Re: Disposal of Smoke Detectors

[William V Lipton <liptonw@dteenergy.com>]

This is a timely contrast to those who want to dispose of sources that are
"exempt quantities" under 10 CFR 30.18.  Smoke detectors fall under the
exemption of 10 CFR 30.20 for "gas and aerosol detectors containing byproduct
material."  Note that this exemption includes an exemption from the
requirements of 10 CFR 20, while the provisions of 10 CFR 30.18 do not.  Thus,
domestically manufactured smoke detectors can be thrown out with ordinary
trash.  (The NRC did a safety analysis to show that this is not a hazard.)  One
caution:  This exemption does NOT apply to imported smoke detectors.

See HPPOS-150, "Disposal Requiremets for Specific and Exempt Licensed Smoke
Detectors.":  "...We agreed that the imported detectors must be returned to the
manufacturer in accordance with your licenses ... To the extent that you
possess domestic smoke detectors distributed as exempt units, you are exempt
from any regulatory requirements.  Therefore, you may dispose of these units as
ordinary trash."

It is also useful to note that the exemption for "self luminous products
containing tritium, krypton-85, or promethium-147," of 10 CFR 30.19 also
includes an exemption from 10 CFR 20.  We invoke this for our security people,
who have self-luminous sights on their weapons.

Another important exemption is that of 10 CFR 40.13, "Unimportant quantities of
source material."  We use the exemption for our welding rods, which contain
thorium.  The question arose regarding radiological controls for those who
grind down the rods.  This exemption is further explained in HPPOS-255,
"Airborne Thorium From Welding Rods."  This states that, "...there are no NRC
regulatory requirements that apply to airborne thorium caused by grinding and
using welding rods that contain thorium."  Having said this, I remind everyone
that it is important to control such use, since this can produce alpha
activity, which has the potential for looking like TRU.

The opinions expressed are strictly mine.
It's not about dose, it's about trust.

Bill Lipton
liptonw@dteenergy.com

The opinions expressed are strictly mine.
It's not about dose, it's about trust.

Bill Lipton
liptonw@dteenergy.com

Chuck Pickering wrote:

> Our institution may be replacing a large number of smoke detectors
> (thousands). I know the first option is to return them to the manufacturer,
> but I have been told that some of the manufacturers may be out of business.
> I am looking for options on how to deal with disposing of these devices
> containing Amerecium-241. Any ideas? Vendors can contact me directly.
>
> Chuck Pickering, RSO
> University of Southern California
> (323) 442-2200
> cpickeri@usc.edu
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