MOD REQ 7

DSTL- answered by DEFENCE ESTATES.

Effects of white phosphorus munitions in the environment

BACKGROUND

In the US there are documented cases of this munition used at artillery training ranges poisoning wildfowl. White phosphorus poisoning of Waterfowl in an Alaskan Salt Marsh (1992). WHITE

The problem has been identified and remediation action has been taking place
over a number of years. The US army suspended  firing p4 munitions over wetland areas as a consequence.

WHAT DID WE ASK AND WHAT DID THEY KNOW?

“I am requesting information under the Freedom of Information Act concerning the firing of the highly toxic incendiary munition white phosphorus (P4).
.
I would like to ask the DSTL
1 if they are aware of any sites where white phosphorus munitions have been fired in the UK by the British military, where these sites are and if any of these sites are over wetland areas?
2if they have investigated if there is the potential for the munitions to enter watercourses via groundwater systems off these sites?
3if any wildfowl or any other animals in or around these areas have been post mortemed for white phosphorus exposure via gas chromatography analysis for P4?
4 are aware of the potential for secondary poisoning in predators?
5 if they are aware of the impact that this chemical could have should it enter the food chain, potentially to neighbouring farms and landowners?

6. they have any remediation strategies or have undertaken any work on any sites to remediate the white phosphorus munitions or have removed any munitions off these sites?

DSTL replied after delay

“Thank you for your enquiry of 14 April 2010 to the Defence Science and Technology Laboratory and subsequent e-mails of 18 May and 5 June. These were passed to Defence Estates (DE) – the Ministry of Defence (MOD) organisation with responsibility for the defence estate – and have been dealt with under the Freedom of Information (FOI) Act 2000.

To recap, you asked five questions regarding the firing of white phosphorus munitions at sites in the UK by the British military, its potential environmental effects and work undertaken to remediate sites.

Let me begin by offering my sincere apologies for the time taken to acknowledge and respond to your request. This was due to an administrative error by DE and the need to identify what information is held across from the various relevant areas of DE and the MOD, in order to provide you with as full a response as possible. This work, which has proven to be more complex than originally hoped, is still ongoing, although I hope to bring it to a conclusion soon.

As you might be aware, the MOD has a Land Quality Assessment programme of works for its sites. This programme is prioritised based upon the risk posed rather than specific contaminants and therefore information relating to specific contaminants such as white phosphorus is not centrally collated. However, it is believed that a number of sites have been investigated where white phosphorous has been either identified or known to be present. To provide the requested details for each such site, including details of any remediation activities, would require the retrieval and scrutiny of various records located across DE and the MOD.

Section 12 of the FOI Act states that a public authority is not obliged to comply with a request for information if it estimates that the cost of complying would exceed the ‘appropriate limit’. This limit is £600 and equates to 24 hours worth of effort on our part (calculated at £25/hour), roughly three and a half working days. It goes on to say that the public authority must provide advice and assistance to help the applicant refine the request so that information can be provided within the ‘appropriate limit’.

It has been assessed that the costs involved in providing the information you have requested will exceed the £600 limit. Under the terms of Section 12 of the Act we are not obliged to comply with this part of your request. However, if you would like to refine your request in order to try and bring it under the appropriate limit please let me know. For example, we might be able to more easily provide information on specific sites of interest.”

 We did refine our request.

“what MOD firing ranges and munitions burning grounds include wetland areas and which of these are SSSI sites?”
Though my original delayed request was to the DSTL and some of the 5 questions are yes or no answers, I would appreciate it if you could explain which of these questions have been deemed to push the threshold over the £600 limit in order that I can refine them further if needed. I trust that Defence Estates is in possession of this information?

The MOD replied again.

“I can confirm that the MOD holds information within the scope of your request.

Dealing with your second point first, each of the five questions posed in your original request could not be responded to within the appropriate cost limit as they are each dependent on the MOD being able to answer your first question – whether it could provide details of all sites, by location and whether they are located over wetland areas, where white phosphorus munitions had been fired in the UK by the British military. Regretably, such a list is not available and to provide it would require significant effort collating information on many sites from across the Department, greatly exceeding the appropriate cost limit.

However, with regards to your refined request, I am able to provide you with the enclosed list of SSSIs on MOD land in the UK, broken down by country. Included within this list are Defence Training Estate (DTE) sites, including ranges, and DSTL sites. I am advised that almost every SSSI includes some areas of wetland, with those designated Ramsar sites (referred to in the enclosed list), being “Wetlands of International Importance”.

Of those sites on the enclosed list, I understand that the only ‘open burning’ facility is located at MOD Shoeburyness. If, however, after subsequent investigation I discover there maybe more of these facilities, I will of course write to you again.

The supplied list of SSSI MOD sites can be viewed HERE.

WHAT DOES THIS MEAN?

We have not been able to obtain a list of white phosphorus contaminated sites, but all those on the supplied list of SSSI sites are of potential contamination, and given that most of them by admission contain wetland areas, and also possible grazing animals where this material has been fired, then there must be some chance that p4 poisoning could have  occured at some point in time. It may be happening still at the sites identified in the previous request. In this request Castlemartin in Pembrokeshire and Larkhill in Wiltshire were identified as being fired in “dry impact areas”, but it is difficult to see how this would not stop potential run off contamination.

 Pendine in Carmarthenshire was also a former P4 site.

Unfortunately we do not know what work the British military have taken in terms of coming to terms with their “p4 footprint”, though we are glad that they claim not to fire over wetland areas, (at least in this country.)  Perhaps this needs some Parliamentary scrutiny to shed a bit more light on work that has been done to date in terms of remediating land that has been contaminated by P4; and it would be in the public interest to make this material available.