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3.0 CURRENT REQUIREMENTS AND PRACTICES

This chapter reviews the existing requirements and practices for information management at DOE sites, focusing on the information needed for long-term stewardship. Because long-term stewardship is an emerging issue, there currently are no requirements or standardized practices that specifically address the management of information to be used in support of future long-term stewardship activities. Some types of stewardship data may be addressed in existing requirements and practices, but not for the specific purpose of supporting future stewardship activities. As a first step in assessing the capability requirements and practices to meet the information needs of future generations, it is necessary to understand generally how information is now managed at DOE sites.

While sites are operating, site personnel create, manage, use, and maintain data about the sites, including site history, current conditions, historical releases, existing contamination, waste management practices, and anticipated cleanup activities. Some of this information is collected to comply with laws and regulations, and some is needed in connection with ongoing operations. Various entities and legal requirements govern how information is managed by DOE, including laws and guidelines that apply to all information management by federal agencies, environmental laws and regulations governing waste and materials management, and internal DOE Orders. This chapter is limited primarily to federal requirements and practices that apply to DOE; specific requirements derived from state or local laws or site-specific compliance agreements are not included. The review also includes a discussion of how information is transferred when property is transferred. Section 3.1 describes the life-cycle of information and provides a framework for later discussions. Section 3.2 describes how information about DOE sites is currently managed throughout its life-cycle. Section 3.3 presents an overview of current requirements and practices that lead to the generation of the types of data identified in Chapter 2 needed to support future information needs. Section 3.4 summarizes current requirements and practices for preserving information about DOE sites. Section 3.5 summarizes current requirements and practices for accessing these data.

3.1 The Life-Cycle of Information

The life-cycle of information about conditions and activities at DOE sites includes three distinct phases: (1) generation, (2) preservation, and (3) future access. This life-cycle lays the foundation for understanding current requirements and practices and for evaluating possible gaps that may exist in generating, preserving, and ensuring future access to stewardship data (Figure 3-1). Each of these phases is described below.

• Generation involves the creation and identification of information about site conditions and activities. Information is created using electronic and/ or non-electronic formats in response to regulatory requirements and site operational needs. Some types of stewardship data (e.g., process history, historical hazards) were generated largely during the years in which sites were actively supporting weapons production. Other types of stewardship data (e.g., existing hazards) will be generated between now and when cleanup is complete. Because stewardship activities will continue at sites once cleanup is completed, some types of stewardship data (e.g., post-closure/ transfer operations) will be generated in the future.

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• Preservation involves managing information while it is in active use; capturing knowledge about its content, quality, condition, and other key characteristics; retaining the information for a specified period of time; and transferring the information to a more permanent archive. Preservation begins when information is in active use (e.g., to support cleanup or long-term stewardship activities), continues when the information is no longer in use but stored or otherwise maintained onsite, and is essentially complete once the information is transferred offsite to a more permanent archival repository. Different types of information are in active use for different periods of time. For example, monitoring data may be updated on a monthly or quarterly basis, while some environmental reports are updated annually. Similarly, established schedules for retaining information onsite and in an archival repository differ among information types. Preservation also includes recording sufficient contextual information about a data source to understand how to interpret and use the data. The accompanying photograph provides an example of a facility at which records are being preserved at the focus site (Building 441, NQA-1).

  

• Future Access involves locating, retrieving, and regenerating information that has been sent to an archival repository. Accomplishing this requires knowing that the information exists, having enough knowledge about the information to understand what it contains and how it might be used, knowing where the information is and how to retrieve it, and being able to retrieve the information using the appropriate technology. Future access may be a particular challenge for stewardship data because of the length of time over which this access may need to occur. Once information is regenerated, it may re-enter the life-cycle and need to be preserved and possibly accessed again (see Figure 3-1).

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3.2 General Model for Information Management at DOE Sites

As noted above, information is generated at DOE sites to support a variety of regulatory and site mission requirements. Figure 3-2 presents an overview of the path information takes from the time it is generated to the time it is preserved and the steps involved in accessing and retrieving stored material. This is a representation of a wide variety of information management practices within DOE (many specific variants exist at the sites). Figure 3-2 provides a summary framework for understanding current requirements and practices.

