UNITED STATES 

.,A NUCLEAR REGULATORY COMMISSION r •WASHINGTON, D. C. 20555 

July 7, 1980 

Regulatory Guide 5.61 

.REGULATORY GUIDE DISTRIBUTION LIST (DIVISION 5) 

SUBJECT: Regulatory Guide 5.61, "Intent and Scope of the Physical 

Protection Upgrade Rule Requirements for Fixed Sites" 

Regulatory Guide 5.61 is being issued as an active guide. The information 

that provided the basis for the preparation of the guide was distributed 

for comment as a draft report to all affected licensees and to other 

interested parties who attended the NRC Upgrade Rule Guide Seminar held on 

March 27-28, 1979, in Richmond, Virginia. No comments were received as a 

result of this distribution. The resulting active guide is being issued 

so that affected licensees may use it for preparation of their physical 

protection plans in response to the new requirements of 10 CFR Part 73 

published in the Federal Register on November 28, 1979 (44 FR' 68184). 

Since a draft guide was not distributed for comment, copies of this active 

guide are being sent to all addressees on the Division 5 distribution list. 

Although comments are always encouraged on all regulatory guides, comments 

on this guide are particularly encouraged at this time since a draft guide 

for comment was not published. 

Robert B. Minogue, Dir tor 

Office of Standards Development

.II
June 1980

U.S. NUCLEAR REGULATORY COMMISSION 

bREGULATORY GUIDE 

OFFICE OF STANDARDS DEVELOPMENT 

REGULATORY GUIDE 5.61 

INTENT AND SCOPE OF THE PHYSICAL PROTECTION UPGRADE RULE 

REQUIREMENTS FOR FIXED SITES

A. INTRODUCTION 

On November 28, 1979, strengthened physical protection 

requirements for fuel cycle facilities and transportation 

involving formula quantities of strategic special nuclear 

material were published in the Federal Register (44 FR 68184). 

The "Physical Protection Upgrade Rule" is the short title 

for these requirements. This guide provides information to 

assist in understanding the physical security requirements 

for, fuel cycle facilities set forth in §§ 73.1, 73.20, 73.45, 

and 73.46 of the Physical Protection Upgrade Rule. Section 

B, "Discussion," provides an overview of the major sections 

of the rule and discusses (1) how the Physical Protection 

Upgrade Rule is structured, (2) what the purposes of its 

major provisions are, and (3) what interrelationships exist 

among the three major portions of the rule that contain 

requirements for the physical protection of fixed sites. 

Section C, Regulatory Position, attempts, by means of a 

question and answer format, to explain, why certain fixed 

site requirements are included in the rule and to clarify the 

intent of these requirements. 

B. DISCUSSION 

This section is intended to give the reader a broad 

overview of the structure of the Physical Protection Upgrade 

Rule as it applies to fixed sites and the purpose of Its major 

provisions. A review of the threat statement is included. 

The Physical Protection Upgrade Rule is structured in three 

distinct levels; two are essentially performance oriented and 

the third, a reference physical protection system, is specifica

tion oriented. 

L. Purpose and Scope: § 73.1 (Threat Statement) 

Paragraphs 73.1(aX)) and (aX2) describe the types of 

threats against which the physical protection system must 

be effective. Distinctions are made between the overall 

protection level to be provided against radiological sabo

tage and that required against theft or diversion of SSNM.

For radiological sabotage, two basic adversary types are 

defined. The first is an external assault by several persons in 

which the attackers are assumed to be well armed, well trained, 

and able to obtain inside help. The second postulated adver

sary is a single insider who may be employed in any posi

tion and who may have an NRC or DOE security clearance. 

For theft or diversion, the basic external assault threat is 

similar to that for radiological sabotage, except that the 

adversaries are assumed to be capable of operating as two or 

more teams. The internal theft or diversion threat is mark

edly different from that for radiological sabotage in that it 

also includes a conspiracy among individuals either with 

access to and knowledge of facilities and activities or 

equipped with items that could facilitate theft of material 

subject to this rule. 

2. General Performance Objective and Requirements: Para

graphs 73.20(a) and (b) 

The general performance objective and requirements are 

referenced to the threat statements of § 73.1, wherein 

appropriate design basis threats for protecting against 

radiological sabotage and preventing theft of special nuclear 

material are specified. 

Paragraph 73.20(a) is the fuist of the two performance

oriented levels and sets forth the rule's basic parameters. 

This paragraph states who is covered by these regulations; 

i.e., licensees authorized to operate fuel reprocessing plants 

pursuant to 10 CFR Part 50, licensees who operate facilities 

that possess or use formula quantities of strategic special 

nuclear materials, and licensees involved in the transport or 

delivery of formula quantities of strategic special nuclear 

material, including import and export. On an interim basis, 

non-power reactors are not subject to the Physical Protection 

Upgrade Rule requirements. It further states that those 

covered by these regulations must establish and maintain or 

make arrangements for a physical protection system which

USNRC REGULATORY GUIDES Comments ihould be sent to the Secretary of the Commission, 

U.S. Nuclear Regulatory Commission Washington, D.C. 20555. 

Regulatory Guides are Issued to describe and Make available to the Attention: Docketing and Service Branch. 

public methods acceptable to the NRC staff of implementing 

apecific parts of the Commlsslon's regulations, to delineate tech- The guides are Issued In the following ten broad divisions: " 

nlques used by the staff In evaluating specific problems or postu

lated accidents or to provide guidance to applicants. Regulatory 1. Power Reactors 6. Products 

Guides are noW substitutes for regulations, and compliance with 2. Research and Test Reactors .7. Transportation 

them Is not required. Methods and solutions different from those set 3. Fuels and Materials Facilities 6. Occupational Health 

out in the guides will be acceptable if they provide a basis for the 4. Environmental and Siting 9. Antitrust and Financial Review 

findings requisite to the issuance or continuance of a permit or 5. Materials and Plant Protection 10. General 

license by the Commiession. Copies of Issued guides may be purchased at the current Government 

Comments and suggestions for improvements in these guides are Printing Office price. A subscription service for future guides In •pe

encouraged at all times, and guides will be revised, as appropriate. cific divisions Is available through the Government Printing Office. 

to accommodate comments and to reflect new information or Information on the subscription service and current GPO prices may 

experience. This guide was revised as a result of su.btantive corn- be obtained by writing the U.S. Nuclear Regulatory Commission, 

ments received from the public and additional Staff review. Washington, D.C. 20555, Attention: Publications Sales Manager.

I I
will have as its objective to provide high assurance that 

activities involving special nuclear material are not inimical 

to the common defense and security and do not constitute 

an unreasonable risk to the public health and safety. 

Paragraph 73.20(b) describes how licensees covered by 

these regulations are to provide effective physical protection 

systems meeting the general performance objective of 

paragraph (a) of section 73.20. To meet the general perform

ance objective, a licensee must establish and maintain or 

arrange for a physical protection system. That physical 

protection system must include the characteristics defined 

in paragraphs (b)(1) through (b)(3), which require that the 

physical protection system (1) provide the performance 

capabilities of section 73.45, (2) be designed with redundancy 

and diversity, and (3) include a testing and maintenance 

program as described therein. 

3. Performance Capabilities for Fixed Site Physical Protec

tion: § 73.45 

Paragraph 73.20(bX 1) provides a direct link between the 

general performance requirements and the performance 

capabilities that comprise the second of the performance

oriented levels. This paragraph states that, in order to meet 

the general performance requirements of paragraph 73.20(a), 

a licensee must establish and maintain or arrange for a 

physical protection system that provides the performance 

capabilities described in § 73.45 for fixed site protection 

unless otherwise authorized by the Commission. Thus, a 

physical protection system must be designed to satisfy the 

performance capabilities in order to meet the objective of 

providing high assurance of preventing the theft of SSNM 

and protecting against radiological sabotage by the previously 

described adversaries. 

