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Re: Smoke Detector shipment
I'm reasonably certain that the Am-241 foils are special form. It may be
worthwhile to look at 10CFR32.26-28, which are the requirements the
manufacturer must meet to obtain a license to manufacture and distribute
these
devices. Although the specifications don't match those for special form, I
don't see how a device could be licensed unless it is special form. (The
DOE
facility where I used to work was located near a smoke detector factory. We
once did bioassay on an employee of the factory who had swallowed some
foils.
We could not find any uptake of Am-241. That's one way of assuring the
population dose limits are met!) Obtaining the documentation is another
matter. I've shipped smoke detectors and was supplied with the documentation
by the vendor. One precaution is for older smoke detectors, which may have
been manufactured before these requirements went into effect. I once ran
into
some really old smoke detectors that contained radium instead of americium!
The dose rate problem is an inconvenience, but not a show stopper. You can
limit the number of devices per package, or use an inner package with
spacers
to assure distance; e.g., a box centered in a 55 gallon drum. If the
recipient is nearby, you could make this an exclusive use shipment, with a 2
mrem/hr dose rate limit.
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Bill Lipton
liptonw@dteenergy.com
You wrote:
>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).
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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