ONR were verbally informed of the issue by DNSR in the summer 2012, and were required to keep the information on a need to know basis for security reasons.
The Vulcan Naval Test Reactor is not a licensed site under the Nuclear Installations Act. Nuclear safety at the site is regulated by the MOD regulator DNSR (the Defence Nuclear Safety Regulator). However, ONR does have wider health and safety legal vires, which include the regulation of the site under the Radiation (Emergency Preparedness and Public Information) Regulations (REPPIR) and Ionising Radiations Regulations (IRR).
Following notice of the issue, ONR sought and received assurance from MOD and from DNSR, both verbally and via the letter referenced at b) below, that the site was meeting its legal requirements under REPPIR and IRR. i.e. that the technical basis for the Hazard Identification and Risk Evaluation (HIRE) required to be produced under REPPIR and, hence, the determination of the Detailed Emergency Planning Zone for Vulcan NRTE remains valid, and, as required under IRR, that doses to workers remained within legal limits and were as low as reasonably practicable.
ONR does have limited records relating to the assurance provided to ONR regarding the matters it regulates at the site. Two documents have been identified as being within scope of your request.
A copy of a) is attached, with redactions limited to removal of personal details (e.g. names, phone numbers, email addresses etc) using the exemption in Section 40 FOI, and the former security classification of documentation. Document b) has been withheld using the exemption in Section 22 FOI - Information intended for future publication, because MOD has a commitment to publish to the Parliamentary Library relevant copies of DNSR Hold Point and Permissioning letters covering the NRTE Vulcan Shore Test Facility following a series of Parliamentary Queries. MOD aims to have placed the document in the Library of the House by the end of May 2014.
This document, dated 9 October 2012, is subject to a public interest test as detailed below.
There is a public interest in matters relating to releases of radioactivity.
There is a public interest in regulatory bodies demonstrating that they are correctly discharging their powers to ensure the health and safety of individuals.
There is a strong public interest in ensuring that Parliamentary Queries are answered in advance of information being made publically available.
Although there are strong arguments for disclosure, doses to workers remained within legal limits and were as low as reasonably practicable, so it is more important that Parliamentary queries are answered first, so the arguments favour withholding in this case.