Because the adversary may consist of insiders operating 

alone or in combination with persons without authorized 

access, the adversary is able to initiate his activities inside as 

well as outside the facility. In order to provide the required 

level of assurance, the physical protection system must 

be able to detect, assess, and respond to unauthorized acts 

initiated at any point outside or inside the facility. The 

performance capabilities necessary to provide assurance 

that the act will be prevented may, therefore, be viewed 

as a series of four protection layers that detect and respond 

to an unauthorized act initiated at any point. 

Starting from the facility perimeter and working inward, 

the first protection layer consists of the performance 

capability delineated in paragraph 73.45(f), which is to 

provide for authorized access and assure detection of and 

response to unauthorized penetrations of the protected 

area. This performance capability is the first line of defense 

against external groups, but does not provide protection 

against persons or material with authorized access to the 

facility. The second protection layer is the performance 

capability delineated in paragraph 73.45(b), which is to 

prevent umauthorized access of persons and materials into 

material access areas and vital areas. This performance 

capability denies unauthorized access to a material access 

area or a vital area but is still not effective against adversaries

with authorized access to a material access area or a vital 

area. This problem is addressed by the third layer of perform

ance capabilities delineated in paragraph 73.45(c) which 

requires that the physical protection system permit only 

authorized activities and conditions within protected areas, 

material access areas, and vital areas, and paragraph 73.45(d) 

which requires that the physical protection system permit 

only authorized placement and movement of strategic 

special nuclear material within material access areas. These 

two performance capabilities ensure that, even in cases in 

which the adversary is authorized access to material access 

areas or vital areas and is authorized to handle and move 

SSNM, the physical protection system will be capable of 

detecting the unauthorized adversary act and initiating an 

effective response. The fourth protection layer permits the 

removal of only authorized and confirmed forms and 

amounts of strategic special nuclear material from material 

access areas (paragraph 73.45(e)). 

The final performance capability [paragraph 73.45(g)] 

is that the physical protection system must provide a 

response capability to assure that the five capabilities 

described in paragraphs (b) through (f) of § 73.45 are 

achieved. In cases where the adversary initiates action 

outside the facility or in the facility's protected areas, he 

will face redundant protection in the several layers of 

performance capabilities remaining between him and his 

objective. But, again, the primary purpose for this layering 

of performance capabilities is to ensure that an unauthorized 

act by an adversary will be detected as soon as it is initiated, 

regardless of who the adversary is or where within the 

facility he is located. 

The proper implementation of these performance 

capabilities will provide the desired high assurance that the 

physical protection system can prevent the theft of strategic 

special nuclear material and protect against radiological 

sabotage by any of the postulated adversaries at any given 

time. 

4. Fixed Site Physical Protection Systems, Subsystems, 

Components, and Procedures: § 73.46 (Reference 

System) 

Regulatory guidance to assist in ensuring the proper 

implementation of the performance capabilities identified 

in § 73.45 in the design of a physical protection system are 

contained in § 73.46 and constitute the third major level of 

the Physical Protection Upgrade Rule. Section 73.46 delineates 

those safeguards measures that usually will be included in a 

physical protection system that satisfies the performance 

capability requirements. In order to clarify the relationship 

between the reference system in § 73.46 and the perform

ance capabilities in § 73.45, Table I has been developed. 

This table is organized by performance capability, with 

each capability function and subfunction designated in the 

rule as necessary to achieve that performance capability 

listed as a separate column heading. Under each heading are 

listed all the provisions from the reference system (§ 73.46) 

that fulfill some portion of that function or.subfunction. 

The table shows how the reference system may be used to 

provide the functions or subfunctions necessary to each

5.61-2

K.
performance capability and thus to achieve each performanc 

capability itself. The table provides several types of informi 

tion on how safeguards measures can be used to help satisf 

a required function or subfunction. In providing thi 

information, various situations must be considered. Fc 

fixed sites, the reference system must consider situationi 

and timing differences (for example, working hours versu 

non-working hours). 

The column headed by paragraph 73.45(bX2)(ii) provide 

an example. This paragraph deals with entry controls an 

procedures for the detection of attempts to gain unauthc 

rized access into material access areas and vital areas b 

deceit. The paragraphs from the reference system tha 

comprise the body of the column contain components an 

measures for dealing with entry attempts by employee: 

non-employees requiring frequent access, visitors, individual 

with NRC or DOE material access authorizations, vehicle: 

and materials. There are also safeguards measures listed fc 

key, lock, and combination control and for communici 

tions. Thus, the reference system contains different ways c 

providing these subfunctions of the performance capabilit 

under different circumstances. Some of the activitie: 

equipment, and design features needed to provide 0h 

functions and subfunctions are not time sensitive (that i 

they must be in effect or be operational at all times 

Physical barriers, for-example, are not the type of safeguard 

measure that needs to be effective only at certain time 

To provide this same high assurance of protection ovr 

time, paragraph 73.20(b) of the general performanc 

requirements, contains two additional requirement 

redundancy and diversity and testing and maintenanco 

5. Redundancy and Diversity: Paragraph 73.20(bX2) 

Paragraph 73.20(b)(2) requires that the physical prote, 

tion system be designed with sufficient redundancy an 

diversity to assure maintenance of the capabilities describe 

in section 73.45. To provide protection against the failuj 

of physical protection system measures that would cause 

performance capability not to be satisfied, the system mu: 

be designed with redundancy and diversity. That is, redunday 

and diverse means of providing functions or subfunctioi 

must be included to ensure that no single adversary act ( 

no single safeguards-measure failure will cause the overa 

system to fail. Redundancy means providing more than or 

measure (which may be the same measure duplicated) I 

perform a given function or subfunction. Diversity meai 

providing two or more different kinds of measures that a 

perform or contribute to the same function or subfunctic 

but that have different operating characteristics (such 

sensitivities, failure modes, strengths, and weaknesses 

Table I is useful in clarifying the role of redundancy an 

diversity in the physical protection system. Paragraph 73.46(g)( 

of the reference system implies that redundancy and dive 

sity are not required everywhere, but only i those cases 

which the effectiveness of the physical protection systei 

would be compromised by failure or other contingencie 

As stated in paragraph 73.20(b), this means that the physic 

protection system must be designed with sufficient redu:

e dancy and diversity to assure maintenance of the capabilities 

t- described in § 73.45. In terms of information provided by 

y the table, this means that components providing redundancy 

[s and diversity will not be found in every column, but only in 

or those in which the criteria of the reference system makes 

al their inclusion warranted. Thus, in providing the functions 

is and subfunctions of the performance capabilities as shown 

through the columns on the table, guidance is given showing 

the usual level for redundancy and diversity needed to 

3s satisfy paragraph 73.20(b)(2). 

d 

- 6. Testing and Maintenance: Paragraph 73.20(bX3) 

y 

it Paragraph 73.20(bX3) requires the physical protection 

d system to include a testing and maintenance program to 

S, assure control over all activities and devices affecting the 

Is effectiveness, reliability, and availability of the physical 

s, protection system, including a demonstration that any 

or defects of such activities will be corrected for the total 

a- period of time, they are required as a part of the physical 

of protection system. This requirement is intended to ensure 

y that all procedures and hardware will remain effective, 

s, reliable, and available at all times. This requires programs to 

[e promptly detect any defects and to correct them in a 

s, timely manner. It also requires a program to provide 

). alternative measures to replace the capabilities lost while 

Is the maintenance and repair is being accomplished. 

S. 

