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.

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??

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.

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

Potentially contaminated RAF Sites in Scotland.

The Secret Scotland web site provides a good indication of number of sites that the  MOD own or once owned in Scotland. 

Whilst there has been considerable publicity about radioactive contamination other contaminates that may be present include  chemical weapons, heavy metals, asbestos, organic solvents and  ordnance.  It is also notable that Gruinard island in Scotland was the site of a biological warfare test by British military scientists from Porton Down in 1942, during the Second World War. Starting in 1986 a determined effort was made to decontaminate the island.

I believe it 's the MODs social and legal responsibility to identify contamination including radioactivity and the consequent risks to man and the environment at these sites and proactively make this information available online.  In fact there is a stautory duty in the Environmental Infomation Regulations that requires authorities to :-

"(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."

The list below taken from the "Secret Scotland" website lists some of the RAF stations in Scotland.  The list provides a good indication of the scale of the defence estate past and present.

.

RAF 13 Group Stations

RAF Airfields Clyde

RAF Alness

RAF Annan

RAF Ayr

RAF Balado Bridge

RAF Banff

RAF Benbecula

RAF Bishopbriggs

RAF Black Isle

RAF Brackla

RAF Buchan

RAF Castle Kennedy

RAF Connel

RAF Donibristle  (Dalgety Bay)

RAF Dornoch

RAF Drem

RAF Dumfries

RAF Dundonald

RAF Edzell

RAF Elgin

RAF Errol

RAF Findo Gask

RAF Fullarton

RAF Gailes

RAF Grangemouth

RAF Greenock

RAF Grimsetter

RAF Invergordon

RAF Kirknewton

RAF Kirkton

RAF Kirkwall

RAF Leuchars

RAF Lossiemouth

RAF Machrihanish

RAF Macmerry

RAF Milltown

RAF Montrose

RAF Oban

RAF Peterhead

RAF Pitreavie

RAF Prestwick

RAF Skeabrae

RAF Tain

RAF Tealing

RAF Tiree

RAF Turnberry

RAF Turnhouse

RAF West Freugh

RAF Wick

RAF Wigtown

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

Disposal of Radium by burial Portsmouth Hampshire

Whilst the radium contamination due to the disposal of radium residues by burial at Dalgety Bay is well known; it is interesting to note that radium wastes arising from defence activities were also disposed of by burial at Hilsea in Portsmouth Hampshire.

By way of background a recent article in the Guardian MOD lists sites not previously known to have been contaminated with radium and sites previously known to have been contaminated with radium. 

It is notable that the site where radium was disposed of by burial at Hilsea Lines Potsmouth was not included in either list. This despite MOD referring to Hilsea Lines  in response to a PQ in 1998

FOI request


Dear Department for Environment, Food and Rural Affairs,


Could you please provide me with the information you hold about the radioactive waste buried at Hilsea Lines. I have attached an extract from Hansard that may be of help


Hansard 9 Feb 1998 : Column: 72


“Radioactive Waste


Mr. Hancock: To ask the Secretary of State for Defence in what years Army personnel from 43 Command Workshop were ordered to dispose of low grade radioactive waste at Hilsea, Portsmouth; and what plans are available relating to the disposal. [27881]


Mr. Spellar: Army personnel from 43 Command Workshop disposed of low grade radioactive waste at Hilsea lines during 1978. Records dating from 1977 for this work are held in MOD files. The burial of the waste at Hilsea lines was approved by the Radiochemical Inspectorate of the then Department of the Environment. The Inspectorate then granted unrestricted access to the sites. Maps showing the locations at Hilsea lines of the buried waste were passed by the Ministry of Defence to the Property Services Agency of the Department of the Environment”


It is gratifying to find that the EA still holds information about the location of the buried Radium waste


Reply from the Environment Agency


RE: Request for information under the Freedom of Information Act 2000 (FOIA) / Environmental Information Regulations 2004 (EIR) 


Thank you for your enquiry which was received by this office on 1 November, 2011. 
Requests for information that is recorded are generally governed by the Freedom of Information Act 2000 (FOIA). The information you have requested is environmental and it is therefore exempted from the provisions of FOIA by FOIA s.39(1). We have therefore considered your request under the provisions of the Environmental Information Regulations 2004 (EIR). 


