . .. .. .. . . .. .. . . . . .. . . ..-.

NWMI made the determination that air permits from the Missouri Department of Natural Resources (MDNR) are not required for the construction and operation based on MDNR's published regulations.

However, NMWI anticipates contacting MDNR with a specific request by March 2016.

7 of 58

• • MII M fNW NWMI-201 5-RA,-001ov0

.lii ..

SALT-I The ISG augmenting NUREG-153 7, Part]1,Section 19.].], "Purposeand Need /"

for the Proposed Action, "states that the ER should describe how the proposed action would satisfy global, national, or regionalprojected demands for the radioisotopeproducts to beproduced through implementation of the proposed action. Section 19.5.] of the ER states that "ftjhe current demandfor 9 9mTc in the U.S. requires a weekly supply of approximately 6,000 six-day Ci of 99Mo, approximately 50 percent of the annual U.S. demand." This seems contradictory.

Is 6,000 six-day Ci of 99 Mo the current demand or 50% of the demand?

Historically, the U.S. demand for molybdenum-99 (9 Mo) is 6,000 six-day curies (Ci), which is 50 percent of the world demand (NAS, 2009, Medical Isotopes Production Without Highly Enriched Uranium; and NEA, 2012, A Supply andDemand Update of the Molybdenum-99 Market). Currently, the world demand is estimated to be 10,000 six-day Cl/week with U.S. demand at 5,000 six-day Ci per week (NEA, 2015, The Supply of Medical Isotopes -2015 Medical Isotope Supply Review." 99 Mo/°gmTc Market Demand and Production Capacity Projection 2015-2020). Section 19.5.1 was modified to state the following: "The current demand for 99mTc in the U.S. requires a weekly supply of approximately 5,000 to 6,000 six-day Ci of 99Mo, approximately 50 percent of the world demand."

• ALT-2A Make availablefor docketing the Alternative Site Selection presentationgiven at  :

the site audit.

The NWMI Site Alternative Study presentation given at the site audit is attached in Appendix E.

,ALT-2B Section 19.5.2.2 of the ER identifies available space as a screening criterion and V"

• states that all sites have the minimum amount of space requiredfor the production

• facility, but differences in available space could impact the complexity of facility design. Discuss the space limitations at the MURR, Oregon State UniversityI If the RPF were to be constructed and operated near one of the university reactors, the complexity and cost of the facility is anticipated to increase compared to the Discovery Ridge Research Park (Discovery Ridge) site. All of the sites next to university reactors have the minimum amount of space required to construct and operate an RIPF. However, all sites had less than half of the space available at Discovery Ridge. Space availability near each of the university reactors is limited due to existing structures and space allocation by the owners of the sites. The differences in available space between the sites near university reactors and Discovery Ridge are anticipated to lead to increased intricacies of the facility design, which leads to operational complexities (e.g., hot cell processing, facility deliveries, personnel movement),

increase in construction (e.g., greenfield construction verses construction within existing infrastructure) costs, and limits the ability to expand the.R~PF inthe future (e~e.g., education, _rese~archand development)...

!ALT-3A The ISG augmenting NUREG-1537, Part 1, Section 19.5 "Alternatives, "states - ,t ti thatfor each reasonable alternativesite, a description should be provided In the lI ER. Provide the following figures pertainingto the MURR alternative site.,

S Radioisotope ProductionFacility site boundary at the MURR alternative site*

S (similar to what was providedfor the Discovery Ridge Site in Figure 19-6 of the The requested figure of the University of Missouri Research Reactor (MURR) site is provided on the following page.

8 of 58

N WM 1-201 5-RAI-001

.o NWM%.

111//l ie'wln-$TusO:A., w!

Rev. 0 RPF FaOliyAI 3 ki RPF Ske E MURR Site O* 8 lun (5 mile) Radius fraom RPF Site

• ]MURR Fence -m= Inters tate

-.- Highwys

,iCity Limits 0 0.03 0.06 0.12 0.18 0.24s Miles 9 of 58

NWMI-2015-RAI-001

""... ".r'atMC,* rIDP IW Rev. 0 The requested figure of the 8 km (5-mi) radius from the MURR site is provided below.

• ]MURR Site ra=Interstate Highways

-Highways 08 km (5 mile) Racjus from MURR Site (? City Limits o 0.5 1 2 3 4 i i Mdes 10 of 58

NW.MlI~f

• ";.;" EIV os.,, tIV. I eNWMI-2o01 5-RAI-O01ev0 Rev.

gggg CON-I 10 CFR 51.45(e and the ISG augmenting NUREG-153 7, Part]1, Section 19.6, v" "Conclusions" state that the ER should include a discussion on the unavoidable adverse environmental impacts of the proposed action. Section 19.6.] states that

"[i'fthe site is returned to its current state, there would be no unavoidable adverse environmental impacts associatedwith the proposedaction." Yet, Sections 19. 6.1.1] and 19.6.1.2 determines SMALL unavoidable impacts to construction and operation. Unavoidable impacts are, by definition, not avoided simply through decommissioning. Unavoidable adverse impacts are predicted adverse environmental impacts that cannot be avoided and that have no practical.

means offlhrther mitigation. Clarify how there can be "no unavoidable adverse environmental impacts" as statedin the headerSection 19.6.1 of the ER andyet there are such impacts, albeit small ones, as discussed in Subsections 19. 6.1.1 and.

19.6.1.2 of the ER. Further, reconcile the statement in Section 19.6.1 with the statements in Section 19.6.2.1 and 19.6.2.2 that "[siome small adverse environmental impacts could remain after allpracticalmeasures to avoid or mitigate them are taken."

The unavoidable impacts defined in Sections 19.6.1.1 and 19.6.1.2 are "unavoidable" during both the construction and operating phases of the RPF. The impacts may include air emissions and land use changes and are defined in Table 19-92. Transient unavoidable impacts (e.g., air emissions) will cease after the RPF is decommissioned. Unavoidable impacts (e.g. impacts to land use) would be mitigated once the RPF has been decommissioned and the site is returned the current state. The first paragraph, fourth sentence of Section 19.6.1 has been revised to read as follows: "If the site is returned to its current state, no unavoidable impacts are expected to remain."

11 of 58

NWMI NWg-0g5RIg0 CONN- Describe a hypothetical third research reactorthat is representativeof the 1A.1 research reactors.NWMI is considering. Include the following environmental I'll 1' parameters:"

A description of necessary or anticipatedmodifications at the reactor to support target irradiation.Identify."

If modifications would be internal or external to the existing structures and if/there would be any associatedground-disturbingactivities (quantify acreage affected)

No external or internal modifications would be required to the hypothetical third reactor. Three equipment refurbishments and/or needs have been identified for the hypothetical third reactor to handle both unirradiated and irradiated LEU targets. These equipment refurbishments and/or needs include:

• Equipment refurbishments

- Refurbish an existing overhead crane (e.g., replacement of contactors, motor brushes, etc.). Any modification will follow the process described in 10 CFR 50.59, "Changes, Tests, and Experiments," for making changes to a facility.

• Equipment needs

- Design and build an intermediate target transfer cask to transfer irradiated targets from the primary reactor tank to a Type B transport cask. This cask will be similar, both physically and functionally, to the current TRIGA single-element transfer cask that is routinely used for fuel movements at TRIGA-fueled facilities worldwide.

- Design and build an unirradiated LEU target storage rack. The storage rack is anticipated to be a metal box with two holding plates containing guide tubes in a grid pattern necessary to maintain a geometrically safe criticality configuration.

These potential activities are anticipated to be internal to existing structures and will not require ground-disturbing activities.

SCONN- Additional workforce needed to support modifications /"

I1A.2 The additional workforce needed to support modifications or equipment needs will be temporary for the hypothetical third reactor. The refurbishment of the overhead crane will be performed by subcontracted personnel with supervision by reactor personnel. The fabrication of the transfer cask and unirradiated LEU target storage rack will be outsourced to a qualified mechanical fabrication vendor.

CO-NN- Depth *o'f ex-cavat-ion e-xpec'ted t-o be r-equ~ire'dfor-n-w/mod-fiqedfacilitiesandutility ..... V1.........

I A.3 connections No new/modified facilities or utility connections will be required for the hypothetical third reactor. Thus, ground-disturbing activities that require excavation are not required.

iC0N-NDrto fatiiist opet olain and to comsso he mo-diid .. ...... >...

_IA -4 __fa~cilities and equ__i me~nt.. . .. . . . .. .. .. .. . . ... .. . . .. . ... .. . . .... . .

The equipment modifications or fabrication of required equipment at an off-site vendor is anticipated to take two months to complete at the hypothetical third reactor.

12 of 58

• ~.* IU~AIflfl

• NWMI-201 5-RAI-O01 I~Ivv IVi N Rev. 0

-N .N .N NI'gllg SCONN- Any additionalnoise, traffic, or air emissionsfrom facility modification activities V" The transport of the fabricated unirradiated LEU storage racks and transfer cask will result in a single delivery for each when completed. The increase in traffic due to the crane modifications will involve a commute to the third reactor facility by one vehicle for a short duration (e.g., less than two weeks). This volume of traffic is considered within the normal traffic patterns expected at the third reactor. Due to minimal traffic and no ground-disturbing activities at the hypothetical reactor, there will be no appreciable increase in either noise or traffic.

CON N- Land-use classification of the thirdreactor V" 1B Land use is a general indication of how land is used--residential, commercial, industrial, open space, etc.

Land use defines broad categories; zoning is used to implement land use plans. These plans can be developed by a number of entities such as universities, cities, counties, regions, or states.

The land use for the hypothetical third reactor is anticipated to be similar to both MURR and Oregon State University (OSU) TRIGA Reactor (OSTR). Thus, the land use will be a university-planned district area that will have a mixed use.

,CON N- Additional workforce needed to support operation activitiesfor irradiatingtargets V

. I C.. . . . . . . . . . . . . . . . . . .. . . . . . . . .. . .. . . .. . . . . . .. . . . . . . . . . . . .. . . . . . . . .

For the hypothetical third reactor, an increase in staff is expected and is anticipated to be similar to OSTR. The operational tempo is anticipated to increase from a nominal 40-hr work week irradiation schedule to 24/7 operations on a weekly basis when commercial LEU target irradiation services are being provided by the hypothetical third reactor. The anticipated required staff of the hypothetical third reactor will comprise four Senior Reactor Operators (SRO) and three Reactor Operators (RO). At least four additional SRO and six additional RO positions are assumed to be required to oversee and manage the increase in operational tempo. The university setting offers flexibility in hiring; thus, additional staff will likely be drawn from the existing university population.

CON N- Identify if target handling and irradiationwill result in changes in the types or V" 1ID increases in the non-radiologicaleffluent releases and waste streams at the reactor.Provide sources, types, and approximate quantities of non-radiological effluents or waste and discuss non-radiologicalwaste management impacts of J target handling and irradiation.

No anticipated changes in the sources, types, and quantities of nonradiological effluent releases and waste streams are expected from the handling of unirradiated or irradiated LEU targets at the hypothetical third reactor.

SCON N- Additional water use to complete modifications and to support operation activities.............. V........t I 1E for irradiatingtargets (as compared to existing operations)

No additional water use to complete modifications and to support operation activities for irradiation targets is anticipated at the hypothetical third reactor.

13 of 58

• ~NWMI NWM[-201 5-RAI-001

. ... . . ii iCON I1F N- Discuss handlingthe andstorage and treatment irradiation of non-radioactivemateraialfrom target at the reactor.  : V, No additional nonradioactive material is anticipated to be generated other than the manufacture of an unirradiated LEU target storage rack. Built entirely of stainless steel, these racks are anticipated to be square, lockable containers with rack locations (i.e., guide tubes) for the unirradiated LEU targets.

Approval for the geometry, design, and construction will be promulgated through a license amendment request by the hypothetical third reactor.

CONN- Discuss human health impacts due to target handling and irradiation. 9' 1 I G.I Specifically, address the following:"

Provide a list of reporting requirementsfor non-radioactivewaste streams to the" Environmental ProtectionAgency (EPA) applicablestate agencies.

At the hypothetical third reactor, reporting of nonradioactive hazardous waste streams will be required annually to the appropriate state agency. The hazardous wastes that require reporting include the hazardous waste listing and descriptions in 40 CFR 261, "Identification and Listing of Hazardous Waste." Other non-hazardous waste streams are unlikely to have reporting requirements.

'CON N- Provide a copy of or discuss the procedure that workers would use for identifying 9"  !

I 1G.2 industrial hazardsprior to performance ofiobs.

The hypothetical third reactor located within a university environment will have a Safety Policies and Procedures Manual (or equivalent) that will provide guidelines and information for employees about programs and services provided by Environmental Health & Safety (EH&S) (or equivalent). The policies and procedures included in this manual will reflect requirements, standards, and statutory and regulatory mandates established at the Federal, State, and local level for occupational and environmental safety and health. Program areas covered and services provided by EH&S will include the following:

• Audits and inspections: Responsible for facility audits, including all campus and off-campus laboratories, classrooms, facility operations, research and experiment stations, and extension centers.

• Biosafety: Responsible for biosafety implementation, control of select agents, compliance with Federal and State regulations, assistance with granting agency compliance and animal welfare, and research and teaching support for the campus and off-campus facilities.

• Chemical safety: Responsible for chemical safety, use, and management, and compliance with Federal, State, and local regulations for the campus and off-campus facilities.

• Construction and plan review: Responsible for construction safety, design criteria development, and plan review for EH&S design requirements related to capital and remodel projects for the campus and off-campus facilities.

° Emergency response and on-call service: Responsible for emergency and non-emergency response to hazardous substance spills and customer concerns for unsafe conditions for the campus, and providing assistance to the campus during other natural emergencies.

0 Environmental protection: Responsible for air, water, and soil resource protection; monitoring; and permitting for the campus and off-campus facilities.

• Fire and life safety: Responsible for fire and life safety prevention and inspections for campus facilities.

14 of 58

N .205=A-0Rev. 0

-N .N .*

Nii

• Hazardous waste and shipping: Responsible for hazardous waste management and shipping of dangerous goods and samples for the campus and off-campus facilities.

• Industrial hygiene: Responsible for industrial hygiene monitoring and employee protection for the campus and off-campus facilities.

• Lead and asbestos: Responsible for identification and management of lead and asbestos-containing materials for the campus and off-campus facilities.

• Occupational safety: Responsible for occupational safety evaluations, consultations, and OSHA compliance for the campus and off-campus facilities.

• Public health: Responsible for implementation, monitoring, and permitting of water systems and sewage disposal systems; pesticide safety; and vectors, housing units, and other areas regulated by health departments for the campus and off-campus facilities.

• Radiation safety: Responsible for the regulation of ionizing and non-ionizing sources of radiation, compliance with the university's broad scope license and Federal and State regulations, and laser safety for research and teaching operations for the campus and off-campus facilities.

• Training outreach: Responsible for creating and delivering training outreach materials to faculty and staff, including training record tracking and training certificate issuance for the campus and off-campus facilities.

CONN- Provide a copy of or discuss the anticifpatedemergency response plan. *V" Possessing and maintaining an emergency response plan is a requirement of any university research reactor facility license. The hypothetical third reactor emergency plan will follow the guidance found in NUREG- 1537, Guidelinesfor Preparingand Reviewing Applicationsfor the Licensing of Non-Power Reactors, and ANSI/ANS 15.16, Emergency Planningfor Research Reactors, as endorsed in Regulatory Guide 2.6, Emergency Planningfor Research and Test Reactors.

iCONN- Provide a copy of or discuss the anticipatedrecycling and reuse plan. .............. V'.......

! 1G.4 ------------------- - -- - -

The hypothetical third reactor will follow the policies and procedures of the university organization assigned the responsibility. The hypothetical university recycling programs will provide information on the types of materials acceptable for recycling (e.g., paper, plastics, metals, glass, batteries, compost, electronic media, ink/toner cartridges, packing peanuts, wood, Styrofoam, comingling limits, etc.), provide containers specific to the materials of interest, and provide pick-up and delivery services scheduling.

TiCON N- Distance travelled of targets to andfrom the reactor. /"

1H The distance travelled of targets to and from the reactor will be bounded by the discussion of the hypothetical third reactor described in Section 19.4.10.1.2 of the Construction Permit Application.

15 of 58

RhlWfSMIftA NWM-215-AI00Rev. 0 CON N- Identify if target handling and irradiationwill result in changes in the types or ii.g V" i1 inzcreasesi'z the radsologi'a/eij/uent re/eases andwaste streamsat/lie reacto;:

Provide sources, types, and approximate quantities of radiologicaleffluents or waste and discuss radiologicalwaste management impacts of target handling and irradiation.Discuss any expected radiologicalimpacts to the workers at those facilitiesdue to those expected changes. Discuss any expectedradfo/ogic'a/impacts from....

t**ran]sporttion._a deto the shipment to..andfrpmtereact!or:..................

The amount of radioactive solid waste that would be generated from the hypothetical third reactor as a result of handling and irradiating LEU targets is not anticipated to increase significantly, as the targets will be minimally handled with little or no potential for contamination. The majority of the waste generated would be solid dry wastes (e.g., paper, gloves, and absorbent materials) from handling the targets on receipt at the reactor. After irradiation, the targets will be moved from the reactor core and into the intermediate transfer cask underwater in the primary tank. Estimates of the added amount of dry-solid-compactable radioactive wastes at the hypothetical third reactor is 0.11 to 0.17 cubic meters (in 3 ) (4 to 6 cubic feet [ft3]) annually. No liquid radioactive waste is anticipated to be generated from these activities.

With respect to gaseous emissions, no gaseous emissions are expected from the LEU targets themselves but gaseous releases from the operation of the hypothetical third reactor may change depending on how the facility is operated. For the hypothetical third reactor, the average amount of gaseous emissions will increase. The only isotope normally measured and emitted from a research reactor is argon-4 1 (4 1Ar).

The hypothetical third reactor will have a limit on the annual average effluent concentration in their technical specifications to ensure that the concentration of 41Ar in the unrestricted areas will be below the applicable effluent concentration value in 10 CFR 20, "Standards for Protection Against Radiation,"

Appendix B, Table 2, assuming continuous discharge. This technical specification will likely be based on the guidance provided in Regulatory Guide 4.20, Constraint on Releases of Airborne Radioactive Materials to the Environmentfor Licensees Other Than Power Reactors. Conservatively assuming that the hypothetical third reactor increases its operational tempo from 10 full power hours a week to 24/7/365 operations, the total activity released could increase by a factor of 16.8 (168/10 --16.8 weekly).

Although the total amount of 41Ar may increase from the increased operating tempo, the concentration will remain the same.

The handling of both unirradiated and irradiated LEU targets is not anticipated to significantly increase the occupational doses at the hypothetical third reactor. Based on information obtained from TRIGA-fueled reactors that have gone through highly enriched uranium (HEU)-to-LEU fuel conversion in the past eight years, the receipt of fresh LEU TRIGA fuel may be indicative of what should be expected for unirradiated LEU targets. The fuel received for conversions was 20 percent enriched and 30 weight percent (wt%) standard TRIGA fuel containing a nominal uranium mass of 820 grams (g) within a stainless-steel clad cylinder with outer dimensions similar to the proposed targets. Typical dose equivalent rate readings on contact and at 0.3 m (1 ft) were 0.1 to 0.3 and 0 millirem (mrem)/hr, respectively. No measurable dose equivalent rate at 0.3 m (1 ft) from a fully loaded storage container was observed. Due to this, no appreciable increase in the occupational dose equivalent is expected from the handling of the proposed unirradiated LEU targets at the hypothetical third reactor. Additionally, no appreciable increase in dose to the general public is expected from handling the unirradiated LEU targets due primarily to the very low-dose equivalent rates observed with the unirradiated LEU TRIGA fuel

=handli~ng and a lack of proximity of the general public to the targets. __

16 of 58

.A* .,:It"IUWMI~

N VEr, VExz. I*soo NWMI-201 5-RAI-001Rv0

. .. .. g.li The occupational doses from handling irradiated targets are not anticipated to significantly increase at the hypothetical third reactor. All research reactors have procedures for handling fuel elements and have established radiation protection and ALARA (as low as reasonably achievable) programs. A shielded transfer cask will be used to remove irradiated targets from the reactor and load them into the shipping cask. While some increase will be observed, due to the very nature of handling radioactive material, the dose increase will not be significant due to the established programs and handling experience.

The quantity, type, and packaging associated with transport of radioactive materials are discussed in Section 19.2.8.2. The radiological impacts from shipment to and from the hypothetical third reactor are discussed in Section 19.4.10.

CON N-21/n support ofaayigthe Site-specific environmental impacts associatedwith the  :

connected actions, identify if target handlingand irradiationwill result in changes -

in the types or increases in the non-radiologicaleffluent releases and waste

,streams at the two identified research'reactors (MURR and OSTR]). Provide sources, 'types, and approximate quantities of non-radiologicaleffluents or waste iand discuss non-.radiologicalwaste management impacts of target handling and

,irradiationat MURR and OSTR.

No anticipated changes in the sources, types, and quantities of nonradiological effluent releases and waste streams are expected from the handling of the unirradiated or irradiated LEU targets at MURR or OSTR.

'CON N-3 In support of analyzing the site-specifjic environmental impacts associatedwith the i. V connected action of irradiationservices, discuss the storage and treatment of non-S radioactivematerialfrom target handling and irradiationat MURR and OSTR.-

No additional nonradioactive material is expected to be generated other than the manufacture of an unirradiated target storage rack. Composed entirely of stainless steel, these racks are anticipated to be square, lockable containers with rack locations (i.e., guide tubes) for the unirradiated LEU targets.

Approval for the geometry, design, and construction will be promulgated through license amendments for each of the reactor facilities.

CON N- Discuss human health impacts due to the connected actions of target handling and V"*

4.A irradiationat MURR and OSTR. Specifically, for MU]?] and OSTR], address the

!following." no-aiaciewst temst P

,Providea list of reporting requirementsfor nnrdociewsesrast P

____ applicable state agencies. .... _

At the OSTR, OSU is required to annually report the amount by volume of all hazardous wastes generated and disposed of to the Oregon Department of Environmental Quality. The hazardous wastes that require reporting include the hazardous waste listing and descriptions in 40 CER 261. Additionally, Oregon Administrative Rule (OAR) 340-101-0033, "Additional Hazardous Wastes," lists wastes that are state of Oregon-only hazardous waste and must be reported. These wastes include pesticides residues and mixtures of wastes containing constituents of Federal P (3 percent) and U (10 percent) listed wastes.

At MURR, the University of Missouri (MU) is required to complete a quarterly Generator's Hazardous Waste Summary Report. This report lists the quantity, type, and status of all 10 CFR 261 listed and described hazardous wastes shipped offsite during the reporting period.

17 of 58

flh:fNWMI UU t SOeEV

.t"Nsmz4EU NWM,-201 5-RAI-001ev0 N .***. . iii C ON N- Provide a copytoof the procedure that woirkers would usefor'identifting industrial ,//

V

!4.B hazards prior performance ofjobs.

• i '

At the OSTR, identifying industrial hazards prior to performance of jobs falls under the requirements of occupational health and safety policies and procedures administered by OSU Enterprise Risk Services.

The OSU Safety Policies and Procedures Manual is provided at http://fa.oregonstate.edu/saf-manual.

Industrial and laboratory safety instructions are numerous and are provided online at http ://oregonstate.edu/ehs/safety-instructions.

At MURR, identifying industrial hazards prior to performance of jobs falls under the requirements of occupational health and safety policies and procedures administered by the MU Department of Health and Safety. The manual governing the policies and procedures is provided in the MU Business Policy and ProcedureManual available at http ://bppm.missouri.edu/.

SCON N- Provide a copy of the emergency responseplanfor each reactor.  :" <  !,

A copy of the OSTR emergency response plan is provided in Appendix F. A copy of the MURR emergency response plan is provided in Appendix G.

CON N- Provide a copy of the recycling and reuse planfor eah/eato.

• At OSTR, recycling and reuse is governed by university policies and procedures administered by Campus Recycling, reporting to the Finance and Administration-Business Affairs Office. This service is managed online at www.recycle.oregonstate.edu.

At MURR, recycling and reuse are governed by university policies and procedures administered by the Sustainability Office, and are managed online at http://sustainahility'missouri~edu/topics/recycling'html" Information related to a third reactor cannot be supplied at this time, as the reactor has not yet been selected. The answer to this question for the third reactor is anticipated to be similar to that for OSTR.

ICONN-5 :In support of analyzing of thel environmental impacts associated ..................

with the "...... ....... /

connected actions, identfif if target handlingand irradiationwill result in changes: i Sin the types or increases in the radiologicaleffluent releases and waste streams at.

the two identifed reactors (MURR and OSTR). Provide sources, types, and i

.*approximate quantities of radiologicaleffluents or waste and discuss radiological "*

'waste management impacts of targethandling and irradiation*at the two identified" reactors. Discuss any expected radiologicalimpacts to the workers at those facilities due to those expected changes. Discuss any expected radiological Iimpacts from transportationdue to the shipment to andfrom the two .identified reactors. s .

As stated in Sections 19.4.13.3.1, 19.4.13.3.2, and 19.4.13.3.3, the solid waste stream will minimally increase, and the liquid waste streams will likely not be affected as a result of handling both the unirradiated and irradiated LEU targets.

With respect to gaseous emissions, no gaseous emissions are expected from the targets, but gaseous releases from the operation of the reactor may change depending on how the facility is operated. At MURR, there will be no expected increase in gaseous emissions because the operating tempo of the reactor will not change. At OSTR, the average amount of gaseous emissions will increase.

18 of 58

WMI W-0 -A-0

-.- .U Si g.S i The only isotope ever measured and emitted at OSTR is 4 1Ar. As reported in annual reports required by the facility technical specifications, the typical annual concentrations at the point of release from OSTR is approximately 5.2E-3 becquerel (Bq)/milliliter (mL) (1 .4E-7 microcurie [iiCi]/mL), with a corresponding total annual radioactivity of approximately 7.4E1 1 Bq (20 Ci). Conservatively, assuming that the O STR runs 24/7/365, the total activity released could increase by a factor of 4.8 (168/3 5 =

4.8 weekly). However, although the total amount of 41Ar may increase from the increased operating tempo, the concentration will remain the same.

As stated in Sections 19.4.13.1.1.2 and 19.4.13.1.2.3, the handling of both unirradiated and irradiated targets should not significantly increase the occupational doses. Those sections describe historical fuel movement experience, how that is similar to moving targets, and the occupational doses incurred.

The quantity, type, and packaging associated with transport of radioactive materials are discussed in Section 19.2.8.2. The radiological impacts from transportation due to the shipment to and from the reactors are discussed in Section 19.4.10.

1 CONN, Section 19.4.13 of the ER identif/iesfacility modifcations at the two ident~iied ... /" ....

6A :reactors (MUJRR and OSTR) needed to support the handling and irradiationof targets. Provide the following information regardingfacility modifications and

' handlingand irradiationof targets:

'A.) Additional workforce needed to support modifications At MURR, all additional workforce needed to support modifications will be temporary. The fabrication of the storage racks and the transfer cask will likely be outs ourced to a qualified mechanical fabrication machine shop. The manufacture of the new reflector elements will be completed by existing MURR staff. Construction of a new airlock will involve an estimated four to six construction workers.

At OSU, all additional workforce needed to support modification will be temporary. The fabrication of the storage racks and the transfer cask will be outsourced to a qualified mechanical fabrication machine shop. The work on the overhead crane will likely be performed by one or two individuals contracted to perform the work.

CON N.. Additional workforce needed to support operation activitiesfor irradiatingtargets /

For MURR, no increase in facility staff is expected, as the handling and irradiation of the LEUJ targets will be consistent with existing expertise and workload.

For OSTR, an increase in staff is expected to provide commercial irradiation services. The operational tempo is anticipated to increase from a nominal 40-hr work week irradiation schedule to 24/7 operations on a weekly basis when commercial LEU target irradiation services are being provided. The anticipated required staff for OSTR will comprise four SROs and three ROs. At least four additional SRO and six additional RO positions are assumed to be required to oversee and manage the increase in operational tempo. The university setting offers flexibility in hiring; thus, additional staff will likely be drawn from the existing university population.

19 of 58

I@IVIV I ,205R-0Rev. 0

. .. .- gglii iCON i6C N- facilities Durationandof activities to complete modifications equipment.. . and to commission the modified- iVi " i The equipment modifications or fabrication of required equipment at an off-site vendor is anticipated to take two months to complete at both MURR and OSTR.

SCON N- Depth of excavation expected to be requiredfor new/modifiedfacilities and utility '¢ i6 connections No ground-disturbing activities are anticipated to occur at either MURR or OSTR as a result of handling and irradiation of targets at either reactor.

No new/modified facilities or utility connections will be required for either MURR or OSTR. Thus, ground-disturbing activities that require excavation are not required.

IONN- Additional water use to complete modifcations and to support operation activities

• 6E for irradiatingtargets (as compared to existing operations) *".

No additional water use to complete modifications and to support operation activities for irradiation targets is anticipated at either reactor.

SCN-Any additionalnoise, traffic, or air emissions from facility modification activities The transport of the fabricated unirradiated LEU storage racks and transfer cask to both MURR and OSTR will result in a single delivery for each when completed. Increase in traffic due to the crane modifications will involve commute to the third reactor facility by one vehicle for a short duration (e.g., less than two weeks). This volume of traffic is considered within the normal traffic patterns expected at MURR and OSTR. Due to minimal traffic and no ground-disturbing activities at the hypothetical reactor, there will be no appreciable increase in either noise or traffic.

VCONN- Would modifications be internal or external to the existing structures? If external

• 6G "modificationsare necessary, would there be any associatedground- disturbing activities? If so, quantfify the acreage and identify the nature of the areas that may be impacted. i All modifications and/or equipment refurbishments or needs would be internal to existing structures at both reactors.

20 of 58

4 -loev.RWIM-o 0

__HiuI SCl-I A JIdentify any theadditional state, county, and regionaldocuments that were reviewed ,/'"

9' (other than cited City of ColumbiaFY2013 CIP PlanningDocument) to Ii* develop Table 19-86. Provide associated URLs for this reference informatio~n and

! specifically identify for which of the listedtprojects each source provides  !

i* supporting information.,

In addition to the City of Columbia FY 2013 CIP Planning Document, the following documents were also reviewed:

• City of Columbia, 2008, 2030 CATSO Long Range TransportationPlan, City of Columbia Department of Planning and Development, http://www.gocolumbiamo.com/community-development/wp-content/uploads/sites/l14/2015/09/2030OTransportationPlanFinal.pdf, Columbia, Missouri, June 20, 2008

• Boone County Planning and Zoning Commission's meeting agendas for 2013, https://www.showmeboone.com/resourcemanagement/PZCommission/Agenda/PZAgenda.asp?YE AR=2013

• RS&H No. 226-1077-000, Columbia RegionalAirport (COU) Columbia, Missouri Draft EnvironmentalAssessment, City of Columbia and U.S. Department of Transportation - Federal Aviation Administration, http ://www.flycou.com/?page_idP=342, Columbia, Missouri, January 2012.

• City of Columbia, 201 2a, City of Columbia FY 2013 CIP PlanningDocument, https ://www.gocolumbiamo.com/Finance/Services/Financial_Reports/index.php, Columbia, Missouri, October 1, 2012.

• CDT, 2013, "MU, Company Partner to Boost Supply of Isotope used in Diagnostic Drug,"

Columbia Daily Tribune, http ://www'columbiatribune'com/news/education/mu-company-partner-to-boost-supply-of-isotope-used-in/article_0c707d88-4909- 11 e3 -9ef7- 10604b9 f6eda.html, Columbia, Missouri, November 9, 2013.

° CW&L, 2013, "New South Substation & Transmission Lines Public Hearing,"

https://www.gocolumbiamo.com/waterandLight/Electric/ProposedElectricTransmission.php, Columbia Water and Light, Columbia, Missouri, July 15, 2013.

Cl-l B Provide the name, .descriiption,location, andstatus of any additionalpast,present " .

or reasonably-foreseeableprojects or actions at or in the vicinity of the proposed RPF that have be~en identifiedsince the applican~t s ER was prepared.

The information provided in the following table identifies the name, description, location, and status of additional projects in the vicinity of the proposed RPF that have been identified since the Environmental Report (ER) was prepared. The Gans Road route 163 to Bearfield road is anticipated to convert some existing farm fields to road surface, which would be considered a minor loss of agricultural lands. The cumulative effect is considered small. All other impacts associated with the new road are anticipated to be within the cumulative impacts already addressed by other projects with the ER, and the resulting cumulative impacts are anticipated to remain the same as documented in the ER.

