ML18213A548

Attachment 13: Larry Brand Declaration

ML18213A548
Person / Time
Site:	Turkey Point
Issue date:	07/26/2018
From:	Brand L Southern Alliance for Clean Energy, Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP
To:	NRC/SECY
SECY RAS
Shared Package
ML18213A528	List: ML18213A529 ML18213A530 ML18213A531 ML18213A532 ML18213A533 ML18213A534 ML18213A535 ML18213A536 ML18213A537 ML18213A540 ML18213A545 ML18213A546 ML18213A547 ML18213A548 ML18213A549 ML18213A550 ML18213A551 ML18213A552 ML18213A553 ML18213A554
References
License Renewal, RAS 54385, 50-250-SLR, 50-251-SLR
Download: ML18213A548 (1)

Text

SACE Hearing Request Attachment 13 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 LARRY E. BRAND, PH.D.

I, Larry E. Brand, Ph.D., being competent to provide this Declaration, declare as follows:

1. I am a marine biologist and ecologist with expertise in phytoplankton ecology, Harmful Algal Blooms and nutrients. I hold a Ph.D. in Biological Oceanography from the Woods Hole Oceanographic Institution/Massachusetts Institute of Technology Joint Program. I am a Professor of Marine Biology and Ecology at the Rosenstiel School of Marine and Atmospheric Science at the University of Miami. 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 nuclear 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 nutrients being released from the cooling canal system (CCS) at the Turkey Point site into surrounding waters. I understand my Expert Report will be submitted in this proceeding.

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.

_______________________________

Larry Brand Dated: 7-26-18