ML20236S348
| ML20236S348 | |
| Person / Time | |
|---|---|
| Issue date: | 11/17/1987 |
| From: | Jeffery Lynch, Mallett B, Wiedeman D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236S340 | List: |
| References | |
| 99990003-87-06, 99990003-87-6, NUDOCS 8711250078 | |
| Download: ML20236S348 (13) | |
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S. NUCLEAR' REGULATORY COMMISSION
. REGION III
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aiepbkNo.':999-90003/87006(DRSS)J R
K LDocket..No. 999-90003'.
General License 40 m:
(10 CFR 31.5) i f '. '
i Wpy y Z" License'e: :: Mead, Corporation l
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.. Worldi Headquarters :
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- Courthous'eiPlaza Northeast-1
$p "Da9 ton,LOH 45463
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pa wr, 26, 1987-Qf JInspection LConducted:-~ June 24: through October vi % L J.
. Lyncti 7
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^, l Inspector:
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Radiation' Specialist ~
Date D "
ReviewedLBy: ;
Ad
/ q 4,4, D. G. Wie eman, Chief m -
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Nuclear Materials' Safety' Date
' k' f Section'1
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[Appro'vedBy:
'B.~S. Mallett,! Chief
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Nuclear Materials Safety Date I
"and Safeguards Branch s
' Inspections ummary.
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Inspection from June 24 to October 26, 1987 (Report No. 999-90003/87006(DRSS))
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" Areas-Inspected:
Special,. announced inspection of generally licensed program relating to-a June'24,.1987, notification of lost nuclear static eliminators.
The-inspection l included a review of.the following:
(1) organization;
?(2)-materials;L(3): facilities;-(4) licensee recovery efforts; and
.-(5)Llicensee. corrective actions.
Results:
Of the areas inspected, two violations were identified:
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.(1) 10.CFR 31.5(c)(8):- improper disposal of generally licensed devices
- containing byproduct material (Section 8); and (2) 10 CFR 31.5(c)(2) - failure 4'
Lto leak test generally 1icensed devices-(Section 8).
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DETAILS 1.
Organization
- Douglas H. Marcero,. Manager, Corporate Health and Safety
- Eileen'M...Sharkey, Industrial Hygiene Program Head
,cAnn Crone, Industrial Hygiene Specialist l
. Fred M.-Eblin,' Employee Relations Representative j
- Harry Sasser, Plant Manager, Kalamazoo I
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> Jerry Kurth, Operations Manager, Kalamazoo l
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- Troy Smith, Plant Engineer, Kalamazoo
- Attended exit interview on August ~18, 1987.
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Mead Corporation produces a wide range of paper products in facilities
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around the country.
The Corporation is divided into a number of divisions, j
including Mead Products,LMead Packaging, and Mead Paperboard Products.
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'A variety of specifically and generally licensed gauges and generally J
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licensed static eliminators are used at 13 of Mead's facilities.
j The corporate safety program operates out of Mead's Headquarters office
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-in Dayton, Ohio.
This program, managed by Mr. Marcero, includes l
radiation safety responsibility for all Mead facilities.
2.
Inspection History None.
3.
Materials The general license, is:ued pursuant to 10 CFR 31.5, allows possession I
and use of industrial gauging.and controlling devices.
Mead Corporation j
uses generally licensed static eliminators on automatic process lines.
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Twenty-one static eliminators were lost, 16 of which contain americium-241 (Am-241) and five containing polonium-210 (Po-210).
The lost devices are Nuclestat static eliminators, Models A-2003, and f
P-2001 manufactured by NRD, Inc., Grand Island, NY and distributed by
. Herbert ~ Products, Westbury, NY.
Both corporations are licensed by the i
State of New York.
Each static eliminator consists of a 36 to 87 inch long aluminum bar plated with silver and gold foil.
Approximately 16 millicuries of americium-241 is incorporated into the foil of each A-2003 static eliminator and 196 millicuries (nominally) of polonium-210 1
in the foil of each P-2001 Model (Attachment A).
