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.

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 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.  

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