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A Study on Urgent Technology Transfer System for the License on Technology Export of Nuclear Plant and Current Issues
The License on Technology Export of Nuclear Plant is a system that permits the export of strategic technologies for large-scale NPP projects collectively during the project period. So, an issuance of the export license could be omitted for each transfer of technology, but Post Strategic Items Confirmation must be performed before the transfer as a follow-up obligation. Sometimes, transfers of technology have been urgently required during the project. As Post Strategic Items Confirmation process takes up to 15 working days, it may be difficult to respond to urgent situations timely, which may cause setbacks on the project. Therefore, Urgent Technology Transfer System, which allows to transfer technology without prior Post Strategic Items Confirmation, was established to reduce a burden on licensee and improve the efficiency of regulation. This system applies only to the License on Technology Export of Nuclear Plant. In other words, the technology transferred through Urgent Technology Transfer System (hereinafter referred as Urgent Transfer Technology) does not pose any problem with regard to export control because it is already licensed. In addition, the Urgent Transfer Technology should be considered as a strategic technology until Post Strategic Items Confirmation, which means that the Urgent Transfer Technology is more strictly controlled than the generally transferred technology. Also, the Urgent Technology Transfer System does not apply to intangible technology transfers such as technical support through personnel dispatch. The system could be only used in specific conditions which are stipulated for each licensed project in advance in order to prevent indiscriminate abuse of the system by licensee. Licensees are required to report quarterly the stipulated condition corresponding to each Urgent Technology Transfer case, and it would be checked through post-site inspection whether the actual reason for the transfer meets the consulted condition. Moreover, the deadline of application on Post Strategic Items Confirmation after the Urgent Technology Transfer is stipulated for licensee so as not to omit the classification procedure. This Urgent Technology Transfer System does not apply to dual-use items. If the Urgent Transfer Technology is classified as a non-Trigger List Item through the Post Strategic Items Confirmation, it is outside the scope of the NSSC’s export license. In this case, the technology may be subject to an export license of the Ministry of Trade, Industry and Energy (MOTIE). However, if the technology is classified to be a dual-use item after Urgent Technology Transfer, it may result in unauthorized transfer because it has already been transferred. Licensee must apply to classification of MOTIE before Urgent Technology Transfer if the technology being transferred may be related with Dual-use Items. It is easy for licensee to overlook due to the low awareness about this system. Therefore, outreach activities are necessary to raise licensee’s awareness by explaining the Urgent Technology Transfer System and current issues in detail. Consultation with MOTIE may be needed for the improvement on issues.
