DU Firing programme at Eskmeals - As Low As reasonably Practical ?

Reference 1

Looking back to the UK depleted uranium firing programme and in particular the firings carried out Eskmeals on the west Cumbrian coast. It is interesting to consider to what extent these firing complied with the duty to restrict exposures to as low as level as reasonably practical (ALARP).  

The  IRR99 and the IRR85 requires employers to keep exposure to ionising radiation as low as reasonably practicable. 

VJ Battery at Eskemals in the early years was essentially a traditional open butt with the addition of a roof and extract ventilation from each side of the butt. this allowed the spray back of aerosolised DU and fragements through the open air onto a apron in front of the butt.

To quote from the reports :-

 Safety Services Organisation MOD(PE) November 1983, The distribution of Depleted Uranium releases at P&&EE Eskmeals, excluding appendices.

Report summarising the measurements taken at VJ Butt P&EE Eskmeals of Depleted Uranium in air during the period 1981 to 1982.

"The penetrator on impacting with the target produced pyrophoric fragments which rapidly disintegrate and. there is a spray back-up the range over an angle of 20 degrees  for a distance of 60 metres."

"Total activity in air measurements taken outside the butt indicate that DU is being released to the environment at levels above the DAC for a period of time after firing. It is not possible to quantify the amounts.".   DAC "Derived Air Concentration" ICRP 30

"The DU dust was found to be well within the respirable size range, dust particles of this size have very long settling times and can remain airborne  for very long periods of time and if allowed to disperse from the butt may travel many hundreds of meters."

This is the  Department of Defense Superbox DU firing facility at Aberdeen Proving Ground Maryland USA. As can be seen the facility offers almost complete containment. It includes a flight tunnel with a drop down door.  The Superbox facility is seen as an example of a facility that reduces exposures to the public and workers outside the facility to a level that is  ALARP

The conclusion is that  that in the early years of the firing programme the MOD failed to meet its legal duty to restrict exposures to as low as level as reasonably practical. It is also interesting to consider that that the VJ Battery at Eskmeals was probably very quick and cheap to build compared to the Superbox facility in the USA. 

It is now also clear that the MOD failed to seek letters of agreement from the Environment Agency for the discharge of DU to atmosphere from VJ Battery at Eskmeals. This was in breach of the MODs' own policies.

Later years of the firing programme at Eskmeals

DRPS Report "Comparison of Kirkcudbright and Eskmeals Environmental Monitoring Data with Generalised Derived Limits for Uranium" June 2002 mentions that a tunnel was added to the face of VJ Butt in order to reduce discharges of DU to the environment. This acknowledged that the original firings at VJ did not comply with the requirement to restrict exposures to as low as level as reasonably practical.

References

1: HSE Reducing risks protecting people 2001

Radiation Protection Technical Advisory Committee (RAPTAC)

In response to a FOI request the MOD has released some of the minutes of the Radiation Protection Technical Advisory Committee (RAPTAC). 

This is the main Committee concerned with ionising radiation protection. The papers provide an insight in the issues of concern to MOD Officials in the late 1970s and early 1980s. 

 It is notable that the MOD have only provided 3 sets of minutes not the 10 requested.. 

 Issues of note include : 

• Nuclear test veterans 
• Retention and recruitment of Health Physicists 
•  Radiation dose limits 
• Application of the proposed Ionising Radiation Regulations to the MOD 

 Minutes 

1983 2nd meeting 
1980 1st meeting 
1979 2nd meeting 
Covering letterFOI and response 

FOI and response

Thank you for your email of 14 September 2012 requesting the following information: Could you please provide me with the following information:- 

1: Terms of reference of the Radiation Protection Advisory Committee (RAPTAC) referred to in the 12th report of the House of Commons Defence Committee Radiological Protection of Service and Civilian Personnel 
 2: date of the first meeting of RAPTAC 
 3: Agendas of the first 10 meetings 
 4: Minutes of the first 10 meetings 

We are treating your correspondence as a request for information under the Freedom of Information Act 2000. We have now completed an extensive search of archives for the information you requested and we have located the following documents.