21 of 58

NWMI-201 5-RAI-001 NWM I Rev. 0 Recently Identified Past, Present, and Reasonably Foreseeable Future Actions Eli. 0.25 Fulton Center Medical TBD TBD !0.40 N 'Certificate

[was not approved of Need CDT, 2015b and CDT, 2015a iunderdetermiined when or if it will be built .... ..... ...... .. . . . . ...

i~raft Heinz plant TBD TBD Greater N :Construction limited 'CDT, 2015c

!expansion than 8 than 5 :to preyiously

.disturbed lands at a Jdistance from the FPR site.

Landmark TBD TBD 6to8 3.7 to 5 N iConstruction limited ~MHFRC, 201. 5 Hospital Sto previously Transitional Care disturbed lands at a Center of distance from the Lolumbia Ii!tKme Gans Road: 1/2015 12/2015 2 to 4 1.3 to 2.5 Y iConstruction include ;CATSO, 2015a and Route163 to iel itre CTO 05 Bearfield Road nelyndisturbd a Coet TS,20 I cumulative effects from air emissions

!and effect to land

__________ _________ use. ___________

. .. .. _ liii, I C' escribe any site inetgtosthat examined vegetation (grasses, shrubs, and ,

V trees) and wildlife (mammals, reptiles and amphibians, and birds) on or near the site, including transient wildlife that may only rise the site as a temporary resting or foragingground, or wildlife that only uses the site seasonally. In addition, describe any site investigations thatfocused on invasive species. ........................  :*.............

A site investigation to examine vegetation, wildlife, and invasive species on the site was conducted by a combination of photographic interpretation, evaluation of the literature, and the ecological site description of grass prairie of the area around Columbia, Missouri. The site is an area that has experienced continuous land disturbance associated with agriculture practices at least since 1934 (Terracon 2011la, provided in Appendix H). In addition, the site is devoid of natural landscapes such as forest, prairies, and other natural plant communities. A site reconnaissance was conducted by NWMI in June 2014 to confirm the site investigation findings._____

22 of 58

'WM,-.0lU-VY,-00Rev. 0

.I'l ..

ECO-2 Section 19.3 .5.7.1 of the ER? states that "representativeplant species include little " i bluestem (Schizachyrium scoparium,), sideoats grama (Bouteloua curtipendula),

winter bentgrass (Agrostis hyemalis), andAtlantic camas (Camassiascilloides)

(Nigh and Schroeder, 2002, Faber-Lagendoen,2001). "Provide the technical basisfor why NWMI assumes these plants occur onsite. Describe the percent

..... cover of__the mostcommon veget~at~iv~especieson site.... ..... . .. . .. .. .. .. .

The representative plant species are based on photographic interpretation and the ecological site description of grass prairie in the area around and near Columbia, Missouri. A site investigation was conducted on September 30 and October 1, 2015. The results of this survey are provided in the attached report: NWMI-2015-RPT-002, RadioisotopeProductionFacility Vegetation Assessment (Appendix I).

ECO-3 Section 19.3.5.7.1 of the ER states that "potentialnative plant species that may V" occur within the proposed site include those associatedwith tall grass hardpan prairie (Nigh and Schroeder, 2002). "Nigh and Schroeder (2002) describe numerous native species. Describe which native species occur on site andprovide a summary of how NMWJ determinedwhich native species occur on site, such as

. ...... onsite ecological-surveys_. .. . .. . . . . . .. . .... ...... ... .. . ... . .. . .... . . ....

A site investigation was conducted on September 30 and October 1, 2015. The results of this survey are provided in the attached report: NWMI-2015-RPT-002, Radioisotope ProductionFacility Vegetation Assessment (Appendix I).

ECO-4 Figure 19-39 of the ER shows the locationsfor wetlands near the proposedRPF "

site. The large size of the symbol for the proposedRPFmakes it difficult to confirm the location of any wetland onsite or near the site. Confirm whether any wetlands are located on the proposedsite and describe the distancefrom the proposed site to the nearest wetland. Describe wetland and wildlife species that are likely to occur in nearby wetlands.

Based on the United States Fish and Wildlife Service (USFWS) National Wetlands Inventory GIS data, there are no wetlands located onsite or near the site. The closet wetland to the site is a 4.9 hectare (ha)

(12.15)-acre pond with an earthen dam, which is 0.24 kin) (0.15 mi) to the northwest of the site.

A qualitative survey of the properties immediately surrounding the site was conducted on September 30 and October 1, 2015. The results of this survey are provided in NWMI-2015-RPT-001 (Appendix J).

The survey identified Bullfrog (Rana catesbeiana), Green Frog (Rana clamitans melanota), Painted Turtle (Chrysemys picta bellii), and Northern Pintail (Anas acuta) within the northwestern pond. The property south of the RPF site to Gans Creek was surveyed and found to have American Elm (Ulmus americana),

Eastern Red Cedar (Juniperus virginiana), Post Oak (Quercus stellate), Bitternut Hickory (Carya cordiformis), and Shagbark Hickory (Carya ovate). At the time of the survey, Gans Creek was not flowing; however, Creek Chub (Semotilus atromaculatus) were observed in small pools within the creek channel. Blanchard's Cricket Frog (Acris crepitans blanchardi) and Eastern Gray Squirrel (Sciurns carolinensis) were also observed in this area.

23 of 58

• NWM.-Io,*,=.=*~ NWM [-201 5-RA,-001 Rev. 0

.I'l ..

The man-made pond to the northwest of the property was also observed and Green Frog (Rana clamitans melanota), Canada Goose (Branta Canadensis), Northern Pintail (Anias acuta), and Trumpeter Swan (Cygnus buceinator). Signs posted around the pond note that is was stocked with largemouth bass, catfish, and crappie by the Missouri Department of Conservation for recreational purposes. The bird

,species also indicate that the surrounding water bodies may be used b.y migra~tory birds__..........,....,

ECO -5 Describe the aquatic species, such as fish and invertebrates that are likely to V" i occur within, the stormwater management ponds, Gans Creek, and nearby I! streams.

As described in Section 19.3.5.6, "Aquatic Communities and Potentially Affected Water Bodies," the aquatic species that are likely to occur within the stormwater management ponds, Gans Creek, and nearby stream include mayflies, stoneflies, caddisflies, dragonflies, beetles, small crustaceans, snails, shiners, suckers, redhorse, sunfish, bass, darters, and stonerollers. No Federally listed threatened or endangered fish species are known to exist in Gans Creek. No specific data is available on the species within the stormwater management ponds; however, the species and habitats are considered to be similar to those found in Gans Creek.

6 EC........ es ri e the.....most.

b..

............... hemshrubsnve etti .....e species.........(grassesO common.........vegetative......

... pand ( rastrees), a d res) -.... /

S wildlife species (mammals, reptiles and amphibians, and birds), and aquatic  !

......specie~s (fish andrmac~roinv~ert~ebr~ates) at e~ach altern~ativesit~e_........................

Based on photographs of the alternative sites, the common vegetation includes the types used for landscaping, including ornamental grasses, shrubs, and trees. The wildlife species using these sites would be limited to species that occur in urban/industrial settings, including rodents, some song birds, and insects. Aquatic species are not anticipated to use these sites due to a lack of water.

24 of 58

• "NWMI

• ..?:* oarra c Es Pto NW MI-201 5-RA[-0oo1Re, R v

- - . .. gIi GEO-1 Provide clarification of the informationpresented in Sections 19.3.3, including I 19.3.3.8 and 19.3.4.3, of the ER with respect to the greaterDiscovery Ridge site development. Specifically, provide a description of the scope and timing of proposed site-specific geo technical and hydrological studies to be performed of the RFP site (Lot 15) and of any adjoiningareas that may be usedfor laydown or site t access. Include studies such as proposed baseline preoperationalgroundwaterand surface water quality monitoring(including samplingparameters) as well as studies to addresssuch potentialissues as soils with high-shrink swell potential, karstfeatures, and confirmation of the depth to perched groundwater or water-L- -table conditions.

NWMI anticipates conducting site-specific geotechnical and hydrological studies starting in January 2016.

Bore holes are anticipated to be drilled a maximum depth of approximately 15.2 m (50 ft) below surface level, or 6.1 m (20 ft) into sound bedrock. The number of bore holes per 9.2 square meters (in 2 )

(100 square feet [ft2]) will be dependent on the foundation type anticipated in a specific area. For each core, the soil/rock profile will be documented and classified, and engineering and geotechnical properties determined. The liquefaction potential of soils will also be determined. Groundwater encountered will be documented, and several samples of the groundwater encountered will be collected to determine the baseline groundwater quality. There is no intention of verifying the depth to the Mississippian aquifer, which lies approximately 548 in (1,800 fi) below the surface. Baseline surface water samples will be collected from Gans Creek and the stormwater management ponds prior to the initiation of operations.

fGEO-i B As part of the site-specific characterizationstudies referenced in (A) above, describe the number, spacing, diameter andproposed depth, and installation method of any groundwater monitoringwells to be installed, such as to verify~and monitor depth to groundwater. Specify whether the wells, if any, would be retained f'or operationalphase groundwater monitoringand/or leak detection.

As noted in the ER, the NWMI RPF is designed to have zero liquid discharge from the radiologically controlled area. The groundwater aquifer beneath the proposed NWMI site is the Mississippian Aquifer (also referred to as the Kimmswick-Potosi Aquifer). There are no defined liquid effluent release pathways, and the groundwater is not expected to be contaminated due to operation of the RPF.

Therefore, groundwater sampling was not included in the radiological environmental monitoring plan.

Shallow groundwater has been detected in two previously drilled boreholes near the NWMI RPF site. As noted in the response to GEO-lA, if encountered during boring, water will be sampled and noted during the site-specific hydrological studies. However, the NWMI RPF is designed to have zero liquid discharge from the radiologically controlled area and as such, these boreholes will not be retained for operational phase groundwater monitoring.

25 of 58

SNWM I NWMI-201 5-RAI-001e.0 jGEO-1 C Provide the following references as cited in the ERrfor docketing."

I'll v

1.) Terracon, 2011a, Phase I EnvironmentalSite Assessment Discovery Ridge Lots 2, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, and 1 8, Terracon Consultants, Inc., preparedfor University of Missouri and Trabue, Hansen & Hinshaw, Inc., Terracon Project No. 0911770], March 23, 2011 (cited in ER Section 19.3.4.3.1).

S 2.) Terracon, 2011b, PreliminaryGeotechnical EngineeringReport Discovery i 'Ridge-Certi~fied Site ProgramLots 2, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, and 18, Terracon Consultants, Inc., preparedfor University of Missouri and Trabue, Hansen & Hinshaw, Inc., Terracon ProjectNo. 09105094.1,

.. ....... ..Febru:ary1,_2 1 cte n E eci n 1 . .3.8.1).. ..... . . . . ..... . . ........ .. . .

Reference documents are attached in Appendix H and K, respectively.

VGEO-2 Section 19.2.3 of the ER indicates that the depth of the processinghot cell below

! grade, without footers, is 4.6 m (15 ft). Section 19.4.3.1 of the ER states that the

'. maximum depth of excavation is anticipatedto be 15.5 ft. below groundsurface,

,! presumablyfor the hot-cells, waste storage areas, and transfer tunnel as S referenced in the ER. Confirm that this excavation depth is still bounded by the il facility design and include relevant information on the thickness and material of S construction of the outer walls and basementfloor of the below groundportions of S the RPF in support ofyour response._J Section 19.2.3 describes the baseline depth below finished grade of the tank skid hot cell and the high-integrity container (HIC) vault. The top of finished concrete for these two deepest areas within the RPF is 4.6 m (15 ft). This depth is in reference to the finished grade, not to the existing site surface.

The baseline composition of the floors for these two rooms is a reinforced concrete mat slab, nominally 45 to 60 cm (18 to 24 in) thick. The room walls will be reinforced concrete, ranging in thickness from 61 to 122 cm (24 to 48 in), based on the structural loading and shielding requirements for each section.

The nominal depth of excavation beyond the slab will vary based on the results of the geotechnical survey and the requirements of the structural design. The over-excavation typically ranges from 15 to 30 millimeters (mam) (6 to 12 inches [in.]) to 1.5 to 1.8 m (5 to 6 fi), based on these factors. The over-excavation will be minimized. If the existing site surface is close to the site finished grade in the area of these two rooms, the maximum excavation depth could range from 5.2 to 7.0 m (17 to 23 fi).

Section 19.4.3.1, referenced excavation calculation uses the nominal finished site elevation to determine excavation volumes. The calculation then adds 37 percent to address uncertainties then rounds that total up another 3 percent to reach the 6,881 m3 (9,000 cubic yards [yd 3]) total used in Section 19.4.3.1. The excavation depth and total volume remain reasonable bounding conditions.

26 of 58

• ,~.*

IUNW IIB EU tJ~*ElTM EuCA.

[OE NwM,-2o 5-RAI-Oe.o1

-...0g*g g**

HC-1 Jdentify

=Plan, and/or any the whe~ther applicant procedures haswould thai, prepared befollowed in Resource a Cultural Management the event that human r *." V .

remains or other items of historic or cultural value are inadvertently discovered

• during construction, operation, anddecommissioning of thefacdiiy _______-,

NWMI has not prepared a Cultural Resource Management Plan. A Cultural Resource Management Plan will be prepared prior to initiating construction of the facility and will be submitted to the Missouri State Historic Preservation Office.

SHC-2 Provide information on whether the proposed RPFwould be visiblefrom any I V".

1 surrqundingNational RegisterofHistoric Places (NHRP)-listed or-eligiblehitrcpoete."'

Baedo tevisual imataayi nScin19.4.1.2.1, the RPF stack could potentially be visible at the David Gordon House and Collins Log Cabin, and the Maplewood House NHRP properties.

HC-3 Section 19.3.6.8 of the ER indicates that the applicant initiatedconsultation with V *....

• the Missouri SHPO and six~Federally-recognizedtribes in 2013, and indicates in Section 19.4.6 that,:the Missouri SHPO has reviewed and concurredwith the  :.

findings of the Phase I archaeologicalsurvey. Provide copies of any letters or

communications, to andfrom the Missouri SHPO, Federally-recognizedIndian t rtribes that may hiave ancestralor hitrclties to the froject area, or local

• ocitie tht hveoccurred subsequentto those discussed in the ER...

hisorial There have been no additional communications to or from the Missouri State Historic Preservation Office (SHPO), Federally recognized Indian tribes, or historical societies subsequent to those discussed in the ER.

27 of 58

• .*

  NWIVII RED" A MEDwz CALElUSOPES NWM,-2o1 5-RAI-Ole.o1 R v

- . .* I'l tH-N- 1 i,he 1I(5 augmenting Provisions, NUREG-]537, Permits, and Part]1,Section Requires Consultations, .19.1.2that "states "Regulatory applicablefederal, .

• V state, local, and other regulatory requirementsshould be summarized. Provide a, list of reporting requirementsfor non-radioactivewaste streams to EPA and . .

L MDNR as discussedin Section 19.3.8.3.of the ER.

Table 19-4 in the ER provides a listing of the applicable Federal, State, local, and other regulatory requirements. The table notes that NWMI is required to notify the U.S. Environmental Protection Agency (EPA) of any Resource Conservation and Recovery Act (RCRA) (42 U.S.C. § 6901 et seq.),

Subtitle C, activity and any spill prevention, control, and countermeasures for storage of oil, if required.

As a small quantity hazardous waste generator, NW/MI will be required to prepare a Notification of Hazardous Waste Activity form to obtain both a Missouri generator identification number and a Federal (EPA) generator identification number. NWMI would be required to submit a Generator's Hazardous Waste Summary Report Form to MDNR annually.

There are no specific reporting requirements associated with the use of weed killer and fertilizer on or near the site noted in Section 19.3.8.3. The statement "Nonradioactive liquid, gaseous, and solid waste effluents from facilities within the Discovery Ridge development are required to report hazardous effluents to the MDNR and the EPA," is not applicable to the section and has been removed.

' HH-NR- The ISG augmenting NUREG-t53 7, Part], Section 19.4.10, "Human Health" V' 2 states that the ER shouldprovide an assessment of the physical occupational hazards. Provide a copy of the plant procedure that workers would use for .;.

identifying industrialhazardspr*.ior to performanceeofjobs .

The plant procedures for identifying industrial hazards prior to performance of jobs have not yet been developed._The procedures will be developed and included in the Operating Permit Application.

T HH*N R-- Th~eISG augmentingNURE*G-]537, Part]1,Section 19.4.9, "Waste Vf ....

!3 Management, "states that the ER shouldprovide a descriptionof the proposed i i " waste management systems designed to collect, store, andprocess waste. Provide " =

i a cop~yof the recycling and reuseplan discussed in Sectionl]9.4.8.].2*4 of the ER. " .

The recycling and reuse plan has not yet been developed. This plan will be developed and included in the Operating Permit Application.______

28 of 58

SNWM I NWMI-2O1 5-RAI-COOev

. .e *. ulii HH-R-1 The ISG augmenting NUREG-]537, Part]1,Section 1J9.3.8, "Human Health,"  :' /.,

states that the ER should provide effluent release points and expected radioactive effluent releases and exposuresfrom construction, operational, and ° decommissioning activities. Baseline radiation levels for the 'generalareaare. .

diCauaas lnsnt1 icei in 19.4.8.

dssaedoof ss the ER, frp rsfo thatctihers e is R n !

da l w y P a iscusseds t n ti ds coaind of the s ti19.3.88.

ERa ofr p ts r m re ac to l ers ikeMUR an possibility th'at the RPF will'releasegaseous and liquidradionuclides into the environment, currentradiationlevels are important to quantify. Clarify ifany  !

baseline monitoringwill be performed at .the RPF, and how effluent releaseswill be monitored/mitigatedduring construction, operations, and decommissioning.

A radiological survey will be conducted before startup of the RPF to provide a baseline. The operational radiological monitoring program discussed in Section 19.4.8.4 will provide the baseline for decommissioning.

There are no plans to conduct a radiological baseline survey for construction activities.

Additional information on the NWMI's Radiological Monitoring Program is provided in the Part 2 Construction Permit Application, Chapter 11, "Radiation Protection and Waste Management."

HH -R-2 The JSG augmenting NUREG-153 7, Part]l,Section 19.3.8, "Human Health,"' V" States that the ER shouldprovide a description of the facility 's radiological i programs and systems. Provide description of the program (s)for radiological i w....

orker protection and m onitoring necessary to comply with 10 CFR Part 20.

The radiological worker protection and monitoring program that complies with 10 CFR 20 is described in NWMI's Part 2 Construction Permit Application, Chapter 11.0, "Radiation Protection and Waste Management."

29 of 58

• ..: l.U. V pV Rv

-. *ii US0DH0 SLAN-I: .Table 19-15 of the ER describes U.S. Geological Survey (USGS) land use " "

) categoriesfor the 8 km (5-mi) region of influence surroundingthe proposed RPF.

S-Describethe current'landuses on si~te as defined by USGS. . .

The current land use of NWMI's RPF site as defined by U.S. Geological Survey (USGS) is pasture/hay.

i.LAN -2 Section 19.3..1 .2.3 of the ER states that the site has an L sensitivity rating, as an  : .¢ j area with low scenic values resultingfrom a low sensitivity to' changes in visual Squality by the type of users in the area, a low amount of use by viewers, low public' S interest in changes to the visual,quality of the site, and a lack of special natural

........ andwilderness areas. Provide the technicaljusti~ficationfor this rating_..........._........<L_*i...

The scenic quality of the proposed site was rated using the Bureau of Land Management (BLM) Visual Resource Management System (H-8410-l, Visual Resource Inventory Manual). The sensitivity level, a measurement of the public concern for scenic quality, is rated on a high (H), moderate (M), or low (L) scale. The sensitivity level was analyzed using six different indicators of public concern: types of users, amount of use, public interest, adjacent land uses, special areas, and the results of a potential viewability analysis from seven vantage points. Even though the facility is potentially viewable to different publics from all seven points, the analysis does not consider screening effects. At both near and far distances, a potentially viewable facility could easily be Screened from view by intervening vegetation, structures, and topographic features. The analysis also does not consider time. A high number of viewers travel on the highway and roads near the proposed facility. The public may view the facility, but only briefly while traveling to their destinations.

Although the facility could be potentially viewed by a high number of people, and may at inception be perceived as having a high effect on visual sensitivity, the area overall has a low sensitivity to changes in visual quality. This is because of the type of users in the area (e.g., workers, residents, travelers), a low amount of use by viewers (i.e., not a public destination), low public interest in changes to the visual quality of the site (another facility in an industrial park would not be unexpected), and a lack of special natural and wilderness areas. Nearby residents would most notice the RPF on the landscape, although the facility would not be considered out of character with its location and context within the research park.

Over time, the facility would be assimilated as a normal component of the landscape. Taking these factors into account, the site was determined to have a low (L) sensitivity rating.

LA- eto 14...oteERstates that "osrcinsaigatvte ol lo"*

occur along Discovery Drive bordering the lot and the adjacentDiscovery Ridge

.. Lot 1 4. Staging activities would be temporary and would cease after construction of the facility. *'Describe the exact locations and approximate acreage of aniy offsite stages areas that would be used during construction.

MU, the owner of Discover Ridge, has given initial approval for the NWMI constructor to access the NV/MI site from the adjacent lot to the east (Lot 14). This plot is adjacent to both the NWMI site and Discovery Drive. The space needed for staging activities in the adjacent lot is estimated to be 23 m (75 fi) along Discovery Drive and 46 m (150 ft) along the common lot boundary between the two lots (approximately 0.1 ha [0.26 acre]). After construction activities are complete, the affected area in the adjacent lot will be revegetated with similar species as currently found throughout Discovery Ridge.

Figure_19-14 will be updated to indicate the Lot 14 laydown area.

30 of 58

@"NWM

• " I NWM,-201 5-RA,-001Re Rev..

- . N ~U gIi LAN-4 Section 19. 4.1.1. of the ER states that "iafterthe facility is:buikt, landscaping would mitigate disturbancescaused during construction on the lot, both exterior

• of the perimeterfenceandfrom the perimeterfence to th~perimeterof the building. "Provide a description of landscapinigactivities NWM[ intends to complete. Forexample, would open areas be covered in grasses, shrubs, or . .

ornamentalflowers. Would any native species be usedfor landscaping? If known, provide the approximate percentage ofspace that would be landscaped "  !:

___ vs. developed.

Consistent with Discovery Ridge master plan and covenants, the site will have earthwork berms providing visual blockage from the adjacent streets. In addition, open areas and berms will be covered with ground materials such as grasses, shrubs, and/or ornamental flowers including native species.

Figure 19-7 currently shows that grasses, shrubs, and trees show a general concept for landscaping.

Approximately 68 percent of the site will be developed, providing 32 percent of the site for landscaping._To date,the specific ground coverage materials have not yet selected.

LAN -5 ,Describe the current zoning classi~fication.at each alternativesite. ."

Discovery Ridge: Discovery Ridge Discovery Ridge was developed under Section 172.273 of the Missouri Revised Statutes, which provided that "the Curators of the University of Missouri may establish research, development, and office park projects in order to promote cooperative relationships and to provide for shared resources between private individuals, companies and corporations, and the University of Missouri, for the advancement of the University in carrying out its educational mission and such projects are declared to be in furtherance of the purposes of the University."

The Discovery Ridge Master Plan and Protective Covenants (MU, 2009) is the applicable land use guidance for the research park. Discovery Ridge is zoned commercial in the A-i district (City of Columbia, 2012b), under the Section 29-18 provision, Board of Adjustment (City of Columbia, 2012c).

The Columbia Code (Section 29-18) has height restriction for A-i of 10.7 m (35 ft). Missouri Revised Statute, Section 172.273, exempts university research parks, including Discovery Ridge, from local land development regulations. This allows MU to develop Discovery Ridge to its own master plan and to include non-agriculture-related structures with sizes in excess of the A-i zoning requirements, provided MU gives Columbia courtesy review of the plan and design drawings and addresses the city's comments.

MURR: The current zoning at MURR (e.g., area encompassed by the reactor) is zoned as "M-1, General Industrial" by the City of Columbia. Conditional uses are allowed under Section 29-20(c), manufacture, compounding, or processing of hazardous materials.

OSTR: The current zoning at the OSTR/OSU is zoned as "Public Institutional" on the City of Corvallis Comprehensive Plan (City of Corvallis, 2000) and "Other Designations - Oregon State University" on the City of Corvallis Official Zoning Map. The OSU Master Campus Plan also describes the university planning expectations and must be consistent with the City of Corvallis Land Development Code.

McVlClellan Business Park: The current zoning at McClellan Business Park is zoned as a Special Planning Area (SPA). An SPA is created for an established area when the countywide zoning regulations do not adequately address local concerns. The SPA allows uses, regulations, and standards that would not be allowed under the countywide regulations.

31 of 58

• NWMI

• ~ ELM,-IoIR-NWioo01

':~'..:"

,L,** Rev. 0

-.

• 0.*

0. ll NOI-1 The JSG augmenting NUREG-]53 7, Part]1, Section 19.4.2, "Air Quality and I" Noise, "'statesthat the ER shouldprovide the potential impacts to sensitive "receptors. Section 19.4.2.3.] of the ER states that the impacts of noisefrom construction are SMALL. However Table 19-90 of the ER state that the noise impactsfrom construction at the Discovery ridge site would be MODERATE.

Clarify the noise construction impact level and reconcile the differences concluded regardingthe impact level.

The noise impacts for the Discovery Ridge site noted in Section 19.4.2.3.1 of the ER are small. The impact in Table 19-90 was incorrectly stated. The noise impacts at Discovery Ridge site are "Small."

NOI-2 The ISG augmenting NUREG-1537, Part]t,Section, 19.3.2, "Air Quality and 1" Noise'"states that the ER shouldprovide a description of any current orpast noise studies and analyses conducted at the proposed site or within an audible range of the site. Section 19.3.2.3.] of the ER states that "[biasedon the most recentpeak 1-hr traffic count summaryfrom the Missouri Department of Transportation,the expected noise levels at the proposed RPF site resultingfrom traffic on U.S. o Highway 63 rangefrom 54 to 58 [A -weighted decibel] dBA (MoDOT, 2009)." The source cited, MoDOT 2009, identifes the peak 1-hr traffic count, however, it does not provide information on noise levels. Provide the.basis for the stated 54 to 58 dBA and/or how that noise level was obtained.

The noise levels provided in Chapter 19.0 were calculated using noise level estimates from Table 1 of the Federal Highway Administration's (FHWA) Traffic Noise Model (TNM) 2.5 Lookup Tables. The noise values assume hard ground and no noise barrier and were used to assess existing noise levels at the proposed RPF site. Current guidance (November 2015) from the FHWA states the TNM 2.5 Lookup Tables should not be used to estimate noise levels. To incorporate the FHWA's current guidance, noise modeling for the nearest resident has been performed using the TNM 2.5 model. This information indicates the change in existing noise levels will be less than 1 A-weighted decibel (dBA).

32 of 58

• N J~,WMl

.:. , IOTeE  : NWMI NWMI-201 5-RA-OI-0Rv0 Rev

- . .. I'llI NOI-3 Noise, The ISG augmenting NUREG-153 7, Part]1, Section 19.4.2, "Air Quality and Vi

'"states that the ER shouldprovide predictednoise levels using the dbA*-

weighted scale and major sources of noise, including all models, assumptions, and.

input data. Section.states that "[tiraffic associatedwith the construction i:

workforce commuting to andfrom thefacility site also generates noise. As previously discussed, the baseline,noise conditionsfor traffic include airports, railways, and highways. The increase in noise relative to baseline conditions is "

most noticeable duringperiods of high activity onsite and duringshfif changes in the morning and late afternoon. "However, predictednoise levels from the additionalworkforce and additional deliveries and offsite shipments was not provided in the ER. Providepredicted increase in noise levels resultingfrom the additionalcommuting workforce and deliveries and offsite shipments during construction, operations, and decommissioning along U.S. Highway 63 and Discovery Drive in the vicinity of the proposed RPF site.

The predicted change in noise levels resulting from increased workforce traffic during construction, operations, and decommissioning have been modeled using FHWA TNM 2.5. Peak traffic counts were used to assess baseline noise conditions at the nearest residence. Noise levels resulting from the addition of 100 vehicles traveling 112.7 km/hr (70 mi/hr) on Highway 63 during peak traffic times were modeled to determine the potential increase over baseline conditions. Based on modeled results, an increase of less than 1 dBA is anticipated due to the increase in traffic from the workforce.

33 of 58

DIIAIW

[I" MI IVI,OPE Ie NWMI-201 5-RAI-001evI Rev.

-eC. C.*.C i i PA-IA Section 19.2 of the ER discusses the activities and schedule if the pre-operation phase. Clarify if the impacts of the pre-operationalphase were considered within the constructionphase or the operationsphase impacts describedin Section 19.4 of the ER.

The impacts associated with the preoperational phase were considered within the operating phase of the RPF.

PA-I1B Section 19.2.1 of the ER states the nominal operationalprocessingcapacity of the RPF would be one batch per week (up to 12 targetsper batch)for up to 52 weeks, .

.and approximately 30 targetsfrom the OSTR or a third university reactor for eight weeks per year per reactor. The discussionfiurther states that the assumed bounding scenariowould be a total of 68 batches of irradiatedLEU targets processed at the RPF annually. For the bounding scenario, clarify."

1.) The estimated number of targetsper batch, batches per week, and batches per year that would be separatelyprocessedfrom the OSTR and the third reactor, respectively.

2.) The estimated annualnumber of targets to befabricated, irradiated,and

___ processed at *the RPF.

The estimated number of LEU targets that can be irradiated (e.g., per batch) at the OSTR or hypothetical third reactor is one batch per week with a maximum of 30 LEU targets/batch. Each reactor can irradiate up to eight batches per year for a total of 16 batches annually.

The RPF has been designed to fabricate a maximum of 20 LEU targets per week or 1040 targets annually to support irradiation at NWMI's network of University research reactors. The RPF does not irradiate LEU targets. The RPF has the capacity to process up to 900 irradiated LEU targets for 99Mo production.

PA-2 Section 19.2.1.1 of the ER states that the start date of site 1" preparation/constructionwould be the first quarterof2 016 and an end date of construction offirst 2017, which would result in a maximum construction phase of 15 months. However, Section 19.4.2.1.1.4 of the ER references an estimated constructionperiod spanning 17 months. Clarif the construction durationphase and/or the difference in construction durationpresented in Section 19.2.1.1 and Section 19.4.2.1.1.4 of the ER.

The construction phase for the RPF is estimated to be 17 months; the end date of construction is estimated to be the end of third quarter 2017 (calendar year).

34 of 58

N MNWM,-201 5-RA,-00CevI

- . .. g.ggIi PA-3 Section 19.2.1.2 of the ER states that 100% of the 3.0 hectare (7.4 acre) site V" would be permanently affected. Differentiate between the total estimatedamount of land that would be temporarily affected by construction activities (e.g., land clearing, material and equipment lay-down areas) versus the amount that would be permanently affected by operationalactivities (e.g., building and support

.. .f acilityfootprints, paved vehicl.e access andparking area~s). . . .......... ..

100 percent of the site would be temporarily affected by construction activities. In addition, approximately 0.1 ha (0.26 acres) of the adjacent site to the east (Lot 14) would be temporarily affected to support construction activities. The response to LAN-3 provides additional information.

Approximately 68 percent of NWMT's RPF site will be permanently affected by operations activities.

The remaining 32 percent of the site will be revegetated or landscaped. The responses to LAN-3 and LAN-4 provide additional information.

VPA-4 Section 19.2.1.3, Table 19-6 of the ER lists shipments by project phase to include ,/

delivery trucks and offsite radioactivematerials and waste shipments.

Section 19.2.8.2.2, Table 19-14 of the ER presents a different set of shipment information. Clarify'the relationship of the values presented in Tables 19-6 and 19-14, specifically."

A.) Whether the estimated delivery trucks listed in Table 19-6 during operation accountfor fresh LEU and irradiatedtargetshipments identified in Table 19-14 of the ER, and B.) Whether the estimated offsite shipments identified in Table 19-6 during operation accountfor the unirradiatedtargets, 99 Mo product, spent LEU, and radioactivewaste shipments during operation identified in Table 19-14 of the ER.

The "delivery trucks" row of Table 19-6 does not include radioactive shipments. The LEU and irradiated LEU targets shipments (etc.) identified in Table 19-14 are included in the "Offsite radioactive materials and waste shipment" row of Table 19-6. In addition, the "Offsite radioactive materials and waste 99 shipment" row includes unirradiated LEU targets, Mo shipments, and radioactive waste shipments.

PA-5 Section 19.2.2.3 of the ER indicates that the proposed RPFsite would be V" connected to local power, sewer, and water infrastructure. Provide estimated annual sanitary sewer, electricalpower, municipal water, and naturalgas requirements required to support each phase of the project.

The estimated annual sanitary sewer, electrical power, municipal water, and natural gas requirements are provided below.

Construction

• Municipal water usage (provided in Section 19.4.7.3): 23,242 liters (L)/day (6,140 gal/day).

• Sanitary sewer usage is estimated at zero; portable units will be provided.

