ML20044A530
| ML20044A530 | |
| Person / Time | |
|---|---|
| Site: | 07109006 |
| Issue date: | 06/22/1990 |
| From: | Roughan C AMERSHAM CORP. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9006290171 | |
| Download: ML20044A530 (22) | |
Text
.
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' Amersham Corporati n 40 North Avenue Burlington, Massachusetts 01803 Telephone (617) 272-2000 June 22, 1990 Mr. Charles MacDonald, Chief Transportation Branch Division of Safeguards and Transportation NMSS U.S. Nuclear Regulatory Commission OWFN 4E4-Washington, D.C.
20555
Dear Mr. MacDonald:
In. response to your request for additional information (letter dated June 1, 1990) for docket #71-9006, Model 500sU without a lock mechanism, I. submit the following.
1.
The operating procedures have been revised to reflect the use of the package without a lock machanism.
They have also been updated to _ reflect the recommendations. outlined in.your letter dated 31 May 1990 for the 500sU with a lock mechanism.
- 2..
Drawings have been enclosed which describe the Model 500SU without a lock _
These have a unique revision designation to distinguish them'from the new version of the package with a lock mechanism.
3.
Amersham Corporation has not manufactured any 500sU packages.
-The only manufacturing that occurs is the updating of the package with the approved lock mechanism and in some cases, the addition of shielding plates'which are already approved.
The descriptive assemblies have been revised-to show the differ-ent slopes of the Model 500SU.
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1 Mr. MacDonald Page Two.of two We contend that the different slopes do not impair the package's ability to withstand the package standards specified in 10 C FR Part 71, Subpart E.
I've enclosed an engineering analysis to reflect this.
I trust this answers your concerns.
If you need any additional information, please contact me.
We need to receive approval to ship this version as soon as possible.
We greatly appreciate your assistance.
Sincerely, D'
Cathleen M. Roughan Radiation Safety Officer CMR/bt Encl.
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ENGINEERING ANALYSIS The Model 500sU package was. originally f abricated by Automation
-Industries in the configuration of figure 1.
To accommodate longer length pigtails (i.e.
A-2-A, RGSA-13) the package _was -
changed to allow for shipment of these.
This change consisted of increasing the slope of the cover to allow for more room at the front of the source changer.
This is shown in figure 2.
l Upon the acquisition of Automation Industries by Tech / Ops in 1984, Tech / Ops submitted a consolidated application to NRC (dated March 1985) to obtain a Type B renewal for the 500SU.
This was based on test reports submitted by Automation Industries.
These-test reports do not indicate which version of the.500sU was tested.
In March 1986, Tech / Ops (subsequently Amersham) submitted an amendment to the package for an improved lock mechanism.-
At this time additional tests were conducted by Tech / Ops to prove the package met Type B requirements.
The version tested is shown in i
figure 2.
The revised package did receive Type B approval.
Given below is an engineering analysis to prove that both ver-j sions pass the package standards in 10 CFR Part 91, Subpart E.
I The two versions of the package are manuf actured the same way.
For example, all welding and assembly methods are identical.
The i
only difference is the slope of the cover.
This change in slope will not affect the following package stand-ards.-
(a)
Smallest package dimension greater than four inches for both versions l
(b)
A security seal is used on both versions of 500sU 1
(c)
Each version uses holddown caps, closure bolt and h
padlock to secure the source and package.
h (d)
Same materials of construction used on both versions (e)
NA 1
L (f)
See following paragraphs for 10 CFR 71.71
.l L
(g)
This was-shown in the original application and l_
difference'in slope will have no appreciable effect L
(h)
NA 10 CFR 71.45 l '
Lifting and tie down tests were satisfactorily performed on the 500sU handle.
The handle is the same on bott. versions, therefore the difference in slope makes no difference in the satisfactory performance as a result of this test.
10 CFR 71.47 Radiation profi2e results were given for 500sU shown in: Figure 1.
Tha difference in slope of the. cover does not affect the radia-tion-profile results.
In both versions the source remains in the stored position by proper use of holddown caps, thereby resulting in the same ac-1 c67 table profile results when loaded with the maximum capacity of 2?J curies.of Ir-192.
10 CFR 71.51 Compliance with these is demonstrated in paragraph 71.73.
10 CFR 71.71 (c)(1-6)
Change in slope has no effect in the package's ability to withstand these tests.
