Peggy J. Warner
Records Manager
Nuclear Waste
Management Programs Center
Sandia National Laboratories
ABSRACT
The International Atomic Energy Agency (IAEA) has conducted consultant and advisory meetings to prepare a Technical Document which is intended to provide guidance to all IAEA Member States (otherwise known as countries) that are currently planning, designing, constructing or operating a deep or near surface geological repository for the storage and protection of vitrified high-level radioactive waste, spent fuel waste and TRU-waste (transuranic). Eleven countries of the international community are presently in various stages of siting, designing, or constructing deep geologic repositories. Member States of the IAEA have determined that the principle safety of such completed and operation sites must not rely solely on long term institutional arrangements for the retention of information. It is believed that repository siting, design, operation and postoperation information should be gathered, managed and retained in a manner that will provide information to future societies over a very long period of time. The radionuclide life is 10,000 years thus the retention of information must outlive current societies, languages, and be continually migrated to new technology to assure retrieval.
This presentation will provide an overview of the status of consideration and implementation of these issues within the United States efforts relative to deep geologic repository projects.
PRESENTATION
The international scientific community has long had an interest in determining methods by which information regarding nuclear waste repositories could be passed from generation to generation and society to society. Because nuclear waste will remain radioactive for thousands of years future generations must be warned of the inherent danger to humanity thus eliminating intentional or inadvertent intrusion. Some of these issues have been addressed in the United States within studies relative to the establishment of Passive Institutional Controls (PICs) on the Waste Isolation Pilot Plant (WIPP) project to meet the requirements established in the Code of Federal Regulations 40 CFR Part 191 and those of 40 CFR Part 194 Section 194.43 specifically. Member States of the IAEA have determined that the principle safety of such sites must not rely solely on long term institutional arrangements for the retention of information. It is believed that repository siting, design, operation and postoperation information should be identified, gathered, managed and retained so that this information remains accessible to future societies. The radionuclide life is 10,000 years or longer; thus the retention of information continues beyond current societies, cultures and languages, and must be continually migrated to new retrieval technologies to assure access.
The International Atomic Energy Agency (IAEA), as a result of this international interest, has conducted consultant and advisory meetings to prepare Technical Documents which are intended to provide guidance to all IAEA Member States (countries) that are currently planning, designing, constructing or operating a deep or near surface geological repository for the storage and protection of vitrified high-level radioactive waste, spent fuel waste and TRU-waste (transuranic).
The United States, and particularly the Department of Energy (DOE) as a federal agency, is a recognized leader in the siting, design, and recordkeeping of deep geologic repository projects. The experience available within the scientific community and the records management expertise of the DOE is presently and will continue to be an essential resource to Member States of the IAEA. The United States has developed this technical and records management expertise as a result of the high rigor requirements from the Nuclear Regulatory Commission (NRC) and the Environmental Protection Agency (EPA) to name two regulatory bodies. Thus the United States repository programs require and have established rigorous documentation and record keeping practices.
In an attempt to assure that all repository designing Member States were planning for and implementing processes to create, collect, manage and retain pertinent repository information, the IAEA embarked upon the development of two Technical Documents. One document deals with and is titled "Maintenance of Records and Documents for Near Surface Waste Disposal Facilities" while the second document is titled "The Maintenance of Records and Documents for Deep Geological Repositories". In October of 1994 the first Consultants Meeting was called for the writing of the deep geological repository paper. Nominated to serve on this committee were representatives of the United States of America, Germany, France and Sweden. The result of a five day meeting was a preliminary draft document.
The next level of IAEA consulting group, an Advisory Group, was called together for a five day working session in December of 1995. Eleven countries were represented and they included: Belgium, Canada, Czech Republic, France, Germany, Japan, Russia, Republic of Korea (South), Russia, Sweden, the United Kingdom and the United States of America. I had the pleasure of being nominated to represent the United States and specifically the Department of Energy (DOE). Additionally, at the request of the IAEA, I was honored to Chair the Advisory Group. The final meeting, a four day Consultants Meeting, was held in May of this year to assure that all Member State review comments were adequately considered and to finalize the Technical Document.
