ML20128H166

Testimony of Jd Case Re Estimated Time of Evacuation & Bus Driver Training During Emergency at Facilities.Related Correspondence

ML20128H166
Person / Time
Site:	Limerick
Issue date:	07/03/1985
From:	Case J PENNSYLVANIA, COMMONWEALTH OF
To:
Shared Package
ML20128H164	List: ML20128H159 ML20128H166
References
NUDOCS 8507090438
Download: ML20128H166 (5)

Text

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RELATED CORRESPONDENC4 UNITED STATES OF AMERICA

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NUCLEAR REGULATORY COMMISSION the Atomic Safety and Licebik BOafd I49 Before I

CH.a s m.,

! In the Matter of 00CKEimG A Semi BRANCH PHILADELPHIA ELECTRIC COMPANY (Limerick Generating Station, Units 1 AND 2)

Dockets No. 50-352, 50-353 i

I i

t STATEMENT OF MAJOR JOHN D. CASE I

j' I.

QUALIFICATIONS I

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i Major John D. Case hereby incorporates by reference his il;l curriculum vitae, which has been marked as applicant's Exhibit I

l j "1" during his deposition of July 1, 1985.

I would also like to l

i that I have served as Brig Commander of LeJeune, d[ stress the fact i North Carolina, and as the custody officer of the Naval Prison l

t in Port Smouth, New Hampshire during my service in the United h

I' il S tates Marine Corps.

Both of these jobs are similar to the l!I civilian position of a prison warden.

I would also like to stress that I was both warden and director of the Depart-ment of Corrections of Bucks County after I was released j

" from the service.

As Director of the Department of Correc-k i

l

! tions, I was in charge of the adult jail facility, the Bucks *

\\

County Rehabiliation Center, one juvenile home, and three half-way houses.

I would also like to note for the record I

I that I do have prior experience in moving large numbers of individuals as I was in charge of the planning and the even-;

utal evacuation of 3,000 troops during the Korean Conflict i

8507090438 850703 PDR ADOCK 05000352 I

T PDR

from the front lines of that conflict to the rear.

My plans called for an evacuation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and this was in fact j

achieved despite adverse weather conditions which prevailed at f

the time.

I concluded that my original estimates were con-servative in that they were met despite the adverse conditions.

I.

I also note for the record that I am currently the Field i

l!

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Director of the Pennsylvania Prison Society, which was founded l

ii

[

in 1787 by Dr. Benjamin Rush.

I also note that I have been I

i a trainer and trainee on numerous occasions throughout my l

I career, which are listed in greater detail in my curriculum 1

I vitae.

i II.

ESTIMATED TIME OF EVACUTION It is my opinion that the overall plan is specula-tive based upon a number of contingencies.

These contingen-cies include the inmate knowledge and education of the plan, time of day of the accident, weather conditions, correc-i tional officer training, inmate response, bus driver training, j

traffic patterns, ability to conduct simultaneous tasks men-tioned in the flow chart, and the availability of the necess-ary resources.

It is my opinion that an equally realistic estimate of the estimated time of evacuation as it has been presented to me and with the information currently available

A is 12 to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />.

I am also concerned about certain specific 1

items mentioned in the sequential analysis.

Initially, I l

l would like to discuss the estimated lock down time which is l

I given as 30 minutes in the flow chart.

Given the current i

knowledge of the inmate population with respect to the plan, l

it is unrealistic to assume a 30 minute lock down time could be achieved.

This time is estimated during the best of condi-l i'

i, tions during the normal operation af the facility.

If..the inmate population hears of a nuclear accident through radio or other means at Limerick and has no concept of the evacuation plan, the lock down could go as long as 4 or 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

Past incidents such as the power outage and subsequent riot on C Block on 9/12/83 suggests this time frame to be appropriate.

l i

This incident occurred at 5:15 P.M. and D Block was not secured l I

until 10:05 P.M.

The lock down time for the hostage siege in October of 1981 also took over 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to complete.

Based l

upon my experience being involved in past lock downs and the l

i l

data regarding prior emergency situations at S.C.I.G.

leads me i

to believe that a lock down could take as long as 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to complete.

With respect to the portion of the sequential analy-sis dealing with the arrival of the buses and other vehicles ll i

at the Institution within 2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, I believe this esti-mate may also be too conservative.

If the buses are coming from up to 190 miles away during a simultaneous evacuation of I

the general public, I do not know if the 2 to 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> estimate l

t can be achieved.

The factors that contributed include the I

i distance the buses will be required to travel, the training I

the bus drivers have received, the weather conditions and the l

time of day, the congestion of the-roadways, the ability to l

h l

.use main roads as opposed to secondary roads, potential bottle h

necks, the possibility of spontaneous evacuations by individ-t uals not conforming to traffic signals and evacuation plans, I

and the type of buses to be utilized.

b i

I have also some concerns as to the ability to i

conduct the other activities mentioned such as the mobiliza-l Il i

I l

tion of manpower, assembly of loading teams, securing and loading inmates, and vehicle exit times; within the suggested I

time frames.

Due to the obvious need to conduct many of these l

l activities simultaneously, the time estimates are speculative.

S h

With a more thorough knowledge of the mechanics of the plan i

i by someone such as Superintendent Zimmerman or another indivi-dual who has knowledge of the development of the time frames, it may be possible to achieve these tasks within the required time.

Today, however, without any additional knowledge, I

e cannot state that these tasks can be performed with any reason-able certainty within the time frame suggested.

8 III.

BUS DRIVER TRAINING With respect to bus driver training, my concern is to the guarantee that such training will in fact be offered 1

l to the drivers and other civilian personnel.

I believe there il is e need for an incentive to be offered in order to guarantee i

participation of the civilian personnel in said training.

To date, no such incentive has been offered.

Such possible i

incentives should include primarily financial inducement such as overtime or extra pay for participation in the training.

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This would insure that all training would in fact occur.

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s also believe that whatever type of training should also be i

offered on an ongoing basis and not as a once-only event.

,n ye - mee