(c)(7)
See justification for more severe 30 foot drop test in the following paragraphs.
(c)(8) \\NA (c)(9)
Change in slope has no effect on package's ability-to withstand compression test.
,a.
(c)(1)
Free Drop and (c)(2) puncture The difference in the~ slope does not change the structural integrity of the package.
The following significant features do not change with a difference in slope.
1)
The gross weight of the package' 1
2)
The center of gravity of the container 1
3)
The hinge. point of the package 4)
Thickness of the cover plate (to 0.138 inch) 5)
securing mechanism for source assembly 6)
Same materials of construction and fabrication T
.These significant features determine how the package responds to the free fall-test.
Since all the features are the same for both' versions, the steeper slope package will accrue the
'l same: approximate damage as a result of the 30 foot drop test and the puncture test.
3
j
.The hinge;is the weakest point in.the securing mechanism, and is.the same for all 500SU's manufactured regardless of slope.
As-a result of the drop and puncture test, the hinge did. not break as described in our test report found in our applica-tion _ dated March 1986.
Since the hinge satisfactorily passed the: 30 foot drop test, the slight change in slope would not significantly affect the final outcome of the drop test, or the puncture test due to the identical weights, center of gravity and thickness of cover plates of'the. packages.
Both
~
versions of the 500SU would pass these required tests.
(c)(3)
There are no significant differences between the packages with steeper slopes than the_ prototype package tested for the thermal test As a result of the satisfactory performance of the package and the identical manufacturing methods for the different slope versions, both versione will pass-the thermal test..
i Based on the above comparisons and analyses, we contend'that the steeper slope version of the 500SU will satisf actorily pass all the required tests in 10 CFR Part 71, Subpart ' E for Type B(U)-
packages.
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Revision instructions-500.SU without mechanism
- Remove Page-Insert Page 1-19 to 1-21 7-22. to 7-34 revision 3 June 90' I
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500 SU SOURCE CHANGER b
OPERATION MANUAL NOTI.CE This-device is used as a radiographic source changer and Type B(U) transport package for the Amersham Corporation radioactive-sources listed in this manual.
The user should become thoroughly familiar with the instruction manual.before attempting operation of the equipment.
-In order to use this equipment to perform source changes within i
the United States, the-user must be specifically_ licensed -to do
- t so.
Application for a license should be filed on Form NRC-313 with the appropriate U.S.
Nuclear Regulatory Commission Region Office or with the appropriate agreement state office.
Prior to initial use of the source changer as a Type B transport package, the user in the United States must register' his name, license number and package identification number with:
Director Officer of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory. Commission Washington, DC 20555 The user must have in his possession a copy of USNRC Certificate of Compliance Number 9006 issued for this package._
l Prior to the first, export shipment of this source changer from the United States, the user must also register with:
Office'of Hazardous Materials Regulation Materials Transportation Bureau
-U.S.
Department of Transportation
-i Washington, DC '20590 The user must have in his possession a copy of International Atomic ' Energy Agency. Certificate of Competent Authority Number' USA /9006/B(U) issued for this source changer.
Users of this equipment outside the United States must comply with the regulatory, licensing and transportation rules and regulations as they apply in their respective countries.
I i
7-22 Revision 3 June 1990
Ge,neral
=-
The AI Model 500 SU source changer is used primarily for the transfer of encapsulated radioactive sources into radiographic
-exposure devices.
The source changer is designed to contain the radioactive sources during transport and' to permit the field exchange of source.
The source changer is five inches.(127 mm) wide, six inches (152-mm) high'and eleven inches (279 mm) long.
The total weight of I
the source changer is 60 pounds (27 kg).
The-source changer contains 39 pounds (18 kg) of depleted uranium as shielding.
The source changer is approved as a Type B(U) transport package under USNRC Certificate of Compliance Number 9006 and IAEA Cer-tificate of Competent Authority Number USA /9006/B(U).
The capac-ity of the source changer is 120 curies of iridium-192 as one of the source assemblies-listed in table 1.
NOTE:
This container is not authorized for sources which are not attached to pigtails or that are not listed in Table 1.
Shipment Data An envelope accompanies each shipment and contains a source certificate with decay data and leak test certification, a source identification plate for attachment to the user's radiographic exposure device, return shipping labels, tamper proof seals and an instruction manual.
