ML18025B172

Official Exhibit - NRC-006I-MA-CM01 - Northwest Medical Isotopes, LLC, Construction Permit Application - PSAR, NWMI-2013-021, Rev. Oa, Chapter 19,19-131 Through End (Jun. 2015)

ML18025B172
Person / Time
Site:	Northwest Medical Isotopes
Issue date:	06/30/2015
From:	NRC/OGC
To:	NRC/OCM
SECY RAS
References
50-609-CP, Construction Permit Mndtry Hrg, RAS 54184
Download: ML18025B172 (258)

Text

Chptr1WWMI01-21 ev. QEUVYChapter 9.0 -Environmental Review19.3.5 Ecological ResourcesThis section describes the terrestrial and aquatic communities within the ROI (8 km [5-mi] radius fromthe proposed RPF) and provides a baseline characterization of the site ecology prior to any disturbancesassociated with the construction and operation of the proposed facility. Prior environmental disturbancesnot associated with the proposed facility are considered when describing the baseline condition.Consultations with the Missouri Department of Conservation (MDC) and U.S. Fish and Wildlife Service(USFWS) were initiated for information regarding ecological resources within the ROI (Haass, 200 14a,Haass, 2014b). The consultation process was used to obtain agency input regarding threatened andendangered species, sensitive habitats, commercial and recreational species, and other ecologicalcharacteristics of the ROI. Ecological resources described herein are based on recorded information fromresource agencies.19.3.5.1 WetlandsWetlands are classified by the EPA as "areas where water covers the soil, or is present either at or nearthe surface of the soil all year or for varying periods of time during the year, including during the growingseason. Water saturation (hydrology) largely determines how the soil develops and the types of plant andanimal communities living in and on the soil. Wetlands may support both aquatic and terrestrial species.The prolonged presence of water creates conditions that favor the growth of specially adapted plants(hydrophytes) and promote development of characteristic wetland (hydric) soils" (EPA, 2013a).According to MDNR Water Resources Report No. 39 (Epperson, 1992), the amount of wetland loss inMissouri has exceeded the national average, and 87 percent of the state's original 1.9 million ha(4.8 million acres) of wetlands have been destroyed. Of the original 9.7 million ha (2.4 million acres) offorested wetlands in southeast Missouri, less than 24,281 ha (60,000 acres) or 2 percent remain intact.Statewide, 13 percent of the original wetland resources remain. These remaining wetlands account for1.4 percent of the land surface.Detailed discussions of natural wetland types and locations within the ROI are discussed inSections 19.3.5.3 and 19.3.5.5.1 9.3.5.1.1 Surface Water Runoff ProtectionWetlands have important filtering capabilities for intercepting surface water runoff from higher dry landbefore the runoff reaches open water. As the runoff passes through, the wetlands retain excess nutrientsand some pollutants, and reduce sediment loads that would otherwise deposit and clog waterways,affecting fish and amphibian egg development. "In performing this filtering function, some wetlandsmaintain stream flow during dry periods, and many replenish groundwater supplies" (EPA, 2013a).19.3.5.1.2 Flood Water ProtectionAccording to the EPA, "Wetlands function as natural sponges that trap and slowly release surface water,rain, snowmelt, groundwater, and flood waters. Trees, root mates, and other wetland vegetation also slowthe speed of flood waters and distributes them more slowly over the floodplain. This combined waterstorage and braking action lowers flood heights and reduces erosion" (EPA, 2013a).Wetlands within and downstream of urban areas are particularly valuable, counteracting the greatlyincreased rate and volume of surface water runoff from impervious surfaces. In addition, the holdingcapacity of wetlands helps control floods and prevents water-logging of crops.19-131/

• ~*NWKRI NWM,-2013-021, Rev. 0Evil Chapter 19.0 -Environmental Review* =.° "NOEITAWEST MEDICAL ISOTOPES19.3.5.1.3 Fish and Wildlife HabitatMore than one-third of the U.S. threatened and endangered species live only in wetlands. EPA states thefollowing:For many animals and plants, like wood ducks, muskrat, cattails, and swamp rose, inland(non-tidal) wetlands are the only places they can live. Many of the U.S. breeding birdpopulations including ducks, geese, woodpeckers, hawks, wading birds, and many song-birdsfeed. nest, and raise their young in wetlands. Migrator. waterfowl use coastal and inlandwetlands as resting, feeding, breeding, or nesting grounds for at least part of the year.An. international agreement to protect wetlands of intern7ational importance was developedbecause some species of migratory birds are completely dependent on certain wetlands andwould become extinct if those wetlands were destroyed. (EPA, 201 3a)19.3.5.2 Offsite AreasThe EPA has established a spatial network of ecoregions for the research and monitoring of ecosystems.Ecoregions are areas of relatively uniform ecological systems that have similar vegetation, climate,geology, and physiology. Missouri is divided into seven Level III Ecoregions, of which two occur in theROI. Ecoregions within the ROI are the Central Irregular Plains and Interior River Valleys and Hills.These Level III Ecoregions are further subdivided into Level IV Ecoregions or subregions. Thesubregions that occur in the ROT are the Claypan Prairie and River Hills. Figure 19-38 illustrates thelocation of the ROT in relation to the ecoregions and subregions. Descriptions by Chapman et al. (2002)for each of the subregions are used to evaluate the current ecological condition of the ROT.The subregion Claypan Prairie of the Central Irregular Plains Ecoregion is characterized by well-developed claypan soils located on gently rolling topography (Chapman et al., 2002). Vegetationcommunities that are common to this subregion include white oak dry woodland, hardpan prairieslowland flatwoods, and ephemeral marshes. Historically, the region was mostly tall grass prairies withseasonally inundated wetlands (Nigh and Schroeder, 2002). After European settlement, the regionexperienced a conversion to cropland and pasture because of the gently rolling topography and soil withlittle natural vegetation remaining (Chapman et al., 2002; Nigh and Schroeder, 2002). The ClaypanPrairie subregion covers approximately 52 percent of the ROT.The subregion River Hills of the Interior River Valleys and Hills Ecoregion is characterized by forestedriver side-slopes and bluffs, some loess-covered hills, and areas with karst features located on a smooth tomoderately dissected topography. This subregion lies along the Missouri River and is a transition zonebetween the flatter plains to the north and the Ozark Highlands to the south (Chapman et al., 2002). TheMissouri River is not located within the ROT. Vegetation communities that are common to this subregioninclude white oak forests, oak savannas, and sugar maple mesic forests. Historically, this region wascovered in timber with glades and sinkhole ponds (Nigh and Schroeder, 2002). After Europeansettlement, many areas remained forests, especially rugged areas, with some of the mixed hardwoodforests converted to pasture (Chapman et al., 2002). The River Hills subregion covers approximately48 percent of the ROT.19-132

~. ., NRTWESMEIC$TP$NWMI-2013-021, Rev. GAChapter 19.0 -Environmental ReviewAk RPF Site8 km (5 mile) Radius from RPF SitesmsInterstate Highways--- Highways'?City Limitso 0.45 0.9 1.8 2.7 3.6, , MileCiato: EPAIB 2010 Level IV Ecoregions of Mitsourl(digital data]: fplntp /fpepa gowedtecoregions,/molmo~eco13.Level IV EcoregionNameClaypan PrairieRiver HillsPrairie Ozark BorderN.zpFigure 19-38. Region of Influence in Relation to Ecoregions and Subregions19-1 33 l...v.......... Chpe9.0 -Environmental Review19.3.5.3 Onsite AreasThe proposed RPF site is located within a 3 ha (7.4-acre) parcel in Discovery Ridge. Because ofcontinuous land disturbance associated with agricultural practices, the site is devoid of natural landscapessuch as forests, prairies, and other natural plant communities. Within the 2.99 ha (7.4-acre) parcel thereare no ephemeral, intermittent, or perennial streams and associated riparian zones.Land cover within the ROI is discussed in detail in Section 19.3.1.1, and is illustrated in Figure 19-15.Urban development accounts for approximately 5,059 ha (12,500 acres), or 25 percent, of the ROI.Developed lands include lands mapped as open spaces, low intensity, medium intensity, and highintensity.Agricultural pasture land and cultivated crops account for approximately 8,013 ha (19,800 acres), or39 percent, of the ROI. Pasture land within the ROI consists of property that is used for the raising oflivestock or hay production. Cultivated crops consist of soybeans, corn, wheat, and sorghum.Forested habitats account for approximately 6,758 ha (16,700 acres), or 33 percent, of the ROI. This landconsists of deciduous forests, evergreen forests, and mixed forests. The majority of this land is thedeciduous forests that account for 31 percent of the ROI. These deciduous forests are comprised of whiteoak forests, oak dry woodlands, and black oak woodlands. These forests are located in the river side-slopes and bluffs and mixed throughout the developed areas.Wetlands within the ROI were mapped using the USFWS National Wetlands Inventory data (USFWS,2010) and are discussed in detail in Section 19.3.5.1. Figure 19-39 shows known wetlands and waterbodies located in the ROI. Based on the inventory data, wetlands make up approximately 168 ha(415 acres), or less than 1 percent, of the total ROI. Forest/shrub wetlands and freshwater emergentwetlands make up the mapped wetlands. A total of 306 ha (755 acres), or 1.5 percent, were mapped asopen water. Grassland resources account for 140 ha (345 acres), or less than 1 percent, of the ROI. Scruband barren lands account for less than 1 percent of the ROI.19-1 34

..,...NWMI.* .-f* "NONThW S MW tA SOTOpEsNWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewA RPF Site Wetlands8 km (5 mile) Radius from RPF Site TypeInterstate thighways Frc~-Iighw~ays Fre~qcr.L , t iy Limits (31 Fre,,o5 1 2 :3 4 Lak0shwatcr Emergent Wetlandshwater Forested/Shrub Wetlandshwatcr Pond[CtrineCalMS UUWtS 2010 .MMsyfTA'Figure 19-39.v vRiv,Wetlands Map19-1 35

• • • NW MI NWMI-2013-021, Rev. GA: OTPESChapter 19.0 -Environmental Review""..: NORTMWEST EI ALiTOE19.3.5.4 HistoryAs discussed in Section 3.1.1, the ROI is located in the Claypan Prairie and River Hills subregions of theCentral Irregular Plains and the Interior River Valleys and Hills ecoregions, respectively. BeforeEuropean settlement, these areas consisted of tall grass prairies, seasonally inundated wetlands, and oakwoodlands. The encroachment of forests into native grasslands would have been limited by fire, grazing,and periodic ponding water (Nigh and Schroeder, 2002). After European settlement, much of the naturalvegetation in the tall grass prairies and oak savannas were cleared for agricultural and urban development.Oak woodlands in rugged areas located in drainages were mostly left intact. Few remnant tall grassprairies and oak savannas remain as the rest has been developed. As part of agricultural development,many of the existing wetlands were drained and surface water was channelized. The proposed RPF site iszoned for agricultural use, indicating that the site has been used for the cultivation of crops and pastureland.19.3.5.5 Places and Entities of Special InterestThis section provides information relative to ecological resources of special interest within the ROI.Ecological resources of special interest include (1) identified natural ecological communities, (2) sensitiveor susceptible areas, and (3) important ecological systems. These resources are discussed in the followingsubsections.19.3 .5.5.1 Ecological CommunitiesThe Missouri Heritage Program identifies and tracks high-quality terrestrial natural communities becausethey provide diverse assemblages of native species. High-quality communities include those that areintact and represent the least distressed examples of ecosystems that existed prior to European settlement.Terrestrial natural communities that are ranked as critically imperiled, imperiled, or vulnerable areconsidered to be communities of conservation concern (MDC, 2013). The "Missouri Electronic FieldOffice Technical Guide" was used to identify communities of conservation concern within the ROI(USDA, 2013b). There are four listed terrestrial and aquatic natural communities within the ROI:White oak forests -The white oak forest communities have been classified as imperiled by theMissouri Heritage Program. These forest communities usually occur on relatively steep slopesabove river corridors and extend from the valley bottoms to ridge tops. These areas have a well-developed forest canopy and subcanopy dominated by a mixture of white oak (Qutercus alba),sugar maple (Acer saccharum), pawpaw (Asimina triloba), and other hardwoods (USDA, 2013b).Common shrubs and forbs include fragrant sumac (Rims aromatic), wild blue phlox (Phloxdivaricata), and woodnettle (Laportea canadensis) (USDA, 2013b). Common wildlife speciesinclude white-tailed deer (Odocoileus virginianus), great crested flycatcher (Myiarchus crinitus),and ringed salamander (Anmbystomna annulatum) (MDC, 2010).*Mixed oak loess/glacial till woodlands -The mixed oak loess/glacial till woodland communitieshave been classified as imperiled by the Missouri Heritage Program. These woodlandcommunities usually occur adjacent to the Missouri River floodplains on upland summit crests(USDA, 2013b). They have a well-developed forest canopy that consists of white oak (quercusalba), black oak (Quercu.s i'elutina), and post oak (Qumercus stellata). Common shrubs and forbsinclude American hazelnut (Corvlus Americana), elm-leafed goldenrod (Solidago ulmifolia), andsmooth blue aster (Aster laevis) (USDA, 2013b). Common wildlife species include wild turkey(Meleagris gallopavo), red-headed woodpecker (Melanerpes erythrocephalus), and tigersalamander (Ambystoma tigrinum) (MDC, 2010).19-136 NW M I WM-030,Rev.MEICL SOOPSChapter 19.0 -Environmental ReviewLoess/glacial till prairies -The loess/glacial till prairie communities have been classified asimperiled and critically imperiled by the Missouri Heritage Program. These prairie communitiesusually occur in areas of low relief with low slope gradients and narrow drainages (USDA,2013b). They are characterized by tall grass prairies that area dominated by little bluestem(Schizachyrium scoparium), Indian grass (Sorghastrum~r nutans), and sideoats grama (Boiutelouacurtipendula). Post oak (Quercus stellata), American hazelnut (Corvlus Americana), and prairiewillow (Salix humilis) occasionally occur in small groves. Common shrubs and forbs includelead plant (Amorpha canescens) and purple prairie clover (Dalea purpurea). Common wildlifespecies include white-tailed deer (Odocoileuis virginianus), upland sandpiper (Bartramialon gicauda), and western slender glass lizard (Ophisaiurus attemnuates) (USDA, 2013b).* Emergent wetlands and shrub swamps -As stated in Section 19.3.5.1, the majority ofdesignated wetlands within the ROI are freshwater ponds, lakes, and rivers. Approximately168 ha (415 acres) of the ROI consist of emergent wetlands (marshes and fens) andforested/shrub wetlands (shrub swaps). Emergent wetlands have standing water for long periodsduring the growing season. Plant species include cattails (Typhaceae latifolia), bulrushes(Schoenopiectus spp), and sedges (Cyperaceae spp). Wildlife species that are common toemergent wetlands include bitterns (Botaurus lentiginosus), pied-billed grebes (podilymbuspodiceps), and muskrats (Ondatra zibethicu.s). Shrub swamps are wetland thickets withbuttonbush (Cephalan thus occidentalis) and willows (Salix spp). Common wildlife speciesinclude yellow warblers (Dendroica petechia) and green herons (Butorides i'irescens)(Leahy, 2010).Due to the urban and agricultural development in the ROT, these listed communities and their remnantsare likely to occur in protected areas such as parks and conservation areas.There are three State and Federally protected areas within the ROT: Rock Bridge State Park, Three RiverConservation Area, and the northwest corner of the Mark Twain National Forest. The Rock Bridge StateMemorial Park is an 858 ha (2,120-acre) park managed by the MDNR that consists of karsts, grasslands,and oak woodlands and forests. This state park also contains the Gans Creek Wild Area. The ThreeRiver Conservation Area is a 607 ha (1,500-acre) natural preserve managed by MDC that consists ofmostly of oak forests and woodlands, with similar plant and wildlife species as described for thosecommunities. A small portion of the Mark Twain National Forest, Cedar Creek Ranger District, is alsolocated within the ROT. The forest consists of tall grass prairies and shortleaf pine-oak woodlands, withplants and wildlife species as described for those communities.Given the current conditions of the proposed site, the area appears to have been prairie habitat before itsconversion to agriculture. However, because the site has been used for agriculture and other developeduses for many years, none of the habitat types discussed in this section are present on the proposed RPFsite or immediately adjacent to the site.1 9.3 .5.5.2 Other Sensitive or Susceptible AreasThere are several parks, natural areas, and nature trails within the city limits of Columbia, Missouri. TheGrindstone Natural Area and Waters Moss Memorial Wildlife Area are Colombia city park and recreationareas in the southeastern part of the city and consist mostly of white oak forests and woodlands withcommon plants and wildlife species as described for those communities. Philips Park and Gans CreekRecreation Area lie directly to the west of the proposed site and consist of mix oak woodlands, tall grassprairies, and a lake. Wildlife and plant species that occur in these communities are similar to thedescribed communities in Section 19.3.5.5.1, in addition to fish species such as channel catfish (lctaluruspunctatus) and black bass (Micropterus spp). Nature trails include MKT Trail and Hinkson Creek Trail.These trails are located in terrestrial communities similar to the Grindstone Natural Area.19-1 37 NOSIWEIMEIASTPSChpe1 NWMI-2013-O21, Rev. OAlviChptr 9.0 -Environmental Review19.3 .5.5.3 Important Ecological SystemsThe ROI is located along the Mississippi flyway (USFWS, 2013a). Natural habitats (e.g., wetlands,creeks, lakes, and tall grass prairies) within the ROI are useful to migrating birds for resting, feeding, andforaging. These natural areas are used by neotropical birds during migration and as potential habitats fornesting and nursery areas. Habitats of the proposed site are dominated by agricultural and developed usesand are not considered high value for migrating birds. There are several areas adjacent to the proposedsite that include surface water (e.g., lakes, stormwater discharge areas) and other surface water locationsthat could be used by migrating birds.19.3.5.6 Aquatic Communities and Potentially Affected Water BodiesThere are no aquatic resources or water bodies present on the proposed RPF site. The water bodies in theROI are within the Bonne Femme and Hinkson Creek watersheds. These areas contain several waterbodies, including Philips Lake, Gans Creek, Hinkson Creek, Clear Creek, and several others. Specificinformation on water bodies within the ROI is provided in Section 19.3.4.Based on topographic maps of the proposed site, the majority of site runoff flows into designatedstormwater management areas. These areas are not expected to provide ideal habitat for many aquaticspecies because the water is intermittent.Water bodies within the ROI are not expected to contain Federally listed threatened or endangered fishspecies. However, perennial streams have a diverse mix of invertebrate and vertebrate species.Invertebrate species include mayflies, stoneflies, caddisflies, dragonflies, beetles, small crustaceans, andsnails. Based on stream monitoring surveys, 18 to 27 invertebrate species are estimated to inhabit streamswithin the Bonne Femme Watershed. The estimated number of fish species within the Bonne FemmeWatershed ranges from 11 to 17 species of shiners, suckers, redhorse, sunfish, bass, darters, andstonerollers. An indicator of good aquatic community health is strong diversity of species or high speciesrichness. Previous sampling events conducted by MDNR at streams and other water bodies near theproposed site were at least partially biologically supporting (i.e., contained sufficient species to indicategood water quality) (BFSC, 2007).The closest water body to the proposed RPF site is Gans Creek, which is located approximately 0.5 km(0.3 mi) to the south. Gans Creek, like most of the streams within the ROI, contains a rocky substratefree of sediment. The MDNR has listed Gans Creek as an impaired water body. Specific information onGans Creek is provided in Section 19.3.4. No Federally listed threatened or endangered fish species isknown to exist in Gans Creek, but the creek has a diverse mix of invertebrate and vertebrate species(BFSC, 2007). Because of the existing stormwater management system near the proposed site, impactson Gans Creek from construction or operational activities are not anticipated.Wetlands are transitional ecosystems between aquatic and terrestrial systems where the water table isusually at or near the surface or the land is covered by shallow water (Cowardin et al., 1979). Wetlandsvary widely because of regional and local differences in soils, topography, climate, hydrology, waterchemistry, vegetation, and other factors, including human disturbance. The CWA defines a wetland as"...those areas that are inundated or saturated by surface or groundwater at a frequency or durationsufficient to support, and that under normal circumstances do support, a prevalence of vegetation typicallyadapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, andsimilar areas." Based in the USFWS National Wetlands Inventory data, there are no recognized wetlandswithin the proposed site (USFWS, 2010). Figure 19-39 shows the locations for wetlands near theproposed RPF site.19-138 Chptr1MWI-0I-21 ev. QI': ChapterI19.0 -Environmental Review19.3.5.7 Terrestrial CommunitiesThis section provides a description and characterization of terrestrial communities identified at theproposed RPF site and within the ROI.19.3.5.7.1 Plant CommunitiesThe proposed site is located in a developed industrial park that was historically used as cultivatedcropland and pasture. The current vegetation at the site consists of mostly grasses reminiscent of openpastureland. Potential native plant species that may occur within the proposed site include thoseassociated with tall grass hardpan prairie (Nigh and Schroeder, 2002). These prairies are dominated bymedium-tall grasses and forbs with scattered shrubs and forbs (Faber-Lagendoen, 2001). Representativeplant species include little bluestem (Schizaclhyrium scopariurn), sideoats grama (Boutelouacurtipendula), winter bentgrass (Agrostis hyemnalis), and Atlantic camas (Camassia scilloides) (Nigh andSchroeder, 2002; Faber-Lagendoen, 2001).As discussed here and in Section 19.3.1.1, the land cover types found in proximity to the site are mainlyurban developed species, cultivated crops, and pastureland. There are several areas within the ROI thatare covered with deciduous forests, evergreen forests, and mixed forests. Most forested areas areprotected in parks and conservation areas.19.3.5.8 WildlifeThe following subsections discuss mammal, bird, amphibian, and reptile species that may occur within ornear the proposed RPF site. The potential for these species to occur within or near the site is based onresources available to the wildlife species. Representative mammal, bird, amphibian, and reptile speciesare discussed in relation to potential habitat within ecological communities that occur in the ROI.Ecological communities are defined in Section 19.3.5.5.1.19.3 .5.8.1 MammalsMammal species are not anticipated to be present at the proposed RPF site because of agricultural andurban development. Available resources (i.e., food, water, and cover) are not present year-round at thislocation. Mammal occurrence on the site is likely driven by the presence and life stage of the surroundingagricultural crops. Typical mammal species that have the potential to occur include species that aretypical for wildland/urban interface. These species include the white-tailed deer (Odocoileus i'irginiaus),eastern cottontail (Syh'ilagus floridanu.s), eastern chipmunk (Tamias striatus), raccoon (Procyon lotor),and red fox ( Vulpes vulpes) (Pitts and McGuire, 2000). No protected mammal species are known to occurat the proposed RPF site.In the area surrounding the proposed RPF site (within the 8 km [5-mi] radius ROL), opportunities formammal occurrence is similar to the proposed site because the land cover is comprised of mostlyagricultural and urban development. However, some areas have deciduous forests, evergreen forests, andmixed forests that provide suitable habitat for mammal species. These areas are located in Rock BridgeState Memorial Park, Three Rivers Conservation Area, and several other parks and protected areas.These areas are used for recreational hunting, especially for white-tailed deer and squirrel. Mammalspecies that occur in these areas include the white-tailed deer (Odocoileus virgin iaus), eastern graysquirrel (Sciurus carolinensis), raccoon (Proc yon lotor), eastern spotted skunk (Spilo gale putorius), andseveral species of bats, including the gray bat (Myotis grisescens) and Indiana bat (Myotis sodalist)(MDC, 2013; Pitts and McGuire, 2000). The gray bat and Indiana bat are listed as endangered by theUSFWS and Missouri (USFWS, 2013b; MDC, 2013). Listed species are discussed in Section 19.3.5.9.19-139

NW,'tChapter NWMI-2013-021, Rev. 0Alviie..,.-Chptr19.0- Environmental Review-e.- NODTEEWEST MEDICAL ISOTOPES19.3 .5.8.2 BirdsThe bird species observed at the proposed RPF site are anticipated to be transients because of the lack ofpermanent cover and other important resources. Typical bird species that may occur at the RPF site include:° Game species -Northern bobwhite (Colinus virginianus), wild turkey (Meleagris gaIlopaivo)* Migratory waterbirds -Sora (Porzana Carolina), common snipe (Gallinago gallina go), Virginiarail (Rallus limicola)° Migratory birds -American bittern (Botaurus lentiginosus), sedge wren (Cistothorus platensis),horned lark (Eremophilia alpestris), eastern meadowlark (Sturnella mnagna), field sparrow(Spizella pusilla), common yellowthroat Geothlypis trichas)" Overwintering birds -Short-eared owl (Asioflammeus), Le Conte's sparrow (Ammodrarnusleconte ii) (USDA, 2013b).The American bittern is listed as a State endangered species (MDC, 2013). Listed species are discussedin Section 19.3.5.9.In the area surrounding the proposed RPF site (within the 8 km [5-mi] radius RO!), opportunities for birdspecies to inhabit the area are similar to the proposed site because the land cover is mostly agriculturaland urban development. Bird species are known to inhabit these areas and will become habituated tourban and agricultural activities. Some areas have deciduous forests, evergreen forests, and mixed foreststhat provide suitable habitat for bird species. Bird species associated with these forested areas include theindigo bunting (Passerina cyanea), red-headed woodpecker (Melanerpes ervthrocephalus), easternbluebird ( Sialia sialis), northern bobwhite ( Colinus i'irginianus), eastern wood-pewee ( Contopus v'irens),broad-winged hawk (Buteo platvpterius), great-crested flycatcher (Alyiarchu~s crinitus), summer tanager(Piranga rubra), and red-eyed vireo ( Vireo oh'aceus) (USDA, 2013b). As stated in Section 19.3.5.5.3,the proposed RPF site is located in the Mississippi Flyway. With open surface water within the ROI,Canada geese and other migratory waterfowl are expected to use these areas for a temporary stopoverlocation. There are no documented rookeries near the proposed site or ROI.19.3 .5.8.3 Amphibians and ReptilesPotential amphibians and reptiles that may occur near the proposed RPF site are those typically found inupland prairie/tall grass prairie habitats. These species include the eastern tiger salamander (Amby stomatigrinum tigrin um), western chorns frog (Pseudacris triseriata triseriata), northern crawfish frog (Ranaareolata circulosa), ornate box turtle (Terrapene ornate ornate), western slender glass lizard (Ophisaurusattenuates attenuates), eastern yellow-bellied racer (Coluber constrictor flavi'entris), prairie ring-neckedsnake (Diadophis punctatus arnyi), and bullsnake (Pituophis catenifer sayi) (USDA, 2013b). Thesespecies are typically found in prairie habitats with nearby ponds/pools, which the stormwater drainageponds would provide at the proposed RPF site (USDA, 2013b).Potential amphibian and reptile species that may occur outside of the proposed site are those typicallyfound in oak woodlands and forests. These species include the eastern tiger salamander (Amnbystomatigrinum tigrinumn), ornate box turtle (Terrapene ornate ornate), northern fence lizard (Sceloporusunmdulatus), five-lined skink (Eumeces fasciatus), broad-headed skink (Eumneces laticeps), flat-headedsnake (Tantilla gracilus), and rough earth snake (Virginia striatula) (USDA, 201 3b).None of the potential amphibian or reptile species are Federal or State listed species (MDC, 2013).1 9.3.5.8.4 Invasive SpeciesNonnative species, as defined by Executive Order 13112 (1999), are species "whose introduction does oris likely to cause economic or environmental harm or harm to human health." Also defined in the Order,nonnative species include alien species that are defined as species that are not native to a particular ecosystemand include ant seeds, eggs, spores, or other biological material capable of propagating that species.19-140 NWINWMI-2013-021, Rev. GAChapter 19.0 -Environmental ReviewPer Executive Order 13112, Federal agencies are mandated to prevent the introduction of invasivespecies, detect and control populations, monitor invasive species populations, and restore native species inecosystems that have been invaded.Because there are no ponds, streams, or other water bodies on the proposed RPF site, aquatic invasivespecies are not present. Terrestrial invasive species that have the potential to occur on the site include tallfescue ( Festuca arundinacea), Canada thistle ( Cirsium arvense), crown vetch ( Securigera varia), andferal hogs (Sus Scrofa). The MDC has recommendations for managing these invasive species.19.3 .5.8.5 Procedures and ProtocolsThe proposed RPF site has been used for agricultural development for several decades. As such, the sitehas a history of frequent ground disturbance and herbicide applications to maximize row crop production.There are no ecological procedures or management plans for the proposed site.19.3.5.8.6 Studies and MonitoringThe MDNR maintains a water quality monitoring program that conducts aquatic biological and waterquality assessments throughout Missouri. The biological assessments are evaluations of the condition ofwater bodies using surveys and other direct measurements of macroinvertebrates, fish, and plants. Nearthe ROI, Cedar Creek is regularly sampled as part of the MDNR biological assessments (MDNR, 2011).Cedar Creek is located along the border of eastern Boone County and northwestern Callaway County, eastof the ROI. Section 19.3.4 provides additional information on water quality studies within the ROI.19.3.5.9 Protected Species and HabitatsFederal and State listed species within Boone County that are endangered, threatened, or are of specialconcern are listed in Table 19-44. There are no designated critical habitats within the ROI. The 10 plant,fish, bird, and mammal species that are Federal or State listed are discussed in the following subsections.Table 19-44. Federal and State Listed Endangered/Threatened,or Species of Special ConcernPallid sturgeonRunning buffalo cloverScaphirhynchus albusTrifolium stoloniferumEndangeredEndangeredEndangeredGray bat Myotis grisescensPlains spotted skunk Spilogale putorius interruptaEndangeredEndangeredEndangeredEndangeredEndangeredThr!American bitternBotaurus lentiginosusNorthern long-eared bat Myotis septentrionalisProposed endangereda USFWS, 2013b, "Missouri: County Distribution of Federally Listed Threatened, Endangered, Proposed,and Candidate Species," www.fws.gov/midwestlendangered/lists/missouri-cty.html, U.S. Fish and WildlifeService, Columbia, Missouri, updated August 2013.b MDC, 2013, Missouri Species and Communities of Conservation Concern Checklist, p. 52, MissouriDepartment of Conservation, Jefferson City, Missouri, January 2013.19-141

.N W "Catr1NWMI-21-2,Rev. OlviChptr 9.0 -Environmental Review* .* .., NORTHWEET MEDICAL ISOTOPES19.3 .5.9.1 Pallid SturgeonThe habitat of the pallid sturgeon includes large, free-flowing rivers that contain warm water and highturbidity. Within these river systems, pallid sturgeons use areas of chutes, backwaters, islands, sandbars,floodplains, and main-channel waters as macrohabitats. Historically, the Missouri River, where pallidsturgeons can be found, was an ideal habitat for this species because of the constant state of change(MDC, 2000a). Due to human development, the Missouri River and other suitable rivers are less dynamicand provide less suitable habitat. The pallid sturgeon is limited to the Missouri River, which is notlocated within the ROI and, therefore, is not likely to occur within the ROI.19.3.5.9.2 Topeka ShinerThe habitat of the Topeka shiner includes small prairie streams (or in areas of former prairies). Withinthese streams, Topeka shiners inhabit pools of clean water in little to no turbidity (MDC, 2000b). Thepreferred substrates are sand or clean rock and gravel. Most of the streams inhabited by this species flowyear-round, but some may not. These streams must be supplied enough groundwater seepage for the fishto survive. There is a potential for this species to occur in several of the streams within the ROL.Topeka shiner populations are adversely affected by increased sedimentation and turbidity enteringwaterways caused by the removal of riparian and upland vegetation. This species is reliant on good waterquality and habitat. Pollution runoff from adjacent lands into streams containing the Topeka shinerreduces the viability of this species. The Topeka shiner is an excellent indicator species for water qualitybecause of its sensitivity to habitat changes (MDC, 2000b).19.3.5.9.3 Running Buffalo CloverRunning buffalo clover habitat includes moderately moist areas with some sunlight, where moderatedisturbances such as grazing or mowing takes place periodically (MDC, 2000c). Historically, this specieswas often found in prairie/forest ecotones. Running buffalo clover is thought to have once beendependent on large grazing animals (e.g., elk, deer, or bison) for the dispersal of seeds and disturbance tothe soil. This species has the potential to occur within the ROI in areas of open woodlands and streambanks that experience moderate disturbance (e.g., mowing, trampling, or grazing).The loss of bison and other large ungulates has contributed to the population decline of running buffaloclover because these animals provided seed dispersal and soil scarification. Other potential causes for thepopulation decline include competition from invasive species, reduced fire frequency, and excessivegrazing (MDC, 2000c). Limited used of herbicides near potential clover habitat and mowing during theperiod of sexual reproduction help maintain suitable habitat for running buffalo clover.19.3.5.9.4 Indiana BatIndiana bats use two types of habitat depending on the season. During summer months, their habitatconsists of wooded or semi-wooded areas, often along streams, floodplains, or riparian areas where theyforage on insects (MDC, 2000d). During this time, female bats form maternity colonies to bear theiroffspring in hollow trees or under loose bark of living or dead trees. During the winter months, Indianabats hibernate in caves, karsts, or mines. These areas are chosen depending on the microclimate insidethe cavity. These species require very low and stable temperatures during hibernation to conserve bodyfat (MDC, 2000d). Both of these types of habitat occur within the ROI; therefore, the Indiana bat has thepotential to be found in the area. Due to the urban and agricultural development throughout the ROI, theIndiana bat is anticipated to be limited to the protected areas in oak woodlands and forests.19-142 M:.:E,,D:ICALlI ISIJIAPES ChapterI NWM,-2013-021, Rev. 0A..f.:............. Ihptr 9.0- Environmental ReviewHuman disturbance during hibernation adversely affects this species. When hibernating bats aredisturbed, their metabolism increases and they use valuable fat reserves that must last them through theentire winter. This often causes disturbed bats to leave hibernation sites too soon, which can result in thedeath of the bat. Interaction with humans can make the bats susceptible to white nose syndrome, adisease that can cause mortality among bat species. Another limiting factor is the decline of habitat dueto deforestation and channelization within the bats' range. Forested riparian areas are foraging areas forthis species and may also be roost areas in the summer (MDC, 2000d).19.3 .5.9.5 Gray BatGray bats are cave-dependent species that use caves for roosting throughout the year (MDC, 2000e).Gray bat colonies migrate between winter caves and summer caves. Winter caves tend to be deep cavesthat are almost vertical and trap cold air. These caves provide very low and stable temperatures in whichthe cold helps to conserve body fat, and the bats are able to hibernate. Summer caves typically havedomed ceilings or restricted rooms so that the combined body heat of the colony is trapped in the cave.Summer caves are typically used as roosting sites for maternity colonies. Summer caves are generallylocated near riparian areas with aquatic insects (MDC, 2000e). Potential summer caves exist within theROI, but gray bats are anticipated to be limited to the protected areas with riparian areas.Human disturbance, disturbance to cave habitat, deforestation between caves and rivers, and pesticidesare factors limiting this species. Human disturbance during hibernation adversely affects this species.When hibernating bats are disturbed, their metabolism increases and they use valuable fat reserves thatmust last them through the entire winter. This often causes disturbed bats to leave hibernation sites toosoon, which can result in the death of the bat. Interaction with humans can also make these batssusceptible to white nose syndrome. The use of pesticides and insecticides reduces the food supply andhas the potential to poison the food chain (MDC, 2000e).19.3 .5.9.6 Northern Long-Eared BatNorthern long-eared bats are similar to the Indiana bat except that they typically roost in smaller numbers,prefer a cooler microclimate, and are more flexible for ideal roost tree features. The Northern long-earedbat uses underground caves and cave-like structures for winter habitat, while during the summer thesebats roost in cavities, crevices, underneath bark, or hollows of both live and dead trees and/or snags. Thisspecies of bat appears to be opportunistic in selecting roosting sites; however, the bats prefer coolerplaces with high humidity. Potential summer roost sites and winter hibernation exist within the analysisarea, but these bats are anticipated to be limited to areas with ideal habitat conditions, namely cave-likestructures or suitable sized trees.The only immediate threat to the northern long-eared bat is white-nose syndrome (USFWS, 2014). Sincethe first symptoms of the disease were observed in 2006, the overall population of this bat has declined(USFWS, 2014). Other threats to this bat include disturbance of the species while in hibernaculum,which can cause the bats to leave hibernation too soon, which usually results in the death of the bat, andremoving suitable forest summer habitat.19.3.5.9.7 Black-Tailed JackrabbitThe black-tailed jackrabbit is a State-listed endangered species that resides in open plains, pastures, hayfields, and cultivated areas (MDC, 2000f). Jackrabbits are dependent on vegetation and eat herbaceousplants and grasses, twigs, roots, and bark. Potential jackrabbit habitat is found throughout the ROI.Human disturbance and habitat loss are factors limiting this species. The loss of native tall grass prairiesand agricultural development has caused a decrease in jackrabbit populations. Furthermore, humans havehistorically eliminated jackrabbits when they occur near cropland.19-143 ChaperI1NWM,-2013-021, Rev. 0AlviChptr 9.0 -Environmental Review* "NORTHWEST MEDICAL ISOTOPES19.3 .5.9.8 Plains Spotted SkunkThe plains spotted skunk is a State-listed endangered species found in open grasslands, shrublands, andcultivated areas (MDC, 2000g). These skunks are omnivorous and eat insects, mice, rats, birds, andvegetation. They create dens belowground in grassy banks, rocky crevices, or aboveground in hay stacks,woodpiles, or hollow trees. This potential habitat is found throughout the ROI.Declines to the spotted skunk population can be attributed to agricultural development that removedhabitat and cover. The use of pesticides has also limited the amount of available food resources for theseskunks.1 9.3 .5.9.9 Bald EagleBald eagles are a riparian-dependent species. They are frequently found in or near riparian areas wherethey forage on waterfowl and fish (MDC, 2012). Some eagles will inhabit terrestrial environments andfeed on small game. Nesting bald eagles are predominantly associated with lakes or rivers. Missouri hasestimated winter populations in the state to be approximately 2,660 eagles, with a summer population ofapproximately 600 eagles. Only two eagle nests have been identified within Boone County(MDC, 2012). Bald eagles have the potential to be found within the ROT, but are unlikely to bepermanent residents.The most limiting factor to this species is loss of habitat. Increased development and the modification ofwildland have had a cumulative adverse impact on this species. Human disturbance, in the form of directmortality, application of pesticides, and removal of nesting sites, has also had a limiting factor on thepopulation.19.3.5.9.10 American BitternThe American bittern is a State-listed species primarily found in wetland and riparian areas with tallemergent vegetation from spring to late fall. These birds will nest in thick vegetation several inchesabove water. American bitterns typically prey on large insects, small fish, mammals, amphibians, andcrayfish (MDC, 2000h). The American bittern is likely to occur in wetlands within the ROI, but for onlya short period of time during nesting.The loss of wetland habitat is the main limiting factor on American bittern populations, along withchemical contamination.19.3.5.9.1 1 Northern HarrierThe Northern Harrier is a State-listed species primarily found in undisturbed marshes, prairies, andpastures with low shrubby vegetation, tall weeds, or reeds. These birds prefer to nest on elevated groundin colonies late in the spring. Northern Harrier prey on small mammals, birds, insects, reptiles, andamphibians (MDC, 2000i). The Northern Harrier is likely to occur within the ROT during the spring andfall, in areas that will provide ideal nesting and foraging habitat. Due to the developed nature of the ROT,the northern harrier is anticipated to be found in the less populated undisturbed parts of the area.19.3.6 Historical and Cultural ResourcesThe ROT for historic, archaeological, and cultural resources was established as the spatial area used toassess the potential direct and indirect impacts in which a proposed project could alter characteristics of ahistoric, archaeological, or cultural resource. The ROT for the proposed RPF is defined as portions ofLot 15 identified for ground disturbance activities at Discovery Ridge and areas immediately adjacent tothis area. Various methods were used to assess potential resources within the ROT.19-144 N MISOOE hpe NWI212,Rev. OIUVVChapter19.0 -Environmental ReviewThe cultural resource analysis was performed for the proposed RPF site in compliance withNRC-201 1-0 135 (NRC, 2012a) guidance. Construction and decommissioning activities would largelyoccur within the area of Lot 15.19.3.6.1 Cultural SettingThe proposed RPF site is located in the Central Missouri Drainage Basin. The Environmental ResearchCenter of Missouri conducted cultural research in 2012 for a communications project in this basin(ERC, 2012). Because the proposed site lies within the same drainage basin, the cultural settinginformation for the basin is summarized in this report to describe the historical cultural setting for the site.19.3.6.1.1 Prehistoric PopulationsThe occupation of Missouri by prehistoric populations has been generally established to include ninetraditions (Chapman, 1975 and 1980). These traditions apply in varying degree to the entire state, withsome traditions often not accounted for in specific drainages. These traditions are incorporated in what iscalled the cultural sequence, which is a major factor used in the interpretation of cultural data, particularlyregarding National Register of Historic Places (NRHP) significance. The following traditions aresummarized below in the sequence provided by Chapman (1975, 1980):* Paleo-Indian (.12000-8000 B.C.)* Dalton (8000-7000 B.C.)* Early Archaic (7000-5000 B.C.)* Middle Archaic (5000-3000 B.C.)* Late Archaic (3000-1000 B.C.)* Early Woodland (1000-500 B.C.)* Middle Woodland (500 B.C. to A.D. 400)* Late Woodland (A.D. 400 to 900)* Mississippian (A.D. 900 to 1400)Paleo-lndian -The Paleo-Indian period is generally accepted as marking the earliest known humanoccupation of Missouri. The specialized hunters of this period lived in small nomadic bands or familygroups and left some traces of their transitory settlement pattern in the forms of hunting camps, kill sites,quarry sites, and possibly small base camps. The major diagnostic materials associated with theoccupation include the Clovis and Folsom fluted spear/knife points. Most fluted point finds have beenlocated along major river valleys (e.g., Missouri River), although some have been recovered alongstreams such as the Moreau River. These finds suggest that the nomadic hunters and gatherers followedthese streams in their movement through the Midwest area.Dalton -The Dalton period is characterized as a time of transition from Paleo-Indian big game hunting tothe hunting-foraging subsistence strategy of the following Archaic period. All known Dalton sites inMissouri are small camps, and all apparently represent short-term utilization. The basic Paleo-Indian toolkit was still in use during Dalton times, although tools associated with plant food processing were added.Point types with long flutes were replaced by types with basal thinning and/or short flutes. The majordiagnostic includes the Dalton Serrated and perhaps the Dalton Adze. Population distribution roughlyparallels that of the Paleo-Indian occupation.Early Archaic -The transition to a subsistence pattern of occupation based on foraging was wellunderway by the time of the Early Archaic period. Hunting and gathering continued as the majoreconomic activities, but emphasis was placed on aquatic resources and vegetal foods. Althoughnomadic wandering was being replaced by specific base campsites that were returned to at regularintervals, the typical Early Archaic site continued to be a small hunting and/or collecting camp.19-1 45

..NW M ChpeI NWM,.2013.o21 Rev. 0Alvii. ......... Chpe9.0- Environmental ReviewThese sites are found in a variety of environmental settings throughout Missouri, including upland ridgesnear small ephemeral streams, upland bluff edges, rock shelters, and the margins of high bottomlandterraces. Diagnostics of Early Archaic include Graham Cave Notched points that have been recovered inthe general area. Hardin Barbed points are also generally associated with Early Archaic occupation.Middle Archaic -This period was basically a continuation and expansion of a forager tradition begun inthe Dalton and Early Archaic periods. A drying climate forced greater reliance on collecting vegetalfoods and small animals as opposed to wet environment subsistence. Sites continued to be small,exhibiting semi-nomadic or seasonal occupation. The tool kit continued to expand, depending on theextraction activity in the specific niche. The drying climate was reflected in the marked tendency forMiddle Archaic sites to be located almost exclusively in or very near bottomland settings.Late Archaic -This period is better known than earlier traditions as a result of the greater populationapparently represented, which resulted in more expansive and numerous occupations. This periodgenerally lacks the small dart point of the earlier traditions, which suggests that hunting had become lessimportant for subsistence. Tool kit function also appears to have expanded, suggesting reliance on amuch larger variety of potential foods requiring varied extraction and processing techniques. The LateArchaic period began toward the climax of a warming trend that reached its height around 2000 B.C.,with a resultant diminishing of the faunal and floral forest species. The Late Archaic population had toadapt to new ecological niches with the associated changes in subsistence-related artifacts. Late Archaicoccupations are one of the more commonly identified traditions in the drainage.Early Woodland -This period is identified by the presence of Black Sand Incised pottery and is poorlyrepresented throughout most of Missouri. In spite of intensive surveys in various areas of the state, only afew unquestionable Early Woodland sites have been identified.Middle Woodland -The occupation during this period in northern Missouri is focused on three relatedregional centers: Havana in the Lower Illinois River Valley and adjacent Mississippi River Valley in thenortheast, Kansas City Hopewell on the Missouri River, and Big Bend on the Missouri River. Analysesof pottery from the three centers indicate there was an intrusion of people into the Big Bend and KansasCity Hopewell centers from the Havana center to the east. Although the initial intrusion appears to havebeen related to subsistence and/or political stress in the Havana center, contacts among the three centerswas maintained throughout the Middle Woodland period. Evidence for a Middle Woodland occupation issparse outside of the areas noted. Some rock shelters and open habitation sites in the general area haveproduced Middle Woodland diagnostics and Chapman (1980) identified south Boone County as a majorMiddle Woodland center. However, there has been no corroborating evidence to support thatidentification through field investigations.Late Woodland -This period exhibits the most numerous defined components (elements) withinprehistoric sites in the general basin area. The occupation in this portion of Missouri has sometimes beendefined as a regression from the preceding traditions, in that emphasis on horticulture developed earlier inthe Woodland was supplanted by earlier hunting subsistence reliance. This pattern is seen in the increasein small temporary camps, along with use of a bow and arrow. Diagnostics include grit- and limestone-tempered pottery, arrow points, burial mounds, and shallow side-notched points. Several Late Woodlandsites have been identified in Boone County, including open habitation sites and burial mounds.Mississippian -This period is not well-documented in the general area of the proposed site. Diagnosticsfor this period include small triangular arrow points and shell-tempered ceramics. Early MississippianSteed-Kisker people apparently abandoned the Kansas City area around A.D. 1250, and around A.D. 1350, theOneota cultural tradition appeared suddenly in the Big Bend area near the junction of the Grand, Chariton,and Missouri Rivers. The most prominent Oneota village in the Big Bend area is the Utz site in SalineCounty, and it was there that the Utz phase, which documents the Oneota culture of the area, was defined.19-1 46 Catr1NvvM,-2013-021, Rev. 0AliE Chapter 19.0 -Environmental Review* NORTHWEST MEDICAL ISOTOPESThe Utz phase, and the Oneota occupation, began at about A.D. 1350 and lasted to the end of theMississippian period (A.D. 1700), when Oneota blends into what is recognized as the Historic MissouriIndian tribe.19.3.6.1.2 Historic PeriodDuring the period from 1730 to 1790, the Missouri tribe was being depleted by smallpox and its powerwas continually being tested by its enemies to the north. By the 1780s, the Missouri tribe became heavilydependent on their allies the Osage for protection; however, the Sac and Fox tribes conquered anddispersed the Missouri tribe in the 1790s. Those who were not killed joined the Osage, Kansas, and Ototribes. The great smallpox epidemic of 1823 reduced the Missouri tribe numbers to less than 100, and theMissouri as a distinct cultural entity became extinct. The last full-blood Missouri Indian died on the Otoreservation in 1907.The land in which the proposed RPF site lies was but a tiny portion of North American territory claimedby France until 1762, when the land was transferred to Spain by secret treaty. Spain retroceded the landto France in 1801, and France ended up selling it to the U.S. in 1803 as the Louisiana Purchase. TheU.S. Congress created the Territory of Missouri in 1812, and in 1821, Missouri was recognized as the21 st state.In general, the post-1800 history of central Missouri reflects both the general patterns of agriculturaldevelopments in the Midwest and specific influences that shaped the region. The process of earlysettlement and the struggle to produce beyond a meager subsistence, the expansion of the agricultural andcommercial activities and creation of a stable society, followed by an era in which regional concerns wereshaped by state and national trends, are all recognized as part of the evolution of the Midwest. In the caseof northern Missouri, an understanding of its Euro-American past requires recognition of the influence ofthe settlers themselves and of the land that they occupied. The early settlers came primarily from theupper south, especially Kentucky, Tennessee, and Virginia. Prior to the Civil War, tobacco and cornplayed an important role in the agricultural economy of the region. The first permanent settlers beganentering the area in the early 1 800s, a process that primarily started after the acquisition of the LouisianaTerritory.The rapid development from uncharted wilderness to statehood stemmed directly from the massivewestward movement of population during the early nineteenth century. Most of the settlers who came tomid-Missouri were attracted to the land. A rich, friable loam predominated, with substantial stands oftimber that provided building materials and generally reminded the immigrants of the lands that they hadleft behind. The background of the settlers made them receptive to cultivating a crop that wouldreproduce the agricultural patterns of their native states. Most of the early settlers came from the uppersouth, which included slave-holding states. Major crops included hemp and tobacco; these crops,particularly tobacco, demand intensive labor for productivity. Tobacco was generally favored as a cashcrop in that tobacco produced a greater value in proportion to bulk when compared to grain crops.While not well-documented, agricultural pursuits were almost entirely geared toward corn and wheat bythe time of the Civil War. Slave holding had also begun to drop at a relatively high rate prior to the CivilWar. The land and its location then became major shaping forces of the economic system of the area,altering the previous patterns established in the southeast and brought to the Midwest. The coming of therailroad in the 1 850s through the 1 870s opened the interior to greater trade and agricultural products,which have been the major source of livelihood in the general area since.19-147 MEIA STPSCatr1NWMI-0321Re.OlviChptr 9.0 -Environmental Review19.3.6.1.3 Recent History -ColumbiaFrom its beginnings, the economy of Columbia, Missouri, has rested on education. Columbia alsobenefited from being a stagecoach stop of the Santa Fe and Oregon Trails, and later from the MissouriKansas Texas Railroad. Columbia was incorporated in 1826, five years after Missouri became the24th state. The city's progress can be traced through the development of its institutions. In 1824,Columbia was the site of a new courthouse; in 1830, the first newspaper was published; in 1832, the firstMissouri theater was opened in Columbia; and in 1834, a school system began to serve its 700 citizens.Missouri's first agricultural fair was held in Columbia in 1835. A school for girls was opened in 1833,and an institution called Columbia College (unrelated to the present school) was opened in 1834.One of the finest U.S. portrait artists, George Caleb Bingham, opened a studio in Columbia in 1834. In184 1, MU was built in Columbia after Boone County outdid several competing counties in raising moneyand setting land aside. In 1851, Christian Female College was established. The college became a coedschool in the 1970s and changed its name to Columbia College. In 1855, Baptist Female College, nowknown as Stephens College, was established. By 1839, the population and wealth of Boone County, with13,000 citizens, was exceeded only by that of St. Louis County.Slavery was a largely accepted practice in Columbia in its early days, and the slave population hadreached more than 5,000 by the beginning of the Civil War. Before the Civil War, many Columbianswere very nationalistic and supported the Missouri Compromise. That agreement admitted Missouri intothe Union as a slave state, but placated northerners with the admission of Maine as a free state and theestablishment of the rest of the Louisiana Purchase (north and west of Missouri's southern border) as freeterritory. Early in the Civil War, Union forces secured the area and enforced a mandatory draft into thelocal militia. Although Missouri was officially a Union state, residents were in reality sharply dividedand supported both sides with supplies and men.Since the turmoil of the Civil War and Reconstruction, Columbia's history is marked by steady and quietgrowth and prosperity, based on its roots in education, along with health care and insurance. The healthcare business can be said to have started in 1822, when Dr. William Jewell set up a hospital in his ownhome. Today, Columbia is among the top cities in the nation for medical facilities per capita. Theinsurance industry also has its roots in Columbia's early days, when pragmatic local businessmen starteda fund to aid one another in case of fire.19.3.6.2 Recent History -Discovery RidgeThe Phase I environmental site assessment for Discovery Ridge (Terracon, 201 Ia) included results ofrecord searches and interviews with personnel associated with the site to document its most recent history.Findings resulting from those efforts are summarized in the following sections.Based on review of the historical information, the Discovery Ridge site has predominately been vacantfarmland consisting of both row crop production and livestock pasture from at least 1934 to 2006. Thewestern portion of the site has been used as a developing research park from approximately 2006 topresent. The eastern portion of the site has always been used as farmland and livestock pastureland. Thenorthern portion of the site is currently used as the MU plant genetic research farm. A residentialstructure was located at the genetics farm on the northern portion of the site, from approximately 1945 to2001, at which time the residential structure was demolished. Multiple small, machine-shed structureshave been located at the genetics farm (on the northern portion of the site) from at least 1956 to the mid-2000s, with two small machine-shed structures still present. A large, machine shed structure located atthe genetics farm was added in approximately 2007. A Quonset hut structure used by the USDA has beenin place on the western portion of the site from approximately 1965 to present. A residential structurewas located on the western portion of the site, east of the current Quonset hut, from approximately 1945to the 1980s. A small, log cabin-type structure was located on the central portion of the site fromapproximately 1945 to 1980.19-1 48

"""...,.. NW MI Chpe wM,_2Ol3-O2l, Rev. OA: : Capter19.0 -Environmental Review19.3.6.3 Previous InvestigationsCultural resources are comprised of both historic properties and archaeological artifacts. In accordancewith Section 108 of the National Historic Preservation Act of 1966 (16 U.S.C. § 470 et seq.), a culturalresource assessment (Section 106 review) of the site was conducted by the MDNR State HistoricPreservation Office for 15 lots, including Lot 15 (Terracon, 2011l a). That assessment reported that, "theSection 106 Review form, signed by Mark Miles, Deputy State Historic Preservation Officer, datedMarch 7, 2011, states that 'an adequate cultural resource survey of the project area has been previouslyconducted. It has been determined that for the proposed undertaking there will be no historic propertiesaffected"'" (Terracon, 2011 la).19.3.6.4 Recent Cultural Resources SurveysNWMI conducted an investigation in October 2013 to inventory and evaluate cultural resources withinthe designated project zone through the use of currently accepted Phase I survey techniques and review ofrecords and literature. The study was initiated to carry out Federally mandated Section 106 complianceregulations. The scope of work placed emphasis on identification of cultural resources within the projectarea, along with recovery of sufficient data to allow the Missouri State Historic Preservation Office(SHPO) to make an informed determination of possible significance of those resources. The investigationincluded (1) a pre-field evaluation of pertinent literature and records from which the field surveytechniques and site designation criteria were developed, (2) an intensive pedestrian survey of the projectarea, (3) an attempt to recover sufficient data for site designation and evaluation in terms of NRHPeligibility requirements, (4) notation of locational information regarding site provenience andphysiographic setting, (5) post-field activities involving data analysis, and (6) report preparation.19.3.6.5 Literature ReviewA review of relevant publications and records prior to the field component of the study was important inestablishing an understanding of the sequence and types of cultural resources that might be expected tooccur. The process began with review of cultural resource management reports that have been producedfor the areas near the RPF project zone. These reports are housed in MDNR SHPO, Jefferson City,Missouri, and are catalogued by county and author. The repository also includes historic architecture siteforms for the State, NRHP forms for Missouri, and correspondence regarding the proposed project.Archaeological Survey of Missouri records located at the SHPO were also reviewed.The Archaeological Survey of Missouri files for reported Missouri archaeological sites contain data thathas been gathered for over 70 years. The data is catalogued by county and section, township, and range,and the Universal Transverse Mercator coordinates. The SHPO Geographical Information System (GIS)data includes overlays illustrating recorded archaeology sites and areas that have been the subject ofprevious cultural resource surveys. Other consulted resources with important data include the Statelibrary and State archives in Jefferson City, local historic societies when available, and the Missourihistoric society in Columbia. Other archaeologists and architectural historians, particularly thoseemployed by Missouri who are involved with Section 106 procedures, were consulted regarding theirknowledge of significant cultural resources in the project area.There are no previously recorded prehistoric archaeology sites within the proposed project boundaries(Figure 19-40). [Proprietary Information]. The proposed RPF site contains no recorded historicarchitecture or possibly significant historic events. Review of 19th' and 20th century plat maps and 20thcentury USGS topographic quadrangles found no evidence of structures within the project area. The1967/81 USGS topographic quadrangle does not illustrate any structures on the proposed RPF site.19-149 N IOONWMI-2013-021, Rev. GAChapter 19.0 -Environmental Review[Proprietary Information]Figure 19-40. Archeology and Survey Layers Map in Relationto the Radioisotope Production Facility Site19-150 MEIA STPSCatr1NWMI-0i-21 ev. OI-....V............ Chpe 9.0- Environmental Review19.3.6.6 Pedestrian Survey19.3.6.6.1 MethodologyThe archaeological field component of the investigation involved pedestrian coverage of the defined RPFsite. The transect width used ranged from 5-15 m (16-49 ft), depending on visibility and the potential forthe presence of prehistoric features based on terrain, streams, and other factors that have been shown tocorrelate with site presence or absence (e.g., presettlement prairie or woodland setting). All vegetation-free zones were observed for the presence of prehistoric cultural materials. Throughout most of Missouri,these cultural finds can include lithic debitage (.chert flakes and shatter), fire-cracked rock, pottery shards,occasional bone and shell fragments, and features such as fire hearths and burial mounds.Where vegetation covered the surface for over 10 m (33 ft), shovel tests were conducted. This effortinvolved removal of an area of sod of approximately 50 x 50 cm (20 x 20-in.) and then controlledremoval of the subsurface soil matrix to depths of up to 50 cm (20 in.) below-ground surface. Soils werecarefully observed to determine the presence or absence of cultural evidence. Where soil conditionsallowed, soils were screened through a portable 1/4A-in, screen. Shovel testing that did not includescreening of the soil matrix was conducted where larger numbers of shovel tests were necessary andsurface visibility conditions were poor. In this instance, the soil matrix was removed by shovel andcarefully scraped with a trowel to look for prehistoric and early historic evidence.While subjective, the archeologist has developed a set of criteria for determining the presence of anarchaeological resource, which is currently accepted by the SHPO as appropriate. These criteria are notpresented as appropriate for all situations, but as the general practice followed by the archeologist inmaking decisions regarding the presence or absence of archaeological resources for cultural resourcecompliance purposes. One extreme records a site where any evidence of cultural activity occurs. Theother extreme requires a significant cultural resource to be present to record the site. The presentapproach attempts to find a middle ground, which allows further consideration for both the culturalresource and the proposed project action prior to threat to either.An archaeology site is designated when evidence of prehistoric and/or early historic land use is presentand at least one of the following specific criteria is met:* A prehistoric feature is present* Two or more artifacts are identified within a 10 x 10 m (33 x 33-ft) (or smaller) area* A shovel test recovers two or more artifactsWhere a site is identified and when the landowner grants permission, materials recovered by the fieldinvestigation are placed in collection bags marked with field site numbers. If permission is not attained,materials are observed and potential diagnostics and tools area measured, photographed, and left in placeor given to the landowner (when requested). When a permanent site number is assigned, retainedmaterials are curated with the site designation. Where material density at a site is obviously high, only arepresentative sample is retained. Historic architecture resources include structures and features. Wherethere are structures over 45 years old or that exhibit some form of possible exceptional significance, thestructures are photographed and a description of the architectural features is prepared, with preliminaryevaluation of NRHP eligibility when located within a direct impact project zone.Historic structures are not recorded where obvious that the structures are less than 45 years old and nototherwise significant. Where an "area of potential effect" has been established beyond the physical areaof potential effect, architectural resources obviously 45 years or older are photographed and located onreport maps.19-1 51 ChptrWWII03-2,Rev. O'l..vi...........ihpe 19.0- Environmental ReviewThe significance of cultural resources is interpreted from the following NRHP eligibility criteria:The qu~alitv, of significance in American history, architecture, archaeology, and culture ispresent in districts, sites, buildings, structures, and objects that possess integrit, of location,design, setting, materials, workmanship, feeling and association, and.A. That are associated with events that have made a significanmt contribution to the broadpatterns of our histor3,; orB. That are associated with the lives of persons significant in our past; orC. That embody the distinctive characteristics of t. pe, period, or method of construction, orthat represent the work of a master, or that possess high artistic valu~es, or that represent asignificant distinguishing en tity whose components may lack individual distinction; orD. That have yielded, or may be likely to yield, inforniation important in prehistomy orhistory. (36 CFR 60.6, "Nominations by the State Historic Preservation Officer underApproved State Historic Preservation Programs")Cultural resources that are identified during a Phase I survey are evaluated in terms of meeting one ormore of the 36 CFR 60.6 criteria. In general, archaeological sites most often are evaluated with referenceto Criterion D. A statewide planning document was prepared by the Missouri Department of NaturalResources Historic Preservation Program that allows minimal means for evaluation of potentialsignificance of cultural resources (Weichman and Weston, 1986). The statewide plan includesinformation regarding traditions, types of traditions expected, forms of data that may be important, andresearch questions that can be incorporated in the interpretation of cultural resource significance whereavailable.A cultural resource is generally evaluated on the (1) basis of types of materials recovered (uniqueness,affiliation, type), (2) resource integrity (degree of disturbance), and (3) material/feature density (densityand quantity of artifacts, and the presence and number of potentially extant features such as hearths, housesites, and burial tumuli). If an archaeological site exhibits sub-plow zone integrity and producesdiagnostic artifacts or features, the site is usually interpreted as significant if considered likely to containsufficient data to contribute to the understanding of the cultural history of the area and meet NRHPeligibility Criterion D. The consultant makes recommendations regarding NRHP eligibility. Thedetermination of eligibility process requires consultation with the SHPO and the Federal agency involvedin the project.19.3.6.6.2 FindingsThe Phase I field investigation was carried out under generally mixed to poor surface visibility conditions,averaging less than 20 percent in a grass/hay setting. Shovel tests were used to interpret the presence orabsence of cultural resources, as described in Section 19.3.6.6.1. The presence of erosion cuts and paths,along with shovel tests, allowed for a sample of the subsurface soil matrix for interpretation of thepotential for the presence or absence of buried cultural resources.No evidence of prehistoric occupation of the area was found. Such evidence typically includes thepresence of chert debitage, fire-cracked rock, lithic artifacts, and occasionally ceramics. No prehistoricsites were recorded.Historic resources include recently constructed roads that do not meet the investigators' historic sitedesignation criteria. No historic sites were recorded. The survey concluded that Lot 15 in the DiscoveryRidge development contains no possibly significant cultural resources.19-1 52 NW MIiCatr1NM-132,Re.A.* .Chpe9.0 -Environmental Review19.3.6.7 Previously Recorded Historic Structures and DistrictsHistoric and archaeological resources that are listed, or eligible for listing, in the NRHP are protected byFederal law, primarily the National Historic Preservation Act and its implementing regulations,specifically 36 CFR 800, "Protection of Historic Properties." Under the authority of Section 106 of theNational Historic Preservation Act, Federal agencies must take into account the potential effects anundertaking may have on properties listed in or eligible for listing in the NRHP.The NRHP was consulted to identify historic and architectural structures. There are 50 NRHP sites inBoone County (Table 19-45), with the vast majority of them located in and around Columbia. There areno historic or architectural resources located within the ROI.The closest site to the ROI is the Maplewood House, which was built in 1877 by Slater Ensor Lenoir andhis wife Margaret Bradford Lenoir. The original farmstead included 173 ha (427 acres) surrounding thehouse to the east and west. A large pond was situated south of the house. In addition to the family home,buildings on the property included the separate summer kitchen (which later served as a cottage for familyserving staff), a four-bay carriage house with storage and living quarters above, a utility house, a haybarn, and a large animal barn. Only four people lived in the home: the Lenoirs, their daughter Lavinia,and later Lavinia' s husband, Dr. Frank G. Nifong. In 1970, the City of Columbia bought 24 ha (60 acres)of the original farm with the house, the remaining furnishings, and the adjacent farm buildings. Theanimal barn was converted to a summer theater playhouse after the property was purchased by the city ofColumbia. The building was lost to fire in 2011 and rebuilt and dedicated in 2012. The area was namedthe Frank G. Nifong Memorial Park and today is called Historic Nifong Park in recognition of the work ofhistoric preservation undertaken by the Columbia Parks and Recreation Department and the BooneCounty Historical Society (Boone County Historical Society, 2013). Table 19-45 lists Boone CountyNRHP listings.Table 19-45. Boone County Listings on the National Register of Historic Places (3 pages)1 Ballenger Building 27-29 S 9th St., Columbia 1/21/043 John W. Boone ("Blind") House 4th St. between E Broadway and Walnut, 9/4/80Columbia4 11 4- 0 Eas .... d Wa, Co .......... Q5 ..5 Albert Bishop Chance House and 319 E Sneed St., Centralia 7/3/79Gardens7 Coca-Cola Bottling Co. Building 10 Hitt St., Columbia 2/14/069 Columbia National Guard Armory 701 E Ash St., Columbia 3/25/9311 Fred Douglass School 310 N Providence Rd., Columbia 9/4/8019-1 53 NWMI~NWMI-2013-021, Rev. 0AChapter 19.0- Environmental ReviewTable 19-45. Boone County Listings on the National Register of Historic Places (3 pages)13 Downtown Columbia Historic 1019, 1020, 1023, and 1025-33 E. Walnut 5/8/08District St., Columbia15 Eighth Broadway Historic District 800-810 E Broadway Blvd., Columbia4/22/0317 First Christian Church 101 N 10th St., Columbia 10/29/9119 Frederick Apartments 1001 University Ave., Columbia 4/16/1321 Gordon Tract Archaeological SiteAddress restricted23 David Guitar House25 Hamilton-Brown Shoe Factory2815 Oakland Gravel Rd., Columbia1123 Wilkes Blvd., Columbia3/16/729/9/9 37/19/0227 Kress Building29 McCain Furniture Store1025 E. Broadway, Columbia3/9/058/17/05916 E. Walnut, Columbia31 Missouri State TeachersAssociation33 Missouri United Methodist Church35 North Ninth Street Historic District407 S 6th St., Columbia 9/4/80204 S 9th St., Columbia5-36 North Ninth St., Columbia9/4/801/21/0419-154

NWMINWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-45. Boone County Listings on the National Register of Historic Places (3 pages)l .--37 Pierce Pennant Motor Hotel(Candlelight Lodge)39 St. Paul's African MethodistEpiscopal Church1406 Old Hwy. 40 W, Columbia501 Park St., Columbia9/2/829/4/8041Second Baptist Church407 E. Broadway41Nb st..Co, mi43 Senior Hall Stephens College Campus, Columbia45 John N. and Elizabeth Taylor House House, 716 West Broadway, Columbia9/4/808/2/775/25/0 13/13/0246~i47Virginia Building23 S 81S.,Quml111 S St., Columbia49 West Broadway Historic District 300-922 W. Broadway (except 800, 808, 4/27/10812), ColumbiaSource

MDNR, 2013i, "~Boone County National Register Listings," www.dnr.mo.gov/shpo/Boone.htm,Missouri Department of Natural Resources, Jefferson City, Missouri, accessed September 2013.19.3.6.8 Native American and State Agency ConsultationNWMI initiated consultation with six tribes that are Federally recognized in Missouri. Copies of theconsultation letters are provided in Appendix A. No responses have been received.NWMI forwarded the cultural resource investigation for Lot 15 of the Discovery Ridge property to theMissouri State Historical Preservation office on October 7, 2013 (ERC, 2013). NWMI receivednotification from the Missouri State Historical Preservation office on October 10, 2013, stating that theoffice concurred that the cultural resources survey was thorough and adequate and that there would be nohistorical properties affected by the proposed RPF project (DNR, 2013).19.3.7 SocioeconomicsThis section describes the social and economic characteristics of the ROI, defined as Boone County forthe socioeconomic resource. Information is provided about population, including minority and low-income areas, economic trends, housing, and community services in the areas of education, health, publicsafety, and transportation. The primary labor market for the proposed project is assumed to come fromBoone County.19-1 55 NWM' ChpeI NWMI-2013-021, Rev. 0AlviChptr 9.0 -Environmental Review* .. NORhW~EST MEOICAL ISOTOPESThe proposed RPF site is located in Boone County, Missouri, as shown on Figure 19-5, which shows the8 km (5-mi) area surrounding the proposed site. The figure also shows the city of Columbia, Missouri.Boone County was selected as the primary ROI, and the locations where impacts could occur wereidentified with the project being located in Boone County. An assumption is also made that the primarylabor market for the project would likely come from this county.19.3.7.1 Boone County19.3.7.1.1 HistoryBoone County was organized in 1820 from a portion of the territorial Howard County and named forDaniel Boone. Boone County was settled primarily from the upper south states of Kentucky, Tennessee,and Virginia. The settlers brought slaves and slaveholding with them, and quickly started cultivatingcrops similar to those in middle Tennessee and Kentucky, namely hemp and tobacco. Boone County wasone of several counties settled by southerners to the north and south of the Missouri River (Moser, 2013).19.3. 7.1.2 Census-Based Population/Demographic InformationBoone County has a total area of 1,790.5 km2 (691 mi2), of which 1,775.3 km2 (685 mi2) is land and15.2 km2 (5.88 mi2) is water. The estimated population density, based on the 2010 Census, is 91 peopleper km2 (237 people per mi2) (USCB, 2010c).In the 2010 Census, there were 162,642 people making up 69,551 households residing in the county.There were 64,077 housing units. The racial makeup of the county includes 82.8 percent White, 9.3 percentBlack or African American, 3 percent Hispanic or Latino, 0.4 percent Native American, 3.8 percentAsian, 0.06 percent Pacific Islander, 0.9 percent from other races, and 2.8 percent from two or more races.The 2010 Census documents 64,077 households, out of which:* 27.0 percent had children under the age of 18* 42.1 percent were married couples living together* 10.7 percent had a female household with no husband present* 3.8 percent had a male household with no wife present* 43.3 percent were nonfamilies.A total of 28.7 percent of all households were made up of individuals, and 6.6 percent had someone livingalone who was 65 years of age or older. The average household size was 2.4 individuals, and the averagefamily size was 2.96.The 2010 Census county population includes 21.1 percent under the age of 18, 26.6 percent from ages18 to 24, 26.6 percent from ages 25 to 44, 22.1 percent from ages 45 to 64, and 9.2 percent age 65 andolder. The median age was 29.6 years.19.3.7.1.3 IncomeThe 2010 Census median income for a household in the county was $47,123, and the median income for afamily was $66,943. The per capita income for the county was $25,970 (USCB, 2010c).19.3.7.1.4 Residents Below the Poverty ThresholdIn the 2010 Census, approximately 9.9 percent of families and 19.2 percent of the population were belowthe poverty line, including 17.8 percent of those under age 18 and 10.3 percent of those ages 65 and over(USCB, 2010c).19-1 56

..NWMICape NWMI-2013-021, Rev. GAlviChater19.0 -Environmental Review19.3.7.1.5 HousingThe 2010 Census reports a total of 69,551 housing units, of which 64,077 are occupied and 5,474 are notoccupied. The homeowner vacancy rate is 2.5 percent, and the rental vacancy is 8.5 percent. The medianhome value is $156,600 (USCB, 2010c).19.3. 7.1.6 Civilian Labor Force/UnemploymentThe civilian non-farm labor force for Boone County is estimated at 93,602, with an unemployment rate of4.9 percent in July 2014 (USDOL, 2014).19.3.7.1.7 Population GrowthTable 19-46 provides the Boone County Table 19-46. Population Growth in Boone Countypopulation over the past 50 years and from 1960 (Estimated) through 2030nrni~nt;nmo fnr th-i navt Ofl projections are based on growth estimated inthe current City of Columbia comprehensiveland use plan (City of Columbia, 2013c) of15ne~rcent annually or 16S1 nterrtnt river*** * .3B -S -S -S -S 0 -.10 years. 1960 55,202 -1970 8,1 6619.3.7.1.8 Transient Population 18 0,7 41A detailed analysis of the transient population 1990 11,39120is provided in Chapter 2.0, Section 2.1.2.2. 20 3,5 0519.3.7.1.9 Water Supply 2010 162,420119.3.7.1.9.1 City of Columbia Water 2020 188,753 16.1%The Columbia Water Treatment Plant is 2030. 219,0... 55 , 16.1%owned by the City of Columbia and operated Source: USCB, 2010c, "U.S. Census 2010."by the Water and Light Department. The factfinder2.census.gov/faces/nav/jsf/pages/community_system supplies water to approximately facts.xhtml#none, U.S. Census Bureau, Reston, Virginia,45,500 customers. The water system has accessed March 12, 2013.approximately 46,250 service connections and the average daily consumption is 47.7 ML/day(12.60 Mgal/day) (CSWP, 2013).The service territory of the Columbia Water Treatment Plant lies in Boone County, including Columbia,where the majority of customers reside. Through cooperative service connections, the city has emergencyties to Public Water Districts No. 1 and No. 9, along with MU.Columbia's water is pumped from 15 shallow wells in the McBaine bottoms that tap into the McBaineaquifer, a water-filled bed of sand and gravel beneath the bottom land bordering the Missouri River justsouthwest of the city (CSWP, 2013). Columbia's water treatment plant and well water source is located16 km (10 mi) south of Columbia on Route K, near the small town of McBaine. The plant isapproximately 2.4 km (1.5 mi) from the Missouri River. The 15 wells are situated on seven sites that areseparated by a minimum of 762 km (2,500 ft) to reduce the possibility of wells competing for the samewater area. These wells average 29 m (95 ft) in depth (20 km [65 ft] of well column and 9.1 m [30 ft] ofstainless steel screen). Each of the wells is capable of pumping approximately 7.6 ML/day (2 Mgal/day)(CSWP, 2013).19-1 57

.NWChapte 19.0 -Environmental ReviewThe water treatment plant is a lime-softening and iron removal plant and includes the addition of chlorineand ammonium sulfate before the water is pumped to three water towers in the city. A series of pumps ineach of these pumping stations then sends the water out into the distribution system (CSWP, 2013).In 1904, a series of 366 m deep (1,200-ft deep) wells were constructed into the Roubidoux formation;however, the formation could not support the continued withdrawals. Seven of the original deep wells arestill listed by MDNR as part of the Columbia water system, although most of the wells have been inactivefor decades. Several of the wells are operational and are identified as emergency backup sources(CSWP, 2013).Deep Wells #8 and #10 have been renovated and brought back into service as aquifer storage andrecovery wells. Well #7 at the West Ash Pumping Station and Well #5 at the northeast booster station arecandidate sites for future aquifer storage wells (CSWP, 2013).The Crump, El Ray, and Prathersville wells were acquired by the Columbia Water and Light Departmentin the 1 990s. Like the majority of the remaining old deep wells, these water district operations are not asource of supply for Columbia. The Crump well is operational (CSWP, 2013).19.3.7.1.9.2 Consolidated Public Water Supply District #1Consolidated Public Water Supply District #1 of Boone County was created in 1975 with theconsolidation of three public water supply districts that originally formed in the 1960s. This marked thefirst consolidation of water districts in Missouri. After subsequent consolidations and the annexation ofthe town of Rocheport, Consolidated Public Water Supply District #1 now encompasses approximately995 km2 (384 mi2) in portions of Boone, Howard, and Callaway Counties. The district provides service tothe rural and suburban areas surrounding the southern and western borders of Columbia.Consolidated Public Water Supply District #1 serves a population of approximately 21,000 through morethan 8,500 service connections, with a total average daily water consumption of 5.49 ML/day(1.45 Mgal/day). The distribution system is comprised of 13 deep wells with a total pumping capacity ofover 41.6 ML/day (11 Mgal/ day), 12 water storage facilities with a total capacity of 212 ML/day(5.6 Mgal/day), and over 966 km (1600 mi) of water mains. Numerous interconnections with the cities ofColumbia and Ashland and with adjoining water districts provide additional water sources in case ofemergencies.19.3. 7.1.9.3 Public Water Supply District #9Public Water Supply District #9 provides service to the northeast portion of the proposed RPF site. Thedistribution system includes approximately 161 km (100 mi) of water line, one elevated 189,270 L(50,000-gal) water tower, five standpipes, and four deep wells with pumps and pump houses. The districtowns the land where the wells, standpipes, and towers are located. The district serves approximately4,000 customers in an area of approximately 272 km2 (105 mi2) (PWSD9, 2013).19.3.7.2 Local SchoolsThe Columbia Public School District services the population within the 8 km (5-mi) radius of theproposed RPF site. Total district enrollment is 17,722, with 6,171 students enrolled in the schools withinthe ROI (CPS, 2012).19-1 58

'*=. NWMI*.f° NOUTNWESTM ISOTDPI$NWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-47 provides additional information oneach district school.19.3.7.3 Population MapTwo Missouri cities, Columbia and Ashland,represent the population centers in the ROI (8 km[5-mi] radius) (see Figure 19-4). As of the 2010Census, Columbia had a population of 108,500,which increased 20.5 percent over the 10 precedingyears, and Ashland had a population of 3,707(USCB, 2010a). While the proposed site is inColumbia, the city population resides primarily tothe north-northwest. Ashland is approximately10 mi south of the site. Figure 19-5 is a map of the8 km (5-mi) radius area surrounding the proposedsite, including the highest population areas.19.3.7.4 Transportation Systems19.3.7.4.1 Local Road NetworksTable 19-47. Public Schools and Enrollmentwithin an 8 km (5-mi) Radius of the ProposedRadioisotope Production Facility SiteBentonGrantNew HavenShepard Blvd.Rock Bridge HgGentry MiddleJefferson Jr.DouglassTotalPK-5PK-5PK-5PK-56-78-122991~i+iii~93ill~l281294!+i ii)287594 ~iiii5978991666.171i~iSource: CPS, 2012, "Columbia Public Schools2012-13 Enrollment (Head Count)." Coluimhia PublicThe proposed RPF site in Discovery Ridge is just Schools, Columbia, Missouri, September 26, 2012.north of Discovery Ridge Drive within Columbiacity limits. Discovery Drive and Discovery Parkway would provide access to the proposed site.Discovery Parkway intersects with U.S. Highway 63 approximately 0.4 km (0.25 mi) to the south.U.S. Highway 63 proceeds north and intersects U.S. Interstate 70 approximately 7.64 km (4.75 mi) to thenorth. U.S. Highway 63 continues to Jefferson City, Missouri, approximately 50 km (31 mi) to the south.U.S. Interstate 70 proceeds approximately 201 km (125 mi) east to St. Louis, Missouri, and 201 km(125 mi) west to Kansas City, Missouri. Figure 19-4 shows the 200 km (124-mi) radius with cities androads. Figure 19-5 shows the road adjacent to the proposed RPF site. Current traffic volume for thenearby road systems is summarized in Table 19-48. Additional information regarding corridordimensions, corridor uses, and traffic patterns and volumes is provided in Section 19.4.10. No currenttraffic data exists for Discovery Drive or Discovery Parkway.Table 19-48. Traffic Volume on Local Road SystemsDiscovery ParkwayDiscovery ParkwayPonderosa StreetU.S. Highway ~63U.S. Highway 63South of Discovery LaneSouth of U.S. 63(traffic heading south)South of Nifong BlvdSouth of Mo 740 (traffic heading sorth)Sotho Mo 740 (traffi~heading north)South of Grindstone Parkway (traffic heading south)6442052 37iiii ii!!ii102522,994:i13,9551~14,243aMoDot, 2009, "Columbia Traffic Count Summary," Missouri Department of Transportation, TransportationPlanning, Jefferson City, Missouri, July 8, 2009.19-159

..NWtM" ChpeI NWMI-2013-021, Rev. 0AlviChptr 9.0 -Environmental Review19.3.7.4.2 RailMissouri is home to the second- and third-largest rail centers in the U.S., in Kansas City and St. Louis,respectively. Union Pacific operates approximately 85 trains each day (UP, 2013). The nearest UnionPacific siding is in Jefferson, approximately 32 km (20 mi) south of the proposed RPF site.COLT Transload operates on the Columbia branch short line and provides rail transportation toColumbia. COLT Transload is owned by the City of Columbia and operated by the Water and LightDepartment. The track is rated Federal Railroad Administration Class II, which allows for a 40 km/hr(25 mi/hr) train speed. The rail line generally parallels State Highway B to Hallsville and StateHighway 124 to Centralia. In Columbia, the rail line is located just west of the Highway B industrialarea, crosses U.S. Highway 63 approximately 4 km (2.5 mi) north of U.S. Interstate 70, and ends south ofRogers Street near the center of town, approximately 7.2 km (4.5 mi) northwest of the proposed RPF site.COLT Transload provides service for industrial land uses along the Route B corridor in northeastColumbia. Other land uses served include the Columbia Municipal Power Plant and a commercial lumberfacility to the north of downtown Columbia. The vast majority (97 percent) of the rail traffic is inbound.Typical usage is approximately 1,500 cars per year. The primary freight includes coal for the City PowerPlant, chemicals, petroleum, steel for several manufacturing facilities, and lumber for several commercialfacilities. COLT Transload, a Class III railroad, moves over 1,500 cars a year with two locomotives(CTR, 2013).The Columbia Star Dining Train provides dining and entertainment on vintage 1930s and 1940s railroadpassenger cars pulled by 1950s streamlined locomotives. The roundtrip route (approximately 3-hr) runsbetween Columbia and Centralia on Friday and Saturday evenings, with a brunch run on Sundays.The nearest station for passenger rail service is Amtrak in Jefferson City (Amtrak-JEF), approximately26 mi (42 kin) to the south (MU, 2006a).19.3.7.4.3 AirThe nearest airport is the Columbia Regional Airport approximately 10.5 km (6.5 mi) south of the RPFsite. The Columbia Regional Airport is used by commercial and privately owned aircraft. The airport issituated on approximately 0.532 ha (1,314 acre) and is owned and operated by the City of Columbia. It isthe sole public use airport located in Boone County for which records are kept. The airport has twoaircraft runways:* A 1,982 x 46 m (6,501 x 150-ft) concrete strip that supports most of the commercial air traffic* A smaller 1,341 x 23 m (4,401 x 75-ft) crosswind runway primarily for private aircraftFor the 12-month period ending October 31, 2013, the airport had 16,610 aircraft operations for anaverage of 46/day that were 80 percent general aviation, 3 percent military, 16 percent air taxi, and1 percent air carrier. At that time, there were 36 aircraft based at the airport that were 47 percent single-engine, 25 percent multi-engine, 22 percent jet, and 6 percent helicopter (AMR, 2014).Two small private airports are located within 16 km (10 mi) of the RPF site. These airports include theCedar Creek Airport, approximately 9.7 km (6 mi) east of the RPF site, and the Sugar Branch Airport,16 km (10 mi) to the west of the RPF site. Operations data for these airports is not available.Three helicopter ports are located with 16 km (10 mi) of the RPF site. These heliports support hospitaloperations and include the University Hospitals and Clinics heliport located 6 km (3.7 mi) northwest, MUheliport located 6 km (3.7 ml) northwest, and Boone Hospital Center heliport located 6.3 km (3.9 mi)northwest. No operations data are available for these heliports.19-1 60 ChptrMWI-0I-21 ev. oAIUVVChapter19.0 -Environmental Review* .,..,NORTWWEST MEOICAL ISOTOPES19.3.7.5 TaxesThe Missouri personal income tax rates range from 1.5 to 6 percent, assessed over 10 income brackets.The rates start at 1.5 percent on the first $1,000 of taxable income. The rate increases 0.5 percent on eachadditional $1,000 up to $9,000. The tax rate for income above $9,000 is 6 percent (MDOR, 2013).Missouri has a State sales tax of 4.225 percent that is levied on the purchase price of tangible personalproperty or taxable services sold at retail. Columbia has an additional sales tax of 3.375 percent(MDOR, 2013) to support capital needs for public safety, parks, transportation, and maintenance (City ofColumbia, 2013e). Boone County collects an additional 1.375 percent sales tax that supportsinfrastructure (MDOR, 2013).Missouri charges what is called a transactional privilege tax, considered a sales tax on all sellers for theprivilege of engaging in business in Missouri. Thus, additional fees on a sale (e.g., administrative fees fora service, such as auction fees) can be considered taxable (MDOR, 2013).The Missouri corporate tax rate is 6.25 percent. Only income earned in Missouri is taxed. Two allocationoptions are offered for calculating this income: (1) the three-factor formula, based on sales, property, andpayroll; or (2) the single-factor formula, based only on sales. Missouri is the only state that permitscompanies to choose the formula that results in the lesser corporate income tax liability. Thus, companiesare not penalized for locating property and jobs in Missouri as they are in the other states (MDOR, 2013).Missouri local governments rely on property taxes levied on real property (real estate) and personalproperty. The Missouri State Tax Commission oversees the property assessment system. The amount ofproperty taxes imposed on any taxpayer is determined by two separate factors (MDOR, 2013):1. The assessed value of their taxable property, as established by the local assessor.2. The total of the tax rates that have been set by the governing bodies of local governments wherethe property is located, plus the $0.03 State tax rate. In 2013, Boone County levied a property taxof $0.2846. Columbia assessed a tax of $0.4 100. In addition, Columbia Public Schools collect$5.40 19. The valuation for determining the taxes mentioned above is determined by dividing theassessed value by $100 (BCC, 2013).Real property is assessed based on its use. Residential property is assessed at 19 percent of value,agricultural is 12 percent of value, and commercial is 32 percent of value (MDOR, 2013).Some personal property is exempt, including household goods, inventories, apparel, and items of personaluse and adornment. Exempt real estate includes property owned by governments and property used asnonprofit cemeteries, exclusively for religious worship, for schools and colleges, and for purely charitablepurposes (MDOR, 2013).19.3.7.6 Public Recreation FacilitiesThe parks and open spaces within the ROI (i.e., Boone County) are listed in Table 19-49, along with theirapproximate distance from the proposed RPF site.19-161 NW MINWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-49. Parks within an 8 km (5-mi) Radiusof the Radioisotope Production Facility SiteA. Perry Philips Park 1.1l 0.7 West ~Rock Bridge Park 5.9 3.7 Northwest1.8 1l Northwest Shepard ParkNifong Park4.5 2.8 NorthRock Quarry ParkWaters-Moss MemorialWildlife AreaCapen Park3.23.52.0 Northwest2.2 NorthwestOakwood Hills ParkGrasslands ParkWillis Quad7.2 4.5 Northwest7.2 4.5 Northwest6.8 4.2 Northwest4.9 3.1 NorthwestHighpointe ParkStephens Lake ParkEastport Park5.15.83.23.6NorthwestNor~~thNorthtForum Nature AreaFlat Branch ParkMcKee Street Park8.07.45.04.6NorthwestNorthwest5.8 3.6 Northeast7.7 4.8 North19-162 NorW.STMEIA ISOOE Catr1 WM-032,Rev. QlviChptr 9.0 -Environmental ReviewIn addition to the parks, several other public facilities, summarized below, are located within the ROT.Aquatic centers -The Columbia Parks and Recreation Department manages four outdoor and two indoorpools. Only two of these facilities, Douglass Family Aquatic Center and Stephens Lake SwimmingBeach and Spraygrounds, are located within the ROI.The Douglass Family Aquatic Center is an outdoor facility that consists of an 18 m (20-yd) recreationalpool, a double-loop slide, and a spray park. The Stephens Lake Swimming Beach and Spraygroundsconsists of a 4.5 ha (1 l-acre) lake with unguarded swimming only allowed in designated areas. The parkalso includes a spraygrounds.Columbia Area Seniors Center -The Columbia Area Seniors Center offers services and activities forseniors, including meals, computers, and meeting places for activities.Armory Sports & Recreation Center -This indoor facility is used for basketball, volleyball, meetings,aerobics, and other programs. The facility includes a gymnasium, classroom, meeting room, aerobicsroom, a cardio/strength training area, computer room, general recreation room, and locker rooms.19.3.8 Human HealthThis section describes the current environment associated with human health for the proposed RPF site.The ROT is defined as the 8 km (5-mi) radius surrounding the RPF site.19.3.8.1 Sensitive Receptor LocationsIn accordance with the requirements of Section 19.3.8 of NRC-201 1-0135 (NRC, 2012a), Figure 19-41shows the location of the proposed RPF and distances to the following locations:* Nearest site boundary (fence and lot boundaries) from the centerpoint of the facility (Figure 2-4)* Nearest full-time residence* Nearest drinking water intake* Nearby sensitive receptors (schools, hospitals, public parks, and recreational areas)19-163

++"NWMI~NWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewLocation Map.Jefferson City SScnsiv cRcccptorsA RPF Site Sensitive ReceptorsC )8 km (5 mile) Radius from RPF Site Type Drinking Wells Educational[0] MedicalN [] ParksRecreationalIReligious Institutions0 0.5 0. 1.8 2.7 6

• Residential0 0,5 0 1,8 2.7 3.6Miles

• Retirement CommunitiesFigure 19-41.Sensitive Receptors19-164 NRTWSIMEIA ISOOE hpe NWMI-2013-021, Rev. 0AIIVVChapter 9.0 -Environmental Review19.3.8.2 Major Sources and Levels of Background RadiationExisting sources of background radiation near the proposed site are associated with both natural andhuman-made sources. These sources include naturally occurring, medical, nuclear reactors, and industrialand commercial sources.Environmental data and historical doses for these sources are described in the following sections. Basedon this information, there are no significant abnormal radiation hazards in the vicinity of the proposedRPF. The background radiation exposure is equivalent to the average radiation dose in the U.S. ofapproximately 6.2 mSv/yr (620 mrem/yr) (NRC, 2013a).19.3.8.2.1 Naturally Occurring Background SourcesThere are three sources of naturally occurring radiation: cosmic, terrestrial, and internal. Cosmicradiation comes from the sun and stars, and the dose received differs with weather and elevation. Theelevation of Columbia is approximately 238 m (780 ft) above mean sea level, so the average annual dosefrom cosmic radiation is 0.28 mSv (28 mrem) (NRC, 2013b).Terrestrial radiation comes from naturally occurring radionuclides in soil, water, and air. Exposure toairborne radon accounts for the majority of natural radiation sources in the U.S., accounting for 2.0 mSv(200 mrem) of the 3.2 mSv (320 mrem) annual dose from naturally occurring sources. Higher doses ofradiation are usually observed in areas with higher soil concentrations of uranium and thorium (NRC, 2013c).Missouri has average background concentrations of uranium and thorium (ORNL, 1981), so the averagedose resulting from terrestrial radiation at the proposed site is 2.28 mSv/yr (228 mrem/yr) (EPA, 2013b).Internal radiation comes from the radionuclides potassium-40 (4°K) and carbon-14 ('4C), which arenaturally occurring inside the human body (NRC, 2013c). This source accounts for an average dose of0.4 mSv/yr (40 mrem/yr) (EPA, 2013b).19.3.8.2.2 Human-Made SourcesHuman-made sources of radiation are discussed in the following subsections. These radiation sourcesinclude medical, nuclear power, industrial and commercial, and radioactive waste. Nearly all the annualradiation dose from human-made sources comes from medical procedures. The remaining sourcesaccount for less than 5 percent of the annual dose (NRC, 2013d). As discussed in the following sections.there are no significant sources of radiation in the vicinity of the proposed RPF site; the average dosefrom human-made sources is 3.1 mSv/yr (310 mrem/yr) (NRC, 2013d).19.3 .8.2 .2.1 Medical SourcesThere are numerous medical facilities in the ROI that use ionizing radiation for imaging and treatmentservices. These facilities are listed in Table 19-9. Patients receiving imaging or treatment servicesinvolving ionizing radiation receive an average dose of 2.98 mSv/yr (298 mrem/yr), which accounts for96 percent of the annual dose from human-made sources (NRC, 2013d).Employees of these medical facilities may be exposed to higher levels of radioactivity than members ofthe public employed at locations where radiation is not used. 19 CSR 20-10 outlines maximumpermissible exposure limits and dosimetry requirements for occupational exposure to ionizing radiationand lists a maximum limit of 50 mSv/yr (5,000 mrem/yr) (whole body dose). Medical facility employeesin Columbia do not receive doses in excess of these limits.19.3.8.2.2.2 Nuclear Reactors10 CER 50.47, "Emergency Plans," requires that the emergency planning zone surrounding nuclear powerreactors includes the area within an 80 km (50-mi) radius of the reactor. There are two nuclear reactorswithin 80 km (50 mi) of the proposed RPF site: the MURR and the Callaway Energy Center.19-1 65 ChapterI1NWM,-2013-021, Rev. OAlviChptr 9.0 -Environmental Review* =.,,;"NORTHWEST MEDICAL ISOTOPESBoth reactor facilities maintain a radiological environmental monitoring program and report annualradioactive effluent releases to monitor for any increases in radioactivity resulting from reactor activities.As discussed in the following paragraphs, there were no abnormal radiological releases from eithernuclear reactor in 2012, and the average annual dose from living near a nuclear reactor of less than0.01 mSv (1 mrem) is applicable to the proposed RPF site (EPA, 2013b).MURR -MURR is located on the MU campus in Columbia. According to the MURR 2012 AnnualReport (MURR, 2013), the radiological environmental monitoring program at MURR entails semi-annualcollection of soil, water, vegetation, and air samples. During each sampling event, soil and vegetationsamples are collected at eight locations, and water samples are collected at three of those locations. Airsamples are collected from environmental monitors placed within 0.8 km (0.5 mi) of MURR, and fromtwo control monitors placed 16 km (10 mi) from MURR.Air monitoring results showed doses of approximately 0.14 mS v/year (14 moremo/year), or less, at allexcept two monitor locations. Both of those monitors are located near loading docks where radioactivematerials are loaded for transport, and elevated doses recorded at these locations are likely the result ofpackaged material and not related to MURR operation. The facility also reported sanitary sewer andstack effluent monitoring results for calendar year 2012 (MURR, 2013). For the sewer effluent, a totalactivity of 0.18 curies (Ci) was released to the sanitary sewer, with tritium accounting for 0.16 Ci of theactivity. All sewer effluents were in compliance with the limits outlined in 10 CFR 20. A total activity of1,220 Ci was released via stack effluent, with the majority of the activity coming from argon-41 (41Ar)releases. All stack effluent releases were compliant with the MURR license technical specifications(MURR, 2013). Results from environmental monitoring during calendar year 2012 demonstrated therewere no environmental impacts from MURR operations (MURR, 2013).Callaway Energy Center -Callaway Energy Center is located 65 km (40 mi) southeast of Columbianear the town of Fulton. The center is operated by Ameren Missouri and provides power for780,000 households annually (Ameren, 2013a). The Callaway Energy Center 2012 Annual Report(EIiML, 2013) outlines the Radiological Environmental Monitoring Program. The monitoring programincludes collection of water, terrestrial, air, and biological samples.Surface water, groundwater, drinking water, and sediment samples are collected and analyzed for gammaisotopes, and water samples are also analyzed for tritium. These samples are collected on either amonthly, quarterly, or semi-annual basis. Low-level tritium activity was detected at two surface waterlocations and in several groundwater monitoring wells; the remaining isotopes were not detected. Low-level cesium-137 (137Cs) activity was noted in both control sediment samples and one indicator sedimentsample, and 4°K activity was noted in all sediment samples. No radionuclide activity was detected in anydrinking water samples.Soil samples are collected annually from two control locations and seven indicator locations andsubsequently analyzed for gamma isotopes (EIML, 2013). Soil samples for 2012 exhibited positive 13Cand 4°K activity (EIML, 2013).Continuous air monitoring is performed at five locations and analyzed for iodone-131 and othergamma isotopes on a weekly basis. Air monitoring results for 2012 demonstrated average activities of0.23 picocurie/cubic meter (pCi/m3) for beryllium-7 (TBe). There were no positive detections ofradionuclides from facility operations (EIM4L, 2013).Direct ambient gamma radiation is monitored at three control locations and 40 indicator locations usingthermoluminescent dosimeters (TLD). The TLDs are analyzed on a quarterly basis. For the reportingperiod (2012), the average dose for the indicator locations was 16.0 mrem/quarter (64 mrem/yr), and was15.3 mrem/quarter (61.2 mrem/yr) for the control locations. These dose levels were similar to historicalTLD results (EIML, 2013).19-1 66 NWMI~VVV I Catr1 WM-032,Rev. OME: ACISpter S9.0 -Environmental ReviewBiological sampling includes collection of milk, fish, and vegetation tissue. Milk samples are collected atleast once per month and also analyzed for 131I and other gamma isotopes. Fish samples are collected ona semi-annual basis and analyzed for gamma isotopes. Edible vegetation is collected monthly during thesummer months and analyzed for 131I and other gamma isotopes. Soybeans are also collected from fourlocations (one control location, and three locations on Ameren property) and analyzed for tritium andgamma isotopes (EIML, 2013). Positive detections of 4°K, which is a naturally occurring isotope, werenoted in all 2012 biological samples. There were no other positive radioisotope detections.The results reported for all environmental samples are consistent with historical data at the site. Theresults for the reactor facility reported no samples above background radiation levels outside of thefacility boundary in 2012; therefore, there are no environmental impacts resulting from facility operationsduring 2012 (EIML, 2013).Doses to members of the public from gaseous plant effluent, facility activities, and inhalation of '4C areoutlined in Table A-5 of the Callaway Energy Center 2012 Annual Radioactive Effluent Release Report(Ameren, 2013b). The whole body dose (0.0000771 mSv/yr [0.00771 mrem/yr]), thyroid dose(0.000077 mSv/yr [0.0077 mrem/yr]), and maximum other organ dose (0.000 161 mSv/yr[0.0161 mrem/lyr]) were well below the allowable doses outlined in 10 CFR 20.1301(e), "Dose Limits forIndividual Members of the Public," and 40 CFR 190, "Environmental Radiation Protection Standards forNuclear Power Operations."19.3.8.2.2.3 Industrial and Commercial Use of RadiationABC Laboratories -ABC Laboratories operates at two locations near the proposed RPF site. Thenearest location is on Lot 1 of the Discovery Ridge development, approximately 152 m (500 ft) from theproposed site, and the second location is approximately 8 km (5 mi) northwest of the site. ABCLaboratories has a radiological material license with the NRC (No. 24-13365-01). Radiological materials atABC Laboratories are used for animal studies, sample analysis and cleaning in gas chromatographs(nickel-63 [63Ni]), calibration of liquid scintillation counters ('37Cs), and research and developmentpurposes. Occupational doses at ABC Laboratories are monitored using dosimetry. Biologicalmonitoring is also conducted for personnel performing duties for field studies or for animal studiesinvolving more than 10 millicurie (mCi). Doses to personnel are managed in accordance with 10 CFR20.1203, "Determination of External Dose from Airborne Radioactive Material" (ABC Laboratories, 2007).MU Pickard Hall -Pickard Hall is on Francis Quadrangle at MU and currently houses the Museum ofArt and Archaeology. The building was formerly used as the university chemistry laboratory building,where radioactive material separation activities were conducted from the early 1900s through the 1930s(MU EH&S, 2013). These activities resulted in legacy radium contamination of subsurface soil in theimmediate vicinity of Pickard Hall, original flooring and ceiling material in several rooms within thebuilding, original ventilation system components, steam tunnel, and sanitary sewer lines associated with thebuilding. The MU Radiation Safety Program has implemented an internal standard operating procedureto limit land and building use at Pickard Hall to reduce public exposure to and environmental releases ofradiological contamination (MU EH&S, 2013). The operating procedure includes exposure monitoringfor selected Pickard Hall faculty and staff, and periodic radiation surveys and monitoring of the building.Areas of the building with residual contamination have controlled access, so members of the public maynot enter these areas without an escort. Faculty and staff working in controlled areas of Pickard Hall mayhave higher radiation doses than the general public, but these doses are not higher than the ALARA levelfor dosimetry monitoring of 0.25 mSv (25 mrem) per quarter (1.0 moSv [100 mrem/yr]) as outlined in thestandard operating procedure (MU EH&S 2013).19-1 67 ME-.D!ICAISOTOPES Chapter NWM,-2013-021, Rev. 0A'l..vi........... Chpe9.0- Environmental Review19.3.8.3 Major Sources and Levels of Chemical ExposureThe areas bounding the proposed RPF site have roadways, buildings, and open agricultural fields. Theseareas are maintained in accordance with MU policies and procedures. The site has not been used forstorage of chemicals; however, the use of chemicals for maintenance is expected. Weed killer andfertilizer are expected to be used on or near the site. No other commercial chemicals are expected to beon the site. The only source for chemical exposure appears to be topical applications of commerciallyavailable pesticides.Nonradioactive liquid, gaseous, and solid waste effluents from facilities within the Discovery Ridgedevelopment are required to report hazardous effluents to the MDNR and the EPA.19.3.8.3.1 Hazardous Waste Management and Effluent Control SystemsMU does not operate any hazardous or radioactive waste disposal sites. Nearby sources that managehazardous waste include ABC Laboratories, RADIL, and the MU School of Agriculture, all located in theDiscovery Ridge development near MU. The following subsections provide further detail on thesesources.19.3.8.3.1.1 Discovery Ridge DevelopmentAccording to the 2011 Phase I environmental site assessment conducted at Discovery Ridge:[There is] no knowledge of any aboveground or underground storage tanks for chemicals orpetroleum, past use, treatment, disposal or generation of hazardous materials or petroleumproducts. polychlorinated biphenyl (PCB) equ~ipmnent, solid waste disposal, or any~ pending,threatened, or past litigation. admninistrative proceedings, violations of environmental laws,or possible litigation relating to hazardous substances or petroleum products associated withthe su~bject site. (Terrac on, 2011 a)The MU School of Agriculture, ABC Laboratories, and RADIL have existing facilities in the DiscoveryRidge development and use/dispose of radioactive and/or hazardous wastes. Waste handling, transport,and disposal activities are performed in accordance with 10 CFR 71; Appendix T of NUREG- 1556,Volume 11, Conzsolidated Gumidance abou~it Materials Licenses, Program-Specific Guidance aboutLicenses of Broad Scope (specific to ABC Laboratories, 2007); MDNR regulations; and DOT regulations.19.3.8.3.2 University of Missouri Research ReactorThe MURR Health Physics Branch has a Radioactive Waste Management Program that managesairborne, liquid, and solid radioactive waste materials. Management and disposal activities for each typeof waste are discussed in the following subsections. MU also has a separate hazardous wastemanagement facility, the Resource Recovery Complex. The complex is located approximately 0.48 km(0.3 mi) northeast of MURR on the MU campus and handles all non-MURR-related waste generated byMU operations.19.3.8.3.2.1 Solid WasteSolid low-level radioactive waste is temporarily stored on the belowgrade level of the MURR laboratoryprior to shipment. No solid waste is permanently stored onsite. Waste is monitored prior to shipment toidentify radioactive and nonradioactive waste to ensure proper disposal of waste and to help reduce thevolume of waste by identifying items that may be reused. Radioactive waste is typically packaged insealed metal drums and processed for shipping by the MURR Health Physics Branch in accordance withDOT requirements. Waste containers are either shipped directly to a waste disposal site or transferred toan authorized radioactive waste vendor. High-level radioactive waste shipments are planned and handledin accordance with NRC and DOT regulations (MU, 2006a).19-1 68 NWMAI~f IflIVChapter 9.0 -Environmental ReviewDuring 2012, MURR shipped 19.9 m3 (703 cubic feet [ift3]) of low-level radioactive waste that contained3,097 mCi of activity (MURR, 2013).19.3.8.3.2.2 Liquid WasteRadioactive liquid waste is sent to a liquid waste retention and disposal system that is also located on thebelowgrade level of the MURR laboratory building. The system consists of tanks, pumps, filter banks,and piping/valves, and uses both chemical and filtration treatment methods to reduce radioactivity levels.Assay monitoring is used to record liquid waste activity levels. When activity levels are below thosespecified in 10 CFR 20, liquid waste is discharged into the sanitary sewer (MU, 2006a).19.3.8.3.2.3 Gaseous WasteThe majority of gaseous waste consists of 4"Ar, which is released through the facility ventilation exhauststack. Exhaust air from the reactor is mixed with uncontaminated air to dilute the concentration ofradioactive gases emitted into the atmosphere. The discharge rates do not exceed the limits outlined inthe technical specifications (MU, 2006a).19.3.8.3.3 Historical Releases and ExposureHistorical releases of hazardous materials may have occurred at the ABC Laboratories location, 8 km(5 mi) northeast of the proposed RPF. This site is currently undergoing decommissioning under the NRC(NRC, 2013e), as discussed below.The ABC Laboratories site consists of commercial buildings and three sanitary lagoons. Two historicallagoons were used between 1968 and 1986, after which they were backfilled. The NRC approved theunrestricted release of both lagoons in 2011, along with four buildings onsite (NRC, 2013e).A third sanitary surface lagoon was constructed in 1986 and operated until 2004. The lagoon receivedsewer waste and rinsates from the laboratories that primarily contained '4C. The lagoon effluent wasdischarged to the site under a NPDES permit (MO-0 104591) via pipe and gravel beds. In 2011, thelagoon was drained and then backfilled in February 2012. Soil samples collected from the lagoondischarge areas showed an average activity of 6 pCi/gram (g), which is below the screening value of12 pCi/g required in NUREG-1757, Volume 2, Consolidated Decomm~issionin~g Guidance:Characterization, Surveey, and Determination of Radiological Criteria. Detectable radiological activitywas not noted in subsurface soils below the clay liner of the lagoon. Modeled doses resulting fromresidual radioactive contamination in the lagoon were calculated to be 0.002 mSv/yr (0.2 mrem/yr). Theaverage concentration in groundwater from the site was 126 pCi/L, with the highest concentrations notedin the shallow water table, which is not available for drinking water according to 10 CSR 23-3.090,"Regionalization." Based on this data, the NRC issued a Finding of No Significant Impact with regard tothe former sanitary lagoon at ABC Laboratories (NRC, 20130).Positive detections of methylene chloride and 2-methyl chlorophenoxyaceticacid were noted in thesediment and clay layer of the lagoon. A minimum of 0.9 m (3 ft) of cover soil was placed in these areasto effectively eliminate potential human contact. Based on this data, the NRC issued a Finding ofNo Significant Impact with regard to the former sanitary lagoon at ABC Laboratories (NRC, 2013f).To-date, there are no additional records of any historic recordable incidences of releases to the generalpublic in the vicinity of the proposed RPF site. Radiological exposure of MURR staff as a result ofroutine tasks is discussed in Section 19.3.8.4.19-1 69 lviiChaper 1NWMI-2013-021, Rev. 0A, ;:.. W MI haper 9.0 -Environmental Review19.3.8.4 Occupational Injury RatesThe occupational injury rate of workers associated with the proposed RPF is expected to be similar to theMURR facility or other MU research facilities currently operating in the vicinity of the proposed RPFsite. While the isotope extraction process may be continuous, the preliminary design of the systems andcomponents of the facility call for many tasks to be automated. The goal is to reduce human error, whilealso reducing occupational risk from many process activities. In addition, occupational dose received byRPF workers will be maintained ALARA, in accordance with an approved ALARA/Radiation ProtectionProgram, similar to the ALARA Program for MURR (MU, 2006a).Occupational dose received by students and faculty while performing activities associated with theMURR are maintained ALARA. The MURR ALARA Program has been established in accordance with10 CFR 20.1101, "Radiation Protection Programs" (MU, 2006b) to ensure that doses from radiation andgaseous effluents are maintained ALARA. Occupational doses at MURR for calendar year 2012 areshown in Table 19-50.Table 19-50. Total Personnel Dose to University of MissouriResearch Reactor Facility EmployeesAnalytical Chemistry 0.27 27 3.43 343Bu &et~ evcs0.86 86 3A3 :343Director' s Office 0.06 6 NR NR0.72 72 1 1100Hot Cell/Shipping 9.81 981 25.25 2,525He1! 4.68 468 8.3 834Irradiations 0.58 58 NR NR1.18 118 34~6 ,6Neutron Scattering 2.16 216 5.09 509Operaions 12.75! 1,275 31.22 3,122Isotope Processing 5.16 516 53.61 5,361~1.09'

• 9 6,29 629Research 1.12 112 13.85 1,385~~0.87' 87 19.95 i: 1,995Silicon 8.42 842 13.33 1,333Epeuogy0.17 17 1.82 182Work Control 2.92 292 52.72 5,272Source: Section IX of MURR, 2013, University of Missouri Research Reactor, Reactor Operations Annual Report,January 1, 2012 -December 31, 2012, MURR Research Reactor Staff, Columbia, Missouri, February 26, 2013.The highest occupational whole body radiation doses at MURR were noted for those employees workingin operations (12.75 mSv [1,275 mrem/yr]) and hot cell/shipping (9.81 mSv [981 mrem/yr]). Radiationdoses for body extremities were highest for isotope processing (53.61 mSv [5,361 mrem/yr]) and workcontrol employees (52.72 mSv [5,272 mrem/yr]). These exposures were less than the occupationalexposure limits outlined in 10 CFR 20.1201, "Occupational Dose Limits for Adults" (MURR, 2013).19-170 NW ISOOE hpe NWM,-2013-021, Rev. QA: IVChapter 9.0 -Environmental Review19.3.9 Connected Action -University Reactor NetworkIrradiation of LEU targets at the university research reactors is key Component of the NWMI process. Fora specific university reactor to irradiate LEU targets for NWMI, an amendment to the university's10 CFR 50 NRC license and an analysis of site-specific environmental impacts related to such anamendment would be required. For the purposes of complying with NEPA's requirements to analyzeconnected actions, the following sections describe the affected environment at each of the proposeduniversity reactors.19.3.9.1 University of Missouri Research ReactorThe University of Missouri Research Reactor (MURR) is a pressurized, reflected, light-water moderated,open pool-type research reactor. The reactor is used to conduct experiments, irradiate materials, andproduce isotopes for use in various fields of medicine. In addition, the reactor is used for training,research, and demonstration purposes associated with undergraduate and graduate-level degree programs.MURR is located in University Research Park, an extension of the Missouri University-Columbia,Missouri and is licensed to the Board of Curators of the Missouri University. A detailed description of thefacilities can be found in the Facility Operating License No. R-103 (NRC Docket 50-186), which willexpire on October 2026 (MU, 2006b).MURR is located in Columbia, Missouri, approximately 201 km (125 mi) east of Kansas City and 201 km(125 mi) west of St Louis. The site is 2.4 km (1.5 mi) south of U.S. Interstate 70, just west of ResearchPark Drive. The Missouri River lies 13.6 km (8.5 mi) west of the site. The site is located 6.4 km (4 mi)northwest of the Discovery Ridge site. Specifically, MURR is located is 1.6 km (1 mi) southwest of themain MU campus. The site's latitude and longitude is 380 55' 53" north and 920 20' 31" west. MURR issituated on a 3.0 ha (7.4-acre) lot in the central portion of the University Research Park, a 34.0 ha(84-acre) tract of land approximately 1.6 km (1 mi) southwest of the MU main campus. The campus issituated in the southern portion of Columbia. The University Research Park consists of low-occupancyresearch buildings. Personnel are currently working in facilities located within 457.2 m ( 1,500 ft) of thealternative site. A detailed MURR site evaluation is provided in Section 19.5.2.3.19.3.9.2 Oregon State University Radiation Center ComplexThe OSU Radiation Center complex is an approximately 47,000 ft2 facility and is comprised of threebuildings including OSTR, Advanced Thermal Hydraulics Research Laboratory (ATHRL), and RadiationCenter Building.* OSTR or Reactor Building is located in a four-story building located on the north side of theRadiation Center. The Reactor Building contains primarily the main Reactor Bay, the ReactorControl Room, space for reactor mechanical equipment, two research laboratories, office spacefor the Reactor Operations Staff, and a small conference room.* ATHRL is a high-bay facility attached to the east side of the Reactor Building and housesexperimental test loops. There is no access between the ATHRL and Radiation Center* Radiation Center Building houses classrooms, offices, a wide variety of radioisotope laboratories,a cobalt-60 irradiation facility, a large inventory of nuclear instrumentation useful for researchapplications as well as for radiation protection, and a number of supporting facilities. Access tothe Reactor Building from the Radiation Center can be made through two secure locations.19-171 N MEICSOPEChpe1 NWMI-2013-021, Rev. OANW. haper 9.0 -Environmental ReviewThe OSTR is a light-water-cooled, graphite-reflected reactor using uranium-zirconium hydride fuelelements. These fuel elements are placed in a circular grid with 16 feet of water over the top of the core.The reactor has an authorized maximum steady-state thermal power of 1.1 MW and may be pulsed to apeak power of over 2,000 MW. A detailed description of the reactor facility can be found in their FacilityOperating License No. R-106 (NRC Docket 50-243), which will expire on August 2028 (NRC, 2008b).The Radiation Center Complex is located on the east side of 35th Street and the north side of SouthJefferson Way both two lane roads. 35th street provides access to the Complex and intersects to the southapproximately 0.75 miles with combined U.S. Highway 20 and Oregon State Highway 34. Highway 20and Highway 34 separate approximately 1.25 miles to the east with Highway 20 continuingapproximately 11 miles where proceed to Albany Oregon and intersects with U.S. Interstate 5. Highway34 intersects U. S. Interstate 5 approximately 8.25 miles to the east. To the west Highway 20 andHighway 34 separate approximately 5 miles with Highway 20 continuing approximately 46 miles to thecoast were it terminates at Newport, Oregon. Highway 34 continues approximates 57 miles to thesouthwest where it terminates in Waldport, Oregon.19.3.9.3 Third ReactorThe third reactor will be similar to the OSTR and will located on a University campus.19-172 I.:T.PESChapter NWMI-2013-021, Rev. OA: I.,,. IVChpter19.0 -Environmental Review19.4 IMPACTS OF PROPOSED CONSTRUCTION OPERATIONS, ANDDECOMMISSIONINGThis section provides an analysis of the impacts of the RPF construction, operation, anddecommissioning. Overall impact rankings are given to each environmental resource evaluated. Unlessotherwise defined, criteria followed the guidance given in NRC Impact Rankings at 10 CFR 51,Subpart A, Appendix B, Table B-i, Footnote 3, as follows:° Small -Environmental effects are not detectable or are so minor that they will neither destabilizenor noticeably alter any important attribute of the resource° Moderate -Environmental effects are sufficient to alter noticeably, but not to destabilize,important attributes of the resource° Large -Environmental effects are clearly noticeable and are sufficient to destabilize importantattributes of the resource19.4.1 Land Use and Visual Resources19.4.1.1 Land UseThis section presents the evaluation of impacts of the proposed action to land use in the 8 km (5-mi) ROI,as described in Section 19.3.Impacts on land use were assessed based on the consistency of the proposed action with State and localplans and on compatibility with land uses in and near to the proposed RPF site. Impacts include effectsfrom (1) activities associated with construction, including excavation, grading, placement of fill material,temporary staging and construction laydown, and construction of permanent features; (2) activitiesassociated with operations, including potential operational disturbances; and (3) activities associated withdecommissioning a nuclear medical isotope production facility, which are similar to construction exceptfor the final handling and disposition of radioactive materials and wastes.Factors considered for determining impacts involving changes to the affected environment are discussedin Section 19.3. The proposed RPF is considered to have an impact on land use if its presence:* Results in land use change on a short- and/or long-term basis* Curtails the range of beneficial uses of the environment* Involves substantial secondary land use impacts (e.g., population changes, effects on publicfacilities/infrastructure)* Conflicts with existing or planned land uses within Discover Ridge or the ROI* Conflicts or is incompatible with the objectives, policies, or guidance of State and local land useplans (e.g., Discovery' Ridge Master Plan and Protective Covenants [MU, 2009], "ColumbiaImagined, The Plan for How We Live & Grow" [City of Columbia, 2013c], Boone CoiuntiMaster Plan [Boone County, 1996])* Conflicts or is incompatible with administrative designations or special land uses* Conflicts or is incompatible with agricultural resources or facilities and mineral resourcesImpacts to land use are related to the amount of land disturbed and the type of construction on the land.The proposed RPF would be approximately 106.7 x 56.4 m (350 x 185 ft) and stands 19.8 m (65 ft) tallabove grade (maximum). The actual RPF building would occupy a rectangular area approximately 213 x91 mn (700 x 300 ft) at the outer perimeter and cover approximately 1.95 ha (4.8 acres) on Lot 15 ofDiscovery Ridge.19-1 73 MIALCatr1NWMI Rev. OANO hES Chaper 9.0 -Environmental ReviewThe land on which Discovery Ridge is sited is zoned for commercial agriculture; however, Missouri, viathe MU, has acquired and set aside this area to achieve the research park mission. Therefore, constructionof the proposed RPF would be consistent with land use at the park. Discovery Ridge is not mined or usedfor any mineral resources. Construction of the proposed RPF was found to be consistent with theobjectives, policies, and guidance of the Discover Ridge, Columbia, and Boone County land use plans.19.4.1.1.1 Impacts of ConstructionThe entire 3 ha (7.4 acres) of Lot 15 would be directly and permanently disturbed to construct and supportthe RPF. Construction staging activities could also occur along Discovery Drive bordering the lot and theadjacent Discovery Ridge Lot 14. Staging activities would be temporary and would cease afterconstruction of the facility. After the facility is built, landscaping would mitigate disturbances causedduring construction on the lot, both exterior of the perimeter fence and from the perimeter fence to theperimeter of the building. The facility would retain the amount of undeveloped open space and developedlandscaped areas in accordance with the Discovery Ridge covenants (MU, 2009). This includesmaintaining a minimum of 30 percent of the site (preferably 35 percent) as open for landscaping and notcovered by buildings or paving for access, circulation, loading, or parking.Direct impacts from construction activities would occur as ground disturbance. Indirect impactsassociated with construction activities could affect Discovery Drive. These impacts (e.g., broken curbingand pot holes) would be temporary since they could be mitigated through road repairs. Overall, becausedirect and indirect impacts are constrained to those typically associated with construction activitiesnecessary to build any facility, they would be small.19.4.1.1.2 Impacts of OperationAfter the RPF is constructed, no additional land would be disturbed during operational activities.Operational activities would not interfere with any surrounding land uses or change land uses near thefacility. Operations activities would not interfere with any mineral resource uses. The addition of98 employees to Discovery Ridge for facility operation would not result in a population change thatwould impact current facilities or infrastructure, or result in any subsequent changes to land use toaccommodate the increase. Thus, both direct and indirect impacts to land use from operations would besmall.19.4.1.1.3 Impacts of DecommissioningFrom a land use perspective, decommissioning activities (except for the final handling and disposition ofradioactive materials and wastes) are assumed to be similar to construction activities. The facility wouldbe demolished, and resultant land would return to commercial agriculture/open space. Facilitymodification and demolition activities both require (de)construction and staging activities. Thus, facilitydemolition activities would result in impacts similar to construction. No additional ground disturbancewould occur if the nuclear components of the building were decommissioned and removed, and if facilitymodification was confined to the interior of the building.Under decommissioning, an additional indirect impact would be an increase in landfilled materials fromdemolition activities for any materials that could not be recycled. This impact would not be significantfrom the proposed RPF in comparison to similar remodeling or demolition activities in the ROI. Impactsfrom final handling and disposition of radioactive materials and wastes under the decommissioningscenario are discussed in Section 19.4.10.19-174 ChaptrI1 WM,-20o3-021, Rev. OAliE Chapter 19.0 -Environmental Review*.. ..NORTHWEST MIEDICAL ISOTOPESWith the land at Discovery Ridge designated as a research park, it is reasonable to assume that the landwould not be returned to commercial agriculture use and the park would remain a dedicatedindustrial/research area for the foreseeable future. The RPF would be used for some time (20 to 40 years)and then demolished at the end of its useful life. As such, direct and indirect impacts to land use that canbe reasonably assumed from decommissioning activities are anticipated to be similar to the impactsassociated with construction, which would be small.19.4.1.2 Visual and Aesthetics ResourcesThis section describes the visual and aesthetic impacts of the proposed RPF during the phases ofconstruction, operations, and decommissioning. Potential impacts to viewers over the facility lifespan areaddressed. Satellite imagery was used to identify populations that would have views of the RPF. Thosewith views on a routine basis would be Discovery Park employees (currently RADII and ABCLaboratories), MU personnel associated with South Farm, residents at nearby homes or businesses,U.S. Highway 63 commuters, and regular travelers on the roads surrounding Discovery Ridge. Thosewith intermittent or a limited-basis view would be Discovery Ridge visitors, Nifong Park and PerryPhillips Lake users, and travelers passing through the area.Eight viewpoints were identified and used to conduct a GIS visual analysis to determine facility impactsto potential viewers and viewsheds. Viewsheds are areas of land or water visible from a fixed vantagepoint (see Section 19.3.1 .2). Using vantage points, viewsheds are calculated using the Spatial AnalystViewshed tool in ESRI ArcMap 10.A calculated viewshed shows all that an observer can see from that point. The tool does not take intoconsideration vegetation, buildings, fences, or other obstructions, but assumes the view is completelyunobstructed, with the exception of intervening topography (e.g., a mountain). Thus, all calculated RPFviewsheds conservatively represent maximum viewsheds because vegetation and structures are foundthroughout the ROI. The calculated observer is 183 cm (6 ft) tall and standing at ground level, aconservative height for analysis purposes. Using the combination of an unobstructed view and a tallperson as model parameters, the calculated viewsheds are exceptionally conservative regarding the viewsthat would be seen by a typical viewer. The viewsheds from the eight viewpoints were calculated andmapped, and the maps analyzed.Factors considered in determining if the proposed RPF would have a significant impact to visual andaesthetic resources include the extent or degree to which the facility would:* Introduce physical features that are substantially out of character with adjacent developed areas* Alter a site so that a sensitive viewing point or vista is obstructed or adversely affected, or if thescale or degree of change appears as a substantial, obvious, or disharmonious modification of theoverall view* Partially or completely obstruct views of the existing landscape* Create visual intrusions (e.g., radar towers, cooling towers, effluent stacks) to the existinglandscape character* Require the removal of natural or built barriers, screens, or buffers, thus enabling lower qualityviewscapes to be seen* Alter historical, archaeological, or cultural properties, other areas of a special land-use category,or the character of the property's setting when that character contributes to the property'ssignificance* Create visual, audible, or atmospheric elements that are out of character with the site or alter itssetting* Be inconsistent with the visual resource policies of the Discover.y Ridge Master Plan andC'ovenants (MU, 2009)19-175

' .,.:'NORPIWE MEOICAL0AISTPENWMI-2013-021, Rev. 0AChapter 19.0 -Environmental Review19.4.1.2.1 Visual ImpactsFigure 19-42 shows an artist's rendition of the proposed RPF to demonstrate what the completed facilitywould look like on Lot 15 of Discovery Ridge.Figure 19-42. Radioisotope Production Facility VisualizationPhotographs of RADIL and ABC Laboratories are provided in Figure 19-43 and Figure 19-44, respectively.The RPF in design and character, as shown in the artist rendition, and as approved by the design reviewcommittee operating under the Master Plan and Covenants, would be similar in aesthetics to thesebuildings. Because the facility is being sited on an open space, there are no natural or built barriers,screens, or buffers that would require removal; therefore, no lower quality viewscapes would becomevisible. As discussed in the Section 19.3.6, there are no historical, archaeological, or cultural propertiesor other areas of a special land-use category in, near, or associated with Lot 15 in Discovery Ridge, or inthe immediate area, with which the proposed RPF would be considered visually incompatible.Figure 19-43. Research and Diagnostic Laboratory Facility Located at Discovery Ridge19-1 76

