• Information management requirements do not appear to be coordinated with property transfer requirements. Information management (IM) efforts currently focus primarily on the dispositioning and archiving records that exist at a site. Many of the information needs of future users, which will depend on the records archived by IM efforts, are determined at the time of property transfer, not during the archival process.

• Transfer of site stewardship has already begun. Community Reuse Organizations (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. Although a survey of CROs did not uncover any major issues associated with stewardship data identification, at least one CRO relies upon retired site personnel to fill existing data gaps; the long-term sustainability of this practice is weak at best.

There are four primary consequences of a failure to identify stewardship data. First, information critical for long-term stewardship may be lost or abandoned. This may require sites to spend enormous resources to cull through volumes of documents, files, and computer drives to catalog abandoned records and assess their stewardship value. It is likely that such searches will be unable to fill all critical data gaps, resulting in the need for DOE to re-create missing data. Some of the costs associated with such attempts are detailed in Section 4.2.

Second, a failure to identify stewardship data may result in inconsistency in the form or format of information preserved for future generations. Information with stewardship value currently exists in a variety of forms, including hard copy reports, maps, electronic databases, electronic reports, and deeds. This lack of consistency will hinder efforts to preserve and provide future access to this information.

Potential Consequences of a Failure to Identify Stewardship Data

Critical data may be lost, thereby endangering human health and the environment. Preservation and accessibility of stewardship data may be hindered due to inconsistent formats. Some data required for property transfer and long-term stewardship may not be available at time of property transfer. DOE may incur higher preservation and retrieval costs if stewardship data are not separated from other data.

Third, some of the data required for property transfer and long-term stewardship may not be readily available at the time sites are to be transferred. This may cause unnecessary delays in the transfer process and additional expenses to locate and retrieve the information from existing archives. Some of the costs associated with property transfer delays are detailed in Section 4.2.

The final consequence will be an increased tendency to save more information than needed. This will make it more difficult to isolate and locate stewardship data and increase costs for information preservation and retrieval.

4.2 Preservation of Stewardship Data

DOE's existing data preservation requirements and practices have focused primarily on maintaining physical control of hard copy and electronic records. These requirements and practices were developed to support data preservation needs when site missions and staff were relatively stable over time. The rapidly changing missions at many sites (e.g., from cleanup to stewardship), coupled with workforce instabilities associated with reduced budgets and alternative contracting strategies, have already resulted in the loss of some stewardship data. Many records have also been abandoned

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without being adequately indexed and archived. These abandoned records are also in jeopardy of being lost.

FINDINGS

Information that has stewardship value is being lost, destroyed, or maintained in formats that may not be useful to future stewards. Some data will not be preserved as long as necessary for stewardship purposes. Some data will be preserved adequately but may not be able to be located, or will not be accompanied by enough descriptive information to be usable. Most records of facilities and site infrastructure are required to be destroyed when facilities are demolished or infrastructure is declared obsolete. DOE has already begun to pay increased clean-up costs because critical data have been lost.

Current preservation requirements and practices for paper and electronic records also may be inadequate for stewardship data needs. Because they were developed for different purposes, many of the current requirements for data retention are shorter than the lengthy or even indefinite period needed for stewardship purposes. For example, the DOE records retention schedules require some records to be archived permanently, but others to be destroyed after periods of time that range up to 80 years. Records of facilities and site infrastructure (e.g., process lines) are particularly vulnerable because they are generally required to be destroyed when facilities are demolished or infrastructure is declared obsolete. Some stewardship data generated in the past may already have been destroyed in accordance with the records retention schedules. In addition, descriptive information that provides sufficient context for understanding archived material may not be adequate. Not all indexing or metadata standards are the same, and existing standards may not include all the information needed by future generations. There is no single place where one can determine the kinds of information about a site that may exist and where this information is located. Information that may be needed by future generations is not distributed to places and the people most likely to use it. Finally, no clear mandate requires DOE to transfer indexes and other finding aids to future site owners. The following illustrations and observations support these findings:

As sites reconfigure or are closed altogether, the problems of locating, transferring, and protecting records loom large. Roadmap to the Year 2000

• Abandoned records increase information management costs. At the focus site, with the transition of the site contractor in 1995, the Research & Development (R& D) department was reduced from 200 personnel to three. These former R& D employees had been responsible for developing stabilization, treatment, and measuring technologies for multiple purposes at the site. When these employees left suddenly, large quantities of records, both paper and electronic, were abandoned. These records are required to be treated as permanent records according to NARA guidelines. Estimated costs to preserve this information is $2 million.

