Plant Record Storage on Optical Disks (Generic Letter No. 88-18)

                                UNITED STATES
                           WASHINGTON, D.C. 20555

                              October 20, 1988



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 
are applied. 

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 
          on-line retrieval. 
     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 
          (301) 492-1021 

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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