Re: Exempt Smoke Detectors

["Wesley M. Dunn" <WDUNN@brc1.tdh.state.tx.us>]

cc: tarzijp@naesco.com

Jay,

The answer is easy: You need to obtain a Specific License that 
authorizes cleaning and maintenance of smoke detectors.  The 
authorization should specify that the detectors be returned to the 
exempt user (e.g., itself).

Wes


> Date sent:      Wed, 21 Aug 96 16:15:34 -0500
> Send reply to:  radsafe@romulus.ehs.uiuc.edu
> From:           "James P. Tarzia" <tarzijp@naesco.com>
> To:             Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:        Exempt Smoke Detectors

>      
>      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.
> 
> 
*********************************************************************
Wesley M. Dunn, CHP                        512-834-6688
Deputy Director, Licensing                 512-834-6690 (fax)
(Texas) Bureau of Radiation Control        wdunn@brc1.tdh.state.tx.us
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