ML070660273

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Comment (11) of Pine Dubois on Behalf of Jones River Watershed Association on NRCs NUREG-1437, Supplement 29 Draft Report Regarding Pilgrim Nuclear Power Station
ML070660273
Person / Time
Site: Pilgrim
Issue date: 02/28/2007
From: Dubois P
Jones River Watershed Association
To:
NRC/ADM/DAS/RDB
References
71FR75280 00011
Download: ML070660273 (9)


Text

{{#Wiki_filter:.Doris M~ndio1a.- Pi!grim SEIS-comment-JRWA Piae--TI From: Pine duBois <pine@jonesriver.org> To: <PilgrimEIS@nrc.gov> Date: 02/28/2007 2:59:16 PM

Subject:

Pilgrim SEIS-comment-JRWA Hello: Please accept the attached comment from the Jones River Watershed Association in Kingston Ma. on the NRC's Supplement 29 Draft Report regarding Pilgrim Nuclear Power Station. Kindly confirm receipt. I will mail a hard copy. Thank you for the opportunity and keeping us informed of any developments regarding this project. I am available by email to address any questions you have regarding our. comments. Pine duBois Executive Director Jones River Watershed Association PO Box 73 Kingston, MA 02364 www.jonesriver.org cell 781-424-0353 64, N) C-rr () Ffl Cl) CC: <hln@nrc.gov>, <arwl @nrc.gov>, <Cwenapco@aol.com> -69 3 6 c) -U ~7 A2e~-~-~'e~4'> ~

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Creation Date From: Created By: Pilgrim SEIS-comment-JRWA 02/28/2007 2:58:22 PM Pine duBois <pine@ jonesriver.org> pine @jonesriver.org Recipients nrc.gov TWGWPO02.HQGWDOO1 PilgrimEIS nrc.gov TWGWPO01.HQGWDOO1 HLN CC (Harriet Nash) nrc.gov TWGWPO04.HQGWDOO1 ARWI CC (Alicia Williamson) aol.com Cwenapco CC Post Office TWGWPO02.HQGWDO01 TWGWPO01.HQGWDO01 TWGWPO04.HQGWDOO1 Route nrc.gov nrc.gov nrc.gov aol.com Files Size MESSAGE 553 JRWAPilgrimSEIScomment022807.doc Mime.822 170608 Date & Time 02/28/2007 2:58:22 PM 122880 Options Expiration Date: Priority: ReplyRequested: Return Notification: Concealed

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New Roman, Bold, Font color: Dark ' L Blue -' Formatted: Font color: Dark Blue Formatted: Font: 14 pt, Bold, Italic, l Font color: Dark Blue i Chief, Rules Review and Directives Branch US Nuclear Regulatory Commission Mail Stop T6-D59 Washington, DC 20555-0001 Also email PilgrimEIS@nrc.gov. Re: Public Comment NUREG-1437, Supplement 29 Formatted: Indent: Left: 3", First line: 0.5" i Summary of Comment As soon as the best method can be determined, and prior to any extension of permit or license for operation, the salt water intake and discharge for the once-through cooling system at Pilgrim Nuclear Power Station must be retrofitted to avoid if possible, and mitigate a.snecessary, adverse impacts to the aquatic populations of Cape Cod Bay and its ,stuarine systems. The SEIS and other reports describe ;Jmpingement and entrainment of aniitic life forms at levels that adversely irnnact the Came Cod Bay Sanctuary thrnohuo Formatted: Indent: Left: 0.38" -{ Deleted: where Deleted: regional Deleted: now caused by Deleted:, anuatic life forms at levels that adversely impact the Cane Cod Bay Sanctuary through unacceptable reduction in fish populations, especially populations of Rainbow smelt, Alewife, Blueback herring, winter flounder. Atlantic mackerel, Atlantic cod, and other fish important to the ecosystem function and balance of the bay as a whole, and to the Jones River in particular. Background of Commenter Jones River Watershed Association [JRWA] is a Kingston based non-profit citizen group that advocates for the waters, natural habitats and environmental resources of the Jones River and Cape Cod Bay ecosystem. The group was established in 1985 to address impacts from the diversion of the Jones River headwaters, Silver Lake, by the City of Brockton for water supply, and years later expanded its mission to include-protection and restoration of the natural resources of Cape Cod Bay. In 2003 JRWA established Jones River Landing Environmental Heritage Center in the Jones River estuary in order to provide education and long term stewardship of the aquatic resources of Jones River and Cape Cod Bay. A primary goal is to reestablish the Alewife and Blueback herring run throughout the Jones River to enable their spawning in Silver Lake, and to improve habitat conditions in the Jones River for native and diadromous fish species including Rainbow smelt, Alewife and Blueback herring. American and Hickory Shad, White perch, American eel and others. To accomplish this we address stream flow issues, water quality, habitat degradation, stormwater management, and provide volunteer monitoring for certain species which at this time include the river herring, smelt and juvenile American lobster. We have also conducted macroinvertebrate and fish inventories in the river system. We work cooperatively with the Massachusetts Riverways Program, State Division of Marine Deleted: as well as cumulative temperature rise in the Cape Cod Bay basin.1 I. Deleted: in 2000 Formatted: Font: 9 pt Formatted: Font: 9 pt JRWA comment to NRC on SEIS Pilgrim Nuclear Power Station re-license February 2S. 2007 1 off7 -

