ML23331A972

Exhibit 1 - Rachel Silverstein 2023 Standing Declaration

ML23331A972
Person / Time
Site:	Turkey Point
Issue date:	11/27/2023
From:	Miami Waterkeeper
To:	NRC/SECY/RAS
SECY RAS
References
50-250-SLR-2, 50-251-SLR-2, RAS 56848
Download: ML23331A972 (0)

Text

EXHIBIT 1 DECLARATION OF RACHEL SILVERSTEIN, PH.D.

I, Rachel Silverstein, declare as follows:

1. I am the Executive Director and a member of Miami Waterkeeper. I make this declaration in support of Petitioner's request for a hearing and leave to intervene in Florida Power and Light Company's application for a second license renewal of its operating licenses for Turkey Point Nuclear Generating Units 3 and 4.

2. Biscayne Bay Waterkeeper, Inc. d/b/a Miami Waterkeeper (Miami Waterkeeper) is a Florida non-profit organization with a mission to ensure swimmable, drinkable, fishable water for all. Miami Waterkeeper achieves its mission through scientific research, public education, advocacy for sound public policies, and participation in legal and administrative forums. Miami Waterkeeper has many members that reside near to, use, and enjoy the Biscayne Bay watershed and its tributaries. Through its work, Miami Waterkeeper hopes to ensure a clean and vibrant South Florida watershed and coastal community for generations to come. Miami Waterkeeper is a member of the Waterkeeper Alliance, an international organization uniting more than 300 Waterkeeper organizations and affiliates across the globe. Miami Waterkeeper has over 500 members.

3. In addition to serving as Executive Director and a member of Miami Waterkeeper, I also serve as the "Miami Waterkeeper." A Waterkeeper is a full-time, paid employee of an organizational member of the Waterkeeper Alliance who serves as a non-governmental public advocate for an identified watershed. I hold a B.A. in Evolution, Ecology and Environmental Biology from Columbia University from which I graduated cum laude, and I received a Ph.D. in the Department of Marine Biology and Fisheries from the University of Miami's Rosenstiel School for Marine and Atmospheric Science. My job as Miami Waterkeeper involves directing 1

teams to monitor and test water quality, investigate pollution problems, educate the public, enforce state and federal environmental laws, and work with civic leaders to support our mission.

4. Many members of Miami Waterkeeper recreate, study, enjoy, and work in the waters in South Florida, including those of the Biscayne Bay Aquatic Preserve, Florida Keys National Marine Sanctuary, Biscayne National Park, and Everglades National Park near Turkey Point. Miami Waterkeeper's members observe and interact with marine organisms such as fish, lobsters and other invertebrates (such as corals), sea turtles, and marine mammals through wildlife observation, research, photography, scuba diving, and recreational fishing. Our members also visit the terrestrial portions of the two national parks and other freshwater wetlands areas near Turkey Point and observe, interact with, and value terrestrial organisms that depend on freshwater wetlands such as crocodiles, panthers, snakes, and a wide variety of birds, or plan on doing so in the future. These activities require healthy freshwater wetlands, which in turn requires continued protection of the groundwater underneath those wetlands.

5. Members of Miami Waterkeeper also rely on the Biscayne Aquifer as a source of potable water. Consequently, Plaintiffs' members are concerned and directly affected by the consequences of Turkey Point's use of a cooling canal system to dispose of waste heat, including salinization of the Biscayne Aquifer, discharges of pollution into surrounding ground and surface waters including Biscayne Bay, the taking of American Crocodiles and harm to their Designated Critical Habitat, as well as harm to the habitat of the subterranean Miami cave crayfish, which U.S. Fish and Wildlife recently proposed to list as a threatened species under the Endangered Species Act. It is reasonably foreseeable that these impacts will intensify as rising seas, changing precipitation patterns, and increased flooding, storms, and extreme heat interact with the continued operation of the cooling canal system.

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6. I am a resident of South Florida, and I also personally share these concerns. I enjoy boating in southern Biscayne Bay, as well as scuba diving, snorkeling, and camping in the area. My family and I frequently visit Everglades National Park and Florida Keys National Marine Sanctuary as well. I plan to continue visiting our spectacular national parks and marine sanctuaries and enjoying viewing the unique wildlife that depends on clean water and sustained freshwater flow for their habitats and life cycles.

7. As a resident of Miami-Dade County, I also rely on the Biscayne Aquifer as a primary source of drinking water. I am concerned that the hypersaline plume emanating from Turkey Point's Cooling Canal System is contaminating the Biscayne Aquifer and threatens the areas drinking water supply.

8. Lastly, I live approximately 30 miles from Turkey Point in Miami-Dade County.

My office is located in Coral Gables, zip code 33134. If an accident happened and a radiation release occurred, my personal safety may be at risk.

9. For these reasons, the relicensing of Turkey Point Units 3 and 4 is of great interest to me, to Miami Waterkeeper, and to our membership. I have authorized Miami Waterkeeper to represent my interests in the Turkey Point subsequent license renewal proceeding, in order to ensure that the most important environmental impacts, and any mitigation alternatives, are fully and adequately presented to the Nuclear Regulatory Commission so that a responsible and informed decision can be reached on whether to relicense Turkey Point Units 3 and 4.

I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed on November 20, 2023 in Miami, Florida.

Executed in Accord with 10 C.F.R. § 2.3-4(d) by 3

Rachel Silverstein, Ph.D.

Executive Director and Waterkeeper Miami Waterkeeper PO Box 141596 Coral Gables, FL 33114-1596 (305) 905-0856 4