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"

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

Dalgety Bay - adjournment debate

It is clear from the adjournment debate  just how desperate the MOD is to avoid liability, the MOD is quite aware of the reputational damage the Dalgety Bay contamination issue has and continues to cause. In particular the knock on effect in Scotland in the context of the referendum on independence and MOD nuclear programmes in Scotland.  

The adjournment debate achieved little apart from even more polarising views on liability etc. The MOD attempted to discredit SEPA and question their competence as the Scottish Environmental Regulator.  The Minister Parliamentary Under-Secretary of State for Defence (Dr Andrew Murrison) approach to the debate was patronising and overbearing and yet again shows the MOD policy is to fight liability every inch of the way even in the face of overwhelming evidence.

The MODs' offer of help whilst offering no admission of liability is a cynical ploy to avoid  court action that could set a legal precedent should the MOD be found liable in the courts for the pollution it caused by historic activities involving Radium. Such a precedent would have implications for hundreds of sites across the UK such as Wig Bay Loch Rayan where there is the potential for Radium contamination and the risk of harm to both man and the environment.

Following the debate SEPA issued a statement  where Calum MacDonald, SEPA Executive Director, said: 

“I was surprised and disappointed by Dr Murrison’s comment that SEPA has been less than helpful."  

I believe its SEPA role to Regulate without fear or favour. In the past I had professional dealings with SEPA I found them to be competent, experienced, constructive and willing to listen . 

It's also clear from the debate that SEPA appears to have  better records of the MODs' historic activities involving Radium than the MOD itself.

Dr Murrison " I must say that we have already looked for some of the documents cited by SEPA but cannot find them. "

SEPA has shown extreme patience with the MOD I believe the time has now come for SEPA to take legal action against the MOD to resolve the issue without further delay

Video of the debate  starts at 21:55



COMARE

SEPA attended a meeting of the Committee on Medical Aspects of Radiation in the Environment (COMARE) today, in which the Committee made five recommendations about the radioactive contamination at Dalgety Bay.:

The recommendations were:

1. The Committee concluded that on the basis of available data to COMARE, from SEPA and Public Health England, on potential Committed Effective Doses, there are sources of potential harm to the public (at Dalgety Bay).
2. The continuing programme of demarcation and monitoring was not a long term viable solution.
3. Remediation should start as quickly as possible,
4. Monitoring & removal of radioactive sources should continue at a frequency and area determined by the Regulator, but this should be to at least current levels,
5. A list should be formed of all Radium-226 sites across the UK.

Liability for Historic Contamination - Information Management

It is clear that the MOD is doing all it can to deny all liability for sites that it has sold off or returned to owners prior to the beginning of the Land Quality Assessment (LQA) programme that began in the late 1980s.

The prime example among hundreds of sites is Dalgety Bay where extensive radioactive contamination has been found on the beach and foreshore. This was due in all probability to work involving radium used to illuminate dials etc on aircraft.

Another site which has many of the same indicators for radium contamination as Dalgety Bay is Wig Bay in south west Scotland. At RAF Pulham the presence radium contamination has been confirmed by the local council. 

In 2000 the Governments independent advisory committee on the management of radioactive waste gave advice to MOD ministers on contaminated land which included the need to preserve historic information and enabling access to that information.

"Discussion and findings

6.1 It is clear that many MoD sites will have been contaminated with radioactivity as a result of past defence activities. RWMAC therefore welcomes the LQA programme that has been set up by MoD to identify contamination, including that arising from radioactivity, within the current defence estate.

6.2 However, the search for radioactively contaminated sites as part of this programme has been substantially hampered by the lack of historical records. While the close-knit military community seems to exhibit a good "folk-memory" of likely sources of contamination, it is unlikely that this can compensate for the lack of written records. Even on the sites where radioactive contamination is known to have occurred, there is a need to identify precisely where it is located across what is usually an extensive area.

6.3 The current LQA programme focuses on the current defence estate, notably the sites which MoD wishes to divest. However, there have been disposals of substantial numbers of sites in the past of which MoD has stated it has no comprehensive record. In RWMAC's view, it is nearly inevitable that some of this former MoD land will have been contaminated by luminising activities and/or luminised materials. None of the key individuals spoken to during the course of RWMAC's work questioned this view.

