1. Transition To Keyhole, A Better Approach To Emergency Response Rich Janati, M.S., Chief Division of Nuclear Safety PA Dept. of Environmental Protection Administrator, Appalachian Compact Commission

2. Emergency Classification
1. Unusual Event (UE)
Potential degradation of the level of safety of the plant or a security threat to facility protection
No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occur
2. Alert
Actual or potential substantial degradation in the level of safety of the plant, or a Hostile Action within the owner controlled area, or an airborne attack threat to the plant
Any releases are expected to be limited to a small fraction (1%) of the EPA PAG exposure levels at or beyond the site boundary
PAG – Protective Action Guides (Sheltering or evacuation - 1 to 5 rem
projected dose over four days; Administration of KI - 5 rem projected child
thyroid dose)

3. Emergency Classification (cont’d)
3. Site Area Emergency (SAE)
Actual or likely major failures of plant functions needed to protect the public, or Hostile Action within Protected Area of the plant
A release of radioactive materials to the environment that could result in radiation doses greater than 10 % of an EPA PAG at or beyond the site boundary
4. General Emergency (GE)
Actual or imminent substantial core damage or melting of reactor fuel with potential for loss of containment integrity, or Hostile Action that results in an actual loss of physical control of the facility
Releases can reasonably be expected to exceed EPA PAG exposure levels offsite for more than the immediate area

4. Emergency Planning Zones
Exposure Pathway EPZ
The plume exposure pathway EPZ has a radius of about 10 miles from the reactor site
Protective action plans for this EPZ are designed to avoid or reduce dose from potential exposure of radioactive materials
Protective actions include sheltering, evacuation, and the use of potassium iodide (Kl) where appropriate
Ingestion Exposure Pathway EPZ
The ingestion exposure pathway EPZ has a radius of about 50 miles from the reactor site
Protective action plans for this EPZ are designed to avoid or reduce dose from potential ingestion of radioactive materials
Protective actions include a ban of contaminated food and water
The sizes of the EPZs were developed by the NRC/EPA Task Force Report on Emergency Planning (NUREG-0396/EPA 520/ )

5. Fission Product Barriers
Fla
Reactor Coolant System
Primary Containment
Fuel Cladding
Reactor Coolant System
Primary Containment
Loss of two fission product barriers and “potential” loss of the third will result in a GE

6. Background Information
PA has the second largest number of nuclear power plants (NPPs) in the U.S. – 9 plants at 5 sites (6 BWRs and 3 PWRs)
PA ranks second in the nation in nuclear generating capacity
More than 700,000 people live within the 10-mile EPZ of the NPPs in PA
PA is within the 50-mile ingestion pathway EPZ of four NPP sites
Three states are within 10-mile EPZ of the PA NPPs (MD, OH, WV)
There are three nuclear utilities in PA – Exelon, FENOC, and Talen
All four types of emergencies or classes of events have been experienced in PA

7. Nuclear Power Plants in PA

8. Responsibilities During Declared Radiological Emergencies in PA
Part 61
Department of Environmental Protection, Bureau of Radiation Protection (BRP) – BRP is responsible for technical assessment of radiological incidents and evaluation of off-site consequences
Pennsylvania Emergency Management Agency (PEMA) – PEMA is the lead agency for direction and coordination of the State response to a radiological emergency
Department of Health (DOH) – DOH is responsible for directing emergency workers, the public, and special population to take KI, in consultation with BRP
Department of Agriculture (DOA) – DOA is responsible for sampling of milk, agriculture and food products, and taking protective actions for the ingestion pathways 7

9. Protective Action Recommendation Concept
Part 61
Purpose of Protective Action Recommendation (PAR) – Protective actions are emergency measures taken for the purpose of preventing or minimizing radiological exposures to affected population groups
Protective Action Decision (PAD) – The OROs will take the PAR from the licensee and make a PAD. The PAD may be the same as the PAR, or it may differ based on additional information available to the OROs
PAR Decision Process – The ORO PAR decision process should consider plant conditions, utility PAR, impediments, and evacuation time estimates
OROs – Offsite Response Organizations 8

