4 The record articles

Reflections from 2018 Year End Reporting – Part 4: DAHS Server Upgrades

Posted: March 6th, 2019

Authors: Matt C. 

Welcome to the fourth of a five-part blog series hosted by ALL4’s Continuous Monitoring Systems (CMS) Practice Area that looks back at some of the key points of discussion that came up while completing reports for the second half and fourth quarter of 2018 reporting periods.  In Part 4, we review potential issues that can result from a CMS data acquisition and handling system (DAHS) server upgrade.  Be sure to check out Part 1: Validation Sequence Impact on Data Validity, Part 2: Ancillary Analyzer Impacts on Data Validity and Part 3: Temperature Monitoring Impacts on Data Validity

The DAHS is a critical component for any CMS because it is the common link between all other components of the monitoring system, and often, for all CMS at a facility.  The DAHS functions to receive, calculate, manage, and record the data outputs from all analyzers (or monitors) and components of a CMS.  As the common link in a system (or multiple systems), issues with the DAHS can potentially cause invalid data for multiple CMS and can potentially affect the process at the facility.  In this past reporting period, we saw issues arise when DAHS software was upgraded as part of periodic maintenance completed by the DAHS vendor.  As an unintended consequence, the DAHS software upgrades caused missing data across multiple CMS.  The validity of data was affected while the upgrade was being completed.  Unfortunately, the impacts continued undetected by the facility for many days after the upgrade was complete.  As a result, operators were working “in the dark” with respect to certain compliance calculations and averages that were affected by the upgrade.  DAHS upgrades are periodically completed by the DAHS vendor; therefore, the facility can take steps to minimize any potential issues that may arise.  So, what can be done?

Well first off, establish a protocol that requires the DAHS vendor to ensure assigned plant personnel are notified prior to and during the DAHS server upgrade.  Consider including a plant personnel approval prior to actual work being performed.  The intent is to make sure that affected parties are in the know – the timing of the upgrade, what CMS are affected, when the CMS come back online, and can any lost data be restored.  Additionally, the facility should ensure that any site-specific changes that were made to the DAHS in the past are carried through to the upgraded DAHS.  Any of these site-specific changes that were made to the DAHS should be documented, and after the DAHS server is upgraded, the facility should confirm the DAHS is operating as expected.  In other words, what procedures does your DAHS vendor follow to manage change during these necessary upgrades to minimize downtime and ensure that the compliance demonstration within the DAHS remains unchanged.

If you have questions about planning for these upgrades or to get more information on what questions to ask you DAHS vendor, please reach out to me.  I can be reached at (610) 933-5246 extension 139, or at mcarideo@all4inc.com.

Don’t forget to look for Part 5, the last of this five-part blog series where we review the importance of accurate production data in the DAHS relative to facility records.  To ensure that you do not miss out on the action, signup below for our 4 The Record articles to receive timely updates of current hot issues, as well as in-depth articles that highlight important regulatory topics.

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