Fisheries [DMF1, Coastal Zone Management [CZM1, The Lobster Conservancy in Maine and recently with the Provincetown Center for Coastal Studies. We are active members of the Watershed Action Alliance of Southeastern Massachusetts, the Taunton River Campaign, and the Massachusetts Instream Flow Task Force. Jn 2006, we established a long term water quality monitoring station at Jones River Landing and work with DMF on the annual monitoring of Rainbow Smelt. Jones River is the largest river draining to Cape Cod Bay and provides important estuarine habitats and functions to support a diverse array of aquatic and avian life. C o n c e r n s JRWA is concerned that te NRC Staff has concluded, that the continued operation of the cooling water system would have MODERATE impacts on the local winter flounder population, and the Jones River population of Eainbow smelt and would have smalltto. moderate impacts on a considerable number of other aquatic species from impingement and entrainment at PNPS

1. JRWA beli6ves that there is sufficient evidence provided through the [2004-2006 DMF study on Rainbow Smelt to conclude that the population of smelt is sipgnificantly reduced and therefore continued impingement at equivalent rates under an extended license as evidenced over the past thirty years at the plant will have a SIGNIFICANT impact on this species.
2. Injaddition, JRWA is,_ concerned that other species, especially the Jones River Alewife and Blueback Herring have not been fully evaluated, and are being severely impacted by plant operations. Annually hundreds, and at times tens of thousands of this fish are impinged, and have been found in the plant cooling system. including in the spring prior to spawning. In 1995 the Alewife was the dominant fish impinged, while the Rainbow smelt have been dominant at least two years.

3Essential Fish Habitat was evaluated for many species, JRWA is concerned that the staff conclusion is not substantiated and should be reconsidered. The staff concludes [E-105] that "Continued operation of the PNPS cooling water system was determined to have a minimal adverse effect on EFH for 17 species, a less than substantial adverse effect on EFH for 8 species, and a substantial adverse effect on EFH for 7 species".... (emphasis added) And goes on to conclude: "Within the overall Cape Cod Bay ecosystem,... continued operation of the PNPS cooling water system would have a minimal adverse effect on EFH." We believe this is a wholly unsubstantiated conclusion because the staff has not- - evaluated the cumulative impact of fish loss to the general fishery. In our view, because Rainbow smelt, Alewife, Atlantic menhaden, Atlantic mackerel, Atlantic silverside, Blueback herring and winter flounder are important prey for Striped bass and Atlantic cod (as examples). the loss of sufficient populations of these smaller fish will ultimately impact on the population of the more valued Striped bass and cod-and therefore is a matter of great concern, that should not be dismissed. Many of the fish suffering large losses are now highlighted for dangerously low population levels (river herring, smelt, and menhaden) in the region although no NMFS management plan yet exists. Formatted: Left: 1.13" Deleted: We have Deleted: --------------- Page Break.----------- -Deleted: T Deleted: sion D-eleted: r Deleted: is of great concern. Formatted: Numbered + Level: 1 + Numbering Style: 1, 2, 3,... + Start at: 1 + Alignment: Left + Aligned at: 0.29" + Tab after: 0.54" + Indent at: 0.54" (Formatted: Font: Bold

