Unregulated disposal of radioactive waste at Chatham

The MOD disposed of radioactive waste by burial at Chatham in Kent.  Its notable that this disposal was not subject to regulatory/statutory  control as the Radioactive Substances Act has been dis-applied to the Ministry of Defence (MOD). 

The waste was buried with the tacit approval of the Regulator under  a "gentleman's agreement" (ref1)  and on the assumption that only small quantities of short lived ( 5.26 years ) Cobalt 60 were present in the waste.  Once sufficient time (~25 years) had passed for the Cobalt 60 to decay there could be unrestricted use of the burial site

The MOD has recently confirmed the presence of 0.95GBq of long lived Carbon14 in the waste.  Because of the very long half life of Carbon 14 (5,730 years) the burial site may have to remain in perpetuity for future generations to maintain and care for.

Has the MOD  informed the Environment Agency (EA) of this new information?  If so what action is the EA taking to ensure the MOD provide updated risk assessment and ensuring that the burial site meets Regulatory standards.  I feel that this is an important issue , in that unlike other radioactive waste disposal sites, this site is in an urban area about to undergo redevelopment.Its  concerning that the MOD has previously said

“The risk assessment for the disposal of radioactive waste by burial Chatham - It has not been possible to locate this information, it would have predated the approvals granted by the 
Department of the Environment in 1980 and has not been located in any of the files recovered”. 

It is clear  from an ORNL 1977 report  that Carbon 14 was a significant activation product in pressurised water reactors (PWR), yet the MOD only discovered that Carbon 14 was an issue in PWR waste streams in 2000.

In the response to a FOI MOD said

"Our records show that work was conducted in 2000 to determine the quantities of Carbon-
14 transferred to the British Nuclear Fuels Limited site near Drigg, Cumbria.  This work 
considered the total predicted production of Carbon-14 from the Naval Nuclear Propulsion 
Programme."


The burial site at Chatham closed in the early 1980s  containing waste from the early years of the nuclear propulsion programme, the figures that MOD have calculated for Carbon 14 are based on measurements taken in waste produced in the late 1990s. It is not clear if the figures have taken account of changes in reactor chemistry between the 1970/60s and the 1990s.  I suspect the early submarines may been more "dirty" in terms of activation products (such as Carbon 14, Colbalt 60, Tritium etc) than later submarines. If this is the case then the MOD may have significantly underestimated the amount of Carbon 14 in the waste buried at Chatham.

It is also clear from the MOD response to a FOI request

"Our records show that six monthly routine radiological monitoring is carried out at the 
disposal site within the wooded area adjacent to Pier Road, Chatham. This schedule was 
agreed with the then regulator, Her Majesty’s Inspectorate of Pollution, (now part of the 
Environment Agency) in 1996. This monitoring comprises groundwater sampling and the 
measurement of surface gamma dose rates in the area.

There is currently no specific Carbon-14 monitoring undertaken of the waste at Chatham."

This is despite knowing in 2000  that Carbon 14 is present in the buried waste.

The way ahead and the future

There are advanced plans to redevelop the industrial waterside area adjacent to the site where 
the MOD buried radioactive waste. 

 The MOD needs to demonstrate that there has been no dispersion of radioactive waste including carbon 14 from the burial site into the adjacent land.  

There needs to be consideration about the effect of building and excavation work may have on integrity of the radioactive waste burial site and  the risks to people during construction and when the development is completed.

The fact that MOD has retained title to the land where the radioactive waste has been buried 
suggests the risks are not insignificant.  The best way forward may well be for the waste to be 
removed and the site cleaned up, this having been done, there could then be  un-restricted use of the site and any blight associated with the burial of the radioactive waste lifted. It would also 
demonstrate the MODs commitment to clean up the legacy of past military activities. 

Reference 

1:  A gentlemen's agreement is an informal agreement between two or more parties. It is typically oral, though it may be written, or simply understood as part of an unspoken agreement by convention or through mutually beneficial etiquette. The essence of a gentlemen's agreement is that it relies upon the honor of the parties for its fulfillment, rather than being in any way enforceable. It is, therefore, distinct from a legal agreement or contract, which can be enforced if necessary.

FOI requesting further information about Carbon 14 at Chatham

FOI requesting Land Quality Assessment

History of Nuclear Submarine Refitting 1970-1983