• Paper records may be fragile. Many old records are preserved as carbon copies. These have proven difficult or impossible to scan electronically. Also, paper records decay over time, particular records preserved on acid-based paper.

  

• Production records have been lost. At the focus site, in preparation for decommissioning of a former nuclear production facility, production records for component testing were identified by records management personnel for long-term retention. Initially, these records could not be archived immediately because they were slightly contaminated. Before they could be archived, the records were inadvertently boxed up in crates and disposed of as low-level waste. These records were intended for transfer to Los Alamos National Laboratory. No one has estimated the cost impacts associated with the loss of these quality assurance documents.

• Information on facility characterization has been lost. During facility closure it is necessary to gather data regarding existing facility hazards. At the focus site, a facility characterization and inventory was performed in 1993, 1994 and 1995 that identified the nature and extent of hazardous and radioactive contamination within several major facilities. Because of a change in the operating contractor and reductions in force, recorded characterization and inventory data were lost. In later efforts to prepare a major facility for demolition, these data were recovered only because a former site employee was available to return and search through a stack of computers that were pending property disposition. Recovery of the data saved DOE nearly $1.5 million.

• DOE may no longer possess important records. On June 6, 1989, the Federal Bureau of Investigation (FBI) began an investigation of the focus site. Unannounced, FBI investigators targeted particular offices in which they knew specific documents were located, and began taking them offsite. On the first day of the investigation, there were no records of which documents the FBI had seized and removed from the site. By the second day, the records management office developed a process for cataloging and copying the documents before the FBI removed them. When requested, the FBI returned the documents seized on the first day for cataloging and photocopying by the records management office. However, it is unknown whether all of the documents seized were returned; it is possible that some documents, potentially including vital records and/ or original records (i. e., records for which DOE does not have a copy), may not have been returned.

• Information sufficient to determine the stewardship value of a record is not being preserved. A pilot test at the focus site showed that data are often not accompanied by information that would help a user identify its value for stewardship. For example, information accompanying the data may describe its content (e.g., groundwater sampling results) but not its pedigree (e.g., whether the data were reviewed for quality). This increases the difficulty of identifying data with stewardship value. Appendix D contains more information regarding the pilot test and its results.

• Ownership of records during contract transition is often unclear. Before there was a change in the operating contract, the environmental records center for the focus site was maintained at an offsite location. During the contract transition period, ownership of these records was not clearly established, and funding to bring these records back under site control was not accounted for in the site budget. Currently, the effort to preserve these records is unfunded. Clear guidance from DOE regarding contractual provisions for record continuity and transfer during changeover of the contract could have avoided these problems.

• The Integrating Management Contractor (IMC) approach creates information management challenges. The focus site was one of the first DOE facilities to change to the IMC approach. Overall, the IMC has resulted in savings over previous management configurations, but has created several smaller information challenges: larger transient work forces make records management control more difficult, work directly associated with performance incentives tends to have higher priority than records management activities, emphasis to reduce requirements has undermined efforts for comprehensive standards, and a greater number of subcontractors make enforcement of standard practices difficult.

• DOE is not fully involved with federal efforts to improve data preservation. There are several efforts in progress at the national level for the generation, identification, and creation of databases and/ or locators. However, there is no clear connection between DOE initiatives and these other efforts.¹

¹ National efforts reviewed include the National Environmental Data Index (NEDI) as well as other agency initiatives. NEDI is a data index that is intended to provide direct access to environmental data and information descriptions primarily within the United States. Agencies involved with NEDI include the Departments of Agriculture, Commerce, Defense, Energy, and Interior as well as the Environmental Protection Agency, the National Aeronautics and Space Administration, and the National Science Foundation.

