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BEACH RADIATION - GORDON BROWN'S REPORT FOR APRIL 2013
COMMUNITY COUNCIL REPORT FOR MARCH
FROM GORDON BROWN
Since the last meeting we have had sight of the Coastal Processes Report, The Investigatory Report is now available to some to view; and we now have the wealth of evidence accumulated by Colin McPhail from residents of what happened to the site in the last 60 or so years. He should be congratulated for compiling such a detailed account. With Colin’s permission I am now submitting a summary of Colin’s report to the Ministry of Defence.
THE COASTAL PROCESSES REPORT
The main conclusion of Coastal Processes Report, from AMEC, seems to be unsatisfactory. It makes no mention of the role of the MOD in dumping materials but suggests debris was shifted after the 196Os
The report states that “The foreshore (e.g. roofing material and pottery) suggest discrete supply events in the past (e.g. tipping of roofing material at an updrift location)”. The report also states that “The Made Ground that the armour stone was built to protect at Promontory 1 is thus considered likely to have historically provided much of the larger (100-500mm dia.) particle debris seen on the foreshore.”
Then the report talks of the effect of site development and says that “The natural coastline has been disrupted at four locations by human activity within the study area, with varying effect on the local coastal processes”. But Mr McPhail who has studied the coastal processes review has advised me that “The report has missed identifying the age of the pottery and roofing debris. It is wrong to assume that the residual debris consisting of pottery and roofing material from Promontory 1 has emanated and travelled with wave erosion and moved to where it is shown on the drawing before 1996 and that the rock armour has effectively cut off this supply for approximately 16 years. Protective rock armour was in place here in the 1980’s and has been replenished on various occasions. A lot of the report hinges on the establishment of rock armour in 1996 to Promontory 1 (headland in front of the Sailing Club)”. Mr McPhail concludes that “As I have stated earlier, to my knowledge the rock armour was placed there well before then”.
The Report recommends continued monitoring and inspections; no mention of any remediation to the coastal situation as described.
THE MCPHAIL REPORT
The inconclusive nature of the Coastal Process Report explains why it is important to submit the evidenced of the workings of the MOD in dumping materials so that MOD can see for itself how much waste removal and dumping was done. I believe the evidence Colin has accumulated on the history of Dalgety Bay shows the Ministry of Defence that they are the radiation polluters, who need to fund and take responsibility for the cleanup.
The facts show that –
• 28 November 1959, Moray Estates Development Co. re-acquired the estate from the Admiralty but in the deeds of sale there was no admission of contaminated land.
• 5 May 1961, Dalgety Bay was proposed as a new town to accommodate 7000 individuals on 500 acres, and it was to include residences, shopping and business areas, schools and country and sailing clubs. At this point there was no mention of any radiation.
• 1961, Moray Estates Development Co. announced it was seeking partners.
March 1962, a company known as Copthall Holdings (Dalgety) Developments was formed.
•1962, 54 acres of the airfield was taken over by the Board of trade to form Donibristle Industrial Estate which was subsequently opened by the President of the Board of Trade.
•And in July 1964, construction was announced for 1965 for 3000 houses, and a shopping centre in a £15million development
• October 1965, the first houses occupied.
• Also in 1965, Fife Council opened Hillend Industrial Estate.
The 1955 map shows a build out of the coastline as compared with the 1927 map. But this means the deposit of waste happened prior to the development of the town given the maps we have seen. It is therefore reasonable to conclude that much of the foreshore deposition came from the dumping of material - most of it incinerated - that can be identified as material that originated from Donibristle Airfield during its decommissioning and subsequent closure.
Mr McPhail’s report shows that besides radioactive particles, a number of pieces of broken crockery bearing WD markings, cutlery, bullets, aircraft dials, bits of aircraft and various old bottles have also been found in the 1990’s along the foreshore within the area of contamination that can identified as coming from the airfield. Mr Mcphail has also shown that after the Community Council in November, through its monthly newsletter “The Diary”, the Council asked for people to come forward with any information in relation to the clearance of Donibristle Airfield during its run down after World War 2 and before or after its eventual closure in 1959.
A resident witnessed in 1946 a dump of incinerated aircraft instrumentation almost overhanging the shore. Another resident said his father was employed by the MOD in the 1950’s as an aircraft fitter and was involved in taking unwanted aircraft for dumping at Dalgety Bay.