• Electrical power usage is not provided in the Construction Permit Application. An estimated 600 amp (A) 480 VAC service for a site crane and a dedicated 500 kilovolt-amp (kVA) 208/120 VAC service are anticipated to be needed for the RIPF construction.

• Natural gas usage is estimated at zero.

35 of 58

• • NM NWM,-201 5RA,-001Ro

- . .. ggggii Pre-Operations Phase

• Pre-operations is assumed to be three months at operations phase estimates.

Operations Phase

• Municipal water usage includes the process water and sanitary needs.

- Process water (provided in Section 19.2.4.1, Table 19-1 1): 890,910 L/year (235,360 gal/year)

- Sanitary water: 4,073,000 L/year (1,076,000 gal/year) for a total of 4,964,000 L/year (1,311,000 gal/year)

Total municipal water usage: 4,964,000 L/year (1,311,000 gal/year). (The WAT-1 response provides a detailed analysis of the municipal water usage.)

• Electrical power usage (provided in Section 19.4.7.3): approximately 10 megawatt (MW) annually.

• Natural gas usage (provided in EDF-3 124-0008, Emissionsfrom Natural Gas-FiredBoiler Operation): 5,880 L/minl (12,460 CF/br) for each of the four boilers that run simultaneously (two heating boilers and two process steam boilers), when running at their peak output.

Decommissioning

• Municipal water usage during decommissioning is not estimated in the Construction Permit Application. Water usage is estimated as being similar to the construction phase (provided in Section 19.4.7.3): 7,571 L/day (2,000 gal/day).

• Sanitary sewer usage is estimated at zero; portable units will be provided.

• Electrical power usage is not provided in the Construction Permit Application. An estimated 600 A 480 VAC service for a site crane and a dedicated 500 kVA 208/120 VAC service are anticipated to be needed for the RPF construction.

• Natural gas usage is estimated at zero.

PA-6 Section 19.2.5.2 of the ER indicates that the RPF would use three electric boilers. ,/

Clarify how these boilers relate to the four naturalgas boilers discussed in Section 19.4.2.1.2.4.

The RPF has two sets of boilers: one set of three boilers for the heating, ventilation, and air conditioning (HVAC) system, and the second set of two boilers for process steam. The three heating boilers are sized such that only two are operating and one is a spare. The process steam boilers are sized such that one operates and the other is a spare. All five boilers are natural gas-fired; however, only three would be expected to be operating at any one time (two heating and one process steam boiler).

The air quality impacts from operation, Section 19.4.2.1.2, evaluate operation of four natural gas-fired boilers to bound emissions from boiler operation.

36 of 58

NWM 1-201 5-RAI-001

~ NWM I Rev. 0

-aa a.g ai i IPN-IA In Section 19.2 of the environmental report, NWMJ summarized the status  :

of all applicable Federal,state, local, and other regulatory requirements, permits, and consultations that would be required.For the permits identified in Table 19-4 of the environmental report, provide a timeline or status updatefor when NWMI expects to apply for and receive the perm its. If relevant, provide a specie regulatory or other milestone on which a given permit may be dependent upon.

The required State and local Missouri permits described in Table 19-4 are accurate. The approximate dates for submittal of these permits are listed below.

Table 19-4. Regulatory Compliance Status (6 pages)

Atomic Energy A*_ct Construction RPF construction Addressed in

-a . a 10 CFR 50.50 Permit i Construction Permit a a i Application 10 CFR 50.57 Operating License RPF operation To be addressed in operation license

.... .. .. ..... .... .appli!cation . . ........

SBy-Product iProduction, possession, 7To be addressed in SMaterial License J!and transfer of license application 10 CFR 30 iradioactive by-product Smaterial Special Nuclear Receipt, possession, To be addressed in Materials License use, and transfer of license application

_special nuclear material_....... _

National Environmental Environmental SSite approval for RPF Addressed in this Policy Act assessment or construction and Construction Permit 10 CFR 51 environmental ioperation Application impact statement U.

Clean Water Act i[Dredge and Fill !Discharges of dredged Not required 33 CFR 323  ;'Permit (Section  !*orfill material into U.S.'

lwaters t 37 of 58

NWM 1-201 5-RAI-001 NMI Rev. 0 Table 19-4. Regulatory Compliance Status (6 pages)

Resource Conservation Notification of iEPA identification Notification to be

• and Recovery Act RCRA Subtitle C number for generation submitted 60 days prior 40 CFR 262 activity of hazardous waste to construction Estimated submission date: 4/1/2016 Estimated receipt date:

7/15/2016

'Clean Water Act SPCC plans for Storage of oi~l during sPCC plans to be 40 CFR 11 2, Subpart D, construction and construction and

• iSubmitted 30 days prior

'Appendix F .. .o perationb } operation ., to construction .

": *iEstimated submission dae:5//21 Estimatd:receit2date

*

iN approvald requieitdae Hazardous Materials iCertificate of !Transport of hazardous Registration to be filed I . *Transportation Act Registration materials ino later than June 30 of 49 !the CFR107 calendar year or j  !~prior to offering i Ihazardous materials for

!transport i Estimated submission I }date: 6/30/2016

~Estimated receipt date:

, 11/30/2017 Federal Clean Air Act Construction Construction of an air Not required 5

-s. - 0 Missouri Revised !Permit emissions source .*Verification 2/28/2016.

Statute Chapter 643 iPart 70 Operating Operation of an air Not required 10 CSR Division 10 Permit pollution emission Verification 2/28/2016 source that has potential emissions exceeding 100 tons/yr of criterion

...pollutants ........ ..

Intermediate Operation of an air Not required Operating Permit pollution emission source that has the potential to emit is above major threshold, ibut a voluntary limits ot

• ioperation is requested Basic State iOperation of an air Not required Operating Permit !pollution emission Ssource that has the ipotential to emit is between de minimis and imaj or levels 38 of 58

mEunamIm U NWMI-201 5-RAI-001 O* * *S*SEU**tE*S Rev. 0

• am Q3ThWESTJEDICAL Table 19-4. Regulatory Compliance Status (6 pages)

- Clean Water Act PNPDES Land disturbance and i:Applications for general,*

3 - or. -

• Missouri Revised PConstruction idischarge of stormwater permits (Forms E and

• Staut Capers64 Sorwatr eritfrom the construction !G) to be submitted o '

• an64

' site i:30 days prior to i01* CSR Division 20 i construction

• ' Estimated submission i'* i' date. 5/1/2016 '

• iiEstimated receipt date:

1 i7/15/2016 NPDES Industrial Discharge of iPermit to be submitted Stormwater Permit !istormwater from the ione year prior to

! ilindustrial site during operation iioperations i;Estimated submission ii " idate: 5/1/2016 Il ~I[ Estimated receipt date:

(( .... ..i! . . . . . I'5/1/2017 . . .. ..

i Section 401 Water i Certifies that the " Not required Quality !Section 404 permitted Request for a waiver:

iiCertification ilactivity complies with "12/30/2015 i ;all applicable State Esiaercipdt:

!iwater quality standards, 2/28/2016cip dte Slimitations, and

. ... . .. .. .... restr iction s ... . .. . .. .. . . . ... . .... . . .. . .

Resource Conservation Notification of Obtain Missouri Registration to be filed

• and Recovery Act Regulated Activity idetiicaio nubr9"aspirt Missouri Revised for generation of generating hazardous Statute Chapter 260 ihazardous waste 'waste 10 CSR Division 25 ;Estimated submission I', !date: 6/1/2017

~Estimated receipt date:

] 10/1/2017

• Cert-ified- Reso-urce !R~eu s-e,,recl a-mati-on,0V or Appli-catio'n *to*'be-.......

SRecovery Facility recycling 1,000 kg submitted 90 days prior SApplication (2,204.6 lb) or more of ;;to operations isite-generated Estimated submission hazardous waste in a date: 6/1/2017 i!month Estimated receipt date:

i 110/1/2017 iNotification to Notify MDNR in INotification to be MDNR of writing and by certified isubmitted 90 days prior Conditional delivery of the claim of ito operations SExemption a conditional exemption Estimated submission for LLMW stored and date: 2/1/2017 treated in the facility Etmtdrcitdt I ___ __5/1/20 17 Hazardous Waste Treatment, storage or Not required Permit disposal of hazardous waste 39 of 58

NWMI-201 5-RAI-001 SK3UNWM! Rev.0

• 00.::.N ',*' a~js'oE Table 19-4. Regulatory Compliance Status (6 pages)

I;Atomic Energy Act  ;!Registration of liProtection against IRadioactive sources 3..Missouri Revised sources of ionizing iqonizing radiationF will be managed under Statute Chapter 192 iradiation . !the NRC license and are,

• :9 CSR Division 20 " *= i 'iexcluded fromMissouri*

• " '.! i.. .. ." * ' lio . * =. * .{regul~ation -  !

.0o-Clean Water Act Stormwater Stormwater iApplication to be

-* - Missouri Revised Discharge Permit management submitted 30 days prior :

Statute, Chapter 64 i ito construction Boone County iEstimated submission Stormwater Ordinance idate: 5/1/2016 Estimated receipt date:

7/15/2016 i FLand Disturbance Activity disturbin Aplication to be Permit0.4 ha (1 acre) or more isubmitted 30 days prior Sof land or disturbing to construction S278.7 m2 (3,000 ft2) in Etmtdsbiso Senviromnentally..I date: 5/1/2016 sensitive areas Estimated receipt date.

! 7/15/2016

• Missouri Revised Application for " Construction of a .Application to be Statute, Chapter 64 Commercial ... commercial building *submitted 30 days prior

)Boone County Zoning Building Permit '! to. construction

• Regulations

• Estimated submission

,

• date: 5/1/2016

• . Estimated receipt date:'

• :7/15/2016

- 0 - Clean Water Act Sanitary sewer Building connection to Required information to

o. Missouri Revised connection District wastewater be submitted 30 days

- -Statute Chapter 250 iapproval treatment works prior to construction Chapter 2 of Boone {Estimated submission County Sanitary Sewer }date: 5/1/2016 Use Regulations } Estimated receipt date:

{7/15/2016 Clean Water Act iApplication connect !Application 10 CSR Division 60 utility service for iAllows RPF to

.to Columbia Water Ssubmitted 30todays be prior

• 0.

Part II City of !Treatment Plant ito construction Columbia Code of iEstimated submission Ordinances, Chapter 27 {date: 5/1/2016 SEstimated receipt date:

{7/15/2016 40 of 58

NWMI-201 5-RAI-001 NWMI Rev. 0 Table 19-4. Regulatory Compliance Status (6 pages)

Plart ii city of'Columbia Building Permit "Approval of building .... Application to be...

• code of Ordinances code and standards, submitted 60 days prior

• 0 Chapter 6, Article II including site plan :to construction

" °Estimated submission

' date: 4/1/2016 Estimated receipt date:

~7/15/2016 Part II City of Electrical plan Electrical Code Information to be Columbia Code of i ppovlsubmitted 60 days prior Ordinances aproalto construction Chapter 6, Article III iEstimated submission i date: 4/1/2016

! Estimated receipt date:

~7/15/2016 Code of Ordinances approval submitted 60 days prior Chapter 6, Article IV to construction

" Estimated submission date: 4/1/2016 Estimated receipt date:

..... 7/15/2016 _

Part II Code of HVAC plan Mechanical Code Information to be Ordinances approval submitted 60 days prior Chapter 6, Article V to construction Estimated submission jdate: 4/1/2016 Estimated receipt date:

7/15/2016

'Part II City of Certificate of Facilities meeting Information to be Columbia Code of Occupancy Building Code submitted on completion

~Ordinances *of construction Chapter 6 Estimated submission date: 9/30/2017 Estimated receipt date.

10/1/20 17 Part II City of Columbia Fire Prevention Fire Code Information to be Code of Ordinances Plan Approval ,submitted 60 days prior Chapter 27, Article II Ito construction Estimated submission'

date: 4/1/2016 Estimated receipt date:

... .. ........... . .. . .. . .... ... .67 15/20 16 41 of 58

NWMI-201 5-RAI-001

• : N:.1J*'IM~l~rw Rev. 0 Table 19-4. Regulatory Compliance Status (6 pages) 5' Pari II City of Land Disturbances Land disturbance .Application to be

• sfI*'I Columbia Code of Permit activity, including ° (su~bmitted 30 days prior

[* ] Ordinances

• iconstruction on 'any Site 'ito construction Chapter 12A, Article iII **, that results in a ' iEstimated submission

• ~~disturbed area of 1 acre:ldate: 6/1/2016 '

• , or ore. *[ Estimated receipt date: :

' . .. . :i  : 7/1512016 Part II City of Stormwater Approval required prior Information to be Columbia Code of iManagement Plan to approval for Land submitted 45 days prior Ordinances iApproval *Disturbance Permit to construction Chapter 12A, Article V iEstimated submission

'~date: 5/15/2016 i !Estimated receipt date.

___________ 7/15/2016 a Full references are provided in Section 19.7.

b Only required when oil is stored in a tank or shell with a capacity over 1,320 gal, and the oil could reasonably reach navigable water.

CFR =Code of Federal Regulations. NRC = U.S. Nuclear Regulatory Commission.

CSR = Code of State Regulations. RCRA = Resource Conservation anid Recovery EPA = U.S. Environmental Protection Agency. Act.

HVAC =heating, ventilation, and air conditioning. RPF = radioisotope production facility.

LLMW =low-level mixed waste. SPCC =spill prevention, control, and MDNR = Missouri Department of Natural Resources. countermeasure.

NPDES = National Pollutant Discharge Elimination System. U.S. =United States.

42 of 58

WM INwMi-201 "* .,',Rev.:"0 5RA,-001evl

. .. .. g-I'l PN-1 B In accordance with Section 401 of the Federal Water Pollution Control Act (i. e., V Clean Water Act (CWA)) (33 U.S. C. 1251 et seq.), a Federalagency cannot issue a permit or licensefor any activity that may result in a discharge to navigable waters of the United States until the state or"tribe where the discharge would originate has grantedor waived certificationthat the potential discharge will comply with applicablewater quality standards. CWA Section 401(a) (1) specifies that the applicantfor the Federallicense or permit is responsiblefor providing the*

Federal licensing or permitting agency the certification or a waiverfrom the state in which the discharge originates.As appropriate,the state could also provide the applicant with documentation that no separate 401 certification is required.

Section 401 requirements are cited under Section 19.1.2 of the ER and in Table 19-4, and Section 19.1.2.5.1.2 of the ER fulrther states that "the construction, operation, and decommissioning of the RPF is not anticipatedto need a Federal Section 404 permit or Section 401 certification... "Clarify whether the state of '

Missouriwill require a separate CWA Section 401 certificationfor NRC-licensed construction and operation of the RPF. Indicate the applicant'splans, and, associatedtimeframe, for providing the NRC with required CWA Section 401

~ stte o Misour NWMI made the determination that a Section 404 or Section 401 certification is not required for construction and operation. NMWI anticipates contacting MDNR for a formal waiver from the state by March 2016.

..PN-2 The ISG augmenting NUREG-1537, Part 1, Section 19.2, "ProposedAction, "' V" i states that the applicant should provide a description of the operational activities.

Clarify if the NWMI facility would produce molybdenum (Mo-99), iodine-131 (I-131) andxenon-133 (Xe-133).

The RPF has only been designed to produce 99Mo. No iodine-131 (1311) or xeonon-133 (133Xe) will be separated as a product. The ALT-4 response provides additional information.

43 of 58

4.... I:- tf W 1215-A-0

-. . .. H.

ii iSOC-1A Section 19.4. 7.1.2 of the ER indicates "89)(non-management,) permanent V" operations workers needed are available in the ROJ." The next sentence states, "About 40 percent (36) of the operations workers and theirfamilies are assumed to relocate to reside in the ROJ."' These statements appear to be in conflict. There is also no discussion about the number of permanent management operations workers. In addition, Table 19-6 of the ER lists an average andpeak operation workforce of98. Clarify'these statements and reconcile the differences,.

The wording in Section 19.4.7.1.2 will be modified to read "Although the required workers are located within the region of influence (ROI), many are assumed to currently be fully employed, and 40 percent (36) of the operations workers and 40 percent (4) of the management positions and their families are assumed to relocate from outside the ROI to reside in the ROI. Using the ROI average of 2.4 individuals per household, the total population increase in the various communities within the ROI due to operational workforce requirements is 96 people."

A revised Table 19-66 is provided below.

Table 19-66. Workforce Required for Operations Techica supot e ,4 3 ,1 Production workers _170 _ _ - - 43 127 ....

Managementc __ 290 I 9  ;* 281

]Production worker support 280 16 264 a BLS, 2012, "May 2012 Metropolitan and Nonmetropolitan Area Occupational Employment and Wage Estimates,"

www.bls.gov/oes/currentloessrcma.htm, U.S. Bureau of Labor Statistics, Washington, D.C., accessed September 2013.

b Includes all architecture and engineering occupations.

SIncludes architectural and engineering managers, and medical and health services managers.

44 of 58

• "i;.*: NiI*ME IAITp 5RI-0 NWI-0 SOC-l B Section workers19. 4. 7.1.3 would of the ERfor be required states

.that duringpeak decommissioning.

construction, However, Tablean estimated 19-6 of the ER 81 I'll

"°"*

"lists a peak workforce of 28. Reconcile the differences in workforee numbers i discussed in Section 19.4.7.1.3 and Table 19-~6 during decommissioning.

Table 19-6 is revised and provided below to reflect a peak workforce of 81 and an average workforce of 38 anticipated during decommissioning. The responses to AIR-i1B, AIR-i1C, and AIR-i1D provide additional information.

Table 19-6. Resources Required During Radioisotope Production Facility Phases Average workforce 38 38 SPeak* workforce 82 a81i

,* 98 98 J Delivery trucks (per week),................... ........ 20 ......

SOffsite radioactive materials and waste 1 0.5 10 20 Ishipments (per week)  :

Fuel (diesel),_L/month (gal/month) b1,647 (435) C189 (50) C189 (50)

ILow enriched uranium kg/year (lb/year) 0 50 (110) 0 e170 (375) f170 (375) ab The The peak number majority of theofdiesel deliveries fuel isduring construction consumed during theis estimated first threeatmonths 30 vehicles.

of construction.

oDiesel fuel is used for backup generator.

d LEU needed for hot commissioning and initial RPF startup.

LEU needed in Operation Year 3 for addition of second university reactor.

SLEU needed in Operation Year 5 for addition of third university reactor.

LEU =low-enriched waste.

45 of 58

.uiNWIu NW[215IoC

-S . .5 .N 'l SOC-2A Section 19.4.7.6.] of the ER states that duringpeak construction, traffic volume * "i i.

is estimated to be 30 heavy vehicles (dump truck and deliveries) and 82 vehicles i, (pickup trucks and cars) daily. However, Table 19-6 of the ER lists 20 delivery i trucks (per week) and]1 offsite material waste and shipment per week. Reconcile i the diff/erences in traffic volume discussed in Section 19.4.7.6.] and shipments The delivery trucks noted in Table 19-6 are assumed to be an average number delivery trucks per week.

A footnote was added to Table 19-6 noting "* The peak number of deliveries during construction is estimated at 30 vehicles." The revised Table 19-6 is provided in the SOC-lB response. Additional information is provided in the SOC-i1B, AIR-i1B, AIR-i1C, and AIR-i1D responses.

{sOC-2B Section 19.4. 7.6.3 of the ER states that there are an .estimated30 heavy vehicles ' -"i;*.......

(waste trucks) and 81 vehicles (pickup and cars) traveling to andfrom the site

• daily during the decommissioningphase. However, Table 19-6 of the ER lists 20 waste shipments per week and a peak workforce of 15. Reconcile the differences !

in traffic volume discussed in Section 19.4. 7.6.3 and shipments and workforce The peak number of waste trucks is an estimated at 20. Section 19.4.7.6.3 will be changed to reflect a peak of 20 heavy vehicles. Per SOC-iB, the peak number of workers is revised to 81 during decommissioning. Additional information is provided in the SOC-iB, AIR-1B, AIR-iC, and AIR-i1Dresponses.________

46 of 58

• ...,Rev.

ItIAIlf NWM,-201 5RA,-001Re 0

. .. .. g.I'l

~STT-NR-1 The ISG augmenting NUREG-153 7, Part]1,Section 19.4.9, "Waste  ! V/'

Management, "states that the ER shouldprovide anticipateddisposalplansfor the waste and a description of waste- minimizationplans to reduce or minimize generation of waste. Provide copies of the chemical management plan and

........ product andlingplan discujssed in Section 19.2.8.1.1 of the ER.

The chemical management and product handling plans have not yet been developed. These plans will be developed and included in the Operating Permit Application.

2A only to radioactiveand mixed wastes.

The first sentence of Section 19.2.8.1.2 was changed to read: "Treatment and temporary storage of hazardous, radioactive, and mixed wastes are performed predominantly onsite within the RPF." A new bulleted item was added that states: "Nonradioactive hazardous wastes are accumulated in satellite accumulation areas or less-than 90-day accumulation areas, prior to on-site treatment and packaging."

STT-NR- Discuss the processes intended to manage transportationof non-radioactive V1 S2B .materialsand wastes.

The transportation of nonradio active materials and waste are governed by the U.S. Department of Transportation (DOT) regulations cited within Section 19.2.8.2, "Transportation of Material." For clarification, the first sentence of the section was changed to read: "The transport of radioactive and nonradioactive materials, waste, and other hazardous materials associated with the RPF must comply with applicable U.S. Nuclear Regulatory Commission (NRC) and DOT regulations."

STT-NR-3 The JSG augmenting NUREG-i537, Part 1, Section 19.4.10, "Transportation" v" states that the ER shouldprovide estimated transportationdistancefrom the Soriginatingsite to the projected destination of non-radioactivewaste. Section S19.4.10.1.6 of the ER states that a non-radioactivewaste recycling drop-off

'point is located approximately 4 miles from the RPP. Clarify that statement.

Will NWMJ be transportingnon-radioactiverecyclables to that drop off point or will the waste brokerpick up the recyclables at the RPF?

The Civic Recycling Center is located at 3300 Brown Station Rd, Columbia, Missouri. NWMI has not yet determined if a recycling contract will be used to collect recyclables or if NWMI will deliver recyclables to the recycling center.

47 of 58

NWMI-201 5-RAI-001 NWM.:*"e~,esur Ir~ Rev. 0

-. *. .9

.ii I SWM-NR-1A Provide

'and the tlhepERj]{

19-13of chemical composition of the waste streams listed in Tables 19-12  ! i*i "

The composition of waste streams was compiled from the MURR and OSTR mass balance worksheets (NWMI-2013.-CALC-002, Overall Summary MaterialBalance - OSU Target Batch, and NWMI-2013 -CALC-006, Overall Summary MaterialBalance - MURR Target Batch) and are provided in the following table for reference.

Waste Stream Chemical Compositions SFe(SO3NI~i)2 1.13E-12 1,12E-03 l .13E-08 Grout  ! i 1.73E+001 HtNO3 2.501-03 8.40E-0 3 5.84E-03 4.27E-05 1.89E-32 1120 i9.72E-01 9.97E-01 7.021-04 1  ;!5.78E-01 2....E-05~o 3

HSO 3 NHI2 8.85E-13 y.4-0i4o S8.82E-09 S NH4 NO 3 7.29E-03 NaNO 2 i 1.8E0 4.61-021- -3.1 4-E-O2 --... . ... ..... .. .

NaNO 3 6.73 E-02 5.991-06 S3.60E-02 NaOH 9.45E-03 4.491-05 S NaH 2P0 4 1 .49-0 Na2SO 3 i 1.89E-03*It........ . 13.721-05 Na2SO 4 _ 1 .44E-03 2.83E-05, 2.841-10 2.83E-07 6.49E-10O 0.00E+00i 1.85E-03 i4.15E-07 l.I06E-06 UO2 (N03 ) 2 9.34E-11 8.07E-05 1.85E-05 4.57E-08 "1.78E-04 .'4.3 1E-"06*

3.00E-01 S3.00E-01 48 of 58

NWMI-201 5-RAI-001 NVIIMI Rev. 0

... D Il SWM-NR-

... B.. Provide strams the anticipatedmass (in a unit applicable to solid material) of the waste lseinTbe1-3of the ER.  :¢ The anticipated mass of the waste streams is provided below in Table 19-13.

Table 19-13. Solid Waste Produced at the Radioisotope Production Facility Target fabrication" [NAa _ __ _ _ NA NA iITarget disassembly and Target cladding materials from disassembly 1,100 L 1,700 kg t dissolutionb (290 gal) (3,748 lb)

Mo recovery and lExchange resins and other solid waste 20 L 34 kg purificationb ________________ (5 gal) (75 ib)

,Uranium recovery and Exchange resin and media A1,350 L 530 kg Irecvclea' (.-360 eal) (1.169 lb)

Waste managementc Solid wastes encapsulated in cement 8,000 L 15,000 kg (2,113 gal) (33,069 lb)

High-dose solidified liquids 200,000 L 300,000 kg

______________________(52,834 gal) (661,380 Ib)

Low-dose solidified liquids 150,000 L 225,000 kg

_____ _______________(39,625 gal) (496,035 lb)

Laboratory facilities iMunicipal waste (e.g., chemicals) 4,000 L d7 6 0 kg SPotentially contaminated laboratory waste (e.g., (1,056 gal) (1,675 lb)

_________________ sample vials and containers) ,..-

Facility support Mncplwaste (e.g., paper) 26,000 L e4,056 kg

________________________________ (6,868 gal) (8,942 lb)

SPotentially contaminated waste 40,000 L e,240 kg

_____________ (e.g., decontamination materials, PPE) (10,566 gal) (13,757 lb) a Solid waste generated during target fabrication is anticipated to be decontaminated and free-released.

b Transferred to waste processing system for final disposition.

eThe waste quantities current bounding estimates. Optimization of waste processing should reduce the volume of liquid waste generation.

3 d Based density of whole glass (uncompacted) municipal waste of 550 lb/yd (or 0.19 kg/L), Mississippi Department of Environmental Quality (http://www.deq.state.ms.us/MDEQ.nsf/page/RecyclingMaterialDensity andVolumeConversion).

Based density of commercial/industrial waste (uncompacted) municipal waste of 450 lb/yd3 (or 0.156 kg/L), from Mississippi Department of Environmental Quality (http://www.deq.state.ms.us/MDEQ.nsf/pagefRecycling_

MaterialDensityandVolumeConversion).

NA = not applicable. PPE = personal protective equipment.

49 of 58

NWMI IwEE-o1R I * :..;e:.o*,*,'*r B~r.*Rev.o

,-oI 0 IWM-N R-2 The ISG augmenting NUREG-153 7, Part]1, Section 19.2, "ProposedAction" rstates that the ER should identify treatment and packagingproceduresfor I'll ,/

radioactive and nonradioactivewastes and radioisotopeproducts;"

transportationpackaging systems to be usedfor waste," and estimated

!transportationdistance to which radioactive and nonradioactivewaste would most likely be sent. Provide a list of anticipatedwaste disposal companies and

'disposalsitesfor the waste streams, including construction wastes, listed in Section 19.2.7 of the ER.

Process system liquid wastes are solidified and disposed of as solid Class A and B waste. These wastes would be transported and disposed of by Waste Control Specialists at their facility in western Andrews County, Texas.

Nonradiological specialty waste is anticipated to be collected by a company such as Veolia or Clean Harbors for separation, processing, and disposal.

Solid waste would be disposed at the City of Columbia Sanitary Landfill, 5700 Peabody Road, Columbia, Missouri. Columbia Solid Waste Services may be used to pick up solid waste from the RPF.

Construction waste would be disposed at the City of Columbia sanitary landfill. Hazardous construction waste would be collected by a company such as Veolia or Clean Harbors for separation, processing, and disposal.

iWM-NR-3 The JSG augmenting NUREG-153 7, Part]1, Section 19.4.9, "Waste  :

Management," states that the ER shouldprovide a description of the sources, types, and approximate quantities of solid, hazardous, and mixed wastes expectedfrom the proposed action. Provide a list of non-radioactivewaste streams, their chemical composition, and their mass.

Table 19-13 provides a solid waste estimate for the RPF. Based on EPA's estimate of municipal waste adjusted for NWMI facility operations, the major components of the non-radiological facility wastes are paper, plastics, and food wastes. Other wastes constituents will include rubber, cloth, and metals.

Additional information, total mass, is provided in the WM-NR- 1 response.

WM-NR-4 The ISG augmenting NUREG-1537, Part]1, Section 19.2, "ProposedAction" v" states that the ER should identif the type of hazardous materialsassociatedwith the facility. Clarify whether the radioisotopeproductionfacility will be a large or small quantity hazardous waste generatorunder the Resource Conservation and Recovery Act (RCRA).-

The RPF is currently anticipated to generate less than 1,000 kg of hazardous waste per month and to be a small quantity generator under RCRA.

50 of 58

NWAMI

• s-.,

I Xl*H* AIoTOres v

NWM,1-201 -RAI-OCI Re.s

,WM-R-l 4_7eSG~aUgmentiegNTUREG-JJ7, Par/i,Section 19.4., "J[Taste Managemen$'" I istates thatthe ER shou/dprovide i4/9rmatiom with respectto waste management as, Sa resu/t ofconstniction, operation, an~ddecommissioningactivities. Partoldihe iinforationnecessary toproperk determiize Ie environmen~ta/impactsof/he

• ,roposed action ie the type anidc/ass oa/radioactive w~astesgeneratedat the/ac/ily'

!_abl L9-Az o/tfheE lB ists the types¢ af/radioactivemateriols andwas/esgenerated/

!by or requiredfor use at the RPF. For the radioactive wastes generated and ishipped to Waste Control Specialist (WCS), clarif what those wastes are and lwhat class of radioactive waste (i.e., Class A, Class B, Class C, Greater Than NWMI's Part 2 submission of the Construction Permit Application describes the RPF radioactive waste handling program in Chapter 9.0, Section 9.7.2. Radioactive wastes anticipated to be transported and disposed of by Waste Control Specialists in Texas will include the following:

• High-dose solidified liquid waste - The high-dose solidified liquid waste consists of liquid waste streams generated by the RPF processes containing a majority of radioisotopes separated from molybdenum (Mo) product and recycled uranium. High-dose liquids are accumulated, neutralized (by addition of caustic), concentrated, and combined with a solidification agent prior to transfer into a disposal container. The quantity of this waste stream is bounded by 300,000 kg/yr as a solid.

Solidified high-dose waste is currently projected to be a Class B waste stream for disposal.

° Low-dose solidified liquid waste - The low-dose solidified liquid waste mass is dominated by condensate generated by process stream concentrators containing small quantities of radionuclides.

A portion of the condensate is recycled for reuse as water input for selected process unit operations.

Condensate that cannot be recycled is accumulated, neutralized (by addition of caustic), partially evaporated, and combined with a solidification agent prior to transfer into a disposal container. The quantity of this waste stream is bounded by 225,000 kg/yr as a solid. Solidified low-dose waste is a Class A waste stream for disposal.

• Encapsulated solid waste - The encapsulated solid waste consists of solid materials generated by the RPF processes. Solid wastes are dominated by cladding pieces generated during the irradiated target disassembly system and filters containing undissolved target particles generated by the irradiated target dissolution system. Solid wastes are collected in a disposal container. After filling with solid waste, a grout material is added to the disposal container to encapsulate the collected waste. The quantity of this waste stream is bounded by 15,000 kg/yr as a solid. Encapsulated solid waste is currently projected to be a Class B waste stream for disposal.

Waste process optimization activities are anticipated to be performed as part of the final design, with the goal of reducing the high-dose solidified liquid waste (and possibly encapsulated solid waste) volume generated by RPF operation. Volume reduction has the potential to change the disposed waste classification from Class B to Class C as a result of optimization activities, and results will be described in the Operating Permit Application.

No greater than Class C waste will be generated by NWMI RPF operations.

51 of 58

• ...-..

• V I IIR

• NWM,-201 5-RA,-001evlv I'll WM-R-2 iThe ISG augmenting NUREG-!53 7, Part]1, Section 19.4.9, "Waste IV

',Management,""states that the ER shouldprovide informationwith respect to lwaste management as a result of construction, operation, and decommissioning iactivities. Part of the information necessary to properly determine the environmental impacts of the proposed action is the amount ofstorage afacility

.has to handle the radioactivewastes generatedat the facility.

Clarify how long radioactive waste must be stored on sitefor decay before

'shipping, and ifsz-fficient storage space is available for all anticipated iradioactive wastes and radioactivematerials necessaryfor operation._......... ......

The disposed waste package radionuclide inventory was compared to transport cask design limits for radionuclides and heat generation. The comparison indicates that high-dose solidified liquid waste should be stored more than -45 weeks for decay prior to transport to a disposal site. Encapsulated solid waste should be stored more than '-12 weeks prior to transport. No decay time requirements are currently defined for transport of Class A low-dose solidified liquid waste. However, a cost incentive may exist for allowing the low-dose solidified liquid waste to decay for -12 weeks prior to disposal.

