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COMAH inspection reports for Springfield Fuels Ltd

Date released
13 January 2025
Request number
202411062
Release of information under
Freedom of Information Act 2000 (FOIA)

Information requested

Please can I obtain copies of all COMAH Competent Authority Inspection Reports for Springfield Fuels Ltd (address: Station Rd, Lea Town, Preston PR4 0XJ) from the past three years.

Information released

We confirm that under s.1 of the FOIA, we hold the information you have requested.

Please find attached three documents:

  1. ONR-TD-IR-21-006 - IR Springfields Fuels LTD - COMAH Inspection- Ammonia - 18 19 May 2021;
  2. ONR-SDFW-IR-21-135 - Springfields Fuels Ltd-COMAH HF Asset Integrity Inspection - 18 November 2021; and,
  3. IR-52900 - Inspection Report Public 22-11-2024 15-10-42 (Springfields fire and explosion).

Qualified exemptions

Some information within each of the three documents has been withheld under the following exemptions of the FOIA:

  • S.24 of the FOIA provides for exemption where information should be withheld in the interests of National Security; and,
  • S.43 exempts information whose disclosure would, or would be likely to, prejudice the commercial interests of any person (an individual, a company, the public authority itself or any other legal entity).

As these are qualified exemptions, we are required to balance the public interest between disclosure and non-disclosure. We have therefore applied the Public Interest Test, as set out below:

Factors for disclosure

  • As set out in our Strategy 2020-25, we aim to be an exemplar of transparency and openness to retain, and enhance, the trust and confidence of the workers and public we serve; 
  • We will use openness and transparency to achieve our objective of developing and maintaining stakeholder trust in ONR as an effective independent regulator; and,
  • Issues related to the nuclear industry are subject to close scrutiny and debate, there is a public interest in information related to Springfields Fuels Ltd’s activities and the release of such information.

Factors against disclosure

S.24 – Safeguarding national security

  • There is a strong public interest in safeguarding national security. The ICO guidance for s.24(1) makes it clear that safeguarding national security includes protecting potential targets even if there is no evidence that an attack is imminent;
  • The disclosure of information relating to specific building locations, key safety controls and features, the location and movement of hazardous material along with procedures and safety case references, could adversely affect the safety and security of the Springfields Fuels Ltd site; and
  • It is likely that the requested information, pieced together with seemingly harmless information readily available in the public domain, could provide malign actors a much larger picture of the site and any potential vulnerabilities it may have.

S.43 – Commercial interests

  • Section 43(2) says that information is exempt if its disclosure under FOIA would, or would be likely to, prejudice the commercial interests of any legal person (including the public authority) holding it;
  • The disclosure of this information would adversely affect the confidentiality of commercial information where such confidentiality is provided by law to protect legitimate economic interest; and,
  • Disclosing the information provided by Springfields Fuels Ltd. could prejudice their commercial interests by divulging information that may benefit their competitors causing them harm.

Conclusion

ONR is committed to being an open and transparent regulator and operates on the basis of openness with a presumption to disclose information. After careful consideration of the factors set out above, we have concluded that the public interest in maintaining the exemptions outweighs the public interest in disclosing the information.

On balance, safeguarding national security and commercial interests of Springfields Fuels Ltd, outweigh the need for openness in terms of the specific information being requested. Disclosure of this information would likely prejudice their interests by assisting its competitors, and breaching existing safety and security protocols.

Absolute exemption – S.40 Personal information

It important to note that information relating to individuals has been redacted from the enclosed document as it constitutes personal data. This consists of names, contact details, and signatures. The release of this type of information could identify an individual either directly or indirectly, and as such, any personal data that could identify another individual has been withheld under the remit of exemption s.40(2) of the FOIA.

Release of the information would breach principle (a) of GDPR (lawfulness, fairness and transparency) on the grounds that there is no lawful basis to process this data. In addition, releasing this personal data would also breach principle (b) of GDPR (purpose limitation) as the data was provided for the purposes of internal report authorship and circulation. 

Further information

The COMAH competent authority for nuclear sites is the ONR and Environment Agency, acting jointly. The Environment Agency may hold information of interest. We suggest you contact them directly at: enquiries@environment-agency.gov.uk

Exemptions applied

s.24, s.40 and s.43

PIT (Public Interest Test) if applicable

Yes