Virginia Program Office

for Recycling & Disposition of

Spent Nuclear Fuel

Virginia Program Office for Spent Nuclear Fuel (SNF) Disposition

Project Plan (Basics)

Page 1 of 4

Background: The nuclear business decided, in the 1950s, to recycle spent nuclear fuel and was on track

to make that happen in time to accept this material from commercial reactors. In 1976, President Ford

declared that recycling spent nuclear fuel was a proliferation risk and issued a presidential declaration

banning reprocessing of spent nuclear fuel. President Carter renewed the ban which put all three

existing recycling companies out of business. By the time President Reagan reinstated the ability to

recycle, the industry was entrenched in mining and enriching uranium to make fuel and the idea of

recycling was tabled. The Nuclear Waste Policy Act in 1982, as amended in 1987, enacted a deep

geologic repository plan to bury commercial spent nuclear fuel in Yucca Mountain (about 100 miles

north of Las Vegas).

The US Government spent $10 billion+ from a fund collected from nuclear power rate payers to study

the geology of Yucca Mountain. Because of Nevada politics, the project was delayed from the planned

opening in 1999. In 2010, the project was defunded. This has resulted in a situation in which the US

Government spends $2.2 million per day to store spent nuclear fuel on each nuclear reactor site. The

fund for handling spent nuclear fuel is currently at $40 billion+ and can be spent for no other purpose.

No progress toward a permanent solution for spent nuclear fuel is in force and no State in the United

States has consented to accept the spent nuclear fuel for disposition.

Introduction and discussion: The US Congress and the current administration heartily support nuclear

energy. For example, the preponderance of the nation is in favor of starting up the project to bury spent

nuclear fuel in the Nevada desert, as evidenced by the overwhelming House vote (340-72) on H.R. 3053,

The Nuclear Waste Policy Act of 20181. Nevada realizes that they are weak in seniority in both the

Senate and House, so they are expected to increase the number of law suits filed in the 9th Circuit Court

to extract as many delays as they can to thwart the effort to secure a final resting place for the spent

nuclear fuel from the United States’ nuclear power plants. Since there appears, at least to the nuclear

professional community, to be no material showstoppers for moving this program along and since it is

the law of the land, it makes sense that the spent fuel issue gets put to bed once and for all. However,

since recycling will preclude the need for a deep geologic repository, the door is open for Virginia to

become the nuclear and clean energy capital of the United States (and a major player in the world).

Virginia is in a perfect position to lead this effort. The university system has a well-established nuclear

engineering program, there is a wealth of nuclear industry in the State, and the citizens have, for the

most part, viewed the nuclear industry as a beneficial one within their State. Virginia also values clean

energy (as does most of the rest of the United States). While renewables have their place in clean

energy, they are suffering from lack of efficient storage, minimal development in the marketplace,

limited lifetime, and recycling issues. The ideal situation would be to advocate next generation nuclear

reactors (Small Modular Reactors or SMR) to supply the base load power source for renewable energy

sources instead of fossil-fuel driven natural gas and coal. Since Virginia already has operational

experience in nuclear reactors and supports the educational programs and research, it would be an ideal

location for the Carbon-Free Energy National Laboratory. Overwhelmingly, when citizens are presented

with the facts and the potential benefits, they favor proceeding with the program. As part of an ANS

1 https://www.congress.gov/bill/115th-congress/house-bill/3053/all-actions?overview=closed&q=%7B%22roll-call-

vote%22%3A%22all%22%7D

Virginia Program Office for Spent Nuclear Fuel (SNF) Disposition

Project Plan (Basics)

Page 2 of 4

Operations and Power Division grant, ANS-Nevada has been conducting outreach to organizations in

northern and southern Nevada. Over the past 4 years, Steve curtis has personally presented to 12

groups on nuclear basics and spent nuclear fuel facts (some on this grant and some independent of this

grant). All of these groups were overwhelmingly in favor of recycling spent nuclear fuel if it leads to

benefits from the US Government and the potential for high-tech business development related to

nuclear energy production. This would lead us to believe that, armed with facts and a picture of the

economic development potential, Virginians would be in favor of spent nuclear fuel acceptance and

their priority for its inception would be high.

