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Category:Legal-Petition To Intervene/Request for Hearing
MONTHYEARML23331A9712023-11-27027 November 2023 Request for Hearing and Petition to Intervene Submitted by Miami Waterkeeper ML23331A9722023-11-27027 November 2023 Exhibit 1 - Rachel Silverstein 2023 Standing Declaration ML23331A9742023-11-27027 November 2023 Exhibit 11 - Waterkeeper Foe Center NRDC Scoping Comments Final ML23331A9752023-11-27027 November 2023 Exhibit 12 - Groundwater Tek Inc - Peer Review Study Final ML23331A9762023-11-27027 November 2023 Exhibit 13 - ARCADIS-DERM Letter Re FPL Year 4 Raasr Final ML23331A9772023-11-27027 November 2023 Exhibit 14 - 161617 MDC Resolution Re FPL CCS Final ML23331A9782023-11-27027 November 2023 Exhibit 15 - Knutson Et. Al ML23331A9832023-11-27027 November 2023 Exhibit 3 - William K. Nuttle Declaration ML23331A9882023-11-27027 November 2023 Exhibit 8 - FPL Turkey Point Y4 Raasr Final ML23331A9792023-11-27027 November 2023 Exhibit 16 - Fws Species Status Assessment Miami Cave Crayfish ML23331A9802023-11-27027 November 2023 Exhibit 17 - Chin_Cooling Canal System at the FPL Turkey Point Power Station ML23331A9862023-11-27027 November 2023 Exhibit 6 - Rebert E. Kopp Declaration ML23331A9812023-11-27027 November 2023 Exhibit 18 - Jeff Mitman Declaration ML23331A9852023-11-27027 November 2023 Exhibit 5 - Bill Powers Declaration ML23331A9842023-11-22022 November 2023 Exhibit 4 - James Fourqurean 2023 Declaration ML23331A9892023-11-15015 November 2023 Exhibit 9 - FPL Turkey Point Remedial Action Annual Status Report Year 5 ML23331A9822023-11-0303 November 2023 Exhibit 2, Request for Hearing and Petition to Intervene Submitted by Miami Waterkeeper ML23332A1912021-11-15015 November 2021 Exhibit 10 - FPL Year 3 Raasr Final ML18253A2802018-09-10010 September 2018 Reply in Support of Request for Hearing and Petition to Intervene Submitted by Friends of the Earth, Natural Resources Defense Council, and Miami Waterkeeper NRC-2018-0074, Petition to Intervene and Request for Hearing from Albert Gomez2018-08-0202 August 2018 Petition to Intervene and Request for Hearing from Albert Gomez ML18213A4342018-08-0101 August 2018 Attachment O: Expert Report by David Chin - the Cooling-Canal System at FPL Turkey Point Station ML18213A4252018-08-0101 August 2018 Attachment G: Declaration of Gina Trujillo ML18213A4182018-08-0101 August 2018 Request for Hearing and Petition to Intervene Submitted by Friends of the Earth, Natural Resources Defense Council, and Miami Waterkeeper ML18213A4272018-07-31031 July 2018 Attachment I: Declaration of Rachel Silverstein ML18213A4242018-07-31031 July 2018 Attachment F: Declaration of Jonathan Lester Fried ML18213A4232018-07-31031 July 2018 Attachment E: Declaration of Patricia Wynn ML18213A4192018-07-31031 July 2018 Attachment a: Declaration of Peter Stocker ML18213A4222018-07-30030 July 2018 Attachment D: Declaration of Vicki McGee-Absten ML18213A4282018-07-30030 July 2018 Attachment J: Declaration of Daniel Parobok ML18213A4362018-07-28028 July 2018 Attachment Q: Declaration of David A. Lochbaum ML18213A4332018-07-26026 July 2018 Attachment N: Declaration of Robert Kopp ML18213A4262018-07-24024 July 2018 Attachment H: Declaration of Philip Stoddard ML18213A4322018-07-18018 July 2018 Attachment M: Expert Reports from Lee Hefty ML18213A4352018-07-10010 July 2018 Attachment P: Expert Report by Wilbur Mayorga Re Site Assessment Report Dated March 17, 2017 ML18213A4212018-06-30030 June 2018 Attachment C: Declaration of Laura Bauman ML18213A4202018-06-29029 June 2018 Attachment B: Declaration of Anne H. Feuer ML18213A4292018-05-14014 May 2018 Attachment K: Expert Report of Bill Powers, P.E., Powers Engineering ML18213A4302017-08-23023 August 2017 Attachment L: Direct Testimony and Exhibits of Sorab Panday ML16130A7702016-05-0909 May 2016 City of Miami'S Reply to NRC Staff & Florida Power & Light Company'S Answers to Petition by City of Miami Fl, for Leave Intervene in Hearing on Florida Power & Light Company'S License Amendment Application for Turkey Point Units 3 & 4 Based ML0830806272008-11-0303 November 2008 Florida Power and Light Company'S Petition to Determine Need for Turkey Point Nuclear Units 6 and 7 Electrical Power Plant ML0823200662008-08-18018 August 2008 Request for Hearing and Leave to Intervene Submitted by Thomas Saporito ML18088B1551977-02-0202 February 1977 Notice of Withdrawal City of Bushnell ML18088B1591976-12-20020 December 1976 Notice of Withdrawal for the City of Leesburg ML18088B1601976-12-17017 December 1976 Notice of Withdrawal for the City of Williston ML18088B1611976-12-17017 December 1976 Turkey Units 3 and 4 - Notice of Withdrawal for the City of Chattahoochee ML18088A8731976-09-0101 September 1976 Response of Florida Power and Light Company in Opposition to: Joint Petition of Florida Cities for Leave to Intervene Out of Time' Petition to Intervene; and Request for Hearing ML23331A9871972-07-31031 July 1972 Exhibit 7 - Turkey Point 1972 EIS Final 2023-11-03
