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

Background


Chatham Dockyard played a key part in the United Kingdom’s nuclear propulsion programme. Refitting and refueling of nuclear submarines was carried out at Chatham from 1970 until March 1983.  These activities gave rise to radioactive waste which had to be disposed of.  Higher activity wastes were disposed of to BNFL Sellafield in Cumbria. However some of the lower activity wastes were disposed of by local burial within the Dockyard site.  This was done with the agreement of the Regulator HMIP (reference 1) on the assumption the waste contained short lived Cobalt 60 which would decay away over a period of 20 to 30 years. In interesting note that in an answer to a PQ about radioactive waste arrangements at Chatham, there was no mention of the disposal of radioactive waste by burial at Chatham. Hansard (26 Nov 2002: Column 172W)


More about the history of refitting and nuclear work at Chatham Dockyard


Amount of waste buried


Approximately 300 cubic meters of radioactive waste was buried between 1968 and 1986 - reference 2


Risk assessment


Reference 6  to quote the MOD “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”.   This is a significant failure in the MOD’s corporate memory.


Cobalt 60 and Carbon 14 


Cobalt 60 has a short half live of around 6 years, so that after about 24 years the amount of radioactivity will have fallen by approximately 93%. It was on this basis that it was considered safe to dispose of the waste by local burial.


However it came to light that nuclear waste arising from the submarine programme also contains significant amounts of Carbon 14 with a half life of 5,700 years. This issue was picked up by the Governments Independent Advisory Committee on Radioactive Waste Management (RWMAC) in their 2001 report on the Ministry of Defence radioactive waste management practices. Reference 3, 4.  DRPS estimates of carbon 14 in wastes arsing form the naval nuclear prolusion programme can be found at reference 5 paragraphs J and K.


Monitoring


Reference 7:  the attached MOD letter dated 13 October 2008 clearly shows that whilst environmental monitoring for Cobalt 60 was being carried out, it was not for Carbon14. This despite the knowledge dating back to 2001 that Carbon14 may be present.


Burial site


It is notable that the burial site remains MOD property this suggests that  the risks from the buried waste are not insignificant.  The site is walled off by a 3 metre high wall, whilst the site its self has reverted to scrub and woodland.

Google Earth view showing the dump site at Chatham out-lined in red

As can be seen from the image above the burial site the immediate area is undergoing extensive redevelopment including the water-front, a new marina and housing etc.

View of the dump site from Pier Approach Road the dump is behind the wall and appears to be heavily wooded

Conclusion

• The assumption that Cobalt 60 was only significant radionuclide present in the waste buried at Chatham was mostly likely wrong.
• The non-availability of a risk assessment or safety case for the burials a Chatham is a serious failing of corporate memory and does little to engender public confidence in the MODs ability to manage the safety of legacy issues over the medium and long term.
• In the absence of any available safety case, the MOD in conjunction with the Environment Agency needs to publish a revised safety case for the burial site to take account of the presence of Carbon 14 in the waste. The safety case should also demonstrate that the burial meets current standards and regulatory requirements to ensure both environmental and human safety. If this cannot be done to the satisfaction of stakeholders and the Regulators serious consideration must be given to remediation of the site.
• The situation at Chatham does little to improve public confidence in the Governments policy and the NDAs strategy for managing radioactively waste nationally and the MOD in particular. It remains to be seen how the MOD will respond to issues surrounding the waste dump at Chatham, but if Dalgety Bay is an indicator, the signs for speedy action are not good.

