Information Notice No. 83-36: Impact of Security Practices on Safe Operations

                                                            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 
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                                                              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

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