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

BBC News report on the Radium contamination at RAF Kinloss

This BBC Scotland news report on the radium contamiantion at RAF Kinloss which highlights the need to ensure records are kept to ensure future questions about contamination can be answered.
 

The report was in part supported by the work of Milcon Research and Consulting

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.