That's not entirely true... they do need checking sometimes. The reason it
is generally never done is because of the NVRAM log of all write traffic.
Crashes and sudden power-downs don't have the same effect on the filesystem
as the unwritten data is not lost. Damage the NVRAM, and you have a corrupted
WAFL. There are ways to fsck the array, but they are not normally made
available to users.
Think of it as an ext2fs that, sans bugs, never gets shutdown improperly. Such
a fs would, in theory, never need to be checked.
--Ricky
PS: I can point out more than a few ways to foobar a NetApp's filesystem.
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