ML18213A536

Attachment 6: Larry Brand Expert Report

ML18213A536
Person / Time
Site:	Turkey Point
Issue date:	05/14/2018
From:	Brand L Friends of the Everglades, Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP, Southern Alliance for Clean Energy, Tropical Audubon Society
To:	NRC/SECY
SECY RAS
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References
License Renewal, RAS 54385, 50-250-SLR, 50-251-SLR
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SACE Hearing Request Attachment 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT COURT OF FLORIDA Miami Division Case No.: 1:16-cv-23017-DPG SOUTHERN ALLIANCE FOR CLEAN ENERGY TROPICAL AUDUBON SOCIETY INCORPORATED, and FRIENDS OF THE EVERGLADES, INC.,

Plaintiffs, v.

FLORIDA POWER & LIGHT COMPANY, Defendant.

EXPERT REPORT OF LARRY BRAND, PH.D.

I have been retained by the Plaintiffs in this matter to offer expert testimony. Pursuant to Fed.

R. Civ. P. 26(a)(2)(B), the following is my written report:

SUMMARY

OF OPINIONS

1. I am relying on the opinions of William Nuttle and Kirk Martin concerning the direct hydrological connection between the FPL Cooling Canal System (CCS) and Biscayne Bay.

Based on their reports, the Cooling Canal System is unlined and carved into porous limestone.

Groundwater clearly flows between the CCS and the surrounding waters, so it cannot be considered to be a closed system. When water level in the CCS is lower than Biscayne Bay, salt water flows into it, contributing to the salt problem that is made worse by evaporation.

When water level in the CCS is higher than Biscayne Bay, the nutrient rich CCS water flows into Biscayne Bay. This is confirmed by the observation of much higher concentrations of nutrients in Biscayne Bay near the CCS on both a tidal cycle and over longer periods of time when the CCS water levels are high. The nutrient concentrations are in exceedance of State and Local regulatory limits. According to Mr. Nuttle and Mr. Martin, tritium also confirms that CCS industrial waste water is being discharged into the surface water of Biscayne Bay.

2. Ammonia is the primary degradation product of nitrogen containing materials under anaerobic conditions, and nitrate is the primary degradation product under aerobic conditions. As a result, much of the total nitrogen in the CCS will be converted to ammonia in anaerobic groundwater. Therefore, ammonia is what will emerge from groundwater into downstream surface water. Therefore, the CCS is the source of high ammonia concentrations found in Biscayne Bay. The reason ammonia concentrations are low in the CCS is because they are shallow, thus receiving plenty of light. The dense algal blooms in the CCS have taken up most of the ammonia, converting the nitrogen into algal biomass. As algal biomass decays in the bottom water and anaerobic sediments, it is converted to ammonia. This explains why the ammonia levels are sometimes greater outside the CCS after traveling through groundwater than the levels observed inside the CCS. In addition to ammonia and other nutrients, the presence of tritium at levels above around 6.6 pCi/L indicates that at some point this water was in the CCS, according to experts in the field, including Mr. Martin and Mr. Nuttle.

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3. Increased nutrients lead to the process of eutrophication. In this process, there is a slow accumulation of nutrients in the ecosystem until it reaches a tipping point, at which time there is a rapid change in the ecosystem and its biota. In the case of South Florida, according to experts, such as James W. Fourqurean, Ph.D., these inputs will typically cause a change in type of sea grasses and density of seagrasses, to seagrass die off and then to algal blooms. This then changes the fauna that can use this system and has an impact on the species and diversity of species of this ecosystem.

4. The remedy that has been ordered by DEP and DERM may in fact keep some of the groundwater from reaching the surface water with the proposed backfilling but not all, as there are known locations where there are connections that are not being backfilled. My greatest concern with the proposed freshening of the CCS with reclaimed sewage from Miami-Dade County is that the addition of all the reclaimed sewage water, treated to an undetermined standard, will not only be a new source of nutrients, but will flush more of the plume into the Bay and the aquifer. The prescription of 34 PSU by the agencies within the CCS requires millions of gallons of water to keep the salinity at that level, and those inputs may actually make the problem worse, especially if that new water has any nutrients associated with it.

QUALIFICATIONS My resume is attached hereto as Exhibit B and contains my qualifications and a list of all publications that I have authored.

PRIOR TESTIMONY I have not testified in a deposition or trial in the past 4 years.

COMPENSATION I am being compensated as follows for my work in this matter: $100.00 per hour.

SIGNATURE:

Larry E. Brand 2

Introduction This report presents my opinions that nutrient pollution is being transported from the CCS at the Turkey Point Power Station into the surface waters of Biscayne Bay and the L31-E canal in exceedance of Florida Department of Environmental Protections (DEP) water quality standards for total nitrogen, total phosphorus, and chlorophyll-a, as well as the Miami-Dade County Department of Environmental Resources Managements (DERM) water quality standards for ammonia. Discharges of any pollutants into surface water are prohibited by the FPL NPDES permit.

Background

The Turkey Point Cooling Canal System The Cooling Canal System at the Turkey Point Power Station is a shallow canal system covering approximately 6100 acres designed to dissipate heat generated by the operation of nuclear generating units 3&4, primarily via evaporation of water. It is located directly adjacent to Biscayne Bay and a short distance from Card Sound. This system was completed over a two-year period and began operation in 1973.

The CCS does not operate as a closed system (See Expert Reports of Nuttle and Martin). The canals are open to the atmosphere, unlined and are dug into porous limestone substrate which allows its contents to seep into the underlying groundwater (Cunningham, 2009). Because this system is carved into porous limestone, it communicates freely with the surrounding environment, including surface water.

Condition I.A.1. of FPLs NPDES permit specifically states This permit does not authorize discharge to surface waters of the state. Discharge of nutrients from the CCS to the surface waters of Biscayne Bay and other surface waters constitutes a violation of this permit. In addition, nutrient discharges from the CCS constitute degradation of Outstanding Florida Waters in Biscayne Bay and have caused exceedances of state and local water quality standards for nutrients. See Florida Administrative Code 62-302.532, Outstanding Florida Waters Standards designated under Florida Administrative Code 62-302.700 , and the Miami Dade County Code of Ordinances, Section 24-42.

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Figure 1. G-III aquifer boundary (SFWMD, 2012)

Chemical and Nutrient Profile of the CCS Because this is an industrial waste facility, any waste generated at the FPL facility may be disposed of in the Cooling Canal system. We are not sure of every potential toxin or chemical now found in the CCS. Some of these chemicals are proprietary and the chemical makeup is unknown. These chemicals spike in concentration when blowdown occurs and are added to the CCS.

In the 10-21-09 letter from Christian Kiernan to Marc Harris, it is stated that the following chemicals are added to the CCS: hydrazine, carbohydrazide, monoethanolamine tolytriazole, nitrite, ammonium hydroxide, ethanolamine, dimethylamine, amerzine ammonia, nitric acid, tetraammonium ethylenediaminetetraacetate, diammonium ethylenediaminetetraacetate, diammonium citrate, and isothiazoline. All of these compounds contain nitrogen. Two forms of sodium phosphate are also added. In addition, various industrial solutions of unknown chemical composition are added. These include Continuum AEC3145, Corrshield MD4100, Foamtrol AF2290, Inhibitors AZ8101 and OP8413, Spectrus CT1300, Betz

Dearborn DCL30,

Hypersperse MDC120, Kleen MCT103 and MCT511, and ROClean L212, L403, P111, and L811. These chemicals are all permitted for discharge into the CCS by the NPDES permit Many of these compounds function as sources of nutrients that can generate algal blooms (NPDES Application, October 2009). The total amount added to the CCS over time is unknown to us at this time, so we cannot specify how significant this particular source might be compared to others.

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Locally generated sewage is also currently released into the CCS likely cleaned to the secondary treatment level, which does not set standards for nitrogen or phosphorus, allowing these pollutants to accumulate over time.

Since the plant was uprated in 2012, a sea-grass die off occurred within the CCS. FPL officials claim that those materials were macerated and left to decay inside the CCS. This seagrass die-off was also accompanied by the die-off of approximately 600 acres of mangroves adjacent to the CCS as well, as noted in a statement from Dade County DERM. All of this additional biomass is a source that has contributed to nutrient loading and the persistent algal blooms in the CCS.

Over time, because of evaporative losses, high concentrations of salt and various chemicals, including nutrients, have accumulated in the CCS (See Figure 2) and in the groundwater immediately underlying the CCS (See Figure 3).

