Recent articles in the media have raised interesting questions about the safety of nuclear
weapons. Whilst the media has focused on the US military the questions raised are equally applicable to the safety of both current and and past UK nuclear weapons in particular and the MOD nuclear programme in general. The media interest has been sparked by the publication of the book "Command and Control", by journalist Eric Schlosser. The book chronicles America's terrifying nuclear mishaps and near misses.
He recounts how in one incident in 1961, days after President John F Kennedy's inauguration, two hydrogen bombs were accidentally dropped on Goldsboro, North Carolina, as a B-52 bomber went into a tailspin. Only the failure of a single low-voltage switch prevented disaster, Schlosser explained to the BBC's Katty Kay. "The bomb assumed it was being deliberately released over an enemy target - and went through all its arming mechanisms save one, and very nearly detonated over North Carolina," said Schlosser.
"And Robert McNamara had just become secretary of defence and he was terrified by this news. We nearly had a hydrogen bomb detonate a few days after JFK's inauguration that would have changed literally the course of history."
Full length interview below
Above - MIRV War-heads sitting on the delivery bus
The Guardian reported on the book and quoted the author
"The US government has consistently tried to withhold information from the American people in order to prevent questions being asked about our nuclear weapons policy," he said. "We were told there was no possibility of these weapons accidentally detonating, yet here's one that very nearly did."
Having previously read the "Limits of Safety" ( ref 1 ) by Scott D Sagan, the revelations made by Eric Schlosse the author of the book "Command and Control" are of little surprise to me as are the lessons for the UK Weapon programme.
This extract from "Limits of Safety" shows the impact on safety of failures of corporate memory when "the complete disappearance of a number of B52 airborne alert accidents from Command's organisational memory"
Various failings in the MODs corporate memory have been highlighted which suggests the problems of of institutional memory loss are still endemic and lessons of previous incidents have not been learnt.
Extract from "Limits to Safety" relating to the UK
The incident on the nuclear submarine HMS Astute where an officer was shot dead shows the importance of human factors and suggests that lessons from the past highlighted in the book "Limits of safety" have not been learnt.
Lack of root cause analysis of the problems on HMS Astute; this is a worrying indicator of the defects within the safety and management culture of MODs' nuclear programmes
Further information
List of military nuclear accidents
UK nuclear weapon accidents
Broken Arrow reports/incidents
Final Switch Golsboro 1961
Reference 1
"Limits of Safety" by Scott D Sagan Princeton Press ISBN 0-691-02101-5
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
" 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"
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
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.
