ML20140E924

Registry of Radioactive Sealed Sources & Devices,Safety Evaluation of Device for Model 2119-02.Certificate: NR-8089-D-801-S

ML20140E924
Person / Time
Issue date:	05/23/1997
From:	Thomas Rich NRC
To:
Shared Package
ML20140E793	List: ML20140E790 ML20140E908 ML20140E924
References
SSD, NUDOCS 9706120249
Download: ML20140E924 (10)

Text

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

1 REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF DEVICE NO.: NR-8089-D-801-S DATE:

May 23, 1997 PAGE 1 OF 6 J

DEVICE TYPE:

Tritium activated runway markers MODEL:

2119-02 DISTRIBUTOR:

Science Applications International Corp.

(SAIC) l 2109 Air Park Road i

Albuquerque, NM 87106 1

MANUFACTURER:

Safety Light Corp.

4150-A Old Berwick Road i

Bloomsburg, PA 17815 l

ISOTOPE:

MAXIMUM ACTIVITY:

Tritium 996 Ci (3. 69 TBq) per device 166 Ci (614 GBq) per sealed source LEAK TEST FREOUENCY:

N/A PRINCIPAL USE: (W) Self-Luminous Light Source CUSTOM DEVICE:

X YES NO CUSTOM USER:

State of Alaska i

Planning and Administrative Services DOT &PF 2301 Peger Road Fairbanks, Alaska 99709-5316 9706120249 970605

~

PDR RC SSD PDR

-.-______._._._._.___._.-_____._____.y 4

j 4

i i

i-REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF DEVICE f

i NO.: NR-8089-D-801-S DATE:

May 23, 1997 PAGE 2 OF 6

\\

{

DEVICE TYPE:

Tritium activated runway markers l

DESCRIPTION:

1 I

Due to the Federal Aviation Administration declaring that radioluminescent runway lights not certifiable for use at l

airports and the prohibitive cost of disposal of such devices, l

the State of Alaska withdrew its application for their own

{

possession and use license for the model 2119-02 tritium j

activated runway markers.

i j

The devices were originally manufactured by Safety Light Corporation for Oak Ridge National Laboratory for a development program sponsored by the United States Air Force and The United States Department of Energy (DOE) DOE procured a total of 280 of these devices.

This certificate approves these specifically licensed devices for licensing purposes for use in community airports in Alaska.

The devices consist of six sealed glass tubes each containing up to 166 curies (614 GBq) tritium in the form of elemental gas.

j The tubes contained no more than 0,04 percent T O at the time of 2

loading.

Each tube is approximately 11 inches (27.9 cm) in length and one inch (2.54 cm) in diameter.

The tubes are mounted using a bed of RTV-108TM silicone adhesive to a vacuum formed plastic sheet with three parabolic shaped troughs.

Two sheets are joined (edge mounted back to back) with RTV-108TM silicone adhesive.

A tube is installed in each trough (3 each side, 6 total per device).

The two sheets are secure in a clear polycarbonate case.

The tritium devices are mounted on tamper-proof fixtures (2 devices per fixture, see attachment 2) that allow the devices to be moved during grading and snow removal operations.

One end of i

a steel cable is attached to the fixture.

The other end of the steel cable is attached to a Duckbill type earth anchor which is driven into the embarkment to secure the fixture.

The fixtures are light weight and resilient to minimize damage that could occur from accidental collision with aircraft.

i I

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF DEVICE NO.: NR-8089-D-801-S DATE:

May 23, 1997 PAGE 3 OF 6 I

DEV7CE TYPE:

Tritium activated runway markers l

f DIAGRAM:

See attachments 1 and 2.

LABELING:

The devices were designed to be labeled in accordance with Subpart J, 10 CFR Part 20.

The labels are made of 0.01 inch (0.025 cm) thick matte finish polycarbonate.

The label contains the custom user's name, activity, serial number, date, and the statements, " CAUTION CONTAINS RADIOACTIVE MATERIAL," and a warning message.