Figure 2. CCS Maximum Quarterly Salinity, Sept. 1973-Sept. 2008 (FL0001562 NPDES Permits Monitoring Reports) 5

Figure 3. Simulated TDS concentrations and temperatures for base simulation case, after specified days since cooling canal system construction (Hughes, 2009)

Because of the high concentrations of salt and other constituents in the CCS, the water in the CCS sinks into the Biscayne aquifer below. This high salinity plume is documented to have spread over 4 miles both to the west of the CCS and to the east into Biscayne Bay (See Figures 4 and 5 below)

Figure 4. Diagram of Plume (Nuttle, 2017) 6

Figure 5. Diagram of Extent of Tritium Migration (Kirk Martin, Water Science Associates, 2017)

While the increasing concentration of salt is the result of evaporation, evaporation cannot completely explain the high concentrations of nutrients in the CCS. A time course for total nitrogen in the CCS from June 2010 to August 2015 shows an 8-fold increase in total nitrogen from 2011 to 2013 while showing no significant change in salinity during the same period (See Figure 6 and Figure 7). Because salinity did not increase significantly, the increase in nutrient concentrations cannot be the result of water evaporation alone. That suggests an internal source. A similar increase at the Biscayne Bay stations (See Figure 8) also suggests a connection between the CCS and Biscayne Bay. Elevated nutrient levels have remained present ever since.

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Figure 6. Time Course showing salinity levels in the CCS Figure 7. Time Course showing Nitrogen mg/L in the CCS 8

Figure 8. Time course showing Nitrogen mg\L in Biscayne Bay surface water High concentrations of nutrients are associated with this saline plume. From May 31, 2015 to April 18, 2016, average concentration of total nitrogen was 6.63 mg/L at station TPSWCCS-1B and 6.88 mg/L at station TPSWCCS-6T in the CCS. During the same time period, average concentration of total phosphorus was 0.049 mg/L at station TPSWCCS-1B and 0.052 mg/L at station TPSWCCS-6T in the CCS. These high concentrations of nutrients resulted in an algal bloom with average concentrations of 130 ug/L of chlorophyll.

Chlorophyll-a (an indicator of algal biomass) is also high in the CCS and will contribute to organic nutrients and decaying biomass. Average concentration of chlorophyll between May 31, 2015 and April 18, 2016 was 130 ug/L. It is estimated that this algal biomass contains 2.3 mg/L nitrogen and 0.32 mg/L phosphorus (This estimate is based upon the typical phytoplankton chemical composition ratio of C/chl of 100 by weight and the Redfield Ratio of C:N:P of 106:16:1 by mole and 41:7.23:1 by weight). The nutrients present in the CCS were able to produce microalgal biomass as high as 380 ug/L. When this decomposes, it would release approximately 6.7 mg/L total nitrogen and 0.935 mg/L total phosphorus.

The analysis of total dissolved nitrogen and phosphorus filters out this particulate algal biomass laden with nutrients, so the total amount of nitrogen and phosphorus in the CCS water is the sum of these two. This yields an average (TPSWCCS-1B and TPSWCCS-6T) concentration of (6.76 + 2.3=) 9.06 mg/L of nitrogen and (0.051 + 0.32=) 0.371 mg/L of phosphorus. The fact that 75% of the nitrogen is dissolved in the water and 86% of the phosphorus is in the algal biomass confirms that the CCS is phosphorus limited, just as Biscayne Bay is (Brand et al, 1991; Caccia and Boyer, 2007).

The actual total amount of nutrients in the CCS could be even higher for several reasons. There is a significant amount of algal biomass in the sediment surface, likely much higher than the water column algal biomass. This biomass is not included in the water column chlorophyll-nutrient calculations.

Furthermore, there could be a significant amount of organic detritus that does not contain chlorophyll, such as from (dead sea-grass, twigs and branches of dead trees, for example). These potential sources of nutrients have not been quantified. Finally, it is important to note that the amount of phosphorus loading into the Biscayne Bay/Card Sound system is likely obscured by the propensity of orthophosphate to bind to the calcium carbonate limestone substrate. When this calcium carbonate is dissolved or degraded however (which can occur as a result of several natural processes), the orthophosphate is released into the water table, loading the environment with nutrients (Fourqurean, 2015).

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The high total nitrogen content of the CCS includes organic nitrogen and various inorganic species.

Decaying biomass and organic nitrogen is eventually broken down to inorganic nitrogen (primarily ammonia and nitrate) by microbes. Ammonia is the primary degradation product of nitrogen containing materials under anaerobic conditions, and nitrate is the primary degradation product under aerobic conditions. As a result, much of the total nitrogen in the CCS will be converted to ammonia in anaerobic groundwater. Therefore, ammonia is what will emerge from groundwater into downstream surface water.

The Cooling Canal System at Turkey Point has exhibited frequent recurring algal blooms since 2013, providing ample substrate for degradation into nutrient pollutants (see figures 9&10).

Figure 9. Satellite Images showing development and persistence of algal bloom in CCS 10

Figure 10. Aerial Photos taken of the Turkey Point Cooling Canal System 5/30/17 To the extent that the CCS relies upon inflow of watershed water to replace the water that evaporates for heat dissipation, nutrients in that water could be a source of nutrients in the CCS, which are concentrated above background by evaporation. Two sites upstream of the watershed of the CCS were examined. Station MW04 on Mowry Canal over the time period of 2000 to 2014 had an average concentration of 0.441 mg/L of total nitrogen and 0.00573 mg/L of total phosphorus (data from SFWMD DBHYDRO data files). These concentrations are approximately 6.5% (TN) and 11.2% (TP) respectively of the concentrations observed in the CCS. Station FC03 on the Florida City Canal a short distance northwest of the CCS over the same time period had an average of 0.337 mg/L total nitrogen and 0.0038 mg/L total phosphorus. These are 5% (TN) and 7.5% (TP) of the concentrations observed in the CCS. Due to the relatively low concentrations nutrients in the upstream canals cannot directly explain the high concentration of nutrients in the CCS, however, evaporation over years of operation combined with other inputs from blowdown chemicals, sewage, biomass death and other permitted activities could.

The CCS-Biscayne Bay Connection A comparison of water level in the CCS, the water height difference between the CCS and Biscayne Bay, and total nitrogen concentrations at station TPBBSW-6 in Biscayne Bay during a time course from June 2015 to April 2016 (Figure11) shows a good correlation with an initial delay of a couple of months. The same is seen with ammonia (Figure12), nitrate-nitrite (Figure 13), total phosphorus (Figure 14), orthophosphate (Figure15), and chlorophyll (Figure16). The chlorophyll values represent the biomass of algae which indicate an algal bloom generated in Biscayne Bay by the high nutrients coming from the CCS. The same temporal pattern is observed at station TPBBSW-7 in Biscayne Bay with total nitrogen (Figure17), ammonia (Figure 18), nitrate-nitrite (Figure 19), total phosphorus (Figure 20), orthophosphate (Figure 21), and chlorophyll (Figure 22). The main difference at this location is that there is essentially no time lag between when the water level in the CCS rises and when 11

the high nutrient concentrations show up in Biscayne Bay. This indicates a higher flux rate of groundwater from the CCS into Biscayne Bay at this location.

Figure 11. Time Course TPBBSW-6, Total Nitrogen Figure 12. Time Course TPBBSW-6, Ammonia Figure 13. Time Course TPBBSW-6,Nitrate-Nitrite 12

Figure 14. Time Course TPBBSW-6,Total Phosphorus Figure 15. Time Course TPBBSW-6, OrthoPhosphate Figure 16. Time Course TPBBSW-6, Chlorophyll 13

Figure 17. Time Course TPBBSW-7, Total Nitrogen Figure 18. Time Course TPBBSW-7, Ammonia Figure 19. Time Course TPBBSW-7, Nitrate-Nitrite 14

Figure 20. Time Course TPBBSW-7, Total Phosphorus Figure 21. Time Course TPBBSW-7, OrthoPhosphate Figure 22. Time Course TPBBSW-7, Chlorophyll 15

The temporal correlation between nutrients at stations TPBBSW-6 and TPBBSDW-7, and the water level in the CCS indicates that the CCS, not natural sources in Biscayne Bay, is the primary source of those nutrients in Biscayne Bay. On page 16 of the Site Assessment Report (2017) the authors suggest that nitrogen fixation could be a possible source of N. This is unlikely, as South Biscayne Bay is phosphorus limited (Brand et al., 1991; Caccia and Boyer, 2007).

Effects of tidal and water level fluctuations The flux rate of groundwater from the CCS into Biscayne Bay depends upon the relative water levels in the CCS and Biscayne Bay. High water level in the CCS and low water level in Biscayne Bay will generate the highest flux rate of water from the CCS into Biscayne Bay (Nuttle 2017). Water level in the CCS is determined primarily by local rainfall and FPL management operations while water level in Biscayne Bay is determined by the tidal cycle along with seasonal and long-term changes in sea level.

An examination of the data at station TTBBSW-8B (Table 1) shows a dramatic difference between average observed concentrations of pollutants at high and low tide.