Sufficient storage space to support RPF operations has been included. Process material lag storage elements are described by the process descriptions in Chapter 4.0 of the NV/MI Part 2 Construction Permit Application. The process lag storage elements discussed throughout Chapter 4.0 are indicated by comparison of the bounding and nominal special nuclear material inventories shown in Tables 4-1 and 4-2. Storage space for radioactive waste is described in Chapter 9.0.

Information related to third reactor cannot be supplied at this time, as the reactor has not yet been selected. Site visits to the potential third reactor sites have indicated that anticipated changes in the sources, types, and approximate quantities of radiological effluents or waste streams; radiological impacts to the workers; and radiological impacts from transportation due to the shipment to and from the reactor will be similar to that assumed for the OSTR.

52 of 58

."IiI:NW fI

• .. "Na.

  ws WEaSrELiOoPEs NWMI-201 5-RA[-OOevR v 1

- .....-I'll WAT-1A iSection 19.2.4.] and Table 19-11 of the ER provide a narrativedescription and' V" tabularsummary, respectively, of the projected water demands, and Section 119.2.7.] summarizes liquid waste streams associated with operation of the p*roposed RPF. Provide a supportingprocess water balance (water use "diagram)forthe facility showingflow rates to andfrom the various water isystems, water system interconnections and interdependence,points of

consumption, and source and discharge locations. Specifically identify'RPF

pfrocess, cooling, steam production,fire protection,potable and sanitary, floor land equipment washdown, and any other specific water uses and identify'

.. .. . ... c.eon~su*tm pt~ive losses. .. . . .. .. . . . .. .... .... . . . . .. . .. . . . . . .. . . . .

The following diagram is based on several assumptions, which include the following:

• Demineralized water is required at a rate of 540 gal/day for 5 days/week.

• Steam is required for 3 days/week for 24 hr/day.

• Steam recharge (blowdown) is assumed at 10 percent of peak load requirement defined in NWMI-2015-SDD-011, Utility Systems SDD.

• Cooling water makeup is minimal and intermittent.

• Waste includes approximately 50 percent solids.

• Water out the stack is assumed to be 10 gal/hr 24/7.

• Recycle is not included in the water balance.

• Th-t. nritpr hci~nr~o rAno.l~. -nf. ,rn -,,f rJ..tJnlim n llVt hocritnrd.

• L'..r lur~*,- '.J~alnoJ fr,,n "L1'Jim crr~

hoLokJitaIO rrirt~.,nib~PPA1.,ci.1..

t1-'.JLA*'fli fh* 1*)

UJ UiIfn O

Ctyof Columbia Water System (potable) 53 of 58

• • hfWMIf NWMI-201 5-RAI-00 1ev0

. . . liii' WAT-1 B ER Table 19-)), which reports total annualwater consumptionfor the RPF, V"

!impliesthat aillfacility water use is "demineralizedwater" with separate

'columns includedfor "wash water. " Raw potable water usage does not appear ito be accountedfor and, except for the activity 'faculty support," there appears ito be no provision to meet the potable and sanitarywater needs oj ihe 9c facil'y In Table 19-11, "Faculty" [sic] should have been "Facility." The various water usage systems that are supplied by the municipal water system is described below.

"The municipal water system will be split into for main users within the RPF: the demineralized water system, the wash water system, the sanitary (drinking, showers, and toilets) system, and the firewater system. Wash water will be used to washdown the tractor/trailers. The firewater system is described in Chapter 9.0, Section 9.3."

The demineralized water system usage has been revised and is provided below.

"The demineralized water system supplies demineralized water to the process for water addition, flushing, and chemical dilution. The demineralized water system can also potentially provide make-up water to the steam boilers."

The sanitary water usage has been inserted into Table 19-1 1 and is provided below. In addition, a note has b een added to Tab le ..19-11. to__addres sfir~e wate~r and-_irrigation usage_.................................

Table 19-11. Radioisotope Production Facility Water Flow Rates and Consumption Information

- S -mI mm

!Target fabrication 25,000 6,600 ....- -

Target disassembly and 1,500 400 . - ., - i - -

!Mo recovery and ...... i-ipurification system I-...

Uranium recovery and !500,410  ! 132,200 -  ! - - --

recycle system i  !

• Waste managemnent ...... - .......

iFacility supot d 2,000 530 -- 360,000 95,100 _4,073,000 ,1,076,000 .

To~tal_ ............. .. 530,.910 .... __140,2_60._ .. 3609,_000... 95,100o .... 4,073,000. 1,076,_0.00 bAverage daily use 2,042 539 1,385 366 15,665 4,140 a These numbers do not account for planned process recycle.

b Assumes 260 days of operation per year.

SNote that there is anticipated to be a (180,000 gal) firefighting water storage tank that will be filled over an 8-hr period at 1,419.5 Llmin (375 gal/min). This water usage is not included in the above totals.

d Annual landscape irrigation is not included in the above totals. Landscape irrigation is assumed to not be required.

54 of 58

• • NWMAIn NWM,-2o1 5-RAI-001R.0 WAT-1 C liAs cited in Table 19-11, reconcile the cited average daily use values (539 -+

1366 gal) with the value of 1,286 gal/day given in Section 19.6.3.1.2 of the ER.

Section 19.6.3.1.2, "Water Resources," has been revised and is provided below.

I'll

,i .

i ' 1 J "The RPF requires water from the*Consolidated Public Water Supply District #1 water supply system for construction, isotope production, potable water, fire protection, and facility heating and cooling. The Consolidated Public Water Supply District #1 presently supplies 5.49 megaliter (ML)/day (1.45 million gallons [Mgal]/day). Construction requirements of the RPF are small compared to the available water supply. As noted in Section 19.2.4, the RLPF would require 19,094 L/day (5,044 gal/day) during operations, less than one percent of the total Consolidated Public Water Supply District #1 operational capacity. This leaves a significant excess capacity. Because there would be significant excess capacity within the Consolidated Public Water Supply District #1, there are no indirect effects associated with the demand from the RIPF. There are also no direct impacts to water quality or hydrology from the RPF, and therefore, there would be no irreversible impacts."

55 of 58

.IVIII NWMI-201 5-RAI-001 REFERENCES 10 CFR 20, "Standards for Protection Against Radiation," Code of FederalRegulations, Office of the Federal Register, as amended.

10 CFR 50.59, "Changes, Tests, and Experiments," Code of FederalRegulations, Office of the Federal Register, as amended.

40 CFR 61, "National Emission Standards for Hazardous Air Pollutants," Code of FederalRegulations, Office of the Federal Register, as amended.

40 CFR 261, "Identification and Listing of Hazardous Waste," Code of FederalRegulations, Office of the Federal Register, as amended.

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

ANSI/ANS 15.16, Emergency Planningfor Research Reactors, Withdrawn 2008, American Nuclear Society, La Grange Park, Illinois, 1982 (W2008).

BLS, 2012, "May 2012 Metropolitan and Nonmetropolitan Area Occupational Employment and Wage Estimates," www.bls.gov/oes/current/oessrcma.htm, U.S. Bureau of Labor Statistics, Washington, D.C., accessed September 2013.

CATSO, 2015a, 2040 Long-Range TransportationPlan, Columbia Area Transportation Study Organization (CATSO), Columbia, Missouri, 2015.

CATS O, 2015b, Appendix Q - CAT SO Major Roadway Plan Network by Segment, Columbia Area Transportation Study Organization (CATSO), Columbia, Missouri, 2015.

CDT, 2013, "MU, Company Partner to Boost Supply of Isotope Used in Diagnostic Drug," Columbia Daily Tribune, http:/wwcolumbiatribune. com/news/education/mu-company-partner-to-boost-supply-of-isotope-used-in/article_0c707d88-4909-11 e3-9ef7- 10604b9f6eda.html, Columbia, Missouri, November 9, 2013.

CDT, 2015a, "New Hospital Adds to Longstanding Fulton Medical Center, MU Health Care Partnership,"

Columbia Daily Tribune, Columbia, Missouri, May 17, 2015.

CDT, 2015b, "New Hospital Not Needed, Says the Committee," Columbia Daily Tribune, Columbia, Missouri, July 18, 2015.

CDT, 2015c, "Kraft Plans $114 million Columbia Expansion," Columbia Daily Tribune, Columbia, Missouri, July 9, 2015.

City of Columbia, 2008, 2030 CATSO Long Range TransportationPlan, City of Columbia Department of Planning and Development, Columbia, Missouri, http://www.gocolumbiamo.com/community-development/wp-content/uploads/sites/1 4/2015/09/2030OTransportationPlanFinal.pdf, June 20, 2008.

City of Columbia, 2012a, City of ColumbiaFY 20l3 CIP PlanningDocument, https ://www.gocolumbiamo.com/Finance/S ervicesiFinancial_Reports/index.php, Columbia, Missouri, October 1, 2012.

City of Columbia, 2012b, "Columbia City View," zoning map, Geospatial Information Office, www.gocolumbiamo.com/Maps/City View, Columbia, Missouri, accessed July 2013.

56 of 58

o N.WE,,C,*to*,OoP,,

MEUU I3VM-01-A-0 Rev. 0 City of Columbia, 2012c, Columbia Code of Ordinances, Chapter 29 - Section 29-18, District M-R, Planned Research, Development and Office Park District, www.gocolumbiamo.com/Council/Columbia Code of Ordinances/Chapter_29/index.html, Columbia, Missouri, accessed August 2013.

City of Corvallis, 2000, City of Corvallis Comprehensive Plan, Corvallis, Oregon, June 26, 2000.

CW&L, 2013, "New South Substation & Transmission Lines Public Hearing,"

hftps ://www.gocolumbiamo.com/WaterandLight/Electric/ProposedElectricTransmission.php, Columbia Water and Light, Columbia, Missouri, July 15, 2013.

EDF-3 124-0008, Emissionsfrom Natural Gas-FiredBoiler and Emergency Diesel Generator Operation, Rev. 0A, Portage, Inc., June 26, 2014.

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

EDF-3 124-0011, Greenhouse Gas Emissions, Rev. 1, Portage, Inc., Idaho Falls, Idaho, July 31, 2015.

EDF-3 124-00 12, Emission Modelingfor Process and HVA C Boilers Using AERSCREEN, Rev. 1, Portage, Inc., Idaho Falls, Idaho, February 4, 2015.

EDF-3 124-00 13, On-RoadEmissionsfor Vehicles During Operations,Rev. 1, Portage, Inc., Idaho Falls, Idaho, July 31, 2015.

EDF-3 124-00 14, Emission Modelingfor ConstructionActivities using AERSCREEN, Rev. 1, Portage, Inc., Idaho Falls, Idaho, June 26, 2015.

H-84 10-1, Visual Resource Inventory Manual, U.S. Department of Land Management, Bureau of Land Management, Washington D.C., January 1986.

MIHFRC, 2015, Certificate of Need Application, ProjectNo. 5210 NS, Landmark Hospital Transitional Recovery Center of Columbia, Missouri Health Facilities Review Committee, Columbia, Missouri, July 2, 2015.

Missouri Revised Statutes, Chapter 172, Section 172.273, "Research, development and office park projects established, when--procedure--curators' powers--real property exempt from zoning, ordinances and property tax--permits, licenses and certificates may be issued, when, application of sovereign and official immunity and public duty doctrines," Missouri General Assembly, Jefferson City, Missouri, as amended, August 28, 2012.

MU, 2009, Discovery Ridge Master Plan and Protective Covenants, https ://uminfopoint.umsystem.edu/media/ed/Discoveryridge/masterplan-discoveryridge.pdf, University of Missouri, Columbia, Missouri, January 6, 2009.

NAS, 2009, Medical Isotopes Production Without Highly Enriched Uranium, National Academy of Sciences, Washington D.C, 2009.

NEA, 2012, A Supply and Demand Update of the Molybdenum-99 Market, Organization for Economic Cooperation and Development/Nuclear Energy Agency, Paris, France, August 2012.

NBA, 2015, The Supply ofMedical Isotopes - 2015 Medical Isotope Supply Review:"99Mo/t 9mTc Market Demand and Production Capacity Projection2015-2 020, Organization for Economic Cooperation and Development/Nuclear Energy Agency, Paris, France, August 2015.

NUREG-1 537, Guidelinesfor Preparingand Reviewing Applications for the Licensing of Non-Power Reactors - Format and Content, Part 1, U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Washington, D.C., February 1996.

57 of 58

• YI.*o.

• ]RlWST ME'DICDI.

TDPES NW MI ~NWMI-201 5-RAI-OO1ei NWMI-2013-002, 2013, Alternative Site Selection for the Radioisotope Production Facility, Rev. 2, Northwest Medical Isotopes, LLC, Corvallis, Oregon, June 9, 2015.

NWMI-20 13 -CALC-002, Overall Summary Material Balance - OSU Target Batch, Rev. B, Northwest Medical Isotopes, LLC, Corvallis, Oregon January 29, 2015.

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

NWMI-20 15-SDD-0 11, Utility Systems SDD, Rev. A, Northwest Medical Isotopes, LLC, Corvallis, Oregon, February 18, 2015.

OAR 340-101-0033, "Additional Hazardous Wastes," Oregon Administrative Rule, as amended.

Regulatory Guide 2.6, Emergency Planningfor Research and Test Reactors, Rev. 1, U.S. Nuclear Regulatory Commission, Washington, D.C., March 1983.

Regulatory Guide 4.20, Constrainton Releases of Airborne RadioactiveMaterials to the Environmentfor Licensees Other Than Power Reactors, Rev. 1, U.S. Nuclear Regulatory Commission, Washington, D.C., April 2012 RS&H No. 226-1077-000, Columbia RegionalAirport (COU) Columbia, Missouri Draft Environmental Assessment, City of Columbia and U.S. Department of Transportation - Federal Aviation Administration, http://www.flycou.com/?page_id='342, Columbia, Missouri, January 2012.

Terracon, 201 la, PhaseI Environmental Site Assessment Discovery Ridge 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. 09117701, March 23, 2011.

Terracon, 201 lb, PreliminaryGeotechnicalEngineeringReport 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.

58 of 58

• • • rNW

• .: MI

VVVIIRev. NwMI-2o1 5-RAI-O010 APPENDICES Appendix A - EDF-3 124-0011, Greenhouse Gas Emissions.................................................. A-i Appendix B - EDF-3 124-0008, Emissions from Natural Gas-Fired Boiler Operation...................... B-i Appendix C - EDF-3 124-001:2, Emission Modeling for Process and HVAC Boilers Using AERSCREEN..................................................................................... C-i Appendix D - EDF-3 124-00 13, On-Road Emissions for Vehicles During Operation...................... D-i Appendix E - Northwest Medical Isotopes, LLC Alternative Site Evaluation .............................. E-i Appendix F - Oregon State University TRIGA Reactor Emergency Response Plan ....................... F-i Appendix G - University of Missouri Research Reactor Emergency Response Plan....................... G-i Appendix H - Phase I Environmental Site Assessment Discovery Ridge Lots 2, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, and 18 Terracon (Terracon, 2011a) ............................... H-i Appendix I - NWMI-2015-RPT-002, Radioisotope Production Facility Vegetation Assessment.......... I-i Appendix J - NWM\I-2015-RPT-001, Radioisotope Production Facility Surrounding Property Assessment ........................................................................................ J-i Appendix K - Preliminary Geotechnical Engineering Report Discovery Ridge - Certified Site Program Lots 2, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, and 18 (Terracon, 201lb) ............................................................................................. K-i

NWMJ-201 5-RAI-001

• *N$*,,W[SM!DC*STP. Rev. 0 Appendix A -

EDF-3124-0011, Greenhouse Gas Emissions A-i

Document ID:EDF-3124-001 1 Revision ID:1 Effective Date:July 31, 2015 Engineering Design File Greenhouse Gas Emissions Portage Project No.: 3124 Project

Title:

NWMI Environmental Report 4Portage TEM-9002 09/29/09 Rev. 0

TEM-9002 ENGINEERING DESIGN FILE EDF-3124-001 1 09/29/09 Rev. 1 Rev. 0 Page 1 of 5

1. Portage Project No.: 3124

2. Proj ectlTask: NWMI Environmental Report DCN#

Title:

Greenhouse Gas Emissions 5 NPH PC orSDC: N/A 6 SSC Safety Category: N/A 7 Summary: This EDF presents the total CO 2 emissions from all the sources identified for both the construction phase and annual operation.

8 Distribution: (Portage, Inc.)

9. Review (Identify(R) and Approval minimutm reviews(A)andSignatures:

approvals. Additional reviews/approvals may be added.)

Printed Name/

R/A Organization. Signature Date Author/Design Agent A Gary McManus (),5 * [8v* 7/31/15 Independent Review R Dave Thomne

• 7/31/15 Independent Review R Project Manager RJA John Beller 7/31/15 Registered Professional Engineer's Stamp (if required) E]N/A

TEM-9002 ENGINEERING DESIGN FILE EDF-3124-001 1 09/29/09 Rev. 1 Rev. 0 Page 2 of 5 INTRODUCTION AND PURPOSE Greenhouse Gases trap heat in the atmosphere, absorbing and emitting radiation in the thermal infrared range. The most important of these gases are C02, methane, nitrous oxide, and fluorinated gases. GHGs are reported as CO2 equivalent (CO2e) and refer to the global warming potential of the GHG or gases being emitted.

Activities associated with the proposed RPF site that are expected to contribute to GHGs include:

Construction activities at the site (assumed to last 17 months, 73.7 weeks) principally resulting in emissions of GO 2; GHG emissions associated with construction activities include:

• The commuting construction workforce.

• Operation of construction equipment at the site.

• Operation of on-road construction vehicles.

These GHG emissions are summarized in Table 1 below.

Table 1. GHG Emissions from Construction Phase Activities Source (lbs) (kg) (ton) (tonne)

Commuting Construction Workers a 1,220,000 552,000 610 552 Operation of Construction Equipment at site b 56,600 125,000 28 13 Operation of on-Road Construction Vehicles a 97,000 43,000 49 43

a. EDF 3 124-0005, On-road Vehicle Emissions During ConstructionRev 1. Portage, Inc, Idaho Falls, ID, July 31, 2015

b. EDF 3 124-0009, Off-road Vehicle Emissions During Construction Rev 1. Portage, Inc, Idaho Falls, ID, July 31, 2015 Plant operation activities associated with the operation of plant equipment and the operations workforce.

This includes:

• The commuting work force

• The four natural gas boilers -

• The emergency diesel generator These GHG emissions are summarized in Table 2 below:

TEM-9002 EDF-31 24-0011 09/29/09 ENGINEERING DESIGN FILE Rev. 1 Rev. 0 Page 3 of 5 Table 2. GHG Emissions during Plant Operation Source (lbs) (kg) (tons) (tonnes)

Daily Workforce Commuting a 860,000 -390,000 440 400 Natural Gas Boilers b 51,000,000 23,000,000 26,000 23,000 Emergency Diesel Generator b 97,000 -44,000 49 44

a. EDF 3124-0013, On-roadEmnissionfor Vehicles Suring Operation, Rev 1. Portage, Inc, Idaho Falls, ID, July 31, 2015

b. EDF 3 124-0008, Emission from Natural Gas Boiler Operation, Rev 0. Portage, Inc, Idaho Falls, ID, June 26, 2014 From Tables 1 and 2 the total GHG emissions for the construction and operation phases of the project are summarized and presented in Table 3 below.

Table 3. Total GHG Emissions during Construction Phase and Normal Operations Phase Source (lbs) (kg) (tons) (tonnes)

Construction Phase 1,500,000 660,000 730 660 0peration Phase 52,000,000 24,000,000 26,000 24,000

TEM-9002 ENGINEERING DESIGN FILE EDF-3124-0011I 09/29/09 Rev. 1 Rev. 0 Page 4of 5

Attachment:

Excel spreadsheets of calculations

__________Source (ibs) (kg (tons) Lt Commuting Construction

_________W res1,220,000 552,000 610 552 Operatio n of Construction 9740 4,0 49 3

________________Equipment at site _____

Operation of on-Road 1462 5,1 2 5

________________ ConstructionVehicles _____ ____

_________Total 1,442,002 651,818 721 652 Construction Phase CO2

______________ Commuting Construction ______ ______ ____

__________Workers (kgs) (lbs) [(to nnes) (ton)

__________ Light Duty Auto (gas) 320,000 700,000 320 350

_________ Light duty Trucks (gas) 180,000 400,000 180 200

__________ Light duty Trucks (diesel) 52,000 120,000 J 5'2 60

_________Total 552,000 1 1,220,000 1 552 1 610

_ __ _ _ _ _ _ _ _ I __ I _ _ _ _

Operation of Construction Equipment at site O

_______________________________(_____ Q ) (lbs) (tonnes) (ton)

Light Heavy Duty Delivery Trucks 15,000 34,000 15 17 Hev uyHaulers 3,300 7,200 3 4 CntutnTrcsConcrete 24,000 54,000 24 27 1,000 2,200 1 1 1

_________Asphalt

_________Total 43,300 [ 97,400 1 43___ 49___

__ _ _ _ _ _ _ _ I _ _ _ _

Operation of Off-Road Construction Equipment at CO2_________

____________ site (kgs) (lbs) (tonnes) (ton)

_________Bulldozer 13,025 28,715 13 14

_________Compactor 9,670 21,318 10 11

_________Excavators 9,065 19,986 9 10

_________Front Loaders 3,126 6,892 3 3 Graders 6,044 13,324 6 7

_________Paver 5,919 13,048 6 7 Roller 9,670 21,318 10 11 1

_________Asphalt

_________Total 56,518 124,602 1 57 62 I- I I- +/- 1-

TEM-9002 EDF-3124-001 1 09/29/09 ENGINEERING DESIGN FILE Rev. 1 Rev. 0 Page 5 of 5 GHG Release During Plant Operation_____ ____

Daily Workforce Commuting CO2 S(kgs) (ibs) (tonnes) (ton)

_________Light Duty Auto (gas) 225,239 496,569 225 248

________Light duty Trucks (gas) 129,506 285,513 130 143 Light duty Trucks (diesel) 37,004 81,580 37 41

_________Daily Workforce Commuting 391,749 863,662 392 432

_________Natural Gas Boilers 23,586,803 52,000,000 23,187 26,000

__________Emergency Diesel Generator 44,000 97,003 44 49 i V Operations Summary So urce (lbs) kg) (to ns) (t Daily Workforce Commuting 863,662 391,749 432 392 Natural Gas Boilers 52,000,000 23,586,803 26,000 23,587 Emergency Diesel Generator 97,003 44,000 . 49 44 Operation Phase 52,960,665 24,022,552 26,480 24,023 Construction Phase [1,451,967 I658,598 [726 I 659

_ _ __ _ _ _ _ _ _ I _ _ I _ _

"O " NWM!I

• ,OC. NORTHWEST MEDICALISOTOPES ATTACHMENT 1 Northwest Medical Isotopes, LLC Response to the U.S. Nuclear Regulatory Commission Request for Additional Information Environmental Review of the Northwest Medical Isotopes, LLC Construction Permit Application (Document No. NWMI-201 5-RAI-001, November 2015)

Information is being provided via hard copy

• ,Oo.O

• eOOO

• 0 @00.0 NWMI NORTHWEST MEDICAL ISOTOPES Response to the U.S. Nuclear Regulatory Comm ission Request for Additional Information Environmental Review of the Northwest Medical Isotopes, LLC Construction Permit Application NWMI-2015-RAI-O01, Rev. 0 November 2015 Prepared for:

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

This page intentionally left blank.

I

NWMI-2015-RAI-001

!;: NWM!I Rev. 0 Response to the U.S. Nuclear Regulatory Commission Request for Additional Information Environmental Review of the Northwest Medical Isotopes, LLC Construction Permit Application NWMI-201 5-RAI-OO1, Rev. 0 Date Published:

November 23, 2015

Title:

Response to the USNRC Request for Additional Information - Environmental Review of the NWMI Construction Permit Application Checked by: N/A Approved by: Carolyn Haass Signature: C w['*Yp *-

ii

NWM1-201 5-RAI-001

!:;i!NWM!I

• , ,, OR'STM*IAIOOESc Rev. 0 REVISION HISTORY Rev Date Reason for Revision Revised By 0 11/23/2015 Issued for Submittal to USNRC NA

NWMI-201 5-RAI-001 WMI Rev. 0 TERMS Acronyms and Abbreviations 41Ar argon-41 99 Mo molybdenum-99 1311 iodine-13l

' 33Xe xenon- 133 ALARA as low as reasonably achievable BLM Bureau of Land Management CATSO Columbia Area Transportation Study Organization CFR Code of Federal Regulations CO carbon monoxide CO 2 carbon dioxide CSR Code of State Regulations Discovery Ridge Discovery Ridge Research Park DOT U.S. Department of Transportation EH&S Environmental Health & Safety EPA U.S. Environmental Protection Agency ER Environmental Report FHWA Federal Highway Administration H2 hydrogen gas HAP hazardous air pollutant HEU highly enriched uranium HIC high-integrity container HVAC heating, ventilation, and air conditioning LEU low-enriched uranium LLMW low-level mixed waste MDNR Missouri Department of Natural Resources Mo molybdenum MU University of Missouri MURR University of Missouri Research Reactor N2 0 nitrous oxide NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NHC n-hydrocarbon NO nitric oxide NO 2 nitrogen dioxide NOx nitrogen oxides NPDES National Pollutant Discharge Elimination System NRC U.S. Nuclear Regulatory Commission NWMI Northwest Medical Isotopes, LLC 02 oxygen 03 ozone OAR Oregon Administrative Rule OSHA Occupational Safety and Health Administration OSTR Oregon State University TRIGA Reactor OSU Oregon State University Pb lead PM particulate matter

• ,,o

  "NOESTMEUAIS/IfTlPE5 PM-2.5 particulate matter, 2.5 micron PM- 10 particulate matter, 10 micron PPE personal protective equipment RCRA Resource Conservation and Recovery Act RO Reactor Operator ROI region of influence RPF Radioisotope Production Facility SHPO State Historic Preservation Office SO2 sulfur dioxide SO* sulfur oxides SPA Special Planning Area SPCC spill prevention, control, and countermeasure SRO Senior Reactor Operator TCE trichloroethylene Terracon Terracon Consultants, Inc.

TNM Traffic Noise Model TRIGA Training, Research, Isotopes, General Atomics U.S. United States U.S.C. United States Code USFWS United States Fish and Wildlife Service USGS U.S. Geological Survey VOC volatile organic compound Units

[tCi microcurie gg microgram A ampere Bq becquerel Ci curie dBA A-weighted decibel ft feet ft2 square feet ft3 cubic feet g gram gal gallon ha hectare hr hour in. inch kg kilogram km kilometer kVA kilovolt-amp L liter lb pound m meter m2 square meter m3 cubic meter Mgal million gallons mi mile mL milliliter ML megaliter mm millimeter ii

NWMI-201 5-RAI-001 NV IVI Rev. 0 mrem milifrem MW megawatt ppb parts per billion ppm parts per million t tonne (metric)

VAC volts alternating current wt% weight percent yd 3 cubic yard yr year iii

K E~M NE 53 NWMI-201 5-RAI-001 Rev. 0

• . EUVI

• ORCAWESTMED CA SCIAPA This page intentionally left blank.

iv

NWM I-201 5-RAI-001 I~I1JV lvi I Rev. 0 iAIR-1A 'Clarif if Table 19-58 of the Environmental Reportpresents emission factors or

( emissionsfor off-road construction equipment. if Table 19-58 does present

emissionsfor off-road construction equipment, verify~the emissions presented for p...*art!iculate matterless_ than 2.5 microns. 2 ... _ * ..

Table 19-58 provides emissions for off-road construction. The emissions in Table 19-58 have been verified. Changes to the table include removing "Factors" from the table title and correcting the mislabeled column headings. Table 19-58 has been revised and is presented below.

Table 19-58. Air Pollutant Emissions for Off-Road Construction Equipment U

Bulldozer

)Compactor (1

1

[100 120 m*ml/m***l*ln 11401...3.10 160 340

_..19 I_41 _.1.*

21 46' 6.3 7.0 -I14 1

!4:7]10 1*'5 :5.3

!13,000j29,000i 12 -15,000 32,000 23 26 51 157j Excavators 2.4 9i54i' 1.8 4.0 4,500 110,0001 8.1 18 tFront loaders 1 120 68 150 10 23 3.4 7.4 2.5 5.6 6,200 14,000 11 25 1 Graders 1 80 i661150 !10 i22j  : . . ) . 6,0001 13,000o 11r24 3.2 iPaver 1 80 =64 1.40 10 22 7.0 2.4 ,5.3 5,900 13,000 11 23]!

Asphalt

......... roller 1 8-*%0---1-iO--230-! 14 ... 31 i 4.7

.......T-otal -647 1i430 9"1.5 ....202- 30.2- 66;.0 22.6 50.0oo 60,300' 132,000 107.1 2-361 Source: EDF-3124-0009, Off-Road Emissions During Construction, Rev. I, Portage, Inc., Idaho Falls, Idaho, July 31, 2015.

PM-2.5 =particulate matter, 2.5 g+/-. PM- 10 =particulate matter, 10 i.

1 of 58

NWMI-201 5-RAI-001 Rev. 0 IAIR-1B Section 19.4.2.1.2.5 of the ER states." "Emissions data shown in Table 19-63 ,/

,provide an estimate of vehicle emissions. Calculationsused to obtain the estimates are based on an average workforce of 25-5 0 vehicles/day using a specific vehicle ratio (60 percent light-duty autos, 30 percent light-duty gas, ftrwckg, andk2percen//igh/-dziy diese/trudi) andaroz/ndlripof 40 rni/day..."

.However, Table 19-6 lists that during operation the average workforce andpeak workforce will be 98. Explain why 25-5 0 vehicles/day were assumed during the The stated estimate assumed that employees will carpool, with two to three people per vehicle. To provide a more bounding evaluation, the calculation has been reanalyzed assuming that each individual will drive their own vehicle and that 100 vehicles are used. Table 19-63 has been revised and is presented below.

Table 19-63. Vehicle Emissions During Operations

-- I ll/

Light duty autos i Gas, 1,085 ;2,392

• 95 210 225,239 496,569 11 1 i 3 ,, 2 3is SLight duty trucks Gas 1,323 2,917 122 268 129,506 !285,513 2 i4 1 3 . 1 Light duty trucks Diesel 177 701 -6 -6 !13 Al T~otal... .. ... . .... 2,443 5,385 286 631 391,748 863,662 9 '21 9 ,19 4 9 Source: EDF-3 124-0013, On-Road Emissions for Vehicles During Operation, Rev. 1, Portage, Inc., Idaho Falls, Idaho, July 31, 2015.

PM-2.5 = particulate matter, 2.5 p.. PM-10 particulate matter, 10 p..

Table 19-64 has been revised and is presented to the right. Table 19-64 Expected Green House Gas Emissions from Radioisotope Production Facility Project SC.onstru)c.t ion p h ase on sit e ....... .. 44 ,000... i 97,000 Construction phase offsite i610,000 1,330,000i Normal plant operations (per year) I23,000,000 51d0*00 00 Operations on-road vehicle travel I 392,000 864,000i l(per year)I Source: EDF-3124-0011, Greenhouse Gas Emissions, Rev. 1, Portage, Inc., Idaho Falls, Idaho, July 31, 2015.

2 of 58

SNW MI NWMI-2015-~-0Rv

-. WUE . . . IPE IAIR-I1C Scin19.4.2.1.2.5 of the ER states "During the operationsphase, vehicular air .

• emissions would resultfrom the commuting workforce andfrom routine deliveries

to andfrom the proposedRPF." Table 19-6 of the ER provides an estimate of ,!

vehicle emissions. Clarify if Table 19-6 emissions accountfor both commuting *t

_workforee andjfrom routine deliveries to/from the RPF....

Table 19-63 has been revised to reflect 100 vehicles a day. This number includes both workforce commuters and routine deliveries to the Northwest Medical Isotopes, LLC (NWMI) Radioisotope Production Faction (RPF). The revised Table 19-63 is provided in the AIR-lB response.

AIR-1D "Table 19-56 of the ER identifies 100 for workforce travel du~ing thee cons truction ;-*

S phase. However, Table 19-6 identifies a peak workforce o,/82 aduriingcorns/ruc//on¢.

C/r, h I2 wr, wervl a sdnTable 19-6. ... . _

The peak workforce is assumed to be 82 during construction, with an average workforce assumed to be

38. By estimating the mileage for 100 vehicles, the calculation bounded any potential emissions, including those by other service providers such as for routine deliveries. Table 19-63 accounts for the commutinlg workforce and routine deliveries to/from the RPF. The revised Table 19-63 is provided in the AIR-lB response.

AIR-I1E Table 19-59 of the ER consideredfugitiv~e dust, windblown dust, and emissions  ; VZ? "

from off-road construction equipment from constructiOnpresented in Tables 19-5 5 <

'and 19-58. However, the total amountpresented in Table 19-59 does not equate * .

