ML18213A537
| ML18213A537 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 05/14/2018 |
| From: | Swakon E Friends of the Everglades, Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP, Southern Alliance for Clean Energy, Tropical Audubon Society |
| To: | NRC/SECY |
| SECY RAS | |
| Shared Package | |
| ML18213A528 | List: |
| References | |
| License Renewal, RAS 54385, 50-250-SLR, 50-251-SLR | |
| Download: ML18213A537 (14) | |
Text
Edward A. Swakon, P.E. May 14, 2018 UNITED STATES DISTRICT COURT SACE Hearing Request SOUTHERN DISTRICT COURT OF FLORIDA Attachment 7 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 EDWARD A. SWAKON, P.E. (Florida)
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:
OPINIONS
- 1. The CCS is a significant contributing factor to the water quality violations in the G-II aquifer to the west of the CSS.
From 1998 thru 2017, EAS Engineering, Inc. (EAS) provided environmental consulting services to several clients in South Miami Dade County including, Atlantic Civil Inc. (ACI) and the City of Homestead. From 2004 thru 2017, EAS collected groundwater samples from numerous wells, the majority of which were located South of SW 344 Street, in the Model Lands Basin. In 2010, Earthfx, in cooperation with EAS Engineering, Inc. developed and calibrated a three-dimensional density-dependent groundwater flow/solute transport model for the area surrounding the Atlantic Civil Incorporated (ACI) property as part a cumulative impact assessment conducted by EAS Engineering for ACI.
Simulations show that since its inception, the FPL Cooling Canal System (CCS) has significantly affected the dynamics of freshwater/saltwater in the vicinity of the ACI property. As salinities in the CCS have increased over time, the simulations showed a corresponding westward migration of the freshwater/saltwater interface from the CCS towards the ACI property.
Edward A. Swakon, P.E. May 14, 2018 Data analyzed over the years, both collected by EAS and by FPL indicate a significant portion of the G-II aquifer west of the CCS have been contaminated. Data shows the steady western migration of the saltfront in the Model Lands. See Exhibit A Figures 1-6,
- 2. Despite remedial measure implemented by FPL the saltfront continues to migrate west contaminating more of the G-II aquifer.
Data recently made available to EAS indicates the western edge of the saltfront continues to migrate west. A well monitored by EAS since 2008 became salt intruded in December of 2017. EAS provided the data and notice to the agencies. See Exhibit A Figure 7
- 3. Remedial methods used to date are not correcting the water quality violation, and proposed use of reuse water may make the conditions worse..
The methods employed by FPL to halt the movement of the saltfront are insufficient.
Additional aggressive cleanup efforts are required to correct the existing water quality violations created by the hypersaline water emanating from the Cooling Canal System at FPLs turkey point plant. It is unclear if the proposed addition of reuse water from Miami Dade Countys South Dade Wastewater treatment plant is the proper solution to address the existing contamination of the G-II aquifer or whether it will make it worse.
The actions by the various regulatory agencies to date, DERM, and FDEP have been insufficient to address the ongoing contamination of the G-II aquifer efficiently.
Edward A. Swakon, P.E. May 14, 2018 QUALIFICATIONS My resume is attached hereto as Exhibit B and contains my qualifications and includes a publications that I have authored.
PRIOR TESTIMONY During the past 4 years, I have testified and have had my deposition taken in several cases between:
Altantic Civil, Inc. v. Florida Power and Light Company, et al., Case No. 15-1746 (Florida Division of Administrative Hearings, Nov. 2-4, 2015).
COMPENSATION I am being compensated as follows for my work in this matter: $180.00 per hour.
SIGNATURE Edward A. Swakon, P.E., President EAS Engineering, Inc.
Edward A. Swakon, P.E. May 14, 2018 Exhibit A: Figures Figure 1: Increasing Conductivity over time at City of Homestead Groundwater monitoring well -01
Edward A. Swakon, P.E. May 14, 2018 Figure 2: FPL Data showing Hypersaline water 2 miles beyond limit of CCS
Edward A. Swakon, P.E. May 14, 2018 Figure 3: FPL data showing tritium (an indicator of water from the CCS) well beyond the western edge of the CCS.
Edward A. Swakon, P.E. May 14, 2018 Figure 4: The simulated position of the saltfront with and without the influence of the CCS
Edward A. Swakon, P.E. May 14, 2018 Figure 5: The simulated movement of the leading edge and hypersaline edge of the saltfront between 1998 and 2015.
