The 3 Yankee Company ISFSIs

The 3 Yankee Company ISFSIs

3 Yankee Companies Update and Perspective on SNF Issue NEHLRW Transportation Taskforce Meeting November 3, 2016, Atlantic City, NJ Eric Howes, Director Public & Government Affairs, Maine Yankee The 3 Yankee Company ISFSIs Connecticut Yankee Maine Yankee 15 Spent Fuel Dry Casks 1 GTCC Dry Cask

NAC canister system 40 Spent Fuel Dry Casks 3 GTCC Dry Casks NAC canister system Yankee Rowe 60 Spent Fuel Dry Casks 4 GTCC Dry Casks NAC canister system 2

ISFSI Only Sites For More Than 10 Years MY, CY, & YR single unit sites shutdown in the 90s; all SNF & GTCC moved to stand-alone ISFSIs by 2005; NAC canisters licensed for Storage & Transport Courts have awarded the three companies about $470m in damages through 2012 resulting from the govts failure to fulfill its contractual obligations to remove the SNF & GTCC waste from the sites. When DOE fulfills its contractual obligations the ISFSIs will be decommissioned, NRC licenses terminated, companies will go out of business, properties will be available for other uses. 3

ISFSI Only Sites For More Than 10 Years Until then, as NRC licensees, the three companies are required to stay in business and are responsible for storing the SNF & GTCC waste in accordance with all regulatory requirements at an average cost per company of about $10 m/year. When DOE begins meeting its obligation equipment will have to be mobilized to transfer SNF & GTCC canisters to transportation casks (which DOE has yet to procure). Rail, barge and truck were used during decommissioning to ship large radioactive components from the 3 Yankee sites. 4 Large Radioactive Components Shipped During Decommissioning

5 Pilot CIS Project for Shutdown Reactor SNF The 3 Yankee Companies continue to advocate for priority removal of SNF from permanently shutdown sites without a reactor to a pilot Consolidated Interim Storage facility in a volunteer host community. This concept has bipartisan support and is embodied in: The 2012 BRC report; DOEs 2013 strategy as the first milestone; The Nuclear Waste Administration Act of 2015; The FY 17 Senate E&W Appropriations bill; and The Interim Consolidated Storage Act of 2015 introduced in the House. For example the Senate E&W Appropriations bill included language directing $10 million in funds from the DOEs Office of Nuclear Energy

in order for the DOE to be able to contract with private parties for the management of spent fuel that DOE holds title to or has a contract to accept title to. Bill passed the Senate 90-8. 6 Pilot CIS Project for Shutdown Reactor SNF Secretary Moniz testified 9/14/16 before the Senate E&W Approps subcommittee that DOE believes it has the authority to engage with private facilities to store commercial spent fuel, but congressional authorization is important for the applicants confidence. He also said he is supportive of private initiatives and that DOE could make progress especially on contracting with private facilities and transportation as part of an integrated waste management strategy . In remarks to the Center for Strategic and International Studies on 10/24/16

Secretary Moniz urged Congress to authorize CIS. The 10/27/16 Request for Information on how DOE might engage with private CIS initiatives (PIs) as part of an integrated spent fuel management program states, PIs represent a potentially promising alternative that can be used either solely or in addition to federal facilities. We agree. 7 Private CIS Proposals, TX and NM Texas Proposal: Waste Control Specialists submitted a license application for a proposed CIS facility to the NRC in April 2016. WCS has indicated their facility, an expansion of their current LLW facility, could be complete as early as 2021. WCS partners in the project are Areva & NAC. NRC is reviewing the LA and WCS is responding to NRC requests for supplemental information. In addition NRC plans to begin the Environmental Impact Statement process for the WCS project now before the

application is formally docketed. WCS is not seeking federal funds to build the facility, but plans to enter into an agreement whereby DOE would take title to the SNF, pay WCS to store the fuel and remain ultimately liable for the waste. WCS would initially receive SNF from shutdown reactor sites. Along with other expressions of local and state support, on January 20, 2015, the Andrews County Commissioners Court unanimously adopted a resolution of support for the WCS project. For more information go to wcsstorage.com. 8 Private CIS Proposals, TX and NM New Mexico Proposal: In April 2015, Holtec International and the Eddy-Lea Energy Alliance announced plans to site a CIS facility about 12 miles from the

Carlsbad WIPP facility. Holtec officials indicate the company expects to submit a license application to the NRC in March 2017 and have met with NRC for preapplication meetings. The proposed NM CIS facility also hopes to be operational in the 2021 timeframe and would initially receive SNF from shutdown sites. NM Governor Susana Martinez in April 2015 sent a letter to Energy Secretary Moniz as a preliminary endorsement of the proposal. This spring the New Mexico Legislature approved a resolution Requesting the Eddy-Lea Energy Alliance to develop a consolidated interim storage facility. For more information go to: http://www.holtecinternational.com/2015/04/holtec-partners-with-elea-llc-innew-mexico-to-build-consolidated-interim-storage-facility/ 9 Response: DOEs Invitation to Comment on Designing a Consent-Based Siting Process

The 3 Yankee Companies responded in July 2016 as members of the Decommissioning Plant Coalition and the Nuclear Waste Strategy Coalition to DOEs invitation to comment on the design of a Consent-based siting process for nuclear waste storage & disposal facilities noting in the DPC comments regarding private CISF proposals in TX and NM that: Before either of these proposed facilities were announced, steps were taken to engage with stakeholders and solicit preliminary support from local and state authorities for their efforts. We would encourage the Department to expeditiously take full advantage of the potential opportunities afforded by these two ventures, as we expect either facility could be capable of offering services to the federal government before a federal facility, interim or permanent, could be readied to accept used nuclear fuel from our member sites. 10

Response: DOEs Invitation to Comment on Designing a Consent-Based Siting Process Nuclear Waste Strategy Coalition comments noted in part that: We supportthe timely preparation of the nations transportation infrastructure needed to support both consolidated storage and a repository program, including DOE certification and procurement of rail cars and licensed transportation casks and components; increased funding for state and tribal transportation preparation and related activities; and DOEs engagement with potential waste site host communities. 11

Response: DOEs Invitation to Comment on Designing a Consent-Based Siting Process Congress and the Administration should facilitate consolidated interim storage as a way for the federal government to begin meeting its obligations, particularly removal of used fuel stranded at sites without an operating reactor. We are encouraged by the private consolidated interim storage initiatives. We urge Congress to fund the completion of the license application review and urge DOE to support the license application it submitted in 2008. We support reforms that would ensure timely access to the NWF for its intended purpose. 12

SNF 115th Congress: Opportunity for Progress At the end of Sept. Congress passed a CR to fund the govt to 12/9/16. Congress returns 11/14 for a 4 week lame-duck session. The long standing policy stalemate on the SNF issue continued this year with some positive developments such as WCS filing its LA, Secretary Moniz stating he has authority to move ahead with private CIS, DOE highlighting Consent-based siting, bipartisan support in the House for the two CIS bills introduced this session, and bipartisan support in the Senate for CIS legislation. At the same time there is strong support, especially in the House, for continuing the YM LA process. (YMs strongest opponent Senator Harry Reid is retiring but YMs strongest supporter Rep. John Shimkus continues as a key player.) The 115th Congress and a New Administration present an opportunity for progress to reform the SNF program. Whether that happens only time will tell.

13 14

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