Dalgety Bay

From The Courier :-

"The Ministry of Defence has stressed it “remains committed” to playing an active role in finding a solution to radiation at Dalgety Bay.

As crunch talks between the MoD and the Scottish Environment Protection Agency continued well into Monday night, the MoD said that, alongside other parties, it was committed in achieving a “long-term solution” to the radioactive contamination issues on the beach and foreshore area of the west Fife town.

The two parties were locked in a meeting with key stakeholders — including senior manager (protective services) Roy Stewart, representing Fife Council — to try to thrash out plans to rid the area of the radioactive stain it has carried for 23 years.
It is hoped the talks could pave the way for a swift and decisive resolution to the problem of contamination which has emerged over the years from debris from dumped Second World War aircraft stationed at Donibristle.

Over the last three years 1,000 radioactive particles have been brought to the surface of the foreshore which has been fenced off to protect the community and visitors. One hundred particles are now washed up every month.


Local stakeholders, including the Dalgety Bay Forum, will be involved in the next stage of consultation on the outcome of Monday night’s meeting before formal plans are announced, possibly at the end of this month."

Little appears to happened with regard to Dalgety Bay since last years adjournment debate

The Courier press report on the meeting suggests that the Stakeholders and Regulators are doing their best to the MOD's feet to the fire.  But there is no mention as to whether  MOD has shifted its position in denying liability for the radioactive contamination at Dalgety Bay.

 It appears yet again  that the MOD is trying to drag the process out as long as possible and to avoid the situation at Dalgety Bay setting a precedent for the numerous other former MOD sites around the country where Radium or indeed other contaminates may be present and for which the risks to man and the environment  may well be un-quantified.

This calls into question the ability of SEPA to act as an effective Regulator so far as the radioactively contaminated land regime and the MOD are concerned

So yet another year has no gone by with little if any progress on resolving the issue of the radioactive contamination on the public beach at Dalgety Bay. 

It will be interesting to see if another year passes with no resolution and the MOD still denying liability

How Britain risked triggering nuclear Armageddon

Readers may remember media interest in operation "Able Archer"

The Guardian reported "Cabinet memos and briefing papers released under the Freedom of 
Information Act reveal that a major war games exercise, Operation Able Archer, conducted in 
November 1983 by the US and its Nato allies was so realistic it made the Russians believe that a nuclear strike on its territory was a real possibility."

It is therefore interesting to note that 20 years before a similar situation occurred in Britain a the height of the Cuban missile crisis when the world was on the brink of nuclear Armageddon.
Scott D Sagan in his book "The Limits of Safety"  describes how  in the early hours  of the 27th of October 1962 the Commander in Chief (Air Marshall Cross)  decided without reference to civilian political authorities  to raise the alert level of the British nuclear forces to " full operational capability" able to launch within fifteen minutes or less against the Soviet Union and the Warsaw Pact.  It is even suggested that the Prime Minister was unaware of the situation. Senior civilian officials  had warned that such mobilizations had sometimes caused war.

The "Able Archer" exercise suggests that the lessons of 1962 had not been learnt and what reason do we have to believe that they have been learnt today.   Sufficient to say that human factors must be at the heart of nuclear safety both civil and military. 

 It is also worthy of note that the operational aspects of the British nuclear weapons programme are only subject to MOD internal regulation rather than independent regulation by the Health and Safety Executive. So both the public and Parliament have to take on trust that operational aspects of the British nuclear weapon programme are being properly managed and safety standards maintained.  

It is worth remembering  that the MOD is and will continue to be subject to deep and damaging 
cuts; how will these impact on the safety ?

Extract from The Limits of Safety - British Alerting Actions

Nuclear weapon safety

Recent articles in the media have raised interesting questions about the safety of nuclear

weapons. Whilst the media has focused on the US military the questions raised are equally applicable to the safety of both current and and past UK nuclear weapons in particular and the MOD nuclear programme in general. The media interest has been sparked by the publication of the book "Command and Control", by  journalist Eric Schlosser. The book  chronicles America's terrifying nuclear mishaps and near misses.

