Disposal of Radium by burial Portsmouth Hampshire

Whilst the radium contamination due to the disposal of radium residues by burial at Dalgety Bay is well known; it is interesting to note that radium wastes arising from defence activities were also disposed of by burial at Hilsea in Portsmouth Hampshire.

By way of background a recent article in the Guardian MOD lists sites not previously known to have been contaminated with radium and sites previously known to have been contaminated with radium. 

It is notable that the site where radium was disposed of by burial at Hilsea Lines Potsmouth was not included in either list. This despite MOD referring to Hilsea Lines  in response to a PQ in 1998

FOI request


Dear Department for Environment, Food and Rural Affairs,


Could you please provide me with the information you hold about the radioactive waste buried at Hilsea Lines. I have attached an extract from Hansard that may be of help


Hansard 9 Feb 1998 : Column: 72


“Radioactive Waste


Mr. Hancock: To ask the Secretary of State for Defence in what years Army personnel from 43 Command Workshop were ordered to dispose of low grade radioactive waste at Hilsea, Portsmouth; and what plans are available relating to the disposal. [27881]


Mr. Spellar: Army personnel from 43 Command Workshop disposed of low grade radioactive waste at Hilsea lines during 1978. Records dating from 1977 for this work are held in MOD files. The burial of the waste at Hilsea lines was approved by the Radiochemical Inspectorate of the then Department of the Environment. The Inspectorate then granted unrestricted access to the sites. Maps showing the locations at Hilsea lines of the buried waste were passed by the Ministry of Defence to the Property Services Agency of the Department of the Environment”


It is gratifying to find that the EA still holds information about the location of the buried Radium waste


Reply from the Environment Agency


RE: Request for information under the Freedom of Information Act 2000 (FOIA) / Environmental Information Regulations 2004 (EIR) 


Thank you for your enquiry which was received by this office on 1 November, 2011. 
Requests for information that is recorded are generally governed by the Freedom of Information Act 2000 (FOIA). The information you have requested is environmental and it is therefore exempted from the provisions of FOIA by FOIA s.39(1). We have therefore considered your request under the provisions of the Environmental Information Regulations 2004 (EIR). 


I enclose plans of the location of the burial of radioactive waste in 1978. The report, we have on file, states that this would be Area B on the attached plan, “Hilsea Lines 1.pdf”. The centre of Area B is at National Grid Reference SU 66464 04208.


Download  maps and correspondence  


Maps from Google Earth showing the location of the radium buried at Hilsea Lines Portsmouth

Maps from the Environment Agency 

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NAO report Managing change in the Defence workforce impact on skills

National Audit Office report Managing change in the Defence workforce published today points out the Minsitry of Defence is under pressure to make rapid financial savings, is significantly reducing the size of its workforce, by over 54,000 personnel. A report today by the National Audit Office has found that these reductions are happening in advance of the Department’s fully understanding how it will operate with significantly fewer staff.


With regard to skills the report says 


“The significant reduction in headcount creates a risk that current skills gaps will worsen. There is a significant risk that current skills shortages will worsen particularly as at least 16,000 personnel, 30 per cent of the reduction required, is predicted to occur through natural wastage, a process over which the Department has less control than redundancy.”


The recent statement by SEPA on the plans submitted by MOD for the remediation of the beach at Dalgety Bay may indicate that MOD has inadequate specialist skills to manage issues such as radioactive contamination.


"We consider that the plan, as it stands, lacks sufficient detail and have requested more information on a number of areas which include:

• timescales for implementation of each stage of the plan;
• more detail relating to the proposed investigation work;
• investigation plans for Crowhill and Ross Plantation;
• investigation of remediation options."

It has been previously pointed out that there are significant nuclear safety skills shortages. It will be interesting to see in this year’s report by the Defence Nuclear Environment Safety Board if the situation has changed

Ministerial Visit to Dalgety Bay

 It’s interesting to note from a recent PA report on the visit of Defence Minister Andrew Robathan.  He said that “the Ministry of Defence does not deny liability” and went on to say “But I don't think you would expect us to accept liability before we know exactly what the situation is.”


Video report from STV


This is surprising since the MOD has known about the contamination since 1990 and even produced its own risk assessments; surely enough time has passed and information gained to establish the responsibility for the contamination based on reasonable probability.
  
The reference to “industrial sites and ship-breaking” and the “need for further investigations”, seems like an attempt to further muddy the waters and play for even more time.
The reference to “earth movement which of course has of course disturbed a great deal of stuff” suggests that buried radium residues may have been disturbed and brought to the surface with a consequent increase in risk.


It seems that MODs continuing failure to accept that in all probability that the MOD is responsible for the contamination of Dalgety bay is very likely to lead to SEPA designating Dalgety Bay as radioactively contaminated land.


