Re[2]: Exempt Smoke Detectors

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

     Wes, 
     Thanks for the reply.  I'm glad you feel confident in your answer. I 
     have received replies from many people around the country, including 
     gov't agencies who have interpreted this issue in different ways.  
     Many people have cleaned the detectors without considering the need 
     for specific authorization.  Pyrotronics information merely says that 
     maintenance on the detectors should be performed by trained personnel. 
      Do you have a requirement in your state regulations (or know of one 
     in federal regs) that requires specific authorization for cleaning of 
     smoke detectors (or maintenance on items distributed as exempt)?  I 
     would appreciate a reference if you have one.
     
     Thanks,
     
     Jay Tarzia, CHP
     tarzijp@naesco.com
     
     _


______________________________ Reply Separator 
_________________________________
Subject: Re: Exempt Smoke Detectors
Author:  radsafe@romulus.ehs.uiuc.edu at Internet
Date:    8/22/96 10:19 AM


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 
*********************************************************************