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• DOE currently stores large numbers of photographic records at multiple locations. Photographic records of facilities, property, processes, and products have existed at DOE sites since their inception and require handling and storing techniques that are different from techniques typically used for documents. At the focus site, more than 1.2 million negatives, nearly 25 percent of which are classified, are stored within secured areas at the site. With current photographic cataloging efforts from decommissioning activities, these quantities will increase rapidly over the next several years. It is not certain which of these photographs are important for stewardship purposes. Efforts are underway to locate suitable offsite storage for both the classified and non-classified negatives. Currently, there is no single location for DOE to consolidate photographic records.

• Costs for generating, preserving, and accessing stewardship information are significant, and generally budgeted as indirect costs within DOE. Several DOE sites are addressing the need to establish cost accountability but are placing much of the burden for the preservation of data on those who generate data. These include establishing chargeback systems on information generators and budgeting of information management services as a direct activity within project baselines. At the focus site, current records management costs are estimated at slightly less than 1 percent of the total site budget for fiscal year 1998.² Records management services are currently funded mainly (80 percent) as an indirect activity. Implementation of the Integrating Management Contractor at the site has reduced records management (RM) costs. This has made the use of RM personnel more attractive for project managers and led to minor improvements in the RM problems at the site. Indirect costs for RM activities at other DOE sites (i. e., Los Alamos National Laboratory, Yucca Mountain) and for other federal agencies are similar.

• Costs for archiving records are only a small portion of site information management costs. Costs associated with information management account for about 8 to 12 percent of the budgets at DOE sites. Information management includes all document control and delivery systems, computers, electronics, and software. and other aspects of managing information at the site. Of the 8 to 12 percent, nearly onequarter of the funds are allocated for document management, which includes activities to manage documents while they are active, including document control systems. An even smaller percentage of site budgets is spent on archiving of records. For example, at the focus site, only 0.3 percent of the site budget is used for archiving records, which includes all activities needed to retain information for future site stewards.

• Changes in technology have historically created problems for record preservation. DOE is moving from a management system that is largely oriented to paper records toward a greater reliance on electronic record-keeping. Historically, many problems have been associated with a radical change in basic technologies.³ As the number of critical stewardship data sources that are retained electronically increases, DOE will likely expect to provide initial and continuing access to electronic archives; encounter more concern about the adequacy of documentation; and be under increased pressure for multi-agency cooperation to link archive services.

• DOE will face increased pressure for multi-agency cooperation. Regulators are increasingly likely to require sites to integrate various data collection efforts to support their oversight activities. At the focus site, regulatory provisions requiring multi-agency cooperation are included within the Rocky Flats Cleanup Agreement (RFCA). These provisions require the creation of a RFCA database to improve the availability of sampling and related documents. The purpose

² Based on the Rocky Flats Closure Project Life-Cycle Baseline. Activities included in the records management totals included records storage/ retrieval, litigation support, library services, imaging services, record oversight, document control, correspondence control and several other associated RM services.

³Playing for Keeps, Electronic Records Management Conference Proceedings, Hedstrom, Margaret, Canberra, Australia, November 1994.

GAPS AND RESULTING CONSEQUENCES

of the database is to improve the effectiveness and efficiency of current monitoring programs conducted by DOE, the Colorado Department of Public Health and Environment, and the surrounding cities of Broomfield and Westminster. The long-range goal for the database is to integrate all environmental and natural resource monitoring at the site.⁴
• Site transfer can be significantly delayed if relevant data are not readily available. Property transfer of the Oxnard facility in 1997 was delayed while final record verification was completed. Record verification involved the rectification of waste manifests with the Environmental Protection Agency. It took approximately three weeks, at an estimated cost of $50,000, to locate and retrieve relevant documents concerning this small, former metal forging site.

• Lack of stewardship information increases cleanup costs. At the focus site, remediation of "Trench 1" was slowed because of incomplete information regarding the burial of 90 to 125 barrels of "special" or "miscellaneous" wastes. DOE spent more than $50,000 in an unsuccessful search for the missing information. Because this information could not be found, the precautionary measures for the cleanup were based on an assumption of the highest level of risk to the workers and the environment, resulting in higher remediation costs.

