Joseph R. Gray

Joseph R. Gray holds BS and MS degrees in nuclear engineering. He also holds a JD and is licensed to practice law in the District of Columbia and the State of Pennsylvania. Mr. Gray served as a senior engineer and nuclear fuel designer at the Westinghouse-Bettis Atomic Power Laboratory in West Mifflin, PA where he was involved in the design and analysis of nuclear reactor cores for US Navy submarines. After law school, Mr. Gray worked for the US Nuclear Regulatory Commission where he served as a hearing attorney and hearing branch chief, representing the NRC Staff in reactor licensing hearings before Atomic Safety & Licensing Boards, Atomic Safety & Licensing Appeal Boards and the Commission. Following his work in NRC hearings, Mr. Gray served as legal assistant for NRC Chairman Lando Zech, executive/legal assistant for NRC Commissioner James R. Curtiss and executive/legal assistant for NRC Commissioner Edward McGaffigan, Jr. Mr. Gray also worked as the Deputy Director of the NRC’s Office of Enforcement. In 1998, Mr. Gray returned to the NRC’s Office of the General Counsel where he served as Associate General Counsel for Licensing and Regulation. In the Spring of 2009, Mr. Gray took on additional responsibilities, serving as Acting Deputy General Counsel until his retirement from NRC at the beginning of 2010. Following his retirement from Federal service, Mr. Gray joined with Francis X. Cameron to form CameronGray, LLC, a firm focusing on federal nuclear regulatory legal consultation and representation. Independent of CameronGray, LLC, Mr. Gray has also engaged in nuclear regulatory consulting providing analyses and advice on a range of nuclear regulatory issues including nuclear power plant decommissioning, new reactor readiness for operation, and quality assurance requirements and enforcement for nuclear facility construction.

EMPLOYMENT HISTORY

8/1969 – 8/1973
Westinghouse Bettis Atomic Power Laboratory, West Mifflin, PA
Engineer and senior engineer and fuel element designer in the Advanced Submarine Project, responsible for fuel element and reactor core fuel design and analysis for new attack submarines. Developed control rod distortion analysis computer program and provided lectures in Navy nuclear power school courses at Bettis.

9/1973 – 6/1976
Dickinson School of Law, Carlisle, PA – student. Part-time employment as mechanical engineer with Masland Carpet Company in Carlisle, PA (summer 1974) and as law clerk with law firm of Myers, Myers, Flower & Johnson in Lemoyne, PA (summer 1975 through June 1976).

8/1976 – 10/1986
US Nuclear Regulatory Commission, Washington, DC

Hearing attorney and senior hearing attorney representing NRC staff in reactor licensing and enforcement hearings, including the Trojan spent fuel pool license amendment proceeding, Trojan control building shutdown/enforcement proceeding involving defective construction issues for the Trojan control building, Skagit construction permit (CP) proceeding, Green County CP proceeding, UCLA Research Reactor license termination proceeding and the TMI restart proceeding (responsible for emergency planning portion). Developed/authored the original NRC Staff Practice and Procedure Digest, NUREG – 0386 on NRC hearing process and procedure.

Deputy Assistant Chief Hearing Counsel and Assistant Chief Hearing Counsel (branch chief) in the NRC’s Office of the Executive Legal Director, managing a hearing branch (typically 8 attorneys and 2 administrative assistants or paralegals) in about 5 active/ongoing hearings per year. Also during this time, served as a member of the NRC’s Regulatory Reform Task Force which developed NRC’s current backfit rule (10 CFR 50.109).
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Legal Assistant to NRC Chairman Lando Zech, providing legal and regulatory advice and analysis to the Chairman and Chairman’s Office staff.

10/1986 – 8/1988
Tourtellotte, Ross and Gray, Washington, DC

Partner in small law firm providing legal and regulatory services for utilities and government agencies. Primary work involved commercial nuclear power plant emergency planning and licensing of the Seabrook NPP.

