View source for ULNRC-03156, Informs That Util Intends to Pursue Utilization of Optical Disk Technology for Storage & Retrieval of Documents, Including QA Records.Util Position on GL 88-18 Guidance for Storage of Records on Optical Disks Encl

{{Adams
| number = ML20080T532
| issue date = 03/07/1995
| title = Informs That Util Intends to Pursue Utilization of Optical Disk Technology for Storage & Retrieval of Documents, Including QA Records.Util Position on GL 88-18 Guidance for Storage of Records on Optical Disks Encl
| author name = Schnell D
| author affiliation = UNION ELECTRIC CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000483
| license number = 
| contact person = 
| document report number = GL-88-18, ULNRC-03156, ULNRC-3156, NUDOCS 9503130373
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 5
}}

=Text=
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:.                         St. touis. Missouri 6*3166 314 556 2650 DonaldF. Schnell L
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b-                      h3   March 7, 1995 U.S. Nuclear Regulatory Commission ATTN:- Document Control Desk E                            Mail Station P1-137 Washington, D.C. '20555 Gentlemen:                                               ULNRC-03156-DDCKET NUMBER 50-483 CALI AWAY PLANT PLANT RECORD STORAGE ON OPTICAL DISKS

==Reference:==
NRC Generic Letter No. 88-18, dated October 20, 1988 Union Electric intends at this time to pursue the utilization of optical disk technology for the storage and retrieval of documents, including Quality
{-                            Assurance records. Generic Letter 88-18 provides guidance pertaining to quality controls for an optical disk system. The attachment to this letter provides Union Electric's position on the Generic Letter 88-18 guidance for storage of records on optical disks. If you have any. questions regarding this information, please contact us.
Very truly yours, Donald F. Schnell WBM/sid Attachment                                                                                  ,
I 9503130373.950307                  I                                     '
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 ,                                                             AttCchment to ULNRC -03156 Page 1 of 3 UNION ELECTRIC RESPONSE TO NRC GENERIC LETTER 88-18
                     " PLANT RECORD STORAGE ON OPTICAL DISKS,"
DATED OCTOBER 20, 1988
                                                                              ~
NRC Generic Letter 8818 was issued to approve the use of optical
    . disk imaging systems when appropriate quality controls are applied.
The following is a list of quality controls from Generic Letter 88-18 and Union Electrec-s position on each. Commitments made herein will be incorporated into plant procedures.
Generic Letter                          Union Electric Position
     - 1. The optical disk technology        1. Complies. Union Electric does not allow deletion or             will use an optical disk modification of record images.          technology which does not allow deletion or modification of record images once they are written to optical disk.
: 2. The image of each record is        2. Complies. Each image will written onto two optical                be written onto at least disks.                                 two optical disks.
: 3. The legibility of each record       3. Scanned images will be is verified to ensure that             compared to hardcopy the image is legible on both           records on a simple basis, disks. If the image is                Sample method (s) will be illegible, the hard copy is            delineated in plant maintained as the record copy.          operating procedures.
A sample plan based on MIL-STD-1235C, plan CSP-V at a 99.6% acceptance level will be used initially. This sampling plan starts with a sampling of 100% of records until a pre-set number of documents successfully meets the acceptance criteria. The sampling frequency is then reduced.
Other sample plans may be used after the initial start-up period when the operating system has demonstrated the capability to consistently produce acceptable results.

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      ',.'                                                         Atttchment to ULNRC-03156
                       .                                            Page 2 of 3
            ' Generic Letter                    EUn ion Electric Position -
Union Electric!will'notLrely solely on-sampling until the-operating system has' demonstrated the: capability.
to consistently produce acceptable records.
The integrity of data transfers from the document scanners-to the optical.
disks will be verified using features of the operating.
system, hardware, or operating software. . Any discrepancies will be-
                                                     . corrected. Any documents whose scanned images are.
found illegible will~be maintained in hard copy..
: 4. One optical disk is stored     4.  . Complies.
in the document imaging system for on-line retrieval.
: 5. The second (backup) optical    5. Complies.
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.
: 6. To ensure permanent            6. Complies. If the need retention of records, the           exists to retain records stored on an                information on optical optical disk are acceptably         disks for longer than copied onto a new optical           the manufacturer's disk before the                     certified useful life, manufacturer's certified            the documents on the useful life of the original         affected optical disks disk is exceeded. This              whose required included verification of           retention periods have the records so copied.              not expired will be copied onto new optical disks prior to that time.
The integrity of data.
written onto the new optical disks will be verified.
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    , . .                                                                  ~Attechment to ULNRC-03156 Page 3 of 3 Generic Letter                       Union Electric Position 4
                 '7. Periodic; random inspections    7. Complies. . Sample. method     i
                      -of images stored on optical           will be. delineated in plant
                      ~ disks are performed to               procedures.                       .
verify that there has been                                             '
no degradation of_ image quality.
8.-   If the. optical' disk If the optical disk-
: 8. . document storage system document imaging. system'in                                             '
use is to be replaced by an          .is to be replaced with incompatible new system,             an. incompatible new
                      'the records stored on the             system prior to the old system's disks'are                expiration of the acceptably converted.into             required retention the new system before the           . period of documents-             '
old system is-taken out of            stored on opticalf service. This includes.               disks, the documents             ,
                      - verification of the records          which are required to            .
so copied.                           be retained at that time will be copied on-an acceptable media and' data integrity will-be verified prior to taking the old system out of service.
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                            ?.cc t - T.iA.-Baxter, Esq.
Shaw,~Pittmank Potts'& Trowbridge.
2300 N. Street, N.W.
j,_                   Washington, D.C.- 20037-M. H. Fletcher Professional Nuclear < Consulting, Inc..
18225-A Flower Hill Way Gaithersburg, MD- 20879-5334 lb. Rdbert Greger.
   ,                                 Chief, Reactor Project Branch 1
                                   ,U.S.' Nuclear Regulatory Commission-Region III' 801 Warrenville Road
                                   -Lisle, IL 60532-4351
    -:f                              Bruce' Bartlett Callaway Resident Office
                ,                    U.S. Regulatory Commission RR#1 Steedman, MO    65077 L. R.'Wharton. (2)
Office of Nuclear' Reactor Regulation U.S.-Nuclear Regulatory Commission 1 White. Flint, North,' Mail Stop 13E21
                                    -11555 Rockville Pike
                                    'Rockville, MD 20852 Manager, Electric Department Missouri Public Service Commission P.O. Box 360' Jefferson City, MO    65102
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