ML20237F114
| ML20237F114 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 07/31/1998 |
| From: | Dienethal E AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML20237F102 | List: |
| References | |
| 98-744-04-LA, 98-744-4-LA, LA, NUDOCS 9809020073 | |
| Download: ML20237F114 (9) | |
Text
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f UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Thomas S. Moore, Chairman Dr. Jerry R. Kline Frederick J. Shon
)
In the Matter of ) Docket Nos. 50-295/304-LA
)
COMMONWEALTH EDISON COMPANY ) ASLBP No. 98-744-04-LA
)
(Zion Nuclear Power Station. )
Units 1 and 2) ) July 31,1998
)
)
AFFIDAVIT OF EDWIN D. DIENETHAL Under the pains and penalties of perjury.1. Edwin D. Dienethal, hereby affirm pursuant to 28 USC s 1746 that the following infonnation is true and correct:
- 1. In close proximity of Plant Zion, I own property, own a home and reside at the following address: 8354 47* Court, Kenosha, Wisconsin,53142.
- 2. The distance between my home and the gate of Plant Zion is 10.2 miles driving and 8 % to 9 miles as the crow flies. It takes only 17 minutes and 23 seconds to drive to Plant Zion from my home in normal traffic conditions.
- 3. My wife and two children, ages 9 and 6 years, live with me at the above address.
9809020073 PDR 980826 '
MM Sage / Of E O ADOCK 05000295 '
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My wife and I have lived at the above address since 1991.
- 4. The property value has an estimated fair market value of $172,504 and the contents of the house are insured at over $100,000. Ifit is revealed that the decommissioning of Plant Zion is not conforming to present rules, I believe that this would affect my ability to sell my property at the current market value.
- 5. My two children attend the Kenosha Montessori School only 12 miles from Plant Zion. My wife and I share duties driving and picking up my children from this school. My children play, along with other children from the community,in the Kenosha Association Soccer League once a week for six months of the year at Anderson Park, within 9 miles of Plant Zion. Both my wife and I attend all of these soccer games.
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- 6. Plant Zion emptics discharge into Lake Michigan. Each year, my family and I enjoy taking a couple of family outings to Lake Michigan. In these outings, my family and I enjoy boating, participating in water sports, and swimming in Lake Michigan. My family and I also fish in Lake Michigan and consume the fish caught from Lake Michigan.
- 7. My children spend at least six hours a day outside. Frequently this time is spent on a bike trail which runs to and through the town of Zion, Illinois, the town where Plant Zion is located, including directly in front of the Plant. In supervising l
Exhibit / ,page 2 of.3_
My wife and I have lived at the above address since 1991.
- 4. The property value has an estimated fair market value of $172,504 and the contents of the house are insured at over $100,000. Ifit is revealed that the decommissioning of Plant Zion is not conforming to present rules, I believe that this would affect my ability to sell my property at the current market value.
- 5. My two children attend the Kenosha Montessori School only 12 miles from Plant Zion. My wife and I share duties driving and picking up my children from this school. My children play, along with other children from the community, in the Kenosha Association Soccer League once a week for six months of the year at Anderson Park, within 9 miles of Plant Zion. Both my wife and I attend all of these soccer games.
- 6. Plant Zion empties discharge into Lake Michigan. Each year, my family and I enjoy taking a couple of family outings to Lake Michigan. In these outings, my family and I enjoy boating, participating in water sports, and swimming in Lake Michigan. My family and I also fish in Lake Michigan and consume the fish caught from Lake Michigan.
- 7. My children spend at least six hours a day outside. Frequently this time is spent on a bike trail which runs to and through the town of Zion, Illinois, the town where Plant Zion is located, including directly in front of the Plant. In supervising 5 l
,p800 A Of L I
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my children, my wife and I frequently take walks or bike upon the bike trail.
Other recreational activities my family and I enjoy is utilizing the Illinois Beach State Park. I also occasionally play golf at the golf course in Zion, Illinois.
- 8. All of my heating and air conditioning business is conducted within 50 miles of Plant Zion. I have customers in several local towns including Kenosha, Wisconsin, which is within 10 miles of Plant Zion. My supplier, Midway Supply, is located within 1 mile of Plant Zion. For the survival of my company, I will be conducting a large amount of business with Midway Su, ply which will require me to drive to Midway Supply 3 to 4 times each week. I am also required to travel most of the roads within 50 miles of Zion in order to conduct my business. Many of the roads I use for my business are the same roads which Plant Zion uses to transport plant waste to Hamford, Washington. This plant waste is also transported through the streets of Zion. Illinois.
- 9. Three or four times a week my family and I drive within I to % miles of Plant Zion to downtown Zion, Illinois, to get gasoline, go shopping, visit the post office, or attend movies. My family and I periodically eat at restaurants or purchase food at the grocery store in Zion. Also while in Zion, my family and I occasionally visit the Power House, a public education center, which is less than 1 block away from Plant Zion.
- 10. The safety of the food and water my family and I consume are continuously l
[ Exhibit / ,pagel of 8_
threatened by Plant Zion. My family and I purchase produce grown on local farms I
located within 10 miles of Plant Zion. The water my family and I drink is from Lake Michigan Plant Zion empties into Lake Michigan. Even the air my family and I breath is threatened by the possible chance of a fire presenting the potential for release of particles into the atmosphere from the plant.
I1. My family and I are year-round residents of Kenosha, Wisconsin. All my family activities, business activities, and daily activities are completed within 50 miles of Plant Zion.