He recounts how in one incident in 1961, days after President John F Kennedy's inauguration, two hydrogen bombs were accidentally dropped on Goldsboro, North Carolina, as a B-52 bomber went into a tailspin. Only the failure of a single low-voltage switch prevented disaster, Schlosser explained to the BBC's Katty Kay. "The bomb assumed it was being deliberately released over an enemy target - and went through all its arming mechanisms save one, and very nearly detonated over North Carolina," said Schlosser.

"And Robert McNamara had just become secretary of defence and he was terrified by this news. We nearly had a hydrogen bomb detonate a few days after JFK's inauguration that would have changed literally the course of history."

    

 
Full length interview below




Above - MIRV War-heads sitting on the delivery bus





The Guardian reported on the book and quoted the author "The US government has consistently tried to withhold information from the American people in order to prevent questions being asked about our nuclear weapons policy," he said. "We were told there was no possibility of these weapons accidentally detonating, yet here's one that very nearly did."

Having previously read the "Limits of Safety" ( ref 1 ) by Scott D Sagan, the revelations made by Eric Schlosse the author of the book "Command and Control" are of little surprise to me as are the lessons for the UK Weapon programme.

This extract from "Limits of Safety" shows the impact on safety of failures of corporate memory when "the complete disappearance of a number of B52 airborne alert accidents from Command's organisational memory" 

Various failings in the MODs corporate memory have been highlighted which suggests the problems of of institutional memory loss are still endemic and lessons of previous incidents have not been learnt. 

Extract from "Limits to Safety" relating to the UK

The incident on the nuclear submarine HMS Astute where an officer was shot dead shows the importance of human factors and suggests that lessons from the past highlighted in the book "Limits of safety" have not been learnt.

Lack of root cause analysis of the problems on HMS Astute; this is a worrying indicator of the defects within the safety and management culture of MODs' nuclear programmes

Further information

List of military nuclear accidents

UK nuclear weapon accidents 

Broken Arrow reports/incidents

Final Switch Golsboro 1961


Reference 1
"Limits of Safety" by Scott D Sagan Princeton Press ISBN 0-691-02101-5

Latest update on Carbon 14 at Chatham

This post includes the the responses from the MOD and the Environment Agency (EA)

FOI request to the Environment Agency 11 August

Dear sir

                the MOD in response to a recent FOI request (ref 1)  has said that  0.95 GBq of Carbon 14 was disposed of by burial at Chatham Dockyard.  The MOD had previously disclosed that the waste buried was short lived Cobalt 60. Has the EA been informed 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 important, in that unlike other radioactive waste disposal sites, this site is in an urban area about to undergo redevelopment (ref 2) . Background information (ref3).

References

1: Request for Information under the Environmental Information Regulations 2004 Further to my letter of 26 July 2013, I am now in a position to provide you with a substantive response to your request for information regarding nuclear waste disposal at Chatham Docks.

2: The Chatham Waters development

3:  Chatham an urban nuclear waste dump and a lasting legacy of the nuclear submarine programme


Environment Agency (EA) Response 30 August

"Thank you for your enquiry in respect of a radioactive waste burial at Chatham, Kent.

We have been aware of the authorised disposal of waste from the site at Chatham where the 
Ministry of Defence (MOD) operated part of the site as a submarine refuelling facility (both as Her Majesty’s Inspectorate of Pollution (HMIP) and now as the Environment Agency).

HMIP was originally made aware that the wastes disposed of were primarily based on Cobalt 60 and that MOD’s environmental monitoring programme has also been based on Cobalt 60. We have recently (in 2012) been made aware of the presence of Carbon 14 and earlier this month (August) of a maximum estimated activity - about 0.95 Giga Becquerels of Carbon 14 disposed within this waste. MOD disposed of approximately 9000 cubic metres of waste at this site. Assuming the maximum activity of Carbon 14 this indicates an estimated activity concentration of about 0.04 Mega Becquerel per cubic metre or 0.032 MBq per tonne. 