...,NWMINWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewFigure 19-44. ABC Laboratories Facility Located at Discovery RidgeThe visual study, review of photos from the eight observer viewpoints, and the artist rendition of thefacility (Figure 19-42) provide significant data to determine the visual impacts with regard to partially orcompletely obstructing views of the existing landscape or creating intrusions in the existing landscapecharacter, as follows:*At its tallest point, the RPF's exhaust stacks, at 22.9 m (75 ft) total height and 3 m (10 ft) aboveroof level, would be the facility' s tallest fixed feature viewable from a distance. While steam,under certain meteorological conditions might be seen coming from the stacks, it would dissipatequickly and is not discussed further in this section. As a viewer observes the RPF from a vantagepoint and then continues to move closer to the facility, more of the facility would come into view,until the entire facility is viewable. Figure 19-18 through Figure 19-25 show various viewpointstoward Lot 15 in Discovery Ridge from distances between 0.4 and 4.4 km (0.25 and 2.72 mi).*When the RPF is completed, if the viewer is located on Lot 15, close to the facility, and expectingto look through or around the facility to the other side, the facility would partially or completelyobstruct views of the surrounding landscape. In this circumstance, having a blocked or obstructedview would be an expected impact of placing a facility in an open space where no facility existedbefore. Because the land was designated for use as a research park, it is reasonable to expect thatat some point buildings supporting research would be constructed. As such, observers who arelocated at close range to the facility would have views of the facility, and their views towardlandscapes on the other side of the facility would be partially or completely obstructed by thefacility.To determine the visual impacts associated with fully or partially obstructed views from further distances,views toward the facility from the eight viewpoints were analyzed with Spatial Analyst Viewshed tool inESRI ArcMap 10. The resultant viewshed is shown in Figure 19-45. The figure shows the areas fromwhich an observer can see the stacks on the RPF. Again, this analysis does not account for screening effectsfrom structures and vegetation, and provides the maximum potential viewsheds from the observer points.19-1 77 NW NWMINWMI-2013-021, Rev. 0AChapter 19.0 -Environmental Review* PhotopointsA RPFCJ 75' Stack is Potentially Visible within this Area8 km (5 mile) Radius from RPF36§0 0.45 0.91.82.7Miles!Figure 19-45. Stack Potentially Visible Areas19-178 NWM*LU I~f WI21-2,Rv oA: : Chapter 19.0 -Environmental Review19.4.1.2.2 Impacts of ConstructionThe most noticeable impact to viewers would be during the construction phase. Lot 15 of DiscoveryRidge would transition from an area of open space to a fully constructed facility with surroundinglandscaping. During this initial phase, changes at the lot would be significant and noticeable. Thechanges would not be out of character with the research park, but the changes would seem sudden anddramatic, particularly to viewers familiar with Discovery Ridge. Specific activities at the lot would bevaried on a daily basis, but would be similar to general facility construction project activities, including:* Heavy equipment would be brought onsite* Materials would be staged on the lot and in the immediate area around the lot* Workers would use equipment for excavation, grading, and building activities* Cranes may be onsite to lift and place materials and components in the facility and on the lotAs the facility progresses toward completion, there would be less large equipment and constructionpersonnel on the exterior of the building as work proceeds to interior construction-related activities (e.g.,electrical installation, sheetrocking, and painting). The final exterior work would require equipment andpersonnel for grading, paving, and landscaping. When the building is complete, the view from the streetand from the other facilities in the park is anticipated to be similar to the views one can see of the RADLLand ABC Laboratories buildings shown conceptually in Figure 19-42, and in Figure 19-43 andFigure 19-44.As discussed in Section 19.3.1.2, the Disco very, Ridge Master Plan and C'ovenants (MU, 2009) addressesvisual resources and scenic considerations throughout the plan's building and design requirements. At aminimum, compliance with the following covenants and review by the Discovery Ridge DesignCommittee would ensure that the RPF visual impact is compatible with the character of the propertysetting (MU, 2009):* 5.4, Minimum Open Space and Landscaped Area* 5.5, Building Height* 5.6, Exterior Appearance of Buildings* 5.8, Parking and Loading Areas* 5.12, Landscape Design* 5.13, Site Lighting* 5.14, Storage Areas and FencesWhile the visual impacts are most notable during the construction phase, over time, as viewers becomemore aware of the activities Discovery Ridge, view the activities more frequently, and the buildingprogresses to completion, the building's presence becomes less noticeable. Because the proposed RPFwould be in context with Discover Ridge and its setting, it is unlikely that the average viewer would seethe facility as an isolated structure or a distraction on the overall landscape. In context, impacts ofconstruction on visual resources are considered small.19.4.1.2.3 Impacts of OperationsThe RPF would not generate electricity and thus does not maintain any power transmission lines. Whilesteam might be seen coming from the stacks under certain meteorological conditions, it would dissipatequickly and is not discussed further in this section. Operation of the RPF has no visual impact onanything external to the building, including the aesthetics of the surrounding area. The facility wouldlook the same on a daily basis during the operations phase. The impacts to visual resources would berestricted to the impact the facility has on the landscape, which is small.19-179 Chptr1MWI-0I-21 ev. QlviChptr 9.0 -Environmental Review*NORIWVEST ME~IICM ISOTOPES19.4.1.2.4 Impacts of DecommissioningAt the end of its lifespan, the RPF would be demolished and returned to commercial agriculture use oropen space. Facility demolition would require activities similar to construction activities. For example,heavy equipment would be used, a crane might be needed to remove interior components to transport, anda number of personnel would be onsite. There would be considerable activity occurring daily as thefacility is demolished, until the end result is obtained. From a visual and aesthetics resource perspective,facility demolition activities are not uniquely different from construction activities. As such, visualimpacts during decommissioning would be similar to those seen in the construction phase, and areconsidered small.19.4.2 Air Quality and Noise19.4.2.1 Air QualityThe proposed RPF site is located in Boone County, Missouri, which is part of the EPA Region 7. TheMissouri DEQ is the regulatory agency responsible to protect and enhance the quality of the Missourienvironment and its citizens, while the MDNR operates an extensive network of ambient air monitors tocomply with the Clean Air Act and its amendments.The ambient air quality monitoring network for Missouri includes State and local air monitoring stations,special purpose monitoring stations, and National Core (NCore) multi-pollutant monitoring stationsconsistent with requirements in Federal regulation 40 CFR 58.10. The only DNR air monitor in BooneCounty is located at Finger Lakes and monitors for 03 from May to October each year. The MDNRcontinuous air monitors nearest to the proposed RPF site, which are also in similar urban locales, are inthe following locations:* Mark Twain State Park -In Stoutsville, Monroe County, approximately 103 km (64 mi)northeast of the proposed RPF site; monitors for SO2, 03, and inhalable particulates PM-10 andPM-2.5* El Dorado Springs -In Cedar County, approximately 261 km (162 mi) southwest of theproposed RPF site; monitors for NO2, inhalable particulate PM-2.5, and 03Both air monitor locations are well outside of the ROI.The EPA established NAAQS for six common pollutants (also referred to as "criteria" pollutants).Missouri DEQ monitors for CO, NO2, 03, total suspended particulate, inhalable particulates (PM-10 andPM-2.5), and Pb. Other pollutants or compounds are measured as part of air toxics or particulatespeciation sampling. Legal descriptions of the standards are provided in 10 CSR 10-6, "Air QualityStandards, Definitions, Sampling and Reference Methods and Air Pollution Control Regulation for theEntire State of Missouri." The NAAQS are summarized in Table 19-27.Gaseous effluents at the proposed RPF would originate from several sources, including constructionequipment, isotope production, fuel combustion from heating and generating systems, anddecommissioning activities. RPF operations would generate gaseous effluents. The permits required forrelease and their status are listed in Table 19-4. The anticipated gaseous effluents and their associated airquality parameters for construction, operations, and decommissioning are discussed in the followingsubsections.19-1 80 ChptrMWI-0I-21 ev. OIUVVCapter19.0 -Environmental Review*.. ..NORl'1WEST MEDICAL ISOTOPES19.4.2.1.1 Air Impacts from ConstructionConstruction activities result in localized increases in air emissions. Earthmoving, excavation, clearing,pile driving, erection, batch plant operation, and construction-related traffic generate fugitive dust andfine particulate matter that potentially impact both on-site workers and off-site residents of thecommunity. Vehicles and engine-driven equipment (e.g., generators and compressors) generatecombustion product emissions such as CO, NOx, and, to a lesser extent, S02. Painting, coating, andsimilar operations also generate emissions from the use of VOCs.People living near or working at or near construction sites may be subject to the physical impacts ofconstruction activities. Activities associated with the use of construction equipment may result in varyingamounts of dust, air emissions, noise, and vibration. The magnitude and area of extent of the impactsfrom these emissions depends on atmospheric conditions at the time of the activity. The magnitude ofthese potential impacts is typically related to specific construction controls and the proximity of the site topopulated areas. Contractors, vendors, and subcontractors are required to adhere to appropriate Federaland State occupational health and safety regulations. These regulations set limits to protect workers fromadverse conditions, including air emissions.19.4.2.1.1.1 Fugitive DustEarth-moving activities involve operation of heavy construction equipment on exposed soil. Methods forcalculating fugitive dust emissions for earth-moving activities outlined in EPA AP 42, Conmpilation of AirPollutant Emission Factors, Volume 1, Stationary Point and Area Sources, Chapter 13, "MiscellaneousSources" (EPA, 2010) were used. Activity rates (A) for earth-moving were derived from information onhours of vehicle operation, tons of material moved, or vehicle miles traveled.E = A x EF x (1-ER/100)where:E = emissionsA = activity rateEF = emission factorER =overall emission reduction efficiency, percentageValues for these parameters are expected to evolve over time as design parameters are refined. Therefore,conservative parameter values based on the notional facility designs were established to bound PM-10and PM-2.5 activity rates. Activity rates for each parameter are provided in Table 19-51.19-1 81 NWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-51. Activity Parameters for Earth Moving£ B- 6 6, 0 .-B -.BulldozingLoading of earth haulers from frontlnader.shrhr1110060NA NA10,886 12,000Compactinghr1 80 NA NASources: EDF-3 124-0001, 2015, Estimate of Excavation for the NWMI Radioisotope Production Facility, Rev. 3,Portage, Inc., Idaho Falls, Idaho, February 2, 2015.EDF-3 124-0004, 2015, Calculation for the Determination of Fugitive Dust during Construction Activitiesfrom Construction Equipment, Rev. 1, Portage, Inc., Idaho Falls, Idaho, February 3, 2015.NA= not applicable.Equations recommended by the EPA (EPA, 2010, Section 13.2, Table 13.2.3-1) for dust-generatingoperations using heavy equipment on exposed soils were used to calculate emission factors for differentsizes of particulate matter. Emission factors for earth moving activities were based on guidance(EPA, 2010) and are provided in Table 19-52 (EDF-3 124-0004, Calculation for the Determination ofFugitive Dust during Construction Activities from Construction Equipment). The total PM-10 andPM-2.5 emissions from earth moving activities during construction presented in Table 19-52 aresummarized in Table 19-53.Table 19-52. PM-10 and PM-2.5 Emission Factorsfor Earth-Moving Activities During ConstructionBulldozingkg/hrlb/hr4.05E-018.92E-014.17E-019.1 9E-0 1Loading of earth haulers from frontloadersaIkg/t 2.96E-02 4.48E-03alb/ton 5.92E-02 8.96E-03Copcigkg/hr 4.05E-01 4.17E-01Copciglb/hr 8.92E-01 9.19E-01Source: EDF-3 124-0004, 2015, Calculation for the Determination of Fugitive Dust during Construction Activitiesfrom Construction Equipment, Rev. 1, Portage, Inc., Idaho Falls, Idaho, February 3, 2015.a Per ton of material moved.PM-2.5 = particulate matter, 2.5 PM-b1 = particulate matter, 10 VMT -vehicle miles traveledVKM -vehicle kilometer traveled19-182

., NM, .NWMI-2013-021, Rev. 0AChapter 19.0- Environmental Review19.4.2.1.1.2 Fugitive Dust Emissions fromWind Erosion of Bare GroundAreas where wind erosion of bare groundcould occur during construction include alldisturbed areas whether temporary orpermanent, including clear and grub areas,roadways, rail lines, power lines, piping, batchplant footprint, gravel pit, and stockpiles.Equations and calculation steps for winderosion of bare ground from EPA (2010),Section 13.2.5, were used. PM-10 and PM-2.5emissions for wind erosion of bare groundduring construction are provided inTable 19-54 (EDF-3 124-0006, Determinationof Wind-Blown Dust during ConstructionActivities).Table 19-53. Annual PM-10 and PM-2.5 Emissionsfrom Earth-Moving Activities During Constructionkgt1 .4E+031.42.7E+0227PM-2.5 = particulate matter, 2.5 PM-10 = particulate matter, 10 Table 19-54. Annual PM-10 and PM-2.5 Emissionsfrom Wind Erosion of Bare Ground19.4.2.1.1.3Summary of Total ParticulateMatter Emission fromConstruction Activitieslb 160 24The total release of particulate matter (PM- 10and PM-2.5) from construction of the facilitypresented in Table 19-53 and Table 19-54 issummarized in Table 19-55. Implementationof controls and limits at the source ofemissions on the construction site would resultin a reduction of impacts offsite.tons0.0820.012Source: EDF-3 124-0006, 2014, Determination of Wind-Blown Dust during Construction Activities, Rev. 0,Portage, Inc., Idaho Falls, Idaho, June 26, 2014.PM-2.5 = particulate matter, 2.5 PM-10 = particulate matter, 10 Table 19-55. Total PM-10 and PM-2.5 Emissions from ConstructionS -S S SEquipmentTotals1 .4E+0314733.0E+03 1.5 1.43160 1.6 1.5270 6.0E+020.27 0.300.28 0.31281624PM-2.5 = particulate matter, 2.5 PM- 10 = particulate matter, 10 Specific mitigation measures to control fugitive dust may include any or all of the following:* Stabilizing construction roads and spoil piles* Limiting speeds on and periodically watering unpaved construction roads* Covering haul trucks when loaded or unloaded* Minimizing material handling (e.g., drop heights, double-handling)* Phased grading to minimize the area of disturbed soils* Revegetating road medians and slopes19-1 83

• . NOIWnSTMICtSTPNWMI-201 3-021, Rev. 0AChapter 19.0 -Environmental Review19.4.2.1.1.4 Vehicle Emissions -Criteria PollutantsOn-road vehicles -On-road vehicle emissions estimates were generated for construction vehicles usedfor hauling and delivery of materials and for the construction workforce traveling to and from theconstruction site. The EMFAC201 1 model was used to calculate on-road vehicle emission factors for thisperiod. The model estimates vehicle emission factors based on fuel type, vehicle type, vehicle speed, andthe climatological normal for temperature and humidity.EMFAC201 1 is the latest installment of the EMFAC series of models, which is the California AirResources Board tool for estimating emissions from on-road vehicles. EMFAC201 1 was used tocalculate on-road and non-road vehicle emission factors for the construction period. The model producesan estimation of vehicle emission factors based on fuel type, vehicle type, vehicle speed, andclimatological normal for temperature and humidity.On-road vehicle emissions were calculated using emission rate in grams (g)/(vehicle miles traveled) +g/day(idle) + g/day(starting). On-road vehicles considered for the construction period were dump trucks,concrete trucks, asphalt trucks, and general delivery trucks. For workforce travel during construction,light-duty gas vehicles, light-duty gas trucks, and light-duty diesel trucks were considered. A round tripvalue of 64.4 km (40 mi) and a vehicle split of 60 percent light-duty gas vehicles, 30 percent light-dutygas trucks, and 10 percent light-duty diesel trucks were assumed for workforce travel.Total mileage estimates for on-road vehicles during the construction period are shown in Table 19-56(EDF-3 124-0005, On-Road Emissions for Vehicles during Construction). Estimates of the on-roadvehicle emissions for criteria pollutants and carbon dioxide (CO2) are provided in Table 19-57(EDF-3 124-0005); emissions are presented for an estimated construction period spanning 17 months.Table 19-56. Total Mileage Estimates for On-Road VehiclesEarth haulers (dump trucks) (4)Asphalt trucks (2)Workforce travel (60)Workforce travel (10O)Material hauling (3 months) 4,258 2,646Asphalt hauling (14 months) 811 504Commute -light duty gas vehicles (17 months) 1,421,373 883,200Commute -light duty diesel trucks (17 months) 236,895 147,200Source: EDF-3 124-0005, 2014, On-Road Emissions for Vehicles during Construction, Rev. 0, Portage, Inc.,Idaho Falls, Idaho, June 26, 2014.19-184

• ~ NWMINWIThWESI MEOCA SO OPt SNWMI-2013-021, Rev. GAChapter 19.0- Environmental ReviewTable 19-57. On-Road Vehicle Emissions (During Construction)S 6 6 -S -09~ -9 9 S S 5 6 6 6 9 9 S SLight duty Gasautos1,500 3,400 140 300 320,000 700,000 2.14.6 1.9 4.2 3.2 7.1Light duty Diesel 49 110 99 220 52,000 120,000 9.0 20 8.3 18 0.50 1.1trucksEarth Diesel 1.8 3.9 21 47 3,3000 7,200 0.22 0.49 0.21 0.45 0.031 0.069haulersAsphalttrucksDiesel 1.1 2.5 9.3 21Totals (t) (tons)3.50 3.86 0.72 0.791,000 2,200597.44 658.700.0560.12 0.050 0.11 0.010 0.022li I 370 1 .316i~ i i1.68 1.85 1.52 1.68 6.0 6.61E-02 E-02 E-02 E-02 E-03 E-03Source: EDF-3124-0005, 2014, On-Road Emissions for Vehicles during Construction. Rev. 0, Portage, Inc.,Idaho Falls, Idaho, June 26, 2014.PM-2.5 = particulate matter, 2.5 ps.PM-10 = particulate matter, 10 Off-road vehicles -Off-road vehicle emissions were estimated for diesel-fueled construction equipmentused for moving, grading, and compacting earthen materials using emission factors for off-roadconstruction based on values from the EPA NONROAD model. Model emission factors were based ong/hr. These values were combined with the number of pieces of equipment and hours of operation toestimate the total pounds released for each activity. The results are shown in Table 19-58(EDF-3 124-0009, Off-Road Emissions During Construction).While emissions from construction activities and equipment are unavoidable, the implementation ofmitigation measures minimizes the impacts to local ambient air quality and the nuisance impacts to thepublic in proximity to the project. Mitigation measures may include any or all of the following:* Implementing controls to minimize daily emissions such as reducing engine idle time, usingcleaner fuels (e.g., ultra-low sulfur diesel fuel or biodiesel), installing pollution control equipmenton construction equipment (e.g., diesel oxidation catalysts and particulate matter filters), andcurtailing or controlling the time of day construction activities are performed* Performing proper maintenance of construction vehicles to maximize efficiency and minimizeemissions19-185

• ;:.:IIA ilNWMI-2013-021, Rev. GAChapter 19.0 -Environmental ReviewTable 19-58. Air Pollutant Emissions Factors for Off-Road Construction Equipment* 0

• S

• SS S S S SBulldozer 1 100 140 310 19 41 6.3Excavators 1 60 49 110 7.5 17 2.4Graders 1 80 66 150 10 22 3.2Asphalt roller 1 80 100 230 14 31 4.7145.47.2104.7 10 13,000 29,000 23 511.8 4 4,500 10,000 8.1 182.4 5.4 6,000 13,000 11 243.5 7.7 9,700 21,000 17 38Source: EDF-3124-0009, 2014, Off-Road Emissions during Construction, Rev. 0, Portage, Inc., Idaho Falls,Idaho, June 26, 2014.PM-2.5 = particulate matter, 2.5 PM-10 = particulate matter, 10 It.19.4.2.1.1.5 Emissions ModelingEmissions from construction activities were evaluated using AERSCREEN, Version 11126. Thisscreening model uses standard defaults for meteorology and terrain values. Modeled emissions includedPM-10, PM-2.5, CO, NOx, and sulfur oxides (SOs). The model estimated ambient air concentrations at112 m (368 ft) (nearest road) and 375 m (1,230 ft) (near residence). These values were then compared torelevant Missouri and EPA air quality standards. This comparison is summarized in Table 19-59. Insummary, unmitigated air emissions during construction are below Federal and State emissions standardsfor all parameters except PM-10 at 375 m (1,230ft) (closest residential receptor). The standard mitigationmethods described previously would be used to ensure that the PM- 10 levels at 112 m (368 ft) remainbelow the air quality parameters (6 CSR Division 10) (EDF-3 124-0014, Emission Modeling forConstruction Activities using AERSCREEN).Table 19-59. Anticipated Gaseous Effluents andTheir Associated Air Quality Parameters for ConstructionPM-10 W, C, OR 1,483 3,270 2.95 .tg/m3NOx C, OR 646 1,422 6 pSOx C, OR 107 236 0.008 ppm1.21 l[tg/m3 b150 30.009 ppm f0.0'75 ppmSource: EDF-3124-0014, 2014, Emission Modeling for Construction Activities using AERSCREEN, Rev. 0,Portage, Inc., Idaho Falls, Idaho, June 26, 2014.aW = wind-blown dust, C = construction activities, OR = emissions from off-road construction activities.b 24-hr, not to be exceeded more than once per year on average over three years.24-hr, 98th percentile, averaged over three years.d1-hr, 98"' percentile, averaged over three years.e8-hr, not to be exceeded more than once per year.1 1-hr, 99th percentile of 1-hr daily maximum concentrations, averaged over three years.PM-2.5 = particulate matter, 2.5 PM- 10 = particulate matter, 10 Ix.19-186

( W INWMI-2013-021, Rev. GAChapter 19.0 -Environmental Review19.4.2.1.2 Air Quality Impacts from OperationsOperation activities may result in a slight increase in vehicle traffic in the immediate area of the proposedRPF, which could cause a slight increase in internal combustion emissions such as GO, NOx and, to alesser extent, SO2.Operation of the emergency standby generator would also result in a slight increase inemission products, but due to intermittent use, these emissions would be low. The majority of effluentwould be from radioisotope production and the release of a small amount of gaseous fission products.The offgas system is designed to filter and/or retain these isotopes in the facility until they are less thanthe established allowable concentrations for residential receptors. Each of these emissions is discussed inthe following subsections.19. 4.2.1.2.1 Stack CharacteristicsThe RPF is designed to have five emission points that would each vent different areas of the process. TheZone I, Zones II/III, and the laboratory stacks would be located in the northwest corner of the facility(Figure 19-9) and extend 22.9 m (75 It) high, which is 3 m (10 ft) above the building roof. The locationsof the process steam and HVAC boilers are not shown on Figure 19-9. A summary of the five emissionsources is provided below.Zone IExhaust air flow rate:Diameter:Exhaust velocity:Release frequency:Effluent temperature:Zone II/IllExhaust air flow rate:Diameter:Exhaust velocity:Release frequency:Effluent temperature:Laboratory ExhaustExhaust air flow rate:Diameter:Exhaust velocity:Release frequency:Effluent temperature:Process Steam BoilerExhaust air flow rate:Diameter:Exhaust velocity:Release frequency:Effluent temperature:IIVAC BoilerExhaust air flow rate:Diameter:Exhaust velocity:Release frequency:Effluent temperature:534 m3/min (18,850 ft3)/min)86 cm (34 in.)911 mn/min (2,990 ft/min)ContinuousAmbient999.5 m3/min (35,300 ft3/min)117 cm (46 in.)933 rn/min (3,060 ft/min)ContinuousAmbient467 m3/min (16,500 ft3/min)81 cm (32 in.)900 rn/min (2,955 ft/min)ContinuousAmbient39 m3/min (1,386 ft3/min)30.4 cm (12 in.)538 rn/min (1,765 ft/min)Continuous29°C (850F)40.6 m3/min (1,435 ft3/min)30.4 cm (12 in.)557 mn/min (1,827 ft/min)Continuous29°C (85°F)19-1 87

• 1 INWMI-2013-021, Rev. 0A1IUVIVIlI Chpe 9.0- Environmental Review* .*

• IS " ffiUTU~mCA. IS119.4.2.1.2.2 Gaseous Control System DescriptionProcess exhaust offgases would be treated in two subsystems for the process offgas components and forthe primary exhaust system for the hot cell(s). Each process offgas subsystem would treat the processoffgas components separately to prevent mixing of waste constituents. A detailed description of thegaseous control system is provided in Section 19.2.3.2.12.19.4.2.1.2.3 Releases from Isotope ProductionGaseous effluents from the RPF production process would originate from three main sources:* Processing of irradiated targets for recovery and purification of 99Mo product* Recovery of LEU from the target processing activities° Recycling the recovered uranium for fabrication into new targets.Process offgases are treated in two subsystems that serve the process offgas components and the primaryexhaust system for the hot cell(s).Each process offgas subsystem would treat the process offgas components separately to prevent mixing ofwaste constituents. (Addition information is provided in Section 19.2.3.2.12.) Gaseous effluentsresulting from the production process are based on a 50-week/year operating schedule. There are noemissions of CO, Pb, 03, or particulate matter from the process exhaust system. All iodine fissionproducts would be removed using absorption methods. Fission product gases such as xenon (Xe) andkrypton (Kr) would be removed using gas trapping to allow decay. The resulting release would bemaintained until levels are less than those defined in Table 2 of 10 CFR 20, Appendix B, "Annual Limitson Intake (ALI) and Derived Air Concentrations (DAC) of Radionuclides for Occupational Exposure;Effluent Concentration; Concentrations for Release to Sewerage."19.4.2.1.2.4 Releases for Fuel CombustionEmergency generator -A diesel generator is used for temporary operation and safe shutdown of the systemif required. The emergency generator would emit CO, NOR, PM, SO2, VOCs, and CO2, as summarized inTable 19-60, assuming less than 24 hr of operation a year, as required for routine maintenance(EDF-3124-0008, Emissions from Natural Gas Boiler and Emergency Diesel Generator Operation).Table 19-60. Emissions for Standby Emergency Diesel Generator3.3 0.12 7.9 0.28 710 25 0.43 0.015 2.5 0.087Standby 2,600 kW 8.7 19 21 45 1,800 4,000 1.1 2.4 6.4 14diesel generator dpryear 21 6 9 &0 4,00 9,0 7 5 5 4Source: EDF-3124-0008, 2014, Emissions from Natural Gas Boiler Operation, Rev. 0, Portage, Inc., IdahoFalls, Idaho, June 26, 2014.aValues from U.S. Environmental Protection Agency Tier 4 standards for non-road diesel generators (Table 7of 40 CFR 1039.102, "What exhaust emission standards and phase-in allowances apply for my engines in modelyear 2014 and earlier.").b Values from EPA, 2010, Compilation of Air Pollutant Emission Factors, Volume 1, Stationary Point andArea Sources, AP 42, Fifth Edition, U.S. Environmental Protection Agency, Office of Air and Radiation,Washington, D.C., 2010.CAssumes 0.5% sulfur content.d Assumes 24 hr/year operation for maintenance.PM = particulate matter.19-188 NWM INWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewNatural gas-fired boilers -Severalcombustion sources at the proposed RPFwould contribute to the gaseous effluents.These combustion sources would be twonatural gas-fired boilers using steamproduction and two natural gas-fired boilersusing heating. In addition to these natural gas-fired heaters, a diesel-fired standby dieselgenerator is proposed at the facility.The two steam boilers and the two boilers usedfor heating would be released through twoseparate stacks. The boiler and generator allemit CO, NOx, PM, VOCs, and CO2.assummarized in Table 19-61 and Table 19-62(EDF-3 124-0012, Emission Modeling forProcess and HVAC Boilers UsingAERSCREEN). The total annual emissions fornatural gas-fired boilers are summarizedTable 19-61 (EDF-3124-0008).Table 19-61. Natural Gas-Fired BoilerTotal Annual EmissionsCOPM (total)S02160.360.12180.400.131.07 4.20.03 0.390.009 0.030Source: EDF-3 124-0008, 2014, Emissions from NaturalGas Boiler Operation, Rev. 0, Portage, Inc., Idaho Falls,Idaho, June 26, 2014.PM = particulate matter.VOC = volatile organic compound.The AERSCREEN modeling system was used to assess the impacts of pollutants expected to begenerated by the RPF from the production unit's four natural gas-fired heaters and the standby emergencydiesel generator.Table 19-62. AERSCREEN Model Total Annual EmissionsCO 4.3E+00CPM-IO (total) 3.9E-01evoc 2.8E-01fco26.1E+0318U!!:1iii i!i iiii! i1.61.226,0007.2E+016.5E+005.1 E-0 14.6E+0 14.2E+003.3E-014.0E+04g 150NASource: EDF-3 124-0012, 2015, Emission Modeling for Process and HVA C Boilers Using AERSCREEN,Rev. 1, Portage, Inc., Idaho Falls, Idaho, February 4, 2015.aIt was determined that the stack effluent maximum concentration was found at 136 m (446 ft).b Based on 50 weeks/year.cUsed as PM-10 values.dAssumed to represent PM-2.5.eNo NAAQS for volatile organic compounds.SNo NAAQS for carbon dioxide.£ 24-hr standard for PM-10 and PM-2.5NA = not applicable.NAAQS -- National Ambient Air Quality Standards.PM-2.5 = particulate matter, 2.5 PM-10 = particulate matter, 10 VOC = volatile organic compound.19-1 89 NW U IMVII Chpeo WI21-2,Rv. Qi : Chpter 9.0 -Environmental ReviewRelease point characteristics -Emissions and stack characteristics for each emission source are basedon the design parameters, assumptions, and emission factors. Exhaust characteristics for the boilers areestimated based on heat input to the source, fuel consumption, and combustion calculations assuming30 percent excess combustion air and 75 percent efficiency.Exhaust gas temperatures for the natural gas-fired boiler are based on temperature data provided by boilervendors for other similar projects. Exhaust from the natural gas-fired boiler is vented to the atmospherethrough different 22.9 m (75 ft) stacks that are separate from the other three process stacks. Each stack is4.9 m (10 ft) taller than the tallest point of the building.The results of the AERSCREEN model, as it relates to the NAAQS, are shown in Table 19 62. Theresults are presented for the point of maximum concentration (136 m [446 ft]J) and at 375 m (1,230 ft),which represents the distance to the closest residential receptor. As shown in Table 19 62, no pollutant isestimated to be released during normal RPF operations that exceeds the NAAQS based on AERSCREENmodeling, making the need for more detailed modeling unnecessary (EDF-3124-0012).19.4.2.1.2.5 Vehicle and Other EmissionsDuring the operations phase, vehicular air emissions would result from the commuting workforce andfrom routine deliveries to and from the proposed RPF. EMFAC20 11 was used to calculate on-roadvehicle emission factors for this period. The model estimates vehicle emission factors based on fuel type,vehicle type, vehicle speed, and climatological normal for temperature and humidity.The volume of traffic generated during operations would be considerably lower than that expected duringconstruction. In additional, the lands on the RPF site are either developed surfaces (buildings, pavedparking/access road) or consist of either agricultural or landscaped areas. Consequently, limiting routinevehicle use to paved areas would reduce the emission of fugitive dust. In summary, impacts from vehicularair emissions and fugitive dust during operations would be far less than during the construction phase.Emissions data shown in Table 19-63 provide an estimate of vehicle emissions. Calculations used toobtain the estimates are based on an average workforce of 25-50 vehicles/day using a specific vehicleratio (60 percent light-duty autos, 30 percent light-duty gas trucks, and 10 percent light-duty diesel trucks)and a round trip of 40 mi/day (EDF-3124-0013, On-Road Emissions for Vehicles During Operations).Table 19-63. Vehicle Emissions During OperationsLight duty autos Gas 540 1,200 48 110 110,000 250,000 0.74 1.62 0.67 1.48 1.1 2.5Light duty trucks Diesel 17 39 35 77 19,000 41,000 3.2 7.0 2.9 6.5 0.18 0.39Source: EDF-3124-0013, 2014, On-Road Emissions for Vehicles During Operation, Rev. 0, Portage, Inc.,Idaho Falls, Idaho, June 26, 2014.PM-2.5 = particulate matter, 2.5 gi.PM-10 = particulate matter, 10 gi.19-190 NOhWETMEDCLISOOE hpe NWM,-2013-02, Rev. OA: l Chapter 9.0 -Environmental Review19.4.2.2 MonitoringGaseous effluents from the RPF would be released through three separate stacks (Zone I stack, Zones 111IIIstack, and the laboratory stack) (discussed in Section 19.2.3.2.12). The airborne effluent exhaust from theZone I stack is expected to contain measurable quantities of noble gas radioactivity (i.e., Xe and Kr).There could also be radioactive iodine, radioactive particulates, and tritium in the airborne effluentexhaust. Due to the expectation of having measurable quantities of radioactivity in the airborne effluentand since malfunction of the exhaust carbon filtration system could result in a change in iodineradioactivity releases, the Zone I exhaust stack would be continuously monitored for gross gammaradioactivity. Grab sampling provisions would also be in place to support routine collection and analysisof gas and particulate samples from the Zone I exhaust stack to identify radionuclides, identify relativeconcentrations of radionuclides in the airborne effluent, and quantify radionuclide releases. Nomonitoring would occur for the HVAC and process steam boiler stacks.19.4.2.2.1 Air Impacts from DecommissioningFollowing the cessation of operations, the facility would be decommissioned. Decommissioningactivities, however, are assumed to be similar to construction activities and involve heavy equipment todismantle buildings and remove roadway and parking facilities. Effluents resulting fromdecommissioning are anticipated to be similar to the impacts associated with construction, with theaddition of some particulate fission products radionuclides as a result of contamination of the equipmentused in the process. The nonradioactive emissions should not exceed those defined in Table 2 of10 CFR 20, Appendix B. Radioactive releases from contaminated equipment would be mitigated toacceptable levels using standard containment methods and procedures.19.4.2.2.2 Visibility Impacts19.4.2.2.2.1 Impacts of ConstructionPeople living near or working at or near construction sites may have some visibility impact due toconstruction activities. The use of construction equipment may result in varying amounts of dust and airemissions. The magnitude and area of extent of the impacts from these emissions depends onatmospheric conditions at the time of the activity. BMPs, including dust control suppressants, would beused to limit any impacts. Contractors, vendors, and subcontractors would be required to adhere toappropriate Federal and State occupational health and safety regulations. Given the above-mentionedfactors, the visibility impacts associated with gaseous effluents during construction are considered small.19.4.2.2.2.2 Impacts of OperationQuantities of gaseous effluent released from the facility during operations would be below regulatorylimits, and these quantities are not anticipated to result in visibility impacts. As such, the visibilityimpacts associated with gaseous effluents during operation are considered small.19.4.2.2.2.3 Impacts of DecommissioningFollowing the cessation of operations, the facility would be decommissioned. Decommissioningactivities are similar to construction activities and involve heavy equipment to dismantle buildings andremove roadway and parking facilities. Visibility impacts from decommissioning are anticipated to besimilar to the visibility impacts associated with construction and, as such, are considered small.19.4.2.2.3 Greenhouse Gas EmissionsGHGs trap heat in the atmosphere, absorbing and emitting radiation in the thermal infrared range. Themost important of these gases are CO2.methane, nitrous oxide, and fluorinated gases. GHGs are reportedas CO,. equivalent (CO2e) and refer to the global warming potential of the GHG or gases being emitted.19-1 91 NW MvIi hpe NWM,-2013-021, Rev. OA.*. NORhChaptIer 1TOES9.0 -Environmental ReviewActivities associated with the proposed RPF site that are expected to contribute to GHGs (summarized inTable 19-64) include:Construction activities at thesite principally result in Table 19-64. Expected Green House Gas Emissions fromemissions of CO2; GHG Radioisotope Production Facility Projectemissions associated withconstruction activities includethose from the commuting -00construction workforce and Construction phase onsite 44,000 97,000operation of constructionCOSUIOpheofst 61,013000equipment at the site..........Normal plant operations* Plant operation activities (per year) 23,000,000 51,000,000associated with the operation of..,..plant equipment and the Op........ ....oad..operations workforce veil rae yer ,0 3,The ncrasein ttalGH~ in he orm Source: EDF-3124-001 1, 2014, Greenhouse Gas Emissions,The ncrasein ttalGH~ in he orm Rev. 0, Portage, Inc., Idaho Falls, Idaho, June 26, 2014.of CO2 from on-road and off-roadsources, and the annual CO2 expected from normal operations are summarized in Table 19-64(EDF-3 124-0011, Greenhouse Gas Emissions).NWMI will develop a comprehensive program to avoid and control GHG emissions associated with theRPF. This program is expected to include elements such as:* Developing a GHG emission inventory* Investigating and implementing methods for avoiding or controlling identified GHG emissions* Encouraging carpooling or other measures to minimize GHG emissions due to vehicle traffic* Conducting periodic audits of GHG control procedures* Implementing corrective actions when necessary19.4.2.2.4 MitigationsEmission-specific strategies and measures would be developed and implemented to ensure compliancewithin the applicable regulatory limits defined by the National Primary and Secondary Ambient AirQuality Standards (40 CFR 50) and NESHAP (40 CFR 61). Contractors, vendors, and subcontractorswould be required to adhere to appropriate Federal and State occupational health and safety regulations.These regulations set limits to protect workers from adverse conditions, including air emissions.Implementation of controls and limits at the source of emissions on a construction site result in reducedimpacts offsite.1 9.4.2 .2 .5 MeteorologyMeteorological measurements would be available for use in responding to accidental radiological releases,other emergencies, and any other routine purposes that require access to meteorological information duringthe licensing period. That meteorological information would be obtained for local government weathermonitoring stations that observe wind and other surface meteorological parameters on an hourly basis.19-1 92 SIVIIICatr NWM,-2013-021, Rev. 0AA SOChaptSr19.0 -Environmental ReviewWhen needed during an emergency, real-time hourly surface meteorological measurements of winddirection, wind speed, air temperature, and weather type would be accessed by NWMI throughGovernment data sources. Access would be attempted during the emergency in the following sequence,until reliable data is obtained, as follows:1. Internet access to hourly surface weather observations recorded at station 231791, ColumbiaRegional Airport (w I .weather.gov/data/obhistory/KCOU.html).2. Telephone access to an automated voice recording at (573) 499-1400 of the most recent hourlysurface observations recorded at the Columbia Regional Airport.3. If weather observations are not available from the station at the Columbia Regional Airport,weather information from another station with hourly meteorological data in the site climateregion would be used. The following Missouri stations would be used as listed in order ofincreasing distance from Columbia:a. Jefferson City Memorial Airport: wl1.weather.gov/data/obhistory/KJEF.htmlb. Kansas City International Airport: wl1.weather.gov/data/obhistory/KMCI.htmlc. Sedalia Memorial Airport: wl1.weather.gov/data/obhi story/KDMO.htmld. Spirit of St. Louis Airport: wl1.weather.gov/data/obhistory/KSUS.htmlDuring normal operations, data would be obtained by internet access to hourly surface weather observationsrecorded at the Columbia Regional Airport at w l.weather.gov/data/obhistory/KCOU.html.19.4.2.3 NoiseThis section provides an assessment of the noise impacts associated with RPF construction, operation,and decommissioning.19.4.2.3.1 Impacts of ConstructionSite preparation, grading, and facility construction activities would require the use of heavy equipmentsuch as graders, bulldozers, and concrete trucks. Noise generated from these types of equipment rangesfrom 75 to 89 dBA at approximately 15 m (50 ft) (FHWA, 2006). Most construction activities wouldoccur during weekday, daylight hours (8:00 a.m.-5:00 p.m., Monday-Friday); however, construction maycontinue during nights and weekends when necessary to maintain the construction schedule. A specialpermit is required per Section 16-265 of the Columbia Code of Ordinances (City of Columbia, 2013b), ifconstruction activities are conducted outside of the normal weekday, daylight hours.Onsite noise level exposure would be controlled through appropriate training, PPE, periodic health andsafety monitoring, and industry best practices. Practices such as maintenance of noise-limiting devices onvehicles and equipment, controlling access to high-noise areas, controlling duration of emissions, and/orshielding high noise sources near their origin limit the adverse effects of noise on workers. Nonroutineactivities with potential adverse impacts on noise levels are limited and use best industry practices thatfurther limit adverse effects.The closest receptor is located 152 m (500 ft) from the proposed RPF, as shown in Figure 19-4 1.Increased noise levels resulting from construction activities would be short-term, lasting the duration ofconstruction of the facility, and would not result in long-term impacts to ambient noise levels. Inaddition, the natural attenuation of the noise over distance would reduce the effect of construction noise.The impact of noise from construction of the new site on nearby residences, churches, and recreationalareas is small.19-1 93 Chapte NWMI-o13-o2, Rev. OA:l:Chater19.0 -Environmental ReviewTraffic associated with the construction workforce commuting to and from the facility site also generatesnoise. As previously discussed, the baseline noise conditions for traffic include airports, railways, andhighways. The increase in noise relative to baseline conditions is most noticeable during periods of high-activity onsite and during shift changes in the morning and late afternoon. In addition, potential indirectimpacts may be anticipated to off-site areas associated with the roadway network and adjacent landsbeyond the site boundary. Noise-related impacts may result from an increased traffic volume andresultant increases in traffic-generated noise. The potential noise impact to nearby receptors due toconstruction-related traffic is small.1 9.4.2 .3 .2 Impacts of OperationLong-term noise sources resulting from operation of the proposed RPF would include process equipment,ventilation, heating and cooling systems, and increased traffic. These noise sources are similar to existingnoise sources near the proposed facility location. Ambient background noise sources in the area currentlyinclude vehicular traffic along highways and commercial building heating, cooling, electrical, andventilation systems. In addition, intermediate operation of agricultural equipment is present in the area.Process equipment would be housed inside the facility, such that the noise contribution to theenvironment would be minimal. The major source of process noise from the facility is anticipated to bethe HVAC systems associated with process and routine operations. Many of these systems are alreadypresent at other facilities within the immediate area (e.g., ABC Laboratories, RADIL). Impacts fromoperation of the systems associated with the RPF are not anticipated to increase the baseline noise levels forany process activity at the RPF. Therefore, potential noise impacts to the community from process noise,including HVAC systems, at the RPF are small.Commercial vehicle traffic would include regular shipments of laboratory supplies, waste, irradiatedtargets, newly fabricated targets, and 99Mo product. Shipments would occur at regular intervals. Supplyshipments would be expected to be weekly or bi-weekly. Transport shipments of irradiated targets areexpected to occur two times per week. Transport of the 99Mo product is also expected to occur two timesper week. Occupational vehicle traffic would include the daily commute of on-site workers, residentworkers, residents, and students. In many cases, this occupational traffic is not expected to significantlyimpact existing traffic patterns. Noise generated from occupational traffic is expected to occur duringnormal weekday, daylight operational hours (8:00-5:00, Monday-Friday).To meet schedule demands, the transport of product, targets, and waste could occur during times otherthan normal operational hours. Noise from truck transports would include engine noise, air brake noise,backup warning beepers, tire noise, and air horn.Potential indirect impacts to off-site areas are associated with the roadway network and adjacent landsbeyond the site boundary. Noise-related impacts may result from an increased traffic volume andresultant increases in traffic-generated noise as discussed in this section. Noise levels during operationsin these off-site areas would not be notable, as these areas are currently located within a roadway network(e.g., highway, agriculture) that is characterized by traffic volumes that exhibit traffic/vehicle noise. Theintermittent increase in traffic volume associated with normal work conditions, intermediate deliveries,and the natural noise attenuation over distance results in noise levels to receptors at baseline levels.Therefore, noise impacts resulting from normal operations are small.19.4.2.3.3 Inpacts of DecommissioningDecommissioning is the removal of a nuclear facility from service and reduction of residual radioactivityto a level that permits release of the property for unrestricted use and termination of the license. Duringthe decommissioning phase activities, equipment usage and the noise associated with their operation areexpected to be similar or less than that of the construction phase. As such, noise impacts during thedecommissioning phase of the RPF are considered small.19-1 94 NW M I NWM,-2013-021, Rev. 0MEICl IOOPSChapter 19.0 -Environmental Review19.4.3 Geologic EnvironmentThis section provides a description of the impacts to geology and soils that can be expected from theproposed RPF construction, operation, and decommissioning. A complete description of the geology andsoils at the proposed site is provided in Section 19.3.3. Brief descriptions of the geology and soilsprovide context for the impacts discussion.19.4.3.1 Soils and BedrockThe proposed RPF would be located on flat terrain, requiring some cut and fill to bring the ground surfaceto the final grade. The excavation of a detention basin would also produce fill material. The maximumdepth of excavation is anticipated to be 4.7 m (15.5 ft). About 6,881 m3 (9,000 cubic yards [yd3]) isestimated to be excavated for the building footprint (EDF-3124-0001, Estimate of Excavation for theNWMI Radioisotope Production Facilit,). The material excavated would be soil; no blasting isanticipated. The volume of material resulting from excavation of the site would be used as fill for thelower areas of the site, with no additional fill required. No contaminated soils are expected to beencountered during construction.Minimal excess excavated material is anticipated. Any excess would be stockpiled by Discovery Ridgefor any future construction and landscaping activities within the park area. Because of the agriculturalhistory of the site, the resulting terrain change for the site from gently sloping to flat topography as aresult of construction of the facility is expected to cause a small environmental impact to the site geologyor soils.Lot 15 is underlain by competent limestone bedrock that would not be expected to subside due toconstruction of buildings and related infrastructure. The possible exception to this generalization is thepotential for the occurrence of sink holes. The subsurface could be subject to collapse due to increasedloads resulting from facility construction. However, there was no evidence of subsidence or sinkholeswithin the Discovery Ridge project area during geotechnical investigation (Terracon, 2011 a). Based onthese observations, the likelihood of subsurface sinkholes within the facility footprint is expected to besmall but should be considered during detailed subsurface investigations associated with facilityconstruction.19.4.3.1.1 Impacts of ConstructionShort-term increases in soil erosion and dust generation in the areas within and adjacent to the proposedRPF footprint and roads may occur during construction due to earth-moving activities, clearing ofvegetation, and compaction of soils. However, dust production and erosional impacts due to site clearingand grading would be mitigated by using construction and erosion control BMPs. Disturbed soils wouldbe stabilized as part of construction work. Earthen berms, dikes, and sediment fences would be used asnecessary during all phases of construction to limit runoff. These measures would prevent the localsurface drainages from being affected substantially by construction activities. Much of the excavatedareas would be covered by structures or paved, limiting the creation of new dust sources. At a minimum(when needed), twice-daily watering would be used to control potentially fugitive construction dust inaddition to other fugitive dust prevention and control BMPs, as discussed in Section 19.4.2.2.4. Becausesite preparation and construction result in only short-term effects to the geology and soils, the impactswould be small.19.4.3.1.2 Impacts of OperationThe proposed RPF operation phase would not involve additional disruption of the local soil or bedrockand, therefore, is expected to have no impact on the site geology beyond that caused by excavationactivities during construction. Thus, the impact to geology and soils due to operation would be small.19-1 95 NWM 'elvii.:.. ......... Chpe 9.0 -Environmental ReviewDuring operation of the proposed facility, BMPs would also be used to manage stormwater runoff frompaved and compacted surfaces to drainage ditches and basins. Process wastewater would be containedwithin enclosed systems, treated, and evaporated. Process waste water would not be disposed to thesubsurface bedrock or local soils. These various measures would minimize impacts to geology and soilsfrom the proposed facility. As such, the impacts associated with RPF operation are small.19.4.3.1.3 Impacts of DecommissioningFollowing the cessation of operations, the facility would be decommissioned. Decommissioningactivities, however, are similar to construction activities and involve heavy equipment to dismantlebuildings and remove roadway and parking facilities. Direct and indirect impacts from decommissioningare anticipated to be similar to the impacts associated with construction and are considered small.19.4.3.2 Large-Scale Geologic HazardsLarge-scale hazards include earthquakes, volcanic activity, landslides, subsidence, and erosionalprocesses. As noted in Section 19.3.3, the USGS projected hazards for Boone County if an earthquakeoccurs along the NMSZ in the 50 years after 2002 include (USGS, 2003):* 25-40 percent chance of a magnitude 6.0 and greater earthquake* 7-10 percent chance of a magnitude 7.5-8.0 earthquakeAccording to the USGS, Boone County is one of the 47 counties in Missouri that would be severelyimpacted by a 7.6 magnitude earthquake with an epicenter on or near the NMSZ (USGS, 2003).According to the Boone Count. Hazard Mitigation Plan for 2010 (MMRPC, 2010), the Missouri StateEmergency Management Agency has made projections of the highest earthquake intensities that would beexperienced throughout Missouri if various magnitude earthquakes occur along the NMSZ(Figure 19-33), as measured by the MMI scale.Geologic features that are associated with landslide, subsidence, and errosional processes are discussed inSection 19.3.3. The occurrence of landslides is low because the topography of the site is relatively level.Previous investigations at the site (Terracon, 201 lb) did not identify any evidence of shallow bedrock,karst features, and/or extensive previous deposits of water-bearing sand associated with sinkholes. Theinvestigation did not find any evidence of subsidence or sinkholes.19.4.4 Water Resources19.4.4.1 Surface WaterWater resources at the proposed RPF site are discussed in Section 19.3.4. The nearest water body is created bythe MU R1 Dam, located approximately 152 m (500 ft) northwest of the site. This dam is not on a regulatedwater body. The second nearest water body is a farm pond approximately 305 m ( 1,000 ft) to the northeastof the site. Gans Creek, which is located approximately 0.8 km (0.5 mi) south of the site, drains the siteand Discovery Ridge. Perry Phillips Lake is located approximately 1.2 km (0.75 mi) west of the RPF site.19.4.4.1.1 Impacts of ConstructionFederal, State, and local regulations and permit procedures provide minimum requirements forstormwater management during construction activities to prohibit adverse impacts on surface water orstormwater. Some dewatering due to groundwater and precipitation may be required during constructionat the deepest excavation. Any water would be collected in a detention/retention pond. Disturbed soilswould be stabilized as part of construction work. Earthen berms, dikes, and sediment fences would beused as necessary during all phases of construction to limit runoff. These measures would prevent thelocal surface drainages from being affected substantially by construction activities. Impacts associatedwith construction of the proposed RPF on the surface water are small.19-1 96 NORWJEMEIAIOPSChpe NWM,-2013-021, Rev. OAIIVYChapter19.0 -Environmental Review19.4.4.1.2 Impacts of OperationAs described in Section 19.2.4, all water used at the proposed RPF would be obtained from theConsolidated Public Water Supply District #1 water supply system, and all sanitary wastewater would bedischarged directly to the Columbia sanitary sewer system. The facility would be designed to have zeroliquid discharge from the radiologically controlled area, and there would be no use or release water fromthe facility to the adjacent environment that would affect surface water. As such, direct and indirectimpacts to surface water from RPF operations are small.19.4.4.1.3 Impacts of DecommissioningFollowing the cessation of operations, the proposed RPF would be decommissioned. Decommissioningactivities, however, are similar to construction activities and involve heavy equipment to dismantlebuildings and remove roadway and parking facilities. Direct and indirect impacts from decommissioningare anticipated to be similar to the impacts associated with construction and, as such, are consideredsmall.19.4.4.2 GroundwaterThe groundwater aquifer beneath the proposed RPF site is the Mississippian aquifer (also referred to asthe Kimmswick-Potosi aquifer). The Mississippian aquifer is the principal aquifer supplying groundwaterto Boone County. In accordance with drillers' reports generated from 1987 to 2005, the estimated staticwater level in the area near the proposed site was approximately 198 m (650 ft) below ground surface.During previous investigations at Discovery Ridge, groundwater was observed at depths ranging fromapproximately 3.7-5.6 m (12-18.5 ft) below ground surface.19.4.4.2.1 Impacts of ConstructionSome dewatering due to groundwater may be required during construction at the deepest excavation. Noalterations to groundwater systems are expected during facility construction. Runoff controls would be inplace during construction as part of the BMPs to prevent uncontrolled releases of water. The potential forwater or other liquids from spills or leaks to cause significant migration of contaminants downward to thegroundwater system is considered unlikely. No groundwater withdrawals or returns are required duringconstruction. As such, direct and indirect impacts of construction of the proposed RPF on groundwaterare small.19.4.4.2.2 Impacts of OperationThe RPF would obtain its water supply from the Columbia municipal water system. Operations wouldnot require any groundwater. Consequently, direct and indirect impacts on groundwater duringoperations are small.1 9.4.4.2 .3 Inpacts of DecommissioningFollowing the cessation of operations, the facility would be decommissioned. Decommissioningactivities are similar to construction activities and involve heavy equipment to dismantle buildings andremove roadway and parking facilities. Direct and indirect impacts from decommissioning areanticipated to be similar to the impacts associated with construction and, as such, are considered small.19-1 97 NWM ilviChater19.0 -Environmental Review19.4.4.3 MonitoringThe proposed RPF is eligible for a Missouri General Operating Permit MO-R10A000. The permit doesnot include any stormwater monitoring requirements. Because of the absence of direct impacts to surfacewater and groundwater, the low potential for indirect impacts, and the use of management measures andcontrols to prevent releases to surface water or groundwater, no surface water or nonradiologicalgroundwater monitoring activities are planned for the site.19.4.5 Ecological ResourcesThis section assesses the impacts of construction, operation, and decommissioning on ecologicalresources, as described in Section 19.3.5, for the proposed RPF site and analysis area. Impacts includeeffects from activities associated with construction, operation, and decommissioning, includingexcavation, grading, placement of fill material, temporary staging and construction laydown, constructionof permanent features (or deconstruction in decommissioning), and potential operational disturbances.19.4.5.1 Impacts of ConstructionAs discussed in Section 19.3.5.3, the proposed site and the ROI are mostly urban development or used foragriculture or pasture. The proposed RPF site is located in an area that has been used historically forcropland and pasture. There are no designated critical habitats for Federal- or State-listed species withinthe ROI (Section 19.3.5.9). Furthermore, Federal- or State-listed species are not likely to occur near theproposed site because of the lack of available resources. There are no aquatic environments located onthe proposed site. Flora within the proposed site consists of common grasses and forbs typically found incropland and pasture. Potential fauna within the proposed site would mostly consist of transient speciesbecause of the lack of available resources.Direct and indirect impacts from construction of the facility would potentially consist of temporarydisplacement of fauna species from the area, bird collisions with construction equipment, and stormwaterrunoff. Construction noise would most likely cause temporary displacement of fauna species and wouldprimarily occur during construction hours. After construction hours, elevated noise levels would ceaseand displaced fauna species would potentially return to the area.Bird collisions with the proposed facility are unlikely because of the low profile of the building and thelow occurrence of bird strikes with buildings. Based on the findings of NUREG-1437, GenericEnvironmental Impact Statement for License Renewal of Nuclear Plants, bird collisions with buildingsoccur at very low frequencies. Bird strikes with construction equipment (e.g., cranes) are rare, but aremost likely to occur during nighttime construction due to the use of artificial lights. To mitigate anypotential strikes, BMPs for artificial lights are used (e.g., artificial lights are directed toward constructionactivities and shielded). Potential impacts from stormwater runoff are limited because there are noaquatic environments located on the site. Potential impacts to aquatic environments offsite would bemitigated because of the stormwater retention systems already in place and the use of BMPs inaccordance with the site-specific construction SWPPP, which prevents runoff and subsequent siltationfrom reaching any of the surrounding streams.Potential impacts to ecological resources, either permanent or temporary, from construction of the facilityare considered small due to:* Historical and current use of the proposed site, which limits available resources for fauna species* Commonality and distribution of the current flora located on the site* Lack of an aquatic environment on the siteMitigations for bird collisions and stormwater runoff would limit any potential impact.19-1 98 N MEIL ISOOE hpe NWI212,Rev. OEUVYChapter 9.0 -Environmental Review19.4.5.2 Impacts of OperationDirect and indirect impacts from operation of the proposed RPF would potentially consist of the exposureof flora and fauna to herbicides used for vegetation management, bird collisions with the facility, andstormwater runoff. Potential impacts from herbicides used for vegetation management would bemitigated with BMP requirements that would limit their use and contain the broad application throughoutthe site. Bird collisions with the proposed facility are unlikely because of the low profile of the building,available windows on the building, and the low occurrence of bird strikes with buildings. Based on thefindings of NUREG-1437, bird collisions with buildings occur at very low frequencies. Potential impactsfrom stormwater runoff would be limited because there are no aquatic environments located on the site.Potential impacts to aquatic environments offsite would be mitigated because of stormwater retentionsystems on the site.Potential impacts, either permanent or temporary, from operation of the RPF are considered small becauseof the historical and current use of the proposed site, which limits the available resources for faunaspecies, the commonality and distribution of the current flora located on the site, the ability for faunaspecies to habituate to their surroundings, and the lack of an aquatic environment on the site. Mitigationsfor bird collisions and stormwater runoff would limit any potential impact.19.4.5.3 Impacts of DecommissioningPotential direct and indirect impacts to ecological resources from decommissioning of the proposed RPFwould be similar to those from construction. As such, potential impacts to ecological resources, eitherpermanent or temporary, from decommissioning of the facility are considered small because of thehistorical and current use of the proposed site, which limits the available resources for fauna species, thecommonality and distribution of the current flora located on the site, and the lack of an aquaticenvironment on the site. Mitigations for bird collisions and stormwater runoff would limit respectivepotential impacts.19.4.5.4 MonitoringAs described in Section 19.3.5, the proposed RPF site has been used for agriculture for the past severaldecades and is routinely disturbed by the discing, plowing, herbicide application, and harvesting activitiesassociated with row crop production. Ecological resources at the site are limited by the lack of surfacewater and the historical agricultural practices on the site. Because the baseline conditions consist ofagricultural land lacking native terrestrial or aquatic habitat, post-construction ecological monitoring andmaintenance plans are not deemed necessary.19.4.6 Historical and Cultural ResourcesAs described in Section 19.3.6.3, no on-site historic properties are associated with the proposed RPFproject area. No archaeological sites or evidence of cultural resources were identified within the surveyarea. The Missouri SHPO has reviewed the findings of the Phase I archaeological survey and indicatedthat no further consultation with the SHPO regarding the proposed RPF is required (DNR, 2013).As discussed in Section 19.3.6.8, NWMI initiated consultation with six Federally recognized tribesregarding the proposed development. No responses have been received. The nearest listed NRHPproperty is the Maplewood House located approximately 1.6 km (1 mi) to the northwest of the proposedRPF site. No direct impacts would occur to this property from construction, operational, ordecommissioning activities. Therefore, potential impacts to historic and archaeological resources aresmall. However, if potential cultural or historical resources are identified during construction, the SHPOwill be immediately notified.19-1 99 NWMI Catr1 WM-130,Rev. OlviChptr 9.0 -Environmental Review..ORTJIWEST MEDICAL ISOTOPES19.4.7 SocioeconomicsThis section assesses the impacts of construction, operation, and decommissioning of the proposed RPFon the socioeconomic environment, including transportation system impacts. The evaluation of potentialsocioeconomic impacts addresses potential changes in the regional population, economy, housingavailability, and public services. The evaluation of transportation system impacts addresses routes andmodes that would be involved with transporting materials, workers, and equipment to the proposed RPFsite.Operation of the RPF from 2017 through 2047 would lead to a permanent increase in employment,income, and population in the area. Facility employment during operation would include up to98 workers. If all 98 operational workers traveled or moved to Boone County from outside the area, thiswould only represent a 0.11 percent increase in the total employed labor force of 92,742 (USDOL, 2014)in Boone County. A significant number of the operational jobs are likely to be filled by local residents.Some of the in-migrating construction workers would likely stay to become part of the operationalworkforce of the RPF.The annual RPF operating payroll is estimated to be approximately $8. 122 million for a workforce of 98,or an average of $82,878 per worker per year (in constant 2013 dollars). This average salary isapproximately 176 percent more than the 2010 Boone County $47,123 median household income (USCB,2010b).19.4.7.1 PopulationThe Boone County population is 162,642 (USCB, 2010a). Growth projections show that the populationis estimated to increase an average of 20.3 percent over the next 20 years (Table 19-46). Analysis of thepopulation changes considers impacts that would result from RPF construction, operation, anddecommissioning.19.4. 7.1.1 Impacts of ConstructionAs shown in Table 19-65, for major labor categories, a large construction trade workforce is available inBoone County. A large number of workers are not anticipated to relocate to Boone County to supportconstruction. The labor force within the ROI for the construction trades is demonstrated to be abundantrelative to construction workforce requirements. Approximately 80 percent (66) of the requiredconstruction workforce for these trades are estimated to come from within the ROI. The remaining 16 (oftotal 82 needed) are anticipated to temporarily relocate to the ROI. Using the ROI average of 2.4 personsper household, the total population increase in the various communities within the ROI due to theconstruction workforce requirements would be 38 people. This estimated population increase constitutes0.02 percent of the 2013 population of the ROI. Therefore, the impact of construction of the RPF onpopulation is small.19-200

..,t-..I IllvI ChapterV 1 NWM,-2013-021, Rev. 0A.,:-.. ES :., EDIC .... ChSOterES 9.0 -Environmental ReviewTable 19-65. Workforce Required for ConstructionCarpenters 750 5 745Electricians 170 8 162Construction equipment operators 370 12 358Sheetmetal workers 50 6 44B LS, 2012, "May 2012 Metropolitan and Nonmetropolitan Area Occupational Employment and WageEstimates," www.bls.gov/oes/current/oessrcma.htm, U.S. Bureau of Labor Statistics, Washington, D.C., accessedSeptember 2013.19.4.7.1.2 Impacts of OperationTable 19-66 shows that the 89 (non-management) permanent operations workers needed are available inthe ROI. About 40 percent (36) of the operations workers and their families are assumed to relocate toreside in the ROI. Using the ROI average of 2.4 persons per household, the total population increase inthe various communities within the ROI due to operational workforce requirements is 86 people. Thisestimated population increase constitutes 0.05 percent of the projected 2015 population of the ROI.Therefore, the impact of operating the RPF on population is small.Table 19-66. Workforce Required for OperationsbTechnical support 1,140 30 1,110Production worker support 280 16 264aBLS, 2012, "May 2012 Metropolitan and Nonmetropolitan Area Occupational Employment and WageEstimates," www.bls.gov/oes/current/oessrcma.htm, U.S. Bureau of Labor Statistics, Washington, D.C., accessedSeptember 2013.b Includes all architecture and engineering occupations.19.4.7.1.3 Impacts of DecommissioningAn estimated 81 workers would be required for decommissioning. The workers needed are assumed to besimilar to workers employed during construction, with the addition of approximately 15 radiationtechnologists. About 60 percent (49) of the 81 workers are assumed to come from the ROI, and theremainder of the workers (32) and their families would relocate to Boone County during thedecommissioning period. Based on the ROI average of 2.4 persons per household, the ROI populationwould increase by 77 due to the decommissioning workforce. This estimated population increaseconstitutes 0.03 percent of the projected population of the various communities within the ROI at the endof the 30-year license period. Therefore, the impact of decommissioning the RPF on population is small.19-201 NW MOPE Chpei NWMI-2013-021, Rev. 0AlviChptr 9.0 -Environmental Review19.4.7.2 HousingSection 19.3.7.1.5 provides a summary of the 2010 Census data concerning availability of housing in theROI. This data is used as a basis for estimating the number of housing units that may be available toaccommodate housing demands resulting from construction, operation, and decommissioning of the RPF.In 2010, there were 69,551 housing units, of which 64,077 are occupied and 5,474 are not occupiedwithin the county.19.4.7.2.1 Impacts of ConstructionAs discussed in Section 19.4.7.1.1, a total of 16 workers would be anticipated to move into the areaduring the construction period, requiring an equal number of housing units. The available number ofhousing units is 5,474. Potential impacts on housing are small due to the large number of availablevacant housing units in the ROI and the relatively small requirements for construction.19.4.7.2.2 Impacts of OperationAs discussed in Section 19.4.7.1.2, a total of 36 workers would be anticipated to move into the areaduring operation of the NWMI facility and would require an equal number of housing units. Theavailable number of housing units is 5,474. Potential impacts on housing are small due to the largenumber of available vacant housing units in the ROI and the relatively small requirements for operations.19.4.7.2.3 Impacts of DecommissioningAs discussed in Section 19.4.7.1.3, a total of 32 workers are anticipated to move into the area duringdecommissioning of the NWMI facility and would require an equal number of housing units. Theavailable number of housing units is 5,474. The percentage of available housing units is anticipated toremain constant over the life of the RPF license. Potential impacts on housing are small due to the largenumber of available vacant housing units in the ROI and the relatively small requirements fordecommissioning.19.4.7.3 Public ServicesPublic services impacts as a result of construction, operation, and decommissioning of the proposed RPFinclude the requirements for water, sanitary sewer, and power.Water -Water at the facility site would be used for dust control and compaction, and to support theneeds of the construction workforce. During construction and operations, Consolidated Public WaterSupply District #1 would provide water to the site. Construction needs are estimated to not exceed anaverage of 7,571 L/day (2,000 gal/day).The average per capita water usage in the U.S. is 340.7 L/day (90 gal/day) per person, including personaluse, bathing, laundry, and other household uses (USGS, 2013d). Assuming half of that level of usage isonsite, the 92 workers would use 15,672 L/day (4,140 gal/day). Including construction needs, thisamounts to a total water usage of 23,242 L/day (6,140 gal/day).As noted in Section 19.3.7.1.9.2, the Consolidated Public Water Supply District #1 presently supplies5.49 ML/day ( 1.45 MgaL/day). Construction requirements of the RPF are small compared to the availablewater supply, and operations requirements are similarly small. As noted in Section 19.2.4, the RPF wouldrequire 4,885 L/day (1,286 gal/day) during operations. This is a small impact compared to the total wateravailable. Decommissioning requirements are anticipated to be similar to construction.19-202 ChaperI1NWM,-2013-021, Rev. 0AIIJVChapter 9.0 -Environmental Review* =... ' NORTWWEST MEOICAL ISOTOPESSanitary Sewer -The facility would be connected to the Columbia sanitary sewer system. Sanitarysewer service is provided to the lot line for each of the Discovery Ridge tenants and has been sized tosupport the industrial park with tenants similar to the RPF. The sanitary sewer requirements forconstruction and operation of the facility would not exceed those presently provided for the research park.Power -The RPF is estimated to require approximately 1,150 kilowatts (kW) of power during operation,or approximately 10 megawatt (MW) hours annually. This is a small impact compared to the total power(1,188,483 MW hours) distributed by Columbia in 2013 (City of Columbia, 2014).19.4.7.4 Public EducationSchools and student populations are discussed in Section 19.3.7.2. The criteria used to determine impactsto public education as a result of construction, operation, and decommissioning of the RPF are based onprojected changes in both student enrollment and the number of teaching staff and classrooms.19.4.7.4.1 Inpacts of ConstructionColumbia Public Schools has a student enrollment of 17,722. Construction of the RPF is estimated toresult in an increased population of 38. Based on the U.S. Census data (USCB, 2010a), 14.9 percent ofthe population in Boone County is school age (5 to 18 years). The estimated impact to the school systemwould be six new students during the construction phase, an increase of 0.03 percent. Columbia PublicSchools are presently planning for an annual increase of 2 percent (CPS, 2006). Impacts from the RPFconstruction on public schools are a small fraction of the presently planned increase and, as such, aresmall.19.4.7.4.2 Impacts of OperationOperation of the proposed RPF is estimated to result in an increased population of 86. Based on theU.S. Census data (USCB, 2010a), 14.9 percent of the population in Boone County is school age (5 to18 years). The estimated impact to the school system would be 13 new students during the operationphase, an increase of 0.07 percent. Columbia Public Schools are presently planning for an annualincrease of 2 percent (CPS, 2006). The impacts from operations on public schools are a small fraction ofthe presently planned increase and, as such, are small.19.4.7.4.3 Impacts of DecommissioningFollowing the cessation of proposed RPF operations, the facility would be decommissioned.Decommissioning activities are considered similar to those of construction, with an estimated increase of32 workers into the ROI. Direct and indirect impacts from decommissioning are anticipated to be similarto the impacts associated with construction and, as such, are small.19.4.7.5 Tax RevenuesTax revenues associated with proposed RPF construction, operation, and decommissioning would includepayroll taxes on wages and salaries of the construction and operations workforces; sales and use taxes onpurchases made by NWMI and construction, operations, and decommissioning personnel; and propertytaxes on owned real property and improvements. Increased tax collections would benefit Missouri,Boone County, city of Columbia, and Columbia Public Schools.Workforce payroll taxes (Federal and State) would be generated by construction, operations, anddecommissioning activities and purchases, and the taxes generated by workforce expenditures. State taxpayments would be distributed throughout the ROI and extend beyond the ROI, based on the expectationthat some construction, operations, and decommissioning employees would reside outside of BooneCounty. Table 19-67 provides an estimate of the annual tax payments (EDF-3 124-0007, Tax Revenuefrom the Construction, Operation, and Decommissioning of the Northwest Medical Isotope Facility).19-203 NW MINWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-67. Estimated Annual Tax Payments0 02015201720192021202320252027202920312033203520372039204120432045Total$200,709$465,296$465,296$465296$465,296$465,296$465,296$465,296$465,296$465,296

