Office for Nuclear Regulation

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1 ONR INSTRUCTION INCIDENT NOTIFICATION AND REPORTING PROCESS Document Type: ONR Instruction Unique Document ID and Revision No: Date Issued: February 2013 Review Date: February 2016 Approved by: A Lindley Director, Civil Nuclear Reactors Programme Record Reference: Trim Folder (2013/53541) Revision commentary: Updated to reflect changes to reporting process TABLE OF CONTENTS 1 INTRODUCTION PURPOSE AND SCOPE RESPONSIBILITIES PROCEDURE AND GUIDANCE DISSEMINATING THE INCIDENT NOTIFICATION REPORT FINALISING INCIDENTS AND CLOSING INF REFERENCES APPENDIX 1 ONR INCIDENT NOTIFICATION FORM (INF1) APPENDIX 2 ONR INCIDENT NOTIFICATION UPDATE FORM (INF2) ANNEX 1 HSE PUBLICATION CRITERIA ANNEX 2 - ONR NUCLEAR AND RADIOLOGICAL INCIDENT/EVENT FOLLOW-UP CRITERIA 14 ANNEX 3 - FLOW DIAGRAM OF INF1 STAGES 14 Crown copyright. If you wish to reuse this information visit for details. You may reuse this information (excluding logos) free of charge in any format or medium, under the terms of the Open Government Licence. To view the licence visit write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or psi@nationalarchives.gsi.gov.uk. Some images and illustrations may not be owned by the Crown so cannot be reproduced without permission of the copyright owner. Enquiries should be sent to copyright@hse.gsi.gov.uk. For published documents, the electronic copy on the ONR website remains the most current publically available version and copying or printing renders this document uncontrolled.

2 1 INTRODUCTION 1.1. Many of the licence conditions attached to the standard nuclear site licence require, or imply, that licensees should make arrangements to comply with regulatory obligations under the conditions. ONR inspects compliance with licence conditions, and also with the arrangements made under them, to judge the suitability of the arrangements made and the adequacy of their implementation. Most of the standard licence conditions are goalsetting, and do not prescribe in detail what the licensees' arrangements should contain; this is the responsibility of the duty-holder who remains responsible for safety Under arrangements made to comply with legal and other requirements ONR regularly receives notifications and reports of incidents and events occurring on nuclear sites and other locations from licensees, operators or other duty-holders. In addition to the alerting aspects, notifications also allow ONR to collect and process operating experience (OpEx) that it needs to assist in its judgement that a nuclear installation or related activity is operated safely and securely and to inform its regulatory strategies and interventions. Furthermore, notifications of incidents are used to inform decisions on whether follow-up action by ONR inspectors is necessary The process for handling incident notifications and reports within ONR has been revised following agreement with licensees and other duty-holders. Details of the agreed arrangements can be found in the ONR Guidance Notifying and Reporting Incidents and Events to ONR (Ref. 1). 2 PURPOSE AND SCOPE 1.4. The purpose of this document is to outline ONRs arrangements for recording and disseminating initial information related to notifications of incidents occurring on nuclear sites and other facilities and locations where activities are regulated by ONR. It includes details on the requirements and arrangements for receipt of follow up reports associated with initial INF1s received from Operators, Licensees and Duty Holders (OLD). These procedures apply to all incident notifications in the areas of nuclear safety (Ns), radiological safety (Rs), security (Sc), safeguards (Sg) and transport (Tr) safety The document covers receipt of initial notifications from licensees, operators or other dutyholders and a common process for recording and disseminating the information to appropriate staff within ONR, HSE and other government departments, if necessary This document also includes guidance on the action needed for incidents meeting the HSE Publication Criteria, which are identical to the Ministerial Reporting Criteria (MRC). These publication criteria apply to all licensed sites and cover: Nuclear safety (Ns); Radiological Safety (Rs) (NB: Transport (Tr); Safeguards (Sg) and Security (Sc) Publication criteria are currently in production) Guidance is also included to assist inspectors in determining the ONR response to incidents where follow-up action by inspectors may be warranted This document excludes notifications of nuclear emergencies received through calls to the red telephone, which are to be dealt with in accordance with instructions contained in the ONR Emergency Procedures Handbook.