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Formatted: Font: Bold - ~Deleted: populations, the American Eel and the American Striped Bass were not evaluated. Although 'Deleted:, [Formatted: Font: Bold I Formatted: Indent: Left: 0.5", First 1 line: 0.29" Formatted: Font: Bold Formatted: Font: 9 pt Formatted: Font: 9 pt JRWA comment to NRC on SEIS Pilorim Nuclear Power Station re-license February 28. 2007 I 2 of7

4. Given the staff conclusion that plant operations are likely to have Significant impacts on the EFH for American plaice. Atlantic cod, Atlantic mackerel, red hake, whiting, windowpane flounder, and winter flounder, and given the tenuous sustainability of many of these species, PNPS, should not be re-licensed without significant upgrades to its cooling system and substantial mitigation efforts to help restore areas, such as salt marshes and spawning habitats in the Cape Cod Bay region that can help boost survivability of PNPS affected species.
5. In the same way that there is concern for the EFH for fisheries determined by NOAA to require Management Plans pursuits to the Magnuson-Stevens Act, so too should there be concern for the habitats essential to fish species that are experiencing precipitous population decline such as the Rainbow smelt, Alewife and Blueback herring, among others-- the cumulative impact resulting from the -

plant impingement and entrainment onpopulation abundance on these fish, and thus on long term survivability, was not adequately examined. Formatted: Numbered + Level: 1 + Numbering Style: 1, 2, 3,... + Start at: 1 + Alignment: Left + Aligned at: 0.29" + Tab after: 0.54" + Indent at: 0.54" Formatted: Underline I Formatted: Bullets and Numbering I Formatted: Font: Bold [Deleted: water quality, temperature and 3 Discussion Rainbow Smelt In 2004 the National Marine Fisheries Service (NOAA) listed Osmerus mnordLax as a Species of Concern Designation.The fishery is closed by regulation from March 1 5 h to June 15t1 to protect spawning fish. The PNPS has consistently impinged adult fish and entrained eggs and larvae. Impinged fish have low survivability, and has occurred every year with some dominant years. NMFS apparently does not yet have an assessment of the impact of PNPS on the population of Rainbow smelt. JRWA is very concerned about the decline in smelt population in the Jones River. Formerly the Jones sponsored the largest smelt run in Massachusetts, [DMF Report 1928]. and now it is a mere shadow of that past. Significant impingement events have periodically occurred at PNPS and can be directly associated as a cause of the decline in the Jones. The essential habitat for this population of Rainbow smelt is very likely Cape Cod Bay, with PNPS as the largest negative influence. Smelt generally live less than I mile from shore and in water less than 19ft deep. Given that an estimated 76% of the species is preyed upon annually by other fish and birds (NOAA.gov information sheet), loss of this food source could have a significant impact on other species. While the SEIS and staff report a potential MODERATE cumulative impact on the smelt, there is no reasonable discussion that this impact would have on a broader range of species. Formatted: Font: Bold, No Formatted: Superscript Formatted: Superscript - I Formatted: No underline Formatted: No underline Formatted: No underline - 4Formatted: No underline I JRWA is of the opinion that the present low population numbers of Rainbow smelt, the designation of Special Concern by NMFS. and the ongoing impingement of adults as well as entrainment of eggs and larvae, including occasional dominant species impingement events at PNPS, is sufficient reason for NRC to determine that continued operation of the once through cooling as now configured will have a SIGNIFICANT and potentially catastrophic impact on the remaining population-and that this impact is NOT acceptable. A_ Formatted: No underline Deleted: T Formatted: Font: 9 pt Formatted: Font: 9 pt ))] JRWA comment to NRC on SEIS Pilarim Nuclear Power Station re-license ornr 25 2007T 3 of7 - Februar 28 2007