$465,296$465,296$465,296$465,296$465,296$465,296$14.095,718$485,574$1,2f$936$1,213,936$1,23,3$1,2 13,936$1,213,936$! 2~3936$1,213,936$I,12j,3$1,213,936$1,213936$1,213,936

$1,213,936$1,213,936?$1,1,3$1,213,936$1,213,936$1,213,936$1,213,936$1,213,936$1,213,936$37..308.300$217,017$821,053$832,053$832,03$832,053$832,053$832,053$832.053$832,053$832,053$832,053$832,053$832,053$832,053$832,053$832,053$24.729.973$903,300$1,366$2,511,285$2,51,28$2,5 11,285$2,511,285$2,511,285$2,511,285

$2,511,285$2,511,285$2,511,285$2,5 11,285$2,511,285$2,511,285$2,511,285$2,511,285$76,133.991Source: EDF-3 124-0007, 2014, Tax Revenue From the Construction, Operation, and Decommissioning of theNorthwest Medical Isotope Facility, Rev. 1, Portage, Inc., Idaho Falls, Idaho, November 1, 2014.19.4.7.6 TransportationImpacts on the local transportation infrastructure as a result of proposed RPF construction, operations,and decommissioning are measured against the existing traffic conditions and the assumption that no newinfrastructure would be developed. Materials for construction, operations, and decommissioning wouldbe transported to and from the facility using the existing roadway networks.19-204 Chapter NWM,-2013-021, Rev. 0A: : VChapter19.0 -Environmental Review19.4. 7.6.1 Impacts of ConstructionThe majority of traffic related to the construction phase would travel to and from the site onU.S. Highway 63. Peak construction traffic volume is estimated to be 30 heavy vehicles (dump truck anddeliveries) and 82 vehicles (pickup trucks and cars) traveling to and from the site daily in 2015. Exceptduring the peak construction period, the worksite traffic volume is expected to be less and represents anestimated 0.5 percent increase over the existing traffic levels. As such, the impact on transportation dueto construction is considered small.19.4.7.6.2 Impacts of OperationTraffic volume during facility operation is estimated to be one heavy vehicle and 98 vehicles (pickuptrucks and cars) traveling to and from the site daily during operations. This estimate does not take intoaccount potential carpooling and alternative transportation that some employees may use. The majorityof this traffic would likely travel to the worksite on U.S. Highway 63 and represents an estimated0.5 percent increase over the existing traffic levels. As such, the impact on transportation due tooperations is considered small.19.4.7.6.3 Impacts of DecommissioningFollowing cessation of operations, the facility would be decommissioned. Decommissioning activitiesare considered similar to those of construction, with an estimated 30 heavy vehicles (waste trucks) and81 vehicles (pickup trucks and cars) traveling to and from the site daily. This estimate represents a0.5 percent increase over the existing traffic levels. As such, the impact on transportation due todecommissioning is considered small.19.4.8 Human HealthThis section describes public and occupational health impacts from both nonradiological and radiologicalsources. Regulations for generating, managing, handling, storing, treating, protecting, and disposing ofhazardous materials during construction, operation, and decommissioning are contained in Federalregulations. These regulations include compliance with provisions of the Clean Air Act, CWA, AtomicEnergy Act, and RCRA, among others.19.4.8.1 Nonradiological ImpactsThe following sections discuss the potential nonradiological public and occupational hazards and impactsfor proposed RPF construction, operation, and decommissioning. Nonradiological hazards/impacts areassociated with emissions, discharges, and waste from processes within the facility and with accidentalspills/releases. Nonradioactive/hazardous materials encountered during construction, operation, anddecommissioning of the facility include chemicals, wastes (solid and liquid), discharges, and airemissions. These materials would be managed in accordance with applicable Federal, State, and locallaws and regulations, and applicable permit requirements.19.4.8.1.1 Nonradiological Impacts During ConstructionConstruction of the proposed RPF would include potential hazards to workers typical of any constructionsite. Slips, trips and falls, heavy lifting, moving machinery, excessive noise, sharp objects, environmentalhazards, and other safety hazards would be encountered by workers while on the RPF site. Properprocedures, BMPs, and access control would be employed to promote worker safety and reduce thelikelihood of worker injury during construction.19-205 NW ICatr1NWMI Rev. OANOR:hChapteri19.0 -Environmental ReviewChemicals, hazardous liquids, and gases may also be encountered during construction. Compressedgases, oxidizers, flammable liquids, and gases are expected to be onsite during construction activities.Access controls, proper PPE and other typical construction practices would be used to ensure safe workconditions and reduce the likelihood of an accident or exposure to hazardous materials. In addition,construction equipment and tooling would be used in such a way to ensure compliance with OSHArequirements. In the event of a spill/accident during construction, the impact to human health and theenvironment would be mitigated by following an emergency response plan. The cumulative impacts tohuman health during construction are small.19.4.8.1.2 Nonradiological Impacts During OperationPotential nonradiological public and occupational hazards pertaining to operation of the proposed RPF areassociated with emissions, discharges, and waste associated with processes within the facility, and withaccidental spills/releases. Typical occupational hazards associated with work conducted in a processfacility would be expected. These hazards include lighting, noise, repetitive motion, awkward posture,sharp objects, and slips, trips, and falls.19.4.8.1.2.1 Chemical SourcesChemical processes would be conducted throughout the proposed RPF, including inside the hot cell area,outside the hot cell, and in the laboratory and waste management areas. The anticipated list of chemicals,locations, and estimated quantities is presented in Table 19-68. The Table 19-68 values are intended to bebounding for accident analysis. Laboratory chemicals and janitorial supplies are also listed forcompleteness. These values may be updated as the process is revised.19.4.8.1.2.2 Nonradiological Waste Management and Effluent Control SystemsChemicals would be recycled and reused to minimize waste when applicable. Any wastes created by RPFprocesses would be handled by waste management processes and procedures, including sorting andsegregating, volume reduction, containerization, and shipping to the appropriate off-site disposal orrecycle facility. Worker exposure to wastes outside of the hot cell could result from accidents/spillsduring receiving, movement, routine operations, or disposal. Exposure to chemicals during laboratoryprocesses can also occur. Waste management processes and procedures help to reduce the probability ofan exposure. If an accident or spill occurs, emergency response plans would mitigate the effects of theaccident or spill. Waste from the accident or spill would be managed according to the facility hazardouswaste management plan.19.4.8.1.2.3 Liquid Waste ManagementLiquid wastes produced at the proposed RPF as a result of routine activities or accidents/spills would besampled and treated as necessary. Wastes that do not meet the local municipal wastewater treatmentstandards would be containerized and disposed of following proper procedures to ensure worker safetyand compliance with applicable disposal requirements. Floor and sink drains would only be used forsanitary purposes. Where applicable, containerized liquid waste, sumps, and traps would be sampled andtreated (if possible) before release.19-206

"-°oN..'"IgWV lNWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-68. Chemical Inventory for the Radioisotope Production Facility0 -SS *

• S .55 .5-Nitric acid (HNO3)100,000 26,420 Chemical make-upTi.vr rnnm/lahnratorvLiquid10.4 M(90) Ammonium hydroxide(NWH'NH100L26.4 gal Chemical make-uprnnmLiquid15.7 M(62 wt%)Carbon dioxide200 kg441 lb Chemical make-uproom'lTGasNitrogen1,800 kg 4,000 lb Chemical make-uproom/laboratoryGasSodium hydroxide(NaOH)70,000 L/yr 18,490gal/yrChemical make-up Liquidroom19M(50 wt%)Sodium hypochlorite 1 L 0.26 gal Chemical make-up Liquid 2 M(NaOC1) roomDiethylbenzene 50 kg 110 lb Chemical make-up Liquidroom/l ahoratorySolvent 200 L 53 gal Chemical make-up Liquidroom/laboratoryUrea (Co(NH2)2)100 kg220 lb chemical make-uproomSolidGeneral laboratory Nominal Laboratory Solids!supplies liquids/gas;f i~i{ i{77DI i7 i{ ;7i / i{ 7 iii~ i]if i~i ;?,7 4] L sic]i4i19-207 NW iMI NWMI-2013-021, Rev. 0Alvii Chapter 19.0 -Environmental Review* .° NRWETMEOICAL ISOTOPES19.4.8.1.2.4 Solid Waste ManagementSolid wastes are expected to be generated during routine operation of the proposed RPF. This waste istypical for a production facility, including wood, metal, plastics, wires and piping, office supply waste,packaging waste, batteries, solidified oil/used solvents, and liquid waste.These wastes would be containerized and disposed of following proper waste management procedures,including a recycling and reuse plan and waste reduction practices. All hazardous waste would be handledin accordance with applicable regulations (e.g., RCRA, Missouri Hazardous Waste Management Law).19.4.8.1.2.5 Gaseous WastesThe proposed RPF would generate gaseous effluents resulting from process operations and the ventilationof operating areas. Gaseous effluent from ventilation of operating areas would include a cascadingpressure zone ventilation control system. This system would draw air from the cleanest areas of thefacility to the most contaminated. Standard offgas treatments would be performed using two-stage HEPAfiltration and activated carbon prior to the release stack(s). Stack sampling and monitoring would occurto establish compliance with NESHAP requirements and applicable State law. The cascading zones aredescribed in Section 19.2.3.2.12.19.4.8.1.2.6 Nonradiological Effluent ReleaseLiquid waste effluents meeting municipal treatment standards would be discharged to the municipalsewer. Liquid wastes that do not meet the municipal treatment standards would be containerized, volumereduced, neutralized, solidified, and shipped to an appropriate disposal facility.Nonradioactive solid wastes (e.g., office waste, recyclables) would be collected, temporarily stored, anddisposed of or recycled locally. Scrap metal, universal wastes (i.e., Federally designated universal wasteincludes batteries, pesticides, mercury-containing equipment, and bulbs [lamps]), used oil, and antifreezewould be collected, stored, and recycled or recovered at an off-site permitted recycling or recoveryfacility, as appropriate.All the gaseous effluents from the RPF would be filtered and vented to the atmosphere through one of thethree main stacks. These stacks would be equipped with air monitors/samplers to ensure compliance withapplicable regulations (e.g., NESHAP, Missouri Air Conservation Law). Impacts of gaseous effluents arediscussed in detail in Section 19.4.2.1.Effluent monitoring and sampling/control systems would be used to detected and mitigate the possiblereleases of air emissions outside the facility. Impacts from nonradiologicai air emissions during normaloperations are discussed in Section 19.4.2.1.2.Most chemicals would be stored in tanks and piping or in controlled access storage. Bulk chemicalquantities would be limited to a four-week supply. Table 19-68 lists the estimated chemical inventory atany given time for the RPF. The general public would not be allowed access to the RPF site. As a result,the public would not have direct contact with chemicals at the RPF. Therefore, potential air emissionseffects to the public are limited to indirect impacts.Quantitative analyses for nonradiological impacts as a result of credible accident scenarios are discussedin Chapter 13.Control systems would be used to mitigate risks and control exposure of the public to nonradiologicalconstituents during accidents. Spill prevention/mitigation procedures, air emission controls, liquideffluent sampling, and treatment and monitoring processes, along with emergency response plans, wouldbe in place as appropriate to ensure that the exposure to the public is in compliance with applicableregulations. Therefore, cumulative impacts from nonradiological sources to human health are small.19-208 NW M LU I~ NWI21-2,Rev. Q~: E1V V Chapter 19.0 -Environmental Review*.,.. .N TWETMEDICAL I$OTOPE$19.4.8.1.2.7 Physical Occupational HazardsExposure characteristics of the workforce for nonradiological hazards would be defined when theoperating strategies are finalized. No indirect impacts (offsite) are identified. General types ofoccupational physical hazards that may be present at the proposed RPF include lighting, noise, repetitivemotion, awkward posture, sharp objects, and slips, trips, and falls.Occupational physical hazards would be addressed and reduced or eliminated through implementation ofadministrative controls, safety practices, training, and control measures. In summary, occupationalhazards would be managed and minimized by compliance with OSHA regulations, and, therefore, impactsfrom physical occupational hazards are considered small.19.4.8.1.2.8 Nonradiological Exposure to the WorkforceThe majority of process chemicals used is in liquid form and would be contained in tanks and pipes.Most processes involving chemicals would occur in hot cells, limiting workforce exposure. The proposedRPF would be designed and practices would be applied to keep air contaminants below the limits in29 CFR 1910.1000, "Air Contaminants." The occupational hazards would be managed and minimized bycompliance with OSHA regulations. The impacts from chemical occupational hazards are small.19.4.8.1.3 Nonradiological Impacts during DecommissioningImpacts associated with decommissioning activities would be similar to impacts associated withconstruction (e.g., heavy equipment, noise, slips, trips, and falls). An additional hazard encounteredduring decommissioning may be exposure to a legacy chemical, caused by an unknown spill or leak. Insuch instances, these hazards would be addressed using work control practices to minimize impacts. Thecumulative impacts to human health during decommissioning are small.19.4.8.1.4 Nonradiological Environmental Monitoring ProgramApplicable regulations and attending administrative codes that prescribe monitoring requirements mayinclude those associated with emergency management, environmental health, drinking water, water andsewage, pollution discharge, air pollution, hazardous waste management, and remedial action. Samplingand monitoring programs would be established to ensure that requirements of the Federal CWA, theMissouri Clean Water Law (i.e., Missouri Revised Statutes, Chapter 640, "Department of NaturalResources," and Chapter 644. "Water Pollution"), and other local requirements are met.The RPF would generate gaseous effluents resulting from process operations, the ventilation of operatingareas, and boiler emissions from facility buildings. Sampling/monitoring procedures would beimplemented to ensure that the Federal Clean Air Act and the Missouri Air Conservation Law (MissouriRevised Statutes Chapter 643, "Air Conservation") requirements are met. Specific monitoringrequirements in support of required local air permits would be determined thrOugh the permitting process.19.4.8.1.5 Mitigation MeasuresMitigation measures, including workplace and environmental regulations, are used to ensure theprotection of human health. NWMI is committed to BMPs during construction, operation, anddecommissioning to minimize pollutant releases to on-site and off-site areas, guarantee delivery of allfacility wastewater to the local municipal wastewater treatment facility, and impose air emission controls,as appropriate. Required permits would be obtained for effluents and emissions. Waste reductionpractices, including recycling and waste minimization, are also employed.19-209 NW MI' NWI212,Rev.NORTHWE- T lvChapter 19.0 -Environmental Review-.,. NRWETMEOZOAL ISOTOPES19.4.8.2 Radiological ImpactsThe proposed RPF may release small quantities of radionuclides to the environment. Gaseous effluentactivity releases and liquid effluent activity releases would be managed to ensure compliance withapplicable Federal, State, and local requirements.19.4.8.2.1 Baseline Radiation LevelsBaseline radiation levels onsite and in the vicinity of the proposed RPF site are discussed inSection 19.4.8. There are no identified abnormal sources of radiation onsite or within the vicinity of thesite that would cause radiation levels to be any higher than the expected natural background radiationlevel.1 9.4.8.2 .2 Radiological Impacts During ConstructionThe majority of the proposed RPF construction activities would not include any sources of radiologicalexposure. The impacts to human health from radiological sources during construction are small. Prior toinitiating operation, radiological sources for analysis and LEU would be brought onsite to support initialstartup and component testing. During this period, the potential impacts would be similar to those duringoperation and are discussed in the following sections.19.4.8.2.3 Radiological Impacts During Operation19.4.8.2.3.1 Location of and Types of Radiological SourcesRadioactive material would be located in the RPF hot cell area, irradiated target receipt and unloadingarea, target fabrication area, and waste management areas. The radioactive liquid effluent and radioactivegas would be contained within process waste management systems and the offgas systems.19.4.8.2.3.2 Dose RatesDirect dose to a member of the public at the fence line would be due to gamma radiation penetrating thewalls of the production facility and the waste staging and shipping area. The facility and facility systemswould be designed to ensure that any dose at the fence line would be below applicable limits.19.4.8.2.3.3 Dose at the Site BoundaryAs a result of site shielding design, the direct dose outside of the buildings would be small and decreaseswith increasing distance. For this analysis, the site boundary is the facility fence line. The fence line islocated at an appreciable distance from the sources of radiation (production facility hot cell and the wastestaging area). Therefore, the dose would be negligible at the fence line, and the impacts to human healthare small.The proposed RPF would be designed such that the radiological impacts to any individual would bebelow applicable limits. Accident scenarios presented in Chapter 13 detail the initiating event, accidentevolution, and the final consequences. The impacts to human health and the environment as a result of anaccident involving radiological materials would be small.19.4.8.2.3.4 Annual Dose to the Maximally Exposed WorkerAdministrative dose limits are occupational radiation exposure limits that radiation workers at the RPFwould not exceed without prior management approval. Administrative controls would be used to ensurethat workers do not receive dose above the regulatory reference.19-2 10 Chater1,,M,,,,, 2, ev. O'-...:........... Chptr 9.0- Environmental Review19.4.8.2.3.5 Dose Rates from Transportation ActivitiesThe radiation dose to the public due to the transport of radioactive waste (considered an indirect effect) isdiscussed in Section 19.4.10. All shipments made to and from the proposed RPF would be in compliancewith applicable DOT regulations. As such, the dose limit for transport of radioactive material is200 milliroentgen/hr (mR/hr) on contact, and 10 mR/hr at 1 m. In addition to these requirements,individual cask and container requirements may dictate a smaller allowable dose. Impacts to the public asa result of transporting radioactive material to and from the RPF are small.The dose to the public and to the workforce resulting from transportation activities is discussed inSection 19.4.10. Under normal operating conditions, the greatest radiological impact to the workforce isanticipated to be during transportation activities. Transportation workers may receive a larger dose. Incompliance with DOT and NRC requirements, the transport of radioactive material would be conductedusing approved radiation control procedures that are based on ALARA principles. Therefore, thecumulative impacts resulting from transporting nuclear material from the addition of the RPF are small.19.4.8.2.3.6 Radiation Exposure Mitigation MeasuresOccupational and public exposures due to routine operations at the RPF would be ALARA. Thisexposure minimization goal would be met through both engineered and administrative controls.Engineered controls -The facility would employ the following engineered controls to minimizeradiation exposure to the public and workers:* Radiation source identification* Shielding around radiation sources* Ventilation control* Access control to radiation areas* Contamination control* Remote operation* Waste minimization* Administrative controlsAdministrative controls -To minimize radiation exposure to the public and workers, the facility wouldemploy administrative controls consisting of written procedures, policies, and employee training in thefollowing subject areas:* General environmental activities, including hazards associated with the facility* Waste minimization requirements and goals* Radiation safety, including workforce protection* ALARA principles* Specific environmental issues and responsible environmental stewardship* Continual improvement* Regulation compliance19.4.8.2.4 Characteristics of Radiological Sources and Effluents19.4.8.2.4.1 Gaseous Sources of Radioactive MaterialRadioactive gaseous effluents produced in the proposed RPF during normal operations would consist ofoffgas from hot cell processes (i.e., processing of irradiated targets, recovery of LEU from processingactivities, and recycling of recovered uranium for target fabrication). All gaseous effluents released fromthe RPF would be combined and released through three vent stacks. As stated in Section 19.4.2.1.2.3, alliodine fission products would be removed using absorption methods. Fission product gases such as Xe andKr would be removed using gas trapping to allow decay. The resulting release would be maintained untillevels are less than those defined in Table 2 in 10 CFR 20.19-211

" NW M Chapter 19.0 -Environmental Review-N °: MEOICAL iSOTOPES19.4.8.2.4.2 Liquid Sources of Radioactive MaterialLiquid waste generated during process operations would be recycled and reused, if practicable. Asdiscussed in Section 19.2.3.1.5, liquid waste would be treated in the aqueous waste handling system.Liquid waste would be treated and solidified into a solid waste form suitable for off-site disposal. Noradioactive liquid sources of radioactive material would be released to the environment as a result ofnormal operating conditions.19.4.8.2.4.3 Solidified Sources of Radioactive MaterialSolid radioactive waste would be located in either the hot cell/target fabrication area or the wastemanagement area.19.4.8.3 Radiological Impacts During DecommissioningThe potential impacts from radiological material associated with decommissioning activities are fromresidual contamination in the hot cell and process areas. Proper radiation protection measures would befollowed for all decontamination operations. During shutdown operations, most areas would bedecontaminated as part of cell cleanout. Piping and vessels would be decontaminated, rinsed, and sampledto ensure that the removal of radioactive material has been achieved. In the event that a vessel/areacannot be adequately decontaminated, a fixative would be applied to prevent the spread of contamination.When the remaining contamination has been immobilized, items would be sized and placed into theappropriate containers and disposed of following applicable regulations. In all activities, proper care,including ALARA practices, would be followed to limit exposure to workers or the public. Thecumulative impact to human health during decommissioning is small.19.4.8.4 Radiological Monitoring ProgramIn addition to the nonradiological monitoring program, the radiological monitoring program wouldinclude effluent monitoring and environmental monitoring.19.4.8.4.1 Radiological Effluent MonitoringThe NWMI Radiological Effluent Monitoring Program identifies and quantifies principal radionuclides ineffluents (Regulatory Position C. 1 of NRC Regulatory Guide 1.21, Measuring, Evaluating, and ReportingRadioactive Material in Liquid and Gaseous Effluents and Solid Waste [NRC, 2009a]). This programwould be used to verify that the RPF is performing as expected and within its design parameters so thatdoses to individual members of the public remain within the limits established in 10 CFR 20.1301 anddoses due to airborne emissions meet the ALARA requirement of 10 CFR 20.1 101(d) as required byRegulatory Guide 4.20, Constraint on Releases of Airborne Radioactive Materials to the Environment forLicensees other than Power Reactors (NRC, 2012b). All effluent pathways that could be a significantrelease pathway for radioactive material from the RPF include radiological effluent monitoring.19.4.8.4.2 Gaseous Monitoring19.4.8.4.2.1 Gaseous Effluent MonitoringAll gaseous effluents from the RPF would be released through three vent stacks (Zone I, Zone II/III, andthe laboratory). Each exhaust system would have a separate stack, with the exception of the processoffgas subsystem, which would merge with the Zone I exhaust stream of the HEPA filter train. Eachexhaust filter train would consist of pre-filters, two stages of HEPA filters, carbon absorbers, and isolationdampers. Exhaust ducts upstream of the filter trains would be round to minimize areas wherecontamination can accumulate and sized to minimize particulate settling in the duct. No monitoringwould occur for the HVAC and process steam boiler stacks.19-2 12 Chptr1MWI-0I-21 ev. OIUVVChapter 9.0 -Environmental ReviewMEDICAl. ISOTOPE SThe Zone I exhaust stack would service the hot cell, waste loading area, target fabrication enclosures, andprocess offgas system. HEPA filters would be included in both the inlet and outlet ducts. The outletHEPA filters would minimize the spread of contamination from the hot cell into the ductwork leading tothe exhaust filter train. The inlet HEPA filters would prevent contamination spread in the event of anupset condition. Zone II/III exhaust would service portions of the target fabrication systems, laboratory,uranium storage, truck bay, mechanical, supply rooms, corridor and airlocks, and general occupationalareas of the facility. The laboratory exhaust system would handle exhaust air from fume hoods andgloveboxes located in the laboratory area.The airborne effluent exhaust from the vent stacks is expected to contain measurable quantities of noblegas radioactivity (i.e., Xe and Kr). Radioactive iodine, radioactive particulates, and tritium could also bepresent in the airborne effluent exhaust. Due to the expectation of having measurable quantities ofradioactivity in the airborne effluent and since malfunction of the exhaust carbon filtration system couldresult in a change in iodine radioactivity releases, the combined exhaust in the vent stacks would becontinuously monitored for gross gamma radioactivity using an off-line gas monitor. Additionally, grabsampling provisions would be available for routine collection and analysis of gas, particulate, iodine, andtritium samples from the combined exhaust in the vent stacks, to (1) identify radionuclides, (2) identifyrelative concentrations of radionuclides in the airborne effluent, and (3) quantify radionuclide releases.19.4.8.4.2.2 Liquid Effluent. MonitoringThe proposed RPF is designed to have zero liquid discharge from the radiologically controlled area, andthere would be no release of water from the facility to the adjacent environment that would affect surfacewater. As such, there are no defined liquid effluent release pathways from the radiologically controlledarea and no requirement for radiation monitoring of liquid effluent pathways.19.4.8.4.3 Radiological Environmental MonitoringThe requirement to have a radiological environmental monitoring program is documented in10 CFR 20.1302, "Compliance with Dose Limits for Individual Members of the Public." Theradiological environmental monitoring program is used to verify (1) the effectiveness of plant measuresthat are used to control the release of radioactive material, and (2) that the measurable concentrations ofradioactive materials and levels of radiation are not higher than expected based on effluent measurementsand modeling of the environmental exposure pathways. Methods for establishing and conductingenvironmental monitoring are provided in Regulatory Guide 4.1, Radiological Environmental Monitoringfor Nuclear Power Plants (NRC, 2009b). Regulatory Guide 4.1 refers to NUREG-1301, Offsite DoseCalculation Manual Guidance: Standard Radiological Efflutent Controls for Pressurized Water Reactors,for detailed guidance on conducting effluent and environmental monitoring. Although RegulatoryGuide 4.1 (NRC, 2009b) and NUREG-1301 are written for nuclear power plants, due to the similaritiesbetween airborne releases of radioactivity from nuclear power plants and those released from the RPF,guidance provided in Regulatory Guide 4.1 and NUREG-1301 was considered when developingradiological environmental monitoring for the RPF. Specifically, guidance provided in Figure 1 ofRegulatory Guide 4.1 and Table 3.12-1 of NUREG-1301 was considered when determining whichexposure pathways to sample, sample locations, types of samples, and sample frequencies for the RPF.The following radiation exposure pathways are considered for monitoring under the NWMI radiologicalenvironmental monitoring program:* Waterborne exposure pathway* Direct radiation exposure pathway monitoring using TLDs* Airborne exposure pathway monitored using continuous air samples* Ingestion exposure pathway19-2 13 Chapter NWM,-2013-021, Rev. 0AlviChater19.0 -Environmental Review19.4.8.4.3.1 Waterborne Exposure Pathway MonitoringThe proposed RPF is designed to have zero liquid discharge from the radiologically controlled area, andthere would be no release of water from the facility to the adjacent environment that would affect surfacewater (e.g., Gans Creek). As such, surface water sampling is not included in the radiological monitoringplan. Similarly, aquatic life in the rivers is not expected to accumulate detectable levels of radioactivity,and sampling of fish or other aquatic creatures for the ingestion pathway is not included in theradiological environmental monitoring plan.The groundwater aquifer beneath the proposed RPF site is the Mississippian aquifer (also referred to asthe Kimnmswick-Potosi aquifer), which is discussed in detail in Section 19.3.4.2. There are no definedliquid effluent release pathways, and the groundwater is not expected to be contaminated due to operationof the RPF. Therefore, groundwater sampling is not included in the radiological environmentalmonitoring plan.19.4.8.4.3.2 Direct Exposure Pathway MonitoringTLDs provide measurements of the direct radiation from radioactive materials located at the RPF andfrom radioactivity in airborne effluent and deposition of airborne radioactivity onto the ground.NUREG-1301 recommends 40 TLD locations but can be reduced based on. geographical limitations. TheTLD locations would consist of an inner ring and outer ring of TLDs, with one TLD located in each ringat each of the 16 meteorological sectors (i.e., a total of 32 TLDs) and the remainder located at specialinterest areas. NUREG-1301 also provides for at least one TLD to be located a significant distance fromthe facility as a control station to measure background radiation dose.At the RPF, six TLDs would be located outside at entry points to the building where personnel maycongregate or spend time outside of the RPF building. An additional TLD would be located on theoutside wall near the target fabrication area of the building to evaluate direct radiation from the hot cellsand waste management area. The location of the on-site TLDs is shown in Figure 19-46.TLDs would also be located at the site boundary (the perimeter of the lot) to evaluate the direct radiationdose. Sixteen TLDs would be placed on the lot line, with a TLD placed at all four corners of Lot 15 andthe remaining TLDs placed at approximately equal distances from each other. The sixteen TLDs wouldprovide adequate coverage to ensure that direct doses to neighboring facilities on adjoining lots can bemonitored and evaluated. The location of the perimeter TLDs is shown in Figure 19-46.An additional TLD would serve as a control and would be located offsite at a significant distance from thefacility such that it represents a background dose. One TLD location would be provided with two TLDsso that data quality can be determined.19-2 14

.:;.Chapter:.NWMI-2013-021, Rev. 0A*lv...i......Chpe 19.0- Environmental ReviewDIS(OVURY RIDGE LOT ISFIIOfUITY LINEs PINEl WATER PUN SKID74L ACIrvES+ WASTE MANAOE~dwr BU A~NOPR--105.'14. SIDE SETEACK -I 5 FEETSPACE RP.EEIVIED lNFUB WATERFULTANK *J On-Ste TLDs* Fence Line TLDsJ! Pr~AKNG SPACESGU R II7 .......Nmu~r m~xGA..... (TcyPICL) SUTE PLANFigure 19-46. Location of On-site Environmental Thermoluminescent Dosimeters andContinuous Air Monitors19.4.8.4.3.3 Airborne Exposure Pathway MonitoringAirborne effluent releases from the RPF contribute to off-site doses. The airborne effluent exhaust fromthe vent stacks is expected to contain measurable quantities of noble gas radioactivity (e.g., Xe and Kr).Radioactive iodine, radioactive particulates, and tritium could also be present in the airborne effluentexhaust. However, most of the off-site exposure due to airborne effluent releases is associated with noblegas and radioactive iodine releases.Environmental airborne sampling is performed to identify and quantify particulates and radioactive iodinein airborne effluents. Regulatory Position C.3.b of Regulatory Guide 4.1 (NRC, 2009b) indicates thatairborne sampling should always be included in the environmental monitoring programs for nuclearpower plants. Since the RPF includes airborne effluent releases, and radioactivity in the airborne effluentcan result in measurable off-site doses, the radiological environmental monitoring program includesairborne sampling.The guidance provided in Table 3.12-1 of NUREG-1301 is used to establish locations for airborne sampleacquisition, sampling frequency, and type of sample analysis. Continuous air sample locations are specifiedin accordance with the guidance provided in Table 3.12-1 of NUREG- 1301. The continuous air monitors(CAM) that are used to obtain continuous air samples include a radioiodine canister for weekly 1311analysis, and a particulate sampler that is analyzed for gross beta activity and for quarterly isotopic analysis.19-215 NW: haper 9.0 -Environmental ReviewFour CAM locations would be located near the facility fence line, with one CAM being located in thedirection of the prevailing wind (e.g., north-northwest) and the other three CAMs being located in theremaining cardinal directions (e.g., 90 degrees) from the first CAM location (i.e., west-southwest, south-southeast, and east-northeast). The CAM locations are shown in Figure 19-46.An additional CAM would be located a sufficient distance from the RPF, in the least prevalent winddirection, to provide background information for airbomne activity.19.4.8.4.3.4 Ingestion Exposure Pathway MonitoringNUREG-1301 suggests sampling of various biological media (biota monitoring) to indirectly assess dosesdue to particulate and iodine ingestion. This type of monitoring may include sampling of soils, broad-leafed plants, fish, meat, or milk. Considering that particulates and iodine radionuclides are not expectedto be present in measurable quantities within the RPF airborne effluent releases, biota monitoring wouldnot be performed. In the event that environmental airborne sample results indicate the presence of iodineor particulates in measurable quantities, or if the effluent monitor sample results indicate the presence ofiodine or particulates in quantities large enough to result in a calculated dose at the property line thatexceeds 10 percent of the dose constraint (i.e., 1 mrem/yr), a sampling campaign would be undertaken.Milk is an important food product that contributes to the radiation dose to people, most notably fromradioactive iodine. If biota sampling is determined to be required as a result of radioactive iodine andparticulate activity measured during effluent monitoring or air sampling, milk sampling would beperformed following the guidance provided in Table 3.12-1 of NUREG-1301 (e.g., sampling frequencyand type of sample analysis). Cow and/or goat milk samples would be obtained from dairy productionsites on a semi-monthly basis (when animals are on pasture) and on a monthly basis (at other times). Agamma isotopic analysis and 1311 analysis would be performed on the samples. Since milk samples areconsidered a better indicator of radioactive iodine in the environment than vegetation, as long as milksamples are obtained, vegetation sampling (e.g., broad leaf vegetation) is not expected to be included inthe exposure pathway sampling, in accordance with guidance provided in Table 3.12-1 of NUREG-1301.19.4.9 Waste ManagementA detailed description of the sources, types, and approximate quantities of waste within the proposed RPFis provided in Section 19.2.7. This section also discusses the proposed waste management systems,including on-site treatment and waste minimization approaches and the anticipated disposal locations.The facility waste types would be managed in accordance with applicable Federal, State, and localregulations. The direct and indirect impacts associated with the treatment and disposal of RPF-generatedwastes are small.19.4.10 TransportationMaterials to be transported to the proposed RPF include LEU, irradiated targets, commercialsupplies/chemicals, and other industrial supplies to support the day-to-day operation of the facility.Materials transported from the facility would include 99Mo product, unirradiated targets, and waste.Section 19.2.7 provides a description of the treatment of radioactive and nonradioactive waste prior toshipment. Section 19.2.8.2.1 provides a description of the waste packaging required for LEU, irradiatedand unirradiated targets, and 99Mo product.19-216 NWMII fe,.: l Chapter 9.0 -Environmental Review19.4.10.1 Transportation Mode and Projected DistancesDescriptions of the modes of transportation and distances are provided in Section 19.2.8.2.2, along withthe estimated distance to projected destinations. The following subsections provide specific informationregarding the transport of LEU, irradiated and unirradiated targets, 99Mo product commercialsupplies/chemicals, and RPF-generated waste.19.4.10.1.1 Fresh Low-Enriched UraniumThe fresh LEU would be transported by commercial carrier to the proposed RPF from the DOE Y-12Program Office in Oak Ridge, Tennessee, approximately 953 km (592 mi) from the proposed RPF site.The transportation route includes one stop for fuel or other provisions.19.4.10.1.2 Irradiated and Unirradiated TargetsBoth unirradiated and irradiated targets would be sent from the three reactor facilities to the proposed RPFby commercial carrier using a commercial cask, certified by the NRC, on public roads. The routes are:* RPF to MURR in Columbia, Missouri -Approximately 9 km (6 mi) with no stops* RPF to OSTR in Corvallis, Oregon -Approximately 3,320 km (2,063 mi) with two stops each way* RPF to third reactor -Approximately [Proprietary Information]19.4.10.1.3 Molybdenum-99 ProductThe 99Mo product produced at the proposed RPF is assumed to be distributed to two vendors. Onevendor, located in Hazelwood, Missouri, would require transport by commercial ground carrier from theRPF to the vendor facility, which is 181 km (112.5 mi) away. The 99MIo product sent to the other vendorwould be transported by commercial ground carrier to the Columbia Regional Airport, which isapproximately 13 km (8 mi) from the RPF site. From the airport, the 99Mo product would be transportedby air carrier to Boston Logan International Airport. Exposure from 99Mo to the general public during theflight is assumed to be negligible and was not calculated. The 99Mo product is assumed to be transportedby commercial ground carrier for a distance of 50 km (31 mi) from Boston Logan International Airport tothe vendor in Billerica, Massachusetts. Approximately 50 percent of the 99Mo product is assumed to beshipped to Hazelwood and 50 percent shipped to Billerica.19.4.10.1.4 Spent Low-Enriched UraniumThe spent LEU would be transported approximately 1,345 km (836 mi) to the Savannah River Site inAiken, South Carolina using an ES-3 100 cask, or equivalent. The transportation route includes one stopfor fuel or other provisions.19.4.10.1.5 Commercial Supplies/ChemicalsCommercial supplies and chemicals would be transported by commercial carrier on public roadways incompliance with vendor requirements. There is no anticipated dose resulting from the transport ofcommercial supplies and chemicals.19.4.10.1.6 Waste TransportationWaste generated at the proposed RPF would be disposed in licensed facilities. Radioactive waste wouldbe transported by truck to Waste Control Specialists (WCS) in Andrews, Texas. WCS is approximately1,470 km (913 mi) from the RPF site. The transportation route includes one stop each way.19-2 17

.NWCatr1NWMI-21-2,Rev. OlviChptr 9.0 -Environmental Review..e.N ORTHWEST M EDICAt ISOTO pEsNWMI also incorporates a recycling program into general operations at the facility. This programincludes arranging for recycle drop-off and pick-up of recyclable wastes. The recycling drop-off point islocated approximately 6 km (4 mi) from the RPF site. Municipal waste would be disposed of at the localsanitary landfill, approximately 17.5 km (11 mi) from the facility.19.4.10.1.7 Radioactive Waste PackagingRadioactive waste generated at the proposed RPF would be treated and packaged as discussed inSection 19.2.7. Solid waste would include used components, equipment, and solidified liquid wastes.This material would be collected, stored at the facility to allow for radioactive decay, and then size-reduced and consolidated for shipment. Prior to shipment, all radioactive material would be packaged tomeet DOT and NRC requirements for transporting radioactive materials.19.4.10.2 Incident-Free Radiological DoseIncident-free radiological doses are determined for members of the public and the transportation andhandling workers involved in transporting the fresh LEU, irradiated and unirradiated targets, 99Moproduct, spent LEU, and radioactive wastes.Calculation of the incident-free radiological doses is performed using the RADCAT/RADTRAN modelingcode. The RADCAT/RADTRAN code calculates doses to workers and members of the public. Forshipments by air, transport of the 99Mo product from the proposed RPF to Columbia Regional Airport ismodeled; ground transport from the RPF to Hazelwood, Missouri, is also modeled. As described below,transportation scenarios based on land routes are used to conservatively estimate the radiological dosesresulting from radioactive material transport.The highway route and distance traveled for a shipment from the proposed RPF to a destination facilitywere determined from route data from MapQuest2 and applicable GIS data available from ArcGIS3software. Census data files were used to derive the population density along the route (USCB, 2010a),which is required for calculating the dose to members of the public. National Highway Planning Networkdata files were used to derive the vehicle density data required for the model (FHWA, 2013).Regions containing segments of each transportation route are classified as rural, suburban, or urban, basedon population. Population zones are based on the following specific population concentration ranges:* Rural -Less than 54 persons/km2 (139 persons/mi2)* Urban -Between 54 and 1,284 persons/km2 (139 and 3,326 persons/mi2)* Suburban -Greater than 1,284 persons/km2 (3,326 persons/mi2)Once data are gathered, the route segment categories, transportation information for each route, packageshielding information, and radioactive characteristics for the constituents of each package would beloaded into the RADCAT interface and run with the RADTRAN computer model. The route informationis listed in Table 19-69. The route segment information is summarized in Table 19-70 (EDF-3124-0010,Radiological Dose Consequences Associated with Transportation of Materials for the RadioisotopeProdu~ction Facility for Northwest Medical Isotopes).2 MapQuest is a registered trademark of MapQuest. Inc., Denver. Colorado.SArcGIS is a trademark of Esri. Redlands, California.19-2 18

~. ~J3AfJ~NWMI-2013-021, Rev. 0AChapter 19.0- Environmental ReviewTable 19-69. General Route Information-00~ 6 *~ 0I-

• a S.RPF to MURRRPF to OSTRRPF to third reactor9.63,32062,06302[ProprietaryInformation]26[ProprietaryInformation][ProprietaryInformation]88DOE Y-12 Program Office (OakRidge, Tennessee to RPF)RPF to distributor (Hazelwood,Missouri)95359211312181052Boston Logan Airport todistributor (Billerica,Massachusetts)50 31 0 52Source: EDF-3124-0010, 2015, Radiological Dose Consequences Associated with Transportation ofMaterials for the Radioisotope Production Facility for Northwest Medical Isotopes, Rev. 2, Portage, Inc., IdahoFalls, Idaho, January 4, 2015.DOE = U.S. Department of Energy. RPF = Radioisotope Production Facility.MURR = University of Missouri Research Reactor. SRS = Savannah River Site.OSTR = Oregon State University TRIGA Reactor. WCS = Waste Control Specialists.19-219 NW~UNWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-70. Route Segment InformationSource: EDF-3124-0010, 2015.,Radiological Dose Consequences Associated with Transportation of Materials for theRadioisotope Production Facility for Northwest Medical isotopes. Rev. 2. Portage, Inc., Idaho Falls, Idaho, January 4, 2015.a Percentage of Geographical Information System census tracts for each destination.DOE = U.S. Department of Energy. OSTR = Oregon State University TRIGA Reactor.MURR = University of Missouri Research Reactor. WCS = Waste Control Specialists.NA = not applicable.19-220 i.NWMIN+W.W.. IR" T MIEWCAUS OsolrpfS19.4.10.2.1 Radiological SourceTermRadiological characteristics arederived from estimated source termdata, and then evaluated from materialbalance calculations, productspecification, and estimated wastecalculations.The radioactive characterization foreach of the materials is presented inTable 19-7 1 through Table 19-76(EDF-3 124-0010). These numbers arepreliminary and subject to changebased on future data. Radionuclidesless than 0.1 Ci were not listed for theirradiated target.NWMI-2013-021, Rev. OAChapter 19.0- Environmental ReviewTable 19-71. Unirradiated Target Shipment Source Term.. ...-.-.232U235w238UTotCs[Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information][Popnetar Inora ion][Proprietary Information][Proprietary Information]MURR = University of Missouri Research Reactor.OSTR = Oregon State University TRIGA Reactor.Table 19-72. Irradiated Targets for Oregon State University andThird Reactor Radiological Characteristicsl .i!l [ I iII :*.. il[l * [, Siiomml~85Kr90Sr91y9SmNb'03Ru"l'Ag'23Sn'25Sb127mTe[Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information]129mTe432Te133m Xe4Oa143pr'5tSm'56Eu237U[Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information]Source: EDF-3124-0010, 2015, Radiological Dose Consequences Associated with Transportation of Mate rials fir the RadioisotopeProduction Facility for Northwest Medical Isotopes, Rev. 2, Portage, Inc., Idaho Falls, Idaho, January 4, 2015.aBased on 30 targets per shipment at 8-hr end of bombardment.' URh is not included in the nuclide library of RADTRAN. '6Ru in secular equilibrium was used as a substitute.19-221

.+*.'.NWlIMIINWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-73. Irradiated Targets for University of Missouri Research ReactorRadiological Characteristics239Np[Proprietary Information][Proprietary Information]+[Proprietary Information]i1311 [Proprietary Information]137Cs95m~pb90y85Kr[Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information][Proprietary Information]i89Sr133mXe237U-I[Proprietary Information]I-I[Proprietary Information][Proprietary Information]I~ I~,[Proprietary Information][Proprietary Information]mi'27Te[Proprietary Information]I29m Te [Proprietary Information]L235U238puL241u[PoreayIfrain[Proprietary Information]m[Proprietary Information][Proprietary Information][PoreayIfrain[Proprietary Information]'06Ru'25Sn[Proprietary Information][Prorietry IformtionI.Source: EDF-3 124-0010, 2015, Radiological Dose Consequences Associated with Transportation ofMaterials for the Radioisotope Production Facility for Northwest Medical Isotopes, Rev. 2, Portage, Inc., IdahoFalls, Idaho, January 4, 2015.a Based on twelve (12) targets per shipment at 8-hr end of bombardment.19-222

..Chapter 1 NWMI-2013-021, Rev. 0A."o.viChptr 9.0 -Environmental ReviewTable 19-74. Low-Enriched Uranium Radiological Characteristics237U235g238u[Proprietary Information][Proprietary Information][Proprietary Information]6OCo9OSrTotal[Proprietary Information][Proprietary Information][Proprietary Information]Source: EDF-3124-0010, 2015, Radiological Dose Consequences Associated with Transportation ofMaterials for the Radioisotope Production Facility for Northwest Medical Isotopes, Rev. 2, Portage, Inc., IdahoFalls, Idaho, January 4, 2015.B Spent LEU is assumed to have the same source term as fresh LEU.b Based on 186.6 kg (411 lb) total uranium.LEU = low-enriched uranium.Table 19-75. Estimated Waste Radiological CharacteristicsI *. A- I ,S9Sr 0.6591y 0.5695Zr 0.56127Sb 0.07 1141Ce1.80.930.112.3Source: EDF-3 124-0010, 2015, Radiological Dose Consequences Associated with Transportation ofMaterials for the Radioisotope Production Facility for Northwest Medical Isotopes, Rev. 2, Portage, Inc., IdahoFalls, Idaho, January 4, 2015.a Based on the quantities in Table 19-13.Table 19-76. Molybdenum-99 Product Radiological Characteristics99MoIiii103R[Proprietary Information][Proprietary Information]89Sr~Sr[Proprietary Information][Proprietary Information]Source: EDF-3 124-0010, 2015, Radiological Dose Consequences Associated with Transportation ofMaterials for the Radioisotope Production Facility for Northwest Medical Isotopes, Rev. 2, Portage, Inc., IdahoFalls, Idaho, January 4, 2015.aBased on cask limit of 1,500 Ci 99Mo.19-223 NOhWETMEIA ISOOE hpe NWMI-2013-021, Rev. 0AlviChptr 9.0 -Environmental ReviewThe dose associated with the transport of LEU is much smaller than the dose associated with the transportof other radioactive materials. Doses associated with the transport of LEU metal are much smallerbecause of the infrequent shipments (two per year) and the low activity in each shipment.Palladium-i112 (1"2pd) was not in the available nuclide library in RADTRAN. This radionuclide is aminor contributor to the 99Mo product source term. The dose consequence from 2Pd was not calculatedfor the transportation scenarios presented. The exclusion of "2pd has a negligible impact to the 99Moproduct source term and derived dose consequence.1 9.4.10.2.2 Dose Model ResultsThe annual incident-free radiological doses resulting from transport of radioactive materials from the RPFare summarized in this section. These doses are calculated assuming that the dose rates associated withthe shipping containers are equal to typical dose rates, based on the DOT-approved dose limits of10 mrem/hr at 2 m. The source term used for the contents of the packages was determined based on thenumbers in Table 19-71 through Table 19-76. The dose to workers due to the handling and transport ofradioactive material to and from the RPF is 0.366 person-sievert (Sv) (36.6 person-rem/yr).The dose to the general public resulting from exposure during transportation, including stops/inspections,is 0.473 person-Sv (47.3 person-rem/yr). The total dose to the maximum exposed individual fromexposure during transit is 3.93E-06 Sv (3.933E-04 rem) (EDF-3124-0010).As indicated in Section 19.3.8.2.1, background radiation for the RPF site is approximately 228 mrem/yr.The population within a 5-mi radius of the facility is 33,966; therefore, the population dose in the vicinityof the RPF due to background radiation is approximately 77.44 person-Sv/yr (7,744 person-rem/yr).Compared to the background dose in the vicinity of the RPF, the effect of incident-free transportation issmall.Materials to be transported to the RPF include LEU, irradiated targets, process chemicals, and otherindustrial supplies to support the day-to-day operation of the facility. Materials transported from the RPFinclude 99Mo product, targets, spent LEU, and waste. Section 19.2.7 provides a description of thetreatment of radioactive and nonradioactive waste prior to shipment. Section 19.2.8.2.1 provides adescription of the packaging associated LEU, targets, and 99Mo product. Descriptions of the modes oftransport and distances are provided in Section 19.2.8.2.2, along with the estimated distance to anticipateddestinations.19.4.11 Postulated AccidentsThis section identifies the hazards associated with the facility, postulated accidents associated with themajor systems of the RPF, the initiating events, the postulated accidents/hazards, and the impacts frompostulated accidents that drive the design of the facility and systems. These accidents are referred to asdesign basis accidents (DBA). Detailed analyses of the radiological and nonradiological consequencesfrom the maximum hypothetical accident (MHA) and subsequent accident categories are discussed inChapter 13.The hazards associated with the RPF include the following:* Criticality* Release of radioactive offgas or radioactive products* Radioactive waste* Hydrogen production by radiolytic decomposition of irradiated fissile solution* Tank and equipment failure leading to a release of radiological or chemical materials* Release during receiving of hazardous chemicals outside the facility19-224 IIVVChapter 9.0 -Environmental Review.... .NORT1HWEST MEDICAL ISOTOPES19.4.11.1 Accident CategoriesAccording to NRC (20 12a), the following accident categories are to be addressed for the RPF:° MHA* Criticality* Loss of normal electrical power* External events* Mishandling or malfunction of equipment* Operator error* Facility fire* Hazardous chemical releaseAll initiating events and scenarios applicable to the RPF are discussed in Chapter 13. Representativeaccident scenarios with bounding consequences for each of the initiating events/scenario categories areevaluated quantitatively in Chapter 13. The most bounding accident scenarios with respect toconsequences for the facility are evaluated in the following subsections.19.4.11.1.1 Maximum Hypothetical AccidentThe RPF is being designed to withstand credible external events. Therefore, an internal accidentreleasing the largest possible quantity of radioactive material is considered to be the initiating event thatwould result in the maximum bounding radiological consequence. The MHA:*Defines an event that results in radiological consequences that exceed those of any accidentconsidered to be credible* Bounds the radiological consequences of postulated DBA scenarios; does not need be a crediblescenario but a failure assumed to establish an outer limit consequence* Is based on events unique to the facility that hypothetically could result in a release of radioactivematerialsThe accident scenario identified as the MHA is initiated after the dissolver system has been runningbeyond its nominal target processing rate (12 MURR targets per week) for 12 weeks. This allows theiodine retention units (IRU) to accumulate an amount of iodine greater than during normal operation.Accident events might degrade the IRU, making it less efficient to capturing the fresh iodine duringdissolution or generate a partial release of accumulated iodine. However, an accident that could releaseall of the accumulated iodine has not been identified.As a conservative analysis, a combustion accident that releases all of the accumulated iodine as a gas wasassumed to take place. As a result of the combustion, the entire inventory of iodine would also bereleased over a two-hour period directly to the 22.9 m (75-ft) stack and into the environment. The sourceterm for the MHA scenario came from NWMI-201I3-CALC-0 11, Source Term Calculations. No reductionfrom secondary filter systems was assumed. In addition, no plating or entrapment of any iodine wasassumed.Controls that mitigate the consequences of the MHA include:* Hot cell containment area/shielding* Radiation monitors* Ventilation system cascading design and secondary iodine retention unit* Design of the entire dissolution offgas system (e.g., chain of filters and retention systems runningin parallel through a large network of piping)19-225 NWMIVNWMI-2013-021, Rev. 0AChapter 19.0 -Environmental Review* Sizing of the target dissolution system and batching of target dissolution process for eight targetsThe evaluation of the inventory for the considered MHA is based on a set of limiting initial conditionsthat were designed to maximize the potential source term and bound the credible scenarios. Theseassumptions include:* Estimating 12 MURR targets for the process batch upstream of the IRU system, which is beyondthe process design capacity of eight MURR targets6 Maximum accumulation of iodine in the IRU based on the 12 targets* Greater than expected release of material (e.g., entire inventory of iodine is assumed to bedeposited on a single IRU, no plating out of iodine, or subsequent capture downstream of IRU).The Radiological Safety Analysis Code (RSAC) system, RSAC Version 6.2, was used to model thedispersion resulting from the MHA. The following common parameters were used for all model runs:* Mixing depth: 400 m (1,312 ft) (default)* Air density: 1,250 g/m3 (1.25 oz/ft3) (sea level)* Pasquill-Gifford a (NRC Regulatory Guide 1.145, Atmospheric Dispersion Models for PotentialAccident Consequence Assessments at Nuclear Power Plants [NRC, 1983])* No plume rise (i.e., buoyancy or stack momentumeffects)* No plume depletion (wet or dry deposition)* 2-hr release (constant release of all activity)* 2-hr exposure* ICRP-30 inhalation model (ICRP-30, 1979)* Finite cloud immersion model* Breathing rate: 3.42E-4 m3/second (sec)(1 .2E-2 ft3/sec)(ICRP-30 heavy activity)* Respiratory fraction: 1.0The results of the modeling show that for a 22.9 m (75-ft)stack with the release detailed above, the maximum dosereceived during a two-hour exposure by an individualwould be 17.1 rem at a distance of 1,100 m. The doseresults for the 12-target inventory are provided inTable 19-83.The 8-hr and 16-hr decay inventories were used.Radionuclides not available in the RSAC library or notedas having an activity less than one atom were removedfrom the inventory in the RSAC model runs. The windspeed (m/s) and stability category were varied. The modelwas also run varying the inventory from 100 to 25 percent(EDF-3124-0003, Preliminary Maximum HypotheticalAccident to Support the Northwest Medical IsotopeFacility Environmental Report). Table 19-83 provides theresults.Results200 6564005006007OO80011001300i401500170013121968262536094265492155774.36E-031.59E-028.15E-021.40E-011.71 E-0 11.67E-011.56E-011 .43E-014.36E-011 .59E+008.15E+001 .40E+0 11.71E+011 .67E+011 .56E+0 11 .43E+01Source: EDF-3124-0003, 2015,Preliminary Maximum Hypothetical Accidentto Support the Northwest Medical IsotopeFacility Environmental Report, Rev. 1, Portage,Inc., Idaho Falls, Idaho, February 5, 2015.19-226 NW M I~ I~f NWMI-2013-021, Rev. OA: :¶¶V Chapter 19.0 -Environmental Review* .Q... NORTHW STEIAIOTOPE$19.4.11.1.2 CriticalityInadvertent criticality is prevented and/or mitigated by the design of criticality safe geometry tanks,piping, drains, and sumps in the hot cell areas. Administrative controls (e.g., batch sizing [mass] and timerequirements) on system operations are implemented to prevent the occurrence of a criticality. Tanks orcomponents containing significant quantities of fissile material are seismically qualified to surviveseismic events.Any potential releases of radioactive material from a criticality are mitigated by the offgas system, theventilation system, and the passive confinement provided by the hot cell and the facility structure. Thecriticality event would result in a singular pulse or series of short duration pulses, followed by adispersion of the fissile material. A criticality would generate source terms and doses that are equivalentto or less than the MHA discussed in Section 19.4.11.1.1.19.4.11.1.3 Loss of Electrical PowerA loss of power could lead to initiating events that result in various accident conditions, including the lossof ventilation and offgas system. Loss of ventilation and offgas systems could lead to deflagration fromthe accumulation of hydrogen gas in the offgas system, in the hot cell area, or in smaller vessels/piping.Hydrogen accumulation in the offgas system and the hot cell area is not expected to exceed the lowerexplosive limit or lower flammability limit. In the event that accumulation occurs in a smaller vessel to apoint above the lower explosive or lower flammability limits, and an ignition source is present, thedeflagration event may occur. During this accident scenario, radioactive material is confined in the hotcell and ventilation system. The consequences of this scenario are bounded by the release of the entirecontents of the dissolver during the MHA.19.4.11.1.4 External EventsThe following potential external events have been identified as possible accident scenarios:* Seismic event* Tornado, high wind, or other natural phenomenon hazard* External crash into the RPFThe facility structure, including the hot cell containment areas and critical process equipment, would bedesigned, as required by the results of the safety analysis, to provide appropriate levels of mitigationduring these accident scenarios.19.4.11.1.5 Mishandling or Malfunction of EquipmentPotential DBAs that could be initiated by mishandling or malfunction of equipment include:* Failure of the offgas system* Vessel or piping failureThe proposed RPF would be designed with multiple engineering features and controls to prevent ormitigate the potential consequences from mishandling or malfunctioning equipment. Critical equipmentwould be designed robustly with significant redundancy or fail-safe features to prevent or mitigate theconsequences from these events. Consequences from these accident scenarios are bounded by the releaseof the entire contents of the dissolver, as discussed in the MHA.19-227 ChptrMWM-2I302,Rev. QlviChater19.0 -Environmental Review19.4.11.1.6 Operator ErrorIn any process, operator error is considered probable. The proposed RPF and systems would be designedto minimize the need for operator inputs. Human factors would be considered when determining processsteps, controls, and procedures used to define operations at the facility. Work controls would includeindependent checks and verifications when transitioning between steps, a mass balance tracking system,and batch-wise process flow controls to help eliminate the need for human judgment and interferencewith a system. When possible, engineered controls would be used to define process steps. This includesgeometrically favorable configurations, small capacity tanks, bird-cages, or zone barriers. Whennecessary, administrative controls would be used to supplement engineered controls. Batch-wise process,zones, active inventory management for all fissile or hazardous material, and storage accountabilitycontrols would be used as administrative controls. The MHA could be initiated by operator error;however, all other postulated accidents that could happen within the hot cell or around the facility properresult in consequences that are bounded by the MHA.19.4.11.1.7 Facility FireA fire in the proposed RPF is identified as a possible DBA. Events that could lead to a fire may beprecipitated by failure of electrical or mechanical equipment or human error involving a loss of control ofcombustible materials or ignition sources. Facility fires are not expected to directly release significantamounts of radioactive material; however, fires can lead to the release of radioactive material where firedamage to process equipment results in a loss of confinement through damage to system integrity,spurious equipment operation, or loss of equipment control. Fire damage to equipment typically resultsfrom direct exposure of equipment to a fire or exposure of equipment to elevated temperatures caused bya fire. Widespread fire damage to process equipment that can lead to a radiological release most likelyoccurs inside a confined enclosure such as the hot cell or vessel. Small spaces also provide confinementof the products of combustion, which can develop into a damaging fire environment.A damaging fire environment in the general area of the RPF is unlikely due to the large size of the area.Direct fire damage to key process equipment that could lead to a significant radiological release is notlikely because redundant control or power circuits are separated by distance to prevent such damage froma single fire. Thus, the DBA is considered to be a fire in an enclosure that may develop into a damagingfire environment.The design basis fire accident is postulated to occur in the hot cell where it would contribute to the releaseof the contents of the dissolver. Fire damage to the dissolver, associated valves, or process piping couldlead to a release of contents of the dissolver into the hot cell area. Release of this material into the hotcell could lead to an airborne release of radiological material into the cell and ultimately migrate into theventilation system. The potential release would be mitigated by design of the fire suppression system andthe ventilation system. Mitigation would occur due to the activation of the fire suppression system andthe isolation of affected parts of the ventilation system in response to a smoke alarm signal or detection ofradioactive material by the radiation monitoring system. Activation of the fire suppression system wouldreduce or stop the spread of combustion. Isolation of the ventilation system would prevent significantrelease to the environment.Radiological release of this DBA is bounded by the MI-A and contained by the facility (i.e., hot cell) andventilation system. The hot cell structure and ventilation systems are designed to withstand or containfire strengths that are postulated for this event.19-228 Chapter WM.-2013-o21 Rev. OA:-"- VV' VChater19.0- Environmental Review* -.,.. -* ORTHEWEST MEDICAL ISOTOPES19.4.11.1.8 Hazardous Chemical ReleaseConsistent with NUREG/CR-64 10, hazardous chemical releases considered for this ER are limited tothose that can be released from the processing of licensed nuclear material or that have the potential foradversely affecting radiological safety. Other Federal and State agencies such as EPA and OSHA alsoregulate hazardous chemical management to protect facility workers and the general public from releases.The controls, programs, licenses, threshold quantities, and other aspects of Federal and State programsother than NRC would be considered during the consequence analysis. Where necessary to ensure thatradiological safety is not adversely affected, engineering or administrative controls would be developed toeliminate or mitigate the chemical release and the postulated accident(s) and resultant controls, asdiscussed in Chapter 13. The effects of chemical releases will also be considered in the facilityemergency response plan and operating procedures.The consequences of chemical releases are evaluated using dispersion models and/or computer codes thatconform to NUREG/CR-6410 methodologies. The ALOHA computer code was used to estimate theconsequences from releases of certain chemicals currently anticipated to be present at the RPF. ALOHAis an atmospheric dispersion model used for evaluating releases of hazardous chemical vapors. Themodel does not monitor combinations or chemical reactions. Chemical reactions will be addressed in thesafety analysis discussed in Chapter 13. The inventory values used in the ALOHA analysis areconsidered to be bounding conditions and may be refined during the development of the Final SafetyAnalysis (FSAR), as the process matures. Within the context of the preliminary safety analysis (PSAR),calculation of the exposure of the maximally exposed off-site individual (MOD) and nearest resident, andcomparison to Protective Action Criteria (PAC) limits serve as a baseline to identify where additionalcontrols should be considered (e.g., where the worker is subject to effects that hinder their ability torespond or where off-site response to a radiological emergency may be hindered by chemical effects).In running the simulation model, no credit is taken for depletion or plate-out of chemicals within the RPFor during transport to the fence line or nearest population location. All dispersion calculations areperformed assuming moderate wind conditions (i.e., Stability Class C) based on the average meteorologicalconditions presented in Section 19.3.2.1. The following environmental parameters were used:* Wind speed is 14.25 km/hr (8.86 mi/hr)* Wind direction is from due south (1 80°)* Temperature is 23.9°C (75°F)* Humidity is 70 percentThe location of the MOI is based on the general layout of the RPF, as shown in [Proprietary Information]Figure 19-10. The distance from the facility to the boundary fence is estimated at 24 m (80 ft). Thelocation of the nearest resident is based on Table 19-77. The nearest resident is 0.43 km (0.27 mi[285 ft]) to the south. The model is run such that the MOI and the resident are both in line with thedirection of the wind. This provides a conservative bound for the exposure calculation.Chemical concentrations were determined for a select list of chemicals from Table 19-68. Chemicalswere selected based on availability in the ALOHA library and quantity. Chemical inventory and releaseconcentrations for the MOI and nearest resident are presented in Table 19-77. In each case, the materialat risk (MAR) represents the estimated maximum inventory of the chemical listed. Two differentscenarios were used for the release, based on the physical form of the chemical. For liquid chemicals, thescenario is a breach in the tank resulting in an unconfined spill and subsequent evaporation. For gases,19-229 Rev. 0Alvioi .. hate 9.0 -Environmental Reviewthe scenario is an immediate release to the atmosphere from a ruptured tank. All scenarios wereconducted for a 1-hr interval.Table 19-77. Chemical Dose Analysis ResultsNitric acid (HNO3) 5,000 (L) 1,321 (gal) liquid 24 (ppm) 1,200 (ppm) 19.1 (ppm)Ammonia 100 (kg) 220 (lb) gas 160 (ppm) 36,800 (ppm) 123 (ppm)aSodium hydroxide (NaOH) 1,900 (L) 502 (gal) liquid 5 (ppm) NA NASource: EDF-3 124-0002, 2014, Chemical Hazard Analysis for Accidents Associated with the RadioisotopeProduction Facility for Northwest Medical Isotopes, Rev. 0, Portage, Inc., Idaho Falls, Idaho, June 26, 2014.a Sodium hydroxide was not analyzed, but based on the quantity, and the low PAC-2 limit, it is assumed toexceed the PAC-2 limit.MAR = material at risk. NA = not applicable.MOI = maximally exposed off-site individual. PAC = Protective Action Criteria.The results for each chemical are compared to the values listed in the PAC for chemicals, including AcuteExposure Guideline Levels (AEGL), Emergency Response Planning Guidelines (ERPG), and TemporaryEmergency Exposure Limits (TEEL) (DOE, 2012). The analysis indicates that some of the chemicalexposures exceed PAC-2 limits. The PAC-2/EPRG-2 limit is the threshold below which it is believedthat nearly all individuals exposed for up to 1 hr would not experience irreversible or other serious healtheffects or symptoms that could impair their ability to take protective actions. Accordingly, releases abovethe PAC-2IEPRG-2 limit will be evaluated, and additional controls will be developed. Theserequirements and controls will be are specifically identified in in the PSAR and subsequent FSAR.19.4.11.2 Postulated Accident ImpactsThe proposed RPF would be designed, constructed, and operated to ensure that the consequences ofpostulated accidents would comply with applicable regulations and standards, as discussed in othersections (e.g., Chapters 11 and 13 of the Construction Permit Application). Therefore, the postulatedaccident impacts associated with construction, operation, or decommissioning of the RPF would be small.19.4.12 Environmental JusticeOn February 11, 1994, President Clinton signed Executive Order 12898, "Federal Actions to AddressEnvironmental Justice in Minority Populations and Low-Income Populations." Executive Order 12898directs Federal executive agencies to consider environmental justice under NEPA (42 U.S.C. § 4321 et seq.).This Executive Order ensures that minority and/or low-income populations do not bear a disproportionateshare of adverse health or environmental consequences associated with the construction, operation, anddecommissioning of the RPF.19-230 ChptrWWMI03-2,Rev. OEUVYChVpter19.0 -Environmental Review" ,= "NORThIWEST MESICAL ISOOfPES19.4.12.1 MethodologyThis section describes the minority population and household income distribution within the ROI, the8 km (5.0-mi) area from the center point of the proposed safety-related area at the proposed RPF. Theinformation includes estimates of the minority population and household income for the most recent(2010) census year, and projects that population for the following future years:* Year submitting Construction Permit application (2015)* Year submitting Operating License application (2016)* Five years after submitting Construction Permit application (2020)* Five years after submitting Operating License application (2021)* Approximate expected end of Operating License period (2047)* Five years after approximate expected end of Operating License period (2052)Estimates and projections of minority and household income distribution around the proposed project sitewere divided into five distance bands ---concentric circles at 0-1 km (0-0.6 mi), 1-2 km (.0.6-1.2 mi),2-4 km ( 1.2-2.5 mi), 4-6 km (2.5-3.7 mi), and 6-8 km (3.7-5.0 mi) from the center point of the RPF--and16 directional sectors (with each direction sector centered on one of the 16 compass points) for a total of80 population segments. For each segment formed by the distance bands and directional sectors, theminority and income distribution was estimated using 2010 Census data. The future minority andhousehold income growth in each distance/direction segment was projected using specific growth ratesthat depend on whether the segment is located in Columbia or in Boone County.The City of Columbia comprehensive land use plan, dated October 7, 2013 (City of Columbia, 2013c),presents projections on the future city population calculated using several possible population growthrates. The plan states that the Columbia Area Transportation Study Organization (CATSO) modelprojects a greater rate of population growth and is considered the most reasonable and conservative basisfor estimating the city's future population. According to the plan, the CATSO model growth rate wascalculated by obtaining historic population data and determining land use trends, which are then projectedforward to estimate future growth. Based on these projections, the CATSO model estimated that the rateof population growth (growth rate) is 1.5 percent annually. This growth rate was used to project futurepopulations for areas within the analysis area that are also within the Columbia city limits. The 2010Census estimate of resident and transient populations in each distance/direction segment that is locatedpartially or entirely within the city boundaries was increased by 1.5 percent each year from 2011 to 2050.The Missouri Department of Administration (DOA) provides State and county population projections thatwere developed using the cohort-component method (DOA, 2008). The cohort-component methodinvolves the review of recent historical patterns to determine age- and sex-specific rates of fertility,mortality, and migration. The DOA used the 2000 Census as a base for population counts. The basecount is then advanced at five-year intervals to the year 2030 by using projected survival rates and netmigration rates by age and sex. The DOA projections show that the population of Boone County isexpected to increase by 7.9 percent for the five-year period from 2010-2015, by 7.2 percent from 2015-2020, by 6.2 percent from 2020-2025, and by 5.0 percent from 2025-2030. For each five-year period,the percent of growth was divided by five to give the estimated annual growth rate within that period.The annual growth rates were used to project future populations for the areas around the project site thatare entirely outside the boundaries of City of Columbia. The estimated 2010 resident and transientpopulation in each distance/direction segment that is located entirely outside of the city boundaries wasincreased by 1.58 percent each year from 2011-2015, by 1.44 percent from 20 16-2020, by 1.24 percentfrom 2021-2025, and by 1.0 percent from 2026-2030. The growth rate, or 1.0 percent, was used for2031-2050.19-23 1 ChaperI1NWM,-2013-021, Rev. 0AlviChptr 9.0 -Environmental Review19.4.12.2 Minority PopulationThe 2010 Census race and ethnic minority data associated with the census block and tract areas were usedto estimate the minority population within the 1 km (0.6-mi), 2 km (1.2-mi), 4 km (2.5-mi), 6 km(3.7-mi.), and 8 km (5.0-mi) distance bands. As defined by the U.S. Census Bureau, ethnic minoritypopulations are Asian Americans, Black or African Americans, Hispanic or Latino, Native Hawaiian orother Pacific Islanders, and Native Indian or Alaska Native. Total minority populations were estimated ineach segment for each of the minority populations. For each segment formed by the distance bands anddirectional sectors, the percentage of each census tract land area that falls, either partially or entirely,within that segment was calculated using ESRI ArcMap 10. The equivalent proportion of each censustract's minority population was then assigned to that segment. If portions of two or more census tractsfall within the same segment, the proportional population estimates for the census tracts were summed toobtain the minority distribution estimate for that segment. This methodology and associated maps arepresented in Section 19.2. The minority distribution estimate was then used to calculate the percentage ofthe resident population by race for each of the designated years. The percent of the resident population byrace is based on the resident population estimate discussed in Section 19.3.7.1.2.19.4.12.3 Household IncomeThe U.S. Census Bureau 2006-20 10 American Community Survey estimate data and associated censustract and block data were used to determine the 2010 household income within the 1 km (0.6-mi), 2 km(1.2-mi), 4 km (2.5-mi), 6 km (3.7-mi), and 8 km (5.0-mi) distance bands (USCB, 2010d). The surveydata estimates household income into 16 income levels, starting with those that earn less than $10,000/yr.The method for estimating household income within the distance bands is the same method used fordetermining the minority population.19.4.12.4 Assessment of Disproportionate ImpactsUnder current NRC staff guidance, a minority or low-income community is identified by comparing thepercentage of the minority or low-income population in the impacted area to the percentage of theminority or low-income population in the county and the state. Significance is defined as when thepercentage of either the minority or low-income population in the impacted area exceeds 20 percentagepoints of the state or the county. Significance is also considered if either the minority or low-incomepopulation percentage in the impacted area exceeds 50 percent of the total population (NRC, 2012c).19.4.12.4.1 Minority PopulationTable 19-78 provides the results of the analysis for minority populations. The minority populationdistribution is anticipated to increase at the same rate of the general population (1.5 percent annually)over the license period. The percentages of each minority category within the county and state are alsoprovided as the basis for determining if any of the population groups meet the NRC criteria of significant.For the most part, the population within each segment block within the 8 km (5-mi) radius is within twopercentage points of the state and county minority populations. In addition, none of the segment blockminority populations exceed 50 percent.19-232