3 3 RESPONSIBILITIES 3.1 OPERATORS/LICENSEES/DUTY-HOLDERS (OLD) Ref. 1 to this guidance clearly outlines the responsibilities for OLD to notify ONR of incidents that meet the published ONR criteria, and to provide follow-up reports where relevant. 3.2 OPEX BUSINESS SUPPORT TEAMS (OPEX BST) AND SECURITY BST When a notification is received into the ONR incident notification account (ONR.Incidents@hse.gsi.gov.uk) from an OLD or ONR inspector, or via courier to the Security BST, then relevant BST are responsible for:- Performing a quality check of the incoming ONR Incident Notification form (INF1) to ensure the required information has been received; Where the above quality check identifies problems with the INF1, discussion with programme business support, site inspector or OpEx inspector should take place to rectify the shortfall, Uploading the INF1 to the ONR Incidents Database thus creating a unique number for the incident report and saving the original INF1 form onto TRIM under this unique identifier; Selection of the appropriate programme from the database options (this automatically generates a notification to the programme BST account). Distribution of the INF1 (post completion of the Part B ( ONR initial response ) to the circulation list selected; Forwarding any security (Sc) related INF1 notifications to security BST for loading onto the incidents database. INF1s loaded by security BST are then only accessible by security staff, and ensures that the information related to security related incidents is adequately protected. Recording any Follow-Up Reports (FUR) received into the onr.incidents account, or by courier, into TRIM, having identified the corresponding INF1, and forwarding to the relevant programme BST for completion of Part C ( ONR follow-up; Licensee/Operator follow-up summary ); Monitoring progress of INF1s and prompting the appropriate programme when progress appears delayed beyond target response timescales set out in Section 4. Requesting Programme business support where incidents meet HSE Reporting Criterion that an update is required for the Chief Inspectors Quarterly Statement of Nuclear Incidents at Nuclear Installations. 3.3 PROGRAMME BUSINESS SUPPORT TEAMS (PBST) Programme Business Support Teams are responsible for:-

4 Assisting in the completion of missing information identified during the OpEx BST quality checks. Maintaining accurate, up-to-date distribution lists for incident notifications and keeping the OpEx Unit informed of any updates; Once notified of a new INF1: Selection of appropriate (and available) Inspector to complete Part B; Updating part C of the INF1 covering incident follow-up actions both by ONR and the OLD; agreeing both parts C(1) and C(2) with the relevant inspector: o o Referencing follow up reports in TRIM on behalf of the inspector; Extracting cause, consequence etc information from the reports. Prompting the relevant inspectors to progress INF1s through Part B and Part C completion 3.4 ONR INSPECTORS Once notified of a new INF1, the ONR inspector (or delegated other) is responsible for:- Working with PBST to complete incomplete INF1s Dealing with a notification if the relevant Inspector is unavailable and requested to do so by PBST; Reviewing Part A of the submitted INF1 for clarity and completeness, and if necessary contacting the OLD for further information or clarification; Providing a statement in plain English in relation to ONR s initial or proposed response to an incident notification, the inspector s view of the adequacy of the OLD s actions in response to the incident, and the inspector s judgement of the nuclear safety significance of the incident in INF1 Part B within 24 hours of being assigned the INF1, where possible. Indicating the extent of the circulation of incident related information (INF1 Part B); Selection of appropriate circulation for the incident based on the severity and consequence (potential). see section 4.1 By agreement with OLD completing an ONR incident notification form (INF1), if the OLD is unable to for any reason, particularly if prompt circulation is needed, and requesting OpEx BST to record and distribute the form; Informing the OpEx BST of any significant amendments to a previous INF1 notification e.g. change to circulation or update to the rating on the International Nuclear and Radiological Event Scale (INES). Note that no changes should be made to the original INF1, and no INF1s should be resubmitted (NB. It should be noted that information changes made on the database are user name and date stamped for audit purposes). In cases of provisional or final INES ratings of 2 or above, the Inspector should inform the UK INES National Officer (UKINO) as soon as practicable (see section 3.10); Timely completion of an ONR Incident notification Update (INF2) form on incidents that are deemed to meet HSE Publication criteria for inclusion in the Quarterly Statement of Incidents for Ministers.

