EOU U.S. NUCLEAR REGULATORY COMMISSION Revi Decembe SREGULATORY GUIC 

OFFICE OF NUCLEAR REGULATORY RESEARCH 

REGULATORY GUIDE 5.52 

(Proposed Revision 3 was issued as DG-5004) 

STANDARD FORMAT AND CONTENT OF A LICENSEE 

PHYSICAL PROTECTION PLAN FOR STRATEGIC SPECIAL NUCLEAR MATERIAL 

AT FIXED SITES (OTHER THAN NUCLEAR POWER PLANTS)

ision 3 

r 1994 

PE

A. INTRODUCTION 

This regulatory guide describes the standard for

mat recommended by the Nuclear Regulatory Com

mission (NRC) for preparing physical protection plans 

for formula quantities of strategic special nuclear mate

rial (SSNM) at fixed sites other than nuclear power 

plants. Formula quantities are sometimes referred to 

as category I quantities of material. Guidance on the 

content of physical protection plans is also provided in 

this regulatory guide. 

The requirement for a physical protection plan is 

included in the regulations for physical protection of 

licensed activities against theft and radiological sabo

tage of formula quantities of SSNM, which are in 

10 CFR Part 50, "Domestic Licensing of Production 

and Utilization Facilities"; Part 70, "Domestic Licens

ing of Special Nuclear Material"; and Part 73, "Physi

cal Protection of Plants and Materials." Specific re

quirements for licensees possessing formula quantities 

of SSNM are found in 10 CFR 73.20, 73.45, and 

73.46. 

Conformance to the format and content of the 

physical protection plan presented in this guide is not 

required by the NRC. The physical protection plan 

may be submitted for NRC review and approval in an 

alternative format that provides an equal level of comUSNRC REGUIATORY GUIDES 

Regulatory Guides are Issued to describe and make available to the public 

such information as methods acceptable to the NRC staff for implement

ing specific parts of the Commission's regulations, techniques used by 

the staff in evaluating specific problems or postulated accidents, and 

data needed by the NRC staff in Its review of applications for permits and 

licenses. Regulatory Guides are not substitutes for regulations, and corn

pliance with them is not required. Methods and solutions different from 

those set out In the guides will be acceptable If they provide a basis for the 

findings requisite to the issuance or continuance of a permit or license by 

the Commission. 

This guide was Issued after consideration of comments received from the 

public. Comments and suggestions for improvements In these guides are 

encouraged at all times, and guides will be revised, as appropriate, to 

accommodate comments and to reflect new information or experience. 

Written comments may be submitted to the Rules Review and Directives 

Branch, DFIPS, ADM, U.S. Nuclear Regulatory Commission, Washing

ton, DC 20555-0001.

pleteness and detail if it addresses every applicable sec

tion of 10 CFR Part 73, as does this regulatory guide. 

Any information collection activities mentioned in 

this regulatory guide are contained as requirements in 

10 CFR Part 73. The information collection require

ments in 10 CFR Part 73 have been approved by the 

Office of Management and Budget, Approval No. 

3150-0002. 

B. FORMAT OF THE PHYSICAL 

PROTECTION PLAN 

This document is divided into two major parts. 

The first part describes the physical protection plan 

format, and the second part outlines the elements of a 

physical protection program that should be described 

in the physical protection plan. 

If the format in this guide is used, the applicant 

should follow the numbering system used in Section C, 

"Physical Protection Plan Contents." Under some cir

cumstances, certain subsections may not be applicable 

to a specific application. If so, this should be clearly 

stated and sufficient information should be provided to 

support that conclusion. 

The applicant may wish to submit information in 

support of an application that is not required by the 

regulations and is not essential to the description of the 

applicant's physical protection program. This informa

tion, which should be relative to the plan, could

The guides are Issued In the following ten broad divisions:

1. Power Reactors 

2. Research and Test Reactors 

3. Fuels and Materials Facilities 

4. Environmental and Siting 

5. Materials and Plant Protection

6. Products 

7. Transportation 

8. Occupational Health 

9. Antitrust and Financial Review 

10. General

Copies of issued guides may be purchased from the Government Printing 

Office at the current GPO price, Information on current GPO prices may be obtained by contacting the Superintendent of Documents, U.S. 

Government Printing Office, Mail Stop SSOP, Washington, DC 

20402-9328, telephone (202)512-2249. 

Issued guides may also be purchased from the National Technical Infor

mation Service on a standing order basis. Details on this service may be 

obtained by writing NTIS, 5285 Port Royal Road, Springfield, VA 22161.
include, for example, historical data submitted in dem

onstration of certain criteria, a discussion of alterna

tives considered by the applicant, or supplementary 

data regarding assumed models, data, or calculations. 

It should be provided in an appendix to the plan. 

STYLE AND COMPOSITION 

A table of contents should be included for each 

submittal. 

The applicant should strive for clear, concise pre

sentation of information. Confusing or ambiguous 

statements and general statements of intent should be 

avoided. Definitions and abbreviations should be con

sistent throughout the submittal and consistent with 

generally accepted usage. 

