Betsy Madru VP Government Affairs Update on WCS’ Plans for Consolidated Interim Storage of Used Nuclear Fuel

Administration Buildings and WCS Current Facilities Byproduct Facility Compact Facility Federal Facility LSA Pad Hazardous Waste Landfill Byproduct Facility Administration Buildings and Treatment Facility Hazardous Waste Landfill Treatment Facilities Federal Facility Compact Facility

Disposal and Service Capabilities WCS provides the most comprehensive, full service, and complete Radioactive and Hazardous Waste Services in the Nation. Commercial Waste In- and Out-of-Compact Class A, B, and C LLRW Federal Waste Federal Class A, B, and C LLRW and MLLRW Accepts LLRW up to 10% of the Class A limit in RCRA/TSCA landfill Low Activity 3 state-of-the-art Type B Casks 2 Type A Casks Transportation Processing Dewatering, Sorting, Stabilization, Repackaging, etc. Storage GTCC, TRU, Sealed Sources, MLLRW WIPP Program

Compact Waste Facility

Federal Waste Facility

Comparison of LLW Disposal Designs

WCS Landfill Design Andrews, TX Multi-layered cover system up to 45 feet thick Depth to waste at least 25 feet below surface 9 ft. liner system on top of red bed clay which is less permeable to water than concrete and 600 feet thick Closest measurable water 225 feet

Compact Disposal Facility WCS CWF – Native Clay Compact Disposal Facility

CWF During Construction

(Previous Industry Standard for Class A) Clive, UT Site (Previous Industry Standard for Class A) Class A waste disposed in lifts, and down blended Class B waste disposed in non-reinforced concrete culverts and covered in sand

Barnwell Facility (Previous Industry Standard for Class B/C)

WCS Compact Facility (New Industry Standard)

CIS – Project Scope Environmental impacts will be analyzed with storage of 40,000 MTHM for 40 years 8 separate phases; storage of up to 5,000 MTHM in each phase Initial SAR will include selected AREVA NUHOMS® and NAC International storage systems which will prioritize shutdown sites Additional systems and sites to be added in future License Amendments Storage of used fuel from over 10 shutdown/decommissioned nuclear power plants will fit in Phase 1 Allows flexibility to transition beyond storage of fuel from currently decommissioned reactors License for 40 years with multiple renewals of up to 20 years each Ongoing discussions with DOE and the U.S. Congress on how to integrate the availability of an interim storage facility into the national strategy for used nuclear fuel management

Timeline February 2015 – filed the notice of intent Currently – meetings with interested parties and legislative members April 2016 – file license application June 2019 – NRC issues license Assumes a three year review period September 2019 – Construction begins December 2020 – Operations begin

License Application WCS has the lead role in preparing the license application, with support from AREVA and NAC License application for Private Fuel Storage (PFS) that was approved by the NRC provides a template A Safety Analysis Report for the DOE following the NRC Standard Review Plan (NUREG-1567) for a generic CISF has already been prepared by AREVA SAR will be prepared for selected AREVA NUHOMS® and NAC systems To ensure lowest cost/risk/schedule duration in the licensing process, the initial SAR will only include systems that: Are currently licensed and in service Are deployed or will be deployed at shutdown reactor sites Additional systems to be added in future license amendments

Initial License Application Priority on currently licensed systems for shutdown sites: NAC International Maine Yankee Connecticut Yankee Yankee Rowe La Crosse Zion AREVA NUHOMS® Rancho Seco SONGS Unit 1 Millstone Unit 1 Oyster Creek* (S/D scheduled 2019) Indicates a “stranded” (ISFSI only) site identified in the 2012 Final Report of the “Blue Ribbon Commission on America’s Nuclear Future” (BRC) * Fuel Burned less than 45 GWd/MTU Initial License Application will cover ~80% of UNF and GTCC at BRC “Stranded” Site

Consolidated Interim Storage: Industry Benefits Availability of a permanent geological repository is projected to take decades and faces significant local and state acceptance challenges Availability of consolidated storage facility offers flexibility for DOE to take title to and efficiently manage UNF Successful demonstration of transportation, licensing, and public consent processes will increase public confidence in the nuclear industry Public is concerned over “stranded” UNF at decommissioned sites Polls show the unresolved UNF management issue remains a vulnerability for the nuclear industry CIS acts a “surge capacity” within the U.S. UNF management system; enables more efficient and effective UNF management in the near-term and will allow DOE to meet its obligations to take title to and remove fuel from shutdown and operating reactor sites while the decades long process of developing a repository works itself out. WCS CISF Project Provides a Way Forward to Deliver a Near-Term, Economically Viable Option for Consolidated Interim Used Fuel Management while a Permanent Disposal Solution Continues to be Developed

