ML070660273
| 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: To: Pine duBois <pine@jonesriver.org> 64,
<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 C-Executive Director rr Jones River Watershed Association PO Box 73 N) Kingston, MA 02364 www.jonesriver.org cell 781-424-0353 () Ffl Cl) CC: <hln@nrc.gov>, <arwl @nrc.gov>, <Cwenapco@aol.com>
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c\tep\Gw}00017.TMP .Page71 Mail Envelope Properties (45E5DF03.E08: 5 : 60936)
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Pilgrim SEIS- comment-JRWA Creation Date 02/28/2007 2:58:22 PM From: Pine duBois <pine@ jonesriver.org> Created By: 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 Route TWGWPO02.HQGWDO01 nrc.gov TWGWPO01 .HQGWDO01 nrc.gov TWGWPO04.HQGWDOO1 nrc.gov aol.com Files Size Date & Time MESSAGE 553 02/28/2007 2:58:22 PM JRWAPilgrimSEIScomment022807.doc 122880 Mime.822 170608 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed
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-' Formatted: Font color: Dark Blue Formatted: Font: 14 pt, Bold, Italic, l Font color: Dark Blue Chief, Rules Review and Directives Branch US Nuclear Regulatory Commission Mail Stop T6-D59 Formatted: Indent: Left: 3", First line: 0.5" Formatted: Indent: Left: 0.38" i
Washington, DC 20555-0001 Also email PilgrimEIS@nrc.gov. Re: Public Comment NUREG-1437, Supplement 29 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 -{ Deleted: where
,stuarine systems. The SEIS and other reports describe ;Jmpingement and entrainment of Deleted: regional aniitic life forms at levels that adversely irnnact the Came Cod Bay Sanctuary thrnohuo anuatic life forms at levels that adversely impact the Cane Cod Bay Sanctuary through Deleted: now caused by 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.
Deleted:, Background of Commenter I. Deleted: as well as cumulative Jones River Watershed Association [JRWA] is a Kingston based non-profit citizen group temperature rise in the Cape Cod Bay basin.1 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 - - Deleted: in 2000 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 Formatted: Font: 9 pt cooperatively with the Massachusetts Riverways Program, State Division of Marine
,' Formatted: Font: 9 pt JRWA comment to NRC on SEIS Pilgrim Nuclear Power Station re-license February 2S. 2007 1 off7 -
-- Formatted: Left: 1.13" 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 - Deleted: We have 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.
Co n ce rn s .. . . .. . . .. . . .. . . . .. . . . .. . . . .. . . .. . .. . . .. . . . .. . . . .. . . .. . . . - Deleted: --------------- Page Break.----------- JRWA is concerned that te NRC Staff has concluded, that the continued operation of the -Deleted: T cooling water system would have MODERATE impacts on the local winter flounder Deleted: sion population, and the Jones River population of Eainbow smelt and would have smalltto. D-eleted: r moderate impacts on a considerable number of other aquatic species from impingement and entrainment at PNPS -* - Deleted: is of great concern.
- 1. JRWA beli6ves that there is sufficient evidence provided through the [2004-2006 -- - Formatted: Numbered + Level: 1 +
DMF study on Rainbow Smelt to conclude that the population of smelt is Numbering Style: 1, 2, 3, ... + Start at: 1 + Alignment: Left + Aligned at: sipgnificantly reduced and therefore continued impingement at equivalent rates 0.29" + Tab after: 0.54" + Indent under an extended license as evidenced over the past thirty years at the plant will at: 0.54" have a SIGNIFICANT impact on this species. (Formatted: Font: Bold
- 2. Injaddition, JRWA is,_ concerned that other species, especially the Jones River * -- Deleted: We have Alewife and Blueback Herring have not been fully evaluated, and are being L"Deleted: al Deleted: the 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 Formatted: Font: Bold 3 system. including in the spring prior to spawning. In 1995 the Alewife was the Formatted: Font: Bold 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 - ~Deleted: populations, the American Eel and the American Striped Bass were not staff conclusion is not substantiated and should be reconsidered. The staff evaluated. Although concludes [E-105] that "Continued operation of the PNPS cooling water system 'Deleted: , 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 [Formatted: Font: Bold I 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- - Formatted: Indent: Left: 0.5", First 1 evaluated the cumulative impact of fish loss to the general fishery. In our view, line: 0.29" 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. - Formatted: Font: Bold 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: Font: 9 pt Formatted: Font: 9 pt
, I JRWA comment to NRC on SEIS Pilorim Nuclear Power Station re-license February 28. 2007 2 of7 ,
- 4. Given the staff conclusion that plant operations are likely to have Significant Formatted: Numbered + Level: 1 +
impacts on the EFH for American plaice. Atlantic cod, Atlantic mackerel, red hake, Numbering Style: 1, 2, 3, ... + Start at: 1 + Alignment: Left + Aligned at: whiting, windowpane flounder, and winter flounder, and given the tenuous 0.29" + Tab after: 0.54" + Indent sustainability of many of these species, PNPS, should not be re-licensed without at: 0.54" significant upgrades to its cooling system and substantial mitigation efforts to help Formatted: Underline 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 - I Formatted: Bullets and Numbering I 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 - Formatted: Font: Bold plant impingement and entrainment onpopulation abundance on these fish, and
[Deleted: water quality, temperature and 3 thus on long term survivability, was not adequately examined. Discussion Rainbow Smelt - Formatted: Font: Bold, No 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 - Formatted: Superscript June 15t1 to protect spawning fish. The PNPS has consistently impinged adult fish and - Formatted: Superscript 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.
