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SSINS No.: 6835 IN 83-36 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C. 20555 June 9, 1985 Information Notice No. 83-36: IMPACT OF SECURITY PRACTICES ON SAFE OPERATIONS Addressees: All nuclear power reactor facilities holding an operating license (OL) or construction permit (CP). Purpose: This information notice is provided to inform licensees of some of the results of an NRC Committee's recent study of the impact of safeguards requirements on safety at power reactor facilities. It is expected that licensees will review this information for applicability to their facilities. No specific action or response is required at this time. Description of Circumstances: In February 1983, an NRC staff committee completed an evaluation of the impact of NRC security requirements on operational safety at power reactor facilities. While the committee did not find that operational safety had been significantly affected at the five facilities which were visited, they did find that the potential for an adverse safety impact does exist, to varying degrees, at licensed facilities. Problems are most likely to occur during abnormal or emergency conditions if plant operators are unable to quickly pass through locked doors because of (1) failure of the computerized security access system or its components, (2) operator mistakes in using automated access systems, or (3) local procedures which require doors (other than security doors) to be locked for other purposes. The NRC committee report (which will be available later this year as a NUREG report) is being used by the staff in developing proposed revisions to 10 CFR 73.55. The information contained in the following paragraphs does not require a change in NRC requirements and should be of use to licensees now in evaluating security and safety interactions at their facilities. 8305110464 . IN 83-36 June 9, 1983 Page 2 of 3 Measures to Minimize the Impact of Security and Other Administrative Procedures on Plant Safety 1. Assurance of prompt operator access to operating spaces and equipment is vital to safe operations. Such access can be achieved by providing backup keys or other means of opening security doors which lock in the closed position in the event of loss of electrical power or access control computer failure. Interior vital area doors are not required to fail in the locked position. These doors may fail in the open position if procedures are established to provide prompt compensatory measures for the open door, e.g., deploying guards to strategic locations. Procedures governing the use of locks for other administrative or personnel safety considerations, including Radiation Areas, should also be structured to ensure prompt operator access, if necessary, for plant safety. 2. The use of individual, manually entered codes and "anti-passback" features in vital area access control systems may adversely affect safety and are not specifically required by NRC. The use of such features can lead to denial of operator access if mistakes are made or if the system malfunctions. Such additional measures, which are beyond those of a basic access control system, are not required and their use is not recommended. Although some licensees were previously encouraged through guidance and interaction with their license reviewers to use the anti-passback and manually entered codes, experience now indicates that a better safety/ safeguards balance may be achieved without these features. Licensees who believe that plant safety could be enhanced through the removal of these features may wish to contact their license reviewers to make appropriate arrangements for modifications. 3. Security Plans, Safeguards Contingency Plans, Emergency Response Plans, and Emergency Operating Procedures which are individually developed, reviewed, and audited for implementation can result in inconsistencies which could affect safe operations. An integrated management review of these documents can be helpful in identifying conflicts and inconsistencies in plans and procedures which might adversely affect safety. 4. Management can use established programs such as Safety Committee reviews, QA audits, and plant-wide deficiency reporting systems, to ensure that security practices do not inhibit safe operations. Although committee review of all security procedure and system changes is not required, the onsite committee could be briefed on planned security procedure or system changes and their effect on operations. The annual audit of the security program would be enhanced through assignment of an auditor with operations experience to the team. A deficiency reporting system which is available to all members of the plant staff, could provide a means for identifying practices and conditions with safety significance which exist outside of written plans and procedures. With management encouragement and followup, all members of the plant and corporate staff can contribute to the identification and correction of security, radiation protection, or other measures which might adversely affect operational safety. . IN 83-36 June 9, 1983 Page 3 of 3 5. Interface and coordination problems between security and operations personnel can be minimized through cross-training and indoctrination of both staffs on the roles, responsibilities, and general practices of both organizations. The committee found that the potential for security practices to adversely affect safe operations is reduced when each organization has an appreciation and respect for the jobs that other members of the shift are expected to perform. If you need additional information about this matter, please contact the Regional Administrator of the appropriate NRC Regional Office or the Division of Safeguards, Office of Nuclear Materials Safety and Safeguards. Edward L. Jordan Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement Technical Contact: George W. McCorkle, NMSS (301) 427-4018 Attachment: List of Recently Issued IE Information Notices .
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