Testing and maintenance that normally will be included 

er in a system providing the capabilities required by paragraph 

Ce 73.20(bX3) are described in paragraph 73.46(g) of the 

s, reference system. In order to ensure that required perform

e. ance capability functions or subfunctions are performed, 

the reference system provides guidance for a testing and 

maintenance program. The purpose of any testing and 

maintenance program should be to ensure continued 

C- operation of the safeguards measures that are used to 

d provide those functions or subfunctions. 

d 

re Table I delineates reference system maintenance provi

a sions corresponding to the appropriate performance capa

st bilities of § 73.45. 

it 

is Q REGULATORY POSITION 

or 

ill This section provides the rationale for and clarifies the 

le intent of particular requirements for fixed sites in the 

Vo Physical Protection Upgrade Rule. 

is 

1l § 73.1 Purpose and Scope (Threat Statement) 

on 

as Q: Is there more concern for theft of SNM than for 

). radiological sabotage? 

Ld A: The threat statements reflect the position that there 

5) is a greater risk to the public from theft of SNM at a fuel 

r- cycle facility than from radiological sabotage because of the 

in type and form of SNM actually located at existing fuel 

m cycle facilities. Therefore, it is necessary for licensees' 

s. physical protection systems to provide a level of assurance 

al that is consistent with the higher potential damage to the 

n- national security and public health and safety. 

5.61-3

I I
TABLE I

RELATIONSHIP BETWEEN THE FIXED SITE PERFORMANCE CAPABILITIES (§ 73.45) 

AND THE FIXED SITE PHYSICAL PROTECTION REFERENCE 1EASURES (6 73.46) 

73.45(b) 

(b) Prevent unauthorized access of persons, vehicles, and 

materials Into material access areas and vital areas. To achieve 

this capability the physical protection system shall:

(1) Detect attempts to gain unauthorized access or Introduce unauthorized 

material across material access or vital area boundaries by stealth or force 

using the following subsystems and subfunctions:

(2) Detect attempts to gain unauthorized access or Introduce unauthorized 

materials into material access areas or vital areas by deceit using the follow

Ing subsystems and subfunctions:

(i) Barriers to channel persons and 

material to material access and vital area entry control points and to delay 

any unauthorized penetration attempts 

by persons or materials sufficient to 

assist detection and permit a response 

that will prevent the penetration; and 

73.46 c 1 

g I 

g 2 

g 3 

g 4

( N

(Ii) Access detection subsystems and 

procedures to detect, assess and com

municate any unauthorized penetration 

attempts by persons or materials at 

the time of the attempt so that a 

response can prevent the unauthorized access or penetration. 

73.46(c)(41 g)(2 

9) g )3 

eS h 4(i) 

e7 h 4() 

1f1118 h 4 i 

f h5 

f 2 h 6 

f 3

(I) Access authorization controls and 

procedures to provide current authori

zation schedules and entry criteria 

for both persons and materials; and 

73.469d11

(ii) Entry controls and procedures to 

verify the Identity of persons and 

materials and assess such Identity 

against current authorization schedules 

and entry criteria before permitting 

entry and to initiate response measures to deny unauthorized entries. 

73.46(d)(1) 

(d)(2) 

d)(3) 

d) (9) 

d)(14) 

f 111 

g 16)

C I-ý

0%
K

(i) Controls end procedures that establish 

current schedules of authorized activities 

and conditions in defined areas; 

73.461dli]

(ii) Boundaries to define areas within 

which the authorized activities and condi

tions are permitted; and 

73.46(c€)1) c€)2)

(111) Detection and surveillance subsystems 

and procedures to discover and assess unauth

orized activities and conditions and coumln

cate them so that response can be such as to 

stop the activity or correct the conditions 

before strategic special nuclear material is 

stolen or radiological sabotage committed.

73.461 43) 

8) 

10) 

12i 11i) 

Ii) 

lii)

TABLE 1 (COTITUED) 

73.45(c) 

(c) Permit only authorized activities and conditions within protected 

areas, material access areas, and vital areas. To achieve this capability 

the Physical protection system shall: 

(1) Detect unauthorized activities or conditions within protected 

areas, material access areas and vital areas using the following subsystems "and subfunctions:

!_J1
TABLE 1 (CONTINUED) 

73.45Ud) 

(d) Peruit only authorized placement and movement of 

strategic special nuclear material within material access areas. To achieve this capability the physical protection system shall: 

(1) Detect unauthorized placement and movement of.strategic 

special nuclear material within the material access area using 

the following subsystems and subfunctions:

(i) Controls and procedures to delineate 

authorized placement and control for 

strategic special nuclear materiel;

73.46(c€ll) d II1 

(g)6)

r

(i11) Controls and procedures to 

establish current authorized place

ment and movement of all strategic 

special nuclear material within 

material access areas;

73.461C

1151

(III) Controls and procedures to main

tain knowledge of the identity, quantity. 

placement, and movement of all strategic 

special nuclear material within material access areas; and

73/461c

(iv) Detection and monitoring sub

system and procedures to discover 

and assess unauthorized placement 

and movement of strategic special 

nuclear materiel and comunicate them 

so that response can be such as to 

return the strategic special nuclear 

material to authorized placement or 

control. 

73.46(c)(5) (g)(1) 

c61 (g 2) 

1 h hll 4 4 7 11) ) f 2 h4 11,,) (f(31 (h)57)

C
K'

(1) Detect attempts at unauthorized[ removal of strategic special nuclear material from material access areas by steel th or 

force using the following subsystems and subfunctions: 

Mi Barriers to channel persons (ii) Detection subsystems and 

and materials exiting a material procedures to detect, assess 

access area to exit control points and communicate any attempts 

and to delay any unauthorized at unauthorized removal of 

strategic special nuclear material strategic special nuclear ma

removal attempts sufficient to terial so that response to 

assist detectiom and assessment the attempt can be such as 

and permit a response that will to prevent the removal. 

prevent the removal - and

-J

(2) Confirm the identity and quantity of strategic special nuclear material presented for 

removal from a material access area and detect attempts at unauthorized removal of strategic special 

nuclear material from material access areas by deceit using the following subsystems and subfunctions: 

MI Authorization controls and (Ii) Removal controls and pro- (1ii) Co~mmunications subsystems 

procedures to provide current cedures to identify and confirm and procedures to provide for 

schedules for authorized removal the properties and quantities notification of an attempted 

of strategic special nuclear of material being removed and unauthorized or unconfirmed 

material which specify the autho- verify the identity of the per- remval so that response can 

rized properties and quantities sons making the removal and be such as to prevent the 

of material to be removed, the assess these against the current remoVal. 

persons authorized to r.nve the authorized removal schedule be

material, and authorized time fore permitting removal; and 

schedule;

73.46 e(5) (g (5 

e7 h4(ji) 

f11 I h j ' 

TABLE 1 (caiTIRMiD) 

73.45(e) 

(e) Permit removal of only authorized and confirmed forms and amounts 

of strategic special nuclear material from material access areas. To achieve 

this capability the physical protection system shall:

73.46(c)(1) 73.46 73.46(g)(6) 19 

10) 

12) 

13 

16 

'7 

1 

ý2 

'31

73.46 d 1 

g 6)
TABLE I (CONTINUED) 

73.45(f) 

(f) Provide for authorized access and assure detection of and response to unauthorized penetrations of the protected area to prevent theft of strategic special nuclear material and to protect against radiological sabotage. To 

achieve this capability the physical protection system shall:

(1) Detect attempts to gain unauthorized access or introduce 

unauthorized persons, vehicles, or materials Into the protected area by stealth or force using the following subsystem and 

subfunctions:

(2) Detect attempts to gain unauthorized access or introduce unauthorized persons, vehicles. and materials into the proteAted area by deceit using the following subsystems and subfunctions:

(I) Barriers to channel persons, vehicles, 

and materials to protected area entry con trol points; and to delay any unauthorized 

penetration attempts or the introduction 

of unauthorized vehicles or materials suf

ficient to assist detection end assessment 

and permit a response that will prevent the penetration or prevent such penetra tion from resulting In theft of strategic 

special nuclear material or radiological 

sabotage; and 

73.461c I 

Ic 2 e. 6 I. 7 

Ih I1 Ih 2 

Ih 3 

fhi61

(ii) Access detection subsystems and pro

cedures to detect, assess and comunicate 

any unauthorized access or penetrations or such attempts by persons, vehicles, or materials at the time of the act or the 

attempt so that the response can be such as to prevent the unauthorized access or penetration, or prevent such penetration 

from resulting in theft of strategic 

special nuclear material or radiological 

sabotage.