5 Monitor and request Follow up Reports that they are approaching due date (60 days post receipt of INF1). 3.5 ONR UNIT HEADS In relation to incident notifications Unit Heads are responsible for:- Completing an INF1 following receipt of an out-of-hours telephone notification, if the OLD is unable to do so, and then submitting it to the ONR incident account for recording and prompt circulation by BST; Ensuring relevant inspectors progress INF1s to completion. Ensuring, for events meeting HSE Publication criteria, that the relevant Inspectors complete an ONR Incident Notification Update form (INF2) in time for inclusion in the Quarterly Statement of Incidents to Ministers. Approving the text within the INF2 (post communication team agreement) that will be extracted into the Quarterly Statement of Incidents to Ministers, and ensuring that this is subsequently cleared through the DCI in time for inclusion in the statement; Ensuring that ONR produces an intervention or investigation report, should the incident s safety significance warrant an investigation and further regulatory action. 3.6 COMMUNICATIONS TEAM In relation to incident notifications the Communications Team is responsible for:- Considering all INF1s received to ensure appropriate lines to take are produced for incidents likely to lead to media interest; Reviewing and approving the text used on the ONR Incident Notification Update (INF2) form prior to Unit Head and DCI approval, noting that this text will be extracted into the Quarterly Statement of Incidents to Ministers, and published on ONR website. Reviewing and approving the Quarterly Statement of Incidents and covering letter prior to signing by the Chief Inspector. Arranging for placement of Quarterly Statement of Incidents on the ONR website. 3.7 DEPUTY CHIEF INSPECTORS (DCI) The DCIs are responsible for:- Ensuring consistent application of these arrangements within their Programme or Division; Approving the text in INF2 forms providing updates to incidents that meet ONR Reportable criteria on an INF2 form post communications team approval.

6 3.8 CHIEF INSPECTOR (CI) The Chief Inspector is responsible for:- Approving the Quarterly Statement of Incidents to Ministers and signing the covering letter authorising issue of the statement. 3.9 OPERATIONAL EXPERIENCE (OPEX) UNIT In relation to Operating Experience (OpEx) information relating to incidents reported to ONR, the OpEx Unit is responsible for:- Coordinating the OpEx function and incident reporting arrangements within ONR; Advising on the distribution for incident notifications; Reviewing and revising as necessary the arrangements outlined in this document; Providing and maintaining guidance to duty-holders in relation to notifying incidents and events to ONR; Developing and maintaining an ONR incident notification database; Maintaining accurate and accessible incident records; Creation and distribution (via the ONR Weekly Bulletin) of the Weekly Summary of Incidents; Managing the incident screening process to decide nuclear safety significance and other relevant factors that enable incident analysis and provision of advice; Analysing incident information, alongside other operational experience information, to identify lessons learned, trends and indicators and the provision of advice to operational programmes to help inform regulatory interventions, to ONR senior managers to inform regulatory strategies, and to industry; Compiling the HSE Quarterly Statement of Incidents at Civil Nuclear Installations for approval by the Chief Inspector and distributing to Ministers and others; Responding to Opex related FOI requests and Parliamentary Questions within response timescales; 3.10 UK INES NATIONAL OFFICER (UKINO) The UKINO is appointed by the Department for Energy and Climate Change (DECC), normally from among ONR s inspectors, and acts independently of ONR in this role. The UKINO is responsible, inter alia, for:- Monitoring the consistency of UK users application of the INES scale through reviewing all relevant incident notifications made to ONR; Submitting to IAEA details of any incident rated at level 2 or above within 48 hours of the event; and