High Tide Low Tide Salinity 30.44 ppt 32.34 ppt Total Nitrogen 0.87 mg/L 6.92 mg/L Total Phosphorus 0.046 mg/L 0.823 mg/L Oxygen 1.31 mg/L 0.07 mg/L Sulfide 0.004 mg/L 35.9 mg/L Table 1: Tidal Flux at TPBBSW-8B (average concentrations)

At low tide, groundwater will flow from land into Biscayne Bay. At high tide, the flow will decline or reverse. In most situations along a coastline, one would see lower salinity at low tide and high salinity at high tide because of the landward freshwater-seaward saltwater gradient. We observe the opposite at station 8, indicating a landward source of high salinity water.

Associated with this flux of high salinity CCS water during low tide is a large increase in total nitrogen (8X) and total phosphorus (18X) (Table 1). The decline in oxygen and increase in sulfide indicates the influx of anaerobic groundwater during low tide. Most places along the coastline, we do not see a significant tidal flux because the flow rate is too slow. The groundwater flow at TPBBSW-8B is apparently high enough to show a consistent tidal flux. The concentrations of total nitrogen and phosphorus exceed Florida DEP standards, especially at low tide when the flux is from the CCS to Biscayne Bay. Natural decomposition of organic matter from Biscayne Bay cannot explain the tidal change in nutrient concentrations at station TPBBSW-8B.

There is only one plausible source for these pollutants - the highly saline and nutrient enriched CCS.

There is clear exchange between the CCS and the Surface Waters of Biscayne Bay.

The largest pool of nitrogen is dinitrogen gas (N2), primarily in the atmosphere. N2 is an inert gas that cannot be used by eukaryotic algae and most prokaryotic cyanobacteria. Some cyanobacteria however, can use N2 by breaking its triple bond with the enzyme nitrogenase, a process call nitrogen fixation.

Ultimately this nitrogen ends up in all biomass throughout the food web. As food is eaten and digested, nitrogen is released, usually as ammonia, but also as urea or uric acid. Urea and uric acid are eventually broken down to ammonia. When organisms die or release feces, the organic nitrogen is 16

eventually released as ammonia. Virtually all algae can use ammonia as a nutrient. Under aerobic conditions, chemoautotrophic bacteria can use ammonia as an energy source and oxidize it to nitrate, which can also be used as a nutrient by algae. Under anaerobic conditions (common in sediments and groundwater), anaerobic respiring bacteria can use nitrate as an oxidant and convert it to ammonia.

Ammonia and nitrate are the two major sources of nitrogen that generate Harmful Algal Blooms. One observes high concentrations ammonia in areas of Biscayne Bay where high concentrations of tritium are found. Tritium is a useful tracer for water from the CCS of the nuclear power plant at FPLs Turkey Point power plant because that is the only significant source of tritium in the region. The correlation between tritium and ammonia suggests that the CCS is the source of that ammonia.

On page 16 of the SAR, it is stated that the CCS cannot be the source of high ammonia concentrations in Biscayne Bay because concentrations are low in the CCS. DERM did not agree with these conclusions, and stated as such in a letter responding to the SAR report sent on July 7th, 2017, stating that Based on the data and information provided, DERM does not concur at this time with the conclusions and recommendations presented in the report (See attachment C) .

The reason ammonia concentrations are low in the CCS is because they are shallow, thus receiving plenty of light. The dense algal blooms have taken up most of the ammonia, converting the nitrogen into algal biomass. As algal biomass decays in the bottom water and anaerobic sediments, it is converted to ammonia. This explains why the ammonia levels can be greater outside the CCS after traveling through groundwater than observed inside the CCS. The presence of tritium at levels above 2 TU indicates that at some point this water was in the CCS, confirming that ammonia originated from inside the CCS.

During times of high CCS water levels and low Biscayne Bay water levels, the nutrient rich groundwater from the CCS is flowing into Biscayne Bay, which accounts for the high nitrogen and phosphorus observed at stations TPBBSW-6, TPBBSW-7, and TPBBSW-8. The concentrations of total N and total P that could be produced by the decay of just the peak microalgal biomass in the CCS along with the dissolved nitrogen and phosphorus (13.46 mg N/L and 0.981 mg P/L) is similar to the concentrations of total N and P at station TPBBSW-8B (6.92 mg N/L and 0.833 mg P/L) at low tide when salinity is higher as a result of the flux from the CCS. These data indicate that water in the bottom of the CCS collecting the decaying biomass is leaking into the groundwater and eventually into the deep water of Biscayne Bay and then into the surface water.

Submarine Springs Scientists and observers have long noted the presence of submarine springs connecting the Biscayne aquifer to the surface waters of Biscayne Bay. Groundwater from inshore can travel laterally eastward to reconvene with surface waters in Biscayne Bay. There are several known submarine springs at a site 1.2 kilometers east of the eastern edge of the CCS (25o 21.684N, 80o 19.182W) (See figures 23 & 24).

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Figure 23. Submarine Springs in Biscayne Bay ExhibitingHydrological Connection to the CCS Station Longitude (N) Latitude (W)

B-1 25 21 41.2200 80 19 10.4160 BAY-1 25 21 266760 80 19 02.6760 BAY-2 25 21 22.7520 80 19 11.5680 S-1 25 21 40.8240 80 19 10.2360 S-2 25 21 40.7880 80 19 10.1280 S-2 DUP 25 21 40.7880 80 19 10.1280 S-3 25 21 40.7880 80 19 10.1640 S-4 25 21 40.7880 80 19 10.2360 Figure 24. Location of Submarine Springs Sampled by DERM, FDEP and SACE Team These locations were first discovered and sampled by Miami Dade County DERM (See Fig 13 and Table 2-B) and then also sampled by Florida DEP,(See Table 2-C) our team also sampled the site to verify the groundwater to surface water flow and the connection offshore to the CCS (See table 2-D).

Each of these sampling events revealed levels of nutrients, tritium, salinity and temperature elevated above background, confirming that these springs are connected to the aquifer beneath the cooling canal system and provides a conduit from the groundwater plume to the surface waters of biscayne bay.

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Samples were collected by SCUBA in the spring where flow and shimmering could be observed, indicating a mixing of waters with different salinities. Surface samples was also taken at the same location. These data are shown in Table 2D.

The water coming out of the spring is saltier and warmer than the surface water. This is the opposite of what one typically sees in near shore springs where groundwater is fresher and cooler than the overlying surface water because the source is land based groundwater. This more typical salty surface/fresh bottom pattern was observed 25 kilometers north of Turkey Point at 25o 36 23.2N, 80o 18 25.8W (Gonzales, 2007). At that location, salinity was typically around 23 ppt during high tide when spring flow was low and around 10 ppt during low tide when spring flow was high. The higher salinities coming out of the spring 1.2 kilometers east of the CCS indicates a land based salty groundwater source. The source of this groundwater is clearly the CCS, as confirmed by tritium measurements as high as 25.8 piCu/L vs. zero piCu/L at the surface see table 2A. We observe much higher concentrations of total nitrogen, total phosphorus, ammonia, and orthophosphate in the salty water coming out of the spring than in the overlying surface waters (Fig. 2). Nitrate/nitrite concentrations are lower because they are converted to ammonia by nitrate reduction under the anaerobic conditions of the groundwater.

Divers collecting data reported a smell of hydrogen sulfide which confirmed that this water was indeed anaerobic. These observations confirm that nutrients from the CCS can make it at least 1.2 kilometers east into Biscayne Bay surface waters, and because of the geology in this area this may be happening in many locations. We found 6 openings in the limestone at this location and 4 that were flowing.

Total nitrogen coming out of the spring is 1.7 times higher than regulatory standards and total phosphorus is 3.9 times higher than regulatory standards.

