HomeAbout NRCOrganization & Functions

# Office of the General Counsel

On this Page:
            - Office of the General Counsel
            - Solicitor
            - Deputy General Counsel for Licensing, Hearings, and Enforcement
            - Program Support Branch
            - Assistant General Counsel for Reactor Programs
            - Assistant General Counsel for Materials, Fuel Cycle and Waste Programs
            - Assistant General Counsel for Security and Enforcement
            - Deputy General Counsel for Legislation, Rulemaking, and Agency Administration
            - Assistant General Counsel for Labor, Employment, and Contract Law
            - Assistant General Counsel for Legislation, Ethics, and Administrative Law
            - Assistant General Counsel for Rulemaking, Agreement States, and Fee Policy

## Office of the General Counsel

**General Counsel:** Brooke P. Clark

Directs matters of law and legal policy, providing opinions, advice, and assistance to the agency with respect to all of its activities; reviews draft Commission opinions on public petitions seeking direct Commission action and rulemaking proceedings; monitors adjudicatory proceedings, and reviews draft Commission adjudicatory decisions; provides interpretation of laws, regulations, and other sources of authority, and the legal form and content of proposed official actions; represents and advises staff offices in all programmatic activities and administrative litigation in connection with licensing and enforcement; prepares or concurs in all contractual documents, interagency agreements, delegations of authority, regulations, orders, licenses, and other legal documents, and prepares legal interpretations thereof; represents NRC in administrative proceedings related to such matters as personnel, procurement, and equal employment opportunity; reviews and directs intellectual property work; represents and protects the interest of the NRC in legal matters, in court proceedings, and in relation to other government agencies, administrative bodies, committees of Congress, foreign governments, and members of the public; provides legal advice to the Commission (including staff), and represents the Commission in courts of appeals proceedings to review Commission orders and rules; and, in cooperation with the Department of Justice, represents the Commission in court proceedings affecting the agency's programs in the Federal district courts and the Supreme Court.

----

## Solicitor

Andrew Averbach

Assists the General Counsel in all aspects in the role as chief legal officer of and legal advisor to the NRC with primary responsibility in matters involving the supervision of litigation in courts of law; and represents the NRC in Court of Appeals litigation and in conjunction with the Department of Justice in other Federal courts. Provides counsel to NRC employees called to testify concerning official duties in cases in which NRC is not a party. Advises the Commission on litigative risk of proposed actions.

----

## Deputy General Counsel for Licensing, Hearings, and Enforcement

**Deputy General Counsel:** Bernice Ammon

Advises the General Counsel, the Commission and the Commission staff on all aspects of reactor licensing and regulation (including license transfers, license renewal and design certification), materials licensing litigation and enforcement and regulatory oversight of reactor and materials licensees. Serves as the OGC representative on the Human Capital Council. Serves as principal legal advisor to the Commission's staff on licensing and enforcement adjudication before the Commission on the conduct of adjudicatory hearings, and the implementation of the Commission's enforcement program. In carrying out these responsibilities, provides advice on the implementation of the Atomic energy Act of 1954, as amended, the energy reorganization Act, the Energy Policy Act of 1992, the National Environmental Policy Act, and other environmental laws. Assists the General Counsel in providing legal advice to the Commission and the staff on interagency and international agreements, procurement, intellectual property, security, personnel, and administrative functions.

## Program Support Branch

**Chief:** Allison Robinson

Provides to the General Counsel program analysis and direction of program support activities. Responsible for program development and evaluation in the areas of resource utilization, personnel management, and organizational planning and analysis. Provides office services, including human resources, recruitment, training, information technology, equipment, space, correspondence control, mail and records control, and maintains Legal Research Center and legislative reference service functions.

## Assistant General Counsel for Reactor Programs 

**Assistant General Counsel:**Susan VrahoretisThe RP Division assists the General Counsel in providing legal advice and support regarding operating reactor licensing, new reactor licensing, advanced reactor licensing, operator licensing, reactor license transfers, reactor decommissioning, and research and test reactor licensing.  In addition to this licensing work, RP handles related litigation before the Atomic Safety and Licensing Boards and the Commission

## Assistant General Counsel for Materials, Fuel Cycle and Waste Programs 

**Assistant General Counsel:** Mauri Lemoncelli

The MFW Division assists the General Counsel in providing legal advice and support in connection with licensing work for materials, fuel cycle, spent fuel storage and disposal, fuel packaging and transportation, and low- and high-level waste storage and disposal.  In addition to this licensing work, MFW handles related litigation before the Atomic Safety and Licensing Boards and the Commission.

## Assistant General Counsel for Security and Enforcement 

**Assistant General Counsel:** Patrick Moulding

The SE Division assists the General Counsel in providing legal advice and support in connection with security and enforcement matters.  SE advises, represents, and assists the NRC staff with respect to all reactor and materials enforcement matters, including cases before the Atomic Safety and Licensing Boards and the Commission.  SE also handles the legal sufficiency function, which includes the provision of advice to the Office of Small Business and Civil Rights on certain equal employment opportunity matters.

