MOD provides no evidence that MOD follows best practice for the management of contaminated land

This FOI was submitted to the MOD following concerns raised about poor record keeping by the MOD relating to contaminated land and the MOD saying that it had in place a “robust, proactive programme mirrors industry best practice, ensures the land is suitable for use and will not cause harm to people or the environment”


“I note from a recent BBC news report into radioactive contamination concerns at RAF Kinloss MOD is quoted as saying "The MoD is committed to assessing land quality across the entire defence estate. This robust, proactive programme mirrors industry best practice, ensures the land is suitable for use and will not cause harm to people or the environment.”

"I note that MOD is a member of “Safegrounds” which has produced best practice guidance for the management of radioactive contaminated land.

Could you please provide me with the audit and compliance reports that demonstrate that the MOD meets this “ industry best practice”

Also you could please provide me with me with the audit and compliance reports that demonstrate that the MOD meets “SAFEGROUNDS Good practice guidance for land quality records management for nuclear-licensed and defence sites””

The MOD replied

“I can confirm that the MOD holds no information that falls within the scope of your request. I am advised that there are no requirements for the MOD to have audit and compliance reports in relation to the management of radioactive contaminated land.”  

“There is no requirement for the MOD to follow the Safegrounds guidance for land quality records management, therefore no audit and compliance reports exist”

Full reply.

The reply clearly shows that the MOD can provide no evidence to support it's statement saying that the MOD meets “best practice” and this by implication means there are no audit or compliance systems to demonstrate that it is meeting its own policy and standards for managing radioactive contaminated land let alone discharge its legal duty of care to protect man and the environment.

It is also interesting to note the MOD in JSP375 Volume 4 the MOD Safety Health and Environment Audit manual lays down the requirement for audits to provide assurance that health safety and environmental standards are being met. The reply to the FOI suggests that this requirement in so far as the management of contaminated land and “best practice” is concerned that the MOD is ignoring its own requirements for audit and assurance.

Refrences

Safegrounds Good Practice  Guidance  for the Management of Contaminated land on Nuclear-licensed and Defence Sites; version 2

Safegounds Good Practcie Guidance for Land Quality Records Management for Nuclear-licensed and Defence Sites

BBC Radio 4 - Face the Facts Radioactive Legacy

Milcon Research and Consulting is  a key contributor to the recently broadcast  BBC programme on  radium contaminated land. The contribution from Milcon Research and Consulting was based on information in the public domain and responses to FOI requests.




BBC reports :-
"A pretty town on the Fife coast remains under threat of an unwelcome distinction. A corner of Dalgety Bay could still become the first place in Britain to be branded as radioactive contaminated land if the Ministry of Defence does not follow through on a plan to deal with radioactive particles washing up on its shore. The MOD's accused of causing the contamination in the first place: aircraft containing potentially hazardous radium were smashed up and buried after the Second World War. The MOD's investigating the scale of the problem and ways it might be put right, but has not promised a full and final clean-up of the bay. That's despite calls for it to do so from the local MP and former Prime Minister, Gordon Brown, and a recent discovery of particles far more radioactive than those previously found. Yet Face the Facts reveals how the MOD has cleaned up other sites deemed far less radioactive; how it's sold off contaminated land for development with radium undetected; how a lack of records means it does not know where similar sites might be and how a confidential government report we've seen from the 1950s warned of the danger of radium dumps being forgotten or, in the case of privately-owned land, deliberately concealed."
Presenter: John Waite
Producer: Jon Douglas

Link to the programme web site

Related Milcon R&C blog posts


Dalgety Bay


Hilsea Lines


Pulham


Chatham 


Failure to provide accurate information in response to FOI requests

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.

Maralinga a lasting legacy of British nuclear weapons tests in Australia

 The Sydney Morning Herald reports

“Ten years after the all-clear, Maralinga is still toxic

More than a decade after the Howard government hailed the clean-up of Maralinga as completed, the government is continuing to support remediation at the former British nuclear weapons test site.

Confidential files released under freedom-of-information laws show Canberra officials have at times been mainly concerned with ''perceptions'' of radioactive contamination while rejecting a request by the Maralinga Tjarutja Aboriginal community for a site near the Maralinga village to be cleared of high levels of contamination. Files released by the Department of Resources, Energy and Tourism show erosion of the massive Taranaki burial trench north of Maralinga, described by officials as ''a large radioactive waste repository'', has required significant remediation. Other burial pits have been subject to subsidence and erosion, exposing asbestos-contaminated debris.

