This revision of the SAPs follows on directly from publication of the Chief Inspector's report on the implications of the Fukushima accident for the UK nuclear industry. That report concluded that there were no significant gaps in the 2006 safety assessment principles, but recommended a review to ensure that lessons learned were incorporated. That review is now complete and this document contains the results. In addition to the lessons from Fukushima, we have also taken account of recent work by the International Atomic Energy Agency (IAEA).
The main changes are in areas where we have learned from analysis of the events at Fukushima, so external events, severe accidents and emergency preparedness.
We take the views of others seriously and wanted to give people the opportunity to comment on our proposals.
We believe the consultation has been successful, we received well over 1000 comments and we reviewed each and every one and in many cases we have modified our text to reflect those comments.
Yes, we will publish all of the comments together with our judgements on them. Where we have disagreed with the comment we will say why.
Standards are certainly not being lowered. The revised SAPs largely bring additional clarity on ONR's expectations. In terms of the Fukushima related changes, the revision draws heavily on the work carried out in response to the Chief Inspector's report and the Stress Test outcomes which are already being addressed by the nuclear industry. Similarly, inclusion of new or revised IAEA safety standards is something we do as a matter of course.
The new SAPs will be used from day 1 of publication, but for the reasons already mentioned we do not expect a step change in our dealings with the nuclear industry. ONR's internal review and checking processes will ensure that the new SAPs are being used, and this process itself will be overseen by ONR's independent Regulatory Assurance function.
We felt that, as far as possible, it was better to retain the numbering used for the 2006 principles that were unchanged or were modified or moved to a new place within the document so that we did not have confusion over individual SAPs – for the most part SAP X is still SAP X and new SAPs have given new numbers. An exception to this is where 2006 SAPs FA 17 – FA 24 on assurance of validity of models have been re labelled as AV1 –AV8, to recognise applicability to data and models in areas other than just fault studies.
The SAPs will be reviewed in 5 years
The SAPs are guidance for inspectors, not mandatory requirements for licensees. Although it is not their prime purpose, the SAPs may provide guidance to designers and duty-holders on the appropriate content of safety cases, clarifying ONR's expectations in this regard.
The technical assessments guides will be brought in to line with the revised SAPs over the next three years as part of the regular review and update process. In some instances ONR may decide to bring forward the update of the TAG.