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.

MOD provides no evidence that MOD follows best practice for the management of contaminated land

This FOI was submitted to the MOD following concerns raised about poor record keeping by the MOD relating to contaminated land and the MOD saying that it had in place a “robust, proactive programme mirrors industry best practice, ensures the land is suitable for use and will not cause harm to people or the environment”


“I note from a recent BBC news report into radioactive contamination concerns at RAF Kinloss MOD is quoted as saying "The MoD is committed to assessing land quality across the entire defence estate. This robust, proactive programme mirrors industry best practice, ensures the land is suitable for use and will not cause harm to people or the environment.”

"I note that MOD is a member of “Safegrounds” which has produced best practice guidance for the management of radioactive contaminated land.

Could you please provide me with the audit and compliance reports that demonstrate that the MOD meets this “ industry best practice”

Also you could please provide me with me with the audit and compliance reports that demonstrate that the MOD meets “SAFEGROUNDS Good practice guidance for land quality records management for nuclear-licensed and defence sites””

The MOD replied

“I can confirm that the MOD holds no information that falls within the scope of your request. I am advised that there are no requirements for the MOD to have audit and compliance reports in relation to the management of radioactive contaminated land.”  

“There is no requirement for the MOD to follow the Safegrounds guidance for land quality records management, therefore no audit and compliance reports exist”

Full reply.

The reply clearly shows that the MOD can provide no evidence to support it's statement saying that the MOD meets “best practice” and this by implication means there are no audit or compliance systems to demonstrate that it is meeting its own policy and standards for managing radioactive contaminated land let alone discharge its legal duty of care to protect man and the environment.

It is also interesting to note the MOD in JSP375 Volume 4 the MOD Safety Health and Environment Audit manual lays down the requirement for audits to provide assurance that health safety and environmental standards are being met. The reply to the FOI suggests that this requirement in so far as the management of contaminated land and “best practice” is concerned that the MOD is ignoring its own requirements for audit and assurance.

Refrences

Safegrounds Good Practice  Guidance  for the Management of Contaminated land on Nuclear-licensed and Defence Sites; version 2

Safegounds Good Practcie Guidance for Land Quality Records Management for Nuclear-licensed and Defence Sites

MOD contaminated land and the demise of stakeholder engagement

This video features a MOD contractor talking about the cleanup of the Atomic Weapons Establishment site in suburban Cardiff. The cleanup took place some years ago. The contractor explains how stakeholders were engaged and kept informed about the project. 

Presentation slides

 It interesting to compare this with the more recent situations at sites such as Dalgety Bay  etc which have been typified by a lack of constructive stakeholder engagement and an un-willingness to address and accept liability for historic contamination.

  

I suspect a driver for more positive behaviours is the need to for MOD to realise as much money as possible for sites that are being sold for redevelopment as opposed to alienated sites which are viewed as liabilities.

The need to find resource savings has means that far less money is available for to remediate polluted sites let alone stakeholder engagement.

Staff cuts cause breach of statutory duty

I recently requested the Defence Nuclear and Environmental Safety Board (DNESB) annual reports for 2011 and 2010


MOD Response


“In the case of your request for the DNESB 2011 report (we have interpreted this as a
request for the Defence Nuclear Safety Regulator Annual Report 2011), as there is
information contained within the report which may need to be withheld from the document
for its release under FOIA, a public interest test is required.


Unfortunately the Public Interest Test is taking longer to carry out than anticipated at the
time; this is in part due subject matter expert unavailability. I am therefore unable to
provide you with a substantive response to the second part of your request at this time.
I will write to you again by Wednesday 4 July, by which time I expect to be able provide
you with a final response to your request for information. ”


This response provides a damming example of how resource cuts are causing the MOD to breach its statutory duties in relation to the Freedom of Information Act to provide the information requested with 20 working days.


I suspect that the “subject matter expert” referred to in the response are specialist staff who because of their years of experience and qualifications cost more to employ than non-specialist staff. Consequently specialist staff have been offered early retirement, enabling the MOD to meet cost and staff reduction targets.


The loss of such staff reflects a dumbing down of MODs’ technical expertise, the loss of the ability to act as an “intelligent customer” for its contractors services and the ability to be properly accountable to Parliament, the public for complex technical issues such as nuclear safety.