[May 2006] The permissioning process of HSE’s Nuclear Installation’s Inspectorate (NII) includes assessment of safety submissions made by licensees of nuclear installations, to determine if the safety measures for any proposed activity meet legal requirements. The law in the UK requires that the risks arising from work activities, to both workers and the public, must be reduced so far as is reasonably practicable. To enable a consistent approach to the assessment of safety submissions NII has developed regulatory assessment guidance for its inspectors, including its published Safety Assessment Principles (SAPs). The primary purpose of the SAPs is to provide NII’s inspectors with guidance as to what they should have a reasonable expectation of finding in a safety case and in the associated management arrangements for its preparation and implementation. The SAPs are not lists of requirement to be complied with, but an expectation to be met so far as is reasonably practical.

Since the SAPs were last revised in 1992 there have been several developments leading to the conclusion that a review and revision was timely. Among these are the publication of HSE's Reducing Risks, Protecting People (R2P2) (HSE Books, 2001) and Guidance on ALARP - As Low as Reasonably Practicable ( http://www.hse.gov.uk/risk/theory/alarp.htm) and changes in the focus of work in the nuclear industry towards decommissioning. Another driver is the UK’s work with its partners in the Western European Nuclear Regulators Association (WENRA) to harmonise regulatory standards.

Within this context a project to review and revise the SAPs was started in 2004 with the objectives of benchmarking against IAEA Standards to identify if they have an equivalence in NII SAPs, and at the same time to meet the needs of the future radioactive waste management, remediation and decommissioning activities of the industry, NII has now started the public consultation phase of this major project. The revised SAPs were published on 31st March 2006 in a down-loadable (Acrobat) format on the SAPs page of the HSE website ( http://www.hse.gov.uk/nuclear/saps/). Comments are invited on the SAPs, using the response form on the same web page. The end-date of 31 May for submitting comments should enable the conclusions of the consultation to be used in HSE’s submission to the DTI’s energy review. It is intended that the SAPs should be finalised in the autumn and implemented in early 2007.

The benchmarking element of the project was a 1-year exercise undertaken on HSE’s behalf by consultants and completed in April 2005. The UK recognises the IAEA safety standards as representing the international consensus of relevant good practice in nuclear safety. The results of the benchmarking have been used in the redrafting of the SAPs.

NII took the risk of making the early draft sections available for comment via the web site despite known inconsistencies at that early stage and the stakeholder comments received have been taken into account. A subsequent workshop hosted by IMechE proved extremely popular ( view the post-event report )
The Defence Nuclear Safety Regulator DNSR) approached HSE early in 2005 to see if a process of joint working could be achieved so as to enable DNSR to adopt the SAPs (except for unavoidable differences) as its assessment standard. This was agreed and no major stumbling blocks have been identified.

As well as updating the topics in the 1992 SAPs, the revised SAPs also provide important guidance on the application of ALARP and proportionality, on expectations for safety cases and safety management systems, and have new sections on radioactive waste management, decommissioning and contaminated land. NII believes that they will be fit for purpose for any future assessment of new facilities and clearer in their application to existing facilities.

Colin Waker (FIMechE)
Project Manager

Enquiries to saps@hse.gsi.gov.uk

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