ML20197B887
| ML20197B887 | |
| Person / Time | |
|---|---|
| Issue date: | 10/29/1997 |
| From: | John Lubinski NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Kinder K HESCO-MEPROLIGHT (FORMERLY HESTER BROTHERS WHOLESALE |
| Shared Package | |
| ML20197B737 | List: |
| References | |
| SSD, NUDOCS 9712240063 | |
| Download: ML20197B887 (7) | |
Text
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UNITED STAT ES t
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NUCLEAR REGULATORY COMMISSION e
WASHINGTON. D.C. 20$$H001 o
October 29,1997 Kerry R. Kinder HESCO, Inc.
2139 Greenville Road.
LaGrange, GA 30241
Dear Mr. Kinder:
This letter is in response to your application dated January 23,1997, requesting registration of the Model ML-404XX series watches and altimeters and Model ML-416XX series personal markers and amending your license for distribution of the products to persons c.Mempt from licensing. We are in the process of evaluating your request. However, in order to continue our evaluation, the following information is necessary:
1.
Your application indicates that the Models ML 404XX and ML-416XX are series of products where XX is a different set of numbers for each model within the series.
Please indicate the limitations on the boundaries for the series (e.g., maximum and minimum dimensions, mounting configuration of the light sources).
2.
Please provide complete drawings, including all materials, dimensions, tolerances, and source mounting configurations for each item within the series of products.
3.
Pleare provide complete drawings, including all materials, dimensions, and tolerances, for each source mounting configuration.
4.
- Your application indicates that the MEPROLIGHT logo is a thin, bold M (M). However, previous applications inhate that the MEPROLIGHT logo is a wide, modified M (cc).
Please verify that the logo nas not been modified, 5.
Your application indicates that the labeling for altimeters will be applied with epoxy paint. Please demonstrate that the epoxy paint will maintain its integrity during the likely conditions of use for the expected usefullife of the products.
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6.
Your application indicates that MEPROLIGHT has tested the watch and altimeter designs and personal marker designs in accordance with MIL-W-46374F and IDF 7-41040630-90/04, respectively. Please provide:
copies of the referenced standards.
details of the tests that were performed.
drawing (s), including all materials, dimensions, tolerances, and source
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mounting configuration, for the design (s) that were prototype tested.
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2 October 29,1997 K/ Kerry the evaluation criteria used to_ demonstrate that the products passed the testing.
demonstration that each model within the series that was not tested would be expected to pass the prototype testing.
7.
With respect to watches and altimeters, your application indicates that the " Design of '
the dials and hands, and their assembly methodology have been taken directly from -
mb microtec and, therefore, are considered acceptable by direct comparison." Please clarify this statement. Specifically, indicate whether MEPROLlGHT tested prototypes of the products er whether HESCO is relying on the testing performed by mb-4-
microtec. if HESCO is relying on the testing performed by mb-microtec, please indicate why the testing is applicable by providing information on the testing performed and why any differences in the designs would not effect the ability of the product to survive the testing.
8.
Section 32.25,10 CFR indicates that persons licensed to distribute self-luminous products carry out adequate quality control procedures to assure each product distributed meets the standards approved by the Commission. Your applic tion includes details of the quality control procedures implemented by MEPROLIGHT.
However, there is not sufficient detail concerning the procedures that will be
-implemented by HESCO. Please verify that all products distributed will be inspected by HESCO to ensure compliance with the design specifications, including labeling requirements.
9.
Your application indicates that the instructions provided with the products will indicate that the products must be returned to the authorized dealer for any corrective measures or disposal. Please note that this is not a regulatory requirement for users of the products and the instructions should not indicate this as a regulatory requirement. Please verify that the instructions do not misrepresent the regulations.
10.
Your demonstration of how the product design meets the safety criteria in 10 CFR 32.23 indicates that the products will not be inadvertantly discarded and will be retumed to the distributor. However, there is no regulatory requirement for the products to be returned to the distributor nor a prohibition against discarding the products in normal trash. Therefore, please demonstrate dose commitments that may result from disposal of the products will not exceed the regulatcry limits provided in 10 CFR 32.23.
Your demonstration of how the personal marker design meets the safety criteria in
- 11.
10 CFR 32.23 was based on the marker containing~2 sources. However, your application request approval for the markers to contain up to 3 sources. Therefore, please demonstrate that markers containing.3 sources will not exceed the regulatory 1ilmits provided in 10 CFR 32.23.
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October 29,1997 12; Your application for the pesonal markers indicates that during normal use the
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markers will be used less than 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per week. This estimate appears low since it appears reasaonable that the markers would remain on hats and clothing even when not in use. Please provide justification for calculations based on 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per. week.-
. 13_
. Section 30.19(c),10 CFR indicates that the exemption provided in Section 30.19 does not apply for products primarily for frivolous purposes or 3 toys or adomments.
Please demonstrate that the use of tritum in personal markers should not be considered a frivolous use.