7 Challenging a licensee s INES rating if considered to be incorrect and ultimately deciding on the final rating of any event. 4. PROCEDURE AND GUIDANCE 4.1. Receiving Notifications of Incidents or Events Incident notifications can be received by , telephone or fax through established lines of communication. All notifications should result in Part A of an INF 1 (see Appendix 1) being completed, normally by OLD staff. If an ONR inspector receives a verbal notification of an incident that clearly falls into an ONR reporting category (refer to Ref. 1 for ONR reporting categories and reporting timescales), then they should prompt the licensee/operator to notify ONR by INF1 to the incident notifications account (onr.incidents@hse.gsi.gov.uk), or by courier if the incident is security related. If the OLD is unable to do this, then the Inspector should complete an INF1 should rapid notification be needed For nuclear safety and radiological related incidents, where immediate notification is necessary in normal office hours the should be accompanied by a telephone call from the OLD alerting ONR to the notification. Where the notification is made out-ofoffice-hours then the OLD representative should contact ONR on the out of hours number detailed on the INF1 Form The process followed for security related incidents or events is the same, except that initial notifications should be made via telephone to an ONR Civil Nuclear Security (CNS) inspector or through the CNS Duty Officer for out-of-hours notifications. The oral report should be confirmed in writing by the OLD within 48 hours, for this purpose the 48-hour report should be communicated by the OLD using an INF1 form, using an appropriate carrier At present Security INF1s will not be held on the central Incident database but within the Security programme itself. This is due to limitations on the ability to send and receive notifications securely and the nature of the content of the INF1 received by Security. It is anticipated that Security INF1s will be unified into the standard ONR incidents recording process over the next 12 months OpEx BST shall maintain oversight of the ONR incident notification account for incoming notifications from OLDs. On receipt of an INF1 form, OpEx BST must complete the relevant quality check for completeness, load the INF1 onto the database, and send to the relevant Programme BST In the case of Defence related incidents, the INF1 will be flagged during upload to the database such that details of the incident will only be visible to Incident database users with the necessary level of clearance (this is associated to the individuals login account) The Programme BST shall then nominate an appropriate and available inspector to complete Part B of the INF The relevant ONR inspector should review Part A of the form for completeness and accuracy and, if necessary, should contact the reporting organisation for further

8 information or clarification. Part B of the INF 1 form should then be completed by the ONR inspector and should include: Technical based quality review of the INF1 to ensure what is written within the INF1 makes sense and is in adequate context; Initial opinion on the adequacy of the OLDs response to the incident Initial proposal for ONR action (or justification if no action proposed, see section 5.5) Statement of nuclear safety significance Any points of significant media interest (and where appropriate guidance on lines to take); and the appropriate circulation option selected, as follows: Normal Distribution: This should be the default distribution for INF1s unless the incident meets the criteria for Programme or Full Circulation Distributed to: Chief Inspector, Deputy Chief Inspectors (all), Relevant Superintending Inspector (Delivery Manager), Relevant Site Inspector, Inspector that completed Part B, HSE Communication Team, ONR Communication Team, Programme BST, Programme Comms Officer, OpEx Programme Leads, OpEx Team members o o Civil incidents: INF1 sent to DECC incidents account Defence incidents: INF1 sent to DNSR incidents account Programme Distribution: Generic interest to other units within the programme, or; Incident which has potential to impact or affect other sites within the same programme; Distributed to: Normal Distribution plus, all inspectors in identified programme(s) Full Distribution (justification required): Incident meets the HSE Publication Criteria, identical to Ministerial Reporting Criteria (MRC), or Provisionally rated as INES Level 2 or above. Distributed to: Normal Distribution plus, all inspectors and BSTs in all programme plus, interested HSE personnel, DECC, EA, SEPA, Respective devolved Scottish and Welsh Government officials, FSA. 5. DISSEMINATING THE INCIDENT NOTIFICATION REPORT 5.1. Dissemination On completion of part B, the database auto-generates an to the OpEx BST notifying them of the completion. The INF1 is then circulated using the selected circulation group via as a portable document format (pdf) file In the case of defence related sites or other premises where security markings may pertain, the Normal and Programme Distribution may be tailored to the content of the