CONDITIONS OF NORMAL USE:

These devices were intended to be installed permanently or for testing on remote airfields for runway and helipad lighting and marking.

The units will be mounted in edge light tamper-proof fixtures.

The devices were designed to operate in Arctic and in remote environments where the temperatures may range from -50 to 105F.

Experience has shown that in similar locations the diurnal and seasonal temperature variations and other environmental factors have no identifiable affect on the light units.

l The expected useful life of these units is from 8 to 12 years.

PROTOTYPE TESTING:

The light sources have been tested in accordance with ANSI N540-1975, " Classification of Radioactive Self-Luminous Light Sources."

The temperature, thermal shock, and reduced pressure tests were performed on the bare (unmounted) glass tubes.

The impact and vibration tests were conducted on the assembled units.

The prototypes were subjected and passed level 4 tests with the exception of the impact test.

The impact test for which the

~ ~

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF DEVICE NO.: NR-8089-D-801-S DATE:

May 23, 1997 PAGE 4 OF 6 DEVICE TYPE:

Tritium activated runway markers i

PROTOTYPE TESTING: (Cont'd) 1 I

l device was subjected to and passed was more stringent than the Level 4 ANSI N540 test.

In addition, the devices were subjected to and passed the tests for Type A shipping packages as described i

in 10 CFR 173.465 and 173.466.

I EXTERNAL RADIATION LEVELS:

The devices emit no ionizing radiation that is detectable at the surface of the unit closure.

i OUALITY ASSURANCE AND CONTROL:

SAIC did not manufacture the components of the device or source.

The devices were originally manufactured by Safety Light Corporation to specifications written by Oak Ridge National Laboratory (ORNL).

ORNL's technical specifications included a documented 100% testing of each device for tritium leakage and photometric output.

l In addition the following tests were also performed (excerpted from ORNL TM/11503):

1.

Thermal Shock test of as received Glass tubes (100%).

2.

Internal Pressure Test of Glass Tubes (100%).

'3.

Phosphor Coating Adherence Check (100%).

4.

Vacuum Drying of Tubes and Storage of Phosphor Coated Tubes i

(100%).

5.

Water Check on Tritium Gas: tritium Gas loaded into RL I

l Airfield lights did not contain more than 0.04% total water.

f This was determined by mass spectrographic analysis either t

[

by the supplier of the gas or the seller's plant.

___m..

j REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF DEVICE NO.: NR-8089-D-801-S DATE:

May 23, 1997 PAGE 5 OF_6 J

I DEVICE TYPE:

Tritium activated runway markers l

1 OUALITY ASSURANCE AND CONTRQL1 (Cont'd) j 6.

Oil free tritium, Seller shall certify that tritium loaded into RL light tubes was 100% oil free.

i' 7.

Thermal shock test of tritium filled tubes (100%).

LIMITATIONS AND/OR OTHER CONSIDERATIONS OF USE:

This registration sheet and the information contained within the l

references shall not be changed without the written consent of l

the NRC.

t i

SAFETY ANALYSIS

SUMMARY

l Based on the test data referenced, the field testing and the q

claimed ANSI-N540 ratings, we concluded that the device is j

acceptable for licensing purposes as specified in this j

certificate.

i l

Furthermore, we concluded that the Model 2119-02 tritium activated runway marker would be expected to maintain its integrity for normal conditions of use and accidental conditions which might occur during uses specified in this certificate.

)

i i

1 i

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY t

EVALUATION OF DEVICE NO.: NR-8089-D-801-S DATE:

May 23, 1997 PAGE 6 OF 6 l

i DEVICE TYPE:

Tritium activated runway markers

REFERENCES:

The following supporting documents for the Model 2119-02 Tritium activated runway markers are hereby incorporated by reference and are made a part of this registry document.

SAIC's letters dated May 26, 1994, April 22, 1994, March 29, 1994 and February 25, 1994 with enclosures thereto.

SAIC's application dated September 10, 1993 with enclosures thereto.

i The State of Alaska letter dated April 28, 1995.

