Keep NRC physical-protection records linked to the requirement they evidence

Treat this document as a focused evidence review: Keep NRC physical-protection records linked to the requirement they evidence. Only the official source and traced locations below supply facts. Confirm applicability before acting.

Source fact:

The official 10 CFR 73.70 – Records from U.S. Nuclear Regulatory Commission via eCFR supports the following bounded statements:

• Under 10 CFR 73, the rule requires that the licensee retain this record of currently designated authorized individuals for the period during which the licensee possesses the appropriate type and quantity of special nuclear material requiring this record under each license that authorizes the activity that is subject to the recordkeeping requirement and, for three years thereafter. The research record locates this support at 10 CFR 73.70(a) (eCFR anchor p-73.70(a)).
• Under 10 CFR 73, the rule requires that the licensee retain the documentation for these events for three years from the date of documenting each event. The research record locates this support at 10 CFR 73.70(e) (eCFR anchor p-73.70(e)).

Keep the evidence boundary at these traced claims. They support a review of access control, video, intrusion detection, communications, supporting facilities, operators, and documented response paths; they do not support conclusions outside the source’s stated conditions.

What the source does not establish

NRC regulation; exact record types, retention periods, protected information, electronic systems, license conditions, and inspections require full-rule and qualified review. It does not establish a deployment’s current state, authorize a production change, prove compliance, or show that identity, Windows DNS where used, time, networks, power, life-safety systems, vendors, and monitoring personnel are healthy. Documented options are review inputs, not universal mandates.

Applicability questions

• For source statement 1 at 10 CFR 73.70(a) (eCFR anchor p-73.70(a)), which observable configuration, record, or test can confirm applicability here?
• For source statement 2 at 10 CFR 73.70(e) (eCFR anchor p-73.70(e)), which observable configuration, record, or test can confirm applicability here?
• Which owner can attest to the recorded state of access control, video, intrusion detection, communications, supporting facilities, operators, and documented response paths, including exceptions?
• What baseline for identity, Windows DNS where used, time, networks, power, life-safety systems, vendors, and monitoring personnel must accompany the source-specific observation?
• Which success, stop, and escalation criteria are written before testing begins?

DSE recommendation:

DSE recommends using the cited source as the evidence anchor for this decision. Anchor the review in the cited section and keep observation separate from interpretation. Record the source location, examined part of access control, video, intrusion detection, communications, supporting facilities, operators, and documented response paths, observed and expected states, owner, and reason for deviation.

If the review warrants change, use a bounded implementation with prerequisites, test population, monitoring, abort criteria, and a rehearsed reversal. Sequence checks for identity, Windows DNS where used, time, networks, power, life-safety systems, vendors, and monitoring personnel and sanitize protected material before retention.

Verification and evidence

Evidence should let another reviewer reproduce this decision. Retain observations beside the traced locations 10 CFR 73.70(a) (eCFR anchor p-73.70(a)); 10 CFR 73.70(e) (eCFR anchor p-73.70(e)). Favor asset and firmware inventories, configuration exports, event tests, inspections, alarm response records, and maintenance findings, linked to stable identifiers, time, and operator.

Retain the starting state, authorization, execution record, outcome, deviation, and final state as one review package. Move disruptive checks to an approved test path. Reopen the decision when versions, design, dependencies, ownership, or official guidance changes.

Official references

• 10 CFR 73.70 – Records — U.S. Nuclear Regulatory Commission via eCFR