----

## Deputy General Counsel for Legislation, Rulemaking, and Agency Administration

**Deputy General Counsel:** Mary Spencer

Advises the General Counsel and Commission in all aspects of domestic licensing and regulation, with particular emphasis on adjudication, legislation, rulemaking, and fuel cycle matters. Provides advice on employee conduct and administrative law issues, as well as on the implementation of atomic energy and environmental law. Provides legal advice and recommendations regarding high- and low-level radioactive waste disposal, spent fuel storage and transportation issues, including issues arising under the Atomic Energy Act, the Low-Level Radioactive Waste Policy Amendment Act and the Nuclear Waste Policy Act; assists NRC staff in drafting rules and policies relating to waste management and disposal, in assuring safe and environmentally sound waste management and disposal, and in assuring safe and environmentally sound spent fuel storage under 10 C.F.R. Part 72. Advises the General Counsel on the use of techniques to enhance the participation of citizens groups and industry associations in the development of Commission rulemakings and policies; identifies areas in which enhanced participation by citizens groups and industry associations may be needed and useful; and supervises the design and implementation of participatory techniques in the development of specific rulemakings and policies. Serve as OGC's Executive on Federal Employees Pay Capability Act (FEPCA), the Strategic Workforce Oversight and Utilization Panel (SWOUP), and CXO Board (CXOB); and the overall OGC Budget.

## Assistant General Counsel for Labor, Employment, and Contract Law

**Assistant General Counsel:**Robin A. Baum, Acting

The LECL Division assists the General Counsel in providing legal advice and support on legal matters relating to the operation and administration of the agency.  The division’s practice covers a broad spectrum of activities, including hiring and discipline of employees, employee pay and benefits, labor and union matters, equal employment opportunity issues, tort and employee claims, contracts, grants, and interagency agreements, security clearance, building and property management, and fiscal matters (e.g., Anti-Deficiency Act and budget matters).  LECL represents the NRC in administrative hearings involving procurement, labor and employment, personnel security, claims, and equal employment opportunity matters.

## Assistant General Counsel for Legislation, Ethics, and Administrative Law

**Assistant General Counsel:** Tison Campbell

The LEAL Division assists the General Counsel in providing legal advice and support to the Commission with matters in Congress and the courts, and advises the agency on fundamental administrative law matters, including information law and intellectual property. LEAL advises on international matters such as treaties and conventions, international arrangements and project agreements, and exports and imports. LEAL advises the Commission and the Secretary on the responsibilities of the Commission and internal Commission governance; drafting and interpreting legislation and supporting the agency in its dealings with Congress; bankruptcy matters; and administers the agency’s ethics program. LEAL also supports the Commission in non-appellate adjudicatory matters and the Solicitor in federal court litigation.

## Assistant General Counsel for Rulemaking, Agreement States, and Fee Policy

**Assistant General Counsel:** Jessica Bielecki

The RASFP Division assists the General Counsel in providing legal advice and support to the Commission and staff with respect to the promulgation and amendment of NRC regulations and guidance issued in conjunction with new or amended rules and policy statements pertinent to the licensing, construction, and operation, and security of nuclear facilities (including nuclear power plants and fuel facilities) and nuclear materials.  RASFP advises on backfitting and issue finality and maintains the Backfitting Community of Practice.   RASFP advises on Agreement State and Tribal matters and advises the Office of the Chief Financial Officer on the annual fee rule, fee disputes, and fee waivers.

Page Last Reviewed/Updated Monday, December 04, 2023

Section Navigation

#### Navigation

          - The Commission
          - Advisory Committee on Reactor Safeguards
          - Atomic Safety and Licensing Board Panel
          - Commission Appellate Adjudication
          - Congressional Affairs
          - General Counsel
          - International Programs
          - Public Affairs
          - Secretary
          - Chief Financial Officer
          - Executive Director for Operations (EDO)
          - Nuclear Material Safety and Safeguards
          - Nuclear Regulatory Research
          - Nuclear Reactor Regulation
          - Enforcement
          - Investigations
          - Nuclear Security and Incident Response
          - Region I
          - Region II
          - Region III
          - Region IV
          - Chief Information Officer
          - Administration
          - Chief Human Capital Officer
          - Small Business and Civil Rights

#### Spotlight

#### Choose a Section

                - The Commission
                - License Renewal Generic Environmental Review
                - Job Openings
                - Palisades Restart
                - Environmental Justice 
                - Pilgrim Water Releases
                - Monticello Tritium Issue
                - International Strategy 2021-2025
                - Tribal Liaison Program
                - MAP-X
                - Transformation at the NRC - Updated
                - OIG Hotline
                - Rulemaking Activity
                - Commission Documents
                - Advanced Reactors
                - Nuclear Security
                - Strategic Plan

#### Key Topics

            - NRC Organization Chart

#### Related Information

            - Honor Law Graduate Program

Page Last Reviewed/Updated Monday, December 04, 2023