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6.0 RECOMMENDATIONS

The transition from a mission focused on cleanup to one focused on long-term stewardship at DOE sites has begun. During this transition process, contracting processes are changing, workforces are being reduced, and responsibilities are being redefined. As sites contend with the changes and uncertainties associated with this transition, it is important not to lose sight of the fact that hazards will remain at these sites and specific information will be required to protect human health and the environment from these hazards, both now and hundreds of years from now.

As noted in the preceding chapters, the requirements for identifying, preserving, and providing access to data relevant to stewardship are not comprehensive and should be evaluated carefully to determine how the gaps can best be filled. Further, better mechanisms are needed for carrying out existing and future requirements, particularly as DOE sites complete their cleanup and are transferred to other owners.

This chapter provides specific recommendations for DOE and sites to begin addressing stewardship data needs. Where appropriate, similar recommendations from DOE's Openness Advisory Panel and Records Management Quality Improvement Team are called out.

As sites reconfigure or are closed altogether, the problems of locating, transferring, and protecting records loom large. Efforts to speed up declassification and to make records relating to the environment and to worker and community health available to the public require an in-depth knowledge of the records in DOE custody that can only come through a vital and well-supported records management program. Roadmap to the Year 2000, U. S. Department of Energy Records Management Quality Improvement Team, Revision 1, August 1995

Section 6.1 presents several general recommendations. Sections 6.2, 6.3, and 6.4 present recommendations specific to data generation, preservation, and accessibility, respectively. Section 6.5 provides recommendations regarding the establishment of a stewardship data entity within DOE.

6.1 General Recommendations

When the cleanup mission comes to an end, responsibility for DOE sites may be transferred to entities other than EM and, in some cases, other than DOE. These entities, and the people who live and work in the surrounding communities, will need sufficient information about the sites to ensure the continued protection of human health and the environment. Some of this critical information has been lost, and more is being lost every day. DOE needs to begin planning for the eventual transfer of this information now, to prevent it from being lost. DOE also needs to begin identifying who will need this information, what

Work with the Records Management Division, DOE's records management officers, the Office of Procurement, Assistance, and Program Management, and the Office of General Counsel to develop and distribute contract language that clearly addresses information ownership and management requirements in all DOE contracts. …[I]t is important to exchange concepts, approaches, and success in implementing the recordkeeping requirements regulations with other agencies. Roadmap to the Year 2000 Openness should be established as a core value of the Department through incorporation in performance reviews, program plans, and contracting activities. Responsible Openness: An Imperative for the Department of Energy, Openness Advisory Panel, Secretary of Energy Advisory Board, August 25, 1997 (Recommendations 5,33)

RECOMMENDATIONS

specific data will be needed, and how the appropriate information will be preserved. The following specific actions are recommended to achieve these objectives:

1. Sites should evaluate the potential gaps in current information management requirements and practices as they pertain to stewardship data and develop and implement strategies for addressing these gaps.

2. DOE should train site personnel to identify stewardship data and ensure their preservation.

3. DOE should provide for adequate funding to ensure sites can identify and preserve stewardship data. The potential return on investment through accelerated site closure and avoided future costs could well justify any additional costs associated with stewardship data efforts.

4. DOE should identify appropriate entities that would manage or use stewardship data, identify their roles and responsibilities with regard to these data, and actively coordinate stewardship data efforts with each entity.

5. DOE should establish a core value to provide for stewardship data needs and incorporate this value into performance reviews, program plans, and contracting activities.

6.2 Recommendations for Data Generation

A large amount of information was generated at DOE sites during the nuclear weapons production era and continues to be generated during cleanup. The challenge facing DOE as sites transition to long-term stewardship is to develop a systematic approach for determining how to distinguish stewardship data from the universe of available information.

A successful records management program begins with having good information management practices at the creation of the information and using those practices throughout the life-cycle of the information. This is critical because the manner in which the records are created and information collected impacts upon their (its) maintenance, use, and disposition. Roadmap to the Year 2000

This determination is necessary to ensure that any new information management procedures are directed only to that information necessary to protect human health and the environment now and into the future. The following specific actions are recommended to achieve these objectives:

1. DOE should develop a consensus on stewardship data needs and the types of information that are required to meet these needs. This report provides a starting point for identifying stewardship data needs, the information that can support these needs, and criteria for identifying the stewardship value of specific information. A broader effort involving DOE Headquarters, sites, stakeholders, and potential stewardship entities is required to define adequately the subset of information that will be critical for stewardship.

