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. Background Information
Emergency Classification
The emergency classification levels, in ascending order of severity, are:
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
Alert
Actual or potential substantial degradation in the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equip. due to Hostile Action
Any releases are expected to be limited to a small fraction (1%) of the EPA PAG exposure levels at or beyond the site boundary

3. Background Information
Emergency Classification (cont’d)
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
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. Background Information
Emergency Planning Zones (EPZs)
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 and 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. 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
There are 3 nuclear utilities in PA – Exelon, FENOC, and Talen
All four types of emergencies or classes of events have been experienced in PA

6. Nuclear Power Plants in PA

7. Responsibilities During Declared Radiological Emergencies in PA
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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

8. Protective Action Recommendation Concept
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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 – In PA, the PAR decisions are based on plant conditions, utility PAR, consideration of impediments, and evacuation time estimates
Utility default PAR at the declaration of a GE creates a challenge for PA
OROs – Offsite Response Organizations

9. PA Protective Action Recommendation Policy
Evacuate or shelter 10 miles and 360 degrees for the entire EPZ
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 dose of 5 rem (CDE)
It is expected that the licensee convey plant conditions, release status, and actions planned or in progress to the Senior State Official in a timely manner

10. Keyhole Evacuation Far fewer people evacuating Less traffic congestion
Significant reduction in resources needed by state and local agencies to support the evacuation

11. Moving Away From a Default Full EPZ PAR
Lessons learned from Hostile Action Based exercises in PA
Potential impact of PA PAR on other states within the EPZ of NPPs in PA (MD, OH, and WV)
Potential for casualties due to evacuation
Consideration of key new concepts in NUREG-0654, Supplement 3 - “Guidance for Protective Action Strategies”
Rapidly Progressing Severe Accident
Staged Evacuation
Wind Persistence and Wind Shifts
Evacuation Time Estimates
Safer To Do So
Impediments

12. Consideration of Key New Concepts in Supplement 3
Rapidly Progressing Severe Accident – A General Emergency (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 (NUREG/CR-7002)
Wind Persistence – 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

13. 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 HAB scenarios and releases of short duration)

14. Transition to a Keyhole PAR
Phase 1: Revisions to Public Information Materials and Development of a Custom PAR to PAD Tool
 Revisions to the 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 to support emergency response planning

15. Transition to a Keyhole PAR
Phase 1 (Cont’d)
A telephone survey of the public within the EPZs to determine the preferred method for dissemination of emergency planning information
Custom PAR to PAD Tool
Uses the licensee’s PAR, maps the sectors to ERPAs, and automatically connects to pre-scripted EAS message
PEMA and the local agencies within the EPZs will have access to the tool and training in proper use of the tool

16. MAP of ERPAs

17. 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
Review and revise the state emergency plan as appropriate to support a potential keyhole evacuation
Incorporate lessons learned from the industry and other states in the development of the revised plan

18. Transition to Keyhole PAR
Phase 3: Public Meetings (TBD)
Conduct public meetings or open houses within the EPZs to educate the public on plan revisions
Expect challenges and opposition to the transition toward a keyhole evacuation or sheltering

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