14.-
Our records indicate that your possession and use license from the State of Georgia was due to expire in January 1997. Please provide a current copy of your renewed Georgia possession and use license.
15.
Since your Georgia possession and use license authorizes by model number, for possession and storage, all of the gunsight systems Hesco is authorized to distribute, it is recommended that Hesco contact the State of Georgia to request amendment of the possession and use license to add the new devices. Please forward a copy of the amended Georgia possession and use license for inclusion in your license file.
16.
We note that your possession and use license references a model ML 270 that is not authorized on your exempt distribution license or registration certificate. Please clarify the following; 1) what type of device is the ML 270; 2) is this device is being distributed under the exempt distribution license; and 3) should this device be deleted or added to the exempt distribution license and registration certificate.
Please provide the requested information within 45 days. If you have any questions, please contact me at (301) 415-7868 or Ms. Susan Greene at (301) 415-7846.
Sincerely, John W. Lub'nski, Mechanical Engineer 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 Distributiom SSSS r/f SSD-97-003 NE01 SGreene
- SSD File # PENDING DOCUMENT NAME:' C:\\ FILES \\SSDS\\HESCO.DEF u r *....,v. w.
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NAME JLubinslRi/}i.
DATE 10/29/97 3
OFFICIAL RECORD COPY -
l 1-FROM : ESCO IHC.
PHOE NO. : 706 082 4683 Apr. 05 1996 02:37PM P2 l
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- Georaia Deoartment.of Natural Resources 4244 Internationt Parkway, Suite 114. Atlanta, Georgia 30364 8
Lonice C. Sa' rett, Commesoner i
Harold P. Plehede. Derector Envimrvnentet Protection Div sean -
404!34224?d RADIOACTWE MATERIALS PROGRAM
- GEORGIA RADIOACTIVE MATERIAIE LICENSE l
Meganusto to Gee,ye am% cons,el Act 0.C.O A. 31 13 (E.a. As7) 1990 and dw Grassie Depernerer of Neural Esecurces Rades and l
Rapsinusu. Am9amme Oispear 391317. and m iellance on seassenses and repressrundens heressises made by es lionsmes designesed below, e hommes is herstr issued suihnrialen nadi linarese e ranshr. roomve, paneses, and use the radiancshe senartal(s) desismand halow; and en une audi sedisasshe sessreis for en learpnas(n) and at the place (s) designeasd holow. This hennes is malgact an all applicshie rules and regulatens eres Ossrgio N -_: of Named Ranwem and aders inmad hy te Depenment. now or herenner in eMeet. and to any condknon specined halow.
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Page 1 of 3 Pages License Number GA 1036-1 j-Amendment Number '.08 4
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Uoonse (1. Name and 2. Addrese) 3.
In accordance with letter dated February 9, 1996, License Number GA 10351 is HESCO Company amended in its entirety to reed as follows:
2139 Greenville Road 4
LaGrange, Georgia 0240 4.
Expiration Date: January 31,1g97 3
5.
Telephone Niembar: (70A) RA4-727M
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6.
RADIOACTIVE MATERIAL 7.
CHEMICAL AN' D/OR S.
MAXIMUM QUANTITY l
(ELNW8T AfD MASS PHYS 4 CAL PORRA LICENSE MAY POSSES 8 L
NUMSWtl AT ANY ONE TNM A.
Hydrogen 3 A.
Sealed Ught Sources A.
No single source to exceed (Senders-Roe model 54 millicuries i
M.H., MS-Microtec A 3
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model 400/1) 4 B.
- Hydrogen 3 -
B.
Sealed Light sources B.
No single device to exceed 50 milliounes C.. Hydrogen 3 C.
Sealed Ught Source C.
No single device to exceed 2.5 curles D.
Hydrogen 3 n.
5tannati i leht heima D.
No singl* device to exceed 4 curtee.
. E.
-Hydrogen 3 E.
Sealed Ught Source E.
No single device to exceed
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PHCRE to. : 706 882 4683 Apr. 0519% 02:38PM P3 Georgia Department of Natural Resources Radioactive Materials License Supplementary Sheet Page 2 of 3 Pages License Number GA 10351 Amendment Number.08 9.
AUTHORIZED USE A.
For possession and storage in the following gun sight systems manufactured by Mwpuliwht: ML 1150, ML 115P, ML 200A, ML 300A, ML 3OON, ML-100, ML-200, ML 270, ML 400, and ML 750 and their cross reference models listed with the U.S.
Nuclear Regulatory Commission.
B.
For possemelon and storage purposes only in the following systems manufactured by Meproll ht respectivalv: PM 100 Parannal Marker; API AiminD Post Llahts: MR 120 O
Map Reeder; snd LPC 200 Compass.
s CONDITIONS 10.
Radioactive material shall be used only at the licensee's address stated in item 2 above.
11.
The licensee shall comply with the provirions of Georola Department of Natural Resources Rule 391-317.03, "Standerde for Protect.sn Against Radiatlun, Amended" and Rule 391317.07, " Notices, instructions and Reports to Workers: Inspections, Amended.'