- 12. My experience at Plant Zion began in December 1989. My last day on which I worked at Plant Zion was April 15,1998 and the last day on which I conducted business on site at Plant Zion was May 29.1998. From December 1989 to August i 1995, I held the position of Mechanical Maintenance Supervisor, supervising up to 50 in-house mechanical and contract personnel. I was directly responsible for I
personnel safety in the Mechanical Maintenance Department, and I ensured that
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Nuclear Regulatory Commission and OSHA safety rules and regulations were followed by those under my supervision. As a supervisor I also corrected maintenance deficiencies. From August 1995 to April 1998,I was a Mechanical Maintenance Work Analyst. At this position,I identified and analyzed corrective l
and preventive maintenance on all equipment for many departments at Plant Zion, end I developed and wrote maintenance procedures in the field of Heating, Ventilation, and Air Conditioning (HVAC). I was also the Lead Work Analyst to Exhibit I ,page Y of 8
I maintain the Reactor Coolant Pumps.
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- 13. During my tenure at Plant Zion, I participated in numerous Commonwealth I Edison trainir.g programs to ensure that I was performing work in the safest manner possible. While employed by Commonwealth Edison, I received l-
! numerous cenifications and took part in the following training sessions: Nuclear .
1 General Employee Training (NGET), First Line Supervisor (FLS), and Human Performance Evaluation System (HPES). I also earned EPA certification in handling refrigerants.
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- 14. Before working at Plant Zion, I was employed by Cosmopolitan Reality in Chicago, Illinois from September 1985 to November 1989. I held the position of Assistant Engineer for Commercial and Residential Building Maintenance, and I directed corrective and preventive maintenance on all facility equipment and structures.
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. 15. From 1984 to 1985,I worked in the Research and Development Division at Y.K.K. Zipper in Northbrook, Illinois where I designed, modified, and set up clothing manufacturing industry equipment. In addition to these responsibilities, I trained personnel in the safe operation of high speed machinery. I also identified and modified any safety problems with the equipment and wrote safety guidelines for machinery operations. ,
Exhibit / ,page d o! E L
L L_______________._____.__ _ _ _ _ _ _ . _
- 16. From February 1976 to August 1984, I was enlisted in the United States Navy. I enlisted as an Aviation Structural Mechanic / Hydraulics and trained to become an Aviation Structural Mechanic / Hydraulics Specialist. Throughout my Naval career I became certified in the performance of critical maintenance processes on military- and civilian-type aircraft. I held qualifications within various fields of -
' aviation maintenance, and I was knowledgeable of the rules and regulations for the military specifications (mil spec) of aviation. From 1980 to 1982, I was the Safety Petty Officer for Squadron H-C9, NAS North Island. At the end of my Naval career, I held the position of Supervisor 2nd Class in the division of the Hydraulics Shop, Aviation Intermediate Maintenance Depot (A.I.M.D.) at NAS North Island.
- 17. From 1986 to 1988, I enrolled in numerous schools to gain qualifications in -
HVAC. For example,I enrolled in the National Association of Power Engineers School in Elk Grove Village, Illinois where I concentrated on Basic and Advanced Steam Plant Operations, Electricity and Refrigeration, and Water Treatment. In 1988, I attended the Coyne American Institute in Chicago, Illinois where I camed i
HVAC certification and became qualified to troubleshoot and repair HVAC l systems.
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- 18. Given my experience of working at Plant Zion for 9 years and my first-hand i knowledge of Plant Zion operations, I am a direct witness of health and safety concerns which will impact the local environment as well as the health and safety Exhibit / ,page _d._ of JE__
of myself, my wife and children, employees at Plant Zion, and the community.
- 19. . I have specific concems about the injuries that could result to my family and the local communities that derive from the proposed amendment by Commonwealth Edison. Based upon my background in nuclear energy and my experience in working at Plant Zion for 9 years, I believe that the proposed amendment rucsents many threats to the public health and safety, harm to the environment, and harm to the health of employees at Plant Zion. These injuries would result from the -
structural and functional changes in Plant Zion proposed by the amendment or if any mishap should occur while Plant Zion is functioning under the proposed changes of the amendment.
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- 20. - As my contentions will demonstrate,if Plant Zion functions under the proposed
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amendments. the potential injuries to me and my family, Plant Zion workers, the community, and the local environment include, but are not limited to: 1. LOCA {
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(Lost of Coolant Accident),2. radiological concerns,3. unsafe levels of radiation for the employees at the plant and the general public, 4. undetectable radiation contamination by employees, 5. contamination of the local community and the environment,6. increase risk of accident at Plant Zion, and 7. contamination of Lake Michigan. After reading the affidavit of Randy Robarge, other injuries appear emminent which include the increased potential of failing to detect radiation in adequate time and the increase risk of the plant functioning unsafely and outside NRC regulations.
Exhibit I ,page 7 of f
~n 21, My family and I, the community, plant workers, and the local envumunent will be directly affected by these potential injuries by the proposed amendment.
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Working directly and indirectly with current and former employees of Plant Zion, j i am provided with additional televant materials conceming the adverse impact l
that the proposed Wts will have on the health and safety of myself, my wife and my children, plant workers, and the community. Individuals with whom !
I I am working include, but are not limited to, Mr. Randy Robarge.
- 22. I have fonned the Committee for Safety at Plant Zion (CSPZ) with Mr. Robarge to jointly work to ensure that the operation and decommissioning ofPlant Zion does not threaten the health acd safety of the public. As co-director of CSPZ,I am capable ofobtaining access to relevant materials to ensure that the publie l
welfme is protected in light of the Plant Zion decommissioning. In addition, I am i
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in the unique position to intervene because of this newly formed committee and my status as co-dizoctor.
THE AFFIANT SAYETH FURTHER NOT.
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Edwin D. Dienetbal Date Enibit / ,page.__ 80f 1 CODg uyo)1 eAe3S +++ 30SSV HH GNY d!' t091Zt6t it IYd it *ZZ IllLL 96/0C/40
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1 EXHIBIT 2 ,
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