ML20134P021

From kanterella
Jump to navigation Jump to search
Ack Receipt of 960409 Application Requesting Safety Evaluation & Registration of Models G2397A,G2398A,G2404A & G2405A
ML20134P021
Person / Time
Issue date: 04/16/1996
From: Randall K
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Donnelly B
HEWLETT PACKARD CO.
Shared Package
ML20134N945 List:
References
SSD, NUDOCS 9702250068
Download: ML20134P021 (1)
v • d • e


Text

. .

, [.#*%

y% ,g

= 3 UNITED STATES

( ij 8

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 16, 1996 ASSIGNMENT NUMBER: 96-19 Mr. Brian Donnelly Hewlett-Packard Company 2850 Centerville Road Little Falls Site Wilmington, DE 19808

SUBJECT:

ACKNOWLEDGEMENT OF REQUEST FOR SAFETY EVALUATION

Dear Mr. Donnelly:

This letter acknowledges the receipt of your April 9,1996 application that requested a safety evaluation and registration of the Models G2397A, G2398A, G2404A and G2405A. We have performed a cursory review of your application and determined that enough information has been provided to allow a technical reviewer to initiate the evaluation process. Applications are assigned to technical reviewers on a first-in basis. Therefore, your application will be assigned in turn. Please note that the technical reviewer may contact you to request information that was omitted from your application or to obtain clarification of technical issues concerning your application. If you have any questions concerning the status of your application, please contact me at j (301) 415-7857. Please reference the assignment number listed above in your  ;

questions or correspondence.

Please be aware that your request may be subject to the NRC's application fees in accordance with 10 CFR Part 170. Therefore, a copy of your application has I

been forwarded to the License Fee and Debt Collection Branch for approval of the fee category and amount. If you have any questions concerning the fees associated with your application, please contact the License Fee and Debt Collection Branch at (301) 415-7544.

Sincerely, C

n/jup/ / )&: dad KimBerly Randall, Registration Assistant Sealed Source Safety Section Medical, Academic, & Commercial Use Safety Branch Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards 9702250068 960731 PDR RC

p._ _ __- ____ _ _. _ - _ ____ ___. _ _ _ ._ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _

' ' ws e . AE i 4 UNITED STATES E NUCLEAR REGULATORY COMMISSION 6 WASHINGTON, D.C. 20SSSet 4 JUL 121993 i

Francis E. Roy Jr.

Du Pont Merck Pharmaceutical Co.

Rad 13 pharmaceutical Division l 331 Treble Cove Road N. Billerica, MA 01862 4

Dear Mr. Roy:

]

! ~ Based on the information submitted in your letter dated May 4,1993, with

enclosures thereto, we have made the changes to the enclosed registration certificate NR-476-S-131-S as you have requested .

I

!' We have broadened the principle use code of these models to code (S), Foil Source. We understand that the models, NER-004.and NER-004P, designate that the Nickel-63 is either a source or is electroplated onto components. This i activity can occur under principle use code (S). We have included examples of ,

uses of the sources under the " Conditions of Normal Use" section of the j registration for clarity. ,

! Please be advised that you must manufacture and distribute the product in j accordance with the statements and representations contained in your application, with enclosures thereto, and the information set out in your

! registration certificate._ As a general rule, you must request and obtain an j amendment to the certificate before you make changes or modifications to the

information submitted to obtain the certificate.

Please read over the registration certificate in its entirety and notify us

immediately of any errors or omissions.

You are obligated to notify us promptly in writing should you decide to no i longer manufacture or offer-service support for the product.

i i

If you have any questions, please contact me at (301) 504-3336 or Mr. Steven l

Baggett at (301) 504-2542.

l Sincerely, l M

  • A--

l Michael Russ, Co-op Engineer

1. Sealed Source Safety Section i

S'urce o Containment and Devices Branch 1 Division of Industrial and i

  • Medical Nuclear Safety, NMSS j

Enclosure:

As stated cc: SKimberley, LFDCB (w/ encl.)

hff l470:09cn C -- /p- - .. - -- -

l l

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF SEALED SOURCE (AMENDED IN ITS ENTIRETY) d DATE: June 25, 1993 PAGE 1 OF $

NO . :. NR-476-S-131-S

\

4 SEALED S_O__URCE TYPE: Beta Ionization Source MODELL NER-004, NER-004P

(

MANUF ACTUR ER /II T STRT HUTOR :

i 1

Radiopharmacentica1 Division j The Du Pont Merck Pharmaceutical Company '

331 Treblo Cove Road )

North Billcrica, MA 01862 l

4 TSOTOPF: MAXTMtfM ACTIVITY:

i 1 50 millicuries (1.85 GBq)

Nickel-63  !

i LEAK _TIST FREQLIENcy1 6 months i

I I

PRINCIPLE USE: (S) Foil Source YES X NO CtfSTOM SotTBCE:.

$f0 sm= w

. - - -. . . . _ . . - _ _ - , . - - _ . . _ . _ . _ - - . _ _ - _ _ . - - _ . . . _ ~ . . . . ~ - . .. -_ - - . -

l

' i r

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF SEALED SOURCE

( AMENDED IN ITS ENTIRrrY)

NR-476-5-131-S DATE: June 25, 1993 EAGE 2 OF 5 i HQti i i .

SEALED SOURCE TYPE: Beta Ionization Source l l

l DESCRIPTION:

i The' sources consist of radioactive Ni-63 electro 1 css plated or i

electroplated onto components fabricated from the approved materials in the following table:

d Model Approved Base Materials

' NER-004 gold, platinum, nickel, copper, or monel (copper-nickel alloy)

[ NER-004P gold, platinum, nickel, copper,

' monel, stainless steel The HER-004 indicates a foil configuration of Du Pont design and l manufacture. The NER-004P allows plating onto components of j l

4 other manufacturer's design and manufacture. All sources must l

! mest the following constraints:

l i

maximum activity: 50 mci (1.85 GBq) minimum specific activity: 5 oci/mg (0.185 GBq/ag) radiopurity of Ni-63: > 99.9%.