6.4 The most likely form of contamination that might have existed on such sites is buried radium-226 either as materials used to produce luminising paint or the paint itself, or products that have been painted. The latter could have been burned before burial. MoD has stated to RWMAC that these disposal practices are unlikely to have caused a wider problem because radium is insoluble and therefore essentially immobile. However, when questioned by RWMAC, the Ministry had relatively little evidence (other than a few early laboratory solubility tests) to substantiate this view. RWMAC believes that significantly more work is needed before MoD's assertion that buried radium is immobile in all soil and groundwater conditions can be reliably proven.

6.5 RWMAC was not made aware of any MoD exercise to identify land disposed of before the LQA system was introduced. Because of the possibility of contamination on at least some of these sites, RWMAC believes that MoD should consider the feasibility of compiling a list of historical disposals, with consideration being given to earmarking those with the highest probability of radioactive contamination."

In the context of alienated, sites It clear that the advice on the preservation of records and the need to retain knowledge of subject matter experts and those with personal experience at sites has been ignored. In fact it appears there has been postive action taken to place key information in the national archive.  This effectively removes the information from the FOI regime since MOD can say they no longer hold the information.  Regarding information the MOD may still hold either in office or archived file lists are needed to access this information but it is clear from the MOD response to a FOI  

File lists - key to accessing corporate memory

However, we have to advise you that we will not be able to answer your request without  exceeding the appropriate limit. This is because to the only official record of registered files  is the MOD Form 262 of which there is one form for each file and part of a file opened.  There are many thousands of MOD Form 262s which make up the official file record for D Def H&S and D SEF Pol and to locate, retrieve, and extract information in scope of your request would involve some 7 man days of effort"

The answer implies that there are significant difficulties in locating files in order to inform policy and questions about issues, some only a few years old.  D Sef pol, D Def H&S and DS&C  were in turn all Directorates of MOD Head Office concerned with health, safety and the environment.  The difficulty in accessing  files means that it is very difficult to look back and learn from  previous accidents and polluting events.  So, such unfortunate incidents are likely to reoccur

MOD as modern forward looking organisation has moved away from paper based document system to an electronic documents records management system (EDRM)

This report explains the advantages of the EDRM system

"Easy location and retrieval of information The ability to find information from document libraries, as well as many other portals and intranets, has fundamentally changed the way the MoD works

Questions answered The infrastructure facilitated the development of a 'Freedom of Information' toolkit, which enables the MoD to fulfill its commitments to Central Government and the public in this area.

The new system enables the MOD to meet UK Government requirements for compliance and records management."

From difficulties the MOD has in providing answers to FOIs it appears the EDRM does not include references to old paper files held in archive and is essentially based around information to hand at the date the EDRM was implemented.

So far as historic information is concerned it appears that the MOD suffered a "corporate lobotomy" .

It is also now clear that the expensive subject matter experts who held  significant parts of the corporate memory in their heads have now left the MOD through retirement or staff cuts.

The report Information Management Assessment Ministry of Defence  March 2009 stated that

"Information is recognised as the key asset for running the business of The Ministry 
of Defence and is used to support effective data and information sharing and knowledge creation".

The examples high-lighted above and else where in this blog suggest there are significant failures in meeting recommendations in the report  Information Management Assessment Ministry of Defence  March 2009

The potential liability

This report provides an excellent overview of the scale of the problem for both the existing and alienated estate :-

Land Contamination: Technical Guidance on Special Sites: MoD Land 
R&D Technical Report P5-042/TR/01  Dr G Bulloch, J E Steeds, K Green, M G Sainsbury, J S Brockwell, N J Slade Research Contractor:  WS Atkins Consultants Limited In association with: BAE SYSTEMS Environmental Services.

Conclusion

• The MOD liabilities for the alienated estate may run  to hundreds of millions pounds of taxpayers money.
• MOD has failed to preserve records that would help identify these liabilities.
• There may have been and may continue to be  a conscious policy within the MOD of  doing everything possible to reject claims relating to the alienated estate and positively obstruct such claims by neglecting to preserve evidence of polluting processes etc; despite advice to preserve such information.
• The MOD policy is to challenge independent assessments of the risks from pollutants and/or  MODs' liability, even in the face of overwhelming evidence to the contrary.
• Communities and the environment continue to suffer blight because of the MODs', failure to take responsibility for the legacy of past activities and the consequent pollution the MOD caused.
• MOD is behaving like an ostrich and just hoping the issue will go away

Wig Bay another Dalgety Bay?