Edward A. Swakon, P.E. May 14, 2018 Figure 6 FPL data showing that portion of the contaminated G-II aquifer attributable to water from the CCS by the presence of tritium.
Edward A. Swakon, P.E. May 14, 2018 Figure 7: Data provided to EAS Engineering indicating ACI-MW-o5-FS monitoring well (a well which had been fresh for since the start of monitoring in 2007) had become salt intruded.
Edward A. Swakon, P.E. May 14, 2018 Figure 8: Cover Page of 50 slide powerpoint presentation which contains additional data and exhibits indented to be used.
Edward A. Swakon, P.E. May 14, 2018 Exhibit B: Curriculum Vitae Edward A. Swakon, P.E.
President, EAS Engineering, Inc.
55 Almeria Ave.
Coral Gables, FL 33134 305-445-5553 ext. 305
Edward A. Swakon; May14, 2018 Edward A. Swakon, P.E.
President, EAS Engineering, Inc.
55 Almeria Ave.
Coral Gables, FL 33134 305-445-5553 ext. 305 Education Purdue University, B.S. in Engineering (Major Water Resources), 1975 University of Miami, RSMAS, M.S. in Ocean Engineering, 1977 Current Status Mr. Swakon is President of EAS Engineering, Inc., a firm offering comprehensive environmental permitting and engineering services to the South Florida community and the Caribbean. Activities undertaken by Mr. Swakon include assistance to local governments, land developers, attorneys, property owners and others in acquiring the necessary permits from local, state, and federal regulatory agencies. These permits include dredge and fill, coastal and freshwater wetland construction, Florida Department of Environmental Protection coastal construction control line, county and federal flood criteria variances, and other specialized permits. Mr. Swakon also specializes in applied computer modeling of various environmental situations such as waterway flow simulations, flushing studies for existing or proposed marinas, as well as groundwater and saltwater intrusion simulations. Mr. Swakon is familiar with both the Regional Planning Councils Development of Regional Impact (DRI) process and Monroe Countys Major Conditional Use process, having worked on both.
Previous Experience Before forming EAS Engineering, Inc., Mr. Swakon was Director of Environmental Permitting for a local Miami engineering firm. During that time, he personally coordinated all of the environmental permitting assignments for the firm. These activities included preparation of DRIs, numerous applications to local governments, Florida Department of Environmental Regulation and Florida Department of Natural Resources (now FDEP), and the U.S. Army Corps of Engineers. Mr. Swakon has provided services to clients such as Miami-Dade County, the City of Miami, and many local law firms such as Thomson Zeder et al., Greenberg Traurig et al., and Carlos Abbott and Ferro.
Before entering the private sector in 1984, Mr. Swakon was employed by the Dade County Department of Environmental Resources Management (DERM) in 1977, one of the largest and most widely respected local environmental organizations in the country. He served as the Chief of the Water Management Division and was responsible for all tidal and freshwater wetland permitting programs. He was also a key participant in the development of the Biscayne Bay Management Plan and the implementation of the Biscayne Bay Restoration and Enhancement Program. He worked closely with other County departments in securing permits for county projects. He was the coordinator of all the Countys efforts regarding beach restoration including the worlds largest beach 13
Edward A. Swakon; May14, 2018 restoration project, the Miami Beach project and the controversial but much needed Key Biscayne beach project. Finally, his responsibilities included the administration of the Countys drainage policies, including the county and federal flood criteria programs, and canal permitting and design.
Mr. Swakon has been retained by Miami-Dade County, the U.S. Justice Department, and private sector attorneys as an expert witness in numerous Florida administrative hearings and federal court proceedings.
Summary Mr. Swakon has a broad background in all aspects of the environmental regulatory process, having worked for both government and the private sector. He aggressively pursues all assignments with the agencies and is well-respected by their personnel. He has a proven record of success.
Publications Modeling of Tide and Wind Induced flow in South Biscayne Bay and Card Sound. SeaGrant Technical Bulletin No. 37. 1977.
Organizations Member, American Society of Civil Engineers Member, Florida Engineering Society Past President, Marine Council Marine Industries Association of South Florida South Florida Environmental Professionals American Society for Photogrammetry and Remote Sensing Previous Second Vice Chair, The Historical Association of Southern Florida Board of Directors and Past President, Executive Associations of Greater Miami Hobbies Woodworking, Golf Registration Professional Engineer #31184, Florida, July 1981 14