Latest update on Carbon 14 at Chatham

This post includes the the responses from the MOD and the Environment Agency (EA)

FOI request to the Environment Agency 11 August

Dear sir

                the MOD in response to a recent FOI request (ref 1)  has said that  0.95 GBq of Carbon 14 was disposed of by burial at Chatham Dockyard.  The MOD had previously disclosed that the waste buried was short lived Cobalt 60. Has the EA been informed of this new information, if so what action is the EA taking to ensure the MOD provide updated risk assessment and ensuring that the burial site meets Regulatory standards.   I feel that this is important, in that unlike other radioactive waste disposal sites, this site is in an urban area about to undergo redevelopment (ref 2) . Background information (ref3).

References

1: Request for Information under the Environmental Information Regulations 2004 Further to my letter of 26 July 2013, I am now in a position to provide you with a substantive response to your request for information regarding nuclear waste disposal at Chatham Docks.

2: The Chatham Waters development

3:  Chatham an urban nuclear waste dump and a lasting legacy of the nuclear submarine programme


Environment Agency (EA) Response 30 August

"Thank you for your enquiry in respect of a radioactive waste burial at Chatham, Kent.

We have been aware of the authorised disposal of waste from the site at Chatham where the 
Ministry of Defence (MOD) operated part of the site as a submarine refuelling facility (both as Her Majesty’s Inspectorate of Pollution (HMIP) and now as the Environment Agency).

HMIP was originally made aware that the wastes disposed of were primarily based on Cobalt 60 and that MOD’s environmental monitoring programme has also been based on Cobalt 60. We have recently (in 2012) been made aware of the presence of Carbon 14 and earlier this month (August) of a maximum estimated activity - about 0.95 Giga Becquerels of Carbon 14 disposed within this waste. MOD disposed of approximately 9000 cubic metres of waste at this site. Assuming the maximum activity of Carbon 14 this indicates an estimated activity concentration of about 0.04 Mega Becquerel per cubic metre or 0.032 MBq per tonne. 

You asked what action we are taking to ensure that the MOD provide an updated risk assessment. In answering this we have taken into consideration current legislation and not legislation in force when the disposals were made. If MOD or any other operator were to dispose of these wastes at the activities they contain today such wastes would be classed as “Out of Scope” under the Environmental Permitting Regulations 2010 (Exemption Orders) – less than 10 Bq/g for Carbon 14 and 1 Bq/g for the previously declared Cobalt 60. As such the material or waste that was disposed would not be classified as radioactive waste. 

The basis on which the numerical values and waste disposal criteria have been developed are mainly related to the radiation dose which might be received by a member of the public. For out of scope values the criteria adopted for artificial radionuclides are based on a radiation dose of 10 microsieverts per year to a member of the public. These dose criteria have been selected on the basis of representing an appropriate level of risk below which regulation is not necessary In this particular case disposal made historically by the MOD at Chatham would now meet the criteria for being out of scope of regulation and regulatory control. Radiation impact assessments conducted take into account a wide variety of possible pathways and assume that no controls are placed on the disposals. Therefore we do not need to revisit the MOD risk assessment at this time.      

In addition we have with discussed with MOD how these wastes were actually buried and 
ultimately capped when the site was closed. As your question also referred to the adequacy of controls it may be of interest to you that the disposal of what was then classified as Low Level Waste at the Chatham burial ground was subject to a number of conditions as stated in the approval certificate. These included a condition that the waste should be capped with at least 1.5 metres of non-radioactive earth and that the specific activity of the waste (and material used for capping) must not exceed 3000 micro curies per cubic metre (111 MBq/m3). These are similar regulatory requirements that would be placed on a landfill site receiving out of scope waste today and at the end of its life or when capping a completed landfill cell.

The site is still owned by MOD. We have not been involved in detailed discussions with the MOD over the future of this site or any redevelopment. At this time there is no further engagement expected between ourselves and the MOD. If the MOD were to sell this land then the impact of any redevelopment would be a matter for the developer. If approached we would recommend that the developer contacts the MOD for information on the material buried, location and radioactive inventory. Any redevelopment might then need to take account of the specific type of development. "

The Environment Agency is to be commended on providing this information in particular the 
information about risk and dose. It is worrying that at no stage did the MOD provide this 
information."

The EA is silent on the issue that Carbon 14 was disposed of  without proper consideration of the risks.  It is notable that the EA only had knowledge of carbon 2012

• Unregulated disposal of radioactive waste at Chatham

" We have recently (in 2012) been made aware of the presence of Carbon 14 and earlier this month (August)"

The MOD knew about the Carbon 14 in 2000


14 August the MOD was asked

" Dear Ministry of Defence, 

I note in a recent answer to an FOI MOD have stated that a maximum of 0.95 GBq of Carbon-14 was buried by the MOD at Chatham. 

Could you please provide me with details of the calculations and assumptions used to arrive a this figure and also information about the statistical uncertainty of the figure. 

Could you provide me with information about the updated risk assessment for the burial site to take account of Carbon 14. 

Could you provide information why Carbon 14 has not been included in the environmental survey reports.  

Also whether or not the MOD has now informed the Environment Agency that Carbon 14 was also disposed by burial at Chatham when the original agreement from the then HMIP was for Cobalt 60. 

