The Scottish Environment Protection Agency’s most expansive survey of radioactive contamination at Dalgety Bay on the Firth of Forth in September 2008 found 39 radioactive particles, some of which could be harmful to children (ENDS Report 404, p 23 ).
The particles were not deemed harmful to adults through ingestion, inhalation or skin contact. But a draft assessment by SEPA concluded that contact with children’s skin, which is thinner than adults’, for over an hour could cause ulceration.1
This constitutes sufficient risk to designate the bay as RCL under the Radioactive Contaminated Land (Scotland) Regulations 2007. Doing so would oblige SEPA to establish the polluter and assign liability for remediation costs according to the ‘polluter pays’ principle. Because the pollution stems from a former RAF base, the polluter is likely to be the Ministry of Defence.
However, the exercise would require further scientific research and a difficult and costly legal process given the MoD’s "not particularly positive" response to date, SEPA says. In its report to the Dalgety Bay Forum, a grouping of national and local bodies set up to discuss ways of handling the contamination, SEPA says the costs involved "may not be an appropriate use of resource."2 Defence Estates, which manages MoD property, told ENDS it neither accepted nor denied any current or previous responsibility for the contamination.
The first traces of radioactivity were found in 1990 and suspected to be radium 220. The then National Radiological Protection Board attributed them to luminous instrument panels from World War II aircraft, once scrapped at the nearby Donibristle airbase (ENDS Report 376, p 17 ). The base was closed years ago and the site redeveloped as private housing. But particles continue to be washed up on the beach despite regular removal of those found.
SEPA is also concerned that designation could stigmatise Dalgety Bay. Once placed on the RCL register it would remain there, even after a successful clean-up. It would be the first Scottish beach on the register.
SEPA is arguing for an alternative to designation. It points out that statutory guidance says designation can be avoided if "effective voluntary actions are taken to protect human health".
The particles pose no threat to the local environment, SEPA argues, but the proximity of a local sailing club and public beach to the contaminated area make the particles a health risk.
SEPA’s director of environmental protection Colin Bayes said: "We want to be the catalyst for action here. The best way forward is to ask key agencies to take voluntary action to deal with the problem as speedily as possible." He wants clearer warning signs, or concreting of the areas where the highest particle concentrations have been found.
Most particles have been traced to a single ‘hot spot’ - a small area of beach between the sailing club’s three concrete slipways. The contaminated sediment is thought to accumulate in the sheltered waters. Joining the slipways could stop radioactive sediment accumulation, leaving it to continue harmlessly out to sea.
The Sailing Club, part of the Dalgety Bay Forum, has yet to respond to the proposals and the costs have not been discussed.
Extra signs on the beach to make people aware of the danger could be installed by Fife Council following a decision on wording between SEPA and the Health Protection Agency. Existing warning signs instruct users to wash their hands and not to remove anything from the beach are viewed as temporary and ineffective.
SEPA has stressed that its proposals are not definitive and it awaits a response from Defence Estates on medium-term and long-term funding solutions. Defence Estates refused to comment but promised to report to SEPA on 30 January.
Further consultations with the Dalgety Bay Forum are expected in February. SEPA hopes to draw up a timetable for action afterwards.
"The powers to make these things happen rest with a number of the agencies round the table and we are keen to work with them all to help find the right way forward", said Mr Bayes. "We’ll welcome ideas from Forum members for other ways of resolving the issue." Members include Defence Estates, the Scottish Government and Fife Council.
Whatever the decision, further monitoring will be necessary to gauge the success of any action.
Radioactive material continues to wash up on two other Scottish beaches, but neither currently face RCL designation. SEPA views them as not dangerous to public health or undergoing satisfactory clean-up.
Contaminated particles are still washing up on beaches near the Dounreay nuclear research facility, which closed in 1994. The contamination arose from decades of poor radioactive waste-handling practice dating back to the 1950s. The site’s owner and operator, the UK Atomic Energy Authority, was fined a total of £140,000 in 2007 after pleading guilty to four offences under the Radioactive Substances Act 1960 (ENDS Report 386, pp 60-61 ). Fishing is banned within a two-kilometre radius of the site’s effluent outfall and nearby beaches continue to be monitored for particles.
SEPA’s expert Dounreay Particles Advisory Group (DPAG) produced its latest report at the end of last year.3 This restated an earlier recommendation to close the foreshore to the public. DPAG says anyone attempting to reach the foreshore would "have to be quite determined" because it is extremely rocky and has no direct access from the site. It urges Highland Council to at least erect signs warning of the risks. Failure to do so could lead to RCL designation following an assessment.
Particles are also washing up on a beach near Aberdeen city centre. The naturally radioactive mineral scale - removed by Scotoil Services from offshore oil drilling equipment - is being ground up and discharged into the sea nearby (ENDS Report 387, p 25 ). SEPA tried to revoke Scotoil’s authorisation for at-sea disposal in November 2006, coming into effect in December 2008. But an appeal saw Scottish ministers conclude in October 2008 that the practice can continue until 2011.