Management of Radioactive Contaminated Land Radioactive versus non-radioactive contamination - tools and techniques

Aims and Objectives  To discuss the management of sites contaminated by chemicals and radioactive substances in Scotland.  To discuss remediation of radioactively contaminated land sites.  To highlight comparisons between sites contaminated with radioactivity by the nuclear industry and other industries.  To explore the future for such sites under emerging statutory guidance.

Definitions Contaminated Land Land is contaminated only where a pollutant linkage exists The effect of the substances must be that significant harm is caused or there is significant possibility of such harm being caused; or there is pollution of controlled waters Radioactively Contaminated Land Land is contaminated only where a pollutant linkage exists The effect of the substances must be that significant harm is caused or there is significant possibility of such harm being caused Harm is defined as:  Effective Dose3mSv or more per year  Equivalent Dose to lens15mSv or more per year  Equivalent Dose to skin 50mSv or more per year

Management of Scottish Sites  12 contaminated land sites identified (July 2008) Most on basis of water pollution alone Some on human health alone Some on human health and water environment  2 designated as Special Sites (neither radioactively contaminated) Former Carless Oil Refinery, Old Kilpatrick, West Dunbartonshire Mid-part of site has enough contamination to warrant designation Rest of site is designated as contaminated land Undergoing remediation as part of Clydebank regeneration Pelikan Hardcopy Scotland Ltd, Turriff, Aberdeenshire Ink manufacturing process Regulated by SEPA under PPC as Part A process Pollution of both shallow and deep aquifers Pollution of deeper sandstone aquifer by organic solvent trichloroethane

Differences between English and Scottish Law EnglandScotland Environment Agency undertake the inspection on behalf of Local Authorities Local Authorities seek advice from SEPA in relation to potential Special Sites* Notifications of identification of contaminated land DO NOT appear in the public registers Notifications of identification of contaminated land appear in the public registers The Regulations specify the content of the remediation notice The Regulations specify the form of the remediation notice *in practice, SEPA are managing the only two designated Special Sites in Scotland

Legislation  Recent amendments to the relevant legislation written to include land within the boundary of a nuclear licensed site  This would tend to suggest there should be an equal approach to radioactive contamination from both nuclear sites and other sources?  Is this borne out in practice?  Contaminated land on “old” nuclear sites is now owned by the NDA and regulated to some extent by HSE/NII which may complicate the clean up process.

Management on Nuclear Licensed Sites  Nuclear Liabilities  Nuclear Decommissioning Authority responsibilities:  to recognise and record potentially radioactively contaminated land  to investigate that land to determine if harm is being caused or if there is a significant possibility of harm being caused  to remediate any land to prevent harm  to return the land to it’s agreed End State  This responsibility is fed down to the Tier 1 M&O contractor using NDA requirements (EGG01)  EGG01 sets out how each M&O contractor should meet their responsibilities

Examples of remediation projects Remediation work carried out on nuclear sites:  Dounreay – remediation of Landfill 42 by removal of “hot spots and capping of the site. Full intrusive remediation not supported by cost benefit analysis undertaken by Komex.  Dounreay – monitoring and removal of “Particles” from Sandside Bay and seabed undertaken over past 10 years. Would a major effort to remove “all” contamination be sustainable?  AWE Aldermaston – Remediation of a number of significant areas of VOC contamination.  AWE Aldermaston – plans to undertake intrusive remediation of landfill area shown not to be sustainable and contaminated groundwater then managed through the authorised liquid waste system.

Nuclear site remediation  Remediation of nuclear sites is occurring  Nuclear sites have funding from NDA or MoD with programmes in place which include contaminated land  Remediation of nuclear sites is not generally being carried out under Part IIA legislation – more often application of RSA’93 and nuclear site license conditions on “leak or escape” of radioactive materials  The problem holder is more easily identified for these sites as very few have been entirely demolished and closed.  For the future the definition of “no harm” and end point for clean up will be critical

Remediation of radioactive contamination  Examples of radioactive contaminated land in Scotland (non-nuclear):  Aberdeen beach area contaminated with NORM  Gowkthrapple clockworks, North Lanarkshire – contaminated with Radium 226 from luminising works  Dalgety Bay, Fife – contaminated with Radium 226 from luminous aircraft dial scrap.  Will we see precedent set with the latter site following ongoing monitoring and retrieval work?

Sustainable remediation?  Currently it would appear that remediation of radioactive contaminated land is progressing where there is an identified person to fund and manage this.  End point for some of these sites is not yet decided  Sites which would appear to meet the definition of “harm” under Part IIA for radioactivity may not be remediated so quickly?  Is the money being spent in the best place?  Is optimum protection of public health and ecology being assured?  Can “blight” be avoided by meeting “harmless” levels?

Finding the Economic Optimum M -1.0 M No Action containment Hot-Spot removal Full source removal INCREASING LEVEL OF CLEAN-UP NET BENEFIT