Exempt Smoke Detectors

["James P. Tarzia" <tarzijp@naesco.com>]

     Does anyone know an answer to the following question?
     
     If a broad-scope licensee performs maintenance (i.e. cleaning) on an 
     exempt smoke detector containing Am-241, is the detector still 
     considered exempt from licensing?  We know that the NRC's position is 
     that exempt detectors may be disposed of in ordinary trash, however, 
     we are not sure whether the exemption is voided if they are opened by 
     a licensee other than the manufacturer licensed to distribute the 
     smoke detectors as exempt. 
     
     We have many smoke detectors (2 mCi Am-241) that we routinely return 
     to the manufacturer for cleaning.  The manufacturer will not be 
     performing this function in the future.  We would like to perform this 
     cleaning, however, we are not sure whether these should be treated as 
     licensed material (under our broadscope) or exempt. We have spent much 
     time reviewing 10CFR30 and NRC positions as well as discussing this 
     issue with other HPs/licensees and have not been able to get a 
     definitive answer.
     
     Please respond to me at:
     
     
     Jay Tarzia, CHP
     Seabrook Station
     
     tarzijp@naesco.com
     603-474-9521 Ext 3868
     
     I will be more than glad to share the results with the radsafe 
     subscribers if anyone is interested.