Alewife (Alosapseudoharengus)ý The alewife was once abundant in the Jones River. Because it is the largest river in Cape Cod Bay, at least potentially, the Jones is one of the largest spawning areas. The Jones River run sees migrating fish by April 1st with the run lastinz into June. Now, monitoring for this and he related Blueback herring, show dismal population counts. JRWA will perform its third annual herring count this spring. In 2006, during the April and May period, with daily counts totaline 6550 minutes of effort, a total of 278 fish were. counted in Formatted: Font: Bold, No Formatted: No underline Formatted: Superscript Deleted: its 31 I J Deriod with dailv counts totaling 6550 minutes of effort a total of 278 fish were counted in the Jones River. This is only slightly more than the mean number of fish impinged by PNPS between 190 and 2001. In a sinole event in 1Q95. 13.100 Alewife were imninoed. while the total for the year, according to Pilgrim'. approaches 27,000. However, a DEP Memo of Gerald Szal of August 2005, puts the number closer to 40,000. (see box below) "Over the last 25 years they (alewife) have the third highest impingement rate at PNPS." Yp2-34l. The report however.fails to discuss biomass and population sustainabilityinight.. of this high impingement rate,,. JRWA is of the opinion that the impingement factor at PNPS may well be having an adverse impact on the species survivability in the Jones River and Cape Cod By region. Plant continuationpust be-conditioned on an upgraded and improved cooling water intake and discharge, or an alternative cooling systerm~that - eliminatesz th* risk tri thw ncmnrlntitsn of nlp~wii (nand (ithlir irninortnnt *:npo'ii" -{ Deleted: in 2-34 I Deleted: We also believe that the alewife may be spawning earlier than reported in the SEIS. Deleted: b Deleted: and expansion 1 Deleted: s 1 i The following fish species were considered those suffering the greatest numerical losses due to impingement over the last 11 years of monitoring at Pilgrim (Environmental Protection Group) 2005): 1 Table I Atlantic Atlantic blueback rainbow silverside menhaden herring smelt 1994 36_498 58 269 1094 9,464 123_ 1995 130 85 1,560 1,244 648 2,191 39_884 1996 16-615 2,168 2,462 1,347 3,_3728 ,_216_- 1997 63_ 0 3 1329 424 405 1,978 317 1998 6.773 1,423 134 335 1 6-158 1999 8,577 42,686 550 628 875 610 2000 25_665 34,354 5,919 1,105 13 2443 2001 4,987 3,599 229 517 879 16_ 1 8 .2002 44_30 53,304 943 1 087 335 334 / 2003 23,149 119,041 1,968 237 532 438 2004 13-107 104311 20_46 22-57 10-92 1 145 Of particular interest are the rainbow smelt. These fish are an anadromous species and ', J J Formatted: Border: Box: (Single solid line, Auto, 0.5 pt Line width) , Formatted: Border: Box: (Single Isolid line, Auto, 0.5 pt Line width) - Formatted: Border: Box: (Single solid line, Auto, 0.5 pt Line width) Formatted: Border: Box: (Single solid line, Auto, 0.5 pt Line width) 1 Formatted: Border: Box: (Single solid line, Auto, 0.5 pt Line width) Formatted: Border: Box: (Single solid line, Auto, 0.5 pt Line width) Formatted: Border: Box: (Single solid line, Auto, 0.5 pt Line width) Formatted: Border: Box: (Single solid line, Auto, 0.5 pt Line width) \\ Formatted: Border: Box: (Single solid line, Auto, 0.5 pt Line width) 1 Formatted: Border: Box: (Single solid line, Auto, 0.5 pt Line width) Formatted: Border: Box: (Single solid line, Auto, 0.5 pt Line width) Formatted: Border: Box: (Single solid line, Auto, 0.5 pt Line width) Formatted: Border: Box: (Single solid line, Auto, 0.5 pt Line width) smelt impinged at Pilgrim most probably come from the Jones River population. AlthouQh there are two other rainbow smelt runs (Town Brook and Eel River) in the Plymouth/Kinston/Duxbu r Bay area they are apparently quite small in comparison to that from the Jones River (based on pers. comm., Brad Chase, MA Division of Marine Fisheries rDMF1 to Gerald Szal. DEP). Rainbow smelt are not known to reDroduce elsewhere in streams entering Cape Cod Bay or in streams elsewhere on Cape Cod. I Formatted: Font: 9 pt Marine Ecology Studies Related to the Operation of Pilgrim Station Annual Report #61 :April 29,2003, p. 17 Formatted: Font: 9 pt JRWA comment to NRC on SEIS Pilgrim Nuclear Power Station re-license February 28. 2007 4 of'7_ I

