RK&M PRESERVATION: CHALLENGES AND OPPORTUNITIES

interpretable, credible23 and meaningful. Hence the importance of dedicating attention to all three of the life cycle sub-processes, since RK&M loss can take place at all levels, as the following section illustrates.

3.2. Causes and consequences of RK&M loss

RK&M loss is real and already happening today, and not without consequences. Projects of any nature are vulnerable to risks of RK&M loss. RWM forms no exception in this regard and the long-term hazardous nature of the waste highlights the relevance of RK&M preservation in this field. To summarise, the point of departure of the RK&M initiative is that if we do not make efforts to substantiate and transfer RK&M, it will without doubt get (partly) lost, forgotten, or become inadequate for future understanding and decision making. Several case studies demonstrate this finding, as well as the fact that RK&M reconstruction is challenging from a practical, economic and safety point of view.

Insights on RK&M loss from both inside and outside the nuclear field were developed within the RK&M initiative. Two dedicated surveys were sent out to RK&M initiative members and beyond (the 2011 Survey on Examples of Memory Loss and the 2012 Survey on Costs Associated with Loss of RK&M in Decommissioning). A dedicated study was published to gain insights from RK&M loss in the area of conventional waste disposal (NEA, 2014). Specialists were invited to project meetings and workshops to present their experience on RK&M loss related to contaminated sites, cultural heritage, knowledge in general, and digital archiving. The examples focused notably on more or less recent cases, since these provide the most hands-on information, both with regard to the reasons and the consequences of RK&M loss.

Lessons from RK&M loss in the nuclear field

The 2011 Survey on Examples of Memory Loss revealed examples within the field of RWM (see S. Tunbrant in NEA, 2012: pp. 47-54). In Hungary for instance, the prolongation of an operational licence of the radioactive waste processing and storage facility required the reconstruction of the facilities and a renewed safety assessment in line with evolved state-of-the-art safety requirements. Very soon it became apparent that some information originating from earlier investigation programmes was not fit for use because of the lack of metadata, which would allow its reliability and quality to be assessed. People were unable to determine the original dataset, which data was used in the assessments and how the data was processed. This led to the necessity to redo some former sampling, measurements and data processing. The main lessons learnt are that safety is a dynamic concept and that new generations require good insight to previous approaches to be able to rely on and work with what has been done in the past. Information reconstruction is not always possible and is always costly.

In the United States, the Hanford site was established in 1943 as part of the Manhattan Project on the Columbia River, Washington. During 1945-1975, radioactive waste was buried away from the facilities. It was disposed at a place that, at the time, was considered to be “far away”, to prevent unintended intrusion. It was not marked to avoid drawing attention to its existence below its well-revegetated surface. However, the waste was discovered when excavating for other purposes. This is a case where radioactive waste itself got “lost” and regretfully, it is not the only instance worldwide where this has happened. The records were not totally lost, but were inadequate. The main lesson learnt here is that places once considered to be “far away” may become exploited when communities and industries evolve and grow. Hiding and trying to forget is not a good way to prevent inadvertent intrusion. Moreover, while RK&M preservation may seem irrelevant at one time, it may become useful or needed at later times.

23.Credible or “believable” is not per se the same as “believed” but refers to messages for instance not being a priori disregarded as outdated superstition, or incorrectly assessed with regard to its genre (scientifically based texts being read as prose, for instance) (Wikander, 2015).

RK&M PRESERVATION: CHALLENGES AND OPPORTUNITIES

In 2012 the RK&M initiative distributed a questionnaire to members of the NEA Working Party on Decommissioning and Dismantling and the NEA Co-operative Programme on Decommissioning related to consequences and costs associated with the loss of RK&M in decommissioning (see I. Rehak in NEA, 2013: pp. 101-102). It received 11 answers; all responses provided examples on records loss (e.g. lack of “as built” drawings, drawings comprising all up- to-date changes in systems and structures having been made during operation); a lack of information on material and radiological inventories of buildings, components, and radiological surveys; and a lack of information on operational history (including events) that may result in discovering an unexpected contamination. Five examples of knowledge loss were shared (e.g. difficulty with interpreting old records and lack of knowledge on how to retrieve archived information) and nine examples of memory loss were given (e.g. related to the retirement of operational staff and the lack of information in operational logs and other documentation).

RK&M loss occurred due to both physical and social reasons, such as not planning for future information needs, not updating information and information being scattered. All examples incurred negative consequences and costs, some marginal, but others significant. An illustration was mentioned in which over 25% of the duration of the total project had to be devoted to reconstructing a minimal amount of critical information to analyse the possible decommissioning and dismantling (D&D) strategies. New surveys of the contamination of the facility and dose rate surveys were necessary, which led to additional unnecessary exposure of the D&D personnel, thus breaching the principle of minimisation of radiation doses (J-G. Nokhamzon in NEA, 2013: p. 103). Overall, it was learnt that lack of RK&M can present the involved parties with considerable safety problems and can have a significant impact on project schedules and costs.