It’s also interesting to see how MODs miss-handling of the radium contamination at Dalgety Bay, and in particular the failure to apologise or accept liability for the contamination may well have played a significant part in shaping people’s views about the options for managing the decommissioned nuclear submarines stored on the Firth of Forth at nearby Rosyth Dockyard. 

Link to press report

Link to press report concerning Devonport and Dalgety Bay

Dalgety Bay provides a classic example of the miss-management of an environmental issue causing reputational damage across all business areas. 


The situation has moved from one concerning essentially scientific and objective decisions to a much more difficult situation primarily driven by ethical and political considerations. This is especially true in the current political environment where the SNP is seeking success in the up-coming referendum on independence.   


31/1/12  (UKPA)  reports


More tests due on bay radioactivity


Further investigations are needed at a beach where radioactive particles were found before anyone should take full responsibility, Defence Minister Andrew Robathan has said.


The Tory MP visited Fife to hand over a draft plan for further action to the Scottish Environment Protection Agency and to see the contaminated area for himself.


It comes after "significant" sources of radiation were discovered at Dalgety Bay on the Firth of Forth coast.


The contamination is thought to stem from residue of radium-coated instrument panels used on military aircraft which were incinerated and land-filled in the area at the end of the Second World War. The area faces the threat of being designated Radioactive Contaminated Land for public protection.


During a short visit to nearby Rosyth, Mr Robathan said the Ministry of Defence does not deny liability and questioned whether a clear-up of the site is needed.


"There was of course a Royal Naval air station here. It closed 53 years ago," he added. "Who knows who's liable. We're not denying liability but I think we need to be quite clear how this contamination has come about.


"For instance, there has been industrial sites. I understand there has been a ship-breaking yard just down the way. There's been earth movement which of course has of course disturbed a great deal of stuff. There's been housing estates built.


"We don't say that we are not in any way willing to help. We are willing to help. But I don't think you would expect us to accept liability before we know exactly what the situation is.


"We are therefore looking at this and we are willing to co-operate with the environment protection agency and others to find exactly what the situation is and then we can determine who is responsible for clearing it up, if there is a need to clear it up."
Last week former prime minister Gordon Brown, MP for Kirkcaldy and Cowdenbeath, called for urgent action to clean up the site. He has previously urged the MoD to "accept responsibility"

Dalgety Bay on-shore Radium Contamination

Recent press reports about Dalgety bay featuring interviews with Gordon Brown speaking about the ”new” discovery of particles of radioactive onshore at Crowhill wood should not ellicit any surprise, it appears that Gordon Brown is playing  catch-up. 


Links to recent press reports

• Courier
• STV including video
• Fife Today
• Link to a 2008 press report  before the Enviros report was published 

It’s clear from a report that MOD commissioned Enviros to produce in 2009 that the possibility of onshore contamination was an issue. The report  describes on-shore contamination including investigations of domestic properties and gardens built over the former RNAS/RAF Donibristle salvage area in the 1960s.  This and associated reports were released by Defence Estates in response to a FOI request made 2010.


Extract from the Enviros report describing areas surveyed inshore from the beach


Link to full report


“Investigation Works Undertaken


8.  As a result of the data from the first Phase Two LQA and in particular the findings relating to Property D in Zone 2A, a further phase of investigations were undertaken. The site works involved both radiological walkover surveys and intrusive investigation, the areas investigated are summarised below (Zone designation used in original Phase Two LQA are shown in brackets):

• Dalgety Bay Sailing Club Boat Park (Zone 1): Radiological walkover survey of northern area where access was previously not possible;
• Property A in Zone 2A and Properties H & I in Zone 4B: Radiological walkover survey and random soil sampling from two properties in Zone 4B.
• Radiological walkover survey and random soil sampling from one property in Zone 2A which had not allowed access during the original Phase Two LQA.
• Former Salvage Section (Zone 2A): 1m by 1m gridded radiological walkover surveys and soil sampling in the garden areas of six properties. Where radium-226 and elevated count rates were identified removal of disseminated contamination and point sources was undertaken where possible.
• Internal Monitoring: Count and dose rate surveys covering accessible areas of the ground floor of six properties on the former Salvage Section and the sailing club house. A similar property outside the impacted area was also surveyed to provide a typical background for the developments which could be used as a comparison.”

Link to full report


Reference: 


DALGETY BAY LAND QUALITY ASSESSMENT PHASE 2B: INTRUSIVE INVESTIGATION AND INTERVENTION LAND QUALITY ASSESSMENT REPORT – FINAL V1 DEFENCE ESTATES, PROJECT NO: 12920, TECHNICAL REPORT, November 2009, by Enviros Consulting.  

The failing regime for managing contaminated land.

RNAS/RAF Pulham  provides a typical  example of a site potentially  contaminated with Radium 


The Government recently introduced a new regime for the management of contaminated land to protect both man and the environment.   Recent FOIs have been asked, to try to establish the extent of the  hazards and risk  arsing from historic contamination due to use of  radium as a luminising agent by the Ministry of Defence.  This issue was also subject to a detailed review by the Governments Radioactive Waste management Advisory committee (RWMAC).


