EPA/ITAS
         044-4-3
September 11, 1989
Agency Automated Document Storage and Retrieval
             Requirements Analysis

          Draft Requirements Analysis
                 Prepared for

 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
       NATIONAL DATA PROCESSING DIVISION

 INFORMATION TECHNOLOGY ARCHITECTURAL SUPPORT
            CONTRACT NO. 68-W8-0083
           Prepared by the Viar Team

              Viar and Company
             30O North Lee Street
                  Suite 200
           Alexandria, Virginia 22314

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                             Table  of Contents


                                                                    Page

SECTION  1 -INTRODUCTION                                            1-1

SECTION  2 -METHODOLOGY                                            2-1

SECTION  3 - MISSION NEEDS STATEMENT                               3-1

SECTION  4 -SUMMARY  OF FUNCTIONAL  REQUIREMENTS                4-1

SECTION  5 -STATEMENT  OF OPTIONS                                   5-1

SECTION  6 - COMPARISON  OF  FUNCTIONAL  REQUIREMENTS
             AND TECHNICAL  OPTIONS                                6-1

SECTION  7 - CONCLUSION                                              7-1



APPENDIX  A - BIBLIOGRAPHY

APPENDIX  B  -POINTS OF CONTACT

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                             SECTION 1 - INTRODUCTION

1.1    PURPOSE

       The purpose of the Agency Automated Document Storage and  Retrieval Requirements
Analysis is to identify the automated document storage and retrieval requirements of the EPA user
community.  This analysis supports the current EPA effort to develop a consistent, Agency-wide
approach to records management.  In order to accomplish this goal, this study provides a Mission
Needs Analysis and a Requirements Analysis that summarizes functional  requirements identified.
In addition, this  document identifies and describes available technological options, compares the
functional requirements to these technological options, and summarizes the ability of each technology
to meet the identified Agency requirements.

1.2    ASSUMPTIONS

       The users to be interviewed were identified by EPA's Information Management and Services
Division (ISMD) of the Office of Information Resources Management (OIRM). Users were selected
because they have known requirements for automated document storage and retrieval. It is assumed
that they are knowledgeable about the requirements of the user community to which they belong.

       Prior to committing Agency resources for procurement of automated storage and retrieval
systems, it is assumed that each program office will provide further justification as required by the
Federal Information Resources Management Regulation (FIRMR) in Section 201-30.007, including
a detailed system design with a cost-benefit analysis and a detailed implementation analysis for their
applications. It is assumed that these documents will address such issues as the legal admissibility of
documents stored on automated media, the expected life of the selected storage medium, and the
disposition of  original documents once an automated  system  is  implemented. The methodology
required to perform these tasks is described in detail in the FIRMR in Section 201-30,007.

1.3    REFERENCES

       A list of documents and points of contact used for the preparation of this document are
presented in Appendices A and B.
                                            1-1

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                              SECTION 2 - METHODOLOGY
       In order to determine the Agency's overall automated storage and retrieval requirements, a
methodology was used that included the following actions:

       •   Conducted  meetings with Office of  Information  Resources  Management  (OIRM)
           personnel to identify users to be interviewed. OIRM personnel also provided an overview
           of Agency records management issues.

       •   Reviewed existing and in-progress documentation, including requirements analyses from
           a number of program offices.  These documents are referenced in Appendix A.

       •   Performed Mission Needs Analysis, as  described in both the EPA System Design and
           Development Guidance document and the FIRMR.

       •   Developed an Interview Introduction Package and Interview Questionnaire.

       •   Performed telephone interviews with EPA regional personnel, the Financial Management
           Division, and the National Enforcement Investigations Center to identify their automated
           storage and retrieval requirements. All personnel interviewed are listed in Appendix B.

       •   Conducted  interviews  with a number  of Headquarters program office personnel to
           identify Agency automated storage and retrieval requirements.  These program offices
           included the Office of Toxic  Substances, the Office of  Pesticide Programs,  the
           Headquarters Accounting  Operations Branch,  the  Office  of  General Counsel,  the
           Procurement and Contracts Management Division, the Contract Laboratory Program, and
           the Headquarters Operations and Client Services Division. The Headquarters personnel
           interviewed from these program offices are listed in Appendix B.

       •   Reviewed technical publications, which are listed in Appendix A.

       •   Performed and documented functional requirements analysis.

       •   Performed analysis of available technological options.

       •   Performed a comparison of the documented functional requirements and the available
           technological options.
                                            2-1

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       In implementing this methodology, use was made of readily available information to assist in
identifying its automated storage and retrieval requirements.  This methodology focuses on the
Agency as a whole, rather than detailing the requirements of each individual program office.
                                            2-2

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                       SECTION 3 - MISSION NEEDS STATEMENT

3.1    INTRODUCTION

       This document follows the Systems Design and Development Guidance (OIRM87-02) which
conforms to the FIRMR and which was developed by the EPA's Office of Information Resources
Management (OIRM). This guidance to life cycle management suggests that the first step of any
system design and development effort is a Mission Needs Statement, which is developed by analyzing
the current environment, interviewing EPA personnel to determine their information and processing
needs, and developing an initial system concept. The Mission Needs Statement contained in this
document should provide the Agency with enough information to justify further effort in acquiring
and developing automated storage and retrieval systems.  The Mission Needs Statement is also the
prerequisite for the next  phase of the system life cycle, as defined by OIRM, the Preliminary Design
and Options Analysis.

       This document presents the Mission Needs Statement for the Agency as a whole, in relation
to its automated storage and retrieval needs for records management. Because of the broad scope of
this effort, this document summarizes the critical needs of a number of EPA offices and program
areas, rather than addressing each program and office in depth.  In addition, the broad scope of the
effort to develop a Mission Needs Statement precludes the development of an initial system concept
for each program office, which would typically be provided. Finally, the offices and program areas
selected for interviews were identified by OIRM as those having records management problems. As
such,  they provide a representative although not a comprehensive view of the Agency's records
management problems and issues.

       In order to complete the Mission Needs Statement,  18 people in eight regional offices and 30
people in nine Headquarters offices and program areas  were  interviewed.  This Mission Needs
Statement incorporates the results of these interviews, as well as additional information obtained from
program office documentation and  OIRM personnel.

       The remaining sections  of this Mission Needs  Statement provide the following information:

       •   A  summary  of the overall Agency mission;

       •   A  brief definition of the records management problem;

       •   A  description of key functions and program offices;

       •   A  summary  of the  records management issues by program office; and
                                            3-1

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       •   A summary of the findings of the mission needs analysis.

3.2    AGENCY MISSION

       EPA was established in 1970 by Congress to protect human health and to preserve our nation's
waterways, land areas, and atmosphere.  This mission was further expanded by a number of laws,
such as the Clean  Water Act, the Toxic Substances Control Act, and the  Superfund Act.  To
accomplish its  mission, the Agency sets standards; issues  regulations; monitors and  enforces
compliance; and conducts, analyzes, and publishes environmental research. An organizational chart
of the Agency is presented in Exhibit 3-1.

3.3    THE PROBLEM

       Within the Agency, there are  a number of programs and offices whose direct function is to
support the Agency's mission. In order to manage and administer these specific programs, documents
and records relevant to the program are received, stored, and generated.

       The Agency has become aware of the increasing volume of paper it deals with in many
regulated areas. Several factors have contributed to a records management problem: the expansion
of existing EPA program requirements,  which  require data  and  document submissions from  the
regulated community; the introduction of new legislation and program requirements, such as  the
Freedom of Information Act or the Emergency Planning and Community-Right-to-Know Act; and
the lack of guidance and standards for automated storage and retrieval.

       Currently, many documents are stored in warehouses, file cabinets, or locked rooms. Both
the quantities of the  documents involved and the effective management of these documents have
resulted in concern with and commitment to effective records management solutions. In particular,
the Agency is investigating methods of electronic record keeping, or automated storage and retrieval.

       Since  document processing supports the Agency's mission, an analysis  of the Agency's
requirements  for automated document storage and retrieval has  been performed.  A number of
programs and offices which routinely process vast  quantities of documents and records have been
identified by OIRM as candidates for automated document storage and retrieval. These programs
and offices are described below.
                                            3-2

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 U.S. ENVIRONMENTAL PROTECTION AGENCY


1
Office of
Adminstration and
Resources
Management




1 1


Office of Enforcement
and Compliance
Monitoring
ADMINISTRATOR I


Office of General
Counsel

1 1
Office of Water


Office of Solid Waste
and Emergency
Response




1 1 1
Office of Policy,
Planning and
Evaluation
Office of External
Affairs
Office of Inspector
General

1 1 1
Office of Air and
Radiation

Regions
Office of Pesticides
and Toxic
Substances
Office of Research
and Development

II    ITT    I    I    I    III
         ID
VI
VII  II VIII I IX

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3.4    KEY FUNCTIONS/USERS AND THEIR MISSIONS

       The Agency, as a whole, processes documents for a variety of purposes.  Some of these
documents contain confidential information while other documents must be made available to the
public. Others are submissions required by law from the public sector, while some may be used as
legal evidence.

       The programs and offices that process huge volumes of paperwork and have been identified
as candidates for automated document storage and retrieval are:

       •   Office of Solid Waste and Emergency Response, which administers Superfund;

       •   Office of Toxic Substances;

       •   Office of Pesticide Programs;

       •   Procurement and Contracts Management Division of the Office of Administration and
           Resources Management, Office of Administration;

       •   Headquarters Accounting Operations Branch of the  Office  of Administration and
           Resources Management, Office of the Comptroller;

       •   Headquarters Operations and Client Services Division of the Office of Administration
           and Resources Management, Office of Human Resources Management;

       •   Financial Management Division  of  the  Office of Administration and Resources
           Management Research  Triangle Park, NC., and

       •   Office of General Counsel.

       These programs and offices do not represent all programs and offices of the EPA, however
they were selected by OIRM for this study because they are a representative sample of the records
management problems and issues of the  Agency.  The mission and key functions of these programs
and offices are discussed in further detail below.

3.4.1  Sunerfund

       Superfund was created by the Congress with the passage of the Comprehensive Environmental
Response, Compensation, and  Liability Act  of  1980 (CERCLA). The Act gave  the  Federal
                                            3-4

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Government authority to respond to emergencies involving uncontrolled releases of hazardous
substances and to develop solutions for the nation's most serious hazardous waste problems.

       A "Superfund" was established to  pay for these activities.  The $1.6  billion  Hazardous
Response Trust Fund was financed primarily by a tax on crude oil and  selected chemicals. The
passage of the Superfund Amendments and Reauthorization Act (SARA) of 1986 increased the
Hazardous Response Trust Fund to $8.5 billion and incorporated many new management policies and
procedures, requiring significant amounts of documentation. Much of this documentation is required
for the legal actions taken by the EPA against responsible parties.

       The Superfund program is  administered by  the Office of Solid Waste and Emergency
Response (OSWER). OSWER is directed by an Assistant Administrator and is divided into a number
of offices and divisions.  Exhibit 3-2 displays a complete organizational chart of OSWER.

       Several areas of the Superfund program have been identified as having automated storage and
retrieval requirements. These are described below.

3.4.1.1     Superfund Site Files

       Under the Superfund program, a site file must be maintained for each Superfund hazardous
waste site or spill location, documenting activities at the site. These site files contain site-specific
information on cleanup operations, legal documents, financial documents, public relations documents,
technical documents, and photographs and maps to support a variety of Superfund activities.

       In keeping track of Superfund cleanup activities, the ten EPA regions must process thousands
of various documents, some  of which must be available to the public and many of which must be
available to use in court should enforcement action be taken.  The regions are responsible for the
preservation and maintenance of these documents, which are received from the  sites.

       Superfund site files are  maintained in a variety  of locations. The site files are eventually
archived at an  off-site location.   The  Superfund site  files  are  integral  to  the  successful
implementation of the Superfund program.

3.4.1.2     Contract Laboratory Program

       The Contract Laboratory Program (CLP) provides state-of-the-art chemical analytical services
on a high volume basis to support the Superfund program. The CLP  provides legally defensible
analytical results to  support Agency enforcement  actions or  other requirements of the user
community.
                                             3-5

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    OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE (OSWER)
     Office of Program
     Management and
        Technology
   Office of Waste
Programs Enforcement
  Progam Mgmt. and
   Support Office
  Federal Facilities
  Hazardous Waste
  Compliance Office
     CERCLA
    Enforcement
      Division
 RCRA Enforcement
      Division
      Assistant Administrator for Solid
      Waste and Emergency Response
Office of Solid Waste
 Office of Program
 Mgmt. and Support
 Office of Planning,
    Policy and
    Information
 Waste Minimization
      Staff
   Municipal Solid
   Waste Mgmt.
     Program
                            Waste Mgmt. and
                           Economics Division
                            Permits and State
                            Programs Division
                            Characterization
                            and Assessment
                                Division
                                                           1
 Office of Emergency
and Remedial Response
   Office of Program
  Mgmt & Technology
     Emergency
  Response Division
    Hazardous Site
    Control Division
    Hazardous Site
  Evaluation Division
                           Emergency
                        Preparedness Staff
                                                          1
Office of Underground
   Storage Tanks
   Implementation
      Division
     Policy and
  Standards Division
                                       Exhibit 3-2

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       The Sample Management Office (SMO) provides managerial, operational, and administrative
support to the CLP.  SMO provides technical and administrative  controls over the processes and
events of sampling and analysis programs. The primary objective of SMO is to facilitate optimal use
of program analytical resources by ensuring data quality, completeness, and timeliness.

       The CLP supplies analytical services in direct response to requests from the EPA regions, the
primary users of the program. Recently, states and other Agency programs have also become part
of the CLP user community.

       The documents received by SMO support Superfund compliance, enforcement, analytical, and
cost activities.  SMO  is responsible for the  preservation  and storage of millions of  Superfund
documents.  These documents are stored in  boxes at an off-site  location near the SMO offices.
Without the existence of these  Superfund documents, many Superfund activities could not be
accomplished.

3.4.2   Office of Pesticides and  Toxic Substances

       The Office of Pesticides  and Toxic Substances (OPTS) is responsible for administering and
monitoring compliance with pesticide and toxic substances statutes. Within OPTS, responsibilities
are divided between three offices.  The  Office of Toxic  Substances (OTS) is  responsible for
administering the Toxic Substances Control Act (TSCA). The Office of Pesticide Programs (OPP)
is responsible for administering the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
The Office of Compliance Monitoring (OCM)  is responsible for monitoring compliance with FIFRA
and TSCA. Exhibit 3-3 displays a complete organizational chart of OPTS.

       In order to accomplish  its mission of administering TSCA,  OTS developed  the  TSCA
Premanufacturing Notification Program.  In addition, OTS administers  the Toxic Chemical Release
Inventory, required under SARA Title III. Additional OPTS programs were identified for automated
document storage and retrieval.   In order to administer FIFRA, OPP developed several programs.
These include pesticide product registration,  product reregistration, and pesticide product labels.
These OTS and  OPP programs are described below.

3.4.2.1     TSCA Premanufacturing Notification

       A variety of reporting requirements promulgated under Section 5 of the TSCA result in tens
of thousands of annual industry submissions to OTS. A major part of the OTS mission is to receive,
process, and disseminate information to Agency personnel and the public. OTS functions include the
following:
                                            3-7

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OFFICE OF PESTICIDES AND TOXIC SUBSTANCES (OPTS)
        Assistant Administrator for Pesticides
               and Toxic Substances
Office of Program
  Management
  Operations
TSCA
Assistance
Office


^m
Office of Toxic
Substances
Economics and
Technology Division
Chemical Control
Division
Information
Management
Division
•

Existing Chemical
Assessment
Division
Health and
Environmental
Review Division
Exposure
Evaluation Division

Office of Pesticide
Programs
Environmental Fate
and Effects Division
Special Review and
Registration
Division
Biobgican and
Economic Analysis
Division
Program
Management and
Support Division
-
Reid Operations
Division
Health Effects
Division
Registration
Division

                                                                                 1
                                                                           Office of Compliance
                                                                               Monitoring
                                                                   Policy and Grants
                                                                      Division
                                                                  Compliance Division
                                                                    Laboratory Data
                                                                     Integration
                                                                  Assurance Division
                                  Exhibit 3-3

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       •   Extensive, formal, and statutory deadline-driven review of new chemical substances
           under TSCA Section 5, which requires producers of new chemical substances to provide
           information and test data to the EPA prior to manufacturing the new chemical. This
           program is known as Premanufacturing Notification and involves Confidential Business
           Information (CBI), which must be protected.

       •   Response  to information  requests from EPA, other federal agencies, and the public.

       The majority of the industry  submissions received by the OTS are claimed as CBI by their
submitters. OTS review of industry  submissions results in the generation of further thousands of
confidential TSCA documents.

       Premanufacturing Notifications are reviewed immediately upon receipt and  are frequently
used to support possible  regulatory action, years after receipt.   In  addition, EPA  is required to
perform an annual audit of all TSCA CBI hard copy documents in its possession.

3.4.2.2     SARA Title ITI Toxic Chemical Release Inventory

       Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA) establishes
requirements for industry and Federal, state, and local governments regarding emergency planning
and "community right-to-know" reporting on hazardous chemicals.

       OTS administers Title Ill's toxic chemical release reporting  program.  OTS developed an
inventory of toxic  chemicals, based on  information  provided  by facilities which manufacture,
process,  or  use specific hazardous  substances.  To accomplish this, OTS maintains industry
submissions and related documents, which must be made available to the public.

       Title III has four major sections: emergency planning, emergency notification, community
right-to-know reporting requirements, and toxic chemical release reporting.

3.4.2.3     Pesticide Product Registration

       Pesticide products  that  must  be  registered  include crop  and  agriculture  pesticides,
disinfectants, and insecticides.  OPP bases registration decisions upon the  determination whether
pesticide products cause unreasonable adverse effects to man or the environment.  In order to make
these regulatory decisions, registrants must perform chemical studies and submit test data and results
to OPP for review.  This process involves millions of pages of pesticide product documentation. The
Registration Standards Program was developed to efficiently identify needed data, obtain those data
from pesticide registrants, review the  data,  and develop  regulatory  conclusions  regarding  the
                                             3-9

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continued registrability of the chemical.

3.4.2.4     Pesticide Product Reregistration

       FIFRA88 is an amendment whose purpose is to speed up progress of the product registration
program,  obtain missing data necessary for pesticide product  review,  and reduce unnecessary
reporting and review. FIFRA88 requires OPP to publish lists of pesticide active ingredients subject
to reregistration.   Registrants intending to seek reregistration are required to provide OPP with a
standard response form, identify data gaps, and agree to fill these data gaps. The responses from the
registrants are legal documents which commit the company to specific actions and, therefore, must
be stored.

       Those registrants seeking reregistration must then submit further documentation to OPP for
review. This additional documentation includes new  data studies and summaries of existing data
studies. If additional data gaps still remain, further data will be requested.  Based on the information
OPP receives,  it will review all data and reregister  the product or take other action.