=to the sum fromTables 19-55 and 19-58. Clarify the differences in these values. *_

The values in Tables 19-55 and 19-58 represent the results of the calculations documented in each referenced engineering design file and are rounded to the appropriate number of significant figures.

Table 19-59 has been revised to the summation of values presented in Table 19-55 and 19-58 and is presented below.

3 of 58

NWMI-201 5-RAI-001

":=,..%=:" No*mwes'raeocat soToP*

Rev. 0 Table 19-59. Anticipated Gaseous Effluents and Their Associated Air Quality Parameters for Construction PM-10 1,503 3,226 2.91 g.g/m , 1.20 j*tglm a150 gig/m 3 r iM_2.5 304.* " *674 61 gtg/mn33.. 25 . gtg/m 3 ' b3 5 jig/mn3 NOx j 647.1 ,430 68ppb i 28ppb clO100ppb S CO- 9P'5 2 20* 0.Olppm .. 006 P~ 35 ppm '

SOx i 107 236 0.008 ppm 0.003 ppm e0.075 ppm Source: EDF-3124-0014 rev-01, Emission Modelingfor ConstructionActivities using AERSCREEN, Rev. 0, Portage, Inc.,

Idaho Falls, Idaho, July 30, 2015.

a24-hr, not to be exceeded more than once per year on average over three years.

b 24-hr, 9 8 th percentile, averaged over three years.

e1-hr, 9 8th percentile, averaged over three years.

d 8-hr, not to be exceeded more than once per year.

l -hr, 99th percentile of 1-hr daily maximum concentrations, averaged over three years.

AIR-IF Tablethe S from 19-61 fourand Table natural 19-62 gas of the boilers. ER present Hourly total annual and annual and hourly emissiions, however, emissions from *V thesetwo tables do not match. Clarify. andprovide the correct annual and hourly "* ,'

t~otal emissionsfrom the gas-firedboilers. ..... J Table 19-6 1 contained several errors on conversion of pounds (lb)/hour (hr) to Tables 19-61. Natural Gas-Fired Boiler Total Annual Emissions kilogram (kg)/hr. The second and third column headers were mislabeled in Table 19-62. Table 19-6 1 and 19-62 have been revised and are presented below.

4.2

.... ..... . ...

• 16 i 18 1.9 1

!NOX 10 11 o1.13 PM (total) {0.36 1.6 0.18 0.39 jNHC(voo) 1.1 12 0.23 So 2 * -- 01..

A2- 0.13 0.0....O 15--*

• I c0 2 ..24,000-- 26,000 2722 2, 6,000 Source: EDF-3 124-0008, Emissionsfrom Natural Gas-FiredJBoiler Operation, Rev. 0A, Portage, Inc., Idaho Falls, Idaho, June 26, 2014.

NHC = n-hydrocarbon.

PM = particulate matter.

VOC = volatile organic compound.

4 of 58

NWMI NWM[-201 5-RAI-00Re.i Tables 19-62. AERSCREEN Model Total Annual Emissions CO I 4"2E+00 __ 18  ! 72E+01 !4.6E+01 i4.0E+04 NO 25E001 4.E0 2.7E+01 1.9E+02]

PM-10 (total)c , 3.9E-01 1.6 . 6..... +/-00 4.E00g 5 jPM-10 (filterable)d9.8E-02 0.40 1.6E+/-00 ,1.0E+00 g3 5 VOCe 2.8E-01J 1.2  ! -  ! -

. SO2 3.0E-02 0.13 - 4.7+01 E +00 +0 197E+021 CO2 -- 6"0E+03 " 26,000 i 5. 1E-01i! 3.3E-01 NA Source

EDF-3 124-0012, Emission Modelingfor Process and HVAC Boilers Using AERSCREEN, Rev. 1, Portage, Inc.,

Idaho Falls, Idaho, February 4, 2015.

aThe stack effluent maximum concentration was determined to be at 136 meters (in) (446 feet [ft]).

b Based on 50 weeks/year.

SUsed as PM-10 values.

d Assumed to represent PM-2.5.

No NAAQS for volatile organic compounds.

rNo NAAQS for carbon dioxide.

g 24-hr standard for PM-10 and PM-2.5 NA =not applicable. PM-10 = particulate matter, 10 I..

NAAQS = National Ambient Air Quality Standards. VOC = volatile organic compound.

PM-2.5 = particulate matter, 2.5 ft.

'*AIR-1 G Section 19.4.2.1.1l of the ER identifies batch plant operations as a source of 1$"

S fugitive dust. Clarify ifa batch plant will be onsite and if emissionsfrom batch  :

plant operations are accountedfor in Section 19.4.2.1.1 of the ER.

The batch plant in assumed to be offsite. The two references to the batch plant being onsite were removed from Section 19.4.2.1.1. Emissions from the batch plant are not included in Section 19.4.2.1.1.

The closest batch plant from the RPF is Columbia Ready Mix located at 2600 N. Stadium Drive, Columbia, Missouri. Columbia Ready Mix is 7.6 kilometer (kin) (4.7 mile [mil) from the RPF. The delivery of the concrete to the RPF site is included in our emission estimates in Table 19-57.

5 of 58

NW iNWM, -20 5-RAI00OevI AIR-2A Section 19.2.3.1.2 of the ER states: "The offgas containing the fission product gases goes through a series of cleanup columns. The nitrogen oxides (NOx) is fI'l v" removed by a reflux condenser and several NOx absorbers, the fission product gases (noble and iodine) are captured on absorbers, and the remaininggas is filtered and discharged into the process ventilation header." Table 19-86 of the ER states "The RPF would emit minor emissions of NOx and CO2 along with levels of radionuclides below 10 CFR 20 levels. "Furthermore, Section 19.4.2.1.2.3 of the ER, states. "Gaseous effluents resultingfrom the production process are based on a 50-week/year operatingschedule. There are no emissions of CO, Pb, 03, or particulatematterfrom the process exhaust system. " However, Section 19.4.2.1.2.3 does not discuss NON, S02, or CO2 emissions or quantify the amount of NOx, SO2, or CO2 emitted resultingfrom the RPF production process. Clarify ifNOx, 502, or CO2 would be emitted during the production process. If so, provide NO., SO 2, and CO2 emissions resulting from... .. ..

o m.the.production.process........ ....... ....... .... ....... ... ... . ...

Primary process system reactions do not generate quantities of carbon dioxide (CO2) or sulfur dioxide (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 (N 2 0), C0 2 , carbon monoxide (CO), and hydrogen gas (H2) at concentrations that are approximately 0.1 percent of the total nitrogen oxides (NOx) (NO + NO 2) generated. The 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 SO2 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. The estimate of NOx, generation from dissolution is 582.5 kg NOx,/year (yr) as nitrogen dioxide (NO2), and the bounding stack emission is 42.64 kg NOx,/yr as NO 2 .

The third paragraph in Chapter 19.0, Section 19.4.2.1.2.3 has been revised and is provided below.

Each process offgas subsystem would treat the process offgas components separately to prevent mixing of waste constituents (additional information is provided in Section 19.2.3.2.12). Gaseous effluents resulting from the production process are based on a 50-week/yr operating schedule. There are no emissions of CO, lead (Pb), ozone (03), or particulate matter (PM) from the process exhaust system. The bounding stack emission estimate of NOx, is 42.64 kg NO,,yr as NO2 . Iodine fission products would be removed using absorption methods. Fission product gases such as xenon and krypton would be removed using decay beds.

6 of 58

NWMI-201 5-RAI-001 NWMI amwesrEDICA]. PEE Rev. 0 IAIR-2B Section 19.4.2.2.4 of the ER states that emission-specific strategies would be developed and implemented to ensure compliance with NAAQS andNESHAP ill' v standards. However, the ER does not quantify the hazardous airpollutants emitted resultingfrom operations. Identijfy sources of hazardous airpollutants (HAPs), quantify HAP emissionsfrom these sources during construction, operation, and decommissioning, andprovide supporting calculations.

The RPF will mitigate any hazardous air pollutants (HAP) to meet standards/release limits. The oniy source of HAPs identified is trichloroethylene (TCE), which is used in the target fabrication system during low-enriched uranium (LEU) target material washing. Spent TCE recovery is described in Chapter 4.0, Section 4.4.2.8.1, and Table 4-75 estimates the RPF inventory at 53 gallons (gal). The TCE systems will be designed to meet Title 40, Code of FederalRegulations, Part 61 (40 CFR 61), "National Emission Standards for Hazardous Air Pollutants" (NESHAP) standards and be significantly less than the Missouri de minimis level for total volatile organic compounds (VOC) of 40 tons/year.

AIR-2C Provide the following ER referencesfor review:" V

• EDF-3124-O011, Greenhouse Gas Emissions, Rev. 0, Portage, Inc., Idaho Falls, Idaho, June 26, 2014.

• EDF-3124-O008, Emissionsfrom Natural Gas Boiler Operation, Rev. 0, Portage,Inc., Idaho Falls, Idaho, June 26, 2014

• EDF-3124-O012, Emission Modelingfor Process andHVA C Boilers Using AERSCREEN, Rev. 1, Portage,Inc., Idaho Falls, Idaho, February 4, 2015.

• EDF-3124-O013, On-Road Emissionsfor Vehicles During Operation, Rev. 0, Portage,Inc., Idaho Falls, Idaho, June 26, 2014.

The reference documents listed above (or most current revisions of those documents) are aftached in Appendix A, B, C, and D, respectively.

AIR-3 The ISG augmenting NUREG-1537, Part]1,Section 19.1.2, "Regulatory V"

• Provisions,Permits, andRequired Consultations,"'and10 CFR 51.45(d) state that an applicantshould list and summarize the status of all applicable Federal, State, local, and other regulatory requirements,permits, and consultations that would be requiredfor the proposedfacility to be constructed and operated

• Table 19-4 in the ER identifies that construction and operatingairperm its from the Missouri Departnent of NaturalResources (MDNR) are not required Has NWMI contacted MDNR regarding the determination that air emission sources will be exempt from permitting requirements and has MDNR confirmed that air permits will not be required? If so, provide documents (e.g., letters) of such communication. Otherwise, indicate the applicant'~splans and associated ti..

.. .e..

.e.. .. . ... .. .. . . .. . . . . . . .. . . .. .. .. . . .. .. .. . . .. .. . . . . .. . . ..-.

NWMI made the determination that air permits from the Missouri Department of Natural Resources (MDNR) are not required for the construction and operation based on MDNR's published regulations.

However, NMWI anticipates contacting MDNR with a specific request by March 2016.

7 of 58

• • MII M fNW NWMI-201 5-RA,-001ov0

.lii ..

SALT-I The ISG augmenting NUREG-153 7, Part]1,Section 19.].], "Purposeand Need /"

for the Proposed Action, "states that the ER should describe how the proposed action would satisfy global, national, or regionalprojected demands for the radioisotopeproducts to beproduced through implementation of the proposed action. Section 19.5.] of the ER states that "ftjhe current demandfor 9 9mTc in the U.S. requires a weekly supply of approximately 6,000 six-day Ci of 99Mo, approximately 50 percent of the annual U.S. demand." This seems contradictory.

Is 6,000 six-day Ci of 99 Mo the current demand or 50% of the demand?

Historically, the U.S. demand for molybdenum-99 (9 Mo) is 6,000 six-day curies (Ci), which is 50 percent of the world demand (NAS, 2009, Medical Isotopes Production Without Highly Enriched Uranium; and NEA, 2012, A Supply andDemand Update of the Molybdenum-99 Market). Currently, the world demand is estimated to be 10,000 six-day Cl/week with U.S. demand at 5,000 six-day Ci per week (NEA, 2015, The Supply of Medical Isotopes -2015 Medical Isotope Supply Review." 99 Mo/°gmTc Market Demand and Production Capacity Projection 2015-2020). Section 19.5.1 was modified to state the following: "The current demand for 99mTc in the U.S. requires a weekly supply of approximately 5,000 to 6,000 six-day Ci of 99Mo, approximately 50 percent of the world demand."

• ALT-2A Make availablefor docketing the Alternative Site Selection presentationgiven at  :

the site audit.

The NWMI Site Alternative Study presentation given at the site audit is attached in Appendix E.

,ALT-2B Section 19.5.2.2 of the ER identifies available space as a screening criterion and V"

• states that all sites have the minimum amount of space requiredfor the production

• facility, but differences in available space could impact the complexity of facility design. Discuss the space limitations at the MURR, Oregon State UniversityI If the RPF were to be constructed and operated near one of the university reactors, the complexity and cost of the facility is anticipated to increase compared to the Discovery Ridge Research Park (Discovery Ridge) site. All of the sites next to university reactors have the minimum amount of space required to construct and operate an RIPF. However, all sites had less than half of the space available at Discovery Ridge. Space availability near each of the university reactors is limited due to existing structures and space allocation by the owners of the sites. The differences in available space between the sites near university reactors and Discovery Ridge are anticipated to lead to increased intricacies of the facility design, which leads to operational complexities (e.g., hot cell processing, facility deliveries, personnel movement),

increase in construction (e.g., greenfield construction verses construction within existing infrastructure) costs, and limits the ability to expand the.R~PF inthe future (e~e.g., education, _rese~archand development)...

!ALT-3A The ISG augmenting NUREG-1537, Part 1, Section 19.5 "Alternatives, "states - ,t ti thatfor each reasonable alternativesite, a description should be provided In the lI ER. Provide the following figures pertainingto the MURR alternative site.,

S Radioisotope ProductionFacility site boundary at the MURR alternative site*

S (similar to what was providedfor the Discovery Ridge Site in Figure 19-6 of the The requested figure of the University of Missouri Research Reactor (MURR) site is provided on the following page.

8 of 58

N WM 1-201 5-RAI-001

.o NWM%.

111//l ie'wln-$TusO:A., w!

Rev. 0 RPF FaOliyAI 3 ki RPF Ske E MURR Site O* 8 lun (5 mile) Radius fraom RPF Site

• ]MURR Fence -m= Inters tate

-.- Highwys

,iCity Limits 0 0.03 0.06 0.12 0.18 0.24s Miles 9 of 58

NWMI-2015-RAI-001

""... ".r'atMC,* rIDP IW Rev. 0 The requested figure of the 8 km (5-mi) radius from the MURR site is provided below.

• ]MURR Site ra=Interstate Highways

-Highways 08 km (5 mile) Racjus from MURR Site (? City Limits o 0.5 1 2 3 4 i i Mdes 10 of 58

NW.MlI~f

• ";.;" EIV os.,, tIV. I eNWMI-2o01 5-RAI-O01ev0 Rev.

gggg CON-I 10 CFR 51.45(e and the ISG augmenting NUREG-153 7, Part]1, Section 19.6, v" "Conclusions" state that the ER should include a discussion on the unavoidable adverse environmental impacts of the proposed action. Section 19.6.] states that

"[i'fthe site is returned to its current state, there would be no unavoidable adverse environmental impacts associatedwith the proposedaction." Yet, Sections 19. 6.1.1] and 19.6.1.2 determines SMALL unavoidable impacts to construction and operation. Unavoidable impacts are, by definition, not avoided simply through decommissioning. Unavoidable adverse impacts are predicted adverse environmental impacts that cannot be avoided and that have no practical.

means offlhrther mitigation. Clarify how there can be "no unavoidable adverse environmental impacts" as statedin the headerSection 19.6.1 of the ER andyet there are such impacts, albeit small ones, as discussed in Subsections 19. 6.1.1 and.

19.6.1.2 of the ER. Further, reconcile the statement in Section 19.6.1 with the statements in Section 19.6.2.1 and 19.6.2.2 that "[siome small adverse environmental impacts could remain after allpracticalmeasures to avoid or mitigate them are taken."

The unavoidable impacts defined in Sections 19.6.1.1 and 19.6.1.2 are "unavoidable" during both the construction and operating phases of the RPF. The impacts may include air emissions and land use changes and are defined in Table 19-92. Transient unavoidable impacts (e.g., air emissions) will cease after the RPF is decommissioned. Unavoidable impacts (e.g. impacts to land use) would be mitigated once the RPF has been decommissioned and the site is returned the current state. The first paragraph, fourth sentence of Section 19.6.1 has been revised to read as follows: "If the site is returned to its current state, no unavoidable impacts are expected to remain."

11 of 58

NWMI NWg-0g5RIg0 CONN- Describe a hypothetical third research reactorthat is representativeof the 1A.1 research reactors.NWMI is considering. Include the following environmental I'll 1' parameters:"

A description of necessary or anticipatedmodifications at the reactor to support target irradiation.Identify."

If modifications would be internal or external to the existing structures and if/there would be any associatedground-disturbingactivities (quantify acreage affected)

No external or internal modifications would be required to the hypothetical third reactor. Three equipment refurbishments and/or needs have been identified for the hypothetical third reactor to handle both unirradiated and irradiated LEU targets. These equipment refurbishments and/or needs include:

• Equipment refurbishments

- Refurbish an existing overhead crane (e.g., replacement of contactors, motor brushes, etc.). Any modification will follow the process described in 10 CFR 50.59, "Changes, Tests, and Experiments," for making changes to a facility.

• Equipment needs

- Design and build an intermediate target transfer cask to transfer irradiated targets from the primary reactor tank to a Type B transport cask. This cask will be similar, both physically and functionally, to the current TRIGA single-element transfer cask that is routinely used for fuel movements at TRIGA-fueled facilities worldwide.

- Design and build an unirradiated LEU target storage rack. The storage rack is anticipated to be a metal box with two holding plates containing guide tubes in a grid pattern necessary to maintain a geometrically safe criticality configuration.

These potential activities are anticipated to be internal to existing structures and will not require ground-disturbing activities.

SCONN- Additional workforce needed to support modifications /"

I1A.2 The additional workforce needed to support modifications or equipment needs will be temporary for the hypothetical third reactor. The refurbishment of the overhead crane will be performed by subcontracted personnel with supervision by reactor personnel. The fabrication of the transfer cask and unirradiated LEU target storage rack will be outsourced to a qualified mechanical fabrication vendor.

CO-NN- Depth *o'f ex-cavat-ion e-xpec'ted t-o be r-equ~ire'dfor-n-w/mod-fiqedfacilitiesandutility ..... V1.........

I A.3 connections No new/modified facilities or utility connections will be required for the hypothetical third reactor. Thus, ground-disturbing activities that require excavation are not required.

iC0N-NDrto fatiiist opet olain and to comsso he mo-diid .. ...... >...

_IA -4 __fa~cilities and equ__i me~nt.. . .. . . . .. .. .. .. . . ... .. . . .. . ... .. . . .... . .

The equipment modifications or fabrication of required equipment at an off-site vendor is anticipated to take two months to complete at the hypothetical third reactor.

12 of 58

• ~.* IU~AIflfl

• NWMI-201 5-RAI-O01 I~Ivv IVi N Rev. 0

-N .N .N NI'gllg SCONN- Any additionalnoise, traffic, or air emissionsfrom facility modification activities V" The transport of the fabricated unirradiated LEU storage racks and transfer cask will result in a single delivery for each when completed. The increase in traffic due to the crane modifications will involve a commute to the third reactor facility by one vehicle for a short duration (e.g., less than two weeks). This volume of traffic is considered within the normal traffic patterns expected at the third reactor. Due to minimal traffic and no ground-disturbing activities at the hypothetical reactor, there will be no appreciable increase in either noise or traffic.

CON N- Land-use classification of the thirdreactor V" 1B Land use is a general indication of how land is used--residential, commercial, industrial, open space, etc.

Land use defines broad categories; zoning is used to implement land use plans. These plans can be developed by a number of entities such as universities, cities, counties, regions, or states.

The land use for the hypothetical third reactor is anticipated to be similar to both MURR and Oregon State University (OSU) TRIGA Reactor (OSTR). Thus, the land use will be a university-planned district area that will have a mixed use.

,CON N- Additional workforce needed to support operation activitiesfor irradiatingtargets V

. I C.. . . . . . . . . . . . . . . . . . .. . . . . . . . .. . .. . . .. . . . . . .. . . . . . . . . . . . .. . . . . . . . .

For the hypothetical third reactor, an increase in staff is expected and is anticipated to be similar to OSTR. The operational tempo is anticipated to increase from a nominal 40-hr work week irradiation schedule to 24/7 operations on a weekly basis when commercial LEU target irradiation services are being provided by the hypothetical third reactor. The anticipated required staff of the hypothetical third reactor will comprise four Senior Reactor Operators (SRO) and three Reactor Operators (RO). At least four additional SRO and six additional RO positions are assumed to be required to oversee and manage the increase in operational tempo. The university setting offers flexibility in hiring; thus, additional staff will likely be drawn from the existing university population.

CON N- Identify if target handling and irradiationwill result in changes in the types or V" 1ID increases in the non-radiologicaleffluent releases and waste streams at the reactor.Provide sources, types, and approximate quantities of non-radiological effluents or waste and discuss non-radiologicalwaste management impacts of J target handling and irradiation.

No anticipated changes in the sources, types, and quantities of nonradiological effluent releases and waste streams are expected from the handling of unirradiated or irradiated LEU targets at the hypothetical third reactor.

SCON N- Additional water use to complete modifications and to support operation activities.............. V........t I 1E for irradiatingtargets (as compared to existing operations)

No additional water use to complete modifications and to support operation activities for irradiation targets is anticipated at the hypothetical third reactor.

13 of 58

• ~NWMI NWM[-201 5-RAI-001

. ... . . ii iCON I1F N- Discuss handlingthe andstorage and treatment irradiation of non-radioactivemateraialfrom target at the reactor.  : V, No additional nonradioactive material is anticipated to be generated other than the manufacture of an unirradiated LEU target storage rack. Built entirely of stainless steel, these racks are anticipated to be square, lockable containers with rack locations (i.e., guide tubes) for the unirradiated LEU targets.

Approval for the geometry, design, and construction will be promulgated through a license amendment request by the hypothetical third reactor.

CONN- Discuss human health impacts due to target handling and irradiation. 9' 1 I G.I Specifically, address the following:"

Provide a list of reporting requirementsfor non-radioactivewaste streams to the" Environmental ProtectionAgency (EPA) applicablestate agencies.

At the hypothetical third reactor, reporting of nonradioactive hazardous waste streams will be required annually to the appropriate state agency. The hazardous wastes that require reporting include the hazardous waste listing and descriptions in 40 CFR 261, "Identification and Listing of Hazardous Waste." Other non-hazardous waste streams are unlikely to have reporting requirements.

'CON N- Provide a copy of or discuss the procedure that workers would use for identifying 9"  !

I 1G.2 industrial hazardsprior to performance ofiobs.

The hypothetical third reactor located within a university environment will have a Safety Policies and Procedures Manual (or equivalent) that will provide guidelines and information for employees about programs and services provided by Environmental Health & Safety (EH&S) (or equivalent). The policies and procedures included in this manual will reflect requirements, standards, and statutory and regulatory mandates established at the Federal, State, and local level for occupational and environmental safety and health. Program areas covered and services provided by EH&S will include the following:

• Audits and inspections: Responsible for facility audits, including all campus and off-campus laboratories, classrooms, facility operations, research and experiment stations, and extension centers.

• Biosafety: Responsible for biosafety implementation, control of select agents, compliance with Federal and State regulations, assistance with granting agency compliance and animal welfare, and research and teaching support for the campus and off-campus facilities.

• Chemical safety: Responsible for chemical safety, use, and management, and compliance with Federal, State, and local regulations for the campus and off-campus facilities.

• Construction and plan review: Responsible for construction safety, design criteria development, and plan review for EH&S design requirements related to capital and remodel projects for the campus and off-campus facilities.

° Emergency response and on-call service: Responsible for emergency and non-emergency response to hazardous substance spills and customer concerns for unsafe conditions for the campus, and providing assistance to the campus during other natural emergencies.

0 Environmental protection: Responsible for air, water, and soil resource protection; monitoring; and permitting for the campus and off-campus facilities.

• Fire and life safety: Responsible for fire and life safety prevention and inspections for campus facilities.

14 of 58

N .205=A-0Rev. 0

-N .N .*

Nii

• Hazardous waste and shipping: Responsible for hazardous waste management and shipping of dangerous goods and samples for the campus and off-campus facilities.

• Industrial hygiene: Responsible for industrial hygiene monitoring and employee protection for the campus and off-campus facilities.

• Lead and asbestos: Responsible for identification and management of lead and asbestos-containing materials for the campus and off-campus facilities.

• Occupational safety: Responsible for occupational safety evaluations, consultations, and OSHA compliance for the campus and off-campus facilities.

• Public health: Responsible for implementation, monitoring, and permitting of water systems and sewage disposal systems; pesticide safety; and vectors, housing units, and other areas regulated by health departments for the campus and off-campus facilities.

• Radiation safety: Responsible for the regulation of ionizing and non-ionizing sources of radiation, compliance with the university's broad scope license and Federal and State regulations, and laser safety for research and teaching operations for the campus and off-campus facilities.

• Training outreach: Responsible for creating and delivering training outreach materials to faculty and staff, including training record tracking and training certificate issuance for the campus and off-campus facilities.

CONN- Provide a copy of or discuss the anticifpatedemergency response plan. *V" Possessing and maintaining an emergency response plan is a requirement of any university research reactor facility license. The hypothetical third reactor emergency plan will follow the guidance found in NUREG- 1537, Guidelinesfor Preparingand Reviewing Applicationsfor the Licensing of Non-Power Reactors, and ANSI/ANS 15.16, Emergency Planningfor Research Reactors, as endorsed in Regulatory Guide 2.6, Emergency Planningfor Research and Test Reactors.

iCONN- Provide a copy of or discuss the anticipatedrecycling and reuse plan. .............. V'.......

! 1G.4 ------------------- - -- - -

The hypothetical third reactor will follow the policies and procedures of the university organization assigned the responsibility. The hypothetical university recycling programs will provide information on the types of materials acceptable for recycling (e.g., paper, plastics, metals, glass, batteries, compost, electronic media, ink/toner cartridges, packing peanuts, wood, Styrofoam, comingling limits, etc.), provide containers specific to the materials of interest, and provide pick-up and delivery services scheduling.

TiCON N- Distance travelled of targets to andfrom the reactor. /"

1H The distance travelled of targets to and from the reactor will be bounded by the discussion of the hypothetical third reactor described in Section 19.4.10.1.2 of the Construction Permit Application.

15 of 58

RhlWfSMIftA NWM-215-AI00Rev. 0 CON N- Identify if target handling and irradiationwill result in changes in the types or ii.g V" i1 inzcreasesi'z the radsologi'a/eij/uent re/eases andwaste streamsat/lie reacto;:

Provide sources, types, and approximate quantities of radiologicaleffluents or waste and discuss radiologicalwaste management impacts of target handling and irradiation.Discuss any expected radiologicalimpacts to the workers at those facilitiesdue to those expected changes. Discuss any expectedradfo/ogic'a/impacts from....

t**ran]sporttion._a deto the shipment to..andfrpmtereact!or:..................

The amount of radioactive solid waste that would be generated from the hypothetical third reactor as a result of handling and irradiating LEU targets is not anticipated to increase significantly, as the targets will be minimally handled with little or no potential for contamination. The majority of the waste generated would be solid dry wastes (e.g., paper, gloves, and absorbent materials) from handling the targets on receipt at the reactor. After irradiation, the targets will be moved from the reactor core and into the intermediate transfer cask underwater in the primary tank. Estimates of the added amount of dry-solid-compactable radioactive wastes at the hypothetical third reactor is 0.11 to 0.17 cubic meters (in 3 ) (4 to 6 cubic feet [ft3]) annually. No liquid radioactive waste is anticipated to be generated from these activities.

With respect to gaseous emissions, no gaseous emissions are expected from the LEU targets themselves but gaseous releases from the operation of the hypothetical third reactor may change depending on how the facility is operated. For the hypothetical third reactor, the average amount of gaseous emissions will increase. The only isotope normally measured and emitted from a research reactor is argon-4 1 (4 1Ar).

The hypothetical third reactor will have a limit on the annual average effluent concentration in their technical specifications to ensure that the concentration of 41Ar in the unrestricted areas will be below the applicable effluent concentration value in 10 CFR 20, "Standards for Protection Against Radiation,"

Appendix B, Table 2, assuming continuous discharge. This technical specification will likely be based on the guidance provided in Regulatory Guide 4.20, Constraint on Releases of Airborne Radioactive Materials to the Environmentfor Licensees Other Than Power Reactors. Conservatively assuming that the hypothetical third reactor increases its operational tempo from 10 full power hours a week to 24/7/365 operations, the total activity released could increase by a factor of 16.8 (168/10 --16.8 weekly).

Although the total amount of 41Ar may increase from the increased operating tempo, the concentration will remain the same.

The handling of both unirradiated and irradiated LEU targets is not anticipated to significantly increase the occupational doses at the hypothetical third reactor. Based on information obtained from TRIGA-fueled reactors that have gone through highly enriched uranium (HEU)-to-LEU fuel conversion in the past eight years, the receipt of fresh LEU TRIGA fuel may be indicative of what should be expected for unirradiated LEU targets. The fuel received for conversions was 20 percent enriched and 30 weight percent (wt%) standard TRIGA fuel containing a nominal uranium mass of 820 grams (g) within a stainless-steel clad cylinder with outer dimensions similar to the proposed targets. Typical dose equivalent rate readings on contact and at 0.3 m (1 ft) were 0.1 to 0.3 and 0 millirem (mrem)/hr, respectively. No measurable dose equivalent rate at 0.3 m (1 ft) from a fully loaded storage container was observed. Due to this, no appreciable increase in the occupational dose equivalent is expected from the handling of the proposed unirradiated LEU targets at the hypothetical third reactor. Additionally, no appreciable increase in dose to the general public is expected from handling the unirradiated LEU targets due primarily to the very low-dose equivalent rates observed with the unirradiated LEU TRIGA fuel

=handli~ng and a lack of proximity of the general public to the targets. __

16 of 58

.A* .,:It"IUWMI~

N VEr, VExz. I*soo NWMI-201 5-RAI-001Rv0

. .. .. g.li The occupational doses from handling irradiated targets are not anticipated to significantly increase at the hypothetical third reactor. All research reactors have procedures for handling fuel elements and have established radiation protection and ALARA (as low as reasonably achievable) programs. A shielded transfer cask will be used to remove irradiated targets from the reactor and load them into the shipping cask. While some increase will be observed, due to the very nature of handling radioactive material, the dose increase will not be significant due to the established programs and handling experience.

The quantity, type, and packaging associated with transport of radioactive materials are discussed in Section 19.2.8.2. The radiological impacts from shipment to and from the hypothetical third reactor are discussed in Section 19.4.10.

CON N-21/n support ofaayigthe Site-specific environmental impacts associatedwith the  :

connected actions, identify if target handlingand irradiationwill result in changes -

in the types or increases in the non-radiologicaleffluent releases and waste

,streams at the two identified research'reactors (MURR and OSTR]). Provide sources, 'types, and approximate quantities of non-radiologicaleffluents or waste iand discuss non-.radiologicalwaste management impacts of target handling and

,irradiationat MURR and OSTR.

No anticipated changes in the sources, types, and quantities of nonradiological effluent releases and waste streams are expected from the handling of the unirradiated or irradiated LEU targets at MURR or OSTR.

'CON N-3 In support of analyzing the site-specifjic environmental impacts associatedwith the i. V connected action of irradiationservices, discuss the storage and treatment of non-S radioactivematerialfrom target handling and irradiationat MURR and OSTR.-

No additional nonradioactive material is expected to be generated other than the manufacture of an unirradiated target storage rack. Composed entirely of stainless steel, these racks are anticipated to be square, lockable containers with rack locations (i.e., guide tubes) for the unirradiated LEU targets.

Approval for the geometry, design, and construction will be promulgated through license amendments for each of the reactor facilities.

CON N- Discuss human health impacts due to the connected actions of target handling and V"*

4.A irradiationat MURR and OSTR. Specifically, for MU]?] and OSTR], address the

!following." no-aiaciewst temst P

,Providea list of reporting requirementsfor nnrdociewsesrast P

____ applicable state agencies. .... _

At the OSTR, OSU is required to annually report the amount by volume of all hazardous wastes generated and disposed of to the Oregon Department of Environmental Quality. The hazardous wastes that require reporting include the hazardous waste listing and descriptions in 40 CER 261. Additionally, Oregon Administrative Rule (OAR) 340-101-0033, "Additional Hazardous Wastes," lists wastes that are state of Oregon-only hazardous waste and must be reported. These wastes include pesticides residues and mixtures of wastes containing constituents of Federal P (3 percent) and U (10 percent) listed wastes.

At MURR, the University of Missouri (MU) is required to complete a quarterly Generator's Hazardous Waste Summary Report. This report lists the quantity, type, and status of all 10 CFR 261 listed and described hazardous wastes shipped offsite during the reporting period.

