Dalgety Bay - an example of the internet empowering citizens

The recent revelations in the media concerning the radioactive contamination of the beach at Dalgety Bay may just provide the impetus to get something done to finally clear of the beach of contamination and to call the polluter to account.
MIlcon Research and Consulting played a key role in supporting the media through analysis of publically available information particularly documents published by SEPA on their website.
The example of Dalgety Bay demonstrates that public bodies can be now held to account by the empowerment of citizens through the use of the internet.  Websites such as the “What do they Know” facilitate the use of both the FOI and EIR regulations by the citizen and ensure that information provided is publicly available.

Nuclear Liabilities Management Strategy

MOD despite a statement in its own policy that NGOs must be involved in the development of the “Nuclear Liabilities Management Strategy”; MOD has confirmed through a response to an FOI request that no NGOs were involved or consulted.

This again demonstrates MOD lack of commitment to its own policies; and the continuing use of the discredited “announce and defend” approach to stakeholder engagement.
In view of the lack of stakeholder involvement in the “Nuclear Liabilities Management Strategy”, it will be interesting to see how many opportunities this will open for judicial challenge relating decisions taken to implement the strategy with all the cost and delays associated with such challenges.  In particular the requirement for strategic environmental assessments of policies plans etc and the associated duty to involve stakeholders.

It is interesting to contrast this to enlightened way in which the NDA went about developing their strategy, involving stakeholders through its development.

FOI request
“Request for Information under the Freedom of Information (FOI) Act 2000
Thank you for your email of 16 September 2011, via www.whatdotheyknow.com, in which you ask:

Can you please tell me if NGOs were consulted in the development of the recently
published MOD Nuclear Liabilities Management Strategy” and if so which NGOs were involved in the consultation. If NGOs were not involved in the consultation on the MOD “ Nuclear Liabilities Management Strategy” why were they not involved despite the commitment in the MOD “MINISTRY OF DEFENCE POLICY FOR DECOMMISSIONING AND THE DISPOSAL OF RADIOACTIVE WASTE AND RESIDUAL NUCLEAR MATERIAL ARISING FROM THE NUCLEAR PROGRAMME” That they should be involved .

This is considered to be a request for information under the FOI Act. Section 1 of the Freedom of Information Act gives an applicant the right to access recorded information held by public authorities at the time the request is made and doesnot require public authorities to answer questions, provide explanations or give opinions, unless this is recorded information held. I can confirm that the Ministry of Defence holds no recorded information that would provide an answer to the questions you have asked in your request.”

MINISTRY OF DEFENCE POLICY FOR DECOMMISSIONING AND THE DISPOSAL OF RADIOACTIVE WASTE AND RESIDUAL NUCLEAR MATERIAL ARISING FROM THE NUCLEAR PROGRAMME

MOD Nuclear Liabilities Management Strategy

Radium contamination of Dalgety Bay in Scotland

Since the discovery of radium contamination on the beach at Dalgety Bay in Scotland in the early 1990s there appears little evidence that the problem has been properly addressed and the source of the contamination removed preventing the re-population of the beach with highly radioactive fragments of radium.  SEPA in their recently published report concluded that :- 


“Work undertaken by Defence Estates has confirmed the typical number, size and
activities of point sources at Dalgety Bay. It has also shown that the beach area
continues to re-populate with high activity point sources once cleared and that it is
estimated that over a year these will number about 100 in total. Thus there remains a
hazard to the public at Dalgety Bay from these point sources, and the total number of
radioactive sources at Dalgety Bay remains unknown.


Based on the results of solubility testing, indicative committed effective doses could
range up to 128 mSv for a 3 month old infant, with the majority of the dose being from radium daughters. However, the 2010 work has indicated that the solubility of these sources may be greater than previously expected (25% rather than up to 15%). Doses could also be greater if the relatively small number of samples subjected for leaching was not representative of the population as a whole. Overall our 2006, 2009 and this 2011 report have shown that several of the sources recovered from Dalgety Bay could give committed effective doses in excess of the relevant value for some age groups, prescribed in the Statutory Guidance issued to SEPA by the Scottish Government for Radioactive Contaminated Land.


Direct measurements of point sources to determine potential skin doses have been
undertaken. The results have been reported separately which indicate that it is unlikely the dose rate from the Dalgety Bay sources could exceed the relevant criteria specified in the guidance issued to SEPA by the Scottish Government for Radioactive Contaminated Land.


The potential committed effective doses from Dalgety Bay point sources remain
significant. The primary pathway of concern is via ingestion and as any potential effects (e.g. cancer) may take many years to be expressed and be unlikely to be easily attributable to an exposure from a visit to Dalgety Bay.


The locations and suitability of the current signage, as an optimal intervention measure, should be reviewed. Given the numbers of people using the beach there is also a need for an ongoing monitoring and recovery programme to reduce the hazard present on the beach. In the longer term, as radium has a half life of 1600 years, a programme of work to determine the primary source of the contamination at Dalgety Bay beach and isolate it from the environment may be the only manner in which the level of contamination can be reduced to a negligible level where no further interventions are needed. Given the potential costs involved of developing any robust risk assessment this approach to isolate the contamination from the environment may be the most cost effective approach to mitigating the contamination in the long term. 


