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MANAGING DATA FOR LONG-TERM STEWARDSHIP

  Table of Contents
CHAPTER 1

1.0 INTRODUCTION

Since 1989, the U. S. Department of Energy's (DOE) Office of Environmental Management (EM)1 has been responsible for managing the environmental legacy of U. S. nuclear weapons research, testing, and production at 137 sites in 31 states and one U. S. territory. Several recent reports have described the magnitude of the environmental problems at these sites and the scope of the planned cleanup effort, which is expected to take more than a decade and cost more than $100 billion. In this context, the term cleanup refers to the deactivation and decommissioning of all facilities, cleanup of all releases to the environment in accordance with agreed upon standards, containment of groundwater contamination, installation of long-term treatment or groundwater monitoring systems, stabilization and/ or safe long-term storage of nuclear material and spent fuel, and disposal of waste produced by past nuclear weapons production activities.2

As cleanup plans have become more clearly defined, there is a growing realization that because of the extent of contamination and the types of contaminants present, it is technically and/ or economically infeasible to clean up all contaminated lands and waters to allow unrestricted future use of these sites. Therefore, when cleanup is considered "complete," additional measures may be required to ensure adequate protection of human health and the environment at many DOE sites. These additional measures are referred to as "long-term stewardship," which is defined broadly to encompass all activities required to maintain an adequate level of protection to human health and the environment from the hazards posed by nuclear and/ or chemical materials, waste, and residual conta-mination remaining after cleanup is completed. Long-term stewardship will be required at the majority of DOE sites (and already has begun at some of these sites).

1 Formerly called the Office of Environmental Restoration and Waste Management.
2Accelerating Cleanup: Paths to Closure,U. S. Department of Energy, Office of Environmental Management, February 1998 Draft.

INTRODUCTION

A companion report provides a comprehensive preliminary view of the sites currently within the responsibility of the EM program that may require stewardship after cleanup is completed. This report notes that, for all practical purposes, it is reasonable to assume that some long-term stewardship activities will be required indefinitely.3

Definition of Key Terms Used in This Report
Long-term Stewardship. All activities required to maintain an adequate level of protection to human health and the environment from the hazards posed by any nuclear and/ or chemical materials, waste, and residual contamination remaining after cleanup is completed.
Stewardship Data. Information about past and present conditions and activities at sites that will be needed to ensure continued protection of human health and the environment. These data include information generated prior to and during cleanup as well as during long-term stewardship.
Site Stewards. Entities responsible for conducting long-term stewardship activities at sites. These entities may include a federal, state, or local government agency or a private organization that owns, leases, or subleases a site or a portion of a site.

This report represents a preliminary assessment of how successfully information about the hazards that remain at DOE sites will be preserved and made accessible for the duration of long-term stewardship. The assessment is limited to information that will be publicly available, although reference is made to information that requires special protection (e.g., classified information). This report provides a preliminary response to the following questions:

3Moving From Cleanup to Stewardship,U. S. Department of Energy, Office of Environmental Management, Discussion Draft, September, 1997 (permission to cite granted by EM Office of Policy, Planning and Budget).

CHAPTER 1

1.1 Background

U. S. nuclear weapons production efforts began during the Manhattan Project and continued through the late 1980s. During that time, information about production processes, activities, and infrastructure was generally retained for operational purposes, while information about the environmental and human health impacts was not given similar priority. In 1989, DOE established the EM program to manage legacy waste and address contamination at DOE sites. Over the next several years, responsibility for managing the sites was transferred from Defense Programs, the office responsible for nuclear weapons production, to the EM program.

The EM program initially focused on determining the nature and extent of contamination at each site. To prepare for the physical assessment of conditions at the sites and plan for their cleanup, EM reviewed historical records describing the various production activities and processes. Because generating, preserving, and providing access to information on environmental impacts was not a high priority during the nuclear weapons production mission, accurate and complete records describing the types of waste disposed of, the nature and location of buried waste, past releases, and other aspects of site contamination were not retained. As a consequence, physical characterization often had to proceed on a trial and error basis, consuming considerable time and other resources. Characterization activities represented a significant portion of the EM program budget from 1989 to 1995. Even after most of the characterization was completed, DOE estimated in 1996 that future characterization efforts would consume more than 10 percent of total life-cycle cleanup costs. Although the additional costs associated with information loss cannot be quantified precisely, one can assume that the characterization process could have proceeded much more efficiently had the pertinent records existed.

