Virginia Program Office for Recycling & Disposition of Spent - - PDF document

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

• pening 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

• rganization 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

• ne 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
• f 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

• pportunity 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
• f 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

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

www.Virginia-Recycles-SNF.com

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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

HITACHI

GE Hitochi Nucleor Energy Jerold G. Heod

Senior Vice President Regulotory Affoirs 3901 Costle HoYne Rood

P.O. Box 780

Wilmington, NC 28402

USA T 910-819-5692 F 910-341-2797

Jerold.Heod@ge.com

MFN 11-L35 Morch 24,2OI1.

U.S. Nucleor Regulotory Commission

• Mr. 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 our

power 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 of weopons plutonium. These benefits ore in oddition to the low corbon benefits of nucleor electricity production. A key octivity to enobling introduction of this technology is the creotion ond opplicotion of supporting

• regulotions. 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

• llow us to understond the process by which our technology will be reviewed ond contribute our

technicol expertise to o broodly opplicoble opprooch. We understond thot the NRC hos committed resources to the preliminory rulemoking process ond

reolize this hos been o chollenge given the mony priorities of the commission. We olso reolize thot

there ore other circumstonces thot, ot ony given time, con determine the direction by which resources

• re 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 11'135 GE Hnad bdear E.4y

March 24,2011

Page2

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

• , 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. Heod Senior Vice President Regulotory Affoirs

cE-Hilad Nudoer EreQy

From: BADER Sven (AREVA) To: Faraz, Yawar Cc: 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 reprocessing Date: 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 other communities that may come forward in the future to offer hosting a CSF, but what our agreement with ELEA ultimately indicates is AREVA’s belief that consolidated interim storage of UNF (as recommend by the Blue Ribbon Commission on America’s Nuclear Future) will be an important first step in moving towards a resolution of issues associated with the back-end of the nuclear fuel cycle in the U.S. However, a CSF by itself does not accomplish an end goal (e.g., Waste Confidence). If a CSF were combined with recycling and ultimately with a repository, then there is an assurance to any State and local community willing to “consent” to host a CSF that the CSF will not 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 receipt facility for UNF, a temporary storage location for UNF, and potentially dry and/or wet UNF transfer areas and an R&D facility) and AREVA believes that a recycling facility would also provide multiple benefits to a repository (e.g., providing a stable waste form ready for disposal in most media and reducing the ultimate volume of waste requiring disposal). Furthermore, AREVA believes (unless Yucca Mountain is restarted) that the horizon for a repository in the U.S. (based on historical evidence) is likely much further out than that for a recycling facility. Hence a recycling facility could incentivize the nearer term movement towards a back-end solution through the added benefits of providing a local community willing to host such a facility significant economic development and job 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 the

• pportunity 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 to early 2018 timeframe. AREVA remains committed to supporting the NRC recycling rulemaking activities, which we believe have shown significant progress over the last year (with the release of the draft Regulatory Basis, the responding SRM from the Commissioners, and the recent release of the 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 the progress shown to date, even with the limited resources available to the Staff, does show meaningful progress towards a final rule and AREVA supports the NRC’s continued effort towards completing 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 effort

• n this rulemaking activity and thank you for your continued progress on this activity.

Sincerely, Sven

Sven Bader, PhD, PE Advisory Engineer 7207 IBM Drive, CLT-1D Charlotte, NC 28262 AREVA Federal Services LLC An AREVA Company 704-805-2809 (W) 434-382-5412 (FAX) 704-643-7086 (H) 704-968-4731 (C)

From: McCULLUM, Rodney To: Faraz, Yawar Cc: Guttmann, Jack; Kokajko, Lawrence; Matula, Thomas Subject: RE: Request for insights on industry plans regarding reprocessing Date: 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 guide staff’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 the position that the option to reprocess should be maintained regardless of whether or not it is being actively pursued at this time. We believe that completing the proposed reprocessing rulemaking in a timely manner is important in this context because the regulatory framework for reprocessing is a significant factor that must be considered in making business decisions about whether or not to move forward. Hence, for reprocessing to truly be available as an option, the regulatory framework must first be established. For this reason, we encourage NRC to move forward with the reprocessing rulemaking on a schedule that supports effective decision-making in advance of the timelines envisioned the responses you received from Areva and GEH. Thanx,

Rod McCullum Nuclear Energy Institute 1776 I Street NW, Suite 400 Washington, DC 20006 www.nei.org P: 202-739-8082 F: 202-533-0166 M: 202-262-4645 E: rxm@nei.org

• nuclear. clean air energy.

From: Faraz, Yawar [mailto:Yawar.Faraz@nrc.gov] Sent: Wednesday, October 17, 2012 5:05 PM To: McCULLUM, Rodney Cc: Guttmann, Jack; Kokajko, Lawrence; Matula, Thomas Subject: Request for insights on industry plans regarding reprocessing

Rod, As you know on August 30, 2012, the Commission provided us the attached Staff Requirements 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 of the current state of activity and…industry plans regarding reprocessing...” Your insights regarding this question as it pertains to NEI’s role in representing industry on reprocessing by the end of this month would be greatly appreciated. Please note that I had sent similar requests earlier this month to Sven Bader of AREVA and James Ross of GEH. GEH responded today. I anticipate AREVA will be responding soon. Please feel free to call me if you have any questions. Thank you Yawar Faraz

• Sr. Project Manager

Division of Spent Fuel Alternative Strategies Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington DC 20555 Ph: 301-492-3207 Fax: 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