Whenever possible, duplication of information 

should be avoided. Information included in other sec

tions of the application may be covered by specific ref

erence to those sections. 

Where numerical values are stated, the number of 

significant figures should reflect the precision to which 

the number is known. The use of relative values should 

be clearly indicated. Drawings, diagrams, and tables 

should be used when information may be presented 

more adequately or conveniently by such means. 

These illustrations shbuld be located in the sections in 

which they are first referenced. Care should be taken 

to ensure that all information presented in drawings is 

legible, that symbols are defined, and that drawings are 

not reduced to the extent that they cannot be read by 

unaided normal eyes. 

PHYSICAL SPECIFICATIONS OF 

SUBMITTALS 

All material submitted in an application should 

conform to the following physical dimensions of page 

size, quality of papers and inks, numbering of pages, 

etc. 

Paper Size 

Text pages: Either the metric standard A4, which 

is 210 mm by 297 mm, or the customary 8-1/2 x 11 

inches. 

Drawings and graphics: The metric A4 size or 

8-1/2 x 11 inches is preferred; however, a larger size is 

acceptable provided the finished copy, when folded, 

does not exceed the A4 size or 8-1/2 x 11 inches. 

Paper Stock and Ink 

Suitable quality in substance, paper color, and ink 

density for handling and for reproduction by micro

filming.

Paper Margins 

A margin of no less than 2.5 cm or 1 inch is to be 

maintained on the top, bottom, and binding side of all 

pages submitted. 

Printing 

Composition: text pages should be single-spaced. 

Type face and style: must be suitable for micro

filming. 

Reproduction: may be mechanically or photo

graphically reproduced. All pages of the text may be 

printed on both sides, and images should be printed 

head to head. 

Binding 

Pages should be punched for standard loose-leaf 

3-ring binders. 

Page Numbering 

Pages should be numbered sequentially through

out the main part of the document. Any appendices 

may be numbered separately if desired. Each page of 

the physical protection plan should contain a page 

number, a revision number if applicable, and a date. 

PROCEDURES FOR UPDATING OR REVISING 

PAGES 

The updating or revising of data and text should be 

on a replacement-page basis. 

The changes or revised portions of each page 

should be highlighted by a vertical line. The line should 

be on the margin opposite the binding margin for each 

line changed or added. All pages submitted to update, 

revise, or add pages to the report are to show the date 

of the change. The transmittal letter should include an 

index page listing the pages to be inserted and the 

pages to be removed. When major changes or addi

tions are made, pages for a revised table of contents 

should be provided. 

NUMBER OF COPIES 

The applicant should submit the appropriate num

ber of copies of each required submittal in accordance 

with 10 CFR 50.4(b)(2)(ii) and 10 CFR 70.21. 

PUBLIC DISCLOSURE 

The NRC has determined that public disclosure of 

the details of physical protection programs is not in the 

public interest, and such details are withheld in accor

dance with 10 CFR 2.790(d). Thus, the physical pro

tection section of each application should be submitted 

as a separate enclosure. Other proprietary or classified 

information, for example, clarifying correspondence 

between reviewer and licensee, should be clearly iden

tified and submitted in separate enclosures. Each such 

submittal of proprietary information should request ex5.52-2

L1
emption from public disclosure as required in 10 CFR 

2.790(b). 

COMPATIBILITY 

The applicant should ensure that the physical pro

tection plan is compatible with the other sections of the 

application. 

SCHEDULE FOR SUBMITTAL 

The applicant should contact the NRC to deter

mine a schedule for the submittal of the physical pro

tection plan. 

C. PHYSICAL PROTECTION PLAN 

CONTENTS 

The following sections describe, in general terms, 

the material and level of detail that should be included 

within a physical protection plan. The applicant's 

physical protection plan should follow the organization 

and numbering system used in this Section C. The 

applicable sections of the regulations are cited for each 

section of the physical protection plan. Upon comple

tion of the plan, the applicant should use this regulato

ry guide as a checklist to ensure that each subject has 

been addressed. 

1. INTRODUCTION AND SCHEDULE FOR 

IMPLEMENTATION 

This section should state the corporate name of 

the applicant, the facility name, and the location of the 

facility. The applicant should describe the type of facil

ity to be operated and the general layout of the facility 

and its surrounding area. This section should include a 

map of the entire facility and other maps and illustra

tions as appropriate. The applicant should indicate on 

these maps the locations of physical protection sys

tems, subsystems, and major components; all material 

access areas; vital areas; vaults; entry/exit control 

points; and alarm stations. 

This section should also describe the schedule for 

implementing the physical protection plan, with special 

attention to those portions involving new construction, 

significant physical modification of existing structures, 

or major equipment installation that may require ex

tensions of time. For approved plans, the scheduling of 

upgrades or new construction should be addressed in 

this section on a case-by-case basis. 

