Within the Convention on the Physical Protection of Nuclear Material (CPPNM/A) Fundamental Principle (FP) A identifies the Responsibility of the State and FP C covers the Legislative and Regulatory Framework.
The IAEA Nuclear Security Series (NSS) document NSS13 “Recommendations on Physical Protection of Nuclear Material and Nuclear Facilities (INFCIRC/225/Revision 5) provides that “the operator should prepare a security plan ….”.
The United Kingdom competent authority ‘Office for Nuclear Regulation (ONR)’ introduced new regulatory guidance to support the Nuclear Industries Security Regulations’ This updated guidance, known as the ‘Security Assessment Principles’ to the regulatory approach further towards an Outcomes Based regulatory regime, and also to more closely align with the UKs approach to Nuclear Safety through guidance known as ‘Safety Assessments Principles’.
The ONR, to support their Inspectorate, produced a number of Technical Assessment Guides (TAGs); one for each of the thirty-eight (38) Security Delivery Principles (SyDPs).
This paper will describe the approaches and assessment methods that the National Nuclear Laboratory (NNL) used to develop their three Nuclear Site Security Plans to meet an Outcomes Based Regulatory approach. We will share the lessons we learnt from using a multi-disciplinary team approach; how we took the opportunity to go back to basics, and the processes and best relevant practice we used to deliver a challenging project.
The authors consider that the learning from experience is equally relevant to operators and technical support contractors irrespective of the type of regulatory regime they operate within.