Verify transportation physical-protection subsystems as an integrated whole

Keep this document to one review outcome: Verify transportation physical-protection subsystems as an integrated whole. Only the official source and traced locations below supply facts. Confirm applicability before acting.

Source fact:

The official 10 CFR 73.26 – Transportation physical protection systems from U.S. Nuclear Regulatory Commission via eCFR supports the following bounded statements:

• Under 10 CFR 73, the rule requires that operational tests and inspections be conducted for physical protection related subsystems and components to assure their maintenance in an operable and effective condition. The research record locates this support at 10 CFR 73.26(h)(3) (eCFR anchor p-73.26(h)(3)).
• Under 10 CFR 73, the rule requires that preventive maintenance programs be established for physical protection related subsystems and components to assure their continued maintenance in an operable and effective condition. The research record locates this support at 10 CFR 73.26(h)(4) (eCFR anchor p-73.26(h)(4)).

Do not import neighboring assumptions into the source record. The supported task is a scoped comparison involving access control, video, intrusion detection, communications, supporting facilities, operators, and documented response paths and the conditions the source actually describes.

What the source does not establish

NRC regulation for defined materials and shipments; routes, times, response, communications, and other protected security details must remain restricted and receive qualified review. A correct source interpretation can still be inapplicable to a particular design. Confirm identity, Windows DNS where used, time, networks, power, life-safety systems, vendors, and monitoring personnel, ownership, and change authority instead of treating documented behavior as a deployment guarantee.

Applicability questions

• For source statement 1 at 10 CFR 73.26(h)(3) (eCFR anchor p-73.26(h)(3)), which observable configuration, record, or test can confirm applicability here?
• For source statement 2 at 10 CFR 73.26(h)(4) (eCFR anchor p-73.26(h)(4)), which observable configuration, record, or test can confirm applicability here?
• Which deployed instance of access control, video, intrusion detection, communications, supporting facilities, operators, and documented response paths will be compared with the source, and why that instance?
• How will the review distinguish a source mismatch from a failure in identity, Windows DNS where used, time, networks, power, life-safety systems, vendors, and monitoring personnel?
• Who approves the conclusion, exception, test window, and rollback threshold?

DSE recommendation:

DSE recommends using the cited source as the evidence anchor for this decision. Use a two-person review for the source interpretation and the resulting operational decision. 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.

An implementation decision needs an owner, approved window, prechecks, observable outcome, stop authority, and rollback path. Validate identity, Windows DNS where used, time, networks, power, life-safety systems, vendors, and monitoring personnel before and after the test, and store only sanitized operational evidence.

Verification and evidence

Build a reproducible chain from 10 CFR 73.26(h)(3) (eCFR anchor p-73.26(h)(3)); 10 CFR 73.26(h)(4) (eCFR anchor p-73.26(h)(4)) to the observed environment. Useful domain evidence includes asset and firmware inventories, configuration exports, event tests, inspections, alarm response records, and maintenance findings; label every item with scope, timestamp, collector, and stable identifier.

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 73.26 – Transportation physical protection systems — U.S. Nuclear Regulatory Commission via eCFR