There are at least three likely consequences of a failure to adequately and efficiently preserve stewardship data. First, site closure or transfer may be delayed, putting many of the critical objectives of the EM plan to accelerate cleanup in jeopardy. Funding that could be devoted to the primary site cleanup mission may be diverted to storing and sifting through abandoned records, re-creating lost information, and maintaining the infrastructure necessary to support records use and retention needs. Also, if there is not sufficient information to fully characterize a contaminated area and additional precautionary measures must be taken to address the high level of uncertainty, the cost of cleanup will increase.

Potential Consequences of a Failure to Preserve Stewardship Data

Cleanup costs may increase and site closure may be delayed. Protection of human health and the environment may be jeopardized because future stewards may not have the information they need. Even if data are provided they may not be usable.

Second, future stewards may not have the information they need because it had been destroyed or lost and is impossible or too expensive to regenerate. Under some circumstances, protection of human health and the environment may be jeopardized. For example, incomplete information may result in the breaching of abandoned process lines and exposures to radioactive substances, or the discovery of previously unknown sources of contamination, during long-term stewardship. Inappropriate future uses of lands or facilities may occur because residual contamination is undetected. On the other hand, incomplete information may result in unnecessary restrictions on the future use of facilities, or lands or the use of control measures that are more stringent than necessary, because the true nature of residual hazards cannot be determined.

Even if stewardship information is available when needed, it may not be usable because it is not accompanied by sufficient descriptive information. The lack of clear indexing and metadata standards for long-term stewardship makes it likely that critical contextual information for many records will not be available. The extent to which this may hinder data usability is difficult to assess at present.

4.3 Future Access to Stewardship Data

During the weapons production era, access to information about site conditions was closely restricted for national security reasons. In the future, the challenge will be to ensure that stewardship data are readily accessible. Current requirements and practices are moving toward that goal. Access to

⁴Final Rocky Flats Cleanup Agreement, Part 23, "Sampling and Data/ Document Availability," July 19, 1996.

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information about past site conditions is primarily through two mechanisms. Some information is conveyed to future users through deeds and related property transfer documentation, while access to archived records is provided primarily through a formal request process. In the latter process, users request information and it is retrieved from archive repositories and sent to the requestor. The process is not particularly rapid, and successful retrieval depends considerably on knowing that a particular archived record exists. Because there is no systematic approach to indexing and other search tools specific to stewardship data needs, over time it is likely that knowledge of the existence of particular records will be lost.

FINDINGS

Knowledge that archived information about DOE sites exists may be lost. Future users may not know where to search for all relevant information, causing delays in action or the potential for unnecessary risk. Even when such knowledge is preserved, and users know where information is located, it may take too long or be too expensive to gain access to stewardship data.

While the right to gain access to certain information is provided by law, users may not know certain information exists and they will not obtain meaningful results from data searches. Moreover, because existing records are not archived in a single place, future users may not know where to look for particular information. For example, information may be accessible through a variety of sources, includingNARA, EPA, agencies responsible for NEPA implementation, states, and local communities. Even if future users know where to look, the current retrieval process may take too long and be too expensiveto be useful, particularly when information is not stored in one location. Also, the costs to access the information may serve as a barrier to information retrieval. Federal agencies do not always charge users for records retrieval costs; states and local communities, however, often require users to pay for such services. In addition, changes in technology may create particular challenges for information retrieval, particularly electronic data. Because many current requirements and practices apply only to federal agencies, it is unclear whether stewardship data generated and preserved by non-federal entities (e.g., states or local communities vested with long-term stewardship responsibilities) will be accessible through current mechanisms. For example, states may maintaintheir own information archives and may not be required to provide copies to NARA. These findings are supported by the following illustrations and observations:

• Changes in information technology have historically created problems for locating, retrieving, and regenerating archived information. Predicted problems include an increase in emphasis on access to, rather than physical control of, data; and an increase in the need for rapid, efficient, locator mechanisms to assist in the identification of electronic data.⁵

• Significant costs are associated with the retrieval of data that span several decades.DOE's Office of Human Radiation Experiments was established in March 1994 to catalog Cold War radiation experiments on human subjects. Relevant historical documents were identified from an estimated 3.2 million cubic feet of records. These records were distributed throughout the United States, many of which were cataloged poorly, if at all. This effort required more than 200 person-years of DOE staff time.

