ML20212F769
| ML20212F769 | |
| Person / Time | |
|---|---|
| Issue date: | 10/31/1997 |
| From: | Doug Broaddus NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Lee Harmon SAFETY LIGHT CORP. |
| References | |
| SSD, NUDOCS 9711050085 | |
| Download: ML20212F769 (2) | |
Text
_ _ _ - .
ptvK8?g
'_ye l*, UNITED STATES -
NUCLEAR REGULATORY COMMISSION-WASHINGTON, D.C. 2056H001
%, october 31, 1997 Larry Harmon, Plant Manager Safety Light Corporation 4150A Old Berwick Rd.
Bloomsburg, PA 17815
Dear Mr. Harmon:
This is in reference to your applications dated April 4,1995, and subsequent letters, with enclosures thereto, requesting approval of the Models 602,604,616,758-14,758-B, and 758-D Emergency Exit Lights for use by persons generally licensed under 10 CFR 31.5, and a follow-up to our meeting on October 30,1997. The above devices have previously been authorized for distribution as Aircraft Luminous Safety Devices for use by persons generally licensed under 10
- CFR 31.7. In order to continue our review, please address the following issues:
- 1. The prototype testing listed in 10 CFR 32.101 for Aircraft Luminous Safety Devices does not seem to be applicable fcr the intended conditions of use you specified for the exit signs for use under 10 CFR 31.5. Examples include typical drops and impacts the signs may be subjected tc, the thermal shock test specified in ANSI N540-1975, and harsh conditions the signs may encounter in a mine or cave.
- 2. The requirements for labeling of devices intended for use by persons generally IMensed under 10 CFR 31.5 is not the same as for those intended for use by persons generally licensed under 10 CFR 31.7. These requirements are codified in 10 CFR 32.51. For example, the following criteria apply:
. The wording of the labeling must meet the requirements of 10 CFR 32(a)(3)(iii).
. 10 CFR 32.51(a)(s) specifies that the labeling must be durable for its intended conditions of use and rnust be installed such that it is legible and clearly visible.
- 3. The instructions and precautions for use of Aircraft Luminous Safety Devices ace l typically not the same as exit signs intended for use by persons generally licensed under i
10 CFR 31.5. Please provide all instructions and precautions for use that will be provided to the users of these devices as exit signs. These may include, but not be limited to, the subject areas of installation, relocation, maintenance (including labeling),
repair, and L:ser do's and don'ts.
l 4. The requirements for exit signs intended for use by persons generally licensed under 10 p CFR 31.5 require a determination of the potential deses to persons under ordinary conditions and accident conditions. The information submitted in support of the Aircraft Luminous Safety Devices is sufficient to address the potential doses under ordinary
!~
conditions. Please address the potential doses under accident conditions as identified in 10 CFR 32.51(a)(2)(iii).
' 5. Please provide the estimated useful working life of these devices when used as standard exit signs, t
.n n V
9711050085 PDR RC 971031 e
f SSD pp
+
h!
e L. Harmon ' Please provide the requested information in duplicate with!n 30 days of the date of this letter. If you have any questions, please contact me at (301) 415-5847 or Mr. Steven Baggett at _
(301)415 7273.
l Sincerely,
/s/ l Douglas A. Broaddus, Mechanical Engineer ;
Sealed Source Safety Section i Medical, Academic, and Commercial Use Safa+y Branch Divisiois of Industrial and Medical Nuclear Safety Office of Nuchar Material Safety and Safeguards ,
Distribution:
SSD-96-113 SSSS r/f NE01 SSD File # NR-0579-D-112-G JKinneman, RI BUllrich, RI
- DOCUMENT NAME: C:\WPDOCS\SSDS\DEF._LTRS\NR579112.DEF n . v ., w. e um.ai. n.ac.i. ni in. b.o c - copy tnout ttaenm.nv ncious c - copy min .ti.cnm.ni/.ncio.ur. u - no cocy OFFICE IMAL [C [_ _
NAME DBrdaddds =
DATE 10/4/97 OFFICIAL RECORD COPY