• "+.. JmAIIOOENWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-78. Percent Population Distribution by Race-. .. 4

• p -I -.. .S6 S.0-1lkm (0-0.6 mi) 221 81% 4%2-4 km (1.2-2.5 mi) 7,608 81% 3%6-8 km (3.7-5 mi) 23,143 79% 3%Missouri 6,444,660 81% 4%9%8%10%11%0% 3% 0% 0% 3%0% 5% 0% 0%20% 5% 0% 0% 2%0% 6% 0% 0% 2%Source: USCB, 2010c, "U.S. Census 2010," factfinder2.census.gov/faces/nav/jsf/pages/communityjfacts.xhtml#none, U.S. Census Bureau, Washington, D.C., accessed March 12, 2013.aPopulation extrapolated to 2015.19.4.12.4.2 Low Income PopulationsTable 19-79 provides the results of the analysis for low income populations. The population distributionis anticipated to increase 1.5 percent annually over the license period.Table 19-79. Estimated Household Income Within Various Distance Bandsand Within State and County (2 pages)Total households$10,000 to $14,999$20,00 to$4,9$30,000 to $34,999$40,000 to $44,999$50,000 to $59,999$75,000 to $99,999$125,000 to $149,999361 9547.5% 8.2%11.1% 11.8%3.9% 4.8%5.5% 5.3%8.9% 9.1%11.6% 10.5%3.3% 2.7%3,2648.3%11.4%6.4%5.4%9.3%9.0%2.6%5,0317.3%9.9%6.1%5.2%8.0%8.3%2.7%11,245 63,420 2,538,6568.7% 6.0% 6.2%8.0% 7.1% 6.2%5.2% 5.7% 5.8%4.5% 5.3% 5.3%6.9% 8.4% 8.8%8.0% 11.5% 11.7%3.6% 3.7% 3.5%19-233

• ~N VVINWMI-21-2, Rv. o: : Chapter 19.0 -Environmental ReviewTable 19-79. Estimated Household Income Within Various Distance Bandsand Within State and County (2 pages)$200,O000or more 1.4% 2.1% 2.0% 1.5% 1.9% 2.6% 2.5%USCB, 2010d, 2006-2010 American Community Survey. Household Income in the Past 12 Months (In 2010Inflation-Adjusted Dollars), www.census.gov/acs/www/data_documentation/data_main, Table B 1900, U.S. CensusBureau, Washington, D.C., accessed September 2013.The percentages applicable to each income category within the county and state are also provided as thebasis for determining if any of the population groups meet the NRC criteria of significant. For the mostpart, the low-income population within each segment block within the 8 km (5-mi) radius is within twopercentage points of the state and county low-income populations. The "less than $10,000" income levelin the segments from 4-8 km (2.5-5 mi) is higher than the state and county (8 to 9.9 percentage points),but below the significance criteria of 20 percentage points. In addition, none of the segment block low-income populations exceed 50 percent.19.4.13 Connected Actions -University Reactor NetworkIrradiation of LEU targets at the university research reactors is key component of the NWMI process. Fora specific university reactor to irradiate LEU targets for NWMI, an amendment to the university's10 CFR 50 NRC license and an analysis of site-specific environmental impacts related to such anamendment would be required. For the purposes of complying with NEPA' s requirements to analyzeconnected actions, the following sections analyze the operations at each of the proposed universityreactors.19.4.13.1 Irradiation ServicesIrradiation of LEU targets at the university research reactors is a key component of the NWMI process.For a university research reactor to irradiate LEU targets for NWMI, an amendment to the university's10 CFR 50 NRC license and an analysis of site-specific environmental impacts related to such anamendment would be required. For the purposes of complying with NEPA requirements to analyzeconnected actions, the following sections analyze the operations at each of the proposed universityreactors.19.4.13.1.1 University of Missouri Research ReactorFacility ModificationA number of facility modifications are anticipated to be required to support handling and irradiating LEUtargets at MURR. The most significant modifications that will be performed, either via licenseamendment or by performing a screen or evaluation per 10 CFR 50.59, "Changes, Tests, andExperiments," include:Fabrication and installation of three graphite reflector elements to provide irradiationlocations for the targets near the reactor core -The fabrication and installation of new graphitereflector elements are routine operations and the facility has years of experience in both areas,with personnel doses well documented during installation. Graphite reflector elements aredesigned based on the programming needs of the facility to support the type of materialirradiations needed for research and development and for service work.19-234

lIChapter 19.0 -Environmental Review.e,.,NORTHWEST MEOICAL ISOTOPESFabrication of an intermediate irradiated target transfer cask -Design and build anintermediate irradiated target transfer cask to transfer irradiated targets from the reactor pooi to aType B transport cask. This cask will be similar, both physically and functionally, to the currentTRIGA single element transfer cask that is routinely used for fuel movements at other TRIGA-fueled facilities worldwide.*Addition of an airlock on the beamport floor -Design and construct an airlock on thebeamport floor of the reactor to enable the intermediate irradiated target transfer cask to bemoved into and out of the containment structure while the reactor is operating.* Addition of storage locations for both unirradiated and irradiated NWMI targets -Designand build storage areas for unirradiated targets in an area yet to be determined and for irradiatedtargets in the reactor pool awaiting shipment. These storage locations will be similar to what iscurrently used to store fresh and irradiated reactor fuel in geometrically safe criticality configurations.Other minor tasks will include refurbishment of the 15-ton capacity overhead rectilinear crane and freightelevator for increased reliability and fabrication of some target handling tools. These tasks may or maynot fall under the 10 CFR 50.59 screen and evaluation process depending on whether modifications needto be made.19.4.13.1.1.1 Fresh Low-Enriched Uranium Target HandlingMURR receives 24 fresh HEU fuel elements per year as part of the normal operating cycle fuelconsumption. These elements undergo a receipt inspection that includes a contamination and radiationsurvey. These elements typically read 2 to 3 mrem/hr on contact. Based on information obtained fromTRIGA-fueled reactors that have gone through HEU-to-LEU fuel conversion in the past eight years, thereceipt of fresh LEU TRIGA fuel may be indicative of what should be expected for unirradiated LEUtargets.The fuel received for conversions was 20 percent enriched and 30 wt% standard TRIGA fuel containing anominal uranium mass of 820 g within a stainless-steel clad cylinder with outer dimensions very similarto the proposed LEU targets. Typical dose equivalent rate readings on contact and at 0.3 m (1 ft) were 0.1to 0.3 and 0 mrem/hr, respectively. No measureable dose equivalent rate at 0.3 m (1 ft) from a fullyloaded storage container was observed. Because of this, no appreciable increase in the occupational doseequivalent is expected from the handling of the proposed unirradiated LEU targets at MURR.Additionally, no appreciable increase in dose to the general public is expected from handling theunirradiated LEU targets due primarily to the very low dose equivalent rates observed with the LEUTRIGA fuel handling and a lack of proximity of the general public to the targets themselves.19.4.13.1.1.2 Irradiated Low-Enriched Uranium Target HandlingMURR has extensive experience in handling fresh and irradiated reactor fuel, fueled experiments, andirradiated samples of varying materials, masses, and fluences within the reactor pool. To support itsoperating cycle, MURR performs a complete reactor core refueling each week that consists of, at aminimum, 16 fuel-handling evolutions. All of these fuel-handling evolutions and material samplehandling have well-documented historical dose rate measurements. The handling of irradiated NWMItargets, using established ALARA principles, is anticipated to have a minimal impact on the occupationaldose to MURR staff. Table 19-80. Table 19-81, and Table 19-82 provide a summary of the pastfive years of occupational dose to the MURR reactor operations, reactor health physics, and shippinggroups, respectively, that are responsible for handling, packaging, and shipping the irradiated LEUtargets.19-235 NW MvI hpe NWMI-2013-021, Rev. 0A: : Chpter 9.0 -Environmental ReviewTable 19-80. Annual Occupational Dose Summary for MURR Reactor Operations Group(typically 28 people badged within the group)2013 1,556 1,236 67 696 19,4892011 2,895 1,010 68 698 16,0552009 2,930 870 41 574 14,928Table 19-81. Annual Occupational Dose Summary for MURR Reactor Health Physics Group(typically 8 people badged within the group)2013 866 425 22 202 1,6212011 1,609 1,248 22 461 3,225"2009 810 772 11 172 2,411a In 2009 and 2010, Reactor Health Physics Group was part of the Regulatory Assurance Group, whichtypically badged up to 14 people within the group.Table 19-82. Annual Occupational Dose Summary for the Shipping Group(typically 8 people badged within the group)2013 3,397 1,565 51 578 4,6232011 3,209 1,253 33 629 4,4032009 3,290 887 36 427 3,84219-236 NORThWESTMEWtCALS/PENWMI-2013-021, Rev. GAChapter 19.0 -Environmental ReviewThe MURR environmental monitoring program includes monitoring the annual dose equivalent at variouslocations and distances from the facility ventilation exhaust stack. There are 40 environmentalmonitoring stations deployed within the fenced, licensed area and also beyond the fenced area up to adistance of 907 m (2,976 ft). Each station includes a three-chip environmental TLD. Table 19-83summarizes the annual dose equivalent of the 40 environmental dosimeters. Two stations (Station No. 9and 15), located immediately adjacent to two separate loading docks that are a part of the laboratorybuilding and well within the fenced area, account for approximately 60 percent of the total annualaccumulative dose.Packages containing radioactive material arestaged for transport and loaded at these locations.Most other environmental TLDS receive little orno dose. Given the similarity in activities (i.e.,fuel handling evolutions and movements ofirradiated NWMI targets), a measureable increasein the projected dose to the general public isunlikely to occur.19.4.13.1.2 Oregon State University TRIGAReactor19.4.13.1.2.1 Facility ModificationsThree modifications are anticipated to be neededfor the OSTR to handle both unirradiated andirradiated NWMI targets, and include thefollowing:Table 19-83. Summation of the Annual DoseEquivalent for the MURR EnvironmentalThermoluminescent Dosimeters2013201120092257214323a After 2010, some of the radioactive materialpacking was relocated further within the facility, awayfrom the two environmental dosimeters located atStations 9 and 15.* Refurbish the existing 5-ton overhead crane (e.g., replacement of contactors, motor brushes, etc.)or replace the crane to increase reliability and weight margin. Either modification will need tofollow the process described in 10 CFR 50.59 for making changes to a facility.* Design and build an intermediate target transfer cask to transfer irradiated targets from theprimary tank to a Type B transport cask. This cask will be similar, both physically andfunctionally, to the current TRIGA single-element transfer cask that is routinely used for fuelmovements at OSTR and other TRIGA-fueled facilities worldwide.* Design and build a storage container for storage of unirradiated LEU targets. This storagecontainer is anticipated to be similar to the one designed and built to hold fresh TRIGA fuelelements during the OSTR fuel conversation in 2008. Approved by the NRC during the order toconvert, this container is a metal box with two holding plates containing holes in a grid patternnecessary to maintain a geometrically safe criticality configuration.1 9.4.13.1.2 .2 Fresh Low-Enriched Uranium Target HandlingExperience with the receipt of fresh LEU TRIGA fuel used for the HEU-to-LEU fuel conversion at theOSTR in 2008 is indicative of what would be expected for the fresh NWMI targets. The fuel receivedwas 20 percent enriched and 30 wt% standard TRIGA fuel containing a nominal uranium mass of 820 gwithin a stainless-steel clad cylinder with outer dimensions similar to the NWMI LEU targets. After thefresh LEU TRIGA fuel was received, each element was visually inspected, dimensions recorded, and thedose equivalent rates measured at contact and at 0.3 m (1 ft) away along the perpendicular bisect. Typicaldose equivalent rate readings at contact and at 0.3 m (1 ft) were 0.1 to 0.3 and 0 mrem/hr, respectively.19-237 S NW MIVI NWI212, Rv. G: : Chapter 1 9.0 -Environmental ReviewOnce the inspections were complete, no measureable dose equivalent rate at 0.3 m (1 ft) from the fullyloaded storage container was observed.The receipt of LEU targets is expected to be similar, with no appreciable increase in the occupational doseequivalent expected from their handling. Additionally, no appreciable increase in dose to the generalpublic is expected from handling the LEU targets due primarily to the very low dose equivalent ratesobserved with the LEU TRIGA fuel handling and a lack of proximity of the general public to the targetsthemselves.19.4.13.1.2.3 Irradiated Low-Enriched Uranium Target HandlingThe handling of irradiated HEU TRIGA fuel during the HEU-to-LEU fuel conversion at the OSTR issimilar to what would be expected for the irradiated NWMI targets. Additionally, the OSTR has collectedunderwater exposure rate measurements on irradiated HEU TRIGA fuel over several decades. The HEUTRIGA fuel is nearly identical in terms of both outer dimensions and uranium mass as the LEU targets.In late 2008, the existing HEU core was unloaded to a neighboring storage pool using the single-elementTRIGA fuel transfer cask. In early 2009, the fuel from the HEU core was moved from the storage pool tothe Type B transport cask. Although the short-lived radioisotopes had decayed away prior to the move,the burn-up on the fuel (1260 megawatt days [MWD]) was considerably higher that what is anticipatedfor the LEU targets (6.5 MWD). Initial estimates of the exposure rates of the irradiated LEU targetsduring the transfer at the OSTR from the primary tank to the cask are approximately a factor of 3 largerthan experienced during the fuel movements just described. This difference would be accommodated byshield optimization of the intermediate transfer cask that will need to be designed and built. This transfercask would be similar, both physically and functionally, to the current TRIGA single-element transfercask that is routinely used for fuel movements at OSTR and other TRIGA-fueled facilities worldwide.In 2013, the OSTR was completely unloaded and reloaded again, involving well over 200 fuel movements.Table 19-84 summarizes the occupational dose equivalent information for the last seven years. Years2008, 2009, and 2014, when large number of fuel movements occurred, would be similar in procedureand application to what is anticipated for the irradiated LEU targets. (Note: The higher values in 2014are largely due to a significant and high-exposure rate maintenance evolution that occurred after unloadingthe core.) Given that the occupational dose did not otherwise significantly change during these years,were within ALARA guidelines, and all less than the applicable dose limit during these time periods, theroutine handling of irradiate LEU targets should not significantly increase the occupational dose rates.Table 19-84. Annual Summary of Occupational Doses Received at theOregon State University TRIGA Reactor2014 382 502 639 914 2,229 3,5182012 102 340 187 1269 717 2,3772010 39 212 64 478 446 1,4892008 106 312 227 566 850 2,49519-238 NWMIChpe1.; IThe OSTR environmental monitoring programincludes monitoring the annual dose equivalent atthe fence that surrounds the reactor. There arenine environmental monitoring stations located onthe fence. Each station includes a three-chipenvironmental TLD. The average measuredTable 19-85. Total Annual Dose EquivalentMeasured at the Oregon State University TRIGAReactor Fence Lineannual close equivalent measured by these stations 2014 15 -20is provided in Table 19-85.2031 6As noted previously, a number of fuel element 2012 8 +/- 4transfers similar to what is anticipated with the !Jirradiated LEU targets, occurred in 2008, 2009, 201 10....4and 2014. Given the similarity in activities (i.e., 2010 7 +/- 3fuel movements and movements of irradiated LEU 2009 18+/-7targets), a measureable increase in the projected ......... ....... ...........dose to the general public is unlikely to occur. 2008 11 +/- 419.4.13.1.3 Third University NetworkReactorThe third university reactor, once selected, would also require an amendment to the university's10 CFR 50 license and analysis of site-specific environmental impacts related to such an amendment.Information is not currently available to conduct additional analysis for the third reactor. However, theimpacts associated with irradiating LEU targets at both MURR and OSTR are considered to be similar towhat would be expected at a third reactor.19.4.13.2 TransportationA detailed description of the transportation of unirradiated and irradiated LEU targets to the universityreactor network is provided in Section 19.4.10.19.4.13.3 Waste Management19.4.13.3.1 University of Missouri Research ReactorThe amount of radioactive waste that would be generated at MURR as a result of handling and irradiatingNWMI targets is not anticipated to be significant, as the targets will be minimally handled with littlepotential for contamination. The majority of the waste generated will be solid dry wastes (e.g., paper,gloves, and absorbent materials) from moving casks into and out of the reactor pool. Estimates of theadded amount of dry-solid-compactable radioactive wastes are 0.11 to 0.17 m3 (4 to 6 ft3) annually. Incomparison, MURR generated an average of 19.4 m3 (685 ft3) of dry solid radioactive waste annuallyover the past five years. No liquid radioactive waste is expected to be generated as a result of theseactivities.19.4.13.3.2 Oregon State University TRIGA ReactorThe amount of radioactive waste that would be generated at OSTR as a result of handling and irradiatingLEU targets is not anticipated to be signification, as the targets will be minimally handled with littlepotential for contamination. The majority of the waste generated would be solid dry wastes (e.g., paper,gloves, and absorbent materials) from19-239

• ChapterII19.0 -Environmental ReviewThe targets will be moved from the reactor core to the intermediate transfer cask underwater in theprimary tank. Estimates of the added amount of dry-solid-compactable radioactive wastes at OSTR is0.11 to 0.17 m3 (4 to 6 ft3) annually. In comparison, OSTR typically generates 0.85 to 1.13 m3 (30 to40 ft3) of dry solid radioactive wastes annually. No liquid radioactive waste is expected to be generatedas a result of these activities.19.4.13.3.3 Third University ReactorThe third university research reactor will generate waste similar to OSTR.19.4.14 Cumulative ImpactsThe Council on Environmental Quality regulations implementing NEPA require that the cumulativeimpacts of a proposed action be assessed (40 CFR 1500-1508, "Regulations for Implementing theProcedural Provisions of the National Environmental Policy Act"). A cumulative impact is defined by theCouncil as "the impact on the environment which results from the incremental impact of the action whenadded to other past, present, and reasonably foreseeable future actions regardless of what agency (Federalor nonfederal) or person undertakes such other actions" (40 CFR 1508.7, "Cumulative Impact").Cumulative impacts can result from individually minor but collectively significant actions taking placeover a period of time (40 CFR 1508.7). The Council on Environmental Quality guidance for consideringcumulative effects states that NEPA documents "should compare the cumulative effects of multipleactions with appropriate national, regional, State, or community goals to determine whether the totaleffect is significant" (CEQ, 1997).This section addresses cumulative effects of the construction, operation, and decommissioning of the RPFin the context of other actions within the ROI and during the reasonably foreseeable future.Section 19.4.14.1 presents the methodology used to evaluate cumulative impacts. Section 19.4.14.2presents other projects within the ROI that may have cumulative effects when combined with the impactsfrom the RPF. Section 19.4.14.3 identifies and describes the cumulative impacts for each of the resourceareas discussed in Sections 19.3 and 19.4.19.4.14.1 MethodologyCumulative impacts were evaluated by other identified projects and actions (Federal, State, and private)that have occurred or may occur in the present, or in the reasonably foreseeable future. Projects wereidentified through several sources. The initial lists of local projects were identified using the City ofColumbia FY2013 CIP Planning Document (City of Columbia, 20130). In addition, State and countyplanning documents were reviewed, and potential projects were discussed with Regional EconomicDevelopment, Inc., to identify potential private projects. After identifying projects, the likelihood that aproject would be reasonably expected to occur was determined.An integral part of the cumulative impacts analysis involved determining if impacts from the proposedprojects would contribute to ongoing or foreseeable resource trends. A list of projects was evaluated toidentify those with the potential to contribute incremental impact resources during RPF construction,operation, and decommissioning. Many of the identified projects are anticipated to have short-term,temporary, direct impacts or are outside of the ROI and not expected to have cumulative impacts with theRPF. These projects include many of the street and sidewalk, maintenance, replacement, and publicsafety projects.The cumulative impacts analyses do not assess all expected environmental impacts from regional projectswithin the ROI. Only those impacts resulting from the RPF and other past, present, and reasonablyforeseeable future actions that influence the identified resource area are assessed.19-240 IWNWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewThe cumulative impacts were then assessed by resource area (e.g., water resources, air quality, andsocioeconomic impacts). Impacts may arise from single or multiple actions, or they may result in additiveor interactive effects. Interactive effects may, in some cases, be countervailing, where the adversecumulative effect is less than the sum of the individual effects; or they may be synergistic, where the netadverse cumulative effect is greater than the sum of the individual effects (CEQ, 1997).For individual resources, the ROI for cumulative impacts is often larger than the ROI for direct andindirect impacts (identified in Section 19.3, within each resource area discussion). The factors consideredin determining the significance of cumulative impacts are often the same as those presented inSection 19.4.19.4.14.2 Past, Present, and Reasonably Foreseeable Future ProjectsTable 19-86 lists 239 projects, which, when considered with the proposed RPF, could result inincremental impacts to a number of resource areas. These activities largely involve State and localconstruction occurring near the proposed RPF site.Table 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)Oil Water Sep 7th &Walnut5th & Walnut ParkingGarage10/1/2003 12/31/20086 to 8 km3.7 to 510/1/2006 10/1/2010 6 to 8km 3.7 to 5Short St. Parking Garage 10/1/2008Columbia Regional-Airport RunwayExpansion10/1/2010 6 to 8km3.7 to 5Greater than Greater8 km than 5Greater than Greater8 km than 5N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.Y Construction includes newlydisturbed lands and the potentialcumulative effects from air emissionsand effects on land use.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.Columbia RegionalAirport TerminalExpansionPower Plant Rail SpurNot yetdefined10/1/2010 9/30/2011 6 to 8km3.7 to 53.7 to 5College Avenue Crossing 10/1/20109/30/2011 6 to 8km-..-Construct Warehouse &Enclosed ParkingMunicipal Office SpaceExpansionGlobal PET Imaging10/1/2013 12/31/20156 to 8 km3.7 to 53.7 to 57/17/2000 4/30/2011 6 to 8 kmN Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Existing facility with newconstruction.N Project is conceptual with noidentified date to initiate.Not yetdefined0tol1km 0to0.619-24 1 NWM INWMI-2013-021, Rev. 0AChapter 19.0- Environmental ReviewTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)mBlind Boone HomeUniversity of MoMemorial StadiumExpansionUniversity of MoCampus Chilled WaterPlant Phase 2MURR IndustrialBuilding ExpansionOdles' Discovery ParkResidential/CommercialDevelopmentAspen Heights HousingDevelopmentEm""'12/1/2000 12/1/2000 6 to 8km 3.7 to 52012 2015 6 to 8km 3.7 to 5-- 6 to 8km 3.7 to 52014 2014 6 to 8km 3.7 to 5El-N Existing facility with newconstruction.N Existing facility with newconstruction.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.Y Development is mostly onundisturbed land located near theRPF site. Could potentially havecumulative effects on land use, air.noise, traffic, and utilities.Not yetdefined0Otol1km 0-0.6 mi2012 2013 2 to 4 km 1.3 to 2.5 Y Development is mostly onundisturbed land located near theRPF site. Could potentially havecumulative effects on land use, air,noise, traffic, and utilities.The Grove StudentHousing2011 2011 2to4km 1.3 to 2.5The Den Student Hosing20132014 2 to 4km 1.3 to2.5Y Development is mostly onundisturbed land located near theRPF site. Could potentially havecumulative effects on land use, air.noise, traffic, and utilities.Y Development is mostly onundisturbed land located near theRPF site. Could potentially havecumulative effects on land use, air.noise, traffic, and utilities.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.Fire Station #1Replace Existing FireStation # 7Police HeadquartersBuilding10/11/2005 10/1/20063/6/2006 1 / 19/20093/17/2012 3/17/20136 to 8km 3.7 to 56 to 8km 3.7 to 56 to 8km 3.7 to 5Distr. Center/Yard -Consolidation &ExpansionDistributed Generator atSoutheast Location10/1/2005 10/1/201210/1/2007 9/30/20086 to 8km 3.7 to 5'4 to 6km 2.5 to 3.7N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.19-242

• l... NOR}WMS MEIAIOESINWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)!-I3.7 to 5El.!N Construction activity limited topreviously disturbed lands at adistance from the RPF site.BroadwayUndergrounding10/2/2008 9/30/201110/1/2009 9/1/20136 to morethan 8 kmNew South Side161/13.8 kV Substation2 to more 1.3 to morethan 8 km than 5Rebel Hill 212-Substation Feeder10/1/2009 10/1/2010 4 to 6km 2.5 to 3.7Perche SubstationTransformer InterconnectWilliam StreetUndergrounding10/1/2009 5/1/201510/1/2009 9/30/2010Underground Rangeline -12/23/2009 3/1/2011Rogers to WilkesRelocation of 69 kV Line 4/1/2010-Hinkson to PerchePrimary Control Center 4/1/2010 4/1/20134 to more 2.5Sto morethan 8 km than 56 to 8km 3.7 to 56 to 8km 3.7 to 56 to 8km 3.7 to 56 to 8km 3.7 to 54 to 6km 2.5 to 3.74 to 6km 2.5 to 3.76 to 8km 3.7 to 52 to 6km 1.3 to 3.72 to 4km 1.3 to 2.5N Construction activity on previouslydisturbed land and some undisturbedlands. However, the impacts areanticipated to be limited and short-term.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed land and some undisturbedlands. However, the impacts areanticipated to be limited and short-term.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed land and some undisturbedlands. However, the impacts areanticipated to be limited and short-term.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed land and some undisturbedlands. However, the impacts areanticipated to be limited and short-term.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.Green Meadows-Providence to Gray Oak-SLAE. Broadway-HinksonCreek-Brickton Dr.Clark Ln-Rte PP to St.Charles Rd-SLAEastpointe Electric LoopClosureGrindstone 223 -Substation Feeder5/1/2010 11/1/201010/1/2010 12/1/201210/1/2010 5/1/20123/24/2011 10/1/201310/1/2011 12/31/201219-243

• ~. NWMINWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)!IlSouth 16! Tie Line(Grindstone-Perche)10/1/2012 12/31/20142 to more 1.3 to morethan 8 km than 56 to 8km 3.7 to 55th St. Undergrounding -Rollins to Turner1 /18/2013College Undergrounding 1/1 8/20 13-Univ to BouchelleExtend Rebel H-ill Feeder 10/1/201321211/1/2014 6 to 8km10/1/2014 6to8 km3.7 to 53.7 to 53.7 to 51.3 to 5New Water Reservoir atPower Plant161 Trans-Perche Sub toNew South SubMill Creek SubstationTrans Interconnect161 Transmission -Power Plant Line161 kV Power PlantSubstationBusiness Loop 70 -Phase 5 UndergroundingBusiness Loop 70 -Phase 6 Undergrounding10/1/2014 10/1/2015 6 to morethan 8 km10/1/2014 10/1/2015 2 to 8kmEl-N Construction activity on previouslydisturbed land and some undisturbedlands. However, the impacts areanticipated to be limited and short-term.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed land and some undisturbedlands. However, the impacts areanticipated to be limited and short-term.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed land and some undisturbedlands. However, the impacts areanticipated to be limited and short-term.N Construction activity on previouslydisturbed land and some undisturbedlands. However, the impacts areanticipated to be limited and short-term.N Construction activity on previouslydisturbed land and some undisturbedlands. However, the impacts areanticipated to be limited and short-term.N Existing facility with newconstruction.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.10/1/2015 10/1/2016 0to8km 0to510/1/2017 10/1/2018 4 to greater 2.5 tothan 8 km greaterthan 510/1/2018 10/1/2019 6 to 8km10/1/2019 10/1/2021 6 to greaterthan 8 km10/1/2020 10/1/2022 6 to 8km3.7 to 53.7 to53.7 to 516 in. Main-Hwy 63 -West Crossing toStadium8 in. Main -Lake-of-the-Woods4/1/2013 9/1/2013 6 to 8km2/25/2009 12/I1/2010 6 to greaterthan 8 km3.7 to 53.7 to 5N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.19-244 NWINWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)8n.ManRneie1012110/03-m-3.7 to 53.7 to 5Smith to Bus Loop 70Deep Well Abandonment 10/1/2016 10/1/20176 to greaterthan 8 km6 to greaterthan 8 kmEC: Cliff Dr.: HawthorneDr. -Univ Close LoopEC: Lawrence PlaceMain RelocationEC: Univ Av: Ann St-Rock Hill Close LoopHillsdale PS -1.5 MgalGround Storage TankHinkson Main -Williamsto Old Hwy 63Hominy Branch: MainRelocationLoop Closure of 12 in.Mains S of Nifong BlvdMaguire -12 in. MainMain Adjustment-ForumBlvd Improvements10/1/2008 5/31/201210/1/2008 9/30/200910/1/2010 5/30/20123/17/2008 12/30/201010/1/2013 10/1/201410/1/2009 12/4/20104 to 6km 2.5 to 3.76 to 8km 3.7 to 56 to 8km 3.7 to 56 to 8 km6 to 8 km6 to 8 km3.7 to 53.7 to 53.7 to 5El-N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed lands and undisturbedlands. However, the impacts areanticipated to be limited and short-term.N Construction activity on previouslydisturbed land and some undisturbedlands. However, the impacts areanticipated to be limited and short-term.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.10/1/2008 10/1/2012 I to greater 0.6 tothan 8 km greaterthan 511/1/2008 10/30/2010 2 to4 km10/1/2018 10/1/20196 to greaterthan 8 km6 to greaterthan 8 km1.3 to 2.53.7 to 53.7 to 52.5 to 53.7 to 5Main Adjustment-Nifong 10/1/2018 10/1/2019Blvd ImprovementsN Section of 24 in. EastTransmission MainNC: Rangeline St &Smith St MainRelocation10/1/2008 9/25/2012 4 to 8km10/1/2008 9/30/2009 6 to 8 km19-245

• =',:"NWRE MEICAIOOENWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)m-II--Old Hwy 63 N &McAlester Loop ClosureProvidence Rd at StewartRd Close LoopQuail Drive -MainRelocationS Section of 24 in. EastTransmission MainStadium Crossing atAudubonThilly & Westmount6 in. Main -2.800 ftBingham Road -Phase I1-WT025410/1/2016 10/1/2017 6 to 8km10/1/2009 6/30/2012 6 to 8 km10/1/2011 12/30/2013 6 to 8km10/1/2009 12/1/2013 I to 6 kmb13.7 to 53.7 to 53.7 to 50.6 to 3.7El-.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands.N Construction activity on previouslydisturbed lands and undisturbedlands. However, the impacts areanticipated to be limited and short-term.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.10/1/2017 10/1/2018 6to8km 3.7 to 510/1/2013 10/1/2014 6to8km 3.7to510/1/2019 10/1/2020 6 to 8km3.7 to 5Discovery Parkway2014 2015 0Otol1km 0-0.6 miAudubon Dr S Sidewalk-Shepard Blvd-N AzaleaBallenger over 1-70:Clark to 740 ExtIRichlandBearfield Rd: ClearCreek-Gans RoadBearfield Rd; Nifong-Clear Creek10/I/2020 12/31/20214 to 6km 2.5 to 3.710/1/2009 12/31/2018 4 to 8km10/1/2013 12/29/2019 2to4km10/1/2013 12/31/2018 2to4km2.5 to 51.3 to 2.51.3 to 2.5Y Construction activity on previouslydisturbed and undisturbed lands.Could potentially have cumulativeeffects on land use, traffic, and waterresources.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.Broadway -Garth Ave to 4/10/2012 12/1/2015 6 to greater 3.7 to 5West Blvd than 8 km19-246 "NRTWESMEICAIOONWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)!I-3.7 to 53.7 to 5Broadway Sdwlk -McBaine-W Blvd. NSideBus Loop 70 Sidewalk-Rangeline to Rt BCarter Lane SidewalkClark Ln -Ballenger toSt. Charles RdClark Ln -WoodlandSprings Ct to BallengerCreekwood Prkwy-GldnBear Dr-Vandvr Dr10/1/1999 5/31/201010/1/2020 12/31/20216 to greaterthan 8 km6 to greaterthan 8 km6/6/2013 6/6/2013 4 to 6km 2.5 to 3.710/3/2005 12/31/2011 6 to 8km10/1/2013 10/1/2019 6 to 8km3.7 to 53.7 to 53.7 to 510/1/2020 12/29/20236 to greaterthan 8 kmDiscovery Parkway:Gans to New Haven12/29/20080Oto 4km 0Oto 2.5El-N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.Y Construction activity on previouslydisturbed and undisturbed lands.Could potentially have cumulativeeffects on land use, traffic, and waterresources.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.East Blvd -Bus Loop 70to Conley (TDD)10/1/2020 12/29/20236 to 8 km3.7 to 5East Side SidewalkPhase 1 StimulusEast Side Sidewalks -Phase 2 (CDBG)East side sidewalksPhase 3 (CDJBG)Elm Street ExtensionForum Blvd Sidewalk -Nifong to Mill CreekForum Blvd: ChapelHill to Woodrail (4-lane)11/3/2009 11I/3/201010/1/2009 10/1/201210/1/2010 10/1/20116 to 8km 3.7 to 56 to 8km 3.7 to 56 to 8 km10/3/2008 12/31/2014 6 to 8km10/1/2019 12/31/2021 6to8km3.7 to 53.7 to 53.7 to 54/16/2010 4/16/20106 to greater 3.7 tothan 8 km greaterthan 519-247

• eQ .NOSRTAY TTMED CALSOTOPESNWMI-2013-021, Rev. 0AChapter 19.0- Environmental ReviewTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)/IEhIIIIlh7/8/2011 7/8/2011 6 to greater 3.7 tothan 8 km greaterthan 5Forum Left turn lanes atM KT/VictoriaCans Rd: Interchange at63Cans Rd: Providence-Bearfld Rd10/3/2005 12/31/2008 0 to 2 km10/1/2020 12/29/2023 2 to 6 km10/1/2020 12/29/2023 2 to 6 km0Oto 1.3,1.3 to 3.71.3 to 3.7Gans Rd:Providnc-Bearfild Rd (4-LaneUpgrade)Cans Rd: U.S. 63Interchange-BearfieldCans Rd: U.S. 63Interchange-Bearfield(4-Lane Upgrade)Grace Ln. -Richland toStadium ExtensionHanover Blvd -OlympicBlvd to Rice RdHeriford Drive -ParkerSt to Route B10/1/2019 10/1/2020 1 to 4km 0.6 to 2.5El-.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.Y Construction activity on previouslydisturbed and undisturbed lands.Could potentially have cumulativeeffects on land use, traffic, and waterresources.Y Construction activity on previouslydisturbed and undisturbed lands.Could potentially have cumulativeeffects on land use, traffic, and waterresources.Y Construction activity on previouslydisturbed and undisturbed lands.Could potentially have cumulativeeffects on land use, traffic, and waterresources.Y Construction activity on previouslydisturbed and undisturbed lands.Could potentially have cumulativeeffects on land use, traffic, and waterresources.Y Construction activity on previouslydisturbed and undisturbed lands.Could potentially have cumulativeeffects on land use, traffic, and waterresources.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.Y Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.10/1/2020 12/29/2023 I to 4 km2/21/2018 2/21/2018 4to 8km10/1/2020 12/29/2023 6 to 8 km0.6 to 2.52.5 to 53.7 to 53.7 to 510/1/2020 12/29/20236 to greaterthan 8 kmHominy TrailConnection7/9/2013 7/9/2013 4 to 6km 2.5 to 3.7Jefferson CommonsPedestrian CrossingKeene Street: Broadwayto 1-70 Drive10/l/2002 3/31/2009 2 to 4 km3/18/2010 3/18/2010 4to 8km1.3 to 2.52.5 to 519-248 MEOICALIOTUPENWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewULake of thTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)*EIEIEEIEe Woods Rd. 10/1/2020 12/29/2023 6 to 8 km 3.7 to 5 N Construction activity Ud toand St Charles Rd.IntersectLake Ridgeway Dr -Clark Ln-Vandiver DrLandscaping Route ACLenoir Woods SidewalkMaguire -N to StadiumBlvd & Exit10/1/2020 12/29/2023 6 to 8 km10/1/2003 12/31/2009 2 to 6 km10/18/2013 10/18/2013 0to2km3.7 to 51.3 to 3.70Oto 1.3 mi10O/1/2001 12/31/20102 to 4km 1.3 to 2.5Maguire/Warren to New 7/I16/2008HavenMissouri TheatreSidewalk10/20/2009MM Maguire Blvd:Lemone to EmilyMM-Green MeadowsRd: Skylark Lane toOaklawn DriveMM-Royal LythamDrive:Glen Eagle Dr toChadwick DrMM-Santiago Drive:Granada Blvd to NifongBlvdNew Haven: Lemone toWarrenNifong -Providence toForum 4 LaneNifong: Forum to OldMill Creek Rd. (4-LaneUpgrade)Nifong-Bethel Sidewalk3/18/2010 3/18/20103/18/2010 3/18/20103/18/2010 3/18/20103/18/2010 3/18/20101lto 4km 0.6 to 2.56 to 8km 3.7 to 51lto 2km 0.6 tol1.36 to 8km 3.7 to 56 to 8km 3.7 to 54 to 6km 2.5 to 3.7previously disturbed lands at adistance from the RPF site.Y Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands.N Construction activity limited topreviously disturbed lands.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.Y Construction activity on previouslydisturbed and undisturbed lands.Could potentially have cumulativeeffects on land use, traffic, and waterresources.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.6/2/2009I to 2 km 0.6 to 1.3 N Construction activity limited topreviously disturbed lands.10/1/2010 12/29/2019 4to8km2.5 to 53.7 to 52/21/2026 2/21/20262/2 1/20 126 to greaterthan 8 kmN Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.4 to 8km 2.5 to 519-249 NWINWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)!I--2.5 to 53.7 to 5Old Plank Road -S. Providence to ForumBlvd.Old Route K Bridge overHinkson Creek10/1/2020 12/29/2023 4 to 8 km10/1/2007 9/8/2010 6 to 8kmEl..N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.Peachtree Connector and 10/20/2009Nifong Signal4 to 6 km 2.5 to 3.7 N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.Phillips Farm Rd -Southampton toPonderosaPonderosa TDD: Gansto Blue AcresProvidence and NifongBike LanesProvidence Corridor -Burnham Inter PHI1Providence Corridor -Burnham Inter PH12Rangeline -Wilkes toBusiness LoopRice Road -Hanover toBallenger LaneRichland -St. Charles toGraceRock Quarry Nifong toGans RoadRock Quarry RdSidewalk: StadiumBlvd-HinksonRock Quarry Rd -Grindstone Prkwy toStadium 9,400 ftRock Quarry Rd -Nifongto Grindstone Prkwy10/1/2020 12/29/2023 2 to 6 km10/1/2017 10/1/2017 0Oto 2km7/9/2013 7/9/20136 to greaterthan 8 km10/2/2006 12/31/2012 6 to 8km1/1/2020 12/31/2020 6 to 8km1.3 to 3.70Oto 1.33.7 to 53.7 to 5'3.7 to 53.7 to 53.7 to 52.5 to 3.71.3 to 2.52.5 to 3.71.3 to 3.7N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.Y Construction activity on previouslydisturbed and undisturbed lands.Could potentially have cumulativeeffects on land use, traffic, and waterresources.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands.N Construction activity limited topreviously disturbed lands.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands.7/16/20086 to greaterthan 8 km6 to greaterthan 8 km2/17/2020 2/17/202310/1/2012 12/29/2018 4to6km6/30/1998 12/30/2023 2 to 4 km10/1/2020 12/31/2021 4 to 6km10/1/2009 12/29/2015 2 to 6 km10/1/1999 12/29/2023 2to4km 1.3to2.519-250

" "l..a"" ORTWESTMEDCALI$OOPESNWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages):LI2 to 4km 1. ~to 2.5Rolling Hills -CountyProject: New Haven toWWRolling Hills Road(4-Lane)Rolling Hills Road- OldHawthorn to Richland3/6/200910/1/2020 12/29/2023 2 to 4 km10/2/2006 12/31/2012 4to6km1.3 to 2.52.5 to 3.7Rustic Road3/19/2010 3/19/20102 to 4km 1.3 to 2.5Shepard Blvd Sidewalk -Old 63 to Danforth10/1/2020 12/31/20214 to 6km 2.5 to 3.76 to 8km 3.7 to 5Short Street GarageTraffic Mitigation9/26/2011Southampton Dr -Sinclair to 1000 ftEastwardSouth Hampton Dr -U.S. Hwy 163-RouteSt Charles Road -Keeneto Richland RdStadium at Old 63IntersectionStadium Extension Eastto 1-70Traffic Islands -Old 63and Broadway10/1/2020 12/29/20236 to greaterthan 8 km10/1/2004 3/31/2008 4 to 6 km10/1/2011 12/29/2017 4 to 8km10/1/2004 11/28/2012 4to6km10/1/2007 12/31/2010 4to8km10/1/2004 11/30/2009 6 to 8 km3.7 to 52.5 to 3.72.5 to 52.5 to 3.72.5 to 53.7 to 5II-!N Construction activity limited topreviously disturbed lands.N Construction activity limited topreviously disturbed lands.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.West Broadway Corridor 3/1/2007 2/8/20 106 to greaterthan 8 km3.7 to 53.7 to 5Williams Street withWilliams -BroadwayIntersection lmprv7/16/2008 12/15/2010 6to8km19-25 1 NWI* , ,NoR'rWESTMED CA SOTOPESNWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)!I--2.5 to 5El..N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.Woodridge Dr -St Charles Rd toTerminus10/1/2020 10/31/2023 4 to 8kmHinkson Cr Tr Stadium -Rockhill Ph II11/9/2008 3/31/20104 to 6km 2.5 to 3.7N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.Hominy Branch Trail:Stephens -WoodridgePhase 18/16/2011 6/8/20124 to 6km 2.5 to 3.7B-8 Relief Sewer -Rangeline & Vandiver10/1/2019 1 0/1/20216 to greater 3.7 to 5than 8 kmC-5 Trunk Relief Swr -Rock Quarry: Nifong-ZoeCalvert Drive SewerRelocationDouglass High SchoolSewer RelocationFlat Branch WatershedRelief Sewers10/1/2019 10/1/2021 2 to 4km 1.3 to2.52/11/2013 2/11/20136 to greaterthan 8 km3.7 to 52/17/2012 2/17/2012 4 to 6km 2.5 to 3.7N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.NConstruction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.10/1/2016 1 1/15/20186 to greaterthan 8 km3.7 to 5Hinkson Creek OutfallReplacement11/18/2010 1/27/2012 6to8 km 3.7 to 5Hominy Branch OutfallExt: LOW Rd-MxcoGrvl10/1/2020 1/1/2023 6 to greater 3.7 to 5than 8 km19-252 NWINWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)!1I-Im2.5 to 5Hominy Branch Outfall 10/1/2008 12/1/2010 4 to 8 kmRelief SewerNorth Grindstone CreekBank Stabilization2/20/2012 2/20/20124 to 6km 2.5 to 3.7North Grindstone Outfall 4/23/2008Extension Phase I6 to 8km 3.7 to 5North Grindstone OutfallExtension Phase IIPCCE # 6: 5 CountryClub Dr AreaPCCE #8: ThillyLathropPCCE #11: WilsonStreet / High StreetPCCE #14: Cliff DrivePCCE #16: Binghamn Rd& West Ridgeley RdPCCE #17: WilsonStreetlRoss StreetPCCE #24: St. Jamesand St. JosephPCCE #25: Glen woodand RedbudSewer District -Hillcreek Road10/1/20081/1/2011 6 to greaterthan 8 km3.7 to 58/1/2008 1/15/2011 6 to 8km 3.7 to 52/9/2010 11/1/2012 6to8km 3.7 to5El!N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However. dfie to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.5/7/20104 to 8km 2.5 to 51/27/2011 1/27/2011 4 to 6km 2.5 to 3.71/27/2011 1/27/20115/7/20 1010/1/2018 9/30/201910/1/2018 9/30/20191/27/2020 1/27/20226 to 8km 3.7 to 56 to 8km 3.7 to 54 to 6km 2.5 to 3.74 to 6km 2.5 to 3.76 to 8km 3.7 to 519-253

• "... 'NRTWETMEICAIOOENWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)ml-mSewer District # 170 -S. Bethel Church RoadSexton Road ReliefSewerStephens Park SewerRelocationWestwood AvenueSewer Relocation1/1/2011 12/31/2012 4to8km2.5 to 53.7 to 52.5 to 5;8/1/2018 8/1/20206 to greaterthan 8 kmiII-N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.10/1/2014 12/15/2016 4 to 8km2/17/2012 2/17/20126 to 8km 3.7 to 52 to 4km 1.3 to 2.5W5toods~b'toc"H WP22021 /0212302 Business 70 East1/28/2025 1/28/20266 to 8 km3.7 to 51Alan LaneAsh & HubbleCalvert Drive10/1/2019 10/1/202110/1/2012 9/30/20131/30/2013 1/30/20136 to 8 km6 to 8 km6 to greaterthan 8 km3.7 to 53.7 to 5;3.7 to 5N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.East DowntownEighth Street DrainageC49084Grasslands-BrandonDrainageGreenwood South1/30/2013 1/30/2013 6 to 8km4/18/2007 4/18/2007 6 to 8 km3.7 to 53.7 to 510/1/2020 10/1/20231/30/2013 1/30/20136 to 8km 3.7 to56 to greaterthan 8 km3.7 to 519-254

'; NWMINWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)I9-.3.7 to 5Hickman and 6th and 7th 1/30/20 13 1/30/2013 6 to 8 kmHinkson AvenueHinkson Cr Trail:Grindstone-StephensPhase IHinkson Cr Trail:Grindstone-StephensPhase 11Hinkson Creek Trail:Stephens to VandiverPedwayHitt and Elm C49099Kelly Detention RetrofitLawrence PlaceMill Creek Phase 3C49 111MKT BridgeImprovements Phase Ii10/1/2020 10/1/2023 6 to 8km3.7 to 52/22/2010 12/31/2011 4to6km 2.5to3.72/22/2010 12/31/201110/1/2018 12/31/20204to6km 2.5 to3.76 to greaterthan 8 km3.7 to 51/28/2011 1/28/20114/14/2011 4/14/201110/1/2007 5/1/20091/30/2013 1/30/20131/1/2017 1/1/20186 to 8km 3.7 to 54 to 6km 2.5 to 3.76 to 8km 3.7 to 54 to 6km 2.5 to 3.7II.!.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed land and undisturbed lands.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.6 to greaterthan 8 km3.7 to 5Nifong and BethelDrainage Project10/15/2014 2/1/20154to6km 2.5to3.7Old Plank StormDrainage -South Side10/1/2019 6/1/2022 6 to 8km 3.7 to 519-255 NMI* .,, .NORTHWVEST MEDICA ISOTOPESNWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)IHuh/III10/I/2028 10/1/12029 4 to 6km 2.5 to 3.7Peachtree Water QualityBasinPear Tree Circle StormDrainagePhilips Lake Connector:Nifong to GCRARangeline Street SmithStreet10/1/2025 10/1/2026 6to8 km10/1/2025 10/1/2026 1 to 4km1/9/2025 1/9/2026 6 to greaterthan 8 km10/1/2017 11/1/2018 6 to 8km10/1/2007 7/1/2010 6 to 8km3.7 to 50.6 to 2.5Rockhill Rd3.7 to 53.7 to 53.7 to 5Royal Lytham -FallwoodSeventh and LocustStewart Park DrainageVandiver/Sylvan StormDrainageEl-N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.Y Construction activity on previouslydisturbed land and undisturbed lands.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.1/28/2016 1/28/2017 6 to 8km 3.7 to 510/1/2016 12/31/2018 6to8km10/1/2014 10/1/2015 6 to greaterthan 8 km3.7 to 53.7 to Wayne RoadWilson Ross10/1/2020 11/1/2023 6 to 8km 3.7 to 51/30/2013 1/30/2013 4 to 8km 2.5 to 5American Legion Park:Shelter. Restrooms,PlaygroundAmerican LegionRenovation -Phase I10/1/2016 10/1/2017 4 to 6km10/1/2009 12/31/2011 4to6km2.5 to 3.7/2.5 to 3.7N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.19-256 NWM INWMI-2013-021, Rev. 0AChapter 19.0- Environmental ReviewTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)II10.6-1.3Aquatic Facility10/1/2017 5/3/2019 1 to 2kmCOLT Railroad TrailPhase I: ColumbiaCollege to VandiverCosmo-Bethel FourCourt Tennis ComplexDouglass ParkImprovements: SecurityDouglass Park:Amphitheater and ShelterDouglass Park:Multipurpose BuildingEastport NeighboredPark Develop10/1/2018 10/1/2020 4 to greater 2.5Stothan 8 km greaterthan 51/7/2008 10/30/2009 4 to 6 km2/24/2012 12/31/1969 6to8km10/1/2013 12/31/2014 6 to8km10/1/2020 12/31/2023 6 to 8 km2.5 to 3.73.7 to 53.7 to 53.7 to 5Eml-Y Construction activity on undisturbedlands. Could potentially havecumulative effects on land use andwater resources.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity limited topreviously disturbed lands.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.Y Construction activity on undisturbedlands. Could potentially havecumulative effects on land use andwater resources.10/1/2007 12/31/20104 to greater 2.5 tothan 8 km greaterthan 5Flat Branch Park -Phase IIGrasslandsNeighborhood ParkDevelopmentGrasslands ParkAcquisitionHinkson Creek -Grindstone TrailheadRestroom10/1/2001 5/5/2009 6 to 8 km10/1/2007 12/31/2009 6 to 8 km9/2/2002 2/28/2003 6 to 8 km3.7 to 53.7 to 53.7 to 510/1/2012 12/31/2014 4to6km 2.5to3.719-257

• =. 4 ORIT1WEST MEIAL SOTOPESNWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)I-lH-ominy Creek Trail:Old 63 to Green ValleyLake of the Woods GolfCourse New RestroomMKT Trail: NewRestroom at Flat BranchParkNifong Park: CoveredTractor and ImplementStructureNifong Park:Maplewood Barn/Home& ParkingNifong Restroom andBuildingsPaquin ParkImprovement-Phase Ill -Raised BedsPhilips/Gans: ParkDevelopment Phase I1Philips/Gans: IceSkating Facility -OutdoorPhilips/Gans: IndoorPavilion/ShelterPhilips/Gans: IndoorSports Center -GymRock Quarry ParkTennis/BasketballSouth Regional Park -Gans/Philips Phase ISouth Regional Park -Philips Phase ISouth Regional ParkAcquisitionSouth Regional ParkDevelopment -Phase IStephens Lake ParkDevelopment -Phase I2/1/2019 2/1/2021 4 to 6km1/19/2006 7/30/2009 6 to 8 km-2.5 to 3.73.7 to 5El.!N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.Y Construction activity on undisturbedlands. Could potentially havecumulative effects on land use andwater resources.N Construction activity limited topreviously disturbed lands at adistance from the RPF site.N Construction activity on previouslydisturbed land.Y Construction activity on previouslydisturbed land and undisturbed lands.10/1/2016 12/31/201710/1/2016 12/31/201710/1/2011 12/31/201310/2/2006 1 /1/200910/l/2009 12/31/201010/1/201610/3/2016 12/31/201810/3/2016 10/3/201810/1/2016 10/l/201810/1/2008 4/1/201110/1/2012 12/31/201510/2/2006 6/1/20103/19/2007 1 1/2/200910/1/2009 12/31/20125/18/2000 12/31/20106 to 8km 3.7 to 51lto 4km 0.6 to 2.51 to 4km 0.6 to 2.51 to 2 km 0.6-1.3 Y Construction activity on undisturbedlands.6 to 8 km 3.7 to 5 N Construction activity limited topreviously disturbed lands at adistance from the RPF site.I to 4 km 0.6 to 2.5 Y Construction activity on previouslydisturbed land and undisturbed lands.I to 2 km 0.6-1.3 Y Construction activity on undisturbedlands.1 to 4km 0.6 to 2.51Ito 2km 0.6-1.32 to 4km 1.3 to 2.51lto 4km 0.6 to 2.51Ito 2km 0.6-1.31 to 4km 0.6 to 2.51to 4km 0.6 to 2.54 to 8km 2.5 to 5Y Construction activity on previouslydisturbed land and undisturbed lands.Y Construction activity on undisturbedlands.Y Construction activity on previouslydisturbed land and undisturbed lands.Y Construction activity on previouslydisturbed land and undisturbed lands.Y Construction activity on previouslydisturbed land and undisturbed lands.Y Construction activity on previouslydisturbed land and undisturbed lands.Y Construction activity on previouslydisturbed land and undisturbed lands.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.19-258

