Mmmmm....From Callaway. I'm in the mood to stir up a hornets nest this morning. .......Let us see if this can spin off to a new discussion.
To answer Chucks question. Callaway does NOT consider a contaminated hard hat to be a PCE. This is specifically and clearly stated in our procedure. Yes, we are aware of INPO C.2.d (Page 74) specifying that a contaminated hardhat should be a PCE. We disagree. The hard hat is a safety device that is several inches away from the body. It is entirely reasonable to expect a worker to handle the hard hat while inside the Contaminated Area, or even fall off of the head to the floor of a CA. It would be entirely reasonable to require the worker to adjust or re-don the hard hat with contaminated gloves. Therefore counting a contaminated hard hat as a PCE is self-defeating and of zero added value. We have never seen skin or hair contamination from this, so the risk is minimal. Additionally, the hard hat is made of thick plastic (generally), that shields any beta dose. The EPRI contamination response guidelines are focused on skin dose, so again, contamination of a hard hat presents little risk. Whether or not our good friends from Atlanta will make an issue of this is for the future to tell. To answer Palo Verde's original question, Callaway does allow use of personal hard hats in Contaminated Areas, we also provide RCA hard hats that stay in the RCA (sometimes they stay in the contaminated area). We have janitors clean and disinfect the hard hats following use and restock the "donning bins". The process is pretty much the same both outage and routine operations, except during outages we set up the don and doff bins inside the Contaminated Area, the worker enters the turnstile at the Containment, and if they need one, grabs a hard hat at the don barrel. The hard hat is removed at dress out and placed in the doff barrel. SO! What say you? Others that do not count a contaminated hard hat as a PCE, what is your motivation and justification? Or for that matter, those on the other side, what is yours? Most respectfully, Dewey. : : : : : : : : : : : : : : : : : : : : : : : : : Dewey Thompson Staff HP Radiation Protection Department T 314.225.1061 F 573.676.4484 E [email protected]<mailto:[email protected]> From: [email protected] [mailto:[email protected]] On Behalf Of Creamer, Charles E Sent: Tuesday, June 03, 2014 2:33 PM To: '[email protected]' Subject: Powernet: RE: hard hats in contaminated areas Browns Ferry uses both designated hardhats and personal hardhats. For some areas with higher levels of contamination like the drywells we always use designated yellow hard hats. We have hard hat covers available when using a personnel hard hat. If you use personnel hardhats in c-zones and they get contaminated, how do you not count them as a Personnel Contamination? Chuck Creamer Charles E. Creamer Health Physicist Tennessee Valley Authority Browns Ferry Nuclear Plant P.O. 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From: [email protected] [mailto:[email protected]] On Behalf Of [email protected] Sent: Thursday, May 29, 2014 4:15 PM To: [email protected] Subject: Powernet: hard hats in contaminated areas Palo Verde is looking for the industry standard on hard hats in contaminated areas: Do you have people use their own, or do you provide hard hats for use in CAs? Do you handle this issue differently during outage vs. online? Thanks for your time! Heather Jackson, CHP, RRPT Sr. Health Physicist Palo Verde Nuclear Power Plant 623-393-6076 --- NOTICE --- This message is for the designated recipient only and may contain confidential, privileged or proprietary information. If you have received it in error, please notify the sender immediately and delete the original and any copy or printout. Unintended recipients are prohibited from making any other use of this e-mail. 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