While I do appreciate Callaway's stance on hardhat PCEs, Cook currently still does count a contaminated hardhat as a PCE. But, we are attempting to navigate the waters to sanity based in part on some of the same reasoning Dewey has expressed. Cook has never assigned dose from a hard hat (or ED) PCE, forgiving the contamination that actually gets on the paper hardhat cover while working inside the CA.
Currently, Cook does take a slightly different twist on hard hat PCEs. We brief workers and RP techs that as a worker doffs their PCs at the SOP, removing the paper cover from their personal hardhat (response to Palo Verde), they need to inform the technician at the SOP if they had to handle their hardhat in the CA. If they had to tighten it (using the unprotected knob, set it down (touching the underside of the bill), dropped it, etc., they need to let the RP tech at the SOP know so he can specifically survey and release the hardhat from the CA, as we would any tool or piece of equipment we suspected to be contaminated. If they fail to inform us of such issues and then ring up the PCM, it would count as a percon. We take this same stance on contaminated EDs. If they handle the ED and believe they could have contaminated it, and we/they don't catch it as they perform a hand/foot frisk as they are leaving the SOP area (before passing through a PCM), they would be a percon for a contaminated ED as well as the PCM alarmed. We take the stance that these uncontrolled contaminated items across the SOP caused the PCE, and certainly could cause more issues as they traversed through the Restricted Area. From this stand point it really is more of an uncontrolled contamination issue of course, not a dose-significant, PCE issue. Now that INPO has expressed the thought that Level 1 PCEs aren't as tragic as once thought (1/day/RFO) we'll see some relief from hard hat PCEs(?). Cook has tried the "Community CA-designated hardhat" route but had too many complaints from workers; not wanting to wear someone else's hardhat, they are sweaty, they have cooties, some bored workers found the time to decorate them with questionable graphics (up to and including a very authentic NRC eagle insignia- found by the NRC), and we had to constantly survey and wipe them down and most of all (being an ice condenser plant) we didn't have the real estate to stage them. Thanks all, Dave Raye RP Operations Gen Supv Cook Nuclear Plant 269-466-2803 (O) 269-405-6040 (C) 2803 pager From: [email protected] [mailto:[email protected]] On Behalf Of Thompson, Dewey L Sent: Wednesday, June 04, 2014 9:11 AM To: [email protected] Subject: Powernet: RE: hard hats in contaminated areas This is an EXTERNAL email. STOP. THINK before you CLICK links or OPEN attachments. ________________________________ 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]> [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. Box 2000 (Mail Stop NAB-1G-BFN) Decatur, Al. 35609-2000 Phone: 256-729-2983 Fax: 256-729-3101 Pager: 1-800-323-4853, pin 30-053 mailto:[email protected] REMEMBER - You don't know what you don't know This electronic message transmission contains information which may be TVA SENSITIVE, TVA RESTRICTED or TVA CONFIDENTIAL. Any misuse or unauthorized disclosure can result in both civil and criminal penalties. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the content of this information is prohibited. If you have received this communication in error, please notify me immediately by email and delete the original message. From: [email protected]<mailto:[email protected]> [mailto:[email protected]] On Behalf Of [email protected]<mailto:[email protected]> Sent: Thursday, May 29, 2014 4:15 PM To: [email protected]<mailto:[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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