Specifically and generally licensed gauges (other then the devices i
reported as lost) used in Mead facilities have been properly maintained j
and accounted for by Mead's corporate safety group (Corporate Safety).
Also, generally licensed static eliminators leased from 3M and used at several Mead facilities, are returned to 3M annually as required.
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Corporate Safety was not aware that the NRD static eliminators were used at other Mead facilities.
A number of personnel changes and a lack of feedback from Mead facilities and vendors resulted in the communication failure.
According to Corporate Safety personnel, they had previously asked each facility for inventories of radioactive material but were never l
informed of the possession of NRD static eliminators.
In May 1987, a Mead engineer from the Kalamazoo, MI facility attended a Mead conference in which hazardous materials (including radioactive material) were discussed.
Prompted by the discussion, he initiated a search on about June 5,1987, ofLthe Kalamazoo, MI-plant where he had used nuclear static eliminators in the past.
When he was unable to locate the devices, the Corporate Safety office was informed of the situation.
Corporate Safety performed inspections of the'Kalamazoo, MI and Garden Grove, CA facilities from June 15 to June 23, 1987.
1he use of NRD static eliminators at Mead facilities has now been discontinued with all recovered devices returned to NRD for disposal.
Leak tests are required by 10 CFR 31.5(c)(2) to be p e formed on the americium-241 devices every six months and on tfa >olonium-210 devices every 13 months.
Herbert Products informs po chasers of static eliminators such as Mead Corporation, of the leak testing requirement and until about 1979 sent leak test reminders to all customers every six (or 13) months.
A notice was sent to customers in 1979 informing them that reminders would no longer be sent (Attachment B).
Several Mead facilities leak tested static eliminators periodically for years before ceasing this practice in 1979 or 1980.
For example,
.The Garden Grove, CA facility tested their devices at approximate six month intervals from receipt in 1972 to late 1980.
No tests were performed after 1980 although five devices remained at that facility.
The Alexandria, PA facility tested their static eliminators from 1976 to 1979.
The Kalamazoo, MI plant tested their devices from I
1975 to 1979 and then stopped even though they retained the devices until 1984 or later.
The polonium-210 static eliminators possessed since November 1982 at the Lynchburg, VA facility were scheduled to be returned to NRD by the end of 1983 for leak test and disposal.
The devices were not returned nor was the 13 month leak test requirement fulfilled by Mead.
Other facilities, such as Atlanta, GA and Chicago, IL apparently never leak tested the static eliminators after receipt according to the records maintained by NRD and Mead.
Mead personnel cite several reasons for the loss of the static eliminators and the failure to perform leak tests.
First, the devices oftentimes did not perform as well as expected and therefore were not being used regularly; secondly, a number of personnel changes were made during this time period and responsibilities were not transferred; and last, in 1979 Herbert Products stopped sending the leak test reminders to Mead.
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.:e 4.
Facilities Six Mead facilities lost Nuclestat americium-241 static eliminators as summarized below:
Mead Products Kalamazoo, MI-4 devices total - 4 lost, none returned to vendor.
Alexandria, PA' 4 devices total - 3 lost, 1 returned.
Atlanta, GA 4 devices total - 3 lost, 1 returned.
Garden Grove, CA 8 devices total - 5 lost, 3 returned.
Mead Packaging Atlanta, GA 2 devices total - 1 lost, 1 returned.
Chicago, IL
'2 devices total - 2 lost (and recovered),
2 returned.
One Mead facility lost Nuclestat polonium-210 static eliminators as indicated below:
Mead Paperboard Products Lynchburg, VA 6 devices total - 5 lost, 1 returned.
The facilities in Kalamazoo, MI; Alexandria, PA; and Lynchburg, VA are under NRC jurisdiction, the other locations are in Agreement States.
l' 5.
Chronology of Events The licensee notified Region III by telephone on June 24, 1987, that four Nuclestat americium-241 static eliminators were not accounted for at the Mead Products Kalamazoo, MI facility.
They indicated that visual searches and radiation surveys of the facility were continuing and that a written report would be submitted to the NRC when completed.
The licensee was instructed to search other Mead facilities and a contractor's Kalamazoo, MI scrap yard.