• Records searching comprises the majority of information retrieval costs. During Phase I of a dose reconstruction project at the focus site, records, many of which were not indexed, were searched at both on and offsite locations over the course of three years. During Phase II of the study, classified records at the site were reviewed. Review of the files led to the discovery that many data gaps existed, forcing an extrapolation of the team's results through months of missing records. It was estimated that with a comprehensive data and records management system, up to 75 percent of the labor hours spent on Phase II of the project would have been unnecessary. The entire cost of Phase I was associated with the records search. In general, the study team reported that data retrievability was not a priority of the

GAPS AND RESULTING CONSEQUENCES

Department; to the extent that records management was practiced, the driving force was regulatory scheduling requirements.

• Abandoned records pose the largest problem facing the focus site litigation support office. Much of the cost for litigation support at the focus site can be attributed to document identification and retrieval. During the litigation process, the production of documents can consume up to 100 percent of the time of the litigation support personnel. At other times, the production may require as little as 5 percent of their time. For example, several years of work by legal support personnel have been required to produce documents for a legal case (the Cookcase). Most of the documents required for the Cookcase and others are historical and may no longer be in use. If a particular document was not in the records management control system, as was often the case, it was difficult to determine if the document even existed. The consequence of failing to produce a document is that the litigation support office is not able to fully support the principals in making their case.

• Assessment of a document index indicates that not all records currently being archived are needed for stewardship. An evaluation of the current document indexing contents, discussed in detail in Chapter 5, was performed on current indexing systems maintained at the focus site. The purpose of this evaluation was to assess the ability of future stewards to locate potential stewardship documents based upon search criteria, or attributes of information, likely to be used in the future. Results of the assessment suggested that nearly 75 percent of the indexed records might not meet the definition of stewardship data. Of the remaining documents, roughly 21 percent had potential, and 4 percent definite, stewardship value. This assessment was performed on over 400,000 records maintained in the Environmental Restoration Database (ERD).⁶ Results of this exercise also indicated that the document index maintained within the ERD was not sufficiently consistent or rich enough in content to identify the potential stewardship value of many records indexed by the system.

• Responding to Freedom of Information Act requests is expensive. Enacted in 1966, the Freedom of Information Act (FOIA) provides any person a statutory right, enforceable in court, to access federal agency records.⁷ Both DOE Headquarters and field offices receive thousands of FOIA requests per year; DOE spent over $5.5 million processing FOIA requests in 1996. The numbers of requests do not include the thousands of requests for documents received at the 14 DOE Reading Rooms located across the nation.

• Electronic information management systems reduce costs. The Nuclear Regulatory Commission (NRC) manages large volumes of records associated with policies, decisions, and bases for regulatory action. The annual cost of records management at the NRC was approximately $7 million, about 1.5 percent of the total NRC budget, before modernization. Recently, the NRC was faced with the issue of updating its 1978-based index system. A cost-benefit study led to the installation of a new NARA-approved electronic system. Benefits obtained from the system included improvements to the business process for regulatory activities, assistance to compliance efforts with the Paper Reduction Act and the Electronic Freedom of Information Act, reduction of personnel needed for records management, and the ability to ensure complete and accurate retention of NRC records. Commercial bench-marks have shown reported cost savings of up to 33 percent based on the reduction in the overhead costs of space and personnel required for maintaining a traditionaldocument repository when electronic information repositories are available.

• Former site employees are required to fill stewardship data gaps. It is a common practice for Community Reuse Organizations to hire former employees of the site to fill existing gaps

⁶ The Environmental Restoration Database (ERD) is a records database in use at the focus site that consists of over 30 record indexing database with over 408,00 records. The primary focus of the ERD is on environmentally related data.
⁷ Freedom of Information Act Guide & Privacy Act Overview, U. S. Department of Justice, Office of Information and Privacy, September 1996 Edition.

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in stewardship data, especially where site historical and infrastructure documentation is missing. This practice appears to be largely successful to date, but its long-term viability is tenuous.

• A lack of data increases stewardship costs today. Organizations currently responsible for long-term stewardship have faced unexpected increases in maintenance and operating costs due to the lack of complete and accurate utility drawings. At one site, for example, utility maintenance and replacement costs increased 15 percent above budgeted costs because information about obsolete infrastructure was missing.