Radiation Safety Considerations Pursuant to USNRC and agreement state regulations, all personnel present during radiographic and source changing operations are required to wear a direct reading-pocket dosimeter and either a film badge or a thermoluminescent dosimeter (TLD).
The pocket dosimeter must be recharged at the start of each shift.
The 3
' opera *or should frequently check the pocket dosimeter reading throughout the shift. ' Dosimeter readings must be' recorded at the end of each shift.
Records of the initial and final readings of the pocket dosimeter must be kept for inspection by the USNRC.
In the event that a person's pocket dosimeter is found to be off scale, that person must stop all work with radiation immedi ely.
-His film badge (or TLD) must be sent in immediately for,
aess-1 ing,. and he must not reenter a restricted area until it 1.-a been determined that he received less than the maximum allowed occupa-tional exposure as defined in 10 CFR Part 20.101.
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personnel performing source changing operations should also have l
a' calibrated and operable radiation survey meter capable of measuring form 2mR/hr to at least 1000 mR/hr to determine radia-tion levels when performing these operations, i
7-23 Revision 3 i
June 1990
~
_ _ ~
Arecs in which courca - chtnging is perform 3d must be idsntified.
Tf.a permanent radiographic installation is used, it must have-the appropriate personnel access control' devices as defined in 10 CFR 20.203.
Otherwise, certain areas must be established as follows:
Access to the Restricted Area must be controlled.
A Restricted Area is defined in 10 CFR 20.105 as the area i
where an individual could receive an exposure in excess of two milliroentgens in any one hour, or 100 milli-roentgens in seven consecutive days or 500 milli-roentgens in one year.
The Restricted Area should also be posted with signs reading " Caution (or Danger)
- Radiation Area."
signs reading " Caution (or Danger)
- High Radiation Area" should be posted around the perimeter where an individual could receive an exposure.
in excess of 100 milliroentgens in any one hour.
The radiographer or radiographer's assistant must guard against i
unauthorized entrance into these areas at all times.
No person-1 I
nel should be allowed into the restricted area without a direct reading pocket dosimeter and either a film badge or TLD.
Receipt o,_f_ Radioactive Material The consignee of a package of radioactive material must make arrangements to receive the package when it is delivered.-
If the package is to be picked up at the carrier's terminal, 10 CFR Part 20.205 requires that this be done expeditiously upon notification of its arrival.
Upon receipt, survey the source changer. with a survey meter as soon as possible, preferably at the time of pickup and no more than - three hours later if it was - received during ~ normal working hours, or no more than 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> later -if it was received af ter normal working hours.
Radiation levels should not exceed' 200
-milliroentgens per hour at the surface of the source changer nor g
10 milliroentgens per. hour at a distance of three, feet from the l
surface.
Actual radiation levels should be recorded on the L'
receiving report.
If the radiation levels exceed these ~1imits, the container should be secured in a Restricted Area,- and the appropriate personnel notified.
i All components should be inspected for physicEl damage.
The radioisotope, activity model number and serial number of the source and the package model number and serial number should be i
recorded..
Operation l
1.
Locate the source changer and the radiographic exposure L
device in a restricted area.
Arrange them so that they can be connected by the source guide tube extension which accompanies the source changer.
1 7-24 Revision 3 l
June 1990
4'
- t l 2.
Locoto tha control unit-to tha radiographic oxposure device.as far away as possible from the exposure device and preferably behind radiation shielding, i
3.
Unlock the source changer and open the cover.
Remove the envelope containing the documentation and remove the source guide tube extension.
4.
Connect the drive cable to the source assembly in the
. exposure device and connect the control unit to the exposure-device in accordance with the manufacturer's instructions and the company's operating and emergency.
procedures.
. 5.
Connect the guide tube extension to-the radiographic exposure device and to the fitting of the source 4
changer over the empty tube.
6.
Insure no unauthorized personnel are in the restricted area.
At the exposure device controls, crank the
. source assembly rapidly from the exposure device to the source changer.
Observe the survey meter during this i
operation.
The radiation intensity should greatly i
increase as the source is first exposed, decrease slightly as the source moves through the guide tube and reduce to background when the source enters the source 4
changer.
7.