3,4.2.5     Pesticide Product Labels

       Every registered product is reviewed by OPP. Each registered product accepted in regulatory
review for the past 15 years has an administrative file or product registration jacket, which contains
all official documents related to the product. The jacket contains the following types of information:
       •   Current and prior versions of the product label;

       •   Proposed and approved use sites;

       •   Pests the product is used against;

       •   Approved  methods of application;

       •   Approved  percentages of active ingredients;

       •   Amendment  requests;

       •   Correspondence between registrant and EPA; and

       •   chemical formulation.
                                             3-10

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       The  product labels are  stored in the product registration jacket and are integral to the
pesticide regulatory program, since they contain all information officially submitted by the registrant
about the product, not just the actual label from the product. The results of all regulatory decision-
making are contained in the jackets.

3.4.3   Procurement and Contracts Management Division

       The  Procurement  and  Contracts  Management Division (PCMD)  of  the  Office  of
Administration and Resources Management, Office of Administration  is responsible for developing
Agency-wide procurement policies  and  regulations, and for administering the Contracts Program
which includes pre-award activities, negotiation, contract award,  post-award administration, and
termination  settlement. The Division also:

       •   Provides technical  guidance to  all field contracting  operations, conducts contracts
            management technical reviews, and performs internal evaluations.

       •   Provides cost and price analysis services to Headquarters and field contracting operations.

       •   Coordinates action on contract proposals with the  Grants  Administration Division.

       •   Represents the Agency on contracts management matters with other Federal agencies and
            industry.

       •   Responds to numerous Freedom  of Information Act (FOIA) requests for information.

       In addition to the Headquarters contract office, there are offices located in each of the ten
EPA  regions,  in  Cincinnati, and in Research Triangle Park, N.C.   AH PCMD offices perform
activities in three crucial areas: cost recovery, FOIA  requests, and contract award and administration.

       The  volume of contract records has grown significantly over the past four years. This growth
has occurred primarily due  to:  (1) a significant increase in the use of contractors to conduct the
Agency's business  and (2)  the  Superfund  Program use of  contractors  to  assist  in  conducting
investigations and cleanup of hazardous waste sites.  The Superfund contract records are voluminous
and must be retained for a much longer  period of time than other contract records.

       PCMD is administered by the Office of Administration and Resources Management (OARM).
OARM is directed by an  Assistant Administrator and is divided into  a number of offices and
divisions. Exhibit 3-4 displays a complete organizational chart of OARM.
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3.4.4   Financial Operations

       The Agency has 14 Financial Management Offices (FMOs), also called Servicing Financial
Offices.  There are:

       •   One office in each of the ten EPA regions.  Each regional FMO processes its travel
           vouchers, commercial invoices, and grants.

       •   One office in Research Triangle Park (RTF), where the financial  processing for all
           Agency contracts is performed. The documents involved are invoices as well as sections
           of the actual contracts.  In  addition, this office  processes all  travel  vouchers  and
           commercial invoices for personnel located in RTP.

       •   One office in Cincinnati, where all of the Agency's Inter-Agency Agreements (lAGs)
           are processed.  In  addition, this office processes all travel vouchers  and commercial
           invoices for Cincinnati personnel.

       •   One office in Las Vegas, where the financial processing of all of the Headquarters grants
           is  performed.  In  addition, this  office processes all travel vouchers  and commercial
           invoices for personnel located in Las Vegas.

       •   One Headquarters  office,  where  regional and  Headquarters payroll  processing  is
           performed by the Headquarters Accounting  Operations Branch.  In addition, this office
           processes  all travel vouchers and commercial invoices for Headquarters personnel.

       There is little exchange of financial data between the regional FMOs. However, the regional
FMOs receive data from the RTP, Las  Vegas, Cincinati, and Headquarters FMOs. The RTP, Las
Vegas, Cincinati, and Headquarters FMOs share information among themselves.

       Documents processed by the Financial Management Offices include payroll time cards, travel
vouchers, commercial invoices, and timesheets.

       Financial operations are part of  the Office of the Comptroller. The Financial Management
Division is administered by the Office of Administration and Resources Management (OARM).
Exhibit 3-4 displays a complete organizational chart of  OARM.
                                            3-12

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OFFICE OF ADMINISTRATION AND RESOURCES MANAGEMENT (OARM)
Program Operations
Support Staff





Assistant Adm
Administration s
Managi

1 1
Office of
Administration
Management and
Organization
Division
Facilities
Management and
Services Division
Grants
Administration
Division
Procurement and
Contracts
Management
Division
Environmental
Hearth and Safety
Division

Off ice of
Administration
Cincinnati. Ohio
Computer Services
and Systems
Division
Facilities
Management and
Services Division
Personnel
Management
Division
Contracts
Management
Division

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Office of Information
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Program Systems
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Information
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Administrative
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             Budget Division
               Financial
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               Resource
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Office of Human
Resources
Management
Human Resources
Development
Division
Executive
Resources and
Special Programs
Division
Policy Research
and Development
Division
•

HQ Operations and
Client Services
Division
Field Operations,
Evaluation and
Support Division
Employee
Participation and
Communication
Division
                             Exhibit 3-4

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3.4.5    Office of General Counsel

       The Office of General Counsel (OGC) is responsible for performing all regulatory review and
legal advisory functions for the Agency. OGC does not initiate litigation, however it represents the
Agency in administrative proceedings.

       In addition, OGC performs regulatory review to ensure that each proposed regulation meets
the intent of the law and to minimize the potential  liabilities to the Agency as a result of the
regulation.  In addition, OGC administers the process of external regulatory review.

       OGC processes and maintains large volumes of litigation-related documents at Headquarters.
In addition, all documents generated as a result of regulatory review are maintained.

       OGC is divided into six divisions. In addition, there are ten Regional Administrators and ten
Regional Counsels, as well  as a Deputy General Counsel.  Exhibit 3-5 displays a complete
organizational chart of OGC.

3.4.6   Personnel Operations

       The Agency has 14 Personnel offices.  There are:

       •   A Personnel Branch in each of the ten EPA regions;

       •   A Personnel Management Division in Research Triangle Park (RTP);

       •   A Personnel Management Division in Cincinnati;

       •   A Personnel Management Division in Las Vegas; and

       •   The Headquarters Operations and Client Services  Division.

       There is little on-going exchange of personnel data between the offices. All locations perform
their own processing.

       Personnel operations processes all documents related to position openings, job classification,
and changes in employee status.
                                             3-14

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   OFFICE OF GENERAL COUNSEL (OGC)
  OFFICE OF GENERAL COUNSEL
Inspector General
   Division
  Deputy General
Counsel for Litigation,
  Legislation, and
 Regional Operations
                                            Regional
                                          Administrators
                                          Regions I-X
                                            Regional
                                           Counsels
                                          Regions I • X
Water Division
Air and Radiation
Division
I i
Solid Waste and
Emergency Response
Division
Pesticides and Toxic
Substances Division

Grants, Contracts
and General Law
Division
                     Exhibit 3-5

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       The Headquarters Operations and Client Services Division is part of the Office of Human
Resources Management and  is administered by  the  Office  of Administration  and Resources
Management (OARM). Exhibit 3-4 displays a complete organizational chart of OARM.

3.4.7   National Enforcement Investigations Center

       The National Enforcement Investigations Center (NEIC) is responsible for performing TSCA
4, 5, 8, and 12 inspections for all regions except Regions II, III, and V. These inspections involve
investigating and auditing paperwork submitted to the EPA by toxic substance manufacturers, as well
as auditing the reporting and manufacturing procedures used throughout the manufacturing process.
Among its other responsibilities, NEIC performs technical investigations, evidence audits, data audits,
and good laboratory practices inspections. Documentation of these activities are maintained by NEIC
on-site and at an off-site location.

       NEIC is part of the Office of Enforcement and Compliance Monitoring (OECM). OECM is
directed  by an  Assistant Administrator and is divided into a number of offices and divisions.
Exhibit 3-6 displays a complete organizational chart of OECM.

3.5    RECORDS MANAGEMENT ISSUES

       Each of  the Agency offices and applications described  above have records management
problems.  In determining their requirements  for  an automated document storage and retrieval
system, the records management problems of each office were  identified.

       The following records management issues have been identified for each program office or
application:

Suoerfund Site Files

       •  Large volumes of documents;
       •  Inadequate storage space;
       •  Unstructured file organization;
       •  Duplication of documents;
       •  Slow document retrieval;
       •  Lost, misplaced, or misfiled records;
       •  Documents retained indefinitely;
       •  Difficulty in  processing confidential data;
       •  Records not updated on schedule; and
       •  Difficulty in after hours access.
                                           3-16

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OFFICE OF ENFORCEMENT AND COMPLIANCE MONITORING (OECM)
National Enforcement
Investigations Center
Denver, CO



Assistant Adr
Enforcement a
Monil

ninistrator for
nd Compliance
oring


Office of Compliance
Analysis and
Program Operations

                        Deputy Assistant
                        Administrator for
                        Civil Enforcement
                           Associate
                          Enforcement
                            Counsel
                         Pesticides/Toxic
                       Substances Division
                           Associate
                          Enforcement
                       Counsel Air Division
                           Associate
                          Enforcement
                         Counsel Water
                            Division
                           Associate
                          Enforcement
                         Counsel Waste
                            Division
                                                 I
  Deputy Assistant
  Administrator for
Criminal Enforcement
   Eastern Branch
   Western Branch
                                      Exhibit 3-6

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Contract Lab Program
           Large volumes of documents;
           Inadequate storage space;
           Duplication of documents;
           Slow document retrieval;
           Lost, misplaced, or misfiled records;
           Documents retained indefinitely; and
           Large volumes of data exchanged.
Office of Toxic Substances
       •   Large volumes of documents;
       •   Confidential business information;
       •   Inadequate storage space;
       •   Slow document retrieval;
       •   Slow, labor intensive document preparation;
       •   Documents retained indefinitely;
       •   Large backlog of documents to be processed;
       •   Difficulty in tracking documents; and
       •   Current processing and storage are expensive.

Office of Pesticide Programs

       •   Large volumes of paper;
       •   Difficulty in locating documents;
       •   Missing documents;
       •   Unstructured information in variable format;
       •   Duplicate documents;
       •   Difficulty in maintaining high quality, readable image;
       •   Significant investment in existing systems; and
       •   Limited budget for automated storage and retrieval system.

Procurement and Contracts Management Division

       •   Large volumes of paper;
       •   No backup;
       •   Inadequate storage space;
                                           3-18

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           Confidential business information;
           Documents retained for extended periods of time; and
           Misplaced or lost documents.
Financial Operations
           Timecard processing is outdated;
           Large volumes of paper;
           No backup;
           Confidential information;
           Inadequate storage space; and
           Exchange information between FMOs.
Office of General Counsel
       •   Large volumes of documents;
       •   Inadequate document retrieval;
       •   Duplicate copies of documents;
       •   Enforcement-confidential information;
       •   Difficulty tracking documents;
       •   Inadequate storage space;
       •   Limited records management procedures;
       •   Difficulty processing nonstandard documents; and
       •   Limited budget for automated storage and retrieval system.

Personnel Operations

       •   Large volumes of paper ("paper factory");
       •   Inadequate storage space;
       •   No backups;
       •   Confidential information; and
       •   Current storage and retrieval is not automated.

National Enforcement Investigations Center

       •   Large volumes of paper;
       •   Inadequate on-site storage;
       •   Documents retained indefinitely;
       •   Enforcement confidential information;
                                           3-19

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       •   Chain of custody must be maintained;
       •   Labor intensive; and
       •   Exchange information with regions.

3.6    MISSION NEEDS SUMMARY

       The Agency processes, stores, and organizes vast quantities of legal and official documents
that support the successful implementation of the Agency's mission.  The responsibilities of the
Agency are increasing and the number of Agency documents is growing in support of additional
legislative, regulatory, and administrative functions.

       Much of the record-keeping of the program offices described in this document is in the form
of paper.  Much of the document processing is, at best, only partially automated.

       As the number of documents increases, maintaining the documents becomes increasingly less
effective.  Documents are more readily lost, backlogged, or difficult to retrieve. Space for the storage
of documents is increasingly scarce and expensive. Other significant issues include document security
and integrity, lack of backup for some documents,  and no current provisions for disaster recovery.
Some offices within EPA are already experiencing the strain of keeping up with the current pace of
paper documents.

       Although the Agency  has a records management  strategy, it  has not  yet  been fully
implemented throughout the Agency. Records management standards and procedures to address the
Agency's record-keeping problems must be in place to support any automated document storage and
retrieval system.

       The effects of the current document systems are expected to eventually impact virtually every
office within the Agency. Therefore, a plan of action to rectify current problems and prevent future
ones should be investigated.
                                            3-20

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               SECTION 4 - SUMMARY OF FUNCTIONAL REQUIREMENTS

       The effort of the Environmental Protection Agency (EPA) to protect the nation's land, air,
and water systems requires the maintenance of extensive, detailed documentation to support actions
taken.  These documents, by law, must be accessible to the public, but confidential information may
not be  revealed.  In addition, these documents are used in litigation proceedings; therefore, their
integrity must be preserved.

       It is apparent that the exclusive use of paper record keeping is not effective for the document
storage and retrieval requirements  of the Agency. The volume of documents  to store has been
increasing at a rate that has exceeded, or will soon exceed, available storage space.  Dealing with such
volumes of paper is very labor intensive. In addition, in terms of the EPA's security objectives of
integrity, confidentiality, and availability, paper record keeping methods are cause for concern.

       The  requirements summarized in this section were identified  as the result of personal
interviews with EPA regional and  Headquarters staff, in addition to a review of requirements
analyses done previously for the Agency. These requirements are discussed below and summarized
in Exhibit 4-J.

4.1    CONSERVE AND/OR MINIMIZE STORAGE SPACE

       The requirement for the conservation and /or minimization of document storage space in
those offices with records management problems  is universal.

       Many present storage systems, using paper and some microform, are not meeting current
requirements for space  conservation.  The volume of documents to be stored is often higher than
expected and space set aside for document storage  inadequate.  Considering projected annual growth
rates, which can be as much as 15 percent, the problem will worsen quickly unless changes are made.

4.1,1  Minimize Space Requirements

       All  the people interviewed for this study  who have records management problems want to
minimize the amount of space required to store their paper documents.

       The Headquarters Operations and  Client Services Division (HOCSD)  of  the Office of
Administration  and Resources Management,  Office  of Human  Resources Management needs to
reduce the amount of space required to store and access large numbers of paper documents. HOCSD
stores  Official  Personnel Folders  (OPFs) containing personnel  information  for each  of the
approximately 6,000 Headquarters employees, position descriptions for each new Headquarters job,
                                           4-1

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                                                 Applications
User  Requirements/
Applications  Matrix
Functional Requirements
                                                 DC
                                                 CD
                                                 o
                                                 DC
                                                 Q

                                                 CO
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                                                  CC
                                                 O
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                                                            LI
                                                            D_
                                                                C/3
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                                                                      CO
                 CO
                 LU
                                                                         CO
                                                                         O
 CONSERVE AND/OR MINIMIZE STORAGE SPACE
    Minimize Space Requirements
    Minimize Number of Duplicate Copies
 PROVIDE EFFICIENT DOCUMENT ACCESS AND RETRIEVAL
    Provide Document Tracking
    Minimize Retrieval Time
    Provide Access at a Convenient Location
    Allow After-Hours Access
    Support Simultaneous Access
 PROVIDE AUTOMATED RECORDS MANAGEMENT
 PROVIDE DATA SECURITY
    Ensure Data Availability
       Minimize Frequency of Lost, Misplaced, or Misfiled Records

    Maintain Data Integrity
       Provide High Quality, Readable Image
       Provide Durable Storage Media
    Ensure Data Confidentiality
       Support Confidential Processing Procedure
       Control Access to Confidential Information
  LEGEND
                     Requirement Not Identified      | Moderate Requirement

                   ] Not A Requirement            | Important Requirement

* Headquarters Office Accounting Branch (HOAB) and Financial Management Office
                               Exhibit 4-1

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                                          Applications
User  Requirements/
Applications Matrix  (cont'd)
Functional Requirements
 INTEGRATE EXISTING SYSTEMS
 SUPPORT CONVERSION OF EXISTING MEDIA
 STANDARDIZE FILE CONTENTS
 ORGANIZE DOCUMENTS
 SUPPORT UPDATE OF RECORDS
 PROVIDE BACKUP CAPABILITIES
 SUPPORT LEGAL ADMISSIBILITY
 GENERATE PAPER COPY
 ENSURE COST EFFECTIVENSS
 EXCHANGE INFORMATION
  LEGEND    [x] Requirement Not Identified     | Moderate Requirement

                 " Not A Requirement          | Important Requirement
  Headquarters Office Accounting Branch (HOAB) and Financial Management Office
                           Exhibit 4-1

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and  employment activity documents which  include  applications  received  for  job openings at
Headquarters. The OPFs, which take up the majority of Personnel's storage space, fill approximately
500 linear feet. They are stored in the Headquarters personnel file room in four Lektriever storage
cabinets, in standard shelving units, and on the floor due to insufficient storage space.

       The folders stored in the  Lektrievers are packed so tightly together  that it is difficult to
retrieve a single folder and it is extremely difficult, if not impossible, to insert new folders in these
cabinets.  The file room is filled beyond its capacity.  There is an immediate and critical need to
reduce the required storage space for these documents.

       The Headquarters Accounting Operations Branch (HAOB)  needs  to minimize the space
required to store its large number of paper documents. These documents are stored in the HAOB file
room, the warehouse in the Waterside Mall, and in the Federal Records Center. The files stored in
the file room alone take up  a large amount of space.  They include:  time cards  (595 linear feet);
travel vouchers and commercial invoices (330 linear feet); payroll/personnel files  (300 linear feet);
and  miscellaneous documents such as cancelled  checks, parking  permit charges,  disbursement
payments, and time sheets (180 linear feet).

       The Procurement and  Contracts Management Division (PCMD) also needs to reduce its
document storage requirements. PCMD processes and stores large numbers of paper documents such
as: preaward documents, contract files (active and closed), and cost-related materials. The preaward
documents are stored in the PCMD contract specialists' offices.  The large volume of active contract
files and the relatively smaller volume of cost-related materials are stored in the file room of the
Fairchild Building.  These documents take up approximately  1,800 linear  feet (roughly 3,350,000
pages).  An additional three million document pages (i.e., unsuccessful proposals and closed contract
files) are stored off-site at the Federal Records Center.  PCMD is expecting an additional 1.1 million
document pages per year, which represents a growth rate of approximately 15 percent per year.

       The regions interviewed are  near capacity or have exceeded available space for records
storage. The volume of documents to store, however, continues to increase. Estimated growth rates
for the volume of documents to be stored are at least 15 to 20 percent per year. Using these growth
projections, the document volume will double within five to seven years.

       Region V Superfund site records consisted of 4,120 linear feet in April 1988 and are projected
to more than  double by 1991.  To  date,  the  projected  growth rate has  proven  accurate.
Conservatively estimating each shelf-foot of paper as  1,900 pages, within two years, more than 15
million pages of documentation will need to be organized and accessible.
                                            4-4

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       The Contract Laboratory Program currently has an estimated 21 million pages, which require
storage in several warehouses.  These documents grow at an estimated rate of six million pages per
year and must be stored indefinitely.