DOE sites are now going through another transition from a mission focused on cleanup to one focused on long-term stewardship. Like the EM personnel who took on the cleanup mission from Defense Programs at former nuclear weapons production sites nearly 10 years ago, those responsible for long-term stewardship at former EM sites will need specific, accurate information about these sites in a form that is both useful and readily accessible. Other people will need to have this information, including those who use sites or portions of sites for other purposes, those who live and work in the surrounding communities, and those responsible for community planning and development. This information needs to include both environmental impacts as well as appropriate information about nuclear weapons production processes (e.g., locations and composition of production wastes). Without the appropriate data in the public domain about what led to these impacts, it will be difficult, perhaps even impossible, to conduct responsible long-term stewardship activities and make future decisions that adequately protect human health and the environment. The costs of long-term stewardship also will increase to the extent information has to be gathered anew or reconstructed, where possible. It is thus imperative that DOE preserve adequate information, maintain the appropriate data, and provide mechanisms for future access to this knowledge.

1.1.1 IMPORTANCE OF ADDRESSING THE NEED FOR STEWARDSHIP DATA

Without adequate stewardship data, it will be very difficult to carry out effective long-term stewardship at the sites. The importance of actively considering stewardship data needs is based on several observations about the EM program:

INTRODUCTION

long-term stewardship at the sites (which may or may not include DOE or another federal agency). These "site
stewards" will need accurate information about site conditions at the time of transfer (i. e., a stewardship "baseline")
and timely access to relevant past records.

  • Institutional change may affect the preservation of stewardship information. Downsizing is occurring rapidly at DOE Headquarters and field sites, resulting in the departure of many experienced personnel. Also, as DOE replaces the old "Management and Operation" contracts with new "Management and Integration" contracts, a significant turnover of contractors is expected. The new contracts pose challenges because they result in multiple levels of activity, for example, when second-and third-tier sub-contractors are used.

1.1.2 OTHER RELATED INITIATIVES

Several DOE organizations have developed recommendations to improve the preservation of, and access to, DOE information. Many of these recommendations are relevant and important to the subset of information required for stewardship. The DOE Records Management Quality Improvement Team, created in July 1993, reviewed and evaluated the Department's records management program and its long-range program objective. The Team summarized its findings and provided recommendations for the records management program in its report, Roadmap to the Year 2000. The recommendations focused on improving access to DOE information.

Recent Recommendations Figure

The Secretary of Energy Advisory Board created the Openness Advisory Panel to review and evaluate the de-classification of documents. The Panel developed a set of recommendations to create an electronic records management system to better preserve information (e.g., retain information in a more permanent format include a comprehensive index system) and allow future access (e.g., improve ability to conduct searches for information), as well as other recommendations to enhance and institutionalize openness throughout DOE and its contractor community. This report seeks to build upon those findings of the Records Management Quality Improvement Team and the Openness Advisory Panel that are relevant to stewardship data.

1.2 Methodology

The assessment outlined in this report was conducted by a diverse team composed of Federal and contractor representatives of DOE Headquarters (the EM Office of Policy, Planning, and Budget); the Federal Energy Technology Center; Pacific Northwest National Laboratory, Washington; and Sandia National Laboratory, New Mexico. The team included experts in long-term stewardship, records management, information management, geographic information systems, data standards, regulatory requirements, DOE's site cleanup program, risk assessment, and policy analysis. The team worked closely with a variety of per-sonnel at the Rocky Flats Environmental Technology Site, including the site Chief Information Officer and contractor staff. In addition, the team provided briefings and held other discussions with the Department's Chief Information Officer, the DOE Historian's Office, and senior management.

A critical element of this assessment was the use of actual examples from one DOE site, Rocky Flats, as a "proof-of-concept" for the evaluations and suggestions developed by the project team. As such, we

CHAPTER 1

will refer to Rocky Flats as the "focus site" for the remainder of this report. The focus site is likely to be the first major DOE site to have cleanup completed. The site is currently being managed under a strict, results-oriented model directed at completing site cleanup as rapidly and efficiently as possible. Because the majority of focus site projects have an anticipated completion date prior to 2006, an effective means to manage stewardship data would help both DOE and stakeholders manage the flurry of activity to be accomplished over the next 10 years, as well as prepare for long-term stewardship of the site. In addition, the focus site management recently expressed its commitment to the effective and efficient capture of key site information through cooperative agreements with local stakeholders.4 Implementation of the focus site information management tasks has been linked to existing performance goals for the site's integrating contractor.

Why Rocky Flats?
Rocky Flats Environmental Technology Site (RFETS) was selected as the focus site for several reasons:
  • It is likely to be the first major DOE site to complete cleanup and go through the closure/transfer process.
  • High-level management has committed to align information management goals with site closure strategies.
  • Past experience in putting together the reports cited on page 1-1 has demonstrated that its information management practices are better than at most DOE sites; therefore, any issues identified at the focus site are probably of equal or greater significance at other sites. In fact, the project team was able to verify that the findings in this report are programmatic in nature.
  • Urban sprawl between two major metropolitan areas has already begun to reach site boundaries, suggesting that many people will be living close to the site in the near future.
  • Interest exists at the site and in the surrounding communities to develop a cooperative system that would include, either as a subset or a whole, the components needed to develop a system for managing stewardship data.