2. GENERAL PERFORMANCE OBJECTIVES 

(10 CFR 73.20(a) and 73.20(b)(1), (2), (3), 

and (4)) 

This section should describe, in general terms, 

how the physical protection program will have, as its 

objective, high assurance that activities involving spe

cial nuclear material are not inimical to the common 

defense and security and do not constitute an unrea

sonable risk to the public health and safety.

This section should also describe how the perform

ance capabilities outlined in 10 CFR 73.45 will be met 

through the establishment, maintenance, and arrange

ment for a physical protection system. 

Further, this section should identify those portions 

of the facility physical protection system for which re

dundant and diverse components are necessary in or

der to ensure adequate performance, as required by 10 

CFR 73.20(b)(2). In general terms, the applicant 

should describe the subsystems and components to be 

used to provide this redundancy and diversity and the 

ways in which these subsystems and components are 

redundant and diverse. 

Finally, this section should describe how the physi

cal protection system is designed to ensure that the in

tegrity of the system is maintained at all times. 

3. DESIGN BASIS THREAT (10 CFR 73.1) 

This section should affirm the intent to prevent, 

with high assurance, the theft of special nuclear mate

rial by the threats described in 10 CFR 73. 1. The plan 

should also describe how measures used to protect 

against theft of special nuclear material also provide 

protection against radiological sabotage. 

4. SECURITY ORGANIZATION 

4.1 Establishment of Security Organization (10 

CFR 73.46(b) (1)) 

This section should state whether the security 

organization is private or contract. If contract, this sec

tion should briefly describe the written agreements 

between the licensee and contract guard force man

agement that pertain to how the guard force will meet 

the requirements of Appendix B, "General Criteria for 

Security Personnel," and Appendix H, "Weapons 

Qualification Criteria," to 10 CFR Part 73. 

4.2 Security Organization Management (10 CFR 

73.46(b)(2) and (3)) 

This section should describe the structure and 

management of the security organization, including 

uniformed security personnel and other persons re

sponsible for security-related functions. This section 

should contain a description of each supervisory and 

management position, including responsibilities and 

how lines of authority extend up to facility and corpo

rate management. 

This section should affirm that written security 

procedures will be used and that provisions for written 

approval of such procedures and any revision thereto 

will be developed and used. 

This section should also affirm that at least one 

full-time member of the security organization with the 

authority to direct the physical protection activities of 

the security organization will be on site at all times.

5.52-3
4.3 Qualification for Employment in Security 

(10 CFR 73.46(b)(4) and (5)) 

This section should affirm that an approved guard 

force training plan in accordance with Appendices B 

and H to Part 73 is in effect. 

In addition, the plan should describe how the li

censee will demonstrate the ability of physical security 

personnel, whether licensee or contractor employees, 

to carry out their assigned duties or responsibilities 

upon the request of an authorized member of the 

NRC. The plan should also affirm that, within any giv

en period of time (at least 1 work shift or 8 hours), a 

member of the security organization will not be as

signed to or have direct operational control over more 

than one of the redundant elements of a physical pro

tection subsystem, if such assignment or control could 

result in the loss of effectiveness of the subsystem. 

4.4 Guard Force Training (10 CFR 73.46(b)(4), 

(7), and (8); II.E of Appendix B to 10 CFR 

Part 73; and Appendix H to 10 CFR Part 73) 

In addition to the affirmation that an approved 

guard force training plan is in effect (see Section 4.3 

above), this section should include a description of the 

qualification and requalification program for guards 

and tactical response team (TRT) members in firing 

with assigned weapons. For TRT members only, in

clude a description of the training program in response 

tactics. 

4.5 Security Force Armament and Equipment 

(10 CFR 73.45(g)(3) and 73.46(b)(6)) 

This section should affirm that every guard and 

tactical response team member will be armed and 

should describe the armament assigned to members of 

the security force by position title. In addition, equip

ment to be used by members of the security force in 

providing effective response capabilities should also be 

described. 

4.6 Force-on-Force Exercises (10 CFR 

73.46(b) (9)) 

This section should describe how scenarios for 

force-on-force exercises are developed, the design 

goals for conducting such exercises, and the frequency 

of such exercises. This section should affirm that the 

NRC will receive a 60-day notice of one force-on-force 

exercise each year so that the NRC may observe the 

exercise. 

4.7 Records (10 CFR 73.46(b)(3)(i), (4), (7), 

(8), and (9)) 

This section should affirm that the following 

records will be maintained and retained and should de

scribe how they will be maintained and retained:

"* Current security procedures until the NRC termi

nates the license for which these procedures were 

developed; if any portion of these procedures is 

superseded, the superseded material should be re

tained for 3 years after the change. 

"* Results of qualification and requalification for se

curity force members; the documentation should 

be retained as a record for 3 years after each quali

fication and requalification. 

"* Results of weapons qualification and requalifica

tion for firing; the results should be retained as a 

record for 3 years after each qualification and re

qualification. 

