Feature

posted 31 Jan 2007 in Volume 3 Issue 7

Case study: British Nuclear Group

Going nuclear

Records management is crucial to the nuclear industry. Now, it is going electronic.

By Graham Farrington

In the 1950s, nuclear power was sold to the British public on the promise that it would be able to provide almost limitless supplies of clean and almost-free energy.

While such a promise proved impossible to keep, nuclear energy today nevertheless still has the potential capacity to provide one-third of the UK’s electricity. However, the generating plants are ageing and when the price of gas and oil fell in the 1990s, the nuclear industry struggled to be a competitive producer in one of the most liberated electricity markets in the world.

The UK’s nuclear power industry was privatised in the early 1990s just as energy prices were starting to drop. Because of the industry’s heavy fixed costs, it struggled to compete.

It was, ironically, just at the start of the recent surge in global energy prices that a decision was taken by the government to restructure the UK’s civil nuclear industry – and that’s when we had to look again at our records management strategy.

British Nuclear Fuels Ltd (BNFL) owned and operated many of the nuclear-licensed sites in the UK until the formation of the Nuclear Decommissioning Agency (NDA) on 1 April 2005. As its name suggests the NDA was established to oversee the orderly running down of the country’s civil nuclear facilities and to look after the sites after they are closed.

The ownership of the sites and their liabilities, which will last for decades after they are closed, were transferred to the NDA and the operators continue running the sites as the licence holders contracted to the NDA. British Nuclear Group is part of the BNFL Group, and was formed as a specialist site management and nuclear clean-up business.

Nuclear legacy

British Nuclear Group Sellafield Limited is based on the west coast of Cumbria. It represents one of the most challenging nuclear site-management programmes in the world. Construction began as long ago as 1947 on a plant that could produce weapons-grade plutonium, as well as generating electricity for civilian use. Indeed, the Calder Hall nuclear power station on the site, which was first connected to the electricity grid in 1956, was the world’s first commercial nuclear power station and when it was closed in 2003 had been generating for some 47 years.

The activities at Sellafield therefore cover a wide range, including the remediation, decommissioning and clean up of the historic nuclear legacy.

The power station was built in the early days of nuclear power generation to a very different design from the pressurised water reactor (PWR) model that has become a standard the industry globally. Both these factors – the design of the reactors and their age – add to the complexity and challenge of running the Sellafield site.

Sellafield is also home to the Thorp and Magnox reprocessing plants, the Sellafield Mixed Oxide Fuel manufacturing plant and a wide range of nuclear-waste management and effluent treatment facilities. The company’s primary objective is to manage plant operations and an extensive clean up and decommissioning programme.

Recently, BNFL and the NDA have agreed a position for the future of the British Nuclear Group, which was approved by the Secretary of State for Trade and Industry in October 2006. Project services and reactor sites will be sold off and the contract to manage and operate the Sellafield site will be put out to competition by the NDA in 2008 – whereby a new Parent Body Organisation will manage the current site licence company.

The challenge

Record keeping in the nuclear industry has always been important. But there is a significant challenge in managing the records for an organisation of this size and complexity.

There is a history of diversity in the ways of working among the business units and there have been many changes in organisations and structures. Record capture is excellent and is in keeping with the need to comply to the letter with the very many regulations that govern the nuclear industry. Furthermore, there is a long-accepted culture in the nuclear industry of keeping everything (just in case) – but there is little or no management beyond the capture phase.

The industry is highly regulated by the Nuclear Installations Inspectorate, the Environment Agency and the Office for Civil Nuclear Security and the record-retention periods are generally long – often 30 years or more. The trigger events are difficult to apply and may occur many years after the record creation/capture. Ahead of our 2008 deadline, we needed to start to streamline the management and retention of records at Sellafield.

Historically, Sellafield has always kept records on paper or microfilm, rather than in an electronic form. This would change, too.

The analysis

There are many variables in establishing the position and state of records within the site. A simplistic model was drawn up divided into four steps or categories (see figure one, below):

Chaos;
Control;
Organise;
Improve.

The quality managers around the business then took a view of how they performed against the descriptions for people, process and systems. The average position was between ‘chaos’ and ‘control’. The requirements under the NDA contract required the site to be at the ‘organise’ step and, if the business was to leverage the use of the information contained in its records, then the ‘improve’ level would be required.

The people working in this area were re-organised into a strategy and standards team, and a service-delivery team. The policy, process, systems and standards are produced by the strategy and standards team. The service delivery was outsourced to records-management specialist Iron Mountain with an initial three year contract. The service to be delivered includes project-document control, scanning, microfilming and archiving for the whole site as a managed service.

The records programme

In parallel with organisational change, the records programme was developed with six stages to be covered in a three-year time frame. The first stage was to introduce a single systematic process for managing records and get all parts of the business working to it.

The second was to capture the archive material much earlier in the ‘records life cycle’ to ensure it was stored securely and in a controlled environment. In tandem with this was the third stage of clearing all of the 110 local archive stores around the site (while this was in progress, the 110 has grown to 180 – an expected escalation and there are probably more to come).

The fourth stage is to go electronic. Much of the day-to-day records, documents and information is created electronically and then printed to paper if it is a record. The plan is taking shape and likely to include the implementation of a Microsoft SharePoint system to handle all of the electronic information needs and collaboration; EMC Documentum is likely to be used as the record repository. The implementation of these stages would take the business to the ‘organise’ level sufficient for the NDA contract.