RAPTAC 2nd Meeting 1979 – Minutes 
RAPTAC 1st Meeting 1980 – Minutes 
RAPTAC 2nd Meeting 1983 – Agenda
RAPTAC 2nd Meeting 1983 – Minutes 
RAPTAC 1st Meeting 1984 – Agenda 
RAPTAC 2nd Meeting 1984 - Agenda 

We have provided all the information that we could locate for you. These documents have been assessed under the Freedom of Information Act 2000 and personal information has been redacted under the Absolute Exemption Section 40.

Unregulated discharge of Depleted Uranium to the environment

Thank you for your enquiry dated 21 September 2012. This has been dealt with under the Freedom of Information (FOI) Act 2000.

You asked for: 

 "letters of agreement from the Environment Agency and its predecessor organisations for  the MOD to discharge of depleted uranium to the environment from Eskmeals and  letters of agreement from the Scottish Environment Protection Agency and its predecessor organisations for the MOD to discharge of depleted uranium to the environment from  Kirkcudbright." 

"I am writing to advise you that the information you requested is not held.  There is no licensing as such of the Ministry of Defence's depleted uranium firing activities. The  procedure adopted at the outset of the depleted uranium trials programme, which is still in force, is  for regulatory authorities with Health and Safety and Environmental Protection responsibilities to  be involved in the design of the safety arrangements and to visit the sites as and when they wish."

In the case of Kirkcudbright some 6,907 shells have been fired into the Solway Hansard and  there appears to be no accurate figures for the amount of DU dispersed to the environment at Eskmeals. 

JSP 392 Vol 2,  Leaflet 30  "DEPLETED URANIUM" states that there are so far as the Radioactive Substances Act 1993 (RSA93)  is concerned there are parallel arrangements, this being the case there should be letters of agreement from the environmental regulators for the discharge of depleted uranium to the environment.  The response to the FOI request shows that none were obtained  and the discharges were unregulated. 

It may be that the MOD felt that it would be pointless to seek letters of agreement form the environmental Regulators as they were unlikely to agree to the discharges and so far as the MOD were concerned it was fortunate that the RSA93 does not apply to the MOD. 

The response to this FOI request clearly shows the MOD failed to meet its own policy to seek letters of agreement from the environmental  Regulators  when discharging substantial quantities of radioactive substances into the environment.  

Extract from JSP 392 Vol 2,  Leaflet 30  "DEPLETED URANIUM" 


"3 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the 
Management of Health and Safety at Work Regulations 1999, the following specific legislation applies 
directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: 
• Ionising Radiations Regulations 1999 (IRR99) (apply directly). 
• Radioactive Substances Act 1993 (RSA93) (parallel arrangements)"



References

MOU between the MOD and Environment Agency

Loss of specialist capabilities needed to support the nuclear propulsion programme

The MOD was asked through a FOI request to provide information about loss of specialist capabilities needed to support the nuclear propulsion programme and to explore what the Union Prospect was doing to resolve the issue.


FOI Request 28 August 2012

"Request for Information under the Freedom of Information (FOI) Act 2000 

Thank you for your email of 28 August 2012 requesting the following information: 

Letters and emails between MOD Officials and the Union Prospect concerning the loss of specialist capabilities needed to support the nuclear propulsion programme and the Frame work Agreement Technical Services for the period January 2012 to June 2012. 

I am writing to advise you that we are still working to identify the information that falls within the scope of your request.  I estimate that it will take a further 20 working days to identify this information, so I will write to you again no later than 23 October 2012.  Please accept my apologies for the delay, and for not providing a response within the 20 working days set out in the FOI Act."  

• The delay in providing the information requested again points out the failure of the MOD to meet its legal duty to provide the information requested within 20 working days.
• It may also indicate that the MOD's  document and record keeping systems, even for recent correspondence are seriously flawed.
• It may be the case that the MOD does not want to release the information and wishes to hide the information for fear that it will inevitably show that the MOD is still failing to provide the required level of specialist resource to safely deliver its nuclear programmes.
• The MOD may now have become reliant on contractors and granting  concessions so that less skilled and experienced personnel can be placed in SQEP posts within the MOD's nuclear progarmmes.