RWMAC ACTION PLAN
Ref. Main Recommendations
Current Position
1.
The LQA programme needs to be made more
• Defence
Infrastructure
Organisation (DIO) manage a single
transparent, with clearer arrangements for
MOD wide prioritised LQA programme. Having one
recording the progress of schemes and assessing
organisation managing the programme has improved
future plans and progress.
transparency, monitoring of progress and planning.
• The LQA process is set out in MOD Defence Estates
Practitioners Guide PG 01/07 – Contaminated Land
Management: Land Quality Assessment (LQA) Management
Guide
http://www.mod.uk/NR/rdonlyres/9BB69BE9-6218-
4F06-9139-BB605C38B2C7/0/pg0107.pdf
2.
The funding arrangements for the LQA programme
• Funding responsibility for the MOD LQA programme now sits
would benefit from being simplified and given higher
with DIO.
priority in the allocation of MOD resources.
3.
Procedural documentation relating to the
• The LQA Practitioners Guide is currently undergoing a major
programme should be subject to regular review.
review with publication scheduled for early 2012.
4.
The responsibilities of those managing remediation
• Environmental Protection Act 1990 Part 2A was extended to
work should be clearly spelt out (successful
cover radioactive contaminated land in 2006 and sets out the
remediation should not be dependent on the
responsibilities for managing remediation work.
involvement and personal knowledge of a few
• The LQA Practitioners Guide sets out the MOD process for
particular individuals).
assessing land contamination risks and managing any
necessary remediation work
• The LQA programme is managed by in-house Environmental
Specialists ensuring a consistent approach to managing
remediation
5.
This definition of responsibilities must include
• See
4
- 1 -
Ref. Main Recommendations
Current Position
specific provision for involving relevant branches of
the environmental regulators, and identifying their
responsibilities, and also provide for the LPA to be
brought in at the appropriate time
6
MOD as the original polluter and a responsible
• Since the Report MOD disposal policy has changed to
Government Department, must itself ensure that
ensure that arrangements are in place for the remediation of
whatever form of site disposal is employed, the land
radioactive contamination.
is cleaned up to an adequate standard.
• Through the LQA process the land condition is known and
the split of responsibility of each party to the transaction with
regard to current and future land contamination is agreed on
sale.
7
MOD should not allow arrangements to be made for
• See
6
the sell-off of land without remediation where there
is no downstream control over the quality of the
remediation work to be carried out.
8
This requires that, in all cases, DE is armed with the
• DIO has access to appropriate RPA through both DSTL
necessary expertise to ensure the eventual quality
(formerly part of DERA) and Specialist Environmental
of clean-up work. DERA RPS is the obvious source
Consultants.
of much of this expertise. If DERA-RPS is not
used, DE must ensure that suitable alternative
sources of expertise are available for use
9
MOD should be as clear as is reasonably possible
• An LQA database has been established. As at Oct 2011 it
about its contaminated land holdings, and should
held 5370 reports.
set up a database for this purpose (drawing on LQA
findings and on previous site investigation records,
including desk studies and other land quality data).
- 2 -
Ref. Main Recommendations
Current Position
At the time of finalising this report (May 2000) the
Ministry indicated that it was in the process of
developing such a database.
10
Not least this database should be used to compile
• Information is extracted from LQAs to inform future radium
as accurate an estimate as possible of future
disposals to Drigg
radium disposals to Drigg
11
MOD should ensure possibly in conjunction with
• The LQA database holds copies of reports produced for past
other Government departments, that existing
and present landholdings.
records of characterisation and remediation of its
past and present landholdings are not lost
12
MOD should give thought to the feasibility of
• The introduction of EPA 1990 Part 2A places the
compiling information on disposals of land predating
responsibility for inspecting land with the local authority to
the LQA programme, where radioactive
identify land contamination.
contamination might have been involved.
13
The Ministry should commission work to establish
• Complete – Commissioned work is published in the Journal
with more certainty, the extent to which buried
of radiological protection vol.25 (2005) pg127-140 Adrian
radium is immobile in all soil and ground conditions.
Baker and Catherine Toque - A review of the potential for
radium for luminising activities to migrate in the environment.
14
The Government, more generally, should revisit its
• No direct action by MOD
conclusion that where a change of use is proposed,
the current planning system alone can ensure an
adequate standard of clean-up.
15
RWMAC also believes that MOD should give
• The extension of EPA 1990 Part 2A to cover radioactive
consideration to the potential for correlation, and, as
contamination, addresses this recommendation
far as possible, ensuring consistency of treatment,
between its procedures for dealing with radioactive
and non-radioactive contamination.
- 3 -
Document Outline