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Attachment J DECLARATION OF DANIEL PARQBOK I, Daniel Parobok, declare as follows:
- 1. I am a member of Miami Waterkeeper and I make this declaration in support of petitioner's request for a hearing and leave to intervene in Florida Power & Light Co.'s application for a second license renewal of its operating licenses for Turkey Point Nuclear Generating Units 3 and 4.
- 2. Miami Waterkeeper, Inc. ("Waterkeeper," also known as Biscayne Bay Waterkeeper, Inc.) is a Florida non-profit organization with a mission to defend, protect, and preserve the aquatic integrity of South Florida's watershed and wildlife through citizen involvement and community action. As its advocate, Waterkeeper seeks to eliminate or mitigate threats to South Florida's coastal waters. Through its work, Waterkeeper hopes to ensure a clean and vibrant South Florida watershed and coastal culture for generations to come. Waterkeeper uses education, community outreach, and legal advocacy to protect South Florida's marine ecosystems, marine life, and coral reefs. Waterkeeper is a member of the Waterkeeper Alliance, an international organization uniting more than 190 Waterkeeper affiliates across the globe.
Waterkeeper has approximately 100 members.
For four years, I lived and worked in Miami-Dade County as an Environmental Scientist. I have recently moved to Monroe County where I work as a biologist.
- 4. As a member of Miami Waterkeeper, I use and enjoy the waters of South Florida, including those of Biscayne National Park and the area near Turkey Point for recreational purposes. I regularly launch my boat out of Black Point Marina or Homestead Bayfront Park to go fishing along the mangrove shoreline and in the seagrass flats of Biscayne Bay, targeting species such as bonefish, permit, snapper, tarpon, sheepshead, snook, and redfish. I spend a 1
significant amount of time boating and fishing in Biscayne Bay, Card Sound, Barnes Sound, and Florida Bay.
- 5. I also enjoy viewing wildlife such as manatees, turtles, birds, dolphins, and crocodiles when I recreate in these areas. In a professional capacity, these species are significant to me as well. I am a biologist by trade and my job involves conducting benthic and land-based field surveys, evaluating environmental permit applications, conducting site inspections, and ensuring compliance with local, state, and federal laws. In my professional work, I regularly conduct listed species surveys for wildlife including turtles, cara caras, queen conch, woodstorks, scrub jays, red cockaded woodpeckers, everglades snail kites, sand skinks, and gopher tortoises.
Many of these species rely on a healthy interaction between terrestrial and marine environments, with a particular emphasis on wetland habitats. Without healthy wetlands, many listed species and other flora and fauna will suffer.
- 6. As a resident of the Florida Keys, I rely on the Biscayne Aquifer as a primary source of drinking water. I am concerned that the hypersaline plume from Turkey Point's Cooling Canal System is approaching the drinking water wellheads for the Florida Keys at more than a foot per day.
- 7. My personal and professional interests will be directly affected by the continued operation of Turkey Point's Cooling Canal System. Specifically, I am concerned that the hypersaline plume from the canals will contaminate my primary source of drinking water. I am also concerned that the canals are degrading natural habitat that I rely on for both recreational and professional purposes. Lastly, I live 28 miles from Turkey Point, and if an accident happened and a radiation release occurred, my personal safety may be at risk. I endorse Miami Waterkeeper seeking to intervene on my behalf in the Turkey Point relicensing proceeding.
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I declare under penalty of perjury that the foregoing is true and correct.
Executed on July 1a , 2018.
Daniel Parobok 143 Pueblo Street Tavernier, Florida 33070
[561-414-5978]
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