What is a Record?

The National Archives and Records Administration defines "records" to include all books, papers, maps, photographs, machine readable materials, or other documentary materials, regardless of physical form or characteristics, made or received by an agency of the United States Government under Federal law or in connection with the transaction of public business and preserved or appropriate for preservation by that agency or its legitimate successor as evidence of the organization, functions, policies, decisions, procedures, operations, or other activities of the Government or because of the informational value of data in them.

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either destroyed or shipped to one of several archival repositories managed by NARA. NARA either retains the record permanently or for a specified period of time prior to destruction (e.g., 75 or 80 years). Specific requirements for preserving and destroying records are established by a variety of NARA-approved Records Retention Schedules (see Section 3.4). Requirements and practices for preserving electronic material (e.g., databases, word processing documents) are evolving at present. Some electronic material (e.g., electronic copies of reports) are considered identical to their hard-copy counterparts and are preserved in a similar manner. The status of other electronic material (e.g., databases) is unclear at present (see Chapter 4).

Future access to preserved records is achieved by request. Users submit a request to the entity responsible for managing the records repository (either an onsite organization or NARA). Requests for specific records (e.g., a specific report) are fulfilled by locating the box containing the record, retrieving it from storage, extracting the record, and sending a copy to the requester. More general requests (e.g., all reports that cover a given topic area) are fulfilled by first searching indexing systems to identify potentially relevant records, then following the above retrieval and shipping process. More recently, DOE has developed searchable electronic indexes to specific types of records and has made electronic copies of some records available via the Internet (see Section 3.5).

Under current practices, records and indexes may be either electronic or hard copy. Electronic indexing systems are used for both electronic and hard copy records. In addition, hard copy indexing systems are used for hard copy records. It is not clear whether any hard copy indexing systems are used for electronic records, but if so, they are probably uncommon.

3.3 Data Generation

Many of the types of data needed for stewardship are required to be generated under current laws, regulations, or guidelines. Very often, these requirements are prescribed in connection with operating a certain type of site or facility, or monitoring a facility after it is closed. Laws and regulations that apply to radioactive and hazardous waste and materials require that certain data be maintained to demonstrate compliance with statutory provisions. Such laws include the Resource Conservation and Recovery Act (RCRA), the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), and the Atomic Energy Act (AEA), as well as laws dealing with the protection of historic properties and cultural resources. Numerous DOE Orders also contain requirements for generating information. These regulations and orders are listed in Appendix A.

Some of the 12 types of stewardship data identified in Chapter 2 clearly are required to be generated under existing regulations and DOE Orders; however, they are not necessarily identified as data intended for future stewards, as defined in this report. For example, data on existing hazards, a type of data needed for stewardship, are required to be generated pursuant to regulations enacted under the AEA, RCRA, and CERCLA. One such regulation, at 40 CFR 264.73, prescribes that an Operating Record maintained for a facility contain data on the location of each hazardous waste within a facility and the quantity at each location. That same provision also requires that information be kept on historical hazards, specifically the quantities and date of placement for each shipment of hazardous waste placed in land disposal units under certain conditions. Regulations pertaining to radioactive waste (e.g., 10 CFR 61) have similar requirements in connection with obtaining a Nuclear Regulatory Commission (NRC) license for land disposal of such waste.

A limited number of existing regulations identify the generation of data, specifically for the use of future stewards. For example, several provisions of the National Historic Preservation Act identify types of information that have historical value to future generations, including important evidence of the organization, functions, policies, decisions, procedures, and operations of a federal agency and

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information of historical and cultural significance. Certain other regulations (e.g., RCRA, CERCLA) and property transfer requirements implicitly recognize information of value to future generations by requiring that such information be included in deeds or administrative records.

