Office for Nuclear Regulation

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Questions on Vulcan Naval Test Reactor

Information requested

  1. A copy of MoD request that following an increase of radioactive gases in the Vulcan reactor in 2012 be 'kept on a strict need to know basis for security reasons'.
  2. The number of similar MoD requests that the ONR received concerning other issues be kept on a strict need to know basis for security reasons.
  3. An explanation for the difference between the ONR and the MoD statements in which Defence Secretary Philip Hammond informed the House of Commons that there has been no 'measurable change' in radiation discharge, something the ONR contradicts.

Information released

  1. Security briefings were done on a verbal basis, however a written request from MoD regarding need to know was received on 9 October 2012.
  2. No such records are kept.
  3. ONR has not made a public statement following the Defence Secretary's announcement, so there is no inconsistency between that statement and ONR's position. ONR concurs with the Ministers statement that doses to the workers are below legal limits. Furthermore, ONR has had assurances from the MoD Site that doses are as low as reasonably practicable. NB. ONR does not regulate environmental discharges, which are a matter for SEPA.

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.

  1. E-Mail MoD Vulcan NRTE to ONR dated 7 March 2014
  2. Letter from DNSR to ONR Dated 9 October 2012 Ref. DNSR/4/24/8

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.

Exemptions applied

PIT (Public Interest Test) if applicable

Section 22

Arguments for disclosure

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.

Arguments for withholding

There is a strong public interest in ensuring that Parliamentary Queries are answered in advance of information being made publically available.

Conclusion

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.