• W INWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-86. Past, Present, and Reasonably Foreseeable Future Actions (19 pages)I---JStephens Lake Park:E. Walnut DevelopmentWaters-Moss DevelopPhase 11: Waters andJones BuildingsWaters-Moss Park:Phase I Development10/1/2016 12/31/2017 6to 8km10/1/2015 12/31/2016 2 to 6km3.7 to 51.3 to 3.7N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.N Construction activity on previouslydisturbed lands and undisturbedlands. However, due to the distancefrom the RPF site, no cumulativeeffects are anticipated.10/1/2012 10/1/2015 2 to 6km 1.3 to3.7CDBGGCRAMHPMURRPCCE= Community Development Block Grant.= Gans Creek Recreation Area.= mobile home park.= University of Missouri Research Reactor.= private common collector elimination.RPFSLATDDWWTPradioisotope production facility.street light addition.Transportation Development District.wastewater treatment plant.19.4.14.3 Summary of Cumulative Impacts19.4.14.3.1 Land Use and Visual ResourcesAs discussed in Section 19.4.1.1, proposed RPF construction, operation, and decommissioning impacts onland use and visual resources are small. Relevant other projects to be considered for cumulative impactsinclude the construction of Discovery Parkway and other Discovery Ridge facilities.19.4.14.3.1.1 Land UseDiscovery Ridge (the proposed site for the RPF) occupies 505 ha (1,250 acres), within which there arepresently two existing facilities. The remaining land is either fallow or being used for agriculturalpurposes. The RPF would change current fallow land to a more industrial use; however, the land-usedesignations would not be changed with the construction and operation of the facility. The 505 ha(1,250 acres) would be anticipated to be converted to industrial use over time, and there would be a minorloss of agricultural lands.The Odles' Discovery Park, Aspen Heights, Grove, and Den developments would also impact land use.None of these lands are prime farmland, and the loss of crop production is a minor impact whencompared to the amount of agricultural land in the ROI. Therefore, cumulative impacts to land useresources, including agricultural resources, are small.19.4.14.3.1.2 Visual ResourcesThe cumulative impacts to the visual or scenic quality of the proposed RPF were assessed byexamining the proposed actions associated with construction of the facility and the development ofsurrounding properties. The RPF would abide by the Discovety Ridge Master Plan and Covenants(MU, 2009) to ensure that the visual impact is compatible with the character of the development.19-259 N MISOOE Chpe WMI,_013-_o Rev. 0Alv..-i.......... Chpe9.0- Environmental ReviewUnder ideal conditions with no interferences from vegetation, the exhaust stacks may be visible from upto a distance of approximately 3.2 km (2 mi). However, this visual impact would be small. Byconsidering both proposed on-site and nearby existing developments, modification to the proposed sitewould result in small visual impacts. Therefore, cumulative impacts would be small on the visual/scenicquality of the proposed RPF site.19.4.14.3.2 Air Quality and Noise19.4.14.3.2.1 Air QualityThe cumulative impacts to the air quality resulting from the proposed RPF were assessed by examiningthe proposed actions associated with construction and operation of the facility and the development ofsurrounding properties. The road, water, power, and sewer projects in the area may have temporaryeffects on air quality, but are likely to be short-term. Therefore, the cumulative impacts on the air qualityof the proposed site would be small. Other sources in the area, when combined with the RPF, would beunlikely to result in significant cumulative impacts. The cumulative impact to the regional air qualitywould be small.19.4.14.3.2.2 NoiseCumulative noise sources would include the proposed RPF, existing traffic along U.S. Highway 63 andDiscovery Parkway, operations at the ABC Laboratories and RADIL facilities, the Odles' Discovery Parkdevelopment, and farm and ranch operations. Road construction projects in the area (e.g., DiscoveryParkway) would also result in a temporary increase in noise, as would RPF construction. Impacts fromall noise sources at the RPF during operation would generally remain at or below Discovery Ridge MasterPlan and Protective Covenants (MU, 2009) and the Columbia Code of Ordinance (City of Columbia,2013b) requirements. Therefore, cumulative noise impacts from the RPF would be small.19.4.14.3.3 Geologic EnvironmentAs discussed in Section 19.4.3, RPF construction and operation impacts on the geologic environmentwould be small. The cumulative impacts to the geologic resources would be similar to the direct andindirect impacts of the facility and those associated with the current land use. RPF construction wouldresult in limited soil erosion, which would be minimized using BMPs. The proposed construction of theDiscovery Parkway adjacent to the RPF and the Odles' Discovery Park development would have similarshort-term impacts that are anticipated to be mitigated with BMPs. Therefore, cumulative geologicimpacts would be small.19.4.14.3.3.1 Water ResourcesThe proposed RPF would not extract groundwater, and there would be no liquid discharge from thefacility. Stormwater runoff from the facility would be discharged to lined, engineered basins. The proposedconstruction of the Discovery Parkway adjacent to the RPF and the Odles' Discovery Park developmentwould be required to follow similar requirements for stormwater. As a result, no significant effects onnatural water systems are anticipated, and the cumulative impact to water resources would be small.19.4.14.3.4 Ecological ResourcesAs discussed in Section 19.4.5, impacts from the construction, operation, and decommissioning of theRPF on terrestrial and aquatic ecosystems, including protected species, is small. The historical andcurrent use of the proposed site limits the available resources for flora and fauna species. The potentialfor impacts from stormwater runoff are limited because there is no aquatic environment located on thesite, and stormwater retention systems would be in place. Therefore, potential cumulative impacts toecological resources are small.19-260 IIVYChapter 9.0 -Environmental Review* e.,.*NORThTWEST MEDICAL ISOTOPES19.4.14.3.5 Historical and Cultural ResourcesAs noted in Section 19.4.6, there were no cultural resources located on the proposed RPF site. Thenearest listed NRHP property is the Maplewood House located approximately 1.6 km (1 mi) northwest ofthe site. No direct impacts would occur to this property by either construction or operational activities ofthe proposed RPF. Other off-site development actions could potentially result in direct or indirectimpacts to NRHP-listed or -eligible historic or archaeological resources. Federal- and State-fundedprojects with such potential impacts on historic resources would require coordination with the SHPO,documentation, and mitigation measures, if warranted. Therefore, potential cumulative impacts tohistoric and archaeological resources are small.19.4.14.3.6 SocioeconomnicsLabor force and population -A number of other development projects have been proposed in BooneCounty that could have cumulative effects with the proposed RPF, depending on their scope andschedules for development. These projects would provide additional employment opportunities forconstruction workers and would increase the economic activity in the region. In addition to the roadprojects, the MU East Campus Chilled Water Plant, the addition to MU Memorial Stadium, the Odles"Discovery Park development, and the Columbia Regional Airport expansion all have the potential toincrease economic activity in the region. The labor pool in the area is considered large enough thatpotential competition is not likely to lead to increased labor rates or require additional housing needs orpublic services. Thus, the cumulative socioeconomic impacts of these projects are expected to be small.Utilities -Discovery Ridge utility service, including power, water, and sewage, has been designed toservice the anticipated future tenants. No additional upgrades would be required. The cumulativeimpacts of these projects on utilities are expected to be small.Tax base -The development of Discovery Ridge would increase the property values specific to the siteand increase the local tax base. The RPF, if built at the Discovery Ridge site, would result in new, well-paying jobs. These jobs would also contribute to the tax base in the area. The overall tax revenues wouldbe positive, but based on the overall tax base, the effects are anticipated to be small.Transportation -No modifications to the local traffic infrastructure are necessary to support theconstruction and operation of the proposed RPF. The construction and occupation of the Odles'Discovery Park, Aspen Heights, Grove, and Den developments would likely increase traffic in the generalarea. However, the construction of Discovery Parkway and the other local road projects is designed toaccommodate the increase in traffic associated with these projects. Therefore, cumulative effects totransportation infrastructure and traffic patterns are small.19.4.14.3.7 Human HealthNonradiological impacts -Construction of the RPF and the other construction projects consideredinclude potential hazards to workers typical of any construction site. Normal construction safety practiceswould be employed to promote worker safety and reduce the likelihood of worker injury duringconstruction.Potential nonradiological public and occupational hazards pertaining to the operation of the RPF, theexpansion of the Columbia Regional Airport, and the Odles' Discovery Park, Aspen Heights, Grove, andDen developments include emissions, discharges, and waste associated with the facilities and potentialaccidental spills/releases. Most of the chemical processes at the RPF would be conducted inside of thefacility, limiting the potential effects on the public. Any wastes would be disposed offsite. The RPFwould implement spill prevention/controls and air emission controls, as appropriate. The cumulativenonradiological health impacts are anticipated to be small.19-26 1 WKCatr1NWMI Rev. OAlviChptr 9.0 -Environmental Review* .. ..NORI$TWEST MEDICAL ISOTOPESRadiological impacts -Operation of the RPF would result in releases of small quantities of radionuclidesto the environment. Gaseous effluent activity releases are discussed in Section 19.4.8.2.4. Direct dose toa member of the public at the fence line is due to gamma radiation penetrating the walls of the productionfacility and the waste staging and shipping facility. With the site shielding design, the direct dose outsideof the buildings is small and decreases with increasing distance. The fence line is located at anappreciable distance from the two fixed sources of radiation (production facility building and wastestaging and shipping building); therefore, the dose is negligible at the fence line.19.4.14.3.8 Environmental JusticeNo present or ongoing environmental justice actions were identified that are relevant to this analysis.Disproportionate impacts on low-income or minority populations from other actions are not expected. Itis not anticipated that there would be any cumulative impacts on low-income or minority groups fromconstruction and operation of the RPF. The cumulative impacts associated with environmental justice areconsidered small.19-262 NOhWSTMEIl I hpe NWMI-2013-021, Rev. GAIIVVChapter19.0 -Environmental Review19.5 ALTERNATIVESNWMI proposed to establish, as soon as practicable, a domestic capability to produce a continuous supplyof 99Mo for the U.S. medical community. The purpose of the proposed action is to ensure a reliabledomestic supply of 99Mo, the most widely used medical isotope worldwide. This section describes thealternatives considered for the production of 99Mo. To determine the reasonable alternatives, NWMIidentified specific criteria (e.g., facility, location, regulatory) necessary to satisfy the purpose of, and needfor, the proposed action.19.5.1 The No-Action AlternativeThe current demand for 99mTc in the U.S. requires a weekly supply of approximately 6,000 six-day Ci of99Mo, approximately 50 percent of the annual U.S. demand. The U.S. supply of 99Mo is currentlyimported. Under the No-Action Alternative, the U.S. medical community would continue to rely on thissource of supply and a domestic supply of 99M0 would not be established. The U.S. Government hasestablished a policy to encourage the domestic production of medical isotopes (Senate Bi11-99). The RPFwould provide a significant contribution toward advancing this policy. Under the No-Action Alternative,this benefit would not be realized.Accordingly, the Discovery Ridge property, the site of the proposed RPF, would not be constructed oroperated. The environmental consequences of the No-Action Alternative are assumed to be the statusquo, and the consequences discussed in Section 19.4 would be circumvented. In the absence of NRCapproval of the RPF license, 99Mo customers would be required to meet their isotope needs through theexisting supply chain that does not include any U.S. producers.19.5.2 Reasonable Alternatives19.5.2.1 Site AlternativesNWMI identified three alternatives for siting the RPF in addition to Discovery Ridge. Each of these threesites is located next to an existing university nuclear research reactor. The siting study of proposed sitelocations next to university reactors included the following (NWMI-2013-002, Site Selection:Radioisotope Production Facilit,):* University of Missouri Research Reactor (MURR) -Columbia, Missouri* Oregon State University TRIGA Reactor (OSTR) -Corvallis, Oregon* McClellan Business Park (McClellan) -Davis, CaliforniaThese proposed sites are described in the following subsections.19.5.2.1.1 University of Missouri, Adjacent to the University of Missouri Research ReactorThis site is adjacent to MURR on the MU campus, near existing buildings on a partially paved parkinglot. MURR is located near Highway 70, just off the MU main campus. No current roadway weight andheight restrictions exist, and the roadways are sufficient for transport of radioactive materials and waste.MU added the stipulation that university personnel operate and staff the RPF at this location.19.5.2.1.2 Oregon State University, Adjacent to the University Oregon State TRIGA ReactorThis site is next to OSU Radiation Center where the OSTR is located, approximately 129 km (80 mi)south of Portland, Oregon, in an area that includes a partially paved parking lot and a small number ofexisting laboratory buildings. The site is immediately east of the university reactor on an area coveringapproximately 1.21 ha (3 acres). Relocation of several buildings and rerouting of transportation routeswould be required.19-263 I* , * .o. ,, , NO--ST MI[fllCAL ISOTOPIE$NWMI-2013-021, Rev. 0AChapter 19.0 -Environmental Review19.5.2.1.3 McClellan Business ParkThis site is near the UC Davis McClellan Nuclear Research Center (MNRC), located off the UC Daviscampus at McClellan Business Park, 16 m (10 mi) northeast of Sacramento, California, and near theU.S. Interstate 5 corridor. McClellan Air Force Base was closed in 1995 and privatized, creating theMcClellan Business Park. The site includes a 4,181 m2 (45,000 ft2) clear span and high-bay buildingapproximately 61 m (200 ft) from MNRC.19.5.2.2 ScreeningTo determine the preferred site, a Simple Multi-Attribute Rating Technique (SMART) decision analysismethodology was used. The methodology is based on DOE Guidebook to Decision-Making Methods(DOE, 2001). NWMI developed the site-specific scoring criteria used in this evaluation. Site selectioncriteria were developed through discussions between NWMI and its subcontractors. A summary of thesiting criteria, description, and ranking is provided in Table 19-87. The criteria were weighted from i to10 based on importance to NWMI.Table 19-87. Summary of Site-Specific Scoring Criteria (2 pages)Political and locallogistics supportAbility of NWMI to leverage connections for local logisticalsupport, based on regional politics and importance of project toeconomic development10Production logisticsNumber of 6-day Ci processed and delivered to distributor10Radioactive, hazardous, Site ability to meet Federal, State, and local requirements and 8and mixed secondary availability of waste disposition pathwaywaste generation (i.e., air,liquids, solids)Federal and State taxesand incentivesIncludes costs associated with sales tax, property tax, corporateincome tax, hiring credits, etc. Criteria does not include RPFownership and lease terms; these would be dealt with by NWMIseparately3Construction costs Site-specific cost estimates; variations in labor rates and materials; 2and construction indices19-264

,l..:vi....... Chpe9.0- Environmental ReviewTable 19-87. Summary of Site-Specific Scoring Criteria (2 pages)-I- .eTotal Weight 60a NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-PowerReactors -Format and Content, Part 1, U.S. Nuclear Regulatory Commission, Office of Nuclear ReactorRegulation, Washington, D.C., February 1996.FEMA = Federal Emergency Management Agency. NWMI = Northwest Medical Isotopes, LLC.NRC = U.S. Nuclear Regulatory Commission. RPF = radioisotope production facility.The following describe the priority and weighting criteria:Political and local logistics support (Weight 10) -NWMI's ability to leverage connections for localsupport is dependent on regional politics and the importance of the project to local economic developmentefforts. This support will play a large role in the financial success of the company. For this reason,political and local logistics support was given the highest weight.Facility operations (Weight 10) -This criterion consists of management and operation of the facility,including staff (i.e., would NWMI have sole responsibility for operations, or would the university beinvolved?). NWMI prefers to directly staff and operate the production facility, rather than have thefacility operated by the university, but some limited involvement by the university reactor faculty couldbe beneficial.Production logistics (Weight 10) -This criterion consists of the number of 6-day Ci processed anddelivered to the distributor, based on time to transport between reactors and processing facility. Due tothe short half-lives of 99VMo (66 hr) and 99(6 hr), the transport time plays a critical role in the amountof product delivered to the end client. Product is shipped between all three facilities regardless of theselected production location, but total transit time for irradiated targets returning to the production facilityaffects the final product significantly.Transportation (Weight 8) -The costs of transporting nuclear material and potential inclement weatherimpact timely transport of both irradiated targets from university research reactors and delivery ofthe 99Mo to the distributor.Radioactive, hazardous, and mixed secondary waste generation (Weight 8) -The selected RPF sitemust comply with Federal, State, and local radioactive and hazardous waste requirements for wastegeneration and have a suitable waste disposition pathway.Federal, State, county, and local requirements to construct and operate facility (Weight 5) -Thiscriterion considers the required NRC licensing (NUREG-1537) and State, county, and local environmentalpermitting (e.g., air, water). Because of the proximity to existing reactors, no site is expected to faceinsurmountable permitting or licensing challenges, but differences between sites could lead to delays inbeginning operations.Federal and State taxes and incentives (Weight 3) -Taxes (including sales tax on equipment andconstruction materials, property tax, and corporate income tax), employment hiring credits, and incentivesare not expected to be strong differentiators between locations, but differences could affect the cost ofconstruction, equipment, and operations. Taxes and incentives were given a low weight.19-265

"'-NWMI! Chapter 190 niomna Review*, .. SAvailable space (Weight 3) -This criterion considers the available space for the production facility(without increasing the complexity of the facility design and construction costs) and suitability for futureexpansion (e.g., boutique isotopes, education, research, and development). All sites have the minimumamount of space required for the production facility, but differences in available space could impact thecomplexity of facility design (leading to operational complexities), differences in cost of construction,and ability to expand the production facility in the future.Construction costs (Weight 2) -This criterion considers site-specific cost variations and constructioncost indices for each location (using RSMeans4). Local labor rates, materials costs, and current sitecondition could affect the cost of construction at each site.Natural or human-made disaster potential (Weight 1) -This criterion is based on Federal EmergencyManagement Agency (FEMA) disaster declarations and USGS seismic activity predictions. Because eachsite is adjacent to an existing reactor, the disaster potential was considered a less significant differentiatorand given the lowest weight.Based on the siting criteria established and using readily available public information and observationsfrom site visits, the sites were scored using a scale of 1 to 5 (5 being most favorable, 1 being least). TheNWMI team determined that all four of the sites are viable and acceptable, with Discovery Ridge selectedas the preferred site of the proposed RPF (see Table 19-88).Table 19-88. Evaluation of Alternative SitesPolitical and local logistics support 4 40 4 40 4 40 1 104...40 4 40 3 30 3 3Production logistics 4 40 2 20 3 30 3 30Radioactive, hazardous, and mixed 4 32 4 32 4 32 3 24secondary waste generation (i.e., air,liquids, solids)Federal and State taxes and incentives 5 15 5 15 3 9 1 3Avials e5 15 3 9 1 3Construction costs 4 8 4 8 3 6 3 6Total 245 219 190 145DR = Discovery Ridge. MURR = University of Missouri Research Reactor.MNRC = McClellan Nuclear Research Center. OSTR = Oregon State University TRIGA Reactor.The Discovery Ridge site total weighted score of 82 percent was followed by the MURR location. Giventhe high weighting of certain criteria (i.e., political and local logistical support, facility operations, andproduction logistics) and high scores for these criteria, the MURR and Discovery Ridge sites have anadvantage over both the proposed McClellan Business Park and OSTR sites.4 RSMeans is a trademark R.S. Means Company, LLC, Kingston, Massachusetts.19-266

.:, .IAIM':.NWMI-2013-021, Rev. OA'"" ,"Chapter 19.0 -Environmental ReviewThe proposed site at the McClellan Business Park ranks fourth for the RPF location. The McClellanBusiness Park score was 34 percentage points lower than the Discovery Ridge site, primarily due to a lackof political and local support, Federal and state taxes and incentives, limited available greenfield space,and weaker ties to the UC Davis reactor team. However, the site's strengths include an existing buildingand abundant available space. The OSTR site, which ranked third, had limited available space,transportation routes and State and local financial incentives.In consideration of these factors, the Discovery Ridge site was selected as the proposed site for the RPF.The siting alternatives of the MNRC Business Park and OSTR locations were not further evaluated. TheMURR site was considered to be viable and was identified as a reasonable alternative; its evaluation isprovided in the following subsections.19.5.2.3 University of Missouri Research Reactor Site Evaluation19.5.2.3.1 Site DescriptionThe MURR site is located in Columbia, Missouri, approximately 201 km (125 mi) east of Kansas Cityand 201 km (125 mi) west of St Louis. The site is 2.4 km (1.5 mi) south of U.S. Interstate 70, just west ofResearch Park Drive. The Missouri River lies 13.6 km (8.5 mi) west of the site. The site is located6.4 km (4 mi) northwest of the Discovery Ridge site.The site is located directly to the south of the existing reactor building on a partially paved parking lot.Access to the site is provided from Research Park Drive and South Providence Road. The site is 1.6 km(1 mi) southwest of the main MU campus. The site's latitude and longitude is 380 55' 53" north and920 20' 31" west.The MURR site is situated on a 3.0 ha (7.4-acre) lot in the central portion of the University ResearchPark, a 34.0 ha (84-acre) tract of land approximately 1.6 km (1 mi) southwest of the MU main campus.The campus is situated in the southern portion of Columbia. The University Research Park consists oflow-occupancy research buildings. Personnel are currently working in facilities located within 457.2 m(1,500 ft) of the alternative site.The site's 8 km (5-mi) radius encompasses nearly the entire City of Columbia and parts of the outlyingmetropolitan area. The nearest permanent residence is located approximately 762 m (2,500 ft) north ofthe reactor facility near Stadium Boulevard (State Highway 740) on Brandon Road.Existing land uses within each concentric ring can generally be described as follows:*0-1 km (0-0.06 mi) -There is very little residential development within 1 km (0.06 mi) of theMURR site. Most of the land is owned by MU. Recreational areas include a golf course to thewest and a park to the south. There are three major University sports venues located in this area:Memorial Stadium/Faurot Field (62,000 seats), Mizzou Arena (15,061 seats), and Heamnes Center(13,300 seats).* 1-2 km (0.6-1.3 mi) -Major residential areas are located north, northwest, and south of theproposed RPF site. A shopping center, business district, two hospitals, and a large portion ofMU's main campus are located within this area. With the exception of a small area to thesoutheast, there is no room for any substantial residential or nonresidential (industrial,commercial, or business) development.19-267 N MEIA Isao~ hpe NWMI-2013-021, Rev. 0A* .. Chapter 1vi9.0 -Environmental Review2--4 km (1.3-2.5 mi) -The major residential areas are located in the northern half of the ROI andto the southwest. A shopping center, business district, two hospitals, two colleges, three highschools, three middle/junior high schools, and nine elementary schools are located in this area.Recreational areas include two golf courses and eight parks. The downtown area of Columbia,which consists mainly of government offices and retail, commercial, and business uses, is locatedto the northeast. Development should continue within this area, most likely south of the reactorfacility.*4-6 km (2.5-3.7 mi) -Most residential development is within the northern half of the ROI.Three shopping centers, two hospitals, one middle/junior high school, three elementary schools,and an industrial park are located in this area. Recreational areas include two golf courses andfive parks. Substantial amounts of land exist for residential or commercial development.*6-8 km (3.7-5 mi) -The only substantial residential development is northeast of the proposedRPF site. A shopping center, two middle/junior high schools, and four elementary schools arelocated in this area. Recreational areas include one park. Substantial amounts of land presentlyexist for residential or commercial development.19.5.2.3.2 Land Use and Visual ResourcesThe MURR site is currently used for industrial purposes and would remain as such if the RPF wasconstructed at that location. Construction of the RPF is not anticipated to threaten any important land useresources; therefore, the land use impact due to project construction would be small. Similarly duringoperation of the RPF, land use impacts would not change beyond those impacts associated withconstruction; therefore, the land use impact due to operation of the RPF would be small. Impacts to landuse that could be reasonably assumed from decommissioning activities are anticipated to be similar to theimpacts previously identified and associated with construction and, as such, would be small.The RPF would be designed to blend in with the architecture of the existing MURR facilities. Becausethe site is presently industrial in nature, the impacts to visual resources as a result of construction,operation, and decommissioning of the RPF at this location would be small.19.5.2.3.3 Air Quality MeteorologyThe impacts to air quality from RPF construction, operation, and decommissioning at the MURR site areanticipated to be similar to those associated with the Discovery Ridge site (discussed in Section 19.4.2.1).Potential air pollution emissions during construction would include dust from earth-moving and material-handling activities, and exhaust emissions from construction equipment and vehicles. In general, theseemissions would be the same as the emissions associated with any large construction project. Emission-specific control measures (e.g., watering areas of disturbed soil) would be implemented to limit air qualityimpacts and ensure compliance with applicable Federal and State regulations. Therefore, air qualityimpacts associated with facility construction would be small. Impacts associated with operation would besimilar to those previously identified in Section 19.4.2.1, and are considered small. Air quality impactsthat could be reasonably assumed from decommissioning activities are anticipated to be similar to impactsidentified and associated with construction and, as such, would be small.19.5.2.3.4 NoiseNoise during construction at the MURR site would be very similar to that discussed in Section 19.4.2.3for the Discovery Ridge site. The primary source of noise during construction would be the operation ofheavy equipment. This noise would be noticeable in the immediate construction area, but wouldpresumably attenuate to acceptable levels before reaching sensitive receptors.19-268 NWMAIRev.: : Chpter 9.0 -Environmental ReviewVehicular traffic due to construction workers commuting to and from the site and deliveries of equipmentand supplies to the site would increase noise levels in the immediate vicinity of several sensitivereceptors. Increased traffic noise would likely be noticeable at some of these receptors; therefore, noiseimpacts associated with project construction would be moderate.During operation, project-related traffic would be greatly reduced, and there would be no use of heavyconstruction equipment on the site. As discussed in Section 19.4.2.3, no significant sources of noise havebeen identified for project operation. Therefore, noise impacts associated with operation would be small.Any impacts to noise levels that could be reasonably assumed from decommissioning activities areanticipated to be similar to impacts identified and associated with construction and, as such, would bemoderate.19.5.2.3.5 Geologic EnvironmentThe proposed MURR location would be located on flat terrain, requiring some cut and fill to bring theground surface to the final grade. The excavation would be considered similar to the Discovery Ridgesite, with a maximum depth of excavation anticipated to be 4.7 m (15.5 ft) and an estimated 6,881 m3(9,000 yd3) excavated for the building footprint. The material excavated would be soil; no blasting isanticipated.The area under the MURR site is underlain by competent limestone bedrock that is not expected tosubside due to construction of buildings and related infrastructure. There is no evidence of subsidence orsinkholes near the MURR site. The impacts to geology for construction, operation, and decommissioningof the facility, if the RPF is constructed at the MURR site, are similar to those of the Discovery Ridge siteand are considered small.19.5.2.3.6 Water ResourcesNo streams or other surface water bodies have been identified within the boundaries of the MURR site.Construction of the RPF would have no direct impacts on surface water. The nearest stream is GrindStone Creek, approximately 305 m (1,000 ft) south of the facility. Federal, State, and local regulationsand permit procedures provide minimum requirements for stormwater management during constructionactivities to prohibit adverse impacts on surface water or stormwater. During construction, anystormwater would be collected in a detention/retention pond. Disturbed soils would be stabilized as partof construction work. Earthen berms, dikes, and sediment fences would be used as necessary during allphases of construction to limit runoff. These measures would prevent the local surface drainages frombeing affected substantially by construction activities. The impacts of RPF construction on surface waterare considered small.For the MURR site, the RPF would obtain its water from the water system owned and operated by MU.The amount used by the RPF is anticipated to be an extremely small percentage of the capacity of the MUwater supply system.Some dewatering due to groundwater and precipitation may be required during construction at the deepestexcavation. No alterations to groundwater systems would occur due to the facility construction. Runoffcontrols would be in place during construction as part of the BMPs to prevent uncontrolled releases ofwater. The potential for water or other liquids from spills or leaks to cause significant migration ofcontaminants downward to the groundwater system is considered unlikely. No groundwater withdrawalsor returns are required during construction. As such, direct and indirect impacts of RPF construction andoperation on groundwater at the MURR site are small.19-269 ChaperI1NWMI-2013-021, Rev. 0AlviChptr 9.0 -Environmental Review* P... I ORTHWEST MECJCAt. lSOTOPESAny impacts to water resources that could be reasonably assumed from decommissioning activities areanticipated to be similar to impacts identified and associated with RPF construction and, as such, aresmall.19.5.2.3.7 Ecological ResourcesThe MURR site is on previously disturbed land. Missouri has determined that there are no threatened orendangered "listed species" on the facility site (MU, 2006b). There are two species of concern in thesurrounding area: the Trout-Perch and Topeka Shiner are both found in Hinkson Creek to the west of theMURR site. Hinkson Creek, which drains the MURR site, is a major tributary of Perche Creek, theprincipal stream of the Boone County drainage basin. Perche Creek enters the county from the northwest,flows southward, and then flows southeasterly before entering the Missouri River approximately 13.7 km(8.5 mi) from the MURR site. To preserve the Trout-Perch and the Topeka Shiner, Hinkson Creek and itstributaries should be protected from soil erosion, water pollution, and in-stream activities that modify ordiminish aquatic habitats. No activities associated with construction or operation of the RPF at theMURR site would contribute to soil erosion. All potential water runoff would be captured in stormwaterdetention ponds. As such, direct and indirect impacts of RPF construction and operation on ecologicalresources are small.Any impacts to ecological resources that could be reasonably assumed from decommissioning activitiesare anticipated to be similar to impacts identified and associated with construction and, as such, are small.19.5.2.3.8 Historical and Cultural ResourcesThe buildings in the near vicinity of the MURR site were constructed recently and are not listed in theNRHP. MU previously performed an assessment of the potential impact of construction on historicproperties at the MURR site, in accordance with Section 106 of the National Historic Preservation Act of1966 (16 U.S.C. § 470 et seq.), and in accordance with the provisions of 36 CFR 800. The studydetermined that there are no buildings, or sites of historical or archaeological importance, located on theMURR site (MU, 2006a). There is insignificant impact to historical properties, as stated in the draft NRCenvironmental assessment (NRC, 2001) related to the MURR request for a construction permit recapturelicense amendment filed on December 27, 2000 (MURR, 2000). The MURR site would be located onpreviously disturbed land; therefore, the potential for an impact on historical or archaeological resourcesdue to the construction and operation of the RPF is small.Any impacts to historical and cultural resources that could be reasonably assumed from decommissioningactivities at the MURR site are anticipated to be similar to impacts identified and associated with RPFconstruction and, as such, are small.19.5.2.3.9 SocioeconomnicsThe socioeconomic impacts associated with siting the RPF at the MURR site would be similar to thosefor the Discovery Ridge site. The ROI for both sites, Boone Country, are the same. Impacts to housing,education, taxes, and utilities (including power and sanitary sewer) would be similar. Water at theMURR site would be obtained from the MU-owned and operated water system that, as previously stated,has the capacity to absorb the additional demand from the RPF.Any impacts to socioeconomics that could be reasonably assumed from decommissioning activities at theMURR site are anticipated to be similar to impacts identified and associated with RPF construction and,as such, are small.19-270 ChaperI1NWM,-2013-021, Rev. 0Ago E Chapter 19.0 -Environmental ReviewEI ..= ORTHWEST MEDICAL ISOTOPES19.5.2.3.10 Human HealthNonradiological -Construction and operation of the RPF at the MURR site would be essentially thesame as the Discovery Ridge site described in Section 19.4.8.1 for the following:* Nonradioactive chemical sources (location, type, strength)* Nonradioactive liquid, gaseous, and solid waste management and effluent control systems* Nonradioactive effluents released into the on-site and off-site environment* Chemical exposure to the public and on-site workforce* Physical occupational hazards* Mitigation measures for nonradiological human health impactsNonradiological chemical sources, wastes, effluents, and occupational hazards associated with the RPFwould be controlled to ensure compliance with applicable environmental and occupational regulationsand standards, as discussed in Section 19.4.8.1. As such, the nonradioiogical human health impactsassociated with RPF construction and operation at the MURR site would be small.Radiological -The RPF constructed at the MURR site would be basically the same as the DiscoveryRidge site, and the following aspects of the facility would be the same:* Characteristics of radiation sources and expected radioactive effluents* Compliance with 10 CFR 20.1301, including calculated radiation dose rates at the fence line* Annual radiation dose to the maximally exposed worker* Mitigation measures to minimize public and occupational exposures to radioactive materialRadiation sources and radioactive effluents would be controlled to ensure compliance with applicableregulations and standards, as discussed in Section 19.4.8.2. The radiological human health impactsassociated with RPF construction and operation at the MURR site would be expected to be small.19.5.2.3.11 TransportationThe MURR site is located within the city limits of Columbia, Missouri. The area is served by two majorhighways: U.S. Interstate 70 and U.S. Highway 63. U.S. Interstate 70 is a major east-west route acrossthe U.S. that connects St. Louis and Kansas City. This interstate currently carries approximately72,530 vehicles/day and is projected to carry more than 109,410 vehicles/day by the year 2026.U.S. Highway 63 is a major north-south route that connects Columbia, Missouri, and Memphis,Tennessee. This highway currently carries approximately 44,300 vehicles/day and is projected to carryover 68,930 vehicles/day by the year 2026.The MURR presently has approximately 140 employees (MU, 2006b). Construction, operation, anddecommissioning of the RPF would add 98 employees to the area, with a similar number of vehicles. Thenumber of vehicles used by facility staff represents a very small percentage of the total number ofvehicles used in the area daily. As such, there is no significant impact on transportation in the areaassociated with the construction, operation, or decommissioning of the RPF at the MURR site.19.5.2.4 Process AlternativesAlternatives to the process proposed for the RPF include different irradiation, target fabrication, andseparations processes selected for use by NWMI. Trade studies were identified as part of thepreconceptual planning. Alternatives are divided into the following categories:* Irradiation technique alternatives* Process alternatives19-27 1 S.S.S NWMINWMI-2013-021, Rev. GAChapter 19.0- Environmental Review19.5.2.4.1 Irradiation AlternativesA major component of design is the selection of the irradiation process. A few varying processes exist tomake 99Mo, including:0S6Neutron capture of molybdenum-98 (98Mo)Use of a linear accelerator for the production of 99M0Use of LEU aqueous homogeneous reactors.Neutron activation/capture -This process of *99Mo production begins with naturally occurringmolybdenum, 98Mo, and uses one of two Neutron M0-98 M0-99techniques to create 99Mo. The first techniquebombards 98Mo with neutrons in a nuclear reactor. Figure 19-47. Molybdenum-98 BombardedWhen successful, the result of the collision is a with Neutrons to Form Molybdenum-99free-released gamma ray and 99Mo (Figure 19-47).The second technique employs an accelerator to produce neutrons in a similar fashion. Neutron captureinvolves using free neutrons to collide with a 98Mo target.The National Academy of Sciences published a report (NAS, 2009) that documents the probability of99Mo generation from uranium fission at 37 barns (b). A barn is a unit of measure equal to 1024 cubiccentimeters (cm2). Because nuclear interaction rates are determined by the cross-sectional area of thetarget atom available to the incident particle, the barn represents a scaled probability of interaction. Thus,an interaction that has a large number of barns has a higher probability of occurrence than an interactionwith a lower number. So for comparison, the neutron capture by 98Mo for the production of 99Mo isapproximately 0.13 b. This is much smaller than the 37 b cross-section for 99Mo production from thefission of uranium; thus, it has a lower probability of occurrence and would require more neutrons toachieve the same quantity of Mo. Another negative aspect of this method is that the 99M0 produced has a lowspecific activity. Most of the Mo produced by this method is 98Mo because of the long half-life of the98Mo and molybdenum-100 ('°°Mo). According to the National Academy of Sciences report, the specificactivity of molybdenum produced by neutron capture is two to four times lower than that produced fromthe fission of uranium (NAS, 2009).Linear accelerators -This technology uses _ _multiple linear accelerators to produce 99Mo. The 6 '7 -linear accelerator accelerates electrons that collide Htgh!neg MO-iGO0 with a metal target, producing extremely intense plmotonshigh-energy photons. The most common methodis to use a photon to produce 99Mo through theI°°Mo('y,n)99Mo reaction (Figure 19-48). The Figure 19-48. Molybdenum-100second method uses protons in one of two ways, Reactions to Form Molybdeieither to produce 99Mo through the'°°Mo(p,pn)99Mo reaction or produce 99mZC directly through the l°°Mo(p,2n)99mTc reaction.Mo-99NeutronHigh Energyhum -99The National Academy of Sciences reported that the cost of construction and operation of multipleaccelerators would have to be analyzed to determine if these approaches could be feasible (NAS, 2009).Another option is to use the accelerator to produce 99m~Tc directly from a 1°°Mo source; however, the shorthalf-life of 99(6 hr) makes this approach impracticable.Another possible application is to use a linear accelerator to induce fission on uranium targets, essentiallyreplacing the traditional reactor with an accelerator. An extraction process would still be needed torecover the 99M0 from any option associated with an accelerator, as with a traditional reactor.19-272 NWM ,vlviChater19.0 -Environmental ReviewLEU aqueous homogeneous reactor approach -This process consists of an array of aqueoushomogeneous reactors to produce 99Mo, 1311, and xenon-133 (133Xe). The aqueous homogeneous reactoruses an LEU uranyl nitrate solution for fuel and target material. A typical facility would consist of asmall number of reactor modules. The use of LEU uranyl nitrate solution for both reactor fuel and targetmaterial allows 99Mo to be produced in the entire reactor solution. To produce 99Mo, 131I, and '33Xe, LEUis dissolved in nitric acid and brought to criticality. To extract these isotopes, the solution is transferredfrom the reactor to a vent tank. After degassing, the solution is transferred to an extraction column whereit undergoes a purification and separation process. The processed solution is cleaned up and returned tothe reactor. The 99Mo is then handled in a manner similar to the NW~MI process.19.5.2.4.2 Additional Process AlternativesIn addition to the acid dissolution process proposed by NWMI, an alkaline dissolution process has alsobeen used. A sodium hydroxide solution is used to dissolve the entire target. Dissolution produces asodium aluminate solution containing sodium molybdate along with small amounts of fission products,other actinides, and residue. The solution is recovered, thus removing suspended solids, and purified by amethod such as ion exchange. The 99Mo recovery yield from the solution typically exceeds 85 to90 percent. The sorbed molybdate is typically washed with a dilute ammonium hydroxide solution andthen removed from the column using a concentrated saline or ammonium hydroxide solution. The 99Mois then recovered, configured, and shipped.19.5.3 Cost-Benefit of the AlternativesTable 19-89 summarizes the cost and benefit analyses of the Discovery Ridge and MURR alternative sitesand alternative technologies.Table 19-89. Cost-Benefit Summary of the Alternatives (4 pages)Land use and Land use is presently set aside for a Land use is presently industrial. Siting thevisual research park. Construction and RPF is not anticipated to impact current landresources operation is harmonious with land use at use. The RPF would be designed to blend inthe park. The RPF would be designed to with the existing MURR facilities. Noblend in with the current facilities. No degradation is anticipated associated with landdegradation is anticipated associated use or visual resources.with land use or visual resources.19-273 L iVI!NWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-89. Cost-Benefit Summary of the Alternatives (4 pages)S.- -S S -~. --GeologicenvironmentA short-term increase in soil erosion anddust production during constructionwould be anticipated. No degradation tothe geologic environment would beanticipated during facility operations.A short-term increase in soil erosion and dustproduction during construction would beanticipated. No degradation to the geologicenvironment would be anticipated duringfacility operations.Ecological The site is on ground that has beenresources historically used for agriculture. Thereare no threatened or endangered specieson the site. There is a potential impactto fauna species near the site due tonoise levels at the site duringconstruction. The fauna would beexpected to return to the surroundingarea after construction is complete. Thepotential impact to off-site aquaticenvironments would be mitigated withthe use of BMPs. There is a potentialfor bird strikes to elevated equipmentduring night construction.The site is on previously disturbed ground,and there are no threatened or endangeredspecies on the site. There are two species, theTrout-Perch and the Topeka Shiner, found inHinkson Creek to the west of the site.Hinkson Creek drains the MURR site.Releases from the MURR site could migrateto Hinkson Creek and impact the Trout-Perchand Topeka Shiner. A potential exists for anaccident or uncontrolled release to degrade theTrout-Perch and the Topeka Shiner habitat.The potential also exists for impacts to faunaspecies near the site due to noise levels at thesite during construction. The fauna would beexpected to return to the surrounding areaafter construction is complete. The potentialimpact to off-site aquatic environments wouldbe mitigated with the use of BMPs. There is apotential for bird strikes to elevatedequipment during night construction.19-274 NWINWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-89. Cost-Benefit Summary of the Alternatives (4 pages)-- ---S.-Socio- Construction and operation would resulteconomics in a small increase in the demand forhousing, utilities, public schools, andother public services. However, thisimpact is anticipated to be small becausethe majority of workers would beobtained from the local labor force.Construction would result in an increasein the amount of local traffic due tocommuting construction workers anddelivery of supplies and materials to thesite. Operations would result inincreased local traffic from commutingemployees.Construction and operation would result in asmall increase in the demand for housing,utilities, public schools, and other publicservices. This impact is anticipated to besmall because the majority of workers wouldbe obtained from the local labor force.Construction would result in an increase in theamount of local traffic due to commutingconstruction workers and delivery of suppliesand materials to the site. Operations wouldresult in increased local traffic fromcommuting employees.Environ- RPF construction and operation would Construction and operations would notmental justice not disproportionally impact minority disproportionally impact minority and/or low-and/or low-income populations, income populations.19-275 IW~NWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-89. Cost-Benefit Summary of the Alternatives (4 pages)No other environmental costs have been No other environmental costs have beenidentified. identified.Construction would result in 83 jobs atthe peak of construction. A total of98 full-time jobs would be filled duringOperations at a salary 75 percent higherthan the current Boone County average.Construction would result in 83 jobs at thepeak of construction. A total of 98 full-timejobs would be filled during Operations at asalary 75 percent higher than the currentBoone County average..- -e -. .-Constructing would result in additionaltax revenue of approximately$2.5 million in Columbia, BooneCounty, and Missouri during operationand approximately $76 million over theperiod spanning construction throughdecommissioning.Constructing would result in additional taxrevenue of approximately $2.5 million inColumbia, Boone County, and Missouriduring operation and approximately$76 million from construction throughdecommissioning.No improvements beyond thosepresently planned for Discovery Ridgeare expected for construction oroperation.No improvements to the infrastructure areexpected due to construction or operations.a -Operations would benefit the health ofpeople who need diagnostic tests thatrequire 99mTc; NWMI intends to providea reliable supply of 50 percent of theU.S. need for 99mTC.Operations would benefit the health of peoplewho need diagnostic tests that require 99mlTC;NWMI intends to provide a reliable supply of50 percent of the U.S. need for 99m'c.a 10 CFR 20, "Standards for Protection Against Radiation," Code of Federal Regulations, Office of theFederal Register, as amended.BMP = best management practice. NWMI = Northwest Medical Isotopes, LLC.MURR = University of Missouri Research Reactor. RPF = radioisotope production facility.NRHP = National Register of Historic Places.19-276

• tO..,.NO1AHWE TMEO4CAAtOOENWMI-2013-021, Rev. 0AChapter 19.0 -Environmental Review19.5.4 Comparison of the Potential Environmental ImpactsThis section compares the environmental impacts, costs, and benefits discussed in Sections 19.5.1, 19.5.2,and 19.5.3. Table 19-90 and Table 19-91 summarize the potential construction and operational impacts ofthe Discovery Ridge site and alternatives, respectively.Table 19-90. Comparison of the Potential Construction Impactsof the Discovery Ridge Site and AlternativesLand useAir qualityGeology, soils, seismologySurfaceEcological resourcesSmallSmallSmallSm~~allSmallSmallSmallSmallSmoealeSmallNoneNoneNoneNoneNoneSocioeconomicPublic servicesPublic eduationTaxesEmploymentWaste managementPostulated accidentsSmalSmallSmalSmall ($2,534,962)Small (82)SmallSmallSmalSmallSmalSmall ($2,534,962)SmallSmall (82)SmallSmallNoneNoneNoneNoneNoneNoneNoneNoneMURR = University of Missouri Research Reactor.19-277

~NWMIVNWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-91. Comparison of the Potential Operational Impactsof the Discovery Ridge Site and AlternativesLand UseAir QualityGeology, Soils,SeismologySurfaceEcological ResourcesSmallSmallSmallSmallSmallSmallSmallSmallSmallSmallNoneNoneNoneNoneNoneSocioeconomicPublic ServicesTaxesEmploymentHuman HealthTransportationEnvironmental JusticeSmallSmall ($72,827,264)Small (98)SmallSmallSmallSmallSmall$2,27263Small (8SmallSmall (8Smalli onieiiNoneNoneNoneNoneMURR = University of Missouri Research Reactor.19-278 NW~MNWMI-2013-021, Rev. 0AChapter 19.0 -Environmental Review

19.6 CONCLUSION

S19.6.1 Unavoidable Adverse Environmental Impacts of the Proposed ActionUnavoidable adverse impacts are predicted adverse environmental impacts that cannot be avoided and forwhich there are no practical means of further mitigation. This section considers unavoidable adverseimpacts from construction and operation of the proposed RPF. The decommissioning of the facilitywould return the site to its present state. If the site is returned to its current state, there would be nounavoidable adverse environmental impacts associated with the proposed action.19.6.1.1 Unavoidable Adverse Environmental Impacts of ConstructionThe impacts associated with construction are discussed in Section 19.4, and as described in that section,all impacts are considered small. Table 19-92 summarizes construction-related impacts that result in ameasurable loss or permanent change in resources, the mitigation and control measures available toreduce those impacts, and the remaining unavoidable adverse impacts after mitigation and controlmeasures are applied.Table 19-92. Construction-Related Unavoidable Adverse Environmental Impacts (2 pages)Land Use and VisualResourcesConstruction wouldpermanently impact3 ha (7.4 acres) ofLot 15 (open space inDiscovery Park).Partial obstruction ofviews of the existinglandscapeVisual obstruction viadust generationConstruction activities comply withall relevant Federal, State, and localregulatory requirements, includingBMPs and stormwater managementplans to control erosion and runoff.Visual impacts are minimizedthrough landscaping of the site.BMPs, including dust control,would be used to limit any impact.A total of 3 ha (7.4 acres)within Discovery Ridgewould be impacted.A minor change in existinglandscape would be expected.Unavoidable adverseenvironmental impacts areanticipated to be small.Air Quality$t~l1 rQSQflStorm'BMPsEmissions and fugitivedustApplication of BMPs, includingdust suppression, periodicallywatering unpaved constructionareas, covering haul trucks whenloaded or unloaded, minimizingmaterial handling (e.g., dropheights, double-handling), phasedgrading to minimize the area ofdisturbed soils, revegetating roadmedians and slopes.Encouraging car poolingUnavoidable adverseenvironmental impacts areexpected to be small.Vehicle emissionsUnavoidable adverseenvironmental impacts areexpected to be small.19-279 NW~NNWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-92. Construction-Related Unavoidable Adverse Environmental Impacts (2 pages)0@ *~.@.S -S -.S.Water Resources No surface water Stormwater would be collected in a Unavoidable adverseimpacts would be detention/retention pond, and runoff environmental impacts areanticipated. Minimal controls would be applied, not anticipated.groundwaterdewatering at thedeepest excavation.Public ServicesUse of water, sanitary No mitigation is required.sewer and power,public education, taxrevenues,transportation.Unavoidable adverseenvironmental impacts areanticipated to be small.Cultural and No adverse impacts on A Phase I archeological survey was Unavoidable adverseHistorical Resources cultural or historic performed and the SHPO reviewed environmental impacts are notresources have been the findings and indicated that no anticipated.identified, further consultation is needed.BMP = best management practice. RPF = radioisotope production facility.LEU = low-enriched uranium. SHPO = State Historic Preservation Office.OSHA = Occupational Safety and Health Administration.For many of the impacts related to construction activities, the mitigation measures are referred to asBMPs. Typically, these mitigation measures are based on the types of activities that are to be performed.The mitigation measures are implemented through permitting requirements and the plans and proceduresdeveloped for the construction activities.19-280

• %e I1VV Chapter 19.0 -Environmental ReviewMEDICAL ISOTOPESUnavoidable adverse impacts from construction of the RPF would be direct and permanent disturbance of3 ha (7.4 acres) of Lot 15 that changes open space to a fully constructed facility with surroundinglandscaping and partially obstructs views of the existing landscape. Even with application of BMPs,construction activities would result in localized increases in air emissions, including GHGs, dust, noise,vibration, and soil erosion, which may impact on-site workers, other Discovery Ridge tenants, and nearbyresidents. Because there are no streams, ponds, or water bodies present on the RPF site, and nogroundwater dewatering would be anticipated, potential construction-related impacts to water resourcesare limited to off-site impacts associated with runoff and siltation that are not fully mitigated throughstormwater management plans and BMPs. There may be temporary displacement of fauna species(because of noise), and bird strikes with illumination. BMPs for artificial lights would be used tominimize bird collisions.Impacts to land and visual resources from facility construction are mitigated by returning lands within thesite boundary, which surround the developed area, to a combination of open and landscaped spaces oncompletion of construction. Potential noise impacts also include traffic noise associated with theconstruction workforce traveling to and from the RPF.19.6.1.2 Unavoidable Adverse Environmental Impacts of OperationsOperational impacts, all of which are considered small, are discussed in detail throughout Section 19.4.Table 19-93 summarizes operations-related impacts that result in a measurable loss or permanent changein resources, the mitigation and control measures available to reduce these impacts, and the remainingadverse impacts after mitigation and control measures are applied. As indicated in Table 19-93, most ofthe adverse impacts are either avoidable or negligible after mitigation and control measures areconsidered.Unavoidable adverse impacts from operation of the RPF include a change to the viewshed, potentialstormwater, infrequent bird collisions with buildings, emissions and dust from traffic, operating noise andvibration, and an increase in potential for nonradiological and radiological hazards to the public andoccupational workers.Visual impacts to the viewshed would occur as a result of the main building's exhaust stacks and exhaustfrom them. The surrounding viewshed includes light industrial development; therefore, impacts areminor. Stormwater runoff during plant operation from paved and compacted surfaces would becontrolled via drainage ditches and basins. Infrequent bird collisions with buildings at the RPF andassociated structures could result in some bird mortality. However, the RPF has a relatively low profile,and the effects on bird populations from collisions with buildings would be minimized. A small level ofnoise and vibration from equipment would occur during operations. Noise would be limited to theinterior of the facility and the immediate exterior area, where it would be perceived as being close toambient levels. There would be an increase in potential for nonradiological and radiological hazards tothe public and workers. These hazards would be mitigated through the facility's design, engineeringcontrols, and administrative controls.19-281 2::NWMIO.R., RftV.NWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-93. Operations-Related Unavoidable Adverse Environmental Impacts (3 pages)., ., ,, .., ,. ,. ... .--'- .. , -Land Use andVisual ResourcesVisual impacts as a result ofthe main building associatedwith the three mainprocessing exhaust ventstacks*The majority of the facilitystructures have a relatively lowprofile. The exhaust stackswould extend to approximately22.9 m (75 ft) high abovegrade.No mitigation is required.Minor impacts toviewscape would occur asa result of the completedfacility; thus, impacts aresmall.Unavoidable adverseenvironmental impacts arenot anticipated.Quantities of gaseous effluent No mitigation is required.released from the facilityduring operations are notanticipated to result invisibility impacts.Noise and Noise and vibration would be These noise sources would Unavoidable adverseVibration generated from process largely be limited to the interior environmental impacts areequipment, ventilation, of the facility. The exterior anticipated to be small.heating and cooling systems, noises would not be significantlyand increased traffic, above ambient level. Nomitigation is required.19-282 NWMI-2013-021, Rev. GAChapter 19.0 -Environmental ReviewTable 19-93. Operations-Related Unavoidable Adverse Environmental Impacts (3 pages)6*.*~ .6 ----S. 6. 6 ~. .6.ueoogic~tormwater runon armprocess wastewaterWater Resources Stormwater runoffLiquid dischargewouto DCuseo o mean!agestormwater runoff from pavedand compacted surfaces todrainage ditches and basins.Proes waciltewye would be dsgecontroiled withiand tenlose ldProesnse wrrlastewater wroulmotbdipoedfclt to the suburacenBniomen sa would busdtmanagecadcmatdsurfaceswator~navoiuawe auverseenvironmental impacts areanticipated to be small.Unavoidable adverseenvironmental impacts aresmall.Unavoidable adverseenvironmental impacts arenot anticipated.Environmental No adverse impacts on Level of impact is comparable Impacts to low income andJustice minority or low-income for all populations, and minority populations arepopulations have been mitigation is not required. not anticipated.identified.Human HealthPotential nonradiologicaipublic and occupationalhazards pertaining tooperation of the RPF areassociated with emissions,discharges, waste associatedwith processes within thefacility, and accidentalspills/releases.Control systems would be usedto mitigate risks and controlexposure.Unavoidable adverseenvironmental impacts areanticipated to be small.I9-28

~NWMINWMI-2013-021, Rev. 0AChapter 19.0 -Environmental ReviewTable 19-93. Operations-Related Unavoidable Adverse Environmental Impacts (3 pages)0*.*~ .0 --'0 -0. 0. 0 -- S.Human Health(cont).Worker exposure to wastesand chemicalsRadiological impacts -publicRadiological impacts -workersProcesses and procedures wouldreduce the probability of anexposure. Emergency responseplans would mitigate the effectsof accidents and spills.The facility would be designedsuch that the radiologicalimpacts at the fence line to anyindividual would be belowapplicable limits. Engineeredcontrols used would include:shielding, ventilation control,access control, contaminationcontrol, etc.Administrative controls(e.g., regulation compliance,waste minimization goals, etc.)would be used to ensure thatworkers do not receive doseabove the regulatory reference.Unavoidable adverseenvironmental impacts areanticipated to be small.Unavoidable adverseenvironmental impacts areanticipated to be small.Unavoidable adverseenvironmental impacts areanticipated to be small.a 10 CFR 20, Appendix B, "Annual Limits on Intake (ALl) and Derived Air Concentrations (DAC) ofRadionuclides for Occupational Exposure; Effluent Concentration; Concentrations for Release to Sewerage," Codeof Federal Regulations, Office of the Federal Register, as amended.BMP = best management practice. SHPO = State Historic Preservation Office.PM = particulate matter. VOC = volatile organic compound.RPF = radioisotope production facility.19.6.2 Relationship between Short-Term Uses and Long-Term Productivity of theEnvironmentThis environmental review focuses on the analyses and resulting conclusions associated with theenvironmental impacts from activities during the construction and operation at the RPF. These activitiesare considered short-term uses for purposes of this section. In this section, the long-term is considered tobe initiated with the conclusion of RPF decommissioning. This section includes an evaluation of theextent that the short-term uses preclude any options for future long-term use of the RPF site.19.6.2.1 Construction of the Radioisotope Production Facility and Long-TermProductivitySubsection 19.6.1.1 summarizes the potential unavoidable adverse environmental impacts of constructionand the measures proposed to reduce those impacts. Some small adverse environmental impacts couldremain after all practical measures to avoid or mitigate them are taken. However, none of these impactsrepresent long-term effects that preclude any options for future use of the RPF site.The acreage disturbed during construction of the facility would be larger than that required for the RPF dueto the need for construction parking areas and the material staging and laydown areas. These disturbances,along with noise from construction activities, may displace some wildlife and alter existing vegetation.Once the RPF is completed, the areas not needed for operations would be restored with landscaping.19-284 fl: Chapter 9.0 -Environmental ReviewConstruction of the RPF would include the installation of water and sewer lines that connect the facility tothe Consolidated Public Water Supply District #1 water supply system. This additional infrastructurewould be available and beneficial to any future use of the RPF site after decommissioning. There wouldbe no effects on the long-term productivity of the RPF site as a result of these impacts.Construction traffic would increase the volume of traffic on local roads, but not to the extent thatmodifications to the traffic infrastructure or increased rate of maintenance would be required. Aspresented in the Section 19.4.7, the facility construction has a small positive socioeconomic effect on thelocal area. These impacts include new construction-related jobs, local spending by the constructionworkforce, and payment of taxes within the area and region. The beneficial impacts from the constructionworkforce and indirect economic output and employment resulting from construction expenditures to thelocal community are limited to the duration of construction. However, the changes that result fromincreased tax revenues and employment of operational workers would continue throughout theoperational life of the RPF.Construction of the RPF would have insignificant impacts on populations identified as minority or low-income. The percentage of minority or low-income population within the impacted area does not exceed20 percent of the State or the county, and the percentage of minority or low-income population in theimpacted area does not exceed 50 percent of the total population.19.6.2.2 Operation of the Radioisotope Production Facility and Long-Term ProductivitySection 19.6.1.2 summarizes the potential unavoidable adverse environmental impacts of RPF operationand the measures proposed to reduce or eliminate those impacts. Some small adverse environmentalimpacts could remain after all practical measures to avoid or mitigate them are taken. However, none ofthese impacts represent long-term effects that preclude any options for future use of the RPF site.The RPF site is located in an area that was previously disturbed for agricultural use and later acquired byMU for use as a research park. Operation of the RPF, therefore, represents a continuation of the plannedland use. Once the facility is decommissioned to NRC standards, the land could be available for otherindustrial or non-industrial uses.During operation, noise levels are largely expected to be similar to ambient levels because facility-generated noise would be limited by the walls and other physical barriers of the facility itself. Operationof the RPF would slightly increase air emissions from the exhaust stacks. The majority of effluent wouldbe from radioisotope production and include the release of a small amount of gaseous fission products.However, the results of modeling showed that no pollutant released during normal operations wouldexceed the NAAQS. Facility equipment would be operated in accordance with applicable Federal, State,and local regulations, and would not be expected to result in any long-term decrease in regional airquality. Once the facility is decommissioned, none of these impacts would preclude future use of the site.Operation of the RPF would have a comparable impact on all populations in the region around the site.19.6.2.3 Summary of the Relationship Between Short-Term Use and Long-TermProductivityThe impacts resulting from construction and operation of the RPF result in both adverse and beneficialshort-term impacts. The principal short-term adverse impacts are small residual impacts (after mitigationmeasures are implemented) to land use and visual resources, ecological resources, human health, and airquality. There are no long-term impacts to the environment.The principal short-term benefits are the creation of additional jobs, additional tax revenues, andimprovements to local infrastructure. The principal long-term benefit would be the continued availability ofthe improved infrastructure and potential benefits from increased tax revenues after RPF decommissioning.19-285

• . N Chater 9.0 -Environmental ReviewThe short-term impacts and benefits and long-term benefits do not affect the long-term productive use ofthe RPF site.19.6.3 Irreversible and Irretrievable Commitments of Resources Used to Support theProposed ActionThis section describes the expected irreversible and irretrievable environmental resource commitmentsused in the RPF construction and operation. The phrase "irreversible commitment of resources" describesenvironmental resources that are potentially changed by either RPF construction or operation such thatthey could not be restored at some later time to the resource's prior state. Irretrievable commitments ofresources are generally materials that are used for the new facility in such a way that they could not, bypractical means, be recycled or restored for other uses.19.6.3.1 Irreversible Environmental Commitments of ResourcesIrreversible environmental resource commitments resulting from the new facility, in addition to thematerials used for radioisotope production, are described in the following subsections.19.6.3.1.1 Land UseThe land used for the RPF would not irreversibly committed because once the RPF ceases operations andthe facility is decommissioned in accordance with NRC requirements, the land supporting the facilitycould be returned to other industrial or nonindustrial uses. There would be no long-term storage ordisposal of radioactive and nonradioactive wastes at the site. Medical isotopes would not be stored forany significant time period as these items would be transported to clients as quickly as possible. LEUwill be recycled.19.6.3.1.2 Water ResourcesThe RPF requires water from the Consolidated Public Water Supply District #1 water supply system forconstruction, isotope production, potable water, fire protection, and facility heating and cooling. TheConsolidated Public Water Supply District #1 presently supplies 5.49 ML/day (1.45 Mgal/day).Construction requirements of the RPF are small compared to the available water supply. As noted inSection 19.2.4, the RPF would require 4,885 L/day (1,286 gal/day) during operations, less than onepercent of the total Consolidated Public Water Supply District #1 operational capacity. This leaves asignificant excess capacity. Because there would be significant excess capacity within the ConsolidatedPublic Water Supply District #1, there are no indirect effects associated with the demand from the RPF.There are also no direct impacts to water quality or hydrology from the RPF, and therefore, there wouldbe no irreversible impacts.1 9.6.3.1.3 Ecological ResourcesLong-term irreversible losses of ecological resources are not anticipated. Subsequent to the completion ofconstruction, floral and faunal resources are expected to recover in areas that are not affected by ongoingoperations. Losses of fauna due to operations are anticipated to be attributable to bird collisions withbuildings at the RPF, as wildlife occurrence on the site would be relatively infrequent. There are nowetlands or water bodies located at the RPF site.All water for the RPF facility would be provided by the Consolidated Public Water Supply District #1,and the RPF would not be discharging into any water body, thus avoiding any environmental impacts.Stormwater BMPs would control runoff and minimize runoff impacts to any off-site water body.19.6.3.1.4 Socioeconomic ResourcesNo irreversible commitments would be made to socioeconomic resources, as they would be available tobe reallocated for other purposes once the RPF is decommissioned.19-286 Catr1NWMI-2013-021, Rev. QAflIVChapter 9.0 -Environmental Review19.6.3.1.5 Historic and Cultural ResourcesNo known historic or cultural resources would be irreversibly altered as a result of RPF construction oroperation.19.6.3.1.6 Air QualityDust and other emissions, such as vehicle exhaust, would be released to the air during constructionactivities. Implementation of controls and limits at the .source of emissions on the construction site resultin the reduction of impacts offsite. Mitigations, such as dust suppression BMPs, would also reduce dustfrom construction activities.During operations, emissions would be a product of vehicle exhaust, isotope production, and fuelcombustion, resulting in very low levels of gaseous pollutants and particulates released from the facilityinto the air. Contractors, vendors, and subcontractors are required to adhere to appropriate Federal andState occupational health and safety regulations to protect workers from adverse conditions, including airemissions. Emissions during operations were shown through modeling to be in compliance withapplicable Federal and State regulations, which would minimize their impact on public health and theenvironment.19.6.3.1.7 Irretrievable Commitments of ResourcesIrretrievable commitments of resources during RPF construction would generally be similar to that of anysmall-scale facility construction project. Materials consumed during the construction phase are shown inTable 19-7. These materials are irretrievable unless they are recycled at decommissioning.Approximately 1,647 L (435 gal) of diesel fuel would be expected to be used on an average monthly basisduring construction. The use of construction materials in the quantities associated with the facility has asmall impact on the availability of such resources.During RPF operations, the primary irreversibly and irretrievably resource committed is the uranium usedas the source for the molybdenum isotope to eventually produce 99mTc for medical diagnostics. Theamount of uranium that NWMI will require on an annual basis and over the lifetime of the operating license(assuming a 30-yr operating license) is small when compared to the amount consumed by other users andthe total global supply of uranium.The World Nuclear Association (WNA) studies of supply and demand of uranium indicate that a total of5,902,500 metric tons (NIT) of uranium were available in 2013. Current usage is a bout 66,000 t U/yrrepresenting an 90-yr supply of uranium at current prices based on known resources (WNA, 2014). Thisrepresents a higher level of assured resources than is normal for most minerals.Uranium is a relatively common metal found in rocks and seawater. The world's known uraniumresources increased by at least one-quarter in the last decade due to increased mineral exploration.Australia has a substantial part (about 29 percent) of the world's uranium, Kazakhstan has 12 percent,Russia has nine percent, Canada has eight percent, and the U.S. has four percent. The amount of uraniumcould increase to a 200-yr supply as market prices rise and other conventional sources of uranium are used.Therefore, the uranium that is used to generate the medical radioisotopes has a negligible impact withrespect to the long-term availability of uranium worldwide.While a given quantity of material consumed during new facility construction and operation at the RPFsite would be irretrievable, except for materials recycled during decommissioning, the impact on theiravailability would be small.19-287

.~NW M INWMI-201 3-021, Rev. OA: : Chapter 19.0 -Environmental Review* e ,..NRHETMEDICAL ISOTOPE$19.7 REFERENCES3 CSR 10-4.110, "General Prohibition; Applications," Missouri Code of State Regulations, as amended.3 CSR 10-9.110, "General Prohibition; Applications," Missouri Code of State Regulations, as amended.3 CSR Division 10, "Department of Conservation," Missouri Code of State Regulations, as amended.6 CSR Division 10, "Air Quality Standards, Definitions, Sampling and Reference Methods and AirPollution Control Regulation for the Entire State of Missouri," Missouri Code of StateRegulations, as amended.10 CFR 20, "Standards for Protection Against Radiation," Code of Federal Regulations, Office of theFederal Register, as amended.10 CFR 20, Appendix B, "Annual Limits on Intake (ALI) and Derived Air Concentrations (DAC) ofRadionuclides for Occupational Exposure; Effluent Concentration; Concentrations for Release toSewerage," Code of Federal Regulations, Office of the Federal Register, as amended.10 CFR 20.1101, "Radiation Protection Programs," Code of Federal Regulations, Office of the FederalRegister, as amended.10 CFR 20.1201, "Occupational Dose Limits for Adults," Code of Federal Regulations, Office of theFederal Register, as amended.10 CFR 20.1203, "Determination of External Dose from Airborne Radioactive Material," Code ofFederial Regulations, Office of the Federal Register, as amended.10 CFR 20.1301, "Dose Limits for Individual Members of the Public," Code of Federal Regulations,Office of the Federal Register, as amended.10 CFR 20.1302, "Compliance with Dose Limits for Individual Members of the Public," Code of FederalRegulations, Office of the Federal Register, as amended.10 CFR 30, "Rules of General Applicability to Domestic Licensing of Byproduct Material," Code ofFederal Regulations, Office of the Federal Register, as amended.10 CFR 40, "Domestic Licensing of Source Material," Code of Federal Regulations, Office of the FederalRegister, as amended.10 CFR 50, "Domestic Licensing of Production and Utilization Facilities," Code of Federal Regulations,Office of the Federal Register, as amended.10 CFR 50.10, "License Required; Limited Work Authorization," Code of Federal Regulations, Office ofthe Federal Register, as amended.10 CFR 50.31i. "Combining Applications," C'ode of Federal Regutlations, Office of the Federal Register,as amended.10 CFR 50.32, "Elimination of Repetition," Code of Federal Regulations, Office of the Federal Register,as amended.10 CFR 50.47, "Emergency Plans," Code of Federal Regulations, Office of the Federal Register, asamended.10 CFR 50.50, "Issuance of Licenses and Construction Permits," Code of Federal Regulations, Office ofthe Federal Register, as amended.10 CFR 50.57, "Issuance of Operating Licenses," Code of Federal Regulations, Office of the FederalRegister, as amended.19-288 ChptrW NM-2I302,Rev. oAflIVChapter 9.0 -Environmental Review*,....NORThWEST MEDICAl ISOTOPES10 CFR 50.59, "Changes, Tests, and Experiments," Code of Federal Regulations, Office of the FederalRegister, as amended.10 CFR 51, "Environmental Protection Regulations for Domestic Licensing and Related RegulatoryReview," Code of Federal Regulations, Office of the Federal Register, as amended.10 CFR 51 Subpart A, "National Environmental Policy Act -Regulations ImplementingSection 102 (2)," Code of Federal Regulations, Office of the Federal Register, as amended.10 CFR 70, "Domestic Licensing of Special Nuclear Material," Code of Federal Regulations, Office ofthe Federal Register, as amended.10 CFR 71, "Packaging and Transportation of Radioactive Material," Code of Federal Regulations,Office of the Federal Register, as amended.10 CSR 10-6, "Air Quality Standards, Definitions, Sampling and Reference Methods and Air PollutionControl Regulation for the Entire State of Missouri," Missouri Code of State Regulations, asamended.10 CSR 10-6.020, "Definitions and Common Reference Tables," Missouri Code of State Regulations, asamended.10 CSR 10-6.060, "Construction Permits Required," Missou~ri Code of State Regulations, as amended.10 CSR 10-6.06 1, "Construction Permit Exemptions," Missouri Code of State Regulations, as amended.10 CSR 20-6.0 10, "Construction and Operating Permits," Missouri Code of State Regulations, asamended.10 CSR 20-7.03 1, "Water Quality Standards," Missouri Code of State Regulations, as amended.10 CSR 23-3.090, "Regionalization," Missouri Code of State Regulations, as amended.10 CSR 25-3.260, "Definitions, Modifications to Incorporations and Confidential Business Information,"Missouri Code of State Regulations, as amended.10 CSR 25-5.262, "Standards Applicable to Generators of Hazardous Waste," Missouri Code of StateRegulations, as amended.10 CSR 25-7, "Rules Applicable to Owners/Operators of Hazardous Waste Facilities," Missouri Code ofState Regulations, as amended.10 CSR 25-7.266, "Standards for the Management of Specific Hazardous Wastes and Specific Types ofHazardous Waste Management Facilities," Missouri Code of State Regulations, as amended.10 CSR 25-7.270, "Missouri Administered Permit Programs: The Hazardous Waste Permit Program,"Missouri Code of State Regulations, as amended.10 CSR 25-9, "Resource Recovery," Missouri Code of State Regulations, as amended.10 CSR 25-9.020, "Hazardous Waste Recovery Processes," Missouri Code of State Regulations, asamended.10 CSR 25-16.273, "Standards for Universal Waste Management," Missouri Code of State Regulations,as amended.10 CSR Division 10, "Air Conservation Commission," Missouri Code of State Regulations, as amended.10 CSR Division 20, "'Clean Water Commission," Missouri Code of State Regulations, as amended.10 CSR Division 25, "Hazardous Waste Management Commission," Missouri Code of State Regulations,as amended.19-289 NW MKIChpe NWM,-2013-021, Rev. 0AE :Chater19.0 -Environmental Review*NORTHWEST MEDICAL ISOTOPES10 CSR Division 60, "Safe Drinking Water Commission," Missouri Code of State Regulations, asamended.16 U.S.C. § 470 et seq., "National Historic Preservation Act of 1966," United States Code, as amended.16 U.S.C. § 1531 et seq., "Endangered Species Act of 1973," United States Code, as amended.19 CSR 20-10, "Protection Against Ionizing Radiation," Missouri Code of State Regulations, as amended.19 CSR 20-10.020, "Exemptions from Requirements of this Chapter," Missouri Code of StateRegu~lations, as amended.19 CSR Division 20, "Division of Community and Public Health," Missouri Code of State Regul~ations, asamended.25 U.S.C. § 3001 et seq., "Native American Graves Protection and Repatriation Act," United States Code,as amended.29 CFR 1910, "Occupational Safety and Health Standards," Code of Federal Regulations, Office of theFederal Register, as amended.29 CFR 1910.1000, "Air Contaminants," Code of Federal Regulations, Office of the Federal Register, asamended.29 U.S.C. §§ 657-658, "Occupational Safety and Health Act of 1970," United States Code, as amended.33 CFR 323, "Permits for Discharges of Dredged or Fill Material into Waters of the United States," Codeof Federal Regulations, Office of the Federal Register, as amended.33 U.S.C. § 1251 et seq., "Clean Water Act of 1972," United States Code, as amended.36 CFR 60.6, "Nominations by the State Historic Preservation Officer under Approved State HistoricPreservation Programs," Code of Federal Regulations, Office of the Federal Register, asamended.36 CFR 800, "'Protection of Historic Properties," Code of Federal Regulations, Office of theFederal Register, as amended.40 CFR 50, "National Primary and Secondary Ambient Air Quality Standards," Code of FederalRegulations, Office of the Federal Register, as amended.40 CFR 51, "Regional Haze Regulations," Code of Federal Regulations, Office of the Federal Register,as amended.40 CFR 58.10, "Annual Monitoring Network Plan and Periodic Network Assessment," Code of FederalRegulations, Office of the Federal Register, as amended.40 CFR 60, "Standards of Performance for New Stationary Sources," Code of Federal Regulations,Office of the Federal Register, as amended.40 CFR 61, "National Emission Standards for Hazardous Air Pollutants," Code of Federal Regulations,Office of the Federal Register, as amended.40 CFR 63, "National Emission Standards for Hazardous Air Pollutants for Source Categories," Code ofFederal Regulations, Office of the Federal Register, as amended.40 CFR 70, "State Operating Permit Programs, Code of Federal Regulations, Office of the FederalRegister, as amended.40 CFR 8 1.416, "Identification of Mandatory Class I Federal Areas where Visibility is an ImportantValue, Missouri," Code of Federal Regulations, Office of the Federal Register, as amended.19-290