3.4 Data Preservation

There are two distinct aspects to data preservation as it relates to stewardship data. The first involves maintaining physical control of the media on which the information resides and ensuring the physical integrity of these media. Reports, electronic databases, photographs, and other types of information must be adequately stored, maintained, and archived. The second aspect involves recording and preserving what we need to know about the information in order to understand enough about it to use it in the future. Sufficient contextual information must be recorded and maintained in order to understand the significance of the reports, databases, photographs, and other types of information present in an archival repository. Federal agencies, including DOE, address physical control and integrity through formal records disposition requirements and practices. Federal agencies address contextual information, at least for electronic records, through metadata standards. Each of these is discussed in a separate subsection below.

3.4.1 PHYSICAL CONTROL OF INFORMATION

As a federal agency, DOE is subject to the guidelines for records disposition established by NARA. Under these guidelines, DOE has established NARA-approved records retention schedules that specify how long records must be retained. Under these schedules, certain records are to be retained for a specified length of time and others may be discarded and destroyed immediately. Records retention periods vary from a few months to many decades (e.g., 75 or 80 years) to permanent retention. Information regarding the records retention schedules that involve the preservation of data potentially useful for stewardship is contained in Appendix B. Records Management personnel at the sites are responsible for evaluating and dispositioning records to offsite locations for long-term preservation. The protocols used in this process determine the types and forms of data retained at sites prior to their closure, and are thus important to the stewardship effort.

Information Management Efforts

Current and planned efforts at the focus site are concentrated on the modernization of key active systems, evaluation of infrastructure needs, and process needs of site closure. Records management efforts are focused on: Reengineering planning and disposition of records for site closure Maintaining priority records (e.g., RCRA operating records) Retaining consistency in capture processes for cost-effective disposition and retrieval of inactive records Removing contaminated and classified records Identifying and dispositioning abandoned records Providing document production for litigation support Providing compliant management and archiving of electronic records.

The environmental laws and regulations that apply to DOE often address the period over which information must be retained. For example, the closure plans for hazardous waste units under RCRA must include information on steps required for closure, post-closure care requirements, and other matters. Post-closure care is required for 30 years, and the closure report must be placed onto the deed indefinitely (40 CFR 265). In the case of certain NRC-licensed facilities (e.g., Uranium Mill Tailings Remedial Action sites, Battelle Columbus Laboratories, Piqua Nuclear Power Facility), records of the disposal of licensed radioactive materials need only be retained until the NRC license expires. Retention schedules are also addressed in various DOE Orders. DOE may also issue moratoriums on the destruction of particular types of records. The regulations and orders, however, do not necessarily prescribe the form in which they should be retained or the types of information that must accompany the data. At some sites, current practices for preserving information are being reevaluated. In preserving records, DOE must also meet the requirements of the Paperwork Reduction Act of

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1995. Designed to minimize the burden of paperwork on federal agencies, this Act requires agencies to evaluate their records management control processes to maximize practical utility and public benefit of the information created, collected, disclosed, and maintained by or for the Federal Government.

As DOE sites complete cleanup, some (or some portions) may be transferred to other entities. Certain data requirements apply if DOE property is to be sold or leased to another entity. Thus, DOE needs to preserve data adequate for these transactions, some of which may not take place until many years into the future.

The property transfer provisions that apply to DOE (see Appendix C) do not necessarily prescribe specific data that must be preserved, but they often require findings or determinations that presume certain data exist. For example, if DOE leases or sells land under the Hall Amendment to the Defense Authorization Act of 1994, the Secretary of Energy is required to determine (in consultation with EPA and the state) that "the environmental conditions of the property... are consistent with safety and the protection of the public health and the environment." To make this determination, DOE must have information about the source, type, and extent of environmental contamination at the site to be transferred. Other examples of information required to be transferred when property is transferred are described in Appendix C.

Historic Mechanisms for DOE Property Acquisition

Acquisition.Obtained through purchase from original owner. Withdrawal. Property withdrawn from public domain, reserved by the Department of Interior (DOI), for use by the DOE. Other. Property provided to DOE via grant or some other vehicle.

3.4.2 CONTEXTUAL INFORMATION

As a federal agency, DOE is subject to existing guidelines and standards for recording and preserving sufficient contextual information to allow a user to understand and use data contained in a record. Contextual information is typically preserved in two ways. Indexes are used to preserve contextual information about books, reports, photographs, maps, and other hard copy records. Metadata are used to preserve contextual information about data in electronic databases.