Approach the exposure device with a survey meter; survey the exposure device on all sides, survey the guide tube and' survey the source changer on all sides i
to assure the source has been properly transferred and stored.
The radiation level should be less than 200-mR/hr and at the surface ~of the source changer and less than'10 mR/hr at'one meter from the surface of the source changer.
1 8.
While maintaining positive forward force on the drive i
cable and source assembly, disconnect the source guide.
- i tube extension from the source changer and expose the drive cable to source assembly connection.
Disconnect the drive cable from the source assembly.
Install the appropriate holddown cap over the source assembly.
9.
Remove the holddown cap from the other' source assembly.
Connect the drive cable to the source assembly.
. Connect the guide tube extension to the source changer fitting.
10.
Insure-no unauthorized personnel are in the. restricted area.
At the exposure device controls, crank the source assembly rapidly from the source changer to the exposure device.
Observe the survey meter during this operation.
The radiation intensity should greatly increase as the source is first exposed, increase 7-25 Revision 3 June 1990
slightly as the source' moves through the guide tube and decrease to background as the source assembly enters i
the exposure device.
]
11.
Approach the exposure device with the survey meter, 1
survey the exposure device on all sides, survey the length of the guide tube, and survey'the-source changer l
on all sides to assure the source has been properly transferred to its storage position in the exposure device.
Radiation levels should be less than 200 j
mR/hr at the surface and less than 10 mR/hr at one i
meter from the surface of the exposure device and the source changer.
12.
Remove the guide tube extension from the source changer and exposure device and. install it in the front compart-ment of the source changer.
13.
Affix the identification plate of the new source to.the exposure device.
Place the identification plate for the old-source in the source changer, secured to the appropriate holdown cap.
14.
Assure that the proper holddown cap is installed over.
the source in the source changer'(see Table 1).
Insert holddown' cap over empty tube also.
Insert seal wire through the holddown caps.
15.
Close the source changer cover and insert closure bolt.
and padlock and secure. Insert seal wire through closure l
bolt.
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u 7-26 Revision 3 June 1990
~
t shipment ~of Radioactive Source 1.
Assure.thEt the source assembly is secured in the
. proper storage position and the source changer is locked.
Assure that the source changer cover is sealwired with.a tamperproof seal.
2.
If the. source-changer is'to be packed in a crate or other outer packaging, the. outer packaging-must.be strong enough to withstand the normal conditions of transport.
These requirements are outlined in 10.CFR 71.71.
The' source changer should be put in the outer package with sufficient blocking to prevent shifting-during transportation.
3.
Assure the removable contamination levels on the outside of the package do not exceed 0.001 microcuries prior to shipment.
- 4.
Survey the package with a survey meter at the surface and at a dittance of one meter from the surface to determine the proper radioactive shipping labels to be applied to the package as required-by 49 CFR Part 172.403.
The radiation exposure limits for each shipping label are given~in figure 1. If. radiation levels above 200 mR/hr at the' surface or 10 mR/hr at one meter from the surface are measured, the package must not be shipped.
5.
Properly complete two shipping labels indicating the radioisotope, activity and the Transport Index.
The Transport Index is used only on Yellow II and Yellow.III' labels and is defined as the maximum radiation level in milliroentgens per hour measured at a distance of one meter from the surface of the.
package.
Put these two labels on-opposite sides of the.
package after' making-sure any previous labels ~have been removed.
The package should be marked with the proper shipping name (Radioactive Material, Special Form, n.o.s'.) and the identification number (UN 2974).
If the source changer is packaged inside an outer container, mark the outside package "INSIDE PACKAGE COMPLIES WITH PRESCRIBED SPECIFICATIONS -
TYPE B(U)
USA /9006/B(U)."
6.-
Complete the appropriate shipping papers - Examples are shown in Figure 2 and 3.
These shipping papers must include:
a.
Proper Shipping name (Radioactive Material, Special Form, n,o.s.) and Identification Number (UN2974).
THe letters '142 must be placed next to the proper shipping name if shipping more than 10 Ci of Ir-192.
7-27 Revision 3 June 1990
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b.
Name of Radionuclide (Iridium-192).
c.
Activity of the source (in' curies).
-d.
Category of Label Applied (i.e. Radioactive Yellow II).
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e.
Transport Index.,
1 f.