The written report, dated l-July 17, 1987, confirmed that the four devices were lost and detailed I
the licensee's recovery efforts (Attachment C).
On August 18, 1987, an inspection of the Kalamazoo, MI facility was
' performed by the NRC.
The licensee informed the NRC during the inspect' ion that their internal investigation had discovered 14 additional missing americium-241 static eliminators at other Mead facilities in Pennsylvania, Georgia, California and Illinois.
The lost devices were all Nuclestat Model No. A-2003 as were possessed in Kalamazoo, MI.
The licensee requested that they be given time to physically search and survey each facility in question.
The licensee's investigation discovered 4
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an additional loss of five NRD Nuclestat P-2001 (polonium-210) static eliminators from a Mead facility in Virginia, which was reported to the NRC in an October 14, 1987 letter (Attachment D).
Six americium-241 and one polonium-210. static eliminators were located during the investigation and were subsequently returned to NRD.
Additionally, two americium-241 static eliminators had been returned to NRD in 1979 from the Garden Grove, CA facility.
Me'ad's-investigation was completed and reported to the NRC in a letter l
dated' October 22, 1987 (Attachment E).
A total of 21 static eliminators were identified.as missing.
The NRC concluded its inspection after receipt of the final report from Mead Corporation.
C_hronology:
July.1972 to
- 24 static eliminators, each containing April 1978 16 millicuries of Am-241 received from NRD, Inc.
1979 - 1980
- Leak tests discontinued on most of the l
Am-241 static eliminators as vendor stopped sending semiannual reminders and Mead personnel changed.
November 1982
- Six static eliminators, each containing 196 millicuries of Po-210 received from j
NRD, Inc.
1979 to 1987
- All NRD static eliminators removed from service with most discarded as scrap.
J June 24, 1987
- Telephone notification from licensee notifying the NRC of the loss of four i
Am-241 static eliminators at Mead's l
Kalamazoo, MI facility.
July 17,1987
- Written report to NRC summarizing the Kalamazoo, MI loss.
August 18, 1987
- NRC inspection of Kalamazoo, MI facility.
Mead identifies a total of 18 Am-241 static eliminators unaccounted for at its facilities.
Mead requests additional time for internal investigation.
l September 30, 1987 - Written notification from licensee reporting that 2 Am-241 static eliminators were located at Mead's l
Chicago, IL facility.
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October 9, 1987
- Telephone notification from licensee
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notifying the NRC of the discovered j
loss of five Po-210 static eliminators at Mead's Lynchburg, VA facility.
October 14, 1987
- Written report to NRC detailing Lynchburg, VA loss.
j October 22, 1987
- Final written report to NRC summarizing losses of 16 Am-241 and five Po-210 static eliminators.
6.
Licensee Recovery Efforts The licensee notified all of its facilities of the incident and conducted I
an extensive investigation of all facilities that used radioactive
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materials'.
Responsible parties at each plant were instructed to provide l
informatiori cegarding such materials to Corporate Safety.
The investigation included a physical search and radiological survey at each facility.
Where applicable, the search included local scrap yards which service Mead j
facilities.
The investigation located seven static eliminators presumed j
lost, including one'at a scrap dealer's facility.
In their final report 4
to the NRC, Mead identified the most likely disposition of each device.
The facility surveys were performed with an Eberline PG-1 low energy gamma probe on loan from NRD.
The NRD Radiation Safety Officer stated that tests at the NRD facility proved that the probe could detect an i
americium-241 static eliminator from a distance of 20 feet unless significant shielding is present.
l The history of the lost static eliminators is very sketchy due to a j
number of personnel changes at Mead facilities and a general lack of j
records.
NRD was able to provide Mead with some information regarding l
installation dates, leak tests and disposals.
Mead's report lists a number of device dispositions as " discarded as scrap sometirne af ter July 1979" or "date unknown."
It is assumed that static eliminators were sent off for burial in a landfill or were sold to a scrap dealer who most likely sold the material to a smelter.
These transactions may have taken place shortly after removing the static eliminators from service or several years later.
