Information Notice No. 86-88: Compensatory Measures for Prolonged Periods of Security System Failures

                                                            SSINS No.:  6835
                                                            IN 86-88 

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                    OFFICE OF INSPECTION AND ENFORCEMENT
                           WASHINGTON, D.C. 20555

                              October 15, 1986

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 
construction 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 applicability 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; therefore, no specific action or written response is required.

Description of Circumstances: 

There have been several instances of major loss of physical security 
effectiveness 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 hours 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 
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                                                       IN 86-88 
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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 
     unforeseen 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). 
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                                                       IN 86-88 
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     b.   An individual should not be permitted to work more than 16 hours 
          in any 24 hour period, nor more than 24 hours in any 48-hour 
          period, nor more than 72 hours in any 7-day period. 

     c.   A break of at least 8 hours 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 hours. 

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. 


                                   Edward L. Jordan, Director 
                                   Division of Emergency Preparedness 
                                     and Engineering Response 
                                   Office of Inspection and Enforcement 

Technical Contact:  Loren Bush, IE 
                    (301) 492-8080 

Attachment:  List of Recently Issued IE Information Notices