Lessons from RK&M loss outside the nuclear field

An exploratory investigation on RK&M loss was conducted based on 21 examples of landfills and contaminated sites in Switzerland, Germany and the United States (NEA, 2014; see also M. Buser in NEA, 2013: pp. 37-44). The examples were all drawn from non-nuclear industrial and military processes operated by a range of landowners including national government, local authorities, private companies and individuals. Each of them had a history in which the original waste disposal practice was forgotten or details had been lost, resulting in uncontrolled environmental contamination and costly clean-up. Combined with the analysis of the 2011 Survey on Examples of Memory Loss (S. Tunbrant in NEA, 2012: pp. 19 and 47-54), the following reasons for RK&M loss were identified as most relevant:

•no/poor records (e.g. with insufficient data to inform retrieval or remediation actions), lack of copies of sets of records or no/poor archives;

•no/insufficient update of information (e.g. maps, plans);

•no/insufficient budgets to fulfil RK&M preservation duties and economic discontinuities (e.g. bankruptcy);

•personnel changes (e.g. retirement, change of job);

•illegal activities (the deliberate destruction of records and knowledge) whether for avoiding legal prosecution, economic gain, political interests or shame about past conduct24);

•societal discontinuities (e.g. war, shift of national boundaries);

•technical failures or environmental degradation of records.

24.The main investigator of the study (NEA, 2014c), M. Buser, in fact mentioned difficulties in retracing reasons for RK&M loss due to the sensitivity of the issue in multiple case studies.

RK&M PRESERVATION: CHALLENGES AND OPPORTUNITIES

Interestingly, technical or environmental factors seem to have the smallest impact of all analysed factors (M. Buser in NEA, 2013: p. 44). With the exception of the two factors mentioned under the last bullet above, the source of loss is directly related in one way or another with human aspects notably related to:

•deficient regulatory guidelines and their enforcement;

•lack of funding, lack of organisational/institutional continuity;

•carelessness (disinterest, negligence, ignorance or incompetence) or wilfully forgetting.

With regard to the last factor above, R. Moxham, author of historical books, also highlighted how, over the longer term, RK&M disappear when they are linked to parts of history that are not deemed particularly positive (R. Moxham in NEA, 2015: pp. 75-87). Regarding the shorter term, another study on RK&M loss related to contaminated sites in Switzerland revealed power games between state officials, representatives of the industry, technical experts, politics and the general population in all of the case studies. Information may be out there, but not in the right place or not with the right people. It was thus pointed out that differences in institutional interests, rivalry, politics and power imbalances can play a major role (Ch. Sieber in NEA, 2012: pp. 20 and 54-57).

Overall, short-term thinking was a key factor to RK&M loss. It may take generations before the effects of inappropriate practices come to the attention of policy makers and regulators, and only when RK&M becomes acutely needed. The fact that environmental consequences are often not acute and that authorities tend to aim to best serve the interests of society during their own time in office are two ingredients of a common recipe for RK&M loss. The same may apply for industry where it is common to only fulfil the minimum requirements of the law. RK&M loss often only becomes an issue in the context of later clean-up activities either out of a wish for developing new economic activities at waste sites or due to shifts in the perception of ecological values (S. Tunbrant in NEA, 2012: pp. 19 and 47-54; see also T. Schneider in NEA, 2012: pp. 104-105). This also tells us that perceptions of RWM, concepts for final disposal, environmental valuations and understandings of safety change over the course of time.

Moreover, people with different disciplinary backgrounds may look at these issues differently, thus calling for a multidisciplinary approach in designing both waste management and RK&M preservation strategies (see also Section 4.6 on actors). Also, within organisations it is important to establish good communication paths between different organisational units. There are plentiful examples where data and information are archived/preserved in one part of an organisation (authority, company, municipality, etc.) and not available to another part of the same organisation that needs them (S. Tunbrant in NEA, 2012: p. 19).

It is important to outline that for many of the examples studied, there never was a dedicated reflection on or explicit intention to keep RK&M at the time. In such a setting, RK&M loss was found to be a very fast process (decades) that notably has to do with a general lack of awareness of the importance of RK&M preservation issues and the dedicated effort it requires. Even if the willingness to preserve RK&M is present, the reality remains that in the longer term, materials degrade, meanings and values change according to culture and context, and RK&M can be manipulated or misused (e.g. as a way of holding power over others). The more general lesson learnt here is that a regulatory framework, an organisational culture, a broader societal scrutiny, and an interest in the matter prove indispensable boundary conditions for RK&M preservation.

On the simplest level of analysis, there are two different forms of RK&M loss. There is epistemic loss when the information is physically available, but not found or understood, and there is physical loss of information when its carriers are no longer available. Invited expert J. Springer of the UNESCO’s Memory of the World Programme explained that in the field of documentary heritage “whether it is recorded on clay, stone tablets or papyrus scrolls; in manuscripts or books; in the form of photographs, film or sound recordings; or accessible through modern media such as blogs and the internet, documents are fleeting and face the risk of disappearing without a trace. The causes are many: war and social upheaval, natural catastrophes (water, fire, earthquakes, etc.), chemical deterioration, technological obsolescence, wilful destruction, neglect and lack of funding. These have all caused the loss of significant documents around the world” (J. Springer in NEA, 2013: p. 87).