JBlueback Herring (Alosa aestivalis) Blueback herring spawn in the Jones River during the same general period as the alewife, ,1he spawning _ migration begins ",_Aprifor river herring and extends into June. The run seems to include fish of all age classes so it is difficult to determine without additional study at what the age the fish are spawning. Blueback herring have different habitat requirements, at least in the river, yet they were not discussed in the SEIS. However, Marine Ecology Studies Related to the Operation of Pilgrim Station; Annual Report #61 for the year 2002, show that Blueback Herring were the dominate species impinged in November that year and fifth in rank for the year. (Table 5) Yet this species is not evaluated in the SEIS. Sand Tiger Shark (Odontaspis Taurus) This animal is not mentioned in the SEIS, which we bring attention to here, as it is designated by NMFS as a Species of Concern Designation, and it has been caugzht and tagged over the past two years in the Jones River estuary. From evidence of the fish caught, we know that the sand tiger feeds on striped bass, and we know that Striped bass feed on smelt, herring and menhaden, etc. Deleted:l {Formatted: Font: Bold Formatted: Font: Bold, No \\\\ cc c\\ \\ Deleted:, Deleted: preferring slightly colder and moving water. Deleted: about Deleted: 1 Formatted: Font: Bold Formatted: Font: Italic We are concerned as we have stated above, that the SEIS has so segmented its analysis of the impact on fisheries as to lose sight on the general and cumulative impact upon the web of fish in the food chain. Ecosystem analysis requires that the operation is evaluated against broad impacts to Cape Cod Bay populations and habitats as well as upon the 66 or species of fish impinged and entrained by plant operations. We do not know enough about Cape Cod Bay and its dependent species to be confident in the assessment that MODERATE imnacts on smelt and winter flounder are only that. and can be isnored. Mitigation..... Mitigating aquatic population loss is different from requiring mitigation of water quality impacts, which the NRC staff state is beyond its jurisdiction to regulate. However, direct kill rate of species is distinct from water quality degradation that impairs habitat and as a result, affects fish. Here we must address the systematic damage to species that, over time, results in a loss in the environment that could significantly impair the ability of other species to survive-and thus NRC should require mitigation. At this time we know that Rainbow smelt, river herring. Atlantic mackerel, winter flounder, Atlantic cod and other fish impacted by the plant are troubled by declining numbers, while some, like the cod, have FMP, others are listed as Special Concern. Impacts of the Pilgrim plant upon these species should be avoided, and if they are not, those impacts must be mitigated so as to not lose important fish populations. Retrofits to the intake and discharge structure should be required to avoid fish kills. That PNPS is supporting hatchery release of winter flounder, is not itself sufficient to address all the impacts to fish and aquatic organisms. In fact, hatchery fish may not even be good mitigation for winter flounder, as over time the genetic pool of the species may become so nan-ow as to threaten the ability of the Cape Cod Bay flounder to adapt, or overcome adversity. A hatchery mitigation and release plan cannot become a license to kill

  • Formatted: Font: Bold, No Formatted: Font: Bold Formatted: Font: 9 pt Formatted: Font: 9 pt JRWA comment to NRC on SEIS Pilgrim Nuclear Power Station re-license February 28. 2007 50of 7,_