! LABELINGL 1

The Model NER-004 foils are serialized by scribing or laser engraving on the non-radioactive side.

l The Model NER-004P pources are permanently marked on a non-i radioactive surface of the component with the radiation symbol,

' serial number and model number (i.e. "NER-004p"). If space permits, the sources will also be labeled with the isotope, activity and the words " Caution, Radioactive Material."

DIAGRAM:

Attachment i shows diagrams of dose rate locations.

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF SEALED SOURCE (AMENDED IN ITS ENTIRETY)

HQ21 NR-476-S-131-S DATE: June 25, 1993 PAGE 3 OF 5 SEALED SOURCE TYPE: Beta Ionization Source CONDITIONS OF NORMAL USEL The Models NER-004 and the NER-004P are beta ionization, sources  !

and are routinely used in gas chromatograhpy systems, gas ,

detection equipment, and aerosol neutralization applications. l The sources shall not be subjected to temperatures which exceed '

752*F (400*C).

4

PROTOTYPE TESTING

The manufacturnr tested prototype Models NER-004 and NER-004P sealed sources to the ANSI N542-1977 77C32211 requirements. In addition, the prototypes were subjected to 752*F (400*C) in air i for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Wipes of the inactive side of the sources after the tests revealed no removable contamination above 0.005 microcurie (185 Sq).

l EXTERNAL RADIATION LEVELS: l The manufacturer reports maximum external radiation levels as follows:

~~

. Model~ Dose Rate (deep / shallow) mrem /hr/ mci _mSv/hr/GBq

NER-004 on contact with active side 0.lb/12.3 0.04/3.32 j inactive side 1.1 /1.1 0. 3 0 / 0. 3 0 ___,

NER-004P at mouth of cavity *

-0.11/6.7 _ 0.03/1.81 l See Attachment 1 for diagrams of dose rate locations.

l
  • The electroplating is typically within a cavity of the component and this in the typical radiation dose when installed in the cavity.

OUALTTY ASSITRANCE AND CONTROL:

Du Pont Merck had previously described a quality assurance program which has been deemed acceptable for licensing purposes.

The progras consists of the following basic components:

- . -- . --_ .. -- . - - - - . . . _ _ . - - . - - ~ ~ - . - - - - - ._

4 1

?

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF SEALED SOURCE (AMENDED IN ITS ENTIRETY) ,

KR-476-S-131-5 phTE1 June 25, 1993 PAGE 4 OF 5

HO.

I SEALED SOURCE TYPEL Heta Ionization Source

]

i

OUALITY ASSURANCE AND COFIRot (cont.1
  • Design control .

S Procurement control

- Process quality control including content activity measurement, leak tests, physical dimensions and visual inspection

  • Final acceptance and records A copy of the program is on file with the Source containment and Devices Branch.

. LIMITATIONS AND/OR OTHER CONSTDERATIONS OF USE!

s i . The maximum activity concentration shall be 15 millicuries (0.555 GBq) per square centimeter.

I

  • The source, when used in the United States, shall be j distributed only to those persons specifically licensed by
the NRC or an Agreement State. Distribution outside the
United States should be to persons authorized by a i regulatory authority, as appropriate.

i

- The source shall not be subjected to pressures or impact which exceed the ANSI NS42-1977 classification of 77C32211.

i - The sources shall not be subjected to temperatures which

exceed 758*F (400*C).

}

  • The model NER-004P shall only be used in devices which are registered with the NRC or an Agreement State, a

The source shall be leak tested at intervals not to exceed 6

) months using techniques capable of detecting 0.005 l microcurie (185 Bq) of removable contamination. Removable

contamination from the inactive side shall not exceed 0.005 i' microcurie and the active side shall not exccod 0.5 microcurie (18.5 kBq).

1

?

i i

. - _ _.~_ - - _ - - - _ - - - . - - - - . . . - -

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF SEALED SOURCE (AMENDED IN ITS ENTIRETY)

QATEL June 25, 1993 PAGE 5 OF 5 HQti NR-476-S-131-5 2

3 SEALED SOURCE TYH L Beta Ionization source LYMITATIONS AND/OR OTHER CONSIDERATIONS OF USE (cont'dir

- - Handling, Storage, Use, Transfer, and Disposal: To be determined by the licensing authority. I f

This registration sheet and the information contained with the references shall not be changed without the. written consent of the NRC. ,

I SAFETY ANALYSIS

SUMMARY

1 4

Based on our review of the information and test data cited below, we continue to conclude that the Du Pont Merck Models NER-004 and NER-004P mealed sources are acceptable for licensing purposes.

} Furthermore, we continue to conclude that the sources would be expected to maintain their containment integrity for normal i

conditions of use which might occur during the uses specified in l this registration sheet.

. l

! REFERENCESL The following supporting documents are hereby incorporated by l

reference and are made part of this registry document.

  • Du Pont Merck letters dated December 9, 1991, May 15, 1992, l

} June 11, 1992, and July 31, 1992, and May 4, 1993, with enclosures thereto.

+ NEN Products letter dated October 1, 1984, with enclosures thereto.

i ISSUING AGENCY 4

l-U.S. Nuclear Regulatory Commission '

/

'fj7 <: _

L June 25, 199) Reviewer: ' M,'l ' 'NV Date -

Steve ~ aggett

]

Date June 25. 1993 Concurrence _

40' V6' j _}/"JohnLubinski 1

i i

d

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF SEALED SOURCE (AMENDED IN ITS ENTIRETY)

NO, NR-476-S-131-S DATE: June 25, 1993

, ATTACHMENT 1 SEALED SOURCE TYPE: Beta Ionization Source 4

NER-004 DOSE RATE REPORT NI-63 ' HOT' SIDC NI-63 SOURCC FOIL et e2 INACTIVC ' COLD' SIDE TYPICAL CCD CCLL NI-63 SOURCC FOIL

\ ,

/ INSTALLCD IN CAVITY i

\ T v

( L-- s #3

\ T- s y \ ^

LOCATION DOSC RATC M' mRCM/HR/ MCI DCCP / SHALLOV

  1. 1 0.15 / 12.3

) e2 1.1 / 1J e3 0.11 / 6.7 NOTES

1. THC 'LANDAUCR' DOSC REPORT IS THC DOSIMCTRY DATA FOR THC DURATION OF THC SURVCY (4 HOURS) USING A 15 MCI NI-63 SOURCC FOIL.
2. TLD BADGCE ARC 'LANDAUCR' TYPC K.

