Release of information under the Environmental Information Regulations 2004
Following a request under Environmental Information Regulations 2004, ONR released the following information. If you require copies of the documents, please contact firstname.lastname@example.org
Environmental Information Regulations 2004 2012060369
1. Please find attached our response to your e-mail of 22 June 2012 requesting any summary reports we hold into any events that received an INES rating at either Sellafield or Dungeness in 2009, 2010 and 2011 and your further clarification e-mail of 11 July confirming that you were seeking events information we have used for screening for 'cause' and 'consequence ' as provided in your earlier request number EIR 2012040402.
2. Please note that the attached events summary reports constitute the early, initial information received by ONR which is gathered and analysed as part of our Operational Experience (OPEX) function. As previously advised, this analysis is produced in accordance with ONR processes and incident screening criteria for cause, actual / potential consequence and description given in our procedure BMM Annex 8 (currently under review). Such analysis helps us ensure we are focusing our regulatory attention proportionately in the right areas and encouraging our licensees themselves to learn from their own incident investigations to prevent recurrences. The data is used to identify possible themes and trends associated with our licensees incidents. We use such data to assist us in our subsequent intervention (inspection) planning.
3. For Dungeness, we have provided the following 10 summary reports (2 for Dungeness A, 8 for Dungeness B), with redactions of personal information in accordance with EIR 2004 Regulation 13 (Personal Data).
4. We have also provided summary report 105/2009 for Dungeness B with Personal Information names, redacted under EIR Regulation 12(3) & Regulation 13. This is an absolute exception so does not require a Public Interest Test.
Further redactions have been made under (EIR 2004.Regulation 12(5) which says: For the purposes of paragraph (1) (a), a public authority may refuse to disclose information to the extent that its disclosure would adversely affect:
(e) The confidentiality of commercial or industrial information where such confidentiality is provided by law to protect a legitimate economic interest.
The Public Interest Test supporting these redactions are detailed below:
For openness and transparency and to demonstrate proportionate ONR regulation
Given the preliminary nature of this report, the technical information provided has subsequently been found to be inaccurate on significant matters and has potential to cause confusion
It is not in the public interest to disclose this information as it is likely to cause confusion and could harm the commercial interests of the Licensee.
5. Please be aware that following a further review of our events information, we have identified 4 additional events at Sellafield where INES ratings were unknown at the time the event summary reports were produced and were finally rated at INES 1. Details of these events are provided below.
|Date||Location||INES Rating||ONR Screened Cause||ONR Screened Actual/Potential Consequence [Hazard]||ONR Screened Description|
|1/4/09||Sellafield||1||Human Performance Intentional / misinformed / unintentional or lapse||Breach of operating limits and conditions, LCs & other relevant legislation||Non-compliance with conditions and limits necessary in the interests of safety.|
|28/5/09||Sellafield||1||Human Performance Management system||Radiation exposure (internal / external)||Conventional Safety|
|22/1/10||Sellafield||1||Human Performance - Intentional / misinformed / unintentional or lapse||Reduced safety margins / safety barriers||Safety related plant requirement incorrectly implanted|
|24/8/10||Sellafield||1||Maintenance failure||Breach of operating limits and conditions, LCs & other relevant legislation||Non-compliance with conditions and limits in the interests of safety|
6. We have provided summary reports for the above events in addition to those listed in earlier request number EIR 2012040402.
Report Numbers are: 116/2009, 11/2009, 127/2010, 7/2011, 17/2011, 104/2010, 54/2009, 09/2010, 89/2009 and 143/2011.
Personal Information names, has been withheld under EIR Regulation 12(3) & Regulation 13. This is an absolute exception so does not require a Public Interest Test.
Additionally information has been redacted under Regulation 12(5) (a) which says: For the purposes of paragraph (1) (a), a public authority may refuse to disclose information to the extent that its disclosure would adversely affect:
(a) International relations, defence, national security or public safety.
The Public Interest Test supporting these redactions is detailed below:-
Issues related to the nuclear industry are subject to close scrutiny and debate, there is public interest in information related to nuclear activities and the release of such information.
Disclosure of Building numbers, building references, locations, room numbers, are withheld, because the release of information could aid the commission of a malicious act and the public would not expect ONR to release information that would aid such an act
The balance is clearly in favour of limiting the potential for a malicious act. The public interest test in this instance would favour prudence by not releasing this information.
Please accept our apologies once again for the extended deadline that was required to answer this enquiry and for any inconvenience the delay may have caused. If you have any queries about this letter please contact me quoting the reference number above.