ISSUING AGENCY:

l U.S.

Nuclear Regulatory Commission Date:

May 23, 1997 Reviewer:

) into Nt/

[48%

l Thom s W.

Rich Date:

May 23. 1997 Concurrence:

47

~

Steven L.

Baggett i

I I

J i

,_ m,_ _ __._.

~.

i I

I l

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF DEVICE i

NO.: NR-8089-D-801-S DATE:

May 23, 1997 l

l

(

t l

7.. [hdC, f, - -

l i

n..

~

M ' 4.e.'7%,

~

f1

[L h

/ x Qi;QM

,m

w n.;

s

.~

wt...

5 l

c

.a.m

?

W

)

g lf 9

MJ W h w m..,

t S

+

4 I

i 1

4 3,,,.

--,,.--,,--n--,

,,,.-,----------,,,,-,,--..--,,_,vn..-

l i

1 l

j REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY a

EVALUATION OF DEVICE j

NO.: NR-8089-D-801-S DATE:

May 23, 1997 l

1 1

l i

I i

i 1

1

(

~

)

i t

1 i

i Yr

., lt ( b ~., ; ['

8$$' e --

Nff y g,

. [. g C/*' **'

pHCW CAa4 r

s.

3, l

j....

0['[

l c,. j,, ' f.

p,.'

• HARDEND PAD.OCK t,

Y

$yTQ'..C ' ',,$$r+

@h@b. **Y-!

f,$,%.'.I

~

~'

l' C~.

. g r-

's fpg'*

, j ', '

e

• aA

'+

?.

. We s' R. *. p l, r,,..*

g ;4 w/<

f.,

v'

,y e

EXTENDED LEGS

'.r)r, - -

'-g<

-Ji,

. a

+

,f **,

ag rarmou COOPWG

},

'jM, [_,

,c v.-

• y

..~

g..

[

h, s

y;O':','f.,.r-

~'#

c.. '

,p

,a,-

.m 4

^

'1

? m$,d%' ;'?

M8 j

• /

tucksu EARN j

,. ;., y pgi,gg:. -

.p em

,e,,z.:g<,w, Q.

y... j',

, g.

W: m:.,~

l

c M.. y, g.

3

...y n #n 4

,7? *O,e;:

..g, ;i a.

g 4.

t f

s

.s yn

, N, ~.3, '

i Ay5 ';fu

> >*)??

l sg r v-;

(

6L r(auc 8

+)

UM w.,,, p

~

s '. *

}

9:$,',, Gyp d

n.

f. ? :*c -), *,<..

l 4

1 x

1

...s

?, g.g g. -

• q'..,.

4 M*e h

fyktj '

[~

j'*],#' $ *'

..,, ' 4 % P

.jg f sa i

.. W gn.

~

l

)$ '

yl;;>. ;3* A*s

,s'-

_e A

. pt.s; Mi gA.Y., h ;,f L

}

rs.,

n.

N M B ASE e

t

• gy - *

( ',-

f, T' N g, q 7. '. V gh.;.,

...,s.

w.,,

%pj

• ale

,,'r

,,[_* * ' _ '

e w.

j A

1 1

?

1 1

g

'*Ne'.--

PACE 1 EC FORM 567 U. S. NUCLEAR REOULATORY COMMISSION REQUEST FOR A SEALED SOURCE OR DEVICE EVALUATION INSTRUCTIONS: Send this request AND a copy of all related letters /applicatons and drawings to: The Sealed Source Safety Secten, ATTN: Chief, ObVFN Mail Stop 6 H3. Change the License Tracking System milestone to 19 and assign to reviewer code I-5.

NOTE: Retain a copy of this request with the application and background files.

