Questions and comments

We are interested in your views on the following questions, as well as any other comments you would like to make. For these questions ‘yes’ or ‘no’ answers with comments as to why you have this view will help us to use the results. Do not feel obliged to respond to all the questions posed, but limit your comments to those you consider of particular importance.

General - format and understanding of the SAPs document

G1 - We would like your views on the clarity of the SAPs - are they clear? How can we improve the layout of the document to make it more understandable?

G2 - Did you view the information on the Website? If so, was the information easy to download and laid out in a logical manner?

G3 - Have terms and references been adequately explained? Are there any assessment areas that need further explanation to make the SAPs easier to understand?

G4 - The revision of the SAPs included benchmarking against the International Atomic Energy Agency’s (IAEA) nuclear safety standards. We believe these standards give guidance on good nuclear industry safety practices. Do you agree? If not, why not?

G5 -We believe that the style and depth of discussion in the document has, at least in part, to fit with the technical complexity of the assessment topic being considered. Is the style and level of detail effective? How could it be improved?

G6 - We believe the new SAPs clarify what we are already looking for when assessing a safety case. Therefore inspectors should be able to use them in their work by 2007, with 6 months of case-by-case transition arrangements. Do you agree? If not, why not?

G7 - We have set the principles at a high level with more text to provide guidance. Much of this guidance was at principle level in the 1992 SAPs. As a result the principles and guidance do different things. There is no change of standard, just a different way of presenting it. Do you agree? If not, why not?

G8 - How often should we update SAPs in the future?

Technical / specific issues

TS1 - We believe the SAPs are valid for existing and new nuclear facilities. Do you agree? Are there any nuclear facilities that the SAPs could not be used to assess?

TS2 - We believe the revised SAPs provide clear guidance on technical assessment for our inspectors. Are the SAPs clear to you too? If not, why not?

TS3 - We believe the use of the new SAPs by our inspectors will have a positive impact on nuclear safety and radioactive waste management without imposing undue burdens. Do you agree? If not, why not?

TS4 - The SAPs on Structural Integrity, Civil Engineering and Graphite components repeat certain points. We believe this will help the reader who is particularly interested in one of these specialist topics. Do you agree?

TS5 - We have worked with the Defence Nuclear Safety Regulator (DNSR) to enable the adoption by them of the Principles (not necessarily supporting guidance) for assessment of the Naval Nuclear Propulsion Plant (NNPP). Has this been achieved?

TS6 - Quality assurance does not have its own heading in the SAPs now. We believe that it is a mature topic, well understand and a subset of Leadership and Management for Safety. Hence quality assurance is covered by general guidance in different places. Do you agree with this approach?

TS7 - We believe the leadership and management principles in the new SAPs represent the characteristics of high reliability organisations. They are intended to set the outcomes to be achieved rather than specify systems, processes and procedures. The reason for this is twofold: it provides flexibility to duty holders to determine the methods of applying the principles and provides HSE with a benchmark against which to judge the methods duty holders wish to adopt.

Are the leadership and management principles at a sufficiently high level to cover most circumstances? Do you agree that the management principles will point towards high reliability outcomes and not just the existence of systems and processes?

TS8 - We have used the term ‘safety case’ in two senses, as the totality of the duty-holder’s documentation that substantiates the safety of an activity and as short hand for the submission to HSE made under various licence conditions or regulations (see Glossary). Is this confusing? Do you have alternative suggestions for distinguishing these two uses?