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Dalgety Bay (Radiation)

Volume 536: debated on Wednesday 30 November 2011

Motion made, and Question proposed, That this House do now adjourn.—(James Duddridge.)

I have called this debate for one purpose and one purpose only: to persuade the Ministry of Defence of the need for urgent action in an area in my constituency where radioactive materials have been discovered.

The affected land on the shores of the Firth of Forth occupied by and near Dalgety Bay sailing club is a few yards from people’s homes, near where children play, and is an area where many go for walks. But in the past six weeks, materials that were dumped there by the Ministry of Defence in the 1950s—aircraft dials, aircraft paint and other materials—have been discovered, with radioactive levels that are 10 times anything witnessed before. They are an undeniable hazard, they are materials which children should not touch, and they are particles which should be removed quickly and in full.

Urgent action is necessary not just because of risks to safety, but because the Scottish Environment Protection Agency has now stated publicly that unless the Ministry of Defence brings forward a remedial plan for the area, the agency will designate Dalgety Bay a radioactive contaminated piece of land. This will be the first and only land to be designated as radioactive contaminated in the United Kingdom, and the agency says that it will nominate the Ministry of Defence as the culpable party.

Does my right hon. Friend agree that the Ministry of Defence abdicated its responsibility for the contaminated land when it unilaterally informed the local forum that it

“had no plans to continue monitoring and removing contamination from the site”?

Surely such irresponsible inaction deserves the strongest condemnation.

That was in 2010. I shall come to that.

I have had to call this debate because, despite a succession of approaches to the Ministry of Defence—letters, phone calls, a chance conversation with the Secretary of State for Defence, whom I acquainted with the issue—the Ministry of Defence has yet to instruct the necessary actions and agree that a plan for remedial work is prepared, funded and implemented.

Since 1983 I have been the Member of Parliament representing the community of Dalgety Bay. It is near where I grew up and went to school, and near where I live and where my children go to school, so I have been aware for many years of the history of the site and of the past dumping of materials there by the Ministry of Defence. Those came from Donibristle airfield, which was created in 1917, was opened, closed and then opened again, and when reopened became, like the nearby Royal Navy base, vital to the second world war effort. Even as late as 1959, when it was announced that it would be closed down as an aircraft repair yard, it employed 1,400 industrial and non-industrial staff.

In that time, disused aircraft, including aircraft dials, materials used for painting dials and other instruments, were broken up and dumped at Dalgety Bay. On that land houses were built and the sailing club was established. Since 1990 materials with some radioactivity have been detected at Dalgety Bay. In June that year, after environmental monitoring by Babcock, the owners of Rosyth dockyard, elevated radiation levels including the presence of radium 226, were found. At that time particles were removed. As was reported later, they were removed “as far as possible”, but since 1990 and at regular intervals, I and the local community council, headed by Colin McPhail, have pressed for regular monitoring of any potential threat to the safety of local residents and to reassure locals that we have consistently asked for surveys to be done, tests to be carried out and investigations to be made.

Until 17 October this year, no investigation that I have seen has yielded evidence of substantial pollution or danger. In fact, at the request of local people, the National Radiological Protection Board—now the Health Protection Agency—carried out surveys during May and June 1991, as it monitored the beach, and then in 1992, 1993 and 1994. It reported that it found only low-level contaminated material buried below a layer of soil.

That was followed in 1995 by a detailed risk assessment, commissioned from a multidisciplinary research team at the university of Aberdeen. Its purpose was to assess the implications of radiation contamination, to consider the level of risk to the public and to review the options for reducing the contamination, if that were necessary. The study found that the variations in the ambient radiation dose rate values were within normal levels and calculated that the highest ambient dose rate found at Dalgety Bay was only two thirds of that found naturally in the granite in Aberdeen.

When the inquiry team published their survey in 1998, they reported that radium contamination was present not as a layer in the sediment, but randomly distributed as particles. However, they found that the number of radiation particles found in the area surveyed was very small and, thus, the risk of coming into contact with such a particle was “very low”. They found that the risk of inhalation was also low and reported that skin contact with a particle for an extended period could produce a very small burn similar in nature and severity to a fire-ash burn, but concluded that the maximum fatal risk per year from inhaling or swallowing a radioactive particle to any user of the area surveyed was negligible; it was calculated as clearly

“less than one in a million”.

