ML18213A549

Attachment 14: Edward Swakon Declaration

ML18213A549
Person / Time
Site:	Turkey Point
Issue date:	06/29/2018
From:	Swakon E A 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: ML18213A549 (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 EDWARD A. SWAKON, P.E. I, Edward A. Swakon, P.E., being competent to provide this Declaration, declare as follows:

1. I am an ocean engineer with expertise in environmental engineering and water managemen t. I hold a Master's Degree in Ocean Engineering from the University of Miami and a B.S. in Engineering from Purdue University. I am President of EAS Engineering, Inc., a firm offering comprehensive environmental permitting and engineering services to the South Florida community and the Caribbean. 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 FPL's CWA permit. 3. On May 14, 2018, I submitted an Expert Report in the CWA Lawsuit regarding the effects of the Turkey Point cooling canal system ("

CCS") on the dynamics of fresh water and saltwater in the region and the likely effectiveness of remediation measures proposed by FPL. 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.

6/29/2018 Edward A. Swakon Dated: