ML17332A762
| ML17332A762 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 05/16/1995 |
| From: | Liza Cunningham NRC (Affiliation Not Assigned) |
| To: | Hodge W INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| References | |
| GL-88-18, NUDOCS 9505220225 | |
| Download: ML17332A762 (8) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C, 20555-0001
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~3/QIg Walter M. Hodge Plant Protection Superintendent Cook Nuclear Plant One Cook Place Bridgman, Michigan 49106
Dear Hr. Hodge:
In your letter of December 2,
- 1994, you asked if the 10 CFR 73.57(f)(4) and 10 CFR 73.57(f)(5) requirements for records on criminal history checks received from the FBI could be interpreted as allowing such records to be stored on optical disks vice storing the actual records.
As you noted in
- part, the 10 CFR 73.57(f)(5) requirement
- says, "The licensee shall retain all fingerprint cards and criminal history records= received from the FBI, or a
copy if the individual's file has been transferred, on an individual (including data indicating no record) for 1 year after termination or denial of unescorted access,to the nuclear power facility or access to Safeguards Information."'ubject to certain controls, optical disk storage of such records from the FBI satisfies the intent of the requirements in 10 CFR 73.57(f)(4) and 10 CFR 73.57(f)(5).
These controls are discussed below.
Controls are required to ensure protection of individual privacy rights.
Cook plant procedures submitted via FAX on April 12, 1995, describe how individual privacy rights will be protected.
These Cook procedures will, accordingly, be considered requisite conditions for use of optical disks to store records that require protection of individual privacy rights.
The specific Cook procedures are:
(1)
PHSO. 101, Rev.
11, para 5.0, "Control of Fingerprint Cards and Criminal History Reports;"
(2) 12 PMP 2060 ACS.002, Rev 0, para 12.3; and (3) 12 PPP 2040.ACS.001, Rev.
1, para 6, "Protection of Information."
Controls are required to ensure the quality of records put onto optical disks.
The quality controls delineated in Generic Letter 88-018, "Plant Record Storage on Optical Disks," of October 20,
- 1988, are requisites for an optical disk document storage and imaging system.
A copy of Generic Letter 88-018 is attached.
We understand that certain documents, such as fingerprint cards and criminal history records, will be retained in their original "hard-copy" form, whether or not they are also put onto optical disks.
We further understand that this I
9505220225 9505i6 PDR ADOCK '050003i5 P
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Walter M. Hodge category particularly includes documents associated with cases where adverse actions have been taken, or might later arise, relative to unescorted access (e.g.,
unescorted access being denied,
- revoked, suspended, etc.).
This letter does not entail or imply any changes to existing record storage and maintenance commitments or requirements.
Sincerely, Original signed by Docket Nos. 50-315/316
Enclosure:
As stated cc:
See next page Distribution:
':Central -Fi1 esi PPP TSGB r/f R. Spessard J.
Calvo R. Former, OGC S. Treby, OGC J.
- Hickman, NRR J.
Creed, RIII J.
- Belanger, RIII LeMoine J.
Cunningham, Chief Safeguards Branch Division of Technical Support Office', of Nuclear Reactor Regulation J
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DOCUMENT NAME:
G: iHENDRENiCOOK.001
- SEE PREVIOUS CONCURRENCE To receive a copy of this document, indicate in the box:
"C" = Copy without attachment enclosure, "E" = Co y with attachment enclos e, or "N" = No co y OFFICE TSGB'NRR E
NAME CHHendren DATE 05//6 /95 BC:
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OGC*
RLFonner 05/02/95 LJ n.
a 05/
95 OFFICIAL RECORD COPY
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Mr. E.
E. Fitzpatrick Indiana Michigan Power Company CC:
Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Attorney General Department of Attorney General 525 West Ottawa Street
- Lansing, Michigan 48913 Township Supervisor Lake Township Hall P.O.
Box 818 Bridgman, Michigan 49106 Al Blind, Plant Manager Donald C.
Cook Nuclear Plant 1 Cook Place
- Bridgman, Michigan 49106 U.S. Nuclear Regulatory Commission Resident Inspector's Office 7700 Red Arrow Highway Stevensville, Michigan 49127 Gerald Charnoff, Esquire
- Shaw, Pittman, Potts and Trowbridge 2300 N Street, N.
W.
Washington, DC 20037 Mayor, City of Bridgman Post Office Box 366 Bridgman, Michigan 49106 Special Assistant to the Governor Room 1
State Capitol
- Lansing, Michigan 48909 Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health Department of Public Health 3423 N.
Logan Street P. 0.
Box 30195
- Lansing, Michigan 48909 Donald C.
Cook Nuclear Plant Mr. S.
Brewer American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, Ohio 43215 Apical 1995
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C y*y4 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Generic Letter 88-018 PLANT RECORD STORAGE ON OPTICAL DISKS, 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 are applied.
Appendix B of 10 CFR 50, under criterion XVII, "equality 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 equality Assurance Records for Nuclear Power Plants,"
as endorsed by Regulatory Guide 1.88 (Rev.
2) and Basic Requirements 17, Supplement 175-1, and Appendix 17A-1 of ANSI/ASME-NgA-I 1983 edition, "equality 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.
~
The optical disk technology does not allow deletion or modification of record images.
~
The image of each record is written onto two optical disks.
~
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.
~
One optical disk is stored in the document imaging system for on-line retrieval.
~
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.
Generic Letter 88-018 PLANT RECORD STORAGE ON OPTICAL DISKS 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'his includes verification of the records so copied.
~ Periodic random inspections of images stored on optical disks are performed to verify that there has been no degradation of image quality.
~ 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 8 equality Evaluation
- Branch, (301) 492-1021 r'\\Cu)Su< L
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