However, we rightly agreed that we would continue monitoring, and in 2006 SEPA compiled a report that concluded that further work needed to be done. It also highlighted the possibility of coastal erosion that might bring particles nearer to the surface, but said:

“The most probable effect of an encounter which lasts for a number of minutes is a skin burn. The chances of ingestion…is highly unlikely, around one in half a million per year”.

The common view locally was that during the break-up of some aircraft some of the redundant luminescent materials had been burnt, and it was likely that the resultant ash and clinker produced from burning were either buried or spread on the ground surface. It was reported:

“It is therefore possible that the action of burning of luminised dials can produce a diverse range of chemical forms”.

Since then, at our request and at the request of others, six monitoring surveys and three intrusive investigations were carried out by Entec over the course of 12 months, and they have found that the radioactive materials probably derived from a bed of ash material. But, as was reported,

“recontamination of the beach continued, indicating that either the ash horizon was not the only potential host material, or that”—


“sources continued to be present…and continued to re-contaminate the beach.”

Of the 128 particles, 48 were recovered from investigations of the ash bed, 28 from clearance surveys of the beach and coastal path, and 51 from regular visits to monitor the area. These surveys made it clear that

“the data do not indicate a reducing rate of hazard recurrence…at the site.”

I should add that, also after our request, work was also commissioned over these years by the health board, whose study of data from 1975 to 2002 did not reveal any correlation between the location of the radioactive materials and the incidence of cancer. So until a few weeks ago none of these surveys revealed any substantial risk or out-of-the-ordinary levels of radiation. Many of them were carried out at the expense of the MOD, because it rightly recognised that this monitoring was its responsibility. But in mid-October, work done by SEPA dramatically revealed particles at a level of radiation 10 times that of any previous discovery and led to the decision by SEPA, after repeated contact with the MOD, that it had to take action in the weekend of 17 to 19 November to remove potentially dangerous items. This was work that, as the correspondence makes clear to me, the MOD was willing to instruct. However, unfortunately, it would not guarantee that it would immediately remove any items discovered or submit them for full investigation.

So on Saturday 19 November, without the help of the MOD, SEPA took action and removed what it reported to be

“a second potentially high activity source”.

It was

“five times greater activity than anything previously recovered”.

SEPA also reported that a

“second source was also recovered”

and that

“a third source was found at the surface”

and that required urgent action.

So the real issue here is that there needs to be agreement on a plan for remedial action, given what we know now about the radioactive materials on the site. In October, SEPA wrote to the defence industrial office asking for assistance in monitoring and for a plan of action to repair the site. On 10 November—I quote from its letter—the MOD said, astonishingly, that

“any suggestions that the Ministry should provide a plan of action is immature at this stage”.

On 24 November, SEPA again wrote to the MOD asking for a commitment to undertake appropriate remediation and

“the delivery of a plan”


“sufficient resources and funds to enable work to be undertaken”.

However, at the most recent meeting with the Dalgety Bay officials, the MOD was

“unable to commit to undertaking any remediation following site investigation”.

That has caused SEPA to say that unless there is a plan—not just agreed in principle but produced by the MOD—it will, in March next year, designate the site as contaminated and name the MOD as the responsible party

My right hon. Friend is to be congratulated not only on securing this debate but on the dogged way that he has pursued this issue over a number of years. He will know that the beach is incredibly popular with his constituents and with mine. Does he agree that it is absolutely vital that the Ministry of Defence deals with this quickly so that our constituents can continue to enjoy this beauty spot?


We now have clear evidence that there is a radioactivity level higher than anything that has been seen before. We have a desire—indeed, a demand—locally for remedial action. The community council chairman, Colin McPhail, has said very eloquently that fears in the area need to be allayed. We have correspondence, which I have seen, between the two Government agencies, but it has failed to resolve the issues despite the urgency of the need for action. It is therefore necessary that I bring this matter to the House so that we can secure agreement on preparing and financing a remediation plan for the site.