Four organizations in South Carolina and Nevada are leading the charge for Nevada clean nuclear energy

business development. The analogs for Virginia would certainly include the Virginia Nuclear Energy

Consortium Authority (VNECA)

1. Citizens for Nuclear Technology Awareness (CNTA) – This is a non-profit organization formed in

Aiken South Carolina (the site of the Savannah River National Laboratory) to promote public

education programs for nuclear energy and encourage the establishment of more business

cases for the nuclear industry, especially for Government programs. CNTA has become an

organization with more than 400 individual members and corporate members include world-

class companies such as Savannah River Nuclear Solutions, Savannah River Remediation, B&W

Technologies, CB&I AREVA MOX Services, the Centerra-SRS Team, and others who recognize the

importance of CNTA programs.

2. The American Nuclear Society - Nevada Section - The nucleus of support for the acceptance of

spent nuclear fuel in Nevada has been driven by the ANS section for more than 30 years. There

is also a strong student chapter of ANS at the University of Nevada, Las Vegas. Technical

presentations suited to the general public have been made all during this time and will continue

into the future. Support from the National ANS hierarchy would greatly help promote and

expand this program. The student section of ANS – Nevada has presented a Nuclear Science

Merit Badge workshop for both Boy and Girl Scouts for more than 12 years. This program has

been very successful in getting the word out to future citizens as well as their parents

(http://www.ans.org/pi/edu/).

3. The National Defense Industrial Association (NDIA), Southern Nevada Chapter (NDIA/SNV) -

Although organized about one year ago, this section has reached to the top levels of the DoD

through the local Nellis AFB and Creech AFB leadership. The issue of primary concern in the

local area is assured power for Creech AFB. The president of NDIA (Retired General Hawk

Carlisle) has been to Nevada to emphasize the importance of assured energy to the group and

to discuss its implications all the way to the Secretary of Defense. Leaders at Creech AFB have

been involved in planning to become a prototype site for a Small Modular Reactor (SMR) for

their assured energy program. NDIA/NV has inspired these discussions and has organized

technical meetings in support of this program. Website: https://ndia-snv.org/.

Virginia Program Office for Spent Nuclear Fuel (SNF) Disposition

Project Plan (Basics)

Page 3 of 4

4. Virginia Recycles SNF (https://virginia-recycles-SNF/ – Formed in July 2019, VRSNF has

established a web site, developed education programs for the public, and has personally briefed

one US Representative on the idea to expand Virginia’s space in the energy industry by recycling

spent nuclear fuel to provide new fuel for the future nuclear industry.

Since Harry Reid (D-NV, former Senate majority leader) has left the Senate, however, there has been

renewed interest within the Silver State to explore the benefits. Through the efforts of the NDIA/NV

leadership, a coalition of business and political leaders in southern Nevada have been focused on

turning around the opposition in favor of securing a solid future in Nevada related to development of

nuclear energy based on spent nuclear fuel coming to Nevada. While the current cadre of Congressional

delegates from Nevada are publically vocal in their disagreement with “dumping” spent nuclear fuel in

Nevada, there is an attitude, through their offices, to resist understanding the basics of this potential

industry. Virginia is certainly one of the states that stands to benefit by realizing this opportunity and

becoming the first “consent site to accept SNF”.

If proposed to the President and the Secretary in the proper way, the following requests would be

eagerly accepted for Virginia to become the first “consent state” to accept spent nuclear fuel (this is a

minimum of $5 billion per year in new high-tech business and 15,000 jobs with no investment needed

by the State of Virginia). The following is a list of recommended benefits Virginia could demand and

receive in return for accepting SNF for disposition:

1. No permanent (deep geological repository) storage of spent nuclear fuel - This stance appeals

to the media and many citizens (i.e. “No nuclear waste dump”).

2. Recycle spent nuclear fuel vs. permanent storage in a repository - This is not now the position

of the US Government, but, since it is cost effective in comparison to a permanent repository

(initial costs = $25 billion vs. $200 billion) and would offer high-tech jobs beneficial to the entire

State, but especially to the local area in which the Center would be located.

3. Applied Engineering for Next-Generation Reactor Technical Transfer - As part of the effort in

recycling spent nuclear fuel, the development of next generation (Small Modular Reactors

(SMR)) for research on the required new fuel forms, next-generation designs, electricity delivery

innovations, and DoD development of assured power sources based on SMR would be included

in the requested benefits. Industry/Government partnerships could take advantage of the

opportunity to locate an “Industrial Park” adjacent to the recycling center.