12.
In accordance with DNR Board Policy adopted May 27,1992, the fees associated with this license fee category H., are:
Annud Fee
$500 Amendment Fee 4 390 Application Fee
$500 Routine inspection Fee
$1200 Renewal Fee
$ 500 Non-ruutine Fee 41200 Checks for tne toes'should be modo payattle to the Department of Naturel flagmanat Radioactiva Materiala Prnaram. and mailed to the following address:
Radioactive Materials Fees P.O Box 101181 Atlante, Georgia 30302 Mell lioenee applicatione, amendment, and mnewol requests the some day se the check to the followine address:
Radiomative Materials Program 4244 International Parkway, Suite 114 Atlants, Georgia 30364
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FROM i KSCO lt4C.
PHOtE to. : 706 082 4683 APr. 05 1996 02:38PM P2 Georgia Department of Natural Resources Radioactive Materials License Supplementary Sheet Page 3 of 3 Pages License Number GA 1035-1 Amendment Number.08 Condition 12 (Continued)
Inspection fees are payable upon receipt of a ch invoice fruns the Depeitenent a
following inspections. Annual fees are billed by the Department at the beginning of each fiscal year.
13.
The Radiation Safety Officer in this program shall be Will C. Senn.
14.
Radioactive material shall be used by, or under the supervision of Will C. Sonn.
15.
The licensee shall conduct a physical inventory every,six (6) months to account,.for all.
license (matesial seceived and punukswd undus thlu license.
16.
This license does not authonze the commercial distribution of licensed material.
17.
Except es specifically provided otherwise in this license, the licenses shall conduct its program in accordance with statements, representations, and proceduran enntainad in the documents including any enclosures listed below:
A.
Application dated November 24,1986, signed by W. C. Senn, General M anwwwe; H.
Application dated January 28,1992, signed by Kerry R. Kinder, National Sales Manager; C.
Letter dated February 9.1996, signed by Kerry R. Kinder, National Salam Manager; and D.
Letter dated March 8,1996, signed by Kerry R. Kinder, National Sales Monager.
The Georgia Department of Natural Resources' regulatione shall govern unless.the.
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statements, representatione and procedures iri the licensee's application and '
correspondence are more restrictive than the regulations.
FOR THE DEPARTMENT OF NATURAL RESOURCES i
Deco u..nh 12.1996 BY
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t UNITED STATES NUCLEAR 9EGULATORY COMMISSION g,
~t WASHINGTON, D.C. 20%W1 o
49.....,o OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS DIVISION OF INDUSTRIAL AND MEDICAL NUCLEAR SAFETY FAX TRANSMITTAL TO LOCATION 1.
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COMMENTS.
COVER SHEET PLUS PAGES FROM:
O L UA "d5V-t (301)415-79bI PiiONE:
FAX:
isol) 415-5369
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NUCLEAR REGULATORY COMMISSION
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December 9,1997 Kerry R. Kinder HESCO, Inc.
2139 Greenville Road LaGrange, GA 30241
Dear Mr. Kinder:
This letter is in response to your application dated January 23,1997, requesting registration of watches, altimeters, and personal markers and amending your license for distribution of the products to persons exempt f.om licensing, and your November 5,1997, letter that provided additionalinformation in support of the application. We are in the process of evaluating your request. However, in order to continue our evaluation, the following information is necessary:
For Watches:
1.
Drawing 044220 has a note that indicates that the drawing applies to all four models of watches. The bill of matenal indicates the drawings for the second, minute, and hour hands. However, the drawings of the second, minute, and hour hands do not indicate that they apply to all models. Therefore, please venfy the that:
a.
drawing 72442205 (hour hand) and drawing 72442204 (minute hand) are applicable to all models of watches.
b.
drawing 72442203 (second hand)is eppiicable to both the ML 442xx and ML-443xx series of watches.
For Personal Markers:
2.
Please venfy that the personal markers will contain 1 ta 3 sources and not 1 to 5 sources which is Indicated on page 5 of your Novsmber 5,1997, letter.
3.
Please venfy that drawing 603ASSY is applicable to the Models ML-4171x, ML-4172x, and ML-4173x.
4 Please venfy that the Modt.,i ML-4170x that is included in the "Used on:" section of drawing 603ASSY is not a muel of personal marker that HESCO desires to distnbute in the United States.
Far all products:
5.
Please verify that all products distributed will be received by HESCO prior to distribution.
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Please provide the requested information within 30 days. If you have any questions, please contact me at (301) 415 7868 or Ms. Susan Greene at (301) 415 7843.
Sincerely, John W. Lubinski, Mechanical Engineer 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 QistrLbution:
SSSS r/f SSD 97 003 NE01 SGreene SSD File # PENDING DOCUMEfJT NAME: C:\\ FILES \\SSDS\\HESCO.DF2 n,.c.
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NAME JLubinsh/jl DATE 12/09/97 OFFICTAL RECORD ~ COPY
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