- I Formatted: No underline 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 Formatted: No underline essential habitat for this population of Rainbow smelt is very likely Cape Cod Bay, with Formatted: No underline 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. - 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. Formatted: No underline )) Deleted: T A_ Formatted: Font: 9 pt ] Formatted: Font: 9 pt JRWA comment to NRC on SEIS Pilarim Nuclear Power Station re-license ornr 25 2007T Februar 28 2007 3 of7 -
Alewife (Alosapseudoharengus)ý - - Formatted: Font: Bold, No 3 The alewife was once abundant in the Jones River. Because it is the largest river in Cape Formatted: No underline 1 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 - - - Formatted: Superscript I 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
- - Deleted: its J
period, with daily counts totaline 6550 minutes of effort, a total of 278 fish were. counted in 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."
The report however.fails to discuss biomass and population sustainabilityinight .. Yp2-34l. -{Deleted: in 2-34 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 I Deleted: alewife mayWebe also believe spawning that the earlier than reported in the SEIS. 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 - --
- Deleted: b 1 eliminatesz th* risk tri thw ncmnrlntitsn of nlp~wii (nand (ithlir irninortnnt *:npo'ii" The following fish species were considered those suffering the greatest numerical Deleted: and expansion 1 Deleted:
s JJ i losses due to impingement over the last 11 years of monitoring at Pilgrim Formatted: Border: Box: (Single (Environmental Protection Group) 2005): solid line, Auto, 0.5 pt Line width) 1 Table I Atlantic Atlantic blueback rainbow silverside menhaden herring smelt , Formatted: Border: Box: (Single Isolid line, Auto, 0.5 pt Line width) 1994 36_498 58 269 1094 9,464 123__ - Formatted: Border: Box: (Single 1995 130 85 1,560 , 1,244 648 2,191 39_884 solid line, Auto, 0.5 pt Line width) 1996 16-615 2,168 2,462 1,347 3,_3728 ,_216_- Formatted: Border: Box: (Single 1997 1998 63_ 0 3 6.773 1329 1,423 424 134 405 335 1,978 1 6- , 317 158 1 solid line, Auto, 0.5 pt Line width) Formatted: Border: Box: (Single solid line, Auto, 0.5 pt Line width) 1999 8,577 42,686 550 628 875 610 Formatted: Border: Box: (Single 2000 25_665 34,354 5,919 1,105 13 2443 solid line, Auto, 0.5 pt Line width) 2001 4,987 3,599 229 517 879 16_ 8 1 Formatted: Border: Box: (Single solid line, Auto, 0.5 pt Line width)
.2002 44_30 53,304 943 1 087 335 334
_ / ,
' Formatted: Border: Box: (Single 2003 23,149 119,041 1,968 237 532 438 solid line, Auto, 0.5 pt Line width) 2004 13-107 104311 20_46 22-57 10-92 1 145 \ Formatted: Border: Box: (Single solid line, Auto, 0.5 pt Line width)
Of particular interest are the rainbow smelt. These fish are an anadromous species and ', 1Formatted: 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 Formatted: Border: Box: (Single Plymouth/Kinston/Duxbu r Bay area they are apparently quite small in comparison to solid line, Auto, 0.5 pt Line width) that from the Jones River (based on pers. comm., Brad Chase, MA Division of Marine Formatted: Border: Box: (Single Fisheries rDMF1 to Gerald Szal. DEP). Rainbow smelt are not known to reDroduce solid line, Auto, 0.5 pt Line width) elsewhere in streams entering Cape Cod Bay or in streams elsewhere on Cape Cod. Formatted: Border: Box: (Single solid line, Auto, 0.5 pt Line width) I Formatted: Font: 9 pt I 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_
- Deleted:l 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 , . {Formatted: Font: Bold seems to include fish of all age classes so it is difficult to determine without additional Formatted: Font: Bold, No study at what the age the fish are spawning. Blueback herring have different habitat \\ \ Deleted:, cc requirements, at least in the river, yet they were not discussed in the SEIS. However, c\ Deleted: preferring slightly colder and Marine Ecology Studies Related to the Operationof Pilgrim Station; Annual Report #61 moving water. for the year 2002, show that Blueback Herring were the dominate species impinged in Deleted: about November that year and fifth in rank for the year. (Table 5) Yet this species is not Deleted: 1 evaluated in the SEIS.
