Dear Ms K Davis,

I note you have flagged this FYI request as successful. To come to this conclusion presumably you had a private conversation with George Bignell at Radio NZ as suggested.

I have a similar problem concerning undocumented actions by Nga Taonga Sound and Vision. After the Earthquakes in Christchurch Canterbury Regional Council wanted to rezone the land around the RNZ AM Transmitting Station at Gebbies Pass. RNZ submitted it would oppose any new construction within one kilometre of the transmission mast due to strong radio frequency radiation having undesirable effects on electric and electronic equipment. However about the same time at the RNZ Transmitting site at Titahi Bay Wellington, Nga Taonga Sound and Vision were constructing a dangerous goods storage vault 520 metres from a transmission mast. Soon a new mast is be erected 130 metres from the vault.

I emailed George Bignell about this problem but failed to receive a response. It appears to be another case of NTSV failing to consult. The dangerous goods vault contains almost the entire NZ collections of pre 1950 Nitrate films held by both NTSV and Archives New Zealand. This building on RNZ land would have required a location compliance certificate from WorkSafe, yet RNZ do not appear to know anything about it.

I am currently attempting to have the compliance certificate revoked on the grounds that the Nitrate Film is subject to Inadvertent Ignition by Radio Frequency induced sparking. Please see my submission to WorkSafe dated 1 March 2018 titled "Location Compliance Certificate for Whitireia Park Titahi Bay Dangerous Goods Storage Vault".

Kind regards
P L Ford

Dear P L Ford,

Thanks for your note. I marked the OIA request as complete as Mr Bignall said he couldn't find any further documentation. I haven't been in contact with him by phone.
That is a very good point you raise about the safety of the nitrate vault. I have copied and pasted some information below taken from the Wikipedia page on Nga Taonga. You could also possibly OIA RNZ, Archives NZ and Te Papa as they are all parties that have an interest in the storage vault. It would also be interesting to find out how the "wind throughs" are undertaken. What safety equipment (ventilation, personal protective equipment etc) is used by archive staff.

From Wikipedia (https://en.wikipedia.org/wiki/Ngā_Taonga...)
The purpose-built, 100 square metre climate controlled nitrate film vault was built in partnership with Archives New Zealand in 2013 on land owned by Radio New Zealand. Archives New Zealand contributed $100,000 towards the project which cost in total $366,000. After construction, Ngā Taonga moved four tonnes of flammable nitrate film from Makomako in North Wairarapa to the Whitireia vault over a one week period. The vault also holds nitrate collections from Archives New Zealand and the Museum of New Zealand Te Papa Tongarewa. Even though it was purpose-built by the archive and publicised as having "controlled preservation conditions", Ngā Taonga Sound & Vision now believes the vault is below standard and not within best practice. Currently the nitrate film is stored at 15C, where ideally it should be stored between 2-4C. In 2018 public concerns were raised over the vault's close proximity to a newly proposed radio transmission mast, potentially heightening the risk of inadvertent ignition of flammable atmospheres by radio frequency radiation - particularly when archive staff do regular “wind-throughs” of nitrate film reels.

Dear Ms K I Davis,

Thank you for your response. I had not looked at the Nga Taonga Sound and Vision entry on Wikipedia for some time and was very surprised to see how up to date the information now is.

Two years ago I notified WorkSafe of the risk of inadvertent ignition by radio frequency radiation and also what could result from another lightning strike to the transmission mast. An Inspector then visited the site. His report states the vault is compliant with NZ hazardous substances legislation. However he qualified the report by a statement that he had no knowledge of risks from Radio Frequency radiation and management told him to close the file.

When I heard in December last year that in 2018 a new mast is to be erected and energised about 130m from the vault, I wrote letters to the WorkSafe Chief Executive expressing my concerns. When she didn't reply I then wrote to Minister Iain Lees-Galloway. WorkSafe finally advised that the Minister had instructed them to take another look. I emailed WorkSafe information I had gathered but failed to receive an acknowledgement. However now that I have made an OIA request via FYI WorkSafe appear to have suddenly started to take notice.

I have sent letters and emails to Archives New Zealand, Nga Taonga Sound and Vision and the Wellington Regional Council who administer the Whitireia Park Plan. Archives NZ claim they have been assured by NTSV the vault is safe. NTSV have replied that they consider the risk is so low they can't justify the expenditure of relocating.

I understand the situation has also recently been discussed by the Titahi Bay Residents Association. I am sure WorkSafe, NTSV or Archives NZ would not have released details so this may be how Wikipedia know of the current situation. Very interesting!

There are two international safety standards I have consulted for information. They are:
“Standard for the Storage and Handling of Cellulose Nitrate Film – NFPA 40” and
“Assessment of Inadvertent Ignition of Flammable Atmospheres by Radio frequency Radiation Guide – PD CLC/TR 50247:2004”.
The Titahi Bay vault fails both.

Archives NZ have a small approved Nitrate work area and storage vault on their premises. It is compliant with NFPA-40. NTSV do not have anything similar so I assume the annual wind through is done inside the vault at Tttahi Bay. This is to inspect the film for deterioration and release any trapped gases. Film cans that have been closed for about a year will be opened releasing stored flammable gas at the same time as there is a separation between the metal film can and lid. All the right condition for a spark to occur leading to a possible explosion. They are lucky there has not been such an event so far.

Kind regards,

P L Ford

Dear Ms K I Davis,

It appears we have similar concerns about NTSV. Not sure if I am meant to do this via FYI, but if you would like more info please txt "Davis" to 027 4484698.

Regards

P L Ford

Has anyone given some thoughts to whether a resource consent is required from PCC? The land is designated in the district plan but only for "radio communication facilities" and only for activities undertaken by Radio NZ. For any other activity/person the rules of the district plan only allow for Open Space things.

Hi Brian,

When I first discovered that the new building at the Radio Transmission site was for the storage of Nitrate Film I contacted PCC Environmental Officer Jim Sutton. He told me they were happy with the resource and building consents they had issued and it wasn't possible to "unconsent". He said if there was a safety issue I should contact WorkSafe. WorkSafe then sent an inspector who reported that the building complied with regulations but qualified this by stating he knew nothing about Electromagnetic Radiation so couldn't comment. WorkSafe management remain unconvinced of the danger. Despite providing him with information on the risks of inadvertent ignition by radio frequency radiation, Minister Iain Lees-Galloway has stated he can't see a problem. Likewise with the contractor providing the annual site certificate. Radio NZ has yet to start work on the replacement mast. When this is erected and energised the source of high power radio frequency energy will be about 150m from the storage vault significantly increasing the danger.

P l Ford .