While the documents indicate ''no radiological contamination of groundwater'' has been detected, the government has been obliged, under its 2009 agreement with Maralinga Tjarutja for the handback of the test site, to initiate further work.

The Taranaki trench was used to bury radioactive debris and soil, mainly from numerous ''minor trials'' - British nuclear weapons safety and development experiments - that between 1956 and 1963 caused the heaviest radioactive contamination.

A brief prepared in April for the Minister for Resources and Energy, Martin Ferguson, questioned the capacity of the Maralinga Tjarutja to manage the site.

The files show the government declined requests by the Maralinga Tjarutja to clean up the trials site closest to the village.

The ''Kuli'' site, east of the airstrip, was used to conduct 262 trials, which dispersed 7.4 tonnes of uranium into the environment.

While a partial clean-up in 1998 removed some larger uranium fragments, reports released under freedom of information show surveys in late 2001 and early 2002 found the spread of fragments was much greater than assessed.

The contamination was not assessed as a radiological hazard but the uranium toxicity prompted consultations on a clean-up of the site, and the Maralinga Tjarutja expressed concern about a risk to children playing on the ground.

Federal officials were more concerned that adults could wrongly interpret the yellow uranium fragments as meaning the site was radioactively contaminated, ''which could create an image issue''.

Alan Parkinson, a retired nuclear engineer and whistleblower who questioned the management of the clean-up, yesterday said the remediation had only been partial and ''the remarkable thing really, is how little [radioactive material] we buried''.”

It should be noted that the tests resulted in contamination not just due to uranium but also plutonium and beryllium

Maralinga - Background Information

British nuclear tests at Maralinga occurred between 1955 and 1963 at the Maralinga site, part of the Woomera Prohibited Area, in South Australia. A total of seven major nuclear tests were performed, with approximate yields ranging from 1 to 27 kilotons of TNT equivalent. The site was also used for hundreds of minor trials, many of which were intended to investigate the effects of fire or non-nuclear explosions on atomic weapons.

The site was contaminated with radioactive materials and an initial cleanup was attempted in 1967. The McClelland Royal Commission, an examination of the effects of the tests, delivered its report in 1985, and found that significant radiation hazards still existed at many of the Maralinga test areas. It recommended another cleanup, which was completed in 2000 at a cost of $108 million. Debate continued over the safety of the site and the long-term health effects on the traditional Aboriginal owners of the land and former personnel. In 1994, the Australian Government paid compensation amounting to $13.5 million to the local Maralinga Tjarutja people.

Continues .......

Parliamentary Question - Radium Contaminated Land on the Defence Estate

A Parliamentary Question to MOD Ministers provides a good example of how MPs are fobbed off with a standard line such as “the information is not held centrally and could be provided only at disproportionate cost”.


Delving into the past it becomes clear that this might not in fact be the case and that in 2000 the Radioactive Waste Management Committee (RWMAC) mentioned in their report Advice to Ministers on “The Ministry of Defence's Arrangements for Dealing with Radioactively Contaminated Land” that the “Ministry indicated that it was in the process of developing such a database.”  


It would seem that such a database  provides a central repository of information requested by the MP.


From Hansard 


“26 Oct 2011 : Column 261W
Radioactive Waste
Mr Weir: To ask the Secretary of State for Defence at which locations his Department has records of the burial of radium fragments. [75757]


Mr Robathan: The Ministry of Defence (MOD) takes a proactive approach to the assessment of land quality across the estate and to the management of the risks to human health and the environment. This includes radium 226 associated predominantly with the historical maintenance and disposal of luminised instruments especially during and after the second world war and which are present to some degree at many current and former MOD sites.


Where radium-226 contamination has been identified the potential risks are managed at site level. Such contamination on MOD sites is present in a relatively non-mobile form, with there being little to no leaching to soils and limited solubility in groundwater. As such, it is believed that radium and for that matter radiological contamination on MOD sites poses a relatively low risk to human health and the wider environment.


While the MOD has information on those sites which have been subject to land quality assessment, the information is not held centrally and could be provided only at disproportionate cost.”


Extract from the recommendations  in RWMAC's Advice to Ministers on The Ministry of Defence's Arrangements for Dealing with Radioactively Contaminated Land


"MoD should ensure, possibly in conjunction with other Government departments, that existing records of characterisation and remediation of its past and present landholdings are not lost"


"MoD should be as clear as is reasonably possible about its contaminated land holdings, and should set up a database for this purpose (drawing on LQA findings and on previous site investigation records, including desk studies and other land quality data). At the time of finalising this report (June 2000), the Ministry indicated that it was in the process of developing such a database;"


More detailed information from the RWMAC report relating to record keeping