Smoke Detector shipment

[Sue Dupre <dupre@Princeton.EDU>]

RADSAFErs:

We've been authorized to return several dozens of old smoke detector
heads, each containing 80 uCi of Am-241, to the manufacturer.  The
manufacturer is assuring me that I can ship these all back without
problem as an excepted package for radioactive instruments and articles
but it doesn't look so straightforward to me for two reasons:

I'm concerned about the radiation level limit for limited quantity
packages (don't have the detectors here in my building and haven't made
any measurements yet but was suspecting that a package of 40 of them
would be likely to exceed the 0.5 mrem/hr limit unless I went to special
lengths to add shielding to the package)

The manufacturer hasn't yet given me any documentation to the contrary
so I'm assuming that the smoke detectors do not contain Am-241 in
special form (when I spoke the manufacturer's rep he kept saying that it
was OK to ship them because they were sealed sources - he didn't know
the special form terminology).  If they're not special form, then the
activity limit per package is 5.41 mCi and the limit per detector is
54.1 uCi.  Consequently, unless there's a special exemption somewhere in
the DOT regs, it doesn't look to me like I can easily ship these back. 
I called DOT's Hazmat Information Center to see if there were any
special exemptions for smoke detectors, and the person I spoke to
referred to the excepted packages for radioactive instruments and
articles reg (49CFR173.424).  

What am I missing?  They got shipped here in the first place so I would
really really hope I can ship them out of here without too much
trouble.  Your suggestions, regulatory references, etc. are appreciated.

Sue Dupre


=======================================================
Sue M. Dupre, Health Physicist

Environmental Health and Safety Office      
262 Alexander Street    
Princeton University                           
Princeton, NJ  08544

E-mail: dupre@princeton.edu
Phone:  (609) 258-6252
Fax:    (609) 258-1804

Visit the EHS Web site at http://www.princeton.edu/~ehs
=======================================================
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