9 specific INF1 inline with the Need to Know principle and will not include distribution outside ONR; As such distribution may not include wider HSE addressees (e.g. Press Office etc). The INF1 will however be shared with the Defence Nuclear Safety Regulator (DNSR) In the case of defence related sites or other premises where security markings may pertain, and following discussion with the appropriate Unit Head, Full Distribution is necessitated, consultation with DNSR (and if so advised, the MoD directly) will take place prior to any distribution. This may lead to caveats on the Full Distribution such as (but not limited to) marking the INF1 NOT TO BE CIRCULATED OUTSIDE ONR or redaction of the INF1 prior to distribution INES Ratings and Submission to IAEA Civilian nuclear and radiological incidents occurring on sites or in transport may be rated on the International Nuclear Events Scale and / or reported to the IAEA (NB. Defence sites are not required to assign INES ratings for reporting to IAEA. Nevertheless, Defence sites have been requested by ONR to assign INES ratings for consistency with the civil sector). If the OLD has provisionally rated the event at INES Level 2 or above then the Inspector receiving the notification details should inform the UK INES Officer, or their deputy, as soon as possible to facilitate international dissemination of the event details through IAEA; the target is to submit preliminary details to IAEA within 48 hours of the event In support of the UKINO role (see paragraph 3.10), any incidents initially reported with an unknown INES rating should have this information updated when it becomes available. Where applicable, the relevant inspector must obtain the rating from the licensee at the earliest opportunity. The rating shall be provided to OpEx Unit to enable the ONR incident database and UKINO to be updated Update Reports for Incidents Meeting ONR Publication Criteria Incidents deemed to have met the HSE Publication Criteria (outlined in Annex 1 and identical to the Ministerial Reportable Criteria) must have an update provided on an INF2 form, preferably following the preliminary investigation. Guidance on the ONR reporting categories that relate directly to the Publishing Criteria can be found in ONR-OPEX-GD- 001 (Appendix 1). As a further guide, any incident which is rated (either provisionally or finally) as INES 2 should be considered under the Publishing Criteria The purpose of the INF2 update is to generate the text which will appear in the Quarterly Statement of Incidents at Nuclear Installations made by the Chief Inspector to Ministers under section 11 of the HSW Act (NB. Wording is generally taken directly from the INF2 and added to the Quarterly Report without edit) This Statement is also published on the ONR website, and must therefore be written in plain English. Guidance on the information to be included in an INF2 is also provided in the form when viewed electronically. The relevant inspector should complete an INF2 form to update the position in relation to the incident and gain agreement to the text from their Programme Communication Team, Unit Head and DCI. The INF2 form should then be forwarded to OpEx Unit within one week of the end of the quarter in which the incident occurred.