Three primary points were addressed by the IAEA Consultants Meetings and the Advisory Group. These points will be discussed in the presentation.
I will discuss these points and the possible records management impacts within the United States for the Department of Energy (DOE), the National Archives and Records Administration (NARA), and possibly the Department of Defense (DoD).
BACKGROUND
As initially stated, the scientific community has been studying passive institutional control methods to protect the safety of humanity and thus to preclude the inadvertent access into a geological repository. The following excerpts from two published reports provide examples of scientific community concerns.
The themes identified in this first document are those that the IAEA established for the writing of two guidance documents which in the terms of the IAEA are Technical Documents. The two primary themes are that one, information must be retained for the use of future societies and two, that an archival system is the best method of preservation. The following excerpt from a second publication emphasizes the need for a system of record keeping.
Eleven countries of the international community are presently in various stages of siting, designing, or constructing deep geologic repositories. Member States of the IAEA have determined that the principle safety of such completed and operational sites must not rely solely on long term institutional arrangements for the retention of information. It is believed that repository siting, design, operation and postoperation information should be gathered, managed and retained in a manner that will provide information to future societies over a very long period of time.
As noted in both of the afore mentioned studies, the need to collect and retain for a very long time a specific body of information is a common theme. Each country may have a different method of conducting their licensing process thus their body of information may not be as great as other countries. For instance the licensing process in the United States, as identified in the Nuclear Waste Policy Act of 1982, established a three-year process which included eighteen months for litigation. Additionally a large number of parties are involved in the United States licensing process: (to name a few) Nuclear Regulatory Commission (NRC), Indian Tribes, States and Counties, Department of Energy (DOE), and the Environmental Protection agency (EPA).
By contrast the German government has issued a single contract to one contractor for the planning, erection and operation of the repositories for the Morsleben repository (license until 2000), for the planned Konrad repository (waiting for the license for construction) and for Gorleben mine (which has to be constructed and researched to find out if it is suitable for high radioactive waste). Everything which has to do with the license is in the hands of the German government.
As you can see a much larger volume of records will be required to support the licensing and litigation process in the United States.
HIERARCHY OF INFORMATION
The first IAEA Consultants utilized the principles of a hierarchy of information to be prepared, collected and managed within a records management system which concluded with final protection for future societies in an archive facility. These principles can be drawn directly from the various scientific publications created in the United States and internationally ( see examples in Appendix C).
The final draft of the deep geological repository Technical Document depicts this hierarchy as containing three levels of information. The Primary Level Information, which is continuously developed during the lifetime of the repository program, depends on the repository system selected, national laws and regulations, and the need for public involvement. Therefore it is expected that relevant information will include siting, construction, operation and closure.
The middle level of the hierarchy is the Intermediate Level Information consisting of condensed information to ensure understanding of the repository system. These records support legislatory and licensing requirements throughout the repository lifecycle. There may be references to specific bodies of information which reside in the Primary Information Level (PLI) as well as the location of the PLI.
The top level of greater condensed information is the High Level Information. This level provides sufficient information to provide a fundamental understanding of the repository system to meet the needs of future societies. This level also contains the required records for IAEA Safeguards (associated with the "Treaty on the Non-Proliferation of Nuclear Weapons"). Appendices A and B identify specific records recommended for placement into the HLI. The HLI body of information should be placed into a national and/or international archive for very long term protection.
You will note that many studies deal with possible methods to assure the preservation of a body of information about the repositories to ensure safety of future societies. The placement of the HLI information into archival protection is a measure to add confidence that information will be preserved even as political, social, and economic changes occur in Member States. Placement of this information into the Member State archive and an international archive creates added protection through duplication (further discussion regarding archival needs follows).
It is of interest to note that the United States has identified a body of knowledge needed for licensing/permitting however a national effort has not been initiated to determine the body of information and specific supporting records which will be needed throughout the very long life of the repository.
Through discussions and communications about Passive Institutional Control studies and the efforts relative to the IAEA Technical Document preparation a larger circle of awareness is being discovered. The emphasis now must be on the development of a strategy to tap into expertise from the scientific, engineering, records management and archivist communities to collectively establish a workable policy for the United States. This policy may ultimately be found to be a guideline for the world nuclear community.