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Collection NH3 NOX TKN TPO4 OPO4 Salinity Collection Point Tritium (pCi/L)

Date & Time (mg/L) (mg/L) mg/L) (mg/L) (mg/L) (PSU)

CS-CV-FB 09/20/16 09:00 U U U U U CS-CV-EB 09/20/16 09:02 U U U U U CS CV-T 09/20/16 09:05 6.15 0.09 U 0.46 0.003 0.002 30.07 CS CV-B 09/20/16 09:10 5.03 0.09 U 0.47 U 0.003 31.49 CS CV-H 09/20/16 09:15 10.73 0.39 U 0.82 0.044 0.047 36.54 CS REF-T 09/20/16 09:45 5.86 0.08 U 0.4 0.004 U 30.79 CS REF-B 09/20/16 09:50 4.9 0.09 U 0.39 0.003 0.003 31.58 CS NSH-B 09/20/16 09:35 6.19 0.07 U 0.36 0.003 0.004 30.74 TPBBSWCSC-M-T 09/20/16 10:05 0.07 U 0.47 0.004 0.004 30.47 TPBBSWCSC-M-B 09/20/16 10:10 13.4 0.1 U 0.44 0.005 0.005 31.35 S20GC-M-B 09/20/16 10:30 8.18 0.1 U 0.43 0.005 0.004 31.42 S20GC-M-T 09/20/16 10:25 10.47 0.09 U 0.53 0.005 0.004 26.92 S20GC-M-T-FCEB 09/20/16 10:40 U U U U U TPSWC-7B 09/20/16 11:20 782.95 7.43 U 8.82 0.486 0.293 44.22 TPSWC-7M 09/20/16 11:15 148.86 0.72 U 1.48 0.034 0.032 32.5 TPSWC-7T 09/20/16 11:10 20.94 0.08 0.01 1.05 0.005 0.003 11.6 S20GC-SD-B 09/20/16 10:50 20.01 0.07 0.01 1.06 0.007 0.003 23.22 TPSWC-7B-FD 09/20/16 11:35 7.88 U 8.07 0.452 0.303 44.26 TC-N-B 09/21/16 09:25 7.06 0.13 U 0.44 0.004 0.005 28.74 TC-S-B 09/21/16 10:00 9.15 0.14 U 0.58 0.003 0.004 28.16 TP NSH-B 09/21/16 10:15 8.06 0.08 U 0.49 0.004 0.005 24.65 TC-S-B-FCEB 09/21/16 09:30 U U U U U BRGB-ENT-B 09/21/16 09:35 6.48 0.12 U 0.46 0.01 U 32.52 BRGB-ENT-M 09/21/16 09:30 6.03 0.11 U 0.46 0.005 U 32.1 BRGB-ENT-T 09/21/16 09:20 7.38 0.1 U 0.51 0.006 0.003 30.68 TTLPT-SH-B 09/21/16 10:30 192.16 1.08 U 1.64 0.054 0.021 36.64 TTLPT-SH-T 09/21/16 10:20 13.98 0.08 0.01 0.47 0.007 0.004 32.36 Table 2A: DERM Submarine Spring Sampling Data Monitoring Sampling Date Tritium Ammoni TKN NOXN TPO4 OPO4 Latitude Longitude Site & Time (pCi/L) a (mg/L) (mg/L) (mg/L) (mg/L) (mg/L)

S-4 25 21 40.788080 19 10.2360 9/28/16 11:44 14.7 0.026 0.45 0.029 0.006 0.005 B-1 25 21 41.220080 19 10.4160 9/28/16 12:12 12.8 0.027 0.37 0.028 0.007 0.005 BAY-1 25 21 26676080 19 02.6760 9/28/16 12:45 1 0.034 0.53 0.033 0.004 0.004 BAY-2 25 21 22.752080 19 11.5680 9/28/16 13:05 11.7 0.035 0.38 0.032 0.004 0.004 S-1 25 21 40.824080 19 10.2360 9/28/16 10:14 9.9 0.026 0.41 0.029 0.005 0.006 S-2 25 21 40.788080 19 10.1280 9/28/16 10:34 7.7 0.028 0.43 0.032 0.005 0.004 S-2 DUP 25 21 40.788080 19 10.1280 9/28/16 10:44 -0.6 0.025 0.51 0.045 0.010 0.004 S-3 25 21 40.788080 19 10.1640 9/28/16 11:04 18 0.067 0.65 0.033 0.10 0.004 Table 2B: FDEP Submarine Spring Sampling Data 20

Station Coordinates date depth tritium (pC/L) total N total P ammonia phosphate nitrate 1573-7 25o 21.678 N 800 19.169 W 11/18/2017 surface 0.57 0.0056 0.052 0.0024 0.126 1573-9 25o 21.678 N 800 19.169 W 11/18/2017 surface -22.554 1573-1 25o 21.678 N 800 19.169 W 11/18/2017 bottom 0.52 0.0135 0.166 0.0037 0.0236 1573-3 25o 21.678 N 800 19.169 W 11/18/2017 bottom 0.69 0.0234 0.176 0.0042 0.009 1573-5 25o 21.678 N 800 19.169 W 11/18/2017 bottom 16.11 1573-2 25o 21.678 N 800 19.169 W 11/18/2017 bottom 0.63 0.018 0.137 0.0042 0.0034 1573-4 25o 21.678 N 800 19.169 W 11/18/2017 bottom 3.222 1573-6 25o 21.678 N 800 19.169 W 11/18/2017 bottom 0.62 0.0141 0.143 0.0033 0.0038 1582-1 25o 21.678 N 800 19.169 W 12/4/2017 surface 0.42 0.004 0.028 0.0019 0.0445 1582-4 25o 21.678 N 800 19.169 W 12/4/2017 surface 0.42 0.0037 0.026 0.0018 0.0421 1582-8 25o 21.678 N 800 19.169 W 12/4/2017 surface 0.44 0.0049 0.03 0.0022 0.0453 1582-2 25o 21.678 N 800 19.169 W 12/4/2017 bottom 0.75 0.0379 0.158 0.0029 0.0078 1582-3 25o 21.678 N 800 19.169 W 12/4/2017 bottom 6.444 0.79 0.0283 0.141 0.0054 0.0042 1582-5 25o 21.678 N 800 19.169 W 12/4/2017 bottom 0.79 0.0323 0.134 0.0026 0.0066 1582-6 25o 21.678 N 800 19.169 W 12/4/2017 bottom 12.888 0.8 0.0492 0.133 0.0013 0.0072 1582-7 25o 21.678 N 800 19.169 W 12/4/2017 bottom 0.81 0.0301 0.122 0.0055 0.0041 1582-9 25o 21.678 N 800 19.169 W 12/4/2017 bottom 25.776 0.84 0.0253 0.142 0.0035 0.0026 Table 2C: Submarine Spring Sampling Data Collected by SACE team Figure 25-A. Cave Sites Total Nitrogen Figure 25-B. Cave Sites Total Phosphorus 21

Figure 25-C. Cave Sites Ammonia Figure 25-D. Cave Sites Salinity L-31 E contamination There is clear evidence that water from the CCS leaks into the L31-E canal to the west (see Table 3).

At station 1575-1,2 at the bottom of the L31-S canal, salinity is 13.5 ppt., whereas the surface water is 2.1 ppt. The bottom water is 28.5oC, warmer than the surface water, 25.6oC. As deeper water is usually colder, this suggests warm water from the CCS. Tritium values of 61.2 pC/L confirm the input of CCS water. Total N is twice as high in the bottom water as the surface and total P is 13.8 times as high. L31-S is a water of the US and as such is subject to the protections of the Clean Water Act.

The L-31 is subject to Florida Class III surface water standards (designated for recreation, propagation and maintenance of a healthy, well-balanced population of fish and wildlife), the narrative nutrient standard of which states under section 47(a) that the discharge of nutrients shall continue to be limited as needed to prevent violation of other standards presented in this chapter. Man induced nutrient enrichment (total nitrogen or total phosphorus) shall be considered degradation in relation to provisions of Rules62-302.300,62-302.700 and 62-4.242, FAC and under section 47(b)that In no case shall nutrient concentrations of a body of water be altered so as to cause an imbalance in natural populations of aquatic flora or fauna. As has been stated previously, nutrient pollution leads to severe deleterious outcomes for aquatic ecosystems and causes an imbalance in the food web.

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Station Coordinates date tritium (pC/L) total N (mg/L) total P (mg/L ammonia (mg/L) phosphate (mg/L) 1575-4 25o 26.470 N 800 21.027 W 11/19/2017 1.05 0.0122 0.125 0.0043 o 0 1575-5 25 26.096 N 80 21.156 W 11/19/2017 1.18 0.0138 0.123 0.0054 1575-12 25o 26.910 N 800 21.210 W 11/19/2017 1.23 0.0185 0.129 0.0069 o

1575-7 25 26.975 N 800 21.203 W 11/19/2017 128.88 1575-1 25o 26.975 N 800 21.203 W 11/19/2017 2.07 0.1922 7.627 0.0979 o

1575-2 25 26.975 N 800 21.203 W 11/19/2017 61.218 o 0 1575-3 25 26.470 N 80 21.027 W 11/19/2017 2.07 0.1411 6.183 0.0921 o 0 1575-6 25 26.470 N 80 21.027 W 11/19/2017 45.108 o

1575-8 25 26.096 N 800 21.156 W 11/19/2017 1.52 0.0669 1.06 0.0193 25o 26.096 N 800 21.156 W 1575-9 11/19/2017 80.55 o

1575-10 25 26.910 N 800 21.210 W 11/19/2017 1.34 0.0189 0.126 0.0052 o 0 25 26.910 N 80 21.210 W 1575-11 11/19/2017 125.658 25o 26.910 N 800 21.210 W 1581-1 12/3/2017 1.31 0.0206 0.189 0.0061 o