REQUESTLN 4L )/L4vL

!e24/4M lI U ll 111 U IV UV HQ LFDCB REGION / LOCATION:

f TELEPHONE NUMBER /

DATE TYPE OF ACTION REQUESTED (Check as appropriate)

QPPLICANT'S NAME SOURCE REVIEW AMENDMENT OF hIdp/0C fl b (MMMM:

^

MQll CONTROL NUMBER (S)

(/

DEVICE REVIEW NUMBER (S LETTER /APPLNON DATE LICENSE NUMBER (S)

CUSTOM REVIEW

/b NO 9 ' A*/1$

i ll fff,/} [ b Al

/}WC-p a. Lx 7Nf" ttfl th2 A 9 e ) A L 715/9 - WG Q FOR SSSS USE ONLY REVIEWER MODEL NUMBERS NUMBER ASSIGNED

/ / f 'N

~

DATE RECEIVED DATE ASSIGNED DATE TO FEES lD f

/O /b.

h TYPE OF ACTION (Indicate the number of each typel f

l COMMERCIAL DISTRIBUTION (FORMAL) l USE BY A SINGLE APPLICANT (CO3 TOM)

'.i SOURCE (9C)

DEVICE (9A)

SOURCE (9D)

DEVICE (98)

NEW PEW

] NEW

[ NEW AMENDMENT AMENDMENT AMENDMENT L

AMENDMENT

]NO SAFETY EVALUATION REQUIRED j LICENSING ACTION REQUIRED IF KNOWN NO NO FEES REQUIRED

} OTHER (Specry)

TOTAL NUMBER OF NOTES

[C REVIEW HOURS gg-jug' NUMBER OF DEFICIENCY LETTERS NUMBER OF DEFICIENCY CALLS FOR BILLING PURPOSES ONLY NEW REGSMATION -

] MODUCT INACME -

NAME CHANGE ADDRESS CHANGE ADD TO BILLING REMOVE FROM BILLING FOR FEE USE ONLY TYPE OF FEE FEE CATEGORY

] 9A U 9B 9C b 9D QMOUNT RECEIVED CHECK NUMBER MATANN UPDATED AS REQUIRED j

g_

n DQTE OF CHECK Loo

[f }

/J _]

TSYS UPDATED ps

_,y y

,g, DA-Re, URN vA, CO6.MENTS I

l NRC FQRM W (6-93)

MIGim TO SSSS c

i fo/'7/P I0l]ffl, (P

fLc g o no w a t

aa ja xa d

u a 9 6 A 6/o/9P' (ca a vna ')

JL L

,,udtLL w kL rwgnet hw 9/u/95 L t

56=LLL

$cA sete,ac_r(

kh w &L + % n & J-,b

~'

+nse ?

W In w & g ' x xx

^ '

yt ct v-o*hr%'P 3

7,pn &"

/,

l r

VOID StiEET 4

Ab' TO:

License fee Debt Collection Branch, FROM:

Region IV - WCFO j

SUBJECT:

VOIDED APPLICATION l

Control Number:

b/[dO b

App 11 cant:

$ &, h 4AL & - hat fr&

030-33 2 7y i

V l

Date Volded:

[- 3C-7f i

Reason for Vold:

b L C&nsiv iVstashL & dA & & M c

vtUtMr' a h C0?nN8h/ L& W t;bab h 2 ?' W,

VW i

l

$'O G kr1w Yk2lYC 5ignature g

Dat's

Attachment:

Official Record Copy of Volded Action FOR LFDCB USE ONLY Final Review of V010 completed:

Refund Authorized and processed No Refund Due 1

Fee Exempt or Fee Not Required Cosnents:

Log completed e'

Processed by: T /s v

(( k$h bbh79 fjl,40 FDR C

4

RECElVED c

A

p DEPARTMENT OF TRANSPORTATION AND PUBLIC FACILITIES siti 45 s4rio* 4t r s PQ 005196900 4 A(HOf 46f. di4 5 A 4 fvif 9 4900 goo?!/ss-tsse or Jss the t

$14fl 66 tul 4614180%

14 & t40?) J4 8 t ill

)

4 l

April 28, 1995

)

Certified Mail Return Receipt Mr. Jim Montgomery License Application Evaluation Group U.