17 of 58

flh:fNWMI UU t SOeEV

.t"Nsmz4EU NWM,-201 5-RAI-001ev0 N .***. . iii C ON N- Provide a copytoof the procedure that woirkers would usefor'identifting industrial ,//

V

!4.B hazards prior performance ofjobs.

• i '

At the OSTR, identifying industrial hazards prior to performance of jobs falls under the requirements of occupational health and safety policies and procedures administered by OSU Enterprise Risk Services.

The OSU Safety Policies and Procedures Manual is provided at http://fa.oregonstate.edu/saf-manual.

Industrial and laboratory safety instructions are numerous and are provided online at http ://oregonstate.edu/ehs/safety-instructions.

At MURR, identifying industrial hazards prior to performance of jobs falls under the requirements of occupational health and safety policies and procedures administered by the MU Department of Health and Safety. The manual governing the policies and procedures is provided in the MU Business Policy and ProcedureManual available at http ://bppm.missouri.edu/.

SCON N- Provide a copy of the emergency responseplanfor each reactor.  :" <  !,

A copy of the OSTR emergency response plan is provided in Appendix F. A copy of the MURR emergency response plan is provided in Appendix G.

CON N- Provide a copy of the recycling and reuse planfor eah/eato.

• At OSTR, recycling and reuse is governed by university policies and procedures administered by Campus Recycling, reporting to the Finance and Administration-Business Affairs Office. This service is managed online at www.recycle.oregonstate.edu.

At MURR, recycling and reuse are governed by university policies and procedures administered by the Sustainability Office, and are managed online at http://sustainahility'missouri~edu/topics/recycling'html" Information related to a third reactor cannot be supplied at this time, as the reactor has not yet been selected. The answer to this question for the third reactor is anticipated to be similar to that for OSTR.

ICONN-5 :In support of analyzing of thel environmental impacts associated ..................

with the "...... ....... /

connected actions, identfif if target handlingand irradiationwill result in changes: i Sin the types or increases in the radiologicaleffluent releases and waste streams at.

the two identifed reactors (MURR and OSTR). Provide sources, types, and i

.*approximate quantities of radiologicaleffluents or waste and discuss radiological "*

'waste management impacts of targethandling and irradiation*at the two identified" reactors. Discuss any expected radiologicalimpacts to the workers at those facilities due to those expected changes. Discuss any expected radiological Iimpacts from transportationdue to the shipment to andfrom the two .identified reactors. s .

As stated in Sections 19.4.13.3.1, 19.4.13.3.2, and 19.4.13.3.3, the solid waste stream will minimally increase, and the liquid waste streams will likely not be affected as a result of handling both the unirradiated and irradiated LEU targets.

With respect to gaseous emissions, no gaseous emissions are expected from the targets, but gaseous releases from the operation of the reactor may change depending on how the facility is operated. At MURR, there will be no expected increase in gaseous emissions because the operating tempo of the reactor will not change. At OSTR, the average amount of gaseous emissions will increase.

18 of 58

WMI W-0 -A-0

-.- .U Si g.S i The only isotope ever measured and emitted at OSTR is 4 1Ar. As reported in annual reports required by the facility technical specifications, the typical annual concentrations at the point of release from OSTR is approximately 5.2E-3 becquerel (Bq)/milliliter (mL) (1 .4E-7 microcurie [iiCi]/mL), with a corresponding total annual radioactivity of approximately 7.4E1 1 Bq (20 Ci). Conservatively, assuming that the O STR runs 24/7/365, the total activity released could increase by a factor of 4.8 (168/3 5 =

4.8 weekly). However, although the total amount of 41Ar may increase from the increased operating tempo, the concentration will remain the same.

As stated in Sections 19.4.13.1.1.2 and 19.4.13.1.2.3, the handling of both unirradiated and irradiated targets should not significantly increase the occupational doses. Those sections describe historical fuel movement experience, how that is similar to moving targets, and the occupational doses incurred.

The quantity, type, and packaging associated with transport of radioactive materials are discussed in Section 19.2.8.2. The radiological impacts from transportation due to the shipment to and from the reactors are discussed in Section 19.4.10.

1 CONN, Section 19.4.13 of the ER identif/iesfacility modifcations at the two ident~iied ... /" ....

6A :reactors (MUJRR and OSTR) needed to support the handling and irradiationof targets. Provide the following information regardingfacility modifications and

' handlingand irradiationof targets:

'A.) Additional workforce needed to support modifications At MURR, all additional workforce needed to support modifications will be temporary. The fabrication of the storage racks and the transfer cask will likely be outs ourced to a qualified mechanical fabrication machine shop. The manufacture of the new reflector elements will be completed by existing MURR staff. Construction of a new airlock will involve an estimated four to six construction workers.

At OSU, all additional workforce needed to support modification will be temporary. The fabrication of the storage racks and the transfer cask will be outsourced to a qualified mechanical fabrication machine shop. The work on the overhead crane will likely be performed by one or two individuals contracted to perform the work.

CON N.. Additional workforce needed to support operation activitiesfor irradiatingtargets /

For MURR, no increase in facility staff is expected, as the handling and irradiation of the LEUJ targets will be consistent with existing expertise and workload.

For OSTR, an increase in staff is expected to provide commercial irradiation services. The operational tempo is anticipated to increase from a nominal 40-hr work week irradiation schedule to 24/7 operations on a weekly basis when commercial LEU target irradiation services are being provided. The anticipated required staff for OSTR will comprise four SROs and three ROs. At least four additional SRO and six additional RO positions are assumed to be required to oversee and manage the increase in operational tempo. The university setting offers flexibility in hiring; thus, additional staff will likely be drawn from the existing university population.

19 of 58

I@IVIV I ,205R-0Rev. 0

. .. .- gglii iCON i6C N- facilities Durationandof activities to complete modifications equipment.. . and to commission the modified- iVi " i The equipment modifications or fabrication of required equipment at an off-site vendor is anticipated to take two months to complete at both MURR and OSTR.

SCON N- Depth of excavation expected to be requiredfor new/modifiedfacilities and utility '¢ i6 connections No ground-disturbing activities are anticipated to occur at either MURR or OSTR as a result of handling and irradiation of targets at either reactor.

No new/modified facilities or utility connections will be required for either MURR or OSTR. Thus, ground-disturbing activities that require excavation are not required.

IONN- Additional water use to complete modifcations and to support operation activities

• 6E for irradiatingtargets (as compared to existing operations) *".

No additional water use to complete modifications and to support operation activities for irradiation targets is anticipated at either reactor.

SCN-Any additionalnoise, traffic, or air emissions from facility modification activities The transport of the fabricated unirradiated LEU storage racks and transfer cask to both MURR and OSTR will result in a single delivery for each when completed. Increase in traffic due to the crane modifications will involve commute to the third reactor facility by one vehicle for a short duration (e.g., less than two weeks). This volume of traffic is considered within the normal traffic patterns expected at MURR and OSTR. Due to minimal traffic and no ground-disturbing activities at the hypothetical reactor, there will be no appreciable increase in either noise or traffic.

VCONN- Would modifications be internal or external to the existing structures? If external

• 6G "modificationsare necessary, would there be any associatedground- disturbing activities? If so, quantfify the acreage and identify the nature of the areas that may be impacted. i All modifications and/or equipment refurbishments or needs would be internal to existing structures at both reactors.

20 of 58

4 -loev.RWIM-o 0

__HiuI SCl-I A JIdentify any theadditional state, county, and regionaldocuments that were reviewed ,/'"

9' (other than cited City of ColumbiaFY2013 CIP PlanningDocument) to Ii* develop Table 19-86. Provide associated URLs for this reference informatio~n and

! specifically identify for which of the listedtprojects each source provides  !

i* supporting information.,

In addition to the City of Columbia FY 2013 CIP Planning Document, the following documents were also reviewed:

• City of Columbia, 2008, 2030 CATSO Long Range TransportationPlan, City of Columbia Department of Planning and Development, http://www.gocolumbiamo.com/community-development/wp-content/uploads/sites/l14/2015/09/2030OTransportationPlanFinal.pdf, Columbia, Missouri, June 20, 2008

• Boone County Planning and Zoning Commission's meeting agendas for 2013, https://www.showmeboone.com/resourcemanagement/PZCommission/Agenda/PZAgenda.asp?YE AR=2013

• RS&H No. 226-1077-000, Columbia RegionalAirport (COU) Columbia, Missouri Draft EnvironmentalAssessment, City of Columbia and U.S. Department of Transportation - Federal Aviation Administration, http ://www.flycou.com/?page_idP=342, Columbia, Missouri, January 2012.

• City of Columbia, 201 2a, City of Columbia FY 2013 CIP PlanningDocument, https ://www.gocolumbiamo.com/Finance/Services/Financial_Reports/index.php, Columbia, Missouri, October 1, 2012.

• CDT, 2013, "MU, Company Partner to Boost Supply of Isotope used in Diagnostic Drug,"

Columbia Daily Tribune, http ://www'columbiatribune'com/news/education/mu-company-partner-to-boost-supply-of-isotope-used-in/article_0c707d88-4909- 11 e3 -9ef7- 10604b9 f6eda.html, Columbia, Missouri, November 9, 2013.

° CW&L, 2013, "New South Substation & Transmission Lines Public Hearing,"

https://www.gocolumbiamo.com/waterandLight/Electric/ProposedElectricTransmission.php, Columbia Water and Light, Columbia, Missouri, July 15, 2013.

Cl-l B Provide the name, .descriiption,location, andstatus of any additionalpast,present " .

or reasonably-foreseeableprojects or actions at or in the vicinity of the proposed RPF that have be~en identifiedsince the applican~t s ER was prepared.

The information provided in the following table identifies the name, description, location, and status of additional projects in the vicinity of the proposed RPF that have been identified since the Environmental Report (ER) was prepared. The Gans Road route 163 to Bearfield road is anticipated to convert some existing farm fields to road surface, which would be considered a minor loss of agricultural lands. The cumulative effect is considered small. All other impacts associated with the new road are anticipated to be within the cumulative impacts already addressed by other projects with the ER, and the resulting cumulative impacts are anticipated to remain the same as documented in the ER.

21 of 58

NWMI-201 5-RAI-001 NWM I Rev. 0 Recently Identified Past, Present, and Reasonably Foreseeable Future Actions Eli. 0.25 Fulton Center Medical TBD TBD !0.40 N 'Certificate

[was not approved of Need CDT, 2015b and CDT, 2015a iunderdetermiined when or if it will be built .... ..... ...... .. . . . . ...

i~raft Heinz plant TBD TBD Greater N :Construction limited 'CDT, 2015c

!expansion than 8 than 5 :to preyiously

.disturbed lands at a Jdistance from the FPR site.

Landmark TBD TBD 6to8 3.7 to 5 N iConstruction limited ~MHFRC, 201. 5 Hospital Sto previously Transitional Care disturbed lands at a Center of distance from the Lolumbia Ii!tKme Gans Road: 1/2015 12/2015 2 to 4 1.3 to 2.5 Y iConstruction include ;CATSO, 2015a and Route163 to iel itre CTO 05 Bearfield Road nelyndisturbd a Coet TS,20 I cumulative effects from air emissions

!and effect to land

__________ _________ use. ___________

. .. .. _ liii, I C' escribe any site inetgtosthat examined vegetation (grasses, shrubs, and ,

V trees) and wildlife (mammals, reptiles and amphibians, and birds) on or near the site, including transient wildlife that may only rise the site as a temporary resting or foragingground, or wildlife that only uses the site seasonally. In addition, describe any site investigations thatfocused on invasive species. ........................  :*.............

A site investigation to examine vegetation, wildlife, and invasive species on the site was conducted by a combination of photographic interpretation, evaluation of the literature, and the ecological site description of grass prairie of the area around Columbia, Missouri. The site is an area that has experienced continuous land disturbance associated with agriculture practices at least since 1934 (Terracon 2011la, provided in Appendix H). In addition, the site is devoid of natural landscapes such as forest, prairies, and other natural plant communities. A site reconnaissance was conducted by NWMI in June 2014 to confirm the site investigation findings._____

22 of 58

'WM,-.0lU-VY,-00Rev. 0

.I'l ..

ECO-2 Section 19.3 .5.7.1 of the ER? states that "representativeplant species include little " i bluestem (Schizachyrium scoparium,), sideoats grama (Bouteloua curtipendula),

winter bentgrass (Agrostis hyemalis), andAtlantic camas (Camassiascilloides)

(Nigh and Schroeder, 2002, Faber-Lagendoen,2001). "Provide the technical basisfor why NWMI assumes these plants occur onsite. Describe the percent

..... cover of__the mostcommon veget~at~iv~especieson site.... ..... . .. . .. .. .. .. .

The representative plant species are based on photographic interpretation and the ecological site description of grass prairie in the area around and near Columbia, Missouri. A site investigation was conducted on September 30 and October 1, 2015. The results of this survey are provided in the attached report: NWMI-2015-RPT-002, RadioisotopeProductionFacility Vegetation Assessment (Appendix I).

ECO-3 Section 19.3.5.7.1 of the ER states that "potentialnative plant species that may V" occur within the proposed site include those associatedwith tall grass hardpan prairie (Nigh and Schroeder, 2002). "Nigh and Schroeder (2002) describe numerous native species. Describe which native species occur on site andprovide a summary of how NMWJ determinedwhich native species occur on site, such as

. ...... onsite ecological-surveys_. .. . .. . . . . . .. . .... ...... ... .. . ... . .. . .... . . ....

A site investigation was conducted on September 30 and October 1, 2015. The results of this survey are provided in the attached report: NWMI-2015-RPT-002, Radioisotope ProductionFacility Vegetation Assessment (Appendix I).

ECO-4 Figure 19-39 of the ER shows the locationsfor wetlands near the proposedRPF "

site. The large size of the symbol for the proposedRPFmakes it difficult to confirm the location of any wetland onsite or near the site. Confirm whether any wetlands are located on the proposedsite and describe the distancefrom the proposed site to the nearest wetland. Describe wetland and wildlife species that are likely to occur in nearby wetlands.

Based on the United States Fish and Wildlife Service (USFWS) National Wetlands Inventory GIS data, there are no wetlands located onsite or near the site. The closet wetland to the site is a 4.9 hectare (ha)

(12.15)-acre pond with an earthen dam, which is 0.24 kin) (0.15 mi) to the northwest of the site.

A qualitative survey of the properties immediately surrounding the site was conducted on September 30 and October 1, 2015. The results of this survey are provided in NWMI-2015-RPT-001 (Appendix J).

The survey identified Bullfrog (Rana catesbeiana), Green Frog (Rana clamitans melanota), Painted Turtle (Chrysemys picta bellii), and Northern Pintail (Anas acuta) within the northwestern pond. The property south of the RPF site to Gans Creek was surveyed and found to have American Elm (Ulmus americana),

Eastern Red Cedar (Juniperus virginiana), Post Oak (Quercus stellate), Bitternut Hickory (Carya cordiformis), and Shagbark Hickory (Carya ovate). At the time of the survey, Gans Creek was not flowing; however, Creek Chub (Semotilus atromaculatus) were observed in small pools within the creek channel. Blanchard's Cricket Frog (Acris crepitans blanchardi) and Eastern Gray Squirrel (Sciurns carolinensis) were also observed in this area.

23 of 58

• NWM.-Io,*,=.=*~ NWM [-201 5-RA,-001 Rev. 0

.I'l ..

The man-made pond to the northwest of the property was also observed and Green Frog (Rana clamitans melanota), Canada Goose (Branta Canadensis), Northern Pintail (Anias acuta), and Trumpeter Swan (Cygnus buceinator). Signs posted around the pond note that is was stocked with largemouth bass, catfish, and crappie by the Missouri Department of Conservation for recreational purposes. The bird

,species also indicate that the surrounding water bodies may be used b.y migra~tory birds__..........,....,

ECO -5 Describe the aquatic species, such as fish and invertebrates that are likely to V" i occur within, the stormwater management ponds, Gans Creek, and nearby I! streams.

As described in Section 19.3.5.6, "Aquatic Communities and Potentially Affected Water Bodies," the aquatic species that are likely to occur within the stormwater management ponds, Gans Creek, and nearby stream include mayflies, stoneflies, caddisflies, dragonflies, beetles, small crustaceans, snails, shiners, suckers, redhorse, sunfish, bass, darters, and stonerollers. No Federally listed threatened or endangered fish species are known to exist in Gans Creek. No specific data is available on the species within the stormwater management ponds; however, the species and habitats are considered to be similar to those found in Gans Creek.

6 EC........ es ri e the.....most.

b..

............... hemshrubsnve etti .....e species.........(grassesO common.........vegetative......

... pand ( rastrees), a d res) -.... /

S wildlife species (mammals, reptiles and amphibians, and birds), and aquatic  !

......specie~s (fish andrmac~roinv~ert~ebr~ates) at e~ach altern~ativesit~e_........................

Based on photographs of the alternative sites, the common vegetation includes the types used for landscaping, including ornamental grasses, shrubs, and trees. The wildlife species using these sites would be limited to species that occur in urban/industrial settings, including rodents, some song birds, and insects. Aquatic species are not anticipated to use these sites due to a lack of water.

24 of 58

• "NWMI

• ..?:* oarra c Es Pto NW MI-201 5-RA[-0oo1Re, R v

- - . .. gIi GEO-1 Provide clarification of the informationpresented in Sections 19.3.3, including I 19.3.3.8 and 19.3.4.3, of the ER with respect to the greaterDiscovery Ridge site development. Specifically, provide a description of the scope and timing of proposed site-specific geo technical and hydrological studies to be performed of the RFP site (Lot 15) and of any adjoiningareas that may be usedfor laydown or site t access. Include studies such as proposed baseline preoperationalgroundwaterand surface water quality monitoring(including samplingparameters) as well as studies to addresssuch potentialissues as soils with high-shrink swell potential, karstfeatures, and confirmation of the depth to perched groundwater or water-L- -table conditions.

NWMI anticipates conducting site-specific geotechnical and hydrological studies starting in January 2016.

Bore holes are anticipated to be drilled a maximum depth of approximately 15.2 m (50 ft) below surface level, or 6.1 m (20 ft) into sound bedrock. The number of bore holes per 9.2 square meters (in 2 )

(100 square feet [ft2]) will be dependent on the foundation type anticipated in a specific area. For each core, the soil/rock profile will be documented and classified, and engineering and geotechnical properties determined. The liquefaction potential of soils will also be determined. Groundwater encountered will be documented, and several samples of the groundwater encountered will be collected to determine the baseline groundwater quality. There is no intention of verifying the depth to the Mississippian aquifer, which lies approximately 548 in (1,800 fi) below the surface. Baseline surface water samples will be collected from Gans Creek and the stormwater management ponds prior to the initiation of operations.

fGEO-i B As part of the site-specific characterizationstudies referenced in (A) above, describe the number, spacing, diameter andproposed depth, and installation method of any groundwater monitoringwells to be installed, such as to verify~and monitor depth to groundwater. Specify whether the wells, if any, would be retained f'or operationalphase groundwater monitoringand/or leak detection.

As noted in the ER, the NWMI RPF is designed to have zero liquid discharge from the radiologically controlled area. The groundwater aquifer beneath the proposed NWMI site is the Mississippian Aquifer (also referred to as the Kimmswick-Potosi Aquifer). There are no defined liquid effluent release pathways, and the groundwater is not expected to be contaminated due to operation of the RPF.

Therefore, groundwater sampling was not included in the radiological environmental monitoring plan.

Shallow groundwater has been detected in two previously drilled boreholes near the NWMI RPF site. As noted in the response to GEO-lA, if encountered during boring, water will be sampled and noted during the site-specific hydrological studies. However, the NWMI RPF is designed to have zero liquid discharge from the radiologically controlled area and as such, these boreholes will not be retained for operational phase groundwater monitoring.

25 of 58

SNWM I NWMI-201 5-RAI-001e.0 jGEO-1 C Provide the following references as cited in the ERrfor docketing."

I'll v

1.) Terracon, 2011a, Phase I EnvironmentalSite Assessment Discovery Ridge Lots 2, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, and 1 8, Terracon Consultants, Inc., preparedfor University of Missouri and Trabue, Hansen & Hinshaw, Inc., Terracon Project No. 0911770], March 23, 2011 (cited in ER Section 19.3.4.3.1).

S 2.) Terracon, 2011b, PreliminaryGeotechnical EngineeringReport Discovery i 'Ridge-Certi~fied Site ProgramLots 2, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, and 18, Terracon Consultants, Inc., preparedfor University of Missouri and Trabue, Hansen & Hinshaw, Inc., Terracon ProjectNo. 09105094.1,

.. ....... ..Febru:ary1,_2 1 cte n E eci n 1 . .3.8.1).. ..... . . . . ..... . . ........ .. . .

Reference documents are attached in Appendix H and K, respectively.

VGEO-2 Section 19.2.3 of the ER indicates that the depth of the processinghot cell below

! grade, without footers, is 4.6 m (15 ft). Section 19.4.3.1 of the ER states that the

'. maximum depth of excavation is anticipatedto be 15.5 ft. below groundsurface,

,! presumablyfor the hot-cells, waste storage areas, and transfer tunnel as S referenced in the ER. Confirm that this excavation depth is still bounded by the il facility design and include relevant information on the thickness and material of S construction of the outer walls and basementfloor of the below groundportions of S the RPF in support ofyour response._J Section 19.2.3 describes the baseline depth below finished grade of the tank skid hot cell and the high-integrity container (HIC) vault. The top of finished concrete for these two deepest areas within the RPF is 4.6 m (15 ft). This depth is in reference to the finished grade, not to the existing site surface.

The baseline composition of the floors for these two rooms is a reinforced concrete mat slab, nominally 45 to 60 cm (18 to 24 in) thick. The room walls will be reinforced concrete, ranging in thickness from 61 to 122 cm (24 to 48 in), based on the structural loading and shielding requirements for each section.

The nominal depth of excavation beyond the slab will vary based on the results of the geotechnical survey and the requirements of the structural design. The over-excavation typically ranges from 15 to 30 millimeters (mam) (6 to 12 inches [in.]) to 1.5 to 1.8 m (5 to 6 fi), based on these factors. The over-excavation will be minimized. If the existing site surface is close to the site finished grade in the area of these two rooms, the maximum excavation depth could range from 5.2 to 7.0 m (17 to 23 fi).

Section 19.4.3.1, referenced excavation calculation uses the nominal finished site elevation to determine excavation volumes. The calculation then adds 37 percent to address uncertainties then rounds that total up another 3 percent to reach the 6,881 m3 (9,000 cubic yards [yd 3]) total used in Section 19.4.3.1. The excavation depth and total volume remain reasonable bounding conditions.

26 of 58

• ,~.*

IUNW IIB EU tJ~*ElTM EuCA.

[OE NwM,-2o 5-RAI-Oe.o1

-...0g*g g**

HC-1 Jdentify

=Plan, and/or any the whe~ther applicant procedures haswould thai, prepared befollowed in Resource a Cultural Management the event that human r *." V .

remains or other items of historic or cultural value are inadvertently discovered

• during construction, operation, anddecommissioning of thefacdiiy _______-,

NWMI has not prepared a Cultural Resource Management Plan. A Cultural Resource Management Plan will be prepared prior to initiating construction of the facility and will be submitted to the Missouri State Historic Preservation Office.

SHC-2 Provide information on whether the proposed RPFwould be visiblefrom any I V".

1 surrqundingNational RegisterofHistoric Places (NHRP)-listed or-eligiblehitrcpoete."'

Baedo tevisual imataayi nScin19.4.1.2.1, the RPF stack could potentially be visible at the David Gordon House and Collins Log Cabin, and the Maplewood House NHRP properties.

HC-3 Section 19.3.6.8 of the ER indicates that the applicant initiatedconsultation with V *....

• the Missouri SHPO and six~Federally-recognizedtribes in 2013, and indicates in Section 19.4.6 that,:the Missouri SHPO has reviewed and concurredwith the  :.

findings of the Phase I archaeologicalsurvey. Provide copies of any letters or

communications, to andfrom the Missouri SHPO, Federally-recognizedIndian t rtribes that may hiave ancestralor hitrclties to the froject area, or local

• ocitie tht hveoccurred subsequentto those discussed in the ER...

hisorial There have been no additional communications to or from the Missouri State Historic Preservation Office (SHPO), Federally recognized Indian tribes, or historical societies subsequent to those discussed in the ER.

27 of 58

• .*

  NWIVII RED" A MEDwz CALElUSOPES NWM,-2o1 5-RAI-Ole.o1 R v

- . .* I'l tH-N- 1 i,he 1I(5 augmenting Provisions, NUREG-]537, Permits, and Part]1,Section Requires Consultations, .19.1.2that "states "Regulatory applicablefederal, .

• V state, local, and other regulatory requirementsshould be summarized. Provide a, list of reporting requirementsfor non-radioactivewaste streams to EPA and . .

L MDNR as discussedin Section 19.3.8.3.of the ER.

Table 19-4 in the ER provides a listing of the applicable Federal, State, local, and other regulatory requirements. The table notes that NWMI is required to notify the U.S. Environmental Protection Agency (EPA) of any Resource Conservation and Recovery Act (RCRA) (42 U.S.C. § 6901 et seq.),

Subtitle C, activity and any spill prevention, control, and countermeasures for storage of oil, if required.

As a small quantity hazardous waste generator, NW/MI will be required to prepare a Notification of Hazardous Waste Activity form to obtain both a Missouri generator identification number and a Federal (EPA) generator identification number. NWMI would be required to submit a Generator's Hazardous Waste Summary Report Form to MDNR annually.

There are no specific reporting requirements associated with the use of weed killer and fertilizer on or near the site noted in Section 19.3.8.3. The statement "Nonradioactive liquid, gaseous, and solid waste effluents from facilities within the Discovery Ridge development are required to report hazardous effluents to the MDNR and the EPA," is not applicable to the section and has been removed.

' HH-NR- The ISG augmenting NUREG-t53 7, Part], Section 19.4.10, "Human Health" V' 2 states that the ER shouldprovide an assessment of the physical occupational hazards. Provide a copy of the plant procedure that workers would use for .;.

identifying industrialhazardspr*.ior to performanceeofjobs .

The plant procedures for identifying industrial hazards prior to performance of jobs have not yet been developed._The procedures will be developed and included in the Operating Permit Application.

T HH*N R-- Th~eISG augmentingNURE*G-]537, Part]1,Section 19.4.9, "Waste Vf ....

!3 Management, "states that the ER shouldprovide a descriptionof the proposed i i " waste management systems designed to collect, store, andprocess waste. Provide " =

i a cop~yof the recycling and reuseplan discussed in Sectionl]9.4.8.].2*4 of the ER. " .

The recycling and reuse plan has not yet been developed. This plan will be developed and included in the Operating Permit Application.______

28 of 58

SNWM I NWMI-2O1 5-RAI-COOev

. .e *. ulii HH-R-1 The ISG augmenting NUREG-]537, Part]1,Section 1J9.3.8, "Human Health,"  :' /.,

states that the ER should provide effluent release points and expected radioactive effluent releases and exposuresfrom construction, operational, and ° decommissioning activities. Baseline radiation levels for the 'generalareaare. .

diCauaas lnsnt1 icei in 19.4.8.

dssaedoof ss the ER, frp rsfo thatctihers e is R n !

da l w y P a iscusseds t n ti ds coaind of the s ti19.3.88.

ERa ofr p ts r m re ac to l ers ikeMUR an possibility th'at the RPF will'releasegaseous and liquidradionuclides into the environment, currentradiationlevels are important to quantify. Clarify ifany  !

baseline monitoringwill be performed at .the RPF, and how effluent releaseswill be monitored/mitigatedduring construction, operations, and decommissioning.

A radiological survey will be conducted before startup of the RPF to provide a baseline. The operational radiological monitoring program discussed in Section 19.4.8.4 will provide the baseline for decommissioning.

There are no plans to conduct a radiological baseline survey for construction activities.

Additional information on the NWMI's Radiological Monitoring Program is provided in the Part 2 Construction Permit Application, Chapter 11, "Radiation Protection and Waste Management."

HH -R-2 The JSG augmenting NUREG-153 7, Part]l,Section 19.3.8, "Human Health,"' V" States that the ER shouldprovide a description of the facility 's radiological i programs and systems. Provide description of the program (s)for radiological i w....

orker protection and m onitoring necessary to comply with 10 CFR Part 20.

The radiological worker protection and monitoring program that complies with 10 CFR 20 is described in NWMI's Part 2 Construction Permit Application, Chapter 11.0, "Radiation Protection and Waste Management."

29 of 58

• ..: l.U. V pV Rv

-. *ii US0DH0 SLAN-I: .Table 19-15 of the ER describes U.S. Geological Survey (USGS) land use " "

) categoriesfor the 8 km (5-mi) region of influence surroundingthe proposed RPF.

S-Describethe current'landuses on si~te as defined by USGS. . .

The current land use of NWMI's RPF site as defined by U.S. Geological Survey (USGS) is pasture/hay.

i.LAN -2 Section 19.3..1 .2.3 of the ER states that the site has an L sensitivity rating, as an  : .¢ j area with low scenic values resultingfrom a low sensitivity to' changes in visual Squality by the type of users in the area, a low amount of use by viewers, low public' S interest in changes to the visual,quality of the site, and a lack of special natural

........ andwilderness areas. Provide the technicaljusti~ficationfor this rating_..........._........<L_*i...

The scenic quality of the proposed site was rated using the Bureau of Land Management (BLM) Visual Resource Management System (H-8410-l, Visual Resource Inventory Manual). The sensitivity level, a measurement of the public concern for scenic quality, is rated on a high (H), moderate (M), or low (L) scale. The sensitivity level was analyzed using six different indicators of public concern: types of users, amount of use, public interest, adjacent land uses, special areas, and the results of a potential viewability analysis from seven vantage points. Even though the facility is potentially viewable to different publics from all seven points, the analysis does not consider screening effects. At both near and far distances, a potentially viewable facility could easily be Screened from view by intervening vegetation, structures, and topographic features. The analysis also does not consider time. A high number of viewers travel on the highway and roads near the proposed facility. The public may view the facility, but only briefly while traveling to their destinations.

Although the facility could be potentially viewed by a high number of people, and may at inception be perceived as having a high effect on visual sensitivity, the area overall has a low sensitivity to changes in visual quality. This is because of the type of users in the area (e.g., workers, residents, travelers), a low amount of use by viewers (i.e., not a public destination), low public interest in changes to the visual quality of the site (another facility in an industrial park would not be unexpected), and a lack of special natural and wilderness areas. Nearby residents would most notice the RPF on the landscape, although the facility would not be considered out of character with its location and context within the research park.

Over time, the facility would be assimilated as a normal component of the landscape. Taking these factors into account, the site was determined to have a low (L) sensitivity rating.

LA- eto 14...oteERstates that "osrcinsaigatvte ol lo"*

occur along Discovery Drive bordering the lot and the adjacentDiscovery Ridge

.. Lot 1 4. Staging activities would be temporary and would cease after construction of the facility. *'Describe the exact locations and approximate acreage of aniy offsite stages areas that would be used during construction.

MU, the owner of Discover Ridge, has given initial approval for the NWMI constructor to access the NV/MI site from the adjacent lot to the east (Lot 14). This plot is adjacent to both the NWMI site and Discovery Drive. The space needed for staging activities in the adjacent lot is estimated to be 23 m (75 fi) along Discovery Drive and 46 m (150 ft) along the common lot boundary between the two lots (approximately 0.1 ha [0.26 acre]). After construction activities are complete, the affected area in the adjacent lot will be revegetated with similar species as currently found throughout Discovery Ridge.

Figure_19-14 will be updated to indicate the Lot 14 laydown area.

30 of 58

@"NWM

• " I NWM,-201 5-RA,-001Re Rev..

- . N ~U gIi LAN-4 Section 19. 4.1.1. of the ER states that "iafterthe facility is:buikt, landscaping would mitigate disturbancescaused during construction on the lot, both exterior

• of the perimeterfenceandfrom the perimeterfence to th~perimeterof the building. "Provide a description of landscapinigactivities NWM[ intends to complete. Forexample, would open areas be covered in grasses, shrubs, or . .

ornamentalflowers. Would any native species be usedfor landscaping? If known, provide the approximate percentage ofspace that would be landscaped "  !:

___ vs. developed.

Consistent with Discovery Ridge master plan and covenants, the site will have earthwork berms providing visual blockage from the adjacent streets. In addition, open areas and berms will be covered with ground materials such as grasses, shrubs, and/or ornamental flowers including native species.

Figure 19-7 currently shows that grasses, shrubs, and trees show a general concept for landscaping.

Approximately 68 percent of the site will be developed, providing 32 percent of the site for landscaping._To date,the specific ground coverage materials have not yet selected.

LAN -5 ,Describe the current zoning classi~fication.at each alternativesite. ."