y--_-__-_____________________.___________________________

-l NRC FORM 374

} 4 h l (10-89) U.S. NUCLEAQ QEGULA10RY COMMISSION E OF W ES I i g MATERIALS LICENSE g I

p Fursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974 (Public Law 93-438), and Title 10,

(; Code of Federal Regulations, Chapter I, Parts 30, 31, 32, 33, 34, 35, 39,40 and 70, and in reliance on statements and representations heretofore p

{E g

N made by the licensee, a license is hereby issued authorizing the licensee to receive, acquire, possess, and transfer byproduct, source, and special .N N

nuclear material designated below; to use such matenal for the purpose (s) and at the place (s) designated below; to deliver or transfer such material N i to persons authorized to receive it in accordance uth the regulations of the applicable Part(s). This license shall be d g specified in Section 183 of the Atomic Energy Act of 1954, as ame ded, and is subject to all applicable rules, regulations and orders of the Nuclear l g

g Regulatory Commission now or hereafter in effect and to any conditions specified below. lg X- !I Licensee l 1. Hewlett-Packard Company 3. Ucense number 07-28762-01 t(

l 1

lN

'N 1

i s 2. Little Falls Center 't i 2850 Centerville Road 4. Expiration date October 31, 1997 i  ;

I Wilmington, Delaware 19808 5' Docket or  !

f Reference No 030-32792 (37-07002-02) y Nj 6. Byproduct, source, and/or 7. Chemical and/or physical 8. Maximum amount that licensee $

di special nuclear material form may possess at any one time II:

under this license N I I

A. Hydrogen 3 A. Titanium Tritide Foils A. 5 curies total

B. Nickel 63 B. Plated sources and parts B. 50 curies (

g g C. Nickel 63 C. Foils C. I curie i g D. Nickel 63 D. Any D. 1 millicurie L g

,tii 4 9. Authorized use I '

I t-l A. through C. For use in the development, testing, production and assembly of detector hj g!

cells; repair and maintenance of detector cells; demonstration of use of ni g detector cells; and for distribution in detector cells to persons  ;

il I

authorized to receive the licensed material pursuant to terms and conditions of specific licenses issued by the Nuclear Regulatory Commission p

[S '

I or any Agreement State. C >

l D. For use in the development, testing, production, assembly, repair and maintenance of detection cells, and for storage of waste materials.

I y CONDITIONS I i N 10. Licensed material may be used at the licensee's facilities at Little Falls Center, jJ j 2850 Centerville Road, Wil;nington, Delaware 19808, and at temporary job sites of the i N

licensee anywhere in the United States where the U.S. Nuclear Regulatory Commission  ;

maintains jurisdiction for regulating the use of licensed material.

g l [h 1 11, A. Licensed material shall be used by, or under the supervision of Brian Donnelly, ll N Irv Maiorano, Rick Phillips, Paul Larson, Vernon Garner, John V. Wisniewski, Marvin Welsh, James Peters, William Howell and Richard H. Kolloff.

l l B. The Radiation Safety Office for this license is Brian Donnelly.

I I

I I, 68& N l_  :/%S?95W7 W/2

=---m--------------------------------------,-y r=NRC Fcrm 3s4A U.S. NUCLEAM REGULATcRY COMMISSION PAGE 2 OF 4 PAGES !

l License nurnber l l

~

MATERIALS LICENSE nocket or Reference nufber SUPPLEMENTARY SHEET P

I I i l (Continued) CONDITIONS l

I R g 12. This license does not authorize commercial distribution of licensed material to y q persons generally licensed pursuant to 10 CFR 31 or to persons exempt from licensing N N pursuant to 10 CFR 30.18. I i l l 13. A. Sealed sources and detector cells shall be tested for leakage and/or l

, contamination at intervals not to exceed 6 months or at such other intervals as y i are specified by the certificate of registration referred to in 10 CFR 32.210, g I not to exceed 3 years. I I I N B. Notwithstanding Paragraph A of this Condition, sealed sources designed to emit I l alpha particles shall be tested for leakage and/or contamination at intervals not y to exceed 3 months. - l 1

y i I q C. In the absence of a certificate from a transferor indicating that a test has been i made within six months prior to the transfer, a sealed source or detector cell I received from another person shall not be put into use until tested. j 1

D. I:ach sealed source fabricated by the licensee shall be inspected and tested for y construction defects, leakage, and contamination prior to any use or transfer as i a sealed source. i

. _ . _ .;f- I E. Sealed sources and detector cells need not be leak tested if: 1 4 .

I

~

(i) theycontainonlyhydrogen3;]or ,

g

..m.. s.- .. ,

(ii) they contain only a gas; or _f.

l (iii) the half-life of the isotope is 30 days or less; or l

(iv) they contain not more than 100 microcuries of beta and/or gamma emitting g material or not more than 10 microcuries'of alpha emitting material; or E

, p (v) they are not designed to emit alpha particles, are in storage, and are not F being used. However, when they are removed from storage for use or transfer to another person, and have not been tested within the required leak test l y

interval, they shnll be tested before use or transfer. No sealed source or g detector cell shall be stored for a period of more than 10 years without i being tested for leakage and/or contamination.

l l

R I

B l

l P

N

.i i

P I

f I

E

- ir------=--=.