SEPA has identified the Ministry of Defence as the "appropriate person" responsible for the radioactive contamination of  the beach and foreshore at Dalgety Bay in Fife.

However it is clear from press reports that the MOD still continues to resist admitting any degree of liability by challenging SEPAs'  competence and evidence

"The MoD said it would consider the report findings in detail and respond to SEPA in due course. However, it said it had concerns over the "adequacy and validity" of both SEPA's risk assessment and its approach to the Appropriate Persons Report. A spokesman said: "We will seek an early meeting with SEPA at senior official level to raise these concerns and discuss the way forward."  Full report

I feel that MOD in denying liability, that this has resulted in a long drawn out expensive process at the end of which the MOD will be found to be liable and suffer significant reputational damage.

I suspect Defence Estates fear that admitting liability in the case of Dalgety Bay would  set a precedent for the hundreds of other sites where there is the potential for radium and other contamination; the liability running into many millions of pounds.

An example of similar coastal site in Scotland site potentially contaminated with Radium, is the former seaplane base at Wig Bay Loch Ryan. 

The Royal Commission on the Ancient and Historical Monuments of Scotland  shows that the former seaplane base at Wig Bay was used  to "break up aircraft" which in all probability contained significant quantities of radium luminised instruments etc.

Google earth shows that some of the old hard standing is now used as a car park complete with interpretation boards and open access to the beach and foreshore.

In response to a FOI request the MOD said:-
"You requested information about what subsequently happened to the radium dials that were in the flying boats which were scrapped and dismantled at Wig Bay in Loch Ryan SW Scotland.

A search of the MOD archives has not identified any material on this subject. Any documentation that has survived will be held by the National Archives at Kew."

reference 1

Image showing numerous aircraft at Wig Bay

View of the site today from the main road showing car park etc

RAF Pulham  where the  MOD held no records about radium contamination,  but where radium contamination has been confirmed.  The MOD has rejected responsibility in this case by saying

"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. 

RAF Kinloss provides yet another example of historic radium contamination and the need to ensure records are kept

Reference 1

"The Military Airfields of Britain, Scotland and Northern Island". Ken Delve, Crowood Press Ltd 2010, page 298 Wig Bay Stranraer
ISBN 978-1-84797-027-5

Ariel View

Overlay showing taxiways etc

Contamination of fish catches in the Irish sea by Depleted Uranium Penetrators

Information  has  been released by the MOD in response to a FOI request asking

"Could you please provide me with Information including reports etc
about the object recovered by fishermen mentioned at para 3, D of
the DUFERC minutes dated 19/10 1999"

In response to this,  the MOD directed me to a reply they made to a similar request

Recovered DU penetrator

The information the MOD provided only relates to the physical characteristics of the recovered round. Of particular note  is the reference made to "black and friable DU oxide" indicating  a significant risk of loose DU contamination.

This DU penetrator was one of over 6000 lying on the seabed of the Irish Sea

Extract from Hansard  HC Deb 07 February 2001 vol 362 cc1038-47

"Some 6,907 shells have been fired into the Solway, and, even allowing for misfires and malfunctions, more than 6,000 are presumably now lying in the Solway. Many of us instinctively object to the Solway being used as a radioactive munitions dumping ground by the MOD."

The MOD have not provided any information about the potential doses and intakes of DU to the fishermen who recovered the round or any information about the extent to which the fish etc caught alongside the round were contaminated with DU or whether or not the catch was sold for human consumption.

The recovery of this DU penetrator begs the question how many other similar situations may have occurred, but where the presence of a DU penetrator in the catch was not recognised or reported.

The MOD in not providing information about dose estimates from the recovered DU penetrator seem to have been negligent in their duty of care to the fishermen who recovered the DU penetrator and the public who may have consumed the fish etc caught alongside the DU penetrator. 

Chemical weapon legacy - Cover-up ??

Defence activities since the first world war have left a legacy of land contaminated with chemical weapons.  This extract from DIOlogue the house magazine of the Defence  Infrastructure Organisation Issue 2 October 2011. Some four years ago, the MOD set up Project Cleansweep to confirm that there was no risk to people or the environment from the UK’s historic programme for manufacturing, storing, handling or disposing of chemical warfare agents (CWAs).

Extract from 2nd issue of the DIOlogue newsletter published October 2011

The article mentioned that the project Cleansweep report was due to be published in the Autumn of 2011. A FOI request made in  2012 asking for the report.