flounder, nor can a program for growing winter flounder for release into the wild address the impacts to the other species of fish, such as Rainbow smelt, Alewife, Blueback herring and Atlantic mackerel or menhaden. It should be required that PNPS assist these populations of concern by correcting its flawed intake structure and assist in habitat restoration activities in the reuion. Formatted: Font: Bold Deleted: ---either in terms of exploitation/sustainability or EFH. Formatted: underline NON-fish related comments on SEIS K.............................. Availability of Materials Raw daýta and original reports are needed to provide in _ dependent evaluation -of the conclusions reached by the staff. JRWA was not provided with monitoring data and -I reports, and found it was dissatisfied with the synopsis of data provided in the SEIS. Wh multiple reports were available, general data reporting did not seem to agree (i.e. Szal an Pilgrim Report #61). We request that, raw data and the monitoring reports required by th NPDES permit be made available., We request that these documents be on deposit at loc libraries, and/or that they be made available on-line. JRWA does not present itself as an expert on any of these matters. However, we were limited in our ability to get assistance for review and investigation given that we only hac the conclusions of others to evaluate. Although the SEIS is instructive, conclusions made are impossible to evaluate without the benefit of the original material. As studies and rencsrtc nrP nrcsdicdllPP" x".q/reauest a public repository contain information. monitoring dat en d e al S Formatted: Font: Bold, No Formatted: No underline Formatted: No underline Formatted: No underline Formatted: No underline Formatted: No underline Formatted: No underline re orts are roduced we and environmental impact assessments of whatever nature, relative to PNPS Other environmental imnacts Formatted: No underline Formatted: No underline Formatted: No underline Deleted: I American Eell 'I Striped Bass¶ I Sand Tiger Sharkil I Rainbow smelt¶ Winter Flounder]l American Lobster] EFH re water temperatur ,Water Supply,: Silver Lake, JRWAbriefly reviewed other aspects of the report, including 2.2.8.2 Public Services. The "Selected Plymouth County Public Water Supply Systems and Capacities in 2003" ignores the largest water supply in the county, the surface water reservoir at Silver Lake. Formatted: Font: Bold, No Formatted: No underline Formatted: Font: Bold, No Silver Lake is 640 acres, and is iust beyond the 10 mile EPZ in the towns of Kingston. Pembroke, Plympton and Halifax. It is the primary water supply for nearly 100.000 user in Brockton and Whitman. At this time an average of about 10 million gallons a day are Formatted: No underline piped to those communities. Brockton qualifies as a social justice community. Silver Lake should be regularly monitored for radiological pollution. Formatted: Font: Bold, No Formatted: No underline Strontium in Groundwater: Municipal wells, USGS performed water quality analysis of regional drinking water wells in 2005 in response to an EPA general program. The presence of Strontium was included in the analysis, and results were provided by weight-without discussion of radioactivity. The highest levels of Strontium in the region were found in the Kingston Millgate well. Discussion with USGS confirmed that the level was high, and that no lab notes provided a I' ~ I' II I' \\\\ Deleted: el Screens, mitigation, alternative cooling from undersea waterl Silver Lake Surface water supply, radiological monitoring: Brockton withdrawal of 10mgd-social justice community further descrintion regarding any analysis for radioactive. Strontiuim-90. Formatted: No underline Formatted: Font: Bold, No Formatted: No underline Formatted: Font: 9 pt Formatted: Font: 9 pt JRWA believes that off -site sampling of groundwater should be included to assess impacts from past and present radioactive venting of gases at Pilgrim. Radiological JlRWA comment to NRC on _SlS_ Pilgrimn Nuclear Power Station re-license February 28. 2007 / 6 of'/__,

monitoring does not include this human and environmental exposure pathway. Ingestion of Strontium-90 is tolerated at MUCH lower doses than airborne exposure. JRWA believes that off -site sampling of regional groundwater should be included to assess impacts from past and present radioactive venting of gases at Pilgrim. Radiological monitoring does not include this type of sampling and the exposure pathway to residents of the area is direct. Dangerous levels of dosing are entirely possible, and have the potential to be long lasting. In the USGS testing, only a few representative wells were sampled and analyzed. The Millgate well is supplied by groundwater which, if not used in drinking water distribution, will ultimately flow to the Jones River. Groundwater in areas of Plymouth flows to Cape Cod Bay. JRWA requests that PILGRIM and NRC test for the presence of Strontium-90 in regional groundwater. The Evacuation Plans have been removed from Kingston Public Library-the only documents relative to nuclear power are the NRC newsletters. This is not acceptable. Terminology needs be explained. Such key language as "significant". "moderate". "less than substantial", "minimal adverse" need qualifying definitions in order to understand the implications of the SEIS. ,Conclusion JRWA is concerned that the adverse environmental impact from impingement and entrainment at PNPS of fish and aquatic organisms that depend on Cape Cod Bay and the Jones River estuary is so severe as to require a change to the once-through cooling system, or a halt to plant operations. No re-licensing should occur without change to a closed-loop cooling system or better available technology. Further, the evidence suggests that impacts to fisheries over the past thirty years have been instrumental in causing declines in fish species populations-especially Rainbow smelt, Alewife, Blueback Herring, as well as winter flounder and others-and therefore, substantial increase in mitigation strategies must be required. - - Formatted: No underline I - Formatted: Font: Bold, Underline Respectfully submitted, Pine duBois Executive Director Formatted: Font: 9 pt Formatted: Font: 9 pt J JIRWA comment to NRC on SEIS Pilprim Nuclear Power Station re-license February 28. 200)7 7 of7}}