ML18213A546
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| ML18213A546 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/17/2018 |
| From: | Nuttle W Southern Alliance for Clean Energy, Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP |
| To: | NRC/SECY |
| SECY RAS | |
| Shared Package | |
| ML18213A528 | List: |
| References | |
| License Renewal, RAS 54385, 50-250-SLR, 50-251-SLR | |
| Download: ML18213A546 (1) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE SECRETARY
)
In the Matter of
)
Florida Power and Light Company
)
Docket Nos. 50-250, 50-251-SLR Turkey Point Units 3 and 4
)
_____________________________________)
DECLARATION OF WILLIAM K. NUTTLE, PH.D, PEeng (Ontario)
I, William K. Nuttle, Ph.D., being competent to provide this Declaration, declare as follows:
- 1. I am an eco-hydrologist with expertise in hydrogeology, hydrology, hydraulics, and water quality. I hold a Ph.D. in civil engineering from the Massachusetts Institute of Technology and I am an Environmental Consultant with the Center for Environmental Science at the University of Maryland. A copy of my curriculum vitae is attached.
- 2. I have been retained by Southern Alliance for Clean Energy, Tropic Audubon Society, and Friends of the Everglades as an expert witness in Southern Alliance for Clean Energy, et al. v. Florida Power & Light Company, No. 1:16-cv-23017-DPG in the United States District Court for the Southern District of Florida, Miami Division (CWA Lawsuit). In that lawsuit, the plaintiffs allege that Florida Power & Light Co. (FPL) has violated and is violating the federal Clean Water Act by discharging pollutants from the Turkey Point Units 3 and 4 reactors, including nutrients, hypersaline water and other chemical and radioactive contaminants, into waters of the United States in the Biscayne Bay and into the Biscayne Aquifer in violation of FPLs CWA permit.
- 3. On May 14, 2018, I submitted an Expert Report in the CWA Lawsuit regarding the hydrogeological, hydrological, and water quality characteristics of the cooling canal system (CCS) at the Turkey Point site, as well as the effectiveness of measures proposed by FPL to remediate hypersaline conditions in the CCS and Biscayne Aquifer.
The facts in my Expert Report are true and correct to the best of my knowledge, and the opinions expressed in my Expert Report are based on my best professional judgment.
I declare under penalty of perjury under the laws of the United States that the foregoing is true to the best of my knowledge.
William K. Nuttle Dated: 17 Jul 2018 SACE Hearing Request 1