Yet another resident showed that her late father was employed by the MOD as a driver and was involved with the clearing of the airfield and the dumping of material at a coup which was a hole near a cliff in Dalgety Bay. This occurred at the end of the 1950’s - “As a pilot in the RAF I occasionally flew into Donibristle to ferry out planes including Ansons, Oxford’s, Tigers, Moths and Chipmunks”. He knew of the breaking and disposal of aircraft that was going on and was told that aircraft machinery had been dumped in the swamp of Ross Plantation.
A relative of the owner of a family roofing and plastering business had a contract with the Ministry of Works from 1940 onward for work at Donibristle Airfield. He stated that the official dump for all rubbish etc. was at what is now the Sailing Club area. After the war he remembers aircraft being dismantled in the area that is now the site of the Sailing Club.
Mr Mcphail concludes:
“From the evidence obtained from the above people, it is quite clear the MOD was involved in the disposal of aircraft material on the foreshore which included incinerated dials, paint pots etc. that has resulted in the radioactive contamination.”
My conclusion is that given that the SEPA says the materials were dumped and that they believe the cause of the radiation was materials from the planes that were dumped by the Ministry of Defence, everyone’s resolve should now be strengthened that the MOD take responsibility for and fund the clean up. “The sooner an agreement is reached the better.”
BEACH RADIATION - LATEST REPLY FROM MOD 14 MARCH 2013
Ministry of Defence
West MidlandsB75 7RL
17 The Wynd,
14 March 2013
Thank you for your letter of the 27 February raising concerns over the time being taken to release the factual findings from the site investigation undertaken in November last year.
I have been asked to provide a response on behalf of The Defence Infrastructure Organisation (DIO) Chief Operating Officer, Mark Hutchinson.
As you will be aware from the recent Adjournment Debate and Dalgety Bay Forum, DIO will be meeting with SEPA on the 14 March to provide them with the factual findings albeit with the exception of the analytical data commissioned by SEPA. The latter has yet to be published in full and rather than delay further the release of the factual findings we have agreed with SEPA to make the report available in its current form. Ultimately it will be for SEPA to agree the timetable for releasing the report into the public domain.
DIO is continuing to assist SEPA fulfil its statutory duty on a voluntary basis and I can assure you we have not sought to delay their inspection. Equally we have not sought to delay a decision on whether the area under investigation meets the criteria for designation and who the appropriate persons are to take forward any necessary remediation.
The statutory regime does however, require SEPA to study and analyse the acts of other parties since the MOD’s occupation ceased in 1959, who may have caused, or knowingly permitted, the radium to be in, on or under the land in question. Hence, they are undertaking an assessment of potential appropriate persons which we understand will be published in May. Therefore, it would no doubt help them if the Community Council’s enquiries could be widened beyond 1959.
I trust this clarifies the situation. Please contact DIO if you have any further questions.
For and on behalf of DIO
BEACH RADIATION - REPORT BY GORDON BROWN MARCH 2013
COMMUNITY COUNCIL REPORT FOR MARCH
FROM GORDON BROWN
A debate was held in the House of Commons on radiation issues in Dalgety Bay. It allowed us to force the pace to establish when the work in Dalgety Bay to clean up will be carried out.
We received an assurance that the long delay investigations report will be with SEPA on March 14th. This is unfortunately after the Dalgety Bay forum meeting and around 3 months later than planned. But it is progress on last week when the MOD was trying to blame SEPA for delays and insisted on waiting for a small piece of statistical data before they made the reports available.
This delivery date still makes a May timetable for an options study and for the risk assessment that precede it difficult.
But I will continue to press as I did on Monday for the clean-up of radiation contaminated Dalgety Bay to be completed in 2013. I suggest that December 2013 deadline is necessary to focus minds on ending the delays in agreeing the clean-up of radiation pollution.
I suggested that the Ministry of Defence (MoD) needed to cooperate more effectively with the Scottish Environment Protection Agency (SEPA).
I said that 18 months after substantial radiation contamination had been discovered, delivery on promises made by the MoD to help was still too slow.
The coastal processes report promised in October last year only arrived after I called this debate, and when it came on Sunday it was almost five months late.
Not only has "the investigations report due in January not been completed despite the fact that the Dalgety Bay forum meets to discuss it on March 11th, but the assessment of the findings, also due to be completed by January, has not yet been finished.”
All these reports are the direct responsibility of the MoD, who promised to deliver them at stage one of the investigation into radiation. The delays mean that work on assessing the risk and devising a clean-up plan - which was supposed to be completed in May and which can only be triggered by the findings of the investigations - is also set back.
