The Safety Assessment Principles (SAPs) provide ONR's inspectors with a framework for making consistent regulatory judgements on nuclear safety cases. The SAPs also provide dutyholders with information on the regulatory principles against which their safety provisions will be judged. However they are not intended or sufficient to be used as design or operational standards, reflecting the non-prescriptive nature of the UK's nuclear regulatory system. In most cases the SAPs are guidance to inspectors, but where guidance refers to legal requirements they can be mandatory depending on the circumstances.
A formal review of ONR's SAPs in 2011 concluded that while no urgent changes were required, the SAPs should nevertheless be updated to reflect both learning from Fukushima and wider changes in the industry since the SAPs were last revised in 2006.
Following extensive work by ONR inspectors, as well as from other regulators and government departments such as the Environment Agency, the Scottish Environment Protection Agency and the Defence Nuclear Safety Regulator, proposals for an update have were drafted. Recognising that our safety assessment standards are important to the wider nuclear industry, ONR offered site licence holders, Non-Governmental Organisations and other interested parties an opportunity to comment on our proposals.
We were specifically interested in views on whether the changes adequately addressed:
We also asked that those responding suggested how the text should be amended to take account of their comment, since this helps to reach a common understanding.
We are pleased with the success of this process having received nearly a thousand comments from the public, non-governmental organisations and from the nuclear industry. Our multidisciplinary team of ONR inspectors have completed a detailed review of the comments received and, in summary, identified that in our opinion:
In accordance with ONR's policy of openness and transparency we have collated and anonymised all the comments received alongside our responses to them. In addition, we have also received additional comments from our inspectors which have also helped us to further clarify some aspects of our SAPs. We believe that the process has been open and inclusive and we sincerely thank everyone who took the time to send us comments. We hope that you will find this note helpful and that it gives you a clear understanding of the basis for the final update of our revised SAPs.