Risk-Informed Material Categorization

The current method of categorizing nuclear material in the United States is too heavy handed for the current age, and its bluntness is a poison to progress. Material categorization refers to the method of specifying the attractiveness of nuclear material to a bad actor and the level of security, controls, and accounting required for a facility. The U.S. Nuclear Regulatory Commission (NRC) classifies material within Title 10 of the Code of Federal Regulations Part 73 using the quantity of nuclear material onsite and the material’s enrichment to determine a material category of I, II, or III. This rating has far-reaching regulatory requirements that prescribe certain material-handling procedures, reporting requirements, prescriptive security measures, personnel organization, and more. However, using only mass and enrichment yields an opaque assessment of the material’s attractiveness. This method neglects the physical form of the material, which can present significant difficulty in harvesting special nuclear material despite its total mass and enrichment. Further, categorizing materials in this way leads to overprotecting and imposing requirements that stifle development with artificial costs at a time when there is an urgent need for new and expanded capabilities in nuclear power production and nuclear material processing. Instead of viewing material categorization simply as a two-dimensional measurement of attractiveness to adversaries, it should be risk informed to accurately characterize attractiveness. Incorporating a riskinformed approach considers more than surface-level measurements of the nuclear material and adds operational context. This context includes factors such as proactive friendly actions, the environment that exists around a licensed facility, and the nuclear material’s physical form. One of the largest drivers of cost burden is physical security against violent design basis threats. Attempts against hardened locations are conspicuous activities that require thorough planning as well as resourcing restricted materials. This behavior deserves consideration for reducing risk because there may be resources around a facility that would detect and interdict such threats. Therefore, considering operational context analytically can avoid unnecessary cost burdens when it can be shown that the risk-informed method provides an equal level of protection to the mass-and-enrichment material categorization method. By reducing cost barriers, the riskinformed framework expands the opportunity for advancement in the nuclear industry.