       It was common to learn that records are stored in cardboard boxes under desks and in empty
offices.  Inadequate storage space has also fostered the use of commercial storage facilities. The use
of these alternative facilities adversely affects the organization and accessibility of information,
increases storage costs, and impacts the security of documents. The use of occupied offices for
excessive amounts of storage also makes the work environment unpleasant and potentially hazardous.

4.1.2  Minimize Number of Duplicate Copies

       The number of duplicate copies of documents must be  reduced.

       The retention of multiple copies of documents contributes to a shortage of storage space.  It
is not unusual for working copies of the same document  to be kept by many people, thus increasing
the amount of paper that must be stored.

       Currently, the Office of General Counsel (OGC) produces and stores many duplicate copies
of paper documents. Duplicate copies of documents are produced  during the internal regulatory
review process, in which each member of a working group (consisting of  members of the program
offices affected by the regulations and OGC attorneys) receives a copy of the proposed regulation.
Also, the OGC stores duplicate copies of proposed regulations.  After the internal review process is
completed, copies of the proposed regulations are kept by both  OGC attorneys and in the publicly-
accessible dockets.

       The Procurement and Contract Management  Division  (PCMD) stores duplicate  copies of
proposals until the contract is awarded. Sometimes the preaward processing can take longer than one
year. In addition, PCMD receives multiple copies of all proposals.

       Copies of contract sections, such as delivery orders and work assignments, are stored by both
the Financial Management Division and the Contracts Management Division at  RTP.  Other
documents, including some SF-50s, are stored by  both the Headquarters Operations and Client
Services Division, and the Headquarters Office of Accounting  Branch.

       In Region VII, it is fairly common for many copies of  a document to be maintained.  This
is  considered appropriate in certain cases, such as  for civil  referral packages.  One reason for
duplicate copies is the lack of procedures for borrowing and lending documents. In addition, Office
                                           4-5

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of Regional Counsel attorneys and media specialists keep duplicate copies because the site files are
in poor condition.

       In Region VIII, various offices and divisions send copies of information from their files to
the Remedial Project Manager to become part of the site file.  The list of offices and divisions
includes  Regional  Counsel, Hazardous Waste Management, Environmental Services, Community
Relations, Finance, Federal Facilities, and Grants. Each of these offices maintains information in
their files which is duplicated in the site file.

4.2    PROVIDE EFFICIENT DOCUMENT ACCESS AND RETRIEVAL

       Documents must be accessible and retrieval time must be minimized.

       Access to stored documents should be improved and retrieval time minimized. To accomplish
this, the ability to locate and track documents must be improved, the retrieval time must be reduced,
the location of storage facilities must be convenient, the ability to obtain files after regular hours
must be available, and the ability to gain access to records in use by someone else is required.

4.2.1   Provide Document Tracking

       In Region I, users request documents from the central files that were never incorporated into
the central files.  Time is spent trying  to locate these  documents.  To alleviate this problem, the
central records manager wants to number and inventory all documents and create an on-line index.
This will indicate what documents are in  the central files, allowing users to make more informed
requests.

       Region IV currently uses an automated indexing/check-in/check-out system and believes it
has improved their records management. They want to upgrade the current system to include more
information (keywords).

       There is a sign-out system for the  product registration jackets maintained by the Office of
Pesticide Programs (OPP), but often  it is not used  and significant time is spent trying to locate
specific jackets.  To address this problem, OPP wants an automated method of tracking the flow of
documents so that they are easy to locate.

       The Office of Toxic Substances must perform an annual  audit of all Premanufacturing
Notification documents they receive.  They require an automated document storage and retrieval
system that will both  support and simplify this process.
                                            4-6

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       The Pesticides and Toxics Litigation Division of the Office of General Counsel (OGC) collects
such vast quantities of information during the course of litigation that it is difficult for them to keep
track of what they have.  OGC wants a system to track and store all the information they receive, so
they know what information they have received and can make more effective use of it.   p (    ,

4.2.2  Minimize Retrieval Time

       Retrieval time is variable across the Agency,  but most offices and regions want to decrease
time spent retrieving  documents.

       Retrieval time for paper files depends on the location and organization of those files, the
quantity  of paper being  retrieved,  the  quality and training of  the staff retrieving and  filing
documents, and the number of requests  at any given time.  Often, inactive files are stored at a
different location than active files, so retrieving them takes more time.

       To support litigation,  records from  multiple offices  and organizations may need  to  be
retrieved quickly. Contract negotiation records, detailed financial records documenting charges for
site remediation, and backup documentation maintained by contractors may be necessary to support
an enforcement action.

       Formal requests for information, including Freedom of Information Act (FOIA)  requests,
have been increasing.  Regions and  offices  believe that excessive staff  time is spent collecting
information and responding to requests.  One reason cited was that large volumes  of paper are
frequently needed for FOIA responses and are difficult to retrieve.

       The Procurement and Contracts Management Division staff manually locates and  retrieves
documents necessary to respond to FOIA requests.  This is a time consuming, labor intensive process.
In addition, individuals often store active contract folders in their work areas  to minimize retrieval
time since on average, a person refers to the active folders assigned to them three to five times a day.
Time spent retrieving  folders stored in their own well-organized desk would average 15 seconds while
going to the centrally  located file room, locating records, and then returning to their office requires
ten to fifteen minutes.

       In Region V,  it is  possible to retrieve a document from the central  files in  two to  three
minutes, which is adequate.  However,  not all documents can  be retrieved this quickly.   The
Superfund records manager felt users had little confidence that documents could consistently be
found within a few minutes. Region V does not necessarily want to speed up document retrieval, but
rather to ensure that documents are consistently retrieved within a reasonable timeframe.
                                            4-7

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       Three of the regions use commercial or warehouse storage for documents. Region V uses
commercial storage facilities for less active documents.  They have approximately 1,800 linear feet
of documents in commercial storage.  In an average week 20 boxes of documents are retrieved from
this facility. The storage facility promises 24-hour retrieval time, which means that 24 hours after
information is requested they receive the boxes which contain the documents.

       Document retrieval requests  to the Office of Toxic Substances Toxic Chemical Release
Inventory staff currently average approximately 800 per week and are expected to increase.  Much
of the information is retrieved for quality assurance, legal, or FOIA purposes.  With this volume of
documents, the retrieval process becomes time-consuming and labor intensive.

       The  National  Enforcement Investigations Center indicates  that the ability to perform
automated text searches of documents to identify what to retrieve has been successful on a pilot basis
and would be  a desired capability. In addition, the Office of Toxic Substances is investigating an
automated storage and retrieval system  and would like the  ability to perform text searches to
minimize their document retrieval  time.

       The  Pesticides and Toxic Substances Litigation  Division of  the Office of General Counsel
(OGC) wants the ability to perform a text search, in order to support their retrieval needs.  OGC
wants to scan and store documents,  then later determine which documents to retrieve  based  on
whether  a specific word or term is contained in the text of the document.

4.2.3  Provide Access at a Convenient Location

       The physical location of a central document storage and retrieval facility must be convenient
to users.

       When selecting a location for document storage, convenience of the location is considered,
but cannot always be achieved. Factors which weigh heavily in determining the location of storage
facilities are cost and the availability of adequate  floor  space.

       In Region I,  most Remedial Project Managers find documentation in the records center easily
accessible, but attorneys find that being in a separate building from the central records center
hampers  document accessibility. The effect of limited access  has resulted in the attorneys holding
original documents  for extended periods of time.
                                            4-8

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4.2.4  Allow After-Hours Access

       After-hours access of documents from the central storage facility is required.

       Paper record-keeping requires staff to file and retrieve documents to fulfill user requests and
to control access to confidential information. This means staff must be present at all times that access
is allowed; therefore, access times are restricted. There is a growing need for access after regular
hours, which may be fueled by increasing Superfund cost recovery efforts.

       In Region V, retrieval requests are received for retrieval on  weekends and  after hours.
Region V wants a system that is operational virtually 24 hours a day, seven days a week, that does
not need attention other than during regular business hours or when problems arise.

       The Region VII Superfund records manager thinks authorized staff members should be able
to access centrally maintained records during nights, weekends, and holidays to the maximum degree
feasible.

4.2.5  Support Simultaneous Access

       Simultaneous access of documents is required.

       The ability for many people to access documents at the same time must be provided. In many
program offices, when one person  has records checked out and another needs access to those records,
time is spent locating the records and making duplicate copies of the document. The time involved
and cost of producing the duplicate copy are obvious, but the hidden costs of maintaining duplicate
documents which may contain confidential information and the questionable integrity  of multiple,
possibly unmaintained copies must also be considered.

       In Region V, simultaneous access to a document is needed periodically.  The Superfund
records  manager indicated that the ability for 12 persons to access a record simultaneously  is
adequate.

       The Region VII Superfund records manager said up to  three people may need access to the
same document at one time. Region VII wants to ensure that  document review can be performed
without unduly restricting access to the records.

       Region VIII has not experienced much need for simultaneous access: this  occurs only three
or four times in a six month period. However, they expect this need to increase as they incorporate
more current documents into the central files.
                                            4-9

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       The Office of General Counsel (OGC) requires simultaneous access to a single document by
several people on a daily basis.  For many of the activities of OGC, project teams are formed and all
members of the team need copies of the same document. For example, in Pesticides and Toxic
Substances Litigation, the litigation team requires simultaneous access to a document by several
people.  OGC regulatory review-teams also have the same requirement. Generally between five and
twenty people can require access to the same Premanufacturing Notification case file at one time.

       The Office of Pesticides and Toxic Substances has several applications for which simultaneous
access to a single document by several people in different geographic locations is required.  For
example, there is a lot of "competition" for Office  of Pesticide Programs product registration jackets.
And there is often a need for several people to review the same submission document for the Office
of Toxic Substances Toxic Chemical Release Inventory.  Generally, between five and twenty people
may require access to the same Premanufacturing Notification case file at one  time.

       Some program offices and regions are not sure if simultaneous access is needed or indicate
it is unnecessary.  Some, like  Region II, believe it would be beneficial,  but have no documented
knowledge of conflicts for document access.

4.3     PROVIDE AUTOMATED RECORDS MANAGEMENT

       Records management  is currently very labor intensive, time-consuming,  and should be
automated.

       In the regions, the amount of time spent by Remedial Project Managers (RPMs) and attorneys
to manage records is significant. RPMs usually maintain the current active site files at their desk or
work area.   They file,  retrieve, and  track  document locations,  and  in some cases schedule
appointments for document viewing.  Attorneys review documents which contain confidential
information  to determine what information can be released to the public.

       In Region VII, RPMs  and attorneys spend two to  eight hours per week on clerical tasks
associated with records  management.  There is  little use  of clericaLstaff for filing, retrieving,
tracking, or refiling of Superfund documents. The RPMs and attorneys expressed dissatisfaction with
the  amount of time they had to spend on records management.

       In Region  VIII, file users devote 5 to 20 percent of their time to records management.  The
primary users are RPMs and attorneys, who indicated this is too much time to devote to records
management.
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       At Headquarters, all incoming documents must be individually reviewed in the Pesticides and
Toxic Substances Division of the Office of General Counsel (OGC). Not including litigation, it is
estimated that the office processes an average of 1,900 to 2,800 pages per day.  During litigation, the
volume of incoming documents increases.  Once reviewed, many of the documents are never used
again simply because it is so time-consuming to keep track of them. OGC cannot take advantage of
all the information received because it is too labor intensive to sort out the useful documents.

       The Headquarters Operations and Client Services Division (HOCSD) processes and maintains
paperwork on each of the nearly 6,000 EPA Headquarters employees.  Because HOCSD "is a paper
factory* dealing with large volumes of documents, they indicated a need for an automated records
management system to support their basic file storage and retrieval needs.

4.4    PROVIDE DATA SECURITY

       Data security is a universal requirement

       The EPA's security  policy focuses  on three objectives:  confidentiality, integrity, and
availability of data.  Data confidentiality is ensured when sensitive information is protected from
disclosure.  The data integrity objective is  attained if the quality of the data is protected  from
corruption. Data availability focuses on preventing data loss and ensuring data is available to users.

4.4.1  Ensure Data Availability

       Data availability is required.

4.4.1.1      Minimize Lost. Misplaced, or Misfiled Records

       The frequency of lost, misplaced, or mis filed records must be reduced.

       Currently, documents are frequently lost, misplaced, or misfiled. The information contained
in the Superfund site files must be available for retrieval by a variety of users, who include Remedial
Project Managers, attorneys, interested citizens, and college students.

       The three main reasons for lost, misplaced, or misfiled documents are: unfiled records because
staff cannot keep pace with the large volume of records; inadequate control procedures, resulting in
the loss of records from the official files; and, even in offices with satisfactory control procedures,
files are sometimes misfiled or misplaced because of the high volumes of documents processed.
                                            4-11

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       At the Office of Pesticide Programs,  approximately 15  to  20 percent of the product
registration jackets can not be located when needed. This occurs because the procedures for checking
out the jackets are often not followed and because it is difficult to track who is using a jacket.

       About ten percent of the time, contract documents at the Procurement and Contract Division
(PCMD) cannot be found, even though there are check-out procedures in place for the PCMD file
room.  Some contract documents are checked out and kept by contract specialists for several years.
In these circumstances, documents are sometimes misplaced by the contract  specialist. Sometimes,
the contract specialist leaves the organization  without returning the contract file to the file room.

       A  study of Region VIII records management showed that five to ten percent of attempted
document retrievals cannot be accomplished because the document is missing from the site file.

       In Region VII, established procedures for borrowing documents are not enforced. Documents
are misplaced or lost in a variety of ways: storage units are left unlocked; the file room doors are left
open when the room is unattended; borrowed documents are not signed out; and the file contents are
not intact when returned.

       Misplaced or lost records can prevent regions and offices from responding to requests for
information,  providing records needed for  audits  by the Inspector General and the General
Accounting Office, providing records for litigation, and from performing activities integral to the
Agency.

4.4.2   Maintain Data Integrity

       Data integrity is required.

       Users specifically requested high-quality, readable images on a durable storage medium.

       In addition, the integrity of the data in Superfund site files must be ensured. These files are
retrieved for a variety of uses such as  determining what actions to take on a site, making decisions
on removal procedures at a site, litigation, FOIA responses, and research. Users must be certain that
the data has not been tampered with and is current.
                                            4-12

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4.4.2.1     Provide Hieh-Qualitv. Readable Image

       A high-quality, readable image is important for the integrity of documents.

       Because the Agency's documents are used for decisions and litigation, it is important that all
pertinent information be available. If a document cannot be read, it cannot be used.  Documents that
are unclear may be misread.

        Time affects the readability of all documents.  Other controllable factors can influence
document readability.  For example, working documents used at desks and work areas are subject to
smudges, stains, and fading from exposure to sunlight, which can render them unreadable.  If an
original document (rather than a copy) is used as a working document, information may be lost.

       Storage  conditions,  such as temperature and humidity,  influence the readable life of
documents. No carbon required (NCR) copies and heat-sensitive paper used in duplicating machines
and printers tend to fade quickly. Any paper document can mildew or fade and film media may
fade.

       The Office of Pesticide Programs (OPP) maintains product registration jackets which contain
all official documents for a specific registered product. These documents, particularly the product
label, contain unstructured information which  is generally numbers and text.  OPP wants high
resolution for storing images of the product labels.

       Readability of documents is a primary requirement of the Office of General Counsel (OGC).
OGC is concerned that some documents which are second or third generation copies may not be easily
read.  Since the documents contain text, diagrams, and handwriting, readability must be ensured.

4.4.2.2     Provide Durable Storage Media

       Durable storage media are required so that documents can be maintained for the lengths of
time specified by law.

       Different types of documents must be maintained for different lengths of time, from one
month to permanently, as set forth in the EPA document disposition schedules.

       At Headquarters, the  Procurement and  Contracts  Management Division maintains all
unsuccessful proposals for seven years. All contract information is on-site while active, which can
be from three to ten years, and then is stored off-site after the contract is closed out.  Closed-out
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non-Superfund documents are retained off-site for six years while closed-out Superfund contract
information is maintained on-site for ten years.

       The Superfund Administrative Records must be maintained in the region for up to 20 years
after cost recovery action is complete. While stored in the region, documents are not kept under ideal
archival conditions.  They are subject to damage from handling and are stored in environments where
temperature and humidity are not controlled to archival standards. After the regional storage, the
documents are archived  for permanent storage.

       Region VII has made few efforts to arrange for appropriate conditions for long-term storage
nf semiactive records  regarding temperature and humidity controls.

       Region VIII maintains Superfund site files in the regional offices for two years after cost
recovery,  then at the Federal Records Center for the next 20 years, and finally the documents are
transferred to the National Archives and Records Administration for permanent storage.

       The National Enforcement Investigations Center, The Contract Laboratory Program, and the
Office of  Toxic Substances Toxic Chemical  Release  Inventory must retain  their  documents
indefinitely.  The bulk of these documents are stored off-site because the on-site storage facilities
are insufficient to handle large volumes of documents for an indefinite period of time.

4.4.3   Ensure Data Confidentiality

       The ability to  ensure confidentiality of portions  of documents and  of entire documents is
required.

       Confidential information  at the EPA can  include:  enforcement  sensitive information,
contract-related information, confidential business information, employee-related information,
attorney work products, and attorney-client privileged materials. Confidential information contained
in documents must  be protected from the time of document creation or receipt, throughout the
storage life, until final document disposition is complete.

4.4.3.1     Support Confidential Processing Procedures

       Document processing  procedures  must  address the  issue  of security  of confidential
information during the time documents are being prepared for storage and while they are stored.

       Region I and Region VII Superfund records management personnel express concern that they
are unaware of any comprehensive guidelines specifying  what  information is confidential.  Region
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I creates redacted copies of confidential documents, which have the confidential information blocked
out, and maintains both the original and redacted versions. If "confidential" only appears on the first
page of a document, there is confusion about what information within the document is confidential
and should be redacted. Comprehensive guidelines from Headquarters regarding Superfund site file
confidentiality are desired.

       Many program offices process confidential information. For example, the Office of General
Counsel, the Office of Pesticide Programs, the Office of Toxic Substances, the Office of Solid Waste
and Emergency Response, the Procurement and Contracts Management Division, the Headquarters
Accounting Operations Branch, the Headquarters Operations and Client Services Division, and the
National Enforcement and Investigations Center all process confidential information.  Any storage
and  retrieval -system  and storage  medium used  for  Agency applications must  support special
processing requirements needed to maintain the confidentiality of information.

4.4.3.2     Control Access  to Confidential Information

       Access to confidential information must be controlled.

       Preventing unauthorized access to documents containing confidential information is a common
concern.

       At the Procurement and Contract Management Division (PCMD), many of the records contain
confidential business information or pre-award procurement information which could result in non-
competitive procurement if divulged. Therefore, only members of the  PCMD staff are authorized
to access the records. Although locked doors with card entry and locked file storage equipment are
used; records may be left unsecured at times on top of desks,  unfiled  in the file room, and in
unlocked file cabinets during working and non-working hours. Most of these problems are due to
difficulty  in managing the large volume of records.

