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.

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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

Radium contamination at RAF Kinloss

The recent  BBC report on radium contamination at RAF Kinloss was supported in part by research from Milcon Research and Consulting

In the report the MOD says "The MoD is committed to assessing land quality across the entire defence estate" this does nothing to address the issue of land that is no longer in MOD ownership. eg Dalgety Bay etc.

MOD is also quoted in the report as saying “This robust, proactive programme mirrors industry best practice,” whilst MOD is a member of Safegrounds  which promotes “Good practice guidance for the management of contaminated land on nuclear and defence sites”.  

I believe that MODs’ compliance with Safe Grounds “best practice” should be subject to independent audit and verification.

BBC Radio 4 - Face the Facts Radioactive Legacy

Milcon Research and Consulting is  a key contributor to the recently broadcast  BBC programme on  radium contaminated land. The contribution from Milcon Research and Consulting was based on information in the public domain and responses to FOI requests.




BBC reports :-
"A pretty town on the Fife coast remains under threat of an unwelcome distinction. A corner of Dalgety Bay could still become the first place in Britain to be branded as radioactive contaminated land if the Ministry of Defence does not follow through on a plan to deal with radioactive particles washing up on its shore. The MOD's accused of causing the contamination in the first place: aircraft containing potentially hazardous radium were smashed up and buried after the Second World War. The MOD's investigating the scale of the problem and ways it might be put right, but has not promised a full and final clean-up of the bay. That's despite calls for it to do so from the local MP and former Prime Minister, Gordon Brown, and a recent discovery of particles far more radioactive than those previously found. Yet Face the Facts reveals how the MOD has cleaned up other sites deemed far less radioactive; how it's sold off contaminated land for development with radium undetected; how a lack of records means it does not know where similar sites might be and how a confidential government report we've seen from the 1950s warned of the danger of radium dumps being forgotten or, in the case of privately-owned land, deliberately concealed."
Presenter: John Waite
Producer: Jon Douglas

Link to the programme web site

Related Milcon R&C blog posts


Dalgety Bay


Hilsea Lines


Pulham


Chatham 


Failure to provide accurate information in response to FOI requests

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