The project team conducted this assessment in three main phases (Figure 1-1). In the first phase, the project team developed a business plan that outlined the rationale for this assessment, identified the potential customers for this report, outlined the tasks and schedule for completing the assessment, and identified the components of an overall system for managing and providing appropriate access to stewardship data. The business plan was later revised to include the results of a needs analysis conducted during the second phase of this project and a series of short discussions of key issues that were raised during the needs analysis. The business plan served to introduce the project and stimulate discussion and was circulated among various DOE Headquarters offices, the focus site staff and contractors, and representatives from key stakeholder groups.

Figure 1-1. Overview of Methodology

Figure 1-1 Overview of Methodology

4 Rocky Flats Cleanup Agreement (RFCA), Part 23 "Sampling and Data/ Document Availability," agreement letter between the DOE, US EPA, Colorado Department of Public Health and Environment, City of Westminster, and City of Broomfield, September, 1996.

INTRODUCTION

In the second phase, the project team conducted a needs analysis for stewardship data. In June 1997, members of the team traveled to the focus site and facilitated two separate needs assessment discussions. One discussion was held with representatives of the focus site staff and contractor organizations involved with regulatory compliance and information management. A separate discussion was held at the offices of the Rocky Flats Local Impacts Initiative5 and involved representatives of several local regulators and stake-holder organizations (see box). To conduct these discussions, project staff asked participants to imagine themselves having four types of responsibilities 10 to 20 years from now, as well as more than 100 years into the future, and to assess what information about the site they would need to perform those responsibil-ities. The four sets of responsibilities were: (1) acting as the site steward (e.g., maintaining active controls to prevent human and ecosystem exposures); (2) emergency response (e.g., discovering and responding to a buried, contaminated pipeline onsite); (3) managing re-use of the site (e.g., leasing an onsite building or facility); and (4) community planning (e.g., determining where to put schools and roads in the areas surrounding the site).

To obtain a broader understanding of potential future information needs, the project team discussed potential stewardship data needs with representatives from a variety of other organizations within and external to DOE. These organizations included the Secretary of Energy's Openness Advisory Panel, the Office of DOE Chief Information Officer; the DOE Historian's Office, the National Archives and Records Administration (NARA), and the Nuclear Regulatory Commission (NRC). The project team also interviewed members of all existing Community Reuse Organizations (CROs)6 to evaluate information needs associated with site reuse and property transfer.

Local Organizations Figure

In the third phase, the project team evaluated a variety of factors that could affect DOE's ability to preserve and provide for access to stewardship data. First, the project team examined the adequacy of current record retention requirements and practices to meet stewardship data needs. The team also examined the adequacy of existing data standards and records indexing practices to assist future users in finding stewardship data of interest. In addition, a group of functional area experts was assembled to analyze scenarios expected to be encountered during each stewardship activity previously identified, identify decisions that would be made under each scenario, and specify the kinds of information required to support the decisions. The project team also evaluated the costs and financial risks associated with the loss of critical stewardship data and the benefits of a proactive approach for managing these data. An important component of these evaluations was the use of specific practices at the focus site (and other sites to a lesser extent) as a validation for various findings. For example, the criteria for identifying the stewardship value of data sources were developed and tested using an electronic record indexing system in use at the focus site. Selection queries were developed for each functional use and applied to the document index. This limited test evaluated the diag-nosticity of the stewardship data selection criteria and identified some barriers to identification of steward-ship records. It is critical to recognize that the specific examples cited in this report, from the focus site and other sites, may or may not be representative of the variety of practices and issues across the 137 DOE cleanup sites. In addition, the general conclusions and recommendations may not be appropriate for every site. Clearly, input and review from a wider range of sites is necessary.

5 The Rocky Flats Local Impacts Initiative is the Community Reuse Organization (CRO) established for RFETS.

6 CROs have been established by DOE to assist in identifying alternatives for reuse of sites, identifying potential site owners or lessees, and facilitating transfer of property to new owners.

CHAPTER 1

1.3 Organization of the Report

The remainder of this report is organized into two parts.

Part I focuses on identifying stewardship data needs, describing current DOE information management requirements and practices, and evaluating their effectiveness in meeting long-term stewardship needs.

Organization of the Report Figure 1

Part II suggests several potential solutions to the gaps and other limitations highlighted in Part I. It also provides specific recommendations for DOE Headquarters and sites to begin addressing stew-ardship data needs. These suggestions are provided to stimulate wider discussion and debate about the issue of stewardship data; they are not intended as specific guidance, requirements, or directives.

Organization of the Report Figure 2
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Last Updated 01/11/2001 (mas)