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

Dalgety Bay the MOD is unable to locate records about the sale of radioactively contaminated land and the local Community Council appeals to the public for their help.

"Dalgety Bay & Hillend Community Council

See the item of 3 October for details of what has prompted this reply
The Chairman writes: A reply from Moray Estates indicates that "They being professionally advised, could equally assume that had clear and accurate information been passed over relating to the exact nature and content of the salvage area in question then, it would be unlikely the Estate would have completed the purchase".

On this reply PLEASE NOTE THAT IF ANYBODY IN THE LOCAL AREA HAS KNOWLEDGE OF ANY OPERATIONS PARTICULARY IN RESPECT OF DONIBRISTLE AIRFIELD ON INCINERATION, DUMPING OF MATERIAL OR OTHER WORKS IN RELATION TO THE FORESHORE IN DALGETY BAY DURING THE 1950'S AND 1960'S, PLEASE CONTACT THE CHAIRMAN cmcphail.oceanwheels@btinternet.com or tel  01383 823750. 

YOU MAY HAVE IMPORTANT INFORMATION WE CAN SEND TO THE MOD AND SEPA."

Letter from MOD to Colin McPhail MBE leader of Hillend Community Council

Dear Mr McPhail,

DALGETY BAY FORESHORE RADIATION

Thank you for your letter of the 6 August 2012. I can confirm that a copy was forwarded to the Rt Hon Andrew Robathan, whilst he was still the Minister for Defence Pensions, Welfare and Veterans, as you requested. Please accept my apologies for the delay in confirming this and for replying to your letter.

As you will be aware we are now in the process of finalising arrangements to commence Stage 2 of the Investigation Plan and hope to have everything agreed ready to start in October. This will include engaging with residents, and I would like to thank you for your offer of assistance. I understand that my officials have already been in touch in this regard.

With regard to the sale of the former RNAS Donibristle, it is unfortunate that  we have not been able to establish the exact details of the documentation which was provided as part of the sale. We cannot therefore, comment on whether or not the information in question was passed across. What is certain is that we would have complied with the practice and legal requirements of the day. Given the fact that the salvage section was still present at the time of sale, combined with the breadth of the proposal put forward by the Moray Estates Development Company in respect of the site, it would seem fair to assume that they had a detailed knowledge of the site before committing to its purchase.

Returning to the Investigation Plan, we remain committed to delivering the investigation in order to assist SEPA to determine the nature and extent of the problem and what needs to be done to ensure the protection of the local community.

Again, please accept my apologies for the delay in responding.

Yours sincerely,

Mark Hutchinson
Chief Operating Officer
Defence Infrastructure Organisation
DESK 9, LEVEL 5 ZONE A, MOD MAIN BUILDING , WHITEHALL, LONDON, SW1A 2HB
MOD telephone: 9621 78294
Telephone:   0207 807 8294    0207 807 8294?
Fax:   0207 218 2470    0207 218 2470
Email: DIO-COSOpspport@mod.uk
Website


The letter makes it clear that the MOD assumed that it would seem fair to assume that the Moray Estates Development Company had a detailed knowledge of the site before committing to its purchase. This is clearly an attempt to shift liability away from the MOD onto the Moray Estates Development Company.   The MOD has not given in the letter any evidence to back up this assumption. It also calls into question how many other situations there are, where the MOD has sold land  making the same assumption.



DALGETY BAY FORESHORE RADIATION  e-petition

WHAT CAN YOU DO?

You can sign our official UK Goverment e-petition, and you can join our email campaign. Please do both! Urge everyone you meet to do the same

"I respectfully ask the Ministry of Defence and Scottish Environment Protection Agency to state that remedial work on the contaminated foreshore area in Dalgety Bay will begin immediately after the investigation plan is satisfactorily completed and that those deemed responsible for the contamination will fund the work and have it completed by the end of 2013"

Dalgety Bay the Music Video

An interesting example of how issues involving radioaactivity enter popular culture and have the potential to go viral.

It should noted that its radium not plutonium at Dalgety Bay. But I sure that this detail will be lost for most people watching the video. What will remain is a lasting albeit wrong association of Dalgety Bay with Plutonium.

Dalgety Bay on-shore Radium Contamination

Recent press reports about Dalgety bay featuring interviews with Gordon Brown speaking about the ”new” discovery of particles of radioactive onshore at Crowhill wood should not ellicit any surprise, it appears that Gordon Brown is playing  catch-up. 


Links to recent press reports

• Courier
• STV including video
• Fife Today
• Link to a 2008 press report  before the Enviros report was published 

It’s clear from a report that MOD commissioned Enviros to produce in 2009 that the possibility of onshore contamination was an issue. The report  describes on-shore contamination including investigations of domestic properties and gardens built over the former RNAS/RAF Donibristle salvage area in the 1960s.  This and associated reports were released by Defence Estates in response to a FOI request made 2010.


Extract from the Enviros report describing areas surveyed inshore from the beach


Link to full report


“Investigation Works Undertaken


8.  As a result of the data from the first Phase Two LQA and in particular the findings relating to Property D in Zone 2A, a further phase of investigations were undertaken. The site works involved both radiological walkover surveys and intrusive investigation, the areas investigated are summarised below (Zone designation used in original Phase Two LQA are shown in brackets):

• Dalgety Bay Sailing Club Boat Park (Zone 1): Radiological walkover survey of northern area where access was previously not possible;
• Property A in Zone 2A and Properties H & I in Zone 4B: Radiological walkover survey and random soil sampling from two properties in Zone 4B.
• Radiological walkover survey and random soil sampling from one property in Zone 2A which had not allowed access during the original Phase Two LQA.
• Former Salvage Section (Zone 2A): 1m by 1m gridded radiological walkover surveys and soil sampling in the garden areas of six properties. Where radium-226 and elevated count rates were identified removal of disseminated contamination and point sources was undertaken where possible.
• Internal Monitoring: Count and dose rate surveys covering accessible areas of the ground floor of six properties on the former Salvage Section and the sailing club house. A similar property outside the impacted area was also surveyed to provide a typical background for the developments which could be used as a comparison.”

Link to full report


Reference: 


DALGETY BAY LAND QUALITY ASSESSMENT PHASE 2B: INTRUSIVE INVESTIGATION AND INTERVENTION LAND QUALITY ASSESSMENT REPORT – FINAL V1 DEFENCE ESTATES, PROJECT NO: 12920, TECHNICAL REPORT, November 2009, by Enviros Consulting.  

MOD admits that it has no clear idea of what the risk is to people from the radium contamination at Dalgety Bay

In press report in the Sunday Herald MOD is quoted as saying

"New radioactive sources have been found at Dalgety Bay and we take this very seriously. However, it is not yet clear what the level of risk is."

This statement clearly shows that despite all the surveys MOD admits that it has no clear idea of what the risk is to people from the radium contamination at Dalgety Bay

Dalgety Bay and COMARE

It is interesting to note that Dalgety Bay is included in the current work
programme of the Committee on Medical Effects of Radiation in the Environment;
but in response to a FOI request COMARE said :-

"I can confirm that COMARE has not provided any advice to SEPA or MOD on
Dalgety Bay."

This begs a question as to what is the work is COMARE doing in relation to
Dalgety Bay and for whom?

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.

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