The polonium-210 devices have decayed significantly and now contain less than 25 microcuries of radioactive material in each device.
Due to the low concentration (decayed) of radioactive material, they do not pose a radiological hazard to the public.
The americium-241 static eliminators remain at about 16 millicuries each and constitute a hazard if the alpha l
particle er:itting americium-241 is inhaled or ingested.
Since the l
i isotope is incorporated into the static eliminator foil, some destruction of the device would have to occur before the americium-241 is released.
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JSurveysiperformed.'by ths; licensee did not detect any contamination at scrap dealers where.such destruction.is possible. 'NRD estimates that maximum surfacet radiatica levels on intact ' americium-241 devices are Eon theV order.of 25 mR/hr.-
m;
.<h 17.s Licensee:Correctiv'e Actions Er
~ Adequate.finventory control-was not maintained by Mead in the past as
- Corporate.' Safety was not aware of.the presence of the generally licensed static: eliminators at itspfacilities. An inventory program is now coordinated by the Corporate Radiation Safety Officer (RS0) to monitor device status andilocation.
Proposed corrective actions by the licensee a.
Linclude:
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! Modification.of the audit program to include generally. licensed materials;
- 1
- Required notification to Corporate, Safety of acquisition of g
. radioactive: materials.
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,3 Annual, source inventory by Corporate Safety.
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Limitation.on use =of americium-241 sources for static control.
. Provide training videotapes to facilities using generally lic w :.a materials.
'The!above actions ~are expected to preclude the possibility of a lost
' device situation in the future.
Mead and NRD will also alert personnel to watch.for any of the lost' devices which may later turn up.
8.
Conclusions I eSd management appears to have established good control over the M
generally licensed devices after becoming aware.of the lost static eliminators.
A significant^cffort was expended in the attempt to
- recover the missing devices, which in some cases proved fruitful.
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'The control program, along with increased management attention to y
. the matter, has resulted in what appears to be a sound radiation safety program.
As previously mentioned, the long intervals in time which the static eliminators were' unaccounted for.significantly diminishes the chances of recovering the-devices.
4 Telephone;and written reports were submitted to Region III in accordance with 10 CFR 20.402.
Two violations were identified during the inspection.
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Static'. eliminators were lost in Agreement and Non-Agreement states:
. Agreement States - Garden Grove, CA 5
Am-241 Atlanta, GA 4
Am-241 Non-Agreement (NRC) States - Kalamazoo, MI 4
Am-241 Lynchburg, "A 5
.A-total of 12 static eliminators are missing from facilities in NRC States.
In addition, the 12-lost devices as well as the two static eliminators recently returned to NRD from the Alexandria, PA and Lynchburg, VA facilities were'not leak tested as required.
The failure to transfer 12 generally licensed static eliminators in an authorized manner constitutes a violation of 10 CFR 31.5(c)(8).
- The failure to leak test 14 generally licensad static eliminators at the required intervals constitutes a violation of 10 CFR 31.5(c)(2).
NRC Region III is coordinating inspection and enforcement for the Non-Agreement State facilities.
The Agreement States were notified of' losses in their respective states for appropriate enforcement action.
9.
Exit Interview On August 18, 1987, an exit meeting was held at the Mead offices in Kalamazoo, MI.
The individuals present at that meeting are denoted in Section 1.
The lost sources incident, apparent violations and NRC enforcement options were discussed at the meeting.
Attachments; A.
Static Eliminator Description.
B.-
Herbert Products Leak Test Notice, 04/09/79.
C. : Mead. Corporation Loss Report to NRC, 07/17/87.
D.
Mead Corporation Loss Report to NRC, 10/14/87.
E.
Mead Corporation Loss Report to NRC, 10/22/87.
8
ATTACHMENT A n
~ Herbert Nuclestat Static Elirninators
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Forthe elimination of static electricity
. through nuclearenergy.
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StaticElectricity:
a nuisance and ahazard.
