RWMAC report on MoD radioactive waste practices

8. ESKMEALS AND KIRKCUDBRIGHT

Depleted uranium

8.1 At the time this report was being prepared (February 2001), there was considerable media coverage of the possible effects on the health of UK armed forces personnel of inhalation and ingestion of particles resulting from use of depleted uranium (DU) projectiles in the Gulf and Balkan conflicts of the 1990s. Parts of the MoD ranges at Eskmeals and Kirkcudbright are set aside for testing of DU projectiles, although the former site has not been used for some years. Test firing of DU projectiles at Kirkcudbright (through "soft targets" out into the Solway Firth) is still taking place. MoD has indicated to RWMAC its view that the projectiles lodge intact in the Solway Firth sea bed.

8.2 The Royal Society has undertaken a study of the use of DU and its possible health effects⁹, which is expected to report in Spring 2001. In its last report on defence wastes, RWMAC drew attention to a 1994 study, commissioned by MoD from independent consultants, to provide estimates of the critical group radiation dose from test firing at Eskmeals¹⁰. The consultants found that the critical group dose was 0.5 microsievert per year, which is of no radiological significance.

8.3 MoD needs to characterise fully the composition of all its DU munitions. If the presence of other radionuclides is confirmed, MoD would, in RWMAC's view, need to consider whether fresh work should be carried out, covering the implications for environmental contamination at both sites and a reassessment of exposure of the critical groups. The findings of any new work should be made public.

Coverage of DU firing in this report

8.4 The main focus of this part of the main report is on the future of the DU projectile testing facilities at Eskmeals in the context of the cost of ongoing radiation protection and environmental monitoring measures, and eventual clean-up. Details of the RWMAC's visit to Eskmeals and perceptions of the Eskmeals and Kirkcudbright land ranges are given in Annex 8 of this report. The Annex includes RWMAC's views on the radiation protection precautions taken at Eskmeals, environmental monitoring at both sites, site waste management, and the need for characterisation of ground contamination.

8.5 Any or all of these issues might be viewed as relevant to assessment of the implications of the use of DU projectiles on the battlefield. It must be emphasised, however, that RWMAC has no remit to look at military use of DU outside the UK and has not carried out any work on this issue. Neither does the Committee's cover consideration of the potential health effects of DU. In practice, such consideration falls to another independent advisory body, the Committee on Medical Aspects of Radiation in the Environment (COMARE).

8.6 The last RWMAC report addressed waste management and radiological monitoring at Eskmeals in some detail, including the precautions taken to contain radioactive contamination to the area of the VJ Battery butt (a near-completely enclosed permanent structure within which the results of test firing projectiles against, for example, armour plate, can be observed). During its visit in July 2000, the Committee observed that the management of very small amounts of residual radioactive waste arisings and of some historical wastes still present on the site, the radiological protection precautions taken, and the environmental monitoring carried out, were all to high standards.

8.7 In view of the heightened public interest in activities at Eskmeals and Kirkcudbright, MoD should review whether it can place additional information in the public domain, preferably independently peer reviewed, to help reassure the public of the safety of operations at the sites. As Annex 8 makes clear, a significant amount of environmental monitoring data is available.

The future of test firing of DU projectiles and its implications

8.8 Questions are raised by the Government's plans to privatise parts of DERA-RPS, the organisation of which the two ranges ultimately form part. If one outcome of the process should prove to be that the ranges come to be managed by the private sector, RWMAC's view is that, given their present organisation, and the good standards of radioactive waste management observed, no obvious problem can be anticipated at this stage with the application of RSA93.

8.9 At the time of preparing this report, however, some of the other implications of the privatisation decision for the two sites were not as clear. For example, the extent of ground contamination, particularly within the confines of the battery controlled area, clearly raises questions of liability which will have to be addressed at Eskmeals, whether or not the site is sold or its operations are contracted to the private sector. Land contamination at Kirkcudbright is believed to be considerably less extensive, and more localised, since it is only unanticipated shortfalls in the firing of projectiles out into the sea which can impact on the site itself.

8.10 While MoD has stated that Eskmeals will be maintained for the foreseeable future, no comment has been made about the future of the battery. At present, there is a considerable cost (£360,000 per year) attached to maintaining the facility, largely deriving from monitoring and radiological protection activities and as long as there is no decision on the future UK requirement for test firing of DU projectiles, these procedures have to be maintained.

8.11 There are other issues that relate to the possible decommissioning of the battery which, whether or not the site as a whole is privatised or contractorised, will ultimately be borne by the taxpayer, and to the waste management and radiation protection standards which might be applied by the regulators if and when DU firing resumes.

8.12 In the absence of drawing up a plan, the cost of decommissioning the battery and of remediating ground contamination cannot, of course, be measured. From its work on MoD's arrangements for dealing with its radioactively contaminated land², RWMAC is aware of the Ministry's intention to bring all its contaminated sites within the system of Land Quality Assessment (LQA; a means of establishing the extent of contamination and appraising the degree of risk posed) by 2007. Eskmeals staff had not been made aware of the LQA programme, however. Given public sensitivity concerning DU, both Eskmeals and Kirkcudbright should be brought formally within MoD's LQA programme.

8.13 It was not clear to RWMAC that MoD has taken any steps to estimate the volume of defence wastes likely to arise from decommissioning of the VJ battery for the purposes of the UK Radioactive Waste Inventory (see section 4, paragraphs 35-36). This needs to be rectified.

8.14 It is not, as stated earlier, part of RWMAC's remit to consider issues associated with military use of DU. However, the Committee believes that, for reasons associated with sensible forward planning of the management of waste arisings, and the liabilities associated with them, MoD should give attention to its future requirements for the two sites to as early a timeframe as is practicably possible.