I enclose plans of the location of the burial of radioactive waste in 1978. The report, we have on file, states that this would be Area B on the attached plan, “Hilsea Lines 1.pdf”. The centre of Area B is at National Grid Reference SU 66464 04208.


Download  maps and correspondence  


Maps from Google Earth showing the location of the radium buried at Hilsea Lines Portsmouth

Maps from the Environment Agency 

.

Ministerial Visit to Dalgety Bay

 It’s interesting to note from a recent PA report on the visit of Defence Minister Andrew Robathan.  He said that “the Ministry of Defence does not deny liability” and went on to say “But I don't think you would expect us to accept liability before we know exactly what the situation is.”


Video report from STV


This is surprising since the MOD has known about the contamination since 1990 and even produced its own risk assessments; surely enough time has passed and information gained to establish the responsibility for the contamination based on reasonable probability.
  
The reference to “industrial sites and ship-breaking” and the “need for further investigations”, seems like an attempt to further muddy the waters and play for even more time.
The reference to “earth movement which of course has of course disturbed a great deal of stuff” suggests that buried radium residues may have been disturbed and brought to the surface with a consequent increase in risk.


It seems that MODs continuing failure to accept that in all probability that the MOD is responsible for the contamination of Dalgety bay is very likely to lead to SEPA designating Dalgety Bay as radioactively contaminated land.


It’s also interesting to see how MODs miss-handling of the radium contamination at Dalgety Bay, and in particular the failure to apologise or accept liability for the contamination may well have played a significant part in shaping people’s views about the options for managing the decommissioned nuclear submarines stored on the Firth of Forth at nearby Rosyth Dockyard. 

Link to press report

Link to press report concerning Devonport and Dalgety Bay

Dalgety Bay provides a classic example of the miss-management of an environmental issue causing reputational damage across all business areas. 


The situation has moved from one concerning essentially scientific and objective decisions to a much more difficult situation primarily driven by ethical and political considerations. This is especially true in the current political environment where the SNP is seeking success in the up-coming referendum on independence.   


31/1/12  (UKPA)  reports


More tests due on bay radioactivity


Further investigations are needed at a beach where radioactive particles were found before anyone should take full responsibility, Defence Minister Andrew Robathan has said.


The Tory MP visited Fife to hand over a draft plan for further action to the Scottish Environment Protection Agency and to see the contaminated area for himself.


It comes after "significant" sources of radiation were discovered at Dalgety Bay on the Firth of Forth coast.


The contamination is thought to stem from residue of radium-coated instrument panels used on military aircraft which were incinerated and land-filled in the area at the end of the Second World War. The area faces the threat of being designated Radioactive Contaminated Land for public protection.


During a short visit to nearby Rosyth, Mr Robathan said the Ministry of Defence does not deny liability and questioned whether a clear-up of the site is needed.


"There was of course a Royal Naval air station here. It closed 53 years ago," he added. "Who knows who's liable. We're not denying liability but I think we need to be quite clear how this contamination has come about.


"For instance, there has been industrial sites. I understand there has been a ship-breaking yard just down the way. There's been earth movement which of course has of course disturbed a great deal of stuff. There's been housing estates built.


"We don't say that we are not in any way willing to help. We are willing to help. But I don't think you would expect us to accept liability before we know exactly what the situation is.


"We are therefore looking at this and we are willing to co-operate with the environment protection agency and others to find exactly what the situation is and then we can determine who is responsible for clearing it up, if there is a need to clear it up."
Last week former prime minister Gordon Brown, MP for Kirkcaldy and Cowdenbeath, called for urgent action to clean up the site. He has previously urged the MoD to "accept responsibility"

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.  

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.

MOD policy on contaminated land and alienated sites

In response to a FOI request about how MOD responded to the recommendations contained in the 2000 report by RWMAC    “RWMAC's Advice to Ministers on The Ministry of Defence's Arrangements for Dealing with Radioactively Contaminated Land“. It is clear from the response to action 12 that the MOD has no intention of identifying  what contamination exists on land that it has disposed of prior to the LQA programme such as Dalgety Bay.  


It is also clear from the response to action 12 of the RWMAC report that MOD believes this responsibility lies with Local Authorities.  Local Authorities hold few if any records that would assist them in identifying contamination on former MOD sites let alone the financial resources to support such activity.  