RECORDS MANAGEMENT SYSTEM
The second area of IAEA concern is that in order to capture this body of information which is to be placed into the High Level Information (HLI) a Member State system of record keeping must be planned and implemented at the earliest possible stage of repository design.
This system may be comprised of several actual organizations or groups of records. The 1995 IAEA Advisory Group was in consensus that the value of and societal need for these records was high enough to warrant the identification and collection during all phases of design, development and operation, and preservation over the 10,000 year period.
It was interesting to observe that all Advisory Group participants and Consultants had a clear understanding that records were important and that a system of keeping them was necessary, however, I was the only Records Manager nominated to serve on these committees. Most other participants were either Project Managers or Quality Assurance Managers. Thus the immense record collection and management requirements of a life cycle records management program was not clearly understood. It was also not clearly understood that a Records Management System within a country like the United States may need to collect and manage records for the High Level Information set from more than one federal agency (e.g. Department of Energy and the Environmental Protection Agency) and possibly state and local governmental organizations..
To my knowledge, no discussions have been held across agency or organizational lines to establish a national records management system which will identify, collect, manage and maintain this large body of information as a living body of knowledge within the United States. Discussions must be held between all parties that will be a) providing waste, b) transporting waste, c) managing repository/storage facilities, d) siting/assessing/building repositories e) regulating/legislating repository activities, etc to establish a single records management system. No such activity or system has been designed. I believe that it is imperative for the United States to establish a high level commission which has two primary goals:
MEMBER STATES ARCHIVE AND AN INTERNATIONAL ARCHIVE
Archival retention and protection of records of the Member States was addressed. A great concern exists that Member State records may be vandalized during civil unrest or war, or present day countries may not exist in the future (as we have witnessed during the end of the cold war). The retention of a body of information which can be communicated to future generations is a basic need of any deep geological repository program. The design of such an information system must be predicated on the concept that technology as we know it today will surely not be the same 10,000 years from now. Yet, the conveyance of the High Level Information as discussed in the Hierarchy is of utmost importance to each Member State.
The consensus was that additionally an International Archive be established to which a second copy of the Member States High Level Information (HLI) would be submitted for long term retention to guard against war, natural disaster and loss of societies. Discussion was held regarding the possible location of the international archive at the IAEA as a neutral location and because Member States already submit Safeguards report documents to the IAEA. It was recommended to the IAEA that a study of the feasibility to establishment an International Archive may be appropriate.
Studies have been conducted throughout the world regarding the need for archival storage. Mikael Jensens publication "Conservation and Retrieval of Information" specifically addresses various archival issues. Specific topical areas include: archives vs markers, archival media and various international archives. The Nordic Study, as it is referred to, studies previous archival resistance to war, cultural and societal changes, and natural disasters. Some of the historically surviving archival references are the German Archive, the Vatican Archive with a more recent reference to the present Mormon Archive which is located in the United States but does not have the history of longevity of the other two.
In the United States it is uncertain whether the National Archives and Records Administration (NARA) would act as the archive for the USA High Level Information sets for the various geologic repositories as it is presently not a specific activity within the mission of the archive. This is a specific area of communication and agreement which is needed between the Department of Energy (DOE), the Nuclear Regulatory Commission (NRC), the Environmental Protection Agency (EPA), and others with NARA until Congress changes the mission of NARA. The Passive Institutional Controls discusses establishment of archives of information at numerous locations around the United States and the offering of a set of information to various countries.
CONCLUSIONS
The areas outlined below should be addressed within the Department of Energy, and in concert with any other regulatory organizations or governmental agencies involved with the deep geologic repositories, to assure that the United States properly reviews the IAEA guidance and establishes appropriate methods to implement record keeping and archival practices which will assure the identification and very long term retention of High Level Information.
APPENDIX A-IAEA DRAFT TECHNICAL DOCUMENT "IDENTIFICATION OF POTENTIAL RECORDS FOR THE HIGH INFORMATION LEVEL"
Information, including Safeguards requirements ( Appendix B), should not be more detailed than that provided to the licensing authority. The HLI information to be collected and retained in the Member States archive and an international archive should cover the following subjects:
Description of the Records Management System (RMS)
Cross Referencing to the Llocation of the Original Records
Site Description, Including Descriptions and Maps
System Description
System Performance
NOTE: Post closure phase: The IAEA and the State should retain all safeguards relevant documentation and information (i.e. records of the complete inventory of nuclear material and/or previous operations of the repository) deem necessary. These records should be kept for at least as long as Safeguards exist for the nuclear material in the repository.
