Compliance or Good Control and Accountability

DOE Orders and draft Orders for nuclear material control and accountability address the need for a complete material control and accountability (MC&A) program for all DOE contractors processing, using, and/or storing nuclear materials. These orders also address performance as well as compliance issues. Very often the existence of a program or an element of a program satisfies the compliance aspect of DOE requirements. The concept of performance requirements is new and requires new thinking with all of the elements of the MC&A program. The contractor is so accustomed to compliance with DOE requirements that dealing with performance is not well understood. In this paper, I will address the receptiveness of performance requirements by the contractor. Auditing for performance is also a new concept and has not been implemented. The contractor will have to learn how to measure the performance of the MC&A program and be able to demonstrate a certain level of performance to the oversight organization. This paper will contain a discussion of a well organized MC&A program, the compliance issues associated with the program, the performance criteria associated with the program, and how to audit such a program.