Discovery Ridge: Discovery Ridge Discovery Ridge was developed under Section 172.273 of the Missouri Revised Statutes, which provided that "the Curators of the University of Missouri may establish research, development, and office park projects in order to promote cooperative relationships and to provide for shared resources between private individuals, companies and corporations, and the University of Missouri, for the advancement of the University in carrying out its educational mission and such projects are declared to be in furtherance of the purposes of the University."

The Discovery Ridge Master Plan and Protective Covenants (MU, 2009) is the applicable land use guidance for the research park. Discovery Ridge is zoned commercial in the A-i district (City of Columbia, 2012b), under the Section 29-18 provision, Board of Adjustment (City of Columbia, 2012c).

The Columbia Code (Section 29-18) has height restriction for A-i of 10.7 m (35 ft). Missouri Revised Statute, Section 172.273, exempts university research parks, including Discovery Ridge, from local land development regulations. This allows MU to develop Discovery Ridge to its own master plan and to include non-agriculture-related structures with sizes in excess of the A-i zoning requirements, provided MU gives Columbia courtesy review of the plan and design drawings and addresses the city's comments.

MURR: The current zoning at MURR (e.g., area encompassed by the reactor) is zoned as "M-1, General Industrial" by the City of Columbia. Conditional uses are allowed under Section 29-20(c), manufacture, compounding, or processing of hazardous materials.

OSTR: The current zoning at the OSTR/OSU is zoned as "Public Institutional" on the City of Corvallis Comprehensive Plan (City of Corvallis, 2000) and "Other Designations - Oregon State University" on the City of Corvallis Official Zoning Map. The OSU Master Campus Plan also describes the university planning expectations and must be consistent with the City of Corvallis Land Development Code.

McVlClellan Business Park: The current zoning at McClellan Business Park is zoned as a Special Planning Area (SPA). An SPA is created for an established area when the countywide zoning regulations do not adequately address local concerns. The SPA allows uses, regulations, and standards that would not be allowed under the countywide regulations.

31 of 58

• NWMI

• ~ ELM,-IoIR-NWioo01

':~'..:"

,L,** Rev. 0

-.

• 0.*

0. ll NOI-1 The JSG augmenting NUREG-]53 7, Part]1, Section 19.4.2, "Air Quality and I" Noise, "'statesthat the ER shouldprovide the potential impacts to sensitive "receptors. Section 19.4.2.3.] of the ER states that the impacts of noisefrom construction are SMALL. However Table 19-90 of the ER state that the noise impactsfrom construction at the Discovery ridge site would be MODERATE.

Clarify the noise construction impact level and reconcile the differences concluded regardingthe impact level.

The noise impacts for the Discovery Ridge site noted in Section 19.4.2.3.1 of the ER are small. The impact in Table 19-90 was incorrectly stated. The noise impacts at Discovery Ridge site are "Small."

NOI-2 The ISG augmenting NUREG-1537, Part]t,Section, 19.3.2, "Air Quality and 1" Noise'"states that the ER shouldprovide a description of any current orpast noise studies and analyses conducted at the proposed site or within an audible range of the site. Section 19.3.2.3.] of the ER states that "[biasedon the most recentpeak 1-hr traffic count summaryfrom the Missouri Department of Transportation,the expected noise levels at the proposed RPF site resultingfrom traffic on U.S. o Highway 63 rangefrom 54 to 58 [A -weighted decibel] dBA (MoDOT, 2009)." The source cited, MoDOT 2009, identifes the peak 1-hr traffic count, however, it does not provide information on noise levels. Provide the.basis for the stated 54 to 58 dBA and/or how that noise level was obtained.

The noise levels provided in Chapter 19.0 were calculated using noise level estimates from Table 1 of the Federal Highway Administration's (FHWA) Traffic Noise Model (TNM) 2.5 Lookup Tables. The noise values assume hard ground and no noise barrier and were used to assess existing noise levels at the proposed RPF site. Current guidance (November 2015) from the FHWA states the TNM 2.5 Lookup Tables should not be used to estimate noise levels. To incorporate the FHWA's current guidance, noise modeling for the nearest resident has been performed using the TNM 2.5 model. This information indicates the change in existing noise levels will be less than 1 A-weighted decibel (dBA).

32 of 58

• N J~,WMl

.:. , IOTeE  : NWMI NWMI-201 5-RA-OI-0Rv0 Rev

- . .. I'llI NOI-3 Noise, The ISG augmenting NUREG-153 7, Part]1, Section 19.4.2, "Air Quality and Vi

'"states that the ER shouldprovide predictednoise levels using the dbA*-

weighted scale and major sources of noise, including all models, assumptions, and.

input data. Section.states that "[tiraffic associatedwith the construction i:

workforce commuting to andfrom thefacility site also generates noise. As previously discussed, the baseline,noise conditionsfor traffic include airports, railways, and highways. The increase in noise relative to baseline conditions is "

most noticeable duringperiods of high activity onsite and duringshfif changes in the morning and late afternoon. "However, predictednoise levels from the additionalworkforce and additional deliveries and offsite shipments was not provided in the ER. Providepredicted increase in noise levels resultingfrom the additionalcommuting workforce and deliveries and offsite shipments during construction, operations, and decommissioning along U.S. Highway 63 and Discovery Drive in the vicinity of the proposed RPF site.

The predicted change in noise levels resulting from increased workforce traffic during construction, operations, and decommissioning have been modeled using FHWA TNM 2.5. Peak traffic counts were used to assess baseline noise conditions at the nearest residence. Noise levels resulting from the addition of 100 vehicles traveling 112.7 km/hr (70 mi/hr) on Highway 63 during peak traffic times were modeled to determine the potential increase over baseline conditions. Based on modeled results, an increase of less than 1 dBA is anticipated due to the increase in traffic from the workforce.

33 of 58

DIIAIW

[I" MI IVI,OPE Ie NWMI-201 5-RAI-001evI Rev.

-eC. C.*.C i i PA-IA Section 19.2 of the ER discusses the activities and schedule if the pre-operation phase. Clarify if the impacts of the pre-operationalphase were considered within the constructionphase or the operationsphase impacts describedin Section 19.4 of the ER.

The impacts associated with the preoperational phase were considered within the operating phase of the RPF.

PA-I1B Section 19.2.1 of the ER states the nominal operationalprocessingcapacity of the RPF would be one batch per week (up to 12 targetsper batch)for up to 52 weeks, .

.and approximately 30 targetsfrom the OSTR or a third university reactor for eight weeks per year per reactor. The discussionfiurther states that the assumed bounding scenariowould be a total of 68 batches of irradiatedLEU targets processed at the RPF annually. For the bounding scenario, clarify."

1.) The estimated number of targetsper batch, batches per week, and batches per year that would be separatelyprocessedfrom the OSTR and the third reactor, respectively.

2.) The estimated annualnumber of targets to befabricated, irradiated,and

___ processed at *the RPF.

The estimated number of LEU targets that can be irradiated (e.g., per batch) at the OSTR or hypothetical third reactor is one batch per week with a maximum of 30 LEU targets/batch. Each reactor can irradiate up to eight batches per year for a total of 16 batches annually.

The RPF has been designed to fabricate a maximum of 20 LEU targets per week or 1040 targets annually to support irradiation at NWMI's network of University research reactors. The RPF does not irradiate LEU targets. The RPF has the capacity to process up to 900 irradiated LEU targets for 99Mo production.

PA-2 Section 19.2.1.1 of the ER states that the start date of site 1" preparation/constructionwould be the first quarterof2 016 and an end date of construction offirst 2017, which would result in a maximum construction phase of 15 months. However, Section 19.4.2.1.1.4 of the ER references an estimated constructionperiod spanning 17 months. Clarif the construction durationphase and/or the difference in construction durationpresented in Section 19.2.1.1 and Section 19.4.2.1.1.4 of the ER.

The construction phase for the RPF is estimated to be 17 months; the end date of construction is estimated to be the end of third quarter 2017 (calendar year).

34 of 58

N MNWM,-201 5-RA,-00CevI

- . .. g.ggIi PA-3 Section 19.2.1.2 of the ER states that 100% of the 3.0 hectare (7.4 acre) site V" would be permanently affected. Differentiate between the total estimatedamount of land that would be temporarily affected by construction activities (e.g., land clearing, material and equipment lay-down areas) versus the amount that would be permanently affected by operationalactivities (e.g., building and support

.. .f acilityfootprints, paved vehicl.e access andparking area~s). . . .......... ..

100 percent of the site would be temporarily affected by construction activities. In addition, approximately 0.1 ha (0.26 acres) of the adjacent site to the east (Lot 14) would be temporarily affected to support construction activities. The response to LAN-3 provides additional information.

Approximately 68 percent of NWMT's RPF site will be permanently affected by operations activities.

The remaining 32 percent of the site will be revegetated or landscaped. The responses to LAN-3 and LAN-4 provide additional information.

VPA-4 Section 19.2.1.3, Table 19-6 of the ER lists shipments by project phase to include ,/

delivery trucks and offsite radioactivematerials and waste shipments.

Section 19.2.8.2.2, Table 19-14 of the ER presents a different set of shipment information. Clarify'the relationship of the values presented in Tables 19-6 and 19-14, specifically."

A.) Whether the estimated delivery trucks listed in Table 19-6 during operation accountfor fresh LEU and irradiatedtargetshipments identified in Table 19-14 of the ER, and B.) Whether the estimated offsite shipments identified in Table 19-6 during operation accountfor the unirradiatedtargets, 99 Mo product, spent LEU, and radioactivewaste shipments during operation identified in Table 19-14 of the ER.

The "delivery trucks" row of Table 19-6 does not include radioactive shipments. The LEU and irradiated LEU targets shipments (etc.) identified in Table 19-14 are included in the "Offsite radioactive materials and waste shipment" row of Table 19-6. In addition, the "Offsite radioactive materials and waste 99 shipment" row includes unirradiated LEU targets, Mo shipments, and radioactive waste shipments.

PA-5 Section 19.2.2.3 of the ER indicates that the proposed RPFsite would be V" connected to local power, sewer, and water infrastructure. Provide estimated annual sanitary sewer, electricalpower, municipal water, and naturalgas requirements required to support each phase of the project.

The estimated annual sanitary sewer, electrical power, municipal water, and natural gas requirements are provided below.

Construction

• Municipal water usage (provided in Section 19.4.7.3): 23,242 liters (L)/day (6,140 gal/day).

• Sanitary sewer usage is estimated at zero; portable units will be provided.

• Electrical power usage is not provided in the Construction Permit Application. An estimated 600 amp (A) 480 VAC service for a site crane and a dedicated 500 kilovolt-amp (kVA) 208/120 VAC service are anticipated to be needed for the RIPF construction.

• Natural gas usage is estimated at zero.

35 of 58

• • NM NWM,-201 5RA,-001Ro

- . .. ggggii Pre-Operations Phase

• Pre-operations is assumed to be three months at operations phase estimates.

Operations Phase

• Municipal water usage includes the process water and sanitary needs.

- Process water (provided in Section 19.2.4.1, Table 19-1 1): 890,910 L/year (235,360 gal/year)

- Sanitary water: 4,073,000 L/year (1,076,000 gal/year) for a total of 4,964,000 L/year (1,311,000 gal/year)

Total municipal water usage: 4,964,000 L/year (1,311,000 gal/year). (The WAT-1 response provides a detailed analysis of the municipal water usage.)

• Electrical power usage (provided in Section 19.4.7.3): approximately 10 megawatt (MW) annually.

• Natural gas usage (provided in EDF-3 124-0008, Emissionsfrom Natural Gas-FiredBoiler Operation): 5,880 L/minl (12,460 CF/br) for each of the four boilers that run simultaneously (two heating boilers and two process steam boilers), when running at their peak output.

Decommissioning

• Municipal water usage during decommissioning is not estimated in the Construction Permit Application. Water usage is estimated as being similar to the construction phase (provided in Section 19.4.7.3): 7,571 L/day (2,000 gal/day).

• Sanitary sewer usage is estimated at zero; portable units will be provided.

• Electrical power usage is not provided in the Construction Permit Application. An estimated 600 A 480 VAC service for a site crane and a dedicated 500 kVA 208/120 VAC service are anticipated to be needed for the RPF construction.

• Natural gas usage is estimated at zero.

PA-6 Section 19.2.5.2 of the ER indicates that the RPF would use three electric boilers. ,/

Clarify how these boilers relate to the four naturalgas boilers discussed in Section 19.4.2.1.2.4.

The RPF has two sets of boilers: one set of three boilers for the heating, ventilation, and air conditioning (HVAC) system, and the second set of two boilers for process steam. The three heating boilers are sized such that only two are operating and one is a spare. The process steam boilers are sized such that one operates and the other is a spare. All five boilers are natural gas-fired; however, only three would be expected to be operating at any one time (two heating and one process steam boiler).

The air quality impacts from operation, Section 19.4.2.1.2, evaluate operation of four natural gas-fired boilers to bound emissions from boiler operation.

36 of 58

NWM 1-201 5-RAI-001

~ NWM I Rev. 0

-aa a.g ai i IPN-IA In Section 19.2 of the environmental report, NWMJ summarized the status  :

of all applicable Federal,state, local, and other regulatory requirements, permits, and consultations that would be required.For the permits identified in Table 19-4 of the environmental report, provide a timeline or status updatefor when NWMI expects to apply for and receive the perm its. If relevant, provide a specie regulatory or other milestone on which a given permit may be dependent upon.

The required State and local Missouri permits described in Table 19-4 are accurate. The approximate dates for submittal of these permits are listed below.

Table 19-4. Regulatory Compliance Status (6 pages)

Atomic Energy A*_ct Construction RPF construction Addressed in

-a . a 10 CFR 50.50 Permit i Construction Permit a a i Application 10 CFR 50.57 Operating License RPF operation To be addressed in operation license

.... .. .. ..... .... .appli!cation . . ........

SBy-Product iProduction, possession, 7To be addressed in SMaterial License J!and transfer of license application 10 CFR 30 iradioactive by-product Smaterial Special Nuclear Receipt, possession, To be addressed in Materials License use, and transfer of license application

_special nuclear material_....... _

National Environmental Environmental SSite approval for RPF Addressed in this Policy Act assessment or construction and Construction Permit 10 CFR 51 environmental ioperation Application impact statement U.

Clean Water Act i[Dredge and Fill !Discharges of dredged Not required 33 CFR 323  ;'Permit (Section  !*orfill material into U.S.'

lwaters t 37 of 58

NWM 1-201 5-RAI-001 NMI Rev. 0 Table 19-4. Regulatory Compliance Status (6 pages)

Resource Conservation Notification of iEPA identification Notification to be

• and Recovery Act RCRA Subtitle C number for generation submitted 60 days prior 40 CFR 262 activity of hazardous waste to construction Estimated submission date: 4/1/2016 Estimated receipt date:

7/15/2016

'Clean Water Act SPCC plans for Storage of oi~l during sPCC plans to be 40 CFR 11 2, Subpart D, construction and construction and

• iSubmitted 30 days prior

'Appendix F .. .o perationb } operation ., to construction .

": *iEstimated submission dae:5//21 Estimatd:receit2date

*

iN approvald requieitdae Hazardous Materials iCertificate of !Transport of hazardous Registration to be filed I . *Transportation Act Registration materials ino later than June 30 of 49 !the CFR107 calendar year or j  !~prior to offering i Ihazardous materials for

!transport i Estimated submission I }date: 6/30/2016

~Estimated receipt date:

, 11/30/2017 Federal Clean Air Act Construction Construction of an air Not required 5

-s. - 0 Missouri Revised !Permit emissions source .*Verification 2/28/2016.

Statute Chapter 643 iPart 70 Operating Operation of an air Not required 10 CSR Division 10 Permit pollution emission Verification 2/28/2016 source that has potential emissions exceeding 100 tons/yr of criterion

...pollutants ........ ..

Intermediate Operation of an air Not required Operating Permit pollution emission source that has the potential to emit is above major threshold, ibut a voluntary limits ot

• ioperation is requested Basic State iOperation of an air Not required Operating Permit !pollution emission Ssource that has the ipotential to emit is between de minimis and imaj or levels 38 of 58

mEunamIm U NWMI-201 5-RAI-001 O* * *S*SEU**tE*S Rev. 0

• am Q3ThWESTJEDICAL Table 19-4. Regulatory Compliance Status (6 pages)

- Clean Water Act PNPDES Land disturbance and i:Applications for general,*

3 - or. -

• Missouri Revised PConstruction idischarge of stormwater permits (Forms E and

• Staut Capers64 Sorwatr eritfrom the construction !G) to be submitted o '

• an64

' site i:30 days prior to i01* CSR Division 20 i construction

• ' Estimated submission i'* i' date. 5/1/2016 '

• iiEstimated receipt date:

1 i7/15/2016 NPDES Industrial Discharge of iPermit to be submitted Stormwater Permit !istormwater from the ione year prior to

! ilindustrial site during operation iioperations i;Estimated submission ii " idate: 5/1/2016 Il ~I[ Estimated receipt date:

(( .... ..i! . . . . . I'5/1/2017 . . .. ..

i Section 401 Water i Certifies that the " Not required Quality !Section 404 permitted Request for a waiver:

iiCertification ilactivity complies with "12/30/2015 i ;all applicable State Esiaercipdt:

!iwater quality standards, 2/28/2016cip dte Slimitations, and

. ... . .. .. .... restr iction s ... . .. . .. .. . . . ... . .... . . .. . .

Resource Conservation Notification of Obtain Missouri Registration to be filed

• and Recovery Act Regulated Activity idetiicaio nubr9"aspirt Missouri Revised for generation of generating hazardous Statute Chapter 260 ihazardous waste 'waste 10 CSR Division 25 ;Estimated submission I', !date: 6/1/2017

~Estimated receipt date:

] 10/1/2017

• Cert-ified- Reso-urce !R~eu s-e,,recl a-mati-on,0V or Appli-catio'n *to*'be-.......

SRecovery Facility recycling 1,000 kg submitted 90 days prior SApplication (2,204.6 lb) or more of ;;to operations isite-generated Estimated submission hazardous waste in a date: 6/1/2017 i!month Estimated receipt date:

i 110/1/2017 iNotification to Notify MDNR in INotification to be MDNR of writing and by certified isubmitted 90 days prior Conditional delivery of the claim of ito operations SExemption a conditional exemption Estimated submission for LLMW stored and date: 2/1/2017 treated in the facility Etmtdrcitdt I ___ __5/1/20 17 Hazardous Waste Treatment, storage or Not required Permit disposal of hazardous waste 39 of 58

NWMI-201 5-RAI-001 SK3UNWM! Rev.0

• 00.::.N ',*' a~js'oE Table 19-4. Regulatory Compliance Status (6 pages)

I;Atomic Energy Act  ;!Registration of liProtection against IRadioactive sources 3..Missouri Revised sources of ionizing iqonizing radiationF will be managed under Statute Chapter 192 iradiation . !the NRC license and are,

• :9 CSR Division 20 " *= i 'iexcluded fromMissouri*

• " '.! i.. .. ." * ' lio . * =. * .{regul~ation -  !

.0o-Clean Water Act Stormwater Stormwater iApplication to be

-* - Missouri Revised Discharge Permit management submitted 30 days prior :

Statute, Chapter 64 i ito construction Boone County iEstimated submission Stormwater Ordinance idate: 5/1/2016 Estimated receipt date:

7/15/2016 i FLand Disturbance Activity disturbin Aplication to be Permit0.4 ha (1 acre) or more isubmitted 30 days prior Sof land or disturbing to construction S278.7 m2 (3,000 ft2) in Etmtdsbiso Senviromnentally..I date: 5/1/2016 sensitive areas Estimated receipt date.

! 7/15/2016

• Missouri Revised Application for " Construction of a .Application to be Statute, Chapter 64 Commercial ... commercial building *submitted 30 days prior

)Boone County Zoning Building Permit '! to. construction

• Regulations

• Estimated submission

,

• date: 5/1/2016

• . Estimated receipt date:'

• :7/15/2016

- 0 - Clean Water Act Sanitary sewer Building connection to Required information to

o. Missouri Revised connection District wastewater be submitted 30 days

- -Statute Chapter 250 iapproval treatment works prior to construction Chapter 2 of Boone {Estimated submission County Sanitary Sewer }date: 5/1/2016 Use Regulations } Estimated receipt date:

{7/15/2016 Clean Water Act iApplication connect !Application 10 CSR Division 60 utility service for iAllows RPF to

.to Columbia Water Ssubmitted 30todays be prior

• 0.

Part II City of !Treatment Plant ito construction Columbia Code of iEstimated submission Ordinances, Chapter 27 {date: 5/1/2016 SEstimated receipt date:

{7/15/2016 40 of 58

NWMI-201 5-RAI-001 NWMI Rev. 0 Table 19-4. Regulatory Compliance Status (6 pages)

Plart ii city of'Columbia Building Permit "Approval of building .... Application to be...

• code of Ordinances code and standards, submitted 60 days prior

• 0 Chapter 6, Article II including site plan :to construction

" °Estimated submission

' date: 4/1/2016 Estimated receipt date:

~7/15/2016 Part II City of Electrical plan Electrical Code Information to be Columbia Code of i ppovlsubmitted 60 days prior Ordinances aproalto construction Chapter 6, Article III iEstimated submission i date: 4/1/2016

! Estimated receipt date:

~7/15/2016 Code of Ordinances approval submitted 60 days prior Chapter 6, Article IV to construction

" Estimated submission date: 4/1/2016 Estimated receipt date:

..... 7/15/2016 _

Part II Code of HVAC plan Mechanical Code Information to be Ordinances approval submitted 60 days prior Chapter 6, Article V to construction Estimated submission jdate: 4/1/2016 Estimated receipt date:

7/15/2016

'Part II City of Certificate of Facilities meeting Information to be Columbia Code of Occupancy Building Code submitted on completion

~Ordinances *of construction Chapter 6 Estimated submission date: 9/30/2017 Estimated receipt date.

10/1/20 17 Part II City of Columbia Fire Prevention Fire Code Information to be Code of Ordinances Plan Approval ,submitted 60 days prior Chapter 27, Article II Ito construction Estimated submission'

date: 4/1/2016 Estimated receipt date:

... .. ........... . .. . .. . .... ... .67 15/20 16 41 of 58

NWMI-201 5-RAI-001

• : N:.1J*'IM~l~rw Rev. 0 Table 19-4. Regulatory Compliance Status (6 pages) 5' Pari II City of Land Disturbances Land disturbance .Application to be

• sfI*'I Columbia Code of Permit activity, including ° (su~bmitted 30 days prior

[* ] Ordinances

• iconstruction on 'any Site 'ito construction Chapter 12A, Article iII **, that results in a ' iEstimated submission

• ~~disturbed area of 1 acre:ldate: 6/1/2016 '

• , or ore. *[ Estimated receipt date: :

' . .. . :i  : 7/1512016 Part II City of Stormwater Approval required prior Information to be Columbia Code of iManagement Plan to approval for Land submitted 45 days prior Ordinances iApproval *Disturbance Permit to construction Chapter 12A, Article V iEstimated submission

'~date: 5/15/2016 i !Estimated receipt date.

___________ 7/15/2016 a Full references are provided in Section 19.7.

b Only required when oil is stored in a tank or shell with a capacity over 1,320 gal, and the oil could reasonably reach navigable water.

CFR =Code of Federal Regulations. NRC = U.S. Nuclear Regulatory Commission.

CSR = Code of State Regulations. RCRA = Resource Conservation anid Recovery EPA = U.S. Environmental Protection Agency. Act.

HVAC =heating, ventilation, and air conditioning. RPF = radioisotope production facility.

LLMW =low-level mixed waste. SPCC =spill prevention, control, and MDNR = Missouri Department of Natural Resources. countermeasure.

NPDES = National Pollutant Discharge Elimination System. U.S. =United States.

42 of 58

WM INwMi-201 "* .,',Rev.:"0 5RA,-001evl

. .. .. g-I'l PN-1 B In accordance with Section 401 of the Federal Water Pollution Control Act (i. e., V Clean Water Act (CWA)) (33 U.S. C. 1251 et seq.), a Federalagency cannot issue a permit or licensefor any activity that may result in a discharge to navigable waters of the United States until the state or"tribe where the discharge would originate has grantedor waived certificationthat the potential discharge will comply with applicablewater quality standards. CWA Section 401(a) (1) specifies that the applicantfor the Federallicense or permit is responsiblefor providing the*

Federal licensing or permitting agency the certification or a waiverfrom the state in which the discharge originates.As appropriate,the state could also provide the applicant with documentation that no separate 401 certification is required.

Section 401 requirements are cited under Section 19.1.2 of the ER and in Table 19-4, and Section 19.1.2.5.1.2 of the ER fulrther states that "the construction, operation, and decommissioning of the RPF is not anticipatedto need a Federal Section 404 permit or Section 401 certification... "Clarify whether the state of '

Missouriwill require a separate CWA Section 401 certificationfor NRC-licensed construction and operation of the RPF. Indicate the applicant'splans, and, associatedtimeframe, for providing the NRC with required CWA Section 401

~ stte o Misour NWMI made the determination that a Section 404 or Section 401 certification is not required for construction and operation. NMWI anticipates contacting MDNR for a formal waiver from the state by March 2016.

..PN-2 The ISG augmenting NUREG-1537, Part 1, Section 19.2, "ProposedAction, "' V" i states that the applicant should provide a description of the operational activities.

Clarify if the NWMI facility would produce molybdenum (Mo-99), iodine-131 (I-131) andxenon-133 (Xe-133).

The RPF has only been designed to produce 99Mo. No iodine-131 (1311) or xeonon-133 (133Xe) will be separated as a product. The ALT-4 response provides additional information.

43 of 58

4.... I:- tf W 1215-A-0

-. . .. H.

ii iSOC-1A Section 19.4. 7.1.2 of the ER indicates "89)(non-management,) permanent V" operations workers needed are available in the ROJ." The next sentence states, "About 40 percent (36) of the operations workers and theirfamilies are assumed to relocate to reside in the ROJ."' These statements appear to be in conflict. There is also no discussion about the number of permanent management operations workers. In addition, Table 19-6 of the ER lists an average andpeak operation workforce of98. Clarify'these statements and reconcile the differences,.

The wording in Section 19.4.7.1.2 will be modified to read "Although the required workers are located within the region of influence (ROI), many are assumed to currently be fully employed, and 40 percent (36) of the operations workers and 40 percent (4) of the management positions and their families are assumed to relocate from outside the ROI to reside in the ROI. Using the ROI average of 2.4 individuals per household, the total population increase in the various communities within the ROI due to operational workforce requirements is 96 people."

A revised Table 19-66 is provided below.

Table 19-66. Workforce Required for Operations Techica supot e ,4 3 ,1 Production workers _170 _ _ - - 43 127 ....

Managementc __ 290 I 9  ;* 281

]Production worker support 280 16 264 a BLS, 2012, "May 2012 Metropolitan and Nonmetropolitan Area Occupational Employment and Wage Estimates,"

www.bls.gov/oes/currentloessrcma.htm, U.S. Bureau of Labor Statistics, Washington, D.C., accessed September 2013.

b Includes all architecture and engineering occupations.

SIncludes architectural and engineering managers, and medical and health services managers.

44 of 58

• "i;.*: NiI*ME IAITp 5RI-0 NWI-0 SOC-l B Section workers19. 4. 7.1.3 would of the ERfor be required states

.that duringpeak decommissioning.

construction, However, Tablean estimated 19-6 of the ER 81 I'll

"°"*

"lists a peak workforce of 28. Reconcile the differences in workforee numbers i discussed in Section 19.4.7.1.3 and Table 19-~6 during decommissioning.

Table 19-6 is revised and provided below to reflect a peak workforce of 81 and an average workforce of 38 anticipated during decommissioning. The responses to AIR-i1B, AIR-i1C, and AIR-i1D provide additional information.

Table 19-6. Resources Required During Radioisotope Production Facility Phases Average workforce 38 38 SPeak* workforce 82 a81i

,* 98 98 J Delivery trucks (per week),................... ........ 20 ......

SOffsite radioactive materials and waste 1 0.5 10 20 Ishipments (per week)  :

Fuel (diesel),_L/month (gal/month) b1,647 (435) C189 (50) C189 (50)

ILow enriched uranium kg/year (lb/year) 0 50 (110) 0 e170 (375) f170 (375) ab The The peak number majority of theofdiesel deliveries fuel isduring construction consumed during theis estimated first threeatmonths 30 vehicles.

of construction.

oDiesel fuel is used for backup generator.

d LEU needed for hot commissioning and initial RPF startup.

LEU needed in Operation Year 3 for addition of second university reactor.

SLEU needed in Operation Year 5 for addition of third university reactor.

LEU =low-enriched waste.

45 of 58

.uiNWIu NW[215IoC

-S . .5 .N 'l SOC-2A Section 19.4.7.6.] of the ER states that duringpeak construction, traffic volume * "i i.

is estimated to be 30 heavy vehicles (dump truck and deliveries) and 82 vehicles i, (pickup trucks and cars) daily. However, Table 19-6 of the ER lists 20 delivery i trucks (per week) and]1 offsite material waste and shipment per week. Reconcile i the diff/erences in traffic volume discussed in Section 19.4.7.6.] and shipments The delivery trucks noted in Table 19-6 are assumed to be an average number delivery trucks per week.

A footnote was added to Table 19-6 noting "* The peak number of deliveries during construction is estimated at 30 vehicles." The revised Table 19-6 is provided in the SOC-lB response. Additional information is provided in the SOC-i1B, AIR-i1B, AIR-i1C, and AIR-i1D responses.

{sOC-2B Section 19.4. 7.6.3 of the ER states that there are an .estimated30 heavy vehicles ' -"i;*.......

(waste trucks) and 81 vehicles (pickup and cars) traveling to andfrom the site

• daily during the decommissioningphase. However, Table 19-6 of the ER lists 20 waste shipments per week and a peak workforce of 15. Reconcile the differences !

in traffic volume discussed in Section 19.4. 7.6.3 and shipments and workforce The peak number of waste trucks is an estimated at 20. Section 19.4.7.6.3 will be changed to reflect a peak of 20 heavy vehicles. Per SOC-iB, the peak number of workers is revised to 81 during decommissioning. Additional information is provided in the SOC-iB, AIR-1B, AIR-iC, and AIR-i1Dresponses.________

46 of 58

• ...,Rev.

ItIAIlf NWM,-201 5RA,-001Re 0

. .. .. g.I'l

~STT-NR-1 The ISG augmenting NUREG-153 7, Part]1,Section 19.4.9, "Waste  ! V/'

Management, "states that the ER shouldprovide anticipateddisposalplansfor the waste and a description of waste- minimizationplans to reduce or minimize generation of waste. Provide copies of the chemical management plan and

........ product andlingplan discujssed in Section 19.2.8.1.1 of the ER.

The chemical management and product handling plans have not yet been developed. These plans will be developed and included in the Operating Permit Application.

2A only to radioactiveand mixed wastes.

The first sentence of Section 19.2.8.1.2 was changed to read: "Treatment and temporary storage of hazardous, radioactive, and mixed wastes are performed predominantly onsite within the RPF." A new bulleted item was added that states: "Nonradioactive hazardous wastes are accumulated in satellite accumulation areas or less-than 90-day accumulation areas, prior to on-site treatment and packaging."

STT-NR- Discuss the processes intended to manage transportationof non-radioactive V1 S2B .materialsand wastes.

The transportation of nonradio active materials and waste are governed by the U.S. Department of Transportation (DOT) regulations cited within Section 19.2.8.2, "Transportation of Material." For clarification, the first sentence of the section was changed to read: "The transport of radioactive and nonradioactive materials, waste, and other hazardous materials associated with the RPF must comply with applicable U.S. Nuclear Regulatory Commission (NRC) and DOT regulations."

STT-NR-3 The JSG augmenting NUREG-i537, Part 1, Section 19.4.10, "Transportation" v" states that the ER shouldprovide estimated transportationdistancefrom the Soriginatingsite to the projected destination of non-radioactivewaste. Section S19.4.10.1.6 of the ER states that a non-radioactivewaste recycling drop-off

'point is located approximately 4 miles from the RPP. Clarify that statement.

Will NWMJ be transportingnon-radioactiverecyclables to that drop off point or will the waste brokerpick up the recyclables at the RPF?

The Civic Recycling Center is located at 3300 Brown Station Rd, Columbia, Missouri. NWMI has not yet determined if a recycling contract will be used to collect recyclables or if NWMI will deliver recyclables to the recycling center.

47 of 58

NWMI-201 5-RAI-001 NWM.:*"e~,esur Ir~ Rev. 0

-. *. .9

.ii I SWM-NR-1A Provide

'and the tlhepERj]{

19-13of chemical composition of the waste streams listed in Tables 19-12  ! i*i "

The composition of waste streams was compiled from the MURR and OSTR mass balance worksheets (NWMI-2013.-CALC-002, Overall Summary MaterialBalance - OSU Target Batch, and NWMI-2013 -CALC-006, Overall Summary MaterialBalance - MURR Target Batch) and are provided in the following table for reference.