73.46

I)

uu'

(

(i) Access authorization controls and pro

ceduros to provide current authorization 

schedules and entry criteria for persons. vehicles, and materials; and 

73

.

46 111u1

(1i) Entry controls and procedures to 

verify the identity of persons, materials, 

and vehicles and assess such identity against current authorization schedules 

before permitting entry and to initiate 

response measures to deny unauthorized access. 

73.46 

b 

d 6) 

~ f f~l 2 

f 311

C £

U,
TABLE I (CONTInED) 

73.45() 

(g) Response. Each physical protection program shall provide a response capability 

to assure that the five capabilities described In paragraphs (b) through (f) of this 

section are achieved end that adversary force will be engaged and Impeded until offslta 

assistance forces arrive. To achieve this capability a licenseeashall: 

(1) Establish a security organization to: (2) Establish a predetermined (3) Provide equipmet for the security organization and facility design 

plan to respond to safeguards features to: contingecy events. 

(1) Provide trained and (00) Provide for routine .(I) Provide for rapid (00) Provide for response by (Mii) Provide protection 

qualified personnel to security operations and assessment of safeguards assigned security organization for the assessment and 

carry out assigned duties planned and predetermined continogences; personel which is sufficient- response personnel so that 

and responsibilities; and response to emergencies and ly rapid and effective to they can complete their 

safeguards contingencies. achieve the predetermined assigned duties. 

objective of the response; and 

73.461b 1l 73.461bl 1 73.461bi3i 73.46 a 1 73.46 b 1 73.46 b 1 

b4b296a Z b 4 b 4 

h 33he3 1 g I 

ha 6e4 g2 g 2 

h3a 3g 3 

6 g4 g 4 a 7 g5 g 5 

g 6 6 

e9 h 3 I~ 2 il)lIl~ gC 4 h 5 

g5 h 7 

g6 

h 6 

(4) Provide coemuications netorks to: (S) Assure that a single adversary action cannot 

destroy the capability of the security organization to 

notify offsite response forces of the need for 

assistance. 

1i) Transmit rapid aend accurate security (11) Transmit rapid and accurate 

formetion amon onsite forces for routine detection and assessment Infor

security operation, assessment of a contin- mtion to offsIte forces. 

gency, and response to a contingency; and 

73.46 f 1 73.46 f 2 73.46 b 5~ f 2 f3 a 41 

fh3 9l 1 S5 

q 1g92 g 11 

9 2 g 3 4g 21 

g 3 g 4 Ig 31 

g 4 g 5 Ig 41 

gh 161 hh161
Q: Is there any reason why the number of adversaries 

has not been specified? 

A: Yes. Threat analysis has shown that basing defense 

capabilities on a predetermined number of postulated 

adversaries can be misleading. Given the dynamic nature of 

the threat and the significance of behavior as well as resource 

characteristics in determining adversary effectiveness, it was 

felt that protection against an adversary with a composite 

of characteristics across a spectrum of threat levels would 

constitute a more prudent performance objective. 

Paragraph 73.1 (a)( )(i) 

Q: Is "hand-carried equipment" intended to include 

toxic gases and antipersonnel ordinance? 

A: It is intended that the term "hand-carried" include 

incapacitating agents (tear gas, mace, tranquilizers, etc.) but 

not poisonous gases, and that adversaries will have available 

to them antipersonnel ordinance (hand grenades, claymore 

mines, etc.). These two adversary attributes indicate that 

unprepared guards or other response force personnel 

may be rendered ineffective either prior to engaging the 

adversary or much more easily during the engagement. The 

attributes also imply that response force personnel must 

have special equipment and receive special training to 

counter these capabilities. 

Paragraph 73.1(a)(2) 

Q: Is there any special reason why the adversaries have 

"the ability to operate as two or more teams?" 

A: The ability to operate as two or more teams implies 

that (1) the adversary may be able to split the response 

force into several groups, thereby reducing the firepower 

that the response forces can concentrate in any area during 

an engagement or (2) the adversary may be able to fix the 

response force in one location by having one team engage 

the response force while another team maneuvers and 

completes the theft mission. This adversary attribute has a 

potential impact on the number of response force personnel 

that may be required and the response tactics they may 

employ. 

Paragraph 73.1 (a)(J) and (a)(2) 

Q: Do the knowledgeable individual who renders inside 

assistance and the conspirators possess the same adversary 

attributes as the "small group of external attackers"? 

A: It is expected that anyone who supports the adversaries' 

actions will be capable of acquiring the same training as the 

most sophisticated members of the adversary's group. 

However, because of the nature of the level of protec

tion required by these regulations it is not expected that 

the single insider or the conspirators will'have available to 

them all of the weapons, ordinance, or special tools that are 

considered the attributes of the "small group of external 

attackers." However, if the insider is a guard or perhaps 

an armed response individual, he may possess some of the

armament referenced in the rule. The prescribed upgrade 

rule protective measures should limit the quantity and 

quality of the weapons and ordinance that can be introduced 

into a facility prior to initiation of the theft or sabotage 

sequence. 

Paragraph 73.1(a)(2) 

Q: Is it the intent of the conspiracy threat statement 

that the physical protection system provide a capability to 

prevent collusion between more than two insiders? 

A: It is the intent of the regulations that those design 

features of the physical protection system that are affected 

by the number of insiders in collusion be effective against 

two colluding individuals. It is expected that some measure 

of protection will be afforded against larger colluding 

groups as a result of those features designed to counteract 

two colluding individuals. Also, the larger the colluding 

group, the higher the probability it will be detected. 

§ 73.20 General Perforrance Objective and Requirements 

Paragraph 73.20(b)(2) 

Q: What is the general scope of the "redundancy and 

diversity" requirement? 

A: The physical protection system must be designed 

with redundant and diverse measures sufficient to ensure 

that the system will remain capable of providing the neces

sary level of protection under adverse conditions causing 

the failure of some elements of the system. 

Redundancy means providing several measures (which 

may be the same measure duplicated) to perform the same 

function or subfunction in order to prevent failure of the 

entire system on the failure of a single measure. The perform

ance of any given capability must not be so dependent on 

any one measure that failure of that measure prevents 

adequate performance of the capability. 

Diversity means providing different kinds or types of 

measures that contribute to the performance of a given 

security function or subfunction. By providing various 

measures that have differing operating characteristics 

(sensitivities, failure modes, strengths, and weaknesses), the 

continued performance of a given capability is ensured 

regardless of the failure of one such characteristic. 

An example of pure redundancy is the use of two 

microwave perimeter intrusion alarm systems installed in 

parallel and provided with independent annunciators and 

power supplies. If one of the two microwave perimeter 

intrusion alarm systems is replaced with' a fence-mounted 

intrusion detection system, both redundancy and diversity 

have been achieved. 

A more abstract example of redundancy and diversity 

would be the use of a perimeter intrusion alarm system 

(any technology) with a low-light-level (LLL) closed circuit 

protected area television surveillance system equipped

5.61-10
with a motion detection capability. For example, a primary 

perimeter intrusion detection system could be an infrared 

(IR) system and a redundant secondary capability would be 

provided by the motion detection feature of the CCTV 

system. A tertiary intrusion detection capability would be 

provided by manual observation of the CCTV monitors. A 

fourth detection capability could be provided by the guard 

patrols. Diversity of the perimeter detection capability 

thus is provided by different types of technology used to 

detect the intrusion. Further diversity is provided by the 

fact that the LLL CCTV cameras may be designed to work 

during the failure of the perimeter lighting system. 