10 5.4. Producing the Quarterly Statement of Incidents The OpEx Unit shall prompt Programme BST at the end of each quarter to provide any INF2 update reports on incidents that have either been deemed to meet HSE Publishing Criteria or were previously identified as possible candidates but needed further investigation. Annex 1 provides guidance on when to produce an INF2 and Appendix 2 provides guidance on what an INF2 should contain The text from the completed INF2 reports will be collated and included in the Quarterly Statement of Incidents, together with a covering letter to relevant ministers. The statement is then approved by ONR Communications Team and OpEx Head prior to signing and authorisation for issue by the Chief Inspector The distribution of the Statement is undertaken by the OpEx Unit to a list maintained through consultation with the ONR Policy Unit and Communications Team. The statement is submitted to Ministers within one month of the quarter end, and then published on the ONR website ONR s Response to Incident Notifications Relevant Unit Heads, in conjunction with their site inspectors, should decide further followup action is required, based on the significance (nuclear safety / radiological / other) of incidents notified to ONR. Annex 2 outlines high level criteria to assist Unit Heads and site inspectors in considering what type of ONR follow-up action should be instigated. How2 contains advice on how to determine if an investigation is necessary and guidance on how the investigation should be conducted Follow-Up by OLD and ONR Follow up reports should be sent to the same account as Incident notifications (onr.incidents account) and copied to the relevant site inspector. Programme BST staff should record any follow-up by ONR as outlined in Part C(1) of the INF1 form. This information should be agreed with the relevant Inspector and recorded on the incident database Part C(2) of the form recommends that the OLD provide a follow-up report outlining the results from the OLD investigation into the circumstances surrounding any incident that has been notified to ONR. The expectation is that the report is furnished to ONR within 60 days of the incident. Ref. 1 contains further guidance on what incidents require a follow-up report, and defines ONR s expectations regarding the content of these reports, including identified root and direct causes, actual and potential consequences, corrective actions both planned and implemented, final INES rating and ONR Category as well as any lessons learnt as appropriate. Programme BST staff will record and process this information for strategic review, analysis and provision of advice to operational programmes and stakeholder engagement purposes. 6. FINALISING INCIDENTS AND CLOSING INF Incident Notifications (INF1s) may only be closed after sufficient information is held by ONR. This includes completion of all stages of the INF1 process (see Annex 3) a well as receipt and agreement of the Follow Up Report by the relevant Site Inspector. Part C of

11 the INF1 should be completed by the Business Support in conjunction with the Site Inspector and be populated with all relevant information on the incident Once Part C is completed, the INF1 will be reviewed by OpEx BST for quality and any gaps addressed with the Site Inspector / Programme BST. Once all fields are complete. The OpEx BST will finalise the INF1 on the database 7. REFERENCES 1) ONR Guidance: Notifying and Reporting Incidents and Events to ONR (ONR-OPEX- GD-001 Revision 4)

12 APPENDIX 1 ONR INCIDENT NOTIFICATION FORM (INF1) A1.1. A version of the INF1 form that contains software providing lists and other helpful features, is available on HOW2, or via the OpEx Unit at onr.opex.unit@hse.gsi.gov.uk. These should be enabled in MS Word by selecting Tools Macro Security and selecting Medium from the options displayed. A1.2. Clicking [F1] in many fields will display help-text. There is a spell-check button at the top of the form. APPENDIX 2 ONR INCIDENT NOTIFICATION UPDATE FORM (INF2) A2.1. This appendix provides additional guidance on completion of the INF2 form: The INF2 should provide a brief summary of incident, written in plain English as far as practicable. It should include, where appropriate personnel affected and any release of radioactive material. Why the event was not reported in the previous quarter, if applicable. Summary of findings of the licensee s investigation. Summary of findings from any ONR s investigation undertaken to date. Commentary on licensee s response and ONR involvement in the aftermath including any enforcement action taken. INES rating (Provisional or Final ) and accompanying description Concluding or holding statement on ONR position e.g. content with licensee s response; investigating further; monitoring licensee s response etc. A2.2. Wording of the INF2 will be taken verbatim, potentially without further edit and added to the content of the Quarterly Report; As such the form must be approved prior to submission to the OpEx team. The approval route consists of the communication team, the relevant Superintending Inspector and finally the relevant Deputy Chief Inspector. Any significant subsequent changes made by the OpEx Team for the Quarterly Report will require agreement from the Programme. A2.3. A copy of the INF2 form can be found on HOW2 on the OpEx page.