10. PA Protective Action Recommendation Policy
Evacuate or shelter 10 miles and 360 degrees for the entire EPZ
PA is the only state that continues to use the 10-mile, 360 degree evacuation/shelter model
Evacuation is considered the preferred PAR for the general population except if there are impediments or if the release duration is short
Administration of KI
A GE has been declared and release is imminent; OR
A release is in progress with offsite projected CDE of 5 rem (child thyroid)
CDE – Committed Dose Equivalent
Utility default PAR at a GE creates a significant challenge for PA due to current PAR Policy of 10-miles, 360 degrees

11. Keyhole Evacuation Far fewer people evacuating Less traffic congestion
Significant reduction in resources needed to support the evacuation
NUREG/CR-7002, “Criteria for Development
of Evacuation Time Estimate Studies”

12. Moving Away From a Default Full EPZ PAR
Lessons learned from Hostile Action Based exercises in PA
Potential impact of PA PAR policy on other states within the 10-mile EPZ of NPPs in PA
Current EAL scheme for declaration of a GE is conservative (loss of two fission product barriers and “potential” loss of the third)
Potential for casualties due to evacuation
Consideration of key new concepts in NUREG-0654, Supplement 3 - “Guidance for Protective Action Strategies”
EAL- Emergency Action Level

13. Consideration of Key New Concepts in Supplement 3
Rapidly Progressing Severe Accident – A GE with rapid loss of containment integrity and loss of ability to cool the reactor (potential for large early release scenario)
Staged Evacuation – A staged evacuation is where one area is ordered to evacuate while adjacent areas are ordered to shelter in place until directed to evacuate
Wind Persistence and Wind Shifts – A documented analysis performed for each site to examine the variability of the wind over the ETE period
Evacuation Time Estimates (ETEs) – The estimated time needed to evacuate the public from affected areas of the plume exposure pathway EPZ
“Safer To Do So” – The PAR determination process will rely upon the judgment of decision makers (licensee and OROs) to determine it is safer for the public to evacuate sheltered areas

14. Impediments to Evacuation
NEI 12-10, “Guideline for Developing a Licensee PAR Procedure Using NUREG- 0654, Supplement 3”
Impediments represent the inability to evacuate a large portion of a given population of a given area vs. individual block or roadway
PA Policy
Impediments to evacuation should be considered as part of the PAR process
Challenge for PA
Identify and communicate impediments BEFORE the licensee provides PAR notification to the state (except for Hostile Action Based scenarios and releases of short duration)
NEI-Nuclear Energy Institute

15. Transition to a Keyhole PAR
Phase 1: Develop Public Information Materials and a User-friendly PAR to PAD to EAS Tool
  Public Information Materials
Development of detailed maps of ERPA and EPZ boundaries
Descriptions of a keyhole evacuation and why it is beneficial
Discussions of important concepts, i.e., shadow evacuation, shelter-in-place, monitor and prepare, etc.
ERPA – Emergency Response Planning Areas defined by geographic or political boundaries

16. Transition to a Keyhole PAR
Phase 1 (Cont’d)
User-friendly PAR to PAD to EAS Tool
Development of a user-friendly interface tool that uses utility PAR, maps the sectors to ERPA-based PADs, and automatically connects to pre-scripted EAS messages
PEMA and the local agencies within the EPZs will have access to the tool and training in proper use of the tool
EAS – Emergency Alert System

17. Emergency Planning for Oyster Creek Generation Station
MAP of ERPAs
Emergency Planning for Oyster Creek Generation Station

18. Transition to a Keyhole PAR
Phase 2: Training and Plan Revisions
Training
Development of training materials for PEMA and local agencies on keyhole evacuation and the changes in methodology and resources needed for this transition
Plan Revisions
Revise the state emergency plan and the SOPs as appropriate to support a potential keyhole evacuation
Incorporate lessons learned from the industry and other states in the development of the revised plan
SOP – Standard Operating Procedures

19. Transition to Keyhole PAR
Phase 3: Public Information and Outreach (TBD)
Consider the need for public meetings or open houses within the EPZs to educate the public on the transition to a keyhole evacuation
Prepare for challenges and opposition to the transition toward a keyhole evacuation or sheltering

20. Transition to Keyhole PAR
Path Forward
Present Statement of Work to REPAC
Seek approval from PA Governor’s Policy Office
Initiate “Request For Proposal”
Award contract and implement new policy
REPAC – Radiological Emergency Preparedness Advisory Committee