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Several features of the NRC bill are key to meaningful licensing reform. These include standardized design, early site review, and authorization of a combined construction permit and operating license. Site and standardized design approvals should be valid for approximately 10 years, with renewals from 5 to 10 years at the discretion of the Commission. With respect to a combined construction permit and operating license, a second hearing prior to commencement of operation should be limited to issues that were not and could not have been considered and decided at earlier stages.

TEMPORARY OPERATING LICENSES

Let me turn next to a few comments on temporary operating licenses. Although no applicant requested a temporary operating license for a nuclear powerplant prior to December 31, 1983, when NRC's authority to issue such a license expired, the potential for licensing delays, which led to the authority provided in Public Law 97-415, continues to exist today.

The Commission believes that it would be desirable to extend its authority to issue temporary operating licenses. Our recommendation is made with the clear understanding that such authority would be exercised sparingly and only when it is clearly demonstrated to the Commission that operation would involve no undue risk to the public health and safety.

In the Commission's view, this authority is an important tool for dealing with situations that might arise where construction gets ahead of our schedule. I should note, Commissioners Gilinsky and Asselstine do not believe there is a need to extend the temporary operating license provision.

EMERGENCY PLANNING

The third topic of special interest is emergency planning. In principle, the Commission believes that failure of a State or local government to plan, or to implement plans, should trigger a requirement that other alternatives for protection of the public be considered. It is, therefore, important to preserve the language in last year's authorization bill that permits the Commission to issue an operating license for a nuclear power reactor, if it determines that there exists a State, local, or utility plan which provides reasonable assurance that public health and safety are not endangered by operation of the facility.

It is also important for the Congress to work with FEMA and NRC to come up with a solution to the problem of legal authority in the absence of State or local government participation. A possible approach would be to make available Federal resources if a governor requested them.

CLEANUP OF TMI UNIT 2 REACTOR

The fourth topic of special interest is the cleanup of the TMI unit 2 reactor. Recent events hold some promise of help for the utility's efforts to secure committed funding for future cleanup activities. However, they do not provide much confidence that the approximately $600 mil

lion effort still remaining will be adequately funded or expeditiously completed. Given the existing funding uncertainties and the formidable technical problems that the utility must overcome, the Commission has serious reservations about GPU meeting its current schedule for completing fuel removal in 1986.

While we believe that adequate protection of public health and safety is currently being maintained, the Commission is concerned about the slow pace of the cleanup, primarily because of the increasing potential for unforeseen problems arising. The Commission believes it may be time for the Congress and the executive branch to consider new approaches. I personally believe that an approach similar to that used at the West Valley site should be considered.

CONSOLIDATION

Let me turn next to the matter of consolidation of NRC. One vexing problem for the Commission is conducting business from 11 widely separated locations in Washington, Rockville, Silver Spring, and Bethesda. Because of facility inadequacies and high maintenance costs, we have been asked by the General Services Administration to move the Commisioners' and staff offices out of the Matomic Building in downtown Washington when the lease runs out next year. Some other buildings we now occupy in suburban Maryland have similar problems, and GSA staff has indicated that it will be looking for alternatives to our current configuration, particularly for two buildings whose leases expire in 1986. However, GSA has not told us where we could relocate and how such relocations could help fulfill our need to consolidate. We urgently need to consolidate, but we have no building in which to do

So.

The subcommittee's continued support is urgently needed to get this matter resolved as soon as possible. We may also need your help later if interests are brought to bear that could delay or prevent consolidation.

This completes my oral presentation, Mr. Chairman. At this time we would be pleased to answer any questions you may have.

RESTRICTION ON HIGHLY ENRICHED FUEL AT UNIVERSITIES

Chairman HATFIELD. Thank you very much, Mr. Palladino.

Would you describe the Commission's efforts that I understand are underway to restrict the use of highly enriched uranium fuel in university research reactors?

Mr. PALLADINO. Mr. Chairman, we have been addressing this question of getting highly enriched uranium out of university reactors and have prepared a policy statement on this matter.

The major difficulties are with two universities that have special requirements. And while we would like to see them proceed also in going to low enriched uranium, provisions are included whereby special problems could be considered.

Chairman HATFIELD. Is there a potential danger posed by the use of highly enriched uranium?

Mr. PALLADINO. There are two problems that we see in the use of highly enriched uranium for university reactors particularly, and general usage by research reactors: One is the question that existence of highly enriched uranium in these locations does increase the possibility of sabotage and would require additional safeguards. The other has to do with setting an example for the rest of the world that we should not be trafficking in highly enriched uranium when it is not necessary from a nonproliferation standpoint. The material in the form that is used could be potentially used for nuclear weapons if it got in the wrong hands.

Chairman HATFIELD. Is lower enriched uranium technically feasible? Mr. PALLADINO. It is in most reactors. There are some reactors that have high fluxes where the development of special fuels needs to be completed before conversion could be made.

Chairman HATFIELD. How many university reactors are affected in

this?

Mr. PALLADINO. Commissioner Gilinsky said 24.

Chairman HATFIELD. Would you supply that for the record?

Mr. PALLADINO. You would like a list for the record? We will provide that.

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* Material taken from LEU Study Group Report of November 15, 1983

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