_J, p----------------------------------------------------y

.l NRC Ferm 374A U.S. NUCLEAR REcULATORY COMMISSION FAGE 3 or 4 PAGES I l License number l l MATERIALS LICENSE Docket or aereience nu  :

4 SUPPLEMENTARY SHEET l l 030-32792 (37-07002-02) y l P 1 - W l

l (13. continued) CONDITIONS l

l R i F. The test shall be capable of detecting the presence of 0.005 microcurie of l i radioactive material u.. the test sample. Records of leak test results shall be i I kept in units of microcuries and shall be maintained for inspection by the I i Commission. If the test reveals the presence of 0.005 microcurie or more of I l removable contamination, a report shall be filed with the U.S. Nuclear Regulatory Commission and the source shall be removed from service and decontaminated, l g ,

i repaired, or disposed of in accordance with Commission regulations. The report g i shall be filed within 5 days of the date the leak test result is known with the 1 l d U.S. Nuclear Regulatory Commission, Region I, ATTN: Chief, Nuclear Materials I

  1. Safety Branch, 475 Allendale Road, King of Prussia, Pennsylvania 19406. The I l report shall specify the source involved, the test results, and corrective action l

1 y taken. y I i i G. The licensee is authorized to collect leak test sampls for analysis by the l l 8 licensee. Alternatively, tests for leakage and/or contamination may be performed I 8 by persons specifically licensed by the Commission or an Agreement State to I l perform such services. -

, l 1 '

i  ;

i 14. The licensee shall conduct a physical inventory every 6 months to account for all l l l sources and/or devices received and possessed under the license. Records of i q

I inventories shall be maintained for 5 years from the date of each inventory. I 4 I l 15. In lieu of using the conventional radiation caution colors (magenta or purple on l l yellow background) as provided in 10 CFR 20.203(a)(1), the licensee is hereby y

, i authorized to label detector cells and cell baths, containing licensed material and R i i used in gas chromatography devices, with conspicuously etched or stamped radiation n

!!I caution symbols. 3 i E i l 16. Detector cells containing a titanium tritide foil or a scandium tritide foil shall l l g only be used in conjunction with a properly operating temperature control mechanism y N which prevents foil temperatures from exceeding that specified by the manufacturer.

p 1 I!

< l 17. Any proposed changes in packaging, labelling, shielding, or instructions for use and W l l

l storage shall be submitted for review to the Nuclear Materials Safety Branch, U.S.  !

y Nuclear Regulatory Commission, Region I, 475 Allendale Road, King of Prussia, i l 1 Pennsylvania 19406 and approval of the changes shall be received by the licensee n i prior to implementing the changes. I N I

18. The licensee may transport licensed material in accordance with the provisions of l 10 CFR 71, " Packaging and Transportation of Radioactive Material". l l ,

I i N I 19. The licensee shall not store licensed material contained in waste for more than two p i

I (2) years from the date the waste is put into storage or November 1, 1992, whichever i '

I is later. The licensee shall maintain records which indicate the date that licensed i l material contained in waste is put into storage. This condition does not apply to l g licensed material intended for disposal by decay-in-storage pursuant to 10 CFR 35.92 h I or other conditions of this license. p d M l l 1 4 8 l

Ll .---------------- -

- p -- 2 N

l

r------------_L-- _------- -----------------------------

,l NRC Fem 374A U.S. NUCLEAR REcULATcRY COMMISSION O' " '

PACE 4 OF 4 PAGES

, 1 License nurnber l

! MATERIALS LICENSE Docket or Reference nu I I SUPPLEMENTARY SHEET I i 030-32792 (37-07002-02) p I f ,

1 I l 1 1 1 (Continued) CONDITIONS l I l t i 20. Except as specifically provided otherwise in this license, the licensee shall conduct g I y its program in accordance with the statements, representations, and procedures t l l contained in the documents, including any enclosures, listed below. The Nuclear 1 8

Regulatory Commission's regulations shall govern unless the statements, I l representations, and procedures in the licensee's application and correspondence are

more restrictive than the regulations. l p

i i

, i A. Drawings attached to original application dated September 16, 1992 I I B. Revised application dated September 16, 1992 that was attached to a letter dated i I October 19, 1992 E l C. Letter dated October 19, 1992 l

i D. Two Telefaxes dated October 23, 1992 ,

y i '

I N I I I I . l I I l .-l - l l

l -: .

l , I 1 N l . . .

l l l -

ll

. . - _ . %o -

l l -

i l g A l I N I i l 1 1 q . . > >

g ,,. -

( ,

I t i F ,

I i ,

4 l l N 1 1 1 I i l I 4 I I t  !

I I I I ,

N P I I I For the U.S. Nuclear Regulatory Commission f I N q

Date 'HOV 0'61992 - By Nuc'e teriaH Safety Branch l  ??

4 I Regi I 4 Prussia, Pennsylvania 19406 8 i _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ King _______________J

g_ ,_______________.-_________--f____

l NRL FORM 374 U.S. NUCLEA") RESULATORY COMMIS$CN PAGE ] OF p PAGES l l p o.sg) p l l MATERIALS LICENSE Amendment No. 01 l Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974 (Public Law 93-438), and Title 10, l l Code of Federal Regulations, Chapter 1, rarts 30, 31, 32,33, 34,35, 39,40 and 70, and in reliance on statements and representations heretofore p l l made by the licensee, a license is hereby issued authorizing the licensee to receive, acquire, possess, and transfer byproduct, source, and special N l 1 nuclear material designated below; to use such material for the purpose (s) and at the place (s) designated below; to deliver or transfer such material E I to persons authorized to receive it in accordance with the regulations of the applicable Part(s). This license shall be deemed to contain the conditions N specified in section 183 of the Atomic Energy Act of 1954, as amended, and is subject to all applicable rules, regulations and orders of the Nuclear

, y Regulatory Commission now or hereafter in eficct and to any conditions specified below. g 1 , I I

Ucensee I I In accordance with the letter dated I 3

I January 10 1995 I

1. Hewlett-Packard Company 3. Ucense number , 07-28762-02G is amended in p i its entirety to read as follows: g i Little Falls Center g i 2. 2850 Centerville Road - R I Wilmington, Delaware 19808 -

4.: Expiration,date November 30, 1997 i

! i g 5. Docket or 3 i g Reference No_ ' 030-32988/37-07002-03G y 1 6. Byproduct, source, and/or 7. Chemical and/or physical -6. Maximum amount that licensee l' E special nuclear material y form .may possess at any one time I under this license l

N I N A. As specified in A.,As specified in A. Not applicable I Condition 10

  • Condition 10 ~M l .

l l t

9. Authorized use ..u _

l l P~ -

.a _.- r &_ ..

