- seeking justice
Radioactivity measurements ignored
This article concerns early radiation measurements made at the Glebelands that, a decade later, have still not been followed up by Newport Council to find out the source of the radiation.
At no time has Newport Council sought to find out:
- the type(s) of radioactive material on the site;
- the precise location(s) of the radioactive material relative to the school building;
- how much radioactive material is present; or
- the likely environmental effects of the radioactive material.
Because there are no records of the radioactive materials dumped on the site, this story starts with the infamous June 2000 report entitled 'Durham Road Schools PFI Project, Newport Contamination Investigation - Interpretative Report'. This was a rudimentary site report prepared by a highways consultancy partly owned by Newport council. Newport council later relied on this superficial report when it granted planning permission for the Glebelands development in October 2000.
Section 7.9 of the report concerning radioactivity measurements states:
"It should be noted that spot readings of 15, 11, 13, and 11 counts per second were recorded on the disturbed spoil from trial pits . . . . that slightly exceed the maximum readings observed during the initial (background) walkover survey."
And Section 8.6 advises:
"If a more detailed survey of the site area for particular types/nuclides of radioactive contamination is required then more sophisticated techniques will need to be employed, such as the use of a portable spectrometer.”
However, none of the subsequent reports made any mention of raised levels of radioactivity at the development site. Neither the 'Remediation Strategy Document' (E3808/GO/PSS-REMSTRAT/JAN06/V2) nor the 'Remediation Validation Report' (November 2009) even mentioned radiation - let alone justified why Newport Council failed to follow up the radiation measurements recorded in the June 2000.
The Planning Application Schedule presented to the local authority planning committee at the time of granting planning permission 00/0768 for the Glebelands development states:
“Additionally, there is no evidence of radioactive contamination at the site which could affect health.”
It is very likely that this statement could have misled the reader into believing that the site was free of radioactive contamination. Due to the extremely limited site investigations carried out at the time, it was unwise of the author of the Planning Application Schedule to include this remark.
In a letter dated 1st March 2010 Newport Council's Head of Public Protection and Environmental Services was asked to explain why no subsequent follow-up actions or investigations were deemed necessary in respect of the elevated radiation measurements.
In the Council's letter that followed in March 2010 (erroneously dated 15 March 2009), Newport Council merely trotted out the now familiar misinformation and unsubstantiated conclusions, as follows:
(1) there had been "monitoring at the site"
Comment: This was clearly stretching the truth, as only a preliminary 'walkover survey' appears to have been carried out to obtain an initial set of 'spot readings';
(2) "the levels identified produce 'negligible dose rates of less than 1 µSvh-1'"
Comment: This was clearly untrue as the apparatus used at the time of the radiation walkover survey was not capable of providing dose rate information.
(3) "radiation levels at the Glebelands were not considered significant and were comparable to background sources of radiation"
Comment: This was clearly untrue as some of the spot readings were between 3 and 5 times that of normal background sources of radiation. As the radiation levels were substantially higher than background levels, further investigations should have been undertaken prior to agreeing the remediation strategy for the site.
(4) "further assessment of radiation at the site was not considered necessary"
Comment: It is not clear that anyone formally recorded or justified this decision. Those who prepared the remediation strategy appear to have ignored the radiation measurement data and comments regarding further investigations.
A further letter to Newport Council on 22 March 2010 challenged Newport Council's reasons for not following up the elevated radiation measurements, as follows:
(a) Newport Council's letter neither states who decided that further assessment was not necessary nor does it reference any reports or further studies in support of its 'do nothing' approach;
(b) the June 2000 report was not as thorough as Newport Council would like us to believe. Indeed the report merely states that the investigation included "a walkover survey to measure background radiation at ground surface", adding that an objective of the report was to "Provide an assessment of the risk posed to human health during future construction work and development on this site". Hence the radiation survey was neither intended to be extensive, in depth, nor pertaining to any particular end use of the site. Indeed, Section 9.1 of the June 2000 report makes it clear that "Proposals for remediation of the site will depend on the end-use of the development."
(c) Although Section 6.6 of the June 2000 report does refer to radiation measurements of spoil material recovered from trial pits, this hardly constitutes comprehensive "radiation monitoring across the proposed development area" – especially when taking into account the haphazard (uncontrolled) disposal techniques employed on the landfill site.
(d) the June 2000 report was only intended to provide an initial assessment. It is important to note that the report makes no mention whatsoever of the presence of polychlorinated biphenyls (PCBs), whereas subsequent excavations that started in the summer of 2008 revealed over 770 corroded drums of PCB contaminated waste beneath the surface, requiring the removal of about 2,779 tonnes of contaminated soils.
(e) the terms of reference and the objectives of the 2000 contamination investigation meant that the resulting June 2000 report was incapable of providing a definitive and accurate assessment of chemical hazards at the development site, such as detecting the presence of PCBs. For the very same reason, the 2000 investigation was also incapable of providing a definitive and accurate assessment of the radiation hazards at the development site.
(f) the Planning Application Schedule presented to the planning committee on 31st October 2000 stated "Additionally, there is no evidence of radioactive contamination at the site which could affect health." It is very likely that this statement could have misled the planning committee into believing that the site was free of radioactive contamination. Due to the extremely limited site investigations carried out at the time, with no end use risk assessment having been carried out, it was unwise of the author of the Planning Application Schedule to include this remark.
(g) it was never made clear why the reference levels for the spot readings were taken to be the background levels for the development site (as observed during the walkover survey) rather than using the background radiation levels for the wider Newport area in general. Such an off-set is very likely to have skewed the results in Newport Council's favour.
In the Council's letter that followed in April 2010 (erroneously dated 14 April 2009), Newport Council dismissed the need for a proper radiation survey. Despite the clear evidence of the presence of radioactivity above normal background levels, Newport Council wrote:
"it is highly unlikely that the Glebelands site was ever a recipient of radioactive waste material".
Such a comment disregards the fact that elevated levels of radiation were detected on the site.
Newport Council failed to find out the nature of the radioactive material detected on the site. The Council does not know the depth of the radioactive material or whether it is in the form of a gas, a liquid, or a solid. It also does not know whether the radioactive material is sealed in glass vessels, or leaking from metal drums that corroded long ago.