1581-7 25 25.866 N 800 21.246 W 12/3/2017 1.22 0.0191 0.139 0.0062 1581-10 25o 25.196 N 800 21.248 W 12/3/2017 1.22 0.0248 0.121 0.0084 o 0 1581-4 25 26.085 N 80 21.156 W 12/3/2017 132.102 1581-2 25o 26.085 N 800 21.156 W 12/3/2017 1.51 0.0186 0.405 0.0061 1581-5 25o 26.085 N 800 21.156 W 12/3/2017 112.77 1581-6 25o 25.866 N 800 21.246 W 12/3/2017 1.04 0.02 0.289 0.0066 1581-8 25o 25.866 N 800 21.246 W 12/3/2017 106.326 1581-9 25o 26.910 N 800 21.210 W 12/3/2017 1.17 0.0279 0.204 0.0081 o 0 1581-12 25 26.910 N 80 21.210 W 12/3/2017 99.882 1581-11 25o 25.196 N 800 21.248 W 12/3/2017 1.2 0.0258 0.252 0.0083 1581-3 25o 25.196 N 800 21.248 W 12/3/2017 112.77 1583-5 25o 26.635 N 800 20.988 W 12/5/2017 1.5 0.0269 0.24 0.0089 1583-6 25o 26.470 N 800 21.027 W 12/5/2017 1.09 0.0181 0.235 0.0048 1583-1 25o 26.635 N 800 20.988 W 12/5/2017 3.96 0.0757 2.468 0.0184 1581-3 25o 26.635 N 800 20.988 W 12/5/2017 57.996 1583-2 25o 26.470 N 800 21.027 W 12/5/2017 5.36 0.0754 4.565 0.0308 Table 3. L31-E Sampling Data collected by the SACE team An average of data at stations TPSWC 1B, 2B, and 3B from May 31, 2015 to April 18, 2016 gives a total nitrogen concentration of 1.26 mg/L, a total phosphorus concentration of 0.011 mg/L, and tritium of around 55 pCu/L. Table 4 compares average concentrations of total nitrogen, total phosphorus and tritium in the CCS, Interceptor Ditch,L-31E and the watershed canal stations M04 and FC03. The concentration gradient and tritium data show that the CCS is a source of nutrients and tritium to the Interceptor Ditch and L31-E. Nutrients are much higher in the CCS than in the nearby Interceptor Ditch and L-31E canals (Table 5). Lowest are the Mowry and Florida City canals in the upstream watershed. Processes in the CCS are generating higher nutrients than any surrounding source water.

Total nitrogen (mg/L) Total phosphorus (mg/L) Tritium (pCu/L)

CCS 6.76 0.051 3,583 ID (TPSWCID-1,2,3) 1.59 0.0153 263 L31-E (TPSWC-1,2,3) 1.26 0.011 58.5 MW04 0.44 0.00573 FC03 0.337 0.0038 Table 4. Comparison of nutrient concentrations and tritium levels in the CCS, 23

Canals to the west, & canals in the upstream watershed; CCS, ID, and L-31E N and P data from DERM data May 31, 2015 to April 18, 2016; tritium data from DERM data March 2015; MW04 and FC03 data from SFWMD DBHYDRO data base, 2000 to 2014.

Nutrient Levels and Nutrient Criteria in Biscayne Bay The nutrient pollution emanating from the CCS into the adjacent waters of the US is of concern because excess nutrients cause eutrophication, leading to algal blooms, the development of increasingly anaerobic sediments, alteration of the benthic community, sea-grass die-off, and alteration of the entire food web and ecosystem (Carpenter et al., 1998;Schindler and Vallentyne, 2004, 2008; Selman, 2007). The development of eutrophication is often slow and not easily detectable. It is only over time that nutrients accumulate in the ecosystem, but they finally reach a critical point where there is a sudden change in the ecosystem.

In order to protect Floridas waters from experiencing these deleterious conditions, Florida DEP has set nutrient criteria for allowable nutrient concentrations in different water bodies under Florida Administrative Code 62-302.532. Because high nutrient concentrations can lead to algal blooms, chlorophyll is used as an indicator of eutrophication and Florida DEP has set standards for chlorophyll as well. These standards for south central mid-bay Biscayne Bay are 0.007 mg/L as Annual Geometric Mean (AGM) for total phosphorus, 0.35 mg/L as AGM for total nitrogen, and 0.2 ug/L for chlorophyll as AGM for south central mid-bay. The Miami Dade County Department of Environmental Resource Managements (DERM) standards for ammonia found in Miami Dade Code of Ordinances Section 24-42(4) are 0.5 mg/L, a concentration that can be directly toxic to marine organisms such as fish (Miami Dade County Code of Ordinances, Section 24-42. Prohibitions Against Water Pollution)

Biscayne Bay and Card Sound are identified for additional protection as Outstanding Florida Waters under FAC 62-302.700. These waters are not to be degraded beyond the ambient water quality baseline determined March 1st, 1979. These levels were set in an effort undertaken by multiple stakeholders at a Project Delivery Team Meeting where the Anti Degradation standards were determined for a CERP project. Below is the table indicating the low nutrient standards required to protect Biscayne Bay from degradation (See attachment D).

Parameter Antidegradation Targets Total Ammonia 0.02-0.05 mg/L (depends on method of collection and analysis)

Nitrite/Nitrate-N 0.01 mg/L TKN 0.22 mg/L Total Nitrogen 0.27 mg/L Ortho-P 0.002 mg/L Total P 0.005 mg/L Table 5. Biscayne Bay Outstanding Florida Water Anti-degradation targets (Keiser & Lopez, 2003)

Violation of Nutrient Standards At stations TPBBSW-6 (Barge basin) and TPBBSW-7 (Turtle Point canal) between May 31, 2015 and April 18, 2016, most of the total nitrogen concentrations are above the nutrient criteria for Biscayne Bay (south central mid-bay) of 0.35 mg/L, often above 2 and as high as 5.5 mg/L (DERM data files).

Total nitrogen concentrations exceeded Florida DEP standards 89% of the time at station TPBBSW-6 and 98% of the time at station TPBBSW-7. Average concentrations were 1.087 mg/L (3.31times the standard) at station TPBBSW-6 and 2.005 mg/L (5.73 times the standard) at station TPBBSW-7.

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Geometric mean concentrations were 0.789 mg/L (2.25 times the standard) at station TPBBSW-6 and 1.62 mg/L (4.63 times the standard) at station TPBBSW-7.

Most of the total phosphorus concentrations are also above the nutrient criteria for Biscayne Bay (south central mid-bay) of 0.007 mg/L, often above 0.05 and as high as 0.25 mg/L. Total phosphorus concentrations exceeded Florida DEP standards 43% of the time at station TPBBSW-6 and 72% of the time at station TPBBSW-7. Average concentrations were 0.031 mg/L (4.43 times the standard) at station TPBBSW-6 and 0.078 mg/L (11.1 times the standard at station TPBBSW-7. Geometric mean concentrations were 0.010 mg/L (1.43 times the standard) at station TPBBSW-6 and 0.035 mg/L (5 times the standard at station TPBBSW-7.

100% of the resulting chlorophyll concentrations are above the nutrient criteria for Biscayne Bay (south central mid-bay) of 0.2 ug/L, often above 1 and as high as 65 ug/L. Average concentrations were 9.9 ug/L (49.5 times the standard) at station TPBBSW-6 and 10.13 ug/L (50.7 times the standard) at station TPBBSW-7. Geometric mean concentrations were 3.29 ug/L (16.5 times the standard) at station TPBBSW-6 and 6.26 ug/L (31.3 times the standard at station TPBBSW-7.

Ammonia concentrations exceeded DERM standards 26% of the time at station TPBBSW-6 and 70%

of the time at station TPBBSW-7. Average concentrations were 0.517 mg/L (1.03 times the standard) at station TPBBSW-6 and 1.538 mg/L (3.08 times the DERM standard) at station TPBBSW-7.

Geometric mean concentrations were 0.244 mg/L (0.49 times the standard) at station TPBBSW-6 and 0.856 mg/L (1.71 times the DERM standard) at station TPBBSW-7 Evaluation of Agency Solutions DEP Consent Order The DEP Consent Order entered on June 20th 2016 does not adequately address the problem of nutrient contamination in the surface waters of Biscayne Bay or the L-31-E Canal. Paragraph 16 of the DEP consent order indicated that nutrient monitoring results submitted to the department by FPL on May 16th, 2016, did not demonstrate exceedances of surface water standards and so no significant action was ordered to ameliorate nutrient pollution. We see from the data presented herein that these exceedances have in fact occurred, as supported by the report of Kirk Martin, P.G., and Biscayne National Park also agreed with these findings (See attachment B).