"* Documentation of completion of training in re

sponse tactics by members of the tactical response 

team; the documentation should be retained as a 

record for 3 years after the training is completed. 

"* Results of tactical response team and guard exer

cises; such records should be retained for 3 years 

after each exercise is completed. 

5. PHYSICAL BARRIERS 

5.1 General Layout (10 CFR 73.46(c)(1)) 

This section should describe facility material ac

cess areas (and vital areas, if applicable) with regard to 

their locations and functions and, in general terms, 

should describe the spatial relationship between re

quired barriers at the protected area and material ac

cess areas. 

5.2 Protected Area Barriers (10 CFR 

73.45(f)(1)(i), 73.46(c)(1) and (2)) 

This section should identify the physical barriers 

(including entry/exit points during both opened and 

closed conditions) at the protected area boundary. 

This should include a physical description of the barri

ers and a discussion of the purpose of each barrier. 

5.3 Vehicle Barriers (10 CFR 73.45(O(1)(i) and 

73.46(c) (1)) 

This section should describe the location and 

placement of vehicle barriers about the protected area. 

A physical description of the barrier system should be 

included, along with information that substantiates that 

the barrier can adequately counter the design basis ve

hicle. Vehicle control at entry/exit points should also 

be described. 

5.4 Material Access Area Barriers (10 CFR 

73.45(b)(1)(i) and 73.46(c) (5) (iii)) 

This section should describe the level of physical 

hardening for the walls, floors, and ceilings of the dif

ferent types of material access areas at the site, for ex

ample, materials used and Underwriter's Laboratory 

hardening level, if appropriate. The number, location,

-5.52-4

I
and type of entry/exit portals should be described. 

Methods used to provide hardening of the portals 

(during opened and closed conditions) should be de

scribed. Hardening of ventilation ducts or other open

ings should also be described. 

5.5 Security Posts and Structures (10 CFR 

73.46(d) (4) (i)) 

This section should describe the location and pur

pose of all permanent security posts and structures. 

The physical construction of structures used as security 

posts should be described. 

5.6 Isolation Zones (10 CFR 73.46(c)(3)) 

This section should describe the location and size 

of all isolation zones at the facility. The section should 

affirm that the zones will be maintained clear of ob

stacles or structures. 

5.7 Illumination (10 CFR 73.46(c)(4)) 

This section should describe the lighting system at 

the facility that ensures necessary illumination for all 

required monitoring, observation, and assessment 

activities. 

5.8 Storage of Strategic Special Nuclear 

Material 

5.8.1 Vaults (10 CFR 73.46(c)(5)(i)) 

This section should describe the purpose of each 

vault located within the facility and the wall, floor, and 

ceiling construction of each vault. The location and 

type of entry portal to the vault should be described. 

5.8.2 Tamper-Indicating Containers (10 

CFR 73.46(c) (5) (ii)) 

This section should describe the construction and 

use of tamper-indicating containers in the storage of 

SSNM other than alloys, fuel elements, or fuel 

assemblies. 

5.8.3 Process Material Access Areas (10 

CFR 73.46(c)(5)(iii) and (iv)) 

This section should describe the purpose of each 

process material access area at the site and the pro

tection afforded SSNM (other than alloys, fuel ele

ments, or fuel assemblies) while within these material 

access areas. Both physical and procedural protective 

measures should be described. 

5.9 Storage of Enriched Uranium Scrap (10 CFR 

73.46(c) (6)) 

This section should describe the locations used for 

storage of enriched uranium scrap and the protection 

(physical and procedural) afforded these locations.

6. ACCESS CONTROL SUBSYSTEMS AND 

PROCEDURES 

6.1 Numbered Picture Badge Identification 

Systems (10 CFR 73.46(d)(1)) 

This section should describe the numbered picture 

badge identification system used at the facility. This 

description should include a discussion of procedures 

used for badging individuals with authorized unes

corted access to the protected area and for individuals 

not employed by the licensee but who require frequent 

and extended access to the protected area. Instruc

tions that badged individuals receive in proper badge 

procedures should also be described, along with proce

dures for control of nonbadged emergency response 

individuals during emergency situations. 

6.2 Access to Vital Areas, Material Access 

Areas, and Controlled Access Areas (10 CFR 

73.45(b)(2) and 73.46(d)(2)) 

This section should describe procedures for deter

mining an individual's need for access to a vital area, 

material access area, or controlled access area; proce

dures for the distribution and maintenance of lists of 

authorized individuals; procedures for ensuring the 

maintenance of the two-man rule within material ac

cess areas; and procedures for ensuring that no activi

ties other than those that require access to strategic 

special nuclear material or necessary maintenance are 

permitted within material access areas. This section 

should also describe methods used to visually identify 

individuals who have authorized unescorted access to 

vital areas, material access areas, or controlled access 

areas. This description should note differences in pro

cedures, if any, between working and nonworking 

hours (i.e., nights, weekends, and holidays) and nor

mal versus emergency conditions. 

