Regulatory  Technology  Services

“The foundational goal of Regulatory Technology Services is to be the

bridge between plant owners and industry experts when emergent

staffing needs are identified.”

- Keith Graham, President

Staff, Strategies, and Solutions for Nuclear Plant Licensing



Regulatory Technology Services supplies our clients with “Regulatory Technology” not a commonly used term.  RTS is committed to work with our clients to change that; to advance the practical application of knowledge about best practices and core competencies for managing nuclear safety.


RTS is experientially qualified to assist your team based on lessons learned through the years.

Examples of assignments relevant to our scope of expertise include:


Callaway Plant Construction – A 10 CFR Part 50 license plant built in an 86 Months construction schedule – that’s construction to power operations; a notable achievement and benchmark example for teamwork when compared with other plants licensed in the 1980s.


Comanche Peak Steam Electric Station – Served as a construction inspection consultant for the US NRC Office of Special Projects.  The NRC’s Region IV Comanche Peak Response Team resolved over 1500 allegations regarding construction quality issues and performed NRC inspections of the plant owner’s recovery programs to resolve nuclear safety issues.  Prepared Safety Evaluation Reports (SERs) for approval of the Unit 1 and 2 Operations License.


US DOE Defense Waste Processing Facility at Savannah River Site – Established an Integrated Commitment Matrix (ICM) for Westinghouse Savannah River Company, based on the DWPF safety analysis report.  The ICM identified and all DOE authorization basis commitments and was used to track their closure; a requirement for DOE Authorization for DWPF to begin startup and operations.


Waterford III – Prepared 10 CFR 50.54(f) response letter regarding Loss of Configuration Management at Millstone Nuclear Station.   A comprehensive evaluation of Entergy’s configuration management  (CM) controls was required along with site specific response to establish NRC confidence in the site’s CM processes.


Arkansas Nuclear One Instrument Uncertainty Calculation Project – Reviewed FSAR, Design Basis Documents, Accident Analysis Assumptions, and Instrument Uncertainty Calculations to determine width of regulatory margins based on a graded approach to the treatment of instrument uncertainties and their impact on regulatory compliance.


Entergy License Renewal Projects – Arkansas Nuclear One Unit 1 and 2, Pilgrim, and Vermont Yankee aging management reviews and preparation of License Renewal Applications.  ANO-1 was the 2nd US NRC licensee to be approved for 20 year extension of the operating license.


Oconee Nuclear Station – Design Basis Recovery Project to resolve High Energy Line Break (HELB) and Tornado Mitigation issues.  Performed reviews of legacy licensing basis, self-assessment of compliance, performed benchmarking review at DC Cook, and gap analysis to determine how to resolve licensing basis issues and the scope of plant licensing basis changes needed to resolve those issues.


General Electric Hitachi STP COLA Project – 10 CFR Part 52 Licensing Engineer for first new nuclear plant license application to be submitted to the US NRC in over 30 years.  Created STP COLA  contents based on US ABWR Design Certification.  This project was first-of-a-kind under the 10 CFR 52 licensing application process.


General Electric Hitachi ESBWR Design Certification Document (DCD) Project – Prepared GEH responses to NRC Request for Additional Information (RAI) regarding DCD Tier 1 Descriptions and ITAAC, and revised the DCD based on the RAI responses.


UniStar COLA Projects – Prepared revisions to Calvert Cliffs R-COLA and prepared Revision O COLAs for PPL Bell Bend Site, AmerenUE Callaway Plant, and Constellation Nine Mile Point 10 CFR Part 52 license applications.  Also supported UniStar legal team on resolution of environmental permitting issues identified by US Army Corps of Engineers.


Dominion R-COLA – Prepared North Anna COLA revision to switch reactor technology from GEH ESBWR DCD to Mitsubishi US APWR DCD, a complex conversion process that required comprehensive analysis of both of the reactor technologies in order to minimize schedule and financial impacts to the customer.


UAE Emirates Nuclear Energy Company (ENEC) Braka Unit 1 and 2 License Applications – prepared license applications based KEPCO APR-1400 reactor technology and a combination of US NRC, IAEA, and Korean nuclear regulatory requirements.  Evaluated robustness of APR-1400 design and licensing basis to mitigate nuclear safety issues linked to Japan’s Fukushima Dai-ichi event.  ENEC’s Braka site is a world leader in new plant construction.


PPL Susquehanna Staff Augmentation and NRA Consultant – Performance of operational licensing tasks including support for NRC team inspections, preparation of Licensing Document Change Notices, screening of Condition Reports for NRC 50.73 reportability, and other routine tasks for Nuclear Regulatory Affairs line management.



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