8/1988 – 12/2009
US NRC, Rockville, MD

Executive/Legal Assistant to NRC Commissioner James R. Curtiss, providing legal and regulatory advice and analysis to Commissioner Curtiss and his staff and managing the office staff; representing the Commissioner in interactions with other Commission offices, the Office of the Executive Director for Operations (OEDO) and NRC technical staff.

Deputy Director and Associate Director for Reactors, Office of Enforcement (OE), overseeing the imposition of enforcement actions, the development of enforcement actions in coordination with regional personnel and inspection staff, the development of enforcement policy and general management of the OE staff. Primary focus was escalated enforcement actions involving power reactors. Also assisted regulators in Ukraine and Russia in their development of regulatory and enforcement infrastructures and the development of the legal bases for commercial nuclear enterprises – reactor design, construction and operation approval and oversight; radioactive materials possession/use and oversight — in their countries following the demise of the Soviet Union.

Executive/Legal Assistant to NRC Commissioner Edward McGaffigan, Jr., providing legal and regulatory advice and analysis to Commissioner McGaffigan and his staff and managing the office staff; representing the Commissioner in interactions with other Commission offices, OEDO and NRC technical staff.

Associate General Counsel for Licensing and Regulation, responsible for directing and overseeing the Legal Counsel, Legislation and Special Projects Division (10 – 12 attorneys and 2 administrative assistants or paralegals) and the Rulemaking and Fuel Cycle Division (12 –14 attorneys and 2 administrative assistants) in the Office of the General Counsel. Work of the divisions included import and export licensing and the development, with other U.S departments and agencies, of international agreements for cooperation and information exchange, development of legislation and interactions with Congress and OMB, Price-Anderson implementation, FOIA administration, all agency rulemaking, Agreement State administration and materials and waste licensing. and regulation. Significant regulatory work included major input to, and successful support for the commercial nuclear provisions of the Energy Policy Act of 2005, a rewrite of the whole of 10 CFR Part 2 (hearings/rules of practice), a major rewrite of Part 52 on new reactor licensing, a rewrite of the safeguards information (SGI) rules, a rewrite of the security regulations in 10 CFR Part 73, a major revision to the fitness-for-duty requirements in 10 CFR Part 26 and input for a substantial update and revision to the NRC’s Waste Confidence decision.

Acting Deputy General Counsel, 2009 until retirement from Federal service at the beginning of 2010, served as acting Deputy General Counsel of the NRC.

2010 to present

Since his retirement from NRC in January 2010, Mr. Gray has engaged in consulting on nuclear licensing and regulatory matters, has served as an instructor in the Pennsylvania Environmental Law Forum and the Duke Environmental Law course at NRC, has done independent nuclear regulatory consulting work for other firms and has worked as a partner in CameronGray, LLC, providing legal and regulatory services in the nuclear licensing and regulatory area and in Federal and State environmental law matters. Work in these areas has involved: the preparation of papers on NRC reactor licensing under 10 CFR parts 50 and 52 for the Blue Ribbon Commission on Nuclear Waste, regulatory analysis and advice on design, construction and licensing of small modular reactors, regulatory analysis and advice on commercial power reactor construction management, analysis and advice on NRC commercial power reactor decommissioning requirements, analysis and advice on low-level radioactive waste management and disposal, advice on potential requirements being considered by the NRC to address Fukushima issues for U.S. power reactors, and analysis and advice to a rebar supplier on commercial grade dedication under 10 CFR Part 50, Appendix B and 10 CFR Part 21.

EDUCATION

BS Nuc.E cum laude – Pennsylvania State University (1969)
MS Nuc.E cum laude – Carnegie-Mellon University (1972)
JD cum laude – Dickinson School of Law (1976)

LICENSES
PA Supreme Court
District of Columbia Court of Appeals

HONORS
NRC Meritorious Service Award – 1994, 2003
US Meritorious Executive Rank Award – 2005
Pennsylvania State University Outstanding Engineering Alumni — 2005

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