I suggested that it was time for an agreement by the MoD to accept responsibility as the polluter - and to pay for the clean-up.
I reminded the House of Commons that COMARE Report (the Committee on Medical Aspects of Radiation in the Environment) had called for a clean-up as quickly as possible and that there had been 3400 particles discovered at Dalgety Bay. Five of the finds were of a serious nature.
I took exception to a MoD letter – sent when it still had to complete its work and was believed to be the polluter - which said that ‘all correspondence should be sent to SEPA, not the MoD.’
I reminded the House that the MoD, had just completed a consultation on the possibility of breaking up redundant nuclear submarines in Fife and would have to fight hard to regain the trust of local people.
BEACH RADIATION - LETTER FROM CHAIRMAN TO MOD
Colin McPhail MBE C.Eng MICE, MCIHT
17, The Wynd
27 February 2013
Your ref DIO COO 14/2012
Dear Mr Hutchinson,
DALGETY BAY FORESHORE RADIATION
I refer to the reply received from Mark Hill dated 21 December 2012.
It is our concern that there has been no sign of the results being issued ofStage 2 of the Investigation that was completed last November. It is now 3 months since the trial pits and boreholes were undertaken. We therefore look forward to the results being announced without further delay in keeping withyour agreed timetable with SEPA for the Investigation.
They say patience is a virtue, but increasingly this becomes less and less with mistrust that the DIO MOD is failing to progresss answers to resolve the contamination after some 22 years of stigma for the community.
We are still obtaining information from former people connected with the airfield and where they are deceased, from their families;on the dumping ofairfield material by the MOD along the Dalgety Bay coastline which I am toldhappened in the late 1950’s and this information is being passed to SEPA and yourselves as suggested.
I remind you of Mark’s letter and quote:
“The Department’s policy is a matter for public record. In the event that MOD is found to be an Appropriate Person in accordance with the statutory regime for contaminated land, the Department will fulfil its obligation to meet its portion of the liability and carry out voluntary action including remediation where appropriate”.
For your information, the Community Council has not identified anybody else other than yourselves responsible for the contamination.
It is important that you have these results for the next meeting of the Dalgety Bay Forum being held on 11 March 2013.
I promised to keep the community council in touch with events and development on the radiation issues at Dalgety Bay.
I am enclosing in this report the latest letter from the Scottish Environmental Protection Agency. (not yet included on the website - ed)
Because of the delays envisaged as a result of the succession of reports I have asked for a parliamentary debate on this issue yet again so that we can secure more information on a timetable for action in Dalgety Bay.
This timetable is important for us because we know that medical experts through COMARE have advised work to clean up the beach should happen as quickly as possible.
As the letter will reveal, the information from the Scottish Environmental Protection Agency means further delays in the clean up. The Scottish Environmental Protection Agency’s Operations Director has conceded that three studies have to be completed before a decision on remedial action could be made and clearly this pushes back the timetable for action months beyond the previously accepted May deadline.
I welcome of course the fact that in depth studies are being done on the scope of the pollution and I also welcome the further assessment by SEPA of the Ministry of Defences plans. But we also need a clear timetable for remedial work to start.
The worry is that we have yet to see from SEPA a decision made on who is the polluter and then on the obligations that the responsible party has for the cleanup. I have written to them saying that I want the Environment Agency to designate the polluting offender as soon as possible and I want them to agree the timetable for the remedial work so that it can be done swiftly and with proper funding. The delays are all the more regrettable because at the same time as Dalgety Bay waits Almondbank in Perth, another site where radiation substances have been found similar to Dalgety Bay, is having its clean up done now.
I have said on many occasions residents of Dalgety Bay have been patient but they cannot be expected to wait much longer. I would again ask residents to sign the petition that is on the Dalgety Bay Community Council website and I thank your chairman Colin McPhail for his persistence in ensuring the needs of residents on this important issue of concern are brought to the attention of the public authorities.
ST DAVID'S HARBOUR DECISION 8 FEB 2013
The Scottish Government Reporter has dismissed Eadie Cairn's appeal and refused planning permission
BEACH RADIATION - LETTER FROM MOD 3 FEB
The following is a letter to the Chairman from the MoD dated 21 Dec 2012
Ministry of Defence
West Midlands B75 7RL
17 The Wynd,
21 Dec 2012
Further to your letter of 9 November and our subsequent conversation at the Dalgety Bay Forum on the 5 December regarding Stage 2 of the Investigation Plan I have been asked to respond on behalf of Mark Hutchinson who sends his apologies for the delay.
