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 $ETED q

NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licebik BOafd I49 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

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t STATEMENT OF MAJOR JOHN D. CASE I

j' I. QUALIFICATIONS I i

i i Major John D. Case hereby incorporates by reference his '

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l curriculum vitae, which has been marked as applicant's Exhibit  !

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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  !

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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 * '

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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 achieved despite adverse weather conditions which prevailed at j f the time. I concluded that my original estimates were con- '

servative in that they were met despite the adverse conditions.

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

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ii l Director of the Pennsylvania Prison Society, which was founded l

[ in 1787 by Dr. Benjamin Rush. I also note that I have been I

, i a trainer and trainee on numerous occasions throughout my  !

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career, which are listed in greater detail in my curriculum  :

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i vitae.

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  !

i be achieved. This time is estimated during the best of condi- l 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

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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  !

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

Il i l tion of manpower, assembly of loading teams, securing and I

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.

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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 I

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

III. BUS DRIVER TRAINING 8 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. I i s

also believe that whatever type of training should also be i offered on an ongoing basis and not as a once-only event.

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