Over the years, the MOD has funded work, including the removal of radioactive contamination from homes in the area, but the result of its work on those homes has never been disclosed. It has funded the permanent erection of signs to provide warning information to the public, but those signs now require updating. In 2009, the MOD undertook an investigation of the slipway area which recovered 100 sources of radium. The MOD analysed whether the inter-tidal area was itself the source of the contamination, but found that not to be the case. The MOD has agreed to fund three annual surveys and removal programmes at Dalgety Bay. However, SEPA believes that it has detected caches of contamination that MOD contractors may have missed. Through the re-monitoring that SEPA has done, significantly more sources of radioactivity have been found, and while the MOD contractor removed 33 sources, SEPA has removed 442 separate particles. Together with this large number of sources, the SEPA investigation has recovered four high-activity sources from the inter-tidal area of Dalgety Bay, and those are, at the highest levels, 76 times greater than anything previously reported. In the light of recent findings, SEPA now considers that any survey and removal at Dalgety Bay that was previously agreed is not enough. It believes that joint work is now required with the Health Protection Agency and that an urgent plan is required to repair the site.

The community that lives in Dalgety Bay and in the vicinity of Rosyth dockyard is a loyal and patriotic community whose patience and good will has been sorely tested. At one time, Rosyth dockyard and naval base employed 15,000 people and was the base for thousands of servicemen and women. Churchill rightly described Rosyth as the greatest defended war harbour in the world. Today, it is home to 1,500 workers who are building the new aircraft carriers, but the naval base that has been so important to the local economy has gone. The current proposal for Rosyth is that nuclear decommissioning work be done on nuclear submarines that are currently stored there. Ironically, at the very moment when the MOD is trying to persuade local people that their fears about any radiation from that nuclear source should be non-existent, it seems to be utterly slow to act on the removal of the other source of radioactivity, which is its responsibility. This is no way to treat loyal supporters of our armed forces and people who, having refitted the Polaris submarines at Rosyth, have lived with nuclear dangers for years.

It seems very strange that this country has been home to nuclear-powered and nuclear weapons submarines, nuclear power stations and experimental nuclear work at Dounreay, and yet we face the prospect, because of the inactivity of the MOD, that a small piece of land occupied mainly by a sailing club will carry the title of the only officially registered area of radiation contaminated land in the United Kingdom.

The damage to the area, the loss to the community, the disruption to local people, the reduction in property values, the loss of a public space where children can play and young people can sail are totally avoidable. That can be avoided by decisions of the MOD that should be announced today. I ask in this debate for a recognition of the Ministry’s responsibility to agree to develop and to fund a remedial action plan to clear up the Dalgety Bay site. The community council, among others, is right to demand nothing less, and, on behalf of the community I make their demands directly to the Minister this evening. I expect not only a full and comprehensive response but a decision to be announced this evening that the action that is necessary to draw up a remedial plan to clear the site at Dalgety Bay will be instructed by the Ministry of Defence immediately.

It is a pleasure to see the right hon. Member for Kirkcaldy and Cowdenbeath (Mr Brown) in his place and I congratulate him on securing this important debate. All those involved understand that there is a serious issue at Dalgety Bay. The Ministry of Defence, the Scottish Environment Protection Agency and other stakeholders who comprise the Dalgety Bay Forum all recognise that there is an issue.

I do not entirely recognise the portrayal of the situation given by the right hon. Gentleman. Since the early 1990s, we have been aware that radioactive material was being washed up on the foreshore and found on land, as he said. This material takes the form of fragments from navigational instruments and dials coated with luminescent paint with radium 226. The flakes of such paint are radioactive. We have worked with SEPA and the Dalgety Bay Forum for many years, certainly between 2007 and 2010, to understand the risk and the requirement for remedial measures. Such measures should be proportionate, sustainable and cost-effective.

We also agree that removal of radioactive sources by MOD and SEPA has reduced any hazard posed to the local population. Notwithstanding the fact that the issues have been around for some time, the general consensus has been that risks were low, as the right hon. Gentleman admitted. We took this approach because it was consistent with the advice of the Health Protection Agency, which he mentioned. Until recently, SEPA publicly acknowledged the MOD’s contribution to finding a credible solution. However, following preliminary testing earlier this month, SEPA disclosed that it has discovered higher levels of radiation than in previous tests. Naturally, this has caused a certain amount of concern among his constituents and he is right to raise that.