6.3 Access Controls at the Protected Area 

6.3.1 Personnel (10 CFR 73.45(f)(1) and 

(2), 73.46(d)(4)(i) and (ii)) 

This section should describe how the licensee will 

control all points of personnel access into the pro

tected area, under both normal and emergency condi

tions. This description should include the methods 

used to identify individuals, methods used to verify in

dividuals' authorizations, methods used to verify emer

gency conditions, and procedures for conducting 

searches of individuals for firearms, explosives, and in

cendiary devices. Individuals exempted from any of 

the aforementioned access controls should be de

scribed. The distribution and maintenance of authori

zation lists should also be described.

5.52-5
6.3.2 Hand-Carried Packages (10 CFR 

73.45(f)(1) and (2), 73.46(d)(3) and 

(5)) 

This section should affirm that the licensee will 

establish and follow written procedures that will permit 

access-control personnel to identify materials in hand

carried packages that are not authorized entry to the 

protected area, during both normal and emergency 

conditions. Further, this section should describe 

procedures for searching hand-carried packages at 

personnel and vehicle access points for firearms, ex

plosives, and incendiary devices. The development, 

distribution, and maintenance of lists of authorized (or 

unauthorized) materials should be described. 

6.3.3 Delivered Packages (10 CFR 

73.45(f)(1) and (2), 73.46(d)(3) 

and (6)) 

This section should affirm that the licensee will es

tablish and follow written procedures that will permit 

access-control personnel to identify materials in deliv

ered packages that are not authorized entry to the 

protected area during both normal and emergency 

conditions. Further, methods used to check for proper 

identification and authorization should be described 

along with search procedures for firearms, explosives, 

and incendiary devices. Any activities exempted from 

the above procedures should be described. The devel

opment, distribution, and maintenance of authorized 

(or unauthorized) materials lists should be described. 

6.3.4 Vehicles (10 CFR 73.45(f)(1) and (2), 

73.46(d)(3), 73.46(d)(4)(i), 

73.46(d) (7), and 73.46(d) (8)) 

This section should describe procedures used for 

controlling all points of vehicle access (nonemergency 

and emergency) into the protected area and should de

scribe how written procedures are established and fol

lowed that will permit access-control personnel to 

identify vehicles that are authorized entry to the pro

tected area. The distribution and maintenance of these 

procedures should be described. Search procedures of 

all vehicles requiring entry to the protected area for 

firearms, explosives, and incendiary devices should 

also be described. Any vehicles exempted from the 

aforementioned procedures should be described. Pro

cedures used for escorting vehicles within the pro

tected area and areas where vehicles may have access, 

along with the purpose for the access, should be de

scribed. 

6.3.5 Designated Licensee Vehicle (10 CFR 

73.46 (d) (8)) 

This section should describe the control and use of 

designated licensee vehicles within the protected area.

6.4 Access Controls at Vital Areas, Material 

Access Areas, and Controlled Access Areas 

6.4.1 Personnel (10 CFR 73.45(b)(2) and 

73.46(d) (9)) 

This section should describe the methods used by 

the licensee to control all points of personnel access to 

material access areas, vital areas, and controlled ac

cess areas, including methods used to verify identifica

tion and authorization. Personnel exit searches from 

material access areas should also be described. 

6.4.2 Material (10 CFR 73.45(b)(2) and 

73.46(d) (9)) 

This section should describe procedures for verify

ing material entry authorizations and procedures for 

verifying quantity and type of material. This section 

should describe the procedures and equipment used to 

detect unauthorized materials that are hand-carried by 

authorized individuals or mailed or otherwise shipped 

as part of an authorized shipment. Describe how con

ditions differ between regular working hours and non

working hours (i.e., nights, weekends, and holidays). 

6.4.3 Vehicles (10 CFR 73.45(b)(2); 

73.46(d)(3) and (9)) 

This section should describe methods used to con

trol all points of vehicle access (e.g., under both non

emergency and emergency conditions) to material 

access areas, vital areas, and controlled access areas, 

including the establishment and maintenance of 

written procedures that will permit access control per

sonnel to identify those vehicles that are authorized 

entry to material access and vital areas. Vehicle exit 

searches should-also be described. 

6.5 Material Access Area Exit Search of 

Contaminated Waste (10 CFR 

73.46(d)(10) and (12)) 

This section should describe procedures and areas 

used for searching contaminated wastes coming from a 

material access area. 

6.6 Shipment of Strategic Special Nuclear 

Material Offsite (10 CFR 73.46(d) (11) 

and (12)) 

This section should describe containers and areas, 

as well as procedures, used for shipping strategic spe

cial nuclear material offsite. 

6.7 Escorts and Escorted Individuals (10 CFR 

73.46(d) (13)) 

This section should identify, by job function, those 

individuals who may be designated as escorts and de

scribe procedures used for escorting individuals during 

both routine and emergency situations. Such proce

dures should describe individuals requiring escort,

5.52-6
badging procedures, training that escorts receive, and 

recordkeeping. 