4. Development of a National Center for University Programs for Next-Generation Reactors -

Virginia universities have impressive nuclear engineering and physics, which grant advanced

degrees and are working with national laboratories and industry on next-generation reactor,

nonproliferation techniques, and emergency response programs. Part of the effort in the

program office would be to inspire these university programs to better integrate with Federal

Agencies, nuclear companies, and the American Nuclear Society to focus their efforts on next-

generation nuclear in Virginia.

5. Carbon-Free Energy National Laboratory (CAFE) - The Commonwealth of Virginia has

emphasized renewable energy as its focus for accomplishing clean-energy goals. If nuclear

energy is included in the clean energy portfolio, the synergies between renewable (solar, wind,

geothermal) and sustainable (nuclear) can be explored in an atmosphere of total focus on a

Virginia Program Office for Spent Nuclear Fuel (SNF) Disposition

Project Plan (Basics)

Page 4 of 4

carbon-free energy program based in applied engineering and research in an atmosphere of

public/private partnership.

6. DoD Assured Energy Development - Virginia has a rich history with DoD missions, especially the

Nuclear Navy. As such, it is the perfect place to expand the DoD use of nuclear reactors by

introducing prototype SMR power systems for use on military bases and for mobile, tactical

applications. This process is already embraced by the NDIA and has been advanced to the levels

of the Secretaries of the Air Force and Army as well as the Secretary of Defense. Talks are

already on-going between the DoD Strategic Capabilities Office (SCO) and DOE-Nuclear Energy.

The NDIA Assured Energy Division was instituted by NDIA and is a supported division within

NDIA.

7. Micro-Grid Applications Research - DoD has already embraced the “islanding” of energy supply

for both its strategic and tactical assets. The issues of EMP and vulnerability of the national

electric grid can be reduced by migrating to a “micro-grid” energy supply posture. SMRs are the

ideal energy sources for this effort based on their compact energy configuration and their

protection from EMP since they will be employed in underground, shielded configurations. They

will be designed to support the national grid, provide assured energy to civilian and military

communities, allow for mobile power supply in emergencies and supply power exclusive of the

national electric grid during times of grid failure.

Virginia is openly seeking economic diversity and supports an impressive pro-nuclear professional cadre.

The capability to improve the K-12 education posture through community-based as well as Government-

funded programs, and has shown that it seeks to improve the economic posture of its rural counties.

With an enhanced education program regarding the possibilities of nuclear industry and a greater

presence from the nuclear industry, American Nuclear Society (ANS) professional organization and pro-

nuclear environmental organizations, Virginia could advance its excellent rapport with the public for

such a beneficial program. Public relations messages, both in media and in person, could quickly inform

the citizens to the vast opportunity and extremely low risk. The timing has never been better for a

modest investment from the nuclear energy and pro-nuclear environmental community to secure the

agreement of the Commonwealth of Virginia to proceed with spent fuel initial storage leading to

recycling of spent nuclear fuel and the possibilities inherent in their taking national leadership in the

carbon-free energy goals established in most of the United States.

Steven Curtis Tom Dolan

Program Manager Operations Manager

Past President of the ANS – Nevada Section

Current Member of ANS, National

Steve@Virginia-Recycles-SNF.com Tom@Virginia-Recycles-SNF.com

Scurtis261@gmail.com thomasedolan@gmail.com

+1 (702) 219-6463 Cell +1 (613) 495-2947 Cell

Virginia Program Office for Recycling & Disposition of

Spent Nuclear Fuel

The Crucial Next Steps to Recycle Spent Nuclear Fuel that is Needed to Advance Nuclear Energy Business in Virginia

The timing has never been better for a modest investment from the nuclear energy and pro-nuclear environmental community to secure the agreement of the Commonwealth of Virginia to proceed with spent fuel initial storage leading to recycling of spent nuclear fuel and the possibilities inherent in their taking national leadership in the carbon-free energy goals established in most of the United States.

However, other states are beginning to revisit this, and the first to consent will

ultimately grab the prize and gain a leadership role on Nuclear Energy.

Next Steps Needed:

1) Establish a Program Office for Spent Nuclear Fuel Recycling & Disposition.

2) Enact the detailed program plan for Virginia Nuclear based on the paper "Program Plan for Virginia Nuclear"

3) Need to have all Virginia Congressional Delegation and Governor make Virginia

the First Lead State in the Union to “Consent” to accepting SNF to Recycle.