Why do we need contextual information for records that are physically retained and archived? The simple answer is that many records (e.g., maps, photographs, databases) are virtually worthless without sufficient contextual information. Imagine the difficulty in re-using a data set you created six months ago if you have lost your reference notes (e.g., groundwater data includes contaminant concentrations levels with no well location or depth information). You may be able to understand the numbers in the data set and where they came from, but you might not know how each data element is defined and whether this is the original or revised version. Imagine yourself with the same task as above, but this time the data set was created two years ago by someone else who now works for another organization. Imagine someone else trying to find the information contained in the two data sets 15 years into the future. If they knew to look for these data sets, and if they could locate and read them, how would they know what the data really represent? If instead, a structured approach for recording a description of this data set had been followed, it is more likely that the information would be retrievable and usable far into the future.

Contextual information is especially important when the life-cycle of the information contained in the data set will extend many years into the future. More specifically, contextual information is important because the life-cycle of stewardship data will extend beyond the period of time when site cleanup is considered "complete." Long-term stewardship will depend on communication— sharing information about sites between people and organizations, across the years. Contextual information

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is necessary to facilitate that communication, so that future stewards will be able to identify and find available information, understand what it represents, and understand its limitations. Without the ability to transfer contextual information to future users, raw records such as maps, photographs, and data archives are of very little use.

3.4.2.1 Indexing

The term "indexing" in this report refers to the process of referencing the content of records through keywords, subject codes, and other identifiers. Without a standard method of indexing, it may be difficult or impossible for future generations to identify and access stewardship data. Although efforts are underway to develop a standard federal index for environmental data, there does not appear to be a Federal regulation or standard that discusses indexing. Also, there does not appear to be any standard indexing system or standard for hard-copy records maintained by DOE. DOE records management guidance¹ provides general conceptual guidance for managing electronic records and developing standard subject codes and other indexing elements but does not establish a standard thesaurus for such elements. (DOE has formally withdrawn this guidance, but sites continue to use it as a working reference). In fact, over the past several years, DOE has not required subject indexing because of its continuing effort to convert its records to a digital format (and thus to use keyword searches to locate information).

The National Performance Review also identified a need to develop indexing standards and has called for the creation of a National Environmental Data Index (NEDI). The NEDI will serve as a standard reference to all government environmental data holdings (i. e., a "yellow pages") and thereby facilitate access to these holdings. NEDI is intended to provide access to existing environmental information locator systems that describe data holdings (metadata databases). Providing one-stop access to these separate indexes for environmental data and information queries is a high priority task in the design and implementation of the NEDI. Phase one implementation will begin with development of a prototype system. DOE plans to include information on global change, energy resources, and renewable energy in the prototype but does not plan to include any information on cleanup. NEDI can be accessed at esdim.noaa.gov.

DOE's Office of Scientific and Technical Information (OSTI) has developed an online bibliographic database for all DOE-sponsored scientific and technical reports issued since January 1, 1994. Indexers assign terms using a controlled vocabulary (based on the publication International Energy: Subject Thesaurus) to describe the specific technical information contained in the report. Users also can search the database using their own keywords. The database can be accessed at this Internet address: www.osti.gov/html/dra/dra.html .

3.4.2.2 Metadata

The term "metadata" refers to information about a given set of electronic data what data are available, what these data represent, and the limitations a user would need to understand to use the information effectively. Many of the basic elements needed to describe a data set are obvious (for example, its name, the name of the person who created it, the date( s) it was created and revised, and a short description of its content). Beyond the basics, however, lie myriad details that can be approached differently. The need for consistent descrip-

Metadata

Metadata describe the content, quality, condition, and other characteristics of electronic data. Metadata are used to organize and maintain investments in data, to provide information to data catalogs and clearinghouses, and to aid data transfers. Metadata records describe data sets in sufficient detail for a user to: Know enough about each data set to understand what it contains and how the data might be used Have a means of sifting through a series of data sets to find the specific data that the user needs Maintain an accessible repository in which data can be preserved and from which they may be accessed.

