Emergency Classification

1. Transition To Keyhole, A Better Approach To Emergency ResponseRich Janati, M.S., ChiefDivision of Nuclear SafetyPA Dept. of Environmental ProtectionAdministrator, 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 520/1-78-016)

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. Part 61 Responsibilities During Declared Radiological Emergencies in PA 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. Part 61 Protective Action Recommendation Concept 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. 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