As you are aware pursuant to the Environmental Protection Act 1990 the Scottish Environment Protection Agency (SEPA) is the lead regulator in Scotland for all matters pertaining to radioactively contaminated land. Consequently it is SEPA and not MOD which has ultimate responsibility for determining what remedial action is required at Dalgety Bay and who is ultimately responsible, informed by the inspection currently underway.
To this end DIO is continuing to assist SEPA on a voluntary without prejudice basis with their statutory inspection in order that the situation is resolved as quickly as possible. Any evidence the Community Council initiative yields should therefore, be passed to SEPA for their consideration. Similarly, any information received from parties such as the Moray Estates Development Company which is pertinent to the inspection should also be forwarded to SEPA.
With regard to community engagement and the road show, we discussed this at the Forum and we together with other Forum members will look to SEPA to take the lead as their inspection moves forward.
The Department’s policy is a matter of public record. In the event that MOD is found to be an Appropriate Person in accordance with the statutory regime for contaminated land, the Department will fulfil its legal obligation to meet its portion of the liability and carry out voluntary action including remediation where appropriate. It is not for MOD or for that matter any other party to pre-empt the outcome of SEPA’s inspection and we will await their findings. As you will appreciate, to do otherwise risks nugatory effort and expenditure which apart from being quite rightly open to criticism could exacerbate the situation. You will recall that the Taxpayers’ Alliance questioned the expenditure of public funds to date following publication of the Health Protection Agency’s report in October of this year.
BEACH RADIATION - REPORT BY GORDON BROWN MP FEB 2013
REPORT TO COMMUNITY COUNCIL
Gordon Brown MP
In my January report I stated that
The Ministry of Defence have had no representations from any other parties admitting culpability for dumping radioactive waste.
The Ministry now believe it is for the Scottish Environment Protection Agency to designate who is responsible for the original dumping and for funding the remediation work.
I said in January that I had written to SEPA asking them to make a dispensation as soon as possible so we can plan a start for the cleanup.
I hope that the Community Council will soon be receiving the full report which will enable the ultimate risk assessment to be undertaken which should happen alongside the development of remedial options. But I now have a reply from the SEPA saying that there was a 2 month delay in completing their investigations but that the responsible party for the bay pollution will be named soon.
The Scottish Environment Protection Agency say that if the polluter is the Ministry of Defence they will have to fund the cleanup work and take responsibility for a remedial action plan - or face legal action.
I have told the Agency that the clean up should happen as quickly a possible - and that work on removing similar radiation had already started at Almondbank in Perthshire which also had airline materials dumped on the site.
“We are currently developing documentation which will provide the evidence of which party(ies) we consider responsible for the contamination. Once a suitable remediation option/management arrangements have been identified SEPA will expect those parties who are responsible for the contamination to undertake this work.”
This means that work may not start until late summer. I hope these will be the last delays.
Give the medical advice I will continue to press for an early date for the start of work.
In the letter the agencies Operations Director Mr. Calum Macdonald stated that –
“As previously indicated, we would prefer that this work is undertaken on a voluntary basis. However, in the event that no party(ies) volunteer to undertake this work, SEPA will use its statutory powers to ensure this does indeed occur.”
“If SEPA were to use its powers it would require the formal designation of area(s) of Dalgety Bay as radioactive contaminated land following which SEPA would determine the 'appropriate person(s)' to undertake the work. Clearly, we would seek to avoid such designation due to the potential impact on the local community.”
They say that they will select the right option for the cleanup and that the option must ensure the problem does not recur and is a long term solution for protection of the public.
SEPA stated –
“We are currently developing documentation which will provide the evidence of which party(ies) we consider responsible for the contamination. As indicated earlier this document will contain information provided from the physical investigation which we are awaiting, together with information from historic maps, images and witness's. We expect our initial views on whom we believe is responsible for the contamination, and would be considered the appropriate person if the land were to be designated, to be complete in May 2013. SEPA hopes that if, following publication of its report, the MoD is identified as a party responsible for the contamination that they would undertake remediation on a voluntary basis. This would avoid the need for designation of the area as radioactive contaminated land.”
I urge residents of Dalgety Bay to sign, as your Chairman has urged, the Community Council petition calling on the Scottish Environment Protection Agency and the Ministry of Defence to sanction the earliest possible cleanup work for Dalgety Bay’s beach. The petition calls for the authorities to move from the investigation phase of their work to the cleanup or remediation phase, where the beach is cleaned up and radioactive elements are removed or covered up for good.