2. DOE should develop guidance for establishing a clear stewardship baseline at site closure. The guidance should define baseline data needs and provide data quality objectives for fulfilling those needs. The baseline should be sufficient to understand fully the location, condition, and status of all former and residual hazards remaining on the site at the time of site closure or transfer and the history of site activities as they pertain to these hazards. Such a baseline would represent the core information required for long-term stewardship.

3. DOE should establish a process for assessing the stewardship value of data to which access is currently restricted (e.g., classified or litigation-sensitive records) so that relevant portions of these can be merged with other stewardship data when such restrictions no longer apply.

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6.3 Recommendations for Data Preservation

Given the absence of clear criteria and guidance for identifying stewardship data, some information critical to the long-term ability to protect human health and the environment has been and is being lost. As sites continue the transition from cleanup to long-term stewardship, it is important to implement procedures to minimize additional data losses. An important first step would be to evaluate the stewardship value of all records being created currently and ensure that those with stewardship value are adequately preserved. This would entail recording critical contextual information (e.g., metadata) in terms that people are

Establish and implement standards and procedures for subject classifying, indexing, and filing of records for all media. Roadmap to the Year 2000 DOE's contractors should be obliged to support declassification, records maintenance, and accessibility activities that further DOE's openness initiatives. All new contracts should contain explicit language covering these obligations and existing contracts should be amended to the extent feasible. Responsible Openness: An Imperative for the Department of Energy (Recommendation 35) DOE should undertake several initiatives in the area of developing "finding aids:" 1. Compile a centralized directory of all currently available "finding aids" for its records. 2. Continue efforts to make finding aids available to the public by placing them on OpenNet and expanding beyond (current) health and safety topics. 3. Develop a uniform format and content standard for new finding aids. 4. Experiment with preparation of finding aids for important topical areas. 5. Use the ongoing Large-Scale Review to develop finding aids to both declassified and still-classified documents. Responsible Openness: An Imperative for the Department of Energy (Recommendations 24-28)

likely to understand in the future, and expediting the transfer of stewardship data to appropriate information stewards, while sites are in the cleanup phase. Once procedures are in place to identify and preserve stewardship data generated between now and when the site transitions to long-term stewardship, more attention can be focused on reviewing information generated in the past. The following specific actions are recommended to achieve these objectives:

1. Sites should focus on identifying and preserving stewardship data from the present and into the future. DOE can avoid many of the potential costs and delays associated with having to re-create necessary data at site closure or transfer by highlighting the potential problem and developing guidance to assist sites in identifying and preserving all stewardship data that will be generated in the future.

2. With regard to present and past records, sites should focus initially on identification and preservation of stewardship data that exist among active records because the marginal cost of their preservation should be relatively low. Active records are more likely to be used on a regular basis and hence readily available. The individuals who know the most about these records are likely to be still involved in their maintenance and would be important players in determining their stewardship value. Metadata and other contextual information for active records should be readily available or could be developed with relatively little effort.

3. Inactive records generally should be a relatively low priority because of the high cost associated with their identification, retrieval, and re-generation. A reasonable approach for evaluating these records would be to preserve them on an as-needed basis. If there were a reason to investigate some inactive records unrelated to long-term stewardship needs, or to meet a specific need such as establishing a site baseline, it would make sense to simultaneously determine whether they had stewardship value.

4. Sites should transfer stewardship information to an offsite stewardship entity(ies) as rapidly as possible. The benefits of a rapid transfer of information include reducing site overheads,

RECOMMENDATIONS

ensuring that adequate baselines are established, and ensuring that data transfer protocols are established early in the process.

5. DOE should evaluate current information management requirements at sites to ensure that stewardship data are preserved in a manner that will allow future users to access these data in a timely manner. DOE should develop specific metadata and indexing standards for stewardship data (including adequate geospatial referencing). These metadata and indexing standards should be applied at the time the data are captured to ensure the information is complete, accurate, and consistent. DOE also should ensure that stewardship information is adequately stored and transferred when information management responsibility shifts from one contractor to another. This should include clear guidelines that assign responsibility for updating stewardship data (e.g., ensuring metadata are current).