Paragraph 73.20(b)(2) 

Q: In what manner will the redundancy and diversity 

requirement aid in the protection against the insider or the 

conspiracy threat? 

A: Whether the threat arises from an insider, a conspiracy, 

or outsiders, redundancy and diversity provides additional 

elements that must be overcome by the adversary to steal 

SSNM or commit radiological sabotage. These additional 

elements improve protection by requiring, for example, the 

adversary to spend more time in learning system functions 

and more time in attempting to disarm or compromise a 

series of systems instead of just one. 

Paragraph 73.20(b)(3) 

Q: What is the general meaning of the requirement of a 

"testing and maintenance program to assure control ovei 

activities and devices affecting the effectiveness, reliability 

and availability of the physical security system" and "a 

demonstration that any defects of such activities ant 

devices will be promptly detected and corrected"? 

A: The physical protection system should include 

testing and maintenance program that addresses all element 

of the physical protection system and will ensure that al 

elements remain operating as they are supposed to and tha 

all elements will operate at all times , including unde 

adverse conditions. Testing means procedures to confirn 

that the individual measures of the safeguards system ar4 

performing as designed and intended and are, therefore 

providing the appropriate functions and capabilities 

Maintenance means not only the repair or replacement o 

hardware components, but also the review and possibl' 

revision of orders establishing procedures that may. b 

necessary to keep physical security systems and subsystem 

operating effectively. 

The testing and maintenance program should b 

designed to ensure that failures or defects in safeguard 

measures will be detected promptly and corrected promptl) 

Both preventive maintenance and repair capabilities ar 

needed. Correction of failures or defects should not b 

merely temporary fixes but should remedy the fundamenti 

problem and prevent a recurrence of the failure or defeci

Paragraph 73.20(b)(3)

Q: What is the intent of the need "to assure control over 

all activities and devices affecting the effectiveness, reliability, 

and availability of the physical protection system"? 

A: It is clear that such security devices as alarms and 

CCTV must be tested and maintained to ensure reliability 

and availability. However, it is not so obvious, for example, 

that, if criticality alarms are activated falsely or illicitly, 

they pose a significant problem to the integrity of the 

physical security system. This problem exists because these 

alarms create the impression of an emergency situation that 

requires emergency evacuations. These evacuations reduce 

the level of protection for a period of time and provide 

paths for adversaries to enter or exit the MAA and remove 

material through an unprotected portal. Therefore, the 

testing and maintenance program should ensure that such 

devices are kept in good working order and that illicit acti

vities can not cause the effectiveness of the physical protec

tion system to be impaired. 

Examples of activities that might cause criticality 

alarms to activate erroneously are (1)setting the detection 

threshold too low and (2) simulating an alarm condition on 

the signal lines. 

Examples of controls over the above activities that 

might reduce the probability that these erroneous alarms 

occur are (1) close supervision by knowledgeable security 

personnel of the calibration process and (2) placing critical

ity alarms out of reach where possible, enclosing signal lines 

in conduits, and tamper protecting detection circuitry. 

Paragraph 73.20(b)(3) 

as Q: What are considered defects of activities and devices? 

t A: Examples of defects in activities that affect the 

r reliability, effectiveness, and availability of the physical 

I protection system are (1) incomplete guard rounds, (2) 

D improper vault opening or closing procedures, (3) escort 

I duties that are not taken seriously, (4) delay in removal of 

4. snow from between perimeter infrared intrusion alarm 

f detectors that are in constant alarm, and (5)failure to 

e properly calibrate portal detectors. 

s Examples of defects in devices that affect the physical 

protection system are (1) tamper switches that stick in the 

closed or secure position, (2) alarm components that do not 

e alarm when they lose power, (3) signal lines that have line 

Is supervision that is not functioning according to specifica

F. tions, (4) exterior equipment enclosures that fill with rain 

e and cause equipment failures because they are not properly 

e waterproofed, and (5) unacceptable degradation in detection 

al performance of alarm systems because of other environ

t. mental conditions such as high winds. 

5.61-11

I I
Paragraph 73.20(b)(3)

Q: What is a "demonstration that any defects.., will be 

•.. detected and corrected"? 

A: Examples of effective demonstrations would be 

procedures that (1) cause tamper switches to be physically 

activated, (2) cause alarm systems to actually operate on emergency power, and (3) measure line supervision tolerances. 

Paragraph 73.20(b)(3) 

Q: Does the requirement for a testing program imply the 

need for adversary type testing? 

A: Testing does not imply that the licensee should 

conduct exercises in which individuals assume the roles and 

characteristics of adversary groups and attempt to commit 

adversary actions. Drills in which an alarm is sounded (but 

for which there is no simulated adversary) and the security 

force's response times and knowledge of contingency plans are demonstrated constitute an appropriate and effective 

test method. The manner in which the alarm is caused to 

sound can be used to test its sensitivity, and the location of 

the alarm selected can be used to test the adequacy of the 

alarm display and assessment functions. 

Paragraph 73.20(c)(2) 

Q: What activities constitute "new construction, signif

icant physical modification of existing structures or major 

equipment modifications," and what kind of evidence that 

these activities are actually being planned is necessary to 

permit a delay in implementation to be authorized? 

A: The intent of this provision is to permit a delay in 

implementing those safeguards measures that require 

lengthy procurement, installation/modification/construction 

periods, and testing before they can become an inte

gral part of the physical protection system. The licensee 

should 4be prepared to show proof, if requested, in the form 

of signed contracts that clearly indicate the dates of delivery 

or completion of the subject components or measures, and 

the name and address of the vendors and contractors. For 

every measure in which there is an implementation delay, 

temporary measures that achieve a comparable level of 

protection will be expected. 

§ 73.45 Performance Capabilities for Fixed Site Physical 

Protection &stenm 

Q: Is it necessary for some capabilities to be maintained 

during both normal and emergency conditions? Which ones 

are they? 

A: The following paragraphs contain requirements to 

maintain the expressed capabilities during both normal and 

emergency conditions: 

73.45(bX1) and 73.45(bX2)

73.45(c)(1) 

73.45(eX!) and 73.45(eX2) 

73.45(0(1) and 73.45(0(2) 

Paragraph 73.45(b) 

Q: Why doesn't this capability statement also include a 

requirement for preventing unauthorized access of persons 

and materials into the protected area? 

A: Because it has been determined that it is not always 

possible to prevent the unauthorized access of materials or 

persons into the protected area (PA). Materials can be 

passed through or thrown over PA barriers, and an external 

group can penetrate the barriers before the response force 

has sufficient time to reach the point of penetration. The 

PA barrier forms only the first of a series of defense-in

depth systems the adversary must compromise in order to 

effect SSNM theft or sabotage. 

Paragraphs 73.45(b)(1) and (bJ(2) 

Q: Paragraph 73.45(bX I) is concerned with adversaries 

who attempt to gain access or introduce material across MAA or VA boundaries using stealthful or forceful tactics. 

Is it not reasonable to speculate that adversaries might 

consider the use of stealth or force to introduce unautho

rized materials or gain unauthorized access into an MAA or 

VA through entry control points? 

A: The boundaries referred to in the rule include the 

entry control points for the purposes of stealth or force. 

Paragraph 73.45(b)(2) 

Q: How do "entry criteria" differ from "authorization 

controls and procedures" and "authorization schedules"? 