4) Request Virginia Nuclear Energy Consortium Authority to be our Premiere Sponsor for an ANS Booth we will have at the upcoming American Nuclear Society’s Winter National Meeting & Expo in Washington DC on November 17th through 21st.

The United States, namely Virginia must make the missing puzzle piece of

“Recycling Spent Nuclear Fuel (SNF)” central to its program if any other state in the union or country in the world will ever regard the United States

or Virginia as a National or Global Leader in Nuclear Energy.

www.Virginia-Recycles-SNF.com

2019Exhibitor and Sponsorship Prospectus

November 17-21, 2019

Washington DC

Marriott Wardman Park

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of Winter Meeting & Expo attendees

make or influence buying decisions

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17'

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Virginia Program Office for Recycling & Disposition of

Spent Nuclear Fuel Proposal

The following eleven pages contain letters from Global Stake Holders involved in Nuclear Business

who are certainly ready to compete for Virginia’s Business upon moving forward with

Recycling of Spent Nuclear Fuel

HITACHIGE Hitochi Nucleor Energy

Jerold G. HeodSenior Vice PresidentRegulotory Affoirs

3901 Costle HoYne RoodP.O. Box 780Wilmington, NC 28402USA

T 910-819-5692F 910-341-2797Jerold.Heod@ge.com

MFN 11-L35Morch 24,2OI1.

U.S. Nucleor Regulotory CommissionMr. Lowrence Kokojko, Director of High LevelWoste Repository Sofety

1-1-555 Rockville Pike

Rockville, MD 20852

Deor Mr. Kokojko:

I om writing to express the continuing commitment of Generol Electric-Hitochi (GEH)to developing ourpower Reoctor lnnovotive Smoll Modulor (PRISM)/Advonced Recycling Center (ARC)technoloqy. This US

developed technology solves three domestic energy issues not currently oddressed with conventionol

nucleor technology. First, it recycles spent nucleor fuel ond reduces long-lived rodiooctive moteriol.

Second, it supports energy security by vostly increosing the energy thot con be extrocted from our

uronium resources. Third, it provides on option for o more cost-effective method of disposing ofweopons plutonium. These benefits ore in oddition to the low corbon benefits of nucleor electricityproduction.

A key octivity to enobling introduction of this technology is the creotion ond opplicotion of supportingregulotions. Therefore we ore strongly supportive of the recycling rulemoking process. We ore olso in

support of o licensing bosis thot is truly technology neutrol ond does not disodvontoge US developed

technology.

Recycling rulemoking will ollow GEH to prooctively porticipote in the NRC regulotory process. lt will

ollow us to understond the process by which our technology will be reviewed ond contribute ourtechnicol expertise to o broodly opplicoble opprooch.

We understond thot the NRC hos committed resources to the preliminory rulemoking process ondreolize this hos been o chollenge given the mony priorities of the commission. We olso reolize thotthere ore other circumstonces thot, ot ony given time, con determine the direction by which resources

ore ollocoted throughout the NRC. But note thot our industry is committed to the recycling process os

evident by the continued investment in.the mony different technologies.

M€N 11'135GE Hnad bdear E.4y

March 24,2011Page2

Continued progress ond o definitive dote for o Finol Rule on the licensing of o recycling focility is o

mojor step forword, ond GEH stonds reody to work with you ond your stoff in onswering ony questions

o, ih" rulemoking process unfolds. In porticulor, we welcome the opportunity to better exploin our

recycling method in more detoilto support the necessity of moking o Finol Rule thot is technology

neutrol.

The Nucleor Energy lnstitute (NEl) hos publicly supported o technology neutrol rulemoking on beholf of

the recycling industry. lt is our hope thot the NRC will consider the industry position while developing

this importont rule.

GEH is committed ot the highest levels of our compony to seeing the recycling rulemoking process

through.

Thonk you for your leodership on this importont issue.