FOI Request 18 September 2012

Dear Ministry of Defence,

In the 2nnd issue of the DIOlogue newsletter published October 2011 MOD regarding project "Cleansweep" said

"A comprehensive Project Completion report is due for publication this autumn, with both the Health Protection Agency and Environment Agency supportive of its findings. A copy will be placed in the Library of the House of Commons as well as being sent to MPs in whose constituencies these sites are located, local authorities and environment agencies. “Cleansweep has been a resounding success, both technically and in terms of partnership working,”

Could you please provide me with the following information

1: A copy of the "Cleansweep" report referred to the DIOlogue newsletter

if the report has not yet been published

2: when will the report will be published

3: information about the delay in publication

16 October 2012 MOD Replied

"You asked for a copy of the Project Cleansweep Completion Report or if the report has not yet been published details of when it will be and information on the delay in publication.
I can confirm that the Report has not yet been published, as two additional ground water monitoring reports on sites, that are included in the Cleansweep Completion Report are still in the process of being produced. While I am unable to say exactly when the rpeort Completion report will be published, I would be happy to provide you with a hard copy when it is,"

It is now 2013 and  as far as I am aware the Project Completion report has yet to be published..  
When asked through a FOI about specific sites and the potential for chemical contamination, the MOD are using the delay in publishing the Project Cleansweep report as an excuse for not providing information about the sites detailed in the FOI request. The also feel that it is not in the public interest to publish information about these sites.

It is notable that the Environmental Information Regulations (2004) require the proactive publication of environmental information

Dissemination of environmental information the legal duty

   4.—(1) Subject to paragraph (3), a public authority shall in respect of environmental information that it holds— 

(a)progressively make the information available to the public by electronic means which are easily accessible; and

(b)take reasonable steps to organize the information relevant to its functions with a view to the active and systematic dissemination to the public of the information.

   (2) For the purposes of paragraph (1) the use of electronic means to make information available or to organize information shall not be required in relation to information collected before 1st January 2005 in non-electronic form. 

FOI request for Information: Chemical Weapon Contamination 

Thank you for your request of 27 May 2012, this was passed to the Defence Infrastructure 
Organisation (DIO) – the Ministry of Defence (MOD) organisation with responsibility for the 
defence estate – and has been dealt with under the Freedom of Information (FOI) Act 2000 and Environmental Information Regulations (2004). 

You requested (verbatim) the following information:- 

a: Land quality assessments 
b: CW Clearance certificates 
c: Results of environmental surveys 
d: whether or not the site is owned by the MOD 
e: any other information about chemical weapon contamination at these sites; 

at the following sites :- 

 1 (FFD) Little Heath Suffolk Under the 
control of 94 Maintenance Unit 

FFD 2 Melchbourne/Riseley Bedfordshire American FFD - Station 572 

FFD 3 Norton Disney Lincolnshire Under the control of 93 
Maintenance Unit 

FFD 4 Lords Bridge Cambridgeshire Under the control of 95 
Maintenance Unit 

FFD 5 Escrick Yorkshire Under the control of 80 Sub Maintenance 
Unit 

RAF Macmerry located about 9 miles east of Edinburgh. In the past, 
the airfield may have been referred to as Tranent, or Penston 

While I can confirm that the MOD holds information within the scope of your enquiry, it is likely that some or all of it falls within the scope of a qualified exemption of the FOI Act. The relevant exemption is Section 22 (Information Intended for Future Publication) which provides that information is exempt from disclosure if the public authority holding it or another person intends to publish it at some future date, whether determined or not, and in all the circumstances it is reasonable to withhold the information prior to publication. 

The exemption is subject to the balance of the public interest. By virtue of section 10(3) of the Act, where public authorities have to consider the balance of the public interest, they do not have to comply with the request until such time as is reasonable in the circumstances. The MOD has not yet reached a decision and I will not be able to fully respond to your request within 20 working days because of the need to carefully consider the issues involved. Our decision will be made as soon as possible and I will inform you immediately thereafter.

Conclusion

MOD has failed to provide the information on the specific sites, failed to publish the project cleansweep report and failed to  disseminate environmental information as required by the Environmental Information Regulations (2004).  The MOD is using its failure to publish the Cleansweep report as a reason to withhold information

Are the MOD afraid of publishing the information because there are significant problems with chemical weapon contamination which they wish to remain hidden??