References


1: HMIP agreement to dispose of radioactive waste by burial 
2: MOD letter dated July 1987
3: RWMAC report on the MODs’ radioactive waste management practices 2001 - Carbon14 paragraphs 6.52 to 6.62
4:  MOD response to RWMAC regarding Carbon 14
5: DRPS estimates of Carbon14 in waste streams arising from the Naval Nuclear Propulsion Programme paragraphs J and K
6: Letter dated 7 August 2009 from MOD providing information on burials of radioactive waste at Chatham
7: Letter dated Medway Council dated 29 May 2009 with attached letter from MOD dated 13 October 2008

Failure to provide accurate information in response to FOI requests

On 18 October 2011 MOD was asked for information about sites contaminated with Radium including those overseas


“Could you please provide the following information a list defence sites in the UK and overseas that have been or might have been contaminated with radium that have been disposed of since 1945. To provide details of radium disposals by on site burial, including amount of radioactivity activity, location and date since 1945.”


The MOD response can be found at the “What do they Know” website



The information provided also fails to identify the site at Hillsea Lines Portsmouth where radium has been disposed of by burial. 


This throws into doubt the accuracy and validity of the information the MOD provides in response to FOI requests.  In particular the unacceptable failings in corporate memory and breaches of statutory duty under the Freedom of Information Act to provide information held by the MOD.

Lack of an independent review of the MODs radioactive management practices

It was custom and practice that MOD would periodically seek independent review of its radioactive waste practices; benefits included engendering public confidence and the advice from the civil nuclear sector against which MOD performance could be independently bench-marked.
  
These reviews were carried out by the Governments independent advisory committee on radioactive waste RWMAC made up of experts in the field of radioactive waste management. RWMACs role in providing advice to government was taken over by the Committee on Radioactive Waste Management (CoRWM).


The last report by RMAC on MoD radioactive waste practices was published in 2001, since then there has been no further review. 


An FOI request dated 24th February 2012 asked


“it is over ten years since the last independent periodic review of the
MODs radioactive waste management practices by RWMAC.


Could you provide me with the following information :-


a: Could you please tell me why there has not been a review of MODs
radioactive waste management practices by CoWRM RWMACs successor or any
other body since 2000; and


b: if it is MODs intention to commission a review of the MODs radioactive
waste management practices.


c: If this is the case when is it intended such a review will take place.”


On the 23rd March MOD replied

“We are still working to identify any information that falls within the scope of your request 
and I apologise that we have been unable to respond to your request in the 20 days as set 
out in the FOI Act.  I will send you a final response or an update as soon as possible but 
no later than 22 April 2012. “


This seems to suggest that those responsible for policy issues such as this within the MOD have either forgotten the need for periodic independent reviews of the MOD’s radioactive waste management practices or it is now policy that no such reviews should take place.  The former suggests incompetence where as if the latter is the case, this suggests that there are issues that the MOD does not wish to come to the attention of the public or the media.  Either way this is a worrying state of affairs and only serves to weaken confidence in the MODs ability to properly manage radioactive waste arising from both the nuclear weapons and propulsion programmes. It also points out MODs failure to comply with its statutory duties under the Freedom of Information Act.


You can track progress on this FOI request on the “What Do They Know” website

23 April MOD failed to reply


As of 23 April the MOD have again demonstrated their inability to meet statutory duties and their own deadlines to provide an update by 22 April or to provide the information requested.


Update - MOD replied late on the 23 of April


"As you are aware the holding letter I provided on 23 March stated that a substantive 
response or a further update would be provided within 20 working days; taking the Easter 
break into consideration, this should have read 23 April 2012.  Unfortunately, a 
typographical error meant that 22 April was written inadvertently, and I apologise if this has 
caused confusion."


This suggests  the Government cannot get its dates right as was the case with the  Home Secretary Theresa May trying to deport Abu Qatada, the extremist Muslim cleric, Report in the Telegraph


"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 does
not 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 (MOD)
holds no recorded information that would provide an answer to the questions you have
asked in your request.” 

The response suggests that the MOD is far from keen to answer the questions, suggesting they have something to hide or they have dropped the ball on this issue.  The MOD  may also have reasons not to subject the Submarine Dismantling Project project to independent scrutiny or there are problems delivering the policy outcomes that the MOD committed to in their policy statement publshed in 2007