Package Identification Number (i.e. USA /9006/B(U)
Type B),
d g.
Shipper's Certification.
i "This is to certify that the above named materials are properly classified,t described, packaged, I
marked and labeled and are in proper condition for transport according.to.the applicable regulations of the Department of Transportation."
I NOTES:
1.
For air shipments, the following shipper's L
certification may be used:
t "I hereby. certify that the contents of this-consignment are fully and accurately y
described above by proper shipping name-and 1
are classified, packed, marked.and labeled.
y and are-in proper condition'for:carriageLby.
~C air according to applicable national governmental regulations."'
2.
For air shipments for, from'or through the United-States, a " CARGO AIRCRAFT ONLY" label-and the. shipping papers must state:
"THIS SHIPMENT IS WITHIN THE LIMITATIONS PRESCRIBED FOR CARGO.ONLY AIRCRAFT."
- 7;
- Due to the depleted uranium used as shielding in.the l t source changer, a notice must also be-enclosed'in or on the package included with the packing list,:or otherwise forwarded with the package.
This notice must include the name of the consignor:or consignee-and the-following' statement-t "This package conforms to the conditions and i.
limitations specified in'49'CFR 173'.424 for excepted L
. radioactive' material, articles manufactured from L
depleted uranium, UN 2909."
(;
8.
For shipment of an empty source changer, assure that there is no source in the container.
Securely insert the I
shipping plugs over the empty tubes.
Close the cover of the source changer, insert closure bolt and padlock. Seal wire through the closure bolt.
Survey the container and 7-28 Revision 3 June 1990
+
m mm
e prepare package depending upon the radiation levels obtained as given below, l
L
- a. If the radiation level is below 0.5 mR/hr at the surface and there is no measurable. radiation level at one meter from the container,'no label is required.. Mark the p-outside of the package with the proper shipping name L
(Radioactive Material, articles manufactured from de-1 L
pleted uranium UN 2909). ' Mark the outside of the g
package:
i
" Exempt from specification packaging, shipping paper and certification, marking and labeling and exempt from a
the requirements of Part 175 per 49 CFR 173.421-1 and 49.CFR 173.424."
]
Additiona31y, a notice must be enclosed in or on.the-package included with the. packing list or otherwise forwarded with the package..This notice must include the name of the consignor or consignee and the statement:
"This-package conforms to the conditions and-limitations specified in 49 CFR 173.424 for excepted radioactive materials, articles manufactured from depleted uranium, UN 2909."
b.
If the radiation level exceeds 0.5 mrem /hr, or if there' His a measurable radiation level-at one: meter from the surface, use~the criteria of table-1 to determine the proper shipping labels to be applied to the. package.
' Mark the outside of the outer shipping package with the-proper shipping name and identification number (Radio-1 active Material, LSA, n.o.s., UNf2912).
If the container is packaged inside a crate. or other outer packaging, mark the outer package with the state-ment "INSIDE PACKAGE COMPLIES WITH PRESCRIBED SPECIFICA-1 TIONS", USA /9006/B(U), Type B.
Properly complete the shipping papers, indicating:
1.
Proper shipping name-and identification number (i.e.
Radioactive Material, LSA, n.c.s., UN 2912 ii.
Name of the radionuclide (i.e. depleted uranium-238) 111.
Physical and chemical form (i.e. Solid Metal) iv.
Activity of the uranium 5 millicuries v.
Category of label applied (i.e. Radioactive, Yellow II) vi.
Transport Index 7-29 Revision 3 June 1990
.vii.
USNRC identification-number or DOT specification number (i.e. USA /9006/B(U))-
l viii.
For export shipments, the IAEA identification number' (i. e. - USA /9006/B(U))
ix.
Shipper's certification:
'"This is to certify that the above named materials are properly classified, described, packaged, marked and' labeled, and are in proper condition for trans-port according to the applicable _ regulations of the Department of Transportation."
NOTE:
1)-
For air shipments, the following Shipper's Certifica-tion may be used:
"I hereby certify that the contents of this consign-
~
ment are fully and accurately described above by proper shipping name and are classified, packed,-
marked and labeled, and are in. proper condition for carriage by air according to applicable national
. governmental. regulations.
