Plant Record Storage on Optical Disks (Generic Letter No. 88-18)
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20555
October 20, 1988
TO: ALL LICENSEES OF OPERATING REACTORS AND HOLDERS OF CONSTRUCTION PERMITS
SUBJECT: PLANT RECORD STORAGE ON OPTICAL DISKS (GENERIC LETTER 88-18)
The NRC has been requested by two utilities and an NSSS supplier to approve
the use of optical disk document imaging systems for the storage and
retrieval of record copies of quality assurance records. The purpose of this
generic letter is to inform addressees that the staff approves the use of
this method of record keeping when appropriate quality assurance controls
Appendix B of 10 CFR 50, under criterion XVII, "Quality Assurance Records,"
establishes requirements for a record keeping system, and chapter 17 of the
Standard Review Plan (NUREG-0800) expounds on these requirements. The
purpose of the record keeping system is to ensure that records are available
when needed. ANSI N45.2.9-1974, "Requirements for Collection, Storage, and
Maintenance of Quality Assurance Records for Nuclear Power Plants," as
endorsed by Regulatory Guide 1.88 (Rev. 2) and Basic Requirements 17,
Supplement 17S-1, and Appendix 17A-1 of ANSI/ASME-NQA-1 1983 edition,
"Quality Assurance Program Requirements for Nuclear Facilities," as endorsed
by Regulatory Guide 1.28 (Rev. 3) both describe quality assurance controls
regarding records. Appropriate quality controls for an optical disk document
imaging system include the following:
o The optical disk technology does not allow deletion or
modification of record images.
o The image of each record is written onto two optical disks.
o The legibility of each record image is verified to ensure that the
image is legible on both disks. If the image is illegible, the
hard copy record is maintained as the record copy.
o One optical disk is stored in the document imaging system for
o The second (backup) optical disk is stored in a records storage
facility meeting the requirements of ANSI N45.2.9-1974 for single
copy storage or in a separate remote location.
o To ensure permanent retention of records, the records stored on an
optical disk are acceptably copied onto a new optical disk before
the manufacturer's certified useful life of the original disk is
exceeded. This includes verification of the records so copied.
o Periodic random inspections of images stored on optical disks are
performed to verify that there has been no degradation of image
o If the optical disk document imaging system in use is to be
replaced by an incompatible new system, the records stored on the
old system's disks are acceptably converted into the new system
before the old system is taken out of service. This includes
verification of the records so copied.
Contact: J. Spraul, Performance & Quality Evaluation Branch
Generic Letter 88-18 -2- October 20, 1988
Licensees using optical disks for record storage should notify the NRC in an
updated FSAR per 10 CFR 50.71(e) or by letter per 10 CFR 50.4 (b)7. License
applicants should notify the NRC in the SAR per 10 CFR 50.34.
Dennis M. Crutchfield
Acting Associate Director for Projects
Office of Nuclear Reactor Regulation
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