Treat fixed-site protection-plan submission and implementation dates as historical requirements

Treat this document as a focused evidence review: Treat fixed-site protection-plan submission and implementation dates as historical requirements. Only the official source and traced locations below supply facts. Confirm applicability before acting.

Source fact:

The official 10 CFR 73.46 – Fixed site physical protection systems from U.S. Nuclear Regulatory Commission via eCFR supports the following bounded statements:

• Under 10 CFR 73, the rule requires that each licensee implement the approved plan pursuant to paragraphs (b)(10) and (b)(11) of this section or (b)(12) of this section within 1 year after NRC approval of the revised Fixed Site Physical Protection Plan. The research record locates this support at 10 CFR 73.46(i)(2) (eCFR anchor p-73.46(i)(2)).
• Under 10 CFR 73, the rule requires that by November 28, 1994, each licensee submit a revised Fixed Site Physical Protection Plan to the NRC for approval. The research record locates this support at 10 CFR 73.46(i)(1) (eCFR anchor p-73.46(i)(1)).

These statements are the factual basis for this document. Do not extend them into a broader assurance. Review access control, video, intrusion detection, communications, supporting facilities, operators, and documented response paths only where the source and recorded environment align.

What the source does not establish

The cited paragraphs contain a November 28, 1994 submission date and a post-approval implementation period; they do not establish a new present-day deadline. NRC requirements, approved plans, and protected security information require 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 73.46(i)(2) (eCFR anchor p-73.46(i)(2)), which observable configuration, record, or test can confirm applicability here?
• For source statement 2 at 10 CFR 73.46(i)(1) (eCFR anchor p-73.46(i)(1)), 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. Start with applicability, then compare the observed state with the cited source. 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

A reviewer should be able to retrace the decision from 10 CFR 73.46(i)(2) (eCFR anchor p-73.46(i)(2)); 10 CFR 73.46(i)(1) (eCFR anchor p-73.46(i)(1)) through asset and firmware inventories, configuration exports, event tests, inspections, alarm response records, and maintenance findings. Record what was collected, where, when, by whom, and which system or role it represents.

Record the decision even when no change is made, including uncertainty and the next trigger. Use safe testing conditions for disruptive work, preserve rollback proof, and revisit the conclusion after relevant platform, dependency, vendor, or ownership changes.

Official references

• 10 CFR 73.46 – Fixed site physical protection systems — U.S. Nuclear Regulatory Commission via eCFR