       In  the regions, only some Superfund documents are confidential. Region VIII estimates that
up to 50 percent of a Superfund site file may be classified as confidential.  In Region VII, some files
that contain confidential information are left on desk tops or in unlocked drawers.  Region VII also
indicates that documents containing confidential information are  not always stored separately from
the rest of the other documents in the files.

       Multiple levels of control are needed to manage confidential data.  For public access, entire
documents or  only portions of documents which include  some confidential data must be made
available.  Documents which are primarily confidential, and to which public access is not allowed,
must also be managed.
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        Headquarters Operations and Client Services Division, Headquarters Accounting Operations
 Branch, and  the Procurement and Contracts Management Division control access to confidential
 information by maintaining them in a secure area and restricting access to only authorized personnel.
 In these as well as other offices working with confidential information, the ability to redact certain
 parts of documents before sending them outside of the office is an important requirement.

        The Office  of Toxic Substances (OTS) Premanufacturing Notification (PMN) program has
 Confidential Business Information (CBI).  Virtually all of the PMN documents submitted to OTS
 contain CBI, which must be protected as required by TSCA CBI procedures.

 4.5     INTEGRATE EXISTING SYSTEMS

        An automated records management system using any type of storage medium must integrate
 with users* existing systems.

        Currently, documents are stored on paper and microform. In  some cases, indexes to the
 documents are stored on a mainframe system. Several Headquarters users indicated that an automated
 records management system using any type of storage medium must be able to be used in conjunction
 with existing systems, without requiring the conversion of these existing systems to the new medium.

       The  Office of Pesticide Programs (OPP) supports several document indexing systems on the
 IBM mainframe.  Rather than "reinventing the wheel," OPP wants a storage and retrieval system
 capable of integrating with their existing ADABAS indexing systems. OPP also wants software that
 does not  require customization and wants the  ability  to use EPA standard local area network
 architecture.

       The Headquarters Accounting Operations Branch (HAOB) provides financial and operational
 support to all Headquarters offices and payroll services for the entire Agency.  They currently use
 several  automated  systems:    the  Integrated  Financial  Management  System,  the EPAYS
 Personnel/Payroll System, and the Time and Attendance Personnel Payroll System. HAOB wants an
 automated time card system, as well as a travel voucher and commercial pay system, to be integrated
 with their existing automated systems.

       The Office of Toxic Substances (OTS) Toxic Chemical Release  Inventory utilizes an IBM
mainframe data base to store information extracted from incoming documents.  Currently, data is
entered into .a PC tracking system, written to a magnetic tape, and loaded  to the mainframe. The
mainframe data base application is used to generate error notifications to submitters, who must return
the corrected information to OTS. Although this data base contains only several years of data, the
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 ability to integrate an automated document storage and retrieval system with the existing system
 should be available.

 4.6    SUPPORT CONVERSION OF EXISTING MEDIA

        A new storage medium must support the conversion of existing documents or media to the
 new medium.

        Currently, documents are stored on paper and microform. In those cases where the users
 would  like  to completely convert their existing  documents or application,  conversion of these
 documents and applications to a  new medium must be supported.

        For  the regional site files, this conversion must be structured to store all documents related
 to a particular site on one medium. For some Headquarters applications, documents are currently
 stored on several types of media and complete  conversion to a new medium, if desired, must be
 supported.

        The Office of Toxic Substances converts Premanufacturing Notification documents submitted
 under the Toxic Substances Control Act to microfiche. They currently receive and generate over
 40,000 document pages per month which  need to be converted and they expect this number  to
 increase. In addition, there is a backlog of over  600,000 pages. They currently can convert 34,000
 pages to microfiche per month, but want the ability to process at least 60,000  pages per month.

 4.7     STANDARDIZE FILE CONTENTS

        Files should contain only relevant, useful information.

        Documents which are needlessly maintained waste storage space. Files should contain only
 information which is useful or meaningful for decisions, litigation proceedings, and other uses
 deemed necessary by the Agency.

        In Region  VII, Superfund site files contain all site-related documents, even  if trivial or
 redundant. The regions have specific questions about the need to retain draft documents that have
 been superseded, duplicate copies of final documents that have been annotated, unvalidated data,
 phone memos, and notes from conversations.

       Current guidelines specifying what information to retain in the Superfund site files and
 Administrative Record are broad, leaving many decisions to the regions. Some regions expressed a
desire for more specific guidelines from Headquarters.
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4.8    ORGANIZE DOCUMENTS

       Organization of existing and future documents to support indexing and retrieval is required.

       Although ail interviewees agreed that documents must be organized and that the organization
method employed should be flexible enough to handle future needs, there was controversy regarding
how this should be accomplished.

       A system which mirrors the current paper filing system was requested and would be the
easiest to implement since it is a known, currently used system. Although there were exceptions,
most offices and regions organized  the files within each program in a consistent manner.  Among
different programs, however, there was no consistency.

       The Procurement and Contracts Management Division (PCMD) wants a system to organize
and access their documents by using keywords such as contract number, modification number, and
site name. This type of indexing will support PCMD's current way of doing business, quick access,
and keyword searches.

       Both the EPA Headquarters Operations and  Client Services Division (HOSCD) and the
Headquarters Accounting Operations Branch  (HAOB) want to continue  to organize their  files by
social security number. Currently, the Official Personnel Folders are indexed and located by social
security number while HAOB's time cards are indexed by social securityiuimber, fiscal year, and pay
period.  The personnel payroll information shared by HOSCD and HAOB is currently organized by
social security number.

       A standard file structure and standard document management procedures are requested by
some regions for the Superfund regional site files.

       The easiest system to implement is not necessarily the best system. Over the long term, the
most benefits will be gained from the organization which is easiest to use. The most useful method
of organization, the benefits, and the tradeoffs of uniform standards must be evaluated.

4.9    SUPPORT UPDATE OF RECORDS

       Fast, easy, and timely update of records is a universal requirement.

       A problem noted in Region III, where paper record keeping is used, is that updates to the
official files may be delayed several months. Region V processes an average of 3,500 document pages
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per day for storage, which is approximately 73,500 documents per month.  Users receiving outdated
information because files aren't updated in a timely manner lose confidence in the official files.

       The Headquarters Operations and Client Services  Division updates position descriptions
annually and the.Official Personnel Folders (OPFs) as needed, sometimes on a daily basis. Generally
documents are added to the OFF; however, if a document contains errors, the document itself will
be corrected.

       Both the Office of Toxic Substances and the National Enforcement Investigations Center
require the ability to add documents as they arrive; however, they do not require the ability to edit
or annotate existing documents.

       The Procurement and Contracts Management Division may infrequently require the ability
to modify some preaward documents but once a contract is awarded, no contract documents may be
modified.  Additional documents are, however, added to the contract file as they are received or
generated.

4.10   PROVIDE BACKUP CAPABILITIES

       The ability to backup data must be provided.

       Any storage medium  is subject to damage and/or loss from disasters, such as fire. A secure,
up-to-date, off-site backup  copy of all documents is important.

       Region VII wants to  ensure that critical regional Superfund site documents are adequately
backed up. Currently most records are not systematically backed up.

       At the Procurement and Contract Management Division,  there is no backup copy of many
records.  PCMD indicated that critical sections of their files can  be reconstructed for litigation  by
obtaining documents from various offices within the Agency. This may be sufficient for an isolated
case of a lost record, but may be inadequate if a major disaster were to occur.

       The Headquarters Operations and Client Services Division is concerned that there are  no
backup procedures for its documents, because of the significant loss if documents are damaged  or
destroyed. Although some of the information could be obtained from other offices, there would  be
no way to completely recreate these files; except by relying  on copies, where available, maintained
by each employee. It is also important to note that all OPFs are kept in the same file room, increasing
the chances for all documents to be destroyed if a disaster should occur.
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       Many offices, such as PCMD and OGC, have a requirement to maintain documents that are
used in court cases.  The loss of information from such documents could affect legal proceedings.

       Some offices specifically identified document backup as a requirement; while in other offices,
because no apparent document backup procedures are in effect, one might assume that a backup
capability is important.

4.11   SUPPORT LEGAL ADMISSIBILITY

       Legal admissibility of the records must be unquestioned,

       Interviews universally indicated that documents  must be  legally admissible.  For example,
Superfund and Contract Laboratory Program documents  are often used to support enforcement and
cost recovery actions.  National Enforcement Investigations Center, Office of General Counsel, and
Procurement and Contracts Management Division documents may also be used in litigation.

       Paper and microform records are currently used and both are legally admissible.   When
microform was being considered for use in the Procurement and Contracts Management Division, the
legality of microform records was questioned.  At that time, a legal decision was obtained from the
Office of General Counsel, which confirmed the legality of microform  records and set usage
guidelines. These usage guidelines addressed the creation of microform records and the destruction
of the original documents.

       Although  microform is considered legally  admissible, some attorneys feel that original
documents must be available for litigation. This is an issue that has been debated for many years and
may remain an issue for years to come.

       The Business Records Act provides for admission of records created in the  regular course of
business by stating:

           If any business, institution, member of a profession or calling, or any department
       or agency of government, in the regular course  of business or activity has kept or
       recorded any memorandum, writing, entry, print, representation, or combination
       thereof, of any act, transaction, occurrence, or event, and in the regular  course of
       business has caused any or all of the same to be recorded, copied, or reproduced by
       any  ... process which accurately reproduces or forms a durable medium for so
       reproducing the original, the original may be destroyed in the regular course of
       business unless its preservation  is required by law.   Such reproduction,  when
       satisfactorily identified, is as admissible in evidence as the original in any judicial or
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       administrative proceeding whether the original is in existence or not....

       The Federal Rule of Evidence 803(6) describes a record of regularly conducted activity.

           Records of regularly conducted activity.  A memorandum, report, record,  or
       data compilation, in any form, of acts,  events, conditions, opinions, or diagnoses,
       made at or near the time by, or from information transmitted by, a person  with
       knowledge, if kept in the course of a regularly conducted business activity, and if it
       was the regular practice of that business activity to make a  memorandum, report,
       record, or data compilation, all as shown by the testimony of the custodian or other
       qualified witness, unless the source of the information or the method or circumstances
       of preparation indicate lack of trustworthiness.

       If a new storage medium is selected, the EPA must obtain a  decision about its legality and
establish usage guidelines.

4.12   GENERATE PAPER COPY

       The ability to produce a paper copy of the document must be available.

       There was universal agreement from the offices and regions that the ability to produce paper
copies must be provided. The most frequently cited reason was to be able to respond to information
requests (FOIA and other).

       Region V wants to keep approximately 1,000 linear feet of very active documents in paper
form, to make them available for check-out. Region I wants the ability to obtain paper copies of any
of their documents.

       Another use of paper copies is to provide  a required copy at or near a Superfund site.
Although microform can normally be used for this purpose since libraries all over the country usually
have microform readers, paper is  sometimes required.  Paper copies  can be transported to any
location and no special equipment is required to read paper copies.

       The Office of  Toxic  Substances Toxic Chemical Release Inventory wants the ability to
produce a printed copy of any of their documents.

       The Procurement and Contracts Management Division responds to many FOIA requests and
would like the ability to generate a paper copy of their documents.
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       The Office of General Counsel (including the Pesticides and Toxic Substances Litigation
 Division) does not require original documents, simply the ability to generate printed images of the
 documents as needed.

 4.13   ENSURE COST-EFFECTIVENESS

       Any automated storage and retrieval system must be cost-effective.

       Many users emphasize the need for a cost-effective records management solution. Although
 they  are  faced  with storage, retrieval, and  processing burdens, users are concerned that any
 automated system would be more costly than they could afford,  given limited resources.  Several
 asked whether  resources would be available to support acquisition  of  an automated  records
 management system.

       The Office of General Counsel (including the Pesticide  and Toxic Substances Litigation
 Division) indicates that an automated storage and retrieval system would be a viable solution to their
 records management problems, however it must be cost-effective. They think any automated systems
 currently available are too labor  intensive and costly to implement.

       The Office of Pesticide Programs wants an automated system capable of quick, simultaneous
 multi-user access from  standard workstations and which could be integrated with their existing
 systems.  However, it must be affordable and  cost-effective.

       The Headquarters Operations and Client Services Division strongly stated its need for an
 automated records management system and asked whether resources would be available to them for
 the acquisition of an automated storage and retrieval system.

 4.14   EXCHANGE INFORMATION

       An automated storage and retrieval system must support the exchange of information, either
 locally or to remote sites.

       A number of users indicate that the ability to exchange information, either on a local area
 network or to remote locations, is critical to their operations.

       The Headquarters Accounting Operations Branch provides payroll services for the entire
Agency.  These services include the processing of time and attendance information and processing
payroll information.  Currently, the ten EPA regional offices, the Research Triangle Park offices.
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and offices in Las Vegas and Cincinnati send time and attendance information to Headquarters for
processing.

       The remaining Agency financial processing requires the exchange of information from remote
locations.  The Financial Management Office (FMO) in Research Triangle Park performs financial
processing  for  all Agency contracts and receives information  from  the  ten  regional  offices,
Headquarters, Las Vegas, and Cincinnati.  The Cincinnati office processes all Agency Interoffice
Agreements and receives information from the other 13 FMOs.

       The Office of Pesticide Programs exchanges information between Waterside Mall, a contractor
site, and offices in Crystal City.  In addition, within  the Crystal  City building, they require the
ability to exchange information using a local area network.

       The National  Enforcement Investigations Center (NEIC) indicates that an automated storage
and retrieval system would be most effective if they could share information with the EPA regional
offices.

       The regions indicate there was little information exchange among regions for Superfund site
files, although information exchange within a region may be important and is not  always  possible
currently. For personnel, payroll, and NEIC applications, it appears that an automated storage and
retrieval system  should support information exchange.  There are  probably other applications not
identified in this study for which regional information exchange is required.
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                   SECTION 5 - STATEMENT OF TECHNICAL OPTIONS

       The technologies considered for document storage are microform and optical disk.  These are
considered optical storage media because they store miniaturized pictures or images of documents.
Microforms include microfilm and microfiche. Optical disks include CD-ROM and WORM disks.

       These optical media are appropriate for storage of documents which contain handwriting,
drawings, and other information which  could not be easily reproduced  by  typing  text into a
computer. Storage and subsequent retrieval of information contained on optical media requires the
use of specialized equipment.

       These technologies are described, in detail, below.

5.1    MICROFORM

       Microforms store photographic images on rolled or flat card film.  Microforms are similar
media that include microfilm and microfiche.  Microfilm stores images on a roll of film; microfiche
stores images on a flat film card.

       Microforms have been in use for years.  The first microphotograph was produced in  1853.
Since that time, microforms have evolved and are now used on a daily basis in many types of
businesses and industries.  People all over the country are familiar with this technology.

       Microforms are easy to copy and mail. Therefore, they are an easy and efficient method of
providing information to users that are not located in the immediate area, as long as they have access
to a reader. Most public libraries throughout the country have  at least one microfilm 6r)microfiche
reader available for public use.

5.1.1   Microfilm

       Microfilm is available in several formats. The most popular film widths are 16mm and 35mm.
Film is also available in(7^rnm and 105mm widths.  All film widths can be mounted on an open reel,
and the 16mm and  35mm  widths can also be contained in cartridges or cassettes.  Cartridges and
cassettes are used to provide protection for the film and make it easier to handle. Some cameras use
the cassettes for undeveloped film;  for others open reel film must be used.

       Training is required to process microfilm, even for highly automated systems.  Documents
must be prepared and photographed, then processing involves developing and duplicating the film.
It may also involve  loading cartridges, cassettes, or microfilm jackets, and indexing.
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5.1.1.1     Preparation

       The first step in creating microfilm is document preparation.
       Microfilming documents before they have been handled extensively can result in faster and
easier preparation, and a better microfilm image. The easiest documents to film are those that have
a high contrast level between the background and printed information.

       The amount of handling a document has experienced before being photographed can affect
the quality of the  microfilm image. Tears, stains, and other damage related to document handling
can be just as obvious on the film image as they are on the original document. Repairs should be
made, if possible, before filming.

       The contrast level of a document can also affect the quality of the microfilm image.  Faded
documents or documents with a colored background and/or nonblack ink may require special
techniques to be used during photography; sometimes, a good image cannot be obtained.

       To redact (block out) confidential information on a document, a paper copy of the document
must be made.  The copy is then altered by inking out or covering  the confidential information
before photographing.

       Documents are easiest to process when batched or grouped.  Once batched, all staples, clips,
and bindings must be removed from the documents.

5.1.1.2     Creation

       Each page of a document is  photographed, in  sequence, onto microfilm.   Remaining
documents in the batch are processed, also in sequence. If microfilm cassettes are used, they may be
removed before they are full and reinserted at a later time.  This  allows related documents to be
stored on  the same roll of microfilm.

       If a nonredacted copy of a document that contains  confidential information is filmed, it
should be filmed onto  separate rolls of  microfilm  because of the lack of control over  what
information on a  roll of microfilm is accessed.

       After photographing is complete,  the documents must  be reassembled  and stored.  All
documents should be retained until the quality of the microfilm image is determined to be acceptable.

       Developing or processing the film.is usually an automated process which can be done in
normal room lighting. Output speeds of the processors vary considerably.
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       Developed microfilm of any size can be mounted on an open reel.  If 16mm or 35mm film
is used, it may be loaded into a cassette or cartridge, or cut into short strips and loaded into microfilm
jackets.

       Microfilm jackets are composed of two clear sheets of plastic separated into  16mm or 35mm
channels. Cut strips of microfilm are inserted into these channels.

       Often the "master" film produced from photographing the documents is retained on an open
reel and  stored as an archival copy that is not handled except for duplication.

5.1.1.3     Imaee Quality

       The image quality of microfilm will depend in  part on  the  type of  film used and its
properties. Over time, the image can deteriorate from the use and handling the film is subjected to.

       Three types of film used for microfilming are silver halide, diazo, and vesicular films.  Silver
halide film is used for source document filming and production of duplicates. Diazo and vesicular
films are used for making duplicate microfilms.

       Properties of the films used affect the clarity of the microimage. Qualities to consider are
film speed, resolving power, granularity, and density.

       Film speed is an indication of sensitivity to light. The higher the rating  number, the faster
the film, and the more sensitive it is to light. High  speed film is required for use in some types of
microfilming cameras because a short exposure time is necessary. This short exposure time can result
in a  microimage that is not equal in quality to the original source document because of a grainy
appearance and lack of detail.

       Resolving power refers to the ability to record fine detail. It is measured in terms of lines per
millimeter. The higher the resolving power, the more detailed the image that can be recorded on the
film. Films with a higher resolving power can produce  a superior microimage.

       Granularity is a measure of coarseness of the grain.  The higher the value of granularity, the
lower the quality of the microimage.  When a microimage is magnified for viewing or paper copy
production, it will appear more grainy.

       Density indicates the degree of contrast that can be produced. The  greater the density, the
greater the contrast and the  sharper the microimage. The perfect density for a master film used to
produce  copies may  be different from the ideal density  of a film for viewing and printing.
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       The image can be affected by use and handling of the microfilm.  Handling of film, for
viewing or duplication, causes deterioration. This is especially true for open reel microfilm, which
is  more subject to fingerprints and tears than film housed in a cartridge or cassette.   For any
microfilm, a tiny particle of dirt in a reader can cause marks across several images as the film is
scrolled.

