MC&A CONSIDERATIONS IN FORCE-ON-FORCE PERFORMANCE EVALUATIONS AT NRC-LICENSED CATEGORY I FUEL CYCLE FACILITIES

The U.S. Nuclear Regulatory Commission (NRC) has licensed two Category I fuel cycle facilities that store and process Category I quantities of strategic special nuclear material (SSNM). The U.S. Code of Federal Regulations (CFR) requires these facilities to protect SSNM against the NRC’s theft and diversion design basis threat (DBT) for Category I facilities. The NRC evaluates the effectiveness of the licensees’ security measures by conducting periodic force-on-force (FOF) inspections. These inspections are conducted by an inter-disciplinary team of NRC subject-matter experts, including a nuclear material control and accounting (MC&A) specialist. A materials specialist plays a critical role by determining potential SSNM targets to be used in FOF exercises, evaluating safetysecurity interfaces, and addressing other nuclear material and process related issues. The paper discusses MC&A aspects of NRC FOF exercises at Category I fuel cycle facilities and is based on past inspection experience.