A Place to Stand

   Having promised/threatened to declare Dalgety Bay beach to be radioactive waste by March if the MoD did not pay them an unspecified and unspecifiable amount of danegeld the Scottish Environment Protection Agency (SEPA) have started to back down. 

In November last year, SEPA set deadlines for MOD to provide a credible remediation plan for the area to prevent the need to designate Dalgety Bay as radioactive contaminated land, the first such designation in the UK. However, work carried out for SEPA over the winter months showed that the situation at the beach was more complicated than initially believed, and therefore a comprehensive investigation is required, before remediation options can be identified.

Dr James Gemmill, SEPA's Radioactive Substances Unit Manager, said:
"We are satisfied that real progress is being made and, as a result, we will not be designating the beach at this time.

But the threat remains if they can get away with it

by the end of May 2013, SEPA will be in full possession of technical issues;...... At that stage we will expect action to follow urgently.

"We would prefer that the contamination at Dalgety Bay is dealt with on a voluntary basis so we can avoid the need for designation. However, SEPA can still designate the area at any time, depending on circumstances. This would be done if SEPA considers that work undertaken by MOD is inadequate, or further relevant information comes to light, or if there is no voluntary remediation following these investigations."

  Meanwhile the Scottish Information Commissioner has told me that I have to make a further appeal for SEPA to specifically answer the FoIs (which they are legally required to answer within 20 working days & don't) before determining whether they should start enforcing the law. So here goes.

Dear SEPA,
                    Regarding my various FoIs  here & numerously here about the evidence that Dalgety Bay is a "radiation hazard", going back to 12th Feb 2009 when you asserted that neither SEPA nor its officers are under a duty to answer such questions and threatened legal action if I investigated. While this was clearly contrary to law it is the road you have followed ever since. I have now been asked to appeal this refusal and once again ask you to provide the specific information requested. Not merely to say it is somewhere on our website, particularly when this is not true.

    I particularly wish factual responses to these 3 major previously asked questions:

1 - SEPA have claimed & continuously maintained for over 3 years, that particles of radioactivity could not possibly be natural because they had been scientifically proven to be made of paint. Obviously if SEPA is not wholly, completely and totally corrupt there must be specific unequivocal tested evidence for this yet for that period you have refused to produce it. Please produce the specific scientific proof.

2 - SEPA have publicly claimed to have found the "daughter elements" of radium yet have refused to provide evidence. Obviously if SEPA is not wholly, completely and totally corrupt there must be specific unequivocal tested evidence for this yet for that period you have refused to produce it. Please produce the specific scientific proof.


   This is particularly disgraceful since the scientific community say that the sole daughter element of radium
is radon; that radon is an inert gas that thus could not possibly be found as part of rock; and that in any case the amount of it produced at any one time would be orders of magnitude less than that of radium (it is undisputed that the amount of manmade radium there cannot be more than 0.26 of a gram or 1/4 of what is naturally there,  in this 1.5 million tons of soil). If SEPA have found the plural daughter elements then much of physics must be discounted and it is disgraceful that you should keep this amazing discovery from humanity.
 
3 - SEPA have claimed and maintained you have provably found radium. Obviously if SEPA is not wholly, completely and totally corrupt there must be specific unequivocal tested evidence for this since then you have refused to produce it. Please produce the specific scientific proof.
 
Since it would be unwise to let your refusal to answer FoI's slow the investigation I am also asking these new questions under the FoI or other appropriate Acts.
 
4 - What was the specific scientifically proven finding or findings since 30th November which has led you to say "work carried out for SEPA over the winter months showed that the situation at the beach was more complicated than initially believed" . This reverses your promise/threat, briefed to the MP Gordon Brown that SEPA , within 3 months "Scottish Environment Protection Agency still says that, unless the Ministry of Defence can give assurances, it will designate the land as radioactive".


5 - It has been acknowledged that SEPA have made no effort to use any close beach as a control to determine whether the radiation detected is in any measurable way excessive and thus, possibly, introduced by man. Obviously this is basic to making any scientific evaluation of the existence of any radiation beyond ordinary background. I now wish to know what efforts, if any, has SEPA made to use a beach near Dounraey as a similar control? Obviously this is basic to making any scientific evaluation of the existence of any radiation beyond ordinary background.

6 - The entire thesis that radiation close to (or at) normal background is in any way harmful depends entirely on the Linear Non-Threshold Theory of radiation danger (LNT). I would like to know what scientific evidence, not hearsay or assertion, SEPA have used to make you accept this theory as true? I ask this because, as far as i can determine, there is no actual evidential proof of this theory at or even close to, the levels involved. Indeed that the evidence that there is points in the opposite direction - to the theory known as hormesis, that at low levels radiation is beneficial to health. The laboratory evidence of hormesis at the cellular level in plants and cultures goes back nearly a century and seems unchallenged. Obviously theories without evidential support, such as astrology and homoeopathy are not scientific and if SEPA is a scientific organisation cannot be promoting the radiation scare without clear proof of harm.