5.1.1.4      Capacity

       The most common microfilms used are 16mm  or 35mm films  with a/simplex orientation.
Using the simplex mode, a single row of sequential images is created down the length of the film.

       Microfilm, for these applications, can store 2,500 - 3,000 images of 8.5 by 11 inch documents
per cassette or roll of film. The images are stored  in  the order they were photographed onto the
film.

5.1.1.5      Updatabilitv

       Because of its sequential nature, microfilm is not easily updatable.  This can make it hard to
work with, but also provides a security advantage  because it is relatively safe from unauthorized
insertions or changes.

       Outdated information contained on microfilm can be spliced out and insertions can be spliced
into a microfilm.  This is a time-consuming process and affects the durability of the film.

       Updatable microfilm has been developed, but its use  is normally restricted to microfiche.

       Microfilm jackets allow the records to be updated by simple removal/insertion of the cut
microfilm  strips.  The jackets are very time-consuming to  maintain, so typically only  a  master
microfilm  is maintained  in a jacket,  and the jacket  is not available for general use.  Instead,
microfiche is produced from the jacket and used for retrieval.

5.1.1.6      Duplication

       Once developed, the original microfilm becomes a "master" that can be copied. Microfilm of
any size can be duplicated to create another roll of microfilm.

       When film is duplicated, sharpness of  image is lost.  Sharpness of image is measured using
resolution chart patterns. Normally, with each  generation of duplication one resolution chart pattern
is  lost. This means that a film created by duplicating an original master film will lose one resolution
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chart pattern.  If this film is in turn used as a master, another resolution chart pattern will be lost.
For most applications, a film should not be used as a master past the fourth generation.

       When 105mm roll film is duplicated, the duplicate roll  is often cut into microfiche. The
16mm and 35mm  microfilm can be cut and inserted into microfilm jackets for use as a master for
creating microfiche.  Microfiche can be created from the jacket by using a suitable fiche-to-fiche
duplicator.

5.1.1.7     Storage

       Storage conditions affect the life of microfilm. This is one of the reasons separate archive
and working copies are kept of film that must be preserved.  The archive microfilm can be stored
under ideal conditions and not used for everyday retrieval.

       Standards exist for archiving microfilm, as established by the National Bureau of Standards.
Both microfilm and microfiche can be prepared to archival standards. The expected archival life of
properly developed and stored black and white film is over 100 years.  The National Archives and
Records Administration (NARA) has accepted microform for long-term storage.

       Storage conditions for archival film include  storage in  a clean well-ventilated  room with
filtered air. The temperature for black and white film must remain below 70 degrees Fahrenheit and
the humidity must be maintained between 30 and 40 percent.

       Dry process microfilm and other microfilm not produced or maintained to archival standards
will have a shorter useful life, averaging approximately 25 years.

5.1.1.8     Indexing

       Documents stored on microfilm can be indexed.

       This can be done by photographing a unique page number or code as part of the image of
each page.  An index  is then created linking the identifiers for the  microfilm and page to the
document name. The inclusion of bibliographic information and keywords (identifying the contents
and/or subject of the document) in the index can be helpful.

       Indexes are usually created and used on computers, which means the purchase of additional
hardware and software in  addition to the standard  microfilm equipment.  For  large document
collections,.automated indexes. if_wellhdeiigjied, can speed up identification and retrieval of
documents.
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5.1.1.9     Retrieval

       Microfilm is read by inserting the film or cassette in a reader and advancing to the desired
document.  Manual procedures are usually used to find the correct reel or cassette and place it in a
reader, perhaps aided by an automated index.

       With reel film, the film must be  manually threaded through the reader.  Cartridges or
cassettes, used with the appropriate microfilm readers, allow the microfilm to be viewed without the
microfilm being handled. After the cassette/cartridge  is placed in the reader, it is automatically
threaded.

       Document images are projected on a screen in front of the user. The user must progress
sequentially through the pages recorded on the film to locate the desired information. Given that up
to 3,000 images  may be stored on each cassette, it may take several minutes to reach the desired
document.  When finished, the microfilm must be rewound and refiled. If a cassette/cartridge system
is used, the film is automatically rewound.

       Microfilm does not allow multiple users to read the same document, or any other document
stored on the same film, at one time.  Multiple copies of the film can be made, but each person that
needs access must have a copy of the microfilm and a reader.

5.1.1.10    Paoer Copies

       Paper copies can be made from microfilm.

       Printers which are designed for this purpose are usually combined with the microfilm readers.
These printers often produce copies which fade over time, so recopying the original paper copy may
be necessary.

5.1.2  Microfiche

       Microfiche is a flat sheet or card of microfilm. It is available in various sizes, but the 148mm
by  105mm size (approximately 6 by 4 inches) is  the NaiionaLMicrognphics Association (NMA)
standard, which supersedes the Council on Scientific and Technical Information (COSATI) standard
that was mandatory for all Federal agencies.

       As  with microfilm,  training is required to process microfiche.  The most common methods
of producing microfiche are to prepare and photograph documents, duplicate microfilm jackets, or
duplicate an existing microfiche.
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 5.1.2.1      Preparation

        Preparation of microfiche is identical to the preparation of microfilm, described in Section
 5.1.1.1 of this document.

 5.1 22      Creation

       Creation of microfiche is identical to the creation of microfilm, described in
 Section 5.1.1.2 of this document.

 5.1.2.3      Image Quality

       The image quality of microfiche identical to that of microfilm, described in
 Section 5.1.1.3 of this document

 5.1.2.4
       Microfiche contains multiple images arranged in a grid pattern. For storage of 8.5 by 1 1 inch
documents, NMA standards call for a grid of 98 frames on a 148mm by 105mm fiche. Frames are
arranged in seven horizontal rows with 14 frames contained in each row.

       Larger documents can also be accommodated using a different grid format

5.1.2.5     Updatabilitv

       Standard microfiche cannot be updated.  This can make it hard to work with, but also
provides a security advantage because it is safe from unauthorized insertions or changes.

       A type of updatable microfiche has been developed, allowing new images to be added to
existing fiche. This is accomplished by exposing and processing one or more individual grid positions
on the "master," rather than the entire microfiche.

       Techniques are available that allow an existing image to be erased from the master film and
replaced with an updated image in the same physical location. A preferable technique is to void the
existing image and place the new image in an unused area of the master fiche. This method saves
the old image for audit trail and file integrity purposes.

       To void an old image, it must be marked to indicate that it has been superseded, but still
remain readable.  This is easily accomplished by manually placing a colored dot on the old image
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using a magic marker. When a user sees a marked image, they need to search through the following
images for the superseding image.

        When changes are frequent, or extensive, multiple microfiche may be needed to contain
updates.

5.1.2.6     Duplication

        Once developed, the original microfiche becomes a "master" that can be copied to produce
microfiche or continuous roll microfilm containing microfiche images.

        When film is duplicated, sharpness of image is lost. Sharpness of image is measured using
resolution chart patterns.  Normally, with each generation of duplication one resolution chart pattern
is lost.  This means that a film created by duplicating an original master film will lose one resolution
chart pattern.  If this film is in turn used as a master, another resolution chart pattern will be lost.
For most applications,  film should not be used as a master past the fourth generation.

        Continuous roll microfilm containing microfiche images can be duplicated to create another
roll of microfilm. This duplicate roll can then be cut into microfiche.

        Duplicate microfiche can be produced using a fiche-to-fiche duplicator.

        Microfiche can be created from a microfilm jacket by  using  a suitable fiche-to-fiche
duplicator.

        Individual microfiche can also be used to create 105mm continuous roll microfilm using a
fiche-to-roll duplicator.

5.1.2.7     Storage

        Storage conditions affecting the  life of microfiche are identical to those  for microfilm,
described in Section  5.1.1.7 of this document.

5.1.2.8     Indexing

        Documents stored on  microfiche can be indexed.

        An area at the top of each microfiche card is reserved for identification information. This
information is  printed in type large enough to read without magnification.  Title lines and fiche
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sequencing numbers may be placed in this area, which may be color-coded.

       NMA standards provide for a grid index of the contents of the microfiche.  Each row is
alphabetically identified from top to bottom, beginning with "A," and each column is numerically
identified from left to right, beginning with "1." The grid code can be photographed as part of the
image of each page.

       An index of the information contained on the microfiche, referencing the grid code, can be
placed on the microfiche itself. A user would select a fiche based on the identifying information at
the top of the fiche, then look at the index contained on the fiche  to determine which grid they wish
to view.  For small document collections, this may be sufficient.

       For larger document collections, a separate index can be  created linking the identifiers for
the microfiche and the grid location to  the  document  name.   The  inclusion of bibliographic
information and keywords (identifying the contents and/or subject of the document) in the index can
be helpful.   .

       Indexes are usually created and used on computers, which means the purchase of additional
hardware and software in addition to the standard microfiche  equipment.  For large document
collections, automated indexes, if well designed, can speed up identification and retrieval  of
documents.

5.1.2.9     Retrieval

       Microfiche is read by inserting the fiche into a reader and locating the desired document.
Manual procedures are used to find the correct microfiche and place it in the reader, perhaps aided
by an automated index.

       Microfiche readers are mechanically simpler than microfilm readers.  The microfiche is placed
between two horizontal glass plates in the reader. These glass plates can be moved by the user to pass
individual images stored on the microfiche over the light source, projecting them on the screen for
viewing.   When finished, the microfiche must be removed and refiled.

       Microfiche does not allow multiple users to read the same document, or any other document
stored on the same fiche, at one time.  Multiple copies of the fiche can be made,  but each person that
needs access must have a copy of the microfiche and a reader.
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5.1.2.10    Paper Copies

       Paper copies can be made from microfiche.

       Printers which are designed for this purpose are usually combined with the microfiche
readers. These printers often produce copies which fade over time, so recopying the original paper
copy may be necessary.

5.2    COMPUTER OUTPUT MICROFORM

       Computer output microfilming is defined by the National Micrographics Association (NMA)
as a method of converting data from a computer into human-readable language  on microfilm.

       The computer output can be produced on  microfilm without first being printed on paper.
Electronic machine-readable data is accepted as input to a computer output microform (COM) unit,
normally from magnetic tapes. The COM unit converts the data to human-readable information and
stores it on microfilm.

       COM units can produce microfilm in 16mm, 35mnu 70mm,  and 105mm widths, either as
continuous roll microfilm or microfiche. Some units can produce more than one width of film.  The
most widely produced COM formats are 16mm continuous roll microfilm that has been loaded into
cartridges  and microfiche.

       Several methods are used to create an image on microfilm, but more recent developments use
a laser beam to record information on dry silver film. Other systems use microfilm which requires
standard processing.

       Dry silver  film is developed with  heat right in the  COM  unit and requires no further
processing.  This type of film has a life  of approximately  25 years  when stored according to
standards.

       Unlike microfiche produced from  photographing source documents,  there is  no single
standard format for microfiche produced on  a COM unit. The grid index standards are the same for
microfiche produced using either method.

       The updatability, duplication, and storage of COM-produced microfilm or microfiche would
be the same as for microfilm or microfiche produced from photographing source documents.
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       COM units can incorporate indexing techniques during the creation of the microfilm or
microfiche.  Indexing techniques can be used for manual or automated retrieval systems. Common
methods used include index frames, flash targets, bar coding, blips, and optical coding.

       In addition to alphanumeric data, some COM units are capable  of producing business
graphics, which are graphic representations of statistical data.  This requires more sophisticated
hardware and software.

5.3    COMPUTER AIDED RETRIEVAL

       The term "computer aided" can be applied to a vast array of techniques for automating part
or all of the retrieval process.  Anything from a  simple, automated  index to  a sophisticated
videomicrographic enhancement system can be considered in this category.

       The goal of this technology is to speed up retrieval of information. The degree to which this
goal is accomplished is dependent on the level of technology selected and the design of the system.

       Computer aided retrieval is generally reserved for large document collections because of the
expense involved in automation. Generally, the more sophisticated and automated the system, the
more it will cost.  The more sophisticated microfilm systems can be as expensive as an optical disk
system.

5.3.1   Computerized Index

       For a simple system, an index code is developed to uniquely identify a roll of film or a fiche
and each image contained on the film.  This index code is filmed as part of each image on the  film.
       Information about each document is entered into a computerized data base for subsequent
reference. This information would include the index code, bibliographic information, and possible
keywords to identify the contents and/or subject of the document.

       To retrieve information stored on microform, a user would determine which roll or fiche they
wanted to view by inquiry  into the data base.  The film or fiche would be manually selected and
inserted into a reader.  The user would manually advance the film to the appropriate image.

       A more advanced system of this type that can be used with continuous roll film would use
microfilmers and readers that automatically encode the index mark onto the film or track the number
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of the image.  This allows the reader to automatically advance the film to the proper image for
viewing.

5.3.2   Automated Display Systems

       Automated microform display systems are available that consist of a microcomputer with a
film "juke box."  These programmed systems combine the advantages of a computerized index with
the ability to select, load, and display stored microform images based on selection information and
commands entered by the user, without the user ever handling the microform.

       For these systems, each user needs a complete microform juke box file, an intelligent
microimage terminal, and a CRT screen.

5.3.3   Vldeomlcrographlc Enhancement

       With videomicrographic enhancement, only one central microfilm juke box file is needed.
As  with automated display systems, the rolls of microfilm are selected and loaded by robotics
operating under computer control, based on selection information and commands entered by the user.

       The microfilm image  is presented to a charge coupled device (CCD) scanner which digitizes
it. This digitized image can be made available to any number of workstations attached to a local area
network (LAN).

5.4    OPTICAL DISK

       Optical disks store digitized images on disks made of various materials. Two types of optical
disks  that are available are compact disk/read-only memory (CD-ROM) and write once read many
times (WORM) disks. These two types of optical disks differ significantly in the way they are created
and in their ability to be updated. These differences represent a clear distinction between CD-ROM
and WORM.

       Optical  disks are  related to  compact disks (CDs),  which have become a popular  way of
recording  music.  Many people are  familiar with the plastic compact disks  with the mirror-like
surface and the compact disk players connected to stereo systems. Optical disks and drives (players)
are similar, but they are designed to work with computers.

       Optical disks have been available since the 1970s. Until recently, many available products
lacked promised capabilities.  Now, promises have matured into viable products.
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       Information can be stored on optical disk using either facsimile format or the American
Standard Code for Information Interchange (ASCII) format.  Using either format, information is
stored as digital data.

       Generally, when data is stored in fax format, what is stored are the sequences (coordinate
locations) of '0' (white or space) and '!' (black or line) bits of a character, much as coordinates on
a video screen are described for bit-mapping. Storing data in facsimile format, however, involves
storing the sequences of the '0' and T bits on optical disk. The facsimile format of storing data on
optical disk by specifying these sequences is what enables text, handwriting, diagrams, maps, photos,
and any other type of image to be stored.

       Data stored in facsimile format can be compressed into CCITT Group 3 and CCITT Group
4 formats. These formats define scan resolutions and a data compression algorithm for each format.
The CCITT Group 4 format is the most recent and uses a more efficient data compression algorithm
than CCITT Group  3 format.

       When data is stored in ASCII format, a single character is represented by 7 bits. This 7 bit
representation of a character requires less storage space than its comparable facsimile format sequence
representation.  However, there are only 128 ASCII characters, which means only 128 alphanumeric
and special characters can  be represented in ASCII.  For this reason, data storage in ASCII format
cannot support handwriting, diagrams, maps, photos, and other non-alphanumeric or special character
images.

       Optical disk storage is a significant technology that offers storagejcapacities jfar beyond those
available using any  other media.

5.4.1  CD-ROM Optical Disks

       Like CDs, CD-ROM disks are read-only disks with a multi-layered sandwich construction.
The  outside layers of a CD-ROM  disk are transparent plastic; inside,  there is a layer of reflective
material.

       Mastering and production guidelines exist for CD-ROM disks and a standard format has been
agreed upon by key vendors in the market. The existence of these standards allows information to
be read from the disk in the same way, regardless of the host computer or operating system.

       CD-ROM is most often used for storage and mass distribution of information that  doesn't
readily change, such as reference and bibliographic/index information. CD-ROM does not support
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on-going addition of information. Rather, it is a method of storing and distributing information that
is unlikely to change, for use by large numbers of people.

       Storing documents on a CD-ROM disk involves document conversion and/or preparation,
writing the prepared information to magnetic tape, creating a master disk from the magnetic tape,
and finally pressing the CD-ROM disks.  This mastering and duplication process takes several days
to complete.

5.4.1.1     Preparation

       Printed documents must be converted to electronic storage.  This can be accomplished by
keying in the data or scanning the documents.  Keying in or scanning documents  is easiest when a
clean, clear copy is provided that has a  high contrast level  between the  background and printed
information.

       To key in documents, they must be readable. Once the data is entered, it must be proofread
carefully. The type of data that is recorded is restricted by the type of information that can be keyed
in.

       For scanning, all staples, clips, and bindings must be removed from the documents. Tears,
stains, and other damage related to  document handling should be repaired,  if possible, before
scanning.

       One of the methods used to control access to confidential information in CD-ROM systems
involves storing two copies of the document, one redacted copy and one complete copy. When keying
in documents, a redacted  copy  can  be created by not entering  the confidential portions  of a
document.  For scanning, a redacted paper copy may be scanned, or processing  software may allow
redaction of a document as it is viewed on a  video screen after scanning.

       Documents stored electronically on magnetic tapes or floppy disks can be processed without
first being printed on paper, if the processing hardware is capable of reading  information stored on
the media.  This may save some preparation time.

       Documents need to  be formatted into a standard page format and organized for storage on
CD-ROM disks.  Index information must be  created for use in retrieving the information.

       Access to confidential information could be controlled by retrieval software; however, this
method,  used alone, does not  provide good  security. It would also be  necessary to ensure  that
retrieval is only  attempted on computer systems with the proper retrieval software. Information is
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stored on the disk in a standard format, allowing the disk to be read on any computer system with
the necessary hardware and software.

       A more secure method of controlling access to confidential information stored on a CD-
ROM disk is to store documents containing confidential information on separate disks and restrict
access to those disks.

       Once stored electronically, organized, and indexed, the documents are written to a magnetic
tape.  This tape is used for creation of the master disk.

5.4.1.2     Creation

       A CD-ROM disk is created by producing a master disk and then pressing copies, much as a
phonographic record is pressed. The creation of the master is an automated process which accepts
information contained on a magnetic tape for input. All information to be recorded on the master
disk, and subsequent copies, must be placed on the master disk  at one time. CD-ROM does not
support incremental  addition of information.  Once the CD-ROM disk is pressed, it  cannot  be
changed or added to.

       The developers of CD-ROM specified strict mastering and production guidelines.  A "High
Sierra" standard format was announced in 1987, when key vendors in the market agreed on standards
for the arrangement of information on the disk.

       Master disks are expensive to manufacture, costing several thousand dollars to produce. The
data preparation phase is usually the most expensive, costing tens  of thousands of dollars.  This cost
can vary considerably depending on the format, amount of standardization, and recording media of
the documents to be prepared.  The actual mastering process usually costs between two and four
thousand dollars.  After the master is produced, copies are relatively inexpensive.

