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 - 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

Dalgety Bay the saga drags on and on......

The MOD needs to accept liability for the contamination at Dalgety Bay so that the contamination can properly identified, managed and dealt with; claims by those who suffered blight etc can be addressed. The MOD needs to implement the principles of environmental justice in its policies and decision making.

MODs reluctance to accept liability may be influenced by the precedent that might be set for the hundreds of other contaminated sites the MOD sold off since WW2, such as RAF Pulham in Norfolk

Dunfermline Press reports :- 

GORDON BROWN has asked the head of the Scottish Environmental Protection Agency (SEPA) to  make an early decision on who is responsible for the radiation leaks at Dalgety Bay. He said this was now essential if the remedial action plan to clean up the Bay area was to go ahead and be funded. It was time, he said, to name who was guilty for the leaks so further delays in cleaning up could be avoided.

He has written to SEPA after a letter to Dalgety Bay Community Council from the Ministry of  Defence. In it the Ministry says it cannot agree to fund the clean-up until SEPA makes a decision as to who is responsible for the damage at the Bay's foreshore.

In his letter Mr Brown says the delays have to be brought to an end and he wants clean-up work to begin next May. Mr Brown, who has already met the Defence Secretary and held a Parliamentary debate on the issues, told SEPA, "It is clear that we will not make progress on the remediation plan until a decision is made about responsibility for the contamination and in that context I am writing to ask when you will make a determination on this issue.

"As we understand it there has yet to be conclusive evidence suggesting that other parties than the Ministry of Defence may be responsible for the dumping of radiation materials. "The MOD say they will only fund the clean-up if they are held to be liable by you and I hope you can 
tell me when we can come to a conclusion on this matter.

"The people of Dalgety Bay have been very patient. We cannot continue with the prevarication and passing of the buck on who is responsible.

"A decision should be made as quickly as possible to protect the May 2013 timetable for the start of the clean-up."

My personal view has always been; that the evidence proves that the MOD was the probable source of the radium contamination and that by denying liability MOD has and continues to waste large amounts taxpayers payers money over the period of 20 or more years since the contamination was discovered.  

It is also very convenient that the papers relating to the sale of Dalgety Bay which may have provided key evidence about liability cannot be found. 

"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."

Its notable that the MOD is looking find a sites to break apart the decommissioned nuclear 
submarines including Roysth a few miles west of Dalgety Bay

NIS report

"MoD has published a Request for Information in the Defence Contracts Bulletin and the Official Journal of the European Union seeking responses from private owners of nuclear licensed sites in the UK that may, subject to a comprehensive and publicly transparent site selection process, be able to meet its intermediate level waste storage requirements.

Babcock Marine, owners of the Rosyth and Devonport dockyards which are being considered as candidate sites for dismantling of the redundant submarines"

In view of the way in which the MOD has handled the contamination of the beach and foreshore at Dalgety Bay, it  will be interesting to see to what extent there is public and political support in 
Scotland for the dismantling work to take place at Rosyth.

From an ethical point of view  the choice of Rosyth could be seen the MOD taking advantage of an economically disadvantaged community by holding out the chance of some short term work in exchange for taking on the legacy of the nuclear submarine programme.  Dalgety Bay provides an example of the consequences of a  legacy left by past defence activities.

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.

NAO report Managing change in the Defence workforce impact on skills

National Audit Office report Managing change in the Defence workforce published today points out the Minsitry of Defence is under pressure to make rapid financial savings, is significantly reducing the size of its workforce, by over 54,000 personnel. A report today by the National Audit Office has found that these reductions are happening in advance of the Department’s fully understanding how it will operate with significantly fewer staff.


With regard to skills the report says 


“The significant reduction in headcount creates a risk that current skills gaps will worsen. There is a significant risk that current skills shortages will worsen particularly as at least 16,000 personnel, 30 per cent of the reduction required, is predicted to occur through natural wastage, a process over which the Department has less control than redundancy.”


The recent statement by SEPA on the plans submitted by MOD for the remediation of the beach at Dalgety Bay may indicate that MOD has inadequate specialist skills to manage issues such as radioactive contamination.


"We consider that the plan, as it stands, lacks sufficient detail and have requested more information on a number of areas which include:

• timescales for implementation of each stage of the plan;
• more detail relating to the proposed investigation work;
• investigation plans for Crowhill and Ross Plantation;
• investigation of remediation options."

It has been previously pointed out that there are significant nuclear safety skills shortages. It will be interesting to see in this year’s report by the Defence Nuclear Environment Safety Board if the situation has changed

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 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