Given the recent finds, we agreed only last week to work with SEPA over the next four weeks to identify a programme of work that will inform the scope of any long-term credible remediation and management measures. This work will also look at interim management measures and we will continue with our existing monitoring programme. Indeed, the first meeting between the MOD and SEPA to establish a credible investigation plan occurred yesterday, which is further evidence of how seriously we take this issue.

Previously, we have acted voluntarily and discreetly to investigate and remediate radium 226 contamination affecting residential properties that have been built on the site of the former Royal Naval Air Station Donibristle. This measured approach was welcomed by the residents as our action avoided unnecessary blight, anxiety and stress. The MOD also took forward the recommendations of the Committee on Medical Aspects of Radiation in the Environment. We remain concerned that any designation of the area because of the contamination would be not only premature but disproportionate and certainly not in the interests of residents.

I must also make it clear that the location from which the artefacts and radioactive material are currently emanating has yet to be conclusively established. We are concerned that recent attempts to attract national media attention to this issue will have the opposite effect to the one intended on the local community.

To put the situation in context, the beach and the foreshore at Dalgety Bay lie adjacent to the former Royal Naval Air Station Donibristle. Our records show that Donibristle was first used by the Royal Flying Corps in early 1917. The RNAS took over in August that year, and from 1 April 1918, when the RNAS and the RFC were amalgamated, the site came under Royal Air Force control. It was put on a care and maintenance basis in 1921, and the airfield was reopened as an air station in 1925, when it was used as a shore base to disembark carrier aircraft and as a training base. Donibristle was a torpedo training school from 1934.

With the onset of world war two, the grass strip airfield came into royal naval use once more, and RNAS Donibristle was commissioned as HMS Merlin, eventually becoming an aircraft repair yard. By 1941 the yard was processing some 320 aircraft a year. A second runway was completed in early 1944, when the station had the capacity to accommodate 220 aircraft and was, therefore, pretty busy. Some 1,000 military personnel and 2,000 civilians were employed on site, and by the end of the war the total number of aircraft repaired and inspected reached more than 7,000. After the war, the site flew the flag of Flag Officer Carrier Training. In 1953, HMS Merlin was paid off, but repair and reconditioning work continued for the Fleet Air Arm.

The yard and airfield are recorded as having closed in August 1959, but there were royal naval barracks at Donibristle between 1962 and 1963. The land was subsequently sold, and some time later—in other words, well after the MOD had gone—it was developed for housing and industrial use, including the Donibristle industrial park.

We all recognise that “radioactivity” and the fact of contamination will give cause for concern, so it makes sense to ask how serious and real the risks are at Dalgety Bay. I am aware that there has been criticism of the manner in which the risk has been presented in the media. SEPA has recently found higher activity sourced at some depth—about 75cm, or 2 feet for those who deal in old-fashioned measurements—beneath the foreshore. MOD experts advise that that does not necessarily imply a step change in the risk to human health, or the need for additional mitigation measures over and above what SEPA has already put in place.

Indeed, as I have said, the Health Protection Agency has and continues to hold the view, despite the recent finds, that the risk is likely to be low—a view that SEPA has hitherto shared. Nevertheless, given the recent finds of relatively high activity, the HPA quite understandably feels it important that the risk be adequately quantified and understood, taking into account the likelihood of exposure. I therefore welcome, as I hope the House will, SEPA’s establishment of an expert group, which is charged with doing exactly that. My officials are observers to the group and stand ready to assist as required. That leads me to the calls for the MOD to develop a “credible remediation plan”.

We need to understand how the contamination at different locations is being caused. Is it, for instance, from erosion of the former refuse tip within the headland, or is it from other sources? Interestingly, the refuse tip is not documented in the 1959 contract of sale, and it is recorded only subsequently in the 1960s, on maps and so on. It is equally important to understand how radioactive sources found at depth in the foreshore have come to be there, the plausibility of their exposure by a storm event, and the impact on public health if that occurs.