E 1 A. Pursuant to 10 CFR 32.51, the licensee is authorized to distribute the devices E i containing seal'6d sources specified in Coridition 10 of"t'his 11 dense to persons k 3

g g

generally licensed pursuant to 10 CFR 31.5 or equivalent provisions of the regulations of any Agreement State. ,

f y

I i s CONDITIONS h i E I 10. Each device distributed pursuant to the terms and conditions of this license shall E' I be in accordance with the following table:

l '

a' Maximum Activity fh

Device Model Per Source F g Numbers (s) Source Isotope (Millicuries) i i E i Model 19312 Plated source Nickel 63 15 E I, Detector Cell l

l i

Model 19282 Detector Cell Plated source Nickel 63 15 i (

l li i Model 19233 Plated source Nickel 63 15 N I Detector Cell h i E l Model G1223A Plated source Nickel 63 15 l

, y Detector Cell y i i i l i Model G1533A Plated source Nickel 63 15 E I Detector Cell 8 I hp,o I% l l "># G h- See a add (Pay {d I l.. N6323636I @4

page 1 A amendments to License 07-28762-02G 10 (continued)

Maximum Activity .

Device Model Per Source '

Numbers (s) Source isotope (Millicuries) i

  • Model G2310A Plated source Nickel 63 5 i Detector Cell ,

i

  • Model G2330A Plated source Nickel 63 5 i Detector Cell
  1. Model G2397A Plated cylinder Nickel 63 15  ;

Detector Cell  !

l

  1. Model G2398A Plated cylinder Nickel 63 15 i Detector Cell
  1. Model G2404A Plated cylinder Nickel 63 15 l Detector Cell '
  1. Model G2405A Plated cylinder Nickel 63 15 l Detector Cell
  • My letter dated Aug. 4,1995 (See Certificate of Registry NR-J48-D-111-B) l l
  1. - New, per this request.  !

i l

I a

, , ..__________________________________. _____________, l l N".C Fum 374A U.S. NUCLEAR REIULATcRY COMMISSION pm 9 y , , l l

- ~

I Licena number l l l l MATERIALS LICENSE n7 -287M ngn y

""'I*""" '

I SUPPLEMENTARY SHEET l l ntn_v onn i l l I l Amonrlmont n_1_

1 l l CONDITIONS l (Continued) l l 11. The licensee is authorized to distribute the devices specified in Condition 10 from l i facilities located at Little Falls Center, 2850 Centerville Road, Wilmington, I  ;

I Delaware. I  !

t l l This license does not authorize possession or use of licensed material.

l 12.

l

! 13. Any propoMd changes in packaging, labelling, shieldi..), or instructions for use and l l storage shull be submitted for review to the Nuclear Materials Safety Branch, U.S. i i Nuclear Regulatory C.ommission, Region I, 475 Allendale Road, King of Prussia, i I Pennsylvania 19406 and approval of the changes shall, be received by the licensee l

prior to implementing the changes. c j l

i i n 14. Except as specifically provided otherwise in this licenh,..the licensee shall y q conduct its program in accordance with the statements, rep'resentations, and i I procedures contained in the documents, including any enclosures, listed below. The i i Nuclear Regulatory Commission's regulations shall~ govern unless the statements, I l l representations and procedures in the licensee'sLapplication and correspondence are . I l more restrictive than the regulations. '

+

(g. l l

, ?s . ._ i l A. Letter dated September 9, 1980 je c i

, i B. Letter dated February 25, 1981- . mrd C - , 7 l 3 C. Letter dated August 24, 1981 -

A I l

D. Letter dated October 28, 1981 1 {? f f 8 2 iL{j;j> 7 I i

E. Letter dated July 19, 1983 j u r. u,; - .'

m j i F. Letter dated November 30, 1983 9 ):- i I G. Letter dated January 30, 1990 '

7'O S '

l 3 H. Letter dated January 10, 1995 -

l l .~ I y N l Y . p .. , q d 1 N I I I l l I I I I I I I I I

~

I u l i i I

I l I For the U.S. Nuclear R::gulatory Commission ,1 l

i . i

! Date MAR I 3 995 gy ( h [ j i c rM Safety Branch N P I King of Prussia, Pennsylvania 19406 {

!.....------......,....---------------...-----.......,.A .

.. - ~-. - .. . - _ - - . . - --

. i

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF DEVICE (AMENDED IN ITS ENTIRETY)

T NO.: NR-348-D-111-B DATE: August 31, 1995 PAGE 1 OF 8 l l DEVICE TYPE: Electron Capture Detector  !

ggt 39'1A, (r>3988) (Th10 YllyGDVQSk '

MODELS: G1223A, G1533A, G2310A, G2330A l(Generally Licensed)

G1224A, G1536A (Specifically Licensed) tiA_'"1FACTURER f / DT FTP I F "'nR : Hewlett-Packard Company Little Falls Site 2850 Centerville Road Wilmington, DE 19808 SEALED SOURCE MODFi 'ESIGNATION: Amersham Corporation Model NBCD 1

ISOTOPE: MAXIMUM ACTIVIT11 MODELS l

Nickel-63 15 millicuries (0.56 GBq) G1223A, G1533A G1224A, G1536A L millicuries (185 MBq) G2310A, G2330A LEAK TEST FREOUENCY: 6 Months PRINCIPAL USE: (N) Ion Generator, Chromatography CUSTOM DEVICE: YES X NO VPI f

% o@&g629( /W

' I l

1 REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES l SAFETY EVALUATION OF DEVICE '

(AMENDED IN ITS ENTIRETY)

NO.: NR-348-D-lll-B DATE: August 31, 1995 PAGE 2 OF 8 DEVICE TYPE 1 Electron Capture Detector l I

DESCRIPTION:

The Models G1223A and G1224A electron capture detector (ECD) assemblies are similar to the previously approved Models 19233 and 19235. The Model G1222A will be distributed to persons generally licensed and the Model G1224A will be distributed to persons specifically licensed. The two detectors are the same ,

except that the detector label plate is different for general l licenses versus specific licenses. The Models G1223A and G1224A ECDs are for use on the Hewlett-Packard Model 5890 Series gas chromatographs.