The absence of any programme to isolate the radioactive contamination at source will mean that sources which pose a significant hazard to health will continue to be present on the beach at Dalgety Bay. It is concluded that a programme to identify the primary source or sources is needed to reduce the number and hazard of these sources to the public using the beach at Dalgety Bay. “


A point to note is that a recent Press report indicates that material from the beach has been used in children’s sandpits; I do not believe that the risk assessments took account of this possibility.


The Committee on the Medical Effects of Radiation (COMARE) has been tasked to provide advice on the health effects of radium exposure at Dalgety Bay, but has yet to publish its findings.


“Dalgety Bay
The appearance of radium particles at Dalgety Bay first came on the committee’s work programme back in 1990. The discovery of much smaller particles recently has seen this item reappear for further consideration. A site visit by members of the Dounreay Working Group was carried out on 13th May 2008. The committee is continuing to liaise with the MoD and SEPA on this matter. The committee will also be kept aware of other similar contaminated sites as and when issues arise.”


Background information about the historic use of radium by the Ministry of Defence and the problems this created with regard to contaminated land can be found in a report by RWMAC dating back to 2000.


Most recent Press articles as of October 2011

• Daily Express
• Rob Edwards Sunday Herald
• Daily Record
• Dunfermline Press

I find it most surprising that after 20 years the beach still  remains contaminated and a significant risk to those who use it; that SEPA, has so far failed to make the “polluter pay”  to clean this contamination up and make the beach safe for unrestricted use. The present publicity relates to the beach little has been said about the potential contamination inshore from the beach.

In response to the press reports the MoD insisted that it took safety very seriously. “We have yet to see the latest findings from SEPA,” said a ministry spokeswoman. “Should significant risks present themselves then SEPA  has the necessary statutory powers to address these.”

This shows how the MOD is doing its best to wash its' hands of this issue and leaving it to others to clean up, so much for MOD saying it takes safety seriously

Site update

Links to the Milcon Research and Consulting pages on Facebook and to the FOI requests on the "What do they know" website have been added to this Blog.

These can be found on right side of this page under the list of external links.

Staff cuts on submarines impact on nuclear safety

Telegraph reports

Submariners sacked at sea despite MoD promise

“A fifth of submarine medics serving on board Trident nuclear deterrent and hunter killer submarines have been axed, including one who cared for the wounded on the HMS Astute after a crewman went on the rampage. It is understood that several sailors were told they were losing their jobs while conducting covert operations after their captains received a signal at sea from the Ministry of Defence”

“Medical Assistants (Submariners), known as MASMs, play a key role as they have to give both primary and secondary care to personnel on board when the boats are many miles from land. They also provide the main radiation checks and radiological safety on the Navy’s 11 nuclear powered submarines.”

“Their role is so important that if there are less than two on a Vanguard nuclear deterrent boat it cannot sail.”

“We were told that the Submarine Service was protected from cuts but now medics have fallen into the bracket which is absurd,” one submariner told The Daily Telegraph. “Submarine medics are sought after but we a losing almost a quarter of our quota of available medics.”.

“It is understood that between 15 and 25 out of 100 deployable medics have been sacked. The medics receive two years intensive training, including NHS placements, and train intensively on dealing with radiological illness and exposure. On special missions a doctor will join them on board.”

If true this indicates how safety is again being trumped by the urgent need to find cost savings. I also suspect that no assessment of the impact of these cuts on safety has been carried out, as required by para 45 of Chapter 3 of JSP 815 “Management of Organisational Change”. The MOD failed duty to respond to a FOI request on this issue dating back to July, despite a legal duty to do so within 20 working days.

Below is an extract from a course prospectus that gives a good indication of Medical Assistants (Submariners) and the their radiation protection duties.

• I.A.W City and Guilds Radiation Safety Practice Scheme Handbook 7410
• Biological Aspects of Ionising Radiation
• Radiation Protection
• Radiation Detection and Measurement
• Structure of Matter and Radioactivity
• Dosimetry
• Storage and Transport of radioactive material
• Accidents and Incidents.
• Industrial uses of radioactive material
• Regulation and Guidance
• Environmental Control

This Guardian report on the 2010 DNESB annual report gives an indication of how the MOD is using the cuts in the number posts as a means of reducing the number of vacant SQEP posts which gives the appearance of an improvement in the situation.

SQEP staffing has been raised as a significant risk for a number of years in both the DESB and DNESB annual reports. See para 16 of the 2010 DNESB report.

So the statement “A Royal Navy spokesman said: "There will be no shortage of medical personnel on our submarines. Redundancies are only being made in surplus areas."  This seems very strange when set against the 2010 DESB and DNESB reports leaving open the question as to what is the true position!!  

The cuts also demonstrate how little notice Ministers take of reports from the MODs main nuclear and safety committees and the Defence Nuclear Safety Regulator.