I believe it is important for the safety of the environment and the public, that risks from defence related pollutants are identified and if necessary remediated.  Examples of such pollutants are :-

• radioactive substances such as  radium, 
• chemical weapon residues such as mustard gas, 
• asbestos, 
• organic solvents, 
• explosives and ammunition
• toxic heavy metals such as mercury, lead and cadmium 

I also believe that it is the MODs’  responsibility to  identify where there is a legacy of pollution from defence activities  and where identified as the polluter, MOD should pay to for any clean up rather that  pushing off the responsibility onto poorly resourced local authorities  and council tax payers and Regulators 


RWMAC ACTION PLAN page 3 


Action 12
“MOD should give thought to the feasibility of compiling information on disposals of land predating the LQA programme, where radioactive contamination might have been involved.”


MOD response 


“The introduction of EPA 1990 Part 2A places the responsibility for inspecting land with the local authority to identify land contamination.”

Maralinga a lasting legacy of British nuclear weapons tests in Australia

 The Sydney Morning Herald reports

“Ten years after the all-clear, Maralinga is still toxic

More than a decade after the Howard government hailed the clean-up of Maralinga as completed, the government is continuing to support remediation at the former British nuclear weapons test site.

Confidential files released under freedom-of-information laws show Canberra officials have at times been mainly concerned with ''perceptions'' of radioactive contamination while rejecting a request by the Maralinga Tjarutja Aboriginal community for a site near the Maralinga village to be cleared of high levels of contamination. Files released by the Department of Resources, Energy and Tourism show erosion of the massive Taranaki burial trench north of Maralinga, described by officials as ''a large radioactive waste repository'', has required significant remediation. Other burial pits have been subject to subsidence and erosion, exposing asbestos-contaminated debris.

While the documents indicate ''no radiological contamination of groundwater'' has been detected, the government has been obliged, under its 2009 agreement with Maralinga Tjarutja for the handback of the test site, to initiate further work.

The Taranaki trench was used to bury radioactive debris and soil, mainly from numerous ''minor trials'' - British nuclear weapons safety and development experiments - that between 1956 and 1963 caused the heaviest radioactive contamination.

A brief prepared in April for the Minister for Resources and Energy, Martin Ferguson, questioned the capacity of the Maralinga Tjarutja to manage the site.

The files show the government declined requests by the Maralinga Tjarutja to clean up the trials site closest to the village.

The ''Kuli'' site, east of the airstrip, was used to conduct 262 trials, which dispersed 7.4 tonnes of uranium into the environment.

While a partial clean-up in 1998 removed some larger uranium fragments, reports released under freedom of information show surveys in late 2001 and early 2002 found the spread of fragments was much greater than assessed.

The contamination was not assessed as a radiological hazard but the uranium toxicity prompted consultations on a clean-up of the site, and the Maralinga Tjarutja expressed concern about a risk to children playing on the ground.

Federal officials were more concerned that adults could wrongly interpret the yellow uranium fragments as meaning the site was radioactively contaminated, ''which could create an image issue''.

Alan Parkinson, a retired nuclear engineer and whistleblower who questioned the management of the clean-up, yesterday said the remediation had only been partial and ''the remarkable thing really, is how little [radioactive material] we buried''.”

It should be noted that the tests resulted in contamination not just due to uranium but also plutonium and beryllium

Maralinga - Background Information

British nuclear tests at Maralinga occurred between 1955 and 1963 at the Maralinga site, part of the Woomera Prohibited Area, in South Australia. A total of seven major nuclear tests were performed, with approximate yields ranging from 1 to 27 kilotons of TNT equivalent. The site was also used for hundreds of minor trials, many of which were intended to investigate the effects of fire or non-nuclear explosions on atomic weapons.

The site was contaminated with radioactive materials and an initial cleanup was attempted in 1967. The McClelland Royal Commission, an examination of the effects of the tests, delivered its report in 1985, and found that significant radiation hazards still existed at many of the Maralinga test areas. It recommended another cleanup, which was completed in 2000 at a cost of $108 million. Debate continued over the safety of the site and the long-term health effects on the traditional Aboriginal owners of the land and former personnel. In 1994, the Australian Government paid compensation amounting to $13.5 million to the local Maralinga Tjarutja people.

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