The recent  concerns  about this  legacy of  radium contamination  and the potential risk to the public and environment has been highlighted by  the  discovery  that the beach at Dalgety Bay is far more extensively contaminated than previously thought  and the MODs extreme reluctance to admit liability. The MOD has also released a list of some of the sites where radium contamination is an issue.


What has become clear that MOD has little if any records about radium contamination for those parts of the defence estate disposed of between the end of the Second World War and the 1980s. What records that do exist are mainly clearance certificates which were concerned about unexploded ordnance and explosives and not with other contaminates such as Radium, heavy metals, asbestos, chemical weaopns or organic solvents.


In response to an FOI  it is clear With introduction of the contaminated land regime that the MOD policy is :- 


“The site was despised of in the early 1960s and predates the MOD Land Quality Assessment programme. The MOD there only holds the enclosed 1969 Clearance Certificate that might be relevant to your request.


I am advised that former sites such as this fall within the statutory responsibility of the Local authority to inspect the land in its area and identify any contaminated land. It is therefore suggested that any evidence of contamination you have should be brought to the attention of the Local Authority “


This effectively shuffles off any responsibility to identify contaminated land that the MOD once owned or controlled to the Local Authorities.  Local Authorities are very unlikely to hold any information about these sites and therefore are unlikely to have the means to identify whether or not such land is contaminated.  


It is clear that with the need to find cost savings MOD has lost the capability to assist local authorities in identifying contaminated defence land.  MOD may have  transferred information that would have helped to the National Archive or the information may have been lost or destroyed. 

I asked the Local Authority  “Could you please provide me with information about the nature and extent of radium contamination at RNAS/RAF Pulham in Norfolk Lat 52° 24.690'N long 1° 14.011'E”


“The historic past use by the Ministry of Defence (MOD) of part of the site many years ago for aircraft breaking raises the possibility of radium 226 contamination. The nature and extent of any possible contamination is being considered but formal investigations which require detailed planning have yet to be instigated. The Council is actively working with the Environment Agency, Health Protection Agency, MOD and others within the legal framework from government to clarify what action is appropriate to investigate the possibility of contamination.” 




The Wikipedia entry for RNAS/RAF Pulham says  “During World War II, Pulham Air Station was used as an aircraft salvage yard for the East of England, with several huge dumps of scrapped aircraft. The resultant contamination of the land is visible even today. The RAF used Pulham for storage and Maintenance Unit work until closure in 1958.” This activity appears to very similar to that at RNAS Donnibristle  which may have lead to the contamination of Dalgety Bay with Radium.

Conclusion


The lack of information to identify whether or radium contamination is present means that only a very expensive physical survey will provide an answer.
  
The lesson to be learnt is that it is important to retain knowledge and information over long periods of time if you wish to answer questions of liability and risk.

MOD policy on contaminated land and alienated sites

In response to a FOI request about how MOD responded to the recommendations contained in the 2000 report by RWMAC    “RWMAC's Advice to Ministers on The Ministry of Defence's Arrangements for Dealing with Radioactively Contaminated Land“. It is clear from the response to action 12 that the MOD has no intention of identifying  what contamination exists on land that it has disposed of prior to the LQA programme such as Dalgety Bay.  


It is also clear from the response to action 12 of the RWMAC report that MOD believes this responsibility lies with Local Authorities.  Local Authorities hold few if any records that would assist them in identifying contamination on former MOD sites let alone the financial resources to support such activity.  


I believe it is important for the safety of the environment and the public, that risks from defence related pollutants are identified and if necessary remediated.  Examples of such pollutants are :-

• radioactive substances such as  radium, 
• chemical weapon residues such as mustard gas, 
• asbestos, 
• organic solvents, 
• explosives and ammunition
• toxic heavy metals such as mercury, lead and cadmium 

I also believe that it is the MODs’  responsibility to  identify where there is a legacy of pollution from defence activities  and where identified as the polluter, MOD should pay to for any clean up rather that  pushing off the responsibility onto poorly resourced local authorities  and council tax payers and Regulators 


RWMAC ACTION PLAN page 3 


Action 12
“MOD should give thought to the feasibility of compiling information on disposals of land predating the LQA programme, where radioactive contamination might have been involved.”


MOD response 


“The introduction of EPA 1990 Part 2A places the responsibility for inspecting land with the local authority to identify land contamination.”

MOD admits that it has no clear idea of what the risk is to people from the radium contamination at Dalgety Bay

In press report in the Sunday Herald MOD is quoted as saying

"New radioactive sources have been found at Dalgety Bay and we take this very seriously. However, it is not yet clear what the level of risk is."

This statement clearly shows that despite all the surveys MOD admits that it has no clear idea of what the risk is to people from the radium contamination at Dalgety Bay