¹ Implementation Guide for Use with 36 CFR Chapter XII -Subchapter B Records Management, DOE G 1324.5B, July, 1996. DOE G 241. X-I, Electronic Records Management Guide for use with 36 CFR XII -Part 1234, Draft, March 1998

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tions of the contents of documents and databases extends well beyond DOE and the concept of long-term stewardship. Metadata standards have long been a national and international priority for professionals in government, information management, and archiving and library communities.

The Federal government has established several sets of metadata standards and required their use under a variety of laws and administrative orders (see Table 3-1). These sets of standards were developed for different purposes and represent a range of complexity. The simpler the metadata standards, the easier they are to implement, but the less information they convey. Three sets of metadata standards provide a good example of the range of available options for stewardship data: the "Dublin Core," the Government Information Locator Service (GILS metadata standards), and the Federal Geographic Data Committee's Content Standards for Digital Geospatial Metadata (FGDC metadata standards).

• The Dublin Core represents a simple set of metadata elements assembled through a series of workshops with experts from libraries, the networking and digital library research communities, and a variety of content specialties. These standards are intended to be used by non-catalogers as well as by those with experience with formal resource description models. Most of the metadata elements can be commonly understood to represent the equivalent of a catalog card for electronic resources. While easy to understand, the Dublin Core is not in itself a sufficiently comprehensive or unambiguous approach to documenting data sets. It is well suited to documenting resources in a form people can read, but not specific enough to facilitate efficient computer-based searching on its own.

• The GILS metadata standards were developed pursuant to U. S. Public Law 44 USC 3511, which requires establishment of "a distributed agency-based electronic Government Information Locator Service … which shall identify the major information systems, holdings, and dissemination products of each agency." The creation of GILS was a goal of the National Information Infrastructure: Agenda for Action, which called for the establishment of a "virtual card catalog" of government information holdings.² GILS was intended to identify information resources throughout the Executive Branch, describe the information available, and provide assistance in obtaining the information. It was also intended to improve the abilities of agencies to carry out their records management responsibilities. The GILS metadata standards are much more comprehensive than the Dublin Core, but are not specifically designed for geospatial data.

² OMB Bulletin 95-01 (December 7, 1994)established GILS as envisioned in The National Information Infrastructure: Agenda for Action, Information Infrastructure Task Force (September 15, 1993).

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• The FGDC metadata standards were developed pursuant to Executive Order 12906 ³, which mandated that all federal agencies adopt these standards for all geospatial data sets created after January 1, 1995, in order to facilitate sharing of geospatial data sets among Federal agencies and with the public. These metadata standards specify the information content of metadata for geospatial data sets like maps, Geographic Information System (GIS) and Computer Aided Drafting (CAD) data sets, and other data files that contain information about where things are located. Metadata meeting these specifications are now required by OMB for any geospatial data disseminated to the public. While not required for non-spatial data, these standards provide a carefully considered approach that can, with minor modifications, be applied for non-spatial data. With 334 metadata elements defined in the current set, the FGDC metadata standards are the most comprehensive Federal metadata standards. Some FGDC metadata elements are mandatory; many more are "mandatory if applicable" or optional. Some fields may be completed with any-typed text ("free text"). Other fields have specifically enumerated values or require index terms to be drawn from an explicit thesaurus; this improves machine readability and searchability of these records.

The FGDC framework does not provide enough information about data sets for all applications. Geologists, for example, may require specific, keyword-searchable information about the types of rock strata that might otherwise be described in a free text field. Biologists might need specific information on species or habitat associations. And stewards of former DOE sites might require specific information on special nuclear materials issues, relevance to litigation, or other issues. The FGDC approach includes a provision to create Supplemental Profiles to be used in conjunction with the existing metadata standards. Rather than re-defining existing elements, this process seeks to narrow the options for filling in the existing data elements to assure that the information that is entered is sufficiently specific, and adding additional user-defined data elements as appropriate to capture the information content of the data set.

