U.S. Nuclear Regulatory Commission
Request for Interpretation Regarding Licensee Recordkeeping
HPPOS-204 PDR-9111210348
Title: Request for Interpretation Regarding Licensee
Recordkeeping
See the memorandum from J. W. N. Hickey to W. L. Axelson
dated May 19, 1987. Although computer storage of required
records is a broad issue, it appears that, in general,
records maintained on computer media would be appropriate.
An example, where computer storage is not appropriate, is
the situation in which a copy of a document is required to
be held. The health physics position was written in the
context of 10 CFR 20.311, but it also applies to "new" 10
CFR 20.2006.
Guidance was requested on whether records maintained only
on computer media and not in hard copy satisfy the
Commission's requirements for record-keeping. Computer
storage of required records is a broad issue, and NRC is
not able to address all situations that may arise for all
licensees. In general, however, records maintained on
computer media would meet the requirements of the
regulations in many cases, provided the records are
available for inspection and can be produced in hard copy
promptly upon request. Computer recordkeeping would not be
acceptable for those requirements that specify a copy of a
document must be held [see, for example, 10 CFR 20.311 (d)
(7) and 10 CFR 20.2006 (d), specifically Section III.B.5 of
Appendix F to 10 CFR 20.1001-20.2401. Note: 10 CFR 30.39
(d) (1) is no longer applicable]. It would be the
licensee's responsibility to take such measures as are
necessary to ensure the reliability of the records,
including protection from loss, tampering, alteration, or
destruction, as is the case with any required records.
Such measures should include storing separately one other
copy (backup) of the computer storage medium for the time
required.
Regulatory references: 10 CFR 20.311, 10 CFR 20.2006, 10
CFR 30.39
Subject codes: 2.1
Applicability: All