A, Detecting attempts to gain unauthorized access into 

MAAs or VAs by deceit will require the establishment of access authorization controls and procedures to provide 

current authorization schedules and entry criteria for 

both persons and materials. Access authorization controls 

and procedures constitute the administrative process of 

determining which persons and materials have a legitimate 

need to enter a given MAA or VA and at what time or under what conditions this need exists. Current authoriza

tion schedules will document for entry control personnel' 

which persons and materials are authorized access and the 

times or conditions for such authorized access. Entry 

criteria are the aggregate of many pieces of information to 

be considered or checked in determining whether or not a person or material is authorized entry to that MAA or VA 

at that time or under those circumstances. 

Paragraph 73.45(b)(2)(ll) 

Q: What is the intended meaning of the requirement to 

verify the identity of materials prior to introduction into an 

MAA?

5.61-12
A: This requirement Is Intended to ensure that all 

materials entering an MAA are searched for contraband and 

that comparisons of shipping documents with package 

identification and authorization schedules are made. In 

2 the case of receipts of SSNM, this requirement does not 

imply that the packages of SSNM presented for entry into 

the MAA must be opened and the SSNM scrutinized, 

weighed, and analyzed at the entry point by security 

personnel. Authorization to receive this material must be 

transmitted to entry control security personnel through 

channels independent of the shipper. SSNM content may be 

verified by matching information on the shipping documents 

with that on the containers. Also required would be some 

form of verification that the package has not been opened 

or its integrity otherwise compromised. This can be accom

plished by the examination of both the container and the 

tamper-indicating devices affixed to it. 

Paragraph 73.45(c) 

Q: What is meant by "unauthorized activities and 

conditions"? 

A: The intent of this capability is to ensure that proce

dures that are consistent with sound security practices are 

maintained within the MAAs and VAs. The focus is on the 

security system detecting, primarily through surveillance, 

activities and conditions that threaten the security posture 

within the MAA. Unauthorized conditions include such 

things as vent grills out of place, holes in walls, and vault 

doors open when not necessary. Unauthorized activities are 

those that would leid to unauthorized conditions if the 

~j activity is not terminated. 

Paragraph 73.45(d) 

Q: Is it the intent of this paragraph to bring about 

substantial changes in material control and accounting 

practices? 

A: The intent of this paragraph is primarily to ensure 

that strategic special nuclear material is located within an 

MAA and to recognize that certain uses of the material 

within the MAA may need to be physically separated to 

make unauthorized removal more difficult. For example, 

materials directly usable in a clandestine fission explosive 

should be stored in a vault when not actively undergoing 

processing, while fuel elements, fuel assemblies, and certain 

other materials need not be afforded the same degree of 

protection because of their form. Furthermore, areas such 

as processing and packaging areas where the material is 

handled should be controlled separately to provide addi

tional help in preventing unauthorized removal of the 

material. A physical protection system can accomplish the 

intent of this paragraph by performing surveillance activities 

to detect gross occurrences of unauthorized movement 

and placement of SSNM. This is not intended to be a 

sophisticated control of small quantities of SSNM that 

would be a material control and accounting function. 

Material control and accounting practices can, however, 

assist in achieving this capability. These practices help to 

accomplish this by (1) defining authorized placements and

movements of SSNM (which should be done in concert 

with the physical protection system) and (2) providing 

procedures for informing the physical protection system of 

current authorizations for placement and movement of 

materials within the MAA. This includes the receipt of 

shipments through MAA portals. Licensees should review 

their fundamental nuclear material control (FNMC) plans 

and submit appropriate revisions to them to ensure that the 

above mentioned activities are covered in their plan. 

Paragraph 73.45(e) 

Q: What is the intended meaning of the term "confirmed 

forms and amounts"? 

A: Confirming the properties and quantities of material 

presented for removal, that is, establishing that the material 

presented for removal is in fact what it is purported to be, 

does not imply that the packages of SSNM presented for 

removal from the MAA must be opened and the SSNM 

scrutinized, weighed, and analyzed at the exit point by 

security personnel. Confirmation does require controls on 

the packaging, measurement of contents, and sealing 

of containers prior to removal. Alternative methods of 

controlling, packaging, measurement, and sealing are 

discussed in Regulatory Guide 5.57. Controls also should 

include procedures that permit the exit control security 

personnel to determine that the package does in fact 

contain the material listed on the packing document. This 

may be accomplished by matching the information on the 

documents accompanying the SSNM with information on 

other documents prepared by MBA or ICA personnel or 

other personnel who certified the packaging of the material. 

These documents are transmitted to the exit control 

personnel through channels beyond the control of the 

individuals making the removal. Also required would be 

some form of verification that the package has not been 

opened or .its integrity otherwise compromised since the 

MBA or ICA personnel or inspectors certified the contents. 

This can be accomplished by the use of packaging containers 

of such design that their structural integrity (or lack thereof) 

is readily apparent and that are sealed with tamper-Indicating 

seals (see Regulatory Guide 5.10, " Selection and Use of 

Pressure-Sensitive Seals on Containers for Onsite Storage of 

Special Nuclear Material," and Regulatory Guide 5.15, 

"Security Seals for the Protection and Control of Special 

Nuclear Material"). Checks on seals should include both 

seal integrity and seal identification. 

Paragraph 73.45(e) 

Q: Is it the intent of this capability statement that only 

the modes of stealth and force will be used by adversaries 

to remove SSNM through the MAA boundary and that only 

deceit will be used to remove SSNM through the MAA 

portal? 

A: As with other provisions of the rule, the major 

concern is for stealthful and forceful attempts to penetrate 

the MAA boundary (barriers) and deceitful attempts to pass 

through the portal. An adversary using stealth or force to 

remove material through a portal would probably select an

5.61-13

I I , I
emergency exit before he would select an exit control 

point. However, removal by stealth or force through normal 

entry control points should be considered in the design and 

operation of the portal. It is also conceivable that an 

adversary might attempt to pass SSNM around an SSNM 

detector by using stealth; however, it is expected that the 

portal design would prohibit this. 

Paragraph 73.45(e) 

Q: What is the distinction between the activities of 

"authorization" and "verification"? 

A: Authorization determines what is to be permitted 

and must occur before the act of verification. Verification 

is the process of determining whether what is happening is 

or is not authorized. 

Paragraph 73.45(e) 

Q: Is it the intent of this requirement to make changes 

in material control and accounting practices? 

A: Compliance with this paragraph may require changes 

in licensee material control and accounting practices and 

hence their FNMCs. Measurement and packaging of SSNM 

is ordinarily performed by either operational or material 

control and accounting personnel. However, controls that 

ensure that two people have attested to the contents and 

witnessed the application of the tamper-indicating seal, 

for example, may need to be instituted in advance to levy 

an overall internal control system to meet the intent of the 

regulation. Although Part 70 presently has requirements for 

tamper-indicating seals, the purpose was to allow the use 

of a previous measurement for accountability purposes. In 

this requirement, the intent is to prevent the theft of SSNM 

both by a single individual and through collusion. Therefore, 

additional control over the seals and the seal records 

may be needed. For example, procedures to provide copies 

of the seal log to exit control individuals might be developed 

to ensure that two individuals have attested to the contents 

and witnessed the affixing of the seal and that both of these 

individuals did not participate in transferring the material 

to the exit control point. 

Paragraph 73.45(e)(2) 

Q: Why not confirm the identity and quantity of strategic 

special nuclear material "authorized" (rather than "presented") 

for removal from a material access area? 

A: The concern is whether material 'presented" for removal 

conforms with the identity and quantity of SSNM "autho

rized" for removal. "Confirmation" occurs at the time the 

material crosses the MAA boundary. "Authorization" must 

occur before the material is moved to the MAA boundary. 

"Confirmation" should be conducted immediately before 

departure of the material to preclude tampering. 

Paragraph 73.45(f) 

Q: Is the intent of this requirement similar to the MAA 

and VA access controls called for in paragraph 73.45(b)?