The only action ordered by the department to address this issue is the restoration of the Turtle Point and Barge Basin Canals, the establishment of a plan to reduce nutrient levels within the CCS itself, and the filling of any material breaches identified in the CCS peripheral levee (DEP Consent Order, paragraphs 19 & 21). Filling in the canals closest to the CCS would reduce the obvious flow of CCS water into those locations. Because of the porous nature of the limestone substrate however, CCS water would continue to flow into Biscayne Bay over a wide area outside those canals, as we observed with the cave openings we sampled.

We see from the preliminary data that has been collected by the agencies and by our team that there are many more locations that have exceedances and there is no guarantee that even the backfilling will abate the connection in those areas. Considering the amount of water being proposed to be added to the CCS on a daily basis will raise the driving head of the CCS causing flushing and forced seepage on a more consistent basis. In other words, requiring a standard of 34 PSU in the CCS will actually make the nutrient pollution in Biscayne Bay and in the G II aquifer worse. Rather than extracting the 25

pollution and disposing of it in the boulder zone, this is a dilution and flushing scheme.

Miami Dade Consent Agreement On October 2nd, 2015 DERM issued a notice of violation indicating that FPL operations had violated Miami Dade County Water quality standards and criteria. The August 2016 addendum to the October 2015 Consent Agreement declared that DERM review had revealed levels of ammonia as N in exceedance of water quality standards set forth in section 24-42(4) and clean-up target levels in section 24-44(2)(f)(v)1. This constitutes pollution under section 24-5 of the Miami Dade County Code. These exceedances were recorded at stations tidally connected to Biscayne Bay, including but not limited to TPBBSW-7, TPBBSW-8. The addendum called for the submittal of a Site Assessment Plan and Corrective Action plan.

The DERM Consent Agreement which FPL entered in October 2015 called for general cleaning of the Cooling Canal System and the implementation of a recovery well system designed to retract the groundwater plume to the west but contained few to no specific solutions for ending the ongoing nutrient pollution emanating from the Cooling Canal System in Biscayne Bay. Again, this agreement requires the CCS to be maintained at 34 PSU, which will require millions of gallons of water everyday to make up from evaporative losses, these additions will flush the pollution out of the CCS into the surrounding environment including the aquifer and Biscayne Bay.

An addendum was added after more data had been collected showing violations of water quality standards in Biscayne Bay violating Chapter 24 of the Miami Dade County Code. FPL is required to enter a corrective action plan to clean up its nutrient pollution found in the surface waters of Biscayne Bay. However, FPL refuses to claiming this cannot be their pollution as the levels of ammonia are lower in the CCS than found in Biscayne Bay. The have cited work by Jerald Ault to support their claim in their report back to Miami Dade. When we requested this information in a records request all we were able to obtain was a power point presentation by Jerald Ault that argues that other locations in Biscayne Bay also have nutrient concentrations that exceed regulatory limits. The presentation cites many sources of the data but does not specify which data come from which source or provide a map of the location from which the data come. A perusal of the graphs shown (no actual data were provided) indicate that most of the data show nutrient concentrations below regulatory concentrations. The nutrient concentrations above regulatory limits are mostly ephemeral spikes, not long term sustained violations of regulatory limits. Regulatory limits are based upon long term geometric mean concentrations, not ephemeral peaks. The data at stations TPBBSWC 6 and 7 show long term excess nutrient in violation of regulatory limits.

In addition, we know that ammonia is a biproduct of the microbial pathways underground once the surface water from the CCS becomes dense and sinks along with the nutrients and that the pathways main byproduct is ammonia.

Suggested Additional Work The existence of a connection between the waters of the CCS and those of Biscayne Bay is troubling for a number of reasons. In addition to nutrients, tritium and salinity there are many other isotopes and heavy metals likely entering the bay and the aquifer. For example, a large volume of copper was added to attempt to kill the massive algal bloom which occurred from 2012-2014 (See figure 10).

There is reason to suspect that large amounts of copper and other toxins will be found in the sediments where they build up over time, but we have not been able to sample sediments in the CCS or on FPL property.

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Evidence that the operations of Turkey Point may contribute to increased toxicity in nearby sediments has been building for some time. In 1998 researchers found that many samples collected in an area off the mouths of North and Mowry canals and off Turkey Point were relatively toxic in amphipod and microtox trials, and to a lesser extent, in the urchin tests (Long, 1998). Additional research into whether the connection between the CCS and Biscayne Bay has led to the accumulation of toxic substances such as copper and heavy metals in Biscayne Bay sediments is warranted.

In addition, a close examination of other locations where the ground water and surface water interact should be conducted and additional samples taken at those known locations. I am sure that many other such locations exist.

Finally, analysis should be done by the regulatory agencies on the newly proposed additions of freshwater as part of the Joint Partnership Agreement that recently passed in Dade County where FPL proposes to add an additional 45 MGD into the CCS. From the data we do have we see whenever large volumes of water are added to the CCS, we see large nutrient spikes and flows into Biscayne Bay and the Aquifer. We suspect impacts of adding this much water daily to the CCS may be devastating to the surrounding environment. We are unsure of the quality of water that will result from the reclaimed effort, it will likely add to the overall nutrient loading because water going into an industrial waste facility such as the CCS have no standards that are required.

Conclusions The hydrologic connection The Cooling Canal System is unlined and carved into porous limestone. The capacity of the limestone topography of this region to transport water is well understood ( Wanless, 1976). Groundwater clearly flows between the CCS and the surrounding waters, so it cannot be considered to be a closed system.

When water level in the CCS is lower than Biscayne Bay, salt water flows into it, contributing to the salt problem that is made worse by evaporation. When water level in the CCS is higher than Biscayne Bay, the nutrient rich CCS water flows into Biscayne Bay. This is confirmed by the observation of much higher concentrations of nutrients in Biscayne Bay near the CCS on both a tidal cycle and over longer periods of time when the CCS water levels are high. The nutrient concentrations are way over DEP and DERM regulatory limits. Tritium data also confirm that CCS water is getting into the surface water of Biscayne Bay. Analysis of data from offshore submarine springs confirm that CCS water is getting into surface Biscayne Bay water at least 1.2 kilometers to the east of the CCS. Data on the L-31E canal to the west of the CCS indicate that CCS water is getting into that canal as well.

Nutrients Ammonia is the primary degradation product under anaerobic conditions and nitrate is the primary degradation product under aerobic conditions. As a result, much of the total nitrogen in the CCS will be converted to ammonia in anaerobic groundwater. Therefore, ammonia is what will emerge from groundwater into downstream surface water. Therefore the CCS is the source of high ammonia concentrations found in Biscayne Bay. The reason ammonia concentrations are low in the CCS is because they are shallow, thus receiving plenty of light. The dense algal blooms have taken up most of the ammonia, converting the nitrogen into algal biomass. As algal biomass decays in the bottom water and anaerobic sediments, it is converted to ammonia. This explains why the ammonia levels can be greater outside the CCS after traveling through groundwater than observed inside the CCS. The presence of tritium at levels above around 6 pCu/L indicates that at some point this water was in the CCS.

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Increased nutrients lead to the process of eutrophication. In this process, there is a slow accumulation of nutrients in the ecosystem until it reaches a tipping point, at which time there is a rapid change in the ecosystem and its biota. In the case of South Florida, these inputs will typically cause a change in type of sea grasses and density of seagrasses, to seagrass die off and then to algal blooms. (Fourqurean, 2015)

The Proposed Remedy What has been ordered by DEP and DERM may in fact keep some of the groundwater from reaching the surface with the proposed backfilling but not all. But my greatest concern is that with the addition of all the reclaimed sewage water, recycled to an undetermined standard will not only be a new source of nutrients but will flush more of the plume into the bay and the aquifer. The prescription of 34 PSU by the agencies within the CCS, requires water to keep the salinity at that level, those inputs may actually make the problem worse, especially if that new water has any nutrients associated with it.

References Atlantic Oceanographic and Meteorological Laboratory. 2004. DETECTION, MAPPING, AND CHARACTERIZATION OF GROUNDWATERD ISCHARGES TO BISCAYNE BAY. SFWMD Contract Caccia, V.G. and J. N. Boyer. 2007. A nutrient loading budget for Biscayne Bay, Florida. Mar. Poll. Bull. 54:

994-1008

.

Carpenter, S.R., N.F. Caraco, and V.H. Smith. 1998. Nonpoint pollution of surface waters with phosphorus and nitrogen. Ecol. Appl. 8: 559-568.

Cunningham & Florea, 2009, The Biscayne Aquifer of SouthEastern Florida, Western Kentucky University, Geography & Geology Dames and Moore, 1978, Salinity evaluation Turkey Point cooling pond system: for Florida Power & Light Co.