       Pressing copies of the master disk  is also an automated  process.   This process records
information on the CD-ROM disk by creating pits in the reflective tracks.

5.4.1.3     Image Quality

       The quality of a facsimile image will depend on the number of dots per inch (dpi) recorded
by the scanning equipment and the number of dpi displayed by retrieval equipment.

       For facsimile data, the number of dpi recorded is a limiting factor in the quality of image that
can be displayed.  For this reason, users that  plan on upgrading their retrieval equipment in the
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future often scan at a higher dpi density than their current retrieval equipment will display.  This
provides the advantage of a higher quality image when the display equipment is upgraded.

       For information stored in the ASCII format, the number of dots per inch displayed by
retrieval equipment will be the most important determinant of the image quality.

       The fact that information is stored digitally is advantageous because the quality of the image
is maintained when duplicate disks are produced.  The data can be copied indefinitely with no
degradation of the image.

5.4.1,4     Capacity

       Large quantities of information can be placed on a CD-ROM disk, but a disk does not have
to be filled to capacity. Using ASCII format, standard 5.25 inch disk can store up to 600M bytes of
data, or 200,000  pages of documents (at 3,000 bytes per page). Using facsimile format, a standard
5.25 inch disk can  store about 8,5000 pages of documents (at 70,000 bytes per page).

5.4.1.5     Uodatabilitv

       To make  a change, a new master disk  must be created and new copies pressed. Master disks
and pressed copies cannot be updated.

       CD-ROM disks are pressed from a master disk; therefore, all information must be placed on
the master disk before copies are pressed. Disks cannot be incrementally updated to add information.
Once  a master disk is generated,  no alterations can be made.

5.4.1.6     Duplication

       CD-ROM disks are always produced by creating a master and then pressing copies from the
master.

       Although a pressed CD-ROM disk cannot be used as a master disk, it can be used to recreate
the master magnetic tape.  This  tape can then be used to create another master disk.

       The  production of a  master  disk is expensive, although pressing copies is  relatively
inexpensive.  This cost breakdown generally  makes CD-ROM unsuitable for small runs, but  cost-
effective for wide distributions of large volumes of information. Usually, at least one thousand CD-
ROM disks are pressed from each master disk.
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5.4.1.7     Storage

       CD-ROM disks can be stored in normal room conditions without detriment to the media.
They are unaffected by humidity, and will not mildew.  Reasonable temperatures are tolerated;
however, they should not be subjected to temperatures high enough to cause softening or melting of
the plastic layer.

       Electromagnetic damage experienced with magnetic storage media such as floppy diskettes
or hard Winchester disks is not a problem experienced with CD-ROM disks.

       CD-ROM disks last at least ten years.  Some manufacturers are projecting a 20-year life for
the disks.

5.4.1.8     Indexing

       During document preparation, index information is entered to facilitate retrieval. The types
of index information entered during document preparation  will affect the features that can be
provided by the retrieval software.

       Features that may be provided by the retrieval software include the capability to identify or
locate documents using bibliographic information, reference information, or keywords that identify
the contents and/or subject of the document.

5.4.1.9     Retrieval

       Software must be written or purchased to gain access  to information stored on a CD-ROM
disk. This software normally includes a user interface and retrieval capabilities.  The ease of use and
speed of retrieval will be affected by the software written or selected.

       To  view a document stored on a CD-ROM disk, a user  would go to a  microcomputer
workstation that either has a CD-ROM drive or is connected to a network with access to a CD-ROM
drive. Using the  retrieval software, the user would identify the document they want to view.

       If software is used to control access to confidential information stored on a CD-ROM system,
the user may be required to enter a password or some type of identification before they are allowed
to view the confidential document.

       Once the document is identified, the storage  location  is  known and the  drive can reach the
correct storage  point on the disk in a fraction of a second. The CD-ROM drive  uses a laser beam
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and light detector to retrieve information recorded on the disk. The document is then displayed for
the user.

       CD-ROM juke boxes  that hold multiple CD-ROM disks are available.  These juke boxes
select and robotically load disks into drives based on selection information entered by the user. Juke
boxes can be connected to a single workstation or a network.

       Since CD-ROM capabilities can be connected with a network, and multiple workstations can
use a network, multiple persons can access a disk, and even the same document, at the same time.
If dial-up access is allowed to the network, users at remote sites could view the documents.

5.4.1.10    Paper Copies

       Paper copies  can be produced  on printers connected to the workstation or network, if the
software allows this capability.

5.4.2  WORM Optical Disks

       WORM disks can be written once and read many times.  The entire disk does not need to be
written at  one time; information can be added  incrementally. This characteristic  is a primary
distinction between CD-ROM and WORM. With WORM, once information is written to a disk, it
cannot be erased or written over, however a changed version may be written to the disk. With CD-
ROM, users are unable to add any information to the disk.

       A WORM disk  consists of a three-layered sandwich and an airspace.  The outside layers are
either glass or plastic;  the inside layer is a reflective surface.  They are  available in sizes of 5.25
inches, 8 inches, 12 inches, and 14 inches.

       A major application for WORM technology is document storage. Electronic document storage
systems are being used to speed the flow of information in paper-intensive industries.  Since stored
data cannot be erased,  WORM is also  ideal  for archiving and backup purposes.

       Storing documents on a WORM disk involves converting printed documents to electronic
storage,  indexing, and  writing the information to the disk.
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5.4.2.1     Preparation

       Printed documents are scanned to convert them to electronic storage. Preparing documents
for scanning involves removing staples, clips, or bindings, and repairing any damage resulting from
document handling. Scanning documents is easiest when a clean and clear document is provided that
has a high contrast level between the background and printed information.

       Individual pages of a document  are passed through a scanner, which digitizes the image.
Documents may be passed through a scanner one page at a time, or multiple pages can be scanned
by loading them into a feeder.

       Using a workstation connected to the scanner, the operator verifies that the scanned image
is acceptable and enters indexing information.  The operator may also denote confidential sections
of the document.

       One of two methods used to control access to confidential information stored on a WORM
system involves storing two copies of the document, one  redacted copy and one complete copy.  A
redacted paper copy may be scanned or processing software may allow redaction of a document as
it is viewed on a video screen after scanning.

       The  other method  uses more  sophisticated  retrieval  software  to redact  confidential
information from the one stored copy of a document as it is displayed.  In this case, processing
software must allow flagging of confidential information as it is viewed  on a  video screen after
scanning.

       Information stored electronically on magnetic tapes or floppy disks can be processed for
storage on WORM disks if the processing hardware is capable of reading information stored on the
media.

       Hardware is available that allows information existing on microfiche to be digitized and stored
on WORM disks without  first being printed on paper.

       Once the information is prepared, it is written to a WORM disk using a  WORM drive.

5.4.2.2     Creation

       Several techniques are used to record data on a disk. The techniques all use a laser to record
the data on disks, but the materials used to compose the disks can vary  with each technique. The
techniques are ablative, bimetallic alloy, bubble forming, and dye polymer.
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       Using the ablative method, the laser creates small pits on the metal alloy surface to record
information.  Disks created using this method last about ten years.

       The bimetallic alloy method, a variation of the ablative approach, employs the laser to heat
two metallic layers, causing them to fuse. The developer of this method claims disks created in this
manner will last 100 years.

       Forming bubbles to record data is accomplished by using the laser to heat a layer in the disk,
causing decomposition.  It is this decomposition which forms a bubble.

       The least expensive method of recording data is the dye polymer method.  A dye polymer
layer in the disk is heated by the laser, causing a change of color.  These disks last about five years.

       Regardless of the method used to record data, it is stored on the disk using either a sequential
or linked file structure. The best file structure for an application must be determined by considering
factors specific  to the application, such as the  frequency of update and  required retrieval time
frames. Once stored, the original image cannot be changed, but files can be updated either by adding
new images or by storing modified versions of existing images.

       To date, the proliferation of WORM technology has been hampered because  of a  lack of
technical standards. Standards are now being set. Some WORM drives now available conform to the
emerging standard which the American National Standards Institute (ANSI) is developing for optical
disks.  The standard is now under review by the International Organization for Standardization.

5.4.2.3     Image Quality

       The  image quality of a WORM optical disk  is identical to that of CD-ROM,  described in
Section 5.4.1.3 of this document.

5.4.2.4      Capacity

       WORM disks hold large amounts of data.  They are available in sizes  of 5.25 inches, 8 inches,
12 inches, and 14 inches.  Using ASCII format,  an 800M byte, 5.25-inch WORM disk can store up
to 260,000 pages of documents (at 3,000 bytes per page).  One 2.000M  byte, 12-inch disk can store
up to 650,000 pages.  Using facsimile format, a 5.25 inch 800M byte WORM disk can store 11,400
pages of documents (at 70,000 bytes per page).  A 12-inch WORM disk can store  28,500 pages in
facsimile format.
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       Document storage systems normally use the larger size disks because of their higher capacity.
These systems may also use a disk juke box, which provides access to several disks.

5.4.2.5     Uodatabilitv

       Updating information that exists on a WORM disk is  accomplished by adding  the new
information to the disk, therefore superseding the previous version of the information.
       If information is stored on  the disk using the sequential file structure, the entire  file is
rewritten. This is the simplest method, but may waste disk space if only minor changes are made to
documents.

       The linked  structure requires only the sectors (portions of data recorded on the disk) changed
to be rewritten, and a pointer to the updated sector is written. The linked structure conserves disk
space, but will increase retrieval time for documents that are changed frequently.

       The fact that information cannot be erased or written over once written to a WORM disk
provides the benefit  of preserving an unalterable record of the original document and subsequent
changes.

5.4.2.6     Duplication

       Information on WORM disks can be copied directly to another WORM disk. This makes them
an attractive alternative to CD-ROM disks when smaller numbers of disks are to be distributed.

       Information stored on WORM disks  can also be used to create magnetic tapes.

5.4.2.7     Storage

       WORM disks can be stored in normal room conditions without detriment to the media.  They
are unaffected by humidity and will not mildew. Reasonable temperatures are tolerated; however,
if plastic disks are used, they should  not be subjected to temperatures hot enough to cause softening
or melting of the plastic layers.

       Electromagnetic damage experienced with magnetic storage media such as floppy diskettes
or hard  Winchester  disks is  not  a  problem  experienced  with  WORM disks.  They  are almost
invulnerable to corruption, short of  fire or vandalism.
                                            5-21

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5.4.2.8     Indexing

       During document preparation, index information is entered to facilitate retrieval. The types
of index information entered during document preparation will affect the features that can be
provided by the retrieval software.

       Features that may be provided by the retrieval software include the capability to identify or
locate documents using bibliographic information, reference information, or keywords that identify
the contents and/or subject of the document.

5.4.2.9     Retrieval

       Software must be written or purchased to gain access to information stored on a WORM disk.
This software normally includes a user interface and retrieval capabilities. The ease of use and speed
of retrieval will  be affected by the software  written or selected.

       To view a document stored on a WORM disk, a user would go to a microcomputer workstation
that either has a WORM drive or is connected to a network with access to a WORM drive.  Using the
retrieval software, the user would identify the document they want to view.

       If software is used to control access to confidential information stored on a WORM system,
the user may be required to enter a password or some type of identification before they are allowed
to view the confidential information.

       Once the document is identified, the storage location is known and the WORM drive can
reach the correct storage point on the disk in a fraction of a second.  The WORM drive uses a laser
beam and light detector to retrieve information recorded on the disk.

       If  no confidential information is contained in  the retrieved  document, or  if a user is
authorized to view confidential information, the complete document is displayed. If software is used
to redact a document as it is displayed and a user is not allowed to view confidential information,
then only the portions of the document that are not confidential are  displayed.

       Juke boxes that hold multiple WORM disks are available.  These juke boxes select and
robotically load disks into drives based on selection information entered by the user.  Juke boxes can
be connected to a single workstation or a network.
                                            5-22

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       WORM, like CD-ROM, can be used over a network with multiple stations.  This allows
multiple persons to access a disk, and even the same document, simultaneously. If dial-up access is
provided on the network, users at remote sites could view the same documents.

5.4.2.10    Paper Copies

       Paper copies of documents  can be produced  on printers connected to the workstation or
network, if the software allows this capability.
                                            5-23

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             SECTION 6 - COMPARISON OF FUNCTIONAL REQUIREMENTS
                               AND TECHNICAL OPTIONS
       This section provides an evaluation of the ability of paper and each of the optical technologies
to fulfill the requirements outlined in the Summary of Functional Requirements.

       Each requirement, the ability of each storage method to fulfill the requirement with a basic
system, and technical options are evaluated. In their ability to address the requirements identified
in the interviews, there is only one difference between CD-ROM and WORM. This difference is
significant, however, allowing WORM to respond to more identified requirements.  WORM supports
incremental addition and update of data stored on the optical disk;  CD-ROM does not. Although
further analysis is required, several interviewees indicated the ability to update records was required.
Exhibit 6-1 summarizes the ability of each technology to meet the identified requirements.

       The level of automation can have a major impact on the retrieval of stored information.
Functions that affect retrieval of information  that can be automated include indexing, controlling
access  to confidential information, retrieval, check-in/check-out, and refiling.

       For the purpose of this evaluation the definition of a basic system and of additional options
are  described below. The level of automation  attained with each system is also described.

PAPER

       A  basic paper document storage system is a totally manual system.

       Equipment for this system includes file folders, filing cabinets, notebooks, binders, and boxes.

       Central file room personnel are responsible for controlling access to confidential information,
retrieval, check-in/check-out, and refiling of the documents.  This method of records management
is very labor intensive.

        Optional equipment available to automate indexing, assist with check-in/check-out, and assist
with access control includes microcomputers with appropriate software and bar code equipment.
                                            6-1

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User  Requirements/
Technology  Matrix
                                                 Technology
Functional  Requirements
                                     o
                                     cr
                                     o
 _
o
rr
O
                                                          DC
                                                          O
 CONSERVE AND/OR MINIMIZE STORAGE SPACE
    Minimize Space Requirements
    Minimize Number of Duplicate Copies
 PROVIDE EFFICIENT DOCUMENT ACCESS AND RETRIEVAL
    Provide Document Tracking
    Minimize Retrieval Time
    Provide Access at a Convenient Location
    Allow After-Hours Access
    Support Simultaneous Access
 PROVIDE AUTOMATED RECORDS MANAGEMENT
 PROVIDE DATA SECURITY
    Ensure Data Availability
       Minimize Frequency of Lost, Misplaced, or Misfiled Records  |
    Maintain Data Integrity
       Provide High Quality, Readable Image
       Provide Durable Storage Media
    Ensure Data Confidentiality
       Support Confidential Processing Procedure
       Control Access to Confidential Information
LEGEND
X I Not Possible

   Unlikely to Meet Requirement

  ] Somewhat Able to Meet Requirement

   Likely to Meet Requirement
                         Exhibit 6-1

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User  Requirements/
Technology  Matrix  (cont'd)
Functional  Requirements
 INTEGRATE EXISTING SYSTEMS
 SUPPORT CONVERSION OF EXISTING MEDIA
                                         Technology
 STANDARDIZE FILE CONTENTS
 ORGANIZE DOCUMENTS
 SUPPORT UPDATE OF RECORDS
 PROVIDE BACKUP CAPABILITIES
 SUPPORT LEGAL ADMISSIBILITY
 GENERATE PAPER COPY
 ENSURE COST EFFECTIVENESS
 EXCHANGE INFORMATION
   LEGEND
~X~| Not Possible
   Unlikely to Meet Requirement
III Somewhat Able to Meet Requirement
   Likely to Meet Requirement
                      Exhibit 6-1

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MICROFILM AND MICROFICHE

       A basic microform system combines a semi-automated production system with a manual
retrieval system.

       Production equipment for this system includes film, microfilm cameras, film processors and
duplicators, splicing equipment, and readers with printers.

       Storage equipment includes rooms with climate and air quality control, racks or cabinets,
cassettes, cartridges, reels, and binders.

       Retrieval equipment includes readers, and readers with printers.

       Central file room personnel are responsible for controlling access to confidential information,
retrieval, check-in/check-out, and refiling of the microforms.  Users would be  responsible for
loading the microform into a reader and locating the desired document.

       Optional equipment available to automate indexing, assist with check-in/check-out, and assist
with access control includes microcomputers with appropriate software and bar code equipment.

       Automated indexing and access control, and the elimination of the need for check-in/check-
out, can be provided by a videomicrographic enhancement system.  Equipment for this optional
system includes videomicrographic enhancement equipment, a network, appropriate workstations,
and a printer. To fully automate this system, a juke box is required.

       Videomicrographic enhancement systems add many of the same costs incurred with optical
disk systems to the cost of a basic microform system.

CD-ROM

       A basic CD-ROM optical disk system combines a semi-automated production system with
a semi-automated retrieval system.

       Production equipment  for a CD-ROM disk system includes tape drives  and/or  printed
document scanners,  disks, mastering and pressing equipment.

       Storage equipment includes a file or cabinet for storage of disks.
                                           6-4

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       Retrieval equipment includes microcomputer workstations, appropriate software, a network,
a CD-ROM drive, and a printer.

       Central  file  room personnel are responsible  for  retrieving, loading, and  refiling  disks.
Indexing and access control is automated and the need to check out documents is eliminated.

       Optional equipment available to fully automate retrieval includes a disk juke box.

WORM

       A basic  WORM optical disk system combines  a semiautomated production system with a
semiautomated retrieval system.

       Production equipment for WORM disk systems includes disks, microcomputer workstations
with appropriate software, a printed document scanner, and a WORM drive.  These workstations may
also be used  for retrieval of information.

       Storage equipment includes a file or cabinet for storage of disks.

       Retrieval equipment includes microcomputer workstations, appropriate software, a network,
a WORM drive, and a printer.

       Central  file  room personnel are responsible  for  retrieving, loading, and  refiling  disks.
Indexing and access control is automated and the need to check out documents is  eliminated.

       Optional equipment available to fully automate retrieval includes a disk juke box.

6.1    CONSERVE AND/OR MINIMIZE STORAGE SPACE

6.1.1       Minimize Space Requirements

       The volume of documents stored on paper can be reduced by using any of the optical storage
media. In the following paragraph, a comparison is made of the ability of each media to store  2,500
pages of paper.
                                            6-5

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       Storing 2,500 pages of 8.5 by 11 inch paper would require approximately one linear foot os
storage space.  In order to store  the images of these 2,500 pages one of the following would be
required:

       •   one roll of microfilm
       •   twenty-six 4 by 6 inch microfiche
       •   1.25  percent of a 5.25 inch (600MB) CD-ROM disk in ASCII format and 29.2 percent
           in  facsimile format
       •   0.375 percent of a 12 inch (2000MB) WORM disk in ASCII format and 8.75 percent in
           facsimile format.

       The reader  will note that if WORM optical disk were chosen to store the 2,500 pages, only
a fraction of a 12-inch WORM disk would be required.

       WORM optical disk is a very compact storage medium.  One 12-inch 2,000MB WORM disk
can store 650,000 pages of information in ASCII format. If the same information were stored on a
different media, one would require one of the following:

       •   260 linear feet of shelf space
       •   260 rolls of microfilm
       •   6,760 microfiche (4x6 inches)
       •   4 CD-ROM disks (5.25 inch, 600MB).