6.8 Keys, Locks, and Combinations (10 CFR 

73.46(d) (14)) 

This section should describe licensee procedures 

for controlling all keys, locks, combinations, and re

lated equipment used to control access to protected, 

material access, vital, and controlled access areas. 

The description should include the circumstances un

der which such keys, locks, etc., are changed and pro

cedures followed when an employee with access to 

such keys, locks, etc., terminates employment. 

6.9 Records (10 CFR 73.46(d)(3), (10), and 

(13)) 

This section should describe recordkeeping proce

dures for (1) current written procedures that permit 

access-control personnel to identify vehicles that are 

authorized and identify materials that are not autho

rized entry to protected, material access, and vital ar

eas, (2) findings of drum-scanning and tamper-sealing 

of containers of contaminated wastes coming from ma

terial access areas, and (3) the required log of escorted 

individuals. 

7. DETECTION, SURVEILLANCE, AND 

ALARM SUBSYSTEMS 

7.1 Isolation Zone Penetration (10 CFR 

73.45(f)(1)(ii) and 73.46(e)(1)) 

This section should describe licensee commit

ments for capabilities to detect penetration through re

quired isolation zones. Generic equipment types, along 

with associated detection capabilities, should be de

scribed. 

7.2 Emergency Exits (10 CFR 73.46(e)(2) and 

(5)) 

This section should describe the location of all 

emergency exits and describe the protection afforded 

them. 

7.3 Material Access Area and Vital Area Protec

tion (10 CFR 73.45(b)(1)(ii) and 73.46(e)(3)) 

This section should describe protection afforded 

(1) unoccupied vital and material access areas, (2) the 

location of strategic special nuclear material within 

process material access areas, and (3) vaults and pro

cess areas that contain strategic special nuclear materi

al that has not been alloyed or encapsulated, including 

a description of procedures for access to these particu

lar vaults and process areas. Generic equipment types 

used to provide this protection, along with associated 

detection capabilities, should be described.

7.4 Duress Alarms (10 CFR 73.46(e)(4)) 

This section should describe the security stations 

and individuals that are provided with duress alarms. 

The type of duress alarms used should be described. 

7.5 Central and Secondary Alarm Stations (10 

CFR 73.45(g) (5) and 73.46(e) (5)) 

This section should describe the location and con

struction of the central and secondary alarm stations. 

Methods used for annunciation of required alarms 

should be described, along with protection afforded 

the stations, both procedural and physical, so that a 

single act cannot remove the capability of calling for 

assistance or responding to an alarm. The licensee 

should affirm that the central alarm station will not 

contain any operational activities that would interfere 

with the execution of alarm response functions. 

7.6 Power Sources (10 CFR 73.46(e)(6)) 

This section should describe types of security 

equipment, including alarms, capable of being oper

ated from independent power sources, the duration of 

operation in the event of loss of normal power, and the 

indications given upon loss of normal power and 

switchover to standby power. This section should also 

affirm that switchover to standby power will be auto

matic and will not cause false alarms. 

7.7 Component Supervision (10 CFR 

73.46(e) (7)) 

This section should describe the physical protec

tion afforded to alarm systems, including transmission 

media, to ensure that the system is not being tampered 

with, compromised, or on standby power without the 

knowledge of the licensee. This section should de

scribe the annunciation systems at the alarm stations 

and commit the licensee to indicate the status of all 

alarms and alarm zones in the alarm stations. 

7.8 External Protected Area Monitoring and 

Assessment (10 CFR 73.45(c) and 

73.46(e) (8)) 

This section should describe methods used to 

monitor all exterior areas within the protected area 

and the duration or periodicity of such monitoring. 

Criteria used in defining authorized and unauthorized 

activities and conditions within the protected area 

should be described, along with methods for develop

ing, maintaining, and distributing lists of authorized ac

tivities and conditions. 

7.9 Observation Methods within Material Access 

Areas (10 CFR 73.46(e)(9)) 

This section should describe methods used to ob

serve individuals within material access areas to ensure 

that strategic special nuclear material is not moved to 

unauthorized locations or moved in an unauthorized

5.52-7
manner. The duration or periodicity of such monitor

ing should be described along with criteria used in 

defining authorized and unauthorized activities and 

conditions within the material access area. Methods 

for developing, maintaining, and distributing lists of 

authorized activities and conditions should be 

described. 

8. COMMUNICATIONS SUBSYSTEMS 

8.1 Security Force Communications (10 CFR 

73.45(g) (4) and 73.46(f) (1)) 

This section should describe how each guard, 

watchman, or armed response individual on duty will 

be capable of maintaining continuous communications 

with the individual in each continuously manned alarm 

station. This section should also describe how the indi

vidual in each continuously manned alarm station will 

be capable of calling for assistance from other guards, 

watchmen, and armed response personnel and from 

law enforcement authorities. 

