Information Notice No. 86-88: Compensatory Measures for Prolonged Periods of Security System Failures
SSINS No.: 6835
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
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.
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.
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
October 15, 1986
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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
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
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
* See 47 FR 7352, NRC Policy Statement, "Nuclear Power Plant Staff Working
Hours," dated 2/18/82; Revised 6/1/82 (47 FR 23836).
October 15, 1986
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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
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
Edward L. Jordan, Director
Division of Emergency Preparedness
and Engineering Response
Office of Inspection and Enforcement
Technical Contact: Loren Bush, IE
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