Sincerely,

,a z/"-z-Jerold G. HeodSenior Vice PresidentRegulotory Affoirs

MFN 11'135cE-Hilad Nudoer EreQy

From: BADER Sven (AREVA)To: Faraz, YawarCc: Guttmann, Jack; Matula, Thomas; DAVIDSON Dorothy (AREVA); JONES David (AREVA); MURRAY Paul

(AREVA); SALAS Pedro (AREVA); LEVIN Alan (AREVA); LUCAS Matthieu (AREVA); BAILLY Frederic (AREVA);PRUD HOMME Pascal (AREVA)

Subject: RE: Request for input for Commission paper on reprocessingDate: Tuesday, October 23, 2012 5:32:25 PM

Yawar,  You may publicly release the below text. Sven   NRC:As you may have heard,  an AREVA-led team recently was selected by the Eddy Lea Energy Alliance(ELEA) as their commercial partner to begin developing the concept of a Used Nuclear Fuel (UNF)Consolidated Storage Facility (CSF) in southeastern New Mexico.  AREVA has spoken to othercommunities that may come forward in the future to offer hosting a CSF, but what our agreementwith ELEA ultimately indicates is AREVA’s belief that consolidated interim storage of UNF (asrecommend by the Blue Ribbon Commission on America’s Nuclear Future) will be an importantfirst step in moving towards a resolution of issues associated with the back-end of the nuclear fuelcycle in the U.S.  However, a CSF by itself does not accomplish an end goal (e.g., WasteConfidence).  If a CSF were combined with recycling and ultimately with a repository, then there isan assurance to any State and local community willing to “consent” to host a CSF that the CSF willnot become a de facto repository for UNF.  So why does AREVA include recycling in this scheme?Because AREVA sees many common elements between a CSF and a recycling facility (e.g., a receiptfacility for UNF, a temporary storage location for UNF, and potentially dry and/or wet UNF transferareas and an R&D facility) and AREVA believes that a recycling facility would also provide multiplebenefits to a repository (e.g., providing a stable waste form ready for disposal in most media andreducing the ultimate volume of waste requiring disposal).  Furthermore, AREVA believes (unlessYucca Mountain is restarted) that the horizon for a repository in the U.S. (based on historicalevidence) is likely much further out than that for a recycling facility. Hence a recycling facility couldincentivize the nearer term movement towards a back-end solution through the added benefits ofproviding a local community willing to host such a facility significant economic development andjob creation (well beyond those associated with just a CSF), while waiting for the siting studies,selection process, licensing process, and design and building processes of a repository to mature. These are only a few reasons why AREVA supports recycling and we would welcome theopportunity to share others with you. AREVA’s plan is to submit a license application for a recycling facility in 2019. To meet this date,AREVA will require rulemaking for a recycling/reprocessing facility to be completed in the 2017 toearly 2018 timeframe.  AREVA remains committed to supporting the NRC recycling rulemakingactivities, which we believe have shown significant progress over the last year (with the release ofthe draft Regulatory Basis, the responding SRM from the Commissioners, and the recent release ofthe ETR). AREVA understands the constraints the NRC is under (considering budget limitations and

issues associated with Waste Confidence and lessons learned from Fukushima), but we believe theprogress shown to date, even with the limited resources available to the Staff, does showmeaningful progress towards a final rule and AREVA supports the NRC’s continued effort towardscompleting this rulemaking activity. Please do not hesitate to contact me for further elaboration on this matter or, if you would like,AREVA could meet with you to discuss this topic further.  We hope that the NRC continues its efforton this rulemaking activity and thank you for your continued progress on this activity. Sincerely,Sven  Sven Bader, PhD, PEAdvisory Engineer7207 IBM Drive, CLT-1DCharlotte, NC 28262AREVA Federal Services LLCAn AREVA Company704-805-2809 (W)434-382-5412 (FAX)704-643-7086 (H)704-968-4731 (C)

From: McCULLUM, RodneyTo: Faraz, YawarCc: Guttmann, Jack; Kokajko, Lawrence; Matula, ThomasSubject: RE: Request for insights on industry plans regarding reprocessingDate: Wednesday, November 07, 2012 8:31:48 AM

Yawar As I mentioned to Jack when I saw him yesterday, NEI is fully supportive of our member companies’efforts in this area.  As such, we are relying primarily on the responses of GEH and Areva to guidestaff’s response to the Commission’s questions.  The one thing I can add from an NEI perspective is that there is broad industry support for theposition that the option to reprocess should be maintained regardless of whether or not it is beingactively pursued at this time.  We believe that completing the proposed reprocessing rulemaking ina timely manner is important in this context because the regulatory framework for reprocessing isa significant factor that must be considered in making business decisions about whether or not tomove forward.  Hence, for reprocessing to truly be available as an option, the regulatoryframework must first be established.  For this reason, we encourage NRC to move forward with thereprocessing rulemaking on a schedule that supports effective decision-making in advance of thetimelines envisioned the responses you received from Areva and GEH. Thanx,  Rod McCullum Nuclear Energy Institute1776 I Street NW, Suite 400Washington, DC 20006www.nei.org P: 202-739-8082F: 202-533-0166M: 202-262-4645E: rxm@nei.org nuclear. clean air energy. From: Faraz, Yawar [mailto:Yawar.Faraz@nrc.gov] Sent: Wednesday, October 17, 2012 5:05 PMTo: McCULLUM, RodneyCc: Guttmann, Jack; Kokajko, Lawrence; Matula, ThomasSubject: Request for insights on industry plans regarding reprocessing Rod, As you know on August 30, 2012, the Commission provided us the attached StaffRequirements Memo concerning reprocessing. They asked us to provide them a notation