       If the information on a 12-inch 2,000MB WORM disk were stored in facsimile format, 28,500
pages could be stored. If the same information was then stored on a different media, one  would
require one of the  following:

       •   11.4 linear feet of shelf space
       •   12 rolls of microfilm
       •   297 microfiche (4x6 inches)
       •   4 CD-ROM disks (5.25 inch, 600MB).

6.1.2      Minimize  Number of Duplicate Conies

       Duplicate copies of documents exist so that more than one person can use the information
contained in the document at the same time. The best way to reduce the  need for duplicate  copies
is to make it convenient to use a shared copy.  This can be accomplished with  videomicrographic
enhancement or  optical disk  systems.
                                            6-6

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       PAPER

       With paper documents, sharing one copy is not always possible or convenient.  With paper
       document storage, it will not be possible to substantially reduce duplication.
       MICROFILM AND MICROFICHE

       With microfilm and microfiche, multiple copies of documents are normally maintained. It
       is possible to maintain only one copy of information, if a videomicrographic enhancement
       system is used.
       CD-ROM AND WORM

       A basic CD-ROM or WORM system has the potential to reducing duplicate copies.  A
       conveniently located workstation can be made available using a network, so that a document
       can be viewed as quickly and conveniently as if each person had their own copy, thereby
       eliminating the need for duplicate copies.
6.2    PROVIDE EFFICIENT DOCUMENT ACCESS AND RETRIEVAL

6.2.1       Provide Document Tracking

       Tracking documents includes knowing what information is stored and where it is located. An
index can provide a reference of what information is stored and where it should be stored.

       For information available for check-out, check-in/check-out tracking can indicate if it is
available from the central file, or who has it checked out. Because they are cumbersome, manual
tracking systems are not considered.

       PAPER

       For paper storage systems, optional hardware and software must be obtained to provide
       automated document tracking. With this type of system, an index and check-in/check-out
       tracking may be provided.
                                          6-7

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       MICROFILM AND MICROFICHE
       Microfilm and microfiche are subject to the same treatment as paper documents, unless a
       videomicrographic  enhancement system is used.  In that case, an  index is provided and
       information is not checked out, so it is always available.
       CD-ROM AND WORM

       A basic CD-ROM or WORM optical disk system provides an index.  Information is not
       checked out; therefore,  it is always available.
6.2.2       Minimize Retrieval Time

       Well-designed  automated systems reduce retrieval  time.  Generally, the  more retrieval
functions that are automated, the faster the retrieval. Retrieval functions that can be automated
include document identification, verification of access authorization, locating the  document, and
document retrieval or display.

       PAPER

       A basic paper  document storage  system  is not automated.  With optional  equipment and
       software, the document identification function can be automated and assistance  can be
       provided for verification of access authorization. Locating the document may be very time-
       consuming because the volume of information to search through is the largest of any storage
       media. The search may be further complicated by misfiling.
       MICROFILM AND MICROFICHE

       A basic microfilm or microfiche system is very similar to a paper system, but the volume of
       information and potential for misfiling are reduced. Document identification can be more
       difficult, if not automated, because documents cannot be scanned without inserting them into
       a reader.  Using a videomicrographic enhancement system with a juke box, fully automated
       retrieval is possible.
                                           6-8

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       CD-ROM AND WORM

       Basic  CD-ROM and WORM optical  disk systems can  provide automated  document
       identification and verification of access authorization. Locating the correct disk and inserting
       it in the drive would be a manual process.  Document retrieval and display are automated.
       If a disk juke box is used, fully automated retrieval is possible.
6.2.3       Provide Access At A Convenient Location

       A central repository allows documents to be shared, but is not always conveniently located.
With videomicrographic enhancement or optical disk systems, access to centrally stored documents
can be provided at a user's desk.

       PAPER

       Paper is voluminous to store, and the volume of documents can be a factor in selecting a
       location for a central storage facility. This may force the central storage facility to be located
       a good distance from where users are located, making it inconvenient and time consuming to
       access documents. If the documents have been checked out, additional time must be taken
       to locate and gain access to the documents.
       MICROFILM AND MICROFICHE

       Microfilm and microfiche are not as voluminous as paper;  therefore, the location of the
       central storage facility may be more convenient.  If the microform has been checked out,
       additional time must be taken to locate and gain access to the microform.

       The use  of  a  videomicrographic  enhancement system eliminates the need  to check  out
       microforms  and can  provide access to the central files at the user's desk through use of a
       network.
       CD-ROM AND WORM

       CD-ROM and WORM optical disk systems provide the most compact storage of all the media.
       The location of the central storage facility can be convenient.  With a basic optical disk
       system, access to the central files can be provided at the user's desk through use of a network.
                                            6-9

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6.2.4       Allow After-Hours Access

       With manual retrieval systems, central file room personnel must be present whenever access
to documents is allowed.  Personnel are required to check access authorization, retrieve, and refile
documents. Fully automated systems provide the advantage of being available whenever people need
access, without requiring personnel to be present.

       PAPER

       Paper storage systems are manual systems, and cannot be upgraded to fully automated systems.
       Central file room personnel must be present whenever access to documents is allowed.
       MICROFILM AND MICROFICHE

       Basic microfilm and microfiche systems are manual systems and require central file room
       personnel  to be  present  during times that access to documents is  allowed.   If  a
       videomicrographic enhancement system with a juke box is used, microform systems can be
       fully automated.
       CD-ROM AND WORM

       A basic CD-ROM or WORM optical disk system would require central file room personnel
       to be present to retrieve, load, and refile disks during hours that access is provided.  The
       option of a disk juke box can provide a fully automated system.
 6.2.5      Support Simultaneous Access

       Simultaneous access of one document by multiple persons in different physical locations can
 be provided by a videomicrographic enhancement system or an optical disk system.

       PAPER

       A paper document storage system cannot provide this capability.
                                            6-10

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       MICROFILM AND MICROFICHE
       A basic microfilm or microfiche system cannot provide this capability. A videomicrographic
       enhancement system can support simultaneous access.
       CD-ROM AND WORM
         basic CD-ROM or WORM optical disk system provides this capability.
6.3    PROVIDE AUTOMATED RECORDS MANAGEMENT

       Areas of file management that were cited for requiring too much time were filing, retrieving,
and tracking documents, and review of documents to determine what information can be released to
the public.

       Filing, retrieving, and tracking documents can be automated to save time. Determining what
information can be released must remain a manual  process.  Once a document is reviewed, the
confidential portions can be permanently recorded as such,  eliminating the need to  review the
document each time information is requested.

       PAPER

       Paper storage systems cannot be automated  to reduce records management time.  Well-
       organized files can minimize time spent dealing with records management, but the volume
       of paper documents makes them difficult to handle.
       MICROFILM AND MICROFICHE

       A basic microfilm or microfiche system is not automated. It does offer some improvement
       over paper storage by reducing the volume of information to manage. If a videomicrographic
       enhancement system with a juke box  is used,  filing, retrieving, and  tracking  can be
       automated.
                                         6-11

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       CD-ROM AND WORM

       A basic CD-ROM or WORM optical disk system provides automated tracking and reduces
       the  volume of information  to manage.  If a juke box is used, filing and retrieving are
       automated.

6.4    PROVIDE DATA SECURITY

6.4.1   Ensure Data Availability

       Records are lost, misplaced, or  misfiled due to human error.  This can be substantially
reduced through the use of automated retrieval and refiling systems provided with the use of a juke
box.

       PAPER

       Documents stored on paper are prone to  being lost, misplaced, or misfiled.  Entire files, or
       pages within a file, can be lost, misplaced, or misfiled.
       MICROFILM AND MICROFICHE

       Microfilm and microfiche offer some improvement over paper records because individual
       pages cannot be lost, misplaced, or misfiled. It remains possible to lose, misplace, or misfile
       an entire roll or a fiche. If a videomicrographic enhancement system with a juke box is used,
       the retrieval and refiling of the media is automated.
       CD-ROM AND WORM

       CD-ROM and WORM optical disks offer further improvement because more images of
       documents can be recorded on one disk.  If a disk juke box is used, retrieval and refiling is
       automated.
                                          6-12

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6.4.2  Maintain Data Integrity

6.4.2.1     Provide High Quality. Readable Image

       A good, readable image can be recorded on any of the media.

       Printed documents with a particularly low level of contrast between the background and
printed information can pose a problem for any of the storage media. Low-contrast documents, in
printed form, are difficult to read and reproduce.  It may be difficult to record a good image on
optical media from these documents.

       Reproduced paper or microform documents will lose resolution with each generation, thereby
becoming less readable.  Optical disks can be reproduced indefinitely without any loss of resolution.

6.4.2.2     Provide Durable Storage Media

       For each of the media categories, the choice of  quality or type of materials affects the
durability of the document image. Information stored on  paper or microform is subject to damage
from handling and is more sensitive to environmental conditions than optical disks are.  If paper or
microforms are used  for everyday retrieval, they cannot be expected to last as long as projected.

       PAPER

       For paper documents, high quality bond paper will last for hundreds of years if stored under
       proper conditions.   Proper conditions include protection from handling, fire,  flood, and
       humidity or dampness, which can encourage damage from mildew. Printed images created
       using erasable or lift-off inks are prone to flaking.   Heat sensitive paper and no-carbon-
       required copies fade  over time and are adversely affected by heat.


       MICROFILM AND MICROFICHE

       Microfilm and  microfiche prepared and stored according  to archival standards can be
       expected to last at least a hundred  years.  These standards  specify  the type of film and
       processing techniques to use, as well as temperature, humidity, and air quality controls for
       storage.  Microforms must also be protected from handling, fire, flood, and humidity or
       dampness.
                                           6-13

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       CD-ROM

       CD-ROM disks can be counted on to last at least ten years.  Some manufacturers  are
       projecting a life of at least 20 years, but this has not been proven  yet. The disks must be
       protected from fire or temperatures high enough to soften or melt the outer plastic layers.
       WORM

       Manufacturers of WORM disks are projecting a life of from 5 to 100 years, depending on the
       composition of the disk and the recording method used.   The technology has not been
       available for the longest projected life of the media; therefore, disks claiming the longest life
       have not been proven yet. WORM disks must be protected from fire and disks with plastic
       outer layers must be protected from temperatures high enough to soften or melt the plastic
       layers.

       Unlike paper or microfilm, duplicate copies of optical disks can be produced without loss of
       resolution.   Making new copies  periodically  would allow  the information to be  stored
       perpetually, with no loss of image quality.
6.4.3   Ensure Confidentiality

6.4.3.1     Support Confidential Processing Procedures

       Determining the procedures that should be followed to protect confidential information from
unauthorized access during conversion of the data for storage is a policy issue that would have to be
considered once a specific technology is selected.

6.4.3.2     Control Access To Confidential Information

       Access to confidential information can be controlled using any of the storage media.  An
automated retrieval system that controls access to confidential information eliminates the need for
central file room personnel to regulate access.

       PAPER

       Access to documents stored on paper must  be manually regulated by file room  personnel.
       This may be accomplished with the aid of a microcomputer index that contains indicators for
                                            6-14

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       confidential documents and/or an automated list of those authorized to view confidential data.
       MICROFILM AND MICROFICHE

       Access to  microfilm  and microfiche  is regulated the same  way that paper is, unless a
       videomicrographic enhancement system is used.  With a videomicrographic enhancement
       system, software can be developed to automate access control.
       CD-ROM AND WORM

       Using a basic CD-ROM or WORM optical disk system, access to confidential information can
       be controlled with automated software procedures that require a password or other identifying
       information to be entered by the user before confidential information is revealed.
6.5    INTEGRATE EXISTING SYSTEMS

       Paper, microfilm, microfiche, CD-ROM, and WORM are all capable of being integrated with
existing systems, based on hardware, software, and application constraints. In order to address the
ability of each medium to effectively integrate with existing systems, further in-depth analysis is
required for each application. Program offices must also perform cost benefit analysis, in-depth
systems design, and any other activities as required by the FIRMR.
6.6    SUPPORT CONVERSION OF EXISTING MEDIA

       Current documents are primarily stored on paper, with some use of microfilm, microfiche,
and electronically readable media. These media can be converted to any of the optical storage media.

       PAPER

       Information stored on any of the current media can be converted to paper.  Documents
       currently stored on paper would need no conversion, while microfilm and microfiche images
       can be printed on paper using a printer combined with a reader.  Electronically readable
       information can be converted to paper by printing the document.
                                           6-15

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       MICROFILM AND MICROFICHE

       For conversion to microfilm or microfiche, paper documents can be photographed. Maps and
       oversized documents may not be convertible, or may have to be filmed in sections, depending
       on the equipment  purchased.   Microfilm and  microfiche would need no  conversion.
       Electronically readable information can be converted to computer output microfilm (COM).
       CD-ROM

       To create a CD-ROM disk, paper documents can be keyed in or scanned. Maps and oversized
       documents may have to be scanned in sections.   Information stored  on microfilm or
       microfiche can also be keyed in by data entry personnel or scanned by machine.  Digital
       information can be stored on CD-ROM.
       WORM

       Paper documents can be keyed in or scanned for storage on a WORM disk.  Maps and
       oversized documents may have to be scanned in sections.  Microfilm and microfiche can be
       keyed in by data entry personnel or scanned by machine. Digital information can be written
       to a WORM disk.
6.1    STANDARDIZE FILE CONTENTS

       Determining  what information should  be kept in the files is a policy issue, not an issue
technology can be used to solve.

6.8    ORGANIZE DOCUMENTS

       All of the storage media are capable of organizing existing and future documents. However,
there are significant distinctions between the media in terms of ease of organizing documents. Paper
is the most time-consuming to organize, while  information stored on WORM can be automatically
indexed.
                                          6-16

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6.9    SUPPORT RECORD UPDATE

       Manual update is sufficient for very small volumes of documents with a small volume of
updates.  As document or update volumes increase, an automated system becomes more important.
The best system to use with a large volume of documents to provide fast, easy, high-volume updates
is a WORM system.

       PAPER

       Very small, consistently organized paper systems can be manually updated quickly and easily.
       Once the files grow, or become disorganized, updates are no longer quick or easy.
       MICROFILM

       Microfilm can be updated by splicing the film to remove outdated information and to add
       new information, but this is a difficult, time-consuming process. Splicing also affects the
       durability of the film. A microfilm jacket is easier to update, but updating is still a time-
       consuming process.
       MICROFICHE

       Microfiche can be updated if updatable microfiche film is used. Updatable microfiche film
       is not as durable as other types of film used for microfiche.
       CD-ROM

       Information stored on a CD-ROM optical disk is not updatable.


       WORM

       Updating a WORM disk is easy. New information is keyed in or scanned (if in printed form),
       written to an unused area of the disk, and the index or file pointers are updated. The original
       version of the document remains on the disk, unchanged.  This provides  a history of the
       document from the original version through all subsequent changes, if the original file pointer
       data is maintained.
                                          6-17

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6.10   PROVIDE BACKUP CAPABILITIES

       Any of the media can be duplicated to provide a backup copy.

       Backup  documents do not have to be  kept in the same  media as the on-site reference
documents. If they are kept on two separate media, the backup copy should be capable of recreating
whatever media is used for on-site reference.

       Duplicating paper documents is usually not a good method of backup because it is unwieldy
and doubles storage space requirements.  For paper documents, it may be desirable to use the printed
documents as off-site backup or archival documents, and use another media for on-site reference.
This would reduce the on-site storage space requirements and provide backup documentation.

6.11   SUPPORT LEGAL ADMISSIBILITY

       Paper is the only form of media that is unquestionably admissible in court. Alternate storage
media, such as microform or optical disks, have not been tested and proven to the same degree.

       The Business Records Act and the  Federal Rule of Evidence 803(6) provide that alternate
storage media produced in the normal course of business are as legally admissible as paper.   The
wording of these documents suggests they would apply to optical disk as well as microfilm storage.

       Actual tests of admissibility in court have accepted and rejected both microform and optical
disks.  A prevailing reason for rejection was that the alternate storage media was created in
preparation for the court case, not in the normal course of business.

       Most people express reluctance to rely solely on alternate storage media until a high-level
court, possibly  the Supreme Court,  rules it  unquestionably admissible.  Until this happens, the
burden of paper documents cannot be completely eliminated.

       An approach that can be used to  reduce primary storage space, while still retaining access to
original documents should it prove necessary, is to use a combination of different storage media.
Alternate media can be  used for on-site storage, and everyday use and original paper documents can
be archived. This approach provides a secure, off-site backup, and the benefits gained by use of an
alternate storage media.
                                           6-18

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6.12   GENERATE PAPER COPY

       All of the storage media are capable of producing a paper copy of a document.

       PAPER

       A xerographic duplicate can be made of information stored on paper.


       MICROFILM AND MICROFICHE

       Microfilm and microfiche images can be printed on paper using a printer combined with a
       reader.


       CD-ROM AND WORM

       Information stored on CD-ROM or WORM optical disks can be printed.

6.13   ENSURE COST EFFECTIVENESS

       In order to determine the comparative cost effectiveness of each of the media, a detailed cost-
benefit analysis would have to be performed, based on the detailed requirements of each application.

6.14   EXCHANGE INFORMATION

       All of the media support data exchange; however, electronic systems allow quick exchange
of data without the transfer of the physical storage media. The ability of each media to support data
exchange depends on  hardware, software, and application constraints.
                                          6-19

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                               SECTION 7 - CONCLUSION
7.1    ESTIMATED NUMBER OF SYSTEMS

       An  estimate of the number of Image Processing Systems which may be required can be
expressed as optical disk jukebox ("Jukebox Systems")  and optical disk systems not including a
jukebox ("Basic Systems"). An estimation model was used and is presented in Exhibit 7-1.

       The model presented in Exhibit 7-1 assumes that the storage capacity of a Jukebox system
is 200 GB.  Also, since document storage estimates for  the regional applications were varied and
difficult  to validate, a conservative estimate of one Jukebox and one Basic system was assumed in
all regions except Regions II and  V, which are the largest EPA regional offices.  In Regions II and
V, two Jukebox and one Basic systems are assumed to be reasonable estimates for all regional
applications including the Superfund site files.  Finally, the model assumes that once 15 2GB optical
disks are filled with data, a jukebox would be required for storing and mounting them, as opposed
to having the disks manually mounted and dismounted in the optical disk drives.

       In determining  the estimated  number of Jukebox and Basic systems, the model considers
two issues:  first, the existence of a distributed processing environment or remote locations; and
second, the estimated bytes of document storage required for the next five years.

       The number of remote locations in a distributed environment is important in determining the
number of Basic systems since communication  is required  between locations.  Therefore,  in all
distributed environments where storage and processing are centralized but remote locations require
access and  communication with the central location, a Basic system is assumed necessary to support
this access via host-to-host communication.  Step  1 of the model addresses this aspect of  the
estimation  process.

       The estimated  bytes  of  document  storage  required by each application are based on
information obtained during phone and personal interviews. If document storage requirements were
not available through interviews, they were then obtained from published documentation.  To
calculate the storage requirements, 1,900 pages are assumed per linear foot. It is assumed an 8 1/2"
by 11" page would require 70,000 bytes of WORM storage in facsimile format.