"INWMI.:,;.;Chapter.NWMI-2013-021, Rev. 0A* I.i.O,.I..Ihaper19.0- Environmental Review.e'" NORTHWEST MEDICAL ISOTOPES40 CFR 112, Subpart D, Appendix F, "Facility-Specific Response Plan," Code of Federal Regulations,Office of the Federal Register, as amended.40 CFR 122, "EPA Administered Permit Programs: The National Pollutant Discharge EliminationSystem," Code of Federal Regulations, Office of the Federal Register, as amended.40 CFR 141 and 142, "National Primary Drinking Water Regulations Implementation," Code of FederalRegulations, Office of the Federal Register, as amended.40 CFR 143, "National Secondary Drinking Water Regulations," Code of Federal Regulations, Office ofthe Federal Register, as amended.40 CFR 190, "Environmental Radiation Protection Standards for Nuclear Power Operations," Code ofFederal Regulations, Office of the Federal Register, as amended.40 CFR 230.404(b)(1), "Guidelines for Specification of Disposal Sites for Dredged or Fill Material,"Code of Federal Regulations, Office of the Federal Register, as amended.40 CFR 260, "Hazardous Waste Management System: General," Code of Federal Regulations, Office ofthe Federal Register, as amended.40 CFR 261, "Identification and Listing of Hazardous Waste," Code of Federal Regulations, Office of theFederal Register, as amended.40 CFR 262, "Standards Applicable to Generators of Hazardous Waste," Code of Federal Regulations,Office of the Federal Register, as amended.40 CFR 266, "Standards for the Management of Specific Hazardous Wastes and Specific Types ofHazardous Waste Management Facilities," Code of Federal Regulations, Office of the FederalRegister, as amended.40 CFR 266, Subpart N, "Conditional Exemption for Low-Level Mixed Waste Storage, Treatment,Transportation, and Disposal," Code of Federal Regulations, Office of the Federal Register, asamended.40 CFR 268, "Land Disposal Restrictions," Code of Federal Regulations, Office of the Federal Register,as amended.40 CFR 282, "Approved Underground Storage Tank Programs," Code of Federal Regulations, Office ofthe Federal Register, as amended.40 CFR 355, "Emergency Planning and Notification," Code of Federal Regulations, Office of the FederalRegister, as amended.40 CFR 370, "Hazardous Chemical Reporting: Community Right-To-Know," Code of FederalRegulations, Office of the Federal Register, as amended.40 CFR 372, "Toxic Chemical Release Reporting: Community Right-To-Know," Code of FederalRegulations, Office of the Federal Register, as amended.40 CFR 373, "Reporting Hazardous Substance Activity When Selling or Transferring Federal RealProperty," Code of Federal Regulations, Office of the Federal Register, as amended.40 CFR 1039.102, "What exhaust emission standards and phase-in allowances apply for my engines inmodel year 2014 and earlier," Code of Federal Regulations, Office of the Federal Register, asamended.40 CFR 1500-1508, "Regulations for Implementing the Procedural Provisions of the NationalEnvironmental Policy Act," Code of Federal Regulations, Office of the Federal Register, asamended.19-29 1 Chapter NWMI-2013-021, Rev. 0AlviChater19.0 -Environmental Review* ... I ORT14WEST MEDICAt ISOTOPES40 CFR 1508.7, "Cumulative Impact," Code of Federal Regulations, Office of the Federal Register, asamended.40 CFR 1508.25, "Scope," Code of Federal Regulations, Office of the Federal Register, as amended.42 U.S.C. § 300(f) et seq., "Safe Drinking Water Act of 1974," United States Code, as amended.42 U.S.C. § 2011 et seq., "Atomic Energy Act of 1946," United States Code, as amended.42 U.S.C. § 4321 et seq., "National Environmental Policy Act," United States Code, as amended.42 U.S.C. § 6901 et seq., "Resource Conservation and Recovery Act of 1976," United States Code,as amended.42 U.S.C. § 7401 et seq., 1970, "Clean Air Act of 1970," United States Code, as amended.42 U.S.C. § 7491, et seq., "Visibility Protection for Federal Class I Areas," United States Code,as amended.42 U.S.C. 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..'Chapter 1 NWMI-2013-021, Rev. 0AflIVVI..o-"Chptr 9.0 -Environmental Review* .,- ORTHWESTMEOIcAL ISOTOPESUnion Electric Company, 2008, Combined License Application, Part J IG: Site Area Paleoliqutefaction andSurface Faulting Investigation Program, Rev. 1, pbadupws.nrc.gov/docs/ML0833/MvL083360 11 8.pdf,St. Louis, Missouri, November, 2008.UP, 2013, "Union Pacific in Missouri," www .up.com/cs/groups/publ ic/documents/up...pdf~nativedocs/pdfjnissouri~usguide.pdf, Union Pacific Railroad, Omaha, Nebraska, accessed August 15, 2013.USCB, 2010a, "2010 Census Interactive Population Search," www.census.gov/2010census/popmap/ipmtext.php, U.S. Census Bureau, Washington, D.C., accessed July 2013.USCB 2010~b, "Selected Economic Characteristics, American Community Survey 5 Year Estimate,"factfinder2.census.us.gov, U.S. Department of Commerce, Washington, D.C., accessed August2013.USCB, 2010c, "U.S. Census 2010," factfinder2.census.gov/faces/nav/j sf/pages/communityjfacts.xhtml#none, U.S. Census Bureau, Washington, D.C., accessed March 12, 2013.USCB, 2010d, 2006-2010 American Comunittyi Survey. Hotisehold Income in the Past 12 Months (In2010 Infation -Adjusted Dollars), www.census.gov/acs/www/data_documentation/data_main,Table B 1900, U.S. Census Bureau, Washington, D.C., accessed September 2013.USDA, 2007, 2007 Census of Agriculture -County Data, www.agcensus.usda.gov/Publications/2007/Full_Report/Volume_1,_Chapter 2CountyLevel/Missouri/st29_2_001_001.pdf,U.S. Department of Agriculture, National Agricultural Statistics Service, Washington, D.C.,accessed July 2013.USDA, 2013a, "Web Soil Survey," Online Mapping Tool, websoilsurvey.nrcs.usda.gov, U.S. Departmentof Agriculture, Washington, D.C., accessed July 10, 2013.USDA, 2013b, "Missouri Electronic Field Office Technical Guide," efotg.sc.egov.usda.gov/treemenuFS.aspx,U.S. Department of Agriculture, National Resources Conservation Service, Washington, D.C.,accessed August 19, 2013.USDOL, 2014; "Labor Force Data by County," www.bls.gov/Iau/laucntycurl4.txt, U.S. Department ofLabor, Washington, D.C., accessed September 17, 2014.USFWS, 2010, Wetlands and Deepwater Habitats of the Con terminous United States. National WetlandsInventory., U.S. Fish and Wildlife Service, Madison Wisconsin, 2010.USFWS, 2013a, "Flyways.us," Mississippi Flyway, www.flyways.us/flyways/info, U.S. Fish andWildlife Service, Laurel, Maryland, 2013.USFWS, 2013b, "Missouri: County Distribution of Federally Listed Threatened, Endangered, Proposed,and Candidate Species," www.fws.gov/midwest/endangered/Iists/missouri-cty.html, U.S. Fishand Wildlife Service, Columbia, Missouri, updated August 2013.USFWS, 2014, "White-Nose Syndrome: The Devastating Disease of Hibernating Bats in NorthAmerica,"https ://www.whitenosesyndrome .org/sites/defauit/files/resource/white-nose_fact_sheet_6-2014_l.pdf, U.S. Fish and Wildlife Service, Washington, D.C., June 2014.USGS, 1986, National Water Sunimarv, 1986 -Hydrologic Events and Ground Water Quality , WaterSupply Paper 2325, pp. 329-338, U.S. Geological Survey, Reston, Virginia, 1986.USGS. 2002, "Earthquakes in the Central United States 1699 -2002," pubs.usgs.gov/imap/i-28 12/i-2812.jpg, U.S. Geological Survey, Reston, Virginia, June 18, 2002.USGS, 2003, "Scientists Update New Madrid Earthquake Forecasts," U.S. Geological Survey, Reston,Virginia, January 13, 2003.19-303 Chaptr 1 WMI,.013_o2, Rev. OAlviChptr 9.0 -Environmental ReviewUSGS, 2007, "Catastrophic Sinkhole Collapse in Missouri," Fact Sheet 2007-3060, U.S. GeologicalSurvey, Reston, Virginia, July 2007.USGS, 2008, "2008 United States National Seismic Hazard Map No. 3195,"earthquake.usgs.gov/hazards/products/conterminous, U.S. Geological Survey, Reston, Virginiaaccessed July 29, 2013.USGS, 2009, "Earthquake Hazard in the New Madrid Seismic Zone Remains a Concern," Fact Sheet2009-307 1, U.S. Geological Survey, Reston, Virginia, 2009.USGS, 201 la, "Poster of the New Madrid Earthquake Scenario of 16 May 2011 -Magnitude 7.7,"earthquake.usgs .gov/earthquakes/eqarchives/poster/20 11/2011051 6.php, U.S. Geological Survey,Reston, Virginia, accessed July 23, 2013.USGS, 201 lb, "Putting Down Roots in Earthquake County -Your Handbook for Earthquakes in theCentral United States," U.S. Geological Survey, General Information Product 119, Reston,Virginia, 2011.USGS, 2013a, "'Geologic Provinces of the United States: Interior Plain Province,"http://geomaps.wr.usgs.gov/parks/province/intplain.htmI, U.S. Geological Survey, Reston,Virginia, accessed July 12, 2013.USGS, 2013b, "Geologic Provinces of the United States: Atlantic Plain Province,"http://geomaps.wr.usgs.gov/parks/province/atlantpl.html U.S. Geological Survey, Reston,Virginia, accessed July 23, 2013.USGS, 201 3c, "Three Centuries of Earthquakes Poster," pubs.usgs.gov/imap/i-281I2/i-2812.jpg,U.S. Geological Survey, Reston, Virginia, accessed July 23, 2013.USGS, 2013d, "Water Questions & Answers How Much Water Does the Average Person Use at HomePer Day," ga.water.usgs.gov/edu/qa-home-percapita.html, U.S. Geological Survey, Reston,Virginia, accessed October 21, 2013.USGS, 2014, "Mineral Commodity Summaries 2014,"http://minerals.usgs.gov/mineral s/pubs/mcs/2014/mcs20l4.pdf, U.S. Department of the Interior,U.S. Geological Survey, Reston, Virginia, accessed October 6, 2014.Weichman, M. 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OAChapter 19 -Environmental ReviewAppendix ACONSULTATION LETTERSA-i NWMI-2013-021, Rev. 0AChapter 19 -Environmental ReviewThis page intentionally left blank.A-ii NWMI-LR0Bloomingon, MN 5437-145RE: ~~~~~ ~* .. NORTHWEST MEDICAL ISOTOPESLC-PO SERAISTPERDU INRESEARCHPARK, CLUMBIAMISSOU4

DeariMs. Szymanski:

NRthestna MSedcaIstiopes LLCoordnWMaitrprigaoplcainfrsbmsintrheUS ulaReUlS ihator Comisslion (NrC)tc ontuteprtaddcmiso aiiooepoutofaclit Amrica n ald Wsite located inClmiMsor.Th9aii0wudb oatdwti o 5ohUnCIverITY LOfAETTEUNVRIYO MisorISseS(MSstmOisoeyRIdg ReSTEarc Park.RRDGasoprto hwes formcal Icesopes apLiCain TheM NRiwlste preparenappiatin analysubission complane with thceaNeuationalyiomeisinta PoliC) Ato (onEPA)t ofp169ase pand ofteolicesiong pradoces.tp Inraddition, hNRCwillt cRF)ontacste youanditneed initoumiate consoultaio. Tefclt ol elctdwtio5ohWhe aRCreqntcings yoarlycinste applicantiton proess to informs you ofths projesdctio and to askvfronetiNfoMatwion adoumen hsassmn na niomentsrltvtoheandadedangeredpeciesR crticatil hbsbitats, tother willifspecies, wetlands, and any other natural resources that would be relevant to our analysis of this project.To facilitate your review, a short description of the project and a site map of the proposed site arepresented in Attachment A.Your response to this request for information would be most helpful if received by August 14, 2014.Should you have any questions or need additional information, please contact me on 509-430-6921 orcarolyn.haass@nwmedicalisotopes.com.Sincerely;Carolyn C. HaassVice President and Technical Program Directorcc: Michael Brooks, Regional Economic Development, Inc. (Columbia, Missouri)Steven Lauzier, University of MissouriWilliam Schuster, U.S. Nuclear Regulatory CommissionNorthwest Medical Isotopes, LLC I 815 NW 9th Aye, Suite 256 j Corvallis, OR 97330 A TTACHMENTADescription of the Proposed North west Medical Isotopes, LLCRadioisotope Production FacilityNWMI is preparing an application for submission to the NRC to construct, operate, and decommission aRadioisotope Production Facility (RPF). This facility is proposed to be located at the University ofMissouri System (UM System) Discovery Ridge Research Park in Columbia, Missouri. The proposedoperations of the RPF includes fabrication of low enriched uranium (LEU) targets, deliver targets to anetwork of university research nuclear reactors for irradiation, receive irradiated targets, and extract andpurify molybdenum-99 (99Mo) from the irradiated LEU. The LEU would be reclaimed and recycled intotargets for delivery to the network of university research reactors. The 99M would be sold anddistributed through the existing U.S. supply chain network.Schedule* Submit construction application to NRC (4th Q 2014)* NRC review and approval (Expected 4h Q 2015)* Site preparation and construction: (2015 -2016)* Facility Operations (2017 -2045)Site LocationThe proposed 7.5 acre site is situated in Boone County, Missouri, within the UM System, DiscoveryRidge Research Park in Columbia, Missouri north of Discovery Ridge Drive (Figure B-l1). Theapproximate center of the NWMI RPF is Longitude: 920 16'34.63" and Latitude: 38o54'3.31"~.Site DescriptionThe proposed site is located on Lot 15 of the Phase II section of the Discovery Ridge Research Park. Thesite is all on property owned by UM System. The facility would be approximately 330 feet (fi) in thelong dimension and 110 ft wide with a maximum height of 45 ft not counting the stacks (Figure B-2).The site would include an outer fence perimeter and provide the necessary initial security barrier. Thefenced area would include paved roads laid out for the turning radius of tractor/trailers used to transportthe materials.Additional information can be found at the UM Systemr, Discovery Ridge Research Park website,http://www.umsystem.edu/ums/aa/umrpi/discoveryridge.

• &;e+-e° NORTHWEST MEDICAL SOTOPES!_lJr+ %++ + # +'++4./A Proposed LocationW--"' Proposed Building Lot (Lot 15)Discovery Ridge[-7_._ Columbia City Limit0 0.15 0.30.6 0.9 1.2m -- MilesDFigure A-I. Proposed Location NWMI RPF -Discovery Ridge located in Columbia, Missouri

"": NWMI-oO "NORTHWEST MEDICAL ISOTOPESI NWMI Facility A NWMI Site5 Mile (8 kin) Radius from NWMI SiteFence ---Interstate-HighwaysCity Limits0 0.03 0.060.120.180.24sMilesFigure A-2. NWMI RPF General Layout.

• °'°*° *IJuly 14, 2014NWMI-LTR-022Missouri Department of ConservationAtten: Resource Sciences DivisionP.O. Box 180Jefferson City, Mo 65102RE: NORTHWEST MEDICAL ISOTOPES, LLC -PROPOSED RADIOISOTOPE PRODUCTIONFACILITY LOCATED AT THE UNIVERSITY OF MISSOURI SYSTEM DISCOVERY RIDGERESEARCH PARK, COLUMBIA, MISSOURI

Dear Sirs:

Northwest Medical Isotopes, LLC (NWMI) is preparing an application for submission to the U.S. NuclearRegulatory Commission (NRC) to construct, operate, and decommission a radioisotope productionfacility (RPF) on a site located in Columbia, Missouri. The facility would be located within lot 15 of theUniversity of Missouri System (UM System) Discovery Ridge Research Park (T.48N -R. 12W).The NRC requires a license applicant to assess the impacts of its proposed action on the environment.NWMI will document this assessment in an Environmental report (ER) that will be submitted to the NRCas part of the formal license application. The NRC will then prepare an analysis in compliance with theNational Environmental Policy Act (NEPA) of 1969 as part of the licensing process. In addition, theNRC will contact you and if needed initiate consultation.We are contacting you early in the application process to inform you of this project and to ask forinformation and comments relative to State of Missouri species of conservation concern, critical habitats,wetlands, and any other natural resources that would be relevant to our analysis of this project. Tofacilitate your review, a short description of the project and a site map of the proposed site are presentedin Attachment A.Your response to this request for information would be most helpful if received by August 14, 2014.Should you have any questions or need additional information, please contact me on 509-430-6921 orcarolyn.haass@nwmedical isotopes.com.Sincerely;Carolyn C. HaassVice President and Technical Program Directorcc: Michael Brooks, Regional Economic Development, Inc. (Columbia, Missouri)Steven Lauzier, University of MissouriWilliam Schuster, U.S. Nuclear Regulatory CommissionNorthwest Medical Isotopes, LLC I 815 NW 9th Aye, Suite 256 I Corvallis, OR 97330

• oe:*NORTHWEST MEDICAL IOOEA TTACHMENTADescription of the Proposed Northwest Medical Isotopes, LLCRadioisotope Production FacilityNWMI is preparing an application for submission to the NRC to construct, operate, and decommission aRadioisotope Production Facility (RPF). This facility is proposed to be located at the University ofMissouri System (UM System) Discovery Ridge Research Park in Columbia, Missouri. The proposedoperations of the RPF includes fabrication of low enriched uranium (LEU) targets, deliver targets to anetwork of university research nuclear reactors for irradiation, receive irradiated targets, and extract andpurify molybdenum-99 from the irradiated LEU. The LEU would be reclaimed and recycled intotargets for delivery to the network of university research reactors. The 99M would be sold anddistributed through the existing U.S. supply chain network.Schedule* Submit construction application to NRC (4th Q 2014)* NRC review and approval (Expected 4th Q 2015)* Site preparation and construction: (2015 -2016)* Facility Operations (2017 -2045)Site LocationThe proposed 7.5 acre site is situated in Boone County, Missouri, within the UM System, DiscoveryRidge Research Park in Columbia, Missouri north of Discovery Ridge Drive (Figure B-l). Theapproximate center of the NWMI RPF is Longitude: 92° 16'34.63"~ and Latitude: 38o54'3.31"~.Site DescriptionThe proposed site is located on Lot 15 of the Phase II section of the Discovery Ridge Research Park. Thesite is all on property owned by UM System. The facility would be approximately 330 feet (ft) in thelong dimension and 110 ft wide with a maximum height of 45 ft not counting the stacks (Figure B-2).The site would include an outer fence perimeter and provide the necessary initial security barrier. Thefenced area would include paved roads laid out for the turning radius of tractor/trailers used to transportthe materials.Additional information can be found at the UM System, Discovery Ridge Research Park website,http://www.umsystem.edu/ums/aa/umnrpi/discoveryridge.

""NWMIS, -NORTHWEST MEDICAL ISOTOPES" iUF\aA Proposed Location[I'Proposed Building Lot (Lot 15)Discovery Ridge7".. 7 Columbia City Limit0 0.15 0.30.6 0.9 1.2am MilesFigure A-I. Proposed Location NWMI RPF -Discovery Ridge located in Columbia, Missouri 0.@o0.**.,,NORTHWEST MEDICAL IOOESNWMI Faiiy A NWMI SiteO 5 Mile (8 kmn) Radius from NWMI SiteFence --Interstatelq -HighwaysCity Limits0 0.03 0.06 0.12 0.18 0.24MilesMilesFigure A-2. NWMI RPF General Layout.

July 14, 2014NWMI-LTR-0 15The Honorable Scott BighorsePrincipal ChiefOsage NationP. 0. Box 779 GrandviewPawhuska, Oklahoma 74056RE: NORTHWEST MEDICAL ISOTOPES, LLC -PROPOSED RADIOISOTOPE PRODUCTIONFACILITY LOCATED AT THE UNIVERSITY OF MISSOURI SYSTEM DISCOVERY RIDGERESEARCH PARK, COLUMBIA, MISSOURI

Dear Mr. Bighorse:

Northwest Medical Isotopes, LLC (NWMI) is preparing an application for submission to the U.S. NuclearRegulatory Commission (NRC) to construct, operate, and decommission a radioisotope productionfacility (RPF) on a site located in Columbia, Missouri. The facility would be located within lot 15 of theUniversity of Missouri System (UM System) Discovery Ridge Research Park.The NRC requires a license applicant to assess the impacts of its proposed action on the environment.NWMI will document this assessment in an Environmental report (ER) that will be submitted to the NRCas part of the formal license application. The NRC will then prepare an analysis in compliance with theNational Environmental Policy Act (NEPA) of 1969 as part of the licensing process. In addition, theNRC will contact you and if needed initiate consultation.We are contacting you early in the application process to inform you of this proposed project and to askfor information and comments relative to the following:* Information you may have regarding historic sites or cultural resources within or near theproposed site* Any specific knowledge of any locations on or near the site that you believe have traditionalreligious and cultural significanceA Cultural Resource Investigations Phase 1 Survey has been completed for the proposed site (AttachmentA). No on-site historical properties or archeological sites were identified. In addition, a short descriptionof the project and a site map of the proposed site are presented in Attachment B.Your response to this request for information would be most helpful if received by August 14, 2014.Should you have any questions or need additional information, please contact me on 509-430-6921 orcarolyn.haass@nwmedicalisotopes.com.Sincerely;Carolyn C. HaassVice President and Technical Program Directorcc: Michael Brooks, Regional Economic Development, Inc. (Columbia, Missouri)Steven Lauzier, University of MissouriWilliam Schuster, U.S. Nuclear Regulatory CommissionNorthwest Medical Isotopes, LLC [815 NW 9th Aye, Suite 256 I Corvallis, OR 97330

• ..O O*."* ... NOR'I"IWEST MEDICAL ISOTOPEJuly 14, 2014NWMI-LTR-0 18The Honorable Gary PrattChairpersonIowa Tribe of Oklahoma335588 East 750 RoadPerkins, Oklahoma 74059RE: NORTHWEST MEDICAL ISOTOPES, LLC -PROPOSED RADIOISOTOPE PRODUCTIONFACILITY LOCATED AT THE UNIVERSITY OF MISSOURI SYSTEM DISCOVERY RIDGERESEARCH PARK, COLUMBIA, MISSOURI

Dear Mr. Pratt:

Northwest Medical Isotopes, LLC (NWMI) is preparing an application for submission to the U.S. NuclearRegulatory Commission (NRC) to construct, operate, and decommission a radioisotope productionfacility (RPF) on a site located in Columbia, Missouri. The facility would be located within lot 15 of theUniversity of Missouri System (UM System) Discovery Ridge Research Park.The NRC requires a license applicant to assess the impacts of its proposed action on the environment.NWMI will document this assessment in an Environmental report (ER) that will be submitted to the NRCas part of the formal license application. The NRC will then prepare an analysis in compliance with theNational Environmental Policy Act (NEPA) of 1969 as part of the licensing process. In addition, theNRC will contact you and if needed initiate consultation.We are contacting you early in the application process to inform you of this proposed project and to askfor information and comments relative to the following:* Information you may have regarding historic sites or cultural resources within or near theproposed site* Any specific knowledge of any locations on or near the site that you believe have traditionalreligious and cultural significanceA Cultural Resource Investigations Phase 1 Survey has been completed for the proposed site (AttachmentA). No on-site historical properties or archeological sites were identified. In addition, a short descriptionof the project and a site map of the proposed site are presented in Attachment B.Your response to this request for information would be most helpful if received by August 14, 2014.Should you have any questions or need additional information, please contact me on 509-430-6921 orcarolyn.haass@nwmedicalisotopes.com.Sincerely;Carolyn C. HaassVice President and Technical Program Directorcc: Michael Brooks, Regional Economic Development, Inc. (Columbia, Missouri)Steven Lauzier, University of MissouriWilliam Schuster, U.S. Nuclear Regulatory CommissionNorthwest Medical Isotopes, LLC I 815 NW 9th Aye, Suite 256 I Corvallis, OR 97330

'*= N WMI*.*. NORTHWEST MEDICAL ISOTOPESJuly 14, 2014NWMI-LTR-0 1 7The Honorable Guy MunroeChairKaw NationP.O. Box 50Kaw City, Oklahoma 74641RE: NORTHWEST MEDICAL ISOTOPES, LLC -PROPOSED RADIOISOTOPE PRODUCTIONFACILITY LOCATED AT THE UNIVERSITY OF MISSOURI SYSTEM DISCOVERY RIDGERESEARCH PARK, COLUMBIA, MISSOURI

Dear Mr. Munroe:

Northwest Medical Isotopes, LLC (NWMI) is preparing an application for submission to the U.S. NuclearRegulatory Commission (NRC) to construct, operate, and decommission a radioisotope productionfacility (RPF) on a site located in Columbia, Missouri. The facility would be located within lot 15 of theUniversity of Missouri System (UM System) Discovery Ridge Research Park.The NRC requires a license applicant to assess the impacts of its proposed action on the environment.NWMI will document this assessment in an Environmental report (ER) that will be submitted to the NRCas part of the formal license application. The NRC will then prepare an analysis in compliance with theNational Environmental Policy Act (NEPA) of 1969 as part of the licensing process. In addition, theNRC will contact you and if needed initiate consultation.We are contacting you early in the application process to inform you of this proposed project and to askfor information and comments relative to the following:* Information you may have regarding historic sites or cultural resources within or near theproposed site* Any specific knowledge of any locations on or near the site that you believe have traditionalreligious and cultural significanceA Cultural Resource Investigations Phase 1 Survey has been completed for the proposed site (AttachmentA). No on-site historical properties or archeological sites were identified. In addition, a short descriptionof the project and a site map of the proposed site are presented in Attachment B.Your response to this request for information would be most helpful if received by August 14, 2014.Should you have any questions or need additional information, please contact me on 509-430-6921 orcarolyn.haass@nwmedicalisotopes.com.Sincerely;Carolyn C. HaassVice President and Technical Program Directorcc: Michael Brooks, Regional Economic Development, Inc. (Columbia, Missouri)Steven Lauzier, University of MissouriWilliam Schuster, U.S. Nuclear Regulatory CommissionNorthwest Medical Isotopes, LLC 815 NW 9th Ave, Suite 256 I Corvallis, OR 97330 S...-NORTHWEST MEDICALW M .TPEJuly 14, 2014NWMI-LTR-0 16The Honorable Douglas G. LankfordChiefMiami Tribe of OklahomaP.O. Box 1326Miami, Oklahoma 74354RE: NORTHWEST MEDICAL ISOTOPES, LLC -PROPOSED RADIOISOTOPE PRODUCTIONFACILITY LOCATED AT THE UNIVERSITY OF MISSOURI SYSTEM DISCOVERY RIDGERESEARCH PARK, COLUMBIA, MISSOURI

Dear Mr. Lankford:

Northwest Medical Isotopes, LLC (NWMI) is preparing an application for submission to the U.S. NuclearRegulatory Commission (NRC) to construct, operate, and decommission a radioisotope productionfacility (RPF) on a site located in Columbia, Missouri. The facility would be located within lot 15 of theUniversity of Missouri System (UM System) Discovery Ridge Research Park.The NRC requires a license applicant to assess the impacts of its proposed action on the environment.NWMI will document this assessment in an Environmental report (ER) that will be submitted to the NRCas part of the formal license application. The NRC will then prepare an analysis in compliance with theNational Environmnental Policy Act (NEPA) of 1969 as part of the licensing process. In addition, theNRC will contact you and if needed initiate consultation.We are contacting you early in the application process to inform you of this proposed project and to askfor information and comments relative to the following:* Information you may have regarding historic sites or cultural resources within or near theproposed site° Any specific knowledge of any locations on or near the site that you believe have traditionalreligious and cultural significanceA Cultural Resource Investigations Phase 1 Survey has been completed for the proposed site (Attachment*A). No on-site historical properties or archeological sites were identified. In addition, a short descriptionof the project and a site map of the proposed site are presented in Attachment B.Your response to this request for information would be most helpful if received by August 14, 2014.Should you have any questions or need additional information, please contact me on 509-430-6921 orcarolyn.haass@nwmedicalisotopes.com.Sincerely;Carolyn C. HaassVice President and Technical Program Directorcc: Michael Brooks, Regional Economic Development, Inc. (Columbia, Missouri)Steven Lauzier, University of MissouriWilliam Schuster, U.S. Nuclear Regulatory CommissionNorthwest Medical Isotopes, LLC I 815 NW 9th Aye, Suite 256 I Corvallis, OR 97330

• .,o~o:O..n N iv mumN , o ORTIHWEST MEDICAL ISOTOPESJuly 14, 2014NWMI-LTR-0 19The Honorable Clifford Wolfe, Jr.ChairmanOmaha Tribe of NebraskaP0 Box 368Macy, Nebraska 68039RE: NORTHWEST MEDICAL ISOTOPES, LLC -PROPOSED RADIOISOTOPE PRODUCTIONFACILITY LOCATED AT THE UNIVERSITY OF MISSOURI SYSTEM DISCOVERY RIDGERESEARCH PARK, COLUMBIA, MISSOURI

Dear Mr. Wolfe:

Northwest Medical Isotopes, LLC (NWMI) is preparing an application for submission to the U.S. NuclearRegulatory Commission (NRC) to construct, operate, and decommission a radioisotope productionfacility (RPF) on a site located in Columbia, Missouri. The facility would be located within lot 15 of theUniversity of Missouri System (UM System) Discovery Ridge Research Park.The NRC requires a license applicant to assess the impacts of its proposed action on the environment.NWMI will document this assessment in an Environmental report (ER) that will be submitted to the NRCas part of the formal license application. The NRC will then prepare an analysis in compliance with theNational Environmental Policy Act (NEPA) of 1969 as part of the licensing process. In addition, theNRC will contact you and if needed initiate consultation.We are contacting you early in the application process to inform you of this proposed project and to askfor information and comments relative to the following:*Information you may have regarding historic sites or cultural resources within or near theproposed site* Any specific knowledge of any locations on or near the site that you believe have traditionalreligious and cultural significanceA Cultural Resource Investigations Phase I Survey has been completed for the proposed site (AttachmentA). No on-site historical properties or archeological sites were identifiedL In addition, a short descriptionof the project and a site map of the proposed site are presented in Attachment B.Your response to this request for information would be most helpful if received by August 14, 2014.Should you have any questions or need additional information, please contact me on 509-430-6921 orcarolyn.haass@nwmedicalisotopes.com.Sincerely;Carolyn C. HaassVice President and Technical Program Directorcc: Michael Brooks, Regional Economic Development, Inc. (Columbia, Missouri)Steven Lauzier, University of MissouriWilliam Schuster, U.S. Nuclear Regulatory Commission*Northwest Medical Isotopes, LLC I 815 NW 9th Aye, Suite 256 Corvallis, OR 97330

.e000e.'.00 0e..July 14, 2014NWMI-LTR-020The Honorable Robert Flying HawkChairmanYankton Sioux Tribe of South DakotaP0 Box 1153Wagner, South Dakota 57380RE: NORTHWEST MEDICAL ISOTOPES, LLC -PROPOSED RADIOISOTOPE PRODUCTIONFACILITY LOCATED AT THE UNIVERSITY OF MISSOURI SYSTEM DISCOVERY RIDGERESEARCH PARK, COLUMBIA, MISSOURI

Dear Mr. Flying Hawk:

Northwest Medical Isotopes, LLC (NWMI) is preparing an application for submission to the U.S. NuclearRegulatory Commission (NRC) to construct, operate, and decommission a radioisotope productionfacility (RPF) on a site located in Columbia, Missouri. The facility would be located within lot 15 of theUniversity of Missouri System (UM System) Discovery Ridge Research Park.The NRC requires a license applicant to assess the impacts of its proposed action on the environment.NWMI will document this assessment in an Environmental report (ER) that will be submitted to the NRCas part of the formal license application. The NRC will then prepare an analysis in compliance with theNational Environmental Policy Act (NEPA) of 1969 as part of the licensing process. In addition, theNRC will contact you and if needed initiate consultation.We are contacting you early in the application process to inform you of this proposed project and to askfor information and comments relative to the following:* Information you may have regarding historic sites or cultural resources within or near theproposed site* Any specific knowledge of any locations on or near the site that you believe have traditionalreligious and cultural significanceA Cultural Resource Investigations Phase 1 Survey has been completed for the proposed site (AttachmentA). No on-site historical properties or archeological sites were identified. In addition, a short descriptionof the project and a site map of the proposed site are presented in Attachment B.Your response to this request for information would be most helpful if received by August 14, 2014.Should you have any questions or need additional information, please contact me on 509-430-6921 orcarolyn.haass@nwmedicalisotopes.com.Sincerely;Carolyn C. HaassVice President and Technical Program Directorcc: Michael Brooks, Regional Economic Development, Inc. (Columbia, Missouri)Steven Lauzier, University of MissouriWilliam Schuster, U.S. Nuclear Regulatory CommissionNorthwest Medical Isotopes, LLC 81i5 NW 9th Aye, Suite 256 I Corvallis, OR 97330

!

NWMI* ...NORTHWEST MEDICAL ISOTOPESA TTA CHMENTACultural Resource InvestigationPhase 1 Survey Cultural Resource InvestigationsPhase I SurveyLot 15 -Discovery RidgeBoone County, MissouriNuclear Regulatory Commission ProjectPrepared for

Northwest Medical Isotopes L.L.C.Prepared By:Environmental Research Center of Missouri, Inc.1201 Moreau DriveJefferson City, MissouriPhone: 573-635-9569Email: craipqsturdevant(,mchs .comPrincipal Investigator:Craig SturdevantSeptember 2013ERC Project No. 3023ERG ABSTRACTDuring September 2013 a Phase I cultural resources survey was carried out for a7.5 acre tract of land at Discovery Ridge, Boone County, Missouri. The area is thelocation of a proposed commercial development project.There are no National Register of Historic Places (NRI-P) properties locatedwithin the proposed project area; State Historic Preservation Office (SHPO) GIS recordsindicate presence of no recorded archaeology sites within the project boundaries; and norecorded SHPO historic architectural sites are present within the project area of potentialeffect. 19t century plat maps do not illustrate any structures within the project area.The field investigation was carried out under poor surface visibility conditions ina grass/hay setting. Shovel testing was implemented following guidelines described inthis report. No evidence of the presence of prehistoric occupation was identified withinthe project area. No evidence of the presence of early historic occupation was identifiedwithin the project boundaries.On the basis of the negative findings regarding presence of possibly significantcultural resources, it is the recommendation of this Phase I cultural resources survey thatthe proposed project proceed as planned in terms of Section 106 compliance concerns.No significant cultural resources will be threatened by the proposed project actions.

TABLE OF CONTENTSABSTRACT 1TABLE OF CONTENTS2LIST OF FIGURES 3INTRODUCTION 4Purpose of Study 4Project Personnel and Schedule 5The Project 5INVESTIGATION METHODS 7Introduction 7Records and Literature Review 7Field Procedures 8Analysis Procedures 9Statement of Findings and Recommendations 10PROJECT SETTING 11Environmental Setting 11Cultural Setting 12INVESTIGATION FINDINGS 18Records and Literature Review 18Field Investigation Findings 21RECOMMENDATIONS 24BIBLIOGRAPHY 252 LIST OF FIGURESFigure 1.USGS Quadrangle Location of Project Area Surveyed& Cultural Resources6Figure 2.DNR Study Unit Location of Project 13Figure 3.SI-PG GIS Archaeology & Survey Layers in Relation to the Project 22Figure 4.Aerial Photograph of Project Area Surveyed 233 INTRODUCTIONPurpose of StudyIn compliance with current environmental regulations and policies, NorthwestMedical Isotopes L.L.C. entered into a contractual agreement with EnvironmentalResearch Center of Missouri, Inc. (ERC) to conduct a Phase I cultural resource survey ofa 7.5 acre tract of land at Discovery Ridge in Boone County, Missouri. The studyfollowed the Missouri Department of Natural Resources (DNR) "Guidelines for CulturalResource Contract Reports and Professional Qualifications" and is submitted inaccordance with current environmental regulations and policies and in agreement withthe study contract.The project actions included discussion of the project with Missouri Departmentof Natural Resources/Historic Preservation Program staff, a records and literature review,and an intensive pedestrian field investigation of the project area. The study methodsused are described and the results of the findings of these actions are presented in termsof cultural resource descriptions, when present, and recommendations for culturalresource compliance in reference to the proposed project actions. The project areacultural and environmental settings are briefly described.Under state and federal legislation and policies outlined by the Antiquities Act of1906, the Historic Sites Act of 1935, the National Historic Preservation Act (NIHPA) of1966 as amended, the National Environmental Policy Act of 1970, the 1986 Protection ofHistoric Properties and other regulations regarding specific activities such as stripmining, it is necessary to inventory archaeological and historical resources located withinproposed project areas which may be threatened by federally regulated or funded actionsand evaluate any disruptive effects these actions might have on resources that are present.Briefly, the National Historic Preservation Act requires that an area threatened by afederally funded and/or regulated project consider cultural resources which might beimpacted by project related actions; the State Historic Preservation Officer (SH-PO)and/or federal agency involved may request that a cultural resource survey be conductedprior to granting permission to proceed with the proposed project actions. If any culturalresources are identified, they are evaluated in terms of National Register of HistoricPlaces (NRHP) eligibility criteria. Where NRH-P eligible sites are found to occupycompliance project areas, consultation is initiated which may include the AdvisoryCouncil on Historic Preservation (Council), the SHPO, and the governmental agencyinvolved in the project. If an eligible site cannot be avoided, a Memorandum ofAgreement may be prepared which would stipulate specific compliance actions to beinitiated prior to project actions. The project initiator, if not a federal agency, may berequested to concur. The present project is partially funded or regulated by a federalagency. As a result, cultural resource compliance has been implemented by a federalagency and Missouri SHPO and the present survey has been carried out in order to meetNHPA requirements.4 Project Personnel and ScheduleThe present project was carried out during December 2010. Principal Investigatorand report author is Craig Sturdevant. Sturdevant has a Master of Arts degree inAnthropology from the University of Iowa, Iowa City and meets state and federalrequirements for Principal Investigator for cultural resource compliance projects. JohnCarrel, ERC research associate, was field technician for the project.The ProiectThe total proposed project area includes approximately 7.5 acres of land locatedsouth of Columbia on the east side of US 63 in the commercial area known as DiscoveryRidge. A detailed project plan and profile was not included in the scope of work and itwas assumed that any cultural resources located within area surveyed would bethreatened by project actions. The project is located in Section 33, Township 48 North,Range 12 West, Boone County, Missouri (Figure 1).The present investigation has been carried out utilizing Phase I survey proceduresas outlined in the methods. section of this report and available standard procedures fordetermining presence/absence of buried resources. Findings and recommendations aremade with the understanding that it sometimes may not be possible to identify allpossibly significant resources within a project area, particularly where vegetation isextremely heavy or valley settings with deep alluvium.5

[Proprietary Information]6 INVESTIGATION METHODSIntroductionThe major goal of the this investigation was the inventory and evaluation ofcultural resources within the designated project zone through the use of currentlyaccepted Phase I survey techniques and records and literature review. It is important thatsufficient data are collected to allow development of appropriate recommendationsconcerning the significance of the identified cultural resources in the project zone interms of National Register of Historic Places (NRI-P) eligibility criteria. The methodsand techniques used during the present investigation allowed an intensity of coverage thatshould have identified all potentially significant cultural resources. Deeply buried sitesand very low material density sites are possible to miss no matter how intensive thesurvey techniques. This study has been initiated in order to carry out federally mandatedSection 106 compliance regulations. The scope of work placed emphasis uponidentification of cultural resources within the project area along with recovery ofsufficient data to allow the Missouri SHPO to make an informed determination ofpossible significance of those resources.The following section includes a discussion of the methods that have beenemployed in this study. These consist of a pre-field evaluation of pertinent literature andrecords from which the field survey techniques and site designation criteria aredeveloped, an intensive pedestrian survey of the project area, an attempt to recoversufficient data for site designation and evaluation in terms of NRA-P eligibilityrequirements, notation of locational information regarding site provenience andphysiographic setting, post-field activates involving data analysis, and report preparation.The methods and techniques and justifications for interpretations are discussed below.Records & Literature ReviewA review of relevant publications and records prior to the field component of thestudy is important in establishing an understanding of the cultural sequence and types ofcultural resources which might be expected to occur. The process begins with review ofcultural resource management (CRM) reports that have been produced for the areas nearthe project zone. These reports are housed in the Missouri Department of NaturalResources State Historic Preservation Office (SHPO), Jefferson City, Missouri and arecatalogued by county as well as author. The repository also includes historic -architecture site forms for the state, NRA-lP forms for Missouri, and correspondenceregarding the proposed project. Archaeological Survey of Missouri (ASM) recordslocated at the SHPO were also reviewed. The ASM files contain information on reportedarchaeological sites in Missouri that have been gathered for over 70 years which arecatalogued by county and section, township, and range and UTM coordinates. TheSHPO GIS data includes overlays illustrating recorded archaeology sites and areas thathave been the subject of previous cultural resource surveys. Other resources consulted7 that contain important data include the state library in Jefferson City, the State Archivesin Jefferson City, local historic societies when available, and the State Historic Society inColumbia. Other archaeologists and architectural historians, particularly those employedby the state that are involved with Section 106 procedures, are consulted regarding theirknowledge of significant cultural resources in a project area.Field ProceduresThe archaeological field component of the present study involved pedestriancoverage of the defined project area by ERC personnel. Transect width utilized rangedfrom 5 to 15 meters depending upon visibility and site potential based on terrain, streams,and other factors that have been shown to correlate with site presence/absence such aspresettlement prairie or woodland setting. All vegetation-free zones are observed forpresence of prehistoric cultural materials. Throughout most of Missouri, this can includelithic debitage (chert flakes and shatter), fire-cracked rock, pottery sherds andoccasionally bone and shell fragments. Features such as fire hearths and burial tumulimay also be encountered. Where vegetation covers the surface for over 10 meters, shoveltests are implemented. This involves removal of around a 50 cm by 50 cm area of sodand then controlled removal of subsurface soil matrix to depths of up to 50 cm belowsurface. Soils are carefully observed to determine presence/absence of cultural evidence.Where soil conditions allow, soils are screened through a portable 1/4 inch screen. Shoveltesting that does not include screening of matrix is implemented where larger numbers ofshovel tests are necessary and surface visibility conditions are poor. In this instance, soilmatrix is removed by shovel and carefully scraped with a trowel to look forprehistoric/early historic evidence.Where evidence of presence of an archaeological resource is defined, the locationis noted on a U.S.G.S. quadrangle and a sketch map and description of the site area arefield prepared. Where features or structures are encountered, photographs are taken. Thefield procedures incorporated in the pedestrian survey are directed toward two majorgoals: The first was the inventory of all possibly significant cultural resources within theproject zone and the second the attempt to recover sufficient information to allowinterpretation of NRH-P eligibility of these sites by the MoSHPO.While subjective, ERC has developed a set of criteria for determining thepresence of an archaeological resource, which are currently accepted by the SHPO asappropriate. These criteria are not presented as appropriate for all situations but as thegeneral practice followed by ERC in making decisions regarding presence/absence ofarchaeological resources for cultural resource compliance purposes. One extreme wouldrecord a site where any evidence of cultural activity occurs. The other extreme wouldrequire a significant cultural resource to be present to result in recording a site. Thepresent approach attempts to find a middle ground, which hopefully allows for furtherconsideration for both the cultural resource and the proposed project action prior to threatto either.8 An archaeology site is designated when evidence of prehistoric and/or earlyhistoric land use is present and at least one of the following specific criteria is met:A. A prehistoric feature is presentB. Two or more artifacts are identified within a 10 by 10mn or less areaC. A shovel test recovers 2 or more artifacts.Where a site is identified and when the landowner grants permission, materialsrecovered by the field investigation are placed in field site number marked collectionbags. If permlission is not attained, materials are observed and potential diagnostics andtools measured, photographed and left in the field or given to the landowner whenrequested. When a permlanent site number is assigned, retained materials are curated withthe site designation. Where material density at a site is obviously high only arepresentative sample is retained.Historic architecture resources include structures and features. Where structuresare present that are over 45 years old or exhibit some form of possible exceptionalsignificance they are photographed and a description of architectural features is preparedalong with preliminary evaluation of NRHIP eligibility when located within a directimpact project zone. Historic structures are not recorded where it is obvious that thestructures are less than 45 years old and not significant in any other respect. Where anarea of potential effect (APE)*has been established beyond the physical APE,architectural resources within this defined APE obviously 45 years or older arephotographed and located on report maps.Analysis ProceduresSignificance of cultural resources is interpreted from National Register of HistoricPlace eligibility criteria that are listed below:"The quality of significance in American History, architecture, archaeology, andculture is present in districts, sites, buildings, structures, and objects that possessintegrity of location, design, setting, materials, workmanship, feeling andassociation, and:A) that are associated with events thathave made a significant contribution to thebroad patterns of our history; orB) that are associated with the lives of persons significant in our past; or9 C) that embody the distinctive characteristics of type, period, or method ofconstruction, or that represent the work of a master, or that possess high artisticvalues, or that represent a significant distinguishing entity whose componentsmay lack individual distinction; orD) that have yielded, or may be likely to yield, information important inprehistory or history: (36 CFR Part 60.6).Cultural resources that are identified during the Phase I survey are evaluated interms of meeting one or more of the above criteria. In general, archaeological sites mostoften are evaluated with reference to D above. A statewide planning document wasprepared by the DNR/HPP that allows minimal means for evaluation of potentialsignificance of cultural resources (Weichman and Weston 1986). The statewide planincludes information regarding traditions, types of traditions expected, forms of data thatmay be potentially important, and research questions that can be incorporated in theinterpretation of cultural resource significance where available. Generally, a culturalresource will be evaluated on the basis of types of materials recovered (uniqueness,affiliation, type), resource integrity (degree of disturbance), and material/feature density(density and quantity of artifacts and presence and number of potentially extant featuressuch as hearths, house sites, and burial tumuli). Usually, if an archaeological site exhibitssub-plow zone integrity and produces diagnostic artifacts or features, the site isinterpreted as significant in that it would very likely contain sufficient data to contributeto the understanding of the cultural history of the area and meet NRHP eligibilitycriterion D. The consultant makes recommendations regarding NRHP eligibility. Thedetermination of eligibility process requires consultation with the SI-PO and the federalagency involved in the project.Statement of Findings and RecommendationsWhere ERC locates a cultural resource within the designated project boundaries,recommendations of significance and justification are made to the MoSHPO and thefederal agency involved. A decision regarding significance would be made at that levelin terms of possible NRHP eligibility of the resource. Recommendations that may bemade include "not eligible for NRiI-P status", "possibly eligible for NRHP status", or"~eligible for NRHP status." Where a recommendation of not eligible is accepted by theSI-PO and federal agency a proposed compliance project can proceed as planned; arecommendation of possibly eligible results in agency request that the project bemodified to avoid the resource or given further evaluation in order to establish NRHPeligibility; a recommendation of eligible results in a request to modify the project toavoid the cultural resource or proceed with the consultation process as outlined by 36CFR Part 800: Protection of Historic Properties that governs the Section 106 reviewprocess established by the National Historic Preservation Act of 1966 as amended.10 PROJECT SETTINGEnvironmental SettingThe project area lies on the border of the Dissected Till Plains to the north andOzark Plateau on the south in Central Lowlands Province of North America. Thebedrock in the area consists of Mississippian limestones covered with varying depths ofclays and glacial drift as well as limestone residuum and colluvium and alluvium (cf.B~ranson 1944; Stout and Hoffman 1973).The project is located within a presettlement prairie zone (Kucera 1961;Schroeder 19891:7) in an upland divide between Cedar Creek on the east and BonneFemme headwaters on the west. The area exhibited a wide variety of indigenous floralspecies in the past (Chapman 1975:12-16). Early surveyors list several species of oak,hickory, black walnut, hackberry, sycamore, elm, and elders in the bottoms along withopen oak-hickory upland woodlands to the east, west, and south and grasses that wouldhave included Big and Little Bluestem, Indian Grass, Switch Grass, Side-oats Grama, andpockets of Bluejoint and Canada Wild Rye in the project area (Allgood and Persinger1979:60).Some species of animals present during the pioneer period have been extirpatedfrom their former ranges since the Euro-American settlement of the area. These speciesinclude gray wolf, elk, and bison (Chapman 1975). The mountain lion and black bearoccur rarely in the forested regions of the interior Ozark Highlands (Wood and McMillan1976). More common species in the drainage basin include white-tailed deer, gray fox,red fox, coyote, raccoon, beaver, bobcat, mink, opossum, muskrat, spotted skunk,squirrels, rabbit, and woodchuck. It is probable that the project area exhibited typicalprairie/woodland ecotonal populations in which a variety of large and small game wasavailable in both woodland and prairie settings.The climate within the project area is midcontinental and experiences temperatureextremes both seasonally and on a day-to-day basis. This area of Missouri is in the pathof cold air moving down out of Canada, warm moist air coming up from the Gulf ofMexico, and dry air from the west. The mean annual precipitation in the area is around40 inches which includes 12 to 17 inches of snow per year. The mean length of thegrowing season is around 187 days. The killing freezes generally begin between October15 and 20 and end between April 15 and 20 (Chapman 1975).The project area exhibits few characteristics suggesting high potential forpresence of intensive or extensive prehistoric occupation. The counties north of theMissouri river exhibit an ecotonal situation that included a relatively high percentage ofpresettlement prairie and lesser amount of presettlement woodland (Schroeder 1981).While Boone County was made up only of 16% presettlemnent prairie, the present projectoccupies the only expansive prairie zone in the county. Earlier studies have well11 illustrated the finding that known prehistoric occupations in the region are almost entirelylocated within presettlement woodland zones with less than 3% of the known prehistoricsites found within presettlement prairie zones (cf. Sturdevant 1983). Another majorconsideration that appears to have entered into prehistoric site selection involvedavailability of cherts that were a primary raw material for much of the subsistencetechnology. Bedrock in the general area does include Missisippian age cherts that wereutilized extensively by prehistoric occupants as raw material for tools. These chertswould not have been easily accessible in the project area. The project setting would havealso lacked immediate availability of a consistent water supply necessary to support anyintensive or extensive human habitation resulting in a low prehistoric site potential.Cultural SettingThe project is located in the Central Missouri Drainage Basin (Figure 2). Theoccupation of Missouri by prehistoric populations has been generally established toinclude nine to ten traditions (cf. Chapman 1975; 1980). These traditions apply invarying degree to the entire state with some traditions often not accounted for in specificdrainages. These traditions are incorporated in what is called the cultural sequence whichis a major factor utilized in interpretation of cultural data, particularly, regarding NationalRegister of Historic Place (NRI-P) significance. These traditions are listed below in thesequence provided by Chapman (1975; 1980).Paleo-Indian 12000 to 8000 B.C.Dalton 8000 to 7000 B.C.Early Archaic 7000 to 5000 B.C.Middle Archaic 5000 to 3000 B.C.Late Archaic 3000 to 1000 B.C.Early Woodland 1000 to 500 B.C.Middle Woodland 500 B.C. to A.D. 400Late Woodland A.D. 400 to 900Mississippian A.D. 900 to 1400Paleo-Indian: With the exception of a possible earlier "Early Man" tradition, thePaleo-Indian is generally accepted as the earliest known occupation of Missouri. Thesespecialized hunters lived in small nomadic bands or family groups and left some traces oftheir transitory settlement pattern in the forms of hunting camps, kill sites, quarry sites,and possibly small base camps (cf. Ford 1974:388). The major diagnostic materialsassociated with the occupation includes the Clovis and Folsom fluted spear/knife points.Most fluted point finds have been located along major river valleys such as the MissouriRiver although some have been recovered along streams such as the Moreau River. Thishas been suggested to indicate that these nomadic hunters and gatherers followed thesestreams in their movement through the Midwest area. Chapman indicates that his divisionof the Northeast and Northwest Prairie region at a point in Cooper and Howard countiesabove Boonville on the Missouri River separates the major occupation zones of the12

.30~IC'~ KOCA WA?SCALEo 40 80MILES0 30 80 00 120 KILOMETEAS-~PR1KOPL DROMAGA AASNS--tlIcs~oFigure 2.DNR Study Unit/Drainage Basin Location of ProjectPaleo-Indian populations. That is, the steep bluffs below this point appear to have beenmore conducive to Paleo-Indian occupation than the more prairie related terrain abovethis point. Fluted points are generally more plentiful below thispoint toward St. Louisthan above this point toward Kansas City (Chapman 1975:75). Chapman's review ofPaleo-Indian diagnostics illustrates larger numbers of reported fluted points beginning inHoward County and continuing toward St. Louis with a small number reported fromCallaway County (1975:67).Dalton: Chapman characterizes the Dalton period as a time of transition fromPaleo-Indian big game hunting to the hunting-foraging subsistence strategy of thefollowing Archaic period (1975:96). All known Dalton sites in Missouri are small camps13 and all apparently represent short-term utilization. The basic Paleo-Indian tool kit wasstill in use during Dalton times although tools associated with plant food processingwere added. Point types with long flutes have been replaced by types with basal thinningand or short flutes. The major diagnostic includes the Dalton Serrated and perhaps theDalton adze. Distribution roughly parallels the Paleo-Indian.Early Archaic: By the Early Archaic the transition to a subsistence pattern basedon foraging was well underway. Subsistence activities were broadened to exploit moreecological niches. Hunting and gathering continued as the major economic activities butemphasis was placed on aquatic resources and vegetal foods. Although nomadicwandering was being replaced by "a regular hunting-gathering range with specific basecamp sites that were returned to at regular intervals" (Chapman 1975:135), the typicalEarly Archaic site continued to be a small hunting and or collecting camp. These arefound in a variety of environmental settings throughout Missouri including upland ridgesnear small ephemeral streams, upland bluff edges, rock shelters, and the margins of highbottomland terraces. Diagnostics of Early Archaic include Graham Cave Notched thathas been recovered in the general area (Chapman 1975). Hardin Barbed is also generallyassociated with Early Archaic occupation.Middle Archaic: The Middle Archaic was basically a continuation and expansionof a forager tradition begun in the Dalton and Early Archaic. A drying climate forcedgreater reliance upon collecting vegetal foods and small animals as opposed to wetenvironment subsistence. Sites continued to be small, exhibiting semi-nomadic orseasonal occupation with no specific topographic location associated (Chapman1975:159). The tool kit continued to expand, depending upon the extraction activity inthe specific niche. The drying climate was reflected in the marked tendency for MiddleArchaic sites to be located almost exclusively in or very near bottomland settings(Chapman 1975). There are no complexes associated with the period in this general area.Collectors in the area often have Big Sandy forms in their collections. It is assumed thatMiddle Archaic was present but in an as yet poorly defined situation. Site forms for thedrainage are inconclusive in terms of presence of Middle Archaic diagnostics.Late Archaic: The Late Archaic is somewhat better known than earlier traditions.This is a result of the greater population apparently represented by the Late Archaicwhich resulted in more expansive and numerous occupations. This period generally lacksthe small dart point of the earlier traditions that suggests that hunting had become lessimportant for subsistence. In addition, tool kit function appears to have expandedsuggesting reliance on a much larger variety of potential foods requiring varied extractionand processing techniques. The Late Archaic began toward the climax of a warmingtrend that reached its height around 2000 B.C. (Cleland 1966), with a resultantdiminishing of the faunal and floral forest species. The Late Archaic peoples had toadapt to new ecological niches with concomitant changes in subsistence related artifacts.Emphasis was probably placed on a method of procurement that could effectively exploitvarious types of resources which were available in reliable quantities at varying seasons.Using a central-based wandering settlement pattern in which the particular seasonal14 resources available would determine the type and location of temporary camps radiatingfrom more permanent occupation sites, Late Archaic settlement pattern appears to havebeen somewhat more restricted than previous foraging traditions. Diagnostic artifacts ofthis period include the Sedalia Lanceolate and Diggers, Clear Fork Gouge, Smith BasalNotch, Afton, Etley, Nebo Hill, Stone Square, as well as 3/4 groove granite axes.Evidence of the Sedalia complex are often found just over the crown of the slope of highridges (Chapman 1975:200). Late Archaic occupations are one of the more commonlyidentified traditions in the drainage according to ASM records.Early Woodland: The Early Woodland period is identified by presence of BlackSand Incised pottery and is poorly represented throughout most of Missouri. In spite ofintensive surveys in various areas of the state, only a few unquestionable Early Woodlandsites have been identified and include Avondale, Renner, and Shields sites in the KansasCity area and a few in the northeast portion of the state. These and other possible EarlyWoodland sites are generally found in the major river valleys, particularly along theMissouri River.Middle Woodland: The Middle Woodland period occupation in northernMissouri is focused on three related regional centers: The Havana center in the LowerIllinois River Valley and adjacent Mississippi River valley in the northeast, the KansasCity Hopewell, and Big Bend centers. The latter two are on the Missouri River.Analyses of pottery from the three centers indicate there was an intrusion of people intothe Big Bend and Kansas City areas from the Havana center to the east (Wedel 1943)although the initial intrusion appears to have been related to subsistence and/or politicalstress (Struever & Houart 1972) in the Havana center, contacts among the three centerswas maintained throughout the Middle Woodland period (Chapman 1980). Thesecontinued contacts insured the Big Bend and Kansas City areas of a place in the ClassicMiddle Woodland's Hopewell Interaction Sphere. Evidence for a Middle Woodlandoccupation is very sparse outside of the areas noted. Some rock shelters and openhabitation sites in the general area have produced Middle Woodland diagnostics andChapman identified south Boone County as a major Middle Woodland center (1980).There has been no corroborating evidence through field investigations regarding theassertion by Chapman. In general, with the exception of the Big Bend and Kansas CityHopewell, Middle Woodland diagnostics usually are interpreted from lithics such asSnyders points with ceramics reflecting Hopewellian occupation lacking but for thecenters.Late Woodland: The Late Woodland period exhibits the most numerous definedcomponents within prehistoric sites in the general project area. The occupation in thisportion of Missouri has sometimes been defined as a regression from the precedingtraditions in that emphasis on horticulture developed earlier in the Woodland wassupplanted by earlier hunting subsistence reliance. This pattern is seen in the increase insmall temporary camps along with use of bow and arrow. Diagnostics include grit andlimestone tempered pottery, arrow points, burial mounds, and shallow side notchedpoints. Several Late Woodland sites have been identified in the county including both15 open habitation sites and burial tumuli. A large number the archaeological sitesidentified in the general project area have exhibited Late Woodland diagnostics(Sturdevant 1978).Mississippian: The Early Mississippian period is not well documented in thegeneral area of the project. Steed-Kisker, an Early Mississippi phase, is located in theKansas City area while Cahokia and the St. Louis area represent a climax associated withEarly Mississippian (Chapman 1980). Diagnostics for this period include smalltriangular arrow points and shell tempered ceramics. Where Early Mississippianexperienced climax levels, temples and towns were part of the settlement pattern. In theimmediate area only triangular points and an occasional shell tempered sherd have beenreported. Early Mississippian Steed-Kisker people apparently abandoned the KansasCity area around A.D. 1250 and around A.D. 1350 the Oneota cultural tradition appearedsuddenly in the Big Bend area near the junction of the Grand, Chariton, and Missouririvers. It is speculated that Oneota developed in northern Missouri and Iowa and itsformation was stimulated by developments at the Cahokia center. While the extent ofCahokia influences remains unknown, cultural developments of the period in that areahave been connected to the cultural background and growth of the historic Siouan-speaking people (Griffin 1960). The most prominent Oneota village in the Big Bendarea is the Utz site and it was there the Utz phase, which documents the Oneota cultureof the area, was defined. The Utz phase, and the Oneota occupation, began at about A.D.1350 and lasted to the end of the Mississippian period (A.D. 1700) when Oneota blendsinto what is recognized as the Historic Missouri Indian tribe.Historic Period: During the period from 1730 to 1790, the Missouri tribe wasbeing depleted by smallpox and its power was continually being tested by its enemies tothe north. By the 1780's, the Missouri became heavily dependent on their allies theOsage for protection. In spite of this, the Sac and Fox conquered and dispersed theMissouri tribe in the 1790's. Those who were not killed joined the Osage, Kansas, andOto tribes. The great smallpox epidemic of 1823 reduced their numbers to less than onehundred and Missouri as a distinct cultural entity became extinct. The last full-bloodMissouri Indian died on the Oto reservation in 1907 (Chapman 1946:29).The lands encompassed by the project were but a small part of North Americanterritory claimed by France until 1762 when it was transferred to Spain by secret treaty.Spain retroceded the land to France in 1801 and France ended up selling it to the U.S. in1803 as the Louisiana Purchase. In 1812, congress created the Territory of Missouri andin 1821 Missouri was recognized as the twenty-first state (March 1963). In general, thepost-1800 history of central Missouri reflects both the general patterns of agriculturaldevelopments in the Midwest and specific influences which shaped the region. Theprocess of early settlement and the struggle to producebeyond a meager subsistence, theexpansion of the agricultural and commercial activities and creation of a stable society,followed by an era in which regional concerns were shaped by state and national trends,are all recognized as part of the evolution of the Midwest. In the case of northernMissouri, an understanding of its Euro-American past requires recognition of the16 influence of the settlers themselves and of the land which they occupied. The earlysettlers came primarily from the Upper South, especially Kentucky, Tennessee, andVirginia. Prior to the Civil War, first tobacco and then corn played an important role inthe agricultural economy of the region. The first permanent settlers began entering thearea in the early 1800's, a process that really began only after the acquisition of theLouisiana territory by the U.S. in 1803. Congress created the territory of Missouri in1812 and nine years later recognized Missouri as the twenty-first state (Meyer 1963).The rapid development from uncharted wilderness to statehood stemmed directly fromthe massive westward movement of population during the early nineteenth century. Mostof the settlers who came to mid-Missouri were attracted to the land. The fertile soil,adequate rainfall, and a growing season that averaged six months a year made the regionparticularly well-suited for agriculture. A rich, friable loam predominated, withsubstantial stands of timber which provided building materials and generally remindedthe immigrants of the lands which they had left behind.The background of the settlers made them receptive to cultivating a crop thatwould reproduce the agricultural patterns of their native states. Most of the early settlerscame from the Upper South that included slave holding states. March (1967) suggeststhat within the "slave belt" through central Missouri, major crops included hemp andtobacco. These crops, particularly tobacco, demand intensive labor for productivity.Tobacco is generally favored as a cash crop in that it produced a greater value inproportion to bulk when compared to grain crops. In areas such as the project,transportation would have been a problem prior to the railways. Cash crops such astobacco in areas that did not provide viable river transportation soon shifted to localconsumption crops such as corn and wheat. While not well documented at present, it isapparent that agricultural pursuits were almost entirely geared toward corn and wheat bythe time of the Civil War. It is further apparent that slave holding had begun to drop at arelatively high rate prior to the Civil War (Campbell 1874). The land and its location,then, became major shaping forces of the economic system of the area, altering theprevious patterns established in the southeast and brought to the Midwest. The coming ofthe railroad in the 1850's through the 1870's opened the interior to greater trade andagricultural products have been the major source of livelihood in the general area sincethis time.17 INVESTIGATION FINDINGSRecords and Literature ReviewBoone County, Missouri currently contains 49 National Register of HistoricPlaces (NRI-lP) properties. These include the following:Ballenger Building (Downtown Columbia. Missouri MPS), 27-29 South Ninth St.,Columbia (1/21/04)Bond's Chapel Methodist Episcopal Church, MO A, 2.5 mi. NE of Hartsburg,Hartsburg vicinity (9/09/93)Boone. John W. ("Blind"), House (Social Institutions of Columbia's Black CommunityTR [see note*]), 4th St. between E Broadway and Walnut, Columbia (9/04/80)Central Dairy Building (Dowtntown Columbia. Missouri MPS), 1104-1106 EastBroadway, Columbia (1/20/05)Chance, Albert Bishop. House and Gardens, 319 E Sneed St., Centralia (7/03/79)Chatol (F. Gano Chance House, Chance Guest House), 543 5 Jefferson, Centralia(4/20/79)Coca-Cola Bottling Co. Building (Downtown Columbia, Missouri MPS), 10 Hitt St.,Columbia (2/14/06)Columbia Cemetery, 30 East Broadway, Columbia (2/01/07)Columbia National Guard Armory, 701 E Ash St., Columbia (3/25/93)Conley, Sanford F., House, 602 Sanford P1., Columbia (12/18/73)Douglass, Fred, School (Social histitutions of Colunmbia's Black C~ommnunity TR [seenote*]), 310 N Providence Rd. (9/04/80)Downtown Columbia Historic District (Downtown Coliumbia, Missouri MPS; man [seenote]), parts of 7th, 8th, 9th, 10th, E. Broadway, Cherry, Hitt, Locust, and E. WalnutStreets, Columbia (11/08/06)Downtown Columbia Historic District (Dowtntown Columbia, Missouri MPS; boundaryincrease), 10 19,1020,1023 & 1025-33 E. Walnut St., Columbia (5/08/08)18 East Campus Neighborhood Historic District, roughly bounded by Bouchelle, College,University, and High Sts., including parts of Willis, Bass, Dorsey, and Anthony Sts.,Columbia (2/16/96)Eig~hth Broadway Historic District [Miller Building, Matthews Hardware, MetropolitanBuilding], 800-8 10 E. Broadway Blvd., Columbia (4/22/03)Elkins, Samuel H. and Isabel Smith, House, 315 N 10th St., Columbia (9/12/96)First Christian Church, 101 N 10th St., Columbia (10/29/91)Francis Ouadrangle Historic District (Red Campus), bounded by Conley Ave., Elm,6th and 9th Sts., Columbia (12/18/73)Frederick Apartments, 1001 University Ave., Columbia (4/16/13)Gordon, David. House and Collins Lo& Cabin (Gordon Manor, Fairmount, CedarView), 2100 E Broadway, Columbia (8/29/83)Gordon Tract Archaeological Site, address restricted (3/16/72)Greenwood (Greenwood Heights), 3005 Mexico Gravel Rd., Columbia (1/15/79)Guitar, David, House (Confederate Hill), 2815 Oakland Gravel Rd., Columbia (9/09/93)Hackman, Samuel E.. Building, 30 S St., Hartsburg (12/10/98)Hamilton-Brown Shoe Facto ry, 1123 Wilkes Blvd., Columbia (7/19/02)Hunt, William B., House, 8939 W Terrapin Hills Rd., Columbia vicinity (1/09/97)Kress Building (Downtown Columbia, Missouri MPS), 1025 E. Broadway, Columbia(3/09/05)Maplewood, Nifong Blvd. and Ponderosa Dr., Columbia (4/13/79)McCain Furniture Store (Downtown Columbia, Missouri MPS). 916 E. Walnut,Columbia (8/17/05)Missouri, Kansas and Texas Railroad Depot, 402 E Broadway, Columbia (1/29/79)Missouri State Teachers Association, 407 S 6th St., Columbia (9/04/80)Missouri Theater, 201-215 S 9th St., Columbia (6/06/79)19 Missouri United Methodist Church, 204 S 9th St., Columbia (9/04/80)Mount Zion Church and Cemetery (Rural Church Architecture of Missouiri, c. 1819 toc. 1945 MPS)., 11070 Mount Zion Rd., Hallsville vicinity (1/14/13)North Ninth Street Historic District (Downtowvn Columbia. Missouri MPS) (m__mp [seenote]), 5-36 North Ninth St., Columbia (1l/21/04)Payne. Moses U.. House, 201 N Roby Farm Rd., Rocheport vicinity (10/07/94)Pierce Pennant Motor Hotel (Candlelight Lodge), 1406 Old Hwy. 40 W, Columbia(9/02/82)Rocheport Historic District, MO 240, Rocheport (10/08/76)St. Paul's A.M.E. Church (Social histitutions of Columbia'is Black Community' TR [seenote*]), 501 Park St. (9/04/80)Sanborn Field and Soil Erosion Plots, University of Missouri Campus, Columbia(10/15/66; NHL 7/19/64)Second Baptist Church (Social Institutions of Columbia's Black Community TR [seenote*]), 407 E Broadway (9/04/80)Second Christian Church (Social Institu.tions of Columbia's Black Commnunity TR [seenote*]), 401 N 5th St. (9/04/80)Senior Hall, Stephens College Campus, Columbia (8/02/77)Stephens College, South Campus, 1200 E. Broadway, Columbia (11/25/05)Taylor, John N. and Elizabeth, House, 716 West Broadway, Columbia (5/25/01 )Tiger Hotel, 23 5 8th St., Columbia (2/29/80)Virginia Building, 111 South Ninth Street, Columbia (3/13/02)Wabash Railroad Station and Freight House (Norfolk and Western Depot), 126 N10th St., Columbia (10/11/79)West Broadway Historic District, 300-922 W. Broadway (except 800, 808, 812),Columbia (4/27/10)Wright Brothers Mule Barn, 1101-1107 Hinkson Ave. & 501-507 Fay St., Columbia(11/01/07)20 There are no previously recorded prehistoric archaeology sites within the projectboundaries (Figure 3). [Proprietary Information] The project area contains no recordedhistoric architecture or possibly significant historic events.Review of 19th and 20th century plat maps and 20th century USGS topographicquadrangles found no evidence of structures within the proposed project area. The1967/81 USGS topographic quadrangle does not illustrate any structures in the projectboundaries.Field Investigation FindingsThe field investigation was carried out under generally mixed to poor surfacevisibility conditions averaging less than 20% in a grass/hay setting (Figure 4). Shoveltests were utilized in order to interpret presence/absence of cultural resources asdescribed in the methods section of this report. The presence of erosion cuts and pathsalong with shovel tests allowed for a sample of subsurface soil matrix for interpretationof potential for presence/absence of buried cultural resources.The field investigation failed to identify any evidence of the presence ofprehistoric occupation of the area. Typically, this includes presence of chert debitage,fire-cracked rock, lithic artifacts, and occasionally ceramics. None of these materialswere encountered on the surface or in shovel tests. No prehistoric sites have beenrecorded.Historic resources include recently constructed roads which do not meet theinvestigators' historic site designation criteria. No historic sites have been recorded.It is the finding of this Phase I cultural resources survey that Lot 15 in theDiscovery Ridge development contains no possibly significant cultural resources.21