Waste Stream Chemical Compositions SFe(SO3NI~i)2 1.13E-12 1,12E-03 l .13E-08 Grout  ! i 1.73E+001 HtNO3 2.501-03 8.40E-0 3 5.84E-03 4.27E-05 1.89E-32 1120 i9.72E-01 9.97E-01 7.021-04 1  ;!5.78E-01 2....E-05~o 3

HSO 3 NHI2 8.85E-13 y.4-0i4o S8.82E-09 S NH4 NO 3 7.29E-03 NaNO 2 i 1.8E0 4.61-021- -3.1 4-E-O2 --... . ... ..... .. .

NaNO 3 6.73 E-02 5.991-06 S3.60E-02 NaOH 9.45E-03 4.491-05 S NaH 2P0 4 1 .49-0 Na2SO 3 i 1.89E-03*It........ . 13.721-05 Na2SO 4 _ 1 .44E-03 2.83E-05, 2.841-10 2.83E-07 6.49E-10O 0.00E+00i 1.85E-03 i4.15E-07 l.I06E-06 UO2 (N03 ) 2 9.34E-11 8.07E-05 1.85E-05 4.57E-08 "1.78E-04 .'4.3 1E-"06*

3.00E-01 S3.00E-01 48 of 58

NWMI-201 5-RAI-001 NVIIMI Rev. 0

... D Il SWM-NR-

... B.. Provide strams the anticipatedmass (in a unit applicable to solid material) of the waste lseinTbe1-3of the ER.  :¢ The anticipated mass of the waste streams is provided below in Table 19-13.

Table 19-13. Solid Waste Produced at the Radioisotope Production Facility Target fabrication" [NAa _ __ _ _ NA NA iITarget disassembly and Target cladding materials from disassembly 1,100 L 1,700 kg t dissolutionb (290 gal) (3,748 lb)

Mo recovery and lExchange resins and other solid waste 20 L 34 kg purificationb ________________ (5 gal) (75 ib)

,Uranium recovery and Exchange resin and media A1,350 L 530 kg Irecvclea' (.-360 eal) (1.169 lb)

Waste managementc Solid wastes encapsulated in cement 8,000 L 15,000 kg (2,113 gal) (33,069 lb)

High-dose solidified liquids 200,000 L 300,000 kg

______________________(52,834 gal) (661,380 Ib)

Low-dose solidified liquids 150,000 L 225,000 kg

_____ _______________(39,625 gal) (496,035 lb)

Laboratory facilities iMunicipal waste (e.g., chemicals) 4,000 L d7 6 0 kg SPotentially contaminated laboratory waste (e.g., (1,056 gal) (1,675 lb)

_________________ sample vials and containers) ,..-

Facility support Mncplwaste (e.g., paper) 26,000 L e4,056 kg

________________________________ (6,868 gal) (8,942 lb)

SPotentially contaminated waste 40,000 L e,240 kg

_____________ (e.g., decontamination materials, PPE) (10,566 gal) (13,757 lb) a Solid waste generated during target fabrication is anticipated to be decontaminated and free-released.

b Transferred to waste processing system for final disposition.

eThe waste quantities current bounding estimates. Optimization of waste processing should reduce the volume of liquid waste generation.

3 d Based density of whole glass (uncompacted) municipal waste of 550 lb/yd (or 0.19 kg/L), Mississippi Department of Environmental Quality (http://www.deq.state.ms.us/MDEQ.nsf/page/RecyclingMaterialDensity andVolumeConversion).

Based density of commercial/industrial waste (uncompacted) municipal waste of 450 lb/yd3 (or 0.156 kg/L), from Mississippi Department of Environmental Quality (http://www.deq.state.ms.us/MDEQ.nsf/pagefRecycling_

MaterialDensityandVolumeConversion).

NA = not applicable. PPE = personal protective equipment.

49 of 58

NWMI IwEE-o1R I * :..;e:.o*,*,'*r B~r.*Rev.o

,-oI 0 IWM-N R-2 The ISG augmenting NUREG-153 7, Part]1, Section 19.2, "ProposedAction" rstates that the ER should identify treatment and packagingproceduresfor I'll ,/

radioactive and nonradioactivewastes and radioisotopeproducts;"

transportationpackaging systems to be usedfor waste," and estimated

!transportationdistance to which radioactive and nonradioactivewaste would most likely be sent. Provide a list of anticipatedwaste disposal companies and

'disposalsitesfor the waste streams, including construction wastes, listed in Section 19.2.7 of the ER.

Process system liquid wastes are solidified and disposed of as solid Class A and B waste. These wastes would be transported and disposed of by Waste Control Specialists at their facility in western Andrews County, Texas.

Nonradiological specialty waste is anticipated to be collected by a company such as Veolia or Clean Harbors for separation, processing, and disposal.

Solid waste would be disposed at the City of Columbia Sanitary Landfill, 5700 Peabody Road, Columbia, Missouri. Columbia Solid Waste Services may be used to pick up solid waste from the RPF.

Construction waste would be disposed at the City of Columbia sanitary landfill. Hazardous construction waste would be collected by a company such as Veolia or Clean Harbors for separation, processing, and disposal.

iWM-NR-3 The JSG augmenting NUREG-153 7, Part]1, Section 19.4.9, "Waste  :

Management," states that the ER shouldprovide a description of the sources, types, and approximate quantities of solid, hazardous, and mixed wastes expectedfrom the proposed action. Provide a list of non-radioactivewaste streams, their chemical composition, and their mass.

Table 19-13 provides a solid waste estimate for the RPF. Based on EPA's estimate of municipal waste adjusted for NWMI facility operations, the major components of the non-radiological facility wastes are paper, plastics, and food wastes. Other wastes constituents will include rubber, cloth, and metals.

Additional information, total mass, is provided in the WM-NR- 1 response.

WM-NR-4 The ISG augmenting NUREG-1537, Part]1, Section 19.2, "ProposedAction" v" states that the ER should identif the type of hazardous materialsassociatedwith the facility. Clarify whether the radioisotopeproductionfacility will be a large or small quantity hazardous waste generatorunder the Resource Conservation and Recovery Act (RCRA).-

The RPF is currently anticipated to generate less than 1,000 kg of hazardous waste per month and to be a small quantity generator under RCRA.

50 of 58

NWAMI

• s-.,

I Xl*H* AIoTOres v

NWM,1-201 -RAI-OCI Re.s

,WM-R-l 4_7eSG~aUgmentiegNTUREG-JJ7, Par/i,Section 19.4., "J[Taste Managemen$'" I istates thatthe ER shou/dprovide i4/9rmatiom with respectto waste management as, Sa resu/t ofconstniction, operation, an~ddecommissioningactivities. Partoldihe iinforationnecessary toproperk determiize Ie environmen~ta/impactsof/he

• ,roposed action ie the type anidc/ass oa/radioactive w~astesgeneratedat the/ac/ily'

!_abl L9-Az o/tfheE lB ists the types¢ af/radioactivemateriols andwas/esgenerated/

!by or requiredfor use at the RPF. For the radioactive wastes generated and ishipped to Waste Control Specialist (WCS), clarif what those wastes are and lwhat class of radioactive waste (i.e., Class A, Class B, Class C, Greater Than NWMI's Part 2 submission of the Construction Permit Application describes the RPF radioactive waste handling program in Chapter 9.0, Section 9.7.2. Radioactive wastes anticipated to be transported and disposed of by Waste Control Specialists in Texas will include the following:

• High-dose solidified liquid waste - The high-dose solidified liquid waste consists of liquid waste streams generated by the RPF processes containing a majority of radioisotopes separated from molybdenum (Mo) product and recycled uranium. High-dose liquids are accumulated, neutralized (by addition of caustic), concentrated, and combined with a solidification agent prior to transfer into a disposal container. The quantity of this waste stream is bounded by 300,000 kg/yr as a solid.

Solidified high-dose waste is currently projected to be a Class B waste stream for disposal.

° Low-dose solidified liquid waste - The low-dose solidified liquid waste mass is dominated by condensate generated by process stream concentrators containing small quantities of radionuclides.

A portion of the condensate is recycled for reuse as water input for selected process unit operations.

Condensate that cannot be recycled is accumulated, neutralized (by addition of caustic), partially evaporated, and combined with a solidification agent prior to transfer into a disposal container. The quantity of this waste stream is bounded by 225,000 kg/yr as a solid. Solidified low-dose waste is a Class A waste stream for disposal.

• Encapsulated solid waste - The encapsulated solid waste consists of solid materials generated by the RPF processes. Solid wastes are dominated by cladding pieces generated during the irradiated target disassembly system and filters containing undissolved target particles generated by the irradiated target dissolution system. Solid wastes are collected in a disposal container. After filling with solid waste, a grout material is added to the disposal container to encapsulate the collected waste. The quantity of this waste stream is bounded by 15,000 kg/yr as a solid. Encapsulated solid waste is currently projected to be a Class B waste stream for disposal.

Waste process optimization activities are anticipated to be performed as part of the final design, with the goal of reducing the high-dose solidified liquid waste (and possibly encapsulated solid waste) volume generated by RPF operation. Volume reduction has the potential to change the disposed waste classification from Class B to Class C as a result of optimization activities, and results will be described in the Operating Permit Application.

No greater than Class C waste will be generated by NWMI RPF operations.

51 of 58

• ...-..

• V I IIR

• NWM,-201 5-RA,-001evlv I'll WM-R-2 iThe ISG augmenting NUREG-!53 7, Part]1, Section 19.4.9, "Waste IV

',Management,""states that the ER shouldprovide informationwith respect to lwaste management as a result of construction, operation, and decommissioning iactivities. Part of the information necessary to properly determine the environmental impacts of the proposed action is the amount ofstorage afacility

.has to handle the radioactivewastes generatedat the facility.

Clarify how long radioactive waste must be stored on sitefor decay before

'shipping, and ifsz-fficient storage space is available for all anticipated iradioactive wastes and radioactivematerials necessaryfor operation._......... ......

The disposed waste package radionuclide inventory was compared to transport cask design limits for radionuclides and heat generation. The comparison indicates that high-dose solidified liquid waste should be stored more than -45 weeks for decay prior to transport to a disposal site. Encapsulated solid waste should be stored more than '-12 weeks prior to transport. No decay time requirements are currently defined for transport of Class A low-dose solidified liquid waste. However, a cost incentive may exist for allowing the low-dose solidified liquid waste to decay for -12 weeks prior to disposal.

Sufficient storage space to support RPF operations has been included. Process material lag storage elements are described by the process descriptions in Chapter 4.0 of the NV/MI Part 2 Construction Permit Application. The process lag storage elements discussed throughout Chapter 4.0 are indicated by comparison of the bounding and nominal special nuclear material inventories shown in Tables 4-1 and 4-2. Storage space for radioactive waste is described in Chapter 9.0.

Information related to third reactor cannot be supplied at this time, as the reactor has not yet been selected. Site visits to the potential third reactor sites have indicated that anticipated changes in the sources, types, and approximate quantities of radiological effluents or waste streams; radiological impacts to the workers; and radiological impacts from transportation due to the shipment to and from the reactor will be similar to that assumed for the OSTR.

52 of 58

."IiI:NW fI

• .. "Na.

  ws WEaSrELiOoPEs NWMI-201 5-RA[-OOevR v 1

- .....-I'll WAT-1A iSection 19.2.4.] and Table 19-11 of the ER provide a narrativedescription and' V" tabularsummary, respectively, of the projected water demands, and Section 119.2.7.] summarizes liquid waste streams associated with operation of the p*roposed RPF. Provide a supportingprocess water balance (water use "diagram)forthe facility showingflow rates to andfrom the various water isystems, water system interconnections and interdependence,points of

consumption, and source and discharge locations. Specifically identify'RPF

pfrocess, cooling, steam production,fire protection,potable and sanitary, floor land equipment washdown, and any other specific water uses and identify'

.. .. . ... c.eon~su*tm pt~ive losses. .. . . .. .. . . . .. .... .... . . . . .. . .. . . . . . .. . . . .

The following diagram is based on several assumptions, which include the following:

• Demineralized water is required at a rate of 540 gal/day for 5 days/week.

• Steam is required for 3 days/week for 24 hr/day.

• Steam recharge (blowdown) is assumed at 10 percent of peak load requirement defined in NWMI-2015-SDD-011, Utility Systems SDD.

• Cooling water makeup is minimal and intermittent.

• Waste includes approximately 50 percent solids.

• Water out the stack is assumed to be 10 gal/hr 24/7.

• Recycle is not included in the water balance.

• Th-t. nritpr hci~nr~o rAno.l~. -nf. ,rn -,,f rJ..tJnlim n llVt hocritnrd.

• L'..r lur~*,- '.J~alnoJ fr,,n "L1'Jim crr~

hoLokJitaIO rrirt~.,nib~PPA1.,ci.1..

t1-'.JLA*'fli fh* 1*)

UJ UiIfn O

Ctyof Columbia Water System (potable) 53 of 58

• • hfWMIf NWMI-201 5-RAI-00 1ev0

. . . liii' WAT-1 B ER Table 19-)), which reports total annualwater consumptionfor the RPF, V"

!impliesthat aillfacility water use is "demineralizedwater" with separate

'columns includedfor "wash water. " Raw potable water usage does not appear ito be accountedfor and, except for the activity 'faculty support," there appears ito be no provision to meet the potable and sanitarywater needs oj ihe 9c facil'y In Table 19-11, "Faculty" [sic] should have been "Facility." The various water usage systems that are supplied by the municipal water system is described below.

"The municipal water system will be split into for main users within the RPF: the demineralized water system, the wash water system, the sanitary (drinking, showers, and toilets) system, and the firewater system. Wash water will be used to washdown the tractor/trailers. The firewater system is described in Chapter 9.0, Section 9.3."

The demineralized water system usage has been revised and is provided below.

"The demineralized water system supplies demineralized water to the process for water addition, flushing, and chemical dilution. The demineralized water system can also potentially provide make-up water to the steam boilers."

The sanitary water usage has been inserted into Table 19-1 1 and is provided below. In addition, a note has b een added to Tab le ..19-11. to__addres sfir~e wate~r and-_irrigation usage_.................................

Table 19-11. Radioisotope Production Facility Water Flow Rates and Consumption Information

- S -mI mm

!Target fabrication 25,000 6,600 ....- -

Target disassembly and 1,500 400 . - ., - i - -

!Mo recovery and ...... i-ipurification system I-...

Uranium recovery and !500,410  ! 132,200 -  ! - - --

recycle system i  !

• Waste managemnent ...... - .......

iFacility supot d 2,000 530 -- 360,000 95,100 _4,073,000 ,1,076,000 .

To~tal_ ............. .. 530,.910 .... __140,2_60._ .. 3609,_000... 95,100o .... 4,073,000. 1,076,_0.00 bAverage daily use 2,042 539 1,385 366 15,665 4,140 a These numbers do not account for planned process recycle.

b Assumes 260 days of operation per year.

SNote that there is anticipated to be a (180,000 gal) firefighting water storage tank that will be filled over an 8-hr period at 1,419.5 Llmin (375 gal/min). This water usage is not included in the above totals.

d Annual landscape irrigation is not included in the above totals. Landscape irrigation is assumed to not be required.

54 of 58

• • NWMAIn NWM,-2o1 5-RAI-001R.0 WAT-1 C liAs cited in Table 19-11, reconcile the cited average daily use values (539 -+

1366 gal) with the value of 1,286 gal/day given in Section 19.6.3.1.2 of the ER.

Section 19.6.3.1.2, "Water Resources," has been revised and is provided below.

I'll

,i .

i ' 1 J "The RPF requires water from the*Consolidated Public Water Supply District #1 water supply system for construction, isotope production, potable water, fire protection, and facility heating and cooling. The Consolidated Public Water Supply District #1 presently supplies 5.49 megaliter (ML)/day (1.45 million gallons [Mgal]/day). Construction requirements of the RPF are small compared to the available water supply. As noted in Section 19.2.4, the RLPF would require 19,094 L/day (5,044 gal/day) during operations, less than one percent of the total Consolidated Public Water Supply District #1 operational capacity. This leaves a significant excess capacity. Because there would be significant excess capacity within the Consolidated Public Water Supply District #1, there are no indirect effects associated with the demand from the RIPF. There are also no direct impacts to water quality or hydrology from the RPF, and therefore, there would be no irreversible impacts."

55 of 58

.IVIII NWMI-201 5-RAI-001 REFERENCES 10 CFR 20, "Standards for Protection Against Radiation," Code of FederalRegulations, Office of the Federal Register, as amended.

10 CFR 50.59, "Changes, Tests, and Experiments," Code of FederalRegulations, Office of the Federal Register, as amended.

40 CFR 61, "National Emission Standards for Hazardous Air Pollutants," Code of FederalRegulations, Office of the Federal Register, as amended.

40 CFR 261, "Identification and Listing of Hazardous Waste," Code of FederalRegulations, Office of the Federal Register, as amended.

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

ANSI/ANS 15.16, Emergency Planningfor Research Reactors, Withdrawn 2008, American Nuclear Society, La Grange Park, Illinois, 1982 (W2008).

BLS, 2012, "May 2012 Metropolitan and Nonmetropolitan Area Occupational Employment and Wage Estimates," www.bls.gov/oes/current/oessrcma.htm, U.S. Bureau of Labor Statistics, Washington, D.C., accessed September 2013.

CATSO, 2015a, 2040 Long-Range TransportationPlan, Columbia Area Transportation Study Organization (CATSO), Columbia, Missouri, 2015.

CATS O, 2015b, Appendix Q - CAT SO Major Roadway Plan Network by Segment, Columbia Area Transportation Study Organization (CATSO), Columbia, Missouri, 2015.

CDT, 2013, "MU, Company Partner to Boost Supply of Isotope Used in Diagnostic Drug," Columbia Daily Tribune, http:/wwcolumbiatribune. com/news/education/mu-company-partner-to-boost-supply-of-isotope-used-in/article_0c707d88-4909-11 e3-9ef7- 10604b9f6eda.html, Columbia, Missouri, November 9, 2013.

CDT, 2015a, "New Hospital Adds to Longstanding Fulton Medical Center, MU Health Care Partnership,"

Columbia Daily Tribune, Columbia, Missouri, May 17, 2015.

CDT, 2015b, "New Hospital Not Needed, Says the Committee," Columbia Daily Tribune, Columbia, Missouri, July 18, 2015.

CDT, 2015c, "Kraft Plans $114 million Columbia Expansion," Columbia Daily Tribune, Columbia, Missouri, July 9, 2015.

City of Columbia, 2008, 2030 CATSO Long Range TransportationPlan, City of Columbia Department of Planning and Development, Columbia, Missouri, http://www.gocolumbiamo.com/community-development/wp-content/uploads/sites/1 4/2015/09/2030OTransportationPlanFinal.pdf, June 20, 2008.

City of Columbia, 2012a, City of ColumbiaFY 20l3 CIP PlanningDocument, https ://www.gocolumbiamo.com/Finance/S ervicesiFinancial_Reports/index.php, Columbia, Missouri, October 1, 2012.

City of Columbia, 2012b, "Columbia City View," zoning map, Geospatial Information Office, www.gocolumbiamo.com/Maps/City View, Columbia, Missouri, accessed July 2013.

56 of 58

o N.WE,,C,*to*,OoP,,

MEUU I3VM-01-A-0 Rev. 0 City of Columbia, 2012c, Columbia Code of Ordinances, Chapter 29 - Section 29-18, District M-R, Planned Research, Development and Office Park District, www.gocolumbiamo.com/Council/Columbia Code of Ordinances/Chapter_29/index.html, Columbia, Missouri, accessed August 2013.

City of Corvallis, 2000, City of Corvallis Comprehensive Plan, Corvallis, Oregon, June 26, 2000.

CW&L, 2013, "New South Substation & Transmission Lines Public Hearing,"

hftps ://www.gocolumbiamo.com/WaterandLight/Electric/ProposedElectricTransmission.php, Columbia Water and Light, Columbia, Missouri, July 15, 2013.

EDF-3 124-0008, Emissionsfrom Natural Gas-FiredBoiler and Emergency Diesel Generator Operation, Rev. 0A, Portage, Inc., June 26, 2014.

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

EDF-3 124-0011, Greenhouse Gas Emissions, Rev. 1, Portage, Inc., Idaho Falls, Idaho, July 31, 2015.

EDF-3 124-00 12, Emission Modelingfor Process and HVA C Boilers Using AERSCREEN, Rev. 1, Portage, Inc., Idaho Falls, Idaho, February 4, 2015.

EDF-3 124-00 13, On-RoadEmissionsfor Vehicles During Operations,Rev. 1, Portage, Inc., Idaho Falls, Idaho, July 31, 2015.

EDF-3 124-00 14, Emission Modelingfor ConstructionActivities using AERSCREEN, Rev. 1, Portage, Inc., Idaho Falls, Idaho, June 26, 2015.

H-84 10-1, Visual Resource Inventory Manual, U.S. Department of Land Management, Bureau of Land Management, Washington D.C., January 1986.

MIHFRC, 2015, Certificate of Need Application, ProjectNo. 5210 NS, Landmark Hospital Transitional Recovery Center of Columbia, Missouri Health Facilities Review Committee, Columbia, Missouri, July 2, 2015.

Missouri Revised Statutes, Chapter 172, Section 172.273, "Research, development and office park projects established, when--procedure--curators' powers--real property exempt from zoning, ordinances and property tax--permits, licenses and certificates may be issued, when, application of sovereign and official immunity and public duty doctrines," Missouri General Assembly, Jefferson City, Missouri, as amended, August 28, 2012.

MU, 2009, Discovery Ridge Master Plan and Protective Covenants, https ://uminfopoint.umsystem.edu/media/ed/Discoveryridge/masterplan-discoveryridge.pdf, University of Missouri, Columbia, Missouri, January 6, 2009.

NAS, 2009, Medical Isotopes Production Without Highly Enriched Uranium, National Academy of Sciences, Washington D.C, 2009.

NEA, 2012, A Supply and Demand Update of the Molybdenum-99 Market, Organization for Economic Cooperation and Development/Nuclear Energy Agency, Paris, France, August 2012.

NBA, 2015, The Supply ofMedical Isotopes - 2015 Medical Isotope Supply Review:"99Mo/t 9mTc Market Demand and Production Capacity Projection2015-2 020, Organization for Economic Cooperation and Development/Nuclear Energy Agency, Paris, France, August 2015.

NUREG-1 537, Guidelinesfor Preparingand Reviewing Applications for the Licensing of Non-Power Reactors - Format and Content, Part 1, U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Washington, D.C., February 1996.

57 of 58

• YI.*o.

• ]RlWST ME'DICDI.

TDPES NW MI ~NWMI-201 5-RAI-OO1ei NWMI-2013-002, 2013, Alternative Site Selection for the Radioisotope Production Facility, Rev. 2, Northwest Medical Isotopes, LLC, Corvallis, Oregon, June 9, 2015.

NWMI-20 13 -CALC-002, Overall Summary Material Balance - OSU Target Batch, Rev. B, Northwest Medical Isotopes, LLC, Corvallis, Oregon January 29, 2015.

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

NWMI-20 15-SDD-0 11, Utility Systems SDD, Rev. A, Northwest Medical Isotopes, LLC, Corvallis, Oregon, February 18, 2015.

OAR 340-101-0033, "Additional Hazardous Wastes," Oregon Administrative Rule, as amended.

Regulatory Guide 2.6, Emergency Planningfor Research and Test Reactors, Rev. 1, U.S. Nuclear Regulatory Commission, Washington, D.C., March 1983.

Regulatory Guide 4.20, Constrainton Releases of Airborne RadioactiveMaterials to the Environmentfor Licensees Other Than Power Reactors, Rev. 1, U.S. Nuclear Regulatory Commission, Washington, D.C., April 2012 RS&H No. 226-1077-000, Columbia RegionalAirport (COU) Columbia, Missouri Draft Environmental Assessment, City of Columbia and U.S. Department of Transportation - Federal Aviation Administration, http://www.flycou.com/?page_id='342, Columbia, Missouri, January 2012.

Terracon, 201 la, PhaseI Environmental Site Assessment Discovery Ridge 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. 09117701, March 23, 2011.

Terracon, 201 lb, PreliminaryGeotechnicalEngineeringReport 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.

58 of 58

• • • rNW

• .: MI

VVVIIRev. NwMI-2o1 5-RAI-O010 APPENDICES Appendix A - EDF-3 124-0011, Greenhouse Gas Emissions.................................................. A-i Appendix B - EDF-3 124-0008, Emissions from Natural Gas-Fired Boiler Operation...................... B-i Appendix C - EDF-3 124-001:2, Emission Modeling for Process and HVAC Boilers Using AERSCREEN..................................................................................... C-i Appendix D - EDF-3 124-00 13, On-Road Emissions for Vehicles During Operation...................... D-i Appendix E - Northwest Medical Isotopes, LLC Alternative Site Evaluation .............................. E-i Appendix F - Oregon State University TRIGA Reactor Emergency Response Plan ....................... F-i Appendix G - University of Missouri Research Reactor Emergency Response Plan....................... G-i Appendix H - Phase I Environmental Site Assessment Discovery Ridge Lots 2, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, and 18 Terracon (Terracon, 2011a) ............................... H-i Appendix I - NWMI-2015-RPT-002, Radioisotope Production Facility Vegetation Assessment.......... I-i Appendix J - NWM\I-2015-RPT-001, Radioisotope Production Facility Surrounding Property Assessment ........................................................................................ J-i Appendix K - Preliminary Geotechnical Engineering Report Discovery Ridge - Certified Site Program Lots 2, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, and 18 (Terracon, 201lb) ............................................................................................. K-i

NWMJ-201 5-RAI-001

• *N$*,,W[SM!DC*STP. Rev. 0 Appendix A -

EDF-3124-0011, Greenhouse Gas Emissions A-i

Document ID:EDF-3124-001 1 Revision ID:1 Effective Date:July 31, 2015 Engineering Design File Greenhouse Gas Emissions Portage Project No.: 3124 Project

Title:

NWMI Environmental Report 4Portage TEM-9002 09/29/09 Rev. 0

TEM-9002 ENGINEERING DESIGN FILE EDF-3124-001 1 09/29/09 Rev. 1 Rev. 0 Page 1 of 5

1. Portage Project No.: 3124

2. Proj ectlTask: NWMI Environmental Report DCN#

Title:

Greenhouse Gas Emissions 5 NPH PC orSDC: N/A 6 SSC Safety Category: N/A 7 Summary: This EDF presents the total CO 2 emissions from all the sources identified for both the construction phase and annual operation.

8 Distribution: (Portage, Inc.)

9. Review (Identify(R) and Approval minimutm reviews(A)andSignatures:

approvals. Additional reviews/approvals may be added.)

Printed Name/

R/A Organization. Signature Date Author/Design Agent A Gary McManus (),5 * [8v* 7/31/15 Independent Review R Dave Thomne

• 7/31/15 Independent Review R Project Manager RJA John Beller 7/31/15 Registered Professional Engineer's Stamp (if required) E]N/A

TEM-9002 ENGINEERING DESIGN FILE EDF-3124-001 1 09/29/09 Rev. 1 Rev. 0 Page 2 of 5 INTRODUCTION AND PURPOSE Greenhouse Gases trap heat in the atmosphere, absorbing and emitting radiation in the thermal infrared range. The most important of these gases are C02, methane, nitrous oxide, and fluorinated gases. GHGs are reported as CO2 equivalent (CO2e) and refer to the global warming potential of the GHG or gases being emitted.

Activities associated with the proposed RPF site that are expected to contribute to GHGs include:

Construction activities at the site (assumed to last 17 months, 73.7 weeks) principally resulting in emissions of GO 2; GHG emissions associated with construction activities include:

• The commuting construction workforce.

• Operation of construction equipment at the site.

• Operation of on-road construction vehicles.

These GHG emissions are summarized in Table 1 below.

Table 1. GHG Emissions from Construction Phase Activities Source (lbs) (kg) (ton) (tonne)

Commuting Construction Workers a 1,220,000 552,000 610 552 Operation of Construction Equipment at site b 56,600 125,000 28 13 Operation of on-Road Construction Vehicles a 97,000 43,000 49 43

a. EDF 3 124-0005, On-road Vehicle Emissions During ConstructionRev 1. Portage, Inc, Idaho Falls, ID, July 31, 2015

b. EDF 3 124-0009, Off-road Vehicle Emissions During Construction Rev 1. Portage, Inc, Idaho Falls, ID, July 31, 2015 Plant operation activities associated with the operation of plant equipment and the operations workforce.

This includes:

• The commuting work force

• The four natural gas boilers -

• The emergency diesel generator These GHG emissions are summarized in Table 2 below:

TEM-9002 EDF-31 24-0011 09/29/09 ENGINEERING DESIGN FILE Rev. 1 Rev. 0 Page 3 of 5 Table 2. GHG Emissions during Plant Operation Source (lbs) (kg) (tons) (tonnes)

Daily Workforce Commuting a 860,000 -390,000 440 400 Natural Gas Boilers b 51,000,000 23,000,000 26,000 23,000 Emergency Diesel Generator b 97,000 -44,000 49 44

a. EDF 3124-0013, On-roadEmnissionfor Vehicles Suring Operation, Rev 1. Portage, Inc, Idaho Falls, ID, July 31, 2015

b. EDF 3 124-0008, Emission from Natural Gas Boiler Operation, Rev 0. Portage, Inc, Idaho Falls, ID, June 26, 2014 From Tables 1 and 2 the total GHG emissions for the construction and operation phases of the project are summarized and presented in Table 3 below.

Table 3. Total GHG Emissions during Construction Phase and Normal Operations Phase Source (lbs) (kg) (tons) (tonnes)

Construction Phase 1,500,000 660,000 730 660 0peration Phase 52,000,000 24,000,000 26,000 24,000

TEM-9002 ENGINEERING DESIGN FILE EDF-3124-0011I 09/29/09 Rev. 1 Rev. 0 Page 4of 5

Attachment:

Excel spreadsheets of calculations

__________Source (ibs) (kg (tons) Lt Commuting Construction

_________W res1,220,000 552,000 610 552 Operatio n of Construction 9740 4,0 49 3

________________Equipment at site _____

Operation of on-Road 1462 5,1 2 5

________________ ConstructionVehicles _____ ____

_________Total 1,442,002 651,818 721 652 Construction Phase CO2

______________ Commuting Construction ______ ______ ____

__________Workers (kgs) (lbs) [(to nnes) (ton)

__________ Light Duty Auto (gas) 320,000 700,000 320 350

_________ Light duty Trucks (gas) 180,000 400,000 180 200

__________ Light duty Trucks (diesel) 52,000 120,000 J 5'2 60

_________Total 552,000 1 1,220,000 1 552 1 610

_ __ _ _ _ _ _ _ _ I __ I _ _ _ _

Operation of Construction Equipment at site O

_______________________________(_____ Q ) (lbs) (tonnes) (ton)

Light Heavy Duty Delivery Trucks 15,000 34,000 15 17 Hev uyHaulers 3,300 7,200 3 4 CntutnTrcsConcrete 24,000 54,000 24 27 1,000 2,200 1 1 1

_________Asphalt

_________Total 43,300 [ 97,400 1 43___ 49___

__ _ _ _ _ _ _ _ I _ _ _ _

Operation of Off-Road Construction Equipment at CO2_________

____________ site (kgs) (lbs) (tonnes) (ton)

_________Bulldozer 13,025 28,715 13 14

_________Compactor 9,670 21,318 10 11

_________Excavators 9,065 19,986 9 10

_________Front Loaders 3,126 6,892 3 3 Graders 6,044 13,324 6 7

_________Paver 5,919 13,048 6 7 Roller 9,670 21,318 10 11 1

_________Asphalt

_________Total 56,518 124,602 1 57 62 I- I I- +/- 1-

TEM-9002 EDF-3124-001 1 09/29/09 ENGINEERING DESIGN FILE Rev. 1 Rev. 0 Page 5 of 5 GHG Release During Plant Operation_____ ____

Daily Workforce Commuting CO2 S(kgs) (ibs) (tonnes) (ton)

_________Light Duty Auto (gas) 225,239 496,569 225 248

________Light duty Trucks (gas) 129,506 285,513 130 143 Light duty Trucks (diesel) 37,004 81,580 37 41

_________Daily Workforce Commuting 391,749 863,662 392 432

_________Natural Gas Boilers 23,586,803 52,000,000 23,187 26,000

__________Emergency Diesel Generator 44,000 97,003 44 49 i V Operations Summary So urce (lbs) kg) (to ns) (t Daily Workforce Commuting 863,662 391,749 432 392 Natural Gas Boilers 52,000,000 23,586,803 26,000 23,587 Emergency Diesel Generator 97,003 44,000 . 49 44 Operation Phase 52,960,665 24,022,552 26,480 24,023 Construction Phase [1,451,967 I658,598 [726 I 659

_ _ __ _ _ _ _ _ _ I _ _ I _ _