U.S. D!PARTM!NT OJI!N!RGY OFFICE OF SCIENCE- CHICAGO OFFICE



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sc.cu ~ g;o.ar.n (1 I!WI Pr.W.W ~.,.on~'- U.S.!PARTM!NT OJI!N!RGY OFFICE OF SCIENCE- CHICAGO OFFICE NATIONAL ENVIRONMENTAL POLICY ACT (NEPAl ENVIRONMENTAl. EVALUATION NOTIFICATION FORM To be completed by "financial assistance award" organization receiving Federal funding. For assistance (Including 11 point of contact), see "Instructions for Preparing SC CH F 56, Environmental Evaluation tification Form". Solicitation/Award. (If applicable): ~~'!uest for lsoto--'pe_p_r_od_uc_oo_ _n_p_r_o: po_sa_ls_2 1_1 Organization Name: Washington University Title of Proposed Project/Research: Production of Positron Emitting Radiometals: Cu-64, Y-86, Zr-89 Total OE Funding/Total Project Funding: -"-39'-9'-9'-8------------------------- I. Project escription <use additional paaes as necessarv>: A. Proposed prolect/actlon (delineate Federally f~;~nded!n-federally funded portions) This proposal seeks support to increase our production of yttrium-86 and zirconium-89 production while continuing to produce copper-64. We have the advantage that we already ship out copper-e4 to some 12-15 institutions per week (over 6 different lnstliutlons total including 2 Canadian sites) and thus our group already has significant experience with producing and snipping radioactive materials. The majority of the funds requested will go towards the purchase of a new hotcell for the production of Zlrconium-89. This proposal aims to produce quantities of copper-64, yttrium-86 and zlrconlum-891n quantnles and schedules suitable for distribution and In support of current and upcoming clinical trials. B. Would!he prolect proceed without Federal fundlna? If 'yes", describe the Impact to the scope: II. escription of Affected Environment: Laboratory setting with suitable radiation protection and monitoring Page 1 of 4

Chic:a~ Offic:e NEPA Tracking NumNr Ill. Preliminary Questions: A. Is the OE-funded worls entirely a "paper study"? ~ If "Y ", nsul'fl that the description In Section I reflects thltj and go directly to Section V. B. Will the work to be performed take place entirely in existing buildings? And NOT: 1. 2. 3. 4. 5. 6. Threaten a violation of applicable statutory, regulatory, or permit requirements for environment, safety, and health? Require the siting, construction or major expansion of waste treatment, storage, or disposal facilities? isturb hazardous substances, pollutants, or contaminants preexisting in the environment? Adversely alfect environmentally-sensitive resources identified in Section IV.A.? Be connected to another existing/proposed activity that could potentially create a cumulatively significant impact? Have an inherent possibility for high consequence impacts to human health or the cnvironmont (e.g., Biosafety Level3 41aboratories, actlvlties involving high levels of radiation)? ff "" to Question 111.8. and ALL six subsequent questions, ensure the descriptions In Sections I and II reflect this and go directly to Section v. IV. Potential Environmental Effects: Attach/Insert an explanation for each "" response. A. Sensitive Resources: Will the proposed action result In changes and/or disturbances to any of the following resources? 1. 2. 3. 4. 5. 6. 7. 8. 9. 1. 11. 12. Threatened/Endangered Species and/or Critical Habitats Other Protected Species (e.g., Burros. Migratory Birds) Sensitive Environments (e.g., Tundra/Coral Reefs/Rain Forests) Archaeological/Historic Resources Important Farmland n-attainment Areas for Ambient Air Quality Standards Class I Air Quality Control Region Special Sources of Groundwater (e.g. Sole Source Aquifer) Navigable Air Space Coastal Zones Areas with Special National esignation (e.g. National Forests, Parks, Trails) Floodplains and Wetlands B B B. Regulated SubstancesfActivtlies: Will the proposed action Involve any of the following regulated Items or activities? 13. 14. 15. 16. 17. Natural Resource amage Assessments Exotic Organisms xious Weeds Clearing or Excavation(indicate if greater than one acre) redge or Fill (under Clean Water Act, Section 44, Indicate if greater than ten acres) Page 2 of 4