• Lost data may limit future use options. At one DOE site, complete and accurate environmental information regarding remaining hazards was lacking when property was transferred to a non-DOE entity. During their development efforts, the non-DOE entity discovered additional contamination that unexpectedly restricted future property uses.

• Local communities do not have access to critical planning data. Many communities surrounding DOE sites do not have spatial planning data related to the physical topography and environment across the property. Several community stakeholders have expressed concern regarding the loss of data or data integrity prior to transfer of the sites to the communities. One important concern is that land use decisions can change until the time that the Record of Decision is issued, and therefore access to key planning data is critical early in the process.

There are five primary consequences of a failure to adequately provide for timely and efficient access to stewardship data. First, future generations may not seek access to stewardship information because they do not know it exists or the information exists outside the boundaries in which they work. For example, it may not occur to scientists or engineers working on a site to look for information about onsite hazards on property deeds.

Second, future stewards may not be able to gain access to existing information in time to adequately protect human health and the environment. Current retrieval times for information obtained through FOIA requests (i. e., more than one year) will not be helpful if future site stewards uncover drums or other potential sources of contamination previously unknown to exist and need to access specific site information quickly.

Potential Consequences of a Failure to Ensure Accessibility of Stewardship Data

Future generations may not know that critical data exist. Protection of human health and the environment may be jeopardized because future generations cannot obtain critical data quickly enough. Future generations may spend unnecessary resources re-creating lost data. Future generations will be unable to re-generate some critical data. Future entities responsible for long-term stewardship may face civil and/or criminal penalties because they do not have the information needed to protect human health and the environment.

Third, future generations may incur excessive costs to obtain or re-create needed information. Unplanned costs of this nature may put pressure on site budgets, perhaps leading to delays or other negative impacts to site activities.

Fourth, future generations will be unable to re-create stewardship information even if records are accessible because sufficient contextual information such as metadata is not preserved. To the extent this becomes relatively commonplace, users may even stop attempting to retrieve archived information because the costs to obtain such information may exceed the benefits from retrieving the data.

Finally, future entities responsible for long-term stewardship may be subject to civil and/ or criminal penalties because they do not have enough information to adequately maintain institutional controls. They also may have to pay damages for the restoration of natural resources because they do not have enough information to prevent injury to those resources.

GAPS AND RESULTING CONSEQUENCES

4.4 Summary

The analysis of current requirements and practices has identified a series of gaps and issues associated with generation, preservation, and future access to stewardship data, illustrated and supported by a variety of observations across the DOE complex. Some of these appear to result from recent changes in DOE's mission and from efforts initiated to gain cost control and improve performance on work directly related to site cleanup. Others appear to result from the fact that current requirements and practices were developed to support missions other than long-term stewardship. These gaps and issues are summarized by information type in Table 4-1.

Current requirements and practices appear to result in the generation of most types of stewardship data. Generation of stewardship data is required under various laws and regulations that appear to apply broadly across the 12 types of stewardship data identified in Chapter 2. However, these requirements may not apply to the generation of stewardship data after site closure or transfer if long-term stewardship activities are conducted by entities that are not agencies of the federal government. Although generation of additional data is not needed for stewardship purposes, few requirements and practices directly address the issue of identifying stewardship data. Therefore, it is likely that data preservation efforts will not be focused on retaining information with high stewardship value.

Under current requirements and practices, preservation of stewardship data is uneven and the focus is primarily on physical retention of information records. Some types of stewardship information are required to be preserved permanently; others are required to be preserved for the near future (up to 80 years); others are required to be destroyed even before long-term stewardship begins. The lack of stewardship information already has resulted in increased costs at some DOE sites, both during and after cleanup. Stewardship information is preserved in a number of different places (including the National Archives) and via several different mechanisms. Most records are packaged and sent to interim or permanent repositories. Some records are maintained through deed restrictions and other legal processes. Others are maintained by EPA, NRC and other regulatory agencies. Current requirements and practices do not appear to address the preservation of contextual information very well. Federal metadata standards apply to some types of electronic records, but no federal indexing standards, or other mechanisms to provide pointers to information, appear to exist.