The Metadata Content Standard for Biological Resources Data, proposed by the Biological Resources Division of the U. S. Geological Survey, is one such "profile." Others are in various stages of preparation for geologic information, utility information, and facility identification information.

3.5 Future Access

Access to information relevant to stewardship can be obtained in a variety of ways. Some aspects are governed by existing laws and regulations, others by DOE's own practices. Certain laws that apply to all federal agencies set a general framework for access to DOE information. For example, the Freedom of Information Act (FOIA) prescribes procedures for public access to certain information maintained by the federal government. A goal of DOE for the year 2000 is to develop and implement processes to provide access to information addressed by these and related laws, regulations, Executive Orders, and directives.⁴ Efforts to meet these requirements are being addressed by the Secretary of Energy Advisory Board (SEAB) Openness Advisory Panel (OAP). The OAP was convened in July 1996 to advise SEAB regarding the DOE's classification and declassification policies and programs and on improving public access by providing the public with accurate and complete information on DOE activities.⁵ Like the environmental laws references in Section 3.3, these efforts are not necessarily focused on stewardship, although they may be quite useful for that purpose. Certain types of information may not be made available, however, under provisions of the Privacy Act. The AEA also restricts access to information about certain nuclear materials and activities.

³ Executive Order 12906, Coordinating Geographic Data Acquisition and Access: The National Spatial Data Infrastructure (11 April 1994) requires federal agencies to ensure that all geospatial data are collected in a manner that meets all relevant standards adopted by the Federal Geographic Data Committee (FGDC), an interagency committee established by the Office of Management and Budget.
⁴Roadmap To the Year 2000, U. S. Department of Energy, Records Management Program, Revision 1, August 1995. ⁵Responsible Openness: An Imperative for the Department of Energy, Openness Advisory Panel, Secretary of Energy Advisory Board, U. S. Department of Energy, August 1997.

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Existing record management procedures instituted by DOE are primarily designed to ensure access to information over the active use of the data and the site. Practices within the Department are beginning to account for changes in its missions and operations in planning for life-cycle management of information. Public access to information is also prescribed in connection with specific legally required processes, such as the preparation of Environmental Impact Statements under the National Environmental Policy Act (NEPA).

For DOE property that is transferred or reused, there are various mechanisms for accessing information. During the transfer process, the future property owner or lessee identifies the information that should be obtained by DOE or requests the appropriate records. As described in Appendix C, site Community Reuse Organizations (CROs) may also request certain types of information as they work with DOE to develop a Community Transition Plan, which can involve transfer, reuse, or other disposition of sites and property. Some information about a site also must be referenced in deeds, particularly when certain use restrictions apply due to environmental conditions. Any documents developed under NEPA that describe environmental conditions at the site are also publicly available. Some sites also have public reading rooms that contain a variety of site-related documents that future stewards may access.

Recommended Stewardship Data From Property Reuse Guidance

Nature and extent of contamination Environmental status of property Information on completed or planned decontamination activities including cleanup levels, schedules, and costs Natural resources, including wetlands,aquifers, floodplains, endangered or threatened species and habitats, migratory bird routes, mineral deposits, pristine areas, etc. Cultural resources Marketability analyses that include facility characteristics Source: Resourceful Reuse: A Guide to Planning Future Uses of DOE Sites, May 1996, DOE/ EM-0285

Approximately 3.2 million cubic feet of DOE records survive in dozens of locations across the United States. A limited number of these records have been electronically scanned and/ or indexed and thus are relatively easy to locate and retrieve. Many other records exist only in hard copy and are poorly cataloged, if at all. At the national level, there are three primary means to access these records:

• DOE maintains reading rooms at various sites around the United States. Holdings at each reading room range from approximately 500 to more than 300,000 documents. DOE receives approximately five to eight thousand requests each year for documents at these reading rooms.

• Each year, DOE receives approximately 3,000 requests for information under the FOIA. DOE is required to respond to each FOIA request within 10 days. However, the average response time to complete the request is considerably longer. In 1991, average response time was nearly 3.5 years. By 1995, this was reduced to approximately 16 months.