As a problem in printing and converting, static Basically it's as simple as that. But getting rid of electricity is essentially a matter of an imbalance of the static once it's generated is not so simple, and electrons. These are the electrons left on the surface the problems it poses can range from a petty nui-(or removedfrom the surface) of printing or convert-sance to potential disaster.. because the static ing stocks af ter they have been in contact with the charge that causes an annoying jolt from a metal moving parts of production equipment. The polarity doorknob is the same agent that can set off an explo-of the static charge can be negative or positive.
sion in a fume-laden environment.
The serious problems Eliminating static can cause.
the problem.
Economically and otherwise, The most effective way to eliminate static is to static can have very serious neutralize it. And the surest way to neutralize it is to
- consequences. These in-ionize the air surrounding the charged material.
s clude:
In this process, electrons are split off from the air PRODUCTION SLOW-molecules, leaving behind particles known as ions, DOWNS (such as occur on which carry either positive or negative charges. The M
sheet fed equipment when static-charged material attracts ions of the polarity l
Opposite to its own and the charge is instantly neu-static attraction causes sheets to cling together).
tralized.
Static eliminators that operate on this principle SPOILAGE (from static-are known as high-energy related web breaks or jam-discharge um,ts (such as ups on printing, folding or the Herbert Curastat). For converting equipment. In years, Curastat type elim-converting, static-attracted inators were the only ef-the function or spoil the a -
el m,n ting static, and A( g j/j contaminants can also affect fecttve instruments for a
pearance of end products.
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DIRECT DAhiAGE TO SENSITIVE hiATERI-c o ce or s rne applica.
ALS (such as photographic film and other light-sen-tions. hiore recently, IIer-I
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I N sitive materia s, magnetic tape and similar converted bert Products perfected a Products).
nuclear solution to the
'k SIIOCK TO PERSONNEL (a minor annoyance to problem and introduced some, but a cause of serious grievance to others).
the Nuclestat, an ad-FIRE & EXPLOSION liAZARD (especially in en.
vanced system with spe-vironments where flammable solvents are used, or cial characteristics and where flammable materials are processed).
benefits.
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Hownuclearstatic eliminationworks...
The major distinction between electrical and nu-other methods.
clear static eliminators is the method by which they With the Nuclestat method there can be no loss ionize the air. Electrical units accomplish this by of the nuclear material from mechanical vibra-means of high voltage electrical discharge, while nu-tion or impact. Second, the precious-metal compo-clear units achieve the same result through the emis-nents of the Nuclestat foil make it highly resistant sion of nuclear energyin the formof alpha particles.
to oxidation, solvent vapors, etc. And third, the In a nuclear static eliminator, millions of alpha Nuclestat's integrated structure is measurably more particles are emitted each second, and each particle efficient and remains effective longer.
produces thousands of ions from surrounding air molecules.The result is an intense cloud of positive end negative ions available for neutralizing static.
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...andwhy it works "d*'""
bestwith aNuclestat.
Radioactive isotope The emitting element in the Nuclestat is a foilinto cold.0003~
and cold.00002" which the nuclear material is incorporated. The foil consists of layers of gold and silver, welded and i
rolled into a thin ribbon. The nuclear material is mcorporated into the foil by means of a metallurgt-cal technique that makes it an integral part of the foil itself, It also insures the safe retention of the nuclear material within the foil during normal har-diing.
The bonded foilis enclosed in a rugged aluminum q
housing which also contains a specially designed grid. The grid protects the foil and permits a maxi-mum degree of alpha emission. The Nuclestat is available in a standard non-induction model and in an induction model that has proved especially ef-s her.oo-
cold Plate.00002" fective in specific applications.
T. he advantages of Slagnified cross section shows patented prectOus-metalbOnded 1011 cens,,ection wh,ch makes the,ad,eactive fOY nuclearemission.
isotope an integral part of the precious met I f ilin the NUCLESTAT.
hiaking the nuclear material an integral art of the precious-metal substrate is a patented feature of the Herbert Nuclestat. It is definitely superior to
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Thespecialqualities Polonium 210 has a half life of 138 days and an l
ofthe-effe tivew rkinglifeof slightlymorethanayear.