Chicago Off/co NEPA Tracking Numb<Jr B. Regulated Substances/Activities: Will the proposed action involve any of the followjng reaurated Items or activities? (continued) i 8. ise (in excess of regulations) 19. Asbestos Removal 2. PCB's 21. Import. Manufacture, or Processing of Toxic Substances 22. Chemical Storage/Use 23. Pesticide Use 24. Hazardous, Toxic, or Criteria Pollutant Air Emissions 25. Liquid Effluents 26. Underground Injection 27. Hazardous Waste 28. Underground Storage Tanks 29. Radioactive Mixed Waste 3. Radioactive Waste 31. Radiation Exposure 32. Surface Water Protection 33. Pollution Prevention Act 34. Ozone epleting Substances 35. OH-Road Vehicles 36. Blosafety Level 3 4 Laboratory [21 12?] 1:81 l8l 181 t8:l 181 121 t8:l t8:l t8:l 181 ~ ~ t8l t8:l t8:l t8:l 181 C. Other Relevant Information Will the proposed action involve the fo!lowlna? 37. Potential Violation of Environment, Safety, or Health Regulations/Permits 38. Siting/Construction/Major Modification of Waste Recovery, or Waste Treatment, Storage, or isposal Facilities 39. isturbance of Pre-existing Contamination 4. New or Modified Federal/State Permits 41 Public Controversy 42. Environmental Justice 43. Action/Involvement of Another Federal Agency (e.g. license, funding, approval) 44. Action of a State Agency In a State with NEPA-type law. (oes the State Environmental Quality Review Act apply?) 45. Public Utilities/Services 46. epletion of a n-renewable Resource 47. Extraordinary Circumstances 48. Connected Actions 49. Exclusively Bench-top Research 5. Only a Laboratory SeUing 181 [8:1 181 t8l l8l 181 l8j ~ l8l t8:l l8j 181 181 181 B. Optional Concurrence (Name and Title): Signature: ate: e-mail: ------------------------------------ Phone: ------------------------ Page 3 of 4

Chicago Office Nt=PA Trt1Cklng Number Remainder to be completed by SC-CH VI. SC-CH Concurrence/Recommendation/etermination ; A. SC CH Office of Acauiaition and Aaal:stance or Office of Safety. Technical & lnfra:structure Service:~ : B. SC-CH NEPA Team Review: Is the project/activity appropriate for a determination or a recommendation to the Head of the Field Organization by the NEPA Compliance Officer (NCO) under Subpart of the OE NEPA Regulations? ~ Specific class(es) of action from Appendices A- to Subpart (1 CFR 121): ~ 3, { Name and Title: - - ---- ----------------------- - - - Signature: ate: --"---- C. SC-CH Counsel!If necessary): Name and Title: - - --------------------------- --- Signature: ate: - -----. SC-CH NEPA Compliance Officer: The preceding pages are a record of documentation required under OE Final NEPA Regulation, 1 CFR 121.4. Action may be categorically excluded from further NEPA review. I have determined that the proposed action meets the requirements for Categorical Exclusion referenced above. Action requires approval by Head of the Field Organization. Recommend preparation of an Environmental Assessment. Action requires approval by Head of the Field Organization or a Secretarial Officer. Recommend preparation of an Environmental Impact Statement. Comments/Limitations if necessary: s;goo~~ ~~~ P err. Siebach SC CH NEPA Compliance Officer ate: Page4 of4

"Production of Positron Emitting Radiometals: Cu-64, Y-86, Zr-89" Washington University School of Medicine Principal Investigator: Suzanne Lapi. Ph.. Use of radioactive substances Washington University in St. Louis has been producing and distributing non-standard PET radionuclides to the research community for over 1 years. The radionuclides that have been produced include copper-64, bromine-76, gallium-66, yttrium-86, bromine-77, iodine-124 and zirconium-89. Presently, copper-64 is produced on a regular basis and yttrium-86, bromine-76 and zirconium-89 sporadically in lower quantities. The increase in shipping of copper-64 to external institutions is illustrated ---------------- -- in Figure 1 and is mainly due to the increasing in clinical trials 5' 1 with this isotope. Since the... inception of our automated ~ Booo production system, (October 1, ~ 28) we have had 145 ~ productions, produced 53562 ~.!. mci and shipped out 25629 mci [ to external users. It is important g- to note that 9861 mci of this has been produced for human use protocols. u 6 4 2 Figure 1. Shipping of copper-64 to outside users from Washinqton University This proposal seeks support to increase our production of yttrium-86 and zirconium-89 production while continuing to produce copper-64. We have the advantage that we already ship out copper-64 to some 12-15 institutions per week (over 6 different institutions total including 2 Canadian sites) and thus our group already has significant experience with producing and shipping radioactive materials. A significant portion of the funds requested will go towards the purchase of a new hotcell for the production of zirconium-89. This proposal aims to produce quantities of copper-64, yttrium-86 and zirconium- 89 in quantities and schedules suitable for distribution and in support of current and upcoming clinical trials.

All proton irradiations will be carried out using the Washington University CS-15 (Cyclotron Corporation, Ep = 15 MeV) shown below in Figure 2. Figure 2. Washington University CS-15 Cyclotron All radioactive materials produced will be allowed to decay in appropriate shielded storage areas after use. The Principle Investigator, r. Lapi, is an authorized user of radioactive substances and all individuals under her supervision have the necessary training to work with radioactive materials. Washington University has an excellent team of radiation safety personnel and is compliant with all NRC regulations.