• In recent years, DOE has developed electronic indexing systems for a variety of hard copy records. These systems allow users to identify documents of interest via electronic keyword searches (e.g., over the Internet). In some cases, the user must order (and pay for) a hard-copy version of each document of interest. In other cases, the documents are available electronically via the Internet. Examples of such systems include:
  • DOE's Office of Human Radiation Experiments has located and identified approximately 13,000 documents related to Cold War radiation experiments on human subjects. These documents are available in electronic format via the Internet (hrex.dis.anl.gov/ ) The information is fully searchable by personal name, location, and many other keywords.

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• The DOE Reports Bibliographic Database provides an electronic index to all technical and scientific reports produced by DOE since January 1994.

• DOE's Office of Science and Technology Information (OSTI) manages several other programs to disseminate scientific and technical information electronically, including a repository of all documents published by DOE.

DOE sites also maintain repositories of hard copy records and have developed electronic indexing systems. In some cases, sites have recorded information contained in these records electronically and have made this information available via electronic search and retrieval methods. For example:

• Los Alamos National Laboratory (LANL) maintains the Facility for Information Management Analysis and Display (FIMAD) database containing the results of several million environmental samples conducted to support cleanup at LANL. Users include the cleanup program as well as other programs at LANL, and state and federal regulators.

• The Oak Ridge site has consolidated documents from 10 records centers at the K-25 plant into two records repositories. These records are searchable via an electronic index using a proprietary document management system known as Documentum. The Savannah River Site also uses the Documentum system.

• The focus site maintains the Environmental Records Database (ERD), which is a compilation of more than 30 records indexing databases from across the site. ERD currently contains more than 400,000 records related to environmental data through 1995. These records are indexed and searchable. (See Appendix D for more information regarding the ERD.)

The options available to persons or organizations outside of DOE who wish to access a particular record or set of records include the following:

1. Visit a DOE public reading room.

2. Search the DOE Internet site, which includes a variety of information such as the published documents available from OSTI.

3. Submit a request to DOE under the FOIA.

4. Visit a NARA archive that contains DOE records.

5. Submit a request to the appropriate field office, where a previous arrangement has been made to provide information directly to the requester (e.g., when property is to be transferred to another entity there may be an agreement to provide any information useful to the future user).

This is not an exhaustive list and other information resources are available (e.g., citizen groups, DOE contractors).

Within DOE, the process to search and retrieve records varies from site to site. There may be multiple records control processes at a site, reflecting the variety of programs and offices. To search for a particular record, a records manager in one program will identify whether the record is in his/ her records management program. If the record is not in the manager's program, she/ he will work with other records managers at the site to identify where the record is likely to be located. Once the appropriate records management program is identified, the manager will search the records management system (e.g., electronic indexing system) for the record. The manager will then be able to identify where the record is located, as well as the size and complexity of the record (e.g., whether

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the record is a specific document or is an entire project file). The records manager can then work with the requester to obtain the portion or portions that are most relevant to the request.

It is possible that the record requested is not contained in any records management program at the site. For example, the record may still be in active use. If the records manager determines that the record is not contained in any records management program and it is in active use, the records manager will work with other managers at the site to identify the office and/ or personnel that are most likely to have the record.

Costs associated with locating and retrieving past records are significant. For example, DOE currently spends approximately $5-6 million each year responding to FOIA requests, and maintenance costs for site-specific systems such as the FIMAD database at LANL and the document management system at K-25 at Oak Ridge are approximately $1.5-2 million per year. Processing costs per record also are significant. For example, the current costs involved in retrieving, scanning, and disseminating OSTI's holdings currently costs approximately $25 for each paper copy record and approximately $3 for each electronic record. It is also extremely costly to locate, retrieve, and make available past records. For example, to assemble the repository of documents related to Cold War radiation experiments on human subjects, more than 200 staff in Washington, D. C. and around the country spent most of their time in 1994 to locate, declassify, and evaluate these records and make more than 13,000 documents available to the public via the Internet. Some of these records were in the custody of private institutions rather than DOE, which complicated retrieval of the records. Details regarding these and other related costs are provided in Appendix E.