[Proprietary Information]22 rI OM15tl lll soap Scale=--1:2758 l~lllFigure 4,Aerial Photograph of Project Area Suweyed (YELLOW)

RECOMMENDATIONSDuring September 2013 a Phase I cultural resources survey was carried out for a7.5 acre tract of land at Discovery Ridge, Boone County, Missouri. The area is thelocation of a proposed commercial development project.There are no National Register of Historic Places (NRH-P) properties locatedwithin the proposed project area; DNR GIS records indicate presence of no recordedarchaeology sites within the project boundaries; and no recorded Missouri DNR historicarchitectural sites are present within the project area of potential effect (APE). 19thcentury plat maps do not illustrate any structures within the project area.The field investigation was carried out under poor surface visibility conditions ina grass/hay setting. Shovel testing was implemented following guidelines described inthis report. No evidence of the presence of prehistoric occupation was identified withinthe project area. No evidence of the presence of early historic occupation was identifiedwithin the project boundaries.On the basis of the negative findings regarding presence of possibly significantcultural resources, it is the recommendation of this Phase I cultural resources survey thatthe proposed project proceed as planned in terms of Section 106 compliance concerns.No significant cultural resources will be threatened by the proposed project actions.24 BIBLIOGRAPHYAilgood, F. P. and I. D. Persinger1979 Missouri General Soil Map and Soil Association Descriptions.Soil Conservation Service. Columbia.Asch, D. I.1976 The Middle Woodland Population of the Lower IllinoisRiver Valley: A Study in Paleodemographic Methods.Northwestern University Archaeological Program,Scientific 1.Baker, M.1984 Analysis of Refuse Pits 23CO 156, Cole County, Missouri.M.A. Thesis. UMC. Anthropology Department.Boone County Land Assessment Book1875 through 1931. State Archives.Branson, E. B.1944 The Geology of Missouri. University of Missouri Studies.Vol. 19, No. 3. Columbia.Broadhead, G. C.1890 Prehistoric Evidences in Missouri. Annual Report of the SmithsonianInstitution for the Year 1878. Washington D.C.Campbell, R. A.1874 Gazetteer of Missouri. R.A. Campbell. St. Louis.Chapman, C. H.1975 The Archaeology of Missouri I. University of MissouriPress. Columbia.1980 The Archaeology of Missouri II. University of MissouriPress.Cleland, C. E.1976 The Focal-Diffuse Model: An Evolutional Perspectiveon the Prehistoric Cultural Adaptations of the EasternU. S. Midcontinental Journal of Archaeology. 1:59-76.25 Collier, J. E.1955 Geographic Regions of Missouri. Annals of theAssociation of American Geographers. 45 (4):368-92.Conard, H. L.1901Encyclopedia of the History of Missouri. The Southern HistoryCompany. New York.Denny, S. G.1964 A Re-evaluation of the Boone Focus: A Late Woodland Manifestationin Central Missouri. M.A. Thesis, UMC.Edwards Brothers1875 Historical Atlas of Boone County, Missouri. Edwards BrothersPhiladelphia.Evans, D. R., E. G. Garrison, and D. J. Ives1977 Cultural Resources Survey: Columbia, Missouri, Phase I SewerImprovements. EPA.Fowkes, G.1910Grantham, L.1977Griffin, J. B.1961Antiquities of Central and Southeastern Missouri. SmithsonianInstitute, Bureau of American Ethnology Bulletin 37. Washington D.C.Cultural Resources Survey Long Branch Lake: ArchaeologyResources. COE.Some Correlations of Climate and Cultural Change inEastern North American Prehistory. Annals New YorkAcademy of Science. 95:710-717.Haas, D.1978 An Archaeological Survey of the Little Femme OsageRiver Hills Area and the Loutre River Valley. DNR.Howe, W. B. and J. W. Koenig1963 The Stratigraphic Succession in Missouri. GeologicalSurvey and Water Resources Series 3.Klippel, W. E.1965 An Archaeological Investigation of the Lower Osage River Valleyin Missouri. M.A. Thesis, UMC.26 Kay, M.1980March, D. D.1967The Central Missouri Hopewell Subsistence -SettlementSystem. Missouri Archaeological Research SeriesNo. 15.The History of Missouri. Lewis Historical Company.New York.Martin, T.1983 An Archaeological Survey in the Middle Drainage -LamineRiver. DNR/H-PP Grant. Jefferson City.Northup, B. B.2001 We are Not Yet Conquered: The History of the Northern CherokeeNation of the Old Louisiana Territory. Turner PubI. Co. Paducah,Kentucky.Northwest Publishing Co.1898 Plat Map of Boone County, Missouri. Northwest Publishing Co.Philadelphia.O'Brien, M.1984Ogle, G. A.1917Archaeological Testing of the Route 63, Boone County Project,Missouri. MoDOT.Standard Atlas of Boone County, Missouri. George A. Ogle & Co.Chicago.Raisz, I.1957 Physiographic Regions of the U.S. Map.Re eder, R. L., E. E. Voigt, and M. J. O'Brien1983 Investigations in the Lower Perche -Hinkson Drainage.EPA.Rollins, J. S.1853 Land Entry Atlas of 1853. Boone County, Missouri -State Archives.Schmits, L. J.1981 Archaeological Investigations at the Roddy Site (23BO966) and theCoatesSites (23BO965), Boone County, Missouri. EPA.27 Schmits, L. et al.1985 Prehistory of the Lower Perche- Hinkson DrainageCentral Missouri Archaeological Investigations at theColumbia Regional Wastewater treatment Facility.Shoemaker, F. C.1943 Missouri and Missourians. Lewis Publishing Company, Chicago.Stevens, W. B.1915 Missouri the Center State, Vol. II. S. J. Clarke Publishing, St. Louis.Struever, S. and G. I. Houart1972 An Analysis of Hopewell Interaction Sphere: INSocial Exchange and Interaction. E. N. Wilmseneditor. University of Michigan, Museum ofAnthropology, Anthropological P~apers. No. 3.Sturdevant, C.1976 Cultural Resource Survey, Algoa ReformatorY, Cole County,Missouri. DNR/HPP.1989 Phase III Data Recovery, 23CY499, Callaway County, Missouri.MoDOT.Wedel, M. M.1943Archaeological Investigations in Platte and ClayCounties, Missouri. U__. S. National Museum Bulletin No. 183.Weichman, M. S. and D. Weston1986 Master Plan for Archaeological Resource Protection inMissouri. DNR/IHPP. Jefferson City.28 N WMI*..** NORTHWEST MEDICAL IOOEA TTA CHMENT BDescription of the Proposed Northwest Medical Isotopes, LLCRadioisotope Production FacilityNWMI is preparing an application for submission to the NRC to construct, operate, and decommission aRadioisotope Production Facility (RPF). This facility is proposed to be located at the University ofMissouri System (UM System) Discovery Ridge Research Park in Columbia, Missouri. The proposedoperations of the RPF includes fabrication of low enriched uranium (LEU) targets, deliver targets to anetwork of university research nuclear reactors for irradiation, receive irradiated targets, and extract andpurify molybdenum-99 (99Mo) from the irradiated LEU. The LEU would be reclaimed and recycled intotargets for delivery to the network of university research reactors. The 99M would be sold anddistributed through the existing U.S. supply chain network.Schedule* Submit construction application to NRC (41h Q 2014)* NRC review and approval (Expected 4th Q 2015)* Site preparation and construction: (2015 -2016)* Facility Operations (2017- 2045)Site LocationThe proposed 7.5 acre site is situated in Boone County, Missouri, within the UM System, DiscoveryRidge Research Park in Columbia, Missouri north of Discovery Ridge Drive (Figure B-l1). Theapproximate center of the NWMI RPF is Longitude: 92° 16'34.63"~ and Latitude: 38o54'3.31"~.Site DescriptionThe proposed site is located on Lot 15 of the Phase II section of the Discovery Ridge Research Park. Thesite is all on property owned by UM System. The facility would be approximately 330 feet (ft) in thelong dimension and 110 ft wide with a maximum height of 45 ft not counting the stacks (Figure B-2).The site would include an outer fence perimeter and provide the necessary initial security barrier. Thefenced area would include paved roads laid out for the turning radius of tractor/trailers used to transportthe materials.Additional information can be found at the UM System, Discovery Ridge Research Park website,httn://www.umnsvstem .edu/ums/aa/umrni/discovervrid~e.29

.. ..%. IV V* .NORTHWEST MEDICAL ISOTOPESA Proposed LocationZ]Proposed Building Lot (Lot 15)Discovery RidgeL ..." Columbia City Limitam MilesFigure B-I. Proposed Location NWMI RPF -Discovery Ridge located in Columbia, Missouri30

• .-;:,*. NI WM I* -,- *NORTHWEST MEDICAL ISOTOPESA NWMI SiteO 5 Mile (8 kin) Radius from NWMI SiteiInterstate-Highways4r1City LimitsMilesFigure B-2. NWMI RPF General Layout.31 This page intentionally left blank.32 NWMI-2013-021, Rev. OAChapter 19 -Environmental ReviewAppendix BMISSOURI STATE HISTORIC PRESERVATION OFFICECONSULTATION LETTER AND RESPONSEB-i NWMI-2013-021, Rev. OAChapter 19 -Environmental ReviewThis page intentionally left blank.B-ii Environmental Research Center of Missouri, Inc.1201 Moreau DriveJefferson City, Missouri 65101573.635.9569craigsturdevant~dinchsi. cornOctober 7, 2013Mr. Mark MilesMissouri Department of Natural ResourcesP.O. Box 176Jefferson City, Missouri 65102Re: Cultural Resource Investigations, Phase I Survey, Lot 15 -Discovery Ridge,Boone County, Missouri

Dear Mark:

Please find one paper and an electronic copy of the above noted report. Please send yourresponse to:Carolyn HaassVice President/Technical Program DirectorNorthwest Medical Isotopes, LLCVice President/Technical Program Director815 NW 9th Aye, Suite 256Corvallis, Oregon 97330Thank you for your time and consideration in this matter. If you have any questions,please call me.Sincerely,Craig SturdevantPresident/ERCc. C. HaasJ. Belier Cultural Resource InvestigationsPhase I SurveyLot 15 -Discovery RidgeBoone County, MissouriNuclear Regulatory Commission ProjectPrepared for:Northwest Medical Isotopes L.L.C.Prepared By:Environmental Research Center of Missouri, Inc.1201 Moreau DriveJefferson City, MissouriPhone: 573-635-9569Email: craiqstu Principal Investigator:Craig SturdevantSeptember 2013ERG Project No. 3023ERG ABSTRACTDuring September 2013 a Phase I cultural resources survey was carried out for a7.5 acre tract of land at Discovery Ridge, Boone County, Missouri. The area is thelocation of a proposed commercial development project.There are no National Register of Historic Places (NRH-P) properties locatedwithin the proposed project area; State Historic Preservation Office (SI-PO) GIS recordsindicate presence of no recorded archaeology sites within the project boundaries; and norecorded SH-IPO historic architectural sites are present within the project area of potentialeffect. 19t century plat maps do not illustrate any structures within the project area.The field investigation was carried out under poor surface visibility conditions ina grass/hay setting. Shovel testing was implemented following guidelines described inthis report. No evidence of the presence of prehistoric occupation was identified withinthe project area. No evidence of the presence of early historic occupation was identifiedwithin the project boundaries.On the basis of the negative findings regarding presence of possibly significantcultural resources, it is the recommendation of this Phase I cultural resources survey thatthe proposed project proceed as planned in terms of Section 106 compliance concerns.No significant cultural resources will be threatened by the proposed project actions.1 TABLE OF CONTENTSABSTRACT 1TABLE OF CONTENTS 2LIST OF FIGURES 3 *[NTRODUCTION 4Purpose of Study 4Project Personnel and Schedule 5The Project 5INVESTIGATION METHODS 7Introduction 7Records and Literature Review 7Field Procedures 8Analysis Procedures 9Statement of Findings and Recommendations 10PROJECT SETT[NG 11Environmental Setting 11Cultural Setting 12INVESTIGATION FINDINGS 18Records and Literature Review 18Field Investigation Findings 21RECOMMENDATIONS 24BIBLIOGRAPHY 252 LIST OF FIGURESFigure 1.USGS Quadrangle Location of Project Area Surveyed& Cultural Resources 6Figure 2.DNR Study Unit Location of Project 13Figure 3.SHPO GIS Archaeology & Survey Layers in Relation to the Project 22Figure 4.Aerial Photograph of Project Area Surveyed 233 INTRODUCTIONPurpose of StudyIn compliance with current environmental regulations and policies, NorthwestMedical Isotopes L.L.C. entered into a contractual agreement with EnvironmentalResearch Center of Missouri, Inc. (ERC) to conduct a Phase I cultural resource survey ofa 7.5 acre tract of land at Discovery Ridge in Boone County, Missouri. The studyfollowed the Missouri Department of Natural Resources (DNR) "Guidelines for CulturalResource Contract Reports and Professional Qualifications" and is submitted inaccordance with current environmental regulations and policies and in agreement withthe study contract.The project actions included discussion of the project with Missouri Departmentof Natural Resources/Historic Preservation Program staff, a records and literature review,and an intensive pedestrian field investigation of the project area. The study methodsused are described and the results of the findings of these actions are presented in termsof cultural resource descriptions, when present, and recommendations for culturalresource compliance in reference to the proposed project actions. The project areacultural and environmental settings are briefly described.Under state and federal legislation and policies outlined by the Antiquities Act of1906, the Historic Sites Act of 1935, the National Historic Preservation Act (NHPA) of1966 as amended, the National Environmental Policy Act of 1970, the 1986 Protection ofHistoric Properties and other regulations regarding specific activities such as stripmining, it is necessary to inventory archaeological and historical resources located withinproposed project areas which may be threatened by federally regulated or funded actionsand evaluate any disruptive effects these actions might have on resources that are present.Briefly, the National Historic Preservation Act requires that an area threatened by afederally funded and/or regulated project consider cultural resources which might beimpacted by project related actions; the State Historic Preservation Officer (SHPO)and/or federal agency involved may request that a cultural resource survey be conductedprior to granting permission to proceed with the proposed project actions. If any culturalresources are identified, they are evaluated in terms of National Register of HistoricPlaces (NRHP) eligibility criteria. Where NRIHP eligible sites are found to occupycompliance project areas, consultation is initiated which may include the AdvisoryCouncil on Historic Preservation (Council), the SIHPO, and the governmental agencyinvolved in the project. If an eligible site cannot be avoided, a Memorandum ofAgreement may be prepared which would stipulate specific compliance actions to beinitiated prior to project actions. The project initiator, if not a federal agency, may berequested to concur. The present project is partially funded or regulated by a federalagency. As a result, cultural resource compliance has been implemented by a federalagency and Missouri SH-PO and the present survey has been carried out in order to meetNIHPA requirements.4 Project Personnel and ScheduleThe present project was carried out during December 2010. Principal Investigatorand report author is Craig Sturdevant. Sturdevant has a Master of Arts degree inAnthropology from the University of Iowa, Iowa City and meets state and federalrequirements for Principal Investigator for cultural resource compliance projects. JohnCarrel, ERC research associate, was field technician for the project.The ProjectThe total proposed project area includes approximately 7.5 acres of land locatedsouth of Columbia on the east side of US 63 in the commercial area known as DiscoveryRidge. A detailed project plan and profile was not included in the scope of work and itwas assumed that any cultural resources located within area surveyed would bethreatened by project actions. The project is located in Section 33, Township 48 North,Range 12 West, Boone County, Missouri (Figure 1).The present investigation has been carried out utilizing Phase I survey proceduresas outlined in the methods section of this report and available standard procedures fordetermining presence/absence of buried resources. Findings and recommendations aremade with the understanding that it sometimes may not be possible to identify allpossibly significant resources within a project area, particularly where vegetation isextremely heavy or valley settings with deep alluvium.5

[Proprietary Information]6 INVESTIGATION METHODSIntroductionThe major goal of the this investigation was the inventory and evaluation ofcultural resources within the designated project zone through the use of currentlyaccepted Phase I survey techniques and records and literature review. It is important thatsufficient data are collected to allow development of appropriate recommendationsconcerning the significance of the identified cultural resources in the project zone interms of National Register of Historic Places (NRH-P) eligibility criteria. The methodsand techniques used during the present investigation allowed an intensity of coverage thatshould have identified all potentially significant cultural resources. Deeply buried sitesand very low material density sites are possible to miss no matter how intensive thesurvey techniques. This study has been initiated in order to carry out federally mandatedSection 106 compliance regulations. The scope of work placed emphasis uponidentification of cultural resources within the project area along with recovery ofsufficient data to allow the Missouri SH-IPO to make an informed determination ofpossible significance of those resources.The following section includes a discussion of the methods that have beenemployed in this study. These consist of a pre-field evaluation of pertinent literature andrecords from which the field survey techniques and site designation criteria aredeveloped, an intensive pedestrian survey of the project area, an attempt to recoversufficient data for site designation and evaluation in terms of NRHP eligibilityrequirements, notation of locational information regarding site provenience andphysiographic setting, post-field activates involving data analysis, and report preparation.The methods and techniques and justifications for interpretations are discussed below.Records & Literature ReviewA review of relevant publications and records prior to the field component of thestudy is important in establishing an understanding of the cultural sequence and types ofcultural resources which might be expected to occur. The process begins with review ofcultural resource management (CRM) reports that have been produced for the areas nearthe project zone. These reports are housed in the Missouri Department of NaturalResources State Historic Preservation Office (SHPO), Jefferson City, Missouri and arecatalogued by county as well as author. The repository also includes historic -architecture site forms for the state, NRH-P forms for Missouri, and correspondenceregarding the proposed project. Archaeological Survey of Missouri (ASM) recordslocated at the SHPO were also reviewed. The ASM files contain information on reportedarchaeological sites in Missouri that have been gathered for over 70 years which arecatalogued by county and section, township, and range and UTM coordinates. TheSHPO GiS data includes overlays illustrating recorded archaeology sites and areas thathave been the subject of previous cultural resource surveys. Other resources consulted7 that contain important data include the state library in Jefferson City, the State Archivesin Jefferson City, local historic societies when available, and the State Historic Society inOther archaeologists and architectural historians, particularly those employedby the state that are involved with Section 106 procedures, are consulted regarding theirknowledge of significant cultural resources in a project area.Field ProceduresThe archaeological field component of the present study involved pedestriancoverage of the defined project area by ERC personnel. Transect width utilized rangedfrom 5 to 15 meters depending upon visibility and site potential based on terrain, streams,and other factors that have been shown to correlate with site presence/absence such aspresettlement prairie or woodland setting. All vegetation-free zones are observed forpresence of prehistoric cultural materials. Throughout most of Missouri, this can includelithic debitage (chert flakes and shatter), fire-cracked rock, pottery sherds andoccasionally bone and shell fragments. Features such as fire hearths and burial tumulimay also be encountered. Where vegetation covers the surface for over 10 meters, shoveltests are implemented. This involves removal of around a 50 cm by 50 cm area of sodand then controlled removal of subsurface soil matrix to depths of up to 50 cm belowsurface. Soils are carefully observed to determine presence/absence of cultural evidence.Where soil conditions allow, soils are screened through a portable 1/4 inch screen. Shoveltesting that does not include screening of matrix is implemented where larger numbers ofshovel tests are necessary and surface visibility conditions are poor. In this instance, soilmatrix is removed by shovel and carefully scraped with a trowel to look forprehistoric/early historic evidence.Where evidence of presence of an archaeological resource is defined, the locationis noted on a U.S.G.S. quadrangle and a sketch map and description of the site area arefield prepared. Where features or structures are encountered, photographs are taken. Thefield procedures incorporated in the pedestrian survey are directed toward two majorgoals: The first was the inventory of all possibly significant cultural resources within theproject zone and the second the attempt to recover sufficient information to allowinterpretation of NRI-P eligibility of these sites by the MoSH-PO.While subjective, ERC has developed a set of criteria for determining thepresence of an archaeological resource, which are currently accepted by the SHPO asappropriate. These criteria are not presented as appropriate for all situations but as thegeneral practice followed by ERC in making decisions regarding presence/absence ofarchaeological resources for cultural resource compliance purposes. One extreme wouldrecord a site where any evidence of cultural activity occurs. The other extreme wouldrequire a significant cultural resource to be present to result in recording a site. Thepresent approach attempts to find a middle ground, which hopefully allows for furtherconsideration for both the cultural resource and the proposed project action prior to threatto either.8 An archaeology site is designated when evidence of prehistoric and/or earlyhistoric land use is present and at least one of the following specific criteria is met:A. A prehistoric feature is presentB. Two or more artifacts are identified within a 10 by 10Om or less areaC. A shovel test recovers 2 or more artifacts.Where a site is identified and when the landowner grants permission, materialsrecovered by the field investigation are placed in field site number marked collectionbags. If permission is not attained, materials are observed and potential diagnostics andtools measured, photographed and left in the field or given to the landowner whenrequested. When a permanent site number is assigned, retained materials are curated withthe site designation. Where material density at a site is obviously high only arepresentative sample is retained.Historic architecture resources include structures and features. Where structuresare present that are over 45 years old or exhibit some form of possible exceptionalsignificance they are photographed and a description of architectural features is preparedalong with preliminary evaluation of NRHP eligibility when located within a directimpact project zone. Historic structures are not recorded where it is obvious that thestructures are less than 45 years old and not significant in any other respect. Where anarea of potential effect (APE) has been established beyond the physical APE,architectural resources within this defined APE obviously 45 years or older arephotographed and located on report maps.Analysis ProceduresSignificance of cultural resources is interpreted from National Register of HistoricPlace eligibility criteria that are listed below:"The quality of significance in American History, architecture, archaeology, andculture is present in districts, sites, buildings, structures, and objects that possessintegrity of location, design, setting, materials, workmanship, feeling andassociation, and:A) that are associated with events that have made a significant contribution to thebroad patterns of our history; orB) that are associated with the lives of persons significant in our past; or9 C) that embody the distinctive characteristics of type, period, or method ofconstruction, or that represent the work of a master, or that possess high artisticvalues, or that represent a significant distinguishing entity whose componentsmay lack individual distinction; orD) that have yielded, or may be likely to yield, information important inprehistory or history: (36 CFR Part 60.6).Cultural resources that are identified during the Phase I survey are evaluated interms of meeting one or more of the above criteria. In general, archaeological sites mostoften are evaluated with reference to D above. A statewide planning document wasprepared by the DNRIHPP that allows minimal means for evaluation of potentialsignificance of cultural resources (Weichman and Weston 1986). The statewide planincludes information regarding traditions, types of traditions expected, forms of data thatmay be potentially important, and research questions that can be incorporated in theinterpretation of cultural resource significance where available. Generally, a culturalresource will be evaluated on the basis of types of materials recovered (uniqueness,affiliation, type), resource integrity (degree of disturbance), and material/feature density(density and quantity of artifacts and presence and number of potentially extant featuressuch as hearths, house sites, and burial tumuli). Usually, if an archaeological site exhibitssub-plow zone integrity and produces diagnostic artifacts or features, the site isinterpreted as significant in that it would very likely contain sufficient data to contributeto the understanding of the cultural history of the area and meet NRHP eligibilitycriterion D. The consultant makes recommendations regarding NRHP eligibility. Thedetermination of eligibility process requires consultation with the SH-PO and the federalagency involved in the project.Statement of Findings and RecommendationsWhere ERC locates a cultural resource within the designated project boundaries,recommendations of significance and justification are made to the MoSHPO and thefederal agency involved. A decision regarding significance would be made at that levelin terms of possible NRH-P eligibility of the resource. Recommendations that may bemade include "not eligible for NRHP status", "possibly eligible for NRHP status", or"eligible for NRIHP status." Where a recommendation of not eligible is accepted by theSHPO and federal agency a proposed compliance project can proceed as planned; arecommendation of possibly eligible results in agency request that the project bemodified to avoid the resource or given further evaluation in order to establish NRH-IPeligibility; a recommendation of eligible results in a request to modify the project toavoid the cultural resource or proceed with the consultation process as outlined by 36CFR Part 800: Protection of Historic Properties that governs the Section 106 reviewprocess established by the National Historic Preservation Act of 1966 as amended.10 PROJECT SETTINGEnvironmental SettingThe project area lies on the border of the Dissected Till Plains to the north andOzark Plateau on the south in Central Lowlands Province of North America. Thebedrock in the area consists of Mississippian limestones covered with varying depths ofclays and glacial drift as well as limestone residuum and colluvium and alluvium (cf.Branson 1944; Stout and Hoffman 1973).The project is located within a presettlement prairie zone (Kucera 1961;Schroeder 19891:7) in an upland divide between Cedar Creek on the east and BonneFemme headwaters on the west. The area exhibited a wide variety of indigenous floralspecies in the past (Chapman 1975:12-16). Early surveyors list several species of oak,hickory, black walnut, hackberry, sycamore, elm, and elders in the bottoms along withopen oak-hickory upland woodlands to the east, west, and south and grasses that wouldhave included Big and Little Bluestem, Indian Grass, Switch Grass, Side-oats Grama, andpockets of Bluejoint and Canada Wild Rye in the project area (Allgood and Persinger1979:60).Some species of animals present during the pioneer period have been extirpatedfrom their former ranges since the Euro-American settlement of the area. These speciesinclude gray wolf, elk, and bison (Chapman 1975). The mountain lion and black bearoccur rarely in the forested regions of the interior Ozark Highlands (Wood and McMillan1976). More common species in the drainage basin include white-tailed deer, gray fox,red fox, coyote, raccoon, beaver, bobcat, mink, opossum, muskrat, spotted skunk,squirrels, rabbit, and woodchuck. It is probable that the project area exhibited typicalprairie/woodland ecotonal populations in which a variety of large and small game wasavailable in both woodland and prairie settings.The climate within the project area is midcontinental and experiences temperatureextremes both seasonally and on a day-to-day basis. This area of Missouri is in the pathof cold air moving down out of Canada, warm moist air coming up from the Gulf ofMexico, and dry air from the west. The mean annual precipitation in the area is around40 inches which includes 12 to 17 inches of snow per year. The mean length of thegrowing season is around 187 days. The killing freezes generally begin between October15 and 20 and end between April 15 and 20 (Chapman 1975).The project area exhibits few characteristics suggesting high potential forpresence of intensive or extensive prehistoric occupation. The counties north of theMissouri river exhibit an ecotonal situation that included a relatively high percentage ofpresettlement prairie and lesser amount of presettlement woodland (Schroeder 1981).While Boone County was made up only of 16% presettlement prairie, the present projectoccupies the only expansive prairie zone in the county. Earlier studies have welll1 illustrated the finding that known prehistoric occupations in the region are almost entirelylocated within presettlement woodland zones with less than 3% of the known prehistoricsites found within presettlement prairie zones (cf. Sturdevant 1983). Another majorconsideration that appears to have entered into prehistoric site selection involvedavailability of cherts that were a primary raw material for much of the subsistencetechnology. Bedrock in the general area does include Missisippian age cherts that wereutilized extensively by prehistoric occupants as raw material for tools. These chertswould not have been easily accessible in the project area. The project setting would havealso lacked immediate availability of a consistent water supply necessary to support anyintensive or extensive human habitation resulting in a low prehistoric site potential.Cultural SettingThe project is located in the Central Missouri Drainage Basin (Figure 2). Theoccupation of Missouri by prehistoric populations has been generally established toinclude nine to ten traditions (cf. Chapman 1975; 1980). These traditions apply invarying degree to the entire state with some traditions often not accounted for in specificdrainages. These traditions are incorporated in what is called the cultural sequence whichis a major factor utilized in interpretation of cultural data, particularly regarding NationalRegister of Historic Place (NRHP) significance. These traditions are listed below in thesequence provided by Chapman (1975; 1980).Paleo-Indian 12000 to 8000 B.C.Dalton 8000 to 7000 B.C.Early Archaic 7000 to 5000 B.C.Middle Archaic 5000 to 3000 B.C.Late Archaic 3000 to 1000 B.C.Early Woodland 1000 to 500 B.C.Middle Woodland 500 B.C. to A.D. 400Late Woodland A.D. 400 to 900Mississippian A.D. 900 to 1400Paleo-Indian: With the exception of a possible earlier "Early Man" tradition, thePaleo-Indian is generally accepted as the earliest known occupation of Missouri. Thesespecialized hunters lived in small nomadic bands or family groups and left some traces oftheir transitory settlement pattern in the forms of hunting camps, kill sites, quarry sites,and possibly small base camps (cf. Ford 1974:388). The major diagnostic materialsassociated with the occupation includes the Clovis and Folsom fluted spear/knife points.Most fluted point finds have been located along major river valleys such as the MissouriRiver although some have been recovered along streams such as the Moreau River. Thishas been suggested to indicate that these nomadic hunters and gatherers followed thesestreams in their movement through the Midwest area. Chapman indicates that his divisionof the Northeast and Northwest Prairie region at a point in Cooper and Howard countiesabove Boonville on the Missouri River separates the major occupation zones of the12 SCALEO 4o 88 Ult.ISO 30 GO 00 120 KILOM(TI[RStPOIGOPt ORAI~GAG SAgSISFigure 2.DNR Study Unit/Drainage Basin Location of ProjectPaleo-Indian populations. That is, the steep bluffs below this point appear to have beenmore conducive to Paleo-Indian occupation than the more prairie related terrain abovethis point. Fluted points are generally more plentiful below this point toward St. Louisthan above this point toward Kansas City (Chapman 1975:75). Chapman's review ofPaleo-Indian diagnostics illustrates larger numbers of reported fluted points beginning inHoward County and continuing toward St. Louis with a small number reported fromCallaway County (1975:67).Dalton: Chapman characterizes the Dalton period as a time of transition fromPaleo-Indian big game hunting to the hunting-foraging subsistence strategy of thefollowing Archaic period (1975:96). All known Dalton sites in Missouri are small camps13 and all apparently represent short-term utilization. The basic Paleo-Indian tool kit wasstill in use during Dalton times although tools associated with plant food processingwere added. Point types with long flutes have been replaced by types with basal thinningand or short flutes. The major diagnostic includes the Dalton Serrated and perhaps theDalton adze. Distribution roughly parallels the Paleo-Indian.Early Archaic: By the Early Archaic the transition to a subsistence pattern basedon foraging was well underway. Subsistence activities were broadened to exploit moreecological niches. Hunting and gathering continued as the major economic activities butemphasis was placed on aquatic resources and vegetal foods. Although nomadicwandering was being replaced by "a regular hunting-gathering range with specific basecamp sites that were returned to at regular intervals" (Chapman 1975:135), the typicalEarly Archaic site continued to be a small hunting and or collecting camp. These arefound in a variety of environmental settings throughout Missouri including upland ridgesnear small ephemeral streams, upland bluff edges, rock shelters, and the margins of highbottomland terraces. Diagnostics of Early Archaic include Graham Cave Notched thathas been recovered in the general area (Chapman 1975). Hardin Barbed is also generallyassociated with Early Archaic occupation.Middle Archaic: The Middle Archaic was basically a continuation and expansionof a forager tradition begun in the Dalton and Early Archaic. A drying climate forcedgreater reliance upon collecting vegetal foods and small animals as opposed to wetenvironment subsistence. Sites continued to be small, exhibiting semi-nomadic orseasonal occupation with no specific topographic location associated (Chapman1975:159). The tool kit continued to expand, depending upon the extraction activity inthe specific niche. The drying climate was reflected in the marked tendency for MiddleArchaic sites to be located almost exclusively in or very near bottomland settings(Chapman 1975). There are no complexes associated with the period in this general area.Collectors in the area often have Big Sandy formls in their collections. It is assumed thatMiddle Archaic was present but in an as yet poorly defined situation. Site forms for thedrainage are inconclusive in terms of presence of Middle Archaic diagnostics.Late Archaic: The Late Archaic is somewhat better known than earlier traditions.This is a result of the greater population apparently represented by the Late Archaicwhich resulted in more expansive and numerous occupations. This period generally lacksthe small dart point of the earlier traditions that suggests that hunting had become lessimportant for subsistence. In addition, tool kit function appears to have expandedsuggesting reliance on a much larger variety of potential foods requiring varied extractionand processing techniques. The Late Archaic began toward the climax of a warmingtrend that reached its height around 2000 B.C. (Cleland 1966), with a resultantdiminishing of the faunal and floral forest species. The Late Archaic peoples had toadapt to new ecological niches with concomitant changes in subsistence related artifacts.Emphasis was probably placed on a method of procurement that could effectively exploitvarious types of resources which were available in reliable quantities at varying seasons.Using a central-based wandering settlement pattern in which the particular seasonal14 resources available would determine the type and location of temporary camps radiatingfrom more permanent occupation sites, Late Archaic settlement pattern appears to havebeen somewhat more restricted than previous foraging traditions. Diagnostic artifacts ofthis period include the Sedalia Lanceolate and Diggers, Clear Fork Gouge, Smith BasalNotch, Afton, Etley, Nebo Hill, Stone Square, as well as 3/4 groove granite axes.Evidence of the Sedalia complex are often found just over the crown of the slope of highridges (Chapman 1975:200). Late Archaic occupations are one of the more commonlyidentified traditions in the drainage according to ASM records.Early Woodland: The Early Woodland period is identified by presence of BlackSand Incised pottery and is poorly represented throughout most of Missouri. In spite ofintensive surveys in various areas of the state, only a few unquestionable Early Woodlandsites have been identified and include Avondale, Renner, and Shields sites in the KansasCity area and a few in the northeast portion of the state. These and other possible EarlyWoodland sites are generally found in the major river valleys, particularly along theMissouri River.Middle Woodland: The Middle Woodland period occupation in northernMissouri is focused on three related regional centers: The Havana center in the LowerIllinois River Valley and adjacent Mississippi River valley in the northeast, the KansasCity Hopewell, and Big Bend centers. The latter two are on the Missouri River.Analyses of pottery from the three centers indicate there was an intrusion of people intothe Big Bend and Kansas City areas from the Havana center to the east (Wedel 1943)although the initial intrusion appears to have been related to subsistence and/or politicalstress (Struever & Houart 1972) in the Havana center, contacts among the three centerswas maintained throughout the Middle Woodland period (Chapman 1980). Thesecontinued contacts insured the Big Bend and Kansas City areas of a place in the ClassicMiddle Woodland's Hopewell Interaction Sphere. Evidence for a Middle Woodlandoccupation is very sparse outside of the areas noted. Some rock shelters and openhabitation sites in the general area have produced Middle Woodland diagnostics andChapman identified south Boone County as a major Middle Woodland center (1980).There has been no corroborating evidence through field investigations regarding theassertion by Chapman. In general, with the exception of the Big Bend and Kansas CityHopewell, Middle Woodland diagnostics usually are interpreted from lithics such asSnyders points with ceramics reflecting Hopewellian occupation lacking but for thecenters.Late Woodland: The Late Woodland period exhibits the most numerous definedcomponents within prehistoric sites in the general project area. The occupation in thisportion of Missouri has sometimes been defined as a regression from the precedingtraditions in that emphasis on horticulture developed earlier in the Woodland wassupplanted by earlier hunting subsistence reliance. This pattern is seen in the increase insmall temporary camps along with use of bow and arrow. Diagnostics include grit andlimestone tempered pottery, arrow points, burial mounds, and shallow side notchedpoints. Several Late Woodland sites have been identified in the county including both15 open habitation sites and burial tumuli. A large number the archaeological sitesidentified in the general project area have exhibited Late Woodland diagnostics(Sturdevant 1978).Mississippian: The Early Mississippian period is not well documented in thegeneral area of the project. Steed-Kisker, an Early Mississippi phase, is located in theKansas City area while Cahokia and the St. Louis area represent a climax associated withEarly Mississippian (Chapman 1980). Diagnostics for this period include smalltriangular arrow points and shell tempered ceramics. Where Early Mississippianexperienced climax levels, temples and towns were part of the settlement pattern. In theimmediate area only triangular points and an occasional shell tempered sherd have beenreported. Early Mississippian Steed-Kisker people apparently abandoned the KansasCity area around A.D. 1250 and around A.D. 1350 the Oneota cultural tradition appearedsuddenly in the Big Bend area near the junction of the Grand, Chariton, and Missouririvers. It is speculated that Oneota developed in northern Missouri and Iowa and itsformation was stimulated by developments at the Cahokia center. While the extent ofCahokia influences remains unknown, cultural developments of the period in that areahave been connected to the cultural background and growth of the historic Siouan-speaking people (Griffin 1960). The most prominent Oneota village in the Big Bendarea is the Utz site and it was there the Utz phase, which documents the Oneota cultureof the area, was defined. The Utz phase, and the Oneota occupation, began at about A.D.1350 and lasted to the end of the Mississippian period (A.D. 1700) when Oneota blendsinto what is recognized as the Historic Missouri Indian tribe.Historic Period: During the period from 1730 to 1790, the Missouri tribe wasbeing depleted by smallpox and its power was continually being tested by its enemies tothe north. By the 1780's, the Missouri became heavily dependent on their allies theOsage for protection. In spite of this, the Sac and Fox conquered and dispersed theMissouri tribe in the 1790's. Those who were not killed joined the Osage, Kansas, andOto tribes. The great smallpox epidemic of 1823 reduced their numbers to less than onehundred and Missouri as a distinct cultural entity became extinct. The last full-bloodMissouri Indian died on the Oto reservation in 1907 (Chapman 1946:29).The lands encompassed by the project were but a small part of North Americanterritory claimed by France until 1762 when it was transferred to Spain by secret treaty.Spain retroceded the land to France in 1801 and France ended up selling it to the U.S. in1803 as the Louisiana Purchase. In 1812, congress created the Territory of Missouri andin 1821 Missouri was recognized as the twenty-first state (March 1963). In general, thepost-1800 history of central Missouri reflects both the general patterns of agriculturaldevelopments in the Midwest and specific influences which shaped the region. Theprocess of early settlement and the struggle to produce beyond a meager subsistence, theexpansion of the agricultural and commercial activities and creation of a stable society,followed by an era in which regional concerns were shaped by state and national trends,are all recognized as part of the evolution of the Midwest. In the case of northernMissouri, anl understanding of its Euro-American past requires recognition of the16 influence of the settlers themselves and of the land which they occupied. The earlysettlers came primarily from the Upper South, especially Kentucky, Tennessee, andVirginia. Prior to the Civil War, first tobacco and then corn played an important role inthe agricultural economy of the region. The first permanent settlers began entering thearea in the early 1800's, a process that really began only after the acquisition of theLouisiana territory by the U.S. in 1803. Congress created the territory of Missouri in1812 and nine years later recognized Missouri as the twenty-first state (Meyer 1963).The rapid development fr-om uncharted wilderness to statehood stemmed directly fromthe massive westward movement of population during the early nineteenth century. Mostof the settlers who came to mid-Missouri were attracted to the land. The fertile soil,adequate rainfall, and a growing season that averaged six months a year made the regionparticularly well-suited for agriculture. A rich, friable loam predominated, withsubstantial stands of timber which provided building materials and generally remindedthe immigrants of the lands which they had left behind.The background of the settlers made them receptive to cultivating a crop thatwould reproduce the agricultural patterns of their native states. Most of the early settlerscame from the Upper South that included slave holding states. March (1967) suggeststhat within the "slave belt" through central Missouri, major crops included hemp andtobacco. These crops, particularly tobacco, demand intensive labor for productivity.Tobacco is generally favored as a cash crop in that it produced a greater value inproportion to bulk when compared to grain crops. In areas such as the project,transportation would have been a problem prior to the railways. Cash crops such astobacco in areas that did not provide viable river transportation soon shifted to localconsumption crops such as corn and wheat. While not well documented at present, it isapparent that agricultural pursuits were almost entirely geared toward corn and wheat bythe time of the Civil War. It is further apparent that slave holding had begun to drop at arelatively high rate prior to the Civil War (Campbell 1874). The land and its location,then, became major shaping forces of the economic system of the area, altering theprevious patterns established in the southeast and brought to the Midwest. The coming ofthe railroad in the 1850's through the 1870's opened the interior to greater trade andagricultural products have been the major source of livelihood in the general area sincethis time.17 INVESTIGATION FINDINGSRecords and Literature ReviewBoone County, Missouri currently contains 49 National Register of HistoricPlaces (NRHP) properties. These include the following:Ballenger Building (Downtown Columbia, Missouri MPS), 27-29 South Ninth St.,Columbia (1/21/04)Bond's Chapel Methodist Episcopal Church, MO A, 2.5 mi. NE of Hartsburg,Hartsburg vicinity (9/09/93)Boone. John W. ("Blind"). House (Social Institutions of Columbia's Black Comm unityTR [see note*]), 4th St. between E Broadway and Walnut, Columbia (9/04/80)Central Dairy Building (Downtown Columbia, Missouri MPS), 1104-1106 EastBroadway, Columbia (1/20/05)Chance, Albert Bishop. House and Gardens. 319 E Sneed St., Centralia (7/03/79)Chatol (F. Gano Chance House, Chance Guest House), 543 S Jefferson, Centralia(4/20/79)Coca-Cola Bottling Co. Building (Downtown Columnbia. Missouri MPS), 10 Bitt St.,Columbia (2/14/06)Columbia Cemetery, 30 East Broadway, Columbia (2/01/07)Columbia National Guard Armory, 701 E Ash St., Columbia (3/25/93)Conley, Sanford F.. House, 602 Sanford P1., Columbia (12/18/73)Douglass, Fred, School (Social Institu~tions of Columbia's Black Community TR [seenote*]), 310 N Providence Rd. (9/04/80)Downtown Columbia Historic District (Downtown Coluimbia, Missouri MPS; ma [seenote]), parts of 7th, 8th, 9th, 10th, E. Broadway, Cherry, Hitt, Locust, and E. WalnutStreets, Columbia (11/08/06)Downtown Columbia Historic District (Downtown Columbia, Missouri MPS; boundaryincrease), 1019,1020,1023 & 1025-33 E. Walnut St., Columbia (5/08/08)18 East Campus Neighborhood Historic District, roughly bounded by Bouchelle, College,University, and High Sts., including parts of Willis, Bass, Dorsey, and Anthony Sts.,Columbia (2/16/96)Eighth Broadway Historic District [Miller Building, Matthews Hardware, MetropolitanBuilding], 800-8 10 E. Broadway Blvd., Columbia (4/22/03)Elkins, Samuel H. and Isabel Smith, House, 315 N 10th St., Columbia (9/12/96)First Christian Church, 101 N 10th St., Columbia (10/29/91)Francis Ouadrangle Historic District (Red Campus), bounded by Conley Ave., Elm,6th and 9th Sts., Columbia (12/18/73)Frederick Apartments, 1001 University Ave., Columbia (4/16/13)Gordon, David, House and Collins Lo2 Cabin (Gordon Manor, Fairmount, CedarView), 2100 E Broadway, Columbia (8/29/83)Gordon Tract Archaeological Site, address restricted (3/16/72)Greenwood (Greenwood Heights), 3005 Mexico Gravel Rd., Columbia (1/15/79)Guitar, David, House (Confederate Hill), 2815 Oakland Gravel Rd., Columbia (9/09/93)Hackmnan, Samuel E., Building, 30 S St., Hartsburg (12/10/98)Hamilton-Brown Shoe Factory, 1123 Wilkes Blvd., Columbia (7/19/02)Hunt, William B., House, 8939 W Terrapin Hills Rd., Columbia vicinity (1/09/97)Kress Building (Downtown Cohumbia, Missouri MPS), 1025 E. Broadway, Columbia(3/09/05)Maplewood, Nifong Blvd. and Ponderosa Dr., Columbia (4/13/79)McCain Furniture Store (Downtown Cohumbia, Missouri MPS), 916 E. Walnut,Columbia (8/1 7/05)Missouri, Kansas and Texas Railroad Depot, 402 E Broadway, Columbia (1/29/79)Missouri State Teachers Association, 407 S 6th St., Columbia (9/04/80)Missouri Theater, 201-2 15 S 9th St., Columbia (6/06/79)19 Missouri United Methodist Church, 204 S 9th St., Columbia (9/04/80)Mount Zion Church and Cemetery (Rural Church Architecture of Missouri, c. 1819 toc. 1945 MPS), 11070 Mount Zion Rd., Hallsville vicinity (1/14/13)North Ninth Street Historic District (Downtown Columbia. Missouri MPS) (_map_ [seenote]), 5-36 North Ninth St., Columbia ( 1/21/04)Payne, Moses U., House, 201 N Roby Farm Rd., Rocheport vicinity (10/07/94)Pierce Pennant Motor Hotel (Candlelight Lodge), 1406 Old Hwy. 40 W, Columbia(9/02/82)Rocheport Historic District, MO 240, Rocheport (10/08/76)St. Paul's A.M.E. Church (Social Institutions of Cohumbia's Black Community TR [seenote*]), 501 Park St. (9/04/80)Sanborn Field and Soil Erosion Plots, University of Missouri Campus, Columbia(10/15/66; NHL 7/19/64)Second Baptist Church (Social Institutions of C'olumbia's Black Community, TR [seenote*]), 407 E Broadway (9/04/80)Second Christian Church (Social Inst itutions of Columbia'is Black Comm unity TR [seenote*]), 401 N 5th St. (9/04/80)Senior Hall, Stephens College Campus, Columbia (8/02/77)Stephens College. South Campgus, 1200 E. Broadway, Columbia (11/25/05)Taylor. John N. and Elizabeth, House, 716 West Broadway, Columbia (5/25/01)Titer Hotel, 23 S 8th St., Columbia (2/29/80)Virginia Building~, 111 South Ninth Street, Columbia (3/13/02)Wabash Railroad Station and Freight House (Norfolk and Western Depot), 126 N10th St., Columbia (10/11/79)West Broadway Historic District, 300-922 W. Broadway (except 800, 808, 812),Columbia (4/27/10)Wright Brothers Mule Barn, 1101-1107 Hinkson Ave. & 501-507 Fay St., Columbia(11/01/07)20 There are no previously recorded prehistoric archaeology sites within the projectboundaries (Figure 3). [Proprietary Information] The project area contains no recordedhistoric architecture or possibly significant historic events.Review of 19th and 20th century plat maps and 20th century USGS topographicquadrangles found no evidence of structures within the proposed project area. The1967/81 USGS topographic quadrangle does not illustrate any structures in the projectboundaries.Field Investigation FindingsThe field investigation was carried out under generally mixed to poor surfacevisibility conditions averaging less than 20% in a grass/hay setting (Figure 4). Shoveltests were utilized in order to interpret presence/absence of cultural resources asdescribed in the methods section of this report. The presence of erosion cuts and pathsalong with shovel tests allowed for a sample of subsurface soil matrix for interpretationof potential for presence/absence of buried cultural resources.The field investigation failed to identify any evidence of the presence ofprehistoric occupation of the area. Typically, this includes presence of chert debitage,fire-cracked rock, lithic artifacts, and occasionally ceramics. None of these materialswere encountered on the surface or in shovel tests. No prehistoric sites have beenrecorded.Historic resources include recently constructed roads which do not meet theinvestigators' historic site designation criteria. No historic sites have been recorded.It is the finding of this Phase I cultural resources survey that Lot 15 in theDiscovery Ridge development contains no possibly significant cultural resources.21

[Proprietary Information]22 II ap Scale = 1s275Figure 4,Aerial Photograph of Project Area Surveyed (YELLOW)9 RECOMMENDATIONSDuring September 2013 a Phase I cultural resources survey was carried out for a7.5 acre tract of land at Discovery Ridge, Boone County, Missouri. The area is thelocation of a proposed commercial development project.There are no National Register of Historic Places (NRHP) properties locatedwithin the proposed project area; DNR GIS records indicate presence of no recordedarchaeology sites within the project boundaries; and no recorded Missouri DNR historicarchitectural sites are present within the project area of potential effect (APE). 19thcentury plat maps do not illustrate any structures within the project area.The field investigation was carried out under poor surface visibility conditions ina grass/hay setting. Shovel testing was implemented following guidelines described inthis report. No evidence of the presence of prehistoric occupation was identified withinthe project area. No evidence of the presence of early historic occupation was identifiedwithin the project boundaries.On the basis of the negative findings regarding presence of possibly significantcultural resources, it is the recommendation of this Phase I cultural resources survey thatthe proposed project proceed as planned in terms of Section 106 compliance concerns.No significant cultural resources will be threatened by the proposed project actions.24 BIBLIOGRAPHYAligood, F. P. and I. D. Persinger1979 Missouri General Soil Map and Soil Association Descriptions.Soil Conservation Service. Columbia.Asch, D. I.1976Baker, M.1984The Middle Woodland Population of the Lower IllinoisRiver Valley: A Study in Paleodemographic Methods.Northwestern University Archaeological Program,Scientific Papers. 1.Analysis of Refuse Pits 23CO 156, Cole County, Missouri.M.A. Thesis. UMC. Anthropology Department.Boone County Land Assessment Book1875 through 1931. State Archives.Branson, E. B.1944The Geology of Missouri. University of Missouri Studies.Vol. 19, No. 3. Columbia.Broadhead, G. C.1890 Prehistoric Evidences in Missouri.. Annual Report of the SmithsonianInstitution for the Year 1878. Washington D.C.Campbell, R. A.1874 Gazetteer of Missouri. R.A. Campbell. St. Louis.Chapman, C. H.1975 The Archaeology of Missouri I. University of MissouriPress. Columbia.1980 The Archaeology of Missouri II. University of MissouriPress.Cleland, C. E.1976The Focal-Diffuse Model: An Evolutional Perspectiveon the Prehistoric Cultural Adaptations of the EasternU. S. Midcontinental Journal of Archaeology. 1:59-76.25 Collier, J. E.1955 Geographic Regions of Missouri. Annals of theAssociation of American Geographers. 45 (4):368-92.Conard, H. L.1901Encyclopedia of the History of Missouri. The Southern HistoryCompany. New York.Denny, S. G.1964 A Re-evaluation of the Boone Focus: A Late Woodland Manifestationin Central Missouri. M.A. Thesis, UMC.Edwards Brothers1875 Historical Atlas of Boone County, Missouri. Edwards BrothersPhiladelphia.Evans, D. R., E. G. Garrison, and D. J. Ives1977 Cultural Resources Survey: Columbia, Missouri, Phase I SewerImprovements. EPA.Fowkes, G.1910Grantham, L.1977Griffin, J. B.1961Antiquities of Central and Southeastern Missouri. SmithsonianInstitute, Bureau of American Ethnology Bulletin 37. Washington D.C.Cultural Resources Survey Long Branch Lake: ArchaeologyResources. COE.Some Correlations of Climate and Cultural Change inEastern North American Prehistory. Anal New YorkAcademy of Science. 95:710-717.Haas, D.1978 An Archaeological Survey of the Little Femme OsageRiver Hills Area and the Loutre River Valley. DNR.Howe, W. B. and J. W. Koenig1963 The Stratigraphic Succession in Missouri. GeologicalSurvey and Water Resources Series 3.Klippel, W. E.1965 An Archaeological Investigation of the Lower Osage River Valleyin Missouri. M.A. Thesis, UMC.26 Kay, M.1980March, D. D.1967The Central Missouri Hopewell Subsistence -SettlementSystem. Missouri Archaeological Society, Research SeriesNo. 15.The History of Missouri. Lewis Historical Company.New York.Martin, T.1983 An Archaeological Survey in the Middle Drainage -LamineRiver. DNR/HPP Grant. Jefferson City.Northup, B. B.2001 We are Not Yet Conquered: The History of the Northern CherokeeNation of the Old Louisiana Territory. Turner Publ. Co. Paducah,Kentucky.Northwest Publishing Co.1898 Plat Map of Boone County, Missouri. Northwest Publishing Co.Philadelphia.O'Brien, M.1984Ogle, G. A.1917Archaeological Testing of the Route 63, Boone County Project,Missouri. MoDOT.Standard Atlas of Boone County, Missouri. George A. Ogle & Co.Chicago.Raisz, I.1957 Physiographic Regions of the U.S. Map.Reeder, R. L., E. E. Voigt, and M. J. O'Brien1983 Investigations in the Lower Perche -Hinkson Drainage.EPA.Rollins, J. S.1853 Land Entry Atlas of 1853. Boone County, Missouri -State Archives.Schmits, L. J.1981 Archaeological Investigations at the Roddy Site (23BO966) and theCoatesSites (23BO965), Boone County, Missouri. EPA.27 Schmits, L. et al.1985 Prehistory of the Lower Perche- Hinkson DrainageCentral Missouri Archaeological Investigations at theColumbia Regional Wastewater treatment Facility.Shoemaker, F. C.1943 Missouri and Missourians. Lewis Publishing Company, Chicago.Stevens, W. B.1915 Missouri the Center State, Vol. II. S. J. Clarke Publishing, St. Louis.Struever, S. and G. I. Houart1972 An Analysis of Hopewell Interaction Sphere: INSocial Exchange and Interaction. E. N. Wilmseneditor. University of Michigan, Museum ofAnthropology. Anthropological Papers. No. 3.Sturdevant, C.1976 Cultural Resource Survey, Algoa Reformatory, Cole County,Missouri. DNR/I-IPP.1989 Phase IIl Data Recovery, 23CY499, Callaway County, Missouri.MoDOT.Wedel, M. M.1943 Archaeological Investigations in Platte and ClayCounties, Missouri. U. S. National Museum Bulletin, No. 183.Weichman, M. S. and D. Weston1986 Master Plan for Archaeological Resource Protection inMissouri. DNR/HPP. Jefferson City.28 t Jeremiah W. (Jay) Nixon. Governor

• Sara Parker Paudey, Director....T OF NATURAL RESOURCESgovOctober 10, 2013Carolyn HaasVice President/Technical Program DirectorNorthwest Medical Isotopes. LLC815 NW 9m Avenue, Suite 256Corvallis, Oregon 97330Re: Lot 15, Discovery Ridge (NRC) Boone County, Missouri

Dear Ms. Haas:

Thank you for submitting information on the above referenced project for our review pursuant to Section106 of the National Historic Preservation Act (P.L.89-665, as amended) and the Advisory Council onHistoric Preservation's regulation 36 CFR Part 800, which requires identification and evaluation of culturalresources.We have reviewed the September 2013 report entitled Cultural Resource Investigations, Phase / Survey,Lot 156- Discovery Ridge, Boone County, Missouri by the Environmental Research Center of Missouri,Inc. Based on this review it is evident that a thorough and adequate cultural resources survey has beenconducted of the project area. We concur with the investigators recommendation that there will be nohistoric properties affected and, therefore, we have no objection to the initiation of project activities.Please be advised that, should project plans change, information documenting the revisions should besubmitted to this office for further review. In the event that cultural materials are encountered duringproject activities, all construction should be halted, and this office notified as soon as possible in order todetermine the appropriate course of action.If you have any questions, please write Judith Deel at State Historic Preservation Office, P.O. Box 176,Jefferson City, Missouri 65102 or call 5731751-7862. Please be sure to include the SHPO Log Number(003-B0-14) on all future correspondence or inquiries relating to this project.Sincerely,STATE HISTORIC PRESERVATION OFFICEMark A. MilesDirector and Deputy StateHistoric Preservation OfficerMAM:jdc Larry W. Camper, NRCCraig Sturdevant, ERCR t3c)frtd Pale~r This page intentionally left blank.