13 ANNEX 1 HSE PUBLICATION CRITERIA MRC/HSE/ Publication Criteria a b c d e f Description of Criteria Dangerous occurrences reportable under the Nuclear Installations (Dangerous Occurrences) Regulations Summary of occurrences from Regulation No 3 are as follows:- 3(a) any occurrence on a licensed site involving the emission of ionising radiations or the release of radioactive or toxic substances, causing or likely to cause death, or serious injury, on or off the site. 3(b) any occurrences during transport causing or likely to cause death or serious injury or the breach of containment of a transport package. 3(c) any explosion or fire on a licensed site affecting or likely to affect the safe working or safe condition of the nuclear installation. 3(d) any uncontrolled criticality excursion. Confirmed exposure to radiation of individuals which exceed or are expected to exceed, the dose limits specified in Schedule 4 to the Ionising Radiation Regulations (IRRs) Examination, inspection, maintenance, test or operation of any part of the plant revealing that the safe operation or condition of the plant may be significantly affected. A confirmed breach of, or discharge expected to breach quantitative limits of a Certificate of Authorisation for the disposal of radioactive waste issued under the Environmental Permitting Regulations 2010 or Radioactive Substances Act Abnormal occurrences leading to a confirmed release to atmosphere or spillage of a radioactive substance which exceeds or is expected to exceed, the limits set out in Column 4 of Schedule 8 to the IRRs 1999, except where the release is in a manner specified in an Authorisation under the Environmental Permitting Regulation 2010 or Radioactive Substances Act Abnormal occurrences leading to a release or suspected release or spread of radioactivity, on or off site, which requires special action or special investigation by the Operator. NB: Further information is provided on the above criteria in the document: ONR Guidance: Notifying or Reporting Incidents and Events to ONR (Ref. 1). NB. The above criteria relates to nuclear safety and radiological incidents only.

14 ANNEX 2 - ONR NUCLEAR AND RADIOLOGICAL INCIDENT/EVENT FOLLOW-UP CRITERIA 1 The sections below set out criteria aimed at guiding ONR Unit Heads and site inspectors in considering what action to take in response to notification of an incident occurring on the site with nuclear or radiological significance. 2 More detailed guidance can be found on How2 referring to when investigation is needed, and how any such investigation should be conducted. AN2.A. Incidents periodically notified to ONR inspectors. 3 Where inspectors receive notifications of incidents NOT falling into the categories B-D below, they should ensure that the licensee has addressed the matters raised in accordance with the arrangements made under LC7, and adequate action in the interests of safety has been taken. AN2.B. All incidents or events that: Are rated on the INES scale at Level 1 or above by the licensee, whether deemed provisional or final; or Are deemed to meet the Ministerial Reporting Criteria/HSE Publication Criteria (see Annex 1). 4 These events should be subject to a preliminary investigation on site by an ONR inspector, with the outcome being recorded in their associated report. AN2.C. Any incident or event; where it is immediately evident or where initial enquiries or a preliminary investigation of the circumstances surrounding the incident reveal that: There appears to be a significant challenge, or potentially significant challenge, to nuclear safety; It appears there was, or could have been a significant breach of nuclear site licence conditions or other relevant statutory provisions; There has been, or there was potential for, a release of radioactivity above, or that approached, the statutory reporting limits; There has been, or there was potential for a dose to an individual or group above, or that approached, the statutory dose limits; The licensee had acted knowingly in not taking conservative action; or There have been a number of incidents that have the same apparent cause. 5 These events should be the subject of a more formal investigation by ONR and a specific investigation report should be produced. D. Incidents that do not fall within the above criteria, but give rise to political or public concern, could be subject to investigation and might also result in production of an investigation report as necessary.

15 ANNEX 3 FLOW DIAGRAM OF INF1 STAGES Event meeting report criteria occurs Duty Holder completes INF1 and s to ONR onr.incidents OpEx BST receives INF1 and performs initial QA check OpEx BST perform final QA check and mark INF1 as COMPLETE Follow Up Report (FUR) Received by OpEx BST and Site Inspector Screening Meeting held Programme BST complete Part C with Site Inspector OpEx BST Uploads INF1 into Database OpEx BST identifies the Programme Group Owner for the INF1 and notifies via OpEx BST distributes Screening pack to quorum members OpEx BST distributes INF1 (Part B complete) to selected distribution Group(s) Programme BST logs onto Database and selects appropriate Inspector Notified Inspector logs onto INF1 Database and completes Part B of the INF1 Does incident meet Publication Criteria? INF2 prepared by Inspector Quarterly report produced by OpEx Team and approved by Chief Inspector