Florida Power & Light, 3/17/2017 Turkey Point Site Assessment Report: Ammonia in Surface Waters Site Assessment Report, Fourqurean, J. October, 2015. Testimony-Effect of Nutrient Addition on Marine Ecosystems of the Florida Keys Gonzalez, C.J. 2007. Detecton, mapping and analysis of freshwater springs in western Biscayne Bay, Florida.

268 pp. Internship Report, RSMAS.

Hughes, J. Langevin, C. Brakefield-Goswami, L., 2009, Effect of hypersaline cooling canals on aquifer salinization, USGS Keiser, J., Lopez, J., 2003, Treatment Objectives-Wastewater Reuse Pilot Project -Miami-Dade, US Army Corps of Engineers, South Florida Water Management District Long, ER, 1998, Magnitude and Extent of Chemical Contamination and Toxicity in Sediments of Biscayne Bay and Vicinity, NOAA Nuttle, 2017, Review of the Water Budget for the FPL Turkey Point Cooling Canal System: Regional Impacts and Discharge to Groundwater, Southern Alliance for Clean Energy.

Ostlund, H.G. and H.G. Dorsey. 1976. Turkey Point Tritium. Progress Report to Energy and Research and Development Administration, Contract E-(40-1)-3944. UM-RSMAS-#76005, April 20, 1976.

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Schindler, D. and J.R. Vallentyne. 2004. Overfertilization of the Worlds Freshwaters and Estuaries University of Alberta Press.

Schindler, D. and J.R. Vallentyne. 2008. The Algal Bowl: Overfertilization of the Worlds Freshwaters and Estuaries. University of Alberta Press.

Selman, M. 2007. Eutrophication: An Overview of Status, Trends, Policies, and Strategies. World Resources Institute.

Wanless, H. 1976 Geologic setting and recent sediments of the Biscayne Bay region, Florida. In Biscayne Bay: Past, Present and Future. P. 1-32. Edited by A. Thorhaug and A. Volker. University of Miami, Sea Grant Special Report, No. 5, 315p.

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Appendix Section 1: Water Gradient Graphs A.1 C.1 C.2 C.3 30

Section 2: Figures Figure A1. Location of Sampling wells 31

Section 3: Attached Documents Attachment A: Letter from the National Parks Service 32

33 Attachment B: Curriculum Vitae Larry E. Brand, Ph.D 6830 SW 65 St.

South Miami, FL 33143 LBrand@rsmas.miami.edu Profile Larry Brand is a phytoplankton ecologist, working in the field for over 40 years. He conducts laboratory studies on the effects of various environmental factors on cultures of individual species of phytoplankton and field studies on phytoplankton distributions and their ecological causes. This includes Harmful Algal Blooms.

Education University of Texas at Austin - B.A., 1974 Woods Hole Oceanographic Institution / Massachusetts Institute of Technology Joint Program. - Ph.D., 1980 Career Summary Woods Hole Oceanographic Institution: Postdoctoral Investigator; 1980-1981 University of Miami, Rosenstiel School of Marine and Atmospheric Science:

Assistant Professor; 1981-1986 Associate Professor; 1986-1993 Professor; 1993 to present Scientific Publications Nelson, D.M. and L.E. Brand. 1979. Cell-division periodicity in 13 species of marine phytoplankton on a light:dark cycle. J. Phycol . 15:67-75.

Waterbury, J.B., S.W. Watson, R.R.L. Guillard, and L.E. Brand. 1979.

Widespread occurrence of a unicellular, marine planktonic cyanobacterium. Nature 277:293-294.

Blackwelder, P.L., L.E. Brand, and R.R.L. Guillard. 1979. Coccolith morphology and paleoclimatology II. Cell ultrastructure and formation of coccoliths in Cyclococcolithina leptopora (Murray and Blackman) Wilcoxon and Gephyrocapsa oceanica Kamptner, pp.

417-420, In: Scanning Electron Microscopy, Vol. 2, AMF O'Hare, Illinois.

Brand, L.E. 1980. Genetic variability and differentiation in niche components of marine phytoplankton species. Ph.D. Dissertation, Massachusetts Institute of Technology/Woods Hole Oceanographic Institution, 227 pp.

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Dudley, W.C., J.C. Duplessy, P.L. Blackwelder, L.E. Brand, and R.R.L.

Guillard. 1980. Coccoliths in Pleistocene-Holocene nannofossil assemblages. Nature 285:222-223.

Brand, L.E., R.R.L. Guillard, and L.S. Murphy. 1981. A method for the rapid and precise determination of acclimated phytoplankton reproduction rates. J. Plankton Res. 3:193-201.

Brand, L.E., and R.R.L. Guillard. 1981. The effects of continuous light and light intensity on the reproduction rate of twenty-two species of marine phytoplankton. J. Exp. Mar. Biol. Ecol. 50:119-132.

Chisholm, S.W., and L.E. Brand. 1981. Persistence of cell division phasing in marine phytoplankton in continuous light after entrainment to light:dark cycles. J. Exp.Mar. Biol. Ecol. 51:107-118.

Brand, L.E., L.S. Murphy, R.R.L. Guillard, and H.-t. Lee. 1981. Genetic variability and differentiation in the temperature niche component of the diatom Thalassiosira pseudonana. Mar. Biol. 62:103-110.

Brand, L.E. 1981. Genetic variability in reproduction rates in marine phytoplankton populations. Evolution 35:1117-1127.

Brand, L.E. 1982. Genetic variability and spatial patterns of genetic differentiation in the reproduction rates of the marine coccolithophores Emiliania huxleyi and Gephyrocapsa oceanica. Limnol.

Oceanogr. 27:236-245.

Tangen, K., L.E. Brand, P.L. Blackwelder, and R.R.L. Guillard. 1982.

Thoracosphaera heimii (Lohmann) Kamptner is a Dinophyte:

Observations on its morphology and life cycle. Mar.

Micropaleo. 7:193-212.

Brand, L.E. 1982. Persistent diel rhythms in the chlorophyll fluorescence of marine phytoplankton species. Mar. Biol. 69:253-262.

Brand, L.E., W.G. Sunda, and R.R.L. Guillard. 1983. Limitation of marine phytoplankton reproductive rates by zinc, manganese and iron.

Limnol. Oceanogr. 28:1182-1198.

Brand, L.E. 1984. The salinity tolerance of forty-six marine phytoplankton isolates. Est. Coast. Shelf. Sci. 18:543-556.

Brand, L.E. 1985. Low genetic variability in reproduction rates in populations of Prorocentrum micans Ehrenb. (Dinophyceae) over Georges Bank. J. Exp. Mar. Biol. Ecol. 88:55-65.

Guillard, R.R.L., and L.E. Brand. 1985. Culturing. pp. 538-539. In:

Toxic Dinoflagellates, Ed. by D.M. Anderson, A.W. White and D.G. Baden, Elsevier.

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Baden, D.G., T.J. Mende, and L.E. Brand. 1985. Cross-reactivity in immunoassays directed against toxins isolated from Ptychodiscus brevis.

pp. 363-368, In: Toxic Dinoflagellates, Ed. by D.M. Anderson, A.W. White, and D.G. Baden, Elsevier.

Dudley, W.C., P. Blackwelder, L. Brand, and J.C. Duplessy. 1986.

Stable isotopic composition of coccoliths. Mar. Micropaleo. 10:1-8.

Brand, L.E., W.G. Sunda, and R.R.L. Guillard. 1986. Reduction of marine phytoplankton reproduction rates by copper and cadmium. J. Exp.

Mar. Biol. Ecol. 96:225-250.

Brand, L.E. 1986. Nutrition and culture of autotrophic ultraplankton and picoplankton. Can. Bull. Fish. Aquat. Sci. 214:205-233.

Brand, L.E. 1988. Assessment of Plankton Resources and their Environmental Interactions in Biscayne Bay, Florida. Final Report to Dade County Department of Environmental Resources Management. 204 pp.

Moffett, J.W., R.G. Zika and L.E. Brand. 1990. Distribution and potential sources and sinks of copper chelators in the Sargasso Sea. Deep Sea Res.

37:27-35.

Brand, L.E. 1990. The isolation and culture of microalgae for biotechnological applications. pp.81-115, In: Isolation of Biotechnological Organisms from Nature, Ed. by D.P. Labeda, McGraw-Hill.

Brand, L.E. 1991. Review of genetic variation in marine phytoplankton species and the ecological implications. Biol. Oceanogr. 6:397-409.

Brand, L.E., M.D. Gottfried, C.C. Baylon and N.S. Romer. 1991. The spatial and temporal distribution of phytoplankton in Biscayne Bay, Florida. Bull. Mar. Sci. 49:599-613.

Brand, L.E. 1991. Minimum iron requirements of marine phytoplankton and the implications for the biogeochemical control of new production.

Limnol. Oceanogr. 36: 1756-1771.