Accessibility appears to be a major issue associated with stewardship data. Under current requirements and practices, access to archived information is provided primarily by request. Users submit a request for information either directly to NARA or to DOE through a FOIA request and must wait for records to be sent to them. It may take more than a year to obtain pertinent records. Because information is preserved in a number of places and in a variety of ways, it is difficult for users to know where to look for all pertinent information. The lack of adequate indexes, metadata standards, and other pointers makes it difficult for users to find information, even if they know where to look for it. The lack of sufficient contextual information may make it difficult or impossible to use any information that is retrieved.

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Information Type	Generation	Preservation	Accessibility
A. Existing Hazards	Most, if not all, stewardship data appear to be generated based on current requirements.	Post-closure notices for hazardous waste units at interim status facilities must be recorded on deed to facility property indefinitely. Regulatory requirements for preservation of other data are limited (e.g., RCRA records preserved for 30 years after unit/site closure). Preservation based on DOE records retention schedules is required for some types of data for 5 to 80 years (e.g., environmental contamination measurement records, radioactive waste disposal records). Records preserved permanently are limited (e.g., general procedures; data gathered to measure residual contamination; some records pertaining to radioactive waste disposal or unplanned disposition). Some data are preserved in NEPA documents and/ or environmental baseline surveys developed at time of site closure.	Transfer of some information to future stewards is via NEPA documents and/ or environmental baseline surveys and conveyance of property transfer. For data that are preserved, access is available via FOIA and requests to NARA. Some information must be available to the public directly (e.g., EPCRA inventory forms). Post-closure notices for hazardous waste units at interim status facilities can be found on property deeds. Some records are transferred to local and/or state entities as appropriate (e.g., licenses for land disposal of radioactive waste is transferred after license is terminated). Records regarding radioactive waste geologic repositories must be preserved for useability by future generations.
B. Past/Present Releases	Most, if not all, stewardship data appear to be generated based on current requirements.	Preservation based on regulatory requirements is limited (e.g., some records preserved until NRC license terminated). Preservation based on DOE records retention schedules is required for most types of data up to 75 years. Records preserved permanently are limited (e.g., standards, operating guides, procedures; data gathered to measure residual contamination; unplanned disposition records of radioactivity; and records of radioactive waste discharges). Some data are preserved in NEPA documents and/ or environmental baseline surveys developed at time of site closure.	Transfer of some information to future stewards is via NEPA documents and/ or environmental baseline surveys and conveyance of property transfer. For data that are preserved, access is available via FOIA and requests to NARA.
C. Disposition of Historical Hazards	Most, if not all, stewardship data appear to be generated based on current requirements. Generation of stewardship data in the past may have been limited.	Some data preserved in RCRA TSDF Closure Plans and CERCLA RODs. Preservation of some data may be required for up to 50 years (e.g., released substances). Remaining regulatory requirements regarding the preservation of records is limited (e.g., one year). Preservation based on DOE records retention schedules is required for some types of data for up to 5 years (e.g., environmental contamination measurement records; radioactive waste disposal records) or more	Transfer of some information to future stewards is via NEPA documents and/ or environmental baseline surveys and conveyance of property transfer. For data that are preserved, access is available via FOIA and requests to NARA. Some data (e.g., RCRA TSDF Closure Plans and CERCLA RODs) may be accessed via EPA. Also, notification of RCRA Closure Plan must be placed on the deed for the property indefinitely.