- Formatted: Font: Bold Sand Tiger Shark (Odontaspis Taurus) - Formatted: Font: Italic 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.
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. ....
- Formatted: Font: Bold, No Mitigating aquatic population loss is different from requiring mitigation of water quality Formatted: Font: Bold 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 Formatted: Font: 9 pt overcome adversity. A hatchery mitigation and release plan cannot become a license to kill 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. NON-fish related comments on SEIS Formatted: underline K.............................. Formatted: Font: Bold, No Availability of Materials Formatted: No underline Raw daýta and original reports are needed to provide in dependent _ evaluation -of the -I conclusions reached by the staff. JRWA was not provided with monitoring data and Formatted: No underline reports, and found it was dissatisfied with the synopsis of data provided in the SEIS. Wh en Formatted: No underline multiple reports were available, general data reporting did not seem to agree (i.e. Szal an d Formatted: No underline Pilgrim Report #61). We request that, raw data and the monitoring reports required by th e Formatted: No underline NPDES permit be made available., We request that these documents be on deposit at loc Formatted: No underline libraries, and/or that they be made available on-line. Formatted: No underline Formatted: No underline 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 hacal Formatted: No underline Deleted: I the conclusions of others to evaluate. Although the SEIS is instructive, conclusions made American Eell are impossible to evaluate without the benefit of the original material. As studies and 'I Striped Bass¶ re orts are roduced we reauest a public repository contain information. monitoring dat rencsrtc nrP nrcsdicdllPP" x".q/ I and environmental impact assessments of whatever nature, relative to PNPS Sand Tiger Sharkil I Rainbow smelt¶ S Other environmental imnacts Winter Flounder]l ,Water Supply,: Silver Lake, American Lobster] JRWAbriefly reviewed other aspects of the report, including 2.2.8.2 Public Services. EFH re water temperatur The "Selected Plymouth County Public Water Supply Systems and Capacities in 2003" Formatted: Font: Bold, No ignores the largest water supply in the county, the surface water reservoir at Silver Lake. Formatted: No underline Silver Lake is 640 acres, and is iust beyond the 10 mile EPZ in the towns of Kingston. Formatted: Font: Bold, No 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 Formatted: Font: Bold, No should be regularly monitored for radiological pollution. - Formatted: No underline Deleted: el Screens, mitigation, alternative cooling Strontium in Groundwater: Municipal wells, from undersea waterl USGS performed water quality analysis of regional drinking water wells in 2005 in Silver Lake Surface water supply, radiological monitoring: Brockton response to an EPA general program. The presence of Strontium was included in the I' ~ \\ withdrawal of 10mgd-social justice I' analysis, and results were provided by weight-without discussion of radioactivity. The II community highest levels of Strontium in the region were found in the Kingston Millgate well. I' Formatted: No underline Discussion with USGS confirmed that the level was high, and that no lab notes provided a Formatted: Font: Bold, No further descrintion regarding any analysis for radioactive. Strontiuim-90. Formatted: No underline JRWA believes that off -site sampling of groundwater should be included to assess Formatted: Font: 9 pt impacts from past and present radioactive venting of gases at Pilgrim. Radiological Formatted: Font: 9 pt
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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. - - Formatted: No underline I 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 - Formatted: Font: Bold, Underline 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.
Respectfully submitted, Pine duBois Executive Director Formatted: Font: 9 pt J
' Formatted: Font: 9 pt JIRWA comment to NRC on SEIS Pilprim Nuclear Power Station re-license February 28. 200)7 7 of7}}