Proposed CISF Site Overview 18

Aerial Photo of LLRW Facilities Expansion of an Existing Radioactive Waste Facility – Not a “Greenfield” Site Aerial Photo of LLRW Facilities Site includes ~14,000 acres (~23 square miles) Includes Compact LLW, Federal LLW, and RCRA Landfills and Storage and Processing Facility for LLW Licensed by Texas as an Agreement State Rail access, irradiated hardware, large components, and large scale D&D project services currently provided

Location of CISF CISF will occupy ~320 acres or only 2.3% of the 14,000 acre site 20

Pad Layout for CISF

View of Deployed Systems for Phase 1 Pad

WCS has Proven Programs and Infrastructure for Managing Radioactive Materials WCS currently operates the most robust LLW disposal facility in the U.S. LLW is put into Modular Concrete Canisters, grouted and then placed into the landfill Operations include irradiated hardware with receipts as high as 20,000 rem/hr on contact, but a collective dose of only 50 mrem for disposal Radiation safety, environmental monitoring, security and other functions are ongoing

Compact Waste Facility

Thorough Environmental Characterization Environmental Impacts have been extensively analyzed in the region NRC prepared an EIS for URENCO USA TCEQ conducted ER supporting issuance of LLW and Storage licenses WCS approach allows addition of new storage systems as amendments, but ensures cumulative environmental impacts are analyzed

Strong Local and State Support WCS initiated discussions with Andrews County, Texas for support to site the CISF WCS underscored it would proceed only with the support of the local community Andrews County resolution endorsing the project passed unanimously on January 20, 2015 Texas Radiation Advisory Board issued a Sept. 2014 position paper strongly recommending Texas position to itself to host the first CISF in the U.S. Enthusiastic support from Texas’ U.S. House and Senate delegation and the Governor’s office PFS showed that broad consent (i.e., state level and not just local level support) is critical for project success

Blue Ribbon Solution The Blue Ribbon Commission’s report in 2012 recommended a consent-based CISF Allows the federal government (DOE) to take title to UNF and remove it from nuclear power plants (“stranded” fuel at shut-down plants should be a priority) WCS proposed CISF is an “outside the beltway” idea that requires no federal funding to start

Drives Progress Toward a Permanent Repository Solution The WCS CISF does not compete against a permanent repository Over 70,000 MTHM generated to date WCS CISF only licensing 40,000 MTHM Still need a permanent solution for the industry Allows transportation system to be developed and demonstrated Easier to prepare fuel for final repository disposal at an active CISF instead of at a shutdown reactor site CIS is a Complement to rather than a Competitor against Permanent Geological Disposal

WCS Offers Most Realistic and Cost-Effective Solution Straightforward approach of only including already licensed and deployed systems in the initial License Application greatly reduces cost & risk of licensing Expansion of an existing radioactive waste facility (vs. a “greenfield” site) greatly reduces cost & risk of licensing, development and construction Consolidation of multiple “stranded” ISFSIs into one CISF will save licensing, aging management, and security costs and allow for re-use of decommissioned reactor sites Federal expenditures for transportation and storage will result in progress instead of just studies Opportunity to reduce taxpayer liabilities and payments owed from DOE’s partial breach of contracts with UNF title-holders

What Does WCS Need? Legislation enabling the DOE to take title to UNF and utilize portions of the Nuclear Waste Fund to pay for interim storage services WCS is willing to start the licensing process with no federal funding, but will need certainty of funding for construction and operation Industry support for development of interim storage capability and supporting transportation infrastructure Engage in development of supportive industry policy positions (NEI) Engage Congressional stakeholders to advance meaningful UNF management policy and enable opportunities for private storage solutions DOE initiative on transportation of used fuel required to facilitate storage commencing in December 2020

Summary WCS project is consistent with the BRC’s recommendations regarding need for consolidated interim storage and consent-based licensing WCS, AREVA, and NAC have the qualifications and capabilities to license, construct, and operate the facility License Application to be submitted by April 2016 will cover ~80% of UNF and GTCC at BRC “Stranded” Sites Site is environmentally well-characterized, enjoys broad local, state level and congressional support, and already has robust infrastructure that supports operating LLW facilities A complement to and not a competitor against a permanent geological repository See the website www.WCSstorage.com for updates