A: It is similar, although the emphasis is on detection 

rather than prevention. This requirement is intended to 

detect individuals penetrating the PA or introducing unautho

rized materials or vehicles through PA portals. Therefore, 

specific authorization for such access must be presented to 

the security guards. This capability will ordinarily be 

accomplished by intrusion sensors, guard patrols, and 

remote assessment of the PA boundary and through person

nel and vehicle searches at the portals. 

§ 73.46 Fixed Site Physical Protection Systems, Subsys

tems, Component:, and Procedures (Reference System) 

Paragraph 73.46(a) 

Q: Why are the systems, subsystems, components, and 

procedures delineated in § 73.46 included in the Physical 

Protection Upgrade Rule if there are already general perform

ance and capabilities requirements? 

A: The level of detail in paragraphs 73.46(b) through 

73.46(h) is included in order to present examples of the 

types of systems, subsystems, components, and procedures 

that would normally be included in a physical protection 

system having the level of performance required of that 

system in order to be licensed. The required level of perform

ance is specified in § § 73.20 and 73.45. 

Paragraph 73.46(a) 

Q: Is there a reference specification provision in § 73.46 

for every capability requirement in § 73.45? 

A: Table I in Section B of this guide demonstrates that 

there is at least one example provision in § 73.46 for every 

capability requirement in § 73.45. Usually, there are 

several provisions in § 73.46 that apply to each requirement 

in § 73.45. A more detailed discussion of the relationship 

between these provisions can be found in Section B.4. of 

this guide. 

Paragraph 73.46(b)(2) 

Q: What is the meaning of the phrase "members of the 

security organization with authority to direct the physical 

protection activities"? 

A: The meaning of the phrase is that someone with 

specifically designated authority and a member of the 

security organization, e.g., the Director of Security or the 

security shift supervisor, must be onsite at all times and 

ready to direct the necessary physical protection activities. 

Paragraph 73.46(b)(2) 

Q: What is the meaning of the term "physical protection 

activities"? 

A: The term includes the full spectrum of activities from 

normal guard force duties, through immediate actions 

required by a secutrity breach, to reaching response forces 

and obtaining necessary assistance.

5.61-14

K
Paragraph 73.46(b)(3)(i) 

Q: What is the meaning of the term "other individuals 

responsible for security"? 

A: Other individuals are such management personnel as 

guard supervisors, response personnel who are not members 

of the guard force, plant security directors, and plant 

personnel directors. 

Paragraph 73.46(b)(3)uii) 

Q: Who is the "individual with overall responsibility for 

the security functions"? 

A: Generally, the individual to whom overall facility 

security responsibility is delegated is a corporate Vice 

President, Plant Manager, or the Plant Director for Security. 

Paragraph 73.46(b) (4) 

Q: Does this provision mean that licensees must submit 

separate plans to implement the requirements of Appen

dix B to Part 73? 

A: Separate plans will be required to implement the 

requirements of Appendix B to Part 73, although these 

should be related to and coordinated with the security plan 

prepared in accordance with the provisions of the Physical 

Protection Upgrade Rule. 

Paragraph 73.46(c)(2) 

Q: Are vehicle barriers required along the PA perimeter? 

A: No. It is- not the intent of the regulations to require a 

PA barrier capable of resisting a forceful entry attempt 

using a vehicle. 

Paragraph 73.46 (c)(5) 

Q: Does "strategic special nuclear material, other than 

alloys, fuel elements or fuel assemblies" mean all SSNM 

that is in the form of powder, liquid, or gas? 

A: Yes, it includes SSNM in solid, liquid, or gaseous 

states. 

Paragraph 73.46(c)(5)(i) 

Q: Must the penetration time of the vault equal local law 

enforcement response time or response time of the facility 

response force? 

A: The penetration time should either be equal to or 

greater than the amount of time necessary to deploy a 

response force capable of containing and preventing removal 

of SSNM from the facility by the external assault threat (a 

small group, well trained, well equipped, able to operate as 

two or more teams, etc.). Depending on site conditions, the

response force with this capability could be an appropriate 

mix of onsite and offsite personnel. 

Paragraph 73.46(c)(5)(fii) 

Q: Does the term "significant delay to penetrations" 

mean that this MAA barrier must be more formidable than 

those surrounding alloys, fuel elements, or assemblies? 

A: Yes. The purpose of this provision is to make it 

difficult for a conspiracy of individuals within the MAA to 

breach the barrier without being detected and transfer 

SSNM to the outside. 

Under this provision, all openings in the MAA barrier, 

such as areas under doors, through-fans, ventilation ducts, 

and pipe passthroughs, that lead to an accessible area 

outside the MAA should be completely closed off or 

specially protected. In addition, the barrier should be 

constructed of a material that resists cutting, drilling, and 

'puncture by small hand tools or tool substitutes. Where 

possible, all operations at a facility involving SSNM that 

has not been alloyed or encapsulated should be consolidated 

in a single location that meets this barrier provision. 

Barriers should be inspected at regular intervals to 

ensure that a breach is not in process. 

The secondary intent of this provision is to provide 

additional protection of unalloyed and unencapsulated 

SSNM in process against external assault. 

Paragraph 73.46(c)(S)(iv) 

Q: Does the term "except when personally attended" 

mean that components and process equipment containing 

SSNM do not need to be locked as long as someone is in the 

MAA? 

A: No. The only SSNM that does not need to be under 

lock is that being processed, handled, worked on, or directly 

observed by personnel. 

Paragraph 73.46(d)(1) 

Q: What type of escort is required for a non-employee 

entering an MAA or VA? 

A: Non-employees who require occasional access to an 

MAA or VA should be escorted by either a member of the 

security organization or a licensee employee who has 

current authorization to enter that MAA or VA. 

Paragraph 73.46(d)(6) 

Q: Is use of x-ray for package search required by the 

rule? 

A: No. X-ray is an acceptable method of conducting 

package searches but is not the only method. Substantial 

61-15

I ~ .l ~ I; 
technical guidance on alternative methods to accomplish package searches are contained elsewhere in the Physical Protection Upgrade Rule Guidance Compendium. 

Paragraph 73.46(d)(8) 

Q: Must a member of the guard force provide escort to 

personnel or vehicles that require an escort to enter the PA 

or may a designating escort be used? 

A: A member of the security force should escort vehicles 

entering the PA. Individual pedestrians may be escorted 

within the PA by either a member of the security force or a licensee employee who has current authorization to enter 

the PA. 

Paragraph 73.46(d)(9) 

Q: To meet the need for dual exit searches from MAAs, 

may one of the searches be a visual search or must both use 

electronic detectors, etc.? 

A: Visual searches are not considered sufficient to detect 

small quantities of concealed SSNM. Electronic SNM 

detectors should be used for both searches. 

Paragraph 73.46(d)(9) 

Q: What normally would constitute an acceptable 

random search? 

A: A technique that ensures that each individual could 

be selected for search each and every time the individual 

leaves the material access area. 

Paragraph 73.46(d)(14) 

Q: Does the definition of "termination of employment" 

include employees who have been transferred to another 

work site? 

A: Yes, it is intended that changes to keys, locks, 

combinations, and other related equipment should be made 

whenever an employee is transferred to another work site. 

Paragraph 73.46(e)(3) 

Q: Does the requirement that an individual other than 

the alarm station operator have knowledge of the opening 

of unoccupied vaults or process areas indicate that the 

individual may be notified some time in advance of the 

opening? 

. A: No. The individual should witness the opening, either 

directly or through an assessment mechanism such as 

CCTV. 

Paragraph 73.46(e)(3) 

Q: Is one monitor per each remote CCTV camera 

required in the CAS and SAS?