GAPS AND RESULTING CONSEQUENCES

Information Type	Generation	Preservation	Accessibility
C. Disposition of Historical Hazards (continued)		(e.g., hazardous material transportation records are retained longer if renewed use is anticipated). Some records are preserved permanently (e.g., general procedures regarding environmental contamination measurement records, data gathered to measure residual contamination; and some records pertaining to radioactive waste disposal or unplanned disposition). Some data are preserved in NEPA documents and/ or environmental baseline surveys developed at time of site closure.
D. Existing Barriers and Other Mechanisms	Some stewardship data appear to be generated.	Preservation based on DOE records retention schedules is required for limited types of data, such as safety management records, which are preserved up to 80 years. Some data may be preserved in RCRA TSDF Closure Plans and CERCLA RODs. Some data are preserved in NEPA documents and/ or environmental baseline surveys developed at time of site closure.	Transfer of some information to future stewards is via communications with future steward at time of property transfer. For data that are preserved, access is available via FOIA and requests to NARA. Some data (e.g., RCRA TSDF Closure Plans and CERCLA RODs) may be accessed via EPA. Also, notification of RCRA Closure Plan must be placed on the deed for the property indefinitely.
E. Process History	Most, stewardship data appear to be generated based on current requirements. Generation of stewardship data in the past may have been limited.	Preservation based on regulatory requirements is limited (e.g., five years). Preservation based on DOE records retention schedules is required for some types of data for 5-20 years (e.g., project planning and design records). Only limited records are retained permanently (e.g., records selected for their architectural, historical, and technological significance).	Transfer of some information to future stewards is via conveyance of property transfer, including terms, conditions, and restrictions on the property. For data that are preserved, access is available via FOIA and requests to NARA.
F. Historical Infrastructure	Some stewardship data currently appear to be generated. Generation/ preservation of past data may have been limited.	Preservation based on DOE records retention schedules is required for some types of data, such as planning and design records to be preserved through project completion or five to 20 years afterwards. Only limited records, such as records selected for their architectural, historical, and technological significance, are maintained permanently.	Transfer of some information to future stewards is via NEPA documents and/ or environmental baseline surveys and conveyance of property transfer. For data that are preserved, access is available via FOIA and requests to NARA.
G. Post-Closure/ Transfer Operations and Infrastructure	Generation of stewardship data is unclear; some may be required if permits or licenses are transferred to new stewards.	Preservation of closure requirements does not appear to be addressed by current requirements, except for information preserved in the transfer of permits and/ or licenses to the new owner or operator.	Access to data unclear since future stewards may not be DOE and different access requirements may apply. If DOE is future steward, information may be accessed via FOIA and requests to NARA (for data that are retained).

CHAPTER 4

Information Type	Generation	Preservation	Accessibility
H. Regulatory Framework (Historical and Present)	Some stewardship data appear to be generated.	Information regarding permits (e.g., CAA, NPDES, UIC, and RCRA) must be maintained while permits are active. Information regarding standards, operating guides, and procedures for some data (e.g., radiation-contamination control program records, environmental contamination measurement records) are preserved permanently based on DOE records retention schedules. Preservation for other data is required for up to 5 years or more (e.g., hazardous material transportation records are retained longer if renewed use is anticipated).	Information regarding active permits to future stewards is transferred to future stewards in agreements. For data that are preserved, access is available via FOIA and requests to NARA.
I. Requirements Specific to Site Transfer/ Closure	Some stewardship data appear to be generated as property is closed and transferred. All data generated will be difficult to determine until all closure requirements are identified.	Preservation of closure requirements does not appear to be addressed, except for information preserved in the transfer of permits and/ or licenses to the new owner or operator. Data may be contained in NEPA documents and/ or environmental baseline surveys at closure.	Transfer of some information to future stewards is via NEPA documents and/ or environmental baseline surveys and conveyance of property transfer. For data that are preserved, access is available via FOIA and requests to NARA.
J. Real Estate Records	Most, if not all, stewardship data appear to be generated based on current requirements.	Prior to closure, real estate records are preserved onsite. Unclear how preserved after closure.	Transfer of some information to future stewards is via NEPA documents and/ or environmental baseline surveys and conveyance of property transfer. For data that are preserved, access is available via FOIA and requests to NARA.
K. Cultural and Natural Resources	Most, if not all, stewardship data appear to be generated based on current requirements.	Preservation of information does not appear to be addressed in DOE records retention schedules. Preservation may be addressed by the National Historic Preservation Act and the Archeological Resources Protection Act. Some data are preserved in NEPA documents and/ or environmental baseline surveys developed at time of site closure.	Transfer of some information to future stewards is via conveyance of property transfer. For data that are preserved, access is available via FOIA and requests to NARA.
L. Geophysical/political	Some stewardship data appear to be generated.	Preservation of information appears to be somewhat limited. Information regarding standards, operating guides, and procedures for some data (e.g., radiation-contamination control program records, environmental contamination measurement records) are preserved permanently, according to DOE records retention schedules.	Transfer of some information to future stewards is via conveyance of property transfer. For data that are preserved, access is available via FOIA and requests to NARA.