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public releases and worker exposures…” is an affirmation of the intent of the applicantto meet those regulations. Petitioners however are pointing to the deficiency in the
application to account for extended and cumulativ
e
possession of wastes that could
impact its ability to meet those dose limits. We are withholding our attack on the limits
themselves precisely because we are intervening in a license proceeding. Because the
possession of these materials is not accounted
for, the statement in the March 17 filingis pointing to the fact that the
ability to meet these dose limits while in possession of this
accumulated waste is also not accounted for. This is not a new base for the contention.
The text of contention 7 clearl
y states that:
PEF’s environmental report does not address the environmental, environmental
justice, health, safety, security or economic consequences that will result from
lack of permanent disposal for the radioactive wastes generated
…
Our reply is merely a restatement of the safety and health concern. Petitionersconcede that our concern for workers is reflexive. Since we do not at this time representany members who are workers
–
indeed the applicant does not currently have any
nuclear workers at t
he Levy County site
– we stand corrected in expressing that
concern inside the pages of pleading in this intervention.
The applicant attempts to categorize our concerns as solely directed to
occupational exposure. This is in error, as the passage in question clearly states “publicreleases” as well as occupational exposure as our concern. Indeed, our combined
members who live, work, play and consume water and foods from the area could beimpacted differently by the accidental (or other) release of a 30 year accumulation of so
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