A: Not in all cases. Guidelines on appropriate CCTV 

configurations are provided in NUREG/CR-0543, "Central 

Alarm Station and Secondary Alarm Station Design," and 

in NUREG-Ol78, "Basic Considerations for Assembling 

CCTV," both of which are contained in the Physical 

Protection Upgrade Rule Guidance Compendium. 

Paragraph 73.46(e)(7) 

Q: Does the requirement that the status of all alarms and 

alarm zones be indicated in the alarm station mean that 

both the central alarm station (CAS) and the secondary 

alarm station (SAS) have identical annunciation and alarm 

control (access, secure, test) capabilities? 

A: A discussion of which capabilities should be duplicated 

between CAS and SAS and how and where to accomplish 

this is discussed in NUREG/CR-0543, "Central Alarm. 

Station and Secondary Alarm Station Design," contained in 

the Physical Protection Upgrade Rule Guidance Compendium. 

Paragraph 73.46(e)(7) 

Q: Is the intent of the rule to require a display board in 

the CAS/SAS indicating the status of each alarm with a visual display? 

A: The intent is that the status of each alarm can be 

independently determined in real time at each alarm 

station, i.e., no "summary alarms." 

Paragraph 73.46(g) 

Q: What is the meaning of the term "other physical 

protection related devices"? 

A: Examples of devices included in this term are: 

"* Emergency power sources 

"* Lighting, normal and emergency 

"* CCTV surveillance systems 

"* Weapons and other guard equipment 

"* Security vehicles 

"* Electronic access control devices 

"* Search equipment 

"* Duress alarms 

Paragraph 73.46(g)(5) 

Q: Does the provision for "two individuals working as a team who have been trained in the operation and perform ance of the equipment" mean the electrician and his 

apprentice or two separate electricians who do not normally 

work together? 

A: The two individuals could be any employees of the 

licensee or agents or contractors of the licensee who meet 

all other requirements for access. Both should be trained in 

the operation and performance of the security equip

ment involved to the extent that each could detect an unauthorized alteration of the system by the other.

5.61-16
Paragraph 73.46(gk(5) 

Q: Do "performance verification tests" differ from 

"operational tests"? 

A: Performance verification tests are an abbreviated 

form of operational tests. Operational tests are rigorous and 

systematic tests conducted on every zone of every alarm 

system at prescribed intervals. Performance verification 

tests involve testing the performance characteristics of only 

those functions that were likely to be affected by the 

maintenance activities in question. 

Paragraph 73.46(g)(6) 

Q: Does the provision for "individuals independent of 

both security management and security supervision" mean 

that someone outside the security program must conduct 

the review? 

A: Yes, the intent is to have a management review by 

persons other than those responsible for the security 

programs. 

Paragraph 73.46(h)(3) 

Q: What is the minimum composition of the response 

force and other armed personnel that should be available to 

cope with safeguards contingencies? 

A: This provision envisions five armed guards totally 

committed to the physical security effort being available 

for response and assessment of safeguards contingencies. 

The number of "additional" guards or other appropriately 

trained (in accordance with Appendix B) and armed personnel 

who must also be available for backup cannot be predeter

mined on a generic basis. This must be done on a site-by-site 

basis, giving due consideration to such factors as (1) the 

size, location, competence, and reliability of the local 

law enforcement agency; (2) the ease or difficulty with 

which the site can be approached undetected; (3) the ease 

with which escape from the site can be made; and (4) the 

general attitude of the local population toward the site and 

its management. These are the kinds of considerations that 

should influence the licensee's determination of the number 

of available armed personnel as expressed in the physical 

protection plan. 

Paragraph 73.46(h)(3) 

Q: May guards and armed response personnel have other 

duties or must they be dedicated to the response function? 

A: Guards and armed response personnel can have other 

duties as long as such duties do not interfere with their 

response to a safeguards contingency. Normally, it is 

expected that the response force would be made up of 

guards who have routine duties other than response, other 

members of the licensee's organization who are qualified 

and trained in accordance with Appendix B, and guards 

from the licensee's organization who may be located at a 

facility that is adjacent to the protected area. Guards

manning the alarm stations have continuing duties in case 

of an assault and are not considered to be part of the 

response force. 

Paragraph 73.46(h) (6) 

Q: What are some of the measures that can be used to 

"facilitate the initial response to detection of penetration 

of the protected area and assessment of the existence of a 

threat"? 

A: To facilitate prompt assessment and initial response 

to the detection of questionable activity at or in the vicinity 

of the protected area perimeter, a capability of observing 

the isolation zones and the physical barrier should be 

provided. Such means as closed-circuit television (CCTV), 

hardened observation posts, armored response vehicles, and 

various combinations of these might be used. The employ

ment of such physical security systems should be governed 

by the following considerations. 

1. CCTV. Coverage should include the entire perim

eter, isolation zones, and, to the extent possible, the clear 

areas between barriers. Cameras on remotely controlled pan 

and tilt mechanisms may be used for optimum effec

tiveness. If, however, fixed position cameras are used, the 

field of view normally would not need to extend beyond 

the isolation zones. Such limitation should allow concentra

tion within the areas of primary concern. Low-light-level 

CCTV cameras are most desirable for this purpose owing to 

their effectiveness during periods of reduced visibility. 

2. Hardened Observation Posts. Hardening should be 

to a level at least equivalent to that of the alarm stations. 

Such posts should be located so that an unobstructed view 

of the perimeter and isolation zone that is supposed to be 

monitored is available. The posts should also have direct 

communication and alerting capability with the alarm 

stations, including duress alarms, in order to avoid delay in 

the transmission of information concerning any threatening 

event. 

3. Armored Response Vehicles. Such vehicles should 

be armored to a level at least equivalent to that of the alarm 

stations. They should be capable of reaching a defensive 

position at any part of the perimeter barrier. Response to 

such a position must be sufficiently rapid to prevent 

intruders from reaching and breaching a second barrier 

without direct visual contact and opportunity for confronta

tion by the response force. The vehicles should be equipped 

with duress codes that can be easily activated through the 

mobile radio. 

Assessment is a continuing process of evaluating the 

security situation and deciding whether or not conditions 

that dictate the initiation of a response exist. The assessment 

functions of security personnel and systems such as that 

described above are important to the achievement of the 

objectives of a perimeter protection system. Personnel 

selected for any of the positions that have an assessment 

role (e.g., observation posts and alarm stations) should be 

highly competent and dependable. Furthermnore, they

5.61-17
should have the unquestionable authority to alert the 

response force and, in the case of those within the alarm 

stations, to request assistance from offsite forces. 

Paragraph 73.46(h)(7) 

Q: Why are security personnel assessing alarms within 

unoccupied vaults and unoccupied material access areas containing unalloyed or unencapsulated SSNM required to use only remote means to assess these alarms? 

A: There are two reasons for this provision. First, to 

maintain the designed delay time built into vaults, the 

doors should be kept closed and locked, especially at night 

and during off shifts. The remote assessment would preclude 

an adversary from intentionally using a false alarm as a means of getting the vault opened. Second, the use of 

remote assessment techniques prevents the two responding

guards from having access to material access areas and the 

SSNM. A possible alternative would be to use a team of 

personnel (more than two) to investigate the source of the 

alarm. 

0. IMPLEMENTATION 

This section provides information to applicants and 

licensees regarding the staff's plans for using this regulatory 

guide. 

Except in those cases in which the applicant proposes an 

acceptable alternative, after publication of this guide the 

Commission's staff will use the intents and understandings 

described herein as one aid for evaluating an applicant's or licensee's capability to conform to the performance-oriented 

physical protection requirements in the Physical Protection 

Upgrade Rule.

5.61-18

K
UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON. 0. C. 20555 

OFFICIAL BUSINESS 

PENALTY FOR PRIVATE USE. $300

POSTAGE AND FEES PAIO 

U.S. NUCLEAR RrGULATOVY 

COMMISSION

K