vote paper with answers to a number of questions including the “…staff’s assessment ofthe current state of activity and…industry plans regarding reprocessing...” Your insightsregarding this question as it pertains to NEI’s role in representing industry on reprocessingby the end of this month would be greatly appreciated. Please note that I had sent similarrequests earlier this month to Sven Bader of AREVA and James Ross of GEH. GEHresponded today. I anticipate AREVA will be responding soon. Please feel free to call meif you have any questions. Thank you Yawar FarazSr. Project ManagerDivision of Spent Fuel Alternative StrategiesOffice of Nuclear Material Safety and SafeguardsU.S. Nuclear Regulatory CommissionWashington DC 20555Ph: 301-492-3207Fax: 301-492-3359

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EnergySolutions’ Statement to the Nuclear Regulatory Commission on Reprocessing

and the Disposition of Used Nuclear Fuel

EnergySolutions has the experience and capabilities to handle, store, reprocess and dispose of used nuclear fuel (UNF). We are very keen to continue to take an active part in the Blue Ribbon Commission’s (BRC) recommended path forward, including the setting up of one or more Consolidated Storage Facilities for UNF in the USA, and also the pursuit of UNF reprocessing.

We are currently contracted with DOE to carry out several studies related to the BRC recommendations, including producing design concepts for one or two CSFs, and the development of standardized transportation, aging and disposal canisters for UNF. We strongly support the setting up of one or more CSFs in the USA and the progressive movement of UNF from the shutdown and operating reactor sites to these CSFs. Our CSF design concepts study first looked at UNF transportation issues from both shutdown and operational sites, the need for repackaging some UNF prior to transport, the difficulties with transport access to certain shutdown sites, the lead time to acquire suitable cask and railroad cars, and the licensing requirements for all equipment and transport methods. It went on to identify, cost and compare 6 options, covering one or two CSFs, differing UNF receipt rates, UNF pickup orders, operational start dates and geological repository operational dates. These scenarios were illustrative only at this stage but the model we developed enables all possible options to be compared and provides the basis for production of a full conceptual design.

EnergySolutions supports the reprocessing of UNF in the USA because it (i) minimizes the volume of high level waste (HLW) that ultimately will require geologic disposal, (ii) provides a vitrified HL Waste form that is more robust than irradiated nuclear fuel assemblies that were not originally designed for long term storage, and (iii) enables the removal from the HLW of long-lived heat emitting transuranics such as americium so that these can be separately destroyed. During the Global Nuclear Energy Partnership (GNEP) period we produced a conceptual design, technology roadmap and business plan for a UNF reprocessing facility capable of reprocessing 1500 MT of UNF per year and future expansion up to 3000 MT/year. During that period we actively engaged with the NRC on its gap analysis of the regulatory framework for analyzing a reprocessing facility. We support the continuation of that process and ultimately a rulemaking for the creation of a Part 7X. At the end of the GNEP period our conceptual design provided all that was required for an immediate move into the detailed design process.

We believe there are significant synergies between a CSF and a reprocessing facility. Each requires a receipt facility and temporary storage for the UNF, a hot cell or pool facility for the removal of UNF from canisters so that it can be reprocessed or re-packaged for repository storage, and an R&D facility. Establishing a CSF and a reprocessing plant on the same site would allow economies to be realized by the common use of these facilities. Such a combined site would also potentially be more attractive than a standalone CSF to a prospective host community because of the much larger range of high quality jobs that it would offer. This could help the identification of volunteer communities for such a site, as recommended by the BRC. EnergySolutions is actively engaged with potential host communities for a CSF and we believe that the CSF will ultimately be tied to a Reprocessing Plant, an R&D facility and, potentially also the Geologic Repository. Chris Phillips January 10, 2013