Regulatory Compliance

Paul provides advice, counsel and best practices guidance on legal and regulatory requirements, safety, site and personnel security, robust compliance and safety cultures and safety conscious work environments.

 

Nuclear Security

Paul counsels nuclear industry clients on the U.S. Nuclear Regulatory Commission (NRC) and U.S. Department of Energy (DOE) regulatory requirements pertaining to nuclear security and is often engaged to assist clients in addressing events and allegations that implicate a degradation of security or potential procedural or regulatory violations. In such engagements, Paul provides stand-alone legal counsel, conducts or oversees internal investigations of security-related events and assists in the development of corrective actions and improvements to minimize recurrence. 

 

Insider Mitigation

Paul has substantial experience with nuclear facility insider mitigation, including access authorization, fitness-for-duty and behavioral observation regulations and assists clients responding to unique or otherwise significant issues arising during the implementation of these regulatorily complex programs and in connection with internal and agency investigations. Clients also seek his expertise while defending employment lawsuits and union grievances that involve access, fitness-for-duty or behavioral observation issues as these programs may implicate employment laws such as the Americans with Disability Act, the Fair Credit Reporting Act and the Health Insurance Portability and Accountability Act.

 

Technical Requirements

Paul provides legal advice on many of the technical requirements applicable to commercial nuclear power facilities. As a degreed and experienced engineer, he quickly assimilates the technical aspects of the issues and events of the matters for which he is engaged. 

Paul works most often with the regulations governing radiation protection, quality assurance, operator training and licensing, and control and accounting of special nuclear material.

 

Non-technical Requirements

Much of Paul’s work involves an array of non-technical yet highly consequential regulatory requirements, including NRC and DOE regulations that: (1) prohibit licensee employees and contractors from deliberately placing the licensee in violation of regulatory requirements (10 CFR §§ 50.5 and 820.71); (2) prohibit retaliating against employees and contractors for raising concerns implicating nuclear safety, security and other similarly significant issues (10 CFR §§ 50.7 and 820.13); and (3) prohibit, among other things, submitting materially incomplete or inaccurate information (10 CFR §§ 50.9 and 820.11). 

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Paul counsels his clients on all aspects of these regulations, including their metes, bounds and implications, how best to respond to and address alleged violations, and training on how to act in full conformance with these requirements.