8.2 Alarm Station Communications (10 CFR 

73.46(f) (2)) 

This section should describe the redundant sys

tems used to ensure the capability of communications 

with the local law enforcement authority. 

8.3 Power Sources (10 CFR 73.46(0(3)) 

This section should describe methods used by the 

licensee to keep nonportable communications equip

ment controlled by the licensee operable in the event 

of loss of normal power. 

9. TEST AND MAINTENANCE PROGRAMS 

9.1 Installation and Construction Tests (10 CFR 

73.46(g) (1)) 

This section should describe the testing and in

spection program for (1) intrusion alarms, (2) emer

gency exit alarms, (3) communications equipment, (4) 

physical barriers, and (5) other physical-protection

related devices and equipment, used pursuant to 10 

CFR 73.46, during the installation and construction of 

the physical protection subsystems and components. 

This description should also include the purpose for 

and the intended level of the testing and inspection 

program. 

9.2 Pre-Operational Tests (10 CFR 73.46(g)(2)) 

This section should describe the testing and in

spection program for (1) intrusion alarms, (2) emer

gency exit alarms, (3) communications equipment, (4) 

physical barriers, and (5) other physical-protection

related devices and equipment, used pursuant to 10 

CFR 73.46, within the pre-operational time frame (after initial installation, but before full-time operation). 

This description should include the purpose for and 

the intended level of the testing and inspection pro

gram. 

9.3 Operational Tests (10 CFR 73.46(g)(3)) 

This section should describe the testing and main

tenance program for (1) intrusion alarms, (2) emer

gency exit alarms, (3) communications equipment, (4) 

physical barriers, and (5) other physical-protection

related devices and equipment, used pursuant to 10 

CFR 73.46, during routine operation. This description 

should include the purpose for and the intended level 

of the testing and maintenance program. In addition, 

specific methods for testing each type of equipment 

should be included in the description, along with perio

dicity of testing. 

9.4 Preventive Maintenance Programs (10 CFR 

73.46(g)(4) and (5)) 

This section should describe the preventive main

tenance program established to ensure that all 

physical-protection-related subsystems and compo

nents are maintained in operable and effective condi

tion. This section should also describe corrective ac

tions or compensatory measures used in the event of 

component failure within physical protection systems. 

9.5 Repairs and Maintenance (10 CFR 

73.46(g) (5)) 

This section should describe procedures used in 

performing repairs and maintenance of physical pro

tection systems. 

9.6 Reviews and Audits (10 CFR 73.46(g)(6)) 

This section should describe the applicant's review 

and audit of the security program. This description 

should include the periodicity of the review and audit, 

a description of who will conduct the review and audit, 

items covered by the review and audit, how the review 

and audit will be documented, to whom the review and 

audit documentation will be provided for review, and 

the recordkeeping associated with the review and 

audit. 

10. CONTINGENCY RESPONSE PLANS AND 

PROCEDURES 

10.1 Contingency Plan Documentation (10 CFR 

73.45(g)(2) and 73.46(h)(1)) 

This section should affirm that the licensee will 

have an approved safeguards contingency plan for 

dealing with threats, thefts, and radiological sabotage 

related to the strategic special nuclear material and nu

clear facilities subject to 10 CFR 73.46. These plans 

should be developed in accordance with the criteria in 

Appendix C to Part 73 and should cover, but not nec5.52-8

L1
essarily be limited to, the response requirements of 10 

CFR 73.46(h) (2) through (h)(5). 

10.2 Local Law Enforcement Agency Liaison (10 

CFR 73.46(h)(2)) 

This section should describe the documented re

sponse arrangements that the applicant has made with 

local law enforcement agencies. It should also include 

estimated response times. 

10.3 Tactical Response Force (10 CFR 

73.46(h) (3)) 

This section should describe the number of tacti

cal response team members immediately available for 

response and the duties they will be assigned. In addi

tion, the required force of guards or armed responders 

available to assist the tactical response team should be 

described, along with a discussion of the rationale for 

determining the number of individuals in this force of 

guards or armed responders and the availability of this 

force. 

10.4 Response Procedures (10 CFR 73.45(g)(1) 

and 73.46(h) (4)) 

This section should describe the applicant's re

sponse procedures for dealing with detection of abnor

mal presence or activity of persons or vehicles within 

an isolation zone, a protected area, a material access 

area, or a vital area or evidence or indication of intru

sion into a protected area, a material access area, or a 

vital area. Methods for assessing the threat and neu

tralizing the threat should be described. 

10.5 Use of Force (10 CFR 73.46(h)(5)) 

This section should describe the instructions that 

guards and armed responders will receive in the use of 

force in the prevention or impeding of theft of strategic 

special nuclear material. 

10.6 Protected Area Alarm Assessment (10 CFR 

73.46(h) (6) 

This section should describe methods used for 

providing assessment of all protected area alarms. 

10.7 Unoccupied Vault and Material Access 

Area Alarm Assessment (10 CFR 

173.46(h) (7)) 

This section should describe methods used for as

sessing alarms occurring within unoccupied vaults and 

unoccupied material access areas containing unalloyed 

or unencapsulated strategic special nuclear material.