The specific differences of the Models G1223A and G1224A relative to the Models 19223 and 19235 are as follows:

1. The detector heat sink is made of aluminum rather than l stainless steel. The new heat sink allows Hewlett-Packard to down rate their heater from 70 watts to 60 watts. This also limits the maximum temperature of the detector. In the event of a catastrophic failure mode, the 5890 gas chromatograph instrument's main processor would detect a shorted sensor fault, and turn off all heaters to devices on the gas chromatograph.
2. A 17-4 PH stainless steel will be used rather than 303 stainless steel. The supplier of the lower plated bl6ck, Amersham Corporati:n, has indicated that the plating quality of Ni-63 is better with 17-4 PH stainless steel. A 17-4 PH stainless steel lower block is currently being used on Models 19303 and 19312 ECD's. The inside of the lower block will be plated with non-radioactive nickel prior to plating of the Ni-63 radionuclide.
3. A metal seal will be used between the lower block (cathode) and the upper block (anode) that is currently used on other ECDs being distributed (for example, Models 78713A, 19282 and 18803-60520). This particular seal uses a silver crushable O-ring. The same tamper proof screws now used on l

all of Hewlett-Packard's distributed ECDs will be used.

i i

i

A REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF DEVICE  !

.(AMENDED IN ITS ENTIRETY)

NO.: NR-348-D-lll-B DATE: August 31, 1995 PAGE 3 OF 8 DEVICE TYPE: Electron Capture Detector DESCRIPTION (Cont.)

4. The upper anode block design has been redesigned. The non-plated part has reduced mass, a purged anode which has been raised (withdrawn) from the region of the nickel-63 plating within the lower block (cathode). The purged anode remains cleaner and is retained with a special nut and seal  ;

removable only with the manufacturer's anode wrench.

5. The outer cover and insulation are different than the 19233 and 19235 merely to accommodate the new gas chromatograph.

The detector label plates will have the same information as our current detectorr and will remain permanently attached to a tamper proof sc.ew.

The Models G1533A and G1536A ECD assemblies are same as the Models G1223A and G1224A with the exception of modifications to the mounting hardware and the outer cover and insulation for use with a different gas chromatograph. The Model G1533A will be distributed to persons generally licensed and the Model G1536A will be distributed to persons specifically licensed. The two detectors are the same except that the detector label plate is different for general licenses versus specific licenses. The Models G1533A and G1536A ECDs are for use on the Hewlett-Packard Model 6890 gas chromatographs.

The Models G2310A and G2330A are identical to the Models G1533A and G1223A respectively, except that the G2310A and G2330A will only contain up to 5 mci of Ni-63. The sources will be plated in the same manner as those in the Models G1533A and G1223A.

All six ECDs are approximately 4" (10 cm) long and 1-1/8" j (2.86 cm)'in diameter at their widest location. General licensees never receive the tamper proof screws wrench or solvent cleaning / disassembly instructions.

i

(- ^

1 l

J

-. - . . . - . ~ -- - - _ . . . _ - - . . .- - - _ - -

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES

{ SAFETY EVALUATION OF DEVICE (AMENDED IN ITS ENTIRETY)  ;

4 j

NO.: NR-348-D-111-B DATE: August 31, 1995 PAGE 4 OF 8 i 4

I 4

DEVICE TYPE: Electron Capture Detector i, i

1 LABELING:

{

Each cell is stamped with the radiation symbol, the words,

" Caution-Radioactive Material," the isotope and activity. Label plates.are attached by cable to a tamper proof screw on the j detector body. Users'are instructed not to remove these plates.

The plate contains the radiation symbol, the words, " Caution-Radioactive Material," the isotope, activity, model number, serial number, date, the words, " Electron Capture Detector," and l the manufacturer name and logo. Additionally, for the Models

G1223A, G1533A, G2310A, and G2330A, the generally licensed j

versions, the plate contains the labeling requirements of Section

' 32.51, and refers the user to an instruction manual that tells them not to open or chemically clean the cell.

i.

l I 1

DIAGRAM- i f See attachment 1.

i CONDITIONS OF NORMAL USE:

Each ECD is designed to be used in conjunction with gas chromatographs in analytical laboratories. Each ECD will be used

.in laboratory environs and by persons trained in the use of gas chromatography equipment. The ECD will normally be operated at temperatures up to 4103C (770 F).

PROTOTYPE TEST _ING:

Hewlett-Packard tested the detector cells to the criteria used on their presently licensed detector cells. The tests consisted of: .

  • Pressure test to 60 psi (414 kPa) .
  • Drop test from 1.5 meters (59").
  • Vibration test to 55 Hz with an amplitude of 0.015"

. (0.38 mm).

    • Freeze test to -40*C (-40*F).

Loss of Nickel-63 in carrier gas during normal use.

.. _ . . - . . _ _ _ - . - . . ._.._ ____. _ ____. ~..._____._.._ ___ _.___.-.____..-_ _

l E

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES

SAFETY EVALUATION OF DEVICE i

(AMENDED-IN ITS ENTIRETY)

! 1 l' NO : NR-348-D-lll-B DATE: August 31, 1995 PAGE 5 OF 8 )

i l i DEVICE TYPE: . Electron Capture Detector I l-PROTOTYPE TESTING (Cont.)-

,

  • Loss of Nickel-63 from detector is all heat control systems

. fail.

{

  • Loss of Nickel-63 during solvent cleaning of the detector.
  • Loss of Nickel-63 at aonor aality high temperatures (625+C

[1157 F] and 800*C [14 72'F] ) .

{ The ECD's met the above tests and exceeded the minimum ANSI N542 l classification of 77C32211 for ion generators, chromatography.

1 i

j EXTERNAL RADIATION LEVELS:

! I The manufacturer has reported that radiation levels do not exceed  !

i background levels for measurements taken from a detector with- l 4 1 15 millicuries of Ni-63 at the surface and at distances of 5 cm 1

(2") and 30 cm (12") from the surface.