With the move towards an electronic environment and the previous poor performance in the long-term management of records, the fifth stage is to introduce active management of the record sets. This will introduce a managed service to each of the business units comprising of an information manager (or librarian) with a team of records professionals to handle the record sets within the business in conjunction with the framework established for the site.

The final stage is to validate the electronic systems to BIP 0008, the British Standards Institute’s code of practice for the Legal Admissibility and Evidential Weight of Evidence Stored Electronically. This will cover the storage of records within those downloading the information to the records management system.

The record instruments

A key part of the programme was for the strategy and standards team to develop those record instruments (retention schedule, business classification scheme, meta data standard, and so on.) that are essential to the business. The first to be tackled was the retention schedule, which has been developed from a base of the regulatory conditions imposed by the nuclear site licence, the environmental and health and safety legislation, and the remaining commercial, financial and administration requirements. The schedule is generic in form allowing varying record types to provide evidence to meet the requirements specified. There are a number of areas where the existing practices could be challenged to produce an improvement to the retention schedule and this will be done when the opportunity arises.

The metadata standard has been developed in partnership with the IT department. A high-level file plan is emerging with wide consultation for use when implementing the electronic system.

Preservation

A risk assessment has been carried out covering our current position in managing records, the retention times and the media types and formats of current records to arrive at a preservation strategy. This has been taken further given the likelihood of greater electronic working in the future.

The first consideration is the retention period: where this is ten years or less, then the hard copy is retained; for 12 years or more, a microfilm is taken. This policy was adopted for two reasons. First, microfilm is more space-efficient than paper and can therefore be stored more cheaply. It is also more robust and ought to last longer. Second, older records are not commonly accessed, so the extra hassle of running a microfilm reader to be able to read the document is not great.

The next consideration is whether the record is classified as ‘vital’. If it is, then we require two ‘renditions’ to be stored in two different locations.

The choice of rendition media is currently between archive paper and microfilm with the likely use of a PDF archive – when the electronic system is available.

Finally, it is considered whether the record is ‘dynamic’ – that is to say, still in use – or ‘static’ (the notion of whether something is ‘active’ or ‘inactive’ has other connotations on a nuclear site!). The native e-file is retained for re-use if the record is dynamic and deleted if it is static. This will change within the electronic system.

The principles will remain as the move to electronic working gathers pace. The need to preserve the electronic records will require more time and effort (and probably cost, too) to manage when compared to an archived record. But we expect this cost to be recouped in terms of access, availability and future re-use.

Progress

The programme was planned over a period of three years. The progress to date stands at 21 per cent complete with the foundations of process in place and electronic ways of working being explored and established. So what?

The move from old ways of working to different process requirements has been achieved by informing and persuading people of the need to change. There is a realisation of the importance of managing the changes and educating most of the people. The most frequently asked question is, “what is a record?” The most difficult part of the answer is how it applies to their process or area of work.

There are two main issues:

1. Competing for attention and the backing from the business leaders when there is so much else going on. The management of records is a low priority in the general scheme of things (this is reflected in the ‘good at capture and keep everything mentality’ that pervades the business). Education will help.

2. The management of records in an outsourcing regime tends towards the cost parameters rather than the quality of the service. This was spotted early and is being reversed. It will require significant effort to educate and train the people required to implement the policies and strategies that are evolving.

Finishing touches

There is concern at the pace of change and the general rush to work in an electronic environment, often poorly controlled, as we grapple to understand the implications for long-term record keeping. We believe there will be a long transition period between the hard-copy era that we were so comfortable with just 15 years ago and a future where the problems of managing electronically are resolved and embedded within the business.

Education is therefore a key element of our programme – not only for those involved in records management in some capacity day-to-day, but to explain the reason for the shift to those in management positions to ensure broad buy-in and support.

Outsourcing of the service delivery element can work, but it needs strong leadership and a robust framework from within the business. The quality of service needs to be monitored as well as the usual cost controls.

Doing nothing is not an answer (as has been proven with our current legacy problems); we must try and steer a middle course towards an educated workforce implementing sensible ways of working. This has the potential to significantly enhance the future business performance over the many years of work ahead at the Sellafield site.

Besides, with the current energy uncertainty in Europe, nuclear may soon make a comeback. Then, best practice sought in this programme will not only be required, it will be expected.

Graham Farrington is Head of Records Management for British Nuclear Group Sellafield Limited. He can be contacted by e-mailing graham.farrington@britishnucleargroup.com.

Figure 1: Where are we on this scale?

CHAOS

People: Clerical with no record-keeping training or experience;

Process: Keep what we have always kept;

System: Paper-based, collected in boxes and stored in a cupboard or room.

--> Average position

CONTROL

People: Minimum record-keeping understanding;

Process: Generic retention schedule in place; records schedule compiled and collecting against it;

System: Paper-based, collected and retained while of value to the business unit, passed to central archive.

ORGANISE

People: Understand the value of record keeping and record management;

Process: Capture processes in place; legacy secured;

System: Authorise, capture and manage records electronically.

--> Where we should be

IMPROVE

People: Value records as information assets;

Process: Common process throughout and ‘learning from experience’ programme in place;

System: Managing systems information through record kepping.

--> Long-term goal