You asked what action we are taking to ensure that the MOD provide an updated risk assessment. In answering this we have taken into consideration current legislation and not legislation in force when the disposals were made. If MOD or any other operator were to dispose of these wastes at the activities they contain today such wastes would be classed as “Out of Scope” under the Environmental Permitting Regulations 2010 (Exemption Orders) – less than 10 Bq/g for Carbon 14 and 1 Bq/g for the previously declared Cobalt 60. As such the material or waste that was disposed would not be classified as radioactive waste. 

The basis on which the numerical values and waste disposal criteria have been developed are mainly related to the radiation dose which might be received by a member of the public. For out of scope values the criteria adopted for artificial radionuclides are based on a radiation dose of 10 microsieverts per year to a member of the public. These dose criteria have been selected on the basis of representing an appropriate level of risk below which regulation is not necessary In this particular case disposal made historically by the MOD at Chatham would now meet the criteria for being out of scope of regulation and regulatory control. Radiation impact assessments conducted take into account a wide variety of possible pathways and assume that no controls are placed on the disposals. Therefore we do not need to revisit the MOD risk assessment at this time.      

In addition we have with discussed with MOD how these wastes were actually buried and 
ultimately capped when the site was closed. As your question also referred to the adequacy of controls it may be of interest to you that the disposal of what was then classified as Low Level Waste at the Chatham burial ground was subject to a number of conditions as stated in the approval certificate. These included a condition that the waste should be capped with at least 1.5 metres of non-radioactive earth and that the specific activity of the waste (and material used for capping) must not exceed 3000 micro curies per cubic metre (111 MBq/m3). These are similar regulatory requirements that would be placed on a landfill site receiving out of scope waste today and at the end of its life or when capping a completed landfill cell.

The site is still owned by MOD. We have not been involved in detailed discussions with the MOD over the future of this site or any redevelopment. At this time there is no further engagement expected between ourselves and the MOD. If the MOD were to sell this land then the impact of any redevelopment would be a matter for the developer. If approached we would recommend that the developer contacts the MOD for information on the material buried, location and radioactive inventory. Any redevelopment might then need to take account of the specific type of development. "

The Environment Agency is to be commended on providing this information in particular the 
information about risk and dose. It is worrying that at no stage did the MOD provide this 
information."

The EA is silent on the issue that Carbon 14 was disposed of  without proper consideration of the risks.  It is notable that the EA only had knowledge of carbon 2012

• Unregulated disposal of radioactive waste at Chatham

" We have recently (in 2012) been made aware of the presence of Carbon 14 and earlier this month (August)"

The MOD knew about the Carbon 14 in 2000


14 August the MOD was asked

" Dear Ministry of Defence, 

I note in a recent answer to an FOI MOD have stated that a maximum of 0.95 GBq of Carbon-14 was buried by the MOD at Chatham. 

Could you please provide me with details of the calculations and assumptions used to arrive a this figure and also information about the statistical uncertainty of the figure. 

Could you provide me with information about the updated risk assessment for the burial site to take account of Carbon 14. 

Could you provide information why Carbon 14 has not been included in the environmental survey reports.  

Also whether or not the MOD has now informed the Environment Agency that Carbon 14 was also disposed by burial at Chatham when the original agreement from the then HMIP was for Cobalt 60. 

Could you tell me if the MOD has provided any information about the radioactive waste burial site to the developers of the adjacent land. If so what information has been provided."

The latest reply from the MOD  9 September

"Your request is being dealt with under the terms of the Environmental Information 
Regulations (EIR) 2004. I can confirm that the Ministry of Defence does hold information 
within the scope of your request. The time limit for this request, however, needs to be 
extended from the initial 20 working days. Under the EIR, a public authority may extend 
this period if it reasonably believes that the complexity and volume of the information 
requested means that it is impracticable either to comply with the request within the earlier 
period or to make a decision to refuse to do so. In this case, I am writing to inform you, that 
we must extend the time limit for responding by a further 20 working days. I will write to 
you again no later than 7 October with a substantive response."

This calls into question the information provided by the EA because the MOD has provided no 
information on the  "details of the calculations and assumptions used to arrive a this figure and 
also information about the statistical uncertainty of the figure"