OUALITY ASSURANCE 7ND CONTROL:

i i The following tests are performed on each detector cell by the i manufacturer prior to shipment:

[

e

  • A visual inspection of the area of radioactive plating using

. I a stereo-optic microscope. l

  • Measurements of the radioactivity levels by use of ionization current.
  • Wipe tests of the non-radioactive surfaces to ensure non-contamination.

l A copy of the Hewlett-Packard's Quality Manual is on file with NRC.

I

=-. .. -

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF DEVICE (AMENDED IN ITS ENTIRETY)

NO.: NR-348-D-111-B DATE: August 31, 1995 PAGE 6 OF 8 DEVICE TYPE: Electron Capture Detector LIMITATIONS AND/nP OTHER CONSIDERATIONS OF USE:

The Models G1224A and G1536A shall be distributed to persons specifically licensed by the NRC or an Agreement State.

The Models G1223A, G1533A, G2310A and G2330A shall be i distributed to persons generally licensed by the NRC or an {

Agreement State.

I Handling, storage, use, transfer, and disposal: To be determined by the licensing authority or as required by 10 CFR 31.5 or Agreement State equivalent.

The devices shall be leak tested at intervals not to exceed 6 months using techniques capable of detecting 0.005 microcurie (185 Bq) of removable contamination.

The user may install the device into gas chromatographs.

However, the device may not be dismantled in any way by the user unless he obtains a specific license from NRC or an Agreement State to perform such activities.

This registration sheet and the information contained within the references shall not be changed without the written consent of the NRC. I iAFETY ANALYSIS

SUMMARY

I i

lewlett-Packard has submitted sufficient information to provide  !

reasonable assurance that:

l The device can be safely operated by persons not having I training in radiological protection. l l

, REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES

SAFETY EVALUATION OF DEVICE (AMENDED IN ITS ENTIRETY) ,

1 l

NO,: NR-348-D-111-B DATE: August 31, 1995 PAGE 7 OF 8 )

i 1

DEVICE TYPE: Electron Capture Detector SAFETY ANALYSIS

SUMMARY

(Cont.):

  • Under ordinary conditions of handling, storage, and use of the device, the byproduct material contained in the device will not be released or inadvertently removed from the  !

source housing, and it is unlikely that any person will I receive in any period of one year a dose in excess of 10  !

percent of the limits specified in Section 20.1201 (a ) , i l

10 CFR Part 20.

Under accident conditions associated with handling, storage, and use of the source housing, it is unlikely that any person would receive an external radiation dose or dose commitment in excess of the dose to the appropriate organ as specified in the following chart:

PART OF BODY DOSE Whole body; head and trunk; active blood-forming organs; gonads; or lens of eye 15 rem (0.15 Sv)

Hands and forearms; feet and

  • ankles; localized areas of skin averaged over areas no larger than 1 square centimeter 200 rem (2.0 Sv) i i

Other organs 50 rem (0.50 Sv)

Based on review of the Models G1223A, G1533A, G1224A, G1536A, G2310A and G2330A ECDs, and the information and test data cited below,-we continue to conclude that the devices are acceptable {

for licensing purposes.

Furthermore, we continue to conclude that the devices would be  !

expected to maintain their containment integrity for normal j conditions of use and accidental conditions which might occur j during uses specified in this certificate, j t

)

3

. _ _ _ _ _ _ _ . _ _ . _ _ . __ ... _ _ _ ___ _.. . . - . . ~ . _ _ _ . . _ _ . _ _ .

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES t SAFETY EVALUATION OF DEVICE (AMENDED IN ITS ENTIRETY)

HQui NR-348-D-111-B DATE: August 31, 1995 PAGE 8 OF 8 DEVICE TYPE: Electron Capture Detector ,

REFERENCEE1 The following supporting documents for the ECDs are hereby

-incorporated by reference and are made a part of this registry document.

+ Hewlett-Packard's letters dated January 30, 1990, February 2, 1990, May 9, 1990, September 17, 1990, October 3, 1990, and October 10, 1990, with enclosures thereto.

  • Hewlett-Packard's letters dated' August 4, 1995 and June 8, 1994, with enclosures thereto, i

ISSUING AGENCY:

U.S. Nuclear Regulatory Commission

//

Date: Aucust 31, 1995 Reviewer:

f/' John W. Lubinski Date: Aucust 31, 1995 Concurrence:

Steven"L'. Baggett I e

O

,e*

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF DEVICE (AMENDED IN ITS ENTIRETY)

NO.: NR-348-D-111-B DATE: August 31,1995 ATTACHMENT 1

~

Nt J,t, it$  !

Qh1>

E'_ /

u,,. , c s w

x 0 c.ca -

~^ '

-)

\[ t

$ [ $3 p ,

/, (((fa5..n a

y&; A

_m e s a / >-

.s ekee (cad. eaeh;d) f '

. - d I lT l

5(-

3 c9

I, .,  ; % ' i ; f,

  • .r f 2. .w ,. %

M

) it IJt. t. I i - E'ai.1 pNu t.;I ::1t *; e n t'pl,E 1 1%!S 1 T41s L ! , I

,  ! '," ,1 ! !!1! R 1 i n U U t1/ 4 11!lN s a l l M q. N g ;a i u. t1;3 : juu SHIP 1U: t ,i i I }>t o .i j F Nut 1:

US NUULEAR REtsULA1URY UUt1t11 bS 1 Ut 4 H m a1e't t--1' sat a r .1 L iJ. 4U i

SEALED buuRIE SAF E l Y SEC l IllN L,ttle Fal17 Upsratton I D I V/ I t4UUS T R I AL & T1Eu l U AL tJU: 1 t. AR SAF E I Y /!'5 U ' .f n t " r v i 1 1 e; Poad tJ ASH I NLs l lir4, DC 20555 U 1 ! ra i n g i n n , 1:t i ' ' ', A l '/ U U t; - 3 f, ! U ULLIULR IU: '

,/U:  ! !!al u N N:1 ',L i i P 1!. I F1R . S 1 E Ul. B AlsGE I 1 I j < ._ p .cJ < , r, 5.

