Re: Smoke Detector shipment

["Eli A. Port" <eport@nwu.edu>]

At 09:07 PM 11/24/98 -0600, Sue Dupre wrote:
>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

Your concerns about both the dose rate at the package surface and the
activity limit for normal form are well founded.  If necessary, you can
divide the shipment to comply with both requirements.  A large container
may control the surface dose rate.  The Am-241 foils are probably special
form.  However, the shipper must have and retain a current Special Form
Certificate to ship as special form.

Eli
ELI A. PORT, CHP, CIH, P.E.
RSSI
eport@nwu.edu
VOICE:708.965.1999, 24X7
FAX:  708.965.1991
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