LICENSING REVIEWS AND DESIGN RECONCILIATION

Certified packaging designs are defined by the packaging certification or licensing drawings, which are usually part of the formal safety analysis and which are referenced in the certificate of compliance granted by the cognizant regulatory authority. The packaging fleet, on the other hand, is typically fabricated using a separate drawing set, which contains much more detail than does the licensing drawings. The same is true for specifications, procedures, and tests: delineated in simplified form in the safety analysis, but containing more detail for actual site use. Document reviews must be performed to ensure that the drawings, specifications, spare parts lists, and operating manuals are consistent with the certification safety documents. Because the USNRC does not grant change authority to the certificate holder, the packagings must strictly conform to the licensed packaging drawings. However, to successfully fabricate a packaging, both more detail and a tighter control of tolerances is typically needed. Thus, a separate set of drawings is created, typically denoted as fabrication, or shop drawings. But it is important that the fabrication drawings and related documents remain in compliance with the licensing drawings. Thus the need for a formal reconciliation of the two. This paper compares the two types of documents, and discusses the performance and timing of licensing reconciliation reviews. It closes with several case studies of issues that could arise from incomplete or ill-timed reviews.