Could you tell me if the MOD has provided any information about the radioactive waste burial site to the developers of the adjacent land. If so what information has been provided."

The latest reply from the MOD  9 September

"Your request is being dealt with under the terms of the Environmental Information 
Regulations (EIR) 2004. I can confirm that the Ministry of Defence does hold information 
within the scope of your request. The time limit for this request, however, needs to be 
extended from the initial 20 working days. Under the EIR, a public authority may extend 
this period if it reasonably believes that the complexity and volume of the information 
requested means that it is impracticable either to comply with the request within the earlier 
period or to make a decision to refuse to do so. In this case, I am writing to inform you, that 
we must extend the time limit for responding by a further 20 working days. I will write to 
you again no later than 7 October with a substantive response."

This calls into question the information provided by the EA because the MOD has provided no 
information on the  "details of the calculations and assumptions used to arrive a this figure and 
also information about the statistical uncertainty of the figure"

Unregulated disposal of radioactive waste at Chatham

The MOD disposed of radioactive waste by burial at Chatham in Kent.  Its notable that this disposal was not subject to regulatory/statutory  control as the Radioactive Substances Act has been dis-applied to the Ministry of Defence (MOD). 

The waste was buried with the tacit approval of the Regulator under  a "gentleman's agreement" (ref1)  and on the assumption that only small quantities of short lived ( 5.26 years ) Cobalt 60 were present in the waste.  Once sufficient time (~25 years) had passed for the Cobalt 60 to decay there could be unrestricted use of the burial site

The MOD has recently confirmed the presence of 0.95GBq of long lived Carbon14 in the waste.  Because of the very long half life of Carbon 14 (5,730 years) the burial site may have to remain in perpetuity for future generations to maintain and care for.

Has the MOD  informed the Environment Agency (EA) of this new information?  If so what action is the EA taking to ensure the MOD provide updated risk assessment and ensuring that the burial site meets Regulatory standards.  I feel that this is an important issue , in that unlike other radioactive waste disposal sites, this site is in an urban area about to undergo redevelopment.Its  concerning that the MOD has previously said

“The risk assessment for the disposal of radioactive waste by burial Chatham - It has not been possible to locate this information, it would have predated the approvals granted by the 
Department of the Environment in 1980 and has not been located in any of the files recovered”. 

It is clear  from an ORNL 1977 report  that Carbon 14 was a significant activation product in pressurised water reactors (PWR), yet the MOD only discovered that Carbon 14 was an issue in PWR waste streams in 2000.

In the response to a FOI MOD said

"Our records show that work was conducted in 2000 to determine the quantities of Carbon-
14 transferred to the British Nuclear Fuels Limited site near Drigg, Cumbria.  This work 
considered the total predicted production of Carbon-14 from the Naval Nuclear Propulsion 
Programme."


The burial site at Chatham closed in the early 1980s  containing waste from the early years of the nuclear propulsion programme, the figures that MOD have calculated for Carbon 14 are based on measurements taken in waste produced in the late 1990s. It is not clear if the figures have taken account of changes in reactor chemistry between the 1970/60s and the 1990s.  I suspect the early submarines may been more "dirty" in terms of activation products (such as Carbon 14, Colbalt 60, Tritium etc) than later submarines. If this is the case then the MOD may have significantly underestimated the amount of Carbon 14 in the waste buried at Chatham.

It is also clear from the MOD response to a FOI request

"Our records show that six monthly routine radiological monitoring is carried out at the 
disposal site within the wooded area adjacent to Pier Road, Chatham. This schedule was 
agreed with the then regulator, Her Majesty’s Inspectorate of Pollution, (now part of the 
Environment Agency) in 1996. This monitoring comprises groundwater sampling and the 
measurement of surface gamma dose rates in the area.

There is currently no specific Carbon-14 monitoring undertaken of the waste at Chatham."

This is despite knowing in 2000  that Carbon 14 is present in the buried waste.

The way ahead and the future

There are advanced plans to redevelop the industrial waterside area adjacent to the site where 
the MOD buried radioactive waste. 

 The MOD needs to demonstrate that there has been no dispersion of radioactive waste including carbon 14 from the burial site into the adjacent land.  

There needs to be consideration about the effect of building and excavation work may have on integrity of the radioactive waste burial site and  the risks to people during construction and when the development is completed.

The fact that MOD has retained title to the land where the radioactive waste has been buried 
suggests the risks are not insignificant.  The best way forward may well be for the waste to be 
removed and the site cleaned up, this having been done, there could then be  un-restricted use of the site and any blight associated with the burial of the radioactive waste lifted. It would also 
demonstrate the MODs commitment to clean up the legacy of past military activities. 

Reference 

1:  A gentlemen's agreement is an informal agreement between two or more parties. It is typically oral, though it may be written, or simply understood as part of an unspoken agreement by convention or through mutually beneficial etiquette. The essence of a gentlemen's agreement is that it relies upon the honor of the parties for its fulfillment, rather than being in any way enforceable. It is, therefore, distinct from a legal agreement or contract, which can be enforced if necessary.

FOI requesting further information about Carbon 14 at Chatham

FOI requesting Land Quality Assessment

History of Nuclear Submarine Refitting 1970-1983

Sea Dumping

This page provides links to a variety of reports and papers on the sea dumping of waste including radioactive waste, chemical weapons, munitions.  The emphasis is on the UK military legacy

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