Information Notice 1986-88, Compensatory Measures for Prolonged Periods of Security Systems Failures

Compensatory Measures for Prolonged Periods of Security Systems Failures

ML031250336
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Skagit, Marble Hill
Issue date:	10/15/1986
From:	Jordan E NRC/IE
To:
References
IN-86-088, NUDOCS 8610090090
Download: ML031250336 (4)

118 O iGIN~SSINS No. 6835 IN 86-88 UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

WASHINGTON, D.C. 20555 October 15, 1986 IE INFORMATION NOTICE NO. 86-88: COMPENSATORY MEASURES FOR PROLONGED PERIODS

OF SECURITY SYSTEM FAILURES

Addressees

All nuclear power reactor facilities holding an operating license or construc- tion permit and fuel fabrication and processing facilities using or possessing

formula quantities of special nuclear material.

Purpose

This notice is provided to alert addressees to increased vulnerability of their

sites when compensatory measures are implemented for prolonged or indefinite

periods. It is suggested that recipients review the information for applicabi- lity to their facilities and consider actions, if appropriate, to preclude

similar problems from occurring at their facilities. However, suggestions

contained in this information notice do not constitute NRC requirements; there- fore, no specific action or written response is required.

Description of Circumstances

There have been several instances of major loss of physical security effective- ness as a result of the failure of critical security subsystems, e.g., the security

computers, protected area (PA) alarm system, and PA or vital area (VA) barrier.

Although licensee security plans address the compensatory measures to be initiated

during circumstances similar to these, in some cases little or no consideration

has been given to those situations where the equipment failure requires the plant

to employ compensatory measures for prolonged periods of time.

Major losses of security system effectiveness have included gross inadequacies

in the PA alarm system and temporary PA configuration because of construction.

Construction has required protracted implementation of compensatory measures

for several months or years. In other cases, security computer failures have

caused employment of measures for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or more to compensate for near

total system outage, i.e., loss of VA access control equipment and PA alarms.

Discussion:

NUREG-1045, "Guidance on the Application of Compensatory Safeguards Measures for

Power Reactor Licensees," states that compensatory measures should be applied

only for the minimum time necessary to effect the repair or replacement of the

failed protection feature. Thus, compensatory measures are intended to be

8610090090

Attachment 1 IN 86-88 October 15, 1986 LIST OF RECENTLY ISSUED

IE INFORMATION NOTICES

Information Date of

Notice No. Subject Issue Issued to

86-87 Loss Of Offsite Power Upon An 10/10/86 All power reactor

Automatic Bus Transfer facilities holding

an OL or CP

86-86 Clarification Of Requirements 10/10/86 All registered users

For Fabrication And Export Of of NRC certified

Certain Previously Approved packages

Type B Packages

86-85 Enforcement Actions Against 10/3/86 All NRC medical

Medical Licensees For licensees

Willfull Failure To Report

Misadministrations

86-84 Rupture Of A Nominal 9/30/86 All NRC medical

40-Millicurie Iodine-125 institution licensees

Brachytherapy Seed Causing

Significant Spread Of

Radioactive Contamination

86-83 Underground Pathways Into 9/19/86 All power reactor

Protected Areas, Vital Areas, facilities holding

Material Access Areas, And an OL or CP; fuel

Controlled Access Areas fabrication and

processing facilities

86-82 Failures Of Scram Discharge 9/16/86 All power reactor

Volume Vent And Drain Valves facilities holding

an OL or CP

86-41 Broken Inner-External Closure 9/15/86 All power reactor

Springs On Atwood & Morrill facilities holding

Main Steam Isolation Valves an OL or CP

86-80 Unit Startup With Degraded 9/12/86 All power reactor

High Pressure Safety Injection facilities holding

System an OL or CP

86-79 Degradation Or Loss Of 9/2/86 All power reactor

Charging Systems At PWR facilities holding

Nuclear Power Plants Using an OL or CP

Swing-Pump Designs

OL = Operating License

CP = Construction Permit

IN 86-88 October 15, 1986 temporary in duration. Furthermore, these measures should be designed to assure

an essentially equivalent level of security as the protection feature to be

replaced.

Compensatory measures typically include deployment of personnel to substitute

for electrical (e.g., alarm systems) or mechanical (e.g., barrier) failures.

Studies have shown that even the most conscientious, dedicated security personnel

gradually lose their effectiveness when performing such tasks, even when posted

for relatively short periods. Furthermore, these personnel are particularly

ineffective when fatigued. Studies indicate that with fatigue, especially

because of loss of sleep, an individual's detection of visual signals deteriorates

markedly, the time it takes for a person to make a decision increases and more

errors are made, and reading rates decrease. Other studies show that fatigue

results in personnel ignoring some signals because they develop their own

subjective standards as to what is important, and as they become more fatigued

these personnel ignore more signals.

Apparent vulnerabilities, whether real or not, could encourage an adversary to

act against the plant. Since the design basis threat confronting nuclear power

plants and fuel facilities includes determined, well-trained and dedicated

adversaries who would be capable of collecting and analyzing information

concerning a plant's security system and procedures, prolonged use of most

typical compensatory measures represent periods of increased vulnerability.

NUREG-1045 recommends backup equipment as the preferred compensatory measures

in most of the examples provided. Backup equipment.could include additional

equipment already installed and operating or portable equipment that can be

quickly deployed if it appears that repair or replacement of the failed equipment

will take longer than a few hours.

When security personnel are employed as compensatory measures, licensees are

reminded that as a general policy security personnel cannot be considered

simultaneously available for both compensatory measures and response force

duties.

Some methods that have been used by licensees and have proven effective in

enhancing alertness and reducing errors, include:

1. Establishing controls on the number of hours worked (excluding time for

shift turnover) for normal conditions and in the event that unforeseen

problems are encountered (recurring or predictable problems are not unfore- seen problems). NRC policy* on working hours for plant staff who perform

safety related functions could be considered in developing these controls.

That policy suggests:

a. An individual should not be permitted to work more than 16 consecutive

hours.

• See 47 FR 7352, NRC Policy Statement, "Nuclear Power Plant Staff Working Hours,"

dated 2/18/82; Revised 6/1/82 (47 FR 23836).

IN 86-88 October 15, 1986 b. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in

any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor

more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period.

c. A break of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> should be allowed between work periods.

d. The use of overtime should be considered on an individual basis and

not for the entire staff on a shift.

2. Periodically reassigning security personnel to new duties, typically every

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

Licensees are reminded that preplanned "compensatory measures" during refueling

or major maintenance or modification work should be described in the NRC-approved

security plan or contingency plan. Otherwise, licensees should initiate

appropriate plan changes under 10 CFR 50.54(p), 50.90, 70.32(e), or 70.34 as applicable.

No specific action or written response is required by this information notice.

If you have any questions regarding this matter, please contact the Regional

Administrator of the appropriate NRC regional office, or this office.

.rd l rector

Oivisi f Emergency Preparedness

and EIgineering Response

Office of Inspection and Enforcement

Loren Bush, IE

(301) 492-8080

Attachment: List of Recently Issued IE Information Notices