10.8 Unoccupied Material Access Area (Alloyed/ 

Encapsulated Strategic Special Nuclear 

Material) Alarm Assessment (10 CFR 

73.46(h) (8)) 

This section should describe methods used for as

sessing alarms occurring within unoccupied material 

access areas that contain only alloyed or encapsulated 

strategic special nuclear material. 

10.9 Records (10 CFR 73.46(h)(1) and (2)) 

This section should describe how the licensee will 

establish, maintain, and retain as a record the current 

safeguards contingency plan. Until the Commission 

terminates the license, if any portion of the plan is su

perseded, the licensee should retain the superseded 

portion for 3 years after the date of the change. This 

section should also describe the licensee's records of 

agreements with local law enforcement agencies. 

11. AUTHORIZED PLACEMENT AND 

MOVEMENT OF STRATEGIC SPECIAL 

NUCLEAR MATERIAL WITHIN 

MATERIAL ACCESS AREAS 

11.1 General (10 CFR 73.45(d)) 

This section should describe the purpose and ob

jective of the measures used to control movement and 

placement of strategic special nuclear material. 

11.2 Establishment of Authorized Placement and 

Movement of Strategic Special Nuclear 

Material (10 CFR 73.45(d) (1) (i) and (iii)) 

This section should describe the criteria to be used 

to delineate the authorized placement and movement 

of strategic special nuclear material within each materi

al access area. For each material access area, the loca

tions within the material access area for which the 

placement and movement of the strategic special nu

clear material are to be authorized should be provided. 

The development, maintenance, and distribution of 

schedules of authorized placement and movement of 

strategic special nuclear material should also be de

scribed. 

11.3 Establishment of Current Knowledge of 

Strategic Special Nuclear Material (10 CFR 

73.45(d)(1)(i) and (ii)) 

This section should describe, for each material ac

cess area, the components to be used to verify the 

type, quantity, and location of strategic special nuclear 

material within the material access area. Procedures 

and frequency of activities used to monitor or verify 

the location of strategic special nuclear material should 

be described. 

11.4 Prevention of Unauthorized Placement and 

Movement of Strategic Special Nuclear 

Material (10 CFR 73.45(c) and 

73.45 (d) (1) (iv)) 

This section should describe the measures to be 

used to detect the unauthorized placement and move5.52-9
ment of strategic special nuclear material within each 

material access area. Also, the containment of strate

gic special nuclear material, when the material is be

tween the vault and process machinery, should be de

scribed. 

12. REMOVAL OF STRATEGIC SPECIAL 

NUCLEAR MATERIAL THROUGH 

MATERIAL ACCESS AREA PORTALS 

12.1 Development of Authorization Procedures 

for Removal (10 CFR 73.45(e)(2)(i) and 

(0)) 

This section should describe how authorization 

procedures for removal are developed. It should also 

describe how lists of authorized personnel are to be 

developed, distributed, and maintained. 

12.2 Procedures and Controls for Strategic 

Special Nuclear Material Removal 

(Including Scrap and Waste) (10 CFR 

73.45 (e) (2)) 

This section should describe how the identification 

and authorization of each person presenting strategic 

special nuclear material for removal from a material 

access area are to be verified. The confirmation of ver

ification of authorization, type, and quantity of strate

gic special nuclear material should also be described.

Further, this section should describe the components 

to be used to detect unauthorized removal of strategic 

special nuclear material. The components to be used 

to deter unauthorized attempts to remove strategic spe

cial nuclear material from material access areas should 

be described. Procedures and controls should be dis

cussed for both normal conditions (e.g., regular work

ing hours and nonworking hours) and emergency con

ditions. Procedures used to verify that an emergency 

condition exists should be described. 

13. COMPENSATORY MEASURES FOR 

PHYSICAL PROTECTION COMPONENTS 

(APPENDIX A) 

This section should describe (in generic terms) 

compensatory measures to be taken in the event of a 

failed or degraded component of the physical protec

tion system. (This section may be an appendix to the 

physical protection plan, if desired.) 

14. SPECIAL SITUATIONS OR CONDITIONS 

AFFECTING PHYSICAL PROTECTION 

(APPENDIX B) 

This section should describe long-term, site

specific unique situations not covered by the main 

body of the physical protection plan (e.g., decommis

sioning activities). (This section may be an appendix to 

the physical protection plan, if desired.)

5.52-10
REGULATORY ANALYSIS 

A separate regulatory analysis was not performed for this regulatory guide. The regulatory 

analysis prepared for amendments to 10 CFR 73.46 in 1988 provides the regulatory basis for this 

guide and examines the costs and benefits of the rule (as implemented by the guide.) A copy of 

this regulatory analysis is available for inspection and copying for a fee at the NRC Public Docu

ment Room, 2120 L Street NW., Washington DC, as Enclosure E to Secy 88-250.

5.52-11
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