NRC Licensing of Am-241 (Smoke Detectors)

[Christopher J Stalpes <stalp001@maroon.tc.umn.edu> (Chris Stalpes)]

I have a copy of a letter from Richard E. Cunningham, Director Division of Fuel Cycle and Material Safety, NMSS that was sent out to State Agreement Programs. The copy of this letter was sent to me via Region III NRC. The letter states:


This is a response to your memorandum concerning disposal of smoke detectors by unlicensed persons.  Our comments are as follows:

  1. Our regulations are clear that secondary distributors and consumers may dispose of smoke detectors as ordinary trash, even in bulk.  This policy was clarified and emphasized by a 1980 rule change (45 CFR 38340, June 9, 1980). Therefore, the term "proper disposal" has no meaning, because it implies a (non-existent) legal restiction.  We do not believe that it is appropriate for a regulatory agency to imply that there are legal restrictions on disposal of smoke detectors by consumers.

  2. We agree that it is not a good idea to combine large quantities of any exempt devices, including smoke detectors. We frequently receive inquiries regarding disposal of exempt items. We inform people that there are no legal restrictionson disposal, but that it is a good idea to try to "spread out" the disposals rather than making a large, bulk disposal. (Note for example 10 CFR 32.19(d) which says that exempt quantities should not be combined).

  3. It would not seem practical or enfoceable to attempt to impose legal restrictions of smoke detectors by retailers or consumers.

  4. NUREG/CR-1156 does not directly analyze bulk disposal of smoke detectors. However, note that the analysis covers disposal of about 10 million devices per year: 9 million at 10,000 - 20,000 landfills and 1 million at 300 incinerators. The estimated doses to trash haulers and exposed individuals near the disposal sites are so low that it seems unlikely that even bulk disposals would result in significant radiation exposures. Also, note that a warehouse fire involving 1,000 smoke detectors would result in estimated doses of 2 millirems to the whole body and 50 mrems to the lung.


Basically it says anyone can dispose of smoke detectors. Just do it in small quantities.

I hope this helps??