S. Nuclear Regulatory Commission, Region V Nuclear Materials Safety Section 1450 Maria Land, Suite 210 Walnut Creek, CA 94596

Dear Mr. Montgomery:

This letter will serve as the notification that the Alaska Department of Transportation and Public Facilities (DOT &PP) has decided to suspend efforts to obtain a Material License from the Nuclear Regulatory Commission to own and operate Radioluminescent Runway Lights.

Please withdraw our license application.

The Federal Aviation Administration has recently concluded its testing of RL lights, and has declared that the RLs are not certifiable for use at airports.

This determination prevents comercial air carriers f rom using an RL-lighted airport under visibility conditions that require the use of a lighted runway.

Moreover, the facilities available to dispose of the RLs, and the related costs have changed dramatically since we started the licensing process. We cannot be assured that a f acility to dispose of the RLs by recycling would be available at the end of the useful life of the units.

The other option for disposal is as radioactive waste. These costs are prohibitive.

The chart compares the costs of disposing of the RL lights using recycling or disposal as waste, now and in the year 2006.

112.i 2DD.fi Recycle lights

$44,800

$60,200 Radioactive Waste

$106,600

$533,000 In summary, the combination of accelerating costs for disposal of the RL units at the end of their useful lif e, and the FAA's refusal

["//7AO

, April 20, 1995 to certify the RL runway lights for commercial air carrier use have made it impractical, if not impossible to continue with this project.

In summary, for all of the reasons stated above, the DOT &PF is asking to withdraw our license application for a nuclear material license.

If you have any questions regarding the RL matter, please call our airport engineer, Mr. Carl Siebe at (907) 266-1465.

Mr.

Widdis no longer works for the DOT &PF.

?bw))

Sincef y,

/

cf

/

tep 1 L. Pavish Acting Director

)

Statewide Aviation cc:

Martin Ott, Chief of Planning and Administration, Northern i

Region, DOT &PF d 'i

')b0 It, U

D

\\

G&

piiu

~ ~. ' " *

^

b g, g' ';;:;. *, ' :

' i G;9 g ' t t,

"[ 7J'..

FOR LFMS (!$E)

INFO (RMATION FROM LTS 8

I 8

BETwilN s

. :.e.

gh License fee Management Branch, ARM

! Program Code!

and I Status Coder 3

' Regional Licensing Sections 8 fee Category!

! Exp, Date 0 I fee Commentst Decom Fin Assur Reqd

!!!stillt Itttt!!stttttttittttttttt!!!

LICENSE FEE T

$NITTAL A.

RIGION 1.

APPLICATION ATTACHED Appilcant/Licenseet ALASKA, STATE OF Received Datet 930729 Docket Not 3033279 Control No.

571820 License No.1 Action Type New Licensee 2.

F(( ATTACHE R 0

.,y') Oh68 Amountt Check No.

3. CO*e4[NTS Si W

cafned e

x - 2 _ +->

v v

ij Check when allestone 03 is en}ered /

8.LICENSEFEEMANAGEMENTBRANCH(P bkb g

3 1.

Fee Category and Amount 2.

Correct fee Paid. Application may be processed fort pD Amenonent Henewal N

D License Ny 3.

OTHER g

g>,rw D

=

,I

/Se/

./ o h

Signed Date

' V /1(J / M

{

l\\'

4 e

~..

e

<<NUDOCS/AD>>

TCON11 Nuclear Regulatory Commission Version 002.000 Records 1 1=== Subject / Field / Boolean Results = Select Count 1

=

=

Accession #

Docket Author Name Affil Issued Microfiche Address 9508160242 03033279 PRANGE,B.A.

NE R4W 950712 85061-226/85061-230

(*)

Voided matls licensing action for State of AL. Control: 571820.

Arrows-Scroll, ENTER-Select, F10-Mark For Download, CTRL-F9-Continue Download.

Char Mode: Replace Page 1 Count:

• 1 DGl.nrc. gov 09:51:37 1

• • %o a

e O\\

j ( i, 2

UNITED STATES

<; 5 NUCLEAR REGULATORY COMMISSION s -

[

W A S H IN G T O N, D C. 20t a 5-0001 JW 1 1 124.

Mr.

J.

A. Tompkins Science Applications International Corp.

2109 Air park Road Albuquerque, NM 87106

Dear Mr. Tompkins:

Based on the information and test data submitted in your application dated July 26, 1993, and subsequent letters, with enclosures thereto, we conclude the Model 2119-02 is acceptable for licensing purposes in accordance with the conditions of the enclosed registration certificate (NR-0780-D-101-S).

A copy of the certificate has been forwarded to the appropriate reviewer

]

for licensing cction.

Please be advised that you must distribute the product in 4

accordance with the statements and represent ations 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 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, j

Please be aware that, as a holder of an NRC registration, you may be subject to the NRC's licensing and inspection fees in accordance with 10 CFR Part 170, and annual fees in accordance j

with 10 CFR Part 171.

If you have any questions concerning the fee requirements, please contact the License Fee and Debt Collection Branch at (301) 492-7225.

If you have any questions, please contact me et (301) 415-7893 or Mr. Steven Baggett at (301) 415-7273.

Sincerely, k/

mo Thomas W.

Rich, Mechanical Engineer Sealed Source Safety Section Source Containment and Devices Branch Division of Industrial and Medical Nuclear Safety, NMSS

Enclosure:

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

)

4 7; s{(jjfl ~'i 7

E UNITED STATES NUCLEAR REGULATORY COMMISSION

/

WASHINGTON, D C. 20555-0301 a s 1 7 1994 MEMORANDUM FOR:

James L. Montgomery, Senior Materials Specialist Region V FROM:

Thomas W. Rich, Mechanical Engineer Sealed Source Safety Section Source Containment and Devices Branch Division of Industrial and Medical Nuclear Safety

SUBJECT:

SSD TECHNICAL ASSISTANCE REQUEST:

STATE OF ALASKA CONTROL NO. -

571820 In response to your memorandum dated September 10, 1993, for the need of a SSD review associated with the State of Alaska's license application, we have completed the SSD review.

Please find enclosed a copy of registration certificate NR-0780-D-101-S.

Please note the reviewer notes under the Limitations Section contained in the certificate.

I have enclosed a copy of the information sent to me from SAIC regarding security and accountability of these devices, If you have any questions, please contact me at (301) 415-7893 or i

Mr. Steven Baggett at (301) 415-7273.

, Iynw 4'4 /'

Thomas W. Rich, Mechanical Engineer Sealed Source Safety Section Source Containment and Devices Branch Division of Industrial and Medical Nuclear Safety

Enclosures:

As stated cc: SKimberly, LFDCB

)

2 October 31,1996 ASSIGNMENT NUMBER: 96-103 Mr. Stephen L. Pavish Alaska State of Fairbanks 4111 Aviation Avenue P.O. Box 196900 Anchorage, AL 99519-6900

SUBJECT:

ACKNOWLEDGEMENT OF REQUEST FOR SAFETY EVALUATION

Dear Mr. Pavish:

This letter acknowledges the receipt of your October 7,1996, application that requested a safety evaluation and registration of the Model 2119-02. We have performed a cursory review of your application and determined that enough information has been provided to allow a 1

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 j

application or to obtain clarification of technicalissues concerning your application. If you have j

any questions concerning the status of your application, please contact me at (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 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) 415-7554.

Sincerely, JJ/

i (imBerly Randall, Registration Assistant Sealed Source Safety Section Medical, Academic, and Commercial Use Safety Branch Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards Distribution:

SSSS r/f SSD-96-103 SBaggett NE01rP DOCUMENT NAME:C:96-103.wpd T3 eeceive e capo of this document. indcote in the hon:

"C" - Copy without ettechment/ enclosure "E" = Copy with attachment / enclosure "N" s= No copy OFFICE IMAB l

NAME KRandall DATE 10/5//96 OFFICIAL RECORD COPY

.