6. DOE should re-evaluate its records retention schedule to ensure that stewardship data are preserved permanently.

6.4 Recommendations for Future Access

Ensuring adequate preservation of stewardship data is necessary but not completely sufficient; ensuring timely access to this information also requires serious consideration. Given the variety of locations where information about DOE sites is archived today, there currently is no single starting point where someone can begin a search for information required to meet stewardship requirements. Also, there are no indexing or metadata standards for stewardship data. As a result, there is no

The bulk of documents under DOE's control are unclassified, but many are effectively unavailable because of poor document management. The Department must improve its document control systems and its methods of information dissemination. DOE should seek to enhance efficiency through the use of technology: 1. Modern computer capability should be harnessed to assist in the classification process for future documents. 2. Test the effectiveness of electronic document management systems. 3. DOE should seek proposals from the laboratories and the private sector for a document management system tailored to the Department's needs, and fund one or more pilot tests. 4. Pursue the use of artificial intelligence to assist in declassification reviews. Responsible Openness: An Imperative for the Department of Energy (Recommendations 20, 29-31)

common or consistent reference system for describing the types of stewardship data that are available. It is important to begin to develop a systematic approach for managing and providing access to stewardship data now, while sites are transitioning from cleanup to long-term stewardship. The following specific actions are recommended to achieve these objectives:

1. DOE should archive information in a user-friendly way. This means that a person without an intimate knowledge of the site or the technical terminology used during weapons production and site cleanup can understand how to search for and find the necessary information. Employing common terminology will increase the utility of stewardship data for the long-term.

2. DOE should begin developing an electronic reference system for stewardship data records. Its primary function would be to allow users to: (1) identify records that are available for a given geographical location, subject matter, or stewardship activity; (2) understand the content, quality, condition, and other contextual characteristics of each record; (3) locate and retrieve any records of interest. Descriptive information (e.g., indexes and metadata) must clearly delineate the type of medium in which data are preserved (e.g., report, journal article, letter, data file); where the record falls within the information taxonomy (e.g., original data, summary of data, analysis of data, transmittal of data); and how to access the record (e.g., electronically or by paper request). Full-text keyword searching of the information is also a likely requirement for any electronic reference or retrieval system.

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3. DOE should develop a conceptual design for a system to manage and provide access to stewardship data. This report provides a starting point for such a system, but a broader effort involving DOE Headquarters, sites, stakeholders, and potential stewardship entities will be required to adequately understand the requirements for such a system.

6.5 Recommendations for Establishing a New Stewardship Data Entity

Establish a DOE National Records Center that would store the majority of inactive DOE records. Roadmap to the Year 2000

Even if all necessary requirements for identifying, preserving, and providing access to stewardship data are put in place and followed, an institutional structure focused on data management is needed. Thus, a final recommendation of the project team is that a new stewardship data entity be established for the entire Department. The new entity would cut across, but be independent of, offices with existing programmatic missions. The new entity would perform and integrate stewardship data functions and encompass the following elements:

• As sites go through closure, ensure that information needed for stewardship is retained in a manner that makes it readily accessible to future stewards.

• Maintain an information repository with electronic control over all stewardship data.

• After closure, ensure that all data generated by stewardship activities (e.g., long-term monitoring data) are integrated with the baseline.

• Ensure that all information is distributed to those who need it.

• Ensure that over time the system remains current and compatible with new technology.

• Solicit and integrate recommendations from other agencies, such as the National Archives and Records Administration.

The entity would have electronic control of all stewardship information, maintain electronic records where appropriate, and develop electronic indexes to information. It would deal with other sites, probably through the site chief information officers, and have oversight of the stewardship data identification and preservation process at the sites. Some of its representatives could be detailed to various sites for periods of time to be sure that stewardship data are retained and go to the appropriate location after the site performs initial data review and indexing. This entity would perform a quality analysis before putting the data into the system to ensure that only data with stewardship value are retained.

There are many different ways of setting up the new entity. One logical approach would be to locate the new entity in a center of excellence at a field site with a well-defined, long-term mission. This center would report to the Undersecretary, possibly within the office of the DOE Chief Information Officer. Making the entity independent of current programs would help its focus on long-term stewardship data remain viable.