InductionNuclestat' Since they must be replaced at yearly intervals, Nuclestats with Polonium 210 are available on a x
The Induction Nuclestat has found widespread yearlylease basis.
-application in processes where the amount of t
' static may range from extremely high to extreme-hMum M ly small,- or where exceptionally high charges must be reduced to virtually zero. Structurally, Americium 241 has the advantage of being an the main difference between it and the non-in-effective alpha emitter and of having a half ~ life duction modelis the inclusion of induction bristle of 433 years. It does not require yearly replace-i assemblies within the grid. These assemblies per-ment and is therefore available on a purchase l
mit the discharge of static by induction in addi-basis. Because of its extended working life, a l
l tion to the high-energy discharge of the non-in-Nuclestate with Americium 241 is the most eco-l
" duction model.
nomical nuclear static eliminator in the long run.
l The Induction Nuclestat differs from other nu-clear eliminators in that each bristle is surrounded
. by an envelope of ionized air, thereby lowering TheHerbert.Nuclestat.
l the threshhold level at which discharge takes
. place. The net result is increased effectiveness Easytoinstall over a wider range of charge levels, plus an en-practicallyanywhere.
hanced capacity for generating Ionized air.
The design of the Nuclestat is so simple that i
it can be installed simply by attaching it to the l
machine it will be used on at the proper location.
YourChoice of Nuclestats are used today on Coaters... Lami-nators... Extruders... Presses... Folders...
. nuclearSource1Haterial.
Sheeters... Bag Machines...and other types of equipment in the graphic arts, converting, pack-aging and plastics industries.
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Freestaticsurvey andtechnical In addition to being available in induction and assistance.
non-induction models, the Nuclestat offers a choice of two" nuclear source materials, each of HerbertProductshr.smore
, which has its own set of economical and opera.
than 30 years of experience
- tional benefits.
in eliminating static in ap-plications of every conceiv-able kind.Callon us for free technicalassistance oran on-Pbionium 210 the-spot surveyof your static Polonium 210 has the more intense alpha emis-problems. We can not only sion of the two and is well suited for neutralizing help you solve existing prob-s
. high-level static charges. A Nuclestat with Polo-lems, but can help prevent r
nium 210 is the highest powered nuclear static new ones in facilities that hf# -
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- climinator available today. It contains 12.5%
are now in the planning or PyI.
more energy per linear inch than other units.
construction stage.
1 HMRBERT Static Eliminators, Sheet and Web Cleaners, Infrared ink Dryers For more information contact Herbert Products Inc., P.O. Box 384, Linden Ave., Westbury, N.Y.11590. Tel: (516) 334-6500
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t er ATTACHMENT B g
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/f7TI HEREEE wastsuav. N r. s iseo e
e tats pneas: sie.asa.esco SPECI ALISTS IN ST ATIC ELIMIN ATION. CLE ANING AND ORYlNG April 9,'1979 Mr. Rudy'Marschik Mead Products 4141 Manchester Road Kalamazoo, Mich.
49001 RE:
NRD 2766
Dear Mr. Marschik:
As"you are undoubtedly aware, Federal regulation require that l
. equipment such as the NUCLESTAT Nuclear Static imination Bar(s) which you have in your plant be " wipe" tested nnually.
This test is necessary to determine radiation leakage from the bar.
Inasmuch as you purchased the bar(s), on your Purchase Order No.
6372, you are completely responsible for maintaining the proper records for inspection by both Federal and State authorities.
We'will,.at you request, supply you with the needed materials and perform the test analysis at a charge of $25.00 per bar.
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If you do.not feel this to be desirable, you may of course have an outside agency or properly licensed staff personnel per-form the test analysis.
Kindly alert any responsible parties and place this letter in your permanent records.
Semi-annual reminders will no longer be provided.
Very truly yours, HERBE PRODUCTS INC.
Roy J.
Simmons RJS:pc cc:WA CERTIFIED MAIL RETURN RECEIPT REQUESTED ATLANTA LosANGELES P M t L A D E LP MI A CMICACO 80STON L I C E N S E O u a N U 8 A C T U D E 88 5 I N ENGLAND INELANDANDJapaN
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