APPENDIX B-IAEA SAFEGUARDS DOCUMENTATION REQUIREMENTS
The following information is excerpted from a presentation given by Mr. Abdul Fattah, IAEA Safeguards, at the IAEA Advisory Group meeting in Vienna, Austria on December 19, 1995.
Safeguards are applied by the IAEA to assure non diversion of nuclear material from peaceful activity. For materials to be disposed in geological repositories these include spent fuel and waste material containing nuclear material, as these will not qualify for termination of safeguards even after the closure of the repositories. The basic safeguards approach for the repository will be a combination of design information verification (DIV) and application containment of surveillance (c/s).
Design Information Verification (DIV) is an important safeguards measure to be applied during excavation and continuing during the operational phase. It should confirm the integrity of the repository area and aim at detecting undeclared activities such as the presence of sensitive equipment or tunneling in the neighborhood. As the repository design will change during excavation, for example to adapt to geological findings, the application of DIV must be a flexible, ongoing process.
DIV should be an ongoing activity. The design information of the underground facility should include maps and information about all excavations. The IAEA should verify that the excavation areas are as declared and that there are no undeclared excavations. The IAEA should also provide assurance of the absence of undeclared underground reprocessing, and an assurance of no undeclared operational capability underground which could facilitate substitution between containers.
Design Information
Nuclear Material Accountancy
Records System
Accounting Records
Operating Records
Reports System
Pre-operational Phase I
Pre-operational Phase II
Operaatonal Phase
Post Closure Phase
APPENDIX C-BIBLIOGRAPHIC LISTING OF REFERENCE AND READING MATERIALS
RIDGWAY, W.R., R.B. COOPER, and R. FUNG, "A System for the Storage and Management of Research and Development Records", ARMA QUARTERLY, October 1990, pages 34-39
KAPLAN , MAUREEN F., "Archeological Data as a Basis for Repository Marker Design", ONWI-354 Battelle , October 1992
WEITZBERG, ABRAHAM, "Building on Existing Institutions to Perpetuate Knowledge of Waste Repositories", August 1982, NUS Corporation, ONWI-379
JENSEN, MIKAEL, "Conservation and Retrieval of Information - Elements of a Strategy to Inform Future societies about Nuclear Waste Repositories" August 1993, Final Report of the Nordic Nuclear Safety Research Project KAN-1.3
"Defense Dept., NASA Aid Voyager Communications", Aviation Week & Space Technology, January 5, 1987, pages 26 and 27
TRAUTH, KATHLEEN M., STEPHEN C. HORA, ROBERT V. GUZOWSKI. Printed November 1993. "Expert Judgement on Markers to Deter Inadvertent Human Intrusion into the Waste Isolation Pilot Plant", SAND92-1382
PASZTOR SUZANNE B., and STEPHEN C. HORA. July 1994, "Lessons from the Vatican Archives for Repository Recordkeeping", RADWASTE Magazine,, pages 39-47
"Messages Out", SPACE WORLD, January 1986, pages 16-20
Committee on Preservation of Historical Records, National Materials Advisory Board, Commission on Engineering and Technical Systems, and the National Research Council . 1986. "Preservation of Historical Records", National Academy Press
Nuclear Energy Agency (NEA). A Collective Opinion of the NEA Radioactive Waste Management Committee. 1995. "The Environmental and Ethical Basis of Geological Disposal"
IAEA. "The Structure and Content of Agreements Between The Agency and States Required in Connection with the Treaty on the Non-Proliferation of Nuclear Weapons"
TOLAN, TERRY L. Printed June 1993. "The Use of Protective Barriers to Deter Inadvertent Human Intrusion Into a Mined Geologic Facility for the Disposal of Radioactive Waste: A Review of Previous Investigations and Potential Concepts", SAND91-7097.