       The results,  using this estimation model, are presented in Exhibit 7-2.  Based on  the
assumptions stated above, the estimated storage requirements, and the limited scope of this analysis,
it is reasonable to assume that the EPA requires  33 Jukebox systems and 80 Basic systems.
                                            7-1

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                        Systems Estimation Model
                                   (Step 1)
m
X
Distributed
Application ?
Yes
No ^^ — <— _ Are there
Remote Users ?
Yesl

t Number of
emote Locations

                                                          No

                                    i
                                Threshold for each
                                Remote Location
iacn\
ion  I

-------
->J
                                Systems  Estimation Model
                                              (Step 2)
              Purpose:
              For each stand alone system or remote host, step 2 is used to determine the size
              of the host.

              Assumptions:
              This model is based on a series of thresholds comparable to those defined by the
m            IPS RFP. Exceeding any single threshold effects the estimated number of sys-
I:            terns. The RFP assumes 70,000 bytes per page. This model assumes 15,000
°"            pages per GB of optical storage.
              Optical Storage Threshold               Access Threshold
                 less than 30GB = Basic (Level II)            less than 16 Simultaneous Users - Basic (Level II)
                 more than 30GB = Jukebox (Level I)         more than 16 Simultaneous Users - Jukebox (Level I)

              Magnetic Storage Threshold             Online Optical Storage Threshold
                 less than 5GB = Basic (Level II)             less than 2GB * Basic (Level II)
                 more than 5GB = Jukebox (Level I)          more than 2GB = Jukebox (Level I)

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m
x
Estimated Number of Systems
Number of
Remote
Applications Locations
Contract Lab 13
Finance 13
NEIC* 0
OGC-all applications 2
OPP-all applications 1
OTS-TRI 0
OTS-PMN 1
PCMD 0
Personnel 13
STARS 14
Testing** 0
Note: No storage estimate for backup is included.
Magnetic Media.
Total 5-yr.
Storage Estimate

3150GB
431GB
NA
7GB
516GB
215GB
253 GB
940GB
134GB
137GB
NA
Backup will not require Level 1 or Level II systems.
Est.
Level 1 ?.
Systems
8
2
0
0
2
1
1
3
1
2
1
Est
Level II
Systems
13
12
1
2
1
0
1
11
13
15
1
Backup may require Optical Platters or
1 * NEIC requires 1 Level 1 System for an optical disk pilot
1 V A/DPf) StAnrlarri nntmiinn nnlint 1C tn nrnuiHo a toctinn an/-/ rlaualnnmant ouotam fnr COA /tiohftu rfs>W /.../.i^^r,/.

-------
m
x
to
                            Estimated Number of Systems


Applications
Reg 1 Site File
Reg 2 Site File
Reg 3 Site File
Reg 4 Site File
Reg 5 Site File
Reg 6 Site File
Reg 7 Site File
Reg 8 Site File
Reg 9 Site File
Reg 10 Site File
Est
Level 1
Systems
1
2
1
1
2
1
1
1
1
1
Est
Level It
Systems
1
1
1
1
1
1
1
1
1
1
                GRAND TOTAL
33
80
                One Level I and one Level II are assumed for all regions but the two largest, Regions 2 and 5. In

                Regions 2 and 5, two Level I and one Level II are assumed.

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7.2    FOLLOW-ON DETAIL ANALYSIS

       The requirements analysis in this  document was performed to determine EPA's overall
requirements for automated document storage and retrieval. In addition to a requirements analysis,
this document includes a mission needs analysis, a statement of available technology options, and a
comparison of the ability of each technology to meet the identified requirements.

       The results of this analysis should be used as the basis for an in-depth systems design and
analysis and a  cost-benefit analysis, as defined by the EPA  System Design and  Development
Guidance document. It is assumed that each program office with automated document storage and
retrieval requirements will follow the steps outlined in  this methodology to identify the document
storage and retrieval solution that can best meet its needs.

       The steps of this methodology, which each program office should perform, are described in
the EPA System Design and Development Guidance document.  They are:

       •  Perform Preliminary Design and Options Analysis, including Operational and Technical
           Feasibility Analysis, Life Cycle  Cost-Benefit Analysis, and  Option Selection and
           Documentation;

       •  Perform System Design, including System Detailed Requirements Analysis and Detailed
           Design;

       •  Perform System Development, including System Production and Programming, Testing
           and Evaluation, and System Integration; and
       •  Perform System Implementation.

       This analysis addresses several specific EPA program  offices and functions  with known
document storage and retrieval requirements. Almost certainly there are other EPA functions which
have or will have document storage and retrieval requirements.  These offices should also conduct
the type of detailed analysis described above.  In performing the Agency Automated Document
Storage and Retrieval Requirements Analysis, it was not  possible to contact all EPA program offices.
A single, two hour interview to elicit general functional requirements was  performed with those
offices contacted. Furthermore, limited documentation  was available for review. Therefore, while
this requirements analysis presents a representative summary of the Agency's requirements, it by no
means provides a complete  or detailed statement of all requirements for all program offices.
                                            7-6

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       The requirements identified by this analysis, which are presented in Exhibit 4-1, include:

       •   Conserve and/or minimize storage space;

       •   Provide efficient document access and retrieval;

       •   Provide automated records management;

       •   Provide data security;

       •   Integrate existing systems;

       •   Support conversion of existing media;

       •   Standardize  file contents;

       •   Organize documents;

       •   Support record update;

       •   Provide backup capabilities;

       •   Support legal admissibility;

       •   Generate paper copy;
       •   Ensure cost  effectiveness; and

       •   Exchange information.

       The technologies described in this document represent those most likely to be available to the
Agency.  Currently, EPA is a multi-media environment and may continue  to be, because of the
limitations of any single technology to meet all user requirements.  Most of the technologies discussed
in this analysis are currently, in some form, used in the Agency.  Further in-depth analysis, including
in-depth system design, cost benefit analysis, configuration analysis, and any other activities required
by the  FIRMR should be performed prior to implementation by each program office with records
management requirements.
                                            7-7

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                                     APPENDIX A
                                    BIBLIOGRAPHY


1.   OTS Information Management Requirements Pertaining to Optical Disk.

2.   Study to Document Regional Suoerfund Records Management Initiatives - Draft Working
    Summary of Data Collected During Interviews in Region VIII for Exit Interview with
    Kerrigan Cloueh. et al, (April 20, 1988).

3.   American Management Systems, Inc., Development of Improved Procedures for Records
    Management for the Region VII Suoerfund Program. Delivery Order No. 106, Contract No.
    68-01-7281, Task 2.4, Requirements Analysis (Cambridge, MA: March 1, 1989).

4.   American Management Systems, Inc., Model Program for Removal Site File Management.
    Contract No. 68-01-7281, Delivery Order No. 057 (January  1988).

5.   Bishop, Jerry E., "Matsushita  Electric To Show Erasable Optical Disk Drive,"  The Wall Street
    Journal, p. B4 (March 22, 1989).

6.   Booz, Allen & Hamilton, Inc., Final Regional Reports  for Study to Evaluate Regional
    Suoerfund Records Management Initiatives. Contract No. 68-01-7282, Work Order No. 35
    (October 20, 1988).

7.   Booz, Allen & Hamilton, Inc., Identification of Requirements and System Design Options for
    a Suoerfund Records  Management System for Region VIII. Contract No. 68-01-7282, Work
    Order No. 079 (November 29, 1988).

8.   Booz, Allen & Hamilton, Inc., Procurement Analysis for a Document Storage and Retrieval
    System. Mission Needs Statement. Contract No. 68-01-7282, Delivery Order No. 88 (May 1,
    1989).

9.   Booz, Allen & Hamilton, Inc., Region V Suoerfund Records Management Study.
    Requirements Analysis Briefing. Contract No. 68-01-7376, Work Order No. F44 (April 26,
    1988).

10. Booz, Allen & Hamilton, Inc., Requirements for an Electronic Recordkeeoing Strategy.
    Contract No. 68-01-7282, Work Order No. 068 (February 7, 1989).

11. Booz, Allen & Hamilton, Inc., Review of the 1MSD Micrographic Study and Identification of
    System Requirements  for Study to Evaluate and Design a Microform System for the
    Procurement and Contracts Management Division. Contract  No. 68-01-7282, Work Order No.
    052 (February 19, 1988).

12. Booz, Allen & Hamilton, Inc., Superfund Transactions Automated Retrieval System (STARS')
    Prototype Evaluation  (March  1989).

13. Bozman, Jean S., "Vendors Scramble To Push Imaging  Market," Comouterworld. Vol. XXIII,
    No. 24, p. 16 (June 12, 1989).

14. Burgess, John, "Digital Imaging Revives Dreams of a Paperless Society," The Washington
    Post. Washington Business, p. 1 (March 27, 1989).

15. Datapro Research Corporation, "All About Mass Storage," Datapro Reports on
    Microcomputers, pp. CM19-005-103—CM19-005-104 (July 1988).

16. Datapro Research Corporation, "All About Optical Storage:  Market Overview," Datapro
    Reports on Microcomputers, pp. CM19-005-481--CM19-005-482 (December 1988).

-------
17.  Datapro Research Corporation, "All About Optical Storage:  Technology Overview," Dataoro
    Reports on Microcomputers, pp. CM19-005-451—CM19-005-455 (December 1988).

18.  Data/ware Development, Inc., "S/370 Optical Storage" advertisement, Computerworld. Vol.
    XXIII, No. 22, p. 20 (May 29, 1989).

19.  Department of Justice, Computer-Related Evidence in Federal Criminal Cases. A Manual for
    Prosecutors and Investigators.

20.  Environmental Protection Agency, Office of Information Resources Management, EPA
    System Design and Development Guidance (October 1987).

21.  Environmental Protection Agency, Office of Information Resources Management, Records
    Management in the EPA: An Overview for  Regional Managers (February 14, 1989).

22.  Environmental Protection Agency, Office of Toxic Substances, A Guide to the Toxic
    Chemical Release Inventory Form R (September 1988).

23.  Environmental Protection Agency, Office of Toxic Substances, Procurement  Analysis for a
    Document Storage and Retrieval System: Briefing on the Options Analysis (June 8, 1989).

24.  General Accounting Office, ADP Modernization: FCCs Automation Planning Is Inadequate
    (September 1988).

25.  General Accounting Office, Superfund:  Overview of EPA's Contract Laboratory Program
    (March  1988).

26.  H.S. Stuttman, Inc. Publishers, The New Illustrated 'Science and Invention Encyclopedia.
    Volume 12 (Westport, CT:  1987).

27.  lies, Doug, "CD-ROM Enters Mainstream IS," Computerworld. Vol. XXIII, No. 23,  pp. 75-79
    (June 5, 1989).

28.  Kish, Jr., Joseph L., Micrographics: A User's Manual. (Wiley-Interscience Publication,
    1980).

29.  Knutson, Tim, Memorandum on Draft Requirements Analysis for Technical  Approval.
    Confidential Data Branch, Information Management Division.

30.  Packard Bell, "PCs & Workstations, New Products, Systems," Computerworld. Vol. XXIII, No.
    20 (Chatsworth, CA: May 15, 1989).

31.  Planning Research Corporation, Assessment  of the Suitability and Costs of Alternatives for
    Administrative Record Document Management. Draft Report, Contract No. 68-01-7331,
    Work Order No. 442 (June 30, 1988).

32.  Smith, Charles, Micrographics Handbook. Artech House, Inc. (1978).

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                                     APPENDIX B
                                POINTS OF CONTACT
B.     Points of Contact

       B.I    Finance Operations
             B.I.I   Headquarters Accounting Operations Branch (HAOB)
                    Douglas Barrett
                    Chief, Headquarters Accounting Operations Branch
                    401 M Street, SW
                    Washington, DC 20460
                    (202) 382-5100
                    E-Mail: EPA3375

             B.I.2   Financial Management Offices

                    B.I.2.1    Cincinnati
                             James Wood
                             Acting Director, Financial Management Division
                             26 West St. Clair Street
                             Cincinnati, Ohio  45268
                             (513) 569-7831
                             E-Mail: EPA3117

                    B.I.2.2   Las Vegas
                             Alan Lewis
                             Financial Management Officer
                             Financial Management Center
                             4220 S. Maryland Parkway,  Bldg. C
                             Las Vegas, Nevada  89119
                             (702) 798-2485
                             E-MAIL: EPA3522

                    B.I.2.3   RTF
                             Joseph Safadi
                             Chief, Superfund Contracts  Branch
                             U.S. EPA
                             Rt 54 & Alexander Drive
                             Research Triangle Park, NC 27711
                             (919) 541-2304
                             E-MAIL: EPA3193

             B.I.3.  STARS

                    Scott Belcher
                    Consultant
                    503 West Main Street, Apt. F
                    Charlottesville, VA  22901
                    (804) 979-2557

                    Jack Johnson
                    Chief, STARS Development Project
                    401 M Street, SW
                    Washington, DC 20460
                    (202) 382-5745
                    E-MAIL: EPA3378

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             Debbie Ross
             Computer Systems Analyst
             401 M Street, SW
             Washington, DC  20460
             (202) 382-2880
             E-MAIL:  EPA3821

B.2    Personnel Operations

       B.2.1  Headquarters Operations and Client Services Division
             Charles Collins
             Personnel  Information Specialist
             401 M Street, SW
             Washington, DC  20460
             (202) 382-3285
             E-MAIL:  EPA3236

             Richard Lemley
             Director, Headquarters Operations and Client Services Division
             401 M Street, SW
             Washington, DC  20460
             (202) 382-3266
             E-MAIL:  EPA3470

       B.2.2  Personnel  Offices

             B.2.2.1    Region 1
                       Laurel Seneca
                       Personnel Management Specialist
                       U.S. EPA
                       John F. Kennedy Building
                       Boston, Mass  02203
                       (617)565-3719
                       E-MAIL: EPA9180

             B.2.2.2    Region 5
                       James Byrne
                       Human Resources and Program Support Officer
                       U.S. EPA
                       536 S. Clark Street
                       Chicago, Illinois 60605
                       (312) 353-8915
                       E-MAIL: EPA9545

             B.2.2.3    Region 7
                       Richard DeVoe
                       Acting Personnel Officer
                       U.S. EPA
                       726 Minnesota Avenue
                       Kansas City, KS  66101
                       (913)236-2821
                       E-MAIL: EPA9747

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             B.2.2.4    Region 9
                       Vicki Lane
                       Personnel Management Specialist
                       U.S. EPA
                       215 Fremont Street
                       San Francisco, CA  94105
                       (415) 974-8016
                       E-MAIL: EPA9954

B.3    National Enforcement Investigations Center (NEIC)
       Robert Laidlaw
       Chief, Information Management Branch
       National Enforcement Investigations Center
       Building 53, Box 25227
       Denver, CO 80225
       (303) 236-5122
       E-MAIL: EPA2346

       Paula Smith
       Assistant Director, Operations
       National Enforcement Investigations Center
       Building 53, Box 25227
       Denver, CO 80225
       (303) 236-5122
       E-MAIL: EPA2391

B.4    Office of the General Counsel (OGC)
       Jeffrey Camp
       PC Site Coordinator
       401 M Street, SW
       Washington, DC 20460
       (202) 475-8888
       E-MAIL: EPA2810

       Paul Frazier
       LAN Administrator
       401 M Street, SW
       Washington, DC 20460
       (202) 475-8052
       E-MAIL: EPA2810

       Kevin Lee
       Assistant General  Counsel, Pesticides
       401 M Street, SW
       Washington, DC 20460
       (202) 382-7505
       E-MAIL: EPA2861

B.5    Office of Pesticide Programs (OPP)
       William Grosse
       Chief, Information Services Branch
       401 M Street, SW
       Washington, DC 20460
       (703) 557-2613
       E-MAIL: EPA7397

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       Jerry Miller
       Chief, Systems Branch
       401 M Street, SW
       Washington, DC  20460
       (703)557-5484
       E-MAIL: EPA7399

B.6    Office of Solid Waste and Emergency Response (OSWER)

       B.6.1  Headquarters
             Lynn Scattolini
             Information Management Specialist
             401 M Street, SW
             Washington, DC  20460
             (202) 475-6757
             E-MAIL: EPA5055

       B.6.2  Contract  Lab Program
             Roch Mongeon
             Senior Environmental Analyst
             209 Madison Street
             Alexandria, VA  22314
             (703) 684-5678

             Pamela Simons
             Senior Environmental Analyst
             209 Madison Street
             Alexandria, VA  22314
             (703) 684-5678

             Richard Thacker
             Program  Manager
             209 Madison Street
             Alexandria, VA  22314
             (703) 684-5678

       B.6.3  Regional Site Files

             B.6.3.1    Region 1
                       Evo Cunha
                       Diane Kelley
                       U.S. EPA - Waste Management Division
                       John F. Kennedy Building
                       Boston, Mass 02203
                       (617) 573-9672

             B.6.3.2    Region 2
                       Jennie Delcimento
                       Dave Levy
                       U.S. EPA - Emergency and Remedial Response Division
                       26 Federal Plaza, Room 737
                       New York, NY 10278
                       (212) 264-8676

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             B.6.3.3   Region 3
                      Anna Butch
                      Peg Leva
                      U.S. EPA
                      841 Chestnut Street
                      Philadelphia, PA  19102
                      (215) 597-2393

             B.6.3.4   Region 4
                      Harold Key
                      U.S. EPA - Site Investigation and Support Branch
                      345 Courtland  Street, NE
                      Atlanta, GA 30365
                      (404) 347-2930

             B.6.3.5   Region 5
                      Lynn Calvin
                      U.S. EPA
                      230 S. Dearborn - 12th Floor
                      Chicago, Illinois  60604
                      (312) 886-5821

             B.6.3.6   Region 7
                      Maureen Hunt
                      U.S. EPA - Waste Management Division
                      726 Minnesota Avenue
                      Kansas City, KS 66101
                      (913) 236-2856

             B.6.3.7   Region 8
                      Sandy York
                      U.S. EPA
                      999  18th Street, Suite 500
                      Denver, Colorado 80202-2405
                      (303)293-1641

             B.6.3.8   Region 9
                      Don Briggs
                      Tom Mix
                      Tom McMenamin
                      U.S. EPA
                      215 Fremont Street
                      San Francisco, CA 94150
                      (415) 995-8550
B.7    Office of Toxic Substances (OTS)
       Janette Petty
       Technical Information Specialist
       401 M Street, SW
       Washington, DC 20460
       (202)382-3590
       E-MAIL: EPA7568

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      JoAnn Martin
      Computer Specialist
      401 M Street, SW
      Washington, DC  20460
      (202) 382-3756
      E-MAIL:  EPA7575

B.8   Procurement and Contracts Management Division (PCMD)
      Paige Peck
      Chief, Specialized Procurements
      401 M Street, SW
      Washington, DC  20460
      (202) 382-2355
      E-MAIL:  EPA3259

      Mark Walker
      Associate Director, ADP Procurement
      401 M Street, SW
      Washington, DC 20460
      (202)475-9458
      E-MAIL: EPA3351

      James Thompson
      Section Head, Contracts Support
      401 M Street, SW
      Washington, DC  20460
      (202) 382-3232
      E-MAIL: EPA3707

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