The removal of what is known has ensured public safety in the short term, but an effective solution depends on assessing what might still be present and the risks from it. Moreover, what precisely would comprise an effective solution, given the current uncertainties? The answers to such questions are necessary in order to inform appropriate remediation measures. For those reasons, the MOD has offered to assist SEPA further. We are engaged with SEPA, working in consultation with it to develop and deliver the investigation necessary to help answer those important and relevant questions.

Of course, responsibility for such investigation would normally fall within SEPA’s statutory mandate for which it is funded, but I recognise that any delay would not be in the interests of residents. Moreover, my Department has disposed of material for them, so we are continuing with our voluntary assistance, which includes arranging for the disposal of material found by SEPA.

The issue comes down to this: even after the letters from the Ministry of Defence and the meeting yesterday, the Scottish Environment Protection Agency still says that, unless the Ministry of Defence can give assurances, it will designate the land as radioactive and contaminated, which is not something people want. It seems strange that the Ministry of Defence was prepared to accept responsibility for monitoring when there was no problem, but now is not prepared to accept full responsibility for remedial action. I simply ask the Minister to give a straightforward assurance that the necessary remedial action will be taken and funded by the Ministry of Defence. I think we should ask for nothing less and that he is in a position to give that assurance.

I think that the right hon. Gentleman would agree that the important thing is to know what the dangers are before getting into a great state about it, because I am afraid that there is some conflict and disagreement on this. We are engaged with SEPA on the matter, and I think that it is important that we remain engaged.

The Ministry of Defence has been told by the Scottish Environment Protection Agency that a remedial action plan is needed. It has the power to designate the land and require the Ministry of Defence to do this. It will not change its mind about whether a remedial action plan is needed, and nor should it because of what we have found in the past few weeks. All we need is an assurance from the Ministry of Defence that it will not only produce the remedial action plan with the Scottish Environment Protection Agency, but properly fund it. The Minister is in a position to give that assurance, based on everything else the Ministry of Defence has said and done in the past, and should do so now to allay the fears of local residents.

The right hon. Gentleman tells me that I am in a position to do this, but for a long time he was in a position to take further action should he have so wished. I am afraid that that is the case. Contrary to some media reports, I do not believe that it can reasonably be said that the MOD is being complacent or unhelpful. On the contrary, we have assisted and will continue to assist SEPA by undertaking surveys and disposing of recovered sources. We have remedied land-based contamination in residential areas within the former RNAS Donibristle site. We have also funded the warning signs and play an active part with the Dalgety Bay Forum. All in all, we have already spent £750,000 on land remediation signage and surveys and on assisting SEPA in other ways. Without further investigation, it is difficult to justify using taxpayers’ money to remediate while the current source, level of risk and remediation necessary remain unclear. That is why, in addition to the three-year monitoring and collection work we are already doing in conjunction with SEPA, we have agreed to undertake further investigative work. As I said earlier, we understand that the work we have done was seen, until recently, as entirely satisfactory by SEPA.

The work is not seen as satisfactory by the Scottish Environment Protection Agency. I talked with head of the agency this afternoon, who assured me that he has had no assurances from the Ministry of Defence that it will do what the Scottish Environment Protection Agency needs. To return to the central point, the Ministry of Defence was prepared to accept responsibility for the site when there was no real problem, but now that we have a problem it should, in order to allay local people’s fears, say that it will fund the necessary remedial action plan. It is not in a position to say whether that action is needed. In law, that is a matter for SEPA, which the Minister seems to misunderstand. The question is will the MOD, having designated the site as an area of difficulty, honour the responsibility to fund the remedial action plan? It is a simple question and we need a simple answer.

I can see the characteristic passion and vigour with which the right hon. Gentleman has put his case. There is more to this than media reports in Kirkcaldy, or wherever it may be, suggest. The Health Protection Agency has a role to play. He shakes his head, but the Health Protection Agency has a role to play in this. He is of course right and entitled to represent the concerns of residents, but I do not think that we should get this out of proportion. We continue to believe that the risk to health remains low and that precipitate action is in no one’s interest. I can assure him and his constituents that the MOD will continue to work in a credible and responsible way with all concerned at Dalgety Bay.

Finally, may I say what a pleasure it has been to discover how many Members of the House are as interested as I am in the concerns of the people of Dalgety Bay?

Question put and agreed to.

House adjourned.