Yih, W.H. and L.E. Brand. 1993. Iron-limited biomass yields of marine phytoplankton clones. J. Ocean. Soc. Korea 28:79-85.

Brand, L.E. 1994. Physiological ecology of marine coccolithophores. pp.

39-49. In: Coccolithophores, Ed. by A. Winter and W. Siesser, Cambridge University Press.

Milne, P.J., D.D. Riemer, R.G. Zika and L.E. Brand. 1995. Measurement 36

of vertical distribution of isoprene in surface seawater, its chemical fate, and its emission from several phytoplankton monocultures. Mar. Chem.

48: 237-244.

Moffett, J.W. and L.E. Brand. 1996. Production of strong, extracellular Cu chelators by marine cyanobacteria in response to Cu stress.

Limnol. Oceanogr. 41:388-395.

Moffett, J.W., L.E. Brand, P.L. Croot and K.A. Barbeau. 1997. Cu speciation and cyanobacterial distribution in harbors subject to anthropogenic Cu inputs. Limnol. Oceanogr. 42: 789-799.

Santana-Casiano, J.M., M. Gonzalez-Davila, L.M. Laglera, J. Perez-Pena, L.E. Brand and F.J. Millero. 1997. The influence of zinc, aluminum and cadmium on the uptake kinetics of iron by algae. Mar. Chem. 59: 95-111.

Boyer, G.L. and L.E. Brand. 1998. Trace elements and harmful algal blooms. pp. 489-508, In: Physiological Ecology of Harmful Algal Blooms, Ed.

by D.M. Anderson, A.D. Cembella and G.M. Hallegraeff, Springer-Verlag, Heidelburg.

Croot, P.L., J.W. Moffett and L.E. Brand. 2000. Production of extracellular Cu complexing ligands by eucaryotic phytoplankton in response to Cu stress. Limnol. Oceanogr. 45: 619-627.

Top, Z., L.E. Brand, R.D. Corbett, W. Burnett and J. Chanton. 2001.

Helium as a tracer of groundwater input into Florida Bay. J. Coastal Res. 17:

859-868.

Brand, L.E. 2002. The transport of terrestrial nutrients to South Florida coastal waters. pp. 353-406, In: The Everglades, Florida Bay, and Coral Reefs of the Florida Keys, Ed. by J.W. Porter and K.G. Porter, CRC Press, Boca Raton, Florida.

Brand, L.E. 2002. Phytoplankton (Planktonic Algae) in the Marine Environment. Pp. 2502-2518, In: The Encyclopedia of Environmental Microbiology, Vol. 5, Ed. by G. Bitton, John Wiley and Sons, New York .

Heikes, B.G., W. Chang, M.E.Q. Pilson, E. Swift, H.B. Singh, A. Guenther, D.J. Jacob. B. D. Field, R. Fall, D. Riemer, and L. Brand. 2002. Atmospheric methanol budget and ocean implication. Global. Biogeochem. Cycles 16(4),

1133, doi: 10.1029/2002GB001895: 80-1 to 13.

Quinn, P., H.R. Thierstein, L. Brand and A. Winter. 2003. Experimental evidence for the species character of Calcidiscus leptoporus morphotypes. J.

Paleont. 77: 825-830.

Clark, C.D., W.T. Hiscock, F.J. Millero, G. Hitchcock, L. Brand, W.L. Miller, L. Ziolkowski, R.F. Chen and R.G. Zika. 2004. CDOM distribution and CO2 production on the Southwest Florida Shelf. Mar. Chem. 89: 145-167.

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Olascoaga, M.J., Rypina, I.I., Brown, M.G., Beron-Vera, F.J., Kocak, H.,

Brand, L.E. Halliwell, G.R., and Shay, L.K. 2006. Persistent transport barrier on the west Florida shelf. Geophys. Res. Let. 33, L22603,doi:10.1029/2006GL027800/

Benetti, D., L. Brand, J. Collins, R. Orhun, A. Benetti, B. OHanlon, A.

Danylchuk, D. Alston, J. Rivera, and A. Cabarcas. 2006. Can offshore aquaculture of carnivorous fish be sustainable? World Aquaculture 37: 44-47.

Brand, L.E. and A. Compton. 2007. Long-term increase in Karenia brevis abundance along the southwest Florida coast. Harmful Algae 7: 232-252.

Sinigalliano, C.D., M.L. Gidley, T. Shibata, D. Whitman, T.H. Dixon, E.

Laws, Hou, D. Bachoon, L. Brand, L. Amaral-Zettler, R.J. Gast, G.F. Steward, O.D. Nigro, R. Fujioka, W.Q. Betancourt, G.

Vithangae, J. Mathews, L.E. Fleming, and H.M. Solo-Gabriele.

2007. Impacts of Hurricane Katrina on microbial landscape of the New Orleans area. Proc. Nat. Acad. Sci. 104: 9029-9034.

Mendoza, W.G., R.N. Mead, L.E. Brand, and D. Shea. 2008. Analysis and detection of brevetoxin analogs in recent marine sediments by HPLC.

Chemosphere 73: 1373-1377.

Erdner, D., et al., L.E. Brand one of 15 coauthors. 2008. Centers for oceans and human health: A unified approach to the challenge of harmful algal blooms. Env. Health 7: S2.

Glibert, P.M., and L.E. Brand, one of 53 other co-authors. 2008. Ocean urea fertilization for carbon credits poses high ecological risks.

Mar. Poll. Bull. 56: 1049-1056.

Olascoaga, M. J., F. J. Beron-Vera, L. E. Brand, and H. Koçak . 2008.

Tracing the early development of harmful algal blooms on the West Florida Shelf with the aid of Lagrangian coherent structures, J.

Geophys. Res., 113, C12014, doi:10.1029/2007JC004533.

Scorzetti, G., L.E. Brand, G.L. Hitchcock, K.S. Rein, C. Sinigalliano , and J.W. Fell . 2009. Multiple simultaneous detection of Harmful Algal Blooms (HABs) through a high throughput bead array technology, with potential use in phytoplankton community analysis. Harmful Algae 8: 196-211.

Sinigalliano, C.D.,J. Winshell, M.A. Guerrero, G. Scorzetti, J.W. Fell, R.W.

Eaton, L. Brand, and K.S. Rein. 2009. Viable cell sorting of dinoflagellates by multi-parametric flow cytometry. Phycologia 48: 249-257.

Brand, L.E. 2009. Human exposure to cyanobacteria and BMAA. Amy.

Lat. Scler. 10: 85-95.

Bollmann, J., C. Klaas, and L. Brand. 2010. Morphological and 38

physiological characteristics of Gephyrocapsa oceanica var. typica Kamptner 1943 in culture experiments: Evidence for genotypic variability. Protist 161: 78-90.

Brand, L.E., J. Pablo, A. Compton, N. Hammerschlag, and D.C. Mash.

2010. Cyanobacterial blooms and the occurrence of the neurotoxin, beta-N-methylamino-L-alanine (BMAA), in South Florida aquatic food webs. Harmful Algae 9: 620-635.

Bienfang, P., S. V. DeFelice, E. A. Laws, L. Brand, R. R. Bidigare, S.

Christensen, H. Trapido-Rosenthal, T. Hemscheidt, D. J. McGillicuddy, D. M.

Anderson, L. C. Backer, H. Solo-Gabriele and A. B. Boehm. 2011. Prominent human health impacts from several marine microbes: History, ecology, and public health implications. Int. J. Microbio. Doi: 10.1155/2011/152815.

Avellaneda, P., J. Englehardt, J. Olascoaga, E. Babcock, L. Brand, D.

Lirman, W. Rogge, H. Solo-Gabriele, and G. Tchobanoglous. 2011. Relative risk assessment of cruise ships biosolids disposal alternatives. Mar. Poll. Bull.

62: 2157-2169.

Brand, L.E., L. Campbell, and E. Bresnan. 2012. Karenia: The biology and ecology of a toxic genus. Harmful Algae 14: 156-178.

Brand, L.E. 2012. Toxic Harmful Algal Blooms: Natural and anthropogenic causes. Pp. 19-52, In: New Trends in Marine and Freshwater Toxins: Food Safety Concerns, Ed. by A.G. Cabado and J.M. Vieites, Nova Science Publishers, New York.

Maze, G., J.J. Olascoaga, and L. Brand. 2015. Historical analysis of environmental conditions during Florida Red Tide. Harmful Algae 50: 1-7.

Brand, L.E. 2017. Karenia. In: Harmful Algal Blooms: A compendium desk reference, Ed. By S.E. Shumway, Wiley-Blackwell (in press).

Brand, L.E. 2017. Takayama. In: Harmful Algal Blooms: A compendium desk reference, Ed. By S.E. Shumway, Wiley-Blackwell (in press).

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Attachment C: DERM Site Assessment Report Letter 40