SULI) 1U: SH 11 'l 1 N 1 LIS NULLEAR RLisul. A I LtRY U Ut1I11 SS 1 Ut1 Ft i t I 't. Ni 't. t '

6 U /, U 1 W ', l SLALLU SUURCE SAFEIY SEUlIUN  : alm i L !' ti I >

1 U I U/1 t4tJtJS I R 1 AL e. t11: U L L AL NUCLEAR SAFL1Y LJ ASH I I4L4 I UN , UU 21155 5 Sa!l)' i ti, I t  : -, - m:> v e, AIlLtilIUN U F' :

1 r '

d;, 4 li t t'rn !! ! L UN i L t i l t, l 1

w :. j

\

j 1 l E t1 S1 PRUUUU1 nut 1HER DESCRIPlIUN UIY tR1 l l

l ly n; nu i u n ' ' 1l.r : i s i r ' 1 :m i t ' 5 Eus t i t .t 1 : ,L c u '-; ' < .'_u. ,

i

+ l

  1. N: *

. ;N t: '

-u.4 i

'.un t! l l

g'* '!

?'!!ii. ( li 71'  : 1 [l!l. t  ! U lI l .{ 1 l

?:'

,;! l!-t;l 't ' '! .J.

1l'!

i 't 4 t. , .

, -,l l.1 i'

l , ;E "

, i , F.

J r  ! ' f; ,

  • ai!5 ,-

1

' ,Ir ! ( !f# ['

U,  ! r ', i ' 'IL  !

  • l' ,F d! l ! { l ,

iMi,  ! ,  !; ' ' ._ ! -)iV - LJ -_wc'.  :! t : t L ,

l i

L IEU blf I'**' t . $ t I' 9 L. [ **

l i

1 i

i I

l i

1 1

1

NRC FORM 577 U.S. NUCLEAR REGULATORY COMMISSION (1 95)

LICENSE FEE AND DEBT COLLECTION BRANCH DIVISION OF ACCOUNTING AND FINANCE LICENSE FEE REQUIREMENTS OFFICE OF THE CONTROLLER U.S. NUCLEAR REGULATORY COMMISSION WASHINGTON, DC 20555-0001 wfL KA.e La-k7 , TMjO TYPE OF'A'CTION

__j NEW LICENSE RENEWAL OF LICENSE Hewlett-Packard Company AMENDMENT TO LICENSE Lit *Je Falls Site ATTN: Brian Donnelly REQUESTED DATE 2850 Centerville Road 4-9-96 Wilmington, DE 19808 UCENS'ENUMBER'~ ~ ~

l NR03480111B i 96-19

1. APPLICATION FEE DUE ~

IL FEE NOT REQUIRED l

~ '

Y6'ur~riquestlir'alicensirkction Esubject tith'~feeisiin e the' category (ies) noted below in accordance with Section 170 31 of the L Enclosed is Check No. which accompanied your cnclosed Federal Register notice Payment of the fee is required prior to

- ~

' request. The fee is not r'e' quired because:

thJ issuance of the license, renewal, or amendment. i

~ We received your Check I j% A'PPLICATION " RENEWAL ~ AMENDMENT - No. in payment of l 9A [5 ~' 3,2;00.001 -

~ ~ ~

the fee. I ls}

$ $ 5

^ ' ~ * ' '

s~ 's~ s The Licensing staff has informed us that your request is to be )

p- --

g- considered as a continuation of your request dated '

~

[S_ _ IS 8' , Control No.

$ s 5 '

l

.f_

S

[5 Your request was combined, prior to review, with your {

.. ? _... _ ._ o request, Control

.s is

.s No. l j

Ill. CHECK RETURNED

~'

l 3,200.00

~ ~ - ~ - - ~ - ~ '

FEE (s) DUE s 5

" ** *

  • which was returned to us PAYMENT RECEIVED - - - - -

by the bank for.

AMOUNT DUE s 3.200.00 4

INSUFFICIENT FUNDS y . Your request was received without the prescribed application

_E J ! fee. ACCOUNT CLOSED  ;

.We received your Check --- -- - --

OTHER

' { No. . __. _ _ _ _ _ in the amount of Payment of the additional fee noted

~

I_._.____.. _

above is required- -- - -

MAIL THE REPLACEMENT CHECK TO THE ADDRESS LISTED AT THE

' Your request willincrease the scope of your license program- TOP OF THIS FORM AND REFERENCE THE ABOVE CONTROL

- -.- , Therefore, your request is subject to the application fee (s) noted NUMBER.

above. Refer to Section 170.31 and Footnote 1(d)(2).

~ ~~ ~

IV. LICENSE ISSUED WITHOUT THE REQUIRED FEE

Amendment - -

~

. ~ -I Youilicense expired pUor~to tEIre~ceipt df your application for ~ -

} Ucense -

L i ! renewal. Therefore, your request is subject to the application fee (s) t-- i No. __

No. _

, issued on

~ " noted above. Refer to Section 170 31 and Footnote 1(a). was issued without the required fee being collected. The fee required is noted in Section I of this MAKE PAYMENT OF THE FEE S TO THE U S NUCLEAR REGULATORY COMMISSION D MAIL THE PAYMENT TO THE -

p ! request is subject to the application fee (s) noted i

. 4 ADDRESS LISTED AT THE TOP OF THIS FORM IF WE DO NOT ' form. Refer to Section 170.31 and Footnote 1(d)(2).

RECEIVE A REPLY FROM YOU WITHIN 30 CALENDAR DAYS FROM THE DATE LISTED BELOW WE SHALL ASSUME THAT YOU DO NOT - - - - - - - - - -

WISH TO PURSUE YOUR APPLICATION AND WILL VOID THIS - - ---Because of the urgency of your request, the license was issued- - - - -

ACTION. ' " without remittance of the prescribed fee noted in Section 1 of this form SIGNATURE - LICLNSE F EE ANALYST LFDCS

! LFDCB . Distribution: /l 4/ 9 f,/ DALE

~ff N ,

  • 4W/Lusta ( -

l Sandra Kimberley 4/16/96 -~' 4/16/96 l h%Qg%y' 3.,,17)sfp ~

g/A 4-16-96 wac5oaur,n p.99 in, tonn was uonc.amou.a ny t- r.o .a onn inc

Retrieved from "https://kanterella.com/w/index.php?title=ML20134P021&oldid=3377126"