2 )-
For air shipments, the package must be labeled.with a " CARGO AIRCRAFT ONLY" label, and.the shipping papers must state:
"THIS. SHIPMENT IS WITHIN THE' LIMITATIONS PRESCRIBED FOR CARGO-ONLY AIRCRAFT".
9.
Return the container to Amersham. Corporation according to' proper procedures for transporting radioactive 1
material as established in Title 49 Code of Federal Regulations part 172-178
' 4,7 NOTE:
The,U.S. Department 1of Transportation, in 49 CFR 173.22 (c) requires each shipper of Type B H
quantities of radioactive material to provide prior notification to the consignee of the dates of shipment and expected arrival.
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7-30 Revision 3 I
t June 1990 x
i ' <
Table 1 i
Source Assemblies Used In t
Conjunction With The Model AI 500 SU Source Changer Without Lock Mechanism Amersham Source Assembly Desions Holddown Cap Desions 848 T
A-1-A N
A-2-A G
RG-13 N
RG SA-13 G
89911 N
89912 G
877 N
879
.G ci
\\
LA424-9 T
A424-1 T
866 P
-B-8-A P
~B-8-T P
1
=i 3
.~(
- 500SU-
'k d
-l.
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fr ll 7-31 Revision 3 June 1990 i
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1 s
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4 I
1 1
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Maxime:. Radiat ion Level
~ ~ ~
at Surface at One Meter Radioactive Whit e I e&
0.5 mk/hr None R,ADIDAt1M i 7
Radioactive Ye llow 11 e&
$0 mR/hr 1.0 mR/hr RADIOACIM ll,7
/.
7/
I
/
Radioactive Yellow III g'.
O 200 mR/r.:
10 mk/hr
\\ RADl0ACIM lli ' '
\\U.!
N/
i 7-32,
o L
l CAR WA UNIF8RM STRA10HT BILL @F LADING
- '#'aiat e ot ies sotaeur
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Amersham Corporation Amersham Corporation 40 North Avenue Hollyfteld Drive Durlington, Massachusetts Ot603 Baton Rouge, LA 70898 tittPHONE $17 2724000 L
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... re,,,e,..,e r, SHIPPERS CERTIFICATION ATTACHED FOR THE FOLLOWING PACKING LIST (S):
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Model 500 Sil source channer c'CN$'t radioactive ma erial, special form NOS, UN2974 etuva ny CHARGt RQ AovANet cod Iridium-192 84 curies CMAAGt Aov& Net TRAN$
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USA / 9006/B(U)
- CMARGE tactss CMARGE Type B(U) Package sus tet At coNsiGNon s toO Radioactive Yellow 11 labela cod Ftr t ransport indez_ 0.8 TOTAL COMutNis RELEASED VALUE NOT TO EXCEE0 40c PER POUND This is to certify that the above Mmed materials are property classified, described.
packaged, marked and labeled and are in proper condition for transportation according to the applicable regulations of the Department of Transportation.
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SHIPPtR'8 D6 CLARAh006 PCR DANetCOV8 0000$
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Aner6 ham Corporation i
40 North Aeenue Page of Pages
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shipper s heteronce Numbee Conaves Amersham International White Lion Road ENGL.AMD I
we cawoo ona ssnea cwm or en o, ewer on mast be nansea to tne werero' WARNING YRANSPORT OETAILS Failure to comply in all tospects witn tne aDphcable This 659 ment a woun tie Da porous G ds Regulations may be in bream of me ort of Departuit,
- 6. nations prominee tor.
appi cable law, sub#ect to legal penalties Trus Deetatation Logan, Boston m.rst not, in any circumstances, be completed and/or
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sgned by a conson.cator a forwa'Oer or an IATA cargo PASSE NGER CARGO agent ANDEAmGO AIRCRAM AIRCMAM ONLY Arpon ot Destinetson:
$hement type,pswo # ion yp6cetwei g,, g,,,,,
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NATURE.*.ND OV ANTITY OF DANGEROv$ GOODS
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I hereby declare that the contents of ins consegnment are tulty and accuratory Name/T!tle of Sqnstory detenbed above by proper aNpping name and are dassrhed, packed ma&ed and labelled. and are in all respects in me proper constion for transport by air W
ITes h Phos and Date acooren0 to me appbcable intomabonal and Nabonal Govemment Regula.
- bons, Burlington.M A U.S. A.
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